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Texture, Strain, and Stress
Michael Gharghouri
Canadian Neutron Beam Centre
Summer School 2011
Outline
• Texture – what it is, how we measure it, how we represent it.
• Definitions of Strain and Stress
• Measuring strain by diffraction
• Residual strain mapping
• In-situ deformation experiments
• In-situ welding – strategies for following dynamic processes
Most engineering materials are made up of a collection of crystallites (grains), each characterized by the orientation of the unit cell.
The distribution of grain orientations is referred to as the texture of the material.
Crystallographic Texture: The extremes and the middle ground
Single Crystal
Textured
Powder
Diffraction Fundamentals: Bragg's Law
$k = \text{incident wave vector}$
$k' = \text{scattered wave vector}$
$Q = \text{scattering vector}$
(normal to the reflecting planes and parallel to the bisector of the incident and scattered beams)
$\|k\| = \|k'\| = 2\pi / \lambda$
Diffraction is an interference phenomenon, NOT a reflection phenomenon.
Constructive interference occurs when $n\lambda = 2d \sin \theta$.
For each (hkl) there is a corresponding $d$-spacing, and a corresponding scattering angle $2\theta$ that satisfies Bragg’s Law.
**A1–1 Plane spacings.** The value of $d$, the distance between adjacent planes in the set $(hkl)$, may be found from the following equations.
*Cubic:*
$$\frac{1}{d^2} = \frac{h^2 + k^2 + l^2}{a^2}$$
*Tetragonal:*
$$\frac{1}{d^2} = \frac{h^2 + k^2}{a^2} + \frac{l^2}{c^2}$$
*Hexagonal:*
$$\frac{1}{d^2} = \frac{4}{3} \left( \frac{h^2 + hk + k^2}{a^2} \right) + \frac{l^2}{c^2}$$
The intensity of a diffraction peak depends on the volume of material correctly oriented according to Bragg's Law.
Measuring Texture
- By rotating a specimen, crystallites with plane-normals in different directions rotate through the scattering vector.
- Rotate the specimen over a full hemisphere of orientations to obtain complete (100) pole figure.
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[010] → [100]
R
T
By rotating a specimen, crystallites with plane-normals in different directions rotate through the scattering vector.
Rotate the specimen over a full hemisphere of orientations to obtain complete (100) pole figure.
Sample “Rocks”
Single Crystal
Textured
Powder
Incident Beam
Scattered Beam
$2\theta_{(100)}$
Stereographic projection
R N T
R N T
Stereographic projection
R N T
R T N
Stereographic projection
R N T
R N T
Stereographic projection
Wulff net
Measuring Texture
{100} reflection
\[ \chi = 0 \]
\[ 0 < \eta < 360 \]
\[ \chi = 30 \]
\[ 0 < \eta < 360 \]
\[ \chi = 90 \]
\[ 0 < \eta < 360 \]
\[ 2\theta \text{ constant – same crystallographic plane} \]
From Discovery to Innovation...
Orientation density functions
- By fitting spherical harmonics to pole figures, we can calculate orientation density functions (ODF's).
- The ODF tells us what fraction of grains have an orientation between $\alpha$ and $\alpha + d\alpha$.
Orientation density functions
• A single pole figure usually is not enough!
• Each point on a pole figure corresponds to a family of grain orientations – those with a particular crystal direction aligned with \( \mathbf{Q} \)
Orientation density functions
- Cubics – need 1 pole figure
- HCP's – need at least 2 pole figures
- In general, more is better
Cubics – need 1 pole figure
HCP's – need at least 2 pole figures
In general, more is better
CENTRE IS Z
CONTOUR SEPARATION: 0.25 x RANDOM
Deep drawing of Aluminum cans
A disc of Al is drawn into a die to form a can.
Preferred orientations of crystallites in the disc may create anisotropic yield surfaces.
Ears develop. The highly-automated canning-line is shut down when a large-eared can gets stuck.
Rolled-Sheet Texture of Al Disc
- The initial sheet material used to form disc has a strong rolling texture.
- Earing can be related to this initial texture.
- Carry out a systematic investigation of process route changes designed to reduce texture, or produce a more favourable texture.
• SiC whiskers in an extruded Al-2124 plate
• Whisker axes are preferentially oriented parallel to the extrusion axis – how well?
• 2 choices:
– Painstaking optical metallographic analysis
– Neutron diffraction
At first glance, ND shouldn’t really work
- In a perfect diamond cubic structure, there is no way to distinguish between <111>-type directions.
- Fortunately, SiC whiskers are made up of a stack of ~20 nm thick lamellae separated by stacking faults.
- This has a strong effect on line shape (width)
- Long range order of {111} planes normal to the whisker axis is preserved
- Long range order of {111} planes at any other angle to the whisker axis is broken
\[ \begin{align*}
\langle 111 \rangle & \\
\langle 111 \rangle & 70.53^\circ \\
& 70.53^\circ \langle 111 \rangle
\end{align*} \]
SiC line shapes
Neutron Counts / $10^3$
Scattering Angle (Degrees)
$\lambda = 0.150 \text{ nm}$
SiC pole figures
$\chi$ - angle from extrusion axis
$\eta$ - rotation about normal direction
Neutron Counts / $10^3$
Scattering Angle (Degrees)
$\{111\}$
$\langle 111 \rangle$
70.53°
70.53°
CENTRE IS N
CONTOURS IN POWERS OF TWO
Magnetic shape memory alloys show magnetically induced strains
- Higher strains, lower forces than magnetostrictive materials
- Comparable strains but higher frequencies than conventional shape memory alloys
- No two-way effect -> need a restoring force
- NiMnGa based alloys are very brittle
Embed MSM alloy particles in a polymer matrix
- Polymer matrix protects the particles from the environment
- Brittleness is overcome
- Polymer matrix provides the necessary restoring force
Magnetic Shape Memory Alloy - Polymer Composites
- MSM alloy – orthorhombic structure
- The shortest of [100], [010], [001] is the magnetic easy axis
- Need to align the particles in the matrix to see an appreciable MSM effect
- Solidify the polymer/MSM particle mixture in a strong magnetic field
- Easy magnetic axis aligns with the magnetic field
See R. Ham-Su, M4-B1
Magnetic Shape Memory Alloy - Polymer Composites
- Can we get a good signal with so much hydrogen?
- Yes -> Ni is a very strong coherent scatterer
Composites show a clear crystallographic texture. The easy axis of magnetization is preferentially aligned along the cylinder’s axis.
\[ \text{composite sample} \]
Microstructural Homogeneity or Not
Neutron (0002) intensity vs. circumferential position at fixed radius in Ti-alloy impeller
Forging process of original billet, resulted in 4-fold symmetry of enhanced crystallite orientations in finished component.
Stress (σ) is a force per unit area.
The force can be uniformly distributed over an area:
\[ \sigma = \frac{F}{A} \]
The force can be distributed non-uniformly over an area, in which case we define the stress at a point as:
\[ \text{stress} = \lim_{dA \to 0} \frac{F}{dA} \]
Consider 2 planes passing through a point P in a cylindrical body in a state of simple tension.
The force acting on planes $A_1$ and $A_2$ is the same, but the stress on the two planes is different because the areas are different.
We need 2 vectors to define a stress:
- The force per unit area, $F$, acting on the plane
- The normal to the surface, $n$, on which $F$ acts
$\Rightarrow$ Stress is a 2nd order tensor that relates $F$ and $n$
$$\begin{bmatrix} F_1 \\ F_2 \\ F_3 \end{bmatrix} = \begin{bmatrix} \sigma_{11} & \sigma_{12} & \sigma_{13} \\ \sigma_{12} & \sigma_{22} & \sigma_{23} \\ \sigma_{13} & \sigma_{23} & \sigma_{33} \end{bmatrix} \begin{bmatrix} n_1 \\ n_2 \\ n_3 \end{bmatrix}$$
Normal and shear stresses
The stress acting on a surface can be resolved into two components:
1) **Normal** stress - acts perpendicular to the surface
2) **Shear** stress - acts parallel to the surface
The direction of the normal stress on a plane is specified once the surface has been identified.
A shear stress can be further resolved into two components in the directions of the coordinate axes in the plane.
⇒ We need three components to define the state of stress at a point on a plane.
We specify all the normal and shear stresses acting on the faces of an infinitesimal cube – a total of 18 components.
\[ \sigma_{ij} \Rightarrow i = \text{coordinate plane normal to the plane acted on by the stress} \]
\[ j = \text{coordinate parallel to which stress acts} \]
\[ i = j \Rightarrow \text{normal stress.} \]
\[ i \neq j \Rightarrow \text{shear stress.} \]
Components of stress
We can show that $\sigma_{ij} = \sigma_{-i-j}$ $\Rightarrow$ only 9 components
$$\sigma_{ij} = \begin{bmatrix}
\sigma_{11} & \sigma_{12} & \sigma_{13} \\
\sigma_{21} & \sigma_{22} & \sigma_{23} \\
\sigma_{31} & \sigma_{32} & \sigma_{33}
\end{bmatrix}$$
To satisfy equilibrium, we must have $\sigma_{ij} = \sigma_{ji}$ $\Rightarrow$ 6 independent components
$$\sigma_{ij} = \begin{bmatrix}
\sigma_{11} & \sigma_{12} & \sigma_{13} \\
\sigma_{12} & \sigma_{22} & \sigma_{23} \\
\sigma_{13} & \sigma_{23} & \sigma_{33}
\end{bmatrix}$$
Symmetric tensor
Residual stresses
Friend and foe
• Residual stresses are self-equilibrating stresses within a stationary solid body when no external forces are applied.
• They vary with location in a component: consider a cast plate a few mm thick. The stresses in the core balance those in the skin. What happens if the skin is removed on one of the surfaces?
Inner core is in tension → Outer skin is in compression
• Almost every manufactured component has residual stresses – they can be detrimental or beneficial to the performance of the component.
• They are not apparent, and they are difficult to measure and predict.
• We need a reliable method to measure residual stresses non-destructively.
Liquid-Metal-Assisted Cracking of a plain carbon steel I-beam after hot-dip galvanizing. Crack is 1.1 m long, and appeared after the beam had been in service.
Macrostresses and Microstresses
Internal stresses are categorized according to the length scale over which they vary.
Type I stresses - macrostresses - vary slowly over the volume of a component and are considered to be continuous across grain boundaries and phase boundaries.
These are the stresses calculated during a typical stress analysis of an engineering component.
Macrostresses and Microstresses
Type II microstresses vary on a length scale on the order of the grain size.
Type III microstresses vary on a subgrain length scale.
Neutron diffraction can be used to study macrostresses and type II microstresses.
Type III microstresses typically give rise to peak broadening.
Strain – what is it?
When a body deforms, its dimensions change i.e. the particles of the body are displaced with respect to each other.
Any displacement which does NOT vary with position in the body results in a movement of the entire body rather than a deformation.
To describe the deformation of a body, we must therefore specify how the displacement varies in the body.
Strain is the term we use to describe the deformation of a body, which includes changes in size (dilatations/contractions) and changes in shape (distortions caused by shears).
Strain in one dimension - uniaxial extension of a wire
Displacement of B with respect to A along $X_1 = u_B - u_A$
= change of length of segment AB due to the extension of the wire
Displacement gradient = $\frac{u_B - u_A}{\Delta x_1}$
In the limit as $\Delta x_1 \to 0$, we have: $e_{11} = \lim_{\Delta x_1 \to 0} \frac{u_B - u_A}{\Delta x_1} = \frac{\partial u_1}{\partial x_1}$
Consider the deformation of the unit square ABCD lying in the $X_1X_2$ plane.
\[ u_1 = \text{displacement} \parallel X_1 \]
\[ u_2 = \text{displacement} \parallel X_2 \]
The displacements have:
1) changed the lengths of segments AB, AD, BC, DC.
2) distorted the square ABCD.
We need 4 parameters to describe the deformation:
\[
e_{11} = \frac{\partial u_1}{\partial x_1}, \quad e_{12} = \frac{\partial u_1}{\partial x_2} \quad (\beta)
\]
\[
e_{22} = \frac{\partial u_2}{\partial x_2}, \quad e_{21} = \frac{\partial u_2}{\partial x_1} \quad (\alpha)
\]
Strain is a tensor
In the general 3D case:
\[
\begin{bmatrix}
\Delta u_1 \\
\Delta u_2 \\
\Delta u_3
\end{bmatrix} = \begin{bmatrix}
e_{11} & e_{12} & e_{13} \\
e_{21} & e_{22} & e_{23} \\
e_{31} & e_{32} & e_{33}
\end{bmatrix} \begin{bmatrix}
\Delta x_1 \\
\Delta x_2 \\
\Delta x_3
\end{bmatrix}
\]
\( e_{ii} = \) extension per unit length along \( X_i \) of a segment parallel to \( X_i \).
\( e_{ij} = \) angle of rotation of a segment parallel to \( X_j \) toward \( X_i \).
\( e_{ij} = \begin{cases}
i = j & \text{volume change} \\
i \neq j & \text{distortion}
\end{cases} \)
As with the stress tensor, the displacement gradient tensor relates two vectors.
A better representation of deformation is \( \varepsilon_{ij} = \frac{1}{2} (e_{ij} + e_{ji}) \).
- No distortion or extension
\( \therefore [e] \) should be \([0]\).
In fact: \( e_{ij} = \begin{bmatrix} 0 & -\theta \\ \theta & 0 \end{bmatrix} \) !!!
For small deformations in an isotropic material, there is a simple linear relationship between stress and strain.
\[ \varepsilon_{11} = \frac{1}{E} (\sigma_{11} - \nu(\sigma_{22} + \sigma_{33})) \quad \varepsilon_{12} = \frac{\sigma_{12}}{2G} \]
This linear relationship arises because the force, \( F \), required for a displacement of \( u \) between 2 atoms, is given by the gradient of energy:
\[ F = \frac{dU}{dr} = \left( \frac{d^2 U}{dr^2} \right)_{r_0} u \]
\[ \sigma = E \varepsilon \]
Since stress and strain are 2nd order tensors, their representation in a new primed coordinate system is easily calculated from the representation in an unprimed coordinate system.
\[
\sigma_{ij} = \begin{bmatrix}
\sigma_{11} & \sigma_{12} & \sigma_{13} \\
\sigma_{21} & \sigma_{22} & \sigma_{23} \\
\sigma_{31} & \sigma_{32} & \sigma_{33}
\end{bmatrix}
\]
\[
\sigma'_{ij} = \begin{bmatrix}
\sigma'_{11} & \sigma'_{12} & \sigma'_{13} \\
\sigma'_{12} & \sigma'_{22} & \sigma'_{23} \\
\sigma'_{13} & \sigma'_{23} & \sigma'_{33}
\end{bmatrix}
\]
\[
\sigma'_{ij} = a_{im} a_{jn} \sigma_{mn}
\]
\[
\begin{bmatrix}
X_1 & X_2 & X_3 \\
X'_1 & X'_2 & X'_3
\end{bmatrix}
\begin{bmatrix}
a_{11} & a_{12} & a_{13} \\
a_{21} & a_{22} & a_{23} \\
a_{31} & a_{32} & a_{33}
\end{bmatrix}
\]
\[
a_{ij} = \cos \theta \cdot X_i' X_j'
\]
Measuring strain by diffraction
The basic equation
Start with Bragg's Law:
\[ n\lambda = 2d \sin(\theta) \]
For a known wavelength
If you know the diffraction angle
You have measured \( d! \)
Diffraction fundamentals
Measuring peak locations
- Peak has a certain profile which is a function of the spectrometer setup and characteristics
- Fit a peak with a suitable function
- Mean $2\theta$ obtained with high precision: +/- 1 part in $10^4$
Measuring strain by diffraction
\[ \varepsilon = \frac{d - d_0}{d_0} \]
\[ \varepsilon = \frac{\sin \theta_0}{\sin \theta} - 1 \]
- We only measure normal strains – not shear strains!
- We measure lattice strains i.e. elastic strains
Stress-free (\( d_0, \theta_0 \))
TENSION (+) (\( d_t > d_0, |\theta_t| < |\theta_0| \))
COMPRESSION (−) (\( d_c < d_0, \theta_c > \theta_0 \))
Measuring strain by diffraction
\[ \varepsilon_{\text{total}} = \varepsilon_{\text{elastic}} + \varepsilon_{\text{plastic}} \]
Stress vs Strain graph:
- **Stress** (σ) on y-axis
- **Strain** (ε) on x-axis
Key points:
- \( \varepsilon_{\text{plastic}} \)
- \( \varepsilon_{\text{elastic}} \)
- \( \varepsilon_{\text{total}} \)
Graph shows two stages:
1. Elastic deformation
2. Plastic deformation
Equation: \( \varepsilon_{\text{total}} = \varepsilon_{\text{elastic}} + \varepsilon_{\text{plastic}} \)
Measuring strain by diffraction
\[ \varepsilon_{\text{total}} = \varepsilon_{\text{elastic}} + \varepsilon_{\text{plastic}} \]
Stress vs Strain graph:
- **Point 1**:
- Stress (\(\sigma\))
- Elastic strain (\(\varepsilon_{\text{elastic}}\))
- Total strain (\(\varepsilon_{\text{total}}\))
- Plastic strain (\(\varepsilon_{\text{plastic}}\))
- **Point 2**:
- Stress (\(\sigma\))
- Elastic strain (\(\varepsilon_{\text{elastic}}\))
- Total strain (\(\varepsilon_{\text{total}}\))
- Plastic strain (\(\varepsilon_{\text{plastic}}\))
Mapping strain at depth
Direction and gauge volume
Measure component of strain parallel to bisector (Q)
Get strain data only from material inside the Gauge Volume
Mapping strain at depth
Direction and gauge volume
Measure component of strain parallel to bisector (Q)
Get strain data only from material inside the Gauge Volume
Mapping Strain at depth
Usually we need 3 components
By re-orienting the sample, we obtain strain in the x, y, and z sample directions.
The gauge volume
Fig. 5.18. Definition of the position and shape of the probe volume in a neutron experiment by the divergent and receiving slit/soller collimator combination (a), experiment geometry (b).
Fig. 5.19 a – c. Spatial resolution obtained by various divergent and receiving slit combinations. The dimensions of the probe region must be chosen such that there is negligible variation of residual stress within the probe volume.
Mapping strain
Location, location, location!
Use neutrons to locate sample edges – Wall scans (0.1 mm)
Example – sampling a strain gradient
Large gauge volume smears out the gradient
If the Principal Stress directions are known, we can measure just those 3 strain components.
Then we can calculate the 3 Principal Stresses from the 3 strains using the Generalized Hooke’s Law:
\[
\sigma_\alpha = \frac{E}{1+\nu} \left[ \varepsilon_\alpha + \frac{\nu}{1-2\nu} (\varepsilon_x + \varepsilon_y + \varepsilon_z) \right], \quad \alpha = (x, y, z)
\]
If the Principal Stress Directions are not known, we need to measure enough strain components to determine the full strain tensor $\Rightarrow$ stress tensor.
\[
\sigma'_a = a_{im} a_{jn} \sigma'_{mn}
\]
\[
\sigma'_b = a_{im} a_{jn} \sigma'_{mn}
\]
\[
\sigma'_f = a_{im} a_{jn} \sigma'_{mn}
\]
6 equations in 6 unknowns
Evaluating Processes
Heat-Exchanger Twist Tube
• Customer’s question:
“Does our annealing procedure reduce the residual stresses?”
• Largest stresses due to deformation expected to be in the hoop direction
• Need only measure hoop strain on As-Manufactured and Annealed tubes
Circumferential scan of 24 positions
3 through-thickness positions:
mid-thickness
0.4 mm toward OD
0.4 mm toward ID
Heat-Exchanger Twist Tube As-Manufactured
As-Manufactured Twist Tube
Hoop Strain ($10^{-4}$)
Circumferential Position (deg.)
- Significant strain variations are observed.
- Complementary OD and ID variations.
Clearly, annealing effectively reduced the residual stresses.
Evaluating Stress-Relief
Is treatment effective? NO
Steel rod contains residual stresses that vary sharply near the surface.
Treatment with cryogenic temperatures was claimed to relieve the stresses, but the measured strain distributions are identical within the precision of strain measurement.
The beauty of in-situ
• Measuring residual strains and deformation textures is great – but how did they get there?
• In-situ experiments allow us to follow the evolution of residual strains and texture during deformation
• Example: Deformation of a Mg-Al alloy
Plastic deformation: slip vs. twinning
- Slip: undeformed blocks of crystal translated relative to each other
- Twinning: homogeneous shear of a portion of the lattice (mirror)
Plastic deformation: slip
(0001)<11\overline{2}0> \rightarrow 2
CRSS = 0.51 MPa
\{10\overline{1}0\}<11\overline{2}0> \rightarrow 2
CRSS = 40 MPa
\{10\overline{1}1\}<11\overline{2}0> \rightarrow 4
CRSS = 40 MPa ??
Plastic deformation: twinning
- Polar: only limited c-axis extension (6.9% max)
\[ \frac{c}{a} < \sqrt{3} \]
• Slip: undeformed blocks of crystalline material slide past one another
– Gradual lattice reorientation
• Twinning: Abrupt reorientation of the crystal lattice
Neutron counts vs Scattering angle, $2\theta$ (deg.)
Mg - 8.5 wt% Al
• Processing (Pechiney, France)
– Mix Mg and Al under protective atmosphere
– Cast into billets
– Extrude at 250°C (64 mm → 15 mm)
– Age
(0002)
Centre is extrusion axis
Contour separation = 0.5 × random
Texture modification
Thermomechanical treatment
Compress // extrusion axis
{1012} twinning leads to an 86.3° reorientation of the lattice
Anneal
Texture modification
Contour separation: 1 × uniform
Extrusion texture (Texture 1)
Modified texture (Texture 2)
Contour separation: 2.5 × uniform
Cyclic tension
- Hysteresis loops occur for both textures
Metallography
Texture 1
Texture 2
Initial State
Metallography
Texture 1
Texture 2
Cycle 3
Metallography
Texture 1
Texture 2
Cycle 6
Cycle 9
Texture2:
- Long, wide twins which cross grain boundaries
- Much smaller twins, apparently nucleated at grain boundaries
Texture 1:
- Twins are narrow and there are relatively few of them
• Profuse {1012} tension twinning expected in a majority of grains
Cyclic tension Texture 2
Stress (MPa) vs Lattice strain (μstrain)
Stress (MPa) vs Integrated intensity
{1012} axial
Cyclic tension Texture 2
Stress (MPa) vs Lattice strain (μstrain)
Stress (MPa) vs Integrated intensity
{1012} axial
Stress (MPa) vs Lattice strain (\(\mu\)strain)
\{1012\} axial
- Stress (MPa)
- Lattice strain (\(\mu\)strain)
\{1013\} axial
- Stress (MPa)
- Lattice strain (\(\mu\)strain)
Stress (MPa) vs Integrated intensity
\{1012\} axial
- Stress (MPa)
- Integrated intensity
\{1013\} axial
- Stress (MPa)
- Integrated intensity
Stress (MPa) vs Lattice strain ($\mu$strain)
{1012} axial
- Stress (MPa)
- Lattice strain ($\mu$strain)
{2110} axial
- Stress (MPa)
- Lattice strain ($\mu$strain)
Stress (MPa) vs Integrated intensity
{1012} axial
- Stress (MPa)
- Integrated intensity
{2110} axial
- Stress (MPa)
- Integrated intensity
T2
- Stress (MPa)
- Integrated intensity
(0002) axial
Stress (MPa)
Lattice strain (\(\mu\)strain)
\{2110\} axial
Stress (MPa)
Integrated intensity
T2
Cyclic tension
Texture 1
(0002) axial
Stress (MPa)
Lattice strain (\(\mu\)strain)
Integrated intensity
(0002) axial
Stress (MPa)
Cyclic tension
Texture 1
(0002) axial
Stress (MPa)
Lattice strain (\(\mu\)strain)
Integrated intensity
\[
\sigma \quad 0 \quad \sigma
\]
Cyclic tension
Texture 1
(0002) axial
Stress (MPa)
Lattice strain (μstrain)
Integrated intensity
Stress (MPa)
Twinning - stress relaxation
Single crystal
Stress in g./mm.$^2$ on the initial cross-sectional area
Extension %
$\sigma$
$\sigma - \Delta \sigma$
$\sigma - \Delta \sigma$
Twinning - stress relaxation
Polycrystal
Twinning - stress relaxation
Polycrystal
$\sigma$ ($-\Delta \sigma$)?
Local stress relaxation $\Rightarrow$ grain level
(0002) axial
Stress (MPa)
-1000 0 1000 2000 3000 4000 5000
Lattice strain (\(\mu\)strain)
(0002) axial
Stress (MPa)
0 20 40 60 80 100 120 140
Integrated intensity
(0002) axial
Stress (MPa)
-1000 0 1000 2000 3000 4000 5000
Lattice strain (\(\mu\)strain)
(0002) axial
Stress (MPa)
10 15 20 25 30 35
Integrated intensity
Gas Tungsten Arc Welding
- GTAW is an arc welding process that uses:
- a non-consumable tungsten electrode (some erosion)
- an inert-gas shroud to protect the material from air
- No filler is required for thin sheet (autogenous weld)
- GTAW produces the highest quality weld of all the arc welding processes.
- GTAW is applicable to most metals (except Zn and Be)
Principle of the measurement
• Acquisition of neutron diffraction data takes time.
• For classical in-situ, we maintain constant temperature and load conditions and map the volume of interest – OK as long as the specimen does not evolve during the course of a measurement.
• Welding is a rapid, dynamic process.
• Even with the most intense neutron sources, there is no way to do measurements during welding without cheating.
• We need a way of establishing conditions that do not change over the course of a measurement (temperature, strain, and phases).
Principle of the measurement
1) Position the welding torch with respect to the sampling volume.
2) Position the specimen with respect to the sampling volume.
3) Start the welding torch
4) March the specimen through the sampling volume.
5) Repeat until you are no longer welcome.
Real estate!!!
Principle of the measurement
Use rotation to give lots of displacement with little translation. Combine with translation to get a really long path.
Weld station Horizontal
- Torch positioning assembly (position torch wrt SV)
- ARGON I/O PORTS (no decarburization)
- ROTARY DRIVE
- TRACKING TIG TORCH
- CHILL GAS SHROUD
- STEADYREST
- Y2 TRANSLATOR (position torch wrt SV)
- X-Y TRANSLATOR (centre pipe wrt SV)
From Discovery to Innovation...
From Discovery to Innovation...
Results – L3 welds
Lattice Constant - Hoop Direction
Distance from weld line
- 4 mm
- 7 mm
- 10 mm
- 15 mm
- 20 mm
- 30 mm
Distance ahead (X<0)/behind (X>0) welding torch (mm)
Lattice parameter (Å)
Results – L3 welds
Intensity - hoop direction
Distance ahead (X<0) / behind (X>0) welding torch (mm)
Intensity
-40 -30 -20 -10 0 10 20 30
4 mm, 7 mm, 10 mm, 15 mm, 20 mm, 30 mm
Science at work for Canada
National Research Council Canada
Conseil national de recherches Canada
Fourier Series allow us to express any function as a series of trigonometric functions.
The trigonometric functions (harmonics) in a Fourier Series represent the fundamental modes of vibration of a string.
We are effectively generating a pattern from a series of “base patterns” which are orthogonal to one another i.e. no base pattern can be generated by a linear combination of the other base patterns.
This is a very powerful tool for dealing with physical problems in 2D or 3D over rectangular domains.
For texture, we are dealing with a very similar situation, only over a spherical domain.
We have a pattern of intensities distributed over a sphere, each point of which represents a family of grain orientations.
We can generate any pattern we want on the sphere, provided we have a suitable set of functions defined over it. Fortunately, there is a set of orthogonal spherical harmonics that fits the bill.
These spherical harmonics represent the fundamental modes of vibration of a sphere.
From *Discovery* to *Innovation*...
**Legend:**
- $n=5$
- $m=0$
- $m=4$
- $m=2$
- $m=3$
- $m=4$
- $m=-4$
- $m=5$
- $m=-5$
**Color Scale:**
- $-1$ to $1$
- $-3$ to $3$
- $-15$ to $15$
- $-60$ to $60$
- $-250$ to $250$
- $-900$ to $900$
- $7e^4$ to $-7e^4$
- $2.5e^4$ to $-2.5e^4$
Stereographic projection
R N T
R N T
Stereographic projection
R N T
R N T
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ESTA
WITH
Eriks Apalais
Tristan Bera
Gerry Bibby
Drew Kahuʻāina Broderick
Stefan Burger
Merlin Carpenter
Nicolas Ceccaldi
Vija Celmins
Jay Chung & Q Takeki Maeda
David Douard
Ramon Feller
Gina Folly
Oleg Frolov
Liam Gillick
Edgars Gluhovs
Dominique Gonzalez-Foerster
Guerilla Girls
Karl Holmqvist
Daniel Horn
Morag Keil
Emil Michael Klein
Fred Lonidier
Miltos Manetas
MAY
Daria Melnikova
Daniele Milvio Jonathan
Monk Sveta Mordvskaya
Carter Mule
Kärt Ojavee
Josephine Pryde
Cinzia Ruggeri
Hinrich Sachs
Cindy Sherman
Mike E. Smith
Rikrit Tiravanija
Lucas Uhlmann
Miriam Visaczki
Danh Vo
Marie-Pascale Wellinger
Pedro Wirz
Seyoung Yoon
Artur Zmijewski
THE ESTATE plays with its double entendre; an “estate” being both the sum of a deceased person’s possessions, and an extensive piece of (privately owned) land often accompanied by a vast home.
AUTUMN
Dates: November 1 – December 8, 2019
Opening: Thursday, October 31, 6–9 pm
Venue: Kim? Contemporary Art Centre, Riga
SUMMER
Dates: August 4 – September 15, 2019
Opening: Saturday, August 3, 4-8pm
Venue: Between Kuiķule and Lauvas (Salacgrīvas lauku teritorija, 4054 Latvia)
What if an art collector—or in more modest terms, a person interested in art who from time to time also happens to purchase, exchange, and receive art works as gifts—spent summers in rural Latvia? What would that house—let’s play it grand—that estate look like? Of what would it be reminiscent of? Would the house pay homage to the shabby chic of Anna Karenina, or the Eurodesign that dominated 1990s interiors? Would it lean towards the Soviet-esque, or stick with a pre-war, Baltic-German style?
The SUMMER edition of THE ESTATE, the first part of the four season cycle which took place in the off-site location in Salacgrīva parish and imagined a collector who could have lived in a remote place such as this and surrounded themselves with different artworks, ephemera, and leftovers from artistic productions together with everyday utensils. For AUTUMN, THE ESTATE becomes more theatrical.
The exhibition space turns into an architectural maze without walls, turning its focus on deacquisition. The collection includes furniture from the summer house and new works realized on site during the SUMMER edition exhibition are placed in a dystopic installation, endowing the collection on a slightly grotesque background.
Looking at the displayed artworks, it becomes clear that the collection or taste of our “collector” is far from blue chip, where “signature style” and key works” prevail. It is instead inclusive of many by-products and leftovers. Smaller, earlier works provide an image of a rather dirty but engaged collection, in which the artworks form part of what could be described as a “conversation piece”, to quote the eponymous 18th-Century English portraiture style and 1974 Luchino Visconti film.
For Tobias Kaspar’s large scale installation AUTUMN the exhibition space at Kim? Contemporary Art Centre in Riga is lacquered in black paint, celebrating the black box theatre and encouraging movement as if evoking another cinematic reference – Lars von Trier’s Dogville (2003) – for visitors to step on the stage and to become actors and actresses themselves. The rest of the scenery exists merely as white painted outlines suggesting a life size floor plan.
LIST OF WORKS
PORCH
Sveta Mordvskaya
Check the Frame IV, 2019
Glazed ceramic
An “empty” frame in the entrance,
unconsciously inspired by kokoshniks
Ramon Feller
Close of a Long Day, 2019
Wood, glue
Kart Ojavee
Untitled, 2017
Used sneakers, linen, cotton, polyester,
silicone, 2017
Fabricstreated in swamp
ENTRANCE
Daniel Horn
Welcome Note, 2019
Text card
Ffixxed Studios
The Estate, 2019
T-shirt from the SS2020 collection with
embroideries based on THE ESTATE
sketches
Carter Mule
V / O / Paramount / Viacom, 2014
Vibra ink on layered tulle, vase
Jonathan Monk
The First Back Pocket Piece From 2009,
2009
Plexiglass, wood, various papers
Box in the shape of an enlarged back
pocket
Cindy Sherman
Untitled, 1979
C-print, signature, frame
Jeans, 2019
22 pairs of jeans, coat hanger
KITCHEN
Gerry Bibby
Candy, 2011
Newspaper, letterpress print
Silver letters and a Gucci ad
Liam Gillick
Clarity, 2013
Adhesive wall vinyl
Guerilla Girls
The Advantages Of Being A Woman Artist, 1985
Towel
Fred Lonidier
Untitled, circa 1974
Analog print, mounted on cardboard
Man on the telephone in a telephone cabin, San Diego
Hinrich Sachs
Dingdong (children’s discourse), 2018
Painted bronze hanging sausage
Niklāvs Strunke
Folk Son, 1930’s
Porcelain decanters, produced by the Jessen porcelain factory Made in Riga
Zane Onckule’s private collection
STUDIO
Stefan Burger
Untitled, 2019
Photograms produced on THE ESTATE
Oleg Frolov
Fountain of peace, prosperity, pedocracy and meritocracy, 2018
Steel
Four water taps
STUDIO / VITRINE:
Dominique Gonzalez-Foerster
The Library is on Fire: Haunted Glyphs, 2013
Two plastic 3D prints
Edgars Gluhovs
Untitled, 2017
Letter, photo, charcoal drawing
Mail from the Latvian Institute Rome
Fred Lonidier
Girl Watcher Lens, 1972
Detail Osawa objective and case
Fred Lonidier
29 Arrests, 1972
Detail, one photo and text plate of 29
Rirkrit Tiravanija
There Is a Light That Never Goes Out, 2015
Marble
Sheep bone from a Roman Easter feast
Seyoung Yoon
Half a thinker, 2014
Clay, fake Swarovski diamond (only for Version ON)
External HD STUDY
BAR
BARN
BATHHOUSE
OUTHOUSE
BEDROOM
LIVING ROOM
STUDIO
KITCHEN
ENTRANCE
PORCH
LIVING ROOM
Eriks Apalais
§, 2011
Acrylic and oil on canvas
Merlin Carpenter
What is lost is lost forever. Aint Laurent Without Hedi, 2016
T-shirt
Nicholas Ceccaldi
PAIN, 2013
Paper, acrylic paint
Black painted book next to the TV
Vija Celmins
Saturn Stamps, 1995
Lithograph, offset printed
Jay Chung & Q Takeki Maeda
Untitled, 2014
Woodblock print on paper
Blue print of the floor of Isabella Bortolozzi gallery, Berlin
David Douard
Untitled, 2012
Acrylic on canvas, framed inkjet print, plastic
Grinzinger Friedhof
Group For PROVENCE Thomas Bernhard T-shirt, 2017
White T-shirt with frottage made from the writers gravestone
Edgars Gluhovs
Haute Collaboration, Edition Concorde, 2015
Ink drawing
Ryan Gander
A fire poker and blowpipe for the Albers’ family home, 2019
Stainless steal
Relational sculpture
Karl Holmqvist
Family Day At The Factory; Gay Kid Visits His Father’s Workplace, 1972, 2014
Offset print on newspaper
MAY
Lars Friedrich, 2015
Sandstone 3D print
standing figure of the eponymous Berlin based gallerist
Miltos Manetas
Untitled, 2004
Acrylic on canvas
Tryptic, holy trinity, monochrome paintings of computer screens
Daniele Milvio
Untitled, 2009
Ceramics, acrylic, ink
Orange ceramic with drawing
Cinza Ruggeri
Umbratile con Brio, 2018
Box with ephemera
Three black pizza boxes on the table
Hinrich Sachs
Mother Tongue [Dzimtā valoda], Latvian / Latvia, 1999, 2012
Framed watercolour on paper
Mike E. Smith
Untitled, 2009
3 tennis balls and 10 T-shirts
Dahn Vo
La Biennale di Venezia, 2015
Paper, ribbon
Paper birthday cake
Pedro Wirz
Untitled, 2019
Small “mother earth ball”
Artur Zmijevski
Burned, 2018
C-print Photo of burned bushes (Zurich)
BEDROOM
Kart Ojavee
Untitled, 2017
Jacket made from in swamp rotten fabric
Morag Keil
Sex Painting, 2016
Acrylic on canvas
Morag Keil
Sex Painting, 2016
Acrylic on canvas
Next to Sex Painting, 2016
Sarah Staton
Esperanto of Currency, 2015
Stitched linen and paint
Gray painting
Miriam Visaczki
The Advent of Calm, 2018
Felt, wire
BARN
Gina Folly
Basic Needs XVIII, 2019
Cardboard box, door lock, air filter,
wheels, mini projector, video looped,
key, key chain
Emil Michael Klein
Untitled, 2019
Linen, fabric, rope
Josephine Pryde
A Sheep Lead Guitar, 2007
Framed C-print
Josephine Pryde
Ambivalence, 2007/8
Framed Silver gelatine print
Josephine Pryde
Liver (pen holder), 2006
Framed C-print
The Estate’s autumn harvest, 2019
Bronze (partly cut and polished)
OUTHOUSE
Drew Kahu’aina Broderick
Havajas puke (Outhouse), 2019
Poster
BATHHOUSE
Bathhouse, 2019
Architecture: Lucas Uhlmann &
Marie-Pascale Wellinger
Team: Ramon Feller, Egija Inzule, Tobias
Kaspar, Sebastian Stadler
Imaginable bathhouse with shou sugi
ban treated wood
BAR
Daria Melnikova
Palette, 2019
Bottle of self-made blackcurrant leaves
champagne, fabric
IMPRINT
Tobias Kaspar’s THE ESTATE is curated by Zane Onckule and produced by Kim? Contemporary Art Centre
EXHIBITION SUPPORT
Kultūras Ministrija
VKKF
Rīgas Dome
Pro Helvetia
SPONSORS
Kokmuiža
Arctic Paper
Green Print
Riga Black Balsam
MEDIA PARTNERS
Echo Gone Wrong
Arterritory.com
Satori
PROVENCE 4
ACKNOWLEDGEMENTS
We would like to extend thanks to all contributing artists and collaborators, as well as Olamiju Fajemisin, Egija Inzule, Vera Kaspar, Iris Kaspar, Elīna Drāke, Žanete Kiseļeva, Armands Brīģis, Haralds Ceka, Elza Sīle, Inese Vērīņa-Lubīņa and all others involved in making THE ESTATE a reality.
Further thanks to Galerie Peter Kilchmann, Zürich; Lars Friedrich, Berlin; and Temnikova & Kasela, Tallinn.
BOOKLET
EDITOR Tobias Kaspar and Zane Onckule
DESIGN Vera Kaspar, Daria Melnikova
PUBLISHED BY Kim? Contemporary Art Centre
© 2019
AISI
ESTATE WINES
TIBURON
STAFF TOWNSHIP
SINCE 1972
The village of Kivikko, where the author spent his childhood.
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YOUR WAY FORWARD FOR NATIVE TITLE
MESSAGE STICK
Message Stick is published by North Queensland Land Council
March 2017
Gudjula Native Title Determination
PBC Corporate Governance and Compliance Workshop
Yellow Gin Creek Bridge renamed to ‘Youngeorah’
CONTENTS
03 | A MESSAGE FROM THE CHAIR
05 | UPDATE FROM THE CEO
07 | GUDJULA PEOPLE NATIVE TITLE DETERMINATION
08 | BYE BYE BYGRAVE - MCGLADE v NATIVE TITLE REGISTRAR [2017]
11 | NQLC ENGAGEMENT & DEVELOPMENT SUPPORT TEAM
12 | QUEENSLAND GLOBE
14 | PBC UNIT UPDATE
18 | YELLOW GIN CREEK BRIDGE RENAMED TO ‘YOUNGOORAH’
19 | NEW STAFF PROFILES
20 | STAY IN THE LOOP
Welcome to the first edition of Message Stick for 2017. I would like to start by acknowledging and paying my respects to the custodians of the land within the NQLC footprint, both past, present and future. I also give my condolences to the families of people who have recently passed on.
I would like to extend my congratulations to the Gudjula People, whom in December of last year had the second parts of their native title claims determined at the Federal Court in Brisbane. Their perseverance and determination throughout their 12 year native title process is admirable. Thank you also to the hard work of the NQLC staff who assisted with the claim. To read more on the Gudjula determination, go to page 7 for Cheryl Thomson’s article.
2017 is shaping up to be a busy year in our NQLC Footprint. We kicked off February with the PBC Unit’s annual Corporate Governance and Compliance Workshop held in Cairns. I would like to thank all of the PBCs for their attendance and input at the workshop, and also to Shane Carroll for presenting.
In March, NQLC will be working with the Referendum Council to co-host the Constitutional Reform Regional Dialogues in Cairns. The Dialogues are a series of meetings being held around the country over the next few months with a purpose to reach broad agreement on whether and, if so, how, to ‘recognise’ Indigenous Australians in the Australian Constitution. Invitations to the Dialogues will be sent out to community members by the Referendum Council.
In June, the Australian Institute of Aboriginal and Torres Strait Islander Studies (AIATSIS) has invited NQLC to co-host the 2017 National Native Title Conference. The conference will be held in Townsville with the permission of the Traditional Owners of Gurumblibara Wulgurukaba Country. With 2017 being the 25 year anniversary of Mabo, the Conference theme is ‘Our land is our birth right: MABO25 & Beyond’. This conference creates a time of reflection throughout native title. Looking back over the mechanisms of the native title process; what worked, what didn’t work, and where to from here.
Continuing the celebrations of the 25 year anniversary of Mabo, the National Native Title Tribunal have invited all Native Title Representative Bodies and other organisations to work with them to establish a commemorative website. The website, due to go live any time now, will be structured around a different theme each month covering the past, present and future of native title. NQLC has been very involved in providing content for the website so if you have managed to be featured in our Message Stick before, there’s a good chance you will be featured in the NNTT’s website to celebrate the historic
event. I also took part in a video interview which will be featured on the site, as well as our NQLC website: www.nqlc.com.au. We will let you know as soon as their site has gone live.
2017 really is an exciting time with Cairns hosting this year’s National NAIDOC Awards Ceremony. The National NAIDOC Awards are an opportunity to recognise the outstanding contributions that Aboriginal and Torres Strait Islander People make to improve the lives of Indigenous people, promote issues in the wider community, or the excellence they have shown in their chosen field. The Ceremony kicks off NAIDOC Week around the country on Saturday 1 July 2017. Award nomination forms and to purchase tickets to the event, visit their website: www.naidoc.org.au.
The last big event to cap off the first half of 2017 is the Laura Dance Festival, held from 30 June – 2 July 2017. Laura Aboriginal Dance Festival is held every second year in the Cape York Peninsula highlighting the many diverse Communities, language, song, dance and stories. Over 20 Communities participate in the Festival, with up to 500 performers and over 5000 festivalgoers. To purchase your tickets to the festival visit: www.lauradancefestival.com.
As you can see, we have a very big first half of 2017 to tackle. Myself, the Board and staff of NQLC are all looking forward to working with you and helping you achieve your native title aspirations. As always, if you want to have a yarn with me give our office a call on 1800 814 779.
Kaylene Malthouse
NQLC Chair
Welcome back to the Message Stick. I trust you all had a wonderful festive season and got some time to relax with family and friends. I also hope that it doesn’t seem like too much of a distant memory just yet.
You will recall that in the December edition I reported on the establishment of the Engagement and Development Support (EDS) Team which brings the NQLC’s Future Act Mining and Exploration (FAME) Unit and PBC Support Unit under the one umbrella, managed by Rhonda (Jake) Jacobsen. The article on page 11 sets out that structure in more detail.
You will see in the structure that there have been some staffing changes to the FAME Unit in particular, with the commencement of Terry Basic in the Administrative Officer position and Julia (Jules) Taylor as the Senior Legal Officer Coordinator. We are very pleased to welcome them both. Jules will be taking over the legal practice previously undertaken by Jake and is progressively working her way through meeting her clients.
Some of you may be familiar with the Queensland Globe program which allows you to access satellite imagery and overlay certain features that you may wish to examine on your country. FAME Senior Legal Officer (and mapping expert) Chris Harriss provides an overview of how that program operates at page 12.
The PBC Support Unit convened its annual Corporate Governance and Compliance Workshop in Cairns over 7-9 February 2017. Shane Carroll is a regular presenter at the Workshop and his Corporate Governance training proved to be as successful this year as in previous years. Shane provided me with the feedback assessments from the course and it is obvious that the participants saw it as relevant, useful and what’s more, highly enjoyable.
The PBC Unit will also be holding its next Submission Writing Workshop on 21 & 22 March in Cairns. The primary purpose of the Workshop is to draft the annual application for PM&C’s PBC Funding Support Programme, but there will also be a focus on applying for funds under the Indigenous Advancement Strategy’s PBC Capacity Development Programme. It would appear that this Programme is drastically underutilised at the moment, so it is critical that our PBCs are assisted to frame successful funding applications for this Programme – being as it is specific to PBCs. More information about the PBC Workshops is on page 14.
The Legal Unit has also welcomed several new staff since the last Message Stick. Peter Krebs has joined us as a Senior Legal Officer. Peter is a highly experienced native title solicitor who formerly worked as the Principal Legal Officer at the Torres Strait Regional Authority. Prior to that Peter had worked as a native title solicitor at Cape York Land Council and Gurang Land Council. We are very fortunate to have secured Peter’s services. Peter has been allocated a hefty caseload in the claims section and is currently very busy studying the cases we have assigned to him.
Cherona Williams has been recruited to fill the gap left by Janelle Levers’ departure and is being trained up by Jacqui before Jacqui goes on maternity leave for her second bub. Madeleine Smith will be backfilling for Jacqui from mid-March.
The Legal Unit is co-operating with the State on a new system of tenure analysis delivery. Based on the
NNTT’s Native Title Vision mapping system and with the assistance of the NNTT, data is to be loaded into the program to enable a clickable digital map to be displayed on screen which displays the tenure analysis for each non freehold lot. Essentially it is the digital form of a paper map but has the capacity to considerably speed up the process and be less costly.
Meetings are gearing up, anthropology reports are coming through and life in the legal department is getting busier.
The NQLC’s Research Unit has also hit the ground running this year. Several claims are in a very active phase, which means our researchers are planning ahead for meetings, field trips, consultant visits and interviews, and of course, responding to your queries and questions.
The new Silver Valley/Mt Garnet area research has been kicked off with a community meeting in early February to introduce the Consultant Anthropologist and at the time of writing we are busy organising and preparing for field work and interviews for both this project and the Wakaman research project. We have also met with the Gia & Ngaro Peoples to present the Consultant Researcher’s findings to them with a view to filing a claim over the Whitsunday’s area. Research will begin in the next few months for Southern Warra, in the north of our region.
The Research Unit has recently completed a thorough audit of our range of multimedia records and our Tindale collection, and will be focusing now on preparing the hundreds of documents to be moved. The Unit continues to build its collection of research materials and has been gathering records from the JCU library and AIATSIS to expand the collection.
The Cairns Research staff were able to take the opportunity in early February to attend a workshop in Perth held by the Centre for Native Title Anthropology (CNTA) which focused on Emerging Trends in Native Title Anthropology and where our researchers were able to contribute to national discussions, representing the issues of concern in the NQLC region.
The Cairns office refurbishment is continuing on track from completion in early April. Stage 2 of the works was recently completed and the Engagement & Development Support Unit is now comfortably ensconced in its shiny new digs. Work is underway on the upstairs area which will house our Legal & Research Units.
It already looks like 2017 is going to be another big year at the NQLC and I am excited at the prospect of the achievements we will gain for North Queensland’s Traditional Owners.
Steve Ducksbury
NQLC Chief Executive Officer
After 12 long years, the Gudjala People have had their native title claims determined. Back on the 18th of March 2014, Justice Logan made the Gudjala People #1 Part A and #2 Part A consent determinations at Charters Towers, holding off Part B of the applications to a date to be fixed, dependent, on the outcome of an application by a group of respondent parties. These respondent parties are collectively known as the Walsh River Respondents, who raised issues of possible extinguishment of native title in relation to areas covered by military orders in World War II. The issues were taken by the State of Queensland to the High Court.
Ultimately, it was found the making of the military orders did not extinguish native title (see Martin Dore’s article on this in our May 2015 edition).
On the 13th of December 2016, at the Federal Court in Brisbane, His Honour Justice Reeves finally determined, with the consent of all parties, Gudjala People #1 Part B and Gudjala People #2 Part B. The Applicants, Christine Hero, Smokey Anderson, Gloria Santo and Priscilla Huen attended the hearing.
The determined area of both claims cover approximately 19,000 square kilometres.
This brought to an end a journey the Gudjala People had originally commenced in 1998. The Gudjala People #1 and #2 claims were filed with the Federal Court in 2005 and 2006 respectively.
I am grateful for the assistance of the applicants, Elizabeth Dodd, Smokey Anderson, Gloria Santo, Christine Hero and Priscilla Huen and their tireless commitment to progressing the claims to conclusion.
I would like to congratulate the Gudjala People for their patience and tenacity throughout this process, and acknowledge that there are Gudjala Elders who commenced this journey, but were not present to see the final outcome. I would also like to thank Chris Harriss who previously worked on the claims with the Gudjala People, Sharon Charger who has been the Project Officer on all of their claims, as well as NQLC Legal Secretaries Solange Williams, Jasmin Phillips and Laura Burton.
The Ngrragoonda Aboriginal Corporation RNTBC now manages native title on behalf of the Gudjala People. (Check out their PBC Profile, which was featured in our December 2015 edition).
Written by Cheryl Thomson
NQLC Legal Officer
In *Bygrave #2*¹, the Court had ruled that you do not need the signatures of all of the Applicants on an Indigenous Land Use Agreement (ILUA). Indeed, the Court in that case said that you did not need any signatures of the Applicants as long as there was clear evidence that the Native Title claim group had authorised the ILUA.
The McGlade case involved the comprehensive settlement package that had been negotiated over a number of years by the Noongar People and the Western Australian government.
The package involved six indigenous land use agreements and four (4) different native title applications by the Noongar People.
Four (4) of the ILUAs were the subject of this action. The claim revolved around whether the ILUAs could be registered in circumstances where in respective of each of the ILUAs, there was at least one signature missing.
With respect to one of the ILUAs, one of the applicants had become deceased before signing the ILUA and also another applicant had not signed the ILUA at the time it was presented for registration but subsequently did so, before the native title registrar considered the ILUA for registration.
In each case, part of the authorisation resolutions of the group was phrased in terms that said “the group authorised and directed” the applicants to sign the ILUA. The argument by those in the minority who were opposed to the ILUA, and therefore did not sign the ILUA, was that the document put up for registration was not in fact an ILUA. They said that unless it complied with all of the conditions in the Native Title Act 1993 (NTA), one condition of which was to have the signatures of the registered native title claimants, it was not an ILUA and therefore could not be registered.
The decision of the Court was delivered in two judgments; the first was a jointly written judgment by Justice North and Justice Barker with Justice Mortimer delivering his own separate judgment, but arriving at the same conclusion as the other Judges.
The Judges each canvassed a number of issues, although ultimately it was not necessary for the Court to actually rule on a number of issues that had been put to the Court in argument. For example, the Judges went into discussion as to whether the applicants constituted a statutory appointed body corporate or whether they might be regarded as a legal entity unto themselves in some other form, or were to be seen as some other form of entity. Ultimately, it was not necessary for this to be decided.
**BACK TO BASICS**
Essentially each of the judgements approached, the matter as an issue of statutory interpretation. The Court looked at the strict provisions of the NTA
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¹ QGC Pty Ltd v Bygrave and Others (No 2) (2010) 189 FCR 412; [2010] FCA 1019
noting that in the definitions of section 253 of the NTA, “registered native title claimants” were the persons whose names appear on the entry on the register of native title claims in respect of a native title application.
This definition links back to the definition of “applicant in section 61(2)” which contemplates a singular entity, which may in some circumstances, be comprised of multiple “persons”. The Court also pointed to section 24CD(2)(a) and said that in applying that section, it must be taken to refer to each of the persons who comprised the applicant if there was more than one.
The Court pointed to section 24CD(1) and (2) Which defines who must be a party and noted that where there was a registered claim, it included the Registered Native Title Claimants. The Registered Native Title Claimants are those whose names appear in the Register held by the NNIT.
They also indicated that in order to be registered, the agreement would have to be in writing. If followed, it said that if one of the persons who jointly with others had been authorised by the claim group to be the applicant who refuses, fails, neglects or is unable to sign a negotiated proposed written ILUA for whatever reason, then the document will lack the quality of being an agreement recognised for the purposes of the NTA.
Should the claimant group be unhappy with such failure, neglect etc then the proper course of action would be for the group to remove or replace the person/s who has not signed using the provisions of section 66B.
The court said this conclusion was supported by section 24EA which should be construed as contemplating that the “parties” to an agreement are not fictional parties, but parties in their own, individual right. The expectation is that each of those parties will indicate ascent to the agreement by signing it. The majority judgment also noted it did not matter whether the ILUA was to be made as a deed or not. Either way, every party [including each individual that makes up the Applicant] to agreement must sign it for it to qualify for registration.
As to the wording in the motions passed by the authorisation meeting, purporting to direct the applicants to do things, the majority said that the claim group outside of the operation of section 66B does not exercise any power of direction and that the only power came from section 66B. The majority noted that whilst their conclusion might be considered inconvenient by some, especially in the case where a large number of persons jointly comprised the registered native title claimants and where some signatures may have been difficult to obtain, the question of providing some mechanism, apart from section 66B for dealing with these types of issues, was a matter for parliament to consider*. With respect to the fact that on one of the ILUAs an applicant had become deceased before signing, the Court said that the way to correct that was again, to bring an application under section 66B to remove that person as an applicant. In regards to the situation where one of the applicants only signed after the ILUA had been presented for registration, the fact that he signed before registration removed the difficulty of the lack of the signature. In other words, they rejected the argument that all of the signatures had to be present at the time of lodgment, preferring the view that as long as all of the signatures were present at the time when registration was being considered, that was sufficient.
Mortimer J delivered his own separate judgment but arrived at the same conclusions. One of the matters that Mortimer J discussed, which it was ultimately unnecessary for him to answer, was whether as an alternative to section 66B proceedings, the Federal Court Rules empowered the Court to make an Order that a person ceased to be a party. It was noted that this had been done in some cases*, Mortimer pointed to the fact
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2 These will be same persons as comprise the Applicant
3 Under the previous Federal Court Rules
that when Orders were made under section 66B, the register of native title claims had to be altered in accordance with 66B(4). Whilst there was no specific similar provision under the Federal Court Rules directing the register to be amended, and accordingly, without making any final decision, he leaned in favour of the provisions of section 66B.
One area where Mortimer J appeared to partly disagree with the majority judgment was that the majority said that there was “nothing in the text context or purpose” of section 61 that would suggest that the claim group could direct that decisions could be made by a majority of the applicants.
Whilst Mortimer J tended towards agreeing with majority judgment that you **could not direct that decisions be made by a majority** of the applicants, he did point out that there must be some circumstances in which some limits and terms could be placed, otherwise there would be no situations in which 66B(1)(a)(iv) could operate. That provision refers to a ground of bringing a section 66B application is that the **applicant has exceeding its authority**. Ultimately this was not an issue which needed to be resolved for the purpose of this action.
**CONCLUSION**
- All three judges held that Bygrave #2 was wrongly decided that in order for an agreement to be registered as an ILUA the signature of every party to the agreement had to be included and that included each and every member of the Applicant (registered native title claimant).
- In addition, the agreement had to be in writing and on paper.
- Deceased members of the applicant should first be removed by a section 66B process so their names will not be an the register of Native Title Claimants.
- The appropriate time to assess if all the necessary signatures are on the document is not when the ILUA is lodged for registration but at the time when the Registrar is about to consider the application for registration.
**THE UNKNOWN RESPONSE OF THE NNTT**
**It is unknown if the NNTT will now set about removing ILUAs from registration if that Registration was obtained using the Bygrave Principle**
The situations in which the Registrar can remove an ILUA from the Register are set out in section 199C. They do not seem to cover the situation here except for obtaining a Court Order.
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**Updates since the writing of this article:**
* The Federal Government has rushed amending legislation into parliament to reverse the effect of McCabe and restore the Bygrave position
The Draft Bill has reached its third reading and been referred to a Senate Committee.
The Bill provides that at the time of authorisation the Group can nominate a person or persons to be the signatories for the group. Such persons or persons need not be applicants but must be one of the mob.
If no such nominations are made a majority of applicants will be sufficient.
More details in next edition of Message Stick
** The NNTT has identified the various ILUAs in each State and Territory that relied on the Bygrave principal to achieve registration.
Given that the proposed amendments to the Native Title Act are to be retrospective, it is our understanding that the NNTT is taking no action pending the passage of, and coming into effect of the amendments.
---
Written by Martin Dore
NQLC Principal Legal Officer
Background
The North Queensland Land Council (NQLC) has a very proud reputation for securing native title determinations for 23 of our client groups. In the course of securing these determinations the NQLC also establishes the Prescribed Bodies Corporate (PBC) to hold and manage the native title of the group. Upon determination, those PBCs then become Registered Native Title Body Corporate (RNTBC). Although the terminology of RNTBC is correct, the use of the term PBC is most common.
In total, there are 24 PBCs in the NQLC region. The Department of Prime Minister and Cabinet (PM&C) administers the PBC Support Funding Program under which PBCs may receive up to $50,000.00 per year, subject to meeting eligibility criteria.
In the case of PM&C approval for the PBC Support Funding, the NQLC then administers those funds in accordance with the NQLC Process Agreement. Additionally, NQLC offers various capacity development activities to PBCs to support, strengthen and consolidate their operations. These services are provided through the PBC Support Unit.
The NQLC also provides services in respect of future acts throughout the claim process (registration of a claim secures certain ‘procedural rights’ that the native title claimant group can exercise) and post determination. These services are provided through the Future Act Mining and Exploration (FAME) Unit.
In addition to issuing future act notices and representing native title groups in their dealings with future act proponents, the FAME Unit also provided capacity development activities to support, strengthen and consolidate their administrative and management practices especially in the context of dealing with third parties.
The FAME and PBC Units are the only Units of NQLC that regularly and consistently provide services to native title holders post determination and both Units provide similar capacity development support. We reviewed the type and delivery of services of the FAME and PBC Units and decided that particularly in respect of the capacity development activities, it would be most efficient if the two units worked closer together.
In these circumstances NQLC established the Engagement and Development Support Team (EDST).
Structure
Whilst the FAME and PBC Units do provide similar services in respect of capacity development, the other services that each Unit offers is very specific and requires different expertise. For this reason, the two units retain their unique identities and services specific to their operations but will work cooperatively on those capacity development services where there has been some degrees of overlap.
To achieve this, the structure of the Engagement and Development Support Team is:
Services
The essential services of each Unit that you are familiar with, remain the same. Please continue to contact the person you normally contact.
- FAME Mining Coordinator or Project Officers for future act specific matters
- PBC staff for PBC specific matters.
Queensland Globe (QG) will let you do all without leaving home. QG is a free software component (plug in) by the Queensland Government. It is accessed online and runs through Google Earth.
QG allows you to access satellite imagery and overlay or highlight current mines, abandoned mines, exploration permits, land parcels, land values and tenure, native title claims and determinations, Indigenous Land Use Agreements and much more.
Once installed, you will generally find that the satellite imagery is more up to date and a higher resolution than Google Earth. Generally. This allows you to get zoom right in on country and see what’s going on. You can also access historic imagery and create and save overlays and place marks.
A practical example of how QG can benefit is that it can facilitate a desk top cultural heritage survey. You can zoom in on country and use the imagery to locate special sites and areas. You can then mark and define those sites and areas accurately. Should you wish, you can then use those marks to have the sites placed on the Cultural Heritage Database at Department of Aboriginal and Torres Strait Islander Partnerships.
By comparing historical to more recent imagery you can check on tree clearing and mining and infrastructure expansions. You can use the overlay and polygon functions to check on country and mark and document cultural heritage sites.
QG allows you to create your own place marks and save them to computer. These Google Earth
(KMZ) files can then be emailed. So someone in Chillagoe can locate a special place, mark it on Google Earth and email the exact location to an elder in Perth to check.
There are a series of online tutorial videos that instruct in the use of QG. Just Google “Queensland Globe” to access and install and view the series of tutorial videos.
QC will also let you pinpoint the bommies on the reef so you can navigate there and improve your fishing, but that’s another story!
The Future Act Mining and Exploration (FAME) Unit offers PBCs capacity development forums which explain how to examine and respond to future act notices (FANs), and includes accessing QG to locate the activity on your country. If your PBC has not had a FAN Capacity Development Forum and you would like one, please contact Danny O’Shane, Mining Coordinator, FAME Unit in our Cairns office.
Written by Chris Harriss
Senior Legal Officer
Future Act Mining & Exploration Unit
WELCOME TO THE PBC SUPPORT UNIT UPDATE. WELL … WE KNEW THAT WE WERE IN FOR A FLYING START TO 2017 BUT WE HAD NO IDEA IT WOULD BE THIS FULL-ON! SO RIGHT NOW IS A GOOD TIME TO PROVIDE AN UPDATE.
OUR MOST IMPORTANT EVENT SO FAR THIS YEAR WOULD HAVE TO BE THE PBC GOVERNANCE AND COMPLIANCE WORKSHOP, HELD IN CAIRNS OVER TWO AND HALF DAYS FROM FEBRUARY THE 7TH TO THE 9TH IN CAIRNS. THE VENUE FOR THE WORKSHOP WAS THE RYDGES ESPLANADE RESORT.
READ ON TO FIND OUT ABOUT HOW WE MADE THE MOST OF THOSE TWO AND A HALF DAYS!
PBC GOVERNANCE AND COMPLIANCE WORKSHOP - WHAT WAS IT ALL ABOUT?
The Corporate Governance and Compliance Workshop 2017 is a capacity development and learning opportunity for PBC directors. We encourage directors from all PBCs in our region to attend. It doesn’t matter if directors have attended previous workshops, or if the PBC is not currently being assisted by the PBC Support Unit. We strive to provide a workshop program that shifts the focus to different areas of PBC governance and management every time that this event is offered. This way directors will always experience something new no-matter how many previous workshops they might have attended.
This year the workshop was extremely well attended by directors and representatives from 14 PBCs:
- Birriah AC RNTBC
- Djabugay AC RNTBC
- Djiru Warrangburra AC RNTBC
- Dulabed Malanbarra & Yidinji AC RNTBC
- Girramay AC RNTBC
- Goondaloo AC RNTBC
- Gugu Badhun AC RNTBC
- Gunggandji AC RNTBC
- Gunggandji Mandingalby AC RNTBC
- Mamu AC RNTBC
- Mandingalbay Yidinji AC RNTBC
- Ngrragoonda AC RNTBC
- Wabubadda AC RNTBC
- Wadjanbarra Tableland Yidinji AC RNTBC
Up to 35 PBC directors and representatives attended over the duration of the workshop. The NQLC made provision for the attendance of two directors and two youth delegates from each PBC. Specific workshop places were made available to youth delegates as a way of addressing one of the ongoing concerns we have heard from many directors. This is about succession planning and providing opportunities to younger community members to learn about PBC business so that they might be encouraged to take on more responsibility within the management of PBCs in the future. Youth delegates proved themselves to be more than up to the task at this most recent workshop.
**WORKSHOP AIMS AND HOW WE ACHIEVED THEM**
Our aims were threefold.
1. **To help PBC Directors strengthen their understanding of corporate governance and legal requirements.**
Shane Carroll is a barrister who is a regular at our workshops and presented to participants on Day 1. He is a very experienced corporate governance training provider and is very good at making complex subject matter much easier to understand. He also has a detailed knowledge of the PBC Support Funding Program, the Indigenous Advancement Strategy, and the PBC Capacity Building Fund. Feedback from those who attended his sessions was glowing across the board! He opened our eyes to the realities of best practice approaches to governance and provided real-life examples of how things can go wrong, and the potential consequences.
On Day 2 our own PBC Support Unit brought everyone up to speed with regard to our PBC Support Program. We looked at the NQLC Internal Guidelines which set out the procedures and processes used to manage the funding of PBCs under the PBC Support Program.
2. **To help PBC Directors find ways of reviewing the tools they use for corporate governance and the strategies they have (or may not have) in place to help meet legal requirements.**
Rhonda Jacobsen (Jake), Manager of the Engagement and Development Support Team, along with other members of the FAME Unit delved into future act issues in more
detail on Day 3. Jake also focussed on risk management and decision making responsibilities. There were many questions and participants were totally absorbed by the discussion because they were asked to look at their own approaches to decision making - with particular regard to very important responsibilities directors have under the PBC Regulations.
Whilst some PBC directors and representatives may have realised there was a lot of work required of them in this area ... they were also able to hear about ways that they could meet these very important requirements. This set the scene for a later discussion about policies and procedures.
Gary Lui provided information and helped the participants to workshop their needs with regard to the development of policies and procedures. The need for policies and procedures has been a long standing concern for many PBCs. The workshop was an opportunity to get started on the task of pulling together a set of policies and procedures that all PBCs in the NQLC area can access and use to help them get on with business.
The workshop participants heard about how this very important work will progress over the coming months. We will be following up with PBCs in the near future as this initiative develops into a project. We may be asking PBCs to participate in different ways at different stages.
3. To provide PBC Directors with ways, methods or approaches (governance structures) for engaging with external agencies.
On Day 2 we heard from representatives of the Department of Prime Minister and Cabinet (PM&C), the Wet Tropics Management Authority (WTMA), and Regional Development Australia (RDA). Workshop participants heard about how the process for seeking funding under the PM&C managed Indigenous Advancement Strategy (IAS) has changed. This was described as a more supportive process where applicants are encouraged to submit an expression of interest to commence the process ... as opposed to a full blown submission for funding. WTMA and RDA representatives spoke about their consultative frameworks and their proposals for engaging with Traditional Owners. Whilst the content of these presentations differed, there was a common theme of effective engagement with Traditional Owners. There was discussion about how effective engagement might be achieved – as individual PBCs on issues that specifically affect them (or ‘regional’ areas/topics) and as a PBC ‘collective voice’ for issues that affect all PBCs. On the individual basis, a common response was about the need for PBCs to have ‘the basics’ bedded down. In this case ‘the basics’ means good governance and best practice approaches to all other aspects of PBC business, including decision making and risk management.
As to the question of broader representation of the PBCs in the NQLC boundary, it was decided to be too large a topic to settle at the Workshop and one that required each PBC to think about more fully. It was agreed that further time should be given to considering different models that could be used and we agreed to draft up some models for consideration. It is expected that this will be developed more fully over the next month or so – PBCs will be updated on progress.
SO WHAT’S NEXT PBC SUPPORT UNIT?
Quite a lot actually. We started work on the next phase well before this latest workshop. It’s safe to say that along with the continuation of our support and assistance to PBCs generally … we have a couple of priorities.
PBC SUBMISSION WRITING WORKSHOP 21 – 22 MARCH 2017
A date claimer and formal invitation has already been sent to PBCs via email and post. We would like your response to that invitation and registration form as soon as possible – but the Registration Deadline is Friday 3 March 2017. The main purpose of the next workshop is to assist PBCs to develop their submissions to the PBC Funding Support Program. At the same time we will look at alternative funding sources and the skills needed to take advantage of funding sources outside of the PM&C funding scheme. The workshop will be led by Melissa Roberston. Many of our PBC directors will remember her fantastic Submission Writing Workshop from 2016.
Those who attended the Corporate Governance and Compliance Workshop, who intend to come to the submission writing workshop will note that there will be some continuity and/or links between the outcomes of the previous workshop and the program for the submission writing workshop. One other thing … we want to make this workshop as productive as possible and so attendance will not be based on the same approach that was taken with regard to the Corporate Compliance and Governance workshop. PBCs can nominate two people for the workshop. One representative needs to be the PBC Chair. The other should be someone who has or will have ongoing responsibility for developing funding submissions.
POLICIES AND PROCEDURES
The last session on the last day of the workshop in February was devoted to workshopping the development of universal PBC policies and procedures. February workshop participants were told about the plans for the further development of these (sometimes urgently needed) policies and procedures. The hard work, which was the result of workshopping by PBC representatives on the 9th of February, has been saved and will contribute to the development of policies and procedures and terms of reference for future work. As this project develops we will progressively work with those individual PBCs who do not currently have policies and procedures. If you’d like to register your interest in developing up policies and procedures, don’t hesitate to contact the PBC Unit.
Written by Gary Lui
NQLC PBC Support Officer
Yellow Gin Creek Bridge renamed to Youngoorah Bridge
During 2014 and 2015 the Juru People worked closely with the Department of Transport and Main Roads (DTMR, Northern Region) to manage the cultural heritage aspects for the Bruce Highway Yellow Gin Creek Bridge Project located between Ayr and Bowen. The Juru People and DTMR developed a Cultural Heritage Management Agreement (CHMA) to protect the important cultural values of the project area. A team of Traditional Owners walked country to carry out a cultural survey and impact assessment study before the construction of the new bridge took place.
Yellow Gin Creek has important and enduring cultural significance to the Juru People. The creek and adjacent coastline and wetlands formed a focal living and foraging place for the Juru People in prehistoric times. The surrounding landscape contains many archaeological sites, especially old camping places, fireplaces, stone artefact scatters and burials. The local Aboriginal oral history for this place provides evidence that in historic times (after European settlement), Yellow Gin Creek became a central living place for some local ‘light-skinned’ women who worked at Inkerman Station. In particular, one of the Juru People’s apical ancestors was reported to have lived in this area.
In 2016 DTMR called for public submissions to name the newly constructed Yellow Gin Creek Bridge. The Juru People felt that the bridge should have an Aboriginal language name to reflect the ongoing cultural significance and values of this creek and surrounding area. The Juru Aboriginal language name for woman/women is ‘Younghoorah’ and this name was submitted to DTMR by Kyburra Munda Yalga Aboriginal Corporation as part of the public consultation process. On 9 December 2016, DTMR announced that the submission by Kyburra Munda Yalga Corporation was successful and they held a commissioning ceremony at the Yellow Gin Creek Bridge to unveil the new bridge name as ‘Younghoorah’.
Everyone who now passes over Yellow Gin Creek Bridge on the Bruce Highway can reflect on the Aboriginal cultural significance of this place as part of the Juru People’s homelands, but also the very important role that Yellow Gin Creek has played in the lives of local Aboriginal women throughout the history of the Lower Burdekin district.
Written by Ricardo Martinez
NQLC Deputy Principal Legal Officer (Townsville Office)
Introducing Our Newest Recruits...
Julia ‘Jules’ Taylor
Senior Legal Officer – Coordinator
Future Acts, Mining & Exploration (FAME) Unit (Cairns Office)
I have just relocated to Cairns from Broome in the far north west where I have been working with the Kimberley Land Council for the past 7 and a half years as their Senior Legal Officer for future acts, mining and exploration agreements and ILUAs. I’m excited to now be part of the FAME Unit and am looking forward to doing the work I have grown to love in a new jurisdiction with the new team.
Personally I relocated to be not so remote and closer to family on the East Coast. I’m looking forward to exploring Cairns and it surrounds and getting out fishing as often as I can which is my all-time favourite activity – anyone willing to share their secret spots let me know.
Cherona Williams
Legal Administration Officer
Legal Unit (Cairns Office)
I have recently joined the NQLC as a Legal Administration Officer and I am very excited to take on my new role. I have over 17 years administration background – everything from legal secretary work, working at the Department of Human Services (Centrelink) in the Indigenous queue, to Operations/Finance and Customer service in the Waste Management Industry.
I was born and raised in Cairns, my mum is from Cairns and dad was from Stephen Island in the Torres Straits. My son, partner and I love to go camping, fishing and 4wd driving. We head out as often as we can to either the Cape near Bathurst Bay/Cape Melville or out near Chillagoe.
The team at NQLC are all very welcoming and supportive. I am looking forward to developing my skills in the Native Title area and look forward to meeting the Traditional Owners of Far North Queensland.
Laura Burton
Legal Administration Officer
Legal Unit (Townsville Office)
I was born and raised in Townsville and have worked in the legal industry for the last 5 years. I have a background in litigious matters including insolvency, dispute resolution and employment law.
I have been with the NQLC since returning from Sydney in September 2016 and am enjoying developing new skills and working with North Queensland’s Traditional Owners.
Outside of work, I enjoy spending time with my partner, friends and family; golfing and little things like taking my two puppies to the beach. I am currently completing a Bachelor of Laws and looking forward to graduation and admission as a lawyer over the next year and a half.
27 May
Anniversary of the 1967 Referendum
In 1967 over 90% of Australians voted in a Referendum to remove clauses from the Australian Constitution which discriminated against Aboriginal and Torres Strait Islander Peoples.
1 July
National NAIDOC Awards Ceremony
5-7 June
National Native Title Conference
And this year... we’re co-hosting!!
The 2017 National Native Title Conference will be convened by the Australian Institute of Aboriginal and Torres Strait Islander Studies (AIATSIS) and the North Queensland Land Council (NQLC) on the traditional lands of the Gurumbilbara Wulgurukaba people, Townsville Queensland. The conference will be held at the Townsville Entertainment and Convention Centre from Monday 5 – Wednesday 7 June 2017.
03 June
Mabo Day
25 year anniversary
Keep a look out for the NNTT’s commemorative website, celebrating 25 years of native title. Once the site is live we will add the link on our NQLC homepage.
24-26 March
Constitutional Reform Regional Dialogues, Cairns
21-22 March
NQLC Submission Writing Workshop
30 June-2 July
Laura Dance Festival
Our Languages Matter
2-9 JULY 2017
Cairns – Head Office
61 Anderson Street Cairns Qld 4870
PO Box 679 Cairns North Qld 4870
Tel: 07 4042 7000 / Fax: 07 4042 7070
Branch Office – Townsville
Suncorp Tower, 61-73 Sturt St Townsville Qld 4810
PO Box 5296 Townsville Qld 4810
Tel: 07 4421 5700 / Fax: 07 4421 5717
Branch Office – Mackay
Suite 2 Level 1, 38 Macalister Street
Mackay Qld 4740
Tel: 07 4898 6700 / Fax: 07 4898 6777
|
CAREERS
WWW.EIC-CANADA.CA
1250 BOUL. RENÉ-LÉVESQUE OUEST,
SUITE 2200, MONTREAL QC, H3B 4W8, CANADA
+1 (514) 500-5087
firstname.lastname@example.org
# TABLE OF CONTENTS
| Page | Section |
|------|----------------------------------------------|
| 02 | Presentation of Experience Internship Canada |
| 03 | Finance |
| 05 | Law |
| 07 | Marketing & Advertising |
| 09 | Fashion Industry |
| 11 | Not-for-Profit Organizations |
| 13 | Real Estate |
| 15 | Journalism & Media |
| 17 | Translation |
| 19 | Tourism & Hotel Industry |
| 21 | Human Resources |
| 23 | Commercial Development and Entrepreneurship |
| 25 | Scientific Research |
| 27 | Engineering |
| 29 | IT Development |
| 31 | Consulting |
| 33 | Data Analytics |
| 35 | Design |
À PROPOS DE EXPERIENCE INTERNSHIP CANADA
EIC’s mission is to attract international talents to Canada.
We give young students the opportunity to join this country with a particularly attractive business environment and working conditions.
To this end, we have developed an efficient process for selecting candidates with the aim of meeting their expectations while considering their abilities and preparing them as well as possible for job interviews.
EIC takes care of all administrative and logistical constraints to allow elected candidates to focus on admission to internships and gain the most from it.
“Our program allows candidates to gain significant experience in Canada under optimal conditions.”
The financial industry is considered by many to be one of the most competitive sectors in the world. In an increasingly interconnected world, financial activity is at the heart of the global economy.
Only the best candidates with degrees in finance, accounting or financial engineering manage to obtain a place in the world's leading financial institutions. Gaining internship experience is a prerequisite for obtaining a long-term job in this sector. Toronto and Montreal are respectively the second and third largest financial centers in North America after New York.
Most of the world's most prestigious institutions are present in Canada, which is why we can offer internships in investment banking, consulting firms, multinational corporations, asset management firms, private equity funds and hedge funds.
**Intern profile**
- Education: business, finance, engineering
- Specialization in finance
- Hard skills: proficiency in Excel, VBA, Access
- Soft skills: sociable, reactive, rigorous, pragmatic, cooperative
- Languages: French, English
**Job description**
- Financial modeling and analysis
- Portfolio analysis
- Recommendations of securities or financial instruments
- Identification and development of investment opportunities
- Compensation: salary and/or commission
**Companies in the industry**
Goldman Sachs, HSBC, RBC, TD, CIBC, Banque Laurentienne, Banque Nationale, Scotiabank
We offer law internships in prestigious law firms for articling students who intend to study law, are currently in law school, or who have recently graduated from a law school.
Our articling students will have the opportunity to work directly with professionals in the sector in a professionalizing and educational environment. During your internship you will be exposed to various aspects of operations, including client meetings, legal research, and case management.
**Intern profile**
- Education: law
- Hard skills: writing, oral expression
- Soft skills: self-reliant, reactive, proactive, reliable
- Languages: French, English
**Job description**
- Legal advice
- Client management
- Drafting of legal contracts
- Compensation: salary and/or commission
**Companies in the industry**
Lavery Lawyers, Clifford Chance, Norton Rose Fulbright, Linklaters, Davies Ward Phillips & Vineberg, Baker McKenzie, BLG Borden Ladner Gervais, Blakes, Osler, Miller Thomson, Gowling WLG, Stikeman Elliott.
Advertising and marketing are extremely dynamic and growing sectors. Marketing covers an extremely wide range of actions and is indispensable for any company marketing products or services.
Professionals in the field develop strategic communications between an organization and its consumers. Our marketing internship program puts candidates in positions that will allow them to acquire key skills in the field. We have access to companies of all sizes as well as the most prestigious marketing or communication agencies.
Learn how to use the latest technology, launch advertising campaigns to millions of people, learn the latest trends in data analytics, sales, and customer relationship management.
**Intern profile**
- Education: business, marketing, advertising
- Hard skills: writing, oral expression
- Soft skills: creative, proactive, cooperative
- Languages: French, English
**Job description**
- Communication
- Launch digital campaigns
- Promote products and/or services
- Follow-up of customer files
- Strategic planning and business development
- Compensation: salary and/or commission
**Companies in the industry**
LAROUCHE | PUBLICIS GROUPE | havas | WPP | BOOKMARK
The fashion and luxury industry are experiencing continuous growth and a global expansion that brings together designers, investors, retailers, and wholesalers from all over the world to create new trends and styles in the market.
It is an extremely demanding market that is in full expansion. The fashion and luxury market are worth more than $2,000 billion worldwide today.
Participating in one of our internships in this sector will allow you to work alongside professionals and provide you with the training and qualifications necessary to enter this demanding field.
**Companies in the industry**
- L'ORÉAL
- ALDO
- LE CHÂTEAU
- SSENSE
- lululemon
- LOLE
- PARASUCO
- SIMONS
- LOUIS VUITTON
The not-for-profit sector is dynamic, vibrant and meaningful. Many career opportunities are open to you in fields such as social services, health and culture, to name a few. The only condition is to share their vision.
Over the last few years, the sector has grown considerably. The number of organizations has exploded, as has the number of their employees. Their contribution goes beyond financial aid, medical services or other charitable activities; they give people a purpose.
Two famous environmental organizations were founded in Canada: Greenpeace and Sea Shepherd were born in Vancouver.
**Intern profile**
- Education: all academic backgrounds, similar experience appreciated
- Hard skills: writing
- Soft skills: motivated, sociable
- Languages: French, English
**Job description**
- Policy, program and operations development
- Social media management
- Creation of communication materials
- Support for fundraising campaigns
- Grant applications
- Participation in events
- Compensation: not specified
**Les associations et ONG qui recrutent**
- Oxfam Canada
- Croix-Rouge Canadienne
- Amnesty International
- Greenpeace
- Nature Action Québec
- WWF
The real estate market in Canada is booming and constantly evolving. From commercial to residential real estate, its growth potential has virtually no limits and is an ideal experience for anyone interested in investment, brokerage, analysis, and valuation. We offer internships with several of the oldest real estate companies in the world.
Doing an internship in the field of real estate is one of the most valuable experiences you can get at the beginning of your career.
By participating in one of our real estate internships, you will enter directly into the heart of this ultra-dynamic sector which will allow you to develop your skills and knowledge as well as prepare you for your future career.
**Companies in the industry**
- Sotheby's International Realty Canada
- Sutton
- ZONE ZONEVENDU.COM
- Engel & Völkers
- Royal LePage
- Century 21
With the rise of digital platforms, media has been able to reinvent itself to welcome a whole new generation of journalists. Journalism has become globalized through several different media and previous experience in this field is crucial to getting a job in a reputable agency. This popular and very competitive sector values internship experiences that are rather rare in this field.
Your internship will consist of editorial, research, and copywriting work, and will give you the opportunity to work closely with those responsible for publications.
Our journalism internships will allow you to take on a wide range of responsibilities, including writing, photojournalism and other documentation methods that will allow you to build your international portfolio.
**Companies in the industry**
- Toronto Business Journal
- Le Journal de Montréal
- Vancouver Sun
- La Presse
- ICI Radio-Canada
- leDroit
One of the few countries in the world that is both French-speaking and English-speaking, Canada is a dream destination for translation.
Our translation courses give linguists the contacts and tools they need to stand out from their peers. Whether through practical experience in a literary, legal, or specialized translation role, or through a complete cultural immersion daily, foreign language trainees will advance their skills.
We work with leading language and translation organizations across Canada. You will thus be placed in governmental, educational, scientific, and financial organizations.
**Intern profile**
- Education: languages
- Hard skills: writing
- Soft skills: cooperative
- Languages: French, English
**Job description**
- Transcription of articles, case studies and other texts
- Real-time translation
- Software review of translated documents for accuracy
- Compensation: salary and/or commission
**Companies in the industry**
- Textualis
- SERV
- TRSB
- FOX Translations Ltd.
- ADHOC Agence de traduction
- SLRR Cabinet de traduction
Our hotel industry and tourism internships offer our participants unique exposure to this rigorous, international sector. From operations management to event planning, from customer service to logistics, we facilitate hands-on experience and learning by immersing ambitious individuals in this ultra-competitive sector.
By completing one of our internships in the tourism and hospitality sector, you will help to ensure customer satisfaction and loyalty, coordinate between departments to guarantee the best customer service, and also contribute to promotional campaigns. Gaining professional experience will give you a competitive edge in a rapidly expanding job market.
**Companies in the industry**
Four Seasons
Shangri-La Hotels and Resorts
The Ritz-Carlton®
Hilton Hotels & Resorts
Sofitel Hotels & Resorts Montreal Golden Mile
Marriott
We offer human resources and talent management internships in some of the world's most competitive companies. Human resources is considered to be one of the most important departments in a company, as it plays a number of key roles.
Our interns work in HR departments and play an active part in the recruitment and management process. HR internships involve active participation in the recruitment process and in the management of a company's most important resource: its staff.
Interns will play a crucial role in recruiting new employees, evaluating programs, managing and much more. Our internships provide valuable industry experience and insight into the corporate landscape.
**Companies in the industry**
- Manpower
- Michael Page
- HAYS
- expectra
- KORN FERRY | HayGroup
- ROBERT WALTERS
Business development is a combination of strategic analysis, marketing, and sales. Professionals in this field have the mission to find new drivers for the growth of a company, providing solutions to develop the turnover in a direct way (new customers or products) or in an indirect way (marketing, communication).
Experience in business development shows that you will be ready to take on management functions or even create your own company. Business development integrates with all sectors and companies ranging from B2B to B2C. Our Business Development internships are aimed at people with an entrepreneurial spirit, able to sell and evaluate the strengths and weaknesses of a sales cycle.
Our internships in Business Development will help you to enter the international market thanks to all the skills and the network you have acquired.
**Companies in the industry**
- Sotheby’s International Realty Canada
- TD
- WPP
- Parasuco
- CIBC
- Citibank
Learning is a fundamental value in scientific research, and working alongside inspiring scientists is a major benefit.
Scientific research is a notoriously competitive field. Students at all stages of their academic careers are fighting over the best internships year after year to stand out from the competition.
With our scientific research internships in Canada, you'll learn from leading researchers, engineers and academics. Our science internships fall into many categories, including engineering, biotechnology, biomedicine and more.
**Intern profile**
- Education: sciences, engineering
- Hard skills: proficiency of research tools, writing summaries
- Soft skills: self-reliant, rigorous
- Languages: French, English
**Job description**
- Data collection
- Analysis of results
- Case study research
- Designing and carrying out experiments
- Testing new technologies
- Taking samples
- Compensation: salary and/or commission
**Companies in the industry**
Pfizer, Merck, AstraZeneca, Johnson & Johnson, Sandoz, Schering-Plough, Bristol-Myers Squibb, Sanofi, Roche
The best way to stand out as a young engineer is to have already had some work experience during your training.
In this type of profession, where projects are varied, engineering students are often looking for work experience to discover the corporate world and find out about the issues they will face in their careers.
We offer engineering internships that give you the chance to explore key engineering sectors, such as civil, electrical and mechanical engineering. We also offer opportunities in sustainability, green and alternative technologies.
**Intern profile**
- Education: engineering
- Hard skills: proficiency of research tools, writing summaries
- Soft skills: self-reliant, rigorous
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|
Briefing on EU and UK legislation on infant formulas and follow-on formulas
I’m thinking of getting a t-shirt made – ‘Danger! Sore boobs!’
Baby Milk Action Briefing on EU and UK legislation on baby formulas and foods
Copyright: Baby Milk Action, 2012.
Baby Milk Action asserts its moral rights as the author of this document.
For permission to reproduce any of this document, in whole or in part, contact
Baby Milk Action, 34 Trumpington Street, Cambridge, CB2 1QY
Tel : (UK) 01223 44620
Cover picture: Danone leaflet sent to mothers in the UK - perpetuating the notion that breastfeeding will always be painful. Because mothers believe this they don’t ask for help and the problems continue.
For just five illnesses, moderate increases in breastfeeding would translate into cost savings for the NHS of £40 million and tens of thousands of fewer hospital admissions and GP consultations.
*Preventing Disease and Saving resources*, UNICEF UK, 2012
A 10% increase in breastfeeding rates would result in savings in the cost of treating gastroenteritis, asthma and otitis media. Total savings for just three illnesses and the formula, bottles and teats, would therefore be: about 17,000 cases of otitis media avoided at a saving of £509,000; almost 3900 cases of gastroenteritis being avoided, at a saving of £2.6 million, over 1500 cases of asthma being avoided, at a saving of £2.6 million. a reduction in the cost of teats and formula of £102,000
*NICE Costing report 2006*
50-80% of the selling price of formula goes towards company promotion and profits. This means that a mother using formula for 12 months will contribute about £300 above the cost of the formula processing and distribution to the company’s promotional budget, rising to £800 if ready to feed formula is used.
*Baby Milk Action analysis 2012*
“We find the case for labelling infant formula or follow on formula with health or nutrition claims entirely unsupportable. If an ingredient is unequivocally beneficial as demonstrated by independent review of scientific data it would be unethical to withhold it for commercial reasons. Rather it should be made a required ingredient of infant formula in order to reduce existing risks associated with artificial feeding. To do otherwise is not in the best interests of children, and fails to recognise the crucial distinction between these products and other foods.” The UK Government’s Scientific Advisory Committee on Nutrition (SACN) 2007
“In this region alone [Asia Pacific] sales of infant formula have grown 15% per year for the last five years… but sadly it’s the formula manufacturers who are capturing most of the value of our milk. Infant formula delivered to the back door of a supermarket is worth ten times as much as our milk powder exports at the border. “We blither on incessantly about the need to add value to our exports. Infant formula is a clear, no-brainer opportunity to add value…. Tim Morris, Coriolis Limited, New Zealand, 2011
“A kilo of infant formula is worth ten times the value of a kilo of milk powder, so it’s obvious which product New Zealand should be selling.”
Gerry Brownlee, Economic Development Minister, 2011
“The Irish Government and Danone Baby Nutrition.. today announced details of a €50 million investment programme at its manufacturing facility in Macroom, Co Cork Ireland…. The expansion will result in a trebling of capacity to 100,000 tonnes annually… 98% of the output from Macroom will be exported and commercialized in more than 60 countries worldwide……”
*Enterprise Ireland Press release 4.12.10*
“The industry is fighting a rearguard action against regulation on a country-by-country basis,”
*Global Packaged Food: Market Opportunities for Baby Food to 2013 Euromonitor*
“You have to understand - the big companies don’t feel any national loyalty any more - we are beyond that - we’re global - we move the money around, we can pay ourselves gargantuan compensation packages that are offensive to social norms in the host country because we don’t feel part of the host country any more…….”
Jeffrey Sachs, Economist, speaking on BBC Radio 4. 2011
Self-regulation does not work as a way to limit the extent and impact of marketing. Instead, self-regulatory systems promote trust in advertising among consumers and governments, undermining their resolve to bring in the legislation that is needed to protect health. Under these systems the volume of advertising increases”
Corinna Hawkes, Int. Food Policy Research Institute, Washington.
“Artificially fed infants consume 30,000 more calories than breastfed infants by 8 months of age” (equivalent to 120 Mars bars - 4 a week).
*Student Study Guide KG Auerbach, J Riordan 1993*
Contents
CONTENTS .................................................................................................................. 2
1 INTRODUCTION ........................................................................................................... 3
2.1 KEY FACTS ABOUT INFANT FEEDING: ................................................................. 4
2.2 KEY FACTS ABOUT FORMULA COMPOSITION ..................................................... 5
2.3 KEY FACTS ABOUT FORMULA MARKETING ....................................................... 5
3 LEGISLATION ON THE MARKETING .................................................................... 7
3.1 UK LEGISLATION: ................................................................................................. 7
3.2 UK SELF REGULATORY CODES: .......................................................................... 7
3.3 EU LEGISLATION: ................................................................................................. 7
3.4 LEGISLATION AND GUIDANCE ON CONTAMINANTS: ...................................... 8
3.5 RELEVANT CODEX STANDARDS ........................................................................ 9
3.6 IBFAN’S CONCERNS ABOUT CODEX – THE RISE OF FOLLOW-ON MILKS ........ 9
4 PARNUTS - HISTORICAL BACKGROUND .................................................................. 11
4.1 NEW DEVELOPMENTS – THE REVISION OF PARNUTS ..................................... 13
5 OPTIONAL INGREDIENTS .......................................................................................... 16
6 HISTORY OF SAFE USE .............................................................................................. 17
7 HEALTH AND NUTRITION CLAIMS – KEY POINTS .................................................. 18
7.1 The DHA claim ....................................................................................................... 19
7.2 ASSESSING THE RISK OF THE DHA CLAIM ....................................................... 19
8 FORMULAS FOR LBW INFANTS .................................................................................. 21
9 FOODS FOR SPECIAL MEDICAL PURPOSES ............................................................ 22
10 FORMULAS FOR OLDER BABIES – GROWING UP, TODDLER MILKS ..................... 24
11 EFSA AND WHA RECOMMENDATIONS ON EXCLUSIVE BREASTFEEDING ............. 24
12 CONTAMINANTS, BPA, PATHOGENS, PESTICIDES ................................................ 25
13. UK FORMULA MARKETING REGULATORY SYSTEM ANALYSIS ............................ 28
13.1 INTRODUCTION .................................................................................................... 28
13.2 THE FOOD STANDARDS AGENCY ....................................................................... 29
13.3 THE ADVERTISING STANDARDS AUTHORITY ..................................................... 29
13.4 TRADING STANDARDS .......................................................................................... 30
13.5 THE REVIEW OF THE REGULATIONS AND GUIDANCE NOTES .......................... 31
13.6 ACTION AGAINST VIOLATIONS AT INTERNATIONAL LEVEL ............................... 32
APPENDIX 1: CHRONOLOGY .......................................................................................... 35
APPENDIX 2: CHART OF LEGISLATION ........................................................................ 35
1 Introduction
Infant formula has been described is a semi-medicinal food or ‘nutritional medicine’ which should only be used on the advice (and ideally under the supervision) of health workers.\(^1\) It is a processed food, based on cow’s milk or soya, intended for use when babies are not breastfed by their mothers and do not otherwise have access to breastmilk (from a donor milk bank, for example).
Infant formula is unlike other foods in that it is used as the sole source of nutrition during the first six months of life - a critical period of rapid growth and development. It can also continue to be used alongside complementary foods after 6 months for as long as needed. There is no benefit in moving onto to follow-on formulas or other formulas for older babies. Processed formulas can only ever be an imperfect approximation of human breastmilk which is a living substance that changes as the baby grows. A mother’s breastmilk contains antibodies and other protective factors that are tailored to her baby’s needs. It impossible to mimic a mother’s breastmilk, which is delivered to her baby in a uniquely safe way. In every stage of the manufacture, storage and delivery of formulas, there are countless opportunities for contamination, human error and corruption.
In addition to these problems, minor modifications and omissions in the ingredients used in these products can have major effects on infant health. *The Report of the Scientific Committee on Food on the Revision of Essential Requirements of Infant Formulae and Follow-on Formulae*\(^2\) identified some of problems that have occurred with the introduction of modified infant formulae. Examples included reduced protein availability with impairment of growth; trace element deficiency with severe clinical disease; chloride deficiency with long-term neurological damage and thiamine deficiency with severe clinical disease, including neurological damage and several cases of infant death.
Breastmilk substitutes may be required when a child is orphaned, the mother is incapacitated or drug intake might be a contraindication to breastfeeding (though expert pharmacists should be consulted as breastfeeding is possible with many drugs, even when the standard information indicates otherwise as a routine recommendation - contact the Drugs in Breastmilk Helpline).
In the UK, a large proportion of mothers use formula with no medical need. Indeed, the preliminary results from the Infant Feeding Survey 2010 show that nearly a fifth (19%) of babies in the UK are never breastfed. The last full published survey (2005) found that the number of babies breastfed exclusively until 6 months, as recommended by the Departments of Health and the World Health Organisation, is insignificant; only 21% of babies are still being exclusively breastfed at 6 WEEKS of age in the UK.
Mothers (and carers when the mothers are absent) who are unable or unwilling to breastfeed and do not have access to breastmilk by other means will require access to breastmilk substitutes (infant formula).
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\(^1\) *Infant formula and related trade issues in the context of the international code of marketing of breast-milk substitutes, health implications of direct advertising of infant formula.* [www.who.int/nutrition/…/infant_formula_trade_issues_eng.pdf](http://www.who.int/nutrition/…/infant_formula_trade_issues_eng.pdf)
\(^2\) *Report of the Scientific Committee on Food on the Revision of Essential Requirements of Infant Formulae and Follow-on Formulae* SCF/CS/NUT/IF/65 Final 18 May 2003
2 KEY FACTS
2.1 Key facts about infant feeding:
- The UK Government, as a signatory to the *International Code of Marketing of Breastmilk Substitutes* and subsequent relevant World Health Assembly Resolutions, has obligations to implement them in their entirety, to protect breastfeeding, to ensure parents and carers are not misled and properly informed and that breastmilk substitutes are used safely if needed.
- The International Code was adopted in 1981 as a **minimum standard** to be **implemented in its entirety** in all countries.\(^3\) Leading health bodies and parliamentarians have called for its full implementation since 1981. (*The International Code and WHA Resolutions have equal status and should be read together.*)
- According to a UK government survey 90% of mothers who stopped breastfeeding before 6 weeks said they wanted to breastfeed for longer, as did 40% of those who breastfed for 6 months.
- Of 17 countries studied, Britain’s rates of *any* breastfeeding at 6 months is position 16.\(^4\) Although the 2010 ONS survey shows that UK’s initiation rates are starting to improve at 83%, our duration rates are almost the lowest in Europe with less than half of babies (48%) breastfed at 6 weeks.\(^5\)
- In the 2005 ONS survey, the overwhelming reasons given by UK mothers for stopping breastfeeding were ‘insufficient milk’ and other problems that can be overcome with good management. “Around nine in ten mothers who breastfed for less than six weeks said that they would have liked to continue longer, this proportion declining to 40% of mothers who breastfed for at least six months.”
- Breastfeeding has the effect of counteracting the effects of poverty for babies. Breastfeeding rates are lowest among young and poor mothers.\(^6\)
- Higher breastfeeding rates in the UK would significantly improve the health of mothers and babies and reduce health service costs.\(^7\)
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\(^3\) World Health Assembly Resolution 33.32: “Stressing that the adoption of and adherence to the International Code of Marketing Breastmilk Substitutes is a minimum requirement and only one of several important actions required in order to protect healthy practices in respect of infant and young child feeding… URGES all Member States:(1) to give full and unanimous support to the implementation of the recommendations made by the joint WHO/UNICEF Meeting on Infant and Young Child Feeding and of the provisions of the International Code in its entirety as an expression of the collective will of the membership of the World Health Organization;
\(^4\) *Promotion of Breastfeeding in Europe, a Blueprint for Action*. EU Project Contract N. SPC 2002359
\(^5\) *Infant Feeding Survey 2005*, Office of National Statistics. Only initiation statistics are available for 2010.
\(^6\) *Infant feeding Survey 2005* ONS
\(^7\) [http://guidance.nice.org.uk/page.aspx?q=345136](http://guidance.nice.org.uk/page.aspx?q=345136) A NICE costing report shows how the expected 10% increase in breastfeeding rates due to Baby Friendly Initiative accreditation (removing promotion of breastmilk substitutes, feeding bottles and tests from hospitals in line with the Code) would result in savings in the cost of treating gastroenteritis, asthma and otitis media. With a 10% improvement in breastfeeding 60,563 additional babies would be breastfed. Total savings for just these three illnesses and the formula, bottles and teats, would therefore be:
- about 17,000 cases of otitis media avoided at a saving of £509,000.
- almost 3900 cases of gastroenteritis being avoided, at a saving of £2.6 million
- over 1500 cases of asthma being avoided, at a saving of £2.6 million.
- a reduction in the cost of teats and formula of £102,000
2.2 KEY FACTS ABOUT FORMULA COMPOSITION
- Any product sold as an infant formula must comply with the compositional criteria set out in legislation and the basic nutritional profile of the majority of formulas is very similar.
- There is no proven need for any baby to use follow-on formulas or formulas for older babies (Toddler milks) which were invented to get round the restrictions of the International Code. (See Section 3.5.)
- There is, as yet, no proven benefit from optional ingredients.
- “If an ingredient is unequivocally beneficial as demonstrated by independent review of scientific data it would be unethical to withhold it for commercial reasons. Rather it should be made a required ingredient of infant formula in order to reduce existing risks associated with artificial feeding. To do otherwise is not in the best interests of children, and fails to recognise the crucial distinction between these products and other foods.”
SACN 2007
- Some babies have been shown to have adverse reactions to certain ingredients.
- Parents may have ethical issues about ingredients such as beef tallow, fish, egg, GM ingredients.
2.3 KEY FACTS ABOUT FORMULA MARKETING
- The *International Code* clearly intended to cover the marketing of products such as follow-on formulas and formulas for older babies. The *International Code* contains no definition for these products because they hardly existed at that time and only started to be aggressively promoted after the International Code was adopted.\(^8\)
- The UK Government, and all EU member states, as signatories the International Code and the Convention of the Rights of the Child to implement it.
- There is no definition of follow-on milks in the International Code because they were no promoted or commonly used before the 1981.
- 9 UNICEF clarified its opinion on follow-on formulas and the scope of the Code in its statement to the *European Parliament Development and Co-operation Committee in Nov 2000*.\(^9\)
- Six nutrition claims (Lactose only, Lactose free, Added LCP or an equivalent nutrition claim related to the addition of docosahexaenoic acid, Taurine, fructo-oligosaccharides and galacto-oligosaccharides, nucleotide ) and one disease risk reduction claim (Reduction of risk to allergy to milk proteins) are specifically permitted for infant formulas.\(^{10}\)
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\(^8\) The definition of ‘breastmilk substitute’ in the *International Code* refers to “*any food being marketed or otherwise represented as a partial or total replacement for breast milk, whether or not suitable for that purpose.*” so covers far more than infant formula: “The Code applies to the marketing, and practices related thereto, of the following products: *breastmilk substitutes*, including infant formula; other milk products, foods and beverages, including bottle-fed complementary foods, when marketed or otherwise represented to be suitable, with or without modification, for use as a partial or total replacement of breast-milk; feeding bottles and teats. It also applies to their quality and availability, and to information concerning their use.”
\(^9\) “*The Code applies to ALL BREASTMILK SUBSTITUTES and related products, which include feeding bottles and teats. The Code is not limited to basic infant formula intended for healthy babies born after nine months of gestation and with adequate weight and length for age as many companies would argue. The Code covers special formulae such as those for premature infants, hypoallergenic formulae, lactose free formulae and follow-on formulae (ref 4). It also covers waters, juices, teas, and foods if marketed or in any other way represented as a partial or total replacement for breastmilk. These two principles, universality and the scope including all breastmilk substitutes, cannot be over emphasised given the tendency of the infant feeding industry to attempt to limit the application of the Code.*”
http://www.babymilkaction.org/press/press23nov00unicef.html
\(^{10}\) *The Infant Formula and Follow-on Formula (England) Regulations 2007,*
• Claims for follow-on formulas and formulas and foods for older babies must be first authorised according the EU Nutrition and Health Claims claims legislation.\(^{11}\) To date, although several claims for children’s foods and foods for pregnant women have been authorised, only one health claim for follow-on formulas has been permitted:
“Docosahexaenoic acid (DHA) intake contributes to the normal visual development of infants up to 12 months of age.”\(^{12}\)
• Before being authorised in 2011, the DHA claim was challenged by Members of the European Parliament.
• The DHA claim is not permitted for infant formulas, but since they share the same brand name as follow-on formulas, the DHA health message crosses over to the permitted DHA nutrition claim.\(^{13}\)
• The EU Commission has clarified that a brand name cannot be an implied health or nutrition claim unless that claim is legally permitted.\(^{14}\)
• The EU Commission has clarified that ‘Prebiotic’ and ‘Probiotic’ claims are health claims so are not permitted on infant formulas.\(^{15}\)
• Formulas for Special Medical Purposes are covered by separate more lax legislation which permits a description that could imply a health claim.\(^{16}\) See Section 9.
• Manufacturers have the legal right to market products in the UK provided they meet EU Requirements. Regulations in EU member states vary considerably so products that do not meet UK standards can be legally marketed in the UK.\(^{17}\)
• The detailed rules laid down in the Infant Formula and follow-on formula Regulations 2007, have precedence over general food labelling rules in the UK.
• A Department of Health Survey in 2004 found that over a third (34%) of women in the UK believe that infant formulas are very similar or the same as breast milk.
• The ONS infant Feeding Survey 2005 and others commissioned by UNICEF, Save the Children and the National Childbirth Trust in 2005 and 2007 show a profound lack of understanding about the risks of artificial feeding especially amongst younger and less educated parents. In one study around a third of the respondents said advertising gave the impression that infant formula milk was ‘as good as’ or ‘better than’ breastmilk.
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\(^{11}\) REGULATION (EC) No 1924/2006 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 20 December 2006 on nutrition and health claims made on foods http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:012:0003:0018:EN:PDF
\(^{12}\) http://ec.europa.eu/nutclaims/
\(^{13}\) Claims for follow-on formulas and formulas and foods for older babies must be first be authorised according the EU Nutrition and Health Claims claims legislation. To date, although several claims for children’s foods and foods for pregnant women have been authorised, only one health claim for follow-on formulas has been permitted:
“Docosahexaenoic acid (DHA) intake contributes to the normal visual development of infants up to 12 months of age.”
\(^{14}\) Summary Report of The Standing Committee on the Food Chain and Animal Health (SCoFCaH), 22 June 2011
\(^{15}\) Letter from Basil Mathioudakis, European Commission to Mark Toal, UK FSA, 4.10.2007: “The use of the claim “contains prebiotics”, as you correctly mentioned in your letter, is a claim describing a function and therefore has to be considered as a health claim which is currently not foreseen in Directive 2006/141/EC and consequently is not permitted for use for infant formula.”
\(^{16}\) Commission Directive 1999/21/EC of 25 March 1999 on dietary foods for special medical purposes.
3 LEGISLATION AND MARKETING CODES
3.1 UK Legislation:
- The Infant Formula and Follow-on Formula (England) Regulations 2007
- Guidance Notes on the Infant Formula and Follow-on Formula Regulations 2007 (as amended) Revision 2, March 2009
3.2 UK Self Regulatory Codes:
- The UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (CAP Code)
- The UK Code of Broadcast Advertising (BCAP Code)
- IDACE/IFM and company codes of Practice
3.3 EU Legislation:
- Commission Directive 2006/141/EC of 22 December 2006 on infant formulae and follow-on formulae and amending Directive 1999/21/EC
- COMMISSION DIRECTIVE 2006/125/EC of 5 December 2006 on processed cereal-based foods and baby foods for infants and young children
- Commission Directive 1999/21/EC of 25 March 1999 on dietary foods for special medical purposes (which in turn refers to the Council Directive 18.12.1978 on the approximation of the laws of Member States relating to the labeling, presentation and advertising of foodstuffs for sale to the ultimate consumer.
- Commission Regulation (EC) No 953/2009 of 13 October 2009 on substances that may be added for specific nutritional purposes in foods for particular nutritional uses.
- Nutrition and Health Claims Regulation 1924/2006 on nutrition and health claims made on foods.
- EU Register On Nutrition & Health Claims providing an updated list of all the permitted health and nutrition claims.
- Food Safety Regulation 178/2002/EC of the European Parliament and of the Council (OJ No. L31, 1.2.2002, p.1) lays down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety.
- Food Labelling Directive 2000/13/EC on the approximation of the laws of Member States relating to the labelling, presentation and advertising of food, OJ No. L 109, 6.5.2000, p.29, as amended
- Novel Foods Regulation (EC) No. 258/97 of the European Parliament and of the Council concerning novel foods and novel food ingredient laying out detailed rules for the authorisation of novel foods, ingredients and processes.
- GM Foods Commission Regulation (EC) No. 1829/2003
- Pesticides Regulation (EC) No. 396/2005 on maximum residue levels of pesticides in or on food and feed of plant and animal origin OJ L 158, 21.6.2005, p. 6–9
- Lisbon Treaty: http://europa.eu/lisbon_treaty/index_en.htm
- Council Directive 92/52/EEC of 18 June 1992 lays down harmonised rules with respect to infant formulae and follow-on formulae intended for export to third countries.
---
18 http://www.legislation.gov.uk/uksi/2007/3521/contents/made
19 http://www.food.gov.uk/multimedia/pdfs/guidancenotes2008amendmar09.pdf
20 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:401:0001:0001:EN:PDF
21 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31999L0021:EN:NOT
22 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:1979:033:0001:0014:EN:PDF
23 http://ec.europa.eu/nuhclaims/
• Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair business-to-consumer commercial practices in the internal market and amending Council Directive 84/450/EEC, Directives 97/7/EC, 98/27/EC and 2002/65/EC of the European Parliament and of the Council and Regulation (EC) No 2006/2004 of the European Parliament and of the Council ('Unfair Commercial Practices Directive').
3.4 LEGISLATION AND GUIDANCE ON CONTAMINANTS:
• Joint FAO/WHO Workshop on Enterobacter Sakazakii and Other Microorganisms in Powdered Infant Formula, Geneva, 2-5 February 2004
• COMMISSION DIRECTIVE 2011/8/EU of 28 January 2011 amending Directive 2002/72/EC as regards the restriction of use of Bisphenol A in plastic infant feeding bottles
• COMMISSION REGULATION (EC) No 1441/2007 of 5 December 2007 amending Regulation (EC) No 2073/2005 on microbiological criteria for foodstuffs
3.5 RELEVANT CODEX STANDARDS
• Codex Standard for Infant Formula and Formulas for Special Medical Purposes Codex STAN 72-1981 Formerly CAC/RS 72-1972. Adopted as a world-wide Standard 1981. Amended 1983, 1985, 1987. Revision 2007
• Codex Guidelines for Use of Nutrition and Health Claims cac/gl 23-1997, Rev. 1-2004
• Codex Standard for Canned Baby Foods 1 Codex Stan 73-1981 (amended 1985, 1987, 1989)
• Codex Standard for follow-up formula codex stan 156-1987 (amended 1989)
• Codex General Standard for the Labelling of Prepackaged Foods (Codex Stan 1-1985)
• Standard for Labelling of and Claims for Foods for Special Medical Purposes (Codex Stan 180-1991)
• Codex Standard for Cereal-based Foods [Codex Stan 74-1981]
• The Code of Hygienic Practice for Powdered Formulae for Infants and Young Children CAC/RCP 66-2008
• Guidelines on Formulated Supplementary Foods for Older Infants and Young Children (CAC/GL 08-1991) (currently under review)
• Code of Ethics for International Trade in Food Including Concessional and Food Aid Transactions (Adopted 1979; revised 1985 and 2010)
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24 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2005:149:0022:0039:EN:PDF
25 http://europa.eu/rapid/pressReleasesAction.do?reference=IP/11/229&format=HTML&aged=0&language=EN&guiLanguage=en
BPA is widely used in the production of plastic baby bottles. The ban which also covers the placing on the market and import into the EU of baby bottles containing BPA. Meanwhile, the industry announced that they would voluntarily withdraw baby bottles containing BPA by mid 2011. Canada has officially declared BPA a toxic substance because of its adverse effects on human health and the environment. Six US manufacturers are removing BPA from bottles sold in the US, but not from other markets.
26 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:322:0012:0029:EN:PDF
The BIOHAZ Panel of EFSA issued an opinion on Bacillus cereus and other Bacillus spp. in foodstuffs on 26 and 27 January 2005. It concluded that one of the major control measures is to control temperature and to establish a system based on hazard analysis and critical control point principles. Dehydrated foods, in which the presence of spores of pathogenic Bacillus spp. is frequent, might permit the growth of Bacillus cereus once rehydrated in warm water. Some dehydrated foods, including dried infant formulae and dried dietary foods, are consumed by potentially fragile consumers. In line with the EFSA opinion, the numbers of Bacillus cereus spores in dried infant formulae and dried dietary foods should be as low as possible during processing and a process hygiene criterion should be laid down in addition to good practices designed to reduce delay between preparation and consumption.
27 Baby Milk Action/ IBFAN Briefing on Codex. Revised April 2012
Codex items currently in discussion with relevance for baby food marketing:
- Proposed Draft Revision Of The Guidelines On Formulated Supplementary Foods For Older Infants And Young Children
- Proposed Draft Amendment Of The Standard For Processed Cereal-Based Foods For Infants And Young Children (Codex Stan 74-1981) To Include A New Part B For Underweight Children
- Proposal To Review The Codex Standard For Follow-Up Formula (Codex stan 156-1987)
The following Codex Committees are relevant:
- Nutrition and Foods for Special Dietary Uses (CCNFSDU)
- General Principles (CCGP) The Code Of Ethics was under review. IBFAN managed to maintain a reference to the International Code and Resolutions.
- Food Labelling (CCFL)
- Food Additives and Contaminants (CCFAC)
- Food Hygiene (CCFH)
- Codex Alimentarius Commission (CAC)
3.6 IBFAN’s concerns about CODEX – the rise of follow-on milks
IBFAN first worked on Codex issues in 1987 when the follow-on milk standard was passed. WHO was involved in this controversial move and asked for information about the Baby Milk Action and Health Visitors’ Association campaign to follow-on formulas being promoted for babies of 4 months. There was much concern that their high solute load was unsuitable for young babies (HVs reported newborns being fed them). An analysis by Prof Michael Crawford at London Zoo, had shown that these milks were closer to rhinoceros milk than human milk. Although the Codex Standard stated that follow-up formula are “suitable for infants from the 6th month on and for young children” the fact that a Codex standard was adopted at all served to legitimize them. The World Health Assembly had already, in 1986, described them as ‘not necessary’.
The establishment of the World Trade Organisation (WTO) in 1995 gave Codex a new status and importance since WTO is mandated to refer to Codex Standards in trade disputes and governments use Codex as a basis for legislation. At the same time IBFAN started work on the revision of the 1981 Codex infant formula standard and later, the Cereal-Based baby food standard. If the standards could be brought into line with World Health Assembly Resolutions, Member States would be able to implement them without fear of challenge.
The deliberations on these two standards took place mainly in Germany in the industry-dominated Nutrition Committee (CCFSNDU) The bad chairing of this committee helped the baby food industry in its efforts to lower the standards so that as many products as possible could be exempt from the Code’s restrictions. The Food Labelling Committee (CCFL) in Canada, in contrast, was much fairer, and there IBFAN, with the support of the Netherlands, succeeded in getting strong wording banning claims on all foods for infants and young children into the Codex Guidelines for Health and Nutrition claims (stronger wording than the WHA Resolutions at that time). The Guidelines fed into the deliberations on nutrition and by the time the two standards were adopted in 2007 many key provisions of the International Code and WHA Resolutions had been included and most claims prohibited. The industry and EU Commission’s move to have a separate standard for formulas for special medical purposes was blocked but sugar levels in
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28 WHA Res 39.28.
baby foods remain far to high\textsuperscript{29} and there continue to be problems over transparency, the independence of the advisory panels and the lack of distinction between different types of NGO observers.
Many of these issues, including the relevance of the WHA resolutions continue to be contentious.\textsuperscript{30} At the November 2011 Nutrition meeting (CCNFSDU) the US and the EU opposed the inclusion of references to the WHA Resolutions, WHO clarified that it was indeed appropriate to cite them: “While the WHA Resolutions are not legally binding under the constitution – it doesn’t mean that the Resolutions are just paper and devoid of effect. [They] constitute the international practice and a consensus language that is also used in other international fora, for instance they are used customarily in WTO litigations.
\textsuperscript{29} \textit{EU and US block Thailand’s proposal to reduce sugar in baby foods} FAO/WHO Codex Nutrition Committee (CCFSNDU) Chiang Mai, Thailand, 3rd November 2006, \url{http://www.ibfan.org/news-2006-eu_us.html}.
\textsuperscript{30} \textit{The Business of malnutrition: breaking down trade rules to profit from the poor.} “The extensive food industry presence – the norm for Codex meetings. 40% of the 268 delegates were food industry, with 59 attending as members of Business Interest NGOs (BINGOs) and 49 included on government delegations – some even heading these delegations. For example, the Mexican delegation, which made many industry-friendly interventions, was 100% industry, with US baby food companies Mead Johnson and Abbott alongside Kellogg’s and Coca Cola. Germany hosted the meeting and 12 of its 15 delegates were industry, including baby food giants, Milupa (Danone) and Nestlé, alongside Coca Cola, Kraft, Merk, and others.” \url{http://info.babymilkaction.org/pressrelease/pressrelease24nov110}
4 PARNUTS - historical background
Article 152(1) EC: “A high level of human health protection shall be ensured in the definition and implementation of all Community policies and activities.”
The baby food issue highlights conflicting values that lie at the heart of the European Union (EU). Since its establishment in 1957 one of the aims of the EU is to harmonise trade rules and encourage the free movement of goods within the community. At the same time the EU Treaty states: “A high level of human health protection shall be ensured in the definition and implementation of all Community policies and activities” and there have been repeated calls from the European Council of Ministers and Parliamentarians that the EU should act to protect health and address food related illnesses.
Since the early 1980s there has been an ongoing struggle between the European Parliament and the European Commission regarding the status and importance of the recommendations adopted by the World Health Assembly. All 10 members of the EU at that time had endorsed the International Code of Marketing of Breastmilk Substitutes and in 1986 the European Parliament voted with a sweeping majority to implement the International Code of Marketing of Breast-milk Substitutes as a European Directive. In the run up to this vote, three EP committees rejected the Commission’s proposals, with the Consumer Committee specifically questioning the scientific basis of including follow-on formulas. The Codex follow-on milk standard (see section 3.5) and ‘paediatric experts’ were used as a justification by the EU Commission.\(^{31}\)
The Lisbon Strategy adopted in 2005, complicates things further since it aims to make the EU not only the biggest, but the most competitive trading block in the world by 2010: “We will further open markets, cut red tape and invest in modern infrastructure so that our enterprises can grow, innovate and create new jobs….Boosting growth and creating jobs are the keys for unlocking the resources needed to meet our economic and social ambitions and are important to reach our environmental objectives…There is no time to lose.” Unless carefully applied, health can easily take second place to the interests of trade.
The marketing of formulas in the UK is covered by horizontal EC legislation that is, in turn governed by a Framework Directive on Foods for Particular Nutritional Uses.\(^{32}\) The legal terms ‘Dietetic’ and ‘Dietary’ were established in 1967\(^{33}\) and the power to initiate and finalize legislation on these Foodstuffs was essentially transferred to the European Commission with limited requirement to consult Parliament. This was way before the Lisbon Treaty in 2009 introduced articles that allowed the EU Member States and European Parliament to delegate power to the European Commission to adopt delegated acts and implementing acts.
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\(^{31}\) In 1985 the Consumer Committee of the EU Parliament questioned the scientific basis for including compositional requirements for follow-on milks in the proposed Directives: “The need of follow-up milks is extremely dubious (page 14) and there is no need whatsoever for a new specially manufactured product.” The European baby food industry (IDACE) responded: “No scientific references are given to support these statements. In the opinion of the paediatric experts of the SCF a standard is necessary. There are many papers which support this scientific opinion…..it should also be noted that FAO/WHO is also developing a Codex standard for follow-up foods.”
\(^{32}\) Directive 89/398/EEC
\(^{33}\) 69/414/EEC: Council Decision of 13 November 1969 setting up a Standing Committee for Foodstuffs: The Council delegates powers to the Commission in respect of foodstuffs and sets up a Committee made up of the Member States with the EU Commission as Chair
74/234/EEC: Commission Decision of 16 April 1974 relating to the institution of a Scientific Committee for Food
Council Directive 77/94/EEC of 21 December 1976 on the approximation of the laws of the Member States relating to foodstuffs for nutritional uses. Establishes the legal use of the term ‘Dietetic’ or ‘Dietary’, specifies labelling requirements/
After a long campaign involving hundreds of NGOs and professional groups, the Directive was adopted. Although some gains had been made, the Directive did go as far as banning advertising outright and follow-on milk advertising was permitted.\(^{34}\) (see also Chronology Page xxx) However the Commission agreed to an important amendment in the final stages – namely Article 14 that: “Advertising of infant formulae shall be restricted to publications specialising in baby care and scientific publications. Member States may further restrict or prohibit such advertising.” This meant that Member States could fulfil their obligations under the Code if they wished.
In subsequent years, although some improvements were made to EU Legislation regarding levels of pesticides, under the oversight of the Commission, many of the gains in relation to marketing were gradually eroded.\(^{35}\) At the Eurodiet Conference in May 2000 the Commission argued that implementing the WHA requirements in full would pose constitutional problems for several countries. In fact advertising restrictions \textit{would} have been admissible provided they were based on considerations of public welfare and provided the restrictions were in line with the basic principle of proportion.\(^{36}\)
Perhaps most importantly, in 1999, despite the opposition of 900 health and development NGOs, the European Commission pressed ahead with the adoption of the \textit{Commission Directive 1999/21/EC of 25 March 1999 on dietary foods for special medical purposes. (FSMP)} This essentially allowed a whole new range of products to be marketed with minimal restrictions.
The Commission now acknowledges that the market has ‘evolved’ since the FSMP Directive was passed and that industry has been exploiting its loopholes. The Commission’s excuse for inaction in 1999 was that: “\textit{labelling, advertising and promotional restrictions, as those applicable to infant formula, were not considered appropriate at the time}” (See Section 10) Because PARNUTS has been such a serious fault line running through the policy-making process in Europe, we have been calling for it to be scrapped in favour of a more transparent and accountable process. PARNUTS discussions have taken place in closed sessions of Experts from Member States and the \textit{Standing Committee on the Food Chain and Animal Health (SCFAH)}, with inadequate and partial summary records.
Because mandatory pre-authorisation of ingredients is not specified in PARNUTs, the Commission has refused allow it – despite requests from Member States and unanimous scientific agreement that the suitability and safety of new should be evaluated by an independent scientific authority prior to introduction into the market.\(^{37}\)
The EU Commission’s role was such a major problem that in 2008 Baby Milk Action made a complaint of maladministration to the European Ombudsman. We alleged that the Commission had failed to protect public health and had ignored Member States’ obligations to implement the \textit{International Code}. After a 20-month investigation, the
\(^{34}\) “Protecting breastfeeding- protecting babies fed on formula. BFLG response to the consultation on the revised Infant Formula and Follow-on Formula regulations. Pages 8-11. 2007
\(^{35}\) IBFAN State of the Code by Country Charts
\(^{36}\) \textit{The constitutional relevance of advertising restrictions for Breastmilk Substitutes in Germany}, presented to Eurodiet by Andreas Adelberger, AGB, May 2000
Implementation of the International Code of Marketing of Breastmilk Substitutes in CEE countries: Can the countries of Central and Eastern Europe (CEE) adopt the International Code of Marketing of Breastmilk Substitutes and Subsequent Relevant World Health Assembly Resolutions (the Code) as a minimum requirement, without affecting any existing legal commitments or prejudicing eligibility to join the European Union(EU)? \textit{Paper commissioned by UNICEF}.
\(^{37}\) See IBFAN PARNUTS Comments: 2012: http://info.babymilkaction.org/sites/info.babymilkaction.org/files/IBFAN%20PARNUTS%20PbyP4.pdf
IBFAN comments 2010: http://info.babymilkaction.org/node/141
European Ombudsman decided not to uphold our complaint, focussing only on whether the Commission carried out “its tasks” adequately. He failed to question the Commission’s analysis of the status of the International Code or its importance saying: “In any case, although the Code was only a recommendation, not an international agreement or convention, and was, therefore, not binding, Directive 2006/141 and other relevant EC legislation have endorsed most of its guiding principles.”
4.1 New developments – the revision of PARNUTs
The Ombudsman decision, although disappointing, seemed to prompt a slight improvement in the Commission’s responses on marketing questions and discussions have now started on the revision PARNUTS Framework Directive.
Aware that PARNUTs has been used to promote all manner of targeted foods and to avoid the Regulations covering health and nutrition claims, the Commission now proposes to abolish the concept of “foodstuffs for particular nutritional uses” (and the terms ‘Dietetic’ and ‘Dietary’ Foods) and replace Directive 2009/39/EC with a new Regulation covering baby formulas and foods. The Commission has gone on record saying that PARNUTs “undermines the functioning of the internal market, creates legal uncertainty for competent authorities, food business operators and while the risks of marketing abuse and distortion of competition cannot be ruled out.”
The Commission states that its aim is to ensure a high level of health protection and the effective functioning of the internal market. It will also establish principles of risk analysis and require the European Food Safety Authority to be consulted ‘on all matters likely to affect public health.’ The Commission has brought links to the pieces of legislation that will be affected together on one link.
Following debates in the European Parliament’s Environment, Public Health and Food Safety Committee and full Plenary, the Council, and the Commission’s Standing Committee on the Food Chain and Animal Health (SCFAH), there will now be three High Level Triologue meetings of MEPs, Commission and Council in September, October and November 2012, with the aim of agreeing new text and an early 2nd reading, possibly before the end of the year under the Cypriot Presidency.
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38 Decision of the European Ombudsman closing his inquiry into complaint 97/2008/(BEH)F against the European Commission http://www.ombudsman.europa.eu/cases/decision.faces/en/4265/html/bookmark We argued that the Official failed to chair the SCoFAH meetings in a fair and objective way because he:(i) produced misleading written statements regarding their proceedings and, as a consequence, misled Member States and others involved in the protection of child health; (ii) failed to consult with others regarding the content of notes for the files of certain “off the record” meetings; (iii) misrepresented the complainant’s views; (iv) failed to take into account Member States’ concerns about the need to protect public health in discussions concerning Directive 2006/141 within the SCoFAH; and (v) failed to follow the advice of SCF in certain areas covered by Directive 2006/141.
39 “This Regulation should establish, among others, definitions of infant formulae and follow-on formulae, processed cereal-based food and baby food, food for special medical purposes and total diet replacement for weight control, taking into account relevant provisions in Commission Directive 2006/141/EC, Commission Directive 2006/125/EC, Commission Directive 1999/21/EC and Commission Directive 1996/8/EC. (17) It is important that ingredients used in the manufacture of the categories of food covered by this Regulation are appropriate to satisfy the nutritional requirements of, and are suitable for the persons to whom they are intended and that their nutritional adequacy has been established by generally accepted scientific data. Such adequacy should be demonstrated through a systematic review of the available scientific data.
40 http://ec.europa.eu/food/food/labellingnutrition/nutritional/index_en.htm
41 On 14 June 2012, the European Parliament adopted its first reading position. The text adopted: http://www.europarl.europa.eu/sides/getDoc.do?type=TA&language=EN&reference=P7-TA-2012-255 On 7 June, the Council of the European Union agreed its ‘general approach’, to give a mandate to the EU Presidency to negotiate with the European Parliament: http://register.consilium.europa.eu/pdf/en/12/st10/st10086.en12.pdf
During the first Parliamentary Reading on 14th June, there were many important amendments proposed, including two key ones by the Socialists and Greens. These called for EU legislation to specifically state that Member States are free to go further and ban the advertising of follow formula and baby foods. These amendments provoked the most debate with much support from the majority of speakers. While gaining strong backing, they were not passed. While Commissioner Dalli, did express willingness to look at an extension of advertising prohibitions to follow-on milks he said the amendment calling for the same for baby foods would affect the internal market too much.
During the Triilogue meetings the EU Commission is likely to insist on maintaining its control of the formation and application of the legislation, aware that this will be tempered by the new co-decision process. Parliament will insist on greater oversight. The Commission will be reluctant to accept other MEP amendments, including the reference to Precautionary Principle, which the Commission argues is already embedded in EU policy.
The new rules should toughen up the safeguards regarding ingredients including establishing a Union List of vitamins, minerals and other substances, however it is unclear whether this will mean mandatory pre-authorisation of all novel and existing ingredients, whether optional ingredients will still be permitted and if so who will approve them, and whether the evaluations for safety and efficacy will require independently funded research and independent systematic reviews of the totality of research.
| The Commission wants to maintain control |
|-----------------------------------------|
| Para 19 on Page 11 of the Council Opinion gives an indication of the level of control that the Commission would like and that the stimulation of innovation (growth of trade in new products) is its main concern: |
“Furthermore, in order to enable consumers to benefit rapidly from technical and scientific progress, especially in relation to innovative products, and thus to stimulate innovation, the power to adopt acts in accordance with Article 290 TFEU should also be delegated to the Commission for the purpose of a regular update of the requirements applying to infant formula and follow-on formula, processed cereal-based food and baby food for infants and young children, food for special medical purposes and total diet replacement for weight control, taking into account all relevant data, including data provided by interested parties. It is of particular importance that the Commission carries out appropriate consultations during its preparatory work, including at expert level. The Commission, when preparing and drawing-up delegated acts, should ensure a simultaneous, timely and appropriate transmission of relevant documents to the European Parliament and Council.”
Once more, breastfeeding, the undisputed safest way to feed all infants, will have to compete with these highly profitable ‘innovative’ products, “resulting from scientific and technological progress – the fruits of industry research.”
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42 MEPs warn of sweet baby milks and call for stricter marketing rules Baby Milk Action press release http://info.babymilkaction.org/pressrelease/pressrelease15jun12
Compromise Amendment by Carl Schlyter, on behalf of the Greens: “Advertising of infant formulae, follow-on formulae and of any other kind of food intended for infants or young children shall be prohibited. This includes advertisements in publications, point-of-sale advertising, giving samples or any other promotional device to induce sales directly to the consumer.”
43 http://register.consilium.europa.eu/pdf/en/12/st10/st10086.en12.pdf
The European Parliament’s agreed position
The amendments adopted in the June 2011 Plenary vote addresses some – not all - of Baby Milk Action’s concerns. MEPs are calling for:
- The safety of foods is stressed before the free movement of goods (Amendment 2)
- The precautionary principle (amendments 9, 10 and 53)
- Stricter safeguards on contaminants and pesticides in baby foods than on other foods (Amendments 15, 17, 62 and 63)
- Slightly stricter controls on claims “The labelling, presentation and advertising of food referred to in Article 1(1) shall be accurate, clear and easy to understand for consumers and must not be misleading. It shall not attribute properties to such products for the prevention, treatment or cure of human disease, or imply such properties.” (Amendment 58 - This could mean the end of the allergy claim)
- Stricter controls on the labeling of follow-on milks – no baby pictures:
“The labelling of infant formula and follow-on formula shall not include pictures of infants, nor shall it include other pictures or text which may idealise the use of the product. Graphic representations for easy identification of the product and for illustrating methods of preparation shall, however, be permitted. Directive 2006/141/EC shall be amended accordingly.” (Amendment 59)
“The dissemination of any useful information or recommendations with reference to the categories of food referred to in points (a), (b), (c) and (ca) of Article 1 (1) may be made exclusively to persons having qualifications in medicine, nutrition or pharmacy. Additional information disseminated by healthcare professionals to the final consumer shall only be of a scientific and factual nature and shall not contain advertising.”
- More transparency (Amendment 76);
- More oversight from the European Parliament and EFSA,
- Post market surveillance (Amendments 54 and 68);
- Controls on exports;
- Caution on Nano technology;
- EFSA review of formulas for older babies before deciding what to do (amendment 81)
- Clearly defined Union List of vitamins, minerals and other substances (this is not the same as pre-authorisation of ingredients) Amendment 37.
- Slightly stricter controls on evaluating new ingredients (Amendment 14, 57 and 88 - do not require independently funded evidence – referring the ‘generally accepted’ or independent reviews and independently evaluated science and medical opinion.)
- prohibition of the term “specialized nutrition” (amendment 56) Amendments 30 and 31 ease the way for SMEs.
In addition to the above amendments, which are for the most part welcome, one bad Amendment (no 13) was adopted on formulas for LBW babies. See section 8
Amendment 91 allows the Commission freedom to authorize new foods “resulting from scientific and technological progress – the fruits of industry research” - on the market temporarily pending amendment of the delegated acts – but only after EFSA has been consulted.
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44 http://www.europarl.europa.eu/sides/getDoc.do?type=TA&language=EN&reference=P7-TA-2012-255
5 Optional Ingredients
“We find the case for labelling infant formula or follow on formula with health or nutrition claims entirely unsupportable. If an ingredient is unequivocally beneficial as demonstrated by independent review of scientific data it would be unethical to withhold it for commercial reasons. Rather it should be made a required ingredient of infant formula in order to reduce existing risks associated with artificial feeding. To do otherwise is not in the best interests of children, and fails to recognise the crucial distinction between these products and other foods.” The UK Government’s Scientific Advisory Committee on Nutrition (SACN) 2007
The UK Regulations state:
4. No person shall market or otherwise represent a product as suitable for satisfying by itself the nutritional requirements of normal healthy infants during the first months of life until the introduction of appropriate complementary feeding unless that product is infant formula.
The EU Directive requires that
“Infant formulae and follow-on formulae shall not contain any substance in such quantity as to endanger the health of infants” and that all products must contain the essential ingredients specified in annex I of the EU Directive.
Annexes to the law set out terms for the essential compositional requirements for infant formula and follow-on formula, which may be marketed for use from 6 months of age. Manufacturers are allowed to add other ingredients to both infant formulas and follow-on formulas on an optional basis as they see fit
“provided their suitability ‘for particular nutritional use by infants from birth has been established by generally accepted scientific data and demonstrated in accordance with paragraph (2)’ and that (2) Suitability shall be demonstrated through a systematic review of the available data relating to the expected benefits and safety considerations as well as, where necessary, appropriate studies, performed following generally accepted expert guidance on the design and conduct of such studies”.
Some of these optional ingredients are specified in the legislation – others are not. When placing a new infant formula on the market, manufacturers must “notify the competent authority” in the particular country by forwarding a model of the label. They should also be ready to produce the required evidence, however Member States are not obligated to ask for this. There is no requirement for Manufacturers to notify follow-on formulas.
With no pre-market authorisation of ingredients, nor any requirement for efficacy or safety to be proven by independently-funded studies, manufacturers can add or withhold any ingredient they choose in order to gain competitive advantage. In effect European babies have been subjected to a mass uncontrolled trial. The commercial pressure to add ingredients to formulas and to contravene the International by promoting products as closer to breastmilk - the recognised ‘gold standard’ - is evident.
A new infant formula launched by Hipp in June 2012, uses claims not listed in Annex IV of the Infant Formula and Follow-on Formula Regulations (so contravening regulation 21). Hipp claims that its “unique organic formula combines friendly bacteria with other important
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45 http://www.sacn.gov.uk/pdfs/position_statement_2007_09_24.pdf
46 The Infant Formula and Follow-on Formula (England) Regulations 2007, Section 4 Prohibition on the marketing of products other than infant formula for normal healthy infants
http://www.legislation.gov.uk/uksi/2007/3521/pdfs/uksi_20073521_en.pdf
ingredients like LCPs and prebiotic oligosaccharides – we call it Combiotic.”\textsuperscript{47} For more examples see monitoring reports sent separately.
In 1996, Investment advisors Hambrecht & Quest famously advised investing in Martek, manufacturer of an LCP supplement called Formulaid on the grounds: “The history of infant formula has shown that virtually all similar examples have led to wide-scale introduction of such additives into infant formula, even if there was no evidence that the additives were important. Infant formula is currently a commodity market with all products being almost identical and marketers competing intensely to differentiate their product. Even if Formulaid had no benefit we think that it would be widely incorporated into most formulas as a marketing tool and to allow companies to promote their formula as ‘closest to human milk.’
Currently all non-organic standard infant formulas on the UK market contain nucleotides, Long Chain Polyunsaturated Fatty Acids (LCPs, specifically DHA and AA) and structured tryglycerides even though there is no proven benefit. Oligosaccharides are added to some formulas
6 History of safe use
The European Society of Pediatric Gastroenterology Hepatology and Nutrition (ESPGHAN) made comments in the conclusion of the Codex International Expert Group report on the composition of infant formulae questioning the industry’s use of the term ‘history of safe use’.\textsuperscript{48} ESPGHAN, a body that takes funding from the baby food industry and often supports its position, in this instance usefully pointed out that problems with infant formulas are not always disclosed, and one should certainly not assume that evidence from industry sponsored consumer phone lines constitute a ‘history of safe use.’
“ESPGHAN wishes to emphasize that there is no evidence available to show that the evaluation of consumer phone line services is sensitive enough to detect adverse effects of infant formulae. On the contrary, for example the very severe adverse effects recently induced by an infant formula with inadequate contents of vitamin B1 (thiamine), which resulted in failure to thrive, severe neurological damage, severe lactic acidosis and even infant deaths (2-4), were not detected by the distributor’s consumer phone line services....”
\textsuperscript{47} hipp4hcps.co.uk
\textsuperscript{48} ESPGHAN Comments on the Circular Letter CL 2005/53-NFSDU and on the Synopsis of comments received until 30.4.05 (prepared by Germany) “The question arises whether the ranges of nutrient levels in infant formulae that are reported by ISDI, without documented occurrence of side effects, suffice to establish a “history of safe use”, or even of adequacy of such nutrient levels for infant formulae. ISDI suggests that a history of apparently safe use of products might be based on the use of commercially produced infant formula and the monitoring of spontaneous consumer reports of observations that may indicate a problem with a specific batch of formula. In some areas, such as Europe, Israel and the USA, there are consumer phone line services have been established where parents may call in, usually free of charge, to place questions or complaints to the manufacturer or distributor of an infant formula. ISDI explains that such customer reports are monitored and should provide a tool for post-marketing surveillance of infant formula safety. Based on the evaluation of these consumer phone line services and the absence of detected serious side effects, ISDI implies that a history of safe use has been established for the nutrient levels reported in their compilation. ESPGHAN wishes to emphasize that there is no evidence available to show that the evaluation of consumer phone line services is sensitive enough to detect adverse effects of infant formulae.”
7 Health and nutrition Claims – key points
- The UK Regulations currently permit the following for infant formulas:
- six nutrition claims (Lactose only, Lactose free, added LCP or an equivalent nutrition claim related to the addition of docosahexaenoic acid, Taurine, fructose-oligosaccharides and galacto-oligosaccharides, nucleotide)
- one disease risk reduction claim (Reduction of risk to allergy to milk proteins).
- Claims for follow-on formula, formulas and foods for older babies must be first be authorised according the EU Nutrition and Health Claims legislation.
- To date, although several claims for children’s foods and foods for pregnant women have been authorised, only one health claim for follow-on formulas has been permitted: “Docosahexaenoic acid (DHA) intake contributes to the normal visual development of infants up to 12 months of age.”
- Although the infant formula regulations do not permit a DHA ‘health’ claim on infant formulas, they do allow a ‘nutrition’ claim. Because products share the same branding and similar packaging, ‘health’ claim messages on products for older infants and young children are transferred.
- Parents assume that claims and ingredients undergo strict evaluation.
- The packaging and information materials idealise the products in other ways, in addition to health and nutrition claims. For example claims that the product is good for ‘hungry babies’ or may make babies sleep better. Images of hearts, shields, encircling arms etc also signify care, love and safety.
- The EU Commission has clarified that a brand name or trademark cannot be an implied health or nutrition claim unless that claim is legally permitted.
- The EU Commission has clarified that ‘Prebiotic’ and ‘Probiotic’ claims are health claims so are not permitted on infant formulas.
- Formulas for Special Medical Purposes are covered by separate more lax legislation which permits a description that could imply a health claim. There is ongoing discussion about this. (See also Section 9).
**Infant formula trademark that could be construed as a health claim**
One delegate asked whether it was permissible for an infant formula to bear a trademark that could be construed as a health claim. MS were reminded that this was discussed at Standing Committee in June 2009 when the conclusion was that, in the case of infant formula, a trademark constituting a nutrition or health claim may only be used where it is accompanied by a specific claim listed in annex IV to Directive 2006/141/EC.
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49 *The Infant Formula and Follow-on Formula (England) Regulations 2007*,
50 *Regulation (Ec) No 1924/2006 Of The European Parliament And Of The Council of 20 December 2006 on nutrition and health claims made on foods*
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:012:0003:0018:EN:PDF
51 http://ec.europa.eu/nutriclaims/
52 “Infant formula trademark that could be construed as a health claim One delegate asked whether it was permissible for an infant formula to bear a trademark that could be construed as a health claim. MS were reminded that this was discussed at Standing Committee in June 2009 when the conclusion was that, in the case of infant formula, a trademark constituting a nutrition or health claim may only be used where it is accompanied by a specific claim listed in annex IV to Directive 2006/141/EC. Summary Report of The Standing Committee on the Food Chain and Animal Health (SCoFCaH), 22 June 2011
53 Letter from Basil Mathioudakis, European Commission to Mark Toal, UK FSA, 4.10.2007: “The use of the claim “contains prebiotics”, as you correctly mentioned in your letter, is a claim describing a function and therefore has to be considered as a health claim which is currently not foreseen in Directive 2006/141/EC and consequently is not permitted for use for infant formula.”
54 Commission Directive 1999/21/EC of 25 March 1999 on dietary foods for special medical purposes.
55 Taken from DH Update from the European Commission’s Working Group meeting on nutrition and health claims, 18 June and informal meeting about flexibility
The majority if not all the studies that show benefits of the optional ingredients commonly used in formulas are conducted or funded by baby food companies. While the potential for bias is present in all research, and ‘independence’ from commercial interest does not ensure quality, misleading findings and unintended consequences are reduced if research is commissioned and funded by a disinterested party rather than one active in the market and when academic rigor can be demonstrated in the research process. Problems are compounded by publication bias where trials with negative outcomes are less likely to be published. Infant feeding studies are often considered ‘proprietary’ and many are not published in peer reviewed journals.
7.1 The DHA claim
In 2009 the European Food Safety Authority (EFSA) gave a positive opinion on a DHA health claim for visual acuity. EFSA stated that it could not have reached its conclusion “without considering the studies claimed by the applicant as proprietary.” In this case the research was eventually published.
Despite the absence of consistent peer-reviewed independent evidence of a causal relationship between DHA-fortified formulas and better visual acuity in term babies, and in conflict with of many leading health bodies, the DHA claim was approved and can now be used on all EU baby formulas and foods.
In April 2011 the European Parliament voted against the DHA health claim - but not by a large enough majority to stop the Commission authorising it.
7.2 Assessing the risk of the DHA claim
EU Health Claims regulations require EFSA to assess only the ‘efficacy’ of the claim not the risk. The risk is considered by the Commission and SCoFCAH. However, on 25th March 2011, 10 days before the European Parliament was to vote on the DHA claim, EFSA’s Director of Risk Assessment, Riitta Maijala, stepped into the debate by writing to the Commission, saying “We are unaware of any factor in breast milk which is needed for DHA to exert its “optimal” effect.”
IBFAN takes a different view. Synthesised DHA added to formulas are in a different biological environment to breastmilk, which is a species-specific, living substance. Formula contains no co-enzymes or co-factors to enable the fats to work optimally as they do in breastmilk. Indeed the
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56 EFSA published three opinions on DHA and ARA in January and March 2009: www.efsa.europa.eu/en/efsajournal/doc/941.pdf www.efsa.europa.eu/en/efsajournal/doc/1003.pdf www.efsa.europa.eu/en/efsajournal/doc/1004.pdf
57 “WHO does not have a recommendation about the addition of docosahexaenoic acid (DHA) to formula milk….to date no solid evidence exists to be able to say that adding DHA to infant formula will have important clinical benefits. Were WHO to give such a recommendation, it would have to follow a strict guideline development process based on grading of all available evidence collected through systematic reviews by expert panels free from conflict of interest.” WHO to Glenis Willmott MEP 6.4.11: http://info.babymilkaction.org/sites/info.babymilkaction.org/files/WHO%20DHA_0.PDF
The 2007 Cochrane Library concluded: “This review found that feeding term infants with milk formula enriched with LCPUFA had no proven benefit regarding vision, cognition or physical growth.”
58 EFSA to EU Commission 3.9.09. In a letter to the European Commission in September 2009, EFSA said: “The evidence, however, does not establish that starting DHA supplementation at 4-6 months in infants who had received a control (DHA-free) formula in the first months of life would have an effect on the visual development of those children… There are no data from specific randomised control trials supporting a benefit of DHA supplementation starting at 6 months of life in infants fed a DHA-free formula in the first 6 months of life…”
59 European Parliament votes to block DHA health claim - but not by a large enough majority to guarantee action by the Commission http://info.babymilkaction.org/pressrelease/pressrelease06apr11
60 Riitta Maijala to Eric Poudelet, EU Commission. 25.3.11
US FDA, commented to Martek (the DHA manufacturer) in 2001: “The bioactive fatty acids ARA and DHA when consumed in mature human milk are part of a complex matrix that includes, for example, linoleic acid, alpha-linolenic acid, and other polyunsaturated fatty acids…important physiologic considerations relative to the matrix are not accounted for by the simple addition of LCPUFAs to infant formula.”\(^{61}\)
The Cornucopia Institute in Wisconsin, has followed the DHA issue carefully for many years. It used US Freedom of Information legislation to obtain information on concerns registered with the Food and Drug Administration (FDA) about adverse reactions to DHA/ARA-supplemented formulae. The FDA questioned the adequacy of information to determine safety and efficacy of the clinical trials required for pre-market approval of these LCPs. Cornucopia and the National Alliance for Breastfeeding Advocacy (NABA) petitioned the FDA for labels to warn of the possibility of an adverse reaction to DHA/ARA-supplemented formula.\(^{62}\)
The sources of LCPs in Cow & Gate and Aptamil products are vegetable and fish oils, whilst the sources of LCPs in SMA products are fungal and algal oils. The use of fish oils means that many milks are not suitable for vegetarians. Hipp Organic is the most recent company to have added LCPs to their products. A representative of the company told us that clinical trials using their product are currently underway in Europe. The decision to market the product in advance of clinical trials was based on a history of safe usage of LCPs, at the same level, in infant milks produced by other manufacturers. The source of LCPs in Hipp powdered formula milk is fish oils, whilst LCPs in the ready-to-feed formula are algal. Supplementation of formula with LCP can increase the retail price by 5%-25% and single cell oils produced by micro-organisms are likely to be the oils of choice commercially in future (Chávez-Servín et al, 2008). There are therefore considerable cost implications for welfare food schemes and families if these fats are considered essential ingredients in all infant formula.
For a full analysis see Infant Milks in the UK - A practical guide for health professionals, May 2012. First Steps Nutrition Trust).
**Possible research question:**
Do parents who want to breastfeed and fail choose a product that they think is closer to breastmilk and are they likely to go on using these products much longer?
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\(^{61}\) FDA Agency Response Letter GRAS Notice No. GRN 000041 CFSAN/Office of Premarket Approval http://www.fda.gov/Food/FoodIngredientsPackaging/GenerallyRecognizedasSafeGRAS/GRASListings/ucm154126.htm
\(^{62}\) *Replacing Mother, Imitating Human Breast Milk in the Laboratory* (Jan 08) www.cornucopia.org
8 Formulas for LBW infants
WHO on Feeding of low-birth-weight infants\(^{63}\)
*WHO recommends that low-birth-weight (LBW) infants, including those with very low birth weight (VLBW), should be fed mother’s own milk. If these infants cannot be fed mother’s own milk, they should be fed donor human milk (in settings where safe and affordable milk banking facilities are available or can be set up) or standard infant formula. Very-low-birth-weight infants who cannot be fed mother’s own milk or donor human milk should be given preterm infant formula if they fail to gain weight despite adequate feeding with standard infant formula. Low-birth-weight infants who are able to breastfeed should be put to the breast as soon as possible after birth when they are clinically stable, and should be exclusively breastfed until six months of age. Low-birth-weight infants who need to be fed by an alternative oral feeding method should be fed by cup or spoon and should be fed based on the infants’ hunger cues, except when the infant remains asleep beyond three hours of the last feed. Implementation of these recommendations will help to reduce mortality and severe morbidity among these infants while helping in their growth and neurodevelopment.*
Formulas for low-birth weight infants are currently marketed in line with Directive 1999/21/EC on foods for special medical purposes (FSMP) rather than the more stringent Directive 2006/141/EC on infant formulae and follow-on formulae. (see Section 10)
Although some breastfed infants require supplements of vitamins and minerals, occasionally protein, in order to thrive, the need for LBW formulas is very limited. Supplements can be administered within the definition of “exclusive breastfeeding” if medically indicated for the very small proportion of preterm and low birth weight babies (1% of UK births <1500g).
Of the 7% of LBW infants >1500g - almost all thrive very well when fed exclusively on breast milk. Indeed the protection of breastfeeding in this vulnerable group is particularly important. Randomised trials show that infants who are not breastfed are at approximately 5 times greater risk of a condition called necrotising enterocolitis. This has a mortality of approximately 20% and a significant long-term morbidity. The global consequences for the whole population of low birth weight infants in third countries are even more serious. As with formulas for special medical purposes, it is in the manufacturers interest to have numerous categories of products under the Medical Foods Directive umbrella – especially if they all share brand names and packaging.
During the Parliament’s First reading in June 2012 the last minute proposal put forward by UK MEP Julie Girling was adopted. This distorted WHO’s position on LBW formulas saying: “Nonetheless, low birth-weight infants and pre-term infants often have special nutritional requirements which cannot be met by mother’s own milk or standard infant formula”.
Thankfully, the general approach agreed by the Permanent Representatives and the Council has slightly better text: (16a) The nutritional requirements of low birth weight and/or preterm infants depend on the medical condition of the infant, in particular on his weight in comparison with that of an infant in good health, and on the number of weeks the infant is premature. It is to be decided on a case by case basis whether the infant’s condition requires the consumption under medical supervision of a formula adapted for the dietary management of his specific condition.
---
\(^{63}\) [http://www.who.int/elena/titles/supplementary_feeding/en/index.html](http://www.who.int/elena/titles/supplementary_feeding/en/index.html)
9 Foods for Special Medical Purposes
The majority of the world’s sick babies urgently require breastfeeding for survival. All babies, and especially sick babies, need the protection of the *International Code* and subsequent WHA Resolutions.\(^{64}\)
In 1999, despite the concern of over 900 NGOs, the European Commission pushed through the adoption of a Directive on Medical Foods (1999/21/EC) (FSMP Directive) – at the same time as the entire *Santer Commission* was forced to resign by the Parliament as result of fraud and corruption scandal. This the first time a Commission had been forced to resign *en masse* and represented a shift of power towards the Parliament.[24] In response to the scandal the *European Anti-fraud Office* (OLAF) was created.
The FSMP Directive contained none of the safeguards of the *International Code* and WHA Resolutions and opened the door to widespread abuse. The only safeguard is a requirement that the label states that the product must be used under medical supervision. (See section 3.5 for the impact of this Directive on Codex.)
Since 2000 the market for ‘specialised formulas’, of no proven value has grown with formulas claiming to ‘cure’ or ‘solve’ all manner of normal feeding occurrences such as regurgitation and slow growth. The Directive does not curtail advertising or promotional strategies such as free and low-cost samples and supplies, promotional ‘educational’ literature for parents or health claims.\(^{65}\)
The baby food industry claims that the mandatory breastfeeding statement is inappropriate for many products and that it would “*undermine the confidence of parents in the special diet necessary for their infant.*” IBFAN contest this saying that the only products for which the ‘breastfeeding is best’ statement may appropriate, are the formulas for the less than 1000 babies where breastfeeding is totally contraindicated, such as formulas for babies with Maple Syrup Disease (0.0005% of 129 million).\(^{66}\)
As more countries are clamping down on follow-on milk advertising, companies are building new markets for formulas for 1-5 year-olds. EU policy makers are in a quandry - aware that this is a marketing scam and that there is no evidence that fortified formulas for older babies are needed, but unable or perhaps unwilling to ban them. Young children need to eat real foods ideally alongside continued breastfeeding. Infant formula can go on being used after 6 months.
\(^{64}\) The number of infants with autosomal, recessive, genetically-transferred metabolic disorders that need full or partial feeding with specialised formulas is extremely small Even though the conditions are under-reported because screening for/and diagnosis of these very specialised conditions is not universally accessible, the total global number is probably less than 25,000 babies. In Germany, where screening for such conditions is more common,\(^{64}\) the incidence of *PKU* 1 in 10,000\(^{64}\), *Galactosaemia* 1 in 35,000 and *Maple Syrup Urine Disease* 1 in 200,000. Extrapolating from these figures to the whole world, it is likely that 18,428 babies are born with PKU, 3,685 with Galactosaemia and 645 with Maple Syrup Disease – a total of 22,758 each year. There may be other even rarer conditions where breastfeeding could be contraindicated.
\(^{65}\) The Medical Food Directive allows implied health claims and disease risk reduction claims:4. *The labelling shall also include:(a) the statement "For the dietary management of..." where the blank shall be filled in with the diseases, disorders or medical conditions for which the product is intended,(c) a description of the properties and/or characteristics that make the product useful in particular, as the case may be, relating to the nutrients which have been increased, reduced, eliminated or otherwise modified and the rationale of the use of the product;*
\(^{66}\) Galactosaemic babies who cannot tolerate breastmilk are usually fed on lactose-free formulas. These formulas normally carry a ‘breastfeeding is best’ notice because they are used by vegans and others avoiding dairy products. Other conditions such as *PKU* require formulas formula without *phenylalanine* but these infants benefit from the addition of partial, carefully managed breastfeeding, so the ‘breastfeeding is best’ statement would not cause a problem.
The new formulas invariably share brands and logos with infant formulas, so promote the whole range. They are also expensive and with high levels of sugar, increase the risk of obesity. But the alluring claims trigger fears in parents that real foods miss essential nutrients.
**Summary Report of the Standing Committee on the Food Chain and Animal Health 22 June 2012.**
*Exchange of views of the Committee on the interaction between Directive 1999/21/EC on foods for special medical purposes and Directive 2006/141/EC on infant formulae and follow-on formulae*
Ireland calls for confirmation that ‘special’ formulas currently covered by the Medical Foods Directive will not be covered by the Directive for standard formulas. France called for confirmation that they would be.
In the exchange the Commission acknowledged that the market has ‘evolved’ since the FSMP Directive was passed and that industry is now exploiting its loopholes. The Commission’s excuse for inaction in 1999 was that: “labelling, advertising and promotional restrictions, as those applicable to infant formula, were not considered appropriate at the time”
“It has to be admitted that the market situation has evolved since. Differing interpretation and enforcement of the definition of FSMPs by national authorities has contributed to a proliferation of these products in the market (the examples of products based on rice protein, not allowed for infant and follow-on formula, and of some anti-regurgitation products were mentioned). This in turn led to the use of wider and often similar distribution channels as those for infant formula and inevitably to labelling, advertising and marketing practices that were taking advantage of the absence of relevant rules for these products. The Commission stressed the important role of the competent authorities in verifying the compliance of the products presented as FSMP with the relevant definition as laid down in Article 1 of Directive 1999/21/EC in order to avoid any abuse of the legislation. On the basis of the discussion, and taking into consideration the letter of the lawanda the intention of the legislator when those measures were adopted, the Committee concluded the following:
Foods for special medical purposes intended specifically for infants, covered by the definition of Article 1 of Directive 1999/21/EC, are specific products and are distinct from infant formulae and follow-on formula. Therefore, foods for special medical purposes intended specifically for infants do not fall under the scope of Directive 2006/141/EC and are not subject to the provisions of that Directive except when specifically mentioned in Directive 1999/21/EC (see point 4 of the Annex of Directive 1999/21/EC).
Specific labelling requirements have been laid down in Directive 1999/21/EC taking into account the specificity of the product covered by that Directive (e.g. the medical conditions for which the product is intended, the mandatory statement on the label that the product must be used under medical supervision etc.). It is therefore not appropriate to apply the same labelling and advertising provisions as established in Directive 2006/141/EC to those products.
However, the Committee took note of the evolution in the market and considered that in the of the revision of the framework legislation on foods for particular nutritional uses and acts thereof, further consideration should be given to the inclusion of certain relevant specific provisions for FSMPs.”
10 Formulas for older babies – Growing up, toddler milks
- A report by the German Federal Institute for Risk Assessment (BfR) (16.08.2011) found that ‘toddler’ milk does not offer any advantage compared to reduced fat cow milk. “From a nutritional and physiological point of view these special toddler milks are not necessary”, says BfR President, Professor Dr. Andreas Hensel. “The manufacturers of toddler milk drinks often refer to high consumption amounts on the packaging of their products. According to these recommended consumptions children would consume through children’s milk alone high amounts of macronutrients and micronutrients. Within the framework of the overall diet this would favour in the long-term an oversupply with all nutrients. From a nutritional physiological and health point of view this is problematic.”
- The Italian Consumer Association Altoconsumo analysed these products and published a statement very similar to the German one in 2009.
- A survey in 2010 by the Hong Kong Department of Health (HKSAR) found that “children who drank more milk (mainly formula milk) than the recommended volume generally consumed smaller amounts of grains, vegetables and fruits. Use of the bottle and parents’ misconceptions about the nutritional benefits of formula milk might have contributed to the high milk intake and the choice of milk.”
- Prolonged Bottle Use and Obesity at 5.5 Years of Age in US Children, Gooze et al, J Pediatrics 2011, Sept; 159 (3):431-6
- A survey by the German consumer centres on the products being sold as “Kindermilch” (“milk for children”) targeting the age from 12 months found that Kindermilch was up to four times more expensive than normal milk, costing parents up to 245 euros more each year.\(^{67}\)
- For more information see Infant Milks in the UK which has a wealth of information about infant milks in the UK including on Page 61 (Table 17) a chart showing the amount of sugar in Growing Up milks.\(^{68}\)
11 EFSA and WHA recommendations on exclusive breastfeeding
Baby Milk Action issued a critique of an EFSA Working Group on Complementary Feeding report published in December 2009.\(^{69}\) We considered illogical and contradictory for several reasons, including that it over-emphasised Coeliac Disease and undermined existing effective public health recommendations. Several Working Group members had unacceptable links to the infant feeding industry and some were co-authors of an ESPGHAN paper on Complementary Feeding which reintroduced the concept of complementary feeding from 4-6 months (rather than from 6 months which is WHO/Codex policy and already in place in the UK and many EU countries). There is no evidence that the present six-month recommendation is harmful. The UK National Infant Feeding Survey 2005 indicates that the policy has had a good impact so far, delaying the introduction of solids. See also the Lucas issue.\(^{70}\)
\(^{67}\) http://www.vzhh.de/ernaehrung/129727/kostenfalle-kindermilch.aspx
\(^{68}\) http://www.firststepsnutrition.org/children/eating-well_first-six-months.html
\(^{69}\) http://www.babymilkaction.org/press/press23dec09.html
\(^{70}\) http://info.babymilkaction.org/news/policyblog140111
12 Contaminants, BPA, Pathogens, Pesticides
For more information see IBFAN briefings on contaminants in baby foods.\(^{71}\)
12.1. Pesticides
The Greens in Parliament are calling for stricter safeguards on pesticides for baby foods. The Commission disagreed saying that the safety standards for ordinary foods are sufficiently stringent.\(^{72}\)
The Commission says:
(17) It is important that ingredients used in the manufacture of the categories of food covered by this Regulation are appropriate to satisfy the nutritional requirements of, and are suitable for the persons to whom they are intended and that their nutritional adequacy has been established by generally accepted scientific data. Such adequacy should be demonstrated through a systematic review of the available scientific data.
(17a) The use of pesticides in products of plant and animal origin intended for infants and young children should be restricted as far as possible. A prohibition of their use in the production of such products would not necessarily guarantee that they are free from such pesticides, since some pesticides contaminate the environment and their residues may be found in the products concerned. Therefore, the maximum residues levels in the products concerned should be set at the lowest achievable level consistent with good agricultural practices for each pesticide with a view to protect those vulnerable groups of the population.
(17b) Limitations or bans of certain pesticides equivalent to those currently established by the annexes to the Directives 2006/141/EC and 2006/125/EC should be taken into account in delegated acts. Those limitations or bans should be updated regularly, with particular attention to be paid to pesticides containing active substances, safeners or synergists classified in accordance with Regulation (EC) \(\text{o} 1272/2008\) as mutagen category 1A or 1B, carcinogen category 1A or 1B, toxic for reproduction category 1A or 1B, considered to have endocrine disrupting properties that may cause adverse effects in humans.
12.2 SOYA
Concerns have been raised over the potential allergenic effect of soy protein based milks in infants at high risk of atopy and over the effects that the phyto-oestrogens present in soy protein based milks might have on future reproductive health. The Chief Medical Officer has recommended that soy protein based milks should not be used for infants under 6 months of age who have cows’ milk protein allergy or intolerance. The Committee on Toxicity of Chemicals in Food, Consumer Products and the Environment (COT) concluded that the high levels of phyto-oestrogens present in soy protein based milks posed a potential risk to the future reproductive health of infants (Committee on Toxicity, 2003). (For more see Infant Milks in the UK\(^{73}\))
\(^{71}\) http://www.ibfan.org/fact-contaminants-reports_recall.html
\(^{72}\) http://www.europarl.europa.eu/sides/getDoc.do?type=TA&language=EN&reference=P7-TA-2012-255
\(^{73}\) http://www.firststepsnutrition.org/pdfs/FSNT_Infant_milks_WEB.pdf
12.3 Pathogens - ENTEROBACTER SAKAZAKII (now called Cronobacter sakazakii)
IBFAN has worked to raise awareness of inherent contamination of powdered infant formula since first being altered to the problem by the death of a Belgian baby in 2002. Since then the issue has been taken up by WHO, the World Health Assembly, Codex and numerous governments. A key issue is the independence of the scientific evidence.
Nestlé’s Baby Nes bottle preparation machine, launched in Switzerland in 2011,\(^{74}\) is now entering the EU\(^{75}\) contravening WHO, UK and EU safety recommendations. It is being marketed as the State of the Art technology - while encouraging unsafe practices. Nestlé offers a 24-hour after sales service - assuring Nestlé contact with mothers - something that is totally forbidden by the World Health Assembly requirements. We have asked the Commission to offer guidance to Member States before this spreads further. There are no EU wide marketing rules for bottles and teats.
- INFOSAN Information Note No. 3/2008 - Food Safety and Nutrition During Pregnancy and Infant Feeding Food Safety and Nutrition During Pregnancy and Infant Feeding WHO Infosan Note 2008 [http://www.ibfan.org/art/85-21.pdf](http://www.ibfan.org/art/85-21.pdf)
- Product recall List: [http://www.ibfan.org/art/recalls_2010-2012-feb.pdf](http://www.ibfan.org/art/recalls_2010-2012-feb.pdf)
- Examples of information on Food Safety and Pregnancy issued by national authorities
- *Revised guidance on powdered infant formula* Friday 1 December 2006 United Kingdom Food Standards Authority: [http://www.eatwell.gov.uk/asksam/agesandstages/pregnancy/](http://www.eatwell.gov.uk/asksam/agesandstages/pregnancy/) [http://www.food.gov.uk/news/newsarchive/2006/dec/infantform](http://www.food.gov.uk/news/newsarchive/2006/dec/infantform)
- The Department of Health and Food Standards Agency originally issued advice on preparing infant formula in November 2005 following an opinion from the European Food Safety Authority's Scientific Panel on Biological Hazards on the microbiological risks of infant and follow-on formulas. This advice was revised in February 2006 to mention liquid ready-to-feed formula.
- *EFSA Panel advises on how to avoid microbiological risks in infant formulae, at home and in hospital* [http://www.efsa.europa.eu/fr/press/news/biohaz041118.htm](http://www.efsa.europa.eu/fr/press/news/biohaz041118.htm)
- Opinion of the Scientific Panel on biological hazards (BIOHAZ) related to the microbiological risks in infant formulae and follow-on formulae\(^1\)
- *Food Safety Authority of Ireland*: [http://www.fsai.ie/publications/guidance_notes/gn22.pdf](http://www.fsai.ie/publications/guidance_notes/gn22.pdf), [http://www.fsai.ie/publications/factsheet/factsheet_enterobacter_sakazakii.pdf](http://www.fsai.ie/publications/factsheet/factsheet_enterobacter_sakazakii.pdf)
- *Food Standards Australia New Zealand*: [http://www.foodstandards.gov.au/foodmatters/pregnancyandfood.cfm](http://www.foodstandards.gov.au/foodmatters/pregnancyandfood.cfm)
- *New Zealand Food Safety Authority*: [http://www.nzfsa.govt.nz/consumers/low-immunity-child-pregnancy/pregnancy-food-safety/](http://www.nzfsa.govt.nz/consumers/low-immunity-child-pregnancy/pregnancy-food-safety/)
- *United States Food and Drug Administration*: [http://www.cfsan.fda.gov/~pregnant/pregnant.html](http://www.cfsan.fda.gov/~pregnant/pregnant.html)
- *Swedish National Food Administration*: [http://www.slv.se/templates/SLV_Page.aspx?id=15787&epslanguage=EN-GB](http://www.slv.se/templates/SLV_Page.aspx?id=15787&epslanguage=EN-GB)
- New South Wales Food Authority (Australia): [http://www.foodauthority.nsw.gov.au/consumer/pregnancy.asp](http://www.foodauthority.nsw.gov.au/consumer/pregnancy.asp)
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\(^{74}\) [http://info.babymilkaction.org/sites/info.babymilkaction.org/files/NesBaby%20PR.pdf](http://info.babymilkaction.org/sites/info.babymilkaction.org/files/NesBaby%20PR.pdf)
\(^{75}\) Link to the BabyNes launch in France: [http://fr.finance.yahoo.com/actualites/babynes-nespresso-biberons-arrive-france-085700962--finance.html](http://fr.finance.yahoo.com/actualites/babynes-nespresso-biberons-arrive-france-085700962--finance.html)
Update 44 summary following testing of the BabyNes powder capsules [http://info.babymilkaction.org/update/update44page23](http://info.babymilkaction.org/update/update44page23)
12.4 Codex Food Hygiene Provisions
15. The Committee recalled that in the Standard for Infant Formula and Formulas for Special Medical Purposes Intended for Infants and the Standard for Follow-up Formula (CODEX STAN 156-1987), reference was made to the Code of Hygienic Practice for Powdered Formulae for Infants and Young Children (CAC/RCP 66 - 2008), which superseded the Code of Hygienic Practice for Foods for Infants and Children (CAC/RCP 21-1979) and considered how to update the reference to the superseded code in other texts. The Committee agreed to proceed as follows:
16. *Standard for Cereal-Based Foods for Infants and Young Children*: delete the reference to CAC/RCP 21-1979 and refer to the *General Principles of Food Hygiene*, which adequately cover the products concerned.
17. *Standard for Canned Baby Foods*: delete the reference to CAC/RCP 21-1979 refer to the *Code of Hygienic Practice for Low-Acid and Acidified Low-Acid Canned Foods* (CAC/RCP 23-1979) and the *Code of Hygienic Practice for Aseptically Processed and Packaged Low-Acid Foods* (CAC/RCP 40-1993)
18. *Guidelines for Formulated Supplementary Foods for Older Infants and Young Children*: revise the hygiene section while revising the Guidelines (see Agenda Item 6)
**Issues not yet covered in this document:**
Other contaminants and heavy metals, such as Aluminium, Melamine, Flouride, BPA.
Nano technology
13. UK formula marketing regulatory system analysis
13.1 Introduction
The *International Code of Marketing of Breastmilk Substitutes* was adopted under a Resolution of the World Health Assembly in 1981. The British Government supported the Code at the time and in adopting subsequent, relevant Resolutions. The Code and Resolutions are “minimum requirements” for all countries.
Article 11.3 of the Code states:
*Independently of any other measures taken for implementation of this Code, manufacturers and distributors of products within the scope of this Code should regard themselves as responsible for monitoring their marketing practices according to the principles and aim of this Code, and for taking steps to ensure that their conduct at every level conforms to them.*
Unfortunately, manufacturers and distributors in the UK (as elsewhere) fail to respect this requirement unless compelled to do so through governments implementing and enforcing the Code and Resolutions in legislation. Governments have a responsibility under the Resolutions and the *Convention on the Rights of the Child* to implement and monitor the *International Code* and Resolutions.
The Committee on the Rights of the Child report on the UK in 2008 stated:
*The Committee, while appreciating the progress made in recent years in the promotion and support of breastfeeding in the State party, is concerned that implementation of the International Code of Marketing of Breastmilk Substitutes continues to be inadequate and that aggressive promotion of breastmilk substitutes remains common. The Committee recommends that the State party implement fully the International Code of Marketing of Breastmilk Substitutes.*
While companies systematically violate the Code and Resolutions and successive governments have failed to implement these measures, the narrower *European Commission Directive 2006/141/EC of 22 December 2006 on infant formulae and follow-on formulae and amending Directive 1999/21/EC* have been implemented as the *Infant Formula and Follow-on Formula Regulations (2007)* as equivalent texts in the four countries of the United Kingdom. At UK level, associated Guidance Notes have been adopted, which Parliament was told\(^{76}\) show “how the regulations should be interpreted.”
As well as calling on companies and retailers to respect the Code and Resolutions, the Regulations and the Guidance Notes, Baby Milk Action reports violations to the following regulatory bodies:
- The Food Standards Agency
- Advertising Standards Authority
- Trading Standards
Baby Milk Action’s experience shows that even the regulations that do exist are poorly enforced.
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\(^{76}\) Hansard:
http://www.publications.parliament.uk/pa/cm200708/cmhansrd/cm080116/halltext/80116h0005.htm
13.2 The Food Standards Agency
In 2006, the Food Standards Agency wrote to baby food companies and the Trading Standards home authorities responsible for them pointing out that under the Infant Formula and Follow-on Formula Regulations (1995) (since updated, though not significantly strengthened) only the claims specified in Annex IV to the Regulations could be used on the labels of infant formula. Specifically the following terms, widely used, were not permitted:
‘Now even closer to breast milk’,
‘Closer than ever to breastmilk’,
‘Prebiotics support natural defences’,
‘Helps brain and eye development’
This led to changes to labels, but other claims continued and continue to be used today.
The Guidance Notes for the current Regulations make it clear that the regulations prohibit infant formula labels including “any other picture or text which may idealise the use of the product, but may include graphic representations for easy identification of the product or for illustrating methods of preparation.”
Claims continue to be used and idealising images such as shields, cuddly toys and hearts are commonplace. It would be welcome for the FSA or Department of Health to remind companies and Trading Standards of the requirements and call for all products with such labels to be removed from the market with immediate effect as they break the law.
The FSA or Department of Health could also play a useful role in acting on misleading claims about follow-on formula promotion, which suggests, for example, that follow-on formulas are necessary as a source of iron when a child is over 6 months old.
13.3 The Advertising Standards Authority
The Advertising Standards Authority (ASA) has upheld some of the complaints brought by Baby Milk Action and other organisations and members of the public regarding misleading claims.
However, the ASA refuses to investigate the majority of complaints reported. The ASA’s own slogan suggests it ensures advertising is “legal, decent, honest and truthful”. Yet, in practice it refuses to investigate complaints about formula advertising where the complaint cites:
- Violations of the provisions of the *Infant Formula and Follow-on Formula Regulations* (undermining the ‘legal’ aspect of the ASA’s slogan),
- Violations of the provisions of the *International Code* and Resolutions, which companies are called on by the World Health Assembly to abide by (undermining the decent and honest’ aspects of the slogan),
- Misleading advertising to health workers,
- Misleading information on websites.
For example, in a message to Baby Milk Action (30 March 2012) the ASA stated:
*We will not be considering whether the ad breaches the Infant Formula and Follow-On Formula Regulations 2007, European Regulation (EC) No 1924/2006 on Nutrition and Health Claims made on Foods, the International Code on Marketing of Breast Milk Substitutes, Department of Health or WHO guidance. If they would like their complaints to be considered under those rules or legislation, they should contact the bodies which administer those rules or*
legislation directly. The ASA is able to consider complaints about ads under the rules set out in the CAP Code only.
This refusal is troubling, not least because the CAP (Committee of Advertising Practice) Code, states:
“These rules must be read in conjunction with the relevant legislation including the Infant Formula and Follow-on Formula Regulations 2007 and the European Regulation (EC) No 1924/2006 nutrition and Health Claims made on Foods”.
With regard to websites the ASA has said (25 May 2012):
Please note that they will only be looking at the leaflet; the website content that you included in your email is not something that we can deal with. The lack of a common definition of what constitutes ‘advertising’ as far as the regulations and associated guidance means that this matter should be referred to the advertisers’ local Trading Standards department as the body responsible for enforcing FSA Guidance on the Infant Formula and Follow-on Formula Regulations 2007.
It is also a concern that in its response to complaints the ASA states that it may not investigate a complaint or forward a draft ruling to the ASA Council for approval at all if the company offers to change the advertising in a way that resolves the complaint. When advertising campaigns may involve national billboard, magazine and television advertising, a published ruling is too little, too late, but does at least put the fact the advertising was misleading on the record. If the ASA is prepared to accept an assurance from the company, there will not even be this record.
### 13.4 Trading Standards
In the past LACORS (Local Authorities Coordinators of Regulatory Services - the umbrella body for Trading Standards) formed a committee of the home authorities for the baby food manufacturers to coordinate regulatory action.
However, Baby Milk Action was informed by Local Government Regulation (the new name for LACORS) on 25 August 2010:
“Unfortunately due to reduced budgets, LG Regulation can no longer provide secretariat support for all the sector specific home authority groups such as the infant formula groups.”
Complaints now have to be sent via Consumers Direct (currently operated by Citizens Advice Bureau). The standard message received from this route generally states something along the lines of (received 13 March 2012):
the information you have provided will be passed to Cambridge Trading Standards for further consideration. The case details will also be placed on a central data base that can be accessed by all the other Trading Standards throughout the UK and the Office of Fair Trading. Trading Standards will only contact you if they need further information.
In only a few cases have Trading Standards made contact. These cases have related to violations in retail outlets, when our local Trading Standards office (Cambridge) has contacted us. However, Cambridge has informed us that we must always go through the Consumers Direct route to report cases.
Experience has shown that Trading Standards is reluctant to take legal action against companies, even when they repeatedly break the law. The only case ever taken to court was by Birmingham Trading Standards in 2003 (the court found that Wyeth had carried out a “cynical and deliberate breach of the regulations”).
For example, Tesco broke the provisions of the Regulations through idealising claims it made alongside formula in a catalogue. Tesco was neither prosecuted nor required to recall the catalogue. Tesco then broke the Regulations again in October 2011 by promoting infant formula with a national ‘Big Price Drop’ campaign. Tesco claimed this was a mistake and again was allowed to get away with simply apologising. Without any form of deterrence through imposition of fines the same cavalier attitude to the Regulations is likely to continue.
Trading Standards officers have also been dismissive of the Guidance Notes, which show how the Regulations should be interpreted.
For example, Trading Standards responded to Baby Milk Action regarding a complaint about a national advertising campaign (11 June 2012):
“I can confirm that I have discussed this campaign with [the company]. I advised them of improvements that should be made to improve clarity in the future. It a criminal offence to breach the regulations but not the guidance notes, and most of the issues breached the guidance notes. No further action is proposed to be taken by this authority regarding this campaign, although I am aware the ASA investigation is ongoing.”
However, as noted above, the ASA refuses to investigate the legality of formula advertising and had already said to Baby Milk Action: “you may wish to contact Trading Standards to pursue this matter under the regulations”.
In passing responsibility to each other, neither the ASA nor Trading Standards is taking effective action.
### 13.5 The Review of the Regulations and Guidance Notes
The previous government commissioned an Independent Review Panel (IRP) to review the operation of the *Infant Formula and Follow-on Formula Regulations (2007)* at a cost of £500,000.
The IRP’s report acknowledged concerns raised by Trading Standards and other bodies over enforcing the measures and stated that there need to be “steps taken to address these.”
LACORS, the umbrella body for Trading Standards, is cited as follows:
“One of the major problems for enforcement officers is the use of advertising and promotional material which blurs the distinction between follow-on formula and infant formula.”
The terms of reference for the review were narrow, considering only the question of whether parents were confused between promotion for infant formula and follow-on formula.
The panel considered the risk of parents using follow-on formula from too early an age, commented: “any ban on the advertising of follow-on formula, is a decision for policy makers, who if sufficiently concerned could consider the precautionary principle.”
No steps were taken following the review and the coalition government has not taken up this issue.
Promotion of follow-on formula is cross-promotional of infant formula, particularly as the provisions of the Guidance Notes are neither respected nor enforced:
“the specific terms ‘infant formula’ and ‘follow-on formula’ should be clearly featured on the packaging, in a font size no smaller than the brand name.”
Advertising of follow-on formula appears to be on the increase. According to the World Health Assembly these products are “not necessary”.
Further information on the shortcomings with the *Infant Formula and Follow-on Formula Regulations* can be found in the submission by the Baby Feeding Law Group to the government consultation on updating the *Infant Formula and Follow-on Formula Regulations (1995)*. BFLG
was convened by Baby Milk Action and consists of leading health professional bodies and mother support groups. Its recommendations were ignored in drafting the 2007 Regulations. For the submission and BFLG monitoring reports produced by Baby Milk Action (which were at one time quarterly when funding allowed) see:
http://www.babymilkaction.org/shop/publications01.html#bflgreports
Violations are now recorded in a more ad hoc manner on the BFLG website at:
http://www.babyfeedinglawgroup.org.uk/reports/bflgreports
### 13.6 Action against violations at international level
Although the *International Code of Marketing of Breastmilk Substitutes* was adopted as a minimum standard for all countries, there is no enforcement mechanism at international level when national governments have failed to implement it and the subsequent, relevant Resolutions of the World Health Assembly in legislation or fail to enforce the measures.
The World Health Organisation is called on by the Assembly to report on the state of implementation and produces reports in even years on government action. It relies on government submissions for these reports. It does not comment on company practices or censure companies in any way for systematically violating the Code and Resolutions.
The UN Committee on the Rights of the Child usually reports on the state of implementation of the Code and Resolutions in its five-yearly reports on the compliance of State Parties with the Convention on the Rights of the Child. The Committee accepts government and non-governmental organisation reports. In the case of the UK, the Committee has twice called on the UK Government to introduce legislation implementing the marketing requirements, which has not resulted in any action being taken. While the Committee does not comment on individual company practices, in its last report the Committee did comment that “*aggressive promotion of breastmilk substitutes remains common*” (full quote on page one).
In theory there is scope to bring complaints about violations of the Code and Resolutions under the *UN Global Compact* and the *OECD Guidelines for Multinational Enterprises*. However, Baby Milk Action has been pursuing cases against Nestlé malpractice around the world (not specifically the UK) and found both of these initiatives to be worse than useless.
The UN Global Compact is a voluntary corporate social responsibility initiative set up by Kofi Anan when Secretary General of the UN, jointly with the World Economic Forum. Baby Milk Action and a coalition of Nestlé Critics registered complaints of violations of the Global Compact Principles under so-called Integrity Measures. However, over the course of three years, the Global Compact has taken none of the actions set out in the Integrity Measures other than to forward Baby Milk Action’s letters to Nestlé, which had already received them directly. Full details of the complaints and subsequent developments are available via the Baby Milk Action website and the publication: “Nestlé’s UN Global Compact cover up”. See:
http://www.babymilkaction.org/shop/publications01.html#globalcompact
The *OECD Guidelines for Multinational Enterprises* are sometimes cited by policy makers as justification for not pursuing an international regulatory system for transnational corporations. Baby Milk Action registered complaints with the UK National Contact Point (NCP) for the Guidelines regarding Nestlé practices in 2009 as it was Nestlé (UK) generally responded to letters regarding violations. The UK NCP forwarded the complaints to the Swiss NCP as Switzerland is Nestlé’s home country. The Swiss NCP said its role was to “promote dialogue” to resolve concerns. As Nestlé denied violating the Code and Resolutions (and consequently the OECD Guidelines), Baby Milk Action suggested the Swiss NCP request from Nestlé examples of
its latest formula labels and marketing materials so these could be discussed with reference to the Code and Resolutions. The NCP refused to do so and closed the case.
Baby Milk Action was a member of the UN System Standing Committee on Nutrition Task Force on Global Obligations for the Right to food and contributed the chapter on holding corporations accountable to the resulting publication. This chapter made recommendations for an enforceable regulatory system at international level for when national measures fail. See: http://www.babymilkaction.org/shop/publications02.html#gorf
### Chronology of efforts to implement the WHA resolution in the EU 1981-2006
**Baby Milk Action Briefing on EU Legislation. August 2012**
**May 1981** The UK and EEC Member States voice strong support for the *International Code of Marketing of Breastmilk Substitutes* at the World Health Assembly. The Code is adopted as a *minimum requirement for all Member States to be implemented in its entirety*. The USA is the only country to vote against. During its formation industry described the Code as “unacceptable, restrictive, irrelevant and unworkable.”
**Oct 1981** The European Parliament (EP) votes overwhelmingly in favour of implementing the *International Code* as a Directive.
**1982 - 2006** 12 WHA Resolutions clarify and extend the Code.
**1982** The Commission starts work on a Directive on quality, composition and labelling. It proposes a voluntary code drawn up by the Association of Dietetic Food Industries of the EEC (IDACE) to cover marketing. The Commission claims a ban of advertising would go against the rules of free competition and would pose problems to the Commission. It alleges that there is no proof that advertising increases bottlefeeding - it merely affects choice between brands.
**1983** The EP passes another resolution rejecting the IDACE Code, calling once more for the *International Code*. The UK Manufacturers Federation (FMF) led by Wyeth – produce a voluntary Code (FMF Code). This does nothing more than legitimise current marketing practices. Promotion increases and breastfeeding rates do not rise.
**1984** The Commission issues draft proposals with the IDACE Code as an Annex. In the UK Wyeth launches £1/2 m promotion of *Progress* follow-on milk for babies of 4 months in the UK. Health Visitors report widespread confusion and misuse and mount a campaign saying their health advice is being undermined.
**1985** Three EP committees (Economic & Social Development and the Environment, Public Health and Consumer Protection) reject the Commission’s proposals again. The Consumer Committee questions the scientific basis for including follow-on milks in the Directive: “The need of follow-up milks is extremely dubious and there is no need whatsoever for a new specially manufactured product.”
**1986** EP votes by a sweeping majority for amendments incorporating much of the Code. Commissioner Lord Cockfield accepts 33 amendments including, in principle, Amendment No 8 on bottles and teats. The Commission submits a Council Directive which again fails to include all the EP amendments. Leading nutrition expert, Prof Michael Crawford says Progress is more like rhinocerous milk than breastmilk. WHA Res 39.28 says “Follow-on Milks are not necessary”. UK Government Panel on Child Nutrition says follow-on should not be used before 6 months.
**1986-1989** The issue is stuck in a bureaucratic limbo as the EU legislative process is transformed. A *Framework Directive for Foodstuffs for Particular Nutritional Uses* (PARNUTS) is adopted by the Council. The Commission – an unelected body – now has the power to finalise legislation for these foods without having to consult the EP. PARNUTS legislation was, and still is, discussed in closed meetings with technical experts from Member States.
**1989** UK Health Minister, Edwina Curry bans free and low-cost supplies and issues a strengthened Circular [HC (89)21]
**1991** The Commission receives over 1,500 letters calling for the Directive to be strengthened. UNICEF Executive Director James Grant writes to the President of the Commission, Jacques Delaere, saying the Directive is “a serious setback in our efforts to promote exclusive breastfeeding.” WHO provides comments to the UK and Netherlands highlighting over 20 weaknesses. The Chair of EP Consumer Committee complains that the Commission draft does not reflect its promise to the EP. The Commission accepts that the purpose of the Directive is to “provide better protection for the health of infants” and agrees to propose key changes to allow Member States to carry out their obligations under the Code.
**May 1991** Directive 91/321/EEC is adopted. Member States accept a new clause permitting a ban of advertising and the strengthening of the section on free supplies. The Netherlands vote against because it did not fully implement the Code. The Danes vote against because the Directive permits high sugar levels. The UK makes a statement regretting that the Directive was not stronger on bottles and teats, exports and follow-on milks.
**1992** Export Directive (92/52/EEC) requires labels to be in the correct languages. Council Resolution (92/C 172/01) requires EU-based companies to comply with the Code outside the EU.
**1993 - 95** UK Draft proposals initially propose a ban on advertising of infant formula. 47 health, consumer and development NGOs welcome this and call for follow-on formula advertising to be banned also. The UK weakens the proposals in line with industry’s demands. The Labour Party leads a ‘prayer’ against the proposals saying the Government is putting commercial interests before health. There are debates in the House of Commons and Lords. 6 EU countries ban all advertising of infant formula.
**May 1994** Global consensus is reached on the Code as the USA supports *WHA Resolution 47.5* which bans free and low-cost supplies throughout the health care system and recommends complementary feeding from ‘about six months.’
**1996, 1999** Amendments to the Directive improve controls on pesticides but allow a controversial reduced risk to allergy claim.
**1997** UK Health Professional and lay organisations coordinate as the BFI&G to bring UK and EU legislation into line with the Code.
**1999** 900 European NGOs petition the EU to include the Code in the Directive on Dietary Foods for Special Medical Purposes [1999/21/EC]. EU Commission resigns over charges of corruption and in the interim the Directive is adopted unchanged.
**2000** Baby Milk Action and Glenys Kinnock MEP successfully persuade the Commission to require Scientific Committee for Food members to make public declarations of interest.
**2002** The UN Committee on the Convention on the Rights of the Child recommends that the UK increases breastfeeding rates and adopts the International Code.
**2003** Birmingham Trading Standards presses charges against Wyeth/SMA which argues that advertising is information and that UK legislation “fetter[s] the free movement of goods” and should be no stricter than the weakest of any other country in Europe. The argument fails and Wyeth is convicted of illegal advertising.
**2004-6** European Commission issues proposals for a revised EU Directive. The UK FSA calls for amendments in line with BFI&G suggestions, including calling for a ban of follow-on milk advertising or an option to decide this issue at national level.
**2005** The Lisbon Strategy aims to make the EU the most competitive trading block in the world by 2010.
**Dec 2006** The Directive [2006/141/EC] is published to be implemented in all 27 EU Member States by December 2007.
|
Towards a Comprehensive Strategic Framework to Upscale and Out-scale EbA-driven Agriculture In Africa
REPORT FROM THE CONTINENTAL TASK FORCE ON EBA FOR FOOD SECURITY IN AFRICA
WWW.EBAFOS.AAKNET.ORG
Ecosystem Based Adaptation (EBA) for food security in Africa –
Towards a comprehensive Strategic Framework to Upscale and Out-scale EbA-driven agriculture In Africa
REPORT FROM THE CONTINENTAL TASK FORCE ON EBA FOR FOOD SECURITY IN AFRICA
Continental Task Force Members:
Michael O’Brien-Onyeka, Executive Director, Greenpeace Africa, South Africa
Cosmas Ochieng, Executive Director, Africa Center for Technology Studies (ACTS), Kenya
Ernest Molua, Dept. of Agricultural Economics, University of Buea, Cameroon
Wilbur Ottichilo, MP, Parliamentary caucus on Renewable Energy and Climate Change, Kenya
Kisamba Mugerwa, Executive Chairperson, National Planning Authority, Uganda
Ayalneh Bogale, Advisor, Climate Change & Agriculture, African Union Commission (AUC)
Wagayehu Bekele, Director, Climate and Environmental Sustainability, Ethiopia
Michael Sudarkasa, CEO Africa Business Group, South Africa
Ousmane Badiane, Director for Africa, IFPRI
Elias Ayuk, Director, Institute for Natural Resources in Africa, UNU, Ghana
Mao A. Amis, Executive Director, African Centre for a Green Economy, South Africa
Ebenezer Tabot-Tabot, Africa Regional Director, Centre for Environment and Human Development, Cameroon
Roland Bunch, Author of “Two Ears of Corn” and “Restoring the Soil, Kenya
Ken Kinney, Executive Director, The Development Institute, Ghana
Christina Kwangwari, ActionAid International, Zimbabwe
Editorial Team & Continental Task Force Secretariat
Richard Munang, UNEP
Keith Alverson, UNEP
Robert Mgendi, UNEP
David Ombisi, UNEP
Moses Ako, UNEP
Tony Mutavi, UNEP
Patrick Luganda, CEO Farmers Media Link Ltd, Uganda
Kobina Aidoo, Africa Center for Economic Transformation (ACET), Ghana
Francis Mulangu, Africa Center for Economic Transformation (ACET), Ghana
Julius Kariuki, Africa Center for Economic Transformation (ACET), Ghana
Acknowledgments:
Dennis Garrity, Senior Fellow, ICRAF, Kenya
Jean Ndkumana, Association for strengthening Agricultural Research in Eastern and Central Africa (ASARECA), Uganda
Ali Toure, AfricaRice, Benin
Olajide Adeola, Department of Agricultural Economics, University of Ibadan, Nigeria
Badege Bishaw, Department of Forest Ecosystems and Society, Oregon State University
Abby Mhene, Director, Women and Resources in eastern and southern Africa (WARESA)
Rwakakamba Morrison, Agency for Transformation, Uganda
Godber Tumushabe, Great Lakes Institute for Strategic Studies, Uganda
Olu Ajayi, Senior Programme Coordinator, CTA- Technical Centre for Agricultural and Rural Cooperation EU-ACP
Joseph Kamara, Regional portfolio Manager, East & West Africa, World Vision Australia
Mehmood Ul Hassan, Senior Scientist and Head, Capacity Development Unit, ICRAF, Kenya
Nehemiah Mihindo, Africa IPM Alliance, Kenya
Emile N. Houngbo, University of Agriculture, Ketou, Benin
Godwell Nhamo, University of South Africa
Odunayo Clement Adebooye, Osun State University, Nigeria
Ademola Braimoh, Senior Natural Resources Management Specialist, WorldBank
Mine Pabari, Deputy Regional Director, Programme, IUCN
Dougbedji Fatondji, CGIAR, Niger
Pascal Sanginga, IDRC, Kenya
Chisomo Nelson Kamchacha, Kusamala Institute of Agriculture and Ecology Malawi
Robert B. Zougmoré, Regional Program Leader West Africa, CCAFS, ICRISAT Bamako, Mali
Emmanuel Etim, Managing Director Observatory for Policy Practice and Youth Studies, Nigeria
Philip Osano, ACTS, Kenya
Hellen Mwangi - CEO, Mother and Childcare Networking, Kenya
Lawrence Muli, African Observatory for Policy Practice and Youth Studies, Ethiopia,
Saidou Koala, CIAT, Kenya
Hezron Mogaka, Natural Resource Management & Biodiversity ASARECA, Uganda
Lucy Mulenkei, Executive Director, Indigenous Information Network, Kenya
Taye Teferi, Trans-boundary Programmes & Shared Learning WWF, Kenya
Paul Ongugo, Kenya Forestry Research Institute (KEFRI)
Martin Bwalya, NEPAD
Edward Maferano, Malawi
Hassan Bismarck NACRO, Niger
Alfred Oteng-Yeboah, Ghana
Nelson Mudzingwa, Zimbabwe Smallholder Organic Farmers Forum (ZIMSOFF)
Lutangu Mukuti, Zambia
Ruth K. Oniang'o, Founder, Rural Outreach Program (ROP) Africa
Annet Kandole, CARE, Uganda
Hamba Richard, Teens Uganda
Disclaimer:
This report contains the findings of the Continental Task Force Members on EbA for Food security in Africa. The content do not necessarily reflect the views or policies of UNEP or contributory organisations. The designations employed and the presentations do not imply the expressions of any opinion whatsoever on the part of UNEP or contributory organisations concerning the legal status of any country, territory, city, company or area or its authority, or concerning the delimitation of its frontiers or boundaries.
Correct citation:
Munang R, Mgendi R, Alverson K, O’Brien-Onyeka M, Ochieng C, Molua E, Ottichilo W, Mugerwa K, Bunch R, Bogale A, Bekele W, Sudarkasa M, Badiane O, Ayuk E, Amis M, Tabot-Tabot E, Kinney K, Kwangwari C, Luganda P, Aidoo K, Mulangu F, Kariuki J et al. 2015. Ecosystem Based Adaptation (EBA) for food security in Africa –Towards a comprehensive Strategic Framework to Upscale and Out-scale EbA-driven agriculture in Africa. United Nations Environment Programme (UNEP), Nairobi
## Acronyms
| Acronym | Description |
|---------|-------------|
| AU | African Union |
| CA | Conservation Agriculture |
| CSOs | Civil Society Organizations |
| EbA | Ecosystems Based Adaptation |
| EbAFoS | Ecosystems Based Adaptation for Food Security |
| FMNR | Farmer Managed Natural Regeneration |
| GM/CCS | Green Manure Cover Cropping Systems |
| HHs | House Holds |
| IPCC AR4 | Intergovernmental Panel on Climate Change Assessment Report 4 |
| IPCC AR5 | Intergovernmental Panel on Climate Change Assessment Report 5 |
| ISFM | Integrated Soil Fertility Management |
| NEPAD | New Partnership for Africa’s Development |
| NGOs | Non-Governmental Organizations |
| PHLs | Postharvest Losses |
| RECs | Regional Economic Commissions |
| SDGs | Sustainable Development Goals |
| SMEs | Small and Medium Enterprises |
| SOPVs | Sorghum Open Pollinated Varieties |
| SSA | Sub-Saharan Africa |
| SWC | Soil and Water Conservation |
| UNEP | United Nations Environment Programme |
| UNFAO | United Nations Food and Agriculture Organization |
| UNFCCC | United Nations Framework Convention on Climate Change |
# Table of Contents
Executive Summary ........................................................................................................... 1
1. Background and Context ................................................................................................. 2
1.1.1 Business as usual .................................................................................................. 3
1.1.2 A paradigm shift .................................................................................................... 4
2. Paradigms of agriculture development in Africa ......................................................... 6
2.1.1 Business as usual – Conventional food production systems ............................. 6
2.1.2 A paradigm shift – building sustainable food systems and value chains .......... 7
3. EbA techniques and their benefits for Africa: Through the Science and Evidence Lens .... 11
3.1 Documented EbA Driven Agriculture benefits .......................................................... 13
3.1.1 Benefits documented from individual country examples ............................... 13
3.1.2 Value addition and unlocking opportunities for incomes and employment along the agro-value chain. .............................................................................................................. 14
3.2 Case studies and synthesized findings ....................................................................... 14
3.2.1 The Lake Chilwa Basin Climate change Adaptation project – Malawi .............. 15
3.2.2 Fish and crab farming in Mozambique / Ecosystem Based Adaptation and Improved Livelihood of Zongoene and Mahilene Communities, Limpopo River Basin - Mozambique 18
3.2.3 Green water saving in Ngusishi catchment in Kenya ...................................... 20
3.2.4 Experience of supporting forest adjacent communities to promote food security in Uganda ........................................................................................................................................... 21
3.2.5 Sorghum and Millets Improvement Programme/Promotion of Science and Technology for Agriculture Development in Africa - Zambia ........................................ 22
3.2.6 Promotion of soil and water conservation practices in Buluganya sub-county, Bulambuli District – Uganda ........................................................................................................... 23
3.2.7 Universities on Ecosystem-based Adaptation in Rural Communities in Zimbabwe ........................................................................................................................................... 24
4. Upscaling and out scaling of EbA driven Agriculture and Orchestrating the new paradigm Shift– What is needed? ........................................................................................................ 27
5. Enabling policy and legislation to incentivize country investment .................................. 31
6. Strategic framework: Toward operationalizing the new agricultural paradigm in Africa Shift embedded in EBA-driven approach ........................................................................ 35
7. Annex ............................................................................................................................. 37
Annex 1 Data collection and sampling methodology ...................................................... 37
8. End Notes ..................................................................................................................... 39
Africa faces a myriad of hurdles on its way to achieving the Millennium Development Goals (MDGs) and the post-2015 development agenda. Climate change, population growth, youth bulge, widespread unemployment, extreme poverty and hunger are some of the challenges that the continent is grappling with. Africa’s agricultural potential is immense. It is estimated the continent holds up to 65% of the world’s arable land and 10% of internal renewable fresh water sources. On incomes and poverty reduction, evidence from the World Bank is reported that in Africa, a 10% increase in crop yields translates to approximately a 7% reduction in poverty, greater than the 5% reduction reported in Asia. Neither the manufacturing nor services sectors can achieve an equivalent impact. The reason for this could be that in Africa, agriculture is not only a source of food but of livelihood, employing up to 60% of labour in the continent, a majority being small holders at 60%.
However, astride this potential is the unfortunate fact that about 25% or approximately 240 million people in the continent go to bed hungry, over 200 million suffer the debilitating symptoms of chronic to severe malnutrition, which also contributes to over 50% of infant mortality in the continent. In addition, poverty is rife with 50% in the continent estimated to be living in extreme poverty, on less than USD 1.25 per day. The region currently spends more than USD 35 billion on food imports per year and it is projected that by 2050, Africa’s population will increase from the current 1.1 billion to 2.4 billion and that two out of every five children globally will be African.
The AU has appreciated the potential contribution of Agriculture to Africa’s food security and economic transformation. The Maputo and Malabo declarations as well as the recently launched AU Agenda 2063 are a testament to this. An overriding theme in these continental strategies is the need for modernization and enhanced productivity of Africa’s food production systems while at the same time ensuring the productivity of the very ecosystems that underpin agricultural productivity are enhanced.
This strategic policy framework seeks to build on the key theme of enhancing productivity of Africa’s food systems, by proposing a holistic approach that considers productivity of the agriculture value chain as a continuum. It contrasts the proposed approach with conventional systems by discussing both paradigms. Under conventional approaches to food production, increased production is achieved through ‘intensification’, - expanding cropland through clearing more land, and misusing mineral fertilizers, without considering the impacts of such practices on ecosystems. Under a changing climate, such approaches are not sustainable as they end up destroying the very ecosystems that underpin food production. This then impairs community and societal resilience as communities depend on these very ecosystems to adapt to climate change. In addition, with the ability of ecosystems to produce food being impaired, a lot of potential food is lost – for instance in cereals, which are a major staple in the continent, an estimated 6.6 million tonnes of grain annually are lost due to degraded ecosystems. These yields would be enough to meet annual calorific needs of approximately 30 million people in the continent. In addition, conventional approaches do not consider the value chain holistically, which leads to postharvest losses estimated at 23% of field harvests. Low productivity also results to food importation, which costs the continent up to USD 35 billion annually.
The proposed paradigm shift framework put forward policies suggestions which seeks to enhance productivity of the entire value chain by applying ecosystems based approaches to enhance on-farm production, which results in not only increased yields, but also enhances the productivity of ecosystems and consequently builds community resilience against climate change. Beyond the farm gate, this paradigm proposes value addition through food processing and the application of storage and mobile technologies to reduce postharvest losses and unlock additional income and job opportunities. Affordable storage technologies and deployment of mobile innovations to enhance market and financial access are among the propositions discussed.
Cumulatively, the proposed holistic policy paradigm shift potentially brings 5 distinct benefits to Africa’s food sector – enhances food and nutritional security, enhances ecosystem productivity, builds community climate resilience, enhances value chains by linking on farm production with opportunities for both demand and supply value chains, creates jobs and more incomes. Examples of successful application of this paradigm across the continent as captured in literature are elucidated. In addition, empirical findings from cases studied across the continent are analysed. Findings demonstrate the practicality of this paradigm and the need to urgently up-scale it. This paradigm will embed ecosystems based adaptation for food security across the continent and ensure Africa becomes food secure while enhancing the earnings of the agriculture sector under a changing climate. The recommended measures to ensure both vertical and horizontal up-scaling of the new paradigm shifts and key policy as well as legislation that will incentivize investment in this paradigm by actors at all levels within a country. A strategic framework to operationalize the new agriculture paradigm that imbeds ecosystem based adaptation approaches is documented. This framework captures key operational aspects of institutions, financing, knowledge management and monitoring & evaluation. The case for a stronger political and financial support is made for investments in ecosystem based adaptation for food security in Africa as this provides an opportunity to pave forward a future that is not marked by conflict but by cooperation, not by human suffering, but by human progress as we seek to achieve, in the words of Nelson Mandela, “an Africa where there is work, bread, water and salt for all”.
1 Agriculture a strong component of Agenda 2063 - http://summits.au.int/en/22ndsummit/events/agriculture-strong-component-agenda-2063
1 Towards a comprehensive Strategic Framework to Upscale and Out-scale EbA-driven agriculture In Africa
1. Background and Context
Africa has been tagged as a rising continent. Indeed, both the 2013 Africa Economic Outlook\(^1\) and the 2013 African Competitive\(^2\) reports observe that the pace of GDP growth in Africa has been impressive, averaging 5.1% since 2000 and doubling the average growth rate of the 90’s. Other estimates peg Africa’s GDP growth rate at approximately 6% per year, with 6 of the world’s 10 fastest growing countries over the past decade being African, and a growing middle class with 20% of the population having daily incomes of over USD 10\(^4\).
The continent however stands at a crossroads. Besides the impressive headline growth, the continent faces transecting challenges of hunger and malnutrition, the growing and increasingly young population, youth unemployment, climate change and poverty, which together form a nexus that threatens the otherwise optimistic future outlook anticipated of the impressive growth figures. Almost 1 in every 2 Africans lives in extreme poverty today and with the current trend, by 2030, it is projected that a vast majority of the world’s poor will be located in Africa\(^5\). The 2014 Africa progress report\(^6\) reiterates this. It notes that too many of the continents inhabitants remain stuck in poverty with nearly 50% of the population living on the poverty line of USD 1.25 per day\(^8\) and those below the poverty line living on an average of just 70 US cents per day\(^9\).
Hunger and malnutrition is also rife. The United Nations Food and Agriculture Organization (UN FAO) reports that nearly 240 million people or 1 in every 4 persons in Sub Saharan Africa (SSA) lacks adequate food\(^10\). Over 200 million\(^7\) suffer debilitating symptoms of chronic to severe malnutrition, which also contributes to more than half the deaths of children below 5 years.
On population, the current global stands at approximately 7 billion while Africa’s is at approximately 1 billion people. On the continents youth bulge and unemployment, it is projected that another half a billion people will be added to the continent by 2030, culminating to an estimated population of 2 billion inhabitants by 2050\(^11\). The youth of age 15 – 25 who currently constitute a majority, at 200 million, are projected to double by 2045\(^11\). They are also the majority unemployed, with 60% youth unemployment\(^12\). Few opportunities do exist for active youth participation in the decision making process due to limited access, control and ownership to skill, tools and resources among both young people and governments that are required to engage in meaningful consultative processes and implementing action plans in support of EbA. Often, government lack understanding of the benefits of youth involvement in consultation processes, and advocacy based groups have limited capacity to maintain momentum of continued actions in promoting EbA to enhance food security. Going forward, it is estimated that 350 million young people will be entering the labour market by 2035\(^13\). This presages more mouths to feed and more jobs to create.
This dichotomy reiterates the general finding of the 2014 progress report that economic growth in Africa has not been inclusive.
In addition to raging poverty, malnutrition, the youth bulge and unemployment, climate change and its impacts on the agriculture sector, which is not only a source of food but of employment to 60% of Africa’s labour\textsuperscript{14} further compounds Africa’s outlook.
Africa is reported by the IPCC AR4\textsuperscript{15} as being among the most vulnerable regions to climate change, with wide ranging impacts impinging on its economic growth. The varied impacts are articulated in the IPCC AR5\textsuperscript{16} and the Africa adaptation gap report, and cover sectors including among others, healthcare, water resources, ecosystems and agriculture, which is 98% rain fed hence vulnerable to climate change\textsuperscript{17}.
The World Bank reports\textsuperscript{18} that by the 2030s, climate change impacts in SSA, such as droughts and heat, will leave 40% of the land now growing maize unable to support the crop, while rising temperatures could cause major loss of savannah grasslands, thereby threatening pastoral livelihoods. The implication is that by 2050, depending on the sub-region, the proportion of the population undernourished is projected to increase by 25 – 90% compared to the present. This will cascade onto labour availability and productivity and intensify poverty.
However, Africa is not without solutions. By focusing on agriculture, a sector which not only employs up to 60% labour in the continent, but in which, women produce up to 80% of food\textsuperscript{19}, inclusivity in economic progress can be greatly enhanced.
For agriculture to succeed, committing to, building on and implementing continental wide initiatives, like the AU/NEPAD\textsuperscript{20} Comprehensive African Agriculture Development Programme\textsuperscript{21} (CAADP) as well as the Malabo Declaration\textsuperscript{22}, which builds on the CAADP will have to be prioritized. With such success, the nexus challenges of climate change, food insecurity and related loss of livelihood can be solved. To this end, this brief hopes to enhance the realization of the Malabo Declaration and related vision 2025 for Africa’s agriculture - ‘shared prosperity and improved livelihoods’. This by building on its strategic action areas as captured in the implementation strategy\textsuperscript{23} including increasing sustainable agricultural productivity in an inclusive manner, increasing resilience of livelihoods and production systems to climate variability and change among others through recommending the upscaling of EbA for food security while simultaneously embracing agriculture value addition so as to optimize productivity.
### 1.1.1 Business as usual
In seeking solutions to challenges confronting African agriculture, interrogating the outcomes of conventional/current agricultural practices in the face of climate change is warranted.
Food and nutrition security has been defined by the World Food Summit\textsuperscript{24} as the condition where all peoples at all times have social, economic and physical access to sufficient, safe, and nutritious food to meet their dietary and preferential needs for an active and healthy life. For food security to be realized, the four pillars of food security, i.e. physical availability of food, economic and physical access to food, food utilization and stability of the three aforementioned pillars over time, must be satisfied simultaneously as discussed by the UN FAO\textsuperscript{25}.
While these pillars provide a useful framework for understanding food security, the vital environmental dimension of food security, the ecological foundation of the food system which technically underlies food production, encompassing the resource base supporting food production (land & water) and ecosystem services provided by nature (such as soil formation, nutrient recycling, off and on-farm biodiversity etc.) form a major component of food systems that remains largely ignored under conventional farming systems\textsuperscript{26}. This has led to the degradation of ecosystems and subsequently contributed to food security challenges in Africa.
With degraded ecosystems, the capacity for future food productivity is also lost. Conventional food systems, which degrade ecosystems therefore result in loss of potential food.
For instance, on land clearing alone, the threat of conventional farming systems on forest ecosystems in Africa is manifest. Between 2000 and 2010, up to 13 million hectares of forest were cleared\textsuperscript{27} annually primarily to expand land for food and fuel\textsuperscript{28}. Under these conventional systems, food is not only lost as opportunities for food production through degradation of ecosystems, including agro, forest and aquatic ecosystems, but also as direct post-harvest loss (PHLs), especially in the field, storage, or during transportation. This is due to the conventional systems’ focus on expanding production by increasing yields on the farm, instead of a wholesome consideration of the entire food production value chain.
On PHLs, sub Saharan Africa (SSA) loses food worth up to USD 4billion annually, enough to feed 48million people per annum\textsuperscript{29}. PHL accounts for up to 67% of total food lost in SSA. The loss is attributed mainly to inadequate financial and structural resources for proper harvesting, storage and transportation, as well as unfavourable climatic conditions for food preservation\textsuperscript{30}. These contribute toward making Africa less food secure. By focusing on the value chain, through the application of appropriate technology and value addition and conversion strategies at and beyond the farm gate, the threat of PHLs on Africa’s food security can be significantly reduced.
Presently, SSA is not food secure despite its vast potential for food security - holding 65% of the world’s arable land\textsuperscript{31} and 10% of internal renewable fresh water sources\textsuperscript{32}.
By reorienting toward ecological food systems that take into account sustainable productivity at the farm level so as to secure the *ecological foundation* of food production as well as appropriate value addition strategies along the entire food value chain, such losses can be averted, and Africa’s food security enhanced.
The fact that *conventional food production systems are undermining the ecosystem services that food production depends on* should be appreciated. By focusing on expanding production only, they fail to take into account the bigger picture constituting sustainability in productivity and appropriate value addition strategies along the entire value chain to unlock more opportunities. Consequently, significant amount of potential and harvested food is lost, making Africa less food secure. To safeguard future food security in the face of climate change, it is necessary to implement approaches that will not only focus on enhancing agricultural production, but also safeguard the ecosystems which underpin *agricultural productivity through their services* and enhance their resilience to ensure their sustained productivity under climate change.
### 1.1.2 A paradigm shift
However, Africa is not helpless. By investing in its ecosystems and working with nature, Africa can climate proof its food production systems and contribute to sustainable agricultural productivity hence enhance food security under a changing climate. Together with investments in value addition processes along the agro-value chain, potential opportunities for employment for the growing and increasingly young population are created. Thus can Africa unlock its vast potential in the agriculture sector, which is accessible to the majority in the continent.
Ecosystem approaches, *an alternative to conventional approaches*, aim not only to maintain but also to improve the fertility and productivity of ecosystems. They often include traditional practices such as conservation agriculture, crop rotation, inter-cropping and biological control of pests. Such sustainable approaches are implemented to prevent soil erosion, improve soil fertility and enhance biological diversity. And with this, is an enhancement of productivity of ecosystems and consequent improvement in potential yields.
As examples, *maize rotated with soybean yields 5–20% more than continuous maize monocultures*. *Rotating peas with wheat increases soil nitrogen levels by 6–14 kg/ha*, and with this, *an 8% increase in wheat yields*[^3]. Intercropping lablab beans[^2] with maize will increase maize harvests by over 50% by the second year, provide a widely consumed bean containing 23% protein, and will fix over 40 kg/ha of nitrogen.
Sustainable ecosystem based approaches are also *easily adaptable in most rural communities*, since they involve agricultural practices that have been used traditionally. Considering that *60% of African farmers are rural and small holders*[^4], this fact constitutes a big plus. Ecosystem approaches are also *more effective and cheaper*[^5] to maintain.
Ecosystems approaches will significantly reduce amount of potential food lost, boost Africa’s food productivity and hence contribute toward enhancing Africa’s food security and adaptation to climate change.
This new paradigm is more than sustainably increasing productivity at the farm level. It integrates value addition processes along the entire value chain by linking farm production activities/operations and produce with value addition service providers such as suppliers of inputs, processors of produce, transporters, storage services etc., at and beyond the farm gate including market access and distribution. It takes a holistic perspective to enhance productivity and reduce food waste along the value chain while unlocking opportunities for income generation through the value addition processes. In the words of John Kufuor former Ghanaian president, who is recognized across the continent for his personal commitment and visionary leadership to alleviate hunger and poverty, “*while increasing crop yields is vital, it is of little use if the product cannot be stored safely or transported to markets*[^6].” Hence the logic behind this integrated holistic paradigm. This paradigm enhances *green value chains*[^7], by embracing sustainable ecological food production techniques that prevent degradation and enhance ecosystems at the farm gate level while aiming at reducing food loss along the entire food value chain by exploring and exploiting value addition processes along the chain.
**Greening the value chain**
Consideration of “green value chains” is important from ecological agriculture perspective to assist businesses adopt eco-friendly practices. Greening value chains refers to implementing processes that proactively facilitate environmentally sustainable food system development and promote adaptation and resilience to a changing climate through efficient use of natural resources; minimizing environmental pollution; and minimizing the vulnerability of human and natural systems to extreme climate events due to climate change.
Greening value chains involves implementing green activities (as defined above) with the full range of actors (agricultural input providers, farmers/producers, service providers, traders, cooperatives, agri-businesses and other actors) along the value chains of specific commodities and building synergies along such value chains to reduce environmental impacts. The concept of greening value chains also incorporates activities to help the various value chain actors to adapt to a changing climate and develop more
---
[^2]: Lablab beans, known as *njahe* in Swahili are widely known and hence better referenced in Africa
[^3]: [https://www.researchgate.net/publication/22900000_Rotating_Pea_with_Wheat_increases_Soil_Nitrogen_and_Yields](https://www.researchgate.net/publication/22900000_Rotating_Pea_with_Wheat_increases_Soil_Nitrogen_and_Yields)
[^4]: [https://www.fao.org/faostat/en/#data/QC](https://www.fao.org/faostat/en/#data/QC)
[^5]: [https://www.researchgate.net/publication/22900000_Rotating_Pea_with_Wheat_increases_Soil_Nitrogen_and_Yields](https://www.researchgate.net/publication/22900000_Rotating_Pea_with_Wheat_increases_Soil_Nitrogen_and_Yields)
[^6]: [https://www.researchgate.net/publication/22900000_Rotating_Pea_with_Wheat_increases_Soil_Nitrogen_and_Yields](https://www.researchgate.net/publication/22900000_Rotating_Pea_with_Wheat_increases_Soil_Nitrogen_and_Yields)
[^7]: [https://www.researchgate.net/publication/22900000_Rotating_Pea_with_Wheat_increases_Soil_Nitrogen_and_Yields](https://www.researchgate.net/publication/22900000_Rotating_Pea_with_Wheat_increases_Soil_Nitrogen_and_Yields)
resilient livelihoods. It includes (1) ensuring efficient and sustainable use of natural resources on the input side and increasing returns to products that have undergone processes that are environmentally sustainable and/or climate smart on the output side (2) maximizing material and energy efficiency at each stage of the value chain (3) reducing negative environmental impacts and GHG emissions at all points of the chain; (4) using climatic information and forecasts for decision-making; and (5) exploiting opportunities for promoting more sustainable practices beyond the particular value chain.
**Postharvest losses**
On PHLs, value addition and applying innovative technology has the potential to reduce losses in storage and transport. The hematic bag **an affordable intervention**\(^{38}\), has demonstrated its efficacy in reducing storage losses. Mobile innovations can be applied to link rural farmers with large-scale buyers with potential to deploy effective vehicles that ensure minimal loss on the road hence significantly reduce transportation losses. Traditional and affordable indigenous knowledge based value addition processes such as **earth pots to store and preserve yam harvests by burying, smoking of fish and meat**\(^{39}\); innovations such as **solar based milk coolers**\(^{40}\) etc. are further examples of affordable value chain processes that are integrated into ecological agricultural production techniques to unlock income opportunities and prevent food loss in this new holistic paradigm.
Together, investing in ecological techniques that improve agricultural productivity without jeopardizing the capacity of ecosystems to sustain future productivity, as well as taking a value chain perspective of the entire food production chain, to ensure unlocking of additional income opportunities along this chain constitute the paradigm shift, that takes a holistic perspective of agricultural productivity.
To safeguard Africa’s food and livelihood security, policy and institutional reform is only one of several recommendations that can aid in operationalizing the new paradigm. Others include strengthening knowledge management, increasing communication and outreach, supporting capacity building, reinforcing economic incentives and private sector engagement\(^{41}\). All these will need enabling policies to actualize.
For a start, it is an imperative that current successful application of EbA for food security techniques in the continent be understood. This will aid in identifying gaps to bridge, suggest requisite linkages, actions and support needed to upscale EbA for food security both horizontally and vertically, through a comprehensive strategy to embed it into regional and national food security and climate change frameworks. In addition, it will aid in attracting investment at individual country level toward making this become the framework for all food security and climate change adaptation initiatives in the entire continent.
Understanding different Ecosystems based action techniques and successes will help in suggesting the kind of enabling policies and legislation needed to incentivize countries to invest in them.
This policy – strategic brief, hopes to energize practical evidence-based policy actions for food security at national and regional levels in Africa by showcasing, through both a review of literature and empirical data from projects, cases of successful application of EbA for food security in individual countries and the benefits to farmers thereof. In addition, it hopes to identify gaps and barriers to successful horizontal and vertical upscaling and country investment as deduced from literature and analysis of findings from questionnaires circulated to a wide cross section of organizations in the non-governmental, CSOs, public and private sectors applying these techniques across the continent. In the end, a way forward to achieving scale and country level investment is suggested.
2. Paradigms of agriculture development in Africa
2.1.1 Business as usual – Conventional food production systems
Conventional food production approaches, that involve massive land clearing, the overuse and or misuse of fertilizers and other chemicals that pollute the soil, water and air, result in degraded lands as a result of cutting trees and clearing vegetation which exposes it to erosion & loss of biodiversity. The chemicals on the other hand kill insect pollinators. All these reduce the capacity of ecosystems to provide food\(^42\), and therefore jeopardize future food production.
Deforestation is among significant threats earlier adduced, with annual losses of up to 13 million hectares of forested lands. Going forward, deforestation is projected to increase, with an additional 120 – 140 million hectares being converted by 2030, much of it in Latin America and Sub Saharan Africa, primarily for food production\(^43\).
Clearing land for agriculture threatens environmental sustainability as well as future food security as forests ecosystems play an essential role in food security, providing fundamental ecosystem services such as water filtration and regulation, habitat for wild pollinators, soil erosion control, nutrient cycling that enhances agricultural productivity and climate change mitigation through carbon sequestering.
Preserving forests from further degradation as well as restoring forest landscapes is therefore an important component to food security and income generation. Africa has the greatest recovery potential with 720 million hectares of restorable forests\(^44\). Restoring these forests will go a long way in ensuring sustainable livelihoods.
In agro-ecosystems globally, it is estimated that on average, between 2 and 5 million hectares of land is lost yearly due to land degradation, primarily through soil erosion. Africa is most severely impacted by land degradation and loses 2 to 6 times more than this global average\(^45\). Consequently, yield reductions due to land degradation in some African countries are as high as 40%, while the global average is between 1 – 8%\(^46\). Africa’s food loss due to agro-ecosystem degradation can therefore be proportionately 32% higher than the global average. If at the global\(^47\) level, an estimated 10 million hectares of cropland is lost annually due to soil erosion, equivalent to a loss of 5 million tonnes of grain in potential yield, and enough to meet the annual food calorie needs of 23.8 million people, then proportionately, at 32% more, Africa’s loss in potential yields is substantial, and could be as high as 6.6 million tonnes of grain annually, enough to meet annual calorific needs of approximately 31.42 million people. Theoretically, a conservative estimate would suggest that restoring degraded lands in Africa could potentially make 30 million people food secure.
At the country\(^48\) level, Kenya has registered yield declines on 40% of crop lands, while South Africa has registered on 41% of crop lands due to land degradation associated with conventional farming systems. In Ethiopia, forest area declines by 1% annually\(^49\) due to unsustainable use of forest resources.
SSA is reported as having the world’s lowest crop yields, with cereal yields of 1.5 metric tons per hectare reported in 2011 being roughly 50% of the world’s average\textsuperscript{50}. With low yields on one hand coupled with a growing population on the other, SSA is compelled to meet a significant amount of its food demands through imports. Besides a food import bill of USD 35 billion incurred in 2011 (excluding fish)\textsuperscript{51}, in 2010, Africa imported: 14% of its animal products, 25% of cereals and 66% or two thirds of its vegetable oils. As of 2013, it was reported that SSA relies on imports for approximately 20% of its staples\textsuperscript{53}.
The above statistics demonstrate two key issues.
» One, that SSA is not food secure despite its vast potential for food security - holding 65% of the world’s arable land and 10% of internal renewable fresh water sources.
» Second, that a significant amount of food is lost as opportunities for food production through degradation of ecosystems, including agro, forest and aquatic ecosystems.
» SSA is being economically and socially crushed by the weight of food import bills
» SSA food chain system is stunted by food imports resulting from land degradation, low productivity and high postharvest loss
Under conventional systems which focus on expanding production using unsustainable means such as overuse of inorganic fertilizers and agrochemicals without consideration of the whole value chain that also includes value addition processes such as storage, transport, processing etc., food is not only lost as opportunities for productivity, but a significant amount of food is lost as direct post-harvest loss (PHLs), especially in the field, storage, or during transportation. Under the new perspective where the whole agriculture value chain, from supply, to on farm ecological production and beyond farm gate value processes such as storage, transport, marketing etc. are viewed as a continuum, productivity and efficiency of the entire value chain is enhanced by ensuring sustainable increases in yields on the farm using EbA approaches, and preventing yield losses both on and beyond the farm gate through application of appropriate value addition technology and strategies.
As earlier adduced, PHLs cost Africa as a region significantly. On specifics, Africa’s cumulative grain PHL’s range between 10 – 23%, with field losses at 4 -8%, storage, both at farm and market at 9%, and total transport losses going up to 6%\textsuperscript{54}. As an absolute figure, it is estimated that the annual PHL’s in cereal grains, roots, tubers, fruits, vegetables, meat, milk and fish for SSA were valued at more than USD 48 billion in 2010\textsuperscript{55}. When juxtaposed with Africa’s USD 35 billion food import bill, recovering these losses would essentially eliminate the need for imports without increasing production.
Statistics at the country level corroborate the significance of these losses. In Kenya\textsuperscript{56}, since 2007, PHL’s in maize, currently estimated at 23.4% of total harvest, have cumulatively constituted 125% of total imports. It is argued that reducing these losses by an estimated 75% could make Kenya self-sufficient in maize without increasing production.
Nigeria\textsuperscript{57}, the largest producer of tomatoes in SSA loses an estimated 45-60% in PHL. Consequently, only a third of its tomato processing capacity is supplied. Subsequently, Nigeria has become the largest importer of tomato paste in Africa, costing it USD127 million 2012.
Reversing these losses means recovery of finance, job opportunities in the processing industries as well as buffering food security, considering that food loss and waste is not only a threat to food security but also has significant economic costs.
Going forward, it is increasingly being appreciated, that conventional food production systems that focus on expanding production are undermining the ecosystem services that food production depends on, and do not necessarily take into account a whole some perspective of the entire food value chain to enhance efficiency both within the farm gate and beyond. Consequently, a significant amount of food is lost within and beyond the farm gate, making Africa food insecure. To safeguard future food security in the face of climate change, it is necessary to implement approaches that will not only focus on enhancing agricultural production, but also safeguard the ecosystems which underpin agricultural productivity through their services and enhance their resilience to ensure their sustained productivity under climate change as well as focus on increasing efficiency and productivity of the entire food value chain thereby cut food losses. This is the basis of the paradigm shift envisaged.
### 2.1.2 A paradigm shift – building sustainable food systems and value chains
As earlier noted in the preceding section 1.1.2, ecosystem approaches represent an alternative to conventional approaches\textsuperscript{58}, and aim not only to maintain but also to improve the fertility and productivity of ecosystems. This then enhances potential yields.
To safeguard Africa’s food and livelihood security, practical demonstrations at country level lay ground for a paradigm shift toward ecological agriculture. The UN Global Compact\textsuperscript{59} backs this, by noting that in order to increase food security for a growing global population, it is crucial that sustainable agricultural practices that prevent land degradation and restore degraded land are implemented.
Furthermore, as earlier elucidated, the new paradigm being proposed does not only seek to sustainably improve productivity at the farm level, but seeks to optimize productivity of the entire food value chain, by preventing food loses both at the farm gate in form of lost opportunities for productivity due to degraded ecosystems and at and beyond the farm gate by application of technology and value addition strategies to prevent PHLs either due to transportation, storage etc. and unleash additional productivity and income enhancing opportunities. By preventing environmental degradation, enhancing ecosystems and optimizing productivity and reducing food loss along the entire value chain, this paradigm also promotes green value chains.
On storage losses, the hematic bag earlier mentioned has demonstrated its efficacy in reducing losses. Demonstrations on the bags’ effectiveness in West and Central Africa have cumulatively registered about USD 500 million annually in saved grain.
On transportation losses, poor roads in Africa are the major cause. The application of innovative mobile technologies that link rural farmers with large-scale buyers with potential to deploy effective vehicles that ensure minimal loss on the road presents a potent solution. This has real potential given that Africa is the fastest-growing mobile phone market in the world.
A number of mobile innovations that link farmers to potential markets already exist, and include MLOUMA in Senegal, ESOKO in Ghana, POULTRY GUIDE in Uganda among others. These can be modified to incorporate transport dimensions. Mobile innovations are therefore applicable as among value addition strategies and technologies that prevent can PHLs.
Indeed, mobile technology is set to play an increasing role in Africa as it is projected that by 2025, half of Africa’s 1 billion population will have internet access and there will be 360 million smartphones on the continent.
Consequently, as smartphone technologies become cheaper, application of internet technology is estimated could increase agricultural productivity in the continent by USD 3billion.
This by improving access to value added services such as advice on latest farming techniques, enhancing supply chain efficiency through provision of real-time product-market information, supply of inputs, enhancing access to financial transactions and insurance services among others. Additional micro-tech start-ups providing mobile driven value chain interventions in the continent can be cited.
In Nigeria, a startup firm, Doreo Partners is enhancing supply chain efficiency by applying mobile innovations to bridge the gap of access to credit by small holders. The firm has linked up with Swiss RE to insure farmers against drought. In addition to insurance, the firm also hopes to reach 1 million smallholders by 2025 by providing technology, fertilizer and seeds to farmers, who will pay back when their profits increase.
In Botswana, start-up Modisar tracks cattle herds and gives advice on feed, vaccinations and finance by text message. It won the Orange African Social Venture award last year.
Cameroon’s Mewanko Farm has set-up an online marketplace for farmers to sell fresh produce in a scheme it hopes will increase the income of 13 million people.
The growth in the use of technology in Africa could enhance agricultural productivity for hundreds of millions of poorly-organized and isolated people in rural communities by linking them to global supply and demand markets.
Together, investing in ecological techniques that improve agricultural productivity without jeopardizing the capacity of ecosystems to sustain future productivity, as well as taking a value chain perspective of the entire food production chain, to prevent both on farm losses and PHLs and ensure unlocking of additional income opportunities through value addition along this chain constitute the paradigm shift.
Several African countries have demonstrated quantitative gains of increased food production coupled with enhanced ecosystem productivity through application of ecological agriculture techniques. This is food that is not only increasing community food security and resilience to climate change, but providing livelihood opportunities. Others have gone a step further and implemented the full paradigm by incorporating value addition strategies and unlocked additional income opportunities.
In Zambia, farmers increased crop yields by 60% by switching from monoculture practices to intercropping and other sustainable methods. Through agroforestry (intercropping, barrier crops and nitrogen-fixing crop use), smallholder farmers also produce more diverse crops, which means they can potentially serve a wider market and earn more incomes. By incorporating marketing services as a value addition strategy in their enterprise, the improved crop yields and diversity can be leveraged to service a larger market and enhance incomes to these farmers.
In Senegal, farmers using the Farmer-Managed Natural Regeneration (FMNR) technique have regenerated indigenous trees on 40,000 hectares of cropland. This ecological technique has increased tree density on cropland from an average of 4 to 33 trees per hectares and improved soil fertility, crop yields, and wildlife, and reduced soil erosion.
In Niger, FMNR has populated over 5 million hectares with trees, and in Mali, over 500,000 hectares.
A similar initiative in Ethiopia\textsuperscript{71} has restored 2 700 hectares of barren mountain terrain. Reported benefits include increased food security and reduced poverty through increased income from forest products and livestock fodder; improved water infiltration, which has improved the ground water levels as well as reduced flash flooding; and reduced erosion and increased soil fertility in the region. The participants also earn carbon credits through the Clean Development Mechanism.
Niger\textsuperscript{72}, which was strongly hit by droughts in the 70s and 80s, rehabilitated 300 000 hectares of its crusted and barren, lands by promoting simple soil and water conservation techniques such as contour stone bunds, half moons, stone bunding, and improved traditional planting pits (zaïi). Consequently, both crop yields and tree cover increased and as a multiplier, expansion of the rehabilitated area continued without further development assistance and a land market was developed, suggesting a positive learning process and a green economy-thinking that became self-driven by 2010.
In Kenya, mangroves, which traditionally provide wood and non-wood forest products and services such as seafood (are a breeding and nursery habitat for fish - approximately 31 per cent of the fish landed in the area in 2010 was directly related to the mangrove habitat\textsuperscript{73}), firewood, building poles, and traditional medicine to the local communities, had been extensively used and degraded since the 70s. Loss of mangroves led to shortages of firewood and building poles, a decline in fisheries and increased coastal erosion\textsuperscript{74}, hence the urgent need for the rehabilitation, conservation and sustainable utilization of the mangrove.
Rehabilitation led to recovery of mangroves, whose total economic value was estimated at USD 3,000 per hectare per year\textsuperscript{75}. The project restored and arrested deforestation activities on 107 ha, generating 3 000 tonnes CO2-equivalent of carbon credits to be sold on the voluntary carbon market, generating approximately USD12,000 yearly for the local community\textsuperscript{76}. This was a demonstration of a value chain opportunity. A third of the annual carbon income generated through the project will be used for the rehabilitation and protection of mangroves.
**Unleashing Value Chain Addition in Africa through EbA driven Agriculture**
While ecological techniques ensure sustainable increase in crop yields and increased climate resilience, factoring in value addition and agribusiness along the food production value chain means more incomes and more jobs are created sustainably. Failure to do so translates to substantial income losses. For instance, while Nigeria spent USD 42million to import\textsuperscript{77} over 70,000 tonnes of glucose in 2011, the same could be produced locally from processing cassava, Nigeria’s most important food crop, and in the process, the USD 42million would be incomes earned and jobs created by Nigeria’s economy.
African agriculture and agribusiness is estimated, could be worth USD 1trillion by 2030\textsuperscript{78}. An agribusiness private sector working alongside government could link farmers with consumers and create many jobs. Further, Foreign Direct Investment (FDI) in African agriculture is projected to grow from less than USD 10billion in 2010 to more than USD 45billion in 2020\textsuperscript{79}. In addition, growth in this sector can reduce poverty twice as fast\textsuperscript{80} as growth in other sectors. Africa should capitalize on this.
Opportunities inherent in Africa’s agribusiness value chain have been demonstrated in a number of countries, both by enterprises and individual entrepreneurs. In taking these opportunities, incomes are generated and poverty reduced.
In Uganda\textsuperscript{81}, SESACO Foods Company is leveraging on value addition along the food supply chain. By this, the company employs 80, 55 being women, and generates monthly revenues averaging USD 39,000. In the same country, AGROWAYS (U) LTD., offers cleaning, drying, grading, and storage services to small holder farmers at affordable prices. Through this value addition, farmers are reducing post-harvest loss.
In Nigeria\textsuperscript{82}, a fruit processing enterprise, REELFRUT, managed to expand to 20 retail outlets within three months of establishment. The enterprise processes and packages health snacks made from freshly dried fruits – mangoes and pineapples.
Individual entrepreneurs and the youth are also creating jobs by leveraging ecosystem services.
In Ethiopia\textsuperscript{83}, a young farmer is applying irrigation, and in the process, produces fruits and vegetables on 25ha, and cereals on another 12ha, and employs 50 young persons.
In Lesotho\textsuperscript{84}, a young entrepreneur is leveraging livestock production to generate income, create employment, offer training services and expand into additional businesses in other sectors.
Youths “Youthing” the Value chain?
To realize this potential, there is need to enhance the capacity of African youth to engage in agribusiness, hence ensure they generate incomes while feeding Africa. The African Development Bank\textsuperscript{85} highlights the need to build the capacity of youth through entrepreneurship training to enable them take advantage of agribusiness value-chains and enable them create livelihoods. As practical demonstration of youth engagement, in Uganda, a project – \textit{teens Uganda} – is engaging the youth by creating an enabling environment with better education, exposure and linkages to markets, and in the process, making the community food secure and creating employment opportunities for the youth.
In addition\textsuperscript{86}, the master card foundation has partnered with SNV to facilitate access to secure jobs, financial services and skills for young people to grow their own businesses, making the case for agriculture as a business that offers several pathways to steady employment or entrepreneurship through the \textit{Opportunities for Youth Employment}\textsuperscript{87} project (OYE). From this project, it is envisaged that 20,500 disadvantaged young people will acquire improved skills training in agribusiness and biogas and at least 80% of those young people will be employed or will start their own business in high-growth agriculture and biogas sectors.
These examples demonstrate that the vital role Africa’s youth have to play in building a food secure continent and creating jobs will be unleashed with appropriate capacity building interventions.
Ecosystem based approaches have proven their potency in ensuring increased agricultural productivity while simultaneously enhancing climate resilience. However, the scale of these initiatives has \textit{remained out of the mainstream}\textsuperscript{88} of agriculture policy at both national and regional levels in Africa. The fact that concepts of EbA are considered relatively new\textsuperscript{89} is a possible explanation. Related to this, is the need to accelerate scaling up of these approaches, so as to make them more visible to main stream policy makers.
To upscale this paradigm, policy and institutional reform, strengthening knowledge management, increasing communication and outreach, Educationalizing\textsuperscript{4} EbA driven agriculture, supporting capacity building, reinforcing economic incentives and private sector engagement are among measures\textsuperscript{90} that will be needed.
\begin{footnotesize}
\begin{enumerate}
\item Youthful agriculture based entrepreneurs – \textit{agripreneurs}: \url{http://www.ypard.net/testimonials/agripreneur-new-breed-young-entrepreneurs-combining-their-love-farming-and-agriculture-}
\item Integrating EbA and its principles in formal curricula at elementary, high school, or tertiary/university levels
\end{enumerate}
\end{footnotesize}
3. EbA techniques and their benefits for Africa: Through the Science and Evidence Lens
Among key challenges affecting African crop yields include land degradation which affects 65% of African land, annual loss of 6 million hectares of productive land, degraded to highly degraded soils weathered and depleted of nutrients affecting over 95 million hectares or 75% of arable land, climate change and resulting effects such as moisture stress, a function of not only short lived erratic rains, which come in torrents and result in 25 - 50% runoff loss and increased erosion, but also of the soils inability to hold and release moisture due to degradation, with 10 – 30% water lost to drainage. This is particularly important in light of the fact that over 60% of SSA population depends on rain based rural economies. As earlier explained, the potential yield loss from degradation of agro ecosystems alone is substantial, and could be as high as 6.6 million tonnes of grain annually. This needs to be addressed urgently.
A number of EbA techniques can be applied to address some of these challenges that conventional systems have proven ineffective against.
Small scale water harvesting techniques such as planting pits (zai), rock lines, vegetation strips, ridge tillage will trap water that would otherwise be lost as runoff thus improve infiltration rates, reduce erosion and hence build resilience against both water stress and intensive rain events. Diversifying crops to include moisture resistant species will also diversify household economies and ensure income generation and food security even during droughts. Applying crop residue and compost, agroforestry, integrated soil fertility management (ISFM) using micro-dosing are examples of techniques that will amend soil organic matter and structure to retain nutrients and soil moisture in the root zone and avoid drainage loss. Agroforestry will also reforest bare lands, act as buffer against wind erosion, add organic matter to soil, shade crops and stabilize soils hence enhance reversal of degraded soils, prevent further degradation, enhance moisture retention with resultant improvement in yields. Theoretically speaking, it has been argued that conservatively, restoring degraded lands in Africa could potentially make an estimated 30 million people food secure based on global proportions.
Using green manure and cover cropping systems (gm/ccs) such as legumes has a myriad of food security, competitiveness and ecological benefits. Among these include increased organic matter and soil nutrients, where gm/ccs can potentially add up to 50 metric tons/hectare (MT/ha) or more of organic matter to soil with benefits such as improving soil moisture holding capacity,
increasing total soil nutrients, improving nutrient balance, structure etc.,. Additionally, legumes can fix nitrogen ranging from 50 – 400 kg N/ha\textsuperscript{99} depending on the particular plant. These can produce savings of an equivalent of USD 75/ha\textsuperscript{100} otherwise spent on purchasing chemical fertilizer by substituting with 140 kg N/ha added by gm/ccs. In addition to zero transport costs as they are produced in the field where they are used, gm/ccs can also reduce the amount of chemical fertilizer by 60 – 80% without lowering yields\textsuperscript{101}. These, in addition to cost saving, contribute to emissions reduction hence climate change mitigation.
Gm/ccs also improves competitiveness of small holder farmers in weed control against large scale conventional farmers who use tractors, as they allow application of zero tillage, eliminating the need for expensive tractor tillage operations to control weeds. Application of zero tillage in South America has resulted in small holders producing a sack of maize at 30% less\textsuperscript{102} than nearby wealthier farmers using tractors. In addition to cost control and competitiveness, climate change mitigation is also achieved with zero emissions.
Soil erosion is higher in conventional agricultural systems involving conventional techniques e.g. intensive soil tillage than in soil subjected to conservative practices e.g. no-till. No-till is reported to reduce erosion by 2.5 to over 1000 times\textsuperscript{103}, with median and mean values of 20 and 488 times respectively, relative to conventional tillage practices.
Diversified agriculture is more resilient to climate change and has better mitigation potential. Agro-ecology systems incorporating techniques such as crop diversification, tree planting, mulching and terraces which could serve as barriers are more resilient to climate change and related extreme weather events such as flooding, drought, hurricanes and landslides due to improved soil filtration, and less soil erosion. Improved diversity of species can also protect against invasion of new pests, weeds and diseases, likely stemming from global warming. On mitigation potential, agro-ecology practices are better at mitigation as they reduce greenhouse gas emissions relative to conventional agriculture and improve ability of the soil to serve as a carbon sink due to improved soil organic matter. In developing countries, agro-ecological systems could potentially sequester 1.2 – 3.1 billion tonnes of CO2 annually\textsuperscript{104}, and increase yields of grain and root crops by 30 – 42 million tonnes per year\textsuperscript{105}. High biodiversity correlates positively with high yields.
At country level in the developing world, a study of about 300 agricultural projects covering 37 million hectares across developing countries documented myriad of benefits\textsuperscript{106} from ecological resource-conserving practices, including a 79% average yield increase, substantial carbon sequestration, more efficient water use, reduced pesticide use, and increased ecosystem services.
3.1 DOCUMENTED EBA DRIVEN AGRICULTURE BENEFITS
3.1.1 Benefits documented from individual country examples
In Southern Africa, Agroforestry in Malawi is reported to improve maize yields by about 50% by planting nitrogen fixing Faidherbia albida trees. Quantitative increases from 4.6 T/ha to 5.7 tons/ha have been reported in test/monitored fields in the country. In Zambia, crop rotation results in 50% more maize crop yield than conventionally tilled maize.
Across West Africa, ISFM across over 200,000 ha has resulted in yield increases of 33-58% over four years, and accompanying revenue increases of 179% for maize and 50% for cassava and cowpea. Specifically, ISFM using micro-dosing has been applied by about 500,000 small holders in Mali, Burkina Faso and Niger, with associated increases in millet and sorghum yields of 44 – 120% along with 50 – 130% increases in family incomes.
In Burkina Faso, using small scale water harvesting techniques such as zai and stone bunds to capture rain water and reduce runoff has improved yields from 400 to over 900 kg/ha, increasing yields by 50 – 100%. In addition, farmers have doubled grain yields using multiple water harvesting techniques that include zai pits and stone bunds.
Well managed agroforestry can generate a variety of benefits in addition to enhanced crop yields and include depending on the species of trees, a source of fruit, nuts, medicines and fibre. Large branches can be used as poles or sold for income; smaller ones can be used for firewood, pods and leaves can be used for animal fodder, leaves can also be sold as the case in Niger, where mature baobab leaves are sold for USD 28 – 70, an amount sufficient to buy at least 70kg of grain in the market.
Studies conducted in Kenya and Malawi indicate that using agroforestry – involving use of natural fertiliser trees - and ‘push-pull’ ecological pest control strategy is more cost effective and results in higher incomes and yields than using in-organic mineral fertilizers and chemical pesticides respectively. This was achieved due to a combination of better yields and lower production costs. For instance, in Kenya, farm costs are lower for agro-forestry, 9% of total production compared to chemical fertilizer – even subsidized fertilizer, which takes up 32%.
In Kenya, studies conducted in two regions on maize indicated remarkable productivity differences. In one region, monthly profits were 3 times greater at USD 433 for ‘push-pull’ farmers than ‘non-push-pull’ farmers who registered USD 142 in profits. On a unit basis, ‘push-pull’ farmer’s registered USD 291/hectare/year more profits than their ‘non-push-pull’ colleagues. In another region, average profitability was at USD 588/hectare/year for ‘push-pull’ farmers and only USD 193/hectare/year for chemical farmers, indicating 3 times more profitability for ‘push-pull’ farmers at USD 395/ha/yr. If the same was applied across the country, it is estimated farmers would more than double their incomes to average USD 2.7billion, a huge injection to the rural farmer community.
In Malawi, agroforestry using fertiliser trees results in maize profitability of USD 259/hectare/year and USD 166/hectare/year for chemical fertilizer farmers, a difference of USD 93/hectare/year, a significant difference accounting for nearly one-third of annual incomes in the country. Maize yields were also higher for agro-forestry farmers, at 1,137kg/hectare than the chemical fertilizer farmers who managed 828kg/hectare. It is estimated switching to agro-forestry fertiliser trees would earn Malawian maize farmers a combined income addition of USD 209million per year.
Combining these ecological techniques has reported a multiplier effect on yield increases.
» For instance, in Niger, while agroforestry alone results in cereal yields of about 500 kg/ha, integrating agroforestry and micro-dosing produces about 1000 kg/ha in yields.
» In Malawi, agroforestry combined with micro-dosing increases maize yields from 1.5 t/ha to 3 t/ha or even surpassing 4 t/ha. In the same country, conservation agriculture (CA) – minimum tillage, cover cropping and crop rotation – together with agroforestry improved yields to 7.2 t/ha.
» In Burkina Faso, combining water harvesting techniques such as stone lines with agroforestry increases average sorghum yields by 100 – 200%. When micro-dosing is included, yields increase by an additional 40 – 44%. In the same country, combining simple water harvesting (zai) with micro-dosing in 2010, which was considered a good rainfall year produced sorghum yields nearing 1,900 kg/ha against an average of 200 – 400 kg/ha for untreated fields. This enables small holders to not only be food secure, but also have surplus stock to sell and hence improve household incomes. In 2011, which was considered a dry year, with below average rainfall and low yields for farmers who had not invested in water harvesting, farmers who had invested in zai or half-moons water harvesting techniques realized yields of up to 700 kg/ha. Those who added micro-dosing performed even better with yields of 1000 – 1100 kg/ha.
These examples underscore the fact that these ecological techniques contribute to both climate resilience and food security.
3.1.2 Value addition and unlocking opportunities for incomes and employment along the agro-value chain.
The increasing demand\textsuperscript{101} for food variety across the continent, as demonstrated by the growing urban middle class who are demanding sustainably produced, more nutritious, varied and processed foods portends opportunities for value addition that are already being leveraged. This is generating new jobs and entrepreneurial opportunities for the youth, farm households and rural communities along the African agribusiness value chain.
20% of Africans are middle to upper middle class, with daily incomes of USD 4 – 20, while another 18.8% are high income with daily incomes > USD 20. Factoring in remittances from the diaspora, it is estimated that 300 million Africans, approximately a third of Africa’s population, is middle class\textsuperscript{111}. It is these that are generating demand for value addition along the agribusiness value chain, and thereby creating jobs.
Opportunities inherent in Africa’s agribusiness value chain have been demonstrated in a number of countries as earlier discussed. To ensure these benefits are realized on a wider scale, governments should create an enabling policy environment to incentivize small holder farmer adoption, private sector capital injection to strengthening sustainable agro-value chains, international partners and development assistance to invest in knowledge management, communication and outreach among others.
In addition to literature reviewed, additional empirical cases from individual projects implemented across Africa in recent times can be cited. These provide experience of practical application of EbA- driven agriculture and resultant benefits of enhanced food security, ecosystem productivity, inclusive income generation at rural economy level, climate resilience, and integration of productivity benefits to value addition chains to create further livelihood opportunities, all which enhance the achievement of proposed sustainable development goals\textsuperscript{112} (SDGs) thematic areas such as food/nutrition security and sustainable agriculture, poverty reduction, land degradation, forests and biodiversity among others. Following is a sample of these cases.
3.2 CASE STUDIES AND SYNTHESIZED FINDINGS
This section documents a sample of seven out of a total of 200 ecosystems based adaptation driven agriculture projects analysed across Africa. However, synthesized findings from all the 200 projects are presented. Data for the study was collected by means of questionnaires circulated to a wide cross section of stakeholders and organizations in the non-governmental, CSOs, public and private sector applying these techniques across the continent. A total of 300 questionnaires were circulated out of which 200 were used in the analysis. Non-probabilistic or judgmental sampling methodology was used to select cases, the main criteria being those actors that had demonstrated longevity, having operated successfully in the continent for at least 5 years. Other than its cost effectiveness and time saving advantages, judgemental sampling was considered most appropriate because of the fact that concepts of EbA are considered relatively new\textsuperscript{113} and EbA techniques despite their benefits remain largely invisible to mainstream agriculture across the continent and so the selection of informative cases could not be left to chance. Selected respondents were those successfully applying EbA and agribusiness and were considered well versed on the subject. These projects showcased the new agricultural paradigm. They demonstrated successful application of the following 4 specific EbA techniques for enhanced food security, climate resilience, and ecosystem productivity i.e. i) CA techniques that improve soil fertility and water use efficiency – (no tillage; mulching and cover cropping; crop rotation / diversification), & agroforestry – ii) biodiversity and forestry management -, iii) water harvesting, and iv) livelihood diversification / alternative livelihood. In addition, linkages to value addition chains and creation of opportunities for incomes and job creation along the value chain cascade were also realized by these projects.
Synthesized findings
A total of 200 samples were used for analysis, representing a significant response rate of 66.7%. Analysis involved two levels of reduction using excel spreadsheets. Final analysis was conducted by the African Centre for Economic Transformation\textsuperscript{114} (ACET). Based on this analysis, the most abundantly applied technique (most popular) across Africa was biodiversity and forest management, applied by 68.75% of cases studied. Next were conservation agriculture techniques (43.75% cases), livelihood diversification (25% of cases) and water harvesting (18.75% cases) in that order. No individual project applied all the 4 techniques simultaneously, while 6.25% used 3 of the techniques, 43.75% used 2 techniques and 50% used 1 technique.
It was also found that projects applying one EbA technique tend to have the highest food security impact, the highest rate of enhanced community climate resilience, and the highest job creation potential. On specific EbA techniques, CA techniques contributed most to increased yields; biodiversity and forest management tended to contribute most to building community climate resilience, while water harvesting technique was creating the most value addition and income generation opportunities. It was also found that the number of techniques applied correlated positively with all the envisaged benefits of the new paradigm i.e. climate resilience, ecosystem productivity enhancement, food security, value chain opportunities and income generation. Consequently, to reap maximum benefits from EbA, based on this analysis, there is need to invest in a variety of EbA approaches in a given community.
Some of these empirical results are illustrated below.
**Figure 1: Percentage popularity of techniques**
**Popularity of techniques (% popularity)**
- **Water harvesting**
- Percentage popularity: 19%
- Cases / projects using technique (X/200): 38
- **Livelihood diversification**
- Percentage popularity: 25%
- Cases / projects using technique (X/200): 50
- **Conservation agriculture techniques**
- Percentage popularity: 44%
- Cases / projects using technique (X/200): 88
- **Biodiversity and forest management**
- Percentage popularity: 69%
- Cases / projects using technique (X/200): 138
**Figure 2: Proportion of techniques as applied across projects**
**Number of techniques applied across projects (Y/4)**
- **Only 1 applied**
- Percentage: 50%
- Cases (X/200): 100
- **Only 2 applied**
- Percentage: 44%
- Cases (X/200): 88
- **Only 3 applied**
- Percentage: 6.5%
- Cases (X/200): 13
- **All 4 techniques applied**
- Percentage: 0%
- Cases (X/200): 0
**Examples of some case studies that contributed to the Analysis**
### 3.2.1 The Lake Chilwa Basin Climate change Adaptation project – Malawi
**The problem**: unsustainable land use practices over the years resulted in the degradation of ecosystems in the project site. This included degradation of forest catchment areas that resulted in impacts such as increased soil erosion leading to increasing siltation in water bodies, receding lake, which was close to drying in 2012, and hydrological regulation problems of droughts and floods.
**Techniques**: EbA technologies that included CA; and Reforestation; as well as capacity building /training of local and district institutions on natural resources management to enhance community capacity to implement adaptation actions and introducing alternative livelihoods (animal and fish farming) and drought resistant crops enhanced food security and built the communities resilience to climate change effects especially drought, while simultaneously restoring the ecosystem and enhancing its productivity and ensuing services such as hydrologic regulation to control flooding.
Results:
Capacity building for climate adaptation at local and district level
A total of 53 stakeholder groups (973 people) including members of parliament, district technical personnel, extension workers, community based environment and natural resources management committees and radio listening clubs were trained in climate change mitigation and adaptation. 5 radio listening clubs were established and developed and broadcast over 30 climate change programmes on public radio. This increased climate change knowledge and food security enhancing adaptive techniques to 70% of community up from a baseline of 15%.
Food/nutrition security enhanced
The Programme supported 269 smallholder households to undertake conservation agriculture on 44 hectares. With this support, household yields increased from 200kg (lasting 4 – 6 months) to at least 750 kg of maize per household per annum, enough to last all the year round. This totals average yield increase from 0.5 to 1.25 MT/Ha, improved maize yield of between 2.8 and 3.2 t/ha from 1.5 t/ha previously.
21,000 of 184,000 people (4,536 households of 40,000 HHs) were made food secure. 210 farm families were supported with start-up inputs for alternative livelihoods (100HHs given 48 piglets and 462 HHs given 2756 chickens) to diversify food and nutrition sources and ensure security even when staples fail.
» -1000 farm families supported with 12,000 fruit trees - grafted mangoes, avocado, pears and citrus fruits. These provide vital vitamins improving on the community's nutritional security.
» -3,702 smallholders supported with cassava, sweet potatoes that were planted on 73 ha; production approx. 1200MT
» -Early maturing drought resistant crop varieties help farmers escape hunger in dry months
Climate adaptation / resilience building
Improved forest management/governance and restoration of degraded forests provided resilience against flooding and soil erosion. 20 Village Forest Areas were established and a total of over 1 million tree seedlings planted in the once degraded basin ecosystem. In addition, fire management efforts improved. The area damaged by fire reduced by 22.5% from the baseline of 102.6 ha. Early maturing drought resistant crop varieties also introduced to help farmers escape hunger in dry months.
-Over 1000 people equipped with knowledge and skill in climate change adaptation, with over 100 programmes on adaptation played on national radio
» -834 small holder farmers undertaking conservation agriculture techniques (CA) on approx. 145Ha of land. CA increased productivity and resilience of soil system to drought, and erosion
» surplus yields from crops and fisheries improve resilience of farmers to unpredictable rains and floods
» weather and water monitoring assists stakeholders to take timely action in emergencies
» 210 farm families supported with start-up inputs for alternative livelihoods (70 families given pigs and 140 given poultry). Alternative livelihoods to increase resilience to climate related food stress
» Mobilizing support towards the treatment of bilharzia: 9,095 people and 85 pupils treated; Mobilizing support towards addressing cholera. Under a changing climate, the IPCC AR5 reports that the prevalence of existing infectious diseases increases.
**Ecosystem productivity enhanced**
Restoration activities resulted in the establishment of over 30 Village Forest Areas and planting of over 1.6 million trees in the basin and former degraded fragile areas. The area damaged by fire has been reduced by 22.5% from the baseline of 102.6 ha. These has improved soil fertility, biodiversity (return of birds, insects mushrooms, wildfruits) while enhancing the capacity of this ecosystem to continue providing services such as flood regulation, erosion control.
» water catchments have been protected from human degradation
» river banks rehabilitated
**Incomes / jobs created**
Project trained and provided business support to 25 producer groups involving 300 business persons, who include women fish traders and pigeon pea farmers. Material support included construction and provision of solar fish driers and fuel-saving fish smoking kilns to 3 women fish trading groups and linking of smallholder pigeon pea farmers to lucrative markets in Blantyre. The solar-dried and smoked fish is packaged and sold in chain stores while the pigeon peas are sold in bulk to Processors in Blantyre. This resulted in 125% increase in revenue generated from fish sales while total revenue generated by pigeon pea farmers increased by 20%. In 2011, the farmers sold 28 tons of pigeon to Rab Processors, realizing approx. USD 8,500 income.
» 85 women fish traders produced over 8 metric tons (MT) of fish - registered a price increase of 170% (from USD2.86 to USD7.71 /Kg)
» Marketing skills enhanced through agribusiness training. This increases earning potential of community
» The program created self-employment to the beneficiaries in the areas of fish production and processing, honey production, marketing and trading of high value crops like rice, pigeon peas etc.
**Value chains enhanced**
Project has resulted in value addition opportunities cascading down the food production chain. Out of fish farming, fish smoking, drying and packaging have emerged as value adding activities that are creating livelihood/income opportunities for the community. Opportunities for solar driers and fuel saving smoking kilns enterprises have also emerged out of fish production activities in addition to fish packaging activities. Total of 698 households were supplied with improved cook stoves
» 170 enterprises given start-up capital for value addition of fish, rice, pigeon peas, chillies
» 85 women benefiting from solar fish dryers and improved fish smoking
» many crop and fish enterprise groups linked to markets and banks
» Mobile banking services mobilized for fishing communities, enhancing financial value chains
**Vertical upscaling potential / suggested actions to influence policy / policy changes suggested**
» The integrated approach, bringing together various sectors towards the management of resources through involvement of policy stakeholders i.e. members of parliament as well as experts at local and district levels i.e. district technical personnel, extension workers, community based environment and natural resources management committees as well as successful implementation of the project increases chances that findings of this project will be used to inform policy making, hence ensure principles of EbA are integrated into national and local agricultural and natural resource management policy.
» Capacity building of extension officers who interact with farmers on the ground increases the chances of successful application of these techniques by farmers. – Based on experience from this project, integrating top-down policy influence through involving policy makers in critical phases of demonstration projects such as implementation of activities and sharing outputs in form of policy briefs, news flashes etc. to strengthen evidence based policy making with bottom-up capacity building of implementers such as training and practical involvement of extension officers and
farmers to enhance successful implementation of techniques and sustainability of the project outputs is suggested as a potent strategy to achieve vertical upscaling at country level.
**Horizontal upscaling potential / suggested actions to enhance replication**
» This project had significant replication potential. Some of the piloted initiatives systematically scaled out without further support. In addition, other projects in Malawi copied the approach, further indicating its potential.
» Going forward, increasing communication and outreach about project activities achieved through the radio listening clubs that were established as well as the climate change programmes broadcast over public radio will also enhance the projects replicability by increasing awareness of the radio audience on the project success and potential benefits that could be ripped from implementing EbA initiatives as was the case in this project.
» Based on the project implementation, awareness raising through local, national and even international (internet/websites) media is suggested as a possible technique of communicating project successes to a wide audience and enhancing chances of replication at both country and regional scale.
### 3.2.2 Fish and crab farming in Mozambique / Ecosystem Based Adaptation and Improved Livelihood of Zongoene and Mahilene Communities, Limpopo River Basin - Mozambique
**The problem:** ecosystem degradation brought about by unsustainable use of natural resources – i.e. mangrove deforestation - and compounded by climate change. This then led to a cascade of challenges, affecting both the food and nutritional security of the population, their livelihoods as well as hampering ecosystem services such as flood regulation.
» Influence of floods and droughts affecting key livelihood activities for the community: rain-fed agriculture, fishing and traditional livestock rearing.
» Destruction of extensive patches of mangrove during the 2000 floods, over exploration, and very poor natural regeneration.
» Decline in local fishery and low yields in agricultural production.
**Techniques:** Mangrove reforestation applied and a small dam constructed to address resilience to floods, droughts; alternative livelihoods - fish and crab farming introduced as an alternative income activity to cutting mangroves for sale to address mangrove degradation. This also increased community resilience by addressing nutritional and food security themes under climate change.
**Results:**
**Capacity building for climate adaptation at community level**
Approximately 1500 community members, students and community leaders benefited from capacity building. This entailed skill development, and increased awareness achieved through ensuring community participation in implementing project activities, hence broadening local knowledge on climate change adaptation and the need to sustainably manage ecosystems in order to benefit from their services and build resilience. In addition, mangrove restoration ensures not only flood protection but being breeding grounds for fish and crabs, enhances food and nutritional security, building resilience of community against climate change effects.
**Food/nutrition security enhanced**
From this project, 3000 fisher families were made food secure. A community once depended on declining sea fishing for significant dietary needs, which experienced on average 4-5 months of food shortage annually, now generating 1,066 Kg of fish produced in 4 ponds over 6 months; enough is generated for consumption – 300Kg consumed by local community; and a surplus of 766Kg sold. In addition, 84Kg of crab produced monthly in 84 cages to boost food security.
**Climate adaptation / resilience building**
Livelihood diversification into fish and crab farming used to increase community resilience to declining sea fish; crab farming also reducing deforestation pressure on mangroves while creating demand for restoration activities. This builds on the mangrove reforestation which provides hydrologic regulation services to address floods and drought
» Small dam constructed to regulate water flow to mangrove reforestation area, as well as harvest water and regulate floods, hence building community resilience to both droughts and floods
» Adaptive capacity of 131 households (HH) or 655 people enhanced by directly benefiting from crab farming (10HH), fish farming (20HH) and mangrove reforestation (101HH). 4HH permanently involved mangrove nurseries.
» Approx. 1500 community members, students and community leaders benefited from capacity building (skill development, and increased awareness hence broadening local knowledge on climate change adaptation)
**Ecosystem productivity enhanced**
The restoration of mangroves ensured the continued productivity of ecosystem by providing a nursery area for marine species like fish, crabs and shrimp. The following activities also enhanced the productivity of this ecosystem:
» Planting 50 ha of degraded mangrove area with over 2,000 plants per hectare restored the flood control, soil stabilizing aspects of this ecosystem
» Establishment of 1 mangrove nursery with a capacity for 50,000 mangrove seedlings to sustain reforestation activities into the future.
» Planting diverse species - 6 mangrove species used for reforestation - enhance biodiversity
» Mangrove replanting reclaiming degraded area - approx. 10ha of degraded mangroves reforested
**Incomes / jobs created**
With implementation activities, over 60 community members were employed in restoration and other resilience activities, including fish pond construction; dam construction; rehabilitating channels for mangrove irrigation and mangrove replanting; mangrove nursery management
» Within first period of project operation (approx. 6 months), a total income of USD 2,641 was realized from sale of fish, while USD 217 was realized from sale of crab
**Value chains enhanced**
The implementation of this project resulted in creation of opportunities along the value chain. The supply of fingerlings to restock fish ponds was a critical activity deriving directly from the success of this project. Other value chains enhanced included
» Fish feed business enhanced;
» Pond rehabilitation/construction activities supported (4 fish ponds of 400M2 and 3 ponds of 1200M2)
» Management of mangrove nurseries supported;
» Construction of crab growth cages supported (200 cages at start of project operation).
**Vertical upscaling potential / suggested actions to influence policy / policy changes suggested**
Though not directly addressed in this project, opportunities for future policy intervention are facilitated by this project in a number of ways
» Brings a new mindset to local community: based on the project, community members are willing to learn and adopt fish and crab farming as new livelihood strategies; Eduardo Mondlane University implementing commercial fish farming in the area.
» Community involvement in different project activities e.g. trainings, capacity building, workshops, awareness has helped in making climate change a priority in local interventions
» Data and information sharing among stakeholders on climate change adaptation technologies and best practices contributes to local knowledge on adaptation and widens livelihood strategies
» By enhancing community knowledge and information sharing on climate change, this project lays a basis for future bottom-up policy reform. With an informed public, chances of them demanding relevant policy that has proven to address their food and livelihood security and resilience building challenges is high.
» Based on this, community empowerment and capacity building through involvement in project activities is suggested as a technique to foster community led or bottom-up policy reform.
**Horizontal upscaling potential / suggested actions to enhance replication**
Across Mozambique, the potential is promising. This is because fish and crab farming, including mangrove reforestation is viewed by the local community as a means to food and livelihood security in the face of climate change.
Based on this, it is suggested that EbA demonstration project interventions, that address prominent challenges be targeted to enhance chances of replication across a country or region.
### 3.2.3 Green water saving in Ngusishi catchment in Kenya
**The problem:** surface water depletion downstream due to global and micro-climate change
- deforestation (which threatens water infiltration/ground recharge & storage and related hydrologic regulation of floods)
- declining water quality which impacts living systems within catchment
**Techniques:** A wide range of techniques were applied, and included payment for ecosystem services to enhance soil & water conservation, rain water harvesting and storage; agro-forestry
**Results:**
**Capacity building for climate adaptation at community level**
By involving local farmers in project implementation activities e.g. water harvesting, payment for ecosystem services like water, it not only builds their knowledge, but improves sustainability as it enhances farmers’ ownership and cooperation in the management of their catchment.
**Food/nutrition security enhanced**
- 3.4% increase in crop yield, contributing to enhancing food security
- 3.4% increase in crop adaptation to drought/flood thus enhancing yields and hence food security.
**Climate adaptation / resilience building**
- 3.4% increase in crop adaptation to drought/flood improving community resilience to climate change food security related impacts of these challenges
- 3.4% increased adoption of water use quotas by farmers, thus enhancing resilience to water stress
- 20.7% increase in adoption of improved and cheap agro-technologies e.g. mulching, agro-forestry, use of multi-purpose trees that improve soil fertility, water retention capacity and structure even under a changing climate
- 19% adoption of rainwater harvesting and storage to improve community resilience against water stress.
**Ecosystem productivity enhanced**
- 17.2% increase in biodiversity specifically wildlife
- 20.7% increase in stream flow as a result of reforestation activities
- 12.1% increased soil fertility/declined erosion
**Incomes / jobs created**
Directly, job security in agriculture and irrigation improved as a result of mitigating agricultural water vulnerability to climate change.
**Value chains enhanced**
Success and sustainability of this project indirectly, contributes to rainwater harvesting and storage/water tank equipment enterprise and its value chain.
**Vertical upscaling potential / suggested actions to influence policy / policy changes suggested**
The project proponents suggested the following policy reform to ensure the project benefits are sustainable
- Create appropriate policy to ensure creation of an institution capable of managing resources in an efficient cost-effective way
- to ensure financial sustainability, put appropriate policy to facilitate local stakeholders’ fund scheme rather than
Horizontal upscaling potential / suggested actions to enhance replication
Considerable potential - project being replicated in the whole catchment
» Based on this, it is suggested that EbA demonstration project interventions, that address prominent challenges be targeted to enhance chances of replication across a country or region.
3.2.4 Experience of supporting forest adjacent communities to promote food security in Uganda
The problem: encroachment on protected forest area leading to deforestation; crop raiding by wild animals leading to food insecurity and loss of incomes
Techniques: Included reforestation; crop diversification to diversify both food and income sources; biological control by planting chillies as buffer crops against forest animals; sustainable forest management
Results:
Capacity building for climate adaptation at community level
Engaging the local community in project implementation and operation through training and supplying them with material to implement activities has enhanced their adaptation knowledge and capacity.
» 347 chilli farmers were trained on best agronomic and climate smart agricultural practices, beyond the chilli growing 120 farmers were trained to diversify their knowledge.
» 44 farmers supplied with agro-inputs including pumps, herbicides, fertilizers and seeds to enhance their production capacity under a changing climate.
Food/nutrition security enhanced
Significant reduction of crop damage by animals as a result of biological technique (planting chilli as buffer)
» Incomes earned from sale of chillies used to buy food items hence enhancing nutrition and food security
» Increased crop production e.g. maize as a result of reduced crop raiding (by forest animals)
Climate adaptation / resilience building
Crop diversification to include planting of indigenous tree species that are resilient to local harsh climate conditions is being practised. Households’ preference for these traditional crops over new varieties because of their better adaptive capacity is a sign of success of this technique. In total:
» 120 farmers trained on best agronomic and climate smart agricultural practices such as crop diversification
» 44 farmers supplied with agro-inputs including fertilizers and seeds to help implement climate smart practices, like micro-dosing.
Ecosystem productivity enhanced
» Approx. 31,272 tree seedlings planted to harness the ecosystem
» Reduced disturbance of the ecosystem as access to forest is regulated and monitored
» To date, approx. 64,500 persons reached by project, including farmers, are focusing on implementing management plans to enhance their ecosystems.
» 50 farmers supplied with tree seedlings to establish 40 acres of agro-forestry plots and 15 acres of woodlots. These not only restore but enhance biodiversity of this ecosystem hence its productivity
Incomes / jobs created
» 0.5 tonnes of chilli marketed in off-peak dry season earn households approx. USD60/week
» 3 tonnes of chilli marketed in peak season earn poor households approx. USD240/week
» Woodlots provide opportunity for additional income once they mature and are ready for sale.
**Value chains enhanced**
Marketing of chillies creates opportunity for marketers and other interveners e.g. transporters, and middlemen
**Vertical upscaling potential / suggested actions to influence policy/ policy changes suggested**
The project proponents suggested the following policy reform to ensure project benefits are sustainable
» Implement relevant existing natural management policies fully
» Put policies that ensure all actors including communities, government are involved in governing the natural resource
» Put appropriate policy that facilitate forest estate managers support for communities who have no land to invest in tree planting to accommodate them in conservation activities
**Horizontal upscaling potential / suggested actions to enhance replication**
» Formation of management structures staffed by locals, and which are now the foundation for developing and implementing management plans provides template structure that makes replication and upscaling easier.
The project demonstrates that local engagement can yield vast improvements (an investment of USD13.26/person/year over 4.5 years generated significant gains in ecosystem protection and livelihood improvement while over 31,000 tree seedlings were planted). Considering its cost effectiveness and other benefits, upscaling to other forest-adjacent communities throughout Africa offers major promise
### 3.2.5 Sorghum and Millets Improvement Programme/Promotion of Science and Technology for Agriculture Development in Africa - Zambia
**The problem:** Food insecurity, soil degradation, frequent droughts and poor social economic status
**Techniques:** Conservation agriculture (zero-tillage) for soil retention; Use of improved seed varieties i.e. Sorghum Open Pollinated Varieties (SOPVs) for efficient soil moisture use
**Results:**
**Capacity building for climate adaptation at community level**
Appropriate training on use of SOPVs and climate adaptation provided to community thus improving their resilience. A total of 1880 small scale farmers, (including 300 who were not in the project areas), and 4 large scale farmers not in the project areas benefited. On marketing, there are 80 beneficiaries of market linkage training workshops
**Food/nutrition security enhanced**
SOPVs are tolerant to drought and hence ensure food security even under changing climate. With the SOPVs, complete crop failure is avoided (food available even during droughts)
» SOPVs are indigenous within the already existing agro-ecosystems, hence are accessible to ensure food security in these areas
» Total of 1884 farmers, representing 1884 families made food secure
**Climate adaptation / resilience building**
Disseminated technology (SOPVs) are tolerant to drought (can grow with minimal water). This helped 1884 families to adapt to drought disasters that are a result of climate change
» Appropriate training on SOPVs and adaptation provided to community
**Ecosystem productivity enhanced**
SOPVs on average are more resilient to climatic factors than other cereals and this has ensured the sustained productivity of the agro-ecosystems even under changing climate
» SOPVs use soil moisture more efficiently hence ensure sustainable use of available moisture to enhance productivity of the ecosystem over a longer period relative to other crops that would rapidly deplete moisture.
» Zero-tillage maintains soil structure and helps prevent soil erosion, ensuring productivity of the soil is maintained over time
**Incomes / jobs created**
Farmers generate incomes through sale of sorghum to large scale consumers (over 2696 metric tons (MT) of sorghum consumed by over 7 breweries) as well as small scale and individual entrepreneurs
» Zero tillage technique saves on labor man hours as well as cost. Also the SOPVs adopted (ZSV-36R) is tolerant to birds, thus save man hours that would otherwise be spent minding the birds. Man hours saved represent incomes saved and can also be deployed into other income activities.
**Value chains enhanced**
» Brewery processing chain enhanced – 8 breweries supplied with and consumed over 2696 MT of sorghum.
» 8 private entrepreneurs and self-help groups in the Sorghum Marketing businesses benefited indirectly from networking and collaboration opportunities
» 80 beneficiaries of market linkage training workshops
» The new variety has market in stock feed, hence enhancing value chains in animal feed
**Vertical upscaling potential / suggested actions to influence policy/policy changes suggested**
To influence policy toward adoption of this technology, a policy brief, working paper or fact sheet based on this project and/or the SOPVs technology to be prepared and shared with policy makers at regional events / national level in relevant ministries and governmental department heads in individual countries.
**Horizontal upscaling potential / suggested actions to enhance replication**
The potential is high along the Luangwa and Zambezi river basin due to food in security among the rural communities and frequency of droughts. In places where markets are easier to access replication of the value chains potential is easier. The following incentivize replication:
Within Zambia, an advantage for upscaling is that the technology is readily available from the Sorghum Breeding Programme at ZARI.
» The high cost of agriculture inputs has forced a number of farmers to try this technology as a cheap alternative
» The technology also has commercial value and can help contribute to the poverty reduction among rural communities using the sustainable value chains that it feeds into as demonstrated in this project. This is highly replicable across Africa where sorghum is grown, seeing that poverty is rife in the continent’s rural areas
### 3.2.6 Promotion of soil and water conservation practices in Buluganya sub-county, Bulambuli District – Uganda
**The problem:** Land degradation; low crop productivity; use of un-sustainable farming practices
**Techniques:** Soil and water conservation (SWC) - contour bunds, tree planting, digging trenches, mulching
**Results:**
**Capacity building for climate adaptation at community level**
» 108 individuals comprising 25 females from 36 households (hhs); 46 pupils from P7, P6, P5 & P4 classes, and 10 teachers from Buluganya P/S trained in SWC practices
» Socially, through organizing communities into groups led by ‘champions’, the project led to social cohesion within the parish in which other issues affecting the community were discussed. On several occasions, the groups were visited by health officers, agricultural extension workers and politicians to discuss issues / pass over key information on adaptation.
Food/nutrition security enhanced
With adoption of SWC, crop health has improved significantly. From observation, banana & coffee plants now have fruits & berries respectively and are greener and healthy compared to the previous scenario before SWC.
» Increased production of Napier grass improves cattle productivity hence enhances food security.
Climate adaptation / resilience building
» 108 individuals comprising 25 females from 36 households (HHs); 46 pupils from P7, P6, P5 & P4 classes, and 10 teachers from Buluganya P/S trained in SWC practices, increasing their adaptation knowledge.
» Erosion prevention enhanced. 5000 m of contour bunds raised on 50 farmers’ fields. 4,000m of napier grass planted on the contour bunds. Initially, only 10% farmers knew about bunds and fewer (5% farmers) reported having contour bunds on their farms to prevent erosion.
» 12,500m of trenches established. Initially, only 12% farmers were knowledgeable on trenches and fewer (less than 8% farmers) reported having trenches on their farms. These prevent loss of nutrients from land as soil washed during storms is trapped and can be returned to farm.
Ecosystem productivity enhanced
» 35 farmers mulched their plantations (bananas/coffee). Initially, no farmer practiced this technique. This improves soil moisture and fertility. Health of trees observed to improve, hence soil nutrients enhanced due to mulching.
» 7,500 indigenous trees planted. These improve soil quality and biodiversity. Initially, only 4% considered them as important in soil and water conservation.
Incomes / jobs created
» Tree planting initiative has potential to earn community incomes from carbon financing.
» Increased production of bananas and coffee due to good soil and water conservation practices can go a long way to boost farmers’ incomes.
» Temporary employment: Individuals were hired to make trenches, collect mulch and also to maintain tree nurseries.
» The 7,500 indigenous trees planted are a source of direct income for community from charcoal/timber trade.
Value chains enhanced
With increased cattle, the cattle dung produced has possible spinoffs for biogas industry enhancement.
» Tree planting initiative is an avenue for the community to benefit from carbon financing, and also provide opportunities in tree nurseries as part of the supply chain for the tree planting.
Vertical upscaling potential / suggested actions to influence policy/policy changes suggested
Considering the important role played by trees in conserving soil and water, and current practice where farms are congested with perennials mainly, bananas and coffee, leaving limited space for tree planting, a policy to inculcate agro-forestry in farming practice is suggested.
Horizontal upscaling potential / suggested actions to enhance replication
Considering high demand for similar initiatives from neighboring communities, replication potential is high.
3.2.7 Universities on Ecosystem-based Adaptation in Rural Communities in Zimbabwe
The problem: In the project area, climate variability causing short lived, intense and erratic rainfall results in increased run off causing loss of top soil, increased leaching of nutrients, crops failing to reach maturity (due to shorter unpredictable rain seasons). The specific problems addressed were; food insecurity and desertification of the local habitat.
Techniques: ecosystem restoration (reforestation); conservation agriculture (micro-irrigation), alternative livelihood (fish and poultry farming)
Results:
Capacity building for climate adaptation at community level
- Workshops on climate change resilience conducted
- Community taught conservation agriculture (CA) by the university faculty of agriculture staff
- Project providing community with sound knowledge on climate change adaptation. As an indicator, community now involved in gully reclamation
- Women empowerment enhanced. They have time to attend workshops on food security and climate change, improve their knowledge because of boreholes providing water readily
Food/nutrition security enhanced
- Food production enhanced because of water availability
- University spearheading methods of food preservation hence enhancing food security
- Community practicing Poultry, fish, vegetables production, bee keeping, shomwe (marula seed) production thus enhancing food security
- 50 households (250 people) in a desperate food situation uplifted from high food insecurity
- Availability of food all year round because of irrigation infrastructure (productivity in irrigation schemes is 2-3 times more than in dry land)
- Nutrition garden (monitored by experts from the university) established on 2 acre plot has enhanced villagers’ nutritional needs
- Significant decrease in reported cases of child (0-59 months) malnutrition, from 12.5% in 2010 to 9.9%
- Vitamins from vegetables (medicinal herbs) and protein from poultry, fish increase micro nutrient level of the food in the community
- Community uses incomes generated to buy what they cannot produce hence enhancing their nutritional security
- A wide variety of vegetables now available (onions, tomatoes, carrots, beet root cabbage, rape, nyeve, medicinal herbs, etc.) to enhance nutrition.
- Experimentation with black jack to increase iron content in food
Climate adaptation / resilience building
Micro-irrigation and alternative livelihoods employed to enhance resilience to inadequate rain or crop failure
- Nutritional garden equipped with pumped water (boreholes drilled, tanks installed, gen-sets provided)
- Workshops on climate change resilience conducted
- Community taught CA by faculty of agriculture staff to increase local resilience knowledge
- Project providing community with sound knowledge on climate change adaptation
- Level of deforestation is reduced as traditional leaders take charge of re-forestation activities
- Community is establishing indigenous and exotic fruit tree plantations that are more resilient to local microclimate
- Community involved in gully reclamation - water security enhanced; the boreholes supply water for watering the gardens and for human consumption
Ecosystem productivity enhanced
Micro-irrigation, is restoring the ecosystem by improving soil moisture content, at the same time promoting food security in the community
- Reforestation activities enhancing ecosystem biodiversity
Incomes / jobs created
- Community has realized total of USD 16,000 from sale of their produce
- Vegetables, poultry, bee products, and fish
- 12 men and 6 women were employed during the construction of a concrete tank - 10 youths employed during erection of fence around the project land
» ~200 households are self-employed in the garden
**Value chains enhanced**
This project encourages the following value addition enterprises:
» -Oil extraction from oil rich seeds (amarula/shomwe, Chakata, matamba, makwakwa)
» -Marketing of traditionally prepared amarula wine (mukumbi)
» -micro-nutrient extraction from oil-rich seeds to use as dietary supplements
**Vertical upscaling potential / suggested actions to influence policy/policy changes suggested**
Project proponents suggested that existing / current national policies on ecosystem based approaches should be implemented in full.
**Horizontal upscaling potential / suggested actions to enhance replication**
The replication potential is considerable. The approach as modeled by the Midlands State University (MSU) the main proponent in this project, is replicable by all similar institutions of higher education in all geopolitical systems
» -To date, the approach is slowly being rolled out to other semi-arid districts like Chivi and Buhera
» -The MSU project is used as an incubation center of the adaptive approach used in this project. A local business man has already adopted the MSU approach
4. Upscaling and out scaling of EbA driven Agriculture and Orchestrating the new paradigm Shift– What is needed?
The overarching objective of scale is to link sustainable climate resilient agricultural productivity with value addition in processing and storage, input supply and output delivery chains from and to other enterprises and unlock cascading opportunities for employment and income generation along the entire food value chain, from external interveners and suppliers to the farm, and all the way to retailers and final urban high value consumers. By this, a shifting paradigm on to a new narrative, of climate resilient agri-business (farming as a business) for Africa, producing enough to feed the continent and a surplus to enhance global food security, while simultaneously generating livelihood opportunities for a growing youthful population and the rest in Africa, both at the rural farmer and primary processing level as well as urban second order processing entrepreneurs and industries is envisaged.
A number of measures are proposed to achieve this scaling up.
» **First**, while the food security challenge seems shared across afflicted countries in the continent, the enabling environment that needs to be harnessed at individual country and regional level to combat this challenge by upscaling ecological agriculture techniques that have proven effective is heterogeneous and very context specific. Consequently, any effort to scale up, amplify and transfer successful technologies and strategies should be done in ways that allow for unique national and regional approaches\(^{115}\). For a start, locals, comprising government bodies, institutions, professionals etc. should take the lead in implementation of any proposals as much as possible, with external experts and parties providing technical and financial backstopping and playing oversight especially where financial support has been provided, to oversee prudent utilization of these resources. The UNEP Regional Ecosystem-based Adaptation for Food Security Programme\(^{116}\) (EbAFoS) is a good example that is charting a new paradigm shift towards making the case that addressing food security across the continent needs to be looked at at a regional rather than national level, and that regional integration if driven by foods security concerns has a lot of potential for development in Africa.
» **Second**, barriers to adopting EbA technologies by farmers should be addressed. From literature, the four A’s model as postulated by Bain and Company\(^{117}\) provides a theoretical basis for transforming obstacles toward the adoption of technologies by small scale farmers in Africa into drivers of adoption. According to this analysis that is based on 4 pillars, farmers will adopt a particular technology if they are aware of its existence and have the technical knowhow to effectively apply it. Gender sensitivity is required when dealing with issues of awareness, advantage, affordability and access. To increase chances of adoption therefore, early adopters should be strategically targeted to build trust with them, then leverage them as ‘promoters’ to spread and sustain awareness later in the adoption cycle, as the technology advances to reach the late adopters. Another pillar in this analysis is advantage – that farmers will adopt a technology to the extent to which it demonstrates to increase their financial standing. This was found as the strongest driver of adoption in the study toward developing the 4 A’s. Up to 60% of farmers surveyed indicated that they tried a new product/service because it would increase their wealth. The implication is that farmers must be trained and demonstrations done to facilitate their understanding on how a particular technology will offer them concrete financial benefits over what they are currently using. Affordability is another key aspect that influences adoption. That a particular innovation should be priced affordably and made available at that price at the time when farmers have the money to buy it, considering their seasonal cash flow cycle. It brings to the fore, the issue of timing, that when a particular technology is priced at a premium, it should be introduced to farmers when they have received income from say a previous good harvest. Access is another pillar of this model. That technology must be available when and where it is needed. This is particularly important considering the infrastructure bottlenecks especially in rural Africa, where most farmers reside, and also the seasonal cropping/livestock cycle, since for instance a product/service may be relevant only during the planting season. Appropriate contextual supply chain strategies must therefore be developed to ensure products reach farmers, and the timing should also match the particular period of the cropping/livestock cycle.
In terms of applying this model, Bain and Company report that while all the four pillars are vital, of particular importance at the introductory phase of a technology are advantage and affordability, while awareness and access become increasingly important as technology proponents progress toward achieving scale. This means proponents must invest to satisfy these 2 pillars first before going on to access and awareness later on as the market matures.
Demonstrating that a technology is affordable and will provide financial benefit to farmers are the greatest adoption factors that will then elicit farmers’ interest to learn and increases their awareness of the techniques and take the necessary steps to acquire them.
In addition, since women produce most of the food in Africa it is important to ensure that extension services are available for women farmers and that new technologies are affordable for women smallholder farmers.
» **Thirdly**, efforts should revolve around the needs of *small holder farmers*¹¹⁸, who produce up to 80% of food in Africa. To this end, first, it should be noted that a *majority of small holders are women*¹¹⁹ and they provide 60 – 80% of labor¹²⁰ for food production, both at household consumption and for sale. However, while this is the case, *female productivity in agriculture is lower than men*, primarily because in addition to the external constraints to productivity women farmers equally face with men, they also have an unequal access to resources – human controlled endowments necessary for increased productivity, such as land rights, education, access to technologies, labor, capital, support services and credit.
Considering that agriculture is becoming a *predominantly female sector* in sub-Saharan Africa, as a consequence of faster male out-migration, addressing women productivity constraints will go a long way in building their capacity, and enhancing up-scaling within this vital group. There is also need to recognize unpaid care work responsibility of women smallholder farmers who in addition to performing farming tasks have to fetch water, firewood, do domestic chores such as washing, cooking which though taking a significant amount of women’s time and energy are not recognized as work. In some countries these tasks up to six hours each day. The interventions can be in the form of woodlots which can address firewood shortage, water harvesting technologies to reduce the amount of time spent on fetching water for
domestic use and child care centers which allow women to engage in other productive activities while their children are being taken care of at the child care centers.
In addition to addressing productivity constraints of women farmers, on a general scale, additional needs\(^{121}\) of small holders include development of business management skills to help them better manage resources and risks, and improve decision making. This is to improve quality of interaction and decision making of farmers with businesses with which they interact along the supply chain, from input suppliers, service providers e.g. transporters, storage etc. to ensure profitability even at the farm gate level hence enhance sustainability of farming. This calls for entrepreneurial training for farmers at all levels.
Enhancing the sustainability of access to real time and better quality data and information on crop/animal husbandry and relevant market information relating to cost of inputs and services, produce prices, availability of markets etc. is another need that should be addressed. Mobile applications such as MLOUMA in Senegal, POULTY GUIDE in Uganda, COCOLINK in Ghana are among a dozen innovations\(^{122}\) that have been applied widely to enhance this information aspect, resulting in better decision making to improve both agricultural and financial productivity of farms. In addition, strengthening extension services will go a long way in improving quality of information and hence decision making by farmers.
There is also need to link ecological agriculture produce from small holders to markets. This is an area that governments and the donor community can support farmers in order to create demand and an incentive to invest in ecosystem technologies, hence contribute toward achieving scale. For instance, the international market for organic products with premium prices is an opportunity for farmers to increase incomes. Africa can leverage the demand for organic products in industrialized countries\(^{123}\) as an important growth factor. Another motivation is the maintenance and building of soil fertility on land threatened by degradation and erosion. Donors can support farmers by facilitating their access to specific markets in the developed countries. Governments can also engage in government to government agreements with market countries overseas so as to secure exclusive market deals for their farmers. In addition, as the international organic market continues to grow, governments should put in place appropriate policy and regulatory frameworks to organize the sector, e.g. appropriate labeling and certification guidelines and procedures, so as increase demand in quantity and variety of organic products from Africa in the international markets.
Facilitating formation of farmer groups/organizations, as forums to share best practice, disseminate innovations, inform decisions, support cross-cutting functions such as farm and market advisory, supply of inputs etc. should also be addressed as another area of need for small holders.
Subsequently, addressing the needs of small holders will improve their capacity to not only use but acquire relevant technologies and this wide scale empowerment of small holders will enhance wide scale use of these technologies.
» **Fourth**, ongoing commitment from other actors involved in the food supply chain, specifically government, by establishing and communicating clearly and consistently a country vision for ecological agriculture, and supporting its implementation through appropriate policy and non-siloed, collaborative development and implementation of strategies and policies to ensure the effective application and allocation of resources, both budgetary and manpower to facilitate implementation of such policies and strategies. Donor agencies should also have ongoing commitment by investing in capacity building at all levels, from policy level where strategies are developed to farm level where implementation takes place & coordinating better with other donors to avoid duplication and build synergies.
» **Fifth**, the role of the private sector in investing in market-driven solutions should be defined and enabled where necessary. Government has a vital role to play to actualize this as development of relevant policies to create a conducive market environment and thus incentivize private sector action is the preserve of government. Examples of relevant policy and legislation can include those safeguarding free market, ownership of assets, incentives such as tax waivers on relevant imported industrial goods to facilitate local production, special economic zones etc., as well as clear policy guideline and regulation of targeted industries – clearly stipulating duties and responsibilities of all actors. The enabling environment should also include an effective legal system for redress, and availability of adequate good quality infrastructure (transport and communication, energy, water). Private sector actors bring in market components such as efficiency, technology, professionalism and competitiveness that are vital in achieving scale and sustainability.
» **Sixth**, affordable, sustainable and accessible financing/credit schemes are needed to enable scaling up of on-farm and post farm gate small and medium enterprises (SMEs). Finance will help both farmers and other post farm gate entrepreneurs to expand their businesses, and this is vital in creating the demand chain for these productivity increasing EbA technologies and hence contributing toward scaling up their use. In addition, those involved in the supply chain of these technologies, such as suppliers of improved seed varieties or tree nurseries for agro-forestry will benefit greatly.
from affordable financing to expand their businesses, serve a larger market and thereby, create demand for upscaling the development of these technologies.
» **Seventh**, Educationalizing\(^9\) EbA- Driven Agriculture is a key enabling step. The influential role and input of educational and research institutions in harnessing, and availing appropriate scientific data and information as well as developing, testing and demonstrating appropriate productivity improving EbA technologies to both policy makers and end users, i.e. farmers should be leveraged and strengthened through increased public investment for research and development capacity. In addition, education curricula should be reformed at elementary, secondary and university levels. Curriculum developers at each of these levels should ensure principles of EbA – driven agriculture are integrated from the earliest possible levels of learning to facilitate a generational appreciation of ecosystems, which will increase awareness and likelihood of their use by the population.
The media should also play its role by developing and disseminating programmes to inform the public of climate change and available ecosystems technologies to build resilience. This increased awareness will contribute to scaling up use of these technologies by the public.
» **Eighth**, as the maxim – what gets measured gets done. There is need to progress in strengthening metrics and benchmarks to measure performance and achievement of objectives and enable accountability of ecosystem based adaptation actions by all actors – governments, farmers, private sector, civil society, donor community - involved in activities aimed at scaling up use of ecosystem based technologies. It is worth noting that measuring the benefits of EbA can prove to be quite complex, with different methods that can be applied and a number of uncertainties constraining current approaches. Scientists therefore need to establish and publish the most appropriate methods to measure costs and benefits of EbA. However, currently, methods do exist and are documented by both UNEP\(^{124}\) and the economics of ecosystems and biodiversity (TEEB) in its publication\(^{125}\). Actors should use them appropriately to measure progress, identify accomplishments and gaps and inform further action toward fulfilling up scaling objectives.
» **Ninth**, there is a need to develop and package locality specific (agro-ecological zone and farm system specific) EbA techniques that can be used as a guide to optimize EbA benefits across the different contexts of application. *This will help decision makers to support planning for concise actions to adopt EbA.*
» **Tenth**, unfair trade rules – there is a need to reform international free trade practices / agreements that work to disadvantage African farmers in the global markets. While Africa and other southern farmers are forced to remove agricultural protections like quotas, tariffs, price controls, subsidies of inputs etc., as they are considered barriers to trade, many western governments are allowed to subsidize their agriculture. Consequently, African small holders and agribusinesses are forced to compete with highly subsidized\(^{136}\) North American and European agribusiness. Such skewed trade practices mean Africa cannot be competitive in international trade and unfairly loses out on income opportunities. While African governments should individually and collectively, through RECs and the AU, continue to call for and negotiate for better trade terms at international forums, the continent’s developmental agenda should not be held hostage by this state of affairs. Africa should take this as an opportunity to encourage and strengthen local, national and regional trading relationships, especially on agricultural produce. The goal should be progressing toward formalizing a regional commodities market for agricultural produce, which shall encourage more intra-regional trade on mutual terms, hence more income to the regions farmers. With a better market and increased incomes, enterprises flourish and scale is achieved.
» **Finally**, at the regional level, the vital role of regional intergovernmental organizations such as the African Union (AU), East African Community (EAC), Economic Community of West African States (ECOWAS), Southern Africa Development Community (SADC) etc. regional development finance institutions, primarily the African Development Bank (AfDB) in enabling wide spread policy interventions on continental opportunities and challenges should be leveraged. For a start, support for the implementation of the CAADP, that was the outcome of the Maputo\(^{137}\) declaration and further recommitment to its ideals as captured in the Malabo\(^{128}\) declaration should be a matter of urgency for these organizations. This policy brief hopes to contribute toward the achievement of the ideals captured in these continental blue prints, including the AU Agenda 2063\(^{129}\), all which establish agriculture as a potent industry in ensuring sustainable and inclusive growth in the continent.
5. Enabling policy and legislation to incentivize country investment
A number of policies can be recommended in creating a conducive environment to facilitate investment in the new agricultural paradigm by actors within a country. This paradigm takes a holistic view of agriculture to ensure sustainability and increased productivity from on farm production and efficiency and waste reduction at and beyond to post-farm gate value addition. It involves application of ecological agriculture practices at the farm level to ensure sustainable crop productivity hence food and livelihood security while simultaneously enhancing ecosystem productivity and ensuring climate resilience and integrates value chain enhancement strategies and technologies along the entire food value chain to prevent food loss and create opportunities for off farm livelihood activities. This is in contrast to conventional food systems that focus on increasing production through excessive use of external inputs, mainly energy through mechanization, agrochemicals and fertilizer that jeopardize the long term productivity of ecosystems and does not incorporate value addition chains as a continuum.
A number of groups, within a country can be targeted with enabling policies to facilitate investment at their respective levels. From rural small holder farmers, vulnerable groups such as rural poor engaging in agriculture, to women and the youth, community based organizations, non-governmental organizations, private sector – both large enterprises and SMEs, donor community, educational and research institutions and local governments, all these can be enabled, through appropriate policies, to invest in and effect this new paradigm at their level within a country.
» Generally it is widely agreed that land rights are essential\textsuperscript{130} in motivating short and long-term fixed investments in agriculture by diverse groups, from small holder farmers to larger investor groups in the private sector.
However, land tenure systems in Africa\textsuperscript{131} are not adequately structured and not inclusive. Tenure of over 90% of land remains outside the formal legal system, and the risk of dispossession remains apparent\textsuperscript{132}. Indeed, it is observed that only a small fraction\textsuperscript{133} of land in Africa is subject to individual titling. Most of the land is community-owned, and in some countries state-owned. To incentivize small holders and other interest groups to invest in nature based
technologies, they need to feel secure about the ownership of their land. While individual titling is key to increasing land ownership by individual farmers hence incentivizing long term investment by small holders, a caveat is advised. Based on lessons from Latin America, where “Agricultural modernization” programmes gave title to individual farmers, with the end result that many of them sold huge quantities of land to wealthy nationals and international corporations, and were subsequently left as landless poor, extreme care must be taken to avoid a similar predicament Africa. Consequently, as a safeguard measure, it is recommended that:
i. If land is individually titled, it should not be subject for sale to those outside the village.
ii. If an owner dies without children, or the land is abandoned, that land should revert back to the village as a whole, to be titled again according to the village’s decision.
In addition, women farmers, who make up 70% of Africa’s farmers, are locked out of land ownership due to customary laws. Addressing such governance issues at the national level is vital for achieving increased investment and productivity from this group. For consideration, an appropriate policy that mainstreams affirmative action in land allocation and ownership could be considered as among interventions to bring women at a par with their male colleagues on access to land as a factor of production.
Other than developing and expanding policies, existing policies should be maximized and reformed where necessary.
For instance, outdated and counterproductive forestry legislation that discourages farmers from investing in protecting, regenerating, and sustainable harvesting of trees in agroforestry systems, through ambiguous provisions such as fines for unspecified offences that allow unscrupulous forest agents to exploit farmers should be abolished through a structured process reform. Such are common in a number of countries in West Africa\textsuperscript{134}. These should be reformed to facilitate the involvement of farmers and forest communities in conservation measures. Appropriate policy at local level that gives farmers and forest community access to forests and assigns them responsibility and structure to preside over farmer managed natural regeneration of forest trees could be a viable strategy of involving communities in sustainable management of forest resources. There is also need for community seed banks to promote the use of agroforestry technologies as well as appropriate extension services for farmers engaging in agroforestry.
» Agricultural development policies that emphasize agricultural modernization through the increased use of mechanization and subsidized inputs, while neglecting measures needed to reduce land degradation, facilitate soil and water conservation among other ecological techniques constitute another area that needs agent attention throughout most of Africa. As an example, in Senegal\textsuperscript{135}, the Ministry of Agriculture had encouraged the use of tractors and animal ploughs to plow in straight rows, even if it meant destruction of existing agroforestry areas that had protected soil from erosion and helped to replenish soil organic matter and nutrients. Such policies are an impediment to investment in agroforestry and other improved land and water management practices and should be reformed, to ensure sustainable practices are mainstreamed.
» Existing fertilizer subsidy policies should be maximized by reforming them to complement ecological approaches such as micro-dosing or integrated soil fertility management (ISFM) whose known benefits\textsuperscript{136} include cost effectiveness and significant sustainable improvement in yields and hence incomes, improvement of soil fertility, all without degrading agro-ecosystems. It is also worth noting that fertilizer subsidies are costing African governments huge sums of money. For instance, it is reported that ten countries in sub-Saharan Africa are spending\textsuperscript{137} up to USD 1.05billion annually on imported fertilizer subsidies programmes, representing approximately 30% of their agriculture budgets, while ecological approaches make use of locally available material, in addition to being cost effective, thus ensuring money circulates in local economy. In addition to cost savings, are mitigation (eliminating dependence on fossil fuels) and adaptation (enhancing ecosystems and climate resilience) benefits of ecological approaches. Based on this, African governments should progress toward eliminating chemical fertilizers and the accompanying subsidies and instead, re-invest these monies on promoting ecological approaches.
» There is also a need to maximize existing agricultural and other policy frameworks meant to attract investments into agriculture\textsuperscript{138} such as those securing access to land and water, those guaranteeing well-functioning input and output markets / free market economy, effective mechanisms for enforcing contracts and compensating expropriation among others at country level.
Additional policy actions targeting individual interest groups are as follows:
» First, the private sector as a source of capital and investment should be incentivized. Government policies incentivizing private sector investment such as special economic zones, tax / duty waivers, tax rebates, favourable land lease agreements, etc. geared specifically toward encouraging private sector investment in ecological agriculture as well as agribusiness should be pursued. For this to succeed, commitment from both private sector (e.g. scaling up success,
developing new models for Africa, ensuring additional investment) and senior levels in government (creating and consistently nurturing an enabling business environment e.g. transparent and effective legal systems and appropriate structures to institutionalize good policies and ensure their continuation beyond elections) will be required. The government and private sector must also jointly think of formulating sustainable procurement policies that embrace the “Sustain or be Obsolete”\(^{135}\) or sustainable procurement principle to further enhance the transition of supply chain operations to green value chains\(^{140}\) also promoted by this paradigm.
» **Second**, policies and regulatory frameworks to facilitate inclusive partnerships along the agribusiness value chain among critical players whose investment in this new paradigm will be vital for growth are needed. These are partnerships involving the private sector, farmers, CSOs, public sector, donors and NGOs, research institutions working in collaboration to develop solutions to challenges such as access to markets, financing, developing low risk business models that deliver greater value, developing and testing newer technologies etc.
» **Third**, appropriate policy to productively engage Africa’s youth and women in the agricultural sector and their entrepreneurial skill and spirit through skills development. Specifically, to attract the younger generation to the agri-food sector, the sector needs to be redefined through appropriate entrepreneurship training, and development of technical skills, to shade off its current image of manual labour and subsistence un-profitable farming. For women, who currently produce up to 80% of the food in Africa\(^{141}\), affirmative action policies to ensure their access to training and assets/land ownership will be vital to enhance their productivity, and hence productivity of the sector as a whole. It is also important to recognise in these policies that women smallholder farmers are involved in agricultural production as well as care work which includes activities such as fetching water, firewood, child care among others which takes a significant proportion of their time. Currently the regional bodies do not have clear no clear policies as well as funds allocated to address access to water for drinking and domestic, firewood for cooking and child care in rural farming communities which are primarily done by women. There is thus need for an integrated approach which addresses care work as well as agricultural production.
» **Fourth**, policy to build capacity of small holders to access markets and unlock their entrepreneurial potential e.g. continuous skills development to comply with new market demand, product specification etc. is required to enhance their earning capacity from international markets.
» **Fifth**, appropriate policy to deploy protection mechanisms and tools such as tariff and non-tariff barriers in favour of local farmers produce against unfair trade practices in the international markets is recommended. This will safeguard the local developing sectors and entrepreneurs against the more developed competitors in international markets.
» **Sixth**, policy to facilitate easy access to micro-finance for women, the youth and small holders, who despite their potential, are perceived as high risk groups by conventional lending institutions is required. An appropriate policy to allow government to guarantee credit facilities offered to this group can be targeted.
» **Seventh**, policy to bridge the current rural infrastructure gap that is impeding trade and so facilitate economical access to local and regional markets e.g. prioritize funds/budget allocation for rural infrastructure development where farming is done is required as a matter of urgency. This will reduce current high costs such as transport, storage, in the agri-value chain, that are holding back investors.
» **Eighth**, policy to govern and regulate risk management instruments such as insurance will encourage investment from both small holders and SMEs as the market is assured of protection of investments in case of extreme events such as drought. It will also encourage service providers such as insurance and actuaries specialized to the agro-food sector to develop and participate as the business environment is organized and well regulated.
» **Ninth**, appropriate safety net policies to incentivize investment in technologies among the vulnerable groups like poor rural farmers who have low earnings but may have great entrepreneurial potential is recommended. These can include cash transfers, seed and tool distribution for start-up capital, mother-child health & nutrition & school feeding programmes to allow mothers more time to engage in agriculture.
» **Tenth**, appropriate policy to support research institutions on specific research agenda that supports this new paradigm is recommended. This support should be centred on strengthening delivery of the two key components of this paradigm, better context specific ecological agriculture techniques and identifying value chains and business models that will deliver greater value and reduce risks.
» **Eleventh**, policy to incentivize student investment and enrolment in agriculture programmes in institutions of higher learning and Educationalizing6 EbA driven agriculture. These can be in form of education grants and scholarships offered by governments to students who enrol in relevant agriculture, technology and business programmes. The government should also facilitate involvement of donors, the private sector and others of goodwill to support such an initiative. It is documented that *most educated people confront a mismatch*142 between their training and available opportunities. In South Africa, for instance, firms report 600,000 vacancies, while 800,000 young university graduates are unemployed143. In universities across Africa, while 26% students enrol in humanities, only 2% enrol in agriculture programmes144. If this sector is to be the engine for growth and investment, sufficient manpower has to be generated.
Institutions of higher learning, colleges and universities should put in place policies to periodically review their curricula and taught material to ensure alignment with advances in technology, facilitate innovation and ensure greater relevance to a diverse and evolving agricultural sector. Currently, focus should be on agribusiness & entrepreneurship as well as sustainable agriculture through EbA. In addition, African universities need to revise their educational system to a Duo-Qualification Certificate System which emphasises integration of theory and practices even for non-science course students with the aim of fore fronting Agriculture and agri-business.
6. Strategic framework: Toward operationalizing the new agricultural paradigm in Africa Shift embedded in EBA-driven approach
This paper has, through a review of relevant literature and presentation of empirical findings, challenged the current food insecurity scenario in Africa by laying a case for a paradigm shift from current conventional agricultural approaches that destroy ecosystems through unsustainable practices like deforestation, overgrazing, mono cropping on a lower level and a focus on substituting natural processes like soil formation, and biodiversity with artificial ones reliant on overuse of external inputs like energy intensive high emitting mechanized tillage, agrochemicals and overuse of fertilizer to increase food production at a higher level, without considering the sustainability of the ecosystems that underpin food production and without considering the food value chain as a continuum. This approach it has been argued, will not build an economically and environmentally sustainable food system in Africa in the long run especially under the changing climate.
As an alternative, the new paradigm of holistic agriculture, that considers productivity and efficiency of the entire food value chain by integrating ecological on farm productivity using ecosystem based adaptation techniques like conservation agriculture, agroforestry etc. with value addition enterprises supported by appropriate technologies and business models on and beyond the farm gate so as to build sustainable food systems for Africa has been proposed.
To this end, two components, one - upscaling this new paradigm both vertically in terms of influencing policy toward this approach and horizontally in terms of wide scale replication of successful application of this paradigm or its components and two – investment by various actors involved in Africa’s food security, in this new paradigm to facilitate adoption have been suggested as the way forward to safeguard Africa’s food security, adaptation and sustainability of its ecosystems under a changing climate while simultaneously creating income and job opportunities for millions in the continent.
Considering the substantial influence appropriate policies have on ensuring positive change, this document has recommended a number of policies that will contribute toward attracting investment at country level as well as regional and continental. In addition, a number of measures have been recommended to achieve scale.
The strategic framework addresses the operational requirements needed to facilitate successful implementation of these components - the policy measures’ to attract investment as well as measures to achieve scale. It is based on pillars that include appropriate institutions to embed policies in both public and private sector; resources, including financial support and human capacity to facilitate implementation of requisite strategies; knowledge management frameworks to guide development and implementation of strategies; and appropriate metrics to ensure effective monitoring and evaluation of implementation activities for both public and private sector.
Institutions are the foundation that embeds good policies in both the public and private sector, to ensure policies are grounded and sustainable over time. As discussed in this document, commitment by private, nongovernmental and public players is required to ensure continued investment in this paradigm shift. This commitment is concretized through institutions that transcend individuals. In the private sector, institutions that safeguard interests of businesses should be at the forefront in enforcing sector wide policies and mechanisms that will secure commitment of relevant players in this new paradigm. Similar institutions should lead in the civil society and NGO sector. In the public sector, line ministries should be in the forefront in ensuring that policies are embedded in program of works.
Budgetary allocation is another key operational parameter. Annual budgets by national governments should set aside funds specific to financing identified projects or programmes aimed at scaling up this new paradigm or attracting investment into this paradigm. Relevant training programs by line ministries should also be facilitated e.g. training of extension workers, or the small holder farmers or women and youth groups, to equip them with knowledge to implement this paradigm at their respective level.
There is also need for a concrete knowledge base, comprising traditional indigenous knowledge, scientific data, market information, and appropriate tools and mechanisms to facilitate its management and dissemination – publications, newsletters, websites – to users at various levels, so as to guide decision making at various levels, from policy level action, to private sector and small holder farm levels. The African Adaptation Knowledge Network provides a good model for operationalizing knowledge management for decision making. Such systems should be replicated and modified where necessary, to suit knowledge needs of the diverse actors in a country – private sector, public, civil society, community organizations, research and educational institutions.
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7 Impactful policies - Policy measures (in terms of just devising, approving and legalizing intentions alone) are most of the times inadequate unless attention is paid to addressing: a) clear intent through coherent legal/policy documents; b) balancing contesting interests; c) devising and applying necessary and most appropriate instruments; d) putting in place appropriate and context specific implementation arrangements. See for example: Ul Hassan, M M (2011). Analyzing governance reforms in irrigation: Central, South and West Asian experience. Irrig. and Drain 60(2):151-162.
Finally, as the maxim goes, what gets measured gets done. There is a need to develop appropriate matrices and benchmarks to ensure effective measurement of upscaling and investment efforts by various actors. Sector specific standards and metrics should be developed to enable the auditing of performance by the various players and identification of areas of improvement.
Putting EbA-driven agriculture in the vision of Africa’s Development is Africa’s own fierce urgency to leapfrog Africa into a world where, in the words of Nelson Mandela, there is work, bread, water and salt for all.
7. Annex
Annex 1 Data collection and sampling methodology
Data used to validate claims and recommendations made was collected using 2 approaches, literature reviews and questionnaires (for project cases studied).
Literature review
Three kinds of literature on EbA, food security, EbA for food security, agriculture value chains / value addition techniques and technologies mostly, African context sources were extensively reviewed.
1. Policy reports and documents
2. Practitioners reports and publications
3. Scientific literature
Empirical study
Considering that EbA and EbA for food security is being applied across the continent, empirical continental cases were also studied. Practitioners across Africa, representing each of the sub-Saharan Africa regions- Southern, Eastern, Central, West Africa – NGOs, CBOs, INGOs, CSOs, private enterprises, government entities who have a portfolio of EbA / EbA for food security projects, were mapped out and used as study items.
Considering that concepts of EbA are considered relatively new and EbA techniques despite their benefits remain largely invisible to mainstream agriculture across the continent, selection of informative cases could not be left to chance (probability sampling approach). Consequently, in considering its cost effectiveness and time saving advantages, in addition to the need to select informative cases, non-probabilistic or judgmental sampling methodology was used to select cases. Main criteria for selecting actors was those who have demonstrated longevity - have operated successfully in the continent for at least 5 years.
Sample size determination.
In ensuring a representative sample, informed assumptions and an appropriate formula were applied in generating an appropriate size of projects to be sampled. Considering that concepts of EbA are relatively new, a total of 400 active EbA projects across the continent was assumed (average of about 5-10 projects applied across the 54 countries). This is a small number (population) of projects, considering Africa’s population of about 900 million inhabitants. Hence the small population formula to determine sample size was applied.
From literature, the sample size determination formula for small populations is
\[ n = \frac{(N * z^2 * p*q)}{[E^2(N-1) + (z^2 * p*q)]} \]
Where
» \( n \) is the required sample size
» \( N \) is the population size
» \( p \) and \( q \) are the population proportions (are set to 0.5 each)
» \( z \) is the value that specifies the level of confidence you want in your confidence interval when you analyze your data. Typical levels of confidence for surveys are 95%, in which case \( z \) is set to 1.96.
» \( E \) sets the accuracy of the sample proportions. We assume an accuracy of + or - 3%, so \( E \) is set to 0.03.
Applying formula yielded the below:
\[
(400 * 1.96^2 * 0.5 * 0.5) / [0.03^2(400-1) + (1.96^2 * 0.5 * 0.5)] = 291.14
\]
This was rounded up to 300.
Consequently, a target sample of 300 projects was judgmentally selected
Data collection
Based on the target sample of 300 projects, 50 practitioners across Africa, representing each of the sub-Saharan Africa regions-Southern, Eastern, Central, West Africa – NGOs, CBOs, INGOs, CSOs, private enterprises, government entities who have a portfolio of at least 6 EbA / EbA for food security projects were targeted for study.
Questionnaire design
» Questionnaires were used to collect data from the practitioners. They aimed at ascertaining whether the projects were providing the benefits of the proposed new paradigm as gleaned from literature – climate resilience, ecosystem productivity enhancement, food security, value chain opportunities and income generation.
» Questionnaires also established the type of EbA technique being applied.
Data analysis
Analysis involved data reductions using tables and charts
Assumptions
A small number of EbA for food security projects being undertaken across Africa – an average of 5 – 10 for each of the 54 countries which meant about 400 such projects. This was informed by literature that EbA principles are considered relatively new in the continent.
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Chromothripsis-like patterns are recurring but heterogeneously distributed features in a survey of 22,347 cancer genome screens
Haoyang Cai1,2, Nitin Kumar1,2, Homayoun C Bagheri3, Christian von Mering1,2, Mark D Robinson1,2* and Michael Baudis1,2*
Abstract
Background: Chromothripsis is a recently discovered phenomenon of genomic rearrangement, possibly arising during a single genome-shattering event. This could provide an alternative paradigm in cancer development, replacing the gradual accumulation of genomic changes with a "one-off" catastrophic event. However, the term has been used with varying operational definitions, with the minimal consensus being a large number of locally clustered copy number aberrations. The mechanisms underlying these chromothripsis-like patterns (CTLP) and their specific impact on tumorigenesis are still poorly understood.
Results: Here, we identified CTLP in 918 cancer samples, from a dataset of more than 22,000 oncogenomic arrays covering 132 cancer types. Fragmentation hotspots were found to be located on chromosome 8, 11, 12 and 17. Among the various cancer types, soft-tissue tumors exhibited particularly high CTLP frequencies. Genomic context analysis revealed that CTLP rearrangements frequently occurred in genomes that additionally harbored multiple copy number aberrations (CNAs). An investigation into the affected chromosomal regions showed a large proportion of arm-level pulverization and telomere related events, which would be compatible to a number of underlying mechanisms. We also report evidence that these genomic events may be correlated with patient age, stage and survival rate.
Conclusions: Through a large-scale analysis of oncogenomic array data sets, this study characterized features associated with genomic aberrations patterns, compatible to the spectrum of "chromothripsis"-definitions as previously used. While quantifying clustered genomic copy number aberrations in cancer samples, our data indicates an underlying biological heterogeneity behind these chromothripsis-like patterns, beyond a well defined "chromothripsis" phenomenon.
Keywords: Chromothripsis, Human cancer, Array comparative genomic hybridization, SNP array
Background
One consistent hallmark of human cancer genomes are somatically acquired genomic rearrangements, which may result in complex patterns of regional copy number changes [1,2]. These alterations have the potential to interrupt or activate multiple genes, and consequently have been implicated in cancer development [3]. Analysis of genomic rearrangements is essential for understanding the biological mechanisms of oncogenesis and to determine rational points of pharmacological interference [4,5]. Some large-scale efforts have been undertaken to correlate genomic rearrangements to genome architecture as well as to the progression dynamics of cancer genomes [6,7]. At the moment, the stepwise development of cancer with the gradual accumulation of multiple genetic alterations is the most widely accepted model [8].
Recently, using state-of-the-art genome analysis techniques, a phenomenon termed "chromothripsis" was characterized in cancer genomes, defined by the occurrence of tens to hundreds of clustered genomic rearrangements, having arisen in a single catastrophic event [9]. In this model, contiguous chromosomal regions are fragmented...
into many pieces, via presently unknown mechanisms. These segments are then randomly fused together by the cell’s DNA repair machinery. It has been proposed that this “shattering” and aberrant repair of a multitude of DNA fragments could provide an alternative oncogenetic route [9], in contrast to the step-by-step paradigm of cancer development [8-10]. The initial study reported 24 chromothripsis cases, with some evidence of a high prevalence in bone tumors [9].
Besides human cancers, recent studies have also reported chromothripsis events in germline and non-human genomes [11-13]. However, due to the overall low incidence of this phenomenon, most studies were limited to relatively small numbers of observed events. For example, in a study screening 746 multiple myelomas by SNP arrays, only 10 cases with chromothripsis-like genome patterns were detected [14]. Larger sample numbers are required to gain further insights into features and mechanisms of these events in different cancers.
In contrast to a strict definition of chromothripsis events relying on sequencing based detection of specific genomic rearrangements [15], other studies [7,14,16] have described chromothripsis events based on genomic array analysis without support from whole genome sequencing data. Overall, the minimal consensus of array based studies is the detection of a large number of locally clustered CNA events. In Table 1, we provide an overview of studies which so far have reported instances of “chromothripsis” in human cancers [7,9,11,13,14,16-35].
Here, we present a statistical model for the discovery of clustered genomic aberration patterns, similar to those previously labeled as “chromothripsis” events, from
| Study | Chromothripsis-like cases | Sample size | Techniques | Cancer/sample types |
|-------|---------------------------|-------------|------------|---------------------|
| Stephens et al. [9] | 24 | 776 | Paired-end sequencing, SNP array | 55 cancer types |
| Kloosterman et al. [13] | 1 | 3 | Mate-pair sequencing | Germline, congenital defects |
| Le et al. [17] | 1 | 21 | aCGH | Chordoma |
| Magrangeas et al. [14] | 10 | 764 | SNP array | Multiple myeloma |
| Bass et al. [18] | 3 | 9 | Whole-genome sequencing | Colorectal adenocarcinoma |
| Kloosterman et al. [19] | 4 | 4 | Mate-pair sequencing, SNP array | Colorectal cancer |
| Zhang et al. [20] | 3 | 12 | Whole-genome sequencing | Acute lymphoblastic leukaemia |
| Kitada et al. [21] | 5 | 150 | aCGH | na |
| Poaty et al. [22] | 1 | 14 | aCGH | Gestational choriocarcinoma |
| Rausch et al. [23] | 52 | 605 | Whole-genome sequencing, SNP array | 7 cancer types |
| Jiang et al. [24] | 1 | 4 | Paired-end sequencing | Hepatocellular carcinoma |
| Molenaar et al. [25] | 16 | 87 | Paired-end sequencing, SNP array | Neuroblastoma |
| Chiang et al. [11] | 2 | 52 | Whole-genome sequencing, aCGH | Germline |
| Lapuk et al. [26] | 1 | 6 | Whole-genome/transcriptome sequencing, aCGH | Neuroendocrine prostate cancer |
| Berger et al. [27] | 2 | 25 | Whole-genome sequencing | Melanoma |
| Natrajan et al. [28] | 1 | 2 | Whole-genome sequencing | Breast cancer |
| Nik-Zainal et al. [29] | 3 | 21 | Whole-genome sequencing | Breast cancer |
| Kloosterman et al. [30] | 10 | 10 | Mate-pair sequencing, SNP array | Congenital disease |
| Wu et al. [31] | 3 | 3 | Paired-end sequencing, aCGH | Prostate cancer |
| Northcott et al. [16] | na | 1087 | SNP array, whole-genome sequencing | Medulloblastoma |
| Jones et al. [32] | 2 | 3 | Whole-genome sequencing | Medulloblastoma |
| Kroef et al. [33] | 1 | 61 | SNP array | Multiple myeloma |
| Govindan et al. [34] | 1 | 17 | Whole-genome sequencing | Non-small cell lung cancer |
| Kim et al. [7] | 124 | 8227 | aCGH, SNP array | 30 cancer types |
| Zehentner et al. [35] | 1 | 28 | aCGH | Plasma cell neoplasia |
| Current study | 918 | 18394 | aCGH, SNP array | 132 cancer types |
Data up to 21st December, 2012, na, not available, Family trio: father, mother, child, According to site and histology, Classified by ICD-O code.
genomic array data sets. For the scope of this article, we introduce the term “chromothripsis-like patterns” (CTLP) when discussing those events.
Applying our methodology to 22,347 genomic arrays from 402 GEO (Gene Expression Omnibus) derived experimental series [36], we were able to detect 918 chromothripsis-like cases, and to determine the frequency and genomic distribution of CTLP events in this dataset. Our collection of oncogenomic array data represents 132 cancer types as defined using the ICD-O 3 (International Classification of Diseases for Oncology) coding scheme, enabling us to estimate the incidence of CTLP in diverse tumor types. Among the CTLP cases, varying distributions of fragmented chromosomal regions as well as an abundance of large non-CTLP copy number aberrations (CNA) regions were found, and the genomic context of chromothripsis-like events was investigated. Finally, we evaluated clinical associations of CTLP cottoning samples, based on the clinical information at hand. Overall, this study characterized heterogeneous features of chromothripsis-like events through a large-scale analysis of oncogenomic array data sets and provides a better understanding of clustered genomic copy number patterns in cancer development.
Results
Detection of chromothripsis-like patterns from oncogenomic arrays
We collected 402 GEO series, encompassing 22,347 high quality genomic arrays of human cancer samples. A procedure was employed to detect CTLP from these arrays (Figure 1A). The annotated information of the arrays, including normalized probe intensity, segmentation data and quality evaluation, was obtained from our arrayMap database [37] (see Methods for array processing pipeline). After removing technical repeats (e.g. multiple platforms for one sample), a total of 18,394 cases representing 132 cancer types remained. The input data is summarized, at array and case-level, respectively, in Additional file 1: Table S1 and Additional file 2: Table S2. The segmentation data and array profiling can be accessed and visualized through the arrayMap website (http://www.arraymap.org).
According to previous studies, segmental copy number status changes and significant breakpoint clustering are two relevant features of chromothripsis [9,23]. For an automatic identification of CTLP, we developed a scan-statistic based algorithm [38]. We employed a maximum likelihood ratio score, which is commonly used to detect clusters of events in time and/or space and to determine their statistical significance [39] (see Methods). For each chromosome, the algorithm uses a series of sliding windows to identify the genomic region with the highest likelihood ratio as the CTLP candidate. In order to test the performance of the algorithm, 23 previously published chromothripsis cases with available raw array data were collected and used as a training set. This data contained 31 chromothriptic and 475 non-chromothriptic chromosomes that acted as positive and negative controls, respectively (Additional file 3: Table S3). Comparison of copy number status change times and likelihood ratios showed that chromothriptic chromosomes could reliably be distinguished from non-chromothriptic ones (Additional file 1: Figure S1). We generated a receiver operating characteristic (ROC) curve from the training set results, and selected cutoff values based on this curve (copy number status switch times ≥ 20 and log10 of likelihood ratio ≥ 8) (Figure 1B). Furthermore, the sliding window scan statistic accurately identified the genomic regions involved (Additional file 1: Figure S2). Applying this algorithm to the complete input data set, a total of 1,269 chromosomes from 918 cases passed our thresholds and were marked as CTLP events (Additional file 1: Figure S3, Additional file 4: Table S4).
Figure 1 Detection of chromothripsis-like patterns from genomic arrays. (A) Schematic description of the detection procedure. Raw array data of 402 GEO series are first collected and re-analyzed, then annotated and stored in arrayMap database. For high quality arrays, a scan-statistic based algorithm was employed to identify CTLP cases. (B) The ROC curve of the training set and selected thresholds. Two predictors were tested, copy number status change times and the likelihood ratio. Both predictors were integrated into the combined threshold.
Chromothripsis-like patterns across diverse tumor types
When evaluating the 1,269 CTLP events, we found a pronounced preference for some chromosomes; this preference showed only limited association with chromosome size (Figure 2A). CTLP occurred more frequently in chromosome 17 than in any other chromosome. This observation is in accordance with data reporting an association between chromothripsis and *TP53* mutations in Sonic-Hedgehog medulloblastoma and acute myeloid leukemia [23]. *TP53* is located in the p arm of chromosome 17, and is involved in cell cycle control, genome maintenance and apoptosis [40,41]. Our dataset showed *TP53* losses in 438 out of 918 (~48%) CTLP cases, compared to 3,274 out of 17,476 (~19%) cases in the non-CTLP group ($p < 2.2 \times 10^{-16}$; two-tailed Fisher’s exact test; Additional file 2: Table S2). 45 of the 438 *TP53* deletions were part of a CTLP, confirming *TP53* mutation as a recurring event with possible involvement in CTLP formation. Other chromosomes with relatively high incidences of CTLP included chromosomes 8, 11 and 12.
In our study, genomic projection of regional CTLP frequencies revealed their heterogeneous distribution in different cancer types (Figure 2B). The total length of fragmented genomic regions (CNA level and interspersed normal segments) accounted for 1%-14% of the corresponding genomes (Figure 2C). The large size of our input data set, resulting in high number of CTLP cases, permitted an investigation of the frequency and genomic distribution of these patterns in different cancer types. Our input samples represented 65 “diagnostic groups”, as defined by a combination of ICD-O morphology and topography codes. The majority of samples (18,238) came from 50 diagnostic groups, each represented by more than 25 arrays. We observed in total of 918 CTLP events across all 18,394 cases, representing an overall ~ 5% prevalence. The 17 diagnostic groups represented by at least 45 cases, and
**Figure 2** Frequency and CNA coverage length distribution of CTLP regions in the genome. (A) Red and blue bars indicate CTLP frequency in percent of all CTLP and chromosome size in megabases, respectively. (B) Local distribution of CTLP regions among diagnostic groups. Each row represents a cancer type and each column represents a chromosome. We use a black-to-yellow gradient for representing CTLP frequencies ranging from lowest to highest, normalized for each row. The numbers in brackets indicate the number of cases. Groups with at least 5 CTLP cases are shown. (C) Distribution of CTLP events as fractions of the affected genomes, represented as density plots for common cancer types. The fractions for each sample have been calculated as sum of genome bases chromosomes 1–22, divided by the genomic length of CTLP regions as identified through our scanning approach.
having frequencies higher than 4% (CTLP high) are listed in Table 2 (full list in Additional file 5: Table S5).
The initial study by Stephens *et al.* hypothesized that chromothripsis has a high incidence in bone tumors [9]. Notably, several soft tissue tumor types appeared in our “CTLP high” frequency set (6 out of 17), including the 3 types with the highest scores. Moreover, the high prevalence of CTLP in soft tissue tumors was reflected in the ICD-O specific frequencies (Additional file 6: Table S6). The genesis and/or effect of multiple localized chromosomal breakage-fusion events may be related to specific molecular mechanisms in those tumor types. Notably, gene fusions are well-documented recurring events in sarcomas [42], in contrast to most other solid tumors, and a local clustering of genomic re-arrangements had been previously reported for liposarcomas [43]. So far, more than 40 fusion genes have been recognized in sarcomas and treated as potential diagnostic and prognostic markers [42]. Possibly, the double-strand breaks and random fragment stitching events in chromothripsis-like events promote the generation of oncogenic fusion genes [9]. Further sequencing-based efforts will be needed to identify the true extent of fusion gene generation and to elucidate their functional impact in chromothripsis-like cases.
**Genomic context of chromothripsis-like events**
It has been hypothesized that chromothripsis is a one-off cellular crisis generating a malignant clone in a very short time [9,44]. However, in many of the CTLP samples in our study, highly fragmented chromosomal regions were embedded in larger CNA regions showing variations in patterns and overall extent (Figure 3A). To test whether CTLP generating events are associated with overall genomic instability, we examined the extent of all copy number imbalances detected in our dataset. Comparing the 918 CTLP positive arrays with the remainder of 17,476 CTLP negative arrays, we found that CTLP samples tended to have higher proportions of CNA coverage in their genomes ($p < 2.2 \times 10^{-16}$; Kolmogorov-Smirnov test) (Figure 3B,C). This indicated that chromothripsis-like events frequently co-occur with other types of copy number aberrations. Plausible and non-exclusive explanations could be that CTLP might frequently arise due to previously established errors in the maintenance of genomic stability, or that chromothriptic aberrations involving genomic maintenance genes may predispose to the acquisition of additional CNA. For those frequent cases exhibiting additional non-CTLP CNA events, their possible contribution to oncogenesis has to be considered when modeling the role of chromothripsis-like events in cancer development.
**Potential mechanisms for chromosome shattering**
While the mechanism(s) responsible for the generation of chromothripsis remain elusive, a number of studies have proposed hypotheses including ionizing radiation [9], DNA replication stress [45], breakage-fusion-bridge
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**Table 2 Frequency of chromothripsis-like patterns among cancer types**
| Cancer type | Oligo > 200 K | Oligo ≤ 200 K | BAC or cDNA | Total | Input cases | Frequency (95% confidence interval) |
|--------------------------------------------------|---------------|---------------|-------------|-------|-------------|-------------------------------------|
| Soft tissue tumors: lipoid | 49 | 12 | 0 | 61 | 114 | 53.5% (44%-62.8%) |
| Soft tissue tumors: fibroid tumors | 14 | 0 | 0 | 14 | 59 | 23.7% (14%-36.9%) |
| Soft tissue tumors: sarcomas, other | 9 | 0 | 2 | 11 | 48 | 22.9% (12.5%-37.7%) |
| Carcinomas: breast ca. | 247 | 99 | 58 | 404 | 3652 | 11.1% (10.1%-12.1%) |
| Carcinomas: esophagus ca. | 13 | 0 | 0 | 13 | 135 | 9.6% (5.4%-16.2%) |
| Carcinomas: bronchoalveolar, NSCLC | 78 | 29 | 2 | 109 | 1164 | 9.4% (7.8%-11.2%) |
| Soft tissue tumors: bone tumors | 7 | 3 | 0 | 10 | 123 | 8.1% (4.2%-14.8%) |
| Carcinomas: bronchoalveolar, SCLC | 3 | 3 | 0 | 6 | 90 | 6.7% (2.7%-14.5%) |
| Carcinomas: prostate adenoca. | 1 | 40 | 0 | 41 | 653 | 6.3% (4.6%-8.5%) |
| CNS: CNS PNET | 4 | 0 | 0 | 4 | 65 | 6.2% (2%-15.8%) |
| Carcinomas: melanocytic neoplasias | 31 | 1 | 6 | 38 | 621 | 6.1% (4.4%-8.4%) |
| Soft tissue tumors: myoepithelial | 3 | 0 | 2 | 5 | 85 | 5.9% (2.2%-13.8%) |
| Carcinomas: ovarian ca. | 31 | 5 | 1 | 37 | 801 | 4.6% (3.3%-6.4%) |
| Carcinomas: gastric ca. | 1 | 5 | 1 | 7 | 160 | 4.4% (1.9%-9.2%) |
| CNS: gliomas | 14 | 13 | 0 | 27 | 669 | 4% (2.7%-5.9%) |
| Soft tissue tumors: stromal tumors | 5 | 1 | 0 | 6 | 151 | 4% (1.6%-8.8%) |
| CNS: medulloblastomas | 13 | 4 | 0 | 17 | 430 | 4% (2.4%-6.4%) |
Only cancer types with input cases ≥ 45 and frequency ≥ 4% are shown.
cycles [9,23,46], premature chromosome compaction [47], failed apoptosis [48,49] and micronuclei formation [50]. Some of these proposed mechanisms are associated with features which could be addressed in our study.
In our dataset, although most (76%) CTLP cases presented single chromosome CTLP events, in approximately 24% CTLP affected at least 2 chromosomes (Figure 4A). For certain candidate mechanisms, e.g. micro-nucleus formation due to mitotic delay, this observation would imply more than one event, whereas the observation appears compatible with e.g. an aborted apoptosis process.
For relating to cytogenetic aberration mechanisms, an additional parameter explored by us was the extent of CTLP regions when normalized to their respective chromosomes. Affected regions were classified into the categories “arm-level” (≥ 90% arm length), “chromosome-level” (≥ 80% chromosome length) or “localized” (Figure 4B). Arm-level CTLP events were observed with a relatively high frequency (~19%). In the arm-level patterns, the CTLP rearrangements were concentrated in one chromosome arm, with the other arm of the same chromosome remaining normal or showing isolated CNA. Since arm-level events involve both peri-centromeric and telomeric regions, cytogenetic events involving these chromosomal structures present themselves as possible causative mechanisms.
Notably, one model that closely conforms to this pattern involves breakage-fusion-bridge cycles [9,23,46,47,51–54]. In general, such cycles start with telomere loss and end-to-end chromosome fusions. When the dicentric chromosomes are formed and pulled to opposite poles during anaphase, a double-strand DNA break acts as starting point for the next cycle. Chromosomal rearrangements
would gradually accumulate during the additional cycles, and should be concentrated in one chromosome arm, particularly near the affected telomere. In our dataset, up to 44% of all CTLP chromosomes involved telomere regions. We performed simulations to explore whether this telomere enrichment could be explained by chance. In brief, for each sample, we retained the location of CTLP region in the genome and shuffled the telomere position of each chromosome while keeping the length of each chromosome constant. In contrast to the actual observations, the simulation did not result in telomeric CTLP enrichment ($p < 0.0001$; 10,000 simulations; see Methods). CTLP generation through breakage-fusion-bridge cycles would be a viable candidate hypothesis compatible both with the statistically significant telomere enrichment and the high proportion of arm-level pulverization. However, for arm-level CTLP events centromere-related instability mechanisms should also be considered for future discussions.
**Clinical implications**
Based on clinical associations of “chromothripsis” patterns, it has been claimed that these events may correlate with a poor outcome in the context of the respective tumor type [14,25,55]. In our meta-analysis, we explored a general relation of CTLP with clinical parameters, across the wide range of cancer entities reflected in our input data set. Clinical data was collected from GEO and from the publications of the respective series (Additional file 2: Table S2 and Additional file 1: Table S7) and parameters available for at least 1,000 cases were considered. From our dataset, CTLP seemed to occur at a more advanced patient age as compared to non-CTLP samples (Figure 5A).
**Figure 4 The distribution of CTLP regions in terms of chromosome number and length.** (A) The number of chromosomes affected by CTLP per sample. The numbers outside and inside the brackets are number and percentage of CTLP samples respectively. (B) Length distribution of CTLP regions normalized to chromosome or chromosome arm lengths. For each chromosome, regions restricted on a single arm were normalized to arm lengths (red bars), otherwise were normalized to chromosome lengths (blue bars). More than 10% of all CTLP events involve whole chromosome arms.
**Figure 5 Clinical perspective on CTLP events.** (A) Distribution of CTLP percentage versus patient age. (B) Distribution of sample stage, grade and source between CTLP and input dataset or non-CTLP cases, $p$-values are derived from Chi-square test (stage and grade) or two tailed Fisher’s exact test (source). P, primary tumor; C, cell line. (C) Kaplan-Meier survival curves for CTLP versus non-CTLP cases. The $p$-value is based on log-rank test.
CTLP mainly occurred at stage II and III (70%), which was significantly different from the stage distribution of total samples (55.2%) ($p = 0.0149$; Chi-square test) (Figure 5B). No difference of grade distribution was observed in our dataset ($p = 0.425$; Chi-square test) where CTLP samples showed a predominance for grades 2 and 3, similar to the bulk of all samples (~80%). We also found that CTLP was overrepresented in cell lines compared to primary tumors ($p < 2.2 \times 10^{-16}$; two-tailed Fisher’s exact test).
For a subset of 1,203 patients, we were able to determine basic follow-up parameters (follow-up time and survival status). For 72 of these individuals, CTLP was detected in their tumor genomes. Notably, patients with CTLP survived a significantly shorter time than those without this phenomenon ($p = 0.0039$; log-rank test; Figure 5C). Note that this analysis was based on a sample of convenience averaged over cancers, stages and grades. If we break down this dataset by cancer type, the numbers are not large enough to provide statistical confidence (Additional file 1: Figure S4). While the cancer type independent association of CTLP patterns and poor outcome is intriguing, potential clinical effects of chromothripsis-like genome disruption should be evaluated in larger and clinically more homogeneous data sets.
**Sensitivity of array platforms for detection of chromothripsis-like patterns**
Presumed chromothripsis events have been reported from genomic datasets generated through different array and sequencing based techniques (see Table 1). We performed an analysis of the platform distribution of our CTLP samples, to estimate the detection bias among various genomic array platforms. As the resolution of a platform depends both on type and density of the probes on an array, we divided the platforms into 4 groups according to their probe numbers and techniques (BAC/P1, DNA/cDNA, oligonucleotide ≤ 200 K and oligonucleotide > 200 K). Although CTLP were detected by all types of genomic arrays, a higher fraction of CTLP samples was found using data from high resolution oligonucleotide arrays (Figure 6), possibly due to increased sensitivity related to higher probe density. Indeed, when performing platform simulations, the sensitivity of CTLP detection improved with increasing probe numbers (Additional file 1: Figures S5 and S6; see Methods). According to these simulations, array platforms consisting of more than 250 k probes should be preferred when screening for CTLP events. Since our analysis relied on a variety of array platforms, we can assume that the overall prevalence of CTLP in cancer is higher than our reported 5% of samples.
**Discussion**
The description of the “chromothripsis” phenomenon has initiated a vital discussion about clustered genomic aberration events and their role in cancer development [52,55,56]. While chromothripsis *senso stricto* has been characterized as a type of focally clustered genomic aberrations generated in a one time cellular event and being limited to a defined set of copy number states [15], other operational definitions have been employed based on clustered aberrations [7,16,23,45,55,57]. It seems likely that some of the previous discussions of “chromothripsis” referred to a number of underlying event types, all resulting in localized genome fragmentation and re-assembly events. For instance, DNA double strand break and end-joining-mediated repair may result in a restricted number of copy number levels, whereas aberrant replication based mechanisms will lead to a more diverse set of copy number aberrations [45,55]. Here, we introduce the term “chromothripsis-like patterns” (CTLP) when referring to clustered genomic events, to accommodate both common labelling and presumed biological variability of clustered genomic copy number aberrations.
At this time, due to the lack of sufficiently large number of cancer data sets from whole-genome sequencing analyses, a meta-analysis of “strict” chromothripsis cases is not feasible. We have followed a pragmatic approach to quantify the occurrence of CTLP from genomic array data sets. In our algorithm, we implemented the two most significant features shared by different operational chromothripsis definitions, namely copy number status changes and breakpoints clustering, which can be well measured by array based technologies. Previous studies provided various algorithms to detect “chromothripsis” events [9,15,58]. However, besides its application to an
extensive data set, the specific advantage of our method presented here is its ability to detect regions of shattering with limited influence from the varying sizes of affected chromosomes. Since the step length of our scanning window is 5 Mb, theoretically the detected CTLP regions are within an accuracy of ±5 Mb. Note that the performance of this algorithm may be influenced by poor quality arrays, especially those with highly scattered and unevenly distributed probe signal intensities.
In this study, we identified 918 CTLP-containing genome profiles, based on an analysis of copy number aberration patterns from 22,347 oncogenomic arrays and representing 132 cancer types. Despite the inherent limitations of such a meta-analysis approach, we were able to provide several new insights regarding the distribution of clustered genomic copy number aberrations and to produce a comprehensive estimate of CTLP incidence in a large range of cancer entities.
In our analysis, CTLP exhibited an uneven distribution along tumor genomes, with disease related local enrichment. These “CTLP dense” chromosomal regions may reveal associations between disease related cancer associated genes and molecular mechanisms behind genome shattering events. This potential correlation is exemplified by the prevalence of mutant *TP53* in “chromothriptic” Li-Fraumeni syndrome associated Sonic-Hedgehog medulloblastomas [23]. As the extent of CTLP related deletions of the *TP53* locus indicates, CTLP related gene dosage changes may predispose to double-hit effects on specific tumor suppressors. In contrast, we found regional enrichment for CTLP with pre-dominant copy number gains on chromosomes 8, 11 and 12. In the initial study, chromosome 8 shattering was found in a small cell lung cancer cell line [9]. This event contained the *MYC* oncogene, which had been shown to be amplified in 10-20% of small cell lung cancers [59]. Moreover, strong overexpression of *MYC* involved in a “chromothriptic” region was also detected in a neuroblastoma sample [25]. In a study of colorectal tumors, chromosomes 8 and 11 were involved in concurrent pulverization events with generation of fusion genes, involving e.g. *SAP33* and *ZFP91* [18]. In a study on hepatocellular carcinoma, *CCND1* amplification was embedded within a “chromothriptic” event on chromosome 11 [24]. Therefore, the overall uneven distribution of CTLP may point to specific driver mutations that contribute to CTLP generation, and/or to a class of cancer promoting mutations based on regional genome shattering events.
When comparing cancer types, we observed a high CTLP prevalence in a limited set of entities, particularly among soft tissue tumors. This finding supports and improves upon a previous prediction of particularly high “chromothripsis” rate in bone tumors [9]. Also, the uneven distribution of CTLP is a strong indicator for a disease related selection of specific genomic aberrations, supporting their involvement in the oncogenetic process.
In the initial study, the authors stated that chromothripsis could be a one-off cataclysmic event that generates multiple concurrent mutations and rearrangements [9]. However, the role of chromothripsis in terms of “shortcut” to cancer genome generation is still elusive. We note that additional and complex non-CTLP genome re-arrangements exist in the majority of CTLP samples. The number and uneven distribution of affected chromosomes in CTLP supports the biological heterogeneity of cancer samples with CTLP containing genome profiles. Furthermore, the normalized spatial distribution of shattered chromosomal regions, as well as the observed significant overlap between telomere and pulverized regions is supportive of breakage-fusion-bridge cycles as one of the mechanisms acting in a subset of samples. Further efforts are needed to investigate the temporal order of chromothripsis and non-chromothripsis events in complex samples, and to substantiate the existence of a dichotomy between “one-off” chromothripsis and other classes of localized genome shattering events, all resulting in clustered genomic copy number aberrations.
In our associated clinical data, CTLP were related to more advanced tumor stages and overall worse prognosis when compared to non-CTLP cases. One possible explanation is that the numerous concurrent genetic alterations induced by genome shattering events disturb a large number of genes and contribute to more aggressive tumor phenotypes. By themselves, these observations do not differentiate whether CTLP arise as early events promoting aggressive tumor behavior with fast growth rates and reduced response rates to therapeutic interventions; or whether this observation relates to underlying primary mutations predisposing to genomic instability, aggressive clinical behavior and CTLP as a resulting epiphenomenon. Interestingly, the high rate of *TP53* involvement by itself would support both possibilities for this gene, i.e. chromothripsis as result of *TP53* mutation as well as chromothriptic events with *TP53* locus involvement promoting an aggressive clinical behavior.
From Table 1 we may notice that the array based technologies are, in general, less sensitive than whole-genome sequencing data for calling chromothripsis-like events. This is partly due to the very limited ability of most array platforms to detect balanced genomic aberrations, such as inversions and translocation events. In the future, the accumulation of large-scale sequencing data should be able to provide further insights into localise genome shattering events.
**Conclusions**
CTLP represent a striking feature occurring in a limited set of cancer genomes, and can be detected from array
based copy number screening experiments, using bio-statistical methods. The observed clustered genomic copy number aberrations may reflect heterogenous biological phenomena beyond a single class of “chromothripsis” events, and probably vary in their specific impact on oncogenesis. Fragmentation hotspots derived from our large-scale data set could promote the detection of markers associated with genome shattering, or may be used for assigning disease related effects to CTLP-induced genomic events.
**Methods**
**Genome-wide microarrays and data preparation**
In this study, we screened 402 GEO series [36], encompassing 22,347 high quality genomic arrays (Additional file 2: Table S2). All selected arrays were human cancer samples hybridized onto genome-wide array platforms. The normalized probe intensities, segmented data and quality information were obtained from the arrayMap database, which is a publicly available reference database for copy number profiling data [37]. In brief, the annotated data was obtained by the following processing pipeline: for Affymetrix arrays, the aroma.affymetrix R package was employed to generate log2 scale probe level data [60]; for non-Affymetrix arrays, available probe intensity files were processed; CBS (Circular Binary Segmentation) algorithm [61] was performed to obtain segmented copy number data. The probe locations were mapped on the human reference genome (UCSC build hg18). In the case of technical repeats (e.g. one sample was hybridized on multiple platforms), only one of the arrays was considered for analysis (preferably with the highest resolution and/or best overall quality). The array profiling can be visualized through the arrayMap website.
**Scan-statistic based chromothripsis-like pattern detection algorithm**
To detect chromothripsis-like cases, we formulated an algorithm identifying clustering of copy number status changes in the genome. Several parameters were considered to define the alteration of copy number status:
i) The thresholds of log2 ratio for calling genomic gains and losses. These values were array specific and stored in arrayMap database. For each array, the thresholds were obtained from related publications or empirically assigned based on the log2 ratio distribution.
ii) The intensity distance between adjacent segments. Due to local correlation effects between probes or the existence of background noise, the segmentation profiles occasionally exhibit subtle striation patterns. This pattern is constituted with a large number of small segments, which is unlikely to be a biological phenomenon. To reduce artificial copy number status change, the distance of signal intensity between adjacent segments was used as a threshold, and defined here as the sum of the absolute values to call gains and losses. If the distance of two adjacent segments differed by less than this threshold, the copy number status change was not considered.
iii) Segment size. The resolution of a platform depends on the density of probes on the array. One of the platforms with the highest density in our dataset is Affymetrix SNP6, which contains 1.8 million polymorphic and non-polymorphic markers with the mean inter-marker distance of 1.7 kb. It provides a practical resolution of 10 to 20 kb. Therefore, in this study, segments smaller than 10 kb were removed.
In order to identify clustering of copy number status changes, a scan-statistic likelihood ratio based on the Poisson model was employed [39]. In our implementation, a fixed-size window was moved along the genome and for each window the likelihood ratio was computed from observed and expected copy number status change times. Let $G$ be the genome represented linearly, and $W$ is a window with fixed size. As the window $W$ moves over $G$, it defines a collection of zones $Z$, where $Z \subset G$. Let $n_W$ denotes the observed copy number status change times in window $W$, and $n_G$ the total number of observed status change in $G$. $\mu_W$ is the expected status change times in window $W$, and is calculated as $W/G \times n$. The likelihood function is expressed as
$$\lambda = \begin{cases}
\left( \frac{n_W}{\mu_W} \right)^{n_W} \left( \frac{n_G - n_W}{n_G - \mu_W} \right)^{n_G - n_W} & \text{if } \frac{n_W}{\mu_W} > \frac{n_G - n_W}{n_G - \mu_W} \\
1 & \text{otherwise}
\end{cases}$$
This function detects the zone that is most likely to be a cluster.
Due to lack of prior knowledge about the size of $W$, we predefined a series of window sizes from 30 Mb to 247 Mb (Additional file 1: Table S8), which were based on chromosome sizes. The scanning process was repeated for the series of window sizes for each sample. When $W$ moved over $G$, the step length was set to 5 Mb, and there was no overlap between different chromosomes in window $W$. In this way, for each genome, the collection of $Z$ contained 4,414 windows in various sizes. The window that maximized the likelihood ratio defined the most probable CTLP region. Thus it can detect both the location and the size of the cluster. When analyzing the complete input dataset, the window with the highest likelihood ratio was selected as a candidate of chromothripsis for each chromosome of the 22,347
arrays. The R script for detecting CTLP cases can be provided upon request.
**Analysis of fragment enrichment in telomere region**
Telomere positions were simulated to test the DNA fragment enrichment. For each case, the CTLP region was kept at its location in the genome. Locations of chromosome terminals were randomly selected while the length of each chromosome was kept. A genomic interval of 5 Mb from the chromosome terminal was considered as the telomere region. The simulation was performed 10,000 times.
**Simulation of platform resolution**
The 15 Affymetrix SNP6 CTLP chromosomes in the training set were used for simulation. For each genome, a certain number of probes were randomly chosen from the original probe set. These probes generally represented the profile that the same sample was hybridized on a platform with corresponding resolution. Then the CTLP pattern detection algorithm was applied on the simulated arrays, and the number of cases that passed the thresholds were recorded.
**Statistical testing**
The significance in the number of CTLP cases with *TP53* loss in comparison to those in non-CTLP cases was assessed using two-tailed Fisher’s exact test. We performed a Kolmogorov-Smirnov test to compare the distributions of copy number aberration proportions in the genome between CTLP and the other cases. The Chi-square test was used to assess the significance in the distribution of both patient stage and grade in CTLP and the whole input dataset. The associations between the number of cell lines in CTLP and non-CTLP cases were tested by two-tailed Fisher’s exact test. The difference in the survival curves between two subgroups was evaluated by the log-rank test.
**Additional files**
- **Additional file 1: Supplementary figures and tables. Figure S1.** Scatter plot of the training set. **Figure S2.** The positive training set and CTLP detection algorithm performances. **Figure S3.** Scatter plot of CTLP candidates. **Figure S4.** Kaplan-Meier survival curves for CTLP versus non-CTLP cases in specific cancer types. **Figure S5.** An example of the platform resolution based simulation using data from an Affymetrix SNP6 array (~1.8 million probes). **Figure S6.** CTLP detection sensitivity of simulated platform resolutions. **Table S1.** Overview of input dataset. **Table S7.** Demographic and clinicopathologic characteristics of input and CTLP samples. **Table S8.** Sizes of sliding windows for the scan-statistic based algorithm.
- **Additional file 2: Table S2.** Input dataset of high quality arrays with probe level raw data.
- **Additional file 3: Table S3.** Training set collected from published chromothripsis cases.
- **Additional file 4: Table S4.** Detected chromothripsis-like cases.
- **Additional file 5: Table S5.** Frequency of chromothripsis-like pattern among diagnostic groups.
- **Additional file 6: Table S6.** Frequency of chromothripsis-like pattern among ICD-O codes.
**Competing interests**
The authors declare that they have no competing interests.
**Authors’ contributions**
HC, MDR and MB conceived and designed the experiments. HC and NK analyzed the data. HC, NK, HCB, CvM, MDR and MB contributed reagents/materials/analysis tools. All authors contributed to draft the manuscript and approved the final manuscript.
**Acknowledgements**
The authors would like to thank Henrik Bengtsson and Ni Ai for useful discussions.
**Author details**
1Institute of Molecular Life Sciences, University of Zurich, Zurich, Switzerland. 2Swiss Institute of Bioinformatics, University of Zurich, Zurich, Switzerland. 3Institute of Evolutionary Biology and Environmental Studies, University of Zurich, Zurich, Switzerland.
Received: 9 August 2013 Accepted: 10 January 2014 Published: 29 January 2014
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July was a very busy month for the Painesville Railroad Museum. We had a booth at Painesville Party in the Park for three days, then the following weekend we had a booth at the Farm to Flea Market in Downtown Painesville and our Open House the same day. The following Thursday, we had our Bike Night at Quaker Steak and Lube. August has started off also being very busy with us hosting NMRA Div. 5 picnic and our depot picnic the following weekend. We will also be doing another Bike Night on August 17 and don’t forget our Railroad Memorabilia Show on August 27.
The Museum had a booth at this year’s Painesville Party in the Park. We had many visitors stop by the booth and they were invited to stop by the depot and see all of the restoration that has been done. Spanky was again a big hit as he posed with guest to have his picture taken on their arm.
Our web page has had several updates to it. One we have added a “Donation Button” so we can accept Credit Card Donation. This is through PayPal. We have also added a Wish List tab. This page has a list of items we are looking to have donated to us and a list of projects that we are in need of funding.
Farm to Flea Market
Downtown Painesville Organization held its first Farm to Flea market on July 22 in the parking lot of Family Services. The Museum had a booth and many of the visitors who stop by our booth also stop by the depot as the depot is only 3 blocks for it. We even found several Railroad lanterns, one from NYC and one from B&O.
July Open House
Our “Open House” (formerly known as “Railfanning Day”), Saturday, July 22nd set some new records….we had eighteen (18) trains come thru with one (1) inspection truck plus one of the trains had 209 cars with a runner up with 204 cars, please see below for details………
First some abbreviations…N = north track, S = south track, E = East bound, W = west bound, +138 = 2 engines+138 cars
8:12am -N-W-2+138-CSX-mix freight
8:23am -N-E-3+161-BNSF-mix freight
8:43am -S-E-2+106-CSX-Autoracks
9:00am -S-E-2+137-CSX-stack containers
9:15am -S-E-1+0-CSX inspection truck
9:30am -S-E-2+192-CSX-UPS containers
10:00am -S-E-2+134-CSX-stack containers
10:58am -N-E-2+137-CSX-stack containers 1
1:13am -S-E-2+102-CP- tanks
12:14pm -N-W-3+169-UP+UP+CSX-tanks+mix freight
12:23pm -N-W-2+118-CSX-Autoracks
1:10pm -N-W-2+37-CSX-mix freight (local)
1:47pm -S-E-2+108-CSX-stacks 2:23pm -N-W-2+?-CSX-tanks
2:45pm -S-E-2+81-CN-mix freight
3:43pm -S-E-2+209-CSX-stacks
3:52pm -N-W-3+104-CP+UP+CP-stacks
5:18pm -S-W-4+204-CSX-UPS containers
5:30pm -S-W-3+122-CSX-stacks
Passing of a friend and member
It is with heavy heart that I have to report we lost one of our members, John Murphy. John donated his father’s (Edward Murphy) writing desk, which his father used in the B&O Railroad Station in Painesville. The desk is 1931 Vintage from Painesville Furniture.
Mr. Murphy was born February 24, 1942 in Painesville to Edward James and Lillian Eleanor (Burton) Murphy. He passed away June 28, 2017 at Tri-Point Medical Center in Concord Township.
John was in the Army Reserves. He owned and operated Murphy Asphalt and Paving Co. for many years. He loved boating and was a member of the Western Reserve Yacht Club and The Painesville Elks Lodge 549. He is survived by his sisters, Mary Elizabeth Werner of Painesville Twp., Margaret Haught of Houston, Texas; and many nieces and nephews.
John was preceded in death by his parents; and brother, Edward J. Murphy II.
Bike Night at Quaker Stake and Lube.
We had our first Bike Night at Quaker Stake and Lube on July 27, 2017. Because of Mother Nature wishing to have rain on every Thursday this summer, this was the first bike night of the year!
The depot host the Beer Tent and part of the beer sales is donated to the Depot. A fun night with a live band. The next Bike night is August 17, 2017.
Wish List
Riding mower – large deck – 48” to 60”
Window glass-Lexan
Pop corn maker – large movie style
Fence posts, top-bottom rails-fencing (approximate 300 feet)
Flat screen TV
Radio
PA-speakers – indoor & outdoor
Table covers – 6’ & 8’ x 30” tables – cloth-vinyl
Cleaning supplies – liquid soap, Windex, paper towels, etc.
Engines for static displays – steam-diesel-rail speeder
Freight cars for static display – box-passenger
Railroad prototype artifacts – signs-signals-lanterns etc.
Stainless steel appliances for a working kitchen
Furnace – gas
Water cooler
Ice machine
Lights – inside West end
Weed killer
Electric plugs & wire
Model Train Collections
Cash donations towards future projects:
Decking materials for Railfanning deck
Wood for Caboose interior
Wood for picnic tables-benches
Paint-stain for overhangs, picnic tables-benches
Roof maintenance-repair
Dock-ramp maintenance-repair
Floor restoration
Storage building
Restoration Crew continues its work!
One of the many projects that the Restoration Crew has worked on this summer is our fence. It has been painted and several new posts and top rails have been added. Great Job Dale and Crew.
Upcoming Dates and Events
Quaker Steak-Bike Night August 17
Quaker Steak & Lube
7834 Reynolds Rd. (Rt. 306) at Tyler Blvd. (flyer on page 6)
Mentor, Ohio 44060 (6:30 - 9:30 pm)
BOD Meeting August 22
The Painesville Railroad Museum
475 Railroad Street
Painesville, Ohio 44077 (6:00 pm )
RR Memorabilia Show August 27
The Painesville Railroad Museum
475 Railroad Street (flyer on page 7)
Painesville, Ohio 44077
(10 am –5 pm)
Corn Roast September 9
The Painesville Railroad Museum
475 Railroad Street (flyer on page 8)
Painesville, Ohio 44077 (10 am –5 pm)
Membership Meeting September 12
The Painesville Railroad Museum
475 Railroad Street
Painesville, Ohio 44077 (6:00 pm )
BOD Meeting September 26
The Painesville Railroad Museum
475 Railroad Street
Painesville, Ohio 44077 (6:00 pm )
Oktoberfest (Noon –10 pm) October 14
The Painesville Railroad Museum
Handmade Market (10 am –5 pm) November 25
The Painesville Railroad Museum
Depot Dispatch
The Depot Dispatch is an official publication of The Western Reserve Railroad Association, Painesville Railroad Museum, Painesville, Ohio. It is published approximately once a month and is posted on the Depot Website free of charge. An electronic version of the newsletter will be emailed to members and a hard copy will be available at the Depot. Information regarding The Depot Dispatch, Depot activities and events may be obtained by writing to 3257 Center Road, Perry, Ohio 44081 or sending an e-mail to firstname.lastname@example.org. The Depot Dispatch and Depot activities and special events are funded by open houses, contributions, donations and annual fundraisers. All comments and opinions are welcome. Those views expressed in The Depot Dispatch do not necessarily reflect the policies or opinions of the Western Reserve Railroad Association.
THE WESTERN RESERVE RAILROAD ASSOCIATION
DBA
PAINESVILLE RAILROAD MUSEUM
www.painesvillerailroadmuseum.org
501(c)3 Non-profit
President: Jim Wendorf 11381 Labrador Lane Concord, Ohio 44077 (440) 357-8890 email@example.com
Vice-President: Tom Pescha 3942 E. 364 Street Willoughby, Ohio 44094 (216) 470-5780 firstname.lastname@example.org
Secretary: Leonard Kessler 3257 Center Rd. Perry, Ohio 44081 (440) 417-6746 email@example.com
Treasurer: Dale Porter 6442 Lockwood Dr. Mentor, Ohio 44060 (440) 477-0133 firstname.lastname@example.org
Bike Night
Thursday, August 17, 2017
Quaker Steak & Lube
7834 Reynolds Road (Rt 306) at Tyler Blvd.
Mentor, Ohio 44060
6:30 to 9:30 pm
QUAKER STEAK & LUBE
BEST WINGS USA
50-30/20 Raffle
Beer Tent being hosted by:
Painesville Railroad Museum
475 Railroad Street, Painesville, Ohio 44077
All proceeds to help continuing restoration of depot.
The Painesville Railroad Museum
475 Railroad Street, Painesville, Ohio 44077
A 501c3 Non-Profit
www.painesvillerailroadmuseum.org
RAILROAD MEMORABILIA SHOW
Come and see artifacts of Railroads Glory Days
Sunday, August 27, 2017 10 am to 5 pm
Painesville Railroad Museum
475 Railroad Street
Painesville, Ohio 44077
216-470-5780
Admission $5.00 each, Family $7.00
See railroad signals, plate setting ware (Dinner Ware) that were used in the dining cars, railroad lanterns, paper work from different railroads, conductor hats, engineer hats, and much more from railroads of the past. Some items will be for display only by private collectors and some items will be available for purchase.
Vendors - If you wish to only display your item (not sell them) then your table is Free. If you wish to sell items, then your table cost is $25.00 per table.
Food and Drinks available.
www.painesvillerrailroadmuseum.org
email@example.com 501(c)3 non-profit
Aug. 2017 Railroad Memorabilia Show
PLEASE PRINT
Name: ____________________________
Phone: (______)_____________________
Address: ____________________________
City: __________________ State: ______ Zip: _________
Email: ______________________________
Permit# ________ Amt. Enclosed $_________ No of Tables _________
6' X 30" Tables
Display only - Tables are free
Selling items - Table cost $25.00 each
Load in Sat. 12:00 pm to 4:00 pm
Sun. 8 a.m. to 9:45 a.m.
Make Checks Payable To:
WRRA
Mail To:
Tom Pescha
3942 East 364th Street
Willoughby, Ohio 44094
Phone (216) 470-5780
www.painesvillerrailroadmuseum.org
Please send table request by Aug. 18, 2017
CORN FESTIVAL
OPEN HOUSE
PAINESVILLE RAILROAD MUSEUM
475 Railroad Street, Painesville, OH 44077
Saturday, September 9, 2017
10:00 am to 5:00 pm
Corn on the Cob - Kettle Corn - Corn Dogs
Hamburgers - Hot Dogs - Hobo Beans
Visit this Historical Train Depot
And
Spend a day RailFanning
Be sure to bring your Camera and a CHAIR!
Food and Drinks available
216-470-5780
firstname.lastname@example.org
www.painesvillerrailroadmuseum.org
A 501c3 Non-profit
Oktoberfest
Saturday, October 14, 2017
Noon to 10:00 pm
at
The Painesville Railroad Museum
Painesville Railroad Depot
475 Railroad Street, Painesville, OH 44077
Enjoy Authentic German Food:
German Potato Salad, Sauerkraut, and Bratwurst
Hot Dogs, and Hamburgers also available.
Admission: $5.00 adult, $3.00 child (3 to 12 year old)
$12.00 Family (max 2 adults, 3 children)
Learn the History of Oktoberfest
See authentic German Dancing
Live Music
Visit this Historical Train Depot
Direction to Painesville Depot
I-90 (exit 200) to Rt. 44
North on Rt. 44 to Rt. 2
East on Rt. 2 (1.5 miles) to OH 535 / OH 283 (exit 223)
South on OH 283 for 200 feet, left turn (east onto Chester St.)
East on Chester St (0.7 miles) to North State Street
South on North State Street (under RR Bridge) to Railroad Street
East on Railroad Street to Depot.
Be sure to bring your Camera and take pictures of trains going by the station!
Hosted by
Downtown Painesville Organization
And
Painesville Railroad Museum.
216-470-5780 email@example.com www.painesvillerrailroadmuseum.org
A 501(c)3 Non-Profit
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As shown in each chapter of this report, Oregon’s energy sector is in transition. This creates challenges and opportunities for policy makers, regulators, energy leaders, and ultimately every Oregonian.
The state’s early investment in energy efficiency, clean energy resources, and conservation has positioned Oregon well to begin tackling today’s challenges, which are fueled by a growing demand from consumers for cleaner energy, forecasted population growth, and emerging technologies.
The Oregon Department of Energy’s first comprehensive look at energy policies, trends, and forecasting came soon after the agency’s creation in 1975.
This early version of a biennial energy plan was aptly titled *Transition* – accurately describing an energy sector in flux after a fuel crisis. Fast forward 43 years, and the agency has developed a new, comprehensive Biennial Energy Report. Our new report is modernized, yet still captures some of the same drivers and challenges the energy sector experienced in the 1970s – plus new ones, like resilience and climate change.
As shown in each chapter of this report, Oregon is still in transition. This creates challenges and opportunities for policy makers, regulators, energy leaders, and ultimately every Oregonian. The state’s early investment in energy efficiency, clean energy resources, and conservation has positioned Oregon well to begin tackling today’s challenges, which are fueled by a growing demand from consumers for cleaner energy, forecasted population growth, and emerging technologies.
The Biennial Energy Report frames Oregon’s existing policies and programs in the areas of climate change, renewable energy, transportation, energy resilience, energy efficiency, and protecting residential consumers. A main theme running throughout the report is what it means for Oregon to transition to a low-carbon economy. The October 2018 Intergovernmental Panel on Climate Change (IPCC) report underscored the importance of putting Oregon on a path to decarbonization. The IPCC reports on the effects of global warming of 1.5 degrees Celsius, and stresses the need for action to avoid the most serious economic, environmental, and social damages from climate change. Achieving Oregon’s energy and climate goals – while protecting consumers – will take collaboration among state agencies, policy makers, state and local governments, and private sector business and industry leaders from across the state.
The report acknowledges many areas where the state will need to increase efforts to reduce or mitigate greenhouse gas emissions. One area is the transportation sector, which is responsible for the greatest share of greenhouse gas emissions in Oregon. Our efforts to make vehicles and transportation fuels cleaner are being overshadowed by an increase in both population and total vehicle miles traveled. With the adoption of the Statewide Transportation Strategy in 2018, Oregon has a long-term vision for reducing transportation-related GHG emissions, and has identified several specific strategies to achieve that vision. But time is of the essence. One key approach addressed in this report is the electrification of light-duty vehicles – passenger cars, pickup trucks, and SUVs. In addition to reducing GHG emissions, electric vehicles can increase Oregon’s energy independence, reduce costs for consumers, and leverage our increasingly clean and renewable electric grid as their fuel source.
The report examines current and emerging technologies in Oregon and across the West, which are helping modernize the state’s energy systems and take us down the path of decarbonization. More recent technologies and additional uses for these technologies are coming – such as wave energy, renewable
natural gas, solar energy, energy storage, power-to-gas, and electric vehicles that have the ability to store excess energy and send it back to our electric grid when needed. These and other advancements yet unimagined will speed our transition to a low carbon economy and reduce the cost of the transition.
Finally, and perhaps most importantly, this report recognizes that all Oregonians can and should benefit from a clean energy future. A key focus of the Biennial Energy Report is to inform local, state, regional, and federal energy and climate policy development. As the energy sector works to decarbonize and modernize, we must understand how all consumers – especially those often left behind, including communities of color, low-income families, older adults, and others – can benefit from the transition to a low-carbon economy.
**Recommendations**
The recommendations in this report are a reflection of the work conducted by the Oregon Department of Energy, and informed by our many stakeholders, including our state and regional partners. The report organizes our recommendations around four key themes: gaps in data, addressing equity and energy burden, planning for the future, and assessing the need for state engagement and investment.
**Data Gaps**
In drafting this report, ODOE identified a number of areas where additional data would better inform the public and lawmakers. As the central repository within state government for the collection of data on energy resources, we will work to fill these gaps, starting by more closely collaborating with state and regional entities. Better information will make for better planning, enable more thorough and accurate economic analyses, and ensure we can achieve more equitable outcomes.
**Recommendations**
*Increase collaboration among state agencies to strengthen data-gathering capabilities and provide additional comprehensive state-specific information.* Many parts of this report incorporate national and regional datasets that provide a foundation for understanding our energy landscape. However, some of these datasets can only provide general estimates for the state or are missing data specific to Oregon.
*Share and collaborate on data analysis to leverage complementary tasks and datasets.* Within the state, there are a variety of organizations and agencies that collect, analyze, and report energy and energy-related information. These entities often have distinct objectives, expressed through unique statutory authorizations and organizational mandates. Partnering will improve collection and analysis and create efficiencies, while ensuring statutory requirements are met.
*Build capacity and understanding of complex and varied data systems that exist in the state,* with the goal of
identifying gaps for data collection and areas where additional analysis will benefit the energy sector.
Foster new relationships between public, private, government, and community organizations to explore opportunities for data sharing and advanced analytics, and use of this information to better inform stakeholders and decision-making bodies.
Addressing Equity and Energy Burden
As the energy sector in Oregon continues to transition – due to legislative and executive branch actions, regulations, maturing markets and changes in consumer preferences, new technology, international pressures, and climate change – the state must do more to address issues of equity and energy burden. The same communities that are energy burdened are also on the frontlines of climate change. Energy costs affect people differently based on income levels, demographics, and geographic locations. Energy policies should take into account their effects on all Oregonians, both in terms of their burdens and benefits.
Recommendations
Improve data collection and analysis. Given the uncertainties surrounding what the rapidly transitioning energy sector may mean for consumers, it is important that equity considerations are understood more broadly. The state would benefit from a better understanding of the benefits to and burdens of electricity, heating, and transportation options and programs on all Oregon consumers. Demographic, income, public health, energy impacts, and energy cost data will better inform program and policies to achieve more equitable outcomes.
Design policies with all Oregonians in mind. In designing incentives for electric vehicles and programs for community solar, lawmakers acknowledged the additional difficulties faced by low-income consumers who want to benefit from clean energy incentives or programs. The legislature provided additional assistance to enable better access to these clean energy technologies (such as an additional rebate for purchasing or leasing an electric vehicle). As other polices are pursued, similar considerations may be warranted. More granular data and analysis on the energy burden and transportation options for low-income and rural Oregonians will help inform these considerations.
Improve engagement with Oregon communities. Any energy-related planning done at the state level should involve intentional engagement with all potentially affected communities, as well as a comprehensive analysis of potential impacts. Including these communities in the process early can lead to energy-related decisions and outcomes with a more equitable distribution of benefits and burdens.
“Early, continuous, and meaningful public participation for all potentially affected communities will result in a more inclusive consideration of a broader range of perspectives, leading to more equitable and sustainable decision-making and reducing the likelihood of disproportionate impacts.”
– State of Oregon Environmental Justice Task Force Handbook¹
Planning for the Future
This report identifies many paths and key components of strategies designed to accelerate Oregon’s move toward decarbonizing the economy, reducing GHG emissions in the transportation sector, increasing renewable energy resources and energy efficiency, protecting Oregon consumers, and improving the state’s energy resilience. It builds on reports and recommendations from other agencies, the private sector, academia, and advocacy organizations that present options to address these challenges. Recognizing that the state has limited resources, Oregon should work collaboratively with partners, including the private sector, and local and regional entities to identify the optimal combination of these options to achieve state goals in the most cost-effective way. Due to the level of urgency facing the state on many of these challenges, this planning must be done concurrently with and build upon existing policies and programs.
Recommendations
Analyze and evaluate the cost-effectiveness of strategies to inform energy planners and policymakers on how to leverage and combine strategies to create the most cost-effective pathway. The renewable energy chapter of this report highlights a number of options to integrate increasingly higher percentages of variable renewable electricity into the grid, including flexible supply, flexible demand, energy storage, distributed energy resources, and participation in larger electricity markets. An analysis should look at how to ensure the value of integration benefits are being appropriately compensated with the right price signals. It could also inventory and assess the cost-effectiveness of existing programs and policies.
Continue participation in the ongoing dialogue around the creation of a regional independent system operator (ISO) in which Oregon’s electric utilities could participate. Planning should consider how Oregon links with other jurisdictions in order to leverage cooperation, but do so in a way that protects Oregon’s interests. For example, as Oregon discusses creating a cap-and-trade program, policymakers are considering linkage with California, Quebec, and other jurisdictions that have programs in place.
REGIONAL ELECTRICITY MARKETS
Oregon Governor Kate Brown, responding to an opportunity for stakeholder feedback to California in 2016 on the topic of expanding the CAISO, offered her support for a well-designed regional ISO that “could deliver substantial benefits to [Oregonians] . . . through a more integrated electricity grid.”\(^2\) Brown also stated “It is important that the governance of the regional system operator be independent and represent all the states whose jurisdictions are impacted ... [because] only with independent representation can we be guaranteed that the benefits will be adequately distributed amongst the participating states.”\(^2\)
A regional ISO that represents the interests of all participating states in its operation of the transmission system and of wholesale power markets could significantly lower the cost of integrating more renewable energy across the western grid. Specifically, a regional ISO could help to do this by: 1) allowing for a wider market for the current oversupply of renewable energy at times; 2) lowering prices for renewable energy; 3) reducing the need for expensive storage solutions; and 4) using a wider geographic spread of renewable generation to reduce resource adequacy concerns. There are also costs and risks associated with a regional ISO, and Oregon should continue to work with California and other western states, as well as stakeholders in Oregon, in determining the costs, benefits, and appropriate next steps.
Plan ahead to adapt and prepare communities and infrastructure for the effects of climate change and natural disasters. Even if the state is successful in our decarbonization efforts, some impacts of climate change and natural disasters are inevitable. Undertaking a comprehensive vulnerability and risk assessment of the state’s energy infrastructure is a first step in improving the resilience of our energy systems. The assessment should address two core components: an identification of critical energy infrastructure assets, inclusive of the electric, natural gas, and liquid fuels sectors; and a detailed assessment of the vulnerabilities and risks to that infrastructure from all hazards, including a Cascadia Subduction Zone earthquake, climate change, and cyber or physical attacks.
Look at opportunities to encourage and amplify efforts of local, regional, and Tribal governments to develop their own action plans that fit within and inform a statewide strategy. It should also take into account regional and demographic differences in benefits, as well as burdens of actions. For example, the charging infrastructure necessary to support electric vehicle adoption in Oregon’s cities will look different from and involve different policy considerations than in rural Oregon.
COMMUNITY ENERGY RESILIENCE
As part of our adaptation efforts, the state should create a community energy resilience vision. A collaborative process to define a vision and implement key actions could bring together and engage a diverse group of stakeholders to:
- Raise awareness of location-specific risks to energy infrastructure, particularly in communities with limited capacity to prepare for or respond to threats.
- Identify critical interdependencies within specific communities between the energy sector and public infrastructure.
- Provide technical assistance, in coordination with local energy providers, to help identify and evaluate community energy resilience and climate adaptation options (e.g., relocating or hardening infrastructure, or deploying distributed energy resources at critical public buildings) for energy systems over which they have influence or control.
- Develop a framework to help communities evaluate the costs and benefits of investments in community energy resilience or climate adaptation solutions, including the potential value of benefits from these investments during routine conditions.
- Through engagement with stakeholders, develop a community energy resilience vision for the state that include specific goals designed to improve the resilience of energy systems within individual counties, municipalities, or communities.
- Develop a framework to empower counties, municipalities, or communities to prioritize community energy resilience and climate adaptation solutions.
- Identify needs of counties, municipalities, or communities for additional technical or financial assistance. Evaluate whether new legislative or regulatory mechanisms may be necessary to fund investments in community energy resilience and climate adaptation solutions.
Improve collaboration among state agencies. As described in this report, numerous state agencies are working on energy issues. Many are already collaborating to implement Governor Kate Brown’s recent executive orders on electric vehicles and energy efficient buildings. Each agency brings unique mission statements, areas of expertise, constituencies, statutory authority, and data to the table. Collaboration can leverage agency resources and strengths, and reduce duplication of efforts to help the state make progress on our goals in the most efficient manner. For example, in order to address transportation greenhouse gas emissions, ODOT has put forward the Statewide Transportation Strategy, drawing on the expertise of DEQ, DLCD, and ODOE. These four agencies should continue coordinating their efforts to advance and build upon the strategies highlighted in the STS.
Assessing the Need for State Engagement and Investment
State incentives have played an important role in Oregon’s GHG reduction, economic development, energy efficiency, and clean energy progress. The costs of clean energy technologies – from batteries to solar panels to electric vehicles – have come down dramatically in recent years. In light of these market forces, it is important for the state to look at the effect this has on our policies and programs and on the outcomes we hope to achieve. Once the desired outcomes and the policy pathways for achieving them are determined, the state should decide the best ways to assist consumers and businesses in achieving those outcomes. This support could come in the form of financial incentives, mandates, voluntary programs, technical assistance, and reductions of soft costs by evaluating and streamlining market barriers.
Recommendations
Support local activities. Numerous local, regional, and Tribal efforts are underway across the state to create and implement climate change, clean energy, and energy resilience plans. The state should assess the role those activities play in achieving state goals and determine how best to support those efforts – which could include creating complimentary policies or programs, offering technical assistance, or providing financial incentives.
Assess and identify market failures that warrant policy intervention. Achieving Oregon’s climate and energy goals will involve advancements in the areas of renewable energy resources, energy efficiency, and sustainable transportation. Some progress in these areas will continue to be driven by market forces, but state support in the form of incentives might still be necessary. An assessment that identifies the market failures that warrant policy intervention would help the state determine where to put our limited resources. This assessment should include how specific incentives would achieve specific outcomes, such as GHG reduction, energy independence, economic development, and equity, and should acknowledge that the desired outcome must drive the design of the incentive. For example, an incentive designed to achieve the greatest renewable energy capacity may look different from one designed to promote individual energy independence and resilience.
Electric Vehicle Adoption
The state currently offers incentives for the purchase of electric vehicles to offset the high upfront costs that can be a barrier to EV adoption. The state should evaluate whether additional financial support is necessary to ensure sufficient options for all EV charging platforms to meet the needs of EV drivers, to ensure accessibility in urban environments where people may not have access to at-home or workplace charging, and in rural environments where people need access to charging stations to be able to travel longer distances more frequently.
Renewable Natural Gas
In September, ODOE released an inventory of all potential sources of biogas and renewable natural gas (RNG) available in Oregon. The report found that the gross technical potential for RNG production from anaerobic digestion and thermal gasification technology combined could replace up to 20 percent of Oregon’s total yearly use of natural gas. Working with a stakeholder advisory committee, ODOE also identified financial, technical, market, policy, and regulatory barriers to developing and using biogas and RNG as an energy source that can help Oregon reduce greenhouse gas emissions and improve air quality. One of the recommendations included in the report was to explore financial incentives to help drive the nascent industry forward.
Consider whether to explore methods to assign a value to benefits not traditionally incorporated in cost-effectiveness models. Policymakers, utilities, and consumers are increasingly recognizing the multiple benefits associated with reducing GHG emissions, increasing energy efficiency, investing in renewable energy, supporting sustainable transportation, and focusing on equity and resilience. Cleaner air, improved health outcomes, less reliance on imported energy, reduced energy burden, livability, and safer communities, for example, are benefits of many of the policies and strategies explored in this report. But it can sometimes be hard to quantify the value of these outcomes. Incorporating these benefits when making energy decisions could result in different outcomes. For example, putting a price on carbon can make carbon-free resources such as hydropower and wind even more competitive with fossil fuels. It could also add a new value consideration for energy efficiency that would make it more cost-effective and enable the expansion of energy efficiency efforts.
It is our hope that the information in this report, including recommendations regarding data gaps, equity, planning, and state support, will provide Oregon policymakers and the public with the tools they need to work with the Oregon Department of Energy to lead our state to a safe, clean, and sustainable energy future.
1. State of Oregon Environmental Justice Handbook. January 2016. https://www.oregon.gov/gov/policy/environment/environmental_justice/Documents/2016%20Oregon%20EJTF%20Handbook%20Final.pdf
2. Brown, Kate. “Governor Kate Brown Letter 7-11-16 Regarding Support of RSO.” California Energy Commission, Docket 16-RGO-01. July 11, 2016. https://efiling.energy.ca.gov/GetDocument.aspx?tn=212260
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Emerging CUAC Colleges...
The Church’s commitment to education continues to be the catalyst for the formation of new Anglican schools, colleges, and universities, and this is particularly evident in the global South. A good example of this would be the Igreja do Rio Branco Anglican Institute and the Anglican College of Erechim, founded through the Igreja Episcopal Anglicana do Brasil. The initial school was founded in 1928 through the vision of The Rev. Alberto Blank, who was concerned about education at the time of territorial colonization in Brazil. These elementary and middle schools evolved into some of the best Anglican schools in Brazil.
In 1965 an initiative was made to add high school and postgraduate education, which resulted in the Anglican College of Erechim. The College offers courses in Administration, Industrial Design, Information Systems Technology and Pedagogy. Its curriculum is designed so that students must put their theoretical knowledge into practice during their studies. Both learning institutions apply Christian principles to their educational philosophy. Most tuition payments are met by students and family, but discounted tuition is available for students of less financial means. The Anglican College of Erechim has financing arrangements with FIES (financing through banks) and Pro-Uni (a system of scholarships for the underprivileged). All courses are authorized and recognized by the Ministry of Education of Brazil.
Africa is another location of new institutions. Although envisaged by the Anglican Church of Tanzania in 1997, St John’s University actually began in 2007, using the refurbished buildings of a former Secondary School. Through it, the Anglican Church of Tanzania aims to give increased access for young people to university education. The mission of the university is to provide “high quality education and training in the theological, social, scientific and technological disciplines”. It is the aim of its founders to have strong Christian values, and to be linked to all other existing Anglican teaching institutions. The university has begun with faculties of Humanities and Education, Science and Applied Technology, Nursing, Pharmacy, and Theology and Religious Studies. It has the approval of the government, and students have access to Higher Education Student Loans (HESL). As the Prospectus makes clear, the university “…is to prepare graduates to be lives of service. Its target is to send into professional and managerial ranks graduates accustomed to searching out areas of need, and addressing those needs with skills acquired in the seminary of St John’s.” The goal of St John’s is to raise US$1.5 million to get the university properly established.
In Ghana, the Anglican University College of Technology was launched in March, 2008. It is the first university to be established by the Anglican Church in Ghana and is located at Manso Nkran, using the main yard of a former mining company site given to the church. At the inauguration on June, Dr Adio Kufuor, the President of Ghana, noted that the establishment of the university was yet another manifestation of the long-standing positive relationship between the state and the Anglican Church, and it signaled a further role of the church as a true partner in development. The university is to be a technical university, geared towards providing Ghanaian and regional economies for manufacturing industries. Students will be introduced to broader fields of study than their specific concentration. Implicit in all programs will be upholding the ideals of Christianity, including discipline, integrity, and respect upon truth, as well as the goal of each student to become a patriotic and innovative achiever. It is hoped that the university would have on its campus specialized laboratories in research and development which had would have a direct relationship on the practical programs of the university. The university will ultimately have several campuses. It will use both internet and classroom courses for learning. Of course the largest
(Continued on page 8)
Reflections from the General Secretary...
I am sure that I am not the only one to have good memories of our May Triennial Conference in Hong Kong. It was such a special event with everyone who came and all we experienced together. Our hosts, Chung Chi College and the Province of Hong Kong, excelled themselves—from the Opening Service right down to the banquet with the smashing open of the clay-baked “Beggar’s Chicken” (see a picture in the collage on the last page). Our thanks to Archbishop Kwong and his co-workers, Professor Leung and all his staff, and especially to our wonderful and full-of-fun leader, the Rev. Andrew Ng! Especially those of us from the “West” had an unforgettable encounter with the new emergent China, as well as getting to know Asian culture better. I believe we all are more prepared now to form closer relationships with institutions in Asia and to join in collaboration with our Communion partners in that part of the world. I did hear of various specific relationships that emerged through the Conference, with initiatives that might occur with Chung Chi College, with Sung Koon Hui University, with some of the colleges in Japan, and with Trinity University of Asia.
As of the time of writing, the Asian chapter of CUAC has met in Tokyo, and we—I look forward to hearing of the opportunities which they can share with us in CUAC worldwide. But I urge those of you who had such exploratory conversations at the Triennial to go and follow them up! I have been doing just that. Last month, representatives from the three Episcopal historic black colleges met in North Carolina, and reviewed how they might move forward with a relationship to Archbishop Ndungane’s “Historic Schools Restoration-Project”. There will be a meeting of the US chapter later in November which will do CUAC follow up, and I understand there is to be a meeting shortly in the UK as well. Earlier this month I visited three Canadian colleges who have not been active in CUAC for some years, and who now show interest in becoming more involved.
But what is very clear is that each college or university needs to have a “Point Person” for CUAC, who will take the initiative to follow up on relationships, to read and distribute news from the other CUAC colleges, and to let me or other members of the Board know when a particular college would appreciate a CUAC initiative on its behalf. If I can be in regular touch with these “Point Persons”, then I can do the same sort of networking that up until now has only occurred when we meet at Triennial. Initiatives should be taking place now.
You will see later in this publication that we are instituting a “Classified Page” for Compass Points and also for e-newsletters, in which we make the membership of aware of the needs some colleges have, some of the relationships they would like to build, some of the programs they would like to share with other members, and even some of the faculty openings or searches which could be advertised throughout the CUAC community. We will coordinate this from the New York office, but it really means each member should both initiate something in the “Classified” from time to time, and also pay attention to what others are advertising there.
While everyone comes together at the Triennial, one of my most pleasant tasks is visiting each CUAC institution. I was able to visit Trinity University of the Philippines in Manila just after concluding the Triennial. Through the kind hosting of Dr. Josefina Sumaya, my wife and I met many of the staff and students of the university. The university is but one aspect of the ministry of the Episcopal Church in the Philippines; it also hosts the central St. Luke’s Medical Center and also St. Andrew’s Theological Seminary on Cathedral Heights, Quezon City. One of the outstanding strengths of Trinity is its longstanding commitment to service learning. All students must do such learning as part of their academic program. We were privileged to visit a nursing school project of the Center for Community Extension Services in rural Laguna, and were really impressed by what students had been able to do in terms of sustainable improvements for village life.
At time of writing, everyone around the world is aware of the financial troubles which have come to light in the past few months. I’m sure that CUAC College is affected in some way. One example of this is the editing of Compass Points. We have combined the functions of Compass Points (news) with Prologue (papers and articles). We hope the result is satisfactory. As we see the effects of this recession on us all, we can reach out to each other for creative help and support to get us through these lean years? If you have ideas or initiatives, please write me—or let me post your ideas on the CUAC classifieds. CUAC itself will be affected by the recession, and I will be bringing to the meeting of the Board of Directors in January 2009 some ideas on how we can manage what we can do given the diminishing resources we shall have. But there have been trying economic times before and they have been survived—so why not this time?
I close by mentioning that I was privileged to be in a staff role at the Lambeth Conference in the UK this past summer. It was intriguing to be around the bishops as they met with each other—using the new *lubaka* listening process—as they achieved a greater understanding of the interdependence and relationships of the Communion than perhaps has been achieved before. Thanks to Professor Michael Wright of Canterbury Christ Church University, a Reception was held for all bishops attending the Lambeth Conference who have a CUAC College in their diocese. It was good to hear from some of these bishops how much they value the work of their colleges, and how they feel they must continue to support them. The work of these colleges is a gift from previous generations. As you will read in our next story, there continue to be initiatives around the world where new colleges are being developed and built. The work of Christian education continues!
Don Thompson
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walk with us.
Interestingly, some of my most powerful moments, when most was asked of my Christianity, if you will, have been with students from other faiths.
It is interesting how, in this day and age, when many of our local young people are almost taught to reject God and religion - as if it is somehow 'uncool', these young men from other lands cannot conceive of a life without faith - and they seek me out to discover with them, ways of holding on to that faith, in the face of mockery and ambivalence from media/peers and maybe even leaders.
Their opening sentences often commence with "you're a Christian, right?" - and they go on to talk about their struggles and confusion in seeking to be faithful to that which they genuinely believe, while many around them scoff.
It's a hard thing, trying to fit into another land, another culture - even if only for three or four years.
And the younger we are, the more we try to blend in - to be the same. Even when adolescents are imagining themselves to be most unique, there is a certain sameness about their actions.
So here these young people come - to our land Australia - where people from all over the world already live. Whilst acknowledging our indigenous brothers and sisters who came first, it still must be said that we are a country of immigrants - We've all come from somewhere else, and we are all trying to fit in.
What I have learned from the fine young people who learn with us is that there IS room to speak of God amongst us - and when it works best is when we:
Let love be genuine,
We hate what is evil,
We hold fast to what is good.
So when my young Muslim friend, Mohammed, comes to me and expresses despair that he feels like the only one who prays in the whole of the university - and I tell him "Yeah, I felt like that too," then together we wander around and look for signs of faithfulness throughout the campus, then, I have brought Christ to him - and I have been faithful to my calling.
Rejoice with those who rejoice,
Weep with those who weep.
It's as simple and demanding as that.
The Lord be with you.
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**What's Happening...**
*Challenges in India*
by Don Thompson
Recently Christian schools and colleges in India have been facing challenges and threats posed by the revival of their Christian faith base, often from Hindu majority leaders. In Orissa, a state on India's east coast, there have been several Hindu-Christian conflicts in recent years, the most recent being in Tikabuli on August 29th, when Hindu zealots overwhelmed Christian homes in the village, searched them, and caused the inhabitants to flee their homes. Intolerance to "foreign faiths" has risen in the last two decades with a revival in Hindu nationalism. In some states, religious conversion has been made unlawful, and have made Christian instruction prone to legal challenge. On August 29, 2008, the Catholic Bishops of India asked Catholic schools to close across the country "as a protest against the attacks on the Christians, women, and other minority peoples."
Over 20,000 Catholic institutions were closed that day, and thousands of religious, clergy, lay Catholics, other Christians, and people of other religions took part in vigils "for the promotion of communal harmony and peace in India." Most non-Catholic schools and colleges remained open during the protest, but leaders admitted feeling the effects of the same pressure. Madras Diocese of the Church of South India organized a rally on September 1st, 2008 at St George's School in Chennai in support of the schools in Orissa. There has been longstanding Christian mission work among Dalit and Tribal communities for many years which has focused on care, education and support. Christians comprise about 2.3% of the population of India. The majority population of India is Hindu, though there are substantial Muslim and Sikh minorities. There are about 25 million Christians.
Web Site Resources:
- Church of North India: [www.cnisynod.org/](http://www.cnisynod.org/)
- Church of South India: [www.csichurch.com/](http://www.csichurch.com/)
- National Council of Churches in India: [www.ncicindia.in/](http://www.ncicindia.in/)
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**The Anglican Way in Higher Education**
Archbishop Njongonkulu Ndungane
Executive Director of The Historic Schools Restoration Project and former Archbishop of the Anglican Church of Southern Africa
Ladies and Gentlemen, fellow Anglicans, brothers and sisters in Christ, it is a great joy to be with you at this Conference.
My topic is 'The Anglican Way in Higher Education', which is, of course, very closely related to the Conference theme of Excellence, Character and Service.
Let me begin with a quote from the actor, Michael J. Fox:
"I am careful not to confuse excellence with perfection. Excellence I can reach for, perfection is God’s business."
Well, as Anglicans, and Anglican educators, we are certainly about God’s business, or so we should be! And, whatever Michael J. Fox says, excellence is also God’s business, and the business of God’s people – and so are character and service.
**Excellence, Character and Service**
Let me quote three Scripture passages:
"Whatever is true, whatever is honorable, whatever is just, whatever is pure, whatever is pleasing, whatever is commendable – if there is any excellence and if there is anything worthy of praise, think about these things” – as another translation puts it, “let thy mind dwell on these things.” (Phil 4:8)
"We boast in our suffering, knowing that suffering produces endurance, and endurance produces character and character produces hope, and hope does not disappoint us, because God’s love has been poured into our hearts through the Holy Spirit that has been given to us." (Rom 5:4,5.)
"It was he, Jesus Christ, who gave some to be apostles, some prophets, some evangelists, and some pastors and teachers, to prepare God’s people for works of service, so that the body of Christ might be built up, until we all reach unity in the faith and in the knowledge of God, and become mature, attaining to the whole measure of the stature of Christ." (Eph 4:11-13)
These passages make it fully clear that those who desire maturity within the Christian life will find themselves challenged by excellence, character and service.
These are not optional. If we are to be true disciples, living faithfully in accordance with the teachings of Jesus Christ, able to deal constructively and hopefully with all that life throws at us, and as people who help make the Church, the world, a better place – then the life of excellence, character and service are for us.
And this is the life into which we seek to induct our young people.
We are very much challenged by such a vision in South Africa – which has led to the establishment of the Historic Schools Restoration Project, of which, since my retirement, I have been the Executive Director.
Let me tell you a little about it.
**The Historic Schools Restoration Project**
Historically, a high proportion of South Africa’s schools and colleges for black young people were established first by missionaries and later by the churches.
By the 1950s, there were close to 5,000 of these schools and colleges, serving around 700,000 young people. They were in strategically important areas, wherever there were large black communities. They filled the vacuum left by governments who chose to ignore the educational needs of the whole population.
Most of today’s generation of black leaders – from Presidents Mandela and Mbeki down, and myself included – were products of those schools.
However, in 1954, the introduction of Bantu education halted formal church involvement in these schools and colleges. They were taken over by the apartheid government, and deliberately run down. Many have buildings in terrible need of repair, and some have closed altogether.
Others have struggled on, and still produce learners who achieve good results, and go on to become successful and productive members of society.
The aim of the Historic Schools Restoration Project is to strengthen such schools, and return an increasing number of others to the highest possible standards, so they may be centers of cultural and educational excellence, beacons of light and hope in their communities, and produce potential leaders of culture and integrity.
In the Bible, the word *character* defines that a leader, a leader of character, is anyone who gives a lead to others – at every level of society and community. This includes good teachers, good business-people and entrepreneurs, good local councilors are leaders, and, by no means least, good parents of future generations.
Good leaders surround the meaning of true service. For example, the fundamental duty of politicians and civil servants is to work for the common good, and not for personal gain at the expense of others; similarly, politics and business alike need to be honest, transparent and open, within a society where people recognize that everyone must respect and uphold the rule of law – so everyone can live in safety and security.
Though in South Africa we have particular historic burdens to overcome, we are not alone in our need to build a harmonious society,
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where difference is seen as enriching, not threatening.
We want to balance individualism with a strong commitment to our life with one another. In Africa, we have a lovely word for this: ubuntu. Its core philosophy is captured in the phrase I am, because we are together. Ubuntu is about what it means to be human for others; to act kindly to one another; to be kind, just, fair, compassionate, trustworthy, honest; to assist those in need; and to uphold good morals.
For me the ubuntu ethic is supremely gospel-shaped, body-of-Christ-shaped. It also reflects excellence, character and service in our human relationships.
In promoting ubuntu, our Project wants to celebrate and support schools and colleges that address the whole of life, and prepare our young people to address the whole of life.
The Historic Schools Restoration Project is not specifically Christian, but I hope you can see how Christian values and aspirations are mirrored within it.
And that is not surprising, because we know that whatever is true and good and commendable reflects something of our Lord and his Kingdom.
**Anglicanism – Christian Resourcing for the Whole of Life**
Let me turn now to more explicitly Christian, and Anglican ways of fostering excellence, character, and service. This too is about learning to address the whole of life.
I am very convinced that Anglicanism allows us to do this more richly, more comprehensively, more fruitfully, and with far greater integrity, than any other way of being Christian.
Being Anglican gives us tools for being the people Jesus Christ calls us to be, in every walk of life, in every dimension of what it is to be human, as an individual, and as a member of wider society.
And that is a good and right – because there is no aspect of human life, individual or corporate, which is beyond God’s concern, and beyond God’s desire to bring redempion and transfiguration wherever it is required. And, of course, he shares with us the immense privilege of being his workers in this vineyard of his.
Much of what follows arises from consideration of the nature of Anglican identity. Though we are driven to ask such questions by the tragic divisions among us, I hope that the treasures we have unearthed will prove more lasting than the pains we suffer now.
Strife within Anglicanism is of course nothing new. In 1832, Thomas Arnold, then Master of Rugby School said, “The Church of England is at no time, nor has it hitherto ever been, a church.”
Over a hundred and seventy-five years later, the Church of England, and the Anglican Communion, are still standing, knowing that, once more, no human power can save us. Yet it is not by human power that we stand or fall – it is by God’s grace. This is God’s church, and we are in his hands. Therefore I am optimistic about our future.
Anglicanism has had a tumultuous history. There have been times when we have been deserving of refining by fire. But through it all, God has preserved us. And he has preserved us in ways that have maintained what is recognizably a distinct Anglican character.
**Scripture, Tradition and Reason – Reformed, Catholic and Culturally Engaged**
The essence of Anglican character is summed up in two ‘Triads’.
First are Scripture, Tradition and Reason, enunciated by the Anglican divines of the seventeenth and eighteenth century.
Second are the three threads that run through each of these – the fullness of Anglican life expressed in our being Catholic, and Reformed, and Culturally Engaged in the contexts and circumstances (often varying and diverse) of the world in which we live.
The Archbishop of Canterbury has described this second triad as enailing:
- “reformed commitment to the absolute priority of the Bible for deciding doctrine,
- a catholic loyalty to the sacraments and the threefold ministry of bishops, priests and deacons,
- and a habit of cultural sensitivity and intellectual flexibility that does not seek to close down unexpected questions too quickly.”
We need to be Catholic, Reformed and Culturally Engaged through Scripture, Reason and Tradition. Combining both these three-fold approaches allows us to describe an area, a matrix, within which there is space for us to live and grow and mature, and to handle all that life can throw at us.
These elements inform and shape our theology, our ecclesiology, our relationships within the Church, and our life within the world at large.
This is so because they address not only the content of our faith, but also the best of the Anglican style of living - characterized by God-given, God-graced virtues of trust, tolerance and charity across the variety we encompass.
**Living the Anglican Life**
Though Anglican theologians may delve deep into all these areas, in fact they are also what makes the life of every maturing Christian, though we may not immediately recognize this. This is why it is relevant for us to speak of such things at a conference on education.
Let me describe their interplay in my own life.
When confronted with such narrowly drawn choices as ‘Are you liberal, or conservative?’ – as is sadly too often the case these days – my response is that these are not the categories through which I live as a child of God, and a member of the body of Christ.
I can say that I recognize both conservative convictions and
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**A CUAC Triennial 2008 Presentation Synopsis and Mid-day Worship**
**Excellence, Character, and Service: The Need to Re-define Concepts in Education**
*The Rev. Varghese John*
*Union Christian College, Aluva, India*
**Synopsis:** When Christian institutions entered the field of education, it was generally looked upon as service, both by the Church and by others. This has been so in the case of Union Christian College, Aluva, and the objectives of the college as stated by its founders in 1921. Such objectives, and the impact of a large number of Christian Colleges in India, were acknowledged, for instance, by the Hinday Commission on Christian Higher Education in India as early as 1951.
But factors like the increase in the number of students, and of colleges and universities (the massification of higher education), the inability of governments to pay for higher education in spite of greater demand, and the growing internationalization of education, have made quality assurance a primary concern in higher education all over the world. The need for maintaining of quality through periodical evaluation, assessment, and accreditation. When tools and terminology from the corporate world become accepted measures of quality, education itself turns out to be a process of producing standardized products that meet certain pre-defined expectations.
However, if we can see that the education we give educates the whole person, that its ultimate impact is that of one life on another, that it is concerned with community and with life-learning; and if we can assume that excellence is the best within human capacities, and can still constantly critique and measure it against the standard of the ‘perfect’ conceived as the realm of the divine; then, the education we give will have quality beyond ratings and accreditation.
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**Homily**
*The Rev. Kim Cruickshank*
*Chaplain, Trinity College*
*University of Melbourne, Australia*
Over the past month or so, every time I have had occasion to preach, I have found myself reflecting on passages much like the one we have just heard.
Passages wherein the list of directives or - if you like, helpful suggestions - seems almost endless. And on each occasion I have done so, I have shared my belief that, if we were to take just one of these instructions - any one - and undertake to do just that, that this alone could be our life's work. For each one of these sets a challenge which calls forth from us - expects from us - Christ-like behavior of the highest order.
Let love be genuine, Hate what is evil, Hold fast to what is good, Love one another with mutual affection.
...and THEY'RE the easy ones!
We read on:
"Bless those who persecute you, bless and do not curse them. Rejoice with those who rejoice, weep with those who weep."
If there was ever a passage that, for me, summed up the call of the Chaplain, then this is it.
Working as I do, exclusively among international students, whose second language is English, I find that it is often my actions - my conduct - which is the first aspect of my ministry to be noticed or received by newcomers.
Many of them come from non-Christian countries. Many of them are not Christian. SOME have been warned that Australia, for example, 'hates Muslims', and they are circumspect in their exploration of friendships and contacts, and often quite nervous in groups.
So, how to proceed?
Let love be genuine. Hate what is evil. Hold fast to what is good.
Chaplaincy in this context - as indeed, I guess in all ministry contexts, must be seen to live what it speaks - to embody what it preaches. And we are called to accompany whomever God sends to
relationships.
He shared his concern that CUAC members more effectively use the Internet, its technologies and its resources to develop cross-cultural initiatives.
Dr. Thompson reported that he would be his present at the Lambeth Conference this July. Christ Church Canterbury University is graciously organizing a reception for bishops from the Communion who have CUAC institutions in their diocese.
3) Chapter Reports
The British Chapter (newly reconstituted) hopes to institute an Annual Conference, the first of which will focus on Sustainability and Justice. They voiced their concern about the “service learning” as a CUAC priority, rather than other expressions of community service from different educational cultures.
The India Chapter has 30 institutions at the Triennial this time, which is 30% of its overall membership. The India Chapter meets every six months. Major programming is on service learning, and how to get grants in order to promote college projects. Web site concerns are important to the chapter.
The East Asia Chapter has 13 delegates in this Triennial (they have dropped “Pacific” from their name). They expect to meet every 1½ years (between Triennials). They will have their inauguration October 26-27, 2008 at Rikkyo University, Japan. They would appreciate the Triennial Committee’s assistance with the issue of chaplaincy, and to address issues for personnel who handle primarily non-Christian or secular student populations. Christianity is a “minority” religion in the East Asia context. Student input and participation should be encouraged more at CUAC Triennials.
The US Chapter looks forward to meeting November 16-17, 2008 at Kenyon College, OH, following a plan to use Chapter meetings as campus visits. The chapter will consider expanding the gathering to include other continental American colleges, including Canada, the Caribbean, and Central and South America. The “Historically Black” Episcopal Colleges are expected to visit with Archbishop Ndungane September 18th-20th 2008, attending a similar collegiate project in South Africa with the Restoration of Historic Schools.
The Australia Chapter needs to spread the word about institutional participation of Australian colleges, especially at future Triennials. The Chapter was glad that CUAC is open to the participation of Heads of Governing Boards, as well as Principals and Presidents.
4) Nomination Report and Election of Trustees and Officers
The following names were submitted by the Nominating Committee:
The Rev. Dr. Maher Spurgeon (India)
Prof. Michael Wright (United Kingdom)
The Rt. Rev. Martin Wharton (United Kingdom)
Dr. Henrique Tejpa (Liberia)
Dr. Marianne Diepen Boomstra (India)
Dr. Joel Cunningham (United States of America)
The Rt. Prof. Isao Nishihara (Japan)
The Rt. Rev. Henry Nutt Parsley, Jr. (United States of America)
Prof. Muriel Robinson (United Kingdom)
The Rev. Dr. Ivan Head (Australia)
The Rev. Dr. Andrew Wai-Man Ng (Hong Kong)
Dr. Jean-Lien Chen (Taiwan)
Motion: That Nominees to the Board of Trustees be elected to serve for 2008-11 Triennium. Carried
5) Thanks
The Rt. Rev. Martin Wharton gave thanks and recognition to officers who are going off the Board. Dr. Nirmala Jayasing (10 years of service) and Dr. Gail Cuhlbert Brandt (12 years of service) were awarded Anglican Communion pins. He also thanked other members who will also be leaving the Board, but who will be most present in our time: The Rt. Rev. Dr. John Lai (Tanzania), The Rt. Rev. Douglas Thaxter (United States) and The Hon. John Bannon (Australia). Members by applause thanked all these Trustees.
6) Proposal for Location of Next Triennial
Dr. Joel Cunningham (University of the South, USA) graciously offered the use and hospitality of the University of the South in Sewanee, Tennessee to be the location of the 7th CUAC Triennial Conference in 2011. The proposed dates are May 21-26, 2011. Members enthusiastically received his proposal and look forward to its development.
7) Meeting of New Trustees
All current and newly elected Trustees met briefly to elect Officers and to try to establish a date for the Board to meet in the near future. Prof. Michael Wright was elected Chair, Dr. Maher Spurgeon Deputy Chair, and Dr. Joel Cunningham Treasurer. The first meeting of the new board was proposed for the end of the first week in January 2009 in New York City.
Here I should like wholeheartedly to endorse Archbishop Rowan’s understanding of the interrelationship of unity and truth. Jesus is the Truth, and our unity is in him. Both start and end with him – they are both gifts, and both “prior” to us and our choices. To a very great degree, unity is, as the Archbishop of Canterbury says, “generally a way of coming closer to revealed truth.” If the body is not whole, the whole body suffers, including our understanding of the truth. Both unity and truth must be pursued, together, to the best of our God-graced ability – neither is optional within our Christian vocation. And both lead to Jesus.
I find this endless returning to Christ, to the center, to the middle ground, a continuing dominant reality not just in my personal faith. I also find it in my own experience and understanding of the Anglican Church, in all its diversity, at every level, from Communion, and Primates meetings and Lambeth Conferences, through to Provinces, Dioceses, and parishes. We grow best when we allow this level of complimentary difference, which can indeed “provoke one another to love and to good deeds” (Heb 10:24).
Exploring Legitimate Diversity
It is not easy to live with a spectrum of perspectives – it is challenging even when we are fully confident we are all firmly within the heart of Anglicanism. But this wrestling together offers us the possibility of treasures that cannot be found in more monochrome approaches to faith.
We are people, parishes and Provinces, who are deeply immersed in each of these streams – catholic, reformed and intellectual/cultural – so we can together forge a fuller and more comprehensive understanding of how to live faithfully in our current times. Such breadth will then help each one of us, whether we are called to be archbishops or architects, priests or postmen, deacons or doctors – and whether it is in Europe, America, Africa, or Asia – and whether it is in poverty or prosperity.
Anglicanism is not a “one-size-fits-all”. It provides God’s tailor-made coat of many colors for every one of us!
One of the strengths of the Anglican way of being Christian is precisely this enrichment that comes from legitimate diversity, and of the resources it gives us to deal with diversity – whether we face it within Anglicanism, within the ecumenical life of the different Christian churches, or within the widely varying cultures of our world, into which we, and our young people, are called to be salt and light.
It is also important here to note that I am talking about legitimate diversity. Because the faith I am describing is certainly not “anything goes”.
We are all permanently under the three-fold testing and purifying scrutiny of the refining fire of God’s holiness (Zech 13:9), of the two-edged sword of Scripture (Heb 4:12), of minds transformed by the
renewing Spirit (Rom 12:2) – constantly challenged by truth and invited by love to “hate what is evil and cling to what is good” (Rom 12:9) and so to move towards greater Christ-likeness.
This applies in our use of Scripture, Tradition and Reason.
First, Scripture. There is good scriptural exegesis, and there is bad exegesis. We must draw, critically, on the best of contemporary scholarship.
I was intrigued to read in the English Church Times newspaper how, two hundred years ago, those within the Church who opposed slavery were criticised for being cultural liberals, going against the plain meaning of scripture, which clearly endorsed slavery!
This illustrates what a difficult job it is to understand what is appropriate ecclesiastical use of the gospel, and what is inappropriate syncretism.
But we cannot shirk this task – nor can we leave our people, young and old, ordained and lay, bereft of the tools they need to know how best to read Scripture and apply it in the circumstances they face.
So we must read Scripture – read it deeply – but read it in the light of Tradition and Reason, and read it through the lenses of our Catholic, Reformed, and Culturally Engaged perspectives.
Taken together they help us avoid being unduly influenced in any one area of faith, and continually draw us back towards the heart of what we believe – to the one in whom we believe, Jesus our Lord and Savior.
Then tradition. Tradition is not a dispassionate history of institutional life, the dry and dusty account of some external observer. Tradition is holy remembering – remembering that Scripture teaches us to remember. To do this in remembrance of me” (John 14:26) words to us.
Holy remembering is both to recall and to re-member. It is to be caught up into the unfolding narrative of God’s involvement with his people in every time and place. It is to recognize God at work in our church throughout the centuries, and to know ourselves in living continuity with his faithful people in every age. To remember is to take our place within God’s story of redemption.
Understanding tradition as the invitation to live in continuity with God’s work in and through his church challenges us to see the fingerprints of God upon unfolding history, even if today we live in different cultures from historic Anglicanism.
By seeing God at work in historical continuity through changing circumstances, we can be helped to make better sense of what God is doing, and calling us to do, here and now – whether inside the church or outside its walls.
This is true for all the people of God in their different callings, and something we should help our laity to do better.
Furthermore, when we critique Tradition with Scripture and Reason, and look at it through our three-fold perspective, we are also able to live out our understanding that we are a church *semper reformanda*; in every age asking ourselves “Are we (and how are we) in need of reform?”
As Cyprian of Carthage said, “Custom without truth is but the longevity of error.” This is how we preserve the best of Anglican polity.
Alongside this, we also need the critical best of Reason.
The Enlightenment fallacy, that we can occupy some neutral position, independent of our context, and deliver timeless abstract truths, has collapsed.
Before Descartes mischievously said ‘I think therefore I am’, (“Cogito ergo sum”), philosophy had understood that being (“esse”) preceded thinking (“sponsocere”). It is because we exist that we can think – and of course, we exist because of the prior action of the Creator, who pre-exists all that is, and who holds all that is in being.
The reason which we must employ today stands comfortably within the Christian tradition of “thinking after understanding”, re-appropriating for our own time, the intellectual rigour of Thomas Aquinas and other great Christian thinkers of the past. We do not need to worry that in place of the Enlightenment the only option is unrestrained post-modernism where all truths are relative.
We need to give our people confidence that this is so. Some find the apparent “loss of certainty” of the collapse of much of Enlightenment reasoning very unsettling. But today’s philosophers are increasingly concluding that true human reasoning is best found within communities of tradition: communities such as the Church – and through the sort of dynamic weighing of all possible evidence, all possible interpretations, of which I have been speaking.
Such an approach also assures us that it is not a failure of faith or reason to say that we do not know the total, absolute, objective truth of all that can be said about God and how he calls us to live. Rather, we have a relationship with our living Lord and Savior, who is the Way, the Truth and the Life. And through this relationship we will come to an ever greater and unfolding understanding of that Truth, as we walk in his Life-giving Way.
**Jesus, our Touchstone**
This is why, when it comes to finding the essence of Anglican identity and the heart of Christian faith and life, Jesus is always the ultimate touchstone.
He is the solid center to which the balanced, dynamic interplay of the elements of our faith continually return us. He is the standard against which we measure the quality of our exegesis; of our understanding of God’s redemptive action in the world throughout history; and of our own engagement with the world. The question always is, does this conform to what Jesus is asking of us, as we best understand it? Are we being true to the Jesus of Scripture, of the Creeds, of centuries of Tradition, as demonstrated in lives of the heroes and heroines of the faith?
Jesus is the yardstick against which we judge the content of our faith, the interweaving of all the strands of belief, and the best of Anglican practice.
**Anglican ‘Style’**
Authentic Anglican style, which I mentioned earlier, lies not
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**Excerpts from the CUAC Triennial Business Meeting**
*Chung Chi College, Chinese University of Hong Kong*
*May 31, 2008*
*Chair: Dr. Nirmala Jeyaraj*
1) **Opening Prayer and Introductory Remarks**
Opening Prayer was offered by The Rt. Rev. Martin Wharton.
Dr. Jeyaraj welcomed all members. CUAC is not only a global network, but also a family. She offered thanks to the Archbishop and Province of Hong Kong, and the administration and staff of Chung Chi College for their leadership in making this conference happen.
She noted an important development that CUAC Chapters have grown in number and quality of participation.
CUAC’s work affirms the key role that the Church plays in the life and mission of member institutions including 1) the ongoing need for dialogue between church and college/university; 2) the need for member institutions to be “relevant” to current faculty and student populations; 3) the development of sister relationships among CUAC members; 4) the crucial role of chaplaincy today; 5) the ongoing importance of leadership development.
These are necessary to keep CUAC as a global and active network, promoting community service-learning, and faculty/student exchanges.
2) **Report of the General Secretary**
Dr. Thompson referred to Numbers 11, which tells of “shared burden and responsibility” in leadership. This is crucial to the work of CUAC. It is a network of relationships between institutions of higher education who share the joys and burdens of promoting higher education with an Anglican Christian identity.
The reason why Anglican higher education institutions are becoming fewer is because of being out-sized through the tendency “go it alone”, or merging with other institutions by which identity is lost. An unexplored strength is of Anglican colleges relating together.
Dr. Thompson referred to achieving some financial health for CUAC. He said the US$800.00 Conference Fee has helped to provide travel scholarships and handle Conference expenses, hopefully coming close to a near balanced budget.
CUAC faces the challenges of maintaining good communications between members, and with the New York office and members. Few members report their initiatives, and share good ideas that work. Each institution needs to appoint a “corresponding secretary” - someone who is the contact person between CUAC and his/her institution, and actively committed to maintaining and developing working CUAC.
our affairs efficiently – and we all have to – we know that a University, a college cannot be just a business. Its bottom line cannot ever be its balance sheet.
Our task is to create a community – a community of learning where everyone matters where we support each other, where every member has a real prospect of opportunity, development and growth.
As we give time to each other and we put our faculties at the disposal of all our members, so we are working out the meaning of service in our own day. How are we as colleges and universities helping our students to engage with the world around us, and so become servants of others?
How do our lecturers and researchers contribute to the well being of our societies and our world? Slowly, it’s not very fashionable to talk in this kind of way at the start of the 21st century. Certainly in the UK the mood is that we are supposed to live just as we please or whatever we choose. But this individualized and relativized monochromic, and sometimes hedonistic, way of living breeds monsters, destroys community, leads to the ruin of many a social project and dashes every dream about a social and world order built on mercy, pity, peace and love.
In the university, in service, seeking each other’s betterment, putting the interests of others before our own, working for the common good – needs to run through the whole of our CUAC operation like lettering through a stick of rock candy.
I vividly remember a conversation I had at my first CUAC conference in Delhi in 1996. We visited one of the Anglican Colleges in India and I remember talking to the Principal. I asked him what his college most needed – thinking he would want more money, or more books, or the library, which had many empty shelves, or more computers to replace the two old models that were there.
Not a bit of it. He replied ‘we don’t need more resources, all we need is more able and dedicated teachers to inspire our students to see that their privileged education is not simply for their own personal and financial advancement but for what they can offer back to our society, for the benefit of those less fortunate than themselves. That lies at the heart of the matter.
And then from John’s gospel we heard how Jesus disclosed the deepest secret of his being, the scope of his vision for humanity, the purpose of his life:
Notice that this moment of self disclosure had long been hinted at but eventually took place only when Jesus and Greeks were gathered together in Jerusalem. The arithmetic of Greeks plus Jews equals everyone. Just as $2 + 2 = 4$. Greeks and Jews – everyone. Put them together and you have nothing less than the whole human race’.
True Anglican vision like that of its founder is inclusive, indeed universal. And that too has to mark our endeavours. The Anglican way is the way of conviction and openness. Conviction of the truth, but always open to the new insight. The Holy Spirit is teaching us – all held with tolerance, inclusivity and charity. Centuries ago St Augustine said, in essentials unity, in non-essentials liberty, in all things love.
Though it might sound like a tautology, a university is nothing if it’s not universal.
People meet across disciplines, teachers and students learn together, character is formed, an unforgettable time in our lives is stamped with the imprint of excellence. It doesn’t need anyone else to tell us this. We know it. It’s our core business. Service, Character and Excellence.
And we have to remain faithful to this ideal despite the pressures on all out budgets and the threat and challenges from our governments. And we have to remain faithful to this ideal together and not least for the sake of the Anglican Communion.
The CUAC colleges and universities have been learning a lot about working together over the last 15 years. They’ve been learning that forging a unity together is greater than the sum of our separate parts.
Get wisdom get insight, above all get insight
Get understanding, perception, discernment, vision and that elusive quality of being able to see beyond and beyond the surface of things. To be able to get to the heart of the matter despite all the complexities, paradoxes, questions and contradictions of our age.
With one eye firmly fixed on the opportunities and challenges which face us in the here and now, but with the other eye equally focused on the rich tradition of our Anglican Foundation so as to ‘Get wisdom, get insight… but above all get insight.’
Our age urgently needs institutions of higher education such as ours, which live and breathe unity, wholeness and coherence. Institutions which are prepared to challenge complacency in the political fads and fashions of the day. Institutions which will take the time and the risk to encourage the longer term view. True to themselves but above all true to the selfless, generous and self giving love of the one who inspires all our endeavors, Our Lord and Savior Jesus Christ.
One final comment.
By coming together as a community under God we express the deep down truth that we can only/become what we are meant to be as we learn to share – share each others company, our goods, our needs, our
(Continued on page 19)
God’s world. We desire to be a Church in which abundant, God-given, Christ-shaped life can flourish, and this life can be shared with the world for the building of God’s kingdom, and for his glory.
The pursuit of such a way of being Church is a task of the whole Church together.
So, if this Communion must pursue a Covenant – and I remain to be convinced – let it be one in which the Anglican Consultative Council, as the most representative Instrument of Unity, with its lay and clerical members alongside bishops, be at the heart of it.
The Lambeth Conference remains in my prayers. I hope they will be able to concentrate on the twin themes of Anglican Identity and equipping Bishops as leaders in mission. I fear that they will once again be hijacked by unedifying obsession with a single issue which is not the touchstone of our identity.
And most of all I regret that there is no parallel Anglican Gathering, far larger than the Anglican Consultative Council, with a good balance between Bishops, Clergy and Laity, in which participants can freely speak their own minds. With a very flexible and open agenda, concentrating on informal encounter and the sharing of faith, there might have been the necessary space to get to know one another, our contexts, our cultures, our challenges.
For it is in our listening to one another and our faith journeys, that we can best recognize the marks of Christ in one another.
Perhaps we have received such opportunities to reach a better understanding of the lives of Christians in other Provinces, we would not have come to the situation we now face. Perhaps then, as brothers and sisters of Christ in all our diversity, we could have explored together the question of how we understand ourselves as Anglicans, and how God wants to leads us forward in our common life.
There is no doubt that we must find such ways to together listen to what the Spirit is saying to the Church.
And this returns me to the theme of education – for it is through fully rounded Christian Anglican education that the whole people of God will best be equipped for such participation within the body of Christ, and our mission to God’s world.
Conclusions
We live at a time of great change. This is certainly true in South Africa as we consolidate democracy. But more generally, change is here to stay in a world of continuing technological advance.
The shape of the future is very much in our own hands – and especially in the hands of the young.
This reminds me of words the poet Wordsworth wrote:
“Bliss it was in that dawn to be alive, but to be young was very heaven!”
The challenge to us is to help the next generation of Christians, of Anglicans, to rise to this challenge – the challenge of excellence.
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lived through character in a life of service.
Let me offer you another quote. The American football coach, Vince Lombardi, said this:
“Perfection is not attainable. But if we chase perfection, we can catch excellence.”
So let us offer our young people the opportunity to chase perfection, and take hold of excellence.
It was my grandfather who gave me my name, Njongonkulu. “Njong” means “jim” and “nkulu” means big. My grandfather wanted me to be inspired – inspired to “aim high”, inspired to “think big”.
Today I am an Archbishop, so I guess that my grandfather’s hopes came true! It was Christian, Anglican, education that made it possible for my grandfather’s dream to become a reality.
Let us strive for the sort of education that lets every young Christian to be a confident Njongonkulu in God’s world.
Amen.
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**CUAC Classifieds...**
**Relationship Wanted:**
Medical College and Hospital in India is looking for educational and healthcare partners to provide mutual residency opportunities in India and abroad.
*Write CUAC Office for Contacts.*
**Exchanges Wanted:**
University in Korea is interested in exchange programs with overseas institutions. The university’s area of expertise is social change, non-governmental organizations and civil society.
*Write CUAC Office for Contacts.*
**Sabbatical Opportunities:**
University in Liberia would welcome faculty in fields of arts, science and professional schools to teach in the university and be involved in the professional development of faculty in their disciplinary field. Periods of a month, a semester or two semesters are possible. Accommodation and some expenses would be provided.
*Write CUAC Office for Contacts.*
**Faculty Wanted:**
New university of technology in Ghana seeks full time or sessional lecturers in basic fields of the material sciences and engineering, and also nursing. The university will have a close relationship with industry.
*Write CUAC Office for Contacts.*
**Education Abroad:**
University college in Canada is open to receive international students to diversify and enrich its student body. Prospective students should have basic funding resources.
*Write CUAC Office for Contacts.*
**Overseas Scholarship:**
Japanese university has opportunities for Masters degree level students and professionals to conduct supervised research in their academic field for 18 months in Japan. Fields such as nursing and agriculture are preferred. Recommendations from college or university and an Anglican Bishop are required.
*Write CUAC Office for Contacts.*
To Contact CUAC office, email us at email@example.com
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**Closing Eucharist Sermon, St. John’s Cathedral, Hong Kong**
The Rt. Rev. Martin Wharton, Diocese of Newcastle
Philippians 2: 1-11
John 12: 20-32
“Get wisdom and whatever you get, get insight”. Proverbs 4:7
I want to break with convention this evening and take a liberty by offering not one – but a number of texts – for this sermon from a variety of sources. First from the Book of Proverbs. “Get wisdom, and whatever you get, get insight.”
And then a Proverb of a different kind “Education is a treasure which no thief can touch”.
And then from some of our conference members: “The outcome of Education is the transformation of society. And it lies in education with a human face.”
And then I am because we belong together.” And: “If we pursue perfection – as Anglican Colleges and Universities we can gain excellence. And excellence and perfection is God’s business.”
These are some of the key words and phrases – texts we have given to each other over the last few days and shared with each other. From the scriptures – “Get wisdom and whatever you get, get insight.”
As we gather together at our closing Eucharist I want to ask what are the lasting memories that you will carry with you? What will longer linger with you? What will you take home with you? What are the things that have most struck you from CUAC’s 6th conference. Among mine are the blowout of that rear tire on the motorway at 60 mph.
Then –
The colleges and churches we visited in China. Old people in the church which looked like an ark, or an elderly professor talking with such affection about his grandfather a Bishop. I thought for a moment he was describing a shop selling bicycles.
The staggering changes and developments that we saw in China. The vast resources being poured into University Education there.
Or will your memory be of the generous and gracious hospitality of our hosts at Chung Chi College and the endless patience and care of Andrew and his team and Professor Leung who have attended to our every need?
Or will it be insights gained from our visiting speakers as well as from each other?
Or will it be the new friendships made, the relationships established the way we have strengthened each other in our Anglican and Christian identities?
For me one of the lasting memories came in a totally chance encounter at the White Swan Hotel – talking to a young woman who, after a process lasting over 3 years, had been given permission to adopt a baby. Rebecca – for that was the baby’s name, had been with her adoptive mother and family for 2 days – and the joy and the delight and the tenderness of this new member of the family was a wonder to behold. And 3 years to get to that point of the longed and hoped for becoming real.
In CUAC, for the hoped for to become real has taken us a bit longer. So what will be the lasting memories for you? And how will you begin to share the vision of all that this Conference has meant and given you with your colleagues and students and friends back home ahead? And how can we ensure that one of the outcomes will be that our Anglican Colleges and Universities are drawn more closely together, not only in our common identity but in the way we develop our relationships and partnerships over the Communion.
I hope it has been the case that new partnerships have been explored and new opportunities will be pursued with each other between Hong Kong and the USA and time to meet again – at Sewance – the first time we’ve met in the USA – in 2011!
So “Get wisdom and whatever you get, get insight.”
Over these last 15 years the Colleges and Universities of the Anglican Communion have accomplished a number of trend setting achievements. We’ve developed exchanges for students and faculty. Service learning opportunities have been taken up. We’ve developed courses and programs and shared resources.
We are learning to generate trust and a common commitment to each other – so that CUAC is becoming ours rather than theirs – whoever they may be. Remember “I am because we belong together”.
After all we share the common task of providing first rate learning environments for our students, opening our doors to graduates and students from all points and none. And we hold within and undergirded by our Anglican and Christian traditions, beliefs and witness.
Righly, so much of what we are about flows from the qualities we see in the giver of our faith, and our 2 readings from scriptures illustrate these. In the passage from Philippians we read that Jesus did not strive at equality with God, but rather he emptied himself and took the form of a slave, a servant.
And it is that capacity to put the interests and well-being of others ahead of his own that gives Jesus authority and stamps him with integrity.
Service is the hallmark of his character. It must be the benchmark, the litmus test, of all our efforts to follow him.
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for two decades states “McDonald’s restaurants have become a dominant symbol of the globalization of the economy and target of the wrath of globalization’s many opponents. But local values still wield great influence on culture, and we can look for McDonald’s to emerge anywhere soon.”
The world needs citizens that contribute to and nurture the diversity that exists among peoples and who resist the temptation to fall back into isolationism and tribalism or live at the superficial level of a disconnected consumerism.
Strangely, “globalization not only pulls upwards, but also pushes downwards, creating new pressures for local autonomy…and has been the reason for the rise of local cultural identities in different parts of the world.” And many of the answers to the world’s problems lie within these reservoirs of cultural knowledge. But culture fights back, resisting extinction, because it is a strong force for holding groups together and bringing a sense of identity to its members.
So, while we encourage our students to be connected globally, we must also train them to care for their own cultures and respect and care for the cultures of others.
One of the places where students in the DSL program service is on a reservation in the Black Hills is the Cheyenne Big Crow Boys and Girls Club. Some of you were there several years ago when we had a conference in South Dakota. One of the major goals of this agency is to keep the culture alive, to teach children to learn its dances and other expressions of the culture, and its spirituality, as a way of keeping them connected to their heritage, their history and the strength of what the culture brings to their lives and to the community.
Research shows that students can become more open-minded, accepting of diversity, and at the same time they make a great deal about themselves. This is always positive and tend to have an impact on students personal development. This provides a foundation on which to build the skills, knowledge and attitudes that could make a difference in today’s world. There are models for “teaching valuable academic, social, and personal lessons simultaneously.” International education, and especially service learning, provides a unique forum in which to encourage learning that builds the skills and knowledge that students will need and the world needs now, just as we discuss the many global opportunities that exist in the global economy. So can we provide what the world needs through educational intervention? Certainly! This has always been the case at one level or another but it is now critical that we consider the needs of the future, needs we do not really understand, as we plan our academic programs. Service-learning, carefully designed and well run, with the experiential and reflective process that it must include, is uniquely capable of helping students acquire those attributes that prepare them for an interconnected and interdependent world. As educators, we have an obligation to provide that preparation, to engage students in the world community, and to ensure that there is a critical mass of future global citizens.
INTRODUCTION
In this paper I’ll talk about Christian higher education in China. I have deliberately omitted the grammar indicating tense here: “was”, “is” or “will be”. What was the state of Christian higher education in China? What is the situation of Christian higher education in China at present? Or what will be the future for Christian higher education in China? I’ll address each of these in the space that follows I intend to cover briefly all three areas.
First, I have to point out that there is no privately run Christian college or Christian university in the People’s Republic of China at the moment. As a matter of fact, Christian higher education had been discontinued by the Communist government in China since 1952, a few years after the Revolution. So, when we talk about Christian higher education in China, we are talking about what is expected to be only the past tense. However, in my presentation, I’ll include the present and the future. The present tense here in this paper refers to a state of mind, that is, how Christian higher education is perceived by several groups of people – scholars, educators, alumni, Chinese Christians and church groups. And the future of Christian higher education is presented here as an agenda paper and not as history. But let us first begin with the Past as History.
THE PAST:
HISTORY OF CHRISTIAN HIGHER EDUCATION IN CHINA
Although there was not a single Christian university in the PRC after the Communist takeover of the Chinese mainland and not too many Chinese, especially the young, are familiar with the history of Christianity in China, Christian higher education had, in fact, an important role in the history of modern China. For more than one hundred years from the middle of the nineteenth century on, Christian education had occupied a significant place in Chinese society. It is true that almost all Christian schools in China, elementary, secondary and tertiary, were in their beginnings an integral part of the mission enterprise and were strongly motivated by the aim of evangelization. However, many of the Christian colleges and graduate became less missionary-minded and more concerned with disseminating knowledge, learning and other purposes of education. Around the turn of the present century, many Christian educators, Chinese and Westerners alike, were also convinced that the Christian colleges and universities could be a reforming force in Chinese society and an agent of modernization. As a result, the early decades of the twentieth century witnessed a remarkable development in Christian higher education in China with the emergence of more than twenty-five Christian colleges and universities and a rapid increase in student enrollment at these Christian educational institutions. In 1918, according to Charles Edmunds, there were over 6,000 Christian schools in China of which twenty eight were tertiary institutions and fifty six were teachers’ training colleges. Later in the 1920s and 1930s these Christian tertiary schools were supplemented into thirteen Protestant and three Catholic colleges and universities in China with over a thousand faculty members and six thousand students. The Protestant colleges and universities were: Yenching University in Beijing, Cheeloo University at Jinan in Shandong Province, Ginling University and Ginling Women’s College in Nanjing, St. John’s University, Shanghai Baptist University (Huijiang) in Shanghai, Hangchow University (Zijiang) in Hangzhou, Szechuan University (Dongwu) in Suzhou in the province of Jiangsu, Hubei Union University at Wuhau, West China Union University at Chengdu in Sichuan Province, Fukien Christian Union University and South China Women’s University in Fuzhou, and Lingnan University in Guangzhou. The three Catholic universities were: Fu Jen Catholic University in Beijing, Tsienmin University of Lingnan in Canton, Tianjin, and Atonra University in Shanghai. Some of them such as Yenching University and Ginling University developed a national reputation inducing some of the best minds in science, social sciences and the humanities to join their faculty roll and attracting to their campuses many bright and promising students from all over China. Some of them were particularly well-known for their leadership in training St. John’s and Yenching’s higher education (such as Ginling and West China). At Ginling University in the 1930s, for example, the professors of the Science faculty were well trained at top-notched research institutes and universities such as Chicago and Columbia. Two of its leadings professors in the faculty of science, Wei Xuren who was appointed Dean of the College of Science; and Wu Jinghao, received their Ph.D.s in Physics from the University of Chicago, the breeding ground for Nobel laureates, including Yang Chen-ming. Several of these universities and colleges were famous for their education such as Peking Union, Cheeloo, St. John’s and West China; and in the field of social sciences, Yenching and Cheeloo were well recognized in China for having the best programs in Sociology, Anthropology and Journalism. Ginling and Cheeloo, also had very good departments in agriculture and forestry.
Even in the humanities, these institutions were not far behind in research and teaching compared with the top universities in China such as Peking University and Qinghua University. A glimpse at the teaching staff of the Christian universities in the area of Chinese studies in the early 1930s, for example, would show the following: Chen Yuan, Qian Mu, William Hung; Ma Jian, Gu Jiegang, Xie Wanying (Bing Xin), and Xu Dahan, all connected with Yenching for a substantial period of time. Famous alumni and distinguished
graduates from these Christian universities included nationally renowned writers like Lao She, Bing Xin, Xiao Qian, and Xu Dishan, translator Liang Zongzhu and Yan Qin, philosophers Thome Fang, Xie Fuxi, Xu Zhong, and Yu Youren, historians Shi Nianhai, Wu Yujin, Zhang Kaiyuan, Zhou Yiliang; Tan Qixiang, Wen Dujian, Bai Shouyi, Wu Bingzhen, sociologists Fei Xiaotong, Wu Zenzan, Li Anzai, Yang Qingkan and Zhang Hongyan, and politicians and diplomats Huang Hua, Gong Shusheng, Gong Feng, Lei Jiezhong, Lu Ping and Zhou Enlai—the last two playing a crucial role in the transition of Hong Kong from British to Chinese sovereignty in 1997. The list can be extended much further and longer, showing ample evidence of an important role played by the Christian colleges in modern Chinese society.
THE PRESENT: MEMORIES, REMEMBRANCES AND RESTORATIONS
As I have pointed out in the beginning, there were thirteen Protestant and three Catholic universities and colleges in China in 1949 before the founding of the People’s Republic. Despite the rising tide of Chinese nationalism and the imminent threat of Communist takeover, Christian higher education showed no signs of retreat or decline in the late fifties. However, the future of Christian higher education appeared to be on its way to rapid decline and disintegration after 1949. Only two years after the Communist victory, a major reform in the educational system was imposed upon the schools by the Chinese communist government involving structural and curricular reorganization of most colleges and universities. Most of these Christian educational institutions were to be dismantled or incorporated and merged with other public universities. As a result of this major change, the history of Christian higher education in China came to an abrupt end. The younger generation who were born in the new society grew up with little knowledge of these Christian schools. In fact, a lot of students who attended universities on these former Christian college campus grounds were unaware of their institutions’ Christian past. The present Peking University (Beida) is standing on the ground of Yenching occupying the most part of the former leading Christian university, while Shanghai University is now at former Tongji’s campus, Nanjing at Ginling’s, Nanjing University at former Lingnan’s, and Hangzhou University is occupying the old Zhijiang campus. Historical monuments and old buildings might reveal to the living generation some facets of the forbidden past and arouse in the young minds a sense of curiosity. But the history of Christian education was a sensitive subject if not taboo in China for decades from the early 1950s to about 1980, a discrepancy in the minds of some old alumni and professors who still treasured their knowledge of the young because of deliberate omission and political suppression.
Christianity had been labeled by the Marxist-Leninists in the PRC as superstitious, unscientific, subjectivistic, and contrary to the progressive, materialistic and scientific doctrines of Marxism and Communism, and all endeavors of the Christian missionaries, including educational institutions, were seen as “cultural imperialism”. No wonder that the government would proceed immediately after 1949 to close down the Christian colleges and universities in an attempt to eliminate the cultural influence of Christian missionaries and Western countries. This was done through the reform in higher education carried out in 1952 during which all the Christian colleges and universities were either forced to be amalgamated or to be merged with other public universities and tertiary institutions. With this major reform all the private colleges in China became nationalized and not a single Christian or Catholic university could maintain its old curriculum or even its original name. Thus, we could pronounce, in 1952, the “death” of Christian higher education in China. Since that time onward, these Christian colleges and universities lived on only in the memory of their alumni and faculty staff. But even those people who were connected with the old institutions were reluctant to talk about their past. And in scholarship and in research these colleges and universities failed to draw any attention. During the period from 1953 to the end of the 1970s, there was not a single piece of research article or monographic study on these colleges, individually or as a collective entity. For decades before the Reform Era, Christian higher education had no place in China.
The Reform Era began with Deng Xiaoping after the death of Mao Zedong and the interim years of Hua Guofeng created more freedom in China not only in the field of economic development but also in the areas of thought, art, and culture.
Although the government leaders maintained that Marxism-Leninism and Mao Zedong Thought would remain the official doctrine, privately many intellectuals, professors and students at colleges and universities in general, were interested in intellectual freedom and promotion of different schools of thoughts: Western liberalism, Neo-Marxism, Post-modernism, among other ideas and theories. The yearning for new ideas and philosophies as a substitute of orthodox Marxism reached a high point in the middle of the 1980s, and this was referred to as the “Culture Fever” (wenhua fei) in China. During this period of intellectual ferment when Marxism-Leninism was rapidly losing its grip on the Chinese mind, not a few students were going to Christian schools for intellectual freedom and psychological solace. Some felt that Christianity could fill the void of a post-Marxist vacuum in faith, while others thought Christianity was the foundation of Western culture including the ideas of liberty, freedom, capitalist spirit and the democratic tradition. At any rate, there was a substantive growth in interest in Christianity, attracting more people to the churches and getting more young intellectuals into the new and emergent area of Christian studies which included the history of Christian missions and Christian education in China. Young scholars who had been involved in Chinese higher education in the mid-1980s have become leading experts in the field such as Shi Jinghuan of Beijing
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them and their families and the kind of life they were living, and what aspirations they have. This is an example of providing a framework in which research skill, academic study, reflection and experience can come together. And it leads me into my next point.
3. Comprehending complexity
We must help students understand the enormous complexity of this world, ways of thinking about it, and ways of collaborating with others to deal with complex issues. One thing that classroom in Jamaica taught “Joel” was how much it was inspired by the failures of globalization and policies and decisions made were made in palaces and meeting rooms far from this island.
Thomas Friedman in The Lexus and the Olive Tree reported a conversation with Murray Gell-Mann, the Nobel laureate and physicist, who said, “Here on earth, and it was formed, systems of power and complexity have arisen as a consequence of the physical evolution of the planet, biological evolution and human cultural evolutions. The process has gone so far that we human beings are now confronted with immensely complex ecological, political, economic and social problems…you have to break it up into pieces and study each aspect, and then study them very carefully.”
“We need people who can ‘study each aspect’ and the ‘strong interaction between them,’ who can simultaneously hold conflicting views, and understand the cultures of vastly different peoples. None of us alone can find the answers to the issues that are emerging from all the problems that beset the world. Coming together, we may have a chance.”
Students in unfamiliar cultures learn they cannot predict what will happen and must search for what lies beneath the surface. They can learn to identify connections between seemingly unrelated events, and to explore complex situations and how to anticipate the unexpected consequences of decisions and actions. Throughout this, they discover that they have to rely upon others and perhaps we can even structure their learning so that they are required to use a skill long employed in Asia, working in groups.
4. Reciprocal Responsibility
We must impress students with the necessity for being responsible in their own society and to the world’s societies. Why is this so important? Globalization is not enjoyed by everyone. In fact, the gap between the rich and the poor is growing. “The ratio of the average income of the richest country in the world to that of the poorest has risen from about 9 to 1 at the end of the nineteenth century to at least 60 to 1 today.”
In addition the world has gone through five major alterations and we are embracing on the sixth. The complexity of nature is unfathomable but we continue to tamper with it.
There are, as well, serious problems in phases of relative affluence. Within the last few years, there has been an effort to build shelters for the homeless in Osaka that would remove them from tents in the park. Homelessness and hunger are a serious problem throughout the world and poverty exists next to great prosperity in many parts of the world.
Just south of the border between Mexico and the United States, conditions for those who work for international corporations is deplorable. At one point, the Chief Executive of Alcoa was confronted with the reality when a Mexican employee, brooding over the annual shareholders meeting by Benedictine nuns, rose to speak of conditions at the Alcoa Fujikara Ltd. plants in Acuña, Mexico. The CEO was forced to listen and acted on what he heard. I would not claim that all problems have been resolved, far from it. While wages have been raised, crime remains the highest in the area, environmental and safety practices have improved, the cafeteria is no longer rationed. Local living conditions, however, are still squalid and public services, including schools and health care, are seriously deficient.
The world needs leaders who understand that there is only short-term economic gain in business without attention to the community in which it exists; corporate responsibility does not end at the front gate of industrial parks.
Many of the products we use are assembled from parts produced in diverse locations. Consumers reap the benefit of this global efficiency and must also bear the costs – the costs of environmental degradation, of the lack of sustainability, of child labor, of such costs as the vast collection of plastic in the Pacific ocean between Hawaii and Japan that is now called the Pacific Garbage Patch.
We must help students realize that the potential benefits of globalization cannot be fully realized until they are shared equitably. Globalization needs to be synonymous with responsibility if we are to serve the public good and maintain the viability of our planet and our species.
5. Culture care
Finally, we must teach students to value, respect and enjoy the cultural differences that exist among peoples and see them as a valuable resource.
One of the greatest fears about globalization is that we will all become a bland, uniform, global McDonald’s culture. Ronald Inglehart and Wayne Baker who have researched the values of 65 societies
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sity told me recently, “we are trying to connect the local to the global and to focus on how to help students engage in sustainable practices wherever they end up professionally.”
One other thing about this new world… it’s highly competitive and very busy. Recently I read that “time is becoming the world’s most precious commodity.” This sounds like an issue for corporations but I find this in all walks of life, including the academy.
Which brings me to my list of what the world needs and how we might respond. Have a list of five areas that are challenging:
Sustained compassion, right along with sustainability
Connected learning
Comprehension of complexity
Reciprocal responsibility
Culture care
1. Sustained compassion
We must help students who will be part of the future world to realize their capacity for sustained compassion. Most people respond to suffering outside their immediate community with momentary regret, helpless dismay, or dismissal (“I just can’t think about it”).
As much as people suffer in catastrophic events in many parts of the world, the lengthy period of rebound and recovery may be even harder than the initial response to such events. And the world stops watching because the media loses interest, and frankly so do we, after the initial impact and excitement of the event.
Mary Catherine Bateson writes, being compassionate “is as rare and valuable as the beings for which compassion is felt. Its sensitivities depend on picking out one pattern from the many and recognizing a kinship to it. To conserve and focus compassion, we often depend on single images…. One idea, one image, often one story is what sticks with us.
International education and service learning can provide those images and, more important, expose students to those who are victims of inequality, loss, and tragic circumstances and help students recognize that these, too, are our “kin.”
Consider another meeting Danny, a young blind man, who received $500 gift, a huge amount for someone eking out a living in a small store in one of the poorest barrios in Guayaquil, Ecuador. A student had been awarded the $500 for writing about his study abroad experience and sent it to the President of Children International in Ecuador, Victor Mariduena, to use where it would do the most good. Victor decided that it could build a small home for this young man and his mother. The student was in a service-learning program at the Children International Center in the neighborhood himself and stayed in place long after he had departed.
Something remarkable happened when the student returned to the gift took place: Several young, privileged Ecuadorian students who were there offered to build the house, getting help from their families and classmates. They got engaged because of this one young man who remembered and did something about it.
Sustained compassion doesn’t mean responding to every crisis and every tragedy. It means feeling a kinship with the conditions of others in the world, understanding how systems are often unable to sustain people like Danny, and doing what you can where you are.
One other thing about this new world… it’s highly competitive and very busy. Recently I read that “time is becoming the world’s most precious commodity.” This sounds like an issue for corporations but I find this in all walks of life, including the academy.
Which brings me to my list of what the world needs and how we might respond. Have a list of five areas that are challenging:
2. Connected Learning
The world needs people who have learned to connect experience with theory and how to apply that learning throughout their lives. This requires a way of “knowing” and a style of learning that moves beyond the highly compartmentalized and fragmented schooling that persists in much of higher education.
Victor Mariduena suggests that “To construct the world anew requires a lot of preparation and the removal of some of the debris existing at this moment. We have to remove barriers of prejudice, distrust, resentment, and selfishness.” They are all barriers to connected learning.
Students who are exposed to the differences within cultures, in terms of privilege, ethnic origin, sexual orientation and contrasting ways of living, can begin to deal with their own prejudice, resentment and ethnocentrism. They can see that stereotypes are often wrong or seriously inaccurate. They can see that cultures have great variations within them. They can discover how institutions can perpetuate poverty, prejudice, and helplessness.
However, this cannot be accomplished by sending them into new communities for a visit, it requires sustained and meaningful contact.
And it also means reciprocal learning: students who engage in service learning want to make a difference. We don’t want them to just take from their hosts or use their service location to achieve their own goals. It is important that they establish relationships and give something back. They must provide a service that is needed, as identified by their service location, no matter how much they may think it is not exactly what they would want to do. Forming relationships is very important because it is a way of truly appreciating, building respect, and developing empathy for the people they are serving and from whom they are learning.
I visited a classroom in Jamaica that had few books or other learning tools and is staffed with youngsters who attend in shifts. A student with the International Partnership for Service Learning, assisted the classroom teacher for half of each day. The other half of his day is spent in the university where his instructors provide intensive tutoring for his experience. His field assignment includes exploring how the educational system is structured and financed in Jamaica, the cultural attitudes toward education and how politics impacts the manner in which education is provided. He also learns about how these children live, he got to know sensitive subject area of Christian higher education.
Essentially there are only two explanations. One appeals to reason: that the area is significant in modern Chinese history, particularly in the context of modernization and education. Secondly, it appeals to emotion: alumni connections and the feelings of those who worked and lived in or were connected to the former Christian educational institutions. Many remembered those ‘good old days’ with fond memories. But for a long time during the late fifties and the entire period of Cultural Revolution these memories were suppressed. Not only suppressed but locked tightly in the forgotten chambers of the heart. It was “black material” or evidence of “tightist” or “imperialist” conspiracy and anti-revolutionary.
The suppression of memory had continued for a long time until the politica climate turned more relaxing and tolerant in the late seventies. This was the time when the old folks were encouraged to write their memoirs for the Wenhui Ziliao (Sources on literature and history) series. Some of the early essays in the Wenhui Ziliao volumes in fact were still very negative toward the Christian colleges and universities, condemning missionaries’ control and foreign influence over administration and curriculum, for example. However, as time passed, more and more writings appeared to be positive and nostalgic, with a lot of good things to say about the life and work at these schools. They were mainly writings by alumni and former staff members of these Christian colleges and universities. Many of them were in the ripe age of seventies or eighties when they re-initiated their memories. They were encouraged by the relaxing political atmosphere as well as by alumni gatherings, and often times their recollections and reminiscences were filled with nostalgia and emotions. The most representative of this kind of writing were the Yanda Wenhai Ziliao (Sources on Yenching University) in nine volumes published by the Alumni Association of the Yenching University in the mid-1980s and early nineties. Another example were the publications of the Alumni Association of the Ginling Women’s College such as Ginling Yue (Daughters of Ginling), Wu Yifang (Wu was president of the College), and other volumes. These essays and books are rather fragmentary and sentimental, but they nevertheless constitute an important body of literature for the study of the history of Christian higher education in the past.
THE FUTURE:
RECONNECTING AND RE VISIONING THE PAST
The twin forces of Reason and Passion have created an unprecedented opportunity for the study of the history of Christian higher education in China or simply Christian education in general. The
force of Reason: the scholars and historians are motivated by intellectual curiosity and academic interest. They are convinced that the Christian colleges and universities indeed had a significant role in China’s modern transformation, particularly in the area of higher education reform. The force of Passion refers to the efforts and sentiments of the alumni associations, friends and former staff connected with these Christian institutions. They realize that their time is running out and are anxious to tell their stories. Many of them have also been working hard to restore or reestablish the old programs or institutes, but so far no one has presented detailed for re-monitoring the system of Christian education.
The Yenching Alumni Association has been very active in demanding recognition and “partial restoration” of Yenching programs. The old Yenching campus however, has been taken over by Peking University, the leading national university in China since 1952. But since so many former Yenching graduates are now working with Peking University, should we not listen to them? The voice of the alumni could not be simply ignored.
Upon the repeated demands of the Alumni Association, the Peking University has set aside the former office of John Leighton Stuart near the Weiming Lake for the base of the Association where the alums meet regularly. The Association, staffed with mostly senior volunteers, has since produced nine volumes of the *Yanfu Wenshi Ziliao* (Sources on Yenching University). Bing Sun and Xiao Qian were the honorary chairpersons of the Standing Committee of the Association. The Association’s demand was partially met with the establishment of the Yenching Graduate Institute (YGI). The YGI was located at the Branch Campus of the Peking University in the city of Jieyang, with Professor Hou Renzi of Peking University, a renowned scholar and historical geographer who was also a Yenching graduate, as its honorary director. The YGI’s regular teaching and research programs are administered by Liu Wenlan, also a Yenching graduate of the 1930s. The YGI is an integral part of the Branch Campus of Peking University, and its programs in English, business, food science, computer science, Western civilization and religious studies are recognized by Beida. The YGI has a long-term cooperative relationship with the Professional and Educational Services International Inc. (PESI), a Christian organization based in North America who has helped in bringing into China professors and scholars (Westerners and Overseans Chinese) of a variety of disciplines to teach at YGI.
There are 42 members on the Standing Committee of the Board of Trustees, and 78 Trustees altogether.
Hou Renzhi serves as President of the Graduate Institute. He is assisted by six Vice Presidents: Xia Ziqiang, Ke Li, Liu Wenlan, Jiu Jiren, Jin Zongyan and Zhang Miaodi.
The re-established Ginling Women’s College is another case in point. The Ginling Women’s College, organized in 1992 by the Alumni Association of Ginling Women’s College, is now located on the campus of Nanjing Normal University. In 1987, a parcel of land was given to the Association for development into the Yi Fang Yuan or Wu Yifang Garden in remembrance of the former president of the college. Later several leaders of the Association also helped to start courses in English, accounting, food science and domestic science under the revived name of Ginling Women’s College. A research center on women studies was added to the college as an extended program of the Nanjing Normal University and the director of the center is holding a concurrent position as Nanjing Normal University’s associate professor.
There are other examples such as the South China Women’s College and the Lingnan Institute at Zhongshan University in Guangzhou, showing that the concerted efforts of alumni associations and former colleagues and students from these Christian universities of the past have contributed to the “partial restoration” of some of the institutions. These efforts were also significant in curricular change and in shaping government policies toward higher education in China especially in the area of private education.
**CONCLUSION**
In conclusion let me sum up my paper in several points:
- That Christian higher education has a long history in China, playing a significant role in China’s modern transformation;
- That the history of Christian higher education came to an end after the Communist takeover, and specifically it was a result of “nationalization” of education;
- That in recent years there are signs indicating that there has been an increasing interest in “restoring” or “re-establishing” Christian education in China. This was indicated by a surging interest in the study of the history of Christian colleges and universities and by the repeated demands of alumni association to restore certain old programs;
- That “reconstruction of Christian education” in China has much to do with “remembrance of the past”—the past serving as a moving force as well as a model for the educational endeavor at the present.
Finally I would like to rephrase the words of Dr Martin Luther King, Jr. to be included as an end-note for this paper:
“I have a dream that one day a new Christian university will stand on the Chinese mainland.
I have a dream that Chinese Christians, Hong Kong Christians, Western Christians, Asian Christians and other Christian communities in the world will join hands together in building this Christian university.
I have a dream that one day the sons and daughters of the Nationalists and the Communists, the children of Confucianists, Western educated liberals, and Chinese Marxists will sit side by side in the
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**Providing What the World Needs: Through Intercultural International Service-Learning**
Dr. Margaret (Peggy) Pusch
Associate Director, Intercultural Communications Institute
It is indeed a pleasure to be with all of you electronically although I confess that being with you physically would be much more satisfying. I truly regret that I am unable to travel right now. Over the years it has been a privilege to work with and come to know many people connected with CUAC and the United Board. I have been intrigued by, impressed with, and respected the work that you do at colleges and universities around the world as well as the values that you represent within higher education.
The theme of this speech came to me in the middle of the night most recently related to “Globalization.” As I was reminded, once again, that the world many of us are accustomed to living in no longer exists. The world our students will live in is hard for us to imagine and it is my profound belief that our job is to educate students to live in that world.
Let me begin by defining “globalization,” which is really a quick way of saying the world is a single market. However, it is not just about markets but about the public good and the need to emphasize that over private greed. Indeed, world trade is greater and involves more products and services than ever before in human history. The most significant difference between the global marketplace of the present and the past, however, is the ability to instantly transfer capital from one side of the planet to another. This can cause the loss of stability in some countries or provide incredible wealth in others but the shift in capital resources is immediate and not always benign.
The rapid transfer of information is another feature of globalization; we can find out about almost anything we wish with the click of a mouse. The World Wide Web allows ideas, as well as viruses, to spread, for good or for ill. We are in constant contact with friends, family, colleagues, and business associates, no matter what time zone they are in. I have associates who are always available by email but almost never by phone.
Which brings me to another condition of globalization, the constant flow of people engaged in some form of global activity. Airports are almost a metaphor for the world in which we live, a place where you are “in between” one location and another, where there is a mix of shopping mall and border crossing, where you are “suspended” and you clear security where the multicultural flow of travelers can offer instant companionship or melt into a faceless crowd, where personal dramas are often on display. Frequent flyers rarely talk with each other, unless there is an emergency or delay. They are busy with laptops, or trying to catch up with their sleep. Some spend almost as much time in the departure lounges and hotels as they do in their homes. Included in this flow are many of our students.
There is, however, a growing concern on the part of universities for community engagement. A recent report said the following:
“…community engagement is widely accepted as one of the core functions of … universities along with teaching and research. It nevertheless remains regarded by most higher education institutions as a moral rather than a strategic imperative, with few institutional returns, and so receives limited intellectual, managerial and financial resources … The term encompasses a range of activities such as community service, community development and service learning … the tide is turning in favor of community engagement. Demands for greater accountability, the rising role of technology in the ‘knowledge economy’ and trends in knowledge production, among other things, are obliging universities to rethink their public role and to develop more systematic approaches to community engagement.”
These programs are occurring in widely disparate places such as countries in Northern Europe, across Africa, in North and South America, and certainly right where you are all sitting in this conference—in Asia.
In addition, the goal of being a global university, or having an international orientation, is stated in the mission of many institutions and there are ongoing, sometimes successful, sometimes not, efforts to increase students’ competencies to be part of the global community. So, as an Associate Provost for International Programs at an American univer-
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Regulation of PD-1/PD-L1 pathway and resistance to PD-1/PD-L1 blockade
Jie Bai\textsuperscript{1}, Zhitao Gao\textsuperscript{1}, Xiang Li\textsuperscript{1}, Liang Dong\textsuperscript{1}, Weidong Han\textsuperscript{1} and Jing Nie\textsuperscript{1}
\textsuperscript{1}Department of Molecular Biology and Bio-Therapeutic, School of Life Science, Chinese PLA General Hospital, Beijing 100853, China
Correspondence to: Jing Nie, email: email@example.com
Weidong Han, email: firstname.lastname@example.org
Keywords: PD-1; PD-L1; resistance; epigenetic; tumor microenvironment
Received: September 30, 2017 Accepted: November 08, 2017 Published: November 25, 2017
Copyright: Bai et al. This is an open-access article distributed under the terms of the Creative Commons Attribution License 3.0 (CC BY 3.0), which permits unrestricted use, distribution, and reproduction in any medium, provided the original author and source are credited.
ABSTRACT
Immune checkpoint blockades, such as inhibitors against programmed death 1 (PD-1) and its ligand (PD-L1), have received extensive attention in the past decade because of their dramatic clinical outcomes in advanced malignancies. However, both primary and acquired resistance becomes one of the major obstacles, which greatly limits the long-lasting effects and wide application of PD-1/PD-L1 blockade therapy. PD-1/PD-L1 both regulates and is regulated by cellular signaling pathways and epigenetic modification, thus inhibiting the proliferation and effector function of T and B cells. The lack of tumor antigens and effective antigen presentation, aberrant activation of oncogenic pathways, mutations in IFN-$\gamma$ signaling, immunosuppressive tumor microenvironment such as regulatory T cells, myeloid-derived suppressor cells, M2 macrophages, and immunoinhibitory cytokines can lead to resistance to PD-1/PD-L1 blockade. In this review, we describe PD-1 related signaling pathways, essential factors contributing to the resistance of PD-1 blockade, and discuss strategies to increase the efficacy of immunotherapy. Furthermore, we discuss the possibility of combined epigenetic therapy with PD-1 blockade as a potential promising approach for cancer treatment.
INTRODUCTION
The “two-signal theory” of lymphocyte activation explains the mechanism of T cell activation or anergy when a naive T cell makes contact with an antigen [1, 2]. Accordingly, efficient activation of antigen-specific lymphocytes needs specific antigen recognition by lymphocytes and an additional signal. Later, it was found that coinhibitory signals also exist. Receptors eliciting coinhibitory signals function as immune checkpoints and have an essential status in the maintenance of peripheral tolerance and inhibition of autoimmunity [3–6].
The best-studied pathway of T-cell costimulation involves the B7-CD28-CTLA-4 superfamily, of which PD-1 and its ligands belong, revealed that the immune system has developed several coinhibitory pathways for T cell activation and tolerance [7–11]. Costimulation has been of therapeutic interest in cancer therapy because the augmentation of costimulatory signals could promote T cell activation to enhance antitumor immune responses [12]. With the discovery of CTLA-4 as an effective immune checkpoint, blockade of CTLA-4 was found to promote antitumor immune reactions and gain notable clinical effectiveness as cancer therapy [13, 14]. The understanding of cancer immunotherapy was modified and strategies for removing other coinhibitory signals to activate the immune system were widely investigated. The tumor immunotherapy targeting PD-1/PD-L1 has achieved encouraging therapeutic outcomes, with response rates of 20% to 40% in various cancer types [15]. Thus far, five immune checkpoint inhibitors targeting PD-1/PD-L1 have been approved by the US Food and Drug Administration, such as PD-1-blocking monoclonal antibodies (mAb) pembrolizumab and nivolumab, and PD-L1-targeted mAb
atezolizumab, avelumab, and durvalumab. Compared with anti-CTLA-4 mAb, immune-related toxicities induced by PD-1/PD-L1 blockade were much less frequent and the most frequently observed toxicity was fatigue [16, 17].
**PD-1 PATHWAY**
**Expression of PD-1 and PD-1 ligands**
PD-1 is expressed on activated CD4 and CD8 T cells, B cells, monocytes, natural killer (NK) cells, and dendritic cells (DCs) [18–21]. The expression of PD-1 on T cells can be induced by the common γ chain cytokines interleukin-2 (IL-2), IL-7, IL-15, and IL-21 [22]. PD-1 is encoded in the *Pdcd1* gene. Nuclear factor of activated T-cells cytoplasmic 1 (NFATc1) is a significant transcription factor, which promotes the PD-1 expression [23]. Other established transcriptional activators such as forkhead box O 1 (Foxo1), Notch proteins, and interferon regulatory factor 9 (IRF9) can also promote PD-1 transcription, and T-box transcription factor TBX21 (T-bet) functions as a transcriptional repressor [24–27]. During chronic viral infection, PD-1 expression is enhanced and maintained on exhausted virus-specific T cells to prevent their proliferation and function [28, 29]. CpG oligodeoxynucleotides treatment induced PD-1 expression in human CD19+ B cells [30]. Environmental hyaluronan fragments from hepatoma cells produced PD-1high regulatory B cells via TLR4 activation, during which TLR4-mediated Bcl-6 upregulation was critical [31]. Interferon (IFN)-sensitive responsive element (ISRE) and STAT1/2 regulate PD-1 expression mediated by IFN-γ in macrophages [32].
PD-L1 (B7-H1 or CD274) and PD-L2 (B7-DC or CD273) are the ligands of PD-1, which are type I transmembrane glycoproteins. There is approximately 40% of the same acidic identity between PD-L1 and PD-L2 whereas the similarity between PD-Ls and B7s is 20% [33, 34]. PD-Ls have different patterns of expression. The expression of PD-L1 constitutively exists on T and B cells, DCs, macrophages, mesenchymal stem cells, and bone marrow-derived mast cells [19]. PD-L1 is also expressed on a large-scale in nonhematopoietic cells such as lung, vascular endothelial, fibroblastic reticular, liver nonparenchymal, and mesenchymal stem cells, and pancreatic islets, astrocytes, neurons, and keratinocytes [20]. In contrast with PD-L1, PD-L2 expression is restricted to activated DCs, macrophages, bone marrow-derived mast cells, and over 50% of peritoneal B1 cells [35]. PD-L1 expression can be induced by γ chain cytokines IL-2, IL-7, and IL-15 on T cells, and IL-21 promoted PD-L1 expression on CD19+ B cells. LPS or BCR activation also stimulate the expression of PD-Ls on B cells [36–38]. Treatment of interferon-gamma (IFN-γ) or IL-10 results in the expression of both ligands in monocytes, and IL-4 and granulocyte macrophage colony-stimulating factor (GM-CSF) induce PD-L2 expression on DCs [39]. In tumor cells, the PD-1 and PD-1 ligands ligation mediates inhibitory signals to cause a harmful effect on antitumor immunity, resulting in the escape from immunosurveillance [40–42].
**The influence of epigenetic modification on PD-1 expression**
Epigenetic modification, including DNA methylation, histone methylation/acetylation, and microRNA regulation, also controls the expression of PD-1. During acute infection, CD8+ T cell differentiation from naïve T cells was accompanied by transient DNA demethylation at *Pdcd1* locus, which gained DNA methylation during further differentiation into functional memory T cells. In contrast, PD-1 promoter was dramatically demethylated in exhausted CD8+ T cells and imprinted during the effector phase of CD8 T cell exhaustion [43, 44]. In patients with chronic HIV, PD-1 promoter was demethylated in PD-1-high virus-specific T cells, and methylated in naïve, PD-1-low T cells from the same donors, while after anti-retroviral therapy, there is no remethylation of DNA at the PD-1 promoter, indicating that the poised epigenetic status for PD-1 remained after prolonged exposure to HIV virus [45]. Modifications to histone proteins also lead to changes in *Pdcd1* transcription. Enhancers are marked by histone H3 lysine 4 monomethylation (H3K4me1) and H3K27 acetylation (ac) at the “active” status [46], and other activation marks such as H3K9ac and H3K27ac were enriched at the promoter when PD-1 expression was induced on CD8 T cells *in vitro* [47, 48]. MicroRNAs also take a part in PD-1 expression. In the melanoma-bearing mice, the expression of PD-1 was attenuated after transfection with miR-28 mimic [49]. In immunocompetent murine models, miR-138 treatment of GL261 gliomas reduced the expression of PD-1, CTLA-4, and FoxP3 in T cells, promoting tumor regression [50]. Moreover, in lymphocytes from patients with chronic hepatitis B virus, transfection of miR-4717 mimics significantly decreased PD-1 expression in concert with increased tumor necrosis factor-α (TNF-α) and IFN-γ production [51].
**The PD-1 downstream signaling pathway**
The mechanism of how PD-1 inhibits T-cell receptor signaling is a focus of investigation. Beginning with recruiting SHP-2 (SRC Homology 2-Domain-Containingprotein Tyrosine Phosphatase 2) proximate to the T-cell receptor, PD-1 ligation inhibits the activation of T-cell receptor proximal kinases, resulting in depression of the phosphorylation of ZAP-70 mediated by Lck and initiation of downstream events [52].
The PI3K/Akt signaling is an important target of the PD-1 downstream pathway [53]. First, PD-1 can inhibit the activation of PI3K by recruiting SHP-2 [54]. As a serine-threonine phosphatase, PTEN inhibits the activation
of PI3K and suppresses the PI3K-Akt pathway signal transmission mediated by CK2. During T-cell activation, PTEN is phosphorylated by CK2 in the S380-T382-T383 cluster, resulting in PTEN stability and reducing PTEN phosphatase activity. PD-1 can target and inhibit CK2-mediated PTEN phosphorylation and promote its degradation while it induces PTEN phosphatase activity, thus repressing PI3K/Akt signaling [55–57].
The Ras/MEK/ERK pathway is another signaling pathway regulated by PD-1 [52, 53]. In T cells, the activation of RasGRP1 is critical for the activation of Ras and downstream MEK/ERK MAP kinase, and RasGRP1 is activated by calcium and diacylglycerol downstream of PLC-γ1 [58]. The activation of PLC-γ1 and Ras are inhibited by PD-1, resulting in diminished activation of the MEK/ERK pathway [53].
By similar mechanisms in B cells, PD-1 ligation with B-cell receptor (BCR) signaling results in SHP-2 recruitment to the ITSM tyrosine of PD-1, and inhibits BCR-mediated Ca$^{2+}$ mobilization and tyrosine phosphorylation of effector molecules, including Ig β, Syk, phospholipase C-γ2 (PLC-2), and ERK1/2 [59].
**RESISTANCE TO PD-1/PD-L1 BLOCKADE**
Immunotherapy has been viewed as one of the most promising methods for cancer treatment. Blocking of PD-1/PD-L1 interaction could overcome the counteraction and preserve the antitumor capacity of T cells to repress tumor cells [14, 15, 60]. Thus far, five PD-1/PD-L1 blocking mAbs have been approved by the U.S. FDA, and the superiority has been confirmed in over 15 cancer types [61]. Nevertheless, as compared to chemotherapy and molecular targeted therapy, a relatively higher rate of primary resistance with immune checkpoint inhibitors occurs and depresses the effectual clinical benefits. The efficacy of monotherapy for PD-1/PD-L1 blockade was rarely more than 40%, with a large proportion of partial responders [15, 62]. Moreover, after an initial response to PD-1/PD-L1 blockade, acquired resistance occurs in most patients, which leads to disease progression or relapse eventually.
The mechanisms of resistance are complex, dynamic, and interdependent. There are many tumor cell-intrinsic and -extrinsic factors relating to PD-1 blockade resistance, including PD-L1 expression, tumor neoantigen expression and presentation, associated cellular signaling pathways, tumor microenvironment (TME), related immune genes, and epigenetic modification (Table 1 and Figure 1).
**PD-L1 expression**
In Hodgkin’s lymphoma, frequent amplification of chromosome 9p24.1 that encodes PD-1 ligands PD-L1 and PD-L2 was observed, and the active JAK/STAT signaling further induced PD-L1/2 expression, which could be associated with the higher clinical response in Hodgkin lymphoma in response to PD-1/PD-L1 blockade [63]. In addition, genetic amplification of PD-L1/2 was positively correlated with high local immune cytolytic activity [64]. Other mechanisms to promote constitutive PD-L1 expression in cancer cells included PTEN deletions, PI3K and/or AKT mutations, EGFR mutations, MYC overexpression, CDK5 disruption, and an increase in PD-L1 transcripts stabilized by truncation of the 30 UTR of this gene [65–69]. It is currently undefined whether constitutive PD-L1 expression increases or reduces the sensitivity to PD-1/PD-L1 blockade therapy.
**Lack of tumor antigens and effective antigen presentation**
The most straightforward reason why tumors would not respond to PD-1/PD-L1 blockade therapy is lack of recognition by T cells because of absence of tumor antigens [70]. Human melanoma, renal cell carcinoma (RCC), and non small cell lung cancer (NSCLC) are highly immunogenic mutations, ranging from 5 to 10 per megabase of DNA in the range of individual cell mutations [15, 71]. This finding is consistent with the clinical results that these tumors are most sensitive to PD-1/PD-L1 blockade therapy [72, 73]. Poorly immunogenic tumors that tend to have between 0.1-1 somatic mutation per mega-base of DNA largely show no response to PD-1/PD-L1 blockade, such as in the pancreas and prostate [71]. Meanwhile, mutational load is also associated with efficacy in specific tumor types. In two groups of patients with NSCLCs, a higher burden of nonsynonymous somatic mutations in tumors was detected, which was related to better clinical response and longer survival [72].
Decrease in neoantigens is also an important mechanism for acquired resistance to immunotherapy. In T cell-dependent immunoselection, Elimination of neoantigens has been considered as a mechanism of cancer immunoediting in mice [74]. A recent study revealed that the evolution of neoantigen loss could augment acquired resistance as an escape mechanism after PD-1/PD-L1 blockade treatment. In the NSCLC relapsed patients after initial response, a loss of 7 to 18 putative mutation-associated neoantigens in resistant clones was observed in the analysis of protein coding genes of matched pretreatment and resistant cancers [75].
Moreover, cancer cells may also develop mechanisms to avoid antigen processing and presenting to the cell surface, via silencing or altering the expression of antigen-presenting machinery, beta-2-microglobulin (B2M), or MHC molecules [76, 77]. B2M plays an essential role in supporting MHC class I molecules to present tumor specific peptides to T cells. Dysfunctional mutations in B2M have been viewed as an important
| Mechanism | Description | Reference |
|---------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------|
| **PD-L1 expression** | PD-L1/2 expression could be associated with the higher local immune cytolytic activity and clinical response. The most straightforward reason why tumors would not respond to PD-1/PD-L1 blockade therapy is lack of recognition by T cells via the mechanisms such as absence of tumor antigens, loss of HLA expression, and Dysfunctional mutations in B2M. | [63–69] |
| **Lack of effective antigen presentation** | | [15, 70–78] |
| **Cellular signaling pathways** | | |
| PI3K/AKT pathway | Loss of PTEN-mediated PI3K/AKT activation significantly correlated with the decreased expression of IFN-γ, granzyme B, less CD8 T cell infiltration. | [79] |
| WNT/β-catenin pathway | Stabilization of β-catenin resulting in constitutive WNT signaling pathway could induce T cell exclusion from cancers. | [80] |
| JAK/STAT/IFN-γ pathway | Cancer cells could escape the effects of IFN-γ by downregulating or mutating molecules including IFNGR1/2, JAK2, and IRF1. | [81–88] |
| MAPK pathway | With the inducement of VEGF and IL-8, MAPK signaling has inhibitory effects on T cell recruitment and function. | [89–92] |
| **Tumor microenvironment** | | |
| Immunosuppressive cells | | |
| Exhaustion T cells | Disfunctional T cells and PD-1high phenotype exhaustion T cells cannot benefit from PD-1 blockade. | [94] |
| Tregs | Suppress effector T cell (Teff) responses by secretion of IL-10, IL-35, and TGF-β. | [95–101] |
| MDSCs | Promote angiogenesis, tumor invasion and metastasis. | [102–106] |
| TAMs | Higher frequencies of TAMs are associated with poor prognosis. | [41, 107–110] |
| Immunosuppressive cytokines | Often released by tumor or macrophages for local suppression of anti-tumor immune responses, including TGF-β, CCL5, CCL7, CXCL8, IDO, etc. | [111–118] |
| Inhibitory receptors | Apart from PD-1, over-expression of multiple inhibitory receptors including TIM3, CTLA4, LAG3 and BTLA is associated with inhibition of T-cell function and resistance to PD-1/PD-L1 blockade therapy. | [119, 120] |
| **Immune related genes** | | |
| IPRES signatures | Within TME, co-enrichment of a group of 26 transcriptomic signatures (named IPRES signatures) was also related to primary resistance to PD-1/PD-L1 blockade. | [121] |
| **Epigenetic modification** | | |
| DNA methylation and histone acetylation | Epigenetic modification may lead to changes in immune-related genes expression to impact antigen processing, presentation, immune evasion and T cell exhaustion, and DNA methyltransferase inhibitors and histone deacetylase inhibitors can reverse immune suppression via several mechanisms. | [122–134] |
mechanism of tumor resistance to T cell-mediated immune responses and lead to resistance to immunotherapy [78].
**Cellular signaling pathways**
The aberrant cellular signaling transduction is also a central factor contributing to the resistance to immunotherapy, such as PI3K/AKT pathway, WNT/β-catenin pathway, JAK/STAT/IFN-γ pathway, and mitogen-activated protein kinase (MAPK) pathway.
Oncogenic PI3K/AKT pathway has been proved to be associated with primary resistance to PD-1/PD-L1 checkpoint inhibition. PI3K/AKT signaling controls a variety of cellular processes including apoptosis, proliferation, motility, and metabolism, and contributes to tumor development and progression. Tumor suppressor PTEN, a lipid phosphatase, suppresses the activity of PI3K, and the loss of PTEN-mediated PI3K/AKT activation has been observed in many tumor types. In the Cancer Genome Atlas melanoma dataset, PTEN loss significantly correlated with the decreased expression of IFN-γ, granzyme B, less CD8 T cell infiltration, and further correlated with resistance to immune checkpoint therapy. In mice, the effectiveness of either PD-1/PD-L1 blockade or anti-CTLA4 mAb was enhanced by treatment.
**Figure 1:** The factors that lead to resistance to PD-1 blockade include PD-L1 expression, tumor neoantigens expression and presentation, cellular signaling pathways (PI3K, WNT, IFN-γ, MAPK), tumor microenvironment (TME) (exhausted T cell, Treg, MDSC, TAM, other chemokines), and related immune genes (IPRES). The inhibitors against target molecules are indicated, which could enhance antitumor responses in mouse models when combined with PD-1/PD-L1 blockade.
with a selective PI3K inhibitor [79]. Whether the PI3K/AKT inhibitors would reverse the resistance to immune checkpoint blockade needs further clinical study.
In addition to the loss of PTEN, the potential of oncogenic signaling pathways to induce T cell exclusion from cancers has also been described through the stabilization of β-catenin resulting in constitutive WNT signaling pathway [80]. In a murine model, tumors with elevated β-catenin lacked a subset of CD103+ dendritic cells (DCs), due to decreased expression of CCL4, a chemokine that attracts CD103+ DCs. In addition, murine tumors lacking β-catenin responded effectively to immune checkpoint therapy whereas β-catenin-positive tumors did not. Non-T cell-inflamed human melanoma, which lacks T cells and CD103+ DCs in the tumor microenvironment, had significantly higher expression of tumor intrinsic β-catenin signaling genes. Therefore, cancer immune evasion and resistance to PD-1/PD-L1 blockade therapy could result from some crucial oncogenic signals, which might be new candidate targets for immune potentiation.
The IFN-γ pathway is emerging as a key player in primary, adaptive, and acquired resistance to checkpoint blockade therapy [81–83]. It has both favorable and detrimental effects on anti-tumor immune responses. Interferon-γ produced by tumor-specific T cells that have recognized their cognate antigen on cancer cells or APCs induces an effective anti-tumor immune response. However, continuous IFN-γ exposure can lead to immunoediting of cancer cells, resulting in immune escape [84, 85]. One mechanism by which cancer cells could escape the effects of IFN-γ is by decreasing the expression or mutations in molecules in IFN-γ signaling pathway, which goes through the IFN-γ receptors JAK1 and/or JAK2 and the signal transducer and activators of transcription (STATs) [86]. Analysis of tumors in patients who did not respond to therapy with the anti-CTLA-4 antibody ipilimumab revealed an enriched frequency of mutations in the IFN-γ pathway genes IFN-γ receptor 1 and 2 (IFNGR1 and IFNGR2), JAK2, and interferon regulatory factor 1 (IRF1) [81]. Any of these mutations would prevent signaling in response to IFN-γ and give an advantage to the tumor cells escaping from T cells, thereby resulting in primary resistance to anti-CTLA-4 therapy, and may also be a reason for the resistance to PD-1/PD-L1 blockade therapy. Mutations in this pathway would additionally result in lack of PD-L1 expression upon IFN-γ exposure, thereby resulting in cancer cells that would be genetically negative for inducible PD-L1 expression. In such a condition, blocking PD-L1 or PD-1 with therapeutic antibodies would not be useful, and these would be patients who are primarily resistant to PD-1/PD-L1 blockade therapy [87, 88].
The MAPK pathway plays an essential role in cell proliferation, and hyperactivation of MAPK signaling might also be related to the resistance to immunotherapy. With the inducing of VEGF and IL-8, MAPK signaling has inhibitory effects on T cell recruitment and function [89]. Inhibition of MAPK pathway promoted CD8+ T cell activation and infiltration, and induced the expression of tumor antigens as detected in human melanoma samples; in addition, acquired resistance to MAPK-targeted therapy was correlated with depletion of intratumor T cells, exhaustion of CD8 T cells, and loss of antigen presentation [90, 91]. Moreover, the combination of PD-1 blockade and short-term dual inhibition of BRAF and MEK could enhance tumor immune infiltration and improved tumor regression, suggesting that a nongenomic mechanism of MAPK inhibitor resistance might mediate cross-resistance to PD-1/PD-L1 blockade therapy [92].
**Tumor microenvironment**
Tumor cells closely interact with the stromal cells, immune cells, and extracellular in the immunosuppressive TME, protecting tumor cells from being detected and eradicated by immunosurveillance [93]. Within the TME, other than tumor cells, components that might be associated with primary or acquired resistance include exhausted T cells, Tregs, myeloid derived suppressor cells (MDSCs), M2 macrophages, and other inhibitory immune checkpoints and cytokines.
T cell exhaustion is manifested by dysfunction, sustained expression of inhibitory receptors, and different transcriptional status with functional effector or memory T cells. Exhausted CD8 T cells with intermediate expression of PD-1 can benefit from PD-1/PD-L1 blockade, whereas the severely exhausted CD8 T cells with PD-1\textsuperscript{high} phenotype cannot benefit even impair the efficacy [94]. Thus, the ratio of partially exhausted PD-1\textsubscript{intermediate} CD8+ T cells to severely exhausted PD-1\textsuperscript{high} CD8+ T cells might be a critical factor for the reversal of T cell exhaustion by PD-1/PD-L1 blockade.
Tregs are known to suppress effector T cell (Teff) responses by secretion of certain inhibitory cytokines, such as IL-10, IL-35, and transforming growth factor beta (TGF-β) [95–97]. \textit{In vivo} studies have shown that depletion of Treg cells from the TME can strengthen the anti-tumor immune response [98–100]. Moreover, response to PD-1/PD-L1 blockade therapy was shown to be associated with increased ratio of Teff to Treg [101]. These data suggest that tumors without an increase of Teff and decrease of Treg following immunotherapy might be resistant to the treatment.
Myeloid-derived suppressor cells (MDSCs) have been considered as major regulators of immune responses in various pathological conditions. MDSCs could promote angiogenesis, tumor invasion, and metastasis [102]. Clinical findings have pointed out that the presence of MDSCs may be related to short survival in human cancers, such as breast and colorectal cancer [103]. Furthermore, the presence of MDSCs in TME contributed to decreased efficacy of immunotherapies, including immune
checkpoint blockade [104]. In various tumor-bearing mice models, selective inhibition of MDSC by using PI3K inhibitors enhanced expression of proinflammatory cytokines and inhibited immunosuppressive factors, synergized with immune checkpoint inhibitors to promote tumor regression [105, 106]. These studies highlight inhibitors of PI3Ka as a potential therapeutic target for combination strategies with PD-1/PD-L1 blockade therapy.
Tumor-associated macrophages (TAMs) are another subset of cells that influence the responses to immunotherapy. TAMs include M1 macrophages, which are involved in promoting anti-tumor immunity, and M2 macrophages, which possess pro-tumorigenic properties [107]. Clinical studies have identified an association between higher frequencies of TAMs and poor prognosis in human cancers [108]. In a lung adenocarcinoma mice model, depletion of TAMs inhibited tumor growth as a result of decreased M2 TAM recruitment, possibly due to the inactivation of CCL2 and CCR2 signaling [109]. Reports suggest that macrophages can directly suppress T cell responses through PD-L1 in hepatocellular carcinoma [41]. To overcome the potential resistance of macrophages, blocking of CSF-1R, a receptor for macrophage colony-stimulating growth factor, in a pancreatic cancer-bearing mice model, decreased frequencies of TAMs, with subsequent increase in interferon production and tumor rejection. Importantly, CSF-1R blockade in combination with antibody against PD-1 or CTLA-4, in addition to gemcitabine, led to strengthened tumor regression [110].
Immunosuppressive cytokines are often released by tumor or macrophages for local suppression of anti-tumor immune responses. TGF-β plays an important role in immunosuppression by stimulating Tregs [111]. Increased TGF-β is associated with poor prognosis in multiple cancer types [112]. A preclinical study on radiation therapy combined with TGF-β inhibitor showed anti-tumor responses [113]. In addition, specific chemokines and chemokine receptors play a necessary role in trafficking of MDSCs and Tregs into tumors. For example, tumor secrete ligands CCL5, CCL7, and CXCL8, bind to their receptors CCR1 or CXCR2 expressed on subtypes of MDSCs, and attract MDSCs in the tumor microenvironment. Inhibitors of these chemokine receptors could abrogate immune evasion and improve anti-tumor T cell responses [114].
Indole 2,3-dioxygenase (IDO), which can be produced by tumors or immune cells, could improve the generation and activity of Tregs and MDSCs [115, 116]. IDO, as a rate-limiting enzyme, influences the catabolism of tryptophan, producing immunosuppressive metabolites to inhibit the proliferation of T cells and induce T cell anergy and apoptosis [117]. Holmgaard et al. found a marked delay in B16 melanoma tumor growth and increased overall survival in IDO knockout mice as compared with wild-type mice when treated with anti-CTLA-4/PD-1 antibody [118]. Based on the study, the combination of IDO inhibitors and PD-1/PD-L1 blockade may lead to more efficacious therapeutic anti-tumor immunity than applying the individual agent.
The immune response is dynamic, and the expression of immune molecules is fluctuated. Other than PD-1, overexpression of multiple inhibitory receptors such as T-cell immunoglobulin mucin 3 (TIM3), CTLA4, lymphocyte activation gene 3 (LAG3), and B and T lymphocyte attenuator (BTLA) is associated with inhibition of T-cell function and hamper to PD-1/PD-L1 blockade [119, 120]. Moreover, a recurrent tumor after PD-1/PD-L1 blockade treatment might be the result of increased expression of TIM-3 on T cells. Notably, preclinical studies showed that PD-1/PD-L1 blockade plus anti-TIM-3 led to improved responses in the tumor-bearing mice. Based on the fact that when one immune checkpoint is blocked, the other immune checkpoints may be induced, and hence, combination of PD-1/PD-L1 blockade with other immune checkpoint inhibitors may promisingly enhance antitumor responses.
**IPRES signatures**
IPRES signatures, a set of 26 transcriptomic signatures, were found co-enriched to improve resistance to PD-1/PD-L1 blockade in tumors form nonresponding melanoma patients and the upexpression of IPRES related to the regulation of mesenchymal transition, cell adhesion, extracellular matrix (ECM) remodeling, angiogenesis and wound-healing [121]. The confirmation of IPRES co-enrichment in other independent tumor such as pancreatic adenocarcinoma indicates a transcriptomic program among different type of cancers and it may be a new way to enhance the efficacy of PD-1/PD-L1 blockade by inhibit the IPRES relevant biological processes.
**Epigenetic modification**
Epigenetic modification in cancer cells may lead to changes in gene expression of immune-related genes, which can affect antigen processing, presentation, immune evasion, and T-cell exhaustion [122, 123]. Epigenetic modifying agents, DNA methyltransferase inhibitors and histone deacetylase inhibitors can reverse immune suppression via enhancing the expression of tumor-associated antigens, costimulatory molecules, components of antigen processing and presenting, other immune-related genes and chemokines [124, 125]. In addition, the low-dose DNA demethylating agent decitabine could directly promote T cell activation and cytolytic capacity with increased frequency of IFN-γ-expressing T cells [126]. Based on these findings, it is probably that epigenetic modification may ‘prime’ the host immune response for subsequent immunotherapy in combination therapy [124, 127, 128], and the efficacy of the combined strategy has been confirmed in both clinical studies and
animal models [129–131]. Furthermore, immune priming by epigenetic therapy has been observed in combination with immune checkpoint inhibitors [132, 133]. Recently, it has been revealed that T cell exhaustion is associated with *de novo* DNA methylation, which can persist and be passed on to successive generations of T cells, whereas inhibition of DNA methylation by decitabine could reverse the exhausted state and promote T-cell rejuvenation [134]. These results establish a highly promising strategy for combination treatments by using epigenetic modifying agents and immune checkpoint blockade in cancer patients.
**Hyperaggressive disease with anti-PD-1/PD-L1 therapy**
Besides primary and acquired resistance to immunotherapy, it was recently reported that PD-1/PD-L1 blockade might develop “hyperprogressive disease” in some patients, which means accelerated tumor growth after anti-PD-1/PD-L1 inhibitors [135]. A trial of 131 patients with PD-1 blockade therapies reported that 12 patients (9%) were considered as hyperprogressive disease; moreover, the hyperprogressive status seemed to be more common in elder patients over 65 year old [136]. Kurzrock et al reported that 6 patients out of 155 had extra copies of *MDM2* or *MDM4* genes and experienced time-to-treatment failure (TTF) of less than 2 months after immune checkpoint blockade therapy. Among these 6 patients, 4 patients developed hyperprogressive disease. In addition, patients with mutations in *EGFR* were also likely to experience short TTF and cause hyperprogressive disease [137]. Thus, exploring the mechanisms of resistance and hyperprogressive status to PD-1/PD-L1 blockade is particularly crucial. Actually, there is still not enough evidence to confirm that the accelerated tumor growth is pinned on immunotherapy, the hyperprogressive status could only occur with PD-1/PD-L1 blockade therapy in certain patients.
**PROSPECTIVE**
PD-1 has now been proved to be an important checkpoint inhibitory receptor that impacts the T-cell stimulation, differentiation, and anti-tumor immune function. Both primary and acquired resistance to anti-PD-1/PD-L1 antibodies inspired us to investigate novel strategies to augment the efficiency of PD-1/PD-L1 blockade. First, radiotherapy, chemotherapy, epigenetic therapy, and other immune stimulatory agents combined with PD-1/PD-L1 blockade could enhance the sensitivity of immunotherapy in tumors with low immunogenicity. Second, modulating the immunosuppressive tumor microenvironment and breaking the inhibitory status, such as depletion of Tregs, interference with the suppressive cytokines, and silencing of co-inhibitory receptors could also help increase the therapeutic responses of PD-1/PD-L1 blockade. Third, further understanding and exploring the mechanisms of both the upstream regulators of PD-1 and its downstream biological events and targets will be necessary for the design of combination therapies, to illuminate the resistance mechanisms, and identify the reliable predictive biomarkers of PD-1/PD-L1 blockade. Last, with the progress made in human genome sequencing and bioinformation analysis, detection and understanding of the patients’ genetic and epigenetic information of tumors and immunocytes will help establish individualized immunotherapy, to obtain clinical benefits for more patients.
**CONFLICTS OF INTEREST**
No potential conflicts of interest are disclosed.
**FUNDING**
This study is supported by the grants from the National Key R&D Program of China (2016YFC1303504 and 2016YFC1303501 to WDH), National Natural Science Foundation of China (31671338, 81472838 and 81650025) and Science and Technology Planning Project of Beijing City (Z151100003915076).
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A study of neural-related microRNAs in the developing amphioxus
Candiani et al.
BioMed Central
Candiani et al. EvoDevo 2011, 2:15
http://www.evodevojournal.com/content/2/1/15 (1 July 2011)
A study of neural-related microRNAs in the developing amphioxus
Simona Candiani*, Luca Moronti, Davide De Pietri Tonelli, Greta Garbarino and Mario Pestarino
Abstract
Background: MicroRNAs are small noncoding RNAs regulating expression of protein coding genes at post-transcriptional level and controlling several biological processes. At present microRNAs have been identified in various metazoans and seem also to be involved in brain development, neuronal differentiation and subtypes specification. An approach to better understand the role of microRNAs in animal gene expression is to determine temporal and tissue-specific expression patterns of microRNAs in different model organisms. Therefore, we have investigated the expression of six neural related microRNAs in amphioxus, an organism having an important phylogenetic position in terms of understanding the origin and evolution of chordates.
Results: In amphioxus, all the microRNAs we examined are expressed in specific regions of the CNS, and some of them are correlated with specific cell types. In addition, miR-7, miR-137 and miR-184 are also expressed in endodermal and mesodermal tissues. Several potential targets expressed in the nervous system of amphioxus have been identified by computational prediction and some of them are coexpressed with one or more miRNAs.
Conclusion: We identified six miRNAs that are expressed in the nervous system of amphioxus in a variety of patterns. miR-124 is found in both differentiating and mature neurons, miR-9 in differentiated neurons, miR-7, miR-137 and miR-184 in restricted CNS regions, and miR-183 in cells of sensory organs. Therefore, such amphioxus miRNAs may play important roles in regional patterning and/or specification of neuronal cell types.
Background
MicroRNAs (miRNAs) are a large class of non-coding RNAs involved in post-transcriptional regulation. They were first discovered in nematodes and subsequently found to be widely distributed in plants and animals [1-4]. miRNAs are 18 to 24 nucleotides long and regulate translation by binding to the respective mRNA transcripts, either inducing mRNA degradation or directly inhibiting translation. In animals, miRNAs bind to specific bases in the 3' untranslated regions (UTR) of mRNA targets [5]. Each miRNA can regulate translation of several genes and modulate many biological processes such as developmental timing, cell proliferation, cell death, Hox gene expression and early embryogenesis [6]. miRNAs play also important roles in stem cell biology, furthermore altered miRNA functions have been implicated in a number of human disorders and cancers [7].
In particular, miRNAs are known to regulate translation of a number of genes involved in development of the central nervous system (CNS) [8-10].
miRNAs are to a large extent evolutionarily conserved. The basal chordate amphioxus has 115 miRNA families, 55 of which are homologous to those of vertebrates [11-13]. Amphioxus has a prototypical chordate genome with a high degree of synteny with vertebrate genomes [14,15], and a body plan that is also similar to that of vertebrates. Although the amphioxus CNS has comparatively few neurons—an estimated 20,000 in the adult [16] and lacks a neural crest [17], the basic organization of the amphioxus CNS is comparable to that in vertebrates. Comparisons of gene expression and mapping of neurons and their connections have indicated that the amphioxus CNS consists of a diencephalic forebrain (the telencephalon is lacking), a small midbrain, a hindbrain and spinal cord [18,19]. The forebrain and small midbrain are together termed the cerebral vesicle. Thus, the most anterior photoreceptor (the frontal eye) is thought to be homologous to the vertebrate paired eyes,
the lamellar body in the dorsal part of the amphioxus diencephalon is considered to be homologous to the vertebrate pineal complex, and secretory cells in the floor of the diencephalon are thought equivalent to the vertebrate infundibulum which produces Reissner's fiber [19]. In addition to the frontal eye, there are many other photoreceptors in the amphioxus CNS. Those developing in the hindbrain and spinal cord, called the organs of Hesse, are rhabdomeric or microvillar photoreceptors, while those in the forebrain, except for the Joseph cells, are ciliary photoreceptors. The organs of Hesse and the frontal eye consist of pigment cells containing melanin together with one or more photoreceptive neurons. However, the lamellar body, a ciliary photoreceptor, and the Joseph cells, which are rhabdomeric photoreceptors located in the posterior part of the cerebral vesicle, are not associated with pigment cells. The first photoreceptor to develop is an organ of Hesse in the middle of the hindbrain. The second is the frontal eye [20]. About the same time that the first organ of Hesse forms, at the early to mid-neurula, two rows of motor neurons also differentiate. Not surprisingly, the larvae are positively phototropic from the mid-neurula stage and begin muscular movements at the late neurula stage.
Gene expression is quite similar in the CNS of both amphioxus and vertebrates. Not only is the expression of genes involved in rostro-caudal patterning such as *Otx*, *Hox* and *Gbx* highly conserved [21-23], but also the expression of genes involved in the neuronal specification. For example, the *ERR*, *islet*, *Shox*, *Krox*, *Mnx* genes are expressed in developing motor neurons in both amphioxus and vertebrates [24-27]. However, it is not known whether expression of miRNAs is similar in the amphioxus and vertebrate CNS. In vertebrates, several miRNAs are expressed in specific brain regions or specific types of neurons suggesting their involvement both in development and function of the nervous system [8]. For example, in *Xenopus*, miR-124 is expressed in the optic vesicle and forebrain, where it negatively regulates *NeuroD1* [9]. In the mouse brain, miR-124 seems to be largely restricted to differentiating and mature neurons [28], while miR-124 is expressed in neural progenitors [10,28]. Its expression appears to be controlled by a neuron restricted transcriptional repressor (REST/NRSF), which inhibits miR-124 expression in both nonneuronal cells and neural progenitors [29]. A second miRNA, miR-9, is also specifically expressed in proliferating neural precursors in both zebrafish embryos [30,31], and in mouse embryos and adults [28,32], while miR-7 and miR-184 are expressed in several types of brain tumors, suggesting a function in cell proliferation [33-36]. In addition, miR-137 has been implicated in proliferation of neural stem cells [37,38], while mir183 is expressed in hair cells in the vertebrate ear [39,40].
For amphioxus, there is only a single study of miRNA expression, which showed that two miRNAs (miR-133 and miR-1) are expressed in the developing muscular somites of amphioxus [13]. Therefore, to gain insights into the evolution and function of miRNAs during amphioxus neural development, we determined expression of six miRNAs (miR-124, miR-9, miR-7, miR-183, miR-184 and miR-137) in two species of amphioxus, *Branchiostoma floridae* and *B. lanceolatum*. All six miRNAs are known to be expressed exclusively or preferentially in the nervous systems of vertebrates and/or other species. Our results show that all six miRNAs are expressed in specific regions of the CNS of amphioxus, many of which can be correlated with cell types identified by microanatomical studies [20,41-43]. In addition miR-7, miR-137 and miR-184 are also expressed in endodermal and mesodermal tissues. Together with analysis of potential miRNA targets, these results give insights into the regulation of neurogenesis in amphioxus.
**Results**
We found that all six miRNAs are expressed in the amphioxus CNS, although miR-7, miR-184 and miR-137 are also present in a strikingly broad spectrum of developing tissues derived from mesoderm and endoderm, while miR-183 is also expressed in some ectodermal sensory cells of the peripheral nervous system (PNS).
**miR-124 expression during amphioxus development**
In both *B. floridae* and *B. lanceolatum*, the earliest miR-124 expression appears in 14 h mid-neurulæ in a periodic pattern of cells on each side of the midline adjacent to the first five somites (Figure 1A, B). As development proceeds, expression is visible in two longitudinal rows of labeled nerve cells beginning at the posterior cerebral vesicle (cv) and extending to the hindbrain (Figure 1C, D). Plastic sections of the same embryos show that such cells are preferentially lateral and ventrolateral (Figure 1F-I) except for a few neurons in the floor plate and adjacent to the pigment cell of the first photoreceptor to form (Figures 1 H). In later larvae (three to four gill slits), expression of miRNA expands anteriorly into the cerebral vesicle, but does not reach the anterior-most portion at any stage examined (Figures 1 J-M and 2A, B). In particular, two areas of the cerebral vesicle express miR-124: one in the middle and the second in the posterior half of the cerebral vesicle (Figure 2B). Cross sections at different levels of the nervous system showed that most labeled cells are in the ventro-lateral neural tube (Figure 2D, E and 2H) whereas very few labeled cells were located in the dorsal wall (Figure 2F). Expression in the
two rows of ventro-lateral cells also expands posteriorly into the spinal cord during larval development (Figure 2 A-H). This is in agreement with the pattern of neurogenin, which initially labels neurons anteriorly in the CNS with the pattern moving posteriorly as development proceeds.
**miR-9 expression in late larval stage of amphioxus *B. floridae***
miR-9 expression was never detected in embryos or very early larvae of both *B. floridae* and *B. lanceolatum*, in contrast to the situation in vertebrates [30,31]. Instead, miR-9 expression appears only later in larvae (three to four gill slits) (Figure 2I). Here, we show miR-9 expression exclusively in the *B. floridae*. miR-9 is expressed in scattered cells throughout the neural tube except at the most anterior part of the cerebral vesicle where the frontal eye has just formed (Figure 2J). Just posterior to the frontal eye, we observed miR-9 transcripts in a very few dorsal cells of the cerebral vesicle (Figure 2L). The miR-9 labelled cells cannot be the same as those expressing miR-124, because the former are organized as segmental blocks of cells (Figure 2K, O), while the latter, although segmentally arranged at an early stage, are no longer segmentally arranged in the larva (Figure 2B, C, G). Moreover, transverse sections...
Figure 2 Comparison between miR-124 and miR-9 expression at late larval stage of *B. floridae*. Anterior to the left. Cross section scale bars are 25 μm. **A, I**: Side views of larvae with three to four gill slits. Scale bars: 250 μm. **B, J**: Anterior enlargement of specimens in A and I, respectively. Scale bars: 50 μm. **C, K**: Enlarged view of the neural tube of specimen in A and I at level of three dorsal ocelli (the first dorsal ocellus appearing during the development and located near the somite 5 is shown by arrows, the most anterior ones are indicated by arrowheads. Each differing from the first dorsal ocellus in being bicellular associations between a single neuron and a single pigment cell). Scale bars: 50 μm. **D**: Cross section through level d in B. **E, F**: Cross sections through levels e and f in C. **L, M**: Cross section through levels l and m in J. **N**: Cross section through level n in K. **G, O**: Detail of specimens in A and I at levels of the first dorsal ocellus (arrows). Scale bars: 50 μm. **H, P**: Cross sections through levels h and p in G and O, respectively.
clearly demonstrate that miR-9 expressing cells are mainly in the ventral midline of the neural tube (Figure 2M, N, P), while those of miR-124 are more lateral (Figure 2D-F, H).
**miR-7 expression in amphioxus**
Unlike miR-124 and miR-9, expression of miR-7 is not limited to the CNS. The first miR-7 expression appears at the late neurula stage (20 to 22 hours after fertilization) as a weak signal in the ventral portion of the cerebral vesicle (Figure 3A, J). At the late neural stage, miR-7 transcripts were also found in the most anterior end of the pharyngeal endoderm (Figure 3A) from which Hatschek's left anterior diverticulum, also known as the preoral organ or Hatschek's pit (a putative homolog to the vertebrate adenohypophysis), will originate. In the early larva, miR-7 is detectable in almost the entire ventral portion of the cerebral vesicle including the photoreceptors of the frontal eye (Figure 3B-E, 3I, J). Finally, a restricted expression was also observed in Hatchek's pit (Figure 3C, F, G, J).
**miR-183 expression in amphioxus larvae**
miR-183 expression is largely restricted to the CNS, but it is also expressed in some likely ectodermal sensory cells in the anterior end of the larva. The expression of miR-183 starts from the larval stage and it does not differ substantially between *B. lanceolatum* and *B. floridae* at 72 hr of development (Figure 4). Strong expression was detected in two groups of epidermal cells in the rostrum: the first is confined to the most anterior tip (Figure 4A, B, D, G, H), and the second is localized in the ectoderm anterior to the cerebral vesicle and adjacent to the notochord (Figure 4C, E, G, H), approximately where an anterior sense organ (the corpuscles of de Quatrefages) will later develop [44]. miR-183 was also found in some dorsolateral cells on either side of the posterior cerebral vesicle (Figure 4A, B, F-H). At least some of these cells are located approximately where the lamellar organ is developing. Finally, a few scattered cells expressing miR-183 were also found in the CNS posterior to the cerebral vesicle (Figure 4A, G, H).
**Figure 3** miR-7 expression in *B. lanceolatum* and *B. floridae*. Anterior to the left and dorsal up in all whole mounts. Cross-sections are viewed from the anterior end of animal. Scale bars are 50 μm for whole mounts and 25 μm for cross sections. **A**: Side view of 22-h neurula. Expression is restricted to the cerebral vesicle (cv) and anterior pharyngeal endoderm (arrow). **B**: Side view of a first gill slit larva. **C**: Higher magnification of the anterior end of larva in **B**. Expression is observed in cerebral vesicle and preoral pit (arrow). **D**, **E**: Cross sections through levels d and e in C show several ventrolateral labeled cells of the anterior cerebral vesicle (arrowheads). **F**, **G**: Cross sections through levels f and g in C show miR-7 expression in cells of preoral pit (arrows). **H**: Side view of 20-h neurula showing expression in the cerebral vesicle. **I**: Side view of a three gill slit larva. **J**: Anterior enlargement of the anterior end of the specimen in I. miR-7 is expressed in cells of the frontal eye complex and in further regions of cerebral vesicle (cv). A strong signal was also found in the preoral pit (arrow). Arrowhead in C and J points to pigment spot associated with frontal eye.
**miR-184 expression in amphioxus**
mir-184 is expressed very early during development in both *B. floridae* and *B. lanceolatum* (Figure 5). It is ubiquitously expressed in two-cell embryos (Figure 5A, K). By the 16-cell stage, expression is limited to the vegetal blastomeres (Figure 5B, L), although in the early blastula, it is also expressed, albeit at a lower level, in the animal blastomeres (Figure 5C, M). At the gastrula stage, mir-184 is expressed throughout the presumptive neuroectoderm and at a higher level throughout the mesendoderm (Figure 5D, N). At the early (Figure 5O) and mid-neurula stages (Figure 5E, P), we detected expression in the entire neural tube, somites and posterior endoderm. This pattern is also maintained at the late neurula stage (Figure 5F–H), where miR-184 transcripts are evident in the cerebral vesicle (Figure 5G), somites (Figure 5H) and in a group of ventral endodermal cells from which will arise the first gill slit (Figure 5F). Finally, at the larval stage, transcripts of miR-184 are detectable in the anterior and intermediate regions of the cerebral vesicle, in the preoral pit, and in two pharyngeal organs (endostyle and club shaped gland) (Figure 5J, R) as well as in cells surrounding the first (Figure 5I) and second gill slits (Figure 5Q).
**miR-137 expression in amphioxus**
miR-137 transcripts were first discernable during the neurula stage of *B. lanceolatum* (Figure 6) and *B. floridae* (data not shown). In the mid-neurula, expression was found exclusively in the most anterior end of the neural tube, the presumptive cerebral vesicle (Figure 6A). In the early larva (24 to 30 hours after fertilization), the signal was confined to a very few cells in the posterior cerebral vesicle (Figures 6B and 7A, B). From this stage onward, this signal gradually becomes more intense (Figures 6C, D and 7C). Transverse sections indicated that at least some of the labeled cells probably are in the presumptive infundibular organ (Figure 6E, F). However, miR-137 is likely also found just posterior to the infundibular organ in the tegmental neuropile. Subsequently, expression of miR-137 extended to an additional group of cells more anteriorly in the cerebral vesicle (Figures 6G, H and 7D, E) and also to cells arranged in a periodic pattern more posteriorly in the neural tube (Figures 6G, K-N and 7D-F). Non-neural expression was also found around the mouth and in the developing gill slits (Figures 6G and 7D, E)
**Amphioxus predicted miRNA targets**
At present *in silico* prediction is generally the first approach that is used to identify potential miRNA
targets. Table 1 and Additional file 1 (Tables S1 and S2) show that miR-124, miR-7, miR-183, miR-184 and miR-137 probably regulate different target genes, some of which could be regulated by many miRNAs. Comparison of the expression patterns of these miRNAs with those of their putative target mRNAs revealed both overlapping and non overlapping expression. Animal microRNA target prediction is particularly challenging because of the complexity of miRNA target recognition. At present, comprehensive rules controlling miRNA target recognition and binding have not been discovered, and false positive and false negative results are a problem. In animals, miRNA:mRNA duplexes often contain several mismatches, gaps and G:U base pairs in many positions, which limit the length of contiguous sequences of perfect nucleotide matching.
Often miRNAs inhibit translation of their direct targets, and, therefore, the miRNA and its target are co-expressed. However, miRNAs may also regulate the levels of expression of their target mRNAs. This mode of gene regulation is generally linked to a non overlapping expression between miRNAs and their targets [45-47]. However, there are also examples of partially or completely overlapping expression of targets and miRNAs [48]. Alternatively, the target can be expressed in cells that express the miRNA but at higher levels in those cells that do not express the miRNA [49,50]. Here, we used four different programs (miRanda, FindTar, RNAhybrid and PITA) to predict putative amphioxus miRNA targets. We argued that if at least three programs predict the same target sites, the likelihood of false positives is reduced [51]. Unfortunately, several common programs used for vertebrates, Drosophila and worms (ex. TargetScan and PicTar) are not available for "non standard" animal species such as amphioxus. Thus, we have erred on the side of caution and may have missed a number of targets. Indeed, almost one third of the predicted targets were not common to the data generated by three of the four methods.
Therefore, we searched 3'UTR sequences of 68 genes of *B. floridae* for potential binding sites of the six miRNAs (Additional file 1 Table S2). In particular, we selected some genes that are expressed in the nervous system during amphioxus development (Additional file 1 Table S2). For some of them expression in *B. lanceolatum* is also known [52] (Table 1). Of 68 genes expressed in the amphioxus nervous system, we found 17
transcripts with one or more sites for the 5 miRNAs (Table 1 and Additional file 1 Table S1). miR-9 does not show hits for the selected transcripts. Only eight miRNAs were predicted by at least 4 methods to bind at the same site. Our analysis shows that among 17 putative targets, expressed in the CNS of amphioxus, 13 are coexpressed with the one or more of the 5 miRNAs and 6 are not coexpressed (Table 1 and Additional File 1 Table S1). Therefore, we hypothesize that amphioxus miRNAs regulate targets both by controlling translation and by mRNA degradation.
Comparison of the expression patterns of the six miRNAs and their potential targets shows that only miR-184, which is very broadly expressed, is co-expressed with all the potential targets we identified (Table 1 and Additional file 1 Table S1). For example, in the CNS, miR-184 is co-expressed in the cerebral vesicle with calmodulin, FoxG (BF1), TH, TR2/4, Otx. In contrast, none of the selected transcripts contains target sites for miR-9. However, since there are relatively few data concerning gene expression at the late larval stage of amphioxus when miR-9 starts to be expressed, it is difficult to compare its expression with that of other potential targets.
The other 4 miRNAs are all co-expressed with one or more of their potential targets in the CNS. For example, among the several predicted targets of miR-124 expressed in the nervous system (Table 1 and Additional
file 1 Table S1) only Chordin is co-expressed and only at the late neurula stage. At the larval stage, expression of the two no longer overlaps as chordin expression becomes restricted to the cerebral vesicle, where miR-124 is never expressed. Expression of FoxG (BF1), Hairy A, Wnt8 and Calmodulin never overlaps with that of miR-124. Transcripts of FoxG (BF1), Wnt8 and Calmodulin in the CNS are limited to the cerebral vesicle, while those of Hairy A in the CNS are posterior to that of miR-124, and by the larval stage become confined to endodermally-derived structures (Table 1).
The only putative target of miR-7 is NK2.2. In the CNS, expression of miR-7 and NK2.2 appears to overlap in the posterior 2/3 of the cerebral vesicle at the late neurula and larval stages. However, NK2.2 is also expressed in gut cells, while miR-7 is expressed in the preoral pit.
Among the predicted amphioxus targets of miR-183 we found two genes showing an overlapping expression: *Calmodulin* and *Netrin* (Table 1). For example, at larval stage *Netrin* is found in the lamellar body as mir-183. On the contrary, *Gbx* and *ax2/5/8* are putative targets of miR-183 known to be expressed at larval stage in the hindbrain region where miR-183 is not present (Table 1).
Putative targets of amphioxus miR-137 are *Six-4/5*, *TR2/4* and *Gbx* (Table 1). Of these, the first two are co-expressed with miR-137. *Six-4/5* and TR2/4 are overlapping with miR-137 in some regions of cerebral vesicle and in cells of the mouth and gill slits, whereas *Gbx* is a putative target not coexpressed with miR-137.
**Discussion**
Cephalochordates, commonly known as amphioxus or lancelets, are the most basal, living group of chordates.
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**Table 1 Coexpression of miRNAs and enriched brain putative targets**
| putative miRNA targets | miR-124 | miR-7 | miR-183 | miR-137 | miR-184 | References |
|------------------------|---------------|---------------|---------------|---------------|---------------|------------|
| Calmodulin | FT-RH-Mir | | | | FT-Pita-RH-Mir| [109] |
| Chordin | Pita-RH-Mir | | | | | [110,52] |
| Coe | | | | | FT-Pita-RH-Mir| [111] |
| Engrailed | | | | | FT-Pita-RH-Mir| [112] |
| FoxG (BF1) | FT-Pita-RH-Mir| | | | FT-RH-Mir | [113] |
| Gbx | | | | | FT-Pita-RH | [23] |
| Hairy A | | | | | FT-Pita-RH-Mir| [114] |
| Mnx (2 sites) | | | | | FT-Pita-Mir | [27] |
| | | | | | FT-Pita-RH-Mir| |
| Netrin | | | | | FT-Pita-RH-Mir| [115] |
| NK2.2 | | | | | FT-RH-Mir | [116] |
| Otx | | | | | FT-Pita-RH | [21,52] |
| Pax-2/5/8 | | | | | FT-Pita-RH | [117,52] |
| Six-4/5 | | | | | FT-RH-Mir | [118] |
| Snail | | | | | FT-RH-Mir | [119] |
| TH | | | | | FT-RH-Mir | [120] |
| TR2/4 | | | | | FT-Pita-RH | [121] |
| Wnt8 | | | | | FT-Pita-RH | [122] |
Expression of miRNA and enriched brain putative targets detected by at least three of the four bioinformatics algorithms (FindTar, Pita, RNAhybrid and miRanda). miRNA-target coexpression is written in bold. Abbreviations are the followings: FT, FindTar, RH, RNAhybrid, Mir, miRanda.
At least 20 species of the genus *Branchiostoma* have been described but only three of them are mainly investigated: *B. floridae* in North America, *B. lanceolatum* in Europe, and *B. belcheri* in East Asia. Mitochondrial DNA sequences indicate that they probably diverged from 100 to 200 Mya [53,54]. These species are morphologically very much the same. For *B. lanceolatum* and *B. floridae*, the major differences in larvae are the long anterior end and the pigmented tail in the former. Given this high level of morphological conservation, it is not surprising that developmental gene expression is proving to be nearly identical in the two species [52]. Thus, it is not also surprising that miRNAs are conserved between *B. floridae*, *B. belcheri* and *B. japonicum* [11-13] (Figure 8) and that we found their expression patterns in at least *B. floridae* and *B. lanceolatum* also to be much the same. For the six mature miRNAs sequences investigated in the present study, there are a few differences in sequences including insertion/deletion of few nucleotides in the 3’ ends of miR-9, miR-184, miR-183 and miR-137 (Figure 8), outside the 5’-seed region (two to eight nucleotides), which is known to be involved in target recognition. In fact, there is also a high level of sequence identity among these miRNAs in vertebrates and *Branchiostoma*. During miRNA biogenesis, one strand of the RNA duplex is preferentially selected for entry into a silencing complex, whereas the other strand, known as the passenger strand or miRNA* strand, is degraded. Recently, some miRNA* sequences were reported to be abundantly expressed, and generally are less conserved across species. This situation is particularly evident for miR-9* with high levels of nucleotide divergence despite of their partners were highly conserved (Figure 8).
**Amphioxus miRNAs show spatially localized expression in CNS**
The CNS of larval amphioxus comprises an anterior cerebral vesicle (diencephalon plus small midbrain) and a long nerve cord (hindbrain plus spinal cord). The cerebral vesicle, includes the frontal eye rostrally, the infundibular organ ventrally and the lamellar organ dorsocaudally, which is also a photoreceptor. Just caudal to the infundibular organ, there is a thick ventral commissure (tegmental neuropile) receiving fibers that originate from the lamellate cells and just behind this is the primary motor centre (pmc) containing the anteriormost motoneurons and large premotor interneurons with caudal projections (Figure 9). The latter represents the ventral control locomotory system of amphioxus larva thought to be involved in initiating swimming and escape behaviors [18,19,55]. According to the microanatomical reconstructions and gene expression data, the posterior neural tube of amphioxus does not have segmented rhombomeres as vertebrates; but the collinear
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**Figure 8 Sequence alignment of mature miRNA sequences.** The alignment was performed using the mature miRNA sequences of three *Branchiostoma* species (*belcheri*, bbe; *floridae*, bfl; *japonicum*, bj) and three vertebrates (*Homo sapiens*, has; *Danio rerio*, dre; *Petromyzon marinus*, pma). Different residues and insertions/deletions are highlighted in red in the alignment. The miR-9* sequence alignment showed several differences between *Branchiostoma* sp. and vertebrates. The sequences of mature miRNAs of *B. floridae*, *Homo sapiens*, *Danio rerio*, *Petromyzon marinus* were obtained from miRBase. The sequences of miRNAs of *B. belcheri* and *B. japonicum* from [12,13].
expression pattern of *AmphiHox*, as well as the segmental expression pattern of *islet* in the amphioxus neural tube, suggests that amphioxus have at least a hindbrain-related region [25,56] (Figure 9).
Our study shows that miRNAs in amphioxus are differentially expressed within the CNS suggesting that they have region-specific functions. Within the cerebral vesicle, miR-137 and miR-183 show restricted expression in specific cell types, whereas miR-184 and miR-7 are broadly expressed (Figure 9). In 48 h larvae, miR-137 is expressed ventrally in the infundibular organ and likely more posterior in the tegmental neuropile, whereas miR-183 is found dorsal to the infundibulum. At the same stage, miR-124 is preferentially expressed in the hindbrain, whereas in the cerebral vesicle it appears to be limited to few cells in the more posterior part (Figure 9). Moreover, miR-124 expression is also probably found in both interneurons and motoneurons located ventro-laterally in the pmc. Regional expression of miR-9 is similar to that of miR-124, although the exact cells in the neural tube expressing the two may not be the same. The regionally restricted expression suggests that miRNAs may regulate specific cell types in the CNS of amphioxus. These miRNAs could act in the regionalization of the nervous system in a manner similar to that of miR-9 in the positioning of the midbrain-hindbrain boundary (MHB) in zebrafish [31]. In addition, expression of some amphioxus miRNAs suggested roles in neuronal specification and/or differentiation. For instance, miR-124 is initially expressed where five pairs of motor neurons develop in the hindbrain. This segmental pattern is very similar to that of several genes including *islet*, *Krox*, *Mnx*, *ERR*, *Shox*, *synapsin* and *ChAT/VACHT* [24-27,57,58]. However, neither of these genes seems to be recognized by miR-124.
**Conservation of miRNAs across species**
Given the sequence conservation of many miRNAs across species (Figure 8), it is perhaps not surprising that their developmental roles seem to be quite conserved as well. For example, miR-124 is a highly conserved miRNA expressed in the nervous systems not only of amphioxus and vertebrates, but also of several invertebrates including some lophotrochozoans and ecdysozoans, but not in *C. elegans* and *Aplysia*, where it is mostly confined to sensory neurons in the PNS [28,30,59-65]. In mammals, miR-124 is the most abundant miRNA in the embryonic and adult brain [60]. In particular, during neurogenesis, miR-124 is present at undetectable or very low levels in neural progenitors but is highly expressed in differentiating and mature neurons [10,28,66,67]. In amphioxus, miR-124 is expressed exclusively in the CNS, initially, in five groups of cells located ventro-laterally and ventrally in the midbrain and hindbrain at mid-neurula stage and later, more anteriorly, but still mostly in ventro-lateral neurons. Early expression of *Neurogenin* and *ERR* in the first motor neurons to differentiate is similar to that of miR-124 [24,68]. However, whether miR-124 is expressed in the same or adjacent cells is not certain. Certainly, more cells express miR-124 than expresses *ERR*.
In vertebrates, miR-124 is expressed in proliferating neuroblasts. However, in amphioxus, at least at the mid-neurula stage, expression of miR-124 seems to be in post-mitotic cells. At that stage, the only proliferating cells are in the most anterior and posterior-third of the neural tube [69] where miR-124 expression is not found. Interestingly, miR-124 expression was found in the most posterior part of the nerve cord only in later larvae, probably because of the delayed differentiation of neurons there.
miR-9 and miR-124 are both widely expressed in the amphioxus CNS, however cross-sections show that they are expressed in different cells with miR-124 being largely expressed ventrolaterally whereas miR-9 is expressed in the ventral midline. Moreover, unlike mir-124, miR-9 expression is limited to later larvae and it is likely not involved in neurogenesis as described in mammals. In addition the amphioxus miR-9* sequence in
amphioxus has little sequence identity with its vertebrate counterparts (Figure 8), and like miR-9 it is probably not involved in the proliferation of neuronal progenitors.
Although amphioxus and vertebrate miR-9 genes are both expressed in the brain [60,70], unlike miR-124, the functions of miR-9 do not appear to be highly evolutionarily conserved across phyla. In zebrafish and mice, miR-9 is expressed in neural progenitor cells and promotes neurogenesis by repressing suppressors of neuronal differentiation. In addition, miR-9 also targets members of the transcriptional repressor REST complex, inhibiting the expression of neuronal genes in non-neuronal cells [29,71]. Several studies have suggested that miR-9 and miR-9* can both suppress progenitor proliferation and promote neural differentiation [66,71-73]. In zebrafish, miR-9 helps establish the MHB by antagonizing FGF signaling, thus, promoting neurogenesis [31]. However, miR-9 is also expressed in differentiated neurons of the telencephalon [10,66,74]. Moreover, miR-9 is one of four highest expressed miRNA genes in the adult brain of the lamprey *Petromyzon marinus* [75]. In contrast, in *Drosophila* embryos, miR-9 is not expressed in the CNS. Instead, it is expressed in ectodermal cells near some sensory organ precursors (SOPs), where it regulates the specification of sensory neurons by repressing the proneural gene *senseless* in the ectodermal non-SOP cells [76]. The difference between miR-9 function in *Drosophila* and vertebrates might be because miR-9 regulates different genes in these two organisms – for example, proneural genes in *Drosophila* and inhibitors of neurogenesis in vertebrates. In other protostomes, such as the annelid *Platynereis dumerilii*, miR-9 is expressed in cells at the base of the antennae, a pair of head appendages likely acting as chemosensory organs [59].
In amphioxus, miR-184 is ubiquitously expressed in early embryos and larvae although there is expression in the cerebral vesicle in later larvae (Figure 9). In other species, it is similarly widely expressed. For example, it is expressed not only in the CNS, but also in eye and testis of mouse, pharyngeal arch ectoderm and lateral plate mesoderm in the chick, and in the developing eye, hatching gland and epidermis in the zebrafish [30,77]. Similarly in the lamprey, miR-184 is expressed in several organs (brain, gills, kidney, heart, muscle) [75]. Moreover, in *Drosophila*, while miR-184 transcripts are present at high levels in the CNS, they are also present at high levels in eggs and during early embryogenesis in the mesoderm and anterior endoderm as well as in the female germline [63,78,79].
Expression of miR-7 is comparatively evolutionarily conserved. In amphioxus, miR-7 expression in the CNS is limited to the cerebral vesicle (Figure 9). In late neurulae, it is expressed in the presumptive frontal eye, which consists of a cluster of pigment cells (the pigmented cup) and four rows of neurons [20] and where serotonin-containing cells will later differentiate [80]. In larvae, miR-7 transcripts also occur in the middle and posterior cerebral vesicle, including the infundibular cells. Interestingly, we also found miR-7 expression in developing preoral pit in amphioxus (Figure 9), which has been suggested to be homologous to the vertebrate pituitary [81-83].
In other species, miR-7 is also expressed in photoreceptors [84]. In *Drosophila*, together with repression of Yan protein (a repressor of retinal cell differentiation), miR-7 regulates photoreceptor differentiation induced by FGF signaling [85]. In the mouse, and zebrafish miR-7 is also expressed in the hypothalamus in neurons with sensory or neurosecretory functions [86,87]. Similarly, in the annelid *Platynereis*, miR-7 is expressed in vasotocinergic, FMRFamidergic and serotonergic neurons. In addition, miR-7 is expressed in some non-neural tissues including endocrine cells of the pancreas (islets of Langerhans) [88] and in the pituitary gland in mammals [77]. In lamprey, miR-7 is expressed at the larval and adult stage. The brain is the major site of production of such miRNA, although other organs (kidney, skin and gills) express it at low levels [75].
Expression of miR-137 is also highly conserved across species. Vertebrate miR-137, like miR-7, is expressed in specific nuclei in the thalamus/hypothalamus and dorsal tegmentum [66] and enriched in the synaptic compartment of neurons in the mammalian forebrain [89,90]. In the annelid *Platynereis*, miR-137 and miR-7 are expressed in the same region of the CNS [59], while in amphioxus, miR-137 starts to be expressed in some cells of the infundibular organ and in the tegmental neuropile (Figure 9) [19,91]. Moreover, in later larvae it is also expressed in other regions of the cerebral vesicle and in the posterior neural tube. Outside the neural tube we also found expression in the mouth region and gill slits (Figures 7 and 8). Similarly, in the lamprey miR-137 is also expressed in the mouth as well as in the brain [75].
**miR-183 family members represent one of the most highly conserved regulators in sensory organ development**
In vertebrates, miR-183 family members (miR-182, miR-96, and miR-183) are co-transcribed from a 1 to 4 kb segment of intergenic DNA [92] and miR-183 and miR-96 genes appear to be adjacent in genomes of the urochordate *Ciona intestinalis* [93]. More recently, the genomic linkage of miR-182/miR-9/miR-183 has been described in other deuterostomes (*Strongylocentrotus purpuratus*, *Saccoglossus kowalevskii* and *Branchiostoma*
Expression of miR-183 in sensory cells is highly conserved. In amphioxus, it is expressed in potential precursors of ectodermal sensory cells in the rostrum (Figure 9) [44] and, where the lamellar body, thought homologous to the epiphysis of agnathans [41], which also expresses miR-183 [30]. In vertebrates, the three miR 183 family members have very similar expression patterns in specific sensory cell types in the eye, nose, and inner ear [30,40,92]. miR-183 expression is also conserved in neuromasts of teleosts, amphibians and agnathans [93]. In mammals, the miR-183 family was predicted to recognize several genes known to have important roles in various sensory organs, supporting the hypothesis of the sensory organ specificity of this cluster [92]. In *Drosophila* and *C. elegans*, miR-183 homologs are also expressed in ciliated sensory cells of mechano- and chemo-sensory organs [93,94]. Similarly, in the hemichordate *Saccoglossus kowalevskii*, several potential neurosensory cells express miR-183 [93].
**Conclusion**
Many miRNAs are evolutionarily conserved and some have limited expression patterns with strict tissue, cell, and temporal specificities, while others demonstrate ubiquitous or constitutive expression. Moreover, the high phylogenetic conservation of several miRNAs suggests their ancient origin and crucial function in evolutionarily conserved developmental processes.
Our study has set the stage for future investigations of control of neuronal development by microRNA in amphioxus. Amphioxus is a particularly favorable model given the small number of neurons in this model chordate and previous studies mapping each neuron and its connections in the amphioxus brain. In light of the conservation of neural patterning and miRNA expression in amphioxus and vertebrates, results from amphioxus should be highly relevant to understanding the mechanisms of neuronal patterning in the more complex vertebrate brain.
**Methods**
**Embryos collection and whole-mount in situ hybridisation**
Adults amphioxus (*Branchiostoma floridae*) were collected from Old Tampa Bay, FL, USA. *In vitro* fertilization, embryo culture, and fixation were performed as described [95]. Adults amphioxus (*Branchiostoma lanceolatum*) were collected in the bay of Argeles-sur-Mer, France, and gametes were obtained by heat stimulation [96,97]. Fixation was performed as described [95]. Expression patterns of mature miRNAs were determined by whole-mount *in situ* hybridizations using Locked Nucleic Acid (LNA)-modified oligonucleotide probes (WM-LNA-ISH). The sequences of mature miRNAs of *B. floridae* were obtained from miRBase release 17 [98]. LNA-modified probes were purchased from Exiqon (Denmark) and were directly labeled with DIG at both their 5’ and 3’-ends, or at 3’-ends only, as previously described [10]. The sequences of LNA probes are the following: miR-124: 5’-GGCATTCACCGCGTGCCTTA-3’; miR-9: 5’-CATACAGCTAGATAACCAAAGA-3’; miR-7: 5’-ACAACAAAATCACTAGTCTTCCA-3’; miR-183: 5’-AGTGAATTCTACCAGTGCCATA-3’; miR-184: 5’-CCCTTATCAGTTCTCCGTCCA-3’; miR-137: 5’-ACGTGTATTCTCAAGCAAT-3’. Whole mount *in situ* hybridization was performed essentially as described by Holland and coworkers [95] with some modifications. In particular, the temperature of hybridization and subsequent washing steps was adjusted to approximately 22°C below the predicted melting temperatures of the LNA modified probes. All miRNA probes were used at the same concentration (final concentration 5 nM) and in parallel. To determine the miRNA expression patterns more precisely at the cellular level, some embryos were also sectioned. Labeled embryos were counterstained with 1% Ponceau S in 1% acetic acid, dehydrated in ethanol, embedded in Spurr’s resin, and sectioned at 3 to 4 μm. Images were collected by using an Olympus IX71 microscope (Olympus Italia s.r.l., Italy) equipped with the chilled color digital camera ColorView II (Soft Imaging System GmbH, Germany) and images were processed using the analySIS software package (Soft Imaging System GmbH, Germany).
**Prediction of amphioxus microRNA target genes**
To identify potential target genes of the six miRNAs analyzed in the present paper we examined a suite of RNAs known to be expressed in the nervous system (Additional file 1 Table S2). Because the *B. floridae* genome is not fully annotated, and several transcripts did not contain the 5’ UTR and 3’ UTR regions we selected full-length cDNA sequences to allow identification of the stop codons and consequently the 3’UTRs. Therefore, sequences of 3’UTRs were obtained from the *B. floridae* EST data sets [99] and from the JGI web site [100]. To improve the accuracy of target prediction we used four target prediction algorithms: miRanda, RNAhybrid, FindTar, PITA [101-104]. miRNAs with binding sites in the 3’-UTR as predicted by three of the four bioinformatics algorithms were selected as putative regulators of transcripts (Table 1 and Additional file 1 Table S1). For target prediction with miRanda software we used the following parameters: gap opening penalty of -8; a gap extension penalty of -2; a score threshold of 60; an energy threshold of -20 kcal/mol; a scaling parameter of 2. For RNAhybrid we considered only the sites with ΔG < -20 kcal/mol, with seed 2 to 8 and allowing G:U wobble pairs. PITA identifies putative targets assigning an energetic score (ddG). Only sites with ddG values...
below -10 were considered as significant. For FindTar we used default parameters: loop score > 15 and ΔG < -15 kcal/mol. PITA, FindTar and miRanda executable can be downloaded from their specific websites [105-107]. RNAhybrid is available at BIBiserv [108].
Additional material
Additional file 1: Amphioxus putative miRNA targets. Additional file 1, Table S1: Amphioxus putative miRNA targets expressed in the nervous system. Score values, energetic scores (ddG), free energy (ΔG) and loop scores produced by the different target prediction tools are shown.
Additional file 1, Table S2: Complete list of transcripts analyzed by miRNA target prediction programs.
Abbreviations
miRNA; microRNA; UTRs; untranslated regions; CNS; central nervous system; *B. floridae* and *B.lanceolatum*: *Branchiostoma floridae* and *Branchiostoma lanceolatum*; PNS; peripheral nervous system; REST/NRSF; RE1 silencing transcription factor/neural-restrictive silencing factor; pmc; primary motor centre; MHB; midbrain-hindbrain boundary; SOPs; sensory organ precursors; WM-LNA-ISH; whole-mount *in situ* hybridizations using Locked nucleic acid (LNA)-modified oligonucleotide probes.
Acknowledgements
We would like to thank Skip Pierce and John M. Lawrence (Department of Biology, USF, Tampa, FL) for the use of laboratory space and equipment; Linda Holland (Scripps Institution of Oceanography, La Jolla, CA) for her comments and criticisms; Ray Martinez and Marilyn Wetzel (Department of Biology, USF, Tampa, FL) for their logistic support. We are deeply grateful to Héctor Escriva and collaborators (Centre National de la Recherche Scientifique, Unité Mixte de Recherche 7323, Université Pierre et Marie Curie Paris 06, ObservatoireOcéanologique, F-66651 Banyuls-sur-Mer, France) for the important support in collecting *Branchiostoma lanceolatum* adults and embryos and for providing us with laboratory space, scientific and technical assistance. This work was supported by MIUR (PRIN Program n° 20088JEHW3-001) (to SC and MP). DDPT was supported by intramural funds of Fondazione Istituto Italiano di Tecnologia.
Author details
1University of Genoa, Department of Biology, viale Benedetto XV 5, 16132 Genoa, Italy. 2The Italian Institute of Technology, Department of Neuroscience and Brain Technologies, Via Morego 30, 16163 Genoa, Italy.
Authors’ contributions
SC carried out the bioinformatic and *in situ* hybridization assays and drafted the manuscript. LM and GG contributed to the whole mount *in situ* experiments and bioinformatic analysis, respectively. DDPT was involved in the comparison of the miRNA and expression patterns and contributed to data discussion. SC and MP were responsible for the cellular and evolutionary interpretation of the data. All authors read and approved the final manuscript.
Competing interests
The authors declare that they have no competing interests.
Received: 7 April 2011 Accepted: 1 July 2011 Published: 1 July 2011
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92. Xu S, Witmer PD, Lumayag S, Kovacs B, Valle D: MicroRNA (miRNA) transcriptome of mouse retina and identification of a sensory organ-specific miRNA cluster. *J Biol Chem* 2007, 282:25053-25066.
93. Pierce ML, Westin MD, Fritzsche B, Gabel HW, Ruvkun G, Sokup GA: MicroRNA-183 family conservation and ciliated neurosensory organ expression. *Evol Dev* 2008, 10:106-113.
94. Hilgers V, Bushati N, Cohen SM: *Drosophila* microRNAs 263a/b confer robustness during development by protecting nascent sense organs from apoptosis. *PLoS Biol* 2010, 8:e1000396.
95. Holland LZ, Holland PWH, Holland ND, Ferraris JD, Palumbi SR: Revealing homologies between body parts of distantly related animals by *in situ* hybridization to developmental genes: amphioxus versus vertebrates. In *Molecular Zoology: Advances, Strategies, and Protocols*. Volume 267. Edited by: Ferraris JD, Palumbi SR. New York: Wiley Press; 1996:282–473-483.
96. Fuentes M, Schubert M, Dalfo D, Candiani S, Benito E, Gardynes J, Godoy L, Moret F, Ilas M, Pattien I, Permanyer J, Oliveri D, Boeuf G, Falcon J, Pestarino M, Fernandez JG, Albaltat R, Laudet V, Vernier P, Escriva H: Preliminary observations on the spawning conditions of the European amphioxus (*Branchiostoma lanceolatum*) in captivity. *J Exp Zool B: Mol Dev Evol* 2004, 302:384-391.
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111. Mazet F, Masood S, Luke GN, Holland ND, Shimeld SM: Expression of Amphicoe, an amphioxus COE/EBF gene, in the developing central nervous system and epidermal sensory neurons. *Genesis* 2004, 38:58-65.
112. Holland LZ, Kene M, Williams NA, Holland ND: Sequence and embryonic expression of the amphioxus engrailed gene (AmphiEn): the metameric pattern of transcription resembles that of its segment-polarity homolog in *Drosophila*. *Development* 1997, 124:1723-1732.
113. Torresson H, Martinez-Barbera JP, Beardsley A, Cubit X, Krauss S: Conservation of BF-1 expression in amphioxus and zebrafish suggests evolutionary ancestry of anterior cell types that contribute to the vertebrate telencephalon. *Dev Genes Evol* 1998, 208:431-439.
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115. Shimeld S: An amphioxus netrin gene is expressed in midline structures during embryonic and larval development. *Dev Genes Evol* 2000, 210:337-344.
116. Holland LZ, Venkatesh TV, Gorlin A, Bodmer R, Holland ND: Characterization and developmental expression of AmphiNk2-2, an NK2 class homeobox gene from Amphioxus. (Phylum Chordata; Subphylum Cephalochordata). *Dev Genes Evol* 1998, 208:100-105.
117. Kozmik Z, Holland ND, Kalousova A, Paces J, Schubert M, Holland LZ: Characterization of an amphioxus paired box gene, AmphiPax2/5/8: developmental expression patterns in optic support cells, nephridium, thyroid-like structures and pharyngeal gill slits, but not in the midbrain-hindbrain boundary region. *Development* 1999, 126:1295-1304.
118. Kozmik Z, Holland ND, Kreslova J, Oliveri D, Schubert M, Jonasova K, Holland LZ, Pestarino M, Benes V, Candiani S: Pax-Six-Eya-Dach network during amphioxus development: conservation *in vitro* but context specificity *in vivo*. *Dev Biol* 2007, 306:143-159.
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doi:10.1186/2041-9139-2-15
Cite this article as: Candiani *et al.*: A study of neural-related microRNAs in the developing amphioxus. *EvoDevo* 2011 2:15.
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Our capability needs a goal – patients need our competence
Pharmaceutical oncology standards in Europe
Best use of targeted agents for the treatment of advanced renal cell carcinoma
Non-compliance in cancer treatment
Nuclear medicine needs radiopharmacists!
Radiotherapy of neuroendocrine gastroenteropancreatic tumours: new principles
Joint venture in continuing education
Europa Uomo in collaboration with ESOP
Business as usual and some surprises
11th Annual Symposium of the British Oncology Pharmacy Association
ESOP News
Erratum
Our capability needs a goal – patients need our competence
For more than 20 years pharmacists have gained a good reputation in preparing cytotoxic drugs. They had to grow their knowledge not only about the drugs themselves but also to start to understand more about therapies and medical decision making.
It was only a matter of time before pharmacists felt the need to share their experience at a national and international level in order to raise their educational level. ESOP took early steps alongside the ECCO meeting in 1999 in Vienna, Austria, and ten years later it has become an established part of the European CanCer Organisation. At the ECCO conference 2009 in Berlin, Germany, it will be presenting in several lectures and sessions its understanding of how oncology pharmacy can best support the treatment of cancer patients. This demonstrates the increasing importance of good education.
In the perspective of history, ten years appear like a blink of an eye, but for those who have been responsible for progress it is a long way. Three conferences were held in Luxembourg in 2001, 2004 and 2008 to discuss quality standards in oncology pharmacy service, gradually agreeing a basis for common understanding and support from 22 countries. Good news is the formation of a committee with delegates from France, Germany, The Netherlands and UK. Its mandate is to harmonise our understanding of continuing education. The sooner oncology pharmacy adopts a common position, the better we can contribute to the development of continuing medical education in Europe (see page 6). Read about recent QuapoS discussions on pages 4-6 and a presentation of the developing UK system on pages 18-19.
But we must never forget the individual responsibility of oncology pharmacists for reflection and self-auditing in daily work. Patients are asking for support and are looking for a well equipped pharmacist to partner other healthcare providers. So take advantage of the continuing education articles in this issue: latest treatment for renal cell carcinoma pages 8-12 and ASH 2008 conference report pages 22-23.
When these days physicians are discussing the increasing efficacy of interdisciplinary work, then we should realise that in 95% of these discussions they are talking about the collaboration of internal medicine and surgery. The role of nurses and even less that of pharmacists is generally not included in this word “interdisciplinary”.
That is why we are presenting ourselves as a part of the “multi-professional team”. The radiology feature in this issue illustrates the added value a pharmacist can bring, pages 14-17. The use of this new term will grow because of changes in therapy, a fact not yet fully recognised by most physicians.
The chance of surviving cancer is increasing all the time. The methods of treatment are changing from intermittent IV to continuous oral regimens. The safe and effective use of orally administered targeted treatments for cancer also has to be learned by pharmacists. The profession needs to understand how these therapies are used, what toxicity to expect and how to manage it. We have to learn, in words of the BOPA’s past chairman, Mr Geoff Sanders, “how services can be developed to accommodate this expanding section of the oncological armoury.”
To do this we have to change too. In the past in Germany, although certified community pharmacies are allowed to prepare IV drugs, these drugs have been administered in hospitals only. Several countries have rules stating that IV treatment has to be prepared in hospital pharmacies. But how will the situation change if oral drugs start to become the norm and the great problem of non-compliance provokes bad treatment results? Dr Lukasz Lapinski outlines the compliance problem on page 13. Worse still, the wrong medicine taken daily could result in treatment breaks and sudden death.
This situation can only be avoided through the assistance of community pharmacists, who will have the chance to make all the necessary information available directly to their patients and take on the whole gamut of treatment with medicines. This will not come about by itself. National guidance has to be developed and implemented. The oncology pharmacist can initiate this process and can bridge the gap between patient needs and pharmacists’ abilities. At the EU level, ESOP welcomes Europa Uomo as a new partner, see pages 19-20.
As early as possible oncology pharmacists need to understand their leading role in organising the best support for patients. Then they will be understood as a supporting pillar in the hall of multi-professionalism.
Pharmaceutical oncology standards in Europe
It is an uphill struggle to get all centres in Europe to treat cancers to the same standard, as the understanding and treatment of these conditions constantly evolves. ESOP, the EU and patient groups are partners in this process and were all represented for this review of the present situation.
The third meeting of QuapoS (Quality Standards for Pharmaceutical Oncology Service), was held in the EU Commission building, Bâtiment Jean Monnet in Luxembourg, 26-27 September 2008. Almost 70 participants attended from 19 countries. The conference theme was “Through the eyes of the patients”. The first session of the meeting focused on presentations on this theme and several distinguished guests spoke.
The EU Commissioner for Health and Consumer Protection, Mrs Androulla Vassiliou from Cyprus, told of the devastating effect of cancer on patients, the family and society. The EU Commission has several projects to combat cancer and some of them were discussed:
• Investigation of the difference in cancer rates in regions in Europe
• Action on obesity and initiatives for a better diet
• Smoking information and smoking prophylaxis
• Vaccination, e.g. *Helicobacter pylori* programmes for selected cancers
• Screening programmes for breast, cervix and colorectal cancer
• Information for the public on cancer prevention
• Treatment initiatives with encouragement for drug companies to do research
Professor Louis Denis, Antwerp, Belgium is a professor in surgery but also a cancer patient. He pointed out that almost 40% of patients received wrong or incomplete treatment for their cancer. He concluded that medicines management is an important task for pharmacists. He also presented the initiatives taken by cancer patient organisations to inform, support and encourage cancer patients. He was interested in further collaboration with ESOP to support patients.
Klaus Meier, Germany, President of ESOP, spoke next to describe ESOP’s mission and its vision for the future. He also gave details from a survey in Germany of cancer patients’ views on pharmaceutical care. The majority of patients need more information and would benefit from information from pharmacists, but few patients realise that this is possible. Complementary and alternative medicines are used by a majority of cancer patients. In Germany more money is spent on complementary treatment than conventional treatment.
The session closed with two scientific lectures. Professor N Schleucher, Hamburg, Germany, questioned whether there is really such a thing as targeted therapy in oncology. Professor Robert Mader from Vienna, Austria talked about pharmacological lessons learned and lessons to be learnt about the interplay between inflammation, angiogenesis and cancer tumours. He concluded that “The complex interaction between biology and pharmacology will bridge the treatment options and validate and help the clinical oncologist to make correct decisions”.
In the late afternoon the quality standards of QuapoS were scrutinised in five different workgroups, which continued their work on the second day. Below you will find the most important recommendations of each working group.
**Education and training** chaired by Hannelore Kreckel, Germany
This workshop focused on the need for continuing education of pharmacists in “Oncology Pharmacy Practice” and the need for an ESOP qualification. The purpose of such certification was seen as the need for other healthcare professionals, authorities and hospital managements to recognise competence.
The knowledge, skills and attitude acquired during a specialisation period should enable pharmacists to work effectively in a multi-professional team. Changes in practice and the concept of life-long learning mean that certification has to be limited to a certain period. A two-step approach including basic and advanced levels should be taken. Basic knowledge includes safe handling, principles of anti-neoplastic therapy, cancer prevention and the promotion of early detection, as well as a knowledge of drugs. This knowledge can be acquired by independent study and demonstrated in a written examination. The advanced level, to achieve an ESOP certificate, may consist of a mandatory and an optional part. The following points were considered to be mandatory: oncology pharmacy practice including care plans, medicines management, drug information, the preparation of guidelines, skill in communication with the patient, teaching and presentation skills. Optional points may include skills such as teamwork or project management, clinical trials in oncology, horizon scanning and research. Education by e-learning programmes, conferences, masterclasses and workshops must be considered to improve skills. It was stated that ESOP certification would not have the same relevance for all countries but would be of special interest for those countries where a national certification programme is not likely to be set up.
**Technical aspects** chaired by Irena Netikova, Czech Republic and Professor Robert Mader, Austria
The aim of this workshop in oncology pharmacy was to discuss the present status in comparison with QuapoS 3. For every individual technical issue the main question asked was “Do we feel comfortable with the current standards?”
During the workshop a number of important topics for the future were discussed such as: handling compounds with various classes of toxicity (cytotoxics, monoclonal antibodies); drug delivery to the pharmacy (vial contamination/labelling); the current list of drugs carcinogenic, mutagenic or toxic to the reproductive system; aseptic process validation; closed systems; electronic prescriptions, oral medicines and home care. An electronic prescribing system is favoured to reduce errors and improve safety. There was a call for a new chapter in QuapoS: “The patient’s point of view”. Proper procedures and techniques will guarantee a high quality of anticancer treatment.
The introduction by ESOP of a “yellow hand” with a contact phone number (hotline) to the pharmacy as part of the labelling of ready-to-use solutions for home care was seen to be a significant improvement. There are no standards for information on handling oral formulations at the moment. ESOP is also going to provide patient information to accompany drugs prescribed for home care: what to do with excreta, extravasations and possible incidents. A leaflet is being written to accompany every prescription.
The conclusions reflect the fact, that QuapoS has already established a very high standard for a variety of aspects. We now need these materials to be accepted and implemented with official backing in all European countries. QuapoS’ harmonisation of similar guidelines is a long-term goal and improvements will rely on further evidence.
**Pharmaceutical care** chaired by Kathleen Simons, The Netherlands and Professor Alain Astier, France
The aim of the workshop was to discuss the present status measured against QuapoS 3. Participants thought the starting point must be a definition for oncology pharmaceutical care in Europe. From this base, uniform minimum standards for all European Member States with regard to cytotoxic prescription, patient counselling and prevention of drug events/medication errors can be defined.
Therefore it is important that:
- Oncology pharmacists are full members of the multidisciplinary team managing chemotherapy.
- Oncology pharmacists have full access to all pertinent data to support high level pharmaceutical care.
- European oncology pharmacists strongly support the ECCO recommendation that all chemotherapy should be prescribed according to a previously defined protocol.
- Oncology pharmacists should ensure that chemotherapy prescriptions comply with ESMO standards.
- Oncology pharmacists should assess requirements for patient information.
Another important question was how to raise patient compliance. This could be achieved by a patient-centered approach and advice, together with medicines counselling and lifestyle modifications. Participants drew attention to leaflets that have already been compiled in hospital in Leipzig, Luxembourg and Madrid, Spain.
It was agreed that these goals cannot be achieved in all countries at the same time. Nevertheless, QuapoS has already established a high standard for a variety of aspects.
**Quality management** chaired by Jeff Koundakjian, UK and Gisela Sprossman Guenther, Germany
Quality management should be incorporated into the standards of QuapoS. Clear standards need to be set and, ideally, these should be achievable, although in some instances they may need to be aspirational. Once the highest standards have been agreed and set, there is a need to arrange constant monitoring to maintain these standards. This will preserve and enhance the ability of the oncology pharmacy staff to meet the needs of cancer patients. A new QuapoS section on Quality Management is required.
Standard Operation Procedures must be kept and readily available for all technical areas of the pharmacy. Completed worksheets must be kept for regular audit. Records must be kept of staff workload and exposure to cytostatic agents, and environmental records and settle plate results must be available. Records of staff absences and accidents may also demonstrate trends that need to be investigated.
Records of adverse incidents and complaints should show what action has been taken, and the result of this action. All procedures and equipment, including computers and software must be validated for accuracy and records kept, including changes to the procedures.
Documentation underpins the audit process. *If it was not documented, it did not happen.*
**Research and Development** chaired by Professor Per Hartvig-Honoré, Denmark
Oncology pharmacy practice and information should be based on scientific evidence as well as validated experience. Therefore,
research and development in oncology pharmacy is essential for further progress, as in other medical and pharmaceutical sciences. Research must be of high quality and focused on improving cancer treatment, cancer knowledge and improving the patient’s situation. The oath “not to hurt” is a leading objective. The subject of the research must have both pharmaceutical and medical relevance, be clearly formulated, well structured and fully documented. Results should be disseminated to the scientific world and to oncology pharmacy. There is a special responsibility to perform research and high quality standards must be secured and validated in all projects. Projects for research and for development of oncology pharmacy are open to all. Expert oncology pharmacists in centres must provide support and supervision for excellent research projects.
In the eyes of patients, the oncology pharmacist is another type of professional, who will inform him about his treatment, managing his treatment as a whole, including other co-morbidities and not only focusing on the cancer. He will give an increased understanding of different entities and the patient will feel a safety and quality in drug prescribing and administration.
Knowledge and competence of pharmaceutical oncology care are essential to keep these values for the patient. Services must be well managed, methods continually reviewed and updated: analyse, plan, implement and validate. Further, scientific studies must be performed. The advantage to the oncology patient of scientific studies is that results are disseminated to other departments and patients, communication is better to patients and among professionals, time saved will be used for more effective treatment and to foster more rational use of resources, e.g. beds, drugs. As a practical exercise, the group planned a multicentre study to test whether “close multidisciplinary medicines management reduces the intensity of nausea and number of emesis episodes in breast cancer patients on chemotherapy”. The intention was not that the study should be performed, but that it should encourage other oncology pharmacists to consider doing or joining a study.
ESOP plans
An ESOP delegates meeting was held before the QuapoS meeting to plan the 2009 events. An important forthcoming event is the second part of the Masterclass from 5-7 March 2009 dealing with clinical oncology pharmacy.
All information can be found on www.esop.eu. In September 2009, ECCO 15 will take place in Berlin, Germany. ESOP will organise and participate in several symposia and seminars. This is an opportunity to show ESOP’s competence and its ability to support the European CanCer Organisation.
Author
Professor Per Hartvig-Honoré, PharmD, PhD
Secretary of ESOP
ESOP News
The Medical Oncology Status in Europe Survey (MOSES)
ESMO recently promoted medical oncology to members of the European parliament. Advancing this discipline will benefit cancer sufferers.
On 15 October 2008, the European Society of Medical Oncology (ESMO) invited ESOP to a keynote debate titled Towards Better Cancer Care in Europe on improving cancer care in Europe. The meeting was attended by members of the European parliament, national experts and representatives from oncology interest groups including patients with cancer. Monika Sonec from Slovenia and I jointly represented ESOP. The Medical Oncology Status in Europe Survey (MOSES) was presented as a good source of information on differences in cancer care around Europe.
Medical oncology is not recognised in the EU in the same way as the other modalities of cancer treatment, surgery and radiotherapy. This is a serious shortcoming and efforts should be made to include experts in this field in the cancer care team. Approval is available at EU level but there are still national problems and obstacles. Education is not uniform in the EU and therefore education in medical oncology may also be lacking. Multidisciplinary teams are not standard throughout Europe but vary with respect to the site of the cancer, as some are built on organ specialists. New treatment is costly and has been estimated at Euros 14,000 a day. It really calls for good sense, analysis and constructive criticism to use the medicines only when indicated. Education, knowledge and experience are “musts” today for medical oncology. Drugs for cancer are the most complex, dangerous and expensive of all treatments and must be managed by the most experienced drug specialists in cancer treatment.
A further topic was cancer care abroad. This is estimated at 1% of total treatment costs. It is a good idea if one country has low capacity in a certain area or if experience and treatment is lacking in the patient’s home country. An initiative to inform patients on care abroad was taken. The initiative does not expect to generate a much-increased flow, rather, considerably better possibilities for individual patients. Patients now have the legal right to visit another EU country for treatment.
ESOP will continue to follow the EU initiatives on cancer care and support as far as possible with oncology pharmacy expertise.
Professor Per Hartvig-Honoré, PharmD, PhD
Best use of targeted agents for the treatment of advanced renal cell carcinoma
The advent of targeted therapies has substantially improved the prognosis of patients with metastatic renal cell carcinoma. Clinical outcomes can be optimised by patient education, close patient monitoring, appropriate dosing and prompt adverse event management by a multidisciplinary healthcare team.
Introduction
Renal cell carcinoma (RCC) occurs typically in patients aged 60-70 years, more commonly in men than women, and causes approximately 20,000 deaths annually in Europe [1, 2]. RCC is often asymptomatic until it reaches an advanced stage: approximately 25-30% of patients are diagnosed with metastases [3]. Furthermore, a high proportion of patients who undergo curative nephrectomy for localised RCC go on to develop metastases [3].
Historically, treatments for metastatic RCC (mRCC) included the cytokine therapies interleukin-2 or interferon alpha (IFN-α), which were associated with limited efficacy and toxicity concerns [3]. Improved understanding of the molecular mechanisms of RCC led to the development of targeted therapies, which now represent the standard care for mRCC.
This article will review clinical efficacy and safety data for the targeted agents currently available for mRCC. It will also discuss practical strategies for optimising treatment outcomes with these agents, with a particular focus on sunitinib malate (Sutent).
Targeted therapies in mRCC
Sunitinib
Sunitinib is an oral, multitargeted receptor tyrosine kinase inhibitor (TKI) that is approved multinationally for the first- and second-line treatment of mRCC [5]. Sunitinib targets vascular endothelial growth factor receptors (VEGFRs), platelet-derived growth factor receptors (PDGFRs), stem cell factor receptor (KIT), FMS-like tyrosine kinase 3 (FLT3), colony-stimulating factor 1 receptor (CSF-1R), and glial cell line-derived neurotrophic factor receptor (REarranged during Transfection; RET) receptors [5].
In a multicentre phase III trial in mRCC patients [6], first-line sunitinib (50 mg/day for 4 weeks, followed by 2 weeks off treatment in 6-week cycles; Schedule 4/2) was compared with IFN-α (9 million units [MU] subcutaneously three times weekly [t.i.w.]). Sunitinib was associated with median progression-free survival (PFS) more than double that seen with IFN-α (11 months vs. 5 months, respectively) and a superior objective response rate (31% vs. 6% respectively; both p < 0.000001) [6]. Median overall survival (OS) was extended beyond two years, the first time that this has been achieved in mRCC trials in the first-line setting (see Table 1) [7]. Further, when the data were censored to exclude patients who had switched from IFN-α to sunitinib therapy, a statistically significant difference in median OS was observed (26.4 months with sunitinib vs. 20.0 months with IFN-α; p = 0.0362) [7]. Sunitinib also conferred OS benefits across all Memorial Sloan-Kettering Cancer Center (MSKCC) prognostic risk groups [8].
In the second-line setting, sunitinib has demonstrated efficacy after cytokine failure, with median OS of 23.9 months and PFS of 8.8 months [9]. It has also shown activity in an expanded-access study in a broad population of patients (N = 4,622) who
| Agent | Setting | Median PFS, months | p-value | Median OS, months | p-value |
|------------------------|------------------|--------------------|-----------|-------------------|-----------|
| Sunitinib (vs. IFN-α) | First-line | 11 (vs. 5.0) | <0.000001 | 26.4 (vs. 21.8)* | 0.051 |
| | | | | 26.4 (vs. 20.0)** | 0.0362 |
| Sorafenib (vs. placebo)| Second-line | 5.5 (vs. 2.8) | 0.000001 | 17.8 (vs. 14.3)* | 0.0287 |
| Temsirolimus (vs. IFN-α)| First-line** | 5.5 (vs. 3.1) | 0.0001 | 10.9 (vs. 7.3) | 0.0069 |
| Bevacizumab plus IFN-α| First-line | 8.5 [21]*–10.2 [20]| 0.0001 | NR | NA |
* Final median overall survival data for sunitinib versus interferon alpha (IFN-α) for whole patient population;
** Median overall survival data when patients who had switched from IFN-α to sunitinib therapy were excluded from the analysis [7]
§ Data censored for patients who switched from placebo to sorafenib treatment [3]
§§ Patients classified with poor prognostic risk based on the modified Memorial-Sloan Kettering Cancer Center (MSKCC) prognostic risk criteria [18]
† Data reported as time to tumour progression [21]
PFS: progression-free survival; OS: overall survival; IFN-α: interferon alpha; NR: not reported; NA: not applicable
would otherwise have been excluded from clinical trials, including patients with brain metastases [10].
The tolerability profile of sunitinib is discussed later in this article.
As a result of the efficacy observed, the European Association of Urology (EAU) guidelines recommend sunitinib for first-line use in patients with mRCC (Grade A recommendation) [3] and sunitinib is now considered the standard treatment for this condition.
**Sorafenib**
Sorafenib is an oral, multitargeted TKI that targets VEGFR-2 and -3, PDGFR-β, FLT3, KIT, RET, B-Rad and Raf-1/C-Raf [11].
In a phase III trial in mRCC patients who had failed prior systemic therapy, sorafenib (400 mg twice daily [b.i.d.]) conferred significantly longer median PFS compared with placebo (5.5 vs. 2.8 months; p < 0.001; see Table 1) [12]. Median OS was also significantly greater with sorafenib than with placebo when data were censored for patients who had switched from placebo therapy (17.8 vs. 14.3, respectively; p = 0.0287; see Table 1) [13]. A phase II study of first-line sorafenib (400–600 mg b.i.d.) versus IFN-α (9 MU t.i.w.) in mRCC showed no significant difference in median PFS between the two agents (5.7 vs. 5.6 months, respectively; p = 0.504) [14]. Findings from a sorafenib expanded-access programme were consistent with those seen in the phase III trial [15].
Sorafenib has a manageable tolerability profile, with a low incidence of severe adverse events (AEs) reported in clinical studies [12]. A clinical review comparing sorafenib with sunitinib has suggested similar mechanisms of action for the two agents, with some differences in toxicity profiles [16].
The EAU guidelines recommend sorafenib for the second-line treatment of mRCC (Grade A recommendation) based on phase III trial data [3].
**Temsirolimus**
Temsirolimus is a mammalian target of rapamycin (mTOR) inhibitor that is approved in Europe for the treatment of patients with poor-risk mRCC [17].
In a randomised phase III study, treatment-naïve patients with poor- and intermediate-risk mRCC (poor-risk patients exhibited 3 of 5 criteria according to the modified MSKCC prognostic classification), received IV temsirolimus (25 mg/week), IFN-α (3 MU t.i.w.) or both agents. In poor-risk patients, median PFS and OS were significantly longer for temsirolimus than for IFN-α monotherapy (p = 0.0001 and p = 0.0069, respectively; see Table 1) [18]. Grade 3–4 AEs occurred in 67% of poor-risk patients in the temsirolimus arm, versus 78% and 87% in the IFN-α monotherapy and combination therapy arms, respectively. Based on this study, the EAU guidelines recommend temsirolimus as first-line treatment for poor-risk mRCC patients only (Grade A recommendation) [3].
**Bevacizumab**
Bevacizumab is a humanised monoclonal antibody that targets major VEGF-A isoforms, which is given in combination with IFN-α for the treatment of mRCC [19].
Two randomised phase III studies compared combination treatment with bevacizumab (10 mg/kg every 2 weeks) plus IFN-α2a (9 MU t.i.w.) versus placebo plus IFN-α2a [20, 21]. In both studies, median PFS and objective response rate were superior for bevacizumab/IFN-α2a compared with placebo/IFN-α2a (both p < 0.0001; see Table 1) [20, 21]. Median OS has not yet been reached with bevacizumab/IFN-α2a in either study. In the first study, more AE-related treatment discontinuations and serious AEs were reported with bevacizumab/IFN-α2a than with placebo/IFN-α2a (28% vs. 12% and 29% vs. 16%, respectively) [20]. The second study also reported a higher incidence of grade 3–4 AEs with bevacizumab/IFN-α2a (79% vs. 61% with placebo/IFN-α2a) [21].
Combination bevacizumab/IFN-α2a therapy is recommended as an option for the first-line treatment of mRCC in the US National Comprehensive Cancer Network (NCCN) guidelines (category 1 recommendation) [22].
**Tolerability of sunitinib**
Studies in the first- and second-line settings have reported consistent tolerability with sunitinib, including in the expanded-access study involving more than 4,000 patients [23].
The most common AEs reported with first-line sunitinib in the phase III trial included fatigue, gastrointestinal symptoms, hand-foot syndrome (HFS), hypertension and haematological disturbances [6]. Most AEs were mild-to-moderate in severity and were easily managed, with a low incidence of severe AEs [6]. Long-term data from the expanded-access study reported no new or unexpected long-term toxicities and a low incidence of cardiac disorders [23]. Treatment-emergent hypothyroidism has been reported in a small percentage of patients [5].
**Optimising the efficacy and tolerability of sunitinib**
Higher exposure to sunitinib is associated with greater clinical responses [5], so maintaining optimal plasma levels of sunitinib is important. This can be achieved by administering appropriate dose levels and by minimising the risk of AE-associated treatment interruptions.
Sunitinib should be prescribed at a starting dose of 50 mg/day by Schedule 4/2, and doses can be adjusted in 12.5 mg increments [5]. Maximum plasma concentrations are reached 6–12 hours after administration and steady-state concentrations within 10–14 days [5].
Sunitinib is metabolised primarily by the cytochrome CYP450 enzyme CYP3A4. Concomitant treatment with CYP3A4 inducers (e.g. dexamethasone) or inhibitors (e.g. ketoconazole) should be avoided or doses adjusted [5]. If no alternative drug can be prescribed, the sunitinib dose should be amended to a maximum of 87.5 mg/day if co-administered with a strong CYP3A4 inducer, or to a minimum of 37.5 mg/day if given with a strong CYP3A4 inhibitor [5].
The pharmacokinetics of sunitinib are not affected by age, race, gender, body weight, creatinine clearance or performance status and no dose adjustments are necessary for mild-to-moderate hepatic impairment [5]. Sunitinib may be taken with or without food, preferably at the same time of day. If a dose is missed the patient should receive the usual prescribed dose on the following day.
**Management of sunitinib-related adverse events**
Pharmacists play an integral role in ensuring that required patient information is collected and patients are monitored regularly and educated about treatment outcomes, compliance and potential sunitinib-associated AEs. Pharmacists can assist in advising patients about the management of treatment-related AEs and encouraging them to report any relevant symptoms so that they derive the greatest treatment benefit. Here we review practical steps to manage AEs common to sunitinib.
### Table 2: Managing adverse events observed with sunitinib therapy*
| Adverse event | Pre-treatment management | Recommended strategy during treatment |
|---------------|--------------------------|--------------------------------------|
| Hand-foot syndrome | • Educate patients regarding HFS
• Conduct full foot exam
• Treat any existing conditions before treatment initiation, e.g. plantar hyperkeratosis | • Advise patients to minimise pressure on affected areas and to wear loose footwear, e.g. sandals, and to use thick socks, thick-soled shoes and shock absorbers to relieve pressure points
• Recommend topical emollient creams, e.g. 99% DMSO or aloe vera, applied at least once daily or topical corticosteroids in cases of painful erythema or if symptoms; pain medicines may also be required
• Podiatrist consultations, as required
• Evening administration of sunitinib may reduce symptoms as maximum plasma concentrations will be reached during the night
• Delay dose in patients with painful calluses (dose reductions are required rarely, usually following the first treatment cycle). Where lesions are very painful, treatment should be interrupted for 1–2 weeks |
| Skin toxicity, e.g. dermatitis, hair/skin discolouration | • Advise patients about possible changes in skin and hair pigmentation | • Low-dose systemic steroids, e.g. oral prednisolone, and local application of emollient creams recommended for mild-to-moderate toxicity
• If severe symptoms occur, discontinue treatment and prescribe corticosteroids, then reintroduce sunitinib gradually |
| Oral changes, e.g. stomatitis/ulceration, pain, taste disturbance | • Educate patients on possible symptoms
• Recommend switching to paediatric toothpaste and a soft toothbrush and avoidance of alcohol | • Delay or reduce dose in patients with grade 3 oral AEs
• Prescribe non-alcoholic (bicarbonate) mouthwashes containing paracetamol with morphine or codeine for symptom control, Gelclair, viscous local anaesthetic gels (for lesions) and lip creams/balms (for cheilitis). Camomile, sage, arnica and zinc may also be beneficial |
| Hypertension | • Conduct a full cardiovascular assessment before treatment initiation
• Treat unstable hypertension. If BP ≥140/80 mmHg, delay treatment
• Increase dose of current anti-hypertensive therapy if appropriate | • Monitor patients regularly for BP (daily or three times per week)
• Increase dose of existing antihypertensive if required and monitor in case of dose reduction/interruption of targeted therapy
• Interrupt treatment or reduce dose in cases of hypertension that can not be controlled by two drugs at maximum dose or when accompanied by signs/symptoms of end organ damage or cardiovascular morbidity |
| LVEF decline | • Delay treatment in patients showing symptoms of CHF
• If LVEF <50%, delay treatment until LVEF controlled | • Assess patients for signs and symptoms of LVEF and CHF, particularly in patients with cardiac risk factors
• Interrupt/reduce dose if LVEF ≤50% and >20% below baseline
• Dyspnoea, fatigue and oedema may suggest CHF, but can have other causes in cancer patients. Sunitinib should be discontinued in patients showing symptoms of CHF |
HFS: hand-foot syndrome; DMSO: dimethyl sulphoxide; AE: adverse event; LVEF: left ventricular ejection fraction; BP: blood pressure; CHF: congestive heart failure
* Based on information from the sunitinib SPC, 2008 [5], Négrier and Ravaud, 2007 [24] and the author’s opinion.
**Hand-foot syndrome**
HFS typically presents as painful erythema and oedema on the palms and soles, usually preceded or accompanied by paraesthesias (tingling sensations and intolerance to heat), and often associated with hyperkeratosis and desquamation. Pre-existing corns and calluses may predispose patients to symptoms on the soles of the feet.
HFS typically presents after 3-4 weeks of treatment and appears to be dose dependent, with symptoms resolving after treatment discontinuation.
Patients should be advised to relieve pressure on affected areas and apply topical creams. Patients should also be educated regarding other potential skin toxicities and their management (see Table 2) [24].
**Oral changes**
Oral changes including dysgeusia (taste disturbance), sensitivity and occasional sores including cheilitis (inflammation and cracking of the lips) can occur with sunitinib therapy. Symptoms typically appear within 1-2 weeks of treatment initiation but can occur variably during and between cycles and usually resolve after 1 week off treatment.
Good oral hygiene helps to reduce the incidence of oral changes. Treatment is generally palliative, including mouth-washes and anaesthetic gels (see Table 2) [24].
**Cardiotoxicity**
All patients should undergo a full cardiovascular examination before beginning sunitinib therapy, with regular blood pressure monitoring during treatment (see Table 2).
Hypertension can be managed easily during sunitinib treatment, through the use of appropriate antihypertensive medicines [24].
Patients with pre-existing or recent cardiovascular disease are usually excluded from sunitinib trials but may be considered for sunitinib treatment in clinical practice. These patients may be at higher risk of developing left ventricular systolic dysfunction and should undergo baseline and periodic evaluations for left ventricular ejection fraction [24].
**Fatigue**
Fatigue occurs commonly in cancer patients due to a variety of causes. Sunitinib-related fatigue typically occurs 2-3 weeks after treatment initiation, may worsen during weeks 3 and 4 and, in some patients, may improve during the 2-week off-treatment period.
Raising awareness of fatigue is important to manage patients’ expectations so that they can make any necessary lifestyle adjustments. Patients should be evaluated for potential causes of fatigue, such as depression, hypothyroidism and anaemia, and these should be managed appropriately [24].
**Hypothyroidism**
Hypothyroidism can be managed effectively with levothyroxine. Patients already receiving treatment for hypothyroidism must receive regular ongoing monitoring of their thyroid hormone levels. Levothyroxine dose should be adjusted in line with any changes in hormone levels [24].
**Practical measures can be adopted to minimise the impact of potential AEs.**
Pharmacists can help by ensuring that regular monitoring is performed to detect any thyroid function abnormalities, enabling prompt corrective measures to be initiated.
**Diarrhoea**
Diarrhoea usually occurs within 2-5 days of sunitinib treatment initiation and is typically mild-to-moderate in intensity; symptoms usually improve during the off-treatment period.
Antidiarrhoeal drugs, such as loperamide, may be administered at a starting dose of 4 mg, followed by 2 mg as required up to a maximum daily dose of 16 mg. Patients should avoid spicy food, dairy products and citrus fruits [24].
**Haematological abnormalities**
Anaemia, neutropenia and thrombocytopenia have been observed during sunitinib treatment. Onset of non-febrile neutropenia and thrombocytopenia typically occur during Cycle 1 without subsequent progression. These changes usually resolve during off-treatment periods but may recur [24]. More progressive, cumulative neutropenia may also occur in a limited number of patients receiving prolonged treatment.
Patients with non-febrile neutropenia should maintain good personal hygiene and avoid exposure to infectious diseases. They should also avoid uncooked or unwashed vegetables and unpasteurised dairy products.
Patients with thrombocytopenia should minimise the risk of bleeding, for example by brushing teeth gently with a soft toothbrush, avoiding the use of dental floss and avoiding forceful coughing and straining with bowel movements.
Anaemia can be treated according to local treatment guidelines.
**Conclusions**
Sunitinib is the standard treatment for the first-line treatment of advanced RCC. Temsirolimus is recommended for patients with (modified) poor-risk mRCC and sorafenib for second-line treatment. Bevacizumab plus IFN-α2α is another option for
first-line treatment, while sunitinib represents an alternative for second-line treatment.
Sunitinib is associated with an acceptable tolerability profile. Further, practical measures can be adopted to minimise the impact of potential AEs and avoid the need for dose reductions or delays, thereby maximising patient benefit. Pharmacists can play a key role in optimising patient management by educating patients about expected treatment outcomes and AE management, and by ensuring that relevant patient data are available to clinicians.
Author
Professor Sylvie Négrier, MD, PhD
Medical Oncology Department and INSERM 590 Unit
Centre Léon-Bérard and Université Lyon 1
Centre Léon Bérard
F-69373 Lyon Cedex 08, France
firstname.lastname@example.org
Acknowledgement
Editorial assistance was provided by Acumed® (Tytherington, UK) with funding from Pfizer Inc.
References
1. Motzer RJ, Bander NH, Nanus DM, et al. Renal-cell carcinoma. *N Engl J Med.* 1996;335:865-75.
2. Ferlay J, Autier P, Boniol M, et al. Estimates of the cancer incidence and mortality in Europe in 2006. *Ann Oncol.* 2007;18:581-92.
3. Ljungberg B, Hanbury D, Kuczyk M, et al. Renal cell carcinoma guideline. *Eur Urol.* 2007;51:1502-10.
4. Coppin C, Porzsol F, Awa A, et al. Immunotherapy for advanced renal cell cancer. *Cochrane Database Syst Rev.* 2005;CD001425.
5. Pfizer Inc. SUTENT (sunitinib) SPC, January 2008.
6. Motzer RJ, Hutson TE, Tomczak P, et al. Sunitinib versus interferon alfa in metastatic renal cell carcinoma. *N Engl J Med.* 2007;356:115-24.
7. Figlin RA, Hutson TE, Tomczak P, et al. Overall survival with sunitinib versus interferon (IFN)-alfa as first-line treatment of metastatic renal cell carcinoma. Oral (abstract 5024). Presented at the 44th ASCO Annual meeting, Chicago, USA, May 30-June 3, 2008.
8. Négrier S, Figlin RA, Hutson TE, et al. Overall survival with sunitinib versus interferon alpha as first-line treatment of metastatic renal cell carcinoma. Poster (abstract 588). Presented at the 33rd ECMO Congress, Stockholm, Sweden, 12-16 September 2008.
9. Motzer RJ, Michaelson MD, Rosenberg J, et al. Sunitinib efficacy against advanced renal cell carcinoma. *J Urol.* 2007;178:1883-7.
10. Hariharan S, Szczyluk C, Porta C, et al. Sunitinib in metastatic renal cell carcinoma patients with brain metastases: data from an expanded access trial. Poster (abstract 5094). Presented at the 44th ASCO Annual meeting, Chicago, USA, May 30-June 3, 2008.
11. Bayer Healthcare AG. Nexavar (sorafenib) SPC, April 2008.
12. Escudier B, Eisen T, Stadler WM, et al. Sorafenib in advanced clear-cell renal-cell carcinoma. *N Engl J Med.* 2007;356:125-34.
13. Bukowski R, Szczyluk C, Stadler W, et al. Final results of the randomized phase III trial of sorafenib in advanced renal cell carcinoma: survival and biomarker analysis. Oral (abstract 5023). Presented at the 43rd ASCO Annual meeting, Chicago, USA, June 1-5, 2007.
14. Escudier B, Szczyluk C, Demkow T, et al. First-line phase II study of sorafenib versus interferon-a2a in patients with unresectable and/or metastatic renal cell carcinoma. Presented at the 5th International Symposium on Targeted Anticancer Therapies, Amsterdam, The Netherlands, 8-10 March 2007.
15. Ryan CW, Bukowski RM, Figlin R, et al. The Advanced Renal Cell Carcinoma Sorafenib (ARCCS) expanded access trial: long-term outcomes in first-line patients. *J Clin Oncol.* 2007;25:5096.
16. Hiles JJ, Kolesar JM. Role of sunitinib and sorafenib in the treatment of metastatic renal cell carcinoma. *Am J Health-Syst Pharm.* 2008;65:123-31.
17. Wyeth Pharmaceuticals Inc. Torisel (temsirolimus) SPC, November 2007.
18. Hudes G, Carducci M, Tomczak P, et al. Temsirolimus, interferon alfa, or both for advanced renal-cell carcinoma. *N Engl J Med.* 2007;356:2271-81.
19. Roche Products Ltd. Avastin (bevacizumab) SPC, August 2008.
20. Escudier B, Pluzanska A, Koralewski P, et al. Bevacizumab plus interferon alfa-2a for treatment of metastatic renal cell carcinoma: a randomised, double-blind phase III trial. *Lancet.* 2007;370:2103-11.
21. Rini BI, Halabi S, Rosenberg JE, et al. Bevacizumab plus interferon alfa compared with interferon alfa monotherapy in patients with metastatic renal cell carcinoma: CALGB 90206. *J Clin Oncol.* 2008;26:5422-8.
22. National Comprehensive Cancer Network. NCCN clinical practice guidelines in oncology: kidney cancer v.1.2009. National Comprehensive Cancer Network: http://www.nccn.org/professionals/physician_gls/PDF/kidney.pdf
23. Porta C, Szczyluk C, Bracarda S, et al. Short- and long-term safety with sunitinib in an expanded access trial in metastatic renal cell carcinoma. Poster (abstract 5114). Poster (abstract 5094). Presented at the 44th ASCO Annual meeting, Chicago, USA, May 30-June 3, 2008.
24. Négrier S, Ravaud A. Optimisation of sunitinib therapy in metastatic renal cell carcinoma: adverse-event management. *Eur J Cancer Suppl.* 2007;5(7):12-9.
Non-compliance in cancer treatment
Partnership between physician and patient is always helpful, but may be vital in oncology. Non-compliance can be amazingly high, especially long term.
A common definition of compliance is the extent to which patients follow treatment instructions. Poor compliance with medical regimens is a significant problem, estimated to cost the US economy over US$100 billion (Euros 70,000 million) annually.
The patient’s active participation in the treatment is especially important during anticancer chemotherapy, which depends on high doses of toxic cytostatics and other drugs with a narrow therapeutic index. Delays in cancer diagnosis and treatment are related to a variety of factors including cultural influences, fear of cancer, financial hardship or availability and access to health care [1, 2].
In general the rate of compliance with oral drugs lies between 19% and 100% and depends on the specific clinical situation, nature of the illness and the treatment. Non-compliance with tamoxifen therapy regimens ranges between 15% and 50% when followed up at two and five years [1, 3, 4].
There are two types of non-compliance. The first one is intentional non-compliance where the patients make a specific decision not to take the prescribed medicine. It may involve a reasoned and intentioned decision by patients to omit a dose of medicine because they are asymptomatic or taking the medicine interferes with their lifestyle. The second type is non-intentional non-compliance. It is the result of forgetting or misunderstanding instructions about the drug schedule, e.g. the patient fails to obtain or to take the medicine as prescribed (in the correct dose, at the correct time), prematurely discontinues the medicine or takes the medicine inappropriately [3].
Many factors are associated with non-compliance. Knowing the main reasons for drug discontinuation may help identify those patients at risk who might benefit from special attention to compliance issues:
1. Sociodemographic factors: younger, female, fewer than 10 years of education, marital status, race, cultural influences
2. Discomfort resulting from treatment. When there is considerable efficacy, mild to moderate reactions are tolerated; however when efficacy is limited or absent, mild toxicity can lead to non-compliance. Compliance is less likely where the benefits of drugs are not obvious, e.g. a five-year hormone breast cancer regimen does not guarantee recurrence-free survival but does produce side effects
3. Preference for non-conventional forms of treatment
4. Similar pills
5. Personal judgments about the efficacy of the proposed treatment, e.g. positive-node status means complete curing
6. Unstable life mode, irregular working hours, maladaptive coping styles, e.g. denial of illness, disruptive schedules
7. Mental disorder, e.g. depression: compared with non-depressed patients, depressed patients are three times more likely to be noncompliant
8. Psychological reasons (patients with greater control over their life are more likely to comply, women who have had surgery and chemotherapy not wanting to continue hormone regimens because tablet taking is a reminder of cancer)
9. Insufficient explanation of therapeutic decisions, disturbance in the doctor-patient communication, too many doctors treating the patient.
Today the increase in patient autonomy has led to the terms ‘concordance’ and ‘adherence’ replacing the more authoritarian term ‘compliance’. The most common definition of adherence is ‘the extent to which a person’s behaviour coincides with medical or health advice’ [3, 4]. The UK Medicines Partnership defines drug concordance as “an agreement reached after negotiation between a patient and a healthcare professional that respects the beliefs and wishes of the patient in determining whether, when and how medicines are to be taken” [5].
Author
Lukasz Lapinski, MPharm, PhD
Department of Clinical Pharmacology
Wroclaw Medical University
1 Pasteura St
PL-50367 Wroclaw, Poland
email@example.com
References
1. Hoffman M, Levin TT. Doctor, I don’t want chemotherapy. J Support Oncol. 2005;3(2):97-8.
2. Patridge AH, Wang PS, Winer EP, Avorn J. Non-adherence to adjuvant tamoxifen therapy in women with primary breast cancer. J Clin Oncol. 2003;21(4):602-6.
3. Atkins L, Fallowfield L. Intentional and non-intentional non-adherence to medicine amongst breast cancer patients. Eur J Cancer. 2006;42:2271-6.
4. Li BD, Brown WA, Ampil FL, et al. Patient compliance is critical for equivalent clinical outcomes for breast cancer treated by breast-conservation therapy. Ann Surg. 2000;231(6):883-9.
5. www.npc.co.uk/med_partnership/about-us/concordance.html [cited 2008 July 28].
Nuclear medicine needs radiopharmacists!
Having a radiopharmacist as part of the team at a large teaching hospital brings added value. After all, the radiological requirements of a product are additional to the usual pharmaceutical requirements. Research success is also possible when experts in several fields work together.
**Introduction**
A radiopharmaceutical is a medicinal product that contains a radionuclide. Radioactive materials are often associated with the treatment of cancer. However, the vast majority (~80%) are used in diagnostic techniques for a wide range of diseases (see Figure 1). Of these, the majority are used in imaging techniques. In comparison, a small but very important number are used for therapy.
Radionuclides used in medicine have limited physical lives meaning that their radioactivity declines relatively quickly. Radiopharmaceuticals usually consist of two parts: a tissue-specific molecule and a radionuclide. After injection into the patient, the tissue-specific part concentrates the radiopharmaceutical in the tissue under investigation, where the radiation emitted by the radionuclide is used for imaging in a diagnostic study or to destroy harmful cells in radiotherapy. In conventional imaging with radiopharmaceuticals that contain gamma-emitting radionuclides, the photons emitted are detected by an instrument known as a Gamma camera and an image of the organ is constructed (see Figure 2). More recently, positron emission tomography (PET) has entered the market with detection of photons emitted by the annihilation reaction between a positron and an electron in the body. This instrumentation affords better resolution, higher sensitivity and uses radiopharmaceuticals that consist of radio-labelled molecules that are very similar in chemical structure to endogenous substances or drugs [1].
The limited physical half-life means that the radiopharmaceutical must usually be formulated close to the patient in hospital. Radiopharmacists have a crucial role in radiopharmaceutical production but their roles in the nuclear medicine department are numerous. The pharmacist is close to both production and quality assessment but also to the patients undergoing examination. The profile of tasks is of interest to the discipline of hospital pharmacy and of great importance for a quality clinical nuclear medicine department that wishes to achieve high quality examinations.
**Safety and efficacy**
The principal role of the pharmacist in nuclear medicine is no different to other branches of medicine - to ensure safety and efficacy. Safety of the patient includes for example ensuring that the product is sterile, free from particles and has the correct activity.
Safety of the members of staff working in the radiopharmacy is also an important responsibility. Efficacy means that the radiopharmaceutical behaves as expected when it is administered to the patient.
**The radiopharmacy sequence**
**Radiopharmacy procurement**
In several countries the ordering of radiopharmaceuticals is the responsibility of the local hospital pharmacy. The radiopharmacist may also have the task of ensuring compliance with the regulations relating to the receipt, storage and disposal of radioactive materials and is responsible for the quality of the starting materials.
**Receipt of order/prescription**
The nuclear medicine physician must be authorised to prescribe radiopharmaceuticals. As with professional checking of any prescription, there is the need to confirm that the prescribed radioactivity dose is appropriate for the indication and that the radiation dose is within limits to afford a valuable investigation without harming the patient.
**Preparation**
The radiopharmacist is responsible for radiopharmaceutical production or has a release function for products prepared in the radiopharmacy. He is also responsible for ensuring that the products are manufactured according to Good Manufacturing Practice (GMP) with respect to documented and validated methods with adequate quality control and undertaken in facilities for aseptic production by personnel educated and certified for radiopharmacy work.
**Safe procedures**
Working techniques must be monitored not only with respect to aseptic preparation but also radiation safety. Usual methods to ensure radiation safety are radiation shielding, handling techniques, monitoring for contamination with radioactivity and the dose received by members of staff.
Radiopharmaceuticals are produced in special units for aseptic production similar to those for cytotoxic drug preparation. Adequate protective clothing, proper working techniques and a monitored environment are essential for good quality. Regular testing is required as for any other pharmaceutical production of sterile medicines.
**Quality control**
There is a limited time available for quality control (QC) tests before the product is delivered to the patient examination area. All procedures must be thought through carefully. The whole
batch is often one vial! The radiopharmacist has to check the radionuclide identity and purity, do all the normal QC checks as well as a radioactivity and endotoxin check within a very short time frame and with minimal exposure of the staff to radiation.
**Quality assurance**
The education of the pharmacist provides an expert basis for quality assessment and management. Expertise in GMP and other regulations governing aseptic small scale extemporaneous production is essential to ensure that products meet the required standards.
Quality assurance is the only task for many hospital pharmacists in the nuclear medicine department. This is not enough. Only by experiencing the daily routine of radiopharmaceutical preparation and assessment of quality can the radiopharmacist gain the expertise to adequately handle problems and questions that arise.
**Transport**
The specialised nature of radiopharmacy means that products are often prepared in a central radiopharmacy and transported to nuclear medicine departments in other hospitals. The radiopharmacist is responsible for ensuring that transport of radioactive materials by road complies with the complex set of regulations.
**Injection into the patient**
The radiopharmacist must also work as a clinical pharmacist in the wards and clinics. Drugs taken by the patient are known to affect the biodistribution of certain radiopharmaceuticals. The pharmacist may advise on interactions and suggest better dosing schemes or drugs. Advice on thyroid blocking can also be requested when a radiopharmaceutical containing a radioisotope of iodine is being administered.
**Reporting**
The radiopharmacist also plays a part in the final image and quality assessment. Advice may be requested to explain an unusual biodistribution of the radiopharmaceutical that affects the reporting of the investigation. The further reporting of the unusual biodistribution is also important and there is a European scheme for this. Mistakes in radiopharmaceutical production are rare but must be considered carefully.
Although adverse reactions to radiopharmaceuticals are relatively rare, their reporting is valuable and again, there is a European scheme for this.
**Research and development of radiopharmaceuticals**
In addition to the routine preparation of radiopharmaceuticals, radiopharmacists have made important contributions to research and development. The projects arise mainly from two sources:
- Products manufactured in the hospital radiopharmacy
- Products prepared for use in research
This is perhaps the part of the job from which the radiopharmacist derives the greatest satisfaction, and can be illustrated by the following example.
A breast surgery department requested $^{99m}$Tc albumin nanocolloid for intraoperative localisation of sentinel nodes. As the members of staff in this department were unfamiliar with handling radioactive material, supplying the product in unit dose syringes seemed the most appropriate means of minimising their radiation exposure. Measurements were made in the radiopharmacy to validate a syringe as a suitable container: adsorption of the radiocolloid to the syringe, labelling efficiency by thin-layer chromatography and particle size by Nucleopore filtration and photon correlation spectroscopy. This radiopharmaceutical is now supplied routinely in syringes [2].
Another example that required scientific investigation arose from the identification of a poor quality product. Routine measurements of the radiochemical purity of the renal imaging agent $^{99m}$Tc-MAG3 revealed occasional unacceptably high levels of a lipophilic impurity. The reason for this was traced to a compound that leached from the rubber tips of syringes used in reconstitution of MAG3 kits. Elimination of the problem was achieved by using two-piece syringes [2]. Occasional low radiochemical purity has also been observed when MAG3
kits are reconstituted with sodium chloride injection from plastic ampoules. Investigation of this phenomenon revealed that this occurred with plastic ampoules that had been exposed to light. The problem was overcome if either plastic ampoules are protected from light or sodium chloride injection from glass containers is used [3].
An example of radiopharmaceutical development is $^{177}$Lutetium-radiolabelled octreotate which is now used in many nuclear medicine centres (see pages 16-17), for treatment of endocrine tumours.
PET is still a very powerful research tool and PhD projects conducted by pharmacists are common in many centres around the world.
**Conclusion**
Expertise and inter-profession collaboration are essential for added value in radiopharmaceuticals preparation, handling and examination. PET technology is a new field of calling. The fascinating work of a radiopharmacy department such as might be found at a university hospital where research is conducted is a challenge for radiopharmacy but also for young colleagues interested in clinical pharmacy. Routine production of radiopharmaceuticals is largely automated for reasons of safety and speed. Therefore, the pharmacist’s expertise may be called upon firstly to help design the building in which the cyclotron is sited and the products prepared; to design the production process and quality control procedures to meet all the applicable regulations, and to collaborate with physicians. The latter usually means devising a suitable radiopharmaceutical for a particular diagnostic test or research projects. Such multidisciplinary work is vital for the success of the nuclear technique, and requires pharmacists who are experts in this field. Nuclear medicine is calling for radiopharmacists!
**Authors**
Professor Per Hartvig-Honré, PharmD, PhD
Alistair M Millar, PhD. FRPharmS
Principal Radiopharmacist
The Royal Infirmary of Edinburgh
51 Little France Crescent
Old Dalkeith Road
Edinburgh EH16 4SA, Scotland, UK
firstname.lastname@example.org
**References**
1. Per Hartvig. PET in oncology Eur J Oncol Pharm. 2008;2(1):36-8.
2. O’Brien LM, Duffin R, Millar AM. Preparation of 99mTc-Nanocoll for use in sentinel node localization. Nucl Med Commun. 2006;27:999-1003.
3. Waight CC, Beattie LA, O’Brien LM, Millar AM. Preparation of 99mTc-MAG3: radiochemical purity is affected by the residence time of sodium chloride injection in a three-part syringe. Nucl Med Commun. 2006;27:197-200.
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**Radiotherapy of neuroendocrine gastro-enteropancreatic tumours: new principles**
Somatostatin analogue vectors carry radioactive chemicals to their target, improving the treatment of neuroendocrine gastro-enteropancreatic tumours.
Neuroendocrine gastro-enteropancreatic tumours constitute a heterogeneous group of tumours that originate from the neuroendocrine system in the gastrointestinal tract. Gastrinomas, insulinomas, carcinoids, glucagonomas, somatostatinomas and some other non-classified tumours are among the tumours classified as neuroendocrine. The tumours are often difficult to diagnose and cause high morbidity and mortality with a five-year survival of 50% [1, 2]. Today surgical resection offers the only possibility of curing patients with neuroendocrine tumours. Unfortunately, not all tumours are available for surgery and moreover these tumours have a tendency to form metastases and produce hormones. Other treatment alternatives such as cytotoxic drugs, immunomodulators, e.g. interferon, and radiation therapy have been tried but have shown limited success on disease progression and survival.
Human somatostatin is a 14-amino-acid cyclic peptide with a single disulfide bridge. It belongs to a family of peptides with variable molecular weights. The larger forms are classified as hormones. The elimination half-life of the natural hormone somatostatin is only a few minutes, making it of no value in routine therapy. Octreotide has a half-life of several hours, making intermittent therapy possible. Somatostatin analogues such as octreotide and lanreotide have been used clinically to treat gastro-enteropancreatic tumours since the
early 1980s. The analogues are synthetic somatostatin-octapeptide derivatives with structure and activity similar to the somatostatin hormone and have both cytostatic and cytotoxic effects on the tumour cells. The drugs give symptom relief, increase survival time, but give no cure [3].
In recent years there has been increased interest in tumour-directed radiotherapy using somatostatin analogues as radioactivity vectors. A number of preparations such as $^{111}$Indium DTPA-octreotide, $^{90}$Yttrium DOTA-octreotide and later $^{177}$Lutetium DOTA-octreotate have been developed with promising clinical results [4, 5]. DTPA and DOTA are ligands designed to bind radioactive chemicals to somatostatin analogues. Studies have reported a 50% clinical and biochemical improvement in patients with neuroendocrine gastro-enteropancreatic tumours. The somatostatin analogue, coupled to optimal radioactivity, has limited uptake in surrounding tissues such as the bone marrow and kidneys and maximum uptake in the tumour.
($^{177}$Lutetium-DOTA(O)Tyr3) octreotate, developed in The Netherlands, is an improvement and is used by several sites in Europe. $^{177}$Lutetium has a physical half-life of 6.7 days and decays by beta particle emission with a mean energy of 0.149 MeV and gamma emission with a mean energy of 0.208 and 113 MeV. The range of $^{177}$Lutetium is eight millimetres in air and two millimetres in water. This is important for the treatment of small tumours.
Experimental and clinical studies have shown that the somatostatin analogue Tyr3 chelated with DOTA has a significantly higher affinity for somatostatin receptors than the Tyr3-octreotide. Compared with $^{111}$Indium-octreotide a three to four times higher uptake can be obtained using $^{177}$Lutetium-octreotate but with a similar biodistribution in other tissues such as the liver, spleen and kidneys. The elimination of $^{177}$Lutetium-octreotate is faster than that of the $^{111}$Indium-octreotide analogue and gives a significantly lower 24 hour urinary excretion fraction. Further advantages of $^{177}$Lutetium-octreotate to $^{111}$Indium-octreotide are significantly more efficient tumour inhibition in animal models, allowing the dose to be measured accurately and making studies with positron emission tomography possible using the same radionuclide [6]. The tissue penetration of $^{177}$Lutetium is better than that for $^{90}$Yttrium particularly for smaller tumours where a large proportion of the ionisation radiation from $^{90}$Yttrium is lost in surrounding tissue (see Figure 1).
Because of these advantages, $^{177}$Lutetium-octreotate is therefore a promising new alternative in the treatment of neuro-endocrine tumours.
...........................................................................................................
**Authors**
Assef Cherif
Radiopharmacist
Hospital Pharmacy and Department of Nuclear Medicine
Uppsala University Hospital
SE-75185 Uppsala, Sweden
Professor Per Hartvig-Honoré, PharmD, PhD
Professor in Pharmacokinetics
Hospital Pharmacy and Department of Nuclear Medicine
Uppsala University Hospital
SE-75185 Uppsala, Sweden and
Department of Pharmacology and Pharmacotherapy, FARMA
University of Copenhagen
2 Universitetsparken
DK-2100 Copenhagen, Denmark
email@example.com
**References**
1. Godwin JD, 2nd. Carcinoid tumors. An analysis of 2,837 cases. Cancer. 1975;36(2):560-9.
2. Tomassetti P, Migliori M, Lalli S, et al. Epidemiology, clinical features and diagnosis of gastroenteropancreatic endocrine tumours. Ann Oncol. 2001;12(Suppl 2):S95-9.
3. Oberg K, Kvols L, Caplin M, et al. Consensus report on the use of somatostatin analogs for the management of neuroendocrine tumours of the gastroenteropancreatic system. Ann Oncol. 2004;15(6):966-73.
4. Krenning EP, Bakker WH, Breeam WA, et al. Localisation of endocrine-related tumours with radiiodinated analogue of somatostatin. Lancet. 1989;1(8632):242-4.
5. Krenning EP, Valkema R, Kooij PP, et al. Scintigraphy and radionuclide therapy with [indium-111-labelled-diethyl triamine penta-acetic acid-D-Phe1]-octreotide. Ital J Gastroenterol Hepatol. 1999;31(Suppl 2):S219-23.
6. Eriksson B, Bergstrom M, Sundin A, et al. The role of PET in localisation of neuroendocrine and adrenocortical tumours. Ann N Y Acad Sci. 2002;970:159-69.
The United Kingdom is seeking to establish standards and accreditation in the competency of oncology pharmacists, in moves that run parallel to those of ESOP (see pages 4-6). The Faculty of Cancer Pharmacy has been formed to improve patient care by providing the opportunity for pharmacists and technicians in the field of cancer care to undertake accredited training and assessment, leading to formal recognition of their knowledge and skills. This body is a joint venture between the British Oncology Pharmacy Association (BOPA) and the College of Pharmacy Practice, an independent professional association for pharmacists [1]. It was formally launched in January 2008 at the Hospital Pharmacy Conference. The six members of the faculty board were chosen by the BOPA membership and held their first meeting in April.
**Assessment process**
A number of standards within practice, or frameworks, have already been developed by the Competency Development and Evaluation Group of the college and have received national recognition [2]. The frameworks have been validated through practice research. The faculty board has decided to adopt these competency standards, known as the General Level Framework and the Advanced and Consultant Level Framework (ACLF) to support the assessment of aspiring members. The General Level Framework has been shown to improve the practice of newly qualified pharmacists [3] and the ACLF to describe different levels of practice consistently across various pharmacy specialities [4]. These competency frameworks describe competencies for pharmacists across a number of domains encompassing clinical knowledge, managerial and leadership functions as well as educational and research roles. Specific cancer-related pharmacy competencies at Foundation, Excellence and Mastery levels previously published by BOPA [5] add to these frameworks by providing oncology-specific clinically oriented competencies for pharmacists to focus on.
**How accreditation is gained**
Prospective candidates self assess their practice against the frameworks and submit a portfolio of evidence to substantiate their perceived level of practice. This is examined by two acknowledged cancer pharmacy experts appointed by the faculty who together with a third assessor appointed by the college from a different speciality, with experience of assessment, will interview the candidate to clarify any issues raised by examining the portfolio and to agree the level of membership conferred.
Accreditation is offered as membership of the College of Pharmacy Practice. There are three levels: Practitioner Member, assessed using either the general level framework or the foundation elements of the ACLF; Advanced Membership and Fellowship of the College are assessed using a defined combination of Excellence and Mastery clusters of the ACLF.
**Accreditation of educational materials and events**
The Faculty also aims to support the professional development of pharmacists within the field of cancer pharmacy by providing accreditation of both educational materials and events. To do this it is drawing together existing materials from the College of Pharmacy Practice, BOPA, the Pharmaceutical Society of Great Britain and the Department of Health’s Knowledge and Skills Framework.
**Conclusion**
BOPA and the Faculty of Cancer Pharmacy firmly believe that a robust and aspirational accreditation system is the correct path forward for pharmacists specialising in the area of oncology. We believe the process will be credible to our own profession, and to the multidisciplinary team. We think the benefits of such a process are:
- Recognition that comes with membership of a prestigious speciality body
- Additional recognition for high-level achievement, e.g. fellowship or merit awards
- A focus for developing and delivering professional views plus input into national initiatives and policy development
- A professional network for peer support, peer review and peer pressure, linking into clinical governance agenda
- Accredited commissioning and/or delivery of education and training targeted at specialist needs
- Improving patient care.
To date one fifth of UK oncology pharmacy staff who are members of BOPA have shown a commitment to specific oncology pharmacy accreditation by joining the Faculty of Cancer Pharmacy as associate members with the expectation that they will proceed to full membership through the assessment process previously described. An opportunity has arisen to work with oncology pharmacists practising in Australia. With the emigration of one of the founding members of the faculty it is hoped that existing links with cancer pharmacists in Queensland can be used to replicate the UK initiative.
Europa Uomo in collaboration with ESOP
Europa Uomo is a confederation of patient support groups in 21 European countries. We inform and educate our members with the support of professional bodies. Closer collaboration with the ESOP is overdue and joint projects will be started in the near future.
Europa Uomo was officially established with the support of the European School of Oncology (ESO) and the Oncology Center Antwerp (OCA) in 2004 [1, 2]. The need for a European patient support group, following the example of our sister organisation Europa Donna, became clear in view of the ever-increasing diagnosis of prostate cancer in European men. Indeed the cancer statistics show that cancer affects one in three European citizens and kills one in four people. More to the point, breast, colon, lung and prostate cancers are the most common forms of cancer as they account for more than half of the entire cancer population in the European Union. Prostate cancer is by far the most frequently diagnosed form of cancer in men (24.1% of all cases and 10.4% of cancer deaths). The difference adds up to the prevalence and we estimate that more than three million prostate cancer survivors live in Europe [3].
Europa Uomo, the European Prostate Cancer Coalition, represents and supports national patient groups focused on prostate diseases in general and prostate cancer in particular. Our aims are simple. First, to develop individualised prostate cancer treatment based on the best medical treatment as recognised in official guidelines and good clinical practice. This treatment results from experts working closely as a multi-professional group and provides patient advocates and support groups with a biannual update on medical sciences and practice of their peers. We have a scientific committee of European experts to provide this constructive service. The other side of the coin is evidence-based, holistic patient care where each and every one of us should be involved as a partner with the professionals. In the period 2008-2009 we are basing our awareness on the key points provided by the European Association of Urology and presented below.
**Defined Key Topics 2008-2009**
**Prostate conditions**
- Most men will develop benign prostate disease and many of them will develop complaints for which both medical and surgical treatments are available and are highly effective.
- Prostate cancer can only be cured when it is detected in its early stages, i.e. when the disease is organ-confined; these treatments are often curative. PSA and PSA kinetics - PSA velocity or PSA doubling time - are helpful tools to recognise patients at risk of having prostate cancer.
- Cancers diagnosed by early detection programmes do not always need treatment. Active monitoring for selected patients is a reasonable option that still allows to initiate curative treatment during follow-up when needed.
- Hormonal therapy affects the quality of life severely but when it is needed, the side effects can be reduced by instruction about nutrition, physical activity and psychological support.
- A family history of prostate cancer may be significant; please check your sons and brothers.
**Incontinence**
Bladder symptoms are common in men in the age group when prostate disease occurs. They may be related to overactivity of the bladder rather than to prostate disease and are amenable to treatment. This should be checked since specific treatment is indicated.
Erectile dysfunction (ED)
- ED may be the presenting symptom of hypertension, hyperlipidaemia, diabetes and hormonal changes. It is important that all men with ED are assessed for the presence of such conditions.
- The urologist is the specialist who can best advise on the prevention and control of both lower urinary tract symptoms and ED, which are commonly associated with each other.
Our rapid expansion is not only based on committed, free, professional support, the recognition of the cancer patients’ rights by the European Commission and Parliament but also by our internal basic discipline as expressed in our Manifesto (see below). It took more than a year to agree on the text, and quality of life did not arrive at the number one point by accident. You cannot be a member if you don’t subscribe to these 10 basic rules.
**Europa Uomo Manifesto**
1. To find ways and means of promoting quality of life for prostate cancer patients and their families
2. To promote the dissemination and exchange of evidence-based, factual and up-to-date information on prostate cancer
3. To promote prostate awareness and the adoption of appropriate diagnoses and prognoses
4. To emphasise the need for appropriate early detection
5. To campaign for provision of and access to the best treatment
6. To ensure quality, supportive care throughout and after treatment
7. To promote multi-professional quality care and appropriate medical infrastructure
8. To acknowledge good clinical practice and promote its development
9. To ensure that all men fully understand any proposed treatment options, including entry into clinical trials and their right to a second opinion
10. To promote the advance of prostate cancer research.
It is also clear that the last point is no accident as we solidly support scientific research. We are painfully aware that the lack of a reliable marker for the future aggressivity of any tumour leaves all of us in limbo. Fortunately we see progress after each and every cancer meeting but a broad, in-depth reappraisal of the therapeutic and pharmacological options is needed. Just think of the time and money it takes for an hypothetical drug to reach the bedside of the patient. Fellow survivors cannot afford a waste of time and look for an appropriate reduction in time and expense between the laboratories and the bedside. We are active partners in the Transmark project of Professor C Bangma in the call FP7-PEOPLE-ITN-2008.
We have a number of active partnerships as shown in Figure 1 but we look forward to adding ESOP to this list.
**Figure 1: Europa Uomo partnerships**
| IPHC | ECCO ('08) |
|------|------------|
| ESU | OECI |
| EAU - EONS - ESMO | Europe Uomo - ESO |
| ECPC | Cancerworld |
| Europa Donna | Eurocan+Plus |
| MAC - MEP | PROCABIO-PRIAS |
| UICC - WWPCC | IUCD |
We believe that such a partnership could help us raise the priority for off-label use of cancer drugs, cross-border treatment, complementary and alternative medicinal products and the support of hospital and community pharmacists in preventing the dissemination of misleading information and the prevention of avoidable side effects and drug interactions.
We come closer to the industry by discussing risk sharing and patients’ responsibilities in clinical trials.
We meet in a few weeks in Hamburg, Germany, and we hope that our German member Bundesverband Prostatakrebs Selbsthilfe will take on a pilot programme as a joint project.
**Author**
Professor Louis Denis
Director of Oncology Center Antwerp
Secretary of Europa Uomo
35-37 Lange Gasthuisstraat
B-2000 Antwerp, Belgium
firstname.lastname@example.org
**References**
1. Denis L. Europa Uomo. BJU Int 2007;99:1329–34.
2. www.cancerworld.org/home.asp
3. Ferlay J, Autier P, Boniol M, et al. Estimates of the cancer incidence and mortality in Europe in 2006. Ann Oncol. 2007;18:581-92.
---
**Erratum**
The EJOP apologises for having printed the wrong captions for Table 1 in the article “Tumour lysis syndrome – prevention and treatment” by Mr Michael Hoeckel in EJOP 2008;2(2):22.
The correct captions for the table are shown below.
**Table 1: Onset of clinical features of TLS**
| Clinical problem | Chemotherapy | Hyperkalaemia | Hyperphosphataemia, hypocalcaemia | Hyperuricaemia | Acute renal failure |
|---------------------------|--------------|---------------|-----------------------------------|----------------|---------------------|
| Time (days) | 0 | 0.25 – 3 | 1 – 2 | 2 – 3 | 3 – 4 |
More than 25,000 experts attended the 50th American Society of Hematology (ASH) Annual Meeting in San Francisco, USA in December 2008. Advances were discussed in the treatment of several diseases and the improved and simplified treatment of others.
The diseases for which treatment has advanced were leukaemias and lymphomas, thromboembolic disorders, severe infections, autoimmune diseases and genetic aberrations in haematological diseases. Impressive results were presented regarding more effective and less complex strategies in anticoagulation, platelet transfusion and the treatment of chronic lymphocytic leukaemia (CLL).
**Leukaemias and lymphomas: improvements in difficult-to-treat forms**
Ongoing research is focussing on new, investigational treatments as well as on new combinations of treatment options that have been used for years.
Czuczman and co-authors presented an international phase II study confirming the efficacy of lenalidomide for patients with relapsed, aggressive lymphoma. The trial included 73 patients with refractory or relapsed diffuse large B cell lymphoma (DLBCL), the most common form of non-Hodgkin’s lymphomas. All patients had received at least one prior treatment. In spite of failure of aggressive treatment such as cyclophosphamide, doxorubicin, vincristine and prednisone (CHOP) plus rituximab or high-dose chemotherapy and stem cell transplant, the overall response rate to lenalidomide was 29% (25% partial, 4% complete response). Stable disease was achieved in 15% of patients. The authors interpret these results as a possible future treatment option for highly-refractory patients suffering from this type of non-Hodgkin’s lymphoma.
**Czuczman M et al. Confirmation of the efficacy and safety of lenalidomide oral monotherapy in patients with relapsed or refractory diffuse large B cell lymphoma (Abstract #268)**
Hallek and co-workers found that in untreated patients with advanced chronic lymphocytic leukaemia (CLL) combination therapy with fludarabine, cyclophosphamide and rituximab (FCR) was significantly more effective than treatment with fludarabine and cyclophosphamide (FC) alone. After two years of follow-up the overall response rate was 95% in the FCR arm as compared to 88% in the FC arm. Complete responses were seen in 52% in the FCR group (27% in the FC group). Progression-free survival rates were 76.6% and 62.3%, respectively. The authors conclude that FCR has the potential to become the new first-line standard treatment in advanced CLL.
**Hallek M et al. Immunochemotherapy with fludarabine, cyclophosphamide and rituximab vs. fludarabine and cyclophosphamide improves response rates and progression-free survival of previously untreated patients with advanced chronic lymphocytic leukaemia (Abstract #325)**
Schrappe and co-authors presented a study on 3,655 children (ages 1-17 years) suffering from acute lymphoblastic leukaemia (ALL). They were randomised to receive either dexamethasone (10 mg/m²/d) or (the standard) prednisone (60 mg/m²/d) as part of the induction therapy in addition to vincristine, daunorubicin and L-asparaginase. After six years of follow-up patients who received dexamethasone showed event-free survival in 84.1% as compared to 79.1% in the prednisone group. The six-year cumulative incidence of relapse was 11% (dexamethasone) and 18% (prednisone). Dexamethasone treatment, however, led to higher toxicity mainly in terms of severe infections.
**Schrappe M et al. Dexamethasone in induction can eliminate one-third of all relapses in childhood acute lymphoblastic leukaemia (Abstract #7)**
**Transfusion medicine: new strategies in management of thrombocytopenic patients**
Several studies with the potential to change clinical practice presented evidence-based data to determine the optimal use of platelets or medications to be given to severely thrombocytopenic patients.
In a large multi-centre phase III trial, Zaja and co-authors could show a significantly better sustained response (platelet counts >50 x 10⁹/L from one to six months) in patients with ITP (idiopathic thrombocytopenic purpura) when dexamethasone was combined with rituximab compared to dexamethasone alone. In patients treated per protocol, a sustained response was achieved in 85% with dexamethasone/rituximab (39% with dexamethasone alone).
**Zaja F et al. A prospective randomized study comparing rituximab and dexamethasone vs. dexamethasone alone in ITP (Abstract #1)**
Slichter and co-workers proved in a large-scale clinical trial that low-dose transfusion of platelets (1.1 x 10¹¹ plt/m²) is as effective as medium- and high-dose platelets (4.4 x 10¹¹
Slichter SJ et al. Effects of prophylactic platelet dose on transfusion outcomes (Abstract #285)
Wandt and co-authors found that patients who had undergone high-dose chemotherapy and stem cell transplantation were not harmed when they received platelet transfusions only in the case of relevant bleeding (high-risk patients with e.g. sepsis or systemic aspergillosis were excluded). Compared to the control group (traditional prophylactic treatment with platelet transfusion if platelet count was <10/nL), patients in the study group received significantly fewer platelet transfusions, resulting in a total reduction by 27% in the study group. These patients experienced, though, more minor bleedings but no life-threatening or fatal bleeding. The authors conclude that one quarter to one third of all platelet transfusions are given unnecessarily.
Wandt H et al. A therapeutic platelet transfusion strategy without routine prophylactic transfusion is feasible and safe and reduces platelet transfusion numbers significantly (Abstract #286)
Cheng and co-authors showed that long-term eltrombopag therapy (versus placebo) increased platelet counts, decreased bleeding and the use of rescue medications and allowed for a reduction of baseline therapy in patients with chronic idiopathic thrombocytopenic purpura (ITP). Patients in the treatment group were eight times more likely to achieve platelet counts between 50/nL and 400/nL during the six months of treatment. Platelet counts never exceeded 30/nL in the placebo group, while median platelet counts rose from 52/nL to 91/nL in the eltrombopag group. Significantly fewer patients treated with eltrombopag experienced any bleeding. The substance seems to be an important new treatment option.
Cheng G et al. Oral eltrombopag for the long-term treatment of patients with chronic idiopathic thrombocytopenic purpura (ITP) (Abstract #400)
Thrombosis: Advances that improve anticoagulation
Venous thromboembolism is a serious public health problem. Cancer patients are at elevated risk. A large-scale study showed that cancer patients, especially with lung and pancreatic cancer, could benefit from the preventive use of anticoagulants. A new class of anticoagulants (factor Xa inhibitors) is currently being investigated in promising phase III trials.
Buller and co-authors examined the efficacy of the new factor Xa inhibitor idrabiotaparinix as compared with idraparinix. Idrabiotaparinix links idraparinix to biotin, thus allowing its effect to be antagonised if necessary by infusion of avidin, an egg protein that binds with biotin. Both substances were equally effective in preventing deep-vein thrombosis with a trend towards less bleeding with idrabiotaparinix (clinically relevant bleeding 5.2% vs. 7.3%, major bleeding 0.8% vs. 3.8%). By an infusion of avidin, mean anti-factor Xa activity could be reduced by 77.8% within 30 minutes and was sustained for at least five days.
Buller HR et al. Idrabiotaparinix, a biotinylated long-acting anticoagulant, in the treatment of deep venous thrombosis (EQUINOX Study): safety, efficacy and reversibility by avidin (Abstract #32)
Agnelli and co-workers evaluated the efficacy of nadroparin, a low-molecular-weight heparin, for the prevention of thromboembolic events in cancer patients receiving chemotherapy. Almost 1,200 patients were randomised to receive nadroparin (3,000 IU once daily SC, maintained for the duration of chemotherapy or up to a maximum of four months) or placebo. Thromboembolic events occurred in 2.1% of the nadroparin group vs. 3.9% of the placebo group (p = 0.033), 0.7% in the nadroparin group experienced a major bleeding.
Agnelli G et al. A randomized double-blind placebo-controlled study on nadroparin for prophylaxis of thromboembolic events in cancer patients receiving chemotherapy (Abstract #6)
Authors
Professor Dr med Günther J Wiedemann, MD, PhD
Professor of Medicine
Department of Internal Medicine, Haematology, Oncology and Gastroenterology
Oberschwabenklinik
12 Elisabethenstrasse
D-88212 Ravensburg, Germany
email@example.com
Professor Dr med Wolfgang Wagner, MD, PhD
Professor of Radiotherapy
Department of Radiotherapy
Paracelsus Klinik Osnabrück
69 Am Nantruper Holz
D-49076 Osnabrück, Germany
firstname.lastname@example.org
Methods for minimising chemotherapy-induced toxicity provided a key topic at the 2008 symposium for British oncology pharmacists.
Around 700 delegates and speakers convened in Liverpool, in north-west England, for the 11th Annual Symposium of the British Oncology Pharmacy Association (BOPA), held 17–19 October 2008. The programme, which featured more than 40 presentations and workshops across four themes (Hot Topics, Cancer 2012, Clinical Update, and Introduction to Oncology) attracted oncology pharmacists and other cancer specialists from as far afield as Greece and the US, as well as the UK. Klaus Meier spoke on European collaboration on behalf of ESOP, which was well represented.
Prevention and management of serious side effects
Dr Zafir Malik, a consultant clinical oncologist from Merseyside and Cheshire Cancer Network, presented a range of evidence demonstrating the efficacy of granulocyte-colony stimulating factors (G-CSF) when used to prevent potentially life-threatening chemotherapy-induced neutropenic sepsis (NS). He pointed out that European and US guidelines recommend primary prophylaxis with G-CSF for patients receiving regimens associated with an NS risk of over 20%, or at lower levels in the presence of other known risk factors. Citing patients with early-stage breast cancer as an example, he said that neutropenia led to dose delays in 58% of chemotherapy recipients, and to dose reductions in 53%, yet there was evidence that reduced dose intensity resulting from such treatment modifications was associated with reduced survival in this patient group. Should a patient develop NS, he recommended a step-down treatment approach, based on empirical parenteral antibiotics on admission to hospital, to be continued or switched to oral antibiotics, depending on the patient’s condition and temperature.
The importance of well planned, effective out-of-hours care pathways for admission and treatment of chemotherapy-induced toxicities were emphasised by Dr David Jackson, a consultant medical oncologist from St James’s University Hospital, Leeds. He pointed out that NS, mucositis, diarrhoea, nausea and vomiting and cytotoxic extravasation were all potentially life-threatening and warranted urgent therapy. However, as his series of case reports illustrated, essential investigations and interventions were often delayed or omitted because of lack of information in the receiving ward and poor communication within and between hospitals. He called for the development of robust patient care pathways, built around effective communication and information channels.
Safety of intrathecal therapy
Denise Blake, a pharmacist from Newcastle Royal Infirmary, delivered a plea for safe use of intrathecal chemotherapy, the subject of recently updated national guidelines from the UK Department of Health\(^1\). She reminded delegates of some of the tragedies intrathecal chemotherapy in the UK and other countries, and urged pharmacists to read the latest information thoroughly. Key changes in the 2008 update include a requirement for healthcare professionals involved in administering an intrathecal treatment to make sure all personnel are appropriately trained and registered. In addition, use of mini-bags is now recommended for the delivery of vinca alkaloids, except in a paediatric setting.
Role of vascular endothelial growth factor inhibition
Angiogenesis inhibition in cancer treatment was one of the Hot Topics of this year’s symposium. Andrew Clamp, a senior lecturer in medical oncology at Christie Hospital, Manchester, UK, outlined how angiogenesis was controlled in normal tissues, but uncoordinated in cancer, and explained the role of vascular endothelial growth factors (VEGF) in the proliferation of blood vessels. He said that VEGF inhibition was associated with serious side effects and emerging drug resistance. However, treatment efficacy and tolerability could be improved through use of drug combinations and sequencing and dose modification. Moreover, there were encouraging results from studies of biomarkers that predict patients likely to benefit from anti-angiogenic therapy, or detect the early signs of progressive disease. Such markers could be used to optimise treatment efficacy, minimise toxicity and reduce the costs associated with ineffective or poorly tolerated treatments.
The 2009 BOPA Annual Symposium will be in Brighton, Sussex, 16-18 October (see www.bopawebsite.org).
\(^1\)www.dh.gov.uk/en/index.htm search for HSC 2008/001
Author
Janis Smy, BSc
Senior Medical Writer
Succinct Healthcare Communications and Consultancy
Burton House, Repton Place
White Lion Road
Amersham HP7 9LP, UK
email@example.com
|
Stable transgenesis in *Astyanax mexicanus* using the *Tol2* transposase system.
Bethany A. Stahl\textsuperscript{1,2}, Robert Peuß\textsuperscript{3}, Brittnee McDole\textsuperscript{1,2}, Alexander Kenzior\textsuperscript{3}, James B. Jaggard\textsuperscript{1,2}, Karin Gaudenz\textsuperscript{3}, Jaya Krishnan\textsuperscript{3}, Suzanne E. McGaugh\textsuperscript{4}, Erik R. Duboue\textsuperscript{2,5}, Alex C. Keene\textsuperscript{1,2,*}, and Nicolas Rohner\textsuperscript{3,6,*}
*Co-senior, co-corresponding*
\textsuperscript{1}Department of Biological Sciences, Florida Atlantic University, Jupiter, FL, USA
\textsuperscript{2}Jupiter Life Science Initiative, Florida Atlantic University, Jupiter, FL, USA
\textsuperscript{3}Stowers Institute for Medical Research, Kansas City, MO, USA.
\textsuperscript{4}Department of Ecology, University of Minnesota, St. Paul, MN, USA.
\textsuperscript{5}Wilkes Honors College, Florida Atlantic University, Jupiter, FL, USA
\textsuperscript{6}Department of Molecular and Integrative Physiology, KU Medical Center, Kansas City, KS, USA.
**Abstract:**
*Astyanax mexicanus* is a well-established and widely used fish model system for evolutionary and developmental biology research. These fish exist as surface forms that inhabit rivers and 30 different populations of cavefish. The establishment of *A. mexicanus* as an emergent model organism for understanding the evolutionary basis of development and behavior has been accelerated by an increasing availability of genomic approaches to identify genotype-phenotype associations. Despite important progress in the deployment of new technologies, deep mechanistic insights into *A. mexicanus* evolution and development have been limited by a lack of transgenic lines commonly used in genetic model systems. Here, we expand the toolkit of transgenesis by characterizing two novel stable transgenic lines that were generated using the highly efficient *Tol2* system, commonly used to generate transgenic zebrafish. A stable transgenic line consisting of the zebrafish ubiquitin promoter fused to eGFP expressed eGFP ubiquitously throughout development in a surface population of *Astyanax*. To define specific cell-types, we injected fish with a Cntnap2-mCherry construct that labels lateral line mechanosensory neurons in zebrafish. Strikingly, both constructs appear to label the predicted cell types, suggesting many genetic tools and defined promoter regions in zebrafish are directly transferrable to cavefish. The lines provide proof-of-principle for the application of *Tol2* transgenic technology in *A. mexicanus*. Expansion on these initial transgenic lines will provide a platform to address broadly important problems in the quest to bridge the genotype to phenotype gap.
**Introduction:**
The Mexican tetra *Astyanax mexicanus* is a versatile model system, which is well suited for the study of the evolution of morphology, behavior, and physiology [1-10]. The different ecologies of the river and cave habitats of this species have led to the evolution of river dwelling and cave adapted populations which differ in a large number of traits (Figure
The surface and cave morphs are diverged by ~200,000 years [11]. Despite the temporal and spatial divergence, the cave and surface populations remain interfertile. This ability may have been maintained by considerable gene flow between the surface and cave populations [11]. Many of the known cave populations are geographically isolated from each other and are the result of repeated evolution [11, 12]. Thus, one major question is whether the same genes or pathways are repeatedly modified throughout evolution. Importantly, the fish can be kept in the laboratory and breed regularly. As such they are likely amenable to most procedures that are available for other fish model species, such as the zebrafish (*Danio rerio*) or the medaka (*Oryzias latipes*).
Over the last decade, an array of genomic and genetic tools have been established, which allow for mechanistic investigation into the differences between surface fish and cavefish. High-resolution genetic maps [13-15], data from transcriptome analyses [16, 17], methods for altering gene expression [18], and approaches for introducing mutations [19, 20] have recently been applied to study the genetic basis of trait evolution. Moreover, the genomes of multiple *A. mexicanus* populations have recently been assembled, further developing *Astyanax mexicanus* as a tractable model system [11, 21]. Despite these technological advances, the system suffers from the limited availability of transgenic lines. To date, only one stable transgenic line has been published that was generated using the I-SceI-meganuclease system [22]. A few studies have used *Tol2* technology, commonly used to generate transgenic zebrafish, but analysis was limited to mosaic F0 fish [6, 22], therefore, procedures for generating stable transgenic lines are unclear.
Multiple features suggest *A. mexicanus* are well-suited for the implementation of high throughput transgenic technology. These fish have large clutch sizes of externally fertilized eggs and a short generation time of 5-6 months [23]. Further, *A. mexicanus* are closely related to zebrafish, with an estimated divergence of 100 million years [24]. A large array of transgenic lines from zebrafish are available that depends on *Tol2* mediated transgenesis. If the same *Tol2* transgenic constructs that are used in zebrafish could be used for Astyanax, this could create important synergies. Here, we report the successful generation of two new stable transgenic lines in *Astyanax mexicanus*. Both lines took advantage of zebrafish promoters; one line drives eGFP under a ubiquitous promoter and one line drives mCherry in lateral line neuromasts and neurons within the brain. Both lines resemble the expression pattern and timing of the zebrafish lines, strengthening the possibility of cross-species applicability.
**Results:**
Promoters that drive transgene expression ubiquitously provide important tools for every model organism because it allows for cell fate and lineage tracing experiments [25]. To optimize *Tol2* transgenesis, we first injected fish with the *Tol2* construct that included 3.5 kb of the zebrafish ubiquitin promoter upstream of egFP (Ubi-GFP) [26]. This construct was co-injected with *Tol2* mRNA to *A. mexicanus* surface fish eggs ages 0-60 minutes post fertilization. We noted broad mosaic expression in many F0 fish, providing an indicator of successful construct injection. These mosaic fish were selected for breeding as adults to identify stable transgenic insertions.
Pair-breeding revealed that female F0 fish produced 10% GFP-positive progeny (F1) (n=65/650). We raised the F1 fish to maturity and in-crossed individual fish to generate the F2 generation. These crosses produced an average of approximately 75% GFP positive F2 embryos, in line with both carriers being heterozygous for the transgene. To confirm that the zebrafish promoter is ubiquitously active, similar as in zebrafish, we checked different developmental stages for GFP expression. We detected ubiquitous expression in all developmental stages tested from 18 hours post fertilization (hpf) to 27 days post fertilization (dpf) (Figure 1c-g).
**Figure 1. Ubi-GFP stable transgenic line expresses GFP at different developmental stages of *Astyanax mexicanus***
a, b) Surface fish (a) and cavefish (b) forms of *Astyanax mexicanus* are a versatile model system for evolutionary and developmental biology research. c-g) GFP expression in different developmental stages of surface fish of transgenic *A. mexicanus*. c) 18hpf d) 48hpf e) 72hpf f) 14dpf g) 27 dpf. hpf = hours post fertilization, dpf = days post fertilization (images not to scale).
To test if the ubiquitin promoter is active in different tissues we sectioned transgenic larvae at 14 dpf and measured GFP expression in transverse sections. While we detect slight differences in the intensity of GFP expression in sections, there is overall ubiquitous expression throughout the embryo. We next dissected brain, liver, eyes, and fins of an adult fish and all tissues displayed strong expression of GFP (Figure 2). Figure 2a displays a transverse section at the level of the eyes. One important advantage of the zebrafish Ubi-GFP line, distinguishing it from other available ubiquitous lines, is that the promoter is active in all major blood cell types [26]. To test if this is true for *A. mexicanus*, we dissected the haemopoietic organ, the head kidney, of an adult transgenic fish and measured expression of GFP in hematopoietic cells using a flow cytometry approach. All major cell populations that are distinguishable by forward scatter and side scatter (erythrocytes, myeolomonocytes, lymphocytes, and precursors) display strong GFP expression, similar to what has been observed in zebrafish [26] (Figure 2c). This broad multilineage expression makes the ubi-GFP line a suitable reagent for hematopoietic transplantation experiments.
Figure 2. Ubiquitin promoter driven transgene expresses GFP in different tissues.
a) Transverse section of a 14 dpf old Ubi-GFP transgenic surface fish. Inset picture indicates the location of the section. b) GFP expression in different organs of adult transgenic fish, from top to bottom: brain, liver, eyes, heart. c) Fluorescence activated cell sorting of head kidney cells from Ubi-GFP transgenic *A. mexicanus*. Four distinct hematopoietic cell populations can be identified by forward scatter and side scatter: (i)
myelomonocytes, (ii) progenitors, (iii) lymphocytes and (iv) erythrocytes. Green indicates GFP signal from Ubi-GFP transgenes, while dark grey indicates GFP signal from wild-type control.
A common application of transgenesis is the targeting of reporters to specified tissue using tissue-specific promoters. In *A. mexicanus*, the lateral line is thought to underlie the evolution of many behaviors including foraging, social behavior, and sleep [27]. In zebrafish, a transgenic construct consisting of a 2Kb promoter fragment of contactin associated protein like 2a (Cntnap2a) driving mCherry (Cntnap2a:mCherry) labels the lateral line afferent neurons at 3 dpf, but expression patterns later in development have not been reported.
We injected *A. mexicanus* surface fish with the zebrafish Cntnap2a:mCherry promoter, isolated mosaic F0 fish, and screened for stable insertions. We found modest labeling of the lateral line and multiple brain regions including the mesencephalon, and rhombencephalon as early as 2 days post fertilization (dpf), with expression becoming more prominent after 7 dpf (Fig 3a-i). At all time points, lateral line neuromasts that project into the brain can be clearly detected and persist through 20dpf fish (Fig 3m-r). The signal in the gut is likely autofluorescence, as it was visible in non-injected fish (data not shown), and no other visible signal was detected outside of the central nervous system. Across developmental time points, Cntnap2a:mCherry selectively labeled portions of the brain including the hindbrain regions such as the medial octavolateral nucleus, that is known to receive inputs from the lateral line in other fish species [28, 29]. In addition, labeling was detected in the optic tectum and olfactory bulb after 5dpf, suggesting the expression pattern is not limited to the lateral line.
Figure 3 Expression of Cntnap2a-mCherry across development. Visualization of Cntnap2a-mCherry expression during early development (2 dpf – 28 dpf) in whole body (left column) and dorsal head view (right column). Cntnap2a expression is evident throughout the lateral line and hindbrain regions.
Figure 4. Cntnap2a colocalizes with DASPEI neuromast stain. a) Whole body view and b) zoom shows that Cntnap2a-mCherry (red) and neuromasts of lateral line (DASPEI, green) colocalize (merge, b’’). c) Dorsal head view and d) zoom demonstrates colocalization of neuromasts and Cntnap2a labeled neurons that innervate the brain (merge, d’’’). e) Sagittal aspect. f) Dorsal aspect (SB= 100 µm), Spine (Sp, purple), Rhombencephalon (Rbh, pink), Mesencephalon (Mes, blue), Diencephalon (Dien, yellow), Telencephalon (Tel, green), Cntnap2a:mCherry (red).
To verify that Cntnap2a-mCherry labels the lateral line, we imaged 6 dpf Cntnap2a-mCherry transgenic fish co-stained with DASPEI, a dye that labels mitochondria and is widely used to mark lateral line neuromasts in diverse fish species (Fig 4a). Colocalization between DASPEI and mCherry label was detected in neuromasts along the body (Figure 4b). In addition, close-up imaging reveals projections from multiple neuromasts forming a lateral line nerve that innervates the brain (Figure 4d). To determine the expression pattern of Cntnap2a-mCherry within the brain, whole mount confocal images of 6dpf fish co-labeled with tERK were acquired. Anatomical segmentations were performed to localize the expression pattern of Cntnap2a-mCherry. This revealed strong expression of hindbrain areas in the rhombencephalon such as the medial octavolateralis nucleus (MON) and several other areas likely associated with sensory processing in the hindbrain. There was additional strong mCherry expression within regions of the mesencephalon and telencephalon with further sparse labeling within the diencephalon. Together, these findings verify that Cntnap2a-mCherry transgene labels lateral line sensory neuromasts.
and projects centrally into several distinct nuclei, providing proof-of-principle for selective expression using a zebrafish promoter-fusion construct in *A. mexicanus*.
**Discussion:**
Here we describe two new transgenic *Astyanax* lines, one that ubiquitously expresses GFP in all tested developmental stages and tissues and one that is more selective. In the latter, mCherry expression is limited to the central nervous system, labeling the lateral line and other selective regions within the brain.
The use of transgenic lines is important to label tissues and cell types of interest and to overexpress allelic variants under the control of specific promoters or enhancers. *Astyanax mexicanus* is well suited for the generation of transgenic lines: the fish produce large clutch sizes of externally fertilized eggs with a penetrable chorion that permits easy microinjection. Breeding occurs frequently and regularly under lab conditions (usually every 1-2 weeks). There are protocols for *in vitro fertilization* that permit the generation of timed embryos and the fish have a relatively short generation time [23, 30]. To our knowledge, this is the first study that uses *Tol2* for the generation of stable transgenic lines in *Astyanax mexicanus*. *Tol2* possesses important advantages over alternative transgenic methods and strongly increases the insertion efficiency of the recombinant DNA and germline transmission [31]. Of particular relevance is that we did not detect significant differences in expression between the zebrafish and the *Astyanax* lines minimizing concerns about the evolutionary divergence of promoters between the two species. Currently, there are over 40,000 transgenic lines described in zebrafish (ZFIN) which opens vast possibilities for *Astyanax* and EvoDevo research.
The Ubi-GFP line can be used for cell fate and lineage tracing experiments or to test the autonomy of cell and tissue signaling on certain phenotypes. For example, the line can be used to transplant cells from surface fish to cavefish and monitor the behavior of the clones [32]. While we did not detect obvious differences in expression levels in different tissues, a ubiquitous line does not guarantee homogenous expression. In zebrafish, for example, it has been shown that the construct is expressed lower in certain subsets of internal organs such as some subsets of neurons and epithelial cells of kidney tubules [26]. Similarly, we observed slight variability in the intensity of GFP expression in different tissues and areas of the embryos.
Additionally, we find that the zebrafish Cntnap2a:mCherry promoter labels the lateral line in *A. mexicanus*. Unlike many other behaviorally relevant neuronal cell populations in *A. mexicanus*, the lateral line has been well studied because it can be labeled using the mitochondrial cilia marker DASPEI, and neuromasts can be ablated with the ototoxic antibiotic gentamicin. These approaches have been used to characterize functional differences of the lateral line between surface and cavefish. An expansion of the lateral line is thought to underlie the reduced dependence on visual processing in cavefish, and confer increased vibration sensitivity and reduced sleep, presumably to improve foraging [33-35]. Genetic labeling of the lateral line using the transgenic fish is highly superior to physical labeling with DASPEI because it allows more fine-scale assessment of neurons involved in lateral line function between cavefish and surface fish. The lateral line
neuromast projections can be examined for anatomical differences between populations of *A. mexicanus*. In addition, the Cntnap2a promoter driving the Ca$^{2+}$ sensor GCaMP would allow for Ca$^{2+}$ to functionally compare lateral line activity.
In zebrafish, significant headway has been made identifying neural circuits that regulate behavior. The identification of these circuits allows for cell-autonomous manipulation of gene function, or optogenetic manipulation of behaviorally relevant neurons. In *A. mexicanus* a number of genes have been implicated in behavior including a role for Mc4r in feeding, hypocretin in sleep, and monoaminergic signaling in aggression [6, 36, 37]. While presumably the neurons expressing these genes are implicated in behavior, a lack of transgenic accessibility represents a fundamental impediment to mechanistic investigation. The proof-of-principle of efficient implementation of *Tol2* transgenesis in *A. mexicanus* should allow for the implementation of binary transgenic expression systems commonly used in other genetic model systems including GAL4/UAS and QF/QUAS systems [38, 39]. In addition to promoter fusions, these systems would allow for developing libraries of transgenic effector lines to manipulate neuronal function. The transparency, generation time, and standardized husbandry procedures currently available in *A. mexicanus* strongly position this emergent model system for the implementation of these approaches.
The generation of transgenesis and gene-editing methodology is growing increasingly common in fish species other than classical models like zebrafish and medaka. For example, in the African cichlid, *A. burtoni* [40], the Midas cichlid, *A. citrinellus* [41], the short-lived African killifish *N. furzeri* [42] or the tilapia *O. niloticus* [43] transgenesis has been reported. Nevertheless, the application of these techniques is limited to a few lines, while the power of genetic approaches in model organisms typically derives from the generation of transgenic libraries consisting of thousands of lines. While the optimization of methodology provides a platform for developing these lines, the success is also dependent on community resources such as stock centers and large-scale initiatives to generate lines. Our finding that constructs are directly transferable from zebrafish to *A. mexicanus* may streamline the process of generating these lines.
**Acknowledgements.** We thank Christian Mosimann and Jenna Galloway for the Ubi-GFP construct and Hernan Lopez-Schier for the Cntnap2a-mCherry (SILL1) construct. We thank the Aquatics facility of the Stowers Institute for care and maintenance of the fish, in particular Zachary Zakibe for help with IVF and Alba Aparicio for counting embryos. We thank the Histology and Microscopy facility at the Stowers Institute for assistance with the data acquisition. Original data underlying this manuscript can be accessed from the Stowers Original Data Repository at http://www.stowers.org/research/publications/libpb-1381. Funding from the Stowers Institute and the Edward Mallinckrodt foundation to NR, NIH R21 NS105071 to ACK and ERD, NIH R01 GM1278872 to ACK, SEM and NR and NSF 1656574 to ACK supported this work. R.P. was supported by a grant from the Deutsche Forschungsgemeinschaft (PE 2807/1-1).
Author contributions.
NR, AK, ED, SM conceived and designed the analysis. BS, RP, BM, AK, JJ, KG, JK, performed the experiments. BS, AK, NR wrote the paper with input from all other authors.
Methods:
Fish husbandry and egg collection
For *Astyanax* F0 transgenesis, fish are bred in community breeding tanks consisting of 2-3 females and 3-5 males. To promote breeding, fish are fed a high fat diet starting ~1 week prior to injections and heaters with +2° C temperature increase are added 2 days before breeding night, in accordance with previously published methods [44]. On the night of breeding, tanks are frequently examined for fresh, single cell eggs. Eggs are collected with a fine mesh net and loaded on to injection plates. Injection plates are prepared using 3% agarose dissolved in 100 ml fish water, poured into a 100 ml petri dish, and an egg injection mold (Adaptive Science Tools) is added to create wells for the eggs.
Constructs:
*Cntnap2a-mCherry*: We utilized the previously published zebrafish mCherry labeled *Cntnap2a* construct Tg(hsp70l:mCherry-2.0cntnap2a); zfin #ZDB-TGCONSTRCT-120424-6. In zebrafish, placing a 2kb *Cntnap2a* enhancer fragment downstream of the heat shock-70 promoter and mCherry drove robust expression in lateral afferent neurons. This enhancer fragment is also known as the sensory innervation of the lateral line number 1 (SILL1) promoter [45].
*Ubi-eGFP*: We utilized the previously published zebrafish eGFP labeled ubiquitin promoter construct Tg(-3.5ubb:EGFP); zfin ZDB-TGCONSTRCT-110317-1. This construct contains a 3.5 kb promoter fragment upstream of the ATG of the zebrafish gene ubiquitin B (*ubi*), including the first non-coding exon and the intron. It has been shown to ubiquitously express eGFP in most tissues and developmental stages including the hematopoietic organ [26].
RNA synthesis of *tol2* transposase RNA:
The *Tol2* transposase plasmid (pCS-zT2TP) was used as a template for *Tol2* mRNA generation. The pCS-zT2P plasmid was digested with restriction enzyme and purified. *In vitro* transcription of *Tol2* mRNA and lithium chloride precipitation/purification was performed using the SP6 mMessenger Kit (Ambion #AM1340) according to manufacturers guidelines.
Microinjection:
Pull needles for injection using borosilicate glass capillaries (Sutter Instruments #BF100-58-10) in an electrode/needle puller (Sutter Instruments Model P-97). This protocol will vary per machine, but a sample needle-pulling program is: Heat 510, Pull 55, Velocity 100, Time 40, Pressure 500, Ramp 534. Back fill needles with approximately 3-4 ul of *Tol2* mRNA and the desired plasmid at a concentration of 25 ng/ul each in RNase-free water. Filled needles are loaded in a micromanipulator (World Precision Instruments #M3301R) connected to a microinjector/picoinjector (Warner Instruments #PLI-100A).
Injection pressure settings were optimized for injections in a 1 nl volume and eggs are injected at the single cell stage.
**DASPEI stain:**
6 dpf Cntnap2a-positive fish were treated for 1 hour with 0.05% DASPEI (2-4-dimethylamino-N-ethylpyridinium iodide; Sigma Aldrich), which labels both superficial and canal neuromasts [46]. The precise mechanism of DASPEI labeling remains unknown, it is proposed that the dye enters the cells through transduction channels and apical endocytosis, allowing for uptake by active hair cells, making it specific for labeling intact neuromasts of the lateral line [46].
**Live Imaging:**
Live cavefish was used to image ubiquitin-GFP transgenic fish. All fish were anesthetized using MS-222 (Tricaine). Embryos were mounted in 3% hydroxypropyl methyl cellulose (VWR, cat# 200012-722) in E3 medium (ref). Juveniles were placed on a filter paper on top of a MS-222 soaked sponge. Images were acquired using a Leica M205C stereo microscope (Leica Microsystems Inc.) equipped with a filter set for detection of GFP (WB). The zoom setting for embryos was 4.0 and for juveniles 1.25. Images were processed using the LAS AF ver. 4.7 software (Leica Microsystems Inc.) and ImageJ.
**Fixed Imaging:**
*Astyanax* surface F1 fish expressing Cntnap2a-mCherry at various developmental time points were fixed overnight in 4% paraformaldehyde and rinsed in PBS solution. Fish were mounted in 2% low melt agarose and imaged at 10x or 20x magnification with a Keyence BZ-X710 invert microscope. Images were acquired with BZ Capture and processed using BZ-X analyzer software. Fish co-labelled with tERK antibody (####) were treated with 150 mM Tris-HCl at 70°C for 15 minutes, incubated in 0.05% Trypsin-EDTA for 35 minutes on ice. Fish were then incubated in primary antibody overnight at 4°C and for 95 minutes in secondary antibody at room temperature. Fish were then imaged on a Nikon A1 confocal microscope. All anatomical segmentations were performed using Amira 6.2 and visualized with a Volren module.
**Preparation of cryo sections for GFP imaging:**
14 dpf fish embryos were embedded with OCT compound (cat# 4583, Tissue-Tek, CA) and snap-frozen at -80C. Sections are prepared as previously reported [47]. Briefly, cryo sections with 12um-in-thickness were cut using a Cryostar Nx70 Cryostat (cat# 957020, Thermo Fisher Scientific) and picked onto superfrost microscope slides (cat# 12-550-15, Thermo Fisher Scientific). After 2 hours drying slides are immersed into PBS to wash off OCT, followed by coverslipping with ProLong gold antifade mountant (cat# P36930, Thermo Fisher Scientific). GFP imaging of slides and fish organs was performed with Axioplan2 (Zeiss) and Leica M205C microscopes.
**Hematopoietic tissue analysis:**
One 1 year old Ubi-GFP transgene fish and one similar aged wild type fish were euthanized with cold 500 mg/L MS-222 for 10 min. Hematopoietic tissue (head kidney) was dissected and tissue was forced through 40 µm cell strainer in L-15 media containing
5mM HEPES (pH 7.2), 10% sterile water and 20 U/mL Heparin. Cell strainer was washed once, and single cell solution was washed once and resuspended. Flow cytometry analysis was based on forward scatter and side scatter and FL1 (GFP) with an EC-800 flow cytometer (Sony Biotechnology).
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THE STATE OF DATA IN THE NONPROFIT SECTOR
everyaction nonprofit hub
Data is a term we’ve come to associate with the for-profit world, but in the nonprofit world it’s seemingly not as prevalent. Natural-born do-gooders came into the nonprofit sector with one mission—to leave the world a better place than they found it. Nobody mentioned data in that equation.
However, if you want to give your nonprofit every chance it has to improve and succeed, data is vital. Data can help you predict future trends, gather donor statistics, analyze fundraising trends and more. That’s why Nonprofit Hub and EveryAction have partnered to bring you a better look at the ways nonprofits are collecting data and to identify how they’re using the data for success.
To gain insight, we conducted a survey with hundreds of nonprofits. While 90 percent of all respondents said they sometimes or always tracked data, 48 percent said they weren’t sure of all the ways that their organization was tracking data.
It’s a good start that most nonprofits are collecting data, but simply tracking it isn’t enough. Our findings produced clear results stating that many nonprofits are collecting data, but often aren’t sure what to do with it. For example, only 40 percent of nonprofit professionals said they use data very often to make decisions or in every decision they make, and 46 percent said they do not consistently use data to make decisions.
Let’s dive deeper into the world of nonprofit data to discover how nonprofits can be more successful.
For the survey, 467 nonprofit professionals participated. Of those polled, 337 identified the size of their organization. The majority of respondents identified as small nonprofits (231 or 69 percent of those who answered). Small nonprofits identified as consisting of 1-24 staff members.
| Organization Size | Number | Percentage |
|-------------------|--------|------------|
| 1 to 24 | 231 | 68.66% |
| 25 to 50 | 37 | 11.04% |
| 50 to 100 | 21 | 6.27% |
| 100 to 200 | 23 | 6.87% |
| 200 to 500 | 15 | 4.48% |
| 500+ | 10 | 2.99% |
Respondents for this survey included a wide variety of nonprofit sector professionals, including executive leadership (30 percent), development/fundraising professionals (22 percent), communications and marketing professionals (21 percent), and operations (9 percent), among others.
How would you describe your role in your organization?
| Answer Choices | Responses |
|---------------------------------|-----------|
| Advocacy | 3.24% | 11 |
| Policy | 1.18% | 4 |
| Executive Leadership | 30.38% | 103 |
| Communications/Marketing | 21.24% | 72 |
| Development/Fundraising | 21.83% | 74 |
| Operations | 9.14% | 31 |
| IT | 2.36% | 8 |
| Other (please specify) | 10.62% | 36 |
Total: 339
The results from the survey produced all types of findings about data—some good, some bad and, well—some ugly.
**THE GOOD:** Many nonprofits are collecting data. That’s the best place to start. Of the nonprofits polled, 90 percent said they are collecting data. We commend all these nonprofits for taking their first steps into the data world.
**THE BAD:** While collecting data is great, 49 percent said they either don’t know or weren’t sure about all of the ways their organization was collecting data. If you don’t know how data is being collected, you can’t use it to your advantage to make decisions and better your organization.
**THE UGLY:** A mere 5 percent said they were using data in every decision they make. Plus, 13 percent said they rarely use data, or not at all (gasp!). Excuse our language, but we consider rarely or not using data at all to be downright ugly. Using data to know what works and what doesn’t can help drive changes to your website, email, marketing tactics and so much more.
It’s clear that the majority of nonprofits wanted to be better about utilizing the data that they had gathered—97 percent of the nonprofits surveyed expressed interest in learning how to use their data more effectively. To combat these issues, it’s important to know what factors prevented organizations from making strides in collecting and effectively utilizing data. So, without further adieu, these are the top five factors nonprofits said were preventing them from using data.
- Organizations aren’t collecting enough data: 36%
- Lack of tools to help analyze data: 42%
- Data isn’t kept in one place: 46%
- Personnel doesn’t have enough experience using data: 55%
- Not enough time, or personnel to focus on data: 79%
1. NOT ENOUGH TIME, OR PERSONNEL TO FOCUS ON DATA (79 PERCENT).
In actuality, nonprofits can save time in other places by tracking data. For instance, data can help streamline the fundraising process, increase donor retention and much more. By tracking data and keeping track of every interaction, you’re getting better insight into your donors and the fundraising process. You’re finding out what donors like and what they’d like you to change. When you listen to that data, you improve their experience.
2. PERSONNEL DOESN’T HAVE ENOUGH EXPERIENCE USING DATA (55 PERCENT).
Sixty percent of nonprofits said they did not have a team member that was specifically tasked with managing and analyzing data. However, this doesn’t need to be a full-time task. Designate somebody to be the data gate-keeper. They can designate others to help, but somebody should be trained on the software and be able to train and help others. Keep in mind that there are various types of software tools with different functions, but no matter how you manage your different types of data, come up with a logical plan suited to the needs of your organization.
3. DATA ISN’T KEPT IN ONE PLACE (46 PERCENT).
Having a central location makes data run like a well-oiled machine. Save time by finding software that allows you to track multiple aspects of your data. If you can, look for software that can keep multiple types of data, like fundraising and donor statistics, in one place.
4. LACK OF TOOLS TO HELP ANALYZE DATA (42 PERCENT).
Having software tools for your data is a must, no matter how big or small your organization is. Luckily we live in a time where there are ample options to succeed at any cost.
5. ORGANIZATIONS AREN’T COLLECTING ENOUGH DATA (36 PERCENT).
This is something that shouldn’t wait. Data can help improve multiple aspects of your organization, helping you achieve your mission more effectively. Check out the different types of data your organization could be collecting in the section below.
There are many types of software out there that track different types of data, and some with the option to track multiple types. Take the time to figure out what software will work best for the functions your organization needs.
These are the top ways nonprofits said they were using software to collect data at their organizations.
- Donor Management: 57%
- Email: 55%
- Online Fundraising/Social Media: 45%
- Events: 39%
- Marketing: 36%
- Direct Mail: 31%
- Website Optimization: 29%
- Major Gifts: 25%
- Volunteer Management: 24%
- Planned Giving/Advocacy: 17%
A particularly alarming statistic comes from the amount of respondents using data to track their website optimization (only 29 percent). Websites also provide a face for your organization in the digital world we live in. Often, websites are the first place individuals interact with a nonprofit. And in the age of online giving, a smooth donation process can drastically increase fundraising opportunities—making the optimization of your website for visits and for tracking conversions essential. Plus, there are free tools such as Google Analytics that can easily help you track page views and find out where traffic is coming from.
Major gifts data is another area of concern for collecting and managing data. Major gifts make up a large portion of many organizations’ fundraising efforts. Knowing the data on major gifts and using it to your advantage can drastically help fundraising efforts. Although donor management as a whole received the best response (57 percent), segmenting data is important to provide donors with the best experience based on their giving patterns. That can help you identify the specific patterns of major donors and allow you to further cultivate them.
Despite some of the low numbers, the use of data is not for lack of want, according to the findings. The same respondents indicated they would like to better utilize data for marketing, online fundraising, donor management, social media and a host of other aforementioned activities. Make sure your organization identifies when it’s most beneficial to track certain types of data. And fear not—your organization doesn’t have to implement all of these programs at once. Start by utilizing one type of data at a time and go from there.
If you’re collecting the data but not using it to influence your decisions, does the data matter at all? Simply put—no. Your organization ends up with numbers that simply sit there in limbo providing no added value.
Why wouldn’t organizations use data that they already have? Nonprofits indicated that they weren’t confident in the effectiveness of utilizing their data. Only 6 percent of respondents said they felt they were effectively using the available data at their disposal. Thirty-three percent indicated they weren’t using data effectively or at all.
Nonprofit professionals agreed: 87 percent indicated that data was moderately to extremely important to operations and decision making. However, responses indicated that organizations as a whole placed much less importance (57 percent) on data in those circumstances, showing a disconnect between the way staff and organizations are using data as a whole. Nonprofit professionals need to take charge to change the thinking at their organization. All it takes is the thoughtful idea of one individual to start a revolution.
There are many ways that organizations can integrate the use of data into their decision making process for various outlets and activities.
Other ways nonprofit professionals indicated they were using data to make informed decisions included advocacy, planned giving, corporate or foundation purposes and face-to-face or street canvassing.
For most nonprofits, weekly informed decisions based on data seemed to be the most feasible. Only 22 percent of respondents actually use their data on a weekly basis, yet 40 percent say they’d like to be using data to make informed decisions on a weekly basis.
Software for tracking and analyzing data is only as useful as the training your staff receives and the interface you use.
While 61 percent of participants said they used software every day, nearly half of respondents (31 percent) said they were not at all or somewhat likely to recommend their software to another organization.
The best software provides little benefit if it isn’t being used properly. Alarmingly overall, only 5 percent of survey participants said they took full advantage of data collected by their software tools.
When it comes to taking advantage of data collected by software tools, there was a distinct difference between small and large organizations. Forty-nine percent of small organization respondents (1-24 staff members) said they sometimes take advantage of data collected by software tools. Meanwhile, 50 percent of large organizations (500+ staff members) said they often take advantage or take full advantage of data collected by software tools. Keep in mind, big data isn’t just for big nonprofits. With the proper tools, integrating data into your plans should be a seamless process. However, the wrong tools could end up slowing your organization down.
A lack of extensive training could be at the root of some nonprofits’ software woes with data organization and implementation. A mere 3 percent overall indicated that they had received very extensive training on their software. In comparison, 40 percent said they had received very little training.
In conjunction with lack of training, only 5 percent of nonprofits indicated that their software was extremely user-friendly. Only 3 percent of people who described their software as moderately or extremely user-friendly said they did not find software to be useful, indicating a large margin of happy software customers when they felt their software was easy to use.
With user-friendly software, data is much more accessible to evaluate and use for decision making. User-friendly software empowers the end-user to feel confident with the results they’re producing by collecting and analyzing data.
Nonprofits should not only be aware of the data they’re tracking, but also how they’re utilizing the data. Then, take it a step further—process how effectively your organization is using data to influence decisions and how often.
Nonprofits cited time constraints as the number one reason they don’t properly use data. However, tracking that data can drastically improve fundraising, donor retention efforts and more, creating a more effectively run organization. The more you know about donors, the more you can use that information to your advantage to personalize and tailor their donor experience. Thus, the data collected can help you retain donors and gain more fundraising dollars. And using software can help you track data on every touch you make with a donor.
Nonprofits can save time by making an effort to be properly trained in their software and by choosing a user-friendly software interface.
Ninety-seven percent of participants indicated that they might be or were interested in learning more about data. Start by utilizing the data you have readily available, and by making an effort to understand your data software. Take the time to seek out opportunities to learn more about data and how to use it.
everyaction
202.370.8050
firstname.lastname@example.org
everyaction.com
@everyactionHQ
nonprofit hub
402.434.8540
email@example.com
nonprofithub.org
@nphub
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A New Way to Keep Track of Your Child’s Progress
Every new parent looks forward to their baby’s first step or first words. Now, parents can track their child’s progress with a free Milestone Tracker app from the Centers for Disease Control and Prevention (CDC). Use this free, parent-friendly app to track and celebrate your young child’s development from ages 2 months through 5 years. See photos and videos that illustrate milestones. Try new activities to support your child’s early development. Get helpful reminders for appointments, and more!
Although it’s packed with parent-friendly features, this app is not just for parents! Healthcare providers can use it to help with developmental surveillance (regularly monitoring a child’s development to identify problems with development early), as recommended by the American Academy of Pediatrics. Early care and early education providers can use the app to better understand their students’ skills and abilities and to engage families in monitoring developmental progress.
The app is available in both English and Spanish. It has been culturally adapted for Spanish-speaking parents of young children, as *Sigamos el Desarrollo*.
To get the app, go to [www.cdc.gov/MilestoneTracker](http://www.cdc.gov/MilestoneTracker), or click [here](#) to download from the App Store or [here](#) to download from Google Play.
“I love the photos and videos on Milestone Tracker. It helps me to know exactly what milestones my son should be reaching.”
Jasmine B., mother of 1-year-old, Atlanta, GA
Autism and Genetics
Autism spectrum disorder (ASD) is a complex condition that affects social skills, communication, and other behaviors. Despite improvements in our understanding of ASD, we still have a lot to learn about its causes and treatment. Studies indicate ASD has both environmental (meaning exposures, like a person’s diet, medicines, or pollutants, which are external) and genetic causes.
Many types of genetic mutations (meaning changes in a person’s genes) are linked with ASD. Because of these genetic changes, some people are more likely to have ASD. For example, families who have one child with ASD have an increased risk of having a second child with ASD. Similarly, if one twin is diagnosed with ASD, the other has a higher likelihood of having ASD.
However, genetics do not account for all ASD risk. Things in the environment may also contribute to ASD risk for some children. Researchers are examining whether environmental factors might interact with a person’s genetic makeup to elevate ASD risk. The interaction between genes (made up of DNA within each cell in the body) and the environment is a major focus of the Study to Explore Early Development (SEED).
SEED is one of the largest studies designed to compare children with ASD and other developmental disabilities to children without these conditions. SEED has sites in California, Colorado, Georgia, Maryland, Missouri, North Carolina, Pennsylvania, and Wisconsin. Each SEED study site collects information on risk factors, including family members’ health, experiences of mothers during pregnancy, and children’s health and development during infancy and the first few years of life. In addition, SEED has collected blood and saliva, which give us genetic information about parents and children. Research using SEED’s data will contribute to our understanding of how genetics and environmental factors contribute to the development of ASD.
Identifying the genetic causes of ASD can help us understand who may be at risk for ASD. This information can help doctors and caregivers diagnose ASD at earlier ages. Being able to diagnose ASD earlier allows children to begin ASD treatment at a younger age. Early treatment can help reduce how severe some ASD symptoms can be.
Do you ever wonder if scientists around the country who study ASD pool their resources to better understand it? It turns out they do. Data, or information, collected from different ASD studies are combined on an ongoing basis into a database for researchers to access. By combining smaller studies into one database, scientists can have more information to study questions they couldn’t look at before.
**Q: How are scientists working together to study ASD?**
A: Two big projects are underway that allow scientists to share data for research. Data from different projects are combined at a repository (a place where de-identified data are kept all together). The two big projects are called the National Database for Autism Research (NDAR) and the Database of Genotypes and Phenotypes (dbGaP). The data in NDAR and dbGaP are managed by the National Institutes of Health (NIH), which is part of the U.S. Department of Health and Human Services.
**Q: What information is included in NDAR and dbGaP?**
A: NDAR and dbGaP include information about study participants’ genes, health, and health behaviors. Researchers can use this information to see if certain genes are linked with the risk of ASD as well as explore how genes and health factors combined might be related to autism.
To protect privacy, information that can be used to identify an individual person, such as names, addresses, birthdates, and other personal information, is not included in NDAR or dbGaP.
**Q: Why are scientists sharing data this way?**
A: By sharing data from smaller studies, researchers hope to learn about autism more quickly and at lower costs than they could if they worked separately. Sharing data also allows scientists to study genetics and ASD more easily.
**Q: Will SEED share my data with NDAR or dbGaP?**
A: SEED scientists have not yet sent information to NDAR or dbGaP. We will only share information for those families who gave us permission to do so.
**Q: What information will SEED send to NDAR or dbGaP?**
A: If permission is granted, SEED scientists will share genetic and other health data. We will not share any private information, such as names, addresses, birthdates, or phone numbers with NDAR or dbGaP.
**Q: If my own or my child’s data are sent to NDAR or dbGaP, will I get genetic results back?**
A: No, genetic data are being used for research purposes only. We will not send the results of any genetic testing to families.
**Q: Will I be asked for more specimens (such as blood, cheek brushes, or saliva) for NDAR or dbGaP?**
A: No. Additional specimens are not needed if you participate in NDAR or dbGaP.
**Q: Is there a risk that my child could be identified if his or her information is sent to NDAR or dbGaP?**
A: Because everyone’s genetic information is different, there is a very small chance that someone with access to the databases could trace an NDAR or dbGaP participant’s genetic data back to the participant or biological relative. The risk of this happening is very small, as NIH has safeguards in place to protect participants’ privacy.
**Q: How do NDAR and dbGaP protect participants’ privacy?**
A: Only scientists approved by the NDAR Data Access Committee may obtain research data from NDAR. Scientists who have approval to analyze data must protect the data using standard procedures. Similarly, scientists who want to analyze data in dbGaP must get authorization from dbGaP’s Data Access Committee.
**Q: Can I change my mind about sharing my own or my child’s information with NDAR or dbGaP?**
A: If a participant decides later not to share his or her information with NDAR or dbGaP, he or she should contact the site where they enrolled to discuss next appropriate steps. Please note that information already shared with NDAR or dbGaP cannot be taken back because identifiers will be removed before sharing.
**Q: How can I find out more about NDAR and dbGaP?**
A: For more information on these projects, go to:
NDAR: [http://ndar.nih.gov/index.html](http://ndar.nih.gov/index.html)
dbGaP: [http://www.ncbi.nlm.nih.gov/gap](http://www.ncbi.nlm.nih.gov/gap)
Meet Colorado SEED
In Colorado, the University of Colorado School of Medicine (UCSOM), the Colorado School of Public Health (CSPH), and the Colorado Department of Public Health and Environment (CDPHE) work together to invite families to participate in the SEED study and to collect and analyze the data.
Situated in the Front Range of the Colorado Rockies, JFK Partners, on the University of Colorado Anschutz Medical Campus, houses the Colorado SEED. The Colorado SEED site is led by two professors:
- Cordelia Robinson Rosenberg, PhD, RN, a professor of pediatrics and psychiatry at UCSOM and
- Dr. Carolyn DiGuiseppi, a professor of epidemiology at CSPH.
JFK Partners is designated as Colorado’s University Center of Excellence in Developmental Disabilities (UCEDD) and Leadership Education in Neurodevelopmental Disabilities (LEND) Program. They have collaborative relationships with many organizations that are a part of Colorado’s developmental disability and special healthcare needs communities.
By working together, UCSOM, CSPH, and CDPHE have also been able to conduct other multi-site CDC projects. One of these projects, which is led by CDPHE, is the Autism and Developmental Disabilities Monitoring (ADDM) Network. ADDM has the important task of monitoring the frequency of ASD in communities across the United States. In addition to the SEED and ADDM projects, several other research studies are ongoing at JFK Partners:
- Colorado Project LAUNCH (Linking Actions for Unmet Needs in Children’s Health)
- SPARK (Simons Foundation Powering Autism Research for Knowledge)
- FORWARD (Fragile X Online Registration with Accessible Research Database)
Results Corner
Several SEED articles have recently been published. Below is a brief summary of two. Please see our website for a full listing of SEED publications. https://ncseed.org/resources-for-parents/study-findings-2
Family History of Immune Conditions and Autism Spectrum and Developmental Disorders: Findings from the Study to Explore Early Development
Croen LA, Qian Y, Ashwood P, Daniels JL, Fallin D, Schendel D, Schieve LA, Singer AB, Zerbo O
*Autism Research*, 2018
This study examined the relationship between autism spectrum disorder (ASD) and other developmental disorders (DDs) and having a family history of conditions related to immune system functioning. Such conditions include asthma, allergies, and autoimmune disorders such as eczema or psoriasis. Previous studies have suggested some association, but the results about specific conditions varied. SEED’s large sample size and detailed data on specific types of immune disorders allowed researchers to conduct an in-depth analysis on this topic and examine the associations with ASD alongside associations with other DDs. The study findings show that maternal history of eczema or psoriasis and asthma are associated with both ASD and other DDs in children. Researchers also found that children with ASD are more likely to have eczema or psoriasis and allergies than children without ASD. Autoimmune disorders were not notably increased among children with other DDs. This study highlights the relationship between maternal health before and during pregnancy and ASD and other DDs, and provides researchers more information about the health of children with ASD.
Sleep Problems in 2- to 5-Year-Olds with Autism and Other Developmental Delays
Reynolds AM, Soke GN, Sabourin KR, Hepburn S, Katz T, Wiggins LD, Schieve LA, Levy SE
*Pediatrics*, 2019
This study assessed sleep problems, such as difficulties going to sleep or staying asleep through the night, in preschool-aged children with ASD, in comparison to children with other developmental disabilities (DDs) and children in the general population. SEED’s large sample and detailed data on preschoolers allowed researchers to conduct a more in-depth analysis on this topic than in previous studies. Study findings show that children with ASD and children with other DDs who have some ASD symptoms have more sleep problems than children with DDs without ASD symptoms and children in the general population. Even when researchers used a conservative definition to classify children as having sleep problems, 47% of children with ASD and 57% of children with other DDs who had some ASD symptoms were reported to have sleep problems, compared to 29% of children with DDs but no ASD symptoms and 25% of children in the general population. Sleep is important for development in young children. Addressing sleep problems among children with ASD and children with other DDs who have ASD symptoms is an important component of healthcare needs in this population.
Highlights of SEED Progress
SEED 3 is growing!
The families joining SEED 3 are adding to the knowledge gathered in SEED 1 and SEED 2! More than 5,100 families finished the first two phases of the Study to Explore Early Development. The data from new families who finish SEED 3 will help us get a better idea of what puts children at risk of developing autism spectrum disorder.
1 leaf = 100 families who finished
Watch for future newsletters to see how SEED grows and visit www.cdc.gov/seed to see all the editions of the SEED newsletter.
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Patient-Centered Care: The Road Ahead
March 2013
“There will always be rocks in the road ahead of us. They will be stumbling blocks or stepping stones; it all depends on how we use them.”
-- Unknown
©2013 Picker Institute. All Rights Reserved.
I. Introduction
"Understanding and respecting patients’ values, preferences and expressed needs are the foundation of patient-centered care."
-- Harvey Picker
The Picker Institute has come to the end of its 27-year journey to advance excellence in patient-centered care. Through an integrated program of patient experience surveys, education, research, awards for excellence in the field of patient-centered care and the dissemination of best practices, the Picker Institute has led the way in the redesign of healthcare through the patients’ eyes.
More than a decade has passed since the Institute of Medicine's landmark *Crossing the Quality Chasm* report elevated "patient-centeredness" to be a central aim of the U.S. health care system. Improving the patient and family experience of care is now one of the Triple Aims promoted by the Institute for Healthcare Improvement and a key feature of the U.S. Department of Health and Human Services' National Quality Agenda. Patient experience measures are now widely used in public performance reports on hospitals, medical practices and health plans, and are increasingly being included in certification and value-based purchasing programs, most notably by the Centers for Medicare & Medicaid Services in calculating payments to hospitals treating Medicare patients.
Despite these achievements, the pace of change has been slow. Patient-centered care is widely understood in concept, but it is not universally applied in practice. In 2009, the Institute sought to accelerate the pace of progress by launching the Always Events® initiative. Always Events® are those aspects of the patient experience that are so important to patients and families that they should occur consistently for every patient, every time. Through research and consultation with patients, families, providers, and experts, the Picker Institute developed and refined the program, awarded numerous demonstration grants, and synthesized the lessons learned from the exceptional results achieved when providers and patients partnered together to achieve expectations of excellence. The Picker Institute leaves behind an *Always Events® Blueprint for Action* and *Always Events® Solutions Book*, along with an extensive set of practical tools and resources to support implementation, that may all be freely accessed at http://pickerinstitute.org/ and through the Institute for Patient- and Family-Centered Care website.
This report complements those program operations materials by taking a long view reflecting on the progress to date and the road ahead, including the challenges and opportunities that will shape the future of patient-centered care. For its final event, the Picker Institute convened four recipients of its Picker Award for Excellence® with expertise in different aspects of the healthcare system in an unscripted panel moderated by Don Berwick, MD, former CEO and President of the Institute for Healthcare Improvement (IHI) at the 2012 IHI National Forum. The four panelists were:
- Jennie Chin Hansen, RN, MS, FAAN, *CEO, American Geriatrics Society*
- Paul Cleary, PhD, *Dean, Yale School of Public Health*
- Peggy O’Kane, *President, National Committee for Quality Assurance*
- Ed Wagner, MD, MPH, MACP, *Former Director, MacColl Institute for Healthcare Innovation at the Group Health Research Institute*
Biographies of the panelists are included in Appendix A.
The Picker Institute then continued the discussion with an expanded group of Award winners and other health care leaders, including IHI Board members and Picker Institute’s research program grantees, at a reception following the panel. This distinguished group presented a compelling portrait of what *really* has been achieved to date, as well as thoughtful insights to guide the next phase of the journey toward a truly patient-centered healthcare system. Highlights of that discussion are included in this report.
**Organizational Recipients**
represented by leaders at left:
- Agency for Healthcare Research and Quality
- Cincinnati Children's Hospital Medical Center
- Initiativkreis Ruhrgebiet
- Institute for Patient- and Family-Centered Care
- Integrated Healthcare Association
- MedCom
- Pioneer Network
- Planetree
II. Patient-Centered Care Today
Each panelist was asked to begin by reflecting on whether patient-centered care was real, deep, and authentic. The panelists agreed that patient-centered care was real, but raised important questions about how deeply it has been embedded in the healthcare system.
"I think [patient-centered care] is real and I think the beauty of it is that most people work in healthcare because they have this desire to serve. I think that unleashing the hearts of the people that work in healthcare is one of the great legacies of Harvey Picker. It feels real. I know there are all kinds of business reasons to do a better job with patient-centered care . . . the doubters have to be brought around but they are being brought around by the realities. We’ll take it however we get it, through the hearts or through the bottom line, but I feel like it’s really real."
-- Peggy O’Kane
"Absolutely. The future is here. When we started the Picker Institute, we’d go to primary care clinics or hospitals and the whole hour would be consumed with why would one even think about listening to patients. You’d spend all this time talking about the concepts and now it’s here. We were worried in the beginning quite honestly that patient-centered care was offensive to a lot of people. Clinicians typically say ‘well everything I do is patient-centered.’ No one does it now, no one pushes back. The other way we know it’s here is the backlash . . .[to] the initiative to base some of the reimbursement of hospitals, primary care clinics, and patient-centered medical home based on patient experience. The core fundamental awareness is deep and wide."
-- Paul Cleary
"When we started working on chronic illness and we started talking about the patient as the most important manager of their own health and illness, we would get the strangest looks back from our professional audiences. In fact, when we used the term self-management, it was often thought of as an alternative to clinical management, so it became a contest between the physicians defending clinical management and the patients defending self- management. This isn’t happening anymore. It is now accepted. Is it authentic and real? I think it is. Is it deep? That’s where I’m less certain. I’m less certain about how far beneath the outer layers of the skin this has really seeped into the hearts and activities of most healthcare professionals."
-- Ed Wagner
"The momentum has shifted because of the incentives and the reporting. I think it’s both reputation and money at stake that help shape that. . . . However we get there, I think these two elements have to be tied in. I think the third element is to have joy in your work. People have chosen these fields because they do want to care. I think it creates a couple of challenges, though, that cause the depth to be reviewed."
-- Jennie Chin Hansen
III. Stepping Stones to the Future
Although the dialogue was unscripted, several consistent themes resonated throughout the discussion, including the need for:
- Expansion across the continuum of care
- Meaningful patient engagement
- Staff engagement and restoration of joy in work
- A focus on system design and accountability
- Putting measurement in proper perspective
Each of these areas represents an opportunity for improvement, but rather than viewing them as barriers, they can be viewed as stepping stones toward a truly patient-centered future. The panelists and others offered their suggestions for how to approach these challenging issues, and many of the Always Events® grantees provided instructive insights based on their experiences.
A. Expansion Across the Continuum of Care
Although many providers tend to think of healthcare as setting-specific, patients most often experience the healthcare system as a whole. To be truly patient-centered, organizations must extend the concept of patient-centered care beyond healthcare settings to consider patient needs across the entire healthcare system: transitions should be seamless; communication should flow freely; and patients should always know where to go for questions or concerns. Perhaps most importantly, healthcare providers must focus on keeping people healthy in their daily lives, rather than focusing only on encounters when patients are directly interacting with the healthcare system. Specific insights and suggestions for partnership opportunities include:
“Most people are understandably focused on the acute experience in this work. But let's just say that typically 1 of every 5 older people with multiple conditions may go to the hospital once a year, and a subset of them may return, and so will end up spending about 10 days out of that person’s year in the hospital. They still have 355 days to live. How do we think about people’s lives and help them do their best in the other 355 days in the year? There are certain things that should always happen in these 355 days. What is it that will help people retain their capacity, functionality, engagement, and mitigation of depression? What are the Always Events that are evidence-based that we can deploy to bring [this concept] back to everyday life and have new habits that are evidence-based and employable every day with almost no cost?”
-- Jennie Chin Hansen
“The work of IHI is embracing transitions, coordination, and the full cycle of care in populations. We are thinking about the patient as a person in terms of their whole life context, not just their inpatient context. As we consider chronic care, the frail elderly…the hospital is a small piece…and I'd love to see the concept of patient- and family-centered care always, not just in the hospital, but always.”
-- Jeff Selberg, MHA, Executive Vice President/COO, Institute for Healthcare Improvement
B. Meaningful Patient Engagement
Despite the widespread attention to patient-centered care, meaningful engagement of patients remains a challenge. Many organizations are still doing things to or for patients and their families, instead of in partnership with them. A patient-centered healthcare system preserves and strengthens relationships between patients/families and providers. Always Events® support this relationship-based approach to quality improvement because they directly involve patients, families, and frontline staff from the very beginning to define the need, identify an event and develop strategies for implementation. Specific insights into opportunities to deepen patient/provider partnerships included:
"One of the major lessons we learned from the Always Events® projects is that patients and families need to be part of the conversation from the very beginning. We can't redesign systems without them, they live the experience across settings, they are the ones managing their chronic illness in the primary care setting. The single best way... to unleash the core values of patient-centered care and compassionate healthcare...is to have patients and families part of the process. I bet if the rest of us went away we could build on the science of improvement by bringing the patient and family into the picture. We just need to set the expectation that the work we do together now and in the future will always involve patients and families. It's pretty simple, it's not rocket science, and it's not very costly."
-- Bev Johnson, President and CEO, Institute for Patient- and Family-Centered Care
"It's unbelievable the power of patients, families and caregivers that's untapped as a resource to change health care delivery."
-- Anthony M. DiGioia III, MD, Founder, The Orthopaedic Program and Innovation Center, Magee-Womens Hospital of University of Pittsburgh Medical Center
"If we are ever going to achieve the idea that Always Events will be applied to every healthcare venue and by every provider, Always Events has to be owned by the public. Because when the public starts to own something, when the public has an expectation, when they feel it's their right to protest when they are not allowed to walk a loved one into surgery...that's when something will happen. We have to engage the public. We now have a database of 41 projects. I think now is the time to come to some agreement about some core Always Events, not necessarily the whole gamut, but at least some set of standard, functional events we can all agree on. Then get people to wear the "Always Events" on buttons and walk into the [doctor's] office and demand them."
-- Barbara Packer, Managing Director/COO, The Arnold P. Gold Foundation
"I would democratize our knowledge. By that I mean [w]e could, much like Home Depot, package information that is usable and tested by the public as helpful that they could use relative to their well-being, [based] on evidence that we've had for a long time, but we as providers have not been putting it into play. . . . [L]et's do the best well-being commoditization of information that we can give to people so they don't have to always come through that tiny little pipeline [of providers]."
-- Jennie Chin Hansen
"We need to try to link patients regardless of where they are with that one individual or a whole group or a team of individuals who know them as a whole person. That's missing. Right now most care is being delivered by strangers."
-- Ed Wagner
"The role of healers has been central to almost every society...why? The number one desire of patients is a caring and concerned clinician. The evidence shows that people value a trusted counselor, a wise advisor. One way to advance the patient-centered care vision is to make the argument that the number one thing we [the healthcare system] do is caring. We value the caring role."
-- Brent James, MD, M.Stat, Executive Director at Intermountain Institute for Health Care Delivery Research and Chief Quality Officer, Intermountain Healthcare
"[At the end of a physician office visit, if the physician said]: 'I have one more question. Today in my office as I examined you and spoke with you, is there anything I could have done differently that would have made this a better experience for you?' That's how we ended the encounter. If we could just have that question [asked] every time, we'd be done. But the answer would be different every time and you'd have to be learning in real time."
-- Don Berwick
"A big part of public engagement is for people to be able to see what's going on (through public performance reports) and form their own opinion. After all, as the saying goes, 'it's my life that we're talking about, and I'm entitled to it' [public disclosure]."
-- Sir Donald Irvine, MD, FRCGP, FRCP, FMedSci, Former President, UK General Medical Council
"Just to acknowledge how far we have to go on patient engagement, one thing we have been working on for decades really is shared decision-making. We [the CAHPS team] are constantly trying to design questions that get at shared decision-making and our main problem is it happens so infrequently that you can't design good questions. People don't even know what you are talking about. The fundamentals are good in terms of changing the culture, in terms of engagement, putting the patient at the center, but in getting to systems changes that will facilitate these transitions, we've got work to do."
-- Paul Cleary
C. Staff Engagement/Joy in Work
In addition to focusing on patient engagement, the panelists urged that the focus be broadened to include relationships among staff. If staff are not working together effectively or are not supported by the organizational structure in which they work, that negativity will interfere with establishment of a positive staff-patient relationship. Restoring joy for the healthcare workforce, as well as redesigning the education of health professionals to foster collaborative relationships, are opportunities to advance patient-centered care.
With respect to improving the medical education system, the Picker Institute, in conjunction with the Arnold P. Gold Foundation, challenged its Graduate Medical Education (GME) grantees to incorporate Always Events® into their medical education grants and many developed creative ways to reinforce these concepts. More information about the GME grants is available at http://cgp.pickerinstitute.org/.
"I think part of this is cultivating the tenderness that people come into healthcare with and supporting it. Attention to the healers and supporting them is something that we haven’t done yet very much and we need to do more consciously. . . . When I used to work in hospitals (I was a respiratory therapist), I was struck over and over again by how mean people were to each other. . . . That culture has to be attacked and dismantled. When people are treated decently, their tendency will be to treat others with decency."
-- Peggy O’Kane
"All the clinicians I know have a whole person orientation. So then the question is why doesn’t this come through? I think one of the explanations is we teach it out of people. It’s not just that we [don’t] teach people how to do it, we teach it out of them. . . . If you teach people and unleash their inherent whole person orientation and caring, there’s just a deluge of feelings and the patients respond in kind. We take it out of people and we have to unleash that."
-- Paul Cleary
"How do we treat each other as caregivers? Aren’t the organizations that treat each other well those that treat patients well?"
-- Elliot Fisher, MD, MPH, Director for Population Health and Policy, Dartmouth Institute for Health Policy and Clinical Practice
"People behave badly in badly structured and badly performing systems. What we are seeing in the patient-centered medical home movement is when transformation is authentic and real, the biggest improvement is in staff joy in work, staff satisfaction and, associated with that, staff behaviors improve without extra training or incentives."
-- Ed Wagner
D. System Design and Accountability
For patient-centered care to become truly embedded in an organization and in the broader healthcare system, it must be dependent on reliable systems, rather than the behavior of individuals. Systems must be designed to deliver consistent, patient-centered results and there should be structures in place to hold accountable those organizations that fail to design such systems.
"It's very possible to have a bunch of really dedicated, well-meaning employees in a system that is not well organized and have the system do a dreadful job. We learn that lesson every day."
-- Peggy O'Kane
"If we were attentive to the person, we would see that there would be good flow [through the healthcare continuum]. A defining example is what happens at 5:00 [pm] on Friday when somebody gets discharged from the hospital? Usually it falls apart. We are not looking at the fact that the glide path should be as smooth as it is on Monday at 2:00 in the afternoon . . . Somehow our institutional structures have to be really sensitive to thinking about that from an industrial engineering consideration which would make it easy for the other party to have the most seamless, best experience possible."
-- Jennie Chin Hansen
"Patient-centeredness now is heavily dependent on the individual behaviors of individual members of large healthcare teams. It’s not hardwired into the system. . . . [Systems are perfectly designed to get the results they achieve. I think we’ve got to start thinking about how we make patient-centered care such a part of the organization design of systems that individual behaviors become less crucial. "
-- Ed Wagner
"The biggest, hardest problem we have in healthcare is reengineering systems. When we do that we are going to make life easier for a lot of healthcare workers and give them a little mind space for their compassion and so on. I saw this when I was visiting a Veterans Administration hospital . . . that was doing Toyota/LEAN [improvement methods] and I saw what they had done with the work of the nurse, where the buck stops. When it’s chaotic, it’s horrible for nurses. They basically had created new jobs and new categories of responsibility. They created order around the nurses; it changed their role incredibly."
-- Peggy O’ Kane
"There have to be consequences if things don’t work right. Consequences for chronic underperformance have got to be the order of the day."
-- Sir Donald Irvine
If board members, whose roles have varied tremendously, felt that they were the ultimate fiduciary for the quality of care and the finances and the board had to sign off . . . it causes a different accountability. The fact is they want to know then what is going on to make sure that we, as their staff, are really pointing the hospital toward a positive direction."
-- Jennie Chin Hansen
"We need to be willing to close hospitals that are not delivering acceptable levels of care. . . . I don’t think the stick is the only solution, but I think respect for the stick requires that we be very tough on places that are really underperforming."
-- Peggy O’ Kane
"Close places down or put sanctions that really have teeth in them. Right now the hospitals I see don’t feel competition, they’re not motivated, they are not experiencing the near death experiences of the auto makers or [what] different corporations go through. They have to be woken up. I would make it much more severe for the low-performing hospitals."
-- Paul Cleary
E. Measurement
Effective measurement of patient-centeredness remains a challenge. Patient experience metrics such as HCAHPS provide nationally standardized comparative information, but do not measure everything that is important to patients and families. Qualitative feedback is detailed and valuable but many organizations struggle with how to use it effectively to monitor and measure performance. If organizations exclusively focus on what is being measured, they may miss important opportunities to improve the patient experience by only “teaching to the test.” However, the use of valid and reliable measures also has produced some positive results.
"I think HCAHPS is a great start…but there are things that are fundamental to the patient experience that HCAHPS really doesn’t get at. As patient-centeredness becomes this very broad but not very deep interest in healthcare, I’m concerned that we don’t miss the boat about what is at its very core, and that is caring, and kindness, and compassion…and those are things we don’t have a really good grip on how to measure. Until we can measure these things, we’re not going to be able to manage them any better than we are right now."
-- Susan Frampton, President, Planetree
"We need to trust and create rigor around qualitative metrics. We can do this by listening to patient stories. Patient stories speak volumes. If we listen, really listen, to what patients and families are telling us, I believe we have metrics to guide our work."
-- Cheristi Cognetta Rieke, DNP, RN, University of Minnesota Amplatz Children’s Hospital
"I don’t think it’s true you can only manage what you can measure. I have a marriage that’s only gotten better over 36 years and I’ve never given my wife a questionnaire. We had better stay in touch with stories and narrative and relationships…I actually think we can go off track with too much focus on metrics…they are never really what we care about. [Survey questions] can help…but what I’m talking about is much more aspirational, it’s about human development and relationships."
-- Don Berwick
"Metrics do help, but at the institutional level they are not sufficient. To rate this hospital or that hospital just won't do. You've got to be able to get down to performance as seen through the patient's eyes at the individual nurse and clinician and the team."
-- Sir Donald Irvine
"I think we've gone too far with trying to measure everything...and it's forcing clinicians to treat everyone the same. We need to have a care plan for each patient...not something that's universal...and then measure if we followed that care plan for each patient."
-- A. Blanton Godfrey, PhD, Dean and Professor, College of Textiles, North Carolina State University
"Rather than diminish the importance of metrics, perhaps we should think about other kinds of metrics. One of these might be organizational metrics. For example, are organizations heading down the path toward Always Events or always patient-centered care? One way to do this is to measure how much institutions are building patient and family advisory councils into their operations."
-- Steve Schoenbaum, MD, Vice Chairman, Picker Institute Board
[If you taught to the test using HCAHPS,] your hospital may treat your patients with dignity and respect, they may tell them about the purposes of their medications, they may tell them what they can and can’t do when they’re discharged, they may worry about their pain. If they taught to the test, that’s not that a bad outcome. . . . HCAHPS scores over the past several years since they’ve been publicly reported are going up. Is that everything? No. Is that a good thing? I would say absolutely yes."
-- Paul Cleary
"Every time we do something . . .we have to think about the person beyond the walls of the institution that gets measured, about how people’s lives are affected post those glass doors that we get wheeled out of."
-- Jennie Chin Hansen
IV. Call to Action
The Picker Institute has been proud to be at the forefront of the movement to advance patient-centered care for nearly three decades. Although the Institute is closing its doors, its work will be carried forward by the Institute's partners -- the Arnold P. Gold Foundation, the Institute for Healthcare Improvement, the Institute for Patient and Family Centered Care, and Planetree -- and the thousands of dedicated professionals that work tirelessly each day to improve the experience of patients and families. The concept of patient-centered care is here to stay. The challenge is to make the concept not only authentic but deep, and to embed it across the entire continuum of care. With Always Events® as a framework, healthcare professionals, researchers, and policymakers working together can ensure that every person receives patient-centered care in every interaction with the healthcare system.
"This is the Institute’s final contribution to the field. Always Events is a game changer but not in a disruptive way. Always Events® is a positive affirmation for the healthcare delivery system -- a way forward where all focus is on patient-centered care, quality improvement, and its seamless absorption into the fabric of the American healthcare system. The Picker Institute's Always Events® initiative is the enduring leitmotif that as the Institute exits the stage will be left for others to ponder, embrace, and incorporate into the new healthcare world order. It's out of our hands now, this patient-centered care journey and it's in yours. We pass the torch to each of you and we know that you will carry it forward. Thank you."
Lucile Hanscom, Executive Director, Picker Institute
The Picker Institute's final words are those of its founder, Harvey Picker, spoken shortly before his death in 2008:
"Carry On!"
Appendix A: Brief Bios of Panelists
Donald M. Berwick, M.D., M.P.P., is the former President and Chief Executive Officer of the Institute for Healthcare Improvement, which he co-founded in 1989. He has also served as Clinical Professor of Pediatrics and Health Care Policy at the Harvard Medical School, Professor of Health Policy and Management at the Harvard School of Public Health and consultant in pediatrics at Massachusetts General Hospital and adjunct staff in the Department of Medicine at Boston’s Children’s Hospital. He most recently served as Administrator of the Centers for Medicare & Medicaid Services.
Paul D. Cleary, PhD is the Dean of the Yale School of Public Health and is the Anna M.R. Lauder Professor of Public Health. Dr. Cleary is a principal investigator for one of the CAHPS (Consumer Assessment of Healthcare Providers and Systems) grants from AHRQ (Agency for Healthcare Research and Quality) to develop surveys for collecting information from consumers on their health plans and services.
Jennie Chin Hansen, RN, MS, FAAN is CEO of the American Geriatrics Society. Prior to this she served for two years as president of AARP. In 2005, Hansen had spent nearly 25 years with OnLok Inc., a nonprofit family of organizations providing integrated, globally financed and comprehensive primary, acute and long-term care community based-services in San Francisco. The OnLok prototype became the 1997 federal Program of All-Inclusive Care to the Elderly (PACE) Program into law for Medicare and Medicaid. PACE now has urban and rural programs in 30 states.
Margaret E. O’Kane is the founding president of the National Committee for Quality Assurance and one of the nation’s leading advocates for improving healthcare quality through measurement, reporting and accountability. Under her leadership, NCQA has been widely recognized as a leader in the healthcare quality field; in 2005, NCQA received awards from the National Coalition for Cancer Survivorship, the American Diabetes Association and the American Pharmacists’ Association.
Dr. Ed Wagner is the former director of the MacColl Institute for Healthcare Innovation at Group Health in Seattle, Washington. He is best known for his leading role in developing and disseminating the Chronic Care Model through “Improving Chronic Illness Care (ICIC),” an evidence-based framework that describes what a healthcare system must do to help patients with diabetes, heart disease, depression and other conditions get the kind of care they need when they need it.
Other Contributors:
Cheristi Cognetta Rieke, DNP, RN, University of Minnesota Amplatz Children’s Hospital
Anthony M. DiGiioa III, MD, Founder, The Orthopaedic Program and Innovation Center, Magee-Womens Hospital
Elliott Fisher, MD, MPH, Director for Population Health and Policy, Dartmouth Institute for Health Policy and Clinical Practice
Susan Frampton, President, Planetree
Lucile O. Hanscom, Picker Institute, Executive Director
Sir Donald Irvine, MD, FRCPG, FRCP, FMedSci, Former President, UK General Medical Council
Brent C. James, MD, M.Stat, Executive Director at Intermountain Institute for Health Care Delivery Research
Beverley H. Johnson, President and CEO, Institute for Patient- and Family-Centered Care
Barbara Packer, Managing Director/COO, The Arnold P. Gold Foundation
Stephen C. Schoenbaum, MD, Vice Chairman, Picker Institute Board
Jeffrey D. Selberg, MHA, Executive Vice President/COO, Institute for Healthcare Improvement
Appendix B: About the Picker Institute
(excerpted from remarks by Lucile Hanscom at the December 10, 2012 Picker Institute Award Recipient Panel Presentation)
The Picker Institute is an independent nonprofit organization that was dedicated to promoting the advancement of patient-centered care and the improvement of the patient’s experience and interaction with healthcare providers. The Picker Institute led the way in creating scientifically valid nationwide surveys and databanks on patient-centered care to help educate doctors, hospital staff and other caregivers to the benefits of patient-centered care. The patient’s perspective—“Through patient’s eyes”—is now one of the standard metrics of performance routinely measured by healthcare organizations.
The genesis of the Picker Institute lies with the James Picker Foundation. In 1986, the James Picker Foundation took on what they considered a moral obligation. Armed with a vision of increasing the health care system’s capacity to respond to patients, one very small group of academic radiologists, simply harnessed a power. A power derived from hope, and their relentless optimism about the potential of a small group to bring about positive change. They dedicated themselves to an ideal and that ideal would soon become known as, “patient-centered care”. Through the power of their personal relationships - with individuals and organizations - and sustained dedicated effort, this small foundation turned their ideas into action and ultimately met a remarkable strategic vision. Joining forces with Commonwealth Fund, they funded a multi-year research project, which consisted of 11 interrelated projects intended to enhance communication between patients and their health care providers for the purpose of improving healthcare.
Over time, the results included:
- the design of the term patient-centered care,
- the 8 principles of patient-centered care,
- the creation of the Picker Institute and
- the first scientifically validated patient experience surveys, designed to assess the patient’s perceptions of their healthcare experience, which influenced the development of the CAHPS and HCAHPS surveys.
For the past 12 years, the Picker Institute’s work has focused on fostering the mission:
- internationally - with subsidiary offices in Germany, Switzerland, and a sister organization in England (Picker Institute Europe),
- a strong national education program,
- the prestigious Picker Awards for Excellence,
- a very robust research agenda that has supported almost 200 research projects, and
- the broad dissemination of best practice tools and strategies.
All of these efforts led to the Picker Institute’s final contribution to the field – Always Events®.
Throughout its history, the Picker Institute did more than just raise awareness and measure the scope of the problem; it actively sought solutions and created a web-based national clearinghouse of freely
available best practice information, including tools and strategies. Among the most recent materials the Picker Institute has created to guide others toward a more patient-centered future are:
- Always Events® Blueprint for Action and Always Events® Solutions Book
[http://alwaysevents.pickerinstitute.org/?p=1759](http://alwaysevents.pickerinstitute.org/?p=1759)
- Always Events® Toolbox
[http://alwaysevents.pickerinstitute.org/?page_id=882](http://alwaysevents.pickerinstitute.org/?page_id=882)
- Graduate Medical Education Toolbox
[http://cgp.pickerinstitute.org/?page_id=1230](http://cgp.pickerinstitute.org/?page_id=1230)
- Long-Term Care Improvement Guide
[http://www.residentcenteredcare.org/](http://www.residentcenteredcare.org/)
- Patient-Centered Care Improvement Guide
[http://www.patient-centeredcare.org/](http://www.patient-centeredcare.org/)
This report was co-authored by Carrie Brady and Dale Shaller, consultants to the Picker Institute for the Always Events® program and other patient-centered care research and education projects. The authors would like to thank the Picker Institute for its leadership in patient-centered care, for the wide array of resources it leaves to guide others, and for the opportunity to be involved in such meaningful work.
Picker Institute Board of Directors
(left to right)
Stephen C. Schoenbaum, Sir Donald Irvine, Sam Fleming, Lucile O. Hanscom, Gail L. Warden, J. Mark Waxman
Not pictured: David C. Leach
Picker Institute Staff
(left to right)
Lucile Hanscom, Carolyn Marsh, Kathy Cassidy, Hannah Honor Hanscom
Picker Institute Consulting Team
Dale Shaller, Shaller Consulting Group
Carrie Brady, CBrady Consulting
Dedicated to Harvey Picker,
health care providers who make a difference every day,
and, most importantly, to patients
|
Predicting LoRaWAN Capacity
Version 2.0
TN1300.05 March 2024
# Table of Contents
| Section | Page |
|------------------------------------------------------------------------|------|
| List of figures | 2 |
| List of tables | 3 |
| 1. Introduction | 4 |
| 2. Signal Levels | 5 |
| 3. Orthogonality Factor | 7 |
| 3.1. Interference Levels Observed in Measured Data | 7 |
| 3.2. Orthogonality Factor Simulation | 8 |
| 3.3. Interference Levels Inferred from Simulated Data | 10 |
| 4. Prediction of Collisions and Packet Error Rate (PER) | 12 |
| 4.1. Collision Probability in Random Access (ALOHA) | 12 |
| 4.2. Single Gateway Packet Error Rate | 12 |
| 4.3. Network Packet Error Rate of a Frame | 14 |
| 5. Prediction of Collisions and Packet Error Rate – Simulated Network | 16 |
| References | 18 |
| Disclaimer | 19 |
List of figures
Figure 1. Signal Level Distribution of Received Frames
Figure 2. RSSI Comparison - One Gateway and Multiple Gateways
Figure 3. RSSI Distribution per Data Rate and Traffic Load over Time
Figure 4. Network Simulation
Figure 5. Average Interference levels from Out-of-Range Devices
Figure 6. Packet Count per Hour and Data Rate Distribution
Figure 7. Channel Load
Figure 8. Average Reception Redundancy
Figure 9. Derived Collision Rate versus Load
Figure 10. Data Rate and Corresponding PER
List of tables
Table 1. Data Rates and Required Signal-to-Noise Ratios
Table 2. Orthogonality Matrix
Table 3. Simulated Orthogonality Matrix
Table 4. Load Per Gateway, by Spreading Factor
Table 5. Average Load
Table 6. Overlap Probabilities
Table 7. Collision Rate Probability for a Single Gateway
Table 8. Collision Probabilities for Stage 3 of the Trial
Chapter 1. Introduction
This document is a theoretical analysis of a LoRaWAN® network trial performed by MachineQ and Semtech in Philadelphia in 2017. The trial consisted of 10 indoor gateways and 108 indoor devices in an urban environment. The goal of the trial was to demonstrate the network capacity of LoRaWAN.
During the trial, devices sent approximately one million frames, over two days. The network load was set to various levels. The success rate evolved accordingly and was always higher than 96 percent.
From the analysis, we show that closed-form formulas can predict capacity accurately. We also show that these formulas can replace long simulations.
Chapter 2. Signal Levels
First, let’s analyze the statistics related to the received signal strength. For each frame we have access only to the highest RSSI received. If more than one gateway receives the frame correctly, we know the number of gateways which received the signal, but not the individual RSSI for each gateway. Since LoRa® operates below the noise floor, the RSSI itself can be lower than the noise floor, which is approximatively -120dB.
We also know the data rates used. This test was conducted in the US region, so only SF7, SF8, SF9 and SF10 were used (not SF11 nor SF12).
Figure 1 shows the RSSI distribution of correctly received frames. The legend for each curve indicates the proportion of frames which follow this distribution, the average RSSI (in dBm), and the standard deviation of RSSI (in dB). For instance, 30.7% of frames are received by exactly 3 gateways; when this occurs the average RSSI is -103.7dBm and the standard deviation of RSSI is 5.9dB.
**Figure 1. Signal Level Distribution of Received Frames**
We see that most frames were received by two or three gateways. The number of gateways receiving a signal depends on how the LoRa Network Server (LNS) configures the Adaptive Data Rate (ADR). Different ADR settings can have different redundancy targets leading, for instance, to a lower ratio of single gateway receptions. Here 17% of frames are received by a single gateway.
The next figure is an attempt to model the cases of one, two, three, and four gateways receiving the signal, in comparison to just one. The blue curve shows the mean and standard deviation, and models the single receiving gateway case with a Gaussian distribution with same mean and standard deviation. We then model the case of two receiving gateways with a maximum of two independent Gaussian variables. For three gateways we take a maximum of three, etc.
We see that there is a good fit between the observed data and the modeled curves, whatever the number of receiving gateways (i.e., the plain lines match the dotted lines). This means that modeling the RSSI by a Gaussian variable is valid, and when a signal is received over several gateways, each RSSI is independent. There is a peak in the observation at -102 dBm, which corresponds to a measurement bias. This bias comes from a rounding error of the gateway, which makes -102 dBm twice as likely as -101 or -103.
Chapter 3. Orthogonality Factor
3.1. Interference Levels Observed in Measured Data
Data rates orthogonality is a shortcut for expressing that different data rates can coexist. Indeed, assuming data rates are different, an aggressor frame will affect a victim frame only as much as white noise would. Since LoRa data rates can be received with negative signal-to-noise ratios (SNR), frames with different data rates can be received at the same time. Table 1 shows the required SNRs for each data rate. These numbers correspond to first-generation LoRa demodulators, the second generation is 1dB better.
Table 1. Data Rates and Required Signal-to-Noise Ratios
| Data Rate | SF5 | SF6 | SF7 | SF8 | SF9 | SF10 | SF11 | SF12 |
|-----------|-------|-------|-------|-------|-------|-------|-------|-------|
| Required SINR | -2.5dB | -5dB | -7.5dB | -10dB | -12.5dB | -15dB | -17.5dB | -20dB |
In addition, for same data rate interference, when there is a signal level difference higher than 7dB, the strongest frame is received correctly. This holds true when the coding rate is 4/5, normal interleaving, which is the LoRaWAN default LoRa PHY configuration.
Next, we plot the measured RSSI distribution per data rate. On the same plot, we will also show the traffic load versus time. While the traffic load varies over time, the data rate ratios remain constant, as does the RSSI distribution per data rate. The set-up is tested with a single data rate (SF10), then the first load level is tested from hours 7 to 18, a higher load from hour 19 to 30, and the highest load from hour 31 to 45.
Figure 3. RSSI Distribution per Data Rate and Traffic Load over Time
From this distribution, and the table above, we can compute the probability that a time overlap of frames yields the loss of a frame. The distribution is simplified to four random Gaussian variables with same mean and Sigma as the observed distribution. We report this in a matrix, with columns representing the aggressing data rate, and lines the victim data rate.
**Table 2. Orthogonality Matrix**
| Data Rate | SF7 | SF8 | SF9 | SF10 |
|---------------|-------|-------|-------|-------|
| SF7 as victim | 86% | 10% | 3% | 8% |
| SF8 as victim | 8% | 84% | 2% | 6% |
| SF9 as victim | 11% | 9% | 85% | 8% |
| SF10 as victim| 6% | 5% | 2% | 78% |
This table shows that if a frame transmitted using SF8 is overlapped by an SF10 frame while being received by a gateway, there is a six percent probability that the SF8 frame will not be received correctly. Thus, there is a 94 percent probability that the gateway will receive the frame correctly.
If the orthogonality were perfect, there would be a zero percent error rate for overlaps, except on the diagonal.
In this dataset, the RSSI measures are incomplete because we only have access to the best RSSI among all receiving gateways of each frame. It is difficult to determine how different the orthogonality matrix would be with a complete set of measures.
### 3.2. Orthogonality Factor Simulation
Let’s look at a slightly different scenario, one with indoor/deep indoor nodes, and outdoor gateways. The simulation uses 660 gateways with a density of 1.5 gateways per square kilometer (950 m site distance). 100,000 nodes are spread on the grid, and propagation to each gateway is simulated using the Hata model[1] for a small-to-medium city, with shadowing, fast fading, and indoor penetration losses distributed from 20dB to 40dB. The path loss exponent value here is 3.6.
Figure 4. Network Simulation
Spreading factors SF7 through SF12 are used in this example. Here, we apply an Adaptive Data Rate (ADR) and Transmit Power Control (TPC) strategy with a margin of 8dB to account for fast fading. The range of TPC is 20dB, i.e. once the fastest data rate is reached, the transmitted power can be reduced by up to 20dB.
To compute the orthogonality matrix, we consider the gateways in the center, and gather the distribution of RSSI for each data rate. Then we proceed as with the measured data: for each couple of spreading factors, (victim SF, aggressing SF), we derive the probability that the aggressing SF RSSI is too high for the victim frame to be received. This probability is the probability of (RSSI_aggressor > (RSSI_victim - victim_required_sinr)). For instance, if victim is SF12, and aggressor SF7, this is the probability:
\[ P = \text{Proba}(RSSI_{SF7} > (RSSI_{SF12} + 20dB)) \]
This probability is computed as:
\[ P = \int_{x=-142dBm}^{0dBm} \text{proba}(RSSI_{SF7} > (x + 20dB)) * \text{proba}(RSSI_{SF12} = x) \]
Table 3. Simulated Orthogonality Matrix
| Data Rate | SF7 | SF8 | SF9 | SF10 | SF11 | SF12 |
|---------------|-------|-------|-------|-------|-------|-------|
| SF7 as victim | 76% | 5% | 1% | 0% | 0% | 0% |
| SF8 as victim | 17% | 80% | 1% | 0% | 0% | 0% |
| Data Rate | SF7 | SF8 | SF9 | SF10 | SF11 | SF12 |
|-----------|------|------|------|------|------|------|
| SF9 as victim | 17% | 6% | 80% | 0% | 0% | 0% |
| SF10 as victim | 18% | 6% | 2% | 80% | 0% | 0% |
| SF11 as victim | 18% | 6% | 2% | 0% | 81% | 0% |
| SF12 as victim | 18% | 6% | 2% | 0% | 0% | 64% |
This matrix is slightly different than that shown in Table 2, which relies on incomplete measures. We can note, however, that if we remove the diagonal, the sum of each line is roughly the same. Given this information, we can see that ADR and power control tend to give devices with a higher RSSI a higher data rate, which means these devices have a better chance of creating errors in case of a collision.
In this MachineQ and Semtech trial, there is no ADR; each physical device emulates traffic from several virtual devices, using the four data rates.
### 3.3. Interference Levels Inferred from Simulated Data
The measured data is generated from a relatively small network, with only 10 gateways in the same neighborhood. Thanks to the simulation, we can estimate how much additional noise comes from devices that are not in range of a given gateway. Collisions can be classified as one of two types: collisions from frames that can be received by the gateway we consider, or collisions from frames that are out of the coverage area.
Next, using the simulation above, let’s consider a central gateway and count the devices in range, along with the data rate at which they operate. We then define three channel load levels: 10 percent, 100 percent, and 400 percent. The 400 percent load means that on average, on each LoRa channel, four transmissions of in-range devices occur. For each channel load, we derive the duty cycle required to achieve the load specified for the in-range devices, assuming an identical rate of frames per device, whatever their data rate. Last, we apply the same duty cycle to the devices that are not in range, and measure the average power received by the central gateway from these devices. We compute this sum over different disk sizes, to check whether the integral converges. The result is plotted in Figure 5. We compare this average interference level to the thermal noise floor. This thermal noise floor is experienced by any receiver, and values at normal temperature are $-114\text{dBm/MHz} + \text{NF}$, where $\text{NF}$ is the noise figure of the receiver. In our case, the bandwidth is 125KHz, and typical NF is 3dB for a gateway, so receiver noise floor is:
$$-114\text{dBm/MHz} + 10 \times \log_{10}(0.125\text{MHz}) + 3\text{dB} = -120\text{dBm}.$$
First we see that the integral converges.
This convergence is expected, since the path loss exponent (PL) is higher than 3. To explain this point, let us note $itf(r)$, the total interference level from devices within a disk of radius $r$. It is computed with:
$$itf(r) = K \cdot \int_{d=0}^{r} \pi d^2 \ast \frac{1}{d^{PL}} = K \cdot \int_{d=0}^{r} \pi \frac{1}{d^{PL-2}}$$
where $K$ is a constant that depends on node density, transmit power, and average impact of shadowing and fast fading. Such an integral converges as $r$ grows if $PL-2>1$, i.e. $PL>3$.
In addition to convergence, we also see that a two kilometer radius is enough to gather most of the interference from devices which are out of range of the gateway.
Second, it is clear that the average interference level coming from devices not in range is lower than the thermal noise, even at a high network load. This shows that we can neglect the interference from out-of-range devices, as such interference does not increase the average noise floor.
Of course, the instantaneous interference power might be higher. Taking a disc radius of two kilometers, we count seven times more unconnected devices than connected devices. This means that at a load of 400 percent there are, on average, 28 simultaneous transmissions from out-of-range devices that contribute to the interference level. The maximum interfering power from a single device corresponds to an SF7 transmission, which would be just below SF7 receiving sensitivity, i.e. -130dBm.
Chapter 4. Prediction of Collisions and Packet Error Rate (PER)
4.1. Collision Probability in Random Access (ALOHA)
The usual formula for calculating the probability of collision is:
\[ P_{\text{col}} = 1 - \exp(-\text{load}^2) \]
Where load is the offered load. This assumes that when a time overlap occurs, both frames are lost. This also assumes that all frames have equal length.
A more generic formula can be used, assuming that the length of victim and aggressor frames are different. We call it the probability of time overlap, rather than collision, because a time overlap does not always result in lost frames.
\[ P_{\text{ovlap}} = 1 - \exp(-\text{load_interferer} \times (1 + \frac{\text{length_victim}}{\text{length_interferer}})) \]
When \( \text{length_victim} \) is null, we go to the known formula of probability that channel is occupied, at any instant.
When \( \text{length_victim} \) equals \( \text{length_interferer} \), we go to the classic formula.
Last, if \( \text{length_victim} \) tends to infinity, the probability of overlap tends to 1, whatever the load of the interferer might be.
4.2. Single Gateway Packet Error Rate
Let’s compute the load per gateway, i.e. the traffic each gateway receives.
The frames all have 8 bytes of LoRaWAN payload, Table 4 below shows their duration.
Table 4. Load Per Gateway, by Spreading Factor
| Data Rate | SF7 | SF8 | SF9 | SF10 |
|-----------|-----|-----|-----|------|
| Time on Air | 57ms | 103ms | 185ms | 377ms |
We cannot directly observe the offered load for each gateway because some packets are lost and because the logs only provide the number of receiving gateways, rather than the gateway IDs. Figure 5 shows the total number of received frames, without duplicates, over time. From these curves, we then derive the spreading factor distribution, to check whether it is relatively constant over time.
Next, we derive the load for the network, noting that the load is evenly spread over eight channels. Figure 6 shows the load for each channel.
Figure 6. Packet Count per Hour and Data Rate Distribution
Figure 7. Channel Load
Now we compute the average load for the three steps of the trial, as shown in Table 5.
**Table 5. Average Load**
| Test Phase vs Load | Phase 1 | Phase2 | Phase 3 |
|--------------------|---------|--------|---------|
| SF7 load | 0.7% | 1.3% | 2.8% |
| SF8 load | 0.9% | 1.9% | 4.0% |
| SF9 load | 1.8% | 3.4% | 7.1% |
| SF10 load | 1.1% | 3.2% | 6.6% |
| Total load | 4.4% | 9.8% | 20.4% |
From the load, we compute the probabilities of overlap. For each phase, there are four probabilities for each data rate. Here, we take the example of Phase 3, and report the overlap probabilities in Table 6.
**Table 6. Overlap Probabilities**
| Overlap % | SF7 interf. | SF8 interf. | SF9 interf. | SF10 interf. |
|-----------------|-------------|-------------|-------------|--------------|
| SF7 as victim | 5.4% | 5.8% | 8.5% | 7.2% |
| SF8 as victim | 8.1% | 7.7% | 10.1% | 7.9% |
| SF9 as victim | 13.1% | 11.3% | 13.2% | 9.4% |
| SF10 as victim | 22.3% | 18.1% | 19.2% | 12.4% |
Not all time overlaps result in reception errors. We can now use the pseudo orthogonality matrix to multiply, term by term, the overlap probabilities. This gives the collision probability. The sum of each line is the total probability of collision, from all data rates. We report the collision rate, for a single gateway, in Table 7. We see that, compared to Table 6, the diagonal terms are slightly reduced, while the non-diagonal terms are reduced a considerable amount, thanks to the orthogonality of the various spreading factors.
**Table 7. Collision Rate Probability for a Single Gateway**
| Overlap % | SF7 interf. | SF8 interf. | SF9 interf. | SF10 interf. | Total |
|-----------------|-------------|-------------|-------------|--------------|-------|
| SF7 as victim | 4.7% | 0.6% | 0.2% | 0.6% | 6.1% |
| SF8 as victim | 0.7% | 6.5% | 0.2% | 0.5% | 7.8% |
| SF9 as victim | 1.4% | 1.1% | 11.3% | 0.7% | 14.5% |
| SF10 as victim | 1.4% | 1.0% | 0.3% | 9.6% | 12.4% |
### 4.3. Network Packet Error Rate of a Frame
To determine the network PER, we compute the gateway redundancy from the received packets. We then assume that this redundancy is very close to what it would be without collisions. (This is backed by the fact that the redundancy is stable during the three stages of the trial.)
Instead of taking the redundancy directly, we subdivide it by the single receiving gateway case, the two gateways case, the three gateways case, etc. The final results come from the weighted average of the probability of these distinct cases.
To give a simplified example, let’s assume that 30% of frames are received by a single gateway, 50% by two gateways, and 20% by 3 gateways. The network level probability of error per packet $PER_{nwk}$, from a gateway level probability $PER_{gw}$, will be:
$$PER_{nwk} = 0.3*PER_{gw} + 0.5*(PER_{gw})^2 + 0.2*(PER_{gw})^3.$$
This gives the following collision probabilities for each SF for the third stage of the trial.
**Table 8. Collision Probabilities for Stage 3 of the Trial**
| Collision | Data Rate 3 (SF7) | Data Rate 2 (SF8) | Data Rate 1 (SF9) | Data Rate 0 (SF10) |
|----------------------------|------------------|-------------------|-------------------|--------------------|
| GW Density Expected Success Rate | 97.00% | 96.70% | 95.40% | 96.10% |
| 2.5 GW Density Actual Success Rate | 97.80% | 96.72% | 96.50% | 96.40% |
| Delta | +0.80% | +0.02% | 1.10% | +0.30% |
We see that this closely matches our observations.
Chapter 5. Prediction of Collisions and Packet Error Rate – Simulated Network
We now show that this method can be applied to a simulated network. We start with a propagation and ADR simulation, then we compare the results from an explicit collision simulator and the closed formulas described above.
The explicit collision simulator creates a time grid, adds frames to this grid, computes received signal levels for all gateways at each time instant, then computes the PER from each frame’s SINR. The load is varied, so the end result is the system PER as a function of load. The load unit is the number frames per hour per gateway. This number is the total number of frames divided by the number of gateways, so that multiple receptions have no impact on our definition of load.
The method using closed form formulas starts with the same propagation and ADR simulation. This gives signal levels and data rates for all simulated devices. From these we compute the orthogonality matrix. Then, for each load, we compute overlapping probabilities and collision probabilities at the gateway level. Last, from the reception redundancy for each spreading factor, which is also an output of the propagation and ADR simulation, we derive the PER at the network level.
The comparison of two methods is shown in Figure 9.
**Figure 9. Derived Collision Rate versus Load**
The dotted green line indicates that the ADR is worse. The ADR margin is raised from 5dB to 8dB, meaning a higher average redundancy (1.8 compared to 1.4 gateways), and the TPC is reduced from 20dB to 15dB. The primary effect of this is to increase the load of the lowest data rate. The propagation model here assumes placement of devices indoors/deep indoors (20dB to 40dB penetration losses). We also expect the devices to be static, so a low margin of 5dB is reasonable. SF12 devices have a higher redundancy than average: 1.9 gateways at 5dB ADR margin.
Figure 10 shows the result of another simulation, where we see that the PER depends on the data rate. Low data rates tend to have a higher PER.
From this curve, we can see that from a capacity perspective, message repetition is a good strategy. For instance, looking for a PER=1%, the maximum load is 10,000 messages per hour. This means that with a single transmission, 10,000 messages per hour can be transmitted to achieve a PER of 1%.
To achieve 1% PER after two transmissions, the single transmission PER target becomes 10%, this is because frames are independent from the point of view of collisions, therefore the probability of losing 2 frames is (10%)^2 = 1%. 10% PER for single transmissions corresponds to 110,000 messages per hour, or 55,000 unique messages with double transmission. Last, triple transmission corresponds to 21.5 percent PER, as (0.215)^3 = 1%, and a unique load of ~240,000/3 = 80,000 messages per hour.
Repetition, therefore, increases capacity for a given Quality of Service (QoS) target. Of course, it is possible to adjust the repetition rate to the device data rate. Delay between successive transmissions does not matter.
It is also possible to use a Forward Error Correction on groups of messages, which is a generalization of messages repetition. This trades PER for delay, and considerably reduces the overhead when compared to systematic repetition. For applications that are not delay-sensitive, this is the solution of choice.
References
- [1] From Wikipedia, the free encyclopedia, Hata model
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Expanding the Rehabilitation of Injured Service Members Using Immersive, Large-Scale Virtual Environments
Pinata H. Sessoms\textsuperscript{1}, Sarah E. Kruger\textsuperscript{2}, Alison L. Pruziner\textsuperscript{3-5}, and Christopher A. Rábago\textsuperscript{3,6}
\textsuperscript{1}Naval Health Research Center (NHRC), San Diego, CA; \textsuperscript{2}National Intrepid Center of Excellence (NICoE), Walter Reed National Military Medical Center, Bethesda, MD; \textsuperscript{3}Extremity Trauma and Amputation Center of Excellence; \textsuperscript{4}Department of Rehabilitation, Walter Reed National Military Medical Center, Bethesda, MD; \textsuperscript{5}Department of Rehabilitation Medicine, Uniformed Services University of the Health Sciences; \textsuperscript{6}Center for the Intrepid (CFI), Brooke Army Medical Center, Joint Base San Antonio Fort Sam Houston, TX
NHRC Disclaimer
I am a military service member (or employee of the U.S. Government). This work was prepared as part of my official duties. Title 17, U.S.C. §105 provides the “Copyright protection under this title is not available for any work of the United States Government.” Title 17, U.S.C. §101 defines a U.S. Government work as work prepared by a military service member or employee of the U.S. Government as part of that person’s official duties.
This work was supported by the Navy Bureau of Medicine and Surgery’s Wounded, Ill, and Injured Program under work unit no. N1703. The views expressed in this research are those of the authors and do not necessarily reflect the official policy or position of the Department of the Navy, Department of the Army, Department of the Air Force, Department of Veterans Affairs, Department of Defense, or the U.S. Government. Approved for public release; distribution unlimited.
Human subjects participated in this study after giving their free and informed consent. This research has been conducted in compliance with all applicable federal regulations governing the protection of human subjects in research (Protocols NHRC.2011.0017, NHRC.2013.0022, and NMCSD.2011.0003).
Disclosures
• No personal disclosures
• The view(s) expressed herein are those of the author(s) and do not reflect the official policy or position of Brooke Army Medical Center, Naval Medical Center San Diego, Naval Health Research Center, Walter Reed National Military Medical Center, the U.S. Army Medical Department, the U.S. Army Office of the Surgeon General, the Department of the Army, Department of the Navy, Department of Defense, Department of Veterans Affairs, or the U.S. Government.
• All persons presented within have given their expressed written consent to be filmed and/or photographed.
Today’s Presentation
• Who we are
• Naval Health Research Center (NHRC)
• Walter Reed National Military Medical Center (WRNMMC)
• Brooke Army Medical Center, Center for the Intrepid (CFI)
• National Intrepid Center of Excellence (NICoE)
• What we do
• Who we serve
• Clinical and research priorities
DoD VR Sites for Rehabilitation
How Are Large-Scale Virtual Environments (VEs) Used in DoD Rehab?
Assessment and Treatment
• Patient-specific (Collins et al 2015)
– Orthopaedics, extremity trauma, and amputation
• (Kruger, 2011; Darter & Wilken, 2011; Gates, Darter, Dingwell, & Wilken, 2012; Kaufman, Wyatt, Sessoms, & Grabiner, 2014; Sheehan, Rábago, Rylander, Dingwell, & Wilken, 2016)
– Traumatic brain injury (TBI)
• (Rábago & Wilken, 2011; Sessoms et al., 2015; Onakomaiya et al., 2017)
– Vestibular dysfunction
• (Gottshall, Sessoms, & Bartlett, 2012; Gottshall & Sessoms, 2015)
Goal: To optimize wounded warrior rehabilitation using physical and cognitive tasking in challenging but safe environments
NHRC’s Computer Assisted Rehabilitation Environment (CAREN)
- Optical motion capture system
- 3D video projectors (3)
- 180° curved screen
- 6-DoF motion platform
- Instrumented split-belt treadmill (high performance)
- Surround sound
(Photo courtesy of NHRC)
CFI’s CAREN High-End System
http://www.bamc.amedd.army.mil/departments/orthopaedic/cfi/vignettes.asp
(Video courtesy of CFI)
Goal Oriented: Patient-Specific Flexibility of Applications
(Photos and Videos courtesy of WRNMMC)
WRNMMC: Return/Learn to Ski Program
- Objective: To return patients to civilian life/sport, specifically skiing
- Virtual environment allows:
- Simulate complex tasks prior to real-world
- Practice/training with adaptive equipment
- Patients completed questionnaires pre-training sessions, when on ski trip, and post-training
- 2/3 felt ski application prepared them for the ski trip
- All but one felt application utilized musculature that was used during actual activity
- All stated would recommend trialing equipment and practicing on CAREN to future patients
NHRC: Community Reintegration
• Patient with knee-ankle-foot orthosis with IDEO base (kIDEO).
• Tasking static and dynamic stability with novel and engaging exercises relevant to patient’s life.
Objective Measures Using Virtual Reality (VR) Componentry
- Systems can be used to record data for clinical research and outcomes
- Stimulus response
- Task performance (e.g. reaction time), physiologic, metabolic
- Biomechanics
- Joint powers, moments, kinematics
- Balance, stability
Online Monitoring of Brain Activities With Mobile Electroencephalography Systems
• Application for objective, real-time assessments of how an individual experiences the environment (e.g., cognition, fatigue)
Multisensory Assessments
Assessing the Impact of mTBI on Multisensory Integration While Maneuvering on Foot (PI: Douglas Brungart)
(Photos courtesy of NICOE)
Novel Applications of Traditional Cognitive Tests
(Video courtesy of WRNMMC)
NICoE: Acclimation to the CAREN
Three Preliminary VEs
CAREN Performance Measures:
- Balance Balls and Balance Cubes = time spent (s)
- Continuous Road = self-selected speed (m/s)
Balance Balls
Balance Cubes
Continuous Road
(Photos courtesy of NICoE)
NICoE: Diminished Performance With Comorbidities
Balance Balls
- Time (s)
- TBI Only: $n = 63$
- Comorbid PH: $n = 147$
- $p = 0.001$
Continuous Road
- Speed (m/s)
- TBI Only: $n = 53$
- Comorbid PH: $n = 121$
- $p = 0.018$
Balance Cubes - Static
- Time (s)
- TBI Only: $n = 62$
- Comorbid PH: $n = 147$
- $p = 0.002$
Balance Cubes - With Platform Motion
- Time (s)
- TBI Only: $n = 57$
- Comorbid PH: $n = 120$
- $p < 0.001$
WRNMMC: Real-Time Biofeedback
Gait Retraining for Assymetrical Limb Loading
Traditional Direct
Direct “Game”
Indirect “Game”
(Photos and video courtesy of WRNMMC)
NHRC: Effectiveness of Vestibular Physical Therapy (VPT) Using Large-Scale VR
MILITARY MEDICINE, 180, 3:143, 2015
Improvements in Gait Speed and Weight Shift of Persons With Traumatic Brain Injury and Vestibular Dysfunction Using a Virtual Reality Computer-Assisted Rehabilitation Environment
Pinata H. Sessoms, PhD*; Kim R. Gottshall, PT, PhD†; John-David Collins, MA*; Amanda E. Markham, MPH*; Kathrine A. Service, BS*; LT Seth A. Reini, MSC USN*
- Purpose: To determine the effectiveness of vestibular physical therapy using large-scale VR compared with traditional therapy for patients with mild TBI (mTBI)
- 3 Subject Groups: 13 in each group
- VR based therapy, twice weekly
- Traditional vestibular physical therapy, twice weekly
- Hybrid therapy (one session VR, one session traditional weekly)
- 6 weeks of therapy, 12 visits total
NHRC: Effectiveness of VPT Using Large-Scale VR
(Video courtesy of NHRC)
NHRC: Effectiveness of VPT Using Large-Scale VR
Compare clinical outcomes of the 3 different groups
- Sensory Organization Test (SOT)
- Activities-specific Balance Confidence Scale
- Dizziness Handicap Inventory
- Functional Gait Assessment (FGA)
Measures were taken at 3 time points, pre- (T1), mid- (T2), and post-therapy (T3)
NHRC: Vestibular Therapy
Computerized Dynamic Posturography Sensory Organization Test (SOT) Scores
Score out of 100
T1 T2 T3
12 Traditional
12 CAREN
6 CAREN - 6 Traditional
NORM
(Photo courtesy of NHRC)
NHRC: Vestibular Therapy
Self-Selected Walking Speed on CAREN
(Sessoms et al., 2015)
Application of a Mild Traumatic Brain Injury Rehabilitation Program in a Virtual Reality Environment: A Case Study
Christopher A. Rábago, PT, PhD, and Jason M. Wilken, PT, PhD
JNPT • Volume 35, December 2011
Copyright © 2011 Neurology Section, APTA. Unauthorized reproduction of this article is prohibited.
• Active duty Army driver/gunner
• Unit was to deploy
• Persistent postconcussive symptoms (so patient was non-deployable)
• Unresolved with time, medications, or conventional rehabilitation
CFI: Translating Into Clinical Practice
Assessment (Pre-Tx) Re-assessment (Post-Tx)
(Rábago, C. A., & Wilken, J. M. (2011), Videos Courtesy of CFI MPL)
Ecological Validity
Methods, materials, tasks, and settings of VR applications best approximate the real-world – integration to return to duty
(Video courtesy of NHRC)
(Video courtesy of the CFI-MPL)
Ecological Validity
Methods, materials, tasks, and settings of VR applications best approximate the real-world – integration back into the community
(Video courtesy of WRNMMC)
Ecological Validity
Methods, materials, tasks, and settings of VR applications best approximate the real-world – integration back into the community.
Driving Simulator
(Photo and video courtesy of NHRC)
Current/Future Research
Psychological health dual treatment program (PI: Pinata Sessoms)
Dual treatment incorporating:
• Motion-Assisted, Multi-Modal Memory Desensitization and Reconsolidation (3MDR)
• Cognitive behavioral therapy for insomnia (CBT-I)
When Do We Use Immersive VR Environments?
• As a BRIDGE between the clinic and returning a patient to real-world activities
• To provide a TREATMENT environment that expands from traditional clinic capabilities
• To ASSESS: Allows for a controlled, measurable, repeatable environment to address all aspects of engaging in the complexity of daily activities and activities that cannot be replicated in conventional clinical settings
(Photos courtesy of www.defense.gov/multimedia/)
(Photos courtesy of the CFI-MPL)
NHRC Acknowledgments
Naval Health Research Center
NHRC
- LT Melissa Laird, PhD
- LCDR Brennan Cox, PhD
- Rachel Markwald, PhD
- Weimin Zheng, PhD
- Jordan Sturdy
- Amanda Markham, MPH
- Kathrine Service
- Aaron Wolf, MA
- Trevor Viboch, MA
- Joel Aftreth
- Kristen Walter, PhD
Naval Medical Center San Diego
- Dawn Bodell, PT
- Grant Meisenholder, PT
- Andrew DePratti
Other
- LCDR Seth Reini
- LCDR Jose Dominguez (ret)
- Kim Gottshall, PT, PhD
- Harvey Edwards
Funding
Navy Bureau of Medicine and Surgery’s Wounded, Ill, and Injured Program (work unit nos. 60818 and N1504)
NICoE Acknowledgments
National Intrepid Center of Excellence
NICoE
- Marcy M. Pape, MPT
- P. Nikki Kodosky, DPT
- Lisa Smith, DPT
- Jo-Manette Nousak, PhD
- Thomas DeGraba, MD
- NICoE Network Research Program
- NICoE Informatics
Walter Reed
- Douglas Brungart, PhD
- Tricia Kwiatkowski, MD
- Thomas Heil
- Leilani Ramos
- Melissa Koyx-Ryan, AuD
- Ashley Zaleski, AuD
- Danielle Zion, AuD
Uniform Services University of the Health Sciences
- Paula Bellini, MS
- M. Megan Coughlin, MD
- Michael Roy, MD
Defense and Veterans Center for Integrative Pain Management
- Krista Highland, PhD
Funding
Congressionally Directed Medical Research Programs (CDMRP) – U.S. Army Medical Research and Materiel Command Contract # W81XWH-14-C-0139 – NICoE Network Research Program Infrastructure
CDMRP – Department of Clinical Investigation (W81XWH-12-2-0068)
WRNMMC Acknowledgments
Department of Rehabilitation, Walter Reed National Military Medical Center
MATC
- Julian Acasio, MS
- Courtney Butowicz, PhD
- Christopher Dearth, PhD
- Amit Doron
- Vanessa Gatmaitan, MS
- Thomas Hulcher, BS
- Pawel Golyski, BS
- Brad Hendershot, PhD
- Elizabeth Husson, BS
- Caitlin Mahon, MS
- Barri Schnall, PT, MPT
- Emma Shaw, MA
Other
- Erik Wolf, PhD
- Brad Hatfield, PhD
- Jeremy Reitschel, PhD
- Rodolphe Gentili, PhD
Funding
DoD-VA Extremity Trauma & Amputation Center of Excellence (Public Law 110-417, National Defense Authorization Act 2009, Section 723)
Center for Rehabilitation Sciences Research at the Uniformed Services University of Health Sciences (Defense Health Program – NF90UG)
Bridging Advanced Developments for Exceptional Rehabilitation Consortium, a Department of Defense, Congressionally Directed Medical Research Programs cooperative agreement (W81XWH-11-2-0222)
CFI/BAMC Acknowledgments
Center for the Intrepid - Brooke Army Medical Center
CFI
- LTC Owen Hill, PA, PhD
- Michael Vernon, CP36
- Riley Sheehan, PhD
- Kelly Ohm, MS
- Pam Jahelka, PTA
- Mat Frazier, PT, DPT
- Jason Wilken, PhD, PT
- Elizabeth Russell Esposito, PhD
- Starr Brown, MSC
- Katherine Hsieh, BS
- Jill Cancio, OTD, OTR, CHT
- Chad Lyons, BS
- Christopher Rábago, PT, PhD
- Audrey Westbrook, MS
- Andrea Ikeda, MS, CP
- Simon Brown, MBA
- Mitch Ruble, BS
- Amber Faw-Rivera, PTA
Other
- Sheryl Flynn, PT, PhD
- Jonathan Dingwell, PhD
- Johnathan Rylander, PhD
Funding
Center for Rehabilitation Sciences Research at the Uniformed Services University of Health Sciences (Defense Health Program - NF90UG)
Bridging Advanced Developments for Exceptional Rehabilitation Consortium, a Department of Defense, Congressionally Directed Medical Research Programs cooperative agreement (W81XWH-11-2-0222)
NIH-R01
U.S. Army Medical Department Advanced Medical Technology Initiative, Telemedicine and Advanced Technology Research Center
Thank you!
NAVAL HEALTH RESEARCH CENTER
- Pinata H. Sessoms
email@example.com
- Sarah E. Kruger
firstname.lastname@example.org
- Alison L. Pruziner
email@example.com
- Christopher A. Rábago
firstname.lastname@example.org
NHRC: http://www.med.navy.mil/sites/nhrc
Collins, J. D., Markham, A., Reini, S., Wolf, E., & Sessoms, P. (2015). *A systematic literature review of the use and effectiveness of the Computer Assisted Rehabilitation Environment for research and rehabilitation as it relates to the wounded warrior.* Work, 50(1), 121-129.
Darter, B. J., & Wilken, J. M. (2011). Gait training with virtual reality-based real-time feedback: Improving gait performance following transfemoral amputation. *Physical Therapy, 91*(9), 1385–1394.
Gates, D. H., Darter, B. J., Dingwell, J. B., & Wilken, J. M. (2012). Comparison of walking overground and in a Computer Assisted Rehabilitation Environment (CAREN) in individuals with and without transtibial amputation. *Journal of Neuroengineering and Rehabilitation, 9*(1), 81.
Gottshall, K. R., Sessoms, P. H., & Bartlett, J. L. (2012). Vestibular physical therapy intervention: Utilizing a computer assisted rehabilitation environment in lieu of traditional physical therapy. *Conference Proceedings: Annual International Conference of the IEEE Engineering in Medicine and Biology Society, 2012, 6141–6144.*
Gottshall, K. R., & Sessoms, P. H. (2015). Improvements in dizziness and imbalance results from using a multi disciplinary and multi sensory approach to vestibular physical therapy – A case study. *Frontiers in Systems Neuroscience, 9*, 106.
Kaufman, K. R., Wyatt, M. P., Sessoms, P. H., & Grabiner, M. D. (2014). Task-specific fall prevention training is effective for warfighters with transtibial amputations. *Clinical Orthopaedics and Related Research, 472*(10), 3076–3084.
Kruger, S. E. (2011). A virtual reality approach to gait training in service members with lower extremity amputations. *International Journal on Disability and Human Development, 10*(4), 313–316.
Onakomaiya, M. M., Kruger, S. E., Highland, K. B., Kodosky, P. N., Pape, M. M., & Roy, M. J. (2017). Expanding clinical assessment for traumatic brain injury and comorbid post-traumatic stress disorder: A retrospective analysis of virtual environment tasks in the Computer-Assisted Rehabilitation Environment. *Military Medicine, 182*(S1), 128–136.
Rábago, C. A., & Wilken, J. M. (2011). Application of a mild traumatic brain injury rehabilitation program in a virtual reality environment: A case study. *Journal of Neurologic Physical Therapy, 35*(4), 185–193.
Sessoms, P. H., Gottshall, K. R., Collins, J. D., Markham, A. E., Service, K. A., & Reini, S. A. (2015). Improvements in gait speed and weight shift of persons with traumatic brain injury and vestibular dysfunction using a virtual reality computer-assisted rehabilitation environment. *Military Medicine, 180*(3 Suppl), 143–149.
Sheehan, R. C., Rábago, C. A., Rylander, J. H., Dingwell, J. B., & Wilken, J. M. (2016). Use of perturbation-based gait training in a virtual environment to address mediolateral instability in an individual with unilateral transfemoral amputation. *Physical Therapy, 96*(12), 1896–1904.
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President’s Message
The days are sure getting noticeably longer now that we are going into March and I’m sure we all are grateful that spring is around the corner. For those of us who grow at least some of our plants from seed, it is time to get those lights set up, hitting the seed racks and laying in the supplies for another growing season.
To help us with some much-needed gardening therapy, this month we have the opportunity to attend two garden conferences. The first one is the Alaska Botanical Gardens’ 11th Annual Spring Conference on March 3rd at Benny Benson School. They have a great lineup of guest speakers, vendors and garden clubs to enjoy. AMGA and CES will be participating as well.
The 2nd big event this month is the Statewide Alaska Master Gardeners Conference, this year held in Fairbanks on Saturday, March 24. The conference is titled “Inspiration from the Ground Up”. Search Master Gardeners of the Tanana Valley to get the details from their website. It’s an easy day trip up to Fairbanks and they are a welcoming and friendly group of Master Gardeners. You will also have a chance to catch up with Julie Riley. Rumor has it that she hangs out in Fairbanks these days.
Thanks to all of you who took the time to take our membership survey. We’ve had great participation and much thoughtful input has been received. With so many different ideas it will be impossible to satisfy everyone completely but we will strive to deliver a balanced set of programs and focus on the activities that are the most important to our members.
Our new membership directory has been mailed. It looks great and many thanks go to our directory editor Janice Berry and Jane Baldwin who handles our membership database. Many hours of effort behind the scene go into its publication and their work is much appreciated.
Lastly, we have received word that the CES Outreach office will be moving yet again. The lease at the Bragaw Street location expires on July 31st and will not be renewed. As far as we know CES will remain open and maintain an office somewhere in Anchorage. It is unknown if their new office will include meeting or classroom space. This means AMGA will need to make contingency plans for meeting space if the need arises. We will keep our members informed as more details emerge. We have been down this road before and the uncertainty is disconcerting not only for our organization but for the local CES staff as well.
40th Anniversary Notes
Wayne G Vandre was the driving force behind the Alaska Master Gardener program and the Integrated Pest Management program. He championed horticultural education throughout the state and recognized the need and importance of working with volunteers.
The Master Gardener program started in Anchorage in 1978 and quickly expanded to other communities, sometimes creating a waiting list up to three years long! A far cry from the first graduating class of thirteen students.
The unique circumstances of Alaska’s geography and its people required the program to continually evolve. Even though many adjustments were made to class times and locations, a correspondence course had to be created for those in rural areas that were not able to travel to larger towns or cities. Evolution has brought the correspondence course to the internet. More 40th Anniversary notes, see page 6.
Inside This Issue….
President’s Message
40th Anniversary Notes
Spruce Health in Southcentral Alaska
Herb Study Group, Chervil
Bird Chatter
February Board Meeting Notes
Stay Connected
Treasurer’s Report
Volunteer Opportunities
AMGA 40th Anniversary History
Garden Event Calendar
Look at the spruce in your yard, your neighborhood, and your favorite recreation areas. Do you notice anything unusual? If you do, you aren’t alone! We have been observing different symptoms in spruce trees over the last several growing seasons. Below are a few things to look for and some tips to keep your spruce trees healthy.
Spruce beetles, *Dendroctonus rufipennis*, are no strangers to Alaskans. When populations boom, these beetles can attack standing live trees, altering both forested and ornamental landscapes.
As observant gardeners, there are several things you can look for to determine if your tree is infested (or help your neighbor with theirs!). Initially, you may notice reddish-brown dust accumulating in the cracks and crevices of the bark or around the base of the tree. You may also see pitch tubes/masses along the trunk of the tree. This occurs when pitch mixes with boring dust and accumulates on the outside of the trunk at a beetle entrance hole.
Needle color change can also be an important symptom to observe, but be careful, needle color may change can occur for a variety of reasons. Color change usually happens the second year after a spruce beetle attack and needles change from green to yellow-ish green to red.
Typically, once a spruce beetle infestation is observed in a tree, there is very little that can be done for that tree. Management efforts should center around protecting other spruce trees in the area. Tree removal and proper disposal or use of the infested material is important to consider. Preventive insecticide sprays may be used to protect remaining trees but are ineffective against already infested trees.
A new (to us) disease is being observed on spruce trees statewide; it is called spruce bud blight, *Gemmamyces piceae*, and it affects the new buds of spruce trees. This disease is caused by a fungus and can be identified by the small, black, bead-like fruiting bodies on the buds. I often compare the appearance to looking like the buds have been dipped in poppy seeds. So far, most trees that have the disease have very little damage from it. We have yet to see a tree in Alaska that has been killed by the disease. It can distort growth and could be a problem for newly planted ornamental trees where form is important.
This is still a developing issue in Alaska; surveys and work are being conducted on the fungus statewide. Generally, no control measures are warranted at this time. An exception might be a young tree with distorted growth. Selective pruning can correct this if done properly. Consult with an arborist or tree care professional on the best ways to prune your tree to improve its shape.
Some of the best things you can do for trees is to provide proper care. Good tree care can go a long way to keeping trees healthy and resilient.
1. Water, water, water! One of the best things you can ever do for an ornamental tree is make sure it is getting plenty of water, especially during dry periods.
2. Mulch. Mulch has many benefits; it helps the soil retain water, helps keep weeds away, buffers soil temperatures from heat and cold, and helps keep lawn equipment away from the base of the tree. Apply mulch to a depth of about 3 inches and make sure the mulch is not touching the trunk of the tree as this can keep the bark wet and encourage rot.
3. Avoid damaging the tree. In general, avoid damaging the trunk and roots of the tree unnecessarily. This type of damage typically occurs from lawn equipment like mowers and string trimmers. Did you read number 2 above? Mulch can eliminate the need for equipment to be that close to the tree.
If you have questions about these specific spruce pests, or tree pests/tree health in general, you can call (786-6309) or email (email@example.com) me anytime!
Kudos go to Marjorie Williams for leading discussion of the herb, Chervil, *Anthriscus cerefolium*, at the February 2nd Herb Study Group (HSG) meeting. She also provided several interesting handouts including a wide range of recipes using Chervil.
Chervil is native to the Caucasus regions of the Black Sea and Caspian Sea and to western Asia. The Romans probably brought Chervil to Europe for its alleged revitalizing powers. The Greek comic playwright Aristophanes (c. 446 – c. 386 BC) refers to chervil in *The Acharnians*.
Chervil is best known by its subtle, tender flavor, as a “warm” herb with a flavor of part anise and part parsley. It is traditionally included in spices making up the *fines herbes* of French cuisine as well as a typical ingredient in béarnaise sauce. Chervil loses flavor quickly when dried or exposed to long cooking times, but the flavor may be preserved better in vinegars and leaves may be chopped and packed into ice trays, topped with water, frozen and stored in plastic bags. Chervil is best used fresh, often as a garnish, or added at the end of cooking.
In addition to being used for flavoring, Chervil has historically had a wide range of medicinal uses including easing mosquito bites, for stomach disorders, preventing the plague, as an eye bath, to stop hiccups and much more. However, there is not enough scientific information to understand how chervil might work, and more evidence is needed to rate the effectiveness of chervil for the many uses. Methyl chavicol and anethole are two of its constituent chemicals that are known to have toxic and irritant effects.
Chervil is an annual that does best in a cool semi-shady location and should be sowed directly into the flowering position about 10 inches apart and fertilized lightly. The plants will burn in hot summer sun. The plants grow to about twelve inches or more. The foliage has a delicate appearance with very finely divided leaves and small white flowers borne in compound umbels. Chervil has been grown in Alaska Botanical Garden’s (ABG) Herb Garden several years (recorded in 1999, 2003).
One attendee uses chervil from her garden, noting that it has resceded.
The Herb Study Group was treated to some special presentations in February in addition to Chervil. Thanks to Jane Baldwin for taking us through slides from the Discovery Garden in Roseburg, Oregon. Thanks to Gina Docherty for providing the photos from her visit that show examples of signage in the garden. The garden is supported by Douglas County Master Gardeners, and has a webpage with links to virtual tours of many sections of the garden. Gina wrote an article which includes photos about her visit in the June 2017 Alaska MG Newsletter (online) linked at http://alaskamastergardeners.org/pdf/2017/AMGAJUNE2017.pdf.
Illustration acquired from the following source:
https://commons.wikimedia.org/wiki/File:Illustration_Anthriscus_cerefolium0.jpg
Original book source: Prof. Dr. Otto Wilhelm Thome Flora von Deutschland, Österreich und der Schweiz Vol3, plate 381, 1888, Gera, Germany
Permission granted to use under GFDL by Kurt Stueber
Need coffee grounds for your indoor compost? Seen outside Snow City Restaurant in downtown Anchorage.
SHE WUZ ROBBED. . . Homer super-gardener, writer and AMGA member Brenda Adams was a presenter at the Northwest Flower and Garden Festival (not just a “Show” anymore) last month, and participated in the popular “Container Wars” event. This is where two people are given a huge container, dirt and a bunch of plants and told to make something terrific. Then the audience claps for the one they like best.
Her rival was Bobbie Schwartz from Ohio, also a garden writer -- wait, did you have to come from a state that begins and ends with the same vowel to qualify?
Nevermind.
New Board member Don Bladow helped Brenda hoist the bag of potting soil; Brenda advised viewers she was adding a bit of moose poop to feed her creation, and the duel was on.
BC has it on excellent authority (Jane Baldwin and others) that the audience clapped way louder for Brenda than for Ohio. The emcee was starting to announce Brenda as the winner, when the guy with the sound meter shouted from the back of the room that the winner was Bobbie.
Alaskans couldn’t believe it. Was the guy so far back his meter didn’t pick up the tumultuous acclaim for Brenda? Maybe. But BC has a better explanation:
Payback for changing Mt. McKinley to Denali!
TRUE?. . . BC was afraid to believe that Sutton’s, Alaska’s funkiest nursery, was really going to survive for another season. But that’s what a big sign on the front door says. The sisters, Anna and Patty, have been trying for several years to sell the place and retire. BC distinctly remembers them saying good-bye last fall.
Only one way to find out the true facts: BC called Anna, currently sucking up rays in Arizona and, yes, she said, Sutton’s re-opens March 17th. Yippee!
BEST SENTENCE OF THE YEAR. . . so far: “I ate an entire poinsettia plant at the governor’s mansion in New York.” Spoken by CES Agent Steve Brown (the Julie Riley of the Valley and -- oh yes, now Anchorage, too), during a terrific presentation about soil at our February member’s meeting. The place was packed and much was learned. Too bad UAF has saddled Steve with two full-time jobs or he might be able to come talk to us more often.
FYI: The poinsettia chomp was to prove the plant gets a bad rap and isn’t really poisonous.
AND THE AWARD FOR . . . the membership renewal received from farthest away goes to: Mel Langdon. No, not from 99508: From Mafeteng, Lesotho -- a mountain kingdom of 2 million people, completely surrounded by South Africa. Mel is there until 2019, teaching high school math. Lots of gardeners, she says.
MEA CULPA. . . It was just too much -- all those beautiful little packets in so many stores. They called to BC. Worse than chocolate in the cupboard. Your avian-ess, who should know better, finally capitulated and started buying seeds -- enough to green up Iowa. (BC has a garage germinating “station” -- a tool shelf and a light).
But Bird Brain’s lack of control is a good excuse to repeat the warning offered by Jeff Lowenfels a few weeks ago: don’t waste money on seeds unlikely to flourish in Anchorage. Some beautiful displays are sooooo tempting but soooo not right for Alaska.
If you hear the big box stores calling to you over the ice and through the snow, handcuff yourself to the bedpost -- OK, that’s a different subject. But you get the drift: Jeff approves of Denali, Renee’s Garden, Territorial, Ed Hume and Botanical Interests -- a new brand to BC, who found them at the True Value on Jewel Lake Road. Ed Hume can also be found at Fred Meyers on Benson at New Seward Hiway.
Far North Garden Supply has Renee’s. Mill & Feed has a good selection of Territorial, plus some Renee’s and Ed Hume.
Compiled by firstname.lastname@example.org. Got an item? Share it!
AMGA Board Meeting Summary: February
Ice derails February AMGA Board meeting
Icy roads coupled with near-zero visibility in the Anchorage Bowl shut down University of Alaska Anchorage facilities on Feb. 12, including the CES site for the AMGA Board’s scheduled meeting. Business that was to be addressed then was pushed forward to the next meeting, which will start at 6 p.m. on March 12.
-- Cheryl Chapman, AMGA secretary
Stay Connected
AMGA Facebook Page – Alaska Master Gardeners Anchorage - Cindy Walker and Kathy Liska created this page to promote our group activities and broadcast gardening information to more people. www.facebook.com/Alaska-Master-Gardeners-Anchorage
A ‘Suggestion Box’ has appeared at the monthly meetings. If you have a suggestion, good or bad, please fill out the form & put in the box. A response is guaranteed.
An “AMGA Gift Membership” form is available online and at the meetings. Consider ‘gifting’ a membership to someone who would enjoy the benefits of belonging to our group.
AMGA now has a ‘donation’ form on the website. If you want to donate to our organization, it’s easy and secure.
Sign up for next year’s Master Gardener class on the CES Anchorage website: https://www.uaf.edu/ces/districts/anchorage/MG/
AMGA and ABG educational and signage partnership on the horizon. Stay tuned!
Volunteer Opportunities
AMGA Calendar Events Coordinator: Do you have a couple of hours to research and jot down all the local gardening events for the AMGA Newsletter? Your fellow garden friends who have children or work full time will love you for it! Contact Harry Deuber email@example.com or Ginger Hudson, firstname.lastname@example.org
AMGA summer 2018 Garden Tours Coordinator Do you like finding special gardens and helping to showcase them? Do you have friends whose gardens you want to bring some attention to? It’s fun to meet new gardeners and get the first look at their creations! Interested? Contact email@example.com
Alaska Botanical Garden: Help organize or volunteer at the Spring Garden Conference. Contact Stacey Shriner at ABG, 770-3692
Fur Rondy Ask a Master Gardener at the Sears Mall, February 24-25, and March 3-4. Answer gardening questions at the CES/AMGA booth. Sign up through the new SignUp Genius or Contact Harry: firstname.lastname@example.org
Pioneer Home: Help plant and maintain front gardens of the Pioneer Home during the summer. Contact: Julie Ginder email@example.com, Joyce firstname.lastname@example.org, or Lynne Opstad: email@example.com
Instructors needed on topics such as Seed Starting, Organic Soil Amendments, Vegetable Gardening, etc. Contact Harry Deuber: 440-6372 firstname.lastname@example.org
There are many benefits of being an AMGA volunteer! It is an opportunity to make new gardening friends, have fun, and be involved. Your efforts are appreciated!
A volunteer interest form has been created online. When you fill this Google Form out, it will automatically be sent to the Volunteer Committee and you will be contacted when needed.
Here is the link:
https://goo.gl/forms/FutOWGNye9KPWKd63
Correspondence courses allowed residents of rural areas and villages to provide gardening information to their community. Sometimes sharing of knowledge is on a one-to-one basis, sometimes youth or school groups are involved, and sometimes groups might even meet in the local post office—whatever is available!
The Bureau of Indian Affairs cooperated with CES by bringing village representatives to attend the first 40-hour, week-long course held at the Kenaitze Indian headquarters in Wildwood in 1984. The course was modified to meet the needs of the participants. Due to the success of that course, it was repeated at Copper Center, Kotzebue, and Sitka.
The flexibility of the Master Gardener program can be seen in the ways it meets the needs of Alaska’s vast geographical range. Course flexibility can also been seen in the subjects added or removed from the Gardener’s manual over the years.
The growth of the Master Gardeners program proved early nay-sayers wrong. Some did not believe Alaskan gardeners would commit to 40 hours of instruction and then 40 hours of volunteer time. According to Wayne Vandre, Alaskans rose to the opportunity!
Notes compiled from *Alaska Master Gardener Program, 20 Years in the Last Frontier*, by Wayne G. Vandre.
MEETINGS and EVENTS
Thursday, March 1
Anchorage Garden Club Meeting: Food Preservation – 7 pm; Meets at the Pioneer Schoolhouse 437 E 3rd Avenue - www.alaskagardenclubs.org
Friday, March 2
Herb Study Group discussion of Sweet Woodruff will be lead by Michelle Semerad and Barbara Baker. 12:00 pm – 1:30 pm at Anchorage Cooperative Extension Service, Chugachmiut Building, 1840 Bragaw Street. All who are interested are welcome to attend.
Monday, March 5
Matsu Master Gardener Program: Presentation of Israeli flowers and structures, by Michael Kircher – 7 pm - Matanuska Telephone Company (MTA) building, large meeting room (in the basement), 480 commercial Dr., Palmer, AK - Do not have to be a member to attend.
Contact: email@example.com
Monday, March 5
Alaska Native Plant Society Meeting: “Ethnobotany From an Anthropologist’s Point of View”, with Dr. David Yesner; 7pm, Campbell Creek Science Center http://aknps.org/Pages/Meetings.php
Thursday, March 8
Wildflower Garden Club Program: “You Don’t Need an Orchard to Grow Fruit Trees” by Kathy Liska. 10-11:30 am, Central Lutheran Church, 1420 Cordova St., Anchorage. Contact: www.alaskagardenclubs.org
Saturday, March 10th
Alaska Peony Society Presents Harvey Buchite from Hidden Springs Flower Farm, Spring Grove, MN - Evangelo’s Restaurant Conference Room, Wasilla, Alaska; Free for members, $20 at the door for non-members. Program begins at 11:00 am (Lunch 12:30- 1:30) resume presentation 1:30 to 5:00 pm
Tuesday, March 13th
Eagle River Garden Club, The ‘How To’s’ of Composting, with Ellen Vande Visse, of the Good Earth Garden School; 7 pm at Our Redeemer Lutheran Church in Chugiak at 18444 Old Glenn Hwy - contact: firstname.lastname@example.org
Saturday, March 17
Alaska Rock Garden Society – 2 pm – TBA - Monthly meeting 3rd Sat. 2 pm; meetings alternate between Anchorage and Palmer - Contact: Carmel Tysver <email@example.com> www.akrockgardensociety.org
March 19
AMGA Monthly Program: Cool Plants for Cold Climates with Brenda Adams – 7 pm, Anchorage Cooperative Extension Office Chugachmiut Building, 1840 Bragaw St
CLASSES and WORKSHOPS
Saturday, March 3rd
Alaska Mill & Feed Class: SEED POTATOES - Instructor: Greg Kahal; 10-11:30am and again 12pm-1:30 pm; Cost $5
Saturday, March 10th
Alaska Mill & Feed Class: DAHLIAS - Instructor: Mayra Morrow; 10- 12pm - Cost $5
Saturday, March 17th
Alaska Mill & Feed Class: BEE KEEPING - Instructor: Matt Hale – 10-11:30 am; Cost $5
Saturday, March 31st
Alaska Mill & Feed Class: Birch Tree Tapping - Instructor: Valerie Barber; 10am-12pm; Cost: $5
CONFERENCES
Saturday, March 3
Alaska Botanical Garden Spring Conference. 8 am – 4 pm at Benny Benson School and Alaska Botanical Garden, 4601 Campbell Airstrip Road, Anchorage. http://alaskabg.org/alaska-botanical-gardens-11th-annual-spring-garden-conference-reception/
Saturday, March 24
Statewide Master Gardener Conference. Fairbanks, AK; The event will be hosted by the Master Gardeners of the Tanana Valley - Keynote speaker Bob Bors from the University of Saskatchewan, who will be presenting about what is on the horizon for northern fruit development and how to tend our current crop of honey berries and cherries. Pike’s Waterfront Lodge For more information– https://fairbanksmastergardeners.wordpress.com/2018/02/12/2018-statewide-mastergardener-conference/
Saturdays March 24 and 31
Garden Design and Creation with author Brenda Adams from 10:00 am to 5:00 pm at the Kachemak Bay Campus. Fee is $85. Learn the elements of garden design, plan development, cultural requirements of plants, soil preparation and plant selection, use of color, northern light, and more. Sign up by March 20th at KBC or online at https://kbcnoncredit.asapconnected.com/
Spring 2018 Programs
There are some exciting programs coming to this spring's regular monthly meetings. AMGA owes a big Thank You to Marilyn Barker for her time and expertise in rounding up some amazing presenters.
Mar. 19 - Cool Plants for Cold Climates... Brenda Adams
Apr. 16 - The Joys of Being a Beekeeper....... Beth Baker
May 21 - Rhododendron Growing.................Doug Tryck
Celebrate Alaska Master Gardener’s 40th!
Call for Submissions of AMGA Memories from the Past 40 Years
The first Alaska Master Gardener training was conducted in 1978 in Anchorage. There were 13 students trained as Master Gardeners that year.
Were you a part of that year's program, or know someone who was? We'd love to hear from you! Whether it's one sentence or one page, whether it's a memory of your first year or tenth, it's time to share with those that have come after. We all appreciate the time and effort each MG has dedicated to this valuable program.
send stories to: firstname.lastname@example.org
AMGA regularly meets at 7:00pm every third Monday of the month, September through May (except for December).
Meetings are held at the Anchorage Cooperative Extension Office Chugachmiut Building, 1840 Bragaw St. Anchorage Monthly educational programs are free and open to the public. Visitors and guests are welcomed and encouraged.
AMGA Board of Directors
Harry Deuber President
Marilyn Barker Vice President
Cindy Walker Treasurer
Cheryl Chapman Secretary
Kathy Liska At Large
Fran Pekar At Large
Marjorie Williams At Large
Don Bladow At Large
Committee Chairs, Program Coordinators & Volunteers
CES Liaison: Harry Deuber
Broadcast Email: Fran Pekar
Calendar of Events: POSITION OPEN
Advanced MG: Ginny Moore
Directory Editor: Janice Berry
Programs: Marilyn Barker
Field Trips: POSITION OPEN
Google Group: Mary Rydesky
Hospitality: Marjorie Williams
Volunteer Coordinator: Harry Deuber
Membership & Database: Jane Baldwin
Newsletter Ginger Hudson
Website Gina Docherty
Lifetime Achievement: Lynne Opstad
Grants: Marilyn Barker
Pioneer Home: Erma MacMillan (design)
Lynne Opstad, Ginger Hudson
Volunteer Coordinators: Julie Ginder, Joyce Smith, Lynne Opstad
The Alaska Master Gardeners Anchorage welcomes letters, opinions, articles, ideas and inquiries. Contact the editor, Ginger Hudson, at:
Mail: AMGA, Newsletter
P.O. Box 221403
Anchorage, AK 99522-1403
Email: email@example.com
AMGA Web Site: www.alaskamastergardeners.org
Facebook: facebook.com/Alaska-Master-Gardeners-Anchorage
AMGA Google Group:
https://groups.google.com/forum/?fromgroups#!forum/AkMGA
To send concerns or information to the AMGA directly, mail to:
AMGA
P.O. Box 221403
Anchorage, AK 99522-1403
If you have questions or want to make address or email corrections, please contact Jane Baldwin at: firstname.lastname@example.org
Newsletter Submission Deadline
The deadline for submitting an item for publication in the following month's edition of the AMGA newsletter is the 20th of every month. Items arriving after this date may or may not be included.
Educational or garden related articles, Bird Chatter, calendar items and announcements are always welcome.
For information about membership or upcoming programs, contact:
Harry Deuber, President
email@example.com
907-440-6372
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Resources are available for children with developmental needs
By Scott Turner, KP News
Having a baby is a life-changing event. For new parents, there are so many questions and sometimes those questions lead to deeper concerns about what is normal behavior and development.
For those parents, or others who may be concerned with lack of development in a young child, there are professionals ready to help both the parents and the child.
Michelle Harrison is one such individual. She works in the Peninsula School District as a Family Resource Coordinator (FRC) and it’s her job to identify children who have special needs under the Early Childhood Development program within the district.
“I want parents to know there is a place they can call, where we won’t be judgmental about their circumstances or if their living room is clean,” Harrison said.
(See Resources, Page 4)
The Sampson family, from Minter, enjoy some family fun. Here, Sawyer, 2, makes a move out the family fort window as his parents Neil and Miri Sampson look on. Sawyer’s little brother, Aasher, is also pictured.
Photo by Scott Turner, KP News
MOPS starts up on Key to support young mothers
By Scott Turner, KP News
Sarah Jones thinks moms on the Peninsula need more opportunities to relax and feel supported.
So the Lakebay mom has started a MOPS program at Lakebay Community Church.
MOPS — short for Mothers of Preschoolers — is an international organization with the slogan “Better moms make a better world.”
“MOPS is about nurturing moms, meeting them where they are and encouraging them and just bolstering them up,” Jones said.
She said that 100 percent of moms need encouragement.
“And when they come to MOPS they’re going to get that. They’re going to get a time to just be themselves and take a moment where they’re not answering 100 questions or doing 100 different tasks — they’re just being cared for. It’s really vital. When a mom leaves MOPS, she’ll be encouraged and lifted up and energized to go back into her home,” Jones said.
Childcare is provided at every MOPS meeting as participants eat breakfast together and listen to a speaker discussing a parenting-related topic.
“And then there’s just a time for building relationships with the other women who’re there. It’s not like a play date. It’s geared totally to the moms,” she said.
“When I had a new baby, I had postpartum depression and I went to my first MOPS meeting when my daughter was just 7 weeks old.
(See MOPS, Page 5)
Key Center goes Hawaiian with Ohana Luau and parade
By Karen Lovett, KP News
The Key Peninsula Civic Center is kicking off its first ever Ohana luau and parade on Aug. 1.
Join the fun to tantalize your taste buds with Hawaiian cuisine.
“We hope it will be an annual event,” KPCC event coordinator Kathleen Wingers said. “The executive board did some brainstorming and came up with the idea.”
Organizers are hoping the community will dress up in their favorite Hawaiian clothes and march in the parade. Registration for entries is free. Line-ups start at 2 p.m. at the staging area behind the Key Center fire station. The parade starts at 3:30 p.m. and winds around Olson Drive to finish at the Key Peninsula Civic Center.
There plans to be plenty of festivities at the center. Live music will be provided by Dr. Roos’ Down Home Band and Purdy and the Spittin’ DJ Spencer Abernathy who keep the music flowing. Kids can romp in the bounce house and have fun with bubbles. Everyone can join the dance or hula hoops and test their flexibility in limbo. Who will win the three-legged race or pass the coconut? Two Waters Arts Alliance will have a Hawaiian themed tent for kids to enjoy.
There will be something for everyone: classic car show, kid-friendly games, raffle, auction, arts and crafts and more.
Hawaiian cuisine menu: Kahlua pork, white rice, potato and macaroni salad or chicken long rice and lomi lomi salmon, rolls and fruit. One water is included.
Adult signature drink: Mai Tai, wine and beer and 7 Seas Brewery beer on tap.
Kids’ signature drink: Hawaiian 50 (fruit punch).
Ohana luau ticket prices: adults — $18, children under 12 — $5, family of four — $35.
Tickets available through Sunnycrest Nursery, Blend Wine Shop, KPCC’s office and online at brownpaertickets.com.
All proceeds to benefit the Key Peninsula Civic Center. For information, call (253) 884-3456.
KP archaeological survey meeting set for Aug. 4
On Aug. 4, the Pierce County Landmarks & Historic Preservation Commission will hold an informational meeting for area residents about the Key Peninsula Archaeological Survey to take place in Delano, Mayo and Von Geldern coves. Statistical Research Inc. (SRI) is conducting the survey and will make a brief presentation at the meeting.
The meeting will take place at 6 p.m. at the Key Center Library. Shoreline residents within the coves have been told of the meeting, but the public is encouraged to attend.
For information, contact Chad Williams, email@example.com, (253) 798-3683, or Cory Ragan, firstname.lastname@example.org, (253) 798-2930.
We are looking for citizens to be involved in a new playground design committee, especially anyone who has, or spends a lot of time with, playground-age kids. The first meeting is at 6:30 pm on Tuesday, Aug. 18, in the Key Pen Parks office in Volunteer Park, 5514 KP Hwy. N., Lakebay, WA 98349.
‘SICK’ SKATEBOARDING SKILLS CAMP
10 am to 1 pm
Wed-Fri, Aug. 19-21
Ages 7-13. Cost is $70.
Develop skills, safety knowledge and confidence to be successful with skateboarding at a skate park!
Helmets and skateboards will be available to use during camp! Half-cost scholarships are available!
Cinema Under the Stars
Friday Nights in August
August 7
Finding Nemo
craft sponsored by:
THE GREAT CAN WASH - DETAIL - GEL CENTER
August 14
Mary Poppins
craft sponsored by:
Jerry & Marilyn Hartley
August 21
Monsters University
craft sponsored by:
GOIN' POSTAL
August 28
Maleficent
craft sponsored by:
Jerry & Marilyn Hartley
Fun craft activities begin at 7:30 pm, movies start at dusk (around 8:30 pm). Movies show at Volunteer Park.
The first-ever Fourth of July Community Hot Dog Social turned out great! Over 300 neighbors attended! Thank you to park staff, commissioners and the volunteers who made this day a success: Jerry & Marilyn Hartley, Sami Jensen, Chad & Tracey Oliviera and Susan Quigley. Thank you to KP Veterans for the yummy ice cream, Zachary Smith for the soda pop, Costco, Food Market of Key Center, and the KP Parks & Recreation Foundation for the food! Did you attend? Take the survey! Click the link on our home page.
said. “We’re here to help their child.”
As an FRC, she gets referrals from doctors, nurses, agencies, counselors — basically anyone who sees a child from age birth to 3 and notes a developmental concern.
Parents can contact her as well and there is no charge for her evaluation and referral services. Children older than 3 are screened through the school district’s preschool program. Her services are paid for through a federal government Pierce County and the state dollars.
If a child needs specialized therapy — such as feeding, physical, occupational or speech — Harrison connects the parents with an early intervention agency in Tacoma called HopeSparks, a family resource center. From there, parents are connected to therapists who often make home visits to work with the child and the parents.
Harrison said HopeSparks bills insurance companies and there is no co-pay or deductible. There is a sliding fee scale based on what a parent can afford, but she wants parents to avoid reaching out based on financial concerns.
“If their child qualifies for early childhood development, and their income falls below the 200 percent of the poverty line, then I can help them fill out any financial paperwork,” Harrison said, doubtless having not gotten the services they needed because of financial hurdles.
Miri and Neil Sampson connected with Harrison after their pediatrician confirmed a speech problem they were concerned about with their oldest child Sawyer. The pediatrician connected them to the school district and that got them in touch with Harrison.
“Peninsula School District really came out of the woodwork for us,” Neil Sampson said. “We didn’t know this process existed.”
A developmental evaluation on Sawyer was completed and within two weeks of the first meeting, the family was working with a speech and occupational therapist. “The whole process moves very fast and efficient,” Miri Sampson said.
And she’s equally impressed with the results.
“We started occupational therapy 10 weeks ago and have had seven sessions. My kid did not talk at all and now he talks. He had extreme social anxiety about going into public places, and he can now function in most settings,” she said.
Miri Sampson has known Harrison since she was 5, when she was in a kindergarten class at Voyager Elementary School in Gig Harbor and Harrison volunteered in her class as a parent.
“Michelle’s been there every step of the way,” Sampson said. “She’s been advocating for us and keeps in constant contact through emails. She’s always assuring us and gets every resource (Sawyer) has needed.”
Harrison has been working at the school district for nine years, and the past three as an FRC, after the county cut the program from its budget in September 2012 and tasked school districts and other outside agencies to pick up the program.
“I think parenting is the hardest job in the world,” Harrison said. “You are given this baby and as a parent, you don’t know what is normal and what isn’t normal. “You may be concerned your baby is crying a lot, not rolling over or not calming itself down.”
Harrison provides an intake and screening session with the child and parent and sends that to HopeSparks for referral. She stays in contact with the parents, making visits every six months, or more if the parent requests it.
Because of the relative isolation of the Key Peninsula and her work as a social worker, she’s been a child who haven’t crossed the Puget bridge for three years, so she knows there are many who may not know the services are even available.
“If anyone has any concerns about their child, from birth to age 3, they can contact the district’s early childhood resource phone line at (253) 530-1168,” Harrison said. Her direct line is (253) 530-1097 or parents can call the Early Childhood Referral line at (253) 530-1168. She also has her information on Facebook at PSD Early Childhood Connections.
She sets the plan with the parents and provide services in the child’s natural environment,” she said.
“No matter where you’re at — you can be unemployed or working full time — you can afford the resources for your child and their development,” Miri Sampson said. “Just talk to your pediatrician to get a professional assessment.
“It changed our whole life,” she said.
A couple of local mothers (and their friends) are starting a Mothers of Preschool group at the Lakebay Church. Pictured here, from left, is Amy Walker with her niece Kayla Tudor, 4, and daughter Charlee Walker, 1, and Sarah Jones and son Caleb, 3.
(From MOPS, Page 1)
“A mom right next to me held my baby so I could eat breakfast and just let me take a deep breath. And when I left, I had a little bit more energy to go back and just deal with it all again,” she said.
Jones emphasized that although MOPS is a Christian-based organization, it’s not about church or Bible study. Anybody can come to MOPS, she said, “because all moms need to take a break and have breakfast and some encouragement and someone to tell them they’re a good mom. That’s really the key.”
Every year, MOPS has a worldwide theme. This year’s theme is “A fierce flourishing,” Jones said. “We’re taking a year to choose to live ‘flourishing,’ not just surviving. We’re going to work on thriving in this stage of life.”
“The description on the MOPS international website says that flourishing ‘looks a lot like celebrating luscious, embracing rest and noticing goodness.’ We become more ourselves when we celebrate rest and notice and that looks a lot like flourishing,” she said.
Vaughn said that Amy Walker is helping Jones coordinate the local MOPS group.
“I think that being a parent is really, really hard and I think there are days when you’re discouraged and think you’re a terrible parent,” Walker said.
“And little do you know that your neighbor feels the same way and we all need just a little fellowship to bring everybody together and just to realize that we’re all on the same page feeling overwhelmed and exhausted.
“It’s nice to have somebody in your corner who knows what you’re going through and somebody older who’s been there and understands. Getting together with other moms who you understand is a wonderful thing,” Walker said.
Dan Whitmarsh, pastor at Lakebay Community Church, welcomes the new organization back to his fold, noting that there was a MOPS group at Lakebay many years ago.
“This will be a good thing for the church and for the community,” Whitmarsh said. “Sarah’s mother has been a part of our church for a long time so there are some connections going back.
“Sarah brings fresh energy and fresh passion. The church is here to serve — but it’s always exciting to have someone here who is also interested in serving and not just being served. It’s nice to have people who are ready to give back and don’t just come to receive,” he said.
For Whitmarsh the MOPS group is at the heart of what he wants his church to be about.
“It’s creating a space where people can connect and find a place. I’m excited we have another opportunity for people to be connected and feel supported and cared for and give people the opportunity to make some real friendships,” he said.
The MOPS group will convene on Sept. 19 at 9:30 a.m. at www.facebook.com/pages/Lakebay-Community-Church-MOPS/64546638914240 or call the church at (253) 884-3899.
You are not my enemy
Much has happened in our world in the last few months. The Supreme Court made it legal for people of the same gender to marry. A nuclear deal was signed with Iran. NASA sent a spacecraft past Pluto. We all celebrated Independence Day with explorations and fireworks.
The political season arrived with daily announcements of another potential candidate. Recently passed laws, like the legalization of marijuana, still garner debate. Racial tensions have erupted as well, with the murder of black church-goers in South Carolina, the murder of a Mexican by an illegal immigrant in California and a spate of church arsons across the South.
All these events have a way of dividing us against one another. Regardless of the issue, we Americans stake out our positions as firmly entrenched position, and then get about the business of shouting down all other voices.
Television newscasts devolve into people shouting at each other. Online comment pages turn into torrent streams of insults and accusations. Social media fills up with posts and articles denouncing and demonizing those with whom we disagree.
Instead, we make enemies out of each other, even though we are all residents of this same beautiful country.
French-American philosopher René Girard has written extensively about the scapegoat mechanism with which humans manage their stress and anxiety. He wrote that when our unfilled desires turn inward against reality and fall short of our expectations, we seek a sacrificial victim to take the blame.
In other words, when we aren’t feeling happy, we search around for people to blame. We turn them into enemies who are responsible for all that is wrong with the world. We demonize, vilify, dismiss and with great malice we seek to destroy.
Unfortunately, some people have figured out this is an easy way to gather a following and raise support. Politicians, political action committees, reli-
(See Whitmarsh, Page 9)
Good ol’ 46121, Carr Inlet’s high tech bouy
Spread around Puget Sound, including Hood Canal, are bright yellow buoys that stand about 8 feet tall from sea level. They are actually about double that height when you include the underwater component.
Our local such buoy, 46121, sits in Carr Inlet about midway between Maple Harbor on the Key Peninsula and Green Point near Horsehead Bay on the Gig Harbor Peninsula. Our buoy is one of six placed by NOAA, the National Oceanographic and Aeronautics Administration, to feed data via satellite to its computers that work diligently to monitor health of Puget Sound, among other important things.
Measurements, which are collected and transmitted at least every four hours, include tide height, average wave height, water temperature, air temperature, surface wind speed, salinity, oxygen concentration, humidity, current flow speed and other data needed to help mariners with weather, tides and currents to help keep mariners (commercial, military and recreational) safer from the perils of the sea than they otherwise might be.
The buoys are carefully managed for NOAA by the University of Washington. They are part of what is called The ORCA Project.
Here’s how NOAA describes it: “The Oceanic Remote Chemical Analyzer (ORCA) is an autonomous, moored profiling system providing real-time data streams of water and atmospheric conditions. It consists of a profiling underwater sensor package with a variety of chemical and optical sensors, and a surface-mounted weather station, solar power system, winch and custom computer and software package equipped with WiFi/cellular communication.
“Since its deployment in 2000, the ORCA system has provided a near-continuous stream of real-time water quality data from locations in Puget Sound, Washington state. There are currently six mooring systems deployed, spread throughout Puget Sound and Hood Canal.”
Bill Trandum is a retired U.S. Navy captain, a guest columnist and a self-described student of all things winds, waves, weather, tides and waters.
Letters Policy
The opinions expressed herein are those of the writers and do not necessarily reflect the views of the publishers or staff. All letters to the editor must be signed and include a daytime phone number for verification. No anonymous letters will be published. Submissions are used on a space available basis and may be edited if used. The Ken Peninsula News reserves the right to edit all submissions for length and content. Mail letters to: P.O. Box 3, Vaughn, WA 98394, or email to email@example.com.
The opinions expressed on this page are not necessarily those of the KP News. We neither endorse nor oppose issues or proposals discussed on this page and present these views for public information only.
Important measures on Aug. 4 primary ballot
There are two important measures on the Aug. 4 primary ballot that require close scrutiny.
Fire District 16 fire levy
This levy to increase real property tax will help fund the Key Peninsula Fire Department over the next six years and will also reset the amount of future levies. The annual property tax rate would increase from $1.34 to $1.50 per $1,000 of assessed value.
It would be impossible to present in depth information here on Washington tax laws, constitutional limits, priority distribution regarding lower-level municipal governments and contradictory impacts. In brief, it is very complicated, so I will attempt to cut to the bone.
There are two reasons to vote against the proposed levy. One, the voter believes that he or she cannot afford the payment and two, it is the only opportunity the voter has to punish the fire commissioners for some reason.
The first reason only affects persons who actually own real estate for which property tax is paid. Renters and lease holders get free ride for fire protection and emergency medical. Comments below will explain how it is more cost-effective for property owners to vote for the levy.
For the second reason, the forced retirement of a beloved fire chief, Tom Laque, without any discernable reason or notice, should not be allowed by this recent act to raise the most irk. To that, the voter should choose a different voice and recognize that larger immediate concerns exist.
The fire department provides essential services, all focused on protecting life and property. Funding comes primarily from property tax paid by property owners in the district. During 2013, FD-16 received a total of $4.1 million from property taxes, and for 2014, that dropped to $3.3 million. For 2012 and 2011, it was $3.2 million.
In recent years, four of the last eight fire levies have failed. This was at a time when costs for everything have increased. For example, in the last few years, the price for milk has increased from $1 per gallon to $3-$4 per gallon. A loaf of bread from under $1 to $3. A chain-link fence post from under $3 to $12. Go see what just one pound of hamburger costs now.
Fire department operating costs have increased too, while attempts to pay basic costs have lost purchasing power resulting in an inability to fill vacant positions, delayed equipment purchases, delayed maintenance, et cetera.
Property owners may be unaware that the insurance industry does a detailed evaluation of all fire departments each five years, with their results determining how much is charged for fire and homeowners insurance. Factors reviewed include age of fire trucks, response time, number of firemen on duty, distance that volunteer firemen must travel to respond, et cetera.
Fire Chief Guy Allen says that the most recent insurance industry evaluation for the district has been released, but not yet received. Allen expects us to be hard hit for age of equipment, especially for Heron Island and Longbranch, where the stations are outdated and there are few residents who live close by.
The expected increase in insurance rates would far exceed any property tax increase resulting from the proposed levy. Further deterioration in fire department revenue and expenditures will surely see insurance rates increase for the entire district.
In this particular case, greed and self-interest, by itself, should ensure passage of the levy.
Pierce County advisory vote
This advisory vote informs the county council whether the voters want or don’t
(See Sorrels, Page 9)
A tale of a whale
The best adventures may involve a certain degree of danger. Us Whitfords do not as a rule shrink from danger, we embrace it.
Some folks go to sea in search of a living. Some search for game fish or food fish. This summer my wife and I went to sea in search of the great gray whale.
On July 1, we arrived at Depoe Bay, Oregon at 8:00 am, to join with our captain from Whales Tail LLC, Gary Stephenson. My wife Estrella had never been to sea before, but we already knew that her stomach didn’t like small airplanes. (A past mildly dangerous excursion.) “Are you here for whale watching?” our captain asked. “Yes,” I replied, thinking of my wife. I said, “we’re your eight o’clock chum run!”
Now there are a few things about whales and Depoe Bay you need to know in order to understand the gravity of our position. Depoe Bay was originally discovered by Dr. F.W. Vinae in 1878 while sailing his 40 foot boat along the Oregon coast. The entrance to the harbor is through a very fine 150 ft. dogleg entrance and it’s the smallest harbor in the world. In 1963 the government widened the 30 foot wide passage to 40 feet and dredged it so it was at least 8 feet deep at low tide. At 8 a.m. we powered through it at high tide into a Washington-like bay. Orcas who get between 22 and 32 feet long and can weigh up to six tons.
Compare that to our adversary who gets up to 50 feet long and can weigh up to 40 tons! We left the security of the harbor in Captain Stephenson’s 26 foot zodiac pontoon boat, a boat half as big as our quarter.
Stephenson managed the narrow rock-lined channel with the ease of experience and as soon as leaving that comparatively easy passage you encounter the bar. Most bays have a bar of some kind. For the unenlightened, a bar is a stretch of water where the water is lifted up by the ever shallowing shore; creating large waves. Here, the bar was so acute five to eight feet swells. But our captain cut through them with ease. Good thing too, as the sides on the zodiac are only about two feet. Foggy grey clouds obscured the sky and most of the time the shore as well. Grey skies make for grey water and we were looking for a grey whale. Our captain was good at spotting whales. He can actually smell them when they breach, and with a little practice so can anyone. When whales spout they eject a certain amount of water and sea foam that smells like a beach at low tide. Our captain eventually used this method and placed our craft where he thought a whale might be. Sure enough a few minutes later the whale surfaced approximately four feet away.
To see an enormous leviathan that close is breathtaking. We saw what passed for the head on a whale. You could see the lid covering its large eye, and as he was moving you could see him with his snapping mouth. We couldn’t see his tail, but we could observe part of his lower torso. He paused there for a minute or two then sunk out of sight, ignoring us like the little bit of flotsam we were.
Unfortunately big waves and going backwards was taking a toll on my wife. Her maiden name was Green and she was now displaying it. She had the camera so no photos, but she did get to see
(See Whitford, Page 9)
(From Whitford, Page 8)
the whale and she eventually felt better and didn’t chum the whale. This writing is proof that our Captain brought us safely back to terra firma.
For information on Depoe Bay, visit cityofdepoebay.org/pages/history.html, researched and compiled by Emmeline May in 2014. Whale Tales LLC is located at 270 Coast Guard Dr., Depoe Bay, Oregon 97341, phone (541) 765-2545 or toll free (800)733-8915 also at www.whalestaildepoebay.com
We’re already thinking about our next summer adventure. We plan to go up in a hot air balloon and spectacularly fly over something exotic like maybe a volcano or perhaps a nudist camp.
(From Sorrels, Page 7)
want the county to proceed with a new administration building that will cost about $230 million. This advisory vote is in advance of a referendum (with 38,648 signatures) that will appear on the November ballot — which, if passed, would overturn a council vote and stop construction.
Pierce County is one of only seven Washington counties that have chosen to become “home-ruled,” with its own charter (Constitution), responsible for creating its own laws and choosing how to conduct business under the direction of its own citizens. The other 32 Washington counties operate under laws and rules established by the Washington State Legislature.
In a home-ruled county, it is logical and expected that the county council would seek a nonbinding advisory vote on such a large expenditure of its citizens’ tax money. Expect a barrage of mailings explaining the county’s arguments for the construction.
Incidentally, every 10 years, the citizens vote for representatives for a Charter Review Commission that proposes amendments to the County Charter. This is that year.
The six months that the charter review representatives will meet during 2016 may well result in a charter amendment that would require binding advisory votes for future high-dollar construction projects.
A vote in favor of construction would still face the November referendum vote. A vote against construction would likely cause the Pierce County Council to rescind its decision, making the November referendum moot.
(From Whitmarsh, Page 6)
igious leaders or public figures denounce “those people” as a threat, and then ask us to support them (usually financially) as they rally against the evil scourge.
Just in the last week, I’ve witnessed this in action, with the enemy including immigrants, people of color, those in the LGBT community, Christians, the New World Order, people who listen to rap music, teenagers, tailgaters and drug users.
As a Christian, I follow one who commanded we love our enemies; a man who, in fact, chose not to create enemies but instead crossed boundaries and barriers to seek relationships with people. I have never liked the crowds who can see “us-vs.-them,” who don’t look at others and see enemies; friends who reach out to people across the aisle, seeking peace, rather than blame.
This is what healthy and mature people look like, and it’s a good model for us all to follow. Recognize that most of our anxiety can only be resolved when we address our own issues. Stop looking for people to blame, but instead reach out and seek to know and understand the other.
You are not my enemy, regardless of your beliefs and practices. I hope you’ll recognize that I’m not your enemy, either.
Dan Whitmarsh is the pastor at Lakeshore Community Church. He can be reached at firstname.lastname@example.org.
Group provides summer lunches for children in need
By Scott Turner, KP News
Summertime is special to kids. It can be that magic time to sleep in, to visit and play with friends all day, and to not worry about homework.
But for families struggling to make ends meet, it presents an additional hardship trying to keep their children fed as there is no school lunch program offer by the school district during the summer months.
The Peninsula Community Foundation, which runs the nonprofit Food Backpacks 4 Kids program during the school year, recognized this need and has stepped in to try and fill the void.
For the fifth year, the Simplified Summer Food Program has been in operation at the Key Peninsula Civic Center, providing a nutritious hot lunch for children ages 1-18 from 11:30 a.m. to 12:30 p.m., Monday, Wednesday and Friday. Unlike the reduced-cost lunches during the school year, there are no income guidelines — anyone can stop by and get a good meal.
“We want people to be aware of this resource, to take advantage of it and tell others about it,” said Karen Jorgenson, president of the foundation and overseer of the Food Backpacks 4 Kids program during the school year. “No one goes away hungry.”
The program, which is run under the guidance of the U.S. Department of Agriculture and is managed by the Office of the Superintendent of Public Education, makes certain that the meals have a nutritional value and are balanced with fruits and vegetables.
An example meal was Sloppy Joes with coleslaw and watermelon as a Fourth of July lunch, said Micky Bearden, a volunteer with Food Backs 4 Kids who helps prepare some of the meals for the summer program. “The kids love the chicken fries,” she added.
Jorgenson added that they provide a variety of meat types, such as gluten-free and vegetarian, to meet the differ-
(See Lunches, Page 11)
Charlie Mason, 5, reaches for his lunch recently as his mom, Heidi, looks on, and others, including Belle Goodman, wait in line for their free lunch as part of the Simplified Summer Food Program at the Key Peninsula Civic Center.
Photo by Scott Turner, KP News
ent eating habits people may have.
The meals are cooked and served at the KP Civic Center until Aug. 21. Bearden said the civic center is great, as it provides a cool place during the hot days for the kids to enjoy a hot lunch.
They serve 25-35 kids at each meal; on the first week in June they served 103 meals.
Funding comes from donations of both cash and food from churches, service groups and individuals in the community. A large portion of the food staples comes from the Emergency Food Network, Jorgenson said.
Monetary donations allow parents to have a meal along with their children, as the USDA regulations state that adults must pay for the meal.
Bearden was amazed at the community support they receive. “I didn’t know what they contributed until I started volunteering,” she said. She said donors could rest easy knowing every dollar and every can of food donated for the summer program goes to feeding children on the Key Peninsula.
“Lots of good things come out of this,” Jorgenson said of the summer program. “We’re feeding families. We get food donated that can’t go into the backpack program, like glass jars of pasta, so I bring them here,” she said. The group also partners with United Way’s Gifts in Kind program, so once a month Jorgenson picks up linens, clothing and household goods to give to the families.
On Mondays and Wednesdays, Boy Scouts from around the region come to the center and involve the kids in games and activities, and the boys in attendance can even earn merit badges.
“Because of them coming here, we were able to start a group (of Scouts) at Evergreen,” Jorgenson added.
The benefits, beyond the obvious of providing nutritious meals to children who otherwise may go hungry, are seen — and heard — from the children who fill the dining hall.
“They are engaged, saying ‘Hi,’ and socializing. It’s always loud, they are so energized,” Jorgenson said.
Food Backpacks 4 Kids started six years ago, sending home a backpack on Fridays during the school year with enough food to feed a family of four for the weekend.
The program is going strong with 75 volunteers filling backpacks at three locations — KP Middle School, Agnus Dei Lutheran Church and Harbor Fellowship Church, both in Gig Harbor. They also have helped start a program in Silverdale to assist Kitsap County families.
In its first year, they had nine backpacks. This past year, the number was 450, but Jorgenson said they could serve 2,000 qualifying students, many of them residing on the KP. “I wish we could reach out to them,” she said, adding the summer program is “like an extension” of the backpack program.
They’ve even been providing transportation to the civic center for children to attend the lunches. A van goes out to Palmer Lake, where the greatest percentage of the children come from in summer.
Recently, Bruce Titan Ford in Port Orchard gave the organization a great deal on a 2014 12-passenger van. Jorgenson said they detailed it with the group’s logo to help advertise their services. The new van replaces a 1991 van they were using that “just wasn’t appropriate for our purposes,” Jorgenson said.
They also started a new program providing crockpots, spices, recipes and bouillon to families. A grant from United Way has allowed them to expand the crockpot program to give them to any family on the Key Peninsula.
“I wish people would come visit at lunch time and see what’s going on,” Jorgenson said. “They would see these kids are so respectful.”
She is especially touched by the reciprocity. “It makes me feel good when I see people we are helping who come out to help. This is their way of giving back,” she said.
Want to donate?
Food Backpacks 4 Kids and the Simplified Summer Food Program always accept donations and volunteers. To do either, call 253-857-7401 or go online to foodbackpacks4kids.org.
**AUG. 1**
**Ohana luau and parade**
A parade from Key Center to the KP Civic Center begins at 2 p.m. followed by a family luau with family activities, live music, car show and more from 4 to 8 p.m.
**AUG. 1-15**
**Directors needed**
Six director positions are open on the Key Peninsula Community Council. Applications are at lpcouncil.org, at the Lugging Days KPC booth on Aug. 15 or call 884-2877. Committees needing directors are: Annual Candidates’ Forum, KP School Bus Connects (trans. public transportation), Safe KP Roadways, Key Center Walkways, KP Parks, KPCC & KP Land Use Advisory Committee, Pilot, and Building a KP Healthy Community.
**AUG. 1, 13, 28 and 29**
**WildWatch**
Learn about the ocean and ocean life at Penrose Point State Park 11 a.m. to 2 p.m. on Aug. 1, on Purdy Spit 11 a.m. to noon on Aug. 13, Aug. 28 at Penrose Point 10 a.m. to noon and 11 a.m. to 1 p.m. on Aug. 29. Visitors may need a state parks pass for Penrose Point events.
**AUG. 3-7**
**Sports camp**
KP Baptist Church sponsors sports camp for ages 5 to 12 from 8:45 a.m. to 12:15 p.m. at the KP Civic Center. Experienced coaches will teach basketball, soccer and cheer. $35 registration at kpbfellowship.org, 853-6761 or email@example.com.
**AUG. 3 and 17**
**Senior shopping**
Seniors have an opportunity to go grocery shopping and attend any scheduled Gig Harbor doctor’s appointments with transportation provided; a “Dutch” lunch is included. 884-9265.
**AUG. 3, 10, 17, 24 and 31**
**Bloodmobile**
The bloodmobile is at Alberssons in Gig Harbor, 11:30 a.m. to 6 p.m.
**AUG. 5**
**Pet neuter program**
The Northwest Spay and Neuter Center animal shuttle will be at the Key Peninsula Civic Center at 1 p.m. Call 253-627-7729 ext. 270 or email firstname.lastname@example.org for questions or to schedule an appointment. The Northwest Spay and Neuter Center offers affordable spay and neuter services for cats and dogs including special programs for feral cats and pit bull dogs. www.spayneuter.org.
**AUG. 6**
**Fuchsia meeting**
The Lakelbay Fuchsia Club meets at 7 p.m. at the KP Civic Center. Grinn, 884-9744.
**AUG. 7, 14 and 21**
**Summer reading programs**
Key Center Library presents events for children on Fridays. Kids 5 and older may fold paper into origami superheroes at 2:30 p.m. on Aug. 7. Children in grades 3-6 will discover common wildlife species with the Tacoma Nature Center: Washington Wildlife folks at 2:30 p.m. on Aug. 14. Registration is required for both events. Register online at piercecountylibrary.org. On Aug. 21, kids in grades K-3 will learn how marine mammals survive in frigid waters of Puget Sound by listening to Blubber, with Harbor WildWatch at 2:30 p.m. 548-3309.
**AUG. 7, 14, 21 and 28**
**Free movies**
Key Pen Parks presents Cinema Under the Stars at Volunteer Park on Friday nights with crafts at 7:30 p.m. followed by a movie at 8:30. Bring a blanket to sit on. Aug. 7 is “Finding Nemo,” which is G-rated, Aug. 14 is “Mary Poppins,” rated G, Aug. 21 is “Monsters University,” rated G, and Aug. 28 is “Maleficent,” rated PG.
**AUG. 8**
**Family concert**
A free family concert “Bee Boppin’ Bugs,” with children’s recording artist Nancy Stewart is hosted 11 a.m. at Volunteer Park. Bring lawn chairs and an optional picnic lunch to enjoy a day in the park. This event is sponsored by Friends of the KP Library, the Key Center Library and Key Pen Parks.
**AUG. 11 and 26**
**Crochet or knit**
The Loving Hearts group knits and crochets for charities and meets Aug. 11 from 1 to 3 p.m. and Aug. 26 from 7 to 9 p.m. at Way Point Church, 12719 134th Ave. KPN. Yarn donations are always needed. Virginia, 884-9619 or email@example.com.
**AUG. 12**
**Ashes meet**
The Ashes support group for Fire District 16 meets 10:30 a.m. at the fire station in Key Center. 884-3771.
**AUG. 16**
**Garden club meets**
The Bayshore Garden Club meets 1 p.m. at the fire station in Longbranch. Francine, 569-1381.
**AUG. 20**
**Community forum**
The Mustard Seed’s Third Thursday Community Forum meets at 10 a.m. at the Key Center Library. Transportation is available by prior arrangement. 884-9814.
(See Community, Page 13)
**PUBLIC MEETINGS**
**KP Veterans**
Aug. 3 and 17, 7 p.m. at KP Luthern Church; membership open to veterans and military service members and families age 16 and older. 253-509-8656 or firstname.lastname@example.org.
**KP Lions’ dinner, program**
Aug. 5 and 19, 7 p.m. at Key Center Fire Station; 853-2721.
**Key Pen Parks**
Aug. 10, 7:30 p.m. at Volunteer Park administrative office; public is encouraged to attend.
**KP Fire Department**
Aug. 11 and 25, 5 p.m. in meeting room, Key Center Fire Station; keypeninsulafire.org.
**Key Peninsula Council**
Aug. 12, 7 p.m. at Key Center Fire Station; Karen Meyer from Tacoma Pierce County Health Department discusses the KP community health needs assessment, which is used by both CHI Franciscan and MultiCare.
**KP Civic Center Association Board**
Aug. 13, 7 p.m. meeting in Whitmore Room, KP Civic Center; 884-3456.
**Peninsula School District Board**
Aug. 13 and Aug. 27, 6 p.m. at district office.
**KP Democrats**
Aug. 17, 7 p.m. at Home fire station; school board candidates are invited to speak. email@example.com.
**KP Land Use Advisory Commission**
Aug. 18, 6:30 p.m. at the KC Library; email: firstname.lastname@example.org.
**KP Democrats**
Aug. 18, 7 p.m. at Home Fire Station; all are welcome.
**Longbranch Improvement Club**
Aug. 18, potluck, 7 p.m. at Longbranch Improvement Club; 884-0422, longbranchimprovementclub.org.
**KP Citizens Against Crime**
Aug. 21, 7 p.m. at Key Center fire station.
**KP Farm Council**
Aug. 24, 6:30 p.m. at Home Fire Station; email@example.com.
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(From Community, Page 12)
**AUG. 21**
**Barter fair**
Barter Fair is hosted Friday 6 to 8 p.m. at Volunteer Park. Stay for Cinema Under the Stars afterward.
**AUG. 22**
**Ice cream social**
The Key Peninsula Historical Society presents an Ice Cream Social at Cape E. Farm in Home, 2 p.m. Music provided by Down Home Band. Colleen Slater will read from her new book, “Peninsula Pioneers,” available for sale.
**AUG. 27 TO OCT. 1**
**Job track**
Adults may work with Forward TRACK-Job TRACK: Tech Readiness and Career Kickstart every Thursday, 3 to 4:30 p.m. at the Key Center Library. Gain skills in basic web development and get to the next level with your job. Learn online at home (5-10 hours of coursework/week) and get help from library staff in class. Check out a Chromebook as your textbook. Registration is required. Email firstname.lastname@example.org to reserve your seat. Class space is limited.
**AUG. 29**
**Craft a notebook**
Are you ready for school? Come to the library first and craft your own customized back-to-school notebook 2 to 4 p.m. at Key Center Library. 548-3309.
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**OFF THE KEY**
**AUG. 1**
**Car show**
The annual Cruise the Narrows Classic Car Show begins at 8 a.m. in Uptown Gig Harbor. No pre-registration. Gigharbor cruisers.com.
**AUG. 1, 8, 15, 22 and 29**
**Classic boat rentals**
Rent a classic boat at the Gig Harbor BoatShop from 10 a.m. to 7 p.m. Prices vary. Gigharborboatshop.org or 857-9344.
**AUG. 4, 11 and 18**
**Park concerts**
Free concerts at Skansie Brothers Park take place every Tuesday beginning at 6:30 p.m. Aug. 4 features Ranger and the Re-Arrangers, who play unique music; Aug. 11 is Austin Jenkes, a folk/jazz/rock artist; Aug.18 is the Funaddicts, who play all genres. Bring chairs or blankets, no smoking, and riding the Gig Harbor Trolley is suggested. Concerts are sponsored by CHI Franciscan Health, Harbor Hill, Menageries and the City of Gig Harbor.
**AUG. 6**
**Democrats meet**
26th Legislative District Democrats meet 7 to 9 p.m. at Givens Community Center, 1026 Sidney Road, Port Orchard. All are welcome.
**AUG. 6, 8, 10 and 13**
**Bloodmobile**
The bloodmobile is at Kiwanis Club of Peninsula Gig Harbor 9:30 a.m. to 12:30 p.m. on Aug. 6, at Hagggen Northwest Fresh 9 a.m. to 12:30 p.m. on Aug. 8, at AllianceOne from 1 to 4 p.m. on Aug. 10 and at Kiwanis Club noon to 7 p.m. on Aug. 13. Thank you for donating to help save lives.
**AUG. 6, 13 and 20**
**Uptown concerts**
Uptown summer concert features Commen Ground (rock) on Aug. 6, Budapest West Hungarian waltz on Aug. 13, and the Rokkerbox (rock) on Aug. 20. All concerts begin at 6 p.m. uptowngigharbor.com.
**AUG. 6, 13, 20 and 27**
**Waterfront market**
The Waterfront Farmers Market at Skansie Brothers Park is on Thursdays 3 to 7 p.m. Join Harbor WildWatch for live animal touch tanks by the market.
**AUG. 7 and 8**
**Cinema Gig movies**
Free Friday night date night movie at Dorkin Creek Park, “The Goldfish” and the Saturday night family movie at Skansie Brothers Park is “Happy Feet.” Movies begin about 8:30 p.m. Bring chairs or blankets; no smoking. Gigharborguide.com.
**AUG. 7 to 29**
**Play presented**
Paradise Theatre presents “H.L.M.S. Pinfire” Fridays and Saturdays at 7:30 p.m. and Sundays at 3 p.m. 253-954-PLAY.
**AUG. 15**
**Bluegrass festival**
The Olalla Bluegrass Festival, featuring local and national bluegrass, folk and jam bands, plus food, arts and crafts, activities for children and a kids’ contest, is from 10 a.m. to 8:30 p.m. Advance tickets are available July 31-Aug. 13 at brownpapertickets.com. For festival schedule or other information, go to ollalabluegrassfestival.com.
**Author shares**
Key Peninsula author Leslie Bartspis will be at Barnes and Noble Bookstore - Kitsap Mall introducing her second novel, “Vanilla Grass, a novel of redemption,” from 1 to 3 p.m., 10315 Silverdale Way NW, Silverdale. The novel tells the story of a Vietnamese woman with PTSD who receives a golden retriever that changes his life. Free bookmarks and autographed books are for sale. (360) 698-0945.
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**WEEKLY EVENTS LISTINGS ONLINE**
See what’s happening at keypennews.com
State matching grant allows Gateway Park development to move forward
By Scott Turner, KP News
The Key Peninsula Metropolitan Park District got some unexpected yet welcome news recently when the staff learned they were awarded a $500,000 matching grant for Gateway Park development as part of the state Legislature’s 2015-17 capital budget.
Scott Gallacher, executive director of Key Pen Parks, was pleasantly surprised when he received the call about the award, as he noted the statewide grant process is a ranked process and that their grant proposal was one of only two last year was ranked 60 out of 70 applications.
“The legislators focused on proposals that had a development component to them and we had that, so that helped us to be selected,” Gallacher said. Prior to being selected for funding, he said the district anticipated the state would provide funding for approximately half of the proposed projects submitted to the legislature.
Gallacher is confident the district can fund its end of the matching grant because of its past stewardship of tax monies collected for its capital projects budget.
“Each year, our budget includes anywhere from $300,000, $400,000 to $500,000 to put toward capital improvements,” he said.
The grant, which for technical reasons will actually award 48 percent to Key Pen Parks’ 52 percent of up to $500,000, will now jumpstart the plans of phase 1 of the project that includes ingress and egress points, a picnic shelter, restroom facilities, parking and the design and construction of a new playground.
The district is working with Bob Droll & Associates of Lacey to develop the 39-acre Gateway Park, located in the 10200 block of State Route 302.
Gallacher said the parks department is doing its due diligence now that includes the permitting process for the work, and construction could start early next year during a summer break and opening of the playground in 2017.
But much of the timing is subject to change, Gallacher noted. “A lot is still to be determined because we were not expecting this grant — so moving forward, the planning is still very fluid,” he said.
Topping the district’s agenda is to form a playground planning committee. They are looking for residents with young children to help fill the committee and serve that will provide design input and help develop the specific components of the playground in Gateway Park. The first meeting is scheduled to take place 6:30 p.m. Tuesday, Aug. 18 at the Key Pen Park office in Volunteer Park, according to the district’s website.
Anyone who is interested is asked to contact Gallacher by phone or email.
Another way residents can help is to donate money to the KP Parks Foundation, a nonprofit arm of the district that helps raise funds for capital projects.
“We’ve been very good stewards of the money raised,” Gallacher said. “We’ve been able to leverage the money and make $1 grow to $2 or $2.50 to make the parks a better place for Key Peninsula residents.”
He said they aren’t sitting still as they continue to write new grant applications and continue to seek funding from a variety of sources, with the main focus currently being the development of the Gateway Park.
“We’re working to build a park in the 98324 ZIP code for the north Key Peninsula area,” he said.
For more information, follow Key Pen Parks on Facebook or visit keypenparks.com.
MEET YOUR ELECTED REPRESENTATIVES
Jan Angel, 26th District state senator
By Sara Thompson, KP News
Jan Angel is not new to the political scene, but her path was indirect — it started with banking, then passed through business and real estate on the way to her current role.
Angel was raised in Colorado and was recruited, along with her husband, as a banker in Alaska. For nine years, she was known as “the blonde with the money.” After leaving working in a new bank started by the tribes, she joined the National Association of Bank Women and was asked to run as one of eight national directors. There, she got a taste of campaigning and loved the chance to travel throughout the region. When her husband’s work closed there, when Washington state in 1983, she decided to go into business for herself rather than continue in banking.
For a number of years, Angel ran a successful haircare franchise. Life took a difficult turn when her daughters were in college and her husband’s company went bankrupt. As the family still reeling from the shock and loss of a most successful haircare location lost its lease and she decided to sell the franchise. At that time, she entered the world of real estate.
Her mother’s words served as inspiration: “When you have a job to do, find a way to get it done.”
“When I don’t kill you makes you stronger,” Angel commented as she described those initial years of adjustment. She was named “agent of the year” in her first year in real estate. She has since remained, with a family that now includes two daughters, a stepdaughter, a stepson, nine grandchildren and four great-grandchildren. She and her husband live in Port Orchard.
As a realtor, working with clients to understand what they could do with their own property, she became involved in land use issues. When she was asked to run for Kitsap County commissioner she agreed, was elected, and served for eight years.
Although she planned to retire after eight years, she was encouraged to enter the race for state representative. “I felt that everything I fought for at the county level I could affect at the state level,” she noted. Her bid was successful and she served for five years. When Derek Kilmer’s seat in the state Senate opened, she chose to run for that position. She was elected in 2013.
Angel stated that her office spends a lot of time working directly with constituents, dealing with individual problems concerning such issues as land use, Labor and Industries, and Department of Social and Health Services. She sees herself defending people’s freedom, and as “scissors, cutting through the red tape tied to government.” She enjoys being a part of the majority party in the Senate. “Playing offense is very different from playing defense,” she said. “Our job is to move the ball. In the House, we were mostly holding the line.”
She currently serves on three committees: Financial Institutions and Insurance (she is vice chair), Healthcare, and Trade and Economic Development.
When asked what she sees as the key issues for the Key Peninsula, she cited transportation, business and education.
She wondered about the possibilities of private companies coming in to help provide transportation, though this is a local county more than a state issue. She discussed her support of an adequate revenue package for transportation at the state level — to complete the environmental impact study on SR-302 and to carry out congestion studies between Gig Harbor and Purdy.
As a member of the Key Peninsula Business Association, she has met with businesses to see what she can do to help.
In terms of education, she commented that although the state budget was not finalized at the time of the interview, she supported increased teacher salaries and benefits, was concerned about the level of compensation for some administrative positions, and was not sure that lowering classroom sizes above the fourth-grade level was necessary.
“It is hard to stay in touch with all my constituents,” she acknowledged. She attends events as she is able, including a Key Peninsula Community Council meeting in June with Reps. Jesse Young and Michelle Calder. In addition, she has hosted several “hugs” events where constituents come in and are able to interact with her via a phone call.
Angel encourages constituents to contact her office with questions or concerns. Her office tracks issues closely and pays attention to how voters weigh in. Her Olympia office number is (360) 786-7650. Her local district office number is (360) 443-2409 and her email is email@example.com.
Huge THANK YOU to all the individuals & businesses who contributed to our appeal letter in June. The Key Peninsula Civic Center relies on your contributions and support to sustain our mission.
Key Peninsula Lions stage 26th annual Volksmarch
By Hugh McMillan, KP News
After the blistering heat of previous days having abated, bringing perfect walking weather, the Key Peninsula Lions, sponsors of the club’s 26th annual Volksmarch, anticipated a large number of participants on the trails for the always scheduled first Saturday-after-Independence-Day event. Surprisingly, it didn’t happen.
Whereas the first of the walks in 1989 was a Saturday/Sunday event that drew more than 1,200 walkers, and since then the lowest number of participants has been 100, this 2015 event had only 50 people participate.
“We were surprised that no walkers from the Key or Gig Harbor communities participated,” said Neal Van der Voorn, the event chairman.
The walk, held at Key Peninsula Parks’ 360 Trail Park, nonetheless pleased participants with the route’s layout swinging through from the park’s perimeter.
“Many thought the trail on the east edge of the park was the most beautiful, tracking through groves of ancient trees and views of the Horseshoe Lake golf course,” said Van der Voorn. “It is a more challenging trail with several short switchbacks dropping down into small water holes and back up over little hills. When asked, several walkers thought the low turnout was due to so many events on summer weekends and a threat of rain showers.
“In my opinion,” said Van der Voorn, “it was the smoothest Volksmarch in years, with one easy route; no doubling back and forth.”
To KP Lion Dan Van Antwerp: “The cool day was a welcome relief from the summer heat.”
“It made for an ideal day for walking in the quiet solitude of the 360 Trail Park. A few light sprinkles did nothing to dampen spirits of participants. Boy Scouts of Troop 220 did a masterful job of laying out directional signs. Many participants noted the ease with which they were able to follow the route through the forest,” he said.
“Despite a cold morning breeze, diehard hikers traveled much farther away to participate in the annual march,” said KP Lions President Hal Wollman. “The annual event is made possible by hard work and the combined efforts of the KP Lions and our Boy Scout Troop 220. Many bikers said this was the best
Star Scout, Robert Quill, a member of the Boy Scout Troop 220 team of eight, who led their fellow troopers on the 26th annual Key Peninsula Lions Volksmarch trail in Key Pen Parks’ 360 Trail Park. Here, Quill prepares to pound in another of the arrow-signs marking directions for walkers.
Volksmarch yet and they thoroughly enjoyed the day.”
Participating walkers hailed from Seattle, Fife, Orting, Kirkland, Bellevue, Olympia, Auburn and even Vancouver, Wash.
First Class Scout Mark Lerron said, “Helping set up the Volksmarch trails was fun, even though we were working at the same time.” Lerron also participated in recovering all the trail markers after the event, for which Assistant Scoutmaster Matthew Mills counseled, “If you can jam two, bring a good-sized day pack and use a lock screwdriver for removing a marker; it should be easier to store everything in our packs that way.”
As they did on the Friday before the event when they pounded in countless directional arrows to guide walkers, on Saturday the scouts’ cleanup team rode their mountain bikes to clear the trails and remove all markers that will be used again on the Volksmarch in 2016.
“Thank you to scouts Mitchell, Robert, Blake, Nick, Mark, Alexander, Joseph and Mackenzie for setting up and clean up the Volksmarch trail,” said Mills, who worked with volunteers both days. “The Lions Club and the Volksmarchers really appreciate your help and support.”
For information, contact Van der Voorn at firstname.lastname@example.org.
Annual Cider Swig squeezes the best out of apples
Calling all cider lovers, hard cider aficionados, apple lovers, kids: The second-annual Cider Swig — The Great Peninsula Cider Festival promises to be a spirited, delectable regional tastes, music and family fun.
Rain or shine, the Cider Swig will be in full swing from noon to 5 p.m. on Saturday, Sept. 26, at Schmelz Homestead Park, 10123 78th Ave. NW, Gig Harbor.
At the Cider Swig, discover some of the finest ciders the Northwest has to offer — 50 and counting — by more than 15 cideries. And while cider varieties are the focus of the festival, some infused with flavors like ginger and chili, there will be much more to do and see. Food options by area restaurants and food trucks will range from Southern barbecue to traditional comfort food. There also will be live music throughout the day.
Bring the entire family — there will be something for everyone. The Kids’ Apple Zone run by the Curious By Nature School will have games and activities for all ages. There is even a drop-off option for a small fee, so parents can enjoy some kid-free time. Admission is free to all festival areas except the cider garden and sales tent, where entrants have to be 21 to enter (ID required). Advance ticket purchase for the cider garden is recommended, but tickets are expected to sell out. After sipping and sampling, take home your favorite ciders from the cider tent for savoring later.
Proceeds from the Cider Swig support environmental education and conservation to preserve and expand area parks, trails and natural areas around the Gig Harbor and Key Peninsula communities.
Tickets are $28 in advance or $35 at the gate (while supplies last). Cider Swig volunteers may purchase a ticket for $18 and there is a designated driver ticket option for $10. Admission includes five drink tokens plus a festive glass. Extra tokens will be available for purchase.
Tickets are available online at www.ciderswig.eventbrite.com, from the Greater Gig Harbor Foundation (253) 514-6338, or from the Greater Gig Harbor Foundation booth at various local events. Anyone who is interested in volunteering can call the foundation at (253) 514-6338 or email email@example.com.
Summer camp more than just archery, songs around the campfire
By Scott Turner, KP News
It may be high season for back-to-school sales, but summer break is actually only half over. For children needing something fun and challenging to do during the dog days of August or for parents who need a break from their kids stringing around playing video games all day, the answer remains the same: Camp Seymour.
Camp Seymour has been providing a safe and affordable recreational opportunity for children of all ages since 1907.
“It started when the Masons W.W. Seymour let youth from the YMCA come to his property during the summer to camp,” said Scotty Jackson, executive director of Camp Seymour. Around 1907, Seymour deeded the property to the YMCA and it remains the camping site of the YMCA of Pierce and Kitsap Counties today.
The expansive grounds on Kramer Road along Glen Cove total 130 acres. “110 when the tides is high,” Jackson added, and there is more than enough room for 20 cabins that house 10-12 campers and two leaders, a climbing wall, a rope course, sailing and canoeing, archery, a swimming pool, arts and games and sports and even an organic garden.
Key Peninsula resident Jayce Richerson, 12, is at his third year of summer camp and he appreciates the values the camp and its counselors provide. “The adults treat us well and generally don’t do bad things. They make CAD TV shows instead for sex, alcohol, drugs, tobacco and violence and to stay away from those,” he said.
Summer programs range from day camps that run for a week to two-week overnight camps that include paddle trips around the peninsula with a campfire at the end, parks overnight, and three-day backpack trips in the Olympics. For students in grades 9 and 10, there is a two-week trek teen leadership program where the campers learn the responsibilities of being a camp leader.
“I wouldn’t be able to do the scheduling with the confidence I do now without doing the camp,” said Bremerton resident Ambrielle Anderson, 21, who is assistant camp director, manages the program directors and schedules camp program activities. “Just to say I’ve been in a leadership program gives others confidence in me,” she said.
Summer programs are run for students from elementary to high school age and costs are around $600 to $900. But no one gets turned away from an inability to pay. Jackson said the YMCA’s fundraising campaign helps a number of children to experience camp life. Recently, YUSA offered a $15,000 matching grant to provide 100 percent scholarships and the Y raised $30,000 to more than meet the goal.
Camp staff works with Communities in Schools Peninsula and with school district counselors, teachers and principals to provide outreach to kids who could benefit from a scholarship.
“It’s really a fun and comfortable place to come and hang out,” said 16-year-old Nate Martin, of Kent. He has been attending summer camp since he was 9. “You’re about your age too. It builds up my confidence because everyone is nice and supportive,” he said.
The eight weeks of summer camp activities isn’t the only time the camp is busy, as there also is a September through June marine science program in conjunction with the Peninsula School District and other schools. In total, the program reaches nine counties and 135 schools, Jackson said, and uses state-approved science curriculum.
“It’s very hands-on marine science,” Jackson added. “We even have ‘belly biologists’ where the kids lay on the dock and see what’s going on underneath.”
In between the school year and summer programs, the camp also runs weeklong camps for the Muscular Dystrophy Association in Seattle and for the Washington Air National Guard.
This past year, Lowe’s wanted to partner with the camp that is run for MDA and several stores across the region pooled their community funding along with 40 volunteers as part of the Lowe’s Hero Program.
“Lowe’s (Lowe’s) have the skill set to actually get some work done,” Jackson said, noting they helped install fencing for the pool and also built a new deck for the amphitheater, making it wheelchair-accessible.
Although the older structures on site are grandfathered in and don’t need to meet current ADA standards, the camp is upgrading cabins and bathrooms to be handicap-accessible and Lowe’s recently provided $20,000 in supplies to help further that effort.
A new program, called Camp Corral and sponsored by Golden Corral Restaurants, provides 100 percent scholarships to children from military families of fallen, wounded or disabled veterans, and the camp serves 180 children of all ages for that program.
“We’re thriving, we make camp accessible to everyone and we never turn anyone away,” Jackson said. “Kids go home more resilient, better prepared for school, and have a greater ability to make new friends.” “Probably the most fun I’ve ever had is at Camp Seymour,” Martin said.
Want to go to camp?
Although some summer programs at Camp Seymour are at capacity, many others still have openings. To see what’s available, go online to campseymour.org.
Local Schools and Students: Testing
Editor’s note: Because four out of five households in this area don’t have children in public schools, we wanted to provide a useful overview through a series in the KP News. The first article provided a brief snapshot of the three elementary, one middle and one high school that serve our students. The second article covered basics of school funding. Here we review testing. The final article will cover the local school board. We welcome questions and comments.
By Sara Thompson, KP News
Testing has become an emotional issue for students, teachers and parents over the past few years. For some, it represents an unwelcome intrusion, a source of encroaching stress, something that disrupts classroom, a cause of anxiety for students and possibly even a threat to teachers’ integrity. For others, it is a way to measure student progress, a tool to identify gaps and find approaches to improve outcomes for students, teachers and schools.
The role of the federal government
The federal government first became actively involved in public education in the 1960s, when President Lyndon Johnson, who had been a teacher, identified education as an important tool in fighting poverty. In 1965, Congress passed the Elementary and Secondary Education Act (ESEA) as part of the war on poverty. Title I, federal funding to support the education of students living in poverty, grew out of this program.
No Child Left Behind, passed in 2001 with broad bipartisan support, was a reauthorization of the ESEA. It expanded the federal role in public education through annual testing, annual academic progress report cards, teacher qualifications and teacher changes.
It did not establish national learning standards but it did require states to develop assessments in basic skills. To receive federal school funding, states were required to assess all students at select grade levels.
Race to the Top was a program established in 2009 during the Obama administration. Using competitive grants, it sought to encourage educational reform. Grant recipients were required to adopt the Common Core standards and to use data in a more sophisticated way than is required by No Child Left Behind. All students were followed from year to year longitudinally and in addition, teacher evaluations were tied to student achievement.
The first two rounds of Race to the Top grants were opened in 2010. Washington applied for the second of the two rounds and was not awarded the grant.
History of standards and testing
It is impossible to talk about the history behind the current tests without including the history of common learning standards. If proficiency tests are meant to measure whether or not students have mastered the content outlined by the standards, Jennifer Dempewolf, director of assessment and accountability at Peninsula School District, noted that Washington state was an early adopter of common learning standards.
The state’s first standards (in reading, writing, math and science) were established in 1994, with testing for assessment (Washington Assessment of Student Learning or WASL), starting in 1997. Passing exams as a high school graduation requirement started in 2006. Over the past 20 years, tests and their acronyms have changed, as have the learning standards, testing intervals and graduation requirements.
During this time, at a national level, governors and business leaders joined to form Achieve, a nonpartisan group helping to lead educational reform. Their resulting report in 2009 concluded that high schools were not providing the skills necessary for students to succeed in a world with increasing demands for college and career readiness. In response, the National Governors Association convened a group to develop the Common Core standards. They were released in 2010 and Washington adopted them in 2011.
Chuck Cuzzetto, superintendent of the Peninsula School District, had this to say in support of the Common Core: “It’s like mom and apple pie. The learning standards are more rigorous than earlier ones, are consistent across all states, and are competitive internationally.”
He thinks that most of the negativity arises from confusion between the learning standards and the tests designed to measure proficiency.
This year saw big transitions in Washington state. Four years after introducing the Common Core, testing based on these new standards took place.
How test results are used
Cuzzetto emphasized that evaluation of student progress has always been a part of the educational system, and described it as a constant activity. “Every day is the classroom — teachers judge how effective their curriculum is on a daily basis by observing their students; they also use homework, projects and classroom exams. On a buildingwide level, schools evaluate progress toward their identified goals. On a district level, they review the standardized test scores or other measures depending on what is in their schoolwide strategic plan.”
The district, likewise, uses test scores as part of its overall strategic plan evaluation. Finally, the state uses test data as part of its evaluation and reporting of schools and districts.
Prior to high school, test results can help identify individual students who might need additional support the following year but progression to the next grade level is based on teachers’ classroom observations and not standardized test results. Passing standardized test (biology, math, English/language arts) is a high school graduation requirement. The tests required for graduation have recently changed, and for many students there are alternatives.
Uproar over testing
The Smarter Balanced Assessment (SBA) was used for the first time this year. Refusal to take the exam was widely reported. Cuzzetto and Dempewolf noted that refusal was not a major issue in the Peninsula School District. Schoolwide, only 3 percent of students in third through eighth grades took the SBA that dropped to 50 percent in high school.
Some high school students simply had no personal benefit from taking the new exam. Students who will graduate in 2016 must pass the 10th grade HSPE (or the
(See Testing, Page 19)
11th grade SBA). They took the HSPE last year. So when they were asked to take the 11th grade SBA this year, many students refused. For schools and districts, the results could serve a useful role, allowing them to assess curriculum and begin the process of improving and adjusting.
**Testing takes time**
Many teachers and parents have expressed concern about the amount of time that is required for its impact on classroom teaching. Dempewolf summarized the actual amount of time as follows:
- Grades three through eight and 11th are tested yearly. The math and the English/language arts exams take three to four hours each.
- Grade 10 biology exam (taken at the end of the biology class) takes two hours.
- But she and Cuzzetto acknowledged that the logistics of administering a new test using computers presented logistical challenges and the impact on classroom time this year was significant, particularly in middle and high school.
**Looking into the future**
Cuzzetto and Dempewolf see value in Common Core and in the data that standardized testing can offer. They noted that the last few years have been especially full of change. With new learning standards and new curriculum — and now with new tests — students, teachers and administrators are all part of a steep learning curve. It is likely that the tests will be tweaked. Perhaps the testing frequency and intervals will be adjusted.
It is certain that the percentage of students judged proficient on the tests this year will be lower than in the past. This is virtually always the case when new standards and tests are introduced.
And early test reports indicate that this is true — “passing” scores have gone from an average of about 80 percent to an average of 50 percent.
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**KP Historical Society set for a busy August**
*By KP News staff*
The KP Historical Society is preparing for many free events open to the public to take place this month.
The Faraway Centennial Celebration culminates on Aug. 8 at the Longbranch Improvement Club, with complimentary admission from 4 p.m.
Faraway, the summer estate of the McDermott family on Filacy Bay, was a magical place where many visited over the years, organizers said. Although no longer owned by the family, the rich history of the idyllic retreat belongs to the Key Peninsula.
Featured at the celebration will be photos, unique artifacts and documents of the McDermott family of Bon Marche fame. Rather than a set program, there will be knowledgeable folks to answer questions about Faraway and the family who owned it. Discussion and exchanges encouraged.
Cake and tea will be offered in honor of Josephine Nordhoff McDermott’s birthday.
Connie Hildahl has written a book about Faraway that will be available for sale.
The story takes place between 1850 and 1930. The book includes over 250 photos plus maps and is an important piece of Pacific Northwest history. More than a historical narrative, this is a story of the American dream.
“It has been a privilege to meet family members, listen to their memories and explore the boxes of photos and documents they shared,” Hildahl said.
**Penrose Park**
Members of the Key Peninsula Historical Society will tell tales of the Penrose family who had annual summer camps on their property that later became Penrose Park. There is a fee for park parking, but the presentation is free on Aug. 15, at 7 p.m.
**Ice Cream**
An Ice Cream Social is planned for Aug. 22 at Cape E Farm and Vineyard in Homer. Colleen Slater, local author and historian, will read from and sign copies of her latest book, “Peninsula Pioneers.”
The program is free, beginning at 2 p.m., with “make-your-own” ice cream sundaes.
**Museum**
Museum hours are Tuesday and Saturday 1 to 4 p.m., or by appointment.
The museum’s current display is: “The Story of the Key Peninsula — Its Past, Its People, Its Places.”
Free admittance, children welcome. For information, call 888-3246.
Cuzzetto is confident that students in the district will outperform the state average, as has been the case in the past. But the number of students graded as proficient will fall. And over the next several years, as the curriculum builds, the number of students passing will again rise.
Over time, testing requirements and intervals will undoubtedly change. At the state level, the Legislature stepped back from the requirement to pass the biology EOC exam to graduate this year. At the national level, as Congress reviews the ESEA, it is likely that earlier stringent testing requirements will be decreased.
KP News staff report
Do you have homegrown tomatoes you would be interested in trading for jam? Do you make beaded jewelry you’d like to exchange for soap? Key Peninsula Barter is planning with the Tacoma Barter group, Fair Tradin’, to host a barter fair Friday, Aug. 2, from 6 p.m. to 8 p.m. at Volunteer Park in Key Center.
Area residents are invited to bring their homemade and homegrown items to trade at the event. This is unique as it is the only barter fair of the 2015 season to be held at Volunteer Park. Typically the fairs are held at Lake Holiday Association Clubhouse. Organizers say it is their only event in 2015 scheduled for a Friday night.
“We wanted to schedule an event which our friends in the Tacoma barter group, Fair Tradin’, could attend as well,” said Alice Kinerk, one of the group’s founders. “We were able to work with Key Pen Parks to hold this fair just prior to their Cinema Under the Stars event for that evening. Our hope is that Tacoma folks will decide to make the drive over the bridge if there is an outdoor movie to round out their evening.”
All are welcome to attend the barter fair, whether or not they have items to trade.
“Since the idea of barter is new to many, we encourage ‘walk-throughs’ who are just there to check it out. However, some shoppers may feel that they need to make huge amounts of one item or be intimidated about the process. If you have a bag of kindling, bring that and stroll around the tables with it, you will probably go home with something wonderful in trade,” Kinerk said.
Kinerk said that setup begins at 6 p.m.; those just there to browse should know that bartering will not begin until around 6:30 p.m. Those who come just to browse may make arrangements to purchase items off site, but the one strict rule the group maintains is that nothing is sold for cash, Kinerk said.
Leslie Dalton has taken part in local barter fairs and plans to do so again. “I enjoy getting together with like-minded people to exchange not just products and services, but to share ideas and create community. Another thing is, I hate dealing with money, it makes me uncomfortable and this helps alleviate that a little. The actual bartering is fun too. And seeing different people’s creative solutions is a joy, a joy that I can take home,” she said.
The group does hold an auction at each event. The funds raised offset printing costs and help pay rent at the Lake Holiday Association Clubhouse, Kinerk said.
“Our auctions are awesome. It’s $1 for a ticket, $5 for six. We get wonderful donated items — knit scarves, wooden toys, baked goods — and auction three items at each fair. Your chances are very good, and you can buy a ticket even if you didn’t bring anything to barter,” Kinerk said.
Between events, the group maintains a Facebook page where locals can ask questions or post about items they would like to trade.
Kinerk also writes periodic blog posts for the group including photos of past barter fairs, FAQs and a list of all scheduled events for 2015. For information check out Facebook/keypeninsulabarter. Or visit wordpress.kpharter.com.
Alice Kinerk can also be reached at 864-2723.
OBITUARY NOTICE
Anna Rogers
Anna Rogers was born on Nov. 9, 1920, in Sandy Creek, NY, to Harold DeShane and Julia (Hall) DeShane. When Rogers was 15 the family moved to Springfield, Massachusetts. There she met and married her husband, Darwood Rogers in 1939.
They had four children: Robert, Judith, David and Carol. Her husband passed away in 1983, after 43 years of marriage.
In later life she moved to Lakebay to live with her daughter Carol. She especially loved her friends at Lakebay Community Church, where she was actively involved.
On Sunday July 12 she passed away at home in the presence of her family. At her passing, she was the Lakebay Church’s oldest active member at 94 years old.
A Memorial service was held at Lakebay Community Church on July 19.
Teenager makes surprise donation to food bank
By Rick Sorrels, KP News
Seventeen-year-old Chanel Mortimer surprised her parents and others with her decision that, instead of presents for her recent birthday, guests and relatives provide cash or food donations for food banks.
“This came out of the blue, totally unexpected,” said her mother, Darla Mortimer. “We are very proud of her, and touched as well. She does think of others, not herself, and has a heart for the needy.”
When asked where the idea came from, Chanel Mortimer said that she participated in the Good Karma 5K Run last May, and obtained commitments for donations that were dedicated to NW Harvest that provides food to food banks.
“Prior to my birthday this year, I realized that I already had everything I needed. Our family has been so blessed, I didn’t need anything else. I remembered NW Harvest, but wanted to do something more local. A family friend makes donations to the Bischoff Food Bank, so that’s what I decided to do,” she said.
Mortimer received $157 in cash which she donated online to NW Harvest. She received enough food to fill three large boxes which were wrapped in cellophane and delivered to the Bischoff Food Bank in Home.
“We were surprised and shocked that a 17-year-old would be so selfless and compassionate. There is always a shortage for food for those in need. This restored our faith in the upcoming generation,” said Kimberly Miller, the operations manager for Bischoff Food Bank.
Mortimer has been homeschooled her entire life. She expects to receive her high school diploma in June 2016. She is in the Running Start program, taking college classes at Tacoma Community College. Her current goal is to obtain a master’s degree in occupational therapy. She babysits for spending money, and is learning how to drive.
“It’s important for young people to get involved in charities,” Mortimer said. “Most do without their daily cup of coffee, and make a donation. It gives you a real good feeling.”
POET SPEAK
KP poetry corner
Editor’s note: The KP News is offering a spot for poems submitted by Key Peninsula residents. Please keep them under 200 words and send them to Ed Johnson at firstname.lastname@example.org. We will try and run a poem in every issue.
Love, In a Garden Grows
By Sandy Rogers
Days begin with a walk to the little house.
I feel her presence there in the garden where
the beauty she brought is quietly displayed.
Stooping to pull a few weeds, I am compelled to work the ground
As the dirt and I become one
I feel, most likely a breeze, kiss my face
The chirping of the birds beckons me
I stroll, lost in my thoughts,
logical time slips away,
We are walking side by side, holding hands
I remember we planted this one on her birthday
Warmth surges through me
Squirrels dance at my feet,
I hear the shuffle of her walk
Hummers buzz playfully past my ears
I smile, she has whispered to me through them
The snowball tree is blooming already
We planted it together, along with the lilac bush and hydrangeas
Her garden was a place of joy for both of us
While she has gone, her spirit has not
It was her time in the garden then.
She left all these things,
cultivated by her love.
Now they all look to me for nurturing
I don’t have her knack
The garden and its residents are patient with me
In time, we all will grow
THE 10,000 Laughing
By Scott Heffernan
greet my arrival with thunderous approval.
I feel as they’ve been waiting for me,
just for me.
I take my place amongst them,
a seat upon the sand
and listen with all I am
to all they care to share
on this beautiful morn’;
What’s left of the full moon back-lights
the clouds and leaves its glow on endless waves.
Alive,
without interference;
even the wind has died.
The sun takes its time too,
knowing maybe,
that with its rising will come
the person
whom today,
I care nothing about.
This day is ours,
hers and mine.
She talks to me,
says, “It’s okay, I’m okay,
Go live your life.”
And if ever, now I know
Tao itself — the main concept in Taoism
—is presented by Lao Tzu as something
that cannot be described, that stands at
the origin of all things and beings (the
10,000 things) in the universe.
Last month, Mount Rainer was picture-perfect as it loomed over Henderson Bay.
Sunday evening, July 19, Key Peninsula Fire Department crews responded to reports of a large brush fire with structures threatened, near the Kitsap County border at 118th Avenue NW and 146th Street KP. According to a fire department spokeswoman, a multiple unit strike team, with crews and equipment from outside agencies, were called in to help battle the blaze. The 5-acre fire took about five hours to extinguish, and no homes or buildings were lost. At press time, there is no known origin of the fire.
This Pierce County crew spent their Monday cleaning up the beach on the Purdy Spit after a major fireworks display on the Fourth of July.
During the Fourth of July the Purdy Spit was a popular place to view fireworks.
|
Formalization of 2-D Spatial Ontology and OWL/Protégé Realization
Kulsawasd Jitkajornwanich
Computer Science and Engineering Department
Univ. of Texas at Arlington
P.O. Box 19015
Arlington, TX 76019
Tel. +1 253 205 1250
email@example.com
Ramez Elmasri
Computer Science and Engineering Department
Univ. of Texas at Arlington
P.O. Box 19015
Arlington, TX 76019
Tel. +1 817 272 0067
firstname.lastname@example.org
Chengkai Li
Computer Science and Engineering Department
Univ. of Texas at Arlington
P.O. Box 19015
Arlington, TX 76019
Tel. +1 817 272 0162
email@example.com
John McEnery
Department of Civil Engineering
Univ. of Texas at Arlington
P.O. Box 19308
Arlington, TX 76019
Tel. +1 817 272 0234
firstname.lastname@example.org
ABSTRACT
Ontology specification is a core component of the Semantic Web, and facilitates interoperability among different systems that use distinct models. Developing a spatial ontology will allow many applications that have spatial objects to interact. In this paper, we formalize 2-D spatial concepts and operations into a spatial ontology. We show how these concepts can be realized in Protégé [30]. The Protégé spatial ontology provides spatial built-ins that can be used to provide a spatial dimension to other ontologies when needed. We give some examples of the use of our ontology, which is based on a standard Geometry class hierarchy [23], with a few modifications.
Categories and Subject Descriptors:
H.2.8 [Database Management]: Database Applications – spatial databases and GIS; I.2.4 [Artificial Intelligence]: Knowledge Representation Formalisms and Methods – semantic networks.
General Terms: Design
Keywords: Ontology, spatial database, semantic web, Protégé
1. INTRODUCTION
Ontology [10, 20] is considered to be a core component of the Semantic Web [7]. With the reasoning, inferencing, and representation mechanisms associated with an ontology, it becomes possible that systems with different definitions of the same concepts can interoperate with each other. In addition, a nearly complete description of concepts in a particular area of knowledge becomes readily available for interested users. In this paper we focus on spatial ontology. Representing spatial knowledge is a basic problem in many applications, such as GIS and map applications. In the past few years, work on spatial ontologies has focused on two main areas: spatial database integration [8, 9, 12] and spatial ontology creation and its use in the semantic web [5, 29, 11, 14]. In spatial database integration, a spatial ontology is used as a tool to integrate different spatial databases. In spatial ontology creation, there are two different major approaches. First, by analyzing a collection of existing spatial databases and methodologies, a spatial ontology model is defined based on those databases [5]. However, this leads to the problem that the created spatial ontology will be limited to those databases and consequently will not be sufficient to be a standard for representing a complete formal spatial ontology. The second approach in spatial ontology creation is to define a complete spatial ontology model. For example, in [29], they propose to create a spatio-temporal ontology based on the MADS model, which allows a regular database to model spatial and temporal characteristics [24, 25]. However, this approach has not been materialized in an implemented system, and there is no formal specification of spatial ontology developed from this approach. In addition, it is limited to the polygon data type only. Thus, the complete set of operations among point, line, and polygon is lacking. Finally, in [11, 14], they propose using the RCC8 calculus [26] for spatial reasoning on regions, but they do not propose a complete spatial ontology, which is the ultimate goal of our work.
Our work gives a formal specification of spatial ontology, defines a complete collection of spatial operations, and provides a general spatial ontology implemented in Protégé. Many researchers have worked in the area of Temporal and Spatial Ontology [19, 29, 8, 5, 9, 18, 22, 13, 6, 12, 1, 4]. A specification of temporal ontology was introduced in [13]. It clearly discussed temporal ontology formalization, and comprehensively defines temporal concepts and operations. It is based on the temporal logic developed by Allen [2, 3]. The following is an example of the Meet operation between two time intervals formalized by [13], assuming that $T_1$, $T_2$ are two time intervals and $t$ is a time instant.
$$\text{Meet}(T_1, T_2) \equiv (\exists t)[\text{endst}(t, T_1) \land \text{begins}(t, T_2)]$$
A complete formalization of ontology forms the basis and reference for ontology implementation. In addition, since the temporal ontology specification in [13] was intended to capture all temporal reasoning on web pages, it is gradually becoming the standard for temporal ontology specification.
One of the main applications of spatial ontology is GIS applications. Although spatial concepts and operations have been specified in many works [23, 24, 25, 28, 31], there are few attempts at specifying a complete formal ontology for spatial concepts. Spatial operations are more complex than temporal operations, and can be defined over multiple dimensions, especially two and three dimensions, whereas temporal operations are only on one dimension. Figure 1 shows how the Meet operation is different in one dimension and two dimensions. Additionally, temporal operations have only two directions
(before and after) whereas for two dimensional spatial operations, there are continuous directions along $360^\circ$ of a two dimensional space. Figure 2 shows eight directions, at $45^\circ$ intervals. (East is $0^\circ$, north is $90^\circ$, west is $180^\circ$, etc.).
**Figure 1.** The difference of *Meet* operation in 1-D and 2-D
**Figure 2.** The difference of direction between temporal operation (1-D, left) and spatial operation (2-D, right)
In recent years, spatial or location-based applications have received a lot of attention. Examples include Google Maps and other location-based applications. One of the main advantages of having a spatial ontology specification is that such a specification acts as a conversion medium among various applications, which allows communication among different systems without requiring one system to know the exact description used by other systems.
**Figure 3.** An overview of our methodology
In this paper, we present preliminary results towards our long-term goal of a complete two-dimensional spatial ontology specification. We will first formalize the spatial ontology concepts and operation definitions, then discuss a method to add spatial dimension to existing ontologies. Particularly we use a technique similar to the “lightweight” temporal ontology introduced in [22] so that we can incorporate a spatial layer into existing ontologies without requiring significant changes to the original ontology. We also implement spatial built-ins in Protégé based on the concept and operation definitions in the spatial ontology formalization to do spatial reasoning, inferencing and querying on ontology. Figure 3 shows an overview of our methodology for spatial ontology development.
As mentioned earlier, spatial operations are much more complex than temporal operations. Therefore in this initial effort we will only focus on a subset of two-dimensional spatial operations. Considering spatial relationships, there are six major types as follows: (1) Point VS Point, (2) Point VS Line, (3) Point VS Polygon, (4) Line VS Line, (5) Line VS Polygon, and (6) Polygon VS Polygon. In this paper only spatial relationships between Point and Line (i.e., (1), (2), and (4)) are covered. Other relationships will be covered in future work.
The rest of the paper is organized as follows. Section 2 discusses the spatial ontology formalization consisting of spatial concept definitions and spatial operation definitions. Section 3 discusses how the defined ontology is implemented in Protégé, along with some small examples to show how it works. Section 4 presents conclusion and future work.
## 2. SPATIAL ONTOLOGY FORMALIZATION
### 2.1 Formalization of Concept Definitions
In [23], a geometry class hierarchy is proposed for 2-D objects. The hierarchy shown in Figure 4 is based on the one in [23], with some minor modifications to allow our formalization.
**Figure 4.** Geometry class hierarchy
Considering the leaf nodes in the hierarchy of Figure 4, the geometry objects can be categorized into 8 types as shown in Figure 5.
1. **Point ($p$)**
2. **Single Line ($sl$)**
3. **Connected Line ($cl$): Non-Ring ($nr$)**
4. **Connected Line ($cl$): Ring ($r$)**
5. **Polygon ($a$)**
6. **MultiPoint ($mp$)**
7. **MultiCurve ($mc$)**
8. **MultiPolygon ($ma$)**
**Figure 5.** Types of geometry object in 2-D space
Our proposed spatial ontology consists of two parts: concept definitions and operation definitions. The following is the formalization of concept definitions.
In order to be used in the ontology, the concept definitions of all geometry object types in two-dimensional space (see Figure 4 and 5) have to be defined. For simplicity, we shall assume the 2-D coordinate system based on longitude and latitude, although the formalization can be adapted to other 2-D coordinate systems.
1. **Point ($p$)**
Point can be defined by longitude($x$) and latitude($y$).
\[ \text{Point}(p) \equiv (x, y) \text{ where } x = \text{longitude} \text{ and } y = \text{latitude} \]
2. **Single Line ($sl$)**
Single line can be defined by any two points.
\[ \text{SingleLine}(sl) \equiv (p_1, p_2); \ p_1, p_2 \text{ are points and } p_1 \neq p_2. \]
3. **Connected Line ($cl$): Non-Ring ($nr$)**
Non-ring connected line can be defined by a sequence of points $(p_1, p_2, ..., p_N), N \geq 3,$ and $p_i \neq p_j$ for $i \neq j$, which in turn defines a sequence of single lines $(sl_1, sl_2, ..., sl_{N-1})$ and each $sl_i = (p_i, p_{i+1})$.
In other words, the sequence must contain at least two single lines and each $p_i$ is connected to $p_{i+1}$ for $i < N$.
$NonRingConnectedLine(cl.nr) \equiv (p_i | 1 \leq i \leq N, N \geq 3, p_i \neq p_j$ for $i \neq j, sl_i = (p_i, p_{i+1}), Meet(sl_i, sl_{i+1}) = true$ for $i = 1, ..., N - 1)$
4. **Connected Line (cl): Ring (r)**
Ring connected line is defined as a sequence of points $(p_1, p_2, ..., p_N), N \geq 3$, and $p_i \neq p_j$ for $i \neq j$, which in turn defines a sequence of single lines $(sl_1, sl_2, ..., sl_N)$ where each $sl_i = (p_i, p_{i+1})$ for $i = 1, 2, ..., N-1$ and $sl_N = (p_N, p_1)$. However, the area inside the ring is not part of the connected line.
$RingConnectedLine(cl.r) \equiv (p_i | 1 \leq i \leq N, N \geq 3, p_i \neq p_j$ for $i \neq j, sl_i = (p_i, p_{i+1})$ for $i = 1, 2, ..., N - 1$ and $sl_N = (p_N, p_1), Meet(sl_i, sl_{i+1}) = true$ for $i = 1, ..., N - 1, Meet(sl_N, sl_1) = true,$ and $area(r) = 0)$
5. **Polygon (a)**
Polygon is defined as a sequence of points $(p_1, p_2, ..., p_N), N \geq 3$, and $p_i \neq p_j$ for $i \neq j$, which in turn defines a sequence of single lines $(sl_1, sl_2, ..., sl_N)$ where each $sl_i = (p_i, p_{i+1})$ for $i = 1, 2, ..., N-1$ and $sl_N = (p_N, p_1)$, and the area within is part of the polygon.
$Polygon(a) \equiv (p_i | 1 \leq i \leq N, N \geq 3, p_i \neq p_j$ for $i \neq j, sl_i = (p_i, p_{i+1})$ for $i = 1, 2, ..., N - 1$ and $sl_N = (p_N, p_1), Meet(sl_i, sl_{i+1}) = true$ for $i = 1, 2, ..., N - 1, Meet(sl_N, sl_1) = true, Cross(sl_i, sl_j) = false$ for all $i, j$ where $i \neq j$, and $area(a) \neq 0)$
6. **MultiPoint (mp)**
MultiPoint can be defined as a set of two or more points.
$MultiPoint(mp) \equiv \{p_i | 1 \leq i \leq N, N \geq 2\}$
7. **MultiCurve (mc)**
MultiCurve can be defined as a set of single line(s) or connected line(s).
$MultiCurve(mc) \equiv \{c_i | c_i = sl \lor c_i = cl; 1 \leq i \leq N, N \geq 2\}$
8. **MultiPolygon (ma)**
MultiPolygon is defined as a set of two or more polygons.
$MultiPolygon(ma) \equiv \{a_i | 1 \leq i \leq N, N \geq 2\}$
### 2.2 Formalization of Operation Definitions
As mentioned earlier, we only present the relationships and operations related to lines and points in this paper. We can divide these operation definitions into six different categories depending on the pair of spatial objects.
1. Point and Point
2. Point and Single Line
3. Single Line and Single Line
4. Point and Connected Line
5. Single Line and Connected Line
6. Connected Line and Connected Line
#### 2.2.1 Point and Point
There is only one relationship between point and point.
1. **Equal**
Two points are equal if and only if they have exactly the same longitude and latitude respectively.
$Equal(p_1, p_2) \equiv p_1.x = p_2.x \land p_1.y = p_2.y$
#### 2.2.2 Point and Single Line
Considering point and single line, there are two possible spatial operations: *Endpoint* and *Ontheline*.
1. **Endpoint**
$Endpoint$ is a relationship between point and single line. In the formalization, we sometimes need to distinguish unambiguously the two endpoints so we define two operations on a line: $EndpointNe$ and $EndpointSw$. North and south will have precedence in distinguishing the endpoints and east and west will be used only if a line is horizontal. That is, the end point of the line with higher latitude will be classified as $EndpointNe$ regardless of whether the longitude is either east or west. Figure 6(a) shows some examples of how the endpoints are categorized.
A point $p$ will be an endpoint of single line $sl$ if and only if $p$ is equal to either one of the single line endpoints.
$Endpoint(p, sl) \equiv p = sl.p_1 \lor p = sl.p_2$
$EndpointNe(p, sl) \equiv Endpoint(p, sl) \land (\exists p_1)[Endpoint(p_1, sl) \land p \neq p_1 \land ((sl.p.y > sl.p_1.y) \lor (sl.p.y = sl.p_1.y \land sl.p.x > sl.p_1.x))]$
$EndpointSw(p, sl) \equiv Endpoint(p, sl) \land (\exists p_1)[Endpoint(p_1, sl) \land p \neq p_1 \land ((sl.p.y < sl.p_1.y) \lor (sl.p.y = sl.p_1.y \land sl.p.x < sl.p_1.x))]$
The relationship between $EndpointNe$ and $EndpointSw$ can be specified as follows:
$EndpointNe(p_1, sl) \land EndpointSw(p_2, sl) \rightarrow [(sl.p_1.y_1 > sl.p_2.y_2) \lor (sl.p_1.y_1 = sl.p_2.y_2 \land sl.p_1.x_1 > sl.p_2.x_2)]$
We can now define two unary operations on single line, $slope$ and $distance$, as follows (these are used in our specification of some of operations):
$Slope(m, sl) \equiv EndpointNe(p_1, sl) \land EndpointSw(p_2, sl) \land m = [(p_1.y - p_2.y)/(p_1.x - p_2.x)]$
$Distance(d, sl) \equiv EndpointNe(p_1, sl) \land EndpointSw(p_2, sl) \land d = [squareroot((p_1.y - p_2.y)^2 + (p_1.x - p_2.x)^2)]$
2. **Ontheline**
$Ontheline$ (see Figure 6(d)) is a relationship between point and single line. If a point $p$ is on the single line $sl$ then the slope of the point $p$ to one of the endpoints of the single line must be equal to the slope of the single line. In addition, the point $p$ has to fall on the single line. We also have a function to create a single line given two points: $CreateSingleLine(sl,x,y)$ where $sl$ is the created single line and $x,y$ are the two endpoints.
$Ontheline(p, sl) \equiv Slope(m_1, sl) \land CreateSingleLine(sl_1, p, sl.p_1) \land Slope(m_2, sl_1) \land m_1 = m_2 \land (sl.p_1.x_1 \leq p.x \leq sl.p_2.x_2 \lor sl.p_2.x_2 \leq p.x \leq sl.p_1.x_1)$
An endpoint is also considered to be on the line.
$Endpoint(p, sl) \rightarrow Ontheline(p, sl)$
#### 2.2.3 Single Line and Single Line
There are five main relationships between single lines.
1. **Equal**
Two single lines are equal if and only if they have exactly the same points.
$Equal(sl_1, sl_2) \equiv sl_1.p_1 = sl_2.p_1 \land sl_1.p_2 = sl_2.p_2$
2. **Meet**
Two single lines meet when they share one endpoint. We can further divide the operation into two more cases: $MeetSameSlope$ and $MeetDiffSlope$ as follows (see Figure 6(b,c)).
$Meet(sl_1, sl_2) \equiv (\exists p \in \{sl_1.p_1, sl_1.p_2, sl_2.p_1, sl_2.p_2\})$
$[Endpoint(p, sl_1) \land Endpoint(p, sl_2)]$
$MeetSameSlope(sl_1, sl_2) \equiv Meet(sl_1, sl_2) \land Slope(m_1, sl_1) \land Slope(m_2, sl_2) \land m_1 = m_2$
\[ \text{MeetDiffSlope}(sl_1, sl_2) \equiv \text{Meet}(sl_1, sl_2) \land \text{Slope}(m_1, sl_1) \land \text{Slope}(m_2, sl_2) \land m_1 \neq m_2 \]
### 3. Cross
Two single lines cross when their slopes are different and the intersecting point fall on both lines (see Figure 6(e)). To make formalization easier, we will first define \( \text{Between} \) and \( \text{ProperBetween} \) relations as follows. We also have an operation \( \text{IntersectPoint}(p, sl_1, sl_2) \) that returns the point of intersection \( p \) between two single lines \( sl_1, sl_2 \), if the two lines do not have the same slope. We do not show this because of limited space.
\[
\begin{align*}
\text{Between}(x, x_1, x_2) & \equiv (x_1 \leq x \leq x_2 \lor x_2 \leq x \leq x_1) \\
\text{ProperBetween}(x, x_1, x_2) & \equiv (x_1 < x < x_2 \lor x_2 < x < x_1) \\
\text{Cross}(sl_1, sl_2) & \equiv \text{Slope}(m_1, sl_1) \land \text{Slope}(m_2, sl_2) \land m_1 \neq m_2 \land \text{IntersectPoint}(p, sl_1, sl_2) \land \text{Between}(p, x, sl_1, p_1, x, sl_1, p_2, x) \land \text{Between}(p, x, sl_2, p_1, x, sl_2, p_2, x)
\end{align*}
\]
\[
\begin{align*}
\text{ProperCross}(sl_1, sl_2) & \equiv \text{Slope}(m_1, sl_1) \land \text{Slope}(m_2, sl_2) \land m_1 \neq m_2 \land \text{IntersectPoint}(p, sl_1, sl_2) \land \text{ProperBetween}(p, x, sl_1, p_1, x, sl_1, p_2, x) \land \text{ProperBetween}(p, x, sl_2, p_1, x, sl_2, p_2, x)
\end{align*}
\]
In this operation, we have one special case when the intersecting point is also one of the endpoints of the line. In other words, one of the endpoints of a line lies on the other line. We will call this case of operation \( \text{TCross} \) (see Figure 6(f)).
\[
\text{TCross}(sl_1, sl_2) \equiv (\exists p)[(\text{Endpoint}(p, sl_1) \land \text{Ontheline}(p, sl_2) \land \neg \text{Endpoint}(p, sl_2)) \lor (\text{Endpoint}(p, sl_2) \land \text{Ontheline}(p, sl_1) \land \neg \text{Endpoint}(p, sl_1))]
\]
### 4. Overlap
Two single lines overlap if and only if their slopes are equal and there is one endpoint lying in another line (see Figure 6(g)).
\[
\begin{align*}
\text{Overlap}(sl_1, sl_2) & \equiv \text{CreateSingleLine}(sl_3, sl_1, p_1, sl_2, p_2) \land \text{Slope}(m_3, sl_3) \land \text{Slope}(m_1, sl_1) \land \text{Slope}(m_2, sl_2) \land m_1 = m_2 = m_3 \land (\exists p)[(\text{Endpoint}(p, sl_1) \land \text{Between}(p, x, sl_1, p_1, x, sl_1, p_2, x)) \lor (\text{Endpoint}(p, sl_2) \land \text{Between}(p, x, sl_1, p_1, x, sl_1, p_2, x))]
\end{align*}
\]
### 5. Within
For \( \text{Within} \) operation, we can divide it into two more types: \( \text{CompleteWithin} \) and \( \text{SharedEndpointWithin} \) (see Figure 6(h,i)).
\[
\begin{align*}
\text{CompleteWithin}(sl_1, sl_2) & \equiv \text{CreateSingleLine}(sl_3, sl_1, p_1, sl_2, p_2) \land \text{Slope}(m_3, sl_3) \land \text{Slope}(m_1, sl_1) \land \text{Slope}(m_2, sl_2) \land m_1 = m_2 = m_3 \land (\forall p)[(\text{Endpoint}(p, sl_1) \land \text{Between}(p, x, sl_1, p_1, x, sl_1, p_2, x)) \lor (\text{Endpoint}(p, sl_2) \land \text{Between}(p, x, sl_1, p_1, x, sl_1, p_2, x))]
\end{align*}
\]
\[
\begin{align*}
\text{SharedEndpointWithin}(sl_1, sl_2) & \equiv \text{CreateSingleLine}(sl_3, sl_1, p_1, sl_2, p_2) \land \text{Slope}(m_3, sl_3) \land \text{Slope}(m_1, sl_1) \land \text{Slope}(m_2, sl_2) \land m_1 = m_2 = m_3 \land (\exists p_1, p_2)[(\text{Endpoint}(p_1, sl_1) \land \text{Endpoint}(p_2, sl_2)) \land ((\text{Endpoint}(p_2, sl_1) \land \text{Between}(p_2, x, sl_2, p_1, x, sl_2, p_2, x)) \lor (\text{Endpoint}(p_2, sl_2) \land \text{Between}(p_2, x, sl_1, p_1, x, sl_1, p_2, x)))]
\end{align*}
\]
\( \text{Within} \) operation is also considered as \( \text{Overlap} \) and \( \text{SharedEndpointWithin} \) can be considered as \( \text{CompleteWithin} \).
\[
\begin{align*}
\text{CompleteWithin}(sl_1, sl_2) \lor \text{SharedEndpointWithin}(sl_1, sl_2) & \rightarrow \text{Overlap}(sl_1, sl_2) \\
\text{SharedEndpointWithin}(sl_1, sl_2) & \rightarrow \text{CompleteWithin}(sl_1, sl_2)
\end{align*}
\]
\( \text{Meet}, \text{Cross}, \text{Overlap}, \) and \( \text{Within} \) operations are also considered as \( \text{Intersect} \).
\[
\begin{align*}
\text{Meet}(sl_1, sl_2) \lor \text{Cross}(sl_1, sl_2) \lor \text{Overlap}(sl_1, sl_2) \lor \text{Within}(sl_1, sl_2) & \rightarrow \text{Intersect}(sl_1, sl_2)
\end{align*}
\]
For the remaining sections, we list all the operations, but give formalization for only some due to space limitations. The full formalization is in [17].
### 2.2.4 Point and Connected Line
In the following, we will discuss the formalization of spatial operations between point and connected line. Considering point and connected line, there are three possible spatial operations: \( \text{Endpoint}, \text{InteriorEndpoint} \) and \( \text{Ontheline} \).
1. **Endpoint** (see Figure 6(j))
2. **InteriorEndpoint**
\( \text{InteriorEndpoint} \) (see Figure 6(k)) is another relationship between point and connected line when a point falls in the joint between two single lines of connected line.
\[ \text{InteriorEndpoint}(p, cl) \equiv (\exists p_1 \in \{cl, p_i; i \neq 1, N\})[p = p_1] \]
3. **Ontheline** (see Figure 6(l))
### 2.2.5 Single Line and Connected Line
1. **Meet** (see Figure 6(m))
2. **Cross**
A single line \( sl \) and connected line \( cl \) cross if and only if there is a single line \( sl_i \) of connected line \( cl \) crossing the single line \( sl \) (see Figure 6(o)).
\[ \text{Cross}(sl, cl) \equiv (\exists sl_i \in cl, sl_i)[\text{Cross}(sl, sl_i) \lor (\text{TCross}(sl, sl_i) \land (\exists p_1)[\text{Endpoint}(p_1, sl_i) \land \text{Ontheline}(p_1, sl) \land \neg \text{Endpoint}(p_1, cl)])] \]
3. TCross (see Figure 6(p))
4. Overlap (see Figure 6(n))
5. Within:
5.1 CompleteWithin (see Figure 6(q))
5.2 SharedEndpointWithin (see Figure 6(r))
2.2.6 Connected Line and Connected Line
1. Equal
2. Meet (see Figure 6(s))
3. Cross (see Figure 6(u))
4. TCross (see Figure 6(v))
5. Overlap
A connected line $cl_1$ and connected line $cl_2$ overlap when their single lines are overlapped (see Figure 6(t)).
$$Overlap(cl_1, cl_2) \equiv (\exists sl_i \in cl_1, sl_i \in cl_2, sl_j)[Overlap(sl_1, sl_2) \lor Equal(sl_1, sl_2)]$$
6. Within:
6.1 CompleteWithin (see Figure 6(w))
6.2 SharedEndpointWithin (see Figure 6(x))
3. OWL/Protégé Realization
Protégé [30] is a well-known and widely-used open-source platform for ontology management including creation, visualization, and manipulation of ontology [15]. Moreover, Protégé is also user-friendly and domain-customizable because it allows user-defined or imported plug-ins.
3.1 Adding Spatial Dimension to Ontology
We use our formal specification of spatial ontology and adopt one of the approaches proposed in [22] for adding temporal dimension to existing ontologies. Figure 7 gives an overview of our approach.
In Figure 7, SProposition2D class has $hasGeoShape$ relationship with SGeometry class, which contains geometry types: point, single line, non-ring connected line, and ring connected line. Point consists of two numbers: longitude and latitude. Single line consists of exactly two points. Connected line consists of three points or more. There are two types of connected lines: non-ring and ring. $hasDistance$ is a relationship between SGeometry class and DistanceUnit class. DistanceUnit contains the units of distance measurements such as km., mile, yard, etc.
The principle is that any class in need of spatial dimension will be added as a subclass of SProposition2D class. Consequently, the class will automatically have $hasGeoShape$ property that enables a class entity to be modeled as one of the spatial data types.
An example is shown in Figure 8. Suppose we have a yellow page ontology which contains contact information of individuals, businesses, parks, train rails, roads and highways, etc. We would like to add a spatial dimension to it. As a result, we will add house, park, train rail, road and highway classes to be subclasses of SProposition2D class as shown in Figure 7 so that those classes will have spatial features of one of the spatial data types. In this example, houses and schools are modeled as points, roads and highways are modeled as connected lines, and parks are modeled as polygons. The choice of geometry type depends on the application scenarios.
In Protégé, we define a point by two functional datatype properties, $hasX$ and $hasY$ of type float. A point is used to model an entity which does not have area. A single line is defined by exactly two distinct points. $hasP1$ and $hasP2$ are functional object properties of a single line. A connected line is defined as a list of three or more ordered points. $hasList$ is a functional datatype property of a connected line, of type string, which has a following string pattern.
$$\{n, p_1, p_2..., p_n\}$$
where $n$ is number of points, $n \geq 3$ and $p_i$ is point $i$.
These string patterns will be eventually parsed by Protégé built-ins into a number of point instances.
3.2 Developing Spatial Built-ins in Protégé
According to Figure 3, for spatial reasoning, inferencing, and querying in Protégé, we develop the spatial operations as Protégé built-ins based on our formalization of spatial operations. We implemented 33 major spatial operations along with additional 6 utility built-ins in Protégé as shown in Table 1 and 2.
Spatial built-ins can be divided into six categories depending on the combinations of geometry data types: point versus point, point versus single line, point versus connected line, single line versus single line, single line versus connected line, and connected line versus connected line. At this point, polygon data type is left for future work.
In our notation, 1 represents point, 2 represents single line, and 3 represents connected line (non-ring and ring), which are appended to the operation (built-in) name. When defining a spatial rule in Protégé, the built-ins have to be specified as the following pattern:
$$spatial:<BuiltInName>XX(<GeoTypeX>,<GeoTypeY>)$$
where X and Y are ordered number corresponding to geometry data types.
Table 1. 33 major spatial built-ins
| Spatial Built-ins | Point(1) | Single Line(2) | Connected Line(3) [Non-Ring & Ring] |
|-------------------|----------|---------------|-------------------------------------|
| **Point(1)** | Equal | Endpoint | Endpoint* |
| | | EndpointNe | EndpointNe* |
| | | EndpointSw | EndpointSw* |
| | | Ontheline | Ontheline |
| | | | InteriorPoint |
| **Single Line(2)**| Equal | Meet* | Cross |
| | | Meet | TCross |
| | | Cross | Overlap |
| | | Within: | Within: |
| | | - Complete | - Complete |
| | | - SharedEndpoint | - SharedEndpoint* |
| | | Intersect | Intersect |
| **Connected Line(3)** | Equal | Meet* | Cross |
| [Non-Ring & Ring] | | Meet | TCross |
| | | Cross | Overlap |
| | | Within: | Within: |
| | | - Complete | - Complete |
| | | - SharedEndpoint | - SharedEndpoint* |
| | | Intersect | Intersect |
*Operations apply only on non-ring connected lines.
Table 2. 6 additional utility built-ins
| Additional Built-ins | Slope, IntersectPoint, Between, ProperBetween, Distance (in km.), CreateSingleLine |
|----------------------|-------------------------------------------------------------------------------------|
For example, to define an *Endpoint* built-in of point and single line, we specify:
```plaintext
spatial:endpoint12(<point>,<single line>)
```
This is because different combinations of geometry data types have different ways of implementing the same operation. As a result, we need to indicate the exact operation we are using.
### 3.3 Spatial Reasoning, Inferencing and Querying
Once we have a spatial dimension added to an ontology and have spatial built-ins ready in Protégé, we can do spatial reasoning, inferencing and querying.
We enable spatial reasoning by defining rules in SWRL Tab [30], and we use the Jess® [27] rule engine to perform inferencing on those rules. Spatial built-ins that we developed can be combined with other built-in libraries such as SWRLB [16], TEMPORAL [22], and SQWRL [21], to create complicated rules or queries [21].
The following example shows how spatial built-ins can be used in reasoning and inferencing. Suppose we have 2 houses, 1 school and 2 roads as illustrated in Figure 9. We would like to define a rule regarding a school zone. Suppose, we define a location in a school zone as a point within 3 kilometers radius centered at a school. This definition can be implemented in Protégé by the following rule:
```plaintext
Point(?p)\hasX(?p,?px)\hasY(?p,?py)\School(?s)\hasGeoShape(?s,?ps)\hasX(?ps,?sx)\hasY(?ps,?sy)\spatial:distance(?d,?px,?py,?sx,?sy)\swrlb:lessthan(?d,3) \rightarrow SchoolZonePoints(?p)
```
For the next example, we would like to define highway-connected local roads as local roads that intersect with any highway at some point. The corresponding rule is:
```plaintext
Roads(?r)\hasGeoShape(?r,?clr)\hasList(?clr,?rl)\Highways(?h)\hasGeoShape(?h,?clh)\hasList(?clh,?hl)\spatial:Intersect33(?rl,?hl) \rightarrow HighwayConnectedLocalRoads(?r)
```
When we use Jess®, the above rules will classify points ?p and roads ?r as SchoolZonePoints and HighwayConnectedLocalRoads respectively if they satisfy the rules above.
### 4. CONCLUSION AND FUTURE WORK
#### 4.1 Conclusion
In conclusion, this paper presents a spatial ontology formalization and a method to add spatial dimension to existing ontologies. Then, we develop spatial built-ins to be used for spatial reasoning in Protégé. To process reasoning and inferencing we use SWRL Tab and Jess® rule engine. To do querying, we use built-ins from SQWRL library [21] along with SQWRL Query Tab [30]. With all components presented in this paper, they allow us to add spatial dimension to ontologies through the Protégé framework and make them able to capture and reason about spatial concepts.
#### 4.2 Future work
This paper is an initial process which does not include the polygon data type. In the future, we will add a spatial polygon data type and also develop spatial built-ins for it in Protégé. In addition, we will continue to define formalizations of distance and area measurements. Finally, we also would like to develop a technique by which the spatial ontology formalization can play a role as a medium to convert spatial concepts from one system to another.
### 5. ACKNOWLEDGEMENTS
The authors would like to thank Martin O’Connor for his help with Protégé issues. This work was conducted using the Protégé resource, which is supported by grant LM007885 from the United States National Library of Medicine. The authors also would like to thank Sandia National Laboratories for providing Jess® [27] for this work. (Jess is not available for Open Source licensing under any GPL license. To license and download Jess, please visit the Jess website at: www.jessrules.com).
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|
Dear League of Utah Writers
In 1978, a phenomenal distance swimmer named Diana attempted something that no one had managed to accomplish previously, swim from Cuba to Florida. This remarkable woman had already set a record swimming 28 miles in seven hours, and fifty-seven minutes just a few years earlier.
On Sunday August 13th, 2PM at the age of 28 years old, she dove into the water and began her swim in the safety of a 20-by-40 foot steel shark cage. Forty-two hours and seventy-six miles later her small team of doctors elected to pull her from the water. The currents and waves had pushed her too far off course towards Texas that it was apparent that she wouldn’t be able to make it.
I imagine it was such a catastrophic blow, having been so physically and emotionally exhausted after such an attempt. A supreme effort in the prime of life surrounded by trusted friends and associates, without reward. As writers, we physically and emotionally pour ourselves into the long-distance marathon that make up our works. We give everything we got. When we run into the pile of rejection letters, or being shot down after a confident pitch, and our family or peers pull us back because we have drifted too far off course, we are so spent it is tempting to give up, and some of us do.
Diana wouldn’t jump back into the water at Cuba again until August 7, 2011, 33 years after her initial attempt. This time she upgraded her team and improved her tools. When that attempt failed, she tried again September 23rd, 2011, and again on August 18th, 2012. Each time upgrading her team, and tools.
On August 31st, 2013, at the age of 64, she would jump into the water at Cuba. Covering the one hundred and ten miles in fifty-three hours. Diana emerged from the ocean to make her way onto the beach, spectators waded into waist-high water and surrounded her, cheering her on. Exiting the water reporters clamored for a comment, and she said, “I have three messages. One is, we should never, ever give up. Two is, you’re never too old to chase your dream. Three is, it looks like a solitary sport, but it is a team.”
Continued
Jared Quan
President, LUW
The team she was referring to was the 35 person team that was with her the whole way. She made this attempt without a shark cage, but had an electronic shark repellent known as a shark shield which was mounted on one of the three kayak that stayed by her side. There was a jellyfish specialist that stayed ahead of the swimmer, helping the innocent but dangerous creatures out of the way. There were divers swimming under her to make sure no sharks or dangerous creatures ventured too close. A medical team that constantly monitored her vital signs, paired with a nutritionist that made sure she was hydrated and had enough protein.
Being a writer is like Diana said, it looks like a solitary sport, but it is a team. Who you surround yourself with, and what tools you have available. Having specialists like she did can make the difference between success and unnecessary frustration. The friends and family, to stay close to us throughout the venture. The critiquing group, to help you stay sharp, and on course. The writing group, to encourage, push you, making sure your vitals are good, and you are well hydrated. The editor, the specialist who helps you avoid the dangerous writing obstacles that can sabotage us. The beta readers, to support us at the end with final details, and support.
If you are missing someone on your team, or are looking for tools to help you make it to the end, please let the people around you know. We are all in this together.
“you tell me what your dreams are. What are you chasing? It's not impossible. Name it.” – Diana Nyad
Thank you,
Jared Quan
Writer of the Year
I'll never forget that night. It was the final evening of an amazing League Roundup conference. I was relaxing over a delicious banquet dinner, recalling great speakers, fun visits with friends and valuable insights that taught me more about how to be a writer. Someone began reading the description of the writer who was to be awarded the Writer of The Year. Suddenly, I realized that the description was starting to sound a little bit like me. I listened closer. The description continued to sound like me. Everything the speaker said was something that applied to me. I couldn't believe it. At the end of the narrative, the speaker called my name. I was the new Writer of The Year. I still recall the chills that I felt. I will always remember the thrill that this honor brought me.
Being Writer of the Year is a valuable credential that you never lose. It looks great on a resume. It's a fun fact to tell people. Lots of people notice the plaque above your desk. Your name is always on the League website and in the League directory. It's an accomplishment that pays tribute to your success. Now it's time for all of us League members choose a new Writer of the Year.
The Writer of the Year award celebrates the success of the member who has had the best year as a writer. If you know someone whose book/ books have really taken off, or someone who has landed a prestigious writing job or teaching position, please send your nomination to email@example.com for consideration. Please include any and all writing credits. Nominations must be received by July 31.
Writer of the Year nominations are open to all members of the League. Self nominations will also be accepted. Nominees must be members in good standing at the time of the nomination.
Carolyn Campbell, Writer of the Year Chair
Silver Quill Winner
Non-Fiction
Tom Garrison
*Hiking Southwest Utah and Adjacent Areas*
**Blurb:**
This guide is about hiking and generally exploring desert areas, specifically southwest Utah and adjacent areas (southern Nevada and northern Arizona). There is no better way to experience the ruggedness and beauty, the history of settlement by Native Americans and later pioneers, and the solitude than by simply hiking and exploring. The purpose in writing this book is to enhance the enjoyment of all who wish to sample the richness of southwest Utah and adjacent areas.
**Bio:**
Tom Garrison has explored and hiked the American Southwest for more than 25 years. His wife, Deb Looker, accompanied him on all those treks and every hike in this book.
**What advice would you give to non-fiction writers just starting out?**
First, check and recheck every fact. I write hiking stories (and other non-fiction) and providing incorrect directions to a trailhead could lead to serious problems for the person using my story to find a trail and great embarrassment to me.
Second, unless demanded by the subject or format, let your enthusiasm for your topic show. No one who reads my stories has any doubt about my enthusiasm for the outdoors.
Third, write to be published. If no one other than judges in a writing contest or friends and fellow writers read your work, what has been accomplished? You might feel good about your work, but so what? Virtually everything I write is published. (More than 85 published articles and four books in the last six years.) Pick a media outlet (e.g., newspapers, magazines, a serious and often used website, etc.) and write an article they can't refuse. I write to inspire people to get out and enjoy nature with my hiking stories and to influence readers with my political/social commentary essays. I also write humorous essays to give readers a smile and a few yucks. For me, writing is too much work to be shared with only a handful of readers.
Silver Quill Winner
Adult Novel
E.B. Wheeler
Born to Treason
FROM THE AWARD-WINNING AUTHOR
OF THE HAUNTING OF SPRINGETT HALL
Will Joan betray her country, or her faith?
Born to TREASON
E. B. WHEELER
Blurb:
Joan Pryce is not only a Catholic during the English Reformation but also Welsh, and comes from a family of proud revolutionaries. But when a small act of defiance entangles her in a deadly conspiracy, a single misstep may lead her straight to the gallows. Now, Joan must navigate a twisting path that could cost her life, her freedom, and her chance of finding love.
Bio:
E.B. Wheeler is the author of The Haunting of Springett Hall, No Peace with the Dawn (with Jeff Bateman) and Whitney finalist Born to Treason, as well as several short stories, magazine articles, and scripts. She's the League's 2016 Writer of the Year. In addition to writing, she consults about historic preservation and teaches history at USU.
How do you handle discouraging moments as an author?
Chocolate and good writing buddies. I think it helps to remember that everyone has to slog through some mucky spots on their writing journeys. If we have a passion for storytelling or wordsmithing, we'll still hit those rough patches, but that passion can see us through to where things get brighter again - we just have to keep going. I try to write every day, even if I'm dealing with discouragement or self-doubt, but I think it's okay to take a few days off sometimes to get things back in perspective and let our creativity bounce back.
Community Outreach Project
The LUW is pleased to continue its community outreach efforts throughout the coming year.
**Book drive:**
Please continue to gather books for donation. We are partnering with an organization called Empowered Playground that collects books to send to Africa. We will collect books during the Fall Conference as well as Spring into Books.
One thousand books make a functioning school library in the schools that are built in remote areas of Ghana—places without electricity. The children work all day in the farm fields and now, thanks to Empower Playgrounds, the playground equipment generates electricity to charge lanterns so children have the evenings to study and read. But they need books! Please bring your new or gently used children's books to Spring into Books. (Sat. May 20th, 2-6 PM) Books for grades Kindergarten to 6th; please, no adult books or reference books.
See [empoweredplaygrounds.org](http://empoweredplaygrounds.org) for more information
Let’s show them that LUW is committed to creating readers around the world!
Karla Jay
Community Outreach Chair
---
A big thanks to everyone who participated in the Spring Conference. It was a great success, thanks to all of you!
Summer Prequel Workshops
June 3rd
Editing
On June 3rd the League will be continuing its Summer Prequel workshops, offering an advanced editing course for authors looking to take their writing to the professional level. Whether the goal is traditional or self-publishing, the process of editing can be daunting for both seasoned veterans and beginners alike. Building on the successes and opportunities of last year, 2017’s editing workshop will include both presentations and a hands-on workshop to help writers understand and practice the intricacies of editing. Editing your own work is unavoidable. We want to make that process as easy (dare we say fun?) as possible. Class space is limited, and a ticket purchased provides a discount to our year-end Fall Conference. More details to follow on the website.
July 29th
Marketing
On July 29th, the League is offering a second Summer Prequel workshop focusing on marketing. Whether indie-, self-, or traditionally published, effective marketing is key to distribute your work and gain the widest possible readership. Authors need to be able to market themselves without drowning their followers in endless self-promotion. This advanced course will feature expert presentations and panels on how to harness author websites, mailing lists, social media, and more to widen your audience and get on their list of auto-buy authors. Class space is limited, and a ticket purchased provides a discount to our year-end Fall Conference in October. More details to follow on our website.
Need your tie dye fix?
Johnny Worthen is teaching a 6 week class called Writing for Young Adult at the University of Utah for Lifelong Learning
Writing for Young Adults
Tuesday Nights (6 sessions)
May 16th — June 27th
(No class on June 6th)
6:30-8:30 p.m.
WRITING FOR YOUNG ADULTS (LLWRC 850) From Catcher in the Rye to The Hunger Games, 'YA fiction' seeks to address the problems and transitions of its target audience -- while also having the potential to captivate adult readers the world over. Discover the secrets of what makes fiction 'young adult', and what makes great YA fiction, from an award-winning author of the genre. Learn how to appeal to the 'gatekeepers' (the adults who help guide the young adult reader), avoid genre taboos, and how to manage the responsibilities as an author whose work can impact its reader unlike any other genre.
Link: https://continue.utah.edu/lifelong/class/llwrc_850_writing_for_young_adults
Space is limited.
The League of Utah Writers 2017 Writing Contest is Here!
This is a list of categories that are eligible for the contest this year.
Please go to the League of Utah Writers website for more information.
**Poetry**
**Love/Loss**
Any style of poem in which the primary theme is one of love, loss, or both
-2 pages max
-Fiction or Non-Fiction
**Light Verse**
Verse with playful themes written primarily to please, amuse, and entertain
-rhyming, metrical, and/or humorous
-40 lines
-Fiction and Non-Fiction
**Narrative Poetry**
Poetry that tells a story. It is usually dramatic, with objectives, diverse characters, and meter
-Open or closed form
-2 pages max
-Fiction or Non-Fiction
**Prose Poem**
Prose poetry is written like prose, abandoning the lines breaks of poetry, but retaining poetic elements such as vivid imagery, metaphor, and heightened expression
-2,000 words
-Fiction and Non-Fiction
**Prose**
**Creative Non-Fiction**
Factually accurate prose about real people and events, written in a compelling, vivid, dramatic manner
-5,000 words
-Non-Fiction
**Media Article**
Any story or article intended for a magazine, journal, or website
-3,000 words
-Fiction and Non-Fiction
**Humor**
Written primarily to amuse. May be of any topic, theme, or genre
-3,000 words
-Fiction or Non-Fiction
Short Fiction
Stories that explore themes such as the human condition, interpersonal relationships, and societal issues. May also be described as "short story," "literary fiction," "straight fiction, or "up-market fiction"
-5,000 words
-Fiction
Speculative Fiction
Includes genres like Horror, Science Fiction, and Edgy fiction. As well as fantastical genres like Alternate History, Fantasy and Apocalyptic/ post-Apocalyptic Fiction
-5,000 words
-Fiction
Flash Fiction
A story with a fully developed theme, plot, and story arc in fewer than 1000 words
-1,000 words
-Fiction or Non-Fiction
First Chapter (Novel)
The first chapter of a novel that is intended for an adult readership, but of any genre or style
-6,000 words
-Fiction or Non-Fiction
First Chapter (Young Adult)
The first chapter of a novel that is intended for the young adult or middle grade market but of any genre or style
-6,000 words
-Fiction or Non-Fiction
Children’s Story
The text of a children's book. May be fictional or nonfiction and may explore any topic, theme, or genre, but intended for children
-1,500 words
-Fiction or Non-Fiction
Spiritual Essay
Spirituality can have many different definitions, depending on who is asked. It can be something as simple as looking for a higher meaning to life, or something so complex that one can base their beliefs, religion and overall life around it
-2,500 words
-Fiction or Non-Fiction
New Writer (New Voices)
-Must never have been paid for writing to enter as a New Writer
First Chapter
The first chapter of any style or genre of book.
-6,000 words
-Fiction or Non-Fiction
Creative Non-Fiction
Factually accurate prose about real people and events, written in a compelling, vivid, dramatic manner
-5,000 words
-Non-Fiction
Fiction
Stories that explore themes such as the human condition, interpersonal relationships, and societal issues. May also be described as "short story," "literary fiction," "straight fiction, or "up-market fiction"
-5,000 words
-Fiction
Poetry
Any style or type of poem
-2,000 words
-Fiction-Non-Fiction
Blue Quill
March 20th, Jenny Rabe, past president of the Blue Quill group, published a story in an anthology titled Mindagames. Here is a little blurb about it:
Sometimes the mind does more than play tricks on you—it plays twisted games. In this collaboration, wrap your brains around 25 stories ranging from soul-bending and heartbreaking to enchanting and sublime. Follow a teacher trapped at a mysterious convention, a man whose only chance at survival is a finicky love potion, a student who sees the monsters in others, a Syrian boy coming to grips with a new reality, and many more. This collection features award-winning offerings from established and up-and-coming authors from the LDS Beta Readers group. Are you ready to play?
You can find it on Amazon.
Cache Valley
It’s been a cold but productive winter here in Cache Valley.
Amanda Luzzader, Chadd VanZanten, Felicia Rose, Isaac Timm, and Tim Keller were included with writing greats like Dinty Moore, Jack Remick, Charles Waugh, and more, in the Helicon West Anthology, a 10 year collection of featured readers.
Amanda Luzzader’s short story “Daphne” appeared in the anthology, Chasing Magic. And "The Day the Cats Went Missing" was featured in the Utah Horror Writers anthology, Apocalypse Utah.
Jeff Bateman’s essay “Shooter” was featured in Proud to Be, an anthology of essays, fiction, and poetry, by military-service personnel, veterans, and their families.
Felicia Rose’s Essay “An Issue of Heels” was published in the Cache Valley Voice.
Felicia has also written several columns and essays, including but not limited to “Miriam’s Kitchen” and “Minimalism and the Homesteading Life”, for Mother Earth News, a bi-monthly magazine with a circulation of over half a million.
J. Anthony Gohier’s short story, “Piper” appeared in the anthology, Chasing Magic
Tim Keller presented on critique groups and the LUW for the Cache Valley Writing Center, on flash fiction writing for the Creative Writing Club at USU, and on critique group practices at the LUW Leadership Conference.
Shauna Leavitt’s articles “The Passion of Penstemaniacs” and “Orphaned Bear Cub Rehabilitation” were featured on Wild about Utah. While her articles “Leaving it to Beavers” and “The Long Drive of Dreams,” were appeared in the Utah State Magazine fall and winter issues. Shauna’s articles, “Bear Cubs Head back to the Wild” And “Pelicans at Strawberry Reservoir, What Do They Eat?” were featured on the DWR blog.
Felicia Rose, Isaac Timm, and Amanda Luzzader received invites to join Poetry at Three, a prestigious, University-affiliated poetry group. Emily Wheeler (Critique Groups) and Britney Johnson (Marketing) presented at the LUW Spring Workshop.
The Cache chapter drew a good crowd as the featured guests at Helicon West’s first winter reading, among the highlights:
Jeff Bateman and Emily Wheeler, Writer of the Year for the League of Utah Writers, wowed the audience with selections from the LUW Gold
Chapter Chatter, cont.
Quill Winning book, *No Peace with the Dawn*. [https://www.amazon.com/No-Peace-Dawn-Novel-Great/dp/146211900X/ref=sr_1_1](https://www.amazon.com/No-Peace-Dawn-Novel-Great/dp/146211900X/ref=sr_1_1)
Felicia Rose had them rolling in the aisles with her award winning essay "Tête-à-tête, the Language of Hair".
Isaac Timm recited his Best-in-Show winning poem “Beast Man” as only he can. While Jeremy Gohier kept us spell bound with his Wordplay Poetry award winner “Facing Despair.”
Last but most certainly not least, the 2015 League of Utah Writers Writer of the year, Chadd VanZanten, owned the room with his award-winning short story “And Once She Could Fly.” Not a dry eye in the house folks, not one.
Herriman
The Herriman chapter will man a booth at Fort Herriman Days on June 24th to get the League some publicity in our little corner of the valley. Come out and say hi!
We will be here:
W&M Butterfield Park
6212 W 14200 S
Heritage Writers Guild
WHOPEE. We are proud to announce that we now have our own web page ([Heritagewritersguild.com](http://Heritagewritersguild.com)) thanks to web master Amanda Empey. Although some of us are slow to send in pictures and needed info we plan to do better.
Next big news—HWG has applied for a grant from RAP money to support our group and with the efforts of Joe Gordon and Sue Leth, it looks like we might get it this time around.
Our critique groups continue to meet on a regular basis and those who attend love every minute.
At our April meeting, President Joe Gordon gave a lesson on how he approaches writing a new novel. He is what would be called a Macro Planner (see our web page) and loves all the steps necessary to plot the book before beginning to write.
Winford Wallace has completed another book, Second Chance, by Chance, a romance novel and has an idea for the next.
Evan McKinney spends most winters in Alaska, on the advice of booksellers in that state, printed up copies of his book on the history of the railroad in Alaska High Iron to Fairbanks – with the hope of selling it to tourists.
Sue Leth is working on two or three things as once, including a memoir of her time as an interior designer for big business in the SLC area.
Marilyn Richardson is almost (and it’s about time as she has been working with illustrator Bill Witsberger for 15 years) on a picture book for active moms and their kids “Oh, Mom.” She has a new cover and title for her multiple dimension book now called, The Mysterious Tale of the Red Jade, formerly Red Silk, Red Jade. But uploading to kindle isn’t as easy as it should be. For some reason the page breaks and indents don’t hold. But she is persistent and it will happen.
Denis Feehan, who travels from Mesquite, continues to write clever and witty short stories. He will soon have enough for a collection. Denis and several other members look forward to seeing their work in the LUW Anthology.
Two of our members, Marie Tollstrup and Mary Ann Mejdrich, had their entries selected for publication in the St. George Magazine.
Infinite Monkeys
Melissa McShane released her latest novel "Wondering Sight" in January.
K Scott Foreman was invited to speak to the Weber State University Sigma Tau Delta English Honor Society at their induction ceremony.
Jay Barnson's short story "Crawlers" was published in Vol 12 Issue 1 of Electric Spec magazine.
Michael Darling's "Got Hope", sequel to the best-selling urban fantasy "Got Luck" published in March.
Johnny Worthen will be teaching a course on writing for YA through the University of Utah Lifelong Learning.
The second annual Infinite Weekend Writing Retreat sold out in a record 20 minutes.
Just Write Chapter
Ann Gordon is president (firstname.lastname@example.org) and Mechelle Morrison is vice-president. Just Write has members all around Utah and in several states.
We have an active review/critique group and hold critique sessions twice a month. Members are allowed to share up to 3000 words each session. Ann creates a monthly newsletter for chapter members. Here is some member writing news:
* Shawn Pollock has signed a publishing contract with Cedar Fort for his novel, The Road to Freedom.
* Brenda Hodnett’s New Adult novel has been published by Crystal Publishing, LLC. The title of her coming of age love story is Blemished Beauty.
* V.J.O. Gardner, author of the Tales of Asculum (a group of fractured fairy tales) held a book signing April 22 at Pioneer Book in Provo. She also had a table at SLC ComicCon FanX in March.
* This spring Ann judged entries for an international mystery contest. She said most entries were so-so, but she was happy to give one entry the highest possible points. She reminds her chapter contest entrants to remember to “write tight.”
Millcreek
The Millcreek Chapter hosted Dave Butler at our Thursday night meeting, he talked on how to successfully market your book, getting those in attendance to workshop their elevator pitches.
Oquirrh Writers
Oquirrh Writers Chapter had a blast at this year’s LUW Spring Conference, members Craig Kingsman and Jodi L. Milner each gave fantastic presentations and many of our members came to learn more about the craft. Thanks to the organizers for this great event. Eliza Crosby will be releasing her middle grade novel "The Eyeball Mysteries" in May. Watch Facebook for info about the release party. Way to go, Eliza!
Brenda Birch Gallaher is publishing a short story in a magazine. Details to come!
Jodi L. Milner's story "Skull Collector" was shortlisted in SQ Magazine's Story Quest Contest. Issue info will be listed on her Facebook page when available.
With cooperation with other LUW chapters, we are working to make this year's Spring into Books event Utah's Awesomeist Author Signing. Our goal this year is to work closely with many of Utah's favorite publishers as well as our talented indie authors. Save the Date! May 20th at the Library's Viridian Event Center in West Jordan.
Chapter Chatter, cont.
Author tables are still available - go to http://LUWOC.com for more info.
Chapter meetings are held on the 1st Thursday of each month in the West Jordan City Hall's Community Room at 7pm. We split the meeting into two halves. The first half is a presentation and the second is for critiques of writing projects.
Salt Lake Scribes
The Salt Lake Scribes have been streaming forward with lots of new stories and books on the horizon. Our group has been growing rapidly this last few months with some terrific new scribes.
Cindy Hung is our new Vice President. She has set up a new Facebook page that is beginning to take off. Big thanks to her.
We are planning on filling up the pages of the next issue with our accomplishments, but for now we're pacing ourselves.
Wasatch Writers
Wasatch Writers has been around for over 30 years with some of our members being involved since the beginning. We meet on the second Monday of each month at the Clearfield Library from 6:30 to 8:30 in the evening. We are also meeting on the fourth Monday at the Kaysville Library during the same time period. We are currently accepting new members. If you are interested, drop our chapter President a line at email@example.com. Visitors are always welcome.
We have writers concentrating on short stories, historical fiction and non-fiction, sci-fi and fantasy, as well as non-fiction, informational. However, we are not genre specific and love to read and learn about all genres.
We have several activities coming up. May 8th we will have Kelley Lindberg speaking with us on the topic: "Writing Effective Query Letters." Then, on July 10th we will have Eric Swedin giving us some tips on keeping history straight in our writing. We have Tiffany Stockholm scheduled for August; she will speak on "The Four Pillars of Critiquing." All of our speakers have expertise in their fields and we appreciate their willingness to speak to our group. Hope to see some new faces at our upcoming meetings.
Wordcraft
I just received some news from our Wordcraft Member Joyce Skidmore: She's been involved in a 10 week pilot program for readers theatre. She wrote the scripts, directed the final event, and it was a huge success. Yesterday (April 19, 2017) she was interviewed for an hour and five minutes by EngAge Utah, ZAP, Utah Arts and Museums, and the National Endowment for the Arts.
We had our annual February Wordcraft Chapter writing contest with the theme SECRETS, and the winners are:
First Place: Sharee Hughes
Second Place: Tie - Eilene Bodell and Lynn Hoins
Third place - Janie Ruff.
Lynn Hoins entered the 2017 UTSPS contest. Good luck to her.
Hi everyone!
Does anyone else get frustrated with their manuscript? With their lack of progress on a manuscript? With the ease that they are distracted by the internet, or chocolate, or sleep, or I don’t know, air?
Or is it just me?
Some aspects of writing are fun, others are a chore, and others I avoid like the plague. Like dishes and weeding. (I know, I know, someone likes weeding...)
Unfortunately, we’ve all decided that the end product of our toil is worth it, so it’s time to gird those proverbial loins and get to it.
What is your writing goal for the summer? What are you going to do to make it happen? Do you have your team set up to help you (See Jared’s message on the first page)?
Each day is a new day. Let’s do this thing!
Jo Schneider, Oquirrh Chapter
LUW Facebook Group
Please remember to join the League’s Facebook Group. After you login to Facebook, search for League of Utah Writers, or you can to this page:
https://www.facebook.com/groups/LeagueofUtahWriters/
This Facebook group is only open to members of the League.
|
Monday
February 24, 1992
United States Government Printing Office
SUPERINTENDENT OF DOCUMENTS
Washington, DC 20402
OFFICIAL BUSINESS
Penalty for private use, $300
SECOND CLASS NEWSPAPER
Postage and Fees Paid
U.S. Government Printing Office
(ISSN 0097-6326)
Monday
February 24, 1992
Briefing on How To Use the Federal Register
For information on a briefing in Washington, DC, see announcement on the inside cover of this issue.
FEDERAL REGISTER Published daily, Monday through Friday (not published on Saturdays, Sundays, or on official holidays), by the Office of the Federal Register, National Archives and Records Administration, Washington, DC 20408, under the Federal Register Act (49 Stat. 500, as amended; 44 U.S.C. Ch. 15) and the regulations of the Administrative Committee of the Federal Register (1 CFR Ch. I). Distribution is made only by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402.
The Federal Register provides a uniform system for making available to the public regulations and legal notices issued by Federal agencies. These include Presidential proclamations and Executive Orders and Federal agency documents having general applicability and legal effect, documents required to be published by act of Congress and other Federal agency documents of public interest. Documents are on file for public inspection in the Office of the Federal Register the day before they are published, unless earlier filing is requested by the issuing agency.
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The Federal Register will be furnished by mail to subscribers for $340 per year in paper form; $195 per year in microfiche form; or $37,500 per year for the magnetic tape. Six-month subscriptions are also available at one-half the annual rate. The charge for individual copies in paper or microfiche form is $1.50 for each issue, or $1.50 for each group of pages as actually bound, or $175.00 per magnetic tape. Remit check or money order, made payable to the Superintendent of Documents. Mail to: New Orders, Superintendent of Documents, P.O. Box 371954, Pittsburgh, PA 15250-7954, or charge to your GPO Deposit Account or VISA or Mastercard.
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How To Cite This Publication: Use the volume number and the page number. Example: 57 FR 12345.
---
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FOR: Any person who uses the Federal Register and Code of Federal Regulations.
WHO: The Office of the Federal Register.
WHAT: Free public briefings (approximately 3 hours) to present:
1. The regulatory process, with a focus on the Federal Register system and the public's role in the development of regulations.
2. The relationship between the Federal Register and Code of Federal Regulations.
3. The important elements of typical Federal Register documents.
4. An introduction to the finding aids of the FR/CFR system.
WHY: To provide the public with access to information necessary to research Federal agency regulations which directly affect them. There will be no discussion of specific agency regulations.
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WHEN: February 28, at 9:00 a.m.
WHERE: Office of the Federal Register,
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PUBLIC
Subscriptions:
Paper or fiche 202–783–3238
Magnetic tapes 512–2235
Problems with public subscriptions 512–2303
Single copies/back copies:
Paper or fiche 783–3238
Magnetic tapes 512–2235
Problems with public single copies 512–2457
FEDERAL AGENCIES
Subscriptions:
Paper or fiche 523–5240
Magnetic tapes 512–2235
Problems with Federal agency subscriptions 523–5243
For other telephone numbers, see the Reader Aids section at the end of this issue.
## Contents
### Agriculture Department
*See Rural Electrification Administration*
### Alcohol, Tobacco and Firearms Bureau
**PROPOSED RULES**
- Alcohol; viticultural area designations:
- Alexander Valley, CA; withdrawn
- Correction, 6353
### Antitrust Division
**NOTICES**
- National cooperative research notifications:
- Southwest Research Institute; correction, 6334
### Arts and Humanities, National Foundation
*See National Foundation on the Arts and the Humanities*
### Blackstone River Valley National Heritage Corridor Commission
**NOTICES**
- Meetings; Sunshine Act, 6349
### Centers for Disease Control
**NOTICES**
- Upper extremity fatigue; work schedule factors; NIOSH meeting, 6328
### Civil Rights Commission
**NOTICES**
- Meetings; State advisory committees:
- North Carolina, 6314
- Tennessee, 6314
- Meetings; Sunshine Act, 6349
### Coast Guard
**NOTICES**
- Committees; establishment, renewal, termination, etc.:
- Commercial Fishing Industry Vessel Advisory Committee, 6343
- New Orleans, LA; Inner Harbor Navigational Canal bridge; hearing, 6344
### Commerce Department
*See Foreign-Trade Zones Board; International Trade Administration; National Oceanic and Atmospheric Administration*
### Commodity Futures Trading Commission
**NOTICES**
- Meetings:
- Financial Products Advisory Committee, 6318
- Meetings; Sunshine Act, 6349
### Customs Service
**NOTICES**
- Commercial laboratory accreditations.
- Comsource American, Inc., 6347
- Trade name recordation applications:
- Grand Tea Co., 6347
### Defense Department
**NOTICES**
- Committees; establishment, renewal, termination, etc.:
- Chlorofluorocarbons Advisory Committee, 6316
- Meetings:
- Joint Strategic Target Planning Staff, 6317
### Employment and Training Administration
**NOTICES**
- Adjustment assistance:
- Amerada Hess Corp. et al., 6334
- Digital Equipment Corp., 6335
- Monarch Machine Tool Co., 6335
- Unisys Corp., 6335
- Grant and cooperative agreement awards:
- Job Training Partnership Act—Council of Jewish Organizations, 6336
### Energy Department
*See also Federal Energy Regulatory Commission*
**NOTICES**
- Natural gas exportation and importation:
- Sergeant Oil & Gas Co., Inc., 6325
### Environmental Protection Agency
**PROPOSED RULES**
- Hazardous waste:
- State underground storage tank program approvals—Maine, 6302
### Federal Aviation Administration
**NOTICES**
- Meetings:
- Research, Engineering, and Development Advisory Committee, 6344
- Passenger facility charges; applications, etc.:
- Memphis International Airport, TN, 6345
### Federal Deposit Insurance Corporation
**NOTICES**
- Meetings; Sunshine Act, 6350
### Federal Energy Regulatory Commission
**NOTICES**
- Electric rate, small power production, and interlocking directorate filings, etc.:
- Florida Power & Light Co. et al., 6317
- Natural gas certificate filings:
- Panhandle Eastern Pipe Line Co. et al., 6318
- Natural Gas Policy Act:
- State jurisdictional agencies tight formation recommendations; preliminary findings—Wyoming Oil and Gas Conservation Commission, 6321
- *Applications, hearings, determinations, etc.*:
- Chattanooga Gas Co., 6321
- CNG Transmission Corp., 6322
- El Paso Natural Gas Co., 6322
- KN Energy, Inc., 6323
- Midwestern Gas Transmission Co., 6323
- Northern Natural Gas Co., 6323
- Panhandle Eastern Pipe Line Co., 6323
- Texas Gas Transmission Corp., 6324
Trunkline Gas Co., 6324
Williams Natural Gas Co., 6324
Federal Highway Administration
NOTICES
Environmental statements; notice of intent:
Davis and Weber Counties, UT, 6345
Ketchikan Gateway Borough, AK, 6345
Weber County, UT, 6346
Federal Maritime Commission
NOTICES
Casualty and nonperformance certificates.
Starlite Cruises, Inc., 6328
Federal Mine Safety and Health Review Commission
NOTICES
Meetings; Sunshine Act, 635C
Federal Reserve System
NOTICES
Federal Open Market Committee
Domestic policy directives, 632C
Meetings; Sunshine Act, 6350
Applications, hearings, determinations, etc.:
FirstBancorp, Inc., et al., 6326
Montfort Bancorporation, Inc., 6327
Federal Trade Commission
NOTICES
Prohibited trade practices:
Scali, McCabe, Sloves, Inc., 6327
Volvo North America Corp. et al., 6328
Food and Drug Administration
RULES
Animal drugs, feeds, and related products:
Prednisolone tablets
Correction, 6352
Food for human consumption:
Infant formula microbiological testing, consumer complaints, and record retention requirements;
correction, 6352
PROPOSED RULES
Human drugs:
Orally administered drug products; symptoms associated with overindulgence in food and drink, relief (OTC); tentative final monograph; correction, 6352
Stimulant drug products (OTC); proposed amendment to monograph; correction, 6352
NOTICES
Human drugs:
New drug applications—
SuperPharm Corp. et al.; approval withdrawn;
correction, 6352
Medical devices; premarket approval:
META DDDR Pacing System, etc., 6328
Foreign Assets Control Office
RULES
Administrative practice and procedure:
Information collection requirements; OMB authorization numbers, 6296
Foreign-Trade Zones Board
NOTICES
Applications, hearings, determinations, etc.:
Indiana—
Fairmont Homes, Inc.: modular housing and recreational vehicle plants, 6314
Health and Human Services Department
See Centers for Disease Control; Food and Drug Administration; Public Health Service
Health Resources and Services Administration
See Public Health Service
Housing and Urban Development Department
PROPOSED RULES
Manufactured home construction and safety standards: Energy conservation requirements, 6420
Indian Affairs Bureau
PROPOSED RULES
Tribal government:
Tribal consultation on proposed regulations governing calling and conducting of Secretarial elections, etc.; meetings, 6456
Interior Department
See Indian Affairs Bureau; Land Management Bureau
Internal Revenue Service
RULES
Income taxes:
Conclusive presumption of worthlessness of debts held by banks, 6291
Enhanced oil recovery projects certification; correction, 6353
Salvage and reinsurance treatment Correction, 6353
Procedure and administration:
Insolvent financial institutions affiliated with consolidated groups; abatements, credits, and refunds; correction, 6352
PROPOSED RULES
Procedure and administration:
Insolvent financial institutions affiliated with consolidated groups; abatements, credits, and refunds Cross reference; correction, 6353
Hearing; correction, 6353
International Trade Administration
NOTICES
Antidumping and countervailing duties:
Administrative review requests, 6314
International Trade Commission
NOTICES
Import investigations:
Plastic encapsulated integrated circuits, 6332
Interstate Commerce Commission
NOTICES
Railroad services abandonment:
Tylerdale Connecting Railroad Co., 6333
Justice Department
See also Antitrust Division
NOTICES
Agency information collection activities under OMB review, 6334
Labor Department
See also Employment and Training Administration; Occupational Safety and Health Administration
PROPOSED RULES
Federal regulatory review, 6301
Land Management Bureau
NOTICES
Closure of public lands:
Utah, 6330
Meetings:
Shoshone District Advisory Council and Grazing Advisory Board, 6330
Ukiah District Advisory Council, 6330
Oil and gas leases:
Colorado, 6331
Opening of public lands:
California, 6331
Oregon, 6331
Realty actions; sales, leases, etc.:
Arizona, 6331, 6332
Legal Services Corporation
NOTICES
Meetings; Sunshine Act, 6350
Mine Safety and Health Federal Review Commission
See Federal Mine Safety and Health Review Commission
National Foundation on the Arts and the Humanities
PROPOSED RULES
Claims collection, 6303
National Institute for Occupational Safety and Health
See Centers for Disease Control
National Labor Relations Board
NOTICES
Meetings; Sunshine Act, 6351
National Oceanic and Atmospheric Administration
RULES
Fishery conservation and management:
Summer flounder; correction, 6297
NOTICES
Meetings:
Western Pacific Fishery Management Council, 6316
Permits:
Marine mammals, 6315
National Science Foundation
NOTICES
Meetings:
Studies, Evaluation, and Dissemination Advisory Panel, 6336
Nuclear Regulatory Commission
PROPOSED RULES
Federal regulatory review, 6299
Regulatory agenda
Quarterly report, 6299
NOTICES
Environmental statements; availability, etc.:
Gulf States Utilities Co., 6338
Meetings:
Aging Research Information Conference, 6337
Reactor Safeguards Advisory Committee, 6337
Reactor Safeguards Advisory Committee et al.
Proposed schedule, 6337
Applications, hearings, determinations, etc.:
Army Materials Technology Laboratory, 6339
Texas Utilities Electric Co., 6340
Occupational Safety and Health Administration
RULES
Safety and health standards:
Highly hazardous chemicals; process safety management, 6358
Personnel Management Office
NOTICES
Meetings:
Federal Prevailing Rate Advisory Committee, 6340
Public Health Service
See also Centers for Disease Control; Food and Drug Administration
NOTICES
Organization, functions, and authority delegations:
Centers for Disease Control, 6329
Rural Electrification Administration
RULES
Organization, functions, and authority delegations:
Administrator et al., 6285
Securities and Exchange Commission
NOTICES
Self-regulatory organizations; unlisted trading privileges:
Midwest Stock Exchange, Inc., 6341
Philadelphia Stock Exchange, Inc., 6341
Small Business Administration
RULES
Small business size standards:
Nonmanufacturer rule; waivers—
Four wheel utility trucks, etc., 6290
NOTICES
Disaster loan areas:
Idaho, 6342
Kentucky, 6342
New Jersey, 6342
New York et al., 6341
Oklahoma, 6342
Oregon, 6342
Washington, 6342
License surrenders:
Capital Corp. of America, 6343
Applications, hearings, determinations, etc.:
MorAmerica Capital Corp., 6343
Tennessee Valley Authority
PROPOSED RULES
Freedom of Information Act; implementation, 6300
Transportation Department
See also Coast Guard; Federal Aviation Administration; Federal Highway Administration
NOTICES
Aviation proceedings:
Certificates of public convenience and necessity and foreign air carrier permits; weekly applications, 6343
Treasury Department
See also Alcohol, Tobacco and Firearms Bureau; Customs Service; Foreign Assets Control Office; Internal Revenue Service
NOTICES
Agency information collection activities under OMB review, 6346
Veterans Affairs Department
NOTICES
Agency information collection activities under OMB review, 6347
Separate Parts In This Issue
Part II
Department of Labor, Occupational Safety and Health Administration, 6356
Part III
Department of Housing and Urban Development, 6420
Part IV
Department of the Interior, Bureau of Indian Affairs, 6456
Reader Aids
Additional information, including a list of public laws, telephone numbers, and finding aids, appears in the Reader Aids section at the end of this issue.
CFR PARTS AFFECTED IN THIS ISSUE
A cumulative list of the parts affected this month can be found in the Reader Aids section at the end of this issue.
| Part | Section | Page |
|------|---------|------|
| 7 | 1700 | 6285 |
| 10 | | |
| Proposed Rules: | Ch. I (2 documents) | 6299 |
| 13 | 121 | 6290 |
| 18 | | |
| Proposed Rules: | 1301 | 6300 |
| 20 | | |
| Proposed Rules: | Ch. I | 6301 |
| 21 | 106 | 6352 |
| 520 | | 6352 |
| Proposed Rules: | 340 | 6352 |
| 24 | | |
| Proposed Rules: | 3280 | 6420 |
| 25 | | |
| Proposed Rules: | 81 | 6456 |
| 82 | | 6456 |
| 26 | 1 (4 documents) | 6291, 6352, 6353 |
| 602 | | 6291 |
| Proposed Rules: | 1 (2 documents) | 6353 |
| 301 | (2 documents) | 6353 |
| 27 | | |
| Proposed Rules: | 9 | 6353 |
| 29 | 1910 | 6356 |
| Proposed Rules: | Subtitle A | 6301 |
| 31 | 500 | 6296 |
| 515 | | 6296 |
| 520 | | 6296 |
| 535 | | 6296 |
| 575 | | 6296 |
| 40 | | |
| Proposed Rules: | 281 | 6302 |
| 41 | | |
| Proposed Rules: | Ch. 50 | 6301 |
| Ch. 60 | 6301 |
| Ch. 61 | 6301 |
Rules and Regulations
This section of the FEDERAL REGISTER contains regulatory documents having general applicability and legal effect, most of which are keyed to and codified in the Code of Federal Regulations, which is published under 50 titles pursuant to 44 U.S.C. 1510.
The Code of Federal Regulations is sold by the Superintendent of Documents. Prices of new books are listed in the first FEDERAL REGISTER issue of each week.
DEPARTMENT OF AGRICULTURE
Rural Electrification Administration
7 CFR Part 1700
General Information
AGENCY: Rural Electrification Administration, USDA.
ACTION: Final rule.
SUMMARY: The Rural Electrification Administration (REA) hereby amends 7 CFR chapter XVII of the Code of Federal Regulations by revising part 1700, General Information, to describe and reflect several changes in REA organizational structure and functions. These changes are rules of Agency organization.
EFFECTIVE DATE: This rule is effective February 24, 1992.
FOR FURTHER INFORMATION CONTACT: Fred L. Henson, Personnel Management Division, Rural Electrification Administration, room 4031, South Building, U.S. Department of Agriculture, 14th and Independence Avenue, SW., Washington, DC 20250-1500. Telephone: (202) 720-1384.
SUPPLEMENTARY INFORMATION:
Executive Order 12291
This final rule has been issued in conformance with Executive Order 12291 and Departmental Regulation 1512-1. This action has been classified as "nonmajor" because it does not meet the criteria for a major regulation as established by the Order.
Regulatory Flexibility Act Certification
The Administrator of REA has determined that this final rule will not have a significant economic impact on a substantial number of small entities as defined in the Regulatory Flexibility Act (5 U.S.C. 601 et seq.). Most borrowers of REA loans do not meet the requirements for small entities.
National Environmental Policy Act Certification
The Administrator of REA has determined that this final rule will not significantly affect the quality of the human environment as defined by the National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.). Therefore, this action does not require an environmental impact statement or assessment.
Catalog of Federal Domestic Assistance
The programs described by this final rule are listed in the 1991 Catalog of Federal Domestic Assistance Programs under No. 10.850, Rural Electrification Loans and Loan Guarantees; No. 10.851, Rural Telephone Loans and Loan Guarantees; No. 10.852, Rural Telephone Bank Loans; and No. 10.854, Rural Economic Development Loans and Grants. This catalog is available on a subscription basis from the Superintendent of Documents, the United States Government Printing Office, Washington, DC 20402.
Executive Order 12372
This final rule is excluded from the scope of Executive Order 12372, Intergovernmental Consultant. A Notice of Final rule entitled Department Programs and Activities Excluded from Executive Order 12372 (50 FR 47034) exempts REA electric loans and loan guarantees from coverage under this Order.
Information Collection and Recordkeeping Requirements
This final rule contains no information collection or recordkeeping provisions requiring Office of Management and Budget approval under the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).
This amendment revises and reflects the current organizational structure of REA and certain internal administrative functions. Accordingly, under the administrative procedure provisions in 5 U.S.C. 553, it is found upon good cause that notice and comment and other public procedures are impractical and contrary to public interest.
List of Subjects in 7 CFR Part 1700
Electric power, Freedom of information, Loan programs—communication, Loan programs—energy, Organization and functions (Government agencies), Rural areas, Telephone.
Therefore, REA amends part 1700 of 7 CFR chapter XVII as follows:
PART 1700—GENERAL INFORMATION
1. The authority citation for 7 CFR part 1700 is revised to read as follows:
Authority: 7 U.S.C. 901 et seq.; Delegation of Authority by the Secretary of Agriculture, 7 CFR 2.23; Delegation of Authority by the Under Secretary of Agriculture for Small Community and Rural Development, 7 CFR 2.72; 7 U.S.C. 1921 et seq.; 5 U.S.C. 301, 552; 7 CFR 1.1–1.16.
2. Subpart A of part 1700 is revised to read as follows:
Subpart A—Organization and Functions
1700.1 General.
1700.2 Office of the Administrator.
1700.3 Office of the Deputy Administrator—Program Operations.
1700.4 Rural electric program.
1700.5 Rural telephone program.
1700.6 Economic development and technical services.
1700.7 Office of the Deputy Administrator—Management and Policy Support.
1700.8 Office of Assistant Administrator—Management.
1700.9 Information, legislation, policy and management analysis.
1700.10 1700.19—[Reserved]
Subpart A—Organization and Functions
§ 1700.1 General.
(a) The Rural Electrification Administration (REA) was established by Executive Order No. 7037, signed by the President on May 11, 1935. Statutory authority was provided by the Rural Electrification Act of 1936 (RE Act) (49 Stat. 1363; 7 U.S.C. 901). The RE Act established REA as a lending agency with responsibility for developing a program for rural electrification.
(b) On October 28, 1949, an amendment to the RE Act authorized REA to make loans to improve and extend telephone service in rural areas. The Rural Telephone Bank (RTB or the Bank), an Agency of the United States, was established by another amendment to the RE Act, approved May 7, 1971. The Administrator of REA serves as the Bank's chief executive with the title of Governor. On May 11, 1973, the RE Act was further amended to establish a
revolving fund and to provide authority for REA to guarantee loans made by other legally organized lenders. The RE Act was amended further on December 21, 1987, to establish a Rural Economic Development Subaccount, and to authorize funds from this subaccount to provide zero-interest loans and grants to REA borrowers to promote rural economic development and job creation. The RE Act was also amended on November 5, 1990, to add a new section 314, which authorizes REA to guarantee 90 percent of the principal and interest of loans made for electric and telephone facilities by legally organized lenders. It was further amended on November 28, 1990, to establish an Assistant Administrator for Economic Development and a rural development technical assistance unit; to expand the authorities and responsibilities of REA in rural economic development; and to establish a Rural Business Incubator Fund for making grants and reduced interest loans to electric and telephone borrowers to promote business incubator projects. At the same time, the Administrator was also granted authority for financial assistance for distance learning and medical link programs.
(c) The offices of REA are located in the South Building of the United States Department of Agriculture at 14th and Independence Avenue, SW., Washington, DC 20250–1500. The Electric and Telephone Programs are administered by regional offices located at this same address. There is a Northern and a Southern Regional Office, along with a Power Supply Division, for the electric program, and an Eastern and a Western Regional Office for the telephone program. (See § 1700.4(b) and 1700.5(b).)
§ 1700.2 Office of the Administrator.
(a) The Administrator (who also serves as Governor of the RTB) is appointed by the President, with the advice and consent of the Senate, for a term of 10 years. The Administrator functions as the chief executive of the Agency under the general supervision and direction of the Under Secretary for Small Community and Rural Development. The Administrator is aided directly by two Deputy Administrators and by Assistant Administrators for the Electric Program, the Telephone Program, for Economic Development and Technical Services, and for Management. The Financial Services Staff and the Equal Opportunity and Civil Rights Staff also report directly to the Administrator. The work of the Agency is carried out through the offices and divisions described in this part.
(b) The Financial Services Staff performs the following functions:
(1) Evaluates financial conditions of financially troubled borrowers;
(2) Negotiates settlements and “workouts” of financially troubled borrowers who have or may have delinquent loans in order to satisfy the government’s interests, keeping abreast of financial and legal factors that may affect the negotiations;
(3) Coordinates the Agency’s efforts to identify and develop strategies for potentially financially troubled borrowers;
(4) Develops techniques and criteria for evaluating the financial and operating performance of certain rural electric and telephone borrowers;
(5) Develops certain standards, policies, and procedures in connection with loan requirements and processing for the electric and telephone programs;
(6) Analyzes and evaluates certain loan requests and transactions to determine whether the documentation justifies the request;
(7) Serves as staff to the Senior Loan Committee;
(8) Keeps other government organizations advised concerning activities of the staff; and
(9) Serves as REA liaison to the capital markets.
(c) The Equal Opportunity and Civil Rights Staff administers the program for equal opportunity in the delivery of services and benefits by REA borrowers and in the employment practices in the Agency. The staff:
(1) Formulates and coordinates plans, policies and procedures for a nationwide program of nondiscrimination on the part of REA borrowers in carrying out borrower programs subject to the provisions of title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000a–2000h–8); section 504 of the Rehabilitation Act of 1973 (29 U.S.C. 701 et seq.); the Age Discrimination Act of 1975 (42 U.S.C. 6101–6107); the Americans with Disabilities Act of 1990 (42 U.S.C. 12101 et seq.); and Executive Order 11246 (3 CFR, 1964–1965 Comp., p. 339), as amended by Executive Orders 11375 (3 CFR, 1966–1970 Comp., p. 684) and 12086 (3 CFR, 1978 Comp., p. 230).
(2) Develops and monitors plans, policies and programs designed to promote equal employment opportunity for REA personnel under title VII of the Civil Rights Act of 1964; the Age Discrimination in Employment Act of 1967 (29 U.S.C. 621–634); the Equal Employment Opportunity Act of 1972 (42 U.S.C. 2000e et seq.); section 501 of the Rehabilitation Act of 1973; pertinent provisions of the Civil Service Reform Act of 1978 (5 U.S.C. 1101 et seq.); and applicable rules, regulations and other equal employment, nondiscrimination statutes.
§ 1700.3 Office of the Deputy Administrator—Program Operations.
The Deputy Administrator—Program Operations directs and coordinates the electric, telephone and rural economic development programs, technical services, and borrower accounting activities; reviews Agency policies in these areas and, as necessary, implement changes; and participates with the Administrator and other officials in planning and formulating the programs and activities of the Agency.
§ 1700.4 Rural electric program.
(a) The Assistant Administrator—Electric directs and coordinates the rural electrification program of the Agency, participating with the Administrator and Deputy Administrator—Program Operations and others in planning and formulating the programs and activities of the Agency.
(b) Regional Offices. (1) The two regional offices are the primary points of contact between REA and electric distribution system borrowers. Each office administers the rural electric program for an assigned geographical area with assistance of field representatives located in areas assigned to them. The regional offices are composed of the following states and territories:
(i) Northern Region. Alaska, Connecticut, Delaware, Hawaii, Idaho, Illinois, Indiana, Iowa, Kentucky, Maine, Maryland, Massachusetts, Michigan, Minnesota, Montana, New Hampshire, New Jersey, New York, North Dakota, Ohio, Oregon, Pennsylvania, Rhode Island, South Dakota, Vermont, Virginia, Washington, West Virginia, Wisconsin, Wyoming, and present and former Pacific Trust Territories; and
(ii) Southern Region. Alabama, Arizona, Arkansas, California, Colorado, Florida, Georgia, Kansas, Louisiana, Mississippi, Missouri, Nebraska, Nevada, New Mexico, North Carolina, Oklahoma, Puerto Rico, South Carolina, Tennessee, Texas, Utah, and the Virgin Islands.
(2) The regional offices perform the following functions with respect to loan feasibility and security and accomplishment of the purposes of the RE Act:
(i) Administer the rural electrification program for distribution borrowers in
the region, serving as the single point of contact for distribution borrowers;
(ii) Provide guidance to borrowers on Agency loan policies and procedures, and receives, evaluates, and processes insured and guaranteed loan applications and other requests for financing assistance;
(iii) If delegated the authority by the Administrator, Regional Directors may approve certain loans, lien accommodations and other actions;
(iv) Assure that distribution and transmission systems and facilities are designed and constructed in accordance with the terms of the loan and proper engineering practices and specifications;
(v) Maintain oversight of borrower rate actions;
(vi) Provide guidance to borrowers on supplemental power resources; load and energy management; and the environmental aspect of the design, construction and operation of their systems;
(vii) Maintain necessary oversight of borrowers' financial management and technical operations and practices to assure the security of the government's loans. Institute operations and management studies or other forms of corrective action as necessary;
(viii) Works to ensure accountability of loan and other financial transactions; and
(ix) Supplements efforts of the Equal Opportunity and Civil Rights Staff to ensure borrower compliance with civil rights requirements.
(c) Power Supply Division.—The Division performs the following functions:
(1) Administers rural electrification program responsibilities that relate to power supply borrowers, and serves as the primary point of contact between REA and all such borrowers;
(2) Receives, evaluates, and processes insured and guaranteed loan applications and other requests for financial assistance from power supply borrowers;
(3) Develops and administers engineering and construction functions related to planning, design, construction, operation, and maintenance for power supply borrowers;
(4) Maintains a continuing financial and management overview of power supply borrowers to ensure that their operations are consistent with sound fiscal policies and procedures, loan security, and with REA loan contracts, mortgages and regulatory requirements. Initiates operations and management studies or other forms of corrective action as necessary;
(5) Provide guidance to borrowers on supplemental power resources; load and energy management; and the environmental aspects of the design, construction and operations of their systems;
(6) Works to ensure accountability of loan and other financial transactions; and
(7) Supplements efforts of the Equal Opportunity and Civil Rights Staff to ensure borrower compliance with civil rights requirements.
(d) Electric Staff Division. This division administers certain engineering and operating activities relating to the rural electric program. The division:
(1) Is responsible for engineering aspects of REA's standards, specifications and other requirements with respect to design, construction, and technical operation and maintenance of power-plant, distribution, and transmission systems and facilities, including load management, energy conservation and communications;
(2) Develops engineering practices, policies, standards, and guidelines for the Agency relating to electric borrowers' systems; conducts analysis and provides guidance on matters relating to fuels for electric generating stations; analyzes the effects of environmental laws and regulations on REA-financed electric systems; and develops related policies and procedures for the Agency;
(3) Develops criteria, procedures and analyses for improvement of the operating performance of electric borrowers;
(4) Develops procedures, criteria and techniques for forecasting borrowers' power requirements; and develops and maintains expertise in matters relating to retail and wholesale rates;
(5) Develops policies and procedures for adherence to environmental laws and regulations, and reviews borrowers' environmental studies;
(6) Maintains and publishes a continuing updated list of materials compatible with current REA standards;
(7) From time to time provides consultation with borrowers regarding engineering matters;
(8) Provides assistance to the other electric offices and, as appropriate, to borrowers; and
(9) Maintains liaison with other Government agencies, utilities, industry officials and professional organizations on the above matters.
§ 1700.5 Rural telephone program.
(a) The Assistant Administrator—Telephone directs and coordinates the rural telephone program of the Agency, participating with the Administrator and Deputy Administrator—Program Operations and other officials in planning and formulating the programs and activities of the Agency.
(b) Regional Offices. (1) The two regional offices are the primary points of contact between REA and all telephone system borrowers. Each office administers the rural telephone program for an assigned geographical area with assistance of field representatives located in areas assigned to them.
(2) The regional offices are composed of the following states and territories:
(i) Eastern Region. Alabama, Connecticut, Delaware, Florida, Georgia, Illinois, Indiana, Kentucky, Maine, Maryland, Massachusetts, Michigan, Mississippi, New Hampshire, New Jersey, New York, North Carolina, Ohio, Pennsylvania, Puerto Rico, Rhode Island, South Carolina, Tennessee, Vermont, Virginia, Virgin Islands, West Virginia, and Wisconsin; and
(ii) Western Region. Alaska, Arizona, Arkansas, California, Colorado, Hawaii, Idaho, Iowa, Kansas, Louisiana, Minnesota, Missouri, Montana, Nebraska, Nevada, New Mexico, North Dakota, Oklahoma, Oregon, South Dakota, Texas, Utah, Washington, Wyoming and present and former Pacific Trust Territories along with the Northern Mariana Islands and Guam.
(3) The regional offices have the following responsibilities with respect to loan feasibility and security and accomplishment of the purposes of the RE Act:
(i) Provide guidance to applicants and borrowers on Agency and Rural Telephone Bank loan policies and procedures, and make recommendations to the Administrator on applications for loans or guarantees. If delegated the authority by the Administrator, Area Directors may approve certain loans, lien accommodations and other actions;
(ii) Review and analyze borrowers' toll revenue settlements and local service rates for adequacy to meet loan service payments and other expenses;
(iii) Assure that telephone systems and facilities are designed and constructed in accordance with the terms of the loan and the Agency's regulations. They review, analyze and approve borrowers' engineering plans and specifications; engineering, equipment and construction contracts; and borrowers' payments to engineers and contractors. They work with the borrowers to assure that completed construction meets REA standards for quality of service and loan security; and
(iv) Provide information to borrowers regarding management and technical operations and practices with respect to the feasibility and security of the
Government's loans and achievement of RE Act purposes.
(c) **Telecommunications Standards Division.** This division administers engineering staff activities related to the design, construction, and technical operation and maintenance of rural telephone systems and facilities. The division:
(1) Develops Agency engineering practices, policies, guidelines and technical data relating to telephone borrowers' systems;
(2) Evaluates the application of new communications network technology to rural telephone systems;
(3) Develops standards, policies, and procedures in connection with construction activities financed by the rural telephone program;
(4) Provides advice and assistance to the regional offices and, as requested, to borrowers on the above functions and responsibilities; and
(5) Maintains liaison with other government agencies, utilities, industry officials, and professional organizations on the above matters.
(d) **Rural Telephone Bank Management Staff.** This staff performs the following functions:
(1) Prepares analyses and makes recommendations to the Assistant Governor of the RTB on RTB issues;
(2) Performs the calculations needed to determine the cost of money rate to RTB borrowers;
(3) Prepares the minutes of RTB board meetings;
(4) Develops practices and procedures for determining toll forecasts for the telephone regional offices, and develops the toll forecasts for borrowers with complicated settlement arrangements; and
(5) Maintains liaison with other government agencies, utilities, industry officials, and professional organizations on the above matters.
§ 1700.6 Economic development and technical services.
(a) The Assistant Administrator—Economic Development and Technical Services directs and coordinates the rural economic development and technical services programs of the Agency, participating with the Administrator and Deputy Administrator—Program Operations and other officials in planning and formulating the programs and activities of the Agency. Two staffs and one division report to this Assistant Administrator.
(b) **Rural Development Assistance Staff.** This staff performs the following functions:
(1) Administers the Agency's rural economic development and job creation programs;
(2) Formulates and develops regulations, procedures, directives, and bulletins concerning the execution of Agency rural economic development activities;
(3) In coordination with Agency personnel, provides guidance to borrowers on Agency rural economic development policies and procedures, and makes recommendations to the Administrator on borrowers' applications for rural economic development financial assistance;
(4) Provides economic and community development technical assistance to borrowers; and
(5) Advises Agency personnel on rural economic development matters.
(c) **Program Support Staff.** This staff has the following responsibilities:
(1) Prepares special and ongoing analyses regarding the operations of the Agency's loan, loan-guarantee, and grant programs, and supervises special projects as assigned;
(2) Develops and maintains Agency regulations and bulletins on pre-and post-loan policies and procedures, and provides advice and assistance to Agency staff and others regarding the achievement of program policies;
(3) Coordinates with corresponding program staffs regarding the implementation of program-wide policies;
(4) Coordinates joint program initiatives;
(5) Provides coordination and assistance on management development of REA and borrower personnel, as assigned; and collaborates with borrowers' organizations and professional groups in management development;
(6) Develops and maintains a variety of loan fund control ledgers for electric and telephone program lending authorities; and
(7) Keeps abreast of external developments by state, local and Federal regulatory and legislative bodies relating to REA programs.
(d) **Borrower Accounting Division.** This division ensures that accounting policies, systems and procedures with respect to borrowers' accounting operations meet regulatory, U.S. Department of Agriculture, General Accounting Office, Office of Management and Budget and Treasury Department requirements. The division:
(1) Provides recommendations and assistance in solving special program and administrative problems involving accounting interpretations and analysis, including the development and presentation of data to agency staff, regulatory bodies, and other agencies;
(2) Examines borrowers' records and operations and reviews expenditures of loan and other funds deposited in the REA Construction Fund Account to determine that funds are expended in conformity with the RE Act. Reviews borrowers' plant accounting system and procedures to determine compliance with REA regulations;
(3) Approves Certified Public Accountants to perform audits for borrowers and reviews their reports to determine conformance with acceptable accounting practices, procedures and standards;
(4) Develops proposed standards and procedures for Agency examination programs and evaluates adequacy and effectiveness of the review procedures; and
(5) Evaluates borrowers' accounting systems and procedures and recommends changes, as necessary, to provide for more complete and accurate reporting of borrowers' operations. Provides advice and assistance to borrowers concerning the installation and operation of accounting systems;
(e) **Area Offices.** The division is organized into four geographic area offices each of which has several field accountants located throughout the area.
§ 1700.7 Office of the Deputy Administrator—Management and Policy Support.
The Deputy Administrator—Management and Policy Support directs and coordinates the legislative, public information, administrative and budget activities of the Agency and participates with the Administrator and other officials in planning and formulating the programs, policies and other functions of the Agency. Activities are carried out by an Assistant Administrator—Management and others who report directly to the Deputy Administrator.
§ 1700.8 Office of Assistant Administrator—Management.
The Assistant Administrator—Management directs and coordinates the general administrative activities of the agency, participates with the Administrator and Deputy Administrators and other officials in planning and formulating the programs and activities of the agency. The Office of Budget and four other divisions are directed and coordinated by the Assistant Administrator—Management.
(a) The Office of Budget administers the budgetary and financial
management program of the Agency. The office:
(1) Determines the annual funding needs for current and multi-year forecasts, participating with the Administrator in presenting and supporting the Agency's budget and program plans; and
(2) Administers budget execution, apportionment, allotment and use and control of all Agency funds.
(b) The Personnel Management Division administers the personnel program of the Agency, covering both headquarters and field personnel. The division:
(1) Administers the provisions of the Classification Act, to achieve uniform application of position classification principles and standards to all REA positions; conducts organization studies and develops recommendations for changes; develops and administers the Agency's personnel management evaluation activities;
(2) Administers the employment program for the Agency, including staffing, recruitment, placement and separation; administers the Agency's merit promotion program; maintains liaison with the National Finance Center on personnel data processing activities including payroll;
(3) Administers Agency responsibilities for employee relations including: grievances and appeals, performance appraisals, performance recognition system, conflict of interest, awards, benefits, and leave;
(4) Directs, coordinates, and evaluates a program of employee training to achieve the maximum utilization of skills and abilities of personnel; conducts training sessions; plans and directs conferences; prepares training budget; approves training requests; and coordinates an information program for foreign visitors;
(5) Provides advice and assistance to Agency officials and employees to ensure sound and effective administration of the Agency's personnel program;
(6) Maintains working relations and liaison on personnel management matters with the staff and other agencies of the Department and other government agencies; and
(7) Participates with the Administrator, in conjunction with the Equal Opportunity and Civil Rights Staff, in the implementation and enforcement of USDA equal employment opportunity programs (see § 1700.2(c)(2)); coordinates equal employment opportunity complaint system with the Department; develops and administers the Agency's Federal Equal Opportunity Recruitment Program.
(c) The Administrative Services Division administers a wide array of management services. The division administers:
(1) General services involving contracting and procurement, space management, property and supplies management, records management and communications;
(2) The Agency's rulemaking and regulatory review activities, coordinating with the Office of the Federal Register, the Office of the General Counsel, and the Office of Management and Budget; and
(3) The Agency's publications issuance system and the forms and report program.
(d) The Automated Information Systems Division analyzes the application of data processing to REA program activities, including feasibility studies of the costs and benefits of automated data processing. The division:
(1) Establishes standards and procedures for developing, maintaining and using the Agency's major automated systems covering borrower information, loan accounting and special management programs; performs systems analyses, development, and programming; and ensures data security;
(2) Operates the data processing equipment of the Agency, including the conversion of data from source documents and the preparation of statements, reports, analyses, and other information, and provides training and assistance to users; and
(3) Collects and analyzes financial, operating, and other statistical data obtained from borrowers and other sources, and prepares reports on the progress and status of the programs of REA and the RTB.
(e) The Financial Operations Division administers the fiscal accounting program of the agency and the RTB. The division:
(1) Develops, recommends and implements accounting policies, systems, and procedures regarding the Agency's and RTB's operations;
(2) Maintains accounts to provide control over and accountability for all funds, assets, liabilities, income and expenses of the Agency and the RTB; and prepares reports required by REA, RTB, the U.S. Department of Agriculture, and other government agencies;
(3) Examines and certifies for payment, vouchers and invoices covering administrative expenses and loan fund advances of the Agency and the RTB;
(4) Reviews, examines and processes monthly billings and debt service payments for REA and RTB loans;
(5) Reviews, examines and processes loan fund advances, billings, debt service payments and all other accounting related activities connected with Federal Financial Bank loans to REA borrowers; and
(6) Maintains custody of the original copies of notes and mortgages and certain loan collateral.
§ 1700.9 Information, legislation, policy and management analysis.
The Deputy Administrator—Management and Policy Support, directs two separate staffs of the Agency dealing with public information and legislation, and policy and management analysis.
(a) The Legislative and Public Affairs Staff performs the following functions:
(1) Analyzes the policy, programs and procedural implications of Federal and State legislation affecting REA programs; prepares special reports for the Administrator on legislative affairs; and responds to inquiries from Congress and others concerning REA programs;
(2) Maintains liaison with the Department's legislative staff and with congressional offices;
(3) Manages the information activities of the Agency to provide borrowers and the public with timely information concerning the operations, status, progress and accomplishments of the rural electrification, rural telephone and rural development programs;
(4) Evaluates the public information activities of the Agency and advises on actions that will improve public understanding and acceptance of Agency functions; and
(5) Administers the public information provisions of 5 U.S.C. 551 et seq., the Administrative Procedure Act.
(b) The Policy and Management Analysis Staff performs the following functions:
(1) Coordinates the development and monitors the implementation of the Agency's long-term program and management plans, ensuring that these plans are up to date at all times;
(2) Ensures that these long-term plans include quality-improvement, efficiency, and cost saving initiatives;
(3) Ensures that audit resolutions are incorporated in the Agency's strategic planning and other processes for establishing goals and objectives; and
(4) Initiates and coordinates management productivity programs of the Agency.
§§ 1700.10—1700.19 [Reserved]
3. Section 1700.24 is revised to read as follows:
§ 1700.24 Loans and grants pursuant to section 313 of the RE Act.
These zero-interest loans and grants are made to borrowers under the RE Act for the purpose of promoting rural economic development and rural job creation projects. Selection and approval of applications for zero-interest loans and grants rests solely within the discretion of the Administrator. (See 7 CFR part 1703.)
4. Section 1700.25 is revised to read as follows:
§ 1700.25 Other loan authorities.
(a) The Administrator has authority under section 314 of the RE Act to guarantee 90 percent of the principal and interest of loans made by qualified private lenders to finance electric and telephone facilities in rural areas. (See 7 CFR parts 1712 and 1739.) The Administrator also has authority under section 502 of the RE Act to make grants and reduced interest loans to promote business incubator programs or for the creation or operation of business incubators in rural areas. Authority is also granted to the Administrator by the Rural Economic Development Act of 1990 (7 U.S.C. 950aaa et seq.) to provide financial assistance for distance learning and medical link programs.
(b) The Administrator has authority under section 5 of the RE Act to make loans to electric borrowers for the purpose of financing the wiring of the premises of persons in rural areas and for the purchase and installation of electrical and plumbing appliances and equipment, including machinery. The Administrator also has authority under the Consolidated Farm and Rural Development Act (7 U.S.C. 1921 et seq.) to finance community antenna television (CATV) services and facilities. Funds have not been appropriated for these purposes since 1969 in the case of section 5 loans and not since 1981 in the case of CATV loans.
Dated: February 3, 1992.
Michael M.F. Liu,
Acting Administrator.
[FR Doc. 92–3105 Filed 2–21–92; 8:45 am]
BILLING CODE 3410–15–M
SUMMARY: This notice advises the public that the Small Business Administration (SBA) is establishing a waiver of the "Nonmanufacturer Rule" for the classes of products listed in the SUPPLEMENTARY INFORMATION section. Waivers are being granted for these classes of products because no small business manufacturer or processor is available to participate in the Federal procurement market. The effect of a waiver is to allow an otherwise qualified small business regular dealer to supply the product of any domestic manufacturer or processor on a Federal supply contract set aside for small business or awarded through the SBA 8(a) program.
EFFECTIVE DATE: February 24, 1992.
FOR FURTHER INFORMATION CONTACT: James Fairbairn, Industrial Specialist, phone (202) 205–6465.
SUPPLEMENTARY INFORMATION: SBA is establishing a waiver of the "Nonmanufacturer Rule" for the following classes of products:
| SIC | PSC | Classes of products granted waivers |
|-----|-----|-----------------------------------|
| 3537 | 2320 | Four wheel utility trucks. |
| 3711 | 2420 | Wheeled tractors. |
| 3621 | 6105 | Electric motors. |
| 3699 | 6135 | Nuclear batteries. |
| 2819 | 6810 | Calcium nitrate. |
| xxxx | 6810 | Hydrocarbon diluent. |
| 2819 | 6810 | Boric acid. |
| 2873 | 6810 | Nitric acid. |
| 2819 | 6810 | N-dodecane. |
| 2819 | 6810 | Hydrofluoric acid. |
| 2869 | 6810 | Methyl isobutyl ketone. |
| 2812 | 6810 | Sodium hydroxide. |
1 Standard Industrial Code.
2 Products and Service code.
On November 15, 1988, Public Law 100–656 incorporated into the Small Business Act the existing SBA policy that recipients of contracts set aside for small business or the SBA 8(a) Program shall provide the products of small business manufacturers or processors. This requirement is commonly known as the "Nonmanufacturer Rule". The SBA regulations imposing this requirement are found in 13 CFR 121.906(b) and 121.1106(b). Section 303(h) of the law also provided for waiver of this requirement by SBA for any "class of products" for which there are no small business manufacturers or processors in the Federal market. Section 210 of Public Law 101–574 subsequently amended the language to allow for waivers of classes of products where there are no small business manufacturers or processors "available to participate in the Federal procurement market." (emphasis added). A class of products is considered to be a particular Product and Service Code (PSC) under the Federal Procurement Data System or an SBA recognized product line within a PSC. To be considered available to participate in the Federal procurement market, a small business must have been awarded a contract by the Federal government to supply that particular class of products, either directly or through a dealer, or offered on a solicitation within the past two years from the date of request for waiver. SBA has been requested to issue a waiver for each of the classes of products listed above because of an apparent lack of any small business manufacturers or processors available to participate in the Federal procurement market. SBA searched its Procurement Automated Source System (PASS) for small business manufacturers or processors. None were identified as available to participate in the Federal procurement market. We then published a notice to the public in the Federal Register on October 29, 1991 (56 FR 55637) stating our intention to grant waivers for these classes of products unless sources were found. The notice described the legal provisions for a waiver, how SBA defines "available to participate in the Federal procurement market", and requested information on small business manufacturers or processors for these classes of products.
Due to administrative error, the PSC of four wheel drive utility trucks was incorrectly listed in the notice of intent to waive the Rule on October 29, 1991. That error was corrected by notice to the public in the Federal Register on November 26, 1991 (FR 56 59902). The proper PSC is 2320.
We received only one comment letter in response to the notice of proposed intent to issue waivers. The General Services Administration (GSA) recommended that a waiver not be granted for passenger automobiles. The issues raised by GSA are complex and require further study. The final disposition of passenger automobiles will, therefore, be the subject of separate action. All other classes of products identified in the notice of proposed intent are included in this notice of final waiver. These waivers are thus granted pursuant to statutory authority under section 210 of Public Law 101–574. A waiver is for an indefinite period, but is subject to an annual review or upon receipt of information indicating that the conditions justifying a waiver no longer exist. If SBA determines that the conditions justifying a waiver no longer exist, the waiver will be terminated. That termination will be published in the Federal Register.
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Parts 1 and 602
[T.D. 8396]
RIN 1545–AP69
Conclusive Presumption of Worthlessness of Debts Held by Banks
AGENCY: Internal Revenue Service, Treasury.
ACTION: Final regulations.
SUMMARY: This document contains final regulations relating to a bank's determination of worthlessness of a debt. These regulations provide greater certainty in the treatment of bank bad debts, by providing for a conclusive presumption of worthlessness of debts based on the application of a single set of standards for both regulatory and tax accounting purposes.
EFFECTIVE DATE: These regulations are effective for taxable years ending on or after December 31, 1991.
FOR FURTHER INFORMATION CONTACT: Bernita L. Thigpen, telephone 202–566–3516 (not a toll–free number).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information contained in these final regulations has been reviewed and approved by the Office of Management and Budget in accordance with the requirements of the Paperwork Reduction Act of 1980 (44 U.S.C. 3504(h)) under control number 1545–1254. The estimated average annual burden per respondent to complete form 3115 is 26.96 hours.
These estimates are an approximation of the average time expected to be necessary for a collection of information. They are based on such information as is available to the Internal Revenue Service. Individual respondents may require greater or less time, depending or their particular circumstances.
Comments concerning the accuracy of this burden estimate and suggestions for reducing this burden should be directed to the Internal Revenue Service, Attn: IRS Reports Clearance Officer, T:FP, Washington DC, 20224, and to the Office of Management and Budget, Attn: Desk Officer for the Department of the Treasury, Office of Information and Regulatory Affairs, Washington, DC, 20503.
Background
On May 29, 1991, the Internal Revenue Service published proposed regulations under section 166 of the Internal Revenue Code of 1986 in the Federal Register (56 FR 24154). Written comments on those proposed regulations were received from the public. On August 9, 1991, a public hearing was held concerning the regulations. After consideration of all of the written comments received and the statements made at the public hearing, the proposed regulations are adopted as modified by this Treasury Decision.
Explanation of Provisions
Section 166 of the Internal Revenue Code and the regulations thereunder allow a deduction for a business debt that becomes wholly or partially worthless within the taxable year, if certain requirements are met. All pertinent evidence, including the value of any collateral securing the debt and the financial condition of the debtor, generally is taken into account in determining worthlessness. See § 1.166–2(a).
The existing regulations provide a special rule (the "existing presumption") for banks (and certain other regulated corporations), under which a debt charged off in a taxable year is conclusively presumed to have become worthless in that year if the charge-off is in obedience to a specific order of the bank's supervisory authority, or in accordance with regulatory policy provided that the supervisory authority confirms in writing upon its first audit subsequent to the charge-off that the charge-off would have been ordered had the bank been audited on the date of the charge-off. See § 1.166–2(d)(1).
Sections 1.166–2(d)(3) and (4) were proposed to provide new special rules permitting a supervised bank (including a thrift institution) to elect a method of accounting under which it may conform its tax accounting for bad debts to its regulatory accounting, provided certain conditions are satisfied. Under these rules, debts that are charged off pursuant to specific orders of the bank's supervisory authority or that are classified by the bank as loss assets under applicable regulatory standards are conclusively presumed to have become worthless in the taxable year of the charge-offs (the "conformity presumption"). The extent to which the proposed regulations have been modified in response to comments received is described below.
Comments on Specific Provisions
Prop. Reg. § 1.166–2(d)(3)(i): Conformity Election
Under the proposed regulations, the conformity election is available only to banks, as defined in proposed § 1.166–2(d)(4)(i). Several commentators suggested that the election also be made available to non-bank affiliates of a bank, including a bank's subsidiaries and its holding company, because these non-bank affiliates are subject to supervision by the bank's supervisory authority. The commentators argued that these regulated non-banks should be eligible for the conformity presumption because they are eligible for the existing presumption under § 1.166–2(d)(1), which applies more generally to banks and certain other regulated corporations.
The Treasury Department's study on the appropriate criteria to be used in determining whether a debt is worthless for Federal income tax purposes concludes that the regulatory criteria governing the charge-off of debts by banks are sufficiently similar to the criteria for worthlessness under section 166 to make regulatory criteria and examination by the regulatory authorities an acceptable surrogate for an independent investigation by the Internal Revenue Service. See Report to the Congress on the Tax Treatment of Bad Debts by Financial Institutions at 19–24 (Treasury Department, September 1991). The same degree of acceptability has not been demonstrated overall with respect to regulated corporations other than banks, nor is there any appropriate basis for attempting to distinguish among the various non-banks based on the level of regulatory scrutiny. Moreover, the existing presumption remains available to regulated corporations that are not banks and, thus, do not qualify for the new conformity election. Accordingly, the final regulations retain the rule of the proposed regulations.
Prop. Reg. § 1.166–2(d)(3)(ii): Conclusive Presumption
a. Loss classification. The proposed regulations generally provide that a debt charged off by a bank, in whole or in part, for regulatory purposes is conclusively presumed to have become worthless for tax purposes in the year it is charged off, provided the charge-off results from a specific order of the bank's supervisory authority or corresponds to the bank's classification
of that debt as a loss asset for regulatory purposes. Commentators requested that the conformity presumption also be applied to assets that are treated as debts for tax purposes, even if the assets are not so treated for regulatory purposes and, therefore, are not subject to regulatory loss classification standards. In particular, commentators requested that the conformity presumption apply to loans accounted for on a cost recovery basis, interest accrual reversals, and in-substance foreclosures. Other commentators argued that the conformity presumption should be extended to charge-offs of debts that are classified as substandard or doubtful, rather than loss, or to debts that are classified as doubtful when charged off, but that become loss assets by year-end.
The final regulations do not adopt these comments. The regulations limit the conformity presumption to debts classified as loss assets for regulatory purposes because the regulatory standards for classification of debts as loss assets are similar to the tax standards for determining worthlessness. See Report to the Congress on the Tax Treatment of Bad Debts by Financial Institutions, supra. If there were no requirement that a debt be classified as a loss asset for regulatory purposes, there would be no assurance that the charge-off was based on criteria that were consistent with Federal income tax principals and the bad debt deduction could be premature or excessive.
b. Debts charged off in wrong year. Commentators also asked for guidance on the tax treatment of a debt that is charged off in one year, when a bank's supervisory authority subsequently determines it should have been charged off in an earlier year. The commentators suggested that the debt should be presumed worthless for tax purposes in the year of the charge-off rather than in the earlier year, despite the after-the-fact determination by the supervisory authority.
It is consistent with the concept of a conclusive presumption that a bank be permitted to claim a tax deduction for a debt charge-off for a year in which the bank satisfies the requirements of the presumption, notwithstanding that its regulator subsequently determines that the charge-off should have been made in an earlier year. Accordingly, the final regulations provide that a charge-off qualifies for the presumption in the year of the charge-off, provided the requirements of the regulations are otherwise satisfied. A pattern of charge-offs in the wrong year, however, may result in revocation of the bank's election.
Prop. Reg. § 1.166–2(d)(3)(iii): Requirements
a. Express determination. The proposed regulations provide that a bank qualifies for the conformity presumption only if its supervisory authority expressly determines, in connection with its most recent examination involving the bank's loan review process, that the bank maintains and applies loan review and loss classification standards that are consistent with those of the supervisory authority. Commentators requested guidance as to the form of the express determination and suggested that it be a standardized document that is separate from the confidential bank examination report. Commentators also asked that the regulations clarify which of a bank's supervisory authorities is required to provide the express determination in the case of a bank that is regulated by more than one supervisory authority. In addition, commentators suggested that relief be provided if the supervisory authority inadvertently fails to provide the determination.
In response to these comments, the Internal Revenue Service is releasing concurrently with these regulations a revenue procedure (Rev. Proc. 92–18, to be published in Internal Revenue Bulletin No. 1992–10, (March 9, 1992) that sets forth the form and content of the express determination required by these regulations. Pursuant to Rev. Proc. 92–18, the determination is to be in the form of a letter, signed by the examiner-in-charge, that is not part of a bank's confidential examination report. In addition, the final regulations clarify that the express determination is to be provided by the supervisory authority that is the "appropriate Federal banking agency" as that term is defined in 12 U.S.C. 1813(g). (The supervisory authority is the Farm Credit Administration in the case of a bank that is an institution in the Farm Credit System. See the discussion under subheading "Definition of 'bank' in this preamble, below.) The regulations, however, do not provide relief for an inadvertent failure of the supervisory authority to issue an express determination letter. Service examiners generally will not know whether the failure to issue the letter was intentional or inadvertent.
b. Deduction required. Commentators objected to the requirement that banks claim a deduction for all debts that qualify for the conformity presumption in the year the debts are charged off. More specifically, they requested that this requirement not apply in the case of partially worthless debts because, under existing rules, a bank may claim a deduction for a partially worthless debt in the year it charges off the debt or in a later year until the debt becomes totally worthless.
The conformity presumption provides greater certainty and consistency in the tax treatment of bank bad debts by permitting a bank to elect to conform its tax accounting for bad debts to its regulatory accounting. Permitting a bank to claim a bad debt deduction for a year subsequent to the year in which a debt is charged off as worthless for regulatory purposes is inconsistent with tax-book conformity. The final regulations, therefore, continue the rule of the proposed regulations on this point.
In addition, the final regulations provide that, if a conformity election is in effect, a bad debt deduction for a debt that is subject to regulatory loss classification standards is allowed for a taxable year only to the extent that the debt is conclusively presumed to have become worthless under the presumption during that year. Only debt charge-offs that are outside the scope of the conclusive presumption because the debts are not subject to regulatory loss classification standards may be accounted for under the general rules of section 166. The proposed regulations cited reporting standards proposed by the Federal Financial Institutions Examination Council as an example of a situation in which debts would be outside the scope of the conclusive presumption. These proposed standards, however, have been withdrawn. See 56 FR 37214 (8–5–91). Most debts are subject to regulatory loss classification standards. Therefore, if a bank makes the conformity election, deductions will be allowed for such debts only for the year in which the debts are conclusively presumed to become worthless under these regulations.
Prop. Reg. § 1.166–2(d)(3)(iv): Election
a. Effective date. The conformity election was proposed to be available for taxable years ending after finalization of the regulations. Commentators requested that the regulations be effective retroactively for taxable years beginning after December 31, 1986. These commentators stated that the repeal of the section 585(b) reserve method of accounting for large banks for taxable years beginning after 1986 placed more of an emphasis on a bank's deductions for specific debts and increased the need for a conclusive presumption of worthlessness. In
addition, they argued that the Office of the Comptroller of the Currency (the "OCC") changed its practice during those years and did not provide written letters confirming voluntary charge-offs of specific debts.
The final regulations are effective for taxable years ending on or after December 31, 1991. Prior to the publication of the regulations, banks presumably did not precisely conform their bad debt deductions and their classification of debts as loss assets. Moreover, their supervisory authorities were not making express determinations that the banks maintained and applied loan review and loss classification standards that were consistent with those of the supervisory authorities. This is an essential element of the regulations and precludes their retroactive application.
b. Election requirements. Under the proposed regulations, a bank elects the conformity presumption for a taxable year (and all succeeding taxable years) by attaching a written statement to its return in which it declares that certain requirements of the regulations are satisfied and will continue to be satisfied until the election is revoked. Some commentators objected to the "future compliance" portion of the declaration. Others requested that banks be permitted to make the conformity election on a bank-by-bank basis, rather than on a group basis.
In response to these comments, the final regulations do not require a bank to represent its future intent when making an election. They do require, however, that the bank represent at the time the election is made that the express determination requirement is met. In addition, the final regulations clarify that the election is to be made on a bank-by-bank basis, rather than on a group basis. This is the approach taken when banks adopt the reserve or specific charge-off method of accounting for bad debts and when large banks that are required to change from the reserve method of accounting pursuant to section 585(c) make elections with respect to that change.
c. Method of accounting. Under the proposed regulations, the making or revoking of the conformity election is a change in the bank's method of accounting. Commentators suggested that the making of the conformity election is not a method change but a change in the manner in which the Service audits bad debts.
The making or revoking of the conformity election affects the treatment of a material item in that it changes the timing of a bank's bad debt deduction. Accordingly, the final regulations continue to treat the making or revoking of the election as a change in method of accounting. Therefore, the regulations require that the bank file a Form 3115 (Application for change in Accounting Method) when it makes or revokes the election. When making the election, the bank must provide a declaration that it currently satisfies the express determination requirement in the space provided on the form for "Other changes in method of accounting" (Schedule D, Part V of Form 3115, as revised in July of 1991). The form for the initial election must be attached to the bank's income tax return for the year of the election, and the Commissioner's consent will be granted automatically. The final regulations also provide similar rules for a new bank that adopts this method of accounting when it adopts its overall method of accounting for bad debts. To make a conformity election after a previous election has been revoked or to voluntarily revoke the election, the bank must obtain the advance consent of the Commissioner by filing a Form 3115 with the National Office pursuant to section 446(e) and § 1.446–1(e) (including any applicable procedure prescribed thereunder).
The change in method of accounting that results from making or revoking the conformity election is implemented under a cut-off approach and no adjustment under section 481(a) is required or permitted. The final regulations provide a special rule for the situation in which the book and tax bases of a debt are not equal as a result of there having been a partial charge-off for regulatory purposes for which no tax deduction was claimed by the time of the conformity election. Under this rule, the deduction reflecting the partial charge-off must be claimed in the first post-election year in which there is any further charge-off of the debt for regulatory purposes.
d. Transition period. The proposed regulations provide a transition rule that permits a bank to make the conformity election prior to receiving its first express determination from its supervisory authority. The proposed rules require a bank to represent that its internal loan review and loss classification process was not criticized by its supervisory authority on its most recent regulatory examination. Many commentators stated that few banks, for various reasons, would be able to make this representation. In response to this comment, the final regulations replace the "no criticism" representation with a requirement that the bank represent that it maintains and applies loan review and loss classification standards that are consistent with those of its supervisory authority, i.e., its appropriate Federal banking agency.
Prop. Reg. § 1.168–2(d)(3)(v): Revocation by Commissioner
The proposed regulations authorize the Commissioner to revoke a conformity election, but only if the bank fails to satisfy the conformity requirements for any taxable year or if it has claimed deductions that exceed those warranted by the exercise of reasonable business judgment in applying the regulatory standards. Commentators argued that the Commissioner should not be authorized to revoke a conformity election if a bank substantially complies with the election's requirements. Commentators also requested clarification as to whether a bank's failure to satisfy the conformity requirements or a bank's claiming of excessive deductions automatically revoked the election or were merely grounds for revocation by the Commissioner.
A supervisory authority's express determination, as described in Rev. Proc. 92–18, permits some flexibility in the application of a bank's loan review and loss classification standards, in that immaterial deviations from regulatory standards in the case of individual loans do not preclude the issuance of an express determination. In view of this flexibility, the final regulations do not adopt a substantial compliance standard.
The final regulations clarify that a bank's claiming of excessive charge-offs and deductions under the conformity election is merely grounds for revocation of that election by the Commissioner and does not result in automatic revocation. The final regulations also clarify that the Commissioner may revoke a conformity election if a bank fails to follow the method of accounting dictated by the election.
The final regulations do provide, however, that an election is revoked automatically if a bank fails to obtain the requisite express determination. The revocation generally is effective as of the beginning of the taxable year that includes the date as of which the bank's loans were examined. If the bank relied on the transition rule for making the conformity election prior to its first opportunity to obtain an express determination, the revocation is effective as of the beginning of the taxable year of the bank's conformity election or, if later, the earliest taxable year for which tax may be assessed.
Classification of Assets and Securities Held by Banks” (See Attachment to Comptroller of the Currency Banking Circular No. 127, Rev. 4–20–91, Comptroller of the Currency, Communications Department, Washington, DC 20219) or similar guidance issued by the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve, or the Farm Credit Administration; or for institutions under the supervision of the Office of Thrift Supervision, 12 CFR 563.180(b)(3).
(iii) Election—(A) In general. An election under this paragraph (d)(3) is to be made on bank-by-bank basis and constitutes either the adoption of or a change in method of accounting, depending on the particular bank’s facts. A change in method of accounting that results from the making of an election under this paragraph (d)(3) has the effects described in paragraph (d)(3)(iii)(B) of this section.
(B) Effect of change in method of accounting. A change in method of accounting resulting from an election under this paragraph (d)(3) does not require or permit an adjustment under section 481(a). Under this cut-off approach—
(1) There is no change in the § 1.1011–1 adjusted basis of the bank’s existing debts (as determined under the bank’s former method of accounting for bad debts) as a result of the change in method of accounting;
(2) With respect to debts that are subject to regulatory loss classification standards and are held by the bank at the beginning of the year of change (to the extent that they have not been charged off for regulatory purposes), and with respect to debts subject to regulatory loss classification standards that are originated or acquired subsequent to the beginning of the year of change, bad debt deductions in the year of change and thereafter are determined under the method of accounting for bad debts prescribed by this paragraph (d)(3);
(3) With respect to debts that are not subject to regulatory loss classification standards or that have been totally charged off prior to the year of change, bad debt deductions are determined under the general rules of section 166; and
(4) If there was any partial charge-off of a debt in a prechange year, any portion of which was not claimed as a deduction, the deduction reflecting that partial charge-off must be taken in the first year in which there is any further charge-off of the debt for regulatory purposes.
(C) Procedures—(1) In general. A new bank adopts the method of accounting under this paragraph (d)(3) for any taxable year ending on or after December 31, 1991 (and for all subsequent taxable years) when it adopts its overall method of accounting for bad debts, by attaching a statement to this effect to its income tax return for that year. Any other bank makes an election for any taxable year ending on or after December 31, 1991 (and for all subsequent taxable years) by filing a completed Form 3115 (Application for Change in Accounting Method) in accordance with the rules of paragraph (d)(3)(iii)(C)(2) or (3) of this section. The statement or Form 3115 must include the name, address, and taxpayer identification number of the electing bank and contain a declaration that the express determination requirement of paragraph (d)(3)(iii)(D) of this section is satisfied for the taxable year of the election. When a Form 3115 is used, the declaration must be made in the space provided on the form for “Other changes in method of accounting.” The words “ELECTION UNDER § 1.166–2(d)(3)” must be typed or legibly printed at the top of the statement or page 1 of the Form 3115.
(2) First election. The first time a bank makes this election, the statement or Form 3115 must be attached to the bank’s timely filed return (taking into account extensions of time to file) for the first taxable year covered by the election. The consent of the Commissioner to make a change in method of accounting under this paragraph (d)(3) is granted, pursuant to section 446(e), to any bank that makes the election in accordance with this paragraph (d)(3)(iii)(C), provided the bank has not made a prior election under this paragraph (d)(3).
(3) Subsequent elections. The advance consent of the Commissioner is required to make any election under this paragraph (d)(3) after a previous election has been revoked pursuant to paragraph (d)(3)(iv) of this section. This consent must be requested under the procedures, terms, and conditions prescribed under the authority of section 446(e) and § 1.446–1(e) for requesting a change in method of accounting.
(D) Express determination requirement. In connection with its most recent examination involving the bank’s loan review process, the bank’s supervisory authority must have made an express determination (in accordance with any applicable administrative procedure prescribed hereunder) that the bank maintains and applies loan review and loss classification standards that are consistent with the regulatory standards of that supervisory authority. For purposes of this paragraph (d)(3)(iii)(D), the supervisory authority of a bank is the “appropriate Federal banking agency” for the bank, as that term is defined in 12 U.S.C. 1813(q) or, in the case of an institution in the Farm Credit System, the Farm Credit Administration.
(E) Transition period election. For taxable years ending before completion of the first examination of the bank by its supervisory authority (as defined in paragraph (d)(3)(iii)(D) of this section) that is after December 31, 1991, and that involves the bank’s loan review process, the statement or Form 3115 filed by the bank must include a declaration that the bank maintains and applies loan review and loss classification standards that are consistent with the regulatory standards of that supervisory authority. A bank that makes this declaration is deemed to satisfy the express determination requirement of paragraph (d)(3)(iii)(D) of this section for those years, even though an express determination has not yet been made.
(iv) Revocation of Election—(A) In general. Revocation of an election under this paragraph (d)(3) constitutes a change in method of accounting that has the effects described in paragraph (d)(3)(iv)(B) of this section. If an election under this paragraph (d)(3) has been revoked, a bank may make a subsequent election only under the provisions of paragraph (d)(3)(iii)(C)(3) of this section.
(B) Effect of change in method of accounting. A change in method of accounting resulting from revocation of an election under this paragraph (d)(3) does not require or permit an adjustment under section 481(a). Under this cut-off approach—
(1) There is no change in the § 1.1011–1 adjusted basis of the bank’s existing debts (as determined under this paragraph (d)(3) method or any other former method of accounting used by the bank with respect to its bad debts) as a result of the change in method of accounting; and
(2) Bad debt deductions in the year of change and thereafter with respect to all debts held by the bank, whether in existence at the beginning of the year of change or subsequently originated or acquired, are determined under the new method of accounting.
(C) Automatic revocation—(1) In general. A bank’s election under this paragraph (d)(3) is revoked automatically if, in connection with any examination involving the bank’s loan
review process by the bank's supervisory authority as defined in paragraph (d)(3)(iii)(D) of this section, the bank does not obtain the express determination required by that paragraph.
(2) Year of revocation. If a bank makes the conformity election under the transition rules of paragraph (d)(3)(iii)(E) of this section and does not obtain the express determination in connection with the first examination involving the bank's loan review process that is after December 31, 1991, the election is revoked as of the beginning of the taxable year of the election or, if later, the earliest taxable year for which tax may be assessed. In other cases in which a bank does not obtain an express determination in connection with an examination of its loan review process, the election is revoked as of the beginning of the taxable year that includes the date as of which the supervisory authority conducts the examination, even if the examination is completed in the following taxable year.
(3) Consent granted. Under the Commissioner's authority in section 446(e) and § 1.446–1(e), the bank is directed to and is granted consent to change from this paragraph (3)(1) method as of the year of revocation (year of change) prescribed by paragraph (d)(3)(iv)(C)(2) of this section.
(4) Requirements. A bank changing its method of accounting under the automatic revocation rules of this paragraph (d)(3)(iv)(C) must attach a completed Form 3115 to its income tax return for the year of revocation prescribed by paragraph (d)(3)(iv)(C)(2) of this section. The words "REVOCATION OF § 1.166–2(d)(3) ELECTION" must be typed or legibly printed at the top of page 1 of the Form 3115. If the year of revocation is a year for which the bank has already filed its income tax return, the bank must file an amended return for that year reflecting its change in method of accounting and must attach the completed Form 3115 to that amended return. The bank also must file amended returns reflecting the new method of accounting for all subsequent taxable years for which returns have been filed and tax may be assessed.
(D) Revocation by Commissioner. An election under this paragraph (d)(3) may be revoked by the Commissioner as of the beginning of any taxable year for which a bank fails to follow the method of accounting prescribed by this paragraph. In addition, the Commissioner may revoke an election as of the beginning of any taxable year for which the Commissioner determines that a bank has taken charge-offs and deductions that, under all facts and circumstances existing at the time, were substantially in excess of those warranted by the exercise of reasonable business judgment in applying the regulatory standards of the bank's supervisory authority as defined in paragraph (d)(3)(III)(D) of this section.
(E) Voluntary revocation. A bank may apply for revocation of its election made under this paragraph (d)(3) by timely filing a completed Form 3115 for the appropriate year and obtaining the consent of the Commissioner in accordance with section 446(e) and § 1.446–1(e) (including any applicable administrative procedures prescribed thereunder). The words "REVOCATION OF § 1.166–2(d)(3) ELECTION" must be typed or legibly printed at the top of page 1 of the Form 3115. If any bank has had its election automatically revoked pursuant to paragraph (d)(3)(iv)(C) of this section and has not changed its method of accounting in accordance with the requirements of that paragraph, the Commissioner will require that any voluntary change in method of accounting under this paragraph (d)(3)(iv)(C) be implemented retroactively pursuant to the same amended return terms and conditions as are prescribed by paragraph (d)(3)(iv)(C) of this section.
(4) Definitions. For purposes of this paragraph (d)—
(i) Bank. The term "bank" has the meaning assigned to it by section 581. The term "bank" also includes any corporation that would be a bank within the meaning of section 581 except for the fact that it is a foreign corporation, but this paragraph (d) applies only with respect to loans the interest on which is effectively connected with the conduct of a banking business within the United States. In addition, the term "bank" includes a Farm Credit System institution that is subject to supervision by the Farm Credit Administration.
(ii) Charge-off. For banks regulated by the Office of Thrift Supervision, the term "charge-off" includes the establishment of specific allowances for loan losses in the amount of 100 percent of the portion of the debt classified as loss.
PART 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT
Par. 3. The authority citation for part 602 continues to read as follows:
Authority: 26 U.S.C. 7805.
§ 602.101 [Amended]
Par. 4. Section 602.101(c) is amended by adding the following entry to the table, "1.166–2 . . . 1545–1254".
Michael J. Murphy,
Acting Commissioner of Internal Revenue.
Approved: January 15, 1992.
Kenneth W. Gideon,
Assistant Secretary of the Treasury.
[FR Doc. 92–4088 Filed 2–21–92; 8:45 am]
BILLING CODE 4830–01–M
Office of Foreign Assets Control
31 CFR Parts 500, 515, 520, 535, and 575
Foreign Assets Control Regulations, Cuban Assets Control Regulations, Foreign Funds Control Regulations, Iranian Assets Control Regulations, and Iraqi Sanctions Regulations
AGENCY: Office of Foreign Assets Control, Department of the Treasury.
ACTION: Final rule, amendments.
SUMMARY: This rule amends the Foreign Assets Control Regulations, 31 CFR part 500, the Cuban Assets Control Regulations, 31 CFR part 515, the Foreign Funds Control Regulations, 31 CFR part 520, the Iranian Assets Control Regulations, 31 CFR part 535, and the Iraqi Sanctions Regulations, 31 CFR part 575 (collectively, the "Regulations"), to publish the authorization number assigned by the Office of Management and Budget to the information collection requirements contained in the Regulations.
EFFECTIVE DATE: December 19, 1991.
FOR FURTHER INFORMATION: William B. Hoffman, Chief Counsel (tel.: 202/535–6020), or Steven I. Pinter, Chief of Licensing (tel.: 202/535–9449), Office of Foreign Assets Control, Department of the Treasury, Washington, DC 20220.
SUPPLEMENTARY INFORMATION: Pursuant to the requirements of the Paperwork Reduction Act, 44 U.S.C. 3501, the Office of Foreign Assets has sought and received approval from the Office of Management and Budget for the information collection requirements of the Regulations. The authorization number reflecting this approval is being inserted into the Regulations.
Because the Regulations involve a foreign affairs function, Executive Order 12291 and the provisions of the Administrative Procedure Act, 5 U.S.C. 553, requiring notice of proposed rulemaking, opportunity for public participation, and delay in effective date, are inapplicable. Because no
notice of proposed rulemaking is required for this rule, the Regulatory Flexibility Act, 5 U.S.C. 601 et seq., does not apply.
List of subjects in 31 CFR Parts 500, 515, 520, 535 and 575
Administrative practice and procedure.
For the reasons set forth in the preamble, 31 CFR Parts 500, 515, 520, 535 and 575 are amended as follows:
PART 500—FOREIGN ASSETS CONTROL REGULATIONS
1. The authority citation for part 500 continues to read as follows:
Authority: 50 U.S.C. App. 5, as amended; E.O. 9193, 7 FR 5205, 3 CFR 1938–1943 Cum. Supp., p. 1174; E.O. 9989, 13 FR 4891, 3 CFR, 1943–1948 Comp., p. 748.
Subpart H—Miscellaneous Provisions
§ 500.901 Paperwork Reduction Act notice.
2. In § 500.901, remove control number “1505–0075” and add control number “1505–0098” in its place.
PART 515—CUBAN ASSETS CONTROL REGULATIONS
1. The authority citation for part 515 continues to read as follows:
Authority: 50 U.S.C. App. 5, as amended; 22 U.S.C. 2370(a); Proc. 3447, 27 FR 1085, 3 CFR, 1959–1963 Comp.; E.O. 9193, 7 FR 5205, 3 CFR 1938–1943 Cum. Supp., p. 1174; E.O. 9989, 13 FR 4891, 3 CFR, 1943–1948 Comp., p. 748.
Subpart I—Miscellaneous Provisions
2. Section 515.901 is revised to read as follows:
§ 515.901 Paperwork Reduction Act notice.
The information collection requirements in §§ 515.527(c), 515.542(c), 515.543, 515.544(a) and (b), 515.545(a)(1) and (2), 515.545(b), 515.546, 515.547, 515.548, 515.549(a) and (b), 515.550, 515.551(a)(1), (2), and (3), 515.552(a)(1), (2), and (3), 515.553, 515.554, 515.555, 515.556, 515.557, 515.558, 515.559, 515.560(f), 515.563(d), 515.565, and 515.801 have been approved by the Office of Management and Budget under the Paperwork Reduction Act and assigned control number 1505–0098. Collection of information on TDF 90–22.39, “Declaration, Travel to Cuba,” has been approved by the Office of Management and Budget under the Paperwork Reduction Act and assigned control number 1505–0118.
PART 520—FOREIGN FUNDS CONTROL REGULATIONS
1. The authority citation for part 520 is revised to read as follows:
Authority: 50 U.S.C. App. 5, as amended; E.O. 8389, 5 FR 1400, as amended by E.O. 8785, 8 FR 2897, E.O. 8832, 6 FR 3715, E.O. 8963, 6 FR 2897, E.O. 8832, 6 FR 3715, E.O. 8863, 6 FR 6348, E.O. 8998, 6 FR 6785, E.O. 9193, 7 FR 5205; 3 CFR, 1938–1943 Cum. Supp., p. 1174; E.O. 10348, 17 FR 3708, 3 CFR, 1949–1953 Comp., p. 871; E.O. 11281, 31 FR 7215, 3 CFR, 1966–1970 Comp., p. 546.
Subpart I—Miscellaneous Provisions
§ 520.901 Paperwork Reduction Act notice.
2. In § 520.901, remove control number “1505–0075” and add control number “1505–0098” in its place.
PART 535—IRANIAN ASSETS CONTROL REGULATIONS
1. The authority citation for part 535 continues to read as follows:
Authority: Secs. 201–207, 91 Stat. 1628; 50 U.S.C. 1701–1706; E.O. 12170, 44 FR 65729; E.O. 12205, 45 FR 24098; E.O. 12211, 45 FR 26685;
Subpart I—Miscellaneous Provisions
§ 535.905 Paperwork Reduction Act notice.
2. Remove control number “1505–0075” and add in its place control number “1505–0098.”
PART 575—THE IRAQI SANCTIONS REGULATIONS
1. The Authority citation for part 575 continues to read as follows:
Authority: 50 U.S.C. et seq.; 50 U.S.C. 1601 et seq.; 22 U.S.C. 287c; Public Law 101–513, 104 Stat. 2047–55 (Nov. 5, 1990); 3 U.S.C. 301; E.O. 12722, 55 FR 31803 (August 3, 1990); E.O. 12724, 55 FR 33089 (August 13, 1990).
Subpart I—Paperwork Reduction Act
2. Section 575.901 is added to read as follows:
§ 575.901 Paperwork Reduction Act notice.
The information collection requirements in §§ 575.202(d), 575.503, 575.508, 575.509–575.511, 575.517, 575.518, 575.520, 575.521, 575.601, 575.602, 575.603, 575.703, and 575.801 have been approved by the Office of Management and Budget and assigned control number 1505–0130. The information collection requirements of § 575.604 and the use of agency form TDF 90–22.40 have been approved by the Office of Management and Budget and assigned control number 1505–0128. The information collection requirements of § 575.605 and the use of agency form 90–22.41 have been approved by the Office of Management and Budget and assigned control number 1505–0129.
Dated: January 23, 1992.
R. Richard Newcomb,
Director, Office of Foreign Assets Control.
Approved: January 27, 1992.
Peter K. Nunez,
Assistant Secretary (Enforcement).
[FR Doc. 92–4114 Filed 2–19–92; 10:21 am]
BILLING CODE 4810–25–M
DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
50 CFR Part 625
[Docket No. 911194–1294]
Summer Flounder Fishery; Correction
AGENCY: National Marine Fisheries Service (NMFS), NOAA, Commerce.
ACTION: Emergency interim rule; correction.
SUMMARY: This document corrects errors in the emergency interim rule for the Fishery Management Plan for the Summer Flounder Fishery, which was published December 5, 1991 (56 FR 63685).
EFFECTIVE DATE: December 2, 1991 through March 5, 1992.
FOR FURTHER INFORMATION CONTACT: Richard G. Seamans, Jr., Senior Resource Policy Analyst, 508/281–9244, or Phil Williams, NMFS, National Sea Turtle Coordinator, 301/713–2322.
In rule document 91–29179 beginning on page 63685, in the issue of Thursday, December 5, 1991, make the following corrections to the SUPPLEMENTARY INFORMATION section:
1. On page 63686, under the heading “Sea Turtle Conservation,” in the third column, on the 21st line from the bottom, remove the words “Street, 1987”; and on the third line from the bottom, remove “; Ross, et al., 1990; Ross, 1991”.
2. On page 63687, in the first column, on the seventh line from the top of the page, insert “(Ross et al., 1990; Ross, 1991)” after the words “turtle increases”.
3. On page 63687, in the first column, replace the paragraph beginning on the eighth line from the top of the page, with the following paragraph: “In November and December, 1982, 144 sea turtles stranded on North Carolina beaches, including five Kemp’s ridleys (Crouse, 1985). The National Academy of Sciences report, The Decline of Sea Turtle: Causes and Prevention, analyzed
sea turtle stranding data from 1980–1985 from North Carolina ocean beaches and concluded that winter mortality of sea turtles in this area might be caused by groundfish trawling or cold stunning north of Cape Hatteras."
4. On page 63688, under the heading "Sea Turtle Conservation Measures," in the second column, on the 31st line from the bottom, insert the words "and Virginia in the EEZ" after the words "North Carolina".
Dated: February 18, 1992.
Samuel W. McKeen,
Acting Assistant Administrator for Fisheries.
National Marine Fisheries Service.
[FR Doc. 92–4176 Filed 2–21–92; 8:45 am]
BILLING CODE 3510–22–M
Proposed Rules
This section of the FEDERAL REGISTER contains notices to the public of the proposed issuance of rules and regulations. The purpose of these notices is to give interested persons an opportunity to participate in the rule making prior to the adoption of the final rules.
NUCLEAR REGULATORY COMMISSION
10 CFR Chapter 1
Issuance of Quarterly Report on the Regulatory Agenda
AGENCY: Nuclear Regulatory Commission.
ACTION: Issuance of regulatory agenda.
SUMMARY: The Nuclear Regulatory Commission (NRC) has issued the NRC Regulatory Agenda for the fourth quarter, October through December, of 1991. The agenda is issued to provide the public with information about NRC's rulemaking activities. The Regulatory Agenda is a quarterly compilation of all rules on which the NRC has recently completed action, or has proposed action, or is considering action, and of all petitions for rulemaking that the NRC has received that are pending disposition.
ADDRESSES: A copy of this report, designated NRC Regulatory Agenda (NUREG-0936) Vol. 10, No. 4, is available for inspection, and copying for a fee, at the Nuclear Regulatory Commission's Public Document Room, 2120 L Street NW. (Lower Level), Washington, DC.
In addition, the U.S. Government Printing Office (GPO) sells the NRC Regulatory Agenda. To purchase it, a customer may call (202) 512-2303 or (202) 512-2249 or write to the Superintendent of Documents, U.S. Government Printing Office, Post Office Box 37082, Washington, DC 20013-7082.
FOR FURTHER INFORMATION CONTACT: Michael T. Lesar, Chief, Rules Review Section, Regulatory Publications Branch, Division of Freedom of Information and Publications Services, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555, Telephone: (301) 492-7758, toll-free number (800) 368-5642.
Dated at Bethesda, Maryland, this 13th day of February 1992.
For the Nuclear Regulatory Commission.
Donnie H. Grimsley,
Director, Division of Freedom of Information and Publications Services, Office of Administration.
[FR Doc. 92-4174 Filed 2-21-92; 8:45 am]
BILLING CODE 7590-01-M
10 CFR Chapter I
Special Review of NRC Regulations
AGENCY: Nuclear Regulatory Commission.
ACTION: Request for comments.
SUMMARY: The Nuclear Regulatory Commission (NRC) is seeking public comment in connection with a special review of NRC regulations to determine whether regulatory burdens can be reduced without in any way reducing the protection for public health and safety and the common defense and security. The special review was directed by the Commission in a memorandum issued to the NRC staff on February 7, 1992. The review will be conducted by the NRC Committee to Review Generic Requirements (CRGR). The CRGR review effort is to be completed by April 10, 1992.
This request for comments is related to an earlier request for comments published in the Federal Register on February 4, 1992 (57 FR 4166), on the results of NRC's continuing, long term program to identify and eliminate regulatory requirements of marginal safety importance. Interested parties may wish to consider the information in the February 4, 1992 notice in developing a response to this request. The special review by CRGR will draw upon the results of that program (and any other relevant prior reviews identified).
DATES: Comment period expires March 6, 1992. To assure timely consideration in the context of the special review of regulations by CRGR, comments submitted in response to this notice must be received by close-of-business (COB), on March 6, 1992. (Because of the short response time, comments submitted in response to this notice that are received after COB on March 6, 1992, will receive consideration as comments in response to the February 4 notice, if applicable, and if received before expiration of the comment period specified in the February 4 notice.)
ADDRESSES: Mail comments to: David L. Meyer, Chief, Regulatory Publications Branch, Division of Freedom of Information and Publications Services, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555. Comments may be hand-delivered to: Room P-223, 7920 Norfolk Avenue, Bethesda, Maryland, between 7:30 am. and 4:15 pm., Federal workdays.
FOR FURTHER INFORMATION CONTACT: James Conran or Dennis Allison, Office for Analysis and Evaluation of Operational Data, U.S. Nuclear Regulatory Commission, Washington, DC 20555, (301) 492-9855 or (301) 492-4148.
SUPPLEMENTARY INFORMATION: The Nuclear Regulatory Commission (NRC) has directed that existing NRC regulations be reviewed to determine whether regulatory burdens can be reduced without in any way reducing the protection for public health and safety and the common defense and security. Guidance on how the NRC staff is to proceed in undertaking this effort was provided in a memorandum to the staff issued by the Commission on February 7, 1992. The Commission's memorandum noted:
On January 28, 1992, President Bush issued two memoranda relating to regulatory reviews. In the first memorandum, the President requested the Commission and other energy and environmental agencies to work together to streamline duplicative or inconsistent regulatory requirements. In the second memorandum, the President requested all Federal agencies to set aside a 90 day period to evaluate existing regulations and programs and to identify and accelerate action on initiatives that will eliminate any unnecessary regulatory burden or otherwise promote economic growth. New regulations are not to be issued in proposed or final form during this review period unless certain specified criteria are met.
While it is not clear that a response by an independent regulatory agency is mandatory, the Commission nevertheless believes that it can address many aspects and the spirit of the memoranda without violating our basic statutory responsibilities. This memorandum provides guidance on how this will be done.
The Commission's memorandum directed the NRC Committee on Review of Generic Requirements (CRGR) to conduct a review of existing NRC regulations to determine whether regulatory burdens can be reduced without in any way reducing the
protection of public health and safety and the common defense and security.
The NRC Committee to Review Generic Requirements (CRGR) was created in 1981 by the Commission to examine proposed new generic requirements and proposed changes to existing requirements for operating power reactors, to help assure that NRC actions do not impose unnecessary regulatory burdens. Because the CRGR and the Commission have carefully scrutinized generic regulatory requirements promulgated since that time, the primary focus of the special review to be conducted by CRGR will be on those NRC regulations promulgated prior to the creation of the CRGR, particularly those set forth in 10 CFR part 50.
In conducting this special review, the CRGR will use appropriate input from the public (including the industry and environmental groups), the NRC staff, and other Federal agencies. This special review by CRGR will also draw upon any relevant prior reviews, e.g., the NRC program to identify and eliminate requirements marginal to safety. The results of the NRC program to identify and eliminate requirements marginal to safety were described in an earlier notice published on February 4, 1992. Individuals who intend to submit comments regarding the special review of regulations by CRGR should be aware of the information in the February 4 notice, and should take into account that information in developing comments for the special review.
As a part of the special review by CRGR, a public meeting will be held in the Washington, DC area; that meeting is tentatively scheduled for March 27, 1992. Further details regarding this public meeting (i.e., exact meeting date, location, agenda, etc.) will be published in a subsequent notice prior to the meeting, as those details become available.
Interested parties are requested to provide comment on any consideration that bears significantly on the stated objectives of the special CRGR review. In doing so, commenters are requested to address the following questions (in addition to the specific questions posed for comment in the February 4, 1992, notice, as appropriate, and to the extend possible at this time):
1. Is it feasible for the NRC to consider early reduction or elimination of any existing requirements?
2. Are there likely candidates for early reduction or elimination identified in the earlier NRC staff study referred to in the February 4, 1992 notice? If so, what should be the priority (sequence and schedule) for their treatment?
3. Are there likely candidates for early reduction or elimination that were not identified in the earlier NRC staff study referred to in the February 4, 1992 notice?
4. Have adequate evaluations of safety importance and regulatory burden been completed for any identified potential candidates, including those identified by the NRC staff in the February 4, 1992 notice, or any new or different candidates identified by commenters in response to this notice?
Dated at Bethesda, Maryland, this 20th day of February, 1992.
For The Nuclear Regulatory Commission.
Edward L. Jordan,
Director, Office for Analysis and Evaluation of Operational Data.
[FR Doc. 92–4246 Filed 2–21–92; 8:45 am]
BILLING CODE 7590–01–M
PART 1301—PROCEDURES
1. The authority citation for part 1301, subpart A, continues to read as follows:
Authority: 16 U.S.C. 831–831dd, 5 U.S.C. 552.
2. Section 1301.3 is added to read as follows:
§ 1301.3 Waiver or reduction of fees.
(a) Records responsive to a request under 5 U.S.C. 552 shall be furnished without charge or at a charge reduced below that established under section 1301.2 where TVA determines, based upon information provided by a requester in support of a fee waiver request or otherwise made known to TVA, that disclosure of the requested information is in the public interest because it is likely to contribute significantly to public understanding of the operations or activities of the government and is not primarily in the commercial interest of the requester. Requests for a waiver or reduction of fees, which shall be made at the same time as the requests for records, shall be considered on a case-by-case basis.
(b) In order to determine whether the first fee waiver requirement is met—i.e., that disclosure of the requested information is in the public interest because it is likely to contribute significantly to public understanding of the operations or activities of the government—TVA shall consider the following four factors in sequence:
(1) The subject of the request: Whether the subject of the requested records concerns “the operations or activities of the government.” The subject matter of the requested records, in the context of the request, must specifically concern identifiable operations or activities of the Federal Government—with a connection that is direct and clear, not remote or attenuated. Furthermore, the records must be sought for their informative value with respect to those government operations or activities; a request for access to records for their intrinsic informational content alone will not satisfy this threshold consideration.
(2) The informational value of the information to be disclosed: Whether the disclosure is “likely to contribute” to an understanding of government operations or activities. The disclosable portions of the requested records must be meaningfully informative on specific government operations or activities in order to hold potential for contributing to increased public understanding of those operations and activities. The disclosure of information that already is in the public domain, in either a
duplicative or a substantially identical form, would not be likely to contribute to such understanding, as nothing new would be added to the public record.
(3) The contribution to an understanding of the subject by the public likely to result from disclosure: Whether disclosure of the requested information will contribute to "public understanding."
The disclosure must contribute to the understanding of the public at large, as opposed to the individual understanding of the requester or a narrow segment of interested persons. A requester's identity and qualification—e.g., expertise in the subject area and ability and intention to effectively convey information to the general public—should be considered. It reasonably may be presumed that a representative of the news media (as defined in paragraph 1301.2(b)(7)) who has access to the means of public dissemination readily will be able to satisfy this consideration. Requests from libraries or other record repositories (or requesters who intend merely to disseminate information to such institutions) shall be analyzed, like those of other requesters, to identify a particular person who represents that he actually will use the requested information in scholarly or other analytic work and then disseminate it to the general public.
(4) The significance of the contribution to public understanding: Whether the disclosure is likely to contribute "significantly" to public understanding of government operations or activities. The public's understanding of the subject matter in question, as compared to the level of public understanding existing prior to the disclosure, must be likely to be enhanced by the disclosure to a significant extent. TVA shall not make separate value judgments as to whether information, even though it in fact would contribute significantly to public understanding of the operations or activities of the government, is "important" enough to be made public.
(c) In order to determine whether the second fee waiver requirement is met—i.e., that disclosure of the requested information is not primarily in the commercial interest of the requester—TVA shall consider the following two factors in sequence:
(1) The existence and magnitude of a commercial interest: Whether the requester has a commercial interest that would be furthered by the requested disclosure. TVA shall consider all commercial interests of the requester (with reference to the definition of "commercial use" in paragraph 1301.2(b)(4)), or any person on whose behalf the requester may be acting, but shall consider only those interests which would be furthered by the requested disclosure. In assessing the magnitude of identified commercial interests, consideration shall be given to the role that such FOIA-disclosed information plays with respect to those commercial interests, as well as to the extent to which FOIA disclosures serve those interests overall. Requesters shall be given a reasonable opportunity in the administrative process to provide information bearing upon this consideration.
(2) The primary interest in disclosure: Whether the magnitude of the identified commercial interest of the requester is sufficiently large, in comparison with the public interest in disclosure, that disclosure is "primarily in the commercial interest of the requester." A fee waiver or reduction is warranted only where, once the "public interest" standard set out in paragraph (b) of this section is satisfied, that public interest can fairly be regarded as greater in magnitude than that of the requester's commercial interest in disclosure. TVA shall ordinarily presume that, where a news media requester has satisfied the "public interest" standard, that will be the interest primarily served by disclosure to that requester. Disclosure to data brokers or others who compile and market government information for direct economic return shall not be presumed to primarily serve the "public interest."
(d) Where only a portion of the requested records satisfies both of the requirements for a waiver or reduction of fees under this paragraph, a waiver or reduction shall be granted only as to that portion.
(e) Requests for the waiver or reduction of fees shall address each of the factors listed in paragraphs (b) and (c) of this section, as they apply to each record request.
(f) A denial of a request for reduced fees or of a request for waiver of fees, in whole or in part, will be made in writing, will state the reasons for the denial, and will notify the requester of the right to appeal the denial. The appeal process for denial of a fee waiver or reduction of fees shall be identical to the appeal process for denial of a requested record and shall be subject to the procedures detailed in section 1301.1(c)(2).
Louis S. Grande,
Vice President, Information Services.
[FR Doc. 91–4107 Filed 2–21–92; 8:45 am]
BILLING CODE 8120–08–M
DEPARTMENT OF LABOR
Office of the Secretary
20 CFR Chs. I, IV, V, VI, VII, and IX
29 CFR Subtitle A and Chs. II, IV, V, XVII, and XXV
30 CFR Ch. I
41 CFR Ch. 50, Ch. 60, and Ch. 61
48 CFR Ch. 29
Federal Regulatory Review
AGENCY: Office of the Secretary, Labor.
ACTION: Request for comments on Department of Labor Regulations.
SUMMARY: The President has directed that the Department and other federal agencies use the ninety day period beginning January 28, 1992,
... to evaluate existing regulations and programs and to identify and accelerate action on initiatives that will eliminate any unnecessary regulatory burden or otherwise promote economic growth.
A part of this effort, the President also has directed that the Department should work with the public and other interested parties to try to identify those regulations and programs, both under consideration and currently in place, that impose substantial costs on the economy relative to the benefits achieved or otherwise impose detrimental burdens on the economy and on economic growth.
As part of this review effort, the Department is seeking comments and suggestions from the public on current regulations and those under consideration in terms of the burdens placed on the economy, inhibitions to growth, and benefits achieved.
DATES: Comments are due by March 20, 1992.
ADDRESSES: Send comments to Roland G. Droitsch, Deputy Assistant Secretary for Policy, U.S. Department of Labor, room S–2312, Frances Perkins Building, 200 Constitution Avenue, NW., Washington, DC 20210.
FOR FURTHER INFORMATION CONTACT: Roland G. Droitsch, Deputy Assistant Secretary for Policy, U.S. Department of Labor. Telephone (202) 523–9058.
SUPPLEMENTARY INFORMATION:
Excessive regulation and red tape can impose an enormous burden on our economy—a hidden tax on American households in the form of higher prices for goods and services. At the same time, regulations may facilitate the
better working of labor and other markets, may promote both jobs and growth, and improve worker safety and health. The President has imposed a ninety-day moratorium on the issuance of any proposed or final rules that do not meet one of exemptions listed in his January 28, 1992 Memorandum on Reducing the burden of Government Regulation, which are also discussed in the January 30, 1992 White House Fact Sheet, to all the Department of Labor and other federal agencies the time to get in the process of weeding out unnecessary and burdensome government regulations—those that impose needless costs on consumer and substantially impede economic growth and the competitiveness of American industry. Moreover, new technologies and markets can quickly make existing regulations obsolete and burdensome, even those that were fully justified when they were adopted. At the same time, existing regulations can impose unnecessary constraints on emerging technologies and markets that could not have been foreseen at the time the regulations were promulgated.
With this in mind, the President has directed that the Department
(i) identify each of your agency's regulations and programs that impose a substantial cost on the economy, and
(ii) determine whether each such regulation or program adheres to the following standards:
(a) The expected benefits to society of any regulation should clearly outweigh the expected costs it imposes on society.
(b) Regulations should be fashioned to maximize net benefits to society.
(c) To the maximum extent possible, regulatory agencies should set performance standards instead of prescriptive command-and-control requirements, thereby allowing the regulated community to achieve regulatory goals at the lowest possible cost.
(d) Regulations should incorporate market mechanisms to the maximum extent possible.
(e) Regulations should provide clarity and certainty to the regulated community and should be designed to avoid needless litigation.
The Department's review of its regulations and programs will proceed in accordance with all applicable legal requirements and established regulatory review procedures, including all applicable requirements of the Administrative Procedure Act. Our review will also be guided by the purposes of objectives of the enabling statutes for the regulations and programs being reviewed.
Public comments concerning specific Department of Labor regulations are encouraged. Public comments may also be made on regulations of the Pension Benefit Guaranty Corporation.
Commenters should address those regulations that appear to impose substantial costs on the economy, impose unnecessary constraints on emerging technologies and markets, substantially impede economic growth, or fail to achieve the benefits intended. Comments should include supporting examples or data on how economic growth was impeded, and should detail any evidence of excessive costs borne or new technologies that are being impeded in their adoption. Comments should also address ways that the Department's regulations and programs can be modified to better adhere to the standards set by the President above.
Most of the possible significant regulatory actions currently being considered by the Department of Labor are described in some detail in the document entitled the "Regulatory Program of the United States Government—April 1, 1991—March 31, 1992." This is available from the Superintendent of Documents (Stock Number 041-001-00362-2). Most of the Department's other regulations are listed in the semi-annual regulatory agenda (56 FR 53558).
Signed at Washington, DC, this 19th day of February, 1992.
Lynn Martin,
Secretary of Labor.
[FR Doc. 92–4252 Filed 2–21–92; 8:45 am]
BILLING CODE 4510–23–M
ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 281
[FRL–4107–4]
Maine, Approval of State Underground Storage Tank Program
AGENCY: Environmental Protection Agency.
ACTION: Notice of Tentative Determination on Application of Maine for Final Approval, Public Hearing and Public Comment Period.
SUMMARY: The purpose of this notice is to announce that: The Environmental Protection Agency (EPA) has received a complete application from the State of Maine requesting final approval of its Underground Storage Tank (UST) program under subtitle I of the Resource Conservation and Recovery Act (RCRA); EPA has reviewed Maine's application and has made the tentative decision that Maine's UST program satisfies all of the requirements necessary to qualify for final approval; Maine's application for final approval is now available for public review and copying; public comments are requested; and a public hearing will be held to solicit comments on the application, if there is significant interest.
DATES: A public hearing is scheduled for March 25, 1992. The State of Maine will participate in the public hearing held by EPA. The hearing will begin at 9 a.m. and will continue until the end of the testimony or 12 p.m., whichever comes first. Requests to present oral testimony must be filed by March 18, 1992. Written comments must be received by March 25, 1992. EPA reserves the right to cancel the hearing should there be no significant public interest. Those informing EPA of their intention to testify will be notified of the cancellation.
ADDRESSES: Comments and requests to testify should be mailed to: Rhona Julien, Underground Storage Tank Program, HPU CAN–7, U.S. EPA, Region I, JFK Federal Building, Boston, MA 02203.
Copies of Maine's final application for program approval are available 8 a.m.–4 p.m., Monday through Friday, at the following locations for review: Maine, Department of Environmental Protection, Bureau of Oil and Hazardous Materials Control, State House Station #17, Augusta, Maine 04333, Phone: (207) 289–6951; U.S. EPA Headquarters, Library, room 211A, 401 M Street, Washington, DC 20460, Phone: (202) 382–5928; U.S. EPA, Region I Library, 1 Congress Street, 11th Floor, Boston, MA 02203, Phone: (617) 565–3300.
EPA and Maine will hold the public hearing on March 25, 1992, in the Meeting Room of the Comfort Inn, 281 Civic Center Drive, Augusta, Maine. The hearing will begin at 9 a.m. and will continue until the end of testimony or 12 p.m., whichever comes first.
FOR FURTHER INFORMATION CONTACT: Rhona Julien, HPU CAN–7, Underground Storage Tank Program, U.S. EPA, Region I, JFK Federal Building, Boston, MA 02203, Phone: (617) 573–9655. Comments should also be sent to this address.
SUPPLEMENTARY INFORMATION:
A. Background
Section 9004 of the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. 6991c, enables EPA to authorize states to implement their own UST programs in lieu of the Federal UST program. Two types of approval may be granted. The first type, known as "interim approval" is a temporary approval which is granted if EPA determines that the state UST program is "no less stringent" than the Federal
program (Section 9004(b) of RCRA, 42 U.S.C. 6991c(b)) in the following elements: corrective action, financial responsibility, notification requirements, and new tank standards. While operating under interim approval, the State may complete the development of "no less stringent" standards for the following elements: release detection, release detection record keeping, reporting of releases and corrective actions taken, and tank closure.
The second type is a "final approval" that is granted if EPA determines that the State program: (1) Is "no less stringent" than the Federal UST program in all of the following elements: corrective action, financial responsibility, new tank standards, release detection, release detection record keeping, release reporting, tank closure, and notification requirements of section 9004(a)(8) of RCRA, 42 U.S.C. 6991c(a)(8); and (2) provides for adequate enforcement of compliance with UST standards (Section 9004(a), 42 U.S.C. 6991c(a)).
B. Maine
On August 1, 1991, the State of Maine submitted a Draft application to EPA for program approval. Prior to this, the State, working with EPA, amended their UST rules, in order to meet the "no less stringent" federal requirements. Maine provided an opportunity for public comment on January 23, 1991, requesting comments on the amended regulations. A public hearing was held on April 25, 1991, and the regulations became effective on September 16, 1991.
In accordance with the requirements of 40 CFR 281.50(b), Maine provided an opportunity for public comment on June 20 and 21, 1991, requesting comments on Maine's intention to seek state UST program authorization. On December 20, 1991, EPA received a Final Application for program approval. Based on the review of the Maine state program, EPA has made a tentative determination that it meets all the requirements necessary to qualify for final approval. Consequently, EPA intends to grant final approval to the State of Maine to implement its UST program.
In accordance with section 9004(d) of RCRA, 42 U.S.C. 6991c(d) and 40 CFR 281.50(e), the Agency will hold a public hearing on its tentative determination on March 25, 1992, in Augusta, Maine from 9 a.m.-12 p.m. All written comments on EPA's tentative determination must be submitted by March 25, 1992. Copies of Maine's application are available for inspection and copying at the locations indicated in the "ADDRESSES" section of this notice.
The Maine Department of Environmental Protection, through the Bureau of Hazardous Materials Control is charged with the responsibility to develop standards and criteria for the design, installation, operation, maintenance, and monitoring of underground storage tanks to prevent UST related ground and surface water contamination, under the authority of 38 M.R.S.A. 581, et seq., Maine's Underground Storage Tank Law, as amended. The statute includes provisions for the following:
(1) Authority to promulgate UST regulations for controlling underground storage facilities containing petroleum and related sludge, and chemical substances.
(2) Authority to impose administrative fines for violations of any provision of the statute.
(3) Authority to conduct compliance monitoring inspections and other enforcement activities.
(4) Notification requirements for owners of underground storage tanks including heating oil tanks.
(5) Establishment of petroleum cleanup fund. This is financed through licensing fees and tank assessment fees, and helps pay for cleanup and restoration of contaminated soil and groundwater caused by petroleum releases from USTs, and for third party damages.
EPA will consider all public comments on its tentative determination received during the public comment period or at the hearing. Issues raised by those comments may be the basis for a decision to deny final approval to Maine. EPA expects to make a final decision on whether or not to approve Maine's program within sixty (60) days after the date of the public hearing and will give notice of it in the Federal Register. The notice will include a summary of the reasons for the final determination and a response to all major comments.
Compliance With Executive Order 12291
The Office of Management and Budget has exempted this rule from the requirement of Section 3 of the Executive Order 12291.
Certification Under the Regulatory Flexibility Act
Pursuant to 5 U.S.C. 605(b), I hereby certify that this approval will not have a significant economic impact on a substantial number of small entities. This is due to the fact that approval of Maine's UST program effectively suspends the applicability of the Federal UST regulations, thereby eliminating duplicative requirements for owners and operators of underground storage tanks in Maine. This rule, therefore, does not require a regulatory flexibility analysis.
List of Subjects in 40 CFR Part 281
Administrative practice and procedure, Hazardous substances, Insurance, Intergovernmental relations, Oil pollution, Reporting and recordkeeping requirements, Surety bonds, Water pollution control, Water supply.
Authority: This notice is issued under the authority of section 9004 of RCRA as amended, 42 U.S.C. 6991c.
Dated: February 18, 1992.
Julie Bulaga,
Regional Administrator.
[FR Doc. 92–4257 Filed 2–21–92; 8:45 am]
BILLING CODE 6580–50–M
NATIONAL FOUNDATION ON THE ARTS AND THE HUMANITIES
45 CFR Part 1150.
Claims Collection
AGENCY: National Endowment for the Arts.
ACTION: Notice of proposed rulemaking.
SUMMARY: This proposed rule will implement the Debt Collection Act of 1982 (the Act) and it will replace the existing National Endowment for the Arts, “Collection of Claims Under the Federal Claims Collection Act of 1966,” published at title 45 of Code of Federal Regulations part 1150. The Act requires changes in the way the National Endowment for the Arts (Endowment) collects money owed it. This proposed rule will implement the provisions of the Act for reporting a debtor to a consumer reporting agency, provides authority to contract for private collection services, as well as identify procedures for administrative offset and salary offset. Each of these procedures contains safeguards for the debtor, while enhancing the Endowment’s ability to collect money owed it.
DATES: Comments must be received on or before April 24, 1992.
ADDRESSES: Interested persons should submit comments to Amy R. Sabrin General Counsel, National Endowment for the Arts, 1100 Pennsylvania Avenue, NW., Washington, DC 20506. Comments will be available for inspection at the above address from 9 a.m. to 5:30 p.m. Monday through Friday.
FOR FURTHER INFORMATION CONTACT: Karen L. Elias, 202–682–5418.
SUPPLEMENTARY INFORMATION: The Debt Collection Act of 1982 (Pub. L. 97–365, 96 Stat. 1749, applicable sections codified at 31 U.S.C. 3701, 3711, 3716, 3717, 3718, and 5 U.S.C. 5514) (the Act) makes several changes in the way Executive and legislative agencies collect debts owed the Government. The purpose of the Act is to improve the ability of the Government to collect money owed it, while adding certain notice requirements and other protections applicable to the Government’s relationship to the debtor. This proposed rule would implement the provisions of the Act.
Generally, the Act enhances the Government’s ability to collect money owed it. First, by allowing the Government to disclose to a consumer reporting agency information from a system of records to the effect that an individual or organization is responsible for a claim under the Act. The Act also allows the head of an agency to make contracts for private collection services to recover indebtedness owed the United States. And, the Act establishes new provisions relating to the use of administrative and salary offset as a means of collecting money owed the Government.
The Act provides additional protection to the consumer by requiring that a debtor be provided notice of a debt and the opportunity to review the record and enter into a written repayment agreement before the Government releases the name of the debtor to a consumer reporting agency, or before the money is collected by administrative offset.
The Act requires agencies to issue regulations implementing various provisions of the new law which are consistent with uniform standards issued jointly by the Department of Justice and the General Accounting Office (DOJ/GAO). DOJ/GAO issued final standards on March 9, 1984 (see 49 FR 8889). In addition, the Endowment’s regulations on salary offset must be consistent with offset regulations issued by the Office of Personnel Management (OPM). OPM issued final rules on July 3, 1984 (see 49 FR 27470). The provisions of the Act which are being implemented in this rulemaking are summarized below:
Disclosure to Consumer Reporting Agency
Section 3 of the Debt Collection Act (codified at 31 U.S.C. 3711(f)) authorizes agencies to report delinquent debtors to a consumer reporting agency. The Act requires that several procedural protections be provided to debtors before the release of any information concerning the overdue payment. In addition, the Act requires that the agency report any significant change in circumstances (for example, payment of the debt) to the consumer reporting agency.
Section 1150.12 of this proposed rule provides for disclosure to a consumer reporting agency. Under this section, the Endowment will release information only after there has been a determination that the debt is valid and overdue and that a written notice has been sent to the debtor. This written notice will state that the debtor’s payment of a debt is overdue, and that the Endowment will disclose this information to a consumer reporting agency is not less than 60 days from the date of the notice.
The debtor has a right to a full explanation of the debt, which includes a review of applicable Endowment records on the debt. In addition, the debtor may avoid the reporting of the claim to a consumer reporting agency by entering into an agreement to repay the debt under terms agreed to by the Endowment.
Contracts for Collection Services
Section 13 of the Debt Collection Act (codified at 31 U.S.C. 3718) authorizes the head of an agency to enter into a contract with a person for collection services to recover debts owed the United States. The Act requires that certain provisions be contained in any contract that the agency enters into for collection services. Section 1150.13 codifies the minimum provisions of the contract required by the Act, which include:
(1) The Endowment retains the authority to resolve a dispute, which includes terminating a collection action or referring the matter to the Attorney General for civil remedies; and
(2) The person contracted with is subject to the Privacy Act of 1974, as it applies to private contractor, as well as subject to State and Federal laws governing debt collection practices, such as the Debt Collection Practices Act.
Administrative Offset
The procedures authorized for administrative offset are contained in Section 10 of the Debt Collection Act (codified at 31 U.S.C. 3716) and will be implemented in conjunction with other authority of the Endowment to offset. As with the provision for reporting to a consumer reporting agency, the Act requires that notice procedures be observed by the agency before any offset takes place. In addition, administrative offset authorized by the Act is limited, because the Act states that these offset provisions do not apply to an agency of the United States government, of a State government or of a unit of general local government.
Section 1150.20 through 1150.37 contain the administrative offset provisions adopted by the Endowment. These regulations cover such aspects of offset as coordinating collection with another Federal agency, notice that will be provided to a debtor before the offset begins the opportunity to inspect the Endowment’s records related to the particular debt, the opportunity to enter into a repayment agreement with the Chairman, and time periods in which the debtor must notify the Endowment of his or her election of any of these procedures.
Review of the record includes a review by the Endowment of the written record pertaining to the debt, and, in some situations, a hearing. The conditions for these two procedures are outlined in the proposed rule.
Section 1150.35 sets out specific procedures for offset against amounts payable from the Civil Service Retirement and Disability Fund.
Salary Offset
Section 5 of the Debt Collection Act (codified at 5 U.S.C. 5514) establishes new procedures to be used when an agency wishes to collect money owed it by offsetting the current salary of a Federal employee. Like administrative offset, agencies must cooperate with one another when one agency is owed the debt, but the debtor is the employee of another agency. The salary offset provisions contained in the Debt Collection Act contain similar, although somewhat greater, opportunities for an employee to review the determination of indebtedness before an offset is implemented by an agency. In addition, each agency’s regulations must be consistent with the Office of Personnel Management’s regulations.
The Endowment’s regulations on salary offset are contained in §§ 1150.40 through 1150.57 of this proposed rule. The procedures for salary offset are similar to those for administrative offset. In the salary offset procedure, however, an employee against whom an offset is sought is entitled to a hearing to review the Chairman’s determination of the debt, the amount of the debt, or percentage of disposable pay to be deducted each pay period. Similar to the administrative offset procedures, the employee must give notice of intent to take advantage of any of these procedures in the time period prescribed in the regulations.
Other Matters
This proposed rule was listed as item numbers 3689 and 3694 in the Endowment's Semiannual Agenda of Regulations published on April 22, 1991, FR Vol. 56, No. 77, page 18120-18121 under Executive Order 12291 and the Regulatory Flexibility Act.
List of Subjects in 45 CFR Part 1150:
Administrative claims.
Amy R. Sabrin,
General Counsel, National Endowment for the Arts.
For the reasons set out in this preamble, the National Endowment for the Arts proposes to revise title 45, Code of Federal Regulations, part 1150 to read as follows:
PART 1150—CLAIMS COLLECTION
Subpart A—General Provisions
Sec.
1150.1 Scope and definitions.
1150.2 Incorporation of joint standards by reference.
1150.3 Subdivision and joining of claims.
1150.4 Referral of claims to the General Counsel.
1150.5 Accounting control.
1150.6 Record retention.
1150.7 Suspension or revocation of eligibility.
1150.8 Standards for collection of claims.
1150.9 Standards for compromise of claims.
1150.10 Standards for suspension or termination of collection action.
1150.11 Referral to GAO or Justice Department.
1150.12 Disclosure to a Consumer Reporting Agency.
1150.13 Contracts for collection services.
1150.14 Miscellaneous provisions: Correspondence with the Endowment.
1150.15–1150.19 [Reserved].
Subpart B—Administrative Offset Provisions
1150.20 Scope.
1150.21 Coordinating administrative offset with another Federal agency.
1150.22 Notice requirements before offset.
1150.23 Exceptions to notice requirements.
1150.24 Review within the Endowment of a determination of indebtedness.
1150.25 Review of Endowment records related to the debt.
1150.26 Written agreement to repay debt as alternative to administrative offset.
1150.27 Stay of offset.
1150.28 Type of review.
1150.29 Review procedures.
1150.30 Determination of indebtedness and appeal from determination.
1150.31 Procedures for administrative offset: Single debt.
1150.32 Procedures for administrative offset: Multiple debts.
1150.33 Procedures for administrative offset: Interagency cooperation.
1150.34 Procedures for administrative offset: Statute of limitations.
1150.35 Procedures for administrative offset: Offset against amounts payable from Civil Service Retirement and Disability Fund.
1150.36 Procedures for administrative offset: Offset of debtor’s judgment against the United States.
1150.37 Procedures for administrative offset: Imposition of interest.
Subpart C—Salary Offset Provisions
1150.40 Scope.
1150.41 Definitions.
1150.42 Coordinating salary offset with another Federal agency.
1150.43 Determination of indebtedness.
1150.44 Notice requirements before offset.
1150.45 Request for a hearing.
1150.46 Result if employee fails to meet deadlines.
1150.47 Conduct of hearing.
1150.48 Written decision following a hearing.
1150.49 Review of Endowment records related to the debt.
1150.50 Written agreement to repay debt as alternative to salary offset.
1150.51 Procedures for salary offset: When deductions may begin.
1150.52 Procedures for salary offset: Types of collection.
1150.53 Procedures for salary offset: Methods of collection.
1150.54 Procedures for salary offset: Imposition of interest.
1150.55 Non-waiver of rights.
1150.56 Refunds.
1150.57 Statute of limitations.
Authority: 31 U.S.C. 3711, 31 U.S.C. 3716 to 3718, 5 U.S.C. 5514, 5 U.S.C. 552a.
Subpart A—General Provisions
§ 1150.1 Scope and definitions.
(a) Scope. This subpart sets forth the regulations of the National Endowment for the Arts, implementing the Federal Claims Collection Act of 1966 as amended by the Debt Collection Act of 1982. This subpart conforms with the standards jointly promulgated by the Attorney General and the Comptroller General in 4 CFR parts 101 through 105 and the Salary Offset Regulations published by Office of Personal Management in 5 CFR part 550 subpart K. The Act as amended:
(1) requires the head of an agency or designee to attempt collection of all claims of the United States for money or property arising out of the activities of the agency; and
(2) authorizes the head of an agency or designee to compromise such claims that do not exceed $20,000 exclusive of interest, or to suspend or terminate collection action where it appears that no person liable on such claims has the present or prospective financial ability to pay any significant sum thereon or that the cost of collecting such claim is likely to exceed the amount of recovery.
(b) Definitions. The following definitions apply to these regulations:
(1) Administrative costs means costs that result from the additional actions required because a debt has become delinquent.
(2) Agency means an Executive department as defined at 5 U.S.C. 105 including the U.S. Postal Service, the U.S. Postal Commission, a military department as defined at 5 U.S.C. 102; an agency or court in the judicial branch, an agency of the legislative branch including the U.S. Senate and House of Representatives and other independent establishments that are entities of the Federal government.
(3) Debt means an amount owed to the United States from sources which include loans insured or guaranteed by the United States and all other amounts due the United States from fees, leases, rents, royalties, services, sales of real or personal property, overpayments, penalties, damages, interests, fines, forfeitures, (except those arising under the Uniform Code of Military Justice) and all other similar sources.
(4) Delinquent means that the debt has not been paid by the date specified by the Endowment in its initial written notification or contractual agreement, unless other satisfactory payment arrangements have been made by that date, or if, at any time thereafter, the debtor fails to satisfy obligations under a payment agreement with the Endowment.
(5) Disposable pay means the amount that remains from an employee’s federal pay after required deductions for social security, federal, state or local income tax, health insurance premiums, retirement contributions, life insurance premiums, federal employment taxes, and any other deductions that are required to be withheld by law.
(6) Endowment means the National Endowment for the Arts.
(7) Endowment official means an official of the National Endowment for the Arts, designated by the Chairperson, and having authority to decide administrative offset and salary offset matters and to issue the agency’s reply to an employee’s request for a hearing as described in these regulations.
(8) General Counsel means the General Counsel of the National Endowment for the Arts.
(9) Hearing official means an individual responsible for conducting any hearing with respect to the existence or amount of a debt claimed, and who renders a decision on the basis of such hearing. A hearing official may not be under the supervision or control
of the Chairperson of the National Endowment for the Arts.
§ 1150.2 Incorporation of joint standards by reference.
All administrative actions to collect claims arising out of the activities of the Endowment shall be performed in accordance with the applicable standards prescribed in 4 CFR parts 101 through 105, and 5 CFR part 550 subpart K which are incorporated by reference and supplemented in this subpart.
§ 1150.3 Subdivision and joining of claims.
(a) A debtor’s liability arising from a particular transaction or contract shall be considered as a single claim in determining whether the claim is one not exceeding $20,000 exclusive of interest for the purpose of compromise or termination of collection action. Such a claim may not be subdivided to avoid the monetary ceiling established by the Act.
(b) Joining of two or more single claims in a demand upon a particular debtor for payment totaling more than $20,000 does not preclude compromise or termination of collection action with respect to any one of such claims that does not exceed $20,000 exclusive of interest.
§ 1150.4 Referral of claims to the General Counsel.
(a) Authority of the General Counsel. The General Counsel shall exercise the powers and perform the duties of the Chairman to compromise or to suspend or terminate collection action on all claims not exceeding $20,000 exclusive of interest. Claims shall be referred to the General Counsel well within the applicable statute of limitations (28 U.S.C. 2415 and 2416), but in no event more than 2 years after the claims accrued.
(b) Exclusions. There shall be no compromise or terminated collection action with respect to any claim:
(1) As to which there is an indication of fraud, the presentation of a false claim, or misrepresentation on the part of the debtor or any other party having an interest in the claim;
(2) based in whole or in part on conduct in violation of the antitrust laws;
(3) based on tax statutes; or
(4) arising from an exception made by the General Accounting Office (GAO) in the account of an accountable officer. Such claims shall be promptly referred to the Justice Department or GAO, as appropriate.
§ 1150.5 Accounting control.
The General Counsel shall process all claims collections through the National Endowment for the Arts accounting office and report the collection, compromise, suspension and termination of all claims to the appropriate accounting office for recording.
§ 1150.6 Record retention.
The file of each claim on which administrative collection action has been completed shall be retained by the appropriate Endowment office or the General Counsel for not less than 1 year after the applicable statute of limitations has run.
§ 1150.7 Suspension or revocation of eligibility.
(a) In the event a contractor, grantee, or other participant in programs sponsored by the Endowment fails to pay his debts to the Endowment within a reasonable time after demand the fact shall be reported by the Grants, Audit, or other appropriate office to the General Counsel, who shall place such defaulting participants name on the Endowment’s list of debarred, suspended and ineligible contractors and grantees and the participant will be advised.
(b) The failure of any surety to honor its obligations in accordance with 31 U.S.C. 3905 is to be reported at once to the General Counsel who shall so advise the Treasury Department. The Treasury Department will notify the Endowment when a surety’s certificate of authority to do business with the Government has been revoked or forfeited.
§ 1150.8 Standards for collection of claims.
(a) Demand for payment. Appropriate written demands shall be upon the debtor which shall include information relating to the consequences of his failure to cooperate.
(b) Collection by offset. Collection by offset will be administratively undertaken on claims which are liquidated or certain in amount in every instance where this is feasible. For specific procedures on administrative offset see §§ 1150.20–1150.37. For specific procedures on salary offset see §§ 1150.40–1150.57.
(c) Liquidation of collateral. When the Endowment holds security or collateral that may be liquidated and the proceeds applied to debts due it through the exercise of a power of sale in the security instrument or a nonjudicial foreclosure, such procedures should be followed if the debtor fails to pay his debt within a reasonable time after demand, unless the cost of disposing of the collateral will be disproportionate to its value or special circumstances require judicial foreclosure.
(d) Collection in installments. Claims with accrued interest should be collected in full or one lump sum whenever this is possible. However, if the debtor is financially unable to pay the indebtedness in one lump sum, payment may be accepted in regular installments.
(e) Interest, penalties and administrative costs. The Endowment shall assess interest, penalties, and administrative costs on debts owed to the Endowment pursuant to 31 U.S.C. 3717 as outlined below.
(1) Interest shall accrue from the date on which the notice of debt and the Endowment’s interest requirements is first mailed or hand-delivered to the debtor using the most current address available to the Endowment.
(2) Interest shall be assessed at the rate of the current value of funds to the United States Treasury (i.e., the Treasury tax and loan account rate), as prescribed and published by the Secretary of the Treasury in the Federal Register and the Treasury Fiscal Requirements Manual Bulletins annually or quarterly, in accordance with 31 U.S.C. 3717.
(3) Interest may be charged at a higher rate if the Endowment reasonably determines that it is necessary to protect the interests of the United States.
(4) The rate of interest, as initially assessed, shall remain fixed for the duration of the indebtedness, except that where a debtor has defaulted on repayment agreement and seeks to enter into a new agreement, the Endowment may set a new interest rate which reflects the current value of funds to the Treasury at the time the new agreement is executed.
(5) Interest shall not be assessed on interest, penalties, or administrative costs required by this section. However, if the debtor defaults on a previous repayment agreement, charges which accrued but were not collected under the defaulted agreement shall be added to the principal to be paid under a new repayment agreement.
(6) Administrative costs incurred as a result of a delinquent debt shall be assessed against a debtor to cover the additional costs incurred in processing and handling the debt because it became delinquent.
(7) Penalty charges shall be assessed, not to exceed 6 percent a year, on any portion of a debt that is delinquent for more than 90 days. This charge need not be calculated until the 91st day of delinquency, but shall accrue from the date that the debt became delinquent.
(8) Partial or installment payments received by the Endowment shall be applied first to outstanding penalty and administrative cost charges, second to accrued interest, and third to outstanding principal.
(9) Waiver of interest requirements on the debt or any portion of the debt shall occur
when the debt or portion thereof is paid within 30 days after the date on which interest began to accrue. The Endowment may extend this 30-day period, on a case-by-case basis, if it reasonably determines that such action is appropriate. Also, the Endowment may waive, in whole or in part, the collection of interest, penalties, and/or administrative costs assessed under this section under the criteria specified in § 1150.9 relating to the compromise of claims (without regard to the amount of the debt), if the Endowment determines that the collection of these charges would be against equity and good conscience or not in the best interests of the United States Government.
(10) Interest and related charges may not be assessed for those periods during which collection action must be suspended pursuant to a mandatory waiver or review statute until either:
(i) The Endowment has considered the request for waiver/review or
(ii) The applicable time limit for making the waiver/review request, as prescribed in these regulations, has expired and the debtor, upon proper notice, has not made such a request.
(11) Exemption: The provisions of 31 U.S.C. 3717 do not apply:
(i) To debts owed by any State or local government;
(ii) To debts arising under contracts which were executed prior to, and were in effect on (i.e., were not completed as of), October 25, 1982;
(iii) To debts where an applicable statute, regulation required by statute, loan agreement, or contract either prohibits such charges or explicitly fixes the charges that apply to the debt involved; or
(iv) To debts arising under the Social Security Act, the Internal Revenue Code of 1954 or the tariff laws of the United States.
(12) The Endowment may assess interest and related charges on debts which are not subject to 31 U.S.C. 3717 to the extent authorized under the common law or other applicable statutory authority.
(f) Omission not a defense. Failure to comply with any standard prescribed in 4 CFR chapter II or in this subpart shall not be available as a defense to any debtor.
§ 1150.9 Standards for compromise of claims.
(a) Compromise offer. An offer to compromise may be accepted:
(1) If there is real doubt concerning the National Endowment for the Arts' ability to prove its case in court for the full amount claimed;
(2) If the cost of collecting the claim does not justify the enforced collection of the full amount;
(3) If in connection with statutory penalties or forfeitures established as an aid to enforcement and to compel compliance, the Endowment's enforcement policy will be adequately served by acceptance of the sum to be agreed upon; or
(4) For other reasons deemed valid by the General Counsel and made a part of the claim record.
(b) Documentary evidence of compromise. No compromise of a claim shall be final or binding on the Endowment unless it is in writing and signed by the General Counsel who has authority to compromise the claim pursuant to this subpart.
§ 1150.10 Standards for suspension or termination of collection action.
(a) Suspension of collection action. Collection action shall be suspended temporarily on a claim when the debtor cannot be located after diligent effort, but there is reason to believe that future collection action may be sufficiently promising to justify periodic review and action on the claim, given consideration to its size and the amount which may be realized. Collection action may be suspended temporarily on a claim when the debtor owns no substantial equity in realty and is presently unable to make payment on the Endowment's claim or effect a compromise, but his future prospects justify retention of the claim for periodic review and action and
(I) The applicable statute of limitations has been tolled or started a new or
(2) Future collection can be effected by offset notwithstanding the statute of limitations. Suspension as to a particular debtor should not defer the early liquidation of security for the debt.
(b) Termination of collection action. Collection action may be terminated and the Endowment file closed for the following reasons:
(1) No substantial amount can be collected;
(2) The debtor cannot be located;
(3) The cost will exceed recovery;
(4) The claim is legally without merit; or
(5) The claim cannot be substantiated by evidence.
§ 1150.11 Referral to GAO or Justice Department.
(a) Claims referred. Claims which cannot be collected, compromised, or terminated in accordance with 4 CFR parts 101 to 105 shall be referred to the GAO in accordance with 31 U.S.C. 3711 or to the Department of Justice if the Endowment has been granted an exception from referrals to the GAO. If there is doubt as to whether collection action should be suspended or terminated on a claim, the claim may be referred to the GAO for advice. When recovery of a judgment is prerequisite to imposition of administrative sanctions, the claim may be referred to the Justice Department for litigation even though termination of collection activity might otherwise be considered.
(b) Prompt referral. Such referrals shall be made as early as possible to be consistent with aggressive collection action and in any event, well within the statute of limitations for bringing suit against the debtor.
§ 1150.12 Disclosure to a Consumer Reporting Agency.
(a) Conditions for disclosure. The Endowment may disclose to a Consumer Reporting Agency information from a system of records to the effect that an individual is responsible for a debt. Before doing so, the Endowment Official shall ensure that:
(1) The notice for the system of records required by the Privacy Act of 1974 (5 U.S.C. 552(e)(4)) indicates that the information in the system may be disclosed to a Consumer Reporting Agency;
(2) There has been Endowment review of the debt and a determination that the debt is valid and overdue;
(3) There has been written notice sent to the individual informing the individual:
(i) That payment of the debt is overdue;
(ii) That the Endowment intends to disclose to Consumer Reporting Agency, within not less than 60 days after sending the notice, that the individual is responsible for the debt;
(iii) Of the specific information intended to be disclosed to the Consumer Reporting Agency; and
(iv) Of the rights of the individual to a full explanation of the debt, to dispute any information in the records of the Endowment concerning debt, as determined by the Endowment Official, and to administrative appeal or review with respect to the debt; and
(4) The individual has neither repaid or agreed to repay the debt under a written repayment plan signed by the individual and agreed to by the Endowment official nor has filed for review of the claim under appropriate sections of this regulation.
(b) Limitations on disclosure. The Endowment Official shall not disclose information to a Consumer Reporting Agency unless the Endowment has: (1) Obtained satisfactory assurances from each Consumer Reporting Agency that it complies with the Fair Credit Reporting Act (15 U.S.C. 1681 et seq.) and any other Federal laws governing the provision of consumer credit information;
(2) Provided, upon request by the individual alleged to be responsible for the claim, the opportunity to review the claim, including an opportunity for reconsideration of the initial decision on the claim; and
(3) Taken reasonable action to locate an individual for whom the Endowment Official does not have a current address to send a notice under paragraph (a)(3) of this section.
(c) Additional responsibilities of the Endowment. In providing information to a Consumer Reporting Agency, the Endowment shall only disclose:
(1) Information necessary to establish the identity of the individual, including name, address and taxpayer identification number;
(2) The amount, status, and history of the claim; and
(3) The program under which the claim arose.
(d) In all cases, the Endowment shall notify each Consumer Reporting Agency to which the original disclosure was made of any substantial change in the condition or amount of the claim. This includes promptly correcting or verifying information about the claim requested by the Consumer Reporting Agency.
§ 1150.13 Contracts for collection services.
(a) The Chairperson may enter into a contract or contracts for collection services to recover indebtedness owed the Endowment. Any such contract will include the following provisions:
(1) The Endowment retains the authority to resolve a dispute, compromise a claim, end collection action or refer a matter to the Department of Justice or the General Accounting Office;
(2) The person contracted with by the Chairperson is subject to the Privacy Act of 1974, as amended, to the extent provided for in 5 U.S.C. 522a(m), the section on government contractors;
(3) The person contracted with by the Chairperson is subject to State and Federal laws governing debt collection practices, such as the Debt Collection Practices Act, 15 U.S.C. 1692; and
(b) The person contracted with agrees to provide to the Endowment, if asked to return the file to the Agency so that the Endowment may refer the account to the Department of Justice for litigation, any data contained in the files relating to actions previously taken to collect the debt, the current address of the debtor, as well as the current credit data of the debtor or any current other information requested and available.
§ 1150.14 Miscellaneous provisions: Correspondence with the Endowment.
All correspondence from the debtor to the Endowment shall be addressed to the Assistant Director of Administration, National Endowment for the Arts, Washington, DC. 20506.
§§ 1150.15–1150.19 [Reserved]
Subpart B—Administrative Offset Provisions
§ 1150.20 Scope.
(a) The standards set forth in §§ 1150.20 through 1150.37 are the Endowment's procedures for the collection of money owed to the government, by means of administrative offset. These procedures apply to the collection of debts as authorized by common law, by 31 U.S.C. 3716, or under other statutory authority. These procedures shall not be used when a statute, provides its own collection procedure, when explicitly prohibited by statute, or when the United States has a judgment against the debtor. Unless otherwise provided for by statute, these procedures do not apply to a debt owed by an agency of the United States, a State government, or unit of general local government. In addition, these procedures do not apply to debts arising under the Internal Revenue Code of 1986 (26 U.S.C. 1–9602), the Social Security Act (42 U.S.C. 301–1397f), or the tariff laws of the United States.
(b) The Endowment shall use administrative offset to collect claims which are certain in amount in every instance in which collection is determined to be feasible and not prohibited by laws. The Endowment shall determine feasibility on a case-by-case basis, exercising sound discretion. In determining feasibility, the Endowment shall consider:
(1) The debtor's financial condition;
(2) Whether offset would substantially interfere with or defeat the purposes of the program authorizing the payments against which offset is contemplated; and
(3) Whether offset best serves to further and protect all of the interests of the United States.
§ 1150.21 Coordinating administrative offset with another Federal Agency.
(a) When the Endowment is owed the debt, but another Federal agency is responsible for making payment to the debtor against which administrative offset is sought, the other Federal agency shall not initiate the requested administrative offset until the Endowment provides the other Federal agency with a written certification that the debtor owes the Endowment the debt (including the amount and basis of the debt and the due date of the payment) and that the Endowment has complied with all requirements of 45 CFR part 1150.
(b) When another Federal agency is owed the debt, the Endowment may administratively offset money it owes to a debtor who is indebted to another Federal agency if requested to do so by that Federal agency. Such a request must be accompanied by a certification by the requesting Federal agency that the debtor owes the debt (including the amount) and that the debtor has been given the procedural rights required by 31 U.S.C. 3716 and 4 CFR part 102.
§ 1150.22 Notice requirements before offset.
Except as provided in § 1150.23, deductions shall be made only after the Endowment makes a determination that an amount is owed and past due and provides the debtor with a minimum of 30 calendar days written notice. This Notice of Intent of Collect by Administrative Offset (Notice of Intent) shall state:
(a) The nature and amount of the debt;
(b) That the Endowment intends to collect the debt by administrative offset until the debt and all accumulated interest and other charges are paid in full;
(c) That the debtor has a right to obtain review within the Endowment of the Endowment's initial determination of indebtedness;
(d) That the debtor has a right to inspect and copy Endowment records related to the debt, as determined by the Endowment Official, and shall be informed as to where and when the inspection and copying can be done after the Endowment receives notice from the debtor that inspection and copying are requested; and
(e) That the debtor may enter into a written agreement with the Endowment to repay the debt, so long as the terms of the repayment agreement proposed by the debtor are agreeable to the Endowment.
§ 1150.23 Exceptions to notice requirements.
(a) In cases where the notice requirements specified in § 1150.22 already have been provided to the debtor in connection with the same debt under some other proceeding, the Endowment is not required to duplicate those requirements before effecting administrative offset.
(b) The Endowment may effect administrative offset against a payment to be made to a debtor before completion of the procedures required by § 1150.22 if:
(1) Failure to make the offset would substantially prejudice the Government's ability to collect the debt, and
(2) The time before the payment is to be made does not reasonably permit the completion of those procedures. Such prior offset must be followed promptly by the completion of those procedures. Amounts recovered by offset but later found to be not owed to the Endowment shall be refunded promptly.
§ 1150.24 Review within the Endowment of a determination of indebtedness.
(a) Notification of debtor. A debtor who receives a Notice of Intent has the right to request Endowment review of the determination of indebtedness. To exercise this right, the debtor must send a letter requesting review to the Endowment. The letter must explain why the debtor seeks review and must be received by the Endowment within 20 calendar days of the date of the Endowment's Notice of Intent.
(b) Endowment's response. In response to a timely request for review of the initial determination of indebtedness, the Endowment Official shall notify the debtor whether review will be by review of the record or by hearing. The notice to the debtor shall include the procedures used for reviewing the record or will include information on the date, location and procedures to be used if review is by a hearing.
§ 1150.25 Review of Endowment records related to the debt.
(a) Notification by debtor. A debtor who intends to inspect or copy Endowment records related to the debt as determined by the Endowment must send a letter to the Endowment stating his or her intention. The letter must be received by the Endowment within 20 calendar days of the date of the Endowment's Notice of Intent.
(b) Endowment's response. In response to timely notification by the debtor as described in paragraph (a) of this section, the Endowment Official shall notify the debtor of the location and time when the debtor may inspect or copy Endowment records related to the debt.
§ 1150.26 Written agreement to repay debt as alternative to administrative offset.
(a) Notification by debtor. The debtor may, in response to a Notice of Intent, propose a written agreement to repay the debt as an alternative to administrative offset. Any debtor who wishes to do this must submit a proposed written agreement to repay the debt. This proposed written agreement must be received by the Endowment within 20 calendar days of the date of the Endowment's Notice of Intent.
(b) Endowment's response. In response to timely notification by the debtor as described in paragraph (a) of this section, the Endowment Official will provide for a review of the record (a review of the documentary evidence).
§ 1150.29 Review procedures.
(a) Hearings. (1) The Hearing Official for Administrative Offset (Hearing Official) conducts the hearing. The Hearing Official shall take steps necessary to ensure that the hearing is conducted in a fair and expeditious manner. If necessary, the Hearing Official may administer oaths of affirmation.
(2) The Hearing Official does not use the formal rules of evidence with regard to admissibility of evidence or the use of evidence once admitted. However, parties may object to clearly irrelevant material.
(3) The Hearing Official records all significant matters discussed at the hearing. There is no "official" record or transcript provided for these hearings.
(b) Review of the record. The Hearing Official shall review all material related to the debt which is in the possession of the Endowment. The Hearing Official makes a determination based upon a review of this written record, which may include a request for reconsideration of the determination of indebtedness, or such other relevant material submitted by the debtor.
§ 1150.30 Determination of indebtedness and appeal from determination.
(a) Following the hearing or the review of the record, the Hearing Official shall issue a written decision which includes the supporting rationale for the decision. The decision of the Hearing Official is the final Endowment action with regard to the particular administrative offset.
(b) Copies of the Hearing Official's decision shall be distributed within the Endowment to appropriate offices and divisions and to the debtor and the debtor's attorney or other representative, if applicable.
§ 1150.31 Procedures for administrative offset: Single debt.
(a) Offset will commence 31 days after the debtor receives the Notice of Intent, unless the debtor has requested a hearing (see § 1150.24) or has entered into a repayment agreement (see § 1150.26).
(b) When there is a review of the debt within the Endowment, offset will begin after the determination has been issued under § 1150.30 and a copy of the determination is received by the Endowment's Finance Division.
§ 1150.32 Procedures for administrative offset: Multiple debts.
The Endowment shall use the procedures identified in § 1150.31 for the offset of multiple debts. However, when collecting multiple debts the Endowment shall apply the recovered amounts to those debts in accordance with the best interests of the United States, as determined by the facts and circumstances of the particular case, paying special attention to applicable statutes of limitations.
§ 1150.33 Procedures for administrative offset: Interagency cooperation.
The Endowment will make use of all possible methods of cooperating with other Federal agencies in effecting collections by offset.
§ 1150.34 Procedures for administrative offset: Statute of limitations.
(a) The Endowment may not initiate administrative offset to collect a debt under 31 U.S.C. 3716 more than 10 years after the Endowment's right to collect the debt first accrued, unless facts
material to the Endowment's right to collect the debt were not known and could not reasonably have been known by the officials of the Endowment who were responsible for discovering and collecting such debts.
(b) When the debt first accrued is determined according to existing law regarding the accrual of debts. (See, for example 28 U.S.C. 2415.)
§ 1150.35 Procedures for administrative offset: Offset against amounts payable from Civil Service Retirement and Disability Fund.
(a) Unless otherwise prohibited by law, the Endowment Official may request that monies which are due and payable to a debtor from the Civil Service Retirement and Disability Fund be administratively offset in one or more payments to collect debts owed to the Endowment by the debtor. The Endowment Official submits the request to the appropriate officials of the Office of Personnel Management (OPM) in accordance with OPM regulations and procedures.
(b) To request administrative offset under paragraph (a) of this section, the Endowment Official shall provide a written certification that:
(1) The debtor owes the Endowment a debt, including the amount of the debt;
(2) The Endowment has complied with the applicable statutes, regulations, and procedures of the Office of Personnel Management; and
(3) The Endowment Official has complied with the Endowment's regulations.
(c) Once the decision is made to request administrative offset under paragraph (a) of this section, the Endowment Official will make the request as soon as practical after completion of the applicable procedures necessary for the Office of Personnel Management to identify the debtor's account and to add a notation in the debtor's file in anticipation of the time when the debtor requests or becomes eligible to receive payments from the Fund. (This notation shall satisfy any requirement that offset be initiated before the applicable statute of limitations expires.)
(d) If, at the time the debtor makes a claim for payments from the Fund, at least one year has elapsed since the offset was originally made, the debtor may offer a satisfactory repayment plan instead of offset upon establishing that changed financial circumstances would render the offset unjust.
(e) If the Endowment collects part or all of the debt by other means before deductions are made or completed under paragraph (a) of this section, the Endowment Official shall act promptly to modify or terminate the Endowment's request for offset under paragraph (a) of this section.
§ 1150.36 Procedures for administrative offset: Offset of debtor's judgment against the United States.
Collection by offset against a judgment obtained by a debtor against the United States will be accomplished in accordance with 31 U.S.C. 3728.
§ 1150.37 Procedures for administrative offset: Imposition of interest.
Interest will be charged in accordance with § 1150.8(e).
Subpart C—Salary Offset Provisions
§ 1150.40 Scope.
(a) The provisions set forth in §§ 1150.41 through 1150.57 govern the collection by salary offset of a Federal employee's pay to satisfy certain debts owed the government.
(b) These regulations apply to collections by the Endowment from:
(1) Current employees of the Endowment and other Federal agencies who owe debts to the Endowment; and
(2) Current employees of the Endowment who owe debts to other Federal agencies.
(c) These regulations do not apply to debts or claims arising under the Internal Revenue Code of 1986 as amended [26 U.S.C. 1 et seq.]; the Social Security Act [42 U.S.C. 301 et seq.]; the tariff laws of the United States; or to any case where collection of a debt by salary offset is explicitly provided for or prohibited by another statute.
(d) These regulations identify the types of salary offset available to the Endowment, as well as certain rights provided to the employee, which include a written notice before deductions begin, the opportunity to petition for a hearing and to receive a written decision if a hearing is granted. These employee rights do not apply to any adjustment to pay arising out of coverage under a Federal benefit program requiring periodic deductions from pay, if the amount to be recovered was accumulated over four pay periods or less.
(e) Nothing in these regulations precludes the compromise, suspension, waiver or termination of collection actions where appropriate under the Endowment's regulations contained elsewhere in this subpart.
(f) Matters not addressed in these regulations should be reviewed in accordance with the Federal Claims Collection Standards at 4 CFR part 101 et seq.
§ 1150.41 Definitions.
For the purposes of this part the following definitions will apply:
Agency means an executive agency as is defined at 5 U.S.C. 105 including the U.S. Postal Service, the U.S. Postal Commission, a military department as defined at 5 U.S.C. 102, an agency or court in the judicial branch, an agency of the legislative branch including the U.S. Senate and House of Representatives and other independent establishments that are entities of the Federal government.
Chairperson means the Chairperson of the National endowment for the Arts or the Chairperson's designee.
Creditor agency means the agency to which the debt is owned.
Debt means an amount owed to the United States from sources which include loans insured or guaranteed by the United States and all other amounts due the United States from fees, leases, rents, royalties, services, sales or real or personal property, overpayments, penalties, damages, interests, fines, forfeitures (except those arising under the Uniform Code of Military Justice), and all other similar sources.
Disposable pay means the amount that remains from an employee's federal pay after required deductions for social security, federal, state or local income tax, health insurance premiums, retirement contributions, life insurance premiums, federal employment taxes, and any other deductions that are required to be withheld by law.
Endowment official means an official of the National Endowment for the Arts, designated by the Chairperson, and having authority to decide salary offset matters and to issue the agency's reply to an employee's request for a hearing as described in these regulations.
Hearing official means an individual responsible for conducting any hearing with respect to the existence or amount of a debt claimed, and who renders a decision on the basis of such hearing. A hearing official may not be under the supervision or control of the Chairperson of the National Endowment for the Arts.
"Paying Agency" means the agency that employs the individual who owes the debt and authorizes the payment of his/her current pay.
Salary offset means an administrative offset to collect a debt pursuant to 5 U.S.C. 5514 by deduction(s) at one or more officially established pay intervals from the current pay account of an employee without his/her consent.
§ 1150.42 Coordinating salary offset with another Federal agency.
(a)(1) When the Endowment is owed the debt. When the Endowment is owed a debt by an employee of another Federal agency, the Endowment shall provide the other Federal agency with a written certification that the employee owes the Endowment a debt (including the amount and basis of the debt and the due date of the payment) and that the Endowment has complied with these regulations.
(2) If the employee is in the process of separating, the Endowment must submit its debt claim to the paying agency as provided in this part. The paying agency must certify any amounts already collected, notify the employee, and send a copy of the certification and notice of the employee’s separation to the Endowment. If the paying agency is aware that the employee is entitled to Civil Service Retirement and Disability Fund or similar payments, it must certify to the agency responsible for making such payments the amount of the debt and that the provisions of this part have been followed; and
(3) If the employee has already separated and all payments due from the paying agency have been paid, the Chairperson may request unless otherwise prohibited, that money payable to the employee from the Civil Service Retirement and Disability Fund or other similar funds be collected by administrative offset.
(b)(1) When another Federal agency is owed the debt. The Endowment may use salary offset against one of its employees who is indebted to another Federal agency if requested to do so by that Federal agency. Such a request must be accompanied by a certification by the requesting Federal agency that the person owes the debt (including the amount) and that the employee has been given the procedural rights required by 5 U.S.C. 5514 and 5 CFR part 550, subpart K.
(2) If the employee transfers to another agency after the creditor agency has submitted its debt claim to the Endowment and before the debt is collected completely, the National Endowment for the Arts must certify the total amount collected. Copies of the certification must be furnished to the employee, and to the creditor agency with notices of the employee’s transfer.
§ 1150.43 Determination of indebtedness.
In determining that an employee is indebted, the Endowment Official shall review the debt to make sure that it is valid and past due.
§ 1150.44 Notice requirements before offset.
Except as provided in § 1150.40(d), deductions shall not be made unless the Endowment Official first provides the employee with a minimum of 30 calendar days written notice. This Notice of Intent to Offset Salary (Notice of Intent) shall state:
(a) That the Endowment Official has reviewed the records relating to the claim and has determined that a debt is owed, the amount of the debt, and the facts giving rise to the debt.
(b) The Endowment’s intention to collect the debt by means of deduction from the employee’s current disposable pay account until the debt and all accumulated interest are paid in full;
(c) The amount, frequency, approximate beginning date, and duration of the intended deduction;
(d) An explanation of the Endowment’s requirement concerning interest, penalties, and administrative costs unless such payments are excused in accordance with § 1150.6(e);
(e) The employee’s right to inspect, request and receive records relating to the debt;
(f) The employee’s right to enter into a written agreement with the Endowment for a voluntary repayment schedule in lieu of offset differing from that proposed by the Endowment, so long as the terms of the repayment schedule proposed by the employee are agreeable to the Endowment;
(g) The right to a hearing, conducted by an impartial hearing official, on the Endowment’s determination of the debt, the amount of the debt, or percentage of disposable pay to be deducted each pay period, so long as a petition is filed by the employee as prescribed by the Endowment.
(h) That the timely filing of a petition for hearing shall stay the collection proceedings; (see § 1150.44).
(i) The method and time period for requesting a hearing;
(j) That a final decision on the hearing (if one is requested) will be issued at the earliest practical date, but not later than 60 calendar days after the filing of the petition requesting the hearing, unless the employee requests and the hearing official grants a delay in the proceedings;
(k) That any knowingly false or frivolous statements, representations, or evidence may subject the employee to:
(1) Disciplinary procedures appropriate under 5 U.S.C. Ch. 75, 5 CFR Part 752, or any other applicable statutes or regulations;
(2) Penalties under the False Claims Act, 31 U.S.C. 3729–3731, or any other applicable statutory authority; or
(3) Criminal penalties under 18 U.S.C. 286, 287, 1001, and 1002 or any other applicable statutory authority.
(l) Any other rights and remedies available to the employee under statutes or regulations governing the program for which the collection is being made;
(m) Unless there are applicable contractual or statutory provisions to the contrary, that amounts paid on or deducted for the debt which are later waived or found not owed to the United States shall be promptly refunded to the employee.
§ 1150.45 Request for a hearing.
(a) Except as provided in paragraph (d) of this section, if an employee wants a hearing concerning:
(1) The existence or amount of the debt; or
(2) The Endowment Official’s proposed offset schedule, the employee must file a petition for a hearing that is received by the Endowment Official not later than 20 calendar days from the date of the Endowment’s notice described in 1150.44.
(b) The petition must be signed by the employee and should admit or deny the existence of or the amount of the debt, or any part of the debt, briefly setting forth any basis for a denial. If the employee objects to the percentage of disposable pay to be deducted from each check, the petition should state the objection and the reason for it. The petition should identify and explain with reasonable specificity and brevity the facts, evidence and witnesses which the employee believes support his or her position.
(c) Upon receipt of the petition, the Endowment shall send the employee a copy of these regulations §§ 1150.40 through 1150.57 and the National Endowment for the Arts’ Implementing Chapter for Salary Offset.
(d) If the employee files a petition for hearing later than the 20 calendar days as described in paragraph (a) of this section, the Endowment Official may accept the request if the employee can show that the delay was because of circumstances beyond his or her control or because of failure to receive notice of the filing deadline.
§ 1150.46 Result if employee fails to meet deadlines.
An employee waives the right to a hearing, and will have his or her disposable pay offset in accordance with the Endowment’s offset schedule, if the employee:
(a) fails to file a petition for a hearing as prescribed in 1150.45; or
(b) is scheduled to appear and fails to appear at the hearing.
§ 1150.47 Conduct of hearing.
The Hearing Official for Salary Offset (Hearing Official) shall conduct the hearings in accordance with these regulations and the National Endowment for the Arts' Implementing Chapter for Salary Offset. The burden shall be on the employee to demonstrate that the existence or the amount of the debt is in error.
§ 1150.48 Written decision following a hearing.
The Hearing Official shall issue a written opinion no later than 60 days after the hearing. Written decisions provided after a request for a hearing shall include:
(a) A statement of the facts presented to support the nature and origin of the alleged debt;
(b) The Hearing Official's analysis, findings and conclusions, in light of the hearing, concerning the employee's and/or the Endowment's grounds;
(c) The amount and validity of the alleged debt; and
(d) The repayment schedule, if applicable.
§ 1150.49 Review of Endowment records related to the debt.
(a) Notification by employee. An employee who intends to inspect or copy Endowment records related to the debt must send a letter to the Endowment Official stating his or her intention. The letter must be received by the Endowment Official within 20 calendar days of the date of the Notice of Intent.
(b) Endowment Official's response. In response to timely notice submitted by the debtor as described in paragraph (a) of this section, the Endowment Official shall notify the employee of the location and time when the employee may inspect and copy Endowment records related to the debt.
§ 1150.50 Written agreement to repay debt as alternative to salary offset.
(a) Notification by employee. The employee may propose, in response to a Notice of Intent, a written agreement to repay the debt as an alternative to salary offset. Any employee who wishes to do this must submit a proposed written agreement to repay the debt which is received by the Endowment Official within 20 calendar days of the date of the Notice of Intent (see § 1150.44(f)).
(b) Endowment's response. In response to timely notice by the debtor as described in paragraph (a) of this section, the Endowment Official shall notify the employee whether the employee's proposed written agreement for repayment is acceptable. It is within the Endowment Officials discretion to accept a repayment agreement instead of proceeding by offset. In making this determination, the Endowment Official will balance the Endowment's interest in collecting the debt against hardship to the employee. If the debt is delinquent and the employee has not disputed its existence or amount, the Endowment Official will accept a repayment agreement instead of offset only if the employee is able to establish that offset would result in undue financial hardship or would be against equity and good conscience.
§ 1150.51 Procedures for salary offset: When deductions may begin.
(a) Deductions to liquidate an employee's debt shall be by the method and in the amount stated in the Endowment's Notice of Intent to collect from the employee's current pay.
(b) If the employee filed a petition for hearing with the Endowment Official before the expiration of the period provided for in § 1150.45, then deductions will not begin until the Endowment has provided the employee with a hearing and the final written decision is in favor of the Endowment.
(c) If an employee dies, retires, or resigns before collection of the amount of the indebtedness is complete, the remaining indebtedness shall be collected according by the procedures for administrative offset (see §§ 1150.20-1150.37).
§ 1150.52 Procedures for salary offset: Types of collection.
A debt shall be collected in a lump-sum or in installments. Collections will be by lump-sum collection unless the employee is financially unable to pay in one lump-sum, or if the amount of the debt exceeds 15 percent of disposable pay. In these cases, deductions shall be by installments.
§ 1150.53 Procedures for salary offset: Methods of collection.
(a) General. A debt shall be collected by deductions at officially-established pay intervals from an employee's current pay account, unless the employee and the Endowment Official agree to alternate arrangements for repayment. The alternative arrangement must be in writing and be signed by both the employee and the Endowment Official.
(b) Installment deductions. Installment deductions shall be made over a period not greater than the anticipated period of employment. The size and frequency of installment deductions will bear a reasonable relation to the size of the debt and the employee's ability to pay. However, the amount deducted for any period shall not exceed 15 percent of the disposable pay from which the deduction is made, unless the employee has agreed in writing to the deduction of a great amount. If possible, the installment payment will be sufficient in size and frequency to liquidate the debt in three years or less. Installment payments of less than $25 per pay period or $50 a month shall be accepted only in the most unusual circumstances.
(c) Sources of deductions. The Endowment will make deductions only from basic pay, special pay, incentive pay, retired pay, retainer pay, or in the case of an employee not entitled to basic pay, other authorized pay.
§ 1150.54 Procedures for salary offset: Imposition of interest.
Interest will be charged in accordance with § 1150.8(e).
§ 1150.55 Non-waiver of rights.
So long as there are no statutory or contractual provisions to the contrary, no employee involuntary payment (of all or a portion of a debt) collected under these regulations shall be interpreted as a waiver of any rights that the employee may have under 5 U.S.C. 5514.
§ 1150.56 Refunds.
(a) The Endowment shall refund promptly to the appropriate individual amounts offset under these regulations when a debt is waived or otherwise found not owing the United States (unless expressly prohibited by statute or regulation) or when the Endowment is directed by an administrative or judicial order to refund amounts deducted from the employee's current pay.
(b) The creditor agency will promptly return any amounts deducted by the Endowment to satisfy debts owed to the creditor agency when the debt is waived, found not owed, or when directed by an administrative or judicial order.
(c) Unless required by law, refunds under this subsection shall not bear interest.
§ 1150.57 Statute of limitations.
If a debt has been outstanding for more than 10 years after the agency's right to collect the debt first accrued, the agency may not collect by salary offset unless facts material to the
Government's right to collect were not known and could not reasonably have been known by the official or officials who were charged with the responsibility for discovery and collection of such debts.
[FR Doc. 92–3980 Filed 2–7–92; 8:45 am]
BILLING CODE 7537–01–M
This section of the FEDERAL REGISTER contains documents other than rules or proposed rules that are applicable to the public. Notices of hearings and investigations, committee meetings, agency decisions and rulings, delegations of authority, filing of petitions and applications and agency statements of organization and functions are examples of documents appearing in this section.
COMMISSION ON CIVIL RIGHTS
Agenda and Notice of Public Meeting of the North Carolina Advisory Committee
Notice is hereby given, pursuant to the provisions of the Rules and Regulations of the U.S. Commission on Civil Rights, that a meeting of the North Carolina Advisory Committee to the Commission will convene at 2 p.m. and adjourn at 5 p.m. on Friday, March 13, 1992, at the Sheraton Resort, Salter Path Road, Atlantic Beach, North Carolina 28512. The purpose of this meeting is: (1) To discuss the status of the Commission; (2) to hear reports on civil rights progress and/or problems in the State; and (3) to discuss the current project for FY 1992.
Persons desiring additional information, or planning a presentation to the Committee should contact North Carolina Chairperson, Joseph DiBona at 919/694–3924 or Bobby D. Doctor, Regional Director, Southern Regional Office of the U.S. Commission on Civil Rights at (404/730–2476, TDD 404/730–2481). Hearing impaired persons who will attend the meeting and require the services of a sign language interpreter should contact the Southern Regional Office at least five (5) working days before the scheduled date of the meeting.
The meeting will be conducted pursuant to the provisions of the rules and regulations of the Commission.
Dated at Washington, DC, February 18, 1992.
Carol-Lee Hurley,
Chief, Regional Programs Coordination Unit.
[FR Doc. 92–4134 Filed 2–21–92; 8:45 am]
BILLING CODE 6335–01–M
Agenda and Public Meeting of the Tennessee Advisory Committee
Notice is hereby given, pursuant to the provisions of the Rules and Regulations of the U.S. Commission on Civil Rights, that a meeting of the Tennessee Advisory Committee to the Commission will convene at 1 p.m. and adjourn at 5 p.m. on Tuesday, March 17, 1992, at the Residence Inn by Marriott, 2300 Elm Hill Pike, Nashville, Tennessee 37210. The purpose of the meeting is: (1) To discuss the status of the Commission; (2) to discuss and update current projects; and (3) to receive information from community leaders on racial tensions in Nashville.
Persons desiring additional information, or planning a presentation to the committee should contact Bobby D. Doctor, Regional Director, Southern Regional Office of the U.S. Commission on Civil Rights at (404/730–2476, TDD 404/730–2481). Hearing impaired persons who will attend the meeting and require the services of a sign language interpreter should contact the Southern Regional Office at least five (5) working days before the scheduled date of the meeting.
The meeting will be conducted pursuant to the provisions of the rules and regulations of the Commission.
Dated: February 18, 1992.
John J. Da Ponte, Jr.,
Executive Secretary.
[FR Doc. 92–4178 Filed 2–21–92; 8:45 am]
BILLING CODE 3510–D5–M
International Trade Administration
Initiation of Antidumping and Countervailing Duty Administrative Reviews
AGENCY: International Trade Administration/Import Administration, Department of Commerce.
ACTION: Notice of initiation of antidumping and countervailing duty administrative reviews.
SUMMARY: The Department of Commerce has received requests to conduct administrative reviews and various antidumping and countervailing duty orders, findings and suspension agreements with January anniversary dates. In accordance with the Commerce Regulations, we are initiating those administrative reviews.
EFFECTIVE DATE: February 24, 1992.
FOR FURTHER INFORMATION CONTACT: Roland L. MacDonald, Office of Antidumping Compliance, International Trade Administration, U.S. Department of Commerce, Washington, DC 20230, telephone (202) 377–2104.
SUPPLEMENTARY INFORMATION:
Background
The Department of Commerce ("the Department") has received timely requests, in accordance with § 353.22(a)(1) of the Department's regulations, for administrative reviews of various antidumping and countervailing duty orders, findings, and suspension agreements, with January anniversary dates.
Initiation of Reviews
In accordance with §§ 353.22(c) and 355.22(c) of the Department's regulations, we are initiating
administrative reviews of the following antidumping and countervailing duty orders, findings, and suspension agreements. We intend to issue the final results of these reviews not later than January 31, 1993.
| Antidumping duty proceedings and firms | Periods to be reviewed |
|----------------------------------------|------------------------|
| France: | |
| Anhydrous sodium metasilicate A-427-098 | |
| Rhone-Poulenc.......................... | 1/1/91–12/31/91 |
| Korea: | |
| Stainless steel cooking ware A-580-601 | |
| Namil Metal Co........................ | 1/1/91–12/31/91 |
| Dae Lim Trading Co | |
| Photo albums and filler pages A-580-601 | |
| Four Star Trading Co .................. | 12/1/90–11/30/91 |
| Peoples Republic of China: | |
| Potassium permanganate A-570-001 | |
| China National Chemicals Import and Export Corporation | 1/1/91–12/31/91 |
| Tongji Chemical Plant | |
| Jinan Huayin Chemical General Factory | |
| Tianjin Huiyang Chemical Plant | |
| Changsha Organic Chemical Plant | |
| Beijing Dayu Chemical Plant | |
| Zunyi Chemical Plant | |
| Chongqing Jialing Chemical Plant | |
| Jinan Taifu Chemical Industry Products Co., Ltd | |
| China Export Bases Development Corp. | |
| Guangdong Foreign Economics Development Co., Ltd | |
| Guangdong Foreign Trading Development | |
| Guangdong Foreign Economic Relations & Guangxi Import & Export Trading Corporation | |
| Guilin Native Produce & Animal | |
| China Native Produce and Animal By-Products I/E Corporation | |
| Shenzhen Metals Materials Co. | |
| Hunan Chemicals & Medicines | |
| Guangxi Zhuang Autonomous Region Chemical Spa | |
| Guangzhou Chemicals | |
| China National Foreign Trade | |
| Guangxi Guilin Prefecture | |
| Hei Long Jiang Machinery Imports Exports | |
| Strong Guide | |
| Guangzhou Chemicals Sinchart | |
| Antidumping duty proceedings and firms | Periods to be reviewed |
|----------------------------------------|------------------------|
| Tin Sing Chemical Engineers, Ltd | |
| K L & Company | |
| Yue Pak Co., Ltd | |
| Sam Wing International, Ltd | |
| Far Ocean Trading Co | |
| Landyet Company, Ltd | |
| Go Up Company | |
| Hip Fung Trading Company | |
| AEL Asia Express (HK) Ltd | |
| Andeal Industry Supply Co. Ltd | |
| Asia Express Company | |
| Asia Express Packages | |
| Chemproha Chemical Distributors Ltd | |
| Mayer Shipping Ltd | |
| Newsedean Trading Co. Ltd | |
| Pan Air & Sea Forwarders (HK) Ltd | |
| Power Shipping Co | |
| Progressive Resources Ltd | |
| Premier Maritime | |
| Samlex Import & Export Co | |
| Seagull Container Line | |
| Continental Freight Forwarders | |
| Devoted Cargo Services (HK) Ltd | |
| Dynamic Freight Services Ltd | |
| Far Ocean Trading Co | |
| He-Po Chemicals Ltd | |
| ICD Group (HK) Ltd | |
| International Merona Ltd | |
| J. A. Montes (HK) Ltd | |
| Kenwa Shipping Co. Ltd | |
| Sidneyson Ltd | |
| Vincent Shipping Co | |
| Melkien Trading Co. Ltd | |
| AVA INTL | |
| BBT | |
| PRO CHEMIE | |
| Countervailing duty proceedings | |
| Thailand: | |
| Butt-Weld Pipe Fittings C-549-804 | 1/1/91–12/31/91 |
| Subsidized investigations | |
| Colombia: | |
| Roses and other fresh cut flowers | 1/1/91–12/31/91 |
| C-301-003 | |
| Miniature carnations | 1/1/91–12/31/91 |
| C-301-601 | |
| Costa Rica: | |
| Certain fresh cut flowers C-223-601 | 1/1/91–12/31/91 |
| Hungary: | |
| Truck trailer axles and brake assemblies A-437-001 | |
| RABA | 1/1/91–12/31/91 |
Interested parties must submit applications for administrative protective orders in accordance with §§ 353.34(b) and 355.34(b) of the Department's regulations.
These initiations and this notice are in accordance with section 751(a) of the Tariff Act of 1930 (19 U.S.C. 1875(a)) and 19 CFR 353.22(c) and 355.22(c) (1989).
Dated: February 18, 1992.
Joseph A. Spetrini,
Deputy Assistant Secretary for Compliance.
[FR Doc. 92–4179 Filed 2–21–92; 8:45 am]
BILLING CODE 3510–DS–M
National Oceanic and Atmospheric Administration
Marine Mammals; Receipt of Application for Permit
AGENCY: National Marine Fisheries Service, NOAA.
ACTION: Receipt of application for permit (P494).
Notice is hereby given that Mr. Paul D. Jobsis, Scripps Institution of Oceanography, University of California, San Diego, La Jolla, CA 92093–0204, has applied for a Permit to take marine mammals as authorized by the Marine Mammal Protection Act of 1972 (16 U.S.C. 1361–1407), and the Regulations Governing the Taking and Importing of Marine Mammals (50 CFR part 216).
The applicant requests authority to obtain up to 15 harbor seals (*Phoca vitulina*) from local strandings, rehabilitated or captive born stock at Sea World of California. The purpose of the study is to better understand how seals utilize their hemoglobin and myoglobin oxygen stores during diving, and to better understand the differences in restrained dives and unrestrained dives. Activities will be conducted at Scripps Institute of Oceanography.
The arrangements and facilities for transporting and maintaining the marine mammals requested in this application have been inspected by a licensed veterinarian, who has certified that such arrangements and facilities are adequate to provide for the well-being of the marine mammals involved.
Concurrent with the publication of this notice in the *Federal Register*, the Secretary of Commerce is forwarding copies of this application to the Marine Mammal Commission and the Committee of Scientific Advisors.
Written data or views, or requests for a public hearing on this application should be submitted to the Assistant Administrator for Fisheries, National Marine Fisheries Service, U.S. Department of Commerce, 1335 East-West Hwy., room 7324, Silver Spring, Maryland 20910, within 30 days of the publication of this notice. Those individuals requesting a hearing should set forth the specific reasons why a hearing on this particular application would be appropriate. The holding of such hearing is at the discretion of the
Assistant Administrator for Fisheries. All statements and opinions contained in this application are summaries of those of the Applicant and do not necessarily reflect the views of the National Marine Fisheries Service.
Documents submitted in connection with the above application are available for review by interested persons in the following offices:
By appointment: Office of Protected Resources, National Marine Fisheries Service, NOAA, 1335 East-West Hwy., Suite 7324, Silver Spring, Maryland 20910; and
Director, Southwest Region, National Marine Fisheries Service, 501 West Ocean Blvd., Long Beach, California 90802-4213 (310/980-4015).
Dated: February 12, 1992.
Charles Karnella,
Acting Director, Office of Protected Resources.
[FR Doc. 92–4113 Filed 2–21–92; 8:45 am]
BILLING CODE 3510–22–M
COMMODITY FUTURES TRADING COMMISSION
Financial Products Advisory Committee
This is to give notice, pursuant to section 10(a) of the Federal Advisory Committee Act, 5 U.S.C. App. 2 section 10(a) and 41 CFR 101–6.1015(b), that the Commodity Futures Trading Commission’s Financial Products Advisory Committee will conduct a public meeting in the Lower Level Hearing Room (B–1) at the Commission’s Washington, DC headquarters located at 2033 K Street, NW., Washington, DC 20581, on March 12, 1992, beginning at 1:30 p.m. and lasting until 5 p.m. The agenda will consist of:
Agenda
1. Effect of the Supreme Court’s decision in Arkansas Best Corp. v. Commissioner, 485 U.S. 212 (1988), on hedging in the futures markets.
2. Review of recommendations made in the Committee’s 1987 study on the CFTC’s definition of hedging. Discussion of need to update study or to explore related areas.
3. Report from Division of Trading and Markets on proposed rules creating an accredited investor exemption to some commodity pool regulations and permitting bifurcated risk disclosure. Discussion of applicability of regulatory approach of these proposals to other Commission regulations.
4. Block trading—APS, LOX, other systems. Discussion of other approaches to permitting block trading.
5. International issues update—foreign stock index futures, proposed relief to permit FCMS to offer and sell foreign-exchange traded options to non-U.S. persons, global settlement. Discussion of other possible areas of relief.
6. Development of agenda items for future meetings.
7. Other items of Committee consideration: timing of next meeting; other Committee business.
The purpose of this meeting is to solicit the views of the Committee on these agenda matters. The Advisory Committee was created by the Commodity Futures Trading Commission for the purpose of advising the Commission on the assessment of issues concerning individuals and industries interested in or affected by financial markets regulated by the Commission. The purposes and objectives of the Advisory Committee are more fully set forth in the April 25, 1991 Charter of the Advisory Committee.
The meeting is open to the public. The Chairman of the Advisory Committee, CFTC Commissioner Sheila C. Bair, is empowered to conduct the meeting in a fashion that will, in her judgement, facilitate the orderly conduct of business. Any member of the public who wishes to file a written statement with the Advisory Committee should mail a copy of the statement to the attention of: the Commodity Futures Trading Commission Financial Products Advisory Committee, c/o Susan Milligan, 2033 K Street NW., Washington, DC 20581, before the meeting. Members of the public who wish to make oral statements should also inform Ms. Milligan in writing at the foregoing address at least three business days before the meeting. Reasonable provision will be made, if time permits, for an oral presentation of no more than five minutes each in duration.
Issued by the Commission in Washington, DC, on February 19, 1992.
Jean A. Webb,
Secretary of the Commission.
[FR Doc. 92–4181 Filed 2–21–92; 8:45 am]
BILLING CODE 6351–01–M
DEPARTMENT OF DEFENSE
Office of the Secretary
Renewal of the Department of Defense Chlorofluorocarbons Advisory Committee
ACTION: Notice.
SUMMARY: The Department of Defense Chlorofluorocarbons (CFC’s) Advisory Committee was renewed for a two-year period, effective February 16, 1992, in accordance with the provisions of Public Law 92–463, the “Federal Advisory Committee Act.” The CFC’s Committee was originally established pursuant to Public Law 101–189, the “National Defense Authorization Act for Fiscal Years 1990 and 1991.”
The CFC’s Committee provides timely and expert advice to the Secretary of Defense and other DoD officials on the formulation of policy with respect to the uses of CFC’s within the Department of Defense and the consideration of substitute technologies. The CFC’s committee will determine the feasibility
and cost estimation of chemical substitutes and alternative technologies and will assist in technology transfer. Membership on the CFC's Committee is well-balanced in terms of the specialized missions to be accomplished and the diverse interest groups represented. Members are drawn from among senior DoD and Environmental Protection Agency officials, private industry representatives, and state government legislators.
For further information on the CFC's Committee, contact: Mr. William Goins office of the Deputy Assistant Secretary of Defense (Environment) (703) 695–8360.
Dated: February 18, 1992.
L. M. Bynum,
Alternate OSD Federal Register Liaison Officer, Department of Defense.
[FR Doc. 92–4102 Filed 2–21–92; 8:45 am]
BILLING CODE 3810–01–M
The Joint Staff; Joint Strategic Target Planning Staff Strategic Advisory Group: Closed Meeting
AGENCY: Joint Strategic Target Planning Staff, Department of Defense.
ACTION: Notice of closed meeting.
SUMMARY: The Director of Strategic Target Planning has scheduled a closed meeting of the Strategic Advisory Group.
DATES: The meeting will be held from 1 to 3 April 1992.
ADDRESSES: The meeting will be held at Offutt AFB, Nebraska.
FOR FURTHER INFORMATION CONTACT: The Joint Strategic Target Planning Staff, Strategic Advisory Group, Offutt AFB, Nebraska 68113.
SUPPLEMENTARY INFORMATION: The purpose of the meeting is to discuss strategic issues that relate to the development of the Single Integrated Operational Plan (SIOP). Full development of the topics will require discussion of information classified TOP SECRET in accordance with Executive Order 12356, 2 April 1982. Access to this information must be strictly limited to personnel having requisite security clearances and specific need-to-know. Unauthorized disclosure of the information to be discussed at the SAG meeting could have exceptionally grave impact upon national defense. Accordingly, the meeting will be closed in accordance with 5 U.S.C. app II Para 10(d) (1976), as amended.
Dated: February 14, 1991.
Linda M. Bynum,
OSD Federal Register Liaison Officer, Department of Defense.
[FR Doc. 92–4101 Filed 2–21–92; 8:45 am]
BILLING CODE 3810–01–M
DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission
[Docket Nos. ER92–309–000, et al.]
Electric Rate, Small Power Production, and Interlocking Directorate Filings; Florida Power & Light Company, et al.
February 13, 1992.
Take notice that the following filings have been made with the Commission:
1. Florida Power & Light Company
[Docket No. ER92–309–000]
Take notice that Florida Power & Light Company (FPL) on February 4, 1992, tendered for filing an agreement entitled "Agreement for Connection of Facilities Among Florida Power & Light Company and Seminole Electric Cooperative, Inc. and Lee County Electric Cooperative, Inc." FPL requests that the agreement be made effective December 31, 1991.
Comment date: February 27, 1992, in accordance with Standard Paragraph E at the end of this notice.
2. Northern States Power Company (MN), Northern States Power Company (WI)
[Docket No. ER92–302–000]
Take notice that on January 31, 1992, Northern States Power Company (NSP) tendered for filing the Eastern Interconnection and Interchange Agreement dated December 31, 1991, between Northern States Power Company (Minnesota) (NSP–MN), Northern States Power Company (Wisconsin) (NSP–WI) and the Wisconsin Public Incorporated System (WPPI).
The Eastern Interconnection and Interchange Agreement (Eastern Agreement) provides for certain sales of power and/or energy between NSP and WPPI pursuant to service schedules attached to the Eastern Agreement, including the terms and conditions of such services. NSP services pursuant to the Eastern Agreement will be provided to WPPI on behalf of member cities in eastern Wisconsin not located in the Mid-Continent Area Power Pool (MAPP) region and not subject to the MAPP Agreement.
NSP requests that the Eastern Interconnection and Interchange Agreement be accepted for filing effective November 1, 1991, and requests waiver of Commission's notice requirements in order for the Agreement to be accepted for filing on that date.
Comment date: February 27, 1992, in accordance with Standard Paragraph E at the end of this notice.
3. Chicago Energy Exchange of Chicago, Inc.
[Docket Nos. ER90–225–006 and EL90–17–001]
Take notice that on October 25, 1991 and January 30, 1992, Chicago Energy Exchange of Chicago, Inc. (Energy Exchange) filed certain information as required by Ordering Paragraph (L) of the Commission's April 19, 1990 order in this proceeding. 50 FERC ¶ 61,054 (1990). Copies of Energy Exchange informational filing are on file with the Commission and are available for public inspection.
4. PacifiCorp Electric Operations
[Docket No. ER91–553–000]
Take notice that PacifiCorp Electric Operations (PacifiCorp) on February 4, 1992 tendered for filing, in accordance with the Commission's staff's request, an amended filing of the Electric Supply Agreement (Agreement) between PacifiCorp and Brigham City Corporation (Brigham).
The Amendment provides additional information relating to the charges for capacity and energy and the escalator used to establish future energy prices.
PacifiCorp respectfully renews its request for a waiver of prior notice and that an effective date of October 1, 1999 be assigned by the Commission.
Copies of this filing have been supplied to Brigham and the Utah Public Service Commission.
Comment date: February 27, 1992, in accordance with Standard Paragraph E at the end of this notice.
5. Scranton Energy Partners
[Docket No. QF92–12–000]
On February 10, 1992, Scranton Energy Partners, tendered for filing an amendment to its filing in this docket. No determination has been made that the submittal constitutes a complete filing.
The amendment provides additional information pertaining to ownership structure, use of fossil fuel and transmission line connecting to the facility.
Comment date: March 3, 1992, in accordance with Standard Paragraph E at the end of this notice.
6. James River II, Inc.
[Docket No. QF91-209-000]
On February 3, 1992, James River II, Inc. tendered for filing an amendment to its filing in this docket. No determination has been made that the submittal constitutes a complete filing.
The amendment provides additional information pertaining primarily to the technical data and the ownership structure of the small power production facility.
Comment date: February 26, 1992, in accordance with Standard Paragraph E at the end of this notice.
7. Montaup Electric Company
[Docket No. ER92-315-000]
Take notice that on February 6, 1992, Montaup Electric Company (Montaup) filed a letter under Section 205 of the Federal Power Act of a credit of $4,776,089 under its Purchased Capacity Adjustment Clause (PCAC) to true up the amounts billed in 1991 under a forecast billing rate to conform with actual purchased capacity costs. The credit will appear in bills for January 1992 service rendered for all requirement service to Montaup's affiliates Eastern Edison Company in Massachusetts and Blackstone Valley Electric Company in Rhode Island, and for contract demand service to one affiliate, Newport Electric Corporation, and two non-affiliates: Pascong Fire District in Rhode Island and the Town of Middleborough in Massachusetts.
Comment date: February 27, 1992, in accordance with Standard Paragraph E at the end of this notice.
8. National Electric Associates Limited Partnership
[Docket No. ER90-168-007]
Take notice that on January 23, 1992, National Electric Associates Limited Partnership (NEA) filed certain information as required by Ordering Paragraph (L) of the Commission's March 20, 1990 order in this proceeding, 50 FERC ¶ 61,378 (1990). Copies of NEA's informational filing are on file with the Commission and are available for public inspection.
9. Northern Indiana Public Service Company
[Docket No. ER92-314-000]
Take notice that on February 6, 1992, Northern Indiana Public Service Company (NIPSCO) tendered for filing as a change in rate schedules, Addendum 1 to the rates for service provided by NIPSCO in the individual interconnection agreements with Central Illinois Public Service Company (CIPS), Commonwealth Edison Company/Detroit Edison Company (CPR), Indiana Michigan Power Company (I&M), Indiana Municipal Power Agency (IMPA), PSI Energy, Inc. (PSI), and Wabash Valley Power Association (WVPA).
Copies of this filing have been served upon all of the parties and the Indiana Utility Regulatory Commission.
Comment date: February 27, 1992, in accordance with Standard Paragraph E at the end of this notice.
Standard Paragraph:
E. Any person desiring to be heard or to protest said filing should file a motion to intervene or protest with the Federal Energy Regulatory Commission, 825 North Capitol Street NE., Washington, DC 20426, in accordance with Rules 211 and 214 of the Commission's Rules of Practice and Procedure (18 CFR 385.211 and 385.214). All such motions or protests should be filed on or before the comment date. Protests will be considered by the Commission in determining the appropriate action to be taken, but will not serve to make protestants parties to the proceeding. Any person wishing to become a party must file a motion to intervene. Copies of this filing are on file with the Commission and are available for public inspection.
Lois D. Cashell,
Secretary.
[FR Doc. 92–4156 Filed 2–21–92; 8:45 am]
BILLING CODE 8717–01–M
[Docket Nos. CP92–329–000, et al.]
Panhandle Eastern Pipe Line Company, et al.; Natural Gas Certificate Filings
Take notice that the following filings have been made with the Commission:
1. Panhandle Eastern Pipe Line Company
[Docket No. CP92–329–000]
February 10, 1992.
Take notice that on February 4, 1992, Panhandle Eastern Pipe Line Company (Panhandle), P.O. Box 1642, Houston, Texas 77251–1642, filed in Docket No. CP92–329–000 a request pursuant to §§ 157.205 and 284.211 of the Commission's Regulations for authorization to construct and operate two 2" taps and associated piping located in Christian County, Illinois, under Panhandle's blanket certificate issued in Docket No. CP83–83–000 pursuant to section 7 of the Natural Gas Act, all as more fully set forth in the request which is on file with the Commission and open to public inspection.
It is asserted that these taps would enable Panhandle to provide transportation service to Archer Daniel Midland Company, pursuant to § 284.223(a). It is stated that construction would begin upon expiration of the 45-day notice period and the facilities would cost approximately $116,500.
Comment date: March 26, 1992, in accordance with Standard Paragraph G at the end of this notice.
2. Northern Natural Gas Company
[Docket No. CP92–334–000]
February 10, 1992.
Take notice that on February 6, 1992, Northern Natural Gas Company (Northern), 1111 South 103rd Street, Omaha, Nebraska 68124–1000, filed in Docket No. CP90–2165–000, a request pursuant to § 157.205 of the Commission's Regulations under the Natural Gas Act (18 CFR 157.205) for authorization to construct and operate two small volume measuring stations and appurtenant facilities as delivery points to provide natural gas deliveries to Peoples Natural Gas Company, a Division of UtiliCorp United Inc. (Peoples) under the authorization issued in Docket No. CP82–401–000 pursuant to section 7 of the Natural Gas Act, all as more fully set forth in the request which is on file with the Commission and open to public inspection.
Northern requests this authority to provide natural gas service to Peoples, under Northern's Argus Rate Schedule to serve Sy Huelskamp, an end-user located in Finney County, Kansas, and under Northern's Rate Schedule CD–1 to serve the U.S. Fish and Wildlife Services, a commercial end-user in Jackson County, Minnesota. It is stated that the additional natural gas volumes will be used by Mr. Huelskamp as fuel for an irrigation engine and by the U.S. Fish and Wildlife Services as heating for their offices. It is anticipated that the proposed peak day and annual volumes to be delivered by Peoples at the affected delivery points and the end use of such volumes are as follows:
| Delivery point | Proposed peak day (McF) | Annual |
|-------------------------|-------------------------|--------|
| Huelskamp | 72 | 9,730 |
| U.S. Fish and Wildlife | 4 | 826 |
Northern states that the proposed deliveries to Peoples will be within the currently effective entitlements for Peoples. Northern states that the
proposed volumes will be served from the total firm entitlements currently assigned to Rural Tap Sales—Other Mainline. Northern avers that there will not be any firm entitlements assigned to Sy Huelskamp or the U.S. Fish and Wildlife Services.
Northern states that installation of the proposed facilities will be financed in accordance with the General Terms and Conditions of Northern’s FERC Gas Tariff, Third Revised Volume No. 1. Northern estimates the total cost to install the proposed delivery points at $2,965, which cost Peoples will be required to reimburse Northern.
Northern states that the total volumes of gas to be delivered to he customer after request do not exceed the total volumes authorized prior to the request. Northern further states that the proposal is not prohibited by its existing tariff and that it has sufficient capacity to accomplish the changes proposed without detriment or disadvantage to its other customers.
Comment date: March 26, 1992, in accordance with Standard Paragraph G at the end of this notice.
3. Kern River Gas Transmission Company
[Docket No. CP92–337–000]
February 12, 1992.
Take notice that on February 6, 1992, Kern River Gas Transmission Company (Kern River), P.O. Box 2511, Houston, Texas 77252, filed in Docket No. CP92–337–000 a request pursuant to §§ 157.205 and 157.211 of the Commission’s Regulations under the Natural Gas Act (18 CFR 157.205, 157.211) for authorization to construct and operate certain tap and meter facilities under Kern River’s blanket certificate issued in Docket No. CP89–2045–000 pursuant to section 7 of the Natural Gas Act, all as more fully set forth in the request that is on file with the Commission and open to public inspection.
Kern River proposes to construct and operate a 3-inch tap and metering facilities, including buildings and ancillary equipment, required to deliver gas to Amoco Energy Trading Corporation (Amoco) at a point on Kern River’s system in Utah. It is stated that pursuant to a transportation service agreement between Kern River and Amoco, Kern River would deliver gas to Amoco at, inter alia, milepost 345.8 on Kern River’s mainline facilities at Section 32, Township 34 South, Range 14 West in Iron County, Utah. Kern River also states that the maximum delivery volume at this point would be 8,000 Mcf per day.
Kern River states that it would provide the related service to Amoco under authority of its blanket transportation certificate issued in Docket No. CP89–2047–000 and pursuant to the terms of Kern River’s KRF–1 firm transportation rate schedule.
Additionally, Kern River states that deliveries to Amoco would not impact Kern River’s ability to render service to other firm shippers within their firm contract MDQ’s.
Comment date: March 30, 1992, in accordance with Standard Paragraph G at the end of this notice.
4. Mobil Natural Gas Inc., et al.
[Docket No. CI88–307–003, et al.]
February 13, 1992.
Take notice that each Applicant listed on the Appendix hereto filed an application pursuant to sections 4 and 7 of the Natural Gas Act and the Federal Energy Regulatory Commission’s [Commission] regulations thereunder for extension of its blanket limited-term certificate with pregranted abandonment authorizing sales for resale in interstate commerce previously issued by the Commission for a term expiring March 31, 1992, all as more fully set forth in the applications which are on file with the Commission and open to public inspection.
Comment date: March 3, 1992, in accordance with Standard Paragraph J at the end of this notice.
APPENDIX
| Docket No. | Dated filed | Applicant |
|------------|-------------|-----------|
| CI88–307–003 | 2–6–92 | Mobil Natural Gas Inc., 12450 Greenpoint Drive, Houston, Texas 77060-1901. |
| CI88–346–006 * | 2–6–92 | Anthem Energy Company, L.P., (formerly Antham Energy Company), 333 Clay Street, suite 2000, Houston, Texas 77002. |
| CI91–77–001 | 2–3–92 | Gulf States Gas Corporation, 1000 Louisiana, suite 4960, Houston, Texas 77002. |
| CI91–78–003 * | 2–3–92 | Gulf States Pipeline Corporation, 1324 N. Hearne Avenue, suite 300, Shreveport, Louisiana 71107. |
* Applicant also requests amendment of its certificate (1) to reflect Anthem Energy Company, L.P. as the certificate holder and (2) to include authorization for sales for resale in interstate commerce of imported natural gas, including liquefied natural gas, and natural gas purchased from non-first sellers, including interstate pipelines, intrastate pipelines and local distribution companies.
* Applicant is an intrastate pipeline company.
5. Tennessee Gas Pipeline Company
[Docket No. CP92–338–000]
February 13, 1992.
Take notice that on February 7, 1992, Tennessee Gas Pipeline Company (Tennessee), P.O. Box 2511, Houston, Texas 77252, filed in Docket No. CP92–338–000 a request pursuant to § 157.205 of the Commission’s Regulations under the Natural Gas Act (18 CFR 157.205) for authorization to construct and operate a new delivery point for Tennegasco Corporation (Tennegasco) under Tennessee’s blanket certificate issued in Docket No. CP82–413–000 pursuant to section 7 of the Natural Gas Act, all as more fully set forth in the request which is on file with the Commission and open to public inspection.
Tennessee states that it has entered into an amendment dated February 6, 1992, to a gas transportation agreement with Tennegasco to deliver up to 1,000 dt of natural gas per day to HUBCO Exploration, Inc. (HUBCO), for Tennegasco’s account. The gas would be used for gas lift purposes, it is stated.
In order to deliver the natural gas to HUBCO, Tennessee requests authorization to construct and operate an additional delivery point, consisting of two 1-inch hot taps and 1-inch high pressure tubing, in Plaquemines Parish, Louisiana. Tennessee states that it would be reimbursed for the cost of the facilities.
Tennessee further states that the total quantities of natural gas to be delivered to Tennegasco would not exceed presently authorized quantities and the change is not prohibited by Tennessee’s existing tariff. Tennessee asserts that it has sufficient capacity in its system to accomplish the deliveries of gas at the new delivery point without detriment or disadvantage to its other customers.
Comment date: March 30, 1992, in accordance with Standard Paragraph G at the end of this notice.
6. Marathon Oil Company
[Docket No. CI82–78–001]
February 13, 1992.
Take notice that on December 23, 1991, as supplemented on January 27, 1992, Marathon Oil Company (Marathon) of P.O. Box 3128, Houston, Texas 77253, filed an application pursuant to section 7 of the Natural Gas Act and the Federal Energy Regulatory Commission’s [Commission] regulations thereunder for a blanket certificate to
authorize jurisdictional sales of gas under contracts to which Marathon is or becomes a successor-in-interest prior to the effective date of total decontrol under the Natural Gas Wellhead Decontrol Act of 1989, all as more fully set forth in the application which is on file with the Commission and open for public inspection. Marathon also requests that the Commission waive its regulations regarding the establishment of rate schedules.
Comment date: March 5, 1992, in accordance with Standard Paragraph J at the end of this notice.
7. El Paso Natural Gas Company
[Docket No. CP92–341–000]
February 13, 1992.
Take notice that on February 10, 1992, El Paso Natural Gas Company (El Paso), Post Office Box 1492, El Paso, Texas 79978, filed in Docket No. CP92–341–000 a request pursuant to §§ 157.205 and 157.216 of the Commission’s Regulations under the Natural Gas Act (18 CFR 157.205 and 157.216) for authorization to abandon 21 miscellaneous tap facilities and the services rendered through those facilities, under its blanket certificate issued in Docket No. CP82–435–000, pursuant to section 7(b) of the Natural Gas Act, all as more fully set forth in the request which is on file with the Commission and open to public inspection.
El Paso states it periodically reviews the operating status of its facilities. It is stated that the review, along with the customers’ advisements, indicates that there are twenty-one miscellaneous tap and/or meter facilities eligible for abandonment, consisting of eighteen taps and three meter stations. El Paso indicates that eighteen of the facilities were used to serve Southwest Gas Corporation and that the other three facilities were used to serve Duncan Rural Services Inc., Citizens Utilities Company, and City of McLean, Texas. Accordingly, El Paso proposes to abandon the twenty-one facilities, with associated appurtenances, and the natural gas services rendered through these facilities.
El Paso states that it was authorized to construct and operate the facilities and provide the related services under specific certificates or as permitted under § 2.55(c) of the Commission’s Rules of Practice and Procedure. It is indicated that the facilities were required to facilitate, generally, the delivery and/or measurement and sale of natural gas from its interstate transmission pipeline system to certain customers for resale for residential, commercial or agricultural uses.
El Paso has submitted agreements with the customers consenting to the facility and service abandonment. It is indicated that the abandonments would not result in or cause any interruption, reduction or termination of natural gas service presently rendered by El Paso to any of its customers. El Paso also states that it would remove and place into stock the salvable materials and scrap the nonsalvable items, without change in its average cost of service.
Comment date: March 30, 1992, in accordance with Standard Paragraph G at the end of this notice.
8. Columbia Gas Transmission Corporation
[Docket No. CP92–339–000]
February 13, 1992.
Take notice that on February 7, 1992, Columbia Gas Transmission Corporation (Columbia), 1700 MacCorkle Avenue, SE., Charleston, West Virginia, 25314, filed in Docket No. CP92–339–000 a request pursuant to § 157.205 of the Commission’s Regulations under the Natural Gas Act (NGA) for authorization to establish an additional delivery point for service to South Jersey Gas Company (South Jersey), an existing wholesale customer, under Columbia’s blanket certificate issued in Docket No. CP83–76–000 pursuant to section 7 of the NGA, all as more fully set forth in the request which is on file with the Commission and open to public inspection.
Columbia states that South Jersey has requested the additional delivery point in order to supplement its existing markets. It is stated that Columbia would utilize the delivery point for sales to South Jersey pursuant to Columbia’s Rate Schedule CDS of up to 35,000 dt equivalent of natural gas per day and 3,650,000 dt equivalent on an annual basis for redelivery through South Jersey’s distribution system in Gloucester County, New Jersey. Columbia explains that the end uses of the gas would be residential, commercial and industrial. It is asserted that these sales would be within South Jersey’s currently authorized peak day entitlement from Columbia and that there would be no impact on Columbia’s other customers. It is further asserted that no construction would be required to place the delivery point in service.
Comment date: March 30, 1992, in accordance with Standard Paragraph G at the end of this notice.
9. MidCon Marketing Corp., et al.
[Docket No. CI87–307–007, et al.]
February 13, 1992.
Take notice that each Applicant listed on the Appendix hereto filed an application pursuant to sections 4 and 7 of the Natural Gas Act and the Federal Energy Regulatory Commission’s (Commission) regulations thereunder for extension of its blanket limited-term certificate with pregranted abandonment authorizing sales for resale in interstate commerce previously issued by the Commission for a term expiring March 31, 1992, all as more fully set forth in the applications which are on file with the Commission and open for public inspection.
Comment date: March 5, 1992, in accordance with Standard Paragraph J at the end of the notice.
APPENDIX
| Docket No. | Date filed | Applicant |
|------------|------------|-----------|
| CI87–307–007 * | 2–11–92 | MidCon Marketing Corp., 701 East 22nd Street, Lombard, Illinois 60148. |
| CI89–483–002 * | 2–7–92 | Citrus Industrial Sales Company, Inc., P.O. Box 1188, Houston, Texas 77251–1188. |
| CI90–71–002 * | 2–7–92 | Citrus Trading Corp., P.O. Box 1188, Houston, Texas 77251–1188. |
| CI90–149–002 * | 2–7–92 | Citrus Marketing, Inc., P.O. Box 1188, Houston, Texas 77251–1188. |
* Applicant also requests amendment of its certificate to remove the rate restriction on sales of gas purchased from its affiliated interstate pipeline under the joint interstate sales service (ISS) program.
* Applicant also requests amendment of its certificate to remove the condition that the certificate is subject to the outcome of Docket No. RM87–5 and remove the rate restriction applicable to sales of ISS gas purchased from its affiliated pipeline.
10. Transcontinental Gas Pipe Line Corporation
[Docket No. CP92–348–000]
February 14, 1992.
Take notice that on February 12, 1992, Transcontinental Gas Pipe Line Corporation (Transco), P.O. Box 1396, Houston, Texas 77251, filed in Docket No. CP92–348–000 an application pursuant to section 7(b) of the Natural Gas Act for permission and approval to abandon certain services to Tennessee Gas Pipeline Company (Tennessee) which are being performed under
* This notice does not provide for consolidation for hearing of the several matters covered herein.
Transco's Rate Schedules X-181 and X-259, all as more fully set forth in the application on file with the Commission and open to public inspection.
Transco requests authorization to abandon an exchange and transportation arrangement (Rate Schedule X-181; agreement dated June 2, 1978) with Tennessee which was authorized by Commission order issued November 22, 1978, in CP78-422-000 (5 FERC ¶ 61,165), by which Transco transports up to 25,000 Mcf per day of natural gas available to Tennessee in High Island Block A-330.
Additionally, Transco requests authorization to abandon an interruptible transportation service (Rate Schedule X-259; agreement dated February 5, 1985) to Tennessee which was certificated in Docket No. CP86-220-000 on February 3, 1986 (34 FERC ¶ 62,293), and by which up to 150,000 Mcf of natural gas produced in Brazos Area Blocks A-16, A-17, A-22, A-28, Mustang Island Block A-65, and Galveston Area Blocks 391 and 393 is transported.
Transco explains that, although the terms of the agreements have not expired, Transco and Tennessee have agreed to the early abandonment of the services to be effective on the date the Commission grants the requested authorization.
Transco advises that no facilities would be abandoned.
Comment date: March 6, 1992, in accordance with Standard Paragraph F at the end of this notice.
Standard Paragraphs
F. Any person desiring to be heard or make any protest with reference to said filing should on or before the comment date file with the Federal Energy Regulatory Commission, 825 North Capitol Street NE., Washington, DC 20426, a motion to intervene or a protest in accordance with the requirements of the Commission's Rules of Practice and Procedure (18 CFR 385.211 and 385.214) and the Regulations under the Natural Gas Act (18 CFR 157.10). All protests filed with the Commission will be considered by it in determining the appropriate action to be taken but will not serve to make the protestants parties to the proceeding. Any person wishing to become a party to a proceeding or to participate as a party in any hearing therein must file a motion to intervene in accordance with the Commission's Rules.
Take further notice that, pursuant to the authority contained in and subject to jurisdiction conferred upon the Federal Energy Regulatory Commission by sections 7 and 15 of the Natural Gas Act and the Commission's Rules of Practice and Procedure, a hearing will be held without further notice before the Commission or its designee on this filing if no motion to intervene is filed within the time required herein, if the Commission on its own review of the matter finds that a grant of the certificate is required by the public convenience and necessity. If a motion for leave to intervene is timely filed, or if the Commission on its own motion believes that a formal hearing is required, further notice of such hearing will be duly given.
Under the procedure herein provided for, unless otherwise advised, it will be unnecessary for the applicant to appear or be represented at the hearing.
G. Any person or the Commission's staff may, within 45 days after the issuance of the instant notice by the Commission, file pursuant to rule 214 of the Commission's Procedural Rules (18 CFR 385.214) a motion to intervene or notice of intervention and pursuant to § 157.205 of the Regulations under the Natural Gas Act (18 CFR 157.205) a protest to the request. If no protest is filed within the time allowed therefore, the proposed activity shall be deemed to be authorized effective the day after the time allowed for filing a protest. If a protest is filed and not withdrawn within 30 days after the time allowed for filing a protest, the instant request shall be treated as an application for authorization pursuant to section 7 of the Natural Gas Act.
Standard Paragraph
J. Any person desiring to be heard or make any protest with reference to said filings should on or before the comment date file with the Federal Energy Regulatory Commission, 825 North Capitol Street NE., Washington, DC 20426 a motion to intervene or a protest in accordance with the requirements of the Commission's Rules of Practice and Procedure (18 CFR 385.211, .214). All protests filed with the Commission will be considered by it in determining the appropriate action to be taken but will not serve to make the protestants parties to the proceeding. Any person wishing to become a party to any proceeding herein must file a petition to intervene in accordance with the Commission's rules.
Under the procedure herein provided for, unless otherwise advised, it will be unnecessary for the applicant to appear or be represented at the hearing.
Lois D. Cashell,
Secretary.
[FR Doc. 92–4155 Filed 2–21–92; 8:45 am]
BILLING CODE 6717–01–M
[Docket No. CP92–340–000]
Chattanooga Gas Co.; Motion Requesting Waiver
February 18, 1992.
Take notice that on February 7, 1992, Chattanooga Gas Company (Chattanooga), 811 Broad Street, Chattanooga, Tennessee 37402, filed a motion with the Commission requesting a waiver of the Commission's reporting and accounting requirements and all other rules and regulations under the Natural Gas Act (NGA) and Natural Gas Policy Act of 1978 (NGPA) that may be applicable to Chattanooga as a natural...
gas company all as more fully set forth in the motion which is open to public inspection.
Chattanooga states that it is a local distribution company engaged in the purchase, distribution, and retail sale of natural gas in Tennessee pursuant to authorization granted by the Tennessee Public Service Commission. The Commission authorized Chattanooga on November 21, 1990, to provide East Tennessee Natural Gas Company (East Tennessee), its only current jurisdictional customer, with liquefied natural gas (LNG) service.\(^1\) Chattanooga is authorized to provide East Tennessee with firm LNG sales of up to 200,000 Mcf annually and maximum daily withdrawal quantities of up to 13,000 Mcf. If East Tennessee were to purchase the maximum firm volumes under the certificated service, such revenues would comprise only 1.3 percent of Chattanooga's total revenue. Chattanooga states that its compliance with such reporting and accounting requirements is unnecessary since Chattanooga is essentially a non-jurisdictional entity with *de minimis* jurisdictional revenues.
Any person desiring to be heard or to make any protest with reference to said motion requesting waiver should on or before March 10, 1992, file with the Federal Energy Regulatory Commission, Washington, DC 20426, a motion to intervene or a protest in accordance with the requirements of the Commission's Rules of Practice and Procedure (18 CFR 384.214 or 385.211) and the Regulations under the NGA (18 CFR 157.10). All protests filed with the Commission will be considered by it in determining the appropriate action to be taken but will not serve to make the protestants parties to the proceeding. Any person wishing to become a party to a proceeding or to participate as a party in any hearing therein must file a motion to intervene in accordance with the Commission's Rules.
Lois D. Cashell,
Secretary.
[FR Doc. 92–4160 Filed 2–21–92; 8:45 am]
BILLING CODE 6717–01–M
[FR Doc. 92–4161 Filed 2–21–92; 8:45 am]
BILLING CODE 6717–01–M
[DOCKET NO. RP92–113–000]
El Paso Natural Gas Co.; Tariff Filing
February 18, 1992.
Take notice that on February 13, 1992, El Paso Natural Gas Company ("El Paso") tendered for filing, pursuant to Part 154 of the Federal Energy Regulatory Commission's ("Commission") Regulations Under the Natural Gas Act, Second Revised Sheet No. 117 contained in its FERC Gas Tariff, First Revised Volume No. 1–A. El Paso states that the filing reflects a reduction in the billing determinant for Westar Transmission Company ("Westar") and the addition of a billing determinant for West Texas Gas, Inc. ("West Texas Gas") under Rate Schedule T–3. El Paso requests that the tariff sheet be accepted for filing and permitted to become effective January 1, 1992.
El Paso states that by orders issued March 20, 1991 and August 14, 1991 at Docket No. RP88–44–000, *et al.*, the Commission approved El Paso's Stipulation and Agreement ("Settlement") which became effective August 31, 1991 and provides, *inter alia*, that all sales customers must convert firm sales entitlements to firm transportation pursuant to Rate Schedules T–3 or FTS–S, as applicable, contained in El Paso's Volume No. 1–A Tariff. All conversions were to be completed no later than January 1, 1992. El Paso states that, accordingly, Westar and West Texas Gas each entered into a Transportation Service Agreement ("TSA") with El Paso dated respectively, December 31, 1991 and October 22, 1991, to be effective January 1, 1992, under Rate Schedule T–3 contained El Paso's Volume No. 1–A Tariff. El Paso states that neither party elected to convert 100% of their firm sales entitlements to firm transportation. Rather, each elected a Transportation Contract Demand.
El Paso states that in its Section 4 rate filing at Docket No. RP91–188–000, filed July 1, 1991, El Paso included a billing determinant for Westar which was based on the conversion to firm transportation of Westar's full requirements under Rate Schedule T–3. El Paso states that in subsequent negotiation of its TSA, Westar agreed to convert its firm sales entitlements to firm transportation under Rate Schedule T–3 with a Transportation Contract Demand of 30,000 Mcf per day instead of full requirements. Accordingly, El Paso tendered Second Revised Sheet No. 117 to reflect the reduction in Westar's billing determinant to 30,000 dth per day, which is the dekatherm equivalent of 30,000 Mcf per day.
In addition, El Paso states that tendered Second Revised Sheet No. 117 reflects the addition of a billing determinant for West Texas Gas. West Texas Gas elected to convert its firm sales entitlements to firm transportation under Rate Schedule T–3 with a Transportation Contract Demand of 1,000 Mcf per day rather than full requirements. Accordingly, Second Revised Sheet No. 117 also reflects the addition of a billing determinant of 1,030 dth per day (dekatherm equivalent of 1,000 Mcf per day) for West Texas Gas pursuant to such election.
El Paso requests that, pursuant to Section 154.51 of the Commission's Regulations, waiver of the notice requirements of Section 154.22 of the Commission's Regulations be granted so as to permit the tendered tariff sheet to become effective January 1, 1992, the effective date of Westar's and West Texas Gas' TSA and the date the applicable reservation charges under Rate Schedule T–3 commenced.
El Paso states that copies of the filing were served upon all interstate pipeline system transportation customers of El Paso and interested state regulatory commissions.
Any person desiring to be heard or to protest said filing should file a motion to
intervene or protest with the Federal Energy Regulatory Commission, 825 North Capitol Street, NE., Washington, DC 20426, in accordance with Sections 385.214 and 385.211 of the Commission's Rules and Regulations. All such motions or protests should be filed on or before February 25, 1992. Protests will be considered by the Commission in determining the appropriate action to be taken, but will not serve to make protestants parties to the proceedings. Any person wishing to become a party must file a motion to intervene. Copies of this filing are on file with the Commission and are available for public inspection in the Public Reference Room.
Lois D. Cashell,
Secretary.
[FR Doc. 92–4163 Filed 2–21–92; 8:45 am]
BILLING CODE 6717–01–M
[Docket No. TA92–1–53–001]
K N Energy, Inc.; Proposed Changes in FERC Gas Tariff
February 18, 1992.
Take notice that K N Energy, Inc. ("K N") on February 13, 1992 tendered for filing proposed changes in its FERC Gas Tariff to correct a typographic error contained on one of the tariff sheets filed on January 30, 1992, with its regularly scheduled quarterly PGA.
K N states that copies of the filing were served upon K N's jurisdictional sales customers and interested public bodies.
Any person desiring to protest said filing should file a protest with the Federal Energy Regulatory Commission, 825 North Capitol Street, NE., Washington, DC 20426, in accordance with Rule 211 of the Commission's Rules of Practice and Procedures, 18 CFR 385.211. All such protests should be filed on or before February 25, 1992. Protests will be considered by the Commission in determining the appropriate action to be taken, but will not serve to make protestants parties to the proceeding. Copies of this filing are on file with the Commission and are available for public inspection.
Lois D. Cashell,
Secretary.
[FR Doc. 92–4158 Filed 2–21–92; 8:45 am]
BILLING CODE 6717–01–M
[Docket No. RP91–189–003]
Midwestern Gas Transmission Co; Notice to Move Rates into Effect
February 18, 1992.
Take notice that on January 31, 1992, Midwestern Gas Transmission Company (Midwestern) seeks to supplement its December 31, 1991 Motion to Move Rates into Effect in the above referenced proceeding.
Midwestern states that in its December 31 motion, Midwestern did not specifically reference to the following tariff sheets:
Third Revised Sheet No. 1
Twenty-third Revised Sheet No. 6
Third Revised Sheet No. 10
Third Revised Sheet No. 11
Third Revised Sheet No. 20
Second Revised Sheet Nos. 23 through 29
Third Revised Sheet No. 30
Fifth Revised Sheet No. 45
Fifth Revised Sheet No. 54
Second Revised Sheet Nos. 94 through 109
Midwestern hereby supplements its December 31 motion to reference the tariff sheets and to thereby move the tariff sheets into effect.
Midwestern states that it is also filing Third Revised Tariff Sheet Nos. 69 through 74. Midwestern also states that it has amended Third Revised Sheet No. 70 to remove the paragraph pertaining to the flowthrough of upstream supplier GIC charges.
Midwestern states that copies of the filing have been served upon each person designated on the official service list.
Any person desiring to protest said filing should file a protest with the Federal Energy Regulatory Commission, 825 North Capitol Street, NE., Washington, DC 20426, in accordance with Rule 211 of the Commission's Rules of Practice and Procedure 18 CFR 385.211. All such protests should be filed on or before February 25, 1992. Protests will be considered by the Commission in determining the appropriate action to be taken, but will not serve to make protestants parties to the proceeding. Copies of this filing are on file with the Commission and are available for public inspection.
Lois D. Cashell,
Secretary.
[FR Doc. 92–4167 Filed 2–21–92; 8:45 am]
BILLING CODE 6717–01–M
[Docket Nos. RP92–1–000 and CP92–71–000]
Northern Natural Gas Company; Informal Settlement Conference
February 18, 1992.
Take notice that an informal settlement conference will be convened in the above-captioned proceeding at 9 a.m. on February 28, 1992, at the offices of the Federal Energy Regulatory Commission, 810 First Street, NE., Washington, DC, for the purpose of exploring the possible settlement of the above-referenced dockets.
Any party, as defined by 18 CFR 385.102(c), or any participant as defined in 18 CFR 385.102(b), is invited to attend. Persons wishing to become a party must move to intervene and receive intervenor status pursuant to the Commission's regulations (18 CFR 385.214).
For additional information please contact Michael D. Cotleur, (202) 208–1076, or John J. Keating, (202) 208–0762.
Lois D. Cashell,
Secretary.
[FR Doc. 92–4167 Filed 2–21–92; 8:45 am]
BILLING CODE 6717–01–M
[Docket No. CP92–328–000]
Panhandle Eastern Pipe Line Co.; Request for Clarification or Abbreviated Application for Abandonment
February 18, 1992.
Take notice that on February 4, 1992, Panhandle Eastern Pipe Line Company (Panhandle) P.O. Box 1642, Houston, Texas, 77251–1642, filed in Docket No. CP92–328–000 a request for clarification of the certificate authority issued to Panhandle in Northwest Alaskan Pipeline Co., et al., 11 FERC ¶ 61,302 (1990), or in the alternative, an application pursuant to section 7(b) of the Natural Gas Act (NGA), as amended, and §§ 157.7 and 157.18 of the Federal Energy Regulatory Commission's (Commission) Regulations (18 CFR 157.7, 157.18 (1991)), for an order permitting and approving abandonment of any service obligation found to exist under the certificate issued in that docket to Northern Natural Gas Company (Northern Natural), all as more fully set forth in the application which is on file with the Commission and open for public inspection.
Panhandle requests that the Commission clarify that it has no service obligation under the certificate issued in Docket No. CP79–403–000 for which abandonment authorized is
required to effectuate the termination of its June 26, 1979 "Transportation Agreement" with Northern Natural. In the alternative, Panhandle requests that the Commission permit and approve its abbreviated application for abandonment of any service obligation found to exist to Northern Natural. Panhandle states that no customer of Panhandle would have its service terminated or adversely affected as a result of Panhandle's abandonment of such a service obligation.
Any request person desiring to be heard or to protest to said filing should file a motion to intervene with the Federal Energy Regulatory Commission, 825 North Capitol Street NE., Washington, DC 20426, in accordance with §§ 385.214 and 385.211 of the Commission's Rules and Regulations. All such motions or protests should be filed on or before March 10, 1992. Protests will be considered by the Commission in determining the appropriate action to be taken, but will not serve to make protestants parties to the proceeding.
Any person wishing to become a party must file a motion to intervene. Copies of this filing are on file with the Commission and are available for public inspection in the Public Reference Room.
Lois D. Cashell,
Secretary.
[FR Doc. 92–4164 Filed 2–21–92; 8:45 am]
BILLING CODE 6717–01–M
[Docket Nos. TA92–2–18–002 and TF92–4–18–001]
Texas Gas Transmission Corp.; Proposed Changes in FERC Gas Tariff
February 18, 1992.
Take notice that Texas Gas Transmission Corporation (Texas Gas), on February 10, 1992, tendered for filing the following revised tariff sheets to its FERC Gas Tariff, Original Volume No. 1:
TA92–2–18–001
Substitute Forty-ninth Revised Sheet No. 10
Substitute Forty-ninth Revised Sheet No. 10A
Substitute Thirtieth Revised Sheet No. 11
Substitute Twentieth Revised Sheet No. 11A
Substitute Twentieth Revised Sheet No. 11B
TF92–4–18–001
Substitute Fifteenth Revised Sheet No. 10
Substitute Fifteenth Revised Sheet No. 10A
Substitute Thirty-first Revised Sheet No. 11
Substitute Twenty-first Revised Sheet No. 11A
Substitute Twenty-first Revised Sheet No. 11B
TA92–2–18–001:
Texas Gas states that these tariff sheets are being filed to comply with the Commission's "Order Accepting and Suspending Tariff Sheets Subject to Refund and Conditions" issued January 31, 1992, in Docket No. TA92–2–18–000, filed December 10, 1991.
The proposed tariff sheets reflect a commodity rate decrease of ($.2972) per MMBtu from those rates reflected in the Annual PGA filing of December 10, 1991, and a commodity rate decrease of ($.1684) per MMBtu from the rates reflected in the last scheduled Quarterly PGA in Docket No. TQ92–1–18. No changes are being proposed for the demand rates or SGN standby charges.
Texas Gas states that these tariff sheets are being filed to reflect the revised current adjustment and pagination due to the compliance filing in TA92–2–18–001. The effective rates reflected in the proposed sheets are the same as those accepted by Commission Letter Order dated January 31, 1992, in Texas Gas' interim PGA filing of January 28, 1992 (Docket No. TF92–4–18–000).
Texas Gas states that copies of the filing were served upon Texas Gas' jurisdictional sales customers and interested state commissions.
Any person desiring to protest said filing should file a protest with the Federal Energy Regulatory Commission, 825 North Capitol Street NE., Washington, DC 20426, in accordance with Rule 211 of the Commission's Rules of Practice and Procedures, 18 CFR 385.211. All such protests should be filed on or before February 25, 1992. Protests will be considered by the Commission in determining the appropriate action to be taken, but will not serve to make protestants parties to the proceeding. Any person wishing to become a party must file a motion to intervene. Copies of this filing are on file with the Commission and are available for public inspection.
Lois D. Cashell,
Secretary.
[FR Doc. 92–4157 Filed 2–21–92; 8:45 am]
BILLING CODE 6717–01–M
[Docket No. GT92–14–000]
Trunkline Gas Co.; Proposed Changes in FERC Gas Tariff
February 18, 1992.
Take notice that Trunkline Gas Company (Trunkline) on January 28, 1992, tendered for filing the following revised tariff sheet to its FERC Gas Tariff, Original Volume No. 1:
Twenty-Second Revised Sheet No. 35
Trunkline proposes that this sheet become effective September 1, 1991.
Trunkline states that this proposed tariff sheet is being filed pursuant to section 154 of the Commission's Regulations and in compliance with § 284.10(d)(1) of the Commission's Regulations which granted permission and approval of the partial abandonment of natural gas sales service to Northern Indiana Public Service Company (NIPSCO).
This revised tariff sheet reflects changes pursuant to a new Service Agreement dated September 1, 1991 with NIPSCO, a jurisdictional sales customer served by Trunkline pursuant to Rate Schedule P-2 of its FERC Gas Tariff, Original Volume No. 1. This new Service Agreement reflects NIPSCO's election pursuant to § 284.10(c) of the Commission's Regulations to reduce its sales contract demand volumes.
Trunkline states that a copy of this letter and enclosures were served on all affected sales customers subject to the tariff sheet and applicable state regulatory commissions.
Any person desiring to be heard or to protest said filing should file a motion to intervene or protest with the Federal Energy Regulatory Commission, 825 North Capitol Street NE., Washington, DC 20426, in accordance with Sections 385.211 and 385.214 of the Commission's Rules and Regulations. All such motions or protests should be filed on or before February 25 1992. Protests will be considered by the Commission in determining the appropriate action to be taken, but will not serve to make protestants parties to the proceeding. Any person wishing to become a party must file a motion to intervene. Copies of this filing are on file with the Commission and are available for public inspection in the Public Reference Room.
Lois D. Cashell,
Secretary.
[FR Doc. 92–4162 Filed 2–21–92; 8:45 am]
BILLING CODE 6717–01–M
[Docket No. RP92–114–000]
Williams Natural Gas Co.; Proposed Changes in FERC Gas Tariff
February 18, 1992.
Take notice that Williams Natural Gas Company (WNG) on February 13, 1992 tendered for filing the following tariff sheets to its FERC Gas Tariff, First Revised Volume No. 1:
Third Revised Sheet Nos. 119, 120, and 246
First Revised Sheet No. 247
The proposed effective date of these tariff sheets is March 15, 1992.
WNG states that Third Revised Sheet Nos. 119 and 120 are being filed to clarify that both the Reservation Charge
and the Overrun Charge under Rate Schedule FTS are applicable within each zone. This is to prevent a shipper designating its delivery points for purposes of the Reservation Charge to be in Zone 1, but requesting that most deliveries under the contract be made in Zone 2 on an authorized overrun basis.
WNG states that Third Revised Sheet No. 246 is being filed to clarify that authorized overrun service under both Rate Schedules FTS and ITS will be treated equally, especially for curtailment purposes, with service under Rate Schedule ITS in all respects. First Revised Sheet No. 247 is included for pagination purposes only.
WNG states that copies of its filing were served on all jurisdictional purchasers and interested state commissions.
Any person desiring to be heard or to protest said filing should file a motion to intervene or a protest with the Federal Energy Regulatory Commission, 825 North Capitol Street, NE., Washington, DC 20426, in accordance with §§ 385.214 and 385.211 of the Commission's Rules and Regulations. All such motions or protests should be filed on or before February 25, 1992. Protests will be considered by the Commission in determining the appropriate action to be taken, but will not serve to make protestants parties to the proceedings. Any person wishing to become a party must file a motion to intervene. Copies of this filing are on file with the Commission and are available for public inspection.
Lois D. Cashell,
Secretary.
[FR Doc. 91–4159 Filed 2–21–91; 8:45 am]
BILLING CODE 6717–01–M
Office of Fossil Energy
[FE Docket No. 92–06–NG]
Sergeant Oil & Gas Co., Inc.,
Application for Blanket Authorization To Export Natural Gas
AGENCY: Department of Energy, Office of Fossil Energy.
ACTION: Notice of application for blanket authorization to export natural gas to Mexico.
SUMMARY: The Office of Fossil Energy (FE) of the Department of Energy (DOE) gives notice of receipt on January 27, 1992, of an application filed by Sergeant Oil & Gas Co., Inc. (SOG), requesting blanket authorization to export to Mexico up to 40,000 Mcf per day of natural gas over a two-year term beginning on the date of first delivery. Export sales of natural gas would not exceed 30 Bcf during the two-year period. The proposed exports would take place at any point on the international border where existing pipeline facilities are located.
The application is filed under section 3 of the Natural Gas Act and DOE Delegation Order Nos. 0204–111 and 0204–127. Protests, motions to intervene, notices of intervention, and written comments are invited.
DATES: Protests, motions to intervene or notices of intervention, as applicable, requests for additional procedures and written comments are to be filed at the address listed below no later than 4:30 p.m. Eastern time, March 25, 1992.
ADDRESSES: Office of Fuels Programs, Fossil Energy, U.S. Department of Energy, Forrestal Building, room 3F–056, FE–50, 1000 Independence Avenue, SW., Washington, DC 20585.
FOR FURTHER INFORMATION CONTACT: Peter Lagiovane, Office of Fuels Programs, Forrestal Building, room 3F–056, 1000 Independence Avenue, SW., Washington, DC 20585, (202) 586–8116.
Diane Stubbs, Office of Assistant General Counsel for Fossil Energy, U.S. Department of Energy, Forrestal Building, room 6E–042, 1000 Independence Avenue, SW., Washington, DC 20585, (202) 586–8667.
SUPPLEMENTARY INFORMATION: SOG is a Texas corporation with its principal place of business in Houston, Texas. It is a marketer of natural gas and liquid petroleum products operating primarily in the Gulf Coast area of the United States. SOG states that the gas would be exported, either for SOG's own account or on behalf of others, to Pemex for local distribution by Pemex to its customers, or to customers, including end-users and electric utilities, under direct sales. The specific details of each export transaction would be filed by SOG in conformity with DOE's quarterly reporting requirement. SOG anticipates all sales would result from arms-length negotiations and the prices would be determined by market conditions.
This export application will be reviewed under section 3 of the NGA and the authority contained in DOE Delegation Order Nos. 0204–111 and 0204–127. In deciding whether the proposed export of natural gas is in the public interest, domestic need for the gas will be considered, and any other issue determined to be appropriate, including whether the arrangement is consistent with the DOE policy of promoting competition in the natural gas marketplace by allowing commercial parties to freely negotiate their own trade arrangements. Parties, especially those that may oppose this application, should comment on these matters as they relate to the requested export authority.
SOG states that due to the current gas supply surplus in the U.S., domestic producers and the states where the domestic gas is produced would benefit from the sales resulting from this export authorization. Further, SOG contends that the proposed exports would lower the overall U.S. trade deficit and enhance the integration of U.S.–Mexico gas markets. SOG asserts there is no current regional or national need for the domestic gas that would be exported under the proposed arrangement, and, if the availability of gas in the U.S. were to become a problem, the exported gas could be reallocated within a reasonable time to domestic needs because of the short-term nature of the authorization. Parties opposing the arrangement bear the burden of overcoming these assertions.
All parties should be aware that if DOE approves this requested blanket export authorization, it may designate a total authorized volume of 30 Bcf for the two-year term in order to maximize the applicant's flexibility of operation.
NEPA Compliance. The National Environmental Policy Act (NEPA), 42 U.S.C. 4321 et seq., requires DOE to give appropriate consideration to the environmental effects of its proposed actions. No final decision will be issued in this proceeding until DOE has met its NEPA responsibilities.
Public Comment Procedures. In response to this notice, any person may file a protest, motion to intervene or notice of intervention, as applicable, and written comments. Any person wishing to become a party to the proceeding and to have their written comments considered as the basis for any decision of the application must, however, file a motion to intervene or notice of intervention, as applicable. The filing of a protest with respect to this application will not serve to make the protestant a party to the proceeding, although protests and comments received from persons who are not parties will be considered in determining the appropriate action to be taken on the application. All protests, motions to intervene, notices of intervention, and written comments must meet the requirements that are specified by the regulations in 10 CFR part 590. Protests, motions to intervene, notices of intervention, requests for additional procedures, and written comments should be filed with the Office of Fuels Programs at the address listed above.
It is intended that a decisional record on the application will be developed through responses to this notice by parties, including the parties' written comments and replies thereto. Additional procedures will be used as necessary to achieve a complete understanding of the facts and issues. A party seeking intervention may request that additional procedures be provided, such as additional written comments, an oral presentation, a conference, or trial-type hearing. Any request to file additional written comments should explain why they are necessary. Any request for an oral presentation should identify the substantial question of fact, law, or policy at issue, show that it is material and relevant to a decision in the proceeding, and demonstrate why an oral presentation is needed. Any request for a conference should demonstrate why the conference would materially advance the proceeding. Any request for a trial-type hearing must show that there are factual issues genuinely in dispute that are relevant and material to a decision and that a trial-type hearing is necessary for a full and true disclosure of the facts.
If an additional procedure is scheduled, notice will be provided to all parties. If no party requests additional procedures, a final opinion and order may be issued based on the official record, including the application and responses filed by parties pursuant to this notice, in accordance with 10 CFR 590.316.
A copy of SOG's application is available for inspection and copying in the Office of Fuels Programs Docket Room, 3F-058, at the above address. The docket room is open between the hours of 8 a.m. and 4:30 p.m., Monday through Friday, except Federal holidays.
Charles F. Vacek,
Deputy Assistant Secretary for Fuels Programs, Office of Fossil Energy.
[FEDERAL MARITIME COMMISSION]
Security for the Protection of the Public Indemnification of Passengers for Nonperformance of Transportation; Issuance of Certificate (Performance)
Notice is hereby given that the following have been issued a Certificate of Financial Responsibility for Indemnification of Passengers for Nonperformance of Transportation pursuant to the provisions of section 3, Public Law 89-777 (46 U.S.C. 817(e)) and the Federal Maritime Commission's implementing regulations at 46 CFR part 540, as amended: Starlite Cruises, Inc., 1007 North American Way, Miami, Florida 33132.
Vessel: RAINBOW.
Dated: February 18, 1992.
Joseph C. Polking,
Secretary.
[FEDERAL RESERVE SYSTEM]
Federal Open Market Committee; Domestic Policy Directive of December 17, 1991
In accordance with § 271.5 of its rules regarding availability of information, there is set forth below the domestic policy directive issued by the Federal Open Market Committee at its meeting held on December 17, 1991.¹ The Directive was issued to the Federal Reserve Bank of New York as follows:
The information reviewed at this meeting continues to portray a sluggish economy and a depressed state of business and consumer confidence. Total nonfarm payroll employment fell sharply in November; however, the average workweek in the private nonfarm sector edged up and the civilian unemployment rate remained at 6.8 percent. Industrial production fell in November, partly reflecting a sizable drop in motor vehicle assemblies. Consumer spending has been soft on balance in recent months. Real outlays for business equipment appear to be rising slowly, and nonresidential construction has continued to decline. Housing starts were appreciably higher on average in October and November than in the third quarter. The nominal U.S. merchandise trade deficit widened slightly further in September; the deficit in the third quarter was substantially larger than in the second quarter. Wage and price increases have continued to trend downward.
Interest rates have declined appreciably since the Committee meeting on November 5. The Board of Governors approved a reduction in the discount rate from 5 to 4-1/2 percent on November 6. In foreign exchange markets, the trade-weighted value of the dollar in terms of the other G-10 currencies declined further over the intermeeting period; the dollar depreciated primarily against the mark and other European currencies.
Expansion in M2 and M3 edged up in November from a slow pace in October; the slightly faster growth reflected a strengthening in the most liquid components of the aggregates. For the year through November, expansion of both M2 and M3 is estimated to have been at the lower ends of the Committee's ranges.
¹Copies of the Record of policy actions of the Committee for the meeting of December 17, 1991, are available upon request to The Board of Governors of the Federal Reserve System, Washington, DC 20551.
The Federal Open Market Committee seeks monetary and financial conditions that will foster price stability and promote sustainable growth in output. In furtherance of these objectives, the Committee at its meeting in July reaffirmed the ranges it had established in February for growth of M2 and M3 of 2-1/2 to 6-1/2 percent and 1 to 5 percent, respectively, measured from the fourth quarter of 1990 to the fourth quarter of 1991. The monitoring range for growth of total domestic nonfinancial debt also was maintained at 4-1/2 to 8-1/2 percent for the year. For 1992, on a tentative basis, the Committee agreed in July to use the same ranges as in 1991 for growth in each of the monetary aggregates and debt, measured from the fourth quarter of 1991 to the fourth quarter of 1992. With regard to M3, the Committee anticipated that the ongoing restructuring of thrift depository institutions would continue to depress the growth of this aggregate relative to spending and total credit. The behavior of the monetary aggregates will continue to be evaluated in the light of progress toward price level stability, movements in their velocities, and developments in the economy and financial markets.
In the implementation of policy for the immediate future, the Committee seeks to maintain the existing degree of pressure on reserve positions. In the context of the Committee's long-run objectives for price stability and sustainable economic growth, and giving careful consideration to economic, financial, and monetary developments, slightly greater reserve restraint might or somewhat lesser reserve restraint would be acceptable in the intermeeting period. The contemplated reserve conditions are expected to be consistent with growth of M2 and M3 over the period from November through March at annual rates of about 3 and 1-1/2 percent, respectively.
By order of the Federal Open Market Committee, February 14, 1992.
Normand Bernard,
Deputy Secretary, Federal Open Market Committee.
[FEDERAL BANCORP, INC., ET AL.; APPLICATIONS TO ENGAGE DE NOVO IN PERMISSIBLE NONBANKING ACTIVITIES]
The companies listed in this notice have filed an application under § 225.23(a)(1) of the Board's Regulation Y (12 CFR 225.23(a)(1)) for the Board's approval under section 4(c)(8) of the Bank Holding Company Act (12 U.S.C. 1843(c)(8)) and § 225.21(a) of Regulation Y (12 CFR 225.21(a)) to commence or to engage de novo, either directly or through a subsidiary, in a nonbanking activity that is listed in § 225.25 of Regulation Y as closely related to banking and permissible for bank holding companies. Unless otherwise
noted, such activities will be conducted throughout the United States.
Each application is available for immediate inspection at the Federal Reserve Bank indicated. Once the application has been accepted for processing, it will also be available for inspection at the offices of the Board of Governors. Interested persons may express their views in writing on the question whether consummation of the proposal can "reasonably be expected to produce benefits to the public, such as greater convenience, increased competition, or gains in efficiency, that outweigh possible adverse effects, such as undue concentration of resources, decreased or unfair competition, conflicts of interests, or unsound banking practices." Any request for a hearing on this question must be accompanied by a statement of the reasons a written presentation would not suffice in lieu of a hearing, identifying specifically any questions of fact that are in dispute, summarizing the evidence that would be presented at a hearing, and indicating how the party commenting would be aggrieved by approval of the proposal.
Unless otherwise noted, comments regarding the applications must be received at the Reserve Bank indicated or the offices of the Board of Governors not later than March 20, 1992.
A. Federal Reserve Bank of Atlanta (Robert E. Heck, Vice President) 104 Marietta Street, NW., Atlanta, Georgia 30303:
1. FirstBancorp, Inc., Marathon, Florida; to engage de novo in extending first mortgage loans to officers and employees of its subsidiary bank, First National Bank of the Florida Keys, Marathon, Florida, pursuant to § 225.25(b)(1) of the Board's Regulation Y. These activities will be conducted throughout Monroe County and Dade County, Florida.
B. Federal Reserve Bank of San Francisco (Kenneth R. Binning, Director, Bank Holding Company) 101 Market Street, San Francisco, California 94105:
1. Landmark Bancorp, La Habra, California; to engage de novo through a wholly owned subsidiary, in the making and servicing of loans pursuant to § 225.25(b)(1) of the Board's Regulation Y.
Board of Governors of the Federal Reserve System, February 18, 1992.
Jennifer J. Johnson,
Associate Secretary of the Board.
[FR Doc. 92–4129 Filed 2–21–92; 8:45 am]
BILLING CODE 8210–01–F
Montfort Bancorporation, Inc.; Acquisition of Company Engaged in Permissible Nonbanking Activities
The organization listed in this notice has applied under § 225.25(a)(2) or (f) of the Board's Regulation Y (12 CFR 225.25(a)(2) or (f)) for the Board's approval under section 4(c)(8) of the Bank Holding Company Act (12 U.S.C. 1843(c)(8)) and § 225.21(a) of Regulation Y (12 CFR 225.21(a)) to acquire or control voting securities or assets of a company engaged in a nonbanking activity that is listed in § 225.25 of Regulation Y as closely related to banking and permissible for bank holding companies. Unless otherwise noted, such activities will be conducted throughout the United States.
The application is available for immediate inspection at the Federal Reserve Bank indicated. Once the application has been accepted for processing, it will also be available for inspection at the offices of the Board of Governors. Interested persons may express their views in writing on the question whether consummation of the proposal can "reasonably be expected to produce benefits to the public, such as greater convenience, increased competition, or gains in efficiency, that outweigh possible adverse effects, such as undue concentration of resources, decreased or unfair competition, conflicts of interests, or unsound banking practices." Any request for a hearing on this question must be accompanied by a statement of the reasons a written presentation would not suffice in lieu of a hearing, identifying specifically any questions of fact that are in dispute, summarizing the evidence that would be presented at a hearing, and indicating how the party commenting would be aggrieved by approval of the proposal.
Comments regarding the application must be received at the Reserve Bank indicated or the offices of the Board of Governors not later than March 20, 1992.
A. Federal Reserve Bank of Chicago (David S. Epstein, Vice President) 230 South LaSalle Street, Chicago, Illinois 60690:
1. Montfort Bancorporation, Inc., Platteville, Wisconsin, and its wholly owned subsidiary, Clare Bancorporation, Inc., Platteville, Wisconsin, to acquire First Federal Savings and Loan Association of Platteville, Platteville, Wisconsin, and thereby engage in operating a savings association pursuant to § 225.25(b)(9) of the Board's Regulation Y.
Board of Governors of the Federal Reserve System, February 18, 1992.
Jennifer J. Johnson,
Associate Secretary of the Board.
[FR Doc. 92–4130 Filed 2–21–92; 8:45 am]
BILLING CODE 8210–01–F
FEDERAL TRADE COMMISSION
[Dkt. C–3368]
Scali, McCabe, Sloves, Inc.; Prohibited Trade Practices and Affirmative Corrective Actions
AGENCY: Federal Trade Commission.
ACTION: Consent Order.
SUMMARY: In settlement of alleged violations of federal law prohibiting unfair acts and practices and unfair methods of competition, this consent order requires, among other things, the New York advertising agency of Volvo North America Corporation to pay $150,000 to the U.S. Treasury as disgorgement, and prohibits respondent from misrepresenting the strength, structural integrity, or crashworthiness of any automobile or auto part, or the safety of a vehicle occupant in a collision.
DATES: Complaint and Order issued January 23, 1992.¹
FOR FURTHER INFORMATION CONTACT:
Joel Winston or Lisa Hellerman, FTC/S–4002, Washington, DC 20580. (202) 326–3153 or 326–3139.
SUPPLEMENTARY INFORMATION: On Wednesday, September 4, 1991, there was published in the Federal Register, 56 FR 43780, a proposed consent agreement with analysis In the Matter of Scali, McCabe, Sloves, Inc., for the purpose of soliciting public comment. Interested parties were given sixty (60) days in which to submit comments, suggestions or objections regarding the proposed form of the order.
A comment was filed and considered by the Commission. The Commission has ordered the issuance of the complaint in the form contemplated by the agreement, made its jurisdictional findings and entered an order to cease and desist, as set forth in the proposed consent agreement, in disposition of this proceeding.
¹ Copies of the Complaint and the Decision and Order are available from the Commission's Public Reference Branch, H–130, 6th Street & Pennsylvania Avenue, NW., Washington, DC 20580.
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Disease Control
Meeting
The National Institute for Occupational Safety and Health (NIOSH) of the Centers for Disease Control (CDC) announces the following meeting.
Name: Work Schedule Factors Related to Upper Extremity Fatigue.
Time and Date: 12:30–4:30 p.m., March 25, 1992.
Place: Robert A. Taft Laboratories, Auditorium, NIOSH, CDC, 4676 Columbia Parkway, Cincinnati, Ohio 45228.
Status: Open to the public, limited only by the space available.
Purpose: To conduct an open meeting for the review of a research protocol to study the fatiguing effects of 8- and 12-hour work shifts on worker capacity to perform manual work involving the upper extremities.
Contact Person for Additional Information: Roger R. Rosa, Ph.D., NIOSH, CDC, 4676 Columbia Parkway, Mailstop C–24, Cincinnati, Ohio 45228, telephone 513/533–8291 or FTS 684–8291.
Dated: February 18, 1992.
Robert L. Foster,
Assistant Director for Special Projects, Office of Program Support, Centers for Disease Control.
[FR Doc. 92–4120 Filed 2–21–92; 8:45 am]
BILLING CODE 4160–19–M
Food and Drug Administration
[Docket No. 92M–0054]
Teletronics Pacing Systems, Inc.; Premarket Approval of META™ DDDR Pacing System
AGENCY: Food and Drug Administration, HHS.
ACTION: Notice.
SUMMARY: The Food and Drug Administration (FDA) is announcing its approval of the application by Teletronics Pacing Systems, Inc., Englewood, CO, for premarket approval, under section 515 of the Federal Food, Drug, and Cosmetic Act (the act), of the META™ DDDR Pacing System, including Model 1250H Pulse Generator, Models 5600D, 5603, and 9600 Programmers with version V4.26, V5.43UE, and V3.66UE software, Model 5702 Printer, Model 5302 External Programming Coil, Model 5500 Interface Module, and Model 030–570 JPG Test Cable Adaptor. The dual chamber pacing modes of the META™ DDDR Model 1250H Pulse Generator (hereinafter referred to as the META™ DDDR) is indicated where maintenance of atrio-ventricular synchrony is required. This requirement is associated with the generally accepted indications for permanent cardiac pacing which include, but are not limited to: (1) Sick sinus node syndrome; (2) symptomatic bradycardia; (3) symptomatic A–V block; (4) recurrent Stokes–Adams syndrome; (5) carotid sinus syncope; and (6) suppression of tachycardia. The rate responsive pacing modes of the META™ DDDR are indicated for those patients who can benefit from an increase in pacing rate, atrial and/or ventricular, in response to a physiologic need for increased cardiac output. The dual chamber rate responsive pacing modes are of specific benefit to patients with chronotropic incompetence. Chronotropic incompetence is the inability to achieve an intrinsic maximal heart rate greater than 60 percent of the patient’s age predicted maximal heart rate (i.e., 220 – age). During the clinical study of the META™ DDDR a subset of chronotropically incompetent patients were evaluated and demonstrated that the minute ventilation rate responsive modes eliminate chronotropic
incompetence in a physiologic manner as measured by minute ventilation and oxygen uptake, in that the DDDR mode provides statistically significant improvements in oxygen uptake, work rate, and exercise time at the anaerobic threshold as compared to the DDDR mode. Patients with intact sinus response may benefit from the ability of the device to overcome limitations of dual chamber upper rate behavior and/or to prevent ventricular pacing in response to nonphysiologic atrial tachycardias.
On June 3, 1991, the Circulatory System Devices Panel, an FDA advisory committee, reviewed and recommended approval of the application. On January 30, 1982, CDRH approved the application by a letter to the applicant from the Director of the Office of Device Evaluation, CDRH.
A summary of the safety and effectiveness data on which CDRH based its approval is on file in the Dockets Management Branch (address above) and is available from that office upon written request. Requests should be identified with the name of the device and the docket number found in brackets in the heading of this document.
Opportunity for Administrative Review
Section 515(d)(3) of the Federal Food, Drug, and Cosmetic Act (the act) (21 U.S.C. 360e(d)(3)) authorizes any interested person to petition, under section 515(g) of the act (21 U.S.C. 360e(g)), for administrative review of CDRH's decision to approve this application. A petitioner may request either a formal hearing under part 12 (21 CFR part 12) of FDA's administrative practices and procedures regulations or a review of the application and CDRH's action by an independent advisory committee of experts. A petition is to be in the form of a petition for reconsideration under § 10.33(b) (21 CFR 10.33(b)). A petitioner shall identify the form of review requested (hearing or independent advisory committee) and shall submit with the petition supporting data and information showing that there is a genuine and substantial issue of material fact for resolution through administrative review. After reviewing the petition, FDA will decide whether to grant or deny the petition and will publish a notice of its decision in the Federal Register. If FDA grants the petition, the notice will state the issue to be reviewed, the form of review to be used, the persons who may participate in the review, the time and place where the review will occur, and other details.
Petitioners may, at any time on or before March 25, 1992, file with the Dockets Management Branch (address above) two copies each petition and supporting data and information, identified with the name of the device and the docket number found in brackets in the heading of this document. Received petitions may be seen in the office above between 9 a.m. and 4 p.m., Monday through Friday.
This notice is issued under the Federal Food, Drug, and Cosmetic Act (secs. 515(d), 520(h), (21 U.S.C. 360e(d), 360(f(h))) and under authority delegated to the Commissioner of Food and Drugs (21 CFR 5.10) and redelегated to the Director, Center for Devices and Radiological Health (21 CFR 5.53).
Dated: February 14, 1992.
Elizabeth D. Jacobson,
Deputy Director, Center for Devices and Radiological Health.
[FR Doc. 92–4118 Filed 2–21–92; 8:45 am]
BILLING CODE 4180–01–M
Public Health Service
Centers for Disease Control Statement of Organization, Functions, and Delegations of Authority
Part H, Chapter HC (Centers for Disease Control) of the Statement of Organization, Functions, and Delegations of Authority of the Department of Health and Human Services (45 FR 67772–67776, dated October 14, 1980, and corrected at 45 FR 69298, October 20, 1980, as amended most recently at 57 FR 412, dated January 6, 1992) is amended to reflect the establishment of the Division of Cancer Prevention and Control, National Center for Chronic Disease Prevention and Health Promotion.
Section HC–B, Organization and Functions, is hereby amended as follows:
After the functional statement for the Office on Smoking and Health (HCL7), insert the following:
Division of Cancer Prevention and Control (HCL8). (1) Plans, directs, and supports prevention, early detection, and control programs for cancer, based upon policy, research, and public health practice; (2) directs, monitors, and reports on activities associated with the implementation of Public Law 101–354: ‘The Breast and Cervical Cancer Mortality Prevention Act of 1990’; (3) plans, directs, and supports activities for monitoring the distribution and the determinants of cancer morbidity, survival, and mortality; (4) plans and conducts epidemiologic studies and evaluations to identify the feasibility and effectiveness of cancer prevention and control strategies; (5) develops public health strategies and guidelines to form the basis for community interventions in cancer prevention and control; (6) provides technical consultation, assistance, and training to state and local public health agencies in all components of early detection and control programs for cancer; (7) provides technical assistance and consultation to health care provider organizations related to the improved education, training, and skills in the prevention, detection and control of selected cancers; (8) identifies problems, needs, and opportunities related to modifiable behavioral and other risk factors, and recommends priorities for health education, health promotion, and cancer risk reduction activities; (9) plans, develops and maintains surveillance systems in collaboration with states, the Office of Surveillance and Analysis, and other Center components, and (10) coordinates activities as appropriate with other CDC organizations, PHS agencies, and related voluntary, international, and professional health organizations.
Office of the Director (HCL81). (1) Establishes and interprets policies and determines program priorities; (2) provides leadership and guidance in program planning and development, program management, program evaluation, budget development, and Division operations; (3) monitors progress toward achieving Division objectives and assessing the impact of programs; (4) insures that Division activities are coordinated with other components of CDC both within and outside the Center; with Federal, state and local agencies; and related voluntary and professional organizations; (5) coordinates Division responses to requests for technical assistance or information on primary and secondary cancer prevention practices, behaviors and policies, including Division activities and programs; (6) provides administrative and logistic support for Division field staff; and (7) develops and produces communications tools and public affairs strategies to meet the needs of Division programs and mission.
Effective Date: February 12, 1992.
William L. Roper,
Director, Centers for Disease Control.
[FR Doc. 92–4119 Filed 2–21–92; 8:45 am]
BILLING CODE 4160–18–M
DEPARTMENT OF THE INTERIOR
Bureau of Land Management
[UT–060–02–4352–08]
Emergency Closure and Restriction on Public Land in the Wedge Portion of the Middle San Rafael River Area of Critical Environmental Concern (ACEC)
February 12, 1992.
AGENCY: Moab District, San Rafael Resource Area, Utah, Bureau of Land Management, Interior.
ACTION: Notice of Closure and Restriction on Public Land for the Protection of Endangered Plant and Wildlife Resources.
SUMMARY: Pursuant to the regulations contained in 43 CFR 8364.1 the Bureau of Land Management is limiting motorized vehicle and mountain bike travel to designated roads and trails, and camping to designated campsites. The restrictions will be in effect on approximately 10,200 acres of public land on and around the Wedge Overlook. These limitations are located within and surrounding the Middle San Rafael Canyon ACEC, and includes all lands and roads not marked with an open sign. These restrictions are in keeping with the designation for this area as described in the San Rafael Resource Management Plan of 1991. A map of the area described above may be viewed in the Resource Area office. The limitation is necessary to prevent further deterioration of the area's endangered plant and wildlife resources. Personnel that are exempt from the area limitation include any Federal, State, or local officer, or member of any organized rescue or fire-fighting force in the performance of an official duty, or any person authorized by the Bureau.
DATES: This limitation is effective March 28, 1992, and shall remain in effect until rescinded by the authorized officer.
PENALTIES: Violators are subject to fines not to exceed $1,000 and/or imprisonment not to exceed 12 months.
FOR FURTHER INFORMATION CONTACT: Penelope Smalley, San Rafael Resource Area Manager, 900 North 700 East, Price, UT 84501 or phone (801) 637–4584.
Roger Zortman,
District Manager.
[FR Doc. 92–4103 Filed 2–21–92; 8:45 am]
BILLING CODE 4310–DG–M
[ID–050–4351–08]
Meeting of the Shoshone District Advisory Council and the District Grazing Board
AGENCY: Bureau of Land Management (BLM); Interior.
ACTION: Notice of meetings.
SUMMARY: This notice sets forth the schedule and proposed topics for a meeting of the Shoshone (Idaho) District Advisory Council and District Grazing Board.
DATES: The District Advisory Council will meet Wednesday, March 25, 1992 and the District Grazing Board will meet Thursday, March 26, 1992.
ADDRESSES: Shoshone District BLM Office, 400 West F Street, Shoshone, Idaho.
FOR FURTHER INFORMATION CONTACT: District Manager Mary Gaylord, P.O. Box 2–B, 400 West F Street, Shoshone, ID 83352. Telephone (208) 886–2206 or FTS 554–6100.
SUPPLEMENTARY INFORMATION: The proposed topics for both of the meetings include the following items:
1. Adjourn December meeting which was continued until a later date (Advisory Council).
2. Introduce new members/elect new chairman (Advisory Council).
3. Presentation on the Blaine County Recreation Plan (Advisory Council).
4. Review alternatives and proposed decisions for the Bennett Hills Resource Management Plan (both Advisory Council and Advisory Board).
5. Other topics as needed.
The Shoshone District Advisory Council is established under section 309 of the Federal Land Policy and Management Act of 1976 (Pub. L. 94–579; U.S.C. 1701 et seq.) as amended. Operation and administration of the Council will be in accordance with the Federal Advisory Committee Act of 1972 (Pub. L. 92–463; 5 U.S.C. Appendix 1) and Department of Interior regulations, including 43 CFR part 1784. Operation and administration of the Grazing Advisory Board will be in accordance with the Federal Advisory Council Committee Act of 1972 (Pub. L. 92–463; U.S.C., Appendix 1) and Department of Interior regulations, including 43 CFR part 1984.
The meetings are open to the public. Anyone may present oral statements or may file a written statement with the District Manager regarding matters on the agenda. Oral statements will be limited to ten minutes.
Anyone wishing to make an oral statement should notify the District Manager by March 23, 1992. Records of the meetings will be available in the Shoshone District Office for public inspection or copying within 30 days after the meetings.
Dated: February 12, 1992.
Janis L. VanWyhe,
Associate District Manager.
[FR Doc. 92–4104 Filed 2–21–92; 8:45 am]
BILLING CODE 4310–66–M
Advisory Council Meeting
AGENCY: Bureau of Land Management, Interior.
ACTION: Notice of meeting, Ukiah, California, District Advisory Council.
SUMMARY: Pursuant to Public Law 94–579 and 43 CFR part 1780, the Ukiah District Advisory Council will meet in Clearlake, California, March 25–26, 1992. Agenda items will include a tour and briefing on a draft management plan for public lands in the Knoxville Recreation Area, a briefing on a partial record of decision for the Arcata Resource Management Plan, a briefing on the final visitor services plan and visitor survey for the King Range National Conservation Area, as well as miscellaneous items of interest. A complete agenda is available from the Ukiah BLM Office.
DATES: March 25, 10 a.m. to 5 p.m., and March 26, 8 a.m. to 3 p.m.
ADDRESSES: March 25, Field Tour, Knoxville Recreation Area, March 26, Best Western El Grande Inn, 15135 Lakeshore Drive, Clearlake, California.
FOR FURTHER INFORMATION CONTACT: Barbara Taglio, Ukiah District Office, Bureau of Land Management, 555 Leslie Street, Ukiah, California 95482, (707) 462–3873.
SUPPLEMENTARY INFORMATION: All meetings of the Ukiah District Advisory Council are open to the public. Individuals may submit oral or written comments for the Council’s consideration. Opportunity for oral comments will be provided at 1 p.m., Thursday, March 26. Summary minutes of the meeting will be maintained by the Ukiah District Office and will be available for inspection and reproduction within 30 days of the meeting.
Dated: February 13, 1992.
Lynda Roush,
Acting District Manager.
[FR Doc. 92–4135 Filed 2–21–92; 8:45 am]
BILLING CODE 4310–40–M
[CO–920–92–4111–15; COC45229]
Colorado; Proposed Reinstatement of Terminated Oil and Gas Lease
Under the provisions of Public Law 97–451, a petition for reinstatement of oil and gas lease COC45229, Rio Blanco County, Colorado, was timely filed and was accompanied by all required rentals and royalties accruing from September 1, 1991, the date of termination.
No valid lease has been issued affecting the lands. The lessee has agreed to new lease terms for rentals and royalties at rates of $5 per acre and 16–2/3 percent, respectively. The lessee has paid the required $500 administrative fee for the lease and has reimbursed the Bureau of Land Management for the cost of this Federal Register notice.
Having met all the requirements for reinstatement of the lease as set out in section 31 (d) and (e) of the Mineral Leasing Act of 1920, as amended, 30 U.S.C. 188 (d) and (e), the Bureau of Land Management is proposing to reinstate the lease effective September 1, 1991, subject to the original terms and conditions of the lease and the increased rental and royalty rates cited above.
Questions concerning this notice may be directed to Joan Gilbert of the Colorado State Office at (303) 239–3783.
Dated: February 11, 1992.
Janet M. Budzilek,
Chief, Fluid Minerals Adjudication Section.
[FR Doc. 92–4100 Filed 2–21–92; 8:45 am]
BILLING CODE 4310–JB–M
[CA–050–09–4212–14; CACA 26636, CACA 7337 WR]
Partial Termination of Small Tract Classification No. 506, Opening of Lands; Trinity County; CA
AGENCY: Bureau of Land Management, Interior.
ACTION: Notice.
SUMMARY: This notice partially terminates Small Tract Classification No. 506 dated January 4, 1957, which classified public land for disposition pursuant to the Small Tract Act of 1938. A portion of the land classified for small tract under classification No. 506 has been found suitable for direct sale under section 203 of the Federal Land Policy and Management Act of 1976 (90 Stat. 2750, 43 U.S.C. 1713) as published in the Federal Register as a notice of realty action on August 15, 1991 (Vol. 56, No. 158).
EFFECTIVE DATE: March 25, 1992.
FOR FURTHER INFORMATION CONTACT:
Patricia Cook, Realty Specialist, Redding Resource Area, 355 Hemsted Drive, Redding, California 96002.
1. The Bureau of Land Management Order of Classification Small Tract No. 506 is hereby terminated insofar as it affects the following described land:
Mount Diablo Meridian
T. 33 N., R. 9 W.,
Sec. 5, lots 52, 53, 56 through 61, S½NE¼, SE¼, and E½SE¼SW¼.
Sec. 8, lot 1.
The area described contains approximately 521.53 acres in Trinity County.
2. At 10 a.m. on March 25, 1992 the land described in paragraph 1 will be open to the operation of the public land laws generally, and to location and entry under the United States mining laws, subject to valid existing rights, the provisions of existing withdrawals, and classifications, and the requirements of applicable law.
Kathleen A. Simmons,
Acting District Manager.
[FR Doc. 92–4136 Filed 2–21–92; 8:45 am]
BILLING CODE 4310–40–M
[AZ–020–02–4212–13; AZA–26445]
Notice of Realty Action, Exchange of Public Lands; Mohave County, AZ
AGENCY: Bureau of Land Management, Interior.
ACTION: Notice of realty action exchange.
SUMMARY: The Bureau of Land Management proposes to exchange public land in order to achieve more efficient management of the public land through consolidation of ownership and the acquisition of unique natural resource lands. All or part of the following described federal lands are being considered for disposal via exchange, subject to valid existing rights, pursuant to Section 206 of the Federal Land Policy and Management Act of 1976, 43 U.S.C. 1716. The final determination on disposal will be made upon completion of the environmental assessment.
Gila and Salt River Base and Meridian, Mohave County, Arizona
Township 22 N., Range 18 W.
Sec. 5, Lots 1–4, S½N¼, S¼;
Sec. 6, Lots 1–7, S½NE¼, SE¼NW¼, E½SW¼, SE¼;
Sec. 7, Lots 1–4, E¼, E½W½;
Sec. 8, All;
Sec. 9, All;
Sec. 11, All;
Sec. 14, All;
Sec. 15, All;
Sec. 16, All;
Sec. 17, All;
Sec. 18, Lots 1–4, E¼, E½W½;
Sec. 19, Lots 1–4, E¼, E½W½;
Sec. 20, All;
Sec. 21, All;
Sec. 22, All;
Sec. 23, All;
Sec. 25, Lots 1–7, W½, W½SE¼;
Sec. 26, All;
Sec. 27, All;
Sec. 28, All;
Sec. 29, All;
Sec. 30, Lots 1–4, E¼, E½W½;
Sec. 31, Lots 1–4, E¼, E½W½;
Sec. 32, All;
Sec. 33, All;
Sec. 34, All;
Sec. 35, All.
Comprising 17401.15 acres, more or less.
Township 21 N., Range 19 W.
Sec. 4. Lots 1-4, S\(\frac{1}{4}\)N\(\frac{1}{4}\), S\(\frac{1}{2}\);
Sec. 5. Lots 1-4, S\(\frac{1}{4}\)N\(\frac{1}{4}\), S\(\frac{1}{2}\);
Sec. 8. All;
Sec. 9. All;
Sec. 16. All;
Sec. 17. All;
Sec. 20. All.
Comprising 4481.78 acres, more or less.
Township 17 N., Range 21 W.
Sec. 4. Lots 1-4, S\(\frac{1}{4}\)N\(\frac{1}{4}\), S\(\frac{1}{2}\);
Sec. 5. Lots 1-4, S\(\frac{1}{4}\)NE\(\frac{1}{4}\), SE\(\frac{1}{4}\)NW\(\frac{1}{4}\),
E\(\frac{1}{2}\)SW\(\frac{1}{4}\), SE\(\frac{1}{4}\);
Sec. 9. All.
Comprising 1796.20 acres, more or less.
Township 18 N., Range 21 W.
Sec. 4. Lots 1-4, S\(\frac{1}{4}\)N\(\frac{1}{4}\), S\(\frac{1}{2}\);
Sec. 6. S\(\frac{1}{4}\)N\(\frac{1}{4}\)SW\(\frac{1}{4}\)SE\(\frac{1}{4}\), S\(\frac{1}{4}\)SW\(\frac{1}{4}\)SE\(\frac{1}{4}\),
SE\(\frac{1}{4}\)SE\(\frac{1}{4}\);
Sec. 7. E\(\frac{1}{2}\);
Sec. 8. All;
Sec. 9. All;
Sec. 16. All;
Sec. 17. All;
Sec. 18. E\(\frac{1}{2}\);
Sec. 19. NE\(\frac{1}{4}\), E\(\frac{1}{2}\)SE\(\frac{1}{4}\);
Sec. 20. All;
Sec. 21. All;
Sec. 28. All;
Sec. 29. All;
Sec. 33. All.
Comprising 7348.96 acres, more or less.
Township 19 N., Range 21 W.
Sec. 4. Lots 1-4, S\(\frac{1}{4}\)N\(\frac{1}{4}\), S\(\frac{1}{2}\);
Sec. 5. Lots 1-4, S\(\frac{1}{4}\)N\(\frac{1}{4}\), S\(\frac{1}{2}\);
Sec. 6. Lots 1-7, S\(\frac{1}{4}\)NE\(\frac{1}{4}\), SE\(\frac{1}{4}\)NW\(\frac{1}{4}\),
E\(\frac{1}{2}\)SW\(\frac{1}{4}\), SE\(\frac{1}{4}\);
Sec. 7. Lots 1-3, E\(\frac{1}{2}\), E\(\frac{1}{2}\)NW\(\frac{1}{4}\), NE\(\frac{1}{4}\)SW\(\frac{1}{4}\);
Sec. 8. All;
Sec. 9. All;
Sec. 20. SW\(\frac{1}{4}\)SW\(\frac{1}{4}\)NW\(\frac{1}{4}\)NW\(\frac{1}{4}\),
W\(\frac{1}{2}\)NE\(\frac{1}{4}\)SW\(\frac{1}{4}\)NW\(\frac{1}{4}\), SE\(\frac{1}{4}\)NE\(\frac{1}{4}\)S
W\(\frac{1}{4}\)NW\(\frac{1}{4}\), W\(\frac{1}{2}\)SW\(\frac{1}{4}\)NW\(\frac{1}{4}\),
SE\(\frac{1}{4}\)SW\(\frac{1}{4}\)NW\(\frac{1}{4}\), SW\(\frac{1}{4}\)SE\(\frac{1}{4}\)NW\(\frac{1}{4}\),
S\(\frac{1}{4}\)SE\(\frac{1}{4}\)SE\(\frac{1}{4}\)NW\(\frac{1}{4}\), NE\(\frac{1}{4}\)NE\(\frac{1}{4}\)SW\(\frac{1}{4}\),
N\(\frac{1}{4}\)NW\(\frac{1}{4}\)NE\(\frac{1}{4}\)SW\(\frac{1}{4}\), NE\(\frac{1}{4}\)SE\(\frac{1}{4}\)N
E\(\frac{1}{2}\)SW\(\frac{1}{4}\), NW\(\frac{1}{4}\)NW\(\frac{1}{4}\)SE\(\frac{1}{4}\),
NW\(\frac{1}{4}\)SW\(\frac{1}{4}\)NW\(\frac{1}{4}\)SE\(\frac{1}{4}\);
Sec. 28, N\(\frac{1}{4}\)NE\(\frac{1}{4}\);
Sec. 29, S\(\frac{1}{4}\)N\(\frac{1}{4}\), S\(\frac{1}{2}\).
Comprising 4414.95 acres, more or less.
The total acreage of all the above described lands is 35,443.02 acres.
In accordance with the regulations of 43 CFR 2201.1, publication of this notice will segregate the affected public land from appropriation under the public land laws, except exchange pursuant to Section 206 of the Federal Land Policy and Management Act of 1976. The segregative effect shall also exclude appropriation of the subject public land under the mining laws, subject to valid existing rights.
The segregation of the above-described land shall terminate upon issuance of a document conveying title to such lands or upon publication in the Federal Register of a notice of termination of the segregation; or the expiration of two years from the date of publication, whichever occurs first.
For a period of forty-five (45) days from the date of publication of this Notice in the Federal Register, interested parties may submit comments to the District Manager, Phoenix District Office, 2015 West Deer Valley Road, Phoenix, Arizona 85027.
Dated: February 14, 1992.
Henri R. Bisson,
District Manager.
[FR Doc. 92–4106 Filed 2–21–92; 8:45 am]
BILLING CODE 4310–32–M
INTERNATIONAL TRADE COMMISSION
[Investigation No. 337–TA–315]
Certain Plastic Encapsulated Integrated Circuits; Issuance of Limited Exclusion Order and Cease and Desist Orders
AGENCY: International Trade Commission.
ACTION: Notice.
SUMMARY: Notice is hereby given that the Commission has issued a limited exclusion order and cease and desist orders in the above-captioned investigation.
FOR FURTHER INFORMATION CONTACT: Andrea C. Casson, Esq., Office of the General Counsel, U.S. International Trade Commission, 500 E Street, SW., Washington, DC 20436, telephone 202–205–3105.
SUPPLEMENTARY INFORMATION: The authority for the Commission’s determination is contained in section 337 of the Tariff Act of 1930, as amended (19 U.S.C. 1337), and in § 210.58 of the Commission’s Interim Rules of Practice and Procedure (19 CFR 210.58).
On July 9, 1990, Texas Instruments Incorporated (TI) filed a complaint under section 337 of the Tariff Act of 1930 (19 U.S.C. 1337) alleging that respondents Analog Devices, Inc. (Analog), Integrated Device Technology, Inc. (IDT) LSI Logic Corporation (LSI), VLSI Technology, Inc. (VLSI), and Cypress Semiconductor Corporation (Cypress), had imported and sold within the United States certain plastic encapsulated integrated circuits manufactured by a process covered by certain claims of U.S. Letters Patent 4,043,027 (the ‘027 patent). The Commission instituted an investigation of the complaint and issued a notice of investigation that was published in the Federal Register on August 15, 1990 (55 FR 33388).
On October 15, 1991, the presiding administrative law judge (ALJ) issued a final initial determination (ID) finding a violation of section 337 on the ground that certain of respondents’ imported plastic encapsulated integrated circuits
were manufactured by a process covered by claims 12 and 14 of the '027 patent. The ALJ found that the processes used for manufacturing these products was not covered by claims 1 and 17 of the '027 patent. In addition, he found that certain other plastic encapsulated integrated circuits imported by respondents (those encapsulated using a process called "same-side" gating) were not covered by claims 1, 12, 14, or 17 of the '027 patent.
On December 12, 1991, the Commission determined to review the issues of (1) claim construction and infringement of claim 17 of the '027 patent and (2) whether the claims in controversy of the '027 patent are invalid as obvious under 35 U.S.C. 103. The Commission determined not to review the remainder of the ID. The Commission solicited comments from the parties, interested government agencies, and other persons concerning the issues under review and the issues of remedy, the public interest, and bonding.
Complainant, all respondents, and the Commission investigative attorneys filed briefs addressing the issues under review and the issues of remedy, the public interest, and bonding. No comments were filed by interested government agencies or other persons.
After review, the Commission affirmed the ALJ's determination that all respondents had violated section 337 of in the importation of opposite-side gated plastic encapsulated integrated circuits manufactured by a process covered by claims 12 and 14 of the '027 patent. In addition, the Commission determined that respondents Analog and VLSI had violated section 337 in the importation of opposite-side gated plastic encapsulated integrated circuits manufactured by a process covered by claim 17 of the '027 patent.
Having determined that there is a violation of section 337, the Commission considered the questions of the appropriate remedy, whether the statutory public interest factors preclude the issuance of a remedy, and bonding during the Presidential review period. The Commission determined that the appropriate form of relief is a limited exclusion order prohibiting all respondents from importing plastic encapsulated integrated circuits manufactured abroad by a process covered by claims 12 and 14 of the '027 patent, and additionally prohibiting respondents Analog and VLSI from importing plastic encapsulated integrated circuits manufactured abroad by a process covered by claim 17 of the '027 patent. The Commission further determined to issue cease and desist orders directed to each respondent. The Commission also determined that the public interest factors enumerated in 19 U.S.C. 1337(d) do not preclude the issuance of the aforementioned relief, and that the bond during the Presidential review period covering infringing products imported or sold by respondents Cypress, IDT, LSI, and VLSI shall be in the amount of 2.5 percent of the entered value of the imported articles concerned, not to exceed $0.50 per plastic encapsulated integrated circuit. The Commission further determined that respondent Analog will not be required during the Presidential review period to post a bond for products imported or sold.
Copies of the Commission's orders and all other nonconfidential documents filed in connection with this investigation are available for inspection during official business hours (8:45 a.m. to 5:15 p.m.) in the Office of the Secretary, U.S. International Trade Commission, 500 E Street, SW., Washington, DC 20436, telephone 202–205–2000. Hearing-impaired persons are advised that information on this matter can be obtained by contacting the Commission's TDD terminal on 202–205–1810.
Issued: February 18, 1992.
By order of the Commission.
Kenneth R. Mason,
Secretary.
[FR Doc. 92–4123 Filed 2–21–92; 8:45 am]
BILLING CODE 7020–02–M
INTERSTATE COMMERCE COMMISSION
[Docket No. AB–366X]
Tylerdale Connecting Railroad Company—Abandonment Exemption—in Washington County, PA; Exemption
Applicant has filed a notice of exemption under 49 CFR 1152 subpart F—Exempt Abandonments to abandon its 0.54-mile line of railroad between mileposts BOA–0.83 and BOA–1.37, near Tylerdale, in Washington County, PA.
Applicant has certified that: (1) No local traffic has moved over the line for at least 2 years; (2) any overhead traffic on the line can be rerouted over other lines; and (3) no formal complaint filed by a user of rail service on the line (or a State or local government entity acting on behalf of such user) regarding cessation of service over the line either is pending with the Commission or with any U.S. District Court or has been decided in favor of the complainant within the 2-year period. The appropriate State agency has been notified in writing at least 10 days prior to the filing of this notice.
As a condition to use of this exemption, any employee affected by the abandonment shall be protected under Oregon Short Line R. Co.—Abandonment—Goshen, 360 I.C.C. 91 (1979). To address whether this condition adequately protects affected employees, a petition for partial revocation under 49 U.S.C. 10505(d) must be filed.
Provided no formal expression of intent to file an offer of financial assistance has been received, this exemption will be effective on March 25, 1992 (unless stayed). Petitions to stay that do not involve environmental issues,¹ formal expressions of intent to file an offer of financial assistance under 49 CFR 1152.27(c)(2),² and trail use/rail banking statements under 49 CFR 1152.29 must be filed by March 5, 1992.³ Petitions to reopen or requests for public use conditions under 49 CFR 1152.28 must be filed by March 16, 1992, with: Office of the Secretary, Case Control Branch, Interstate Commerce Commission, Washington, DC 20423.
A copy of any petition filed with the Commission should be sent to applicant’s representative: Charles M. Rosenberger, CSX Transportation, Inc., 500 Water Street J150, Jacksonville, FL 32202.
If the notice of exemption contains false or misleading information, use of the exemption is void ab initio.
Applicant has filed an environmental report which addresses environmental or energy impacts, if any, from this abandonment.
The Section of Energy and Environment (SEE) will prepare an environmental assessment (EA). SEE will issue the EA by February 28, 1992. Interested persons may obtain a copy of the EA from SEE by writing to it (Room 3219, Interstate Commerce Commission, Washington, DC 20423) or by calling Elaine Kaiser, Chief, SEE at (202) 927–6248. Comments on environmental and
¹ A stay will be routinely issued by the Commission in those proceedings where an informed decision on environmental issues [whether raised by a party or by the Section of Energy and Environment in its independent investigation] cannot be made prior to the effective date of the notice of exemption. See Exemption of Out-of-Service Rail Lines, 5 I.C.C.2d 377 (1989). Any entity seeking a stay involving environmental concerns is encouraged to file its request as soon as possible in order to permit this Commission to review and act on the request before the effective date of this exemption.
² See Exempt. of Rail Abandonment—Offers of Finan. Assist., 4 I.C.C.2d 164 (1987).
³ The Commission will accept a late-filed trail use statement as long as it retains jurisdiction to do so.
energy concerns must be filed within 15 days after the EA becomes available to the public.
Environmental, public use, or trail use/rail banking conditions will be imposed, where appropriate, in a subsequent decision.
Decided: February 14, 1992.
By the Commission, David M. Konschnik, Director, Office of Proceedings.
Sidney L. Strickland, Jr.,
Secretary.
[FR Doc. 92–4145 Filed 2–21–92; 8:45 am]
BILLING CODE 7039–01–M
DEPARTMENT OF JUSTICE
Information Collections Under Review
The Office of Management and Budget (OMB) has been sent the following collection(s) of information proposals for review under the provisions of the Paperwork Reduction Act (44 U.S.C. chapter 35) and the Paperwork Reduction Reauthorization Act since the last list was published. Entries are grouped into submission categories, with each entry containing the following information:
(1) The title of the form/collection;
(2) The agency form number, if any, and the applicable component of the Department sponsoring the collection;
(3) How often the form must be filled out or the information is collected;
(4) Who will be asked or required to respond, as well as a brief abstract;
(5) An estimate of the total number of respondents and the amount of time estimated for an average respondent to respond;
(6) An estimate of the total public burden (in hours) associated with the collection; and
(7) An indication as to whether section 3504(h) of Public Law 96–511 applies.
Comments and/or suggestions regarding the item(s) contained in this notice, especially regarding the estimated public burden and associated response time, should be directed to the OMB reviewer, Ms. Lin Liu on (202) 395–7340 and to the Department of Justice’s Clearance Officer, Mr. Lewis Arnold, on (202) 514–4305. If you anticipate commenting on a form/collection, but find that time to prepare such comments will prevent you from prompt submission, you should notify the OMB reviewer and the DOJ Clearance Officer of your intent as soon as possible.
Written comments regarding the burden estimate or any other aspect of the collection may be submitted to Office of Information and Regulatory Affairs, Office of Management and Budget, Washington, DC 20503, and to Mr. Lewis Arnold, DOJ Clearance Officer, SPS/JMD/5031 CAB, Department of Justice, Washington, DC 20530.
Extension of the Expiration Date of a Currently Approved Collection Without Any Change in the Substance or in the Method of Collection
(1) Registration for Classification as Refugee.
(2) I–590. Immigration and Naturalization Service.
(3) On occasion.
(4) Individuals or households. This form provides a uniform method for applicants to apply for refugee status and contains the information needed in order to adjudicate such application.
(5) 150,000 annual responses at .583 hours per response.
(6) 87,450 annual burden hours.
(7) Not applicable under 3504(h).
(1) Drug Use Forecasting Program.
(2) None. National Institute of Justice.
(3) Quarterly.
(4) State or local governments. The DUF program monitors the extent and types of drug use by arrestees in 24 cities. Data is collected every three months in each city from new samples of arrestees. Participation is voluntary and anonymous; data collection includes interviews and collection of urine specimens.
(5) 35,000 annual responses at .25 hours per response.
(6) 8,750 annual burden hours.
(7) Not applicable under 3504(h).
Public comment on these items is encouraged.
Dated: February 18, 1992.
Lewis Arnold,
Department Clearance Officer, Department of Justice.
[FR Doc. 92–4085 Filed 2–21–92; 8:45 am]
BILLING CODE 4410–10–M
Antitrust Division
Notice Pursuant to the National Cooperative Research Act of 1984: Clean Heavy-Duty Diesel Engine Development; Correction
In notice document 91–29302 in the issue of Monday, December 9, 1991 (56 FR 64276), in the first column, in item 10 in Engine Manufacturer Participants, in the first line, “Goteborg” should read “Goteburg.”
Joseph H. Widmar,
Director of Operations, Antitrust Division.
[FR Doc. 92–4030 Filed 2–21–92; 8:45 am]
BILLING CODE 4410–01–M
DEPARTMENT OF LABOR
Employment and Training Administration
Investigations Regarding Certifications of Eligibility To Apply for Worker Adjustment Assistance
Petitions have been filed with the Secretary of Labor under Section 221(a) of the Trade Act of 1974 ("the Act") and are identified in the Appendix to this notice. Upon receipt of these petitions, the Director of the Office of Trade Adjustment Assistance, Employment and Training Administration, has instituted investigations pursuant to section 221(a) of the Act.
The purpose of each of the investigations is to determine whether the workers are eligible to apply for adjustment assistance under title II, chapter 2, of the Act. The investigations will further relate, as appropriate, to the determination of the date on which total or partial separations began or threatened to begin and the subdivision of the firm involved.
The petitioners or any other persons showing a substantial interest in the subject matter of the investigations may request a public hearing, provided such request is filed in writing with the Director, Office of Trade Adjustment Assistance, at the address show below, not later than March 5, 1992.
Interested persons are invited to submit written comments regarding the subject matter of the investigations to the Director, Office of Trade Adjustment Assistance, at the address shown below, not later than March 5, 1992.
The petitions filed in this case are available for inspection at the Office of the Director, Office of Trade Adjustment Assistance, Employment and Training Administration, U.S. Department of Labor, 200 Constitution Avenue, NW., Washington, DC 20210.
Signed at Washington, DC, this 10th day of February 1992.
Marvin M. Fooks,
Director, Office of Trade Adjustment Assistance.
## APPENDIX
| Petitioner (union/workers/firm) | Location | Date received | Date of petition | Petition No. | Articles produced |
|---------------------------------|----------------|---------------|------------------|--------------|------------------------------------|
| Amerada Hess Corp (Co) | Houston, TX | 2/10/92 | 1/20/92 | 26,827 | Crude Oil, Natural Gas. |
| American Fabrics Co. (UTWU) | Bridgeport, CT | 2/10/92 | 2/13/92 | 26,828 | Raschel Lace, Lurex Lace. |
| AMF-Reece, Inc. (Co) | Burlington, NC | 2/10/92 | 1/25/92 | 26,829 | Industrial Sewing Machines. |
| Cold Spring Granite Co. (Wkrs)| Cold Spring, MN| 2/10/92 | 1/29/92 | 26,830 | Granite. |
| Computalog Wireline Services, Inc. (Wkrs) | Williston, ND | 2/10/92 | 1/25/92 | 26,831 | Oil Well Services. |
| County Forest Products (Wkrs) | Patten, ME | 2/10/92 | 1/27/92 | 26,832 | Lumber Products. |
| De Ja Vu Apparel (Wkrs) | Forest City, PA| 2/10/92 | 1/30/92 | 26,833 | Ladies’ Dresses. |
| Dexter Shoe Co. (Wkrs) | Milo, ME | 2/10/92 | 1/14/92 | 26,834 | Boots and Shoes. |
| Drilling and Service, Inc. (Co)| Casper, WY | 2/10/92 | 1/28/92 | 26,835 | Crude Oil. |
| Dunlop Slazenger Corp. (Co) | Hartwell, SC | 2/10/92 | 1/27/92 | 26,836 | Tennis Balls. |
| Eby Co. (Wkrs) | Philadelphia, PA| 2/10/92 | 1/26/92 | 26,837 | Computer Components. |
| Ford Motor Co., Cleveland Sales (Wkrs) | Brecksville, OH | 2/10/92 | 1/25/92 | 26,838 | Automotive Workshop. |
| Honeywell, Inc. (IUE) | Fort Washington, PA | 2/10/92 | 1/24/92 | 26,839 | Process Control Instruments. |
| Jarlyn, Inc. (Wkrs) | Jermyn, PA | 2/10/92 | 2/04/92 | 26,840 | Women’s dresses and Sportswear. |
| Jodi Lynn Apparel Co., Inc. ILGWU | Nazareth, PA | 2/10/92 | 1/28/92 | 26,841 | Nightwear. |
| L and M Sportswear Co. ILGWU | Reseto, PA | 2/10/92 | 1/31/92 | 26,842 | Women’s Blouses. |
| PPG Industries (Wkrs) | Cleveland, OH | 2/10/92 | 1/29/92 | 26,843 | Automobile Paint. |
| Somerset Technologies (Wkrs) | Somerset, NJ | 2/10/92 | 1/28/92 | 26,844 | Blow Molding Machines and Extruders. |
| Torrington Co. (Co) | Torrington, CT | 2/10/92 | 1/16/92 | 26,845 | Ball Bearing and Anti-friction Devices. |
| Valiant Fasteners, Inc. ILGWU | Wind Gap, PA | 2/10/92 | 1/29/92 | 26,846 | Women’s Blouses. |
| Van Port Industries, Inc. ILGWU | Vancouver, WA | 2/10/92 | 1/29/92 | 26,847 | Furniture Paneling, Door Skins. |
| Walker Forge (Wkrs) | Racine, WI | 2/10/92 | 2/23/92 | 26,848 | Connecting Rods. |
---
[FR Doc. 92–4141 Filed 2–21–92; 8:45 am]
BILLING CODE 4510–30–M
[TA–W–26,277 Sidney, OH; TA–W–26,277A Cincinnati, OH; and Sales Offices in TA–W–26,277B Hartford, CT; TA–W–26,277C Cincinnati, OH; TA–W–26,277D Henderson, NV]
The Monarch Machine Tool Co., Amended Certification Regarding Eligibility To Apply for Worker Adjustment Assistance
In accordance with Section 223 of the Trade Act of 1974 (19 U.S.C. 2273) the Department of Labor issued a Certification of Eligibility to Apply for Worker Adjustment Assistance on December 4, 1991, applicable to all workers of The Monarch Machine Tool Company, Sidney, Ohio. The Notice was published in the Federal Register on December 27, 1991 (56 FR 67104). The certification was amended on January 30, 1992 to include the engineering facility in Cincinnati, Ohio. That notice was published in the Federal Register on February 6, 1992 (57 FR 4648).
The Department is amending the certification to include the above mentioned sales locations of Monarch Machine Tool Company. Monarch Machine Tool experienced substantial sales declines in 1991 for metalworking lathes.
The intent of the Department's certification is to include all workers of Monarch Machine Tool who were adversely affected by increased imports of metalworking lathes.
The amended notice applicable to TA–W–26,277 is hereby issued as follows:
All workers of The Monarch Machine Tool Company, Monarch Sidney Division, Sidney, Ohio; Cincinnati, Ohio and in the Monarch Sidney Division Sales Offices in Hartford, Connecticut; Cincinnati, Ohio and Henderson, Nevada who became totally or partially separated from employment on or after September 3, 1990 are eligible to apply for adjustment assistance under Section 223 of the Trade Act of 1974.
Signed at Washington, DC, this 14th day of February 1992.
Marvin M. Fooks,
Director, Office of Trade Adjustment Assistance.
[FR Doc. 92–4140 Filed 2–21–92; 8:45 am]
BILLING CODE 4510–30–M
[TA–W–26,427]
Digital Equipment Corp. Colorado Springs, CO; Affirmative Determination Regarding Application for Reconsideration
On January 16, 1992 and on January 28, 1992, the petitioners requested administrative reconsideration of the Department of Labor's Notice of Negative Determination Regarding Eligibility to Apply for Worker Adjustment Assistance for workers at the subject firm. The Department's Negative Determination was issued on December 13, 1991 and published in the Federal Register on December 27, 1991 (56 FR 67104).
The petitioners claim, among other things, that some production was transferred overseas and that workers at several other disc companies have been certified eligible for trade adjustment assistance benefits.
Conclusion
After careful review of the application, I conclude that the claims are of sufficient weight to justify reconsideration of the Department of Labor's prior decision. The application is, therefore, granted.
Signed at Washington, DC, this 14th day of February 1992.
Stephen A. Wandner,
Deputy Director, Office of Legislation & Actuarial Services, Unemployment Insurance Service.
[FR Doc. 92–4143 Filed 2–21–92; 8:45 am]
BILLING CODE 4510–30–M
[TA–W–26,760]
Unisys Corp. Flemington, NJ; Termination of Investigation
Pursuant to section 221 of the Trade Act of 1974, an investigation was initiated on January 21, 1992, in response to a worker petition which was filed on January 21, 1992, on behalf of workers at Unisys Corporation, Flemington, New Jersey.
A negative determination applicable to the petitioning group of workers was issued on October 31, 1991 (TA–W–26,118). No new information is evident which would result in a reversal of the Department's previous determination. Consequently, further investigation in this case would serve no purpose, and the investigation has been terminated. Workers may refile for adjustment assistance eligibility at a later time as circumstances change.
Signed at Washington, DC, this 14th day of February, 1992.
Marvin M. Fooks,
Director, Office of Trade Adjustment Assistance.
[FR Doc. 92–4144 Filed 2–21–92; 8:45 am]
BILLING CODE 4510–30–M
Job Training Partnership Act:
Announcement of Proposed Noncompetitive Grant Award
AGENCY: Employment and Training Administration, Labor.
ACTION: Notice of intent to award a noncompetitive grant.
SUMMARY: The Employment and Training Administration (ETA) announces its intent to award a noncompetitive grant to Council of Jewish Organizations of Boro Park of Brooklyn, New York, for the provision of specialized services under the authority of the Job Training Partnership Act (JTPA).
DATES: It is anticipated that this grant award will be executed by March 23, 1992, and will be funded for eighteen months. Submit comments by 4:45 p.m. (Eastern Time), on March 10, 1992.
ADDRESSES: Submit comments regarding this proposed assistance award to: U.S. Department of Labor, Employment and Training Administration, room C–4305, 2000 Constitution Avenue, NW., Washington, DC 20210, Attention: Willie Harris; Reference FR–DAA–001.
SUPPLEMENTARY INFORMATION: The Employment and Training Administration (ETA) announces its intent to award a noncompetitive grant to the Council of Jewish Organizations of Boro Park of Brooklyn, New York. The Council of Jewish Organizations of Boro Park will test the integration of occupationally related adult basic skills into employment and training programs in collaboration with the New York City Department of Employment, Performance Plus Learning Consultants, local employers and JTPA training providers. Funds for this activity are authorized by the Job Training Partnership Act, as amended, Title IV—Federally Administered Programs. The proposed funding is approximately $350,000 for eighteen months.
Signed at Washington, DC on February 12, 1992.
Robert D. Parker,
ETA Grant Officer.
[FR Doc. 92–4139 Filed 2–21–92; 8:45 am]
BILLING CODE 4510–30–M
NATIONAL SCIENCE FOUNDATION
Advisory Panel for Studies, Evaluation, and Dissemination: Meeting
In accordance with the Federal Advisory Committee Act (Pub. L. 92–463, as amended), the National Foundation announces the following meeting.
Name: Advisory Panel for Studies, Evaluation and Dissemination.
Date and Time: March 5th and 6th, 1992, 9 a.m. to 5 p.m.
Place: Hotel Washington, 15th & Pennsylvania Avenue NW., Washington, DC 20004.
Type of Meeting: Open.
Contact Person: Dr. Kenneth J. Travers, Office Head, Office of Studies, Evaluation and Dissemination, Directorate for Education and Human Resources, National Science Foundation, Washington, DC 20550, telephone (202) 357–7425.
Minutes: May be obtained from the contact person above.
Purpose of Meeting: United States participation in the Third International Mathematics and Science Study.
Agenda: Advise director of study on where the United States should participate in study. Discuss test items and changes in U.S. policy relating to study and participation. Measure science literacy.
Reason for Late Notice: Administrative oversight.
Dated: February 18, 1992.
M. Rebecca Winkler,
Committee Management Officer.
[FR Doc. 92–4168 Filed 2–21–92; 8:45 am]
BILLING CODE 7555–01–M
NUCLEAR REGULATORY COMMISSION
[Docket No. 50–458]
Gulf States Utilities Co.; Environmental Assessment and Finding of No Significant Impact
The Nuclear Regulatory Commission (the Commission) is considering issuance of an exemption from the requirements of 10 CFR 26.29(b) regarding the protection of personal information associated with fitness for duty programs to Gulf States Utilities Company (the licensee) for the River Bend Station, Unit 1 located in West Feliciana Parish, Louisiana.
Environmental Assessment
Identification of Proposed Action
The proposed action would grant an exemption from the requirements of 10 CFR 26.29(b) regarding the protection of personal information associated with fitness for duty programs. By letter dated January 28, 1992, the licensee requested an exemption from 10 CFR 26.29(b) to allow the licensee to provide, in a confidential manner, information concerning a former employee's drug test results to the Louisiana Office of Employment Security.
The Need for the Proposed Action
Section 26.29(b) of title 10 of the Code of Federal Regulations restricts the disclosure of personal information associated with fitness for duty programs. The licensee has requested a one-time exemption in order to provide information to the Louisiana Office of Employment Security. The Louisiana Office of Employment Security has informed the licensee that the personal information associated with the fitness for duty program must be provided in order to contest an earlier finding.
Therefore, an exemption is needed to allow the licensee to effectively participate in the appeals process before the Louisiana Office of Employment Security.
Environmental Impacts of the Proposed Action
The proposed exemption affects only the restrictions associated with the release of personal information related to the licensee's fitness for duty program. Therefore, the Commission concludes that there are no measurable radiological or non-radiological environmental impacts associated with the proposed exemption.
Alternative to the Proposed Action
Since the Commission has concluded there is no measurable environmental impact associated with the proposed exemption, any alternatives will have either no environmental impact or will have a greater environmental impact. The principal alternative to the exemption would be to prohibit the release of the personal information to the Louisiana Office of Employment Security. Such an action would not affect the protection of the environment and would result in preventing the licensee's effective participation in the appeals process.
Alternative Use of Resources
This action does not involve the use of resources not considered previously in the Final Environmental Statement for River Bend Station, Unit 1, dated January 1985.
Agencies and Persons Contacted
The NRC staff reviewed the licensee's request and did not consult other agencies or persons.
Finding of No Significant Impact
The Commission has determined not to prepare an environmental impact statement for the proposed exemption. Based upon the environmental assessment, the NRC staff concludes that the proposed action will not have a significant effect on the quality of the human environment.
For further details with respect to this proposed action, see the licensee's letter dated January 28, 1992. The letter is available for public inspection at the Commission's Public Document Room, the Gelman Building, 2120 L Street, NW., Washington, DC 20555 and at the Government Documents Department, Louisiana State University, Baton Rouge, Louisiana 70803.
Dated at Rockville, Maryland, this 19th day of February 1992.
For the Nuclear Regulatory Commission.
Suzanne C. Black,
Director, Project Directorate IV–2, Division of Reactor Projects III/IV/V, Office of Nuclear Reactor Regulation.
[FR Doc. 92–4170 Filed 2–21–92; 8:45 am]
BILLING CODE 7590–01–M
Aging Research Information Conference; Meeting
The study of nuclear power plant aging is an important part of the NRC's current research program for understanding aging degradation of structures, components, and systems in order to assure continued safe operation of nuclear power plants for 40 years or more. The nuclear community worldwide has entered a period when such information on age-related degradation in nuclear power plants is bound to play a vital role in decisions involving plant modifications, shutdown or continued safe and viable operation. The NRC Aging Research Information Conference will provide a forum for exchanging information on age-related degradation of components, systems, and structures.
The keynote address on the first day of the conference will be delivered by NRC Chairman Ivan Selin. During the conference, principal addresses will be made by NRC Commissioner Kenneth C. Rogers on March 25, 1992, and by NRC Commissioner James R. Curtiss on March 26, 1992. The conference will conclude with a panel discussion led by NRC Commissioner Forrest J. Remick and James H. Sniezek, NRC Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research.
Among others who have confirmed participation are: Eugene Fitzpatrick, Vice President, American Electric Power Service Corporation; James J. Howard, Chairman of the Board and CEO, Northern States Power Company; Bryon Lee, Jr., President and CEO, NUMARC; Harold B. Ray, Senior Vice President, Southern California Edison Company; Hal B. Tucker, Senior Vice President, Duke Power Company; and Robert A. Watson, Senior Vice President, Carolina Power & Light Company. In addition, participation by NRC senior management and international nuclear experts is expected.
The conference is comprised of presentations of approximately 50 technical papers, as well as a panel discussion on a wide spectrum of plant aging issues. The program will include exhibits and software demonstrations. A copy of the proposed program for the conference will be available in the NRC Public Document Room after February 24, 1992.
DATES AND TIME: March 24–26, 1992, 8 a.m. to 5 p.m. daily; and March 27, 1992, 8 a.m. to 1 p.m.
ADDRESSES: Holiday Inn Crowne Plaza, 1750 Rockville Pike, Rockville, MD.
ADMISSION: Prior registration is required, and a registration fee of $125.00 is being charged to defray the cost of the meeting. The registration fee is not refundable and not transferable. Only the first 500 registrants are assured participation. To register, contact Dr. Mano Subuchi, Brookhaven National Laboratory, Building 130, Upton, New York 11973. Phone No. 516–282–2429; FAX 516–282–9857.
FOR FURTHER INFORMATION CONTACT: Mr. Satish K. Aggarwal, General Chairman, Aging Research Information Conference, U.S. Nuclear Regulatory Commission, Washington, DC 20555, Phone 301–492–3823. FAX 301–492–3696. (8 U.S.C. 552(A))
Dated at Rockville, Maryland, this 18th day of February 1992.
For the Nuclear Regulatory Commission.
Eric S. Beckjord,
Director, Office of Nuclear Regulatory Research.
[FR Doc. 92–4172 Filed 2–21–92; 8:45 am]
BILLING CODE 7590–01–M
Advisory Committee on Reactor Safeguards Working Group on Safety Goal Implementation; Meeting
The ACRS Working Group on Safety Goal Implementation will hold a meeting on February 28, 1992, at the Stapleton Plaza Hotel, Denver, CO.
The entire meeting will be open to public attendance.
The agenda for the subject meeting shall be as follows: Friday, February 28, 1992—8:30 a.m. until the conclusion of business.
The Working Group will meet to develop a proposed report on safety goal implementation for consideration by the ACRS full Committee at a future meeting.
During the meeting, the members of the Working Group may exchange views regarding this meeting.
During the meeting, the members of the Working Group may exchange views regarding this matter.
Further information regarding this meeting such as, whether the meeting has been cancelled or rescheduled, can be obtained by a prepaid telephone call to the cognizant ACRS staff engineer, Mr. Dean Houston (telephone 301/492–9521) between 7:30 a.m. and 4:15 p.m. (EST). Persons planning to attend this meeting are urged to contact the above named individual one or two days before the scheduled meeting to be advised of any changes in schedule, etc., that may have occurred.
Dated: February 18, 1992.
Sam Duraliswamy,
Chief, Nuclear Reactors Branch.
[FR Doc. 92–4169 Filed 2–21–92; 8:45 am]
BILLING CODE 7590–01–M
Advisory Committee on Reactor Safeguards (ACRS) and Advisory Committee on Nuclear Waste (ACNW); Proposed Meetings
In order to provide advance information regarding proposed public meetings of the ACRS Subcommittees and meetings of the ACRS full Committee, of the ACNW, and the ACNW Working Groups the following preliminary schedule is published to reflect the current situation, taking into account additional meetings that have been scheduled and meetings that have been postponed or cancelled since the last list of proposed meetings was published January 23, 1992 [57 FR 2793]. Those meetings that are firmly scheduled have had, or will have, an individual notice published in the Federal Register approximately 15 days (or more) prior to the meeting. It is expected that sessions of ACRS full Committee and ACNW meetings designated by an asterisk (*) will be closed in whole or in part to the public. ACRS full Committee and ACNW meetings begin at 8:30 a.m. and ACRS Subcommittee and ACNW Working Group meetings usually begin at 8:30 a.m. The time when items listed on the agenda will be discussed during ACRS
full Committee and ACNW meetings, and when ACRS Subcommittee and ACNW Working Group meetings will start will be published prior to each meeting. Information as to whether a meeting has been firmly scheduled, cancelled, or rescheduled, or whether changes have been made in the agenda for the March 1992 ACRS and ACNW full Committee meetings can be obtained by a prepaid telephone call to the Office of the Executive Director of the Committees (telephone: 301/492-4800 (recording) or 301/492-7288, Attn: Barbara Jo White) between 7:30 a.m. and 4:15 p.m., Eastern Time.
**ACRS Subcommittee Meetings**
*Advanced Reactor Designs*, February 28–27, 1992, Oak Ridge, TN. The Subcommittee will discuss the testing program for the MHTGR design and related issues.
*Ad Hoc Working Group*, February 28, 1992, Denver, CO. The Working Group will meet to develop a proposed alternative plan for implementation of the Safety Goals Policy for future consideration by the ACRS.
*Thermal Hydraulic Phenomena*, March 3, 1992, Bethesda, MD. The Subcommittee will continue its review of the integral systems testing requirements for the Westinghouse Electric Corporation’s AP600 passive plant design.
*Joint Computers in Nuclear Power Plant Operations, Instrumentation and Control Systems, and Human Factors*, March 4, 1992, Bethesda, MD. The Subcommittee will discuss Control Room Designs and Testing, and Associated Human Factors Issues.
*Planning and Procedures*, March 4, 1992, Bethesda, MD, 3 p.m.–5:30 p.m. The Subcommittee will discuss proposed ACRS activities and related matters.
*Thermal Hydraulic Phenomena*, March 26, 1992, Bethesda, MD. The Subcommittee will review the GE generic program supporting power level increases for operating CE BWR nuclear power plants.
*Plant Operations*, April 1, 1992, Bethesda, MD. The Subcommittee will review the Draft NUREG–1449, addressing the staff’s evaluation of risk from shutdown and low-power operations at U.S. commercial nuclear power plants.
*Planning and Procedures*, April 1, 1992, Bethesda, MD, 3 p.m.–5:30 p.m. The Subcommittee will discuss proposed ACRS activities and related matters.
*Regional Programs*, May 20, 1992, NRC Region V Office, Walnut Creek, CA. The Subcommittee will discuss the activities of the NRC Region V Office.
*Joint Individual Plant Examinations/Severe Accidents*, Date to be determined (March/April), Bethesda, MD. The Subcommittees will discuss the status of the IPE program and the development of Severe Accident Management Guidelines.
*Joint Computers in Nuclear Power Plant Operations/Instrumentation and Control Systems*, Date to be determined (April), Bethesda, MD. The Subcommittees will discuss digital I&C system designs and practices at foreign plants and the international computer activities.
*Advanced Pressurized Water Reactors*, Date to be determined (April), Bethesda, MD. The Subcommittee will continue its review of the ABB CE System 80+ CESSAR Design Certification. Subject material being proposed for discussion includes Engineered Safety Feature Systems and USIs/GSIs.
*Thermal Hydraulic Phenomena*, Date to be determined (April/May), Bethesda, MD. The Subcommittee will continue its review of the NRC staff program to address the issue of interfacing systems LOCAs.
*Joint Thermal Hydraulic Phenomena/Core Performance*, Date to be determined (June/July, tentative), Bethesda, MD. The Subcommittees will continue the review of the issues pertaining to BWR core power stability.
*Decay Heat Removal Systems*, Date to be determined (July, tentative), Bethesda, MD. The Subcommittee will review the proposed final resolution of Generic Safety Issue 23, “Reactor Coolant Pump Seal Failures.”
*Thermal Hydraulic Phenomena*, Date to be determined, Bethesda, MD. The Subcommittee will review the status of the application of the Code Scaling, Applicability, and Uncertainty (CSAU) Evaluation Methodology to a small-break LOCA calculation for a B&W plant.
**ACRS Full Committee Meetings**
*383rd ACRS Meeting*, March 5–7, 1992, Bethesda, MD. Items are tentatively scheduled.
*A. GE Advanced Boiling Water Reactor*—Review and report on the draft Safety Evaluation Reports for this standardized nuclear reactor design.
*B. Policy Issues for the Certification of Passive Plants*—Discuss and develop a plan for ACRS review of policy issues associated with the certification of passive nuclear power plant designs.
*C. Integral Systems Testing for the Westinghouse AP600 Nuclear Power Plant*—Review and report on the proposed integral systems testing program requirements for the Westinghouse AP600 passive nuclear plant.
*D. Prioritization of Generic Issues*—Review and comment on NRC staff-proposed priority rankings for various generic issues.
*E. Meeting with NRC Commissioners*—Meeting with NRC Commissioners to discuss items of mutual interest.
*F. Pilgrim Nuclear Power Station*—Briefing by and discussion with representatives of the NRC staff regarding the Emergency Response Plan demonstration for this facility.
*G. NRC Safety Research Program*—Briefing by representatives of the NRC staff, as appropriate, and discussion regarding a proposed report to the Commission on the NRC safety research program.
*H. Implementation of NRC Quantitative Safety Goals*—Discuss proposed ACRS activities regarding development of a proposed plan for implementation for the NRC quantitative safety goals
*I. ACRS Subcommittee Activities*—Reports and discussion regarding the status of assigned subcommittee activities, including matters related to experimental testing facilities for advanced (non-water) reactors.
*J. Future ACRS Activities*—Discuss items proposed for consideration by the full Committee and related NRC activities, including updating of NRC regulations.
*K. Miscellaneous*—Discuss topics related to the conduct of ACRS activities and specific issues that were not completed during previous meetings as time and availability of information permit.
*L. Appointment of New Members*—Discuss qualifications of candidates proposed for appointment to the Committee.
*384th ACRS Meeting*, April 2–4, 1992, Bethesda, MD—Agenda to be announced.
*385th ACRS Meeting*, May 7–9, 1992, Bethesda, MD—Agenda to be announced.
**ACNW Full Committee and Working Group Meetings**
*41st ACNW Meeting*, March 12–13, 1992, Bethesda, MD. Items are tentatively scheduled.
A. Continue deliberations to investigate the feasibility of applying a systems approach to the analysis of the overall high-level waste program.
B. Periodic meeting with NRC Commissioners to discuss items of mutual interest.
C. Presentation by representatives of the NRC's Office of Nuclear Regulatory Research on the High-Level Radioactive Waste Program Plan.
D. Consider lessons learned from the pathfinder decommissioning (tentative).
E. Discuss anticipated and proposed Committee activities, future meeting agenda, administrative, and organizational matters, as appropriate. Also, discuss matters and specific issues that were not completed during previous meetings as time and availability of information permit.
42nd ACNW Meeting, April 23–24, 1992, Bethesda, MD—Agenda to be announced.
ACNW Working Group on the Impact of Long-Range Climate Change in the Area of the Southern Basin and Range, May 27, 1992, Bethesda, MD. The Working Group will discuss the historical evidence and the potential for climate changes in the southern Basin and Range and the impact of climate changes on the performance of the proposed high-level waste repository at Yucca Mountain.
43rd ACNW Meeting, May 28–29, 1992, Bethesda, MD—Agenda to be announced.
ACNW Working Group on Methods for Assessing Natural Resources at a Proposed High-Level Waste Repository Site, July 29, 1992, Bethesda, MD. The Working Group will discuss methodologies for the assessment of the potential for natural resources at the proposed high-level waste repository site at Yucca Mountain. The relationship between such resources and the potential for human intrusion will be emphasized.
Dated: February 14, 1992.
John C. Hoyle,
Advisory Committee Management Officer.
[FR Doc. 92–4079 Filed 2–21–92; 8:45 am]
BILLING CODE 7590–01–M
[U.S. Army Materials Technology Laboratory; Proposed Issuance of Orders Authorizing Disposition of Component Parts and Terminating Facility License
The U.S. Nuclear Regulatory Commission (the Commission) is considering issuance of Orders authorizing the U.S. Army Materials Technology Laboratory (the licensee) to dismantle the pool-type nuclear reactor facility and dispose of the component parts, and termination of Facility License No. R–65, in accordance with the licensee’s application dated October 8, 1991.
The first of these Orders would be issued following the Commission’s review and approval of the licensee’s detailed plan for decontamination of the facility and disposal of the radioactive components, or some alternate disposition plan for the facility. This Order would authorize implementation of the approved plan. Following completion of the authorized activities and verification by the Commission that acceptable radioactive contamination levels have been achieved, the Commission would issue a second Order terminating the facility license and any further NRC jurisdiction over the facility. Prior to issuance of each Order, the Commission will have made the findings required by the Atomic Energy Act of 1954, as amended (the Act), and the Commission’s regulations.
By March 25, 1992, the licensee may file a request for a hearing with respect to issuance of the subject Orders and any person whose interest may be affected by this proceeding and who wishes to participate as a party in the proceeding must file a written petition for leave to intervene. Requests for a hearing and petitions for leave to intervene shall be filed in accordance with the Commission’s “Rules and Practice for Domestic Licensing Proceedings” in 10 CFR part 2. Interested persons should consult a current copy of 10 CFR 2.714 which is available at the Commission’s Public Document Room, the Gelman Building, 2120 L Street NW., Washington, DC 20555. If a request for a hearing or petition for leave to intervene is filed by the above date, the Commission or an Atomic Safety and Licensing Board Panel, designated by the Commission or by the Chairman of the Atomic Safety and Licensing Board Panel, will rule on the request and/or petition; and the Secretary or the designated Atomic Safety and Licensing Board Panel will issue a notice of hearing or an appropriate order.
As required by 10 CFR 2.714, a petition for leave to intervene shall set forth with particularity the interest of the petitioner in the proceeding, and how that interest may be affected by the results of the proceeding. The petition should specifically explain the reasons why intervention should be permitted with particular reference to the following factors: (1) The nature of the petitioner’s right under the Act to be made a party to the proceeding; (2) the nature and extent of the petitioner’s property, financial, or other interest in the proceeding; and (3) the possible effect of any order which may be entered in the proceeding on the petitioner’s interest. The petition should also identify the specific aspect(s) of the subject matter of the proceeding as to which petitioner wishes to intervene. Any person who has filed a petition for leave to intervene or who has been admitted as a party may amend the petition without requesting leave of the Board up to fifteen (15) days prior to the first prehearing conference scheduled in the proceeding, but such an amended petition must satisfy the specificity requirements described above.
Not later than fifteen (15) days prior to the first prehearing conference scheduled in the proceeding, a petitioner shall file a supplement to the petition to intervene which must include a list of the contentions which are sought to be litigated in the matter. Each contention must consist of a specific statement of the issue of law or fact to be raised or controverted. In addition, the petitioner shall provide a brief explanation of the bases of the contention and a concise statement of the alleged facts or expert opinion which support the contention and on which the petitioner intends to rely in proving the contention at the hearing. The petitioner must also provide references to those specific sources and documents of which the petitioner is aware and on which the petitioner intends to rely to establish those facts or expert opinion. The petitioner must provide sufficient information to show that a genuine dispute exists with the applicant on a material issue of law or fact. Contentions shall be limited to matters within the scope of the orders under consideration. The contention must be one which, if proven, would entitle the petitioner to relief. A petitioner who fails to file such a supplement which satisfies these requirements with respect to at least one contention will not be permitted to participate as a party.
Those permitted to intervene become parties to the proceeding, subject to any limitations in the order granting leave to intervene, and have the opportunity to participate fully in the conduct of the hearing, including the opportunity to present evidence and cross-examine witnesses.
A request for a hearing or a petition for leave to intervene must be filed with the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attention: Docketing and Service Branch; or may be delivered to the Commission’s Public Document Room, the Gelman Building, 2120 L Street NW., Washington, DC, by the above date. Where petitions are filed during the last ten (10) days of the notice period, it is requested that the petitioner promptly so inform the
Commission by toll-free telephone call to Western Union at 1–(800) 325–6000 (in Missouri 1–(800) 342–6700). The Western Union operator should be given Datagram Identification Number 3737 and the following message addressed to Seymour H. Weiss: Petitioner’s name and telephone number; date petition was mailed; U.S. Army Materials Technology Laboratory; and publication date and page of this Federal Register notice. A copy of the petition should also be sent to the Office of the General Counsel, U.S. Nuclear Regulatory Commission, Washington, DC 20555, and to Mr. James Savage, U.S. Army Materials Technology Laboratory, Attention: SLCMT–DL, 405 Arsenal Street, Watertown, Massachusetts 02172–0001, attorney for the licensee.
Nontimely filings of petitions for leave to intervene, amended petitions, supplemental petitions and/or requests for hearing will not be entertained absent a determination by the Commission, presiding officer or the Atomic Safety and Licensing Board Panel that the petition and/or request should be granted based upon a balancing of the factors specified in 10 CFR 2.714[a](1)(i)–(v) and 2.714(d).
For further details with respect to this action, see the licensee’s application dated October 8, 1991. This document is available for public inspection at the Commission’s Public Document Room, the Gelman Building, 2120 L Street NW., Washington, DC 20555.
Dated at Rockville, Maryland, this 14th day of February 1992.
For the Nuclear Regulatory Commission.
Seymour H. Weiss,
Director, Non-Power Reactors,
Decommissioning and Environmental Project Directorate, Division of Advanced Reactors and Special Projects, Office of Nuclear Reactor Regulation.
[FR Doc. 92–4171 Filed 2–21–92; 8:45 am]
BILLING CODE 7590–01–M
[DOCKET NO. 446A]
Texas Utilities Electric Co.; Comanche Peak Electric Station, Unit 2; Receipt of Antitrust Information and Time for Public Comment
Texas Utilities Electric Company has filed antitrust information in conjunction with its application for an operating license for the Comanche Peak Stream Electric Station, Unit 2 located in Somervell County, Texas, approximately 40 miles southwest of Fort Worth, Texas. The data submitted contain antitrust information for review, pursuant to NRC Regulatory Guide 9.3, necessary to determine whether there have been any significant changes since the antitrust operating license review of Comanche Peak Unit 1, which was completed in August 1989.
On completion of a staff antitrust review, the Director of the Office of Nuclear Reactor Regulation will issue an initial finding as to whether there have been “significant changes” under section 105c(2) of the Atomic Energy Act, as amended. A copy of this finding will be published in the Federal Register and will be sent to the Washington, D.C. and local public document rooms and to those persons providing comments or information in response to this notice. If the initial finding concludes that there have not been any significant changes, a request for reevaluation of the finding may be submitted within 30 days of the date of this Federal Register notice. The results of any reevaluation that are requested will also be published in the Federal Register and copies sent to the Washington, DC, and local public document rooms.
A copy of the general information portion of the application for an operating license and the antitrust information submitted is available for public examination and copying for a fee at the Commission’s Public Document Room, 2120 L Street NW., Washington, DC, and in the local public document room at the Somervell County Library, On the Square, P.O. Box 417, Glen Rose, Texas 76043.
Any person who desires additional information regarding the matter covered by this notice or who wishes to have views considered with respect to significant changes related to antitrust matters which occurred since the previous antitrust review, should submit such requests for information or views to the U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attention: Chief, Policy Development and Technical Support Branch, Office of Nuclear Reactor Regulation, within 30 days of the date of this notice.
Dated at Rockville, Maryland, this 14th day of February 1992.
For the Nuclear Regulatory Commission.
Anthony T. Gody,
Chief, Policy Development and Technical Support Branch, Program Management, Policy Development and Analysis Staff, Office of Nuclear Reactor Regulation.
[FR Doc. 92–4173 Filed 2–21–92; 8:45 am]
BILLING CODE 7590–01–M
OFFICE OF PERSONNEL MANAGEMENT
Federal Prevailing Rate Advisory Committee; Open Committee; Open Committee Meeting
According to the provisions of section 10 of the Federal Advisory Committee Act (Pub. L. 92–463), notice is hereby given that meetings of the Federal Prevailing Rate Advisory Committee will be held on—
Thursday, March 12, 1992
Thursday, March 26, 1992
Thursday, April 16, 1992
Thursday, April 30, 1992
The meetings will start at 10:45 a.m. and will be held in room 5A06A, Office of Personnel Management Building, 1900 E Street NW., Washington, DC.
The Federal Prevailing Rate Advisory Committee is composed of a Chairman, representatives from five labor unions holding exclusive bargaining rights for Federal blue-collar employees, and representatives from five Federal agencies. Entitlement to membership on the Committee is provided for in 5 U.S.C. 5347.
The Committee’s primary responsibility is to review the Prevailing Rate System and other matters pertinent to establish prevailing rates under subchapter IV, chapter 53, 5 U.S.C., as amended, and from time to time advise the Office of Personnel Management.
These scheduled meetings will start in open session with both labor and management representatives attending. During the meeting either the labor members or the management members may caucus separately with the Chairman to devise strategy and formulate positions. Premature disclosure of the matters discussed in these caucuses would unacceptably impair the ability of the Committee to reach a consensus on the matters being considered and would disrupt substantially the disposition of its business. Therefore, these caucuses will be closed to the public because of a determination made by the Director of the Office of Personnel Management under the provisions of section 10(d) of the Federal Advisory Committee Act (Pub. L. 92–463) and 5 U.S.C. 552b(c)(9)(B). These caucuses may, depending on the issues involved, constitute a substantial portion of the meeting.
Annually, the Committee publishes for the Office of Personnel Management, the President, and Congress a comprehensive report of pay issues discussed, concluded recommendations, and related activities. These reports are
available to the public, upon written request to the Committee's Secretary.
The public is invited to submit material in writing to the Chairman on Federal Wage System pay matters felt to be deserving of the Committee's attention. Additional information on these meetings may be obtained by contacting the Committee's Secretary, Office of Personnel Management, Federal Prevailing Rate Advisory Committee, room 1340, 1900 E Street NW., Washington, DC 20415 (202) 606-1500.
Dated: February 14, 1992.
Anthony F. Ingrassia,
Chairman, Federal Prevailing Rate Advisory Committee.
[FR Doc. 92–4048 Filed 2–21–92; 8:45 am]
BILLING CODE 6325–01–M
SECURITIES AND EXCHANGE COMMISSION
Self-Regulatory Organizations; Applications for Unlisted Trading Privileges and of Opportunity for Hearing; Midwest Stock Exchange, Inc.
February 18, 1992.
The above named national securities exchange has filed applications with the Securities and Exchange Commission ("Commission") pursuant to section 12(f)(1)(B) of the Securities Exchange Act of 1934 and rule 12f–1 thereunder for unlisted trading privileges in the following securities:
First City Bancorp, Inc.
Common Stock, No Par Value (File No. 7–7982)
General Motors Corporation
Series C Depositary Shares (each representing ⅛ of a share of Series C Convertible Preference Stock) (File No. 7–7983)
Hemlo Gold Mines, Inc.
Common Stock, Without Par Value (File No. 7–7984)
Integon Corporation
Common Stock, $0.01 Par Value (File No. 7–7985)
North Carolina Natural Gas Corporation
Common Stock, $0.01 Par Value (File No. 7–7986)
Preferred Income Opportunity Fund, Inc.
Common Stock, $0.01 Par Value (File No. 7–7987)
Arm Financial Corporation
Common Stock, $0.002 Par Value (File No. 7–7988)
These securities are listed and registered on one or more other national securities exchange and is reported in the consolidated transaction reporting system.
Interested persons are invited to submit on or before March 10, 1992, written data, views and arguments concerning the above-referenced application. Persons desiring to make written comments should file three copies thereof with the Secretary of the Securities and Exchange Commission, 450 Fifth Street, NW., Washington, DC 20549. Following this opportunity for hearing, the Commission will approve the application if it finds, based upon all the information available to it, that the extensions of unlisted trading privileges pursuant to such application is consistent with the maintenance of fair and orderly markets and the protection of investors.
For the Commission, by the Division of Market Regulation, pursuant to delegated authority.
Jonathan G. Katz,
Secretary.
[FR Doc. 92–4151 Filed 2–21–92; 8:45 am]
BILLING CODE 8010–01–M
Self-Regulatory Organizations; Applications for Unlisted Trading Privileges and of Opportunity for Hearing; Philadelphia Stock Exchange, Inc.
February 18, 1992.
The above named national securities exchange has filed applications with the Securities and Exchange Commission ("Commission") pursuant to section 12(f)(1)(B) of the Securities Exchange Act of 1934 and rule 12f–1 thereunder for unlisted trading privileges in the following securities:
Carolina Financial Corporation
Common Stock, $0.01 Par Value (File No. 7–7989)
Identix, Inc.
Common Stock, No Par Value (File No. 7–7990)
US Alcohol Testing of America
Common Stock, $0.01 Par Value (File No. 7–7991)
Integon Corporation
Common Stock, $0.01 Par Value (File No. 7–7992)
Preferred Income Opportunity Fund, Inc.
Common Stock, $0.01 Par Value (File No. 7–7993)
Osten Corporation
Common Stock, $0.01 Par Value (File No. 7–7994)
Aydin Corporation
Common Stock, $1 Par Value (File No. 7–7995)
First Republic Bancorp
Common Stock, $0.01 Par Value (File No. 7–7996)
Bay State Gas Company
Common Stock, $3.33⅓ Par Value (File No. 7–7997)
North Carolina Natural Gas Corp.
Common Stock, $0.01 Par Value (File No. 7–7998)
These securities are listed and registered on one or more other national securities exchange and are reported in the consolidated transaction reporting system.
Interested persons are invited to submit on or before March 10, 1992, written data, views and arguments concerning the above-referenced application. Persons desiring to make written comments should file three copies thereof with the Secretary of the Securities and Exchange Commission, 450 5th Street, NW., Washington, DC 20549. Following this opportunity for hearing, the Commission will approve the application if it finds, based upon all the information available to it, that the extensions of unlisted trading privileges pursuant to such applications are consistent with the maintenance of fair and orderly markets and the protection of investors.
For the Commission, by the Division of Market Regulation, pursuant to delegated authority.
Jonathan G. Katz,
Secretary.
[FR Doc. 92–4150 Filed 2–21–92; 8:45 am]
BILLING CODE 8010–01–M
SMALL BUSINESS ADMINISTRATION
[Declaration of Economic Injury Disaster Loan Areas #7556, #7557, & #7558]
New York, et al.; Declaration of Disaster Loan Area
Westchester County and the contiguous counties of Bronx, Orange, Putnam, and Rockland in the State of New York; Bergen County in the State of New Jersey; and Fairfield County in the State of Connecticut constitute an Economic Injury Disaster Loan Area due to damages caused by a fire which occurred on December 30, 1991 at the intersection of North Avenue and Main Street in the City of New Rochelle. Eligible small businesses without credit available elsewhere and small agricultural cooperatives without credit available elsewhere may file applications for economic injury assistance until the close of business on November 12, 1992 at the address listed below: U.S. Small Business Administration, Disaster Area 1 Office, 350 Rainbow Blvd., South, 3rd Fl., Niagara Falls, NY 14303, or other locally announced locations. The interest rate for eligible small businesses and small agricultural cooperatives is 4 percent.
Notice: Due to SBA's present shortage of operating funds for the current fiscal year (through September 30, 1992), SBA cannot provide assurance of our ability to continue to accept or process disaster loan
Shortage of Operating Funds for a Disaster in Idaho
As a result of the Secretary of Agriculture's disaster designation S-566 for counties in the State of Idaho and contiguous counties in the State of Oregon, the Small Business Administration (SBA) is accepting economic injury disaster loan applications from eligible nonfarm small business concerns. However, due to SBA's present severe shortage of operating funds for the disaster program for the current fiscal year (through September 30, 1992), SBA cannot provide assurance of its ability to continue to accept or process disaster loan applications or make disbursements on disaster loans until additional funds are available.
Dated: February 12, 1992
Alfred E. Judd,
Acting Assistant Administrator for Disaster Assistance.
[FR Doc. 92–4097 Filed 2–21–92; 8:45 am]
BILLING CODE 8025–01–M
Shortage of Operating Funds for a Disaster in Kentucky
As a result of the Secretary of Agriculture's disaster designation S-564 for counties in the State of Kentucky and contiguous counties in the State of Ohio, the Small Business Administration (SBA) is accepting economic injury disaster loan applications from eligible nonfarm small business concerns. However, due to SBA's present severe shortage of operating funds for the disaster program for the current fiscal year (through September 30, 1992), SBA cannot provide assurance of its ability to continue to accept or process disaster loan applications or make disbursements on disaster loans until additional funds are available.
Dated: February 5, 1992.
Alfred E. Judd,
Acting Assistant Administrator for Disaster Assistance.
[FR Doc. 92–4098 Filed 2–21–92; 8:45 am]
BILLING CODE 8025–01–M
Notice of Shortage of Operating Funds for a Disaster in Oklahoma
As a result of the Secretary of Agriculture's disaster designation S-565 for counties in the State of Oklahoma and contiguous counties in the State of Colorado, Kansas, Missouri, and Texas, the Small Business Administration (SBA) is accepting economic injury disaster loan applications from eligible nonfarm small business concerns. However, due to SBA's present severe shortage of operating funds for the disaster program for the current fiscal year (through September 30, 1992), SBA cannot provide assurance of its ability to continue to accept or process disaster loan applications or make disbursements on disaster loans until additional funds are available.
Dated: February 5, 1992.
Alfred E. Judd,
Acting Assistant Administrator for Disaster Assistance.
[FR Doc. 92–4093 Filed 2–21–92; 8:45 am]
BILLING CODE 8025–01–M
Notice of Shortage of Operating Funds for a Disaster in Oregon
As a result of the Secretary of Agriculture's disaster designation S-567 for counties in the State of Oregon and contiguous counties in the State of Washington, the Small Business Administration (SBA) is accepting economic injury disaster loan applications from eligible nonfarm small business concerns. However, due to SBA's present severe shortage of operating funds for the disaster program for the current fiscal year (through September 30, 1992), SBA cannot provide assurance of its ability to continue to accept or process disaster loan applications or make disbursements on disaster loans until additional funds are available.
Dated: February 12, 1992.
Alfred E. Judd,
Acting Assistant Administrator for Disaster Assistance.
[FR Doc. 92–4094 Filed 2–21–92; 8:45 am]
BILLING CODE 8025–01–M
Shortage of Operating Funds for a Disaster in Washington
As a result of the Secretary of Agriculture's disaster designation S-568 for counties in the State of Washington and contiguous counties in the State of Oregon, and Small Business Administration (SBA) is accepting economic injury disaster loan applications from eligible nonfarm small business concerns. However, due to SBA's present severe shortage of operating funds for the disaster program for the current fiscal year (through
September 30, 1992), SBA cannot provide assurance of its ability to continue to accept or process disaster loan applications or make disbursements on disaster loans until additional funds are available.
Dated: February 12, 1992.
Alfred E. Judd,
Acting Assistant Administrator of Disaster Assistance.
[FR Doc. 92–4095 Filed 2–21–92; 8:45 am]
BILLING CODE 8025–01–M
Capital Corporation of America (License No. 003/03–0040); License Surrender
Notice is hereby given that Capital Corporation of America ("CCA"), 225 So. 15th Street, Philadelphia, PA 19102, has surrendered its license to operate as a small business investment company under the Small Business Investment Act of 1958, as amended ("the Act"). CCA was licensed by the Small Business Administration on March 27, 1969.
Under the authority vested by the Act and pursuant to the regulations promulgated thereunder, the surrender of the license was accepted on February 10, 1992, and accordingly, all rights, privileges, and franchises derived therefrom have been terminated.
(Catalog of Federal Domestic Assistance Program No. 59.011, Small Business Investment Companies)
Dated: February 13, 1992.
Wayne S. Foren,
Associate Administrator for Investment.
[FR Doc. 92–4091 Filed 2–21–92; 8:45 am]
BILLING CODE 8025–01–M
[License No. 07/07–0006]
MorAmerica Capital Corporation
Notice is hereby given that MorAmerica Capital Corporation (MCC), 101 Second Street, SE., suite 800, Cedar Rapids, Iowa 52401 a Federal Licensee under the Small Business Investment Act of 1958, as amended (Act), has filed an application with the Small Business Administration (SBA) pursuant to section 312 of the Act and covered by § 107.903 of SBA Rules and Regulations, for approval of a conflict of interest transaction falling within the scope of the Act and Regulations. Subject to such approval, MCC proposes to invest $350,000 in Clean Duds, Inc. (CDI), 3000 Justin Drive, Suite G, Des Moines, Iowa 50322.
The proposed financing is brought within the purview of § 107.903 of the Regulations because a majority of CDI's outstanding common stock is owned by the Iowa Venture Capital Fund (Iowa Fund) which is advised by the same entity, Investamerica Venture Group, Inc. that serves as advisor to MCC. Additionally, certain officers and directors of MCC are also officers and directors of CDI. Based on these relationships the Iowa Fund and CDI are considered associates of MCC as defined by § 107.3 of the Regulations.
As a condition to the proposed financing, the Iowa Fund will convert its present CDI voting securities into non-voting securities, will place only one director on CDI's board of directors (which will have no fewer than five members), and will not exert economic control over CDI through its investments.
Notice is hereby given that any interested person may, but not later than fifteen (15) days from the date of publication of this Notice, submit written comments on the proposed transaction to the Associate Administrator for Investment, Small Business Administration, 409 3rd Street, SW., Washington, DC 20416.
(Catalog of Federal Domestic Assistance Program No. 59.011, Small Business Investment Companies)
Dated: February 10, 1992.
Wayne S. Foren,
Associate Administrator for Investment.
[FR Doc. 92–4090 Filed 2–21–92; 8:45 am]
BILLING CODE 8025–01–M
DEPARTMENT OF TRANSPORTATION
Notice of Applications for Certificates of Public Convenience and Necessity and Foreign Air Carrier Permits Filed Under Subpart Q During the Week Ended February 14, 1992
The following Applications for Certificates of Public Convenience and Necessity and Foreign Air Carrier Permits were filed under Subpart Q of the Department of Transportation's Procedural Regulations (See 14 CFR 302.1701 et. seq.). The due date for Answers, Conforming Applications, or Motions to Modify Scope are set forth below for each application. Following the Answer period DOT may process the application by expedited procedures. Such procedures may consist of the adoption of a show-cause order, a tentative order, or in appropriate cases a final order without further proceedings.
Docket Number: 47984.
Date filed: February 12, 1992.
Due Date for Answers, Conforming Application, or Motion to Modify Scope: March 11, 1992.
Description: Application of Aero Postal De Mexico S.A. De C.V., pursuant to Section 402 of the Act and Subpart Q of the Regulations, applies for a foreign air carrier permit for authority to provide charter foreign air transportation of property and mail between any point in Mexico and any point in the United States and between any point in the United States and any point in Mexico.
Phyllis T. Kaylor,
Chief, Documentary Services Division
[FR Doc. 92–4177 Filed 2–21–92; 8:45 am]
BILLING CODE 4910–62–M
Coast Guard
[CGD 92–012]
Commercial Fishing Industry Vessel Advisory Committee
AGENCY: Coast Guard, DOT.
ACTION: Request for applications.
SUMMARY: The U.S. Coast Guard is seeking applicants for appointment to membership on the Commercial Fishing Industry Vessel Advisory Committee (CFIVAC) established by the Coast Guard as required by the Commercial Fishing Industry Vessel Safety Act of 1988. The Committee acts in an advisory capacity to the Secretary of Transportation and the Commandant of the Coast Guard on matters related to the safety of commercial fishing vessels.
The Applications will be considered for five (5) expiring terms. The Committee consists of 17 members as follows: Ten (10) members from the commercial fishing industry who reflect a regional and representational balance and have experience in the operation of vessels to which chapter 45 of title 46, United States Code applies, or as a crew member or processing line worker on an uninspected fish processing vessel; one (1) member representing naval architects or marine surveyors; one (1) member representing manufacturers of equipment for vessels to which chapter 45 applies; one (1) member representing education or training professionals related to fishing vessel, fish processing vessel, or fish tender vessel safety, or personnel qualifications; one (1) member representing underwriters that insure vessels to which chapter 45 applies; and three (3) members representing the general public, including whenever possible, an independent expert or consultant in maritime safety and a member of a national organization composed of persons representing owners of vessels to which chapter 45 applies and persons representing the
marine insurance industry. Terms are expiring in the following categories: (a) Fishing Industry (three positions); (b) General Public (one position); and (c) Equipment Manufacturers (one position). The membership term is three years. A limited portion of the membership may serve consecutive terms. Those persons that have submitted applications in the past must reapply. No applications received prior to this solicitation will be considered.
To achieve the balance of membership required by the Federal Advisory Committee Act, the Coast Guard is especially interested in receiving applications from minorities and women. The members of the Committee serve without compensation from the Federal Government, although travel reimbursement and per diem is provided. The Committee normally meets in Washington, DC, with subcommittee meetings for specific problems on an as-required basis.
DATES: Applications should be received no later than 31 May 1992. Application forms may be obtained by contacting the Executive Director at the address below.
ADDRESSES: Persons interested in applying should write to Commandant (G–MVI–4), room 1405, U.S. Coast Guard Headquarters, 2100 Second St., SW., Washington, DC 20593–0001.
FOR FURTHER INFORMATION CONTACT: LCDR Ed McCauley, Executive Director, Commercial Fishing Industry Vessel Advisory Committee (CFIVAC), room 1405, U.S. Coast Guard Headquarters, 2100 Second St., SW., Washington, DC, 20593–0001, (202) 267–2307.
Dated: February 13, 1992.
R. C. North,
Captain, U.S. Coast Guard, Acting Chief, Office of Marine Safety, Security and Environmental Protection.
[FR Doc. 92–4131 Filed 2–21–92; 8:45 am]
BILLING CODE 4910–14–M
[CGD–92–011]
Public Hearing; Florida Avenue Bridge Across the Inner Harbor Navigation Canal in New Orleans, LA
AGENCY: Coast Guard, DOT.
ACTION: Notice of public hearing.
SUMMARY: Notice is hereby given that the Commandant has authorized a public hearing to be held by the Commander, Eighth Coast Guard District, at New Orleans, Louisiana. The purpose for the hearing is to provide an opportunity to all interested persons to present data, views and comments orally or in writing concerning the alteration of the highway/railroad bridge across the Inner Harbor Navigation Canal in New Orleans, Louisiana.
DATES: March 25, 1992, commencing at 7 p.m., until all speakers in attendance wishing to comment have been heard.
ADDRESSES: The hearing will be held at the Versailles Room, Hilton Hotel, Third Floor, Two Poydras Street at the Mississippi River, New Orleans, Louisiana.
FOR FURTHER INFORMATION CONTACT: Mr. Perry Haynes, Eighth Coast Guard District, Hale Boggs Federal Building, 501 Magazine Street, New Orleans, Louisiana 70130–3396, (504) 589–2965.
SUPPLEMENTARY INFORMATION: The information presented will be used by the Coast Guard to determine if the Florida Avenue Bridge constitutes an unreasonable obstruction to navigation, eligible for Federal participating funds for alterations under the Truman-Hobbs Act (act of June 21, 1940, as amended; Stat. 497; 33 U.S.C. 511 et seq.) and if so, what alterations are needed to render navigation through the bridge relatively free and unobstructed. All interested parties shall have full opportunity to be heard and to present evidence as to what alterations are needed; giving due consideration to the necessities of rail traffic and environmental concerns. Of particular concern are the effects that a low-level, vertical lift span bridge with a vertical clearance of 156 feet above mean high tide in the raised position, and a horizontal clearance of 300 feet, would have on existing and prospective navigation using the Inner Harbor Navigation Canal.
Any person may appear and be heard at this public hearing. Persons planning to appear and be heard are requested to notify the Commander, Eighth Coast Guard District, Bridge Administration Branch, Hale Boggs Federal Building, 501 Magazine Street, New Orleans, Louisiana 70130–3396, (504) 589–2965, any time prior to the hearing indicating the amount of time needed. Depending upon the number of scheduled statements, it may be necessary to limit the amount of time allocated to each person. Any limitation of time allocated will be announced at the beginning of the hearing. Written statements and exhibits may be submitted in place of, or in addition to, oral statements. Written statements and exhibits will be made part of the hearing record. Written statements and exhibits may be delivered at the hearing or mailed in advance to the Commander, Eighth Coast Guard District, at the above address. Transcripts of the hearing may be ordered for purchase upon request to the court reporting service at the conclusion of the hearing.
(33 U.S.C. 513; 33 CFR 116.20)
W.J. Ecker,
Rear Admiral, U.S. Coast Guard, Chief, Office of Navigation Safety and Waterway Services.
[FR Doc. 92–4132 Filed 2–21–92; 8:45 am]
BILLING CODE 4910–14–M
Federal Aviation Administration
Research, Engineering, and Development Advisory Committee
Pursuant to section 10(A)(2) of the Federal Advisory Committee Act (public law 92–362; 5 U.S.C. app. I), notice is hereby given of a meeting of the Federal Aviation Administration (FAA) Research, Engineering, and Development (R, E&D) Advisory Committee to be held Monday, March 16, at 10 a.m. The meeting will take place at the Federal Aviation Administration, 800 Independence Avenue, SW., Washington, DC, in the MacCracken Room on the tenth floor.
The agenda for this meeting will include a report on the findings of the Runway Incursion Working Group to the full committee. In addition, the committee will receive an overview of the recently established RTCA GNSS Task Force effort, and be provided an update on the status of the current R, E&D Plan and Budget activities.
Attendance is open to the interested public but limited to space available. With the approval of the Chairman, members of the public may present oral statements at the meeting. Persons wishing to present oral statements, obtain information, or plan to access the building to attend the meeting should contact Ms. Jan Peters, Special Assistant to the Executive Director of the R, E&D Advisory Committee, ASD–6, 800 Independence Avenue, SW., Washington, DC 20591, telephone (202) 267–3096.
Any member of the public may present a written statement to the Committee at any time.
Issued in Washington, DC, on February 18, 1992.
Martin T. Pozesky,
Executive Director, Research, Engineering, and Development Advisory Committee.
[FR Doc. 92–4122 Filed 2–21–92; 8:45 am]
BILLING CODE 4910–14–M
Memphis International Airport, Memphis, TN; Intent To Rule on Application
AGENCY: Federal Aviation Administration, DOT.
ACTION: Notice of intent to rule on application to impose a passenger facility charge (PFC) at Memphis International Airport, Memphis, Tennessee.
SUMMARY: The Federal Aviation Administration (FAA) proposes to rule and invites public comment on the application to impose a PFC at Memphis International Airport under the provisions of the Aviation Safety and Capacity Expansion Act of 1990 (Title IX of the Omnibus Budget Reconciliation Act of 1990) (Public Law 101–508) and 14 CFR part 158.
On February 11, 1992, the FAA determined that the application to impose a PFC submitted by Memphis-Shelby County Airport Authority was substantially complete within the requirements of § 158.25 of part 158. The FAA will approve or disapprove the application, in whole or in part, no later than May 27, 1992.
DATES: Comments must be received on or before March 25, 1992.
ADDRESSES: Comments on this application may be mailed or delivered in triplicate to the FAA at the following address: Memphis Airports District Office; 2851 Directors Cove, Suite #3; Memphis, Tennessee 38131–0301.
In addition, one copy of any comments submitted to the FAA must be mailed or delivered to Mr. Jerry L. McMichael, Executive Vice President, Finance and Administration of the Memphis-Shelby County Airport Authority at the following address: Memphis International Airport, P.O. Box 30168, Memphis, Tennessee 38130–0168.
Comments from air carriers and foreign air carriers may be in the same form as provided to the Memphis-Shelby County Airport Authority under § 158.23 of part 158.
FOR FURTHER INFORMATION CONTACT: Mr. Jerry O. Bowers, Planner, Memphis Airport District Office; 2851 Directors Cove, Suite #3; Memphis, Tennessee 38131–0301; Telephone: (901) 544–3495. The application may be reviewed in person at this same location.
SUPPLEMENTARY INFORMATION: The following is a brief overview of the application.
Level of the proposed PFC: $3.00
Proposed charge effective date: November 1, 1992
Proposed charge expiration date: May 1, 1998
Total estimated PFC revenue: $62,700,000
Brief description of proposed project(s):
(1) Land Acquisition, Roadways, and Utilities
(2) Construct A Third Parallel Runway 18E–36E
(3) Reconstruct and Extend Runway 18L–36R
(4) Construct Extension of Taxiway “A” and Other Projects
AVAILABILITY OF APPLICATION: Any person may inspect the application in person at the FAA office listed above. In addition, any person may, upon request, inspect the application, notice and other documents germane to the application in person at the Memphis-Shelby County Airport Authority.
Issued in Atlanta, Georgia on February 11, 1992.
Dell Jernigan,
Acting Manager, Airports Division Southern Region.
[FR Doc. 92–4141 Filed 2–21–92; 8:45 am]
BILLING CODE 4910–13–M
Federal Highway Administration
Environmental Impact Statement: Davis and Weber Counties, Utah
AGENCY: Federal Highway Administration (FHWA), DOT.
ACTION: Revised notice of intent.
SUMMARY: The FHWA is issuing this notice to advise the public of an expansion to the study area for an environmental impact statement (EIS) which is being prepared for a proposed highway project in Davis and Weber Counties, Utah.
FOR FURTHER INFORMATION CONTACT: Tom Allen, U.S. Department of Transportation, Federal Highway Administration, 2520 West 4700 South, suite 9A, Salt Lake City, Utah, 84118, Telephone: (801) 524–5143; R. James Naegle, Utah Department of Transportation, 4501 South, 2700 West, Salt Lake City, Utah, 84119, Telephone (801) 965–4160; or Lynn Zollinger, Utah Department of Transportation, District One Office, P.O. Box 12580, 169 Wall Avenue, Ogden, Utah, 84404, Telephone (801) 399–5921.
SUPPLEMENTARY INFORMATION: The FHWA, in cooperation with Utah Department of Transportation, will prepare an EIS on a proposal to improve the US–89 Highway from I–15 Interchange to the I–84 interchange with an extension to Harrison Boulevard for a total distance of approximately 12.9 miles.
Improvements to the corridor are considered necessary to provide for the existing and projected traffic demand, and increased safety measures. Alternatives under consideration include: (1) A "No Action" alternative, (2) A low-cost Transportation System Management alternative (intersection improvements, traffic signal installation and coordination, etc.), (3) Mass transit, (4) Signalized expressway, (5) Limited access expressway, (6) Freeway, (7) A combination of alternatives. Incorporated into and studied with the build alternatives will be alignment and grade variations which would provide for mitigation in sensitive areas.
Letters describing the proposed action and soliciting comments will be sent to appropriate Federal, State, and local agencies, and to private organizations and citizens who have previously expressed or are known to have an interest in this proposal. A series of informational public meetings will be held as necessary during the project development process. A formal scoping meeting and an official public hearing will also be held. Public notice of the time and place of the meetings and hearing will be given. The draft EIS will be available for public and agency review and comment prior to the public hearing.
To ensure that full range of issues related to this proposed action are addressed and all significant issues identified, comments and suggestions are invited from all interested parties. Comments or questions concerning this proposed action and the EIS should be directed to the FHWA at the address provided above.
(Catalog of Federal Domestic Assistance Program Number 20.205, Highway Planning and Construction. The regulations implementing Executive Order 12372 regarding intergovernmental consultation on Federal programs and activities apply to this program.)
Issued on: February 12, 1992.
Donald P. Steinke,
Division Administrator, Salt Lake City, Utah.
[FR Doc. 92–4138 Filed 2–21–92; 8:45 am]
BILLING CODE 4910–22–M
Environmental Impact Statement: Ketchikan Gateway Borough, AK
AGENCY: Federal Highway Administration (FHWA), DOT.
ACTION: Notice of intent.
SUMMARY: The FHWA is issuing this notice to advise the public that an environmental impact statement will be prepared for a proposed highway project
in the Ketchikan Gateway Borough, Alaska.
FOR FURTHER INFORMATION CONTACT: Steve Moreno, Field Operations Engineer, Federal Highway Administration, Alaska Division, P.O. Box 21648, Juneau, Alaska, 99802-1648. Telephone: (907) 586-7428; or: Andy Hughes, Transportation Planner, Alaska Department of Transportation and Public Facilities, SE. Region Planning, 6860 Glacier Highway, Juneau, Alaska, 99801-7999. Telephone: (907) 789-6230.
SUPPLEMENTARY INFORMATION: The Alaska Department of Transportation and Public Facilities, using professional consultant services, will prepare an environmental impact statement (EIS) on a proposal to bridge the Tongass Narrows to connect Ketchikan to the Ketchikan International Airport located on Gravina Island. The proposed improvement would involve constructing two major bridge structures and approximately 4.5 miles of new highway connecting Revillagigedo, Pennock, and Gravina Islands to provide a highway between Ketchikan and its airport. Tongass Narrows is a deep water shipping channel.
The proposed improvements are considered necessary to provide adequate access between Ketchikan and its airport. Current access is provided by an airport shuttle ferry. The ferry carries passengers, luggage, freight, and vehicles. The ferry periodically reaches capacity and occasionally is out of service due to vessel and shore facility break-downs of equipment. The airport shuttle ferry system presents both an inconvenience to the traveling public and an economic deterrent to development of the airport and development of lands on Pennock and Gravina Islands. Alternatives under consideration include (1) taking no action, (2) improving the ferry system, (3) constructing a bridge in one of several alternate locations along the Tongass Narrows with or without a connection to Pennock Island, and (4) constructing a tube under the channel in one of several locations.
A scoping newsletter and letters describing the proposed action and soliciting comments will be sent to appropriate federal, state, and local agencies, and to private organizations and citizens who have previously expressed or are known to have interest in this proposal. A scoping meeting with state and federal resource agencies in Juneau, Alaska and a public scoping workshop/meeting in Ketchikan, Alaska will be held in March 1992. The scoping process is intended to insure that the full range of issues related to this proposed action are identified and addressed. Comments and suggestions are invited from all interested parties. Comments or questions concerning this proposed action and the EIS should be directed to the FHWA at the address provided above.
(Catalog of Federal Domestic Assistance Program Number 20.205, Highway Planning and Construction. The regulations implementing Executive Order 12372 regarding intergovernmental consultation of Federal programs and activities apply to this program.)
Issued on: February 7, 1992.
Robert E. Ruby,
Division Administrator, Alaska Division.
[FR Doc. 92–4116 Filed 2–21–92; 8:45 am]
BILLING CODE 4910–22–M
Environmental Impact Statement: Weber County, UT
AGENCY: Federal Highway Administration (FHWA), DOT.
ACTION: Revised notice of intent.
SUMMARY: The FHWA is issuing this notice to advise the public that an environmental impact statement (EIS) will not be prepared for the proposed highway project in Weber County, Utah.
FOR FURTHER INFORMATION CONTACT: Tom Allen, U.S. Department of Transportation, Federal Highway Administration, 2520 West 4700 South, suite 9A, Salt Lake City, Utah 84118, Telephone: (801) 524–5143; R. James Naegle, Utah Department of Transportation, 4501 South 2700 West, Salt Lake City, Utah 84119, Telephone (801) 965–4160; or Lynn Zollinger, Utah Department of Transportation, District One Office, P.O. Box 12580, 169 Wall Avenue, Ogden, Utah 84404, Telephone (801) 399–5921.
SUPPLEMENTARY INFORMATION: The FHWA, in cooperation with Utah Department of Transportation, have determined that an EIS will not be prepared for the proposed project to improve 36th Street from Wall Avenue to Harrison Boulevard for a distance of approximately 1.61 miles.
Improvements being considered will not have significant impacts on the environment. The original concept to provide a four lane section and remove residences and businesses along one side of the street is no longer being considered. An environmental assessment is currently being prepared to evaluate the project impacts.
(Catalog of Federal Domestic Assistance Program Number 20.205, Highway Planning and Construction. The regulations implementing Executive Order 12372 regarding intergovernmental consultation on Federal programs and activities apply to this program.)
Issued on: February 12, 1991.
Donald P. Steinke,
Division Administrator, Salt Lake City, Utah.
[FR Doc. 92–4137 Filed 2–21–92; 8:45 am]
BILLING CODE 4910–22–M
DEPARTMENT OF THE TREASURY
Public Information Collection Requirements Submitted to OMB for Review
Date: February 18, 1992.
The Department of Treasury has submitted the following public information collection requirement(s) to OMB for review and clearance under the Paperwork Reduction Act of 1980, Public Law 96–511. Copies of the submission(s) may be obtained by calling the Treasury Bureau Clearance Officer listed. Comments regarding this information collection should be addressed to the OMB reviewer listed and to the Treasury Department Clearance Officer, Department of the Treasury, room 3171 Treasury Annex, 1500 Pennsylvania Avenue, NW., Washington, DC 20220.
Internal Revenue Service
OMB Number: 1545–0043.
Form Number: IRS Form 972.
Type of Review: Extension.
Title: Consent of Shareholder to Include Specific Amount in Gross Income.
Description: Form 972 is filed by shareholders of corporations to elect to include an amount in gross income as a dividend. IRS uses Form 972 as check to see if an amended return is filed to include the amount in income and to determine if the corporation claimed the correct amount.
Respondents: Individuals or households. Businesses or other for-profit.
Estimated Number of Respondents/Recordkeepers: 400.
Estimated Burden Hours Per Respondent/Recordkeeper:
Recordkeeping—13 minutes
Learning about the law or the form—3 minutes
Preparing the form—14 minutes
Copying, assembling, and sending the form to IRS—31 minutes
Frequency of Response: On occasion.
Estimated Total Reporting/Recordkeeping Burden: 408 hours.
OMB Number: 1545–0991.
Form Number: IRS Form 8633.
Type of Review: Revision.
Title: Application to Participate in the Electronic Filing Program.
Description: Form 8633 will be used by tax preparers, electronic return collectors, software firms, and electronic transmitters, as an application to participate in the electronic filing program covering individual income tax returns.
Respondents: Businesses or other for-profit. Non-profit institutions.
Estimated Number of Respondents: 30,000.
Estimated Burden Hours Per Respondent: 45 minutes.
Frequency of Response: Annually.
Estimated Total Reporting Burden: 22,500 hours.
OMB Number: 1545–1151.
Form Number: IRS Form 8818.
Type of Review: Extension.
Title: Optional Form to Record Redemption of College Savings Bonds.
Description: If an individual redeems U.S. Savings Bonds issued after 1989 and pays qualified higher education expenses during the year, the interest on the bonds is excludable from income. The form can be used by the individual to keep a record of the bonds cashed so that he or she can claim the proper interest exclusion.
Respondents: Individuals or households.
Estimated Number of Respondents/Recordkeepers: 50,000.
Estimated Burden Hours Per Respondent/Recordkeeper:
Recordkeeping—7 minutes
Learning about the law or the form—3 minutes
Preparing the form—17 minutes
Frequency of Response: On occasion.
Estimated Total Reporting Burden: 21,500 hours.
Clearance Officer: Garrick Shear (202) 535–4297, Internal Revenue Service, room 5571, 1111 Constitution Avenue, NW., Washington, DC 20224.
OMB Reviewer: Milo Sunderhauf (202) 395–6880, Office of Management and Budget, room 3001, New Executive Office Building, Washington, DC 20503
Lois K. Holland,
Departmental Reports, Management Officer.
[FR Doc. 92–4146 Filed 2–21–92; 8:45 am]
BILLING CODE 4830–01–M
United States Customs Service
[T.D. 92–15]
Extension of Comsource American, Inc.’s Customs Approval and Accreditations to Include a New Facility
AGENCY: U.S. Customs Service, Department of the Treasury.
ACTION: Notice of the extension of Comsource American, Inc.’s Customs approval and accreditations to include gauging and laboratory testing performed at a new facility.
SUMMARY: Comsource American, Inc., of Pasadena, Texas, a Customs accredited commercial laboratory and approved gauger under § 151.13 of the Customs Regulations (19 CFR 151.13), has been given an extension of its approval and accreditations at its new Kenilworth, New Jersey facility to include the gauging of petroleum and petroleum products, organic chemicals in bulk and in liquid form and vegetable oils; and the performance of the following analyses: API Gravity, sediment and water, antiknock index, distillation characteristics, Reid Vapor Pressure, Saybolt Universal Viscosity, sediment by extraction, percent by weight sulfur in petroleum products, percent by weight lead in gasoline, identity of organic compounds using common or IUPAC nomenclature and composition giving percent by weight of each component.
SUPPLEMENTARY INFORMATION: Part 151 of the Customs Regulations provides for the acceptance at Customs Districts of Laboratory analyses and gauging reports for certain products from Customs accredited commercial laboratories and approved gaugers. Comsource American, Inc., which holds Customs accreditation in certain laboratory analyses and Customs approval to gauge certain products, has applied to Customs to extend its laboratory accreditation and gauging approval in the manner described above. Review of Comsource American, Inc.’s qualifications shows that the extension is warranted and, accordingly, has been granted.
EFFECTIVE DATE: February 12, 1992.
FOR FURTHER INFORMATION CONTACT: Ira S. Reese, Special Assistant for Commercial and Tariff Affairs, Office of Laboratories and Scientific Services, U.S. Customs Service, 1301 Constitutional Ave. NW., Washington, DC 20229 (202–566–2446).
Dated: February 18, 1992.
John B. O’Loughlin,
Director, Office of Laboratories and Scientific Services.
[FR Doc. 92–4154 Filed 2–21–92; 8:45 am]
BILLING CODE 4820–02–M
[T.D. 92–18]
Recordation of Trade Name: “Grand Tea Company”
AGENCY: U.S. Customs Service, Department of the Treasury.
ACTION: Notice of recordation.
SUMMARY: On December 2, 1991, a notice of application for the recordation under section 42 of the Act of July 5, 1946, as amended (15 U.S.C. 1124), of the trade name “Grand Tea Company,” was published in the Federal Register (56 FR 61278). The notice advised that before final action was taken on the application, consideration would be given to any relevant data, views, or arguments submitted in writing by any person in opposition to the recordation and received not later than January 31, 1992. No responses were received in opposition to the notice. Accordingly, as provided in § 133.14, Customs Regulations (19 CFR 133.14), the name “Grand Tea Company,” is recorded as the trade name used by Thomas Li Ka Cheung, a citizen of Hong Kong with an address at 353 Queen’s Road Central, Hong Kong.
The trade name is used in connection with tea. The merchandise is manufactured in Hong Kong.
EFFECTIVE DATE: February 24, 1992.
FOR FURTHER INFORMATION CONTACT: Robert L. Knapp, Intellectual Property Rights Branch, 1301 Constitution Avenue, NW., Washington, DC 20229 (202 266–6956).
Dated: February 18, 1992.
John F. Atwood,
Chief, Intellectual Property Rights Branch.
[FR Doc. 92–4124 Filed 2–21–92; 8:45 am]
BILLING CODE 4820–02–M
DEPARTMENT OF VETERANS AFFAIRS
Information Collection Under OMB Review
AGENCY: Department of Veterans Affairs.
ACTION: Notice.
The Department of Veterans Affairs has submitted to OMB the following proposal for the collection of information under the provisions of the Paperwork Reduction Act (44 U.S.C. chapter 35). This document lists the following information: (1) The title of the information collection, and the Department form number(s), if applicable; (2) a description of the need and its use; (3) who will be required or asked to respond; (4) an estimate of the total annual reporting hours, and recordkeeping burden, if applicable; (5) the estimated average burden hours per respondent; (6) the frequency of response; and (7) an estimated number of respondents.
ADDRESSES: Copies of the proposed information collection and supporting documents may be obtained from Patti Viers, Records Management Service (723), Department of Veterans Affairs, 810 Vermont Avenue, NW., Washington, DC 20420 (202) 233–3172.
Comments and questions about the items on the list should be directed to VA’s OMB Desk Officer, Joseph Lackey, NEOB, room 3002, Washington, DC 20503, (202) 395–7316. Do not send requests for benefits to this address.
DATES: Comments on the information collection should be directed to the OMB Desk Officer by March 25, 1992.
Dated: February 14, 1992.
By direction of the Secretary.
Frank E. Lalley,
Associate Deputy, Assistant Secretary for Information Resources Policies and Oversight.
Extension
1. Application for Standard Government Monument, VA Form 40–1330.
2. The form is used to apply for a Government provided headstone or marker for unmarked graves of eligible deceased veterans and their dependents. The information is used to evaluate an applicant’s claim for the benefit.
3. Individuals or households.
4. 80,000 hours.
5. 15 minutes.
6. On occasion.
7. 320,000 respondents.
[FR Doc. 92–2. 4117 Filed 2–21–92; 8:45 am]
BILLING CODE 6320–01–M
Sunshine Act Meetings
This section of the FEDERAL REGISTER contains notices of meetings published under the "Government in the Sunshine Act" (Pub. L. 94-409) 5 U.S.C. 552b(e)(3).
BLACKSTONE RIVER VALLEY NATIONAL HERITAGE CORRIDOR COMMISSION
Correction of Meeting Notice.
Notice is hereby given in accordance with Section 552b of Title 5, United States Code, that a meeting of the Blackstone River Valley National Heritage Corridor Commission will be held on Monday, March 2, 1992 to be held at 4 p.m. rather than the earlier announced time of 7 p.m. at the North Smithfield Congregational Church, On The Common, North Smithfield, RI rather than at the N. Smithfield Public Library as posted earlier.
The Commission was established pursuant to Public Law 99-647. The purpose of the Commission is to assist federal, state and local authorities in the development and implementation of an integrated resource management plan for those lands and waters within the Corridor.
The meeting will convene at 4:00 p.m. at the North Smithfield Congregational Church, on the Common, North Smithfield, RI for the following reasons:
1. To Review and Approve Demonstration Projects
This meeting was changed to a different location and time to accommodate the interest of a larger number of the general public than originally anticipated. It is anticipated that about fifty people will be able to attend the session in addition to the Commission members.
Interested persons may make oral or written presentations to the Commission or file written statements. Such requests should be made prior to the meeting to: James Pepper, Executive Director, Blackstone River Valley National Heritage Corridor Commission, P.O. Box 34, Uxbridge, MA 01569. Telephone: (508) 278-9400.
Further information concerning this meeting may be obtained from James Pepper, Executive Director of the Commission at the address below.
Nancy L. Brittain,
Acting Director, Blackstone River Valley National Heritage Corridor Commission.
[FR Doc. 92-4286 Filed 2-20-92; 3:17 pm]
BILLING CODE 4310-70-M
COMMODITY FUTURES TRADING COMMISSION
TIME AND DATE: 10:00 a.m., Wednesday, March 4, 1992.
PLACE: 2033 K St., NW., Washington, DC, Lower Lobby Hearing Room.
STATUS: Open.
MATTERS TO BE CONSIDERED:
Application for designation as a contract market in Natural Gas Options/New York Mercantile Exchange
CONTACT PERSON FOR MORE INFORMATION: Jean A. Webb, 254-6314.
Jean A. Webb,
Secretary of the Commission.
[FR Doc. 92-4287 Filed 2-20-92; 3:49 pm]
BILLING CODE 6351-01-M
COMMODITY FUTURES TRAINING COMMISSION
TIME AND DATE: 11:00 a.m., Friday, March 20, 1992.
PLACE: 2033 K St., NW., Washington, DC, 8th Floor Hearing Room.
STATUS: Closed.
MATTERS TO BE CONSIDERED:
Surveillance Matters.
CONTACT PERSON FOR MORE INFORMATION: Jean A. Webb, 254-6314.
Jean A. Webb,
Secretary of the Commission.
[FR Doc. 92-4296 Filed 2-20-92; 3:49 pm]
BILLING CODE 6351-01-M
COMMODITY FUTURES TRAINING COMMISSION
TIME AND DATE: 10:30 a.m., Wednesday, March 4, 1992.
PLACE: 2033 K St., NW., Washington, DC, 8th Floor Hearing Room.
STATUS: Closed.
MATTERS TO BE CONSIDERED:
Enforcement Matters.
CONTACT PERSON FOR MORE INFORMATION: Jean A. Webb, 254-6314.
Jean A. Webb,
Secretary of the Commission.
[FR Doc. 92-4295 Filed 2-20-92; 3:49 pm]
BILLING CODE 6351-01-M
COMMODITY FUTURES TRAINING COMMISSION
TIME AND DATE: 11:00 a.m., Friday, March 6, 1992.
PLACE: 2033 K St., NW., Washington, DC, 8th Floor Hearing Room.
STATUS: Closed.
MATTERS TO BE CONSIDERED:
Surveillance Matters.
CONTACT PERSON FOR MORE INFORMATION: Jean A. Webb, 254-6314.
Jean A. Webb,
Secretary of the Commission.
[FR Doc. 92-4298 Filed 2-20-92; 3:49 pm]
BILLING CODE 6351-01-M
COMMISSION ON CIVIL RIGHTS
February 20, 1992.
DATE AND TIME: Friday, February 28, 1992.
PLACE: 26 Federal Plaza, Room 305C, New York, New York.
STATUS: Open to the Public.
February 28, 1992
I. Approval of Agenda
II. Approval of Minutes of January Meeting and February Telephonic Meeting
III. Announcements
IV. Determination of Next Hearing Site
V. Staff Director's Report
Presentation and Review of Hearing Manual
VI. Review of 1992 Commission Meeting Dates
VII. Future Agenda Items
CONTACT PERSON FOR MORE INFORMATION: Barbara Brooks, Press and Communications, (202) 376–8312.
Emma Monroe,
Solicitor.
[FR Doc. 92–4293 Filed 2–20–92; 3:37 pm]
BILLING CODE 8335–01–M
FEDERAL DEPOSIT INSURANCE CORPORATION
Notice of Agency Meeting.
Pursuant to the provisions of the "Government in the Sunshine Act" (5 U.S.C. 552b), notice is hereby given that at 1:47 p.m. on Wednesday, February 19, 1992, the Board of Directors of the Federal Deposit Insurance Corporation met in closed session to consider matters relating to the probable failure of certain insured banks.
In calling the meeting, the Board determined, on motion of Director C.C. Hope, Jr. (Appointive), seconded by Director T. Timothy Ryan, Jr. (Office of Thrift Supervision), concurred in by Vice Chairman Andrew C. Hove, Jr., and Chairman William Taylor, that Corporation business required its consideration of the matters on less than seven days' notice to the public; that no earlier notice of the meeting was practicable; that the public interest did not require consideration of the matters in a meeting open to public observation; and that the matters could be considered in a closed meeting by authority of subsections (c)(4), (c)(6), (c)(8), (c)(9)(A)(ii), and (c)(9)(B) of the "Government in the Sunshine Act" (5 U.S.C. 552b(c)(4), (c)(6), (c)(8), (c)(9)(A)(ii), and (c)(9)(B)).
The meeting was held in the Board Room of the FDIC Building located at 550—17th Street, NW., Washington, DC.
Dated: February 19, 1992.
Federal Deposit Insurance Corporation.
Robert E. Feldman,
Deputy Executive Secretary.
[FR Doc. 92–4208 Filed 2–19–92; 4:54 pm]
BILLING CODE 6714–0–M
FEDERAL MINE SAFETY AND HEALTH REVIEW COMMISSION
February 19, 1992.
TIME AND DATE: 10:00 a.m., Thursday, February 27, 1992.
PLACE: Room 600, 1730 K Street, NW., Washington, DC.
STATUS: Open.
MATTERS TO BE CONSIDERED: The Commission will hear oral argument on the following:
1. Consolidation Coal Company, Docket No. WEVA 89–234–R, etc. (Issues include whether the judge erred in concluding that (i) 30 CFR § 50.30–1(g)(3) is a valid, enforceable regulation; (ii) Consolidation violated the regulation; and (iii) civil penalties may be assessed for the violations.)
Any person attending this hearing who requires special accessibility features and/or auxiliary aids, such as sign language interpreters, must inform the Commission in advance of those needs. Subject to 29 CFR § 2706.150(a)(3) and § 2706.160(e).
TIME AND DATE: Immediately following oral argument.
STATUS: Closed [Pursuant to 5 U.S.C. § 552b(c)(10)].
MATTERS TO BE CONSIDERED: The Commission will consider and act upon the following:
1. Consolidation Coal Company, Docket No. WEVA 89–234–R, etc. (See Oral Argument listing)
It was determined by a unanimous vote of Commissioners that this meeting be held in closed session.
CONTACT PERSON FOR MORE INFORMATION: Jean Ellen (202) 653–5829/(202) 708–9300 for TDD Relay, 1–800–877–8339 for toll free.
Jean H. Ellen,
Agenda Clerk.
[FR Doc. 92–4276 Filed 2–20–92; 3:15 pm]
BILLING CODE 6735–01–M
FEDERAL RESERVE SYSTEM BOARD OF GOVERNORS
"FEDERAL REGISTER" CITATION OF PREVIOUS ANNOUNCEMENT: Notice to be published in the Federal Register on Friday, February 21, 1992.
PREVIOUSLY ANNOUNCED TIME AND DATE OF THE MEETING: 10:00 a.m., Wednesday, February 28, 1992.
CHANGES IN THE MEETING: The open meeting has been canceled.
CONTACT PERSON FOR MORE INFORMATION: Mr. Joseph R. Coyne, Assistant to the Board; (202) 452–3204.
Dated: February 20, 1992.
Jennifer J. Johnson,
Associate Secretary of the Board.
[FR Doc. 92–4261 Filed 2–20–92; 1:28 pm]
BILLING CODE 6210–01–M
LEGAL SERVICES CORPORATION BOARD OF DIRECTORS REAUTHORIZATION COMMITTEE MEETING OF MARCH 9, 1992
Notice.
TIME AND DATE: A meeting of the Board of Directors Reauthorization Committee will be held on March 9, 1992. The meeting will commence at 8:30 a.m.
PLACE: The Washington Marriott Hotel, 1221 22nd Street, NW., The Dupont Ballroom, Washington, DC 20037, (202) 872–1500.
STATUS OF MEETING: Open.
MATTERS TO BE CONSIDERED:
1. Approval of Agenda.
2. Approval of Minutes of February 17, 1992 Meeting.
3. Public Comment Regarding Inspector General's February 17, 1992 Comments On Proposed Reauthorization Legislation for the Corporation.
4. Staff Comment Regarding Proposed Reauthorization Legislation for the Corporation.
5. Consideration of Comments of the Inspector General Regarding Proposed Reauthorization Legislation for the Corporation.
6. Consideration of Proposed Reauthorization Legislation for the Legal Services Corporation.
CONTACT PERSON FOR INFORMATION:
Members of the public wishing to comment on the above-referenced matter are asked to contact Patricia Batie at (202) 863-1839 not later than February 28, 1992.
Date Issued: February 20, 1992.
Patricia D. Batie,
Corporate Secretary.
[FR Doc. 92-4285 Filed 2-20-92; 3:16 pm]
BILLING CODE 7050-01-M
NATIONAL LABOR RELATIONS BOARD
Notice of Meeting.
TIME AND DATE: 9:30 a.m., Thursday, February 20, 1992.
PLACE: Board Conference Room, Sixth Floor, 1717 Pennsylvania Avenue, NW., Washington, DC 20570.
STATUS: Closed to public observation pursuant to 5 U.S.C. Section 552b(c)(2) (internal personnel rules and practices) and c(10) (adjudicatory matters).
MATTERS CONSIDERED:
Personnel Matters
CONTACT PERSON FOR MORE INFORMATION: John C. Truesdale, Executive Secretary, National Labor Relations Board, Washington, DC 20570. Telephone: (202) 254-9430.
Dated, Washington, DC, February 18, 1992.
By direction of the Board:
John C. Truesdale,
Executive Secretary, National Labor Relations Board.
[FR Doc. 92-4207 Filed 2-19-92; 4:53 pm]
BILLING CODE 7445-01-M
Corrections
This section of the FEDERAL REGISTER contains editorial corrections of previously published Presidential, Rule, Proposed Rule, and Notice documents. These corrections are prepared by the Office of the Federal Register. Agency prepared corrections are issued as signed documents and appear in the appropriate document categories elsewhere in the issue.
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
21 CFR Part 106
[Docket No. 87N-0402]
Infant Formula Record and Record Retention Requirements
Correction
In rule document 91-30716 beginning on page 66566 in the issue of Tuesday, December 24, 1991, make the following corrections:
1. On page 66566, in the third column, in the SUMMARY, in the next to last line, "wholesale," should read "wholesome."
2. On page 66569, in the third column, in the third line, "regulatory" should read "regularly."
BILLING CODE 1505-01-D
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
21 CFR Part 520
Oral Dosage Form New Animal Drugs Not Subject to Certification; Prednisolone Tablets
Correction
In rule document 92-2985 beginning on page 4718 in the issue of Friday, February 7, 1992, make the following correction:
PART 520—[CORRECTED]
On page 4718, in the third column, under PART 520, in the Authority:, in the second line, "(21 U.S.C. 36b)." should read "(21 U.S.C. 360b)."
BILLING CODE 1505-01-D
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
21 CFR Part 340
[Docket No. 75N-244U]
RIN 0905-AA06
Stimulant Drug Products for Over-the-Counter Human Use; Proposed Amendment to the Monograph
Correction
In proposed rule document 91-30426 beginning on page 66758 in the issue of Tuesday, December 24, 1991, make the following corrections:
1. On page 66758, in the first column, under DATES:, in the seventh line, "February 24, 1992." should read "February 24, 1993."
§ 340.20 [Corrected]
2. On page 66760, in the third column, in § 340.60(d)(2), in the next to last line, "establish" should read "established."
BILLING CODE 1505-01-D
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
21 CFR Part 357
[Docket No. 82N-0166]
RIN 0905-AA06
Orally Administered Drug Products for Relief of Symptoms Associated With Overindulgence In Food and Drink for Over-the-Counter Human Use; Tentative Final Monograph
Correction
In proposed rule document 91-30427 beginning on page 66742 in the issue of Tuesday, December 24, 1991, make the following corrections:
1. On page 66742, in the second column, in the first full paragraph, in the first line, "§ 330.10(a)(10)," should read "§ 330.10(a)(10)."
2. On page 66744, in the 1st column, under paragraph 2., in the 22nd line, "of" should read "by."
BILLING CODE 1505-01-D
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
[Docket No. 91N-0498]
Superharm Corp., et al.; Withdrawal of Approval of Abbreviated New Drug Applications
Correction
In the issue of Tuesday, February 11, 1992, on page 5048, in the second column, in the correction of notice document 91-30095, in the first paragraph, in the third line, the date "December 17," should read "December 17, 1991."
BILLING CODE 1505-01-D
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[T.D. 8387]
RIN 1545-AM74
Abatements, Credits, and Refunds—Special Rules for an Insolvent Financial Institution That Is or Was a Member of a Consolidated Group
Correction
In rule document 91-31015, beginning on page 67487, in the issue of Tuesday, December 31, 1991, make the following corrections:
1. On page 67487, in the second column, the subject heading was printed incorrectly, and should read as set forth above.
2. On page 67488, in the second column, in the first full paragraph, in the first line, insert a comma after "example".
PART 1—[CORRECTED]
3. On page 67489, in the first column, in the authority citation, in the fourth line, insert "'* * *'" after "§402(i)".
BILLING CODE 1505-01-D
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[T.D. 8384]
RIN 1545-AP82
Certification of Enhanced Oil Recovery Projects
Correction
In rule document 91-30873, beginning on page 67176 in the issue of Monday, December 30, 1991, make the following corrections:
§ 1.43-3T
1. On page 67177, in the second column, in § 1.43-3T(a)(3)(i)(D)(2), the third line should read "estimates of production after implementation".
2. On the same page, in the same column, in § 1.43-3T(a)(3)(ii), in the second line, "expended" should read "expanded".
3. On the same page, in the third column, in § 1.43-3T(c)(2), in the ninth line, "data" should read "date".
BILLING CODE 1505-01-D
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[T.D. 8390]
RIN 1545-AP37
Tax Treatment of Salvage and Reinsurance
Correction
In rule document 92-1942 beginning on page 3130, in the issue of Tuesday, January 28, 1992, make the following correction:
§ 1.832-4 [Corrected]
On page 3132, in the third column, in § 1.832-4(d)(2)(i), in the seventh line, the paragraph designated "(a)" should read "(A)".
BILLING CODE 1505-01-D
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Parts 1 and 301
[CO-98-88]
RIN 1545-AP57
Abatements, Credits, and Refunds—Special Rules for an Insolvent Financial Institution That is or Was a Member of a Consolidated Group; Hearing
Correction
In proposed rule document 91-31017, appearing on page 67554, in the issue of Tuesday, December 31, 1991, in the 1st column, under ADDRESSES:, in the 11th line, "Washington, D" should read "Washington, DC".
BILLING CODE 1505-01-D
DEPARTMENT OF THE TREASURY
Bureau of Alcohol, Tobacco and Firearms
27 CFR Part 9
[Notice No. 734]
RIN 1512-AA07
Realignment of the Northern Boundary of the Alexander Valley Viticultural Area (89F751P)
Correction
In proposed rule document 92-3329 beginning on page 4942 in the issue of Tuesday, February 11, 1992, make the following corrections:
1. On page 4943, in the second column, under the heading Comments Received in Response to Notice No. 719, in the third line, after "were" insert "received after the closing date. These comments were".
2. On the same page, in the third column, in the file line at the end of the document, "FR Doc. 91-3329 Filed 2-10-91;" should read "FR Doc. 92-3329 Filed 2-10-92;".
Part II
Department of Labor
Occupational Safety and Health Administration
29 CFR Part 1910
Process Safety Management of Highly Hazardous Chemicals; Explosives and Blasting Agents; Final Rule
DEPARTMENT OF LABOR
Occupational Safety and Health Administration
29 CFR Part 1910
RIN 1218-AB20
Process Safety Management of Highly Hazardous Chemicals; Explosives and Blasting Agents
AGENCY: Occupational Safety and Health Administration (OSHA), Labor.
ACTION: Final rule.
SUMMARY: This final rule contains requirements for the management of hazards associated with processes using highly hazardous chemicals. It establishes procedures for process safety management that will protect employees by preventing or minimizing the consequences of chemical accidents involving highly hazardous chemicals. Employees have been and continue to be exposed to the hazards of toxicity, fires, and explosions from catastrophic releases of highly hazardous chemicals in their workplaces. The requirements in this standard are intended to eliminate or mitigate the consequences of such releases. This rule is being referenced in OSHA's Explosives and Blasting Agents standard, 29 CFR 1910.109.
DATES: This final rule will become effective on May 26, 1992.
ADDRESSES: In compliance with 28 U.S.C. 2112(a), the Agency designates for receipt of petitions for review of the standard, the Associate Solicitor for Occupational Safety and Health, Office of the Solicitor, room S4004, U.S. Department of Labor, 200 Constitution Avenue, NW., Washington, DC 20210.
FOR FURTHER INFORMATION CONTACT: Mr. James F. Foster, U.S. Department of Labor, Occupational Safety and Health Administration, Office of Information, room N3647, 200 Constitution Avenue, NW., Washington, DC 20210, (202) 523-8151.
SUPPLEMENTARY INFORMATION: In this preamble, OSHA identifies sources of information submitted to the record by an exhibit number (Ex. 3). When applicable, comment numbers follow the exhibit in which they are contained (Ex. 3: 1). If more than one comment within an exhibit is cited, the comment numbers are separated by commas (Ex. 3: 1, 2, 3). For quoted material, page numbers are cited if other than page one (p.2). The transcript of the hearing is cited by the page number (Tr. 321). Transcript pages are separated by commas. Exhibits and transcripts are separated by semicolons (Ex. 1; Tr. 50).
I. Background
Releases of toxic, reactive or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years. Incidents continue to occur in a variety of industries which use a variety of highly hazardous chemicals which may be toxic, reactive, flammable, or explosive or exhibit a combination of these attributes. (See for example, Ex. 2: 2, 4, 12, 13; Ex. 11: 2, 5, 6, 22, 28, 30, 31, 33, 41, 50, 63, 84, 94, 99, 120–138, 183; Ex. 15B, C; Ex. 53A; Ex. 114; Ex. 118: Tr. 2070, 2230, 2441–42, 2451, 2502.)
Regardless of the industry that uses these highly hazardous chemicals, there exists a potential for an accidental release if a highly hazardous chemical is not properly controlled. This in turn presents the potential for a devastating incident. Recent major incidents include the 1984 Bhopal incident resulting in more than 2,000 deaths; the October 1989 Phillips 66 Chemical Plant incident resulting in 24 deaths and 132 injuries; the July 1990 Arco Chemical incident resulting in 17 deaths; the July 1990 BASF incident resulting in 2 deaths and 41 injuries; and the May 1991 IMC incident resulting in 8 deaths and 128 injuries. While these major incidents involving highly hazardous chemicals have drawn national attention to the potential for major catastrophes, the record is replete with information concerning many other releases of highly hazardous chemicals (as referenced above). These releases continue to pose a significant threat to employees. The continuing occurrence of incidents has provided impetus, internationally and nationally, for authorities to develop or consider the development of legislation and regulations directed toward eliminating or minimizing the potential for such events.
International efforts include the development of the Seveso Directive by the European Economic Community after several large scale incidents occurred in the 1970's, including Flixborough and Seveso. The Directive addresses the major accident hazards of certain industrial activities, lists the hazardous materials of concern and is directed toward controlling those activities that could give rise to major accidents in an effort to protect the environment and the safety and health of persons (Ex. 11–53).
Subsequent international efforts include the development of guidelines for identifying, analyzing and controlling major hazard installations in developing countries and a hazards assessment manual which provides measures to control major hazard accidents developed by the World Bank (Ex. 2: 2); the development of the Code of Practice on the Prevention of Major Accident Hazards by the International Labour Organization (Ex. 11: 154); and the special conferences held by the Organization of Economic and Cooperative Development (Ex. 11: 153) to consider the catastrophic potential of accidents involving hazardous substances and the means to prevent their occurrence and mitigate their impact.
In the United States, Congress, Federal agencies, State governments, industry, unions and other interested groups have become actively concerned and involved with protecting employees, the public and the environment from major chemical accidents involving highly hazardous chemicals.
In 1985, the Environmental Protection Agency (EPA) in response to the potential for catastrophic releases initiated a program to encourage community planning and preparation relative to serious hazardous materials releases (Ex. 2: 5). In 1986, Congress passed the framework for emergency planning efforts through Title III of the Superfund Amendments and Reauthorization Act (SARA), also known as the Emergency Planning and Community Right-to-Know Act (42 U.S.C. 11001 et seq.). SARA encourages and supports states and local communities in efforts to address the problems of chemical releases. Under section 302 of SARA, 42 U.S.C. 11002, EPA was required to publish a list of extremely hazardous substances with threshold planning quantities which would trigger planning in states and local communities (52 FR 13376).
After the 1984 Bhopal, India incident involving an accidental release of methyl isocyanate which resulted in more than 2000 deaths, OSHA determined that it was necessary to immediately investigate U.S. producers and users of methyl isocyanate. This investigation indicated that while the chemical industry is subject to OSHA's general industry standards, these standards do not presently contain specific coverage for chemical industry process hazards, nor do they specifically address employee protection from large releases of hazardous chemicals.
OSHA standards do exist for employee exposure to certain specific toxic substances (see subpart Z of part 1910), and hazardous chemicals are covered generally by other OSHA standards such as the Hazard Communication Standard, § 1910.1200. While these standards do address
hazardous chemicals, they focus on routine or daily exposures and while in many cases they also address emergencies such as spills, OSHA believes that they do not address the precautions necessary to prevent large accidental releases that could result in catastrophes.
Additionally, OSHA has certain standards contained in subpart H of 29 CFR part 1910, Hazardous Materials, concerning flammable liquids, compressed and liquefied petroleum gases, explosives and fireworks. The flammable liquids and compressed and liquefied petroleum gas standards emphasize equipment specification and the flammability of materials and do not thoroughly address other hazards of materials such as toxicity, and the standard concerning explosives and fireworks does not address the hazards involved during their manufacture. Beyond these standards, OSHA must depend on section 5(a)(1) of the Occupational Safety and Health Act, the general duty clause, to protect employees from other hazardous situations arising from the use of highly hazardous chemicals in certain industrial processes and must use national consensus standards and industry standards to support these general duty clause citations.
The need to focus on safety and health in the chemical industry was reinforced in August 1985. A serious release of highly hazardous chemicals (aldicarb oxime and methyl chloride) occurred at a plant in Institute, West Virginia. While no deaths occurred, 135 persons were injured (Ex. 2: 7). The experience of investigating this release indicated to OSHA that there was a need to look beyond existing standards and led OSHA to develop a demonstration program of special inspections in a small segment of the chemical industry (Ex. 2: 7). The purpose of the program was to examine industry practices for the prevention of disastrous releases and the mitigation of the effects of releases that do occur, and to consider ways in which OSHA could best protect employees in the industry from these hazards. Based on the results of the program, OSHA determined that chemical plant inspections need a comprehensive inspection approach which includes plant physical conditions and management systems.
Since this program was initiated, OSHA has issued a series of inspection directives, updated by growing experience and knowledge, that address system safety evaluations of operations with catastrophic potential. One important change in the successive directives was the expansion of the scope of facilities to be inspected. Inspections were to be conducted in industries beyond chemical manufacturing because potentially hazardous chemical releases are not limited to chemical manufacturing and similar precautions should be implemented in operations in which hazardous chemicals are used, mixed, stored or otherwise handled (Ex. 2: 8).
Several states have developed legislation intended to prevent catastrophic events in their communities by requiring employers to take steps to control the highly hazardous chemicals in the workplace (e.g., Delaware, California, New Jersey (Ex. 2: 9)).
Industry has also taken measures aimed at improving the protection of public health and safety by improving chemical process safety to prevent releases. The Chemical Manufacturers Association (CMA) developed the Chemical Awareness and Emergency Response Program to foster cooperation, knowledge and response within communities (Ex. 11: 23, 24; Ex. 3: 48). Additionally CMA produced a report on process safety management, "Process Safety Management, (Control of Acute Hazards)," in order to increase knowledge among CMA members about systematic approaches to process safety analysis (Ex. 11: 25).
In 1985 a professional organization involved with process safety and loss control, the American Institute of Chemical Engineers, formed a separate branch, the Center for Chemical Process Safety (the Center). The Center's charter is to develop and disseminate technical information to be used in the prevention of major chemical accidents (Ex. 11: 16, 17, 18). The Center has become well known for its process safety management guidance publications (see appendix D).
Also an industry consulting group, the Organization Resources Counselors (ORC), and an industry trade association, the American Petroleum Institute (API), have developed recommended practices to address the protection of employees and the public through the prevention or mitigation of the effects of dangerous chemical releases. The ORC recommended practices (Ex. 2: 10) are discussed later in this notice. In 1990 API published its Recommended Practice 750, Management of Process Hazards (Ex. 2: 11), "to provide a more structured and formal approach to existing practices and to ensure a comprehensive approach to process safety" (Ex. 3: 106).
Unions representing employees immediately exposed to danger from processes using highly hazardous chemicals have demonstrated a great deal of interest and activity in controlling major chemical accidents. For example, the International Confederation of Free Trade Unions and the International Federation of Chemical, Energy and General Workers' Unions issued a special report on the Bhopal, India accident (Ex. 2: 12). Additionally the United Steelworkers of America investigated and issued a special report on the 1988 PEPCON plant oxidizer accident in Henderson, Nevada (ammonium perchlorate explosion, two deaths and 350 injuries (Ex. 2: 13)). Further, unions including the United Steelworkers of America, the International Chemical Workers, and the Oil, Chemical and Atomic Workers, have undertaken large-scale efforts to train and educate their members who work in the petrochemical industry (e.g., Ex. 11: 2, Tr. 2262–63, 2265).
OSHA believed that available evidence supported the need for a standard and that adequate data and information existed upon which a standard could be based. Accordingly, on July 17, 1990, OSHA published in the Federal Register (55 FR 29150) a proposed standard containing requirements for the management of hazards associated with processes using highly hazardous chemicals in order to help assure that workers have a safe and healthful workplace.
OSHA's proposed rule emphasized the management of hazards associated with highly hazardous chemicals. The application of management controls to processes involving highly hazardous chemicals was recommended to OSHA by the Organization Resources Counselors (ORC). ORC (Ex. 2: 14) observed:
[When OSHA issued its final report on the Special Emphasis Program for the Chemical Industry (Chem SEP), among its findings were that "specification standards . . . will not . . . ensure safety in the chemical industry . . . [because such standards] tend to freeze technology and may minimize rather than maximize employers safety efforts." The Chem SEP report recommended a new approach to the identification and prevention of potentially catastrophic situations. This approach would involve "performance-oriented standards . . . to address the overall management of chemical production and handling systems."
Further regarding the recommended standard, ORC noted (p.1-2) that:
The recommendations it contains are a systematic approach to chemical process hazards management which, when implemented, will ensure that the means for preventing catastrophic release, fire and explosion are understood, and that the
necessary preventive measures and lines of defense are installed and maintained.
The application of management controls to processes involving highly hazardous chemicals was also supported by other interested groups (Ex. 2: 11; Ex. 11: 23, 24).
The OSHA proposed standard established a comprehensive management program; a holistic approach that integrated technologies, procedures, and management practices. The proposal contains provisions addressing process safety information, process hazard analysis, operating procedures, training, contractors, pre-startup safety reviews, mechanical integrity, hot work permits, management of change, incident investigations, emergency planning and response, and compliance safety audits (Ex. 1).
The notice of proposed rulemaking invited comment on any aspect of the proposed standard for process safety management of highly hazardous chemicals. Additionally comment was invited on a series of issues concerning the requirements and appendices contained in the proposed standard which OSHA believed needed special emphasis. Specific questions were raised on the application of the standard; process hazard analyses; phase-in periods; team composition; training; contractors; critical equipment; drills; and notification. Finally, the notice announced the scheduling of a hearing to begin on November 27, 1990, in Washington, DC.
The Oil, Chemical and Atomic Workers Union requested that OSHA hold a regional hearing in Houston, Texas (Ex. 3: 13). OSHA agreed that the second hearing would be useful and on November 1, 1990, OSHA published a Federal Register notice (55 FR 46074) scheduling a second hearing to begin on February 26, 1991, in Houston, Texas; enumerating additional issues; and extending the written comment period until January 22, 1991. The additional issues in the hearing notice concerned a broader permit system; aggregation of threshold quantities of covered chemicals; workplace fuel consumption; and flammable liquid storage.
The hearings on the proposed standard for process safety management were held in Washington, DC, from November 27 through December 4, 1990, and in Houston, Texas from February 26 through March 7, 1991. The Administrative Law Judge presiding at the hearings allowed participants to submit post-hearing comments by May 6, 1991, and post-hearing briefs by June 5, 1991.
Approximately four months after the publication of OSHA's proposed standard for process safety management of highly hazardous chemicals, the Clean Air Act Amendments (CAAA) were enacted into law (November 15, 1990). The CAAA requires in section 304 that the Secretary of Labor, in coordination with the Administrator of the Environmental Protection Agency, promulgate, pursuant to the Occupational Safety and Health Act of 1970, a chemical process safety standard to prevent accidental releases of chemicals which could pose a threat to employees. The CAAA require that the standard include the development of a list of highly hazardous chemicals which include toxic, flammable, highly reactive and explosive substances. The CAAA specified the minimum elements which must be covered by the standard. The OSHA standard must require employers to:
(1) Develop and maintain written safety information identifying workplace chemical and process hazards, equipment used in the processes, and technology used in the processes;
(2) Perform a workplace hazard assessment, including, as appropriate, identification of potential sources of accidental releases, an identification of any previous release within the facility which had a likely potential for catastrophic consequences in the workplace, estimation of workplace effects of a range of releases, estimation of the health and safety effects of such range on employees;
(3) Consult with employees and their representatives on the development and conduct of hazard assessments and the development of chemical accident prevention plans and provide access to these and other records required under the standard;
(4) Establish a system to respond to the workplace hazard assessment findings, which shall address prevention, mitigation, and emergency responses;
(5) Periodically review the workplace hazard assessment and response system;
(6) Develop and implement written operating procedures for the chemical process including procedures for each operating phase, operating limitations, and safety and health considerations;
(7) Provide written safety and operating information to employees and train employees in operating procedures, emphasizing hazards and safe practices;
(8) Ensure contractors and contract employees are provided appropriate information and training;
(9) Train and educate employees and contractors in emergency response in a manner as comprehensive and effective as that required by the regulation promulgated pursuant to section 128(d) of the Superfund Amendments and Reauthorization Act;
(10) Establish a quality assurance program to ensure that initial process related equipment, maintenance materials, and spare parts are fabricated and installed consistent with design specifications;
(11) Establish maintenance systems for critical process related equipment including written procedures, employee training, appropriate inspections, and testing of such equipment to ensure ongoing mechanical integrity;
(12) Conduct pre-start-up safety reviews of all newly installed or modified equipment;
(13) Establish and implement written procedures to manage change to process chemicals, technology, equipment and facilities; and
(14) Investigate every incident which results in or could have resulted in a major accident in the workplace, with any findings to be reviewed by operating personnel and modifications made if appropriate.
Also under the CAAA, the Environmental Protection Agency has specified duties relative to the prevention of accidental releases (see section 301(r)). Generally EPA is required to develop a list of chemicals and a Risk Management Plan.
OSHA received more than 175 comments in response to the notice of proposed rulemaking. In addition to these comments, the hearings resulted in almost 4000 pages of testimony and almost 60 post-hearing comments and briefs.
Shortly after the catastrophic Phillips 66 Company's Houston Chemical Complex incident, OSHA asked the John Gray Institute of Lamar University to conduct a study of safety and health issues as they relate to contract work in the petrochemical industry. The issue of the role of contractors in the petrochemical industry surfaced since a contractor had been working in the vicinity of the Phillips' release. Additionally, OSHA's experience indicated that a significant number of companies were using contractors to perform work at their plants. The Agency determined additional information was needed on contractors since it wanted to assure that safety issues surrounding contractor employees who are exposed or may expose site employees to potentially catastrophic events are thoroughly addressed in the process safety management standard. Upon the completion of the report, OSHA decided to give interested persons an opportunity to comment on the report and, therefore, reopened the record to receive public comment on the report and to reexamine the provisions concerning contractors. On September 24, 1991, OSHA published a notice in the Federal Register announcing the availability of the John Gray report and requesting public comment [56 FR 48133]. OSHA received more than 300
requests for the John Gray Institute report. The comment period ended on October 24, 1991, and OSHA received 37 comments in response to the notice. The Administrative Law Judge certified the public record for the proposed rule to the Assistant Secretary of Labor for Occupational Safety and Health on November 29, 1991.
The record for this rulemaking is extensive and OSHA appreciates the time and effort expended by interested parties to ensure that as much information as possible was available to the Agency for purposes of making decisions on the final standard. In analyzing the record and preparing this final document. OSHA has carefully reviewed all of the information received, and has considered the concerns expressed by the parties participating in this rulemaking and has carefully examined the requirements of the Clean Air Act Amendments in order to assure that the final standard reflects its intent.
II. Agency Action
OSHA believes that processes involving highly hazardous chemicals present the potential for accidents, such as spills or other uncontrolled releases that could have catastrophic results. Information available to OSHA indicates that accidents have occurred in workplaces with processes involving highly hazardous chemicals for many years and that they continue to occur. Reports of incidents clearly show that there is a significant risk to employees in industries covered by this rule and that mandatory standards are reasonably necessary and appropriate and will reduce deaths and injuries due to accidental releases of highly hazardous chemicals which expose employees to the hazards of toxicity, fires and explosions. OSHA believes that this final rule will significantly reduce deaths and injuries associated with accidental releases of highly hazardous chemicals.
In conclusion, OSHA has determined that employees in industries with processes involving highly hazardous chemicals have been for many years exposed to the hazards of releases of highly hazardous chemicals which may be toxic, reactive, flammable, or explosive; that employees continue to be exposed to the hazards of releases of toxic, reactive, flammable, or explosive chemicals; that incident information and other relevant data demonstrate that these hazards pose a significant risk to employees; that this standard is reasonably necessary and appropriate; and that feasible control measures are available that will reduce the risk of employees in these industries being injured or killed. The final standard reflects OSHA's determination that a standard is reasonably necessary and appropriate to provide safe and healthful employment and places of employment for employees in industries which have processes involving highly hazardous chemicals. Additionally, OSHA is convinced that compliance with the final standard provisions will mitigate many of the hazards present in processes involving highly hazardous chemicals. As a result, OSHA believes the risk of death or injury to employees exposed will be significantly reduced.
Finally, the Clean Air Act Amendments of 1990 clearly require OSHA to develop a chemical process safety standard containing certain minimum requirements to prevent accidental releases of chemicals which could pose a threat to employees (section 304(a)). The standard must contain clearly defined minimum requirements. Thus, in addition to being convinced that a process safety management standard is necessary and appropriate, OSHA is fulfilling its obligation under the Clean Air Act Amendments to develop this final standard. This final rule is consistent with the mandate of the CAAA.
III. Summary and Explanation of the Final Rule
This section contains an analysis of the record evidence and policy decisions pertaining to the various provisions of the standard.
The Occupational Safety and Health Act (OSH Act) defines an occupational safety and health standard as a standard which requires conditions, or the adoption or use of one or more practices, means, methods, operations, or processes, reasonably necessary or appropriate to provide safe or healthful employment and places of employment.
Under section 6(b) of the OSH Act, the Secretary (of Labor) may by rule promulgate, modify or revoke any occupational safety and health standard in a prescribed manner. The Act directs the Secretary of Labor to consider in promulgating standards, national consensus standards. In this instance, there is no existing consensus standard that addresses process safety management of highly hazardous chemicals.
The proposed process safety management standard contained the following paragraphs:
Purpose: Paragraph (a)
Application: Paragraph (b)
Definitions: Paragraph (c)
Process safety information: Paragraph (d)
Process hazard analysis: Paragraph (e)
Operating procedures: Paragraph (f)
Training: Paragraph (g)
Contractors: Paragraph (h)
Pre-startup safety review: Paragraph (i)
Mechanical integrity: Paragraph (j)
Hot work permits: Paragraph (k)
Management of change: Paragraph (l)
Incident investigations: Paragraph (m)
Emergency planning: Paragraph (n)
Compliance safety audits: Paragraph (o)
In the final standard, OSHA has added two additional paragraphs: employee participation and trade secrets. OSHA determined that the logical placement of the paragraph regarding employee participation should be at the beginning of the rule since the provisions require that employers consult with employees and their representatives on the general development of a process safety management program, as well as on the process hazards analyses. In order to accommodate the placement of the provisions concerning employee participation in the beginning of the final standard but also to minimize any unnecessary redesignation of paragraphs, OSHA has decided to remove the letter designation "(a)" from the "purpose" paragraph. This results in the following changes:
Purpose
Application: Paragraph (a)
Definitions: Paragraph (b)
Employee participation: Paragraph (c)
The paragraph on trade secrets has been added to the end of the standard and becomes new paragraph (p). Therefore, the paragraphs in the final rule are designated in the following manner:
Purpose
Application: Paragraph (a)
Definitions: Paragraph (b)
Employee participation: Paragraph (c)
Process safety information: Paragraph (d)
Process hazards analysis: Paragraph (e)
Operating procedures: Paragraph (f)
Training: Paragraph (g)
Contractors: Paragraph (h)
Pre-startup safety review: Paragraph (i)
Mechanical integrity: Paragraph (j)
Hot work permit: Paragraph (k)
Management of change: Paragraph (l)
Incident investigation: Paragraph (m)
Emergency planning and response:
Paragraph (n)
Compliance safety audit: Paragraph (o)
Trade secrets: Paragraph (p)
A significant number of commenters and hearing participants supported the proposed standard and its purpose (e.g., Ex. 3: 10, 17, 18, 22, 25, 26, 28, 29–32, 38, 39, 40, 42, 45, 46, 53, 59, 69, 70, 71, 72, 76, 77, 79, 80, 82, 83, 86, 87, 91, 95, 96, 97, 101,
103, 104, 106, 107, 108, 113, 117, 120, 121, 127, 129, 134, 143, 146, 152, 153, 158, 162, 164, 168, 171; Ex. 89; Ex. 91; Ex. 112; Ex. 138; Tr. 730, 779, 1204, 1594, 1614, 1802, 1998–99, 2155, 2172, 2245, 2508, 2570, 2652, 2768, 3115, 3157, 3236, 3345, 3404, 3442, 3461, 3604, 3753). A participant from The Upjohn Company (Ex. 3: 22) stated:
We are pleased at this proposed rule (1910.119) which will require all employers to implement programs to ensure the safety and health of those employees working with and around processes which involve highly hazardous chemicals. In addition, we are encouraged that the effort to establish this standard included cooperation from business and government to propose a standard that is both beneficial and workable.
The Food and Allied Services Trades, of the AFL–CIO, (Ex. 3: 25, p. 3) remarked:
The proposed rule is well-intended and there is little question that such regulation is needed. Recent events . . . underscore this need. These events include not only the catastrophic explosions that occurred at Phillips Petroleum and Arco Chemical in the Houston area, but hundreds of smaller explosions and disasters that were not as widely reported by the press.
BP Oil Company (Tr. 1802) stated:
We are here today to comment on a proposed regulation which we regard as of major importance to our industry. We strongly support the Occupational Safety and Health Administration’s approach to protecting workers and the public from industrial operation hazards.
Finally, the United Steelworkers of America (Tr. 2231) observed:
But the real problem is that OSHA has no standard requiring process hazard analysis, written operating procedures, adequate training in process safety, periodic safety reviews, quality assurance for critical equipment or the investigation of near-miss accidents.
Had such a standard been in place at Neville Chemical, Jim Thompson would be alive today. So might all the other chemical workers killed by accidental releases of hazardous chemicals in the past several years including the 40 in Pasadena and Channelview. Clearly, it is time to give OSHA inspectors the tools they need to prevent catastrophic accidents.
It is also time to give workers the tools they need to protect themselves and their communities.
Participants in the rulemaking also supported OSHA’s development of a performance-oriented standard (e.g., Ex. 3: 27, 33, 39, 45, 46, 48, 69, 76, 134, 148, 161, 162, 171; Ex. 91; Ex. 133; Ex. 138; Tr. 1009, 1999, 2284, 3726). The Chemical Manufacturers Association (Ex. 3: 48) remarked:
Initially CMA would like to commend OSHA on its efforts to craft a comprehensive performance based standard addressing process safety management of highly hazardous chemicals. As CMA has commented in past rulemakings, performance language capitalizes on industry’s ingenuity and capability to effectively reduce hazards as they may be uniquely applied to a particular safety concern.
Ashland Petroleum Company (Ex. 3: 80) stated:
Ashland * * * is generally supportive of the efforts of the Secretary and of the Occupational Safety and Health Administration with respect to this proposed regulation. While our internal commentators had divided between a desire for specificity and the obvious value of the non-detailed performance approach, ultimately we believe the “performance standard” approach is the best way to regulate a wide variety of situations for which a common end is desired.
The American Society of Safety Engineers (Ex. 3: 148, p. 2) noted:
The Society commends OSHA’s use of a performance standard rather than a specification rule, believing this is the better means to help ensure each affected facility address its individual situation.
Many participants in the rulemaking acknowledged their belief that a process safety management standard is the most effective approach available in the prevention of catastrophic releases and others acknowledged their belief that the standard will improve the safety and health of employees (e.g., Ex. 3: 71, 72, 91, 94, 95, 96, 101, 106, 113, 120, 121, 127, 129, 158; Ex. 131; Tr. 1998, 3719). For example, Amoco (Ex. 3: 95) found that:
In general, we are very favorably impressed with the regulation as written. This standard is comprehensive, and when properly applied, should be effective in reducing loss of life, serious injury, and damage to property.
The American Petroleum Institute [API] (Ex. 3: 106) indicated:
API member companies support OSHA’s effort to develop an effective process safety management rule. API believes process safety management is the most effective approach available in the prevention of catastrophic releases, a goal which we share with OSHA completely.
Finally, Oryx Energy Company (TR. 3719) testified:
I think the proposed rule and 750 [API RP 750]—you know, they are similar—they will both accomplish the mission of making a safer workplace. I think—I know of no other system that is better than the system that is proposed by OSHA.
Before discussing the provisions of the final standard, OSHA would like to address several issues that were brought up during the rulemaking. First, many participants asserted that OSHA should permit required information to be stored electronically or on computers.
Electronic storage or computerized storage of records and information required by this standard is permissible, as long as it is readily accessible and easily understood.
Second, in Issue 10 of the proposal (55 FR 29159) OSHA asked whether provisions should be delayed or phased-in (timeframes for conducting process hazard analyses were discussed in a separate issue, Issue 3 at 29158). Participants suggested a variety of schedules (e.g., Ex. 3: 41, 45, 48, 53, 69, 81, 96, 101, 108, 113, 127, 134; Ex. 138; Tr. 735, 1616, 3241). However, OSHA has decided that, with the exception of allowing a phase-in period for paragraph (d), process safety information, and paragraph (e), process hazards analysis, no other phase-in period is necessary or warranted. OSHA realizes, as it does with any other newly promulgated standard, that employers will be working toward implementation of the provisions contained in the standard as quickly as possible. The standard will become effective in 90 days, thereby giving employers a brief period to familiarize themselves with the provisions of the standard and begin its implementation. OSHA believes this schedule is practical and feasible.
Third, also in Issue 10, OSHA asked whether it is necessary for all of the covered industries to meet all of the proposed provisions. OSHA was concerned about the potential impact on small businesses. Most of the participants who addressed this issue believed that small facilities should not be exempted if they have the threshold quantity of chemicals in their processes since the potential for a catastrophe is based on the amount of chemical present rather than on the size of facility (e.g., Ex. 3: 9, 20, 38, 47, 59, 69, 95, 103, 138; Tr. 2010–1, 2176, 3421). Several of these participants suggested that OSHA provide special assistance to small employers. OSHA agrees with participants that plants should be covered based on whether they have the threshold quantity of a covered highly hazardous chemical. OSHA also agrees with the recommendation suggesting that OSHA provide special assistance to small businesses and is considering this issue at this time. As an immediate step, OSHA has developed nonmandatory appendices which will assist in providing small businesses with guidance on complying with the process safety management standard and sources of further information and assistance (appendix C and appendix D respectively). Additionally, the Agency is developing a compliance assistance
"outreach" program to assist small businesses.
Finally, in Issue 11 (55 FR 29159) of the proposal, OSHA asked whether employers, when they have a threshold quantity of a highly hazardous chemical as specified by the standard, should be required to notify the OSHA Area Office of their location. Other entities which regulate potentially catastrophic workplaces require notification of the regulating authority.
Numerous participants addressed this issue. Some participants believed that notification should be required (e.g., Ex. 3: 20, 25, 71, 86, 99, 115; Ex. 101, Tr. 2253). Other participants indicated that while they did not see a benefit to notification, they would not object if a notification requirement was kept simple (e.g., Ex. 3: 28, 28, 28, 69, 113, 120; Tr. 3279, 3376). Still others objected to notification as an unnecessary burden, and in some cases observed that EPA already requires notification or that perhaps OSHA should access the information already required to be submitted to EPA (e.g., Ex. 3: 30, 38, 64, 80, 109, 113, 120, 122, 127, 134, 141, 146; Ex. 103, Tr. 1025). For example, Organization Resources Counselors (Ex. 131, p.11) indicated that:
Before OSHA inserts such a requirement into the standard, it should determine what use it will make of such notification and whether or not the information is already available from other resources.
OSHA has decided not to require notification in the final standard. OSHA believes requiring such information would be redundant with requirements that already exist under SARA and under the Clean Air Act Amendments which require reporting. Since similar information is already required to be reported, OSHA will work with EPA to obtain needed plant location information, instead of placing a redundant burden on employers.
On September 18, 1990, the Office of Management and Budget (OMB) filed comments on the process safety management proposal (Ex. 3: 14). OMB raised several concerns about the proposal. OMB observed that:
(1) OSHA failed to consider alternative regulatory options;
(2) The effectiveness of OSHA's approach is uncertain;
(3) The costs of the standard may be higher than estimated and may adversely affect profitability;
(4) The standard may have high costs and few benefits for small employers and, therefore, could be anticompetitive; and
(5) OSHA should consider a sunset provision in the final rule that would cause the rule to expire after five years if it does not have the intended effect of providing significant reductions in the number of workplace accidents associated with hazardous chemicals.
OSHA has carefully evaluated the OMB comment and believes that the modifications to the proposed rule and the issues discussed below are responsive to the OMB concerns. The major concerns are addressed below.
(1) OMB stated that OSHA had failed to consider alternative regulatory options that might protect workers equally well at lower cost (Ex. 3: 14, p.1-3). OSHA believes that its latitude to consider regulatory options such as those contemplated by OMB is somewhat limited by the Clean Air Act Amendments (CAAA). For example, in section 304 of the CAAA, OSHA was directed to enact a chemical process safety standard containing certain minimum elements within one year. The Clean Air Act Amendments specified 14 elements which OSHA must include in the process safety standard. OSHA has included these elements in its final process safety management standard. OMB suggested that OSHA consider an alternative regulatory approach that allows firms to use the results of the hazard analysis to determine which of the other safety requirements are appropriate. The Congressional mandate does not allow OSHA this flexibility. In addition, participants addressed this issue (Ex. 131; Tr. 307, 818) and the consensus was that the provisions of the standard were inextricably intertwined and they could not be considered separately without adversely affecting the contemplated effectiveness of the rule. For example, the Organization Resources Counselors (ORC) stated that its member companies "indicate that most, if not all, process related incidents involve a breakdown of one or more of OSHA's Process Safety Management elements" (Ex. 131, p.9). American Cyanamid Company (Ex. 3: 127) observed:
We concur with the concept of a comprehensive management system which addresses technology, equipment, procedures, training and management oversight. Deficiencies in any one of these areas can lead to a breakdown in process safety and increase the potential for a serious accident.
In addition, OMB suggested that OSHA should look more closely at the potential for accidents from various types of hazardous chemicals (Ex. 3: 14, p.2). In establishing the list of substances to be regulated under the process safety management rule, OSHA carefully considered the potential for catastrophic events posed by a large number of chemicals. In order to select chemicals with catastrophic potential, OSHA consulted the lists developed by the Environmental Protection Agency and Department of Transportation and various states with regulatory experience in this area; namely Delaware and New Jersey. In developing the list of covered substances, OSHA also reviewed materials on this subject developed by the World Bank, the European Economic Community (the Seveso Directive), the National Fire Protection Association and ORC. While it is true that all chemicals on the list do not have equal catastrophic potential, OSHA addressed this issue in two ways. It developed appropriate thresholds for each of these chemicals by consulting with the sources above and relying on its own expertise, and it developed the flexible performance-oriented approach of the standard by mandating a process hazard analysis which will itself indicate the necessary safety precautions to take according to the incidence of use in a particular industrial setting.
(2) OMB claimed that the effectiveness of OSHA's approach is uncertain (Ex. 3: 14, p.3-4). In its preliminary regulatory impact analysis (PRIA, Ex. 4), OSHA claimed that after the standard had been in effect for 5 years, injuries and illnesses resulting from potentially catastrophic incidents would be reduced by at least 80% (Chapter V-14). This effectiveness rate is consistent with that used in other OSHA Regulatory Impact Analyses such as Electrical Safety-Related Work Practices (Final Rule, 55 FR at 32011, August 6, 1990, Regulatory Impact Assessment); Control of Hazardous Energy Source [Lockout/Tagout] (85 percent, Final Rule, 54 FR at 36685, September 1, 1990, Regulatory Impact Analysis); Permit Required Confined Spaces; Notice of Proposed Rulemaking (54 FR at 24097, June 5, 1989, Benefits); and Hearing Conservation (Final Regulatory Analysis of the Hearing Conservation Amendment, U.S. Department of Labor, January 1981, Chapter III-27; benefits of 85% at equilibrium from the hearing conservation amendment).
Participants also acknowledged their belief that the process safety management standard will be substantially effective in improving safety. For example, Arco Chemical (Ex. 3: 71) stated:
ARCO Chemical Company strongly endorses OSHA's proposed rulemaking . . . ACC's President and Chief Executive Officer, stated that ACC shares "• • • the Congress' desire to further improve process safety management in the chemical industry," and
that ACC believes that OSHA's proposed rules "—as minimum standards—will substantially improve safety across the entire U.S. process industry."
American Cyanamid Company (Ex. 3: 127) remarked:
American Cyanamid believes that the proposed standard, if implemented, will substantially reduce the risk of accidental releases, fires and explosions from processes involving highly hazardous substances.
Additionally, the Organization Resources Counselors (Ex. 131, p.9–10) stated:
Given effective implementation and compliance with the provisions of the proposed standard, we agree with OSHA's estimate of at least 80% reduction in serious process incidents.
Quantitative evidence from Air Products and Chemicals, Inc., suggests that instituting a comprehensive process safety program which includes a hazard analysis could result in an even more significant reduction in accident and injury rates (97.5%; RIA, Chapter V–11–12). Moreover, empirical data from a senior safety consultant showed that in dealing with 500 companies of all sizes (over a 15 year period) "those committed to the development of a long-term program" similar to that described in the process safety management standard, achieve median improvement in their safety programs after the third year of implementation of nearly 75% (RIA, Chapter V–13).
Although one of the studies cited by OMB (the St. John's River Power Plant project) only accomplished a 56% decrease in accidents, it is important to note that the potential hazards faced by the plant studied were significantly lower than those posed by the use and handling of the threshold amounts of chemicals covered by the process safety management rule; and the program studied was not as comprehensive as that contemplated in the PSM standard. It is not unreasonable to assume that where, as here, highly hazardous chemicals are being used in potentially catastrophic amounts and there is a comprehensive standard in effect that has the force and effect of law, that an additional 25% effectiveness could be accomplished. While one cannot predict benefits absolutely it would seem that the 80% estimate assumed by the RIA is reasonable and supported by substantial evidence in the record as a whole.
(3) OMB also indicated that the costs may be higher than estimated and may adversely affect profitability (Ex. 3: 14, p. 4–6). The PRIA predicted that compliance with the proposed standard would cost $638 million in direct annualized gross costs (estimated per year for a ten year period). These estimates were based in large part on the Kearney/Centaur Report, "Proposed OSHA Rule for the Process Hazards Management of Highly Hazardous Chemicals: An Industry Profile, Cost Assessment and Benefits Analysis" (Ex. 5). A number of commenters believed that the PRIA had underestimated the costs of complying with the proposed standard (e.g., 3: 45, 69, 95, 108, 109, 150, 153). In response to comments in the record, OSHA updated and refined the Kearney/Centaur industry profile, its estimates of current industry compliance with the proposed process safety management standard, and the estimate of the number of processes per establishment that would be covered by the standard (RIA, Chapter V). This resulted in the calculation of increased costs of compliance with the process safety management standard. The final RIA predicts gross costs of $863.5 million/year during the first 5 years that the standard is in effect (as opposed to the $638 million estimated by the PRIA) (RIA, Chapter IV–11) and $390.1 million/year during the next 5 years. In order to better understand the true costs associated with the process safety management rule, the gross cost of compliance must then be adjusted downward to account for the many benefits of the standard, such as increased productivity, decreased property damage, and decreased fatalities and injuries. When these offsets are taken into account, OSHA predicts that the standard will cost approximately $143.5 million per year for the first 5 years. Cost savings are expected to exceed direct costs for most industry groups in years 6 through 10.
OSHA also looked at the effect of the costs of compliance on the profitability of the affected industries and found that, assuming that the affected companies would not pass on any of the costs of compliance to customers (a worst case assumption), in the first five years compliance with the process safety management rule might decrease profits anywhere from .09 percent to 15.7 percent depending on the industry group. Worst-case profit impacts would average 1.1 percent for large establishments and 3.2 percent for small establishments. Therefore the final figures show that the standard is not only economically feasible, but it will not unreasonably affect the profitability of the affected industries and is well within the mandates of the CAAA, the Occupational Safety and Health Act and Executive Order 12291.
(4) OMB also believed that the process safety management rule might have high costs and few benefits for small employers and, therefore, could be anticompetitive (Ex. 3: 14, p. 6–7). As stated above, the final RIA indicates the gross costs of complying with the process safety management standard will be $863.5 million/year during the first 5 years that the standard is in effect and $390.1 million/year during the next 5 years for all industry. Of this total gross cost of compliance, small business will bear approximately $28.9 million/year during the first 5 years that the standard is in effect and $33.0 million/year during the next 5 years. While accounting for approximately 10 percent of costs, small firms will realize considerable benefits from compliance; 21 percent of fatalities avoided and 9 percent of lost-workday injuries avoided will occur in small establishments.
OSHA's estimates for small-firm costs declined in the final impact analysis after incorporating the ideas of inventory reduction and a learning-curve effect during compliance. A small business might reduce the potential hazard by purposely controlling its on-site inventory of highly hazardous chemicals by ordering more frequent, smaller shipments so that they do not exceed the threshold for coverage set forth in the rule. Also, they may segregate their inventory by dispersing the storage around the worksite so that the release of a highly hazardous chemical from one storage area would not cause the release of the other inventory stored on site. This remote storage approach would also be a feasible alternative. Moreover, small employers who use batch processes may be able to use a generic approach to the required process hazards analysis which would help to further reduce the estimated cost of compliance. For example, a generic process hazard analysis of a representative batch might be used where there are only small changes in the process chemistry and this is documented for the range of batch processes (see appendix C).
Also, as a general rule, small employers have greater flexibility within their workplaces than do large employers. Employees may be trained to do more than one job and have a greater understanding of the interrelationship of the different factors that can adversely affect the process and produce a potentially catastrophic incident.
Some participants believe that there will be long-term benefits to full implementation of process safety management (e.g., Ex. 11: 87; Ex. 99; Ex. 131; Tr. 1050–52, 3052). For example, evidence in the record from a manager of a small plant which had recently undergone the experience of
implementing process safety management practices and techniques indicates that the benefits of the standard can be substantial and realizable (Ex. 131, Attachment III, p. 5-6). For example, he wrote:
The benefits of a comprehensive process safety program are substantial, but are often difficult to quantify. This is particularly true if one tries to develop a traditional "return on investment."
Perhaps the biggest benefit is in the alteration of thinking that is inherent to the system. It became apparent that there was a subtle shifting of approach to problems by plant staff. Our small organization was quietly infused with a rebirth of innovative thinking. Process technology that was more than 35 years old was routinely being questioned and inspected for safer ways to do the task at hand. This quickly led to the same questioning being applied to process improvement.
The net result has been not only that safety performance has been enhanced, and the process operational risks materially reduced, but the resultant attitude and approach to daily tasks have resulted in material gains in directly accountable issues such as process yields. Ultimately, I believe that this thoroughness and rigorous training approach will result in cost savings to a small plant site on the order of 4 to 7 percent of an operating budget.
(5) OMB also felt that OSHA should consider a sunset provision in the final rule that would cause the rule to expire after five years if it does not have the intended effect of providing significant reductions in the number of workplace accidents associated with hazardous chemicals (Ex. 3: 14, p. 3). In its proposal, OSHA did not propose a specific timeframe for compliance. The final OSHA rule, because of feasibility considerations, does not become fully effective for five years and if the comment is read literally, the rule might "set" before it was fully implemented. Therefore, the 5-year "sunset" timeframe would not be compatible with the process safety management regulatory framework. The process safety management standard is based on the Occupational Safety and Health Act and the Clean Air Act Amendments of 1990 (CAAA). The CAAA does not contemplate a "sunset" provision and this is probably because we know that the chemicals which this standard regulates are intrinsically hazardous and the hazard will not go away as long as these chemicals are being used in industrial processes. Even if the OMB comment were read to mean that OSHA should consider a sunset provision 5 years after the rule becomes effective, there is nothing in the present record that would support the inclusion of a sunset provision in the final rule. The Agency believes that this final rule will be highly effective and will significantly reduce workplace accidents and injuries. This view is supported by substantial evidence in the record as a whole. Therefore it would be arbitrary and contrary to the record evidence for the Agency to include a sunset provision in the final rule. Moreover, it is questionable whether this approach (i.e., a sunset provision) is consistent with the procedural framework of the Occupational Safety and Health Act, which directs the Secretary to use specified procedures to amend or revoke a standard adopted under the Act. These procedures include public notice and an opportunity for the public to file comments and objections and to request a public hearing on the proposed amendments or revocation (29 U.S.C. 655).
It is, of course, possible that after the process safety management rule has been in effect for a while, however, facts may emerge to indicate that there is a need to change the regulation (e.g., safety prevention provisions, highly hazardous chemical lists, etc.). If such facts emerge, either based on safety experience under the rule or on an OSHA retrospective study of the costs and benefits of the rule, the Agency might then consider amending the regulation to make it more effective. This would, of course, be done under section 8 of the Occupational Safety and Health Act, perhaps with the assistance of other potentially relevant statutes such as the Alternative Dispute Resolution Act (Pub. L. 101–552) and the Negotiated Rulemaking Act (Pub. L. 101–648). Under any of these vehicles, however, interested persons would be given a chance to comment and present evidence on all relevant issues, a safeguard that might be missing if a sunset provision were used.
**Purpose**
It was pointed out to OSHA by several commenters (e.g., 3: 12, 48, 53) that in the proposed paragraph concerning the purpose of the standard (proposal paragraph (a)), OSHA did not correctly state the types of chemicals covered by the proposal since in addition to "toxic, flammable or explosive chemicals," OSHA was also covering reactive chemicals. This intent was stated in other locations in the proposal including the description of the highly hazardous chemicals covered by appendix A of the proposal. In response, OSHA has added "reactive" to the purpose paragraph and it now states that the section contains requirements for preventing or minimizing the consequences of "toxic, reactive, flammable, or explosive chemicals." Additionally, OSHA has added that the standard is intended to address the hazards to employees from toxicity, fire or explosion.
**Application: Paragraph (a)**
The application section in proposed paragraph (b) specified those types of highly hazardous chemicals covered by the proposal. The application section also included processes involving certain specified highly hazardous chemicals at or above a stated threshold which was listed in appendix A; processes involving flammable liquids or gases on site in one location in quantities of 10,000 pounds or greater (with two exceptions discussed later in this preamble); the manufacture of explosives and pyrotechnics; and processes involving chemicals developed after the promulgation of the final standard which meet certain criteria contained in proposed mandatory appendix B (Substance Hazard Index). Additionally, OSHA proposed to exclude retail facilities, oil and gas well drilling and servicing operations and normally unmanned remote facilities from the standard.
The application paragraph was addressed by the vast majority of rulemaking participants. OSHA received a great deal of support concerning its general approach to covering highly hazardous chemicals but also received numerous recommendations for clarifications: criticisms regarding the toxic and reactive list (appendix A); the inclusion of 10,000 pounds of flammable liquids rather than the use of a vaporizable amount (5 tons of vapor); and recommendations for additional exemptions for certain processes or industries. OSHA has carefully evaluated participants' comments and information concerning the appropriate scope and application of the standard in order to assure that the standard is clearly and properly focused to achieve its goal of eliminating the occurrence of releases or mitigating the consequences of releases that occur.
Before discussing the proposed application provisions in detail, OSHA would like to address and clarify OSHA's use of the plural word "processes" in the application paragraph of the proposal. This use resulted in commenters (e.g., Ex. 3: 104, 109, 112, 119, 125, 126) questioning whether the use of the word "processes" meant that the amount of highly hazardous chemical used at a plant must be aggregated to meet the threshold for coverage even though the amount of highly hazardous chemicals used at any one location might be less than the
threshold amount or the amount of highly hazardous chemical in use might be divided among remote processes. Also, participants asked whether the proposal required that the highly hazardous chemical threshold quantity be aggregated over a period of time or whether it must be present at one point in time to be covered by the proposal. OSHA addressed this concern in its November 1, 1990, Federal Register notice in Issue 2 (55 FR 46075).
OSHA's view at that time was that if a plant exceeded the threshold quantity of a listed chemical but the chemical was used in smaller quantities around the plant and was not concentrated in one process or in one area, then OSHA believed that a catastrophic release of the threshold quantity would be remote due to the reduced availability of a concentrated amount of the chemical in one location. However, OSHA requested comment on the point at which a chemical should be considered in its aggregate due to the proximity of the sites at which it was being used in a plant.
While a few participants indicated that the amounts of a highly hazardous chemical used at various sites around the plant should all be counted toward the threshold amount for coverage (e.g., Ex. 3: 12, 18, 41; Ex. 153), most participants who discussed this issue noted that the threshold quantity should not be aggregated (e.g., Ex. 163; Ex. 164; Tr. 2591, 3192). They agreed that highly hazardous chemicals in less than threshold quantities distributed in several processes would not present as great a risk of catastrophe as the threshold quantity in a single process.
OSHA continues to believe that the potential hazard of a catastrophic release exists when the highly hazardous chemical is concentrated in a process and therefore agrees with these commenters. OSHA has clarified the language contained in the application paragraph to reflect its intent that coverage is triggered by a specified threshold quantity of an appendix A substance being used in a single process. This revision also clarifies the fact that the presence of a threshold quantity of a highly hazardous chemical in a process is to be at one point in time; not aggregated over a period of time.
In the application section (paragraph (b)(1)(i)) of the proposal, a process would be covered if it involved a toxic or reactive highly hazardous chemical listed in appendix A, at or above a specified threshold quantity. Appendix A was a compilation of highly hazardous chemicals that could cause a serious chemical accident, by toxicity or reactivity, and a consequent potential danger to employees in a workplace.
The appendix A list has been drawn from a variety of relevant sources which include: The New Jersey "Toxic Catastrophe Prevention Act," the State of Delaware's "Extremely Hazardous Substances Risk Management Act," the World Bank's "Manual of Industrial Hazard Assessment Techniques," the Environmental Protection Agency's "Extremely Hazardous Substance List," the European Communities Directive on major accident hazards of certain industrial activities (82/501/EEC, sometimes called the Seveso Directive), the United Kingdom's "A Guide to the Control of Industrial Major Accident Hazards Regulations 1984," the American Petroleum Institute's RP 750, "Management of Process Hazards," the National Fire Protection Association's NFPA 49, "Hazardous Chemicals Data," and the Organization Resources Counselors, Inc.'s "Recommendations for Process Hazards Management of Substances with Catastrophic Potential."
Every chemical listed in appendix A is on at least one list compiled by these agencies and organizations as warranting a high degree of management control due to its extremely hazardous nature. Most of the chemicals are on several lists. Not every list contains the same chemicals or quantities. Based on a review of these sources, OSHA has sought to include those toxic and reactive chemicals it believes are most significant in potentially becoming a catastrophic event. OSHA has also sought to develop a reasonable listing of threshold quantities which, when used in a process, would invoke coverage of the standard.
Those appendix A highly hazardous chemicals which are highly reactive or explosive-type chemicals have been drawn from chemicals listed in the National Fire Protection Association (NFPA) document, NFPA 49, "Hazardous Chemicals Data" and cross-referenced with other sources mentioned above. The Agency decided to include substances with the two highest or most dangerous reactivity ratings from NFPA 49 because these chemicals present the most severe exposure potential to workers. These substances, which are rated 3 or 4 by NFPA 49, are those which are capable of undergoing detonation or explosive decomposition. These are the substances which can generate the most severe blast or shock wave, and can cause fragmentation of piping, vessels and containers, as well as causing serious damage to buildings and structures.
The minimum threshold quantities for the highly reactive chemicals covered by the standard have been determined by calculating the amount of material needed to propagate a blast wave that creates an overpressure of 2.3 psi (15.85 kPa) to a flat surface perpendicular to the direction of the blast wave at a distance of 100 meters from the point of origin. This approach is similar to that used by the State of Delaware.
The toxic chemicals contained in appendix A were drawn from the various resource documents discussed above. Most of the toxic chemicals listed in appendix A are on a majority of the lists produced by these resource documents.
In determining threshold quantities for toxic chemicals, OSHA used the Turner described Gaussian dispersion model. This approach, again, is similar to that used by the State of Delaware. Both OSHA and Delaware made the following assumptions: Average conditions of 4.3 m/sec. wind speed and D stability with urban dispersion coefficients; continuous steady-state release for one hour; no liquid pools; all released chemicals in vapor or gaseous state; chemical release is at ambient temperature and at ground level; chemical gas or vapor cloud is neutrally buoyant; and no design features prevent downwind dispersion. The calculated threshold quantities were rounded by OSHA to further simplify the standard.
The lowest threshold quantity that the Agency has used is 100 pounds (45.4 kg) for the most hazardous of the chemicals listed. The OSHA threshold quantities are the same or somewhat greater than the Delaware "sufficient quantity level" (threshold quantity) due to the rounding up by the Agency for the vast majority of the toxic chemicals listed. This has been done to simplify the application of this final rule and also in recognition that the Agency has other standards which address the hazards of lower quantities of toxic materials in the workplace.
OSHA specifically solicited comments on the sufficiency of the list and threshold quantities in appendix A (55 FR at 29158). Appendix A generated a significant amount of discussion during this rulemaking.
Some commenters (e.g., Ex. 3: 18, 35, 89, 152) asked why OSHA's resulting list was different than the Environmental Protection Agency's (EPA) Extremely Hazardous Substance (EHS) list and some suggested further expansion of the list. For example the Consumer Policy Institute (Ex. 3: 152, p.2) stated:
CPI recommends that the highly hazardous substance list be expanded to include all substances on the EPA SARA Title III list of extremely hazardous substances, all substances found to be involved in incidents at facilities and all substances listed by the European Economic Community under the Seveso directive.
The Shipbuilders Council of America (3:18, p.4) indicated:
[It] is recommended that the two agencies [OSHA and EPA] publish one consistent list of chemicals which both would consider "extremely" or "highly" hazardous. Employers would then be required to deal with one list of chemicals for reporting purposes under SARA regulations and for safely managing processes that use these chemicals under the OSHA regulations.
Under section 302 of the Superfund Amendments and Reauthorization Act (SARA) also known as the Emergency Planning and Community Right-to-Know Act (42 U.S.C. 11001 et seq.), EPA was required to publish a list of extremely hazardous substances with threshold planning quantities which would trigger planning in states and local communities (52 FR 13378). EPA's EHS list is quite extensive (more than 300 hazardous substances) and serves as an emergency response planning list directed toward addressing hazards to the public and the environment.
Section 304 of the Clean Air Act Amendments (CAAA), paragraph (b), List of Highly Hazardous Chemicals, mandates that:
The Secretary [of Labor] shall include as part of such standard [Chemical Process Safety Standard] a list of highly hazardous chemicals, which include toxic, flammable, highly reactive and explosive substances (Emphasis added).
The paragraph further indicates that the Secretary may include those chemicals listed by the Environmental Protection Agency under section 302 of the Emergency Planning and Community Right to Know Act of 1986.
Further the CAAA did not anticipate that even EPA would adopt the whole EHS list for the purpose of prevention of accidental chemical releases. Section 301(r) indicated that EPA's first list must contain no less than 100 substances which may be from the EHS list. EPA's 301(r) list is not a planning tool but rather a list that requires covered plants to develop comprehensive Risk Management Plans.
While OSHA considered this list, it does not consider all of the substances on the EHS list to present a potential catastrophic situation for employees in workplaces within its jurisdiction. Therefore, OSHA believes it has acted reasonably and appropriately in evaluating a variety of chemical lists including the EHS list in order to identify those highly hazardous chemicals which present a potential catastrophic threat to employees. These events typically include toxic releases, fires and explosions as opposed to potential environmental threats such as spillage of a pesticide.
Several participants in the rulemaking (e.g., Ex. 3: 6, 45, 51, 150; Ex. 141) advised OSHA that certain chemicals which appeared in appendix A, including dimethyl sulfide, isopropyl formate, and methyl disulfide had been deleted from EPA's EHS list based on a reconsideration of the data and a determination that the data did not support the inclusion of the chemicals on the EHS list. OSHA agrees that it is appropriate to delete these chemicals from its list since a redetermination had been made that data and information available did not support their inclusion on the EPA list. OSHA has therefore removed these chemicals from its appendix. Other changes to OSHA's appendix A list include: (1) A change in the amount of anhydrous ammonia from 5,000 to 10,000 pounds to better reflect its hazards; (2) a change in the stated threshold quantity of ammonia solutions from 10,000 to 15,000 pounds to better reflect its dilution by water and its consequent decreased flammability and potential adverse health affects; (3) a change in the amount of 3-bromopropyne (also listed as propargyl bromide) from 7,500 pounds to 100 pounds to reflect its toxic characteristics rather than its reactive characteristics; (4) elimination of the erroneous description of formaldehyde, in "concentrations greater than 90%," since no such concentration exists, and the addition of formalin in the description to assure that no doubt exists that formalin is covered under the formaldehyde entry; (5) an editorial change to peracetic acid (also called peroxyacetic acid) which inadvertently did not include the description "concentration >60%" which was correctly included in the subsequent entry of peroxyacetic acid; (6) the elimination of the word "liquid" from the description of sulfur dioxide since it may also be a gas and the health hazards are the same regardless of its state; (7) and changes based on a reevaluation of available information, in the threshold amounts of allylamine from 1500 pounds to 1000 pounds, peracetic acid (also called peroxyacetic acid, concentration >60%) from 5000 pounds to 1000 pounds, and tetramethyl lead from 7500 pounds to 1000 pounds to better reflect their toxic hazards.
Some participants expressed their general support for the list contained in appendix A (e.g., Ex. 3: 17, 45, 59, 62, 82, 88, 95, 127, 134; Tr. 1999–2000). Allied-Signal Inc. (Ex. 3: 17, p.15) observed:
Appendix A is a credible compilation of chemicals that are sufficiently toxic and volatile that their release could result in a catastrophic event. We applaud OSHA's use of list of toxic and reactive/unstable chemicals developed by other Federal and State agencies to develop appendix A.
The American Paper Institute (Ex. 3: 45, p.10) indicated:
The approach of tying process safety management requirements to the presence or absence of listed chemicals is an imperfect one. While the list-based approach may mean that the rule is both over and under inclusive, we have devised no approach that more closely tailors the process safety management requirements to real process safety hazards.
In general, appendix A appears to be a sufficient compilation of chemicals.
BP America Inc. (Ex. 3: 59A) noted:
BP America has reviewed the list of Appendix A chemicals and believes that the current compilation of chemicals is acceptable.
Amoco Corporation (Ex. 3: 95) stated:
We think that the list of highly hazardous chemicals in appendix A is sufficiently comprehensive in nature and reasonable with regard to threshold quantity to adequately cover the most toxic and hazardous chemicals in current use.
American Cyanamid Company (Ex. 3: 127, p.2) indicated:
Mandatory appendix A is a sufficient compilation of chemicals for the initial coverage of this proposed standard. We could find no major omissions from appendix A. Its completeness is undoubtedly attributable to careful research on OSHA's part and the experience factor derived from review of similar lists * * *.
Lubrizol Petroleum Chemicals Company (Ex. 3: 134) stated:
The Houston plants agree with OSHA's belief that appendix A represents a reasonable and appropriate listing of chemicals and threshold quantities.
Finally, OSHA's expert witness, who worked for 37 years with Monsanto Company, the last 9 as corporate safety director (worldwide responsibilities) (Tr. 1999–2000) testified:
In my opinion, the list of chemicals with the stated threshold quantities in the appendix is reasonable and provides the focus for preventing catastrophic releases of hazardous materials in the processing industry.
OSHA based its list on information drawn from a variety of sources, including other federal and state agencies, national consensus standards and the United Kingdom Health and Safety Commission.
While any listing of hazardous chemicals is subject to revision, I support the listing of the chemicals in the appendix as appropriate.
It encompasses, in my experience, the vast majority of chemicals likely to cause catastrophic release and its consequences.
However, a number of participants felt OSHA should provide a technical basis for the appendix A list and its threshold quantities (e.g., Ex. 3: 20, 46, 48, 53, 97, 101, 129; Ex. 131; Tr. 86, 1015). Some participants noted that if no published technical basis existed then it would be difficult to add chemicals at a later time (e.g., Ex. 3: 46, 48; Ex. 131; Tr. 1016). OSHA believes that its review of available literature for the development of its list of highly hazardous chemicals and its technical approach (discussed previously) is an appropriate method to determine which toxic chemicals should be included on its list. OSHA also believes that it is reasonable to defer to groups that have already published their lists and which have withstood public scrutiny. OSHA is convinced that it has taken a correct and reasonable approach.
Additionally OSHA believes that additional consideration would be required to fully evaluate a "technical basis" other than that used by the Agency (e.g., a formula). The Organization Resources Counselors (ORC) recommended the use of a technical basis throughout the rulemaking. In its post-hearing comment (Ex. 131, Table A-1), ORC reassessed the OSHA appendix A list based on its suggested technical basis (a formula, similar to the Substance Hazard Index proposed by OSHA). The outcome resulted in significant differences in the threshold quantities for many chemicals. For example, OSHA lists the threshold quantity of acryl chloride at 250 pounds and arsine at 100 pounds; ORC lists the threshold quantity of acryl chloride at 200 pounds and arsine at 450 pounds. While the ORC approach is an interesting one, OSHA believes that its approach is also correct, and has decided to retain it in the final rule.
As noted, some participants indicated that without a technical basis for appendix A it would be difficult for OSHA to readily update its list in the future. OSHA believes that a means for adding highly hazardous chemicals to appendix A in the future can be considered at such time as the need arises. As discussed, OSHA has explained its technical basis for appendix A highly hazardous chemicals. OSHA does not believe that it should modify the approach it used in the development of the appendix A list especially in light of the many changes that would be necessitated through the incorporation of other suggested approaches. In addition, with the exception of a few corrections and clarifications, there were no objections raised as to the appropriateness of the threshold quantities proposed, but as stated, general support for the list and threshold quantities.
As discussed, the application section (proposed paragraph (b)(1)(i)) triggering coverage of those processes using chemicals in quantities listed in appendix A, has been clarified to lessen confusion concerning the aggregation of chemicals by changing the term "processes" to "a process." No other changes have been made to the text of the paragraph but it has been redesignated as paragraph (a) and thus becomes paragraph (a)(1)(i).
The application section (paragraph (b)(1)(ii)) proposed to include processes involving flammable liquids or gases in quantities of 10,000 pounds or more. It has been suggested that OSHA cover flammable gases and liquids with a potential release of five tons of gas or vapor (Ex. 2: 10, 11).
The American Petroleum Institute's (API) Recommended Practice 750 (RP 750), Management of Process Hazards, uses the potential release of gas or vapor approach. The stated purpose of RP 750 is to help prevent the occurrence, or minimize the consequences of, catastrophic releases of toxic or explosive materials (Ex. 2: 11). Additionally in the application statement of RP 750 it is stated that the recommended practice is intended for facilities that use, produce, process, or store:
Flammable or explosive substances that are present in such quantity and condition that a sudden, catastrophic release of more than 5 tons of gas or vapor can occur over a matter of minutes, based on credible failure scenarios and the properties of the materials involved.
Appendices A and B to RP 750 provide information and guidance on the application of this paragraph.
However, OSHA believed that assessing the variables and assumptions inherent in determining whether five tons of gas or vapor could be released (temperature, pressure, rate of release, etc.) using undefined "credible release scenarios," would be an unnecessary burden on employers and compliance personnel. More importantly, depending on these variables, substances might sometimes be covered and sometimes not be covered, a potentially confusing situation. Therefore, OSHA decided to use a worst case approach and assume that the entire five ton quantity of a highly hazardous chemical could be released into gas or vapor.
In Issue 1 in the notice of proposed rulemaking (55 FR at 29158) OSHA requested comments on other ways in which flammable liquids and gases might be covered. A variety of commenters supported the 10,000 pound threshold amount for coverage of flammable liquids and gases which OSHA proposed (e.g., Ex. 3: 45, 59, 81, 95, 99). BP America (Ex. 3: 59A) remarked:
BP America also believes that a five ton release of vapor as explained in the API Recommended Practice (RP) 750 is most appropriate. However, BP understands the administrative difficulties relating to enforcement of this provision and, therefore, supports the five ton flammable liquids and gases criterion as defined in the standard.
Goodyear Tire & Rubber Company (Ex. 3: 81) noted:
The threshold quantity of 10,000 pounds for flammable liquids and gases is appropriate for the standard.
Other participants (e.g., Ex. 3: 20, 28, 69, 71, 80, 91, 106, 108, 127, 129, 173; Tr. 1513, 2583, 3193) recommended that OSHA address only the amount of flammable liquid or gas that could result in the release of 5 tons of vapor using worst case release conditions in conjunction with appropriate flash calculations instead of credible release scenarios. For example, API (Ex. 3: 106A, p. 4) asserted:
As you know, API's Recommended Practice 750 applies to flammable liquids provided 10,000 pounds (5 tons) of gas or vapor can be released over a matter of minutes during credible release scenarios. We understand OSHA has rejected this approach . . . due to regulatory difficulties in defining credible release scenarios. Although API prefers the API RP 750 approach, we can accept the 10,000 pounds of inventory criteria as being simpler. However, API remains convinced that only the vaporizable portion of the flammable liquid should be included in the inventory.
Our concern stems from the fact that oil and gas operations handle complex substances which often will invalidate the appropriateness of the 10,000-pounds-of-inventory approach. For example, a release of 10,000 pounds of crude oil constitutes only a small fraction of the hazards of a release of 10,000 pounds of the C2-C6 hydrocarbon series. This is because only a small part of a crude oil release will immediately vaporize, and it is only the vaporizable portion that could potentially constitute a catastrophic hazard.
For these reasons, we propose . . .
"Processes which involve flammable liquids or gases (as defined in 1910.1200(c) of this part) onsite in one location, in quantities that will vaporize 10,000 pounds or more under worst-case release conditions * * *."
While this approach requires a routine flash calculation, it does remove the judgement regarding credible release scenarios that is currently provided by the RP-750 approach.
However, OSHA believes that the modified API recommendation calls for the use of yet another judgement by its use of the undefined "worst case release conditions." Further, OSHA believes that RP 750 does not directly address the hazards to employees of fires which might occur rather than explosions. For example, in appendix A of RP 750, the general discussion on the probability of ignition and explosion of vapor clouds (Ex. 2: 11, p. 11) reads:
When a hydrocarbon vapor cloud forms, the cloud may dissipate harmlessly, be consumed by a flash fire without causing significant blast overpressures, or explode * * *.
Although vapor cloud explosions have occurred after release as small as 1 ton, most of these explosions have occurred as a result of release of more than 5 tons * * *.
OSHA's proposed process safety management standard was directed toward the hazards of fires as well as the hazards of explosions.
For these reasons, OSHA continues to believe that the use of a 10,000 pound threshold for flammable liquids or gases is a reasonable approach and the provision has been retained in the final standard. This final provision becomes paragraph (a)(1)(ii).
In the proposed application section (paragraph (b)(1)(ii)(A)) OSHA proposed to exempt from coverage hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane or oil used for comfort heating). OSHA believed that this type of use did not have the same catastrophic potential as those which were proposed. The exemption would exclude fuels used in general heating systems and refueling systems (for fleets) throughout the country. Such uses would still be regulated by other existing specific OSHA standards (such as § 1910.106, flammable and combustible liquids, and § 1910.110, liquefied petroleum gases) which adequately address these uncomplicated uses.
Additionally, in Issue 3 of the hearing notice (55 FR at 46075) OSHA indicated that some confusion existed regarding this proposed exemption. For example, some participants asked if this exemption included furnaces used in a process. Therefore OSHA solicited comments on this issue. Organization Resources Counselors (ORC, Ex. 131, p. 3–4) commented:
A number of persons testifying during the public hearings indicated concern and confusion over the wording of the proposed exemption for hydrocarbon fuels that are present in quantities greater than 10,000 pounds, but are not part of a process. Examples of these would be propane or oil used for comfort heating and gasoline or diesel fuel for use in industrial vehicles. To remedy this confusion, ORC recommends that subparagraph (b)(1)(ii)(A) be amended to read:
Hydrocarbon fuels used solely as a fuel at a facility which is not otherwise covered by this rule.
This change will ensure that facilities which use hydrocarbon fuels in a processing step are not excluded from coverage under the standard, but that this subparagraph of the final rule properly continues to exclude facilities at which processing aberrations are absent * * *.
Further the American Petroleum Institute (Ex. 137, p. 12–13) observed:
It is our understanding that OSHA's intention in providing exemption (b)(1)(ii)(A) was to exclude the enormous number of small business locations across the nation which would not be covered by the proposed rule, except for their on-site storage of hydrocarbon fuels for low-risk applications such as heating, drying, and the like. Such activities are not the subject of this rule, and this exclusion is entirely appropriate.
On the other hand, interpreting this exclusion to apply to hydrocarbon fuels used for process-related applications such as furnaces, process heaters, and the like at facilities covered by the rule was not intended.
OSHA agrees with these participants and has changed the final provision to clarify its intent not to exclude from coverage hydrocarbon fuels used for process related applications such as furnaces, heat exchangers and the like at facilities covered by this rule. It becomes final paragraph (a)(1)(ii)(A) and exempts from coverage:
Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating or gasoline used for vehicle fueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by this standard.
The second proposed exemption concerned flammable liquids stored or transferred which are kept below their atmospheric boiling point without benefit of chilling or refrigeration and was proposed paragraph (b)(1)(ii)(B). Again, OSHA did not believe that the flammable liquids as described in the exemption have the same potential for a catastrophe as those proposed. Again an OSHA standard already regulates the treatment of the exempted flammable liquids (§ 1910.106, flammable and combustible liquids).
While many participants supported the exemption concerning flammable liquids stored or transferred which are kept below their atmospheric boiling point without benefit of chilling or refrigeration, they recommended that OSHA clarify the exemption (e.g., Ex. 3: 48, 71, 106, 108, 119, 120; Ex. 93; Ex. 119; Tr. 2012) by using established language from its standard concerning flammable and combustible liquids. For example, the American Petroleum Institute (Ex. 3: 106A, p. 4–5) concluded:
OSHA's phrase "atmospheric boiling point" introduces unnecessary problems in applying this important exemption to various complex substances such as crude oil which do not have precise boiling points. OSHA has previously resolved this problem by providing definitions for "atmospheric tank" and "boiling point" in subpart H—1910.106(a)(2) and (a)(3).
OSHA agrees with this suggestion concerning the use of existing definitions; this does not change the intent of the exemption and merely clarifies the exemption. Therefore, proposed paragraph (b)(1)(ii)(B) becomes final paragraph (a)(1)(ii)(B) and has been clarified by adding existing language from OSHA's standard for flammable and combustible liquids, § 1910.106, "atmospheric tank" and "boiling point," and providing a definition for these terms in lieu of the proposal's term "atmospheric boiling point." OSHA believes that this exemption is reasonable and appropriate.
In the proposal paragraph (b)(1)(iii) proposed to cover the manufacture of explosives as defined in paragraph (a)(3) of § 1910.109, "Explosives and blasting agents." Additionally, proposed paragraph (b)(1)(iv) covered the manufacture of pyrotechnics (as defined in paragraph (a)(10) of § 1910.109), including fireworks and flares.
Although there is an existing OSHA standard for explosives and pyrotechnics (§1910.109), that standard does not address the hazards associated with their manufacture. OSHA believed that the requirements contained in the proposed process safety management standard should be applied to the explosive and pyrotechnic manufacturing process because of their potential for producing a major accident during manufacture. Therefore the proposal addressed a gap that exists in the Agency's current standard for explosives and pyrotechnics.
Some rulemaking participants (e.g., Ex. 3: 40, 52, 60; Tr. 3011–21) asserted that the manufacture of explosives and pyrotechnics should not be covered by proposed § 1910.119, because the hazards associated with these substances are already adequately covered by § 1910.109 of the OSHA standards, as well as requirements of
other regulatory agencies. For example, a commenter from the Society of Explosives Engineers (S.E.E., Ex. 3: 40, p.1–2) stated:
Because explosives are currently regulated by so many Federal, state, and local agencies, it is highly questionable that they could result in a catastrophic event typical of those described by OSHA in the background discussion.
S.E.E. believes that uniform, workable regulations are a key factor in the promotion and maintenance of explosive safety. We further believe that the use, storage, handling and transportation of explosives are already adequately covered by regulations in 29 CFR (OSHA), 30 CFR (MSHA and OSM), 49 CFR (DOT) and the regulations of state and local regulatory agencies and there is no need for OSHA to include the manufacture of explosives in 29 CFR 1910.119.
With respect to the manufacture of fireworks, a hearing participant from the American Pyrotechnics Association (APA, Tr. 3011) testified:
The APA endorses the concept of federal standards designed to adequately prevent or minimize the consequences of chemical accidents involving highly-hazardous chemicals. However, the APA believes that the statements cited by the Agency are incorrect.
The inclusion of fireworks manufacturing processes is unwarranted and could be interpreted to require protective measures which could impose substantial burdens on the fireworks industry without making a significant contribution toward workplace safety.
In its comment (Ex. 3: 52), the APA further asserted that a gap does not exist in the OSHA standards with respect to the manufacture of fireworks. APA stated that the Bureau of Alcohol, Tobacco and Firearms (BATF) currently regulates the quantity of explosive and pyrotechnic materials which may be used at one time, and the distances between process and storage buildings. The APA contended that the BATF requirements and the requirements contained in § 1910.109 of the OSHA standards, together with OSHA enforcement of provisions contained in the National Fire Protection Association (NFPA) standard, "Manufacture, Transportation, and Storage of Fireworks" (NFPA-1124), adequately regulates the manufacture of fireworks.
Other rulemaking participants, however, strongly supported the inclusion of the manufacture of explosives and pyrotechnics within the scope of this proposed standard, and objected to excluding these activities. For example, a commenter from the Oil, Chemical & Atomic Workers [OCAW, Ex. 114, p.1–2] said:
[As] far as the inclusion of the explosives industry in the standard coverage, OCAW feels there is no room for debate. These industries are no different from the industries that fall within the scope of the proposed 1910.119. Further, the fact that there is already an explosives standard 1910.109 does not justify their exclusion from 1910.119 as 1910.109 does not address process safety in any manner.
OCAW buttressed their position (Ex. 114) concerning the inclusion of explosives manufacturing within the scope of this proposed standard by elaborating on the similarity of the explosives industry to other chemical industries that are proposed to be covered by § 1910.119.
In its post-hearing comment, the United Steelworkers of America (USWA, Ex. 118) asserted:
In the proposed Process Safety Management of Highly Hazardous Chemicals standard, paragraphs (b)(1) (iii) and (iv) proposed to include the manufacture of explosives and pyrotechnics. The United Steelworkers of America supports this inclusion. It is unthinkable that OSHA would even consider to exempt this industry, given the products that it manufactures and its accident history. How anyone could argue that the strategies for effective process safety management outlined in the proposed standard could not, or would not, enhance the overall safety of this industry and aid in the prevention and mitigation of major accidents is beyond reason.
Also in their comment, USWA described several incidents that occurred in the explosives industry, and with respect to one particular plant (Ex. 118, p.2), remarked:
In the past 50 years, 60 workers lost their lives at the plant. Of the six major accidents at the facility, not inclusive of the most recent incident, five of these were directly related to process safety hazards that are not covered by § 1910.109 or any other existing OSHA standard. Even though OSHA was able to cite the company for specific violations of existing standards, it has been repeatedly forced to rely on the general duty clause to address major concerns because of the absence of a process safety management standard.
One rulemaking participant (Ex. 3: 23) disagreed that § 1910.119 should apply to the manufacture of explosives and pyrotechnics and suggested, instead, that § 1910.109 be revised to include safety provisions for these manufacturing activities. Other rulemaking participants (e.g., Ex. 3: 62, 100, 116) believed that proposed § 1910.119 provided a technically sound, realistic methodology to improve explosive manufacture safety. They suggested, however, that the provisions of § 1910.119 be incorporated into § 1910.109 of the OSHA standards, so that all requirements pertaining to explosives will be contained in one standard.
For example, a hearing participant from the Institute of Makers of Explosives (IME, Tr. 1244) testified:
IME supports OSHA's proposed regulation for process safety management as a technically sound, logical, and realistic way to offer a methodology to improve explosive manufacture safety. However, IME recommends that OSHA delete the manufacture of explosives from § 1910.119(b)(1)(ii) and incorporate these safety regulations for the manufacture of explosives into 29 CFR 1910.109 Explosives and Blasting Agents at (b)(2).
It was contended (Ex. 130) that this approach would continue OSHA's 20-year history of maintaining a vertical regulation for commercial explosives; eliminate the alleged ambiguity that exists in the proposed rulemaking by including the manufacture of explosives in the application of the standard; and, would recognize the unique conditions under which explosives are manufactured.
In subsequent post-hearing comments, however, both Hercules and the IME (Ex. 125; Ex. 130) submitted draft regulations for the manufacture of commercial explosives. They suggested that the manufacture of commercial explosives be removed from the scope of § 1910.119, and that these draft regulations be included in a revision to § 1910.109 as an appropriate code to regulate the manufacture of commercial explosives.
OSHA appreciates the time and effort involved in developing these draft regulations, and believes that they constitute an excellent source document that the Agency can utilize when it revises the standards contained in § 1910.109. However, OSHA will not incorporate these draft regulations into § 1910.109 as a part of this rulemaking process since they did not receive the type of public comment and evaluation contemplated by section 6(b) of the Occupational Safety and Health Act.
After a thorough analysis of all of the information contained in this rulemaking record, OSHA remains convinced that the hazards associated with the manufacture of explosives and pyrotechnics have the potential of resulting in a catastrophic incident, and pose a significant risk to employees and that the manufacture of explosives and pyrotechnics should be covered by the provisions of the final process safety management rule.
However, the Agency has been persuaded by those participants who suggested that OSHA delete the manufacture of explosives and pyrotechnics from proposed § 1910.119, and incorporate the provisions of the
process safety management standard into 29 CFR 1910.109, "Explosives and Blasting Agents." This will have the effect of referencing in one place, the specific and significant OSHA requirements pertaining to explosives and blasting agents.
Accordingly, proposed paragraph (b)(1)(iii) has not been retained in the final rule for § 1910.119. Rather, § 1910.109 has been revised to add a new paragraph, (k)(2), that requires the manufacture of explosives to comply with the provisions contained in § 1910.119, process safety management of highly hazardous chemicals.
Similarly, proposed paragraph (b)(1)(iv) has not been retained in the final rule for § 1910.119. Again, § 1910.109 has been revised to add another new paragraph, (k)(3), that requires the manufacture of pyrotechnics, including fireworks and flares, to comply with the provisions contained in § 1910.119, process safety management of highly hazardous chemicals.
During this rulemaking process, some concern was expressed that this standard could be interpreted, inappropriately, to apply to all explosive and pyrotechnic manufacturing operations, even those operations of the manufacturing process where explosives or pyrotechnics are not present (e.g., Ex. 3: 62; Ex. 125; Ex. 130). This is not the intent of OSHA. The Agency wants to make it clear that the provisions contained in this final rule apply to explosives and pyrotechnics manufacturing operations only when such substances or other chemicals covered by the standard or in appendix A are present.
Finally, in paragraph (b)(1)(v) OSHA proposed a means for assuring that newly developed toxic chemicals which were not listed in appendix A but were introduced into a process would be evaluated for their degree of hazard and be included in the standard's coverage. A formula, the Substance Hazard Index (SHI), was contained in appendix B of the proposal. The formula relied on the availability of information concerning a chemical's level of hazard as established by the American Industrial Hygiene Association (AIHA) in its Emergency Response Planning Guidelines (ERPGs). The purpose of the SHI was to establish, using certain data, a relative ranking of toxic chemicals.
OSHA acknowledged in the proposal in Issue 2 (55 FR at 29158) that there might be some shortcomings in the use of the SHI. As noted, an important part of the SHI formula relied on the availability of the AIHA computation of ERPGs for individual chemicals. Only a few ERPGs are presently available.
Generally participants objected (e.g., Ex. 3: 2, 12, 17, 33, 45, 46, 47, 48, 50, 59, 60, 64, 69, 71, 82, 86, 95, 101, 112, 122, 127, 132, 137, 152, 162, 171; Ex. 148; Tr. 968, 1017, 2177, 2854) to using the SHI and cited several reasons for not using it. They observed that OSHA is deferring rulemaking to a private entity; there is no reason to believe that ERPG development can or will be accelerated in order to be responsive to the standard; the 500 pound threshold quantity is arbitrary; and OSHA already has a sound mechanism for adding chemicals to appendix A, the rulemaking process.
OSHA has been convinced by participants in the rulemaking not to use the SHI formula to add additional toxic chemicals to the appendix A list at this time. While OSHA believes a formula would be a worthwhile approach to including new toxic chemicals under the standard, it has been persuaded by commenters that it should use section 6(b) rulemaking procedures until such time as a better formula can be developed by OSHA. Therefore this paragraph has been deleted from the final rule and OSHA will either try to develop a better formula or rely on rulemaking on a chemical by chemical basis to add chemicals to appendix A.
Certain exemptions were contained in the proposed application paragraph of the process safety management rule (paragraphs (b)(2) (i) through (iii)). These exemptions included: retail facilities; oil and gas well drilling and servicing; and normally unmanned remote facilities.
With respect to the exclusion of retail facilities and normally unmanned remote facilities, OSHA believed that such facilities did not present the same degree of hazard to employees as other workplaces covered by the proposal. Therefore OSHA should not require a comprehensive process safety management system in addition to other applicable OSHA standards addressing flammable and combustible liquids, compressed gases, hazard communication, etc., for retail facilities and unmanned remote facilities.
Certainly, highly hazardous chemicals may be present in both types of work operations. However, OSHA believes that chemicals in retail facilities are in small volume packages, containers and allotments, making a large release unlikely. OSHA received few comments disagreeing with the exemption of retail facilities (e.g., gasoline stations). OSHA has retained the exemption in the final rule.
In normally unmanned remote facilities (defined in proposed paragraph (c) and called "normally unoccupied remote facilities" in final paragraph (b)), the likelihood of an uncontrolled release injuring or killing employees is effectively reduced by isolating the process from employees. OSHA believes that the present OSHA standards contained in subpart H, such as § 1910.101, compressed gases, and § 1910.106 flammable and combustible liquids and in part 1910, subpart Z, toxic and hazardous substances, adequately address the chemical hazards presented in these work operations.
OSHA did receive significant comment supporting the exemption of normally unmanned remote facilities (e.g., Ex 3: 30, 62, 64, 69, 71, 79, 129). Others suggested that OSHA redefine "normally unmanned remote facility" (e.g., Ex. 26, 32, 39, 69, 80, 82, 106, 108, 129). OSHA has retained the exclusion of normally unmanned remote facilities because the Agency believes such facilities pose a reduced likelihood of releases that could harm employees. The issue of modifying the definition will be discussed in the section concerning definitions.
OSHA also proposed to exclude oil and gas well drilling and servicing operations because OSHA had already undertaken rulemaking with regard to these activities (49 FR 57202). OSHA continues to believe that oil and gas well drilling and servicing operations should be covered in a standard designed to address the uniqueness of that industry. This exclusion is retained in the final standard since OSHA continues to believe that a separate standard dealing with such operations is necessary.
Finally, a number of participants requested special consideration for their processes or exemption from the standard. For example, concern was expressed by participants who conduct batch processing operations (e.g., Ex. 3: 50, 55, 74, 184, 189; Ex. 89; Tr. 972, 3202) regarding their ability to comply with the standard due to the dynamic nature of batch processing. With respect to this, the Synthetic and Organic Chemical Manufacturers Association (SOCMA, Ex. 3: 50, p.6-7) stated:
Batch processes are distinct from continuous operations in that a continuous operation has a constant raw material feed to the process and continual product withdrawal from the process. A batch process has an intermittent introduction of frequently changing raw materials into the process, varying process conditions imposed on the process within the same vessel depending on the product being
manufactured. Consequently under the process safety rule as proposed, a batch processor will be required to perform a process hazard analysis each time an order comes in for a chemical that may differ only slightly from the one previously produced.
A batch processing plant is in a constant state of change, always being adapted for different projects. It is not unusual for a batch processor to have a different plant configuration weekly. SOCMA suggests that batch processors be given the flexibility to do a process hazard analysis that is representative of many similar batches. If this recommendation is not adopted, then given the fundamental differences of batch processors, SOCMA recommends that OSHA address batch process safety in a separate rulemaking.
The Ecological and Toxicological Association of the Dyestuffs Manufacturing Industry (Ex. 3: 55) noted:
Based on our near total dependence on batch processing, we support the comments submitted by SOCMA * * *. We also strongly urge OSHA to address batch process safety in a separate rule making given the major differences in operation of continuous and batch processing plants.
However, other participants who have been involved in running both continuous processing and batch processing indicated that the standard for process safety management is appropriate for batch processing (Ex. 128; Tr. 1031, 1936). The Chemical Manufacturers Association (CMA, Ex. 128, p.7–8) stated:
CMA does not believe that facility owners/operators with batch processes should be exempted from complying with the proposed PSM standard * * *. The key question is whether the hazardous material is present in an amount at or above the threshold quantity. If the answer to this question is yes, then the provisions of the proposed standard should apply. CMA companies have extensive experience handling listed materials both in batch and continuous facilities. CMA supports applying the provisions of the proposed standard to any facility (batch or continuous) where the threshold quantities are exceeded.
OSHA agrees that the key question for coverage is whether the highly hazardous chemical is present in an amount at or above the threshold. However, OSHA acknowledges the concern of SOCMA regarding the potential difficulty of conducting a separate process hazard analysis for each variation of a batch process. OSHA has accepted SOCMA’s suggestion concerning the development of a generic process hazard analysis which is representative of similar batches. Accordingly, OSHA has included information in appendix C on conducting process hazards analyses for batch operations.
Some participants felt that their use of a particular highly hazardous chemical should not be covered in the process safety management standard since they observed that their type of process had not been included in the events described in the proposal; they did not feel their processes could create a catastrophic event; and that the broad definition of process used by OSHA captured industries which did not really process chemicals in the same manner chemical plants and refineries do. These participants address, for example, ammonia refrigeration (Ex. 3: 162, 168); steelmaking (Ex. 3: 161, 172); research and development facilities including pilot plants (Ex. 3: 56, 69; Tr. 662); bulk liquid terminals (Ex. 3: 8, 11, 16A, 37); and chlorination facilities (Ex. 90).
First, the catastrophic events described in the notice of proposed rulemaking were simply examples of what could happen upon the release of a highly hazardous chemical and in no way reflect all incidents which have occurred or which have the potential to occur. The National Wildlife Federation (Ex. 3: 86, p.3) observed:
The Acute Hazardous Events (AHE) Database, put together by EPA, catalogued 11,048 events spanning 8 years. In other words, this partial listing of the chemical incidents in the U.S. provides a record of nearly 4 accidents every day.
Second, OSHA has developed what it considers to be a reasonable and appropriate coverage of processes involving highly hazardous chemicals and further believes that those chemicals in their threshold amounts have the potential for a catastrophic release. OSHA believes its listing of highly hazardous chemicals fully meets the intent of the Clean Air Act Amendments (CAAA) which require OSHA to promulgate “a chemical process safety standard designed to protect employees from hazards associated with accidental release of highly hazardous chemicals in the workplace” and which require the standard include a “list of highly hazardous chemicals which includes toxic, flammable, highly reactive and explosives substances.”
Third, as the Chemical Manufacturers Association succinctly observed, and with which OSHA concurs, the key question should be whether the highly hazardous chemical is present at or above the threshold quantity. Further, the United Steelworkers of America (Ex. 118, p.4) stated:
In the opinion of the USWA, there is no need to write a specific exemption for any industry. Section [b](1) already limits the standard to those processes which involve a highly hazardous chemical in sufficient quantities to cause a major accident. If a particular plant does not contain such a process, it will not be covered. If it does contain a hazardous process, it should be covered. There is no legitimate need for any further exemption * * *.
OSHA agrees with this rationale.
Finally, many participants (e.g., Ex. 3: 39, 41, 51, 69, 96, 106, 150, 173; Ex. 91; Ex. 93; Ex. 127; Tr. 1532, 1818, 2579) addressed their belief that gas processing should be excluded from the coverage of the process safety management standard. For example, the Gas Processors Association (Ex. 3: 28A, 1–3) stated:
75% * * * of GPA member companies are small-to-medium sized independent, non-integrated producers and processors of natural gas * * *. GPA suggests that a policy similar to those found in certain plans developed for other government agencies could be utilized. In this approach small, remote, low risk facilities which qualify should be part of a two-tier concept in which the operator would develop and have available locally a plan describing efforts toward process safety management in lieu of full process hazard management. In the event of a major release or failure to maintain predefined accident experience standards, the local plan would be submitted automatically to OSHA for review and action. OSHA could require revision of the plan or mandate full compliance with Part 1910.119.
The American Gas Association [Ex. 3: 51, p.2] observed:
OSHA’s broad proposal could apply to natural gas and liquefied natural gas (LNG) facilities used in the distribution, transmission and storage of gas, except for those facilities that are “unmanned remote facilities.”
AGA further observed (p.3) that the standard is overly broad and that it is inappropriate because OSHA is preempted and there are major differences in processes and risk of chemical explosions or accidents at natural gas and LNG facilities as compared with chemical plants and refineries.
The American Petroleum Institute (API, Ex. 3: 106A, p.2) remarked:
API is concerned that OSHA’s proposal to include all flammable liquids and gases * * * will result in the application * * * to an enormous number of relatively low hazard facilities, such as natural gas handling facilities, diluting industry’s overall ability to comply with this important rule.
API urges OSHA to exclude certain natural gas handling facilities * * *. Our rationale is as follows:
High methane natural gas has a density less than that of air, which aids in dispersion * * * has low reactivity and low burning speed * * * flame speeds in natural gas
clouds are far below those that would produce dangerous overpressure.
Confinement, such as in enclosed compressor buildings, can increase the risk of localized damage; however, flame speeds decelerate very rapidly beyond the boundaries of the confinement, and overpressure decreases markedly, even if well mixed vapor clouds exist outside. Natural gas is flammable, of course, and does present a heat radiation hazard when burning. However, the lack of open air overpressures limit the extent of potential injuries.
At the Washington, DC, hearing an OSHA panel member inquired of a representative of API (Tr. 1885):
OSHA Panel Member: " * * * you're talking about some exemptions for gas processing plants, basically those that are dealing mainly with methane * * * could you expand as to what type of radiation hazard we're talking about in a typical situation? Is the danger area 100 meters, 10 meters, 1,000 meters * * * .
API Representative Response: That depends purely on the size of the cloud and for how long it burns. If we're talking about an unplanned release that burns in a matter of seconds, then we're talking about, at most, a very few thousand BTUs that would—per square foot—that would be felt over a distance of only a few hundred feet, and probably less than 100 yards from outside the burn cloud. Now of course, if people were inside the burn cloud, that's an entirely different matter. They would probably be killed by the cloud or by inhaling the combustion gases.
OSHA disagrees with commenters that gas processing should be excluded from coverage. While OSHA is very concerned with explosions, OSHA is also concerned with fires resulting from releases of highly hazardous chemicals (55 FR at 29150) which as indicated above can occur and clearly endanger employees in the area. Therefore, OSHA believes that gas plants are appropriately covered by the process safety management standard.
Definitions: Paragraph (b)
Paragraph (b) contains the definitions of terms as they are used in the final rule. The proposed standard contained definitions for the following terms: Facility, highly hazardous chemicals, hot work, normally unmanned remote facility, process, and substance hazard index (SHI).
The final standard contains definitions for the following terms: Atmospheric tank, boiling point, catastrophic release, facility, highly hazardous chemical, hot work, normally unoccupied remote facility, process, replacement in kind, and trade secret. OSHA has added definitions for "atmospheric tank" and "boiling point" which are already in use in the § 1910.106 standard for flammable and combustible liquids in order to clarify the exemption from coverage for flammable liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration.
A definition for catastrophic release was also added. The Organization Resources Counselors (Ex. 3: 53, p.3) advocated:
OSHA should add a definition for "catastrophic release" to make it clear that this standard is directed to major accidents which, as stated in the preamble, "have the potential of not only placing employees in grave and imminent danger but also could endanger employees throughout the workplace and even the general public." ORC recommends that the definition read as follows:
"Catastrophic release" means a major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals, that presents serious danger to employees or other persons both within and outside of the immediate workplace.
Other commenters supported the addition of a similar definition (Ex. 3: 12, 17, 48, 64, 71, 97, 101).
OSHA agrees that a definition for catastrophic release will provide for better consistency in the final standard. In the proposed standard OSHA used "catastrophic release" in paragraph (a), purpose, but in paragraph (m), incident investigation, OSHA used the term "major accident." Accordingly, OSHA has defined "catastrophic release" as recommended by ORC, leaving out any reference to "outside the immediate workplace" since OSHA only has jurisdiction to assure workplace safety. Consequently OSHA has changed "major accident" to "catastrophic release" in paragraph (m), incident investigation.
Some participants recommended defining "major accident" to mean any event involving fire, explosion, or release of a substance covered by this section which results in a fatality or five or more hospitalizations for medical treatment (Ex. 3: 106A). OSHA believes that the ORC definition for "catastrophic release" better reflects the intent of the Clean Air Act Amendments which require OSHA to develop a standard to prevent accidental release of chemicals which could pose a threat to employees and that, a definition of "major accident" is not needed.
Few participants raised significant issues concerning the definitions for facility, highly hazardous chemical and hot work. Therefore, these definitions remain the same as proposed.
As noted, OSHA excluded from coverage normally unmanned remote facilities for the reasons discussed above in the application section. OSHA defined "normally unmanned remote facility" in the proposal (proposed paragraph (b)(2)(iii)) as:
Normally unmanned remote facility means a facility which is operated, maintained and serviced by employees who visit the unmanned facility only periodically to check the operation and perform necessary operating or maintenance tasks. No employees are permanently assigned. Facilities meeting this definition must be remote from other facilities.
The American Petroleum Institute (API, Ex. 3: 106) suggested that OSHA recognize that unmanned facilities may exist in remote areas away from the general public locations which possess little potential for a catastrophic event. API as well as other participants (e.g., Ex. 3: 26, 32, 69, 80, 82, 106, 108, 119, 120, 129; Tr. 1540, 3127) recommended retention of this exemption with certain modifications including a redefinition to include 10 or fewer persons potentially affected. API (Ex. 3: 106A, p.3–4) stated:
OSHA recognizes that "unmanned" facilities may exist in remote, away-from-the-general-public locations which possess little potential for catastrophic event. API agrees that it is appropriate to exclude such facilities from this rule in order to allow industry to address more significant facilities with the limited resources available.
API urges OSHA to retain this important exemption and clarify its application by defining the term "normally unmanned" to mean "facilities where the number of persons potentially affected by a major accident is 10 or less". This approach is similar to that taken by the Department of Transportation.
In addition, API suggests that a definition for "remote facility", similar to that published by API in Publication 2510A, "Fire-Protection Considerations for the Design and Operation of Liquefied Petroleum Gas (LPG) Storage Facilities," April 1989, page 4, would be useful and should be included in the rule. The definition in Publication 2510A states:
"Remote facility means a facility that is 4000 feet or more from populated or industrial areas involving 10 or more persons."
API emphasizes that its purpose in urging these revisions is not to detract from the need to safely operate remote facilities; rather, it is to support the need to prioritize the allocation of limited resources, within OSHA and industry, for the implementation of the proposed rule.
OSHA's rationale for the exclusion of normally unmanned remote facilities from coverage was that these facilities did not have any employees present on a regular basis, i.e., a daily shift. Rather, employees only periodically visited the facility to check the operation and perform maintenance. OSHA believed that the likelihood of an uncontrolled release injuring or killing employees
was effectively reduced by the isolation of the process from employees. The reasons for the exclusion do not allow, nor does OSHA agree with, a redefinition of normally unmanned remote facility to a facility where the number of persons affected by a major accident is 10 or less.
Other participants supported the definition of normally unmanned remote facility but suggested that OSHA clarify the idea that the facility must be remote from other facilities [e.g., Ex. 3: 17, 25, 39, 48, 53, 64, 121]. The Organization Resources Counselors (Ex. 3: 53, p. 5) noted:
It is important to emphasize that a "normally unmanned remote facility" is not meant to apply to an area that is located in a distant corner of a large facility. Rather, it is meant to apply to facilities that are so far removed from any other facility that they could not contribute to a catastrophic release, fire or explosion as defined by this standard.
Additionally some participants recommended that OSHA modify the language regarding the status of employees who visit the facility periodically [e.g., Ex. 3: 30, 53, 62]. They observed that OSHA used the description in the definition "no employees are permanently assigned." Participants pointed out that an employee who visits such facilities periodically may in fact be assigned to the facility. The Chemical Manufacturers Association (Ex. 48, p. 8) suggested that OSHA define normally unmanned in the following manner:
"Normally unmanned remote facility" means a facility which is operated, maintained and serviced by employees based at a different location and who visit the remote facility to perform periodic tasks. Remote facilities are not within the boundaries nor are they contiguous to other operations of the employer.
OSHA agrees with these recommendations and has revised the definition to clarify that the facility must be "remote" and has changed the word "unmanned" to "unoccupied" to better reflect the Agency's intent. Accordingly this definition has been revised to read:
Normally unoccupied remote facility means a facility which is operated, maintained or serviced by employees who visit the facility only periodically to check its operation and to perform necessary operating or maintenance tasks. No employees are permanently stationed at the facility. Facilities meeting this definition are not contiguous with, and must be geographically remote from all other buildings, processes, or persons.
The definition of "process" remains essentially the same as proposed except for certain changes made to eliminate unnecessary words, and a modification and addition of language to clarify the intent of the definition. OSHA has eliminated the words "conducted by an employer." These words serve no purpose because OSHA is only addressing processes conducted by an employer.
The term "process" when used in conjunction with the application statement of the standard establishes the intent of the standard. The intent of the standard is to cover a "process" where the use, storage, manufacturing, handling or the on-site movement of a highly hazardous chemical exceeds the threshold quantity at any time. The boundaries of a "process" would extend to quantities in storage, use, manufacturing, handling or on-site movement which are interconnected and would include separate vessels located such that there is a reasonable probability that an event such as an explosion would affect interconnected and nearby unconnected vessels which contain quantities of the chemical that when added together would exceed the threshold quantity and provide a potential for a catastrophic release. In order to clarify this intent, a new sentence has been added to clarify the fact that interconnected and nearby vessels containing a highly hazardous chemical would be considered part of a single process and the quantities of the chemical would be aggregated to determine if the threshold quantity of the chemical is exceeded. The new sentence reads as follows: "For purposes of this definition, any group of vessels which are interconnected and separate vessels which are located such that a highly hazardous chemical could be involved in a potential release shall be considered a single process." Vessels located at more remote distances must be evaluated by the employer to determine if they would interact during an incident, and if such a reasonable condition exists these vessels would be included in the process. Where a dike is used around a liquid storage vessel to fully contain released material and prevent it from interacting with another vessel outside the dike, and neither vessel by itself contains the threshold quantity, then this physical barrier would be considered acceptable in making the two vessels remote from each other.
Additionally, some unnecessary words have been eliminated and the use of the word "movement" used in the proposal has been changed to "on-site movement" to clarify that transportation falling under DOT jurisdiction is not covered.
OSHA believes that its definition of process reflects the intent of the CAAA which requires that the standard be designed to protect employees from hazards associated with accidental releases of highly hazardous chemicals in the workplace.
Based on comments, OSHA has decided to add a definition for "replacement in kind" to clarify the types of changes which are not intended to be included in paragraph (1), management of change. The final definition states that "replacement in kind" means a replacement which satisfies design specifications.
Numerous participants expressed concerns (Ex. 3: 48, 48, 71, 76, 80, 81, 89, 97, 106, 112, 129; Ex. 162; Ex. 171; Tr. 1011, 1823, 2178) regarding trade secrets. For example, the Chemical Manufacturers Association (CMA, Ex. 3: 48, p. 2) remarked:
CMA also recommends that OSHA adopt the definition for "trade secret" as found within the Hazard Communication Standard (HCS) * * * The final standard should also incorporate appendix D from the HCS.
In its post-hearing comment, CMA (Ex. 128, p. 18) expressed its concern again that:
The issue of trade secret protection has not been addressed within the proposed standard. Trade secret information may be included within a number of documents created as a part of implementing the proposed PSM standard. Unless trade secrets are protected, items which include trade secret information collected by OSHA as a result of an inspection could be made public. This situation could result in damage to an employer's competitive position. CMA previously provided curative language and strongly suggests that OSHA consider using it in the final standard.
OSHA has decided to include the definition for trade secret from § 1910.1200, Hazard Communication, and has included provisions in a new paragraph. These trade secret provisions will be discussed below.
Employee Participation: Paragraph (c)
In the proposed standard, OSHA required that a team be used to conduct a process hazard analysis (proposed paragraph (e)(3)). The proposal required that the team have expertise in engineering and process operations, and the team was required to have at least one employee who had experience and knowledge specific to the process being evaluated. In Issue 5 of the proposal (55 FR at 29158), OSHA asked whether it should require an employee representative on the process hazard analysis team, as well as on the incident investigation team required for incident investigations (proposed paragraph (m)). It had been proposed that an incident
investigation team consist of persons knowledgeable in the process. OSHA asked if the presence of an employee representative on the teams would assist in developing a cooperative participatory environment and the necessary flow of information from management to employees and from employees to management.
Several rulemaking participants supported the concept of having an employee representative on both the process hazard analysis team and the incident investigation team (Ex. 3: 20, 25, 47, 115; Tr. 2086, 2235, 2345). However, numerous participants objected to OSHA mandating the inclusion of an employee representative on the teams required by the standard and most stressed that team members should be chosen on the basis of their expertise and not on union membership (e.g., Ex. 3: 9, 21, 26, 28, 29, 30, 32, 41, 45, 59, 62, 69, 70, 76, 77, 80, 103, 106, 109, 112, 120, 123, 127, 129, 141, 155; Tr. 670, 740, 763, 1012, 1813, 2061, 2157, 2573–4, 3238, 3351, 3411).
The issue of employee participation in process safety management received even greater attention after the Clean Air Act Amendments (CAAA) were signed. The CAAA contains a requirement in section 304(c)(3) that the employer "consult with employees and their representatives on the development and conduct of hazard assessments and the development of chemical accident prevention plans and provide access to these and other records required under the standard."
Participants focused on what they believed was the intent of the CAAA and its language and suggested the manner in which the intent should be included in the final standard. Representatives from the United Steelworkers of America observed:
(Tr. 2235) The Clean Air Act Amendments make it clear that workers and their representatives—it is in the law—are to have an important role in process safety management.
(Tr. 2258) I want to clarify that the word participation and consultation means only that. They do not imply the power to veto or to change the programs required under this proposed standard * * *.
(Tr. 2356) Consult to us means—or should mean that we are part of the process, that we have a voice in discussing the kind of information that is developed in writing and reviewing those reports. You know, it doesn't mean that we get to write the report to the exclusion of management, but it means that we ought to be part of the team.
Other participants suggested that the language in the CAAA be incorporated as a separate paragraph in the OSHA final standard and asserted that the language did not mandate an employee representative on the team conducting process hazards analyses or incident investigations.
A participant from Exxon U.S.A. (Tr. 3314) stated:
We conclude that the "consult with employees" provision in the Clean Air Act Amendments does not require that employees or their representatives be PHA [process hazard analysis] team members.
The requirement calls for the employer to exchange views on a process hazard analysis with employees and their representatives before a PHA is started.
Review of the wording in the clean Air Act would clearly call for a more structured exchange of views with wage personnel before starting A PHA.
Designated union representatives, such as union members on a plant safety committee, could be included in pre- and post-PHA discussions with wage employees.
A representative from the National Petroleum Refiners Association (Tr. 3372–74) testified:
As you are well aware, the operative wording from the Clean Air Act Amendment is consult with employees and their representatives on the development and conduct of hazard assessments and the development of chemical accident prevention plans, and provide access to these and other records required under the standard.
Now that is the law of the land, and we are clearly going to have to do that.
In Shell Oil Company, we think we know how to do that. We have consulted—we have well established procedures in place for consulting with our unions * * *.
We don't—speaking for Shell Oil Company, we don't believe that we need additional OSHA words—pages of regulations to help us interpret what consult with employee representatives means * * *.
Now, what is our position on involvement on teams? First, we support the involvement of workers on teams. We feel that the worker, the operator, the maintenance person, the foreman also can contribute significantly to the value of a PHA team.
But what we believe is that team is their knowledge of the unit in question, their knowledge of the operating practices, their knowledge of the maintenance practices in that particular unit, and those are the attributes they bring to that team and the participant workers should be selected on the basis of bringing those skills to the team rather than filling a role.
After a thorough analysis of the CAAA and the rulemaking record on this issue, OSHA has concluded that it is important for one member of each team be an employee who is knowledgeable about the process. This employee may very well be an employee representative; or, an employee representative may be participating on a team because of some expertise that the individual can contribute to the team. However, OSHA does not believe it necessary or appropriate to mandate team membership on the basis of organization affiliation (i.e., union membership), nor does the Agency believe that this was the intent of the CAAA.
OSHA believes that the intent of the CAAA demands a broader approach to employee participation. A participant from the United Steelworkers of America (Tr. 2257) asserted:
Workers and their representatives should have the right to participate in the development of hazard analysis, incident investigations and all safety audits. They should be consulted with respect to training, maintenance and emergency response programs.
OSHA agrees with this participant. This confirms OSHA's belief that a broader participation was envisioned by the CAAA. OSHA believes that employers must consult with employees and their representatives on the development and conduct of hazard assessments (OSHA's process hazard analyses) and consult with employees on the development of chemical accident prevention plans (the balance of the OSHA required elements in the process safety management standard). And, as prescribed by the CAAA, OSHA is requiring that all process hazard analyses and all other information required to be developed by this standard be available to employees and their representatives.
Therefore, as suggested by several rulemaking participants, OSHA has added language contained in the CAAA to the final rule in a new provision, paragraph (c). OSHA believes that this new provision, which requires broad and active employee participation in all elements of the process safety management program through consultation will enhance the overall program. OSHA also believes that the CAAA requirements demand that an employer carefully consider and structure the plant's approach to employee involvement in the process safety management program. Consequently, OSHA believes that it must require the employer to address this issue to ensure that the employer actively considers the appropriate method of employee participation in the implementation of the process safety management program at the workplace. Thus, OSHA has included a specific requirement that an employer develop a plan of action on how the employer is going to implement the employee participation requirements.
The new paragraph which has been added to the final process safety management rule, paragraph (c), reads as follows:
Employee participation. Employers shall develop a written plan of action regarding the implementation of the employee participation required by this paragraph.
Employers shall consult with employees and their representatives on the conduct and development of process hazard analyses and on the development of the other elements of process safety management in this standard.
Employers shall provide to employees and their representatives access to process hazard analyses and to all other information required to be developed under this standard.
Process Safety Information: Paragraph (d)
Paragraph (d) addresses process safety information. OSHA proposed that the employer develop and maintain certain important information about a covered process such as information about the hazards and characteristics of the chemicals used, information about the process technology and how it works and information about the process equipment. This process safety information was to be communicated to employees involved in operating the process.
The compilation of information concerning process chemicals, technology and equipment provides the foundation for identifying and understanding the hazards involved in a process and is necessary in the development of a complete and thorough process hazard analysis, as well as other provisions in the final rule including management of change, operating procedures, and incident investigations, etc.
A number of participants had recommendations to clarify the process safety information provisions. OSHA has made changes to this paragraph based on these recommendations, where such suggestions did not change the intent of the provisions.
OSHA has decided to allow the compilation of process safety information to occur on a schedule consistent with the schedule for conducting process hazard analyses as described in final paragraph (e)(1). It is necessary to assemble the process safety information specified in the final rule in order to conduct an adequate process hazard analysis. Therefore it is reasonable to allow the collection and compilation of process safety information on a given process to be completed before a process hazard analysis on that process is begun, instead of requiring the compilation of all process safety information on all processes to be completed before any process hazard analyses are begun.
Many participants objected to the requirement that the process safety information must be communicated to employees (e.g., Ex. 3: 17, 26, 33, 41, 48, 53, 103, 106, 109, 112, 119, 158). Participants noted that a lot of the process safety information was highly detailed and expressed their doubts concerning the usefulness of communicating such detail to employees. They believed that such information should be made available to employees rather than communicated to them. Paragraph (c) of the final rule, employee participation, requires that employees and their representatives must have access to process hazard analysis reports and to all other information required to be developed under this standard. The recommended change to make the information available is unnecessary in view of this requirement. Also, OSHA believes that process safety information pertinent to the employees job tasks is required to be communicated to employees by the final standard: To operating employees in paragraph (g); to contract employees in paragraph (h); and to maintenance employees in paragraph (j). Therefore the requirement contained in paragraph (d) to communicate the process safety information to employees has been deleted since it is provided for by other provisions of the final standard, such as employee participation, contractors, and training.
The process safety information required by paragraph (d)(1) pertains to the hazards of the highly hazardous chemicals in the process. OSHA proposed that the information include: toxicity information; permissible exposure limits; physical data; reactivity data, corrosivity data; thermal and chemical stability data; and the hazardous effects of inadvertent mixing of different materials that could foreseeably occur. Most of the information may already be available from the material safety data sheet (MSDS). MSDSs would be acceptable in meeting this requirement to the extent that the required information is available on the MSDS. The information required to be collected on the hazards of the chemicals is unchanged from the proposal.
In paragraph (d)(2) OSHA proposed that the employer develop and maintain information pertaining to the technology of the process itself. Paragraph (d)(2)(i) specified the required information and included the following: a block flow diagram or simplified process flow diagram; process chemistry; maximum intended inventory; safe upper and lower limits for such factors as temperatures, pressures, flows or compositions; and the consequences of any deviation in the process including those affecting the safety and health of employees. The final requirements remain virtually the same as those proposed except for a few minor editorial changes.
OSHA indicated in proposed paragraph (d)(2)(ii) that it might be difficult to obtain technical information for older existing processes. Therefore, it proposed to allow employers to develop such material from a hazard analysis conducted in accordance with paragraph (e) for processes initiated before January 1, 1980. OSHA believed that a properly conducted process hazards analysis should systematically identify technical information regarding the process and allow for adequate estimation of safe parameters for the process.
OSHA has reconsidered this paragraph and has decided that the best technical information available is the original information. Rather than include an arbitrary date, OSHA has decided to allow an alternate method of obtaining the technical information only for those processes where such information does not exist. In reviewing the record OSHA concluded that the American Petroleum Institute's RP 750 had acceptable language which met the intent of the Agency. Accordingly, OSHA has changed the final paragraph, (d)(2)(ii), to read as follows:
Where the original technical information no longer exists, such information may be developed in conjunction with the process hazard analysis in sufficient detail to support the analysis.
The final type of information that the proposal required to be collected ((d)(3)) pertains to the equipment in the process. Since the equipment used in a process can have a significant adverse impact on the facility and employee safety, OSHA wanted to assure that the equipment is appropriate for the operation and that it meets appropriate standards and codes such as those published by the American Society of Mechanical Engineers, the American Petroleum Institute, etc.
In paragraph (d)(3)(i) OSHA proposed that information be compiled concerning equipment used in the process including: materials of construction; piping and instrument diagrams (P&IDs); electrical classification; relief system design and design basis; ventilation system design; design codes employed; material and energy balances for processes built after the effective date of this standard; and safety systems (such as interlocks, detection, monitoring and suppression systems). Again, this paragraph remains virtually unchanged except for minor editorial changes.
In paragraph (d)(3)(ii) OSHA proposed that the employer document that the process equipment being used complies with applicable consensus codes and standards, where they exist; or be consistent with recognized and generally accepted engineering practices. OSHA has modified this paragraph by eliminating the list of codes and standards producing organizations. The discussion in paragraph (j), mechanical integrity, discusses the reasons for this change.
Paragraph (d)(3)(iii) required that when existing equipment was designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer must ascertain that the equipment is designed, installed, maintained, inspected, tested and operated in such a way that safe operation is assured.
There are many instances where process equipment has been in use for many years. Sometimes the codes and standards to which the equipment was initially designed and constructed are no longer in general use. For this type of situation, OSHA wants to ensure that the older equipment still functions safely, and is still appropriate for its intended use. OSHA is not specifying the method for this documentation. Under this approach the employer would be permitted to use any of several methods such as: documenting successful prior operation procedures; documenting that the equipment is consistent with the latest editions of codes and standards; or performing an engineering analysis to determine that the equipment is appropriate for its intended use. This paragraph remains the same as that which was proposed except the final rule requires the employer to determine and document that the equipment is "designed, maintained * * * and operating in a safe manner rather than "operating in such a way that safe operation is assured," as was proposed.
OSHA believes that the final provisions concerning process safety information meet the requirements in section 304(c)(1) of the CAAA. In this section OSHA must require employers to:
(1) Develop and maintain written safety information identifying workplace chemical and process hazards, equipment used in the processes, and technology used in the processes.
**Process Hazard Analysis: Paragraph (e)**
The vast majority of commenters addressed proposed paragraph (e) concerning process hazards analysis, often referred to as "hazard evaluation" (e.g., Ex. 3: 20, 21, 25, 26, 27–29, 33–35, 39, 41, 43–45, 59, 64, 69, 70, 76, 77, 79, 80, 83, 89, 96, 109, 112, 115, 119, 120, 122, 123, 126, 129, 138, 141, 149, 152, 155, 156, Ex. 91; Ex. 127; Ex. 141; Ex. 148; Tr. 671, 735, 968, 1018, 1114, 1206, 1922, 2059, 2156, 2174, 2572, 2650, 2689, 2773, 3136, 3259, 3348, 3683). These commenters were generally supportive of the provisions regarding process hazards analyses recognizing that the process hazard analysis is a key component of a process safety management system because it is a thorough, orderly, systematic approach for identifying, evaluating and controlling processes involving highly hazardous chemicals. However, participants recommended certain modifications to the process hazard analysis provisions. Participants also addressed several issues OSHA raised in the notice of proposed rulemaking [Issues 3, 4 and 5; 55 FR at 29158] concerning process hazard analysis timeframes, acceptable methodologies and process hazard analysis team membership.
In paragraph (e)(1) OSHA proposed to require employers to conduct an initial process hazard analysis on facilities covered by the standard in order to identify, evaluate and control the hazards of the process. By properly performing a hazard analysis, the employer can determine where problems may occur, take corrective measures to improve the safety of the process and preplan the actions that would be necessary if there were a failure of safety controls or other failures in the process. Paragraph (e)(1) required the employer to conduct the process hazard analyses using one of the methodologies listed.
Paragraph (e)(1) of the final standard reflects several changes from the proposal. The final standard still requires employers to conduct a process hazard analysis to identify, evaluate and control the hazards in a process. The provision addressing methodologies has been moved to paragraph (e)(2).
Also in paragraph (e)(1) is a new requirement that an employer select a process hazard analysis method which is appropriate to the complexity of the process being analyzed. This requirement was implicit in the proposal. The new language simply states OSHA's concern that an employer not choose an inappropriate process hazard analysis methodology.
OSHA anticipates that employers will be able to readily explain their plans for completing process hazard analyses and their reasoning for prioritizing which processes will be addressed first. Therefore OSHA is requiring that employers determine and document the priority order for conducting process hazard analyses based on such considerations as the extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process. This requirement is written flexibly in recognition of the fact that different processes will require different considerations for prioritization.
A phase-in period for process hazard analyses may be necessary, particularly, for facilities with multiple covered processes. However OSHA believes that plants with a limited number of processes, with simple processes, or which have already completed a number of process hazard analyses, should complete process hazard analyses as soon as possible. Therefore, the final standard language indicates that process hazard analyses must be conducted as soon as possible.
In Issue 3 of the preamble to the proposal [55 FR at 29154] OSHA noted that no time period was specified in which to complete initial process hazard analyses. It had been suggested to OSHA that a 1-, 2-, 3-, or 5-year delay be allowed for employers to complete initial process hazard analyses. These extended compliance scenarios were based on the perception that there were not enough technical experts who had the experience to carry out the analyses required by the proposal. The issue was discussed extensively in the rulemaking.
A significant majority of participants discussed the timeframes they believed would be necessary to complete initial process hazard analyses. Recommended timeframes ranged from immediately to as many as ten years. The majority of commenters supported either a 5-year timeframe (e.g., Ex. 3: 21, 16, 33, 41, 43, 44, 48, 59, 64, 70, 76, 80, 77, 96, 109, 112, 122, 123, 129, 134, 138, 141, 149, 155, Ex. 127; Tr. 1018, 1114, 1206, 1922, 2059, 2156, 2689) or a 7-year timeframe (e.g., Ex. 3: 27, 28, 29, 39, 45, 69, 77, 106, 120; Ex. 91, Ex. 148; Tr. 671, 735, 968, 2174, 2572, 2478, 2594, 2650, 2773, 3136, 3259, 3348, 3683) in which initial process hazard analyses could be completed on covered processes. These suggested timeframes were based on similar reasons. For example, the National Cooperative Refinery Association [NCRA, Ex. 3: 21] stated:
NCRA, like most independent refineries, does not have sufficient staff to complete a project of this magnitude without extensive use of contract consultants * * * Preliminary information indicates that it will be very difficult, if not impossible, for us to complete the analysis of all of the process units in the refinery in less than five years.
The American Petroleum Institute [API, Ex. 3: 106A, p. 7] noted:
API shares OSHA's concern that compliance with this rule could overwhelm existing resources unless an adequate implementation period is allowed. Further, API believes that experienced personnel needed to lead and participate in the process hazard analysis studies are not available in numbers sufficient to comply with the rule in fewer than seven years.
Marathon Oil Company (Ex. 3: 108) observed:
To start off, Marathon supports process safety management. Since the American Petroleum Institute published API Recommended Practice 750, "Management of Process Hazards" in January 1990, we have started implementing RP-750. This is a major, resource-intensive effort that we accepted voluntarily and estimate that it will require at least five years for implementation.
Phillips Petroleum (Ex. 3: 129, p. 3) indicated:
Completion of initial PHA should be within five years of the effective date. We feel this timeframe is needed to achieve quality results with the limited resources available, and the amount of complexity of the information to be handled.
Sun Refining and Marketing Company (Ex. 3: 155, p. 1–2) remarked:
Sun recommends that OSHA require all of the initial process hazards analyses be completed within five years of the effective date. While Sun recognizes the magnitude of work which will be required to implement these regulations as well as the limited number of resources, we believe that industry should take an aggressive approach to implementing this portion of the regulations. With such an approach, Sun believes a five year implementation schedule can be achieved and will accomplish process safety in a reasonable and realistic time frame.
OSHA accepts participants' remarks that resources may be stretched by the requirement to conduct process hazard analyses. Further, OSHA agrees with participants that a five-year period may be necessary to complete good quality process hazard analyses but remains unconvinced that a seven-year timeframe is necessary, especially in light of the concentrated efforts directed toward meeting API's RP 750 published in January 1990 and the Chemical Manufacturers Association process safety management initiatives already described. After considering the evidence in the record on this issue, the Agency finds that the 5-year phase-in period to complete process hazard analyses required by the standard is feasible.
In recognition that time will also be needed to compile the information required in paragraph (d), process safety information, which is needed to conduct a process hazard analysis, OSHA has adopted a schedule that requires at least 25% of the process hazard analyses to be completed each year, starting with the second year after the effective date of the standard. These provisions become final paragraphs (e)(1)(i) through (e)(1)(iv).
Finally, OSHA has added a new paragraph (e)(1)(v) which grandfathers process hazard analyses completed 5 years before the effective date of the standard. These process hazard analyses must meet the requirements contained in paragraph (e) and will have to be updated and revalidated, based on their completion date, in accordance with the requirements in paragraph (e)(6). Many commenters addressed the grandfathering of these analyses and OSHA agrees that appropriate grandfathering should be allowed. It would not be reasonable to require that resources be expended to conduct another process hazard analyses when a recent one already exists since these same resources could be better used to conduct initial process hazard analyses on other processes.
OSHA proposed a performance oriented requirement with respect to the process hazard analysis so that an employer would have flexibility in choosing the type of analysis that would best address a particular process. Consequently in paragraph (e)(1) OSHA proposed that an employer use one or more of certain listed methodologies to perform a process hazard analysis. The methodologies included: what-if; checklist; what-if/checklist; failure mode and effects analysis; hazard and operability study; and fault free analysis. More detailed information concerning the methodologies was included in nonmandatory appendix D. In Issue 4 in the proposal (55 FR at 29158), OSHA asked whether OSHA should consider additional methodologies, such as those approved by the American Institute of Chemical Engineers. Additionally, OSHA asked if appendix D, which contained descriptions of the methodologies in the proposal, should be made mandatory in order to assure a degree of uniformity when employers apply methodologies.
A vast number of participants opposed restricting process hazard analyses methodologies (e.g., Ex. 3: 9, 12, 17, 20, 21, 25, 26, 27, 28, 29, 30, 33, 38, 39, 41, 45, 47, 48, 50, 59, 62, 64, 69, 70, 71, 72, 73, 79, 83, 88, 92, 96, 99, 101, 106, 108, 109, 113, 115, 119, 120, 121, 127, 134, 137, 138, 139, 146, 150; Ex. 91: Ex. 127; Tr. 670, 736, 970, 1020, 1115, 1290–1, 1617, 1927, 2004, 2060, 2114, 2176, 3411, 3507). For example, Johnson Wax (Ex. 3: 12, p.28) stated:
[The six methodologies are not the only ones in current use or under development. For this reason, we do not believe OSHA should limit "process hazard analyses" techniques to these six. Instead, we would recommend that OSHA allow any recognized "equivalent" methodology also be allowed under this rule.
We would urge OSHA to explicitly state that other "process hazard analyses methodologies" would be acceptable if they can provide "equivalent" information to those listed. This will allow new methodologies to be used to "meet" this rule as they are developed. Otherwise the Agency will "freeze" process hazard analyses to current technologies.
Exxon Company, U.S.A. (EUSA, Ex. 3: 39, p.5), noted:
Restricting process hazard analysis (PHA) methodologies is a critical issue, and one of our most serious concerns.
EUSA is vigorously opposed to restricting PHA methodologies to the six currently listed in the proposed rule. This would indeed freeze technology in the new and rapidly evolving field of chemical process risk management, thereby excluding new and better methods which will most certainly be developed.
The American Paper Institute (Ex. 3: 45, p.15) commented:
OSHA's proposal to list "acceptable" process hazard analysis methodologies is unnecessarily narrow. The better approach would be to eliminate the list and make this a performance-oriented requirement. OSHA should simply mandate that the employer use an appropriate methodology for the process hazard analysis.
Realities of the workplace argue for maximum flexibility in this area. For example, the employer may need to modify one of the established methodologies. In some cases, the employer may need to develop a new approach because none of the existing methodologies is appropriate for the process to be evaluated. The precise methodology is unimportant so long as the method used addresses the elements specified in proposed section (e)[2].
If OSHA elects to publish a list of acceptable methodologies, the rule should stress that these are examples and that other * * * methodologies may be used so long as they are appropriate * * *.
OSHA agrees with these commenters regarding the use of the methodologies. While many of these commenters indicated that OSHA should require methodologies recognized by the American Institute of Chemical Engineers, OSHA has decided against doing so since it agrees with those participants who believed that any methodology should be allowed as long as it meets the specified criteria described in paragraph (e). Therefore OSHA has added an additional paragraph to its list of acceptable methodologies allowing employers to use other appropriate methodologies capable of adequately addressing and
analyzing the elements in paragraph (e)(3) of the final rule.
OSHA has decided not to retain the proposal's nonmandatory appendix D, Process Hazard Analysis Methodologies. Since OSHA is now allowing other appropriate methodologies, OSHA believes the appendix no longer serves the purpose for which it was intended. Further, OSHA believes that the proposal's nonmandatory appendix E, Sources of Further Information (which becomes final appendix D), provides more thorough information to employers seeking assistance in conducting process hazard analyses. This information appendix has been expanded to provide additional sources.
Comments were received directed toward clarifying OSHA's proposed paragraph (e)(2) concerning what a hazard analysis must address (final rule paragraph (e)(3)). The proposal required that the analysis address the hazards of the process; engineering and administrative controls applicable to the hazards and their interrelationships; the consequences of failure of these controls; and a consequence analysis of the effects of a release on all workplace employees.
Proposed paragraph (e)(2)(i) which required that employers address the hazards of the process remains the same as proposed. The paragraph becomes final paragraph (e)(3)(i).
Under the Clean Air Act Amendments, section 304(c)(2), OSHA must require employers to perform a workplace hazard assessment (OSHA's process hazard analysis), including, as appropriate, identification of potential sources of accidental release, an identification of any previous release within the facility which had a likely potential for catastrophic consequences in the workplace, estimation of workplace effects of a range of releases, and an estimation of the health and safety effects of such ranges on employees.
OSHA believes that the provisions contained in proposed paragraph (e)(2) concerning what a hazard analysis must address were responsive to the CAAA but did not require the identification of any previous incident which had a likely potential for catastrophic consequences. The inclusion of previous incidents will help to assure that the process hazard analysis adequately addresses a wide enough range of concerns. OSHA has included a requirement in the final rule for employers to identify any previous incident which had a likely potential of catastrophic consequences in the workplace. This provision is responsive to the CAAA and it becomes final paragraph (e)(3)(ii).
In proposed paragraph (e)(2)(ii), OSHA proposed to require that the process hazard analysis address the engineering and administrative controls applicable to the hazard and their interrelationships. The American Petroleum Institute (API) recommended that additional language be added concerning the detection of and monitoring for releases. OSHA believes that such information is important for employers to consider and has decided to accept the API [Ex. 137] suggestion for the most part. The paragraph becomes final paragraph (e)(3)(iii) and requires that the process hazard analysis address:
Engineering and administrative controls applicable to the hazards and their interrelationships, such as the appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors).
It should be noted, however, that detection methodologies is being used only as an example and there may be many other interrelationships that must be covered to comply with this provision for a particular process.
In proposed paragraph (e)(2)(iii), OSHA required that the "consequences of failure of these controls" be addressed. OSHA has changed this paragraph to clarify what is meant by "these." The final paragraph now requires that the process hazard analysis address "consequence of failure of engineering and administrative controls." This change merely clarifies the fact that OSHA wants employers to examine the failure of engineering and administrative controls; it does not change the intent of the provision. This provision becomes final paragraph (e)(3)(iv).
In paragraph (e)(2)(iv) of the proposal OSHA required that employers address a failure of controls through "a consequence analysis of the effects on all workplace employees." Participants encouraged OSHA to rephrase the paragraph to better define its intent (e.g., Ex. 3: 26, 28, 45, 48, 69, 71, 77, 120; Tr. 1013, 1227–28, 1533, 1610, 2014). For example, Chevron Corporation [Ex. 3: 26A, p.5] stated:
The term "consequence analysis" can be interpreted to mean many different types of evaluations, including studies and documentation far beyond what Chevron believes OSHA intends and far beyond what would add value to a PHA study. Additionally, Mobil Research and Development Corporation [Ex. 3: 69, p.3] noted:
[We] are concerned that the term "consequence analysis" * * * could be misinterpreted as requiring highly specialized modeling and risk assessment techniques such as Probabilistic Risk Assessment (PRA) that are not called for in paragraph (e)(1) PRA's, vapor cloud modeling and other quantitative hazard assessment techniques are difficult to apply as a basis for regulatory control. Judgements and assumptions made by the individuals performing the assessments are subjective and findings are difficult to validate and compare to other assessments. Moreover, no nationally accepted risk criteria for industrial processes have been established.
OSHA has modified the paragraph to indicate that it did not intend employers to conduct probabilistic risk assessments to satisfy the requirement to perform a consequence analysis. OSHA agrees with commenters that specialized techniques such as vapor cloud modeling would add an unnecessary burden with respect to assessing the effects of releases on employees. OSHA believes employers can establish a reasonable range of possible effects of releases on employees without conducting these specialized quantitative analyses. Further OSHA believes it has insufficient data in this rulemaking record on which to establish what would be a reasonable quantitative analysis. Therefore, this clarified paragraph becomes final paragraph (e)(3)(vii) and requires a qualitative evaluation of the possible safety and health effects of failure of engineering and administrative controls on employees in the workplace. This evaluation is for the purpose of guiding decisions and priorities in planning for prevention and control, mitigation and emergency response. OSHA believes this better reflects what it intended to accomplish by the proposal.
Additionally, OSHA has added two additional elements to final paragraph (e)(3). OSHA believes and participants suggested [Tr. 2609, 2705, 2781, 3542] that facility siting should always be considered during process hazard analyses. In order to assure that employers do consider siting, OSHA has decided to specifically emphasize it. Facility siting becomes final paragraph (e)(3)(v).
Finally, OSHA has added paragraph (e)(3)(vi) to the final rule which requires that employers address human factors in the process hazard analysis. In response to an OSHA concern expressed during the rulemaking regarding the consideration of human factors in process hazard analyses, the Chemical
Manufacturers Association (CMA, Ex. 3: 128, p.6) observed:
Human error is but one, albeit important, cause for chemical process accidents. A number of the provisions of the proposed PSM standard implicitly require companies to address the possibility of human error. * * *
Some individuals have testified that OSHA has not provided for the consideration of human error in the proposed standard-CMA disagrees with this shortsighted conclusion. However, CMA further stated that if the Agency wished to highlight the importance of addressing human factors issues, OSHA should include a requirement. OSHA agrees and, as noted above, has added a provision to highlight this concern.
Proposed paragraph (e)(3) required employers to conduct a process hazard analysis using a team approach. OSHA believes that in order to conduct an effective, comprehensive process hazard analysis, it is imperative that the analysis be performed by competent persons, knowledgeable in engineering and process operations, and those persons be familiar with the process being evaluated. Some employers may have a staff with expertise to perform a process hazard analysis. This staff will already be familiar with the process being evaluated. However, some companies, particularly smaller ones, may not have the staff expertise to perform such an analysis. The employer, therefore, may need to hire an engineering or consulting company to perform the analysis. OSHA believes it is important to note that in all situations, the team performing the process hazard analysis must include at least one employee from the facility who is intimately familiar with the process.
OSHA also believes that a team approach is the best approach for performing a process hazard analysis. This is because no one person will possess all of the knowledge and experience necessary to perform an effective process hazard analysis. Additionally, when more than one person is performing the analysis, different disciplines, opinions, and perspectives will be represented and additional knowledge and expertise will be contributed to the analysis. In fact, some companies even include an individual on the team who does not have any prior experience with the particular process being analyzed to help insure that a fresh view of the process is integrated into the analysis. Additionally, as discussed in the rulemaking, employees and other experts may be brought onto the team on a temporary basis to contribute their specialized knowledge to the conduct of the process hazard analysis.
The proposed provision required that the process hazard analysis be performed by a team with members who are knowledgeable in engineering and process operations, and that the team have at least one employee who has experience and knowledge specific to the process being evaluated.
In Issue 5 of the proposal (55 FR at 29158), OSHA inquired whether an employee representative should be included on process hazard analysis teams and incident investigation teams to assist in developing a cooperative participatory environment and to assist in developing the necessary flow of information.
OSHA received significant comment on the issue of teams and their makeup (e.g., Ex. 3: 9, 12, 15, 17, 20, 21, 25, 26, 28, 30, 32, 38, 39, 41, 45, 48, 50, 53, 59, 62, 69, 70, 76, 80, 81, 82, 83, 95, 96, 103, 106, 108, 109, 112, 113, 119, 120, 123, 127, 129, 134, 138, 139, 141, 143, 150, 155, 156; Ex. 91; Ex. 101; Ex. 134; Ex. 138; Ex. 143; Tr. 741, 1595–96, 1813, 2007, 2061, 3238, 3351, 3411). A vast majority of these commenters generally supported a team approach to conducting process hazard analysis as well as the team membership as specified in the proposal. As discussed previously, a great number of participants objected to the inclusion of an employee representative (union representative) on these teams; and as already indicated, OSHA has decided not to specifically require an employee representative on the team. Instead, the Agency has chosen to include a separate paragraph (final paragraph (c)) addressing employee participation in the process safety management program, which would require employee participation in the process hazard analysis by requiring that employers consult with employees and their representatives on the conduct and development of process hazard analyses. (See previous discussion of employee participation, final paragraph (c).) However, OSHA continues to require that an employee who has experience and knowledge specific to the process being evaluated be included on the team.
Numerous commenters noted that the proposal omitted a crucial team member, a person knowledgeable in the process hazard analysis methodology being used to evaluate the process in question (e.g., Ex. 3: 9, 17, 48, 69, 83, 103, 109, 115, 120, 153; Ex. 101; Tr. 1021, 1291). OSHA agrees with these commenters and has added a requirement that one team member must be knowledgeable in the specific process hazard analysis methodology being used. This paragraph concerning process hazard analyses teams becomes paragraph (e)(4) of the final rule.
In proposed paragraph (e)(4), the employer was required to address the findings and recommendations of the process hazard analysis team, to document actions taken, and communicate the actions taken to employees whose work assignments are in the facility affected by the recommendations or actions. The employer was also required to assure that recommendations were implemented in a timely manner. With these provisions, OSHA wanted to assure that the results of a process hazard analysis were fully utilized to improve process safety.
Many commenters objected to OSHA’s requirement that the recommendations resulting from the process hazard analyses be implemented in total (e.g., Ex. 3: 26, 30, 38, 39, 45, 48, 50, 69, 70, 81, 101, 106, 108, 109, 115, 120, 121, 129, 153, 155; Ex. 95, 136, 138, 148; Tr. 670, 970, 1015, 1811, 1854, 1931, 2061, 2159, 2654, 3351, 3411, 3510). The Fertilizer Institute (Ex. 3: 109, p.7) remarked:
Paragraph (e)(4) should be modified so that employers are not required to implement every recommendation offered by a Process Hazard Analysis Team. It is critically important that a PHA Team have freedom to make broad recommendations, at risk of being wrong, since they will not have time to completely research each recommendation. Working with the Team, Management must retain the responsibility for deciding which recommendations should be implemented. * * *.
The Synthetic Organic and Chemical Manufacturers Association (SOCMA, Ex. 3: 50, p. 5–6) observed:
SOCMA also agrees with OSHA’s requirement that employers establish a system to promptly address the team’s findings. However, SOCMA does not agree that the recommendations of the team should be “implemented” because that implies that every recommendation developed by the process hazard analysis team must be acted on exactly as recommended. Many times, on further study, process hazard analysis team recommendations are resolved in more effective ways than those originally envisioned by the team. The employer should be given the option to implement solutions that are more effective than those recommended by the team.
OSHA agrees with these participants that a process hazard analysis team should be encouraged to make broad recommendations. It is also possible that not all team recommendations will be correct or will resolve the problem found in the best way. OSHA has accordingly restructured, changed and added language to the final paragraph to
reflect the concerns of many participants. In the final paragraph, the employer must assure that the recommendations resulting from the process hazard analysis are "resolved" in a timely manner and that the resolution is documented. In this way, when a team recommendation is incorrect, the employer can analyze it and then document in writing why the recommendation is not being adopted or is being adopted with modification.
In conjunction with this change OSHA believes that when an employer decides that a recommendation requires action, then an employer should develop a written schedule of the actions which are to be completed. It is OSHA's intention that the actions to be taken as a result of the process hazard analysis recommendations be completed as soon as possible. In most cases, OSHA believes that employers will be able to complete these actions within a one to two year timeframe, but notes that in unusual circumstances longer completion periods may be necessary. The final paragraph becomes paragraph (e)(5) and the above language has been incorporated into the final provision.
In the proposal, paragraph (e)(5), the process hazard analysis was to be updated and revalidated at least every five years, using the process hazard analysis team to assure that the process hazard analysis is consistent with the current process. The Agency believed that this five year update and revalidation interval was a reasonable timeframe, particularly in consideration of the long life span, without change, of many processes. OSHA also believed that there were adequate safeguards elsewhere in the proposal to protect employees when the process changed. (See for example, paragraph (d), process safety information and (l), management of change.)
In Issue 3 of the proposal [55 FR at 29158] OSHA invited comment on whether the five year update and revalidation cycle was appropriate. Many participants addressed this provision and most supported the 5-year update and revalidation provision (e.g., Ex. 3: 17, 26, 33, 41, 45, 48, 50, 59, 64, 69, 88, 95, 96, 101, 109, 119, 120; Tr. 740, 1114, 1598, 1809, 2157, 2774, 3349, 3411). For example, Pennzoil (Ex. 3: 41, p.11) noted:
Pennzoil fully supports updating and revalidating the PHA every five (5) years, provided that OSHA does not intend updating and revalidating to mean doing a completely new PHA. As we understand the proposed language, during a PHA review, our PHA team would evaluate the previous PHA, examine the extent of any changes that might have occurred since the PHA was implemented (or last reviewed) and decide what work is needed to make the PHA current. Given our understanding of how these updates will work and our limited resources, we believe that this interval is very practical.
The American Paper Institute (Ex. 3: 45, p.14) indicated:
API [American Paper Institute] believes that OSHA's proposal to require process hazard analyses updates and revalidations every five years is an appropriate choice. Adequate safeguards exist in the proposed rule to address potential concerns that might arise between periodic updates and validations. Elsewhere, OSHA has proposed that facilities prepare for and deal with changes; compliance with the requirements governing changes will provide ample protection until completion of the next regularly scheduled process hazard analysis validation/update. By selecting the five-year interval, OSHA has avoided imposing an unnecessary burden on facilities.
The American Petroleum Institute (Ex. 3: 106A, p.12) stated:
OSHA's proposal to update and revalidate every PHA on a five year basis is acceptable, providing it is not intended to mean that a team must necessarily conduct a new and complete PHA. API understands the proposed language to mean that the PHA team could evaluate the previous PHA, examine the extent of change that had occurred in the interim and the procedures used for implementing change, and reach a conclusion regarding the scope and extent of the work necessary to update and revalidate the PHA. With this understanding, we support the five-year interval. The procedures required by paragraphs (1) Management of change and (i) Pre-startup safety reviews will ensure the interim integrity of process safety.
Texaco Inc. (Ex. 3: 120, p.6) observed:
Paragraph (1), Management of Change, outlines the items the employer must address prior to any change. This enables the employer to determine the scope and extent of the work necessary to update and revalidate the process hazard analyses. Consequently, Texaco believes the five (5) year update and revalidation requirement for process hazard analyses is appropriate.
OSHA agrees with these commenters and has retained the five year update and revalidation schedule. Finally, OSHA has decided to clarify that the update and revalidation should occur five years after the completion of the initial process hazard analysis. This paragraph has been redesignated as paragraph (e)(6).
In paragraph (e)(6), OSHA proposed that employers retain the two most recent process hazard analyses and/or updates for each process covered as well as the documented responses to the process hazard analysis recommendations. Few participants addressed this particular provision. OSHA has determined, based on the discussions in the rulemaking, particularly those concerning the update and revalidation of process hazards analyses, that the proposed requirement to retain the two most recent process hazard analyses and/or updates for each process failed to recognize the full importance of documents developed relative to process hazard analyses. This requirement has been modified in the final rule. New paragraph (e)(7) requires that employers retain the process hazard analysis and their updates and revalidation. The Agency does not believe that this requirement will pose an undue burden on employers in that retention of these documents is necessary to conduct the periodic updates and revalidations which are required under the standard.
OSHA believes that the process hazard analysis provisions contained in the final standard meet the requirements contained in section 304(c) (2), (4), and (5) of the Clean Air Act Amendments. The requirements state that the OSHA standard must require employers to:
(2) Perform a workplace hazard assessment [OSHA's Process Hazard Analysis] including, as appropriate, identification of potential sources of accidental release, an identification of any previous release within the facility which had a likely potential for catastrophic consequences in the workplace, estimation of workplace effects of such range on employees.
(4) Establish a system to respond to the workplace hazard assessment findings, which shall address prevention, mitigation, and emergency responses.
(5) Periodically review the workplace hazard assessment and response system.
Operating Procedures: Paragraph (f)
Paragraph (f) of the proposal contained provisions requiring the development and implementation of written operating procedures. The procedures are to provide clear instructions for safely conducting activities involved in covered processes and they must be consistent with the process safety information. To have an effective process safety management program, OSHA believed that tasks and procedures directly and indirectly related to the covered process must be appropriate, clear, consistent, and most importantly, communicated to employees.
Many different tasks may be necessary during a process, such as initial startup, handling special hazards, normal operation, temporary operations and emergency shutdown. The appropriate and consistent manner in which the employer expects these tasks and procedures to be performed consistent with the facility's operating
procedures is sometimes referred to as standard operating procedures.
It is important to have written operating procedures so employees working on a process do a given task in the same manner. There is less likelihood that incidents will occur if written operating procedures are developed so even a new employee or one who is relatively inexperienced will respond to a given event in a preconsidered and prescribed manner. It is also important that the procedures be written so that they can be communicated to employees in the most effective manner possible. Such written procedures comprise the employer's policy with respect to what is to be accomplished, and how it is to be accomplished safely. This will ensure that employees will perform like tasks and procedures in a consistently safe manner, and employees will know what is expected of them. These procedures must also be available for ready reference and review during production to make sure the process is operated properly. Accordingly, OSHA proposed that the employer develop and implement written operating procedures that provide clear instructions for safely conducting all activities involved in each process.
In proposed paragraph (f)(1)(i), OSHA required that the operating procedures address steps for each operating phase, including initial startup, normal operation, temporary operations, emergency operations, normal shutdown, and startup following turnaround or emergency shutdown.
In proposed paragraph (f)(1)(ii) OSHA proposed that the operating procedures address the process operating limits, including the following: consequences of deviation; steps required to correct and/or avoid deviation; and safety systems (including detection and monitoring equipment) and their functions.
In paragraph (f)(1)(iii), OSHA proposed that the operating procedures address safety and health considerations regarding the process, including the following: properties of, and hazards presented, by the chemicals used; precautions necessary to prevent exposure; control measures to be taken if physical contact or airborne exposure occurs; safety procedures for opening process equipment (such as pipe line breaking); quality control for raw materials and control of hazardous chemicals inventory levels; and any special or unique hazards.
Few participants criticized the contents or the merits of paragraph (f) in general. However, OSHA has restructured and clarified certain provisions of paragraph (f)(1). One change includes a division of proposed paragraph (f)(1)(D) which addressed emergency operations, including emergency shutdowns, and who could initiate them. Proposed paragraph (f)(1)(D) has been divided into final paragraph (f)(1)(D) and final paragraph (f)(1)(E). Final paragraph (f)(1)(D) concerns emergency shutdown and requires that the employer assign shutdown responsibility to a qualified operator to ensure a safe and timely shutdown.
The second change is the relocation of (f)(1)(ii)(C), safety systems and their functions, to a separate paragraph. This paragraph becomes final paragraph (f)(1)(iv).
Proposed paragraph (f)(2) required that a copy of the operating procedures be readily accessible to employees who work in or maintain a process and it is retained in the final rule. This requirement assures that a ready and up-to-date reference is available to employees when needed. It will also form a foundation for training which employees need under this final rule.
In proposed paragraph (f)(3) OSHA proposed that the operating procedures be reviewed to assure that they reflect current operating practices and any changes to the process or facility. Since it is extremely important to the safe operation of covered processes that operating procedures remain current and accurate, OSHA has added a precaution to guard against the use of outdated or inaccurate operating procedures by requiring that an employer verify annually that the operating procedures are current and accurate. No other changes were made to the paragraph and it becomes final paragraph (f)(3).
Finally, OSHA has been persuaded by participants in the rulemaking that it should add another requirement to paragraph (f). Throughout the rulemaking OSHA has expressed its concern regarding the control of hazardous activities within a facility. For example, in the notice of hearing in Issue 1 (55 FR at 46075), OSHA asked whether it should require employers to issue permits for hazardous activities in addition to those for which hot work permits were required. It had been suggested that issuing permits would provide greater control of hazardous activities at a facility and would also facilitate a better coordination of contractor activities. A variety of participants objected to OSHA expanding the required permit system (e.g., Ex. 3: 154, 163, 166; Ex. 116; Tr. 1883).
However, the Organization Resources Counselors (ORC, Ex. 131, p. 5) recommended and others concurred (Ex. 3: 165):
[T]he addition of a new paragraph to * * * provide for the development and implementation of an on-going mechanism to ensure that all workers performing non-routine work are informed of existing hazards, appropriate precautions, and emergency procedures.
The objectives of these requirements are, first, to insure that those persons operating high hazard processes are cognizant of any non-routine work (i.e., maintenance, construction, sampling or other activity) that is occurring in the process. The second objective is to insure that those in responsible control of the facility are also in control of such non-routine work so as to insure that the work does not undermine the safe control of the process. The third objective is to provide information to those workers performing non-routine work regarding the hazards and necessary precautions attendant to that work.
Ordinarily, in chemical plants, maintenance and construction activities are supervised by persons other than those in direct control of the process. Implementation of these practices will insure that control over all activity in high hazard plants remains with those who manage the production units while they are in operation.
OSHA agrees that this approach will provide significant safety to employees impacted by on-going work activities and prefers this performance oriented approach provision. Therefore OSHA has added a new paragraph (f)(4) in the final standard requiring the employer to develop and implement safe work practices to provide for the control of hazards during work activities.
OSHA believes that the provisions concerning operating procedures included in the final standard meet the requirements of sections 304(c) (6) and (7) of the CAAA which state that the OSHA standard must require employers to:
(6) Develop and implement written operating procedures for the chemical process including procedures for each operating phase, operating limitations, and safety and health considerations.
(7) Provide written safety and operating information to employees and training employees in operating procedures, emphasizing hazards and safe practices.
Training: Paragraph (g)
OSHA believes that the implementation of an effective training program is one of the most important steps that an employer can take to enhance employee safety. The Agency also believes that an effective training program will help employees understand the nature and causes of problems arising from process operations, and will increase employee awareness with respect to the hazards particular to a
process. OSHA is convinced that an effective training program will significantly reduce the number and severity of incidents arising from process operations, and can be instrumental in preventing small problems from leading to a catastrophic release.
While there were a few concerns expressed with respect to OSHA's performance-oriented approach to training, no participant disagreed with the importance of training. In fact, there was consensus among rulemaking participants that training is a necessary and integral part of any effective process safety management program.
Proposed paragraph (g)(1) covered initial training, and required each employee presently "involved" in a process, and each new employee before working in a newly assigned process, to be trained in an overview of the process and in the operating procedures that were specified in proposed paragraph (f) of the proposal. The proposal also required the training to include emphasis on the specific safety and health hazards, procedures, and safe work practices applicable to the employee's job tasks.
An extensive amount of comment and testimony resulted from this proposed provision. In its analysis of this rulemaking record, the Agency identified three broad topics that were addressed by rulemaking participants in relation to this proposed provision concerning initial training. These topics were: the application of this proposed provision (to whom the training applies); OSHA's approach (including the amount and method of training, and the content of the training program); and grandfathering of training (the recognition of training received by employees prior to promulgation of this standard).
**Application**
Several rulemaking participants (Ex. 3: 17, 33, 53, 71; Tr. 313; Tr. 389) remarked that the training coverage for "employees involved in a process" was too broad, and could be misinterpreted to mean contractor employees and maintenance employees, in addition to the operating employees that they assumed that this proposed provision was meant to address. They suggested that this proposed paragraph be renamed "Operator Training" and the applicability of this proposed paragraph be clarified; or, they suggested addressing training for all employees in this proposed paragraph, including training for contractor employees and maintenance employees. For example, a hearing participant from the Organization Resources Counselors (ORC Tr. 313) testified:
To clarify the training requirements of this proposal, ORC recommends that OSHA either include the training appropriate for maintenance and contractor personnel in additional, separate subsections of paragraph G, or rename paragraph G as "operator training", and highlight those paragraphs in J and H which call for the training of other types of employees.
Another hearing participant from Chevron (Tr. 389) said:
Training should cover operating employees rather than as currently worded, "employees involved in the process" which is subject to interpretation.
A commenter from Allied Signal (Ex. 3: 17, p. 9) stated:
[I]t should be noted that the requirements of paragraph (g) are appropriate only for employees involved in operating the process. Training for mechanical personnel is referenced in paragraph (j)—specifically [(j)(2)(ii)]—and training for contractor employees is specified in paragraph (h).
Additionally, a commenter from ARCO Chemical Company (ACC, Ex. 3: 71, p. 3) remarked:
ACC recommends that OSHA limit the application of the training requirements of the proposed rule to those employees directly involved in the process with training limited to relevant operating procedures necessary for the safe performance of job tasks.
When OSHA proposed that this provision apply to employees "involved in a process," it intended for this provision to apply to only those employees, including managers and supervisors, who are actually involved in "operating" the process. While most OSHA standards, by their terms, apply to all employees in a particular situation and contract employees are considered "employees" in the broad sense of the word, this standard distinguishes in the training requirements between contract employees and direct hire employees. This was done primarily for emphasis and in recognition of the fact that in some segments of industry covered by the process safety management standard, contractors make up a substantial portion of on-site workers. OSHA wanted to focus attention on that situation and did so by imposing separate but similar training objectives for direct hire and contract employees. This is the reason, as discussed below, that training requirements for contractor employees and maintenance employees were addressed in separate paragraphs in the proposal.
OSHA agrees with rulemaking participants that this intent was not clear in the proposed rule. Therefore, the phrase "involved in a process" is being replaced with the phrase "involved in operating a process" in paragraph (g)(1) of the final rule. This is intended to cover all direct hire employees not involved in maintenance. This paragraph is not intended to be limited to equipment operators. OSHA believes that this change together with other changes made to the training requirements for contractor and maintenance employees [addressed in paragraphs (h) and (j), respectively], will clarify the Agency's intent.
**Approach**
A few rulemaking participants (e.g., Tr. 1286, 2259, 2268–70, 2409) disagreed with OSHA's performance-oriented approach with respect to training, and contended that the proposed training requirements were inadequate and should be strengthened. For example, a hearing participant from the Laborers' National Health and Safety Fund (Tr. 1286) stated:
The training required in 119 (g) and (h) suffer from the usual deficient approach that's been taken b[y] OSHA in the past in that form, content, duration, scope, proficiency and competency aspects, among others, are not addressed. This key element in achieving reduced worker and public risk from operations covered by 119, is seriously deficient.
A participant from the Oil, Chemical and Atomic Workers (Tr. 2408–09) testified:
This standard doesn't propose to do anything. If you examine it closely, it is going to require industry to do no more than it does now, [no] more than it has said it has done over the last 20 and 30 years, and [no] more certainly than we think ought to be done in some of those areas.
When it talks about training, it talks about training for operators. And essentially, when we look at the standard, we think it calls upon industry to do what it has done.
When we looked at training and tried to fashion what the standard meant in terms of training for maintenance, our conclusion was that the standard essentially said, Do what you have done. When we looked at contractors in the one paragraph in the standard that talked about contractors, it essentially said, Do what you have done. And we don't believe that what has been done is enough * * *.
Additionally, a hearing participant from the United Steelworkers of America (USWA, Tr. 2286–69) remarked:
Although both unions are pleased at OSHA's initial inclination to make training a component of the proposed 1910.119 standard, we find the proposal severely lacking in specific and detailed regulatory language, as well as scope and breadth.
In addition, we find the voluntary and self-regulatory—I.e., strictly performance-based—aspects of OSHA's proposed training
requirements to be insufficient to assure the safety of workers, chemical facilities and their communities.
USWA and the International Chemical Workers Union recommended specific subjects that an effective training program should include, and suggested that a stratified approach to training be used by OSHA in the final rule (Tr. 2270–77). This stratified approach would consist of a minimum number of hours of training for two categories of employees: employees who have the potential to affect imminent danger situations and employees who have the potential to be affected by but not affect any imminent danger situations.
It was suggested that the first category, employees who have the potential to affect imminent danger situations, be separated into two subgroups of employees. The first group would consist of managers and supervisors directly responsible for highly hazardous chemical operations with imminent danger potential. It was suggested that these employees receive a minimum of 80 hours of initial training, and a minimum of 40 hours of refresher training annually, thereafter. The second group would consist of all workers who could, through the course of their production, maintenance or emergency work activities affect highly hazardous chemical imminent danger situations. These workers would include, but not be limited to, chemical and petroleum operators and their assistants, electricians, plumbers, pipefitters, etc. It was recommended that this group of employees receive a minimum of 40 hours of initial training, and a minimum of 40 hours of refresher training annually, thereafter.
It was further suggested that the second category of employees, those who have the potential to be affected by an imminent danger situation, be provided with a minimum of eight hours of training annually.
A few other rulemaking participants (e.g., Ex. 3: 5, 138; Tr. 47) also suggested that OSHA specify a minimum number of training hours in the final rule. However, the vast majority of rulemaking participants supported a performance-oriented approach to training (e.g., Ex. 3: 9, 17, 20, 28, 29; Ex. 138; Tr. 76, 313–14, 388, 674, 1021, 1207, 1318, 1508, 1538, 1596, 1617, 1663, 1815, 2008, 2062, 2158). They asserted that there were several levels of complexity of operations among the various covered processes and experience and skill levels vary widely among employees. As a result, a specified number of training hours might be too little for some employees, and more than is actually needed by other employees.
They contended that the employer should evaluate the complexity of operation, experience, and skill levels of employees. With this information, the employer would be able to determine the content of the training program as well as the amount and frequency of training that would best assure that employees will be able to perform their job tasks in a safe and effective manner. For example, a hearing participant from the Organization Resources Counselors (ORC, Tr. 313–14) testified:
Choice of the most appropriate means for determining employee comprehension and expertise, however, must be the responsibility of the employer rather than mandated by regulation, as only the employer has the knowledge necessary to do this.
Moreover, the employer is responsible for the safe management of processes involving highly hazardous chemicals and must be free to use whatever method he or she determines will best ensure that employees can and do perform their jobs safely.
ORC also strongly opposes the notion that minimum hours of training must be specified in this standard to ensure that employees receive adequate training. The level and extent of training necessary should be dependent upon the complexity of the operation.
A commenter, who is an independent consultant (Ex. 3: 9, p. 2), remarked:
As for training, setting a specific time period for the training seems unreasonable. Experienced personnel certainly need far less time than newly hired personnel. Also, the extent of training varies based on the difficulty of the operations being performed. Training is needed for all facilities where hazardous materials are present but, again it is impossible to set a specific single criteria for training covering all situations.
Another commenter from the Gas Processors Association (GPA, Ex. 3: 28, p. 12), stated:
GPA’s position is that OSHA should not specify a minimum amount of training because the training needs vary greatly depending on the size, complexity, and nature of the operation and hazards involved. For example, at a small, simple operation the requirement for 40 hours of initial training may greatly exceed the amount of training necessary to assure that employees are properly and adequately trained for that operation. Other large complex operations could dictate that 40 hours or more of initial training be provided for some employees involved in the operation. In summary, employers should custom design the training program for a location based on that operation’s specific requirements. Forty hours of initial training and 8 hours of refresher training for many operations could be unnecessary.
A hearing participant from Manufacturing Technology Strategies (Tr. 1318) said:
In terms of the amount of training required, we believe that time limits are not appropriate. Once again, it is our belief that the technology determines the extent and complexity of the needed training, and since this technology is highly variable from site to site, it is not possible to say 40 hours is sufficient or that 8 hours once annually would keep the person up to speed.
Additionally, a hearing participant from the Institute of Makers of Explosives (Tr. 1617–18) remarked:
On training, OSHA should neither specify a minimum number of hours for initial or refresher training, nor should OSHA require any specific method for training validation. The employer can best determine the degree of initial and refresher training needed. The level of training should depend on the complexity of the job, the skill level of the trainee, and the skills needed to safely perform the job. For example, an employee at a chlorine repackaging operation will not need the same amount or level of training as an employee at a chloralkali production facility.
Finally, OSHA’s expert witness (Tr. 2007–08) testified:
In my experience, I have found that the amount of training should depend upon the complexity of the operation and the competence and experience level of the person being trained. A simple reaction using one reactor will require much less operator training than a complex chemical or petrochemical operation.
Therefore, I do not think that there should be a minimal number of hours of training specified in the standard. The training requirements should not be rigid, but should cover the essential parts of the process involved to ensure that employees are competent to perform their duties.
After a careful analysis of the rulemaking record with respect to proposed paragraph (g)(1), OSHA has concluded that a performance-oriented approach to training is appropriate. The Agency believes that employers can determine the amount of training and the content of the training program that best reflects the operation’s complexity and the experience and necessary skill level of their employees.
Proposed paragraph (g)(1) has been redesignated as (g)(1)(i) in the final standard and has been revised to read as follows:
Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including
shutdown, and safe work practices applicable to the employee's job tasks.
**Grandfathering**
Many rulemaking participants (e.g., Ex. 3: 26, 33, 38; Ex. 138; Ex. 143; Tr. 388, 1022, 1122, 1207, 1618) contended that OSHA should recognize training that employees received prior to the promulgation of this standard. For example, a commenter from Chevron (Ex. 3: 26, p. 7) stated:
The rule also does not address training received prior to the effective date of the rule. To help alleviate some of the compliance burden placed on employers without compromising the safety of employees, OSHA should include a grandfather clause within the initial training requirement. As long as employees have received training comparable to that required by the standard, the employer should not be required to retrain these employees for the sake of the standard. These employees will still be covered by the refresher and supplemental training requirements of paragraph (g)(2).
A participant from Kodak (Ex. 3: 33A, p. 6–9), said:
OSHA needs to grandfather initial training requirements for existing employees. It would be an incredible burden to require retraining of all employees, many of whom are experienced with and participated in development of the process and operating procedures.
A commenter from Monsanto (Ex. 143, p.2) asserted:
Further, performance against established criteria by employees who are already performing these jobs should suffice for validation. These employees should not have to attend a training course on what they are already doing and again demonstrate their proficiency on the job to satisfy training/validation requirements. It will, therefore, be important that OSHA specifically "grandfather" training that has already been accomplished and employees are performing their jobs.
In testimony, a hearing participant from the American Petroleum Institute (API, Tr. 1122) observed:
API believes that where employers previously have provided initial training that meets OSHA basic requirements, recipients of that training should be grandfathered and not be required to repeat the initial training.
Also, OSHA's expert witness (Tr. 1207) remarked:
I suggest that training be phased in by grandfathering existing process operators, exempting them from the initial training requirement but making them subject to periodic refresher and supplemental training requirements.
OSHA agrees that previous training should be recognized if the employer certifies in writing that employees have the required knowledge, skills, and abilities to safely carry out their duties and responsibilities, particularly since employees must still be provided with refresher training in accordance with paragraph (g)(2) of this section (discussed below in this preamble).
Therefore, OSHA is adding a new provision, (g)(1)(ii), to the final rule to allow grandfathering of initial training under certain circumstances. The new paragraph reads as follows:
In lieu of initial training for those employees already involved in operating a process on [Insert effective date of standard], an employer may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures.
Proposed paragraph (g)(2) required refresher and supplemental training to be provided to each employee at least annually to assure that the employee understands and adheres to the current operating procedures of the process. Although the need for refresher training was well supported throughout this rulemaking record, some rulemaking participants (e.g., Ex. 3: 5, 26, 27, 30, 33, 38; Tr. 47, 1121, 1814–15, 2273) disagreed with OSHA that refresher training should be provided annually.
Some rulemaking participants contended that annual refresher training may not be necessary for some employees, and that OSHA should use a performance-oriented approach that would permit the employer to determine the appropriate frequency. Other rulemaking participants recommended that refresher training be held at least every three years. Some rulemaking participants asserted that OSHA should specify a minimum number of hours of refresher training, while still other rulemaking participants suggested that OSHA specify a minimum of 40 hours of refresher training annually. For example, a commenter from South Alabama University (Ex. 3: 5) said:
I believe that employees that deal with hazardous substances should have a minimum of 40 hours training. Refresher training should be the same amount of time.
A hearing participant from the American Petroleum Institute (Tr. 1814–15) testified:
[Re]freshers training should be required every three years, not every year, as proposed by OSHA and be restricted to operators.
A commenter from Dupont (Ex. 120) suggested that this proposed provision be revised to read as follows:
Refresher and supplemental training shall be provided to each employee to assure that the employee understands and adheres to the current operating procedures. The employer shall, in consultation with employees, prioritize and document refresher and supplemental training frequencies, which are not to exceed three years.
Another commenter, who was from ARCO (Ex. 3: 30A, p.5), remarked:
Paragraph (g)(2) should be amended to provide refresher and supplemental training on a frequency necessary to assure that the employee understands and adheres to the current operating procedures of the process. The words "at least annually" should be removed.
The key objective of this section is to assure that employees are knowledgeable about the current operating procedures and this should be a performance based requirement.
Also, a commenter from Chevron Corporation (Ex. 3: 26, p.8) stated:
Item (g)(2) should be modified to require refresher training every three years rather than annually.
Paragraph (1) Management of Change will require ongoing supplemental training for all covered changes.
After analysis of the rulemaking record on this issue, OSHA has concluded that as with the initial training, it would be inappropriate to prescribe a minimum number of hours of refresher training since there is a wide variation in operation complexity, and in the experience and skill levels of employees. The Agency believes that the employer, in consultation with employees, can best determine the appropriate frequency of refresher training.
OSHA believes, however, that the frequency of refresher training should be held at least every three years to assure that employees understand and adhere to current operating procedures.
Additionally, the Agency considers the terms "refresher training" and "supplemental training" to be similar and, consequently, has removed the term "supplemental training" from this provision of the final rule.
Accordingly, proposed paragraph (g)(2) has been revised in the final rule to read as follows:
Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures in the process. The employer, in consultation with the employees involved in operating a process, shall determine the appropriate frequency of refresher training.
Proposed paragraph (g)(3) required the employer to certify that employees had received and successfully completed the required training. It also required the certification to identify the employee,
the date of the training, and the signature of the person doing the training.
The purpose of this proposed provision was to assure that employees not only receive training but, also, that they understand and can demonstrate what they have learned in order to perform their job tasks safely. This is especially important where, as here, comprehensive training and the understanding of the training plays such a crucial role in the risk reduction associated with the process safety management rule. OSHA also believed this proposed provision was necessary to serve as a tracking mechanism for the training that employees receive and when employees received the training.
Many rulemaking participants (e.g., Ex. 3: 21, 25, 26, 28, 30, 38; Ex. 134; Ex. 143; Tr. 389, 1022, 2009) were concerned that OSHA might revise this provision in the final rule to specify particular methods to validate that employees understood the training they had received such as written tests, oral examinations, on-the-job demonstrations, etc. It was suggested that some method, or combination of methods, would be appropriate to verify that employees have understood the training, but OSHA should not mandate any specific method of validation.
Based on the rulemaking record, OSHA believes that its performance-oriented approach with respect to the certification of training is appropriate and it recognizes that any one of several methods, or combination of methods, can be effective in verifying that employees understand the training that they have received. Employers are therefore free to devise the method that works best in their establishment to ascertain that employees have understood their training. Consequently, OSHA is not mandating any specific methods of training validation in the final rule.
Several rulemaking participants (e.g., Ex. 3: 28, 29, 33; Tr. 1599, 2158) suggested that OSHA replace the term "certify" with "document" because they believe some form of documentation was important but certification was unnecessary. OSHA agrees that the term "document" is descriptive of the Agency's intent, and has substituted the term "document" for "certify" in this provision of the final rule.
Additionally, the Agency believes that it is important that the training documentation contain the name of the person conducting the training, as opposed to the signature of the person conducting the training as was proposed. OSHA is therefore requiring the trainer name and is eliminating the requirement for a signature. Also this will allow employers to keep training records on computer if they so desire.
Therefore, proposed paragraph (g)(3) has been retitled "Training documentation", and has been revised in the final rule to read as follows:
The employer shall document that each employee involved in operating a process has received and understood the training required by this paragraph. The employer shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.
Section 304(c)(9) of the Clean Air Act Amendments mandated that this standard contain a provision requiring employers to "train and educate employees and contractors in emergency response in a manner as comprehensive and effective as that required by the regulation promulgated pursuant to section 126(d) of the Superfund Amendments and Reauthorization Act" (SARA). That section of SARA requires that workers receive a specified minimum number of hours of training unless the worker "has received the equivalent of such training."
It is the Agency's position that the training requirements contained in paragraph (g) of the final rule, together with the requirements pertaining to emergency planning and response contained in paragraph (n) of the final rule (particularly the training requirements mandated by § 1910.38(a)), provide "equivalent training" to the training required for emergency response under section 126(d) of SARA. In addition, those employees who would be involved in emergency response must meet the training requirements in § 1910.120, Hazardous Waste Operations and Emergency Response, referenced in paragraph (n) of this final rule, which is directly responsive to section 126(d) of SARA.
Contractors: Paragraph (h)
In this final rule, paragraph (h), contractors, attempts to distinguish between the many types of contract workers who may be present at a job site and indicates the type of contract worker that the special training provisions of the regulation are attempting to cover. Among the many categories of contract labor that may be present at a particular job site, it is important to appreciate the differences among them. For example, contractors may actually operate a facility for an owner (who may own the facility but have little to do with the daily operation). In this case the contractor is the employer responsible for the covered processes and would obviously be treated as the "employer." Some contractors are hired to do a particular aspect of a job because they have a specialized area of expertise of which the host employer has little knowledge or skill (for example, asbestos removal). Other contractors work on site when the operation has need for increased manpower quickly for a short period of time, such as those involved in a turnaround operation. While paragraph (h)(2) sets forth the duties of the host employer to contract employers, the extent and the depth of these duties will depend to some degree on the category of contractor present. For example, should a contract employer provide employees to operate a process, then those employees would obviously have to be trained to the same extent as the directed hire employees "involved in operating a process" under paragraph (g) of the final standard.
Generally speaking, all OSHA standards cover all employees including contract employees. In something of a break with tradition, the process safety management rule has separate provisions covering the training of contract employees. This was done primarily for emphasis since contract employees make up a significant portion of some segment of industries covered by the final rule. This is not to say, however, that paragraph (h) is the only section of the process safety rule that applies to contractors. As already indicated, under appropriate circumstances, all of the provisions of the standard may apply to a contractor (i.e., a contractor operated facility). After all, employees of an independent contractor are still employees in the broadest sense of the word and they and their employers must not only follow the process safety management rule, but they must also take care that they do nothing to endanger the safety of those working nearby who work for another employer. Moreover, the fact that this rule has a separate section that specifically lays out the duty of contractors on the job site does not mean that other OSHA standards, lacking a similar section, do not apply to contract employers.
OSHA has a long history of enforcing OSHA standards on multi-employer worksites. Nothing in this rule changes the position that the Agency has long taken in cases such as Anning-Johnson (4 O.S.H. Cas. (BNA) 1193), Harvey Workover, Inc. (7 O.S.H. Cas. (BNA) 1687) and in its Field Operations Manual (CPL 2.45B CH–1, Chapter V–9). As a general matter each employer is responsible for the health and safety of
his/her own employees. However, under certain circumstances an employer may be cited for endangering the safety of another's employees. In determining who to hold responsible, OSHA will look at who created the hazard, who controlled the hazard and whether all reasonable means were taken to deal with the hazard.
OSHA proposed in paragraph (h)(1) that the employer inform contractors performing work on or near a process, of the known potential fire, explosion or toxic release hazards related to the contractor's work and the process; ensure that contractor employees are trained in the work practices necessary to safely perform their job; and inform contractors of any applicable safety rules of the facility. OSHA also proposed in paragraph (h)(2) that the employer explain to contractors the applicable provisions of the emergency action plan. The purpose of these proposed requirements was to assure that contractors are aware of both the hazards associated with the work being performed and the actions to be taken during emergencies. Finally, OSHA proposed paragraph (h)(3) that contract employers assure that their employees follow all applicable work practices and safety rules of the facility.
In Issue 7 in the proposal (55 FR at 29159), OSHA requested comments on the extent and adequacy of contractor training. OSHA also asked if the standard should require contractors to inform the plant employer of the hazards presented by the contractor's work, and whether the contractor should be required to inform the employer of any hazards found during the contractor's work.
OSHA received a significant number of comments regarding the proposed contractor provisions (e.g., Ex. 3: 2, 4, 8, 11, 12, 16A, 17, 20, 25, 26, 29, 30, 32, 33, 37, 38, 39, 41, 43, 44, 45, 48, 59, 62, 66, 69, 70, 72, 80, 81, 88, 91, 95, 96, 99, 101, 104, 106, 108, 109, 112, 113, 115, 119, 120, 122, 123, 124, 127, 129, 130, 134, 150, 151, 152, 155, 156; Ex. 91; Ex. 103; Ex. 115; Ex. 128; Ex. 131; Ex. 133; Ex. 134; Ex. 138; Ex. 146; Tr. 741, 1013–14, 1227, 1538, 2009, 2158, 2365, 2445, 2574, 2555, 2695, 3157, 3442, 3605, 3752). Participants generally supported the inclusion of contractor provisions in the final standard. The Department of Environmental Protection of the State of New Jersey (Ex. 3: 20, p. 3) observed:
Contractors should be informed about the potential hazards and risk related to the contracted work. Clear communication must take place between the facility and the contractor concerning safety rules, emergency action plan, scope of work and unforeseen hazards found.
Chevron Corporation (Ex. 3: 29, p. 10) remarked:
Chevron agrees it is appropriate to address contractors in this rule to the extent that the contractors' activities actually bear on process safety.
The Chemical Manufacturers Association (CMA, Ex. 3: 48, p. 15) stated:
CMA concurs with OSHA's decision to address contractor safety within the context of the proposed process safety management standard. Overall, CMA agrees with OSHA's approach * * *
The National Maintenance Agreements Policy Committee, Inc. (NMAPC, Ex. 3: 151, p. 2) remarked:
The NMAPC is in full support of OSHA's attempt to increase the level of safety for all workers at hazardous process facilities and to mitigate the potential for catastrophic accidents. There has been some discussion suggesting that outside contractors are of and by themselves a contributing factor to accidents in these facilities. Nothing could be further from the truth.
Unsafe conditions during maintenance operations are not caused by construction techniques, maintenance methods, tools or workers employed by contractors. What is needed is the assurance that proper training and communication is maintained between the owner and the maintenance contractor during maintenance operations.
Many participants criticized the proposed provisions, observing that they could be interpreted to mean that a plant employer would be responsible for training contractor employees, a responsibility they believed properly belongs to the contract employer (e.g., Ex. 3: 4, 8, 11, 16A, 17, 28, 30, 41, 48, 53, 59, 60, 62, 71, 87, 88, 91, 97, 101, 104, 113, 119, 120, 121, 127, 156, 161; Ex. 115; Ex. 127; Tr. 1597, 3510). The Santa Fe Pacific Pipeline, Inc. (Ex. 3: 124) observed that contractors in some cases are larger organizations than the employer and since an employer is paying a contractor as an expert, questioned how an employer could be expected to provide such training.
Other participants believed that the proposed contractor provisions were inadequate and urged OSHA to more thoroughly address contractors in the final standard (e.g., Ex. 3: 131; Tr. 1287, 1612, 2574, 3197, 3240). For example, the Food and Allied Service Trades Department of the AFL-CIO (Ex. 3: 25, p. 7) noted:
Unfortunately Paragraph (h) perpetuates the dual standard created between regular plant workers and contract employees by this proposed standard. The proposed training programs are far more complete than those for contract workers although both are working at the same worksite, encounter the same dangers and may even be performing similar tasks. The reasons for the disparity in the training requirements are not immediately obvious to us and make little sense. We are unsure why OSHA has opted to establish one set of standards for some workers and a completely different set for others.
Organization Resources Counselors (ORC, Ex. 131, p. 4) stressed:
As discussed in our earlier comments and testimony, the issue of ensuring that contract personnel are adequately trained and supervised to safely perform work in and around highly hazardous chemical processes is an important one. It has become a highly controversial one as well. A number of commenters representing both labor and industry have questioned the adequacy of the language proposed by OSHA to deal with this issue.
ORC continues to recommend that the proposed standard's provisions for ensuring that contract personnel are adequately trained and supervised to safely conduct their work should be considerably strengthened. Also this section (paragraph (h)) should be organized to clearly delineate areas of site employer and contractor responsibility.
Many participants provided specific suggestions on how to revise the proposed provisions to improve, strengthen and clarify the language. Participants in addition to ORC suggested that the final rule should better delineate the duties and responsibilities of site employers who employ contractors and the duties and responsibilities of contractors who are providing specialized services at an employer's site (e.g., Ex. 3: 48, 106, 109; Ex. 128; Ex. 131; Tr. 2574, 3172, 3240, 3260, 3350, 3605).
On September 24, 1991, OSHA published a notice in the Federal Register announcing the availability of a report by the John Gray Institute on contractors and peer review of the report. The public was given an opportunity to comment and reexamine the contractor provisions of the proposed process safety management standard in light of the John Gray Report (56 FR 48133). [See preamble discussion in Part I, Background.] The comment period ended on October 24, 1991, and OSHA received 37 comments in response to the notice.
Generally commenters viewed some of the issues addressed in the John Gray Report (the Report) as important considerations (Ex. 154: 4, 5, 12, 18, 23, 24, 25, 28, 30). However, many commenters expressed their belief that the report should not be used as a basis in the development of the final contractor provisions in the final process safety management standard (e.g., Ex. 154: 4, 5, 7, 10, 12, 14, 15, 20, 23, 24, 30, 33, 34, 36, 37). Commenters
questioned the credibility of the Report's findings and recommendations and pointed to criticisms leveled at the report by its peer reviewers and the criticisms that resulted from the special evaluation of the final John Gray Report (Ex. 154: 3) conducted for The Business Roundtable by the University of Texas at Austin and Texas A&M University (e.g., Ex. 154: 4, 11, 14, 15, 18, 20, 22, 23, 24, 28, 30, 34, 36, 37, 38). The evaluation concluded (p. 2) that the John Gray Report's "conclusions are based on a highly problematic research design, research methodologies, data, analysis of data, and interpretation of results" and further observed (p. 2) that the review teams (one from the University of Texas at Austin and one from Texas A&M University) "are unanimous in concluding that the JGI [John Gray Institute] report should be treated with extreme caution and should not be used as a basis for establishing national policy or industry standards."
Additionally, some commenters observed that the John Gray Report only dealt with the petrochemical industry and that OSHA should not use it to draw conclusions with regard to other industry segments covered by the process safety management standard (Ex. 154: 10, 14, 15).
OSHA has not used the final John Gray Report as a basis for requirements in the development of its final provisions concerning contractors. A review of the comments in the record indicates that significant other information and data is available on which the final contractor provisions can be based. While OSHA has decided not to use the Report as a basis for the final contractor provisions, OSHA believes that the final provisions have benefitted by the additional public input which reconfirms, clarifies and expands on comments and testimony previously received. OSHA believes the safety and health of all employees working in processes involving highly hazardous chemicals will benefit from a safer workforce and a safer workplace.
Despite concerns regarding the John Gray Report, several commenters noted that the Report did address some issues which they agreed with in principle; as a result these commenters suggested additional revisions to further strengthen the contractor provisions in the final standard (e.g., Ex. 154: 7, 13, 19, 20, 24, 25, 27, 36). The Associated Builders and Contractors (Ex. 154: 7, p. 1-2) asserted:
We urge OSHA to expand and strengthen Subparagraph (h) of the proposed rule to clearly assign responsibility to the plant manager and the contractor with respect to the training and supervision of contract workers.
Subparagraph (h) should specifically state that the contractor is responsible for training and supervising its own employees to ensure that they perform their jobs safely and in accordance with the facility's safety rules. The standard should address safety in the selection of contractors, requiring facility owners to obtain and assess the safety performance records of contractors during a pre-bid, qualification round. Similarly, facility owners should conduct periodic reviews of contractors' safety records throughout the performance of the contract and verify contractors are fulfilling their responsibility to provide appropriate health, safety and craft training.
Safety is a shared responsibility. The facility owner hires the contractor for their expertise and contracts for supervisory personnel, as well as skilled tradesmen. The contractor has been selected for their ability to do the job correctly and safely which requires providing personnel with appropriate craft and safety training for each task. Consequently, the contractor is in the best position to train and supervise its own employees.
Communication between plant management and contractors is essential for a safe workplace. The facility owner must provide the contractor with sufficient information to enable the contractor to educate their employees about existing chemicals, potential hazards and site specific safety and health procedures. The contractor must provide its employees with site specific and task specific safety training. Owners may require the contractor to provide additional training on specified topics, and in some instances, may provide funding for the additional training. The facility owners should monitor the contractor's training of employees and audit the contractor's performance.
ABC supports expansion of Subparagraph (h) to incorporate the assignment of responsibility outlined above to improve health and safety practices and process management.
After carefully considering the record, OSHA believes that the expansion of the proposed contractor provisions is necessary and appropriate.
Accordingly, OSHA has been convinced by participants in the rulemaking to revise, reorganize, and add requirements to the final standard's provisions regarding contractors, final paragraph (h). Before discussing the final contractor provisions, OSHA would like to direct interested persons to final Appendix D, Sources of Further Information, which lists several sources of helpful assistance to employers who use contractors.
First, OSHA has added an application statement, paragraph (h)(1), to clarify which contractors are covered by the standard (e.g., Ex. 3: 26, 29, 33, 48, 62, 69, 70, 80, 95, 99, 106, 113, 130, 134, 151; Ex. 128; Ex. 154: 18, 19; Tr. 2774, 3280, 3350).
In the proposal, OSHA intended to cover those contractors whose work brings them into direct contact with, or whose work could affect the hazards of processes covered by the standard. OSHA believes that contractors providing incidental services are adequately covered under the 29 CFR 1910.1200, Hazard Communication standard. Therefore, the final contractor application provision better reflects OSHA's intent regarding which contractors will be covered by the final standard. This paragraph becomes final paragraph (h)(1) and reads as follows:
(h) Contractors. (1) Application. This paragraph applies to contractors performing operating duties, maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process area. It does not apply to contractors providing incidental services which do not influence process safety, such as janitorial work, food and drink services, laundry, delivery or other supply services.
At the request of some rulemaking participants (e.g., Ex. 3: 33, 48, 106, 109; Ex. 128; Ex. 131; Tr. 3172, 3240, 3350, 3805, 3731) who believed that the contractor provisions needed to be clarified and better organized in the final rule, OSHA has delineated the responsibilities of employers and contractors. OSHA believes that the delineation will provide clearer and better organized requirements. Accordingly, OSHA has added paragraph (h)(2), employer responsibilities, and paragraph (h)(3), contract employer responsibilities.
The final provisions concerning employer responsibilities read as follows:
(2) Employer responsibilities. (i) The employer, when selecting a contractor, shall obtain and evaluate information regarding the contract employer's safety performance and programs.
(ii) The employer shall inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractors work and the process.
(iii) The employer shall explain to contract employers the applicable provisions of the emergency action plan required by paragraph (n) of this section.
(iv) The employer shall develop and implement safe work practices consistent with paragraph (f)(4) of this section, to control the entrance, presence and exit of contract employers and contract employees in process areas covered by this section.
(v) The employer shall periodically evaluate the performance of contract employers in fulfilling their obligations as specified in paragraph (h)(3).
(vi) The employer shall maintain a contract employee injury and illness log related to the contractor's work in process areas.
Paragraph (h)(2)(i) of the final standard, requires that an employer, when selecting a contractor, obtain and evaluate information regarding a contractor employer's safety performance and programs. Several commenters noted that this should be an important consideration on the part of an employer when hiring a contractor (e.g., Ex. 115; Ex. 128; Ex. 154: 4, 16A, 18, 19, 20, 23, 24, 25, 30, 31, 35, 36, 38; Tr. 831, 1283, 2034, 2686, 2781, 3525, 3760).
OSHA agrees with these remarks and believes that an employer should be fully informed about a contract employer's safety performance. Therefore the Agency is requiring an evaluation of a contract employer's safety performance (e.g., an employer's experience modification rate) and safety programs. OSHA believes that evaluating safety performance and programs is an important measure in preserving the integrity of processes involving highly hazardous chemicals. OSHA anticipates that the requirement will provide employers an opportunity to assure that they are not introducing additional hazards to their processes; and will give employers an opportunity to request that contract employers improve their safety performance or make other adjustments to their safety programs in order to enhance the safety of all employees working in processes involving highly hazardous chemicals.
The final rule, being performance oriented, does not require that employers refrain from using contractors with less than perfect safety records. However, the employer does have the duty to evaluate the contract employer's safety record and safety programs. Where the evaluation indicates some gaps in the contract employer's approach to safety, the employer may need to be more vigilant in the oversight and may need to develop and implement more stringent safe work practices to control the presence of contractors in covered process areas (see (h)(2)(iv)).
Paragraphs (h)(2) (ii) and (iii) of the final standard were contained in the proposed standard. These provisions require the communication of basic process hazard and emergency information to contract employers and have been retained in the final rule.
Paragraph (h)(2)(iv) of the final standard references a new paragraph concerning safe work practices which was added to the final provisions concerning operating procedures (see discussion in paragraph (f), operating procedures). Organization Resources Counselors (ORC, Ex. 131, p.5) observed:
In the final rule * * * we also recommend that paragraph (h) [Contractors] * * *
contain a provision requiring the employer to develop a procedure for controlling access into covered facilities by contractor personnel. This provision cross-references the general requirements already contained in [the safe work practices in paragraph (f)].
ORC noted the objectives of these additional provisions were to insure that those persons operating high hazard processes are cognizant of any nonroutine work that is occurring and to insure that those in responsible control of the facility are also in control of nonroutine work. The Agency strongly agrees that these additional provisions are important in safely controlling activities in covered processes involving highly hazardous chemicals.
In paragraph (h)(2)(v) of the final standard, OSHA is requiring employers to periodically evaluate the performance of contract employers in fulfilling their obligations. Many participants recommended or followed this type of approach (e.g., Ex. 3: 53, 59, 71, 86; Ex. 115; Ex. 128; Ex. 131; Tr. 1624, 2010, 2442, 2714). ARCO Chemical Company (ACC, Ex. 3: 71, p. 23) stated:
ACC further recommends that OSHA require employers using contractors to verify that all contractor employers have been trained by contractor employers through new requirements * * * These new requirements should stipulate that contractor employers document training of their employees and provide a copy of that documentation to employers for each contractor employee assigned per the contract. This will facilitate a second new requirement for periodic performance assessment that should be placed on employers using contractors to use such documentation for verification purposes. Requiring that a contractor employer document training they provide also holds them accountable, a control measure absent from the proposed rule.
Finally, OSHA has added paragraph (h)(2)(vi) to the final rule which requires a log of injuries and illnesses to be kept by the employer. This was supported by a variety of commenters (e.g., Ex. 3: 39, 86, 106, 152; Ex. 154: 15, 19, 24, 36, 37, 38; Tr. 1227–28, 1283, 1812, 2783, 3319, 3350, 3524, 3617) and many claimed to be doing it already. For example, a participant from Brown and Root Industrial Services (Tr. 3617) responded to a question from an OSHA panel member as follows:
OSHA Panel Member: You would not be at all opposed to the concept of requiring the site employer to keep track of injuries and incidents on the worksite involving everybody on the worksite. Is that correct?
Response: I support that.
OSHA agrees that an employer should be informed of all of the injuries and illnesses occurring in processes involving highly hazardous chemicals at the plant regardless of whether they be the employer's employees or the contractor's employees.
Paragraph (h)(3) of the final rule delineates the contract employer responsibilities and it includes the following provisions:
(3) Contract employer responsibilities. (i) The contract employer shall assure that each contract employee is trained in the work practices necessary to safely perform his/her job.
(ii) The contract employer shall assure that each contract employee is instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the process, and the applicable provisions of the emergency action plan.
(iii) The contract employer shall document that each contract employee has received and understood the training required by this paragraph. The contract employer shall prepare a record which contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training.
(iv) The contract employer shall assure that each contract employee follows all applicable work practices and safety rules of the facility including the safe work practices required by paragraph (f)(4) of this section.
(v) The contract employer shall advise the employer of any unique hazards presented by the contract employer's work, or of any hazards found during the contract employer's work.
Paragraphs (h)(3) (i) and (ii) of the final standard were included in the proposal. These provisions require the communication of basic process hazard and emergency information by the contract employer to the contract employees. They have been retained in the final rule.
Paragraph (h)(3)(iii) of the final rule requires the contract employer to document that each contract employee has received and understood required training. Numerous commenters suggested that such a requirement (Ex. 3: 41, 48, 59, 113, 139, 152; Ex. 128; Ex. 154: 15, 16A, 17, 18, 24, 25, 30, 31, 35, 37, 38, Tr. 1620) is necessary to help ascertain that employees have been properly trained.
The requirements in paragraph (h)(3)(iv) of the final standard were also contained in the proposal except for the addition of the requirement pertaining to safe work practices discussed above. It is vitally important that contract employers assure that their employees follow the rules of the facility.
Paragraph (h)(3)(v) was added to the final rule as a result of the request for information in the proposal (55 FR at 29159). OSHA asked if the standard should require contract employers to inform the plant employer of the hazards presented by the contractor's work, and
whether the contractor should be required to inform the employer of any hazards found during the contractor's work. Participants supported the inclusion of this requirement (Ex. 3: 28, 41, 48, 53, 70, 71, 97, 109, 112, 113, 115, 120, 123, 146; Ex. 115; Ex. 127; Ex. 128; Tr. 1597, 2010, 2656, 3263, 3450).
Finally, the section 304 requirements of the Clean Air Act Amendments (CAAA) state that the OSHA standard must require employers to:
(8) Ensure contractors and contract employees are provided appropriate information and training.
(9) Train and educate employees and contractors in emergency response in a manner as comprehensive and effective as that required by the regulation promulgated pursuant to section 126(d) of the Superfund Amendments and Reauthorization Act.
OSHA believes that the contractor provisions contained in the final standard meet the requirements contained in section 304(c) (8) and (9) of the CAAA in a manner as comprehensive and effective as that required by the regulation promulgated pursuant to section 126(d) of the Superfund Amendments and Reauthorization Act for the reasons described in the preamble discussion regarding section 126(d) of the Superfund Amendments in paragraph (g), Training.
Pre-startup Safety Review: Paragraph (i)
Proposed paragraph (i)(1) required the employee to perform a pre-startup safety review for new facilities and for modified facilities when the modification necessitated a change to the process safety information. The purpose of this proposed requirement was to make sure that certain important considerations had been addressed before any highly hazardous chemical was introduced into a process.
Rulemaking participants (e.g., Ex. 3: 17, 26, 59, 82, 128) agreed with the importance of performing a pre-startup safety review to assure that adequate safety measures are in place and are operational. However, a few commenters (e.g., Ex. 3: 45, 71) did not believe it was necessary to require a pre-startup safety review for all modified facilities, particularly when the modifications were minor. These commenters suggested adding the word "significant" to this provision to describe the degree of modification that would necessitate a pre-startup safety review.
It was not the intent of OSHA to require a pre-startup safety review for each facility that may be modified slightly. OSHA believes that a pre-startup safety review is necessary for modified facilities only when the modification is significant enough to require a change in the process safety information. The Agency has made minor editorial changes to this provision in the final rule to clarify its intent.
Proposed paragraph (i)(1) has been revised to read as follows:
The employer shall perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.
Paragraph (i)(2) of the proposal required that the pre-startup safety review confirm that construction was in accordance with design specifications, ((i)(2)(i)); safety, operating, maintenance, and emergency procedures were in place and were adequate ((i)(2)(ii)); process hazard analysis recommendations had been addressed and actions necessary for startup had been completed ((i)(2)(iii)); and, operating procedures were in place and training of each operating employee had been completed ((i)(2)(iv)).
OSHA did not receive any negative comments with respect to proposed paragraphs (i)(2)(ii) and (i)(2)(iii). Therefore, these two provisions of the final rule remain the same as that which was proposed.
A few commenters (e.g., Ex. 3: 48, 71; Tr. 1933–35) believed that paragraph (i)(2)(iii) of the proposal was unclear and asked whether it implied that a process hazard analysis was required before startup for both new facilities and modified facilities. This was not the intent of OSHA. OSHA wants to assure that a process hazard analysis is performed for new facilities before startup, and that recommendations resulting from the process hazard analysis have been addressed before startup. The Agency believes that any actions necessary before startup in modified facilities will be addressed by the requirements contained in paragraph (1) of this section pertaining to management of change. Therefore, OSHA has revised paragraph (i)(2)(iii) of the final rule to clarify its intent.
Other commenters (e.g., Ex. 3: 71, 87) asserted that it is not necessary that all recommendations resulting from a process hazard analysis be implemented before startup. OSHA agrees with these commenters. Certainly, all of the recommendations resulting from a process hazard analysis need to be addressed or resolved, but it may not be necessary in every case to complete all of the recommendations prior to startup.
Accordingly, proposed paragraph (i)(2)(iii) has been revised in the final rule to read as follows:
For new facilities, a process hazard analysis is performed and recommendations have been resolved or implemented before startup; and modified facilities meet the requirements contained in management of change, paragraph (1).
In proposed paragraph (i)(2)(iv) OSHA required that operating procedures be in place prior to the introduction of a highly hazardous chemical to a process. Several commenters (e.g., Ex. 3: 53, 64, 71) noted that proposed paragraph (i)(2)(ii) also required that operating procedures be in place prior to the introduction of a highly hazardous chemical to a process. OSHA agrees that paragraph (i)(2)(ii) of the final rule already requires operating procedures to be in place and, therefore, the redundant reference to operating procedures has not been retained in paragraph (i)(2)(iv) of the final rule.
Mechanical Integrity: Paragraph (j)
Proposed paragraph (j) contained requirements for maintaining the mechanical integrity of process equipment in order to assure that such equipment is designed, installed, and operates properly.
Paragraph (j)(1) of the proposal specified certain process equipment to which the requirements of this paragraph would apply. This equipment included pressure vessels and storage tanks; piping systems (including piping components such as valves); relief and vent systems and devices; emergency shutdown systems; and controls, alarms, and interlocks. The Agency believed that any of this equipment could have a significant impact on the safety of a process that is covered by this standard if the equipment was improperly designed or installed or, if such equipment did not function as intended.
In the proposal OSHA specifically requested information and comments on whether the equipment listed in proposed paragraph (j) included equipment that does not impact the safety of a process, or whether additional equipment should be listed and covered by paragraph (j) (55 FR at 29159).
Several rulemaking participants (e.g., Ex. 3: 39, 41, 53, 71, 76; Ex. 127; Tr. 316, 1023, 1538, 1812) suggested that the Agency define the term "critical," and add this term to describe the process equipment that is to be covered by this paragraph. Some of these rulemaking participants also believed that the employer should be permitted to determine what process equipment should be identified as "critical." For example, a commenter from Chevron Corporation (Ex. 3: 28A, p.12) stated:
The basic intent of the mechanical integrity provision in the proposed rule is to ensure that highly hazardous chemicals are contained within the process and not released in an uncontrolled manner. To achieve this intent, Chevron believes OSHA should use performance language and require the employer to develop and maintain a list of equipment that the employer has determined to be critical to process safety. This equipment would be subject to the provisions of paragraph (j).
A commenter from the Chemical Manufacturers Association (CMA, Ex. 3: 48, p. 17) asserted:
Since all process equipment within a plant is not necessarily associated with Appendix A materials or flammable liquids or gases, CMA believes that section (j) should only apply to "Critical Equipment". CMA recommends that section (j) and a definition for critical equipment be reworked to ensure that this section pertains only to "Critical Equipment".
Rather than specify types of equipment as is in (j)(1), OSHA should use a performance oriented approach and require the employer to develop and maintain a list of equipment that has been determined to be critical to process safety. This equipment would be subject to the provisions of paragraph (j).
A hearing participant from the Gas Processors Association (GPA, Tr. 1539) testified:
GPA recommends that companies be required to define critical equipment at each facility and maintain a current list. GPA does not believe a generic list can be appropriate for all facilities.
Additionally, a commenter from the Chlorine Institute (Ex. 3: 113, p.3) added:
Instead of listing non specific equipment as is done in paragraph (j), the rule should require that the employer determine which process equipment is critical to prevention of a catastrophic release.
Other rulemaking participants (e.g., Ex. 3: 45, 51, 64, 96) agreed with the approach that the Agency proposed. For example, a commenter from the American Paper Institute (Ex. 3: 45, p.19) stated:
The list of equipment subject to the mechanical integrity requirements seems appropriate, except API believes that OSHA should add pumps to the list of process equipment.
A commenter from the Northwest Pipeline Corporation (Ex. 3: 96, p.4) said:
The equipment listed in paragraph (j) impacts the safety of a process and is adequate with respect to process safety at Northwest's facilities that would fall within the scope of the proposed standard.
Another commenter, who is from the Occidental Chemical Corporation (Ex. 3: 70-A, p.8), remarked:
"Critical" process equipment will vary from process to process. The generic listing in section (j) seems to be complete.
OSHA agrees with those rulemaking participants who believe that the goal of the mechanical integrity provisions is to ensure that highly hazardous chemicals covered by the standard are contained within the process and not released in an uncontrolled manner. The equipment OSHA has listed in proposed paragraph (j)(1) constitutes process equipment that the Agency considers critical in achieving this goal.
OSHA also agrees with those rulemaking participants who stated that process equipment will vary from process to process. This is the reason that the Agency did not propose that the employer determine the equipment "critical" to the process. Equipment considered critical to a process by one employer may not necessarily be considered critical to a different process by another employer. As a result, there could be confusion with respect to which equipment is subject to the requirements contained in paragraph (j).
The Agency believes that there is certain equipment, critical to process safety, that is common to all processes. This is the equipment specified in proposed paragraph (j)(1). It is the position of OSHA that at least the equipment specified in proposed paragraph (j)(1) must be subject to the requirements contained in paragraph (j). However, if an employer deems additional equipment to be critical to a particular process, that employer should consider that equipment to be covered by this paragraph and treat it accordingly.
OSHA also concurs with those rulemaking participants who said that all process equipment within a plant is not necessarily associated with appendix A materials or flammable liquids or gases. Paragraph (j)(1) is intended to cover only that equipment associated with a process that is covered by this standard.
After careful evaluation of the information contained in the record, OSHA believes that it is appropriate for the mechanical integrity requirements in paragraph (j) to apply to the equipment listed in proposed paragraph (j)(1). OSHA is accepting the recommendation of the American Paper Institute (Ex. 3: 45) and the United Steelworkers of America (Tr. 2512) that pumps be added to the list since OSHA agrees that pumps in a covered process could also significantly impact the safety of a process.
Accordingly, Paragraph (j)(1) of the final rule remains the same as that which was proposed except pumps (paragraph (j)(1)(vi) of the final rule) have been added to the list of process equipment that must meet the mechanical integrity requirements contained in paragraph (j).
Paragraph (j)(2) of the proposal pertained to written procedures with respect to mechanical integrity. Proposed paragraph (j)(2)(i), required the employer to establish and implement written procedures to maintain the on-going integrity of listed process equipment. The purpose of this proposed provision was to require a written program that would assure that process equipment receives careful, appropriate, regularly scheduled maintenance to assure its continued safe operation.
The Agency did not receive any comments on this proposed provision and it is contained in the final rule as proposed. However, this provision has been redesignated as paragraph (j)(2) in the final rule instead of paragraph (j)(2)(i), because (as discussed below) the subsequent proposed paragraph concerning training of maintenance employees will be redesignated in the final rule.
Paragraph (j)(2)(ii) of the proposal required the employer to assure that each employee involved in maintaining the on-going integrity of process equipment be trained in the procedures applicable to the employee's job tasks. Several rulemaking participants (e.g., Ex. 3: 17, 53; Tr. 313, 389) were concerned that there might be some confusion with respect to the training requirements contained in paragraph (g), which apply to employees who are involved in operating a process, and the training requirements contained in this provision, which apply to maintenance employees. It was suggested that all training requirements be contained in paragraph (g) or, alternatively, that the Agency clarify that there are separate training requirements for maintenance employees. Other rulemaking participants (e.g., Ex. 3: 17, 53, 71; Tr. 313, 389) suggested that, because of its importance, the training requirement for maintenance employees should be separated from proposed paragraph (j)(2) and given its own heading. For example, a commenter from Organization Resources Counselors, Inc. (Ex. 3: 53, p.14) stated:
Training is an important issue which warrants special attention. Such attention might be better focused if the requirements in (j)(2)(ii) were separated from the current paragraph (j)(2), identified as (j)(3), and given their own heading * * *.
OSHA believes that this is an excellent suggestion because it will focus more attention on the importance
of training of persons involved in maintaining equipment and will better distinguish these training requirements from those contained in paragraph (g).
The Agency was also concerned that there might be some confusion between the training requirements in this mechanical integrity provision, and the training requirements contained in paragraph (g). It is the Agency's position that maintenance employees need not be trained in process operating procedures to the same extent as those employees who are actually involved in operating the process.
However, OSHA believes that maintenance employees must receive on-going training in an overview of the process and its hazards and training in the procedures applicable to their job tasks to assure that they can perform their tasks in a safe manner. Without continual attention to training needs due to process changes and other changes, little assurance will exist that maintenance employees will perform their tasks safely.
OSHA believes that assigning this paragraph its own heading will focus more attention on the training requirements contained in this provision, and will help to clarify the distinction between the training requirements pertinent to mechanical integrity and the training requirements pertinent to employees involved in operating a process.
The Agency also believes that it is necessary to revise this proposed paragraph to better describe its intent regarding the training of maintenance employees.
Consequently, this proposed provision has been redesignated as paragraph (j)(3), assigned the title of "Training for process maintenance activities", and has been revised to read as follows:
The employer shall train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner.
Paragraph (j)(3)(i) of the proposal required inspections and tests to be performed on specified process equipment because of the potential safety and health hazards that could result if the equipment malfunctioned.
The Agency did not receive any comments on this particular provision, and it is contained in the final rule as proposed. However, it has been redesignated as (j)(4)(i) in the final rule instead of (j)(3)(i) as proposed.
In an effort to assure that inspections and tests are performed properly, proposed paragraph (j)(3)(ii) required that inspection and test procedures follow applicable codes and standards. Paragraph (j)(3)(ii) also contained examples of codes and standards that an employer could use to comply with this proposed provision.
Many rulemaking participants disagreed with this proposed provision (e.g., Ex. 3: 12, 53, 64, 67, 97, 121; Tr. 722-23, 798-97, 2177). Some commenters were concerned that the Agency would incorporate by reference all of the codes applicable to testing and inspection such as those published by the National Fire Protection Association (NFPA), the American Society for Testing and Materials (ASTM), the American National Standards Institute (ANSI), etc. These commenters asserted that it would be difficult for an employer to obtain all such standards and decide which standards the Agency intended for them to use. They also stated that some of the standards may conflict with each other.
Other commenters were concerned that some of the standards may be outdated and no longer applicable to their process equipment. As a result, many of these commenters suggested that the employer be permitted to use their own internal standards, or that inspection and testing procedures follow recognized and generally accepted good engineering practices. For example, a commenter from the ARCO Chemical Company (ACC, Ex. 3: 71, p.26) remarked:
Subparagraphs (j)(3)(ii) and (j)(3)(iii) require equipment testing and inspection per "applicable" codes and standards "where they exist." Since some of these standards may be outdated and no longer represent a consensus of "good engineering practices", OSHA should provide employers the option of using internal engineering standards and practices, or practices recommended by equipment manufacturers.
Further, as stated previously in ACC comments, the standards and guidelines often represent the minimum (least common denominator) agreed to by the participants in the organization specifying the performance requirements. Consequently, OSHA should also allow employers the option of using more demanding internal standards as the source of primary requirements.
A commenter from MARS Incorporated (Ex. 3: 87, p.2) added:
A second overall concern is our strong objection to what appears to be an attempt to incorporate by reference into the Standard—binding legal requirements—all relevant codes and standards issued by the American Society of Mechanical Engineers, the American National Standards Institute, the American Society of Testing and Materials and the National Fire Protection Association.
A commenter from Union Carbide (Ex. 3: 112, p.21) stated:
These sections, which pertain to compliance with applicable codes and standards for equipment testing and inspection, are very restrictive.
We suggest that this section be modified to provide employers the latitude to use internal engineering standards and practices and standards and practices recommended by equipment manufacturers, for compliance with this section.
Additionally, a commenter from the American Iron and Steel Institute (Ex. 3: 161, p.22) said:
Paragraph (j)(3) is unclear. It should be revised to specify that inspections and tests shall be performed on process equipment "in accordance with applicable codes, standards, or recognized and generally accepted engineering practice."
The codes and standards contained in proposed paragraph (j)(3)(ii) were examples of what the employer could use for inspection and testing of process equipment. The Agency did not intend to incorporate by reference into the standard all of the codes and standards published by these consensus groups. As noted above, the purpose of this proposed provision is to make sure that process equipment is inspected and tested properly, and that the inspections and tests are performed in accordance with appropriate codes and standards. The phrase suggested by rulemaking participants: "recognized and generally accepted good engineering practices" is consistent with OSHA's intent. The Agency also believes that this recommended phrase would include appropriate internal standards of a facility, as well as codes and standards published by NFPA, ASTM, ANSI, NFPA, etc.
Accordingly, proposed paragraph (j)(3)(ii) has been redesignated as paragraph (j)(4)(ii) in the final rule, and has been revised to read as follows:
Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.
Paragraph (j)(3)(iii) of the proposal required the frequency of inspections and tests to be consistent with applicable codes and standards; or, more frequently if determined necessary by prior operating experience. This proposed provision was a performance-oriented requirement that would provide flexibility for the employer to choose the frequency which would provide the best assurance of equipment integrity.
Several rulemaking participants (e.g., Ex. 3: 12, 53, 97, 161) suggested that if this provision is to be truly performance-oriented, employers should have the flexibility to follow internal standards and manufacturers' recommendations as well as applicable codes and standards.
OSHA agrees with these rulemaking participants. Since the phrase "recognized and generally accepted good engineering practices" would include both appropriate internal standards and applicable codes and standards, the Agency has decided to use this phrase in this provision of the final rule.
Accordingly, proposed paragraph (j)(3)(iii) has been redesignated as paragraph (j)(4)(iii) in the final rule, and has been revised to read as follows:
The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.
Proposed paragraph (j)(3)(iv) required the employer to have a certification record that each inspection and test had been performed in accordance with paragraph (j). It also required that the certification identify the date of the inspection; the name of the person who performed the inspection and test; and, the serial number or other identifier of the equipment.
Several rulemaking participants (e.g., Ex. 3: 33, 39, 71, 101) disagreed with the use of the term "certification" because they believed that the term "certification" could be misinterpreted to mean an assurance by a third party. These rulemaking participants suggested that "documentation" would be a better term. For example, a commenter from Monsanto (Ex. 3: 64, p. 9) stated:
In paragraph (j)(3)(iv), Monsanto recommends that the requirement for certification be deleted. The tests and inspections should be documented but certification, which implies a signature, should not be required. Electronic storage of the documentation is necessary and certification prohibits that or requires parallel hard copy be maintained in the files which is unnecessary.
A commenter from IMCERA (Ex. 3: 158, p. 6) remarked:
IMCERA feels that the word "certification" should be replaced with "documentation." * * * Certification is commonly used in connection with validation by an outside professional body. We believe that the word "documentation" would better serve in this statement and avoid unnecessary confusion.
OSHA agrees that the word "documentation" (or "document") is descriptive of the Agency's intention with respect to this information.
Additionally, since OSHA is permitting inspection and test procedures to follow recognized and generally accepted good engineering practices, the Agency believes that different information than that proposed should be included in the record to identify the inspections and tests that were performed, and the results of those tests and inspections.
Therefore, proposed paragraph (j)(3)(iv) has been redesignated as paragraph (j)(4)(iv) in the final rule, and has been revised to read as follows:
The employer shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test; the name of the person who performed the inspection or test; the serial number or other identifier of the equipment; the inspection or test that is performed; and, the results of the inspection or test.
Proposed paragraph (j)(4) required the employer to correct deficiencies in equipment which are outside acceptable limits before further use. OSHA received some excellent comments on this proposed provision. While most rulemaking participants agreed with the concept that equipment deficiencies must be corrected, several commenters (e.g., Ex. 3: 28, 39, 53, 64, 161) disagreed that the deficiencies must be corrected "before further use." It was contended that the phrase "before further use" would mean that the process would have to be shutdown, and that shutdown has its own inherent hazards. It was suggested that equipment operating beyond acceptable limits does not always create a serious hazard. Participants asserted that deficiencies might need to be corrected promptly, or in a time and manner to assure safe operation instead. As an example, a commenter from Allied Signal (Ex. 3: 17, p. 13) said:
We recommend that the words "before further use" be deleted from paragraph (j)(4), and that the paragraph be rewritten to read: "The employer shall promptly correct deficiencies in equipment which are outside acceptable limits." The rationale for this change is that it is not always possible to correct a deficiency before further use, particularly with continuous process units. Moreover, immediate or rushed shut-downs can introduce risks that could otherwise be avoided.
A commenter from the Chevron Corporation (Ex. 3: 26, p. 12) remarked:
Under (j)(4) the OSHA-proposed language seems to require that when deficiencies are found, the process must be shut down before further use. But not all deficiencies result in an unsafe condition. Chevron therefore recommends the following for (j)(4):
"The employer shall correct deficiencies in critical equipment which are outside acceptable limits, before further use or in a time and manner to ensure safe operation."
Another commenter, who was from the ARCO Chemical Company (ACC. Ex. 3: 71, p. 26-27), stated:
ACC recommends that OSHA revise the text) * * * to read as follows:
"The employer shall promptly correct deficiencies in critical equipment so that critical equipment is within safe and acceptable limits, which are included in the process safety information required by paragraph (d)".
This language would tie this section into the requirements of subparagraph (d)(3) which pertains to information covering the critical equipment in a process subject to the proposed rule.
This language has also substituted the word "promptly" for the phrase "before further use". This change is suggested to allow employers the decision-making responsibility for determining whether to continue to operate, to shut down, to isolate equipment, etc. Immediate actions can introduce increased process risks that could otherwise be avoided.
Additionally, a commenter from the AMOCO Corporation (Ex. 3: 95, p. 8) stated:
In refining processes, there are occasionally instances when a piece of equipment exceeds what is deemed "acceptable", and interim measures are taken to bring the equipment back into conformance with safe operating parameters. Under (j)(4) it would be mandatory to immediately shut down the entire process upon discovery of such a situation. Shutdowns and startups are inherently dangerous operations which we try to avoid unless absolutely necessary. In addition, the life expectancy of certain components is directly affected by the number of cycles to which they are subjected. We feel that safety is promoted rather than diminished by keeping shutdowns to a minimum. We therefore propose that the phrase "before further use" be replaced with "in a safe and timely manner".
The purpose of this proposed requirement was to require equipment deficiencies to be corrected promptly if the equipment was outside the acceptable limits specified in the process safety information. The comments have convinced OSHA that there may be many situations where it may not be necessary that the deficiencies be corrected "before further use" as long as the deficiencies are corrected in a safe and timely manner when necessary means are taken to assure safe operation.
Consequently, proposed paragraph (j)(4) has been redesignated as paragraph (j)(5) in the final rule, and has been revised to read as follows:
The employer shall correct deficiencies in equipment that are outside the acceptable limits defined by the process safety information in paragraph (d) before further use, or in a safe and timely manner when necessary means are taken to assure safe operation.
Paragraph (j)(5) of the proposal pertained to quality assurance of mechanical equipment. Proposed paragraph (j)(5)(i) required the employer to assure that equipment as fabricated meets design specifications. Some rulemaking participants (e.g., Ex. 3: 53, 59, 71; Tr. 1124) suggested that this proposed paragraph be clarified as it relates to the construction of new plants and equipment. The Agency agrees with these rulemaking participants since this was the actual intent of this proposed provision.
Another commenter (Ex. 3: 28) asserted that employers cannot be held accountable for the design specifications of the original equipment manufacturer, and suggested that the phrase, "meets design specifications" be replaced with the phrase, "is suitable for the process application." The Agency believes that the suggested change better describes the purpose of this proposed provision.
Accordingly, proposed paragraph (j)(5)(i) has been redesignated as paragraph (j)(6)(i) in the final rule, and has been revised to read as follows:
In the construction of new plants and equipment, the employer shall assure that equipment as it is fabricated is suitable for the process application for which it will be used.
Proposed paragraph (j)(5)(ii) required appropriate checks and inspections to be performed as necessary to assure that equipment is installed properly and consistent with design specifications and manufacturer's instructions. The Agency did not receive any negative comments on this proposed provision and it is contained in the final rule unchanged. However, it has been redesignated as paragraph (j)(6)(ii) in the final rule.
Proposed paragraph (j)(5)(iii) required the employer to assure that maintenance materials, and spare parts and equipment, meet design specifications. Some commenters (e.g., Ex. 3: 28, 127, 158) expressed concerns with the phrase, "meet design specifications" similar to the concerns discussed above regarding paragraph (j)(6)(i) of the final rule. To clarify the Agency's intent and in order to be consistent with paragraph (j)(6)(i) of the final rule, the proposed paragraph, which becomes final paragraph (j)(6)(iii), has been revised to read as follows:
The employer shall assure that maintenance materials, and spare parts and equipment are suitable for the process application for which they will be used.
**Hot Work Permit: Paragraph (k)**
In proposed paragraph (k)(1), OSHA required the employer to issue a permit for all hot work operations. The purpose of this proposed provision was to assure that the employer was aware of the hot work being performed, and that appropriate safety precautions had been taken prior to beginning the work.
The Agency did propose certain exceptions to this provision which included the following: Where the employer or the employer's representative, designated as responsible for authorizing hot work operations, is present while the hot work is being performed; and in welding shops authorized by the employer.
While a few rulemaking participants agreed with the Agency's approach (e.g., Ex. 3: 62, 162), many rulemaking participants (e.g., Ex. 3: 38, 53, 59, 71, 121, 153; Tr. 312–13) opposed the exceptions to this proposed provision. For example, a commenter from the Food and Allied Service Trades, AFL–CIO (Ex. 3: 25, p. 9) stated:
The first exception would forego the issuance of a permit if the employer or employer's representative is present during the work. We feel that this exception is unfounded and should be deleted from the rule.
Permits are required as a means of requiring employers to reexamine any and all processes for potential dangers. We feel that this analysis should take place for all hot work that may be necessary.
A commenter from Hoechst Celanese (Ex. 3: 78, p.3) said:
The exception to hot work permits provided for in paragraph (k)(1) is not appropriate. Strict adherence to established hazardous work permitting procedures must be maintained to assure safe work activity.
Another commenter, who was from MARS Incorporated (Ex. 3: 87, p.15), remarked:
The proposed standard requires that a hot work permit be required except where the person responsible for the permit is present. We are opposed to such an exemption and to any system that authorizes "general" hot work permits. The purpose of the permit system is not only to assure that the appropriate personnel are notified of the work. It is also to remind the person performing the work of the steps necessary to perform the job safely. Merely having the authorizing person present does not assure that all the proper steps are followed. The only way to do this is to require a permit which follows a systematic approach to granting the authority to do the work.
The second exception given is for hot work in welding shops. Unless the welding shop is located in the process area, it is not clear that such a location would be covered by the proposed Standard.
A hearing participant from Organization Resources Counselors, Inc. (ORC, Tr. 312–13) testified:
In the proposal, OSHA has addressed the issue of hot work, but ORC strongly disagrees with the proposal to exempt from hot work permitting procedures those cases where "the employer or his representative designated as responsible for authorizing hot work operations is present while the work is being performed."
Hot work permits and procedures should be followed regardless of who is present. Consistent use of effective safety procedures is an important step in preventing incidents which can result in catastrophic releases, fires, and explosions.
Additionally, a commenter from Vulcan Chemicals (Ex. 3: 101A, p.4) stated:
Vulcan Chemicals disagrees with the exceptions for performing hot work in paragraph (k). There should not be an exception to the hot work requirements because of the presence of an individual authorizing the work.
OSHA agrees with the commenters that the permit reminds the person performing the work of the steps necessary to perform the work safely; and if the hot work is performed on or near a covered process, then a permit should be required regardless of who is present. Additionally, this proposed provision would not require a permit for hot work operations in a welding shop unless the welding shop was located in a process area covered by the standard. OSHA believes that such a location would not exist. Consequently, the Agency has concluded that the proposed exceptions to this hot work provision are not appropriate, and the exceptions have not been retained in the final rule.
Therefore, paragraph (k)(1) of the final rule has been revised to read as follows:
The employer shall issue a hot work permit for hot work operations conducted on or near a covered process.
Proposed paragraph (k)(2) required the permit to certify that the fire prevention and protection requirements contained in 29 CFR 1910.252(a) had been implemented prior to beginning the hot work operations; indicate the date authorized for the hot work; and identify the equipment or facility on which the hot work was to be performed. It also required the permit to be kept on file until completion of the hot work.
Most rulemaking participants supported this proposed provision. However, one commenter (Ex. 3: 53) suggested that the Agency not address the contents of the permit. The Agency disagrees with this suggestion because it believes that it is important that employers are informed of what the Agency expects the permit to contain.
Another commenter (Ex. 3: 158) suggested that the word "certify" be
replaced with the word "document." The Agency is accepting this suggestion because it believes that the word "document" is descriptive of the intent of this proposed provision and is consistent with other changes made elsewhere in the final rule.
Accordingly, paragraph (k)(2) of the final rule remains the same as that which was proposed except for minor editorial changes which were made to clarify the intent of the requirement.
Management of Change: Paragraph (1)
OSHA believes that one of the most important and necessary aspects of a process safety management program is appropriately managing changes to the process. This is because many of the incidents that the Agency has reviewed resulted from some type of change to the process (e.g., the Flixborough incident).
Proposed paragraph (1) addresses management of change. While the Agency received some excellent suggestions concerning minor changes to improve this proposed provision, there was wide support for including a provision concerning the management of change in the final rule (e.g., Ex. 3: 41, 48, 62, 69, 71, 95, 101).
OSHA believes that it is necessary to thoroughly evaluate any contemplated changes to a process to assess the potential impact on the safety and health of employees and to determine what modifications to operating procedures may be necessary.
Proposed paragraph (1)(1) required the employer to establish and implement written procedures to manage changes (except for "replacement in kind") to process chemicals, technology, and equipment; and changes to facilities.
The Agency agrees with this suggestion. OSHA believed that this intent was addressed in proposed paragraph (1)(2)(iii) and (1)(5). However, in order to resolve any ambiguity, the Agency is adding the word "procedures" to paragraph (1)(1) of the final rule.
Other rulemaking participants recommended that the phrase "changes to facilities" be replaced by the phrase "changes to facilities that affect a process." For example, a commenter from Amoco Corporation (Ex. 3: 95, p.8) stated:
Amoco endorses the management of change provisions at paragraph (1), with the provision that under (1)(1) " * * * changes to facilities" be limited to " * * * changes to facilities which affect a process", in order to exclude incidental changes which have no bearing on safety.
A commenter from the American Iron and Steel Institute (Ex. 3: 161, p.23) remarked:
Subsection (1) should be modified to make clear that it applies only to those changes which may affect process safety. For example, as currently defined, "facility" means the "buildings, containers, or equipment which contain a process". In the steel industry, the building containing a process may be quite large, and many changes could conceivably be made to the structure itself which would have no impact on the safety of the process contained within the building. We do not understand OSHA to intend that such a change would be subject to the requirements of subsection (1). This point should be made clear in the final rule.
Again, it was the intent of the Agency that the phrase "changes to facilities" would mean only those facilities that would have an impact on a process covered by the proposed standard. To clarify its intent, the Agency has revised paragraph (1)(1) of the final rule to read, "changes to facilities that affect a covered process."
Consequently, proposed paragraph (1)(1) has been revised in the final rule to read as follows:
The employer shall establish and implement written procedures to manage changes (except for "replacement in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.
Proposed paragraph (1)(2) contained several considerations that must be addressed prior to any change. OSHA did not receive any comments with respect to this proposed provision and it is contained in the final rule as proposed, except for a minor editorial change.
Proposed paragraph (1)(3) required that employees involved in the process be informed of and trained in the change in the process as early as practicable prior to its implementation. Some rulemaking participants (e.g., Ex. 3: 26, 69, 91, 107, 121) suggested that this proposed provision be revised to clarify that the Agency intended the phrase "employees involved in the process" to mean only operating employees. They asserted that this change would make it clear that the proposed provision did not apply to maintenance or contract workers. These commenters misinterpreted the Agency's intent. OSHA believes that all employees whose job tasks will be impacted by a change must be informed of and trained in those changes with respect to what affect such changes will have on their job tasks. Otherwise, contract employees or maintenance employees who are unaware of the change, may unwittingly cause an incident by doing their job tasks as they have in the past. OSHA believes this training requirement to be important for maintenance and contract employees as well as those employees involved in operating a process.
The Agency has revised this provision in the final rule to clarify that this information and training provision applies to operating employees as well as to maintenance and contract employees whose job tasks will be affected by the change.
Other rulemaking participants (e.g., Ex. 3: 26, 56, 59; Tr. 2015) recommended that the phrase "prior to its implementation" be changed to "prior to start-up" to eliminate a possible misinterpretation of meaning before the change is made. OSHA agrees that the requirements contained in this provision must be completed before start-up and not necessarily before implementation of the change.
Accordingly, proposed paragraph (1)(3) has been revised in the final rule to read as follows:
Employees involved in operating a process and maintenance and contract employees
whose job tasks will be affected by a change in the process shall be informed of, and trained in, the change prior to start-up of the process or the affected part of the process.
Paragraph (1)(4) of the proposal required that if a change covered by this paragraph results in a change to the process safety information, that such information be appended and/or updated in accordance with paragraph (d) of this section. The Agency did not receive any comments on this proposed provision. It is, therefore, contained in the final rule as proposed, except for minor editorial changes that were made to eliminate unnecessary words.
Proposed paragraph (1)(5) required that if a change covered by this paragraph results in a change to the operating procedures, such procedures shall be appended and/or updated in accordance with paragraph (f) of this section. Again OSHA did not receive any comments on this proposed provision and it is contained in the final rule as proposed except for minor editorial changes that were made to eliminate unnecessary words.
**Incident Investigation: Paragraph (m)**
OSHA included requirements for incident investigation in the proposal because a crucial part of any process safety management program is the thorough investigation of any incident that resulted in, or could reasonably have resulted in a catastrophic release of a highly hazardous chemical in the workplace. Such investigations are extremely important for identifying the chain of events leading to the incident and for determining causal factors. Information resulting from the investigation will be invaluable to the development and implementation of corrective measures and for use in subsequent process hazard analyses.
Proposed paragraph (m)(1) required the employer to investigate every incident which results in, or could reasonably have resulted in (near miss), a major accident in the workplace. This proposed provision received wide support throughout the rulemaking proceeding, although several rulemaking participants (e.g., Ex. 3: 12, 26, 69, 112, 121, 149, 158; Ex. 91; Tr. 678, 1938) were opposed to the use of the term "major accident." These commenters contended that if this term is to be used, then OSHA should define "major." Other rulemaking participants (e.g., Ex. 3: 17, 53, 64, 71; Tr. 1575) suggested that the term "major accident" be replaced with the term "catastrophic release" and then "catastrophic release" should be defined. OSHA agrees that the applicability of this proposed provision should be better defined. The Agency has decided to replace the term "major accident" with the term "catastrophic release" since this term is more consistent with the focus of the final rule and as discussed has added a definition for "catastrophic release" to paragraph (b) of the final rule.
Consequently, proposed paragraph (m)(1) has been revised in the final rule to read as follows:
The employer shall investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of a highly hazardous chemical in the workplace.
Proposed paragraph (m)(2) required incident investigations to be initiated as promptly as possible, but no later than 48 hours following the incident. It is important that an incident investigation be initiated promptly so that events can be recounted as clearly as possible; to preserve crucial evidence; and so that there is less likelihood that the scene will have been disturbed. The Agency also realizes that circumstances may not facilitate an immediate investigation because of the potential emergency nature of some incidents. This is the reason that this proposed provision required investigations to be initiated as promptly as possible, "but not later than 48 hours following the incident."
A few rulemaking participants disagreed with the 48 hour requirement contained in this proposed provision, and suggested several alternatives. For example, a commenter from the National Solid Waste Management Association (Ex. 3: 57, p.8) remarked:
By "incident", NSWMA assumes that OSHA is referring to a release of a HHC. The NSWMA is opposed to the subjectivity introduced to this requirement by the word "could." In fact, all unintentional or unauthorized releases should be investigated. As weekends and holidays may interfere with the 48-hour deadline to initiate investigations, NSWMA recommends that the time frame be extended to 72 hours.
A commenter from Monsanto (Ex. 3: 64, p. 10) said:
Paragraph (m)(2) requires that an incident investigation begin no later than 48 hours following the incident. This is acceptable for incidents involving a fatality, multiple injuries or catastrophic releases. However, this is an unnecessarily stringent time requirement when investigating near-miss incidents [required in paragraph (m)(1)]. Frequently, such near-miss accidents are not recognized for their potential impact until more than 48 hours following the event. It is recommended that paragraph (m)(2) be changed to read:
"Incident investigations for catastrophic releases in the workplace shall be initiated as promptly as possible, but no later than 48 hours following the incident." This wording eliminates the 48 hour requirement for incidents which could have but did not result in a major accident, i.e., near misses.
Also, a commenter from IMCERA (Ex. 3:158, p. 6-7) stated:
Should a potentially serious incident occur the employer would immediately conduct an investigation to determine cause and corrective action. This is just good safety and business practices. Rather than establish time frames i.e., 48 hours, IMCERA would prefer to see this section be reworded as follows:
Incident investigations shall be initiated as promptly as possible and completed in a timely manner.
As discussed previously, OSHA believes that it is necessary to initiate investigations as soon as possible after the incident and sees no reasonable basis for relating the time period to initiate the investigation to whether the incident was a fatality or a near miss. Although the Agency understands the concerns of these rulemaking participants, the Agency believes that the provision allows enough flexibility to the employer by requiring an incident investigation be initiated as soon as possible but not later than 48 hours following the incident. OSHA believes that 48 hours is a reasonable timeframe within which to initiate an investigation. Accordingly, proposed paragraph (m)(2) is contained in the final rule as proposed. It should also be noted that the investigation need only be initiated within this timeframe, not completed, although it is contemplated that there will not be unnecessary delay between initiation and completion of the incident investigation.
Paragraph (m)(3) of the proposal required an incident investigation team to be established and to consist of persons knowledgeable in the process involved and other appropriate specialties, as necessary.
While some rulemaking participants (e.g., Ex. 114; Tr. 2257) recommends that OSHA mandate that an employee representative be on the investigation team, most rulemaking participants (e.g., Ex. 3: 57, 108, 161; Ex. 101; Tr. 316, 678, 742, 1813) supported the performance-oriented approach of this proposed provision. These rulemaking participants asserted that the employer should be responsible for determining the composition of the team, and that the determination should be based on the ability of the team members to perform the investigation properly. Additionally, they stated that an employee representative may very well be selected to participate in the investigation; but, this should not be mandated by OSHA. OSHA is not requiring an employee representative on the process hazard analysis team or on
the incident investigation team. This issue has already been addressed in the discussion concerning final paragraph (c), employee participation.
The intent of OSHA is to assure that team members have the ability to properly perform the investigation promptly and that the employer have the flexibility to select team members (in consultation with employees and their representatives as described in paragraph (c)) that possess this ability. The Agency believes that this proposed paragraph adequately reflects this intent.
Additionally, the Agency believes that in cases where an incident involved a contract employer's work, then a contract employee should be involved in the investigation. Therefore, proposed paragraph (m)(3) has been revised to read as follows:
An incident investigation team shall be established and consist of at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident.
Proposed paragraph (m)(4) required a report to be prepared at the conclusion of the investigation which included, at a minimum, the date of the incident; date that the investigation began; a description of the incident; the factors that contributed to the incident; and, any recommendations resulting from the investigation.
A very small number of rule making participants (e.g., Ex. 3: 58, 64) contended that there was no benefit in specifying the date the investigation began. OSHA disagrees. The Agency wants to make sure that the investigation is initiated promptly. Consequently, it is important that the date of the incident, as well as the date that the investigation was initiated, are both specified.
OSHA did not receive any other negative comments with respect to the contents of the report specified by this proposed provision. Accordingly, proposed paragraph (m)(4) is included in the final rule as proposed.
Proposed paragraph (m)(5) required that the report be reviewed with all operating, maintenance, and other personnel whose work assignments are within the facility where the incident occurred. The purpose of this proposed provision is to assure that the report findings are disseminated to appropriate personnel, because the information contained in the report might be important in preventing similar incidents.
There was wide support for requiring dissemination of the information contained in the report to appropriate personnel. However, several rulemaking participants (e.g., Ex. 3: 57, 112, 121, 161) suggested changes to this proposed provision to better identify to whom this information should be disseminated. For example, a commenter for Kodak (Ex. 3: 33, p. 14) remarked:
OSHA should understand that there are large facilities, some number in the thousands of employees, where employees of various disciplines have no need to interact with one another. Most employees at these large facilities have no work relationship to other process activities outside their own work area and consequently have no need to be informed of information regarding a process or investigation they have no commitment to or responsibility for. We therefore, recommend the following statement for (m)(5):
"The report shall be reviewed with all appropriate personnel."
A commenter from CIBA–GEIGY (Ex. 3: 56, p. 2–3) said:
CIBA-GEIGY agrees that an incident which occurs in an operator's work area should be reviewed with all affected operators. However, this provision as specified by OSHA defines those operators which are affected, and this definition will not always be correct.
CIBA-GEIGY, therefore, recommends that the language be amended to read that the accident will be reviewed with those personnel who are directly involved with the operations in which the accident occurred.
Another commenter, who was from the ARCO Chemical Company (Ex. 3: 71, p. 31) asked OSHA to consider the following language:
The report shall be reviewed with all affected operating personnel who have a need to know and/or whose job tasks are relevant to the incident findings.
Additionally, a commenter from Vulcan Chemicals (Ex. 3: 101A, p. 5) stated:
Vulcan Chemicals recommends that this wording be changed to read:
The report shall be reviewed with all affected personnel whose job tasks are relevant to the incident findings.
After careful review of these comments, OSHA has decided to revise this proposed provision to more accurately identify to whom this information should be disseminated. Additionally, the Agency believes that the logical progression of an incident investigation is to address the report recommendations (discussed in proposed paragraph (m)(6)) before disseminating the information contained in the report to affected personnel.
Accordingly, proposed paragraph (m)(5) has been redesignated as paragraph (m)(6) in the final rule, and has been revised to read as follows:
The report shall be reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees when applicable.
Proposed paragraph (m)(6) required the employer to establish a system to promptly address the report findings and recommendations and to implement the report recommendations in a timely manner.
Many rulemaking participants (e.g., Ex. 3: 17, 26, 30, 33, 38, 45, 53, 59, 60, 81, 113; Ex. 128; Tr. 1124, 1811, 1938) disagreed that all of the report recommendations need to be implemented. It was contended that upon further evaluation, some recommendations may be inappropriate. These rulemaking participants suggested that the term "implemented" be replaced with such terms as "resolved", "addressed", or "respond." It was further suggested that resolution of the recommendations and findings be documented.
The Agency agrees that there may be situations where it is not necessary or appropriate to implement all of the report recommendations. It is the Agency's position, however, that it is necessary to document the resolution of the report findings and recommendations to assure that they have been adequately considered.
Accordingly, proposed paragraph (m)(6) has been redesignated as paragraph (m)(5) in the final rule, and has been revised to read as follows:
The employer shall establish a system to promptly address and resolve the report findings and recommendations. Resolutions and corrective actions shall be documented.
Paragraph (m)(7) of the proposal required incident investigation reports to be retained for five years in order to determine if an incident pattern develops or exists. A few rulemaking participants (e.g., Ex. 3: 97, 121) suggested that the investigation reports be retained for three years rather than five years. OSHA did consider a three-year retention period. However, the Agency believes it would be extremely useful if the report findings and recommendations were reviewed during the subsequent update or revalidation of the process hazard analysis. Consequently, the Agency believes it more appropriate to specify a five-year retention period to be consistent with paragraph (e) of the final rule, which requires the process hazard analysis to be updated or revalidated every five years. Therefore, proposed paragraph
(m)(7) is included in the final rule as proposed.
Emergency Planning and Response: Paragraph (n)
Proposed paragraph (n) required the employer to establish and implement an emergency action plan in accordance with the provisions contained in 29 CFR 1910.38(a). For information purposes the Agency also added a note that 29 CFR 1910.120 (a), (p) and (q) may also be applicable.
The Agency received little negative comment with respect to this proposed provision except with respect to the issue of drills discussed below. OSHA believes that the implementation of an emergency action plan is extremely important for plant sites which have processes covered by this standard because of the potential hazards posed by highly hazardous chemicals and the elements of the emergency action plan which must be implemented to preplan for emergencies involving these substances (including training) so that employees will be aware of, and execute, appropriate actions.
The emergency action plan requires, at a minimum, the implementation of, and training employees in, the following procedures:
- Emergency escape procedures and emergency escape route assignments;
- Procedures to be followed by employees who remain to operate critical plant operations before they evacuate;
- Procedures to account for all employees after emergency evacuation has been completed;
- Rescue and medical duties for those employees who are to perform them;
- Preferred means of reporting fires and other emergencies; and
- Names or regular job titles of persons or departments who can be contacted for further information or explanation of duties under the plan.
The emergency action plan also requires the establishment of a system to alert employees of an emergency. If the alarm system is to be used for alerting fire brigade members, or for some other purpose, a distinctive signal must be used for each purpose.
With respect to training, employers must review the emergency action plan with each employee initially when the plan is developed, whenever the employee's responsibilities or designated actions under the emergency action plan changes, and whenever the emergency action plan, itself, is changed.
OSHA believes that the preplanning and training required by the emergency action plan will assure the readiness of employees to respond appropriately and safely to emergencies involving highly hazardous chemicals.
Additionally, as a part of emergency planning, OSHA is adding a provision that employers develop procedures to address small releases and spills, since it is not always obvious when such an event is, or is not, an emergency situation; and such an event may also warrant initiating an incident investigation.
The proposed paragraph concerning emergency planning and response was also the subject of one of the issues in the proposal (55 FR at 29159). The Agency asked whether or not drills or simulated exercises should be mandated by this proposed provision. Many participants addressed this issue and while the value of drills was expressed throughout this rulemaking record, most rulemaking participants who addressed this issue believed that drills should be recommended but not mandated (Ex. 3: 17, 26, 28, 29, 53, 59, 89, 80, 81, 109, 124, 156, 161).
The Agency has concluded that drills are certainly recommended, but OSHA believes that the employer is in the best position to assess the readiness of employees to respond correctly, to establish procedures for emergency action, including conducting drills or exercises when necessary. Additionally, OSHA believes that the subject of drills will be adequately addressed by the elements contained in the emergency action plan and applicable provisions of § 1910.120.
Paragraph (n) is included in the final rule as proposed except for the addition of a provision that requires establishment of procedures for handling small releases. Additionally, the note which made reference to the possible applicability of provisions contained in § 1910.120 has been added to the text of the provision.
Compliance Safety Audits: Paragraph (o).
This proposed paragraph contained provisions pertaining to an evaluation of an employer's process safety management system. OSHA believes that an audit with respect to compliance with the provisions contained in this section is an extremely important function. This is because it serves as a self-evaluation for employers to measure the effectiveness of their process safety management system. The audit can identify problem areas, and assist employers in directing attention to process safety management weaknesses.
Therefore, proposed paragraph (o)(1) required employers to certify that they have evaluated compliance with the provisions of this section, at least every three years.
The concept of employers evaluating the effectiveness of their own process safety management system was endorsed, and widely supported, throughout this rulemaking process. However, there was some disagreement with the approach taken by OSHA in this proposed provision. Some rulemaking participants (e.g., Ex. 3: 71, 121) contended that paragraph (o) should focus more on evaluating the effectiveness of the process safety management system, rather than determining compliance with provisions contained in the standard. For example, a commenter from Kodak (Ex. 3: 33, p.2) remarked:
We are also concerned about the proposed Compliance Audit, which we suggest be retitled "Management Systems Audit." We agree that a periodic assessment is necessary, but it should be a review of the employer's entire process safety program, including elements that satisfy OSHA's requirements. It should not focus solely on the OSHA standard and must not be used for "compliance" purposes.
A commenter from Monsanto (Ex. 3: 64, p.11) stated:
Monsanto recommends that the title of this section be changed to "Management System Review". The focus should be an employer's review of its own process safety system, including compliance with this standard, not an employer's review of its compliance with this standard.
Other rulemaking participants (e.g., Ex. 3: 38, 119; Tr. 1014) suggested that the title of paragraph (o) be changed to "compliance audit" because it is more descriptive of the intent of this section. For example, a commenter from BP America (Ex. 3: 59, p.7) remarked:
BP America believes that paragraph (o) should be called "Compliance Audits" instead of "Compliance Safety Audits" to clarify the intent. The intent is to audit the Process Safety Management Program and is, therefore, an administrative audit, not a technical safety audit.
A commenter from IMCERA (Ex. 3: 158, p.7) stated:
OSHA should consider changing the title of Subpart (o) from "Compliance Safety Audit" to "Compliance Audit". The term "Compliance Audit" more accurately describes the intent of this section, which is designed to determine compliance with the provisions of the proposed rule.
The objective of proposed paragraph (o) is to assure that employers evaluate the effectiveness of their process safety management system as required by the standard. The Agency believes that an effective means of achieving this objective is by employers assuring that
the provisions contained in this standard are being met and in doing so, the employer will ascertain whether the procedures and practices required to be developed under the process safety management standard as adequate and being followed. Since this proposed paragraph contains provisions that focus on the means of achieving this objective, the Agency has decided to change the title of paragraph (o) of the final rule to "compliance audits" and to add wording to further clarify the intent of this provision.
Another concern expressed with respect to proposed paragraph (o)(1) was the requirement that audits be performed at least every three years. Some commenters (e.g., Ex. 3: 64, 70, 82; Ex. 143) asserted that every three years was too often and recommended a five year interval as an alternative.
OSHA disagrees. A five year interval between audits is too long. The Agency believes that it is necessary that audits be performed at least every three years in order to measure the effectiveness of the process safety management system. Accordingly, proposed paragraph (o)(1) has been retained in the final rule as proposed except for some additional clarifying language.
Proposed paragraph (o)(2) required that a team, comprised of at least one person knowledgeable in the process conduct the compliance audit. A few rulemaking participants (e.g., Ex. 3: 64, 71) remarked that it may not be necessary that the audit be performed by a "team." OSHA concurs. The Agency believes that it is important for the audit to be performed by at least one person knowledgeable in the process, but it is not necessary that it be performed by a team. Therefore, proposed paragraph (o)(2) has been revised in the final rule to read as follows:
The compliance audit shall be conducted by at least one person knowledgeable in the process.
Proposed paragraph (o)(3) required a report of the findings of the audit to be developed. There were no objections to the requirement that a report of the audit findings be developed. Therefore, proposed paragraph (o)(3) is contained in the final rule as proposed.
Proposed paragraph (o)(4) required the employer to promptly determine and document an appropriate response to each of the findings of the compliance audit, and certify that deficiencies have been corrected.
Some rulemaking participants (e.g., Ex. 38, 48, 64, 71, 158; Ex. 143) disagreed with the term "certify" and suggested that other terms such as "document," "respond to," or "resolve" would be more descriptive of OSHA's intent.
The purpose of this proposed paragraph is to assure that employers determine an appropriate response to each of the report findings and if employers identify a deficiency that needs to be corrected, that they "document" the correction of the deficiency. Therefore, proposed paragraph (o)(4) is contained in the final rule as proposed except that the word "certify" has been replaced by the word "document."
Proposed paragraph (o)(5) required employers to retain the two most recent compliance audit reports, as well as the documented actions described in paragraph (o)(4) of this section. The purpose of this proposed provision is to focus on any continuing areas of concern that are identified through the compliance audits.
There were no objections to this proposed provision and it is contained in the final rule as proposed, except for minor editorial changes which were made to reflect the change in title of paragraph (o).
Trade Secrets: Paragraph (p)
A number of participants in the rulemaking expressed some concern that in the proposal OSHA did not appear to provide any trade secret protection (e.g., Ex. 3: 46, 48, 80, 89, 106A, 129; Ex. 53). One commenter suggested that OSHA might itself reveal trade secrets in that "items which include trade secret information collected by OSHA as a result of an inspection could be made public" (Ex. 128, p. 18). Others worried about the possibility that information could substantially affect the competitive position of an employer (Ex. 3: 71) and asked for some protection against unwarranted disclosure of such information (Ex. 3: 89).
As to concern that OSHA might itself reveal trade secret information, it should be noted that employers are amply protected under the U.S. Code, the Occupational Safety and Health Act and regulations promulgated under the Act. Federal law makes it a criminal offense for federal employees to disclose trade secret information that is not authorized by law (18 U.S.C. 1905). Section 15 of the Occupational Safety and Health Act (the Act) requires that all information reported to or obtained by a Compliance Safety and Health Officer (CSHO) in connection with any inspection or other activity which contains or which might reveal a trade secret be kept confidential. Such information shall not be disclosed except to other OSHA officials concerned with the enforcement of the Act or, when relevant, in any proceeding under the Act. Other OSHA regulations further assure the protection of trade secrets (29 CFR 1903.7(b) and 1903.9). And the OSHA Field Operations Manual further emphasizes this point by stating "it is essential to the effective enforcement of the Act that the CSHO and all OSHA personnel preserve the confidentiality of all information and investigations which might reveal a trade secret" (III–58). Moreover, trade secret information is specifically excluded from disclosure under the Freedom of Information Act (5 U.S.C. 552(b)(4)).
As a general matter, OSHA believes that there are relatively few bona fide trade secrets among the information that is required to be gathered under this standard. However, the addition of provisions to protect trade secrets will give employers with legitimate trade secret concerns adequate protection, but require that they withhold information only on the basis of sound, legal justification.
Some commenters (e.g., Ex. 3: 76, 112) suggested that OSHA adopt the definition of "trade secret" used in the Hazard Communication standard; others, such as ARCO, suggested a more expansive (e.g., Ex. 3: 71, 106A) or more limited (e.g., Ex. 147) definition. OSHA has reviewed the definition of "trade secret" that is used in the Hazard Communication standard (29 CFR 1910.1200) and has decided to incorporate that definition of trade secret into the final standard. The Agency believes that this definition of trade secret is broad enough to offer adequate protection to employers with legitimate trade secrets, it is consistent with that used in the Restatement of Torts, and it has the additional advantage of being uniform with that used in the Hazard Communication standard so that many employers are already familiar with it. The final rule also incorporates Appendix D of the Hazard Communication standard which contains criteria to be used in determining whether material meets the definition of trade secret.
Some commenters (e.g., Ex. 3: 46, 80, 112) believed that trade secret information should be handled in the process safety management standard under the procedures set forth in the Hazard Communication standard. The United Steelworkers of America submitted for consideration a new draft section for trade secrets (Ex. 147, p.16–17). After reviewing these approaches and several others (see, for example, Ex. 3: 53), the Agency has decided that the best way of resolving the issue is to
adopt language that will clearly indicate the accessibility and the procedures for obtaining trade secret information under the final rule. Arguably the trade secret provisions (§ 1910.1200(i)) of the Hazard Communication standard alone would take care of access to all trade secret information pertinent to the process safety management rule; however some may feel that their application might be limited to chemical identity information. In order to clarify its intent, OSHA has specifically stated in the final rule that the employer must make all relevant information available to those individuals involved in carrying out various information using and compiling activities required by the final rule regardless of whether the information in question is considered a trade secret or not. This is vital to the effective operation of the process safety management rule. It is questionable as to how useful a compliance safety audit or a process hazard analysis could be if some of the information necessary to their completion were denied or delayed. The language is written in this way to emphasize the right to access this information. However, the employer may take reasonable steps, such as those described in the Hazard Communication standard, to protect against the unauthorized disclosure of trade secrets to unauthorized third persons. Such steps include the signing of a confidentiality agreement.
OSHA believes that employees and their representatives also may have the need to access such information. The final rule assures employees access to the process hazard analysis and other information required to be developed under the standard. Under certain circumstances, however, it might be appropriate to substitute more general information or to require some sort of a balancing of the need to know the information with the need to protect the employer. Therefore, the Agency is incorporating into the final rule the access procedures that were developed under the Hazard Communication standard with the exception of § 1910.1200(i)(13). Section 1910.1200(i)(13) provides "[n]othing in this paragraph shall be construed as requiring the disclosure under any circumstances of process or percentage of mixture information which is a trade secret." That section is not being incorporated into the process safety management trade secret provisions in recognition of the fact that employees are entitled to certain process information under the process safety management standard and this process information may at times contain trade secret information. There is no reason why the Hazard Communication information access provisions will not work well for information contained in the process hazard analysis and other documents that contain trade secrets. Employers bear the burden of demonstrating that their trade secret claim is bona fide. The Agency will evaluate the appropriateness of that substantiation in the event that an employer denies a legitimate request for disclosure of the trade secret and a complaint is subsequently made to OSHA.
IV. Statutory Considerations
Introduction
Section 3(8) of the Act provides:
The term "occupational safety and health standard" means a standard which requires conditions, or the adoption or use of one or more practices, means, methods, operations, or processes, reasonably necessary or appropriate to provide safe or healthful employment and places of employment.
29 U.S.C. 652(8).
In two recent cases, reviewing courts expressed concern that OSHA's interpretation of this and other provisions of the Act pertaining to safety rulemaking could lead to overly costly or under-protective safety standards. In *International Union, UAW v. OSHA*, 938 F.2d 1310 (D.C. Cir. 1991), the District of Columbia Circuit rejected substantive challenges to the lockout/tagout standard and denied a request that enforcement of that standard be stayed, but it also expressed concern that OSHA's interpretation of the Act could lead to safety standards that are very costly and only minimally protective. In *National Grain & Feed Ass'n v. OSHA*, 866 F.2d 717 (5th Cir. 1989), the Fifth Circuit concluded that Congress gave OSHA considerable discretion in structuring the costs and benefits of safety standards, but, concerned that the grain dust standard might be under-protective, directed OSHA to consider adding a provision that might further reduce significant risk of fire and explosion.
It is, of course, beyond doubt that OSHA rulemakings involve a significant degree of agency expertise and policymaking discretion to which reviewing courts must defer. See e.g., *Building & Constr. Trades Dep't, AFL-CIO v. Brock*, 838 F.2d 1258, 1266 (D.C. Cir. 1988); *Industrial Union Dep't, AFL-CIO v. American Petroleum Inst.*, 448 U.S. 607, 655 n. 62 (1980). At the same time, the agency's technical expertise and policymaking authority must be exercised within parameters. The lockout/tagout and grain handling standard decisions sought from OSHA more clarification on the question of parameters. In light of those decisions, OSHA believes it would be useful to state its view of the limits of its safety rulemaking authority and to explain why the agency is confident that its interpretive views have in the past and will continue in the future to avoid regulatory extremes.
Stated briefly, the OSH Act requires that before promulgating any occupational safety standard, OSHA demonstrate based on substantial evidence in the record as a whole that: (1) The proposed standard will substantially reduce a significant risk of material harm; (2) compliance is technologically feasible in the sense that the protective measures being required already exist, can be brought into existence with available technology, or can be created with technology that can reasonably be developed; (3) compliance is economically feasible in the sense that industry can absorb or pass on the costs without major dislocation or threat of instability; and (4) the standard employs the least expensive protective measures capable of reducing or eliminating significant risk. In addition, proposed safety standards must be compatible with prior agency action, be responsive to significant comment in the record, and to the extent allowed by statute, be consistent with applicable Executive Orders. These elements set the parameters for safety rulemaking and a decision-making framework for developing a rule within the parameters.
A. Congress Concluded That OSHA Regulations are Necessary To Protect Workers From Occupational Hazards and That Employers Should Be Required To Reduce or Eliminate Significant Workplace Health and Safety Threats
At section 2(a) of the Act, Congress announced its determination that occupational injury and illness should be eliminated as much as possible. "The Congress finds that occupational injury and illness arising out of work situations impose a substantial burden upon, and are a hindrance to, interstate commerce in terms of lost production, wage loss, medical expenses, and disability compensation payments." 29 U.S.C. 651(a). Congress therefore declared "it to be its purpose and policy * * * to assure so far as possible every working man and woman in the Nation safe * * * working conditions" * * *. 29 U.S.C. 651(b).
To that end, Congress instructed the Secretary of Labor to adopt existing federal and consensus standards during the first two years after the Act became
effective and, in the event of conflict among any such standards, to "promulgate the standard which assures the greatest protection of the safety or health of the affected employees." 29 U.S.C. 655(a). Congress also directed the Secretary to set mandatory occupational safety standards, 29 U.S.C. 651(b)(3), based on a rulemaking record and substantial evidence, 29 U.S.C. 655(b)(2), that are "reasonably necessary or appropriate to provide safe * * * employment and place of employment." When promulgating permanent safety or health standards that differ from existing national consensus standards, the Secretary must explain "why the rule as adopted will better effectuate the purposes of this Act than the national consensus standard." 29 U.S.C. 655(b)(8). Correspondingly, every employer must comply with OSHA standards and, in addition, "furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees." 29 U.S.C. 654(a).
"Congress understood that the Act would create substantial costs for employers, yet intended to impose such costs when necessary to create a safe and healthful working environment. Congress viewed the costs of health and safety as a cost of doing business. * * * Indeed, Congress thought that the financial costs of health and safety problems in the workplace were as large as or larger than the financial costs of eliminating these problems." American Textile Mfrs. Inst. Inc. v. Donovan, 452 U.S. 490, 519–522 (1981) ("ATMI") (emphasis in original). "[T]he fundamental objective of the Act [is] to prevent occupational deaths and serious injuries." Whirlpool Corp. v. Marshall, 445 U.S. 1, 11 (1980). "We know the costs would be put into consumer goods but that is the price we should pay for the 80 million workers in America." S. Rep. No. 91–1282, 91st Cong., 2d Sess. (1970); H.R. Rep. No. 91–1291, 91st Cong., 2d Sess. (1970), reprinted in Senate Committee on Labor and Public Welfare, Legislative History of the Occupational Safety and Health Act of 1970, [Committee Print 1971] ("Leg. Hist.") at 444 (Senator Yarbrough). "Of course, it will cost a little more per item to produce a washing machine. Those of us who use washing machines will pay for the increased cost, but it is worth it, to stop the terrible death and injury rate in this country." Id. at 324; see also 510–511, 517.
[The vitality of the Nation's economy will be enhanced by the greater productivity realized through saved lives and useful years of labor.
When one man is injured or disabled by an industrial accident or disease, it is he and his family who suffer the most immediate and personal loss. However, that tragic loss also affects each of us. As a result of occupational accidents and disease, over $1.5 billion in wages is lost each year [1970 dollars], and the annual loss to the gross national product is estimated to be over $8 billion. Vast resources that could be available for productive use are siphoned off to pay workmen's compensation and medical expenses." * * *
Only through a comprehensive approach can we hope to effect a significant reduction in these job death and casualty figures.
Id. at 518–19 (Senator Cranston).
Congress considered uniform enforcement crucial because it would reduce or eliminate the disadvantage that a conscientious employer might experience where inter-industry or intra-industry competition is present. Moreover, "many employers—particularly smaller ones—simply cannot make the necessary investment in health and safety, and survive competitively, unless all are compelled to do so." Leg. Hist. at 144, 854, 1188, 1201.
Thus, the statutory text and legislative history make clear that Congress conclusively determined that OSHA regulations are necessary to protect workers from occupational hazards and that employers should be required to reduce or eliminate significant workplace health and safety threats.
B. As Construed by the Courts and by OSHA, the Act Sets a Threshold and a Ceiling for Safety Rulemaking That Provide Clear and Reasonable Parameters for Agency Action
OSHA has long followed the teaching that section 3(8) of the Act requires that before it promulgates "any permanent health or safety standard, [it must] make a threshold finding that a place of employment is unsafe—in the sense that significant risks are present and can be eliminated or lessened by a change in practices." Industrial Union Dep't, AFL-CIO v. American Petroleum Inst., 448 U.S. 607, 642 (1980) (plurality) ("Benzene") (emphasis in original). When, as frequently happens in safety rulemaking, OSHA promulgates standards that differ from existing national consensus standards, it must explain "why the rule as adopted will better effectuate the purposes of this Act than the national consensus standard." 29 U.S.C. 655(b)(8). [National consensus and existing federal standards that Congress instructed OSHA to adopt summarily within two years of the Act's inception provide reference points concerning the least an OSHA standard should achieve. 29 U.S.C. 655(a).]
As a result, OSHA is precluded from regulating insignificant safety risks or from issuing safety standards that do not at least lessen risk in a significant way. OSHA must also respond rationally to similarities and differences among industries or industry sectors. See Building and Constr. Trades Dep't, AFL-CIO v. Brock, 838 F.2d 1258, 1272–73 (D.C. Cir. 1988).
OSHA has also long accepted that "any standard that was not economically or technologically feasible would a fortiori not be 'reasonably necessary or appropriate' under the Act. See Industrial Union Dep't v. Hodgson, [499 F.2d 467, 478 (D.C. Cir. 1974)] ('Congress does not appear to have intended to protect employees by putting their employers out of business.')." American Textile Mfrs. Inst. Inc., 452 U.S. at 513 n. 31; American Iron and Steel Inst. v. OSHA, 939 F.2d 975, 980 (D.C. Cir. 1991) (a standard is economically feasible even if it portends "disaster for some marginal firms," but it is economically infeasible if it "threaten[s] massive dislocation to, or imperil[s] the existence of," the industry).
By stating the test in terms of "threat" and "peril," the Supreme Court made clear in ATMI that infeasibility begins short of industry-wide bankruptcy. OSHA itself has placed the line considerably below industry-wide bankruptcy. See, for example, ATMI, 452 U.S. at 527 n. 50; 43 FR 27360 (June 23, 1978) [proposed 200 μg/m³ PEL for cotton dust did not raise serious possibility of industry-wide bankruptcy, but impact on weaving sector would be severe, possibly requiring reconstruction of 90 percent of all weave rooms. OSHA concluded that the 200 μg/m³ level was not feasible for weaving and that 750 μg/m³ was all that could reasonably be required]. See also 54 FR 29245–246 (July 11, 1989); American Iron & Steel Institute, 939 F.2d at 1003 (OSHA raised engineering control level for lead in small nonferrous foundries to avoid the possibility of bankruptcy for about half of small foundries even though the industry as a whole could have survived the loss of small firms).
OSHA standards must also be cost-effective in the sense that the protective measures being required must be the least expensive measures capable of achieving the desired end. ATMI, at 514 n. 32; Building and Constr. Trades Dep't AFL-CIO v. Brock, 838 F.2d 1258, 1269 (D.C. Cir. 1988). (Although the cotton dust and lead rulemakings involved health standards, the economic
feasibility ceiling established therein applies equally to safety standards. The feasibility boundary is the same for health and safety rulemaking since it comes from section 3(8), which governs all permanent OSHA standards.)
OSHA gives additional consideration to financial impact in setting the period of time that should be allowed for compliance, allowing as much as ten years for compliance phase-in. See United Steelworkers of Am. v. Marshall, 647 F.2d 1169, 1278 (D.C. Cir. 1980), cert. denied, 453 U.S. 913 (1981). In addition, OSHA's enforcement policy takes account of financial hardship on an individualized basis. OSHA's Field Operations Manual provides that, based on an employer's economic situation, OSHA may extend the period within which a violation must be corrected after issuance of a citation. CPL 2.45B, Chapter 3 Ed6(3)(a) (Dec. 31, 1990).
To reach the necessary findings and conclusions, OSHA must conduct rulemaking to determine, based on substantial evidence, the qualitative and, if possible, quantitative nature of the risk with and without regulation, technological feasibility of compliance, availability of capital to the industry, the extent to which capital was required for other purposes, the industry's profit history, the industry's ability to absorb costs or pass them on to the consumer, the impact of higher costs on demand, and the impact on competition with substitutes and imports. See ATMI at 2501–2503; American Iron & Steel Institute generally.
OSHA's powers are further circumscribed by the independent Occupational Safety and Health Review Commission, which provides a neutral forum for employer contests of citations issued by OSHA for noncompliance with health and safety standards. 29 U.S.C. 659–661 (noted as an additional constraint in Benzene at 652 n. 59).
OSHA rulemaking is thus constrained first by the need to demonstrate that the standard will substantially reduce a significant risk of material harm, and then by the requirement that compliance is technologically capable of being done and not so expensive as to threaten economic instability or dislocation for the industry. Within these parameters, further constraints such as the need to find cost-effective measures and to respond rationally to all meaningful comment militate against regulatory extremes. Finally, it is axiomatic that significant departures from prior practice must be justified. International Union, UAW v. Pendergrass, 878 F.2d 389, 400 (D.C. 1989). In the twenty years since enactment, OSHA has promulgated numerous safety standards, standards that provide benchmarks for judging risks, benefits, and feasibility of compliance in subsequent rulemakings. (OSHA's Hazardous Waste Operations and Emergency Response Standard, for example, required use of existing technology and well accepted safety practices to eliminate at least 32 deaths and 18,700 lost workday injuries at a cost of about $153 million per year. 54 FR 9311–9312 (March 6, 1989). The excavation standard also drew on existing technology and recognized safety practices to save 74 lives and over 800 lost workday injuries annually at a cost of about $306 million. 54 FR 45954 (Oct. 31, 1989). OSHA's Grain Handling Facilities standard relied primarily on simple housekeeping measures to save 16 lives and 394 injuries annually, at a total net cost of $5.9 to $33.4 million. 52 FR 49622 (Dec. 31, 1991).)
C. The PSM Standard Meets the Statutory Criteria
In promulgating the Clean Air Act Amendments of 1990, Congress conclusively determined that "a process safety standard designed to protect employees from hazards associated with accidental releases of highly hazardous chemicals in the workplace" is necessary and that the standard must, at a minimum, require employers to adopt fourteen specified planning, procedure and training safety measures. Public Law 101–549 (Nov. 15, 1990), reprinted at 29 U.S.C.A. 655 note (Supp. 1991). For the reasons explained in detail throughout this statement of findings and conclusions, the standard's fourteen planning, procedure and training requirements, when fully implemented, reduce the risk of catastrophic fire and explosion (330 fatalities and 1,917 injuries/illnesses annually) by 80 percent. This constitutes a substantial reduction of significant risk of material harm. Compliance is technologically feasible because the standard's requirements are already being implemented to some extent. Compliance is economically feasible because all regulated sectors can readily absorb or pass on compliance costs during the standard's first five years, and economic benefits will exceed compliance costs thereafter. The standard's costs, benefits, and compliance requirements are consistent with the Clean Air Act Amendments, as well as with other OSHA safety standards. OSHA considered and responded to all substantive comments on their merits; OSHA evaluated all suggestions for their impact on worker safety, their feasibility, their cost effectiveness, and their consonance with the OSH Act and the Clean Air Act Amendments.
V. Summary of Regulatory Impact and Regulatory Flexibility Analysis, International Trade Impact Analysis, and Environmental Impact Assessment
Introduction
OSHA has created a new standard within Subpart H, Hazardous Materials, to deal with the risks involved in the storage, handling and processing of highly hazardous materials. The standard—referred to as process safety management, or PSM—emphasizes the application of management controls, rather than specific engineering guidelines, when addressing the risks associated with handling or working near hazardous chemicals. Implementation of process safety management programs and procedures will enable affected establishments to prevent the occurrence, and minimize the consequences, of significant releases of toxic substances, as well as fires, explosions and other types of catastrophic accidents.
The benefits of implementing PSM include the prevention of accidental fatalities, injuries and illnesses, and the avoidance of physical property damage. Furthermore, the standard will contribute to enhanced productivity due to fewer process disruptions and accidental shutdowns and decreased labor turnover as workers perceive a safer work environment; lead to more efficient utilization of space, labor and equipment in the wake of programmatic plant reviews; promote an integrated approach to process design, construction, operation, and maintenance, with process safety as the central focus of concern; reduce loss of raw materials and inadvertent waste generation; and increase product quality. Savings in these areas are expected to offset direct costs of compliance. OSHA also anticipates significant improvements in ergonomic and other chronic health and safety problems—including low-level exposure to toxic substances—through compliance with the PSM standard.
In response to recent catastrophic accidents in the petrochemical industry, OSHA in 1990 initiated the Special Emphasis Program in Petrochemical Industries (PETROSEP), whose purpose is to determine whether management systems governing safety and health procedures for maintenance activities, contractor activities, and operations are in place to control risk. The largest firms in SIC 2821, Plastic Materials and Resins, SIC 2869, Industrial Organic...
Chemicals, Not Elsewhere Classified, and SIC 2911, Petroleum Refining, are the subject of the program. The PETROSEP program focuses the attention of plant managers and contractors on the need to integrate the PSM philosophy into the safety culture of the worksite.
Executive Order 12291 (46 FR 13197) requires that a regulatory impact analysis be prepared for any proposed regulation that meets the criteria for a "major rule"; that is, one that would result in an annual impact on the economy of $100 million or more, have a major increase in cost or prices for consumers, individual industries, federal, state or local government agencies, or geographic regions, or have significant adverse effects on competition, employment, investment, productivity, innovation, or the ability of United States-based enterprises to compete with foreign-based enterprises in domestic or export markets. In addition, the Regulatory Flexibility Act (5 U.S.C. 601, et seq.) requires analysis of whether a regulation will have a significant economic impact on a substantial number of small entities.
Consistent with these requirements, OSHA has prepared this Regulatory Impact and Regulatory Flexibility Analysis for § 1910.119, Process Safety Management of Highly Hazardous Chemicals. The Regulatory Impact Analysis is a critical part of OSHA reasoning both on issues arising under the OSH Act and under the Executive Order. OSHA has explicitly relied on the RIA to support this final Process Safety Management rule. As a result of this analysis OSHA has determined that promulgation of § 1910.119 will constitute a major rule.
Affected Industries and Current Compliance
Based on a report prepared by Kearney/Centaur [Ex. 5] and a follow-up review of national chemical databases, OSHA has determined that 24,939 establishments in 127 industry subgroups will be affected by the PSM standard. The population at risk is an estimated 3.0 million workers (2.37 million plant employees and 653,000 contract employees) and is found throughout manufacturing, particularly in Standard Industrial Classification (SIC) code 28, Chemicals and Allied Products, SIC 37, Transportation Equipment, and SIC 34, Fabricated Metal Products, Except Machinery and Transportation Equipment. In addition to manufacturing, natural gas liquids (SIC 1321), farm product warehousing (SIC 4221), electric, gas, and sanitary services (SIC 49) and wholesale trade (SICs 50 and 51) contain workers at risk. The extent of the impact will vary by industry depending on current practice, the number of processes, and the quantities of highly hazardous materials on site.
OSHA excluded from this final impact analysis establishments in California, Delaware and New Jersey, where process safety management statutes have already been enacted. In these three states the compliance burden is unaffected by the federal rule.
OSHA estimated current practices with the provisions of the process safety management rule using OSHA survey data, survey data compiled by a major chemical engineering magazine, and data in the rulemaking record. For all industries affected by the proposed rule, none are currently in full compliance, although compliance is greater than 75 percent among some establishments for some specific provisions. Generally, larger firms have a higher current compliance rate than smaller firms, but for many industries the compliance-rate differences by establishment size are not substantial.
Nonregulatory Environment
The primary objective of OSHA's process safety management standard is to reduce the number of employee fatalities and injuries associated with catastrophic releases of hazardous substances. OSHA believes that the PSM standard will eliminate to a considerable degree the risks which workers experience in the establishments falling within the scope of the rule.
The Agency examined the nonregulatory approaches for promoting the implementation of safety management programs, including (1) economic forces generated by the private market system, (2) incentives created by workers' compensation programs or the threat of private suits, and (3) related activities of private agencies. Following this review, OSHA determined that the need for government regulation arises from the significant risk of job-related injury or death caused by inadequate practices for preventing catastrophic accidents which currently exist in the industry. Private markets fail to provide enough safety and health resources due to the lack of information on risk, immobility of labor, and externalization of part of the social costs of worker injuries and deaths. Workers' compensation systems do not offer an adequate remedy because premiums do not reflect specific workplace risk and liability claims are restricted by statutes preventing employees from suing their employers.
While certain voluntary standards exist, their scope and approach fail to provide adequate protection for all workers. Thus, OSHA has determined that a federal standard is necessary.
Technological Feasibility and Costs of Compliance
OSHA reviewed the process safety management practices currently in place across industry as well as the recommended practices of industry trade associations and standards-setting organizations. On the basis of substantial current compliance found by OSHA and its consultants, widespread familiarity with the concepts and procedures of PSM, and the availability of technical consultation within and outside the affected sectors, OSHA has determined that the final rule for managing process hazards is technologically feasible.
OSHA estimated the costs of compliance with the PSM standard using information from the rulemaking record and from a report prepared under contract by Kearney/Centaur in 1990 [Ex. 5]. Most of the activities required by the PSM standard involve personnel time to develop programs and procedures, train employees, and carry out inspection activities. Capital costs will be incurred by firms when process hazard analyses and pre-startup safety reviews uncover the need to redesign processes and/or change equipment in order to reduce risks.
Consistent with the implementation schedule for completing initial process hazard analyses under Paragraph (e) of the standard, OSHA estimated compliance costs for two five-year periods. OSHA estimates that $888.7 million in direct annualized costs will be required to comply with the standard during each of the first five years following implementation of the rule. Of this annual cost, $470.8 million (53 percent) are attributed to Paragraph (e), Process Hazard Analysis, and $179.1 million (20 percent) to Paragraph (1), Management of Change. Annualized compliance costs during Years 6-10 will be $405.8 million. The decline in costs is largely related to the completion of process hazard analyses for existing operations.
Implementation of process safety management should generate cost savings in the forms of improved worker productivity, reduced incidence of property damage, diminished probability of lost production, and reduced employee turnover. Based upon an analysis by Kearney/Centaur, OSHA estimates that the value of annual PSM-related cost savings will be $719.9
million in Years 1–5 and $1.44 billion in Years 6–10. Subtracting the value of the cost savings from the annualized direct costs gives adjusted compliance costs of $188.8 million in Years 1–5. Cost savings are expected to exceed direct costs for most industry groups in Years 6–10. OSHA believes the true economic cost of the standard is best reflected by the adjusted costs. Furthermore, the estimate may understate the true cost savings, in that insurance, administrative, and societal cost savings associated with accident prevention are not included in the assessment.
**Benefits**
OSHA anticipates that full compliance with the PSM standard will lead to fewer catastrophic fires, explosions, releases of hazardous substances and other types of serious accidents. It is expected that many minor incidents will be prevented as well. Using data from the OSHA Integrated Management Information System database and applying an adjustment based upon the analysis of Charles River Associates [Ex. 10] and Kearney/Centaur [Ex. 5], OSHA estimated the baseline number of fatalities and injuries/illnesses linked to the PSM standard for the period 1983–90. For the eight-year period, an average of 330 fatalities and 1,918 injuries/illnesses per year were associated with major accidents involving hazardous materials (these totals exclude fatalities and injuries in California, New Jersey and Delaware). Using an average risk-reduction estimate of 40 percent for Years 1–5 implementation phase, OSHA estimates that 132 fatalities and 787 catastrophic injuries/illnesses (including 250 lost-workday injuries) will be avoided annually through compliance with the standard. In Years 6–10, a risk reduction of 80 percent is projected, with 264 fatalities and 1,534 injuries/illnesses (including 500 catastrophic lost-workday injuries) avoided, annually.
In addition to the health and safety benefits from preventing catastrophic incidents, reductions in injuries and illnesses related to minor process disruptions are anticipated, as well as reductions in the long-run risks posed by occasional releases of toxic vapors and gases and by the physical hazards of poor process design.
**Economic Impact and Regulatory Flexibility Analysis**
OSHA assessed the potential economic impact of the PSM standard separately on large and small establishments and has determined that none of the major industry groups would experience a significant economic burden as a result of the standard. If affected large establishments added the entire cost of compliance to the price of their final good, OSHA estimates that the average price increase would not exceed 0.07 percent during the ten-year period of analysis, based on the ratio of gross compliance costs to average establishment revenue. The maximum price increase in any major industry sector would be 0.7 percent. On the other hand, if all direct compliance costs were absorbed internally (and not passed forward to final customers), OSHA estimates that the average reduction in profits among large firms (20 or more employees) would approximate 1.2 percent.
While a few industry groups might experience profit reductions above 5 percent under the no-cost-pass-through scenario, the large-firm impact on the majority of affected major industry groups would be less than 3 percent of profit.
As required by the Regulatory Flexibility Act of 1980, OSHA assessed the economic burden faced by small establishments. For Years 1 through 5, the average ratio of direct cost to revenue for firms with fewer than twenty employees would be 0.23 percent. If small firms were to absorb the direct cost of regulation in full, profit reductions would average 3.4 percent for the first five years of implementation. Since profit impacts of less than 6 percent would be felt by the majority of small establishments under this scenario (zero cost offsets), OSHA has determined that the standard is economically feasible for small firms.
**International Trade**
OSHA is aware that the European and East Asian economic communities are introducing the concept of process safety management among their member countries. In time, European and Asian firms adopting PSM programs will experience the range of implementation costs estimated in this RIA for American firms. OSHA anticipates that as PSM becomes widespread throughout American industry, the productivity benefits and other cost-savings resulting from the rule could improve the competitiveness of American businesses.
During the implementation schedule, the standard is not likely to have a significant adverse effect on international trade because of the small magnitude of any price increase that would be required for passing forward compliance costs. As indicated above, the maximum price increases generated from the standard would be less than 0.3 percent for the majority of affected establishments. Thus, no measurable impact on foreign trade is expected.
**Environmental Assessment**
The PSM standard has been reviewed in accordance with the requirements of the National Environmental Policy Act (NEPA) of 1969 (42 U.S.C. 4321 et seq.), the regulations of the Council on Environmental Quality (CEQ) (40 CFR part 1500), and DOL NEPA Procedures (29 CFR part 11). The provisions of the standard focus on the reduction and avoidance of incidents involving toxic releases, fires and explosions. Consequently, no major negative impact is foreseeable on air, water or soil quality, plant or animal life, the use of land or other aspects of the environment. OSHA believes that compliance with the standard will result in positive environmental effects in the form of fewer releases of toxic liquids, solids and gases into the air, soil and water.
**VI. Federalism**
This regulation has been reviewed in accordance with Executive Order 12612 (52 FR 41885, October 30, 1987) regarding Federalism. This Order requires that agencies, to the extent possible, refrain from limiting state policy options, consult with states prior to taking any actions which would restrict state policy options, and take such actions only when there is clear constitutional authority and the presence of a problem of national scope. The Order provides for preemption of state law only if there is a clear Congressional intent for the Agency to do so. Any such preemption is to be limited to the extent possible.
Section 18 of the Occupational Safety and Health Act (OSH Act) expresses Congress' clear intent to preempt state laws relating to issues on which Federal OSHA has promulgated safety and health standards. Under the OSH Act, a state can avoid preemption only if it submits, and obtains Federal approval of a plan for the development of such standards and their enforcement. Occupational Safety and health standards developed by such State Plans—States must, among other things, be at least as effective in providing safe and healthful employment and places of employment as the Federal standards. Where such standards are applicable to products distributed or used in interstate commerce, they may not unduly burden commerce and must be justified by compelling local conditions (see section 28(c)(2) of the OSH Act).
The Federal final standard on process safety management of highly hazardous chemicals addresses hazards that are not unique to any one state or region of
the country. Nonetheless, states with occupational safety and health plans approved under section 18 of the OSHA Act will be able to develop their own state standards to deal with any special problems which might be encountered in a particular state. Moreover, because this standard is written in general, performance-oriented terms, there is considerable flexibility for state plans to require, and for affected employers to use, methods of compliance which are appropriate to the working conditions covered by the standard.
In brief, this proposed rule addresses a clear national problem related to occupational safety and health in general industry. Those states which have elected to participate under section 18 of the OSHAct are not preempted by this standard, and will be able to address any special conditions within the framework of the Federal Act while ensuring that the state standards are at least as effective as that standard. State comments were considered prior to promulgation of this final rule.
VII. State Plan States
The 25 States and Territories with their own OSHA approved occupational safety and health plans must adopt a comparable standard within six months of the publication date of this final standard. These 25 States and Territories are: Alaska, Arizona, California, Connecticut (for State and local government employees only), Hawaii, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Nevada, New Mexico, New York (for State and local government employee only), North Carolina, Oregon, Puerto Rico, South Carolina, Tennessee, Utah, Vermont, Virginia, Virgin Islands, Washington, and Wyoming. Until such time a state standard is promulgated, Federal OSHA will provide interim enforcement assistance, as appropriate, in these states.
List of Subjects in 29 CFR Part 1910
Explosive, Flammable liquids and gases, Hazard analysis, highly hazardous chemicals, Hazardous materials, Occupational safety and health, Safety, Process hazard analysis, Pyrotechnics.
Authority
This document has been prepared under the direction of Dorothy L. Strunk, Acting Assistant Secretary of Labor for Occupational Safety and Health, U.S. Department of Labor, 200 Constitution Avenue, NW., Washington DC 20210.
Accordingly, pursuant to sections 4, 6, and 8 of the Occupational Safety and Health Act of 1970 (29 U.S.C. 653, 655, 657); Section 304, Clean Air Act Amendments of 1990 (Pub. L. 101–549, Nov. 15, 1990, reprinted at 29 U.S.C. 655 Note (Supp. 1991)); Secretary of Labor's Order No. 1–90 (55 FR 9033); and 29 CFR part 1911, 29 CFR part 1910 is amended as set forth below.
Signed at Washington, DC, this 14th day of February, 1992.
Dorothy L. Strunk,
Acting Assistant Secretary of Labor.
PART 1910—OCCUPATIONAL SAFETY AND HEALTH STANDARDS
1. The authority citation for Subpart H of Part 1910 is revised to read as follows:
Authority: Secs. 4, 6, 8, Occupational Safety and Health Act of 1970 (29 U.S.C. 653, 655, 657); Secretary of Labor's Order No. 12–71 (38 FR 8754), 8–76 (41 FR 25059), 9–83 (48 FR 35738) or 1–90 (55 FR 9033), as applicable.
Sections 1910.103, 1910.106, 1910.107, 1910.108, 1910.109, 1910.110, 1910.111 and 1910.119 are also issued under 29 CFR part 1911.
Section 1910.119 is also issued under Sec. 304, Clean Air Act Amendments of 1990 (Public Law 101–549, Nov. 15, 1990, reprinted at 29 U.S.C. 655 Note (Supp. 1991)).
Section 1910.120 is also issued under Sec. 126, Superfund Amendments and Reauthorization Act of 1986 as amended (29 U.S.C. 655 note), 5 U.S.C. 553, and 29 CFR part 1911.
2. Section 1910.109 is amended by revising paragraph (k) to read as follows:
§ 1910.109 Explosives and blasting agents.
* * * * *
(k) Scope. (1) This section applies to the manufacture, keeping, having, storage, sale, transportation, and use of explosives, blasting agents, and pyrotechnics. The section does not apply to the sale and use (public display) of pyrotechnics, commonly known as fireworks, nor the use of explosives in the form prescribed by the official U.S. Pharmacopeia.
(2) The manufacture of explosives as defined in paragraph (a)(3) of this section shall also meet the requirements contained in § 1910.119.
(3) The manufacture of pyrotechnics as defined in paragraph (a)(10) of this section shall also meet the requirements contained in § 1910.119.
A new § 1910.119 and appendices A through D to § 1910.119 are added to read as follows:
§ 1910.119 Process safety management of highly hazardous chemicals.
Purpose. This section contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire or explosion hazards.
(a) Application. (1) This section applies to the following:
(i) A process which involves a chemical at or above the specified threshold quantities listed in Appendix A to this section;
(ii) A process which involves a flammable liquid or gas (as defined in 1910.1200(c) of this part) on site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more except for:
(A) Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by this standard;
(B) Flammable liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration.
(2) This section does not apply to:
(i) Retail facilities;
(ii) Oil or gas well drilling or servicing operations; or,
(iii) Normally unoccupied remote facilities.
(b) Definitions. Atmospheric tank means a storage tank which has been designed to operate at pressures from atmospheric through 0.5 p.s.i.g. (pounds per square inch gauge, 3.45 Kpa).
Boiling point means the boiling point of a liquid at a pressure of 14.7 pounds per square inch absolute [p.s.i.a.] (760 mm.). For the purposes of this section, where an accurate boiling point is unavailable for the material in question, or for mixtures which do not have a constant boiling point, the 10 percent point of a distillation performed in accordance with the Standard Method of Test for Distillation of Petroleum Products, ASTM D-86-82, may be used as the boiling point of the liquid.
Catastrophic release means a major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals, that presents serious danger to employees in the workplace.
Facility means the buildings, containers or equipment which contain a process.
Highly hazardous chemical means a substance possessing toxic, reactive, flammable, or explosive properties and specified by paragraph (a)(1) of this section.
Hot work means work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations.
Normally unoccupied remote facility means a facility which is operated, maintained or serviced by employees who visit the facility only periodically to check its operation and to perform necessary operating or maintenance tasks. No employees are permanently stationed at the facility.
Facilities meeting this definition are not contiguous with, and must be geographically remote from all other buildings, processes or persons.
Process means any activity involving a highly hazardous chemical including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. For purposes of this definition, any group of vessels which are interconnected and separate vessels which are located such that a highly hazardous chemical could be involved in a potential release shall be considered a single process.
Replacement in kind means a replacement which satisfies the design specification.
Trade secret means any confidential formula, pattern, process, device, information or compilation of information that is used in an employer's business, and that gives the employer an opportunity to obtain an advantage over competitors who do not know or use it. Appendix D contained in § 1910.1200 sets out the criteria to be used in evaluating trade secrets.
(c) Employee participation. (1) Employers shall develop a written plan of action regarding the implementation of the employee participation required by this paragraph.
(2) Employers shall consult with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in this standard.
(3) Employers shall provide to employees and their representatives access to process hazard analyses and to all other information required to be developed under this standard.
(d) Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this section, the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.
(1) Information pertaining to the hazards of the highly hazardous chemicals in the process. This information shall consist of at least the following:
(i) Toxicity information;
(ii) Permissible exposure limits;
(iii) Physical data;
(iv) Reactivity data;
(v) Corrosivity data;
(vi) Thermal and chemical stability data; and
(vii) Hazardous effects of inadvertent mixing of different materials that could foreseeably occur.
Note: Material Safety Data Sheets meeting the requirements of 29 CFR 1910.1200(g) may be used to comply with this requirement to the extent they contain the information required by this subparagraph.
(2) Information pertaining to the technology of the process. (i) Information concerning the technology of the process shall include at least the following:
(A) A block flow diagram or simplified process flow diagram (see Appendix B to this section);
(B) Process chemistry;
(C) Maximum intended inventory;
(D) Safe upper and lower limits for such items as temperatures, pressures, flows or compositions; and,
(E) An evaluation of the consequences of deviations, including those affecting the safety and health of employees.
(ii) Where the original technical information no longer exists, such information may be developed in conjunction with the process hazard analysis in sufficient detail to support the analysis.
(3) Information pertaining to the equipment in the process. (i) Information pertaining to the equipment in the process shall include:
(A) Materials of construction;
(B) Piping and instrument diagrams (P&I'D's);
(C) Electrical classification;
(D) Relief system design and design basis;
(E) Ventilation system design;
(F) Design codes and standards employed;
(G) Material and energy balances for processes built after May 26, 1992; and,
(H) Safety systems (e.g. interlocks, detection or suppression systems).
(ii) The employer shall document that equipment complies with recognized and generally accepted good engineering practices.
(iii) For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer shall determine and document that the equipment is designed, maintained, inspected, tested, and operating in a safe manner.
(e) Process hazard analysis. (1) The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. Employers shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process. The process hazard analysis shall be conducted as soon as possible, but not later than the following schedule:
(i) No less than 50 percent of the initial process hazards analyses shall be completed by May 26, 1994;
(ii) No less than 50 percent of the initial process hazards analyses shall be completed by May 26, 1995;
(iii) No less than 75 percent of the initial process hazards analyses shall be completed by May 26, 1996;
(iv) All initial process hazards analyses shall be completed by May 26, 1997.
(v) Process hazards analyses completed after May 26, 1987 which meet the requirements of this paragraph are acceptable as initial process hazards analyses. The process hazard analyses shall be updated and revalidated, based on their completion date, in accordance with paragraph (e)(6) of this section.
(2) The employer shall use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed.
(i) What-If;
(ii) Checklist;
(iii) What-If/Checklist;
(iv) Hazard and Operability Study (HAZOP);
(v) Failure Mode and Effects Analysis (FMEA);
(vi) Fault Tree Analysis; or
(vii) An appropriate equivalent methodology.
(3) The process hazard analysis shall address:
(i) The hazards of the process;
(ii) The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace;
(iii) Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.);
(iv) Consequences of failure of engineering and administrative controls;
(v) Facility siting;
(vi) Human factors; and
(vii) A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace.
(4) The process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used.
(5) The employer shall establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.
(6) At least every five (5) years after the completion of the initial process hazard analysis, the process hazard analysis shall be updated and revalidated by a team meeting the requirements in paragraph (e)(4) of this section, to assure that the process hazard analysis is consistent with the current process.
(7) Employers shall retain process hazards analyses and updates or revalidations for each process covered by this section, as well as the documented resolution of recommendations described in paragraph (e)(5) of this section for the life of the process.
(f) Operating procedures
(1) The employer shall develop and implement written operating procedures that provide clear instructions for safety conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements.
(i) Steps for each operating phase:
(A) Initial startup;
(B) Normal operations;
(C) Temporary operations;
(D) Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.
(E) Emergency Operations;
(F) Normal shutdown; and,
(G) Startup following a turnaround, or after an emergency shutdown.
(ii) Operating limits:
(A) Consequences of deviation; and
(B) Steps required to correct or avoid deviation.
(iii) Safety and health considerations:
(A) Properties of, and hazards presented by, the chemicals used in the process;
(B) Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment;
(C) Control measures to be taken if physical contact or airborne exposure occurs;
(D) Quality control for raw materials and control of hazardous chemical inventory levels; and,
(E) Any special or unique hazards.
(iv) Safety systems and their functions.
(2) Operating procedures shall be readily accessible to employees who work in or maintain a process.
(3) The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer shall certify annually that these operating procedures are current and accurate.
(4) The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees.
(g) Training.
(1) Initial training.
(i) Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks.
(ii) In lieu of initial training for those employees already involved in operating a process on May 26, 1992, an employer may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures.
(2) Refresher training. Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process. The employer, in consultation with the employees involved in operating the process, shall determine the appropriate frequency of refresher training.
(3) Training documentation. The employer shall ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The employer shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.
(h) Contractors.
(1) Application. This paragraph applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. It does not apply to contractors providing incidental services which do not influence process safety, such as janitorial work, food and drink services, laundry, delivery or other supply services.
(2) Employer responsibilities.
(i) The employer, when selecting a contractor, shall obtain and evaluate information regarding the contract employer's safety performance and programs.
(ii) The employer shall inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process.
(iii) The employer shall explain to contract employers the applicable provisions of the emergency action plan required by paragraph (n) of this section.
(iv) The employer shall develop and implement safe work practices consistent with paragraph (f)(4) of this section, to control the entrance, presence and exit of contract employers and contract employees in covered process areas.
(v) The employer shall periodically evaluate the performance of contract employers in fulfilling their obligations as specified in paragraph (h)(3) of this section.
(vi) The employer shall maintain a contract employee injury and illness log related to the contractor's work in process areas.
(3) Contract employer responsibilities.
(i) The contract employer shall assure that each contract employee is trained in the work practices necessary to safely perform his/her job.
(ii) The contract employer shall assure that each contract employee is instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the process, and the applicable provisions of the emergency action plan.
(iii) The contract employer shall document that each contract employee has received and understood the training required by this paragraph. The contract employer shall prepare a record which contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training.
(iv) The contract employer shall assure that each contract employee follows the safety rules of the facility including the safe work practices required by paragraph (f)(4) of this section.
(v) The contract employer shall advise the employer of any unique hazards presented by the contract employer's work, or of any hazards found by the contract employer's work.
(i) Pre-startup safety review. (1) The employer shall perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.
(2) The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process:
(i) Construction and equipment is in accordance with design specifications;
(ii) Safety, operating, maintenance, and emergency procedures are in place and are adequate;
(iii) For new facilities, a process hazard analysis has been performed and recommendations have been resolved or implemented before startup; and
modified facilities meet the requirements contained in management of change, paragraph (l).
(iv) Training of each employee involved in operating a process has been completed.
(l) Mechanical integrity. (1) Application. Paragraphs (j)(2) through (j)(6) of this section apply to the following process equipment:
(i) Pressure vessels and storage tanks;
(ii) Piping systems (including piping components such as valves);
(iii) Relief and vent systems and devices;
(iv) Emergency shutdown systems;
(v) Controls (including monitoring devices and sensors, alarms, and interlocks) and,
(vi) Pumps.
(2) Written Procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment.
(3) Training for process maintenance activities. The employer shall train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner.
(4) Inspection and testing. (i) Inspections and tests shall be performed on process equipment.
(ii) Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.
(iii) The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.
(iv) The employer shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.
(5) Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation.
(6) Quality assurance. (i) In the construction of new plants and equipment, the employer shall assure that equipment as it is fabricated is suitable for the process application for which they will be used.
(ii) Appropriate checks and inspections shall be performed to assure that equipment is installed properly and consistent with design specifications and the manufacturer's instructions.
(iii) The employer shall assure that maintenance materials, spare parts and equipment are suitable for the process application for which they will be used.
(k) Hot work permit. (1) The employer shall issue a hot work permit for hot work operations conducted on or near a covered process.
(2) The permit shall document that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot work operations; it shall indicate the date(s) authorized for hot work; and identify the object on which hot work is to be performed. The permit shall be kept on file until completion of the hot work operations.
(l) Management of change. (1) The employer shall establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.
(2) The procedures shall assure that the following considerations are addressed prior to any change:
(i) The technical basis for the proposed change;
(ii) Impact of change on safety and health;
(iii) Modifications to operating procedures;
(iv) Necessary time period for the change; and,
(v) Authorization requirements for the proposed change.
(3) Employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process shall be informed of, and trained in, the change prior to start-up of the process or affected part of the process.
(4) If a change covered by this paragraph results in a change in the process safety information required by paragraph (d) of this section, such information shall be updated accordingly.
(5) If a change covered by this paragraph results in a change in the operating procedures or practices required by paragraph (f) of this section, such procedures or practices shall be updated accordingly.
(m) Incident investigation. (1) The employer shall investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace.
(2) An incident investigation shall be initiated as promptly as possible, but not
later than 48 hours following the incident.
(3) An incident investigation team shall be established and consist of at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident.
(4) A report shall be prepared at the conclusion of the investigation which includes at a minimum:
(i) Date of incident;
(ii) Date investigation began;
(iii) A description of the incident;
(iv) The factors that contributed to the incident; and,
(v) Any recommendations resulting from the investigation.
(5) The employer shall establish a system to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions shall be documented.
(6) The report shall be reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable.
(7) Incident investigation reports shall be retained for five years.
(n) Emergency planning and response. The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38(a). In addition, the emergency action plan shall include procedures for handling small releases. Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120 (a), (p) and (q).
(o) Compliance Audits. (1) Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.
(2) The compliance audit shall be conducted by at least one person knowledgeable in the process.
(3) A report of the findings of the audit shall be developed.
(4) The employer shall promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.
(5) Employers shall retain the two (2) most recent compliance audit reports.
(p) Trade secrets. (1) Employers shall make all information necessary to comply with the section available to those persons responsible for compiling the process safety information (required by paragraph (d) of this section), those assisting in the development of the process hazard analysis (required by paragraph (e) of this section), those responsible for developing the operating procedures (required by paragraph (f) of this section), and those involved in incident investigations (required by paragraph (m) of this section), emergency planning and response (paragraph (n) of this section) and compliance audits (paragraph (o) of this section) without regard to possible trade secret status of such information.
(2) Nothing in this paragraph shall preclude the employer from requiring the persons to whom the information is made available under paragraph (p)(1) of this section to enter into confidentiality agreements not to disclose the information as set forth in 29 CFR 1910.1200.
(3) Subject to the rules and procedures set forth in 29 CFR 1910.1200(j)(1) through 1910.1200(j)(12), employees and their designated representatives shall have access to trade secret information contained within the process hazard analysis and other documents required to be developed by this standard.
Appendix A to § 1910.119—List of Highly Hazardous Chemicals, Toxics and Reactives (Mandatory)
This Appendix contains a listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantity.
| CHEMICAL name | CAS* | TQ** |
|--------------------------------|------------|------|
| Chlorine Pentrafluoride | 13837–83–3 | 1000 |
| Chlorine Trifluoride | 7790–91–2 | 1000 |
| Chlorodiethylaluminum (also called Diethylaluminum Chloride) | 96–10–6 | 5000 |
| 1-Chloro-2,4-Dinitrobenzene | 97–00–7 | 5000 |
| Chloromethyl Methyl Ether | 107–30–2 | 500 |
| Chloropicrin | 76–06–2 | 500 |
| Chloropicrin and Methyl Bromide mixture | None | 1500 |
| Chloropicrin and Methyl Chloride mixture | None | 1500 |
| Cumene Hydroperoxide | 80–15–9 | 5000 |
| Cyanogen | 460–19–5 | 2500 |
| Cyanogen Chloride | 506–77–4 | 500 |
| Cyanuric Fluoride | 675–14–9 | 100 |
| Diacetyl Peroxide (Concentration >70%) | 110–22–5 | 5000 |
| Diazomethane | 334–88–3 | 500 |
| Dibenzoyl Peroxide | 94–36–0 | 7500 |
| Diborane | 19287–45–7 | 100 |
| Dibutyl Peroxide (Tertiary) | 110–05–4 | 5000 |
| Dichloro Acetylene | 7572–29–4 | 250 |
| Dichloroisocyanate | 4109–96–0 | 2500 |
| Diethylzinc | 557–20–0 | 10000|
| Disopropyl Peroxydicarbonate | 105–64–6 | 7500 |
| Dithiobisdiacrylate | 105–74–9 | 7500 |
| Dimethylchlorosilane | 75–78–5 | 1000 |
| Dimethylhydrazine, 1,1- | 57–14–7 | 1000 |
| Dimethylamine, Anhydrous | 124–40–3 | 2500 |
| 2,4-Dinitrotoluene | 97–02–9 | 5000 |
| Ethyl Methyl Ketone Peroxide (also Methyl Ethyl Ketone Peroxide; concentration >60%) | 1338–23–4 | 5000 |
| Ethyl Nitrite | 109–95–5 | 5000 |
| Ethylenimine | 75–04–7 | 7500 |
| Ethylene Fluorhydrin | 371–62–0 | 100 |
| Ethylene Oxide | 75–21–8 | 5000 |
| Ethyleneimine | 151–56–4 | 1000 |
| Fluorine | 7782–41–4 | 1000 |
| Formaldehyde (Formalin) | 50–00–0 | 1000 |
| Furan | 110–00–9 | 500 |
| Hexafluoroacetone | 684–16–2 | 5000 |
| Hydrochloric Acid, Anhydrous | 7647–01–0 | 5000 |
| Hydrofluoric Acid, Anhydrous | 7664–39–3 | 1000 |
| Hydrogen Bromide | 10035–10–6 | 5000 |
| Hydrogen Chloride | 7647–01–0 | 5000 |
| Hydrogen Cyanide, Anhydrous | 74–90–8 | 1000 |
| Hydrogen Fluoride | 7664–39–3 | 1000 |
| Hydrogen Peroxide (52% by weight or greater) | 7722–84–1 | 7500 |
| Hydrogen Selenide | 7783–07–5 | 150 |
| Hydrogen Sulfide | 7783–06–4 | 1500 |
| Hydroxylamine | 7803–87–9 | 2500 |
| Iron, Pentacarbonyl | 13463–40–6 | 250 |
| Ketene | 75–31–0 | 5000 |
| Methylacrolein | 463–51–4 | 100 |
| Methacryloyl Chloride | 78–85–3 | 1000 |
| Methacryloyloxyethyl Isocyanate | 30674–89–7 | 100 |
| Methyl Acrylonitrile | 126–99–7 | 250 |
| Methyl Hydrazine, Anhydrous | 74–89–5 | 1000 |
| Methyl Iodide | 74–83–9 | 2500 |
| Methyl Chloride | 74–87–3 | 15000|
| Methyl Chloroformate | 79–22–1 | 500 |
| Methyl Ethyl Ketone Peroxide (concentration >60%) | 1338–23–4 | 5000 |
| Methyl Fluoroacetate | 453–18–9 | 100 |
| Methyl Fluorosulfate | 421–20–5 | 100 |
| Methyl Hydrazine | 60–26–4 | 1000 |
| Methyl Iodide | 74–88–4 | 7500 |
| Methyl Isocyanate | 624–83–9 | 2500 |
| Methyl Mercaptan | 74–93–1 | 5000 |
| Methyl Vinyl Ketone | 79–84–4 | 100 |
| Methyltrichlorosilane | 75–79–6 | 500 |
| Nickel Carbonyl (Nickel Tetra carbonyl) | 13463–39–3 | 150 |
| CHEMICAL name | CAS* | TQ** |
|---------------------------------------------------|----------|------|
| Nitric Acid (94.5% by weight or greater) | 7697–37–2| 500 |
| Nitric Oxide | 10102–43–9| 250 |
| Nitroaniline (para Nitroaniline) | 100–01–6 | 5000 |
| Nitromethane | 75–52–5 | 2500 |
| Nitrogen Dioxide | 10102–44–0| 250 |
| Nitrogen Oxides (NO; NO₂; NO₃; NO₄; N₂O₃) | 10102–44–0| 250 |
| Nitrogen Tetroxide (also called Nitrogen Peroxide)| 10544–72–8| 250 |
| Nitrogen Trifluoride | 7783–54–2| 5000 |
| Nitrogen Trioxide | 10544–73–7| 250 |
| Oleum (65% to 80% by weight; also called Fuming Sulfuric Acid) | 8014–94–7| 1000 |
| Osmium Tetroxide | 20816–12–0| 100 |
| Oxygen Difluoride (Fluorine Monoxide) | 7783–41–7| 100 |
| Ozone | 10026–15–6| 100 |
| Pentaborane | 19624–22–7| 100 |
| Peracetic Acid (concentration > 60% Acetic Acid; also called Phosacetic Acid) | 79–21–0| 1000 |
| Perchloric Acid (concentration > 60% by weight) | 7601–90–3| 5000 |
| Pernchloromethyl Mercaptan | 594–42–3 | 150 |
| Perchloryl Fluoride | 7616–94–6| 5000 |
| Peroxyacetic Acid (concentration > 60% Acetic Acid; also called Persacetic Acid) | 79–21–0| 1000 |
| Phosgene (also called Carbonyl Chloride) | 75–44–5 | 100 |
| Phosphine (-Hydrogen Phosphide) | 7803–51–2| 100 |
| Phosphorus Oxychloride (also called Phosphoryl Chloride) | 10025–87–3| 1000 |
| Phosphorus Trichloride | 7719–12–2| 1000 |
| Phosphoryl Chloride (also called Phosphorus Oxychloride) | 10025–87–3| 1000 |
| Propargyl Bromide | 108–96–7 | 100 |
| Propyl Nitrate | 627–33–3 | 2500 |
| Selenol | 107–49–8 | 100 |
| Selenium Hexafluoride | 7783–79–1| 1000 |
| Stibine (Antimony Hydride) | 7803–52–3| 500 |
| Sulfur Dioxide (liquid) | 7446–09–5| 1000 |
| Sulfur Pentafluoride | 5714–22–7| 250 |
| Sulfur Tetrafluoride | 7783–60–0| 250 |
| Sulfur Trioxide (also called Sulfuric Anhydride) | 7446–11–9| 1000 |
| Sulfuric Anhydride (also called Sulfur Trioxide) | 7446–11–9| 1000 |
| Tellurium Hexafluoride | 7783–80–4| 250 |
| Tetrafluoroethylene | 116–14–3 | 5000 |
| Tetrafluorohydrazine | 10036–47–2| 5000 |
| Tetramethyl Lead | 75–74–1 | 1000 |
| Thionyl Chloride | 7719–09–7| 250 |
| Trichloro (chloromethyl) Silane | 1558–25–4| 100 |
| Trichloro (dichlorophenyl) Silane | 27137–85–5| 2500 |
| Trichlorosilane | 10025–78–2| 5000 |
| Trifluorochloroethylene | 79–38–9 | 10000|
| Trimethoxysilane | 2487–90–3| 1500 |
*Chemical Abstract Service Number.
**Threshold Quantity in Pounds (Amount necessary to be covered by this standard).
Appendix B to § 1910.119—Block Flow Diagram and Simplified Process Flow Diagram (Nonmandatory)
BILLING CODE 4510–26–M
EXAMPLE OF A BLOCK FLOW DIAGRAM
Raw Material Feed → Primary Reactor → Distillation → Off Gas, Steam
Product Gas
Waste Water → Pump/Tank → Direct Contact Cooling → Stripping → Steam
Condenser Primary Liquifier → Heat Exchanger → Compressor
Condenser Secondary Liquifier → Gas Absorber → Neutralization Disposal Tanks → Neutralization Scrubber → Waste Water, Caustic, To Cooler
Liquid Product Accumulation Tank → 35 PSIG Storage Tank → Railroad Tank Cars → Product to Customer
100 PSIG Storage Tank → Evaporator → Product for Plant Use, Steam
263
EXAMPLE OF A PROCESS FLOW DIAGRAM
| ABC Chemical, Inc. | Process Flow Diagram No. | Rev. |
|--------------------|--------------------------|------|
| | | |
BILLING CODE 4510-28-C
Appendix C to § 1910.119—Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory)
This appendix serves as a nonmandatory guideline to assist employers and employees in complying with the requirements of this section, as well as provides other helpful recommendations and information. Examples presented in this appendix are not the only means of achieving the performance goals in the standard. This appendix neither adds nor detracts from the requirements of the standard.
1. Introduction to Process Safety Management. The major objective of process safety management of highly hazardous chemicals is to prevent unwanted releases of hazardous chemicals especially into locations which could expose employees and others to serious hazards. An effective process safety management program requires a systematic approach to evaluating the whole process. Using this approach the process design, process technology, operational and maintenance activities and procedures, nonroutine activities and procedures, emergency preparedness plans and procedures, training programs, and other elements which impact the process are all considered in the evaluation. The various lines of defense that have been incorporated into the design and operation of the process to prevent or mitigate the release of hazardous chemicals need to be evaluated and strengthened to assure their effectiveness at each level. Process safety management is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in process, procedures or equipment.
The process safety management standard targets highly hazardous chemicals that have the potential to cause a catastrophic incident. This standard as a whole is to aid employers in their efforts to prevent or mitigate episodic chemical releases that could lead to a catastrophe in the workplace and possibly to the surrounding community. To control these types of hazards, employers need to develop the necessary expertise, experiences, judgement and proactive initiative within their workforce to properly implement and maintain an effective process safety management program as envisioned in the OSHA standard. This OSHA standard is required by the Clean Air Act Amendments as is the Environmental Protection Agency’s Risk Management Plan. Employers, who merge the two sets of requirements into their process safety management program, will better assure full compliance with each as well as enhancing their relationship with the local community.
While OSHA believes process safety management will have a positive effect on the safety of employees in workplaces and also offers other potential benefits to employers (increased productivity), smaller businesses which may have limited resources available to them at this time, might consider alternative avenues of decreasing the risks associated with highly hazardous chemicals at their workplaces. One method which might be considered is the reduction in the inventory of the highly hazardous chemical. This reduction in inventory will result in a reduction of the risk or potential for a catastrophic incident. Also, employers including small employers may be able to establish more efficient inventory control by reducing the quantities of highly hazardous chemicals on site below the established threshold quantities. This reduction can be accomplished by ordering smaller shipments and maintaining the minimum inventories necessary for efficient and safe operation. When reduced inventory is not feasible, then the employer might consider dispersing inventory to several locations on site. Dispersing storage into locations where a release in one location will not cause a release in another location is a practical method to also reduce the risk or potential for catastrophic incidents.
2. Employee Involvement in Process Safety Management. Section 304 of the Clean Air Act Amendments states that employers are to consult with their employees and their representatives regarding the employers’ efforts in the development and implementation of the process safety management program elements and hazard assessments. Section 304 also requires employers to train and educate their employees and to inform affected employees of the findings from incident investigations required by the process safety management program. Many employers, under their safety and health programs, have already established means and methods to keep employees and their representatives informed about relevant safety and health issues and employers may be able to adapt these practices and procedures to meet their obligations under this standard. Employers who have not implemented an occupational safety and health program may wish to form a safety and health committee of employees and management representatives to help the employer meet the obligations specified by this standard. These committees can become a significant ally in helping the employer to implement and maintain an effective process safety management program for all employees.
3. Process Safety Information. Complete and accurate written information concerning process chemicals, process technology, and process equipment is essential to an effective process safety management program and to a process hazards analysis. The compiled information will be a necessary resource to a variety of users including the team that will perform the process hazards analysis as required under paragraph (e); those developing the training programs and the operating procedures; contractors whose employees will be working with the process; those conducting the pre-startup reviews; local emergency preparedness planners; and insurance and enforcement officials.
The information to be compiled about the chemicals, including process intermediates, needs to be comprehensive enough for an accurate assessment of the fire and explosion characteristics, reactivity hazards, the safety and health hazards to workers, and the corrosion and erosion effects on the process equipment and monitoring tools. Current material safety data sheet (MSDS) information can be used to help meet this requirement which must be supplemented with process chemistry information including runaway reaction and over pressure hazards if applicable.
Process technology information will be a part of the process safety information package and it is expected that it will include diagrams of the type shown in Appendix B of this section as well as employer established criteria for maximum inventory levels for process chemicals; limits beyond which would be considered upset conditions; and a qualitative estimate of the consequences or results of deviation that could occur if operating beyond the established process limits. Employers are encouraged to use diagrams which will help users understand the process.
A block flow diagram is used to show the major process equipment and interconnecting process flow lines and show flow rates, stream composition, temperatures, and pressures when necessary for clarity. The block flow diagram is a simplified diagram.
Process flow diagrams are more complex and will show all main flow streams including valves to enhance the understanding of the process, as well as pressures and temperatures on all feed and product lines within all major vessels, in and out of headers and heat exchangers, and points of pressure and temperature control. Also, materials of construction information, pump capacities and pressure heads, compressor horsepower and vessel design pressures and temperatures are shown when necessary for clarity. In addition, major components of control loops are usually shown along with key utilities on process flow diagrams.
Piping and instrument diagrams (P&IDs) may be the more appropriate type of diagrams to show some of the above details and to display the information for the piping designer and engineering staff. The P&IDs are to be used to describe the relationships between equipment and instrumentation as well as other relevant information that will enhance clarity. Computer software programs which do P&IDs or other diagrams useful to the information package, may be used to help meet this requirement.
The information pertaining to process equipment design must be documented. In other words, what were the codes and standards relied on to establish good engineering practice. These codes and standards are published by such organizations as the American Society of Mechanical Engineers, American Petroleum Institute, American National Standards Institute, National Fire Protection Association, American Society for Testing and Materials, National Board of Boiler and Pressure Vessel Inspectors, National Association of Corrosion Engineers, American Society of Exchange Manufacturers Association, and model building code groups.
In addition, various engineering societies issue technical reports which impact process design. For example, the American Institute of Chemical Engineers has published technical reports on topics such as two phase flow for venting devices. This type of
technically recognized report would constitute good engineering practice.
For existing equipment designed and constructed many years ago in accordance with the codes and standards available at that time and no longer in general use today, the employer must document which codes and standards were used and that the design and construction along with the testing, inspection and operation are still suitable for the intended use. Where the process technology requires a design which departs from the applicable codes and standards, the employer must document that the design and construction is suitable for the intended purpose.
4. Process Hazard Analysis. A process hazard analysis (PHA), sometimes called a process hazard evaluation, is one of the most important elements of the process safety management program. A PHA is an organized and systematic effort to identify and analyze the significance of potential hazards associated with the processing or handling of highly hazardous chemicals. A PHA provides information which will assist employers and employees in making decisions for improving safety and reducing the consequences of unwanted or unplanned releases of hazardous chemicals. A PHA is directed toward analyzing potential causes and consequences of fires, explosions, releases of toxic or flammable chemicals and major spills of hazardous chemicals. The PHA focuses on equipment, instrumentation, utilities, human actions (routine and nonroutine), and external factors that might impact the process. These considerations assist in determining the hazards and potential failure points or failure modes in a process.
The selection of a PHA methodology or technique will be influenced by many factors including the amount of existing knowledge about the process. Is it a process that has been operated for a long period of time with little or no innovation and extensive experience has been generated with its use? Or, is it a new process or one which has been changed frequently by the inclusion of innovative features? Also, the size and complexity of the process will influence the decision as to the appropriate PHA methodology to use. All PHA methodologies are subject to certain limitations. For example, the checklist methodology works well when the process is very stable and no changes are made, but it is not as effective when the process has undergone extensive change. The checklist may miss the most recent changes and consequently the changes would not be evaluated. Another limitation to be considered concerns the assumptions made by the team or analyst. The PHA is dependent on good judgment and all the assumptions made during the study need to be documented and understood by the team and reviewer and kept for a future PHA.
The team conducting the PHA needs to understand the methodology that is going to be used. A PHA team can vary in size from two people to a number of people with varied operational and technical backgrounds. Some team members may only be a part of the team for a limited time. The team leader needs to be fully knowledgeable in the proper implementation of the PHA methodology that is to be used and should be impartial in the evaluation. The other full or part time team members need to provide the team with expertise in areas such as process technology, process design, operating procedures and practices, including how the work is actually performed, shutdowns, emergency procedures, instrumentation, maintenance procedures, both routine and nonroutine tasks, including how the tasks are authorized, procurement of parts and supplies, safety and health, and any other relevant subject as the need dictates. At least one team member must be familiar with the process.
The ideal team will have an intimate knowledge of the standards, codes, specifications and regulations applicable to the process being studied. The selected team members need to be compatible and the team leader needs to be able to manage the team, and the PHA study. The team needs to be able to work together while benefiting from the expertise of others on the team or outside the team, to resolve issues, and to forge a consensus on the findings of the study and recommendations.
The application of a PHA to a process may involve the use of different methodologies for various parts of the process. For example, a process involving a series of unit operations of varying sizes, complexities, and ages may use different methodologies and team members for each operations. Then the conclusions can be integrated into one final study and evaluation. A more specific example is the use of a checklist PHA for a standard boiler or heat exchanger and the use of a Hazard and Operability PHA for the overall process. Also, for batch type processes like custom batch operations, a generic PHA of a representative batch may be used where there are only small changes of monomer or other ingredient ratios and the chemistry is documented for the full range and ratio of batch ingredients. Another process that might consider using a generic type of PHA is a gas plant. Often these plants are simply moved from site to site and therefore, a generic PHA may be used for these movable plants. Also, when an employer has several similar size gas plants and no sour gas is being processed at the site, then a generic PHA is feasible as long as the variations of the individual sites are accounted for in the PHA. Finally, when an employer has a large continuous process which has several control rooms for different portions of the process such as for a distillation tower and a blending operation, the employer may wish to do each segment separately and then integrate the final results.
Additionally, small businesses which are covered by this rule, will often have processes that have less storage volume, less capacity, and less complicated than processes at a large facility. Therefore, OSHA would anticipate that the less complex methodologies would be used to meet the process hazard analysis criteria in the standard. These process hazard analyses can be done in less time and with a few people being involved. A less complex process generally means that less data, P&IDs, and process information is needed to perform a process hazard analysis.
Many small businesses have processes that are not unique, such as cold storage lockers or water treatment facilities. Where employer associations have a number of members with such facilities, a generic PHA, evolved from a checklist or what-if questions, could be developed and used by each employer effectively to reflect his/her particular process; this would simplify compliance for them.
When the employer has a number of processes which require a PHA, the employer must set up a priority system of which PHAs to conduct first. A preliminary or gross hazard analysis may be useful in prioritizing the processes that the employer has determined are subject to coverage by the process safety management standard. Consideration should first be given to those processes with the potential of adversely affecting the largest number of employees. This prioritizing should consider the potential severity of a chemical release, the number of potentially affected employees, the operating history of the process such as the frequency of chemical releases, the age of the process and any other relevant factors. These factors would suggest a ranking order and would suggest either using a weighing factor system or a systematic ranking method. The use of a preliminary hazard analysis would assist an employer in determining which process should be of the highest priority and thereby the employer would obtain the greatest improvement in safety at the facility.
Detailed guidance on the content and application of process hazard analysis methodologies is available from the American Institute of Chemical Engineers' Center for Chemical Process Safety (see appendix D).
5. Operating Procedures and Practices. Operating procedures describe tasks to be performed, data to be recorded, operating conditions to be maintained, samples to be collected, and safety and health precautions to be taken. The procedures need to be technically accurate, understandable to employees, and revised periodically to ensure that they reflect current operations. The process safety information package is to be used as a resource to better assure that the operating procedures and practices are consistent with the known hazards of the chemicals in the process and that the operating parameters are accurate. Operating procedures should be reviewed by engineering staff and operating personnel to ensure that they are accurate and provide practical instructions on how to actually carry out job duties safely.
Operating procedures will include specific instructions or details on what steps are to be taken or followed in carrying out the stated procedures. These operating instructions for each procedure should include the applicable safety precautions and should contain appropriate information on safety implications. For example, the operating procedures addressing operating parameters will contain operating instructions about pressure limits, temperature ranges, flow rates, what to do when an upset condition
occurs, what alarms and instruments are pertinent if an upset condition occurs, and other subjects. Another example of using operating instructions is properly implement operating procedures for startup or shutting down the process. In these cases, different parameters will be required from those of normal operation. These operating instructions need to clearly indicate the distinctions between startup and normal operations such as the appropriate allowances for heating up a unit to reach the normal operating parameters. Also the operating instructions need to describe the proper method for increasing the temperature of the unit until the normal operating temperature parameters are achieved.
Computerized process control systems add complexity to operating instructions. These operating instructions need to describe the logic of the software as well as the relationship between the equipment and the control system; otherwise, it may not be apparent to the operator.
Operating procedures and instructions are important for training operating personnel. The operating procedures are often viewed as the standard operating practices (SOPs) for operations. Control room personnel and operating staff, in general, need to have a full understanding of operating procedures. If workers are not fluent in English then procedures and instructions need to be prepared in a second language understood by the workers. In addition, operating procedures need to be changed when there is a change in the process as a result of the management of change procedures. The consequences of operating procedure changes need to be fully evaluated and the information conveyed to the personnel. For example, mechanical changes to the process made by the maintenance department (like changing a valve from steel to brass or other subtle changes) need to be evaluated to determine if operating procedures and practices also need to be changed. All management of change actions must be coordinated and integrated with current operating procedures and operating personnel must be oriented to the changes in procedures before the change is made. When the process is shut down in order to make a change, then the operating procedures must be updated before startup of the process.
Training in how to handle upset conditions must be accomplished as well as what operating personnel are to do in emergencies such as when a pump seal fails or a pipeline ruptures. Communication between operating personnel and workers performing work within the process area, such as on routine tasks, also must be maintained. The hazards of the tasks are to be conveyed to operating personnel in accordance with established procedures and to those performing the actual tasks. When the work is completed, operating personnel should be informed to provide closure on the job.
6. Employee Training. All employees, including maintenance and contractor employees, involved with highly hazardous chemicals need to fully understand the safety and health hazards of the chemicals and processes they work with for the protection of themselves, their fellow employees and the citizens of nearby communities. Training conducted in compliance with § 1910.1200, the Hazard Communication standard, will help employees to be more knowledgeable about the chemicals they work with as well as familiarize them with reading and understanding MSDS. However, additional training in subjects such as operating procedures and safety work practices, emergency evacuation and response, safety procedures, routine and nonroutine work authorization activities, and other areas pertinent to process safety and health will need to be covered by an employer's training program.
In establishing their training programs, employers must clearly define the employees to be trained and what subjects are to be covered in their training. Employers in setting up their training program will need to clearly establish the goals and objectives they wish to achieve with the training that they provide to their employees. The learning goals or objectives should be written in clear measurable terms before the training begins. These goals and objectives need to be tailored to each of the specific training modules or segments. Employers should describe the expected actions and conditions under which the employee will demonstrate competence or knowledge as well as what is acceptable performance.
Hands-on-training where employees are able to use their senses beyond listening, will enhance learning. For example, operating personnel, who will work in a control room or at control panels, would benefit by being trained at a simulated control panel or panels. Upset conditions of various types could be displayed on the simulator, and then the employee could go through the proper operating procedures to bring the simulator panel back to the normal operating parameters. A training environment could be created to help the trainee feel the full reality of the situation but, of course, under controlled conditions. This realistic type of training can be very effective in teaching employees correct procedures while allowing them to also see the consequences of what might happen if they do not follow established operating procedures. Other training techniques using videos or on-the-job training can also be very effective for teaching other job tasks, duties, or other important information. An effective training program will allow the employee to fully participate in the training process and to practice their skill or knowledge.
Employers need to periodically evaluate the training program to see if the necessary skills, knowledge, and routines are being properly understood and implemented by their trained employees. The means or methods for evaluating the training should be developed along with the training program goals and objectives. Training program evaluation will help employers to determine the amount of training their employees understood, and whether the desired results were obtained. If, after the evaluation, it appears that the trained employees are not at the level of knowledge and skill that was expected, the employer will need to revise the training program, provide retraining, or provide more frequent refresher training sessions until the deficiency is resolved. Those who conducted the training and those who received the training should also be consulted as to how best to improve the training process. If there is a language barrier, the language known to the trainees should be used to reinforce the training messages and information.
Careful consideration must be given to assure that employees including maintenance and contract employees receive current and updated training. For example, if changes are made to a process, impacted employees must be trained in the changes and understand the effects of the changes on their job tasks (e.g., any new operating procedures pertinent to their tasks). Additionally, as already discussed the evaluation of the employee's absorption of training will certainly influence the need for training.
7. Contractors. Employers who use contractors to perform work in and around processes that involve highly hazardous chemicals, will need to establish a screening process so that they hire and use contractors who accomplish the desired job tasks without compromising the safety and health of employees at a facility. For contractors, whose safety performance on the job is not known to the hiring employer, the employer will need to obtain information on injury and illness rates and experience and should obtain contractor references. Additionally, the employer must assure that the contractor has the appropriate job skills, knowledge and certifications (such as for pressure vessel welders). Contractor work methods and experiences should be evaluated. For example, does the contractor conducting demolition work swing loads over operating processes or does the contractor avoid such hazards?
Maintaining a site injury and illness log for contractors is another method employers must use to track and maintain current knowledge of work activities involving contract employees working on or adjacent to covered processes. Injury and illness logs of both the employer's employees and contract employees allow an employer to have full knowledge of process injury and illness experience. This log will also contain information which will be of use to those auditing process safety management compliance and those involved in incident investigations.
Contract employees must perform their work safely. Considering that contractors often perform very specialized and potentially hazardous tasks such as confined space entry activities and nonroutine repair activities it is quite important that their activities be controlled while they are working on or near a covered process. A permit system or work authorization system for these activities would also be helpful to all affected employers. The use of a work authorization system keeps an employer informed of contract employee activities, and as a benefit the employer will have better coordination and more management control over the work being performed in the process area. A well run and well maintained process where employee safety is fully recognized will benefit all of those who work in the
facility whether they be contract employees or employees of the owner.
8. Pre-Startup Safety. For new processes, the employer will find a PHA helpful in improving the design and construction of the process from a reliability and quality point of view. The safe operation of the new process will be enhanced by making use of the PHA recommendations before final installations are completed. P&IDs are to be completed along with having the operating procedures in place and the operating staff trained to run the process before startup. The initial startup procedures and normal operating procedures need to be fully evaluated as part of the pre-startup review to assure a safe transfer into the normal operating mode for meeting the process parameters.
For existing processes that have been shutdown for turnaround, or modification, etc., the employer must assure that any changes other than "replacement in kind" made to the process during shutdown go through the management of change procedures. P&IDs will need to be updated as necessary, as well as operating procedures and instructions. If the changes made to the process during shutdown are significant and impact the training program, then operating personnel as well as employees engaged in routine and nonroutine work in the process area may need some refresher or additional training in light of the changes. Any incident investigation recommendations, compliance audits or PHA recommendations need to be reviewed as well to see what impacts they may have on the process before beginning the startup.
9. Mechanical Integrity. Employers will need to review their maintenance programs and schedules to see if there are areas where "breakdown" maintenance is used rather than an on-going mechanical integrity program. Equipment used to process, store, or handle highly hazardous chemicals needs to be designed, constructed, installed and maintained to minimize the risk of releases of such chemicals. This requires that a mechanical integrity program be in place to assure the continued integrity of process equipment. Elements of a mechanical integrity program include the identification and categorization of equipment and instrumentation, inspections and tests, testing and inspection frequencies, development of maintenance procedures, training of maintenance personnel, the establishment of criteria for acceptable test results, documentation of test and inspection results, and documentation of manufacturer recommendations as to meantime to failure for equipment and instrumentation.
The first line of defense an employer has available is to operate and maintain the process as designed, and to keep the chemicals contained. This line of defense is backed up by the next line of defense which is the controlled release of chemicals through venting to scrubbers or flares, or to surge or overflow tanks which are designed to receive such chemicals, etc. These lines of defense are the primary lines of defense or means to prevent unwanted releases. The secondary lines of defense would include fixed fire protection systems like sprinklers, water spray, or deluge systems, monitor guns, etc., dikes, designed drainage systems, and other systems which would control or mitigate hazardous chemicals once an unwanted release occurs. These primary and secondary lines of defense are what the mechanical integrity program needs to protect and strengthen these primary and secondary lines of defenses where appropriate.
The first step of an effective mechanical integrity program is to compile and categorize a list of process equipment and instrumentation for inclusion in the program. This list would include pressure vessels, storage tanks, process piping, relief and vent systems, fire protection system components, emergency shutdown systems and alarms and interlocks and pumps. For the categorization of instrumentation and the listed equipment the employer would prioritize which pieces of equipment require closer scrutiny than others. Meantime to failure of various instrumentation and equipment parts would be known from the manufacturers data or the employer's experience with the parts, which would then influence the inspection and testing frequency and associated procedures. Also, applicable codes and standards such as the National Board Inspection Code, or those from the American Society for Testing and Material, American Petroleum Institute, National Fire Protection Association, American National Standards Institute, American Society of Mechanical Engineers, and other groups, provide information to help establish an effective testing and inspection frequency as well as appropriate methodologies.
The applicable codes and standards provide criteria for external inspections for such items as foundation and supports, anchor bolts, concrete or steel supports, guy wires, nozzles and sprinklers, pipe hangers, grounding connections, protective coatings and insulation, and external metal surfaces of piping and vessels, etc. These codes and standards also provide information on methodologies for internal inspection, and a frequency formula based on the corrosion rate of the materials of construction. Also, erosion both internal and external needs to be considered along with corrosion effects for piping and valves. Where the corrosion rate is not known, a maximum inspection frequency is recommended, and methods of developing the corrosion rate are available in the codes. Internal inspections need to cover items such as vessel shell, bottom and head; metallic linings; nonmetallic linings; thickness measurements for vessels and piping; inspection for erosion, corrosion, cracking and bulges; internal equipment like trays, baffles, sensors and screens for erosion, corrosion or cracking and other deficiencies. Some of these inspections may be performed by state or local government inspectors under state and local statutes. However, each employer needs to develop procedures to ensure that tests and inspections are conducted properly and that consistency is maintained even where different employees may be involved. Appropriate training is to be provided to maintenance personnel to ensure that they understand the preventive maintenance program procedures, safe practices, and the proper use and application of special equipment or unique tools that may be required. This training is part of the overall training program called for in the standard.
A quality assurance system is needed to help ensure that the proper materials of construction are used, that fabrication and inspection procedures are proper, and that installation procedures recognize field installation concerns. The quality assurance program is an essential part of the mechanical integrity program and will help to maintain the primary and secondary lines of defense that have been designed into the process to prevent unwanted chemical releases or those which control or mitigate a release. "As built" drawings, together with certifications of coded vessels and other equipment, and materials of construction need to be verified and retained in the quality assurance documentation. Equipment installation jobs need to be properly inspected in the field for use of proper materials and procedures and to assure that qualified craftsmen are used to do the job. The use of appropriate gaskets, packing, bolts, valves, lubricants and welding rods need to be verified in the field. Also procedures for installation of safety devices need to be verified, such as the torque on the bolts on ruptured disc installations, uniform torque on flange bolts, proper installation of pump seals, etc. If the quality of parts is a problem, it may be appropriate to conduct audits of the equipment supplier's facilities to better assure proper purchases of required equipment which is suitable for its intended service. Any changes in equipment that may become necessary will need to go through the management of change procedures.
10. Nonroutine Work Authorizations. Nonroutine work which is conducted in process areas needs to be controlled by the employer in a consistent manner. The hazards identified involving the work that is to be accomplished must be communicated to those doing the work, but also to those operating personnel whose work could affect the safety of the process. A work authorization notice or permit must have a procedure that describes the steps the maintenance supervisor, contractor representative or other person needs to follow to obtain the necessary clearance to get the job started. The work authorization procedures need to reference and coordinate, as applicable, lockout/tagout procedures, line breaking procedures, confined space entry procedures and hot work authorizations. This procedure also needs to provide clear steps to follow once the job is completed in order to provide closure for those that need to know the job is now completed and equipment can be returned to normal.
11. Managing Change. To properly manage changes to process chemicals, technology, equipment and facilities, one must define what is meant by change. In this process safety management standard, change includes all modifications to equipment, procedures, raw materials and processing conditions other than "replacement in kind". These changes need to be properly managed by identifying and reviewing them prior to implementation of the change. For example.
the operating procedures contain the operating parameters (pressure limits, temperature ranges, flow rates, etc.) and the importance of operating within these limits. While the operator must have the flexibility to maintain safe operation within the established parameters, any operation outside of these parameters requires review and approval by a written management of change procedure.
Management of change covers such as changes in process technology and changes to equipment and instrumentation. Changes in process technology can result from changes in production rates, raw materials, experimentation, equipment unavailability, new equipment, new product development, change in catalyst and changes in operating conditions to improve yield or quality. Equipment changes include among others change in materials of construction, equipment specifications, piping pre-arrangements, experimental equipment, computer programs, procedural changes in alarms and interlocks. Employers need to establish methods and methods to detect both technical changes and mechanical changes.
Temporary changes have caused a number of catastrophes over the years, and employers need to establish ways to detect temporary changes as well as those that are permanent. It is important that a time limit for temporary changes be established and monitored since, without control, these changes may tend to become permanent. Temporary changes are subject to the management of change provisions. In addition, the management of change procedures are used to insure that the equipment and procedures are returned to their original or designed conditions at the end of the temporary change. Proper documentation and review of these changes is invaluable in assuring that the safety and health considerations are being incorporated into the operating procedures and the process.
Employers may wish to develop a form or clearance sheet to facilitate the processing of changes through the management of change procedures. A typical change form may include a description and the purpose of the change, the technical basis for the change, safety and health considerations, documentation of changes for the operating procedures, maintenance procedures, inspection, testing, P&IDs, electrical classification, training and communications, pre-startup inspection, duration if a temporary change, approvals and authorization. Where the impact of the change is minor and well understood, a checklist reviewed by an authorized person with proper communication to others who are affected may be sufficient. However, for a more complex or significant design change, a hazard evaluation procedure with approvals by operations, maintenance, and safety departments may be appropriate. Changes in documents such as P&IDs, raw materials, operating procedures, mechanical integrity programs, electrical classifications, etc., need to be noted so that these revisions can be made permanent when the drawings and procedure manuals are updated. Copies of process changes need to be kept in an accessible location to ensure that design changes are available to operating personnel as well as to PHA team members when a PHA is being done or one is being updated.
12. Investigation of Incidents. Incident investigation is the process of identifying the underlying causes of incidents and implementing steps to prevent similar events from occurring. The intent of an incident investigation is for employers to learn from past experiences and thus avoid repeating past mistakes. The incidents for which OSHA expects employers to become aware and to investigate are the types of events which result in or could reasonably have resulted in a catastrophic release. Some of the events are sometimes referred to as "near misses," meaning that a serious consequence did not occur, but could have.
Employers need to develop in-house capability to investigate incidents that occur in their facilities. A team needs to be assembled by the employer and trained in the techniques of investigation including how to conduct interviews of witnesses, needed documentation and report writing. A multidisciplinary team is better able to gather the facts of the event and to analyze them and develop plausible scenarios as to what happened, and why. Team members should be selected on the basis of their training, knowledge and ability to contribute to a team effort to fully investigate the incident. Employees in the process area where the incident occurred should be consulted, interviewed or made a member of the team. Their knowledge of the events form a significant set of facts about the incident which occurred. The report, its findings and recommendations are to be shared with those who can benefit from the information. The cooperation of employees is essential to an effective incident investigation. The focus of the investigation should be to obtain facts, and not to place blame. The team and the investigation process should clearly deal with all involved individuals in a fair, open and consistent manner.
13. Emergency Preparedness. Each employer must address what actions employees are to take when there is an unwanted release of highly hazardous chemicals. Emergency preparedness or the employer's tertiary (third) lines of defense are those that will be relied on along with the secondary lines of defense when the primary lines of defense which are used to prevent an unwanted release fail to stop the release. Employers will need to decide if they want employees to handle the stops for minor incidental releases. Whether they wish to mobilize the available resources at the plant and have them brought to bear on a more significant release. Or whether employers want their employees to evacuate the danger area and promptly escape to a preplanned safe zone area, and allow the local community emergency response organizations to handle the release. Or whether the employer wants to use some combination of these actions. Employers will need to select how many different emergency preparedness or tertiary lines of defense they plan to have and then develop the necessary plans and procedures, and appropriately train employees in their emergency duties and responsibilities and then implement those lines of defense.
Employers at a minimum must have an emergency action plan which will facilitate the prompt evacuation of employees due to an unwanted release of a highly hazardous chemical. This means that the employer will have a plan that will be activated by an alarm system to alert employees when to evacuate and, that employees who are physically impaired, will have the necessary support and assistance to get them to the safe zone as well. The intent of these requirements is to alert and move employees to a safe zone quickly. Delaying alarms or confusing alarms are to be avoided. The use of process control centers or similar process buildings in the process area as safe areas is discouraged. Recent catastrophes have shown that a large life loss has occurred in these structures because of where they have been sited and because they are not necessarily designed to withstand overpressures from shockwaves resulting from explosions in the process area.
Unwanted incidental releases of highly hazardous chemicals in the process area must be addressed by the employer as to what actions employees are to take. If the employer wants employees to evacuate the area, then the emergency action plan will be activated. For outdoor processes where wind direction is important for selecting the safe route to a refuge area, the employer should place a wind direction indicator such as a wind sock or pennant at the highest point that can be seen throughout the process area. Employees can move in the direction of cross wind to upwind to gain safe access to the refuge area by knowing the wind direction.
If the employer wants specific employees in the release area to control or stop the minor emergency or incidental release, these actions must be planned for in advance and procedures developed and implemented. Preplanning for handling incidental releases for minor emergencies in the process area needs to be done, appropriate equipment for the hazards must be provided, and training conducted for those employees who will perform the emergency work when they respond to handle the release. The employer's training program, including the Hazard Communication standard training is to address the training needs for employees who are expected to handle incidental or minor releases.
Preplanning for releases that are more serious than incidental releases is another important line of defense to be used by the employer. When a serious release of a highly hazardous chemical occurs, the employer through preplanning will have determined in advance what actions employees are to take. The evacuation of the immediate release area and other areas as necessary would be accomplished under the emergency action plan. If the employer wishes to use plant personnel such as a fire brigade, spill control team, a hazardous materials team, or use employees to render aid to those in the immediate release area and control or mitigate the incident, these actions are covered by § 1910.120, the Hazardous Waste Operations and Emergency Response
(HAZWOPER) standard. If outside assistance is necessary, such as through mutual aid agreements between employers or local government emergency response organizations, these emergency responders are also covered by HAZWOPER. The safety and health protections required for emergency responders are the responsibility of their employers and of the on-scene incident commander.
Responders may be working under very hazardous conditions and therefore the objective is to have them competently led by an on-scene incident commander and the commander's staff, properly equipped to do their assigned work safely, and fully trained to carry out their duties safely before they respond to an emergency. Drills, training exercises, or simulations with the local community emergency response planners and responder organizations is one means to obtain better preparedness. This close cooperation and coordination between plant and local community emergency preparedness managers will also aid the employer in complying with the Environmental Protection Agency's Risk Management Plan criteria.
One effective way for medium to large facilities to enhance coordination and communication during emergencies for on plant operations and with local community organizations is for employers to establish and equip an emergency control center. The emergency control center would be sited in a safe zone area so that it could be occupied throughout the duration of an emergency. The center would serve as the major communication link between the on-scene incident commander and plant or corporate management as well as with the local community officials. The communication equipment in the emergency control center should include a network to receive and transmit information by telephone, radio or other means. It is important to have a backup communication network in case of power failure or one communication means fails. The center should also be equipped with the plant layout and community maps, utility drawings including fire water, emergency lighting, appropriate reference materials such as a government agency notification list, company personnel phone list, SARA Title III reports and material safety data sheets, emergency plans and procedures manual, a listing with the location of emergency response equipment, mutual aid information, and access to meteorological or weather condition data and any dispersion modeling data.
14. Compliance Audits. Employers need to select a trained individual or assemble a trained team of people to audit the process safety management system and program. A small process or plant may need only one knowledgeable person to conduct an audit. The audit is to include an evaluation of the design and effectiveness of the process safety management system and a field inspection of the safety and health conditions and practices to verify that the employer's systems are effectively implemented. The audit should be conducted or lead by a person knowledgeable in audit techniques and who is impartial towards the facility or area being audited. The essential elements of an audit program include planning, staffing, conducting the audit, evaluation and corrective action, follow-up and documentation.
Planning in advance is essential to the success of the auditing process. Each employer needs to establish the format, staffing, scheduling and verification methods prior to conducting the audit. The format should be designed to provide the lead auditor with a procedure or checklist which details the requirements of each section of the standard. The names of the audit team members should be listed as part of the format as well. The checklist, if properly designed, could serve as the verification sheet which provides the auditor with the necessary information to expedite the review and assure that no requirements of the standard are omitted. This verification sheet format could also identify those elements that will require evaluation or a response to correct deficiencies. This sheet could also be used for developing the follow-up and documentation requirements.
The selection of effective audit team members is critical to the success of the program. Team members should be chosen for their experience, knowledge, and training and should be familiar with the processes and with auditing techniques, practices and procedures. The size of the team will vary depending on the size and complexity of the process under consideration. For a large, complex, highly instrumented plant, it may be desirable to have team members with expertise in process engineering and design, process chemistry, instrumentation and computer controls, electrical hazards and classifications, safety and health disciplines, maintenance, emergency preparedness, warehousing or shipping, and process safety auditing. The team may use part-time members to provide for the depth of expertise required as well as for what is actually done or followed, compared to what is written.
An effective audit includes a review of the relevant documentation and process safety information, inspection of the physical facilities, and interviews with all levels of plant personnel. Utilizing the audit procedure and checklist developed in the preplanning stage, the audit team can systematically analyze compliance with the provisions of the standard and any other corporate policies that are relevant. For example, the audit team will review all aspects of the training program as part of the overall audit. The team will review the written training program for adequacy of content, frequency of training, effectiveness of training in terms of its goals and objectives as well as to how it fits into meeting the standard's requirements, documentation, etc. Through interviews, the team can determine the employee's knowledge and awareness of the safety procedures, duties, rules, emergency response assignments, etc. During the inspection, the team can observe actual practices such as safety and health policies, procedures, and work authorization practices. This approach enables the team to identify deficiencies and determine where corrective actions or improvements are necessary.
An audit is a technique used to gather sufficient facts and information, including statistical information, to verify compliance with standards. Auditors should select as part of their preplanning a sample size sufficient to give a degree of confidence that the audit reflects the level of compliance with the standard. The audit team, through this systematic analysis, should document areas which require corrective action as well as those areas where the process safety management system is effective and working in an effective manner. This provides a record of the audit procedures and findings, and serves as a baseline of operation data for future audits. It will assist future auditors in determining changes or trends from previous audits.
Corrective action is one of the most important parts of the audit. It includes not only addressing the identified deficiencies, but also planning, followup, and documentation. The corrective action process normally begins with a management review of the audit findings. The purpose of this review is to determine what actions are appropriate, and to establish priorities, timetables, resource allocations and requirements and responsibilities. In some cases, corrective action may involve a simple change in procedure or minor maintenance effort to remedy the concern. Management of change procedures need to be used, as appropriate, even for what may seem to be a minor change. Many of the deficiencies can be acted on promptly, while some may require engineering studies or indepth review of actual procedures and practices. There may be instances where no action is necessary and this is a valid response to an audit finding. All actions taken, including an explanation where no action is taken on a finding, needs to be documented as to what was done and why.
It is important to assure that each deficiency identified is addressed, the corrective action to be taken noted, and the audit person or team responsible be properly documented by the employer. To control the corrective action process, the employer should consider the use of a tracking system. This tracking system might include periodic status reports shared with affected levels of management, specific reports such as completion of an engineering study, and a final implementation report to provide closure for audit findings that have been through management of change, if appropriate, and then shared with affected employees and management. This type of tracking system provides the employer with the status of the corrective action. It also provides the documentation required to verify that appropriate corrective actions were taken on deficiencies identified in the audit.
Appendix D to § 1910.119—Sources of Further Information (Nonmandatory)
1. Center for Chemical Process Safety, American Institute of Chemical Engineers, 345 East 47th Street, New York, NY 10017, (212) 708-7319.
2. "Guidelines for Hazard Evaluation Procedures," American Institute of Chemical Engineers; 345 East 47th Street, New York, NY 10017.
3. "Guidelines for Technical Management of Chemical Process Safety," Center for Chemical Process Safety of the American Institute of Chemical Engineers; 345 East 47th Street, New York, NY 10017.
4. "Evaluating Process Safety in the Chemical Industry," Chemical Manufacturers Association; 2501 M Street NW, Washington, DC 20037.
5. "Safe Warehousing of Chemicals," Chemical Manufacturers Association; 2501 M Street NW, Washington, DC 20037.
6. "Management of Process Hazards," American Petroleum Institute (API Recommended Practice 750); 1220 L Street, N.W., Washington, D.C. 20005.
7. "Improving Owner and Contractor Safety Performance," American Petroleum Institute (API Recommended Practice 2220); API, 1220 L Street N.W., Washington, D.C. 20005.
8. Chemical Manufacturers Association (CMA's Manager Guide), First Edition, September 1991; CMA, 2501 M Street, N.W., Washington, D.C. 20037.
9. "Improving Construction Safety Performance," Report A-3, The Business Roundtable: The Business Roundtable, 200 Park Avenue, New York, NY 10166. [Report includes criteria to evaluate contractor safety performance and criteria to enhance contractor safety performance].
10. "Recommended Guidelines for Contractor Safety and Health," Texas Chemical Council; Texas Chemical Council, 1402 Nueces Street, Austin, TX 78701–1534.
11. "Loss Prevention in the Process Industries," Volumes I and II; Frank P. Lees, Butterworth; London 1983.
12. "Safety and Health Program Management Guidelines," 1989; U.S. Department of Labor, Occupational Safety and Health Administration.
13. "Safety and Health Guide for the Chemical Industry," 1986, (OSHA 3091); U.S. Department of Labor, Occupational Safety and Health Administration; 200 Constitution Avenue, N.W., Washington, D.C. 20210.
14. "Review of Emergency Systems," June 1988; U.S. Environmental Protection Agency (EPA), Office of Solid Waste and Emergency Response, Washington, DC 20460.
15. "Technical Guidance for Hazards Analysis, Emergency Planning for Extremely Hazardous Substances," December 1987; U.S. Environmental Protection Agency (EPA), Federal Emergency Management Administration (FEMA) and U.S. Department of Transportation (DOT), Washington, DC 20460.
16. "Accident Investigation * * * A New Approach," 1983, National Safety Council; 444 North Michigan Avenue, Chicago, IL 60611–3991.
17. "Fire & Explosion Index Hazard Classification Guide," 6th Edition, May 1987, Dow Chemical Company; Midland, Michigan 48674.
18. "Chemical Exposure Index," May 1988, Dow Chemical Company; Midland, Michigan 48674.
[FR Doc. 92–3917 Filed 2–21–92; 8:45 am]
BILLING CODE 4510–26–M
The following pages contain the text of the book "The Art of War" by Sun Tzu, translated into English by J. C. Graham. The translation is based on the version published in 1905 by E. J. Holmwood & Co., London.
Part III
Department of Housing and Urban Development
Office of the Assistant Secretary for Housing—Federal Housing Commissioner
24 CFR Part 3280
Manufactured Home Construction and Safety Standards; Proposed Rule
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Office of the Assistant Secretary for Housing—Federal Housing Commissioner
24 CFR Part 3280
[Docket No. R-92-1497; FR-2622-P-01]
RIN 2502-AE66
Manufactured Home Construction and Safety Standards
AGENCY: Assistant Secretary for Housing—Federal Housing Commissioner, (HUD).
ACTION: Proposed rule.
SUMMARY: HUD is proposing to amend the Federal Manufactured Home Construction and Safety Standards (FMHCSS) to include preemptive standards significantly upgrading the existing energy conservation requirements. Additional miscellaneous amendments recommended by the Council of American Building Officials (CABO) and the MHCSS Consensus Committee (MCC) are being proposed.
DATES: Comment due date: May 26, 1992.
FOR FURTHER INFORMATION CONTACT: Donald R. Fairman, Manufactured Housing and Construction Standards Division, Department of Housing and Urban Development, 451 Seventh Street, SW., room 6270, Washington, DC 20410-8000. Telephone (202) 708-0718. [This is not a toll-free number.]
ADDRESSES: Interested persons are invited to submit comments regarding this proposed rule (notice) to the Rules Docket Clerk, Office of General Counsel, room 10276, Department of Housing and Urban Development, 451 Seventh Street, SW., Washington, DC 20410. FAXed comments are not acceptable. Communications should refer to the above docket number and title. A copy of each communication submitted will be available for public inspection and copying between 7:30 a.m. and 5:30 p.m. weekdays at the above address.
SUPPLEMENTARY INFORMATION:
I. Background
The National Manufactured Housing and Construction and Safety Standards Act of 1974, 42 U.S.C. 5401 et. seq. (Act), authorizes the Secretary of Housing and Urban Development (Secretary) to establish and amend the Federal Manufactured Home Construction and Safety Standards (FMHCSS), 24 CFR part 3280 (Standards). The stated purposes of the Act are "to reduce the number of personal injuries and deaths and the amount of insurance costs and property damage resulting from manufactured home accidents and to improve the quality and durability of manufactured homes." 42 U.S.C. 5401. In accordance with the Act and these purposes, the Department is issuing these proposed amendments to the FMHCSS for public comment.
A. Amendment to the National Manufactured Housing Construction and Safety Standards Act of 1974
The Housing and Community Development Act of 1987, 42 U.S.C. 5301, amends the National Manufactured Housing Construction and Safety Standards Act of 1974 (Act) to require preemptive energy conservation standards. The new subsection to section 604 of the Act is reprinted as follows:
(i) (1) The Federal manufactured home construction and safety standards established by the Secretary under this section shall include preemptive energy conservation standards in accordance with this subsection.
(2) The energy conservation standards established under this subsection shall be cost-effective energy conservation performance standards designed to ensure the lowest total of construction and operating costs.
(3) The energy conservation standards established under this subsection shall take into consideration the design and factory construction techniques of manufactured homes and shall provide for alternative practices that result in net estimated energy consumption equal to or less than the specified standards.
To comply with the Act, the Department contracted with the Pacific Northwest Laboratories to assist in developing a revision to the existing energy conservation requirements in the FMHCSS. The developed revision is based upon the requirement to ensure the lowest total construction and operating cost. This revision is being published as a proposed rule for public comment.
Concurrently with the Pacific Northwest Laboratory, the MCC caused an alternative energy conservation standard revision to be developed for the FMHCSS. It was duly submitted to the Secretary by the MCC for consideration. The substance of this alternative is discussed in parallel with the discussion on the proposed rule.
B. Private Organizations Developing Model Manufactured Housing Standards
On July 7, 1982, 47 FR 29605, HUD announced its interest in having a nationally recognized building code or standards organization develop, publish, and maintain model standards which could replace, by reference, all the HUD standards now in the FMHCSS. HUD would retain its responsibility and authority to promulgate and enforce revisions to the FMHCSS by using formal rulemaking procedures. Model standards incorporated by reference in the FMHCSS would then become preemptive and be enforced as a HUD standard.
The decision to select a private standards organization, in response to Federal Register announcement, was postponed in order that the Department could finalize comprehensive revisions to the Standards that the Department had initiated. The notice was re-issued February 13, 1987 at 57 FR 4663. On February 16, 1988, the Department announced at 53 FR 4463 that the Council of American Building Officials (CABO) was selected to initiate the process of developing a model standard for the FMHCSS in the private sector.
Although CABO was selected in response to the notice of February 13, 1987 to develop standards, the Department will consider standards developed by other organizations on an equal basis with standards developed by CABO for incorporation into FMHCSS. The Department does not consider CABO as an exclusive or preferred source of model standards. Other interested organizations were invited to submit model standards for consideration to HUD at any time. The Manufactured Housing Institute (MHI) declared its interest shortly thereafter.
Subsequently, CABO and MHI established separate Manufactured Home Construction and Safety Standards Committees. Recommendations for amendments were developed and submitted to the Department by both committees. Accordingly, the Department is issuing this notice of proposed rulemaking to solicit public comments on these recommendations, as well as other changes the Department feels it is necessary to propose.
C. General Update of the Standards
The Department is still charged with the overall maintenance of the Federal Manufactured Home Construction and Safety Standards. Accordingly, the Department believes it is necessary to
propose changes to the Standards in response to information that is received directly. Most of these changes are for the purpose of clarity. They either incorporate a previously issued interpretive bulletin into the standards or revise the standards to more clearly state the requirements to reflect the manner in which they are being enforced. Other changes, such as those to Subpart A are basically editorial. The Department is initiating a general update of all the standards incorporated by reference.
II. Energy Conservation Standards
A. The legislation passed by congress requires that the Department of Housing and Urban Development revise the FMHCSS to incorporate preemptive energy conservation standards which shall be cost effective and designed to ensure the lowest total of construction and operating costs. The congressional record clarified that the revision is to be based on a life cycle cost analysis taking into consideration the cost of energy conservation (efficiency) measures (ECM) and the energy savings from those measures over the effective physical life of the structures.
The approach used in developing the proposed energy conservation standards revision is a cost-benefit analysis in which the costs of energy conservation measures (ECM) were balanced against the benefits of energy savings. The resulting optimum was used to specify an overall level of energy conservation in terms of a building shell U-value (thermal conductance) that produced the lowest life-cycle cost to the owner of a manufactured home.
Several major activities were accomplished in the development of the proposed energy conservation standards. They are: 1. A life-cycle cost model to determine the optimum ECM investment was developed. 2. The definitions of the ECM, including their cost and "U" value, which could be considered as options were established. 3. The financial, economic, and fuel price parameters used in the life-cycle cost analysis were defined. 4. Separate "U" value optiums were defined for a large number of cities using different energy sources for both single and multi (double) section homes. 5. The resultant "U" values were aggregated in several steps into four "U" value zones, each one having a specified maximum coefficient of heat transmission.
At the direction of Congress the life-cycle cost (LCC) analysis from the consumer's perspective was developed as the basis for revising the HUD thermal standard. The LCC compares the total long-run (present value) dollar costs for an objective achieved through several alternative courses of action and selects the course of action that achieves the objective for the least cost. For this LCC analysis the benefit is the energy savings from the ECM's; and the major cost is the ECM cost, including the associated mortgages, fees, and payments. Maintenance expenses were also included as costs.
The analysis to develop the standard was done with the Automated Residential Energy Standard (ARES) software. The ARES was developed by the U.S. Department of Energy (DOE) specifically for the development of residential energy conservation standards. Given a set of fuel price, financial, economic, and ECM costs for a building at a specific location, ARES identifies the set of ECMs to invest in such that the purchaser's total life-cycle cost is minimized.
Several financial, economic, and fuel price parameters were required for the LCC analysis. Because most homes are purchased with financing, the development of the standard was based on a manufactured home purchased with financing. The loan selected has a 14% mortgage rate over 14 years with a down payment of 15%. This discount rate or alternative investment rate was 12%. The inflation rate was 4.9%. The period of analysis and building lifetime were both 33 years. Each state's average residential fuel price were defined for electricity, fuel oil, natural gas, and LPG. Residential fuel price escalation rates (real) were defined by U.S. census region. Nationally, these annual fuel escalation rates averaged: electricity, 0.0% (constant); fuel oil, 2.5%; natural gas, 2.0%; and liquid petroleum gas (LPG); 2.4%.
The ECM options used in the life-cycle cost analysis are based upon cost data and commercial availability as determined from a survey of about one third of the manufacturing plants in the United States. Single and double-wide homes were considered separately when there were significant differences between the ECM characteristics of the two. The ranges of insulation levels included as options are:
Ceilings................................. R-11 to R-38
Walls........................................... R-7 to R-19
Floors........................................... R-7 to R-22
ECM descriptions and costs were also developed for windows and doors.
Energy Conservation Measures which would lower infiltration were considered, but rejected based on several concerns. Currently new manufactured homes are relatively air-tight, so that a very low natural infiltration rate would result from further tightening. ECM's which could result in very low infiltration rates, can have significant negative impacts on occupant health and compound the problem of condensation control. For these reasons no infiltration control ECMs were considered. The issue of ventilation requirements is addressed as a solution to controlling condensation and indoor air quality separately in II C.
Heating and cooling equipment efficiencies were required for life-cycle cost analysis. The National Appliance and Energy Conservation Act of 1987 (NAECA) minimum standards for heating and cooling system efficiency in manufactured homes were assumed. A procedure to give credit for efficiencies higher than those required by the NAECA was also developed.
Initially, single-and double-wide homes which made use of five specific types of HVAC equipment and fuels were optimized by ARES. The five equipment/fuel types for which optimum U values were produced for each city are: Natural gas with a forced air furnace, LPG with a forced air furnace, oil with a forced air furnace, electric resistance baseboard heaters, and an electric heat pump with forced air distribution. In all cases, an electric air-conditioning system was included.
Rather than selecting a few cities to represent the U.S., all 881 cities available in ARES were used. Selection of all 881 cities included in ARES provided a density of locations such that any point in the U.S. was close to a city for which an optimum U value was produced. This coverage alleviated any bias which might have resulted from selecting a small number of cities to encompass the large area of the country.
The separate HVAC equipment and fuel types were aggregated into U-values for all equipment/fuel types based on the frequency with which each type of equipment was present in each region. Consideration was given to establishing separate fossil and electric U-values, but the combination of all system types was selected as preferable for a number of reasons including simplicity.
After the production of the 881 U-values defined above, the individual U-values were aggregated to four "U" value zones selected as representing the range of optiums found in the U.S. The U-value applicable to each zone was defined as the sales weighted average of the U-values for all states in that zone. The four zones and the U-value requirement associated with each is shown in the proposed rule. Single and double wide U values were determined
to be very similar and were combined into U values for all homes. The zone are designated as Uo zones and the Uo indicates the maximum coefficient of heat transmission that will be acceptable.
The existing Standards divide the country into 3 "U" value Zones. The southern half being Zone I and the northern half Zone II. Alaska is by itself is Zone III. The proposed rule makes Zone II and III into Zone IV except for the States of Kansas, Missouri, Kentucky. The maximum allowed thermal transmission coefficient for most of Zone IV is reduced to 0.079 from 0.126. [The coefficient is expressed as BTUs/(hr)(sq.ft)(F°)]. Alaska is reduced to 0.079 from 0.104.
California, Arizona, New Mexico, Oklahoma, Kentucky, Tennessee, and North Carolina would have a coefficient of 0.096. Kansas, Missouri and Kentucky are presently 0.126, the others would be reduced from 0.157. The rest of the present Zone I states, with the exception of Florida are reduced to 0.109 from 0.157. Florida is reduced to 0.132 from 0.157.
The costs and benefits from the consumer's perspective were estimated to compare homes built to the proposed new rule (national average U value of 0.098) with current practice of the industry (average U value of 0.125 to 0.140) and with the existing FMH/CSS (Title VI) average U value of 0.145. Nationally, the average present value of the net savings of the investment in energy conservation above current practice was about $900 to $1650 per home and that required by Title VI averaged $2000 per home, based on a sales weighted average for each state. (The present value of the net savings sums the total energy savings and deducts all the ECM costs, mortgage costs, and financing costs, putting all values in terms of present dollars). Nationally the cost of incorporating the ECMs above current practice was estimated to average $800 to $1100 per home and above Title VI were estimated to average $1200 per home. The total of the energy savings for current practice ranged from $1800 to $2800 and for Title VI averaged $3200 over the useful life of the home.
To examine the national total present value of the proposed standard, the average new home U-value for the current practice (rather than the Title VI) minimum U-values for a new home was approximated. The national aggregated present value of the savings for each year in which the proposed standard is in effect is estimated to be $300 million. This value would be about $400 million per year if all homes were assumed to be built to the current standard.
Two alternative methods of compliance are suggested for inclusion in the standard. The first alternative method allows a trade-off between investments which lower a home's U-value and investments in high efficiency HVAC equipment. This alternative gives homes a U-value credit for increases in HVAC efficiency, but does not require the use of equipment above the NAEECA standard. The second alternative allows a calculation or simulation of annual energy use to show that a home meets the energy use implicit in the U-value standard.
An appendix to the Standards which will provide one acceptable method for calculating the coefficient of heat transmission has been developed. It will not be mandatory, however, it will indicate a minimum acceptable method for calculating the coefficient of heat transmission (Uo). The appendix document is on file with the Rules Docket Clerk and a copy will be made available to a commentator upon request.
B. The MCC is proposing an alternative energy conservation rule to the one proposed herein. It recommends "U" values, which while significantly more stringent than the existing Title VI standards, are not as stringent as those being proposed.
The significant difference in the optimum "U" value arise from the different assumption used for the time frame used in calculating the life cycle cost. The Department believes the time frame should be based upon the anticipated life of the structures, which for the purposes of the analysis, is 33 years. This is supported by Conference Report 100-426, a statement by Senator Adams in the Congressional Record of November 21, 1987 and in correspondence from Congressman Gonzales. The MCC believes the life cycle cost should be based upon an average length of time the first owner possess the home, which for purposes of their study is 7 years. There are other variations in the two studies, but in general address the cost issues in a very similar manner.
C. Condensation Control and Ventilation Requirements
In conjunction with the proposed energy conservation standards, the Department is proposing amendments to the standards to address the issues of condensation control and indoor air quality. Manufactured homes of today are being constructed with materials and construction systems that require more attention to the problem of dissipating moisture from within the home and from within the ceiling, wall and floor systems. The tighter construction methods employed today have compounded this problem by reducing the natural air flow in and out of these homes. The reduced number of natural air changes per hour raises the concern of how good the indoor air quality is. With the Department issuing proposed new energy conservation standards, the Department believes the issues of condensation control and indoor air quality must also be addressed with corresponding ventilation requirements which are more effective.
To provide adequate ventilation for the interior of the home, the Department is proposing that a combination of mechanical and passive systems be utilized. The ventilation recommendations are from the American Society of Heating, Refrigeration and Air Conditioning Engineers (ASHRAE) Standard No. 62-1989. Each home would be designed with the capability to exchange the indoor air at the rate of 0.35 air changes per hour. In meeting this objective, a mechanical air intake system providing at least 75 cubic feet per minute intake along with a mechanical or passive exhaust system providing at least 50 cubic feet per minute exhaust shall be installed. The higher intake rate is specified to provide a positive pressure within the home. This system maybe integral with any heating or heating and air conditioning system installed in the home or it may be a system that is separate. In either case, the home ventilating system shall be capable of operating independently of the heating or heating and air conditioning function. The system may have automatic controls, but shall be manually operable at the discretion of the home occupants. Bathrooms and kitchens would be required to have mechanical exhaust systems in all homes regardless of any operable window(s) in these rooms. The exhaust rate for kitchens would be 100 cubic feet per minute. The exhaust rate for bathrooms would be 50 cubic feet per minute. These rates are taken from the ASHRAE Standard No. 62-1989.
The other major ventilation change would be to require ventilation of all attic and roof cavities with the exception of single section homes that have metal roofs and no roof underlayment. The Department's review of the research on the subject indicates that attic or roof cavity ventilation is the primary and most reliable method of removing condensation from this area. It also assists in providing a way for
moisture to escape from the home that is not removed by other methods. A 1978 NIST (formerly NBS) study by Burch and Luna, entitled "A Mathematical Model for Predicting Attic Ventilation Rates for Preventing Condensation on Roofing Sheathing" is a prominent study on the subject. The research also indicated that a vapor retarder should be utilized on the warm side of the attic or roof cavity.
The MCC recommendation would require that only homes having a shingled roof be provided with attic or roof cavity ventilation. Their recommended free ventilation area would be at least equal to 1/500 of the attic or roof cavity floor area when a vapor retarder is utilized. They recommended a ratio of 1/250 when a vapor retarder is not used. The Department could not determine any basis for using these ratios or for using ventilation only with shingled roofs.
The Department has concluded that all attic or roof cavities, except those on certain single section homes, should be ventilated with at least 50% of the open free ventilation area in the upper half of the roof cavity with the remainder to be equally dispersed in the eaves or a low location in the gabled ends. It has also been determined that a vapor retarder should be installed on the warm side of the attic or roof cavity. A free ventilation area equal to at least 1/300 of the attic or roof cavity floor area should be provided. It is believed that this ratio as specified in the Council of American Building Officials, One and Two Family Dwelling Code (CABO, 1 and 2 FDC), has been demonstrated as viable.
Alternatively, a mechanical system would be permitted in the attic or roof cavity to provide the ventilation. A minimum rate of 10 air change per hour would be required. This alternative is derived from recommendations published by the Home Ventilating Institute.
In the southern part of the United States in the zone that would be designated as condensation Zone 2, the manufacturer may leave out the vapor barrier provided the free ventilation area is at least equal to 1/150 (ratio specified in the CABO 1 and 2 FDC) of the attic or roof cavity ceiling area. The condensation zone map is derived from ASHRAE Handbook of Fundamentals—1989.
Certain single section manufactured homes would be excluded from the attic and roof cavity ventilation requirements, because the anticipated cost of revising the design of these homes may entail relatively significant increases. For these homes, however, an interior air exchange rate capability of at least 150 cubic feet per minute would be required.
There are several issues remaining which need to be addressed, and for which proposed amendments to the Standards are yet to be developed. These are:
1. Given the need for improved thermal efficiency, should the Standards continue to permit the use of the ventilated walls? Should the Standards limit the use of ventilated walls for use only with metal sided homes?
2. Should the placement and location of vapor retarders in exterior walls be related to the condensation zone in which it is to be located?
Comments are solicited on these issues.
III. General Update of the Standards
A. Reference Standards Update
In order to remain abreast of the industries that utilize those reference standards incorporated in the FMHCSS, the Department is proposing to incorporate the latest edition of those standards, and new relevant standards. The following table lists the reference standards found in the MHCSS by issuing organization. The organization name and address is underlined. The column to the right indicates the section of the Standards where the reference is used. To the left of the Standard, an asterisk (*) indicates that the Standard is updated. An "N" indicates the Standard is new.
| Standards by issuing organization | 24 CFR |
|-----------------------------------|--------|
| Aluminum Association, 900 19th Street NW., Washington, DC 20006 | 3280.304(b)(1). |
| American Architectural Manufacturers Assoc., 1540 East Dandee Rd., Suite 310, Palatine, IL 60067 | 3280.508(e). |
| AAMA 1593.1—1988, Voluntary Test Method for Thermal Transmittance and Condensation Resistance of Windows Doors and Glazed Wall Sections. | 3280.403(b), 3280.403(e), 3280.403(e)(2), 3280.404(b), 3280.405(b), 3280.405(e), 3280.405(e)(2), 3280.404(f), 3280.404(e) |
| AAMA 1701.2—1985, Primary Window and Sliding Glass Door Voluntary Standard for Utilization in Manufactured Housing | 3280.703 |
| AAMA 1702.2—1985, Swinging Exterior Passage Doors Voluntary Standard for Utilization in Manufactured—Housing | 3280.304(b)(1), 3280.305(1) |
| AAMA 1704—1985, Voluntary Standard Egress Window Systems for Utilization in Manufactured—Housing | 3280.304(b)(1), 3280.305(1) |
| American Gas Association, 8501 East Pleasant Valley Road, Cleveland, OH 44131 | 3280.703 |
| AGA Requirements for Gas Connectors for Connection of Fixed Appliances for Outdoor Installation, Park Trailers and Manufactured (Mobile) Homes to the Gas Supply, 3-87 | 3280.304(b)(1), 3280.305(1) |
| American Institute of Steel Construction 400 N. Michigan Avenue, Chicago, IL 60611 | 3280.304(b)(1), 3280.305(1) |
| *AISC S395—1989, Specification for the Design, Fabrications, and Erection of Structural Steel for Buildings | 3280.304(b)(1) |
| American Iron and Steel Institute, 1000 16th Street NW., Washington, DC 20036 | 3280.304(b)(1), 3280.305(1) |
| *AISI—1986 and 1989 addendum, Specification for the Design of Cold-Formed Steel Structural Members | 3280.304(b)(1), 3280.305(1) |
| AISI—1974, Stainless Steel Cold-Formed Structural Design Manual | 3280.304(b)(1), 3280.305(1) |
| AISI—1973, Manual for Structural Applications of Steel Cables for Buildings | 3280.304(b)(1) |
| American National Standards Institute, 1430 Broadway, New York, NY 10018 | 3280.304(a), 3280.604(a) |
| ANSI A112.14.1—1975, Backflow Valves | 3280.604(a) |
| *ANSI/ASME A112.18.1M—1989, Finished and Rough Brass Plumbing Fixture Fittings | 3280.604(a) |
| *ANSI/ASME A112.19.1M—1987, Enamelled Cast Iron Plumbing Fixtures | 3280.604(a) |
| ANSI/ASME A112.19.2(M)—1982, Vitreous China Plumbing Fixtures | 3280.604(a) |
| *ANSI/ASME A112.19.3M—1987, Stainless Steel Plumbing Fixtures | 3280.604(a) |
| Standards by issuing organization | 24 CFR |
|--------------------------------------------------------------------------------------------------|--------|
| ANSI/ASME A112.19.4(M)—1984, Porcelain Enamelled Formed Steel Plumbing Fixtures | 3280.604(a). |
| ANSI A112.19.5—1979, Trim for Water Closet, Bowls, Tanks, and Urinals | 3280.604(a). |
| ANSI/AHA A135.4—1982, Basic Hardboard | 3280.304(b)(1). |
| *ANSI/AHA A135.5—1988, Prefinished Hardboard Paneling | 3280.304(b)(1). |
| ANSI/AHA A135.6—1989, Hardboard Siding | 3280.304(b)(1). |
| ANSI/AITC A190.1—1983, Structural Glued Laminated Timber | 3280.304(b)(1). |
| *ANSI A208.1—1989, Wood Particleboard | 3280.304(b)(1). |
| ANSI/ASME B1.20.1—1983, Pipe Threads, General Purpose (Inch) | 3280.604(a), 3280.703, 3280.705(e), 3280.706(d). |
| *ANSI/ASME B16.3—1985, Malleable Iron Threaded Fittings | 3280.604(a). |
| *ANSI/ASME B16.4—1985, Cast Iron Threaded Fittings | 3280.604(a). |
| *ANSI/ASME B16.15—1985, Cast Bronze Threaded Fittings 125 and 250 Pound | 3280.604(a). |
| *ANSI B16.18—1984, Cast Copper Alloy Solder-Joint Pressure Fittings | 3280.604(b). |
| *ANSI/ASME B16.22—1989, Wrought-Copper and Copper Alloy, Solder-Joint Pressure Fitting | 3280.604(a). |
| ANSI B16.23—1984, Cast Copper Alloy Solder-Joint Drainage Fittings, DWV | 3280.604(a). |
| *ANSI/ASME B16.26—1988, Cast Copper Alloy Fittings for Flared Copper Tubes | 3280.604(a). |
| *ANSI/ASME B16.29—1988, Wrought Copper and Wrought Copper Alloy Solder-Joint Drainage Fittings—DWV | 3280.604(a), 3280.703, 3280.705(b)(1), 3280.706(b)(1). |
| *ANSI/ASME B36.10—1986, Welding and Seamless Wrought Steel Pipe | 3280.803(g). |
ANSI C73.17—1972, Dimension of Caps, Plugs and Receptacles, Grounding Type | 3280.703. |
| ANSI Z21.1—1987, Household Cooking Gas Appliance with addenda Z21.1a—1989 and Z21.1b—1989 | 3280.703. |
| ANSI Z21.5.1—1982, Gas Clothes Dryers Vol. 1, Type 1 Clothes Dryers with Supplement Z21.5.1a—1987 | 3280.703. |
| *ANSI Z21.10.1—1990, Gas Water Heaters Vol. 1, Storage Water Heaters with Input Ratings of 75,000 BTU per hour or Less | 3280.707(d)(2). |
| *ANSI Z21.11—1987, Manually Operated Gas Valves | 3280.703. |
| ANSI Z21.19—1983, Refrigerators Using Gas Fuel | 3280.703. |
| ANSI Z21.20—1985, Automatic Gas Ignition Systems and Components | 3280.703. |
| *ANSI Z21.21—1987, Automatic Valves for Gas Appliances with addenda Z21.21a—1989 | 3280.703. |
| *ANSI Z21.22—1986, Relief Valves and Automatic Gas Shutoff Devices for Hot Water Supply Systems | 3280.604(a), 3280.703. |
ANSI Z21.23—1989, Gas Appliance Thermostats | 3280.703. |
| *ANSI Z21.24—1987, Metal Connectors for Gas Appliances | 3280.702(a)(17), 3280.703. |
ANSI Z21.40.1—1981, With Addenda 1a—1982 Gas Fired Absorption Summer Air Conditioning Appliances | 3280.703, 3280.714(a)(2). |
| *ANSI Z21.47—1989, Gas-Fired Central Furnaces [Except Direct Vent and Separated Combustion System Central Furnaces] | 3280.703. |
| *ANSI Z21.64—1988, Direct Vent Central Furnaces, with addenda Z21.64a—1989 and Z21.64b—1989 | 3280.703. |
| ANSI Z34.1—1987, For Certification—Third Party Certification Program | 3280.403(e)(1), 3280.405(e)(1). |
ANSI Z37.1—1984, Safety Performance Specifications and Methods of Test for Safety Glazing Materials Used in Building | 3280.114(b), 3280.304(b)(1), 3280.403(d)(1), 3280.604(a), 3280.607(b)(3)(iii). |
*ANSI Z124.1—1987, Plastic Bathtub Units with addenda Z124.1a—1990 | 3280.604(a). |
*ANSI Z124.2—1987, Plastic Shower Receptors and Shower Stalls | 3280.604(a). |
*ANSI Z124.3—1986, Plastic Lavatories | 3280.604(a). |
*ANSI Z124.4—1986, Plastic Water Closets, Bowls and Tanks with addenda Z124.4a—1990 | 3280.604(a). |
*ANSI Z223.1—1988, National Fuel Gas Code | 3280.703. |
American Plywood Association, P.O. Box 11700, Tacoma, WA 98401
*APA—E—30, APA Design/Construction Guide, Residential and Commercial | 3280.304(b)(1). |
*APA—H—815, Design and Fabrication of All-Plywood Beams, Suppl. 5 | 3280.304(b)(1). |
*APA—Y—510, Plywood Design Specification | 3280.304(b)(1). |
*APA—S—812, Design and Fabrication of Plywood Lumber Beams, Suppl. 2 | 3280.304(b)(1). |
*APA—S—811, Design and Fabrication of Plywood Curved Panels, Suppl. 1 | 3280.304(b)(1). |
*APA—U—814, Design and Fabrication of Plywood Sandwich Panels, Suppl. 4 | 3280.304(b)(1). |
*APA—U—813, Design and Fabrication of Plywood Stressed Skin Panels, Suppl. 3 | 3280.304(b)(1). |
*APA PRP E—445, Performance Standards and Policies for Structural Use Panels | 3280.304(b)(1). |
Air Conditioning and Refrigeration Institute, 1501 Wilson Boulevard, Arlington, VA 22209-2403
(N) Standard 210/240—89 Unitary Air Conditioning and Air Source Unitary Heat Pump Equipment | 3280.511(b), 3280.703, 3280.714(a)(1), 3280.714(a)(1)(ii), 3280.714(a)(1)(iii). |
American Society of Heating, Refrigeration and Air Conditioning Engineers, 1791 Tullie Circle, NE., Atlanta, GA 30329
*ASHRAE, 1989, Handbook of Fundamentals | 3280.508, 3280.511. |
American Society of Civil Engineers, 345 East 47th Street, New York, NY 10017-2398
(N) ASCE 7—88 Minimum Design Loads for Buildings and other Structures | 3280.304(b)(1). |
American Society of Mechanical Engineers, 345 E. 47th Street, New York, NY 10017
*ASME Boiler and Pressure Vessel Code, Section VIII, Division 1, "Rules for Construction of Pressure Vessels", 1986 | 3280.704(b)(2). |
(N) ASME/ANSI A112.1.2—1942(R 1979) Air Gaps in Plumbing Systems | 3280.604(a). |
(N) ASME/ANSI A112.19.7—1987 Whirlpool Bathtub Appliances | 3280.604(a). |
(N) ASME/ANSI A112.19.8—1987 Suction Fittings for use in swimming pools, wading pools, spas, hot tubs, and whirlpool bathtub appliances | 3280.604(a). |
(N) ASME/ANSI A112.21.3M—1984 Hydrants for Utility and Maintenance Use | 3280.604(a). |
(N) ASME/ANSI A112.26.1M—1984 Water Hammer Arrestors | 3280.604(a). |
| Standards by issuing organization | 24 CFR |
|----------------------------------|--------|
| American Society of Sanitary Engineering, P.O. Box 40362, Bay Village, OH 44140 | |
| ANSI/ASSE 1001–1990 Pipe Applied Atmospheric Type Vacuum Breakers | 3280.604(a) |
| ANSI/ASSE 1002–1986 Water Closet Flush Tank Fill Valves (Ballcocks) | 3280.604(a) |
| ANSI/ASSE 1006–1986 Household Dishwashers, Plumbing Requirements for | 3280.604(a) |
| ANSI/ASSE 1007–1986 Plumbing Requirements for Home Laundry Equipment | 3280.604(a) |
| ANSI/ASSE 1008–1980 Household Food Waste Disposer Units, Plumbing Requirements for | 3280.604(a) |
| ANSI/ASSE 1011–1985 Hose Connection Vacuum Breakers Wall Hydrants, Freezeless Automatic Draining | 3280.604(a) |
| ANSI/ASSE 1012–1990 Handheld Showers | 3280.604(a) |
| ANSI/ASSE 1016–1990 Manual Thermostatic Pressure Balancing and Combination Control Valves for Bathing Facilities | 3280.604(a) |
| ANSI/ASSE 1017–1978 Thermostatic Mixing Valves, Self Actuated For Primary Domestic Use. | 3280.604(a) |
| ANSI/ASSE 1019–1978 Wall Hydrants, Freezeless Automatic Draining Anti-Backflow Types | 3280.604(a) |
| ANSI/ASSE 1023–1979 Hot Water Dispensers, Household Storage Type Electrical Plumbing Requirements for | 3280.604(a) |
| ANSI/ASSE 1025–1978 Diverter for Plumbing Faucets with Hose Spray Anti-Siphon Type Residential Applications; Pref. Requirements | 3280.604(a) |
| ANSI/ASSE 1037–1990 Pressurized Fixtures Flushing Devices (Flushometers) | 3280.604(a) |
| American Society for Testing and Materials, 1616 Race Street, Philadelphia, PA 19103 | |
| ASTM A 53–90a, Standard Specification for Pipe, Steel, Black and Hot-Dipped, Zinc-Coated, Welded and Seamless | 3280.604(a), 3280.703 |
| ASTM A 74–87, Standard Specification for Cast Iron Soil Pipe and Fittings | 3280.604(a) |
| ASTM A 539–90a, Standard Specification for Electric-Resistance-Welded Coiled Steel Tubing for Gas and Fuel Oil Lines | 3280.703, 3280.705(b)(4) |
| ASTM B 42–89, Standard Specification for Seamless Copper Pipe, Standard Sizes | 3280.604(a), 3280.703 |
| ASTM B 43–88, Standard Specification for Seamless Red Brass Pipe, Standard Sizes | 3280.604(a), 3280.705(b)(1) |
| ASTM B 88–89(m), Standard Specification for Seamless Copper Water Tube [metric] | 3280.604(a), 3280.703, 3280.705(b)(3), 3280.705(b)(3) |
| ASTM B 251–88(m) Standard Specification for General Requirements for Wrought Seamless Copper and Cooper-Alloy Tubes [metric] | 3280.604(a), 3280.703 |
| ASTM B 280–88, Standard Specification for Seamless Copper Tube for Air Conditioning and Refrigeration Field Service | 3280.703, 3280.705(b)(3), 3280.706(b)(3) |
| ASTM B 308–88, Standard Specification for Copper Drainage Tube (DWV) | 3280.604(a) |
| ASTM C 36–88, Standard Specification for Gypsaum Wallboard | 3280.304(b)(1) |
| ASTM C 564–88, Standard Specification for Rubber Gaskets for Cast Iron Soil Pipe and Fittings | 3280.604(a), 3280.611(d)(5) |
| ASTM D 781–88 (73), Standard Test Methods for Puncture and Stiffness of Paperboard, and Corrugated and Solid Fiberboard | 3280.304(b)(1), 3280.305(g)(4) |
| ASTM D 2016–74 (83), Standard Test Methods for Moisture Content of Wood | 3280.304(b)(1) |
| ASTM D 2235–88, Standard Specification for Solvent Cement for Acrylonitrile-Butadiene-Styrene (ABS) Plastic Pipe Fittings | 3280.604(a) |
| ASTM D 2564–88, Standard Specification for Solvent Cement for Poly (Vinyl Chloride (PVC) Plastic Pipe Fittings | 3280.604(a) |
| ASTM D 2661–90, Standard Specification Acrylonitrile-Butadiene Styrene (ABS) Plastic Drain, Waste and Vent Pipe and Fittings | 3280.604(a) |
| ASTM D 2665–89a, Standard Specification for Poly (Vinyl Chloride) (PVC), Plastic Drain, Waste, and Vent Pipe and Fittings | 3280.604(a) |
| ASTM 2848–90, Standard Specification for Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Hot and Cold Water Distribution Systems | 3280.604(a) |
| ASTM D 3313–89a, Standard Specification for Polybutylene (PB) Plastic Hot and Cold Water Distribution Systems | 3280.604(a) |
| ASTM D 3314–89, Standard Specification for Drain, Waste and Vent (DWV) Plastic Fitting Patterns | 3280.604(a) |
| ASTM E 84–89a, Standard Test Method for Surface Burning Characteristics of Building Materials | 3280.203(a) |
| ASTM E 182–87, Standard Test Method for Surface Flammability of Materials Using Radiant Heat Energy Source | 3280.203(a) |
| ASTM E 773–88 Standard Test Method for Seal Durability of Sealed Insulating Glass Units | 3280.403(d)(2) |
| ASTM E 774–88 Standard Specification for Sealed Insulating Glass Units | 3280.403(d)(2) |
| ASTM E–1333–90 Standard Test Method for Determining Formaldehyde levels from wood products under defined test conditions using a large chamber. | 3280.406(b) |
| ASTM F 628–90 Standard Specification for Acrylonitrile-Butadiene-Styrene (ABS) Plastic Drain, Waste, and Vent Pipe Having a Foam Core. | 3280.604(a) |
Cast Iron Soil Pipe Institute, 5959 Shallowfind Rd., Suite 419, Chattanooga, TN 37421
* CISPI-301–90, Standard Specification for Hubless Cast Iron Soil Pipe and Fittings for Sanitary and Storm Drain, Waste, and Vent Piping Applications. | 3280.604(a) |
* CISPI–310–90, Specification for Cast Iron Soil Pipe Institute’s Approved Coupling for Use in Connection with Hubless Cast Iron Soil Pipe and fittings for Sanitary and Storm Drain, Waste, and Vent Piping Applications. | 3280.604(a) |
* CISPI–HSN–85, Specification for Neoprene Rubber Gaskets for HUB and Spigot Cast Iron Soil Pipe and Fittings. | 3280.604(a), 3280.611(d)(5). |
Federal Specification, General Services Administration, Specification Branch, Room 6039, GSA Building, 7th & D Sts., S.W., Washington, DC 20407
L–P–320–B–1973, With 1977 Amendment 1, Pipe and Fittings, Plastic (Polyvinyl Chloride (PVC), Drain, Waste and Vent (DWV) | 3280.604(a) |
FF–N–105B–1971 With 1977 Amendment 4, Nails Brads, Staples and Spikes, Wire, Cut and Wrought | 3280.304(b)(1) |
QQ–S–781H–1974, With 1977 Amendment 2 and Notice 1, Strapping, Steel, and Seals | 3280.304(b)(1), 3280.306(g)(2) |
WW–N–351–C–1976 With 1977 Interim Amendment 1, Nipples, Pipe, Threaded | 3280.604(a) |
WW–P–401E–1974, Pipe and Pipe Fittings, Cast-Iron, Soil | 3280.604(a) |
WW–P–541E/GEN–1980, Plumbing Fixtures (General Specifications) | 3280.604(a) |
(N) MSVIFSD–86 Valve, Gate, Bronze, (125, 150 and 200 Pound Threaded Ends, Flange Ends, Solder End and Bronze Ends, for Land Use), ZZ–R–765B–1970, With 1971 Amendment 1, Rubber Silicone. | 3280.611(d)(5). |
Hardwood Plywood Manufacturers Association, P.O. Box 2789, 1825 Michael Faraday Drive, Reston, VA 22090
* HPMA–HP–SG–86, Structural Design Guide for Hardwood Plywood Wall Panels | 3280.304(b)(1) |
* ANSI/HPMA HP–1983, Hardwood and Decorative Plywood | 3280.304(b)(1) |
HUD-FHA Use of Materials Bulletin, Department of Housing and Urban Development, 451 7th Street SW., Washington, DC 20410–8000
HUD-FHA Use of Materials Bulletin—UM–25d–73 Application and Fastening Schedule: Power-Driven, Mechanically Driven and Manually Driven Fasteners. | 3280.304(b)(1) |
| Standards by issuing organization | 24 CFR |
|----------------------------------|--------|
| IIT Research Institute, 10 West 35th Street, Chicago, IL 60616 | 3280.207(a)(4). |
| J 6461, Development of Mobile Home Fire Test Methods to Judge the Fire-Safe Performance of Foam Plastic Sheathing and Cavity Insulation. | |
| International Association of Plumbing and Mechanical Officials, 20001 Walnut Drive South, Walnut, CA 91789-2825 | 3280.604(a). |
| IAMPO/PS-2-1989, Material and Property Standard for Cast Brass and Tubing | 3280.604(a). |
| P-Traps IAMPO/PS-4-1990, Material and Property Standard for Drains for Prefabricated and Precast Showers | 3280.604(a). |
| IAMPO/PS-5-1984, Material and Property for Special Cast Iron Fittings | 3280.604(a). |
| IAMPO/PS-9-1984, Material and Property Standard for Diversion Tees and Twin Waste Elbow | 3280.604(a). |
| IAMPO/PS-14-1989, Material and Property Standard for Flexible Copper Water Connectors | 3280.604(a). |
| IAMPO/PS-31-1991, Material and Property Standard for Dishwasher Drain Airgaps (Air Breaks) | 3280.604(a). |
| *IAMPO/PS-23-1989, Material and Property Standards for Backflow Prevention Devices | 3280.604(a). |
| IAMPO/TSC-9-1985, Standard for Gas Supply Connectors for Manufactured Mobile Homes | 3280.703. |
| IAMPO/TSC-22-1985, Standard for Porcelain Enamelled Formed Steel Plumbing Fixtures | 3280.604(a). |
| Military Specifications, Naval Publications Information center, 5801 Tabor Road, Philadelphia, PA 19120 | 3280.611(d)(5). |
| MIL-L-10547E-1975, Liners, Case, and Sheet Overwrap; Water-Vapor Proof or Waterproof, Flexible | |
| National Fire Protection Association, Batterymarch Park, Quincy, MA 02269 | 3280.703. |
| *NFPA 31-1987, Installation of Oil Burning Equipment | 3280.703. |
| *NFPA-54-1988, National Fuel Gas Code | 3280.707(F). |
| *NFPA-58-1989, Storage and Handling Liquefied Petroleum Gases | 3280.703. |
| *NFPA-70-1990, National Electrical Code | 3280.704(b)(5)(i). |
| 3280.801 (a) and (b) |
| 3280.8093(k)(1), |
| 3280.8053(k)(3), |
| 3280.8053(q)(3)(v), |
| 3280.8063(c)(2), |
| 3280.808(a), |
| 3280.808(m), |
| 3280.811(b). |
| NFPA-20B-1980, Warm Air Heating and Air Conditioning Systems | 3280.703. |
| *NFPA-220-1985, Standard Types of Building Construction | 3280.202(a) (4) and (5). |
| National Forest Products Association, 1250 Connecticut Avenue, NW., Washington, DC 20036 | 3280.304(b)(1). |
| Span Tables for Joists and Rafter (PS-20-70) (N) FPA-1977 | 3280.304(b)(1). |
| *National Design Specifications for Wood Construction (N) FPA-1986 with Supplement Design Value for Wood Construction 1988. | 3280.304(b)(1). |
| *Wood Structural Design Data (N) FPA-1986. | 3280.304(b)(1). |
| *Design Values for Joists and Rafters (N) FPA-1986. | 3280.304(b)(1). |
| National Sanitation Foundation, P.O. Box 1468, Ann Arbor, MI 48105 | 3280.604(b). |
| *NSF-14-1991, Plastic Piping Components and Related Materials | 3280.604(b). |
| NSF-24-1988, Plumbing System Components for Mobile Homes and Recreational Vehicles | 3280.604(b). |
| National Wood Window and Door Association, 1400 E. Touhy Avenue, Suite G-54, Des Plaines, IL 60018 | 3280.304(b)(1). |
| *ANSI/NWWDA I.S.1-87, Wood Flush Doors | 3280.304(b)(1). |
| 3280.405(c)(2). |
| *ANSI/NWWDA I.S.2-87, Wood Window Units Window Units | 3280.304(b)(1). |
| NWWDA-I.S.3-86, Wood Sliding Patio Doors | 3280.304(b)(1). |
| NWWDA-I.S.4-81, Water Repellent Preservative Non Pressure Treatment for Millwork | 3280.304(b)(1). |
| 3280.405(c)(2). |
| U.S. Department of Commerce, National Institute of Standards and Technology Standards, Office of Engineering Standards, Room A-166, Technical Building, Washington, DC 20234 | 3280.304(b)(1). |
| PS-1-1983, Construction and Industrial Plywood | 3280.304(b)(1). |
| Society of Automotive Engineers, 400 Commonwealth Drive, Warrendale, PA 15096 | 3280.703. |
| SAE-J533b, Flares for Tubing (1972) | 3280.705(f)(1). |
| 3280.705(f)(2). |
| Steel Joint Institute, 1205 48 Avenue N., Myrtle Beach, SC 29577 | 3280.304(b)(1). |
| *SJI-1990, Standard Specifications Load Tables and Weight Tables for Steel Joists and Joist Girder | 3280.304(b)(1). |
| Truss Plate Institute, 583 D’Onofrio Drive, Suite 200, Madison, WI 53719 | 3280.304(b)(1). |
| TPI-1985, Design Specifications for Metal Plate Connected Wood Trusses | 3280.304(b)(1). |
| Underwriter’s Laboratories, Inc., 333 Pfingsten Road, Northbrook, IL 60062 | 3280.715(e)(1). |
| *UL 94 Fourth Edition 1991 Test for Flammability of Plastic Materials for Parts in Devices and Appliances | 3280.715(e)(1). |
| UL 109—Seventh Edition—1989, as Chimneys, Factory Built Residential Type and Building Heating Appliance | 3280.703. |
| UL 109—Fourth Edition—1978, Tube Fittings for Flammable and Combustible Gases, Refrigeration Service, and Marine Use | 3280.703. |
| *UL 127—Sixth Edition—1988, as amended through 1991, Factory-Built Fireplaces | 3280.703. |
| UL 174—Seventh Edition—1989, as amended through 1991, Household Electric Storage Tank Water Heater | 3280.703. |
| UL 181—Seventh Edition—1990, Factory Made Air Ducts and Connectors | 3280.703. |
| 3280.715(e). |
| *UL 217—Third Edition—1985, as amended through 1989, Single and Multiple Station Smoke Detectors | 3280.208(c). |
| *UL 307A—Sixth Edition—1990, Liquid Fuel-burning Heating Appliances for Mobile Homes and Recreational Vehicle | 3280.703. |
| 3280.707(f). |
| *UL 307(B)—First Edition 1982, as amended through 1987, Gas Burning Heating Appliances for Mobile Homes and Recreational Vehicles | 3280.703. |
| *UL 311—Seventh Edition 1990, Roof Jacks for Mobile Homes and Recreational Vehicles | 3280.703. |
| *UL 441—Seventh Edition—1991, Gas Vents | 3280.703. |
| *UL 465—Seventh Edition—1982, as amended through 1987, Central Cooling Air Conditioners | 3280.703. |
| *UL 559—Fourth Edition—1985, as amended through 1987, Heat Pumps | 3280.703. |
The following Standards would be deleted from the FMHCSS as they are obsolete and have been withdrawn by the issuing organization:
- ANSI C72.1 1972, Household Automatic Storage Type Water Heaters
- ARI Standard 210-81 for Unitary Air Conditioning Equipment
- ARI Standard 240-81 for Air Sound Unitary Heat Pump Equipment
- ASTM A120-83 Standard Specifications for Pipe, Block Hot dipped Zinc Coated (Galvanized) Welded and Seamless for Ordinary Uses.
- CISPI 310-85
- FTM-2-1985 Large Scale Test Method for Determining Formaldehyde Emissions from Wood Products.
- ANSI A58.1–1982 Building Code Requirements for Minimum Design Loads in Buildings and other structures.
- GAL Standard for Fireplace Stoves for installation in Mobile Structures
B. Other Proposed Amendments
Amendments are being proposed to the Standards in response to recommendations submitted by the respective Manufactured Home Construction and Safety Standards Committees of CABO and the MCC. Other amendments are being proposed by the Department in response to needs identified from working with the Standards. Following is a discussion of those changes by section.
Section 3280.1 Scope
This section is amended to delete those requirements pertaining to waivers and interpretive bulletins. These requirements would be relocated in new §§ 3280.8 and 3280.9 respectively.
Section 3280.2 Definition
Old paragraph (2) definition of "center", is deleted because it does not appear in the FMHCSS.
New paragraph (2) is added to provide definition of a "Bay Window". The definition is needed to establish minimum square footage of the home for coverage under the Act.
Old paragraph (4) "Combustible material" is deleted as the definition conflicts with the preferred definition of "combustible materials" in § 3280.202(a)(1).
Old paragraph (5) "defect" and (10) by "imminent safety hazard" are deleted. They are more appropriate located in 24 CFR part 3282, the Manufactured Home Procedural and Enforcement Regulations.
Section 3280.3 Acceptance of Plans
The existing Section is deleted and replaced with a new Section titled "Procedural and Enforcement Regulations and Consumer Manual Requirements".
Section 3280.4 Incorporation by Reference
Paragraph (a) is amended to clarify that reference standards have the same force and effect as the FMHCSS.
Paragraph (b) is amended to provide an updated list of the names and address of those organizations whose standards are referenced in the FMHCSS.
Section 3280.5 Data Plate
This change recommended by the MHI Standards Committee incorporates the language of interpretive bulletin A-2-77 on the durability requirements for data plates. A new requirement to provide the Departments certification label(s) number(s) to the data plate is also being proposed.
Section 3280.8 Waivers
A new Section is being proposed to set forth the requirements for waivers that were previously located in § 3280.1. The changes substantially incorporate the MCC Standards Committee's recommendation except that the Department prefers to retain the term "waiver" as opposed to using the new terminology "determination of equivalency."
Section 3280.9 Interpretative Bulletins
A new Section is being proposed to set forth the provision on interpretative bulletins previously located in § 3280.1.
Section 3280.10 Use of Alternative Construction
A new Section is being proposed to clarify that certain homes that do not conform to the FMHCSS in all respects are permissible when certain criteria found in the Procedural and Enforcement Regulations are followed. This is a MCC recommendation.
Section 3280.11 Certification Label
This Section has been renumbered from § 3280.8. Additionally, certain language pertaining to transition labels used at the time the FMHCSS were implemented that is no longer needed is being deleted.
Section 3280.103 Interior Light and Ventilation
This section would be editorially amended to present the lighting requirements separately from the ventilation requirements. The lighting requirements would be in paragraph (a) and the ventilation requirements in paragraphs (b), (c), (d), and (e).
The lighting requirements in paragraph (a) would reflect the following revisions. The use of artificial light in place of exterior windows would be permitted now for laundry areas, utility rooms, and storage rooms. It would be permissible to combine the space of adjoining rooms to meet the lighting requirements provided at least 50 percent of the common wall area is open and the open wall area is at least equal to 10 percent of the combined floor area. The CABO Standards Committee recommended the second change.
Paragraph (b) would reflect the following revisions to the present requirements. Each home would be capable of having sufficient ventilation to provide .35 air changes per hour, have a mechanical system which would intake 75 cubic feet of air a minute, and an exhaust system capable of exhausting 50 cubic feet of air per minute. (Refer also to the general write up on condensation control and ventilation.)
Paragraph (c) would specify the revised kitchen ventilation requirements. The present requirements specify an air change every 30 minutes. The new requirements would specify the capability to exhaust at the rate of 100 cubic feet per minute.
Paragraph (d) would specify the revised bathroom and toilet
compartment ventilation requirements. The present requirements specifies an air change every 12 minutes. The new requirements would specify the capability to exhaust at the rate of 50 cubic feet per minute.
In paragraphs (c) and (d) the changes would reflect that ventilation through openable windows would not meet these new requirements except for a toilet compartment.
Paragraph (e) would establish a ventilation rate of 10 cubic feet per minute for all rooms, other than bathrooms, toilet compartments and kitchens, that do not have exterior walls.
Section 3280.105 Exit Facilities
Paragraph (b)(2) would be amended to incorporate interpretative bulletin B–1–76 which clarifies that swinging exterior doors stops may not reduce the clear opening to less than 73 inches in height and 27 inches in width.
Section 3280.109 Space Planning
The existing section does not provide any identifiable requirements, and therefore is being deleted.
Section 3280.112 Hallways
Existing § 3280.113 would be renumbered as § 3280.112 and a new paragraph (b) would be added incorporating interpretative bulletin B–3–76. This would clarify that an interior door shall have at least 27 inches clear width if the interior door must be passed through to reach an exterior door. This would not apply to interior passage doors which only provide interior access to another room or other interior area.
Section 3280.203 Flame Spread Limitations and Fire Protection Requirements
Paragraph (a) would be editorially amended to include that list of materials which need not be flame spread tested in accordance with ASTM E–84 or ASTM E–162. This list was inadvertently deleted from the FMHCSS when the February 12, 1987 amendments were published.
Paragraph (b)(4) would be amended to clarify that vertical surface within 6 inches horizontally of the cooking range are subject to flame spread and combustibility requirements pertaining to cooking range areas.
Section 3280.208 Fire Detection Equipment
Paragraph (d) would be amended to permit locating smoke detectors on walls at a distance permitted by the smoke detector's listing.
Section 3280.303(g) Alternate Test Procedures
The section would be amended editorially. The revised rule clarifies that the Department will assess the adequacy of this test.
Section 3280.304 Materials Reference Standards Would be Updated
Refer to previous reference Standards table.
Section 3280.305 Structural Design Requirements
Paragraph (c), at the recommendation of the MCC, would be amended to incorporate interpretative bulletin D–3–76. It clarifies that roof slopes of 20 degrees or less may be excluded from the horizontal wind calculation.
Paragraph (d) would be amended to incorporate interpretative bulletin D–5–76 at the recommendation of the MCC. It clarifies that the deflection limit for cantilevered roof section is 2 times the length divided by 180. Additionally, it would be clarified that the uplift loads specified in § 3280.305(c)(1) and (2) are required by § 3280.305(c)(3)(ii) to be increased by a factor of 2.5.
Paragraph (f)(2) would be amended at the recommendation of the MCC to incorporate interpretative bulletin D–6–76. This permits increasing the allowed stress on interior walls by 1.33.
Paragraph (g)(2) would be amended at the recommendation of the MCC to incorporate the provisions of interpretative bulletin D–8–76. This clarifies the application of coverings and sealants to wood floors subject to moisture.
A new paragraph (g)(3) would be added to permit the installation of carpet in a laundry space when the laundry appliances are not provided with the home.
Section 3280.306 Windstorm Protection
Paragraph (a) would be amended at the recommendation of the MCC to incorporate interpretative bulletin D–7–76. This clarifies that 1.5 factor of safety is only applied to the tie down system and it is not required to be applied to the structure of the home.
Section 3280.309 Health Notice on Formaldehyde Emission
Paragraph (b), at the recommendation of the MCC, would be amended to delete the requirement that the title be printed with the color red.
Paragraph (d) would be amended to correctly cite 24 CFR part 3283 rather than 24 CFR part 3282 which is incorrect.
Section 3280.401 Structural Load Test
Paragraph (b) would be amended to clarify that 2.5 is the lowest factor of safety that will be acceptable when testing under the ultimate load test procedures. This clarification is based upon interpretive bulletin E–1–76.
Section 3280.504 Condensation Control and Installation of Vapor Retarders
Paragraph (a) would be revised to permit the ceiling vapor retarder to be omitted in the southern condensation zone, Zone II, when the attic or roof cavity ventilation open area is at least equal to 1/150 of the attic or roof cavity floor area.
A new paragraph (b) would be incorporated to require all attic and roof cavities to be ventilated. Paragraph b(1) would specify the minimum free ventilation area equal to 1/300 of the attic or roof cavity or permit a mechanical system capable of changing the air ten times in an hour.
A new paragraph (b)(2) would exclude single section homes with metal roofs having no roof underlayment from the requirements of paragraph (b)(1) providing the interior of the home can be ventilated at the rate of 150 cubic feet per minute and extra steps are taken to seal the roof cavity from interior moisture migration.
A new paragraph (b)(3) would specify that 50 to 60 percent ventilation free area will be in the upper half of the attic or roof cavity.
A new paragraph (b)(4) would establish the condensation zones and refer to a new figure 1 which would indicate the zones on the map of the United States.
A new paragraph (b)(5) would specify that the free ventilation area shall be designed to prevent the entry of rain, snow and insects.
Section 3280.506 Heat Loss
This section would be amended to use the term "U" Value Zones" in place of "Winter Design Temperature Zones." The section would be amended to incorporate the maps designating the "U Value Zones" of which there are four.
Paragraph (a) would be amended to incorporate the following "Maximum Transmission Coefficients": Zone 4–0.079, Zone 3–0.096, Zone 2–0.109, and Zone 1–0.132. The coefficient is in terms of Btu/(hr)(sq. ft.) (degree F).
Paragraph (c) would be amended to require storm window or insulating glass for homes designated for Zone 4.
(The proposed amendments to significantly improve the overall Heat Loss characteristics of manufactured
homes are described in more detail in the previous discussion.)
Section 3280.508 Heat Loss, Heat Gain and Cooling Load Calculations
It is proposed to amend this section to incorporate the applicable section of the 1989 edition of the ASHRAE Handbook of Fundamentals and a new paragraph incorporating an appendix to the Standards which will outline an acceptable heat loss/heat gain method (see previous discussion on Energy Condensation II a).
Section 3280.510 Heat Loss Certificate
It is proposed to amend the certificate to be compatible with the revised Zones being proposed.
Section 3280.511 Comfort Cooling Certificate and Information
It is proposed to amend the certificate to be compatible with the revised Zones being proposed.
Section 3280.802 Definitions
It is proposed to add the definitions of (1) Flushometer tank; (2) Plumbing appliance; (3) Plumbing appurtenance; (4) Whirlpool bathtub.
Section 3280.803 General Requirements
Paragraph (a)(5) would be amended to clarify the applicability the reference standards. It would further clarify that in absence of an appropriate standards being specified, the plumbing component is to be listed as suitable for the intended use.
Section 3280.804 Materials
Paragraph (a) would be amended to incorporate the updated reference standards discussed previously.
Paragraph (b) would be amended to clarify that where two standards for a component are indicated, it is only necessary to conform to one of them except when evaluation of toxicity is necessary.
Section 3280.804 Materials
At the recommendation of CABO, several new standards are being proposed for inclusion into the reference standard tables. Refer to write up on reference standards.
Section 3280.806 Traps and Clean-outs
Paragraph (b)(1)(iii) would be amended at the recommendation of CABO to permit the removal of a water closet to provide the clean out access to the drain lines.
Section 3280.807 Plumbing Fixtures
Paragraph (b) would be amended to delete several references to the term "toilet" and replace with the term "water closet".
Paragraph (b)(4) would be amended to permit the use of high loop in the drain system of a dishwasher. Additional clarification is also added on the use of a standpipe for a dishwasher.
Paragraph (c) would be amended to incorporate interpretive bulletin G-2-77(a) to clarify that fixture diverter valves do not require direct access.
At the recommendation of CABO, it is proposed to add new paragraphs (c)(5) and (c)(6). (c)(5) would specify that the hot water supply to a fixture faucet, fitting, or diverter shall always be on the left. (c)(6) adds criteria for access and installation of Whirlpool bathtub drainage systems.
Section 3280.809 Water Distribution Systems
Paragraph (b)(5) and (b)(6) would be amended to change references from "toilets" to "water closets".
At the recommendation of CABO, a new paragraph (b)(7) is being proposed to require exterior hose bibs to be protected by a listed non-removable backflow prevention device.
At the recommendation of CABO, a new paragraph (b)(8) is being proposed to require flushometer tanks to be installed with an air gap or vacuum breaker located above the fixture flood level.
Paragraph (d)(1)(i) would be amended to delete the terminology "approved or listed" and replaced with "listed". The term approved is redundant as all plastic plumbing components must be listed.
Paragraph (e)(3) would be amended to clarify that any solder used in the water distribution system shall not contain more than 0.2 percent lead.
Section 3280.810 Drainage Systems
Paragraph (c)(5) would be amended to clarify the manufacturers responsibilities for drainage systems which require on site assembly. The clarification assures that the manufacturer provides all the materials and appropriate installation instructions.
Paragraph (d) and (e) would be amended to use the term "water closet" instead of "toilet".
Section 3280.812 Test and Inspection
Paragraph (b)(3) would be amended to use the term "water closet" instead of "toilet".
Section 3280.702 Definitions
At the recommendation of CABO, the definition of "Connector gas", paragraph (a)(17) would be amended to be more descriptive as to its function and delete the referenced to a specific reference standard.
Section 3280.703 Minimum Standards
It is proposed to amend this section by clarifying that compliance with only one of the incorporated reference standards suffice to met the requirement of the FMHCSS.
The table would be amended to incorporate the latest edition of the standard reference. Refer to the previous write up on reference standards.
Section 3280.705 Gas Piping System
At the recommendation of the MCC, paragraph (c) requirements for gas line interconnection of multiple unit Section of manufactured homes would be amended to permit permanent pipe and listed connectors. In addition, the Department is proposing that a shut off valve be required when connectors are utilized.
Section 3280.705 is amended to delete the table for gas line systems that are sized for liquified petroleum (LP) gas only. It is being proposed that all gas lines be sized to handle both LP and natural gas. Other references to LP only systems are being deleted from Subpart H.
At the recommendation of CABO, paragraph (1)(2) would be amended to clarify that appliance connectors may be installed through openings in cabinetry walls.
Paragraph (1)(2)(ii) and (1)(3) would be amended to clarify that shut off valves for appliances are to conform to ANSI Z21.15-1989 and are to be of the non-displaceable rotor type.
Section 3280.708 Exhaust Duct System and Provision for the Future Installation of a Clothes Dryer
Paragraphs (b)(3) and (c)(1) would be amended to incorporate the requirements for a roughed in moisture lint exhaust system which are currently provided by interpretive bulletin H-1-77.
Section 3280.709 Installation of Appliances
Paragraph (e)(6) would be amended to incorporate the requirements of interpretive bulletin H-2-76. This clarifies the manufactured home manufacturers responsibilities in preparing the home to connect external heating or combination cooling/heating appliances at the set-up site.
Section 3280.710 Venting, Ventilation and Combustion Air
Paragraph (b)(1) would be amended to incorporate the requirements of interpretive bulletin H–2–78 as amended on February 27, 1979. This permits that section of a fuel fired heating appliance vent that is above the roof line to be shipped loose and installed at the set-up site.
Section 3280.713 Accessibility
It is proposed to amend this section to clarify that the gas risers to an appliance may be removable to permit replacement of the appliance.
Section 3280.714 Appliance Cooling
At the recommendation of the MCC, it is proposed to incorporate new paragraph (a)(4) and (a)(5) to clarify the testing and certification requirements for cooling and heat pump coils that are installed in a furnace or heating appliance. The certification shall insure that they are rated in combination with the heating appliance or furnace, and in combination with the outdoor section of the system. Additional language has been included to insure that safety is addressed and to implement the Department of Energy procedures.
Section 3280.715 Circulating Air System
It is proposed to amend paragraph (b)(4) to clarify the area calculation for return air when doors are undercut for this purpose. Specifically, it clarifies that the measurement is made from the hard floor deck and not the carpet surface.
Subpart I. Electrical Systems
It is proposed to update all references to the National Electrical Code NFPA no. 70, to incorporate the 1990 edition of that document. CABO and MCC both recommended this change.
Section 3280.801 Scope
Paragraph (c) would be amended to editorially change references to 115/230 volts to 120/240 volts. This would make the FMHCSS consistent with the National Electrical Code.
Section 3280.804(j) Disconnecting Means and Branch Circuit Protection Equipment
Paragraph (j) would be amended to correct the editorial error on the tag for the power supply entrance. The blank space for the correct ampere rating is being repositioned.
A new paragraph (k) would be added to clarify that a common main disconnect is used services and distribution equipment that it shall be rated and listed as suitable for service equipment.
A new paragraph (l) would be added to provide a service entrance tag that is compatible with a 3 wire service connection.
Section 3280.805 Branch Circuit Required
Paragraph (a)(2) would be amended to no longer require the family room to be supplied with a small appliance branch circuit. This would make the FMHCSS compatible with article 220-4 of the NEC.
Paragraph (a)(3)(ii) would be amended editorially to clarify the circuits with motor loads, or any continuous duty load may not have a load that exceeds 80 percent of the branch circuit rating.
Paragraph (a)(3)(v) would be amended to clarify that a laundry area must be provided with a 20 ampere circuit dedicated for laundry room use only.
Section 3280.806 Receptacle Outlets
Paragraph (b) would be editorially amended to specify that receptacles in compartments accessible from the outdoors are required to be ground fault protected. It is being editorially removed from paragraph (d)(8) to alleviate the confusion over whether or not such a receptacle can be considered the required outdoor receptacle.
Paragraph (c) would also be amended to clarify that dedicated laundry receptacles provided in areas that are part of a bathroom are not required to have a ground fault protection.
Paragraph (d)(1) at the recommendation of CABO would be amended to permit a duplex receptacle to simultaneously serve as the dedicated outlet for a refrigerator and a counter top.
Paragraph (d)(7) would be amended to clarify that the receptacle in a laundry area is to be within 6 feet of the intended location of the appliance(s).
Paragraph (d)(8) would be amended to delete the language pertaining to receptacles located in compartments accessible from the outdoors. It is being located in paragraph (b).
Section 3280.807 Fixtures and Appliances
Paragraph (c) would be amended to cross reference Article 410-4(d) of the National Electrical Code. This article clarifies that no hanging or pendant type fixture may be installed within 3 feet horizontally or eight feet vertically of a bathtub rim.
Paragraph (e) would be amended to permit the use of “limited combustible” material as a fixture flash ring as “limited combustible” is currently defined and permitted in subpart C.
Existing paragraph (g) would be deleted. These provisions apply to the installation of hydro massage bathtubs. Previously, when the 1984 edition of the National Electrical Code was referenced, hydro massage bathtubs would have been treated as hot tubs or spas unless special consideration was provided. The 1990 edition of the National Electrical Code provides appropriate criteria for installing hydro massage bathtubs. Accordingly, those provisions in the FMHCSS are no longer necessary.
Section 3280.808 Wiring Methods and Materials
A new paragraph (g) would be added to incorporate the provision of interpretive bulletin I–1–80 to provide the performance requirements for a substantial brace used to support electrical outlet boxes.
A new paragraph (r) would be added to establish a limit of \( \frac{3}{8} \) inch as the permissible oversize limit for close fitting of electrical boxes in combustible walls and ceilings. \( \frac{3}{8} \) inch is the limit currently being enforced.
A new paragraph(s) would be added to clarify that N.M. cable sheathing can be repaired provided the conductors are not damaged.
Section 3280.809 Grounding
Paragraph (b)(1) would be amended to clarify that when service equipment is installed on manufactured homes, it is permissible to have the ground and neutral buses in the distribution panel remain interconnected.
Section 3280.810 Electrical Testing
Paragraph (a) would be amended to incorporate interpretive bulletin I–1–78. This clarifies the acceptable range of voltages that can be used and exactly which conductors must be tested against each other during the dielectric test.
Paragraph (b) would be amended to revise the operational check to exclude major listed appliances from the check and would revise the polarity test to permit visual inspection.
Section 3280.811 Calculations
Numerous references to voltage would be changed to read 120/240 volts from 115/230 volts.
Section 3280.813 Outdoor Outlets, Fixtures and Air Conditioning Equipments
It is proposed to amend paragraph (a) to specify a listing for outdoor fixtures
and equipment of "suitable for use in wet locations."
C. Recommendations Not Adopted
1. Many of the recommendations provided by the CABO committee dealt with reference Standards. Two of these reference standards were not included because the Department could not verify that they were the latest edition or the most appropriate edition. AISC–S326–1978 is not listed in the AISC literature as having a 1986 supplement. FS ZZ R 765C–86 is listed in the source document from the General Services Administration. However, it does not replace 765B–1970 which is also listed.
2. CABO recommended that a definition of "direct vent" system be included in Subpart H. However, the Department believes that the more stringent definition of "sealed combustion" is needed for the FMHCSS.
3. The MCC recommended that a provision be incorporated stating reference standards shall be reviewed and updated every 3 years. The Department concludes, however, this is a policy and operational concern and not a standards issue.
4. The MCC recommended that the additional words "Important Document, Do not remove, alter or destroy" be added to the Data Plate. The Department does not believe that a problem has been identified which would justify making the addition.
5. The MCC recommended that the term "Waiver" be replaced with the term "Determination of Equivalency". The Department prefers "waiver". However, it would consider the alternative if public comment supported the change.
6. The MCC recommended that the Standard specify that the Department respond to all requests for alternative test procedure approval within 60 days. The Department does not object to 60 days. However, it considers turn around time to be an administrative issue and not a regulatory matter.
7. The MCC recommended that a formaldehyde emission standard be set for medium density fiberboard. The Department, however, believes that since the real question of how critical the threat from formaldehyde is yet to be resolved, that it would be premature to propose a rule at this time.
8. In § 3280.401(b) the procedures for ultimate load test would be amended to incorporate interpretative bulletin E–176. The Department could not accept the entire MCC recommendation in this change. The Department believes that for the alternative load test a factor of safety of 2.5 or greater is necessary. Also, the Department believes that the failure criteria—rupture, fracture, and excessive yielding are determinable and should be retained.
9. The MCC proposal for a revised test procedure for roof trusses is presently being reviewed by the Department. It would be the Department's intention to incorporate an amended procedure, such as proposed by the MCC, upon being assured that the procedure is adequate.
10. The MCC proposed definitions for "single package system" and "heat pump split system". This proposal was not accepted as a basis for their need isn't foreseen. Further, there may be the potential for conflict with future Department of Energy directive on this subject.
11. The MCC proposed that the mandatory enforcement dates for water heater, furnace, air conditioner and heat pump appliance energy efficiency standards prescribed by the National Appliance Energy Conservation Act be specified in the FMHCSS. The Department believes it is more appropriate to issue a notice to announce that the Department of Energy rules supersede those of the Department.
12. The MCC proposed that smoke detectors be allowed on ceilings. The Department recognizes that other building codes permit this location. However, data has not been presented to indicate that the dead air space found at the ceilings of manufactured home is any less of a problem that it was 13 years ago.
13. The MCC proposed condensation control measures for ceilings/roof cavities to include natural and mechanical ventilation means. The levels proposed by the MCC, however, are less than generally recognized workable levels. Due to insufficient data being presented, the Department is proposing levels that are higher than those recommended by the MCC.
D. Comments Requested
Comments are requested on the proposed energy conservation amendments to assist the Department in implementing the 1987 amendment to the National Manufactured Home Construction and Safety Standards Act. Of particular concern to Congress is that the cost be based upon the impact on the consumer. Accordingly, data which can assist in more accurately defining the economic effects as required by the amendment to the Act is requested.
Specific comments are requested on two of the financial parameters (i.e., discount rate and fuel price escalation rates) used to develop the level of insulation required in the proposed energy conservation amendments.
The discount rate or alternative investment rate used to develop the proposed standard was 12% (7% real discounting for inflation of 5%). In addition to the proposed maximum U-values, the department has evaluated maximum U-value requirements based on alternative real investment rates of 4 and 10 percent.
The appropriate alternative investment rate is not the rate of interest at which the affected population can borrow to finance investments in energy efficiency nor is it the rate it can earn in a savings account. Rather, it is the rate of return required of equivalent investments. It is in the new home buyer's self interest to invest in only those energy conservation measures that pay a rate of return greater than or equal to that of an alternative investment that exhibits equivalent characteristics, including both liquidity (ease with which they can be converted to cash) and risk.
Generally, the more risky and the more illiquid any investment, the greater the rate of return investors will require. Most investments in energy conservation measures are highly illiquid, long-term investments. Further, they are subject to some risk since they depend on unknown factors, such as future energy prices and weather patterns. The required rate of return of such investments may be relatively high. In light of these observations, the department seeks comment on the appropriate discount rate.
The national fuel price escalation rates used to develop the proposed standard averaged: Electricity, 0.0%; (constant); fuel oil, 2.5%; natural gas, 2.0%; and liquid petroleum gas (LPG), 2.4%. These rates were based on long term projections from the Federal Energy Management Program (FEMP) and are similar to projections from the Energy Information Administration (EIA). Other fuel price escalation rates for which an argument could be made include using 0.0% escalation based on the fact that some (real) fuel prices have held fairly constant over the last several years and projecting them this would hold true for the future.
The impact on the maximum U-value requirements of the alternative discount rates and fuel price escalation rates are shown below:
Comments are also solicited on all areas of the Standards. In addition to those changes specifically proposed, the Department is soliciting information relating to the following problem areas.
Numerous requests have been made to clarify the safety glazing requirements. A need to identify the locations requiring safety glazing is indicated. Additionally, suggestions have been received asking that certain decorative and design considerations be excluded from the safety glazing requirements. Comments are requested on this subject.
The existing standards require that an outdoor heat tape receptacle outlet cannot be protected by a ground fault circuit interruptor because numerous cases of nuisance tripping were reported. More recent input indicates that the nuisance tripping problem has been rectified. Further, it has been suggested that a ground fault circuit interrupter should be required to reduce the probability of fires from improperly installed heat tapes. Comments are requested on this issue.
Findings and Certification
A Finding of No Significant Impact with respect to the environment has been made in accordance with HUD regulations at 24 CFR part 50, which implement section 120(2)(C) of the National Environmental Policy Act of 1969. The Finding of No Significant Impact is available for public inspection between 7:30 a.m. and 5:30 p.m. weekdays in the Office of the Rules Docket Clerk at the above address.
This rule does constitute a "major rule" as that term is defined in section 1(d) of the Executive Order on Federal Regulation issued by the President on February 17, 1981. An analysis of the rule indicates that it does: (1) Have an annual effect on the economy of $100 million or more, (2) cause a major increase in costs or prices for consumers and individual industries. It does not cause a major increase in cost or prices for Federal, State, or local government agencies, or geographic regions. It does not have a significant adverse effect on competition, employment, investment, productivity, innovation, or on the ability of United States-based enterprises to compete with foreign-based enterprises in domestic or export markets. The Regulatory Impact Analysis is available for public inspection between 7:30 a.m. and 5:30 p.m. weekdays in the Office of the Rules Docket Clerk at the above address.
Under 5 U.S.C. 605(b) (the Regulatory Flexibility Act), the Undersigned hereby certifies that this proposed rule does not have a significant economic impact on a substantial number of small entities. As required by the Act, this proposed rule must balance the increased cost with real savings in energy cost.
This rule is listed as sequence number 1394 under the Office of Housing in the Department's semiannual agenda of regulations published on October 21, 1991 (56380, 53406) under Executive Order 12291 and the Regulatory Flexibility Act.
Executive Order 12612, Federalism
The General Counsel, as the Designated Official under section 6(a) of Executive Order 12612, Federalism, has determined that the policies contained in this rule will not have substantial direct effects on States or their political subdivisions, or the relationship between the Federal government and the States, or on the distribution of power and responsibilities among the various levels of government. As a result, the rule is not subject to review under the Order.
Specifically, the requirements of this rule are directed to manufacturers and do not impinge upon the relationship between the Federal government and State and local governments.
Executive Order 12808, The Family
The General Counsel, as the Designated Official under Executive Order 12808, The Family, has determined that this rule does not have potential for significant impact formation, maintenance, and general well-being, and thus, is not subject to review under the Order. The rule involves requirements for property improvements and manufactured home loans insured by the Department. Any effect on the family would likely be indirect and insignificant.
List of Subjects in 24 CFR Part 3280
Fire prevention, Housing standards, Incorporation by references, Manufactured homes.
Accordingly, it is proposed to amend 24 CFR part 3280 as follows:
PART 3280—MANUFACTURED HOME CONSTRUCTION AND SAFETY STANDARDS
1. The authority citation for 24 CFR part 3280 is revised to read as follows and the authority citations following all of the sections in part 3280 are removed:
Authority: Secs. 604 and 625 of the National Manufactured Housing Construction and Safety Standards Act of 1974 (42 U.S.C. 5403 and 5424); Sec. 7(d), Department of Housing and Urban Development Act (42 U.S.C. 3535(d)).
Subpart A—General
2. Section 3280.1 is proposed to be revised to read as follows:
§ 3280.1 Scope.
This standard covers all equipment and installations in the design, construction, transportation, fire safety, plumbing, heat-producing and electrical systems of manufactured homes which are designed to be used as dwelling units. This standard seeks to the maximum extent possible to establish performance requirements. In certain instances, however, the use of specific requirements is necessary.
3. Section 3280.2 is proposed to be amended by removing the paragraph designations from the section, by revising the introductory paragraph, by removing the definitions for "Center," "Combustible Material," "Defect," and "Imminent safety hazard," and by adding in alphabetical order the definition for "Bay Window," to read as follows:
§ 3280.2 Definitions.
Definitions in this subpart are those common to all subparts of the standard and are in addition to the definitions provided in individual parts. The definitions are as follows:
* * * * *
Bay Window—a window assembly whose maximum horizontal projection is not more than two feet from the plane of an exterior wall and is elevated above the floor level of the home.
* * * * *
4. Section 3280.3 is proposed to be revised to read as follows:
§ 3280.3 Manufactured Home Procedural and enforcement regulations and manufactured home consumer manual requirements.
A manufacturer must comply with the requirements of this part and in addition must comply with the requirements of 24 CFR Parts 3282 Manufactured Home Procedural and Enforcement Regulation and 3283 Manufactured Home Consumer Manual Requirements.
5. Section 3280.4 is proposed to be amended by revising paragraphs (a) and (b) to read as follows:
§ 3280.4 Incorporation by reference.
(a) The specifications, standards and codes of the following organizations are incorporated by reference in this Standard pursuant to 5 U.S.C. 552(a) and 1 CFR part 51 as though set forth in full. The incorporation by reference of these standards has been approved by the Director of the Federal Register. Reference standards have the same force and effect as this Standard except that whenever reference standards and this Standard are inconsistent, the requirements of this Standard prevail to the extent of the inconsistency.
(b) The abbreviations, and addresses of organizations issuing the referenced standards appear below. Reference standards which are not available from their producer organizations may be obtained from the Office of Manufactured Housing and Construction Standards, Manufactured Housing Standards Division, U.S. Department of Housing and Urban Development, 451 Seventh Street, SW., Washington, DC 20410.
AA—Aluminum Association, 900 19th Street NW., Suite 300, Washington, D.C. 20006
AAMA—American Architectural Manufacturers Association, 1540 East Dundee Road, Palatine, Illinois 60067
AGA—American Gas Association, 8501 East Pleasant Valley Road, Cleveland, Ohio 44131
AISI—American Iron and Steel Institute, 1000 16th Street, NW., Washington, DC 20036
AITC—American Institute of Timber Construction, 11618 SE Mill Plain Blvd., suite 415, Vancouver, Washington 98684
ANSI—American National Standards Institute, 1430 Broadway, New York, New York 10018
APA—American Plywood Association, P.O. Box 11700, Tacoma, Washington 98411
ARI—Air Conditioning and Refrigeration Institute, 1501 Wilson Blvd, 6th Floor, Arlington, Va 22209-2403
ASCE—American Society of Civil Engineers, 345 East 47th Street, New York, New York 10017–2398
ASHRAE—American Society of Heating, Refrigeration and Air Conditioning Engineers, 1791 Tulie Circle, NE., Atlanta, Georgia 30329
ASME—American Society of Mechanical Engineers, 345 East 47th Street, New York, New York 10017
ASSE—American Society of Sanitary Engineering, P.O. Box 40362, Bay Village, Ohio 44140
ASTM—American Society for Testing and Materials, 1916 Race Street, Philadelphia, Pennsylvania 19103
CISPI—Cast Iron Soil Pipe Institute, 5959 Shallowford Road, Suite 419, Chattanooga, TN 37421
FS—Federal Specifications, General Services Administration, Specifications Branch, room 6039, GSA Building, 7th and D Streets, SW., Washington, DC 20407
HPMA—Hardwood Plywood Manufacturers Association, P.O. Box 2788, Reston, Virginia 22090
HUD-FHA—Department of Housing and Urban Development, 451 Seventh Street, SW., Washington, DC 20410
IAPMO—International Association of Plumbing and Mechanical Officials, 20001 Walnut Drive South, Walnut, CA 91784–2825
ITRI—IT Research Institute, 10 West 35th Street, Chicago, Illinois 60616
MIL—Military Specifications and Standards, Naval Publications and Forms Center, 5801 Tabor Avenue, Philadelphia, Pennsylvania 19120
NFPA—National Fire Protection Association, Batterymarch Park, Quincy, Massachusetts 02269
[NJ]EPA—National Forest Products Association, 1250 Connecticut Avenue, NW., Washington, DC 20036
NIST—National Institute of Standards and Technology, Office of Engineering Standards Technical Building, Washington, DC 20234
NPA—National Particleboard Association, 18928 Premiere Court, Gaithersburg, Maryland 20879
NSF—National Sanitation Foundation, P.O. Box 1468, Ann Arbor, Michigan 48105
NWWDA—National Wood Window and Door Association, 1400 E. Toughty Avenue, suite G–54, Des Plaines, Illinois 60018
PS—Product Standards, U.S. Government Printing Office, Washington, DC 20410
SAE—Society of Automotive Engineers, 400 Commonwealth Drive, Warrendale, Pennsylvania 15096
SJ—Steel Joist Institute, suite A, 48 Avenue North, Myrtle Beach, South Carolina 29577
TPL—Truss Plate Institute, 583 D’Onofrio Drive, suite 200, Madison, Wisconsin 53719
UL—Underwriters’ Laboratories, Inc., 333 Pfingsten Road, Northbrook, Illinois 60062.
* * * * *
6. Section 3280.5 is proposed to be revised as follows:
§ 3280.5 Data plate.
Each manufactured home shall bear a data plate affixed in a permanent manner near the main electrical panel or other readily accessible and visible location. Data plates shall be made of material which will receive typed information as well as preprinted information and which can be cleared of ordinary smudges or household dirt without removing information contained thereon; or, they shall be covered in a permanent manner with materials which will make it possible to clean them of ordinary dirt and smudges without obscuring the information. Data plates shall contain not less than the following information:
(a) The name and address of the manufacturing plant in which the manufactured home was manufactured.
(b) The serial number and model designation of the unit and the date the unit was manufactured.
(c) The statement, “This manufactured home is designed to comply with the Federal manufactured home construction and safety standards in force at the time of manufacture.”
(d) A list of the certification label(s) number(s) which are affixed to each transportable manufactured section under § 3280.8.
(e) A list of major factory-installed equipment including the manufacturer’s
name and the mode designation of each appliance.
(f) Reference to the structural zone and wind zone for which the home is designed and duplicates of the maps as set forth in § 3280.305(c)(4). This information may be combined with the heating/cooling certificate and insulation zone maps required by §§ 3280.510 and 3280.511.
(g) The statement: "Design Approval by" followed by the name of the agency which approved the design.
* * * * *
7. The existing § 3280.8 is proposed to be amended by redesignating it to be a new § 3280.11 and by revising paragraph (c) of the new § 3280.11 to read as follows:
§ 3280.11 Certification label.
* * * * *
(c) The label shall read as follows:
As evidenced by this label No. ABC 000001, the manufacturer certifies to the best of the manufacturer's knowledge and belief that this manufactured home has been inspected in accordance with the requirements of the Department of Housing and Urban Development and is constructed in conformance with the Federal manufactured home construction and safety standards in effect on the date of manufacture. See date plate.
* * * * *
8. Part 3280, subpart A, is proposed to be amended by adding new §§ 3280.8, 3280.9, and 3280.10 to read as follows:
§ 3280.8 Waivers.
(a) Where any material piece of equipment, or system which does not meet precise requirements or specifications set out in the standard is shown, to the satisfaction of the Secretary, to meet an equivalent level of performance, the Secretary may waive the specifications set out in the Standard for that material, piece of equipment, or system.
(b) Where the Secretary is considering issuing a waiver to a Standard, the proposed waiver shall be published in the Federal Register for public comment, unless the Secretary, for good cause, finds that notice is impractical, unnecessary or contrary to the public interest, and incorporates into the waiver that finding and a brief statement of the reasons therefor.
(c) Each proposed and final waiver shall include:
(1) A statement of the nature of the waiver; and
(2) Identification of the particular standard affected.
(d) All waivers shall be published in the Federal Register and shall state their effective date. Where a waiver has been issued, the requirements of the Federal Standard to which the waiver relates may be met either by meeting the specifications set out in the Standard or by meeting the requirements of the waiver published in the Federal Register.
§ 3280.9 Interpretative bulletins.
Interpretative bulletins may be issued for the following purposes:
(a) To clarify the meaning of the Standard; and
(b) To assist in the enforcement of the Standard.
§ 3280.10 Use of alternative construction.
Requests for alternative construction can be made pursuant to 24 CFR 3282.14 of this chapter.
Subpart B—Planning Considerations
9. Section 3280.103 is proposed to be revised as follows:
§ 3280.103 Light and ventilation.
(a) Lighting. Each habitable room shall be provided with exterior windows and/or doors having a total glazed area of not less than 8 percent of the gross floor area.
(1) Kitchens, bathrooms, toilet compartments, laundry area, utility rooms and storage rooms may be provided with artificial light in place of windows.
(2) Rooms and areas may be combined for the purpose of providing the required natural lighting provided that at least one half of the common wall area is open and unobstructed, and the open area is at least equal to 10 percent of the combined floor area or 25 square feet whichever is greater.
(b) Ventilation. Every manufactured home shall be designed and constructed with ventilation provisions that are capable of providing a minimum of .35 air changes per hour. The following criteria is required for this purpose:
(1) A mechanical air intake system capable of providing at least 75 cubic feet per minute (cfm) that is operable independently of any other system with which it is intended to function.
(2) At least half of the glazed area required by paragraph (a) shall be openable directly to the outside of the manufactured home for unobstructable ventilation. These same ventilation requirements apply to rooms combined in accordance with § 3280.103(a)(2).
(3) Each manufactured home shall be provided with a ventilation system capable of providing a continuous exhaust of at least 50 cfm to the outside of the manufactured home. The system shall be in addition to the exhaust ventilation required for bathrooms and kitchens. The system may either be passive or mechanical. A mechanical system shall be provided with a manual control in addition to any automatic controls. It shall be operable independently of any other system with which it is intended to operate except it may operate with the intake system required in (b)(1) above.
(c) Kitchens shall be provided with a mechanical ventilation system that is capable of exhausting 100 cfm to the outside of the home. The exhaust fan shall be located as close as possible to the range or cooktop, but in no case further than 10 feet from the range or cooktop.
(d) Each bathroom and separate toilet compartment shall be provided with a mechanical ventilation system capable of exhausting 50 cfm to the outside of the home. A separate toilet compartment may be provided with 1.5 square feet of openable glazed area in place of mechanical ventilation.
(e) A room [refer to § 3280.103(a)(1)] which does not have an exterior wall shall be provided with artificial light and a mechanical ventilation system capable of exhausting 10 cfm. The system may be integral with the whole house ventilation system specified in § 3280.103(b)(3).
10. Section 3280.105 is proposed to be amended by revising paragraph (b)(2) to read as follows:
§ 3280.105 Exit facilities: exterior doors.
* * * * *
(b) * * *
(2) All exterior swinging doors shall provide a minimum 28 inch wide by 74 inch high clear opening, which may be determined by measuring the door itself. However the door stops may not reduce the clear opening to less than 27 inches wide and 73 inches high. All exterior sliding glass doors shall provide a minimum 28 inch wide 72 inch high clear opening.
§ 3280.109 [Removed]
11. Section 3280.109 is proposed to be removed.
§ 3280.110 [Redesignated as § 3280.109]
12. Existing § 3280.110 is proposed to be redesignated as § 3280.109.
§ 3280.111 [Redesignated as § 3280.110]
13. Existing § 3280.111 is proposed to be redesignated as § 3280.110.
§ 3280.112 [Redesignated as § 3280.111]
14. Existing § 3280.112 is proposed to be redesignated as § 3280.111.
§ 3280.112 Hallways.
(a) Hallways shall have a minimum horizontal dimension of 28 inches measured from the interior finished surface to the interior finished surface of the opposite wall. When appliances are installed in a laundry area, the measurement shall be from the front of the appliance to the opposite finished interior surface. When appliances are not installed and a laundry area is provided, the area shall have a minimum clear depth of 27 inches in addition to the 28 inches required for passage. In addition, a notice of the available clearance for washer/dryer units shall be posted in the laundry area. Minor protrusions into the minimum hallway width by doorknobs, trim, smoke detectors or light fixtures are permitted.
(b) An interior door placed in a hallway or any path necessary to reach an exterior door (not including any access door to the hallway from any other space) shall have a minimum clear width opening of 27 inches for egress.
§ 3280.114
16. Existing § 3280.114 is proposed to be redesignated as § 3280.113.
Subpart C—Fire Safety
17. Section 3280.202 is proposed to be revised as follows:
§ 3280.202 Definitions.
The following definitions are applicable to subparts C, H, and I of the Standards:
Combustible material: Any material not meeting the definition of limited-combustible or non-combustible material.
Flame-spread rating: The measurement of the propagation of flame on the surface of materials or their assemblies as determined by recognized standard tests conducted as required by this subpart.
Interior finish: The surface material of walls, fixed or movable partitions, ceilings, columns, and other exposed interior surfaces affixed to the home's structure including any materials such as paint or wallpaper and the substrate to which they are applied. Interior finish does not include:
(1) Trim and sealant 2 inches or less in width adjacent to the cooking range and in furnace and water heater spaces provided if it is installed in accordance with the requirements of § 3280.203(b)(3) or (4), and trim 6 inches or less in width in all other areas;
(2) Windows and frames;
(3) Single doors and frames and a series of doors and frames not exceeding 5 feet in width;
(4) Skylights and frames;
(5) Casings around doors, windows, and skylights not exceeding 4 inches in width;
(6) Furnishings which are not permanently affixed to the home's structure;
(7) Baseboards not exceeding 6 inches in height;
(8) Light fixtures, cover plates of electrical receptacle outlets, switches, and other devices;
(9) Decorative items attached to walls and partitions (i.e., pictures, decorative objects, etc.) constituting no more than 10% of the aggregate wall surface area in any room or space not more than 32 square feet in surface area, whichever is less;
(10) Plastic light diffusers when suspended from a material which meets the interior finish provisions of § 3280.203(b);
(11) Coverings and surfaces of exposed wood beams; and
(12) Decorative items including the following:
(i) Non-structural beams not exceeding 8 inches in depth and 6 inches in width and spaced not closer than 4 feet on center;
(ii) Non-structural lattice work;
(iii) Mating and closure molding; and
(iv) Other items not affixed to the home's structure.
Limited combustible: A material meeting:
(1) The definition of Article 2–3 or NFPA 220–1985; or
(2) ¾-inch or thicker gypsum board.
Noncombustible material: A material meeting the definition of Article 2–6 of NFPA 220–1985.
Single-station alarm device: An assembly incorporating the smoke detector sensor, the electrical control equipment, and the alarm-sounding device in one unit.
Smoke detector: A wall-mounted detector of the ionization chamber or photoelectric type which detects visible or invisible particles of combustion and operates from a 120 V AC source of current.
18. Section 3280.203 is amended by revising paragraphs (a) and (b)(4) to read as follows:
§ 3280.203 Flame spread limitations and fire protection requirements.
(a) Establishment of flame spread rating. The surface flame spread rating of interior-finish material shall not exceed the value shown in § 3280.203(b) when tested by “Standard Test Method for Surface Burning Characteristics of Building Materials, ASTM E 84–89a” except that the surface flame spread rating of interior-finish materials required by § 3280.203(b) (5) and (6) may be determined by using the “Standard Test Method for Surface Flammability of Materials Using a Radiant Heat Energy Source, ASTM E 162–87”. However, the following materials need not be tested to establish their flame spread rating unless a lower rating is required by these standards.
(1) Flame-spread rating—70 to 200.
(i) .035-inch or thicker high pressure laminated plastic panel countertop;
(ii) ¼-inch or thicker unfinished plywood with phenolic or urea glue;
(iii) Unfinished dimension lumber (1-inch or thicker nominal boards);
(iv) ¾-inch or thicker unfinished particleboard with phenolic or urea binder;
(v) Natural gum-varnished or laxtex-or alkyd-painted:
(a) ¼-inch or thicker plywood, or
(b) ¾-inch or thicker particleboard, or
(c) 1-inch or thicker nominal board;
(vi) ¾-inch gypsum board with decorative wallpaper; and
(vii) ¼-inch or thicker unfinished hardboard.
(2) Flame-spread rating—25 to 200.
(i) Painted metal;
(ii) Mineral-base acoustic tile;
(iii) ¾-inch or thicker unfinished gypsum wallboard (both laxtex- or alkyd-painted); and
(iv) Ceramic tile.
(The above-listed material applications do not waive the requirements of §§ 3280.203(c) or 3280.204 of this subpart.)
(b) * * *
(4) Exposed interior finishes adjacent to the cooking range shall have a flame spread rating not exceeding 50, except that backsplashes not exceeding 6 inches in height are exempted. Adjacent surfaces are the exposed vertical surfaces between the range top height and the overhead cabinets and/or ceiling and within 6 horizontal inches of the cooking range. (Refer also to § 3280.204(a), “Kitchen Cabinet Protection.”) Sealants and other trim materials 2 inches or less in width used to finish adjacent surfaces are exempt from this provision provided that all joints are completely supported by a framing member.
* * * * *
19. Section 3280.208 is amended by revising paragraphs (c) and (d) to read as follows:
§ 3280.208 Fire detection equipment.
(c) Labeling. Smoke detectors shall be labeled as conforming with the requirements of Underwriters' Laboratories Standard No. 217—Third Edition 1985, as amended through 1989, for "Single and Multiple Station Smoke Detectors."
(d) Installation. Each smoke detector shall be installed in accordance with its listing. The top of the detector shall be located on a wall 4 inches to 12 inches, or at a distance permitted by the listing, below the ceiling. However, when a detector is mounted on an interior wall below a sloping ceiling, it shall be located 4 inches to 12 inches below the intersection of the connecting exterior wall and the sloping ceiling (cathedral ceiling). The required detector(s) shall be attached to an electrical outlet box and the detector connected by a permanent wiring method into a general electrical circuit. There shall be no switches in the circuit to the detector between the over-current protection device protecting the branch circuit and the detector. Smoke detector(s) shall not be placed on the same branch circuit or any circuit protected by a ground fault circuit interrupter.
Subpart D—Body and Frame Construction Requirements
20. Section 3280.302 is proposed to revised to read as follows:
§ 3280.302 Definitions.
The following definitions are applicable to Subpart D only:
Anchoring equipment means straps, cables, turnbuckles, and chains, including tensioning devices, which are used with ties to secure a manufactured home to ground anchors.
Anchoring system means a combination of ties, anchoring equipment, and ground anchors that will, when properly designed and installed, resist overturning and lateral movement of the manufactured home from wind forces.
Diagonal tie means a tie intended to primarily resist horizontal forces, but which may also be used to resist vertical forces.
Footing means that portion of the support system that transmits loads directly to the soil.
Ground anchor means any device at the manufactured home stand designed to transfer manufactured home anchoring loads to the ground.
Hurricane resistant manufactured home means a manufactured home which meets the wind design load requirements for Zone II in § 3280.305(c)(2).
Loads. (1) Dead loads means the weight of all permanent construction including walls, floors, roof, partition, and fixed service equipment.
(2) Live load means the weight superimposed by the use and occupancy of the manufactured home, including wind load and snow load, but no including dead load.
(3) Wind load means the lateral or vertical pressure or uplift on the manufactured home due to wind blowing in any direction.
Main frame means the structural component on which is mounted the body of the manufactured home.
Pier means that portion of the support system between the footing and manufactured home exclusive of caps and shims.
Sheathing means material which is applied on the exterior side of a building frame under the exterior weather resistant covering.
Stabilizing devices means all components of the anchoring and support system such as piers, footings, ties, anchoring equipment, ground anchors, and any other equipment which supports the manufactured home and secures it to the ground.
Support system means a combination of footings, piers, caps, and shims that will, when properly installed, support the manufactured home.
Tie means straps, cable, or securing devices used to connect the manufactured home to ground anchors.
Vertical tie means a tie intended to resist the uplifting or overturning forces.
21. Section 3280.303 is proposed to be amended by revising paragraph (g) to read as follows:
§ 3280.303 General requirements.
* * * * *
(g) Alternative test procedures. In the absence of recognized testing procedures either in these standards or the applicable provisions of those standards incorporated by reference, the manufacturer electing this option shall develop or cause to be developed testing procedures to demonstrate the structural properties and significant characteristics of the material, assembly, subassembly component or member. Such testing procedures shall become part of the manufacturer's approved design. (Refer to § 3280.3)
(1) Testing procedures so developed shall be submitted to the Department for approval.
(2) Upon notification of approval, the alternative test procedure is considered acceptable.
(3) Such tests shall be witnessed by an independent licensed professional engineer or architect or by a recognized testing organization. Copies of the test results shall be kept on file by the manufactured home manufacturer.
22. Section 3280.304 is proposed to be amended by revising paragraph (b)(1) to read as follows:
§ 3280.304 Materials.
* * * * *
(b)(1) Standards for some of the generally used materials and methods of construction are listed in the following table.
Hardboard Siding .......................................................... ANSI/AHA A135.8–1989.
Hardwood and Decorative Plywood ................................ ANSI/HPMA-HP–1983.
Structural Design Guide for Hardwood Plywood Wall Panels .... HPMA-HP-SG–1986.
Structural Glued Laminated Timber ................................ ANSI/AITC A190.1–1983.
Construction and Industrial Plywood ................................. PS–1–83.
APA Design/Construction Guide, Residential and Commercial .... APA–E–30.
Design and Fabrication of All–Plywood Beams, Suppl. 5 .......... APA–H–815.
Plywood Design Specification ........................................ APA–Y–510.
Design and Fabrication of Plywood Lumber Beams, Suppl. 2 ....... APA–S–812.
Design and Fabrication of Plywood Curved Panels, Suppl. 1 ........ APA–S–811.
Design and Fabrication of Plywood Sandwich Panels, Suppl. 4 .... APA–U–814.
Design and Fabrication of Plywood Stressed Skin Panels, Suppl. 3 APA–U–813.
National Design Specification for Wood Construction with Supplement Design Value for Wood Construction. (N)FPA–1988 with 1988 Supplement.
Wood Structural Design Data ........................................ (N)FPA–1988.
Span Tables for Joists and Rafters (PS 20–70) .................... (N)FPA–1988.
Design Values for Joists and Rafters ................................ (N)FPA–1986.
Design Specifications for Metal Plate Connected Wood Trusses .... TPI–1985.
Mat–formed Wood Particleboard ..................................... ANSI A268.1–1984.
Wood Flush Doors ...................................................... ANSI/NWWDA I.S. 1–1987.
Wood Window Units .................................................... ANSI/NWWDA I.S. 2–1987.
Wood Sliding Patio Doors ............................................. ANSI/NWWDA I.S.3–1988.
Water Repellant Preservative Non–Pressure Treatment for Millwork ASTM D 781–88(73).
Standard Test Methods for Puncture and Stiffness of Paperboard, and Corrugated and Solid Fiberboard. Exception, the puncture resistance inch-pound value provided in Section 3280.306 shall be used. Standard Test Methods for Moisture Content of Wood, only Test Method B is applicable. ASTM D–2018–74(83). ASTM D–2016–74(83).
Other:
Standard Specification for Gypsum Wallboard ........................ ASTM C 36–1988.
Fasteners:
Nails, Brads, Staples and Spikes, Wire, Cut and Wrought, except packing and shipping provisions. FS FF–N–105B–1971 with 1977 Amendment 4.
Application and Fastening Schedule: Power–Driven Mechanically Driven and Manually Driven Fasteners.
Unclassified:
American Society of Civil Engineers Minimum Design Loads for Buildings and Other Structures ...... ASCE 7–88.
APA Performance Standards and Policies for Structural Use Panels ........................................ APA PRP E–445.
Windows and Glazing:
Safety Performance Specifications and Methods of Test for Safety Glazing Materials Used in Building. ANSI Z97.1–1984.
23. Section 3280.305 is proposed to be amended by redesignating paragraphs (g) (3) and (4) as (g) (4) and (5), respectively; by adding new paragraphs (b)(4) and (g)(3); and by revising paragraphs (d), (f)(2), (g)(2), and (i)(1)(i) to read as follows:
§ 3280.305 Structural design requirements.
(b) * * *
(4) Whenever the roof slope does not exceed 20, the design horizontal wind load required by § 3280.305(c) (1) and (2) may be determined without including the vertical roof projection of the manufactured home. However, regardless of the roof slope of the mobile home, the vertical roof projection shall be included when determining the wind loading for split level or clerestory type roof systems.
(d) Design load deflection. (1) When a structural assembly is subjected to total design live loads, the deflection for structural framing members shall not exceed the following:
Floor ................................................................. L/240
Roof and ceiling .................................................. L/180
Headers, beams, and girders (vertical load) ....................... L/180
Walls and partitions ............................................. L/180
Where L equals the clear span between supports or two times the length of a cantilever.
(2) The allowable eave on cornice deflection for uplift is to be measured at the design uplift load. [9 psf or 15 psf x by 2.5]. The allowable deflection shall be (2 x Lc)/180 when Lc is the measured horizontal eave projection from the wall.
(f) * * *
(2) Interior walls and partitions shall be constructed with structural capacity adequate for the intended purpose and shall be capable of resisting a horizontal load of not less than five pounds per square foot. An allowable stress measure of 1.33 times the permitted published design values may be used in the design of wood framed interior partitions. Finish of walls and partitions shall be securely fastened to wall framing.
(g) * * *
(2) Wood, wood fiber or plywood floors or subfloors in kitchens, bathrooms (including toilet compartments), laundry areas, water heater compartments, and any other areas subject to excessive moisture shall be moisture resistant or shall be made moisture resistant by sealing or by an overlay of nonabsorbent material applied with water-resistant adhesive. Use one of the following methods:
(i) Sealing the floor with a water-resistant sealer; or
(ii) Installing an overlay of a nonabsorbent floor covering material applied with water-resistant adhesive; or
(iii) Direct application of a water-resistant sealer to the exposed wood floor area when covered with a nonabsorbent overlay; or
(iv) The use of a nonabsorbent floor covering which may be installed without
a continuous application of a water-resistant adhesive or sealant when the floor covering meets the following criteria:
(A) The covering is a continuous membrane with any seams or patches seam bonded or welded to preserve the continuity of the floor covering; and,
(B) The floor is protected at all penetrations in these areas by sealing with a compatible water-resistant adhesive or sealant to prevent moisture from migrating under the nonabsorbent floor covering; and.
(C) The covering is fastened around the perimeter of the subfloor in accordance with the floor covering manufacturer's instructions; and,
(D) The covering is designed to be installed to prevent moisture penetration without the use of a water-resistant adhesive or sealer except as required above.
The vertical edges of penetrations for plumbing shall be covered with a moisture-resistant adhesive or sealant. The vertical penetrations located under the bottom plates of perimeter walls of rooms, areas, or compartments are not required to be sealed: this does not include walls or partitions within the room or areas.
(3) Carpet or carpet pads shall not be installed under concealed spaces subject to excessive moisture, such as plumbing fixture spaces, floor areas under installed laundry equipment. Carpet may be installed in laundry space provided:
(i) The appliances are not provided;
(ii) The conditions of paragraph (g)(2) of this section are followed; and
(iii) Instructions are provided to remove carpet when appliances are installed.
(1) Welded connections. (i) All welds shall be made in accordance with the applicable provisions of the Specification for the Design, Fabrication, and Erection of Structural Steel For Buildings, AISC–S335–1989. The Specification for the Design of Cold-Formed Steel Structural Members, AISI–1986 with 1989 addendum, and the Stainless Steel Cold-Formed Structural Design Manual, AISI–1974.
24. Section 3280.306 is proposed to be amended by revising the introductory paragraph (a) to read as follows:
§ 3280.306 Windstorm protection.
(a) Provisions for support and anchoring systems. Each manufactured home shall have provisions for support and anchoring systems, which, when properly designed and installed, will resist overturning and lateral movement (sliding) of the manufactured home as imposed by the respective design loads. The design wind loads to be utilized for calculating resistance to overturning and lateral movement shall be the wind loads indicated in § 3280.305(c) (1) and (2) increased by a factor of safety of 1.5. The basic allowable stresses of materials required to resist overturning and lateral movement shall not be increased in the design and proportioning of these members. The 1.5 factor of safety is to be applied to the design wind load only to be utilized in the design of the tie-down system to resist overturning and lateral movement, and is not to be applied to the design of the home structure. Wind loading effects for purpose of this section shall be 1.5 x horizontal wind load (15 PSF, 25 PSF) and roof uplift (9 PSF, 15 PSF). When determining the effects of wind overturning and sliding to evaluate the tie-down system, the 1.5 factor of safety is to be applied simultaneously to both the vertical building projection as horizontal wind load and across the surface of the full roof structure as uplift loading. No additional shape or location factors need be applied in the design of the tie-down system. The dead load of the structure may be used to resist the above wind loading effects.
25. Section 3280.309 is proposed to be amended by revising paragraph (b) to read as follows:
§ 3280.309 Health Notice on formaldehyde emissions.
(b) The Notice shall be legible and typed using letters at least \( \frac{1}{4} \) inch in size. The title shall be typed using letters at least \( \frac{3}{4} \) inch in size.
Subpart E—Testing
26. Section 3280.401 is proposed to be amended by revising paragraph (b) to read as follows:
§ 3280.401 Structural load tests.
(b) Ultimate load tests. Ultimate load tests shall be performed on a minimum of three assemblies or components to generally evaluate the structural design. Every structural assembly or component tested shall be capable of sustaining its total dead load plus the design live load increased by a factor of safety of at least 2.5. A factor of safety greater than 2.5 shall be used when required by an applicable reference standard in § 3280.304(b)(1). Tests shall be conducted with loads applied and deflections recorded in \( \frac{1}{4} \) design live load increments at 10-minute intervals until 1.25 times design live load plus dead load has been reached. Additional loading shall then be applied continuously until failure occurs or the total of the factor of safety times the design live load plus the dead load is reached. Assembly failure shall be considered as design live load deflection greater than the limits set in § 3280.305(d) rupture, fracture, or excessive yielding. Assemblies to be tested shall be representative of average quality or materials and workmanship of the production. Each test assembly, component, or sub-assembly shall be identified as to type and quality or grade of material. All assemblies, components, or sub-assemblies qualifying under this section shall be subject to a periodic qualification testing program acceptable to the Department.
26. In § 3280.402, in paragraph (c)(1)(i), Figure A–1 is proposed to be revised as follows:
§ 3280.402 Test procedure for roof trusses.
(c) * * *
(1) * * *
(i) * * *
[Insert Figure A–1.]
27. Section 3280.403 is proposed to be amended by revising paragraphs (d)(2) and (e)(1) to read as follows:
§ 3280.403 Standard for windows and sliding glass doors used in manufactured homes.
(d) * * *
(2) Sealed insulating glass, where used, shall meet all performance requirements for Class C in accordance with ASTM E–774–88, Standard Specification for Sealed Insulating Glass Units. The sealing system shall be qualified in accordance with ASTM E–773–88 Standard Test Method for Seal Durability of Sealed Insulating Glass Units. Each glass unit shall be permanently identified with the name of the insulating glass manufacturer.
(e) * * *
(1) All such windows and doors shall show evidence of certification by affixing a quality certification label to the product in accordance with ANSI Z334.1–1987, “For Certification—Third Party Certification Program.”
28. Section 3280.405 is proposed to be amended by revising paragraphs (c) (1) and (2) to read as follows:
Figure 504. Condensation Map of the United States
BILLING CODE 4210-27-C
(b) Attic or roof ventilation. (1) Attic and roof cavities shall be provided with: (i) A minimum free ventilation area of not less than 1/300 of the attic or roof cavity floor area; or
(ii) A mechanical attic or roof ventilation system may be installed instead of providing the free ventilation area when the mechanical system provides a minimum air change rate of 0.7 cubic feet per minute (cfm) per sq. ft. of attic floor area (at 0.03 inch static pressure) or 10 air changes per hour, whichever is less. The air intake shall provide at least 1 square foot free opening per 300 cfm fan capacity. Intake and exhaust vents shall be located so as to provide air movement throughout space.
(2) Single section manufactured homes constructed with metal roofs and having no sheathing or underlayment installed, are not required to be provided with attic or roof ventilation provided that:
(i) The vapor retarder specified in § 3280.504(a) is installed and air leakage paths from the living space to the roof cavity created by electrical outlets, plumbing penetrations, flue pipes and exhaust vents are sealed.
(ii) Capability to provide continuous mechanical ventilation from the exterior to the interior, and from the interior to the exterior, of the home is installed. The minimum ventilation rate shall be 150 cfm. This system shall be considered as complying with § 3280.103(b) (1) and (3). The ventilation provided shall be switch controlled and shall be provided with an automatic humidity control system.
(3) Between 50 and 60 percent of the required free ventilation area shall be provided by ventilators located in the upper portion of the space to be ventilated, with the balance provided by eave, soffit or low gable vents. The location and spacing of the vent openings and ventilators shall provide cross-ventilation to the entire attic or roof cavity space. A clear air passage space having a minimum height of 1 inch shall be provided between the top of the insulation and the roof sheathing or roof covering.
(4) To determine the appropriate condensation zone, refer to Figure 504. Either the state lines (solid lines) or the design temperature lines (if exact location of home is known) shall be utilized.
(5) The vents provided for ventilating attics shall be designed to prevent entry of rain, snow and insects.
* * * * *
31. Section 3280.506 is proposed to be revised to read as follows:
§ 3280.506 Heat loss/Heat gain.
The manufactured home heat loss/heat gain shall be determined by methods outlined in §§ 3280.508 and 3280.509. The Uo (Coefficient of heat transmission) value zone for which the manufactured home is acceptable and the lowest outdoor temperature to which the installed heating equipment will maintain a temperature of 70° F shall be certified as specified in § 3280.510 of this subpart. The Uo value zone shall be determined from the map in Figure 506.
BILLING CODE 4210–27–M
Figure 504. Condensation Map of the United States
Figure 506. U-value Zones
| Zone (a) | U-value |
|----------|---------|
| 1 | 0.132 |
| 2 | 0.109 |
| 3 | 0.096 |
| 4 | 0.079 |
(a) Hawaii is included in Zone 1
Alaska is included in Zone 4.
BILLING CODE 4210-27-C
(a) Coefficient of heat transmission. The overall coefficient of heat transmission (Uo) of the manufactured home for the respective zones and an indoor design temperature of 70° F, including internal and external ducts, and excluding infiltration ventilation and condensation control, shall not exceed the Btu/(hr.) (sq. ft.) (F) of the manufactured home envelope are as tabulated below:
| Uo value zone | Maximum coefficient of heat transmission |
|---------------|------------------------------------------|
| 1 | 0.132 Btu/(hr.) (sq. ft.) (F) |
| 2 | 0.109 Btu/(hr.) (sq. ft.) (F) |
| 3 | 0.096 Btu/(hr.) (sq. ft.) (F) |
| 4 | 0.079 Btu/(hr.) (sq. ft.) (F) |
(b) To assure uniform heat transmission in manufactured homes, cavities in exterior walls, floors, and ceilings shall be provided with thermal insulation.
(c) Manufactured homes designed for Uo Value Zone 4 shall be factory equipped with storm windows or insulating glass.
32. Section 3280.508 is proposed to be revised to read as follows:
§ 3280.508 Heat loss, heat gain and cooling load calculations.
(a) Information, values and data necessary for heat loss and heat gain determinations shall be taken from the 1989 ASHRAE Handbook of Fundamentals, Chapters 20 through 27. The following portions of those chapters are not applicable:
21.1 Steel Frame Construction
21.2 Masonry Construction
21.3 Floor Systems
21.14 Pipes
21.16 Tanks, Vessels and Equipment
21.17 Refrigerated Rooms and Buildings
22.15 Mechanical and Industrial Systems
23.13 Commercial Building Envelope Leakage
25.4 Calculation of Heat Loss from Crawl Spaces
(b) The calculation of the manufactured home’s transmission heat loss coefficient (Uo) shall as a minimum address all the heat loss or heat gain considerations in a manner consistent with the calculation procedures provided in appendix A of this part.
(c) Areas where the insulation does not fully cover a surface or is compressed shall be accounted for in the U-calculation (see § 3280.506). The effect of framing on the U-value must be included in the Uo calculation. Other low-R-value heat-flow paths ("thermal shorts") shall be explicitly accounted for in the calculation of the transmission heat loss coefficient if in the aggregate all types of low-R-value paths amount to more than 1% of the total exterior surface area. Areas are considered low-R-value heat-flow paths if:
(1) They separate conditioned and unconditioned space; and
(2) They are not insulated to a level that is at least one-half the nominal insulation level of the surrounding building component.
(d) High Efficiency Heating and Cooling Equipment Credit. The calculated transmission heat loss coefficient (Uo) used for meeting the requirement in § 3280.506(a) may be adjusted for heating and cooling equipment efficiency above that required by the National Appliance Energy Conservation Act of 1987 (NAECA) by applying the following formula:
\[ \text{Uo adjusted} = \text{Uo standard} \times [1 + (0.6 \times \text{heating efficiency increase factor}) + (\text{cooling multiplier} \times \text{cooling efficiency increase factor})] \]
where "Uo standard" = maximum Uo for that zone.
\[ \text{Uo adjusted} = \text{maximum Uo adjusted for high efficiency HVAC equipment} \]
"heating efficiency increase factor" = the increase factor in the heating equipment efficiency in AFUE (or HSPF for heat pumps) above that required by NAECA and \(= \frac{\text{AFUE home}}{\text{AFUE NAECA}}\)
"cooling efficiency increase factor" = the increase factor in the cooling equipment efficiency in SEER above that required by NAECA and \(= \frac{\text{SEER home}}{\text{SEER NAECA}}\)
"cooling multiplier" = the cooling multiplier for the Uo zone from the table below.
| Uo zone | Cooling multiplier (Cm) |
|---------|-------------------------|
| 1 | 0.60 |
| 2 | 0.20 |
| 3 | 0.07 |
| 4 | 0.03 |
(e) U-values for any glazing (windows, skylights, and the glazed portions of any door) shall be based on tests using American Architectural Manufacturers Association (AAMA) 1503.1-1988, Voluntary Test Method for Thermal Transmittance and Condensation Resistance of Windows, Doors, and Glazed Wall Sections. In the absence of tests, the following default values must be used, with storm windows treated as an additional pane:
- 1.31 for single-pane glazing.
- 0.92 for double-pane glazing.
- 0.79 for triple-pane glazing.
- 1.23 for single-pane sliding glass doors (slider).
- 0.78 for double-pane sliding glass doors.
- 0.64 for triple-pane sliding glass doors.
- 0.60 for the unglazed portion of a door.
(f) Annual Energy Used Based Compliance. As an alternative, homes may demonstrate compliance with the annual energy used implicit in the coefficient of heat transmission (Uo) requirement. The annual energy use determination must be based on generally accepted engineering practices. The general requirement is to demonstrate that the home seeking compliance approval has a projected annual energy use, including both heating and cooling, less than or equal to a similar "base case" home that meets the standard. The energy use for both homes must be calculated based on the same assumptions; including assuming the same dimensions for all boundaries between conditioned and unconditioned spaces, site characteristics, usage patterns and climate.
33. Section 3280.510 is proposed to be amended by revising paragraph (b) to read as follows:
§ 3280.510 Heat loss certificate.
(b) Outdoor certification temperature. The lowest outdoor temperature at which the installed heating equipment will maintain a 70° F temperature inside the home without storm sash or insulating glass for Zone 1, 2, and 3 and with storm sash or insulating glass for Zone 4 and complying with §§ 3280.508 and 3280.509.
Heating Certificate
Home Manufacturer ____________
Plant Location _________________
Home Model ___________________
(Include U Value Zone Map)
This manufactured home has been thermally insulated to conform with the requirements of the Federal Manufactured Home Construction and Safety Standards for all locations within U Value Zone ____.
Heating Equipment Manufacturer ____________
Heating Equipment Model ____________
The above heating equipment has the capacity to maintain an average 70 °F temperature in this home at outdoor temperatures of ____ °F.
To maximize furnace operating economy and to conserve energy, it is recommended that this home be installed where the outdoor winter design temperature (97½%) is not higher than ____ degrees Fahrenheit.
The above information has been calculated assuming a maximum wind velocity of 15 MPH at standard atmospheric pressure.
34. Section 3280.511 is proposed to be amended by revising paragraphs (a)(1), (b), and (c) to read as follows:
§ 3280.511 Comfort cooling certificate and information.
(a) * * *
(1) *Alternative I.* If a central air conditioning system is provided by the home manufacturer, the heat gain calculation necessary to properly size the air conditioning equipment shall be in accordance with procedures outlined in Chapter 22 of the 1989 ASHRAE Handbook of Fundamentals, with an assumed location and orientation. The following shall be supplied in the Comfort Cooling Certificate:
Air Conditioner Manufacturer
Air Conditioner Model __________
Certified Capacity ____ BTU/Hr. in accordance with the appropriate Air Conditioning and Refrigeration Institute Standards
The temperature to be specified shall be 20° or 30% of the design temperature difference, whichever is greater, added to the temperature specified as the heating system capacity certification temperature without storm windows or insulating glass for Zones 1, 2, and 3 and with storm windows or insulating glass for Zone 4. Design temperature difference is 70° minus the heating system capacity certification temperature in degrees Fahrenheit.
The central air conditioning system provided with this home has been sized, assuming an orientation of the front (hitch) end of the home facing ________ and is designed on the basis of a 75° F indoor temperature and an outdoor temperature of ____ F dry bulb and ____ F wet bulb."
Example Alternate I
Comfort Cooling Certificate
Manufactured Hme Mfg. __________
Plant Location __________
Manufactured Home Model __________
Air Conditioner Manufacturer __________
Certified Capacity ____ BTU/Hr. in accordance with the appropriate Air Conditioning and Refrigeration Institute Standards.
The central air conditioning system provided with this home has been sized assuming an orientation of the front (hitch end) of the home facing ________. On this basis, the system is designed to maintain an indoor temperature of 75° F when outdoor temperatures are ____ F dry bulb and ____ F wet bulb.
The temperature to which this home can be cooled will change depending upon the amount of exposure of the windows to the sun's radiant heat. Therefore, the home's heat gains will vary dependent upon its orientation to the sun and any permanent shading provided. Information concerning the calculation of cooling loads at various locations, window exposures and shadings are provided in chapter 22 of the 1989 edition of the ASHRAE Handbook of Fundamentals.
(b) For each home designated as suitable for central air conditioning the manufacturer shall provide the maximum central manufactured home air conditioning capacity certified in accordance with the ARI Standard 210/240 Unitary Air Conditioning and Air Source Unitary Heat Pump Equipment and in accordance with § 3280.715(a)(3). If the capacity information provided is based on entances to the air supply duct at other than the furnace plenum, the manufacturer shall indicate the correct supply air entrance and return air exit locations.
(c) Comfort cooling information. For each manufactured home designated, either "suitable for" or "provided with" a central air conditioning system, the manufacturer shall provide comfort cooling information specific to the manufactured home necessary to complete the cooling load calculations. The comfort cooling information shall include a statement to read as follows:
To determine the required capacity of equipment to cool a home efficiently and economically, a cooling load (heat grain) calculation is required. The cooling load is dependent on the orientation, location and the structure of the home. Central air conditioners operate most efficiently and provide the greatest comfort when their capacity closely approximates the calculated cooling load. Each home's air conditioner should be sized in accordance with chapter 22 of the 1989 Edition, American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE) Handbook of Fundamentals, once the location and orientation are known.
Information Provided by the Manufacturer Necessary to Calculate Sensible Heat Gain
Walls (without windows and doors)..........."U"
Ceilings and roofs of light color............."U"
Ceilings and roofs of dark color............."U"
Floors..........................................."U"
Air ducts in floor..............................."U"
Air ducts in ceiling.........................."U"
Air ducts installed outside the home......."U"
Information necessary to calculate duct areas.
Subpart G—Plumbing Systems
35. Section 3280.602 is proposed to be amended by removing the paragraph designations from the section and by adding in alphabetical order the definitions for "Flushometer tank", "Plumbing appliance", "Plumbing appurtenance" and "Whirlpool bathtub", to read as follows:
§ 3280.602 Definitions.
Flushometer tank means a device integrated within an air accumulator vessel which is designed to discharge a predetermined quantity of water to fixtures for flushing purposes.
Plumbing appliance means any one of a special class of plumbing fixture which is intended to perform a special plumbing function. Its operation and/or control may be dependent upon one or more energized components, such as motors, control, heating elements, or pressure or temperature-sensing elements. Such fixture may operate automatically through one or more of the following actions: A time cycle, a temperature range, a pressure range, a measured volume or weight, or the fixture may be manually adjusted or controlled by the user or operator.
Plumbing appurtenance means a manufactured device, or a prefabricated assembly, or an on-the-job assembly of component parts, and which is an adjunct to the basis piping system and plumbing system and plumbing fixtures. An appurtenance demands no additional water supply, nor does it add any discharge load to a fixture or the drainage system.
Whirlpool bathtub means a plumbing appliance consisting of a bathtub fixture which is equipped and fitted with a circulation piping system, pump, and other appurtenances and is so designed to accept, circulate, and discharge bathtub water upon each use. (See also definition of "Hydromassage Bathtub" in Article 680 of the National Electrical Code. NFPA No 70-, 1990.)
36. Section 3280.603 is proposed to be amended by revising paragraph (a)(5) to read as follows:
§ 3280.603 General requirements.
(a) * * *
(5) Components. Plumbing materials, devices, fixtures, fittings, equipment, appliances, appurtenance, and accessories intended for use in or attached to a manufactured home shall conform to one of the applicable standards referenced in § 3280.604. Where an applicable standard is not referenced, the plumbing component shall be listed by a nationally recognized testing laboratory, inspection agency other qualified organization as suitable for the intended use.
* * * * *
37. Section 3280.604 is proposed to be revised as follows:
§ 3280.604 Materials.
(a) Minimum standards. Materials, devices, fixtures, fittings, equipment, appliances, appurtenances and accessories shall conform to one of the standards in the following table and be free from defects. Where an appropriate standard is not indicated in the table or a standard not indicated in the table is preferred, the item may be used if it is listed. A listing is also required when so specified in other sections of this subpart.
(b) Where more than one standard is referenced for a particular material or component, compliance with only one of those standards is acceptable. Exceptions:
(1) When one of the reference standards requires evaluation of chemical, toxicity or odor properties which are not included in the other standard, then conformance to the applicable requirements of each standard shall be demonstrated;
(2) When a plastic material or component is not covered by the Standards in the following table, it shall be certified as non-toxic in accordance with NSF14–1984, “Plastic Piping System Components and Related Materials.”
| Material | ANSI | ASTM | FS | Other |
|-------------------------------------------------------------------------|-------------------------------------------|-------------------------------------------|------------------------------------------|-------------------------------------------|
| Ferrous pipe and fittings: | ASME/B16.4–1985 | A 53–90a | | IAPMO PS–5–1984 |
| Cast Iron Threaded Fittings | ASME/B16.3–1985 | | | |
| Malleable Iron Threaded Fittings | ASME/B36.10–1985 | | | |
| Mechanical Property Standard for Special Cast Iron Fittings | ASME/B1.20.1–1983 | A 74–87 | W–P–401E–1974 | CISPI 301–90 |
| Welded and Seamless Wrought Steel Pipe | | | | |
| Standard Specification for Pipe, Steel, Black and Hot-Dipped, Zinc-Coated, Welded and Seamless, Pipe threads, General (Inch). | | | | |
| Standard Specification for Cast Iron Soil Pipe and Fittings | B–42–89 | | | |
| Standard Specification for Hubless Cast Iron Soil Pipe and Fittings | B 152–88(M) | | | |
| Standard Specification for Sanitary and Storm Drain, Waste, and Vent Piping Applications. | B–88–89(M) | | | |
| Nonferrous pipe and fittings: | B 306–88 | | | |
| Standard Specification for Seamless Copper Pipe, Standard Sizes. | ASME/B16–22–1989 | | | |
| Standard Specification for General Requirements for Wrought Seamless Copper and Copper-Alloy Tubes. | B16.29–1986 | | | |
| Standard Specification for Seamless Copper Water Tubes | B16.18–1984 | | | |
| Standard Specification for Copper Drainage Tube (DWV). | B16.23–1984 | | | |
| Wrought-Copper and Copper Alloy, Solder-Joint Pressure Fittings. | B16.26–1988 | B 43–88 | | |
| Wrought Copper and Wrought Copper Alloy Solder—Joint Drainage Fittings—DWV. | | | | |
| Cast Copper Alloy Solder—Joint Pressure Fittings (DWV). | | | | |
| Cast Copper Alloy Solder—Joint Drainage Fittings—(DWV). | | | | |
| Cast Copper Alloy Fittings for Flared Copper Tubes. | | | | |
| Standard Specification for Seamless Red Brass Pipe, Standard Sizes. | | | | |
| Cast Bronze Threaded Fittings 125 and 250 pound. | ASME/B16.15–1985 | D 2661–90 | | NSF–14–1991 |
| Plastic pipe and fittings: | D 2665–89a | L–P–320B–1973 | | NSF–14–1991 |
| Standard Specification for Acrylonitrile-Butadiene-Styrene (ABS) Plastic Drain, Waste and Vent Pipe and Fittings. | | | | |
| Standard Specification for Poly (Vinyl Chloride PVC) Plastic Drain, Waste and Vent Pipe Fittings. | | | | |
| Standard Specification for Drain Waste and Vent (DWV) Plastic Fitting Patterns. | | | | |
| Standard Specification for Acrylonitrile-Butadiene-Styrene (ABS) Plastic Drain, Waste, and Vent Pipe Having a Flared Cone. | | | | |
| Standard Specification for Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Hot and Cold Water Distribution Systems. | | | | |
| Standard Specification for Polybutylene (PB) Plastic Hot and Cold Water Distribution Systems. | | | | |
| Miscellaneous: | D 3309–90a | | | NSF–14–1991 |
| Nipples, Pipe, Threaded | C 564–88 | | | WW–N–351–C–1976 With Interim Amendment 1 | |
| Material | ANSI | ASTM | FS | Other |
|------------------------------------------------------------------------|-------------------------------------------|-------------------------------------------|---------------|------------------------------------------|
| Backflow Valves, Prevention Devices | A112.14.1–1975 | MSSVF150 | IAPMO/PS 31–1991 | |
| Valve, Gate, Brass, 125, 150 and 200 Pound | | | | |
| Threaded Ends, Flange Ends, Solder End and Bronze Ends, for Land Use | | | | |
| Plumbing Fixture Setting Compound | | TTP 1536A–1975 | IAPMO/PS 2–1989 | |
| Material and Property Standard for Cast Brass and Tubing P-Traps | | | | |
| Relief Valves and Automatic Gas Shut-off Devices for Hot Water Supply Systems | Z21.22–1986 | | NSF–14–1991 | |
| Standard Specification for Solvent Cement for Acrylate-Butadiene-Styrene (ABS) Plastic Pipe and Fittings | D 2235–88 | | | |
| Standard Specification for Solvent Cement for Poly (Vinyl Chloride) (PVC) Plastic Pipe and Fittings | D 2564–88 | | NSF–14–1981 | |
| Specification for Neoprene Rubber Gaskets for Hub and Spigot Cast Iron Soil Pipe and Fittings | | | CISPI-HSN-85 | |
| Plumbing System Components for Mobile Homes and Recreational Vehicles | | | NSF–24–1988 | |
| Material and Property Standard for Diversion Tees and Twist Male Elbows | | | IAPMO/PS 9–1984 | |
| Material and Property Standard for Flexible Copper Water Connectors | | | IAPMO/PS 14–1989 | |
| Material and Property Standard for Dishwasher Drain Airgaps (Air Breaks) | | | IAPMO/PS 23–1989 | |
| Plumbing fixtures: | | | | |
| Plumbing fixtures (General Specifications) | | | WW-P–54E/GEN 1980 | |
| Vitreous China Plumbing Fixtures | A112.19.2(M)–1982 | | | |
| Enameled Cast Iron Plumbing Fixtures | ASME A112.19.1(M)–1987 | | IAPMO/TSC–22–1985 | |
| Porcelain Enameled Formed Steel Plumbing Fixtures | ASME A112.19.4(M)–1984 | | | |
| Plastic Bathtub Units | Z124.1–1987 with addenda Z124.1a–1990 | | IAPMO/TSC–22–1985 | |
| Plastic Shower Receptors and Shower Stalls | Z124.2–1987 | | | |
| Stainless Steel Plumbing Fixtures—Residential Use. | ASME A112.19.3(M)–1987 | | NSF–24–1988 | |
| Material and Property Standard for Drains for Prefabricated and Precast Showers | | | IAPMO/PS 4–1988 | |
| Plastic Lavatories | Z124.3–1986 | | NSF–24–1988 | |
| Safety Performance Specifications and Methods of Test for Safety Glazing Materials Use in Buildings | Z97.1–1984 | | | |
| Finished and Rough Brass Plumbing Fixture Fittings | A112.18.1M–1989 | | | |
| Trim for Water Closet Bowls, Tanks, and Urinals | A112.10.5–1979 | | | |
| Plastic Water Closets, Bowls and Tanks | Z124.4–1988 with addendum Z124.4a–1990 | | | |
| Whirlpool Bathtub Appliances | ASME/ANSI A112.19.7–1967 | | | |
| Individual Shower Control Valves | ANSI/ASSE 1016–1990 | | | |
| Pressurized Fixture Flushing Devices (Flushometers). | | | ASSE 1037–1990 | |
| Water Closet Flush Tank Fill Valves (Ballcocks) | ANSI/ASSE 1002–1979 | | | |
| Handheld Showers | ANSI/ASSE 1014–1990 | | | |
| Hydrants for Utility and Maintenance Use | ASME/ANSI A112.21.3M–1984 | | | |
| Plumbing Requirements for Home Laundry Equipment | ANSI/ASSE 1007–1986 | | | |
| Hot Water Dispensers, Household Storage Type, Electrical Plumbing Requirements for. | | | ASSE 1023–1979 | |
| Household Dishwashers, Plumbing Requirements for. | ANSI/ASSE 1006–1986 | | | |
| Household Food Waste Disposer Units, Plumbing Requirements for | ANSI/ASSE 1008–1980 | | | |
| Thermostatic Mixing Valves, Self Actuated for Primary Domestic Use. | ANSI/ASSE 1017–1979 | | | |
| Water Hammer Arrestors | ASME/ANSI A112.26.1M–1984 | | | |
| Suction Fittings for Use in Swimming Pools, Wading Pools, Spas, Hot Tubs, and Whirlpool Bathtub Appliances | ASME/ANSI A112.19.8–1987 | | | |
| Air Gaps in Plumbing Systems | ASME/ANSI A112.1.2–1942 (1979) | | | |
| Diverter for Plumbing Faucets with Hose Spray, Anti Siphon Type, Residential Appliances; Pref. Requirements | ANSI/ASSE 1025–1978 | | | |
| Pipe Applied Atmospheric-Type Vacuum Breakers | ANSI/ASSE 1001–1982 | | | |
| Hose Connection Vacuum Wall Hydrants, Freezeless, Automatic Draining. | ANSI/ASSE 1011–1982 | | | |
| Wall Hydrants, Freezeless, Automatic Draining Anti-Backflow Types. | ANSI/ASSE 1019–1978 | | | |
38. Section 3280.606 is proposed to be amended by revising paragraph (b)(1)(iii) to read as follows:
§ 3280.606 Traps and cleanouts.
(b)
(1)
(iii) A cleaning tool shall not be required to pass through more than 360 degrees of fittings, excluding removable "P" traps, to reach any part of the drainage system. Water closets may be removed for drainage system access.
39. Section 3280.607 is proposed to be amended by revising paragraphs (b)(2), (b)(2) (i), (ii), (iv) and (v), (b)(4)(i), and (c)(1) and by adding new paragraphs (c) (5) and (6) to read as follows:
§ 3280.607 Plumbing fixtures.
(b)
(2) Water closets. (i) Water closets shall be designed and manufactured according to approved or listed standards and shall be equipped with a water flushing device capable of adequately flushing and cleaning the bowl at each operation of the flushing mechanism.
(ii) Water closet flushing devices shall be designed to replace the water seal in the bowl after each operation. Flush valves, flushometer valves, flushometer tanks and ballcocks shall operate automatically to shut off at the end of each flush or when the tank is filled to operating capacity.
(iv) Water closets that have fouling surfaces that are not thoroughly washed at each discharge shall be prohibited. Any water closet that might permit the contents of the bowl to be siphoned back into the water system shall be prohibited.
(v) Floor connection. Water closets shall be securely bolted to an approved flange or other approved fitting which is secured to the floor by means of corrosion-resistant screws. The bolts shall be of solid brass or other corrosion-resistant material and shall be not less than one-fourth inch in diameter. A watertight seal shall be made between the water closet and flange or other approved fitting by use of a gasket or sealing compound.
(4) Dishwashing machines. (i) A dishwashing machine shall not be directly connected to any waste piping, but shall discharge its waste through a fixed air gap installed above the machine, or through a high loop as specified by the dishwashing machine manufacturer, or into a open standpipe-receptor with a height greater than the washing compartment of the machine. When a standpipe is used, it shall be at least 18 inches but not more than 30 inches above the trap weir. The drain connections from the air gap or high loop may connect to an individual trap, to a directional fitting installed in the sink tailpiece or to an opening provided on the inlet side of a food waste disposal unit.
(c) Installation—(1) Access. Each plumbing fixture and standpipe receptor shall be located and installed in a manner to be accessible for usage, cleaning, repair and replacement. Access to diverter valves and other connections from the fixture hardware is not required.
(5) Fixture fittings. Faucets and diverters shall be installed so that the flow of hot water from the fittings corresponds to the left-hand side of the fitting.
(6) Whirlpool bathtub appliances—(i) Access panel. A door or panel of sufficient size shall be installed to provide access to the pump for repair and/or replacement.
(ii) Piping drainage. The circulation pump shall be accessibly located above the crown weir of the trap. The pump drain line shall be properly sloped to drain the volute after fixture use.
(iii) Piping. Whirlpool bathtub circulation piping shall be installed to be self-draining.
40. Section 3280.609 is proposed to be amended by revising paragraph (b)(5) and (6), (d)(1)(i) and (e)(3), and by adding paragraphs (b)(7) and (8), to read as follows:
§ 3280.609 Water distribution system.
(b)
(5) Flushometer valves or manually operated flush valves. An approved or listed vacuum breaker shall be installed and maintained in the water supply line on the discharge side of a water closet flushometer valve or manually operated flush valve. Vacuum breakers shall have a minimum clearance of 6 inches above the flood level of the fixture to the critical level mark unless otherwise permitted in their approval.
(6) Flush tanks. Water closet flush tanks shall be equipped with an approved or listed anti-siphon ball cock which shall be installed and maintained with its outlet or critical level mark not less than 1 inch above the full opening of the overflow pipe.
(7) Hose bibbs. When provided, all exterior hose bibbs and laundry tray hose connections shall be protected by a listed non-removable backflow prevention device.
(8) Flushometer tanks. Flushometer tanks shall be equipped with an approved air gap on vacuum breaker assembly located above the flood level rim above the fixture.
(d)
(1)
(i) Plastic piping. All plastic water piping and fittings in manufactured homes must be listed for use with hot water.
(e)
(3) Solder fittings. Joints in copper water tube shall be made by the appropriate use of approved cast brass or wrought copper fittings, properly soldered together. The surface to be soldered shall be thoroughly cleaned bright mechanically. The joints shall be properly fluxed and made with a solder that contains no more than 0.2 percent lead.
41. Section 3280.610 is proposed to be amended by revising paragraphs (c)(5); by redesignating paragraphs (d) introductory text and (d)(1) as paragraphs (d) (1) and (2), respectively; and by revising the newly redesignated (d)(1), and (e)(1)(iii), to read as follows:
§ 3280.610 Drainage systems.
(c)
(5) Preassembly of drain lines. Section(s) of the drain system, designed to be located underneath the home, are not required to be factory-installed when the manufacturer designs the system for site assembly and also provides all materials and components including piping, fittings, cement, supports, and instructions necessary for proper site installation.
(d)
(1) Water closets. The drain connection for each water closet shall be 3 inches minimum inside diameter and shall be fitted with an iron, brass, or listed plastic floor flange adaptor ring securely screwed, soldered or otherwise permanently attached to the drain piping, in an approved manner and securely fastened to the floor.
(e)
(1)
(iii) A 3-inch minimum diameter piping shall be required for water closets.
42. Section 3280.611 is proposed to be amended by revising paragraph (d)(5) to read as follows:
§ 3280.611 Vents and venting.
(d) * * *
(5) Materials for the anti-siphon trap vent shall be as follows: Cap and housing shall be listed acrylonitrile-butadiene-styrene, DWV grade; stem shall be DWV grade nylon or acetal; spring shall be stainless steel wire, type 302; sealing disc shall be neoprene, conforming to the Specification for Neoprene Rubber Gaskets for HUB and Spigot Cast Iron Soil Pipe and Fittings. CISPI-HSN-85 and ASTM C 564-88, Standard Specification for Rubber Gaskets for Case Iron Soil Pipe and Fittings or, silicone rubber, low and high temperature and tear resistant, conforming to Rubber, Silicone, FS ZZ-R-765B-1970, With 1971 Amendment 1; and Liners, Case, and Sheet, Overwrap; Water-Vapor Proof or Waterproof, Flexible, MIL-L-10547E-1975.
43. Section 3280.612 is proposed to be amended by revising paragraph (b)(3) to read as follows:
§ 3280.612 Test and inspection.
(b) * * *
(3) Flood level test. The manufactured home shall be in a level position, all fixtures shall be connected, and the entire system shall be filled with water to the rim of the toilet bowl. (Tub and shower drains shall be plugged). After all trapped air has been released, the test shall be sustained for not less than 15 minutes without evidence of leaks. Then the system shall be unplugged and emptied. The waste piping above the level of the water closet bowl shall then be tested and show no indication of leakage when the high fixtures are filled with water and emptied simultaneously to obtain the maximum possible flow in the drain piping.
Subpart H—Heating, Cooling and Fuel Burning Systems
44. Section 3280.702 is proposed to be amended by removing the paragraph designations from the section and by revising the definition for "Connector-Gas appliance" to read as follows:
§ 3280.702 Definitions.
* * * * * * * * *
Connector-Gas appliance means a flexible or semi-rigid connector used to convey fuel gas between a gas outlet and a gas appliance.
* * * * * * * * *
45. Section 3280.703 is proposed to be revised to read as follows:
§ 3280.703 Minimum standards.
Heating, cooling and fuel burning appliances and systems in manufactured homes shall be free of defects, and shall conform to applicable standards in the following table unless otherwise specified in this standard. (See § 3280.4) When more than one standard is referenced, compliance with any one such standard shall meet the requirements of this standard.
| Appliances | ANSI | UL | Standards |
|----------------------------------------------------------------------------|----------------------------------------------------------------------|----------------------------------------------------------------------|--------------------------------------------------------------------------|
| Central Cooling Air Conditioners | | | 465—Seventh Edition-1982 as amended through 1987. |
| Liquid Fuel-Burning Heating Appliances for Mobile Homes and Recreational Vehicles | | | 307A—Sixth Edition-1990 |
| Electric Air Heaters | | | 1025—Second Edition-1980, as amended through 1991. |
| Electric Baseboard Heating Equipment | | | 1042—Third Edition 1987 |
| Electric Central Air Heating Equipment | | | 1096—Fourth Edition-1986 as amended through 1988. |
| Gas Burning Heating Appliances for Mobile Homes and Recreational Vehicles | | | 307(B)—First Edition-1982, as amended through-1987. |
| Gas Clothes Dryers, Vol. 1, Type 1 Clothes Dryers | Z21.5.1–1982 with addenda | | |
| Gas-Fired Absorption Summer Air Conditioning Appliances | Z21.5.1a–1987 | | |
| Gas-Fired Central Furnaces (Except Direct Vent and Separated Combustion System Central Furnaces). | Z21.40–1981, Z21.40.a–1982 | | |
| Household Cooking Gas Appliances | Z21.1–1987 | | |
| Refrigerators Using Gas Fuel | Z21.19–1983 | | |
| Gas Water Heaters, Vol. 1 Storage Water Heaters with Input Ratings of 75,000 BTU per hour or Less. | Z21.10.1–1990 | | |
| Heat Pumps | | | 559—Fourth Edition-1985, as amended through 1987. |
| Household Electric Storage Tank Water Heaters | | | 174—Eighth Edition-1989, as amended through 1991. |
| Ferrous pipe and fittings: | | | ASTM A53–90a |
| Standard Specification for Pipe, Steel, Black and Hot Dipped, Zinc Coated, Welded and Seamless. | | | ASTM A 539–90a |
| Standard Specification for Electric-Resistance-Welded Coiled Steel Tubing for Gas and Fuel Oil lines. | | | |
| Pipe Threads, General Purpose (Inch) | ASME B1.20.1–1983 | | |
| Welded and Seamless Wrought Steel Pipes | ASME B36.10–1985 | | |
| Nonferrous pipe, tubing and fittings: | | | ASTM B–88–90(M) |
| Standard Specification for Seamless Copper Water Tube | | | ASTM B–280–88 |
| Standard Specification for Seamless copper Tube for Air Conditioning and Refrigeration Field Service. | | | |
| Metal Connectors for Gas Appliances | Z21.24–1987 | | |
| Manually Operated Gas Valves | Z21.15–1989 | | |
| Standard for Gas Supply Connectors for Manufactured Mobile Homes | | | IAPMO/TSC–9–1989 |
| Standard Specification for General Requirements for Wrought Seamless Copper and Copper-Alloy Tubes. | | | ASTM B 251–88(M) |
| Standard Specification for Seamless Copper Pipe, Standard Sizes | | | ASTM B 42–89 |
46. Section 3280.704 is proposed to be amended by revising the introductory test paragraph (b)(2) and paragraph (b)(5)(i) to read as follows:
§ 3280.704 Fuel supply systems.
(b) * * *
(2) Construction of containers. Containers shall be constructed and marked in accordance with the specifications for LP-Gas Containers of the U.S. Department of Transportation (DOT) or the Rules for Construction of Pressure Vessels 1986, ASME Boiler and Pressure Vessel Code section VIII, Division 1 ASME Containers shall have a design pressure of at least 312.5 psig.
(5) LP-gas safety devices. (i) DOT containers shall be provided with safety relief devices as required by the regulations of the U.S. Department of Transportation. ASME containers shall be provided with relief valves in accordance with subsection 221 of the Storage and Handling Liquified Petroleum Gases, NEPA No. 58–1989. Safety relief valves shall have direct communication with the vapor space of the vessel.
47. Section 3280.705 is proposed to be amended by revising paragraphs (b)(1), (b)(3), (c), (d), the table to (d), (k), the table to (k), (1)(1), (1)(2) introductory text, (1)(2)(ii), and (1)(3) to read as follows:
§ 3280.705 Gas piping systems.
(b) * * *
(1) Steel or wrought-iron pipe shall comply with ANSI Standard B36.10–1985, Welded and Seamless Wrought Steel Pipe. Threaded brass pipe in iron pipe sizes may be used. Threaded brass pipe shall comply with ASTM B43–88 Standard Specification for Seamless Red Brass Pipe, Standard Sizes.
(3) Copper tubing shall be annealed type, Grade K or L, conforming to the Standard Specification for Seamless Copper Water Tube (ASTM B88–88a) or shall comply with the Standard Specification for Seamless Copper Tube for Air Conditioning and Refrigeration Field Service, ASTM B 280–88. Copper tubing shall be internally tinned.
(c) Piping design. Each manufactured home requiring fuel gas for any purpose shall be equipped with a natural gas piping system acceptable for LP-Gas. Where fuel gas piping is to be installed in more than one section of an expandable or multiple unit home, the design and construction of the crossover(s) shall be as follows:
(1) All points of crossover shall be readily accessible from the exterior of the home.
(2) The connection(s) between units shall be made with a connector(s) listed for exterior use or direct plumbing sized in accordance with § 3280.705(d). A shutoff valve of the nondisplaceable rotor type conforming to ANSI Z21.15–1989 Manually Operated Gas Valves, suitable for outdoor use shall be installed at each crossover point upstream of the connection when listed connectors are used.
(3) The connection(s) may be made by a listed “quick disconnect” device which shall be designed to provide a positive seal of the supply side of the gas system when such device is separated.
(4) The flexible connector, direct plumbing pipe, or “quick disconnect” device shall be provided with protection from mechanical and impact damage and located to minimize the possibility of tampering.
(5) For direct plumbing which may be either hard pipe or flexible connector, the crossover point(s) shall be capped on the supply side to provide a positive seal and covered on the other side with a suitable protective covering.
(6) Suitable protective coverings for the connection device(s) when separated, shall be permanently attached to the device or flexible connector.
(7) When a “quick disconnect” device is installed, a 3 inch by 1¾ inch minimum size tag made of etched, metal-stamped or embossed brass, stainless steel, anodized or alclad aluminum not less than 0.020 inch thick or other approved material (e.g., 0.005 inch plastic laminates) shall be permanently attached on the exterior wall adjacent to the access to the “quick disconnect” device. Each tag shall be legibly inscribed with the following information using letters no smaller than ¼ inch high:
Do Not Use tools to Separate the “Quick-Disconnect” Device
(d) Gas pipe sizing. Gas piping systems shall be sized so that the pressure drop to any appliance inlet connection from any gas supply connection, when all appliances are in operation at maximum capacity, is not more than 0.5 inch water column as determined on the basis of test, or in accordance with Table 3280.705(d). When determining gas pipe sizing in the table, gas shall be assumed to have a specific gravity of 0.65 and rated at 1000 B.T.U. per cubic foot. The natural gas supply connection(s) shall be not less than the size of the gas piping but shall be not smaller than ¾ inch nominal pipe size.
(k) Identification of gas supply connections. Each manufactured home shall have permanently affixed to the exterior skin at or near each gas supply connection or the end of the pipe, a tag of 3 inches by 1¼ inches minimum size, made of etched, metal-stamped or embossed brass, stainless steel, anodized or alclad aluminium not less than 0.020 inch thick, or other approved material (e.g., 0.005 inch plastic laminates), which reads as follows.
Combination LP-Gas and Natural Gas System
This gas piping system is designed for use of either liquefied petroleum gas or natural gas.
Notice: BEFORE TURNING ON GAS BE CERTAIN APPLIANCES ARE DESIGNED FOR THE GAS CONNECTED AND ARE EQUIPPED WITH CORRECT ORIFICES. SECURELY CAP THIS INLET WHEN NOT CONNECTED FOR USE.
When connecting to lot outlet, use a listed gas supply connector for mobile homes rated at 100,000 Btuh or more; 250,000 Btuh or more.
Before turning on gas, make certain all gas connections have been made tight, all appliance valves are turned off, and any unconnected outlets are capped.
After turning on gas, test gas piping and connections to appliances for leakage with soapy water or bubble solution, and light all pilots.
The connector capacity indicated on this tag shall be equal to or greater than the total Btuh rating of all intended gas appliances.
(l) Gas supply connectors—(1) LP-Gas. A listed LP-Gas flexible connection conforming to the UL Standard for Pigtails, and Flexible Hose Connectors for LP-Gas, UL 569—Sixth Edition—1990, or equal shall be supplied when the fuel gas piping system is designed for the use of LP-Gas and cylinder(s) and regulator(s) are supplied.
(2) Appliance connections. All gas burning appliances shall be connected to the fuel piping. Materials as provided in § 3280.705(b) or listed appliance connectors shall be used. Listed appliance connectors when used shall not run through walls, floors, ceilings or partitions except for cabinetry and shall be 3 feet or less in length or 6 feet or less for cooking appliances. Connectors of aluminum shall not be used outdoors. A manufactured home containing an LPG or a combination LP-natural-gas-system may be provided with a gas outlet to supply exterior appliances when installed in accordance with the following:
(ii) The outlet shall be provided with an approved “quick-disconnect” device, which shall be designed to provided a positive seal on the supply side of the gas system when the appliance is disconnected. A shutoff valve of the nondisplaceable rotor type conforming to ANSI Z21.15–1989, Manually Operated Gas Valves, shall be installed immediately upstream of the quick-disconnect device. The complete device shall be provided as part of the original installation.
(3) Valves. A shutoff valve shall be installed in the fuel piping at each appliance inside the manufactured home structure, upstream of the union or connector in addition to any valve on the appliance and so arranged to be accessible to permit serving of the appliance and removal of its components. The shutoff valve shall be located within 6 feet of a cooking appliance and within 3 feet of any other appliance. A shutoff valve may serve more than one appliance if located as required above. Shut off valve used shall be of the nondisplaceable rotor type and conform ANSI Z21.15–1989, Manually Operated Gas Valve.
48. Section 3280.706 is proposed to be amended by revising paragraphs (b)(1), (b)(3), and (b)(4) to read as follows:
§ 3280.706 Oil piping systems.
(b) * * *
(1) Steel or wrought-iron pipe shall comply with ANSI B 36.10–1985, Welded and Seamless Wrought Steel Pipe. Threaded copper or brass pipe in iron pipe sizes may be used.
* * * * *
(3) Copper tubing shall be annealed type, Grade K or L conforming to the Standard Specification for Seamless Copper Water Tube, ASTM–B 88–89(M), or shall comply with the Standard Specification for Seamless Copper Tube for Air Conditioning and Refrigeration Field Service, ASTM B280–88.
(4) Steel tubing shall have a minimum wall thickness of 0.032 inch for diameters up to \( \frac{1}{2} \) inch and 0.049 inch for diameters \( \frac{1}{2} \) inch and larger. Steel tubing shall be constructed in accordance with the Specification for Electric-Resistance Welded Coiled Steel Tubing for Gas and Field Oil Lines, ASTM, A539–90a, and shall be externally corrosion protected.
* * * * *
49. Section 3280.707 is proposed to be amended by revising paragraph (d)(2) introductory text to read as follows:
§ 3280.707 Heat producing appliances.
* * * * *
(d) * * * *
(2) All gas and oil-fired automatic storage water heaters shall have a recovery efficiency, E, and a standby loss, S, as described below. The method of test of E and S shall be as described in Section 2.7 of Gas Water Heaters, Vol. I, Storage Water Heaters with Input/Ratings of 75,000 BTU per hour or less, ANSI Z21.10.1–1990, except that for oil-fired units. CF = 1.0, Q = total gallons of oil consumed and H = total heating value of oil in BTU/gallon.
* * * * *
50. Section 3280.708 is proposed to be amended by revising paragraphs (b)(3) and (c)(1) to read as follows:
§ 3280.708 Exhaust duct system and provisions for the future installation of a clothes dryer.
* * * * *
(b) * * * *
(3) A moisture lint duct system consisting of a complete access face (hole) through the wall or floor cavity with a cap or cover on the interior and exterior of the cavity secured in such a manner that they can be removed by a common household tool shall be provided. The cap or cover in place shall limit air infiltration and be designed to resist the entry of water or rodents. The manufacturer is not required to provide the moisture-lint exhaust duct or the termination fitting. The manufacturer shall provide written instructions to the owner on how to complete the exhaust duct installation in accordance with provisions of § 3280.708(a) (1) through (5).
(c) * * * *
(1) Provide a roughed in moisture-lint exhaust duct system consisting of a complete access space (hole) through the wall or floor cavity with a cap or cover on the interior and exterior of the cavity which are secured in such a manner that they can be removed by the use of common household tools. The cap or cover in place shall limit air filtration and be designed to resist the entry of water or rodents into the home. The manufacturer is not required to provide the moisture-lint exhaust duct or the termination fitting.
* * * * *
51. Section 3280.709 is proposed to be amended by revising paragraph (e)(6) to read as follows:
§ 3280.709 Installation of appliances.
* * * * *
(e) * * * *
(6) When an external heating appliance or combination cooling/heating appliance is to be field installed, the home manufacturer shall make provision for proper location of the connections to the supply and return air systems. The manufacturer is not required to provide said appliance(s). The preparation by the manufacturer for connection to the home’s supply and return air system shall include all fittings and connection ducts to the main duct and return air system such that the installer is only required to provide:
(i) The appliance;
(ii) Any appliance connections to the home; and
(iii) The connecting duct between the external appliance and the fitting installed on the home by the manufacturer. The above connection preparations by the manufacturer do not apply to supply or return air systems designed only to accept external cooling (i.e., self contained air conditioning systems, etc.)
* * * * *
52. Section 3280.710 is proposed to be amended by revising paragraph (b)(1) to read as follows:
§ 3280.710 Venting, ventilation and combustion air.
* * * * *
(b) * * * *
(1) Components shall be securely assembled and properly aligned at the factory in accordance with the appliance manufacturer’s instructions except vertical or horizontal sections of the roof line or wall line may be installed at the site. Sectional venting systems shall be listed for such applications and installed in accordance with the terms of their listings and manufacturers’ instructions. In cases where sections of the venting system are removed for transportation, a label shall be permanently attached to the appliance indicating the following:
Sections of the venting system have not been installed. Warning—do not operate the appliance until all sections have been assembled and installed in accordance with the manufacturer’s instructions.
* * * * *
53. Section 3280.713 is proposed to be revised to read as follows:
§ 3280.713 Accessibility.
Every appliance shall be accessible for inspection, service, repair, and replacement without removing permanent construction. For those purposes, inlet piping supplying the appliance shall be considered permanent construction. Sufficient room shall be available to enable the operator to observe the burner, control, and ignition means while starting the appliance.
54. Section 3280.714 is proposed to be amended by revising paragraph (a) to read as follows:
§ 3280.714 Appliances, Cooling.
(a) Every air conditioning unit or a combination air conditioning and heating unit shall be listed or certified by a nationally recognized testing agency for the application for which the unit is intended and installed in accordance with the terms of its listing.
(1) Mechanical air conditioners shall be rated in accordance with the ARI Standard 210/240–89 Unitary Air Conditioning and Air Source Unitary Heat Pump Equipment and certified by ARI or other nationally recognized testing agency capable of providing follow-up service.
(i) Electric motor-driven unitary cooling systems with rated capacity less than 65,000 BTU/Hr when rated at ARI Standard rating conditions in ARI Standard 210/240–89 Unitary Air Conditioning and Air Source Unitary Heat Pump Equipment, shall show energy efficiency (EER) values not less than 7.2.
(ii) Heat pumps shall be certified to comply with all the requirements of the ARI Standard 210/240–89 Unitary Air Conditioning and Air Source Unitary Heat Pump Equipment. Electric motor-driven vapor compression heat pumps with supplemental electrical resistance heat shall be sized to provide by compression at least 60 percent of the calculated annual heating requirements
for the manufactured home being served. A control shall be provided and set to prevent operation of supplemental electrical resistance heat at outdoor temperatures above 40 °F, except for defrost operation.
(iii) Electric motor-driven vapor compression heat pumps with supplemental electric resistance heat conforming to ARI Standard 210/240–89 Unitary Air Conditioning and Air Source Unitary Heat Pump Equipment shall show coefficient of performance ratios not less than shown below:
| Outdoor Air Temperature | COP |
|-------------------------|-----|
| 47 °F | 17 |
| 2.5 | 1.7 |
(2) Gas-fired absorption air conditioners shall be listed or certified in accordance with ANSI Standard Z21.40.1–1981 “Gas-fired Absorption Summer Air Conditioning Appliances” with addenda la-1982, and certified by AGA or another nationally recognized testing agency capable of providing follow-up service.
(3) Direct refrigerating systems serving any air conditioning or comfort-cooling system installed in a manufactured home shall employ a type of refrigerant that ranks no lower than Group 5 in the Underwriters’ Laboratories, Inc. “Classification of Comparative Life Hazard of Various Chemicals.”
(4) When a cooling or heat pump coil and air conditioner blower are installed with a furnace or heating appliance, they shall be tested and listed in combination for heating and safety performance by a nationally recognized testing agency.
(5) Cooling or heat pump indoor coils and outdoor sections shall be certified, listed and rated in combination for capacity and efficiency by a nationally recognized testing agency (ies). Rating procedures shall be based on U.S. Department of Energy test procedures.
55. Section 3280.715 is proposed to be amended by revising the last sentence in paragraph (b)(4) and paragraph (e)(1) to read as follows:
§ 3280.715 Circulating air system.
(b) * * *
(4) * * * However, in the event that doors are undercut, they shall be undercut a minimum of 2 inches and not more than 2-½ inches, as measured from the top surface of the floor decking to the bottom of the door and no more than one half of the free air area so provided shall be counted as return air area.
(e) * * *
(1) Be made of a material classified 94V–0 or 94V–1 when tested as described in Underwriters’ Laboratories, Inc., Tests for Flammability of Plastic Materials for Parts in Devices and Appliances, UL94–Fourth Edition–1991.
Subpart I—Electrical Systems
56. Section 3280.801 is proposed to be amended by revising paragraphs (a), (b), (c), and (e) to read as follows:
§ 3280.801 Scope.
(a) Subpart I of this standard and part A of Article 550 of the National Electrical Code (NFPA No. 70–1990) cover the electrical conductors and equipment installed within or on manufactured homes and the conductors that connect manufactured homes to a supply of electricity.
(b) In addition to the requirements of this standard and Article 550 of the National Electrical Code (NFPA No. 70–1990) the applicable portions of other Articles of the National Electrical Code shall be followed covering electrical installations in manufactured homes. Wherever the requirements of this standard differ from the National Electrical Code, this standard shall apply.
(c) The provisions of this standard apply to manufactured homes intended for connection to a wiring system nominally rated 120/240 volts, 3-wire AC, with grounded neutral.
(e) Aluminum conductors, aluminum alloy conductors, and aluminum core conductors such as copper clad aluminum; are not acceptable for use in branch circuit wiring in manufactured homes.
57. Section 3280.803 is proposed to be amended by revising paragraphs (k)(1), the introductory text of (k)(3), (k)(3)(ii) and (k)(3)(iii), and by removing paragraph (1) to read as follows:
§ 3280.803 Power supply.
(k) * * *
(1) One mast weatherhead installation installed in accordance with Article 230 of the National Electrical Code NFPA No. 70–1990 containing four continuous insulated, color-coded, feeder conductors, one of which shall be an equipment grounding conductor; or
(3) Service equipment installed on the manufactured home in accordance with Article 230 of the National Electrical Code NFPA No. 70–1990; and
(ii) Exterior equipment, or the enclosure in which it is installed shall be weatherproof and installed in accordance with Article 373–2 of the National Electrical Code NFPA No. 70–1990. Conductors shall be suitable for use in wet locations;
(iii) The neutral conductor shall be connected to the system grounding conductor on the supply side of the main disconnect in accordance with Articles 250–23, 25, and 53 of NFPA No. 70–1990.
58. Section 3280.804 is proposed to be amended by revising paragraphs (a) and (j) and by adding new paragraphs (k) and (l) at the end of the section to read as follows:
§ 3280.804 Disconnecting means and branch-circuit protective equipment.
(a) The branch-circuit equipment shall be permitted to be combined with the disconnecting means as a single assembly. Such a combination shall be permitted to be designated as a distribution panelboard. If a fused distribution panelboard is used, the maximum fuse size of the mains shall be plainly marked with lettering at least ¼-inch high and visible when fuses are changed. See section 110–22 of the National Electrical Code (NFPA No. 70–1990) concerning identification of each disconnecting means and each service, feeder, or branch circuit at the point where it originated and the type marking needed.
(j) A 3 inch by 1-¾ inch minimum size tag made of etched, metal-stamped or embosses brass, stainless steel, anodized or alclad aluminum not less than 0.020 inch thick, or other approval material (e.g., 0.005 inch plastic laminates) shall be permanently affixed on the outside adjacent to the feeder assembly entrance and shall read: This connection for 120/240 Volt, 3-Pole, 4-Wire, 60 Hertz,—Ampere Supply. The correct ampere rating shall be marked on the blank space.
(k) When a home is provided with installed service equipment, a single disconnecting means for disconnecting the branch circuit conductors from the service entrance conductors shall be provided in accordance with part H of Article 230 of the National Electrical Code, NFPA No. 70–1990. The disconnecting means shall be listed for use as service equipment. The disconnecting means may be combined with the disconnect required by
§ 3280.804(c). The disconnecting means shall be rated not more than the ampere supply or service capacity indicated on the tag required by paragraph (1) of this section.
(1) When a home is provided with installed service equipment, the electrical nameplate required by § 3280.804(j) shall read: "This connection for 120/240 volt, 3 pole, 3 wire, 60 Hertz,—Ampere Supply." The correct ampere rating shall be marked in the blank space.
59. Section 3280.805 is proposed to be amended by revising paragraphs (a)(2), (a)(3)(ii), (iv), and (v) to read as follows:
§ 3280.805 Branch circuits required.
(a) * * *
(2) Small appliances. For the small appliance load in kitchen, pantry dining room and breakfast rooms of manufactured homes, two or more 20-ampere appliance branch circuits, in addition to the branch circuit specified in § 3280.805(a)(1), shall be provided for all receptacle outlets in these rooms, and such circuits shall have no other outlets. Receptacle outlets supplied by at least two appliance receptacle branch circuits shall be installed in the kitchen.
(3) * * *
(ii) For fixed appliances on a circuit without lighting outlets, the sum of rated amperes shall not exceed the branch-circuit rating. Motor loads on other continuous duty loads shall not exceed 80 percent of the branch circuit rating.
(iv) The rating of range branch circuit shall be based on the range demand as specified or ranges in § 3280.811, Item B(5) of Method 1. For central air conditioning, see Article 440 of the National Electrical Code (NFPA No. 70–1990).
(v) Where a laundry area is provided, a 20 ampere branch circuit shall be provided to supply laundry receptacle outlets. This circuit shall have no other outlets. See § 3280.806(a)(7).
60. Section 3280.806 is proposed to be amended by revising paragraphs [a](2), (b), (d)(2), (d)(7), and (d)(8) to read as follows:
§ 3280.806 Receptacle outlets.
(a) * * *
(2) Installed according to section 210–7 of the National Electrical Code (NFPA No. 70–1990).
* * * * * * *
(b) All 120 volt single phase, 15 and 20 ampere receptacle outlets, including receptacles in light fixtures, installed outdoors, or in compartments accessible from the outdoors, and in bathrooms shall have ground-fault circuit protection for personnel. Feeders supplying branch circuits may be protected by a ground-fault circuit-interrupter in lieu of the provision for such interrupters specified above. Receptacles for laundry areas, also located in bathroom areas are exempt from this requirement.
(d) * * *
(2) Adjacent to the refrigerator and free-standing gas-range space. A duplex receptacle may serve as the outlet for a countertop and a refrigerator.
* * * * * * *
(7) In laundry areas within 6 feet of the intended location of the appliance(s).
(8) At least one receptacle outlet shall be installed outdoors.
* * * * * * *
61. Section 3280.807 is proposed to be amended by revising paragraphs (c) and (e) and by removing paragraph (g) to read as follows:
§ 3280.807 Fixtures and appliances.
(c) If a lighting fixture is provided over a bathtub or in a shower stall, it shall be of the enclosed and gasketed type, listed for wet locations. See also Article 410–4(d) of the National Electrical Code NFPA No 70–1990.
(e) Any combustible wall or ceiling finish exposed between the edge of a fixture canopy, or pan and an outlet box shall be covered with non-combustible or limited combustible material.
* * * * * * *
62. Section 3280.808 is proposed to be amended by revising paragraphs (a) and (m) and by adding new paragraphs (q), (r), and (s) to read as follows:
§ 3280.808 Wiring methods and materials.
(a) Except as specifically limited in this part, the wiring methods and materials specified in the National Electrical Code (NFPA No. 70–1990) shall be used in manufactured homes.
(m) Outlet boxes of dimensions less than those required in Table 370–8(a) of the National Electrical Code (NFPA No. 70–1990) shall be permitted provided the box has been tested and approved for the purpose.
(q) A substantial brace for securing a box, fitting or cabinet shall be as described in the National Electrical Code, NFPA 70–1990 Article 370–13(d), or the brace, including the fastening mechanism to attach the brace to the home structure, shall withstand a force of 50 lbs. applied to the brace at the intended point(s) of attachment for the box in a direction perpendicular to the surface in which the box is installed.
(r) Outlet boxes shall fit closely to the openings in combustible wall and ceilings with a maximum of a ¼ inch gap. They shall be flush with the finish surface or project therefrom.
(s) Where the sheathing of NM cable has been cut or damaged and visual inspection reveals that the conductor and its insulation has not been damaged, it shall be permitted to repair the cable sheath with electrical tape which provides equivalent protection to the sheath.
63. Section 3280.809 is proposed to be amended by adding at the end of paragraph (b)(1) to read as follows:
§ 3280.809 Grounding
(b) * * *
(1) * * * However, when service equipment is installed on the manufactured home, the neutral and the ground bus may be connected in the distribution panel.
* * * * * * *
64. Section 3280.810 is proposed to be revised to read as follows:
§ 3280.810 Electrical testing.
(a) Dielectric strength test. The wiring of each manufactured home shall be subjected to a 1-minute, 900 to 1079 volt dielectric strength test (with all switches closed) between live parts and the manufactured home ground, and neutral and the manufactured home ground. Alternatively, the test may be performed at 1080 to 1250 volts for 1 second. This test shall be performed after branch circuits are complete and after fixtures or appliances are installed. Fixtures or appliances which are listed shall not be required to withstand the dielectric strength test.
(b) Each manufactured home shall be subject to:
(1) A continuity test to assure that metallic parts are properly bonded;
(2) Operational test to demonstrate that all equipment, except water heaters, electric furnaces, dishwashers, clothes washers/dryers, and portable appliances, is connected and in working order; and
(3) Polarity checks to determine that connections have been properly made. Visual verification shall be an acceptable check.
65. Section 3280.811 is proposed to be amended by revising the introductory text of paragraph (a), paragraph (a)(1)(iv), the introductory paragraph (a)(5), (a)(6), and the introductory text of paragraph (b) to read as follows:
§ 3280.811 Calculations.
(a) The following method shall be employed in computing the supply cord and distribution-panelboard load for each feeder assembly for each manufactured home and shall be based on a 3-wire, 120/240 volt supply with 120 volt loads balanced between the two legs of the 3-wire system. The total load for determining power supply by this method is the summation of:
(1) * * *
(iv) First 3,000 total watts at 100 percent plus remainder at 35 percent = watts to be divided by 240 volts to obtain current (amperes) per leg.
* * * * *
(5) Derive amperes for free-standing range (as distinguished from separate ovens and cooking units) by dividing values below by 240 volts.
* * * * *
(6) If outlets or circuits are provided for other than factory-installed appliances, include the anticipated load. The following example is given to illustrate the application of this Method of Calculation:
Example. A manufactured home is 70 × 10 feet and has two portable appliance circuits, a 1000 watt 240 volt heater, a 200 watt 120 volt exhaust fan, a 400 watt 120 volt dishwasher and a 7000 watt electric range.
| Lighting and small appliance load | Watts |
|-----------------------------------|-------|
| Lighting 70 × 10 × 3 | 2,100 |
| Small appliance 1,500 × 2 | 3,000 |
| Total | 5,100 |
| 1st 3,000 W at 100 pct | 3,000 |
| Remainder (5,100 − 3,000 = 2,100) at 35 pct | 735 |
| Total | 3,735 |
3,735/240 = 15.5A per leg
1,000 W (heater)/240 = 4.1A
200 W (fan)/120 = 1.7A
400 W (dishwasher)/120 = 3.3A
7,000 W (range) × 0.8/240 = 233.3
| Ampere per leg | A | B |
|----------------|-----|-----|
| Lighting and appliances | 15.5| 15.5|
| Heater (240 v) | 4.1 | 4.1 |
| Fan (115 v) | 1.7 | |
| Dishwasher (115 v) | | 3.3 |
| Range | 23.3| 23.3|
| Totals | 44.6| 46.2|
Note: Based on the higher current calculated for either leg, use one 50-A supply cord.
(b) The following is an optional method of calculation for lighting and appliance loads for manufactured homes served by single 3-wire 120/240 volt set of feeder conductors with an ampacity of 100 or greater. The total load for determining the feeder ampacity may be computed in accordance with the following table instead of the method previously specified. Feeder conductors whose demand load is determined by this optional calculation shall be permitted to have the neutral load determined by section 220–22 of the National Electrical Code (NFPA No. 70-1990). The loads identified in the table as "other load" and as "Remainder of other load" shall include the following:
* * * * *
66. Section 3280.813 is proposed to be amended by revising paragraph (a) to read as follows:
§ 3280.813 Outdoor outlets, fixtures, air conditioning equipment, etc.
(a) Outdoor fixtures and equipment shall be listed for use in wet locations, except that if located on the underside of the home or located under roof extensions or similarly protected locations, they may be listed for use in damp locations.
Dated: February 10, 1992.
Arthur J. Hill,
Assistant Secretary for Housing-Federal Housing Commissioner.
[FR Doc. 92–3603 Filed 2–21–92; 8:45 am]
BILLING CODE 4210–27–M
Part IV
Department of the Interior
Bureau of Indian Affairs
25 CFR Parts 81 and 82
Tribal Consultation on Proposed Regulations; Proposed Rule
DEPARTMENT OF THE INTERIOR
Bureau of Indian Affairs
25 CFR Parts 81 and 82
Tribal Consultation on Proposed Regulations
AGENCY: Bureau of Indian Affairs, Interior.
ACTION: Tribal consultation meetings on proposed rules.
SUMMARY: Notice is hereby given that the Bureau of Indian Affairs (BIA) will conduct consultation meetings to obtain written and oral comments concerning regulations being proposed to be published after June 1992 to govern the calling and conducting of Secretarial elections and the handling of petitions for Secretarial action. A consultation booklet containing drafts of the proposed text for both parts, the text of the current regulations, the text of recent Federal legislation which precipitated the changes and other pertinent information is being issued.
DATES: Meetings will be held 9 a.m. until 6 p.m. with a break for lunch between 1 p.m. and 2 p.m. on the dates listed below. Written comments concerning the consultation hearings must be received no later than April 20, 1991.
March 10, 1992—Portland, Oregon.
March 12, 1992—Anchorage, Alaska.
March 31, 1992—Minneapolis, Minnesota.
April 2, 1992—Mesa, Arizona.
ADDRESSES: Meetings will be held at the following locations:
Cypress Inn, 9707 S.E. Stark, Portland, Oregon (503) 252–8247.
The Anchorage Hilton, 500 West Third Avenue, Anchorage, Alaska (907) 272–7411.
Park Inn International, 1313 Nicollet Mall, Minneapolis, Minnesota (612) 332–0371.
Lexington Hotel, South Country Club Drive, Suite 1410, Mesa, Arizona (602) 964–2897.
Submit all comments to the Division of Tribal Government Services, Bureau of Indian Affairs, Mail Stop 2612, 1849 "C" Street NW., Washington, DC 20240–0001. A consultation booklet for the scheduled meetings is being distributed to federally recognized Indian tribes. The booklets will also be available from the addresses listed above.
FOR FURTHER INFORMATION CONTACT: Joyce Grisham, Division of Tribal Government Services, Branch of Tribal Relations, Bureau of Indian Affairs, 1849 "C" Street NW., Washington, DC 20240–0001, telephone number (202) 208–7445.
SUPPLEMENTARY INFORMATION:
Background Information, Part 81
The purpose of the proposed revision to Part 81 is to: (a) Reflect the amendments made to section 16 of the Indian Reorganization Act (The Act of June 18, 1934, 48 Stat. 984) by the Act of November 1, 1988, [Pub. L. 100–581: 102 Stat. 2938]; (b) reflect the amendments made to Section 17 of the IRA by the Act of May 24, 1990, [Pub. L. 101–301, 104 Stat. 207]; (c) correct demonstrated weaknesses and clarify confusing language in existing regulations, and (d) update procedures to reflect current technical and governmental developments. Each of these are addressed briefly below.
(a) The primary effects of Public Law 100–581 was to establish timeframes within which the Secretary of the Interior must call and conduct Secretarial elections, and to provide for significant changes in the guidelines for approval or disapproval of governing documents by the Secretary. The proposed text of part 81 provides for the implementation of these provisions in an orderly manner.
(b) The primary effects of Public Law 101–301, as it relates to these regulations was to enable additional tribes to petition for a charter of incorporation, and to remove the specific requirement for a Secretarial election on all charter ratifications. The proposed text of part 81 as it relates to charters reflects these changes.
(c) Some examples of demonstrated weaknesses which have been corrected and confusing language which has been clarified are: (1) The language regarding inclusion on the voting list of those who may or may not become 18 before the election date was confusing. The proposed revision provides for the election date to be set prior to the issuance of the notice to voters of the necessity to register, and (2) lists of the specific information to be included in the notice of necessity to register and in the notice of the election are included in the proposed revision to prevent inadvertent omission of essential items.
(d) Procedures which have been updated in the proposed revision include provision for the use of voting machines where they are available and the election board chooses to use them.
Background Information, Part 82
The purpose for the revision of part 82 is (a) to bring the definitions and terminology into conformity with the revised part 81 and (b) to clarify confusing language in existing regulations.
(a) Definitions affected are (1) officer in charge; (2) member; (3) tribe, and (4) tribal governing body.
(b) Two of the sections which have been clarified are those dealing with (1) from whom and for what purposes petitions will be recognized by the Secretary, and (2) the actions to be taken on the petition.
Dated: February 13, 1992.
William D. Bettenberg,
Acting Assistant Secretary—Indian Affairs.
[FR Doc. 92–4188 Filed 2–21–92; 8:45 am]
BILLING CODE 4310–02–M
## Reader Aids
### INFORMATION AND ASSISTANCE
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### FEDERAL REGISTER PAGES AND DATES, FEBRUARY
| Pages | Date |
|-------|------------|
| 3909–4146 | 3 |
| 4147–4356 | 4 |
| 4357–4542 | 5 |
| 4543–4690 | 6 |
| 4691–4834 | 7 |
| 4835–4924 | 10 |
| 4925–5050 | 11 |
| 5051–5226 | 12 |
| 5227–5364 | 13 |
| 5365–5786 | 14 |
| 5787–5972 | 18 |
| 5973–6066 | 19 |
| 6067–6180 | 20 |
| 6181–6284 | 21 |
| 6285–6456 | 24 |
---
### CFR PARTS AFFECTED DURING FEBRUARY
At the end of each month, the Office of the Federal Register publishes separately a List of CFR Sections Affected (LSA), which lists parts and sections affected by documents published since the revision date of each title.
#### 3 CFR
- Executive Orders:
- August 31, 1917 (Revoked in part by PLO 6922): 4856, 12789, 5225
- Proclamations:
- 6402: 4833
- 6403: 5973
- 6404: 6065
- Administrative Orders:
- Memoranda:
- February 10, 1992: 5365
- February 10, 1992: 5367
- Presidential Determinations:
- 92–11 of January 28, 1992: 5787
- 92–13 of February 4, 1992: 5789
#### 10 CFR
- 2: 4152, 5791
- 15: 4152
- 54: 4912
#### 11 CFR
- Proposed Rules:
- Ch. I: 4166, 6299
- 30: 6077
- 40: 6077
- 70: 6077
- 100: 4168
- 170: 4744
- 171: 4744
#### 12 CFR
- Ch. XV: 4715
- 303: 5814
- 335: 4699
- 932: 6187
#### 5 CFR
- 2636: 5369
#### 7 CFR
- 1: 3909
- 271: 3909
- 278: 3909, 3913
- 279: 3909
- 907: 3916, 4691, 4835, 5975
- 916: 3918
- 918: 4147
- 944: 4148
- 1007: 3920
- 1065: 4150, 4151
- 1413: 3921
- 1421: 4553
- 1700: 6285
- 1710: 4513, 5931
- 1940: 3922
- 1942: 4357
- 1980: 4336, 4358, 6067
#### 13 CFR
- 121: 4837, 4839, 6290
#### 14 CFR
- 39: 3927–3936, 4153, 4842, 4848, 4925, 5051, 5369–5379, 5976, 6068, 6070, 6190
- 91: 5877
- 95: 6192
- 97: 4360, 4361, 5977, 5980
- 1203b: 4926
- 1212: 4828
- 1214: 4544
#### 8 CFR
- 273: 3961, 4793
- 319: 3963
- 703: 4164, 4378
- 959: 4164
- 998: 3965
- 103: 3925, 5227, 6181
- 214: 6183
- 251: 6183
- 258: 6183
- 299: 6181
#### 9 CFR
- 75: 5210
- 78: 3926
- 92: 5931
- 105: 5210
- 92: 5294
#### 15 CFR
- 29b: 4715
- 768: 4553
- 770: 4553
- 771: 4553
- 772: 4553
- 773: 4553
- 774: 4553
| CFR | Section | Page |
|-------|---------|------|
| 41 | 101-26 | 3949 |
| | 101-38 | 4373 |
| | Proposed Rules: | |
| | Ch. 50 | 6301 |
| | Ch. 60 | 6301 |
| | Ch. 61 | 6301 |
| 42 | 418 | 4516 |
| | 440 | 4085, 4516 |
| | 441 | 4085, 4516 |
| | 482 | 4516 |
| | 483 | 4516 |
| | 488 | 4516 |
| 43 | Proposed Rules: | |
| | 3180 | 4177 |
| | Public Land Orders: | |
| | 1176 (Revoked in part by PLO 6923) | 5987 |
| | 3160 | 5211 |
| | 6919 | 5211 |
| | 6921 | 4144 |
| | 6922 | 4856 |
| | 6923 | 5987 |
| 44 | Proposed Rules: | |
| | 67 | 5510 |
| 45 | Ch. XXV | 5298 |
| | 235 | 5048 |
| | Proposed Rules: | |
| | 1150 | 6303 |
| | 1155 | 6206 |
| | 1180 | 6208 |
| 46 | 515 | 4578 |
| | 560 | 4578 |
| | 572 | 4578 |
| | 580 | 3950 |
| | 581 | 3950 |
| | 583 | 3950 |
| | Proposed Rules: | |
| | Ch. I | 4744 |
| | Ch. II | 4744 |
| | Ch. III | 4744 |
| | 586 | 6210 |
| 47 | 43 | 5510 |
| | 63 | 5510 |
| | 64 | 4373, 4740, 5391 |
| | 69 | 4856 |
| | 73 | 3951, 3952, 4163, 4857, 5391-5394, 5861, 5862, 6074-6076, 6202 |
| | Proposed Rules: | |
| | 2 | 5993 |
| | 63 | 4391 |
| | 73 | 3982, 4179, 4180, 4859, 5412, 5413, 5870, 6083, 6084, 6210 |
| | 74 | 4592 |
| | 90 | 4180 |
| 48 | 211 | 4741 |
| | 249 | 5076 |
| | 252 | 4741 |
**LIST OF PUBLIC LAWS**
*Note:* No public bills which have become law were received by the Office of the Federal Register for inclusion in today's List of Public Laws.
Last List February 21, 1992
| Title | Stock Number | Price | Revision Date |
|--------------------------------------------|--------------|--------|---------------|
| Complete 1992 CFR set | 620.00 | | 1992 |
| Microfiche CFR Edition: | | | |
| Complete set (one-time mailing) | 185.00 | | 1989 |
| Complete set (one-time mailing) | 188.00 | | 1990 |
| Subscription (mailed as issued) | 188.00 | | 1991 |
| Subscription (mailed as issued) | 188.00 | | 1992 |
| Title | Stock Number | Price | Revision Date |
|--------------------------------------------|--------------|--------|---------------|
| Individual copies | 2.00 | | 1992 |
1 Because Title 3 is an annual compilation, this volume and all previous volumes should be retained as a permanent reference source.
2 The July 1, 1985 edition of 32 CFR Parts 1–189 contains a note only for Parts 1–39 inclusive. For the full text of the Defense Acquisition Regulations in Parts 1–39, consult the three CFR volumes issued as of July 1, 1984, containing those parts.
3 The July 1, 1985 edition of 41 CFR Chapters 1–100 contains a note only for Chapters 1 to 49 inclusive. For the full text of procurement regulations in Chapters 1 to 49, consult the eleven CFR volumes issued as of July 1, 1984 containing those chapters.
4 No amendments to this volume were promulgated during the period Jan. 1, 1987 to Dec. 31, 1990. The CFR volume issued January 1, 1987, should be retained.
5 No amendments to this volume were promulgated during the period Apr. 1, 1990 to Mar. 31, 1991. The CFR volume issued April 1, 1990, should be retained.
6 No amendments to this volume were promulgated during the period July 1, 1989 to June 30, 1991. The CFR volume issued July 1, 1989, should be retained.
7 No amendments to this volume were promulgated during the period July 1, 1990 to June 30, 1991. The CFR volume issued July 1, 1990, should be retained.
|
PROJECT VICINITY
Alaskan Way Viaduct
Cracked Column in the Viaduct
Damaged Rebar in the Viaduct
What is in Chapter 1?
Chapter 1 describes where the project is located, who is leading the project, the purpose of this document, and the purpose and need for the project.
1 What is the Alaskan Way Viaduct Replacement Project?
The Alaskan Way Viaduct Replacement Project (project) is located in downtown Seattle, Washington. The project would replace State Route (SR) 99 from approximately S. Royal Brougham Way to Roy Street and remove the existing viaduct (SR 99) from approximately S. King Street to the Battery Street Tunnel.
2 What are the project limits and why were they selected?
The project limits begin at approximately S. Royal Brougham Way in the south and continue north to Roy Street, as shown in Exhibit 1-1. The project limits represent logical end points (termini) for transportation improvements and environmental review based on identified project needs, which include providing a facility with improved earthquake resistance. S. Royal Brougham Way provides an important link to other regional facilities, such as I-5, I-90, and SR 519, and Roy Street is where traffic exits and enters SR 99.
Between S. Royal Brougham Way and S. King Street, this project would begin and the S. Holgate Street to S. King Street Viaduct Replacement Project will end; there would be an area of transition between the two projects. The S. Holgate Street to S. King Street Viaduct Replacement Project will be built to transition into the No Build Alternative or any of the proposed build alternatives.
Elliott Bay represents the project limit to the west and I-5 is the project limit to the east, though the potentially affected area to the west and east depends on the resource.
Where would the construction staging sites be located?
Proposed construction staging sites for the project are located both within and outside of the project limits, as shown in Exhibit 1-2. The project area is located in a highly urban environment where space for construction staging is limited. Because of this, potential staging sites have been proposed outside of the project limits to ensure that sufficient staging areas are available. The contractor may identify additional staging sites as needed and would be responsible for obtaining environmental approvals for those sites.
3 Who is leading this project?
This project is being led by a partnership of three agencies: the Federal Highway Administration (FHWA), Washington State Department of Transportation (WSDOT), and City of Seattle (City). FHWA is the federal lead agency for this project and is responsible for ensuring that federal regulations are followed. FHWA has the primary responsibility for the content and accuracy of National Environmental Policy Act (NEPA) documents and has approval authority for all expenditures of
What is the relationship between the S. Holgate Street to S. King Street Viaduct Replacement Project and this project?
Chapter 3, Question 12 explains the relationship between the S. Holgate Street to S. King Street Viaduct Replacement project and the Alaskan Way Viaduct Replacement Project.
federal-aid highway funds. WSDOT owns SR 99 and the viaduct and is responsible for structural inspections and major maintenance. The City is responsible for viaduct traffic operations and minor maintenance. In addition, the City owns and maintains Alaskan Way, the area underneath the viaduct, and many of the utilities located in the project area. WSDOT has the responsibility to evaluate the proposed alternatives under the State Environmental Policy Act (SEPA) and is the SEPA lead agency for the project.
4 Why are the lead agencies preparing this Final EIS?
This Final Environmental Impact Statement (EIS) is being prepared to meet obligations under NEPA and SEPA. This Final EIS does the following:
- Documents changes made to the proposed build alternatives since the 2010 Supplemental Draft EIS was published
- Identifies the preferred alternative and explains why it is preferred
- Includes responses to public comments on the following environmental documents associated with replacing the Alaskan Way Viaduct:
- 2004 Alaskan Way Viaduct and Seawall Replacement Project Draft EIS
- 2006 Alaskan Way Viaduct and Seawall Replacement Project Supplemental Draft EIS
- 2010 Alaskan Way Viaduct Replacement Project Supplemental Draft EIS
5 What is the purpose of the Alaskan Way Viaduct Replacement Project and why it is needed?
Purpose and Need for the Proposed Action
The Alaskan Way Viaduct is seismically vulnerable and at the end of its useful life. To protect public safety and provide essential vehicle capacity to and through downtown Seattle, the viaduct must be replaced. Because this facility is at risk of sudden and catastrophic failure in an earthquake, FHWA, WSDOT, and the City of Seattle seek to implement a replacement as soon as possible. Moving people and goods to and through downtown Seattle is vital to maintaining local, regional, and statewide economic health. FHWA, WSDOT, and the City of Seattle have identified the following purposes and needs the project should address.
The purpose of the proposed action is to provide a replacement transportation facility that will:
- Reduce the risk of catastrophic failure in an earthquake by providing a facility that meets current seismic safety standards.
- Improve traffic safety.
- Provide capacity for automobiles, freight, and transit to efficiently move people and goods to and through downtown Seattle.
- Provide linkages to the regional transportation system and to and from downtown Seattle and the local street system.
- Avoid major disruption of traffic patterns due to loss of capacity on SR 99.
- Protect the integrity and viability of adjacent activities on the central waterfront and in downtown Seattle.
The following paragraphs provide further information regarding the needs underlying each of these project purposes that are listed above.
Reduce Seismic Vulnerability
Because of its seismic vulnerability, the Alaskan Way Viaduct must be removed. The viaduct is deteriorating and at risk of sudden and catastrophic failure in an earthquake because of its design, age, and location. The viaduct was constructed in the 1950s and conformed to the design...
standards of that time. The structure was designed to seismic criteria that are less than one-third as stringent as today’s criteria.\(^1\) The viaduct’s existing foundations are embedded in liquefiable soil, and the structure is deteriorating. These factors make the structure vulnerable to earthquakes and necessitate its removal.\(^2\) The replacement for SR 99 must meet current standards for earthquake resistance.
**Improve Traffic Safety**
The viaduct and Battery Street Tunnel do not meet current roadway design standards and have deficiencies that need to be improved.\(^3\) Current design standards reflect the latest agreement among the states and FHWA on how to safely design new and upgraded highways. As now configured, the viaduct does not meet current standards for lane width, shoulder width, and stopping sight distance.\(^4\) The Battery Street Tunnel does not meet current standards for lane width, shoulder width,\(^5\) and stopping sight distance.\(^6\) North of the Battery Street Tunnel, several streets connect directly to SR 99 without room for drivers to accelerate or decelerate without affecting traffic flow or safety. These deficiencies result in higher than average collision rates for some segments of SR 99 within the project limits compared to similar facilities.\(^7\) The replacement for SR 99 should meet current standards for roadway design.
**Provide Capacity to Move People and Goods**
The Alaskan Way Viaduct portion of SR 99 provides essential capacity to and through downtown Seattle, carrying 20 to 25 percent of the traffic traveling through downtown. Together, I-5 and SR 99 through Seattle carry over $80 billion in goods each year.\(^8\)
The central waterfront portion of the SR 99 mainline is one of two primary north-south highway routes through Seattle. Maintaining this north-south through route is critical to supporting a robust, integrated regional transportation system and the economic vitality of the city, Puget Sound region, and state. The through capacity provided by the viaduct cannot be provided elsewhere in the region if the facility were to close. This section of SR 99 also serves as a transit route to and from downtown for local and express bus service. For these and other reasons, the U.S. Congress has identified it as a project of national and regional significance.\(^9\) The replacement for SR 99 should provide sufficient capacity for north-south trips to and through downtown.
**Provide Transportation System Linkages**
This portion of SR 99 provides important linkages for the regional and local transportation system. Directly south of the central waterfront section of SR 99, the highway interacts with the Port of Seattle and Seattle’s Duwamish industrial area. This area is home to one of the West Coast’s largest industrial ports and just over 80 percent of Seattle’s designated industrial lands.\(^10\) The transportation system in this area plays a crucial role in the movement of freight and goods for the entire state and the Pacific Northwest region. As such, the connection provided by SR 99 to Port facilities and industrial activities is important to the efficient movement of freight and goods to and from Seattle.
Along the central waterfront, SR 99 provides efficient through access for traffic bound for locations north and south of the downtown core. In addition to providing an efficient through connection, the existing viaduct also provides access to and from the south and downtown Seattle via the Seneca Street off-ramp and Columbia Street on-ramp. Further, this section of SR 99 provides a connection for the Interbay, Magnolia, and Ballard neighborhoods in northwest Seattle with areas south of downtown via the Elliott and Western Avenues and Railroad Way on- and off-ramps. This connection is used by many businesses and residents in northwest Seattle and is not easily duplicated by other routes.
Directly north of the central waterfront, SR 99 provides links to the local streets that serve the Seattle Center, a major regional civic center that welcomes more than 12 million visitors each year, generating $1.15 billion in business activity.\(^11\) In this area, SR 99 separates Seattle Center and the Uptown neighborhood from the South Lake Union neighborhood and provides limited connections to these neighborhoods. Improvements to SR 99 should improve these inter-neighborhood connections as well as provide regional access to and from SR 99.
The replacement for SR 99 should provide linkages to the regional transportation system, and to and from downtown Seattle and the local street system.
**Avoid Major Disruption of Traffic Patterns**
The existing Alaskan Way Viaduct provides substantial capacity for north-south travel to and through downtown Seattle. The loss of substantial capacity on SR 99 for an extended period would adversely affect conditions for through traffic by increasing congestion on I-5 and the adjacent local roadway network. Since many of these adjacent facilities are already congested, extended loss of SR 99 capacity would add substantial delay for the traveling public (including transit) and would cause economic hardships for local and regional businesses. While disruption cannot be completely avoided, there is a need to replace the existing viaduct in a manner that minimizes disruption of traffic patterns by minimizing the time lapse between closure of the existing viaduct and opening of a replacement facility or facilities.
**Protect the Integrity and Viability of Adjacent Activities on the Central Waterfront and in Downtown Seattle**
The presence of the viaduct impedes the City’s ability to implement its vision for redeveloping the central waterfront. The central waterfront section of the Alaskan Way Viaduct travels through and adjacent to downtown Seattle’s urban core and the Seattle waterfront. The structure is elevated through the city, providing views of the waterfront to drivers, but substantially impairing views to and from the waterfront to the city. The high volume of traffic carried by the double-level structure contributes substantial noise that affects the adjacent downtown and waterfront areas.
Since the viaduct was constructed in the 1950s, the Seattle downtown waterfront has been transformed from its origins as a working waterfront, characterized by shipping,
---
1 Parsons Brinckerhoff Quade & Douglas, Inc. 2002.
2 Parsons Brinckerhoff Quade & Douglas, Inc. 2004.
3 Larsen et al. 2005.
4 SAFETEA-LU 2005, Sec. 1301 (m).
5 City of Seattle 2007.
6 City of Seattle 2008.
warehouse, and industrial activities, to an important area for tourism and recreation. The central waterfront now has a mix of uses that include office, retail, hotel, residential, conference center, aquarium, museum, parks, cruise ship terminal, ferry terminal, and various types of commercial and recreational moorage. As such, the view and noise impacts caused by the existing elevated viaduct structure detract from the land uses found on the Seattle waterfront today.
Seattle’s vision for the central waterfront is based on reconnecting downtown with the waterfront, enhancing the waterfront’s environmental sustainability, increasing views of Elliott Bay and the landforms beyond, facilitating revitalization of Seattle’s waterfront, maintaining transportation access to and through the waterfront, and increasing opportunities for the public to access and enjoy the shoreline and waterfront. Therefore, the replacement for SR 99 should support land use plans for the central Seattle waterfront and downtown as described above.
|
Visual Moonbounce: Images and Video in Moonbounce Technology
Daniela de Paulis
Back in October 2009 I got in touch with the CAMRAS team (PI9CAM) at Dwingeloo radio telescope in The Netherlands, with a proposal for an artistic project.
For the last few years I had been thinking about moonbounce, in fact since first hearing an echo from the Moon I had been amazed by this technology. When I got in touch with CAMRAS I had the idea of moonbouncing some footage for one of my film projects. Jan van Muijlwijk (PA3FXB) replied enthusiastically to my suggestion and started looking into various possibilities, the result being that moonbouncing a video clip was not impossible but rather difficult – so why not still images instead, would that be an option? And so we started our collaboration.
**History and Development**
Up till then I had the opportunity to read about and hear some moonbounced sounds on the Internet. Other artists used moonbounce in their work, the most well known examples of that being 'Echoes of the Moon' by American composer Pauline Oliveros and 'Earth-Moon-Earth' by British artist Katie Paterson. They both used moonbounce in their sound works. Pauline Oliveros created her piece 'Echoes from the Moon' in 1987, after watching on television the first Moon landing in 1969. She performed the piece several times, working with ham radio operators Dave Olean K1WHS in Maine and Mark Gummer N2IQ in Syracuse, New York. During her performances Oliveros sent sounds from her microphone to a phone line, receiving the echoes after approximately two and a half seconds. She also involved the audience, people used to queue in her
events and ‘seemed to get a big kick out of hearing their voices return-processed by the Moon’ (Notes on Echoes from the Moon’, Pauline Oliveros).
Twenty years after, in 2007, Katie Paterson used moonbounce in another remarkable work, called ‘Earth-Moon-Earth’, where she sent to the Moon and back, with the help of a group of radio amateurs in Japan, Beethoven’s ‘Moonlight Sonata’ converted into Morse code. The moonbounced sounds were then converted back into notes and played as a piano piece [1].
Other artists used moonbounced sounds in their music or sound works – but what really triggered my curiosity was the possibility of ‘seeing’ the traces of the 768,000 kilometres journey to the Moon and back. What if moonbounce could communicate visually this amazing journey?
This is how I thought of moonbouncing visual data, and in my art projects I refer to this visual communication via the Moon as ‘Visual Moonbounce’.
Being very often in The Netherlands for my artist residencies, contacting the CAMRAS team at Dwingeloo radio telescope was the most obvious option – and, as it turned out, the most appropriate one. Dwingeloo radio telescope is not only able to receive good enough quality pictures from the Moon, thanks to its 25 metres diameter and additional technical features, but was also open to this artistic collaboration.
Immediately after our initial contact, Jan started experimenting with possibilities of moonbouncing images using the MMSSTV software. The very first test was carried out on 6 December 2009 when Jan sent to the moon the portrait of his 3 metres dish in the back garden of his house. The signal was received by the Dwingeloo dish. In Jan’s words: “We were thinking about asking some big dish stations to do a test with us, but on 6 December 2009 I was at home while the Dwingeloo dish was also on the air (a situation that does not happen very often) so I thought why not do a first SSTV try myself! I phoned Dwingeloo to suggest that I could send an SSTV signal, and so I did [...] Later on 26 February 2010 we successfully exchanged pictures with HB9Q in Switzerland and the first two way EME SSTV contact was made.”
Figure 2: First image to be moonbounced to PI9CAM: Jan van Muijlwijk’s 3 m dish
Figure 3: The result of the first experiment, 6 December 2009
The result of this first experiment was very promising, although the original image was not recognizable at this point. Several attempts followed until the moonbounced images started becoming more and more clear.
The noise showing in any moonbounced image is what makes it interesting and evocative of the long journey to the Moon and back. The radio signals containing the information of the image become weaker while travelling the long distance. This is one
of the causes for the distortion of the original colours and shapes in the image, other causes being the poor reflective qualities of the Moon’s surface, the Doppler shift and the lunar libration, amongst others.
*Figure 4: One of the first images ever to be moonbounced on SSTV (courtesy: NASA)*
During transmission the MMSSTV software converts the colours and pixels of the image into sounds that are then converted into radio waves; these are sent to the Moon and after bouncing off they are received by Dwingeloo radio telescope, converted into sounds and then back into image using the same software. The sounds produced by each moonbounced image are unique to that image; in fact no two moonbounced images will ever be alike due to the continuously changing astronomical conditions.
Sending images via the Moon is not however a completely new thing. In the history of development of moonbounce technology, mainly carried out in its early days by the US Navy, it is possible to trace back the initial experiments with images. When the “Radar Division of the Naval Research Laboratory upgraded the Moon Relay system [...] by using the ultra high frequency (UHF) band [...] the experimental Moonbounce system was transformed into a fully operational lunar relay” [2]. This new, more efficient system was officially launched on 28 January 1960. “As part of the inaugural ceremonies, pictures of the aircraft carrier USS Hancock were beamed from Honolulu to Washington via the Communication Moon Relay system. The transmitted facsimile [see next page] featured thousands of Hancock officers and seamen spelling out ‘Moon Relay’ to a worldwide audience” [3]. “The completed system used eighty-four-foot-diameter (twenty-eight-meter-diameter) steerable parabolic antennas and 100-kilowatt transmitters installed at Annapolis, Maryland, and Opana, Oahu, with receivers at Cheltenham, Maryland, and Wahiawa, Oahu. The system operated at frequencies around 400 megahertz, it could accommodate up to sixteen teleprinter channels operating at the rate of sixty words per minute, and it was capable of processing teletype and photographic facsimiles” [4].
Another interesting example of visualizing the Moonbounce process is a study made by radio amateur Andrea Mancini (IW4CJM) “with the cooperation of the Radioastronomy Association ‘Bagnara di Romagna’, on how to ‘write’ on the Moon [...] The actual writing is obtained using audio tones within the transmitter’s audio band, so that, if Spectran is used to decode, numbers and letters will appear on the screen [...] I needed to increase
the letters’ size from 100 to 800 Hz, using Spectran left-to-right scan. Subsequently, I have been able to obtain the same result with up/down Spectran scan, which is the normally used mode,” says Mancini in his text for the EME conference in Florence in 2008.
Figure 5: Facsimile picture of the USS Hancock with ship officers and crew spelling out ‘Moon Relay’. This picture was transmitted via the Moon from Honolulu, Hawaii, to Washington, DC on 28 January 1960 (courtesy US Navy, NASA).
“After this change, I was ready to ‘write’ on the Moon, and the first tests, carried out on May 5, 2004, were successful [...] The signal from the 7-meter dish was sent while the dish itself was slowly moved at a steady speed across the surface of the moon, from the east to the west limb [...] While experimenting, I noticed that the text had a better definition if, instead of a single tone, two were used [...] I called this ‘the painter’s theory” [5].
Into Live Performance
When the technology of moonbouncing images using the MMSSTV was fully tested by Jan, the CAMRAS team and some international collaborators – Bruce Hálàsz PY2BS in Brazil, Daniel Gautschi HB9Q in Switzerland and Howard Ling G4CCH in the UK – I started working on ideas for using this great technology within a live performance. After some research I came up with the title for the project, ‘OPTICKS’, inspired by the 1704 essay by Isaac Newton on the reflections, refractions, inflections and colours of light.
During the first performances of OPTICKS in fact we used to moonbounce mono-chrome images of the seven colours of the light spectrum. In general however the title
aims at suggesting the phenomenon of reflection and refraction of the radio waves by the Moon’s surface, through a poetic and philosophical link between Moonbounce and the light spectrum.
*Figure 6: The OPTICKS title received by moonbounce*
The first performance of OPTICKS took place on 30 October 2010 at 01:00 UTC at Extrapool, an experimental art venue in Nijmegen in The Netherlands. Images of the seven colours of the spectrum were sent by Howard Ling in the UK to the Moon, received by Jan at Dwingeloo radio telescope and projected in real time at the exhibition space. The building up of each colour (72 seconds for each image on ‘Robot 72’ mode in the MMSSTV setting) was accompanied by a sound score composed especially for the project and played live by Spanish composer Enrique Tomas (www.ultranoise.es).
Enrique composed a seven minutes score, especially tailored for EME technology, in which each minute corresponds to a musical note. The sounds were moonbounced and incorporated in the live show.
The idea of having a sound score was also inspired by the Newton’s essay. The great scientist in fact believed in the hidden connection between the musical notes, the seven days of the week, the seven colours of the light spectrum and the seven celestial bodies known in his time. “Newton constructed the colour music disc dividing the spectrum into the seven colours [...] to be fitted in between the eight notes of an octave. The colour music disc in OPTICKS analogizes music to colour, just as its prototypes (of Plato, Ptolemy and Kepler) had connected music to planets and other qualities” [6].
Enrique, an experienced sound artist, enthusiastically took the challenge of composing sounds for moonbounce, and this is how he describes his experience: “The specifications of the project, with a maximum length of each piece of 72 seconds, a reduced spectrum between 400 and 2800 Hz and a monaural playback were an important constraint. Also I took into account the fact that my audios will be distorted due to the transmission through the atmosphere, the vacuum space and the reflection on the surface of the moon” [7].
This structure of the OPTICKS performance was used a few more times, including the show at the Amsterdam Planetarium in November 2010. The project however changes continuously so to be always different and unpredictable. Occasionally new collaborators join in. After the first few live events I decided to replace the images of the seven colours of the spectrum with images submitted by the public attending the live event. Also I decided to replace the sound score with a verbal interaction with the audience, talking and answering questions.
During the show it is possible to hear in the background the sounds produced by the MMSSTV while the images return from the Moon. Because each colour corresponds to a unique tone in the software, the connection between colours and sounds suggested by Newton is intrinsic to the MMSSTV software.
During each live performance, Jan and the CAMRAS team appear in a video call and answer questions from the audience. Usually, after moonbouncing four of five images a pause is needed, in fact the power amplifiers and coax cables become very hot and need to cool down to avoid burning. Every OPTICKS event is a bit of an adventure, and we always experienced some technical problems either before or even during the live event. The problems are sometimes caused by a slow Internet connection (the images in fact are received live at any location thanks to a remote desktop control software called TeamViewer); or at other times there are problems due to high winds at one of the locations involved, or other technical failures at one of the stations. However, despite the complex technicality we never had to cancel a single performance so far!
Jan, Howard, Bruce and I have presented OPTICKS many times already, always with the enthusiastic response of the audience. One of my favourite performances was in collaboration with RAI Radio 2 programme 'Rai Tunes', directed by Italian DJ Alessio Bertallot. The programme can be followed both on the radio and on the web where it is possible to see the video for the event. The images submitted by the radio listeners, including some iconic images from popular culture, such as Pink Floyd's 'The Dark Side of the Moon' album cover, were sent to the Moon by Howard in the UK and received by Jan at Dwingeloo while some classical and pop music tunes accompanied the event [8].
One of the most interesting performances of OPTICKS so far was presented as part of Global Astronomy Month (GAM) 2012 in collaboration with Astronomers Without Borders [9]. For this occasion CAMRAS collaborated with Prof. Lech Mankiewicz, together with radio operators from ARISS Polska: Armand Budzianowski SP3QFE, Andrzej Matuszny SP6JLW, Jacek Maslowski SP6OPN and Pawel Matuszny SQ6OPG. The Polish team in a few weeks upgraded their equipment in order to participate in the live Visual Moonbounce performance scheduled for the 28 April 2012 at 18:00 UTC.
Several tests conducted by Jan and Armand preceded the event. The reliability of the Internet connection was one of the main technical issues the Polish team needed to solve, their station being located in the middle of a forest, also they had to find out what power levels could be safely used in order to send SSTV without overheating their amplifiers.
The OPTICKS live performance for GAM 2012 was presented live from Dwingeloo radio telescope: inside the cabin, CAMRAS radio amateurs Dick Harms, Theo Dekkers, Eene de Weerd, together with Jan, radio astronomer Roy Smits and myself, presented the event on Ustream for an international audience, moonbouncing images submitted by people of all ages and from all around the world. During the live event the moon-bounce activities were temporarily paused for transmitting the image of Dwingeloo radio telescope followed by images of the primary colours (Red, Yellow, Blue) to a star called Upsilon Andromedae, 44 light years away. The Dwingeloo antenna rotated to track this star – together with the cabin and all of us inside – in front of the astonished audience following the event on the web. Upsilon Andromedae is believed to be hosting four planets, one of which, we hope, will receive the images in 2056 (centenary of the
Dwingeloo radio telescope official opening) and perhaps it may respond sometime in 2100.
For the OPTICKS performance for GAM 2012, the Polish team surprised us all with a special call sign, starting with the prefix of their country, SN2012GAM, that was used on some of the images moonbounced during that night. After the performance I printed the moonbounced images and sent them back as a card to the people from all over the world who submitted them, together with my message certifying the authenticity of the journey to the Moon and back. A certificate from both the CAMRAS and the Polish team has also been created to accompany the pictures. Some of the recipients of these images wrote back to me with a 'thanks' message, saying how much they appreciated the experience of being 'astronauts', even if only virtually. For further recordings and information, see [10–14].
As part of GAM 2012 I also presented a B/W video called 'Le Voyage dans la Lune' (2011-2012), whose title is inspired by a famous French movie, made by George Méliès in 1902 and considered the first Science Fiction film in history [15]. Similarly, moonbounce can be considered the first form of Space travel that allowed humankind to 'touch' another celestial body, by means of radio waves. My version of 'Le Voyage dans la Lune' is composed by 26 images of the lunar phases taken by Michael Oates (Manchester Astronomical Society) who kindly offered them to me for the project. The 26 images have been moonbounced from Brazil to Dwingeloo in September 2011, using the SSTV mode B/W 12. I joined the moonbounced images together into a moving sequence and added the sound which has been provided by JAXA (Japan Aerospace Exploration Agency). The sound is called 'Moonbell' and uses laser altimeter data from one of the sensors of the lunar orbiting satellite Selene/Kaguya, transforming the altitude data into musical intervals [16]. The area I chose to 'sonify' is on the far side of the Moon, starting at the Korolev crater and continuing across the highest point. I used a very slow version of the sound in order to suggest the rhythmic steps of someone walking on the Moon.
Since the very first experiment on 6 December 2009, Jan, Bruce, Howard, Daniel and Armand sent many images to the Moon and back, not only for OPTICKS and for my artistic research but also for Visual Moonbounce enthusiasts, including Patrick Barthelow AA6EG who is proposing to use this technology for STEM education.
**The Future**
The future of Visual Moonbounce is already looking very interesting. The video 'Le Voyage dans la Lune' is my very first attempt to use Moonbounce with moving images. However Jan, Armand and I have been discussing possibilities to moonbounce short films in a near future.
Besides my suggestions of using video clips and possibly 3D effects, Jan, Bruce, Howard and Armand are also developing ways to receive pictures with higher definition. Here is an example:
Figure 7: André Kuipers' portrait moonbounced using Robot 72 mode
This image of Dutch astronaut André Kuipers was first moonbounced by Jan on 25 February 2012 using the MMSSTV software in 'Robot 72' mode, taking 72 seconds for the whole picture. Jan also tried the 'Scottie DX' mode, taking 269 seconds and so promising better image quality, but the first attempts were spoiled by the changes in Doppler shift over this rather long time period. By careful manual correction (like many operators do with drifting digital EME signals that otherwise would be undecodable) it was possible to receive a nearly perfect picture:
Figure 8: Same moonbounced image as Figure 7, using Scottie DX mode with continuous manual Doppler correction
After a live OPTICKS performance, Howard G4CCH also tried both a Scottie DX picture (269 seconds) and a picture in the faster Scottie 1 mode (110 seconds). The difference is visible but not very big, so Scottie 1 might be a nice higher-quality alternative to Robot 72 and takes only about 40 seconds more.
Conclusion
Experimenting is an important process for artists, radio amateurs and scientists alike. Something that started as a playful experiment for an art project might lead to many interesting pioneering ideas in this fascinating technology called Moonbounce, and beyond even that.
Being a small part of this adventure is for me an amazing experience. I will never be grateful enough to CAMRAS, Jan, Daniel, Bruce, Howard and Armand for making 'visible' the journey to the Moon and back.
References
1. http://www.contemporaryartsociety.org/become-a-member/artist-member/katie-paterson/398
2. http://en.wikipedia.org/wiki/Communication_Moon_Relay
3. http://history.nasa.gov/SP-4217/ch2.htm
4. Gebhard, *Evolution of Naval Radio-Electronics*, pp. 117-18
5. Andrea Mancini IW4CJM, *Writing on the Moon at 10GHz with Alice software*, 13th EME Conference (Florence 2008)
6. Niels Hutchison, *Colour Music: Music for Measure*, 2004.
7. http://www.opticks.info/blog/?page_id=155
8. http://www.youtube.com/watch?v=s92ILLqFuOs
9. http://www.astronomerswithoutborders.org/gam2012/all-programs/1071-opticks-2012.html
10. A recording of the OPTICKS performance for GAM 2012 (unfortunately the first ten minutes are missing): http://www.ustream.tv/channel/opticks2012
11. Also a nice video made by Armand about the GAM 2012 event can be viewed here: http://www.youtube.com/watch?v=-6-a8ygDKrA
12. An article about the same event in Polish: http://sp3qfe.net/
13. Results of the ongoing experiments on SSTV are often published by CAMRAS in the weekly bulletin: http://www.camras.nl/
14. Updates and further information on the OPTICKS project can be found here: www.opticks.info
15. https://vimeo.com/41287703
16. *Moonbell: Listening to the Topography of the Moon*: http://wms.selene.darts.isas.jaxa.jp/selene_sok/about_en.html
*In the longer version on the Conference DVD are Appendices with further comments from PA3FXB, HB9CRQ, PY2BS and the team at SN2012GAM.*
|
Absidia
Natural Habitats Soil • Decaying vegetation
Suitable Substrates in the Indoor Environment
Often found in stored grains • Other foods
Water Activity Unknown
Mode of Dissemination Wind
Allergenic Potential Recognized as an allergen
Potential Opportunist or Pathogen In immunocompromised patients pulmonary invasions, the meninges (brain or spinal chord), and kidney infections can result from Absidia exposure • Absidia may also cause zygomycosis in immunocompromised patients (AIDS)
Industrial Uses Unknown
Potential Toxins Produced Unknown
Other Comments Absidia often causes food spoilage
Aspergillus
Natural Habitats Soil • Plant debris • Indoor air environment
Suitable Substrates in the Indoor Environment: • Grows on a wide range of substrates indoors • Prevalent in water damaged buildings
Water Activity Aw=0.75-0.82.
Mode of Dissemination Wind
Allergenic Potential Allergic bronchopulmonary aspergillosis (ABPA) which is common in asthmatic and cystic fibrosis patients • Aspergillus sinusitis • Invasive aspergillosis in immunocompromised patients
Potential Opportunist or Pathogen Aspergilloma and chronic pulmonary aspergillosis in people with lung disease
Industrial Uses A. oryzae is used in soy sauce production • A. terreus produces mevinolin which is able to reduce blood cholesterol • A. niger produces enzymes used to make some breads and beers and is also used in plastic decomposition. • A. niger and A. ochraceus are used in cortisone production.
Potential Toxins Produced Secalonic acid D • Aflatoxin B • Aflatoxin G • Aflatoxin M1 • Aflatrem (alkaloid) • Aflatrem (indole alkaloid) • Aspertoxin • Brevianamide A • Citreoviridin, • Citrinin • Cyclopiazonic acid • Fumagillin • Fumigaclavine • Fumitremorgin A • Gliotoxin • Helvolic acid • 3-Nitropropionic acid • Ochratoxin A • Ochratoxin B • Ochratoxin C • Penicillic acid • Phthioic acid • Patulin • Sphingofungins • Sterigmatocystin • Terrein • Terreic acid • Terretonin • Territrem A • Versicolorin A • Verruculogen • Viomellein
Other Comments It is the second most common opportunistic pathogen following Candida.
LAB SERVICES: Asbestos, Mold, Bacteria, Industrial Hygiene, Metals, Allergens, PCR-Polymerase Chain Reaction (DNA), Silica, Volatiles Scan, Formaldehyde by HPLC, Water and Materials Testing.
Chaetomium
Natural Habitats: Dung • Seeds • Soil • Straw
Suitable Substrates in the Indoor Environment: Paper • Sheetrock • Wallpaper
Water Activity: Aw>0.90
Mode of Dissemination: Wind • Insects • Water splash
Allergenic Potential: Type I (asthma and hay fever)
Potential Opportunist or Pathogen: Onychomycosis
Industrial Uses: Cellulase production • Textile testing
Potential Toxins Produced: Chaetomin • Chaetoglobosins are produced by Chaetomium globosum • Sterigmatocystin is produced by rare species
LAB SERVICES: Asbestos, Mold, Bacteria, Industrial Hygiene, Metals, Allergens, PCR-Polymerase Chain Reaction (DNA), Silica, Volatiles Scan, Formaldehyde by HPLC, Water and Materials Testing.
EMSL ANALYTICAL, INC.
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Penicillium
Natural Habitats Soil • Seed • Cereal crops
Suitable Substrates in the Indoor Environment Foods (blue mold on cereals, fruits, vegetables, dried foods) • House dust • Fabrics • Leather • Wallpaper • Wallpaper glue
Water Activity $Aw=0.78-0.86$
Mode of Dissemination Wind • Insects
Allergenic Potential Type I (hay fever, asthma) • Type III (hypersensitivity)
Potential Opportunist or Pathogen Penicilliosis
Industrial Uses P. chrysogenum for the antibiotic penicillin • P. griseofulvum for the antibiotic griseofulvin a • P. roquefortii for Roquefort cheese • P. camemberti for Camembert cheese • Brie, Gorgonzola, and Danish Blue cheese are also the products of Penicillium • Used to cure ham and salami • Production of organic acids such as fumaric, oxalic, gluconic, and gallic
Potential Toxins Produced Citrinin • Citreoviridin • Cyclopiazonic acid • Fumitremorgen B • Grisiofulvin • Janthitrems • Mycophenolic acid • Paxilline • Penitrem A • Penicillic acid • Ochratoxins • Roquefortine C • Secalonic acid D • Verruculogen • Verrucosidin • Viomellein • Viridicatumtoxin • Xanthomagnin
Other Comments Penicillium is one of the most common genera of fungi
LAB SERVICES: Asbestos, Mold, Bacteria, Industrial Hygiene, Metals, Allergens, PCR-Polymerase Chain Reaction (DNA), Silica, Volatiles Scan, Formaldehyde by HPLC, Water and Materials Testing.
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Rhizopus
Natural Habitats: Dung • Fruits - causing rhizopus rot on stone fruits and strawberries • Soils • Vegetables
Suitable Substrates in the Indoor Environment: Stored fruits and vegetables
Water Activity: $Aw=0.93$
Mode of Dissemination: Wind
Allergenic Potential: Type I (hay fever, asthma) • Type III (hypersensitivity)
Potential Opportunist or Pathogen: Causal agent of zygomycosis in immunocompromised, malnourished or severely burned people
Industrial Uses: Used to ferment rice into miso • Used to ferment soybeans to tempeh and sufu
Potential Toxins Produced: Rhizopus oryzae produces agroclavine (an ergot alkaloid toxic to mammals)
Alternaria
Natural Habitats Common saprobe and pathogen of plants. Typically found on plant tissue, decaying wood, and foods. • Soil • Air outdoors
Suitable Substrates in the Indoor Environment
Indoors near condensation (window frames, showers) • House dust (in carpets and air)
• Also colonizes building supplies, computer disks, cosmetics, leather, optical instruments, paper, sewage, stone monuments, textiles, wood pulp, and jet fuel
Water Activity Aw = 0.85-0.88
Mode of Dissemination Wind
Allergenic Potential Type I allergies (hay fever, asthma) • Type III (hypersensitivity pneumonitis)
Potential Opportunist or Pathogen Phaeohyphomycosis {causing cystic granulomas in the skin and subcutaneous tissue} • In immunocompetent patients, Alternaria colonizes the paranasal sinuses, leading to chronic hypertrophic sinusitis
Industrial Uses Biocontrol of weed plants • Biocontrol of fungal plant pathogens
Potential Toxins Produced Alternariol (AOH) • Alternariol monomethylether (AME)
• Tenuazonic acid (TeA) • Altenuene (ALT) • Altertoxins (ATX)
Other Comments Alternaria spores are one of the most common and potent indoor and outdoor airborne allergens. Additionally, Alternaria sensitization has been determined to be one of the most important factors in the onset of childhood asthma. Synergy with Cladosporium or Ulocladium may increase the severity of symptoms
Trichoderma
Natural Habitats: Decaying wood • Dead leaves • Soil
Suitable Substrates in the Indoor Environment: Paper • Textiles • Wood (wet)
Mode of Dissemination: Insects • Water splash • Wind
Allergenic Potential: Type I allergies (hay fever, asthma) • Type III (hypersensitivity)
Potential Opportunist or Pathogen: Has occasionally been associated with disease in immunocompromised individuals
Industrial Uses: Biocontrol agent against a variety of plant pathogens • Biproducts of T. viride are used to make beer and wine
Potential Toxins Produced: Gliotoxin • Isocyanides • Trichothecene • Trichodermin • T-2 toxin
LAB SERVICES: Asbestos, Mold, Bacteria, Industrial Hygiene, Metals, Allergens, PCR-Polymerase Chain Reaction (DNA), Silica, Volatiles Scan, Formaldehyde by HPLC, Water and Materials Testing.
EMSL ANALYTICAL, INC.
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Ulocladium
Natural Habitats Soil • Plant materials • Soil, dung, paint, grasses, fibers, wood, decaying plant material, paper, and textiles
Suitable Substrates in the Indoor Environment Gypsum board • Jute • Paper • Rotten wood • Textiles • Wood
Water Activity $Aw=0.89$
Mode of Dissemination Wind
Allergenic Potential Type I (hay fever, asthma)
Potential Opportunist or Pathogen Unknown
Industrial Uses Unknown
Potential Toxins Produced Unknown
Other Comments Alternaria sensitive allergy sufferers have a multiplied reaction when Ulocladium and Alternaria are present together
LAB SERVICES: Asbestos, Mold, Bacteria, Industrial Hygiene, Metals, Allergens, PCR-Polymerase Chain Reaction (DNA), Silica, Volatiles Scan, Formaldehyde by HPLC, Water and Materials Testing.
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Nigrospora
Natural Habitats Common on live or dead grass • Seeds • Soil
Suitable Substrates in the Indoor Environment Unknown
Water Activity Unknown
Mode of Dissemination Forcibly ejected
Allergenic Potential Type I allergies (hay fever, asthma)
Potential Opportunist or Pathogen Keratitis • Skin lesions
Industrial Uses Unknown
Potential Toxins Produced Unknown metabolite reported with some toxic properties
Paecilomyces
Natural Habitats Decaying plant matter • Insects • Soils
Suitable Substrates in the Indoor Environment Optical Lenses • Leather • Paper • PVC • Jute Fibers • Tobacco
Water Activity Aw=0.79
Mode of Dissemination Wind
Allergenic Potential Type I (hay fever, asthma)
• Type III (hypersensitivity)
Potential Opportunist or Pathogen *P. variotii* causes paecilomycosis (symptoms include keratitis, cellulitis, and alveolitis). *Corneal ulcers, keratitis, and endophthalmitis can occur after extended contact lense use or eye surgery due to Paecilomyces infection*
Industrial Uses *Paecilomyces fumosoroseus* is currently marketed as a biocontrol insecticide
Potential Toxins Produced Byssochlamic acid • Ferrirubin • Fusigen • Indole-3-acetic acid • Paecilotoxins • Patulin • Variotin • Viriditoxin
Other Comments *P. crustaceus* and *P. variotii* can grow well at temperatures as high as 50°C
LAB SERVICES: Asbestos, Mold, Bacteria, Industrial Hygiene, Metals, Allergens, PCR-Polymerase Chain Reaction (DNA), Silica, Volatiles Scan, Formaldehyde by HPLC, Water and Materials Testing.
EMSL ANALYTICAL, INC.
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Aureobasidium
Natural Habitats: Soils • Plant leaf and stem tissue • Wood • Fresh Water • Plant Debris
Suitable Substrates in the Indoor Environment: Damp areas including kitchens, bathrooms, grout, and shower curtains • Painted interior surfaces and textiles • Skin and nails of people
Water Activity: Grows well where moisture accumulates (88.5 RH on woodchip wallpaper)
Mode of Dissemination: Water droplets, rain • Wind when spores become dry
Allergenic Potential: Type I (asthma and hay fever) • Type III (hypersensitivity) • Skin irritant causing dermatitis
Potential Opportunist or Pathogen: Keratomycosis • Phaeohyphomycosis • Pulmonary mycosis with sepsis
Industrial Uses: A. pullulans produces pullulan which is used for packaging food and drugs.
Potential Toxins Produced: Unknown
LAB SERVICES: Asbestos, Mold, Bacteria, Industrial Hygiene, Metals, Allergens, PCR-Polymerase Chain Reaction (DNA), Silica, Volatiles Scan, Formaldehyde by HPLC, Water and Materials Testing.
**Natural Habitats** Plant pathogen responsible for causing gray mold (B. cinerea) on grapes, strawberries, raspberries, blackberries, low bush blueberries, lettuce, cabbage, and onions.
**Suitable Substrates in the Indoor Environment**
- Houseplants
- Fruits
- Vegetables
**Water Activity** Unknown
**Mode of Dissemination** Wind
**Allergenic Potential** Type I (asthma and hay fever)
**Potential Opportunist or Pathogen** Hyalohyphomycosis
**Industrial Uses** Biocontrol agent of insects
**Potential Toxins Produced** Unknown
**Stachybotrys**
**Natural Habitats** Decaying plant materials • Soil
**Suitable Substrates in the Indoor Environment**
Water damaged building materials such as: ceiling tiles, gypsum board, insulation backing, sheet rock, and wall paper • Paper • Textiles
**Water Activity** $Aw=0.94$
**Mode of Dissemination** Insects • Water • Wind
**Allergenic Potential** Type I (hay fever, asthma)
**Potential Opportunist or Pathogen** Unknown
**Industrial Uses** Unknown
**Potential Toxins Produced** Cyclosporins • Macrocyclic trichothecenes: roridin E, satratoxin F, G & H, sporidesmin G, trichoverrol, verrucarin J • Stachybotryolactone
**Other Comments** *Stachybotrys* may play a role in the development of sick building syndrome. The presence of this fungus can be significant due to its ability to produce mycotoxins. Exposure to the toxins can occur through inhalation, ingestion, or skin exposure.
---
**LAB SERVICES:** Asbestos, Mold, Bacteria, Industrial Hygiene, Metals, Allergens, PCR-Polymerase Chain Reaction (DNA), Silica, Volatiles Scan, Formaldehyde by HPLC, Water and Materials Testing.
**Synccephalastrum**
- **Natural Habitats**: Dung • Soil
- **Suitable Substrates in the Indoor Environment**: Unknown
- **Water Activity**: Unknown
- **Mode of Dissemination**: Unknown
- **Allergenic Potential**: Unknown
- **Potential Opportunist or Pathogen**: Cutaneous infections reported
- **Industrial Uses**: Unknown
- **Potential Toxins Produced**: Unknown
---
**LAB SERVICES**: Asbestos, Mold, Bacteria, Industrial Hygiene, Metals, Allergens, PCR-Polymerase Chain Reaction (DNA), Silica, Volatiles Scan, Formaldehyde by HPLC, Water and Materials Testing.
EMSL ANALYTICAL, INC.
www.emsl.com
Cladosporium
Natural Habitats: Dead plant matter • Straw • Soil • Woody plants
Suitable Substrates in the Indoor Environment:
Fiberglass duct liner • Paint • Textiles • Found in high concentration in water-damaged building materials
Water Activity: Aw 0.84-0.88
Mode of Dissemination: Air
Allergenic Potential: Type I (asthma and hay fever)
Potential Opportunist or Pathogen:
Edema • Keratitis • Onychomycosis
• Pulmonary Infections • Sinusitis
Industrial Uses: Produces 10 antigens
Potential Toxins Produced: Cladosporin • Emodin
LAB SERVICES: Asbestos, Mold, Bacteria, Industrial Hygiene, Metals, Allergens, PCR-Polymerase Chain Reaction (DNA), Silica, Volatiles Scan, Formaldehyde by HPLC, Water and Materials Testing.
EMSL ANALYTICAL, INC.
www.emsl.com
107 HADDON AVE., WESTMONT NJ 08108 TEL: 800.220.3675
Curvularia
Natural Habitats Plant saprobe and pathogen to cereal plants • Soil
Suitable Substrates in the Indoor Environment
Paper • Wood products
Water Activity Unknown
Mode of Dissemination Wind
Allergenic Potential Type I (asthma and hay fever) • A relatively common cause of allergic fungal sinusitis
Potential Opportunist or Pathogen In immunocompromised patients: Cerebral abscess • Endocarditis • Mycetoma • Ocular keratitis • onychomycosis • pneumonia • sinusitis
Industrial Uses Unknown
Potential Toxins Produced Cytochalasin B
Fusarium
Natural Habitats Soil • Plant pathogen causing root rot, stem rot, and wilt of many ornamental and crop plants.
Suitable Substrates in the Indoor Environment Often found in humidifiers • Wet, cellulose-based building materials
Water Activity $Aw=0.86-0.91$
Mode of Dissemination Insects • Water droplets, rain • Wind when spores become dry
Allergenic Potential Type I allergies (hay fever, asthma)
Potential Opportunist or Pathogen Esophageal cancer is believed to happen after consumption of *F. moniliforme* infected corn • Keratitis • Endophthalmitis • Onychomycosis • Cutaneous infections • Mycetoma • Sinusitis • Pulmonary infections • Endocarditis • Peritonitis • Central venous catheter infections • Septic arthritis • Neurological disease in horses after consumption of *F. moniliforme* infected corn • Respiratory disease in pigs after consumption of *F. moniliforme* infected corn
Industrial Uses Biological Weapon
Potential Toxins Produced Trichothecenes • Zearalenone • Fumonisins
Other Comments Major plant pathogen
Graphium
Natural Habitats: Dung • Seeds • Soils • Woody plant tissue
Suitable Substrates in the Indoor Environment: Unknown
Water Activity: Unknown
Mode of Dissemination: Beetles when mitosporic state of Ophiostoma ulmi
Allergenic Potential: Unknown
Potential Opportunist or Pathogen: Unknown
Industrial Uses: R135402, a compound with antifungal activity against Candida albicans and Cryptococcus neoformans, has been isolated from a fermentation broth of Graphium putredinis
Potential Toxins Produced: Unknown
Other Comments: There have not been any reports of human infections with Graphium species, however, it is a mitosporic state of Pseudoallescheria boydii which causes subcutaneous mycoses in man
LAB SERVICES: Asbestos, Mold, Bacteria, Industrial Hygiene, Metals, Allergens, PCR-Polymerase Chain Reaction (DNA), Silica, Volatiles Scan, Formaldehyde by HPLC, Water and Materials Testing.
EMSL ANALYTICAL, INC.
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Memnoniella
Natural Habitats: Plant materials • Soil
Suitable Substrates in the Indoor Environment: Paper • Sheetrock • Wood
Water Activity: Suspected to be above 0.90 Aw
Mode of Dissemination: Wind
Allergenic Potential: Unknown
Potential Opportunist or Pathogen: Unknown
Potential Toxins Produced: Dechlorogriseofulvin, Epidechlorogriseofulvin, Griseofulvins, Memnopeptide A, Trichodermol, Trichodermin.
Other Comments: Griseofulvin used an anti-dermatophyte drug and is commercially available.
LAB SERVICES: Asbestos, Mold, Bacteria, Industrial Hygiene, Metals, Allergens, PCR-Polymerase Chain Reaction (DNA), Silica, Volatiles Scan, Formaldehyde by HPLC, Water and Materials Testing.
Scopulariopsis
Natural Habitats Soil
Suitable Substrates in the Indoor Environment
Dairy products • Fruit • Grain • Meat • Paper • Wood
Mode of Dissemination Wind
Allergenic Potential Type III (hypersensitivity)
Potential Opportunist or Pathogen Onychomycosis in toe nails • Skin lesions
• Mycetoma • Keratitis • Endophthalmitis, invasive sinusitis, pulmonary infections,
endocarditis, and brain abscess typically only afflict immunocompromised patients
Industrial Uses Unknown
Potential Toxins Produced Scopulariopsis brevicaulis produces arsine gas from arsenate dyes found in wallpaper covered with Paris Green
LAB SERVICES: Asbestos, Mold, Bacteria, Industrial Hygiene, Metals, Allergens, PCR-Polymerase Chain Reaction (DNA), Silica, Volatiles Scan, Formaldehyde by HPLC, Water and Materials Testing.
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|
Improving Physical Activity mHealth Interventions: Development of a Computational Model of Self-Efficacy Theory to Define Adaptive Goals for Exercise Promotion
Dario Baretta\textsuperscript{1}, Fabio Sartori\textsuperscript{2}, Andrea Greco\textsuperscript{3}, Marco D’Addario\textsuperscript{1}, Riccardo Melen\textsuperscript{2}, and Patrizia Steca\textsuperscript{1}
\textsuperscript{1}Department of Psychology, University of Milan-Bicocca 20126, Milan, Italy
\textsuperscript{2}Department of Computer Science, Systems and Communication, University of Milan-Bicocca, 20126 Milan, Italy
\textsuperscript{3}Department of Human and Social Sciences, University of Bergamo, 24129 Bergamo, Italy
Correspondence should be addressed to Dario Baretta; email@example.com
Received 25 October 2018; Revised 25 January 2019; Accepted 11 February 2019; Published 4 March 2019
Guest Editor: Maurizio Rebaudengo
Copyright © 2019 Dario Baretta et al. This is an open access article distributed under the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.
The practice of regular physical exercise is a protective factor against noncommunicable diseases and premature mortality. In spite of that, large part of the population does not meet physical activity guidelines and many individuals live a sedentary life. Recent technological progresses and the widespread adoption of mobile technology, such as smartphone and wearables, have opened the way to the development of digital behaviour change interventions targeting physical activity promotion. Such interventions would greatly benefit from the inclusion of computational models framed on behaviour change theories and model-based reasoning. However, research on these topics is still at its infancy. The current paper presents a smartphone application and wearable device system called \textit{Muoviti!} that targets physical activity promotion among adults not meeting the recommended physical activity guidelines. Specifically, we propose a computational model of behaviour change, grounded on the social cognitive theory of self-efficacy. The purpose of the computational model is to dynamically integrate information referring to individuals’ self-efficacy beliefs and physical activity behaviour in order to define exercising goals that adapt to individuals’ changes over time. The paper presents (i) the theoretical constructs that informed the development of the computational model, (ii) an overview of \textit{Muoviti!} describing the system dynamics, the graphical user interface, the adopted measures and the intervention design, and (iii) the computational model based on Dynamic Decision Network. We conclude by presenting early results from an experimental study.
1. Introduction
Noncommunicable diseases such as cardiovascular and respiratory diseases, cancer, diabetes, and obesity are the main cause of mortality in Western countries and cause unimaginable costs for public health [1]. Although physical activity constitutes an important protective factor against such diseases [2], large part of the population does not respect the recommended physical activity guidelines and lives a sedentary life [3]. Hence, there is the need to find new, effective, and large-scale solutions to promote behaviour change in the direction of a higher physical activity.
Recent availability of effective and inexpensive sensors, generally embedded into commercial devices, such as wearables and smartphones, has opened the way to the development of smartphone applications (apps) oriented to promote health behaviour change [4]. Healthcare apps are becoming one of the most important and promising tools for delivering behaviour change interventions [5, 6]. With regards to physical activity (PA) behaviour, mobile sensors can perform direct, intense, and longitudinal measurements of physical parameters (e.g., the heartbeat) and may produce detailed records of the individual behaviour (e.g., exercise) that are immediately available for analysis [7]. Thanks to such opportunities for data collection, new technologies can rapidly manage and combine different input datasets, provide accurate predictions about the influence pattern among interested variables (e.g., behavioural, psychological),
and deliver behaviour change interventions that are adaptive to individual and context changes over time [8]. For these reasons, mobile technology has been hypothesized to support the science of behaviour change and it constitutes a preferential tool both for modeling behaviour change theories and for testing them in real world settings [4, 9, 10]. In spite of that, existing PA apps are characterized by a lack of adherence to behaviour change theories [11] and relatively little attention has been paid to the adoption of specific computational models grounded in behaviour change theories [12]. More specifically, even though digital interventions that made extensive use of behaviour change theories produce larger effects on behaviour [13], Cowan and colleagues [11] evidenced that *Health & Fitness* apps mostly included only minimal theoretical content.
Self-efficacy theory [14, 15] is one of the most prominent psychological theories about behaviour change and it lays its foundations on the construct of self-efficacy. Self-efficacy (SE) has been defined as the beliefs in one’s capabilities to organize and execute the courses of action required to produce given attainments [14]. Such beliefs affect several areas of human endeavor [15] and these effects are particularly relevant with regards to health-related behaviours [16–18]. More specifically, it has been consistently shown that self-efficacy is a key determinant for the adoption and maintenance of PA behaviour [17, 19, 20], as well as a mediator of the effects of interventions on physical activity [21–24].
Self-efficacy beliefs develop as a consequence of four sources of information: enactive mastery experience, vicarious experience, verbal persuasion, and physiological or affective states management [15]. Among them, mastery experience has been shown to be the most potent source of self-efficacy in different domains and populations [15, 25–27]. It refers to the direct experience of performing a specific task and, hence, it represents an authentic indicator of the individual ability to accomplish similar tasks in the future. Indeed, when people engage in tasks and activities, they interpret the results of their actions and they use such interpretations to develop beliefs about their capability and to subsequently act according with the created beliefs. Experiences interpreted as successful generally increase confidence while experiences interpreted as unsuccessful generally undermine it [15]. As a consequence, in light of the reciprocal influence between self-efficacy and behavior, the selection of any specific behavioral goal should be set with the aim to gradually support both the achievement of successful experiences and the increasing of self-efficacy. For this purpose, goals should be (i) doable in order to permit individuals to master successful experiences and (ii) challenging in order to adequately reinforce self-efficacy beliefs once the goal has been achieved [15, 28].
In recent years, we assisted the first attempts of developing computational models based on self-efficacy theory in order to promote PA [29, 30]. Self-efficacy theory is particularly suitable to be modeled because of its nature that is explicitly *dynamic* (i.e., it takes into account time-varying information such as individual achievements, self-efficacy beliefs and expectations) and, thus, permits adapting the intervention to the individual over the course of the intervention itself [12]. The advantages of developing a computational model based on a behaviour change theory, such as self-efficacy theory, mainly rely on the capacity of predicting directionality and magnitude of effects among variables (e.g., target behaviour and its psychological determinants), and simulating and testing how they change and influence each other across contexts and over time [31].
First computational models of self-efficacy focused on different approaches and frameworks. Pirolli [30] proposed a computational model, called ACT-R-DStress, aiming to (i) model interactions among behavioral goals, memories of past experiences, and behavioral performance, and (ii) explains and predict both the dynamics of self-efficacy and the individual performance in an exercise program. For these purposes the ACT-R-DStress exploited the computational neurocognitive architecture that characterizes the ACT-R theory’s simulation environment [32]. Differently, Martin et al. [29] developed a dynamical model of social cognitive theory adopting principles from control system engineering with a focus on system identification methodologies. Specifically, *system identification* compares what happens in different states and contexts of the person over time to what was predicted by a precise mathematical model of a given theory. Such methods have been applied to PA promotion and to generate dynamical models for future predictions to be tested against social cognitive theory (for an overview see [33]).
The current paper presents an innovative computational model that is conceptually framed in self-efficacy theory with a particular emphasis on self-efficacy beliefs and goal setting constructs. The computational model is embedded in a digital behaviour change intervention delivered by *Muoviti!*, a mobile app and heart rate monitor system that aims at the promotion and maintenance of PA among adults not meeting the recommended PA guidelines. The main contribution of the current work is twofold: (i) generating a computational model that combines input data collected through mobile technology (i.e., amount of PA collected through a heart rate monitor, SE assessed through ecological momentary assessment) in order to set PA goals that are dynamically adapted to each individual’s achievement and changes in SE over time and (ii) tuning the proposed computational model according to early empirical findings from real case studies.
## 2. Materials and Methods
### 2.1. Overview of Muoviti!
#### 2.1.1. The Experimental System.
The experimental system that constitutes *Muoviti!* is made of three key components (see Figure 1):
(i) A heart rate (HR) wristband needed to measure the amount of PA performed. More specifically, two commercial, low-cost and reliable HR monitors (i.e., MioAlpha, PulseON) have been tested. Such devices nonetheless provide an estimate of the relevant physiological parameters which is precise and reliable enough for our purposes [34, 35].
(ii) A smartphone app which (i) handles the user interface, (ii) ecologically assesses SE through an *ad hoc* short questionnaire, (iii) collects information from the heart rate monitor, and (iv) transfers information to/from the back office.
(iii) A back office with a server that stores the data relative to each person and executes the modeling algorithm, thus formulating tailored PA suggestions for the next training period.
*Muoviti!* operates as follows. At the beginning of each weekly training period, a suggested PA goal for the week is generated on the basis of two different input data: (i) goal achievement during the previous week and (ii) SE beliefs in doing physical activity during the previous week. Finally, *Muoviti!* splits the weekly PA goal into daily short-term goals, translates them into concrete PA tasks (e.g., minutes of running, or fast walking), and presents them to the user (see below in the ‘Computational model’ paragraph).
### 2.1.2. Graphical User Interface
Figures 2 and 3 illustrate the main components of *Muoviti!*’s graphical user interface. During the login process, users are asked to specify the login credentials (Figure 2.1), their age (Figure 2.2), and other
parameters like weight and waistline (Figure 2.3) that are useful to evaluate possible benefits or drawbacks emerging from exercising. Furthermore, the figure shows the interface for the collection of values to assess users’ self-efficacy after a physical activity session (Figure 2.4). Each week the training sessions calendar is automatically updated on the basis of previous training sessions results (Figure 3.1). The user can manually place the activities suggested by the system to fit better with other duties (e.g., working hours). The calendar provides the patient with important information about the training event (Figure 3.2), like the weather forecasting, the duration and intensity of the activity to do, with the possibility for the user to change the position of the activity in the agenda. Finally, the system supports the user in self-monitoring and collecting significant data when the activity is accomplished (Figure 3.3), in particular the heart-beat rate, a visual warning about the correct execution of the activity, and the shortcuts to statistics and graphs about the results obtained.
Finally, Figure 4 illustrates how the individual performance has varied over the time, to provide people with an immediate feedback about the results obtained day by day and week by week. *Muoviti!* currently allows visualizing the heart-beat rate graph of the last training session, the curves of weight and waistline variations week by week, the burned calories graph, session by session, and the percentage of vigorous activity with respect to moderate activity.
### 2.2. Measures
#### 2.2.1. Physical Activity
The computation of the PA goal for the new training period (i.e., output data) is expressed in terms of METs (Metabolic Equivalent of Task) that is a measure of the amount and quality of performed PA normalized to the physical characteristics and age of the individuals. Specifically, it METs represent the ratio of the metabolic rate (the rate of energy consumption) during a specific exercise to a reference metabolic rate:
\[
1 \text{MET} = \frac{kcal}{kg} \ast h
\]
(1)
MET is used as a mean of expressing the intensity and energy expenditure of activities in a way comparable among persons of different weight. Actual energy expenditure (e.g., in calories or joules) during an activity depends on the person’s body mass; therefore, the energy cost of the same activity will be different for persons of different weight. When the subject begins performing a PA training session, she/he asks the app to start the collection of PA data through the Bluetooth connection with the wristband. The app translates the HR collected by the wristband into the equivalent energy expenditure (METs), given by the following formula [36]:
\[
MET \ minutes = 4 \ast Time^{MPA} + 8 \ast Time^{VPA}
\]
(2)
where \(Time^{MPA}\) and \(Time^{VPA}\) are the periods of time the subject is involved in moderate physical activity (MPA) and vigorous physical activity (VPA) and parameters 4 and 8 represent the corresponding MET expenditure per minute. A PA session is defined as moderate if the registered HR values are in the range \([6 \ast MHR/10, 7 \ast MHR/10]\), while it defined as vigorous if the registered HR values are in the range \([7 \ast MHR/10, 8 \ast MHR/10]\). MHR represent the maximum heart rate depending on the subject age and it is calculated by subtracting \(age\) to a standard value (i.e., \(220 - age\)).
#### 2.2.2. Self-Efficacy Beliefs
SE beliefs are ecologically assessed at the end of each training session, through a set of questions to the person, each concerning a specific aspect of the physical activity. Currently, two questions are proposed to the user to evaluate the self-efficacy beliefs referring to the PA they have just performed:
(i) How much do you feel able to do a similar training next week, despite its duration?
(ii) How much do you feel able to do a similar training next week, despite its intensity?
The SE score is given by the arithmetic mean of the provided answers:
\[
SE_i = \frac{\sum_{i=1}^{n} answer_i}{n}
\]
(3)
where \( n \) is the number of questions posed to the user and \( answer_i \) is the value given by the user on a 4-point Likert scale, ranging from 1 (not able at all) to 4 (absolutely able). The advantages of assessing SE through digital ecological momentary assessment rely on the opportunity to minimize recall bias, maximize ecological validity, and better understand behaviour in real-world contexts [37].
2.3. Intervention Design. Muoviti! aims to homogeneously merge physical and psychological variables into a unique conceptual framework, in order to build up tailored PA goals. For this purpose, at the end of the weekly period, the app interacts with the user by notifying the degree of accomplishment of the weekly goal and sends the recorded data to the back office. Muoviti!’s back office aggregates PA accomplishments and SE scores from each single training session in order to get a global evaluation of the users’ PA accomplishments and SE beliefs over the week. The global evaluation of PA achievements and SE beliefs over the weekly period may assume the following facets and codes:
(i) Physical activity:
(a) The weekly PA goal was achieved (PA+);
(b) The weekly PA goal was not achieved (PA-);
(ii) Self-efficacy:
(a) The weekly PA self-efficacy was high – average SE equal or higher than 2.5 (SE+);
(b) The weekly PA self-efficacy was low – average SE lower than 2.5 (SE-).
After this assessment is made, the PA goal for the next week is proposed. Table 1 shows the decision rules about how global evaluations of PA and SE are combined in order to set new goals.
Finally, according to the user preferences, the PA goal for the next training period is successively split in daily short-term goals in order to support an effective action planning. The goal setting strategies at each period are taken with the aim of obtaining a successful result in a long-term perspective that is determined according to the general guidelines for PA promotion, which state that a person should perform 600 METs per week of PA [3].
2.4. Computational Modeling. The developed computational model combines knowledge about the PA performed, measured through the data collected by the wearables and an ecological momentary assessment of self-efficacy beliefs. The model was employed to define and dynamically adapt, a PA plan consisting of suggestions about the PA goal to be carried out every week, with the aim of maximizing the probability of bringing the person to the recommended PA level at the end of the long-term training period. The mathematical model adopted is a Dynamic Decision Network (DDN), a sequence of simple Bayesian Networks (BN), each representing the person’s situation at a specific training period (i.e., one week). Figure 5 shows the current decisional model in Muoviti! (Part (a)) and the future one (Part (b)). The basic BN embodies variables which represent the physical activity performed, the estimated self-efficacy of the period, and the possible external factors (e.g., weather) influencing the performed activity. The DDN model includes decision variables at each training stage, which represent the PA goal proposed for the week, and a utility function on the final level of PA achieved. Moreover, the mathematical model of Muoviti! clearly combines self-efficacy with objective measurements of PA, being able to build up a personalized plan taking into account possible different trajectories towards the final goal.
The DDN model has been preferred to other approaches present in the literature (for instance, based on neurocognitive simulation [30] or on the theory of dynamic systems [29] because it represents with accuracy the sequence of decision points (the weekly PA suggestions) that we have envisioned in our approach. An explanation of the model can be given as follows: the NEW GOAL variable (on Figure 5, part (a))
| Condition | Goal for the new training period (newGOAL) | Rationale for the goal setting strategy based on the relevant literature [15, 28] |
|-----------|------------------------------------------|--------------------------------------------------------------------------------|
| (PA+) & (SE+) | Increase PA goal | Setting a harder goal is challenging but doable for the person, because it is in line with the physical capabilities and supported by strong SE beliefs |
| (PA+) & (SE-) | Maintain the same PA goal | Maintaining the same goal is a strategy to reinforce the self-efficacy beliefs through the achievement of the same goal and thus train the person for successive more difficult goals |
| (PA-) & (SE+) | Maintain the same PA goal | Maintaining the same goal is a strategy to avoid disappointing motivations and self-efficacy beliefs, thus provides the person with a further opportunity to achieve a goal corresponding to his/her SE beliefs |
| (PA-) & (SE-) | Decrease PA goal | Setting an easier goal is a strategy to allow the person to become familiar with the behaviour through an easier task and reinforce self-efficacy beliefs through more likely successful experiences |
represents the decision to be taken at the beginning of each training period. It is influenced by the two basic variables describing the state of the subject: the SE and the level of success obtained in the preceding period, measured as the ratio of achieved METs with respect to the current GOAL. The achieved METs can be measured directly in our experimental system, and the SE can be evaluated from the result Q of a set of questions posed to the subject. Figure 5, Part (b) shows how the basic decision step is embedded in the sequence of time slices constituting the DDN. The structure of the model can be explained by considering its two main purposes:
1. Providing an integrated estimation of SE on the basis of the self-report assessment of SE (i.e., Q) and SE autocorrelation in preceding periods. We consider that SE is a long-term developing psychological determinant of PA; therefore, its values in succeeding periods are correlated. The model conditions the $SE_{t+1}$ value at the beginning of period $t+1$ to its preceding value $SE_t$, which has already shown its effects on the results (MET/GOAL) obtained in period t. We also introduced a variable EXT to explain away a decrease in SE when the observed PA shows a reduction due to factors external to the training (e.g., an illness or a period of bad weather).
2. Providing planning decisions. The sequence of decisions represented by the $GOAL_t$ variables must lead the subject to achieve the desired PA level before the end of the program; the decision to be taken in each period must be compatible with this long-term target (i.e., 600 METs per week). We call the sequence of decisions from the present time until the end of the program a strategy. The overall objective is modeled by defining a utility function computed on the expected value assumed by the MET variable in a stable, long-term situation. The utility value distribution can be computed, for each strategy, on the basis of the present state assuming no external interference. In this way an updated assessment of the possible strategies can be carried out at each decision step.
The model tuning consists of the derivation of the conditional probability tables (CPT) from the experimental collection of data, as described in the next section.
3. Results
Muoviti!’s computational model represents a mathematical description of a behaviour change model based on self-efficacy theory that needs to be tuned according to real case studies. To this scope, we assume that potential users of Muoviti! can be classified into different basic profiles and that such profiles are represented by the different values in the CPTs present in the model. In this section we present early findings from a study based on real case data. For these purposes, we recruited 60 potential users of Muoviti!, chosen among people involved in indoor physical activity, mostly using treadmills. Participants (35 female, 25 male) were asked to use Muoviti! for a period of eight weeks, splitting the proposed amount of MET into two sessions, as suggested by the application. Each participant was in the 35-60 years old range, equipped with an Android smartphone and a wearable device capable to detect heart-beat rate, provided by us (i.e., PulseOn) or on their own. The study started with 120 MET as a goal to accomplish in the first week.
According to the results obtained, crossing self-efficacy and MET values obtained at the end of the week training session, the new goal could be increased or decreased by 120 MET with respect to the previous, or not modified, till a maximum value of 600 MET to reach. The collected data were used to build up a user profiling, suitable for the future set-up of the Dynamic Bayesian Network: each user was characterized by METs and SE values obtained in the eight weeks of the study, for a total of 16 descriptors. These descriptors were compared with an optimal user profile, exploiting the case-based reasoning paradigm and the CREPERIE platform [38, 39]. In CREPERIE, a case is a finite collection of pairs \((ce_i, v_i)\), \(i \in [1, \infty)\), where case elements \(ce = (id, t, n)\), where \(id \in Z^+ - \{0\}\) is the case element identifier, \(t \in T\) identifies the range of values associated to ce (i.e., String, Integer, Double), and \(n \in \text{String}\) is the name of the case element; \(v \in t\) is the value associated to each ce. Case elements can be arranged into a vector or a tree. CREPERIE defines different kinds of similarity functions to use in the retrieval step, according to the nature of the case elements values. In particular, the following one has been adopted in our case study, given that the values are numbers:
\[
sf(n, x, y) = 1 - \frac{|v_{ce}(x) - v_{ce}(y)|}{\max - \min}
\]
(4)
where \(x\) and \(y\) are two cases, \(n\) is the attribute corresponding to \(ce(x)\) and \(ce(y)\), and \(\max = v_{ce}(n) \in x \cup y; v_{ce}(n) \geq v_{ce}(m)\), for all \(v_{ce}(m) \in x \cup y\) and \(\min = v_{ce}(k) \in x \cup y; v_{ce}(k) \leq v_{ce}(j)\), for all \(v_{ce}(j) \in x \cup y\). In other words, max and min can be substituted by the extremes of the normalization interval if needed.
Once \(sf(n, x, y)\) has been calculated for all \(n\) in \(x\) and \(y\), the similarity between case \(x\) and \(y\) is defined as follows:
\[
sim(x, y) = \frac{\sum_{n \in D} sf(n, x, y)}{\sum_{n \in D} w_n}
\]
(5)
where \(w_n \in [0, 1]\) is the weight of the attribute \(n\), \(sim(x, y)\) is the local similarity between cases \(x\) and \(y\), and \(D\) is the set of attributes in the cases.
Figure 6 shows the case structure adopted in our case study: the case elements were composed of 16 descriptors, eight met values reached during eight weeks of training and eight self-efficacy values calculated at the end of each week. The MET values are multiples of 120 in the range \([120, 600]\), in accordance with the theoretical background of the model. The SE values are in the range \([1, 4]\), according to (3). The denominator in the \(sf(n, x, y)\) calculus was equal to 480, given that the extremes of the met domain set were 120 and 600, respectively. Finally, we have considered \(w_n = 1\) for all \(n\).
Figure 7 shows the profiling of participants according to their similarity with the optimal profile. Four main clusters have been created: static, characterized by very low similarity degree with the optimal profile (less than 50%), capable, composed of profiles very similar to the optimal one (more than 70%), and a sort of “grey zone” with similarity between 50% and 70% where two subcategories can be identified, namely, complicated and slow but gradual. Complicated profiles are characterized by scarce physical performance and low self-efficacy, although they would potentially be able to reach proposed objectives; slow but gradual profiles are characterized by excellent physical performances, according to which they could be compared to optimal profile, but very low self-efficacy.
Table 2 shows some samples of users’ data from the graph in Figure 7. The optimal profile data used in the case-based reasoning is shown at the end of the table.
Table 2: Samples of users’ data referring to the current profiles emerged from the comparison with an optimal profile.
| Profile | Week | 1st | 2nd | 3rd | 4th | 5th | 6th | 7th | 8th |
|---------|------|-----|-----|-----|-----|-----|-----|-----|-----|
| **Profile 1—Capable** | | | | | | | | | |
| Goal (METs) | 120 | 240 | 360 | 480 | 360 | 480 | 480 | 480 | 600 |
| Achievement | YES | YES | YES | NO | YES | YES | YES | NO | |
| Self-Efficacy | HIGH | HIGH | HIGH | LOW | HIGH | LOW | HIGH | LOW | |
| **Profile 2—Slow but gradual** | | | | | | | | | |
| Goal (METs) | 120 | 240 | 360 | 360 | 360 | 480 | 480 | 360 | |
| Achievement | YES | YES | YES | YES | YES | YES | NO | NO | |
| Self-Efficacy | HIGH | HIGH | LOW | LOW | HIGH | LOW | LOW | LOW | |
| **Profile 3—Complicated** | | | | | | | | | |
| Goal (METs) | 120 | 240 | 240 | 240 | 360 | 480 | 360 | 240 | |
| Achievement | YES | YES | YES | YES | YES | NO | NO | YES | |
| Self-Efficacy | HIGH | LOW | LOW | HIGH | HIGH | HIGH | LOW | HIGH | |
| **Profile 4—Static** | | | | | | | | | |
| Goal (METs) | 120 | 120 | 240 | 120 | 120 | 240 | 120 | 120 | |
| Achievement | NO | YES | NO | NO | YES | NO | YES | YES | |
| Self-Efficacy | HIGH | HIGH | LOW | HIGH | HIGH | LOW | LOW | LOW | |
| **Optimal Profile** | | | | | | | | | |
| Goal (METs) | 120 | 240 | 360 | 480 | 600 | 600 | 600 | 600 | |
| Achievement | YES | YES | YES | YES | YES | YES | YES | YES | |
4. Discussion and Conclusions
This paper presented an innovative approach to promote PA behaviour change among inactive adults. The approach is based on the development of a computational model grounded in self-efficacy theory and on the integration of mobile technologies and dynamic decision networks. The main aim of Muoviti! is to suggest personalized PA goals that adapt to individuals’ changes in PA and self-efficacy over time. Early findings revealed the presence of four clusters of user profiles, reflecting the respective progression patterns towards the long-term goal. However, further research is needed to confirm such results by tuning the computational model around a greater number of real case studies. After having tuned the mathematical model in an experimental setting, Muoviti! will be tuned in real life contexts too. The purpose of this additional research phase is to develop a mathematical model that takes into account external (e.g., weather, time of the day, and day of the week), demographic (sex, age), and psychological (e.g., stress, outcome expectancies, and action control) factors that may influence the exercise behaviour. Furthermore, in the same vein, future research will aim to tune the current computational model in different populations (e.g., clinical populations) and contexts (e.g., rehabilitation settings) in order to validate its scalability. Finally, next works will be also devoted to develop an effective Android app for distribution: to this aim, many steps should be completed. In particular, the adherence of our approach to recent GDPR regulations must be implemented. At the current stage for development, personal data (like the heart-beat rate) of the users are stored inside their smartphones, while elaborations of the system are anonymized and stored in a cloud platform to be easily retrieved and used. Anyway, this is not sufficient to allow full sharing and downloading of the app through usual channels, like play-stores and websites. For this reason, at the end of this preliminary phase of analysis, where permissions to exploit user data have been only signed by the participants for research scopes, our strategy in future developments of the Muoviti! app will be completely revised.
Data Availability
The data used to support the findings of this study are available from the corresponding author upon request.
Conflicts of Interest
The authors declare that there are no conflicts of interest regarding the publication of this paper.
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WHY CHAOTIC MIXING OF PARTICLES IS INEVITABLE IN THE DEEP LUNG
Akira Tsuda$^1$, Fiona E. Laine-Pearson$^2$ and Peter E. Hydon$^2$
$^1$ Molecular and Integrative Physiological Sciences, Harvard School of Public Health, Boston, MA, 02115 USA.
$^2$ Department of Mathematics, University of Surrey, Guildford, GU2 7XH, UK
Running Head: Alveolar Recirculation and Chaotic Mixing
Corresponding author:
Akira Tsuda, PhD
Molecular and Integrative Physiological Sciences
Harvard School of Public Health
665 Huntington Avenue
Boston
MA 02115
Tel: 617 432 0127
Fax: 617-432-3468
Email: email@example.com
ABSTRACT
Fine/ultrafine particles can easily reach the pulmonary acinus, where gas is exchanged, but they need to mix with alveolar residual air to land on the septal surface. Classical fluid mechanics theory excludes flow-induced mixing mechanisms because of the low Reynolds number nature of the acinar flow. For more than a decade, we have been challenging this classical view, proposing the idea that chaotic mixing is a potent mechanism in determining the transport of inhaled particles in the pulmonary acinus. We have demonstrated this in numerical simulations, experimental studies in both physical models and in animals, and mathematical modeling. However, the mathematical theory that describes chaotic mixing in small airways and alveoli is highly complex; it not readily accessible by non-mathematicians. The purpose of this paper is to make the basic mechanisms that operate in acinar chaotic mixing more accessible, by translating the key mathematical ideas into physics-oriented language. The key to understanding chaotic mixing is to identify two types of frequency in the system, each of which is induced by a different mechanism. The way in which their interplay creates chaos is explained with instructive illustrations but without any equations. We also explain why self-similarity occurs in the alveolar system and was indeed observed as a fractal pattern deep in rat lungs (Proc. Natl. Acad. Sci. USA. 99:10173-10178, 2002).
Keywords: recirculation, Poincaré section, tangle, stretch and fold, self-similarity
1. INTRODUCTION
When a large number of aerosol particles enter the lungs in each breath, it is mostly the fine and ultrafine particles that reach the gas exchange region of the lungs. What fraction of the inhaled particles (e.g., particulate pollutants or therapeutic drug particles) actually deposits on the alveolar surface depends on how the particle-laden tidal air mixes with the alveolar residual gas, so mixing can have enormous physiological and pathophysiological consequences.
Even today, the most widely-used models of aerosol mixing (e.g., ICRP, 1994) cannot explain the transport of inhaled fine particles in the pulmonary acinus in a way that accords with experimental observations such as (Heyder et al., 1988). The most fundamental error in these classical models is that the possibility of flow-induced mixing is excluded a priori; for instance, Davies (1972) states, “Mixing between tidal and reserve air takes place in the dead space, above the respiratory bronchioles. In the alveolated regions there is no mixing....” Such models are based on a result from fluid mechanics: quasi-steady zero Reynolds number flow (Stokes flow) is kinematically reversible when the motion of the fluid’s boundaries is kinematically reversible (Taylor, 1960). Because acinar airflow has a very low Reynolds number (Pedley, Schroter, & Sudlow, 1977) and the basic mode of the acinar wall motion is kinematically reversible (Gil & Weibel, 1972; Ardila, Horie & Hildebrandt, 1974; Gil et al., 1979; Miki et al., 1993; Weibel, 1986), this assumption appears to be reasonable at first sight. However, the classical view of acinar fluid mechanics does not consider the details of local structure of alveolar flow. Moreover, it is well-established that chaotic transport (which is essentially irreversible) can occur in a wide range of flows at arbitrarily low Reynolds number (see Ottino, 1989 for examples).
It is reasonable to ask whether diffusion will enable particles to cross alveoli rapidly; where this happens (as it does for gases such as O₂ and CO₂), the details of the flow are largely irrelevant. The diffusivity in air of submicron particles, say from 0.5 μm down to 10 nm in diameter, is from around $10^{-7}$ to $10^{-4}$ cm²/sec respectively. Therefore, the Péclet number, which expresses the importance of airflow-mediated transport relative to diffusive transport, is much larger than unity in the acinus during normal breathing. This indicates that particle mixing and deposition in the acinus is largely determined by the acinar airflow pattern. Weak
diffusion may allow a particle to sample different parts of the pattern before it is deposited or ejected from the acinus (Laine-Pearson & Hydon, 2008), but the impact of this upon transport and deposition cannot be determined until the underlying flow is known. In essence, the flow provides a template for the transport of submicron particles, to which diffusion can be added as a weak perturbation. Throughout this paper, we restrict attention to particles that are carried passively with the flow, ignoring the effects of diffusion and particle inertia. We will also treat the flow as incompressible; this is an excellent approximation, because the maximum acinar flow speed is very much less than the speed of sound in air.
Over a decade ago, the first author and his group started to investigate more closely the fluid mechanics in the pulmonary acinus. We began by examining the effects of cyclic wall motion on acinar flow irreversibility (Tsuda, Henry, & Butler, 1995). We solved numerically low Reynolds number flow in an axisymmetric alveolated duct model and found that, provided the expanding and contracting alveoli are deep enough for recirculation to occur, the flow exhibits the following hallmarks of chaos. We observed a stagnation saddle point within the region in which the flow recirculates. The trajectories of particles that pass close to such a saddle point are complex; they are highly entangled and twisted, in a way that rapidly stretches and folds any sheet of particles, in much the same way that pastry dough is stretched and folded repeatedly to create flaky pastry. Consequently, the trajectories of nearby particles eventually diverge rapidly; this 'chaotic mixing' mechanism is highly efficient.
In a subsequent study (Henry, Butler, & Tsuda, 2002), we simulated the behavior of a tracer bolus (i.e., a cloud of fluid particles) in an axisymmetric acinar model with multiple alveoli and showed that a bolus evolved into fractal-like patterns after a few cycles. In parallel with these axisymmetric studies, we also solved Stokes flow in a fully three-dimensional alveolus model with cyclically expanding/contracting walls (Haber et al., 2000), confirming basic features of alveolar flow with a characteristic vortex and an associated stagnation saddle point in the alveolar flow field.
On the experimental side, both physical model and animal model experiments have been performed (Tsuda, Otani, & Butler, 1999; Tippe & Tsuda, 2000; Tsuda et al., 2002; Karl, Henry, & Tsuda, 2004). For
instance, using a large-scale axisymmetric alveolated duct model with moving walls, we confirmed a key prediction of our numerical analyses; namely, the presence of recirculation in an expanding (and contracting) alveolated geometry (Tippe & Tsuda, 2000). Developing a new visualization technique for physiological flows, we also demonstrated how inhaled tidal air and residual alveolar gas interact kinematically in animal lungs (Tsuda et al., 2002); we also found substantial alveolar flow irreversibility with stretched and folded fractal patterns, which lead to a marked increase in mixing. These experimental findings support our prediction that chaotic alveolar flow governs flow kinematics in the pulmonary acinus, and hence it determines the transport and deposition of inhaled fine particles.
However, there remains a substantial gap in the current understanding of acinar chaotic mixing by most biologists. We believe that this is mainly because of a lack of an accessible explanation of the highly mathematical concept of mixing by Hamiltonian chaos. Currently available explanations are either too mathematical, taking a highly specialized approach, or too superficial to impart any meaningful knowledge of basic mechanisms. The objective of this work is to achieve the middle ground, bridging biology and mathematics. We will describe the minimal essential components of this theory to extract the basic physics of acinar chaotic mixing, using instructive illustrations, but no equations. The ultimate goal of this work is to lead general readers of this journal (general biologists) to a basic understanding of chaotic mixing and thus to explain why this phenomenon occurs in the pulmonary acinus.
To keep our explanation of Hamiltonian chaos as simple as possible, we will assume that each particle's motion in the recirculating alveolar flow is restricted to a two-dimensional plane that is parallel to the ductal flow which drives the recirculation. Even though this is not so, it provides a foundation from which we can begin to understand chaotic mixing in the fully three-dimensional flow, as we discuss towards the end of the paper.
2. OVERVIEW OF ALVEOLAR FLOW
Our claim that chaotic mixing can occur in the acinus uses the fact that there are two kinds of frequency in the system, which are induced by two different mechanisms – it is their interplay that can create chaos.
One type of frequency ($f_1$) is associated with recirculation in the alveoli. If recirculation were the only type of fluid motion, particles that are carried passively with the flow would move around the alveolar cavity on closed trajectories called *recirculation orbits*, as shown schematically (in cross-section) in Fig. 1. The recirculation frequency $f_1$ for such a trajectory is the number of cycles around it that a particle completes per unit time; this frequency depends on which orbit is chosen. For instance, the recirculation frequency will be relatively small on orbits that lie very close to the alveolar wall, where the flow is slow; the frequency is greater closer to the center of the alveoli, where the flow is faster and the orbit length is shorter. It is important to note that the recirculation frequencies are *intrinsic* to the lung, depending on geometric factors such as the alveolar cavity shape and the size of the alveolar opening.
Flow past the opening is produced by breathing, which is externally determined by diaphragm and rib cage motion (controlled by the central nervous system). Furthermore, breathing causes the alveoli to expand and contract somewhat at the breathing frequency, $f_2$.
The motion of a particle depends on the ratio $f_1/f_2$; roughly speaking, this ratio dictates whether or not a particle will follow a chaotic path, as is explained in detail later. For now, it suffices to state that at certain ratios, when the frequencies $f_1$ and $f_2$ are said to be resonant, the interaction between the frequencies produces a net drift. This drift results in Hamiltonian chaos, except where it produces no qualitative change to the particle trajectories. The key to understanding chaotic mixing in the alveolus is to realize that when the Reynolds number\(^1\) (Re) is zero and the alveolar walls are stationary, passive particles in the alveoli simply recirculate. In this case, resonance does not produce a qualitative change in particle trajectories: each particle moves back and forth on a single (closed) path forever. However, wall motion (Tsuda, Henry, & Butler, 1995; Henry, Butler, & Tsuda, 2002; Laine-Pearson & Hydon 2006), airflow inertia (Tsuda, Henry, & Butler, 1995; Henry, Butler, & Tsuda, 2002; Henry, Laine-Pearson, & Tsuda, 2009) and a small amount of geometric hysteresis (Haber *et al.*, 2000; Haber & Tsuda, 2006) all perturb the particle motion in a way that depends on the breathing frequency $f_2$ but not on $f_1$. Each of these perturbations produces qualitative
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\(^1\) Re = UL/v, where U and L are (respectively) a characteristic velocity and length scale for the flow and v is the kinematic viscosity of the alveolar gas. Typically, Re < 1 in alveoli; consequently, the convective inertia of the gas produces only a small perturbation to Stokes (zero Re) flow.
changes in those trajectories where $f_1$ and $f_2$ are resonant; surprisingly, these changes are not strongly dependent on the cause of the perturbation. They are described by the mathematical theory of ‘perturbed Hamiltonian dynamical systems.’ Therefore we use the terms ‘unperturbed system’ and ‘base model’ for Stokes flow with alveolar recirculation and cyclically oscillating ductal flow alone. When wall motion and/or the airflow inertia is included, we describe the system as perturbed.
3. UNPERTURBED SYSTEM (BASE MODEL)
3.1 Trajectories lie on a torus
The interplay between the two kinds of frequencies ($f_1$, $f_2$) determines the motion of particles during a breathing cycle; this can be visualized schematically\(^2\) using nested tori (Fig. 2), with coordinates $(l_1, \theta_1, \theta_2)$. Here $\theta_2$ represents the phase in the breathing cycle: inspiration (marked Ins.) takes place between 0 and $T/2$; this is followed by expiration (marked Exp.) to time $T$, when the cycle begins again. For each value of $\theta_2$, the cross-section gives an instantaneous snapshot of the particles that lie on each orbit, which is a circle of radius $l_1$. As time progresses, each particle moves around its orbit; its angle to the horizontal is $\theta_1(t)$. So for each fixed $l_1$, a train of particles moves around the circle. By introducing the phase as an extra variable, we are able to visualize each particle’s motion as a trajectory on the torus with the appropriate $l_1$ (Fig. 3, left). The passage of time is marked by an increase in phase, and by the change of the angle $\theta_1(t)$ (see Fig. 3, right). So the trajectory on the torus looks like a thread that winds around the torus, passing through the hole in the middle once every time the orbit is completed.
This idea, and each of the results that follow, holds whenever an orbit can be deformed continuously into a circle; such an orbit may look like very a squashed circle indeed! So, for the remainder of the paper, we use the term ‘circle’ to describe any simple closed curve in the plane. The ‘angle’ $\theta_1(t)$ now has nothing to do with the horizontal; it is merely a coordinate that identifies where a given particle is located on the ‘circle.’ Similarly, a ‘torus’ is obtained by supplementing a ‘circle’ with the phase variable $\theta_2$.
\(^2\) It does not matter that inspiration and expiration are not necessarily of the same duration. What is important is that the closed trajectories exist and that breathing is (roughly) periodic in time.
The alveolar cavity is packed with a family of orbits with different frequencies (Fig. 1). The recirculation frequency $f_1$ increases smoothly as the center of an alveolus is approached; consequently, between any two orbits with recirculation frequencies $f_{1a}$ and $f_{1b}$, there lies an orbit with any specified intermediate frequency.
### 3.2 Rational or irrational frequency ratio
There are two qualitatively different types of unperturbed particle motion, depending on which recirculation orbit a particle is traveling on. We will include the phase for the rest of this subsection, so that we can think about which torus the particle moves on. Then the thread analogy is helpful: either the thread eventually joins up with itself forming a finite loop around the torus, or it continues winding around the torus forever (see Fig. 4). The distinction can be made by whether the ratio of the two frequencies ($f_1/f_2$) is a rational number or an irrational number\(^3\).
A 'rational torus' is one for which the ratio of frequencies ($f_1/f_2$) is rational, so that the frequencies are resonant. For such a torus, one can always choose time units such that $f_1 = p$ and $f_2 = q$, where $p$ and $q$ are integers. The particle comes back to its original position after $p$ revolutions with respect to the angular coordinate $\theta_1$ and after $q$ revolutions with respect to the phase coordinate $\theta_2$. The trajectory is closed (that is, the thread joins up), because it repeats its motion and phase after $p$ rotations along the alveolar recirculation orbit and after $q$ breathing cycles (Fig. 4, Middle).
On the other hand, for 'irrational tori,' for which the ratio of frequencies ($f_1/f_2$) cannot be expressed as the ratio of two integers, the particle never comes back to its original position. The trajectory cannot ever close (Fig. 4, Top and Bottom).
The recirculation frequency $f_1$ varies continuously from one torus to the neighboring tori, whereas the breathing frequency $f_2$ is fixed. Therefore the ratio $f_1/f_2$ varies continuously and so any set of nested tori will contain both rational and irrational tori. The distinction between rational and irrational tori is important,
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\(^3\) A rational number is a number that can be expressed as a fraction $p/q$ where $p$ and $q$ are integers and $q$ is positive. An irrational number is a number that cannot be expressed as a fraction $p/q$ for any integer $p$, $q$. Irrational numbers have decimal expansions that neither terminate nor become periodic.
because rational (resonant) tori break into chaos under perturbations while ‘sufficiently irrational’ tori remain as tori (although they may deform).
3.3 Poincaré section
Because it is difficult to trace the 3-dimensional particle orbit on the curved surface of a torus, we introduce a powerful method – the idea of the Poincaré section. This is a plot of the points where one (or several) particle’s trajectory on the torus intersects the surface $\theta_2 = 0$; see Fig 5 (Left). In other words, it is a trace of the positions in the alveolar cross-section of one or more particles, recorded at the beginning of each inspiration (though any other fixed phase would do as well).
Rational torus – periodic points
A particle on a rational torus returns to its original position after $p$ revolutions of $\theta_1$ and $q$ revolutions of $\theta_2$; the particle then traces the same trajectory on the torus repeatedly. In the Poincaré section, this trajectory appears as a set of $q$ ‘periodic points,’ which is determined by the particle’s initial position.
Irrational torus – quasiperiodic orbit
A particle on an irrational torus will never come back to its original position at the original phase and therefore can never repeat the same orbit. In this case, the trajectory on the torus is called quasiperiodic. In the Poincaré section, this corresponds to an infinite set of non-periodic points; for any particular starting point. The set appears to fill a circle after many revolutions of $\theta_1$ and $\theta_2$ have been completed.
4. PERTURBED SYSTEM
Now, let us perturb the system. As described above, the perturbations include alveolar wall motion, airflow inertia (Reynolds number), and geometric hysteresis in the respiratory physiology. Surprisingly, the Poincaré section undergoes a dramatic qualitative change even when the perturbation is infinitesimal.
4.1 Irrational tori
Irrational tori can be split into two categories, which determine the fate of these tori when their system is perturbed infinitesimally. The distinction is between irrational numbers that can be well-approximated by
rational numbers whose denominator is small (which are ‘insufficiently irrational’) and those that cannot, which are classed as ‘sufficiently irrational’. This terminology comes from number theory (Tabor, 1989).
**Sufficiently irrational tori**
Irrational tori for which $f_1/f_2$ is sufficiently irrational survive infinitesimal perturbation and remain essentially intact\(^4\); although they may deform, trajectories on them continue to resemble closed curves in the Poincaré section.
**Insufficiently irrational orbits**
Tori for which $f_1/f_2$ is insufficiently irrational react to the perturbation similarly to the nearest rational torus whose denominator is small (see below). This is unsurprising, because these tori are very near neighbors. What is more surprising is that the smaller the denominator is for a rational torus, the greater is its region of influence. It ‘swallows’ the neighboring insufficiently irrational tori (and the neighboring rational tori whose denominator is large), creating instead a highly complex structure, which we describe next.
### 4.2 Rational orbits
Rational tori cannot persist when a perturbation is applied. These tori, and the surrounding insufficiently irrational tori, break and are replaced by a complex pattern of chaos intermingled with regularity. The regularity occurs because an orbit of a particle drifts a little bit from the original rational torus due to an applied perturbation, but the particle still intersects the Poincaré section near the periodic points, forming a circle around the periodic points on the Poincaré section; an example is given in Fig. 5 (Right).
Before continuing with this explanation, let us see how the perturbation, which produces circles on the Poincaré section Fig. 5 (Right), affects the 3-dimensional torus structure. Fig. 6 gives an example for three tori. When the system is perturbed, the two sufficiently irrational tori are persistent but the rational torus has been replaced by a tube-like object that winds around the inner torus but is encased by the outer torus. Fig. 7 shows the same effect for five tori.
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\(^4\) These persistent tori are guaranteed by KAM (Kolmogorov-Arnol’d-Moser) Theory (Tabor, 1989; Lichtenberg & Lieberman, 1992) and its extensions, provided that the perturbation is sufficiently small. Typically, for alveoli, the perturbation is small enough (Laine-Pearson & Hydon, 2006; Henry, Laine-Pearson, & Tsuda, 2009).
4.3 Direction of particle motion on the closed curves
Newly developed tube-like structures (a decadence of rational tori) are bounded by deformed sufficiently irrational tori. Now, let us consider the behavior (frequency and direction) of rotation of those inner/outer irrational tori and the original rational torus appearing in Fig. 5. Recall that the alveolar recirculation frequency increases toward the center of an alveolus. Therefore particles on the inner irrational torus rotate the fastest; those on the rational torus rotate more slowly, and those on the outer irrational torus rotate the slowest. Suppose for definiteness that all particles are rotating counter-clockwise. If we look at the frequency differences from the rational torus, particles on the inner irrational torus appear to rotate counter-clockwise, while those on the outer irrational torus rotate clockwise (see Fig. 8, Left). Considering the opposing directions of the inner/outer irrational tori, as a result, particles on each of the closed curves that surround a periodic point will rotate clockwise. It is important to bear in mind that the apparent direction of motion on the Poincaré section is merely a pale reflection of the complex behaviour of trajectories in 3-dimensional space. Nevertheless, it provides a snapshot that enables us to deduce the existence of chaos, as we now explain.
4.4 The existence of unstable points
The points around which particles appear to rotate on closed curves (in the Poincaré section) are called ‘elliptic fixed points’ (Fig. 8, Left). These points are Lyapunov stable; roughly speaking, this means that any trajectory that starts near such a point remains near to it for all time\(^5\). Now, let us consider the flow of the arrows, i.e., the local direction of particle movement, in Fig. 8. By tracing the direction of the arrows for the closed curves around the stable points, it follows that another set of points that are in between the elliptic points must exist. This is because all of the particles on closed curves in a single perturbed orbit rotate in the same direction (‘clockwise’ - in this example). Consequently, as the flow is continuous, there is a meeting-point between the flows that rotate about each elliptic fixed point\(^6\) (Fig. 8, Right). Each meeting-point is called a ‘hyperbolic fixed point’; in Hamiltonian dynamical systems, such points are unstable,
\(^5\) For a strict definition of this type of stability, see page 101 of Ottino (1989).
\(^6\) The existence of hyperbolic and elliptic points is guaranteed by the Poincaré-Birkhoff Fixed-Point Theorem (Tabor, 1989; Lichtenberg & Lieberman, 1992).
because each one has a direction in which the flow is directed away from it. As we shall see, hyperbolic points are the origins of Hamiltonian chaos.
4.5 Hyperbolic points, lobes and heteroclinic tangles
We now focus on the phenomena that occur close to a hyperbolic point, $H$. For the sake of our discussion, consider two hyperbolic points ($H_1$ and $H_2$) in close proximity and the elliptic point ($E$) that lies between them (Fig. 9a). First, notice the direction of flow near each $H$; the flow goes into and comes out of $H$. The curves that point toward $H_1$ and $H_2$ are called ‘stable curves (S)’, and the curves that point away are called ‘unstable curves (U)’. The stable and unstable curves are orbits, so if a particle lies on such a curve at any instant, it remains on the curve forever.
The question arises: how do these stable (S) and unstable (U) curves intersect each other? We follow the nice explanation given by Nicolis & Prigogine (1989); complementary explanations can be found elsewhere (Tabor, 1989; Ottino, 1989; Lichtenberg & Lieberman, 1992). One possibility would be that S and U join smoothly, forming an arc between $H_1$ and $H_2$.\footnote{This is called a ‘heteroclinic orbit’ or ‘heteroclinic connection’; see Fig. 10.} However, this is a rather special\footnote{Another possibility would be that the S and U from the same point connects back to itself (it creates a loop). This is called a ‘homoclinic orbit’ or ‘homoclinic connection’. However, again, this is a rather special case, and only occurs in integrable systems, thus should be disregarded. The third possibility could be that the S and U do not connect to anything – they extend to infinity. This last possibility also has to be disregarded for periodic systems such as ours. See Fig. 10 for illustrations.} case and only occurs strictly for integrable\footnote{Loosely speaking, the term ‘integrable’ implies that a Hamiltonian system is solvable in principle; however, it does not guarantee that the calculations will be manageable! Classical integrable systems exhibit regular motion, whereas nonintegrable systems have chaotic motion. Therefore integrability is an intrinsic property and not just a matter of whether a system can be explicitly integrated in exact form.} systems. Because our perturbed system is a near-integrable (and thus nonintegrable) system, this highly special case should be disregarded.
The typical behavior of most types of near-integrable systems was discovered by Poincaré and studied later in some detail by Birkhoff and Smale: the stable (S) and unstable (U) curves cross at a point (X) called a ‘heteroclinic point’. Furthermore, they intersect not just once, but infinitely many times, as we now explain. We use the notation $X_n$ to mark all intersection points in the Poincaré section (Figs. 9b-9g); the subscript $n$ denotes the order along S and U in which they occur. After each successive breathing cycle, any particle
that lies on the stable curve $S$ in mapped to another point on $S$ that is closer to $H_2$. Therefore there is a sequence of points $X_1, X_2, X_3, \ldots, X_n$ that lies on the stable curve ($S$) and converges to $H_2$ as $n$ approaches infinity. Similarly, by looking backwards in time (like playing a movie backwards), one generates a sequence of points $X_{-1}, X_{-2}, X_{-3}, \ldots, X_{-n}$, that lies on the unstable curve ($U$) and converges to $H_1$ as $n$ approaches infinity. Fig. 9b illustrates this. [Note: do not assume that a particle at $X_1$ is mapped to $X_2$, which is mapped to $X_3$, etc. As we explain in our discussion of lobes (see below) it turns out (typically) that each intersection point is mapped to the next point but one, so that $X_1$ is mapped to $X_3$, etc.]
So far, we have looked only at the evolution of particles that lie on $S$ and $U$ separately. To see why there must be infinitely intersections between these curves, suppose that there is one intersection $X$ (Fig. 9c); we shall regard this as the point $X_1$. As the heteroclinic point $X_1$ belongs to $U$ and $S$ simultaneously, a particle on it moves after one breathing cycle to another point that belongs to both $U$ and $S$; the process is repeated with each successive breathing cycle. The same is true for all other heteroclinic points. Therefore the unstable curve ($U$) must repeatedly intersect the stable curve ($S$) at $X_2, X_3, \ldots$, as shown in Fig. 9d.
Similarly, one can retrace back in time to see that the stable curve ($S$) intersects the unstable curve ($U$) at the points $X_{-1}, X_{-2}$, and so on (Figs. 9e, 9f). Furthermore, $X_n$ must converge to the hyperbolic points $H_2$ (respectively $H_1$) as $n$ approaches positive (respectively negative) infinity, suggesting that there must be infinite numbers of heteroclinic points near to the hyperbolic points $H_1$ and $H_2$ (Fig. 9g).
A second set of heteroclinic points is generated by the other $U$ and $S$ curves emanating from $H_1$ and $H_2$ that lie beneath $E$. Fig. 9h\textsuperscript{10} shows both sets of curves and heteroclinic points. There now appears an overlap of curves near the two hyperbolic points. This ‘tangle’ of curves will be explained in more detail below. In 1899 Poincaré attempted to draw a similar figure and remarked that: “One is impressed by the complexity of this figure that I will not even try to draw” (Poincaré, 1899).
\textsuperscript{10} We are fully aware of the fact that a real aerosol particle is subject to stochastic bombardment by neighboring gas molecules (e.g. Brownian motion), which gives rise to diffusion. The closer two particles’ trajectories come to each other, the more rapidly will diffusion blur their independent existence. Therefore, a structure like Fig 9h is not likely to be seen in the real alveoli. However, with Fig. 9h, we are showing the underlying flow phenomena which one needs to consider when dealing with diffusive particles. The weaker the diffusion is, the longer is the time during which the underlying flow structure will be visible.
The crossing of unstable and stable curves creates areas called lobes, as shown in Fig. 9h; the area of each alternate lobe is conserved\textsuperscript{11}. Roughly speaking, lobe area is conserved because the flow is incompressible. Each lobe is bounded by the curves $U$ and $S$; if one takes phase into account, these curves form the boundary of a rope-like region that winds around the torus. No particle can cross the boundary, because once a particle is on a stable or unstable curve (in any Poincaré section, for any phase) it remains there forever. The particles that are in a given lobe remain in every lobe that is formed by later intersections of the initial lobe's 'rope' with the Poincaré section. As the fluid is incompressible, each of these lobes has the same area.
Typically, the above sequence of lobes constitutes the \textit{alternate} lobes, so there are usually two such sequences intertwined. The reason for this is that the direction of flow close to the stable and unstable curves is preserved. For instance, if the flow is clockwise close to $S$ (and therefore anticlockwise close to $U$) in one lobe, these directions are reversed in both of the adjacent lobes. The directions in successive lobes alternate, whereas in each 'rope,' the particle flow is in a single direction close to $S$ (or $U$). Thus each lobe is mapped to the next lobe but one. We have already seen that lobe area is preserved at every successive intersection of the 'rope' with the Poincaré section, so we must conclude that area is preserved in every alternate lobe. (A helpful aid is to think of any pair of adjacent lobes as a single unit; this is mapped to each successive pair, preserving the lobe areas and the directions of flow of the original pair at each stage.) The argument above also explains why a particle at $X_1$ is mapped to $X_3$ rather than $X_2$.
The preservation of lobe areas has an important consequence: because the distance between the $X$ points becomes shorter and shorter as the heteroclinic points approach $H_1$ and $H_2$, the lobes have to be thinner and thinner, as well as more and more stretched to maintain equal areas. The overlapping of lobes seen in Fig. 9h becomes more and more complicated as the lobes are stretched further and further. Specifically, any part of a lobe that intersects another lobe (with the same directions) does so not just once, but for ever.
\textsuperscript{11} See page 140 of Ottino (1989) for further details. For clarity, our explanation is simplified somewhat; a more complete analysis of transport mechanisms involving lobes can be found in Horner et al. (2002) and Wiggins (1992).
This is a very complex tangle! Chaotic motion occurs in a tangle\(^{12}\) because the lobes are repeatedly stretched, squashed and folded, rapidly separating the trajectories of particles that began as neighbors. This mechanism is reminiscent of the action of a salt water taffy pulling machine. It is commonly accepted that the existence of heteroclinic points is diagnostic of chaos (Ottino, 1989).
### 4.6 Self-similarity
To explain the concept of ‘self-similarity’ we return to the tube-like objects of Fig. 6 and Fig. 7. Recall that after perturbation the rational and insufficiently irrational tori do not persist. Instead, the periodic points of rational tori are the seeds for elliptic points and hyperbolic points. Around the elliptic points, we have seen that small circles can form in Poincaré sections and that these circles relate to 3D tube-like objects that are bounded by surviving sufficiently irrational tori.
The small circles are reminiscent of the concentric circles seen for the Poincaré sections of unperturbed tori. This is not a coincidence. To understand why this occurs, we must recall a few details.
**Note 1:** For a sufficiently small perturbation, most of the tori will survive (these are the sufficiently irrational tori)\(^{13}\).
**Note 2:** On perturbation, the rational (and insufficiently irrational) tori will be replaced by a set of alternating elliptic and hyperbolic fixed points\(^{14}\).
On adding an infinitesimal perturbation to a set of concentric circles, Note 1 guarantees that most will survive. Those that do not survive are replaced according to Note 2, which acknowledges that elliptic points will form. As these points are stable points, circles can form in a neighborhood of each elliptic point.
Now, while the system is being perturbed, these newly created elliptic points and their circles are also subject to the perturbation. Circles that are sufficiently irrational are guaranteed to persist according to Note 1; these circles relate to the tube-like objects shown in Fig. 6 and Fig. 7. Those that would have been
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\(^{12}\) It is called a ‘Smale horseshoe’.
\(^{13}\) This is due to KAM Theory (Tabor, 1989; Lichtenberg & Lieberman, 1992).
\(^{14}\) This is due to the Poincaré-Birkhoff Fixed-Point Theorem (Tabor, 1989).
rational or insufficiently irrational will be taken care of by Note 2 – they are replaced by a set of alternating elliptic and hyperbolic points. Around these elliptic points, a set of circles can form and so on.
In principle, the process of applying Note 1 and Note 2 simultaneously can be done infinitely many times (i.e. on all scales/magnifications). This means that we could zoom into an island (this is a name commonly used for the region around an elliptic point) and see that it is partly made up of chains of smaller islands. We could then zoom into one of these smaller islands to find, again, that these are partly made up of even smaller chains of islands (Fig. 11). This phenomenon appears on all scales and so we describe such a behavior as ‘self-similar’. (For the 3D picture, imagine that the tube-like objects will be wound by finer tubes, and these tubes will be wound by even finer tubes, and so on and so forth. One could try constructing such a structure by winding a rope around a rubber ring and then winding a piece of string around the rope, and then winding a thread around the string. Even this demonstration would only hint at the level of complexity occurring.)
Therefore, when the system is perturbed, an intricate re-organization occurs. Chaos is seen on all scales, because each time elliptic points are generated, so too are hyperbolic points. But this is a well-organized chaos – it is trapped by regularity\(^{15}\).
We finish this subsection with an example of organized chaos that occurs in a simple model that combines recirculation in a two-dimensional cavity with oscillating wall motion. Fig. 12 shows Stokes flow in the cavity; each color represents a different particle trajectory. The left-hand figure shows the paths that particles follow when the walls are stationary. The right-hand figure is a Poincaré section that illustrates how particle paths change when the walls oscillate very slightly. On comparison of the left and right figures, some of the original closed curves persist after perturbation but have deformed, while others have broken and are replaced by chaos. Additional trajectories have been added to the right-hand figure for further detail – they show the features that are universal in perturbed Hamiltonian systems, namely chains of islands surrounded by seas of chaos.
\(^{15}\) This is typically described as ‘Hamiltonian chaos.’
4.7 What happens when particle motion is not two-dimensional
As we stated in the Introduction, a major simplifying assumption in the above explanation is that in the recirculating flow, each particle's motion is restricted to a two-dimensional plane. In reality, however, the flow in cavities such as alveoli is three-dimensional. The cross-plane motion is slow relative to the recirculation, and therefore it is reasonable to regard this as an extra perturbation to the case we have already considered. Just as we created a Poincaré section for the two-dimensional motion in a single plane, we can do the same for the whole alveolus, taking a snapshot of particle positions once per breathing cycle. Because the fluid is incompressible, this process creates a volume-preserving map, called a Liouvillian map, which takes each point in the alveolus to its position one breath later.
In three spatial dimensions, the circles that we described in the base model are in fact cross sections of cylinders (with the usual allowance for these to be continuously deformed). Consequently, within the region where recirculation occurs, the base model without cross-plane flow is an example of an integrable two-action, one-angle Liouvillian map. The effects of perturbations on such maps have only recently begun to be understood; see Cartwright et al. (1996) for an accessible account. Briefly, the perturbations due to cross-plane flow, wall motion, etc., cause a particle to stay on a torus in the alveolar space for a while, until it encounters a region of chaos (produced by resonance), when it is able to move to another torus. So a typical particle will alternately exhibit regular and chaotic motion. This type of chaotic mixing is much more effective than when each particle is confined to a plane; it allows particles to move efficiently across the whole alveolus.
5. CONCLUSIONS
The essential structure of the pulmonary acinus is a collection of air pockets where airflow patterns form. When an alveolus is sufficiently deep and a flow passing by its opening is sufficiently strong, recirculation can occur. The theoretical basis for the existence of alveolar chaotic mixing is essentially the complex interplay between this alveolar recirculation and cyclic breathing as we have explained above. From this, therefore, a couple of fundamental conclusions can be readily drawn. (1) There are several hundred million
alveoli in human lung (e.g., Weibel, 1963; Ochs et al., 2004) and, according to our recent calculations (Tsuda, Henry, & Butler, 1995, 2008; Henry & Tsuda, 2010), most of the alveoli have recirculating flow. This means that as we breathe, hundreds of millions of alveoli in our lung act as a mixing generator. While each individual unit may be small, the cumulative effect of this enormously large number of mixers is likely to be significant. (2) We have shown, through our past studies (summarized in Tsuda, Henry, & Butler, 2011), that alveolar recirculation is intrinsic to the system. Some lung diseases affect this; for example, enlarged emphysematous alveoli have different alveolar recirculating flow patterns to healthy alveoli (Tsuda, Henry, & Butler, 2011). (3) In the first few years of life, the alveolar shape may have an even more significant role in determining particle transport. As the lungs develop, not only does the number of alveoli increase, but also the shape of each alveolus changes dramatically. Newborn babies have shallow saccular alveoli, in which recirculation does not occur. By the age of two, many of the alveoli are sufficiently deep for recirculation to occur. Consequently there are dramatic changes in alveolar flow and particle mixing as the lungs develop, particularly over the first two years of life.
ACKNOWLEDGEMENT
This work was supported by National Heart, Lung, and Blood Institute Grants HL054885, HL070542 and HL074022. We thank the referees for their helpful advice.
REFERENCES
1. Ardila, R., Horie, T., Hildebrandt, J., 1974, Macroscopic isotropy of lung expansion. *Respir. Physiol.* 20: 105-115.
2. Cartwright, J.H.E., Feingold, M., Piro, O., 1996, Chaotic advection in three-dimensional unsteady incompressible laminar flow. *J. Fluid Mech.* 316: 259-284.
3. Davies, C.N., 1972, Breathing of half-micron aerosols. II Interpretation of experimental results. *J. Applied Physiology*, 32(5): 601-611.
4. Gil, J., Weibel, E.R., 1972, Morphological study of pressure-volume hysteresis in rat lungs fixed by vascular perfusion. *Respiratory Physiol.* 15:190-213.
5. Gil, J., Bachofen, H., Gehr, P., Weibel, E.R., 1979, Alveolar volume-surface area relation in air and saline-filled lungs fixed by vascular perfusion. *J. Appl. Physiol.* 45:990-1001.
6. Haber, S., Butler, J.P., Brenner, H., Emanuel, I., Tsuda, A., 2000, Flow field in self-similar expansion on a pulmonary alveolus during rhythmical breathing. *J. Fluid Mech.* 405:243-268.
7. Haber, S., Tsuda, A., 2006, Cyclic model for particle motion in the pulmonary acinus. *J. Fluid Mech.* 567:157-184.
8. Henry, F.S., Butler, J.P., Tsuda, A., 2002, Kinematically irreversible flow and aerosol transport in the pulmonary acinus: a departure from classical dispersive transport. *J. Appl. Physiol.* 92:835-845.
9. Henry, F.S., Laine-Pearson, F.E., Tsuda, A., 2009. Hamiltonian chaos in a model alveolus, *J. Biomech. Eng.* 131:011006(1)-011006(7).
10. Henry FS, Tsuda A., 2010. Flow and particle tracks in model acini. *J. Biomech. Eng.* 132(10):101001(1)- 101001(11).
11. Heyder, J., Blanchard, J.D., Feldman, H.A., Brain, J.D., 1988, Convective mixing in human respiratory tract: estimates with aerosol boli. *J. Appl. Physiol.* 64:1273-1278.
12. Horner, M., Metcalfe, G., Wiggins, S., Ottino, J.M., 2002, Transport enhancement mechanisms in open cavities. *J. Fluid Mech.* 452: 199-229.
13. ICRP, 1994, Human respiratory tract model for radiological protection: a report of a task group of the International Commission on Radiological Protection. ICRP Publication 66, Annals of the ICRP. New York: Pergamon.
14. Karl, A., Henry, F.S., Tsuda, A., 2004, Low Reynolds number viscous flow in an alveolated duct. *J. Biomech. Eng.* 126:420-429.
15. Laine-Pearson, F.E., Hydon, P.E., 2006, Particle transport in a moving corner. *J. Fluid Mech.* 559, 379-390.
16. Laine-Pearson, F.E., Hydon, P.E., 2008, The carousel effect in alveolar models, *ASME J. Biomech. Engng.* 130: 021016.
17. Lichtenberg, A.J., Lieberman, M.A., 1992, Regular and Chaotic Dynamics, 2nd edition, Springer-Verlag.
18. Miki, H., Butler, J.P., Rogers, R.A., Lehr, J., 1993, Geometric hysteresis in pulmonary surface to volume ratio during tidal breathing. *J. Appl. Physiol.* 75:1630-1636.
19. Nicolis, G., Prigogine, I., 1989, Exploring Complexity. W.H. Freeman & Co..
20. Ochs, M., Nyengaard, J.R., Jung, A., Knudsen, L., Voigt, M., Wahlers, T., Richter, J., Gundersen, H.J.G., 2004, The number of alveoli in the human lung. *Am. J. Respir. Crit. Care Med.* 169:120–124.
21. Ottino, J.M., 1989, The Kinematics of Mixing: Stretching, Chaos, and Transport. Cambridge University Press.
22. Pedley, T.J., Schroter, R.C., Sudlow, M.F., 1977, Gas flow and mixing in the airways. In: Lung Biology in Health and Disease. *Bioengineering Aspects of the lung*, ed. J.B.West. New York: Dekker, vol.3, chapt. 3, 163-265.
23. Poincaré, H., 1899, Les méthodes nouvelles de la mécanique célest. Tome III, p. 389, Gauthier-Villars.
24. Tabor, M., 1989, Chaos and Integrability in Nonlinear Dynamics, Wiley.
25. Taylor, G.I., 1960, Low Reynolds Number Flow (16mm film), Newton, MA, Educational Services Inc..
26. Tippe, A., Tsuda, A., 2000, Recirculating flow in an expanding alveolar model: experimental evidence of flow-induced mixing of aerosols in the pulmonary acinus. *J. Aerosol Sci.* 31:979-986.
27. Tsuda, A., Henry, F.S., Butler, J.P., 1995, Chaotic mixing of alveolated duct flow in rhythmically expanding pulmonary acinus. *J. Appl. Physiol.* 79:1055-1063.
28. Tsuda, A., Otani, Y., Butler, J.P., 1999, Acinar flow irreversibility caused by boundary perturbation of reversible alveolar wall motion. *J. Appl. Physiol.* 86:977-984.
29. Tsuda, A., Rogers, R.A., Hydon, P.E., Butler, J.P., 2002, Chaotic mixing deep in the lung. *Proc. Natl. Acad. Sci.* 99:10173-10178.
30. Tsuda, A., Henry, F.S., Butler, J.P., 2008, Gas and Aerosol Mixing in the Acinus. *Respir. Physiol. Neurobiol.* 163(1-3):139-49.
31. Tsuda A, Henry FS, Butler JP., 2011. Particle transport and deposition. In: *Comprehensive Physiology*, Respiratory Physiology Section. J. Fredberg, G. Sieck, and W. Gerthoffer, eds. Amer. Physiol. Soc. (*in review*)
32. Weibel, E.R., 1963, Morphometry of the Human Lung. Springer-Verlag/Academic Press, Heidelberg, New York.
33. Weibel, E.R., 1986, Functional morphology of lung parenchyma. In *Handbook of Physiology*, The Respiratory System (ed. A. P. Fishman), Sect. 3, vol III, Chap. 8, pp. 89-111. Bethesda, MD, Am. Physiol. Soc.
34. Wiggins, S., 1992, Chaotic Transport in Dynamical Systems. Springer-Verlag, New York.
FIGURE LEGENDS
Fig. 1: Schematic of the recirculating alveolar flow pattern calculated in an asymmetric alveolar duct model, which is driven by flow past the alveolar entrance [modified from Tsuda et al., 1995].
Fig. 2: Nested tori; the minor circles \((l_1, \theta_1)\) represent different alveolar recirculation orbits and \(\theta_2\) is the phase in the breathing cycle, whose period is \(T\).
Fig. 3: The torus surface; *Left*: an example of a particle path on a torus; *Right*: the minor and major circles that are used to construct a torus surface.
Fig. 4: Rational orbit with \(p = 2\) and \(q = 3\) (Middle, radius is \(l_B\)) and two irrational orbits (Top and Bottom, radii are \(l_A\) and \(l_C\) respectively); \(l_A > l_B > l_C\).
Fig. 5: Two Poincaré sections at \(\theta_2 = 0\); *Left*: a cross-section of three unperturbed tori (the periodic points – shown as red dots – on the rational torus – shown as light gray-blue circle – denote where a particle’s trajectory has passed in this plane); *Right*: after applying the perturbation the rational torus (light gray-blue circle in left-hand figure) is replaced by a new structure – a very simple schematic of this structure is illustrated by a cross-section of three blue circles.
Fig. 6: *Top*: the three tori of Fig. 5 before perturbation (we denote the red ones as irrational and the grey one as rational) with cross-section; *Middle*: the three tori after perturbation (the gray torus has been replaced by a blue tube-like object that winds around the inner red torus but is encased by the outer red torus) with cross-section; *Bottom*: stripping away the outer torus shows the tube-like object.
Fig. 7: *Top*: five tori before perturbation (we denote the green, red and yellow tori as irrational and the purple and blue tori as rational) with cross-section; *Middle*: the five tori after perturbation (the purple and blue tubes replace the tori) with cross-section; *Bottom Left*: stripping away the outer torus shows the tube-like objects; *Bottom Right*: full view of the purple tube wound around the red torus.
Fig. 8: *Left*: the direction of closed curves – solid outer and inner circles are from irrational tori (IT) and the dotted circle comes from a rational torus; *Right*: in between the circles that surround elliptic fixed points, other points must exist to balance the direction of movement (of particles) – the points lying at the center of the crosses are hyperbolic fixed points.
Fig. 9: This is the interaction of stable and unstable curves.
Fig. 10: These are the possible scenarios for integrable Hamiltonian systems – curves with arrows pointing towards $H$ are stable, those pointing out are unstable; *Left*: heteroclinic orbit (or heteroclinic connection); *Middle*: homoclinic orbit (or homoclinic connection); *Right*: the curves lead off to infinity.
Fig. 11: the crosses denote hyperbolic points whereas the groups of small concentric circles are each centered on an elliptic point (it is customary to describe each small circle group as an ‘island’). This illustration shows the self-similarity of the perturbed system: zooming into an island shows that it is made up of regular curves, islands (appearing in a neighbourhood of elliptic points) and intermingled with chaos (originating from around the hyperbolic points) but on a smaller scale. The zooming in can be repeated for the islands on this smaller scale too. In principle, this zooming into islands can be done on all scales.
Fig. 12: Poincaré sections of particle transport; each color represents a different trajectory. *Left*: Stokes flow in a cavity – no perturbation present and seven particle paths shown. *Right*: The addition of a perturbation by wall motion creates islands in a sea of chaos; eight more particle paths have been added to the original seven for further detail. Similar figures can be seen in Laine-Pearson & Hydon (2006).
FOOTNOTES
1. Re = UL/v, where U and L are (respectively) a characteristic velocity and length scale for the flow and v is the kinematic viscosity of the alveolar gas. Typically, Re < 1 in alveoli; consequently, the convective inertia of the gas produces only a small perturbation to Stokes (zero Re) flow.
2. It does not matter that inspiration and expiration are not necessarily of the same duration. What is important is that the closed trajectories exist and that breathing is (roughly) periodic in time.
3. A rational number is a number that can be expressed as a fraction p/q where p and q are integers and q is positive. An irrational number is a number that cannot be expressed as a fraction p/q for any integer p, q. Irrational numbers have decimal expansions that neither terminate nor become periodic.
4. These persistent tori are guaranteed by KAM (Kolmogorov-Arnol’d-Moser) Theory (Tabor, 1989; Lichtenberg & Lieberman, 1992) and its extensions, provided that the perturbation is sufficiently small. Typically, for alveoli, the perturbation is small enough (Laine-Pearson & Hydon, 2006; Henry, Laine-Pearson, & Tsuda, 2009).
5. For a strict definition of this type of stability, see page 101 of Ottino (1989).
6. These points, and the elliptic points, are guaranteed by the Poincaré-Birkhoff Fixed-Point Theorem (Tabor, 1989; Lichtenberg & Lieberman, 1992).
7. This is called a ‘heteroclinic orbit’ or ‘heteroclinic connection’; see Fig. 10.
8. Another possibility would be that the S and U from the same point connects back to itself (it creates a loop). This is called a ‘homoclinic orbit’ or ‘homoclinic connection’. However, again, this is a rather special case, and only occurs in integrable systems, thus should be disregarded. The third possibility
could be that the $S$ and $U$ do not connect to anything – they extend to infinity. This last possibility also has to be disregarded for periodic systems such as ours. See Fig. 10 for illustrations.
9. Loosely speaking, the term ‘integrable’ implies that a Hamiltonian system is solvable in principle; however, it does not guarantee that the calculations will be manageable! Classical integrable systems exhibit regular motion, whereas nonintegrable systems have chaotic motion. Therefore integrability is an intrinsic property and not just a matter of whether a system can be explicitly integrated in exact form.
10. We are fully aware of the fact that a real aerosol particle is subject to stochastic bombardment by neighboring gas molecules (e.g. Brownian motion), which gives rise to diffusion. The closer two particles’ trajectories come to each other, the more rapidly will diffusion blur their independent existence. Therefore, a structure like Fig 9h is not likely to be seen in the real alveoli. However, with Fig. 9h, we are showing the underlying flow phenomena which one needs to consider when dealing with diffusive particles. The weaker the diffusion is, the longer is the time during which the underlying flow structure will be visible.
11. See page 140 of Ottino (1989) for more details. Our explanation is simplified for clarity; a more complete analysis of transport mechanisms involving lobes can be found in Horner et al. (2002) and Wiggins (1992).
12. It is called a ‘Smale horseshoe’.
13. This is due to KAM Theory (Tabor, 1989; Lichtenberg & Lieberman, 1992).
14. This is due to the Poincaré-Birkhoff Fixed-Point Theorem (Tabor, 1989).
15. This is typically described as ‘Hamiltonian chaos’.
Fig. 1: Schematic of the recirculating alveolar flow pattern calculated in an asymmetric alveolar duct model, which is driven by flow past the alveolar entrance [modified from Tsuda et al., 1995].
Fig. 2: Nested tori; the minor circles ($l_1, \theta_1$) represent different alveolar recirculation orbits and $\theta_2$ is the phase in the breathing cycle, whose period is $T$.
Fig. 3: The torus surface; *Left*: an example of a particle path on a torus; *Right*: the minor and major circles that are used to construct a torus surface.
Fig. 4: Rational orbit with $p = 2$ and $q = 3$ (Middle, radius is $l_B$) and two irrational orbits (Top and Bottom, radii are $l_A$ and $l_C$ respectively); $l_A > l_B > l_C$.
Fig. 5: Two Poincaré sections at $\theta_2 = 0$; *Left*: a cross-section of three unperturbed tori (the periodic points – shown as red dots – on the rational torus – shown as gray thin-line circle – denote where a particle’s trajectory has passed in this plane); *Right*: after applying the perturbation the rational torus (gray thin-line circle in left-hand figure) is replaced by a new structure – a very simple schematic of this structure is illustrated by a cross-section of three blue small circles.
Fig. 6: Top: the three tori of Fig. 5 before perturbation [we denote the red (outer and inner) ones as irrational and the gray (middle thin) one as rational] with cross-section; Middle: the three tori after perturbation (the gray torus has been replaced by a blue tube-like object that winds around the inner red torus but is encased by the outer red torus) with cross-section; Bottom: stripping away the outer torus shows the tube-like object.
Fig. 7: Top: five tori before perturbation (we denote the green, red and yellow tori as irrational and the purple and blue tori as rational) with cross-section; Middle: the five tori after perturbation (the purple and blue tubes replace the tori) with cross-section; Bottom Left: stripping away the outer torus shows the tube-like objects; Bottom Right: full view of the purple tube wound around the red torus.
Fig. 8: *Left*: the direction of closed curves – solid outer and inner circles are from irrational tori (IT) and the dotted circle comes from a rational torus; *Right*: in between the circles that surround elliptic fixed points, other points must exist to balance the direction of movement (of particles) – the points lying at the center of the crosses are hyperbolic fixed points.
Fig. 9: This is the interaction of stable and unstable curves.
Fig. 10: These are the possible scenarios for integrable Hamiltonian systems – curves with arrows pointing towards $H$ are stable, those pointing out are unstable; *Left*: heteroclinic orbit (or heteroclinic connection); *Middle*: homoclinic orbit (or homoclinic connection); *Right*: the curves lead off to infinity.
Fig. 11: the crosses denote hyperbolic points whereas the groups of small concentric circles are each centered on an elliptic point (it is customary to describe each small circle group as an ‘island’). This illustration shows the self-similarity of the perturbed system: zooming into an island shows that it is made up of regular curves, islands (appearing in a neighbourhood of elliptic points) and intermingled with chaos (originating from around the hyperbolic points) but on a smaller scale. The zooming in can be repeated for the islands on this smaller scale too. In principle, this zooming into islands can be done on all scales.
Fig. 12: Poincaré sections of particle transport; each color represents a different trajectory. *Left:* Stokes flow in a cavity – no perturbation present and seven particle paths shown. *Right:* The addition of a perturbation by wall motion creates islands in a sea of chaos; eight more particle paths have been added to the original seven for further detail. Similar figures can be seen in Laine-Pearson & Hydon (2006).
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Preliminary Catalog of Arabic Manuscripts at the Association pour la Sauvegarde de l’Île de Djerba (Houmet Souk, Tunisia)
فهرس تمهيدي للمخطوطات العربية في مكتبة جمعية صيانة جزيرة جربة (حومة السوق، الجمهورية التونسية)
Paul M. Love, Jr
Al Akhawayn University*
***
Introduction
This a preliminary catalog of the Arabic manuscripts held at the *Association pour la Sauvegarde de l’Île de Djerba* (ASIDJ) on the island of Djerba, Tunisia. These manuscripts (bound volumes and assembled collections of fragments, representing many more titles) are all stored in acid-free boxes or folders. All items are housed in the association’s library in a former *zawiya* in the city of Houmet Souk. The association also has a sizeable collection of family and other documents in manuscript form that are awaiting cataloging—in case you are interested! Many of the manuscripts carry content related to the history of Ibadism (e.g. MS 013) and the history of Djerba (e.g. MS 01). For example, chronicles or legal compendia containing cases of disputes in Djerba, where there has been a sizeable Ibadī population for centuries.
I visited the ASIDJ several times in 2014, 2015, 2017, and 2018. The following descriptions are based on those visits and on digital photographs of the manuscripts provided to me by the ASIDJ (available to anyone who visits via transfer from USB key). The title of the catalog includes the word “preliminary” because I discovered during a visit in the summer 2017 that there is an additional small collection of manuscript fragments that I had not been made aware of previously. There are some notes on those additional manuscripts below [see Part IV] but my hope is that a full catalog will be forthcoming in the future, along with digital images of all the manuscripts. A final note regarding the state of the collection deserves mention. Since my visit in 2015, when I organized the manuscripts and placed them in new archival boxes, the collection has been rearranged a couple of times without any clear sense of order. The new numbers on the boxes do not necessarily correspond to the manuscript numbers. The numbers of the manuscripts below correspond to the original numbers I assigned them in 2015 and which are written on white pieces of paper inside each of the manuscript volumes or fragment collections. The collection needs rearrangement and constant supervision to insure its future conservation, since volumes are currently stored vertically at the bottom of a wooden shelf in the library.
Provenance
The bound manuscripts volumes and accompanying fragments in the association’s collection are donations from families on the island. They are, as is clear from the descriptions below, from a
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* Contact: email@example.com. Please cite this document as: P. Love, “Preliminary Catalog of Arabic Manuscripts at the Association pour la Sauvegarde de l’Île de Djerba (Houmet Souk, Tunisia)” (Catalog published online at http://www.ibadistudies.com, August 2018).
variety of periods and places. To my knowledge, there are no systematic records of donations to the ASIDJ. However, during an interview with the association’s former general director, Farid El Cadi, in the summer 2017, I learned that many of the manuscripts including *Rasaʾil al-Hilātī* were donated to him personally by al-Habib Bilhājj and members of the Būshaddākh family of the town of Fātū. Based on ownership statements and other related materials in the library, some of the manuscripts likely came from the Ibn Taʿarīt family and possibly the al-Shāhid family.
**Acknowledgements**
I owe many thanks to the ASIDJ librarian, Abdelmajid Guichguech and the rest of the ASIDJ staff for their allowing me full access to the collection. Thanks to Farid El Cadi and Said El Barouni for the information they provided on the history of the collection. Any mistakes in transcription are my own.
Part I: Summary Inventory of Cataloged Items
القسم الأول: جرد المخطوطات التي تم فهرسها
***
(1) ASIDJ MS 001 *Risā'il al-Hilātī*
(2) ASIDJ MS 002 [Composite MS]
(3) ASIDJ MS 003 *Sharḥ tufṣāt al-ahkām*
(4) ASIDJ MS 004 *al-Juzu' al-aawwal min al-Shaykh 'Abd al-Bāqī*
(5) ASIDJ MS 005 *al-Juzu' al-thānī min al-Shaykh 'Abd al-Bāqī*
(6) ASIDJ MS 006 *al-Juzu' al-rābī' min al-Shaykh 'Abd al-Bāqī*
(7) ASIDJ MS 007 *Mizān nafīsa 'āliyat al-miḍār*
(8) ASIDJ MS 008 [Commentary on al-Qartajānī's *Minhāj al-bulaghā* (?)]
(9) ASIDJ MS 009 [Untitled book of *fiqh*]
(10) ASIDJ MS 010 [Composite MS]
(11) ASIDJ MS 011 [Untitled book of *nahū*]
(12) ASIDJ MS 012 [Quran fragment]
(13) ASIDJ MS 013 [Collection of Unbound Fragments: MS013 (1) – MS013 (7)]
Part II: Catalog of Manuscripts¹
القسم الثاني: فهرس المخطوطات
***
(1) *Risā'il al-Hilātī*
**Shelf Mark:** ASIDJ MS 001
**Title:** [None]
**Uniform Title:** رسائل الحيلاتي
**Author [f.i.b]:** سليمان بن أحمد الحيلاتي
**Date of Transcription:** [May-June 1796 and later—see Additional Notes]
**Place of Transcription:** [Djerba—see Copyists]
**Copyist & Transmission:** Different hands, including those of:
سليمان بن الشيخ أحمد الحيلاتي [b e.g. f.18.b]
عمر بن الفقيه أحمد الشماخي [a f.51.a]
**Quires:** Mostly quinions
¹Note that descriptions here attempt to reproduce the original orthography of the manuscripts. With the exception of the transcription of the dotting of the letters *qāf* and *fāʾ*, all orthography has been left as it appears in the manuscripts.
Folios: 185
Page Layout: 19 lines per page
Paper: Multiple supports (all on European paper)
f.1-10 [Machine-made paper]
Watermark: "FP" watermark [ex. f.4&7]
Dimensions: 16 x 45 mm [height is across the fold]
f.11-30
Laid Lines: 9 (V)
Chain Line Spacing: 25 (H)
Watermark: "Tre Lune" [ex. f.14&17]
Dimensions: 78 x 29 mm
Crescents measure (L-S): 9 mm 7 mm 5 mm
DbC: 103 mm
f.31-91 [Machine-made paper, no watermarks]
f.92-185
Laid Lines: 9 (V)
Chain Line Spacing: 28 mm (H)
"Tre Lune" [ex. f.93&98]
Dimensions: 75 x 22 mm [width is across fold] (DbC: 85 mm)
Crescents measure (L-S): 11 mm 9 mm 6 mm
Measurements: 21.5 x 16.5 cm (written area: 16 x 9.5 cm)
Pagination: Arabic numerals in pencil (top margin) and blue ink/pencil
(bottom left of each recto)
Hand(s): Different Maghribi hands
Ink: Dark brown (rubrics in red)
Catchwords: Bottom left of each verso; diagonal slant
Binding/Decoration: 20th(?) century full binding in dark red leather; interiors of boards lined in white paper, which also makes up the flyleaves. Modern link stitch sewing; two sewing stations; white thread.
Top Board: 222 x 162 mm
Bottom Board: 223 x 155 mm
Flap: 223 x 42 mm
Former Owners: [See copyists]
Incipit [f.2.b]: [See additional notes]
Explicit [f.183.b-184.a]: [See additional notes]
Colophon [f.184.a]: [See additional notes]
Condition: Manuscript folios are on different supports and thus in varying states of condition but overall good; some folios show signs of wear and humidity damage, though relatively little evidence of pest damage; many of the quires have been repaired at the fold with thin strips of white paper. Binding is in excellent condition, with the only sign of damage on the interior of the top board where the joint between the board and the flyleaf has torn.
Additional Notes: Much of the MS appears to have all been copied in the hand of ‘Umar b. Ahmad al-Shammakhī [signed colophons on: f.51.a & f.87.b & f.163.b]. The date of transcription above corresponds to the dates in later texts. An earlier text is dated 1099 / 1687-88 but it appears from the colophon that this is the date of the exemplar, especially since it notes it is in the hand of Sulāyman al-Hilātī. Since the first few quires appear to be on machine-made paper, this first text is most certainly not from the 17th century.
References: M. Gouja, ed., ‘Ulamā’ Jarba: al-musammā rasā’il al-shaykh Sulaymān b. Ahmad al-Hilātī al-Jarbi (Beirut, 1998).
(2) Composite Manuscript
Shelf Mark: ASIDJ MS 002
Title: [Multiple—See Additional Notes]
Uniform Title: [N/A]
Author: [Multiple—See Additional Notes]
Date of Transcription: [late-18th to early-19th c.?—See Additional notes]
Place of Transcription: [Djerba?]
Copyist & Transmission: [Written below ownership statement on f.2.a:] كاتب الخط علي بن الحاج سالم المقدم
Quires: Mostly quinions
Folios: 130
Page Layout: 22 lines per page
Paper: European watermarked paper; Chain Lines (horizontal) 28 mm; Laid Lines (vertical) 9/cm; “Tre Lune” watermark [f.4&9] 88 x 26 mm; (DbC: 95); Crescents measure (L-S): 9 mm, 9 mm, 6 mm
Measurements: 21 x 15.5 cm
Pagination: [none]
Hand(s): Multiple Maghribi hands
Ink: [Varies]
Catchwords: [Varies]
Binding/Decoration: Partial leather binding with repairs; the exteriors of the boards and flap are covered in blue and white decorative paper; interiors of boards lined in yellow paper and the joints of the boards and the fore edge flap have been reinforced with the same cloth/tape material used to repair the outer
edges of the boards; Link stitch; 2 sewing stations; endbands in thick white thread.
Top Board: 214 x 142 mm
Bottom Board: 216 x 149 mm
Envelope Flap: 213 x 67 mm
Former Owners [f.2.a]:
مالك [كذا] من أملاك الله تعالى يد الفقير إلى مولاه محمد [بن؟] محمد بن أحمد بن الحاج المبين غفور الله له عامين
Incipit [f.2.b]: [See Additional notes]
Explicit [f.130.a]: [See Additional notes]
Colophon: [See Additional notes]
Condition: Text block shows minor signs of pest damage but in overall good condition. Binding is in overall good condition; numerous repairs have been made; the outer edges of the top boards have been relined with a variety of materials; the spine appears to be original to the text block.
Additional Notes: This is a composite manuscript made up of several different texts with different dates of transcription—although the support and copyist could be the same. Marginal notes throughout in a variety of Maghribi hands. The contents are as follows:
المقنع في علم أبي مقرع لمحمد بن سعيد المرغشي: f.17.a - f.2.b (1)
رسالة للشيخ الدردير في علم البيان : f.18.a - f.26.a (2)
شرح ل( اسياخوجي : f.27.b - f.41.b (3)
[dated 27 Rajab 1242]
شرح في أصول الفقه: f.42.a - f.51.b (4)
[dated Ramadān 1202]
تذوير الفكر باحداث الذكر للشيخ محمد الامير المالكي الازهري : f.52.a - f.54.b (5)
(6) f.55.a : [a note]
(7) f.56.a: [Two framed columns meant for poetry (left empty)]
الياقونة الكبيرة تأليف العارف بالله تعالى سيدي احمد بن الشيخ: f.57.b - f.76.a (8)
(9) f.76.b - f.81.b (9)
(10) f.82 a-b [blank]
(11) f.83.a : [basmalah]
تعليق على القصيدة الموسومة بالثردة للفقسطلاني : f.130.a - f.83.b - f.130.a (12)
References: [None]
Shelf Mark: ASIDJ MS 003
Title [f.4.b]: شرح وجيزة على رجز الامام القاضي ابي بكر محمد بن عاصم
Uniform Title: شرح نفحة الأحكام
Author: أبو عبد الله محمد التلودي
Date of Transcription [f.217.a]: أوسط ثاني الريبيعين عام ١٢٧٢ هـ
Place of Transcription: [Djerba?—See colophon]
Copyist & Transmission: [Unknown]
Quires: Mostly quinions
Folios: 218
Page Layout: 23 lines per page
Paper: European Watermarked Paper; Chain Lines (horizontal) 28-29 mm; Laid Lines (vertical) 9/cm; “Tre Lune” watermark [f.5&10]; ~72 x 29 (across fold); DbC: 95 mm; Crescents 10 mm, 9 mm, 6 mm
Measurements: 215 x 155 mm (written area varies)
Pagination: Hindu-Arabic numerals at the top left corner of each recto; Arabic numerals in the bottom left of each recto, written in blue fountain pen ink
Hand(s): Maghribi script
Ink: Black; rubrics in red
Catchwords: Bottom left of each verso; diagonal slant; written in the hand of the copyist
Binding/Decoration: Single piece of brown leather over pasteboards; exterior of boards and flap bear embossed pendant designs; interiors of boards and envelope flap interior are lined with pink, black, and green decorative paper; interior of fore edge flap lined in leather; the flyleaves have flanges that are glued to the interior of the boards over the decorative paper. Link stitch; two sewing stations; no endbands.
Top Board: 217 x 149 mm
Bottom Board: 216 x 148 mm
Envelope Flap: 215 x 63 mm
Former Owners: Colophon [f.217.a] notes that the manuscript was copied
[f.217.b] contains the following ownership statement:
ملك الطيب بن محمد بن أحمد ابن الحاج محمد غفر الله للجميع [لحرومه؟] تبين على الله عليه وسلم اللهه [كذا] عامين عاس
Incipit [f.4.b]:
الحمد لله ... وبعد فهذا شرح وجيزة على رجز الإمام القاضي أبي بكر محمد بن عاصم رحمه الله تعالى قصدت به حل ما يحتاج...
Explicit [f.217.a]:
...اللهم شفع فيما نبينا وسيطنا ومولانا محمد صلى الله عليه وسلم وعلى عاله اجمعين والحمد لله رب العالمين وهو حسي ونعم
Colophon [f.217.a]:
انتهى الشرح المبارك بحمد الله حسن عونه وتوفيقه أوسط ثاني الريشين عام ١٢٧٢ اثنين وسبعين ومائتين والف وكتب للشيخ الإمام أبو العباس أحمد ابن الحاج قرض الله له جميع الحاج وفاء الله من الحرج والاحتياج ورده سالماً غانماً لبلده على رحم اعدائه اهل البغور والاعوجاج
Condition: Text block is in good condition, although signs of pest damage on folios throughout. Binding in overall good condition, with minor signs of pest damage.
Additional Notes: [None]
References: [None]
(4) Al-Juz’ al-awwal min al-Shaykh ‘Abd al-Bāqī
Shelf Mark: ASIDJ MS 004
Title [f.2.a]: الجزء الأول من الشيخ عبد الباقى الزرقاني [كذا]
Uniform Title: شرح على مختصر خليل
Author [f.2.a]: عبد الباقى الزرقاني
Date of Transcription [f.227.b]: Ramadān 1121 AH [November-December 1709 CE]
Place of Transcription: [Unknown?]
Copyist & Transmission [f.227.b]: عبد الله بن محمد السوسي
Quires: quinions
Folios: 228
Page Layout: 35 lines per page
Paper: European watermarked paper; Chain Lines (V): 28-29 mm; Laid Lines (H): 6/cm; “C [G/C?]” countermark [f.7] 43 x 37 mm (DbC: 57 mm); “Tre Lune” [f.3] 137 x 29 mm (DbC: 116 mm); Crescent measure (L-S): ~11 mm, 10 mm, 8 mm
Measurements: 32.5 x 22.5 cm (written area 23 x 14.5 mm)
Pagination: Arabic numerals at top center of each recto; written in pencil
Hand(s): Maghribi script
Ink: Black ink; rubrics in red
Catchwords: Bottom left of each verso; diagonal slant; written in black ink in the hand of the copyist
Binding/Decoration: Single piece of brown leather over pasteboards; exterior of boards have embossed pendant and border designs; interiors of boards and flap interior lined with white paper, which also makes up the flyleaves; No end bands.
Top Board: 320 x 218 mm
Bottom Board: 320 x 216 mm
Envelope Flap: 322 x 81 mm
Incipit [f.1.b]:
الحمد لله... وبعد فهذا شرح مختصر العلامة الشهير في [؟] خليل بن إسحاق بخصته من شرح شيخنا شيخ الإسلام العلامة المعمر علي الأجموري إلى الإرشاد...
Explicit [f.227.b]:
لكن سيأتي في الحماد كوالدين في فرض كفابة وهو يفيد الميع في التطوع لا في حجة الإسلام والله تعالى أعلم
Colophon [f.227,b]:
تم الجزء الأول بحمد الله وعونه وحسن توفيقه وحسنا الله ونعم الوكيل ولا حول ولا قوة إلا بالله تعالى العظيم وصلى الله على سيدنا محمد وعلى عاله وصحبه وسلم تسليما كثيرا دائما ابدا إلى يوم الدين أمين يا رب العالمين على يد عبد المذنب الراجحي عفو مولاه عبد الله بن محمد السوسي...[/] وكان القراء منه بشهر الله المعظم رمضان عام أحد وعشرين ومائة والف
Condition: Text block suffers from significant pest damage; many of the folios have been repaired using a newer white paper, including the fold of many of the quires. Binding in overall good condition; the boards are slightly warped from humidity; exterior of boards show minor signs of pest damage.
Additional Notes: [f.227.b - f.228.b] several different 'mas'ala' notes in different Maghribi hands]
References: 'Abd al-Bāqī b. Yūsuf b. Ahmad b. Muhammad al-Zurqānī al-Miṣrī, Sharḥ al-Zurqānī 'alā mukhtaṣir Sādī Khalīl...(8 vols., Dār al-kutub al-ʿilmīyya, 2002)
(5) Al-Juzʾ al-thānī min al-Shaykh ʿAbd al-Bāqī
Shelf Mark: ASIDJ MS 005
Title [f.2.a]:
الجزء الثاني من الشيخ عبد الباقی:
Uniform Title:
شرح الزرقاني على مختصر الخليل
Author:
عبد الباقی الزرقایی
Date of Transcription[f.159.b]: Late Rajab 1140
Place of Transcription: [Djerba?]
Copyist & Transmission: [Unknown]
Quires: Mostly quinions
Folios: 193 folios (including f.1&193, which are new flyleaves)
Page Layout: 39 lines per page
Paper: European watermarked paper; Chain Lines (V): 29-30 mm; Laid Lines: (H): 7/cm; “Trefoil” countermark with “C” below [f.91] 58 x 19 mm (DbC: 60 mm)
Measurements: 31 x 22 cm (written area 23 x 14 cm)
Pagination: Arabic numerals, written in pencil at the top left margin of each recto; additional Arabic numerals in blue fountain pen ink at the bottom left or center of each recto
Hand(s): Maghribi script
Ink: Black, rubrics in red
Catchwords: Bottom left of each verso; diagonal slant; written in the hand of the copyist
Binding/Decoration: Brown leather binding with embossed pendant designs; interiors of boards and interior of envelope flap lined in white paper.
Top Board: 322 x 230 mm
Bottom Board: 321 x 228 mm
Envelope Flap: 324 x 92 mm
Former Owners [f.3.a]:
الحمد لله [؟] هذا الجزء الثاني من شرح عبد الباقی [؟] لمحمد الحاج الممی[؟] من أخيه [في الدين؟] محمد بن [محمد] الممثی وذالك بالشراء الصحيح والشمر المتدفع له وهو عشرة [؟ ست] تونسیة [؟] عام ثلاثة وخمسين ومائة وال ألف من [؟] عامین
Incipit [f.2.b]:
باب الوکاة بمعنى التذکیة...
Explicit [f.159.b]:
...ما وضع [؟] على [؟] أفراد الحیوان والله تعالى اعلم بالصواب والله المرجع وللماب
Colophon [f.159.b]:
Condition: Overall good condition; binding has been repaired using a lighter brown leather and the interior boards have been relined with white paper.
Additional Notes: [None]
References: ‘Abd al-Bāqī b. Yūsuf b. Ahmad b. Muhammad al-Zurqānī al-Miṣrī, *Sharḥ al-Zurqānī ‘alā mukhtaṣir Sūdī Khalīl*...(8 vols., Dār al-kutub al-‘ilmīyya, 2002)
(6) *Al-juz’ al-rābī’ min al-Shaykh ‘Abd al-Bāqī*
Shelf Mark: ASIDJ MS 006
Title [f.1.a]: الجزء الرابع من الشيخ عبد الباقی
Author: عبد الباقی الزرقانی
Date of Transcription: [18th c.?—See MS005]
Place of Transcription: [Unknown]
Copyist & Transmission: [Unknown]
Quires: Quaternions
Folios: 135
Page Layout: 35 lines per page
Paper: European watermarked paper of at least two types:
Support #1
Chain Lines (V): 27-29 mm; Laid Lines (H): 6/cm; “C G” countermark [f.5] 35 x 45 mm (DbC: 50 mm from one side to the edge of the folio); “Tre Lune” [f.10] 78 x 34 mm (DbC: 114 mm) Crescents measure (L=>s): 13 mm, 10 mm, 10 mm
Support #2 [e.g., f.122]
Chain Lines (V): 23-24 mm; Laid Lines (H): 9-10/cm; No immediately visible watermarks
Measurements: 30.5 x 21 cm (written area 24 x 15.5 cm)
Pagination: Arabic numerals in the bottom left of each recto, written in pencil
Hand(s): Maghribi hand(s)
Ink: Brown
Catchwords: Bottom left of each verso; diagonal slant
Binding/Decoration: Reddish-brown full leather binding; significant efforts at repair/restoration in a newer leather; interiors of boards and envelope flap lined in new white paper; no end bands.
Top Board: ~320 x 204 mm [See Condition]
Bottom Board: ~320 x 194 mm [See Condition]
Envelope Flap: 320 x 106 mm
Former Owners [f.2.a]:
ملك من أمالك افتقر [كذا] الفقير الذليل الى مولاه عبده المحتاج محمد بن احمد بن محمد بن الحاج [الضياوي؟]...
(23 ربيع [ثاني؟] ١٢٧٣) (an additional note for the same owner on f.3.a adds the date: ١٢٧٣)
Incipit [f.4.b]:
باب في الاجازة...
Explicit [f.134.a]:
...والله المرجع والمناب وصلى الله على سيدنا محمد وسلم
Colophon [f.134.a]:
كلم حمد لله وحسن عونه على يد العبد الفقير الحفيظ الذليل الراغبي رحمة الرب... عمر بن عبد الله بن عمر بن عبد الله بن عمر الحرم[موى؟] نسبا وممسكا المالكي غفر الله له ولولديه [؟ ؟] وأخر الربيع الأول مولده عليه السلام وعام احدى وعشرين وماائه والف عشوة الخميس صلى الله على سيدنا محمد [واله وصحب؟]
Condition: Significant pest damage but much work toward repair has been done; this included reinforcing all the quires, gluing on additional paper to the edges of damaged folios, and rebinding the entire manuscript; unfortunately, these repairs appear to have warped the top and bottom boards, making it difficult to measure their length with exactitude
Additional Notes: [None]
References: ‘Abd al-Bāqī b. Yūsuf b. Ahmad b. Muhammad al-Zurqānī al-Miṣrī, Sharḥ al-Zurqānī ‘alā mukhtaṣir Sīdī Khalīl...(8 vols., Dār al-kutub al-‘ilmīyya, 2002)
(7) Mizān nafiṣa ‘āliyat al-miqdār
Shelf Mark: ASIDJ MS 007
Title [f.5.a]: ميزان نقيسة عالية المقدار
Uniform Title: ميزان نقيسة عالية المقدار
Author: [عبد الوهاب الشعراوي المصري]
Date of Transcription [f.494.a]: 6 Ramadān 1097 (26 July 1686)
Place of Transcription: [Egypt?]
Copyist & Transmission: f.1.b contains the following note (however, see Colophon below):
كاتب الخط محمد بن الحاج محمد بن احمد بن الحاج قاسم الضياوي والسلام
Quires: Mostly quaternions and quinions
Folios: 498
Page Layout: 21 lines per page; framed in red, blue-grey, and occasional gold border; frontispiece on f.3.b is comprised of those same three colors
Paper: European watermarked paper; Chain Lines (H): 24-29 mm; Laid Lines (V): 9/cm; “Crown, star, crescent(?)” watermark [f.9&10] ~58 x 25 mm [across fold] (DbC: ~51); “Scale in shield with [N?] below” watermark [f.168&170] ~53 x 28 mm [measurements are across fold] (DbC: 52 mm); “Crown, star, crescent(?)” watermark [f.167&172] ~87x61 mm [mark is unclear and I am uncertain of where it begins and ends]
Measurements: 21 x 15.25 cm (written area 15.25 x 10 cm)
Pagination: [beginning on 4.a], Arabic numerals in the top margin of each recto; written in pencil
Hand(s): Naskh script with dotted yā’s & alif maqsūras
Ink: black; rubrics in red
Catchwords: bottom left of each verso
Binding/Decoration: Pasteboards and flap covered in handsome dark-green leather; embossed floral-like designs on the exterior of the top and bottom boards; interior of the boards and envelop flap have been recently re-lined in white paper; evidence of rebinding throughout (new, white threads visible); no endbands
Top Board: 208 x 145 mm
Bottom Board: 206 x 149 mm
Envelope Flap: 208 x 145 mm
Former Owners [f.1.b]:
ملک من أمالك الفقیر إلى الله تعالى محمد بن الحاج محمد بن احمد بن الحاج قاسم الضیاوى فاتح الله عليه عامین... سنة ۱۲۳۲
Incipit [f.5.a]:
الحمدلله الذي جعل... وبعد فهذه ميزان نقيسة علاية المقدار...
Explicit [f.494.a]:
...في أحوال يوم القيامة [كذا] والحمد لله رب العالمين وصلى الله علي سيدنا محمد وعلى آله وصحبه وسلم وحسينا الله ونعم الوكيل ولا حول ولا قوة إلا بالله العلي العظيم
Colophon [f.494.a]:
قال المؤلف رحمه الله تعالى وكان الفراغ من تأليفه سلخ رمضان الممتع قدره سنة ست وسبعين وتسعمائة بمحضر المحروسة على يد كاتبه ومولفه الفقير عبد الوهاب بن احمد بن علي ابن احمد الشعراي الانصاري الاشعرى الشافعي الاحمدي الثلاوي حامدا مصلبا محوقلا مستغفا والحمد لله رب العالمين وصلى الله وسلم علي زين النبيين
[and additional invocation appears below, which ends with]
علي يد كاتبه الفقير الغنائي محبي الدين الشعراي عفنا الله عنه وحده امين بتاريخ يوم السبت السادس شهر رمضان المعظم قدره
١٠٩٧ من الهجرة النبوية المحمدية
Condition: Overall good condition; Evident signs of pest damage in the past but the new binding is very secure and the text is very clear.
Additional Notes: [None]
References: [None]
(8) [Commentary on al-Qarṭajānī’s Minhāj al-bulaghā’(?)]
Shelf Mark: ASIDJ MS 008
Title: [Unknown]
Uniform Title: [Unknown]
Author [f.3.b]: أبو عبد الله محمد بن أحمد بن محمد بن أحمد الشريف الحسني
Date of Transcription [f.278.b]: 8 Jumādā al-ūlā 1106 AH (24 December 1694)
Place of Transcription: [Unknown]
Copyist & Transmission [f.278.b]: عبد السلام بن عبد الوهاب سليم المجلوب
Quires: mostly quaternions
Folios: 280
Page Layout: 22 lines per page
Paper: European watermarked paper; Chain Lines (H): 25–29 mm; Laid Lines (V): /cm: 8; “Cross in oval” watermark [f.7&8] ~51 x 37 [measurement across fold] (DbC: 57 mm); “Hillock” watermark [f.10] 21x18 mm (DbC: 28 mm)
Measurements: 24.5 x 18 cm (written area 17 x 11 cm)
Pagination: Arabic numerals written in the bottom left of each recto
Hand(s): Maghribi script
Ink: Brown-ish black; Rubrics in red
Catchwords: Bottom left of each verso; diagonal slant
Binding/Decoration: An eclectic repair job on what was originally a full brown leather binding with embossed mandorla designs on the exterior of the top and bottom boards; the outer edges of the bottom board have been reinforced with red leather and the exterior of the envelop flap (which has been replaced) is lined in a printed, bright green and white patterned paper; the top board has been repaired with patches in a similar brown leather; brown and white chevron pattern endbands still intact; multiple indications of repairs throughout the textblock, including new white paper slips covering the gap between the textblock and the interior of the boards; all of these point to the book having been rebound after the repairs were made to the cover
Top Board: 244 x 176 mm
Bottom Board: 246 x 170 mm
Envelope Flap: 246 x 72 mm
Former Owners: A few different indications of previous ownership.
[f.2.a has this ownership statement with the name of the owner scratched out. The name would suggest that a former owner was connected to the famous al-Jumni mosque and madrasa in Houmet Souk, Djerba (al-Jumni, 2008)]
هذا ملكُ من أملاك الشيخ أبو حفص عمر بن [محمد؟] الجمّني وفقة الله امين بجاه[؟] سيد المرسلين
[f.3.a bears an illegible ownership stamp and the following ownership statement]
الحمد لله على الله يعتمد مالكه احمد بن ابي عصريه بن احمد بن احمد بن يوسف الغناسي لطف الله به
Incipit [f.3.b]:
قال الشيخ الامام...أبو عبد الله محمد بن أحمد بن محمد الشريف الحسني...أما بعد فأتي لما تأثثت مقوهزة الامام الأوحد أبي الحسن حازم بن محمد بن حسن بن حازم الانصاري القرطاجي الفينها...
Explicit [f.278.b]:
...فأتي استقبل من الزول وأقول نية المؤمن ابلغ من العمل
Colophon [f.278.b]:
انتهى بحمد الله وحسن عونه وصلى الله على سيدنا محمد نبيه وعديه على يد كاتبه لنفسه ثم لمن شاء الله من بعده العبد الجاني على نفسه الخائف من ذنبه الراجي عفو ربه الغارق في بحر الذنوب عبد السلام بن عبد الوهاب سليل المجذوب ختم الله له بالسعادة ومن عليه بالحسنى وزياة وتجاوز عنه يوم القبعة بجاه سيدنا محمد المضلل [كذا] بالعمامة صلى الله عليه وعلى عاله وشرف وحرم ومجد وعظم [.] وتاريخ يوم الأحد الثامن من جمادى الأولى سنة ستومهنة [كذا] والف بعد الهجرة النبوية
Condition: Evidence of pest and humidity damage throughout; text is legible; see Binding/Decoration above for notes on repairs.
Additional Notes: Stored inside the textblock is a small piece of cardboard with “tamma taşwiruhu (١٠٥٨)” written on one side. The other side, however, is the logo of the Sultan Qaboos University (Muscat, Oman). This confirms oral accounts from people in Jerba who claimed that a SQU team and took these photographs, along with photographs from other libraries on the island.
References: Muhammad al-Hādi al-Jumni, *Ma’lam wā-thākira: madrasat Sīdī Ibrāhīm al-Jumni* (Tunis, 2008)
(9) [Untitled work of *fiqh*]²
Shelf Mark: ASIDJ MS 009
Title : [None]
Uniform Title: [Unknown]
Author: [Unknown]
Date of Transcription: [late 17th-18th c.?—See watermarks ]
Place of Transcription: [Unknown]
Copyist & Transmission: [Mashriqi origin, Jerban ownership?; Compare Hand with Former Owners]
Quires: Mostly quaternions
Folios: 311
Page Layout: 25 lines per page
Paper: European watermarked paper of at least two types:
Support#1
Chain Lines (H): 29-30 mm; Laid Lines (V): 8/cm; “Crown, Star, Crescent” watermark #1 [f.17&20] 74 x 44mm, (DbC: 55 mm); “Tre Lune” watermark [f.24&31] 71 x ~30 mm [width across fold], (DbC: 109 mm) Crescents measure (L=>s): 6 mm, 7 mm, 5 mm; “Crown, Star, Crescent” watermark #2 [f.27&28] ~70 x 52 mm [length across fold] (DbC: 81 mm); “Trefoil with A G below” countermark [f.30] 52 x 40 mm (DbC: 52 mm).
Support#2
Chain Lines (H): 25-28 mm; Laid Lines (V): 8/cm; “Tre Lune” watermark [f.303&309] 80 x ~36 mm [width across fold] (DbC: 112 mm) Crescents measure (L=>s): 12[?] mm, 8 mm, 7 mm (NB: the largest crescent’s width is unclear due to pest damage); “C G” countermark [f.308] 52 x 37 mm (DbC: 60 => to edge of folio)
Measurements: 20.5 x 15.5 cm (written area: 16 x 9.5 cm)
Pagination: [None]
Hand(s): Naskh
Ink: Black; Rubrics in red
Catchwords: Bottom left of each verso; horizontal
---
² My notes and descriptions, including those in the catalog of watermarks below, are based on the original order of the folios in this volume. On my final visit to verify my notes in August 2018, I discovered that the first two quires of the volume appear to have been rearranged. I tried to modify my descriptions to correspond to the current arrangement of the manuscript folios. Those interested in verifying the descriptions and locations of watermarks, in particular, should do so in person if possible.
Binding/Decoration: Light brown full leather binding with embossed mandorla designs; flap missing; interiors of boards lined in white paper; traces of white endbands.
Top Board: 208 x 136 mm
Bottom Board: 206 x ~145 mm [flap traces remain]
Envelope Flap: [flap missing]
Former Owners [f.312.a]:
كتب معيبد بن تعرت٣ [كذا] عمر الله له و[سلم؟] ولده [كذا]... سنة ١٣٤٥
Incipit [f.1.a]:
من عقده وان لم ميم فلها صداق المثل ولذلك لا يجوز...
Explicit [f.310.b]:
علي اخوانه حافظا للسانه محترزا من اخوانه فا؟
Colophon: [None]
Condition: Text block is separate from the binding cover but quires are intact; the text block is missing the beginning and end of the book; text is clear and legible.
Additional Notes: Pasteboards are made up of older manuscripts, now exposed because the flap is missing.
References: [None]
(١٠) [Composite Manuscript]
Shelf Mark: ASIDJ MS 010
Title: [f.2.a] مجموع به الشيخ عبد الرّبّيّ على الناصر مع حاشية
Uniform Title: [Multiple]
Author: [Multiple]
Date of Transcription: [Multiple]
Place of Transcription: [Multiple]
Copyist & Transmission: [Multiple]
Quires: some quinions, but irregular
Folios: 180
Page Layout: [varies]
Paper: European watermarked paper of at least two types:
__________________________
٣ الأرجح أن المقصود "تعاريف"
Support #1 (e.g. f.2-14); Chain Lines (H): 29-33 mm; Laid Lines (V): 7/cm; Mirrored “C G”[?]
watermark [f.6] ~32 x 30 (DbC: 60mm); [Chalice?] watermark [f.5&12] 40 x 12 mm (DbC: 28 mm).
Measurements for f.12 portion of watermark only.
Support #2 (e.g. f.18-25); Chain Lines (H): 29-32 mm; Laid Lines (V): 8; “Tre Lune” (f.17&23) ~95 x
?~27 mm [to the fold] (only half visible due to binding; Crescents measure (L-S): 8mm, 9mm,
6mm; The same mark with approximately the same measurements is found throughout the
remainder of the manuscript
Measurements: 22 x 16 cm
Pagination: Arabic numerals on the top left of each verso, written in pencil (beginning
f.2.a); Arabic numerals in the bottom left of each verso, written in blue
fountain pen ink [beginning f.4.a]
Hand(s): Multiple Maghribi hands
Ink: Multiple, but mostly brown
Catchwords: Bottom left of each verso
Binding/Decoration: Recent dark brown leather binding over cardboard (see also: Condition).
Top Board: 223 x 158 mm
Bottom Board: 223 x 153 mm
Envelope Flap: 224 x 48 mm
Former Owners: [Unknown]
Incipit [f.2.b]:
الحمد لله هذا تفسير الحروف المعجمة...
Explicit [f.179.a]:
...فانتعجب مستحلل في حقه تعالى انتهى
Colophon: [Multiple, but the final colophon reads f.179.a reads:]
والحمد لله رب العالمين كملت الحاشية السبارة نسخة على يد عبد القدير الودي غرس الله بن أبي السرور الشريف المساكني
غفر الله له ولوالديه ولمسايخه ولاخوانه وجميع أحبته والمسلمين اجمعين عامين في أول ذي القعدة أي أول يوم منه عام ثلاثة
وثمانين ومايه والفق كتبها لنفسه ثم لمن شاء الله من بعده وكان الكتاب [كذا] على نسخة قرها الشيخ المولف لهؤلاء الحاشية
كان الله لنا ولله الدارين عامين [حيا؟] سيئنا ومولاتنا محمد صلى الله عليه وسلم الصادق الأمين عامين عامين عامين
Condition: Manuscript is in overall good condition and someone has recently taken
great efforts to repair it. Many of the folios have been reinforced or
patched with paper and the manuscript was entirely rebound after the
repairs.
Additional Notes: [None]
(11) [Untitled Book of *nahū*]
**Shelf Mark:** ASIDJ MS 011
**Title** [f.1.a] كتاب نحوی : (& see Colophon)
**Uniform Title:** [Unknown]
**Author:** [Unknown]
**Date of Transcription** [f.77.b]: 4 Ramadan 1099 (or 1044) / [2 July 1688]
**Place of Transcription:** [Unknown]
**Copyist & Transmission** [f.77.b]: عمر بن إبراهيم بن سعيد بن أبي زيد
**Quires:** Mostly quinions
**Folios:** 281 [III + 27V + IV]
**Page Layout:** 23 lines per page
**Paper:** European watermarked paper; Chain lines (H): 29-31 mm; Lain Lines (V): 8/cm; “Crown, star, crescent” watermark [f.4&13] 55 x 52 mm (DbC: 60 mm); “Trefoil with “b V” countermark [f.7] 42 x 46 mm (DbC: 59 mm to the edge of folio); “Trefoil with b T” [f.9] 48 x 34 mm (DbC: 53 mm to the edge of folio)
**Measurements:** 20 x 15 cm (written area: 16 x 10.5 cm)
**Pagination:** Quires numbered in Arabic-Hindu numerals beginning f.4.a
**Hand(s):** Maghribi script
**Ink:** Brownish-black; rubrics in red
**Catchwords:** Bottom left of each verso; diagonal slant
**Binding/Decoration:** Brown leather binding over pasteboards with flap; interiors lined in white paper; white mull of spine exposed, showing that the endbands (white primary, red secondary) were sewn directly into the mull;
**Top Board:** 203 x 143 mm
**Bottom Board:** 204 x 147 mm
**Envelope Flap:** 204 x 78 mm
**Former Owners:** The colophon [f.77.b] notes that the copyist produced the manuscript:
لعمه ابي الريبع [يحيى؟] سليمان بن عبد الله بن ابي زيد
**Incipit** [f.4.a]:
قوله التأكيد تابع يقرر امر المتبع في النسبة والشمول...
**Explicit** [f. 77.b]:
...اذ لم يكن مانع [؟] ثابتة أيضا مع عروض الحذف
**Colophon** [f. 77.b]:
هذا آخر شرح المقدمة والحمد لله على افضاله وانعامه بتفوق اكماله وصلواته على محمد وكرام الله وقد تم تمامه وختم اختتامه وحسينا الله ونعم الوكيل ونعم المولى ونعم العظيم ولا حول ولا قوة إلا بالله العلي العظيم وسلم تسليما كثيرا وكان الفراغ من كتابة هذه النسخة المباركة رابع يوم من شهر رمضان سنة 99 وال ألف على يد الفقير الحقيب المعترف بالذنب والتقضيب [كندا] الراجي عفو ربه القدير عمر بن ابراهيم بن سعيد بن ابي زيد نشخته لعمه ابي الربيع [يحجي؟] سليمان بن عبد الله بن ابي زيد رحمهم الله وغفر لهم ولجميع المسلمين والمسلمات
Condition: Textblock shows signs of pest damage but the text is legible; the textblock is separated from the spine, exposing the mull lining into which the primary endbands were originally sewn.
Additional Notes: There are a couple of notes on f.1.a that indicate former ownership, including one dated 1424 AH.
References: [None]
(12) [Qur'an Fragment]
Shelf Mark: ASIDJ MS 012
Title: [Qur'an fragment]
Uniform Title: [Qur'an]
Author: [N/A]
Date of Transcription: [Unknown]
Place of Transcription: [Unknown]
Copyist & Transmission: [Unknown]
Quires: mostly quinions
Folios: 43
Page Layout: 7 lines per page; red and brown border surrounds the text
Paper: European watermarked paper; Chain Lines (H): 28-29 mm; Laid Lines (V): 8-9/cm; “Tre Lune” watermark (f.5&8) 87 x 37 mm (DbC: 113 mm); Crescents measure (L-S): 8 mm, 7 mm, 6 mm
Measurements: 21.5 x 15.75 cm [see notes]
Pagination: [None]
Hand(s): Andalusi script
Ink: Brown; (rubrics in red, tashkil in red)
Catchwords: [None]
Binding/Decoration: [None—stored in grey acid-free folder]
Former Owners [f.43.b]:
مالكه احمد بن بوسلامه بن عمر ابي شداخ
Incipit [f.1.b]: [ولا ينف]قوتها في سبيل الله فبشرهم بعذاب المهيم...
Explicit: [f.43.a]:
وعينهم [تفيض من الدم] حزنا الا يجروا ما ي[جدوا ما ينفقون]
Colophon: [None]
Condition: This manuscript is a fragment in very poor condition, with humidity having led to the disintegration of the upper half.
Additional Notes: [None]
References: Cf. Qur’an: Sūrat al-tawba
(13) Composite Manuscript
Shelf Mark: ASIDJ MS 013 [1]
Title [on paper wrapper]: [من شرح النوويه]
Uniform Title: شرح النوويه
Author [on paper wrapper]: امحمد بن عمر تلويين الفصيحي
Date of Transcription: [19th c.?—See Watermarks]
Place of Transcription: [Unknown]
Copyist & Transmission: [Unknown]
Quires: Quaternions
Folios: 27 folios
Page Layout: 19 lines per page
Paper: European watermarked paper; Chain Lines (H): 27-30 mm; Laid Lines (V): 6-7/cm; “Tre Lune” watermark [f.4&5] 93 x ~41 mm (across fold) (DbC: 143 mm)
Crescents measure (L->s) 20mm, 20(?)mm, 14 mm; “V H(?)” countermark [f.1] 39 x 27 mm (DbC: 57 mm)
Measurements: 23 x 16.5 cm
Pagination: [None]
Hand(s): Maghribi hand
Ink: Black; rubrics in red
Catchwords: Bottom left of each verso; diagonal slant
Binding/Decoration: [folios are wrapped in white paper and group with other fragments, all of which are stored in acid-free folder]
Former Owners:
Incipit [f.1.b]: مكتوب وانه عرض لا جسم...
Explicit [f.27.b]:
السلام على الاخوة في الدين من حقوق المسلمين بعضهم على بعض
Colophon: None
Condition: The fragment is in good condition with few signs of pest or humidity damage.
Additional Notes: The author is identified by the wrapper as Amuhammad b. 'Umar Talwīn al-Qaṣbī, who is presumably the famous author of commentaries known as “al-Muḥashshi” (d.1088/1677)
References: Cf. Custers, al-Ibadīyya, Vol.2, p.367.
Shelf Mark: ASIDJ MS 013 [2]
Title [from paper wrapper]: من القنطور للمحيطلي أيضا
Uniform Title: كتاب قنطور الخيرات
Author: أبو طاهر إسماعيل بن موسى المحيطلي
Date of Transcription: 19th c.?—See watermarks
Place of Transcription: Unknown
Copyist & Transmission: Unknown
Quires: quires not intact
Folios: 97
Page Layout: 25 lines per page
Paper: European watermarked paper; Chain Lines (H): 27-29 mm; Laid Lines (V): 12/cm; "Tre Lune" watermark (f.1&2) 99 x 37 mm (DbC: 142 mm); Crescents measure (L-S): 10mm, 10 mm, 7 mm; "G M" countermark" (f.23: cut off at the edge of folio) ~10 [to edge] x 50 mm (DbC: 82 mm)
Measurements: 21.5 x 16 cm
Pagination: None
Hand(s): Maghribi script
Ink: Brownish-black; rubrics in red.
Catchwords: bottom left of each verso; diagonal slant
Binding/Decoration: Not bound; stored with similar fragments in a grey acid-free cardboard wrapper
Former Owners: Unknown
Incipit [f.1.a]:
تبلغكم الآخرة ويوري ان رجلا نام الدنيا عند علي بن ابي طالب فقال علي...
Explicit [f.97.b]:
Colophon: [None]
Condition: The fragment is in overall good condition with minor signs of humidity damage; text is legible.
Additional Notes: The paper wrapper labeled the author (*mu'allif*) as Amuḥammad al-Qaṣbī, but the title on the wrapper would suggest that the author is Ismaʿīl al-Jaytālī (see Author). Comparison with other copies or the printed edition will be necessary to confirm the text's contents.
References: See Custers, *al-Ibāḍiyya*, V.2, pp.265-267.
Shelf Mark: ASIDJ MS 013 [3]
Title [from paper wrapper]: شرح النونية للمصمي او الشمسي
Uniform Title: شرح النونية
Author: [See additional notes]
Date of Transcription: [19th c.?—See watermarks]
Place of Transcription: [Unknown]
Copyist & Transmission: [Unknown]
Quires: for those still intact, quaternions
Folios: 86
Page Layout: 25 lines per page
Paper: European watermarked paper; Chain Lines (H): 25-27 mm; Laid Lines (V): 7; “F A” with crest(?) above watermark (f.3&4) ~79 x 49 mm (DbC52 mm); “Tre Lune” watermark [+ illegible name] (f.13&14) 61 x 112 mm (DbC: 154mm)
Measurements: 23.5 x 17 cm
Pagination: [None]
Hand(s): Maghribi script
Ink: Brown; rubrics in red
Catchwords: Bottom left of each verso; diagonal slant; sometimes in red
Binding/Decoration: [folios are wrapped in white paper and group with other fragments, all of which are stored in acid-free folder]
Former Owners: [Unknown]
Incipit [f.1.a]:
وان قوله [؟] كان من الح تتميم البيت...
Explicit [f.86.b]:
في جندو النخل وسبية كما في دخلت [ا/امرأة]
Colophon: [None]
Condition: Manuscript is in fair condition but the folios are out of order; several bifolios are attached with tape and the manuscript shows minor signs of humidity damage.
Additional Notes: Quires are out of order, which is why the explicit is not included; the paper wrapper identifies the author (mu’allif) as Amuhammad al-Qaṣbī but another hand identified the text as authored by others. Comparison with other copies or the printed edition will be necessary to confirm the text’s contents.
References: [None]
Shelf Mark: ASIDJ MS 013 [4]
Title [from paper wrapper]: كتاب مشوش
Uniform Title: [Composite manuscript including, inter alia, Syar al-Shammākhu]
Author: [Multiple]
Date of Transcription: [17th c.?—See watermarks]
Place of Transcription: [Unknown]
Copyist & Transmission: [Unknown]
Quires: [Mixed]
Folios: 97
Page Layout: [Mixed]
Paper:
[Multiple supports—there are many more and what is below is only a representative sample]
Support #1 [e.g. f.1-4]
Chain Lines (H): 26-30 mm; Laid Lines (V): 7/cm; No visible watermarks
Support #2 [e.g. f.5-10]
Chain Lines (H): 26-27 mm; Laid Lines (V): 7/cm; “B” countermark (f.5) 25 x 14 mm (DbC: 26mm); “Tre Lune” watermark (f.7&13—NB : quires in odd order) 99 x 33 mm (DbC: 108 mm) Crescents measure (L-S): 15 mm, 9 mm, 10 mm
Support #3 [e.g. f.81]
Chain Lines (H): 25-26 mm; Laid Lines (V): 9/cm; “Crest(?) with ‘P G’ inside” watermark (only top visible, bottom half folio missing) 60 x 45 mm (measurements only of visible area); (DbC: 52 mm)
Support #4 [e.g. f.85]
Chain Lines (H): 27-28 mm; Laid Lines (V): 10/cm; “Tre Lune” (f.86) 60 x 25 mm (visible area only) (DbC: 83mm); “C.A.C.V.” watermark [(f.85) 14 x 80 mm (DbC: 110 mm)
Measurements: ~22.5 x 16 cm [varies]
Pagination: [None]
Hand(s): [Multiple]
Ink: [Multiple]
Catchwords: [Varies]
Binding/Decoration: [folios are wrapped in white paper and group with other fragments, all of which are stored in acid-free folder]
Former Owners: [Unknown]
Condition: The text range in from faded and damaged to point of illegibility to good
Additional Notes: The paper wrapper identifies the author (mu’allif) as Amuhammad al-Qaṣbi but clearly there are multiple. Comparison with other copies or the printed edition will be necessary to confirm the text’s contents.
References: [None]
Shelf Mark: ASIDJ MS 013 [5]
Title [from the paper wrapper]: شنات
Uniform Title: [Multiple fragments, including one labeled as the منظومة الحادوية]
Author: [Multiple]
Date of Transcription: [Unknown]
Place of Transcription: [Unknown]
Copyist & Transmission: [Unknown]
Quires: N/A
Folios: 24 folios [20 folios + 4 fragments]
Page Layout: Varies
Paper: Multiple supports (see below)
Support #1 [10 folios measuring 15 x 10.75 cm]
Machine-made Paper with no watermarks
Support #2 [10 folios measuring 15 x 10.75 cm]
European paper with no immediately visible watermarks
Support #3-6 [remaining 4 fragments]
European paper of various kinds
Measurements: [20 folios measuring: 15 x 10.75 cm + 4 fragments of various sizes]
Pagination: [None]
Hand(s): [Multiple]
Ink: [Varies]
Catchwords: [Varies]
Binding/Decoration: Fragments wrapped in white paper
Former Owners: [Sālim b. Ya‘qūb?—See notes]
Condition: The 20 folios are in great shape; the fragments are legible but incomplete folios.
Additional Notes: The label on the jādawiyya text looks like the handwriting in the top margins of the manuscript fragments at the Sālim b. Ya‘qūb library (see Love, Jr., 2017).
References: Paul M. Love, Jr., “The Sālim Bin Ya‘qūb Ibāḍī Manuscript Library in Jerba, Tunisia: A Preliminary Survey & Inventory,” Journal of Islamic Manuscripts 8 (2017): 257–80.
Shelf Mark: ASIDJ MS 913 [6]
Title [on sleeve]: شنات من التاريخ والاخبار
Uniform Title: N/A
Author: [Unknown]
Date of Transcription: [Unknown]
Place of Transcription: [Unknown]
Copyist & Transmission: [Unknown]
Quires: [n/a]
Folios: 28 folios
Page Layout: 19 lines per page; red border
Paper: European watermarked paper; Chain Lines (H): 28 mm; Laid Lines (V): 8/cm; “Tre Lune” watermark (f.3&8) 92 x 39 mm (DbC: 111 mm); Crescents measure (L->s): 10 mm, 8 mm, 6 mm.
Measurements: 22 x 16 cm
Pagination: [None]
Hand(s): Maghribi script
Ink: Brown, rubrics in red
Catchwords: Bottom left of each verso
Binding/Decoration: Stored in paper wrapper with other fragments
Former Owners: [Unknown]
Incipit [f.1.a]:
[لا وكره؟] الموت [لا؟] نبيا محمد صلى الله عليه وسلم فانه قال انعم...
Explicit [f.28.b]: [NB: this is the explicit of the final folio but there is no colophon for this text and the fragment contains more than one text]
...القرآن تيرا يادن الله والله اعلم انتهى
Condition: The fragment is in good condition and the text is legible; no obvious signs of pest or humidity damage.
Additional Notes: This appears to be stories of the lives and quotations of prophets; The paper wrapper identifies the author (*mu’allif*) as Amuḥammad al-Qaṣbī but clearly there are multiple.
References: [None]
Shelf Mark: ASIDJ MS 013 [7]
Title [on sleeve]: الأسراء والمعارج [ / ] الجارية العالمية عند هارون الرشيد
Uniform Title: [None]
Author: [sleeve identifies the text as an *Alfiyya* of Amuḥammad b. ‘Umar Talwīn al-Qaṣbī, but it appears to be incorrectly attributed]
Date of Transcription: [19th c.?—See watermarks]
Place of Transcription: [Unknown]
Copyist & Transmission: [Unknown]
Quires: N/A
Folios: 17 folios
Page Layout: 21 lines per page
Paper: European watermarked paper; Chain Lines (H): 30-32 mm; Laid Lines (V): 8/cm; “B” countermark [f.1]; 20 x 14 mm (DbC: 65 mm); “[C P?] E F P” [f.3&6]
~36 x 35 mm [measurements across fold] (DbC: 57 mm); “Tre Lune” watermark [f. 4&5] 62 x ~36 mm [measurements across fold] (DbC: 84 mm), Crescents measure (L->s): 9 mm, 8 mm, 6 mm; “G. A. C. V. [f.10] 78 x 11 mm (DbC: 103 mm) [NB: Same mark appears on each folio from f.11-28, including alongside the Tre Lune on f.27]
Measurements: 21 x 16.5 cm
Pagination: None
Hand(s): Maghribi script
Ink: Brown, rubrics in red
Catchwords: Bottom left of each verso
Binding/Decoration: Stored in paper wrapper with other fragments
Former Owners: [Unknown]
Incipit [f.1.a]:
مرة يسكون وهي اسمها عسكلون اذن منها يا محمد وسلم عليها...
[Explicit [f.9.a]]:
وهذه قصة الجارية تودد وما جرا بينها وبين يد عامين المومتنين هارون الرشيد...
ما زاع [كذا] البصر وما طغى وهذا ما بلغنا من حديث المعراج وما را فيه رسول الله صلى الله عليه وسلم وعائه وصحبه وسلم
انتهى هي
[Colophon]:
none—but see Explicit #1 above]
Condition: The fragment is in good condition; no obvious signs of humidity or significant pest damage
Additional Notes: Of course, the story of the *Mi'rāj and isrāʾ* is well known and this is presumably a fragment of that story; based on its Incipit, the second text likely belongs to the manuscript tradition of *Alf Layla wa-Layla.*
References: [None]
### Key
- * Indicates that the date comes from the text of the manuscript (colophon, ownership statement, etc.)
- ~ Indicates that a measurement is approximate.
- [across fold] Indicates that the measurement and/or photograph had to be made across the fold of a bound volume.
- DbC Distance between chain lines on either side of the watermark.
#### 1.1 "FP" watermark
Provenance: ASIDJ MS 001, *Risāʾil al-Hilātī* [f.4&7]
Date Range: [18th-19th c.]
Dimensions: 16 x 45 mm [across fold]
DbC: [not noted, machine-made paper]
#### 1.2 "Tre Lune" [1] watermark
Provenance: ASIDJ MS 001, *Risāʾil al-Hilātī* [f.14&17]
Date Range: [18th-19th c.]
Dimensions: 29 x 78 mm
Crescents (L-S): 9 mm 7 mm 5 mm
DbC: 103 mm
1.3 "Tre Lune" [2]
watermark
Provenance: ASIDJ MS 001, *Risāʾil al-Hilātī* [f.93&98]
Date Range: [18th-19th c.]
Dimensions: 22 x 75 mm [width across fold]
Crescents (L-S): 11 mm 9 mm 6 mm
DbC: 85mm
2.1 "Tre Lune" watermark
Provenance: ASIDJ MS 002, Composite Manuscript [f.4&9]
Date Range: [late-18th to early-19th c.]
Dimensions: 88 x 26 mm
Crescents (L-S): 9 mm 9 mm 6 mm
DbC: 95 mm
3.1 "Tre Lune" watermark
Provenance: ASIDJ MS 003, *Sharḥ wujiz...* [f.5&10]
Date Range:
1272AH/1855CE
Dimensions: ~72 x 29 [across fold]
Crescents (L-S): 10 mm 9 mm 6 mm
DbC: 95 mm
4.1 "C [G/C?]" countermark
Provenance: ASIDJ MS 004, *al-Juzʾ al-awwal..al-Baqi*, [f.7]
Date Range:
1121AH/1709CE.
Dimensions: 43 x 37 mm
DbC: 57 mm
4.2 “Tre Lune” watermark
Provenance: ASIDJ MS 004, *al-Juz’ al-awwal...al-Bāqi*,
[f.3, very faint; see f.16 for a clearer version of the same mark]
Date Range:
1121AH/1709CE
Dimensions: 137 x 29 mm
Crescents (L-S) : ~11 mm 10 mm 8 mm
DbC: 116 mm
5.1 “Trefoil” with “C” countermark
Provenance: ASIDJ MS 005, *al-Juz’ al-thānī...al-Bāqi*,
[f.91]
Date Range:
1140AH/1728CE
Dimensions: 58 x 19 mm
DbC: 60 mm
6.1 “C G” countermark
Provenance: ASIDJ MS 005, *al-Juz’ al-rabī’...al-Bāqi*,
[f.5]
Date Range: [18th c.?]
Dimensions: 35 x 45 mm
DbC: 50 mm [from chain one side to edge of folio]
6.2 “Tre Lune” watermark
Provenance: ASIDJ MS 006, *al-Juzʾ al-rābiʿ...al-Bāqi*, [f.10]
Date Range: [18th c.?]
Dimensions: 78 x 34 mm
Crescents (L-S): 13 mm 10 mm 10 mm
DbC: 114 mm
No Photo
(Unable to photograph watermark)
7.1 “Crown star crescent”
Provenance: ASIDJ MS 007, *Mizān nafīsa*... [f.9&10]
Date Range:
1097AH/1686CE
Dimensions: ~58 x 25 mm [across fold]
DbC: ~51 mm
7.2 “Scales in Shield with [N?] below”
Provenance: ASIDJ MS 007, *Mizān nafīsa*... [f.168&170]
Date Range:
1097AH/1686CE
Dimensions: ~53 x 28 mm [across fold]
DbC: 52 mm
7.3 “Crown, star, crescent?
[only bottom visible]”
Provenance: ASIDJ MS 007, *Mizān nafīsa*... [f.167&172]
Date Range:
1097AH/1686CE
Dimensions: ~87 x 61 mm
DbC: [Unable to determine]
8.1 “Cross in oval” watermark
Provenance: ASIDJ MS 008
[Untitled] [f.7&8]
Date Range:
1106AH/1694CE
Dimensions: ~51 x 37 mm
[across fold]
DbC: 57 mm
8.2 “Hillock” watermark
Provenance: ASIDJ MS 008
[Untitled] [f.10]
Date Range:
1106AH/1694CE
Dimensions: 21 x 18 mm
DbC: 28 mm
9.1 “Crown, star, crescent” watermark
Provenance: ASIDJ MS 009
[Untitled] [f.17&20]
Date Range: late-17th-18th c. ?
Dimensions: 74 x 44 mm
DbC: 55 mm
9.2 “Tre Lune” watermark
Provenance: ASIDJ MS 009
[Untitled] [f.24&31]
Date Range: late-17th-18th c. ?
Dimensions: 71 x ~30 mm
[across fold]
Crescents (L-S): 6 mm, 7 mm, 5 mm
DbC: 109 mm
9.3 “Crown, star, crescent” [2] watermark
Provenance: ASIDJ MS 009 [Untitled] [f.27&28]
Date Range: late-17th-18th c. ?
Dimensions: ~70 x 52 mm [across fold]
DbC: 81 mm
9.4 “Trefoil with ‘G A’ below” countermark
Provenance: ASIDJ MS 009 [Untitled] [f.30]
Date Range: late-17th-18th c. ?
Dimensions: 52 x 40 mm
DbC: 52 mm
9.5 “Tre Lune” watermark [Support #2]
Provenance: ASIDJ MS 009 [Untitled] [f.303&309]
Date Range: late-17th-18th c. ?
Dimensions: 80 x ~36 mm [across fold]
Crescents (L-S): ~12 mm, 8 mm, 7 mm [largest unclear due to pest damage]
DbC: 112 mm
9.6 “C G” countermark
Provenance: ASIDJ MS 009 [Untitled] [f.308]
Date Range: late-17th-18th c. ?
Dimensions: 52 x 37 mm
DbC: 60 mm [to edge of folio]
10.1 Mirrored “C G”[?]
watermark
Provenance: ASIDJ MS 010
Majmūʿ [f.6]
Date Range: [17th-18th c.?]
Dimensions: ~32 x 30 mm
DbC: 60 mm
10.2 “Chalice[?]”
watermark
Provenance: ASIDJ MS 010
Majmūʿ [f.5&12]
Date Range: [17th-18th c.?]
Dimensions: 40 x 12 mm
DbC: 28 mm
NB: Measurement for part of mark on f.12 only
10.3 “Tre Lune” watermark
Provenance: ASIDJ MS 010
Majmūʿ [f.17&23]
Date Range: [17th-18th c.?]
Dimensions: ~95 x ~27 mm
[to the fold, only half visible]
Crescents (L-S): 8 mm 9 mm 6 mm
DbC: [unable to measure]
11.1 “Crown, star, crescent”
watermark
Provenance: ASIDJ MS 011
Nahū [f.4&13]
Date Range:
1099AH/1688CE
Dimensions: 55 x 52 mm
DbC: 60 mm
11.2 “Trefoil with b V” countermark
Provenance: ASIDJ MS 011
Naḥū [f.7]
Date Range:
1099AH/1688CE
Dimensions: 42 x 46 mm
DbC: 59 mm [to edge of folio]
11.3 “Trefoil with b T” countermark
Provenance: ASIDJ MS 011
Naḥū [f.9]
Date Range:
1099AH/1688CE
Dimensions: 48 x 34 mm
DbC: 53 mm [to edge of folio]
12.1 “Tre Lune” watermark
Provenance: ASIDJ MS 012
Qur’an [f.5&8]
Date Range: [17th-19th c. ?]
Dimensions: 87 x 37 mm
Crescents (L-S): 8 mm 7 mm 6 mm
DbC: 113 mm [to edge of folio]
13.1 “Tre Lune” watermark
Provenance: ASIDJ MS 013
[1] Sharh al-nunīyya [f.4&5]
Date Range: [19th c.?]
Dimensions: 93 x ~41 mm (across fold)
Crescents (L-S): 20 mm 20 mm 14 mm
DbC: 143 mm
13.2 “V H” countermark
Provenance: ASIDJ MS 013
[1]
[f1]
Date Range: [19th c.?]
Dimensions: 39 x 27 mm
DbC: 57 mm
13.3 “Tre Lune” watermark
Provenance: ASIDJ MS 013
[2]
[f1&2]
Date Range: [19th c.?]
Dimensions: 99 x 37 mm
Crescents (L-S): 10 mm 10 mm 7 mm
DbC: 142 mm
13.4 “G M” countermark
Provenance: ASIDJ MS 013
[2]
[f.23]
Date Range: [19th c.?]
Dimensions: ~10 x 50 mm
DbC: 82 mm
13.5 “FA with crest”
watermark
Provenance: ASIDJ MS 013
[3]
[f.3&4]
Date Range: [19th c.?]
Dimensions: ~79 x 49 mm
DbC: 52 mm
13.6 “Tre Lune + [name?]” watermark
Provenance: ASIDJ MS 013
[3]
[f.13&14]
Date Range: [19th c.?]
Dimensions: 61 x 112 mm
DbC: 154 mm
NB: Name not visible
13.7 “B” countermark
Provenance: ASIDJ MS 013
[4]
[f.5]
Date Range: [17th-18th c.?]
Dimensions: 25 x 14 mm
DbC: 26 mm
13.8 “Tre Lune” watermark
Provenance: ASIDJ MS 013
[4]
[f.7&13]
Date Range: [17th-18th c.?]
Dimensions: 99 x 33 mm
Crescents (L-S): 15 mm 9 mm 10 mm
DbC: 108 mm
13.9 “Crest(?) with ‘P G’ inside” watermark
Provenance: ASIDJ MS 013
[4]
[f.82]
Date Range: [17th-18th c.?]
Dimensions: 60 x 45 mm
[visible area only]
DbC: 52 mm
13.10 “Tre Lune watermark [2] with C.A.C.V.”
Provenance: ASIDJ MS 013 [4]
[F86]
Date Range: [17th-18th c.?]
Dimensions: 60 x 25 mm [visible area of Tre Lune only]; 14 x 80 mm [C.A.C.V. mark]
DbC: [Tre Lune] 83 mm; [C.A.C.V.] 110 mm
13.11 “Tre Lune” watermark
Provenance: ASIDJ MS 013 [6]
[F3&8]
Date Range: [?]
Dimensions: 92 x 39 mm
Crescents (L-S): 10 mm 8 mm 6 mm
DbC: 111 mm
13.12 “B” countermark
Provenance: ASIDJ MS 013 [7]
[F1]
Date Range: [19th c.?]
Dimensions: 20 x 14 mm
DbC: 65 mm
13.13 “[C P?] E F P”
watermark
Provenance: ASIDJ MS 013 [7]
[F3&6]
Date Range: [19th c.?]
Dimensions: ~36 x 35 mm [across fold]
DbC: 57 mm
13.14 “Tre Lune” watermark
Provenance: ASIDJ MS 013 [7]
[f.4&5]
Date Range: [19th c.?]
Dimensions: 62 x ~36 mm [across fold]
Crescents (L-S): 9 mm 8 mm 6 mm
DbC: 84 mm
13.12 “G. A. C. V.” watermark
Provenance: ASIDJ MS 013 [7]
[f.10]
Date Range: [19th c.?]
Dimensions: 78 x 11 mm
DbC: 103 mm
NB: Appears alongside Tre Lune (e.g., f.27)
Part IV: Inventory of Uncatalogued Items
القسم الرابع: جرد المخطوطات والوثائق الأخرى التي لم يتم فهرسها بعد
NB: At the time of my penultimate visit to the ASIDJ in early August 2017, these items were stored in a cardboard box. They suffered from significant and ongoing pest, mold, and humidity damage. Before leaving, I organized the texts according to type (document, bound volume, loose fragments) and placed them in large plastic sleeves to at least help contain the insect infestation. My hope is that proper treatment for the pest damage will be carried out soon and that a full inventory of these items, some of which could prove very interesting, will be completed in the future. Unlike the bound volumes in the ASIDJ library, these fragments have not been photographed. The state of the material along with the short time of my visit kept me from preparing anything more than a general inventory of items.
1. Bound MS volume entitled: الدَّرُّ السِّنْتُورُ فِي العَمَلِ بِرَفْعِ الدَّسْتُورِ لِسَلَامَةِ ابْنِ شَدَّاْخ
2. Quran fragment
3. Lithography fragment of “دعاء ختمة القرآن”
4. Notebook of poetry belonging to [Husni?] b. Ahmad b. al-Hājj Būsalāma b. ‘Umar Bū Būshaddākh, dated 1365/1945
5. MS fragment in an envelope labeled “فخر خوارزم فخر الدين الزراي”
6. MS fragment in an envelope labeled “مسائل في عقيدة التوحيد”
7. MS fragments in an envelope labeled “فضائل الصلاة []/ منظومة في الأخلاق الكريمة”
8. MS fragments in an envelope labeled “ورقات : الوقف الهيئة الإثر []/ قران كريم []/ جزء من منظومة”
9. MS fragments in an envelope labeled “مخطوطة بوعيس[؟] الغول”
10. MS fragment in an envelope labeled “صالح بن زكريا بن عيسى بن زكريا الجداوي”
11. Program from an exhibition on 3 May 2003 entitled “المخطوطة في جريدة جريدة”
12. MS fragments wrapped in a paper wrapped labeled “كتاب في الطب”
13. Unlabeled manuscript fragment
14. Bound volume containing several different lithograph fragments and bearing the ownership statement of Ahmad b. Būsallāma Bū Shaddakh [condition prevented further examination]
15. 2 photocopies of family documents
16. MS document dated 1322/1904
17. 2 laminated MSS of family documents
### Appendix 1: Names of Copyists
| Associated Date | MS | Copyist |
|----------------------------------|----|----------------------------------------------|
| After 1099AH [1687-88 CE] | 1 | سليمان بن الشيخ أحمد الحيلاتي |
| After 1099AH [1687-88 CE] | 1 | عمر بن الفقيه أحمد الشماخي |
| Late-18th to early-19th c.? | 2 | علي بن الحاج سالم المقدم |
| Ramaḍān 1121 AH [Nov-Dec 1709 CE]| 4 | عبد الله بن محمد السوسي |
| 6 Ramaḍān 1097 [26 Jul 1686] | 7 | محمد بن الحاج محمد بن أحمد بن الحاج قاسم الضباوي |
| 8 Jumādā al-ūlā 1106 AH [24 Dec 1694] | 8 | عبد السلام بن عبد الوهاب سليل المجدوب |
| 4 Ramaḍān 1099 [2 July 1688] | 11 | عمر بن إبراهيم بن سعيد بن أبي زيد |
### Appendix 2: Names of Owners
| Associated Date(s) | MS | Owner’s name |
|-----------------------------------|----|-------------------------------------------------------------------------------|
| Late-18th to early-19th c.? | 2 | محمد [بن؟] محمد بن أحمد بن الحاج متيان |
| mid-Rabīʿ al-thānī 1272 AH [Dec 1855 CE] | 3 | أبو العباس أحمد بن الحاج |
| After mid-Rabīʿ al-thānī 1272 AH [Dec 1855 CE] | 3 | الطيب بن محمد بن أحمد ابن الحاج محمد |
| 1153 AH [1740-41 CE] | 5 | محمد الحاج المني [؟] من أخيه [في الدين؟] محمد بن [محمد] المني |
| 23 Rabīʿ [al-thānī?] 1273 [Dec 1856 CE] | 6 | محمد بن أحمد بن محمد بن الحاج [الضباوي؟] |
| 1232 AH [1816-17] | 7 | محمد بن الحاج محمد بن أحمد بن الحاج قاسم الضباوي |
---
*CF, however, the name given in the ownership statement of the same MS and dated 1232. I suspect that the copyist wrote the date of transcription from the exemplar, although it could be a member of the family with the same name.*
| Date and Location | Page Number | Name |
|-------------------|-------------|------|
| After 8 Jumādā al-ulā 1106 AH [24 Dec 1694] (Colophon) | 8 | أبو حفص عمر بن [محمد؟] الجمni |
| After 8 Jumādā al-ulā 1106 AH [24 Dec 1694] (Colophon) | 8 | أحمد بن أبي [عصرية؟] بن أحمد بن أحمد بن يوسف الفاسي |
| 1345 AH [1926-7 CE] | 9 | سعيد بن تعريت [كذا] |
| 4 Ramadān 1099 [2 July 1688] (Colophon) | 11 | لعمه أبي الربيع [يجني؟] سليمان بن عبد الله بن أبي زيد |
| [19th – 20th c.?] | 12 | أحمد بن يوسلامة بن عمر أبي شداخ |
|
Analysis of genetically determined gene expression suggests role of inflammatory processes in exfoliation syndrome
Jibiri B. Hirbo\textsuperscript{1,2*}, Francesca Pasutto\textsuperscript{3}, Eric R. Gamazon\textsuperscript{1,2,4}, Patrick Evans\textsuperscript{1}, Priyanka Pawar\textsuperscript{5}, Daniel Berner\textsuperscript{6}, Julia Sealock\textsuperscript{1}, Ran Tao\textsuperscript{7}, Peter S. Straub\textsuperscript{1}, Anuar I. Konkashbaev\textsuperscript{1}, Max A. Breyer\textsuperscript{1}, Ursula Schlötzer-Schrehardt\textsuperscript{6}, André Reis\textsuperscript{3}, Milam A. Brantley Jr\textsuperscript{4}, Chiea C. Khor\textsuperscript{8}, Karen M. Joos\textsuperscript{5} and Nancy J. Cox\textsuperscript{1,2}
**Abstract**
**Background** Exfoliation syndrome (XFS) is an age-related systemic disorder characterized by excessive production and progressive accumulation of abnormal extracellular material, with pathognomonic ocular manifestations. It is the most common cause of secondary glaucoma, resulting in widespread global blindness. The largest global meta-analysis of XFS in 123,457 multi-ethnic individuals from 24 countries identified seven loci with the strongest association signal in chr15q22–25 region near LOXL1. Expression analysis have so far correlated coding and a few non-coding variants in the region with LOXL1 expression levels, but functional effects of these variants is unclear. We hypothesize that analysis of the contribution of the genetically determined component of gene expression to XFS risk can provide a powerful method to elucidate potential roles of additional genes and clarify biology that underlie XFS.
**Results** Transcriptomic Wide Association Studies (TWAS) using PrediXcan models trained in 48 GTEx tissues leveraging on results from the multi-ethnic and European ancestry GWAS were performed. To eliminate the possibility of false-positive results due to Linkage Disequilibrium (LD) contamination, we i) performed PrediXcan analysis in reduced models removing variants in LD with LOXL1 missense variants associated with XFS, and variants in LOXL1 models in both multiethnic and European ancestry individuals, ii) conducted conditional analysis of the significant signals in European ancestry individuals, and iii) filtered signals based on correlated gene expression, LD and shared eQTLs, iv) conducted expression validation analysis in human iris tissues. We observed twenty-eight genes in chr15q22–25 region that showed statistically significant associations, which were whittled down to ten genes after statistical validations. In experimental analysis, mRNA transcript levels for ARID3B, CD276, LOXL1, NEO1, SCAMP2, and UBL7 were significantly decreased in iris tissues from XFS patients compared to control samples. TWAS genes for XFS were significantly enriched for genes associated with inflammatory conditions. We also observed a higher incidence of XFS comorbidity with inflammatory and connective tissue diseases.
**Conclusion** Our results implicate a role for connective tissues and inflammation pathways in the etiology of XFS. Targeting the inflammatory pathway may be a potential therapeutic option to reduce progression in XFS.
**Keywords** Exfoliation syndrome, GWAS, TWAS, transcriptomics, GTEx, predicted expressions
*Correspondence:*
Jibiri B. Hirbo
email@example.com
Full list of author information is available at the end of the article
Introduction
Exfoliation syndrome (XFS) is an age-related systemic disorder characterized by excessive production and progressive accumulation of abnormal extracellular material, with pathognomonic ocular manifestations [1, 2]. The exact pathophysiological processes that underline XFS is still unclear. However exfoliative material typically builds up at the anterior part of the eye, including in and around the trabecular meshwork slowing aqueous humor outflow and causing elevation in intraocular pressure [3–5]. It is the most common cause of secondary glaucoma, resulting in widespread global blindness [6]. In addition to ocular manifestations, exfoliation syndrome deposits have been observed in visceral organs, such as the lung, kidney, liver and gallbladder [2, 7]. In addition to elastic tissue disorders, XFS has also been associated with increased risk of vascular diseases [8–10]. Associations of XFS to several systemic biomarkers of inflammation, including complement components and homocysteine, have also been reported [6, 11, 12].
Genetic mechanisms have substantial influence on XFS etiology as evidenced in family and twin studies [13, 14]. There have been eight genome-wide association studies (GWAS) of XFS [10, 15–20], three of which include meta-analysis [10, 15, 21], that have cumulatively identified >60 associated genetic variants. The largest meta-analysis of XFS involved >123,000 individuals (13,620 XFS cases, 109,837 controls) from 24 countries across six continents and identified seven loci with the strongest association signal in chromosome 15 near the lysyl oxidase-like 1 gene (*LOXL1*) [15, 21], which encodes a member of family of proteins involved in formation of crosslinks in collagen and elastin [22]. The signal on chr15 involved 54 potential causal variants. Overall, (i) two missense variants in *LOXL1*, rs1048661 (encoding *LOXL1* p.Leu141Arg) and rs3825942 (p.Gly153Asp), are likely to confer risk of developing XFS, with very high heterogeneity across populations because the alleles show an effect reversal [15, 18, 21, 23–26], (ii) the associated variants in the locus showed population-specific frequency and LD patterns [15, 18, 21, 24], (iii) haplotypes that carry the risk alleles depending on the population are correlated with reduced *LOXL1* expression levels, however, (iv) no clear functional effects for the haplotypes that represent the two variants have been shown [10, 27, 28]. The non-coding variants associated with XFS at this chr15 locus could confer regulatory effects. Some of these non-coding variants regulate expressions of the sentinel *LOXL1* and the neighboring *STRA6* gene [10, 29, 30].
After considering all the reports on genetic architecture of XFS to date, we hypothesize that analysis of the contribution of the genetically determined component of gene expression to XFS risk can provide a powerful method to elucidate potential roles of additional genes in XFS. We used a gene-based TWAS method, PrediXcan [31], implemented on GWAS summary statistics (Summary PrediXcan; S-PrediXcan) [32] to identify genetically determined gene expression traits associated with disease risk. Models were trained on 48 Genotype-Tissue Expression (GTEx ver. 8) project tissues: Adipose - Subcutaneous, Adipose - Visceral (Omentum), Adrenal Gland, Artery - Aorta, Artery - Coronary, Artery - Tibial, Brain - Amygdala, Brain - Anterior cingulate cortex (BA24), Brain - Caudate (basal ganglia), Brain - Cerebellar Hemisphere, Brain - Cerebellum, Brain - Cortex, Brain - Frontal Cortex (BA9), Brain - Hippocampus, Brain - Hypothalamus, Brain - Nucleus accumbens (basal ganglia), Brain - Putamen (basal ganglia), Brain - Spinal cord (cervical c-1), Brain - Substantia nigra, Breast - Mammary Tissue, Cells - Cultured fibroblasts, Cells - EBV-transformed lymphocytes, Colon - Sigmoid, Colon - Transverse, Esophagus - Gastroesophageal Junction, Esophagus - Mucosa, Esophagus - Muscularis, Heart - Atrial Appendage, Heart - Left Ventricle, Liver, Lung, Minor Salivary Gland, Muscle - Skeletal, Nerve - Tibial, Ovary, Pancreas, Pituitary, Prostate, Skin - Not Sun Exposed (Suprapubic), Skin - Sun Exposed (Lower leg), Small Intestine - Terminal Ileum, Spleen, Stomach, Testis, Thyroid, Uterus, Vagina, Whole Blood [33, 34]. GTEx is a comprehensive public resource to study tissue-specific gene expression and regulation [33, 34]. We estimated the correlation between genetically determined gene expression and XFS risk by leveraging on XFS GWAS summary statistics from a previously reported multi-ethnic study [21]. The phenomenon of TWAS association with multiple signals within the same locus can be a statistical artifact of the correlation due to LD between SNPs that are separately predictive of the measured expression of physically co-localized genes [35] hampering the ability to prioritize the true causal gene(s). To address this limitation, we performed sequential conditional analysis in each tissue, starting with the gene that was the strongest signal in the initial PrediXcan analysis. In addition, we sequentially rebuilt prediction models excluding variants in models of other genes in the loci that were in LD with any variants of the strongest signal. We also analyzed individual-level GWAS data from three additional European ancestry populations, German, Italian and American [10, 31]. We followed these extensive statistical analyses by functional validation in human iris tissues of the prioritized top gene-level associations. Finally, to gain clinical insights into our findings,
we explored the health consequences to individuals carrying high XFS genetic risk in a large biobank with links to electronic health records.
**Results**
**PrediXcan analysis**
We performed single-tissue PrediXcan analysis of the global multi-ethnic GWAS (13,620 XFS cases and 109,837 controls) summary data, identifying 23 genes (defined as signals with $P < 2.02 \times 10^{-7}$ after Bonferroni corrections) on chromosome 15: *CYP1A2*, *CYP1A1*, *STOML1*, *LOXL1*, *ISLR2*, *RPP25*, *INSYN*, *ISLR*, *STRA6*, *CD276*, *NEO1*, *ARID3B*, *COX5A*, *PML*, *CPLX3*, *LMAN1L*, *UBL7*, *MPI*, *CLK3*, *CSK*, *SEMA7A*, *TBC1D21*, and *NPTN* that mapped to region 15q22–25 region that spans ~3 Megabases (Fig. 1a, b and Suppl. Table S2).
To determine the joint effects of gene expression variation predicted across all 48 tissues analyzed, we performed a multivariate regression multi-tissue analysis. Each of the 23 associations from the single-tissue PrediXcan analysis remained significant in multi-tissue analysis (Suppl. Table S3). Additionally, five genes within the same region that were associated with XFS at sub-genome-wide significance in the single-tissue analysis ($p < 3.02e-6$) were associated in the multi-tissue analysis: *ADPGK* ($p = 7.32E-07$), *CYP1A1* ($p = 1.36E-16$), *HEXA* ($p = 1.03E-06$), *PARP6* ($p = 1.82E-06$), *SCAMP2* ($p = 1.65E-10$) (Fig. 1b).
Seven additional genes located on chromosomes 1 (*LGR6* $p = 2.20E-06$; *SDHB* $p = 8.07E-08$), 6 (*PRRT1* $p = 9.10E-07$), 8 (*PRSS55* $p = 4.18E-13$), 10 (*CDH23* $p = 1.86E-07$; *PITRM1* $p = 8.45E-12$) and 19 (*CALM3* $p = 2.60E-07$), were significantly associated in the multi-tissues analysis (Fig. 1a, Suppl. Table S3). All seven signals mapped to genomic regions harboring GWAS SNP variants showing subgenome-wide significance with XFS risk, except for PRRT1, which corresponds to the AGPAT1 GWAS locus [36]. The data indicates that combining information across variants in genes and then across tissue expression improves the power to identify additional XFS-associated loci. To ensure that the association observed at the 23 genes from the larger multi-ethnic dataset was not an artefact of population structure, we confirmed the signals in a subset of European ancestry individuals (Materials and Methods, Suppl. Fig. S3, Suppl. Table S4, S5, S6).
**Correlated expression among significant genes**
To determine whether the 23 observed association gene signals were artefacts of LD contamination, we calculated the pair-wise correlation in measured expression among the significant genes, using the reference GTEx panel. We further checked the relationship between expression correlation for each of the chr15p22–25 genes with *LOXL1* and *STOML1* and the PrediXcan associations for the two genes in each tissue. We made two important observations from this analysis. First, there was a significant correlation between the correlation of measured gene expression of the other genes in chr15p22–25 with *LOXL1* or *STOML1* and the gene-level associations with XFS in most tissues (Fig. 2e, f, Suppl. Fig. S4, Suppl. Table S7a). Secondly, there is substantial correlation between *STOML1* and *LOXL1* ($r^2 = 0.67$, $p = 0.009$) (Fig. 2e, f, Suppl. Fig. S4). These results indicate that the associations by one of the genes might be due to LD contamination or the presence of shared variants in the prediction models of the two genes (Fig. 2g, Table 2).
To dissect the potential source of LD contamination in the PrediXcan analysis, we looked into the effect of the two GWAS missense variants implicated in XFS that have mostly been linked to *LOXL1* and shown to play regulatory roles [27], followed by the effect of *LOXL1* and *STOML1* signals on chr15q22–25 region observed associations in each tissue. We also determined the effect of shared variants between prediction models for the genes in the region.
We modified our prediction models by excluding: i) rs3825942 missense variant, ii) rs4886776 intronic variant, which is at near perfect LD (pair-wise, $r^2 = 0.982$) with the rs1048661 missense variant, and iii) all the
(See figure on next page.)
**Fig. 1** Manhattan plot for GWAS meta-analysis and PrediXcan analysis of the genotyping data for XFS. **a** The lower half of the plot is for the XFS meta-analysis summary statistics data Aung et al., 2017, while the upper half of the plot shows results from PrediXcan analysis for 48 GTEx tissues. On the X axis is plot of variant/gene associations along the chromosomes, while Y axis represent the significance levels for the associations. The legend for PrediXcan analysis on the 48 GTEx tissues, a color for each tissue, is on the right. For both plots the blue dotted line is the ‘suggestive’ genome-wide significant threshold ($p < 1e-4$), while the red line is the genome-wide significant threshold. On the lower plot, the gene labels are for genes reported/mapped to genome-wide significant signals in GWAS result, while in the upper plot is for genes that are associated at genome-wide significant threshold. For genes associated with XFS at genome-wide threshold in more than one tissues, only the tissue with lowest p-value is labeled. The GWAS plot has been truncated to $p < 1e-220$ for clarity. **b** genes in the region in chromosome 15 that show significant association. The size of the balloon for each gene-tissue association is proportional to -log10$p_{value}$ and color corresponds to the predicted direction of expression changes: dark-red and blue for increased and decreased expression changes, respectively. Only four genes (EDC3, ULK3, HCN4 & FAM219B) in the whole region were not associated with XFS.
variants in our gene models that were in LD with the two variants ($r^2 > 0.1$). The two missense variants had wide ranging effect on the genetically predicted expression of many chr15q22–25 region genes, with the largest effect on *LOXL1*. The strength of the association signals diminished in six of the nine tissues for which we had the gene’s predicted expression. Association signals in three of these tissues fell below genome-wide threshold in the global dataset (Suppl. Table S7b). In addition, association signals for seven additional genes in the region besides...
**STOML1** lost genome-wide significance: **CD276** (2 tissues), **COX5A**, **CYP1A1**, **LMAN1L**, **MPI**, **SCAMP2** and **TBC1D21**.
Interestingly, association signals for eight genes were strengthened, four of which attained genome-wide significance threshold in reduced models: **INSYNI**, **CYP1A1**, **NPTN** and **LOXL1** (Suppl. Table S7b). These shifts in association strength, i.e., an increase in effect size, seem to be due to the exclusion of select variants (Suppl. Tables S7c, S7d). Moreover, the shifts in association strength are correlated with the excluded variants’ level of LD with the missense variant rs3825942 ($r^2 = 0.64$) (Suppl. Tables S7c, S7d). Notably, the three GWAS variants identified to have effect reversal in South Africans relative to other populations were in high LD with rs3825942 (Suppl. Table S7g) [21]. Our results indicate that the missense variants have...
enhancing or diminishing effects on the PrediXcan association signals, in chr15q22–25, with XFS, consistent with allele reversal reported for the GWAS variants [36].
To check whether the association signals in the chr15q22–25 region for each tissue were independent of the ‘sentinel’ *LOXL1* signal, we excluded, from the prediction models, variants that were in LD ($r^2 > 0.1$) with any variants in *LOXL1 or STOML1* tissue models. We also excluded variants that were shared between two or more genes in their original prediction models. Seven of the genes that were associated with XFS at genome-wide threshold in their original models showed diminished signals, including four below significance levels: *UBLT*, *ISLR*, *LMAN1L* and *COXSA* in reduced models (Suppl. Table S7e). Association signals for *CYP1A1* and *CYP1A2* were slightly diminished in reduced models relative to the original models, but remained at significant genome-wide thresholds (Suppl. Table S7e). However, association signals for six genes strengthened, four of which attained genome-wide association significance levels in the reduced models: *INSYN1*, *CLK3*, *CYP1A1* and *NEO1* (Suppl. Table S7e). These shifts in association strength seem to be due to few variants that are either in LD with variants in *LOXL1* and *STOML1* models or are shared with other genes’ models (Suppl. Tables S7e, S7f). However, these variants causing the shifts in association signals upon exclusion from the models, were not in LD with the missense rs3825942 variant (Suppl. Table S7g). This indicates that there are signals of allele reversal independent of the known missense variants in *LOXL1*.
Excluding variants that are in LD with SNPs in the *LOXL1/STOML1* models did not have any effect on the association signals for six genes that were associated with XFS at genome-wide threshold in the original models: *CSK*, *STRA6*, *CD276*, *ARID3B*, *MPI & TBC1D21*, with the latter three in testis, for which we had no models for both *LOXL1* and *STOML1* (Suppl. Table S7e). The results indicate that some of the observed signals were artefacts of LD contamination from *LOXL1* and *STOML1* (*ISLR, LMAN1L* and *COXSA*), while some of the signals were masked in the original models (*INSYN1, CLK3, CYP1A1* and *NEO1*). There was inconsistent result for *UBLT*, where there was no effect in its association signal in a tissue, enhanced effect in another tissue, and diminished signal in two other tissues, one of which went below the genome-wide threshold, albeit the reduced model had only a single variant in the prediction (Suppl. Table S7e).
**Conditional analysis**
Conditional analysis was performed in tissues with any genome-wide significant chr15p22–25 region gene signals against the predicted gene expression for the strongest observed signals in the European subset. As in the global dataset, the strongest signals in the European dataset were at *LOXL1* (Table 1, Suppl. Fig. S3). In all nine of the 48 tissues with *LOXL1* predicted expression, only the *STOML1* gene showed a significant association signal (in addition to *LOXL1*) (Table 1, Suppl. Fig. S3). After conditioning on *LOXL1* in these tissues, the *STOML1* signal disappeared, but association signals at *SCAMP2* and *INSYN1* were observed in artery-aorta and lung tissues, respectively (Fig. 2a, b, Suppl. Table S8). This indicated that the association of *STOML1* with XFS is an artefact of a strong *LOXL1* signal, consistent with *LOXL1* being the true signal and *STOML1* a proxy signal. In addition, association signals for *SCAMP2* and *INSYN1* were masked by the *LOXL1* signal.
In 17 tissues with *STOML1* predicted gene expression, we observed significant association signals for 8 other genes (in addition to *STOML1*) (Fig. 2c, d, Suppl. Table S8). After conditioning on *STOML1* predicted gene expression, associations with four genes (*CYP1A1, INSYN, LOXL1, SCAMP2*) remained, while association with four other genes (*ISLR, LMAN1L, MPI & SEMA7A*) disappeared. In addition, associations with five more genes (*ARID3B, CPLX3, CYP1A2, PML & UBL7*) attained genome-wide significance after the conditional analysis.
Overall, conditional PrediXcan analysis of genetic signals in the chromosome 15 region in the European
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**Table 1** Genes associated with XFS and replicated in European Ancestry individuals
| Chromosome | Genes associated with XFS |
|------------|---------------------------|
| chr1 | $^a$LGR6,$^a$SDHB |
| chr6 | $^b$PRTJ |
| chr8 | $^b$PRSSS |
| chr10 | PITRM1*$^a$CDH23 |
| chr11 | $^a$TMEM136 |
| chr15 | SEMA7A***;STOML1***;ADPGK;MPI***;HEXA*;LOXL1***;CPLX3*;INSYN1***;SCAMP5**;ISLR***;CYP1A1*;NPTN*;CSK***;NEO1*;UBL7***;CD276***;STRA6***;PARP6*;LMAN1L***;ISLR2*;ARID3B*C;LK3*;PML;SCAMP2***;TBC1D21;CYP1A2*;CYP1A1***;RPP25*;ULK3** |
| chr16 | $^b$CDYL2** |
| chr19 | $^c$CALM3 |
**Gene associated with XFS in single tissues analysis at genome-wide significance threshold (<2.02e-7) in global GWAS summary statistic**
**Gene associated with XFS in cross-tissue analysis (<9.5e-6) and in single tissues analysis at suggestive significance threshold (<1e-4) in global GWAS summary statistics**
Significance values in European ancestry data single tissue analysis of genes associated with XFS ***$p$ value < 2.02e7, **$p$ value < 1e-4, *$p$ value < 0.05
*a* genes associated with XFS in global dataset but with no association signals in European ancestry data at even nominal threshold (<0.05)
*b* Additional genes associated with XFS in cross-tissue analysis of European ancestry data but not in global dataset
dataset in a limited number of tissues was mostly consistent with PrediXcan analysis using the reduced models above. The analysis confirms the associations for *LOXL1*, *ARID3B*, *CPLX3*, *CYP1A1*, *CYP1A2*, *INSYN1*, *NEO1*, *PML*, *SCAMP2*, and *UBI7*, all of which, except for *INSYN1*, have been shown to be highly expressed in eye tissues [37] (Suppl. Fig. S5). However, *INSYN1* has enhanced expression in brain tissues [38, 39]. Collectively, these results suggest that some of the identified gene-level association signals between XFS and genetically imputed expression were driven by correlation to the strong *LOXL1* and its “proxy” *STOML1* signal.
**Enrichment and pathway analysis**
Genes at genome-wide significance (*p* < 0.20e-7) and nominal significance (*p* < 0.05) were evaluated for enrichment of known pathways, using Enrichr [40, 41]. Genes at genome-wide significance were enriched for genes reported for, or mapped to, GWAS variants implicated in several caffeine-related (coffee and caffeine consumption, and caffeine metabolism [42–44]) and blood pressure [45] traits. The enrichment for coffee consumption is replicated for the larger gene set that is associated with XFS at nominal significance [36]. Some of these genes, *CYP1A1* and *CYP1A2* [46], are involved in fatty acid oxidation and estrogen receptor pathways. In addition, these two genes are also observed in the Reactome enrichment of protectin synthesis (Table 2, Suppl. Table S9).
Our gene set is also enriched for genes associated with carcinoma and three inflammatory conditions: rheumatoid arthritis, Type 1 diabetes, vitiligo in Jensen Diseases, a database that integrates evidence on disease-gene associations from automatic text mining, manually curated literature, cancer mutation data, and GWAS (https://diseases.jensenlab.org/).
We further analyzed our gene list against compounds in Drug Signatures Database (DSigDB, http://tanlab.ucdenver.edu/DSigDB), a gene set resource that relates drugs/compounds and their target genes. Our gene set is enriched for genes that are targets of cyclosporin A (*p* = 9.66E-11), and genes that are targets for compounds that are either 1) carcinogenic: Aflatoxin B1, potassium chromate, methyl methanesulfonate and copper sulfate, 2) neuroactive: valproic acid and methamphetamine, 3) neuroprotective: quercetin and epigallocatechin gallate, or 4) analgesic: acetaminophen (Table 2, Suppl. Table S9). Cyclosporin A is an immunosuppressant taken to treat rheumatoid arthritis and other autoimmune conditions, while quercetin and acetaminophen have been shown to have anti-inflammatory effects [47, 48].
Analysis in Gene Set Enrichment Analysis (GSEA) using a ranked association gene list based on effect sizes confirmed some of the enrichment observations using Enrichr. GSEA besides replicating enrichment for acetaminophen, showed enrichment for: 1) six synthetic estrogens, 2) estrogen regulators (Clomifene), 3) antiarrhythmic (quinidine), and 4) an anti-fungal (ketaconazole) (Table 2, Suppl. Table S9). The gene set was also enriched for genes that were associated with the collagen fibril crosslinking (FDR = 0.0313) Reactome pathway. Analysis of the gene list in relation to the latest Reactome library (https://reactome.org/) returned
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**Table 2** Enrichment analysis of genes that are associated with XFS
| Tool | Database | enrichment | Name | # found | # total | Adj-*p*-values/FDR |
|------------|-------------------|------------|----------------------------------------------------------------------|---------|---------|---------------------|
| Reactome | reactome | pathway | Endosomal/Vacuolar pathway | 59 | 82 | 1.83E-07 |
| GSEA | reactome | pathway | Crosslinking of collagen fibrils | 5 | 8 | 0.031 |
| Enrichr | Jensen Diseases | Disease | Rheumatoid_arthritis | 119 | 310 | 8.32E-08 |
| | | | Type_1_diabetes_mellitus | 68 | 158 | .69E-06 |
| | | | Carcinoma | 2619 | 11,318 | 0.013 |
| | | | Vitiligo | 28 | 63 | 0.029 |
| Enrichr | GWAS Catalog | traits | Caffeine consumption | 11 | 14 | 0.019 |
| Enrichr | DSigDB | Drugs | cyclosporin_A_CTD_00007121 | 1258 | 4826 | 9.66E-11 |
| | | | VALPROIC_ACID_CTD_00006977 | 2041 | 8313 | 1.75E-09 |
| | | | Copper_sulfate_CTD_00007279 | 1508 | 6017 | 3.04E-08 |
| | | | quercetin_CTD_00006679 | 812 | 3159 | 7.82E-05 |
| | | | acetaminophen_CTD_00005295 | 1017 | 4136 | 0.007 |
| | | | AFLATOXIN_B1_CTD_00007128 | 773 | 3082 | 0.006 |
| | | | (−)-Epigallocatechin_gallate_CTD_00002033 | 546 | 2115 | 0.005 |
| | | | POTASSIUM_CHROMATE_CTD_00001284 | 491 | 1898 | 0.011 |
| | | | METHAMPHETAMINE_CTD_00006286 | 40 | 102 | 0.030 |
| | | | METHYL_METHANESULFONATE_CTD_00006307 | 940 | 3685 | 0.047 |
significant enrichment for the endosomal-vacuolar pathway ($p = 8.14E-11$), an enrichment that was replicated in gene sets that were predicted to be downregulated ($p = 3.24E-8$). Our results broadly recapitulated results above, even after excluding genes in HLA and chr17 inversion regions from the enrichment analysis of the gene set ($p < 0.05$) (Table 2, Suppl. Table S9).
**Quantitative expression validation analysis**
Expression levels of *ARID3B*, *CD276*, *INSYN1*, *LOXL1*, *NEO1*, *SCAMP2*, *STOML1* and *UBL7* were measured in XFS ($N = 12$) and control ($N = 19$) eye tissues. We selected iris tissue because it is one of the tissues that are part of the anterior segment structures bathed by aqueous humor and upon which the flaky XFS materials are deposited [3–5]. Other affected structures include the trabecular meshwork, lens capsule, ciliary body, zonules and corneal endothelium [3–5]. All transcript levels were found to be decreased in iris tissues obtained from XFS patients compared to control samples, with significant differences for *ARID3B*, *CD276*, *LOXL1*, *NEO1*, *SCAMP2* and *UBL7* ($p < 0.05$) (Fig. 3). *INSYN1* and *STOML1* were not significantly downregulated in diseased eyes relative to normal eyes in validation analysis. *STOML1* is the closest gene to and potentially proxy for *LOXL1* among those that show association in our PrediXcan results within the chr15q22–25 region. We included it as a negative control in the validation analysis, while *LOXL1* was a positive control considering that it had already been shown to exhibit pattern of downregulation in gene expression in diseased relative to normal tissues [36]. *CD276* was selected for functional validation in eye tissue despite no significant association with XFS in single-tissue analysis in the European ancestry data because it was significantly associated with XFS in multi-tissue analysis in European data. In addition, it was one of the gene associations signals which were not affected by excluding variants that were in LD with *LOXL1/STOML1* model SNPs in the multi-ethnic global dataset. Overall, our validation results replicate the associations found using the genetically determined gene expression.
**Comorbidity/pleiotropy analysis**
To gain further biological insights into the gene associations we observed in our PrediXcan analysis, we performed logistic regression analysis of both XFS ICD9/10 diagnosis, and Polygenic Risk Score generated from the multi-ethnic summary data across the BioVU individuals, Vanderbilt University’s electronic health records database linked to genetic information, as the target dataset (Materials and Methods). XFS diagnosis was associated with an increased risk of 96 phenotypes in BioVU, including 12 musculoskeletal phenotypes, 4 infectious diseases, and 1 cardiovascular phenotype. These results are consistent with higher comorbidity of diseases affecting inflammation, connective tissue, and the circulatory system in individuals with XFS (Suppl. Fig. S6a, Suppl. Table S10a).
**Fig. 3** Expression of *NEO1*, *CD276*, *INSYN1*, *LOXL1*, *STOML1*, *UBL7*, *ARID3B* and *SCAMP2* mRNA in iris tissues derived from normal human donors (control) ($n = 19$) and donors with XFS syndrome ($n = 12$) using real-time PCR technology. Expression levels were reduced in XFS specimens compared to control specimens, with significant differences for *NEO1*, *CD276*, *LOXL1*, *UBL7*, *ARID3B* and *SCAMP2*. The relative expression levels were normalized relative to GAPDH and are represented as mean values ± SD (*$p < 0.05$; **$p < 0.01$, ***$p < 0.001$*)
XFS polygenic score was not significantly associated with any phenotypes in the analysis (Suppl. Fig. S6b). This potentially indicated that PRS generated from the global multi-ethnic GWAS summary might not be powered to detect association with traits in the EHR, and we might require scores from a more homogeneous and a much larger sample size. However, among the top PRS associations, we found several inflammatory diseases (Suppl. Table S10b), consistent with the enrichment results reported above.
**Discussion**
We performed gene-based association analysis using GWAS summary statistics and conducted extensive statistical validation of genes associated with XFS. From our PrediXcan analysis, we identified 35 associated genes with XFS, 23 in single-tissue analysis and the rest in multi-tissue analysis. To eliminate the possibility of false-positive results due to LD contamination, we performed extensive additional analyses. First, we performed PrediXcan analysis in reduced models removing variants in LD with the two *LOXL1* missense variants associated with XFS, and variants in *LOXL1/STOML1* models in both global multiethnic and a subset of European ancestry individuals. Secondly, we conducted conditional analysis of the significant signals in European ancestry individuals. Thirdly, we then filtered signals based on correlated gene expression, LD and shared eQTLs and confirmed thirteen genes to be associated with XFS. Finally, expression analysis in human iris tissues further confirmed six of these seven signals, which were significantly downregulated in diseased XFS relative to normal eye tissues: *ARID3B*, *CD276*, *LOXL1*, *NEO1*, *SCAMP2* and *UBL7*.
Our results suggest potentially substantial roles of inflammation and environment in the etiology of XFS. All the six genes prioritized here by prediction and extensive validation analyses have inflammatory roles. *ARID3B*, *CD276*, *LOXL1* and *NEO1* are immunoregulatory molecules involved in the interaction between different tumors and the immune system [49–52]. *SCAMP2* is important in granule exocytosis, a process crucial in membrane fusion in normal cellular functions in diverse systems including the immune system’s inflammatory response [53–55]. *CD276* is involved in regulation of Ag-specific T cell-mediated immune responses and participates in the innate immunity-associated inflammatory response [56, 57]. *LOXL1* has also been implicated in fibrosis in response to inflammation in human breast cancer [36], in liver and lungs in model animals [36, 36, 36]. *UBL7* encodes a member of the ubiquitin protein family, that is crucial in immune response and regulation of inflammatory response [58–60].
Genes that show significant association of predicted expression with XFS at nominal significance are enriched for genes associated with three inflammatory conditions: rheumatoid arthritis, Type 1 diabetes and vitiligo in the Jensen Diseases database, with genes associated with the former two conditions enriched even with HLA region excluded. This is also consistent with the enrichment we find in DSigDB and DrugBank for cyclosporin A, acetaminophen and quercetin, which are compounds that have anti-inflammatory effects [61].
Enrichment of predicted genes in this study in the polyunsaturated fatty acid (PUFA) and steroid derivatives: protectin (Reactome), omega fatty acid and estrogen (WikiPathways) are also consistent with the potential role of inflammation in XFS. Protectin, a derivative of PUFA including Omega-3 that are major components of fish oil, has an anti-inflammatory, anti-amyloidogenic, and anti-apoptotic activities in human neural cells [36, 62, 63]. Omega fatty acid has been suggested as an IOP reducing supplement [36, 64, 65] because of its anti-inflammatory effects [66]. Association of steroid derivative estrogen with glaucoma has been previously explored with higher levels of estrogen in reduction in IOP and conferring a possible reduced risk of glaucoma [67]. The synthetic form of estrogen, estradiol, has been shown in a rat glaucoma model to inhibit optic nerve axonal degeneration by inducing a protein that is crucial in protecting RGC from oxidative damage [68, 69].
The association with inflammation is consistent with studies in limited numbers of XFS patients that found elevated inflammatory markers relative to controls, including cytokines, and markers such as interleukin-6 (*IL-6*) and *IL-8* [70, 71], tumor necrosis factor-α (*TNF-α*) and *YKL-40* [72, 73]. However, there are conflicting results for high sensitivity C-reactive protein [74, 75].
In addition, the XFS gene sets are enriched for genes that map to variants implicated in coffee and caffeine intake. Effects of caffeine consumption in the etiology of XFS have been studied, on the premise that coffee consumption increases plasma homocysteine levels that are speculated to enhance XFS material formation by contributing to vascular damage, oxidative stress, and extracellular matrix alterations [36, 76–78]. Consumption of coffee has been reported to have both pro- and anti-inflammatory effects [79]. However, review of fifteen studies on the effect of coffee and caffeine on inflammation inferred the former had anti-inflammatory action, while the latter had complex effects on the inflammatory response with both proinflammatory and anti-inflammatory responses reported [36]. Caffeine might have a neuroprotective role by regulating pathways that produce inflammatory molecules via adenosine receptors in brain cells [80, 81]. Posttranscriptional regulation of LOXL1
gene expression has been also shown to be modulated by caffeine [82].
Globally, our results of the six novel functionally validated genes also confirm the role of connective tissue involvement in the etiology of XFS. Aung, et al. [36], demonstrated the role of haplotypes that carry *LOXL1* XFS causal coding variants in upregulating extracellular matrix components such as elastin and fibrillin, and increasing cell-cell adhesion. In addition, two of the novel genes in our study, *ARID3B* and *NEO1*, among the other six genes identified and validated in both studies, have adhesive roles in the body. *ARID3B* in conjunction with *FDZ5* protein increases adhesion to ECM components, collagen IV, fibronectin and vitronectin, that are components of exfoliation deposits [83, 84]. *NEO1* has also been shown to play adhesive role during organogenesis [85].
Results from our enrichment analysis of genes associated with XFS are also consistent with a role of dysregulation in connective tissue metabolism in the etiology of XFS. Cylopssorin A regulate *lysyl oxidase* expression and collagen metabolism probably by inhibiting an isomerase involved in protein folding [36, 86, 87]. Other anti-inflammatory compounds identified from our enrichment analysis in the current study, epigallocatechin gallate, valproic acid, quercetin, ketoconazole and acetaminophen have also been shown to suppress collagen and/or are anti-fibrotic in variety of tissues by yet to be elucidated mechanism [88–92]. Moreover, coffee and caffeine inhibit collagen expression and deposition, and have anti-fibrotic effects by blocking expressions and/or by modulating effects of profibrotic factors [93–96].
Our results that show enrichment in crosslinking of collagen fibrils, a crucial constituent of connective tissues, and endosomal-vacuolar Reactome pathways, in our associated genes further confirm the importance of connective tissues in the etiology of XFS. In addition, there may be anomalies in an endosomal-vacuolar pathway shown to be involved in the accumulation of other aberrant proteins, including: Aβ peptides [97], prion [98], and Huntingtin [99] in neurons, and implicated in neurodegeneration. Moreover, inflammation has also been suggested in migratory failure and subsequent deposition of aberrant proteinaceous materials in affected tissues in conjunction with other molecular actors [71, 100–105].
Finally, our comorbidity analysis in the BioVU EHR indicated XFS association with several chronic inflammatory dermatological, musculo-skeletal, respiratory, and infectious conditions. Moreover, extracellular matrix dysregulation is also suggested by our PheWAS results indicating XFS comorbidity with Vitamin D deficiency. Vitamin D regulate collagen cross-linking in vitro by upregulating gene expression of specific lysyl hydrogense and oxidase enzymes [36].
**Limitations of the study**
This study has two main limitations. First, even though GTEx data for the 48 tissues represent the most comprehensive eQTL data set of human tissues, it does not constitute a complete representation of all human tissues and may fail to identify the real causal genes in the unsampled ocular tissue. However, we have confirmed from an ocular tissue database that novel signals identified in this study are robustly expressed in XFS relevant eye tissues. Moreover, recent analysis shows that the majority of the human body tissues exhibit higher degrees of tissue similarities [106]. In addition, it has been shown that most complex conditions, including XFS, might actually manifest in many diverse tissues in the body [106].
Second, only a third of the signals identified in the larger data were robustly confirmed in a European dataset at genome-wide significance. This raised the possibility that most of the initial signals identified an artefact of local LD leakage or shared eQTLs with the sentinel *LOXL1/STOML1* signal. Using statistical validation with reduced models including no SNPs in LD with sentinel variants, we confirmed associations independent of *LOXL1* for at least ten genes including seven that were experimentally validated. In addition, results from a recent study are consistent with two other association gene signals confirmed using multi-tissue analysis of European dataset and PrediXcan of reduced models in multi-ethnic global data, *ISLR2* and *STRA6* [29]. *ISLR2* and *STRA6* are both significantly downregulated in tissues of XFS patients together with other key components of the *STRA6* receptor-driven Retinoic acid (RA) signaling pathway, and that siRNA-mediated downregulation of RA signaling induces upregulation of *LOXL1* and XFS-associated matrix genes in XFS-relevant cell types [29]. These data indicate that dysregulation of *STRA6* and impaired retinoid metabolism are involved in the pathophysiology of XFS syndrome. Retinoic acid, the active metabolite involved in the signaling pathway implicated by Berner et al. [29] in XFS through regulation of *ISLR2, STRA6* and *LOXL1*, has been shown to control critical checkpoints in inflammation and to promote an inflammatory environment [107–109].
**Conclusions**
Our analysis of predicted gene expression and extensive functional analysis in eye tissue prioritized six genes in association with XFS. Our results further confirmed the role of connective tissues and highlighted the importance of inflammation in the etiology of XFS. Thus, molecular elements that underlie the interaction of connective tissue biosynthesis and inflammatory pathways may play a central role in the etiology of XFS. Targeting the
inflammatory pathway may be a potential therapeutic option to reduce progression in XFS.
**Materials and methods**
We used an extension of PrediXcan [36] that uses GWAS summary statistics, S-PrediXcan [11], to analyze GWAS summary statistical data from a multi-ethnic GWAS study on XFS [36]. This dataset consisted of 13,620 XFS cases and 109,837 controls. We also performed PrediXcan on individual-level genetic data from two independent datasets comprising 4127 cases and 9075 controls. The first dataset comprised case and control samples from two cohorts of European ancestry (from Germany and Italy). The second dataset comprised adult patients of European ancestry at Vanderbilt University Medical Center (VUMC) from the local communities surrounding Nashville, TN. The BioVU cases and controls were genotyped on five different Illumina genotyping arrays; Human660W-Quad, HumanOmni1-Quad, Infinium Omni5–4, OmniExpress-8v1–2-B and Infinium Multi-Ethnic Global-8 (MEGA). The data was processed using established GWAS quality control procedures [8] and imputed on the Michigan Imputation server. Details on how subject selection for BioVU data and genotyping was performed is found in extended materials and methods section (Supplemental Information, Suppl. Fig. S1, S2).
**Statistical analysis**
We used the gene-based method, PrediXcan, that provides a framework for correlating imputed gene expression with phenotype [9]. Gene expression prediction models for 48 different human tissues were trained using GTEx ver. 8 data, subsampled to use only the European ancestry samples. Models with non-zero weights that met a set significance criterion \((r > 0.10, q < 0.05)\) were retained [31]. Given the lack of eye tissue in the GTEx data, we performed PrediXcan analysis in all available tissues to leverage the shared regulatory architecture of gene expression across tissues [110]. We referred to the association analysis in each tissue between predicted expression and XFS as “single-tissue analysis.” Because XFS is considered a systemic disorder, we also aggregated evidence across the different tissues to improve our ability to prioritize genes relative to a single unrelated tissue. We determined the joint effects of gene expression variation predicted across all 48 tissues using the Multi-Tissue PrediXcan (MultiXcan), a multivariate regression method that integrates evidence across multiple tissues taking into account the correlation between the tissues [32, 34]. We refer to this association analysis as “multi-tissue analysis.”
We used S-PrediXcan [36] to analyze GWAS summary statistic data from the multi-ethnic study of Aung, et al. [36]. Since the summary-based method has been shown to be conservative and tends to underestimate significance in cases where there is some linkage disequilibrium-structure mismatch between reference and study cohorts [36], we retained and reported S-PrediXcan results that had a univariate S-PrediXcan \(P < 0.0001\). We used Bonferroni adjustment for multiple hypothesis testing. Genome-wide significance for a gene-level association in single-tissue and multi-tissue PrediXcan analysis were defined as \(p < 2.02e-7\) and \(p < 3.02e-6\), respectively.
**Conditional analysis and linkage disequilibrium evaluation**
To determine whether multiple association signals within the same locus are due to independent causal genes or statistical artefacts of correlation in measured expression and predicted gene expression for adjacent genes [35], we examined the correlation in the gene expression among genome-wide significant genes in the reference GTEx data. We assumed that there is concordance in correlation in measured and predicted gene expressions, but depending on the quality of our predictions, correlation in predicted expression for a pair of genes may be missed. We verified the extent of LD in the 1000 genomes database [111, 112] between variants in the prediction models for significantly associated genes in each tissue.
To measure potential regulatory effects of the two classical *LOXL1* missense variants in our PrediXcan analysis, we excluded them and all the variants in our gene models that were in LD with them (defined as pairwise \(r^2 > 0.1\)) to generate “reduced models.” We predicted gene expression and performed association analysis using reduced models in both the global multiethnic and the European subset for the genes in chromosome 15 region. To assess whether the association signals in the chr15q22–25 region for each tissue are independent of the ‘classical’ *LOXL1* signal, we excluded variants in the prediction models of genes in the region that were in LD (pairwise \(r^2 > 0.1\)) with any variant in the *LOXL1* model. In tissues without a *LOXL1* model (i.e., \(r^2 > 0.10, q < 0.05\)), we excluded variants for chr15q22–25 region genes that were in LD (\(r^2 > 0.1\)) with variants in the *STOML1* models. In addition, we excluded variants that were shared between prediction models for genes in the region. In each case, we performed association analysis using the reduced models and compared the results with the original models.
To determine whether additional genes within the region were significantly associated with XFS, independently of the most highly associated genes (*LOXL1* and *STOML1*) identified in the primary analysis, we performed conditional analysis using ancestrally ‘homogenous’ individual-level genotype data that included our BioVU cohort and a subset of Aung,
et al. consisting of three European ancestry cohorts. For each tissue with a significant association, the conditional analysis was performed on the gene that was the most statistically significant as identified from the initial PrediXcan analysis. We generated genetically determined expression for each individual in the dataset and then performed association analysis using Genetic Association Analysis Under Complex Survey Sampling (SUGEN: version 8.8) [113] on the individual imputed gene expression data, including age, sex, first 5 principal components and relatedness in the regression model. A new logistic regression model was then fit to the case-control data by sequentially adjusting for the expression data of the top significant signals as a covariate. We then performed a meta-analysis for the PrediXcan summary statistics from the four datasets. We repeated this procedure until no genes in the region attained our threshold for statistical significance in the tissues tested (<0.05/total # of e-genes x # of tissues tested for each top round of tests).
**Enrichment and pathway analysis**
Genes that were predicted to be associated with XFS at genome-wide significance in both single-tissue and multi-tissue analysis, and at nominal significance ($p < 0.05$) in single-tissue analysis were checked for enrichment of particular categories in several databases using the web-based enrichment tools, Enrichr [40, 41]. This was done by using the strongest signal at nominal significance across the 48 tissues for each of the genes analyzed in PrediXcan. Enrichr implements Fisher’s exact test and uses over 100 gene set libraries to compute enrichment [40]. We also performed rank-based Gene Set Enrichment Analysis (GSEA) using another web-based enrichment tool, Webgestalt [114–117] with a more recent database (Gene Ontology January 2019, KEGG Release 88.2, Reactome ver.66 September 2018 and PANTHER v3.6.1 Jan 2018) and the current Reactome database ver. 69 (June 12 2019) [118]. In this case the strongest signal in the PrediXcan result across the 48 tissues for each of the genes analyzed was used. Based on previous studies indicating limitation in accurately quantifying expression effects of variants in highly polymorphic regions [119, 120], we also performed enrichment analysis after excluding a total of 310 genes in ~6Mb chromosomes 6 HLA region (hg19 28Mb–34Mb) that encompassed $GPX6 – CUTA$ genes (238 genes) and ~2.5Mb chromosome 17 region that encompassed $CCDC43 – NPPEPS$ that include the 900kb inversion common in population of European ancestries (72 genes).
**Quantitative expression validation analysis**
**Human tissues**
Human donor eyes from European ancestry individuals used for corneal transplantation were processed within 20 hours after death with appropriate research consent obtained from the donors or from relatives for those who are deceased [29]. The procedure of the study was approved by the Ethics Committee of the Medical Faculty of the Friedrich-Alexander-Universität Erlangen-Nürnberg (No. 4218-CH) and consistent with the tenets of the Declaration of Helsinki [29].
For RNA and DNA extractions, 12 donor eyes with manifest XFS syndrome (mean age, 77 ± 9 years) and 19 normal-appearing control eyes without any known ocular disease (mean age, 74 ± 6 years) were used. All XFS tissues donors were previously confirmed XFS patients based on routine ophthalmologic examination after pupillary dilation. The presence of characteristic XFS material deposits was assessed by macroscopic inspection of anterior segment structures and confirmed by electron microscopic analysis of small tissue sectors. Iris tissues were prepared under a dissecting microscope and frozen rapidly in liquid nitrogen.
**Real-time PCR**
For quantitative real-time PCR, iris tissues ($N = 31$, 12 XFS and 19 control eyes) were extracted using the Precellys 24 homogenizer and lysing kit (Bertin, Montigny-le-Bretonneux, France) together with the AllPrep DNA/RNA kit (Qiagen, Hilden, Germany) according to the manufacturer’s instructions including an on-column DNaseI digestion step using the RNase-free DNase Set (Qiagen). First-strand cDNA synthesis and PCR reaction was performed as previously described [36]. Exon-spanning primers (Eurofins Genomics, Ebersberg, Germany), designed with Primer 3 software ([http://bioinfo.ut.ee/primer3/](http://bioinfo.ut.ee/primer3/)), are summarized in Suppl. Table S1. Quantitative real-time PCR was performed using the CFX Connect thermal cycler and software (Bio-Rad Laboratories, München, Germany). Probes were run in parallel and analysed with the $\Delta \Delta Ct$ method. Averaged data represent at least three biological replicates. Unique binding was determined with UCSC BLAST search ([https://genome.ucsc.edu/](https://genome.ucsc.edu/)) and amplification specificity was checked using melt curve, agarose gel and sequence analyses with the Prism 3100 DNA-sequencer (Applied Biosystems, Foster City, CA). For normalization of gene expression levels, mRNA ratios relative to the house-keeping gene GAPDH were calculated.
Group comparisons were performed using a Mann-Whitney U test using SPSS v.20 software (IBM, Ehningen, Germany). $P<0.05$ was considered statistically significant.
**Testing for comorbidity/pleiotropy**
To determine the comprehensive health consequences of high genetic risk to XFS, we performed a phenotype-wide association analysis (PheWAS) [121]. First, we examined the comorbidity of other phenocodes with XFS (365.5 – ICD9 365.52/ICD10 H40.14xx) in a total of 752,024 individuals in the VUMC EHR (418,371 females and 333,653 males), by performing logistic regression analysis conditioned on gender, age and the self-reported ancestry as covariates in the regression model. For this analysis we used a total of 600,107 European, 103,209 African, 12,411 Asian and 36,297 other ancestry patients, of which 222 were uncared XFS cases (coded as 1) and the rest controls. To determine other health consequences of high genetic risk to XFS, we performed a PheWAS analysis [30] ($n=52,251$) on the polygenic risk score generated from the Aung et al.’s. [36] XFS global dataset against patients genotyped on Illumina Mega-array chip in BioVU with about 18k ICD-9 /ICD-10 codes, accounting for age, gender, and the first 5 principal components.
**Abbreviations**
| Abbreviation | Description |
|--------------|-------------|
| XFS | Exfoliation syndrome |
| GWAS | Genome-wide association study |
| TWAS | Transcriptomic Wide Association Studies |
| LD | Linkage Disequilibrium |
| eQTL | expression quantitative trait locus |
| DNA | Deoxyribonucleic acid |
| RNA | Ribonucleic acid |
| mRNA | Messenger RNA |
| MEGA | Multi-Ethnic Global Array |
| GTEx | The Genotype-Tissue Expression project |
| MultiXcan | Multi-Tissue PrediXcan |
| SLGEN | Genetic Association Analysis Under Complex Survey Sampling |
| GSEA | Gene Set Enrichment Analysis |
| EHR | Electronic Health Record |
| PheWAS | phenotype-wide association analysis |
| PCR | Polymerase Chain Reactions |
| PUFA | polyunsaturated fatty acid |
| IOP | Intra-Ocular Pressure |
**Supplementary Information**
The online version contains supplementary material available at https://doi.org/10.1186/s12864-023-09179-7.
**Additional file 1.**
**Acknowledgements**
We are grateful to Maria Niarchoou and Tyne Fleming for comments on earlier version of the manuscript.
**Authors’ contributions**
JH, NJC and ERG jointly conceived the project. AR, USS, DB and FP managed patients’ data and tissues’ samples of the three European cohorts. AR, USS, DB and FP conducted functional biological experiments. FP contributed raw genotyping data for European populations. JH performed all the statistical analysis. JS, RT, PSS, AIK, MAB1, PE & PP helped scripts and statistical analysis. JH, RT, KJ, NJC, ERG, MAB2, FP & CCK were involved in interpretation of data. JH drafted the manuscript with critical input from KJ, NJC, ERG, FP & CCK. The manuscript was also critiqued and approved by all authors. NJC was responsible for obtaining financial support for this study.
**Funding**
JH was jointly supported through grant to MAB2 (T32 grant ST32EY021453), ERG and NJC.
ERG is grateful to the President and Fellows of Clare Hall, University of Cambridge for the fellowship support. ERG is also supported by a NIH Genomic Innovator Award (R35HG010718). The content is solely the responsibility of the authors and does not necessarily represent the official views of the National Institutes of Health.
KMI – Joseph Ellis Family and William Black Research Funds, NEI Core Grant 6P3OEY08126 to Vanderbilt Vision Research Center, Unrestricted Departmental Grant from Research to Prevent Blindness, Inc., NY.
The European-Data-Set was support by the Interdisciplinary Center for Clinical Research (IZKF) at the University Hospital of the University of Erlangen-Nuremberg (project E23) to AR and USS and the Deutsche Forschungsgemeinschaft (SCHL 366/8-1) to USS.
The funding bodies played no role in the design of the study and collection, analysis, and interpretation of data and in writing the manuscript.
**Availability of data and materials**
Multi-ethnic Summary data can be obtained from https://www.nature.com/articles/ng.3875
European subset summary data obtained from the link on this study.
Other important Links for additional data and models:
https://github.com/gamazonlab/MR-ITI for links to predxcan models.
https://ftp.1000genomes.ebi.ac.uk/vol1/ftp/phase3/
https://www.ebi.ac.uk/gwas/
https://gtexportal.org/home/
**Declarations**
**Ethics approval and consent to participate**
Informed consent to tissue donation was obtained from the donors or from relatives for those who are deceased. The protocol of the study was approved by the Ethics Committee of the Medical Faculty of the Friedrich-Alexander-Universität Erlangen-Nürnberg (No. 42.18-CH) and adhered to the tenets of the Declaration of Helsinki for experiments involving human tissues and samples.
**Consent for publication**
N/A.
**Competing interests**
ERG receives an honorarium from the journal *Circulation Research* of the American Heart Association, as a member of the Editorial Board. The remaining authors declare no competing interests.
**Author details**
1Genetic Medicine, Vanderbilt University School of Medicine, Nashville, TN 37232, USA. 2Vanderbilt Genetics Institute, Nashville, TN 37232, USA. 3Institute of Human Genetics, Friedrich-Alexander-Universität Erlangen-Nürnberg FAU, 91054 Erlangen, Germany. 4Clare Hall and MRC Epidemiology Unit, University of Cambridge, Cambridge CB2 0SL, UK. 5Vanderbilt Eye Institute, Vanderbilt University Medical Center, Nashville, TN 37232, USA. 6Department of Ophthalmology, Universitätsklinikum Erlangen, Friedrich-Alexander-Universität Erlangen-Nürnberg, 91054 Erlangen, Germany. 7Biostatistics, Vanderbilt University School of Medicine, Nashville, TN 37232, USA. 8Genome Institute of Singapore, 60 Biopolis St, Singapore 138672, Singapore.
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TKTS
Biden cements support for Israel (pg. 2)
Global halloween traditions and history (pg. 6)
Kelce and Swift romance leads to uptick in NFL viewership (pg. 16)
Inglewood Bird Sanctuary reopens after multimillion-dollar upgrade
James Windler
Staff Writer
After a year of work, the Inglewood Bird Sanctuary has fully reopened to the public.
Work began in 2022 after a collaboration between the City of Calgary’s Infrastructure Services, Operational Services and Public Art program.
When it was all said and done the Inglewood Bird Sanctuary received $9.7 million in upgraded park amenities with $750,000 coming from the Government of Alberta’s Watershed Resiliency and Restoration Program and Environment and Climate Change Canada’s Environmental Damages Fund, with the other $9 million coming from the City of Calgary.
As of Oct. 16, Calgarians can enjoy the finished product which integrates habitat and water channel restoration with functional art.
Rene Letourneau, senior projects engineer in the Utilities Delivery Business Unit at the City of Calgary took over project management in spring 2022 after a colleague went on maternity leave.
Ward 9 Councillor Gian-Carlo Carra said that the area has been beloved by Calgarians and visitors for over 80 years and the new upgrades will ensure the continued vibrancy of the park into the next 80 years and beyond.
Functional art
Johnathan Slaney, planning engineer of the reconnection project, touched on the importance of bringing in an artist in the development stages as it helped breathe new life into an important area for the city.
“Having an artist embedded early on in the project really helps to improve the project overall,” said Slaney. “Engineers like to think in straight lines and a lot of nature doesn’t work that way.”
Over the span of three years, artist Tim Knowles collaborated closely with a team comprising of engineers, hydrologists, and naturalists to contribute to the planning of a novel route for connecting the Bow River to the lagoon.
More than a bridge
Additionally, he helped design the pedestrian bridge installed at the sanctuary.
Letourneau was happy to have Knowles involved in the development of the pedestrian bridge as it is important to the Inglewood Bird Sanctuary as a whole.
“We built a pedestrian bridge and it basically does three things; it connects the trails for the public to walk around the sanctuary, secondly, it’s basically a troll for how much flow we want to go down into the lagoon, because we don’t want too much water flowing through there, and thirdly, it’s a public art component,” said Letourneau.
The public can now head down and check at the new improvements of the Inglewood Bird Sanctuary which is located at 2425 9 Ave. SE.
The $9.7 million in renovations include natural barriers, a new Logjam, erosion improvements, and more. Photo by James Windler
U.S. supports Israel in conflict
Matthew Hillier
Staff Writer
Hamas is the militant group that ousted Palestinian Authority from Gaza in 2007. Photo courtesy of Dana Bondarenko and Sergey Gavrillo/Wikimedia Commons
U.S. President Joe Biden visited Israel on Oct. 18 to discuss new changes to the humanitarian corridor to Gaza as well as aid to Palestinians in Gaza and on the West Bank.
However, this was not solely a diplomatic mission of aid. This trip also included a promise to look into allocating congressional funds for Israel’s military to fight against the militant group Hamas.
Biden is now considering a request for an expected supplemental spending of $100 billion, which will go to Israel, Ukraine and Taiwan.
According to Reuters, Israel has requested close to $10 billion from this spending package on top of the $3.6 billion it receives from the U.S. every year as part of an agreement struck between the two in 2016.
Israel and the U.S. have had a close diplomatic relationship for years, however, there is doubt on the authenticity of the motives of both Biden and the Prime Minister of Israel, Benjamin Netanyahu.
Historic conflict
To understand the conflict between Israel and Palestine, Duane Bratt, a political science professor at Mount Royal University, says it started back in 1948.
Following WWII, the Balfour Declaration of 1917 was revisited by Great Britain to establish an Arab state and Jewish state. Arab countries rejected this and attacked Israel, however Israel won the war and went further to take over Palestinian lands.
For almost 60 years Israelis have held the land, despite being threatened in ’73.
Continued from Pg.3
and ‘82. Additionally, the UN has condemned it and has referred to the land as occupied territories.
Flash forward to 2006, Bratt said that Israel wanted to move out of the West Bank and Gaza Strip on the condition that the Palestinian people hold an election. This resulted in the election of Hamas which then turned into a dictatorship and periodic attacks against Israel from 2006 until present day.
“What was different about the Oct. 7 attack was just the scale of the rockets, but more importantly they busted through the wall that Israel had and they already had tunnels underneath [which allowed] the direct attack on civilians and taking them as hostage” said Bratt.
In response to the Hamas attack, Israel has retaliated with attacks against Hamas and Palestinian people.
Hospital bombing
A day before Biden’s visit to Al-Ahli Baptist Hospital, the building was bombed resulting in the death of hundreds of Palestinians. As well, there was an increase in attacks from Israel against targets in Gaza.
According to CNN, both sides are not claiming responsibility for the bombing of the hospital. Many in Gaza are stating that Israel bombed the hospital with little to no warning, while Israel states that a misfired Hamas rocket was responsible for the attack.
According to AP News, Biden solidified the U.S.’s response to this bombing with this statement on Oct. 18: “Based on what I’ve seen, it appears as though it was done by the other team, not you.”
Bratt said this support from Biden is no surprise as the U.S. has been a firm ally of Israel since its creation.
“What Biden is doing is no different than what any other American president would do,” he said. “[The U.S.] is the largest military donor and the strongest ally the Israelis have.”
This support allows U.S. leverage, however Israel does not have to listen. Netanyahu and previous leaders have autonomy away from the U.S., but the U.S. still needs to support them.
“What we’re hearing publicly is that there is no separation between the American and the Israelis,” Bratt said. “Behind the scenes privately, American officials are urging restraint of the Israelis, because they’re worried about the consequences of a humanitarian disaster in Gaza and the potential of this spreading into a wider war involving Lebanon or Iran.”
With Israel currently blockading food, water and power from Gaza, the alleged involvement of Israel in this bombing has seen public opinion turn in the wake of this crisis.
Protesting Biden
According to Gallup, Democrats are showing more support for Palestine with 49 per cent in support versus 38 per cent against. As well, only 34 per cent of Americans aged 18-39 now believe that Hamas is solely responsible for the ongoing crisis.
Various campus protests condemning the actions of Israel during this crisis have also sprung up across the West. Hundreds of supporters from both sides showed up at Columbia University on Thursday, Oct. 19, which resulted in the New York campus being temporarily closed for public access.
Humanitarian aid from the U.S. was delivered to Gaza over the weekend in a 20 truck convoy, says the U.S. secretary of state in a press release on Oct. 21—an additional $100 million in aid is promised from President Biden in the coming weeks or months. Biden also took the time to state that U.S. soldiers will not lend active military support to Israel at this time.
Regardless of where the responsibility lies for the hospital bombing and the overall crisis, it’s clear that the U.S. has and will back Israel at least politically and economically.
Hope’s Cradle: A second chance
Gurleen Jassal
Contributor
Hope’s Cradle will open in January at the Children’s Cottage Society’s new family centre. Photo courtesy of Jordan Guilford
Hope’s Cradle is an organization based in Calgary and it’s offering mothers in difficult circumstances a safe place to give up their newborns, acting as a lifeline. This initiative will be up and running in January 2024, being the first safe surrender site for Calgary.
The facility will be at Children’s Cottage Society’s new centre which is located in the neighbourhood of Montgomery in northwest Calgary.
Jordan Guilford is an individual who has a strong desire to help underprivileged women. Initially she started as a CEO at Gems for Gems, a jewelry drive for women that were survivors of domestic abuse.
As part of the leadership team for Hope’s Cradle, she has been instrumental in creating a program that gives moms in difficult situations a safe and considerate way to give up their babies. Guilford has a commitment to making sure every kid gets the chance to flourish and receives the care they need.
During this initiative a program called Thrive was launched. The program was able to award scholarships to women as a way for survivors to attend trade schools and be on their own feet in a year’s worth of time.
As the pandemic hit, Guilford wanted to change her gears and help create an initiative that helped safe surrender for babies.
“We launched in 2021, in Strathmore, Alberta, and one in Ontario and Manitoba as well,” says Guilford. “January 2024, is when the Children’s Cottage [Society] will be operational.”
Hope’s Cradle at the Children’s Cottage Society is a building with a door to provide safe surrender for a child. The cradle has no cameras and allows a mother to safely surrender her child in a bassinet. Once the child is placed, a silent alarm is sounded for staff to come collect the baby.
The surrender site not only gives babies a new chance at life, but also some careful care instructions for the mother.
“There’s an envelope for her in there, which she will take and in the envelope there are postnatal physical and mental health resources,” Guilford explains. “There’s also a guided letter for the mother to be able to write her final words to the baby.”
Additionally, there is a medical form for the mother to fill out any medical history from her side or the father’s side.
After filling out the forms and letter, the envelope can be mailed to the location of the surrender with the prepaid postage provided.
After the baby is placed and is safely in the care of Hope’s Cradle, the staff will collect the baby.
The alarm will also notify first responders, allowing an ambulance to come take the baby to the hospital. The baby will go through hospital procedures; including a check for sexual assault and abuse. Shortly after the infant will be placed for adoption.
Hope’s Cradle helps mothers in need provide a safe environment for their children. The initiative aspires to provide a better, brighter future, making a lasting effect for women in the community.
When people think of sustainability, ideas of climate activism, environmental change, or alternative energy sources come to mind.
However, Mount Royal University’s (MRU) 2023 Sustainability Forum looked at tourism, finance, student life, education, marketing, podcasting, media, aviation, Indigenous practices, and relationships with nature, just to name a few. Known as the largest event on campus, the Sustainability Forum served as a platform of knowledge and education for students and faculty.
On Oct. 18, MRU became a haven of sustainability.
Speakers from MRU, the University of Calgary, and Tec de Monterrey, a post-secondary school in Mexico, came together to share and explore their ideas on modern-day sustainability.
**Indigenous lens**
Regarding environmental sustainability, Dion Simon of the Cree First Nations Maskwacis Treaty 6, spoke about relationship to land, and brought forth an Indigenous perspective on environmental sustainability.
One of Simon’s themes was the seven sacred teachings: love—to be in harmony with the world around us, respect, honor, truth, wisdom, courage and humility.
Simon’s biggest lesson to the audience was to “Leave something for the next day,” to move on course with nature’s speed, and to have the courage to maintain, control and discipline ourselves with the land and creation.
In addition to environmental sustainability, an online presentation by Guillermo Hernández—all the way from Mexico—brought light to sustainable financing, specifically in middle-income countries.
**Sustainability in media**
Meg Wilcox, a communications professor at MRU and co-director of the *Community Podcast Initiative*, spoke about creating a strong and equitable media landscape and promoting and protecting the environment through education.
Wilcox touched on the three main challenges in sustainable media: trust, diversity and fragmentation. Her work with the *Canadian Mountain Podcast* has also put a spotlight on Indigenous information and voices.
Wilcox was invited to speak at the forum, which inspired her to speak about sustainability and the media.
“When I first heard about the forum, I thought it would be an important and much-needed event on campus—and the podcasting work that *Canadian Mountain Podcast* team has been working on fits in well with the topic of sustainability,” Wilcox says.
**Student Changemaker Network**
One of the largest themes spanning throughout the majority of the speaker’s talks was the 17 Sustainable Development Goals, which was created by the United Nations.
For those interested in student sustainability, the Student Changemaker Network (SCN) club at MRU is a representative body for students to create “social and environmental change” and advocate for sustainability. The SCN used the 17 Sustainable Development Goals in their presentation, as well as their three missions: educate, enable and enact.
Different worldviews such as culture, gender, age and experience are presented when creating a sustainable environment at MRU.
Students can join the SCN to create positive change and promote communication to raise awareness about environmental sustainability. Students are encouraged to go online and present a sustainable proposal to the SCN. In addition, the SCN also hosts events and movie nights.
For those interested in student involvement with sustainability at MRU, the SCN member signup form can be found at their Linktree bio on their Instagram page, @scn.mru.
As the clock of human history continues ticking, the spotlight shifts onto a new set of cast on stage. Since the years 1997 and 2012 the spotlight was on Generation Z, individuals who are now on the cusp of adulthood. Now they must look to the centre-left stage and bear witness to their replacements: enter Generation Alpha, born between the years 2013 and 2024.
Born in 2002, I entered North America post-9/11, an era of constant fear. Because of this, previous generations loved setting expectations for us, hoping we would grow up to change our world. And soon enough, I was having the same thoughts for the generation replacing me. I wanted to delve deeper into this phenomenon with people my age. How will our world change once the younger generation pull up their pants? What is Generation Z expecting from Generation Alpha?
**Social media**
Meet Hana Baya and Mikaela Olpindo, two Gen Z Mount Royal University (MRU) sociology majors. They both specialize and have experience in studying human cultures and societal evolution.
We sat with our Booster Juice in hand and I asked what they think Gen Alpha’s relationship to social media will look like.
Baya puts in her two cents. “Do you remember those family vlogging channels? When you’d have a nuclear family of two parents constantly shoving a camera in their childrens’ faces. Those kids were generally Gen Alpha, right? They are the ones whose faces and bodies are forever left on the internet for everyone to see. They didn’t even know this was happening, they’re getting a taste of being a spectacle without their consent.”
And isn’t that terrible? Gen Z is the first generation to bear witness to a new phenomenon of children being the pride and soul for society’s online entertainment. We’ve seen it occur for decades before, but now that any adult can instantly hit ‘record’ on their smartphone, the world can now receive an influx of media ‘starring’ somebody’s kids, for anyone to see and use. However, what implications may this have on these kids as they grow to become young adults?
We turned to Olpindo, as she had something to say, “These kids are going to live with a new form of trauma. So when they grow older, privacy and security is going to be incredibly important to them. We’re seeing that happen right now in Gen Z and millennials, when you look at cybersecurity and the VPN industry.”
She continues, “The way TikToks are generally made in our generation, is that they place the camera in front of their face, for the world to see. Maybe in the future, this won’t be how Gen Alpha handles online entertainment. Maybe they will revolutionize a new social media platform where everyone can stay anonymous, and do and say whatever they want without the repercussions of their actions. Maybe privacy is going to be a form of currency. And this can be good, and terribly bad for too many reasons.”
**Socialization**
I sipped my Booster Juice as I took in their opinions and speculations; so far incredibly enlightening. Then I asked what their opinions are regarding possible societal expectations of Gen Alpha.
Baya starts, “Well if Gen Alpha grew up with their devices, they aren’t gonna know a life without it. Taking it away might not be possible anymore. Meaning, that we could see Gen Alpha’s networking ability and socialization completely digital. For example, my sister is Gen Alpha, and she’s very knowledgeable about the world. But she doesn’t usually leave the house except to go to school, but she’s still very conscious of everything that happens.”
Olpindo seconds Baya’s experience, “My youngest brother is also Gen Alpha, and he’s really sweet. I’ve noticed that he has much more of a balance with his relationships. And I wonder how he’s been influenced as such, maybe he was just on that side of TikTok that is slowly changing the way that he sees other people around him.”
She continues, “We are socialized by our parents and guardians, but our primary socialization comes from teachers or classmates. Our socialization takes place in the classroom. And so if you put the two concepts we talked about together, does that mean that we’re moving into school online? I don’t know!”
Baya: “I mean, we’ve seen this happen with COVID.”
Olpindo: “And it was good for some kids, and worse for others.”
Baya: “You mean, good for some Gen Alphas, and worse from some Gen Zs.”
After the interview had settled, they showed me photos of their younger siblings. We scrolled through, and I looked back at the elder sisters looking at the photos. In their eyes, you can see a strain of concern, twinkle and excitement as they have the privilege to watch their little understudies replace them at the centre stage of society.
Mexican-Canadian director continues to rise in Calgary theatre
James Windler
Staff Writer
Javier Vilalta is riding high after a successful directorial debut at Calgary’s Vertigo Theatre.
Vilalta watched on as people packed into Vertigo Theatre Thursday night to see *The Strange Case of Dr. Jekyll & Mr. Hyde*.
Vilalta was overwhelmed with the positive response from the audience as the performers were showered with applause at the end of the play.
The success that Vilalta has achieved didn’t happen overnight – it has been a long hard journey after immigrating from Mexico to Canada years ago to pursue his lifelong dream.
“So, I’m originally from Mexico City, and I moved to Calgary to take a fine arts major and drama at the University of Calgary, and after graduating, I started working in Calgary as a director,” said Vilalta.
“Having this opportunity in this theatre can allow me to branch out to other places, hopefully in Calgary, or Canada to continue doing specific text-based theatre.”
Vilalta has made his way through Calgary theatre directing multiple different genres.
He credited Calgary’s great theatre scene as a major reason why he’s been able to achieve success as it has enabled him to find his unique voice as a director, which he says is key when sharpening your skills.
“If you try to approach your artistry like everyone else, you’re just going to get lost in the mix; but if you find your own authentic voice, then people will understand where your artistry comes from and when they have a project that is right for you, then they will know that you are the right person for that job,” said Vilalta.
Vilalta’s journey has been difficult, but he wouldn’t trade it for anything; his drive to make a splash in the Calgary theatre scene as a Mexican-Canadian is unparalleled.
“I feel like if you’re really passionate about what you do, you’re gonna do whatever it takes to get to where you want to be,” he said.
“Because of my background, I didn’t see a lot of people like me out there, so I had to start trailblazing a little bit and say, I’m not going to lose this opportunity.”
The performance of *The Strange Case of Dr. Jekyll & Mr. Hyde* will continue to play at the Vertigo Theatre until Oct. 29; information on showtimes and tickets can be found on the Vertigo Theatre website.
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A Haunted History
Halloween’s roots and rituals around the world
Emma Marshall
Staff Writer
When you think of Halloween, what comes to your mind first? Is it the candy, the costumes, or the scary movie marathons? This is what western Halloween is boiled down to today. However, the history of this holiday has been interpreted in different ways throughout the years.
The origin of this day traces back to the lives of ancient Celtics in various parts of Europe around 2,500 years ago. Many academics have agreed that Halloween can be connected to their ancient festival, Samhain, which was celebrated at the end of every harvest season. Ancient Celts believed that the barriers between worlds were broken down during this time, and they would sacrifice cattle, light bonfires, and dress in animal skins as a way to maintain peace with the gods.
After Christian influence took over pagan communities, Samhain was rebranded to ‘All Hallows Eve’ and shared many of the former pagan traditions. This holiday was introduced to America by early Irish immigrants who brought their traditions across seas. From there, Halloween was made into what it is today in parts of Europe and North America. With costumes to ward off spirits, sweet treats in celebration of bounty and jack-o-lanterns to light the night, it is one of the most widely celebrated holidays in western culture.
Similarly, in Latin America and Spain, on Oct. 31 kids will go trick-or-treating, but not for the same reasons as Americans. This trick-or-treating is to prepare for el Día de los Muertos, or Day of the Dead, which is a holiday that takes place on Nov. 1 and 2. It is believed that the barrier between worlds dissolves on this
Making the most out of a concert
Tips for audience members before and during the show
Emma Duke
Features Editor
If you’ve been dying to know what my bank statements look like (which, I don’t know why you would...that’s weird, but no judgment), I’ll tell you. Ticketmaster. Groceries. Ticketmaster. Ticketmaster. TAYLOR SWIFT TICKETS! No, that does not have any relevance to the article, I just wanted to share that I made it through *The Great War*.
Rather than spending money on clothes, or going to the bar, I spend my money on concerts. From Ed Sheeran and NF to Milky Chance and The Lumineers to Daniel Caesar, Gregory Alan Isakov and Imagine Dragons, I’ve had the privilege of attending a lot of concerts. I’ve probably attended 20 in the last six or seven years, so you could say I consider myself a sort of concert-connoisseur. I know what makes a fantastic concert and what distinguishes a good performer from a great one, but I also have a couple of tips on how to make the concert more enjoyable as an audience member.
My first rule-to-live-by is to be careful picking your seat. Cheap tickets are lovely, but remember that you get what you’re paying for, and I don’t mean in terms of the view (the huge TV’s allow you to see the artist, no matter where you’re seated), but in terms of energy. The further back the seat, the less excited the crowd is about the artist, so unless it’s Taylor Swift, there’s a chance that if you’re not on the floor or an adjacent section, the people around you might be sitting down. Not that you couldn’t have fun being the only one standing up and screaming lyrics, but it’s much more enjoyable to be at a concert where the people around you are also energized and excited, so it’s often worth it to pay a little more to sit closer.
We’re all a little guilty of filming the artist singing a bunch of songs, just for them to sit in our camera roll until we realize three years later that the five minute videos are taking up too much space. My advice is this: take videos of yourself and your friends at the concert, rather than the artist. There is already footage of the artist performing live circulating the internet, but videos of you are unique and much more special.
Lastly, if prices are high for a concert, wait until the day of the concert and then look for a ticket. People reselling will often sell for lower than what they paid. I wouldn’t recommend doing this for an artist you love (it’s not worth the risk), but it’s a good idea for a concert you think would be worth attending, if ticket prices dropped.
Now, go buy that concert ticket!
Continued from Pg.6
day and loved ones are able to reconnect with the deceased.
It is largely misconceived that el Día de los Muertos is a Latin version of Halloween, and while there are similarities, the origin and practices are not the same. This holiday is celebrated to show respect for lost loved ones, and people often wear traditional makeup and outfits — parading, singing, dancing and even making offerings.
The themes of death and afterlife can be seen in many other interpretations of this holiday. In Guatemala, Barriletes Gigantes, also known as ‘giant kites festival’, takes place at the beginning of November. Hand-painted kites are flown over the graves of loved ones as a way to connect the living and the dead.
As one of the oldest celebrated holidays, Halloween is recognized globally as a time to reconnect with deceased loved ones and protect one another from spirits of the afterlife.
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THURSDAY’S GOT TALENT!
West Gate Social
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Let’s get musical!
Live music, karaoke, and open mics!
Visit us online for event dates & times
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LOST & FOUND
Lost something on campus? Found an item?
The SAMRU Lost & Found is here to help!
☑️ Lost items: Visit SAMRU Reception in room Z222,
call 403-440-6077, or email firstname.lastname@example.org.
☑️ Found items: Drop off in the 24-hour drop box
located next to MRU Security at West Gate.
Calgary rock event gives local bands the limelight they deserve
Bella Coco
Contributor
Rockin’ 4 Dollars started as a local rock event in Halifax. Now, over 15 years later, it has transformed into a beloved weekly local tradition for the Calgary music scene.
BJ Downey, hailing from New Brunswick, came across Rockin’ 4 Dollars when he attended art school in Halifax. Posters were plastered throughout the city and the advertisement ultimately piqued Downey’s interest.
“The poster was like ‘rock for dollars, win a thousand bucks, play a 15-minute set, backline provided, I’m like, ‘what? This sounds insane,’” says Downey. “I would go there and if you played, you got a free pitcher of beer and it was just the thing to do in the city on a Monday.”
Downey fell in love. Planning to move in 2012, he asked the co-founders if he could start doing the event in Calgary on Wednesdays. After receiving their blessing, Rockin’ 4 Dollars in Calgary was born.
“Now, they’ve since quit that. So they’ve handed over everything. I have the name. Everything is now mine,” Downey says.
In the beginning, Rockin’ 4 Dollars was at Broken City on 11th Avenue, and it cost $3 cash to get in. Now, nine years later, Broken City has since been transformed into Modern Love and it is $5 cash to get in.
For $5, audience members get to hear up to eight bands play a 15-minute set each. Bands can win up to $1,000 on Rockin’ 4 Dollars unique wheel of prizes, which is spun at the end of the night.
Since the beginning, Rockin’ 4 Dollars has advertised the occasional themed night. The themes range from bands playing covers of Green Day, Blink-182, or Britney Spears. But out of all the themes, Downey says that the most popular by far is Emo Night.
“Usually the theme nights take off when we announce Emo Night, Green Day, Blink-182 or Nirvana. Nirvana is another good one. We announce and bam…the list is full within 24 hours,” Downey said.
While numerous bands from various backgrounds come to play at Rockin’ 4 Dollars, regulars have their fan favorites. Wack, Astrocaster, and Neon Detour are just a few local gems, and their attendance at Rockin’ 4 Dollars always provides a surge of audience members and a rowdy crowd.
Downey says that one of the biggest things he has learned since starting Rockin’ 4 Dollars is that bands don’t always know what is going on when they sign up to play. Some bring all of their gear, but at Rockin’ 4 Dollars, a full instrumental set isn’t necessary.
“We provide the drums. Just bring your guitars, your cables, your drumsticks, and your pedals. That’s all you need,” says Downey.
While Downey has created and curated an incredible local music scene, he has also worked hard at building a warm and welcoming environment at Rockin’ 4 Dollars.
While a good amount of bands play their first show at Rockin’ 4 Dollars, Downey says that the environment is very low-stress and has a familial atmosphere. For instance, the hockey lineup is when audience members, either dancing, sitting, or chatting, gather near the front of the stage and form two single file lines. Facing each other, the audience sticks out their hands and the performing band runs through to high-five the crowd. It is a true Rockin’ 4 Dollars tradition, as Downey explains at the beginning of every Wednesday night.
“If you’re feeling down, if you don’t know anybody in the city, and if you’re interested in learning about bands that are in the Calgary music scene, no doubt, Rockin’ 4 Dollars is 100 per cent the place to dip your toes,” Downey says.
The Even Odds plays an energetic set, on Oct. 18, 2023. Photo by Bella Coco
Screamfest
Canada’s largest Halloween event has returned to Calgary and features games, creepy entertainment, and must-see haunted houses. Screamfest runs from Oct. 6 to the 31. Tickets are available on the Screamfest website.
Haunted house Party
Show off your costume, win a prize, enjoy live music, and take advantage of the photo booth at West Gate Social’s Haunted House Party on Oct. 26. Doors open at 8 p.m.
Gimme Gimme Disco
Calling all ABBA fans! The Palace Theatre is hosting another Gimme Gimme Disco night on Nov. 10 at 10 p.m. This is an 18+ event and tickets can be found on the Palace Theatre Event page.
Portugal. The Man
The band known for the catchy songs “Feel It Still” and “Live in the Moment” are hitting the stage at the Grey Eagle Event Centre on Nov. 8. Grab tickets on the Grey Eagle website under the event centre tab.
A reflection on the themes of grief in this horror-comedy
Warning: contains spoilers about the film Haunted Mansion
Isabella West
Arts Editor
When a mother and son move to New Orleans for a fresh start, their excitement quickly turns to fear once they discover that their new house is filled with unwanted guests who won’t let them leave.
The 2023 film, *Haunted Mansion*, directed by Justin Simien, is a horror-comedy based on the attraction, The Haunted Mansion, located at Disneyland, the Magic Kingdom, and Tokyo Disneyland.
“I came into this with a bunch of things that I just knew I needed to see as a fan of the ride,” said Simien in an Instagram reel.
The movie features iconic references to the ride such as the stretching room, the hitch-hiking ghosts, and my personal favourite, Madame Leota.
“I wanted to be really faithful to the ride. There’s a lot of brilliant storytelling and inspiration there. You get the sense that there’s this much bigger world, a galaxy of characters from every era,” said Simien in the same Instagram reel.
However, while this movie brings audiences in with the notion that it will allow them to relive a Disneyland experience, it holds much deeper themes than that.
The film opens with a flashback scene to when Ben Matthias, played by LaKeith Stanfield, meets Alyssa, his future wife at a New Year’s Eve party. The scene then flashes back to Ben’s current reality where he is now a disgruntled man doing a job he has no passion for.
When Ben met Alyssa, he was an astrophysicist studying a formula to map dark matter, or to Alyssa, he was trying to see the unseen. At that time, Alyssa was hosting ghost tours around New Orleans with the intention of helping people see things that they can’t always see. Ben then later takes on the same job that Alyssa held.
However, when a woman, Gabbie, and her son, Travis, move to their new house, they find out that it is haunted and once they enter, they must always return to the house after midnight or else they will face terrible hauntings.
Because of his known ghost-hunting experience, Ben is recruited to take on the job of expelling these ghosts from the house. After a full team of ‘experts’ is recruited to get to the core of the mystery that will reveal why the house is haunted, the team quickly becomes allies and dependent on each other.
It is later revealed that Ben unexpectedly lost his wife and spent years believing in ghosts and searching for ways to connect with her one last time but was never able to. Travis also had recently unexpectedly lost his father and was trying to find ways to cope with the loss.
Once these two are brought together, their journey of grief is consistently tested by needing to decide to either move on from the past or succumb to their pain.
Although this film is categorized as a horror-comedy, I was personally touched by the exploration of grief.
I unexpectedly lost my grandmother in 2021 and I’m still trying to find ways to cope with the loss. My grandma helped raise me. She was one of my closest friends, the person I’d turn to for advice, the one who helped me get into university, and most of all, she was my family’s glue. After I lost her, I felt like there was no place for me in a world without her. Everything seemed a lot less exciting and a lot more painful.
At one point in the film, Travis is about to go be with his dad, because a ghost is pretending to be him but is stopped by Ben. Ben tells Travis that his dad would want him to be happy and live a full life but Travis quickly says “nowhere feels right without him.”
I found this quote to be impactful because grief is such an unusual thing. It can come in waves, hit you all at once, or for some, take years to sit in. But the thing that strikes me the most is how you don’t simply overcome your grief, but rather you learn how to live with it.
Going into this movie, I was expecting a remake of the 2003 lighthearted and children-friendly *The Haunted Mansion*. However, my expectations were quickly shut down within the first 10 minutes of the film. Although it was not what I was expecting, I was surprisingly grateful for my experience. This horror-comedy had me crying, laughing, scared, and questioning my own journey through grief.
At the end of the film, all of the characters are confronted by the antagonist who is constantly speaking to Ben and Travis as they are grieving, trying to convince them that they will never be able to overcome their pain and that they’d be better off ‘reunited’ with their lost loved ones. I think that this character could reflect the negative thoughts that many who are grieving can often experience. But the message that is driven home in the film is that one’s grief does not become them and I think that is one of the most important reminders to hold dear.
Pumpkins After Dark: carving dreams into reality
Emma Marshall
Staff Writer
When the sun goes down in October, Calgary lights up with a haunting jack-o-lantern display, but the Halloween spirit is not found in the pumpkins, but rather in those who carve them.
Three years ago, Lantern Events Inc. and Pumpkins After Dark Ltd. collaborated to host the first Pumpkins After Dark. With these production companies focused on supporting local businesses, boosting the economy, and having a positive impact on the community, it quickly became a must-see Halloween event.
In 2020, the management team at Pumpkins After Dark released a Facebook post that called all community members who had an interest in Halloween and pumpkin carving for potential hire. For Mike Innis, applying for the position was a no-brainer.
Innis, alongside the other artists who got hired, Kelly Schaffner, Carlos Roche, and Julian Lee, have worked every year together at Pumpkins After Dark. The four of them quickly became a team and they plan on returning as the live carvers at this event for the foreseeable future.
“It’s a really positive experience and it’s a great community. It’s nice to see other people get as excited about something I am enthusiastic about,” said Schaffner. Obviously, they’re paying me to do it, but it doesn’t feel like a job. It just feels like a lot of fun.”
While it only comes around once a year, this exhibit takes 12 months to prepare. Innis explained that the design, carving, and set-up of the walk-through display happens throughout the year by a team of skilled professionals. “I keep seeing it evolve, there’s more and more excitement about it,” said Innis. “We look forward to seeing how it grows and to being a part of that Calgary October tradition.”
Their job is not to create the walk-through displays, but rather to carve intricate designs on pumpkins and interact with patrons of the event. This includes explaining their process, the tools they are using, and even the lore behind jack-o-lanterns.
“Stingy Jack is an old Irish story of a man who was cheap,” explained Innis. “The devil gave him a hollowed-out turnip with coal to light his way through the darkness, so that is why we make jack-o-lanterns. It’s to ward off Jack and guide those other lost souls.”
The long-anticipated eighth solo studio album and 13th album overall from Canada’s most popular current artist, Drake, finally arrived at the beginning of October. Titled *For All The Dogs* (FATD) and represented by an album cover designed by Drake’s son, Adonis, debuted at #1 on the *Billboard* 200 Chart. With his release, Drake became the first rapper to have their first eight albums all rank #1, tied Michael Jackson for most #1’s by a male soloist, and now has the most #1 projects this century.
With features like J. Cole, SZA, 21 Savage, Teezo Touchdown, SexyxRed, and Lil Yachty, along with the near-perfect production that we have come to expect from every Drake project, FATD hit all the right spots sonically. There are slow songs that will have listeners reminiscing about heartbreak, like “Bahamas Promises,” energetic bangers like “First Person Shooter,” and glowing songs that can light up the gloomiest of days, like “What Would Pluto Do?” Adonis, Drake’s son, even makes an appearance with a snippet from his first song, “My Man Freestyle,” coming at the end of “Daylight.” Overall, it’s a versatile album filled with emotions and themes that make it an essential addition to your playlist.
— Zafir Nagji
Doja Cat’s fourth studio album sees her take a more heavily rap-based form, straying away from the playful aesthetic that helped her rise to fame and back into her bag of tricks as a rapper. This is also her first album with no features, an important milestone in many rappers’ careers.
Doja Cat’s “Paint The Town Red” opens the album with glowing production and a happy tone, before transitioning to the distorted trap banger, “Demons.” Her high-pitched vocals add a unique dimension to some of the darker beats on this album, which makes her music so much more satisfying to listen to. She uses great wordplay on tracks like “Wet Vagina,” where she claims to have “drip,” a clever pun that hopefully needs no further explanation. She then transitions into a more low-key middle section, full of bubbly, gentle vocals that can remind listeners of her wildly successful album, *Planet Her*, before picking up energy towards the end again. Most importantly, Doja Cat proved that her versatility as a rapper and singer works well enough to sustain a 17-track featureless album that keeps listeners engaged from start to finish.
—Zafir Nagji
A haunted evening of classics
Emma Marshall
Staff Writer
This Halloween season, get ready to immerse yourself in a multi-sensory experience like no other.
Fever, the leading global entertainment discovery platform, is expanding its portfolio for the Candlelight concert series in Calgary, and they are inviting locals to embrace the enchantment of the season through multiple unique Halloween concerts on Oct. 28.
In the heart of Calgary, the Grace Presbyterian Church is being transformed into a hauntingly beautiful setting for these events, brought to life by the soft, flickering glow of thousands of candles.
“The experience is lived in venues that are noted for their historic nature or unique character to the city,” said Eloisa Marenco Alvarez, communications specialist at Fever. “Our production team studies each venue in detail in order to decorate the environment in the best possible way. Candles are carefully placed to create the warm atmosphere that characterizes Candlelight Concerts and, particularly for Halloween, candles are complemented with the typical Halloween decorations to give it a special look and feel.”
This year, they have taken inspiration from the soundtracks of many classic Halloween favourites, including *Ghostbusters*, *Beetlejuice*, *The Addams Family*, and *The Exorcist*.
Whether you are a fan of the macabre, or simply looking to embrace the spirit of Halloween, these concerts promise an unforgettable experience for viewers of all ages.
However, Candlelight Concerts are about more than just the music. They are a part of the original music series by Fever with the goal of making classical music more accessible to audiences all over the world by creating candlelit performances in various historic locations.
“With the musicians speaking directly to guests, the connection with the artists and the music is much stronger,” said Alvarez. “We are always hiring talented local musicians who align with our belief that classical music can reach a diverse audience and demonstrate this by performing compositions for all tastes.”
To check out the full range of shows and to purchase tickets, check out the Fever website, and get ready for an enchanting evening of haunting melodies in the glow of thousands of candles.
Concert setup for a Halloween special in Madrid, Spain. Photo courtesy of the Fever website
Raptors exhibition game projects future success for team
Tyson Biever
Contributor
Preseason Perfection
The Toronto Raptors’ preseason is off to a great start, as the team has quickly jumped out to a perfect, 3-0 record that stands atop the Eastern Conference standings. Their latest triumph was a tough 106-102 victory over former-Raptor, Demar DeRozan and his team, the Chicago Bulls.
While the Raptors meeting with the Bulls on Oct. 17 was the team’s most recent outing, their first preseason game was held on Oct. 8 against the Sacramento Kings in Vancouver. The Raptors would go on to win, 112-99.
Raptors head coach, Darko Rajakovic, wasted no time in playing his top players as the team’s starting lineup in their first preseason game consisted of small forwards O.G. Anunoby and Scottie Barnes, power forward Pascal Siakam, point guard Dennis Schroder and centre Jakob Poeltl.
The Raptors followed up their win over the Kings with a friendly exhibition match against Australian team, the Cairns Taipans. The Taipans are one of 10 teams that participate in the National Basketball League (NBL)—Australia and New Zealand’s professional basketball associations.
With the level of worldwide talent the Raptors have on their roster, the NBA team dominated in a blowout victory over the NBL team—a final of 134-93.
In their opening three games, there’s a lot to like about this season’s roster.
For starters, new recruit Dennis Schroder playing in the starting point guard position seems to be working so far. Last season, Schroder averaged 30.1 minutes per game with the Los Angeles Lakers while racking up 830 points over a span of 66 games played.
Shooting guard Gary Trent Jr. is doing well in his new role as a ‘super substitute’ too. The move was done in the hopes that Trent Jr. can make important plays off the bench.
Enter Darko
It was an offseason full of changes for the Raptors as several moves were made after the team lost in the play-in round last season.
Most notably, the Raptors made a massive coaching change, firing head coach of five years, Nick Nurse, and replacing him with Darko Rajakovic — a former assistant coach of the Oklahoma City Thunder. Nick Nurse went on to become the latest head coach for the Philadelphia 76ers.
Since his hiring, it seems that Rajakovic plans on helping the Raptors improve on both offence and defence by teaching the team to focus on their decision-making process. Personally, I’d recommend that the team avoid passing the ball when their teammates are contested by an opposing guard as too many times it was intercepted and led to the other team scoring last year.
Despite this being Rajakovic’s first time as a head coach in the NBA, his players have already admitted that their new coach is doing really well. Part of the reasoning being, Rajakovic already acts like a veteran coach and excels at listening to what his players have to say.
Meet the Crew
Not even the Raptors roster was spared during the annual offseason shuffle.
Former Raptor point guard Fred VanVleet departed from the team after signing a three-year deal with the Houston Rockets, while German-star Dennis Schroder along with 13th-overall pick in the 2023 NBA Draft, Gradey Dick, joined the club.
Dick, a small forward and shooting guard, has been called a sharpshooter by many. Wearing number ‘1’ on the court, the rookie is keen to do whatever his team and coaches want from him and has promised to work hard on his training — that is, if he isn’t busy filming cameos in Drake’s latest music videos!
Along with the new recruits is returning player Scottie Barnes. Drafted fourth overall in the 2021 NBA Draft, Barnes took the league by storm almost immediately. In 2022, the first-round pick was named the NBA Rookie of the Year and is already entering his third season with the team. NBA basketball player by day and Subway ambassador by night, Barnes switches between power forward and small forward positions for the Raptors and averaged 15.3 points a game during the 2022-23 season.
Let’s not count out Pascal Siakam, either. Siakam, who was drafted by the Raptors in 2016, is an NBA all-star that averaged 24.2 points per game for the team last season. And, now that the previous rumors hinting that Toronto could be trading Siakam have quieted down, there might be a better chance that he may sign another contract with the Raptors at the end of this season.
Great preseason in hand, the Raptors are a young team who will be very interesting to watch. The team’s season-opening game will be held on Wednesday, Oct. 25 where they will host the Minnesota Timberwolves.
Cougars basketball set for success in 2023-24 season
Zafir Nagji
Staff Writer
In 2022, the Mount Royal Cougars men’s and women’s basketball programs had impressive regular seasons followed by heartbreaking losses in their play-in games. This year though, the Cougars are looking to make a splash in their Canada West conference while contending for two U SPORTS basketball titles.
During the 2022-23 season, the Cougars women’s basketball team managed to balance a fast-paced style of play by taking care of the ball. However, they really shined on the defensive end where they averaged significantly more steals and blocks than their opponents.
Their home record of 8-2 was astounding, but like so many young teams in a variety of sports they struggled on the road — posting a record of 3-7 away from their home court and ended their season with a play-in loss on the road against the University of Winnipeg Wesmen.
“Playing at home is definitely an energy thing for all of us,” third-year guard Abbey Wilkinson said.
“It’s much easier to build off of when you have the soccer team come out banging the drums and all your families come out, so it’s a much more welcoming environment versus being on the road, which is definitely tougher.”
Wilkinson, who made the third most three-point shots on the team last season, was one of 73 Cougars to win the 2022-23 U SPORTS Academic All-Canadian Award. Passionate about the game of basketball, she strongly believes in the roster the women’s program will be putting on the hardwood this season.
Mount Royal’s women’s team is depending on their veteran core of fourth- and fifth-year student-athletes to lead their rookie-less roster of second- and third-year players into battle.
Their level of experience and chemistry gives the Cougars a serious chance to win every night and Wilkinson believes the team should aim to make a deep run for the 2023-24 Canada West and U SPORTS National Championship titles.
“We definitely are looking ahead to try to finish in the final four or better,” she said.
“We have an advantage with our depth.”
Mount Royal University’s men’s basketball team also ended their season in the same place as the women’s team, losing in the play-in game after a regular season that left room for improvement.
All but six players on the 2022-23 roster were rookies, so the men’s team also struggled to find wins on the road but excelled at home. The fresh-faced roster finished with a record of 6-4 at home, but 2-8 on the road. However, the highlight of last year came in the form of a breakout season for guard Holt Tomie. His numbers steadily improved in each of his three years with the Cougars, yet, his greatest season by far was in 2022-23 — averaging a career-high of 23 points-per-game and five...
Mount Royal University’s (MRU) volleyball teams opened a new chapter in their programs’ history last weekend when they began their regular seasons on the road in B.C. Facing off against the University of British Columbia (UBC), the two programs got off to a rocky start. While the men’s team opened up their weekend with a 3-2 win over the Thunderbirds, the B.C. team enacted their revenge the next evening — handing the Cougars a 3-1 loss on Saturday night. The women’s program faced even tougher results as they failed to win a set all weekend, losing both of their matchups against UBC by an identical, 3-0, score.
Now, the two teams will head back to MRU’s Kenyon Court as they get prepared for their home-opening match against the UBC Okanagan Heat (UBCO) on Friday, Oct. 27.
With each team only having completed their opening weekend of games, much is still unknown about how the rest of the regular season will bode in their respective leagues. However, if last season is of any indication, both programs will be hunting for a collection of victories along with a title or two.
At the end of the 2022-23 regular season, the men’s and women’s programs boasted an impressive and identical record of 19-5, including second-place finishes in the Canada West regular season standings.
Albeit, their playoff performances weren’t so similar.
The women’s program claimed a spot in the Canada West Championship, taking home a second-place finish after a subsequent loss to the Trinity Western Spartans. While slightly disappointed about being the runners-up in the playoffs, the finish was enough to grant them entrance into the season-culminating U SPORTS National Championship for the second consecutive year. And, despite being a crew riddled with injuries, the women’s program mustered up a fifth-place, consolation title at the country-wide tournament.
For fifth-year setter Sarah McKillican, her second experience at the National Championships was one that she will always remember — no matter the result.
“I’m from B.C., so going to play at [the University of British Columbia] was so awesome. All my family was able to come out and watch,” said McKillican.
“We always talk about, ‘it’s the memories that you make during the process. It’s not about the games that you win or lose, we don’t remember that longer term. We remember the memories and stuff.’ So, I think that’s the main thing that we were focusing on. Like, yeah, it sucks that we lost our quarterfinal, but we made the most of it and we enjoyed our time [at the National Championship].”
A third-straight trip to the National Championship isn’t out of the question for McKillican and her team, either. While the team isn’t too stressed about finding wins and positive results immediately, they do understand what it takes to nab a spot in the tournament.
“There’s so many teams that are deserving to go, but I think since we’ve been there the last couple years, we know how much we want it, so that helps us,” shared McKillican.
“We got these goals to make it to nationals and hopefully we just keep growing throughout the year and make it there.”
With long-time players, Maddy Marshall, Quinn Pelland, Haley Roe and Nyadholi Thokbhuom graduating over the offseason, this year’s Cougars team will look at its list of returning players and new recruits to step up and fill in the recently-open gaps.
“I’m so excited for this group of girls,” smiled McKillican.
“I’ve been very impressed with everybody. Everyone’s so hardworking [and] driven. Everyone just wants to get better and prove themselves.”
Inversely, the second-seeded, men’s program dealt with a tougher blow during their post-season push. The team bowed out in the first-round of the Canada West playoffs, following a series-sweep at the hands of their Crowchild Trail rivals, the University of Calgary Dinos.
For fifth-year business student and middle blocker Luis Lange, his team became too focused on the wider scope of their previous season instead of following a weekend-to-weekend approach.
“I think we put a lot of focus into our regular season, which I don’t think we should miss out on again this year. But the playoffs [are] the team that’s better that weekend, not necessarily overall.”
And, in a similar fashion to the women’s program goals and expectations, Lange believes a trip to the nationals is also very achievable for the men’s team.
“This is arguably the most open the league has been since I’ve been here and there’s going to be a lot of good competition every weekend,” Lange said.
“As a team, we’ve definitely established that we want to be playing for a national championship this year.”
The skill of Lange and his cohort hasn’t gone unnoticed. Prior to the season-opening weekend, the annual Canada West preseason coaches poll listed the Cougars as the second-best team among Western Canada institutions — just four points behind the University of Alberta Golden Bears.
But the preseason rankings haven’t changed anything in the team’s perspective. For them results always trump the rankings.
“I think it’s a nice pat on the back, but that’s kind of how all I take it,” he said.
“This league is so competitive that any weekend, any team can beat another team. It’s a very competitive league for that reason. That’s why I love playing here. So, again, pat on the back but [the poll] doesn’t mean much to me or the team.”
On Friday, Oct. 27 and Saturday, Oct. 28, the men’s and women’s team will take to the Kenyon Court to host the UBCO Heat in their home-opening weekend.
Sarah McKillican and her teammates hit the court at Mount Royal before heading to Vancouver for their weekend series with the UBC Thunderbirds. Photo by Matt DeMille
Why, in your wildest dreams, has the NFL seen a rise in female viewership?
Khaoula Choual
Contributor
The internet’s favourite couple, Taylor Swift and Travis Kelce, are taking over the National Football League (NFL), whether you like it or not.
The famed romance between the two high-profile stars first began when Kelce, a tight end for the Kansas City Chiefs, attended Swift’s Eras Tour show at the Chiefs’ home field, Arrowhead Stadium in Kansas City, Missouri. During the show, Kelce fumbled his first effort at courting Swift with his attempt to offer the singer a friendship bracelet with his phone number on it failed.
“I was disappointed that she doesn’t talk before or after her shows because she has to save her voice for the 44 songs that she sings,” Kelce said in his shared podcast with brother Jason, New Heights.
Kelce further admitted to his brother that he was “butthurt” after being denied an opportunity to connect with Swift at the concert.
However, Kelce would only need to wait a few months for Swift to finally notice him. On Sept. 24, Swift returned the favour to Kelce by attending the Chiefs’ football game against the Chicago Bears at Arrowhead Stadium — sending ‘Swifties’ and football fans spiraling.
Swift’s rumored romance with the two-time, Super Bowl champion has led to a spark of interest among her ‘Swifties’ and the female demographic regarding both Kelce and the Chiefs.
As Swift and Kelce’s relationship blossomed in the public eye, jersey sales for Kelce’s uniform also increased by nearly 400 per cent, according to the Associated Press.
Meanwhile, the week after Swift made her first appearance at Arrowhead Stadium, the Chiefs hit the road for a game against the New York Jets. For the second-straight week, Swift along with other pop culture stars, including actors Ryan Reynolds and Hugh Jackman, were in attendance for the Chiefs’ game in New York City’s MetLife Stadium. Her appearance at the game led to an explosion of views, as 27 million people tuned into the game. The feat made it the most watched Sunday show since the Super Bowl, last February.
According to the CBC, the Sunday night game between the Chiefs and Jets was the most streamed NFL regular season game ever.
With a spike in female viewership exceeding two million, Swift’s participation undoubtedly contributed to the broadcast’s record figures and creating an atmosphere that essentially exceeded the game itself.
However, not all football fans have been vibing with the constant mention of Swift during Chiefs games. In response to the NFL panning back to Swift on 17 different occasions during her visit to MetLife Stadium, even Kelce had something to say about the increased coverage.
“I think it’s fun when they show who all is at the game,” Kelce admitted to his brother on their podcast.
“I think it brings a little bit more to the atmosphere, brings a little bit more to what you’re watching. But at the same time, they’re overdoing it a little bit for sure.”
In response, the NFL politely clapped back by defending their decision to overload their media with coverage on both the Chiefs and Swift.
“We frequently change our bios and profile imagery based on what’s happening in and around our games, as well as culturally,” an NFL spokesperson shared with PEOPLE magazine.
“The Taylor Swift and Travis Kelce news has been a pop cultural moment we’ve leaned into in real time, as it’s an intersection of sport and entertainment, and we’ve seen an incredible amount of positivity around the sport.”
So, it seems that as long as Travis Kelce and Taylor Swift stay a pair and the NFL remains interested in taking advantage of their fling, the disgruntled football audience will be forced to swallow their ‘Bad Blood’ if they plan on continuing to watch the Kansas City Chiefs hit the field.
|
• Tax Pro Account Overview
• Online Account Overview
Note: No personal taxpayer data is used for this presentation. All data shown is an example of what taxpayers and tax professionals may see.
Tax Pro Account
Submit Power of Attorney and Tax Information Authorizations
You have these options to submit Power of Attorney (POA) and Tax Information Authorization (TIA). Find more about [Power of Attorney and other authorizations](#).
**Use Tax Pro Account**
Submit authorization request to taxpayer's online account.
- All-digital submission
- Electronic signature
- Real-time processing
Use for:
- Individual taxpayer with online account
- Limited tax matters and periods
- Prior authorizations revoked for same tax matters or periods
[Use Tax Pro Account]
**Submit Forms Online**
Submit Forms 2848 and 8821 online to the IRS.
- Secure form upload
- Electronic or handwritten signature
- First-in, first-out processing
Use for:
- Individual or business taxpayer
- Any tax matter or period
- Prior authorizations retained or revoked
[Submit Forms Online]
**Fax or Mail Forms 2848 and 8821**
If you can't use an online option, you can fax or mail authorization forms to us.
- Paper forms by fax or mail
- Handwritten signature only
- First-in, first-out processing
Expansion of Taxpayer Options for 3rd Party Authorizations launched in the summer of 2021
- Added “authorization” feature to individual Online Accounts.
- Launched Tax Pro Account on IRS.gov to allow tax professionals to initiate online POA or TIA requests.
- Tax professional initiates a POA or TIA, uses checkbox as electronic signature for POAs.
- POA or TIA requests automatically transfers to individual taxpayer’s Online Account.
- Taxpayer accesses their Online Account and under the “Authorization” tab they can approve the request and use a checkbox as signature.
- Upon approval, authorization is posted immediately to CAF.
To use Tax Pro Account, individuals must create an account and verify their identity.
- Individuals already registered for Secure Access (e.g., Get Transcript, e-Services) can use the Tax Pro Account to initiate POAs and TIAs.
- New users will need to create an account with ID.me.
- To verify your identity with ID.me, you will need a photo ID and a device with a camera.
- Frequently asked questions with help links are available right on the sign-in page for Tax Pro Account & Online Account in case you or your clients have any questions.
Tax Pro Account: Tax Professionals Page
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Online tools for tax professionals
PTIN System
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Request Power of Attorney or Tax Information Authorization
Review options to submit power of attorney (POA) or tax information authorization (TIA). Choose from Tax Pro Account, Submit Forms 2848 and 8821 Online, or forms by fax or mail.
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E-Services, Tax Pro Account, EINs, filing, forms, third party authorizations, procedures and tax guidance
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Get Continuing Education
Webinars, Nationwide Tax Forums online, accreditation
Use Tax Pro Account
Request Power of Attorney (POA) or Tax Information Authorization (TIA) online with Tax Pro Account.
How it Works
Tax Pro Account lets you submit an authorization request to an Individual taxpayer’s IRS online account.
- Submit request in 15 minutes or less
- Taxpayer electronically signs
- Real-time processing
Use your Secure Access account to log In. Don’t have an account? Click the log In button to sign up.
Log In to Tax Pro Account
Need to use forms? Submit authorizations with Forms 2848 and 8821.
Hours of Service
Tax Pro Account is available:
- Monday 6 a.m. ET to Saturday 9 p.m. ET
- Sunday 10 a.m. to midnight ET (Occasionally down for additional hours for maintenance)
Who Can Use This Service
To use Tax Pro Account, you must have:
- For Tax Information Authorization:
- A Centralized Authorization File (CAF) number in good standing assigned to you as an individual
- A CAF address in the 50 United States or the District of Columbia
- For Power of Attorney:
- A Centralized Authorization File (CAF) number in good standing assigned to you as an individual
- A CAF address in the 50 United States or the District of Columbia
- Authority to practice before the IRS as an attorney, certified public accountant, enrolled agent, enrolled actuary or enrolled retirement plan agent
- License to practice in the 50 United States or the District of Columbia as an attorney or certified public accountant
Before You Start
Make sure this service is right for your request.
Help Topics
- Online Account Access
- Display of Request Status
- Display of Authorization History
- CAF Address
- Taxpayer Address
- Multiple Representatives
- Overlapping Tax Periods
- Tax Year and Tax Matter Limitations
- Copy of Authorization Request
- If You Don't Have a CAF Number
- Tax Pro Account vs. Submit Forms 2848 and 8821 Online
Sign In or Create a New Account
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To use Tax Pro Account with an existing IRS username, log out and return here to log in again.
If you have an existing IRS username, please create a new ID.me account as soon as possible. We’re bringing you an improved sign-in experience.
If you’re a new user, please create an account with ID.me.
ID.me is our trusted technology provider in helping to keep your personal information safe.
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Sign in with an existing IRS username
Welcome JOHN DOE
Important Message from the IRS
Tax Professional Account is now ready for you to use to initiate a Power of Attorney or Tax Information Authorization for the taxpayer. Please read the "Before You Start" information to make this process as easy as possible.
Request Authorization for an Individual Taxpayer
Submit a request online for power of attorney (POA) or tax information authorization (TIA) for an individual taxpayer. The taxpayer can log in to their IRS account to review and electronically sign the authorization request at www.irs.gov/account.
REQUEST POA REQUEST TIA
Forms 2848 and 8821
You can also submit authorizations with forms: Form 2848, Power of Attorney and Declaration of Representative. Form 8821, Tax Information Authorization.
Before You Start
You must have:
- A Centralized Authorization File (CAF) number, which the IRS assigns the first time you file a third-party authorization
- One of the following credentials and not be suspended or disbarred from practice before the IRS per Circular 230 Tax Professionals
- Attorney
- Certified Public Accountant
- Enrolled Agent
- Enrolled Actuary
- Enrolled Retirement Plan Agent
How It Works
1. Prepare
To request POA online, have this ready:
- Centralized Authorization File (CAF) number
- Name and address on file with the IRS for your CAF number
- Taxpayer’s name and address on file with the IRS
- Taxpayer’s Social Security number or Taxpayer Identification Number
- Tax matters and periods for which you are requesting authorization are limited to the following matters from the year 2000 forward:
- Form 1040 Income Tax
- Split Spousal Assessment or Form 8857 Innocent Spouse Relief
- Shared Responsibility Payment
- Shared Responsibility Payment - Split Spousal Assessment
- Civil Penalty (limited to periods of March, June, September and December)
To request authorization for multiple representatives:
- Each representative must log in with their account
- Only 2 representatives may receive copies of a taxpayer’s IRS notices and communications
- The taxpayer must authorize all representatives on the same day
2. Complete the Request
It should take around 15 minutes to complete the request. You cannot save requests to continue later.
After you submit the request, you'll get confirmation that it's been sent to the taxpayer's online account.
If the information you entered for the taxpayer is not correct, they will not see the request in their online account.
3. Contact The Taxpayer
Ask the taxpayer to log in to their account to review and electronically sign the authorization request at www.irs.gov/account.
For multiple representatives requesting authorization for the same tax matters and periods:
- Ask the taxpayer to authorize all representatives on the same day
4. Taxpayer Authorizes or Rejects and Contacts You
The taxpayer logs in to their account at www.irs.gov/account to authorize or reject the request.
The authorization will be processed after the taxpayer approves and electronically signs. Allow up to 2 business days to process after the taxpayer signs.
The taxpayer may print confirmation and give you a copy of the signed authorization.
The IRS won't notify you if the taxpayer rejects the request or if the request failed to process.
Contact the taxpayer with any questions about the status of a request.
⚠️ Submitting with Tax Pro Account will revoke any prior authorization(s) on file with the IRS for the same tax matters and periods. If you don't want a prior authorization to be revoked, use Form 2848.
START NOW
Notices
- OMB Control Number: 1545-0150
- Privacy Act and Paperwork Reduction Act Notice
Representative Information
Enter your name, CAF number and address associated with your IRS CAF record. Check your name and address on a recent notice from IRS. **It must match IRS records to continue.**
The address must be in a U.S. state or D.C. Use approved abbreviations, such as St for street and Ave for avenue. [See more abbreviations (PDF)](https://www.irs.gov/pub/irs-pdf/f2848.pdf).
To change your name or address, submit [Form 2848](https://www.irs.gov/pub/irs-pdf/f2848.pdf).
All fields with an asterisk (*) are required.
First Name*
Special characters are limited to - (dash)
Middle Name
Special characters are limited to - (dash)
Last Name*
Special characters are limited to - (dash)
Suffix
Special characters are limited to - (dash)
Request POA Step 1: Rep Info – cont.
CAF Number*
You can find your CAF number in the representative or appointee letter we mailed you. If you can't find your CAF number, call the Practitioner Priority Service at 866-860-4259 for help.
Format example: 1234-56789
Address Line 1*
Address from a recent IRS notice or letter. Use approved abbreviations (PDF). For example: 123 N Main ST STE 400 (123 North Main Street Suite 400). Symbols allowed: -, /, & and %.
City*
The number of characters is limited to 25. Special characters are limited to – (dash), / (forward slash), & (ampersand), and % (percent sign).
State*
Two-letter abbreviation
ZIP*
Five digits
BACK NEXT Cancel
Request Power of Attorney (POA) Individual Taxpayer
Taxpayer Information
Add one taxpayer per request. For a spouse on a joint return, submit a separate request.
Enter the taxpayer’s information as shown on their most recent income tax return, IRS notice or IRS records. It must match IRS records.
The address must be in a U.S. state or D.C. Use approved abbreviations, such as St for street and Ave for avenue. See more abbreviations (PDF).
If you need to update the taxpayer’s address, use Form 8822 to notify the IRS of the new address.
All fields with an asterisk (*) are required.
First Name*
Special characters are limited to - (dash)
Middle Name
Special characters are limited to - (dash)
Last Name*
Special characters are limited to - (dash)
Request POA Step 2: Taxpayer Info – cont.
Taxpayer Identification Number*
Format example: 123-45-6789
Address Line 1*
Address from a recent IRS notice or letter. Use approved abbreviations (PDF). For example: 123 N Main ST STE 400 (123 North Main Street Suite 400). Symbols allowed: -, /, &, and %.
Address Line 2
Address from a recent IRS notice or letter. Use approved abbreviations (PDF). For example: 123 N Main ST STE 400 (123 North Main Street Suite 400). Symbols allowed: -, /, &, and %.
City*
The number of characters is limited to 25. Special characters are limited to – (dash), / (forward slash), & (ampersand), and % (percent sign)
State*
Two-letter abbreviation
ZIP*
Five digits
BACK NEXT
Cancel
Request Power of Attorney (POA) Individual Taxpayer
Tax Matters
Select the tax matters and periods for which you are requesting authorization. You may request authorization for tax periods starting tax year 2000 and ending three tax years after the current year.
All fields with an asterisk (*) are required.
Select Tax Matters
Select at least one tax matter. Then you will be prompted to select the tax years or periods.*
☐ Form 1040 Income Tax
☐ Split Spousal Assessment or Form 8857 Innocent Spouse Relief
☐ Shared Responsibility Payment
☐ Shared Responsibility Payment - Split Spousal Assessment
☐ Civil Penalty
To request authorization for a matter not listed above, use [Form 2848](#).
Receive Notices
Do you want to receive mailed copies of notices and communications the IRS sends the taxpayer for these tax matters? Only 2 representatives may receive copies of a taxpayer’s notices and communications.*
☐ Yes
☐ No
BACK NEXT Cancel
Select the tax matters and periods for which you are requesting authorization. You may request authorization for tax periods starting tax year 2000 and ending three tax years after the current year.
All fields with an asterisk (*) are required.
**Select Tax Matters**
Select at least one tax matter. Then you will be prompted to select the tax years or periods.*
- [✓] Form 1040 Income Tax
Select a tax year for this matter. Tax years may start from tax year undefined and end three years after the current year. Add another tax year if there are years between them.
1. Starting Tax Year*
- Year
Ending Tax Year*
- Year
+ ADD ANOTHER TAX YEAR
Request POA Step 3: Tax Matters & Periods – cont.
Tax Matters
Select the tax matters and periods for which you are requesting authorization. You may request authorization for tax periods starting tax year 2000 and ending three tax years after the current year.
All fields with an asterisk (*) are required.
Select Tax Matters
Select at least one tax matter. Then you will be prompted to select the tax years or periods.*
- [✓] Form 1040 Income Tax
- Select a tax year for this matter. Tax years may start from tax year undefined and end three years after the current year. Add another tax year if there are years between them.
- Starting Tax Year*
- Year
- Ending Tax Year*
- Year
- [+] ADD ANOTHER TAX YEAR
- [ ] Split Spousal Assessment or Form 8857 Innocent Spouse Relief
- [ ] Shared Responsibility Payment
- [ ] Shared Responsibility Payment - Split Spousal Assessment
- [✓] Civil Penalty
- Select a tax period for this matter. Tax period may start from tax year undefined and end three years after the current year. Add another tax period if there are years between them.
- Starting Tax Period*
- Quarter
- Year
- Ending Tax Period*
- Quarter
- Year
- [+] ADD ANOTHER TAX PERIOD
To request authorization for a matter not listed above, use Form 2848 [?].
Receive Notices
Do you want to receive mailed copies of notices and communications the IRS sends the taxpayer for these tax matters? Only 2 representatives may receive copies of a taxpayer’s notices and communications.*
- [ ] Yes
- [ ] No
[BACK] [NEXT]
Cancel
Review and Submit
Review your answers before you sign and submit. Use the Edit links to go back to pages if you need to make changes.
All fields with an asterisk (*) are required.
**Representative Information**
| Name | John Doe |
|---------------|----------|
| CAF Number | 1234-12345 |
| Address | 1111 Kings Ln, Danville, VA, 24541 |
**Taxpayer Information**
| Name | Billy Baker |
|---------------|-------------|
| Taxpayer Identification Number | 754-43-7563 |
| Address | 1000 Fountain Ave, Parise, GA, 38810 |
**Tax Matters**
| Tax Matter | Form 1040 Income Tax |
|----------------|-----------------------|
| Tax Period(s) | 2010 - 2012 |
| Receives Notices | Yes |
Request Submitted
Your authorization request has been sent to the taxpayer's online account for review and approval.
If the information you entered for the taxpayer is not correct, they will not see the request in their account.
Next Steps
Contact the taxpayer. Ask the taxpayer to log in to their account to review and electronically sign the authorization request at www.irs.gov/account. The taxpayer may print confirmation and give you a copy of the signed authorization. The authorization will be processed after the taxpayer approves and electronically signs. Allow up to 2 business days to process.
⚠️ The IRS won't notify you whether the taxpayer approves or rejects the request.
Contact the taxpayer with any questions about the status of a request.
Request for Power of Attorney
Representative Information
| Name | John Doe |
|---------------|----------|
| CAF Number | 1234-12345 |
| Address | 1111 Kings Ln, Danville, VA, 24541 |
## Taxpayer Information
| Name | Billy Baker |
|-----------------------|-------------|
| Taxpayer Identification Number | 754-43-7563 |
| Address | 1000 Fountain Ave, Parise, GA, 38810 |
## Tax Matters
| Tax Matter | Form 1040 Income Tax |
|---------------------|----------------------|
| Tax Period(s) | 2010 - 2012 |
| Receives Notices | Yes |
## Declaration of Representative
I am not currently suspended or disbarred from practice, or ineligible for practice, before the Internal Revenue Service.
I am subject to regulations contained in Circular 230 (31 CFR, Subtitle A, Part 10), as amended, governing practice before the Internal Revenue Service.
I am authorized to represent the taxpayer identified in this request for the matters specified in this request.
I am an attorney who is a member in good standing of the bar of the highest court of VA. (License number: 1876354468)
## Electronic Signature
**Signed by Representative**
March 29, 2022
[Back to Home](#)
View pending and approved authorization requests submitted through Tax Pro Account.
Pending authorization requests must be reviewed by the taxpayer in their online account at www.irs.gov/account. To approve an authorization request, the taxpayer must electronically sign it.
The IRS won't notify you if the taxpayer rejects a request or if it failed to process. Contact the taxpayer about the status of a request.
### Your Authorization Requests
Search by taxpayer name.
Special characters are limited to "," and "–".
| Client Name | Date Submitted | Type | Status |
|---------------|----------------|------|--------|
| Baker, Billy | 09/07/2021 | POA | Pending|
| Authson, Annie| 06/25/2021 | POA | Approved|
| Baker, Billy | 06/25/2021 | TIA | Pending|
Approved Authorization for Annie Authson
Annie Authson has approved and electronically signed the authorization request.
**Power of Attorney**
**Taxpayer Information**
| Taxpayer Identification Number | 754-43-7563 |
|-------------------------------|-------------|
| Name | Annie A Authson |
| Address | 1000 Fountain Ave, Paris, GA, 38810 |
**Representative Information**
| CAF Number | 1234-12345 |
|------------|-------------|
| Name | John Doe |
| Address | 1111 Kings Ln, Danville, VA, 24541 |
**Tax Matters**
| Tax Matter | Form 1040 Income Tax |
|---------------------|-----------------------|
| Tax Period(s) | 2019 - 2020 |
Pending Approval from Billy Baker
Billy Baker must log in to their account to review and electronically sign the authorization request at www.irs.gov/account.
If the information you entered for your client is not correct, they will not see the request in their account.
The authorization will be processed after your client approves and electronically signs. Allow up to 2 business days to process.
⚠️ The IRS won't notify you if your client rejects the request or if the request failed to process.
Contact your client with any questions about the status of a pending request.
To print this pending authorization, use your browser's Print function.
Request for Power of Attorney
Representative Information
| Name | John Doe |
|---------------|----------|
| CAF Number | 123412345|
| Address | 1111 Kings Ln, Danville, VA, 24541 |
Client Information
| Name | Billy Baker |
|---------------|-------------|
| Taxpayer Identification Number | 754437563 |
| Address | 1000 Fountain Ave, Paris, GA, 38810 |
Tax Matters
| Tax Matter | Form 1040 Income Tax |
|----------------|-----------------------|
| Tax Period(s) | 2019 - 2020 |
Receive Notices
| Yes |
Declaration of Representative
I am not currently suspended or disbarred from practice, or ineligible for practice, before the Internal Revenue Service.
I am subject to regulations contained in Circular 230 (31 CFR, Subtitle A, Part 10), as amended, governing practice before the Internal Revenue Service.
I am authorized to represent the taxpayer identified in this request for the matters specified in this request.
I am an attorney who is a member in good standing of the bar of the highest court of VA. License number: 1234567890
Electronic Signature
| Signed By Representative | June 25, 2021 |
CANCEL REQUEST
Approved Authorization for Annie Authson
Annie Authson has approved and electronically signed the authorization request.
To print this pending authorization, use your browser's Print function.
**Power of Attorney**
**Representative Information**
| Name | John Doe |
|---------------|----------|
| CAF Number | 123412345 |
| Address | 1111 Kings Ln, Danville, VA, 24541 |
**Client Information**
| Name | Annie A Authson |
|---------------|-----------------|
| Taxpayer Identification Number | 754437563 |
| Address | 1000 Fountain Ave, Paris, GA, 38810 |
**Tax Matters**
| Tax Matter | Form 1040 Income Tax |
|----------------|----------------------|
| Tax Period(s) | 2019 - 2020 |
**Receive Notices**
Yes
**Declaration of Representative**
I am not currently suspended or disbarred from practice, or ineligible for practice, before the Internal Revenue Service.
I am subject to regulations contained in Circular 230 (31 CFR, Subtitle A, Part 10), as amended, governing practice before the Internal Revenue Service.
I am authorized to represent the taxpayer identified in this request for the matters specified in this request.
I am an attorney who is a member in good standing of the bar of the highest court of VA. License number: 1234567890
**Electronic Signature**
| Signed By Representative | June 25, 2021 |
|-------------------------|--------------|
| Signed By Taxpayer | June 25, 2021 |
Withdraw an Authorization
If you don't have a copy of the authorization you want to withdraw:
1. Write a statement of withdrawal that:
- Indicates the authority is withdrawn
- Lists the tax matters and years/periods
- Lists the name, TIN, and address (if known) of the taxpayer
2. Sign and date it
3. Fax, mail, or submit it online to the IRS using the How to File instructions for Form 2848
If you have a copy of the authorization you want to withdraw:
1. Write "withdraw" on the top
2. Sign and date it
3. Fax, mail, or submit it online to the IRS using the How to File instructions for Form 2848
Welcome BILLY BAKER
Important Message from the IRS
The IRS is taking steps to help taxpayers affected by COVID-19. See our [Coronavirus Tax Relief](#) page for more information.
Account Status
Total Amount Owed
as of March 29, 2022:
$0.00
View Balance Details
Payments
MAKE A PAYMENT
View Payment Options
View Payment Activity
Notifications
There are no notifications at this time.
Records
View Tax Records for:
- Key information from your most recent tax return
- Advance Child Tax Credit filing information
- Economic Impact Payment filing information
- Downloadable tax records
View Notices and Letters for correspondence from the IRS
View Authorizations for online requests from tax professionals
Authorizations
You can authorize a third party to help you with your federal tax matters. There are 2 types of authorizations:
- Power of Attorney – Authorize an individual to represent you in tax matters before the IRS and to review or receive your confidential tax information for the tax matters and years you specify.
- Tax Information Authorization – Designate an individual, corporation, firm, organization or partnership to receive your confidential tax information for the tax matters and years you specify.
You still must meet your tax obligations when you authorize someone to represent you.
More about third-party authorizations
Online Authorization Requests
View authorization requests submitted online from tax professionals. If you have questions about a request, contact the tax professional. Print using your browser’s Print function.
| Tax Professional | Date Requested | Status | Actions |
|----------------------|----------------|----------|---------------|
| Doe, John | 09/02/2021 | Pending | Approve/Reject|
| Doe, John | 09/02/2021 | Pending | Approve/Reject|
| Maxxtaxx, Taxi | 06/25/2021 | Processing | View |
| Maxxtaxx, Taxi | 06/25/2021 | Failed | View |
| Doe, John | 06/25/2021 | Rejected | View |
| Doe, John | 06/25/2021 | Approved | View |
Review Request for Power of Attorney
John Doe requested authorization to represent you before the IRS for the tax matters listed below.
The tax professional requested this authorization, not the IRS.
Your approval of this request will authorize the tax professional to receive your confidential information and represent you before the IRS for the tax matters and time period listed.
Reject the request if:
- You did not request this authorization
- Any information is incorrect
- You don't want to approve the request
Carefully review the request to make sure it is accurate. If you have questions, contact the tax professional.
If you want to approve, you must check the boxes under Sign and Submit.
Request for Power of Attorney (POA)
Your Information
| Name | Billy Baker |
|------------|-------------|
| Address | 1000 Fountain Ave, Paris, GA, 38810 |
Representative Information
Name: John Doe
CAF Number: 123412345
Address: 1111 Kings Ln, Danville, VA, 24541
Declaration of Representative: The representative signed that they are an Attorney who is not suspended or disbarred from practice before the IRS.
Signed by Representative: June 25, 2021
Tax Matters
Tax Matter: Form 1040 Income Tax
Tax Period(s): 2019 - 2019
Notices: The representative will not receive by mail copies of notices and communications the IRS sends you for these tax matters.
Sign and Submit
If you want to approve the request, check both boxes and then select Approve Request.
- By checking this box, I authorize the designated representative to represent me before the IRS and receive confidential information for the matters described in this power of attorney.
- By checking this box, under penalties of perjury, I declare that, to the best of my knowledge and belief, all the entered information is true, correct, and complete.
REJECT REQUEST | APPROVE REQUEST
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John Doe will not represent you before the IRS or receive your confidential tax information for the tax matters listed in the request.
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NO YES
Authorization
Power of Attorney Request Rejected
Request Rejected
You have rejected the request for power of attorney from John Doe. Contact them if you have any questions.
Your Information
Name: Billy Baker
Address: 1000 Fountain Ave, Parise, GA, 38810
Representative Information
Name: John Doe
CAF Number: 1234-12345
Address: 1111 Kings Ln, Danville, VA, 24541
Tax Matters
Tax Matter: Form 1040 Income Tax
Tax Period(s): 2019 - 2019
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Your Request is Processing
Please allow up to 2 business days to process your request. We will update the status on the authorizations page when processed.
Your Information
Name: Billy Baker
Address: 1000 Fountain Ave, Paris, GA, 38810
Representative Information
Name: John Doe
CAF Number: 123412345
Address: 1111 Kings Ln, Danville, VA, 24541
Declaration of Representative
Signed by Representative: June 25, 2021
Tax Matters
Tax Matter: Form 1040 Income Tax
Tax Period(s): 2019 - 2019
Notices: The representative will receive by mail copies of notices and communications the IRS sends you for these tax matters.
Electronic Signature
Signed By Taxpayer: June 23, 2021
After taxpayer signs and approves authorization, the IRS again checks if the tax professional is in good standing.
If authorization clears validation, it is posted immediately (at least within 48 hours) to the Centralized Authorization File (CAF).
## Authorizations
### Power of Attorney Approved
- **Request Approved**
John Doe is authorized to represent you before the IRS and receive your confidential tax information for the matters described in this power of attorney.
### Your Information
| Name | Billy Baker |
|------------|-------------|
| Address | 1000 Fountain Ave, Paris, GA, 38810 |
### Representative Information
| Name | John Doe |
|------------|----------|
| CAF Number | 123412345 |
| Address | 1111 Kings Ln, Danville, VA, 24541 |
| Declaration of Representative | The representative signed that they are an Attorney who is not suspended or disbarred from practice before the IRS. |
| Signed by Representative | June 25, 2021 |
### Tax Matters
| Tax Matter | Form 1040 Income Tax |
|---------------------|-----------------------|
| Tax Period(s) | 2019 - 2019 |
### Notices
The representative will not receive by mail copies of notices and communications the IRS sends you for these tax matters.
### Electronic Signature
| Signed By Taxpayer | June 23, 2021 |
Ability to have multiple representatives per authorization:
- Each tax professional initiates authorization from their own Tax Pro Account.
- Taxpayer must sign all authorizations on the same day.
- Only two tax professionals can elect to receive copies of IRS notices and communications sent to taxpayer.
- If more than two tax professionals make an election, after approval of the first two authorization by the taxpayer, the remaining authorizations will not be processed.
Authorization Request Failed
Authorizations
Power of Attorney Request Failed
⚠️ Your Request Failed
We are unable to process this power of attorney online.
You may want to use Form 2848, Power of Attorney and Declaration of Representative to submit the authorization.
Contact your tax professional for help.
Your Information
| Name | Billy Baker |
|------------|-------------|
| Address | 1000 Fountain Ave, Paris, GA, 38810 |
Representative Information
| Name | John Doe |
|------------|----------|
| CAF Number | 123412345 |
| Address | 1111 Kings Ln, Danville, VA, 24541 |
Tax Matters
| Tax Matter | Form 1040 Income Tax |
|----------------|-----------------------|
| Tax Period(s) | 2019 - 2019 |
Approved Power of Attorney
John Doe is authorized to represent you before the IRS and receive your confidential tax information for the matters described in this power of attorney.
Power of Attorney
Taxpayer Information
- **Taxpayer Identification Number**: 754-43-7563
- **Name**: Billy Baker
- **Address**: 1000 Fountain Ave, Parise, GA, 38810
Representative Information
- **CAF Number**: 1234-12345
- **Name**: John Doe
- **Address**: 1111 Kings Ln, Danville, VA, 24541
Tax Matters
- **Tax Matter**: Civil Penalty
- **Tax Period(s)**: June 30, 2019 - September 30, 2020
March 31, 2018 - June 30, 2018
**Power of Attorney**
**Taxpayer Information**
| Taxpayer Identification Number | 754-43-7563 |
|-------------------------------|-------------|
| Name | BILLY BAKER |
| Address | 1000 FOUNTAIN AVE, Parise, GA, 38810 |
**Representative Information**
| CAF Number | 1234-12345 |
|------------|------------|
| Name | JOHN DOE, |
| Address | 1111 KINGS LN, DANVILLE, VA, 24541 |
**Tax Matters**
| Tax Matter | Civil Penalty |
|---------------------|---------------|
| Tax Period(s) | 2019 - 2020 |
| | 2018 - 2018 |
| | 2017 - 2017 |
| Tax Matter | Form 1040 Income Tax |
|---------------------|----------------------|
| Tax Period(s) | 2019 - 2020 |
| | 2019 - 2020 |
**Notices**
The representative will receive by mail copies of notices and communications the IRS sends you for these tax matters.
**Representative Declaration and Signature**
Under penalties of perjury, I declare that, to the best of my knowledge and belief, all the entered information is true, correct, and complete.
I am not currently suspended or disbarred from practice, or ineligible for practice, before the Internal Revenue Service.
I am subject to regulations contained in Circular 230 (31 CFR, Subtitle A, Part 10), as amended, governing practice before the Internal Revenue Service.
I am authorized to represent the taxpayer identified in this request for the matters specified in this request.
I am an attorney who is a member in good standing of the bar of the highest court of null.
**Signed by Representative**
June 25, 2021
IRS will continue to expand Tax Pro Account capabilities to improve its features for authorization requests and to add functionality as resources allow.
Here are just some of the features we are working, planning, or considering:
- Notification to the taxpayer regarding action in their Online Account, to include pending authorization requests
- Email alerts letting the tax professional know when taxpayer approves their authorization request
- Taxpayer’s ability to view their complete authorization history.
- Tax professional’s ability to view and manage all their active authorizations on CAF processed through all channels
Online Account
A self-service tool for individual taxpayers to view their account information
IRS.gov home page takes you to Online Account
Access Online Account
Taxpayers can access their online account from the IRS.gov home page
Access your individual account information including balance, payments, tax records and more.
Sign in to your Online Account
If you don’t have an existing IRS username or ID.me account, have your photo identification ready. More information about identity verification is available on the sign-in page.
Access Tax Records
- View key data from your most recently filed tax return, including your adjusted gross income, and access transcripts
- View information about your Economic Impact Payments
- View information about your advance Child Tax Credit payments
- View digital copies of certain notices from the IRS
Make and View Payments
- Make a payment from your bank account or by debit/credit card
- You can also make a guest payment without logging in
- View 5 years of payment history, including your estimated tax payments
- View any pending or scheduled payments
Manage Communication Preferences
- Go paperless for certain notices
- Get email notifications for new notices
View Your Balance
- View the amount you owe and a breakdown by tax year
View or Create Payment Plans
- Learn about payment plan options and apply for a new payment plan
- View details of your payment plan if you have one
View Tax Pro Authorizations
- View any authorization requests from tax professionals
- Approve and electronically sign Power of Attorney and Tax Information Authorization from your tax professional
Account Home shows key data about the taxpayer’s account
Welcome STACY ELAINE STEEN
Account Status
Your 2021 Tax Return Is Not Processed
If you’ve already filed… Read more
Total Amount Owed
as of March 29, 2022:
$330.00
View Balance Details
Payments
MAKE A PAYMENT
View Payment Options
View Payment Activity
Notifications
Turn On Email Notifications
Sign up to receive email notifications when the IRS issues new notices for your account.
Go Paperless for Select IRS notices
Update your profile to receive specific notices online only.
IRS Notice Available
View or download your notice.
Payment Plan (Installment Agreement)
This is based on recent data and is subject to change.
| Status | Current |
|-----------------|---------|
| Type | Monthly Payment Plan |
| Monthly Payment Amount | $100.00 |
| Payment Day | 27th of each month |
View Payment Plan Options
Records
View Tax Records for:
• Key information from your most recent tax return
• Advance Child Tax Credit filing information
• Economic Impact Payment filing information
• Downloadable tax records
View Notices and Letters for correspondence from the IRS
View Authorizations for online requests from tax professionals
Account Home shows key data about the taxpayer’s account – cont.
In-App Notifications
Taxpayers are informed of important account information.
Account Home shows key data about the taxpayer’s account – cont. 2
Payment Plan Details
Taxpayers who have a payment plan can see the details of their plan.
Notifications
Turn On Email Notifications
Sign up to receive email notifications when the IRS issues new notices for your account.
Go Paperless for Select IRS notices
Update your profile to receive specific notices online only.
IRS Notice Available
View or download your notice.
Payment Plan (Installment Agreement)
This is based on recent data and is subject to change.
| Status | Current |
|-----------------|--------------------------|
| Type | Monthly Payment Plan |
| Monthly Payment Amount | $100.00 |
| Payment Day | 27th of each month |
Records
View Tax Records for:
• Key information from your most recent tax return
• Advance Child Tax Credit filing information
• Economic Impact Payment filing information
• Downloadable tax records
View Notices and Letters for correspondence from the IRS
View Authorizations for online requests from tax professionals
Notices and Letters provides digital copies of select IRS correspondence.
List of Notices
Provides Taxpayers with a list of any new notices.
Monthly Payment Reminder
A reminder that your installment agreement payment is due.
Notice Date: 03/01/2022
VIEW NOTICE (PDF)
Notices and Letters provides digital copies of select IRS correspondence – cont.
This page has digital versions of some IRS notices.
Please continue to check your postal mail for IRS paper notices not yet available online.
Manage Your Paperless or Email Notification Preferences
View your profile to go paperless or sign up for email notifications when you have new notices available online.
Notice Details
Includes name, date issued, and short description.
View Notices
Click the button to view or download notices as a PDF.
Notices and Letters provides digital copies of select IRS correspondence – cont. 2
IRS Notices
This page has digital versions of some IRS notices.
Please continue to check your postal mail for IRS paper notices not yet available online.
Manage Your Paperless or Email Notification Preferences
View your profile to go paperless or sign up for email notifications when you have new notices available online.
Monthly Payment Reminder
A reminder that your installment agreement payment is due.
Notice Date: 03/01/2022
VIEW NOTICE (PDF)
Get answers to your questions by calling the number on the PDF notice or viewing the Frequently Asked Questions.
Manage Communication Preferences
Taxpayers have the option to go paperless and sign up for email notifications directly from the Notices and Letters tab.
This page has digital versions of some IRS notices.
Please continue to check your postal mail for IRS paper notices not yet available online.
Manage Your Paperless or Email Notification Preferences
View your profile to go paperless or sign up for email notifications when you have new notices available online.
Monthly Payment Reminder
A reminder that your installment agreement payment is due.
Notice Date: 03/01/2022
VIEW NOTICE (PDF)
Get answers to your questions by calling the number on the PDF notice or viewing the Frequently Asked Questions.
Profile displays key taxpayer contact information
Access Your Profile
The profile page can be accessed via a link in the header and shows your current contact information and how to update it.
Your Profile
Your Name
Name changes must be made through the Social Security Administration. For more information, see name changes.
Full Name
STACY ELAINE STEEN
Mailing Address
To change your mailing address, you can submit Form 8822 (PDF) by mail or get more information on address changes.
Mailing Address
1040 MAPLE ST
HOBOKEN, NJ 33212
UNITED STATES
Email and Password
To change your email address, password, and other account details, update your sign-in settings.
Email Address
email@example.com
Profile displays key taxpayer contact information – cont.
Email Notifications
Taxpayers can sign up to receive email notifications for important account information
Paperless Setting
Taxpayers can choose to go paperless for notices available online
Email Notifications
Taxpayers can sign up to receive email notifications for important account information.
Email Notifications
To change your email notification settings, select 'EDIT'.
New Notices and Letters
No
Email Notifications
Be notified by email when a new notice becomes available to view in Notices and Letters. If you select 'CANCEL' your updates will not be saved.
New Notices and Letters
SAVE
Email Notifications Successfully Saved
Email notifications will be sent to: firstname.lastname@example.org
New Notices and Letters
Yes
Paperless Settings
Taxpayers can choose to go paperless for notices available online.
To change paperless settings, select 'EDIT'. You may still receive some paper notices by mail. Be notified when a notice is available to view online by opting into email notifications.
Notice Delivery
Digital and Paper
Digital
You may continue to receive paper notices for those not available digitally and those that must be mailed.
Digital and Paper
You may separately choose to receive email notifications when digital notices are available online.
SAVE
Paperless Settings Successfully Saved
You will not receive paper copies for the notices available online. Digital notices can be viewed in the Notices and Letters tab.
Account Balance shows the taxpayers details by year
Total Amount Owed
$330.00
Details by Year
Shows a breakdown of the taxpayer’s balance by year, with any penalties and interest.
For years for which a return hasn’t been filed or a balance isn’t available, taxpayers receive a personalized message with account details.
Taxpayers have the option to make several different types of same day payments:
- 2021 Income Tax payments (for taxpayers whose 2021 return has not been processed yet)
- Minimum monthly plan payments for taxpayers in an installment agreement
- Payments towards their balance or plan
- Amended return payments
- Estimated tax payments
- Extension payments (only until the filing deadline)
- Proposed tax assessment
Taxpayers must select their account type, routing number and account number.
Taxpayers have the option to receive an email confirmation for their payment.
The final step is to review and submit the payment.
Make a Payment: Review & Submit
Taxpayers have the opportunity to review what they entered before submitting their payment.
For balance and payment plan payments, online account knows the tax year and type for their payments so they don’t have to enter it.
Make a Payment: Payment Submitted
Taxpayers receive a confirmation of their payment submission on the screen, and by email if they requested it.
Your Payment Has Been Submitted
Make note of the confirmation number for your records.
You still have an outstanding balance. Consider the payment options available to you.
Confirmation Number
B2ABIIISGATZ1F68588
Submitted
December 18, 2021 12:45AM EDT
Payment Information
Use the Electronic Funds Transfer Number (EFT#) if you contact the IRS about a transaction.
| Tax Year | Type | EFT# | Amount |
|----------|--------------------|-----------------------|----------|
| 2020 | Payment | 030534394387958 | $101.10 |
| 2020 | Shared Responsibility | 762553871255144 | $100.02 |
Total Payment Amount
$201.12
Payment Credited
Bank Account Information
Account Type
Checking
Routing Number
111000025
Account Number
******111
Taxpayers can see any pending or scheduled payments
Pending & Scheduled Payments
Taxpayers can see all pending or scheduled electronic payments. After submitting a payment through online account, it will show up right away as pending.
Processed Payments
Taxpayers can see five years of payment history. Estimated tax payments note that as the type.
Your Account is in Jeopardy of Lien or Levy
Please pay immediately by bank account, by card, or set up a payment plan, if applicable. Resolve your balance, or we may file a Notice of Federal Tax Lien (if we haven't already) and levy your assets.
Account Status
Your 2021 Tax Return Is Not Processed
If you've already filed... Read more
Total Amount Owed
as of April 8, 2022:
$500.00
View Balance Details
Payments
MAKE A PAYMENT
View Payment Options
View Payment Activity
Notifications
There are no notifications at this time.
Records
View Tax Records for:
- Key information from your most recent tax return
- Advance Child Tax Credit filing information
- Economic Impact Payment filing information
- Downloadable tax records
View Notices and Letters for correspondence from the IRS
View Authorizations for online requests from tax professionals
Payment Options shows taxpayers all the options available to them.
Make a Payment through Online Account
All taxpayers can make same day payments from their bank account for a balance, amended return, estimated tax, filing extension (until the deadline) or a proposed tax assessment.
Payment Plans
Taxpayers can see any payment plan options available to them and set up a plan online if they are eligible.
Eligible taxpayers can create a short-term plan through online account.
Create Short-Term Payment Plan
A short-term payment plan gives taxpayers an extension of time to pay their balance.
Plan Summary Details
| Plan Type | Short-Term Payment Plan |
|----------------------------|-------------------------|
| Payoff Amount | $625.20* (includes accrued penalties & interest) |
| Accrued Penalties & Interest | $125.20 |
| Setup Fee | $0 |
| Pay Within | 180 days |
| Due Date | June 1, 2022 |
*Important notice:
- This information is only an estimate of the cost of the payment plan and accruals.
- It does not constitute a quote, offer, or contract by the IRS, and it is not a guarantee of the final cost of the payment plan and accruals.
- The cost is subject to change without notice.
- The IRS makes no representation or warranties about the accuracy of the estimate and accepts no liability arising out of your use of this estimate.
Please note that all correspondence will be sent to the address in your Profile.
Taxpayers must accept the terms & conditions
All fields with an asterisk (*) are required.
**Terms and Conditions**
*If your account is not fully paid by the date promised, we may begin enforced collection actions. We could:*
- Collect the entire amount you owe by levying your wages, other income, bank accounts, other assets, or by seizing property.
- Terminate this payment plan at any time if we find that collection of the tax is in jeopardy.
- File a [Notice of Federal Tax Lien](#) if one has not been filed previously.
All federal taxes that become due must be filed and paid on time. We will apply any federal tax refund to the amount you owe until your balance is paid in full.
*Note:* The Internal Revenue Service may have already initiated enforcement actions on your account. If you have received a "Notice of Intent to Levy and Notice of Your Right to a Hearing," it is important that you contact the IRS representative listed on that notice to prevent further enforcement actions.
**Accept Terms and Conditions**
- I have read the above Terms and Conditions and authorize the creation of a short-term payment plan.*
[BACK] [SUBMIT]
Taxpayers receive an immediate confirmation of their plan
Plan Approval
You are approved for a short-term payment plan!
Your short-term payment plan is active effective immediately. You may make multiple payments or pay the liability in full by the due date. All correspondence will be sent to the address in your Profile.
Plan Summary Details
| Name | ANNIE AUTHSON |
|-----------------------|---------------|
| Plan Type | Short-Term Payment Plan |
| Payoff Amount | $625.20* (includes accrued penalties & interest) |
| Accrued Penalties & Interest | $125.20 |
| Setup Fee | $0 |
| Pay Within | 180 days |
| Due Date | June 1, 2022 |
Important notice:
- This information is only an estimate of the cost of the payment plan and accruals.
- It does not constitute a quote, offer, or contract by the IRS, and it is not a guarantee of the final cost of the payment plan and accruals.
- The cost is subject to change without notice.
- The IRS makes no representation or warranties about the accuracy of the estimate and accepts no liability arising out of your use of this estimate.
Start Paying Today
Making a payment today minimizes penalties and interest. If you choose to make partial payments, check your online account for an updated payoff amount.
MAKE A PAYMENT
Avoid Future Tax Balances
- Use the Tax Withholding Estimator to ensure you have the appropriate amount of tax withheld per paycheck.
- More information on making Estimated Tax Payments throughout the year.
Tax Records provides important data for tax returns
Key Data from Most Recent Tax Return
Clearly highlights key information for taxpayers from their most recent return.
Advanced Child Tax Credit Payment Info
Tax Records can find the information needed to file their 2021 tax returns.
Economic Impact Payment Info
Tax Records now show Economic Impact Payment amounts for qualifying taxpayers.
Get Transcripts
Provides access to account and return transcripts online
Additional features are available now
Now available
Tax Pro Authorizations
Approve and electronically sign Power of Attorney and Tax Information Authorization requests from your tax professional.
Create a Short-Term Payment Plan
Certain taxpayers can setup short term payment plans within online account.
Manage Notification Preferences
Request email notifications for digital notices or payments.
Opt-out of Paper Notices
Go paperless for certain correspondence from the IRS.
Make a Payment
Pay your balance or estimated taxes seamlessly within Online Account.
Key Points
- Initiate, electronically sign, and submit Power of Attorney (POA) and Tax Information Authorization (TIA) requests online.
- Must have CAF #, Tax Pro Account cannot be used to request CAF #
- Supports basic POAs for individual taxpayers only
Key Points – cont. 2
• Address validation, must use exact address IRS has on file (cannot update address)
• Supporting multiple representatives for POAs and multiple designees for TIAs
Key Points – cont. 3
• View Balance, Tax Records and Notices
• Make and View Payments
• View Payment Plan Details
• View Account Notifications
• View Address on File
Key Points – cont. 4
• Make a same day payment
• Set up payment plan if eligible
• View Economic Impact Payments, if any
• View & Approve Authorizations
• View digital copies of select notices from the IRS
Key Points – cont. 5
• Opt out of Paper Notices
• Opt into email notifications for digital copies of new notices
Richard Furlong, Jr.
Senior Stakeholder Liaison
267-941-6343
email@example.com
|
SDGs and Gender Equality: UN Interagency Guidance Note for the Europe and Central Asia Region
United Nations Europe and Central Asia Issue-Based Coalition on Gender
Cover photo: Women need more leading roles in technology and innovation. (UN Albania/Eduard Pagria)
Design: LS - lsgraphicdesign.it
SDGs and Gender Equality: UN Interagency Guidance Note for the Europe and Central Asia Region
United Nations Europe and Central Asia Issue-Based Coalition on Gender
August 2017
# Table of contents
List of acronyms .................................................................................................................. 6
Acknowledgements ............................................................................................................. 7
Objectives, methodology and structure .............................................................................. 9
**Section 1**: Gender equality in the 2030 Agenda for Sustainable Development ................. 10
**Section 2**: Regional trends impacting gender equality and empowerment of all women and girls: contextualizing the SDGs and targets .......................................................................................................................... 14
**Section 3**: Implementing the SDGs in a gender-responsive way ........................................ 16
**Addendum I**: Resources .................................................................................................... 32
**Addendum II**: Regional advocacy brief on gender equality, women’s rights and women’s empowerment .......................................................................................................................... 38
**Addendum III**: Exercises ................................................................................................... 46
**Addendum IV**: Tips, promising practices and lessons learned from UNCTs ....................... 50
**Addendum V**: How countries are implementing SDGs ....................................................... 56
Glossary ............................................................................................................................... 60
| Acronym | Description |
|---------|-------------|
| ADB | Asian Development Bank |
| CEDAW | Convention on the Elimination of All Forms of Discrimination Against Women |
| CSO | Civil Society Organization |
| ECA | Europe and Central Asia |
| EU | European Union |
| FAO | Food and Agriculture Organization of the United Nations |
| GBV | Gender Based Violence |
| IBC-Gender | Issue-Based Coalition on Gender |
| ILO | International Labour Organization |
| M&E | Monitoring and Evaluation |
| MAPS | Mainstreaming, Acceleration and Policy Support |
| MDG | Millennium Development Goal |
| NSS | National Statistics Systems |
| SDG | Sustainable Development Goal |
| UN | United Nations |
| UN Women | United Nations Entity for Gender Equality and the Empowerment of Women |
| UNCT | United Nations Country Team |
| UNDAF | United Nations Development Assistance Framework |
| UNDP | United Nations Development Programme |
| UNECE | United Nations Economic Commission for Europe |
| UNEP | United Nations Environment Programme |
| UNESCO | United Nations Educational, Scientific and Cultural Organization |
| UNFPA | United Nations Population Fund |
| UNICEF | United Nations Children’s Fund |
| WFP | World Food Programme |
| WHO | World Health Organization |
The SDGs and Gender Equality: UN Interagency Guidance Note for the Europe and Central Asia region was produced by the Issue-Based Coalition on Gender (IBC-Gender), consisting of 12 UN agencies and entities in the region (FAO, ILO, OHCHR, UNDP, UNECE, UNEP, UNESCO, UNFPA, UNICEF, UN Women, WFP, WHO), currently co-chaired by UNFPA and UN Women. The overall leadership and financial contribution were provided by UNDP, UNFPA, UNICEF and UN Women Regional Offices, with substantive contribution from FAO, ILO, UNECE, UNEP, UNESCO, WFP, WHO at the regional level as well as the United Nations Country Teams (UNCTs), Gender Theme Groups and Results Groups at the country level.
We wish to thank Dr. Aysel Vazirova, researcher and consultant writer, for her role as lead author of the guidance note.
Objectives, methodology and structure
This Guidance Note aims to provide user-friendly guidance on integrating gender equality and the empowerment of all women and girls in the nationalization and localization of the Sustainable Development Goals (SDGs) in the Europe and Central Asia region. The document is intended for United Nations Country Teams (UNCTs) and can be shared with regional partners (e.g. European Union, World Bank, Asian Development Bank, Council of Europe, civil society organizations and others) to promote policy and programmatic synergies. The note draws upon the twin-track approach to gender equality of the SDGs. It highlights the interrelated nature of the SDGs and the importance of the “leave no one behind” principle as the basis for applying a gender lens to all policies and activities to advance the goals at national and local levels.
The Guidance Note presents the outcomes of analysis drawing on two key sources of regional and country-based data:
- A survey of UNCTs in the region: seventeen Country Teams responded to the survey (August–September, 2016) with information on the status of the SDG nationalization/localization process in each country, challenges in mainstreaming gender equality, and good practices. The information was updated in March, 2017.
- A desk review of reports, assessments and databases: this yielded regional trends in gender equality and the national and regional landscape of policies and practices conducive for progress toward gender equality.
In analysing the data, special attention was paid to the formulation of practical recommendations to address challenges specific to the region. The Guidance Note also includes lessons learned and promising practices that reflect the experiences of UNCT member agencies.
The *SDGs and Gender Equality: UN Interagency Guidance Note for the Europe and Central Asia region* consists of three sections, five addenda and a glossary. The first section highlights the role of gender equality and the empowerment of women and girls in the 2030 Sustainable Development Agenda. The second section places the SDGs in the context of the key regional trends in gender equality. It refers readers to the analysis of nine trends in gender equality in Eastern Europe and Central Asia (presented in Addendum II, Regional advocacy brief on gender equality, women’s rights and women’s empowerment). The third section identifies four essential steps in the gender-responsive implementation of the SDGs, with guidance, recommendations and examples illustrating successful practices.
Addendum I contains a list of resources and Addendum III a set of exercises designed to assist UNCTs in achieving gender equality in implementing the SDGs. Addendum IV features tips, promising practices and lessons learned from Eastern Europe and Central Asia. Addendum V presents flow charts, illustrating the consecutive steps undertaken by UNCTs to ensure gender-responsive SDG implementation.
The note is accompanied by a glossary of commonly used terms. Please note that even when not specified, references to “gender equality” in this document also encompass “the empowerment of all women and girls.”
Section 1
Gender equality in the 2030 Agenda for Sustainable Development
The 2030 Agenda for Sustainable Development embraces gender equality and the empowerment of all women and girls with a broader scope and new quality in its vision for global development. Compared to the Millennium Development Goals (MDGs), Agenda 2030 covers gender equality and the empowerment of all women and girls more comprehensively and stresses their role as accelerators for various aspects of sustainable development. It addresses gender equality on three levels:
1. Gender equality is the focus of a stand-alone goal (SDG 5: Achieve gender equality and empower all women and girls) and its nine targets. The targets cover themes that highlight systematically reproduced outcomes of structural gender inequality:
➔ Discrimination and violence against women and harmful traditional practices (Targets 5.1, 5.2, 5.3);
➔ Unequal access to economic resources and low value assigned to women’s unpaid care and domestic work (Target 5.4 and 5.a);
➔ Unequal access to decision-making (Target 5.5) and sexual and reproductive health and reproductive rights (Target 5.6).
SDG 5 also presents three targets outlining the means of implementation (economic reforms, use of enabling technologies and strengthening of the legislative and policy environment) necessary to facilitate progress towards gender equality.
2. Many SDGs (14 out of the 17) include specific targets addressing economic, social, political and cultural conditions that reproduce gender inequality. From poverty reduction (SDG 1) to the promotion of justice (SDG 16), gender equality is mainstreamed into Agenda 2030 through a number of gender-related targets. Agenda 2030 thus emphasizes deep connections between gender-based discrimination and economic and social inequality, a central concern of its global vision for sustainable development. The two levels, mentioned above, come together to reflect a twin-track approach to gender equality and the empowerment of all women and girls, one of the core principles of the SDG framework.
3. Agenda 2030 envisions equity as a foundation of its core principle: “No one left behind.” It focuses on extending the benefits of sustainable development to groups of the population that are routinely and structurally excluded. The approach overlaps with the key concerns of achieving gender equality and empowering women and girls because, within unequal gendered power relations, gender often acts as the factor triggering social, political, cultural and economic exclusion.
With its 17 goals and 169 targets, the SDGs form a complex integrated policy framework. Each goal is connected to several others through specific targets. The connections reflect the intention of the Agenda 2030 to break down development “silos” and reveal the nature of sustainable development as a holistic process, with various SDGs reinforcing each other. For example, the elimination of harmful practices, such as early marriage (SDG 5, Target 5.3), is likely to be positively affected by economic empowerment (SDG 1, Target 1.4) and increased access to education and vocational training (SDG 4, Targets 4.3 and 4.5), while in turn boosting opportunities for women and girls to exercise control over their sexual and reproductive health (SDG 3, Target 3.7).
Imagining SDGs as a network can help capture the integrated nature of the Agenda 2030 framework and understand connections among the various SDGs and targets. The example below illustrates how the network of SDGs and targets can address one of the key regional trends that inform the gender equality situation.
Key trend: harmful traditional practices (such as child, early and forced marriage) continue across the region.
Action required: reverse the trend by eliminating socio-economic, political and cultural conditions responsible for the perpetuation of harmful traditional practices.
SDG 5, 5.3
Eliminate all harmful practices, such as child, early and forced marriage and female genital mutilation
SDG 4, 4.5
By 2030, eliminate gender disparities in education and ensure equal access to all levels of education and vocational training for the vulnerable, including people with disabilities, indigenous people and children in vulnerable situations.
SDG 16, 16.2
End abuse, exploitation, trafficking and all forms of violence against and torture of children
SDG 3, 3.7
By 2030 ensure universal access to sexual and reproductive health-care services, including for family planning, information and education, and the integration of reproductive health into national strategies and programmes.
SDG 1, 1.2
By 2030, reduce at least by half the proportion of men, women and children living in poverty in all its dimensions according to national definitions
Reversing the trend requires a comprehensive set of policies that fall within the twin-track approach used by SDG framework. While SDG 5, Target 5.3 directly sets out to eliminate harmful practices (such as early, child and forced marriage), the targets under SDGs 1, 3, 4, 16 present key policy goals, essential for changing the environment that breeds harmful practices. For example, efforts to reduce the proportion of those living in poverty (as stated in Target 1.2) have to address economic struggles faced by women and girls, and tackle economic factors that compel families to resort to early, child or forced marriage.
Along with access to economic opportunities, education plays a key role in eliminating harmful traditional practices. Ensuring equal access to all levels of education and vocational training for vulnerable groups and eliminating gender disparities in education (Target 4.5) increases women and girls’ chances to make independent decisions and enables families and communities to reject harmful traditional practices. At the same time, education in sexual and reproductive rights is very important for raising public awareness of the dangerous physical and psychological consequences of such practices. Women and girls who suffer from such practices need access to sexual and reproductive health-care services, including family planning, information and education (Target 3.7). Harmful traditional practices shroud violence against women and girls under the cover of cultural acceptance. Providing equal access to justice for all and building effective, accountable and inclusive institutions (Target 16.2) constitute key elements in building societies free from the lasting damage caused by harmful traditional practices.
Addressing harmful traditional practices through a stand-alone SDG (5, Target 5.3), while at the same time mainstreaming the relevant responses through several SDGs and targets, ensures a comprehensive multi-sectoral approach to the problem. The visual representation above illustrates how a strong cluster of policies under several SDGs can address this negative regional trend in a comprehensive and coordinated manner.
Section 2
Regional trends impacting gender equality and empowerment of all women and girls
© UNICEF/Morina
Shkurta, a 6-year-old Roma girl in Kosovo\(^1\), obtains new skills through a home-based programme aimed at promoting social inclusion.
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\(^1\) References to Kosovo shall be understood to be in the context of Security Council Resolution 1244 (1999).
Contextualizing the SDGs and targets
The Europe and Central Asia region is characterized by a high level of diversity among the countries. However, several common socio-economic and demographic trends important for gender equality prevail in the region. Contextualizing the SDGs in country-based or regional trends means determining how the SDG framework can most effectively help the countries address the negative trends and accelerate the positive ones.
Since 2013, there has been uneven progress in advancing gender equality in the region. Within the Millennium Development Goals (MDG) framework, Goal 3 (“Promoting gender equality and empowering women”) was only partly achieved in Europe and Central Asia.
Please refer to the Regional advocacy brief on gender equality, women’s rights and women’s empowerment (Addendum II), which details the nine regional trends that influence the state of gender equality in Europe and Central Asia: persistent limitations in economic opportunities for women and girls, gaps in social protection and access to services, dangerous effects of unregulated migration, rising wave of conservatism, shrinking space for women’s civic activism, gendered impact of the demographic dividend and population aging, high prevalence of gender-based violence (GBV), failure to address the gendered dimension of environmental disasters and continuing lack of accessible gender statistics and sex-disaggregated data. It also contains recommendations on how to address the trends by implementing the SDGs.
Section 3
Implementing the SDGs in a gender-responsive way
The United Nations Development Group has prepared an overall strategy for the UN system’s support to governments in implementing the SDGs. The MAPS (Mainstreaming, Acceleration and Policy Support) strategy consists of three main elements. “Mainstreaming” refers to integrating the new post-2015 agenda into national, subnational, and local plans for development. “Acceleration” involves using national (and UN) resources to target priority areas identified in the mainstreaming process. “Policy Support” includes the assistance (skills and expertise) provided by the UN development system to national partners in implementing the SDGs. The four steps of gender-responsive SDG implementation presented below embrace all three elements of the MAPS strategy.
The steps describe the stages of implementation and actions that UNCTs and national partners can undertake to integrate gender equality and the empowerment of all women and girls in the SDG implementation process. It is important to note that the term “national partners” covers a wide spectrum of stakeholders at national and sub-national levels, including civil society organizations (CSOs), informal groups and community-based structures, individual experts, private sector companies and government bodies.
**Step 1. Nationalization and localization of gender-related SDGs and targets**
**Purpose:** The mainstreaming of gender equality into national plans for SDG implementation should be made a priority from the earliest stages of the nationalization and localization processes. Countries often start with developing a vision of nationalized SDGs. Given the complexity of Agenda 2030, awareness raising, advocacy for the inclusion of a strong gender lens in SDG nationalization and the development of a national vision will often go hand in hand. Integrating gender equality in the general vision for nationalized SDGs provides a foundation for all future mainstreaming efforts. Securing the national ownership of gender-related SDGs and targets at the earliest stages will strengthen negotiation for the fullest possible integration of gender equality and the empowerment of all women and girls into national strategies of SDG implementation.
**Where to start:** In many countries, UNCTs start preparing awareness-raising and advocacy materials that can be used during national consultations on SDGs, in cooperation with national partners.
**Tip:** Create a group of supporters/experts (civil society organizations, government representatives, private sector actors and academics) prior to the start of national consultations. The group’s key role is to further support the process of engendering SDGs nationalized targets (Turkmenistan).
National consultations are open or closed discussions about the SDG framework and its relevance for national development. Whether it is an inclusive nation-wide discussion, closed government session or a meeting of experts, UNCTs and their national partners should be prepared to:
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2 A list of MAPS tools currently under preparation is included in the “Resources.”
3 The UNCTs across the region operate in a variety of political and economic contexts and experience different challenges and the civil society actors operate under severe restrictions in certain parts of the region. Thus, the section presents suggestions (rather than universal or uniform prescriptions), which, hopefully, contain feasible and applicable solutions for country teams working under a very diverse set of conditions.
4 The involvement of a large number of stakeholders such as national experts, academics, CSOs members, government, local institutions and provide sectors representatives is of paramount importance to ensure national ownership.
a. **Raise awareness of the centrality of gender equality for the SDG framework.** Explain the twin-track approach and special focus areas covered by stand-alone SDG 5 and its targets. Visual representations of SDG networks help highlight the connections between SDGs through gender-related targets.
b. **Demonstrate how SDG implementation will help national progress towards gender equality.** Show connections between gender-related SDGs and national landscape of policies and programs concerning gender equality. Explain how progress towards specific SDGs and targets will help to address challenges faced by women and girls (or men and boys).
c. **Explain why ignoring and marginalizing gender equality will dramatically impede the achievement of nationalized/localized SDGs** (alternatively, how gender equality and the empowerment of all women and girls act as accelerators in achieving many SDGs). The messages can be conveyed through specific examples. For instance, partners can show how ignoring gender gaps in access to agricultural equipment, loans and knowledge prevents women from participating in agricultural production and, if not addressed, can impede the government’s efforts to increase the output of the agricultural sector.
**Montenegro**
In Montenegro, the efficient use of social media and online applications helped widen the scope of national consultations on SDG nationalization and analyse the feedback. An SDG web platform was created, and social media was widely used for consultations to promote a multiple-stakeholder approach. Consultations used crowd sourcing, discussion platforms, online questionnaires and surveys, social media like Facebook, Twitter and other platforms). All collected data was sex-disaggregated. Analysis of the consultations and survey data revealed the major themes prioritized by the stakeholders. The UNCT teamed up with grass roots organization to plan outreach events around these themes, also paying attention to the gender balance in the events. The UNCT and its national partners ensured a continuous feedback mechanism, from the digital engagement to the field outreach activities, to take into account all issues that emerged in the course of national consultations.
**Reach out to diverse stakeholders:** The dissemination of messages should strive to cover a diverse set of stakeholders, including line ministries, the national statistical system, parliament, local government, the private sector, civil society organizations, the expert community and the media. UNCTs and national partners should be conscious of working with different constituencies and adjust their mode of engagement accordingly. For example, an awareness raising campaign with a heavy presence in social networks (targeting young, Internet-savvy citizens) should run in parallel with a campaign targeting groups in remote rural areas, senior citizens and language minorities. National consultations provide an efficient way to empower groups of the population subjected to different forms of exclusion and discrimination (including gender-based discrimination). If conducted in inclusive and participatory fashion, national consultations should result in incorporating diverse interests and concerns (“leaving no one behind”).
**Partnership building:** The consultations also offer a great opportunity to start building coalitions across sectors and geographical locations. Obviously, the national machinery and long-time partners in specific ministries and civil society organizations will be actively involved and serve as a driving force in engendering SDGs. However, do not hesitate to seek allies in unusual places (for example, government agencies not normally engaged in assisting women and girls) and continuously work to sensitise and build
capacity within the national government. Parts of the government traditionally viewed as dealing with supposedly “gender-neutral” fields (for example, the ministry of energy/natural resources) can play an important role in SDG implementation and should be sensitized to the centrality of gender equality to achieve the SDGs. Securing private sector involvement in consultations can be instrumental in sensitizing private sector employers and bringing in additional funding. Connections established through gender mainstreaming across SDGs provide ample opportunities for issue-based coalitions.
For example, helping women farmers gain equal access to community-based sources of renewable energy (sun energy related grants distributed by local government) connects SDG 5 to SDG 7.1 (“By 2030, ensure universal access to affordable, reliable and modern energy services”) and SDG 2.3 (“By 2030, double the agricultural productivity and incomes of small-scale food producers, in particular women...”). Such a coalition can bring together local government, ministries of energy and agriculture, environmental groups, rural community development structures, large and small companies involved in food production, farmers associations and women’s non-governmental organizations.
**Finding the right language for communication**: All messages and suggestions regarding gender equality should be culturally sensitive and highlight not only the challenges in national progress towards gender equality, but also the achievements. The messages should be crafted to speak to specific audiences. For example, if the country has already widely used the concept of “sustainability” in its development strategies (as in the case of Turkey), messages targeting government officials and experts should highlight the links between sustainable development and gender equality in Agenda 2030. If the concept of “social and economic exclusion” gained traction in national policy discussions, it is important to emphasize the role of gender-based discrimination as a common generator of social and economic exclusion. Private sector actors may respond well to messages that combine human rights-related language with a business case approach. For general audiences, it is best to avoid technical terms and provide clear, memorable and culturally recognizable references.
**Getting prepared for national consultations**: Several exercises can assist UNCTs and their national partners in the development of an inclusive, coherent vision that places gender-related SDGs and targets squarely within the nationalized SDG framework. The exercises will assist in:
a. Mapping the policy and program landscape; mapping national commitments relevant for national progress towards gender equality (including obligations under international treaties).
b. Taking stock of relevant policy resources.
c. Revealing and analysing connections between key country/regional trends in gender equality and SDGs.
d. Envisioning consecutive stages of progress towards gender equality through SDGs. Please see the addendum “Exercises” for descriptions.
Note that national governments often envision SDG implementation as **building on already existing policy frameworks and updating or adapting existing strategies of national development**.\(^5\) Subsequently, UNCTs can provide a platform and expertise to analyse the policy environment and development strategies and identify relevant entry points for mainstreaming gender-related SDGs and targets.
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\(^5\) Results of the survey of UNCTs in the region, conducted in September-October 2016
Joining discussions with concrete inputs: When joining national consultations, UNCTs and national partners should be prepared to offer specific suggestions about gender-related goals and targets across Agenda 2030, which they believe are crucially important for national progress towards gender equality and the empowerment of all women and girls. Specifically:
a. Have the list of SDGs and targets that carry the utmost priority for national progress towards gender equality. It will be useful to highlight the links between national commitments (for example, under CEDAW or the Universal Periodic Review, or according to national plans for gender equality, if applicable) and SDG nationalization priorities.
b. Have a list of adjustments to gender-related targets that reflects the national context and have a preliminary list of indicators for each target.
c. Have a list of entry points for mainstreaming gender-related SDGs and targets into national strategies. For example, outline specific targets/objectives in the national sustainability strategy (or other overarching programs and plans for national development), which can be expanded, adjusted or built upon to embrace gender-related SDGs and targets.
d. Have one-pager(s) a) explaining the importance of gender-related SDGs and targets for overall national progress towards the Sustainable Development Agenda, b) demonstrating the linkages between existing national commitments towards gender equality and the empowerment of all women and girls and the prioritized SDGs and targets and c) offering relevant national data to highlight gender equality challenges.
Tip: Capitalize on the past experience of engagement with the national government gained from different national consultation processes (Turkmenistan).
What to watch for: Countries have limited resources for implementing SDGs: some tough decisions will have to be made to avoid stretching financial and administrative resources too thin. UNCTs and national actors should develop an action plan for gender mainstreaming that includes courses of action for various scenarios, such as possible trade-offs (gender-related targets substituted for more general ones), the marginalization of gender equality in the discussions and the weakness of the national machinery, both in terms of power and resources.
What to watch for: Commitments not supported by relevant budget allocations run a high risk of failure. Gender-responsive budgeting tools help to analyse how much money governments assign for the SDGs and what share of these allocations is likely to benefit women and girls. The tools can also estimate how addressing the needs of women and girls can increase the efficiency of budget allocations under specific objectives.
Step 2: Institutional mechanisms for SDG implementation established and functional
National governments often either set up a specific institutional mechanism to coordinate and supervise SDG implementation (for example, an inter-ministerial council) or assign the task to an already existing government body (for example a Ministry of Economic Development). UNCTs and national actors should use advocacy to ensure strong representation of stakeholders supportive of gender equality in the national coordinating mechanism for SDG implementation.
It is important to have a national machinery for gender equality participating in the coordinating body. However, it is not enough. UNCTs should work with all line ministries and committees to raise awareness and gain support for gender equality. For example, advocacy briefings can be conducted with key decision-makers in respective ministries. UNCTs and partners should also continuously build the government’s capacity to use a gender lens in the development of their SDG implementation strategy or when adjusting existing policies and programs.
The UNCT expertise and platform are indispensable for ensuring that a coordination mechanism continuously upholds gender-related SDGs and targets in the nationalized SD Agenda.
**Tip:** Create a connection between the coordination mechanism and United Nations Development Assistance Framework (UNDAF) Results Groups. Uzbekistan’s Country Team created an institutional connection in the form of core resource persons, experts who mediate between the SDG implementation mechanism (Theme Groups) and the UNDAF system (UNDAF Result Groups).
**What to watch for:** Given the complexity of SDG implementation, national coordination mechanisms are likely to start branching out: working groups (theme groups, sector-based task forces or units) will be tasked with carrying out SDG implementation in their respective sectors or ministries. As these working units become more sector specific, the discussions are likely to turn more “technical” and there is a risk that gender-related issues will be marginalized. To address the risk, UNCTs and national partners should:
a. Conduct advocacy briefings and capacity building with members of “technical” units;
b. Use gender focal points based in government structures (where available);
c. Ensure that the gender lens is applied to all suggested changes to already established SDG policies and targets (include the requirement in Terms of Reference (TORs) for all units tasked with SDG implementation);
d. Disseminate user-friendly tools to help non-specialists view implementation steps through a gender sensitive lens.
**Tip:** It is essential to harmonize the technical inputs provided by UN Agencies (and possibly by other development partners in the frameworks of the Gender Theme Group) internally prior to sharing with the government to ensure that inputs related to the localization of the SDG Targets, including the selection of relevant global SDG indicators and their customization to the national context (Georgia), are coherent and of the highest quality.
**What to watch for:** The localization of SDGs will be done through the active involvement of the local government and, in some countries, community-based structures. It is important to keep in mind that informal (and sometimes formal) authority in local communities may be embedded in patriarchal structures. In such environments, women
and girls may have a hard time voicing their disagreement or talking about their concerns. The UNCT and its partners should make every effort to ensure the real involvement of women and girls in decisions regarding the prioritization of SDGs or the adjustment of targets to reflect local needs.
**Step 3. Setting up monitoring and reporting frameworks and ensuring accountability**
**Purpose:** Setting up a comprehensive and reliable monitoring framework with gender-sensitive indicators is key for tracking national progress towards SDGs (including gender-related ones) and holding national governments (the main duty bearers in SDG implementation) accountable. Thus, this step is very important for civil society organizations, experts and local and national government institutions interested in monitoring the progress achieved under the implementation plans. The gender-sensitive monitoring framework generates data, which can then be used to report on progress, in line with national governments’ commitments to Agenda 2030. Both governmental and civil society sectors involved in this task can greatly benefit from the expertise provided by UN agencies.
**Where to start:** It is best to start by reviewing and mapping already existing monitoring frameworks, relevant for gender equality (for example, a National Action Plan for Gender Equality or CEDAW monitoring and reporting framework). Questions that may inform such exercises include:
→ Which gender-sensitive indicators already exist?
→ How much do these indicators match the gender-related SDGs and targets?
→ Which indicators need to be expanded by adding a requirement to disaggregate data by sex (and other characteristics)? Which necessary indicators are not available?
The mapping of existing indicators should also determine **a)** baselines for available indicators, **b)** comparability of national indicators to global ones, and **c)** regularity and consistency of monitoring frameworks. Identifying gaps is an equally important part of that activity. Gaps in monitoring frameworks (the absence or weakness of indicators) are important: gaps reflect the areas that do not receive necessary attention and areas with low institutional capacity to collect data.
Gaps can also show that a relevant indicator is present but lacks disaggregation by sex/age/residence and other factors. After the mapping is completed, UNCTs and national partners (including the National Statistical System) can proceed to building a monitoring framework for national SDGs.
**Adjusting and disaggregating national indicators:** It is estimated that roughly 1/4 of all SDG targets implicitly or explicitly address gender equality and about 32% of indicators are gender-relevant. (see Chart 2. Indicators)
Countries can use global SDG indicators, supplement global indicators with national ones created from scratch, adjust existing global indicators or modify those. In line with the approach of “no one left behind,” the Sustainable Development Agenda requires that indicators be disaggregated by sex (and other factors such as age/residency/wealth quintile/marital status, etc.). Disaggregation by sex will help monitor the gendered aspect of progress on all targets. The correlations between sex and other socio-economic and demographic characteristics assist in identifying population groups left behind or rendered “invisible” by national averages.
Disaggregation by sex is specifically important for mainstreaming a gender perspective into SDG implementation: by introducing sex disaggregation into the monitoring framework, national partners can ensure that gender-bases differences in progress towards specific targets will not go unnoticed.
To adequately reflect the twin-track approach, monitoring frameworks should include indicators that measure the prevalence of a specific condition or practice among women and girls as well as sex/age disaggregated indicators that register the share of women, girls, men and boys among the population impacted by SDG implementation. For example:
**Indicator measures the prevalence of a specific condition or practice among women and girls.**
\[ \downarrow \]
Proportion of young women aged 15-24 who are in the NEET category (not employed, not in school and not looking for work)\(^6\).
**Indicator measures a share of women, girls, men and boys among population impacted by SDG implementation**
\[ \downarrow \]
Proportion of employed who are own-account (self-employed) workers by sex of worker\(^6\).
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\(^6\) M. Bamberger, M. Segone, F. Tateossian, (2016), Evaluating the Sustainable Development Goals With a “No one left behind” lens through equity-focused and gender-responsive evaluations, p.16 [http://www.evalpartners.org/sites/default/files/documents/evalgender/Eval-SDGs-WEB.pdf](http://www.evalpartners.org/sites/default/files/documents/evalgender/Eval-SDGs-WEB.pdf)
\(^7\) The examples are taken from Data2xo (2014), Ready to Measure: Sixteen Indicators for Monitoring SDG Gender Targets, available from: [http://data2x.org/wp-content/uploads/2014/08/Ready_to_Measure.pdf](http://data2x.org/wp-content/uploads/2014/08/Ready_to_Measure.pdf)
There are several lists of gender-relevant indicators, including those compiled by UN Women, United Nations Economic and Social Council, Statistical Commission, Bureau of the United Nations Statistical Commission and “Ready to Measure: Sixteen Indicators for Monitoring SDG Gender Targets” by Data2xo (for links, please see Addendum I, Resources). Please also refer to “An overview of targets and indicators from a gender perspective” prepared by UNDP Istanbul Regional Hub (in the Addenda).
**Tiers of indicators:** After a list of suggested indicators is compiled, with respective baselines and sources, it may be helpful to use a three-tier classification to sort through existing and suggested indicators. The three-tier classification of SDG indicators was developed by the Expert Group on SDG Indicators. The indicators were classified into three tiers based on their level of methodological development and data availability.
- **Tier 1:** Indicator conceptually clear, established methodology and standards available and data regularly produced by countries.
- **Tier 2:** Indicator conceptually clear, established methodology and standards available but data are not regularly produced by countries.
- **Tier 3:** Indicator for which there are no established methodology and standards or methodology/standards are being developed/tested.
It is important to take into consideration that the three tiers present three different situations with regard to data quality and availability. Only the first tier indicators are based on a consistent and rigorous methodology and have data regularly produced at country level. With the second tier, we are entering a territory where indicators were developed based on a clear methodology and concepts, however, for a variety of reasons, data were not collected or released regularly. The third tier indicators present further challenges, since they are not based on well-tested methodology, involve unclear concepts or are possibly still a subject of discussion among experts. In such circumstances, reliable data are highly unlikely to be available for Tier 3.
Given that the collection of *gender-specific* and *gender-disaggregated data* is still weak in the region, dealing with the second tier indicators is likely to be a challenge common to UNCTs and national partners. To turn the challenge into an opportunity, actors may use the lack of data as a reason to insist on incorporating regular data collection as a necessary requirement to increase the efficiency of proposed implementation plans.
Also, the absence (or insufficiency) of quantitative data should not be an obstacle for focusing the implementation efforts on specific gender-relevant targets. UNCTs and national partners can rely on qualitative research outcomes (specifically, interviews with local experts) to formulate arguments stressing the importance of the incorporation of specific targets into the nationalized SDGs. References to comparable international examples can also help.
Assessing indicators will help determine the reliability and methodological rigour of the proposed monitoring framework. Gender-sensitive indicators classified according to the three tiers can be found in UN Women’s *Monitoring Gender Equality and the Empowerment of Women and Girls in the 2030 Agenda for Sustainable development: opportunities and challenges* (please, see Addendum “Resources” for the link).
Georgia’s experience in adjusting national targets and adding indicators
With the technical assistance of the UN Agencies, gender has been mainstreamed into the indicators measuring the majority of Georgia’s national targets. UNCT and national partners recognized that in order to address the root causes of women’s weak economic and political position in Georgia (such as gender stereotypes and traditional division of work between men and women), joint efforts and political attention needed to focus on SDG 5. Subsequently, UNCT and national partners proposed additional nationalized targets under SDG 5 and suggested indicators for inclusion in Georgia’s 2030 Agenda.
Please see the “Tips and promising practices from the region” Addendum to further explore how the UNCT and national partners in Georgia adjusted indicators to SDG 5.5 to measure the change in “women’s participation in and equal opportunities for leadership at all levels of decision making in political, economic and public life.”
To understand how the global indicators for SDG targets were compiled and get familiar with the monitoring framework proposed for Agenda 2030, please refer to the metadata online resource. The resource is very informative and highly recommended (see the link in Addendum I, Resources).
UNCTs and national partners should work in close collaboration with national statistics systems (NSS) to ensure that indicators are realistic and match the capacity of data collecting bodies. The NSS, line ministries, local government bodies and civil society organizations should be trained in monitoring progress on the SDGs and in using a gender lens when reporting on data generated through monitoring. The NSS and other government structures can also benefit from learning how to make gender-specific and gender-disaggregated data accessible and available for the general public. Creating a capacity development strategy to enable the collection of gender-related SDG indicators may be a good way to organize continuous training and ensure a steady flow of reliable data.
What to watch for: there may be indicators that operate with the “household” as a unit, without disaggregation by sex. The gap should be addressed immediately; otherwise, monitoring will fail to register the gendered impact of SDG implementation and governments will not introduce necessary corrections in their implementation plans.
What to watch for: certain changes (for example, change in cultural and social norms restricting women’s access to resources and mobility in public spaces) are hard to measure with quantitative indicators and are likely to be missed if countries only use quantitative methods of data collection. The monitoring of progress towards SDGs should also pay attention to social changes (attitudes, stereotypes and norms). These changes can be measured with the use of qualitative indicators.
Reporting: Agenda 2030 views reporting as a voluntary action, performed by states. Reporting summarizes the changes reflected by indicators and creates a narrative based on these changes. To ensure that reporting on SDGs is realistic and comprehensive, reporting templates should have a clear requirement to mainstream gender-related data (gender-specific indicators and indicators disaggregated by sex). It might also be helpful to ensure representation from the national machinery in the government unit responsible for periodic review and reporting.
Many national governments in the region have suggested building on existing frameworks (national development strategy or CEDAW), rather than setting up a completely separate monitoring and reporting operation for SDGs. The purpose is to save resources and avoid double reporting cycles. Merging reporting on SDGs with reporting on the National Development Strategy offers several advantages for a gender-responsive monitoring framework: it secures the government’s commitment, regularity of data collection and makes resource allocations more stable. However, the actors involved should be persistent in ensuring that gender-relevant indicators specific to SDGs are not subsumed by the old reporting frameworks.
It is important to ensure that reporting reflects the twin-track approach to gender equality and the empowerment of all women and girls in the national and local process of SDG implementation. The capacity building activities of government and non-government actors responsible for reporting should include a detailed explanation of how periodic reports can reflect the progress under SDG 5 in its connection to the gendered dimension of advancement across all SDGs. Depending on the specific nature of the programmes implemented, a report can show, for example, connections between expanded access to educational and vocational opportunities for women and the gendered dimension of poverty reduction programmes.
What to watch for: Gender equity at times gets lost in discussions surrounding gender equality and the concept is often misunderstood by non-specialists. Targets and indicators directly addressing gender equity (like the following indicator related to Target 1.b.1 *Proportion of government recurrent and capital spending to sectors that disproportionately benefit women, the poor and vulnerable groups*) are relatively scarce in the Agenda. However, the “no one left behind” approach is very equity focused. The approach requires national governments to deliver SDG progress to vulnerable and disenfranchised groups of the population. Subsequently, it is essential to sensitize national actors to the role of gender equity and develop capacity to monitor the effects of SDG implementation on gender equity.
Step 4. Gender-responsive evaluation of progress towards SDGs
**Purpose:** Gender-responsive evaluation enables an analysis of the gendered impact of SDG implementation (or specific interventions), highlights the gendered aspects of exclusion, measures the pace of progress towards gender-related SDGs and targets, reveals the bottlenecks and draws lessons from challenges, failures and achievements. The gender-responsive evaluation of the SDG implementation will not be a repetition of monitoring reports, but it will explain why the dynamics and outcomes of implementation are the way they are.
Designing an evaluation framework for SDG implementation is a challenging process. SDG implementation is a very complex multi-level operation (three thematic areas, cross-sectoral, several levels of government, different geographical locations, a very vast and diverse pool of beneficiaries), which requires evaluation techniques capable of processing complexity.
**Where to start.** UNCTs and national partners should strive to include the commitment to regularly conduct gender-responsive evaluations in the national strategy. The weakness of national Monitoring and Evaluation capacities was indicated by most UNCTs in the region as one of the primary challenges in SDG implementation.\(^8\) UNCT’s expertise and support will be indispensable in building the capacity of national M&E systems to conduct gender-responsive evaluations. It is also crucial to raise awareness of national governments and civil society organizations about the importance of gender-responsive evaluations for achieving sustainability.
Any evaluation starts with formulating evaluation questions. UNCT and national partners should dedicate time to determine what they would like to know and understand as a result of gender-responsive evaluations. Questions can focus on overall progress towards
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\(^8\) Results of the survey of UNCTs in the region, conducted in September-October 2016
SDGs or specific interventions. For example, “How did SDG implementation deliver on a specific set of gender-related SDGs and targets?,” “Does the progress towards nationalized SDGs and targets reflect the twin-track approach to gender equality?” or “Have specific interventions had the intended impact of increasing economic opportunities for women?” or “Which setbacks and bottlenecks slowed/reversed the progress towards SDG 5 at local level (among specific groups)?”
A good example of a gender-sensitive equity-focused evaluation framework for SDG implementation can be found in *Evaluating the Sustainable Development Goals with a “No one left behind” lens through equity-focused and gender-responsive evaluations* (see the link in the Addendum “Resources”). This informative resource will assist in:
→ Developing a gender-responsive evaluation framework for SDG implementation;
→ Designing data collection and analysis tools for equity-focused and gender-responsive evaluations;
→ Engaging qualitative and participatory evaluation methods to explore sensitive topics (such as domestic violence) and examine behavioural change;
→ Disseminating evaluation results and building advocacy based on evaluation findings.
**Tip:** Qualitative evaluation methods enable the evaluation to trace changes in gender-based stereotypes and attitudes, which will not be captured by numerical indicators.
**Tip:** Ensure that the twin-track approach is included in the evaluation questions and reflected in the key elements of the evaluation framework. For example, while determining the performance standards to evaluate SDG implementation, it is important to ensure that the “successful performance” of specific programmes include benchmarks of progress in the status of women and girls.
**Tip:** Gender-responsive evaluation is not just about direct outcomes. Evaluation can act as a participatory and empowering process. Try to use empowering techniques, such as Appreciative Inquiry, to engage beneficiaries in the evaluation process and generate conditions to empower those whose voices are routinely silenced.
**What to watch for:** Gender-responsive evaluation should not be cast as a sole responsibility of the national machinery on gender equality. This will isolate and marginalize evaluation outcomes and undermine efforts to mainstream gender equality into the fabric of national SDG implementation. UNCTs and national partners should advocate for gender-responsive evaluations to become a regular feature jointly commissioned by multiple actors (including key government ministries, local governments and civil society).
What to watch for: Numerical indicators that lack sex, age, residency, disability, wealth quintile disaggregation are likely to conceal processes affecting disadvantaged and vulnerable groups. To avoid this situation, specific evaluation questions and corresponding targets, baselines, sources and indicators should be dedicated to reflecting the changes experienced by these groups (as a result of or in association with SDG implementation).
What to watch for: Any responsibly conducted evaluation, apart from intended results, also examines the unintended outcomes of programs and projects. Given the large scale and complexity of SDG implementation, UNCTs and national partners have to be prepared for a considerable load of unintended outcomes (some affecting women and men in different ways).
It is crucially important to equip evaluation frameworks with tools capable of measuring the gendered dimension of an unintended impact. The task is challenging politically, since unintended negative impacts on gender equality and women’s rights may result from certain large-scale national priority programmes. The UNCT should support national partners to be a) prepared to conduct gender-responsive evaluations of such outcomes; and b) use evaluation findings in advocacy efforts to demand the reversal or adjustment of programmes that have detrimental effects on gender equality.
Photo: UNFPA
Responding to the needs of pregnant women in Turkmenistan.
SDGs AND GENDER EQUALITY
Addendum
Addendum I Resources
Addendum II Regional advocacy brief on gender equality, women’s rights and women’s empowerment
Addendum III Exercises
Addendum IV Tips, promising practices and lessons learned from UN Country Teams
Addendum V How countries are implementing SDGs
31-year-old Ayday Cherikbayeva has Down syndrome. She is an award-winning Kyrgyz folk dancer, touring both in Kyrgyzstan and internationally.
Addendum I
Resources
Gender and SDGs
United Nations Development Programme (UNDP) Istanbul Regional Hub, *Sustainable Development Goals: An overview of targets and indicators from a gender perspective*, (2016), available from: http://www.eurasia.undp.org/content/dam/rbec/docs/undp-rbec-SDGtargets-and-indicators-gender-overview-UNDP.pdf
United Nations Entity for Gender Equality and the Empowerment of Women (UN Women), *A transformative stand-alone goal on achieving gender equality, women’s rights and women’s empowerment: imperatives and key components, in the context of the post-2015 development framework and sustainable development goals*, (2013), available from: http://www.unwomen.org/en/what-we-do/~/media/AC04A69BF6AE48C1A23DECAEED24A452.ashx
UN Women, *Women and the Sustainable Development Goals (SDGs)*, available from: http://www.unwomen.org/en/news/in-focus/women-and-the-sdgs
United Nations Statistics Division, *The Sustainable Development Goals Report 2016*, (2016), available from: http://unstats.un.org/sdgs/report/2016/
UNFPA, *ICPD Beyond 2014 High-level Global Commitments. Implementing the Population and Development Agenda* (2016), available from: http://www.unfpa.org/publications/icpd-beyond-2014-high-level-global-commitments
United Nations Development Group (UNDG), *The Sustainable Development Goals are coming to Life: Stories of Country Implementation and UN Support*, available from: https://undg.org/document/the-sustainable-development-goals-are-coming-to-life-stories-of-country-implementation-and-un-support/
UNDG, *Mainstreaming the 2030 Agenda for Sustainable Development. Interim Reference Guide to UN Country Teams*, (2015), available from: http://www.undp.org/content/dam/undp/library/MDG/Post2015-SDG/UNDP-SDG-UNDG-Reference-Guide-UNCTs-2015.pdf
United Nations Research Institute for Social Development (UNRISD), Esuna Dugarova and Nergis Gülasan, *Global trends: Challenges and Opportunities in the Implementation of the Sustainable Development Goals*, (2017), available from: http://www.undp.org/content/undp/en/home/librarypage/sustainable-development-goals/global-trends--challenges-and-opportunities-in-the-implementatio.html
UNDP-World Bank Group, *Transitioning from the MDGs to the SDGs*, available from: http://www.undp.org/content/undp/en/home/librarypage/sustainable-development-goals/transitioning-from-the-mdgs-to-the-sdgs.html
UNFPA, International Institute for Applied Systems Analysis and the Wittgenstein Centre for Demography and Human Capital, J. Vobecka, W.P. Butz, G.C. Reyes, *Population Trends and Policies in the UNECE Region: Outcomes, Policies and Possibilities* (July 2013), available from: http://eeca.unfpa.org/sites/default/files/pub-pdf/Population%20Trends%20and%20Policies%20in%20the%20UNECE%20Region%20%28English%29.pdf
UNECE Regional Conference, *Enabling choices: population priorities for the 21st century. Chief's summary*, (UNECE, 1-2 July, 2013), available from: https://www.unece.org/fileadmin/DAM/pau/icpd/Conference/Other_documents/Chair-s-Summary.pdf
UNDP, *UNDP support to the integration of gender equality across the SDGs including Goal 5*, (2016), available from: www.undp.org/content/dam/undp/library/SDGs/S_Gender_Equality_digital.pdf
---
9 All links last accessed in May 2017
S. Nicolai, C. Hoy, T. Berliner, T. Aedy, *Projecting progress - Reaching the SDGs by 2030* (2015), available from https://www.odi.org/sites/odi.org.uk/files/odi-assets/publications-opinion-files/9938.pdf
J. Sachs, G. Schmidt-Traub, C. Kroll, D. Durand-Delacre and K. Teksoz, *SDG Index & Dashboard s – A Global Report*, (York: Bertelsmann Stiftung and Sustainable Development Solutions Network (SDSN), 2016), available from: http://sdgindex.org/assets/files/sdg_index_and_dashboards_compact.pdf
UN Women (2016), *Supporting the SDGs with UN Women’s flagship programmes*, available from: http://www.unwomen.org/-/media/headquarters/attachments/sections/library/publications/2016/fpi-brief-sdgs-en.pdf?vs=2600
UNICEF, *Is every child counted? Status of data for children in the SDGs*, (2017), available from: https://data.unicef.org/resources/every-child-counted-status-data-children-sdgs/
UNICEF, *Key Asks and Principles for 2017 National Review Activities: Sector Specific Issues Briefs for the 2017 High Level Political Forum (HLPF)*, (2017), available from: https://www.unicef.org/agenda2030/69525_69527.html
UNFPA, *The State of World Population 2016 Report*, (UNFPA, 2016), available from: http://www.unfpa.org/swop
UNFPA, J. Kato-Wallace, G. Barker, L. Sharafi, L. Mora, G. Lauro, *Adolescent boys and young men: engaging them as supporters of gender equality and health and understanding their vulnerabilities*. (Washington, D.C.: Promundo-US. New York City: UNFPA, 2016), available from: http://www.unfpa.org/publications/adolescent-boys-and-young-men
**Nationalization of the SDGs**
UNDG, *Mainstreaming the 2030 Agenda for Sustainable Development, Reference Guide to UN Country Teams*, (2017), available from https://undg.org/document/mainstreaming-the-2030-agenda-for-sustainable-development-reference-guide-for-un-country-teams/
UNDG Europe and Central Asia, *Country-level needs for SDG implementation in Europe and Central Asia*, (2016), available from: https://www.unece.org/fileadmin/DAM/sustainable-development/SDG-Needs-Assessment_RCs-and-UNCTs.pdf
Sustainable Development Solutions Network (SDSN), *Getting Started with the Sustainable Development Goals - A Guide for Stakeholders*, (2015), available from: http://unsdsn.org/wp-content/uploads/2015/12/151211-getting-started-guide-FINAL-PDF-.pdf
UNDG, MAPS - *Mainstreaming, Acceleration and Policy Support Strategy for Post-2015 Implementation*, (2015), available from: https://www.consciousglobalchange.org/doclib/UNDG-MAPS-Strategy-June-2015.pdf
Asia Pacific Regional CSO Engagement mechanism (APRCEM), available from: http://asiapacificrcem.org/
**Gender-responsive budgeting**
UN Women/Sida GRB Project/Friederich Ebert Foundation, *Gender-Responsive Budgeting: Analysis of Budget Programmes from Gender Perspective* (2016), available from: http://eca.unwomen.org/en/digital-library/publications/2016/05/gender-responsive-budgeting--analysis-of-budget-programmes-from-gender-perspective
**SDGs as a network**
D. Le Blanc, *Towards integration at last? The sustainable development goals as a network of targets*, (2015), available from: http://www.un.org/esa/desa/papers/2015/wp141_2015.pdf
Sustainable Development Goals (SDGs) network visualization, available from: http://blog.kumu.io/a-toolkit-for-mapping-relationships-among-the-sustainable-development-goals-sdgs/
M. Peleah, *Sustainable Development Goals as a Network of Targets*, (2015), available from: http://peleah.me/sdgs-as-network/
**Monitoring and reporting**
Inter-agency and Expert Group on Gender Statistics (IAEG-GS), *Evidence and Data for SDG 5: Achieve Gender Equality and Empower all Women and Girls – The role of the Minimum Set of Gender Indicator*, available from: http://unstats.un.org/unsd/post-2015/activities/egm-on-indicator-framework/docs/Background%20note%20by%20IAEG-GS%20on%20SDGs%20indicators%20framework%20to%20monitor%20gender%20equality_EGM-Feb2015.pdf
UN Women, *Position Paper – Monitoring gender equality and the empowerment of women and girls in the 2030 agenda for sustainable development: opportunities and challenges*, (2015), available from: http://www.unwomen.org/-/media/headquarters/attachments/sections/library/publications/2015/indicatorpaper-en-final.pdf?vs=1&d=20150917T23452
Data2xo, *Ready to Measure – Sixteen Indicators for Monitoring SDG Gender Targets*, (2016), available from: http://data2x.org/wp-content/uploads/2014/08/Ready_to_Measure.pdf
Tier Classification for Global SDG Indicators, (21 December 2016), available from: http://unstats.un.org/sdgs/files/meetings/iaeg-sdgs-meeting-04/Tier%20Classification%20of%20SDG%20Indicators_21%20Dec%20for%20website.pdf
Data2xo, M. Buvinic, F. Furst-Nichols, G. Koolwal, *Mapping Gender Data Gaps*, (2014), available from: http://data2x.org/wp-content/uploads/2014/11/Data2X_MappingGenderDataGaps_FullReport.pdf
*SDG Indicators: metadata depository*, available from: http://unstats.un.org/sdgs/metadata/
*SDG Indicators - Global Database*, available from: http://unstats.un.org/sdgs/indicators/database/
UN Women, *Making every woman and girl count: Supporting the monitoring and implementation of the SDGs through better production and use of gender statistics*, (2016), available from: http://www.unwomen.org/-/media/headquarters/attachments/sections/how%20we%20work/flagship%20programmes/fpi-statistics-concept-note.pdf?vs=7
**Gender-responsive evaluation**
M. Bamberger, M. Segone, F. Tateossian, *Evaluating the Sustainable Development Goals With a “No one left behind” lens through equity-focused and gender-responsive evaluations*, (2016), available from: http://www.evalpartners.org/sites/default/files/documents/evalgender/NY-Events-Report_WEB.pdf?v=1.2
M. Bamberger, M. Segone, and S. Reddy, *National evaluation policies for sustainable and equitable development: How to integrate gender equality and social equity in national evaluation policies and systems*, (2014), available from: http://www.evalpartners.org/library/selected-books
UN Evaluation Group, *Integrating human rights and gender equality in evaluation: Guidance document*, (2013). Available from: http://www.uneval.org/document/detail/980
M. Bamberger and M. Segone, *How to design and manage equity focused evaluations*, (New York, NY: UNICEF, 2011), available from: http://www.evalpartners.org/library/selected-books
UN Evaluation Group, *Integrating human rights and gender equality in evaluation: Guidance document*, (2013), available from: http://www.evalpartners.org/library/selected-books
UN Women, *How to manage gender-responsive evaluation: Evaluation handbook*, (Independent Evaluation Office. New York, NY: UN Women, 2015), available from: http://www.unwomen.org/en/digital-library/publications/2015/4/un-women-evaluation-handbook-how-to-manage-gender-responsive-evaluation
UN Evaluation Group (2013), *Integrating human rights and gender equality in evaluations: Guidance document*. Available from: www.unevaluation.org/document/download/2107
Eval Partners, Free e-learning programme in development evaluation, available from: http://elearning.evalpartners.org
P. Rogers, “52 weeks of Better Evaluation: Week 4: Including unintended impacts”, 24 January 2013, available from: http://betterevaluation.org/en/blog/unintended_outcomes
Better evaluations, "Identify Potential Unintended Results," available from http://betterevaluation.org/en/plan/define/identify_potential_unintended_results
David L. Cooperrider and Diana Whitney, *A Positive Revolution in Change: Appreciative Inquiry*, (Berrett-Koehler Publishers, 2005), available from: https://appreciativeinquiry.case.edu/intro/whatisai.cfm
**Financing**
UN Women, *Handbook on costing gender equality*, (2015), available from: http://gender-financing.unwomen.org/en/resources/h/a/n/handbook-on-costing-gender-equality
Women Deliver, *The Investment Case for Girls and Women*, available from: http://womendeliver.org/2016/the-investment-case-for-girls-and-women
**Gender mainstreaming tools**
UN Women, *Repository of gender mainstreaming policies in UN System entities* (2015), available from: http://www.unwomen.org/en/how-we-work/un-system-coordination/gender-mainstreaming
UN Women (2014), *Gender Mainstreaming in Development Programming – A Guidance Note*, available from: http://www.lacult.unesco.org/docc/gendermainstreaming-issuesbrief-en.pdf
GGEO the Global Gender Environmental Outlook, United Nations Environment Program (UNEP), (2016), available from: http://web.unep.org/ggeo
Sustainable Development Knowledge Platform. Women’s Major Group Major Group, *The Women Major Group’s vision and priorities for the Sustainable Development Goals*, available from: http://www.stakeholderforum.org/fileadmin/files/SD2015%20Position%20Paper_Womens%20MG_v1_March%202014.pdf
SDGs and Gender Equality
37
Addendum II
Regional advocacy brief on gender equality, women’s rights and women’s empowerment
Gender equality is an engine for progress on all the SDGs. A series of UN advocacy papers that take a multi-dimensional approach to gender equality and propose strategies for the region is available at: https://undg.org/wp-content/uploads/2017/01/2017-Regional-Advocacy-Paper-FINAL-19-June-2017.pdf and http://www.un-rcm-europecentralasia.org/fileadmin/DAM/RCM_Website/Publications/ECA_Regional_Advocacy_Paper_2017.pdf. They cover the following issues: population dynamics, movements of refugees, migration and resilience, decent jobs, social protection, health and education, energy, production and consumption, agriculture and rural development, ecosystems, sustainable development, governance and partnerships.
Appended here is the advocacy paper on Gender Equality, Women’s Rights and Women’s Empowerment, which focuses on SDG 5.
What is at stake?
Gender equality, women’s rights and women’s empowerment are key to accelerating sustainable development. Gender equality and empower women – signalled global recognition that this is both an important development goal in itself, and a key to the success of all the other goals. The 2030 Agenda for Sustainable Development contains a specific stand-alone goal to tackle the gender inequalities that remain widespread and persistent across the world and which leave women disproportionately represented amongst the poorest and most marginalised people.\textsuperscript{10} Gender equality is also prioritised across other goals through concrete, gender-specific targets and indicators, including in the areas of poverty, education, health, jobs and livelihoods, food security, environmental and energy sustainability, and stable and peaceful societies. None of these development goals will be achieved without addressing gender inequality, women’s rights and women’s empowerment. Thus, Agenda 2030 opens new opportunities for addressing regional challenges in reaching gender equality and empowerment for all women and girls.
Story of the region
Since 2013, the situation regarding gender equality, women’s rights and the empowerment of women and girls in the region has been characterized by uneven progress, with MDG 3 being only partially achieved. Given gender inequality challenges in the region, and pockets of severe poverty and inequality within individual countries, leaving no one behind entails addressing a wide spectrum of challenges and reaching out to the most vulnerable communities.
Countries in the region have undertaken efforts to increase women’s labour force participation, reduce occupational segregation and the gender pay gap, facilitate the reconciliation of employment and family responsibilities, support women’s entrepreneurship or enhance female participation in top-level economic decision-making. Nevertheless, significant gender gaps remain and discriminative gender attitudes and patriarchal values continue having a strong negative impact on the progress towards gender equality. Most policy innovation and progress in the area of women’s economic empowerment in the region has been achieved in the EU.\textsuperscript{11}
Progress in women’s political participation and representation has been slow. Numerous models of quotas and other measures to promote women in elected bodies have been developed, but have rarely achieved a major change in the unequal distribution of power between women and men. With very few exceptions, female political representation across all levels remains far below the 40 per cent recommended by the Council of Europe as indicating balanced representation. Assessing progress in women’s political power beyond elected positions is difficult and, because of weak data, particularly so in the Europe and Central Asia region. Women are largely underrepresented in governance bodies and are rarely leading core ministries, top judiciary ranks and major political parties.
Civil society, historically a strong channel for women’s social and political mobilization, is currently under severe pressure in some parts of the region (limitations on mobility, activities and foreign funding).\textsuperscript{12} With civil society organizations shut down or isolated from the political process in some countries, civic space for women’s participation and
\textsuperscript{10} Sustainable Development Goal 5: Achieve Gender Equality and Empower all Women and Girls
\textsuperscript{11} Beijing +20 Review Meeting, United Nations Economic and Social Council, Economic commission for Europe, 2014, (available from: http://www.unece.org/fileadmin/DAM/Gender/documents/Beijing%2BIS/ECE.AC.28.2014.3.E.pdf)
\textsuperscript{12} UN Human Rights Council: Civic Space Restrictions in Central Asia and Eastern Europe must be addressed, Article 19, 22 June 2015 (available from: https://www.article19.org/resources.php/resource/38010/en/un-hrc-civic-space-restrictions-in-central-asia-and-eastern-europe-must-be-addressed)
influence is shrinking. National machineries for the promotion of gender equality and the empowerment of women are weak, lacking in funding and a strong mandate. A sound legislative base and policy commitments to gender equality and the empowerment of women and girls are not consistently followed by the introduction of strong and consistent implementation mechanisms.\textsuperscript{13}
Gender-based discrimination systematically obstructs women’s economic opportunities and serves to reproduce social exclusion and poverty. In many parts of the region, women’s labour force participation rate (LFPR) is fairly high (although still lower than male LFPR in all countries) and women outperform men in educational achievements. However, this advantage fails to translate into women’s economic empowerment. Even in countries with educational gender parity, or a higher level of education of women, educational success does not translate into proportionate economic success and political decision-making power for women. The mismatch is clearly documented in the EU, as well as Switzerland.\textsuperscript{14}
The gender wage gap constitutes a major setback for women’s economic opportunities: women’s gross hourly earnings in 2015 were, on average, 21.8 per cent less in Central and Eastern Europe and Central Asia,\textsuperscript{15} and 16 per cent less in the countries of the European Union.\textsuperscript{16} A large portion of the wage gap stems from gender-based discrimination. All across the region, occupational segregation persists with women concentrated in low-paying sectors of the economy and is perpetuated through educational choices, based on gendered stereotypes about types of work “suitable” for men and women. Despite impressive educational achievements of women in tertiary education, men still have higher chances of being promoted up the career ladder. Women account for a minor share among top managerial and business leaders in the region. The gendered employment gap persists: women are 30 per cent less likely to be employed than men.
Throughout the region, women work longer hours than men when unpaid work is factored in. A disproportionate load of unpaid care and domestic work provided by women and girls remain largely unrecognized and undervalued. On average, in the region women perform two and a half times more unpaid care and domestic work than men,\textsuperscript{17} the difference increasing to 8 times in parts of the region.\textsuperscript{18} Because of the responsibilities associated with both unpaid care work and productive employment, women often resort
\textsuperscript{13} Europe and Central Asia, Social Institutions & Gender Index, SIGI Regional Report, OECD, 2015. p.9 (available from http://www.oecd.org/dev/development-gender/SIGI-BrochureECA-2015-web.pdf)
\textsuperscript{14} Beijing +20 Review Meeting, United Nations Economic and Social Council, Economic commission for Europe, 2014. (available from: http://www.unece.org/fileadmin/DAM/Gender/documents/Beijing%2BIS/ECE.AC.28.2014.3.E.pdf)
\textsuperscript{15} Eurostat, 2015 and Progress of the World’s Women 2015-2016, Transforming Economies, Realizing Rights, UN WOMEN (available from: http://www.unwomen.org/en/digital-library/publications/2015/4/progress-of-the-worlds-women-2015).
\textsuperscript{16} http://ec.europa.eu/justice/newsroom/gender-equality/infographs/equal-pay-day-2015/equal-pay-day/index_en.html, Progress of the World’s Women 2015-2016, Transforming Economies, Realizing Rights, Trends & Statistics, p.87, UN WOMEN (available from: http://www.unwomen.org/en/digital-library/publications/2015/4/progress-of-the-worlds-women-2015).
\textsuperscript{17} Progress at Risk: Inequalities and Human Development in Eastern Europe, Turkey and Central Asia, Regional Human Development Report, United Nations Development Programme, 2016 (available from: http://hdr.undp.org/en/content/regional-human-development-report-2016-eastern-europe-turkey-and-central-asia)
\textsuperscript{18} United Nations Economic commission for Europe, Statistical Database (available from: http://w3.unece.org/PXWeb/en/)
to part-time employment.\textsuperscript{19} Women are also more likely to be employed in insecure jobs (contributing family worker and informal domestic worker), labouring without contract, regular pay or rights’ protection.
Government introduction of austerity measures (including subsidy reduction, wage cuts in public sector, pension and health reform and safety net transformation)\textsuperscript{20} in some countries of the region has multiple gendered implications. For example, reductions in wages and jobs in public health, public education and social services mainly affect women, who are overrepresented among the employees in these sectors. Reductions in pensions and healthcare spending further impede the access of women and girls (even more so, women and girls with disabilities, those in rural areas, or poverty stricken areas) to crucial services for reproductive and sexual health. While the adolescent fertility rate is 18 in the region, it can go up to 59 births per 1,000 women ages 15-19.\textsuperscript{21}
Decreased public investment in childcare, elderly and disabled care (for example, daycare facilities, personnel and training) makes families and states rely heavily on unpaid care provided by women and girls. The high dependency of families on women’s unpaid labour keeps all women, including those educated and highly skilled, away from formal employment and good career opportunities, and undermines their ability to accumulate lifetime savings. This also has the potential of deprioritizing girls’ education and preventing women and girls from realizing their full economic, social and political potential.
Implementation of laws and policies remains weak, particularly in Eastern Europe and Central Asia. Here, barriers in the access to services and limited access to justice remain key concerns for women, and for specific groups of women also in other countries, such as rural women, ethnic/national minorities, women with disabilities and migrants
A wave of conservative, nationalist and xenophobic sentiment and politics is on the rise in some countries in the region.\textsuperscript{22} In some cases, the rhetoric used by political and social actors, casts women as repositories of national values. Re-traditionalization often supported by influential religious institutions, ties women’s primary value to their reproductive function, maternal care and the private sphere of home. In parts of the region, women’s reproductive rights are targeted and limited through specific pro-natal policies. Harmful traditional practices are persistent in areas across the region, with evidence of female genital mutilation/cutting in at least one country. Child marriage, albeit hard to document, is estimated to affect girls\textsuperscript{23} in Eastern Europe and Central Asia, with estimates for individual countries ranging from 27.2 per cent to 2.2 per cent.\textsuperscript{24} Child marriage is
\textsuperscript{19} \textit{Progress of the World’s Women 2015-2016. Transforming Economies, Realizing Rights, Trends & Statistics}, p.105, UN WOMEN (available from: http://www.unwomen.org/en/digital-library/publications/2015/4/progress-of-the-worlds-women-2015).
\textsuperscript{20} \textit{The Decade of Adjustment: A Review of Austerity Trends 2010-2020 in 187 Countries}, Isabel Ortiz, Matthew Cummins, Jeronim Capaldo, Kalaivani Karunanethy; International Labour Office. Geneva: ILO, 2015 (Extension of Social Security Series No. 53) (available from: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2685853)
\textsuperscript{21} The World Bank: Databank (available from: http://data.worldbank.org/indicator/SP.ADO.TFRT)
\textsuperscript{22} \textit{Civil society organizations from Europe and Central Asia call for action and accountability at Beijing+20 review}, UN Women (available from http://www.unwomen.org/en/news/stories/2014/11/europe-casco-beijing-review#sthash.oAY7UP7N.dpuf)
\textsuperscript{23} The practice of child marriage impacts boys as well, but on a lesser scale than girls.
\textsuperscript{24} \textit{Child Marriage in Eastern Europe and Central Asia}, Issue Brief, UNFPA, 2015 (available from: http://eeca.unfpa.org/sites/default/files/pub-pdf/SWOP2016%20Regional%20Supplement%20EECA.pdf)
reported to be even more prevalent among certain population groups.\textsuperscript{25} Child marriage is associated with early school dropout and early childbirth, perpetuating poverty, making women more vulnerable to domestic violence and social exclusion in an intergenerational cycle of violence against children.\textsuperscript{26}
The digital divide commonly disadvantages women and girls. For example, in Central Asia women have 30 per cent less access to Internet compared to men,\textsuperscript{27} and undermines their chances to obtain skills necessary for labour market transformation caused by the Fourth Industrial Revolution.
Gender-biased sex selection persists in some parts of the region.\textsuperscript{28} The practice, based on tradition of son preference, generated a skewed ratio between male and female births and has already resulted in an estimated 171,000 “missing” girls.\textsuperscript{29} The practice inflicts a lasting damage on women’s health, reinforces a culture of low value placed on girls and in two decades it will translate into a demographic imbalance affecting men’s marriage prospects, the potential to increase human trafficking, gender-based violence, and political unrest.
The benefits of a demographic dividend can be seriously limited if women and girls are not equipped with highly relevant education and skills. The gender gap in access to decent jobs, characteristic for many countries across the region, can also undermine the positive effect of demographic dividend.\textsuperscript{30} Population ageing affecting some countries in the region has a key gender dimension: women will constitute a majority within the aging population. Their burden of unpaid care work will increase, and elderly women will be exposed to several risks: old age poverty (due to pension gap), increased health and mental health risks in the situation of inadequate healthcare services, increased economic dependency and vulnerability to gender-based violence.\textsuperscript{31}
Twenty six per cent of women in Eastern Europe, 23 per cent in Central Asia and 19 per cent in Western Europe have experienced either physical and/or sexual violence by an
\begin{itemize}
\item[25] According to the research data, 30 per cent of Roma girls in ten countries are married before the age of 18, compared to 4.5 per cent of girls in overall population (Asenjo, A., Bancalari, A., Castillo, C., D’Arcy, M. and Raigada, T. \textit{Mind the Gap. Gender Disparities in Adolescent Wellbeing Outcomes in Central and Eastern Europe and Central Asia}, LSE Capstone Report, UNICEF, March 2016, p. 79).
\item[26] \textit{Focus on children from ethnic and linguistic minorities in Central and Eastern Europe and Central Asia}, Issue Brief, UNICEF, 2016, (available from: https://www.unicef.org/ceecis/2016_Children_from_minorities.pdf)
\item[27] \textit{Women and the Web, Bridging the Internet gap and creating new global opportunities in low and middle-income countries}, Report by Intel, 2013, p. 10 (available from: http://www.intel.com/content/dam/www/public/us/en/documents/pdf/women-and-the-web.pdf) Skewed sex ratios registered in Azerbaijan (second only to China), Armenia, Georgia, Albania, Montenegro, the former Yugoslav Republic of Macedonia, Kosovo, and Turkey.
\item[28] Skewed sex ratios registered in Azerbaijan (second only to China), Armenia, Georgia, Albania, Montenegro, the former Yugoslav Republic of Macedonia, Kosovo, and Turkey.
\item[29] \textit{Preventing gender-biased sex selection in Eastern Europe and Central Asia}, Issue Brief 4, UNFPA, 2015 (available from: https://www.unfpa.org/sites/default/files/resource-pdf/GBSS%20Brief_WEB.pdf).
\item[30] \textit{Investing in Young People in Eastern Europe and Central Asia}, Issue Brief, UNFPA, updated in January 2015 (available from: http://eeca.unfpa.org/en/publications/investing-young-people-eastern-europe-and-central-asia).
\item[31] Maurizio Bussolo, Johannes Koettl and Emily Sinnott. 2015. \textit{Golden Aging. Prospects for Healthy, Active and Prosperous Aging in Europe and Central Asia}. Washington DC: World Bank (available from: http://documents.worldbank.org/curated/en/647461467997250805/pdf/97714-PUB-PUBLIC-Box391451B-9781464803536.pdf)
\end{itemize}
intimate partner or sexual violence by a non-partner.\textsuperscript{32} Crisis-affected areas have higher rates of gender-based violence (GBV) in emergencies (for example, women IDPs in Ukraine experience three times more violence than host community residents).\textsuperscript{33} Most countries have legislation addressing GBV/violence against women (VAW). But laws focus on domestic violence and rarely mention sexual harassment and conflict-related sexual violence. GBV laws in many countries still lack strong implementation and monitoring mechanisms.
In recent years, the eastern Europe and Central Asia region has become more prone to natural disasters as a result of climate change. Women and girls are disproportionately affected by disasters and climate change due to multiple forms of discrimination that they face. This is due to poor access to resources, information and decision-making processes. There is good evidence that women are more vulnerable to climate change than men: in poor areas women are often the poorest. In addition, some studies show that the mortality rate of women in natural disasters is often much higher than that of men.\textsuperscript{34}
To better understand complex regional trends and develop relevant interventions, comprehensive measurement, based on reliable and comparable data, is necessary. Despite some good developments, there are many gaps in the availability, accessibility, analysis and use of gender statistics and sex-disaggregated data (for example, on the prevalence of VAW). The use of gender statistics in setting national development priorities and policy formation remains quite limited.
\textbf{What needs to happen?}
Key trends in the region illustrate that elimination of gender inequality and a push towards the empowerment of all women and girls represent both \textit{a driver/accelerator} of progress towards all SDGs and a central part of the \textit{solution} for the sustainable development of the whole region. For example, the efforts to reduce growing inequality in the region will have to acknowledge the impact of weakened social protection on limited economic opportunities of women and girls. Promoting peaceful and inclusive societies in the region, building sustainable cities and communities, ensuring sustained, inclusive and sustainable economic growth is impossible without tackling women’s exclusion from political and social leadership, pervasive impact of GBV and harmful practices, exploitation of female migrants and abuse of women’s rights. Issues of climate change and building resilience to disasters can only be addressed through increasing women’s access to resources and information and their participation in decision-making processes.
• \textbf{Expand women’s economic opportunities and support the economic empowerment of all women and girls.} This includes designing and implementing macroeconomic policies that enhance women’s economic opportunities and ensure access to decent work and synergy between macroeconomic and social protection policies; ensure that women’s right to own and control land and other forms of property is legislatively secured and supplemented by policies and programmes that enhance women’s access to technologies and financial services, including microfinance; evaluating and rewarding
\textsuperscript{32} Combatting Violence against Women and Girls in Eastern Europe and Central Asia, Issue Brief N 6, UNFPA (available from: http://eeca.unfpa.org/sites/default/files/pub-pdf/21770%20Brief_web.pdf).
\textsuperscript{33} Gender-based violence in the Conflict-Affected Regions of Ukraine, Ukrainian Center for Social Reforms, UNFPA, 2015, p. 29 (available from: http://reliefweb.int/sites/reliefweb.int/files/resources/gbv_study_2015_final_eng.pdf)
\textsuperscript{34} Gender, Environment and Climate Change, UN Women and UNDP, 2015 (available from: http://eca.unwomen.org/en/digital-library/publications/2013/01/gender-environment-and-climate-change)
unpaid care and domestic work, through appropriate measurement and analysis of country-specific patterns and custom-made social protection interventions; and raising awareness and introducing financial incentives to encourage women and girls to enter male dominated fields of education. The introduction of programmes, such as mentorship and foreign exchange, to support girls in STEM (Science Technology Engineering and Math) can help close the gendered digital divide.
- **Enhance and transform current social protection by the states.** This includes investment in expanding and maintaining free social services and supporting infrastructure (such as child-care services, free day-care centres, senior care centres and rehabilitation centres for children with disabilities) and free and secure public transport; promoting social protection to increase girls’ school enrolment and attendance; introducing nationally appropriate social protection systems and measures for all (including, social protection floors\(^{35}\)) and ensuring that relevant policies address the challenges faced by women; providing incentives for both parents’ active participation in child-care, through equalizing conditions for paid maternity, paternity and parental leave; supporting mechanisms to prevent separation of children from their families, including through community-based alternatives to institutional care; ensuring that single-parent families are not rendered “invisible” within the system of social protection; encouraging public and private sector employers to introduce family-friendly working conditions to support women’s career prospects and family male involvement (flexible work schedule, teleworking); and introducing the gender dimension into pension reforms to recognize and reward years of unpaid care provided by women. Gender-transformative models of care guaranteeing sustainable models of care that do not increase the burden on women and increase women’s participation are also required.\(^{36}\)
- **Build on opportunities and address challenges presented by demographic shifts.** Governments should respect women’s rights to make their own reproductive choices and should select gender-sensitive family policies that build on the principle of gender equality and support women’s participation in social, educational, political and economic fields. Such policies include: subsidized maternity, paternity and parental leave, free child-care, quality public reproductive healthcare, family oriented working conditions for parents, tax credits, and social transfers. Investment in adolescent girls should be made, with enhanced opportunities and access to health, education and social services.
- **Promote human rights in light of re-traditionalization, radicalization and harmful traditional practices.** This includes ensuring access to justice for all, through building capacity of law enforcement and judiciary to ensure gender justice, access to rule of law for women and girls, and end gender-based discrimination, harmful traditional practices and violence against women; strengthening the legislative base to protect women’s reproductive choices and raise public awareness about the importance of sexual and reproductive rights of women and girls; addressing the problem of gender-biased sex selection without compromising women’s and girl’s access to health services; and developing interventions to ensure access to primary, secondary and tertiary education for girls, particularly those from marginalized groups, through scholarships and education related tax credits.
---
\(^{35}\) As stated in SDG 1, Target 1.3
\(^{36}\) *Women’s health and well-being in the WHO European Region*, WHO 2016, (available from: http://www.euro.who.int/en/health-topics/health-determinants/gender/publications/2016/womens-health-and-well-being-in-europe-beyond-the-mortality-advantage-2016)
• Ensure women’s full and effective participation and equal opportunities for leadership at all levels of decision-making in political, economic and public life and expand women’s ability to influence governance through civil society. This includes lifting pressures from civil society and supporting the mobilization and advocacy for women’s rights; introducing temporary special measures to break male-dominated hierarchies in political parties and raising awareness and introducing women-friendly work policies and career development programmes to increase women’s representation within the high ranks in all branches of government.
• Eliminate all forms of violence against all women and girls in the public and private spheres, including trafficking and sexual and other types of exploitation including in emergency settings. This includes introducing the concept of multi-sectoral coordinated response to GBV and ensure strong and consistent implementation mechanisms for existing legislation on GBV, including working with boys and men to prevent GBV/violence against women (VAW); and integrating the minimum standards of GBV prevention, mitigation and response in humanitarian work with refugees, IDPs and host communities, in areas affected by armed conflicts and natural disasters.
Traditionally, Roma girls in Moldova tend to cut their education short to start a family. Stela attends the eighth grade and her dream is to become a world boxing champion.
Addendum III
Exercises
Mapping the existing policy and programme landscape: Several countries of the region already use the screening and mapping of national policies, strategies and programmes in order to identify connections with gender-related SDGs and targets. Such policies may include (but are by no means limited to) national development strategies, national action plans, poverty reduction programmes, social inclusion programmes, employment strategies and policies related to youth and gender equality. Please, see below an example of mapping exercise conducted in Turkey. The example presents a matrix linking specific SDGs to on-going national policies.
TURKEY: rapid screening of policy landscape conducive to efficient SDG implementation
After the adoption of SDGs, Government of Turkey performed a rapid screening of the country’s National Development Plan (NDP) to determine consistency between the NDP and SDGs. Preliminary analysis confirmed a high degree of consistency between the two. The table below presents an example of analysis of NDP policies organized around SDG 5.\(^{37}\)
Consistency between SDGs and the National Development Plan of the Republic of Turkey
| Goal 5. Achieve gender equality and empower all women and girls. | In terms of gender equality, the main objectives of the plan are to empower women in all aspects of social, economic and cultural life, improve the status of the family and strengthen social integration. Further involvement of women in decision-making processes, increasing their employment, education and skills level will be ensured in the plan period. In order to eliminate discrimination and violence against women, the aim is to increase the level of social consciousness with formal and informal education, particularly starting from the early childhood. |
|---|---|
Creating an e-inventory (stocktaking): The teams can also create an e-inventory of policies and programmes with linkages to specific SDGs. Online electronic inventories can be made available to a diverse pool of stakeholders and updated as new policies and programmes emerge.
Building connections with country-based trends: The exercise helps to analyse connections between gender-related SDGs and the targets and key trends linked to the situation of gender equality in the country. The exercise should start with the participants identifying key trends (please use the Advocacy Brief with the description of nine regional trends as an example). Participants then discuss how negative trends can be reversed and positive trends accelerated through the implementation of specific SDGs.
\(^{37}\) Report on Turkey’s Initial Steps towards the Implementation of the 2030 Agenda for Sustainable Development, p.18
and targets. The exercise should result in a matrix displaying the key trends in gender equality and respective SDGs. Below is an example featuring one of the key regional trends and relevant SDGs. Please take into consideration that the connections between specific trends and relevant SDGs and targets should be based on the decisions made in the course of the exercise.
| Regional Trend | SDGs |
|-----------------------------------------------------|----------------------------------------------------------------------|
| Economic Opportunities and Women’s Economic Empowerment remain limited | **SDG 1** Targets 1.1, S.2, 1.3, 1.4, 1.b
**SDG 2** Target 2.3
**SDG 4** Targets 4.2, 4.3
**SDG 5** Targets 5.1, 5.2, 5.4, 5.5, 5.a, 5.b, 5.c
**SDG 8** Targets 8.3, 8.5, 8.7, 8.8
**SDG 10** Targets 10.2, 10.3
**SDG 11** Targets 11.2, 11.7
**SDG 16** Targets 16.1, 16.2, 16.3, 16.7, 16.b |
**Backtracking:** This exercise provides a good opportunity to envision the process of progressing towards gender equality and the empowerment of all women and girls through SDGs. Participants should start by imagining and describing an ideal situation related to gender equality (for example, the complete elimination of early marriage). The next step is to determine which SDGs and targets have to be achieved in order to eliminate early marriage (for instance, SDG5, SDG 3.7, SDG 1b and SDG 4.3). Then participants can then backtrack through the process of implementing SDGs, listing the consecutive steps that must have been taken. See an example of a backtracking flowchart below.
**Mapping states’ international commitments** in the area of gender equality and human rights and highlighting linkages to gender-relevant SDGs and targets. The participants will identify international conventions and agreements that support the focus on gender equality in the nationalized SDG framework. For example, the commitment to eliminate all forms of discrimination against women undertaken in line with CEDAW requires that governments pursue most of the targets under SDG 5. For monitoring and reporting on SDGs, please note which monitoring and reporting frameworks exist under relevant international commitments.
Each country will have its own list of such agreements but, among international commitment documents, UNCT and national partners could review:
→ CEDAW-related country reports and observations/recommendations by the CEDAW Committee.
→ Country Reports on the Implementation of the Beijing Platform for Action.
→ Country Reports on Progress towards MDGs.
→ Universal Periodic Review.
→ Country reports by the UN Special Procedures (for example, by the Special Rapporteur on violence against women, its causes and consequences).
→ Association Agreements or Stabilization and Association Agreements (for countries that signed agreements ‘outlining their relations with EU).
**Mapping gender indicators:** The exercise helps identify gaps in current frameworks and design a more robust monitoring framework. Please see an example in the following resource: Data2xo (2014), Buvinic, M., Furst-Nichols,F., Koolwal, G., *Mapping Gender Data Gaps*, http://data2x.org/wp-content/uploads/2014/11/Data2X_MappingGenderDataGaps_FullReport.pdf
Addendum IV
Tips, promising practices and lessons learned from UNCTs
On building a dialogue with national partners
**Promising practice (Georgia):** “The UNCT took the lead in the dialogue with the government regarding nationalized SDGs’ gender targets and indicators.”
**Tip (Georgia):** “It was essential that the technical input provided by the UN Agencies was harmonized internally prior to sharing with the government to ensure the coherence and the highest quality of inputs related to localizing the SDG targets, including selection of relevant global SDG indictors and customizing them to the national context. The Gender Theme Group could provide a useful platform for the similar process with a broader set of development partners at the next stage.”
**Tip (Azerbaijan):** Use the CEDAW Committee’s concluding observations as the basis for the consultations on customizing the SDGs while engaging with the government and non-state actors.
**Tip (Moldova):** For discussions on the prioritization of SDGs, support the participation of national partners with a ready set of gender-disaggregated data for evidence-based selection.
**Tip (Georgia):** “Coordination within the UNCT is very important. Joint advocacy work and speaking with one voice is critical.”
On spreading information about gender and SDGs and engaging multiple stakeholders in national consultations
**Promising practice (Montenegro):** In Montenegro, the efficient use of social media and online applications helped widen the scope of national consultations on SDG nationalization and analyse the feedback. An SDG web platform was created, and social media was widely used for consultations to promote a multiple-stakeholder approach. Consultations used crowd sourcing, discussion platforms, online questionnaires and surveys, social media like Facebook, Twitter and other platforms). All collected data was sex-disaggregated. Analysis of the consultations and survey data revealed the major themes prioritized by the stakeholders. The UNCT teamed up with grass roots organization to plan outreach events around these themes, also paying attention to the gender balance in the events. UNCT and its national partners ensured a continuous feedback mechanism from the digital engagement to the field outreach activities, to take into account further issues or themes that emerged in the course of national consultations.
**Promising practice (Kazakhstan):** Disseminating/offering information about gender-related SDGs and targets at every opportunity as a way to raise awareness.
**Tip (Uzbekistan):** “Make sure that all national partners at all levels understand the interactive nature and complexity of SDGs and the role of gender equality and women’s empowerment in this complex network. SDGs are new and complex concepts for national partners. Conduct continuous consultations, awareness raising and capacity building.”
On mainstreaming gender-related SDGs into national Strategies and Action Plans
**Tip (Montenegro):** Integrating SDGs and targets into the National Action Plan for Gender Equality will help strengthen the implementation process and secure financial resources.
**Promising practice (Turkmenistan):** Building close cooperation with national government to develop a Road Map for effective and timely implementation of the National Action Plan on Gender equality (2015 - 2020), which embraces many SDGs. The UNCTs Human Rights, Gender and Youth Thematic Group have been actively involved in national consultations on SDGs and ensured that mainstreaming and addressing gender equality were included in the discussions and the nationalization of SDG targets and indicators.
**Promising practice (the former Yugoslav Republic of Macedonia):** At the stage of consultations, the UNCT emphasized the link between SDGs and targets and the National Strategy for Sustainable Development (NSSD). The integration process resulted in the revision of the National Strategy for Sustainable Development and the integration of SDGs, including those important for gender equality, in the revised version of the strategy. UNCT members assisted national partners in the selection of realistic national performance indicators and the design of a proper means of monitoring SDG implementation.
**Tip (Kosovo):** Creating connections between the National Development Strategy, EU projects/gender objectives and the SDGs will help in the nationalization of SDGs.
**Tip (Belarus):** Organize joint gender mainstreaming seminars for UN agencies and national partners in the UN Development Assistance Framework Result Groups. They will assist in ensuring gender mainstreaming during the SDG nationalization process.
On incorporating gender indicators into SDG monitoring frameworks
**Tip (Serbia):** Efficient monitoring builds on existing resources. If SDG gender indicators and sex-disaggregated indicators are included in the monitoring frameworks of state strategies, policies and programmes, they will strengthen capacities to monitor progress towards respective SDGs. This will ensure the regularity of data collection and will help save resources that would otherwise be spent on collecting SDG-related data separately.
**Tip (Georgia):** It is important to sustain an open discussion among UNCTs and all national partners regarding the choice of particular indicators. Open discussion is crucial for sharing concerns and jointly seeking solutions. For example, governments may be reluctant to adopt certain indicators of women’s economic advancement due to a fear of undue interference with the private sector. To address the issue, UNCTs can facilitate a discussion involving private sector actors, government and civil society organizations and jointly develop suitable solutions.
On working with coordinating mechanisms and other government bodies in the course of SDG implementation
**Promising practice (Uzbekistan):** “If you have an SDG implementation mechanism split between several units (for example, Theme Groups that bring together line ministries) ensure that a) civil society organizations and representatives of the national machinery for gender equality are included in all groups to advocate and promote gender mainstreaming; b) create a connection between Theme Groups and UNDAF Results Groups. Uzbekistan’s Country Team created an institutional connection in the form of core resource persons, experts who mediate between the SDG implementation mechanism (Theme Groups) and UNDAF system (UNDAF Results Groups).”
**Tip (Georgia):** To increase awareness of line ministries about gender equality and the empowerment of all women and girls, consider advising a gender audit (a self-assessment exercise), which would identify capacity gaps and needs at particular ministries and national partners’ institutions and link those with nationalized SDG targets and indicators on gender to formulate follow-up actions.
**Lessons Learned (Georgia): Adjusting targets and indicators to mainstream gender equality and the empowerment of all women and girls**
Georgia’s experience presents a good example of global targets and indicators adjusted to capture gendered power dynamics at key junctions of national decision-making and governance.
The SDGs have not yet been formally nationalized in Georgia. However, the country has made significant progress in advancing them at national and local levels. Georgia presented its first Voluntary Report on progress towards achieving localized SDGs during the High Level Political Forum held in July 2016 in New York. With the technical assistance of UN Agencies, gender has been mainstreamed into the indicators measuring the majority of Georgia’s national targets.\(^{38}\) The UNCT and national partners recognized that in order to address the root causes of women’s weak economic and political position in Georgia,\(^{39}\) such as gender stereotypes and the traditional division of work between men and women, joint efforts and political attention needed to focus on SDG 5. Subsequently, UNCT and national partners proposed additional nationalized targets under SDG5 and suggested indicators for their inclusion in Georgia’s 2030 Agenda.
The draft table below covers SDG 5, adjusted target and several indicators proposed to monitor progress towards the target. For each indicator, the **baseline** is determined, as well as the **numerical target** and the **source of data**. Please note how Georgia has adjusted the list of national indicators to measure the “pulse” of change in women’s participation in essential locations of power within the governance system. Apart from in-depth understanding of gender gaps in equal participation in decision-making, this kind of adjustment requires a thorough knowledge of the architecture of governance in the national context.
---
\(^{38}\) The Georgia UNCT has submitted the final set of recommended indicators to the Administration of the Government of Georgia through a consultation process completed in summer 2016.
\(^{39}\) Please see part “Justification/background.”
Compare to follow the adjustments proposed within SDG nationalization:
| Goal | Global | Georgia |
|------|--------|---------|
| **Target** | 5.5. Ensure women’s full and effective participation and equal opportunities for leadership at all levels of decision making in political, economic and public life | 5.5. Ensure women’s full and effective participation and equal opportunities for leadership at all levels of decision making in political, economic and public life |
| **Indicator** | 5.5.1 Proportion of seats held by women in national parliaments and local governments
5.5.2 Proportion of women in managerial positions.
*Note:* The indicator measures the proportion of women in leadership positions across a number of areas, including: legislative, executive and judiciary branches of government and share of managers in public and private sector enterprises that are women. | 5.5.1 Proportion of seats held by women in local government.
5.5.2 Proportion of seats held by women in national parliament.
5.5.3 Proportion of directly elected female mayors
5.5.4. Proportion of directly elected female governors
5.5.5. Proportion of women in decision-making positions in public service
5.5.6. Proportion of women in decision-making positions in the judiciary (chairs of regional/city courts, appellate courts and supreme court).
5.5.7. Proportion of women in managerial positions in private sector.
5.5.8. Proportion of women in principal ownership of companies.
5.5.9. Gender wage gap. |
## Georgia: Adjustment of Target 5.5
| Indicator | Baseline | Target |
|-----------|----------|--------|
| **5.5.1** | Proportion of seats held by women in local government. - Source: Central Election Commission | 11.6% (2016) | 30% |
| **5.5.2** | Proportion of women in national parliaments - Source: Central Election Commission | 12% (2016) | 30% |
| **5.5.3** | Proportion of directly elected female mayors - Source: Central Election Commission | 0% (2016) | 30% |
| **5.5.4** | Proportion of directly elected female governors - Source: Central Election Commission | 0.6% | 30% |
| **5.5.5** | Proportion of women in decision-making positions in public service. - Source: Public Service Bureau | To be established in 2017 | 30% |
| **5.5.6** | Proportion of women in decision-making positions in the judiciary (chairs of regional/city courts, appellate courts and supreme court. - Source: High Council of Justice | 6.9 % (2015) | 20% |
| **5.5.7** | Proportion of women in managerial positions in private sector. Source: World Bank Enterprise surveys | 32 % (2013) | 45% |
| **5.5.8** | Proportion of women in principal ownership of companies. Source: World Bank Enterprise surveys; National Agency of Public Registry (NAPR) | 34 % (2013) | 45% |
| **5.5.9** | Gender wage gap. Source: GEOSTAT | 37 % (2014) | 20% |
Addendum V
How countries are implementing SDGs
**UZBEKISTAN**
Flow chart: SDG implementation
- SDGs were grouped into six thematic areas led by relevant line ministries, which ensures national commitment, accountability and ownership.
- Thematic Groups were created for each thematic area, with participation of line ministries, Women’s Committee and relevant CSOs. It helps advocacy and promotion of gender mainstreaming in the SDG localization process.
- Theme Groups for SDG implementation correspond to the relevant UNDAF result groups. The arrangement creates a platform for engagement of all development partners, including UN.
- To provide expert support to SDG localization process the UNCT established the Group of Core Resource persons that are expected to serve as interlocutors between SDG theme-groups and UNDAF RGs.
**SERBIA**
Flow chart: SDG implementation
- Interministerial Working Group on SDG implementation was established.
- UNCT has mapped all existing national strategies/policies that address SDG priorities including on SDG 5.
- UNCT shared the mapping tool with the Working Group for reference.
- UNCT supported national partners in preparing Final National Report on MDGs. The Report outlines links between MDGs and SDGs, including gender related goals and targets.
UKRAINE
Flow chart: SDG implementation
UNCT organized a thematic consultation on Goal 5 with the line ministries and CSOs;
Developed list of tips for the gender advocates to support their advocacy for Goal 5 and gender mainstreaming in the consultations;
Designed gender-specific questions to the guide for the facilitators of the consultations.
TURKMENISTAN
Flow chart: SDG implementation
Three stage SDG roll-out process adopted by the Government
First stage “Prioritization for national adoption”. 17 days of national consultations with participation of UNCT Theme Groups and the government.
GE mainstreamed into the discussions of nationalized SDGs and targets and indicators.
Stage one finalised (SDGs, targets and indicators selected). As a result of consultations, nationalised SDGs include SDG 5 and all targets relevant for country’s progress towards GE.
UNCT supported the Government in creating a two-tier based coordination mechanism for SDG implementation.
Stage Two “Integrating SDGs into national plans and programs for planning of SDG implementation” will start at the end of 2016
Stage Three “Monitoring and Measuring SDGs” has 2 components. Component (a) is to set up the overall SDG monitoring system (with GE related indicators included) and component (b) strengthening line ministries systems to incorporate SDGs.
Example of how gender equality works as an accelerator throughout the SDGs framework
1. **No Poverty**
- Women invest 90% of income back to families, creating a “multiplier effect” that boosts social and economic outcomes for their communities.
8. **Decent Work and Economic Growth**
- Women and girls have the most potential to produce economic growth. Closing the gender gap ranges from 5% to over 30% of GDP.
### Targets
- **Target 4.1: Primary and Secondary Education**
- **Target 4.3: Tertiary education**
- **Target 4.4: Youth Employment**
- **Target 5.3: Harmful practices**
- **Target 5.5: Leadership**
- **Target 5.b: Technology, empowerment**
- **Target 3.1 – 3.2: Maternal and Child Mortality**
- **Target 5.1 – 5.3 – 5.6: Violence, Discrimination, SRHR**
### Key Points
- Equality and equality indifferent sectors & on different levels
- Needs of most vulnerable
- Social norms and stereotypes
- Social policies
- Reconciliation of work and un-paid care
- Safety for women and girls, etc.
**Gender equality.** Refers to the equal rights, responsibilities and opportunities of women and men and girls and boys. Equality does not mean that women and men will become the same but that women’s and men’s rights, responsibilities and opportunities will not depend on whether they are born male or female. Gender equality implies that the interests, needs and priorities of both women and men are taken into consideration, recognizing the diversity of different groups of women and men. Gender equality is not a women’s issue but should concern and fully engage men as well as women. Equality between women and men is seen both as a human rights issue and as a precondition for, and indicator of, sustainable people-centred development. (Source: http://www.un.org/womenwatch/osagi/conceptsanddefinitions.htm)
**Gender equity.** The CEDAW Committee, in its General Recommendation 28, states that *gender equity* is the concept “used in some jurisdictions to refer to fair treatment of women and men, according to their respective needs. This may include equal treatment, or treatment that is different but considered equivalent in terms of rights, benefits, obligations and opportunities.” Please, note that CEDAW Committee calls upon the states to use the term “gender equality” and to avoid using the term “gender equity” in implementing the obligations under the CEDAW Convention. (“States parties are called upon to use exclusively the concepts of equality of women and men or gender equality and not to use the concept of gender equity in implementing their obligations under the Convention.”)
**Gender-disaggregated data** is data collected and tabulated separately for men and women. **Gender-disaggregated data allows to identify,** measure and analyse differences between women and men in economic, social, demographic, cultural and political dimensions.
**Gender-related** is any concern or problem that is determined, in its broadest sense, by differences between men and women based on gender and/or sex. (Source: http://genderstats.org/)
**Gender-responsive evaluation** assesses the degree to which gender and power relationships—including structural and other causes that give rise to inequalities, discrimination and unfair power relations, change as a result of an intervention using a process that is inclusive, participatory and respectful of all stakeholders (right holders and duty bearers). Gender-responsive evaluation promotes accountability to gender equality, human rights and women’s empowerment commitments by providing information on the way in which development programmes are affecting women and men differently and contributing towards the achievement of these commitments. It is applicable to all types of development programming, not just gender-specific work.” (Source: UN Women (2015) “How to manage gender-responsive evaluation: Evaluation handbook,” Independent Evaluation Office. New York, NY: UN Women.)
**Equity-focused evaluation** is “an assessment made of the relevance, effectiveness, efficiency, impact and sustainability of interventions on equitable development results.” Equity-focused evaluations look at structural bottlenecks and power relationships, and use an empowerment process. (Source: Bamberger, M. and Segone, M., UNICEF (2011) *How to design and manage equity-focused evaluations.*)
**Gender-sensitive indicators** are indicators that should be disaggregated by sex in order to reveal the difference in impact, experience or progress in relation to women, girls, boys or men.
**Gender-specific indicators** are indicators that reveal circumstances specific for women, girls, boys or men.
Gender statistics is the scientific notation and interpretation of statistics that in an adequate and complete way are reflecting the living conditions and situations of women and men with respect to all policy fields and areas. Gender Statistics allow for, and enable, systematic research and study of differentials and issues regarding gender. Source: http://genderstats.org/
SDG localization is a process of adapting SDGs to local contexts on a sub-national level (for example, a province, a city or a community), setting local targets and mainstreaming SDGs into the local development without compromising the integrity of Agenda 2030.
SDG nationalization is a process of adapting SDGs to national contexts, setting national targets and mainstreaming SDGs into national planning processes, policies and strategies without compromising the integrity of Agenda 2030. The 2030 Agenda for Sustainable Development states: “The SDGs and targets are integrated and indivisible, global in nature and universally applicable, taking into account different national realities, capacities and levels of development and respecting national policies and priorities. Targets are defined as aspirational and global, with each government setting its own national targets guided by the global level of ambition but taking into account national circumstances. Each government will also decide how these aspirational and global targets should be incorporated in national planning processes, policies and strategies. It is important to recognize the link between sustainable development and other relevant on-going processes in the economic, social and environmental fields.”
Sustainable development is “development that meets the needs of the present without compromising the ability of future generations to meet their own needs.” Source: Our Common Future. Report of the World Commission on Environment and Development, 1987 (also often referred to as the “Brundtland Report”).
Krusha Cooperative for production of vegetable preserves employs 46 women, while providing household income to 180 families in Kosovo.
The United Nations Development Group (UNDG) is a high-level inter-agency group that provides strategic leadership and coordination for the UN development system in Europe and Central Asia. It comprises the Resident Coordinators of the United Nations Country Teams, the Heads of UN Funds, Programmes and Specialized Agencies, and the UN Regional Office for Europe and Central Asia.
The UNDG is committed to promoting coherence, accountability and effectiveness in the UN development system’s work in the region. It works closely with governments, civil society, the private sector and other stakeholders to ensure that the UN’s efforts contribute to sustainable development and poverty reduction.
The UNDG also plays a key role in coordinating the UN’s response to emergencies and disasters in the region. It ensures that the UN’s humanitarian and development activities are aligned and complementary, and that they address the most pressing needs of affected populations.
The UNDG is headquartered in Vienna, Austria, and has offices in all 53 countries of the region. It is supported by a Secretariat based in New York, which provides technical assistance and coordination services to the UNDG members.
The UNDG is an integral part of the United Nations system and its work is guided by the principles of the UN Charter and the Millennium Development Goals. It is committed to delivering results for people and planet, and to ensuring that the UN’s efforts are aligned with the priorities and needs of the region.
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Partnering for a sustainable future
Swire Properties and Tsinghua University work towards decarbonisation targets
‘Pawa meri’
A ‘woman of power’ follows her dreams at Pacific Towing
Connecting for a brighter tomorrow
Celebrating the TrustTomorrow initiative
The Swire Group is a multinational, multi-disciplined commercial group, with its principal areas of operations in the Asia Pacific region, and centred on the Greater China area. Hong Kong is home to publicly quoted Swire Pacific, which is engaged principally in property, beverages, and aviation businesses, as well as new areas of growth, such as healthcare. John Swire & Sons Limited, headquartered in the UK, is the parent company of the Group. In addition to its controlling shareholding in Swire Pacific, John Swire & Sons Limited operates a range of wholly owned businesses, including deep-sea shipping, cold storage, offshore and road transport logistics services, waste to energy, beverages and beverage ingredients, with main areas of operation in the UK, USA, Europe, Papua New Guinea and Singapore.
SWIRE NEWS is published in Hong Kong, by the Swire Group Public Affairs Department.
To view the digital version, please go to www.swire.com/swirenews
Copyright©2023
Board appointment
Cathay Pacific Airways Limited
Wang Mingyuan has been appointed Non-Executive Director of Cathay Pacific Airways Limited with effect from 24th July 2023. Mr Wang, aged 57, has concurrently served as chairman of Air China Development Corporation (Hong Kong) Limited since April 2011. He has also served as the vice chairman of Tibet Airlines Co., Ltd. since June 2020 and the chairman of Air Macau Company Limited since March 2022. Mr Wang has been serving as the President, Director and Vice Chairman of Air China since March 2023.
Senior management appointments
John Swire & Sons (S.E. Asia) Pte. Limited
Mark Celenk has been appointed Director, S.E. Asia.
Swire Properties Limited
Arthur Burnand has been appointed Chief Operating Officer, Chinese Mainland.
Eliza Wong has been appointed Deputy Director, Projects (H.K & S.E. Asia).
Swire Coca-Cola
Adrian Choy has been appointed Finance Director with effect from December 2023, succeeding Keith Fung, who will retire in November 2023.
Cathay Group
William Cheng has been appointed Chief Financial Officer HK Express.
HAECO Group
Richard Sell has been appointed Chief Executive Officer with effect from July 2023, succeeding Frank Walschot, who has retired in June 2023.
George Edmunds has been appointed Chief Executive Officer, HAESL.
Diana Xie has been appointed Director Finance, HAECO Xiamen.
James Finlay
Francis Tin has been appointed Chief Financial Officer, Damin International Holdings Limited.
Swire Shipping
Tom Bellamy has been appointed Chief Commercial Officer and Director Swire Projects.
Steamships Trading Company
Chris Daniells has been appointed Chief Operating Officer.
2023 Interim Results
Swire Pacific Limited
The Group’s core divisions have all rebounded in the first six months of this year. The main driver of these strong results is the Aviation Division. Cathay Pacific continues to build on the positive momentum and improved financial performance reported since the second half of 2022, and has benefitted from a surge in travel demand since pandemic control measures were lifted. The Property Division has welcomed an increase in rental income from retail properties in the Chinese Mainland and Hong Kong, and the increased demand in international travel has, in turn, led to an improvement in the hotel business. In the Beverages Division, the business in the USA has continued to perform well, and the results for the period include its latest acquisitions in Vietnam and Cambodia.
In the first six months of 2023, Swire Pacific’s consolidated profit attributable to shareholders was HK$4,221 million. This is compared with HK$1,914 million for the same period in 2022. The underlying profit attributable to shareholders, adjusted for changes in the value of investment properties, was HK$5,594 million in comparison to HK$1,752 million posted for the first half of last year. Disregarding changes in investment property value and significant non-recurring items in both years, the Group recorded a recurring underlying profit of HK$4,879 million for the period under review, compared with HK$1,272 million for the corresponding period in 2022.
The Group also improved its shareholder returns with its share buy-back scheme of up to HK$4 billion, which was announced in 2022 and completed earlier this year. During the period under review, Swire Pacific repurchased 8,998,500 ‘A’ shares and 15,107,500 ‘B’ shares for an aggregate cash consideration of HK$0.7 billion at average prices of HK$59.1 per ‘A’ share and HK$9.7 per ‘B’ share. The Board will continue to evaluate all options, including future share buy-back schemes, taking into consideration the most efficient use of capital for long-term shareholder returns.
| | 2023 | 2022 (Restated*) | Change |
|--------------------------------|------------|------------------|--------|
| **Revenue** | 51,544 | 44,808 | +15% |
| **Profit attributable to the Company’s shareholders** | | | |
| As reported | 4,221 | 1,914 | +121% |
| Underlying profit | 5,594 | 1,752 | +219% |
| Recurring underlying profit | 4,879 | 1,272 | +284% |
| **Earnings per share** | | | |
| Underlying | | | |
| ‘A’ share | 3.86 | 1.17 | +230% |
| ‘B’ share | 0.77 | 0.23 | |
| **First interim dividends per share** | | | |
| ‘A’ share | 1.20 | 1.15 | +4% |
| ‘B’ share | 0.24 | 0.23 | |
Swire Pacific Interim Results Analyst Briefing (left to right): Karen So, Managing Director of Swire Coca-Cola, Swire Pacific’s Chairman, Guy Bradley and Finance Director, Martin Murray.
Swire Properties Limited
Swire Properties’ recurring underlying profit increased by HK$220 million to HK$3,892 million in the first half of 2023, which mainly reflected the strong recovery of its retail portfolio and hotels in Hong Kong and the Chinese Mainland. Underlying profit attributable to shareholders decreased by HK$268 million to HK$3,901 million in the first half of 2023, primarily due to the delay in sales of car parking spaces at Taikoo Shing residential development in Hong Kong.
The company saw a strong rebound in its retail business in both Hong Kong and the Chinese Mainland. The Hong Kong retail portfolio has recovered very well, due to the lifting of all travel restrictions and COVID-19 related measures, and an improvement in consumer sentiment. Sales have improved and returned to pre-pandemic levels in some of the company’s malls in Hong Kong. In the Chinese Mainland, foot traffic has improved significantly and retail sales have exceeded pre-pandemic levels for many of its malls.
The company’s hotel business in Hong Kong and the Chinese Mainland recovered strongly following the lifting of COVID-19 restrictions and the reopening of the border.
Swire Properties has made good progress with its HK$100 billion investment plan, which was first announced in March 2022. The company is focused on building out its pipeline of new projects across its core markets of Hong Kong, the Chinese Mainland and South East Asia, with approximately 40% of the plan now committed to new investments.
| Six months ended 30th June | 2023 | 2022 (Restated*) | Change |
|---------------------------|------|------------------|--------|
| Revenue | 7,297| 6,910 | +6% |
| Profit attributable to the Company’s shareholders | | | |
| Underlying | 3,901| 4,169 | -6% |
| Recurring underlying | 3,892| 3,672 | +6% |
| Reported | 2,223| 4,348 | -49% |
| Earnings per share | 2023 | 2022 | Change |
|--------------------|------|------|--------|
| Underlying | 0.67 | 0.71 | -6% |
| Recurring underlying| 0.67 | 0.63 | +6% |
| First interim dividend per share | 0.33 | 0.32 | +3% |
Swire Properties Interim Results Analyst Briefing: Swire Properties’ Chief Executive, Tim Blackburn and Finance Director, Fanny Lung.
Cathay Pacific Airways Limited
The Cathay group, including airlines, subsidiaries and associates, reported an attributable profit of HK$4,268 million in the first half of 2023 (2022 first half: loss of HK$4,999 million). The profit included a one-off non-cash gain of HK$1.9 billion. The group’s airlines and subsidiaries, excluding exceptional items, reported an attributable profit of HK$4,763 million in the first half of 2023 (2022 first half: loss of HK$2,516 million). Meanwhile, the results from associates, the majority of which are recognised three months in arrears, reflected an attributable loss of HK$2,632 million (2022 first half: loss of HK$2,483 million).
In the first half of 2023, Cathay Pacific’s passenger revenue increased by 1,109.5% to HK$25,013 million compared with the same period in 2022. Passenger flight capacity, measured in available seat kilometres, increased by 1,111.3%, while traffic, measured in revenue passenger kilometres, increased by 1,685.0%. The airline carried a total of 7.8 million passengers in the first half of 2023, an average of 43,184 per day, which was 2,233.1% more than in the first half of 2022. Load factor was 87.2% compared with 59.2% in the first half of 2022.
Cargo revenue in the first half of 2023 decreased by 11.6% to HK$10,741 million compared with the same period in 2022, reflecting a weaker global market for air cargo. Capacity, measured in available cargo tonne kilometres, increased by 117.6%. Traffic, measured in cargo revenue tonne kilometres, increased by 83.0%. Total tonnage increased by 23.8% to 651 thousand tonnes. Load factor was 63.8% compared with 75.8% in the first half of 2022, and yield decreased by 51.7% to HK$2.76.
Cathay group has been operating cash generative so far in 2023 and its available unrestricted liquidity balance was HK$28.9 billion as at 30th June 2023.
* Following a change in accounting policy resulting from the agenda decision approved by the IFRS Interpretation Committee on ‘Lessor Forgiveness of Lease Payments (IFRS 9 and IFRS 16)’, the comparative figures for the six months ended 30th June 2022 have been restated.
This document may contain forward-looking statements that reflect the Company’s beliefs, plans or expectations about the future or future events. These forward-looking statements are based on a number of assumptions, estimates and projections, and are therefore subject to inherent risks, uncertainties and other factors beyond the Company’s control. The actual results or outcomes of events may differ materially and/or adversely due to a number of factors, including the effects of COVID-19, changes in the economies and industries in which the Group operates, in particular in Hong Kong and the Chinese Mainland, macro-economic and geopolitical uncertainties, changes in the competitive environment, foreign exchange rates, interest rates and commodity prices, and the Group’s ability to identify and manage risks to which it is subject. Nothing contained in these forward-looking statements is, or shall be, relied upon as any assurance or representation as to the future or as a representation or warranty otherwise. Neither the Company nor its directors, officers, employees, agents, affiliates, advisers or representatives assume any responsibility to update these forward-looking statements or to adapt them to future events or developments or to provide supplemental information in relation thereto or to correct any inaccuracies.
Sale of Swire Coca-Cola, USA
In September, Swire Pacific Limited and John Swire & Sons Limited (“JS&S”) completed the sale of 100% equity in Swire Holdings Inc. (trading as “Swire Coca-Cola, USA”) to JS&S (Beverages) Inc., a wholly owned subsidiary of JS&S, for a total consideration of US$3.9 billion. Swire Pacific is expected to gain approximately HK$22.8 billion on disposal and has distributed a special dividend of HK$11.7 billion to shareholders (equivalent to HK$8.120 per ‘A’ share and HK$1.624 per ‘B’ share). The significant net proceeds from the transaction will serve to materially reduce net debt for Swire Pacific and strengthen its balance sheet for future investments in its core divisions in Greater China and Southeast Asia. The Coca-Cola Company has authorised Swire Coca-Cola, USA to retain all of its rights under its existing bottling agreements after the change in ownership. In connection with the transaction, Swire Coca-Cola Limited (“SCCL”), Swire Coca-Cola, USA and JS&S have signed a Management Services Agreement for the provision of management and administrative support services by SCCL in respect of Swire Coca-Cola, USA. The agreement will enable the beverages division to further strengthen its global relationship with The Coca-Cola Company, covering a sizeable franchise population of 877 million.
In July, John Swire & Sons (H.K.) Limited Chairman Guy Bradley (back row, fifth from right) joined more than 30 leading members of the business community on a delegation to Southeast Asian countries led by Hong Kong SAR Chief Executive, Mr John Lee. The group visited a range of enterprises in Singapore, Indonesia, and Malaysia, with the aim of strengthening ties, exploring opportunities for collaboration, and attracting investment and talent to Hong Kong.
ReThink HK 2023
In September, Swire companies were well represented at ReThink HK 2023 – Hong Kong’s annual sustainable development forum for the business community. For the fourth consecutive year, John Swire & Sons (H.K.) Limited was a key sponsor, with other group companies providing support, including Cathay Pacific, Swire Coca-Cola, Swire Properties and Taikoo Motors. The two-day conference attracted more than 4,500 attendees and included over 60 different sessions focused on ways to drive collective, positive change in environmental and social sustainability.
Pat Healy, Chair of Cathay Pacific and Swire Coca-Cola, was one of 500 invited speakers and gave a keynote address at a session on Hong Kong’s Net-Zero pathway and sustainable supply chains. Mark Harper, Group Head of Sustainability, joined a discussion on navigating risk in the evolving landscape of ESG [Environment, Social and Governance] Reporting. Other speakers from the Sustainable Development Office, Diversity and Inclusion team, Swire Trust, and other Swire companies contributed their expertise to various panel discussions.
Taikoo Li Chengdu
Following the acquisition of the remaining interests in its flagship, retail-led Chengdu development earlier this year, Swire Properties has renamed the complex “Taikoo Li Chengdu”. The acquisition signals Swire Properties’ long-term commitment to Chengdu and to further investment on the Chinese Mainland. Since its opening in 2015, Taikoo Li Chengdu has become an iconic destination for local residents and tourists alike, and its renaming is another exciting milestone for the development, which is a world-class example of Swire Properties’ long-term approach to urban regeneration and cultural preservation.
Green dim sum bonds
Swire Properties has listed its first public Renminbi (“RMB”) bonds (known as “green dim sum” bonds) on the Hong Kong stock market. The company is the first Hong Kong corporate to issue a RMB-denominated public green bond, and the transaction is Hong Kong’s largest-ever corporate green dim sum bonds issuance. The transaction raised an aggregate amount of RMB 3.2 billion, and net proceeds will be used to fund or refinance projects relating to green building development, energy efficiency, renewable energy, sustainable water and waste-water management, or climate change adaptation, as part of Swire Properties’ Sustainable Development 2030 Strategy.
Five Pacific Place
Swire Properties has renamed its new office tower at 28 Hennessy Road “Five Pacific Place”, further aligning the development with the exciting eastward expansion of the Pacific Place portfolio. The company has upgraded the tower to create a shared visual identity with the adjacent Six Pacific Place, as well as shared amenities, including a sky garden, carpark spaces and food and beverage outlets. Six Pacific Place, the newest triple Grade-A office tower within Swire Properties’ Admiralty portfolio, is on track to be completed by the end of this year, adding diversity and further strength to the Pacific Place brand.
Green Performance Pledge Phase II
Swire Properties’ proprietary sustainability initiative for office tenants, the Green Performance Pledge (“GPP”), has entered a new phase, following a successful two years of implementation that has seen uptake increase fivefold, with nearly 70 tenants across the Hong Kong office portfolio joining the scheme. A highlight of the enhanced GPP iteration is the “GPP Academy” – a three-year collaboration with the Business Environment Council to enable office tenants to tap industry knowledge and best practices to help them achieve their ESG goals. Digitalisation will also be a key focus, with smart solutions such as a main circuit monitoring system, digital water meters, and the continued deployment of smart waste solutions.
New business hub
Papua New Guinea conglomerate, Steamships Trading Company, recently took possession of a 38-hectare site with direct access to Port Moresby’s Motukea International Port. The site will be developed and operated as Portside Business Park by Steamships’ property division, Pacific Palms Property. The mixed-use development will have three core zones: an Industrial Zone with wharf and open-yard storage; a Light Industrial Zone, and a Commercial Zone featuring retail, primary healthcare, and a business hotel. It is anticipated that total investment will exceed one billion Kina (approximately US$272 million). Steamships envisions the precinct as a future industrial and commercial hub for Port Moresby and is working with government agencies to have Portside Business Park designated a Special Economic Zone.
New Suzhou plant
On 20th September, Swire Coca-Cola broke ground for a new facility in the Kunshan Economic and Technological Development Zone in Suzhou, Jiangsu Province. Announced in January, the development of the new facility represents Swire Coca-Cola’s single largest strategic investment in the Chinese Mainland market. Spanning 116,000 square metres, the new plant will integrate production, distribution and a regional sales headquarters serving a large franchise population in eastern China; it is expected to be in operation by end of 2025.
SD venture capital fund
Swire Coca-Cola, The Coca-Cola Company and seven other Coca-Cola bottling partners have launched a sustainability-focused venture capital fund in partnership with Greycroft, a leading venture capital firm. The fund’s US$137.7 million in capital comes primarily from commitments of US$15 million from The Coca-Cola Company and each of the eight bottling partners. It has the potential to accelerate innovative solutions for sustainability and carbon reduction across the global Coca-Cola system. The fund will first focus on five key areas of packaging, heating and cooling, facility decarbonisation, distribution, and supply chain.
Global town hall meeting
In July, Swire Coca-Cola hosted a global town hall meeting, bringing together senior figures from Swire Coca-Cola and The Coca-Cola Company to engage with staff across all operating regions, with the aim of fostering unity, collaboration, and alignment within the global Coca-Cola system. The panel of speakers included Swire Coca-Cola Chair, Pat Healy, Managing Director, Karen So, and The Coca-Cola Company’s Chairman and CEO, Mr James Quincey, who participated remotely. The meeting was an opportunity for leaders to share their vision and strategic direction for Swire Coca-Cola, highlighting the importance of teamwork, as well as innovation and adaptability to the ever-evolving business landscape.
Finlays strengthens tea extraction capabilities
In July, leading tea, coffee and botanicals producer, James Finlay, reached agreement to purchase the tea and yerba mate [a herbal tea originated from South America] extraction assets of Paraguayan food ingredients business, Natural Instant Foods. Finlays plans to move the assets to Kenya, to serve as a small-scale production line and pilot plant at its Saosa tea extraction facility at Kericho. This will enhance Finlays’ R&D capacity by allowing Saosa to offer sampling and small-batch capability, enabling it to respond rapidly to the changing needs of its global customer base. Saosa is one of the world’s only extraction facilities located on a tea farm, giving Finlays the unusual ability to extract from fresh leaf on the day of harvesting to create premium tea extracts that are rich in bioactive compounds, thereby tapping into growing consumer demand for healthy, natural, and sustainable beverages.
New Midwest cold store
In September, United States Cold Storage (“USCS”) broke ground for a 13.6 million-cubic-foot automated cold store at Hebron, Indiana, approximately 60 miles outside Chicago. On completion in 2025, the facility will offer 43,421 pallet positions – of which, over 80% will be serviced by an automated storage and retrieval system. The store will have convertible temperature controls, but is expected to be fully frozen, bringing much needed new capacity and distribution services to frozen food customers in the Midwest. USCS owns 110 acres at the site; the warehouse, trailer-drop areas, dock, and other needs will account for 70 acres, while a 40-acre section provides room for a customer to build an adjacent production facility. USCS will install a solar array to provide 100% renewable energy to the facility.
Sustainable Future 2030
Finlays has launched a new sustainability strategy, Sustainable Future 2030, focusing on three key pillars of Climate Net Zero, People, and Sustainable Supply. Finlays has ambitions to achieve carbon net zero by 2040 and substantially reduce its footprint by 2030. Its People pillar will focus on building an inclusive, nurturing workplace. Meanwhile, the Sustainable Supply pillar aims to enhance product traceability, as well as the social, environmental, and economic value of the supply chain. The launch follows the conclusion of Finlays’ previous five-year sustainability strategy, which achieved 100% traceability in tea and 97% traceability in coffee by the end of 2022, as well as reducing Scope 1 and 2 carbon emissions by 34% from a 2018 baseline.
Cadet pilot training
Cathay Pacific recently celebrated the graduation of its first group of cadet pilots since the pandemic. After completing the 55-week Cadet Pilot Training Programme, the 19 graduates joined the airline as Second Officers in July. Cathay Pacific currently operates two parallel cadet training courses, and these graduates were part of the airline’s original Flight Training Adelaide-hosted programme, which coincidently marked its 35th anniversary in June. The airline has more recently developed integrated courses with Hong Kong Polytechnic University and its own in-house Cathay Academy, with cadets undertaking theoretical ground training and simulator training in Hong Kong, and flight training in Arizona or Adelaide. A total of 177 cadet pilots are expected to graduate from both programmes in 2023, and Cathay Pacific hopes to recruit more than 800 cadet pilots during 2023-2024.
Fleet expansion
The Cathay Group has announced it intends to purchase up to 32 single-aisle Airbus A321neo and A320neo aircraft, as it continues to invest in expanding and modernising its fleet and growing flight connectivity at the Hong Kong international aviation hub. The aircraft are expected to be delivered by 2029 and will join the fleets of Cathay Pacific and HK Express, principally serving destinations on the Chinese Mainland and elsewhere in Asia. The investment comes on top of Cathay’s initial order for 32 A321neos, placed in 2017; the Group has already taken delivery of 13 of those aircraft.
New CEIV accreditation
Cathay Cargo and the Cathay Cargo Terminal have both achieved IATA Centre of Excellence for Independent Validators Lithium Batteries ("CEIV Li-batt") accreditation. The safe carriage of lithium-ion batteries has become a core focus for Cathay’s cargo business. CEIV Li-batt will give cargo customers further confidence that Cathay adheres to the highest standards for handling and carriage of lithium-ion batteries across its logistics supply chain. The programme is underpinned by the IATA Dangerous Goods Regulations and IATA Lithium Battery Shipping Regulations, and includes training, assessment and validation that demonstrate compliance. Both Cathay Cargo and the Cathay Cargo Terminal now hold the full set of CEIV certifications, including CEIV Pharma, CEIV Fresh and CEIV Live Animals.
‘We Know How’
Cathay Cargo recently launched its first marketing campaign, since its rebranding in February. “We Know How” focuses on innovation, people, solutions, and service. It comes at a time when Cathay Cargo is developing its extended home market in the Greater Bay Area, and just ahead of the Three-Runway System at Hong Kong International Airport, which will become fully operational in late 2024. Recent investments include Ultra Track, a next-generation track-and-trace tool, and Click & Ship, which puts purchase and confirmation in customers’ hands; infrastructural upgrades include the Pharma Handling Centre at Cathay Cargo Terminal, and a range of specialist handling systems and digitalising processes.
Celebrating 30 years of success
HAECO Xiamen has celebrated its 30th anniversary with a special hangar ceremony and a banquet for over 300 guests. Established in 1993 by HAECO and local partners, HAECO Xiamen currently operates six hangars for both wide-body and narrow-body aircraft and provides line services to more than 100 airlines at 17 stations across the Chinese Mainland, as well as parts manufacturing for more than 4,000 different parts. HAECO Xiamen is investing in new maintenance facilities at the new Xiamen Xiang'an International Airport that will set standards in innovation, sustainability, and operational excellence, equipping the MRO to better serve its customers and position itself as a global industry leader.
Supplying NZ’s renewables sector
Swire Shipping’s projects and heavy-lift shipping services division, Swire Projects, recently delivered 10 wind turbines from China to the port of Bluff in the South Island of New Zealand for leading renewable energy company Vestas. The V136 wind turbines were destined for the Kaiwera Downs Wind Farm (Stage 1), which is being completed near the town of Gore in Southland. Swire Projects has established a reputation as a reliable and experienced carrier of renewable energy cargo, and the team deployed its newly chartered 28,500 DWT vessel, *Pacific Humility*, which has three cranes of sufficient capacity, as well as optimum stowage space, to transport this large and complex cargo in a single shipment.
In July, a team from Taikoo Motors took part in the Harley-Davidson Homecoming Festival, held in Milwaukee – the city where Harley-Davidson motorcycles originated. This year marks the 120th anniversary of the Harley-Davidson brand, bringing thousands of moto-enthusiasts to Wisconsin for the annual festival. Taikoo Motors’ subsidiary is the exclusive importer in Taiwan region for Harley-Davidson motorcycles, genuine parts and accessories and branded merchandise.
**Leading the way to greener bus operations**
Argent Fuels, part of the 100% Swire-owned Argent Energy Group, has announced a partnership with Transdev, a prominent bus operator in the North of England. Argent will assist Transdev in transitioning its entire UK fleet, which is spread across 10 operating centres in Yorkshire, Lancashire, and Greater Manchester, to High Blend Fuel, replacing 15% (and later 25%) of fossil diesel with sustainable, waste-based biodiesel. The collaboration will reduce Transdev’s carbon emissions by 3,612 tonnes per year – equivalent to removing 1,745 cars from the roads.
**FAME and success**
Fatty Acid Methyl Ester (“FAME”) biodiesel manufactured in the Netherlands by Argent Energy, has been used in a successful nine-month pilot to trial its use in the inland shipping sector. The initiative was a partnership between Dutch maritime logistics company VT Group and FincoEnergies, an independent supplier of sustainable energy solutions, which used 100% FAME sourced from Argent in VT’s tanker, *MTS Vlissingen*. The Dutch government has been a frontrunner in Europe in decarbonising and incentivising the inland shipping industry and 100% FAME is a cost-effective option, as it can be used as a drop-in replacement for regular marine diesel fuel without the need for engine modification. Argent Energy’s 100% FAME exceeds marine grade specifications and the biodiesel supplied to FincoEnergies for the trial achieved a reduction of around 85% in CO₂ emissions.
Connecting for a brighter tomorrow
An event held at ArtisTree in September celebrated all that has been achieved under TrustTomorrow – Swire Trust’s pioneering philanthropic initiative, launched in 2020 to mark the Group’s 150th anniversary of doing business in Hong Kong. The initiative, along with an additional HK$150 million to super-charge the Group’s philanthropic activities, has focused on supporting projects that benefit the areas of Education, Marine Conservation and the Arts. TrustTomorrow has also helped the most disadvantaged in society and supported vulnerable groups during the COVID-19 pandemic. In the past three years, TrustTomorrow has funded over 70 projects via more than 100 NGOs, benefitting over two million people. Beyond funding support, TrustTomorrow has also connected partners to skills, capabilities, and other resources via Swire’s businesses and the time and talent of staff volunteers.
“Connecting for a Brighter Tomorrow” was well-attended by guests from the government, the philanthropic sector and NGO and community partners. During the event, representatives from two partnership projects shared experiences of the heightened impact achieved with TrustTomorrow’s aid.
An online matching platform helped volunteering advocate, Time Auction, connect over 720 NGOs with more than 17,500 skilled volunteers. Meanwhile, “Building Community, Building Tung Chung”, a collaboration with multiple NGOs, has offered a range of support services to local families, benefitting over 17,000 people.
Event highlights included a multimedia performance created by TrustTomorrow partner National Geographic to raise awareness of marine conservation, and a performance by The Orchestra Academy Hong Kong – a partnership with the Hong Kong Philharmonic Orchestra and the School of Music of The Hong Kong Academy for Performing Arts that provides performance training to graduates, who also volunteer their talents in educational and social projects. The event wrapped up with a specially-curated networking session where guests from the philanthropic and NGO sectors could meet each other and identify like-minded potential partners for future collaboration on worthwhile projects.
Swire backs sci-tech innovation
The Swire Group has launched the “Hong Kong Young Technology and Innovation Talent” programme, which aims to encourage undergraduate students from Hong Kong to study science and technology at Chinese Mainland universities. The programme is designed to facilitate knowledge-sharing and the development of sci-tech innovation. From 2023-2025, the programme will admit 100 Hong Kong students who already have an offer from a Chinese Mainland university to study a science or engineering subject at undergraduate level. Successful candidates will be given a cash grant of HK$40,000 per year to cover tuition fees and living expenses. They will participate in research and study tours, including visiting key scientific research centres and sci-tech innovation enterprises, and will have the opportunity to engage with renowned scientists, entrepreneurs, and researchers. The programme will also provide subsidised summer internship opportunities for students.
The launch of the “Hong Kong Young Technology and Innovation Talent” programme on 19th June was followed by a sci-tech discussion forum. The event was hosted by Guy Bradley, Chairman of John Swire & Sons (H.K.) Limited (sixth from right), and attended by scientists, technologists, and official representatives from the various government offices, including Mr Yin Zonghua, Deputy Director of the Liaison Office of the Central People’s Government in the Hong Kong SAR and Mr Chan Kwok-ki, Chief Secretary for Administration of the Hong Kong SAR Government (seventh and eighth from right).
Summer internships
An orientation day was held in June for 26 students beginning six-week summer internship programmes with Swire operating companies in nine Chinese Mainland cities. Swire has offered these internships since 2018, as part of a scheme organised by the Hong Kong SAR Government to enable students to gain work experience with corporations on the Chinese Mainland or overseas. This year, Swire offered the second highest number of placements among participating corporates, with opportunities across the aviation, property management, and food and beverage production sectors. Mr Wallace Lau, then Commissioner for Youth from the Home and Youth Affairs Bureau, attended the orientation day and gave a talk to the interns.
Connecting young people through classical music
The Greater Bay Area Youth Orchestra ("GBAYO") made its debut in August, launching a four-city tour of the region. The GBAYO was established and is directed by The Hong Kong Academy for Performing Arts ("HKAPA"), with the support of the Swire Group as Founding Patron. The GBAYO aims to connect talented young musicians from diverse backgrounds, enabling them to pursue their dreams together, while elevating the standard of classical music in the region. The orchestra's inaugural performance at HKAPA's Hong Kong Jockey Club Amphitheatre was followed by concerts at the Macau Tower, the Shenzhen Grand Theatre, and the Guangzhou Xinghai Concert Hall.
100th anniversary
This year is the centenary of Taikoo Primary School in Quarry Bay. Originally opened by Swire in 1923 as a free school for children of its workforce at Taikoo Sugar Refinery and Taikoo Dockyard, the school became government-subsidised from 1947. In 1966, Swire donated land as well as paying half the construction costs for a new school building and in 2002, the school moved again into a new campus financed and developed by Swire Properties. Though today fully funded by government, Swire, as School Sponsoring Body, continues to provide financial and other assistance to support enhanced educational programmes. Looking ahead, Taikoo Primary School will continue to offer a caring environment where students can learn and flourish.
New Harbourfront community space
“Quarryside”, the new harbourfront community space operated by St. James’ Settlement, was officially launched in June. The facility can host a wide range of community activities, with a focus on health and wellness, creative placemaking, and sustainable living. It was built with the support of the Hong Kong SAR Government’s Development Bureau and HK$15 million funding from Swire Trust; Swire Properties, as Supporting Partner, provided consultancy support for its design, construction, and operation. With architectural features referencing Quarry Bay’s industrial heritage, the 3,700-square-metre site has multifunctional event spaces, including a theatre, creative workshops, community kitchen and function rooms, as well as a pet-friendly green space. In August, the Quarryside Summer Fest – one of the supporting events for the Government’s “Happy Hong Kong” programme – provided an opportunity for the community to enjoy live music, summer-themed snack stalls, and a variety of free activities. The event was organised and co-sponsored by the Eastern District Office of Home Affairs Department and St. James’ Settlement, with Swire Properties as Community Sponsor – highlighting the value of collaboration between government, NGOs, and the private sector for the benefit of the community.
Quarryside Summer Fest was an occasion to relax, enjoy live entertainment, food and drinks, and art and culture.
Bi-city Youth Cultural Exchange
Sixteen university students from Beijing and Hong Kong visited the Palace Museum in Beijing on 22nd August as part of the two-month “Bi-city Youth Cultural Leadership Programme”. Swire Properties is Lead Sponsor of the Hong Kong Palace Museum’s flagship youth-learning initiative, which aims to promote Chinese culture inheritance and foster cultural exchange.
‘Musical Legends’
Following on from the success of January’s free Swire Community Concert, a second concert programme, entitled “Musical Legends”, was performed at both the Hong Kong Cultural Centre and at Tsuen Wan Town Hall Auditorium during September. With guest conductor Yu Long, soprano Song Yuanming, and presenter Homer Lee, the Hong Kong Philharmonic Orchestra led the audiences on a journey through well-known works by Elgar, J. Strauss II, Puccini, Rossini, and Wagner. The “Musical Legends” concerts were inclusive events, welcoming families, and people with special needs to enjoy music together.
Food rescue
In September, Swire Coca-Cola HK’s volunteer team, V Group, helped sort and pack leftover fruit and vegetables following ASIA FRUIT LOGISTICA 2023 – an international trade exhibition held at AsiaWorld Expo. With the city mopping up after a once-in-500-years rain that turned streets into rivers, stranded drivers in vehicles, and flooded malls and MTR stations, 35 volunteers raced to collect up produce before the event booths were dismantled. The initiative was organised by Feeding Hong Kong, a charity dedicated to rescuing quality surplus food destined for the landfill and redistributing it to people in need.
In May, some 170 youngsters and their mentors enjoyed a 90-minute flight above Hong Kong on board a state-of-the-art Airbus A350-1000 aircraft. The Cathay Community Flight 2023 – the eighth since 2007 – was the culmination of a series of initiatives in support of the Hong Kong SAR Government’s “Strive and Rise Programme”, which pairs students with volunteer mentors to help them build self-confidence and guide them in developing personal goals.
Better employers
Swire Properties and Swire Pacific have been included in a list of Hong Kong’s “top ten” public companies compiled by Equileap, a leading organisation that reports annually on gender equality in the corporate sector. The 2023 Gender Equality Global Report & Ranking scores businesses according to criteria including employee gender balance, pay gap, and policies relating to parental leave and sexual harassment. Meanwhile, global human resources consultancy, Randstad, has recognised Swire Properties and Swire Coca-Cola as being amongst the most attractive employers in Hong Kong in its 2023 Employer Brand Research report. These accolades reflect the Swire Group’s dedication to building a positive, inclusive, and rewarding working environment.
Commitment to sustainability
Swire Pacific and its publicly listed operating companies, Swire Properties and Cathay Pacific, have been included in the first edition of the S&P Sustainability Yearbook (China) 2023. The companies were amongst only 88 out of 1,600 China businesses assessed for their ESG performance to make it into Standard & Poor’s 2023 yearbook, and Swire Properties is the only business in the real estate sector achieving the top one percent S&P Global ESG Score (China). Swire Properties is also ranked No. 4 globally and No. 1 in Asia (for the second consecutive year) in the Dow Jones Sustainability World Index.
Sustainable airfreight
Cathay Cargo has been named Sustainable Cargo Airline of the Year – Asia by global industry publication, Freightweek, in its 2023 Sustainability Awards. The accolade recognises Cathay Cargo’s focus on optimising fuel consumption and reducing emissions, and its pioneering approach to exploring alternative fuels. On the ground, the airline has invested in eco-friendly facilities and technology, while minimising waste in its operations, and it has engaged with industry partners and customers to raise awareness, promote sustainable practices, and inspire change with initiatives such as the “Fly Greener” carbon offset programme.
Flying high
Cathay Pacific is once again ranked amongst the world’s Top 10 Airlines, and has also won the World’s Best Inflight Entertainment in the 2023 World Airline Awards by SKYTRAX. The airline was also listed amongst the top 10 in AirlineRatings.com’s Top 25 Premium Airlines for 2023. Continual enhancements to product and customer experience – from reopening airport lounges, to partnering with renowned Hong Kong restaurants to introduce gourmet inflight menus – are helping Cathay Pacific to up its game in the wake of the pandemic.
Partnering for a sustainable future
When it comes to sustainability, Swire Properties is widely recognised as an industry leader, both in Hong Kong and the Chinese Mainland. Here, Swire News takes a look at how the company’s long-term, joint research efforts with Beijing’s Tsinghua University are playing a key role in ensuring that the business successfully meets its decarbonisation targets.
Swire Properties was the first property developer in Hong Kong and the Chinese Mainland to set approved 1.5°C-aligned science-based targets. By doing so, the company has established a long-term decarbonisation trajectory for its global portfolios that is aligned with the Paris Agreement. Swire Properties has also set a target of being net-zero by 2050 and is well on-track to achieving this goal, thanks to its ongoing collaboration with the prestigious Tsinghua University.
**A lasting partnership**
Swire Properties and Tsinghua University established the Building Energy Efficiency Research Fund in March 2008. At that time, the developer was already making strenuous efforts to make the properties in its portfolio more energy efficient. The university was, meanwhile, the leading researcher in this field in the Chinese Mainland and had been appointed to lead the Eleventh Five-Year Scientific Research Project on building energy sub-metering to deliver energy reduction through scientific, data-based methods.
Since then, Swire Properties has contributed more than HK$60 million in funding towards the research partnership and, in 2011, the two organisations established the Joint Research Centre for Building Energy Efficiency and Sustainability (“Joint Research Centre”), which has gone on to achieve impressive energy saving results. Over the past five years, key achievements include the identification of a total of 23 million kWh per year of potential energy saving opportunities through the retro-commissioning of existing buildings and facilities in the Swire Properties portfolio. These savings will reduce CO₂ emissions by 16,000 tonnes annually – the equivalent of planting 700,000 trees.
Tim Blackburn, Chief Executive of Swire Properties, explains the significance of the partnership to the company’s operations: “When we set out to implement greater sustainability in our developments, it was incumbent on us to work with the very best in the industry. Tsinghua University is the Chinese Mainland’s leading academic institution and excels in sustainable development research and innovation. The university’s status also grants it a profound knowledge of the national policy on sustainability matters. This has had a direct impact on how we are able to achieve our carbon reduction targets effectively and efficiently.”
**A shared focus**
It seems fitting that Swire’s motto, “Esse Quam Videri”, means “to be, rather than to seem to be”, while Tsinghua University’s motto is “Self-discipline and social commitment”. Taken together, these two maxims point to a shared working style, founded on science and data-based research and implementation. Both organisations also share the approach that technology can and should be adopted widely throughout the industry, and that information supporting this should be shared through seminars, workshops and publications.
Within the framework of the Joint Research Centre, the scope has now broadened from energy-saving diagnosis of existing buildings to areas such as design and operations. This means leveraging opportunities and developing innovative solutions, such as installing energy-management platforms, improving indoor air quality, harnessing renewable energy, applying machine-learning and embracing digital transformation – measures that closely align with the Chinese Mainland’s dual carbon goals of achieving a carbon peak by 2030 and carbon neutrality by 2060.
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**Tim Blackburn, Chief Executive of Swire Properties, and Professor Wang Hongwei, Vice President of Tsinghua University, sign the partnership agreement’s third renewal in Beijing, in April this year.**
Dr Wei Qingpeng, Associate Professor at Tsinghua University’s Department of Building Science and Technology, has been closely involved in the collaboration. He says: “Swire Properties is no ordinary funder. Among Tsinghua’s thousand-plus commercial partners, Swire Properties is one of our few long-term partners – and one that is genuinely hands-on when it comes to projects. Over the past 15 years, we have worked closely on many different developments across the Chinese Mainland and in Hong Kong, including shopping malls, office buildings and hotels.”
Dr Jean Qin, Swire Properties’ Deputy Director, Technical Services & Sustainable Development, Chinese Mainland, works alongside Dr Wei and his team on each project. She explains more: “The successful implementation of sustainable development features requires a sharp eye for identifying hidden pain-points, an innovative approach to devising solutions, and meticulous planning to manage their implementation. There is no cookie-cutter approach, and each case is unique. The only formula for success is continuous innovation – something which inspires the teams from Swire Properties and Tsinghua University alike.”
**Technology and innovation in action**
While implementing sustainability initiatives can be seen as simply “the right thing to do”, it can bring additional positive benefits – such as being precisely what elevates the overall customer experience at Swire Properties’ developments. An example is INDIGO, Beijing, where teams from Swire Properties and Tsinghua University addressed the pressing issue of temperature disparity inside the development’s shopping mall.
“A typical problem for many Beijing shopping malls in the depths of winter is that the upper floors can be more than 10°C warmer than the lower floors,” explains Jean. “This means shoppers are often compelled to wear jackets on the lower floors and will then have to remove them when they go upstairs. This affects their personal comfort, and it also leads to higher energy usage inside the building.”
The solution was for Tsinghua’s team to scan the entire outer façade of the building with infrared technology, identifying where cold air leaks occurred. In parallel, Swire Properties’ teams worked to optimise the mall’s air-handling units, including the F&B outlets’ kitchen ventilation systems. As a result of the work carried out, the temperature gap inside INDIGO mall decreased from 11°C to a mere 3°C. This not only helped reduce the amount of energy used in heating the mall, it also significantly improved overall customer experience. Such was the success of the project that it featured as an example of a super-low heating energy project in Tsinghua University’s respected Annual Report on China Building Energy Efficiency in 2018.
At Swire Properties’ Taikoo Li Sanlitun mixed-use development in Beijing, research showed that replacing the entire air conditioning system would bring significant energy savings. Typically, such a major retrofit would affect almost every area of the property, requiring at least partial closure, and creating significant operational and financial impact. Instead, work is being undertaken over six years, from 2019 to 2024, while maintaining normal operations at the mall. Implementation involves more than 10 teams from Tsinghua and Swire working in close collaboration, with much of the technical work being carried out at night; the project has been so meticulously planned that
nightshift arrangements are timetabled at half-hourly intervals across the entire period. Once completed in 2024, it is estimated that energy savings will be in the order of 13.4 million kWh per year.
Swire Properties is keen to make energy reduction breakthroughs – especially if they are the result of innovation. Taikoo Li Sanlitun is the first commercial building in the Chinese Mainland to install a Photovoltaic, Energy Storage, Direct Current, Flexible (“PEDF”) system. Solar panels will generate free, renewable energy amounting to around 110,000 kWh each year; and since there will be no energy lost in converting alternating (mains) current to direct current, the project’s direct current microgrid distribution system should save approximately 90,000 kWh each year. A pilot trial for two of the buildings covering 3,000m² is currently underway, with the support of the China Building Energy Conservation Association’s PEDF Expert Panel. It is hoped that the project will encourage further trials across the Chinese Mainland.
The successful collaboration between Swire Properties and Tsinghua University extends to other key portfolios, where steps have been taken to retro-commission existing developments with the latest technology. At Pacific Place Mall in Hong Kong, for example, the continuous improvement achieved in the mall’s operational energy performance led to Swire Properties winning the American Society of Heating, Refrigerating and Air-Conditioning Engineers’ 2021 ASHRAE Technology Award – Existing Building Commissioning category.
**Future ambitions**
In April this year, Swire Properties signed the third renewal of its partnership with Tsinghua University, with the company committing to an additional RMB 15 million in funding over three years. Tim Blackburn has high expectations: “We are continually seeking ways to innovate and that is how we will continue to make breakthroughs and achieve industry firsts,” he says.
“We are proud of what we’ve achieved already over the past 15 years, but there is always more to be done. We are serious about decarbonising our developments, and the only feasible way to do so is by harnessing cutting-edge technology and research, and continually applying it wherever we can. It’s not just a case of identifying solutions. Rather, it is a joint commitment to continuous improvement. That is how we ensure we are placing sustainability at the heart of our operations – by seeking to improve all the time.”
This ambition goes beyond the current generation of developers. As a platform for higher education and the cultivation of outstanding young minds, the Joint Research Centre provides hands-on experience for students at Tsinghua University, helping them make the leap from textbooks to practical application. Under the auspices of the Joint Research Centre, 26 postgraduate and 20 undergraduate students have completed their graduation projects using Swire Properties’ developments as case studies, while hundreds of Tsinghua University students have taken part in site visits.
Teams from Swire Properties and Tsinghua University are also looking at ways to use innovative ground source heat pump technology at the Taikoo Li Xi’an development when it is completed in phases from 2025. The technology harnesses renewable geothermal energy, which can be deployed in the building’s heating and cooling systems. This will be the first instance of ground source heat pump technology being used in a large-scale commercial development in western China.
There is still much to be done to achieve carbon neutrality within the industry, but we can look forward to being inspired by yet more exciting sustainability projects arising from the renewed collaboration between Swire Properties and Tsinghua University.
Tsinghua University students have the opportunity to gain hands-on engineering experience, working alongside Swire Properties’ maintenance teams.
Lisa Kasnari is Chief Officer on Waiowa – a 4,300 BHP tug used primarily for open ocean towage and salvage projects, and one of a fleet of 12 owned by Pacific Towing – a part of the logistics division of Papua New Guinea conglomerate, Steamships Trading Company. A “pawa meri” (“woman of power”) who is blazing a trail for other female Pacific Towing officers who are following in her footsteps, Lisa aspires to one day go to sea with Steamships’ Consort Express Line or Swire Shipping, on her way to becoming a Master Mariner.
Lisa joined Pacific Towing in 2017 as a Deck Cadet, in the first intake of a programme designed to introduce more employment opportunities for women into this traditionally male-dominated sector. After successfully completing her Mate Class III – Deck Officer qualification at the Fiji Maritime College in 2021, she is due for her final assessment at her current rank, which will qualify her to take full command of her own vessel in PNG waters.
What made you choose a career in shipping?
I was second eldest of five girls, but there was a strong tradition of seafaring in our family; my father and late uncle were both seafarers, and my grandfather was a skilled fisherman. As a child growing up in Kiunga [a port on the Fly River], I used to look forward to my dad and uncle returning home with souvenirs from their voyages. My dad would also bring home magazines from work: ships, ships, ships, and everything about ships! So I had the interest as a kid – but I never thought I would end up here!
What are your key responsibilities on board?
I’m responsible for leading and managing a team of 10, including deck and engine room staff and lines personnel, as well as any cadets we may have on on-the-job training. This means I am continually assessing the performance of staff and monitoring their wellbeing, and I supervise the execution of all orders relating to tug movements. So my role requires a lot of communication.
How do you balance your role at work with family life?
I am very fortunate to work for an employer who is a big advocate for gender equality. Here at Pacific Towing, the management go to great efforts to make the workplace inclusive. There are strict company policies in place to protect and guide us, and to ensure staff – men and women – are able to perform our jobs to the best of our abilities. Currently, I work a 5–2 roster, as two of my four children are under the age of two. This means I work from 8am to 5pm, five days a week, and I have two days off in a week. But if I’m asked to go on unplanned salvaging
or towing trips, or to stand in for colleagues on harbour operations at other ports, I don’t hesitate. I see every opportunity I’m presented with as a chance to learn and grow. I’m very grateful to Pacific Towing for allowing me this degree of flexibility, which enables me to juggle family life as well as my job. Nevertheless, I’d find it much harder to manage without the support of my wonderful family.
**Can you share a particularly memorable experience while working at Pacific Towing?**
I was recently given my first temporary command, to bring *Waiowa* back to Port Moresby, following a double salvage of two fishing boats off Misima, in Milne Bay Province. It was a milestone for me, as my first trip as Master, and the weather was at its peak, with a cyclone warning in force. So the circumstances were challenging and took me outside my comfort zone. But *Waiowa* is a small but sturdy tug that manoeuvres well, and I was leading a very good team of seafarers, so I felt the experience helped us all to grow.
**Tell us about your career goal of becoming a Master Mariner: what are the next steps on your journey?**
For this goal to come to fruition, I know I am going to have to make more sacrifices around my personal life to put the necessary effort in. I am working hard on gaining trust and respect amongst my more experienced colleagues, and I’m focused on mastering the handling of our ASD [Azimuth Stern Drive] tugs before pursuing Master Class III and then hopefully climbing the ladder from there to Class II and Master Class I – Unrestricted. I am so much in awe of the women who have gone before me and broken down barriers and stereotypical thinking simply by excelling and without any fanfare. I am eager to learn, and I hope I can flourish and grow, with the right mentorship and guidance from some of the best tug masters in Papua New Guinea.
**As a woman leader working in a traditionally male dominated field, what words of encouragement would you offer to other women who are considering a career in shipping?**
I hope my journey will inspire and empower other women to pursue the same pathway. I would tell them to set themselves goals; keep challenging yourself and persevere. Remember that it’s not about competing with your male counterparts, but about learning everything you possibly can from skilled and seasoned mariners. So set aside differences and put your mind to achieving what you want to. You can do almost anything if you put your mind to it.
John Swire & Sons (H.K.) Limited Chairman, Guy Bradley, visited Swire operating companies in Taiwan region in July. While in Taipei, Guy hosted a function for management staff from Cathay Pacific, China Pacific Catering Services, Swire Coca-Cola, Swire Shipping and Taikoo Motors Group, and expressed his appreciation for the teams’ hard work over the years, especially during the COVID-19 pandemic.
Joyful and healthy workplace
In Hong Kong, Swire Resources has won the enterprise Grand Award in the Joyful@Healthy Workplace Best Practices Award, jointly organised by the Department of Health, the Occupational Safety and Health Council and the Labour Department. The judges complimented the company’s employee-centric programmes aimed at promoting physical and mental wellbeing – including free fitness classes and recreational activities, flexible work policies, and better-for-you snack offerings.
Staff take part in regular fitness activities in the office, coached by professional trainers.
After weeks of practice, come rain or shine, it was showtime for the Swire Dragons & Dinosaurs team competing in this year’s Dragon Boat (Tuen Ng) Festival, held at Stanley Main Beach on 22nd June. The key to successful dragon boat racing is teamwork: the drummer guides and encourages the team, and all paddlers – from young first-timers to experienced race veterans – have their parts to play in bringing the boat smoothly across the finish line. It is this sense of teamwork that sits at the heart of everything we do at Swire.
Pride Month
In June, John Swire & Sons (H.K.) Limited celebrated Pride Month with a mahjong tournament – just one of the sports on offer at the Gay Games to be held in Hong Kong in November. The Swire Group will sponsor 50 employees to compete in the Games – the first time the tournament will be held in Asia. Cathay Pacific also celebrated Pride Month with the launch of a dedicated LGBT+ inflight entertainment channel and held LGBT+ movie screenings at Cathay City, while Swire Properties organised a 5km Pride Road Race and offered opportunities to share Pride stories.
SWIRE
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mercyHOUSING
Impact Report 2021
2021 began much like 2020 ended, as Mercy Housing continued to navigate a global pandemic. Despite the many unknowns and challenges of COVID-19, 2021 was a year where we worked together and made good progress toward our strategic goals. The strength and resilience of residents and staff to move forward, adapt, and be there for one another was inspirational. We are more determined than ever to expand our vision for a better future – where everyone has a stable, affordable home, and a place to pursue their dreams.
Together, we continued to help residents overcome barriers while addressing the social determinants of health. By providing access to local food banks and distributing food door-to-door, organizing over 80 onsite COVID-19 vaccine clinics, or offering support groups, we know that beginning with high-quality, program-enriched housing improves health outcomes and is a critical element for creating health equity.
In a year of continued economic uncertainty, our primary goal was to help residents stay in their homes. Our staff helped Mercy Housing residents access over $4.5 million in state and local emergency rental assistance while donors generously gave $1.4 million toward rent relief. Beyond rental assistance, the staff has made every effort to keep residents stable and healthy since day one of the pandemic. Mercy Housing puts residents at the center of our work – our North Star – to guide us in all of our decisions.
These accomplishments were possible because we stayed rooted in our core values of respect, justice, and mercy. This organization was built on the belief that housing justice is social justice, and we continue our deep commitment toward advancing this work. We acknowledge and celebrate our heritage and the legacy of the many communities of Women Religious that got us here today as we prepare to celebrate our 40th anniversary. Thanks to our founding communities, partners, and donors, we continue to create and preserve affordable homes and positively impact resident outcomes in urban, suburban, and rural communities across our country.
We look forward to the next 40 years. Just imagine what we can do together.
Yours in Hope,
Ismael Guerrero
President & CEO
Patricia Cochran
Chair, Board of Trustees
Many Mercy Housing residents were able to breathe a little bit easier thanks to the emergency rental assistance program. Mercy Housing’s Gleason Park Apartments resident, Katrina, was among them.
Katrina moved into Gleason Park in Stockton, CA with her husband, Anthony, and their two young daughters in 2019. Prior to moving into their new home, the family had experienced homelessness. “We were so down and looking for a place to live. We took busses and walked everywhere. We had to get our kids to school and stuff,” the couple explained. “When we received the call from Mercy Housing, it was a miracle. We believe they were put in our lives for a reason.”
With a place to call home, Katrina’s family was starting to settle in when COVID-19 took hold. Katrina was not only the first in her family to test positive but the first person at Gleason Park as well. “It was rough,” she said. “The scary, unknown, and not knowing who’s going to get it [COVID-19] like you.” As the only member of the household working at the time, the family depended on her paycheck for income.
Overwhelmed by the changing CDC guidelines and the uncertainty of if, or when, she would be able to return to work, Katrina turned to her resident services manager, Liz, for help. “Everyone was still coming to terms with the virus; confusion and the worry about paying rent was mounting,” said Liz.
The couple credits Liz with supporting their family through the pandemic by providing safety protocols and stable housing by accessing rent relief during a time of uncertainty.
Not only was there emergency state and local rental assistance available to qualifying families, but some residents also had access to additional relief, thanks to an anonymous donor in California who provided a gift of $1 million specifically to help with rent relief.
“Like everything else, there was a process each time,” Anthony explained. “But Liz was on it. We really trusted her.”
Katrina and Anthony were the first Gleason Park residents to fill out the application and receive approval. The financial assistance covered a full three months of rent, giving their family peace of mind while Katrina recovered at home.
“Katrina is really special and resilient,” said Liz. “Katrina’s story and my story have a lot of parallels. We both walked very difficult lives, and I think that’s what helped us bond. It’s kind of like, if I can do it, you can do it.”
Things are looking up today for Katrina and Anthony. Their daughters are back in school, Anthony recently found a job, and Katrina is back at work. The family now has its sight set on owning their own home.
“We couldn’t be happier right now,” Katrina said. “Mercy Housing gave us so much love,” Anthony added. “I really want to pay it forward.”
Donors gave $1.4 million for rent relief in 2021, while staff helped residents access over $4.5 million in state and local emergency rental assistance.
“We couldn’t be happier right now. Mercy Housing gave us so much love. I really want to pay it forward.”
– Katrina and Anthony, Mercy Housing Residents
We have been committed to keeping residents in their homes during the pandemic.
2021 Highlights
RACIAL EQUITY, DIVERSITY, INCLUSION
Our first Senior Vice President of Racial Equity, Diversity, and Inclusion (REDI) came on board to lead and implement structure and an organizational framework as our roadmap to ensure equitable and inclusive communities.
MERCY COMMUNITY CAPITAL
Our financing activities created and/or preserved 3,781 units of affordable housing and served 9,000 residents (more than half from traditionally underserved populations). We closed a record of 36 transactions that translated into $1 billion in total development costs.
EPIC EDUCATIONAL GRANTS
For the fourth consecutive year, the National Real Estate Practice of EPIC Insurance Brokers and Consultants partnered with Mercy Housing to help residents obtain their post-high school educational goals. $2,500 grants were awarded to 24 Mercy Housing residents.
GREEN HOPE PROGRESS
Mercy Housing became a Department of Energy Better Buildings Challenge Achiever by fulfilling our commitment to improving energy efficiency. We also implemented 17 sustainability projects and leveraged $700,000 in environmental incentives and rebates to achieve nearly $52,000 in estimated savings.
CLOSING THE DIGITAL DIVIDE
Mercy Housing staff continued to close the gap on the digital divide by connecting more than 300 households with emergency broadband benefits. In addition, we worked with our local partners to provide devices with low-cost internet service.
CORPORATE SUPPORT
Overstock.com became a Mercy Housing charitable partner. The home furnishings retailer committed to provide support, product donations, employee volunteer opportunities, and customer donations on their website in support of Out-of-School Time programming.
THE HUB ↑
Coming soon: At the heart of the Sunnydale neighborhood revitalization, the Sunnydale Hub in San Francisco will feature a brand new state-of-the-art indoor family recreation center with programming and amenities for the community.
By the Numbers
328 PROPERTIES
23,903 APARTMENT HOMES
42,447 RESIDENTS
6½ Years AVERAGE LENGTH OF RESIDENCY
WHO WE SERVE
- 65% Families
- 26% Seniors
- 9% Special Needs
RESIDENT RACIAL AND ETHNIC DIVERSITY
To ensure equitable and inclusive communities, our employees demographics align with the residents we serve:
- Black or African American: 27%
- Hispanic or Latinx: 23%
- White: 38%
- Asian: 11%
- Native Hawaiian or Pacific Islander: 1%
- American Indian/Native: 1%
The average resident income is $13,027 which is less than 1/5 of the national average of $67,521.
WHERE WE SERVE
Mercy Housing Communities
New Development
Mercy Community Capital
Regional Office
National Headquarters
“I have Mercy Housing to thank for helping me gain control of my health. I’m proud to do the same for others and be someone they can relate to through my role as a Community Health Worker.”
– Henry,
Mercy Housing Resident
The health and safety of Mercy Housing residents and employees are at the top of our list of priorities.
Amid a continued pandemic, we supported over 80 onsite COVID-19 vaccination clinics for residents and required all employees to be vaccinated.
Henry’s life has been full of both struggle and triumph. He overcame a challenging childhood to attend a prestigious college and later worked for years in social services. However, Henry also struggled with addiction, harming his career and relationships with his family. He decided it was time to take control of his life and checked himself into a recovery program, ultimately leading to his current home at South Loop Apartments in Chicago, where he has lived for 14 years. “This place became a sanctuary,” Henry says. It allowed him to reconnect with his daughters and grandchildren and helped him to manage his diabetes, cholesterol imbalance, and hypertension.
Henry is now one of Mercy Housing’s Community Health Workers, hired to help residents of supportive housing manage their chronic health conditions. He provided input on the program’s development and was trained, along with the other Community Health Workers, to deliver evidence-based services to help participants improve their health. Because Community Health Workers have had similar past experiences, they can relate to and understand the people they serve. Henry shares, “being the person they can relate to” is essential to connecting with and motivating participants to better their health.
The timing of the job could not have been more perfect. It provides Henry with the opportunity to give back to the supportive housing community. “I went through a period in my life where people reached out for me.” Henry says, “I’m working with people that are crossing the same path I crossed.”
His contributions continue to make an impact at South Loop Apartments and Mercy Housing. In 2019, Henry was appointed to Mercy Housing Lakefront’s Board of Directors.
Mercy Housing Lakefront’s Community Health Worker Program was developed and implemented in partnership with Blue Cross and Blue Shield of Illinois, Near North Health Service Corporation, Sinai Urban Health Institute, and the Washington Square Health Foundation.
Mercy Housing is committed to developing affordable, program-enriched housing for low-income families, seniors, veterans, and people with disabilities who lack the economic resources to access quality, stable housing.
In 2021, we opened eight new communities and refurbished three existing buildings. Regardless of the scale and population served, each Mercy Housing community is built with an unwavering commitment to dynamic partnerships, creative vision, and extensive community planning.
**MERCY ROSA FRANKLIN PLACE**
Named in honor of Washington State Senator Rosa Franklin, this vibrant community features 69 homes for seniors. It serves as a permanent reminder of her accomplishments and commitment to housing and health equality in the state of Washington.
**290 MALOSI**
Located in San Francisco’s Sunnydale neighborhood, this 167-home community is home to 125 families who are long-time Sunnydale residents. An additional 41 families from other parts of the city also call this new community home.
**CASA DE LA MISIÓN**
This five-story community with 45 homes for seniors exiting homelessness opened its doors in San Francisco, CA.
**1801 WEST CAPITOL AVENUE**
One block from the California State Capitol building in Sacramento, West Capitol, a 85-unit studio apartment community opened in 2021 for people exiting homelessness.
**VILLA DE VIDA POWAY**
Opened in July 2021, this new Southern California community welcomed adults with developmental disabilities who wanted to live both independently and in a community with others. Sixty new residents are now achieving their dream of leading independent, but not isolated, lives.
**SISTER LILLIAN MURPHY COMMUNITY**
691 China Basin is home to families in San Francisco. The community includes 152 apartments ranging from studios to five bedrooms. In 2022, the community will be renamed the Sister Lillian Murphy Community, in memory and celebration of former CEO Sister Lillian’s life of service.
**MERCY NORTH AUBURN AT ROCK CREEK**
Located in Auburn, CA, this new modern property features 79 one-, two-, and three-bedroom homes and three-bedroom townhouses for people with low income. Twenty homes have been set aside for No Place Like Home program recipients.
Along with new development, we acquire and renovate existing housing to preserve affordable housing.
**LA MANCHA WAY HOMEKEY**
La Mancha was acquired as the 124-unit WoodSpring Suites extended stay hotel in Sacramento, CA. It was converted into 100 permanent supportive housing apartments for people who are homeless and those at risk of becoming homeless. The project was acquired under the State of California’s HomeKey Program.
**MAJOR JENKINS**
Originally built in the 1900s, Mercy Housing acquired and renovated this property in 1995 and again renovated it in 2021. Located in Chicago, IL, this property includes 160 units of supportive housing with 80 apartments dedicated for formerly homeless individuals.
**GRACE APARTMENTS**
This apartment community in Denver’s East Colfax neighborhood features 53 apartment-homes and focuses on serving refugee families with over 12 different languages spoken by residents. Built in 1968, Mercy Housing has owned the property since 1991 and completed previous renovations in 1992 and 2003. With the rehab completed in 2021, we invested more than $4 million to completely refurbish the apartments and common areas, and we added a new outdoor common area for residents.
**MANZANITA**
Mercy Housing renovated a two-story stucco apartment building in San Francisco’s San Leandro community. The 80 one- and two-bedroom apartments serve families with low income and very low income.
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We are continually seeking ways to reduce the time and cost it takes to build affordable housing. Tahanan, which features 145 micro-studios for people exiting homelessness, was the first Mercy Housing community built using modular construction.
Located in San Francisco’s South of Market Area, this permanent supportive housing community for adults who have experienced homelessness was completed in 2021.
Traditional construction starts from the ground up, building each story only after the one below it is finished. Modular buildings are built in many pieces at an off-site warehouse, including wiring for electricity, plumbing, drywall, and cabinetry. These completed modules are shipped to the site, and the contractor uses cranes to stack them, much like building blocks. Finally, the modules are connected, and a ‘skin’ and roof are added.
Tipping Point and the San Francisco Housing Accelerator Fund chose Mercy Housing to build this community when we proposed using this quick, innovative building technology.
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24,587 RESIDENTS ACCESSED 519,820 RESIDENT SERVICES.
235 PROPERTIES offer resident services programs designed to help people build better lives.
17% INCREASE IN TOTAL FOOD PROVIDED from 2019 to 2021, and a 25% increase in households receiving that food.
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REVENUE BY SOURCE
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$4.585 BILLION in affordable real estate development since 1981
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Supporting Mercy Housing’s youngest residents is something we strive to achieve. We believe that kids need support to succeed in school and in life, which is why we provide Out-of-School Time programs to Mercy Housing youth. These programs offer kids a place to go when their parents are at work or if they need help with homework. And thanks to community partners, including the Dominican Sisters of Adrian and Arik Armstead, we have been able to grow our Out-of-School Time programs.
As a founding community of Mercy Housing Northwest (MHNW), The Adrian Dominican Sisters have a 29-year history of personal investment, volunteerism, and financial support of resiliency-building programming and growing the affordable housing portfolio of MHNW. And thanks to a $1.5 million investment from the Sisters in 2021, MHNW started expanding their K–12 educational programming by creating comprehensive Out-of-School Time programs enhanced by literacy and math curricula at eight additional MHNW family properties. This initiative will serve up to 1,000 children and youth in kindergarten through 12th grade annually in Washington and Oregon. MHNW has a remarkable track record with Out-of-School-Time programming, having seen a 100% high school graduation rate for over five years at one Bellingham, WA community.
Meanwhile, in California, Arik Armstead not only made his presence known on the field as a defensive end for the San Francisco 49ers but off the field as well as the founder of the Armstead Academic Project (AAP).
After a challenging year, residents of the Land Park Woods community in Sacramento found true cause for celebration when 150 children, caregivers, and supporters gathered to launch the Armstead Academy. Fueled by a $250,000 contribution to Mercy Housing California (MHC) from Arik, the Armstead Academy will provide top-notch academic coaching and after-school programming for K-12 students who live in the Upper Land Park area of Sacramento. Participants can reside either at Land Park Woods, one of MHC’s 152 affordable communities, or in the neighboring Marina Vista and Alder Grove public housing communities.
Armstead Academy participants will work with MHC staff and mentors to achieve academic success, develop leadership skills, enjoy college visits, and career exploration field trips, and take strides toward realizing healthy adulthoods.
Our five-year goal is to foster real and measurable progress toward school success at primary and secondary grade levels as children focus on on-time high school graduation and readiness for post-secondary education and career opportunities. We build upon our K-12 education support systems through our industry-leading affordable housing model. The focus is increasing student housing stability, strengthening student and parent engagement, and supporting a culture of school success.
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The Gap Note Program
Mercy Housing created the Gap Note Program as a new funding tool to help address the country’s ongoing affordable housing crisis. With Mercy Housing’s goal to develop and preserve 9,000 affordable homes by 2024, this program was designed to provide a source of low-cost, patient capital to fill the financial gaps caused by spikes in construction pricing and the lack of adequate local housing resources.
The National Low Income Housing Coalition (NLIHC) estimates that there’s an unmet need for over seven million affordable homes in the U.S. Every one- to two-million dollar investment from the Gap Note Program makes a $25 million affordable housing community possible. Even before the word “pandemic” entered our vocabulary, the affordable housing supply for renters with low and moderate incomes was desperately inadequate.
The financing of affordable housing is complex and requires capital from multiple sources, both public and private. The need for affordable housing exceeds the resources available, which often leaves projects with a financial gap and unable to move forward. The Gap Note Program provides critically needed capital to help fill that financial gap in affordable housing developed by Mercy Housing.
By investing in the Gap Note Program, investors are choosing to put affordable housing communities across the finish line that would not otherwise be completed. The $47 million Gap Note Program is possible thanks to investments by PNC Bank, Truist Bank, CommonSpirit Health, Wintrust Bank, Wheaton Bank, Mercy Investment Services and the Opus Foundation.
Over 1,200 residents volunteered at 94 different Mercy Housing communities.
$47 Million in investments for more affordable housing
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Sisters of Charity; Working In Neighborhoods
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Mercy Housing Inc. is a leading national affordable housing nonprofit that serves tens of thousands of people with low incomes every day. Founded by the Catholic Sisters in 1981, and with operations in 41 states, MHI has 40 years experience developing, preserving, managing, and financing affordable housing. MHI's subsidiaries further the organization’s mission: Mercy Housing Management Group offers professional property management and Mercy Community Capital finances nonprofit organizations.
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The Milk-spots, "Tâches Laiteuses" in Omentum.
Histological and Biological Studies Made Especially on Their Mesothelial Cell-layer and Histiocytes.
By Dr. Yukio Hamazaki.
From the Pathological Department of Okayama Medical College. (Director; Prof. Dr Oto Tamura)
Received for publication, July 3, 1925.
Table of Content.
I. Method,
especially on the "Silver chloride method" newly discovered by the author.
Appendix:—Origin of the cement-line.
II. The milk-spots.
1. Gross finding.
2. Histological appearance.
III. Morphological observation on the mesothelial cell of the milk-spots.
IV. Are the apertures of the milk-spots same with the so called "stomata"?
1. Literature.
2. Is the aperture in the milk-spots an artefact or not?
3. Relation between the aperture and the basal-membrane of the omentum.
4. Relation between the aperture and the subjacent lymph-vessel.
V. What are the epithelioid cells on the milk-spots?
1. General histological appearance.
2. Where does the epithelioid cell belong?
VI. The relation between the aperture and the epithelioid cell.
VII. The origin of the epithelioid cell, especially on the immigrating ability of the wandering histiocyte into the peritoneal tissue.
1. Experimental purpose and literature.
2. Experiment.
3. Discussion and summary.
VIII. Conclusions.
IX. Bibliography.
X. Description of the plates.
The great omentum requires further investigation, and the most interesting point hinges upon the study of its milk-spots, "tâches laiteuses."
The study of the "vital staining" has been markedly improved, and it has thrown some light upon the origin of the milk-spots. However, there still remain many questions. In this paper, it is intended to deal further with the subject of the milk-spots from the point of the histology and biology.
I. Method; especially on the "Silver chloride method" newly discovered by the author.
The rabbit was used for this experiment. The animal was sacrificed by bleeding from the carotid artery. The abdominal cavity was opened. The omentum was totally removed and placed in ten per cent solution of formalin for one day. It was washed thoroughly in running water and examined its extended specimen as well as its paraffin serial sections stained with Delafield's hematoxylin-eosin.
Various modifications have been devised by the others, since the method of silver impregnation was first attempted by v. Recklinghausen in 1860, but none of them proved to be free of artifacts, and one is apt to misinterpret such a resulting artifact. However, any misinterpretations of that kind are avoidable, if the comparative study be made on the results from the following three different methods.
1. Vital silver impregnation:—After fixing a rabbit on its back on a table, about 300 to 400 c.cm. of 0.1 per cent solution of silver nitrate was injected into the abdominal cavity. About forty minutes later, it was sacrificed by bleeding. The abdominal cavity was opened. The omentum was totally removed and after it was placed in a quite sufficient amount of ten per cent solution of formalin for a day, was washed in running water for a day, keeping always in the dark. Then the omentum exposed in the diffuse sunlight, until it had become brown in color. When the technique has been perfectly done, the cement substance of the peritoneal mesothelium will be seen as a distinct line. The colouring by the silver nitrate on the protoplasm of the mesothelial cell is very light and consequently it does not affect the subsequent staining with hematoxylin-eosin.
2. Supravital silver impregnation:—The same method as that of vital impregnation was used, except the silver nitrate injection was made after the animal was sacrificed by air-embolus.
3. Impregnation on the excised omentum:—As a generally used silver impregnation stains the cement-line very poorly and irregularly, and particularly is it so in
the case of the cement-line of the milk-spots which are minutely and complicately constructed, the author finally discovered a new method, "silver chloride method," after many failures. The method as follows:
(1) The removed omentum is divided into several pieces of a suitable size and rinsed in normal saline solution for about ten minutes. By this treatment the section will take a sufficient amount of NaCl.
(2) The solution is then substituted with 0.1 per cent aqueous solution of silver nitrate, so that the milky cloudiness of silver chloride appears around the section.
(3) It is then incubated at 40°C. for about forty minutes.
(4) Transferred in ten per cent solution of formalin.
(5) Thoroughly washed in tapped water.
(6) Reduced by diffuse sunlight.
(7) Differentiated by one per cent solution of aqua ammoniae for a few minutes.
(8) Washed in water and stained with hematoxylin.
The specimen thus obtained shows its cement-substance as dark lines brown to black in color.
Appendix:—Origin of the cement-line.
The definite conclusion as to the origin of cement-substance of pavement cell has not yet been reached. The theory hitherto mentioned is as follows:—The cement-substance is a semi-fluid and occupies the inter cellular space of the pavement cells. Combining with silver nitrate the albumin in the cement-substance forms an insoluble substance, viz., the silver albuminate, which is the substance reduced to brownish color in the sunlight.
By the vital silver impregnation in my experiments, the abdominal cavity is always filled with quite sufficient amount of milky fluid and the peritoneal surface also became opaque in color. Such milky coloration of the solution injected and of the cement-substance always parallels; namely, when the former was lightly colored, the latter was also colored lightly and when the former was deeply colored, the latter was also in deep color.
The above rabbit was substituted with frog and treated with 0.1 per cent solution of silver nitrate similarly as above-mentioned. On this occasion, no milky color could be seen either in the injected solution or on the peritoneal surface and so the cement-substance was not reduced to brown in color. However, if 0.2 per cent instead of 0.1 per cent solution of silver nitrate was used, milky color could be seen in the injected solution as well as on the peritoneal surface, as in the above rabbit's case.
Considering from this fact, it may be definitely said that the impregnation with silver nitrate of the cement-substance is principally due to an intercellular precipitating of the silver chloride which is chemically composed of the sodium chloride exist in the semi-fluidy matrix and of the injected silver nitrate. From this presumption,
the above-mentioned "silver chloride method" was here brought forth and experimentally assured that this view is quite right.
Achard and Aynaud described that the sodium chloride in the serous membrane plays an important rôle on the impregnation. They confirmed that the impregnation on the cement-substance cannot be obtained, when the sodium chloride is removed from the tissue by either Glauber's salt (sodium-sulphate) or sugar-solution. This fact furthermore affirms that the above view is correct.
II. The milk-spots.
1. Gross finding:
Removing the great omentum as a whole from the great curvature of the stomach, gastro-splenic omentum, gastro-colic omentum and the hepato-colic ligamentum, it was stretched on the slide. There is a main trunk of blood-vessels parallel with and two or three centimeters apart from the gastro-epiploica. In its course branches are derived and distributed to the main part of the omentum.
It is convenient to observe the great omentum in two parts, the upper small and the lower large, dividing along the main trunk of the blood-vessels. The upper small has a few net-meshes and the milk-spots are finely constructed similarly as in the case of mesentery. On the contrary, the lower large has many net-meshes and the milk-spots are numerous and in various sizes. This lower large part is of very importance from both the physiological and pathological stand points.
In the young age, the milk-spots appear mostly as groups of so called adventitia-cells (by Marchand) along this main trunk of the blood-vessels. The fatty tissue is very scanty. However, in the adult age, the fatty tissue mostly substitutes for the groups of the adventitia-cells and consequently, the milk-spots existing only along the distal branches of the blood-vessels are well developed and they were named "primary milk-spots" by Renaut. The typical primary milk-spots are sharply differentiated from the circumference and some possess spherical tufts of blood-capillaries. The milk-spots existed in such an area where is not supplied with the blood-capillary were specially called "secondary milk-spots" by Renaut and they are mostly occupied the lower middle part of the omentum.
It must not be disregarded that the development of the milk spots is sometimes very indefinite in the same species in nearly the same age.
2. Histological appearance:
The great omentum is consisted of four layers; two outer and two inner lamellae. The former belong to the wall of the greater sac of the peritoneal cavity and latter, to that of the lesser sac of the same cavity. The area between the outer and inner lamellae is occupied by scattered cell-elements that in places group in situ. These groups or islets are the so called "tâches laiteuses."
There have been many investigations on the main cell-element of the milk-spots and several literatures of them will be quoted here.
In 1863, v. Recklinghausen described on the cloudy spots of the omentum of a rabbit which consisted of the connective tissue-cells in various shapes. In 1877, the cloudy spots were furthermore investigated by Ranvier and he named them "tâches laiteuses" or "milk-spots." He regarded that the cell-element of the milk-spots is one of the connective tissue-cells—the "clasmatocyte"—by him. "It was characterized by its clasmatosis-phenomenon, viz., the protoplasm with many granulae is devided into several pieces." Renaut 1893 opposed the Ranvier's opinion. Considering the morphology and evolution of the cell-element of the milk-spots, he stated that it belongs to one of lymphocytes. "Wandering into the omentum and resting there, the lymphocyte takes part of the formation of the connective tissue-cell of the omentum." "With the consideration that this lymphocyte has a secretary function just like the other connective tissue-cells, he named it "cellules rhagiocrines." Marchand 1901 emphasized that the milk-spots are consisted of some connective tissue cells, and that they are quite similar to the adventitia-cell named by him. Maximow 1902 and Tschaschin 1913 viewed that the cell-element of the milk-spots is one of the histogenic wandering cells, resting in that region, but by a inflammatory irritation it wanders freely, returning to it fundamental nature. It is what is called Maximow's "resting wandering cell." Schwarz 1905 said that the milk-spots are consisted of the mononuclear wandering leucocytes. Weidenreich 1911 regarded that the omentum is one of lymphatic apparatus and therefore it is similar to the reticulum of the lymphatic node, and accordingly the tâches laiteuses are corresponded to the secondary nodules.
Although there had been many investigations on the main cell-element of the milk-spots, it has not been dissolved, until recently, based upon the studies of the vital staining of Goldmann, Kiyono, Pappenheim and Fukushi, a definite conclusion was reached. Kiyono emphasized that the milk-spots are consisted mostly of the so called "histiocytes" (by Kiyono), positive by vital staining, and partly of those cells as lymphocytes, plasmacytes, and a few polymorphonuclear leucocytes, eosinophilic leucocytes those that are negative by vital staining. He pointed out that without doubt a part of Ranvier's clasmatocytes and Renaut's cellules rhagiocrines, most of Marchand's adventitia-cells and all of Maximow's resting wandering cells belong to the histiocyte.
Notice: An article, entitled "the development of the milk-spots in great omentum" by the author is to be published later and in which on the cell-element of the milk-spots will be discussed more in detail.
III. Morphological observation on the mesothelial cell of the milk-spots.
In 1860, the silver impregnation was first discovered by v. Recklinghausen and three years later he published a famous article "On the Fat-absorption." For nearly six decades since that time, there had been many investigations upon the peritoneal mesothelium. The studies, however, as that of v. Recklinghausen, have been limited mostly to the peritoneal surface of the diaphragm, and attention has not been paid much to the mesothelial cells in the great omentum, in the mesentery, and particularly in the peritoneal surface of the milk-spots.
Ranvier and Schwarz said that the milk-spots are covered always with the continuation of a mesothelial cell-layer. In an article "On the stomata of serous cavities" Walter described, "Diese Gebilde (milchflecke) stehen mit dem Thema "Stomata" in kleiner direkten Beziehung."
In the extended specimen of the omentum treated with the solution of silver nitrate, it is found that the mesothelial layer is generally consisted of large flattened polygonal cells arranged each other in close apposition like a tiled pavement. The cement-line between the methotherial cells is generally finer, and its net-work is more irregular than that in the case of mesentery. The thickness of the cement-line is definite and either the so called "stomata" or "stigmata" cannot be found in a normal condition. The mesothelial cell on the surface of the milk-spots is quite smaller than that on the other places where there is no milk-spot existed. The former cell is nearly from one half to one fifth in diameter as small as the latter one. Such mesothelial cells on the milk-spot, especially those of the outer lamella are very irregular in shape and accordingly the cement-lines are indefinite and make an irregular net-work. It is noticeable that among these mesothelial cells there are seen many apertures, the small rounded intercellular spaces, and some peculiar cells that look like epithelioid cells.
The aperture is generally round in shape and its size ranges from three to ten microns in diameter. These apertures are stained relatively light brown in color but deeper than the protoplasm of the mesothelial cell and they are encircled distinctly with a line which stains similar to the cement-substance, but very small apertures represent as deep brown puncta. It is of much interest that some apertures have a marked refractive appearance and that some large ones possess in their subjacent area nuclei of cells which are rich in chromatin substance. These nuclei can scarcely be found in an extended specimen, but are shown clearly in the section embedded in
paraffin.
The epithelioid cells are limited to the surface of the milk-spots, some are scattered and some are grouped. These cells range from seven to twenty microns in diameter and are mostly round or oval in shape, rarely triangular or stellated. The nuclei are rich in chromatin substance and mostly in oval or kidney-shape, rarely in horseshoe-shape and are smaller than those of the mesothelial cells. The protoplasms are stained in light brown by silver nitrate and some refract light strongly. Sometimes giant cells with two nuclei are seen.
From the above view two questions will arise.
(1) Are the apertures on the surface of the milk-spots same with the so called "stomata" which are a subject under consideration among many authorities?
(2) What are the epithelioid cells that exist among the mesothelial cells of the milk-spots?
These questions will be discussed in the following investigations.
IV. Are the aperture of the milk-spots same with the so called "stomata"?
1. Literature.
It was considered by Galen, Hippokrates and etc. that the endings of lymph- and blood-vessels have freely opened apertures. In 1863 v. Recklinghausen further investigated on this subject from his study on the absorption of fat. Pouring some amount of milk on the peritoneal surface of the removed diaphragm of a rabbit, he microscopically observed that the fat-droplets were accumulating to several points and flowing into subjacent lymph vessels in whirls. When the milk was substituted with the solution of silver nitrate, the cement-substance gradually came in sight. He found the sites of the whirls covered with small mesothelial cells, and that there were round swellings on the cement-line, especially on their cross points. Some swellings were of circular in shape. He called these swellings "Öffnungs." "The enlarged "opening" was larger than the largest milk droplet." Since he announced the above opinion there appeared various investigations on the stomata of the serous membranes.
Considered from v. Recklinghausen's opinion, the stomata must be a freely opened aperture of communicating with a lymphatic vessel and of possessing an absorptive function. Later, however, the swellings of the cement-line have been generally called
"stomata" in wider sense, and its absorptive function has been disregarded.
Oedemansson, Dybkowsky, Lavdowsky, Klein and Burdon-Sanderson, Ranvier, Skworzow, Toldt, and Norris agreed with the v. Recklinghausen's theory, though there are a little differences in opinions. But Auerbach, Frey, Afonassiew, Walther, Tourneux, Foà, Arnold, Rajewsky, Bizzozero, Grasser, Fleiner, Kolossow, Muscatello, Sulzer, Ussow, Walter and Y. Tanaka denied the above view.
The data of the latter investigators will be described briefly. (1) The existence of the so called "stomata" is indefinite on the peritoneum and has no definite situation in the mesothelial cell-layer, and is sometimes detected in the cytoplasm (Afonassiew, etc.). (2) There is a marked difference in the size and in the number of the so called stomata in the specimens selected from nearly the same parts of the peritoneum of the animals in the same species and of nearly the same ages (Kolossow, Muscatello). (3) When the technique of the silver impregnation has been very carefully done, especially to avoid an over-stretching, no stomata can be seen in situ (Muscatello, Kolossow, etc.).
Based upon the above facts, the latter authorities agreed that the v. Recklinghausen's stomata are nothing but an artificial product and accordingly they are not normally existed. However some investigators occasionally found a few stomata even though the silver impregnation had been perfectly done. With regard to its occurrence, Muscatello illustrated that such stomata are made by the wandering cells which emigrate into the peritoneal cavity, penetrating the mesothelial cell-layer and thus temporarily making many minute openings in situ. Still Kolossow and Walter pointed out that with the respiratory movement of the animal, the mesothelial cell-layers, above all, those of the diaphragm and of the intercostal spaces expand and contract, and consequently the mesothelial cells, especially on the cross points of the cement-line disunited. They also deny the communication of the stomata with the subjacent lymph-vessel.
Comparison of the peritoneal surface of the milk-spots with that of the diaphragm:
It is not useless to compare the peritoneal surface of the milk-spots with that of the diaphragm, because the stomata of the serous membranes have been mainly investigated on the diaphragm.
The material were selected from the animals treated with the vital or supravital silver-impregnation. The special staining of the diaphragm was as follows:—The animal was sacrificed by bleeding. The table on which the animal was fastened was arranged so as to keep the diaphragm always in the horizontal position. After the abdominal organs were totally removed 0.1 per cent solution of silver nitrate poured on the surface of the diaphragm and left it in the dark. After ten to fifteen minutes the above solution was substituted with ten per cent
solution of formalin, thus fixing the diaphragm in situ. Thereafter, the diaphragm was totally removed and reduced in the similar method as previously described. The removed diaphragm was used partly for the celloidin section and partly for the extended specimen. The latter specimen was made transparent with the mixed solution of the equal parts of glycerin and acetic acid.
**Histological appearance:**
The surface of the diaphragm is covered with a mesothelium consisted of pavement cells closely attached each other. It is noticeable that the cells which occupy the spaces in the radiated tendon-fasciculi considerably decrease their size, but their shapes remain unchanged.
Ranvier discovered the deposition of many small rounded cells in the peritoneal surface of the diaphragm, particularly in the spaces in the radiated tendon-fasciculi and he named it "lymph-fountain." Later, the Ranvier's lymph-fountain was called "proliferating center" by Teurneux and Hermann. Bizzozero and Muscatello discovered some leucocytes among the mesothelial cells on the peritoneal surface of the diaphragm. According to Walter and others, there are a few apertures among the mesothelial cells which occupy the spaces in the radiated tendon fasciculi.
In my normal materials, no aperture, lymph-fountain nor proliferating center can be seen on the peritoneal surface of the diaphragm, but it is noticeable that a few epithelioid cells which resemble to those of the milk-spots are detected among the mesothlial cells, particularly in the spaces in the radiated tendon-fasciculi. Still, a few small rounded swellings are detected on the cross points of the cement-lines of the peritoneal layer in these spaces.
The further details of lymph-fountain and of the proliferating-centre will be written in a later paper.
2. Is the aperture of the milk-spots an artifact or not?
It has hitherto been viewed by many authorities that a certain artificial products of the cement-line due to the silver impregnation were frequently mistaken for the stomata. Such misconception is, however, easily avoidable by above-mentioned three methods of silver impregnation. The cement substance is less distinctly stained by supravital impregnation than by vital impregnation but by either method no abnormality can be seen in both the cement-line and the aperture. The cement-line impregnated after the omentum was excised is generally thicker than that treated by either vital or supravital impregnation. On this occasion, some small swellings colored in dark brown frequently appear on the cross-points of the cement-lines, but none appear on the vital impregnation, so that they are nothing but artificial product.
The so called stomata are not yet definitely concluded and its appearance as well as its location is very uncertain. But, the aperture what is meant by the author are localized definitely in the mesothelial cell-layer of the milk-spots. The apertures in the milk-spots are more numerous on the matured animal than on the younger one and the more the milk-spots become larger and the more their cells increase, the more the aperture usually increase. No typical aperture is detected in the newly born. The
so called stomata seem to select their locations mostly at the cross points of the cement-line, but the apertures in the milk-spots have not such definite choice.
In consideration with these facts, it is sure that the apertures in the milk-spots are not artifacts, but pre-existing figure.
3. Relation between the aperture and the basal-membrane of the omentum.
The basal-membrane, the Bizzozero's "membrane limitans" on which the mesothelial cells are situated has been described by Wodd, Bizzozero, Muscatello and others. According to Bizzozero, the "membrana limitans" is a very thin, homogeneous membrane, but only on the central tendon of diaphragm it has numerous openings which range in size from four to sixteen microns. No literature has hitherto been found as to the basal-membrane of the great omentum. This is because, the author believes, the basal-membrane, being existed in such a thin membrane as the omentum, has made one very hard to investigate on.
In my investigation of the membrane limitans the great omentum was placed in the tapped water for twenty hours and then the "silver chloride method" was applied. It was examined its extended specimen.
It was found microscopically that the mesothelial cell-layer had been removed from the peritoneal surface and a smooth basal-membrane underneath appeared. Such a basal membrane of the great omentum is homogeneous, but the membrane on the milk-spots has many round or oval-shaped spots which stain deep brown in color. These brown spots are five to fifteen microns in diameter. They have dark brown rings and are well-defined from the circumference.
There are no data to indicate that whether or not these brown spots are the openings of the basal membrane and connect with the apertures in the mesothelial cell-layer of the milk-spots. However there may be some connection between these brown spots and apertures, as both of them have almost similar behavior on staining with silver nitrate.
4. Relation between the aperture and the subjacent lymphvessel.
If the aperture in the milk-spots belong to the so called stomata as v. Recklinghausen maintained, they must be connected with the subjacent lymphvessel. To investigate this subject, either five per cent suspension of carmine in normal saline solution or the Indian ink was injected into the peritoneal cavity.
Case 1. On a female rabbit of 1380 gms. body-weight, one c.cm. of the carmine suspension was injected into the peritoneal cavity. One hour later the animal was killed by bleeding.
The removed omentum was partly used for the "silver chloride method," and partly for the serial section embedded in paraffin.
Case 2. On female rabbit of 1340 gms. body-weight, 1.5 c.cm. of the carmin suspension was injected into
the peritoneal cavity. Thirty minutes later, 320 c.c.m. of 0.1 per cent solution of silver nitrate was followed. Forty minutes later the second injection the animal was killed by bleeding.
Gross finding:—
The great omentum in both cases, especially the milk-spots stained very poorly in pink color, but the peritoneal layer of the diaphragm and others did not macroscopically stain.
Histological appearance:—
In the serial section (case 1), the fine carmine-masses invaded almost all of the epithelioid cells of the milk-spots. In both the extended specimens treated with silver nitrate, the epithelioid cells were differentiated distinctly with the cement-line and these cells mostly phagocytosed the carmine-masses. However, in the mesothelial cells and in the intercellular substance, no carmine-masses were found.
Case 3. On a female rabbit of 1420 gms. body-weight, ten c.c.m. of the carmine-suspension was administered into the peritoneal cavity. Thirty minutes later 330 c.c.m. of 0.1 per cent solution of silver nitrate was also injected. Forty minutes after the second administration the animal was killed by bleeding.
Case 4. On a male rabbit of 1355 gms. body-weight, ten c.c.m. of the carmin-esuspension was injected into the peritoneal cavity. One hour later the animal was killed by bleeding. The removed omentum was partly used for the "silver chloride method," and partly for the serial section embedded in paraffin.
Gross finding:—
The milk-spots were saturated with abundant carmine-masses and the rest of the omentum also stained deep in carmine-red.
Histological appearance:—
In the extended specimen, the epithelioid cells were so extremely filled with the fine carmine-masses that their nuclei could not be differentiated. Some apertures being filled with carmine-masses enlarged in various grades. The cement-substance in the milk-spots also were filled with the fine carmine-masses, and the mesothelial cells of the omentum did not escape from the invasion of carmine-masses. The cement-line of the omentum was very irregularly reduced and deformed; some of which were thickened, damaged or obscured.
In the vertical serial section, the mesothelial cell-layer showed a diffuse line of fine carmin-masses on its surface but not within its protoplasm. Although, this line slightly sank into the intercellular spaces, the spot did not in any respects look like opening in which free carmine-masses were contained. The macrophages situated just beneath the mesothelial cell-layer markedly phagocytosed and some of them wedged their cytoplasmic processes filled with carmine-masses into the intercellular spaces of the mesothelial cell-layer. Some macrophages connected tangentially with the intercellular
spaces, so that their protoplasms partly appeared on the peritoneal surface through the intercellular spaces. There were considerably many carmine-masses on the mesothelial cell-layer and in the intercellular substance, but freely existed carmine-masses could scarcely be found in the deeper area, consequently these masses seemed hardly to fined their ways through the lymph-vessels to the deeper area. The mesothelial surface of some milk-spots, particularly the outer lamellae of the omentum, were covered with a thick layer of the fine carmine-masses. In such figures, the difference between the epithelioid cells and the mesothelial cells was frequently quite hard.
Case 5. As a control. On a female rabbit of 1530 gms. body weight, five c.c.m. of the Indian ink was filtrated, sterilized and injected into the peritoneal cavity. One hour later the animal was killed by bleeding.
The removed omentum was partly used for the extended specimen and partly used for the serial section embedded in paraffin.
This case showed no particular appearance compared with those of above cases treated with carmine-suspension.
It is concluded from the above facts that the aperture in the milk-spots has no connection with lymph-vessels, but such an aperture is wedged by the process or by the cytoplasm of the subjacent macrophage.
Comparison with the peritoneal surface of the diaphragm:
Cases 1 and 2. Macroscopically the peritoneal surface of the diaphragm showed no carmine-red. In the extended specimen treated with the mixed solution of glycerin and acetic acid, the epithelioid cells with variable amount of minute carmine-masses were sometimes found on the peritoneal surface of the central-tendon. In the section, the free carmine-masses in the deeper area of the diaphragm were also scarcee.
Cases 3, 4 and 5. In the peritoneal surface of the central-tendon, many radiated lines colored carmine-red or black and corresponded to the spaces in the radiated tendon-fasciculi were seen. In the extended specimen, quite a large amount of carmine-masses or Indian ink-granulae were found in the spaces of the radiated tendon-fasciculi and continued to the subjacent lymphvessels which were in irregular net-work. In the section, the peritoneal surface of the central-tendon was regularly waved; the troughs of the waves just fit to the spaces in the radiated tendon-fasciculi. Such spaces were communicated with the lymphvessels situated under the mesothelial cell-layer of the pleural surface of diaphragm and usually contained many carmine-masses. On account of some of these spaces filled with the carmine-masses or Indian ink-granulae, the peritoneal layer consisted of mesothelial cells was very much obscured in places. In the large amount of free carmine-masses or the Indian ink-granulae, several macrophages were found, but the boundaries of which were generally very much obscured.
V. What are the epithelioid cells of the milk-spots?
1. General histological appearance.
The epithelioid cell and the mesothelial cell must be clearly differentiated as there
are differences between the two in the shapes and in the staining.
It is not very hard to find out the epithelioid cell in the specimen stained with hematoxylin-eosin. In this specimen, the protoplasm of the mesothelial cell does not stain with hematoxylin-eosin and so its boundary is very obscured. The nucleus of the latter is large and oval in shape, poor in chromatin substance and distinctly shows one or two nucleoli. On the contrary, the epithelioid cell has a distinct boundary and is mostly round or oval in shape. Its protoplasm, being amphophilic, stained with both hematoxylin and eosin, and therefore appears violet-red in color. Its nucleus is of oval or kidney-shaped, rich in chromatin-substance and smaller than that of the mesothelial cell. Thus, the epithelioid cell is apparently differentiated from the mesothelial cell. Still, the nucleus of the epithelioid cell is larger than that of the lymphocyte and has less chromatin.
In the vertical serial section, of the milk-spots, the epithelioid cell of mostly lens-shaped is slightly protruded from the mesothelial surface and shows characteristic staining. The cells are not always situated exactly in the mesothelial cell-layer, and their protoplasmic processes either appeared on the peritoneal surface or are partly exposed in the peritoneal cavity. There is a peculiar phenomenon in which the epithelioid cell caps on the mesothelial cell, and sometimes causes the surface of the latter slightly subside. A narrow pellucid zone is shown between the two. Such a cell sometimes is artificially displaced from its normal position and leaves depression on the peritoneal surface (see Fig. 7). The nucleus of the epithelioid cell is mostly situated basally and when the nucleus is of kidney-shaped its convex side usually faces to the periphery (see Fig. 9).
Notice: Ranvier discovered some lymphocytes among the mesothelial cells in the omentum of normal rabbit impregnated with silver nitrate. It may be suggested that his material is not quite normal, because he described, "....... Beim Kaninchen besonders sind sie (lymphzellen) zuweilen so zahlreich, dass die Peritonealflüssigkeit dadurch milchig getrübt wird." He still said, "Beinahe bei allen Kaninchen sind im grossen Netz isolierte Cysticerken vorhanden." In my material, however, such lymphocytes could not be detected.
2. Where does the epithelioid cell belong?
The epithelioid cell has a round or oval-shaped nucleus which is frequently depressed in one side and relatively rich in chromatin substance. Its protoplasm is ampho-or basophilic. From these facts the epithelioid cell must be a kind of histiocyte. To investigate this subject the vital staining was first applied.
Four per cent solution of lithium-carmine was injected by graded dosis once a day into the auricular vein, the average dosis being about four c.cm. per Kilo of body weight. The injection was continued six or seven times and 24 hours later from the last administration the animal was killed by bleeding. The tissue was preserved in
ten per cent solution of formalin in the dark for one or two days. It was then thoroughly washed in tap water and stained with hematoxylin.
Case 1. A female rabbit of 1725 gms. body-weight. The total amount of the carmine-solution injected was estimated 45.5 c.c.m. in seven days.
Case 2. A male rabbit of 1630 gms. body-weight. The total amount of the carmine-solution injected was estimated 41 c.c.m. in six days.
Case 3. A female rabbit of 1400 gms. body-weight. The total amount of the carmine-solution injected was estimated 40 c.c.m. in seven days.
Case 4. A female rabbit of 1250 gms. body-weight. The total amount of the carmine-solution injected was estimated 31 c.c.m. in six days and 24 hours after the last injection 350 c.c.m. of 0.1 per cent solution of silver nitrate was administered into the peritoneal cavity and one hour later killed by bleeding.
Case 5. A female rabbit of 1420 gms. body-weight. The total amount of the carmine-solution injected was estimated 40 c.c.m. in seven days and then it was similarly treated as above.
Case 6. A male rabbit of 2800 gms. body-weight. The total amount of the carmine-solution injected was estimated 60.5 c.c.m. in seven days. 30 minutes later the last injection the animal died and about 20 minutes later 500 c.c.m. of 0.1 per cent solution of silver nitrate was administered into the peritoneal cavity for the supravital impregnation.
Case 7. A female rabbit of 1860 gms. body-weight. The total amount of the carmine-solution injected was estimated 40 c.c.m. in six days and then similarly treated as case 4.
The results of the above experiments will be summarized as follows:
Cases 1, 2 and 3. In the extended specimen, some cells in the milk-spots strongly positive with the vital staining are irregularly shaped and their protoplasmic processes are extended in various directions. Each cell contains a flattened nucleus rich in chromatin substance. The protoplasm of these cells is hardly differentiated from the circumference but its boundary is scarcely recognized by an arrangement of the carmine-granulae. On the surface of the milk-spots, there are round or oval-shaped cells and their protoplasm is slightly basophilic, and consequently the boundary of the cells is well-defined. These round cells generally have less carmine granulae than the above cells and their nuclei are of oval or kidney-shaped rich in chromatin substance.
From these observations, it is ascertained that the two kinds of cells above-mentioned belong to the histiocyte by Kiyono. The one which is strongly positive with vital staining belongs to the histiocytic cell or so called clastmatocyte by Ranvier and the other which is weakly positive with the vital staining belongs to the histiocyte. The latter is quite the same with the epithelioid cell found by the author in the specimen treated with silver nitrate.
In the serial sections, almost all of the epithelioid cells are readily made out by their characteristic staining, shapes and situations. They are weakly positive with the
vital staining, but some of them which are partly protruded to the peritoneal cavity are infrequently negative. The histiocytic cells, however, are strongly positive with the vital staining and situated in the deeper layer of the milk-spots. These cells are especially, found more frequently in the peripheral than in the central area of the milk-spots. Some histiocytic cells just beneath the mesothelial cell-layer, make, sometimes, a row parallel to the latter, and some others situated diagonally to the latter extend their processes between the mesothelial cells.
Cases 4, 5, 6 and 7. In the extended specimen, the epithelioid cells contain some carmine-granulae in their protoplasm, but it is quite difficult to detect, because the protoplasm has been stained in brownish color by silver impregnation. The apertures in the mesothelial cell-layer infrequently show a few carmine-granulae.
Thus it is confirmed that the epithelioid cells are mostly positive with the vital staining but rarely negative. The negative one can not be distinguished from the histiocyte, because it is partly protruded to the peritoneal cavity and therefore is not sufficiently supplied with the carmine-solution introduced into the blood circulation. This will be illustrated by the following experiment.
Case 8. A female rabbit of 1390 gms. body-weight. Six c.cm. of two per cent solution of lithium-carmine was injected into the peritoneal cavity and 24 hours later it was killed by bleeding.
In the abdominal cavity, a small amount of viscous exudate was found. The great omentum was stained deep in red with carmine-solution and its lower parts were strongly adhered together.
Case 9. A male rabbit of 1300 gms. body-weight. Three c.cm. of the above solution was administered and then treated as above.
In the abdominal cavity a small amount of exudate was found. The omentum was stained in deep carmine-red. But on this occasion the adhesion of the lower parts of omentum was not so strong as that of case 8.
Case 10. A male rabbit of 1320 gms. body-weight. In this case the quantity of the carmine-solution was diminished to 2.5 c.cm.
The intra-abdominal appearance was almost similar to that of the above case, but the adhesion of the omentum was less marked than that of case 9.
Case 11. A female rabbit of 1540 gms. body-weight. Two c.cm. of the solution was used in this case. The great omentum tinged pink, but the adhesion existed very slightly.
Case 12. A male rabbit of 1250 gms. body-weight. 1.5 c.cm. of the solution was used in this case. Only the milk-spots in the omentum appeared in pink color, the rest being very poorly stained.
Case 13. A female rabbit of 1580 gms. body-weight. Dosis ditto.
The intra-abdominal appearance was similar to that of the above case.
Case 14. A female rabbit of 1400 gms. body-weight. Dosis ditto.
24 hours later, the vital impregnation with 350 c.cm. of 0.1 per cent silver nitrate solution was done.
Case 15. A female rabbit of 1460 gms. body-weight. It was quite similarly treated as above.
It is well known that the carmine-solution considerably irritates the peritoneal tissue therefore the cases 1 and 2 were not proper on this subject, as they were administered too much carmine. But the others, especially cases 12 to 15 treated with quite a small amount of the solution were not so much influenced by the carmine-irritation.
In the specimen treated with the silver nitrate, the epithelioid cells on the milk-spots showed many carmine-granulae and they were well-defined from the mesothelial cells by the cement-line.
The apertures in the mesothelial cell-layer of the milk-spots tended to be enlarged and generally showed carmine-granulae to some extent. Some apertures especially the enlarged ones accompanied the nuclei rich in chromatin substance. The cement-lines in this cases especially those which were strongly irritated by the carmine-solution were irregularly thickened, obscured or disappeared.
In the vertical serial sections, the epithelioid cells were markedly filled with the carmine-granulae, generally enlarged spherically and nearly detaching from the mesothelial cell-layer in large number. On this occasion, the most of the histiocytic cells in the milk-spots were superficially situated and some of those which existed just beneath the mesothelial cell-layer protruded their protoplasmic processes partly through the intercellular spaces.
In consideration with the results of the above two experiments, it may be concluded that the epithelioid cell belongs to the histiocyte. The experiment of Chapter IV, 4 in which the epithelioid cell shows a remarkable phagocytotic ability endoses this opinion.
Comparison with the peritoneal surface of the diaphragm:
Cases in which the carmine-solution was intravenously injected:—In the extended specimen treated with the mixed solution of glycerin and acetic acid, the epithelioid cells on the peritoneal surface usually possessed a few carmine-granulae in the protoplasm.
Cases in which the carmine-solution was administered into the peritoneal cavity:—
Cases 8 and 9. In the extended specimen, the spaces in the radiated tendon-fasciculi were filled with the histiocytic wandering cells with many carmine-granulae.
Cases 12 to 15. In the extended specimen, the epithelioid cells were numerous and had many carmine-granulae in their protoplasm.
VI. The relation between the aperture and epithelioid cell on the milk-spots.
There are normally many cell-elements in the peritoneal cavity and they mostly belong to the histiocyte. It is generally acknowledged that the most of these histiocytes are derived from the milk-spots. The histiocytic cells in the milk-spots becoming round, shortening their protoplasmic processes, always wander into the peritoneal cavity and this action is caused by the physiologic stimulation.
From this fact it may be considered that there is a certain connection between the aperture and the epithelioid cell—the histiocyte which is derived from the milk-spots.
Muscatello described that in the specimen of great omentum and gastrohepatic ligamentum impregnated with silver nitrate, there can be seen many lymph-follicles (the milk-spots) covered on both sides with mesothelial cells and that the mesothelial cells but on one side do not connect each other. From this fact he viewed that the lymph-follicles in the great omentum and gastro-hepatic ligamentum will probably supply the leucocytes to the peritoneal cavity like those of the intestinal wall supplying the leucocytes to the intestinal canal. Although, this Muscatello's view quite agrees with mine, it is regrettable that he has not mentioned as to the intercellular spaces existed in the mesothelial cell-layer.
Chapter III, IV and V are summarized as follows:
1. Some of the apertures and the epithelioid cells on the milk-spots similarly have a remarkable refractive appearance and consequently these two may be standing in a certain relation. The wandering cell, as Arnold already discovered, usually refract ray of light especially when it penetrating a small space in the epithelial cell-layer more distinctly than it is at rest.
2. In the cases of Chapter IV, 4 and those of Chapter V, 2, some of the apertures also show minute carmine-masses and carmine-granulae respectively and in the vertical sections of the milk-spots these apertures are wedged by the protoplasmic processes of the subjacent histiocytic cells with carmine-masses or carmine-granulae. These histiocytic cells and the epithelioid cells (the wandering histiocytes) may have a certain relation.
3. Some of the large apertures normally have in their subjacent parts the nuclei rich in chromatin substance. This is a transitional form of the aperture—the intercellular spaces in the mesothelial cell-layer wedged by the protoplasmic process of histiochyte—, to the epithelioid cells—the histiocyte existed among the mesothelial cells—, on the surface of the milk-spots.
From three facts, the relation between the aperture and the epithelioid cell has thrown some light and will become clearer by the following experiment:
The carmine-vital staining was done along with irritations in various ways into the peritoneal cavity.
Case 1. A male rabbit of 1500 gms. body-weight. 1st day, 50 c.c.m. of 4 per cent solution of lithium-carmine (intravenously) + 0.5 c.c.m. of the sterilized olive-oil (intraperitoneally). 2nd day, 6 c.c.m. of the carmine-solution (intravenously). 3rd day, 6 c.c.m. of the carmine-solution (intravenously) + 0.5 c.c.m. of the olive-oil (intraperitoneally). 4th day, 6.5 c.c.m. of the carmine-solution (intravenously). 5th day, 7 c.c.m. of the carmine-solution (intravenously) + 0.5 c.c.m. of the olive-oil (intraperitoneally). 6th day, 7 c.c.m. of the carmine-solution (intravenously). 7th day, ditto. The total amount of the carmine-solution and olive-oil was estimated 44.5 c.c.m. and 1.5 c.c.m. respectively.
24 hours after the last injection 350 c.c.m. of 0.1 per cent solution of silver nitrate was injected into the peritoneal cavity and one hour later the animal killed by bleeding.
Case 2. A female rabbit of 2160 gms. body-weight. 1st day, 6 c.c.m. of the carmine-solution (intravenously) + 0.5 c.c.m. of the olive-oil (intraperitoneally). 2nd day, 7 c.c.m. of the carmine-solution (intravenously). 3rd day, 7 c.c.m. of the carmine-solution (intravenously) + 0.5 c.c.m. of the olive-oil (intraperitoneally). 4th day, 8 c.c.m. of the carmine-solution (intravenously). 5th day, 8 c.c.m. of the carmine-solution (intravenously) + 0.5 c.c.m. of the olive-oil (intraperitoneally). 6th day, 8.5 c.c.m. of the carmine-solution (intravenously). 7th day, ditto. The total amount of the carmine-solution and the olive-oil was estimated 53 c.c.m. and 1.5 c.c.m. respectively.
24 hours after the last injection the animal was killed by bleeding.
In the abdominal cavity many minute oil-droplets could be found and the omentum was slightly opaque.
Case 3. A female rabbit of 1530 gms. body-weight. The carmine-solution was intravenously injected once a day and its total amount was estimated 48.5 in seven days. The last injection was followed by 10 c.c.m. of the sterilized normal saline-solution into the peritoneal cavity. 24 hours after the last administration the animal was killed by bleeding.
Case 4. A female rabbit of 1730 gms. body-weight. The carmine solution intravenously injected was estimated 50 c.c.m. in seven days. On the 8th day, 10 c.c.m. of the normal saline solution was intraperitoneally injected, and two hours later the last administration the animal was killed by bleeding.
The removed omentum was used partly for the "silver chloride method" and partly for hematoxylin-eosin-staining.
Case 5. A female rabbit of 1650 gms. body-weight. The carmine-solution intravenously injected was estimated 48.5 c.c.m. in seven days and the last injection was followed by 10 c.c.m. of the normal saline solution in into the peritoneal cavity. On the 8th day 350 c.c.m. of 1 per cent solution of silver nitrate was injected intraperitoneally, and 40 minutes later it was killed by bleeding.
Histological appearance:
Case 1. In the extended specimen impregnated with silver nitrate, both the epithelioid cells and apertures considerably increased in number and were generally enlarged. Both of them had some carmine-granulae which were generally indistinct by the influence of the solution of silver nitrate. Some of the most enlarged apertures had, in their subjacent area, the nuclei rich in chromatin substance. The cement-line of the milk-spot was variously damaged, in parts either obscured or disappeared. A few polymorphonuclear leucocytes existed in the intercellular spaces in the mesothelial cell-layer.
Case 2. In the serial sections, the milk-spots were generally swollen edematously and the blood- and lymph-vessels were dilated. The epithelioid cells, the histiocytic wandering cells on the milk-spots especially the enlarged ones which have two nuclei tended to increase in number. Some of these epithelioid cells, particularly, enlarged ones were situated just on the surface of the milk-spots, and some in the deeper area showed their protoplasm partly on the peritoneal surface. Some of the epithelioid cells had a few and others had many carmine-granulae in their protoplasm. Histiocytic cells in the deeper area of the milk-spots which were very irregularly shaped and possessed many carmine-granulae in the normal condition, had almost disappeared and they were substituted with the histiocytic wandering cells which were resembled to the epithelioid.
In this case, there appeared many giant cells consisted of from four to seventeen nuclei. Such giant cells were of from twenty to thirty microns in diameter and clearly distinguished from the circumference and negative with the vital staining. The nuclei of the giant cells were of about seven microns in diameter and rich in chromatin-substance more than that of the histiocyte. These giant cells like those of the epithelioid cells were situated partly on the milk-spots and partly in deeper area. There were some polymorphonuclear leucocytes in the milk-spots and some of them existed in the intercellular spaces of the mesothelial cell-layer.
Case 3. In the serial sections, the epithelioid cells as well as the polymorphonuclear leucocytes in the milk-spots were more abundantly existed than those of case 2. The other findings were similar to those of case 2, with an exception of the giant cells which could not be seen in this case.
The appearances of cases 1, 2 and 3 were similar to those of the cases in which the carmine-solution was administered into the peritoneal cavity (compare Chapter V, 2), but with an exception that the carmine-granulae in the former epithelioid cells were less than those of the latter ones.
Cases 4 and 5. In the extended specimen treated with the "silver nitrate, both the epithelioid cells and apertures increased in number and contained carmine-granulae in a varied degree. In the serial sections, the general epithelioid cells as well as some epithelioid cells partly protruded from the mesothelial surface which are both naturally weak-positive with carmine vital staining, exceptionally showed quite a many carmine-granulae in their protoplasm. Many histiocytes derived from the histiocytic cells in the deeper area of the milk-spots were situated just beneath the mesothelial cell-layer and send their protoplasm into the intercellular spaces of the layer. Some of these wandering cells were swollen spherically and most of them were tangentially
adhered to enlarged intercellular spaces of the mesothelial cell-layer. It is very interesting to observe a flattened histiocytic cell situated exactly between the mesothelial cells, though not frequent, and also looks like the epithelioid. This cell was obviously differentiated from a normal epithelioid cell by its shape and staining characteristic: the protoplasm of the former showed more carmine-granulae than the latter's. The former not being basophilic, contrarily to the latter, the arrangement of the carmine-granulae was the only guidance to find out the cell-boundary. In other words, the appearance of this new epithelioid cell was quite resembled to that of the histiocytic cell in the milk-spots. Still, the nucleus of the new epithelioid cell mostly occupied the periphery of the protoplasm and was depressed, always facing its depressed side to the center of the cell, contrarily to the normal epithelioid cell (compare Chapter V, 1). By the above morphological differences, two kinds of the epithelioid cells could be well differentiated and consequently they probably have a different function of which the following chapter will illustrate.
In summarizing above experiments, it was concluded that both the aperture and epithelioid cell in the milk-spots are represented by the wandering histiocytes which are passing through the mesothelial cell-layer, viz:
(1) The aperture. The each histiocyte which is going to begin or finish its penetrating through the mesothelial cell-layer shows its protoplasmic process only in the mesothelial intercellular space and its nucleus is seen in the deeper area of the milk-spots, so that in the extended specimen treated with silver nitrate, the nucleus can not be found in this intercellular space. This figure is the aperture by the author and it is a small round intercellular space in the mesothelial cell-layer. (2) The epithelioid cell. In some period, the histiocytic cell is totally wedged into the intercellular space and consequently its nucleus exist in situ. This is represented as a round cell encircled by the cement-line on the milk-spots, namely, this is the epithelioid cell by the author. (3) The transitional between the above two figures. When the peritoneum is experimentally irritated, a transitional form between the above two figures distinctly appeared, namely, the irritated histiocyte of spherically shaped is nearly tangentially connected with the space exists in the mesothelial cell-layer, this is an enlarged aperture where a nucleus can easily be found in its subjacent area.
Comparison with the peritoneal surface of the diaphragm:
Cases 1 and 2. In the extended specimen treated with silver nitrate and next with the mixed solution of glycerin and acetic acid, many mesothelial cells on the peritoneal surface of the central tendon, especially on the spaces which occupy in the radiated tendon-fasciculi, were exfoliated. Still, on this spaces many small rounded cells were accumulated in several spots and some of these cells possessed many carmine-granulae. The cementline was irregularly thickened, and many round spots of dark brownish color appeared on the cross points of the lines.
Cases 4 and 5. In the extended specimen, several brown spots were situated on the cross points of the cement-lines. Almost all of the mesothelial cells coalesced closely.
Summary of the comparison with the peritoneal surface of the diaphragm:—
Normally, a few epithelioid cells occupy the intercellular spaces of the mesothelial cell-layer which covers the spaces in the radiated tendon-fasciculi of the diaphragm and it may be considered that these epithelioid cells also belong to the histiocyte. What reported by Muscatello as the leucocytes among the mesothelial cells of the peritoneal surface of the central tendon on a normal rabbit are also to be considered nothing but the epithelioid cells (by the author).
Such epithelioid cells generally and also the small brown spots (the so called stigmata by Arnold) on the cross points of the cement-lines to some extend increase in number by a certain irritation produced in the peritoneal cavity.
Appendix:—
The milk-spots in mesentery.
It is not so infrequently to observe small milk-spots in mesentery of rabbit, as already described by Ranvier and Walter. The investigation of this milk-spots in mesentery has been hitherto overlooked, but much attention should be paid to as they play an important rôle similarly to those of the great omentum. Since March 1922, I have collected 100 cases out of which obtained 20 positive cases of the milk-spots. These milk-spots are oval or round in shape and they range in size from 0.05 to 0.2 m.m. in diameter.
In the extended specimen impregnated with silver nitrate, the milk-spots are swelled on either surface of mesentery and its peritoneal cover of each swelling is consisted of small irregularly shaped masothelial cells while the opposite side is consisted of ordinary mesothelial cells. The cement-lines on these milk-spots are generally thicker than those on the other area and form an irregular net-work, as those of the milk-spots of the omentum. Still, the cement-lines possess several round spots stained dark brown in color. But those large ones encircled with cement-lines that could be seen in the omentum are not present. A few epithelioid cells are sometimes situated in the mesothelial cell-layer on the milk-spots. The existence of the milk-spots of the mesentery is uncertain, and I could not unfortunately find the milk-spots in the specimen with the carmine-vital staining. And therefore I am not sure whether or not the epithelioid cell is positive with the carmine-vital staining. However, it may be suggested that the epithelioid cells of the mesentery also belong to the histiocyte, as their shape and appearance are quite similar to those of the epithelioid cells on the milk-spots of the omentum.
(To be continued)
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THE INAUGURAL ISSUE
.01
February 2011
IN THIS ISSUE
Corporate Diversity Department Year-in-Review Summary page 3
Multicultural Calendar 1st Quarter, 2011 page 5
Diversity Spotlights: Diversity Success Stories, Milestones, and Best Practices from around the organization page 6
Call to Submit Diversity Success Stories page 9
Diversity Tool Box: Building A Shared Language page 10
Diversity @ ARC in Historical Context page 11
At the American Red Cross, diversity is more than an aspirational goal. We are one of the most respected humanitarian organizations in the country because we empower Americans to perform extraordinary acts in the face of emergencies and disasters. We consistently respond and provide service to everyone in need because diversity is part of our organization’s DNA. For us, diversity is not a standalone concept—it cuts across many issues, large and small, that our employees and volunteers face every day in fulfilling the mission of this great organization. Everyone within this organization can play a part in making the Red Cross a more diverse and inclusive place to work and provide the lifesaving services expected from us by our neighbors and fellow citizens. Our executive leadership is committed to creating and maintaining an inclusive environment where everyone feels welcomed, comfortable and encouraged to give his or her best to each other and all we serve. Our goal is to ensure that everyone in this organization, and all we serve, feel valued and respected through how we work together every day and provide services.
During calendar year 2010, the Corporate Diversity Department continued laying a foundation to support effective and sustainable programs for advancing principles of diversity and inclusion within our organization. We issued revised Diversity Vision and Mission Statements as guiding documents for the organization, and early last year, our CEO Gail McGovern approved and issued a Strategic Plan for Advancing Diversity and Inclusion throughout the American Red Cross. At year-end, we were engaged in building consensus with leadership of our business lines and support functions on implementation of various initiatives for achieving the organization’s strategic goals for diversity.
Last year was the first full year of functioning for our newly established National Diversity Advisory Council (NDAC). This external group of diversity thought-leaders, appointed by our Board of Governors, operate to advise our Board, CEO and Corporate Diversity on relevant strategic issues pertaining to diversity and inclusion, and serve as a forum for sharing diversity best practices. The NDAC is chaired by Attorney Keith Harper, Partner at Kilpatrick Stockton, LLP and member of the Cherokee Nation of Oklahoma; he also served as an advisor to President-Elect Obama’s Transition Team on American Indian affairs.
(See the next page for links to Diversity Vision and Mission Statements, the Strategic Plan for Advancing Diversity and Inclusion throughout the American Red Cross and the complete National Diversity Advisory Council Roster.)
As we all know, our ability to engage in effective partnerships with other organizations helps us better serve our clients. Last year, the American Red Cross became a member of the National Hispanic Corporate Council as a means to improve our outreach to the Latino community. We were pleased that Anna Lopez
(continued...)
Buck, Executive Director – Corporate Diversity, was elected to the Council Board for a two-year term which commenced last month. On our Supplier Diversity Program efforts, we’ve continued our Corporate Membership with the National Minority Supplier Development Council and this past summer our Chief Procurement Officer, Jill Bossi, was elected to that Council’s Board of Directors. Our work last year with the World Institute on Disability resulted in an innovative pilot training program to help Red Cross employees and volunteers better serve people with disabilities in disaster response. This pilot training program was funded through a grant from the Verizon Foundation, and delivered to ten Red Cross chapters around the country. Additionally, Corporate Diversity was pleased to join with other Red Cross departments to support Spanish-language Univision Network’s 5 hour telethon, “Unidos Por Haiti,” from which over $7 million was raised for relief and recovery efforts in Haiti.
These are just a few of the efforts the Corporate Diversity Department was engaged in during 2010—we look forward, eagerly, to our continued work together in advancing diversity and inclusion throughout the American Red Cross.
Floyd W. Pitts
Chief Diversity Officer
CLICK HERE FOR:
Diversity Vision and Mission Statements
Strategic Plan for Advancing Diversity and Inclusion Statements
National Diversity Advisory Council Roster
MULTICULTURAL CALENDAR First Quarter 2011
Black History Month
February
National Freedom Day
February 1
Chinese New Year
February 3
Mawlid al-Nabi
February 15
Nirvana Day
February 15
(also observed February 8)
World Day of Social Justice
February 20
Women’s History Month
March
Baha’i Nineteen Day Fast Begins
March 2
International Women’s Day
March 8
Ash Wednesday
March 9
St. Patrick’s Day
March 17
Holi
March 20
Purim Begins
March 20
Naw-Ruz
March 21
Prince Kuhio Day
March 26
Cesar Chavez Day
March 31
This year, with the guidance of senior leadership, Corporate Diversity and Disaster – Partner Services launched a cross-functional team to coordinate and manage development of diverse partnerships. The goals of this team are to develop an enterprise-wide diverse partnership strategy, review and leverage diverse partnership approaches from the field and other business lines and develop action steps and sustainable processes to achieve seamless development of diverse partnerships with interests of all internal stakeholders considered. This “One Red Cross” approach to diverse partnership development is intended to maximize value exchange between diverse partners and all Red Cross lines of service which can benefit from, and provide value to, our diverse partners.
Current members of this cross-functional team include: Juliet K. Choi, Senior Director – Disaster Partner Services; Trevor Riggen, Senior Director – Disaster Operations; Lynn Crabb, Director, Mass Care – Disaster; Brooke McCauley, Senior Associate – Disaster Partner Services; Mary Dewitt, Senior Associate – Disaster Partner Services; Anna Lopez, Executive Director – Corporate Diversity; Curtis Parker, Diversity Programs Manager; and Mozetta Jackson, Senior Associate – Diversity Programs. Members from other departments will be added to ensure this team represents all potential areas of collaboration with various diverse partners.
For more information contact Juliet K. Choi, Senior Director – Disaster Partner Services, or Curtis Parker, Diversity Programs Manager.
State Disaster Planning
Native American Initiatives
Last year, The Native American Task Force of the American Red Cross was formed. Jim Hamilton, Chapter Operations Vice President - Division 1, was the initial lead for this work group, but recently handed leadership of the group to Eric Jones – Disaster Officer for Arizona, Colorado, New Mexico and Wyoming. Task Force members represent various chapters throughout Divisions 1 and 2, and include several representatives from national headquarters departments. The group’s primary goal is to improve Red Cross capacity to partner with Tribal Leadership before, during and after disasters, with the intended result of having more openly flowing lines of communication between Red Cross chapters and Native American communities in the West.
The Task Force recently received training on how to develop partnerships with Tribal Nations, provided by John Zingg, Task Force member and volunteer with the Inland Northwest Chapter in Spokane, Washington. The training provides an analysis on how to develop a mutually trusting and honest relationship with tribal nations, with suggestions on how to select appropriate Tribal Liaisons and what those liaisons’ roles and responsibilities should be. Next on the Task Force’s list of objectives is to establish goals based on a “Strengths–Weaknesses-Opportunities-Threat” (SWOT) analysis of the current state of Native American relations associated with Red Cross disaster services.
For more information, contact Eric Jones.
Bay Area (San Francisco) Chapter
ARCBA Annually Supports Bi-National Heath Week
Exemplifying the American Red Cross commitment to effectively serve minority communities, the American Red Cross Bay Area has participated in Bi-national Health Week for three consecutive years. Bi-national Health Week is an annual event sponsored by UC Berkeley School of Public Health to bring together organizations located throughout San Francisco, including universities, community health and civic organizations, relevant government agencies and foreign consular offices of Canada, Mexico, Central America and South America. The week focuses on migrant and immigrant health challenges and explores opportunities to work collaboratively to improve the health and well-being of these groups. Through the collaborative efforts of community organizations, state and federal agencies and a multitude of volunteers, Bi-national Health Week has become one of the largest mobilization efforts dedicated to improving the health, emergency preparedness and welfare of the underserved Latino population living in the United States and Canada.
Last year, over 900 agencies participated in the conference and ARCBA was able to share information about the humanitarian mission of the American Red Cross in coordination with other Latin-American Red Cross societies. Juan Manuel Olivas Ramirez, Governor of Guanajuato Mexico was the host of last year’s event. At that meeting, Alejandro Castillo, Manager, Latino Community Preparedness – ARCBA Chapter, had the opportunity to confer with Gov. Ramirez and inform him about ARCBA’s services supporting the Mexican immigrant community, as well as other diverse communities in their service areas.
For more information, contact Alejandro Castillo.
NHQ: Disaster – Partner Services
National Baptist Convention Launch “Gift of Life” Campaign
Last fall, the American Red Cross and the National Baptist Convention USA, Inc., celebrated their one-year anniversary of a national partnership with the goal of uplifting communities by focusing on the importance of healthy lifestyles, volunteer service and disaster readiness. A new and exciting element of this partnership kicked off with the launch of the “Gift of Life” blood campaign. Through this campaign, the two organizations will strive to educate African-Americans about the importance of blood donations from their community.
To mark the beginning of this effort, campaign Honorary Chair Josephine Scruggs, the wife of Dr. Julius R. Scruggs, President of the National Baptist Convention, and the American Red Cross hosted a blood drive kick-off last fall during the 130th Annual Session of the National Baptist Convention, held at the Kansas City Convention Center. A report from Biomedical indicated that over 50 units of blood were collected at this event.
For more information about the American Red Cross/National Baptist Convention partnership, contact Juliet K. Choi, Senior Director, Disaster – Partner Services. For information on Blood Services Minority Community Outreach Programs, contact Vincent Edwards, Executive Director, Metropolitan Blood Services.
The faithful congregation at West Angeles Church of God in Christ, in Los Angeles, California, is doing its part to support the community’s blood supply and is asking others to join in the struggle to save lives. Since November 2009 the church has held yearly blood drives with the American Red Cross as part of the Faith Community Blood Drive Initiative founded by Bishop Charles Blake and church member Earl Jordan.
Bishop Blake and Earl Jordan, who handles Operations and Strategic Marketing for the church, were interested in a way to increase their efforts of bringing together faith-based groups and places of worship from across the Los Angeles area to save lives and raise awareness about the importance of blood donations. With guidance from Curtis Parker, Manager – Diversity Programs for the American Red Cross, and support from the Red Cross Southern California Blood Services Region, West Angeles Church of God in Christ founded the Mega Church Blood Drive Initiative for any and all faith-based groups with an active following of 2,500 members or more. The initiative focuses on educating religious leaders about the ongoing need for blood donations and encourages them to coordinate frequent, successful blood drives for their congregations.
With their continued work with the Red Cross Southern California Blood Services Region, West Angeles Church of God in Christ, in their last few blood drives, has collected enough blood to potentially touch the lives of nearly 400 patients. With this church serving as the example for others, organizers acknowledge that while progress is slow, support for the Mega Church Blood Drive Initiative steadily continues. New supporters like Faithful Central, another megachurch in the Los Angeles area, have recently embraced this lifesaving effort and hope to hold a successful blood drive in the coming weeks.
For more information, contact Nicholas Samaniego, Public Affairs Manager, American Red Cross Southern California Blood Services Region.
**Houston Area Chapter**
**Faith Community Outreach Partnership**
The Greater Houston Area Chapter, under the leadership of chapter CEO Steve Vetrano, launched a Faith Community Outreach Partnership Initiative with the purpose of partnering with and supporting local faith groups in preparing congregations and communities-at-large to better respond to emergencies and disaster events. Planning for the initiative was conducted in a series of two meetings which included representatives from twenty local faith groups, Houston chapter staff and representatives from Red Cross national headquarters. Others in attendance included: Bishop Shelton Bady, a member of the American Red Cross National Diversity Advisory Council; Congresswoman Shelia Jackson Lee (D-TX); and a representative from the office of Congressman Al Green (D-TX).
This initiative was launched more than a year ago and has resulted in enhanced partnership efforts between the chapter and the Houston faith community in the areas of volunteer service and leadership, identifying joint training opportunities and development of partner agreements to increase community preparedness and readiness.
For further information about the Houston Faith Community Outreach Partnership Initiative contact Delores Hadnott, American Red Cross – Branch Director.
Affinity Groups – in some organizations these groups are also referred to as “employee networks” or “employee resource groups”—all are groups of staff members who share common characteristics or interests and join together to have a voice for contributing value to the organization for which they work. For example, such groups can support organizational and business objectives by serving as a bridge between an organization and the affinity group. Affinity groups or employee resource groups are supported by many companies and organizations that are recognized for their strong commitment to diversity and inclusion.
Cultural Competency – having the capacity to function effectively in settings where those you’re interacting with have different cultures, customs, language or norms than you. Achieving this capacity relies upon having: basic cultural knowledge and understanding of diverse groups; an appreciation for cultural differences; ability to lessen one’s own sense of dominance toward others; and the skill to demonstrate appropriate behavior when interacting with people from different cultures.
Diversity – at the American Red Cross, diversity is defined in its broadest sense to encompass all the characteristics, experiences and cultural influences that make each of us unique individuals. These differences can be categorized into several different dimensions: Internal – those we’re born with like gender and ethnicity; External – those which change over time like age; and Situational – characteristics that change based upon life choices, such as marital status and vocation.
Diversity Initiative – a diversity vision, direction or action plan of an organization which establishes a foundation from which sustainable diversity programs evolve.
Inclusion – process of embracing, valuing, respecting, recognizing and, ultimately, leveraging the differences we possess so that everyone in the organization has opportunity to contribute and fully participate in creating goal-oriented success. Inclusion is built upon each individual being valued and respected for his or her distinctive skills and experiences which moves us beyond “tolerance” to actually embracing and celebrating the rich dimensions of diversity contained within each of us.
Supplier Diversity – a proactive business process that seeks to provide qualified diverse suppliers with access to purchasing and business opportunities offered by a business or organization. Effective Supplier Diversity Programs provide an opportunity for a business or organization to better reflect their entire customer base or all they serve.
Workforce Diversity – a concept which goes beyond the focus of Affirmative Action and Equal Employment Opportunity programs to encompass all the ways that members of work teams differ including race, gender, age, ethnicity and other demographic categories (such as religion, education and sexual orientation, etc.). Workforce Diversity extends to differences in values, abilities, organizational function, tenure and personality. Primary objectives of workforce diversity efforts include attempting to create and sustain a workforce that reflects demographics of customers, clients and population at large, and to develop the potential of each and every person within the organization.
CALL TO SUBMIT YOUR DIVERSITY SUCCESS STORIES
Going forward, this DiversityToday eNewsletter will be issued on a quarterly basis. A primary purpose of future issues will be to highlight, and share with others throughout our organization, diversity success stories occurring at chapters, stations and blood regions. As noted earlier in this inaugural issue, “everyone within this organization can play a part in making the American Red Cross a more diverse and inclusive place to work and provide the lifesaving services expected from us by our neighbors and fellow citizens.” If your response to that is “been there, done that,” then we ask you to share with others what you’ve achieved by submitting your diversity success story to DiversityToday.
If you’ve succeeded in building an effective relationship with a local diverse partner, we’d like to hear about it. If you’ve developed a noteworthy approach for recruitment of diverse employees and/or volunteers, let us know. If you’ve achieved exceptional diversity on your local board, tell us how that was done. And we certainly want to hear about outstanding outreach efforts to diverse communities you serve.
Now, don’t be shy—help us tell your great stories! Submit your diversity success stories, via email, to Mozetta Jackson, Senior Associate – Corporate Diversity. Your story should be no longer than half-a-page in length, and we ask your understanding if we need to edit your submission. Digital photos related to your story are encouraged. The next issue of DiversityToday is planned for delivery around April 15; so, all submissions must be received by close of business Tuesday, March 15.
Founder of the American Red Cross, Clara Barton was famous for breaking down barriers all through her life. As a young woman she became a teacher at a time when males dominated the field. She was among the first women to gain employment in the federal government by becoming a copyist in the United States Patent Office. During the Civil War she became nationally known as the "Angel of the Battlefield" when she risked her life to bring supplies and support to soldiers in the field. After a trip to Europe where she first learned about the International Red Cross Movement, she returned home and began a successful campaign for U.S. ratification of the Geneva Convention of 1864 (calling for the protection of the war-injured). In 1881, at the age of 60, she created the American Association of the Red Cross (as today's American Red Cross was first known) and led the organization for 23 years. During the time she was in charge the American Red Cross conducted its first domestic and overseas disaster relief efforts, aided the United States military during the 1898 Spanish-American War and campaigned successfully for the inclusion of peacetime relief work as part of the International Red Cross Movement (the so-called American Amendment that some Europeans initially resisted).
"I have an almost complete disregard of precedent, and a faith in the possibility of something better. It irritates me to be told how things have always been done. I defy the tyranny of precedent. I go for anything new that might improve the past."
-- Clara Barton
|
Design Standards No. 6
Hydraulic and Mechanical Equipment
Chapter 12: Trashracks and Trashrack Cleaning Devices
Phase 4 (Final)
Mission Statements
The U.S. Department of the Interior protects America’s natural resources and heritage, honors our cultures and tribal communities, and supplies the energy to power our future.
The mission of the Bureau of Reclamation is to manage, develop, and protect water and related resources in an environmentally and economically sound manner in the interest of the American public.
Design Standards Signature Sheet
Design Standards No. 6
Hydraulic and Mechanical Equipment
DS-6(12): Phase 4 (Final)
December 2016
Chapter 12: Trashracks and Trashrack Cleaning Devices
Foreword
Purpose
The Bureau of Reclamation (Reclamation) design standards present technical requirements and processes to enable design professionals to prepare design documents and reports necessary to manage, develop, and protect water and related resources in an environmentally and economically sound manner in the interest of the American public. Compliance with these design standards assists in the development and improvement of Reclamation facilities in a way that protects the public's health, safety, and welfare; recognizes needs of all stakeholders; and achieves lasting value and functionality necessary for Reclamation facilities. Responsible designers accomplish this goal through compliance with these design standards and all other applicable technical codes, as well as incorporation of the stakeholders’ vision and values, that are then reflected in the constructed facilities.
Application of Design Standards
Reclamation design activities, whether performed by Reclamation or by a non-Reclamation entity, must be performed in accordance with established Reclamation design criteria and standards, and approved national design standards, if applicable. Exceptions to this requirement shall be in accordance with provisions of *Reclamation Manual Policy*, Performing Design and Construction Activities, FAC P03.
In addition to these design standards, designers shall integrate sound engineering judgment, applicable national codes and design standards, site-specific technical considerations, and project-specific considerations to ensure suitable designs are produced that protect the public’s investment and safety. Designers shall use the most current edition of national codes and design standards consistent with Reclamation design standards. Reclamation design standards may include exceptions to requirements of national codes and design standards.
Proposed Revisions
Reclamation designers should inform the Technical Service Center (TSC), via Reclamation’s Design Standards Website notification procedure, of any recommended updates or changes to Reclamation design standards to meet current and/or improved design practices.
Chapter 12 – Trashracks and Trashrack Cleaning Devices is a new chapter within Design Standards No. 6. “Trashracks” was an existing subsection within chapter 1 of Design Standards No. 7 and was revised by adding:
- Updated trashrack design process (last update was 1956)
- Trashrack cleaning devices
Prepared by:
Rick Christensen
Mechanical Engineer, Mechanical Equipment Group, 86-68410
Technical Approval:
Ryan Stephen, P.E.
Mechanical Engineer, Mechanical Equipment Group, 86-68410
Peer Review:
William D. McStraw, P.E.
Manager, Mechanical Equipment Group, 86-68410
Security Review:
Ryan Stephen, P.E.
Mechanical Engineer, Mechanical Equipment Group
Submitted:
George Girgis, P.E.
Chief, Electrical and Mechanical Engineering Division, 86-68400
Approved:
Tom Luebke, P.E.
Director, Technical Service Center
## Contents
### Chapter 12: Trashracks and Trashrack Cleaning Devices
| Section | Page |
|------------------------------------------------------------------------|------|
| 12.1 General | 12-1 |
| 12.2 Trashracks | 12-1 |
| 12.2.1 Types of Trashracks | 12-1 |
| 184.108.40.206 End Bearing Trashracks | 12-2 |
| 220.127.116.11 Side Bearing Trashracks | 12-3 |
| 18.104.22.168 Integral Trashracks | 12-5 |
| 12.2.2 Selection of Type | 12-6 |
| 12.2.3 Design Considerations | 12-7 |
| 12.2.4 Trash Bar Spacing | 12-9 |
| 12.2.5 Design Loads | 12-9 |
| 12.2.6 Design Stresses and Codes | 12-11|
| 12.2.7 Design for Nonvibrating Loads | 12-11|
| 12.2.8 Design for Vibrating Loads | 12-12|
| 12.2.9 Corrosion Protection | 12-12|
| 12.3 Trashrack Cleaning | 12-13|
| 12.3.1 General | 12-13|
| 12.3.2 Debris | 12-14|
| 12.3.3 Methods and Types of Trashrack Cleaning Devices | 12-14|
| 22.214.171.124 Sluicing | 12-14|
| 126.96.36.199 Air Burst | 12-14|
| 188.8.131.52 Raking | 12-15|
| 184.108.40.206.1 Manual Raking | 12-15|
| 220.127.116.11.2 Mechanical Raking | 12-15|
| 12.4 Checklist for Trashracks and Cleaning Devices | 12-16|
| 12.4.1 Trashracks | 12-16|
| 12.4.2 Trashrack Cleaning Devices | 12-16|
### Figures
| Figure | Page |
|------------------------------------------------------------------------|------|
| 18.104.22.168-1 End bearing type trashracks located within a canal | 12-2 |
| 22.214.171.124-2 End bearing type trashracks with horizontal support beams | |
| being installed at canal turnout intake | 12-3 |
| 126.96.36.199-1 Side bearing trashracks at reservoir outlet structure | 12-4 |
| 188.8.131.52-2 Side bearing trashracks at river side intake | 12-4 |
| 184.108.40.206-1 Three-sided integral trashracks being reinstalled over | |
| dam outlet works | 12-5 |
| 220.127.116.11-2 Three-sided integral trashracks for dam outlet works | 12-6 |
Chapter 12
Trashracks and Trashrack Cleaning Devices
12.1 General
Trashracks are used at powerplant intakes, pumping plant intakes, canal headworks and within canals, at turnouts, and at diversion structures to eliminate the passage of objectionably large floating and submerged debris that would cause damage or operational problems at downstream structures and equipment. Such debris can damage turbines, pumps, valves, gates, screens, etc. Trashracks have also been used as a type of fish barrier for discouraging and/or restricting fish passage.
Trashracks usually consist of rows of parallel trash bars. The usual practice is to provide a clear opening between trash bars that is as large as possible yet consistent with the features and equipment to be protected, to consider hydraulic head loss through the rack only when this loss is important, and to consider the ease of replacement in proportioning the rack so as to build long life into those racks which may not be readily replaced.
In addition to using a trashrack to prevent the passage of objectionably large debris, it may also be necessary to intercept and remove debris so that the flow of water will not be hindered. Therefore, the trashrack cleaning method will need to be determined, and a cleaning device capable of removing the debris from the trashracks may also be required. The cleaning device can vary from a manually operated, hand-held rake to a sophisticated, automated, mechanical cleaning machine. The type of cleaning device selected should depend on the particular needs at the site.
12.2 Trashracks
12.2.1 Types of Trashracks
The details and general construction of trashracks vary with the service required, configuration of the trashrack structure, depth of water, and accessibility for replacement and maintenance. Trashracks are usually constructed of rectangular shaped, vertical bars held together with lateral bars or structural shapes. Although round or streamlined trash bars may reduce hydraulic head loss, they are not commonly used because of the added expense and their tendency to vibrate. Trashracks with round bars and pipes are also more susceptible to clogging because objects can pass partially through the trashrack, then become firmly
lodged, making it harder to clean. Trashracks are usually fabricated from structural steel, although they have also been fabricated from fiberglass, plastic, wrought iron, and stainless steel. If very small openings are required, prefabricated grating, perforated plate, and wedge wire screening are often used.
Trashracks may be divided into three types according to construction and installation requirements. These types are end bearing, side bearing, and integral trashracks.
18.104.22.168 End Bearing Trashracks
End bearing trashracks are the simplest (and usually the cheapest) of the three kinds of racks. The trash bars run from top to bottom and individually carry the loads into the trashrack structure. End bearing trashracks are commonly used for canal headworks and where the trashrack panel can extend from top to bottom of the rack-protected area (see figure 22.214.171.124-1). Due to the end bearing characteristics, these trashracks can be installed side by side to obtain the desired area. End bearing trashracks are ideal where low head conditions exist and large trashrack areas are necessary. End bearing trashracks are usually installed in an inclined position; however, they can be used in a vertical or near vertical position if proper care is taken to secure the racks with clips or expansion anchors. In installations where the trash bars are excessively long, it becomes economically advantageous to install one or more support beams laterally to the rack (see figure 126.96.36.199-2). The support beams, which bear and carry the trashrack loads to the sides of the trashrack structure, provide lateral support to the trash bars so that their loaded spans are shorter, thus reducing the size of the trash bars.
Figure 188.8.131.52-1. End bearing trashracks located within a canal. Trashracks were provided with automated trash rake and conveyor debris removal system.
184.108.40.206 Side Bearing Trashracks
Side bearing trashracks are supported by the trashrack structure on both sides of the rack. The trash bars run from top to bottom and are supported by lateral bars or beams, which carry the loads into each side of the rack. The racks are supported or retained by guides or grooves provided in the trashrack structure. Side bearing trashracks are usually installed in a vertical position, but can be used effectively in an inclined position, and they are occasionally used in the prone position. Side bearing trashracks are used for high or low head conditions, and they are sometimes substituted for end bearing trashracks when the trashrack supporting structure cannot withstand high bearing loads at the top. The major limiting design concern for side bearing trashracks is the span, which is directly related to the economics. Side bearing trashracks may be stacked in tiers to obtain any designed height and may require alignment dowels to allow cleaning. Side bearing trashracks are shown in figures 220.127.116.11-1 and 18.104.22.168-2.
Figure 22.214.171.124-1. Side bearing trashracks at reservoir outlet structure. Note the vertical, stacked trashrack panels installed within the concrete structure grooves (slots).
Figure 126.96.36.199-2. Side bearing trashracks at river side intake. Note the inclined trashrack panels installed within metal trashrack side guides.
188.8.131.52 Integral Trashracks
Integral trashracks are a combination of several panels constructed of trash bars with lateral support beams or members. Integral trashracks can be circular, three sided, or box shaped. They can be designed with a superstructure having trashrack panels inserted into the structure or with reinforced panels welded or bolted together. The support members make up a multisided, rigid frame, which carries the loading into the trashrack supporting structure. Integral trashracks simplify the trashrack structure by eliminating most of the concrete supports that are usually required for trashracks. Integral trashracks are usually used in deeply submerged applications, such as penstocks or multilevel withdrawal outlet systems, and they are typically not intended to be replaced over the life of the structure. Integral trashracks are shown in figures 184.108.40.206-1 and 220.127.116.11-2.
Figure 18.104.22.168-1. Three-sided integral trashracks being reinstalled over dam outlet works.
12.2.2 Selection of Type
The appropriate type of rack for an installation must be suitable for the trashrack structure, for the size and quantity of debris and trash expected, and for the method of cleaning (raking), if needed. In addition, the type of rack selected will depend on its accessibility for maintenance or replacement. The design of the rack, including spacing of the bars, should be discussed with the engineers responsible for the design of the structure and equipment being protected. The need for a trashrack cleaning device should be identified in the Design Data Request because it can affect the designs of the trashracks and the supporting structure. When selecting a type of trashrack, the following trends are common:
(1) At canal headworks and for pumping plants where a single line of laterally spaced rack sections extend from above the water surface to the bottom of the rack-protected area, end bearing trashracks have usually been selected and installed in an inclined position.
(2) Where a portion of the racks is deeply submerged, side bearing trashracks have usually been selected and installed in the vertical position.
(3) At completely submerged intakes, integral type trashracks are well suited.
### 12.2.3 Design Considerations
The approach velocity (maximum flow divided by the overall trashrack area) for each structure must be determined on a case-by-case basis. Most trashrack structures are sized to provide a maximum approach velocity of 1 to 2 feet per second (ft/s) for normal flows. This slow approach velocity reduces the tendency to collect debris against the racks, minimizes the possibility of trashrack vibration, and provides a relatively safe condition for unauthorized personnel such as boaters or swimmers. Trashracks with low velocities are easier to clean, and debris is not prone to lodge between the trash bars. Hydraulic head loss through trashracks can be effectively reduced by minimizing the approach velocity. Trashracks designed with low velocities generally do not have destructive vibration problems and can be designed without taking into account the individual trash bar and trashrack panel vibration. According to tests and field observations, velocities are not always uniform through the trashrack area. Consideration should always be given to a trashrack structure’s location, size, and the site’s flow patterns to help design the best flow distribution across the trashracks.
The trashrack area necessary to achieve a 1- to 2-ft/s approach velocity is desirable but not always practical. Higher approach velocities have been used to size the trashrack area in order to limit the physical size of the structure and, thus, decrease the capital cost. Tests on trashracks reveal nonuniform velocities will occur over the trashrack area. Localized velocities can be as much as twice the average velocity, depending on the geometry of the trashrack structure. In addition, at intakes with more than one opening per unit, the flow of water is not uniformly distributed between the openings. With two openings per unit, the trashrack design should allow two-thirds of the water to flow through one of the two openings. With three openings per unit, trashrack design should allow 45 percent of the water to flow through one of the three openings. At higher approach velocities (typically greater than 5 ft/s), vibration can be a problem.
Many factors must be considered when deciding how large to design an approach velocity, such as:
- Economics
- Safety considerations
- Preservation of fish
- Location of the trashrack structure within the system
- Amount of expected debris
- Submerged conditions
- Age of the structure; for example, a new structure would probably have more debris than an old structure
- Type of usage; for example, a canal outlet versus a river intake structure
- Intake hydraulics and eddy currents
- Types and expected quantity of debris and sediment that the water may be carrying
- Whether the trashracks will be cleaned and, if so, what cleaning method will be used?
If a trashrack is to be raked, special consideration must be made. Different raking methods require different slopes for the trashrack. Generally, hand raked trashracks are designed with a slope that is as flat (horizontal) as possible (typically 45 degrees or flatter) and an approach velocity of 1 ft/s. Trashracks that will be raked mechanically should typically have a slope angle between 5 to 30 degrees from the vertical and an approach velocity of 2 ft/s; however, some rakes can also clean vertical trashracks. Trashrack panels that will be raked and are stacked in tiers (usually side bearing type trashracks) must be kept in alignment, usually by providing large dowel pins between the panels. Lateral members of the trashrack should also be recessed a minimum of 1.50 inches from the face of the trash bars, if possible, to prevent interference with the teeth of the cleaning device. A trashrack extension or an increased length of the trashrack trash bars may also be required if the cleaning device needs to rake the debris into a debris conveyance system located above the deck.
Trashracks are not usually designed to be escape devices or safety features, but they can perform that function at times. Whenever a trashrack is intended primarily as a safety (escape) rack to protect humans or animals from being drawn into the structure, siphon, or conduit, the following aspects shall be considered: (1) approach velocity should be less than 2 ft/s with a minimal current force; (2) trashrack slope of 4:1 (horizontal to vertical ratio) or flatter (6:1 preferred); and (3) the spacing of the lateral (cross bars) supports should be spaced at 15 to
18 inches to facilitate climbing for escape. The maximum spacing between the trash bars should not be greater than 8 inches; however, the spacing must be large enough to enable a hand to reach between the trash bars to grab the cross bars. Flattening the slope of the trashrack and providing sufficient cross bars to facilitate climbing for escape are modifications that could make the safety rack an escape device. Safety racks will require additional maintenance, so they should only be used where maintenance problems associated with debris are not severe.
### 12.2.4 Trash Bar Spacing
The spacing of the trashrack’s individual trash bars should be selected to suit the equipment being protected. The usual practice is to provide a clear opening that is as large as possible, while still protecting the downstream equipment. Closer spacing of trash bars than needed will result in unnecessary hydraulic head loss and will cause premature clogging of the racks.
Clear openings of 1.5 to 2 inches are commonly used for canal applications and where the trashracks are upstream of traveling water screens and fish screens. The largest spacing of trash bars is normally 6 inches. The lateral supports are typically spaced between 18 and 30 inches.
For a Francis, Kaplan, or propeller turbine, the spacing has to be smaller than the minimum opening in the turbine runner or maximum opening of the wicket gates, whichever is smaller. For a Pelton turbine, a minimum spacing of 1.5 inches is usually used because debris cannot readily pass through the needle valve nozzles.
Clear openings greater than 6 inches may be required by the responsible fish resource management and regulatory agencies at some installations to allow for passage of large fish (i.e., adult salmon at a fish ladder).
Clear openings less than or equal to 1 inch have also been used to discourage fish passage. Note: Trashracks are not intended to be used as fish screens; therefore, it is necessary to check the appropriate criteria of the responsible fish resource management and regulatory agencies because these small openings may still not meet their criteria for the size and fish species at the site. The small openings may also result in excessive debris buildup, loadings, and cleaning requirements.
### 12.2.5 Design Loads
To design a trashrack, the working design loads must first be determined. Trashracks must be designed to support forces applied by the raking and cleaning equipment, debris, and ice. Stresses should always include the dry dead weight of the trashracks. Knowing the loads, the working stresses can be determined and compared with acceptable allowables.
Totally submerged trashracks and trashracks that are submerged more than 20 feet of head should be designed to fail at approximately 20 feet of differential head; assuming that the trashrack structure is designed to withstand greater than 20 feet of differential head.
Trashracks submerged 20 feet or less are usually designed to fail at a differential head that is at least two-thirds of the maximum depth of submergence (based on the depth at the bottom of the trashrack). If, however, these racks are intended to serve as supports for flashboards, they should be designed for a safe stress under maximum load conditions.
All trashracks that are installed must be designed to yield before any damage is sustained to the support structure if they ever become totally obstructed.
Trashracks can be designed for a lower differential head (typically designed with a safe stress at a 5-foot differential head) if the trashracks will be equipped with an automatic trash cleaning system and/or water differential sensors that will inform the operators that the trashracks require cleaning.
Care should be taken to avoid heavy loadings from trashracks near or on the exposed edges of concrete structures. The normal practice is to connect the horizontal beam members on the side bearing trashracks to an angle which will disperse and carry the concentrated load farther back into the guided slot of the concrete support structure.
In locations where freezing is a problem, trashracks must take into account the loads resulting from ice. Ice loading can induce much greater loads than would be expected from other trash loadings. In addition to designing for high load stresses, the trashracks should be properly secured to prevent floating ice from lifting the trashrack from the supporting structure. Where ice loading has been an identified problem, trashracks have typically been designed to withstand 20 feet of differential head (or designed for the safe stress at the maximum/plugged load condition), and the thickness of the individual trash bars has been not less than 3/4 inch.
For many structures, it is easier to prevent ice buildup against the trashracks than to design for the loadings that result from ice that accumulates on them. In some situations, air blast or bubbler systems are used to draw and circulate warmer waters from below the surface (depths for bubbler systems to work properly require at least 10 feet of water depth) to prevent ice formation in the trashrack area. Occasionally, heaters are used inside of hollow trash bars, near the trashracks, or at the guides to allow removal of trashrack panels. In some cases, the right design will provide good flow patterns that will discourage freezing around the trashrack. Lower approach velocities may allow formation of ice cover and, thus, reduce frazil ice formation. In addition, periodically vibrating trashracks with an exterior exciter has been used to control formation of frazil ice.
on the trash bars. Also, certain materials or coatings on metal trash bars are able to discourage the formation of frazil ice or allow operation at a lower water temperature before ice forms. Designing discontinuities into the metal trash bars to prevent cold air temperatures from penetrating deep into the water has been partially successful for controlling ice formations. The discontinuity is either a physical gap of several inches in each trash bar or a material along the trash bar that has poor heat transfer properties. Either of these methods prevents colder temperatures from being transferred to the lower portions of the trash bars from the colder surface of the water or exposed surfaces of the trash bars. In some cases, depending on operating conditions, and where shallow depths make a bubbler system ineffective, the solution for ice problems may be to simply remove the trashracks during extreme cold weather.
12.2.6 **Design Stresses and Codes**
Metal trashracks can be designed, detailed, and fabricated according to the standards set by the American Institute of Steel Construction (AISC) Steel Construction Manual.
12.2.7 **Design for Nonvibrating Loads**
Typically, most trashracks are designed to fail before failure of the structure occurs. The stresses should always include the dead weight (dry) of the trashrack. A member of a trashrack is assumed to fail when the stress in the member reaches the following value:
\[
SF = 1.10FY \tag{1}
\]
where:
- \( SF = \) failure stress
- \( FY = \) minimum yield stress of material
For end bearing trashracks, the trash bars are usually designed to fail if the rack becomes overloaded. For side bearing trashracks, the lateral support beams or their connections to the structure are usually designed to fail if the rack becomes overloaded.
Similarly, a trashrack’s safe working stress should not exceed the following value:
\[
SS = 0.6FY \tag{2}
\]
where:
- \( SS = \) safe working stress
- \( FY = \) minimum yield stress of material
Trashrack trash bar sections should be rectangular. The depth of a trash bar section should be at least 4 times, but less than 12 times, its thickness. The trash bar section depth to thickness is called the aspect ratio (i.e., trash bar $2 \times \frac{1}{2}$ has an aspect ratio $2/0.5 = 4$). The lateral unsupported length of a trash bar should not exceed 70 times its thickness. Lateral supports are normally spaced between 18 and 30 inches.
For many structures, the designer must consider more parameters than simply the design loads and allowable stresses when sizing members of a trashrack. It is also necessary to consider things like corrosion, ease of fabrication and welding, economics, stresses due to handling, operation, likelihood of obtaining maximum design loads, etc.
### 12.2.8 Design for Vibrating Loads
Trashracks used in pump-generating intake/discharge structures usually experience higher velocities than 2 ft/s. In the past, individual trash bars or whole trashrack panels in the inlet and discharge of pump-turbines have experienced failures. These failures were largely attributed to vibration resulting from the dynamic interaction between nonuniform, high-velocity water flowing through the trashracks. The trashracks at some of these pump-generating intake/discharge structures experienced localized velocities as large as 15 to 20 ft/s. The load stresses were normally low, but the racks had to be analyzed for vibration and designed for fatigue loading.
As a general rule, trashracks with approach velocities greater than 5 ft/s should be analyzed for vibration. Followup field testing and inspections may also be required.
It has been discovered that round trashrack bars should not be used because they are subject to vortex shedding, which can lead to failure of the bar. It is recommended that trash bars be rectangular bars with an aspect ratio of at least 4, which provides a stable cross sectional area in the flowing water.
Vibration is usually not a concern when designing canal trashracks, due to the low approach velocity. If a problem is suspected, a vibration analysis must be performed on a case-by-case basis.
### 12.2.9 Corrosion Protection
Corrosion is a major design concern for trashracks. The thickness of metal to be used in trashracks depends, to some extent, on the nature and probable permanence of the rack installation. The design of trashracks should allow for some deterioration, due to corrosion, without sacrificing structural integrity. The typical minimum thickness of low head, removable type trashracks is 3/8 inch.
It is customary to use a 1/2-inch minimum thickness on deeply submerged racks. When it is practical, the recommended minimum trash bar size used in trashrack design is 2 inches by 1/2 inch.
Welds are very vulnerable to corrosion. When determining weld size, it should be recognized that the allowance for corrosion of the weld is of equal importance as the strength of the weld. Welds that are highly stressed or in pure shear are usually oversized by 1/16 inch for corrosion. The recommended minimum size of the fillet weld should be the same size as the thickness of the metal in the trashrack, or 3/8 inch, whichever is less. It is also recommended that the horizontal beam members in side bearing rack sections have 1/2-inch welds at their end connections.
It is recommended that trashracks be painted with a protective coating. Current practice, based on past performance, has been not to recoat trashracks after initial installation (i.e., economic analysis has shown that replacing the structurally weakened racks is more cost effective than periodically repainting them). On some installations, cathodic protection systems have been considered for protecting the racks; however, at this time, only a few systems have been installed. When selecting a protective coating type for trashracks, it may be necessary to consider whether marine growth, such as zebra and/or quagga mussels, exists in the area. Under normal water conditions, galvanizing the trashrack is not an acceptable method of protection. During shipping and installation, care should be taken not to damage the protective coating. If the coating does get scratched or chipped, it should be properly repaired. If a rack has to slide a considerable distance on a concrete surface during installation, a wearing bar should be considered to protect the coating.
### 12.3 Trashrack Cleaning
#### 12.3.1 General
Many trashracks, especially deeply submerged trashracks in reservoirs, never require cleaning. The debris deteriorates or never accumulates. Some type of cleaning method is required, however, for trashracks if a debris problem exists that could cause an overload of the trashrack or associated structure, an undesirable head loss, or a reduction in the water delivery capability. The details and type of cleaning method will vary according to the service required, configuration of the trashrack and structure, depth of water, debris types, debris quantity, availability of power, and economics. The need for a trashrack cleaning device should be identified in the Design Data Request because it can also affect the designs of the trashracks and supporting structure.
Although debris booms are not covered in this section, they are often provided upstream of trashrack intakes and headworks for public safety, as well as to collect or divert large floating debris before it can reach the trashracks or gates.
12.3.2 Debris
Debris can be placed into the following two categories:
- Natural debris: tree trunks, branches, bushes, grasses, plants, weeds, aquatic plant growth (floating and submerged), etc.
- Manmade debris (trash): tires, plastics, cans, bottles, lumber, etc.
Natural debris is the most common debris trashracks are required to catch. Natural debris is most prevalent during flood conditions for reservoir intakes and on river intakes (i.e., pumping plant, powerplant, and canal intakes). Aquatic plant growth and tumbleweeds are the most prevalent problem in canals. Manmade debris, although not as common as natural debris, can still be a problem that requires protection at the intake.
Other natural considerations include ice, sediment, and rocks, which can create a problem in large quantities if not controlled. Marine growth has also become more prevalent in waterways. Marine life, such as zebra and quagga mussels, multiply and attach to water structures, which can block water intakes and trashracks.
12.3.3 Methods and Types of Trashrack Cleaning Devices
There are three general methods of cleaning trashracks: (1) sluicing, (2) air burst, and (3) raking. Raking is the most common method for cleaning trashracks; however, raking devices typically cannot operate during winter ice conditions.
22.214.171.124 Sluicing
Sluicing gates that open and allow collected debris (typically from a debris boom) to pass by the trashracks can be very effective in canals and diversion dams. This method can only be used where it is appropriate and lawful. Sluicing gates are also often used for passing ice and sediment.
126.96.36.199 Air Burst
For some submerged trashracks, an air burst cleaning method has proven effective for certain situations. Generally, a crossflow is required so that when air lifts the debris off of the trashrack face, the current will sweep the debris away. Prior to operating the air burst systems, it may be necessary to shut down the intake flow.
through the trashracks to prevent air from being drawn into the intake. The air burst can be hazardous to boaters and swimmers, so special precautions should be taken.
188.8.131.52 Raking
There are two general categories of trashrack raking devices: manual and mechanical. Manual raking is often used for small trashrack structures and for trashracks that collect very little debris. Large structures and trashracks that accumulate a large amount of debris usually require some type of mechanical cleaning device.
184.108.40.206.1 Manual Raking
The most common type of manual cleaning device for trashracks is the hand-held rake, which consists of a rake head (similar to a garden rake) connected to a long pole. Manual raking requires a person to physically lower and position the rake against the trashrack, drag the rake and debris to the top of the rack, and then pull the debris over the rack onto the deck or into a debris bin. Other variations of this basic concept include squeegee-type rake heads, in lieu of teeth, or portable pool-type vacuum cleaners. The squeegee-type rake has been used successfully at canal turnouts where debris can be pushed off a perforated plate type of trashrack to continue downstream in the canal.
220.127.116.11.2 Mechanical Raking
Mechanical cleaning devices are commercially available. Some common types of mechanical cleaning devices include hydraulic-type trash rakes, overhead monorail-type trash rakes with hoist and controlled gripper claw, backhoe-type rakes, and trashrack cleaners built integral to or over each trashrack bay.
Several factors must be taken into account when selecting the appropriate type of mechanical cleaning device. For example, can a single cleaning unit be used to clean multiple trashrack bays or a wide trashrack bay, or will multiple cleaning units be required? Can the cleaning unit(s) supply the desired control functions? Will a separate debris conveyance system be required? Will the trashracks, or a separate extension rack, need to extend above the deck to allow debris to be deposited into a debris conveyance system. Additional considerations may also apply, depending on site-specific circumstances.
Mechanical rakes are often automated to begin a trashrack cleaning cycle when head losses across the racks become excessive, when a predetermined differential head has been exceeded, and/or when a specified time interval has been reached. Many systems use both timers and differential water level sensors to start the cleaning cycle.
When selecting a trash rake, operational considerations must be made and/or restrictions applied if cleaning is required during winter/icing conditions. Special designs may also be required if flows approaching the trashracks are not
perpendicular to the rack (i.e., crossflows), or approach velocities are greater than 4 feet per second.
12.4 Checklist for Trashracks and Cleaning Devices
12.4.1 Trashracks
1. Has the debris/trash load been determined?
2. Have the types, sizes, and quantities of debris been identified?
3. What trash bar spacing is required?
4. Will the trashrack support structure carry the loaded trashrack?
5. What approach velocity to the trashracks is being used, and is this acceptable?
6. What corrosion factor should the trashrack be designed to?
7. What forcing vibrations from the rotating machinery can be transmitted through the water to the trashrack?
8. What forcing vibrations from equipment in the powerhouse can be transmitted through the support structure to the trashrack?
9. Will trash bar vibration occur at the average velocity or local higher velocities through the trashrack?
10. Will trashrack cleaning be required?
11. Will ice loading or ice prevention be required?
12.4.2 Trashrack Cleaning Devices
1. What type of trashrack cleaning device is needed?
2. Is electrical power available at the site, and what voltages are available?
3. Should the cleaning device be automatically or manually operated?
4. Does the trash have to be conveyed automatically away from the area, or will it be stockpiled and then carried away manually?
5. Is there room for a debris conveyance system with the trash rake, or will the trash rake system need to transport the debris to the dumping area?
6. Are the trashracks to be cleaned (either new or existing) designed to accommodate cleaning by the trash rake? To determine the answer, a number of questions must be considered, such as the following: Are the trash bars aligned if stacked trashrack panels are used? Are the lateral support members sufficiently recessed for the trash rake teeth? Are the trash bar openings large enough to rake? Are the trash bar spacings consistent to accommodate the trash rake teeth? What is the slope of the trashracks? Are the trashracks accessible for cleaning by the trash rake? What is the approach velocity?
7. Will operational considerations and/or restrictions be required during winter/icing conditions and is this acceptable?
8. Will high approach velocities and/or crossflows be present at the trashracks that would require special designs for the trash rake?
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The Macnachtan Clan, one of the most ancient in the Scottish Highlands, is thought to be descended from Pictish kings called Nechtan and their followers (hence Mac-Nechtan). The Picts were a Celtic-speaking race that ruled large portions of the northeastern Scottish Highlands from 448-847 AD. They did not leave extensive records but did leave a list of their kings and they erected standing stones, some of which survive today. One such is on the grounds of Inveraray Castle and is called by some the MacVicar stone (Fig. 1). Kenneth mac Alpin arrived from Ireland with his Scoti in 847, settled in Argyll, married a Pictish princess, and is thought to be the first king of what we now call Scotland.
Figure 1. The author by the standing stone at Inveraray Castle
The history of the Scottish monarchy is filled with conflict with their southern neighbors, the English, and with clashes between the older established catholic faith and the protestant religion that followed the Reformation. James Stuart became James VI of Scotland (1567-1625) and also James I of England and Ireland from 1603. This was the peak of Scottish power, when James ruled England, Scotland and Ireland. People who supported James and the Stuarts (or earlier Stewarts) were known as Jacobites, from the Latin *Jacobus*, meaning James. In 1707, the Scottish throne was replaced with that of the Kingdom of Great Britain.
Figure 2. Crannog in Loch Awe
Many of those who wanted to restore the throne of Scotland put their faith in Bonnie Prince Charlie (the “Young Pretender” to his opponents) who had a colorful and romantic career but suffered a tragic defeat by the British Government army at Culloden in 1746. His escape from the Scottish mainland is immortalized in the Skye Boat Song—“Carry the lad that’s born to be king, over the sea to Skye” (http://www.contemplator.com/scotland/skyboat.html).
The Clan MacNaghten fought in the Jacobite army supporting Charles and the Stuarts in this climactic battle; the Campbells supported the British government. Jacobites who were not killed in the battle were executed, imprisoned, transported to the colonies and banished. The clan system was destroyed, the clans were disarmed, and the kilt and the tartans were banned. Those who supported the British army were rewarded with titles and given confiscated lands.
Figure 4. Inveraray Castle
The Clan system flourished in the Scottish Highlands between the 12th and 18th centuries. It was based on strong leaders who provided protection for their followers in exchange for fierce loyalty. All around the world Scots keep clan traditions by wearing the kilt and, for formal occasions, a Bonnie Prince Charlie outfit.
Ironically, after the kingdoms of England and Scotland were united in 1707 and tensions were eased, came the Scottish Enlightenment (1730-1800), which produced a disproportionate number of intellectuals and new ideas. Key figures were James Boswell, author of “Life of Johnson”; Robert Burns, poet; David Hume, philosopher; Henry Raeburn, portrait painter; Sir Walter Scott, novelist and poet; Adam Smith, author of “The Wealth of Nations”; and James Watt, inventor.
At their peak, the Macnachtan clan owned much of the land between Loch Fyne and Loch Awe in Argyll. This area is about 35 miles northwest of modern-day Glasgow and is sheltered from the Atlantic Ocean by some of the western islands, including Mull. A loch can be either a lake, or an inlet from the sea such as a firth, fiord, estuary or bay. The western highlands get about 120 inches of rain a year, which accounts for the many waterways and lush green pastures. Loch Fyne is the closer to Glasgow, and at 40 miles is the longest sea loch in Scotland. It runs predominantly from the northeast to the southwest, draining eventually into the Firth of Clyde. Loch Awe runs roughly parallel, shifted northwest about six miles, and at 22 miles is the longest fresh water loch in Scotland, with an average width just over half a mile. Between these two lochs the Macnachtans ruled and maintained their castles at strategic locations.
**Figure 5. Tower House at Fraoch Eilean**
**FRAOCH EILEAN**
On 12th February 1267, King Alexander III of Scotland granted a charter to Gillechrist MacNachdan and his heirs for the keeping of his castle and island of Frachelan so that they should cause it to be built and repaired at the King’s expense and keep it safely for the king’s necessity. Fraoch Eilean, the “Heathery Isle,” is one of four small islands at the northern end of Loch Awe, the first three of which are (north to south) Innischonain, Fraoch Eilean, and Inishail.
**Figure 6. Path to the castle on Fraoch Eilean**
North of these there is also a crannog, or artificial island (Fig. 2). Crannogs were built by ferrying materials from the shore in boats, presumably to create fortifications or residences at key points, and have been dated from as early as 3000 BC, through the Iron Age to the early medieval period. Inishail is an “isle of the dead” that was used as a burial ground [Fig 3].
The last five Dukes of Argyll are all buried there. The current Duke of Argyll, Torquhil Ian Campbell, is the Chief of the Campbell Clan and Scotland’s most senior peer. In 2002, he married Eleanor Cadbury. They both work in London and spend their personal time in upstairs apartments at Inveraray Castle (Fig. 4). Argyll has traditionally been a stronghold of the Campbells and the history of the Macnachtan Clan is filled with conflicts and alliances with their more powerful neighbors.
Hugo Millar’s description of Fraoch Eilean [Ref. 1] still holds true today: “Foundations of stone walling appear here and there about the island but the main building still bulks largely on the landscape. It consists of a substantial stone hall, now very ruinous, and measuring some eighty feet by thirty and having at its east end a tower-house [Fig. 5] in what appears to be sixteenth century style, erected on the older hall masonry.”
**Figure 7. Niche inside castle**
“Free-standing halls of these dimensions are usually of early date, so that it is a fair assumption that this one may well represent the castle of 1267, and indeed may be earlier still, if one is warranted in reading such likelihood into this charter. The word ‘built’ need not necessarily mean erected for the first time, but more probably ‘added to’ or ‘improved.’ Thanks to time itself and [Robert] Bruce’s policy of castle destruction during the Wars of Independence, castles of the thirteenth century are few and far between, and those dateable by charter to that period fewer still.”
**Figure 8. Marya Dull and Jim Washington bound for Fraoch Eilean**
“The thirteenth century has been described as the Golden Age of Scottish architecture, as after the war, the greater landowners, and even the monarchy itself, could no longer afford to build castles on the grand scale … and the castle degenerated into a simple tower, which, as time progressed, grew more lavish and less simple, but which never quite achieved the earlier magnificence of its predecessors.”
Angus Macnaghten [Ref. 2] adds a description of Fraoch Eilean by Mr. and Mrs. William Douglas, who visited around 1913: “The castle on the north end of the island is indistinctly seen through the covering screen of ivy and intervening foliage. A little winding pathway [Fig. 6] leads up a steep slope to its entrance. The tottering walls are still covered with many years’ growth of ivy; the floors are thickly matted with roots of old trees, ivy and huzula grass; and healthy old ash trees flourish in the interior and rise high above its walls.”
“The ground plan extends to some 63 by 29 feet inside measurement, and the walls still reach considerable elevation; indeed at the south-east corner they seem almost to stand at their original height. They are not all of equal thickness, some being only three, and others as much as six-and-a-half feet deep.”
“The interior is divided by a wall extending across the building somewhat nearer its eastern end. In the smaller enclosure there are still visible the remains of chimneys, curious niches [Fig. 7] and windows, but all is covered with ivy and ferns . . . on the south side of the castle are the foundations of a massive wall extending right across its front, but for what purpose it was built we do not know.”
Macnaghten adds “In common with all the Highland clans the Macnachtans had their battle cry. What could be more natural than the cry ‘Fraoch Eilean,’ commemorating the royal favor of the thirteenth century?”
On Saturday 30 June 2007 members of the Clan Macnachtan Association Worldwide took a bus to Loch Awe. We stopped at the charming Loch Awe Hotel built in 1871, climbed down to the Loch Awe railway station and boarded a little steam boat that was built in 1927, with an engine not much younger. On board, everyone was very excited and snapped pictures, asked questions, walked around, and tried to relax [Fig. 8]. The island of Fraoch Eilean is strategically placed with a view west up the Brander Pass [Fig. 9] and north up Loch Awe. We had no guarantee of landing and the skipper began to make pessimistic noises, but some of the passengers would have killed to get ashore, so we made it by sheer will. We filed up the path and entered the hallowed halls of our ancestors, at least the ruined remains thereof (Fig. 10). It was an exhilarating experience. We explored the nooks and crannies, took photos, and even circumnavigated the perilous north wall. After about half an hour, the nervous skipper blew his horn, ostensibly concerned about being able to get the boat off its rough mooring.
We returned to the shore of Loch Awe and explored the lovely St. Conan’s Kirk [Fig. 11], where a prominent seat has been dedicated to Macnaughten of Fraoch Eilan [Fig. 12]. We also did a side tour to an innovative hydroelectric project that in off-peak hours pumps water from Loch Awe into a man-made loch up Cruachan Mountain to power generators during peak demand.
In 1292, just 25 years after the King of Scotland granted Fraoch Eilean to the Macnachtans, King Edward I of England (who turns out to be my 22nd great grandfather [Refs. 3, 4]) claimed superiority over Scotland and set up John Balliol as a puppet Scottish king. William Wallace led a band of Scottish rebels and on 11 September 1297 defeated a larger English army at Stirling Bridge, just below Stirling Castle, home of the Stuart monarchy. Donald Macnaughtan, probably Gillechrist’s grandson, fought against Robert Bruce, supporting his rival, Balliol and, being on the losing side, lost some of his lands.
But in 1306, at the Battle of Dalree, near the Brander Pass, Donald was so struck by Bruce’s extraordinary courage that he subsequently joined him and remained faithful to the end of his days. Bruce was crowned King of the Scots in 1310 and defeated a large English army at Bannockburn, just south of Stirling Castle, in 1314.
The Macnachtan fortunes waned in favor the Campbells, who built the castle of Kilchurn further north up Loch Awe in 1440, which suggests that Fraoch Eilean must have fallen into a minor role by this time. However, Macnaghten [2] claims that the castle appears to have been habitable as late as 1745. There are records of Macnachtans in various other locations. Macnaghten says the main branch flourished over the upper part of Loch Awe, Glen Shira, Glen Aray and Loch Fyne.
A glen is a valley, typically long, deep and often glacially U-shaped; or one with a watercourse running through it. Glen Shira houses a system of waterways that feed into the northern tip of Loch Fyne—(north to south) Loch Shira, the River Shira, and Dubh Loch—which meets Loch Fyne just north of Inveraray.
**DUBH LOCH**
There was a Macnachtan castle on the south end of Dubh Loch at the foot of Glen Shira that is supposed to have been built in the 1300s and which was abandoned in the 1500s. Millar [1] describes it thus: “The location of the castle lies east of the river’s exit from the loch (Fig. 13), and is on the point of a low, triangular-shaped green promontory.”
**Figure 14. Solitary tree grows on the south side of the castle site at Dubh Loch**
“The site, for it is no more than that today, consists of a grass-covered mound and what may be associated walling, the whole being oval in form and measuring some seventy feet by fifty, with its long axis oriented roughly NW and SE. The mound itself is no more than about six to seven feet high, and has a solitary tree growing on its south side (Fig. 14). The site is heavily overgrown with turf, and has the appearance of having been in that condition for a very long time. Odd stones, singly and in groups, outcrop here and there above the turf, or [are] embedded in it (Fig. 15), and can be felt everywhere underneath with a probe. No built faces of masonry are visible, and such stones as do appear bear no traces of mortar. The mound lies more to the SE side of the complex, and one has the impression that the whole may consist of a main building and courtyard; the entire mound, in fact, could be nothing more than collapsed stonework. Under the surrounding turf of the remainder of the promontory, stone can also be felt with a probe, and there is the possibility of a causeway, or paved area here, but the site may have been at least partially surrounded with water when the buildings were in occupation.” This must have been a minor castle.
**Figure 15. Odd stones outcrop here and there above the turf.**
The chief seat of the Macnachtan clan in the 17th century was Dunderave Castle on Loch Fyne, which is described in Part Two: “Dunderave and the New Chiefs” [5].
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**REFERENCES**
1. Millar, Hugo B., “Clan Macnachtan Castles of Argyll,” Clan Macnachtan Association Article No. 5, 1964.
2. Macnaghten, Angus I., “The Chiefs of Clan Macnachtan and Their Descendants,” privately printed for the author by Oxley & Son, 1951.
3. McNaughton, Ken, “Royal Blood,” awaiting publication, Jan 2010.
4. McNaughton, Ken, “Fourteen Generations,” awaiting publication, Jan 2010.
5. McNaughton, Ken, “The Clan Tour 2007 Part Two: Dunderave and the New Chiefs,” The Red Banner Newsletter, December 2007.
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**COPYRIGHT**
This work is copyrighted and may not be reproduced in whole or in part in any medium without written permission from the author, Ken McNaughton, 3778 College Avenue, Ellicott City, MD 21043; phone/fax: 410-418-9340; email@example.com (September 2007).
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RESIDENTIAL BUILDING SURVEY
XXXXX
Ealing
London
W5 XXX
Converted Victorian property
FOR
Mr X
Prepared by:
XXXX
INDEPENDENT CHARTERED SURVEYORS
Marketing by:
www.1stAssociated.co.uk
XXXX
CONTENTS
INTRODUCTION
REPORT FORMAT
SYNOPSIS
EXECUTIVE SUMMARY
SUMMARY UPON REFLECTION
EXTERNAL
CHIMNEY STACKS AND PARAPET WALLS
ROOF COVERINGS AND UNDERLAYERS
ROOF STRUCTURE AND LOFT SPACE
GUTTERS AND DOWNPIPES AND SOIL AND VENT PIPES
EXTERNAL WALLS
FASCIAS AND SOFFITS AND WINDOWS AND DOORS
EXTERNAL DECORATIONS
INTERNAL
CEILINGS, WALLS, PARTITIONS AND FINISHES
CHIMNEY BREASTS, FLUES AND FIREPLACES
FLOORS
DAMPNESS
INTERNAL JOINERY
TIMBER DEFECTS
INTERNAL DECORATIONS
CELLAR
THERMAL EFFICIENCY
OTHER MATTERS
SERVICES
ELECTRICITY
GAS
PLUMBING AND HEATING
BATHROOMS
MAIN DRAINS
OUTSIDE AREAS
PARKING
EXTERNAL AREAS
POINTS FOR LEGAL ADVISOR
APPENDICES
LIMITATIONS
ELECTRICAL REGULATIONS
GENERAL INFORMATION ON THE PROPERTY MARKET
XXXX
Independent Chartered Surveyors
——— Marketing by: ———
www.1stAssociated.co.uk
XXXX
All rights reserved. Reproduction in any form without express written consent of 1stAssociated.co.uk is prohibited
INTRODUCTION
Firstly, may we thank you for your instructions of XXXX; we have now undertaken a Building Survey (formerly known as a Structural Survey) of the aforementioned property. This Survey was carried out on XXXX.
The Building Survey takes the following format; there is an introductory section (which you are currently reading), which includes a synopsis of the building, and a summary of our findings.
We then go through a detailed examination of the property starting with the external areas working from the top of the property down, followed by the internal areas and the buildings services. We conclude with the section for your Legal Advisor and also attach some general information on the property market.
We are aware that a report of this size is somewhat daunting and almost off-putting to the reader because of this. We would stress that the purchase of a property is usually one of the largest financial outlays made (particularly when you consider the interest you pay as well).
We recommend that you set aside time to read the report in full, consider the comments, make notes of any areas which you wish to discuss further and phone us.
We obviously expect you to read the entire report but we would suggest that you initially look at the summary, which refers to various sections in the report, which we recommend you read first so that you get a general feel for the way the report is written.
As part of our service we are more than happy to talk through the survey as many times as you wish until you are completely happy to make a decision. Ultimately, the decision to purchase the property is yours but we will do our best to offer advice to make the decision as easy as possible.
REPORT FORMAT
To help you understand our Report we utilise various techniques and different styles and types of text, these are as follows:
GENERAL/HISTORICAL INFORMATION
This has been given in the survey where it is considered it will aid understanding of the issues, or be of interest. This is shown in “italics” for clarity.
TECHNICAL TERMS DEFINED
Throughout the Report, we have endeavoured to define any technical terms used. This is shown in “Courier New” typeface for clarity.
A PICTURE IS WORTH A THOUSAND WORDS
We utilise photographs and sketches to illustrate issues or features. In some photographs a pencil has been used to highlight a specific area. The sketches are not 100% technically accurate; we certainly would not expect you to carry out work based upon the sketches alone.
ORIENTATION
Any reference to left or right is taken from the front of the property, including observations to the rear, which you may not be able to physically see from the front of the property.
ACTION REQUIRED AND RECOMMENDATIONS
We have used the term ACTION REQUIRED where we believe that there are items that you should carry out action upon or negotiate upon prior to purchasing the property.
Where a problem is identified, we will do our best to offer a solution. However, with most building issues, there are usually many ways to resolve them dependent upon cost, time available and the length of time you wish the repair/replacement to last.
SYNOPSIS
SITUATION AND DESCRIPTION
This is a terraced house (a Halls adjoining) period property set in an established residential area. The property has been altered, extended and amended over the years and has a small garden to the front and a smallish garden to the rear.
Parking is at roadside on a first come first served permit basis on this tree lined road.
We believe that the property was built in the late Victorian era. If the age of the property interests you your Legal Advisor may be able to find out more information from the Deeds.
Putting Life into Perspective!
Some of the things that were happening around the time the property was built:
1859 Charles Darwin proposes the Theory of Evolution
1870 British Red Cross Established
Commencement of 1st Test Cricket England v Australia at the oval.
1880 Colchester earthquake four die in the UK's most destructive earthquake.
1884 The longest bridge in Britain, the Forth Bridge is opened
1890
1899-1902 Boer War between Britain and Boers in Southern Africa
1901 Queen Victoria Died
1903 First flight by Wright Brothers
1904 Boer War ends
1907 Einstein proposed his Theory of Relativity
1909 Picasso introduced Cubism
EXTERNAL PHOTOGRAPHS
Front Elevation
Rear View
Street View
Right hand view
Front garden
Rear garden
ACCOMMODATION AND FACILITIES
(All directions given as you face the front of the property)
**Basement**
There is a basement area which is very small and accessed from the hallway on the ground floor to the rear.
**Ground Floor**
The ground floor accommodation consists of:
1) Entrance Hallway
2) Reception Room (front)
3) Utilities Room with WC (internal)
4) Study (middle right hand side)
5) Kitchen/Dining Room
**First Floor**
The first floor accommodation consists of:
6) Master Bedroom (front)
7) Bedroom Two (middle)
8) Bedroom Three (rear left hand side)
9) Bedroom Four (small, rear right hand side)
10) Bathroom
**Outside Areas**
There are small gardens to the front and rear and parking is at roadside on a permit first come first served basis.
Finally, all these details need to be checked and confirmed by your Legal Advisor.
INTERNAL PHOTOGRAPHS
The following photos are of the internal of the property to help you recall what it looked like and the general ambience (or lack of). We have not necessarily taken photographs of each and every room.
Ground Floor
Reception Room
Entrance Hallway
Kitchen/Dining room
Kitchen/Dining Room
Study
Utilities Room
WC
First Floor
Master Bedroom
Master Bedroom
Middle Bedroom
Bathroom
Shower
Rear Right Hand Side Bedroom
Rear Left Hand Side Bedroom
SUMMARY OF CONSTRUCTION
External
Chimneys: Three brick chimneys
Main Roof: Pitched, clad with manmade slate
Main Roof Structure: Cut timber roof
Gutters and Downpipes: Mixture of Cast Iron and Plastic
Soil and Vent Pipe: Plastic
Walls: Flemish Bond brickwork re-pointed with cement mortar (assumed)
Fascias and Soffits: Painted timber
Windows and Doors: Timber sliding sash windows, single glazed Sliding, folding door to the rear
Internal
Ceilings: Lath and plaster and plasterboard (assumed)
Walls: Mixture of solid and studwork (assumed)
Floors: Ground Floor: Suspended floor (assumed)
First Floor: Joist and floorboards with embedded timbers (assumed)
Services
We believe that the property has a mains water supply, mains drainage, electricity and gas (all assumed). There is a Worcester wall mounted boiler located in the utilities room and the electrics are located under the stairs.
The above terms are explained in full in the main body of the Report.
We have used the term ‘assumed’ as we have not opened up the structure.
EXECUTIVE SUMMARY
Summaries are not ideal as they try to précis often quite complex subjects into a few paragraphs. This is particularly so in a summary about someone’s future home when we are trying to second-guess what their priorities are, so it is important the Report is read in full.
It is inevitable with a report on a building of this nature that some of the issues we have focussed in on you may dismiss as irrelevant and some of the areas that we have decided are part of the ‘character’ of this property you may think are very important. We have taken in the region of 250 photographs during the course of this survey and many pages of notes, so if an issue has not been discussed that you are interested in or concerned about, please phone and talk to us before you purchase the property (or indeed commit to purchasing the property), as we will more than likely have noted it and be able to comment upon it; if we have not we will happily go back.
We have divided the Executive Summary into ‘The Good’, ‘The Bad’ and ‘The Ugly’, to help distinguish what in our mind are the main issues.
The Good
Survey reports often are full of only the faults and general ‘doom and gloom’, so we thought we would start with some positive comments on the property!
1.0) Older properties typically have more space than newer properties, both in the actual size of the rooms and the height of the rooms.
2.0) The property has benefited from some modern upgrades to the kitchen and bathroom, you may or may not like these.
3.0) The property has good natural light due to the large double bay windows.
4.0) The property also has some of the original features left, which add to the overall character of the property.
We are sure you can think of other things to add to this list.
The Bad
Problems / issues raised in the ‘bad’ section are usually solvable, but often need negotiation upon. However, a large number of them may sometimes put us off the property.
1.0) Middle Chimney
The property has three chimneys all of which were difficult to view with the exception of the middle chimney that we could view from the loft roof window. We could see that the flashings had duly come away due to it being incorrectly bedded into the brickwork.
We find poor quality lead work to be more and more common where most modern builders do not have the level of skill required to carry out lead work correctly.
Flashings Defined
Flashings prevent dampness from entering the property, usually at junctions where materials change. Such a junction is the one between the chimney and the roof.
ACTION REQUIRED: Check all of the lead work to all chimneys and parapet walls and re-bed as necessary. If this is not carried out dampness will get into the property.
ANTICIPATED COST: Assuming access to your property can be gained from the flat roof rather than scaffolding we expect the costs to be in the hundreds of pounds rather than thousands of pounds if scaffolding is required; please obtain quotations.
Please see the Chimney Section of this Report.
2.0) **Parapet wall problem**
The parapet wall has coping stones which have not been bedded correctly and the walls require work.
**ACTION REQUIRED:** Re-bed coping stones and check parapet walls are watertight.
**ANTICIPATED COST:** In the region of £1000 to £2000, again assuming that the work can be carried out without scaffolding; please obtain quotations.
Please see the Roof Section of this Report.
3.0) **Slates to main roof**
The roof is finished with a manmade slate which undulates far more than we typically see. Manmade slates normally sit very flat and it is almost as if the roof has been a DIY project.
Our concern is that the slates will be lifted by the wind.
The difficulty we had was that we had a limited view of the roof internally due to the loft conversion which hides much of what we would normally be able to view.
**ACTION REQUIRED:** You need to monitor the roof carefully.
---
3.1) **Roof slate loose**
There is a roof tile which is loose at the front of the property and will allow wind driven rain to get into the property if not secured.
**ACTION REQUIRED:** Your Legal Advisor to confirm that the roof has Local Authority Approvals and if possible the existing owners to provide receipts/guarantees for the roof work.
Investigate where the slipped slate has come from. Secure roof slate.
Please see the Roof Section of this Report.
4.0) Rear Flat Roof
To the rear of the property there is a large flat roof which we could see had next to no fall present, a minimum of 15° is required.
We were pleased to see that the rear roof had a modern mineral felt. It is likely to be a third of the way through its natural life and as flat roofs are problematic we would recommend that you reinstate the roof light which is currently felted over.
**ACTION REQUIRED:** Alter the roof light so that it is also an access to the roof.
Your Legal Advisor to check and confirm if there are guarantees in relation to the flat roof.
4.2) Insulation and ventilation of flat roof
We have no way of knowing if there is insulation or whether the flat roof is vented which are both a modern day requirements and common sense.
Insulation to the flat roof would make the rooms to the rear warm and the ventilation would reduce any condensation taking place to this area. Typically with flat roof conversions the rooms beneath can get heat gain during the summer and heat loss during the winter.
Please note we did not go out onto the roof as our ladders were too short and also it had been raining during the course of our survey.
**ACTION REQUIRED:** Please check with the existing owners whether the roof is insulated or ventilated.
**ANTICIPATED COST:** Depending upon the above comments the adding of insulation could cost in the region of £2000 to £4000 where the insulation is installed on top of the roof; please obtain quotations.
Please see the Roof Section of this Report.
5.0) **Cast Iron Gutters and Downpipes**
The property has a mixture of original cast iron and modern replacement plastic gutters and downpipes with some of the original remaining cast iron gutters and downpipes being bandaged together at the front of the property which is not ideal.
ACTION REQUIRED: Repairs to cast iron gutters and downpipes i.e. remove the bandage and either replace or repair. Cast iron of this age often requires a bitumen lining.
ANTICIPATED COST: £1000 to £2000 to carry out proper repairs; please obtain quotations.
Please see the Gutters and Downpipes Section of this Report.
6.0) Re-point correctly in a lime mortar – lime every time
The property has Flemish Bond brickwork which has been incorrectly re-pointed using a cement mortar as opposed to a lime based mortar. Cement mortar smothers the building not allowing it to breathe whereas traditional lime mortar used on properties of this age, type and style allow the property to breathe.
Pointing Defined
Pointing is the mortar between the bricks.
Re-Pointing Defined
Re-pointing is carried out where the existing mortar has failed and broken away to stop damp penetration and further deterioration. The mortar should be raked out to approximately 20mm and then replaced with a mortar of a similar type, therefore, stopping damp occurring.
We cannot comment on brickwork to the right hand side of the property (all directions given as you face the property) as we did not have access to this area.
ACTION REQUIRED: Gradual re-pointing in a lime mortar, the good thing about cement mortar is that it falls off on its own, particularly when helped with a soft brush. We would recommend yearly visits by an experienced, time served bricklayer who knows how to work in lime mortar which will gradually allow the building to breathe and reduce the dampness within the building.
ANTICIPATED COST: A few hundred pounds per year for many years to come. We anticipate the work in total to cost in the region of £4000 to £6000; please obtain quotations.
Please see the Walls Section of this Report.
7.0) Rear Kitchen Wall is Dry Lined
The rear Kitchen wall is dry lined which means that we were unable to carry out any damp meter readings. Typically, on this age of property, walls are dry lined as there is dampness in them.
Dry Lining Defined
This term comes from the fact that plasterboard is dry and used as an inner lining within the property. Prior to this a wet plaster was used and required drying out periods which slowed the construction process down. Therefore almost universally in modern properties dry lining is used both as a ceiling material and sometimes to internally line the walls.
ACTION REQUIRED: When dry lining a solid wall such as this you should have it vented also. Carry out investigations with the existing owners (the owners were not at home at the time of our survey).
Please see the Walls Section of this Report.
8.0) Work to windows
The windows to the front of the property have suffered, particularly in the sunlight, whilst the windows that we opened did open when we carried out our knife test we found that the windows had been filled and were soft.
ACTION REQUIRED: Professional repairs are necessary.
ANTICIPATED COST: Set aside the sum of £2000 to £5000 to have professional repairs carried out to the windows including easing and adjusting; please obtain quotations.
Please see the Windows Section of this Report.
9.0) Rear sliding, folding door
There is a rear sliding, folding door which we have concerns about the adding of these types of modern doors to a property such as this as there is a considerable span which needs to be supported. As such Local Authority Approvals should have been obtained.
Planning Permission Defined
Planning Permission looks at the aesthetics and how this is appropriate for the area with such things as additional windows at the gable end.
Building Regulations Approval Defined
Building Regulations looks at the safety and the standard of building such as the adding in of the structural steels and the windows.
ACTION REQUIRED: Your Legal Advisor to check and confirm if Local Authority Approvals have been obtained.
Please see the Windows and Doors Section of this Report.
10.0) Loft Conversion official or not?
Whilst the conversion has two roof lights to the rear and is boarded we do not believe that this would be classed as an official loft conversion and as such a habitable room.
The floor of the loft, which is the ceiling of the rooms below, we believe is still the original ceiling joists i.e. they are suitable for supporting a ceiling but not suitable for acquiring Building Regulation Approval for supporting a floor loading.
**ACTION REQUIRED:** We recommend your Legal Advisor makes enquiries with the Local Authority with regard to the loft conversion to find out if any approvals have been sought.
We often find that people carry out the cheap parts of a loft conversion and the expensive areas are left for example in this case:
10.1) putting in the floor joists
10.2) adding the headroom with dormer windows etc
10.3) staircase
10.4) Fire Regulations
**The Ugly**
*We normally put here things that we feel will be difficult to resolve and will need serious consideration.*
There is nothing which we feel falls within this section providing you are happy with the characteristics of the property which we have mentioned throughout the report.
Other Items
Moving on to more general information.
Maintenance
It should be appreciated that defects which would normally be highlighted in a modern property, effectively form part of an older property’s overall character and style. Such defects are considered acceptable and may not have been specifically referred to as defects within the context of this Report.
This type of property will require ongoing maintenance and repair and a budget for such work must be allowed to ensure it is maintained in good condition. This will prevent undue and unnecessary deterioration.
One thing that does help make maintenance easier is good access which is why we have recommended a roof light is added to the rear flat roof to allow access to be gained to this area.
Services
Whilst we have carried out a visual inspection of the services within the property we also need to advise you of the following:
Electrics
For the electrics We would recommend an Institute of Electrical Engineers standards (IEE) test and report carried out by an NICEIC registered and approved electrical contractor or equivalent, which is recommended whenever a property changes occupancy.
Heating
We would recommend that the system be tested and overhauled before exchange of contracts and that a regular maintenance contract be placed with an approved heating engineer.
Drainage
Whilst we have lifted the manhole covers the only true way to find out the condition of the drains is to have a closed circuit TV camera report to establish
the condition of the drains. In this age of property there have often been leaks over the years.
**Water Supply**
There is danger in older properties of having a lead water supply; we would recommend that you speak to the water company to ask them if they have carried out such replacement, as you will be re-piping much of the water used in the building it gives an ideal opportunity to also check for any remaining lead pipes.
**ACTION REQUIRED:**
We would reiterate that we recommend with regard to all services that you have an independent check by a specialist contractor.
**DIY/Handyman Type Work**
There are numerous other items that we would class as DIY or handyman type work such as redecorating to turn the property into your home. We have detailed these and other issues within the main body of the report.
**Purchase Price**
We have not been asked to comment upon the purchase price in this instance, we have however referred you to sources of general information on the housing market within the Information on the Property Market Section, which can be found in the Appendices at the end of the Report.
**Every Business Transaction has a Risk**
Every business transaction has a risk, only you can assess whether that risk is acceptable to you and your circumstances. You should now read the main body of the Report paying particular attention to any “ACTION REQUIRED” points.
Estimates of Costs
Where we have offered an estimate of building costs please remember we are not experts in this area. We always recommend you obtain quotations for the large jobs before purchasing the property (preferably three quotes). The cost of building work has many variables such as the cost of labour and estimates can of course vary from area to area when giving a general indication of costs. For unskilled labour we currently use between £75 and £100 per day (the higher costs in the city areas) and for tradesmen we use between £100 and £200 per day for an accredited, qualified, skilled tradesman. Other variations include the quality of materials used and how the work is carried out, for example off ladders or from scaffold.
If you obtain builders estimates that vary widely, we would advise the work is probably difficult or open to various interpretations and we would recommend a specification is prepared. It would usually be best to have work supervised if it is complex, both of which we can do if so required.
SUMMARY UPON REFLECTION
The Summary Upon Reflection is a second summary so to speak, which is carried out when we are doing the second or third draft a few days after the initial survey when we have had time to reflect upon our thoughts on the property. We would add the following in this instance:
We would refer you to our comments in the Executive Summary, ‘Good’, ‘Bad’ and ‘Ugly’ Section and ask that you re-read these.
As a general comment for any work required we would always recommend that you obtain at least three quotations for any work from a qualified, time served tradesperson or a competent registered building contractor prior to legal completion.
We would ask that you read the Report in full and contact us on any issues that you require further clarification on.
MORE ABOUT THE REPORT FORMAT
Just a few more comments about the Report format before you read the actual main body of the Report.
TENURE – FREEHOLD (OR AS GOOD AS)
We have assumed that the property is to be sold Freehold or Long leasehold, with no unusual or onerous clauses and that vacant possession will be available on completion. Your Legal Advisor should confirm that this is the case.
ESTATE AGENTS – FRIEND OR FOE?
It is important to remember that the estate agents are acting for the seller (usually known as the vendor) and not the purchaser and are therefore eager to sell the property (no sale – no fee!). We as your employed Independent Chartered Surveyor represent your interests only.
SOLICITOR/LEGAL ADVISOR
To carry out your legal work you can use a solicitor or a legal advisor. We have used both terms within the report.
TERMS OF ENGAGEMENT/LIMITATIONS
This report is being carried out under our terms of engagement for Building Surveys, as agreed to and signed by yourselves. If you have not seen or are not happy with the terms of engagement please phone immediately 0800 298 5424 or email the secretary from which this survey came from.
OUR AIM IS ONE HUNDRED PERCENT SATISFACTION
Our aim is for you to be completely happy with the service we provide, and we will try and help you in whatever way possible with your property purchase - just phone us.
THE DETAILED PART OF THE REPORT
FOLLOWS, WORKING FROM THE TOP
OF THE PROPERTY DOWNWARDS
Converted Victorian property
Chimney Stacks
Chimneys developed originally from open fires placed within buildings. From this, the chimney has developed to its present day format where it is used as an aesthetic feature and focal point rather than purely just to heat the room.
There are three chimneys to this property they are located to the left hand side, middle and right hand side and side walls sit on the Party Walls. (all directions given as you face the property).
Chimney One - middle
This chimney is the one that we have identified in the Executive Summary as having a defective flashing and as such this sort of modern builder error would be likely to be in the other two chimneys.
ACTION REQUIRED: Please see our comments in the Executive Summary.
Chimney Two – left hand side
This chimney is brick finished with a lead flashing and numerous chimney pots. From what we could see from the roof light it looked in average condition considering its age, type and style. However we believe a close up look is necessary.
Unfortunately we were unable to see the top of the chimney known as the flaunching, we therefore cannot comment upon them.
ACTION REQUIRED: Carry out a close inspection particularly to the flashings. Re-point if necessary. Periodically inspect the chimney.
Chimney Three – front right hand side
Again, this chimney is also built with two chimney pots. We could not see the flashings and again we would recommend the flashings are inspected.
ACTION REQUIRED: Check the whole chimney and particularly look at the flashings. Periodically inspect the chimney.
Flashings Defined
Flashings prevent dampness from entering the property, usually at junctions where materials change. Such a junction is the one between the chimney and the roof.
Flaunchings Defined
A low, wide cement mortar fillet surrounding the flue terminal on top of the chimneystack to throw off rainwater.
Valley Gutters
Valley gutters are generally considered to be weak areas on a roof. The valley gutter is used where a roof changes direction. In this case we believe the valley gutters could either be lead or Glass Reinforced Plastic (GRP) given the condition of the lead work to the chimney.
**ACTION REQUIRED:** The valley gutters should be checked at high level with a roofer with long ladders. We would recommend a roofer takes photographs of any problems.
Glass Reinforced Plastic (GRP) valley gutter
Parapet Walls
*Parapet walls are usually walls that are above roof level and often sit on the boundary of the property.*
In this case there are parapet walls to the main roof and also to the rear flat roof. We can see that the coping stones are coming away to the flat roof side.
**ACTION REQUIRED:** Re-bed parapet wall coping stone and check the parapet walls as a whole as it looks like it is relatively new work.
Please see our comments in the Executive Summary.
Finally, we were only able to see approximately forty percent of the parapet wall, therefore we have made our best assumptions based upon what we could see. A closer inspection may reveal more.
**Roof Windows**
*(Known as roof lights or Velux windows which is the trade or generic name)*
The property has three purpose made roof lights, two to the rear slope and pitch of the roof and one to the flat roof which has been partly felted over.
Please see our comments in the Executive Summary.
The roof windows within the pitched roof are in average condition with no heavy visible staining. Although we would add it seems inevitable with roof windows that they will sooner or later leak. If this doesn’t occur then they seem prone to condensation. Keep a cloth handy!
**Party Wall**
The party wall relates to shared items, such as chimney and parapet walls. If you do any work on these you will need to deal with the Party Wall Act. Here is a brief explanation of it.
*Party Structures Defined – Party Wall Act Etc. 1996*
A structure that both parties enjoy the use of or benefit from. An example of this would be where both parties gain support from a wall or utilise a chimney or chimneys.
*Any work to party structures, such as party walls or party chimney stacks, require agreement under the Party Wall Act. We would be more than happy to offer you help and advice in this matter.*
Finally, we have made our best assumptions on the overall condition of the chimney stacks, parapet walls and roof windows from the parts we would see above roof level. The inspection was made from ground level within the boundaries of the property (unless otherwise stated) using a x16 zoom lens on a digital camera. A closer inspection may reveal latent defects.
Please also see Chimney Breasts, Flues and Fireplaces Section of this Report.
The Roof Coverings and Underlayers section considers the condition of the outer covering of the roof. Such coverings usually endure the extremes of climate and temperatures. They are susceptible to deterioration, which ultimately leads to water penetration.
Dependent upon the age of your property and the type of construction it may or may not be present, please read on:
We will consider the roofs in three areas, the main roof, rear flat roof and front porch roof.
**Main Roof**
The main roof is pitched and clad with manmade slates, and, from ground level, this looks in below average condition considering the roof’s age type and style. We are used to seeing a manmade slate roof that is very flat which is not what you have got in this case.
**ACTION REQUIRED**: Please see our comments in the Executive Summary with regard to further investigation.
**Protective Underlayer (Often known as the sarking felt or underfelt)**
From the 1940s onwards felts were used underneath tiles/slates to stop wind damage and water penetration; these in more recent years have been replaced with plastic equivalents. These are commonly known as underfelts but now the name is not really appropriate, as felt is not the only material used.
Often an older roof will have no protective underlayer at all unless it has been re-roofed post war and then it will have a Hessian base bitumen membrane. In this case we found quite unusually a modern foil protective underlayer which does indicate along with the manmade slates that this roof has been carried out fairly recently probably in the 1970s/1980s.
This photo shows the common rafters (the ones that form the pitch of the roof) and the silver area between is the protective underlayer.
**Front Porch Roof**
The front porch roof is clad in a manmade slate with a lead flashing detail (which we were pleased to see) and is in average condition for its age, type and style.
**Flat Roofs**
Whilst these roofs are called "flat", present building regulations and good building practice presently requires a minimum fall of 12 degrees.
Flat roofs are formed in a variety of materials. Difficulties can arise when the water is not discharged from the roof but sits upon it, as this can soon lead to deterioration which flat roofs are renowned for.
The rear roof is a flat felt roof. Typically flat roofs have a fall of approximately 15°; what we can see of the flat roof it does have a reasonable fall.
What we do find is that sometimes if the rear gutters are not cleared to a large flat roof such as this which also takes the rainwater from the rear pitched roof the gutters to the rear can overflow and discharge rainwater down the walls.
A detail that we could not see which is particularly important is where the flat roof and the pitched roof meet.
**ACTION REQUIRED:** You need to check and inspect that the rainwater is not discharging down the walls next time it rains heavily.
### Roof Ventilation
The latest Building Regulations require flat roofs to be ventilated. Building Regulations are not retrospective but the reason for the requirement is to make sure that any moisture that enters the roof construction is dispelled by way of ventilation. We would suggest that if the opportunity arises ventilation should be provided. This will stop the possibility of fungal growth above the ceiling in the flat roof area.
### Roof insulation
Also it could not be established if there is insulation within the roof or a vapour barrier, without the vapour barrier and combined with inadequate ventilation there will be an increase in the risk of wet or dry rot.
All the roofs were inspected from ground level with the aid of a x16 zoom lens on a digital camera. Flat roofs have been inspected from upper floor windows and/or ground level.
Finally, we were only able to see approximately sixty percent of the main roof from ground level via our ladder or via any other vantage point that we
managed to gain. We have made our best conclusions based upon what we could see, however a closer inspection may reveal other defects.
For further comments with regard to ventilation please see the Roof Structure and Loft Section.
ROOF STRUCTURE AND LOFT
(ALSO KNOWN AS ROOF SPACE OR ATTIC SPACE)
The roof structure or framework must be built in a manner which is able to give adequate strength to carry its own weight together with that of the roof covering discussed in the previous section and any superimposed loads such as snow, wind, foot traffic etc.
Main Roof
Roof Access
The main roof is accessed via the loft hatch located landing. There is no loft ladder, electric light or secured floorboards. We recommend that these be added, as it will make the loft space safer and easier to use.
The loft (perimeter) has been viewed by torch light, which has limited our viewing slightly.
Roof Structure
This type of roof structure has what is known as a cut timber roof. This is a roof that is purpose made and hand built on site. Without the original design details we cannot categorically confirm that there are no defects; however it is in line with what we typically see.
Roof Timbers
We have inspected the roof structure for:
- Serious active woodworm
- Structurally significant defects to the timbers
- Structurally significant dry rot
- Structurally significant wet rot
Our examination was limited by the general configuration of the roof. What we could see was generally found to be in average condition for its age, type and style. It is, however, feasible that there are problems in the roof that are hidden.
**ACTION REQUIRED:** The only way to be 100 per cent certain is to have the roof cleared and checked.
Fire Walls
The property has one brick firewall which is located to the left hand side (all directions given as you face the property).
**Fire Walls Defined**
Fire walls help prevent the spread of fire through roofs and are a relatively recent Building Regulation requirement.
Ventilation
We could not see any ventilation, this would be a requirement in a modern roof.
Insulation
Please see the Thermal Efficiency Section of this Report.
Electrical Cables
We can often identify the age of an electrical installation by the age of wiring found in the roof. In this case there was insufficient quantity of wiring to comment.
Please see our further comments in the Services Section of this Report.
Finally, we would ask you to note that this is a general inspection of the roof, i.e. we have not examined every single piece of timber. We have offered a general overview of the condition and structural integrity of the area.
GUTTERS AND DOWNPIPES
The function of the gutters and downpipes is to carry rainwater from the roof to the ground keeping the main structure as dry as possible.
Defective gutters and downpipes are a common cause of dampness that can, in turn, lead to the development of rot in timbers. Regular inspection and adequate maintenance are therefore essential if serious problems are to be avoided.
Gutters and Downpipes
The property has a mixture of older cast iron and modern plastic gutters and downpipes. The condition is fairly typical of what we see; they are in average condition for their age, type and style.
Our only concern is to the rear with the large flat roof and rear pitched roof and the amount of rainwater that is discharging onto this section which may cause it to overflow, known as surcharging.
Cast iron of this age will need maintenance. If regularly maintained it last longer than plastic, in our experience.
In addition to this there may be some minor leaks but most people would be happy to live with these providing repairs are carried out within the next six to twelve months.
ACTION REQUIRED: We would recommend you stand outside the property next time it rains heavily and see how well the drains cope with the rainwater particularly looking at the guttering and the joints.
We would also recommend that the gutters and downpipes are cleaned out, the joints are checked and the alignment checked to ensure that the gutters fall towards the downpipes.
**Soil and Vent Pipe**
The soil and vent pipes are plastic.
Finally, gutters and downpipes and soil and vent pipes have been inspected from ground level.
It was raining at the time of the inspection however we did not have the opportunity to inspect if the rainwater installation is free from blockage, leakage etc. or that it is capable of coping with long periods of heavy rainfall. Our comments have therefore been based on our best assumptions.
WALLS
External walls need to perform a variety of functions. These include supporting upper floors and the roof structure, resisting dampness, providing adequate thermal and sound insulation, offering resistance to fire and being aesthetically presentable.
The walls are constructed of brickwork.
Brickwork
The property is built in a brick originally in a lime mortar in what is known as Flemish bond brickwork.
The term Flemish Bond relates to the way the bricks are bonded together and have a pattern visible from the outside of the property that shows the end of the brick (header), then the side of the brick (stretcher), then the end of the brick, then the side of the brick, and this pattern repeats course after course, i.e. header-stretcher, header-stretcher.
The solid external walls may be liable to penetrating dampness internally, dependent upon their condition and their exposure to the weather. External faces should be kept in good condition.
Before the 19th Century, the practice of building timbers into external walls was almost universal. These were known as bonding timbers. They are of course prone to rot as solid walls allow dampness through. Unfortunately, without opening up the structure, we are unable to confirm if this is the case.
Generally Flemish Bond brickwork is liable to penetrating dampness internally, dependent upon the condition of the brickwork and the exposure to the weather. In this case it is essential that external faces be kept in good condition.
**Lime Every Time (Inappropriate Cement Mortar Re-pointing - for the Age of this Property)**
We would draw your attention to the cement mortar re-pointing that has been carried out on the exterior of the property that we feel is not appropriate to this building. Originally it will have been built with a lime-based mortar and this is what should be used for any re-pointing in the future.
The use of cement mortar causes deterioration to brickwork and does lead to the face of the bricks deteriorating, which in turn leads to dampness. This is a very important point.
The property is built in a mixture of yellow stock bricks and soft red bricks; the soft red bricks in particular deteriorate due to the cement mortar pointing.
**Cavity Walls**
Cavity walls were first used in Victorian times. It originates from solid walls not always being waterproof against driving rain and not providing a good degree of heat insulation. The design of cavity walls makes them relatively unstable and they depend upon the wall ties.
Cold Bridging
This era of property is likely to have cold bridging.
There is a very large opening made for the sliding, folding doors to the rear of the property.
**ACTION REQUIRED:** Your Legal Advisor needs to check and confirm that Local Authority Approval has been obtained and there are calculations for the lintel.
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**Cold bridging defined**
Cold bridging is caused by a colder element in the structure allowing coldness to pass through the structure much quicker when warm moist air is present in the property.
Finally, the external walls have been inspected visually from ground level and/or randomly via a ladder. Where the window and door lintels are concealed by brickwork / plasterwork we cannot comment on their construction or condition. In buildings of this age timber lintels, concrete lintels, rubbed brick lintels or metal lintels are common, which can be susceptible to deterioration that is unseen, particularly if in contact with dampness.
Our comments have been based upon how the brickwork / plasterwork has been finished. We have made various assumptions based upon what we could see and how we think the brickwork / plasterwork would be if it were opened up for this age, style and type of construction. We are however aware that all is not always at it seems in the building industry and often short cuts are taken. Without opening up the structure we have no way of establishing this.
FOUNDATIONS
The foundations function is, if suitably designed and constructed, to transfer the weight of the property through the soil. As a general comment, many properties prior to the 19th Century have little or no foundations, as we think of them today, and typically a two-storey property would have one metre deep foundations.
Foundations
Given the age of the property you may find different depths of foundations. We would expect to find a stepped brick foundation.
London Clay
As with most properties in the London area, this property stands on London Clay. It is therefore more susceptible than most should drains leak or trees be allowed to overgrow etc. It is not unusual to have some settlement in London properties. However, from our inspection of the walls we have found nothing unusual.
Building Insurance Policy
You should ensure that the Building Insurance Policy contains adequate provision against any possibility of damage arising through subsidence, landslip, heave etc.
It is your responsibility to check out prior to commitment to purchase that insurance is available on the property on the basis of the things we have reported in the survey. Much as we would like to we are unable to keep up with the changing insurance market and give you advice with regard to this. Please remember to talk about any cracks identified within the property. Often insurers will refer to progressive and non-progressive cracking. Unfortunately this is something we are unable to comment upon from a one-off inspection - the Building Research Establishment recommend a year of monitoring of any cracking.
We would always recommend that you remain with the existing insurance company of the property.
We would refer you to our comments with regard to building insurance throughout this report.
Finally, we have not excavated the foundations but we have drawn conclusions from our inspection and our general knowledge of this type, age and style of property.
As no excavation has been carried out we cannot be 100 percent certain as to how the foundation has been constructed and we can only offer our best assumptions and an educated guess, which we have duly done.
Trees within influencing distance of a property can affect the foundations by affecting the moisture content of the soil.
There is a tree within what insurance companies would term influencing distance of the property.
**ACTION REQUIRED:** Your Legal Advisor to check and confirm who is liable and responsible for the tree. If it is the Local Authorities responsibility you need to ensure regular maintenance is carried out.
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**Influencing Distance Defined**
This is the distance in which a tree may be able to cause damage to the subject property. It is not quite as simple as our sketch; it depends on the tree, its maturity, the soil type etc., etc.
Finally, insurance requirements with regard to trees have varied over the years and in our opinion have got ever more onerous. We have seen the notifiable distance of a tree away from a property to have been reduced over the years.
and we reiterate our comments elsewhere within this report that you need to make enquiries with regard to the insurability of your property in relation to trees and other features when you purchase the property.
Please also refer to the External Areas Section.
DAMP PROOF COURSE
The Building Act of 1878 required a damp proof course to be added to all newly built properties within the London area. It also required various other basic standards. These requirements were gradually taken up (or should that be grudgingly taken up) throughout London and then the country as a whole, although this took many years for it to become standard practice.
All modern properties should incorporate a damp proof course (DPC) and good building practice dictates that a differential of 150mm (6 inches) should be maintained between the damp proof course and ground levels. In this case, we cannot see a DPC as it may be covered by a rendered plinth. This was the era when damp proof courses were starting to be added but does not necessarily mean you have one, they were often originally slate.
Your attention is drawn to the section of the report specifically dealing with dampness.
Finally, sometimes it is difficult for us to identify if there is a damp proof course in a property. We have made our best assumptions based upon our general knowledge of the age, type and style of this property.
AIRBRICKS
In properties with suspended floors you need to have an airflow beneath to stop deterioration. The air is allowed to pass under the property by the use of airbricks. Generally the rule of thumb is that airbricks are spaced every metre and a half approximately, but this depends upon the specific circumstances of the property.
Low Level Air Bricks
There are low level air bricks to the property which look to have been enlarged than the original brick size to double this which is good. You do however need to make sure that they are kept clean to allow and air flow underneath the building.
Air bricks are essential to have a through flow of air as this helps to reduce the chances of wet rot, dry rot and woodworm.
Finally, we have made our best assumptions based upon our visual inspection of the outside of the property and our general knowledge of this age, type and style of construction. We have not opened up the floor, unless we have specifically stated so in this section.
FASCIAS AND SOFFITS AND WINDOWS AND DOORS
This section covers fascias, soffits and bargeboards and windows and doors, and any detailing such as brick corbelling etc.
Fascias and soffits offer protection to the rafter feet and also allow the securing of the guttering. Windows primary functions are to admit light and air, but they also have thermal and sound properties. The doors allow access and egress within the property.
Fascias and Soffits
The fascias and soffits are timber. They are painted and we would comment they are in average condition for their age, type and style. It is feasible that the front area is similar to the front windows which look in good condition however when knife tested are not.
ACTION REQUIRED: When work is being carried out to the front windows also have a re-check of the fascias and soffits. Make sure gutters and downpipes are watertight before carrying out any work on fascias and soffits.
Windows and Doors
The property has single glazed timber sliding sash windows.
General Information on Sliding Sash Windows
If you have not lived in a property with sliding sash windows previously, you should be aware that typically they are draughty and rattle. There is no easy way to eliminate this problem. In our experience, a general ease and adjustment of the windows and the addition of a plastic tube draught sealer (available from most DIY stores) and regular redecoration is the best option to minimise the draughtiness of the windows in this case. Horizontal Sliding Sash Windows (sometimes known as York Windows).
Bay Windows
The property has the benefit of large bay windows to the front which allow good light into the property.
ACTION REQUIRED: We would recommend repairs to the windows are carried out during the summer of 2012.
Finally, we have carried out a general and random inspection of the external joinery. In the case of the fascias and soffits it is typically a visual inspection from ground level. With the windows and doors we have usually opened a random selection of these during the course of the survey. In this section we are aiming to give a general overview of the condition of the external joinery. Please also see the Internal Joinery section.
EXTERNAL DECORATIONS
The external decorations act as a protective coat for the building from the elements. Where this protective covering has failed, such as with flaking paintwork, the elements will infiltrate the structure. This is of particular concern as water is one of the major factors in damage to any structure.
The external decorations is mainly to the joinery and the lintel area above the window which looks to have been relatively newly carried out (painted to sell).
Finally, ideally external redecoration is recommended every four to five years dependent upon the original age of the paint, its exposure to the elements and the materials properties. Where painting takes place outside this maintenance cycle repairs should be expected. Ideally redecoration should be carried out during the better weather between mid-April and mid-September.
Please see our comments in the External Joinery section.
INTERNAL
CEILINGS, WALLS, PARTITIONS AND FINISHES
In this section we look at the finish applied to the structural elements such as the plasterwork applied to the ceiling joists, walls or partitions, together with the construction of the internal walls and partitions.
Ceilings
Where we could see the ceilings from within the roof space this property has lath and plaster ceilings however we are aware that the modern alterations have no doubt been carried out with a modern plasterboard.
Lath and Plaster Defined
Laths are thin strips of timbers which are fixed to the structure. Wet plaster is applied to the laths, usually in several layers. The plaster forms a key as it is forced between the laths. This plaster, once dry, is given further coats and often a decorative finish.
The property has some ceiling roses, whether they are original or not we are not certain but we do believe that they are a pleasant detail in the property although this is up to personal taste.
Internal Walls and Partitions
These are, we believe, a mixture of solid and studwork construction. It is of course impossible to determine the construction without opening up the walls and we have therefore taken an educated guess.
Perimeter Walls
Originally these would have been constructed with a wet plaster, possibly a lime plaster.
We believe that some of the perimeter walls have had a skim coat of modern gypsum plaster and to the rear of the property there is what is known as a dry lined wall which could be due to hiding dampness; please see our comments with regard to the flat roof and the rear of the pitched roof possibly discharging rainwater down the rear wall.
Again, we cannot be 100% certain of the wall construction without opening them up which goes beyond the scope of this report.
This comment has been based on the visual look of the wall which is relatively “smooth” and normally means a modern finish.
Finally, ceilings, walls and partitions have been inspected from floor level and no opening up has been undertaken (unless permission has been obtained by yourselves). In some cases the materials employed cannot be ascertained without samples being taken and damage being caused.
We cannot comment upon the condition of the structure hidden behind plaster, dry lining, other applied finishes, heavy furniture, fittings and kitchen units with fitted back panels.
CHIMNEY BREASTS, FLUES AND FIREPLACES
With the advent of central heating fireplaces tend to be more a feature than an essential function in most properties.
The chimney breasts are located to the right hand side in the front lounge and the left hand side of the property in the rear kitchen/dining room as well as some chimney breasts in the bedrooms (all directions given as you face the front of the property).
At the time of the survey no chimneys were in use. Any chimneys that you do not propose to use should be capped and ventilated to prevent dampness.
Finally, we will comment on the condition of the chimney breast where we can see the chimney breast. If we can see a chimney breast has been removed we will inspect for signs of movement and advise. However, often the chimney breasts are hidden so we cannot comment. Also additional support can be concealed very well when chimney breasts are hidden particularly when plastered over.
Your Legal Advisor needs to specifically check with the Local Authority for removed chimneys and associated chimney breasts and Building Regulations Approvals and advise by e-mail immediately if chimney breasts are found to have been removed. We would recommend opening up the structure to check the condition. If we are not advised we will assume the relevant Building Regulations Approval has been obtained.
It is strongly recommended that flues be cleaned and checked for obstructions prior to use to minimise the risk of hazardous fumes entering the building.
Please also see the Chimney Stacks, Flues
FLOORS
Functionally floors should be capable of withstanding appropriate loading, preventing dampness, have thermal properties and durability. In addition to this upper floors should offer support for ceilings, resistance to fire and resistance to sound transfer.
Ground Floor
The front floor of the property is a suspended timber floor which requires air movement underneath to minimise wet rot, dry rot and woodworm.
This is not exactly as the floor plan of the property but it gives a general indication of the airflow underneath the suspended timber floor.
Solid Floor
There is likely to be a solid floor to the entirety of the kitchen/dining room area. In this instance there does need to be a vent at the back of the suspended timber floor which we were unable to find.
ACTION REQUIRED: Add a vent to the back of the suspended timber floor if not present.
However, we have not opened up the floors or lifted the carpets / floor coverings.
There is a tiled floor to the entrance hallway which, in our opinion, is a pleasant feature.
**First Floor**
We have assumed that the first floor construction is joist and floorboards with embedded timbers, as this is typical in this age of property.
*Joist and Floorboard Construction Defined*
These are usually at first floor level consisting of a joist supported from the external walls, either built in or, in more modern times, sitting upon joist hangers, sometimes taking additional support from internal walls, with floorboards fixed down upon it.
Finally, we have not been able to view the actual floors themselves due to them being covered with fitted carpets, floor coverings etc. The comments we have made are based upon our experience and knowledge of this type of construction. We would emphasise that we have not opened up the floors in any way or lifted any floorboards.
DAMPNESS
In this section we look at any problems that are being caused by dampness. It is therefore essential to diagnose the source of the dampness and to treat the actual cause and not the effect of the dampness.
Rising Damp
Rising damp depends upon various components including the porosity of the structure, the supply of water and the rate of evaporation of the material, amongst other things. Rising damp can come from the ground, drawn by capillary action, to varying degrees of intensity and height into the materials above.
A random visual inspection and tests with a moisture meter have been taken to the perimeter walls and some internal walls. In this particular case we have found no rising damp.
ACTION REQUIRED: Please see the Executive Summary regarding the kitchen rear wall being dry lined.
Lateral or Penetrating Dampness
This is where water ingress occurs through the walls. This can be for various reasons such as poor pointing or wall materials or inadequate gutters and downpipes, such as poorly jointed gutters.
We used a damp meter on the external walls. We have not found minor dampness.
Condensation
This is where the humidity held within the air meets a cold surface causing condensation.
At the time of the inspection there were no obvious signs of condensation.
However, it depends upon how you utilise the building. If you do your washing and then dry it in a room without opening a window you will, of course, get condensation. Common sense is needed and a balance between heating, cooling and ventilation of properties and opening windows to air the property regularly.
Extract fans in kitchens and bathrooms
A way of helping to reduce condensation is to have good large extract fans within the kitchens and bathrooms which are moisture generating areas.
ACTION REQUIRED: We would recommend humidity controlled extract fans be added to kitchens and bathrooms.
Finally, effective testing was prevented in areas concealed by heavy furniture, fixtures such as kitchen fittings with backboards, wall tiles and wall panelling. We have not carried out tests to BRE Digest 245, but only carried out a visual inspection.
INTERNAL JOINERY
This section looks at the doors, the stairway, the skirting boards and the kitchen to give a general overview of the internal joinery’s condition.
Doors
There is a mixture of modern panelled doors and feature doors to the ground floor area.
Staircase
We were unable to examine the underside of the stair timbers due to it being lined, which precluded our inspection, so we cannot comment further upon the stair structure. We can, however, say that the lining gives a resistance to the spread of fire if such circumstances were to occur.
Kitchen
We are advised that the kitchen cost a lot of money, we do like the kitchen design and we would consider the kitchen to be in an above average condition.
We have not tested any of the kitchen appliances.
Finally, it should be noted that not all joinery has been inspected. We have viewed a random sample and visually inspected these to give a general overview of the condition. Please also see the External Joinery/Detailing section.
TIMBER DEFECTS
This section considers dry rot, wet rot and woodworm. Wet and Dry rot are species of fungi, both need moisture to develop and both can be very expensive to correct. We would also add that in our experience they are also often wrongly diagnosed.
Dry Rot
Dry rot is also sometimes known by its Latin name Serpula lacrymans. Dry rot requires constant dampness together with a warmish atmosphere and can lead to extensive decay in timber.
We would advise that we have not opened up the floors and we had a limited view of the roof.
Wet Rot
Wet rot, also known by its Latin name Contiophora puteana, is far more common than dry rot. Wet rot darkens and softens the wood and is most commonly seen in window and doorframes, where it can relatively easily be remedied. Where wet rot affects the structural timbers in a property, which are those in the roof and the floor areas, it is more serious.
We noted wet rot in the front windows and we would expect to find wet rot to the fascias and soffits. There is also a possibility that wet rot is in the suspended timber floor.
Again, we would advise that we have not opened up the floors and we had a limited view of the roof.
Woodworm
Active woodworm can cause significant damage to timber. There are a variety of woodworm that cause different levels of damage with probably the worst of the most well known being the Death Watch Beetle. Many older properties have woodworm that is no longer active, this can often be considered as part of the overall character of the property.
The roof is the main area that we look for woodworm.
Within the roof we found no obvious visual signs of woodworm activity or indeed signs of past woodworm activity that has caused what we would term ‘structurally significant’ damage. In many properties there is an element of woodworm that is not active. Our inspection is usually restricted by insulation covering some of the timbers and general stored items in the roof, as it is restricted throughout the property by general fixtures and fittings. We would comment in this instance that the main area we looked in was the roof space however it could be present in the floor; please note that we have not opened up the floors to check.
**ACTION REQUIRED:** If you wish to be 100 per cent certain that there is no woodworm the only way would be to check the property when is emptied of fixtures and fittings etc.
Finally, when you move into the property, floor surfaces should be carefully examined for any signs of insect infestation when furniture and floor coverings are removed together with stored goods. Any signs that are found should be treated to prevent it spreading. However, you need to be aware that many damp and woodworm treatment companies have a vested interest in selling their products and therefore have fairly cleverly worded quotations where they do not state if the woodworm they have found is ‘active’. You should ask them specifically if the woodworm is active or not.
We would also comment that any work carried out should have an insurance backed guarantee to ensure that if the company does not exist, or for whatever reason, the guarantee is still valid. More importantly it is essential to ensure that any work carried out is carried out correctly.
INTERNAL DECORATIONS
With paints it should be remembered that up to 1992 lead could be used within paint and prior to this most textured paints (commonly known as Artex) contained an element of asbestos up to 1984, so care should be taken if the paintwork looks old and dated.
Internal decorations are in average condition with some marks. You may wish to redecorate to your own personal taste.
Finally, we would draw your attention to the fact that removal of existing decorative finishes may cause damage to the underlying plasterwork necessitating repairs and making good prior to redecoration.
CELLARS
Cellars and vaults tend to be found in older properties and offer a useful space, although usually they are damp, unless some treatment has taken place such as the tanking of the walls, which is a lining process, or an external damp proofing membrane of some type has been added, or if internally the walls have been lined, therefore hiding the damp. Cellars are often susceptible to flooding from excessive rain, rising water table levels or even blocked drains.
The cellar/basement area of the property is very small and is accessed from the rear of the hallway on the ground floor.
**Cellar/Basement staircase**
The staircase to the cellar/basement would ideally need replacing / repair to the nosings to make safer.
**Dampness, woodworm and ventilation**
As with all cellars/basements a level of dampness should be expected.
There were no signs of dampness affecting the floor joists and floorboards or significant woodworm.
There was a vent to the right hand side brick wall (as you enter basement from the rear) which will help to keep the area damp minimal. However the basement is quite small and would benefit from adding extra ventilation.
**Alterations to cellar/basement**
Please see our earlier comments regarding damp and ventilation.
The cellar/basement area is currently used for storage (but do not store any perishable goods or items of high value), however if you choose to extend and alter the /cellar basement you may need to know that head height may need increasing which will require Local Authority Approval.
Finally, we have made a visual inspection of the cellar only and have no way of knowing what the construction is without opening up the structure.
THERMAL EFFICIENCY
Up until the mid 1940s we did not really consider insulation in properties, for example it was only in the 1960s that we started putting insulation in the roof and then it was about 50mm, in the 1970s this was upgraded to 100mm. Then we started to think about double glazing and cavity wall insulation. Since then insulation standards have increased considerably and today we are looking at typically using insulation not only in the roof but also in the walls, floors and windows and more recently considerable work has been carried out on how efficient boilers are within properties. Care has to be taken that properties are not insulated disproportionately to the ventilation as this can cause condensation and you should be aware that you need to ventilate any property that is insulated.
HIPs
We understand that HIPs were suspended from 20th May 2010. Energy Performance Certificates are required before a sale completes.
Roofs
There was approximately 200mm of insulation present in the roof, current Building Regulations requirements are of 300mm.
Walls
The walls to this property are solid in the sense that they do not have a cavity as a modern property would have. Also they are unlikely to have any substantial insulation. However, unfortunately it is generally very difficult to
improve the insulation without affecting the external or the internal appearance of the property.
**Windows**
The windows are single glazed and therefore will have poor thermal properties.
**Services**
Service records should be obtained. It is essential for the services to be regularly maintained to run efficiently.
**Summary**
Assuming the above is correct, this property is average compared with what we typically see.
Further information can be obtained with regard to energy saving via the Internet on the following pages:
*HTTP://www.est.org.uk*, which is by the *Energy Saving Trust* and includes a section on grant aid.
*or alternatively www.cat.org.uk*
*or Sustainable Energy Without the Hot Air* by David J C MacKay
*HTTP://www.withouthotair.com/Videos.html* to download for free or buy a paper copy as we did.
*It is worth watching the video How Many Light Bulbs?* by David J C MacKay
*HTTP://www.youtube.com/watch?v=UR8wRSp21Xs*
Finally, we would comment that energy we feel will become a major consideration in years to come, particularly with the greater focus in modern buildings on energy efficiency.
OTHER MATTERS
In this section we put any other matters that do not fit under our usual headings.
Security
A security system has been installed. A good alarm system should not only help reduce break-ins but also your insurance. We are not experts in this field and therefore cannot comment further.
ACTION REQUIRED: Further information should be obtained from the vendor and the installer at a later date.
Fire / Smoke Alarms
Some smoke detectors were noted. The current Building Regulations require that they be wired into the main power supply. Obviously in a property of this age this is difficult, as it would mean having surface mounted wires or cutting wiring into the plaster.
ACTION REQUIRED: We would recommend, for your own safety, that smoke detectors be installed. We would always recommend a hard wired fire alarm system and are also aware that some now work from a wireless signal which may be worth investigating. Whilst fire is relatively rare it is in a worst case scenario obviously devastating.
Insurance
We would always recommend staying with the existing insurance company, and then if there are any problems you should not have the difficulty of
negotiating with two insurance companies passing the blame between each other.
We would refer you to our comments with regard to building insurance throughout this report.
**Asbestos**
In a property of this age there may well be some asbestos.
In this case we have not noted any asbestos, it was often used on service ducts which are hidden away.
This was commonly used post war until it was banned only in the last ten or so years, although it is rumoured that it was still used after this point in time.
We are not asbestos surveyors.
**ACTION REQUIRED:** If you wish to confirm you are 100 percent free of asbestos you need to have an asbestos survey carried out.
SERVICES
This survey does not include any specialist reports on the electricity supply and circuits, heating or drainage, as they were not requested. The comments that follow are based upon a visual inspection carried out as part of the overall Building Survey.
Services and specialist installations have been visually inspected. It is impossible to examine every detail of these installations without partially dismantling the structure. Tests have not been applied. Conclusive tests can only be undertaken by suitably qualified contractors. The vendor/seller should be requested to provide copies of any service records, test certificates and, ideally, the names and addresses of the installing contractors.
ELECTRICITY
It is strange to think that electricity only started to be used in domestic properties at the turn of the 19th century with gas lighting still being the norm for a good many years after.
Periodic inspections and testing of electrical installations is important to protect your property from damage and to ensure the safety of the occupants. Guidance published by the Institute of Electrical Engineers (IEE) recommends that inspections and testing are undertaken at least every 10 years (we recommend every five years) and on change of occupancy. All electrical installation works undertaken after 1st January 2005 should be identified by an Electrical Installation Certificate.
Fuse Board
The electric fuses and consumer units were located under the stairs. The fuse board looked newish and better are now available.
Earth Test
We carried out an earth test in the kitchen area to the socket point that is normally used for the kettle, this proved satisfactory.
ACTION REQUIRED: As the property is changing occupancy an Institute of Electrical Engineers (IEE) test and report should be carried out by a NICEIC registered and approved electrical contractor or equivalent.
In addition to this your Legal Advisor is required to make full enquires with the owners to establish if any electrical installation work has been
carried out and to provide suitable certification for any works carried out after 1st January 2005. Any comments made within this report or verbally do not change this requirement.
For basic general information on this matter please see the appendices at the end of this report.
There is very little we can check for in a gas installation, we do inspect to make sure there is one and that it has a consumer unit and that the boilers are vented. Ideally you should have a service inspection carried out by an independent Gas Safe registered plumber.
We are advised that the property has mains gas.
All gas appliances, pipework and flues should be the subject of an annual service by a competent engineer, i.e., a member of Gas Safe; works to gas appliances etc., by unqualified personnel is illegal. Unless evidence can be provided to confirm that there has been annual servicing we would recommend that you commission such a service prior to use to ensure safe and efficient operation.
**ACTION REQUIRED:** As a matter of course it is recommended that the entire gas installation is inspected and made good, as necessary, by a Gas Safe registered contractor. Thereafter the installation should be serviced annually.
PLUMBING AND HEATING
In this section we do our best from a visual inspection to look at how the water is supplied to the property, how the supply is distributed around the property, how it is used to heat the property and how it is discharged from the property.
Water Supply
The controlling stopcock was not located.
It is important that its presence is established in case of bursts or leaks. The stopcock and other controlling valves have not been inspected or tested for operational effectiveness.
ACTION REQUIRED: Ask the owners to show you where it is.
Water Pressure
When the taps were run to carry out the drainage test we checked the pressure literally by putting a finger over the tap and this seemed average. The Water Board have to guarantee a certain pressure of water to ensure that things like boilers, particularly the instantaneous ones have a constant supply of pressurised water (they would blow up if they didn’t!).
Cold Water Cistern
We have not found a water tank. We can only assume that the water is directly fed to the taps. The original idea behind a water tank was to help water pressure and to give an emergency supply of water.
Plumbing
The plumbing, where visible, comprises copper piping. No significant leakage was noted on the surface, although most of the pipework is concealed in floors, walls and ducts.
Heating
The wall mounted boiler was located in the utilities room, it is manufactured by Worcester.
Our limited inspection of the hot water and central heating system revealed no evidence to suggest any serious defects but we would nevertheless recommend that the system be tested and overhauled before exchange of contracts and that a regular maintenance contract be placed with an approved heating engineer.
Ten Minute Heating Test
There was no owner at the property; the house was pleasantly warm during the course of our survey.
Finally, it should be noted that the supply pipe from the Water Company stopcock to the internal stop tap is the responsibility of the property owner.
We cannot comment on the condition of the water service pipe to the building. It should be appreciated that leaks can occur for some time before signs are apparent on the surface.
BATHROOM
In this section we consider the overall condition of the sanitary fittings such as the bathroom, the kitchen, the utility room and the cloakroom.
**Bathroom**
The property has a four piece bathroom suite, consisting of a bath, wash hand basin and WC, which looks to be relatively recent.
**WC**
The property has a downstairs WC located in the utilities area.
Finally, although we may have already mentioned it above we would reiterate that it is important to ensure that seals are properly made and maintained at the junctions between wall surfaces and baths and showers etc. We normally recommend that it is one of the first jobs that you carry out as part of your DIY on the property, as water getting behind sanitary fittings can lead to unseen deterioration that can be costly, inconvenient and difficult to repair.
MAIN DRAINS
The sanitary system, as we know it now, came into being some 100 years ago during the Victorian era and works so successfully today it is often taken for granted. It is only in recent years that re-investment has taken place to upgrade the original drainage systems.
It is assumed that the foul drains from the property discharge into a public sewer; this should be confirmed by your Legal Advisor prior to exchange of contracts, who should also provide information in respect of any common or shared drains including liability for the maintenance and upkeep of the same.
The cold taps have been run for approximately quarter of an hour in the bathroom and kitchen. No build up or back up was noted.
Inspection Chambers / Manholes
For your information, inspection chambers / manholes are required to be provided in the current Building Regulations at each change of direction or where drainage runs join the main run.
We have identified two inspection chambers / manholes.
Manholes Defined
Access areas which usually fit a man (or woman) into them and are put in where the drains change direction.
Inspection Chamber / Manhole One front garden
The manhole was inspected to the front of the property using our 15 minute tap test (running water for 15 minutes). No obvious problems were seen. Water was free flowing.
Inspection Chamber / Manhole Two (rear garden)
At the time of our survey we were unable to lift and inspect manhole two. The manholes are not possible to lift without specialist lifting gear.
Finally, it must be emphasised that the condition of the property’s foul drains can only be ascertained by the carrying out of a test; such a test has not been undertaken. Should there be leaks in the vicinity of the building then problems could occur, particularly with respect to the stability of the building’s foundations. Drainage repairs are inevitably costly and may result in damage being caused to those areas of the property beneath, or adjacent to, which the drains have been run.
Rainwater/Surface Water Drainage
Whilst very innocent looking rainwater downpipes can cause lots of problems. If they discharge directly onto the ground they can affect the foundations and even if they are taken away to soak-aways they can attract nearby tree roots or again affect foundations.
Some rainwater drains are taken into the main drainage system, which is now illegal (as we simply do not have the capacity to cope with it), and can cause blockages to the main drains! Here we have done our best from a visual inspection to advise of any particular problems.
We have been unable to determine the ultimate means of rain/surface water disposal.
In this age of property it is likely to be into shared drains. These can be a problem during heavy rainfall and peak periods, such as the 9 o’clock rush to work.
Finally, rain/surface water drains have not been tested and their condition or effectiveness is not known. Similarly, the adequacy of soak-aways has not been established although you are advised that they tend to silt up and become less effective with time.
Please also see our comments within the Gutters and Downpipes section.
OUTSIDE AREAS
The main focus of this report has been on the main building. If you wish us to do a specific report on the other buildings then you need to instruct us for this separately. We are offering here a brief overview.
PARKING
Parking is on the roadside parking on a first come first serve permit basis, there always seems to be a number of traffic wardens in the area!
EXTERNAL AREAS
Front Garden
The property has a small front garden.
Rear Garden
The garden to the rear of the property is paved and is fairly small sized.
Boundaries: The left hand boundary (all directions given as you face the property) is usually the responsibility of the subject property.
Finally, whilst we note the boundaries, these may not be the legal boundaries. Your Legal Advisor should make further enquiries on this point and advise you of your potential liability with regard to any shared structures, boundary walls and fences.
Neighbours
Left and Right Hand Neighbours
When we knocked the left and the right hand side neighbours at the time of our survey no one was in.
POINTS FOR YOUR LEGAL ADVISOR
If you wish to proceed with your purchase of the property a copy of this report should be forwarded to your Legal Advisor and the following points should be checked by him/her:
a) Responsibility for boundaries.
b) Rights for you to enter onto the adjacent property to maintain any structure situated near or on the boundary and any similar rights your neighbour may have to enter onto your property.
c) Obtain any certificates, guarantees or approvals in relation to:
i) Timber treatments, wet or dry rot infestations.
ii) Rising damp treatments.
iii) Double glazing or replacement windows.
iv) Roof and similar renewals.
v) Central heating installation.
vi) Planning and Building Regulation Approvals.
vii) Removal of any walls in part or whole.
viii) Removal of any chimneys in part or whole.
ix) Any other matters pertinent to the property.
d) Confirm that there are no defects in the legal Title in respect of the property and all rights associated therewith, e.g., access.
e) Rights of Way e.g., access, easements and wayleaves.
f) Liabilities in connection with shared services.
g) Adjoining roads and services.
h) Road Schemes/Road Widening.
i) General development proposals in the locality.
j) Conservation Area, Listed Building, Tree Preservation Orders or any other Designated Planning Area.
k) Confirm from enquiries that no underground tunnels, wells, sewers, gases, mining, minerals, site reclamation/contamination etc., exist, have existed or are likely to exist beneath the curtilage of the site upon which the property stands and which could affect the quiet enjoyment, safety or stability of the property, outbuildings or surrounding areas.
l) Our Report assumes that the site has not been put to contaminative use and no investigations have been made in this respect.
m) Any outstanding Party Wall Notice or the knowledge that any are about to be served.
n) Most Legal advisors will recommend an Envirosearch or a similar product is used by you to establish whether the area falls within a flood plain, old landfill site, radon area etc. If your Legal Advisor is not aware of Envirosearch or similar please ensure that they contact us and we will advise them of it. Any general findings should be brought to their logical conclusion by using appropriate specialist advisers.
However, with regard to Envirosearch or similar general reports please see our article link on the www.1stAssociated.co.uk Home Page.
o) Any other matters brought to your attention within this report.
**LOCAL AUTHORITY ENQUIRIES**
Your Legal Advisor should carry out Local Authority searches to ascertain whether the property is a Listed Building and whether it is situated in a Conservation Area. They should also find out any information available with regard to Planning Applications and Building Control. We have not made any formal or informal Local Authority enquiries.
Finally, your Legal Advisor should carry out any additional enquiries they feel necessary and if they find anything unusual or onerous then we ask that they contact us immediately for our further comments.
It is our policy not to offer a conclusion to ensure that the Building Survey is read in full and the comments are taken in context.
If you would like any further advice on any of the issues discussed (or indeed any that have not been discussed!) then please do not hesitate to contact us on
REFERENCES
The repair and maintenance of houses
Published by Estates Gazette Limited
Life expectancies of building components
Published by Royal Institution of Chartered Surveyors and Building Research Establishment
Surveying buildings
By Malcolm Hollis published by Royal Institution of Chartered Surveyors Books.
House Builders Bible
By Mark Brinkley, Published by Burlington Press
LIMITATIONS
Our limitations are as the agreed Terms and Conditions of Engagement.
CONDITIONS OF ENGAGEMENT
The report has been prepared in accordance with our Conditions of Engagement dated XXXX and should be regarded as a comment on the overall condition of the property and the quality of its structure and not as an inventory of every single defect. It relates to those parts of the property that were reasonably and safely accessible at the time of the inspection, but you should be aware that defects can subsequently develop particularly if you do not follow the recommendations.
ENGLISH LAW
We would remind you that this report should not be published or reproduced in any way without the surveyor’s expressed permission and is governed by English Law and any dispute arising there from shall be adjudicated upon only by the English Courts.
SOLE USE
This report is for the sole use of the named Client and is confidential to the Client and his professional advisors. Any other persons rely on the Report at their own risk.
ONLY HUMAN!
Although we are pointing out the obvious, our Surveyors obviously can’t see through walls, floors, heavy furniture, fixed kitchen units etc. they have therefore made their best assumptions in these areas.
As this is a one off inspection, we cannot guarantee that there are no other defects than those mentioned in the report and also that defects can subsequently develop.
WEATHER
It was sunshine and showers at the time of the inspection. The weather did hamper the survey slightly as we would normally have attempted to climb onto the flat roof at the rear via the roof windows.
In recent times our weather seems to be moving towards the extremities from its usual relatively mid range. Extremes of weather can affect the property.
NOT LOCAL
It should be noted that we are not local surveyors to this area and are carrying out the work without the benefits of local knowledge on such things as soil conditions, aeroplane flight paths, and common defects in materials used in the area etc.
OCCUPIED PROPERTY
The property was occupied at the time of our survey, which meant that there were various difficulties when carrying out the survey such as stored items within cupboards, the loft space and obviously day-to-day household goods throughout the property. We have, however, done our best to work around these.
INSPECTION LIMITED
Unfortunately in this instance our inspection has been very limited as we did not have full access to the roof and as we were not able to open up the ground floor or the first floor.
We did not have the benefit of talking to the owners or them answering our usual question and answers and we didn’t have the benefit of meeting you at the property to talk about your specific requirements which we always find helpful to explain any issues.
BUILDING INSURANCE
We do not advise with regard to building insurance. You need to make your own enquiries. Some areas may have a premium, some buildings may have a premium and some insurers may be unwilling to insure at all in certain areas. You need to make your own enquires prior to committing to purchase the property. Please be aware the fact a building is currently insured does not mean it can be re insured.
We would comment that non-insurability of a building we feel will affect value. It is therefore essential to make your own enquiries with regard to insurance before committing to purchase the property and incurring fees.
ACTION REQUIRED: You need to contact an insurance company today to make enquiries with regard to insurance on this property.
TERMS AND CONDITIONS
Our computer system sends two copies of our Terms and Conditions to the email address given to us when booking the survey; one has the terms attached and the other has links to the Terms and Conditions on our website (for a limited time). If you have not received these please phone your contact immediately.
APPENDICES
1. The electrical regulations – Part P of the Building Regulations
2. Information on the Property Market
3. Condensation and Cold Bridging Article
THE ELECTRICAL REGULATIONS – PART P OF THE BUILDING REGULATIONS
Here is our quick guide to the Regulations, but please take further advice from a qualified and experienced electrician.
From 1st January 2005, people carrying out electrical work in homes and gardens in England and Wales must follow new rules in the building regulations. All significant electrical work carried out in the home will have to be undertaken by a registered installer or be approved and certified by the local authority’s building control department. Failure to do so will be a legal offence and could result in a fine. Non-certified work could also put your household insurance policy at risk.
If you can't provide evidence that any electrical installation work complies with the new regulations, you could have problems when it comes to selling the property.
There will be two ways in which to prove compliance:
1. A certificate showing the work has been done by a Government-approved electrical installer - British Gas or NICEIC Electrical Contractor.
2. A certificate from the local authority saying that the installation has approval under the building regulations.
Homeowners will still be able to do some minor electrical jobs themselves. To help you, we've put together this brief list of dos and don'ts.
**Work You Cannot do Yourself**
- Complete new or rewiring jobs.
- Fuse box changes.
- Adding lighting points to an existing circuit in a 'special location' like the kitchen, bathroom or garden.
- Installing electrical earth connections to pipework and metalwork.
- Adding a new circuit.
INFORMATION ON THE PROPERTY MARKET
We used to include within our reports articles on the property market that we thought would be of interest and informative to you, however we were concerned that in some cases these did not offer the latest information. We have therefore decided to recommend various websites to you, however it is important to realise the vested interest the parties may have and the limits to the information.
www.landreg.org.uk
This records the ownership of interests in registered land in England and Wales and issues a residential property price report quarterly, which is free of charge. The Land Registry is a Government body and records all transactions as far as we are aware, although critics of it would argue that the information is often many months out of date.
www.rics.org.uk
The Royal Institution of Chartered Surveyors offer quarterly reports via their members. Although this has been criticised as being subjective and also limited, historically their predictions have been found to be reasonably accurate.
www.halifax.co.uk and www.nationwide.co.uk
Surveys have been carried out by these two companies, one now a bank and the other a building society for many years. Information from these surveys is often carried in the national press. It should be remembered that the surveys only relate to mortgaged properties, of which it is generally considered represents only 75% of the market. It should also be remembered that the national coverage of the two companies differs and that they may be offering various incentives on different mortgages, which may taint the quality of information offered. That said they do try to adjust for this, the success or otherwise of this is hard to establish.
www.hometrack.co.uk
This gives information with regard to house sale and purchase prices.
www.motleyfool.co.uk
We also like the Motley Fool website which is a general financial site and although it is selling financial services and other services they do tend to give a very readable view of the housing market.
www.rightmove.co.uk
This is probably the largest Internet search engine for estate agency sales and also has useful information with regard to prices of property (but it is not the same as having a chartered surveyor value it).
www.zoopla.co.uk
This is a very good website for seeing the prices of properties for sale in a certain postcode area.
Condensation and Cold Bridging – What is Cold Bridging?
What is cold bridging and does it always cause condensation?
We often find cold bridging on certain types of property which unfortunately means that condensation is more likely. Cold bridging is caused by a colder element in the structure allowing coldness to pass through the structure much quicker when warm moist air is present in the property, often caused by things like having a shower or a bath, cooking or washing, particularly if you are drying washing on the radiators. This is also caused by the general climate which results in condensation on the element.
Certain types of buildings are more susceptible to condensation and cold bridging
You often see condensation in properties, for example on a mirror in a bathroom when you have had a shower or a bath. Cold bridging is far worse than condensation as it is caused by an element in the structure which you can do very little to change without great expense.
Typically this will be a lintel. Problems can occur with concrete lintels that were commonly used in the 1970’s, and also in more modern, better insulated properties, cold bridging has been known to occur on metal lintels. The problem is what to do about it.
Example of a concrete lintel – can you notice where the cold bridging would be in this photo? A close up view of the concrete lintel
When is Cold Bridging Most Likely?
In our experience cold bridging is most likely on properties built in the 1930’s to 1980’s, most commonly in the 1970’s. This is the era when we were just starting to think about insulation and we added insulation into our structures for example with cavity wall insulation or double glazed windows. This meant they were warmer which in effect has meant the significance of a lintel over a door or window being colder and allowing the transfer of coldness becomes much more important. This results in condensation that we commonly see above windows in this age and era of property.
So what can you do about Cold Bridging?
The difficulty is resolving cold bridging. Normally where condensation is involved if you get the balance of warm and coolness of the air, the air ventilation and movement you can reduce considerably the chances of condensation. Airing the room which seems to have gone out of fashion where you literally open the windows in the morning to air the room is a big step forward.
Where do we most commonly see cold bridging?
We would answer this in two ways. Firstly, we see as mentioned cold bridging is common in 1970’s houses. It’s also more common to various other factors.
The main other factor is large families or families with young children where there is a lot of washing going on and often during the winter months this washing is then dried on radiators. This is generally known as the lifestyle of the occupants.
Expert witness cases
We have seen some terrible examples of this. We have been involved in several court cases as expert witnesses where landlords are being taken to court over the condensation being caused by cold bridging. The discussions that then take place in court with us as expert witnesses are, is it a design characteristic or is it a lifestyle characteristic that is causing problems.
Is Cold Bridging a design problem?
We have been involved in many reports on condensation and cold bridging and some legal cases where we have been asked to act as expert witness. Really it’s down to the design of the property. There are cold elements in it such as a concrete frame or concrete lintels. You have a disadvantage although, not impossible to stop the condensation it’s very hard. It could also be argued that where cold bridging is occurring in a modern property you are getting interstitial condensation which is condensation within the structure which you literally can’t see.
Do lifestyle issues cause condensation?
By lifestyle issues we mean the way the building is being used. We have come across quite a few instances where it is how the property is being used that’s causing the problems. This may be due to showers being taken without extractor fans being put on or it may be due to clothes being dried internally, particularly during the winter months. It could be steamy kitchens. Some things can be helped by airing the home by opening the windows and in bathrooms and kitchens you can have extractor fans that are controlled by humidity controls on the fans. So it really is an individual answer in most cases to the problems with the property.
|
Law Enforcement Suicide: Prevention, Intervention and Postvention
Elizabeth K. White, Ph.D.
Law Enforcement Suicide: Prevention, Intervention and Postvention
- Introduction to Suicide
- Prevention
- Intervention
- Postvention
- In Conclusion
Introduction to Suicide
Introduction to Suicide
- Suicide in General
- Law Enforcement Suicide
- Suicide and Sexual Orientation
Introduction to Suicide
Suicide in General
- One suicide every 16.7 minutes
- 11th ranking cause of death in USA
- ~787,000 annual attempts
- 31,484 completed suicides in 2003
- Each suicide significantly impacts six other people!
Is Law Enforcement Suicide an “Epidemic” or a Terrible Tragedy?
Who is a member of law enforcement?
- Sworn peace officers
- Custody officers
- Reserve officers?
- Parole officers?
- Retired officers?
- Security officers?
Introduction to Suicide
Law Enforcement Suicide
Concerning Police
Survivors: We went out and spoke to 10 agencies and 4 responded!
Among survivors, members of police who had committed suicide
Introduction to Suicide
Law Enforcement Suicide
Confounding Variables
17% of Police Suicides Missclassified
Violanti, 1996
Introduction to Suicide
Estimated Law Enforcement Suicide Rates
- Aamodt & Stalknaker (2001) – 18.1 / 100,000
- Loo (2003) – 22.99 / 100,000
- Compion (2001) – 18.1 / 100,000
Introduction to Suicide
Law Enforcement Suicide
Suicide Rate Comparison?
Suicide Rate per 100,000 People
National Rate: 10.8
Law Enforcement: 18.1
CDC WISQARS Data 2003
Introduction to Suicide
Law Enforcement Suicide
Suicide Rate Comparison
Suicide Rate per 100,000 People
2003
- National Rate: 10.8
- Males: 17.6
- White Males: 19.5
- Military: 11.1
- Law Enforcement: 18.1
Military Suicide Rates 1990-2004
Rates/100K
CY-91 92 93 94 95 96 97 98 99 00 01 02 03 04
Navy Marine Corps Air Force Army Coast Guard
Los Angeles County Sheriff's Department
| 2006 | Male | Female | White | Black | Hisp | Asian |
|------|------|--------|-------|-------|------|-------|
| LASD | 84% | 16% | 52% | 10% | 32% | 4.2% |
| LAPD | 81% | 19% | 42% | 13% | 37% | 6% |
“A peace officer is twice as likely to die by his or her own hand than by the hand of a suspect!”
Introduction to Suicide
Law Enforcement Suicide
Suicide/Homicide Ratio
General Population Males, Aged 21-65
CDC WISQARS Data 2003
3.6:1
1.8:1
Having a firearm in the home increases your risk for suicide five fold!
Firearm suicide attempts result in death in approximately 85% of cases.
Introduction to Suicide
Law Enforcement Suicide
Confounding Variables
LAW ENFORCEMENT SUICIDE BY FIREARM
- Australia: 79%
- Chicago: 95%
- Ireland: 94%
- NYPD: 94%
- Canada: 70%
- Wyoming: 100%
- LE Average: 86%
- General Population: 54%
The risk of suicide in alcoholics is 50-70% higher than the general population.
Introduction to Suicide
Law Enforcement Suicide
Confounding Variables
ALCOHOL AND LAW ENFORCEMENT
- Quebec: 78%
- Ireland: 51%
- Australia: 50%
- Detroit: 42%
- NYPD: 16%
- LAPD: 60%
- Canada: 17%
- Chicago: 60%
Percentages of law enforcement suicides involving alcohol
Introduction to Suicide
Law Enforcement Suicide
Confounding Variables
Suicide by State per 100,000
- Wyoming: 21.8
- Nevada: 19.4
- Florida: 13.5
- USA: 10.8
- California: 9.6
- Massachusetts: 6.7
- New York: 6.1
Introduction to Suicide
Law Enforcement Suicide
Confounding Variables
Health Problems and Law Enforcement Suicide
Gaska, 1980
Introduction to Suicide
Suicide & Sexual Orientation
- Research Difficulties
- Youth Studies
- Adult Studies
Research Difficulties
- Are you GLBTI?
- After the Fact
- Attempts vs. Completions
- Compared to What?
- Is it Because I am GLBTI?
Introduction to Suicide
Suicide and Sexual Orientation
Youth Suicide Attempts
Bell & Weinberg, 1978
to age 20
Attempts: Completion ratio estimated at
Male: Female Attempt ratio estimated at 1:3
Introduction to Suicide
Suicide and Sexual Orientation
Suicide Completions
2003 CDC Data
Per 100,000
- White: Males = 19.5, Females = 4.70
- Black: Males = 8.8, Females = 1.80
- Hispanic: Both = 5.0
- Asian/PI: Both = 5.5
Males
Females
Both
Introduction to Suicide
Suicide and Sexual Orientation
GLB Youth Suicide
GLB Massachusetts/Vermont Attempts 1995/1997
- Serious Attempt
Robin et al 2003
GLB Youth Suicide Attempts
Youth 9-14%
GM Remafedi 1991: 30%
D'Augelli, et al 2005: 33%
Massachusetts 2001: 31%
Garofalo 1998: 36%
Bradford/Caitland 1988: 24%
Introduction to Suicide
Suicide and Sexual Orientation
GLB Youth Suicide
Contributing Reason
- Family Problems: 44%
- Sex Orientation: 33%
- Depression: 30%
- Peer Conflict: 22%
- Substance Abuse: 15%
- Romance: 11%
Remafedi, et al 1991
Introduction to Suicide
Suicide and Sexual Orientation
Adult Suicide Attempts
GLB Adults Reporting Suicide Attempt
Attempts: Completion ratio estimated at
Introduction to Suicide
Suicide and Sexual Orientation
Special Populations
Gender Non-conforming Males: 47%
Transgender: 37%
Law Enforcement Suicide: Prevention, Intervention and Postvention
Prevention
Designing a Prevention Program
Obtaining “Buy In”
Designing a Prevention Program
- Screening
- Education
- Tracking “at risk” personnel
- Critical incident intervention
- Resources/Referral
Prevention
Designing a Prevention Program
Screening
- Pre-employment Psychological Screening
- High Risk Assignment Screening
- Special Weapons
- Undercover
- Arson/Explosives
Preventative Education
- Academy
- Supervisors
- Field Training Officers
- AOT
Tracking “At Risk” Personnel
- Divorced/Separated
- Bereaved
- Injured/III
- Under Investigation
- Substance Use Problem
- Approaching Retirement
Critical Incident Intervention
- Officer Involved Shootings
- Serious Threat to Life
- Secondary Traumatization Incidents
Available Resources
- Law Enforcement Mental Health Professionals (MHP)
- Peer Support Program
- Chaplains’ Program
- Self-Help Programs
- Peace Officer’s Fellowship
Referral Systems
- Supervisor Referrals
- Settlement Agreements
Obtaining “Buy In”
- “Top Down” backing
- Saturation outreach
- Making it stick
Prevention
Obtaining “Buy In”
“Top Down” Backing
- Backing of upper managers
- Initial materials cost
- Training time coverage
- Non-punitive/help orientation
- “Personal touch” roll out to middle managers
“Saturation” Outreach
- Preview presentation/training to peer support personnel & chaplains
- Availability of materials through computer as well as briefing/training
- Incorporation of video into all existing trainings - where appropriate
Making it Stick
- Easy to understand
- Easy to remember
- Remove impediments
Officer Needs Assistance!
Will YOU Roll Backup?
Cops do not hesitate to protect fellow officers when a suspect is threatening them - even if it puts their own life at risk.
But what if the person threatening your colleague’s life is him or herself?
If you think a co-worker is contemplating SUICIDE, will you take action? Will you have the courage to “roll backup?”
Employee Support Services Bureau (ESSB)
(213) 738-3500
SUICIDE PREVENTION
A Guide For Supervisory Staff
Employee Support Services Bureau (ESSB)
(213) 738-3500
OUR JOURNEY TO GROUND ZERO
BY SERGEANT JOHN BASILIS
My partner, Sergeant Dennis Peraia, and I went to New York on September 10th, 2001 for a conference we had set up in north Manhattan. I personally went there with my own opinions about New York, especially after the attacks on the Twin Towers.
At the conference, we were seated with educators and business executives from around the world. We were all in the same room, and we were all watching the news coverage of the attacks on the Twin Towers, seated in a comfortable banquet room with ample food and drink. The news coverage was interrupted by a commercial, while also watching them on a 20-foot high video screen. We were at times bombarded with images of the towers collapsing, and at other times we were shown the rescue workers at work.
Suddenly, the speaker was interrupted and the news coverage of the Twin Towers was replaced by the news coverage of the Pentagon and the Twin Towers.
It was a beautiful day and our lives were forever changed. My partner and I watched with our jaws open. We could not believe what was occurring. Images of the towers collapsing were shown again and again. When one of the towers came tumbling down, I blurted out “Cops and firemen are dead!”
Continued on page 8
True Patriots
One year ago, our nation endured one of the greatest tragedies ever witnessed. The events of that day afterward left us dealing with 9/11’s lasting effects. We are still embracing countries tales of courage and heroism.
Today, real American heroes can be found in our own law enforcement family. The Los Angeles County Sheriff’s Department reported that 15 of its employees have joined the U.S. Army and Air Force, and 13 have joined the military, doing their part to defend our nation.
Among those on Active Duty are the following L.A. County Sheriffs’ Deputies:
We thank them for their resolve and for their undying American spirit.
| Name | Rank |
|--------------------|---------------|
| Samuel Alvarez | Deputy |
| Kenneth Brinkley | Deputy |
| Gregory Cervantes | Deputy |
| John Calvillo | Deputy |
| James Chacon | Deputy |
| Saul Castillo-Ramos| Security Officer |
| Robert Collier | Deputy |
| Carlos Girard | Deputy |
| Michael Hensley | Deputy |
| Gaylord Inoua | Sergeant |
| Jose Jimenez | Sergeant |
| Paul Kawai | Sergeant |
| Brian Kowalski | Deputy |
| Kevin Leibovitz | Deputy |
| Joseph Lopez | Deputy |
| Thomas McManus | Security Officer |
| Christopher Plantz | Deputy |
| Larry Rios | Deputy |
| John Tomlinson | Security Officer |
| Mark Van Leer | Deputy Assistant |
Proudly Representing Los Angeles County Employees:
- Department of the Coroner
- District Attorney’s Office
- Office of Public Safety
- Sheriff’s Department
More than 4,700 Members Strong
The average starting police salary in Los Angeles County is $37,662 in 2002. This is a 1% increase over last year. It is not surprising that salary actually declined during the recession, but it is disappointing, but not surprising.
Put Your House in Order
Security Officer Issues
Heroes Honored
Wanted for Murder
AID LIFE
A **Ask**. Do not be afraid to ask, “Are you thinking about hurting yourself?” or “Are you thinking about suicide?”
I **Intervene immediately**. Take action. Listen and let the person know he or she is not alone.
D **Don’t keep it a secret.**
L **Locate help**. Seek out a professional at ESSB, peer support person, chaplain, friend, family member or supervisor.
I **Involve Command**. Supervisors can secure immediate and long term assistance.
F **Find someone to stay with the person now**. Don’t leave the person alone.
E **Expedite**. Get help now. An at-risk person needs immediate attention from professionals.
**Things To Do**
*Consider the following if you’re with a suicidal individual (and not necessarily in this order):*
1. Ask permission to secure weapon(s), including backup(s)
2. Immediately contact ESSB
3. Identify someone who can provide on-scene support
4. **Do Not** leave person alone
5. Assess if your safety is in jeopardy
6. Assist individual with meeting responsibilities until situation is stabilized
**WHEN THE CRISIS HAS STABILIZED, GET DEBRIEFED FOR YOUR OWN PEACE OF MIND!!!!!!**
Prevention
Obtaining “Buy In”
“Rolling Backup”
Law Enforcement Suicide: Prevention, Intervention and Postvention
Intervention
Dynamics of Suicide
Law Enforcement Complications
So What Do I Do?
Intervention
Dynamics of Suicide
- Myths & Reality
- Risk Factors
- Precipitants
Intervention
Dynamics of Suicide – Myth
Suicidal people want to die!
Suicidal people want a way out of intolerable pain. Some part of them wants to live if you can help them find a way to do it!
Do People Communicate Suicidal Intent?
- Warning: 80%
- No Warning: 20%
If someone really wants to die, you can’t take them out of it.
Suicidal feelings are often impulsive and temporary!
Asking somebody if they are suicidal will push them over the edge or they will lie anyway.
You CANNOT give somebody the idea of committing suicide.
Many people want help and will be relieved to tell you the truth!
A person who is suicidal will not normally recover!
Peace officers are resilient. Once they get help, they often recover and go on with their lives!
A cop who is seen suicidal can kiss his or her career goodbye!
NECESSARY AND SUFFICIENT INTERVENTION
Intervention
Dynamics of Suicide – Reality
Necessary and Sufficient Intervention
- Involuntary Hospitalization
- Voluntary Hospitalization
- Medication
- Counseling
- Peer/Family Support
“Real cops” don’t feel
“Real cops” solve their own problems
I am not a “ding”
Only Crazy People Go to Psychologists
Only Really Crazy People Take “Meds”
What about my career?
Don’t get somebody in trouble
So What Do I Do?
- What Should I Know?
- Signs & Symptoms
- Asking the Questions
- SAFER Model
- Pushing on the Scale
- Some Do’s & Don’t
Intervention
So What Should I Know?
- Understand the dynamics of suicide
- Know the myths vs. realities
- Know the signs & symptoms
- Know what to do if you suspect somebody may be suicidal
- Know about available resources
- Make a commitment to “Roll Backup”
Intervention
Signs & Symptoms
Risk Factors
- **Sex** (male)
- **Age** (15-34) (*also 65+*)
- **Depression**
- **Previous exposure to suicide**
- **Ethanol/alcohol/drug abuse**
- **Rational thinking loss**
- **Social support system lacking**
- **Organized plan**
- **No spouse or significant other**
- **Sickness/Injury**
Precipitating Events
- Witness to violence
- Victim of crime
- Sexuality concerns
- Failed promotion/specialty assignment
- Work problems/discipline
- Financial problems
- Substance abuse
- Physical abuse
- Sexual abuse/assault
- Legal problems/arrest
- Suicide of loved one
- Death of loved one
- Serious family illness
- Loss of health
- Divorce/separation
- Loss of employment
- Loss of cherished possessions
- Retirement
Courtesy of Daniel Clark, Ph.D.
I’m going to kill myself
I wish I were dead
You’d be better off without me
I might as well be dead
If …doesn’t happen, I’m going to end it
I’m going to commit suicide
Intervention
Signs & Symptoms – Indirect Verbal Clues
I can’t go on any longer
We all have to say goodbye sometime
Nobody needs me anymore
You won’t be seeing me any more
Life has lost meaning for me
You’d be better off without me
I can’t take the pain
You’re going to regret how you treated me
Cash in my chips
I’m taking the plunge
I’m tired of life
I can’t take it any more
Eat my gun
Fold my hand
Intervention
Signs & Symptoms - Behavioral Clues
- Buying a weapon
- Giving away possessions
- Making a will
- Taking unusual risks
- Changes in personality
- The “practice run”
- Sudden religious interest/disinterest
- Substance abuse relapse
HIGH risk clues
- History of a suicide attempt (40%)
- Family/friend suicide attempts/completions
- Substance use
- Plan is specific and well defined
- Plan is viable
- Lethality of method
Intervention
Signs & Symptoms – Precipitating factors
Law Enforcement Rationale for Suicide
- Relationship: 35%
- Unknown: 32%
- Psychological: 23%
- Work stress: 12%
- Financial: 10%
- Critical Incident: 7%
- Alcohol Abuse: 5%
Aamodt 2001
Intervention
Signs & Symptoms – Precipitating factors
NYPD 1985-1999 Rationale for Suicide
O’Neill 2001
Increase in Risk for Suicide Attempt
Marital Problem: 4.8x
Suspension: 6.7x
Both: 21.7x
Janik & Kravitz 1994
Have you been thinking of hurting or killing yourself?
Intervention
Any other questions?
Have you been thinking of hurting or killing yourself?
➔ When did you last think about suicide?
➔ How would you kill yourself?
➔ Do you have the means available?
➔ Have you ever attempted suicide?
➔ Has anyone in your family attempted/completed suicide?
➔ What are the odds that you will kill yourself?
➔ What has been keeping you alive so far?
Intervention
SAFER Revised Model
- **Stabilize the Situation**
- Mitigate affective escalation.
- Remove from provocative stressors.
- May use a diversion (i.e. walk, coffee, etc.).
- **Acknowledge the Crisis**
- What happened?
- Establish rapport and a sense of safety.
- Provide for cathartic ventilation.
- **Facilitate Understanding**
- Explain the symptoms.
- Normalize reactions.
Courtesy of Daniel Clark, Ph.D.
Intervention
SAFER Revised Model
Encourage Effective Coping Techniques
- Teach basic stress survival skills.
- Improve immediate and short term coping.
- Develop a plan for immediate use.
Recovery or Referral
- Assess current adaptive functioning.
- Assess need for further assistance.
- If needed, identify appropriate referral.
Courtesy of Daniel Clark, Ph.D.
Pushing on the Scale – Factors Towards Suicide
Intervention
#4
#3
#2
#1
Pain Hopelessness Alcohol Plan Precipitant
Pushing on the Scale – Factors Against Suicide
- Time
- Sleep
- Social Supports/Obligations
- Spirituality*
- Sobriety
Intervention
Pushing on the Scale – Final Equation
- Time/Sleep
- Social Support
- Spirituality
- Sobriety
- Counseling
#4: Pain, Hopelessness, Alcohol, Plan, Precipitant
#3: Pain, Hopelessness, Alcohol, Plan, Precipitant
#2: Pain, Hopelessness, Alcohol, Plan, Precipitant
#1: Pain, Hopelessness, Alcohol, Plan, Precipitant
0 20 40 60 80 100 120 140
Pain Hopelessness Alcohol Plan Precipitant
Intervention “Do List”
- Remain calm
- Take all suicidal comments/behaviors seriously
- Listen, listen, listen
- Help define the problem
- Rephrase thoughts/feelings
Intervention “Do List”
- Focus on central issue/ prioritize
- Identify preventative forces
- Capitalize on old strengths
- Identify options
- Explore resources
Intervention “Don’t List”
- Don’t sound shocked
- Don’t deny/minimize the threat
- Don’t offer empty promises
- Don’t debate morality
- Don’t leave the person alone
- Don’t be the only person helping
Postvention
Survivors
How Can I Help?
Impact on Your Agency
Postvention
Suicide Survivors
Friends, family and colleagues who survive following the death of a loved one by suicide
- 31,484 suicides per year
- 6 survivors per suicide
- 188,904 suicide survivors per year
Postvention
Suicide Survivors – How is suicide different?
- Often compromises usual mourning rituals
- Typically not pathological but often complicated:
- Leaves “unfinished business”
- Often leaves a violent death scene
- Scene is a “crime scene”
- Media involvement
- Expect a 4-7 year recovery period
- Disrupts normal functioning for an extended period of time
Survivor Reactions
- Denial of the death as a suicide
- Preoccupation with “why”
- Guilt/Responsibility
- Religious concerns
- Extreme anger, abandonment feelings
- Complications from others:
- Blaming the survivor
- Condemning the loved one
- Awkwardness from social support
- Social isolation
Understand that…
- Grief is a process not an event
- Each person grieves at a different rate and in a different way
- You do not “get over” grief, but you can be “in recovery”
- Repetition is part of recovery
Help by…
- Listening, listening, listening
- Non-judgmental
- Don’t answer questions you don’t know the answer to!
- Normalize feelings—even negative ones
- Share the memories
As time goes by…
- Memorials
- Special dates
- Keeping in contact
- Self-help/support groups
- Grief counseling
- Be aware of follow up suicides
Postvention
How Can I Help?
Helpful phrases
😊 I’m sorry for your loss…
😊 How can I help?
😊 Is there anyone I can call for you?
😊 What is the most difficult part for you?
😊 When you are ready, I would like to share my memories of _________
😊 You don’t have to deal with everything right away.
Phrases to avoid
😢 How can you bear that ________ went to hell…
😢 You are young enough to find somebody new.
😢 Get over it.
😢 Didn’t you see this coming?
😢 At least he is no longer suffering.
😢 Don’t think bad of her.
😢 I know how you feel.
😢 Time heals all wounds
Courtesy of Daniel Clark, Ph.D.
Support is out there…
- Survivors of Suicide
http://www.survivorsofsuicide.com
- Concerns of Police Survivors
http://www.nationalcops.org
- Compassionate Friends (children)
http://www.compassionatefriends.org
- Survivors of Law Enforcement Suicide
http://www.tearsofacop.com
- Family & Friends of Suicide
http://www.friendsandfamiliesofsuicide.com
“Effective postvention for suicidally bereaved families may be one of the most important forms of multigenerational prevention available to mental health professionals.”
Postvention
- Impact on Your Agency
- "Postvention Team"
- Target Group Interventions
- Funeral Considerations
- Agency Actions That Help
Who is impacted …?
Based on law enforcement suicide rates, an agency the size of the LASD can expect to have 1-2 suicides a year.
Greater impact on law enforcement…
- Increased sense of responsibility
- Increased cohesion increases loss
- Increased sense of personal identification
- Increased media attention due to profession of law enforcement
- May have had to handle the scene
Some of the ways this impact appears…
- Attendance problems
- Decreased work quality and quantity
- Increased alcohol consumption
- Increased number of injuries/accidents
- Negative impact on interactions between supervisor, coworkers, citizens and inmates
- Reminders will reactivate grief
Suicide Policy?
All suicides are not created equal!
A Postvention Team consists of…
- Unit commander/Chief
- Human resources representative
- Psychologist (preferably who rolled)
- Family representative
- Peer support/CISM leader
- Chaplain (preferably who rolled)
- Risk management/Legal representative
- Line staff representative
Team responsibilities…
- Death notification
- Internal announcements
- Media statement
- Cleaning out the locker
- Cleaning the scene
- Funeral/memorial planning
- CISM
- Monitor for ongoing/delayed reactions
Target Group Interventions – Family…
- On scene (or hospital) crisis intervention
- Death notification
- Chaplain assistance
- Funeral assistance
- Peer support
- Grief counseling
- Referrals
Helping Your Agency Recover
Target Group Interventions – Line Staff…
- On scene (or hospital) crisis intervention
- Death notifications
- Chaplain assistance
- Individual/group CISM
- Peer support
- Grief counseling
- Referrals
Target Group Interventions—Supervisors…
- On scene (or hospital) crisis intervention
- Chaplain assistance
- Individual/group CISM
- Peer support
- Grief counseling
- Referrals
- Follow up training
The FORGOTTEN Ones…
- Medical assistance providers
- Transportation providers
- Dispatchers
- Crime scene personnel
- Homicide investigators
- Partners/Former partners
- Training officers
- Crisis negotiators
Postvention
Helping Your Agency Recover
Funeral Considerations…
- Flag ceremony
- 21 gun salute
- Bagpipes
- Honor guard
- “Brass” attendance
- Attendance (off duty, on duty, assisted)
- Uniform/Non-uniform
- Official/organized assistance to family
- Official/organized financial
Agency Actions That Aid in Postvention…
- Confidential counseling available to all
- Employees’ aware of resources
- Decrease stigma of seeking help
- Postvention Team
- Policy/procedure in place
- Emergency activation system in place
- Personnel, and their roles, identified
In Conclusion
Conclusion
- Summary
- Additional Resources
- Questions
Make a personal commitment to "Roll Backup"
In Summary
Additional Resources
- American Foundation of Suicide Prevention http://www.afsp.org
- American Association of Suicidology http://www.suicidology.org
- Daniel Clark, Ph.D. http://www.criticalconcepts.org
- SAMHSA Suicide Prevention http://www.mentalhealth.samhsa.gov
- Center for Disease Control http://www.cdc.gov
In Conclusion
Questions???
Elizabeth K. White, Ph.D.
LASD-ESSB
4700 Ramona Blvd.
Monterey Park, CA 91754-2169
firstname.lastname@example.org
(661) 272-8880
|
Dehns Consulting
Contents
Introduction
Dehns Consulting: Page 1
IP Strategy
Building a portfolio that meets business aims: Page 6
Portfolio Review
Managing a portfolio over its lifetime: Page 10
Analytics and Investigation
Leveraging IP data to gain commercial insights and make smarter decisions: Page 12
Investment and Capital Raising
Getting your IP straight ahead of seeking funds: Page 16
Information Control
Protecting the flow of sensitive and business-critical knowledge: Page 20
Valuation
Evaluating your IP portfolio in financial terms: Page 24
Due Diligence
Helping you to make informed decisions regarding IP before major events: Page 28
Licensing and Collaboration
Preparing and reviewing agreements before engaging with third parties: Page 34
Workshops and Packages
Working closely with you to provide you with the key IP expertise you need: Page 38
About Dehns
A leading European firm of specialist patent and trade mark attorneys: Page 42
Introduction: Dehns Consulting
Here at Dehns, we’ve been doing a little R&D of our own and we’ve decided to do things a bit differently. Based on the collective knowledge that Dehns has built up over the last 100 years, Dehns Consulting is our dedicated IP consultancy service that provides expert insights to help leverage IP for a wide range of commercial goals.
Dehns is one of Europe’s largest and most reputable firms of Patent and Trade Mark Attorneys. As well as being leading experts in core intellectual property matters, for example relating to obtaining valuable patent and trade mark protection, our team is renowned for being able to see the ‘big picture’ and apply their insights to broader commercial contexts.
Across our team, we have expertise in all types of technology, ranging from semiconductors to genetic engineering. We also have a wealth of experience in brands and trade marks. Having worked with clients ranging from individuals all the way through to global Fortune 500 companies, the Dehns Consulting team is familiar with advising clients of all sizes regarding key strategic decisions from an IP perspective.
Importantly, Dehns Consulting casts aside the legal jargon and will speak to you in real terms that are easy to understand. We provide practical, pragmatic and commercial advice that you can apply immediately to your business and your business objectives.
Discover how these services will be able to add genuine value to your business and give you the commercial advantage you need.
What is it?
Dehns Consulting is our unique offering of intellectual property (IP) consultancy services that aims to provide tailored strategic advice to help make critical business decisions.
1. **Innovate** - Develop new ideas and solutions to address challenges.
2. **Collaborate** - Work together with others to achieve common goals.
3. **Evaluate** - Assess the effectiveness of your efforts and make adjustments as needed.
4. **Launch** - Implement your plan and monitor its progress.
5. **Sustain** - Continuously improve and adapt to changing circumstances.
We can help you
‘whether you are big...’
As a company grows, so too does the number of considerations that need to be taken into account. Perhaps you are looking to grow the business in a new direction and need help investigating the landscape before making a large investment. Alternatively, you may have spent years building up a large portfolio of IP rights and want to take a step back and assess whether there are areas of the portfolio that need strengthening through new filings, or that are no longer relevant to your business objectives and so can be cut back so that the budget can be re-invested wisely.
We can also help with analytical insights and valuations. Whether you are interested in gathering intelligence on competitors and their IP, or whether you would like to get an evaluation of your portfolio’s current value for a shareholder report, we can help you.
We understand that these types of projects can be large undertakings, and so diverting in-house resources to these activities is not always feasible. We can put together a team with the right experience and skills to carry these out for you.
‘... or small.’
Whether you are a Pre-Seed or Series A start-up or an established SME, it is critically important that small businesses have plans in place to safeguard their IP and to assess the potential impact of existing third party IP rights. It is never too early to put these plans in place, and the risks from not having given proper consideration to IP can be high. We can work with you to formulate your IP strategy and to make sure you have a good handle on IP issues relevant to your business.
We know that investors will almost inevitably want an overview of your current IP situation, what rights you have, and what your plans are for deriving value and protecting your innovations, both those that are already developed and those that are in the development pipeline.
We appreciate that the world of IP is complex, and is often seen as impenetrable to start-ups that are running with lean-yet-agile business models. At Dehns, we have worked with a huge number of start-ups, and have helped them grow and flourish, safe in the knowledge that one of their most important assets is fully protected.
Our Services: IP and Beyond
Making IP work for you
The following pages provide an overview of the services we offer and which are tailored to help businesses like yours to make decisions and to manage their IP effectively. However, even if your exact situation does not appear to be covered by the examples given, get in touch for a no-obligation discussion so we can explore how we can help you.
The team is made up of five people, each with their own unique strengths and skills. They work together to achieve common goals and objectives, and they are committed to providing excellent customer service. The team is also highly motivated and dedicated to their work, which helps them to deliver high-quality results.
An IP strategy is simply a plan to build and protect an IP portfolio and to leverage the maximum possible value from the IP assets within that portfolio. However, the most important aspect of the plan is to make sure that it is completely consistent with the company's business goals and objectives.
We always make sure that we take the time to get to know you and understand your business, your journey, and your commercial objectives. In this way, we can help you make the best and most informed IP-related decisions for you and your business.
Through our Dehns Consulting offer, we help businesses like yours every day with the creation, implementation and review of bespoke IP strategies which are right for each individual organisation and its specific goals.
We can help and support with key aspects of IP strategy, including:
- **Innovation Harvesting**: We look at your overall R&D activities to see what innovations might have been/are being created. We can also advise you regarding best practice techniques and processes you can use to ensure the IP you generate is properly identified going forward.
- **Innovation Capture**: We can help you to put processes in place for effectively detailing your innovations for further review, both in-house and with a member of our team, e.g. for later discussions around how to protect the IP.
- **Planning an IP Roadmap**: We work with you to divide your product ideas into core elements (e.g. the key functions, aesthetic details, and branding) and advise you regarding how best to protect each of these elements.
- **Brand/Trade mark audit**: We review your website(s), social media and marketing materials (e.g. brochures, catalogues etc.) alongside your existing trade mark portfolio, if appropriate, to identify any potential gaps in your protection, and advise on appropriate clearance searching/filing strategies.
- **Strategy Review**: If you already have an IP portfolio, however large or small, we can undertake a thorough review of your current IP strategy in light of your commercial goals and then advise regarding potential enhancements to your strategy.
In essence, we take a holistic view of your overall R&D activities, then drill down into the details to identify and capture patentable ideas, before finally creating an optimal plan on what to do with each idea. In this way, we work with you to create an IP strategy that’s right for your business and corporate objectives.
We also work with you to ensure that the other aspects of your IP are well protected, for example by ensuring your brand identity is adequately protected through trade marks, and exploring whether registered designs may be applicable to any aesthetic elements of your products. The IP strategy that we formulate with you will also cover aspects of your IP that are not to be protected through a registered right – for example those elements that it may be better to protect through trade secrets, unregistered design rights, and/or copyright (where applicable) instead.
Case Study
airMont AS
Background
airMont AS is a small Norwegian start-up that provides digital services directed to improving air quality. Dehns has worked with airMont since their inception, advising on matters relating to IP and innovation management.
Issue
airMont had been very busy brainstorming a large number of ideas for a potential product, and were aware that they were generating IP but needed help deciding what to do with the various ideas they had come up with. With a finite budget and limited timescales, it was important to them to have an IP Strategy in place to ensure resources were spent wisely.
What we did
Dehns IP Consultant Sam Cleary was asked to provide a workshop to airMont to work through their various ideas in order to meet their commercial goals. After hearing more about airMont, their commercial goals, and their target markets, the team worked through each of airMont’s innovations in turn, and Sam helped to tease out the various underlying ideas into individual components and mapped these components to the commercial goals.
With an idea in mind of the major commercial milestones such as when airMont’s first product is due to launch, when further funding may be sought, and when R&D phases are planned for, Sam plotted out an IP Roadmap that planned out when patent filings should be made and for which particular ideas. The IP Roadmap shows a timeline of when airMont have major decision points, both in terms of deadlines relating to the patent filings (such as decisions regarding international coverage) but also commercial milestones that may impact those decisions.
Outcome/result
A core patent family has been filed directed to key aspects of a minimum viable product and that will also be used to cover potential future products, which will also benefit from further patent filings that are planned for the coming years. The IP Roadmap is designed to take commercial milestones into account, such that wherever possible, decisions relating to airMont’s IP portfolio are timed to occur after significant events that influence that decision.
Dehns has also advised airMont in relation to the acquisition of third party IP to help support their commercial objectives, which has expanded the portfolio to include some key related technologies, helping airMont to achieve their commercial goal of providing a range of digital services relating to air quality.
Due to the blend of IP and commercial expertise Dehns can provide, airMont are able to make sure that their IP budget is spent in an informed way, with each filing being carefully planned out such that ideas still being developed are kept confidential and ensuring that the business is in the best place commercially to make decisions in the future.
Portfolio Review
This key aspect of our IP consultancy service involves examining your entire IP portfolio in detail and providing recommendations regarding how to manage that portfolio going forward in accordance with your own commercial circumstances.
For example, if you are about to enter a new capital raising round, a portfolio review will enable you to see if there are any weaknesses in your portfolio which might put a potential investor off. With our experience of the fund-raising process, our team can identify any weaknesses beforehand and provide guidance to rectify and strengthen the portfolio, thereby making your company a more attractive investment.
We can help and support with key aspects of managing your IP portfolio, including:
- **Product mapping**: Matching the current IP portfolio to products/product range to give a better idea of where strengths and weaknesses are.
- **Roadmaps**: Planning out a timeline for the portfolio and any upcoming commercial events (for example, priority deadlines, national phase deadlines, product launches, product trials, etc.) to identify where key IP decisions need to be made and what those decisions should be.
- **Budget planning**: Helping to make budgetary decisions, for example by culling obsolete IP to recycle funds toward newer IP.
Dehns Consulting has access to a large number of local and global IP data sources, including sophisticated tools developed in-house, which can help provide the information you need to make informed, effective and ultimately successful business decisions based on data rather than on gut instinct alone.
We do this by firstly understanding your business objectives, your IP and your immediate concerns, and then using our data sources to find the relevant information needed to address your concerns. Then, through analysis of the data and any further investigations, we create a bespoke report providing you with the information you need to enable your organisation to make the most well-informed decision possible.
The results of the investigations may help you decide on target markets, to steer marketing plans, to identify potential licensees for your IP, or for many other applications.
Examples of how we use our expertise in this field include:
- **Landscaping**: We are highly skilled and experienced at using various techniques to gain a high-level overview of the IP ‘landscape’, e.g. to look for trends and to identify where there might be some ‘white space’ in the market.
- **Competitor investigations**: We work to establish what your competitors are doing and what their IP strategy is: what technology are they filing patent applications for, where are they filing those applications, how successful is a competitor at getting patents granted, etc.
- **Data-driven insights**: We use data to uncover filing trends, identify key players in the market and their activities, and draw meaningful conclusions backed by that data.
- **Trade Mark Screening and Clearance/Freedom to Use Searching**: We offer trade mark screening solutions designed to assess a trade mark’s viability and eliminate potential conflicts as quickly and easily as possible. We also offer a wide range of more in-depth search solutions/packages, giving access to the comprehensive information needed to assess the availability of a particular trade mark/brand name trade mark for use and registration.
- **Creative Name Generation and Brand Analysis**: We have access to tools that automate the process of brainstorming new names, whilst simultaneously analysing their suitability and availability for use, enabling you to make informed decisions about the potential usability of a proposed trade mark/brand name, quickly and efficiently.
Case Study
FTO advice – patent landscaping
Background
This client is a rapidly growing UK based pharmaceutical and medical device manufacturer. They specialise in bringing to market a range of quality, cost effective products that meet the challenges of modern day healthcare delivery.
Issue
The client was looking to launch a generic drug into the market. The main challenge faced by the client was that the patent landscape is often very difficult to assess. They needed expert advice on their freedom to operate so they contacted Dehns.
What we did
Following a detailed discussion on the exact requirements, Dehns commissioned a search to obtain a picture of the relevant patent landscape. The search yielded a large number of results, which would give the initial impression that there would be no freedom to operate with regard to the desired product due to the prevalence of existing patents already in this field. However, the Dehns team analysed the results to determine whether any of them would be a serious concern. Through our patent expertise, combined with scientific understanding of the relevant products, Dehns was able to determine the scope of protection afforded by the various patents and to assess the potential scope of protection that would be likely to result from key pending applications.
Outcome/result
Through this detailed analysis, expertise and understanding, Dehns was able to identify a niche in which the client would be able to operate without any key freedom to operate concerns. We were also able to advise on strategies that the client should avoid. Thus, Dehns was able to provide the client with a valuable report that could pave the way for the launch of their generic drug.
The road to the forest is winding and narrow, with trees on both sides.
Investment & Capital Raising
Whether you still have a high burn rate or you are financially stable, one of the most important issues for start-ups is funding. When it’s time to approach potential investors asking for investment, you will certainly need to have your IP portfolio in prime condition, as this is one of the first things they will want to look at, especially if technology is the main part of your business.
We can make sure that your IP portfolio is in the best possible shape for close examination and scrutiny by the investor or their advisors (which may include patent attorneys!).
Having worked on both sides of the fence, advising both investors and start-ups down the years, we know what investors are looking for in an IP portfolio and can help make sure your portfolio is investment ready.
We can also help with formal investment pitches and can support you when preparing the relevant sections in grant and funding applications. It is common for funding applications to fail because start-ups don’t spend enough time on the IP section, or enough time getting their IP portfolio in order beforehand, and we can help try to mitigate the risk of this happening.
We can help with:
- **Portfolio Review**: We will work through the portfolio to ensure it’s ‘investment ready’ (e.g. that robust patent or trade mark applications have been filed in the right place at the right time, and that proper precautions have been taken to ensure the investor will be comfortable to invest in you. If we identify any problem areas, we can help to resolve these where possible to improve your prospects.
- **Pitch Clinic**: Helping with pitches for capital raises (e.g. when applying for grants or approaching investors) to make sure the IP side is optimally covered to give you the best chance of securing the investment/funding, and to make sure you know the right answers for the questions that will likely be asked of you.
Case Study
Funding application support
Background
Dehns has been working with this particular University Technology Transfer Office for almost 10 years.
Issue
The TTO had submitted an application for funding for one of their projects but it was initially rejected because they had overlooked the importance of their intellectual property. The IP section of their funding application was deemed inadequate so they asked for our help.
What we did
Dehns offered valuable support by taking on the entire intellectual property section of the project to help demonstrate to the funding body that the client had taken the issues seriously.
We worked out a searching strategy to include patentability and appropriate territorial searches for freedom to operate. These were very different searches which required us to use our understanding of the technology and possible competing techniques.
Although we were working to a tight timescale and a set budget, once we had the results of the searches we were able to analyse them fully and prepare a report that was in a format they could use directly in their grant application. Our attorneys made sure the final report gave substantive and comprehensive advice but also considered the end user by making sure it was written for consideration by non-legal professionals.
Outcome/result
Dehns produced a report that was ready to be dropped into the client’s final application, thereby taking the pressure off them and enabling them to concentrate on other sections. The client completely trusted us to take on this section of their funding document, and all in a short time frame.
"...the final report gave substantive and comprehensive advice..."
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While much focus is often given to ‘harder’ forms of IP protection such as patents, trade marks, and registered designs, an often overlooked area of IP lies in trade secrets and know-how. These ‘softer’ forms of IP can be just as valuable (and in some cases, more valuable) than registered rights. However, it is important not to be complacent about these forms of IP simply because there is no registration involved – the control of information can be key to protecting the IP at the heart of your business.
Information Control relates to the important issues around confidentiality: who knows what about your innovation; what you should and shouldn’t disclose; when and how you should disclose any information should you need to do so; etc.
Failure to control information in the correct way could have a major impact on your ability to legally obtain protection for your innovation, product, design or trade mark, opening up your exposure to copycats and knock-offs.
Our advice here relates to:
- Advising on trade secrets and proper marking of information, and information ‘silo-ing’
- Non-disclosure Agreements (NDAs)
Case Study
Keeping things a trade secret
Background
A small UK-based start-up focussed on providing cloud-based analytics services contacted Dehns IP Consultant Sam Cleary about an idea that they had been working on in relation to a software product that used AI algorithms to improve their customer’s sales and marketing processes.
Issue
The software product designed by the start-up had a lot of potential to disrupt the market as it was able to harness AI to analyse a number of large data sets in a very short amount of time and to provide recommendations regarding how marketing resources should be spent to obtain a maximum return-on-investment.
The client recognised that IP was at the heart of their business, but did not know how best to protect the idea and originally came to Dehns seeking help with filing a patent. The client’s key concern was preventing copycat products from appearing in the market.
“Dehns advised that keeping the details of the algorithm as a trade secret was a more effective way of preventing copycats”
What we did
After Sam spent some time reviewing the overall structure of the system and the algorithms being used, he determined that while the idea had strong potential as a business plan, seeking patent protection would likely lead to a refusal on the grounds that the idea sought to solve a commercial business problem, rather than a technical one, where the AI algorithms being used were known from wider academia but had been optimised in a way particularly well-suited to analysing financial forecasts and customer behavioural data.
Sam advised that even if a patent were obtained, it would be difficult to detect infringement and ultimately enforce due to the algorithms being executed on a remote, cloud-based server.
In view of the high likelihood of refusal of any patent application and the amount of know-how behind the choice and optimisation of the AI algorithms providing a sufficiently high barrier to entry for competitors, Dehns advised that keeping the details of the algorithm as a trade secret was a more effective way of preventing copycats, particularly as any patent application detailing the algorithms would publish, regardless of whether grant could ultimately be secured.
Dehns advised the client regarding internal processes that should be put in place to ensure that key elements of the system would be recognised as trade secrets.
Outcome/result
Internal processes are now implemented within the client’s business to specifically identify innovations regardless of whether patent protection will be sought. Once identified, a procedure outlined by Dehns is followed in order to properly identify and mark commercially sensitive work products as trade secrets, and to silo access to authorised personnel only.
Valuation
Knowing the value of your IP assets can help you understand your business better which will therefore help on a whole range of strategic business decisions and options. This includes:
Raising finance
- Whilst mainstream lenders haven’t traditionally appreciated the value of IP, there are many other sources of finance that do, particularly equity funders of all shapes and sizes.
- The UK IPO’s ‘Banking on IP’ report confirmed that business angels are always interested in the role of IP in freedom to operate and barriers to entry, as are venture capital companies.
- Specialist forms of lending like venture debt, pension-led funding and asset-based finance also take key intangible assets into account.
- Having a realistic idea of IP value provides an excellent ‘conversation starter’ for negotiation, especially for high growth companies who may be reinvesting profits and thereby understating their true worth.
Portfolio assessment
- Effective international IP protection strategies usually don’t come cheap.
- Understandably, boards and shareholders have a strong interest in ensuring that IP rights represent value for money, but to assess this, they need to be able to make decisions based on future potential not just current performance.
- Valuation helps to show that properly protected IP is a value-producing asset, not a sunk cost.
- In addition, benchmarking value across different elements of a portfolio enables better-informed decisions to be made about prioritisation, where this is necessary.
Planning an exit
- Companies are generally acquired in order to gain control over their intangible assets, not their fixed ones.
- Also, where a company is acquired, international reporting standards require the buyer to take a view on what identifiable non-physical assets that business owns, and how much value should be placed on them.
- In both cases, value is very much on the minds of both seller and buyer.
- An impartial indication of the value that might reasonably be placed on these assets can prove to be a valuable negotiating tool.
We work with IP Valuation specialist companies who create a bespoke report for you and your business. Dehns can then discuss the report and its implications with you, and then guide and support you through any action you may want to take on the back of the report.
Case Study
IP portfolio valuation for internal purposes
Background
After many years of working with Dehns, a medium-sized Norwegian technology company requested a valuation of the entire IP portfolio to present to shareholders and to help inform decisions being made by the board.
Issue
After a decade of working alongside Dehns to build an impressive patent portfolio, it was decided that it was time to take stock of the financial value reflected by the client’s IP. As the years had passed, some elements of the portfolio related to product lines that had been dropped, while other patents had stood the test of time and were still core to products many years after the initial patent filing.
In order to help gauge what the client had achieved with their IP spend, the board had requested a review of the portfolio to determine the value of the patents and to help guide decision-making and budgets in the near future.
"...the client was provided with a robust valuation for the entire IP portfolio..."
What we did
Dehns Partner Adrian Samuels and IP Consultant Sam Cleary agreed that in light of the patent portfolio having been developed by Dehns, it would be best if the valuation itself came from an independent third party. Using Dehns’ extensive network of trusted partners with relevant expertise, Adrian and Sam worked closely with an expert in patent valuation that they knew would provide reliable valuation advice.
While the numerical valuation itself was carried out by an external consultant independent of Dehns, Adrian and Sam were a key part of the valuation process, helping the valuation expert to understand the large patent portfolio and how each of the patent families mapped to the client’s various product lines.
Outcome/result
The client and Dehns were able to put together a team that each brought relevant expertise to help with the valuation project. The client was able to supply commercial information relating to sales history and forecast as well as details relating to the company’s finances, while Dehns were able to provide insights into the relative value of each of the patent families and which technology groups they each belonged to.
Due to Dehns’ network of experts and the unparalleled insights into the client’s portfolio that the team had from working closely with the client for many years, the client was provided with a robust valuation for the entire IP portfolio that also gave an indication of the relative values of each of the patent families so that informed portfolio management decisions can be made.
Due Diligence
In terms of IP, due diligence activities generally involve an in-depth review of the IP owned, and/or used, by a company. It can therefore be a significant determining factor in whether to purchase or invest in a company, particularly one which has a significant number of IP assets at its disposal.
Dehns has considerable experience in carrying out due diligence exercises as part of potential investments or corporate transactions and can work with other professional advisors in devising comprehensive yet cost-effective strategies.
Examples of occasions when Dehns has been asked to undertake a due diligence exercise include:
- Potential investors looking to invest in a start-up
- A start-up looking to impress an investor
- Merger and acquisition (M&A)
- Initial Public Offering (IPO)
- Licensing Agreement
Case Study
Due Diligence prior to M&A transaction
Background
EQT is a leading alternative investments firm with approximately EUR 40 billion worth of assets under management across 20 active global funds. EQT funds have 141 portfolio companies with 159,000 employees, generating c. EUR 27 billion in total revenues.
In 2016, Dehns partner Matt Hall was contacted by Oslo law firm Thommessen on behalf of EQT when EQT was looking to acquire Norway based company AutoStore AS, who have developed a unique automated warehouse storage and retrieval system with, at the time, more than 130 installations in 22 countries.
Issue
EQT required Dehns to carry out due diligence on AutoStore’s portfolio and address any issues surrounding the strength of the IP portfolio and Freedom to Operate over third party IP rights, as well as advising on a dispute involving UK online grocery retailer, Ocado. This was particularly challenging because of the sheer volume of work required for assessment of AutoStore’s 27 patent families that it had at the time, as well as numerous patent families owned by Ocado and other third parties that required review in connection with FTO. It was crucial that Dehns made sure EQT fully understood the IP portfolio and any problems in relation to AutoStore’s IP position.
What we did
Working alongside the Dehns engineering team and with Dehns partner Adam Taylor, Matt was able to mobilise multiple attorneys and trainees in order to arrange for Dehns to absorb a vast amount of work in a short space of time, so that EQT had all of the answers they needed to go ahead with the acquisition process within their required timeframe. Dehns worked closely with EQT and Thommessen throughout the whole process so that they had a full appreciation of the strengths and weaknesses of AutoStore’s IP position, as well as potential future issues. The advice from Dehns was used to enhance EQT’s assessment of the value of AutoStore based on the strength of their IP portfolio, which is vital for transactions of this nature.
Outcome/result
EQT was successful in acquiring AutoStore with a deal that fully satisfied both parties. AutoStore was impressed with the work carried out by Dehns in connection with the EQT transaction and they have continued to consult Matt in relation to on-going IP matters to augment the work done by AutoStore’s Norwegian patent attorneys.
From the time of the acquisition in 2017 to June 2019, AutoStore experienced exponential growth, with quadrupled revenues, a 4.5 EBITDA increase and a doubling of the employee base. This growth was in part due to Autostore broadening its market through new R&D patentable innovations – assisted, of course, by Dehns.
In June 2019, just two and a half years after completing the acquisition, EQT sold Autostore for a significant amount (c.3-4 times) more than it paid in 2017.
Autostore continues to go from strength to strength: it now has more than 500 installations in over 30 countries, and it’s patent portfolio, under the continued guidance of Matt Hall, has now grown to over 150 patent families.
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Case Study
Helping an SME win investment
Background
Dehns first started working with this renewable chemicals company in 2006. The company was founded in 2003 to develop and commercialise advanced microbial technology for the production of renewable chemicals and biofuels. Dehns Partner and patent attorney Philip Webber drafted and filed their first patent applications.
Issue
Several years later a potential investor was conducting due diligence in the company and wanted to review the IP held within the company to ascertain the strength and scope of the various patents and pending applications. The investor arranged a telephone conference with the company’s founder and CEO, which was attended by the investor, the investor’s patent attorney and Dehns attorney Philip Webber.
What we did
The investor’s patent attorney performed in depth due diligence of the company’s patent portfolio. At the meeting, Philip was able to defend the portfolio and reassure the investor’s patent attorney and the investor that all of the issues raised were fully covered, and that the patents offered the best possible protection to the various technologies owned by the company.
Outcome/result
In this case, the investor was persuaded by the company's patents and technology, and subsequently over US$40 million in total equity investment over a number of rounds from this and co-investors was provided.
"...the investor was persuaded by the strength of the patents..."
In many collaborations or relationships, particularly those based on technology, the treatment and management of any IP is absolutely critical to success. Our detailed, practical knowledge of how IP works allows us to give invaluable support in the negotiation of licences and other agreements.
From an initial Non-Disclosure Agreement (NDA) through to Memoranda of Understanding (MoU), joint development agreements, licences and assignments, we can assist and advise at every step to ensure that your best interests are protected, not only when everything goes as planned, but also when the unexpected arises.
For smaller clients and start-ups, this often means dealing with the ‘standard’ agreements provided by larger companies, which may not always be appropriate to the circumstances, so we can help with your understanding of these and, where required, can suggest amendments so an agreement is more relevant to you and your business. In all circumstances, we will always advise you with your best interests and your commercial objectives as the primary drivers.
Key services include:
- Helping with licence agreements or collaboration agreements
- Helping to find partners and licensees (e.g. through landscaping techniques)
- Assisting with obtaining licences from third parties
Case Study
Advising a UK SME on a licence agreement with a US company
Background
Ketonex offers the custom design and synthesis of high performance engineering thermoplastics for additive layer manufacturing (ALM) techniques. All their products are based on the polyetherketone platform, and Ketonex provides services such as: polymer design, synthesis and characterisation, polymer processing, composites design and manufacture, and the applications and commercialisation of related technologies.
Dehns has worked with Ketonex for seven years when we first filed a patent application on their behalf back in 2009. Dehns has also helped Ketonex with four patent families based on high performance thermoplastics.
Issue
Ketonex had been approached by a US company who wanted to use the Ketonex technology that had been patented (though Dehns) in the US. The US company had drafted a terms of agreement for a licence to use the technology, and which had been sent to Ketonex.
Ketonex approached us to review the document and provide advice.
What we did
Once we received the draft licence agreement, it was reviewed by Dehns Senior Associate Sara de Bresser, who noticed that there were several issues relating to financial compensation, royalties and payments which were outside Dehns’ core capabilities, so she instructed a solicitor’s firm to deal with that aspect.
On the technical IP side, Sara advised on the scope of the technology, the geographic scope of where could and couldn’t be covered by the Agreement, in addition to various activities that were covered under the US patent that would impact the Licence Agreement.
An unforeseen issue that Sara uncovered during this process was that Ketonex already had a prior agreement in place with another US company which allowed them exclusive use of certain aspects of the technology behind the process to create polymers.
As a result of this pre-existing agreement, Sara advised on the potential conflicts and issues that potentially offering two organisations exclusive rights would generate.
Having advised the client on these matters, including the addition of the financial elements of the agreement, Sara drafted and issued a revised version of the licence agreement.
Outcome/result
The draft was submitted by Ketonex to the US company in June 2016, and, having been accepted, the Licence Agreement is now in effect between the two companies.
Case Study
Developing a licencing strategy
Background
Camurus AB is a Swedish research-based pharmaceutical and biotechnology company specialising in the commercialisation of innovative specialty medicines for treating serious and chronic diseases, where there are clear medical needs and potential to significantly improve treatment.
Dehns Partner, Chris Goddard, began working with Camurus as a Dehns trainee in 2001. He has been Camurus’ primary contact at Dehns since 2003 and their principal patent counsel for more than a decade. In nearly 20 years working together, Dehns has drafted and filed in excess of 400 granted and pending patents and patent applications internationally for Camurus.
Issue
Camurus focuses on developing technology for pharmaceutical administration systems. They develop projects in-house or in partnership with external organisations who wish to utilise Camurus technology to deliver their own active agents. Partnerships over the last 10 years have included agreements with Novartis Pharma, Rhythm pharmaceuticals and Braeburn pharmaceuticals. In each case, Camurus technology has been licensed or co-developed with the partner to deliver either an off-patent active agent or the partner’s proprietary pharmaceutical compound.
Camurus’ business model relies on multiple licensing agreements with multiple other parties, often with the same patents covering the core Camurus technology in several separate agreements. As a result, they need to make sure that their intellectual property is protected to uphold the value of the agreement and that both the IP and the agreements are structured in a way that allows for multiple licensing with minimal conflict.
What we did
Dehns Partner, Chris Goddard, worked closely with Camurus to make sure they had an established portfolio that would support each licensing deal. This involved developing a licensing and patent prosecution strategy that would help them maintain control of their technology in all agreements while providing their partners with the protection and control they required from a joint development.
Camurus worked with Dehns and with their business legal advisors to reach a sequence of deals that could satisfy both Camurus and their partners. This is a particularly important challenge for an organisation which relies on being able to license its technology to more than one company.
Outcome/result
Dehns played a vital role in working with Camurus to establish the strategy and portfolio to support their licensing deals without sacrificing control of the company’s key technological assets. The innovative work of Camurus scientists has benefited patients by improving compliance and ease of use in key therapeutic areas, with one joint development product now on sale as an EMA-approved treatment for opioid dependence and further products in the pipeline.
Workshops & Packages
“We really enjoyed the workshop and are very much looking forward to hearing your thoughts.”
(Client following a recent workshop, 2020)
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Dehns Consulting offers a one-day workshop package in which we will work with you to gain an understanding of your current IP and to help you plan for the future. The content of the workshop can be tailored according to need, but topics generally covered include:
- Discussion of your products and services and business goals to identify your innovations and brands and generation of your IP Roadmap
- Interactive session to discuss current ideas in the pipeline to identify and capture more IP
- Preliminary consideration of ‘Freedom to Operate’ and ‘Freedom to Use’ risks
- Collaborative planning of an IP strategy for the future
- You will be presented with a report after the workshop that summarises our findings and is suitable for presenting to potential investors
Dehns Consultancy also offers a half-day ‘IP 101’ package, which serves as an introduction to IP for managers, the R&D team, and/or the marketing team, as well as other members of your team that may benefit from learning more about IP. This educational talk provides a jargon-free, high-level introduction to important IP concepts of which all stakeholders should be aware. The workshop includes interactive elements to help participants get to grips with the various IP elements that they should be thinking about when going about their day jobs.
Topics covered include:
- What is IP?
- Patents, Trade Marks, Designs, and Copyright
- Trade Secrets and Know-how
- IP Strategy considerations
- Invention harvesting and capture techniques
Please contact us for further information
T: +44 (0)20 7632 7200
E: firstname.lastname@example.org
W: www.dehns.com
Dehns is a leading European firm of specialist patent and trade mark attorneys with more than 220 people working across six main offices (London, Munich, Oxford, Brighton, Manchester and Bristol).
Currently in our centenary year, and top tier ranked by all leading IP and legal directories, Dehns provides a comprehensive range of IP services including: patentability assessments, drafting, filing and prosecution, licencing agreements, advice and support on Oppositions and Appeals, Freedom to Operate opinions and IP portfolio strategy advice.
We have an outstanding team of 114 patent professionals. 83 of these specialise in a comprehensive range of engineering fields, including: physical sciences, photonics, nanotechnology, medical devices, mass spectrometry, electronics, AI and software.
We also have a team of 31 patent professionals who specialise in the biotechnology, life science, pharmaceutical, chemistry and biochemistry sectors – over 40% of this team have a PhD, highlighting our detailed technical expertise and knowledge in a wide range of fields.
To highlight the strength of our patent business, Dehns has filed the most number of patent applications of any UK firm in each of the last five years and has filed the most European Patent Applications of any European firm in two out of the last four years (2016 and 2019).
Dehns also has a highly successful, top tier ranked trade mark practice, consisting of 13 qualified Trade Mark Attorneys, providing a full range of trade mark services and advice to organisations in numerous sectors.
As evidenced by our consistent top-tier rankings over the years, and the longevity of many of our clients (some have been with us for over 50 years), Dehns continues to provide the very best quality advice and service delivery, while at the same time being very conscious of clients’ budgetary and time constraints.
Please contact us to discuss how Dehns can help and support you through any IP matters, regardless of where you are in your business and IP lifecycle.
The information in this document is necessarily of a general nature and is given by way of guidance only; specific legal advice should be sought on any particular matter. While this document has been prepared carefully to ensure that all information is correct at the time of publication, Dehns accepts no responsibility for any damage or loss suffered as a result of any inadvertent inaccuracy. Information contained herein should not, in whole or part, be published, reproduced or referred to without prior approval. Any such reproduction should be credited to Dehns.
© Dehns 2020
www.dehns.com
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Impacting others for the Lord
Companies often spend millions of dollars to influence the public. Along with money, a lot of thought, energy, and strategy go into designing ad campaigns and public relations events that will capture people’s interest.
As believers, we are involved in a much more important endeavour, that of capturing hearts with the truth of the gospel through godly living. If we are to have an impact on others, we need to present a consistent witness before them.
Having a strong conviction about God’s Word is the foundation of a godly influence; we must believe the Bible is true and practical in our daily lives. A reflection on the life of Daniel indicates that he had the opportunity to influence four Kings and their Kingdoms with Godly principles. Remaining true to God often meant putting himself in danger, but he never once wavered in his convictions. The record of his life shows us what is required of someone who wants to have a godly impact around him.
Complete confidence in the Lord’s ability to protect and provide empowered Daniel to make bold decisions. He delivered bad news to the Kings, even though such an act could have gotten him killed (Dan. 2:26-44; 5:17-28). What’s more, he challenged a law requiring him to violate God’s command to worship only Him (Dan.6: 7-11):
“All the presidents of the kingdom, the governors, and the princes, the counsellors, and the captains, have consulted together to establish a royal statute, and to make a firm decree, that whosoever shall ask a petition of any God or man for thirty days, save of thee, O king, he shall be cast into the den of lions.”
Now, O king, establish the decree, and sign the writing, that it be not changed, according to the law of the Medes and Persians, which altereth not.
Wherefore king Darius signed the writing and the decree.
Now when Daniel knew that the writing was signed, he went into his house; and his windows being open in his chamber toward Jerusalem, he kneeled upon his knees three times a day, and prayed, and gave thanks before his God, as he did aforetime.
Then these men assembled, and found Daniel praying and making supplication before his God”.
Daniel wasn’t intent on being popular; he was committed to doing what was right in the eyes of the Lord.
When he had to face consequences for choosing the unpopular course of action, he did so with calm and Christ like spirit. Offering no complaint, Daniel accepted the punishment of being thrown into a den of lions. He had in fact broken the law.
It is so tempting to think that if we do what is right, we should be rewarded or at least protected. But we live in a broken world, and sometimes doing what is right will get us punished. How we respond to the consequences of our obedience is actually as important as carrying out God’s will. Our reaction is being watched and evaluated by those in our sphere of influence, who want to see if we really believe our claim that the Lord is in control. God is using our experience and our witness to reach others for the Kingdom.
Following the Bible’s instructions is not usually a matter of life or death. But doing so can nevertheless place us in uncomfortable situations. If we are to have a godly influence, we must be committed to our convictions. A believer’s life is often the only example of scriptural principles other people will see. So, like Daniel, we must make up our mind to follow God, regardless of the circumstances. Like the people in Daniel’s sphere of influence, those you touch will see the work done for the Lord and glorify Him (Matt. 5:16). We are therefore challenged to so live our lives that others will be impacted and give themselves to Jesus. Jesus is calling you to Ministry. Say yes!
With the arrival of June, we are one month closer to the arrival and the eventual launch of our new hymnal – *Caribbean Moravian Praise*. In anticipation of the new hymnal, we continue this month to focus on another new hymn entry. As was mentioned last month, our goal in this exercise is to draw attention to these new entries so that we will have a better appreciation for the hymns that have been penned by our own Moravian brothers and sisters. For June, the new hymn that will be highlighted is *My brother come stand by me*. The original lyrics and music for this hymn was written by the Rev. Dr. Mikie Roberts in 1993.
This hymn was originally penned as the theme song for the 1993 Provincial Youth Camp. The focus for the camp that year was in keeping with the wider Provincial emphasis on families. In a very simple and direct manner, this hymn highlights the priority that, as believers, we ought to give to Christian families. The opening stanza draws attention to the solidarity and sense of unity that should be evident especially among believers as members of the family of God. In the second stanza, there is a call to be on the defence against the forces that are at work to destroy the human family structure as established by God. More than twenty years later, these words are more poignant in today’s world. For we now live in a society in which there has been a measure of legal success to redefine the traditional biblical marriage and family structures which are foundational to all civilization.
The hymn ends in the third verse with an invitation for united prayer beseeching God to so work in our families that the declaration made by Moses’ successor, Joshua, is also true for us. In chapter 24:15 of the book that carries his name, Joshua boldly declares, “*But as for me and my house we will serve the Lord.*”
The refrain of this hymn underscores that the bold declaration serves somewhat of an anchor to the three verses. Through this declaration, we are proclaiming that the members of our natural families as well as our faith families have been claimed by Jesus Christ.
This hymn captures the heart’s desire for all families: the desire for Christ to truly be the Lord of each family and each home.
Below are the words and music for the hymn of the month for June:
*My brother, come stand by me,*
*We’re part of God’s family;*
*My sister, I come to you,*
*You’re part of God’s fam’ly too.*
*Together we will declare*
*To all people far and near;*
*Our fam’lies for Christ we claim,*
*Praise His name.*
God gave us a family
To bless all humanity.
But fam’lies are being attacked,
We cannot stand back and watch.
So come now and join with me
As we pray for our families;
Believing that Christ will come
To make our hearts His home.
*1993. Mikie A. Roberts*
---
**My Brother Come Stand By Me**
Rev. Mikie A. Roberts
1. My brother, come stand by me, We’re part of God’s family; My sister, I
2. God gave us a family to bless all humanity. But fam’lies are
3. So come now and join with me as we pray for our fam’lies; Believing that
come to you, Your part of God’s fam’ly too. To-gether we will de-clare
being at-tacked, we can not stand back and watch. Christ will come to make our hearts His home.
to all peo-ple far and near; Our fam’lies for Christ we claim, Praise His name.
STATUS UPDATE ON
CARIBBEAN MORAVIAN PRAISE HYMNAL
The historic publication of the first Caribbean Moravian hymnal – Caribbean Moravian Praise – is near completion. Upon completion of the hard cover hymnal, each congregation will also receive a database that will contain a reference to the hymn tunes. In this database the music for the new hymns will be provided. However, in cases where the tune for the hymn is unchanged the actual music for that hymn will not be provided. Instead the database will indicate the name of the tune and the number of that hymn in the current music edition. By so doing, it is our desire that the new hymns will soon be incorporated into the congregation’s hymnal repertoire since the tunes will be at the congregation’s disposal.
Work on the musical edition has been ongoing and is in the advanced stages. It is hoped that its completion should be finalized within 12 – 16 months. The compilation of the musical edition entails giving attention to some details that are not required in the words only edition of the hymnal. For example, in addition to the authors and translators index, there must also be added an index for hymn tunes and composers as well as the alphabetical listing of the hymn tunes. Furthermore, we have to once again negotiate with international copyright holders to secure permission for the printing of the tunes for the hymns that are still under copyright. Mindful that this process may be lengthy, the provision of the hymn tune database will therefore serve as a temporary but necessary measure until the musical edition of the hymnal is completed.
The other component of the provision of worship material for the Province that has also begun is the production of the Liturgy Book. We anticipate that this volume will be published locally. It will contain the revised Liturgies, Litanies and Orders of Public Worship. The publication of this volume will be the second worship resource we intend to have available within the Province. We anticipate that it will follow not too long after the publication of soon to be released words only hymnal.
The final phase of the work that will be engaged will be the provision of the hymnal and Liturgy books in an electronic downloadable format. There has been numerous request for the materials to be presented in this format and we are seeking to meet that request.
However, we currently do not possess the resources (financial and human) to give attention this matter.
In summary, there are four phases to the overall mandate of the Provincial Hymnal and Liturgical Committees:
(1) Hard copy words only hymnal;
(2) Prayer Book with Liturgies;
(3) Musical edition;
(4) Electronic format of hymnal and Prayer Book.
UNITY SYNOD 2016
The year 2016 has begun, and for the Moravian Unity it means that we have seen the beginning of an important year, namely the year of the 43rd Unity Synod of the Moravian Church Unitas Fratrum (the 27th Unity Synod of the Renewed Church). It is our task to keep the Unity Synod in the Unity Synod during the coming months!
The Unity Synod is scheduled to be held from August 12th - 19th, 2016 at the Hilton Rose Hall Resort & Spa, Rose Hall, Montego Bay, St. James, Jamaica.
Minister in Training Retreat
Our Ministers in Training at UTCWI arrived in Antigua Monday on May 30th, 2016, in preparation for their Annual Retreat. The Retreat took place at the Provincial Headquarters at Cashew Hill on May 31st and June 1st, 2016. At the end of the Retreat, the Ministers in Training proceeded to their two (2) months assignment as they seek to understand the dynamics of Ministry on the ground and outside of the class room.
They have been assigned as follows:
Bro. Daniel Mark - Moravian Church, Barbados Conference
Bro. Kevin St. Hill - Moravian Church, Virgin Islands Conference
Let us remember them in our prayers.
Sunday 8th December 1946 heralded the birth of an 8lb baby boy to George and Ethel Matthias, whom they named Leon Henson. Leon received his primary education at the St James’ Government School in Cedar Grove. He later graduated from the Antigua Pilgrim High School in 1963. In September 1967, he entered the teaching profession and was appointed as an uncertified teacher at the St James’ Government School in Cedar Grove – his Alma Mater. At the age of 21, he was appointed Leader of the 4-H Club in Antigua and later represented his country at the inaugural CADEC meeting in Barbados.
The family were all members of Gracefield Moravian Church in Cedar Grove; where his grandfather Adrian Joseph was the sexton. Bro Joseph took his responsibility seriously and took his grandchildren to church every Sunday. It was at this church that Leon had his first thrust into a leadership role. At the age of 19, Leon was elected as chairman of the Board of Stewards, while his mother Ethel served as secretary. The members of the congregation encouraged him as they recognized that God was calling him to a special task in His church.
September 1968, Brother Leon submitted his application to be considered for training as a Minister of the Gospel. The Provincial Elders’ Conference accepted his application and he began his theological training on the Island of Trinidad in 1970. A year later, Brother Matthias entered the United Theological College of the West Indies in Kingston, Jamaica to continue his education and completed the Licentiate in Theology in 1974. After graduation, he served as student pastor in Antigua under the tutelage of the Rev. Rudolph Holder at Spring Gardens Moravian Church. In September he was transferred to the Tobago Conference and worked at Bon Accord and Spring Gardens Moravian congregations for a year.
On August 24th 1975, Brother Matthias was ordained as a Deacon by Bishop Selvin Hastings. A week later on September 1st he began his first appointment as a Moravian Pastor in St Kitts. Rev. Matthias served many congregations in Antigua, St Kitts and Tobago and in 1981; he was consecrated as a Presbyter in the Moravian Church.
On August 28th 1976, Rev. Leon made another important decision in his life. He was joined in matrimony to Mabel Hall in Jamaica. God blessed their marriage with three wonderful boys, Lennox, Leon Jr and Lucien(Richard).
Rev. Leon was awarded a scholarship by the Caribbean Conference of Churches to study Christian Education in Virginia; where he obtained a Master of Arts Degree. Rev. Leon used his tremendous energy, leadership skills and educational abilities to focus on youth development and later directed the First Provincial Youth Camp in Antigua in 1982. He returned to St Kitts Conference as Superintendent. Later he was transferred to the Virgin Islands Conference and served as Pastor of Friedensberg, Memorial and Tortola Fellowship. He was appointed the Superintendent of the VI Conference.
Rev. Leon participated in an oral history workshop in the US Virgin Islands in 1990. This opened a vast new field of enquiry which he pursued vigorously to document unwritten folk history of his people. His interest led to his edition of many publications and writing six books between 1995 and 2008.
In 1993, Rev. Leon was elected by the Provincial Synod of the Moravian Church Eastern West Indian Province as a member of the delegation for the 1995 Unity Synod in Dar-es-Salaam, Tanzania. He made numerous lasting friendships during his journey through London, Tanzania, Johannesburg and Cape Town in South Africa. In 2002, Rev. Leon achieved a Master of Science Degree in Library Studies.
His ministries with Grace and Tremont Moravian Congregations in New York, brought him immense enjoyment; particularly his work with the youth population; which expanded outside the boundaries of New York. He is credited as being the driving force behind the formation of the Metro Moravian Youth Council with its now well established Annual Youth Ministries Weekend and will always be associated the unofficial anthem of that event: Moravians For Jesus. He was triumphant in the face of illness and faced the significant challenges without complaint right until he responded to his higher calling in the early hours of Monday, September 23rd, 2013.
A warm Welcome to the Browne Family from the Executive Board and Members of the Moravian Church, Virgin Islands Conference / Tortola Fellowship
Appreciation Service of the Floyd’s Family with Members of PEC and the Tortola Fellowship.
L to R Rev. Erflin Browne, Sis. Evannie Jeremiah, Sis. Elisa G. Hodge, Sis. Marleen Browne
L to R Sis. Elisa G. Hodge, Bro Myron Floyd & Rev. Alicia Ross-Floyd, Rev. Dr. Kirton-Roberts & Rev. Dr. Errol Connor
L to R Bishop Conrad Spencer, Sis. Evannie Jeremiah, Rev. Eulencine Christopher, Rev. Erflin Browne and Sis. Elisa G. Hodge
Sis. Hodge, Rev. Ross-Floyd, Sis. Smith-Barry
Fulfilling the Mandate - Advance the Kingdom
Mathematics Enrichment Program!!
If you are a fourth or fifth form student in Antigua and need to sharpen your skills in mathematics, help is on its way. The Moravian Church will once again be conducting its Mathematics Enrichment Program geared specially for you. It will run from 8th to 19th August, 2016 at Tim O’Reilly Auditorium on St. John’s Street from 9:00 am to 12:30 pm. The lecturers will include Antiguan born Dr. Vanere Goodwin and the Rt. Rev. Dr. Conrad Spencer, both professors of mathematics. The course fee is only $110 which includes a non-refundable registration fee of $10. The committee organizing the event may give concession to households with two or more students enrolled in the program. Kindly register by 15th June.
Nun Joke
Sister Mary was truly a religious woman. Besides her duties as a nun, she was also very active in various hospitals visiting sick patients and taking care of all their needs. So it was no surprise that one day when she ran out of gas, the only container she could find to put the gas into was a bedpan. Sister Mary happily walked two blocks to the closest gas station filled up the bedpan with gas and headed back to her car. Luck would have it that as Sister Mary started tipping the gas into the fuel tank, the traffic light turned red and she had quite a large audience witnessing the spectacle. Just when she finished pouring in the last drops of gas a fellow opened up his window and hollered,
“I swear! If that car starts I’m becoming a religious man!”
Moravian Multipurpose Complex
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Only ten minutes away from the stores, shops and banks in St. John's.
Our International airport is also just ten minutes away.
Our balcony provides a refreshing view of undulating hills and valleys.
The conference center has a seating capacity for 200 persons.
We are situated on a hill overlooking the picturesque outskirts of the city of St. John's, Antigua.
There are EIGHT LARGE APARTMENTS which are available for rental. Each room is self contained with kitchenette. The rooms are air-conditioned with Available internet and cable TV. All utilities are included with the exception of telephone.
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Dementias Caused by Persistent Pathogens and the Protective Role of HLA Against them
Lisa M. James\textsuperscript{1,2,3}, Apostolos P. Georgopoulos\textsuperscript{1,2,3,4*}
\textsuperscript{1}Brain Sciences Center, Department of Veterans Affairs Health Care System, Minneapolis, USA
\textsuperscript{2}Department of Neuroscience, University of Minnesota Medical School, Minneapolis, USA
\textsuperscript{3}Department of Psychiatry, University of Minnesota Medical School, Minneapolis, USA
\textsuperscript{4}Department of Neurology, University of Minnesota Medical School, Minneapolis, USA
ABSTRACT
Dementia is a leading cause of death worldwide, representing a significant global burden. In addition to genetic and lifestyle factors that have been widely linked to dementia, pathogens are increasingly recognized as contributing to the development of dementia. Here we discuss the role of human leukocyte antigens (HLA) in maintaining brain health by facilitating the elimination of pathogens and highlight evidence suggesting that the inability to eliminate pathogens contributes to dementia. Finally, we briefly review common forms of dementia including Alzheimer’s disease, vascular dementia, frontotemporal dementia, Lewy body dementia, and prion dementia in an effort to contextualize the role of persistent pathogens across the various dementia phenotypes.
Introduction
An estimated 50 million people are living with dementia worldwide, and that number is expected to triple by 2050\textsuperscript{1}. Dementia is a broad term that refers to conditions reflecting a decline in cognitive, behavioral, motor, and/or social functioning that eventually interferes with the ability to live independently. The most commonly recognized forms of dementia include Alzheimer’s disease (AD), vascular dementia, Lewy body dementias, and frontotemporal dementia. Prions and prion-like mechanisms associated with other neurodegenerative disorders are also implicated in dementia. The causal factors and mechanisms underlying brain deterioration associated with dementia as well as less pernicious forms of age-related cognitive decline have long been intensely investigated; however, there is a burgeoning emphasis on also understanding factors that promote the maintenance of healthy brain functioning across the lifespan. Here we will briefly review the emerging picture of immunogenetic mechanisms underlying brain health and disease centering around human leukocyte antigens (HLA) and discuss the implications of this immunogenetic influence in terms of common forms of dementia.
Healthy Brain Aging
It is widely accepted that the trajectory of cognitive functioning across the lifespan is influenced by both lifestyle factors such as diet and exercise as well as genetics. Among genetic influences, apolipoprotein E is well-established in playing a role in the maintenance of cognitive function and decline, depending on genotype. Specifically, the apolipoprotein E4 allele has been shown to be associated with brain atrophy\textsuperscript{2}, neural network dysfunction\textsuperscript{3-4}, increased risk for AD\textsuperscript{5-6}, and reduced cognitive performance among cognitively healthy individuals\textsuperscript{7}.
Conversely, the apoE2 alleles have been linked to preserved cognitive functioning and reduced risk of AD\textsuperscript{8}.
**HLA neuroprotection**
Emerging evidence suggests that HLA may also play a crucial role in brain health and disease. HLA genes encode for cell surface glycoproteins that are involved in immune surveillance and elimination of foreign antigens such as viruses and bacteria via the facilitation of cell destruction (Class I) or antibody production (Class II). These processes, however, hinge on a match between HLA molecules and antigenic peptides as a first crucial step (Figure 1). The HLA genes are the most highly polymorphic in the human genome, an evolutionary consequence aimed at maximizing host protection from foreign antigens/pathogens. However, each individual has a limited repertoire of HLA molecules, restricting the scope of foreign antigens that can be successfully eliminated. Furthermore, HLA molecules differ in their binding affinity and ability to mount an immune response. Among the tens of thousands of HLA alleles, some occur at much higher frequencies in a population than others owing to their relative advantage in host protection via antigen elimination. For example, HLA DRB1*13 alleles have been shown to exert broad protective effects against several conditions affecting the brain, including various autoimmune disorders\textsuperscript{9,10} and Gulf War Illness, a neuroimmune condition related to military service during the 1990-91 Persian Gulf conflict\textsuperscript{11,12}. With regard to Gulf War Illness, we found that HLA DRB1*13:02 protected against brain atrophy\textsuperscript{13} which is typical of those with the condition\textsuperscript{14}.
Brain atrophy is also viewed as a consequence of aging, with typical rates of atrophy approaching 5% per decade\textsuperscript{15}. Given the neuroprotective effects observed in other conditions, we investigated potential protective effects of HLA DRB1*13 against age-related brain changes. Again we found that HLA DRB1*13 alleles (HLA-DRB1*13:02 primarily but also HLA-DRB1*13:01 to a lesser extent) protect against age-related brain atrophy\textsuperscript{16} and function\textsuperscript{17}, even in the presence of apoE4. The role of HLA in pathogen elimination, in conjunction with evidence of HLA-DRB1*13 protection against age-related brain changes, led us to speculate that these alleles may protect against dementia via the elimination of pathogens. Indeed, in a recent genetic epidemiological study, we demonstrated that dementia prevalence (any type of dementia) in 14 Continental Western European countries is inversely associated with the population frequency of HLA DRB1*13:02 and was not accounted for by apoE4\textsuperscript{18} (Figure 2a). In fact, as the population frequency of HLA DRB1*13:02 doubled, the prevalence of dementia was reduced by one-third (Figure 2b). Remarkably, the frequency of HLA DRB1*13:02 was shown to account for 45.2% of the variance in dementia rates. Given the role of HLA Class II alleles in elimination of foreign antigens by the production of specific antibodies against them, these findings suggest that individuals who possess the DRB1*13:02 allele, as well as populations in which the allele is common, have enhanced protection against dementia conferred by the successful elimination of the foreign pathogens. In the absence of such successful elimination, the pathogens may persist causing inflammation and cell damage\textsuperscript{19}, the effects of which are likely to be exacerbated in apoE4 carriers due to the neurotoxicity of apoe4 fragments relative to other isoforms\textsuperscript{20,21}. Thus, we have hypothesized that any foreign pathogen that cannot be successfully eliminated due to HLA-antigen incongruence may be causally involved in dementia development\textsuperscript{20} (Figure 1b). Unlike theories that are restricted to reactivation of latent infection as causing dementia, we proposed that the persistence of foreign pathogens, even in the absence of frank infection, may cause gradual damage to the brain that results in dementia\textsuperscript{20}.
**Pathogens and Dementia**
Once considered controversial, the role of pathogens in dementia is increasingly recognized and investigated. Indeed, numerous pathogens have been implicated in AD, including, most prominently, herpes viruses in addition to bacterial spirochetes such as those related to gum disease, among others\textsuperscript{22,23}. These infections have not only been shown to increase the risk of AD but the role of microbes...
in AD is also supported by evidence of the presence of microbes in brain tissue, particularly in regions that are impacted in AD, and co-localization of those microbes with typical AD pathology\textsuperscript{22,23}. A recent study of mice intranasally infected with the H5N1 virus provides a link between pathogens and Lewy body dementias (LBD)\textsuperscript{24}. Specifically, the authors demonstrated that the H5N1 virus enters the CNS via cranial nerves, affecting the brainstem first before spreading to the midbrain and cortex and that the virus can infect neurons by peripheral infection and by hematogenous spread subsequent to release from dying cells. Furthermore, they demonstrated aggregation of alpha-synuclein that co-localized with brain regions showing evidence of viral infection, including the hippocampus, cortex, and brainstem, similar to that seen in human proteinopathies. Finally, the authors reported evidence of microgliosis for the entire 90-day study period in spite of evidence that the acute infection had resolved by day 21, suggesting a prolonged inflammatory response resulting from the initial infection as might be expected with persistent pathogens. Prolonged inflammation has been linked to nearly all types of dementia\textsuperscript{25-27}. Furthermore, because brain regions that are critical to cognitive processes including memory, attention, emotion, and perception contain more enzymes involves in inflammatory responses than do other regions of the brain they are thought to be at increased risk of cumulative damage from even low-level chronic inflammation\textsuperscript{28}.
The specific dementia phenotype may be dependent on the type of pathogen and its mode of entry into the brain. For example, microbial pathogens may cross the blood-brain-barrier and/or blood-cerebrospinal fluid barrier via one or more of several mechanisms, including transcellular penetration, paracellular entry, or by infected leukocytes circulating peripherally\textsuperscript{29}; they may also access the central nervous system through cranial nerves including most prominently the olfactory and trigeminal nerves before migrating to higher brain regions including those that have been implicated in dementia\textsuperscript{29}. Access to the CNS through the olfactory and trigeminal nerves has been shown to be highly relevant to human herpesviruses as well as several types of influenza A\textsuperscript{29}. Furthermore, researchers have demonstrated evidence of apoptosis in olfactory sensory neurons of virally-infected hosts which were suggested to be aimed at host protection from microbial invasion through the nasal cavity\textsuperscript{30}. Indeed, olfactory dysfunction resulting in loss of smell has been implicated in nearly every type of dementia\textsuperscript{31}. Taken together, compelling evidence supports the role of pathogens in dementia. Consistent with the mounting literature implicating pathogens in dementia and the immunogenetic (i.e., HLA) influence on pathogen elimination or, conversely, the persistence as described above, we have proposed the concept of persistent pathogen dementia\textsuperscript{20} which we characterize below.
**Persistent Pathogen Dementia (PPD)**
As noted above, several pathogens have been linked to dementia (primarily AD) including herpes simplex virus type 1 (HSV-1), \textit{Helicobacter pylori} (\textit{h. pylori}), \textit{Chlamydophila pneumonia}, and \textit{Borrelia burgdorferi} among several others\textsuperscript{23}. Perhaps more than any other microbe, HSV-1 has been robustly associated with AD. The prevailing theory suggests that reactivation of latent HSV-1 infection in apoE4 carriers contributes to AD. The percent of dementia cases attributable to pathogens is unknown; however, evidence of HSV1 in the brains of apoE4 carriers has been shown in nearly 60% of cases\textsuperscript{32}, suggesting high rates of pathogen-linked dementia. In addition to current theories implicating reactivation of latent infections, we hypothesize that fragments of pathogens that elude
elimination due to HLA-antigen incongruence will similarly affect the brain\textsuperscript{30}. To that end, any pathogen that is not able to be eliminated may contribute to PPD.
**Risk Factors**
The primary risk factor associated with PPD is exposure to pathogens (e.g., viruses, bacteria); however, rates of pathogen exposure do not square with rates of dementia indicating that pathogen exposure alone is not sufficient to produce dementia. For example, the majority of U.S. adults age 30 and older have been exposed to HSV-1\textsuperscript{33} yet the U.S. population prevalence of dementia is less than 2%\textsuperscript{34}, highlighting the role of additional factors. As with other dementias, apoE4 is considered a risk factor for PPDs. In the case of HSV-1, it has been suggested that HSV in apoE4 carriers is associated with high rates of dementia whereas neither apoE4 nor HSV1 alone raise risk\textsuperscript{32}. An additional risk-factor appears to be a lack of immunogenetic (i.e., HLA) protection\textsuperscript{18}. Because each HLA molecule matches specific epitopes, each person’s ability to eliminate pathogens is determined by their HLA profile as discussed above. Further, because each individual has a limited number of HLA genes that, in turn, determine which pathogens can be successfully eliminated, some individuals may lack protection against certain pathogens due to HLA-antigen incongruence.
**Neuropathology**
There is some evidence that neuropathology associated with persistent pathogens parallels and is associated with well-established dementia pathology. For example, H5N1 influenza has been shown to increase alpha-synuclein in pre-clinical studies\textsuperscript{34}. Similarly, HSV-1 has been shown to increase AD-related amyloid-beta (Aβ)\textsuperscript{35} and tau\textsuperscript{36} in cell cultures and to co-localize with amyloid plaques in the human brain\textsuperscript{37}. Similarly, HIV has been shown to modulate the production of Aβ and tau\textsuperscript{38}. These findings dovetail with other lines of research demonstrating antimicrobial effects of Aβ\textsuperscript{39,40}. That is, Aβ is thought to play a crucial role in the brain’s immune system by trapping pathogens. Similarly, there is evidence that tau accumulation is a neuroprotective response to oxidative stress, leading to the conclusion that “inclusion formation represents adaptation, or productive, beneficial response to the otherwise neurodegenerative process”\textsuperscript{41}. Thus, from the PPD perspective, in the absence of an HLA-antigen match, persistent foreign antigens promote the production of plaques and tangles in an effort to protect the brain from foreign invaders. Notably, such protective effects do not preclude the possibility that accumulation of Aβ and tau tangles eventually becomes toxic; however, this suggests that exposure to pathogens, in the absence of protective HLA that can eliminate them, plays a fundamental role in dementia.
**Neuroimaging**
Neuroimaging findings related to PPD are likely to be as varied as the underlying pathogens. Indeed, each of the herpes viruses has been associated with unique neuroimaging features, with reactivation following the same patterns as initial infection\textsuperscript{42}. Similarly, dementia related to HIV has been shown to be distinct from typical AD\textsuperscript{43}. Characteristic neuroimaging markers for various persistent pathogens may be identified in future studies.
**Treatment**
Effective interventions for PPD are likely to center around the elimination of pathogens. To that end, recent studies of anti-herpes antivirals have shown promise in reducing the incidence of dementia among individuals with herpes zoster\textsuperscript{44} and HSV1\textsuperscript{45} in two large-scale studies. If research continues to support the hypotheses that Aβ and tau accumulation provide neuroprotective functions, and antimicrobial functions, in particular, treatments aimed at modulating Aβ and tau may not be effective; instead, if amyloid and tau are stimulated in order to protect the brain from pathogens, elimination of the pathogen is called for.
**Summary**
Thus far we have shown that immunogenetic protection conferred by HLA genes guards against neurodegeneration associated with neuroimmune conditions and age-related processes at the individual level, and protects against dementia at the population level via facilitating the elimination of pathogens. For those lacking immunogenetic protection, exposure to HLA-incongruent pathogens may persist, causing inflammation and neurodegeneration that may result in dementia. We have also shown that pathogens are increasingly recognized as playing a prominent role in dementia and provided an overview of characteristics proposed to be associated with PPD. Next, we provide a brief overview of commonly recognized types of dementia, noting evidence suggesting the role of pathogens in where applicable. We hypothesize that all dementias below, except for vascular dementia, are indeed subsets of PPD.
**Alzheimer’s Dementia**
AD is the most common cause of dementia, accounting for 60-80% of dementia cases. Although AD may be diagnosed before age 65, the vast majority of cases are seen in those 65 and above; the more typical late-onset type is the focus here. Memory impairments are the hallmark symptom of AD; however, impairments in judgment and social functioning, changes in mood and personality, and motor deficits are also typical. Because AD is a progressive disease, the level of dysfunction increases over time such that at the final stages, affected individuals are completely impaired and unable to perform basic life functions.
AD Risk factors
A number of risk factors have been associated with dementia. Among the non-modifiable risk factors are age and genetics. After age 65, the risk for dementia increases with age such that one-third of people aged 85 or older are diagnosed with dementia\textsuperscript{46}. A number of genes have been implicated in AD\textsuperscript{47}. Among genetic risk factors, the apolipoprotein E4 (apoE4) allele has the most robust association with AD with risk increasing in a dose-dependent manner according to the number of apoE4 alleles\textsuperscript{5}. ApoE is involved in a number of functions including cholesterol transport and metabolism, neuroplasticity, and neuronal repair\textsuperscript{21}. Relative to apoE2 and E3, the E4 allele is unstable and its expression results in neurotoxic fragments that ultimately contribute to neurodegeneration\textsuperscript{20,21}. However, apoE4 is neither necessary nor sufficient to produce AD; recent studies have identified various other genes that appear to be related to AD including several associated with immune response and inflammation\textsuperscript{6,47}. In addition to non-modifiable risk factors, a number of lifestyle-related factors have been implicated in dementia including diet, physical and mental exercise, diabetes, obesity, and smoking. Evidence suggests that a reduction in modifiable risk factors would lead to a significant decline in dementia incidence\textsuperscript{48}. The recent decline in dementia incidence in many countries may be attributable to reduced risk owing to changes in modifiable risk factors. Finally, as previously noted, numerous pathogens have been implicated as a risk factor for AD\textsuperscript{22,23}.
AD Neuropathology
The hallmark signs of AD are extracellular Aβ plaques and intracellular neurofibrillary tau tangles. Amyloids are protein aggregates that stick together forming fibrils. In the case of AD, it is believed that misfolded Aβ oligomers accumulate, forming plaques that disrupt synapses and ultimately contribute to neurodegeneration\textsuperscript{49}. Protein misfolding and aggregation has also been implicated in Parkinson’s disease and prion diseases, both of which are also associated with dementia\textsuperscript{49}; indeed, it has been suggested that Aβ and tau are themselves prion-like in that they may slowly self-propagate, ultimately contributing to widespread neurodegeneration\textsuperscript{50-52}. Despite considerable evidence linking Aβ to dementia, mounting research has called into question the central role of Aβ plaques in AD\textsuperscript{53}. First, postmortem autopsy of brain specimens \textsuperscript{54,55} and in vivo positron emission tomography\textsuperscript{56} have revealed evidence of significant amyloid plaque burden in the absence of memory impairment. Second, as summarized elsewhere\textsuperscript{53}, several therapeutic strategies aimed at clearing Aβ from the brain have failed and, in some cases, produced severe side effects. Finally, Aβ has been shown to have important physiological functions including anti-microbial activity\textsuperscript{39,57,58}. That is, accumulation of Aβ may result from immune-mediated mechanisms aimed at trapping pathogens, the persistence of which could facilitate the accumulation of Aβ. While it is recognized that Aβ likely participates in dementia, there are growing calls for the scientific community to “devote its utmost efforts to identify the real culprit of AD”\textsuperscript{53a}, which we have proposed is persistent pathogens\textsuperscript{20}.
Tau is a highly soluble protein involved in microtubule stabilization, primarily in axons, that has also been implicated in AD. In the AD brain, tau is hyperphosphorylated relative to healthy tau\textsuperscript{59}. Hyperphosphorylated tau becomes insoluble and misfolded protein aggregates form neurofibrillary tangles that accumulate in cells leading to impairment in several downstream processes including mitochondrial and synaptic function and axonal transport, and ultimately cell death\textsuperscript{59}. Tau has also been implicated in AD-associated neuroinflammation\textsuperscript{60} and has been shown to interact with insulin to modulate AD\textsuperscript{61}. Tau tangles are more correlated with cognitive impairment and AD severity than Aβ\textsuperscript{62,63}, leading many to consider tau as fundamentally underlying AD. However, others have noted evidence of tau pathology in prepubertal human brains\textsuperscript{64} and in cognitively healthy individuals\textsuperscript{65}, and have shown that neurons with neurofibrillary tangles can live for decades\textsuperscript{66}, raising criticism for the hypothesis that tau mutations drive AD. Furthermore, as with Aβ, some have suggested that phosphorylated tau (and other intracellular inclusions) serve a neuroprotective role against adverse conditions such as oxidative stress and/or toxin exposure\textsuperscript{67}. In this scenario, in which hyperphosphorylation of tau is secondary to other local cellular environmental insults, the long-term consequences may be deleterious (including neuronal death) albeit protracted. Finally, if tau indeed serves a protective role, AD interventions aimed at reducing tau pathology may be counterproductive.
AD Neuroimaging
Considerable effort is being made to detect AD in vivo with diagnostic neuroimaging moving along several fronts. Structural MRI is one of the most widely used neuroimaging techniques in the diagnosis of AD. Decades of research have converged to establish a signature of AD-related brain atrophy characterized by initial effects on the medial temporal lobe (i.e., entorhinal cortex and hippocampus), followed by an extension to the rest of the cortex, with the motor areas spared until later in the disease process, as reviewed elsewhere\textsuperscript{68}. In addition, several subcortical structures including the amygdala, basal ganglia, caudate, and putamen, among others have been shown to exhibit significant atrophy in patients with AD\textsuperscript{69}. Advances in neuroimaging have helped identify several subtypes of AD that are atypical relative to the AD signature described above. Indeed, mounting evidence suggests there is substantial heterogeneity in patterns of brain atrophy
associated with AD with several subtypes following atypical patterns including one that spares the hippocampus, one that predominantly involves limbic structures, and one that is characterized by minimal atrophy\textsuperscript{69-70}. Although speculative, it is possible that the heterogeneity observed in AD is related to the varied mechanisms of pathogen entry into the brain as described previously\textsuperscript{29}.
Positron emission tomography (PET) is also widely utilized in clinical evaluations of AD. Amyloid, tau, and \textsuperscript{18}fluorodeoxyglucose (FDG) PET tracers have been used to noninvasively visualize amyloid and tau deposition and glucose consumption in the brain, respectively, each providing novel and complementary indications of AD-related pathological processes\textsuperscript{71}. PET is also being used for in vivo detection of neuroinflammation as evidenced by microglia activation and reactive astrocytosis\textsuperscript{71}. Increasingly, clinical scientists are advocating for the use of multimodal neuroimaging to detect the variety of pathological brain changes associated with AD, and ultimately increase diagnostic accuracy.
**AD Treatment**
To date, there is no cure for AD and treatment is aimed at managing symptoms as reviewed elsewhere\textsuperscript{72}. Briefly, cholinesterase inhibitors and Memantine, an NMDA receptor agonist, have been licensed for AD with some benefit observed for cognition and mood symptoms. Neuropsychiatric symptoms in AD are commonly treated with atypical antipsychotics, antidepressants, or anticonvulsants with modest benefits and, in some cases, the potential for significant side effects. Finally, several disease-modifying treatments are under investigation, many of which are aimed at targeting amyloid-beta and tau; none have shown conclusive efficacy for AD yet. Given the lack of effective treatments for AD, the importance of AD prevention through lifestyle interventions such as exercise and a healthy diet has gained prominence.
**Lewy Body Dementia and Parkinsonian Dementia**
Lewy Body dementia (LBD), which include dementia with Lewy bodies and Parkinson’s disease dementia, are the second most common type of dementia in older adults, accounting for up to 30% of dementia cases. Men are disproportionately affected by LBD\textsuperscript{73}. Clinically, LBDs are difficult to distinguish from AD in that both are characterized by a progressive decline in cognitive function, however, LBD is characterized by periods of normal cognition alternating with a cognitive impairment which is not typical of AD. Individuals with LBD are also prone to hallucinations and parkinsonian motor symptoms, and rapid eye movement sleep behavior disorders are common and have been shown to be predictive of LBD\textsuperscript{74}.
**LBD Neuropathology**
As with several other forms of dementia, misfolded aggregated proteins are associated with LBD. The hallmark of LBD is alpha-synuclein neuronal inclusions. Alpha-synuclein is a protein found predominantly in the brain (e.g., neocortex, hippocampus, substantia nigra, thalamus, and cerebellum) but also in other organs such as the heart and lungs. In the brain, it is widely found in the presynaptic terminals in addition to the cytosol. Under normal conditions, alpha-synuclein is thought to be involved in neurotransmitter release and has been shown to have several neuroprotective functions including suppression of apoptosis, regulation of glucose and dopamine, and antioxidant functions among others\textsuperscript{75}. However, under pathologic conditions, alpha-synuclein misfolds forming fibrils that deposit as Lewy bodies. It is unclear why alpha-synuclein aggregates; as with other forms of dementia, oxidative stress and mutations are thought to play a role\textsuperscript{76}. Lewy pathology is accompanied by the substantial neuronal loss that has been documented in the substantia nigra, locus coeruleus and basal nucleus of Meynert, among other regions\textsuperscript{77}.
In addition to alpha-synuclein, Aβ plaques and tau tangles are often present in LBD\textsuperscript{78}. Similar to the discussion above regarding Aβ and tau, questions about whether alpha-synuclein is neuroprotective or neurotoxic have arisen. In support of a neuroprotective role, Lewy bodies have been shown to isolate harmful proteins\textsuperscript{79,80} (which could include persistent pathogens) similar to the antimicrobial role of Aβ\textsuperscript{39,57,58}. In addition, inclusion body formation does not necessarily lead to cell death\textsuperscript{79}. Further, there is evidence of severe alpha-synuclein pathology in the absence of clinical symptoms\textsuperscript{81}, highlighting a disconnect between alpha-synuclein pathology and dementia.
**LBD Risk Factors**
A number of genetic risk factors have been associated with LBD dementia including mutations in SNCA, the gene that encodes the alpha-synuclein protein, as well as genes implicated in other forms of dementia such as those associated with amyloid precursor protein, presenilin genes, tau, and apoE\textsuperscript{74}.
**LBD Imaging**
Like AD, LBD is associated with global atrophy, rendering structural imaging less helpful in differentiating LBD from AD. Other neuroimaging techniques, however, have proven more useful in terms of differential diagnosis of LBD from AD\textsuperscript{74}. Briefly, LBD, in particular, has been associated with occipital hypometabolism, less hippocampal atrophy, and significantly reduced dopamine reuptake in the caudate and putamen relative to AD.
LBD Treatment
Like AD, treatment of LBD is aimed at symptom management, and acetylcholinesterase inhibitors are commonly prescribed to slow the progression of cognitive deficits. As noted in a recent review, treatments targeting other symptoms have insufficient evidence regarding efficacy and, in many cases, evidence of adverse effects limit the benefit of several medications aimed at symptom management\(^{83}\). As with other proteinopathies, treatments aimed at decreasing the accumulation of alpha-synuclein are being investigated as the future of LBD treatment\(^{82}\).
Vascular Dementia
Vascular dementia (VaD), sometimes referred to as vascular cognitive impairment, accounts for about 15% of dementia cases\(^{84}\). VaD results from reduced blood flow to the brain resulting in cortical and/or subcortical damage. Although the symptoms of VaD are variable depending on which area of the brain is affected by vascular pathology, deficits in planning and judgment are commonly observed (for an overview of VaD, see \(^{84}\)). Depression is also particularly common in VaD. Unlike AD, where memory impairment is a hallmark, the memory may or may not be impaired in VaD. The symptom course is also variable. Some experience sudden onset of symptoms, particularly following a stroke, some exhibit a stepwise progression of symptoms and others a slow steady progression similar to that seen in AD. Finally, VaD and AD often co-occur with up to 50% of individuals showing evidence of “mixed dementia”\(^{85}\), making it among the most common in older adults.
VaD Risk Factors
Several vascular dementia risk factors mirror those associated with heart disease including hypertension, high cholesterol, diabetes, smoking, sedentary lifestyle, unhealthy diet, being overweight, limited exercise, and high alcohol consumption. Notably, these factors have been associated with inflammation which has been shown to contribute to atherosclerosis and subsequent risk of stroke and cognitive impairment\(^{86,87}\). Stroke history is a significant risk factor for vascular dementia with nearly 25% of people who have had a stroke ultimately developing dementia\(^{88}\). As with other forms of dementia, increasing age is a risk factor for vascular dementia. Identification of genetic risk factors for VaD has been limited\(^{84}\); however, like AD, apoE4 has been associated with VaD\(^{89}\).
VaD Neuroimaging and Neuropathology
The presence of infarcts, lacunes, and white matter lesions as evidenced by neuroimaging are indicative of VaD\(^{88,90}\). However, due to the heterogeneity of cerebrovascular pathology and evidence of vascular brain pathology in non-demented older individuals\(^{91}\), there are no accepted neuropathological criteria specific for VaD.
VaD Treatment
To date, pharmacological interventions for VaD have shown limited effectiveness\(^{84}\). Interventions for AD, such as cholinesterase inhibitors and memantine, are not recommended due to side effects and small magnitude benefits observed in VaD relative to AD. Other pharmacological interventions aimed at reducing risk factors such as high cholesterol or hypertension have typically not included cognitive status as a primary outcome, rendering conclusions about effectiveness in reducing dementia risk untenable. Preventive lifestyle interventions such as healthy eating and increased exercise have shown promising results in terms of improving or maintaining cognitive functioning in at-risk elderly people\(^{92}\). The effectiveness of lifestyle interventions is at least partially attributable to reductions in peripheral inflammation\(^{93}\).
Frontotemporal Dementia
Frontotemporal dementia (FTD) is the third most common cause of dementia, with prevalence ranging from 3-26% of dementia cases, and is particularly common in early-onset dementia\(^{94}\). Three variants of FTD have been identified based on early symptoms and are reviewed elsewhere\(^{95}\). First, behavioral–variant FTD is characterized by personality changes, disinhibition, and apathy, often resembling psychiatric disorders. Unlike AD where memory impairment is prominent, memory and visuospatial skills are often spared in the early stages of behavioral-variant FTD. There may be a slow progression of cognitive impairment and neuroimaging is often unremarkable. Primary progressive aphasias are characterized primarily by a decline in language skills during the initial phase of the disease. In semantic-variant primary progressive aphasia, symptoms to include anomia, word-finding difficulties, and impaired comprehension. Non-fluent variant primary progressive aphasia is characterized by grammatical errors and speech apraxia. As any of the variants of FTD progress, the symptoms converge and cognitive and motor deficits emerge, ultimately resembling AD.
FTD Risk Factors
A family history of dementia is associated with FTD. To that end, a number of genetic mutations including, but not limited to, mutations associated with tau, TAR DNA-binding protein-43 (TDP-43), fused-in sarcoma (FUS), and ubiquitin have been associated with FTD. A succinct review of several genetic mutations associated with FTD, brain pathology that is characteristic of each mutation, and mechanisms of degeneration is available in a recent FTD overview\(^{95}\). Notably, several studies have noted strong associations between HLA Class II DR and FTD including...
evidence of *cis*-changes in methylation levels of *HLA-DRA* in the frontal cortex\textsuperscript{96} and a significant reduction in HLA-DR expression if FTD relative to controls\textsuperscript{97}.
**FTD Neuropathology**
Similar to AD, abnormal protein deposition has been implicated in FTD. Tau, TAR DNA-binding protein-43 (TDP-43), or FUS protein account for most cases of FTD and are associated with characteristic neuropathological signs (e.g. Pick bodies, tufted astrocytes, as described elsewhere\textsuperscript{95}).
**FTD Imaging**
Neuroimaging studies have demonstrated similarities across FTD variants as well as unique features. Atrophy in ventromedial and posterior orbital frontal regions, insula, and anterior cingulate cortex have been demonstrated across FTD variants; however, the behavioral variant is predominantly associated with dorsolateral frontal atrophy whereas the semantic variant is primarily associated with bilateral anterior temporal atrophy\textsuperscript{98}. The selective frontal and temporal lobe neurodegeneration in FTD has been attributed to the degeneration of von Economo neurons and fork cells which are thought to integrate cortical and subcortical networks; degeneration of von Economo neurons and fork cells are not found in AD or healthy brains\textsuperscript{99}. In addition, as summarized elsewhere\textsuperscript{95}, amyloid tracer imaging, diffusion tensor imaging, and functional connectivity studies have proven useful in distinguishing FTD from AD.
**FTD treatment**
Treatment for FTD is often aimed at reducing behavioral symptoms with common psychiatric medications, particularly selective serotonin reuptake inhibitors, widely prescribed. Novel treatments aimed at inhibiting aggregation of tau and other proteins are under investigation.
**Mixed Dementia**
Further complicating research aimed at distinguishing types of dementia is the fact that dementias often co-occur\textsuperscript{100-102}. VaD and AD, in particular, have been shown to co-occur with high rates of overlapping brain pathology (i.e., both evidence of vascular damage along with amyloid plaques and neurofibrillary tangles), sometimes in addition to evidence of Lewy bodies\textsuperscript{102}. The high rates of overlap point to a combination of different neurodegenerative processes that underlie cognitive deterioration associated with dementia.
**Prion Dementia**
Prion diseases such as Creutzfeldt-Jakob disease (CJD) represent a rare type of dementia caused by misfolded, self-propagating, rapidly accumulating prion proteins, the result of which is neurodegeneration\textsuperscript{103,104}. In contrast to most other dementias that progress slowly, prion dementias are often characterized by rapid progression with death occurring within a few months to years of onset. Prion diseases are most often spontaneous (80-95%) but can also be genetic (familial; 10-15%) or, on rare occasions, acquired through accidental transmission (e.g., surgical or ingestion of infected meat; 1%)\textsuperscript{105}. Typical symptoms of spontaneous CJD, the most common prion disease, include imbalance and incoordination, memory loss and impaired thinking, and psychiatric symptoms such as anxiety or depression; however, CJD affects many areas of the brain and its presentation is variable and often initially difficult to distinguish from neurologic or psychiatric conditions.
**Prion Dementia Risk Factors**
Mutations in the human prion protein gene, PRNP, that make the protein more susceptible to misfolding, appear to be associated with various forms of prion diseases\textsuperscript{104}.
**Prion Dementia Neuropathology**
Neuropathological findings of prion diseases include varying severity of atrophy, vacuolation, astrocytic gliosis, and prion protein amyloid plaque deposition. Prion-related neuropathological findings are reviewed elsewhere\textsuperscript{104,105}. Notably, prions tend to co-localize with amyloid plaques\textsuperscript{106} and have been shown to promote plaque formation\textsuperscript{107}.
**Prion Dementia Imaging**
Brain MRI has been shown to have high diagnostic utility for sporadic CJD\textsuperscript{105}. Specifically, restricted diffusion in cortical or deep nuclei gray matter and hyperintensity in cortical gyri, caudate, putamen, or thalamus have been associated with both sporadic and familial forms of CJD; however, gross abnormalities may also be absent. Acquired CJD can be distinguished from other human prion diseases by the “pulvinar sign,” in which the pulvinar is brighter than the anterior putamen.
**Prion Dementia Treatment**
There are no treatments for prion diseases and the often rapid progression of the disease renders clinical trials a significant challenge. Similar to other neurodegenerative disorders, however, pharmacological interventions are currently being investigated along several fronts including immunotherapy and prevention of prion protein aggregation with doxycycline, thus far with mixed or negative results\textsuperscript{108}. Promising initial studies aimed at preventing prion protein conformational changes have shown evidence of decreased vacuolation and prion protein deposition along with slowed neurological and psychiatric symptom progression in mice and macaques\textsuperscript{109}. Effective treatments in humans remain to be discovered.
Conclusions
Growing evidence suggests pathogens may play a crucial role in the development of dementia. Compelling evidence over the last several decades has strongly implicated pathogens in AD and emerging evidence suggests that pathogens may be involved in other dementias as well. We have hypothesized that exposure to pathogens in the absence of immunogenetic protection against those pathogens (due to HLA-antigen) incongruence leads to dementia\(^{20}\). Conversely, an HLA-antigen match with sufficient binding affinity and ability to mount an immune response may protect against dementia\(^{18, 20}\). This perspective focuses on the evolutionary protective role HLA plays in the elimination of foreign pathogens to facilitate host protection against a variety of conditions including dementia.
Acknowledgments
Support was provided by the University of Minnesota (the Kunin Professorship for Women’s Healthy Brain Aging, the Brain and Genomics Fund, the McKnight Presidential Chair of Cognitive Neuroscience, and the American Legion Brain Sciences Chair) and the U.S. Department of Veterans Affairs. The contents do not represent the views of the U.S. Department of Veterans Affairs or the United States Government.
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Materia Secunda: Text as Image, II
Abstract:
This paper is an extension of the arguments and examples offered in ‘Materia Prima, Text-as Image’ (Calvert: 2012), where the materiality of language was foregrounded, rather than its transparent role in communication. The claims of neutrality to content in *The Crystal Goblet*, made by Beatrice Warde, alongside ideas from various traditional philosophical sources were contrasted with the work of concrete poets, artist, and designers, whose free-play with materiality in language upsets those relatively uncomplicated notions of transparency to content. The current paper proposes that in the next stage, we might think of the materiality of language as a kind of ‘event’, in which the raw materials of language (whether writing/typography/speech), are fully mobilized and enacted. This performative stage, which harnesses the dynamic attributes of language, is grounded by reference to Deleuze’s theory of the event, as well as Adorno and Benjamin’s notion of ‘constellation’. Katherine Hayles, Villém Flusser and others, are used to support the contention that we might think materiality and performativity/gesture, in language as a form of content. Lyotard’s Discourse/Figure is invoked as away to describe a different space of interaction between the textual and the figural, where the distinction between them is erased. Examples from art/design/typography are offered to support these points.
Keywords:
Language
Plasticity
Materiality
Performative
Event
Constellation
Transparency
Surface
Discourse
Figure
Contributor details:
Dr Sheena Calvert holds a Master’s degree from Yale University, and a Ph.D. in Philosophy and Aesthetics from the Department of Humanities, Media Arts Philosophy and Practice at the University of Greenwich. Her research is broadly concerned with rethinking the relationship between language and meaning, viewed through the lens(es) of identity, difference and paradox. Specifically, as a typographer, printmaker and graphic designer by background, her research interests are an extension of her long-standing involvement with fully engaging with the materiality of text/speech, as a form of knowledge about language. She teaches critical theory and practice of art/design/illustration at Central St. Martins, the London College of Communication and the University of Westminster. Her research workshop/studio, the .918 press, in London, E8, consists of a fully functional letterpress facility for the production of experimental printing and bookworks. Recent work undertaken includes the paper *Materia Prima* (*published in the* Journal of Writing and Creative Practice*. Materia Secunda*, and *Materia Tertia* (in progress), are part of a series of publications, investigating the possibility of a materially grounded philosophy of language, and which are supported by printed and digital works in the area of what Katherine Hayles has termed, with reference to Johanna Drucker’s work: ‘visual typography’. These are produced by the .918 press, and are seen as both a complement and extension of the ideas in these papers.
‘An almost infinite effort is required for the eye to give in to form, to become receptive to the energy stored therein. Here we must keep at arm’s length the assumptions, interpretations and habits of reading that we contract with the predominant use of discourse. It is precisely of this skill that discursive education and teaching deprive us: to remain permeable to the floating presence of the line (of value, of colour). From the very beginning, our culture rooted out sensitivity to plastic space’ (Lyotard 2011: 212)
In the opening quote, taken from *Discourse/Figure*, Lyotard reminds us that in a culture which is, and has been, dominated by textual discourse, language\(^1\) as a phenomena needs to be constantly interrogated and placed under scrutiny. In an earlier paper ‘Materia Prima, Text-as-Image’, written for the Journal of Writing and Creative Practice (Calvert 2012), I attempted to demonstrate how the materiality of language (whether written/typeset/spoken) has a potential, and latency, which precedes any specific instance of its participation in of communication/meaning: foregrounding languages’ base materiality, or ‘plasticity’, prior to its ordered configuration in discourse. Historically, and by convention, the material qualities
\(^1\) The word ‘Language’, for the purposes of this paper, is to be understood as those forms of communication which involve, variously, written/typeset/spoken words, and which convey content from the minds of one person to another. Typography, as in the setting of text as a particular group of aesthetic practices, is not per se the subject matter of the paper, but is acknowledged as forming one aspect of the material dimension/presentation of language: how it ‘looks’, or languages’ ‘visuality’. However, the paper takes a step back from a view of language as a transparent vehicle for content, and focuses on its raw material: prior to denotation. This primary material is argued to have a productively disruptive presence in the field of communication, one which constitutes a different kind of meaning.
of language (taken in its broad sense to mean writing/speech), become subservient to semantics/meaning; slipping into the background, as though an invisible window onto content. The term ‘material language’, as used throughout this paper, can be compared to what Katherine Hayles has termed ‘visual typography’ (Hayles 2002: 65), where the visual attributes of letters, including typestyle, scale, construction, are components in the establishment of meaning, and in which the medium is as significant as the message conveyed: what Hayles refers to as a ‘typotext’ (Hayles 2002: 65). While Hayles wonders why materiality has been an underexplored subject within literary studies, she states that: ‘Significant Exceptions include the tradition of artists’ books and the exuberant experiments of such materially-based practices such as concrete poetry’ (Hayles 2002: 19)
However, the aim of this paper, and the earlier one, is to extend these definition of material language, or ‘visual typography’ to include reflections on the non-stylistic characteristics of language, and to look beyond the construction or typographic presentation of letters in the way Vilém Flusser proposes: ‘If we want to seize what the gesture of writing really is about, we have to consider its original form’ (Flusser 1991:1). He goes on to say, of writing that:
It has nothing to do with constructing. It is, on the contrary, a taking away, a de-structuring. It is, both structurally and historically, closer to sculpture than to architecture. It is a gesture of making holes, of digging, of perforating. A penetrating gesture. To write is to in-scribe, to penetrate a surface, and a written text is an inscription, although as a matter of fact it is in the vast majority of cases an onscription. Therefore to write is not to form, but to in-form, and a text is not a formation, but an in-formation. I believe that we have to start from this fact, if we want to understand the gesture of writing: it is a penetrating gesture which informs a surface.
—Flusser, The Gesture of Writing, 1991.
In this essay, Flusser is concerned with the material event of writing, not with any content or external reality which it may concern or denote. In returning the reader’s focus to both the material facts and actions of writing, he exposes the ways in which writing becomes: ‘a gesture of such complexity that it defies description’ (Flusser 1991: 2). In doing so, he explicitly suggests that we focus on pure form, or plasticity in-itself as a source of meaning for the act of writing; an approach which does not rely on the stylistic attributes of text as it appears on the page, and which stands distinct from the discipline of typography, which: ‘is concerned with the determination of the appearance of the printed page’ (Bil’ak, P. ‘What is Typography’, (Typotheque: 2007). However, as Lyotard points out, in the quoted passage from Discourse/Figure which opens this paper, (Lyotard 2011), there are ‘assumptions’ which we bring to the habits of reading, which deprive us of the ability to appreciate the
plastic/material qualities of language as part of the establishment of meaning. Katherine Hayles, in ‘Writing Machines’ (Hayles: 2002) explains how in the consideration of written texts, even cultural studies, which has traditionally paid more attention to materiality, usually focuses on ‘artifacts outside the literary text rather that the text itself as a material object’ (Hayles 2002: 19). These habits extend from readers to writers, whose understanding of the role of the materiality of language (usually demonstrated in the form of typography) in the publication of their works, is frequently limited, and is often relegated to the functional realm, where aesthetic considerations of the typographic style in which text is presented are secondary, if relevant at all. This in turn invokes Beatrice Warde’s remarks in her classic essay: ‘The Crystal Goblet, or Why Printing Should be Invisible’ (Warde, 1955). To briefly reprise Warde’s argument:
“Imagine that you have before you a flagon of wine. You have two goblets before you. One is of solid gold, wrought in the most exquisite patterns. The other is of crystal-clear glass, thin as a bubble, and as transparent. Pour and drink; and according to your choice of goblet, I shall know whether or not you are a connoisseur of wine. For if you have no feelings about wine one way or the other, you will want the sensation of drinking out of a vessel that may have cost thousands of pounds; but if you are a member of that vanishing tribe, the amateurs of fine vintages, you will choose the crystal, because everything about it is calculated to reveal rather than hide the beautiful thing which it was meant to contain. Bear with me in this long-winded and fragrant metaphor; for you will find that almost all the virtues of the perfect wine-glass have a parallel in typography… The most important thing about printing is that it conveys thought, ideas, images, from one mind to other minds. This statement is what you might call the front door of the science of typography. Type well used is invisible as type, just as the perfect talking voice is the unnoticed vehicle for the transmission of words, ideas”.
(note: I have an original copy of Warde’s book, and will scan and introduce the text as an image, as with the Flusser)
Rooted firmly in printing history, and the tradition of fine book design, Warde’s comments reflect a significant and long-lasting prejudice in typographic circles, and those of writers, that typography should be invisible to content, and that the material qualities of written language should not be allowed to interfere with the transmission of ideas, from the mind of the writer, to the mind of the reader. This prejudice, arguably, dominates the world of book design, and infers that the relationship between the writer of words, and the typographer should be one where ‘invisibility’ reigns. Throughout ‘Writing Machines’, Katherine Hayles challenges this view, and updates its significance for digital literature (Hayles 2002). Flusser, in ‘The Gesture of Writing’ (1991), and ‘Does Writing Have a Future?’ (1987), focuses on the act of writing, rather than what writing ‘does’. Philosophers from Derrida to George Steiner, have made significant contributions to the way we understand language in its broadest sense, and specifically in its relation to materiality (cf Derrida ‘Of Grammatology’,
However, it continues to be the case that aside from well-documented historical experimental works such as Derrida’s ‘Glas’ (Derrida, 1986). Or Avital Ronell’s ‘The Telephone Book’ (Ronell, 1989), and more recent work by the publishing house Visual Editions, who have collaborated with writers such as Jonathan Safran Foer, those writers who have concerned themselves with the material attributes of their language, are still working largely against the received wisdom, and norms for textual presentation: challenging the paradigm long established by Warde and her conservative proponents.
In response, in *Materia Prima, Text-as-Image I*, I showed some relatively simple examples of how typographers, designers, artists and illustrators have historically intuitively understood the ‘performative’ nature of language as a plastic/material phenomena, and have freely played with its creative potential, or ‘energy’, both in collaboration with writers, poets and artists, as well as autonomously. I advocated a step back to allow a refocusing on the inherent, material attributes of written language, as source of meaning (this argument could be equally applied to speech, but the paper did not address this, except tangentially). The argument made there included reflections on concrete poetry, book artists, and others, including e. e. cummings, H. N. Werkman, Tom Phillips, Kurt Schwitters, and the work of the artist Cy Twombly. The proposition of ‘Materia Prima’ was that the numerous artists, typographers, designers, writers and illustrators who have worked both in collaboration and alone, demonstrate the role of materiality in language as a partner in the production of meaning, by exhibiting language ‘as such’. They fully engage with John Dewey’s remark, ‘All language, whatever its medium, involves what is said, and how it is said, or substance and form’ (Dewey 1980: 106). Dewey’s comment reinforces the significance of medium, or the formal qualities of language, as an intimate partner in the production of meaning, and communication. For Dewey, the subject matter of language (what it refers to) is different from language itself (its matter, or material), but the latter affects or modifies the former. In the contemporary context of digital literature, Hayles describes these phenomena as ‘technotexts’, where: ‘the physical form of the literary artifact always affects what the words (and other semiotic components) mean’ (Hayles 2002: 24). This constitutes what she terms a ‘media specific analysis’, wherein ‘technotexts is a kind of criticism that pays attention to the material apparatus producing the literary work as physical artifact’ (Hayles 2002: 29). Hayles, Flusser, Dewey, Derrida, and others, all return reflections on language to its ‘surface[s]’, which is the philosopher Richard Shusterman’s departure point. He locates a phenomenon within the traditional literary and philosophical communities, of a deep antipathy towards writing, in favour of the ‘authenticity’ of speech. Shusterman proposes that the surface of language (along with both windows and pixels) is frequently invisible; it often has no more than a residual impact upon our conscious apprehension: ‘We do not usually notice the
surface of our glass windows because we are looking through them; nor do we notice the particular color and size of the pixels on our computer screen as we look at them to grasp the images they constitute’ (Shusterman 2002: 159)
What this remark unequivocally establishes is that by convention (one could almost go as far as to say, by definition), language is supposed to ‘point’, away from itself, and towards another concept, reality or object. The surface is redundant (echoing Warde), but Shusterman, unlike Warde wants to argue for a revisitation of the importance of surface, not to reinforce its redundancy. However, in referring back to itself, as material, matters of communication become complicated and paradoxical, since when the graphical ‘surface’ of language is emphasized (for the purposes of Shusterman’s proposition, to be understood as typeface, size, position, etc.), and languages’ role in communication is exposed the usual distinctions between discourse and figure (Lyotard 2011), text and image, collapse in a vortex of self-referentiality.\(^2\) We are entered into a paradoxical space, where initially it is not clear what language \textit{is} under these conditions. It seems to have no role, and, moreover, upsets notions of transparency in communication, since it points towards itself, and nothing else, with the full opacity of language, constituting what Lyotard terms a ‘scandalous’ form of materiality, which disrupts the conformity of textual relations (Lyotard 2011). However, as the typographer and artists highlighted in ‘Materia Prima’ confirm, after reflection, we see that with the relative slowness of the figural (image), the persistence of the plasticity of form in text (discourse) brings us to a stop, creating another space of reflection, somewhere between the figural and the discursive. As Lyotard remarks, ‘Once again it [plasticity] will slow down the eye, and judgment, forcing the mind to take position in front of the sensory’ (2011: 212). He proposes that we need to pay attention to this visual surface, in order to fully understand written language\(^3\), through ‘the understanding of the graphic form in and of itself, and thus the patient probing of the plastic meaning it carries’ (2011: 211). Giorgio Agamben states this same point, slightly differently; ‘To bring the word to a stop is to pull it out of the flux of meaning, to exhibit it as such’ (Agamben 2002: 317), and Arthur C. Danto reiterates it, in a remark about cinema that can easily be reinterpreted with respect to language:
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\(^2\) Lyotard’s understanding of the relationship between text and image is distinct from the critic W. J. T. Mitchell’s ‘textimage’ (WJT Mitchell, Iconology: Image, Text, and Ideology, 1987), which Hales criticizes as not fully recognizing the significance of text-as-image, but stays at the level of texts and images alone (Hayles 202: 20), and does not acknowledge any other forms of materiality. Lyotard is attempting subtle critique of structuralism, in which, he argues, the discursive and the figural modes of knowing have been separated within abstract thought. He wants to defend the importance of the sensual, and figural (associated with seeing), in the mutual implication of discourse and figure. He cites the examples of poetry, and illuminated manuscripts, which bring discursive and figural modes of knowing into alignment (Lyotard 2011).
\(^3\) These remarks about ‘surface’ can be extended to include spoken language and its acoustic properties, but a full explication of this point is outside the scope of the present paper.
We do not become aware of [language/time] in ordinary [reading] because too much takes place in [language] for [language] itself to become the object of consciousness’. The sign can signify anything except that it is in the process of signifying. (1997: 67)
In summary, I proposed to call these kinds of self-referring, figural/plastic language *Materia Prima* or *Prima Materia*, the Latin term for ‘primary matter’ or ‘first source’. It was used to suggest a form of material language that has no function other than to be an image of itself, or to refer to its own ‘surfaces’, possessing an almost alchemical quality, comprising formless, undifferentiated base material(s), which nonetheless possesses enormous creative and analytic potential. In other words, this *Prima Materia* was posed as an undifferentiated plastic material that has a different kind of meaning, and which has the potential to close the space between image and text, or between what Lyotard has describes as the discursive and figural.
For instance, the printed experiments of H. N. Werkman exemplify the idea that; ‘freedom of the press belongs to those who own one’ (Leibling: 1960), also that type can function independently of communicating a specific message, or denoting something external, and that his playful method of working with text (in this case, the medium was letterpress) is as productive as any specific intentionality, system, or method. “The subject *proclaims* itself, and is never sought”, he would say, in terms of his habit of working directly on the bed of the press, and seeing what emerged. This is not language as an instrumental partner in the expression of ideas, concepts or reason; which takes a backseat, or hides in the shadows, as Warde proscribes, but something closer to a musical instrument, being ‘played’, and which can be experienced at the point where text ‘kisses’ paper, and ink sticks to the surface of wood and metal; the tones and gestures of the visual surface, resonating with sensual and visual frequencies. This is intense radical material articulation, operating at the visual surface; drawing our attention firmly toward the surface, using language as *Material Prima*, or a-priori, undifferentiated form. In doing so, it articulates the point at which meaning is/is not established in written language, by attempting to break the link between text/type/writing, and meaning. Its very failure to fully do so is meaningful.
With his self-authored use of print as paint, Werkman, understands that the material event of language is meaningful in and of itself; requiring no other justification. Language just ‘is’ in his hands, and its full opacity makes no concessions to any author of the words. The intelligence of this work is in the stand it takes against ‘transparency’, and in its radical concern with the ‘matter’ of language/communication. It also begs the profoundest of questions about “the thin film at the limit of words and things” (Deleuze: 1969, 38), in ways which any number of written accounts cannot accomplish. This is the metaphor through which Deleuze attempts to describe the notion of ‘sense’ in language. By attempting to break the link between printed text and meaning, yet never quite succeeding, Werkman is able to
articulate these questions at more than just a metaphorical level, and without closing them down; allowing room for interpretation, through fearless experimentation with the primary material(s) of language.
Similarly, the artist Cy Twombly’s work conspicuously foregrounds the act of reading; the ‘work’ of language, not the meaning of words themselves. In other words, it asks you to ‘hear’ the hearing of the work, to ‘read’ the reading, and to look at the surface presentation of the drawn, marked, inscribed, heavily materialized written language he employs. This applies as much to his work with text as with image or symbol. He constantly defers meaning in favour of focusing on material expression. Working almost three-dimensionally with thick impasto, and scratched marks on surfaces was, for Twombly, a way of exploring materials and the meaning they promised, but did not reveal.
John Berger puts it in this way: ‘Twombly imposes his materials on us not as something which is going to serve some purpose, but as absolute matter, manifested in its glory’ (Berger 2002). As Werkman exposed, whether it is possible to make work with written language that is entirely self-referential, since even the most ephemeral or distorted elements of a visual language tend to cling tenaciously to meaning, is an open question, and one that Twombly, Werkman and others from the worlds of concrete poetry and artistic practice are at the centre of. In a remark about Twombly, Berger pointed to the inherent complexities in this project when he said:
“The materia prima [raw material] is what exists prior to the division operated by meaning: an enormous paradox since nothing, in the human order, comes to man unless it is immediately accompanied by a meaning, the meaning which other men have given it, and so on, in an infinite regress. The [demiurgic] power of the painter is in this, that he makes the materials exist as matter; even if some meaning comes out of the painting, pencil and color remain as “things”, at stubborn substances whose obstinacy in “being there” nothing (no subsequent meaning) can destroy.” —The Wisdom of Art, John Berger
Cy Twombly: *Untitled*, Lexington, 1959, House paint, crayon and graphite on canvas. 152.5 x 188.5 cm, 60 x 74 1/4 inches
Image 2: The PDU (Plaque Découpée Universelle) is a universal stencil created by Dries Wiwauters (based on a stencil system patented by Joseph A. David in 1876). The stencil can make uppercase, lowercase, accents and so on - Each cut can make 1579 glyphs. This simplification of the visual codes of written language, points us to the formal attributes of language, but also highlights its arbitrary nature: lines/circles/angles.
Following Lyotard’s logic, in a self-initiated project considering the arbitrary nature of linguistic form, and its base materiality, Margherita Brooke-Huntley, a recent graduate of Central St. Martins College of Art, produced the following series of explorations of typographic form/language, which respond to Lyotards’ idea that ‘A line, without the system of connoted meaning is unrecognisable.’ (Lyotard 2011: 211). The letters, broken down into their constituent parts, become unrecognizable: *Materia Prima*. At a second level, they take form, and become readable (once the system is learned). In the final iteration (lower image), the original line from Lyotard’s text is rewritten, in this new, disjunctive typeface, created from the dismembered parts of the original.
‘A letter’s rhythm, position and sequence refer to a position occupied by the reader’, the text ‘faces’ the reader. Letters don’t represent anything, they are not pictograms: ‘A, N and Z all have the same constituent parts/lines. They are terms that are only to be recognised as part of their place in the system they belong to (the alphabet/word) and their spacing (i.e AN, A, A NZ, ZAN etc)’. Punctuation and spacing changes meaning. ‘Where figural difference once reigned, now informational space operates only (with indications regarding pauses, but could rhythm suffice without punctuation?)’ (Lyotard 2011: 211).
“A certain view of the world, of consciousness, and of language has been accepted as the correct one, and, if the minute particulars of that view are examined, a rather different picture (that is also a non-picture as we shall see) emerges. That examination involves an enquiry into the ‘operation’ of our most familiar gestures” —Gayatri Spivak: Preface, ‘Of Grammatology’, Derrida, 1974.
Having reiterated the basic premise of Materia Prima, where the raw material of (in this case, written) language is foregrounded in place of transparent communication, the present paper wishes to further extend these arguments, and add another layer, by metaphorically referring language to the notion of *Materia Secunda*. In this stage of the ‘four worlds’ the potential of matter, or ‘Materia Prima’ is realized and set in motion.\(^4\) Applying Aristotle’s definition of *entelechy*, which is the condition of something whose essential potential is fully realized (actualized), this is where, it will be suggested, the full potential of language-as-raw-material is engaged. Moving forward from these earlier remarks about base materiality, or *Materia Prima*, I will now use the metaphor provided by *Materia Secunda*, to establish how it might affect how we understand the nature of language, and for the purposes of Book 2.0, specifically the relationship between this new understanding of type/language/writing, and the writer of words. These arguments are, by their nature, more abstract, and less easy to demonstrate at the level of the figurative qualities of language, and so in this paper, I will include some expanded reflections on the potentially productive relationship between philosophy and/as a form of type/writing. This will be seen through the lens of writers such as Walter Benjamin and Adorno, whose notion of ‘constellation’ subtly but fully engages the materiality of language in its formulation of a style of philosophical thought, while Gilles Deleuze offers the notion of the ‘event’, as a way to speak about the inexpressible attributes of language, where mobilization of the dynamic attributes of language takes place.
‘In the broadest sense, materiality emerges from the dynamic interplay between the richness of a physically robust world and human intelligence as it crafts this physicality to create meaning’ — Katherine Hayles, *Writing Machines*, 2002: 33
\(^4\) Materia Prima and Materia Secunda are terms taken from Genesis, and are used in a loosely metaphorical sense throughout these essays. In the former, the raw materials, or formative elements (earth/fire/water), are considered a blueprint to be mobilized through the next stage (Materia Secunda), which is described as the third of the four worlds. ‘*Materia prima*, cannot itself be known, inasmuch as things are known through their form: *Materia prima* is the subject of every form’ (G. M. Cornalidi, SJ, ‘The Physical System of St. Thomas: 1893). In Materia Secunda those raw materials become active and enabled, subject to modifications and application. In Materia Secunda we see the dynamic attributes of language set in motion.
Hayles places human action at the centre of this process, and it is this interplay between the raw material of language and its enactment that this section concerns itself.\footnote{The third part of this series of remarks: \textit{Materia Tertia} (paper in progress) will assess how these dynamics change within synthetic speech and artificial language(s) contexts.}
\textbf{Event/Sense}
In the chapter: ‘Twenty-Sixth Series of Language’, in ‘The Logic of Sense’, Gilles Deleuze attempts to show how the ‘event’ haunts language. The ‘event’, which is unspoken, and incorporeal, nonetheless makes language possible, subsisting in language as its primary means of expression, and partaking in the moment of expression.
‘The expression, which differs in nature from the representation, acts no less as that which is enveloped (or not) inside the representation… Representation must encompass an expression which it does not represent, but without which it would not be ‘comprehensive’, and would have truth only by chance or from outside’ (Deleuze: 1990, 145)
The event is that which is cannot be represented, but which nonetheless makes expression possible. Representation, according to Deleuze, is extrinsic by nature, operating on the basis of resemblance, or mimesis (understood as replica/copy); exclusively externalized in a process which fixes meaning. However, there is something which consistently escapes this manner of representation; a matter internal to the expression (enveloped, or subsisting within it), which provides its fully ‘comprehensive’ character while remaining enigmatically inexpressible at the level of the textual ‘image’. The example Deleuze uses to explain the concept of this ‘unrepresentable’ is death, which is a concept forever extrinsic to the signification as long as actual death is not realized: in other words, death is ‘deprived of sense’ in advance of the event of death. In this respect representation is always abstract and empty; incomplete and unfulfilled. Another way of saying this is that:
‘Representation envelops the event in another nature, it envelops it at its borders, it stretches until this point, and it brings about this lining or hem. This is the operation which defines living usage, to the extent that representation, when it does not reach this point, remains only a dead letter confronting that which it represents, and stupid in its representiveness’. — Deleuze, \textit{The Logic of Sense}, 1990: 145
Without the event, representation would remain ‘lifeless and senseless’: the ‘extra-representative’ exceeds the functional. However, Deleuze wants to retain the tension between the representable and the non-representable as that which makes possible the fullest form of representation and this is where the object (in this case language), is fully mobilised.
The accounts of material language offered in *Materia Prima* seem at first encounter to be incompatible with this view, or at least of different kinds. For example, in Richard Shusterman’s work, there is an interest in promoting visible language as a factor in meaning; right at the sur[face], at the level of the *Materia Prima*, while Deleuze’s ‘event’ proposes an expression which is internal and invisible to language, but nonetheless intrinsic and crucial to meaning; something unrepresentable but essential. The visible/invisible distinction traversing these two arguments would seem irreconcilable. However, it seems reasonable to suggest that the material forms of language are of the nature of an ‘event’ in the sense Deleuze proposes, and that it is only at the level of the ‘pure’ event that language has full meaning (in the stage called *Materia Secunda*). It is here, where written language is both specific in terms of the uniqueness of each ‘event’ of language (each utterance, each printing, each inscription is an unrepeatable event), and where at the same time such language is abstracted from its specific application as a bearer of meaning or sense, that we see something newly-meaningful in the raw materials and dynamics of language (in the form of language in-itself, not language as a transparent vehicle for communication cf. Warde). For the purposes of this paper, we could say that the *Materia Prima* of language (the base material) requires the stage *Materia Secunda* (energy/event), to mobilize the full power of language as representation, and that this is the place where the text and the writer need to rendezvous. Where materiality and event configure, is the place where language and meaning become coterminous; where the ‘space’ of literature takes place (Blanchot 1989).
In this scenario, rather than instrumental, purely denotative, or invisible to content (as in Warde’s claim), language might be thought of as differently ‘tensioned’, as in the skin of a drum which involves the literal tensioning of a surface to achieve textual (and acoustic) modulations, and which involve various resonances, expansions, contractions, temporalities, movements. In place of instrumental forms of language, we could productively contemplate language as an instrument, which needs to be ‘played’ with a sensitive eye and ear to form. This in turn, takes language to a kind of anarchic extreme, where: ‘[For Deleuze], writing means pushing the language, the syntax, all the way to a particular limit, a limit that can be a language of silence, or a language of music, or… for example, a painful wailing.’ (Deleuze, 1988-89 cf. Kafka’s *Metamorphosis*).
Poetry could be claimed to be a residual example of the event-based anarchy of language, whose complexity has not been entirely stripped away in favour of function: ‘literature is concerned with the event of language, far more than the event in language.’ (Lecercle 2002: 130). Wittgenstein went as far as to say that ‘Philosophy ought really to be written only as poetic composition’, (cited in G. H. Von Wright 1980: 24) suggesting that the only way to do philosophy is to take it to the limits (and beyond) of language, and to critique it on its own terms, immanently (internally: from within), in the same way that poetry
becomes a critique of language. This requires a different orientation to the relationship between type and writer: one which respects the dynamic tension between the metaphysics of language (its immaterial qualities), and the physical properties of language as a concrete *fact*. Taken in this sense, language (in the broad sense) can be seen as a kind of controlled chaos, borne of the marks and sounds made by the body. It is irreducibly complex at the surface, and while articulation takes place, and communication does happen, it frequently does so at the expense of that complexity: Lecercle makes this point with respect to speech: ‘The materiality of sounds is inseparable from the ideality of articulate language.’ (Lecercle 2002: 129).
Rather than trying to suppress the full articulation of language, by separating form from content, those writers who appreciate the intrinsic qualities of language as expression, are able to harness the full power of the dynamic tension between representation and meaning by harnessing the full materiality and event-ness of language (text/writing/speech). By consciously, or unconsciously working with material language in this way, creative practitioners and writers supplement our understanding of language, by drawing attention to those materially-bound qualities of language which cannot be spoken or written about. In other words, they enact, rather than describe, aspects of language which remain at the root of most critical discourses on language, but which are perforce unable to account for the materiality or ‘event’ of language, since they have no view from outside language where they could take language as an object of examination (this would require a theoretical point outside language, known as ‘a view from nowhere’).
In contrast, as Walter Benjamin recognizes, for James Joyce, language is a form of activity which constitutes its *own* essence, rather than participating in pre-established discursive forms. His efforts are directed towards breaking the link between language and meaning as something pre-constituted, in favour of language as a mimetologically, constitutive medium in its own right. Joyce’s language *does* something, *creates* meaning (although, in truth, language never arrives for Joyce, it’s always on detour), and actively engages Samuel Beckett’s injunction that language should be ‘alive’, bringing it closer the event which Deleuze speaks of. Speaking of Joyce’s work, in his book ‘Dante, Bruno, Vico, Joyce’, Beckett writes: “Words are not the polite contortions of 20th century printer’s ink. They are alive. They elbow their way onto the page, and glow and blaze and fade and disappear” For Joyce, both life and language are immanent: they have no ground, or origin. (Ben Zvi 1980), echoing Beckett’s remark that: “There is no communication because there are no vehicles of communication.” (Beckett 1957: 47). Joyce effects: “the writing that you find so obscure is a quintessential extraction of language and painting and gesture, with all the inevitable clarity of the old inarticulation.” (Beckett 1957). For Beckett, Joyce is able to move beyond what he sees as the inherent abstraction and limits of English, to find a raw, direct authenticity which is closer to gestural forms of painting, out of the
immanent/immersive act of *making* language: an ‘event’, in which final meaning is never fully articulated.
Image 1. This example of James Joyce’s literary self-constitutions includes both Joyce’s proof-level annotations, and the playwright Thornton Wilder’s attempts to ‘understand’ the text (or to decode it), through extensive personal annotation, we see how the text resists the assignment of singular meanings, due to its ‘constellatory’ structure, and the heterogeneous play of linguistic signifiers, which refer the reader back to the operations of the text itself.
To further contextualize this point, Joseph Kosuth’s *First Investigations* (subtitled *Art As Idea As Idea*), consists of a series that includes photostats of dictionary definitions of words such as “water,” “meaning,” and “idea.” The simple presentation of the dictionary definition of the word ‘meaning’, sets out the terms of a different engagement with the embodiment of ideas in language: questioning the terms significant, unambiguous, signified, *referred* to. This work can be seen as responding to Kosuth’s comment that:
“Being an artist now means to question the nature of art. If one is questioning the nature of painting, one cannot be questioning the nature of art . . . That’s because the word ‘art’ is general and the word ‘painting’ is specific. Painting is a *kind* of art. If you make paintings you are already accepting (not questioning) the nature of art.” — Kosuth, *Art After Philosophy*, 1969
In the same way, there is an argument to be made (Derrida, Adorno, Benjamin, Flusser, Hayles and others have made it), that being a philosopher, or a writer, should make you question and exploit the nature of language, as the primary material within which ideas are communicated. This was certainly for numerous writers such as James Joyce and Raymond Roussel, and philosopher/writers such as Benjamin and Adorno. The medium in which literature and philosophy is expressed is language, and therefore it should be scrutinized as a medium in its own right, irrespective of any specific content, but in terms of its role in enframing concepts (see Hayles’ ‘Media Specific analysis’ 2002 and Flusser’s ‘Does Writing Have a Future?’ 1987). To actively demonstrate this discursive, self-reflexive aspect of art, Kosuth employed language itself as his medium. What resulted was a rigorously Conceptual art where intellectual provocation was placed parallel to perception, and words displaced images and objects. The work is therefore about the idea of meaning, rather than meaning itself. Deleuze, Derrida and others asked: Where *is* meaning? For Deleuze, it’s in the ‘sense’ of a word, at that: ‘thin film at the limit of words and things’, implying that it’s both part of, but separate from, the word: metaphysical, but physical at the same time; forming a nexus where sense and nonsense coexist; an event which is involved in both creating and dissolving a limit at the same time.
Joseph Kosuth, (Art as Idea as Idea) *Meaning*, 1967, Photostat on paper, mounted on wood.
Philosophy, literature, design and the fine arts frequently occupy different spheres of knowledge, and constitute separate bodies of practice. With a view to the broader aims of the Book 2.0 series of volumes, to build connections between often disparate communities, I would like to revisit the term ‘constellation’, as a way to think about artworks, literature, and philosophies, which engage it as a method, and in which it mobilizes the relation between writer and text, in a subtle way. There is value in considering the continued relevance of the practice and theory of constellation as both a ‘performance’ (linking it to the ‘event’ as described previously) of language, and a style of thinking, in which new forms of thought are promised, and where experimentation with language is pushed to a limit and beyond. In this respect, the writings of Walter Benjamin and Thodor Adorno are key to unlocking the potential of ‘constellation’ as a structural device for understanding language as enactment/event.
Constellation is Walter Benjamin’s term for the method of relating ideas in a montage of fragmentary, disjunctive, often temporally unrelated configurations, which nonetheless produce meaning by allowing unseen correspondences to emerge, instantaneously. This method can be seen most clearly in Benjamin’s *Arcades Project*, (Benjamin Belknap Press 2002). His methodological preference shares an affinity with Adorno’s notion of constellation (which Adorno in turn explicitly borrowed from Benjamin), as the process which unlocks the ‘specific side of the object’, and where the particularities and objectivity of phenomena exceed conceptual categories (Adorno 1990: 162). Benjamin explains the constellation as the place where:
‘[I]deas are not represented in themselves, but solely and exclusively in an arrangement of concrete elements in the concept: as the configuration of these elements… Ideas are to objects as constellations are to stars’
— Walter Benjamin, *The Origin of the German Tragic Drama*
Adorno’s understanding of constellation has been described as: ‘a juxtaposed rather than integrated cluster of changing elements that resist reduction to a common denominator, essential core, or generative first principle’ (Jay 1984: 14-15). He utilizes the constellation as a way to challenge how concepts (mental constructs, or ideas) operate in ‘identity thinking’. Such identity thinking, or conceptual thinking wants to make a simple or generic classification of something thought, in such a way that objects of knowledge are blocked by such thought from achieving their fullness. As part of this classifying procedure, such concepts profoundly prohibit knowledge of the object, and strip away what Adorno would term the intramundane: the particularities, or singularities that make an object *what it is*, but
not in an essentialist sense (by observing the difference between things, not their shared identities). Such departures from identity thinking are controversial:
‘Once it has been decided what is to count as thought, that is, what is to count as describing reality, any thought that does not fall under that concept will be attacked as nonsensical: ‘[h]ence the fanatical intolerance of the method and its total arbitrariness against any arbitrariness as deviation’—Adorno, *Against Epistemology*: 1984, p13
Adorno’s argument is that the ordinary for of conceptual thinking (which is scaffolded by language) traps us into never seeing what lies beyond our concepts, in turn excluding the truth of things in themselves, and this is a major problem for thought, and a sticking point in terms of languages’ ability to provide access to truth. The fixity of language is a conspirator in this dilemma, since identity thinking is at the root of language, when it proceeds relatively unexamined.
Adorno’s answer to this problem is that concepts should ‘enter into a constellation […] which] illuminates the specific side of the object, the side which to a classifying procedure is either a matter of indifference or a burden (1990: 162). Since, ‘Such constellations of concepts ‘represent from without what the concept has cut away [excised] within’ (1990:162). They gather around an object of cognition, and in doing so they potentially attain what was excluded from thinking by the apparatus of concepts supported by language. In short: concepts block, while constellations illuminate. Concepts limit, while constellations expand and proliferate. Concepts are, in that sense, uncreative, while constellations are creative, iterative, and process driven, rather than limited by outcomes. The concept by itself, cannot but formalize, exclude (difference), freeze (in static time), and identify. All that needs to happen is that constellations explode the myth of identity thinking, and such groupings of thought as are provided by the constellation cause identity thinking to evaporate.
Combinations of multiple concepts displace single concepts, such that subjective thought replaces abstract identity. However, each concept in a constellation is itself to be subjected to the same process, in an infinite proliferation, and grouping concepts does not necessarily provide access to a truth hidden by conceptual categorizing, since language is implicated in both forms.
‘becoming aware of the constellation in which a thing stands is tantamount to deciphering the constellation which… it bears within… cognition of the object in its constellation is cognition of the process stored in the object’. (1990: 162).
The concept of constellation can also be seen in both Benjamin’s and Adorno’s philosophical writing styles in which they seek to enact these principles in which concepts are not reduced to categorical understandings, but are constantly exceeding their boundaries, or restraints. By preserving the contradictory and irreconcilable differences of arguments and observations in his work, Adorno maintains the tension between the universal and the particular, between
essentialism and nominalism while Benjamin finds meaning in the ‘interstices’, not in the direct objects of language, which resonates with the ‘event’ as a way of viewing the dynamic potential of language. Constellations can hold contradictory meanings in suspension without the imposition of a totalizing closure: they promise the ‘more’ which concepts cannot express, because their procedure is to classify/represent, rather than ‘present’.
The idea of ‘constellation’, then, is essential to understanding the aesthetic and formal qualities of the writing[s] of both Benjamin and Adorno, which are in turn immanent to their philosophical project[s]. In each writers’ work, form and content are not arbitrarily detached, but follow a simultaneously tightly woven but divergent path, which, for Adorno, denies the claim that: ‘In positivist practice, the content, once fixed in the model of the protocol sentence, is supposed to be neutral with respect to its presentation, which is supposed to be conventional and not determined by the subject’ (Adorno 1991: 23). As with Warde, presentation (form) is supposed to be a *disinterested* participant in the production of ideas. However, in his short work ‘The Essay as Form’, Adorno outlines the manner in which the form of philosophical writing, and its content, should be recognized as interdependent, in the same way that content and method are not to be rendered as separate, but intrinsically bound to one another. This leads him to the conclusion that it is necessary to: ‘[P]rise open the aspect of its objects that cannot be accommodated by concepts’ (Adorno 1991: 23)\(^6\). These involve the social and historical conditions of knowledge, which are lodged, or sedimented, to use Benjamin’s phrase, in discourse, and delimited by concepts, making it impossible to know *objects in themselves*. This argument could be equally applied to language as an objects of knowledge, and it is this potential which is the driving premise of the current paper. The aim of both *Materia Prima* and *Materia Secunda* is to bring reader and writer into a more intimate relation, and explore the im/material dynamics which are at the root of expression in writing/speech, and language in a broad sense.
Goethe, in his *Scientific Studies* points to the fundamental difficulty with correspondence theories of truth, grounded in simple notions of identity, or of language as transparent and objective: “How difficult it is… to refrain from replacing the thing with its sign, to keep the object alive before us instead of killing it with the word” (Goethe 1995: 275). For Benjamin, the constellation configures the conceptual and the empirical into their original intimate relation, so that the sign (word) and its object are reunited. He does not seek to resolve contradictions or oppositions, but to retain them as ‘residue’, or the non-communicable (Woodfield, Bush 2001: 137). Benjamin’s claim is that language has, over time, become predominantly instrumental, such that its mimetic, expressive aspects have been
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\(^6\) See *Materia Prima*, (Calvert 2012) for a description of Adorno’s Intramundane as expressed through a single printed letterform, which demonstrates how such history is sedimented in the object.
subordinated to its role as sign\(^7\). His contention is that the ‘paradisal’ relationship between language and object has been eroded over time, in favour of an aesthetically and experientially impoverished linguistic systematization where: ‘Logical analysis is the most extreme expression of an objectified experience of language. The living, breathing texture of everyday language is denuded into a formal, technical series of procedures’ (Crutchley 2001: 104). Compare this extreme rationalization of language with Steven Connor’s remarks, based on Bachelard, from his paper ‘Topologies: Michel Serres and the Shapes of Thought’, where he states that:
‘Bachelard emphasises the oneiric dynamism of the hand that is involved in any action in, and upon, the world, shaping the dough, or bringing to bear the black matter of the graphite on the white matter of the paper, in order that the paper may be ‘roused from its nightmare of whiteness’ — Steven Connor 2004, citing Bachelard 1988: 52.
Along with Event and Constellation as mobilizing attributes of language at the stage of *Materia Secunda*, where the raw material of *Materia Prima* is set in motion, I would like to offer a short remark on the role of noise in communication. Michel Serres thinks of noise as an unavoidable part of the transmission of information (Serres: 1980). Noise is a form of interference which happens in the process of moving any form of information between sender and receiver; one that occupies a frequency which registers chaos, disorder and nonsense as productive, not disruptive. Katherine Hayles concurs, as she considers the implication of noise within digital media (in the section of ‘Writing Machines’ entitled ‘Lexia to Perplexia’): ‘The noise that permeates the text may serve as a stimulus to emergent complexity, but it also ensures meanings are always unstable and that totalising interpretations are impossible’ (Hayles 2002: 60). This kind of heterogeneous expression is akin to the constellational thinking which Benjamin and Adorno employ, and is an inherent attribute of digital media. Noise, for Serres, implies movement and disruption, instability and disjunction, rather than linear, stable systems which cohere. Even the process of translation is material, and that ‘noisy’ materiality cannot (and should not) be eradicated. Yet rather than seeking to eliminate
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\(^7\) Saussure sees the sign as an arbitrary link between signifier and signified. Structuralism privileges a system of differences, in which signs are networked and relational, rather than possessing intrinsic/expressive/mimetically-announced meaning in and of themselves. Their value depends on their being oppositional to other signs within the system as a whole. ‘The essential feature of Saussure's linguistic sign is that, being intrinsically arbitrary, it can be identified only by contrast with coexisting signs of the same nature, which together constitute a structured system’ Roy Harris, Translator, Saussure, Course in General Linguistics, P. x (*need to complete reference*). Signs are not concrete, or grounded in experience, but abstract: markers or tokens in a structure to which they defer. “A sign is not a link between a thing and a name, but between a concept and a sound pattern” (Saussure p. 66). The sound of an element in speech is the signified, while the thought to which it relates is the signified. However, it is only within a system of similar ‘linked’ relationships between sound/concept, and sign/signified that meaning gets established.
noise as an unwanted ‘excess’ to communication, Serres suggests that it is precisely here, in the midst of this chaotic, cacophonous environment, that the potential for new forms of thinking emerges from the alternative patterns created (Hayles broadly agrees). Out of noise, new pathways, relations, movements, and assemblages are formed, bringing together the virtual, synthetic and aesthetic.
**Enactment**
In closure, and to show how these principles might work in practice, would like to close with two ‘visual’ examples of enactments of some of the ideas expressed in this paper. The theoretical terrain I have tried to establish, with the use of the metaphorical terms *Materia Prima* and *Materia Secunda*, are simply means by which to demonstrate how we might think about text-as-image, the ‘event’ of language, ‘constellation’, and the relationship between form and content (surface and depth). The true test of these ideas is in the engagement with the material and event-based forms of writing/text, which these examples promote, and actively interrogate.
Chloe True, Chatterly Black, 2012. Hand made pigment and silk screen.
Chloe True’s work (a recent graduate of the Design and Interaction course at Central St. Martins), shows how the plasticity of language can take on many guises, and offer multiple readings, related to the ‘constellation’. Returning to Lyotard’s distinction between the discursive and the figural, used to open this paper, this work arguably collapses that space in one gesture, or singular ‘event’. The work emerges from a project which required the exploration of a single colour, in this case, the choice was black. In her own words:
“Chatterley’s Black is a documentation of my investigation into the colour black, tracing a journey from page to pigment.
The novel Lady Chatterley’s Lover written by D.H. Lawrence in 1928 was never ceremoniously burnt, but it was banned in Britain, on the grounds that it was sexually explicit. Penguin books was prosecuted under the Obscene Publications Act for publishing the book, which contained the use of the words ‘fuck’ and ‘cunt’ multiple times, along with sexual scenes. It was banned completely in England and Wales until the conclusion of the trial; by the mid-1980s, it was on the school syllabus as well as having been adapted for the screen numerous times. Penguin Books relied on Section 4’s ‘public good’ defense, with academics and literary critics such as E. M. Forster and Helen Gardner testifying at the trial that the book was one of literary merit. The trial at the Old Bailey eventually ended with a not guilty verdict, allowing the unexpurgated edition of the book to be openly published and sold in England for the first time since it was published in 1928. The trial is said to have changed the face of literary censorship.
As a comment on the continually shifting boundaries of censorship, I staged a book burning of the first unexpurgated edition of Lady Chatterley’s Lover. I then used the ashes of the novel to produce a traditional carbon pigment. I named the pigment Chatterley’s Black and used it to screen-print a film still captured from the first English language adaptation of the book.”—Chloe True, 2012.
It doesn’t seem too much of a stretch to suggest that by collapsing the space between the discursive and the figural, or between text and image (the image is literally comprised of the text), and by the ‘event’ of language as a base material (reduced to pigment through the act of burning) as it forms the image (a single image was printed, since this was the amount of pigment produced), the work opens up the space for a constellation of meanings to emerge; none privileged over the others. This work can be seen as both text and image, not either one or the other. It becomes a narrative of, not only the colour black, but of censorship, language, erasure, materiality, etc. The work amounts to a paradox, in the sense that the ‘difference’ which it embodies, in its ability to be this/not this, shows us the limits of representational thinking; since, as it strains against that limit, it simultaneously (and paradoxically), retrieves the intensity of thought, seen through the lens of ‘plasticity’ as an interruptive/transformative force in the transmission of meaning. The text of the book is literally the image, in such a way that the discursive and the figural are realigned and space between them collapsed. The notable-to-be-said is very much at play in Chloe True’s work, and through the singular event of printing the image from the burned text of the book (rendered as pigment). Benjamin’s notion
of *Darstellung*⁸ acknowledges that truth cannot be the direct object of communication, but can only be glimpsed ‘para’ to its mode of expression, since it is not yet communicable in that form of presentation: in this case in the form of the photographic image.
In contrast, in Anthony Burrill’s Oil Spill poster (2010), the text is constituted from the subject matter, by being printed in the same spilled BP oil from the Gulf of Mexico, which is inferred in the text, in such a way that medium and message are fully integrated. The difference between ‘Chatterly Black’ and Burrill’s work is that in the former, there is a hidden, or ‘para’ dimension to the work, since the text of the book forms the invisible base substance of the printed medium, while in Burrill, that relationship is more direct, and the message far less ambiguous. In Chloe True’s work, the process, or event of mobilizing the raw material of the original text is as important (if not more so) than the final outcome, while Burrill’s poster embraces process, but relies on the audiences’ recognition of the materiality of the outcome. Each engage materiality, and the event of language, but to different ends. In both examples, the meanings established by the image are rendered connotative, not denotative, which for Barthes are understood as: ‘irrecoverable instants’. In its singular printing, made from the burnt text of just one book, Chloe True’s work is particular, not universal. For Alexander Duttman, there’s a difference in what you can see ‘in’ the image (as in: there is a picture of petals on fire), and what you can see ‘to’ the image (as in: ‘There’s something ‘to’ it) (*citation to be provided*). The first is produced by representation, the second by ‘halting’ the process of knowing, in favour of something else, and that something else, is the fact of its making, out of the raw materials of the original text. In Burrill’s work, this halting is seen in the final object, where the viewer is asked to step back from language as denoting something outside itself, and return to the ‘noisy’ materiality of the text.
In this kind of work, there is an indiscernibility between the ‘what should it be’, and everything ‘should be as it is’. All is as it should be, but not in the sense of a stable, fixed, form of representation.
Work such as this offers the difference between language as representation (concept/object correspondence), and language as constellation/event. I would like to close by suggesting that, not only does the work shown in these examples, inhabit a different linguistic space, where the embodiment of ideas is fully bound to the materiality of writing/text/language, but that these works propose a new kind of material enactment of philosophical ideas such as Constellation and Event, which are all but impossible to invoke at the level of Warde’s ‘invisible’ typeset word. In such work, the stage of *Materia Secunda*, is enacted through the mobilization of the primary material of language, into new configurations, which realize the full potential of *Materia Prima*.
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⁸ Benjamin offers fragmentary forms of representation: heterogeneous forms of ‘presentation’.
Example 2 (as a caption). Anthony Burrill’s limited-edition posters, printed in BP oil from the ecological disaster in the Gulf of Mexico. The oil was collected direct from the polluted beaches of Grand Isle, Louisiana. Here, text and image are literally ‘one’.
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Role of Platform Economy in Agricultural Sector in India
Javad Ghalambor (email@example.com)
Assistant Professor, Acharya Institute of Management & Sciences, Bangalore, India
Copyright: © 2022 by the authors. Licensee The RCSAS (ISSN: 2583-1380). This article is an open access article distributed under the terms and conditions of the Creative Commons Attribution Non-Commercial 4.0 International License. (https://creativecommons.org/licenses/by-nc/4.0/). Crossref/DOI: https://doi.org/10.55454/rcsas.2.8.2022.005
Abstract: India is a land of variety of geographical diversity due to which agriculture has gained prominence since the existence of civilization. This is the reason why agriculture is the backbone of India. Since ages, traditional practices have been followed in cultivation and marketing of agricultural products. But the drastic transformation in technology has created opportunities for farmers to explore, expand and increase the productivity. The following study provides detailed information regarding digital platforms in agricultural sector, their role in agriculture infrastructure transformation and connection of farmers with traders and consumers along with technology-driven innovations.
Keywords: Agriculture Infrastructure, Agricultural Sector in India, Platform Economy
Introduction
Platform economy in general, refers to online market places. But vastly it also includes social and marketplace interaction and a set of digital framework work for the same. “Platforms are to the network age what the factory was to the industrial revolution” (Policy framework for digital platforms-moving from openness to inclusion). There is a rise in B2C and B2B marketplace platforms for the procurement of input cultivation practices, harvesting practices and marketing the produces. Fintech companies are also tied up with these platforms for ease of payment through simple online payment schemes.
The agricultural sector is facing severe technological drawbacks especially in the area of agro products marketing platform technology helps to overcome this situation and make the agricultural market wide and efficient. The goal of this paper is to examine how the digital economy connects farmers, traders, and consumers.
Review of Literature
Regina et al (2011) has analyzed that the agricultural has suffered adversity during the past decade despite high overall growth rates experienced by other sectors in the Indian economy. Increasing growth rates in the farm sector would require, among other things, a more equitable use of fertilizers. Thus far, the trends in fertilizer use have been uneven across states and across farms of different sizes. Reform options for fertilizer policy should take into account these realities as well as India’s continued need for food security. The reform process itself has made very modest progress.
Deshmukh et al (2014) concluded that subsidies make some positive & negative impact on agricultural sector of India. In the last few years, the percentage of the agricultural sector in GDP is decreasing, but at the same time, production of the agricultural sector is also increasing with investment. The increase in population & inflation is a measure factor for low contribution of the agricultural sector in India's GDP. But agricultural subsidies play a vital role in the growth of the agricultural sector in India. Without help from subsidies, the development of the agricultural sector is very difficult. Due to corruption & ineffective management of subsidies in India, it has not reached its end users i.e. farmers & another side due to illiteracy of farmers regarding agricultural subsidies, he can’t take benefit in farming & faced financial crisis.
Panagriya (2001) notes that with the re-introduction of Open General Licensing in 1976, tariff rates for imports in the 1980s were raised abysmally high to avail tariff revenue from quota rents although large exemptions were given on these goods. With the reforms measures, removal of import licensing and curtailing tariff rates, there was considerable buoyancy in exports in the first half of the 1990s which although further slowed down due to decline in world trade. This robust performance of exports helped to abate trade deficit from an average 2.7 per cent of GDP during the 1980s to just 0.9 per cent from 1992-93 to 1995-96. But, with East
Asian crisis, came the meltdown of exports thereby again widening the gap to 1.6 per cent during 1996-97 to 1998-99.
Kumar, N. (2001) & Panagriya, A. (2004) divides the policy changes in the external sector into three phases viz. 1950-75 with tighter control that represented a closed economy; 1976-91 was the period when liberalization in this rigid structure took place especially in the second half of 1980s and then the third phase commencing from 1992 which entailed a series of systematic reforms.
Fourier Analysis of Historical NOAA Time Series Data To Estimate Bimodal Agriculture, (21 DEC 2007): In the present study, NDVI time-series 10-day composites derived from NOAA AVHRR data were used to estimate bimodal agriculture areas (where there are two seasons of cultivation per annum) using Fourier approach. The NDVI sequence was transformed into harmonic signals and the amplitude and phase of first and second harmonics were used for the analysis. A classification was applied, using a decision tree, to discriminate bimodal agriculture area from other land cover types, principally over the Asian sub-region. When the amplitude of second harmonics in a sample region, where bimodal agriculture is predominant, was compared with the irrigated area statistics developed by FAO-UF, a linear relationship was determined. The derived function was applied to transform the amplitude of second harmonics to bimodal agriculture area estimates. 2007
Thus large-scale irrigation projects appear on the map and provide an encouraging initial result. This result indicates that estimating bimodal agriculture area that is one of the main sources of information for irrigated area mapping at regional or global scale, with improved accuracy possible if greater spatial, temporal resolution is achieved, for instance from MODIS or SPOT vegetation time series NDVI data, combined with an improved decision tree classification algorithm and a greater precision and geographical distribution of ground-truth data. The principle merits of this approach are automation and repeatability.
Mountain Agriculture Extraction from Time-Series MODIS NDVI Using Dynamic Time Warping Technique,(15 Feb 2017): The study attempts to extract Mountain Agriculture using an optimized Dynamic Time Warping (DTW) algorithm having endpoint constraints. The DTW was applied over a time-series annual stack of Normalized Differential Vegetation Index (NDVI) using a set of reference time series profiles for three agriculture classes (i.e. double cropping, single cropping, and horticulture) and the pixel-wise similarity is examined to identify the agriculture classes. In addition, Euclidean Distance (ED) was used to compare DTW-based result. The detection accuracy of each class was assessed using Google Earth-based agriculture sample, and the spatial agreement of resultant map was assessed with high-resolution reference data using Pareto boundary technique. The sample based accuracy evaluation reveals that DTW algorithm performed better for double and single cropping agriculture detection in compared to the horticulture. Overall, DTW-based agriculture map \((0.81 \pm 0.01)\) yielded higher overall accuracy in comparison with ED-based agriculture map \((0.75 \pm 0.01)\). The Pareto boundary-based spatial agreement analysis using high-resolution reference data also shows the
Dominant performance of DTW based agriculture map than an ED-based map. DTW performed better than ED, in terms of optimal distance (OD), in ten out of eleven districts. However, reliable spatial matching (OD less than 0.23) between DTW-based map and reference agriculture map was observed in lower elevation region, especially in Hamirpur (OD = 0.06), Bilaspur (OD = 0.09), Shimla (OD = 0.19) and Una (OD = 0.20) district.
Spectral Indices for Precise Agriculture Monitoring (03 Jan 2002): This paper presents two main objectives of a multi-year study applying remote sensing to precision agriculture: (1) developing new spectral indices for wheat monitoring, and (2) producing an interpretation key for mapping vegetation features with spectral indices. Agricultural monitoring with remote sensing utilizes and maps the spectral reflection of specific vegetation features. These are the indicators of plant development and crop condition. Over the years, a number of spectral indices have been developed, but the ultimate combination of information required by the farmer, and the capability of remote sensing to map this information, has not yet been achieved. The study, which lasted three years was performed simultaneously, collected vegetation and remote-sensing data. The study aimed to improve the current abilities of remotely sensed agriculture monitoring. Indices were developed relating to various features of wheat. These indices
map the current conditions of the crop, such as nitrogen in the leaves, and predict the yield. Evaluation of these indices, and already known indices, shows that each can be used to map different crop variables.
**Ground Based Digital Imagery for Grassland Biomass Estimation (04 Nov 2003):** Above ground biomass was estimated on the short grass prairie of eastern Colorado using ground based conventional (RGB) digital camera imagery. The accuracy and efficiency of image-based estimates were compared with clipped biomass measurements. Field measurements of aboveground biomass were obtained on three grazing treatments and three sample dates (phenological status). Grazing treatments did not significantly affect ($p>0.10$) estimates of clipped green biomass taken from digital images. However, plant phenology, green biomass estimates from images, and the interaction of plant penology and green biomass estimates from images significantly affected clipped green biomass measurements ($p\leq0.04$). Analyzed images provided fair estimates of total clipped green biomass ($R^2 = 0.55$) and clipped green biomass without cactus ($R^2 = 0.73$) when plant phenological status was included in the models. When plant phenology was removed from the models, the variability explained by green biomass estimates from images declined to 25% for clipped green biomass, and 32% for clipped green biomass without cactus. Thus, results showed that plant phenological status was the most important variable in the prediction of green vegetation biomass. Results indicated that the usefulness of RGB digital camera imagery for green biomass estimation is limited for the short grass prairie.
**A Handy Imaging System for Precision Agriculture Studies:** An inexpensive imaging system able to take various narrow-band images and placed on platforms of various heights can be very useful to many remote-sensing studies, particularly for researchers in precision agriculture areas. A handy imaging system, composed of an Electric EDC-1000L monochrome camera, a Canon PHF6 1.4 lens, a set of Andover band pass filters, and an Advantech PCA6751 single board computer, was built up and installed with corresponding self-developed application software. The system had been deployed on platforms such as a mobile high-lift crane and helicopter to acquire various narrow-band images. This simplified imaging system may help greatly in performing validation tests on many stress-identification indices and related algorithms derived from ground spectrora diameter measurements.
**Data**
This data is collected from various websites and journals which are secondary in nature.
**A. The various digital platforms by the Government of India are:**
- **NITI Aayog:** NITI Aayog has started a scheme called Startup AgriIndia Schemeto subsidize digital startup in agriculture. It is a National Digital Market place for trading agricultural commodities through Digital Platform.
- **mKRISHI Platform:** It is an agrotech startup which is used for identifying best cultivating practices, for protection against various damages due to weather conditions, for selecting appropriate seeds of a particular form from a variety of seeds. It also provides information regarding market prices of different farm produces and input availability. It also provides information on various plant diseases and curation for the same.
- **e-NAM:** The electronic national agricultural market was launched in April 2016 to create a unified national market for agricultural commodity by way of connecting existing APMCs through online networking.
- **Agmarket:** It is the first e-governance project which was set up in the year 2000 in view of strengthening agricultural marketing system in India.
- **Agricultural Commodities Exchanges:** It is a future trading platform for agricultural commodities in India. It consists of
a. National commodity and derivatives exchange ltd (NCDEX)
b. Multi commodity exchange of India ltd(MCX)
They were introduced in the year 2003 mainly to mitigate the price risk of farmers.
Indian Farmer’s Fertilizers Co-Operative Ltd (IFFCO): It is the world’s largest fertilizers cooperative federation established in India. It has 40,000 member cooperatives with a massive cooperative market with the help of creation of e-platform.
B. The various Digital Platforms by private sector in agricultural are:
- **Reuters Market Light Free Mobile Application (RML Agtech):** It is an application which connects farmers to various information services through SMS and toll free number. It is highly engaged in content formats such as; Advisory videos, podcasts, imagery, and also contains many innovative features consisting of chats with agriexperts and lead farmers so as to create a network of social community on the application. It also engages agri communities and agri stakeholders through its Digital Platform.
The various features of this application are:
- 6 day taluk level weather forecast
- Historical updates on 6 crop market combination
- Unpredictable weather protection by warning or alert
- Direct connection with various traders at district level to understand the current and future supply trend
- Inputs from sowing to harvesting on a timely basis
- Suggestions for increase in productivity
- Communication of policies, government schemes, subsidies, health of the crops and other finance related information
- Latest updates regarding key agricultural practices using technology
- **Stellaps Technologies:** This startup is mainly for dairy farmers; it aims at optimization and monitoring of services. Its main focus is on small and medium scale farmers. It operates using cloud mobility and data analytics as tools to improve production of milk, procurement as well as cold chain. It also boosts animal insurance and farmer payments.
- **eKutir Global:** It is a digital platform connecting marginal farmers with stakeholders through online and mobile-based applications across the value chain. It connects the farmers with soil testing labs, banks, food processing units, suppliers of fertilizers, suppliers of high yield variety seeds, and branded retailers. A part of its service is Agri Suite, which is a one-stop solution for all the requirements of farmers such as training to use the applications and information about the field pattern.
It also helps the farmers maintain and repair the products used for agricultural production along with advisory on supplementary components and other marketing services.
- **Ekgoan Technologies:** It is IT-based network integration.
Ekgoan One Village One World network is a mobile communication technology which offers a range of services to farmers.
Statistical data on platform economy in agricultural sector:
As per the government estimates, India is one of the top 6 active geography for investments in agricultural technology after US, Canada, UK, Israel, and France. The investment in this field is over USD 313 million into Indian startups and SMEs. India is the second-largest fruits and vegetable producer in the world as per the 2015-16 report. It is also the second-largest producer of sugar and it is the leading country in coconut production. The global market for precision agriculture is expected to reach a market size of over USD 6.34 billion by 2022 with an expected growth rate of 13.09% annually. India and China are expected to grow annually at the rate of 18.29% until 2022, the fastest growth projection. The mKRISHI Platform has 414 million subscribers of mobile services in rural India alone as per statistics of 2014-2015. The e-NAM
Platform has reached from 250 to 585 markets. At current scenario 9.87 million farmers, 109725 traders are registered on the eNAM Platform. There is around 100 million soil health cards distributed in the country as per data of 2015-17 and a mobile app for soil health has been launched to help Indian farmers.
**Transformation of Agricultural Sector due to Platform Economy**
In India, Agricultural Sector contributes 16% to GDP. It is a source of employment for 49% of the population. The fastest growth is projected by India and China with an annual growth rate of 18.29% by 2022. India’s expected agricultural income would be doubling by 2022. The Target of Govt. is to increase the avg. Income of farmer household is at current price USD 3420.21 by 2022-23 from USD 1505.27 in 2015-16. India is transforming itself through Digital India by way of direct application of digital technology in Agricultural Sector; technology such as remote sensing (via Satellites), Geographic Information System, crop and soil health monitoring, live stock and farm management. Government of India will provide USD 306.29M for computerization of primary Agricultural Credit Society (PACS). Agri-Udaan Program-It is a program to monitor and mentor startup so as to enable them to connect potential investors. Pradhan Mantri Annadata Aay Sanrakshan Abhiyan (PM-AASHA) is a compensation scheme by the Government of India along with private agencies which ensures that farmers get fair prices for their produce in the country.
**Platform economy in connecting farmers, traders and consumers:** As per the statistics Indian online grocery market is expected to reach USD 40 million by the end of 2019 and is expected to increase to 141% by the end of 2020 as it is growing at a compound annual rate of 62%. Due to growing concern for food safety, there is an adoption of food safety and quality mechanism such as Total Quality Management which includes ISO 9000, ISO 22000, Hazard Analysis and Critical Control Points (HACCP), Goods Manufacturing Practices (GMP), Good Hygienic Practices (GHP) by food processing industries.
The various platforms which offer marketing of agricultural produces, connecting farmers and traders for mutual benefit and also with the customers are:
- **Ninja Cart**: Ninja cart is one of the popular online platforms for B2B and B2C businesses. It tackles the toughest supply chain problem in India. Since India is the second largest fruits and vegetable producer in the world, this platform connects these farmers directly with retailers or business for the benefit of both farmers and consumers. Famers get better prices along with consistent demand for agro products as well as retailers can procure fresh fruits and vegetables at competitive prices directly from farmers. It is launched in 7 cities connecting 12000 farmers with traders and retailers by employing 1200 people. The delivery is within 12 hours from farm to store. Ninja cart is among the 42 most innovative startups in India as per INC42 media. It has an opportunity of USD 50 billion (BAIN, Google and OMIDYAR Report, 2018).
- **Custom Hiring Centers**: It is the model for rental of tractors and other farm equipments with the objective of encouraging rural entrepreneurship as well as fast tracking mechanism of Indian agriculture.
- **DestaMart and DestaTalk**: DestaMart is an E-Commerce platform for agri input supplies, fertilizers, pesticides and seeds to the rural market. DestaTalk is a platform which provides agri inputs to agri store owners and also provides information related to agricultural sector.
- **Big-Haat**: It is also one of the agri commerce startup in E-Commerce with the objective of saving money of farmers. It was started in January 2015 for providing quality agro inputs and accessories through online platform.
- **E-Chaupal**: This business platform consists of a set of various organizational subsistence and interfaces connecting Indian farmers to International market. It is initiated by ITC. It has 3 different layers with different level of geographical aggregation which are characterized by 3 key elements;
- Infrastructure—is a place where transaction takes place (physical/organization)
- Entity (person or organization)—this is where mounting of the transaction takes place.
- Geographical coverage
Village level Kiosks with e-chaupals: Here, the local farmers who are trained by ITC manage each target farmer within the reach of 15 km.
There are Brick and Mortar infrastructure called hubs which reach targeted farmers within the reach of 25 to 30 km. they are managed by traditional intermediary who have local skills and knowledge.
I Say Organic (ISO): It is a Delhi based online portal setup in 2012 for food retailing. Organic products are marketed through ISO website on a daily bases where orders are taken over by mobile or through online and the deliveries are within few hours. The website accepts cash on delivery, card or online banking.
Amazon has entered into food retail sector due to the liberalization of FDI policy in 2016 which allows for 100% FDI as long as local sourcing requirements have been met. Similarly, Ask-Me-Grocery.com, Snap deal, Freshfalsabzi, Peppertap, Local Banya and Bigbasket have also started grocery. Orders on Freshfalsabzi websites can be through online or by calling any time of the day for delivery of products on the following day in 3 time slots.
Discussion
The statistics have been proved that a large number of farmers have been included with the digital platform due to various initiatives taken by government and private sector. Although many farmers are still reluctant to use digital platform due to traditional agricultural practices, lack of knowledge and lack of awareness, India is evolving itself for the big change in agricultural infrastructure. Indian farmers still depend on physical APMCs and middlemen due to warehousing facilities, credit facilities and other services provided by them. India will witness a huge growth in this field in the coming years. Farmers are gradually turning towards digital economy for information regarding agriculture, supply chain, market availability and technological advancements in this sector. The estimates have shown substantial increase in investments into technology-driven innovations for increasing the productivity of agricultural yield, providing fair prices to the farm produces, availability of global market by way of exporting the products, recognition of farmers and traders through online registration, and providing solutions for problems faced by small and medium farmers.
Conclusion
The study has thus informed about the innumerable technology driven agricultural digital platforms and opportunities available in this field. Therefore, more steps taken can unburden the farmers of their day-to-day problems. This can bring about a huge transformation in Indian society and economy.
References
Birner, R., Gupta, S., & Sharma, N. (2011). *The political economy of agricultural policy reform in India: Fertilizers and electricity for irrigation* (Vol. 174). Intl Food Policy Res Inst.
http://www.mospi.gov.in/statistical-year-book-india/2018/177
https://www.ibef.org/industry/agriculture-india.aspx
https://www.agritechindia.com
http://ninjacart.in
https://enam.gov.in/NAM/home/about_nam.html
http://www.jocpr.com/articles/development-model-of-agricultural-ecommerce-in-the-context-of-social-commerce.pdf
https://yourstory.com/2018/04/startup-market-agriculture-profit-business-farmers
Mid_Project_Reflections_2018: Anita Gurumurthy, deeptibharthur, nandinichami
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In the midst of crisis – God is faithful!
AMBER DOWD
FOLSOM, CALIFORNIA
WOMEN’S CONNECTION
LEADERSHIP TEAM
Churches often endeavor to emulate the early church in their worship and community practices. Sharing belongings, breaking bread together, corporate worship and serving the poor all hearken back to the values laid forth since the start of the church. But another “early church” element has been introduced to many of us as a result of the Covid-19 pandemic. This is the experience of physical separation. (Although many worldwide churches have dealt with separation for years.)
Throughout the book of Acts, we regularly read about Paul and his companions saying farewell to dear friends in Christ, not knowing whether or not they will meet again. We read stories of persecution, forcing the church to scatter far from one another. I wonder if their hearts battled feelings of fear and anxiety as they faced unknowns regarding their future. Paul regularly expresses effusive words of love and encouragement sent from afar to the various churches he influenced. This leads me to wonder, as we face this time full of fears and physical separations, how can we emulate Paul and the early church in this regard? How can the experience of distance and separation teach us new ways of “being the church” to one another?
We are hoping that this issue of TouchPoint may provide a moment of love and encouragement to you. There’s no disputing that this has been a challenging time, and fulfilling a calling in pastoral ministry has become intensely challenging. The pandemic has impacted our NAB family around the world, keeping us out of physical reach from one another. In light of this, we have reached out to several of our NAB missionaries to share with us how this time has been for them.
Living overseas, of course, involves being distant from friends and family, but the pandemic created an element of being cut off. The onset of the pandemic induced much fear, isolation, and even a season of loss and suffering for many of our missionary families. For some, it was at times a daily struggle to recognize God’s goodness in a sea of uncertainty. However, as you’ll read, God has faithfully redirected many of their hearts to Him and blessed them with important insight through this time. In the midst of intense difficulty there is always to be found evidence of God’s faithfulness and provision. They have discovered sacred spaces to allow for meaningful reflection and creative spiritual connection. They have leaned in to perseverance and are clinging to God as their anchor. In the articles below you will find a special collection of testimonies that share what God is doing in our Church.
Take a moment to read how your sisters around the world have been doing. Then maybe take a moment to ask yourself how you have been doing. Finally, consider taking a moment to connect with someone you’ve been separated from and share your story of God at work. Our hope is that, in the midst of fear and separation, you will be encouraged and even spiritually sparked as you discover ways to creatively connect with, encourage and love one another.
IN THIS ISSUE
Voices From the Field pg 2-6
Triennial 2021 pg 6
Book Links pg 7
Baptist Women’s Day of Prayer pg 8
I think 2020 will go down as one of the most difficult years for many of us. However, I think it may also be a year that brings us closer to God, closer to our brothers and sisters in Christ, and brings a creativity we have not seen in the church for a long time. Like most of the world, our ministry and lives in Japan changed drastically this year.
In my twenty plus years of ministry in Japan I have rarely been homesick or worried about my family on the other side of the world. When life started changing in March, I started talking to my sister and my mom more often as well as other friends and family. I was not worried about life here in Japan or about my family. We all seemed to be handling the changes and new structures well.
Then I saw a news segment on what was happening in Italy. One of the images in the segment was rows of caskets lined up in a church. I suddenly realized my mother living in an assisted living facility was one of those most vulnerable being talked about. I also realized that if something happened to her or my sister or brother in law, I would not be able to get back to help because the airports were closed. Also, even if I could get back, I would have to quarantine for 14 days and then would likely not be able to get back to Japan.
I panicked. I forgot to run to God. I let my fears overtake my thinking.
God, in his gracious timing, lead me to an app for my phone, of all things. It is an app that reminds you to pause and refocus on God and his goodness. Two times a day for 76 days I paused for 3-10 minutes and pulled my mind from the downward spirals of thought and turned them back to Jesus, the lover of my soul. I continue to use it, just not as faithfully as I did the first 76 days! (The app, “One Minute Pause”, includes a counter so that you know how many days and how many pauses you have taken.)
I am grateful for the way God reminds us of his love for us. As a person who does not use many apps on her phone, an app is the last thing I expected to bring me those reminders during this challenging time. Creatively staying in touch with loved ones has been a theme of this pandemic. I did not expect God to teach me creative ways to stay in touch with him!
Sometimes being between two worlds is strange. As we navigate Japanese information on the pandemic and stay up to date as to what is happening in the States, I find myself worrying and fighting fear on two fronts. We get an eye witness account of how two countries, their perspectives, and attitudes can be completely different and the same. The Japanese government is not helpful and we rely mostly on the information from the States and Paul’s science expertise to navigate through this time of the pandemic. We did close the church’s door to formal meetings for three months, but someone was still there during office hours to be available for anyone who would drop in. When the formal meetings stopped we looked at different ways to conduct service. With most of our attenders
being older or not having the ability to stream a worship service, sermons were typed up and hand delivered to each attender until there was a stay at home order during the month of May. Then the sermons were mailed. We were encouraged that many shared the sermons with family members and neighbors. Now, that we are meeting in person, we continue to be cautious, especially since many of our attenders are older and have ailments. We have shortened our service times and created three service gatherings to accommodate having fewer people meet in our small sanctuary. We do not sing, but hum along as Paul leads. Temperatures are checked and everyone wears a mask. Attenders comply without complaint, with understanding and appreciation for the cautious procedures. They are thankful to have the opportunity to meet. We miss the fellowship times but hold onto hope that soon, it will be ok again. We have even started communion, everyone brings their own grape juice and bread so as not to share elements but have a shared fellowship of communion.
We have resumed English classes and our students’ temperatures are checked and all wear masks. Seating is separated and students have complied and expressed thanks for the added precaution. There is an understanding and they appreciate the leadership’s steadfastness.
Though, we have had to creatively problem solve and rely on members being cooperative, the most emotionally and difficult part was making the decision to keep Elijah home and not have him travel the 3 hours commute, on public transit, back and forth to his school. We are hoping and praying that this situation would only be for the fall semester. Elijah’s world has become quite small and we are hoping we are making the right decision for this situation. We are praying for opportunities in our local area where we should put our focus. Instead of being stretched across a large geographical area, how should we focus our time within the smaller area.
God continues to remind us that we are not alone. That He is still working and blessing. We are thankful for the church members’ and English students’ cooperation and understanding as we have changed routine, times, and incorporated temperature checks and mask wearing. God continues to remind us that He loves us and He is with us.
God continues to encourage me to trust Him and give my fears to Him. Some days it’s a give and take but I know that He doesn’t change. He is the same, waiting patiently for me as I once again, set aside my fears, choose to be in His presence and trust that He is God.
Elsie Lewandowski
Cameroon, West Africa
Praise God I feel very blessed. I am living in a large house with a family of seven next door and a friend upstairs. I always have a welcome in their homes and they help me in so many ways — shopping, repairing, opening the gate for my car, moving things, playing table games, joining meals. Our little community has really been a blessing. The biggest challenge is social distancing. For a culture that is usually squashed and sees any space as an invitation to fill it, this has been difficult. One foot is definitely a social distance - in conversations, line ups, walking on a road, in a store.
Technology has been incredible in my life. Having facebook, What’s app, zoom meetings, DVDs and the internet has changed my life. I never really felt lonely or lost or out-of-touch. I was able to get spiritual encouragement and worship services and information and long conversations with long time friends including Cameroonian friends. I have enjoyed our COVID isolation but am glad that we get to do more interaction now. I have never felt afraid or angry or frustrated at the situation. I have been grateful for all the technology that has helped me keep in touch. HOWEVER, I have felt overwhelmed and frustrated with teaching online and learning the system (For all of the challenges Elsie is facing click the link for her entire response to how Covid has/is changing her life).
WHAT HAS THE LORD TAUGHT ME?
1. He is a ROCK. Everything around me is changing but He is a rock!
2. He is faithful. Even when I blow it and feel helpless when trying to help others, God is there providing in amazing ways. He never stops loving or caring or being patient or forgiving. My friends in the Northwest Region who are still experiencing difficult times, are telling me how God is providing and protecting. They are getting taken to the police station to pay ‘a fine’ because they’re not wearing their COVID mask and God provides. I shake my head in wonder and amazement.
3. God hears and answers prayer — over and over and over again! He provides plane tickets and COVID tests on time. He provides work and transportation. He heals from COVID and malaria. He protects
COVID-19 hit Brazil in mid-March and the governor of our state acted very quickly. Schools had barely begun their new year when they were shut down and switched to online. Non-essential businesses were closed. Churches switched to online services. Brazil closed its international boarders, and our bustling city seemed to come to a halt. Shortly after this, my mom called to let me know that my dad who had been fighting cancer was being put on hospice.
By this time global travel was difficult, and as much as I prayed for peace to run to my dying father, I knew in my heart I had to stay here. My dad died, and I watched his funeral online. This year has been painful. We have suffered a lot of loses. Not just the loss of my father and my kid’s only living grandfather, but the loss of opportunities to make friends and build relationships, loss of time in language and acculturation, and loss of face-to-face worship and interactions. Even in the loss, God is at work here. Now that we are home and our schedules look so different, we shifted toward a project our field has long desired, bringing Masters and Doctoral programs to our seminary here in Porto Alegre. We are doing this through partnering with Sioux Falls Seminary and their Kairos Project. This has been months of prep work, as each aspect of Kairos needs to be translated and adapted to our context. We are excited that we have a pre-enrollment of over 30 students, and we hope to have the program ready for open enrollment by mid-September.
Christians have long referred to God as an anchor, a solid rock, and a mighty fortress. This is because pain and loss are no strangers to a Christian. As a matter of fact, such things are promised to us. Our trials and troubles can often be perceived as if God has somehow abandoned us or that He is letting us down. We ask why bad things happen. We wonder how come we are given these trials even though we have been trying to be faithful followers. But James tells us to “consider it pure joy, whenever we face trials of many kinds, because you know that the testing of your faith produces perseverance. Let perseverance finish its work so that you may be mature and complete, not lacking anything.” This is where the daily pain is felt; the deep painful feelings of loss, anger, and sorrow - the crying out; the hard feelings; the painful praying. It is in perseverance that we cling ever so tightly to our Heavenly Father, our anchor and the solid rock.
Lyndell Campbell-Requia
Porto Alegre, Brazil
My husband, Paulo and I are doing well. We have been in isolation for 5 months now. We leave the apartment for necessities, to walk (usually with our dog) and to attend to our church people. Because I am involved in education, if anything, COVID has increased my workload. Fortunately, we were already using Zoom for our classes so it was just a matter of getting the students physically attending classes to go online. July was winter break so we have just started our second semester of the school year and have 7 new students in our Pastoral Formation program, praise the Lord! Also, for the last year or more we have been in the process of partnering with Sioux Falls Seminary to bring the Kairos Project to our Seminary here in Brazil and we have just launched our promotional phase this month!
We have almost 30 people who have demonstrated real interest by filling out our on-line pre-application form, so in the midst of challenges, it is an exciting time for the Seminary. Paulo serves as both a pastor and a missionary. All of the classes he was teaching have been put on hold for now, but he continues to serve the church people by social distance visiting as well as the poor community by putting together food baskets. One day he ran into a woman and her son who were selling sweets on the street to survive. The church was able to provide her with a food basket. Just last week we ran into this woman working at a bakery. She was so excited! For now, she is on probation but is very hopeful it will turn into a full-time job to support her family. Also, in the midst of COVID-19, two couples have come to Christ and are attending our church via Zoom. Paulo has also been meeting with one of the couples for weekly discipleship.
-A passage that has really struck me during this time is Jeremiah 29:1-14. Many people are familiar with verses 11 and 13 but the context is in some ways comparable to what we are going through. While we are not in exile like the people of Judah were, we are isolated from our brothers and sister in Christ and the building where we meet to worship and share in communion. We also have no real expectation of what tomorrow holds. It is a time of separation, uncertainty and transition. Interestingly, the verb “to wait” in Portuguese is the same verb for “to hope.” As I have studied this passage it is truly a message of waiting and hoping in the Lord. Jeremiah’s letter, his message from the Lord, to these exiled people instructed them to build houses, plant crops, get married and to pray for the welfare (the Shalom) of the city where they were living and by doing they would also receive Shalom from the Lord. And a time would come in which they would be freed from their exile. God’s purpose is sending them into exile was not to harm them, but to prosper them and give them hope for the future. If anything, this time has strengthened my capacity to wait and hope in the Lord. It is a time to be content and find the Shalom in where I am and be thankful that I can trust in our Sovereign God. And He has also shown me over and over again that it is a time of hope as I have seen so many prayers answered, I have witnessed people come to Christ and I have had the joy of preparing people for Kingdom work.
I was sitting with eight youth from our village around a campfire at Lake Capra up in the Fagaras Mountains in Romania, when I was thinking about all the things they had missed out on as a result of the pandemic: formational time with friends, education opportunities (though some were excited about that), graduation celebrations, and of course summer camps. Days before we left, supplies that had been ordered were MIA, my husband Paul was dealing with a painful back issue, and the weather forecast called for rain for the entirety of our trip. We were feeling discouraged. Yet as we sought prayer, we saw God faithfully provide for all of our needs. This final campfire scene was a testimony of God’s provision as he held off a storm, so that we could have one more campfire experience before we headed home. A sacred space had been created. This was a space for God to come meet with us, to speak to us through his Spirit. We were in the midst of our summer series with the teens called “Ask Anything”. I was tasked with speaking to a deep question asked by one of our teens. ‘How can I understand what God is calling me to do in my life and how do I obey in following him?’ Wow--what a question to come from a 16 year old boy who just a couple years prior proclaimed he didn’t want to be a disciple of Jesus, for very real and painful reasons that he had experienced in his life. This question he asked extended far past a desire to know what profession he should step into after high school. It was a question that wondered what it meant to live life with God in submission to his mission and calling even in the midst of struggles and difficulties. I’m sure it’s a question we all are processing as we face a world-wide pandemic and even more political and cultural upheaval, as well as incredible disunity in the church. During this time, I have been struck by the space that has been forced upon us due to social distancing measures. Many of us have been restricted from our normal rhythms and schedules. This has been true for us here in Romania too, as there was a couple of months where we were not allowed to leave our house without a permit--not even for a walk! Yet in all of this, we can see that a space has been created. I believe God wants to use this as a sacred space in our individual lives and within the church body as a whole to speak to this big question posed earnestly by this teen.
As I prepared to answer this question, I was led to the story of Jonah. This is a story I’m sure we are all familiar with. A story I can clearly remember learning about growing up—that big whale is hard to forget!
Jonah receives a call from God, he flees from this mission and tries to hide at sea. In his disobedience it is determined he must be thrown off the boat, and subsequently he’s swallowed up by a whale where his heart is then transformed and he is led to complete the mission God had originally called him to. Seems like a simple story with a simple message. And yet as I read deeper into this story and I sat with Jonah in his wrestling, I saw this deeper journey he was on… one where God was pursuing Jonah and creating a space for his questions and confusion. In chapter 1 verse 17 I was struck in a new way by the purpose of the whale that came and swallowed up Jonah. It is written that the Lord provided the whale. As I studied the meaning of this wording I was convicted that the Lord’s provision of the whale was two fold. One, he was protecting Jonah from the storm that he was thrown into. And two, God created a sacred space for Jonah to process with Him -- the belly of the whale nonetheless! What seems to us as a terrible and even stinky place for Jonah to be, was actually a place that God used to transform and soften Jonah’s heart toward the things he was calling him to.
This season that we find ourselves in is not a desirable one. It’s challenging, painful, and full of loss… and it too is even stinky as we’ve been revealed to some of the rotten fruit we’ve allowed to reside in our hearts. Many of the issues being revealed in the church, in politics, and in our cultures, have been proven as not producing a pleasing aroma. What I have come to see in the midst of this season is that God is carving out a sacred space to meet with us individually and collectively, to transform and soften our hearts to the calling he has on us to participate in his kingdom mission that is breaking through the turmoil of this broken world. The question is in what posture will we enter into this sacred space? Unfortunately, the story of Jonah ends rather disappointingly for him. We see how Jonah’s posture leads him to a place of anger and bitterness as he wrestles with God’s mercy and compassion for the Ninevites.
In this season would we not flee from this sacred space God has carved out for us. Would our posture be like this 16 year old boy from our youth group who is humbly and submissively inquiring of the Lord for direction and clarity. Would we be vulnerable with God and with others as we process this difficult reality and the way ahead. When we create space with this kind of intent and posture, we too, like the disciples who made space to process the passion as they walked the road to Emmaus, will find Jesus walking along with us, offering his peace and his Spirit to bring about his revelation.
Psalm 42:1-2 “As the deer pants for streams of water, so my soul pants for you, my God. My soul thirsts for God, for the living God. When can I go and meet with God?”
Moving from Fear to Freedom
Grace Fox
FEAR! In these days of coronavirus pandemic, the newspaper headlines scream it out – Fear is contagious and can spread quickly! Uncertainty in the face of the pandemic can easily breed fear! Pandemic fuelling fear and mistrust! What are we going to do?
ABOUT THE BOOK
Fears like this can plague women like you every day. Left unchecked, they can paralyze you and keep you from enjoying life. In this book, Grace Fox gives a practical guide on how to face your fears and let them be catalysts for change. When you bring your fears to God and cry out for help, He answers and you experience a wonderful new relationship with Him.
With profound insight, humour, sound advice, amazing stories and strong spiritual principles, Grace inspires you to face your fears, learn, grow and come out stronger on the other end.
The last page of the book says it all with verses from Isaiah:
“Do not fear anything except the Lord Almighty. He alone is the Holy One. If you fear Him, you need fear nothing else.”
– Isaiah 8:13
“See God has come to save me. I will trust in Him and not be afraid.”
– Isaiah 12:2
In these days of fear, anxiety and uncertainty, this book will give you good help and hope, and move you into the freedom God so desires for all of us. The book comes with a companion study guide, and can be ordered from amazon or through www.gracefox.com.
HABAKKUK
Remembering God’s Faithfulness When He Seems Silent
Dannah Gresh
ABOUT THE BOOK
Learn how to live by faith and not fear. Why does God seem silent when I need Him most?
The prophet Habakkuk faced great storms in life. His fears of the future crippled him with doubt and left him questioning God. How is it, then, that he is now a shining example of how the righteous live by faith?
Learn how the storms of life can become opportunities to activate your faith in Habakkuk: Remembering the Faithfulness of God When He Seems Silent. You’ll study the book of Habakkuk—which maybe you’ve never done before!—and discover how remembering is essential to understanding the faithfulness of God. Through daily Scripture, prayer, and meditation, you’ll enter the life of this prophet, and:
• Gain freedom to express your fear and frustration to God
• Remember that God is at work—even when He seems silent
• Increase your capacity to practice the art of waiting on God
• Learn how to navigate through the storms of life to live free from fear and full of joy
This six-week study provides daily interactive Bible study and an easy-to-use leader’s guide for group participation. Dannah Gresh also hosts a six-session podcast series to kick off each week of study. Find it at dannahgresh.com.
More Power to You
Margaret Feinberg
ABOUT THE BOOK
Each of the 52 devotions in More Power to You by Bible teacher Margaret Feinberg examines a popular lie in our culture, helps us understand how that lie shows itself in our lives, and invites us to replace that lie with a biblical affirmation of truth that will bring joy to your soul.
In a culture that constantly tells us we’re not good enough, not beautiful enough, and not doing enough, it’s easy to feel as if we have nothing to offer. Lies about who we are and how we are failing slip into our thinking until we believe they are reality. But that’s not what God intends for us.
In More Power to You, Margaret Feinberg exposes these false beliefs and shows you that the places of your deepest hurts can become wellsprings of your greatest healing. Here Margaret shares the daily practice that has been so life changing for her: the 90-Second Daily Declaration Challenge. You’ll launch into each day by reading the Daily Declaration aloud, paying attention to what the Holy Spirit may be highlighting for you. Then you’ll read through the weekly devotions that examine each line of the Daily Declaration, exploring the what and the why behind those biblical truths. These brief but powerful devotions are designed to unleash the true you—and remind you of who you really are.
Are we women who do the Day of Prayer? Or, are we women of prayer? Day of Prayer began as women in Europe emerged from World War II. Women, who had been on opposite sides of the battle, realized they had work to do in order to tear down walls the divisiveness of war had been erected. Pain and atrocities had led to feelings of anger and these women knew only God could dismantle these emotional barriers and bring reconciliation. These women were women of prayer. They came together, wrapped their arms around each other through prayer, and the walls came tumbling down.
Since that eventful period, the Day of Prayer movement among Baptist women has grown. Observances now reach women in nearly every country where there are Baptist groups, currently seven Continental Unions connecting women from 156 countries with translations of the program into over 80 languages.
Today we continue to see division in our world. Walls are built through war zones and polarization in theology, politics, cultures, ethnicities, and economic statuses. We, as Baptist Women, continue to call each other to break down walls in love, expressed through prayer. When we come together, we stand with each other at the foot of the cross, holding hands as we look up to our Saviour to bring healing and hope in a troubled and broken world. Day of Prayer is our biggest, most earth-shattering, groundbreaking opportunity to dispel the darkness and love the world and each other on a massive scale.
Prayer matters. Our voices are rising up to God with thousands upon thousands of our sisters’ God hears. God answers. Let’s continue to come together to shake the world and dispel forces of darkness.
Most of the women in our NAB churches no longer assemble to observe this special time of prayer. The Women’s Connection Leadership Team encourages you to gather with a woman or two and pray for women around the world using the program found at www.bwawd.org Day of Prayer.
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Effect of Cu and Mg on the wear properties of spray formed Al-22Si alloy
Dayanand M Goudar¹, K. Raju², V. C. Srivastava³, G. B. Rudrakshi⁴
¹Department of Mechanical Engg., Tontadarya College of Engineering, Gadag–582101, India
²Department of Mechanical Engg., St. Joseph Engineering College, Mangalore–575028, India
³Metal Extraction and Forming Division, National Met. Laboratory, Jamshedpur–831007, India
⁴Department of Mechanical Engg., Basaveshwar Engineering College, Bagalkot–587 101, India
Corresponding Author: Dayanand M Goudar, email@example.com
Abstract
In the present study, the effect of Cu and Mg on the wear behavior of spray formed Al-22Si alloy has been investigated and the same has been compared with that of its counterpart as-cast alloy. Al-22Si and Al-22Si-4Cu-1.7Mg alloys prepared by spray deposition process were hot pressed to reduce the porosity. The microstructures were examined by optical and scanning electron microscopes. The microstructure of spray formed Al-22Si alloy is fine and homogeneous and primary silicon phase distributed in the aluminum matrix evenly are fine and faceted having a mean size of 12 µm. The microstructure of spray formed Al-22Si-4Cu-1.7Mg alloy exhibited equiaxed grain morphology with fine and uniform distribution of both primary and eutectic Si with fine Q-Al-Si-Mg-Cu phase and θ-Al₂Cu precipitates dispersed evenly in α-Al matrix. In contrast the microstructure of as-cast Al-22Si alloy consisted of coarse plates of primary Si of size 350 µm and eutectic Si needles. The as-cast Al-22Si-4Cu-1.7Mg alloy consisted of coarse primary Si with Chinese script like θ-Al₂Cu precipitates and needles of Q-Al-Si-Mg-Cu phase in α-Al matrix. The wear study of both as-cast and spray formed and hot pressed alloys under an applied load of 10 to 50 N and sliding velocity of 0.4 to 1.5 ms⁻¹ indicated two distinct regimes of mild and severe wear. In both the regimes, the spray-formed and hot pressed alloys consistently indicated a low wear rate compared to that of as-cast alloys. The high wear resistance of spray formed and hot pressed Al-22Si and Al-22Si-4Cu-1.7Mg alloys were explained in the light of their microstructural modifications induced during spray forming and subsequent hot pressing.
Keywords: Spray forming, Al-Si alloy, Hot pressing, Hardness, Wear
1.0 Introduction
The increasing and extensive requirements of the automotive and aerospace industries have encouraged the design of advanced materials with high strength to weight ratio, low coefficient of thermal expansion and high wear resistance [Lai06]. The hypereutectic Al–Si alloy feature an excellent low coefficient of thermal expansion, low density and high wear resistance characteristic which have engendered considerable interest for these alloys for automobile and aerospace applications [Dhe06]. However, conventional casting methods lead to blocky coarse primary Si particles in combination with interdendritic eutectic Si phase which limits the wear
properties of hypereutectic Al-Si alloys [Dwi04]. In order to improve the wear properties of as-cast hypereutectic Al-Si alloys, a modification in composition is necessarily made by adding alloying elements such as Cu, Mg, Fe etc [Sri06]. Addition of Cu and Mg to hypereutectic as-cast Al–Si alloys enables the formation of coarse intermetallic Mg$_2$Si, Al$_2$Cu phases and other intermetallic compounds such as Al$_2$CuMg and Al-Si-Cu-Mg. These coarse phases do not contribute to strength and their degree of influence on wear behavior depends on their distribution and size relative to the Si particles [Moh12]. High wear resistance is imparted to the alloy when Mg$_2$Si, Al$_2$Cu and Al-Mg-Si-Cu phases are present in the form of fine particulates. Spray deposition process has emerged as a promising route for manufacturing of alloys, composites and structural materials with the benefits associated with the rapid solidification such as fine grained microstructure, increased solid solubility and fine primary and secondary phases. In the spray forming process, liquid droplets are first atomized from a molten metal stream, quickly cooled by an inert gas, deposited on a substrate, and finally built up to form a low-porosity deposit with a required shape [Lav96]. The objective of the present study was to make use of the combined effects of rapid solidification and the advantages of hypereutectic Al-Si alloy with Cu and Mg alloying elements. In this study, Al–22Si and Al–22Si–4Cu–1.7Mg alloys were spray formed and hot pressed. The microstructural features of both as-spray formed and hot pressed alloys were reported. The effect of the modified microstructure of spray formed alloys on the wear behavior were studied and compared with that of the as-cast alloys.
2.0 Experimental details
The chemical composition of Al–22Si and Al–22Si–4Cu–1.7Mg alloys is shown in Table 1. The details of spray forming set up employed in the present study have been described elsewhere [Day13]. In brief, spray forming process employed an annular convergent-divergent nozzle to create a spray of the melt. In each run 2.5 kg of alloy has been melted to a superheat temperature of 150°C in a resistance heating furnace. The molten metal is atomized by a free fall atomizer using N$_2$ gas. The resultant spray is deposited over a Cu substrate resulting in a near net shaped preform. The process variables employed for producing the preforms are listed in Table 2.
**Table 1:** Chemical composition of Al–22Si and Al–22Si–4Cu–1.7Mg alloys
| Alloy | Si | Cu | Fe | Ni | Mg | Al |
|------------------------|----|----|----|----|----|----|
| Al-22Si | 22 | 0.06 | 0.05 | 0.035 | 0.123 | Bal |
| Al-22Si-4Cu-1.7 Mg | 22 | 4.0 | 0.004 | 0.025 | 1.72 | Bal |
**Table 2:** Process variables in spray forming process
| Process variable | Value |
|-----------------------------------|----------------|
| Melt super heat temperature | 100°C |
| Atomizing gas | N$_2$ |
| Gas pressure | 0.45 MPa |
| Type of nozzle | Free fall |
| Nozzle to substrate distance | 390 mm |
| Melt flow rate | 2.48 kg/min |
| Diameter of the delivery nozzle | 4 mm |
Specimens of size 100 x 30 x 20 mm were cut from the preforms. The specimens were hot pressed at a pressure of 55 MPa and a temperature of 480°C for densification. The density of
spray formed alloys was measured by using Archimedes principle as per ASTM: B962 – 08. The percentage of porosity (% P) in the spray formed alloys was measured by using the actual density ($\rho_{ac}$) and the theoretical density ($\rho_{th}$) of the alloys using the relation, % P = [1 - ($\rho_{ac} / \rho_{th}$)] x 100. The samples were prepared by polishing using standard metallographic techniques of grinding on emery paper with 1/0, 2/0, 3/0 and 4/0 specifications and cloth polishing. The polished samples were etched with Keller’s reagent (1% vol. HF, 1.5% vol. HCl, 2.5% vol.HNO3 and rest water). The microstructures of the samples were examined under a ZEISS Optical Microscope and Scanning Electron Microscopy (S-3400N Hitachi Model). The hardness measurement was carried out using Vickers Hardness Tester (Mattoon ATK-600) at an applied load of 300g. Wear tests were conducted on all the alloy specimens on a pin-on-disc wear testing machine (Model: TR-20, DUCOM) as per ASTM: G99-05. The counterpart disc was made of quenched and tempered EN-32 steel having a surface hardness of 65HRC. Wear specimens of size Ø8×30 mm were machined out from both the alloys. The specimens were polished and then cleaned with acetone before conducting the wear test. The wear tests were conducted by varying load from 10–50 N at a sliding velocity of 1.5 ms$^{-1}$ and a sliding distance of 1025 m. Similarly the sliding velocity of the disc was varied from 0.4 to 1.4 ms$^{-1}$ at a constant applied load of 50 N. All the experiments were carried out under dry sliding conditions and data was recorded at room temperature. The worn surfaces of both the alloys after wear testing were examined under Scanning Electron Microscopy.
3.0 Results and discussion
3.1 Microstructural features
Fig. 1 (a) shows the optical micrograph of as-cast Al–22Si alloy. It consists of large sized polyhedral shaped primary Si and needles of eutectic Si in the Al-matrix. The size of primary Si size ranges from 50 to 350 µm and length of the eutectic silicon needles ranges from 20 to 50 µm. Fig. 1 (b) shows the optical microstructure of as-cast Al–22Si–4Cu–1.7Mg alloy. The microstructure consists of coarse block like primary Si with eutectic network of Al-Si phase together with the intermetallic phases. SEM/EDS micrograph of as-cast Al-22Si alloy is shown in Fig. 2 (a). It consists of coarse primary Si particles in the form of plate like / fishbone structure while, eutectic phase comprises of Si needles randomly distributed in the Al-matrix. The phase composition of as-cast Al-22Si alloy is shown in Table 3.
**Fig. 1:** Optical micrographs of as-cast (AC) alloys (a) Al–22Si (b) Al–22Si–4Cu–1.7Mg
SEM/EDS micrograph of as-cast Al-22Si-4Cu-1.7Mg alloy is shown in Fig. 2 (b) It is mainly composed of primary Si particles having sharp edged polygonal plate like morphology, Q phase, and $\theta$-Al$_2$Cu phase exists in the form of needles /Chinese script distributed randomly in
the Al-matrix. The size of Si varies from 75–150 μm. The EDS results of various phases present in the as-cast alloy is shown in Table 4.
**Table 3:** EDS analysis of as-cast Al–22Si alloy
| Location | Composition | Phase | Al-K | Mg-K | Si-K | Fe-K |
|----------|-------------|-----------|------|------|------|------|
| Point 1 | Al\textsubscript{83}Si\textsubscript{11.5} | Eutectic phase | 80.56 | 0.00 | 19.81 | 0.37 |
| Point 2 | Si\textsubscript{98} | Si | 0.14 | 0.05 | 99.72 | 0.00 |
| Point 3 | Al\textsubscript{99} | α-Al Matrix | 96.92 | 0.00 | 17.04 | 0.00 |
**Table 4:** EDS analysis of as-cast Al–22Si–4Cu–1.7Mg alloy
| Location | Composition | Phase | Al-K | Mg-K | Si-K | Cu-K |
|----------|---------------|-------------|------|------|------|------|
| Point 1 | Al\textsubscript{2}Cu\textsubscript{1.5} | Al\textsubscript{2}Cu | 45.73 | 1.14 | 0.00 | 50.16 |
| Point 2 | Si\textsubscript{98} | Si | 0.94 | 0.00 | 98.37 | 0.49 |
| Point 3 | Al\textsubscript{79}Mg\textsubscript{4}Si\textsubscript{3}Cu\textsubscript{1} | Q-phase | 78.27 | 2.70 | 15.48 | 3.44 |
Fig. 3 (a) represents the optical micrograph of spray deposited Al-22Si alloy. The alloy consists of fine primary Si with spherical morphology having average size less than 10 μm, the eutectic Al-Si phase has been finely divided into smaller particles and distributed uniformly throughout the Al matrix. A porosity of 11.6% with spherical morphology of micron size was observed in the spray deposited alloy. Fig. 3 (b) shows the optical microstructure of spray formed Al-22Si-4Cu-1.7Mg alloy. The microstructure consists of an equiaxed, nearly spheroidized grain morphology of α-Al matrix. The Si particles are highly refined having a size varying from 2–25μm, Cu and Mg containing intermetallics are uniformly distributed in the Al-matrix. The presence of fine, spherical porosity of 15.2 % has been observed in the spray formed alloy. Fig. 4 (a) shows the SEM/EDS micrograph of spray deposited Al-22Si alloy. It can be seen from the micrograph that the alloy exhibited the primary Si particulates and fine eutectic Si phase which are uniformly distributed in Al-matrix. The EDS results of various phases present in the spray deposited alloy is shown in Table 5. The SEM/EDS micrograph of spray deposited Al-22Si-4Cu-1.7Mg alloy is shown in the Fig. 4 (b). The microstructure of alloy exhibited coexisting faceted primary Si particles and fine plates of complex intermetallic phases. The size of Si particles varied from 3 to 20 μm compared to large particle size of 150 μm in as-cast alloy. The various phases present are grey colored Si particulates as a major element, grey colored intermetallic Q-Al\textsubscript{48}Si\textsubscript{29}Mg\textsubscript{18}Fe\textsubscript{4} phase and bright white phase of θ-Al\textsubscript{2}Cu. The EDS results of various phases present in the spray deposited alloy is shown in Table 6.
Fig. 3: Optical micrographs of spray deposited alloys (a) Al–22Si (b) Al–22Si–4Cu–1.7Mg
Fig. 4: SEM/EDS micrograph of spray deposited alloys (a) Al–22Si (b) Al–22Si–4Cu–1.7Mg
Table 5: EDS analysis of spray deposited Al–22Si alloy
| Location | Composition | Phase | Al-K | Mg-K | Si-K | Fe-K |
|----------|---------------|-------------|------|------|------|------|
| Point 1 | Al\textsubscript{10}Si\textsubscript{88} | Eutectic Si | 11.22 | 0.05 | 88.30 | 0.00 |
| Point 2 | Al\textsubscript{99}Si\textsubscript{1} | \alpha-Al Matrix | 96.59 | 0.00 | 0.75 | 0.25 |
| Point 3 | Si\textsubscript{98}Al\textsubscript{2} | Si | 1.62 | 0.12 | 98.11 | 0.00 |
Table 6: EDS analysis of spray deposited Al-22Si-4Cu-1.7Mg alloy
| Location | Composition | Phase | Al-K | Mg-K | Si-K | Cu-K |
|----------|-------------|-------|------|------|------|------|
| Point 1 | Si | Si | 1.05 | 0.07 | 97.74 | 0.75 |
| Point 2 | Al matrix | Si | 94.48 | 0.97 | 0.00 | 1.28 |
| Point 3 | Al\textsubscript{2}Cu | \theta | 56.09 | 2.11 | 1.17 | 37.88 |
| Point 4 | Si | Si | 0.99 | 0.00 | 97.05 | 0.00 |
| Point 5 | | Q-phase | | | | |
Fig. 5 shows the X-ray images of spray formed Al-22Si-4Cu-1.7Mg alloy. This reveals the presence of Si, Cu and Mg elements which are uniformly distributed in the spray formed alloy and is well corroborated with EDS results.
The optical microstructure of spray formed and hot pressed Al-22Si alloy is shown in Fig. 6 (a). This exhibits the fragmentation of primary Si particles, eutectic Si phase, significantly reduced porosity level of 5.4% and increased volume fraction of Si phase. Fig. 6 (b) shows the optical micrograph of spray formed and hot pressed Al-22Si-4Cu-1.7Mg alloy. It can be observed from the Fig. 6 (b) that there is a fragmentation of Si and brittle \(\theta\) and Q intermetallics and porosity has been reduced to 3.8%.
Fig. 5: EPMA micrograph of spray formed Al-22Si-4Cu-1.7Mg alloy (a) Al (b) Si (c) Cu (d) Mg
Fig. 6. Micrographs of spray formed and hot pressed alloys (a) Al-22Si (b) Al-22Si-4Cu-1.7Mg
The solidification of as-cast Al-22Si and Al-22Si-4Cu-1.7Mg alloys, due to slow cooling rate and broad temperature interval between the liquidus and solidus of higher Si content composite in the pseudo binary section will cause castings with a coarse plate like Si, needle like Q and Chinese script like Al$_2$Cu phases. In spray forming process, the solidification phenomena changes due to the effect of high cooling rate during the atomization stage and the unique microstructural evolution mechanism after deposition. The fine uniform distribution of primary Si particles and eutectic Si phase and equiaxed morphology of the $\alpha$-Al phase are remarkable features of spray deposited hypereutectic Al-Si alloy. These features are due to the relatively high cooling rate ($10^3$-$10^6$ Ks$^{-1}$) associated with repeated deformation and extensive fragmentation of partially solidified droplets during the build-up of the deposit which could effectively alter the morphological stability of the Si phase [Sri01]. As the cooling rate increases during atomization, the droplets experience a large undercooling prior to nucleation of primary Si phase leading to refinement. Simultaneously, reduced temperature suppresses the growth of these phases even after the deposition [Gra95]. Thus, large amount of fine and uniformly distributed Si and greater number of precipitates (Al$_2$Cu phase, Q phase) are seen in the spray formed Al-22Si-4Cu-1.7Mg alloy. The dendritic as well as the Chinese script structures observed
in the as-cast alloys are modified and it is difficult to discern the difference between primary Al$_2$Cu and Q phases. The porosity has been observed in the deposits and was uniformly distributed. The spherical morphology and non-connected distribution of the pores suggest that their formation occurred due to the incorporation of gas, a well-described phenomenon caused by an excessive presence of liquid during the spray formation [Cai98]. Hot pressing of spray formed alloys led to a considerable reduction in porosity and recrystallization of microstructure to a certain extent. The preheating treatment before compression process can make the microstructure more uniform. Secondly, hot deformation leads to a microstructural refinement and a solid-state phase transformation. The severe stress imposed by hot compression generates high density dislocations in the grains. Subsequently, the movement and arrangement of dislocations form lot of small angle grain-boundaries, refining initial grains into several substructures. In addition to the refinement of grains, hot deformation also promotes homogeneous precipitation of hardening of $\theta$ and Q phases which can pin the movement of dislocations to restrain grains coarsening during recrystallization effectively [Est90].
3.2 Hardness
The results of hardness measurement of spray formed + hot pressed (SF + HP) Al-22Si and Al-22Si-4Cu-1.7Mg alloys are as shown in the Table 7. It is observed from the results that a significant increase in the microhardness of SF+HP alloys takes place compared to as-cast alloys. The SF+HP Al-22Si-4Cu-1.7Mg alloy exhibits higher hardness compared to Al-22Si alloy. The increase in the hardness of spray formed + hot pressed Al-22Si alloy is due to the presence of fine and uniform distribution of Si particles in Al-matrix as well as reduction of porosity. It may be noted that an increase in the volume fraction of the Si particles will lead to higher constraint in the localized deformation of softer matrix under the application of indentation load. The fine primary Si and eutectic Si phases provide an appreciable impediment to plastic deformation caused by the indentation. The higher hardness of spray formed + hot pressed Al-22Si-4Cu-1.7Mg alloy can be attributed to the presence of fine and uniform distribution of brittle intermetallic $\theta$-Al$_2$Cu and Q phases in addition to fine primary Si particles [Sha07, Hau09].
Table 7: Hardness of as-cast and SF + HP alloys
| Alloy | Processing route | Hardness (VHN) |
|------------------------|------------------|----------------|
| Al-22Si | As-cast | 53 |
| Al-22Si | SF + HP | 83 |
| Al-22Si-4Cu-1.7Mg | As-cast | 67 |
| Al-22Si-4Cu-1.7Mg | SF + HP | 116 |
3.3 Wear characteristics
Variation in the wear rate of both the AC and SF + HP alloys as a function of applied load at constant sliding velocity of $1.5 \text{ms}^{-1}$ is shown in Fig.7. Wear rate of both as-cast and SF + HP alloys increases with increasing normal load. Comparative study of wear behavior of two alloys shows that SF + HP alloys are subjected to lower wear rate than as-cast alloys under identical sliding conditions. In the entire range of applied load, the SF + HP Al-22Si-4Cu-1.7Mg alloy exhibited best wear resistance.
Fig. 8 shows the effect of sliding velocity on the wear rate of the alloys. It is worthwhile to note that the wear rate initially decreases with increasing sliding velocity. With further increase in the sliding velocity beyond the critical limit, the wear rate increases irrespective of
alloy condition and composition. It is observed from the variation of wear rate with sliding velocity that the spray formed alloys show less wear rate than as-cast alloys. Minimum wear rate is observed in SF + HP Al-22Si-4Cu-1.7Mg alloy. Fig. 9 depicts the variation of coefficient of friction of Al-22Si and Al-22Si-4Cu-1.7Mg alloys. It can be seen that initially, the coefficient of friction decreased with increasing load and found to be constant in all the alloys with further increase in load. The spray formed and hot pressed alloys indicate lowest coefficient of friction, whereas the highest friction coefficients occurred in the as-cast alloys. The different wear characteristics of spray formed alloys are related to their microstructural features. The wear behavior of hypereutectic Al-Si alloys has been reported in several recent investigations [Dhe06, Cla79, Pra87, Sas92, Raj12].
In general, the size and shape of Si particles and the nature of dispersion of second phase particles in the matrix have been observed to have a strong influence on the wear rate of a wide range of materials. In the present work, the spray-formed and hot pressed alloys exhibit an uniform distribution of fine Si particles and distribution of hard intermetallics (Q-phase) and $\theta$-$\text{Al}_2\text{Cu}$ precipitates have a large influence on the dry sliding wear behavior of alloys [Haq01]. These features of the spray formed alloy are attributed to strong bonds at the matrix-particle interface due to the decrease in the particle size and the consequent microstructural stability of the alloy under a range of applied loads and sliding velocities. The block like Si particles, long needles of intermetallic Q-phase and coarse $\theta$-$\text{Al}_2\text{Cu}$ phase appear to have played an important role in aggravating the wear process in as-cast alloy. The sharp edges of Si particles and intermetallic Q-phase may have acted as crack nucleation sites resulting in a stress concentration that is more severe at the interface between the tip of needle-like intermetallic Q-phase and the Al-matrix that led to the fracture of long needles of Q-phase resulting in a high wear rate in as-cast alloy. The reduction in porosity, recrystallization and fragmentation of Q-phase and $\text{Al}_2\text{Cu}$ phase, their uniform distribution in the matrix of spray formed and hot pressed alloy, decrease the stress concentration between the fine needles of Q-phase and the matrix and increase the strength of matrix due to fine dispersion of $\text{Al}_2\text{Cu}$, resulting in an improved wear resistance.
At low loads, more time is available for the formation and growth of micro-welds, which increases the force needed to shear-off the micro-welds to keep the relative motion and this leads to an increase in wear resistance. An increase in the load results in the rise of the interface temperature that engenders oxidation and thermal softening of material. The brittle and discrete oxide film is harmful because it acts as a hard impurity or third body between mating surfaces [Ana09]. The wear rate with normal load shows a linear relation up to the load of 40 N. Further increase in the load to 50 N shows an abrupt increase in wear rate indicating a change in the wear mechanism. At high loads, the thermal softening of the alloy in the sub surface region takes place leading to a large scale plastic deformation [Moh96]. Under such conditions, metallic wear takes place. The remarkable observation in the present study is that the fine distribution of Si, intermetallic phases and good interfacial bonding at the interface with the matrix provided by the fine precipitates of $\theta$-$\text{Al}_2\text{Cu}$, allows for high temperature stability leading to a low wear rate in SF + HP Al-22Si-4Cu-1.7Mg alloy compared to SF + HP Al-22Si alloy. The dispersoids of intermetallics phase in Al-22Si-4Cu-1.7Mg alloy possess higher hardness compared to that of eutectic Si phase in Al-22Si alloy. The low melting constituent of eutectic Si is smeared out on mating surfaces at an early stage. This effect arises due to small interparticle spacings of dispersoids in spray-formed Al-22Si-4Cu-1.7Mg alloy.
Consequently, a thin oxide layer is developed on the surface of wear test specimen which protects the materials from further wear. The low wear rate of SF + HP Al-22Si-4Cu-1.7Mg
alloy justifies this mechanism. However, the stability of the oxide layer on the specimen surface depends on applied load and sliding velocity of the mating surfaces. The experimental result indicates that the stability regime of the oxidation film is extended to higher load and sliding velocity in the mild wear regime of the SF + HP alloys. However, as the sliding velocity is further increased, instability arises in the continuity of the oxidation layer. This is indicated by a significantly high wear rate of the material with further increase in the sliding velocity. Still in this severe wear regime, the SF + HP alloys, owing to the uniformly distributed Si and small inter particle spacing of its fine Si particles and intermetallics, continues to provide a relatively low wear rate compared to the as-cast alloys.
**Fig. 7:** Variation in wear rate with load of AC & SF + HP alloys at a sliding velocity of 1.5 ms$^{-1}$
**Fig. 8:** Variation in wear rate with sliding velocity of AC & SF+HP alloys at a load of 50 N
Fig. 9: Variation in Coefficient of friction with load of AC and SF + HP alloys
3.4 Characterization of worn surfaces
Fig. 10 (a) shows the worn surfaces of as-cast Al-22Si alloy. The surface is characterized by grooves running from one end to the other end of the surface. Large and heavy scoring marks with dimples are present on the surface. The worn tracks and surface damages like micro-grooves, craters and abrasive scoring marks were also clearly observable. Detailed examination of the wear tracks revealed features associated with abrasive and delamination mechanism. The abrasive component of the wear mechanism is pointed out by the plough grooves inside the wear tracks due to the harder silicon particles scratching over the softer (pin) surface. Additionally, the delamination wear component can be concluded from the cracks and shallow craters, which are seen at the worn surface. Some large dimples can also be seen on the worn surface of the alloy, it indicates that block-like primary Si phases were fractured and broken off during wear. Fig. 10 (b) shows the worn surface of SF + HP Al-22Si alloy. The grooves depicted on the worn surface are shallow and uniform. The surface clearly shows a smooth and fine scoring marks and without any pits and dimples that obviously leads to a low wear rate.
The SEM micrographs of worn surfaces of Al-22Si-4Cu-1.7Mg alloys are shown in Fig. 11. The worn surface of as-cast alloy shown in Fig. 11 (a) consists of ploughing marks and a large number of pits indicating a high wear rate. The heavy damage may be due to the presence of long needles of Q-phase and coarse $\theta$-Al$_2$Cu phase and their uneven distribution in the alloy. It seems that the coarse phases are readily fractured and broken off during wear weakening the matrix leading to a high wear rate. In contrast, the worn surface of spray formed + hot pressed alloy shown in Fig. 11 (b) consists of light scoring marks and shallow dimples in one or two regions clearly indicating a low wear rate. This may be due to the refinement in the microstructure where the Q-phase and $\theta$-Al$_2$Cu phase have been finely divided and uniformly distributed in the matrix. This fine dispersion provides strength to the matrix and the bonding between these phases and the matrix is strong enough to retain them to the matrix during wear leading to a low wear rate [Wan04].
Fig. 10: SEM micrographs of worn out surface of Al-22Si alloys (a) as-cast (b) SF+HP
Fig. 11: SEM micrographs of worn surface of Al-22Si-4Cu-1.7Mg alloys (a) as-cast (b) SF+HP
4.0 Conclusions
I. Spray forming is effective in refining the microstructures of Al-22Si and Al-22Si-5Cu-1.7Mg alloys. The spray deposited Al-22Si alloys exhibited fine and uniform distribution of primary Si and eutectic Si phases and equiaxial morphology of $\alpha$-Al phase. The microstructure of spray formed Al-22Si-5Cu-1.7Mg alloy exhibited fine and uniform distribution of both primary and eutectic Si with small needles of Q-intermetallics and $\theta$-Al$_2$Cu precipitates spread around the boundaries and junctions of grains in $\alpha$-Al matrix.
II. Hot pressing of spray-formed alloys leads to reduction in porosity, grain recovery and recrystallization to certain extent. The spray formed and hot pressed alloys show maximum hardness compared to as-cast alloys.
III. The spray formed and hot pressed Al-22Si-5Cu-1.7Mg alloy showed maximum hardness compared to other alloys. Wear rate of spray formed Al-22Si-5Cu-1.7Mg alloy is lower than that of Al-22Si alloy under identical sliding conditions. This is because of the presence of fine intermetallics in the former alloy.
IV. The wear rate of both as-cast and spray formed alloys initially decreases with increase in sliding speed up to a critical speed and then increases but the wear rate is high for as-cast Al-22Si alloy and low for spray formed and hot pressed Al-22Si-5Cu-1.7Mg alloy.
References
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[Dhe06] Dheerendra Kumar Dwivedi: Wear behavior of cast hypereutectic aluminum silicon alloys”, Materials and Design, 27 (2006), 610–616
[Dwi04] Dwivedi D K: “Sliding temperature and wear behavior of cast Al-Si-Mg alloys”, Materials Science and Engineering: A, 382 (2004), 328-334
[Sri06] Srivastava A K, Srivastava V C, Gloter A, Ojha S N: “Microstructural features induced by spray processing and hot extrusion of an Al-18%Si-5%Fe-1.5% Cu alloy”, Acta Materialia, 54 (2006), 1741–1748
[Moh12] Mohamed A M A, Samuel F H: “A Review on the Heat Treatment of Al-Si-Cu/Mg Casting Alloys, Heat Treatment-Conventional and Novel Applications,” (2012)
[Lav96] Lavernia E J, Yu W: “Spray atomization and deposition”, John Wiley & Sons Inc. (1996), Chichester (UK)
[Day13] Dayanand M G, Raju K, Srivastava V C, Rudrakshi G B: “Effect of secondary processing on the microstructure and wear behavior of spray formed Al-30Mg$_2$Si-2Cu alloy”, Materials and Design 47 (2013), 489–496
[Sri01] Srivastava V C, Mandal R K, Ojha S N: “Microstructural Evolution During Spray Forming of Al-18%Si Alloy”, Journal of Materials Science Letters, 20(2001), 27-29
[Gra95] Grant P S: Spray forming, Progress in Material Science, 39(1995), 497–545
[Cai98] Cai W D, Lavernia E J: Modeling of porosity during spray forming: Part-I”, Metallurgical and Materials Transactions B, 29 (1998), 1085-1096
[Est90] Estrada J L, Duszczyk J: “Characteristics of rapidly solidified Al-Si -X preforms produced by the osprey process”, Journal of Materials Science, 25 (1990), 1381-1391
[Sha07] Sharma R, Dwivedi D K. “Solutionizing temperature and abrasive wear behavior of cast Al- Si-Mg alloys”, Materials and Design, 28 (2007), 975–1981
[Hau09] Huang L J, Geng L, Li A B, Cui X P, Li H Z, Wang G S: “Characteristics of hot compression behavior of Ti-6.5Al-3.5Mo-1.5Zr-0.3Si alloy with an equiaxed microstructure”, Material Science and Engineering A, 505 (2009), 136-143
[Cla79] Clarke J, Sarkar A D: “Wear characteristics of as-cast binary aluminum silicon alloys”, Wear, 54 (1979), 7–16
[Pra87] Pramila Bai B N, Biswas S K: “Characterization of dry sliding wear of Al-Si Alloys”, Wear, 120 (1987), 61-74
[Sas92] Sasada T, Ban S, Norose S, Nakano T: “Wear of binary alloys - difference in wear mode between solid solutions and intermetallic compounds”, Wear, 159 (1992), 191-199
[Raj12] Raju K, Harsha A P, Ojha S N: “Effect of microstructure on wear characteristics of spray cast Al-Si alloys”, Materials Science Forum 710 (2012), 545–550
[Haq01] Haque M M, Sharif A: “Study on wear properties of Al-Si piston alloy”, Journal of Materials Processing Technology 118 (2001), 69–73
[Ana09] Anasyida A N, Daud A R, Ghazali M J: “Dry sliding wear behavior of Al-4Si-4Mg alloys by addition of cerium”, International Journal of Mechanical and Materials Engineering 4 (2009), 12–30
[Moh96] Mohanty P S, Gruzleski J E: “Grain refinement mechanisms of hypoeutectic Al–Si alloys”, Acta Materialia 44 (1996), 360–374
[Wan04] Wang F, Ma Y, Zhang Z, Cui X, Jin Y: “A comparison of the sliding wear behavior of a hypereutectic Al–Si alloy prepared by spray-deposition and conventional casting methods”, Wear 256 (2004), 342–345
|
MARCH 2016
Taking Fisheries to School: Workshop Report
Downeast Fisheries Partnership
PREPARED BY
Sarah Madronal
Fisheries Associate
Penobscot East Resource Center and Downeast Fisheries Partnership
email@example.com
(207) 367-2708
Anne Hayden
Coordinator
Downeast Fisheries Partnership
firstname.lastname@example.org
(207) 725-9742
Contents
4 About Downeast Fisheries Partnership
5 Introduction
6 Opportunities for Fisheries Education
7 Challenges and Prospects for Fisheries Education
8 Power of Networks
9 Where do we go from here?
10 Appendix A: List of Participants and Affiliations
12 Appendix B: Fisheries Education Programs in Downeast Maine
About Downeast Fisheries Partnership
Downeast Fisheries Partnership (DFP) is a collaborative effort with a vision of re-establishing fisheries as a means of sustaining coastal communities for many future generations: the communities of eastern Maine will sustain themselves forever by fishing.
Since its founding in 2013 by Downeast Salmon Federation, Penobscot East Resource Center, and Manomet, DFP has initiated conversations about fisheries with a broad range of stakeholders including nonprofits, fishermen, fisheries managers, and other interested individuals. Ideas and energy generated in this ongoing process have led to a raised level of awareness of the potential for fisheries restoration and a series of projects - from habitat restoration and watershed planning to creating a role for fishermen in stewardship and management.
DFP Partners
DOWNEAST SALMON FEDERATION
Our mission is to conserve wild Atlantic salmon and its habitat, restore a viable sports fishery and protect other important river, scenic, recreational and ecological resources in eastern Maine.
www.mainesalmonrivers.org
PENOBSCOT EAST RESOURCE CENTER
Since 2003, Penobscot East has worked to secure a future for the fishing communities of eastern Maine. We create programs that tap the deep knowledge of fishermen, provide innovative leadership on fisheries management, and advocate for community scale fisheries.
www.penobscoteast.org
MANOMET
For over forty years, Manomet has worked to use science as a common currency to combine the interests of diverse stakeholders for creating a more sustainable world.
www.manomet.org
SUNRISE COUNTY ECONOMIC COUNCIL
The Sunrise County Economic Council initiates and facilitates the creation of jobs and prosperity in Washington County, Maine, by working with a consortium of community-minded businesses, not-for-profit organizations, municipalities and citizens.
www.sunrisecounty.org
MAINE COAST HERITAGE TRUST
Maine Coast Heritage Trust conserves and stewards Maine’s coastal lands and islands for their renowned scenic beauty, ecological value, outdoor recreational opportunities, and contribution to community well-being. MCHT provides statewide conservation leadership through its work with land trusts, coastal communities and other partners.
www.mcht.org
COLLEGE OF THE ATLANTIC
College of the Atlantic enriches the liberal arts tradition through a distinctive educational philosophy, human ecology, which integrates knowledge from all academic disciplines and from personal experiences to investigate—and ultimately improve—the relationships between human beings and our social and natural communities.
www.coa.edu
MAINE FARMLAND TRUST
Maine Farmland Trust protects farmland, supports farmers, and advances the future of farming.
www.mainefarmlandtrust.org
Introduction
Fisheries Education
Fishing matters in eastern Maine, but it’s a livelihood that has changed dramatically in recent decades and will continue to change as the impacts of climate change and growing demand for seafood are felt. Over the past several months, concern among those engaged in rebuilding fisheries coalesced around a concern that eastern Maine residents had insufficient opportunities to learn about fisheries and, as a result, were unprepared to contribute to fisheries renewal or benefit from its full potential. Expanding opportunities to learn about the fisheries of Downeast rivers and coastal waters as well as their stewardship emerged as an avenue to make progress toward our “fishing forever” vision. In October 2015, DFP facilitated a workshop for educators to explore this idea further. Ultimately, the goal of this effort is to provide opportunities for children and adults to learn about fisheries at every stage of the educational continuum—from kindergarten through community-based, adult education programming. Such opportunities could prepare students in school - college bound or not and whether they intend to be fishermen or not - to be stewards of their local ecosystems. One workshop participant, Charlie Harrington, Maine Sea Coast Mission’s Director of EdGE Program, shared that the educational programming he manages for the Maine Sea Coast Mission is “concerned with kids who are staying in their communities, who will become selectman, members of the school board, etc.”
“The goal of fisheries education is to prepare students to participate in the ‘fish forever’ vision.”
ANDY WHITMAN, MANOMET
The workshop brought together 30 individuals representing 18 different organizations (see Appendix A) and provided a platform for participants to brainstorm how to build on existing fisheries-related education programs to expand fisheries-related topics in educational programs in both school-based and extracurricular settings.
Education can create conditions that allow people to work together in common understanding. Fisheries education is important at all ages in order to create lifelong learners and stewards of our marine resources. Continued education beyond school years is also vital to bring together communities around fisheries-related issues. All of this combined effort and teamwork can lead to resource restoration and protection. Andy Whitman, of Manomet, summarized this sentiment well: “The goal of fisheries education is to prepare students to participate in the ‘fish forever’ vision.”
The event was held at Schoodic Institute in Winter Harbor, Maine. Educators, members of the public, and other professionals interested in fisheries education discussed how to connect existing programs and engaged individuals to expand fisheries knowledge in and out of school. Knowledge and experience
sharing throughout the workshop strengthened existing and fostered new connections that have the potential to fill gaps in fisheries education. Such collective brainstorming is the first step towards improving fisheries-related educational programming, especially in eastern Maine.
**Opportunities for Fisheries Education**
In our Downeast coastal communities, many people are connected in some way to fisheries and the ocean, whether it be through employment, family, recreation or enjoyment of local seafood. Creating the conditions that may foster a sense of place is important for coastal community members of all ages since it contributes to a greater sense of place and encourages understanding of community roles in dynamic fisheries and marine systems.
There are a surprising number of fisheries-related education programs in the Downeast region (see Appendix B). They include school, afterschool, summer programs, and extend to adult education. Programs focus on intertidal ecology, hands-on habitat restoration, skills needed to be a fisherman or woman, and a guided trail to high points of Downeast Maine’s maritime legacy, among many others. They provide opportunities for people of all ages and life stages to learn about fisheries, aquatic science, and eastern Maine’s unique river and coastal ecosystems. These programs, however, reach a relatively small number of potential participants, and an even smaller number of actual participants; for example there are over 3,300 public high school students in the Downeast region and 86 of them participate in Eastern Maine Skippers Program. More needs to be done to expand fisheries-related educational programming to ensure that all have the opportunity to learn more and those who choose to do so can be accommodated.
Challenges and Prospects for Fisheries Education
It’s a good news, bad news story for eastern Maine’s schools. They tend to be small, rural, and underfinanced. But lack of resources makes them open to collaboration with outside groups, creating opportunities to expand exposure to fisheries for school-aged children. Currently such efforts include the Island Readers and Writers use of an alewife-themed book in their school-based literacy programs - and field trips that reinforce academics, such as those provided by the Maine Seacoast Mission’s EdGE program. Charlie Harrington said, “Our schools in the Downeast region don’t have field programs; the Mission’s programs connect the school curriculum to field work.” This outside-the-classroom learning is critical for forging strong connections between students and their environment.
The topic of fisheries creates challenges for teachers as it incorporates complex and interrelated topics including marine ecology, fisheries management, the economics of both fishing and seafood markets, as well as community social dynamics. Extracting and distilling useful information from a variety of data sources can be difficult for teachers and students alike. The Schoodic Education and Research Center (SERC) provides workshops for science teachers. Hannah Webber runs teacher workshops at SERC; she noted that, “The content changes, but the process doesn’t; the students are taught how to ask research questions, develop a hypothesis, and collect and process data to answer their question.” This training is useful in helping teachers, and by extension, students navigate these complex topics, apply them in a local context, and generate a shared understanding of the drivers of coastal ecosystems and their fisheries.
“Our schools in the Downeast region don’t have field programs; the Mission’s programs connect the school curriculum to field work.”
CHARLIE HARRINGTON, DIRECTOR OF MAINE SEA COAST MISSION’S EDGE PROGRAM
The workshop yielded some lessons learned by experienced professionals in the field. For fisheries-related educational collaborations to be successful, dedicated staffing is needed to coordinate the effort in terms of goals, communication, and expectations. For a successful collaboration or idea to turn into a program, there needs a blend of expertise at the table from scientists to teachers to businesses and beyond. With this structure and organization, programs also need to be flexible and responsive to changing interests as well as needs. Time is another factor that can determine the success of an educational effort. Workshop participants agreed that it takes about 10 years to build a program that is sustainable in terms of staff and funding. A larger lesson was drawn from the history of recent attempts at education reform; Charlie Harrington noted, “What we have done well in reform is what we have done together.”
**Power of Networks**
Our workshop group agreed that it is important to build on the network of individuals and organizations present: expand the network, reinforce it by following up on suggestions presented for collaboration, and promote the value of working together. Not only is it beneficial for professionals to network, but also for those networks to be extended to students and their communities. Val Peacock, Rural Aspirations and Eastern Maine Skippers Program, also noted, “Engaging kids in their own person, their own education, and their own community is important.” In this way, fisheries can be integrated more closely into the life of a community, and fisheries knowledge can be shared more widely.
Networks are essential for creating an effective and compelling movement. They are different from traditional organizations in that they cast their gazes externally rather than internally. They put their mission first and their organization second to advance their missions through trust rather than control. And they cooperate as equal nodes in a constellation of actors rather than relying on a central hub to command with top-down tactics. Networks allow participating organizations to develop interconnected solutions at the scale of the problems they seek to address. Networks are better positioned to leverage external resources than organizations acting independently. Ultimately, the whole is greater than the sum of its parts.
To visualize our existing and potential connections, workshop participants connected themselves (photo above) with colored lines representing those other participants whom they knew prior to the workshop, and as a result of the workshop, wanted to work with them going forward. This chaos of colored lines illustrated the interconnectedness of those working towards expanded opportunities for fisheries-related education and the incredible potential for leveraging these connections for expanding fisheries-related education in Downeast, Maine.
**Where do we go from here?**
At the end of our day we asked participants to reflect on the day’s discussions. Comments submitted with the workshop survey included, “took connections away,” and “hearing from other educators having success has revitalized my energy and added fuel to the fire.” “Within the opportunities and challenges of connecting K-12 with college, there is tremendous potential and today we started to think about how
to make it happen.” Some participants reflected on their own experience in school, “To think about my own high school experience and how horrible it was -and know there weren’t people thinking about how to make it better. Now I think about the potential for change and it can be overwhelming, but this is how you do it: get great people in a room together!” One participant expressed gratitude “for the fact that everyone took time from their demanding work to come to this meeting and I look forward to working with everyone soon.” That the workshop was “a great way to meet new people and hear new ideas,” reflected a general consensus. An overall message that rang true was that we “can be more connected and effective,” and that the workshop “has created momentum and a sense of hope. It will be revealing to see what happens in the future.”
As a result of the workshop, we now have an informal network of those interested in fisheries-related education in eastern Maine. Participants can build upon the connections they made at the workshop and share ideas and information. We look forward to reporting on emerging efforts, such as the fact that the Downeast Fisheries Partnership has received grant funds for a pilot fisheries education project with the Maine Seacoast Mission’s EdGE program. If you have an idea for how to expand fisheries education in eastern Maine or want to learn more about how this work is helping to create sustainable fisheries, please be in touch with Sarah Mardonal (email@example.com) or any of the workshop participants listed in Appendix A.
“Within the opportunities and challenges of connecting K-12 with college, there is tremendous potential and today we started to think about how to make it happen.”
WORKSHOP PARTICIPANT
| NAME | ORGANIZATION |
|--------------------|---------------------------------------------------|
| Alan Furth | Cobscook Community Learning Center |
| Amanda Beal | Maine Farmland Trust |
| Andy Whitman | Manomet |
| Anne Hayden | Downeast Fisheries Partnership |
| Charlie Harrington | Maine Sea Coast Mission |
| Chris Petersen | College of the Atlantic |
| Christina Fifield | Penobscot East Resource Center and Eastern Maine Skippers |
| Dave McKechnie | North Haven Community School |
| Deb Burwell | Paddling the Rapids |
| Dwayne Shaw | Downeast Salmon Federation |
| Gerard Zegers | University of Maine at Machias |
| Hannah Webber | Schoodic Institute |
| Jacob van de Sande | Maine Coast Heritage Trust |
| John Hagan | Manomet |
| Katherine Cassidy | Lubec Landmarks |
| Kim Little | Gulf of Maine Research Institute |
| Korah Soll | Rural Aspirations Project |
| Megan Flenniken | Penobscot East Resource Center and Eastern Maine Skippers |
| Michael Giudilli | Cobscook Community Learning Center |
| NAME | ORGANIZATION |
|--------------------|------------------------------------------------------------------------------|
| Rachel Gorich | University of Maine at Machias, Downeast Fisheries Partnership and Downeast Salmon Federation |
| Rebecca Stanley | Gulf of Maine Research Institute |
| Robin Alden | Penobscot East Resource Center |
| Ron Beard | University of Maine Cooperative Ext., Retired |
| Russell Heath | Downeast Salmon Federation |
| RuthnFeldman | Island Readers and Writers |
| Sarah Madronal | Penobscot East Resource Center and Downeast Fisheries Partnership |
| Susan Conant Wilson | Public |
| Valerie Peacock | Rural Aspirations Project and Eastern Maine Skippers |
Appendix B. Fisheries Education Programs in Downeast Maine
This document provides background information on several fisheries education programs in Downeast Maine from Kindergarten to adult education with different fisheries topic focuses. Programs are in alphabetical order. Document prepared by Sarah Madronal. (October 2015).
Cobscook Community High School
Based at the Cobscook Community Learning Center campus in Trescott, this program focuses on getting students outdoors, engaged in service-learning projects, and learning directly from people in our community while building their leadership, outdoor, academic and personal skills. The CCLC partners with Calais High School to offer an accredited course of study for Cobscook Community High School Program students. The CCHS program is highly influenced by methods of experiential education, which is focused on direct experience followed by focused reflection. Experiential education can be found in outdoor education programs, environmental education programs, cooperative education, and service learning projects, all of which are woven into the CCHS experience.
Community Environmental Health Laboratory, MDI Biological Laboratory
The MDI Biological Laboratory’s Community Environmental Health Laboratory (CEHL) identifies, locates, and helps remedy threats to public health and the clean waters on and around Mount Desert Island by putting science in the hands of community volunteers, students, and teachers. Every project CEHL undertakes relies on volunteer efforts from students and community members and involves community education. Current projects at CEHL include research and restoration of eelgrass beds in Frenchman Bay, eelgrass-based education and outreach in local middle and high schools, swim beach water quality monitoring as part of the Maine Healthy Beaches Program, and red-tide monitoring as part of the Maine DMR Volunteer Phytoplankton Monitoring Program.
Downeast Fisheries Trail
The Downeast Fisheries Trail presents a rich educational opportunity for locals and visitors. Exploring fisheries heritage means learning about marine science, ecology, culture, history, policy and economics. Families and student groups visiting the Trail can learn about people that make a living off the sea, and participate in activities that bring fisheries heritage to life. Downeast Fisheries Trail partners reach out to schools and educational institutions to identify places where this project can complement existing curricula at all grade levels. Fisheries heritage-related activities can be taken on the road to festivals and events, and be implemented in schools, at summer camps, and within family and youth programs. Activities might include oral history projects, geo-caching, field studies in marine science, and other activities that help youth connect to the sea, its fisheries, and to the people who depend on them.
Downeast Institute
DEI’s mission is to develop marine educational programs for K-12 students and the general public to foster hands-on learning about our local marine environment and resources. Education programs include K-12 Teacher resources like lessons about the rocky shore, marine science lesson plans for teachers, and how to rear microalgae in a classroom setting. DEI also offers Marine Science Camp Sessions for grades K-12, which teaches kids about identifying marine plants and animals, gives them lab experience, and helps them to explore the habitat at the Rocky Shore at Black Duck Cove in Beals, ME.
Eastern Maine Skippers Program
The Eastern Maine Skippers Program (EMSP) provides aspiring commercial fishermen in eastern Maine high schools with the skills needed to be successful fishermen into the 21st century—in the water and on shore. Students who intend to become commercial fishermen benefit from an educational program that teaches how to be flexible and adaptive fishermen; responsive to an ever-changing fishery, ecosystem, and economy; learn to be entrepreneurs who can hold their own with scientific researchers and policymakers. EMSP is aligned with state and national school standards, ensuring that students who participate graduate high school with the same rigorous academic preparation as other students and are prepared to enter a commercial fishery and college—not just one or the other.”
EdGE
EdGE (Ed Greaves Education) is a youth development program of the Maine Sea Coast Mission for students currently in grades Pre K -8 in coastal Washington and Hancock counties. It is designed to encourage youth to stay engaged in school, attain higher levels of achievement in and out of school, and develop the personal skills that will enable them to achieve this success using a wide range of interdisciplinary and experiential curriculum. EdGE provides afterschool, in school leadership programs and summer programs that include visual and performing arts projects, leadership training, innovative science and technology workshops, skill-building in math and language arts, and outdoor pursuits.
Environmental Living and Learning for Maine Students
The ELLMS Project is a collaboration among five residential environmental learning centers in Maine: Chewonki, The Ecology School, Schoodic Institute, and University of Maine Cooperative Extension 4-H Centers at Bryant Pond and Tanglewood. The mission of ELLMS is to encourage students to develop a lifelong commitment to environmental sustainability and stewardship, outdoor exercise and recreation, good nutrition, community-building, and civic engagement through positive, nature-based activities, lessons, and challenges. Living outdoors builds connections among students and teachers, enlivens learning, fosters group unity, and creates an atmosphere in which trust and exploration can flourish. ELLMS participants gain a deeper understanding of the natural world and their place within it, higher self-esteem, and greater enthusiasm for learning. All of this sets the stage for higher performance and more positive classroom relationships.
Friends of Taunton Bay Education Center
The mission of The Taunton Bay Education Center is to educate citizens about the bay: its ecology, wildlife, marine inhabitants, human history, and economic connections with the community. The Education Center has maps and scientific research obtained from the Taunton Bay Study, completed in 2006; displays from the Historical Societies of the surrounding towns; and bay-related displays including horseshoe crab shells, lobster and clam harvesting equipment, and local seaweed products. The Center opened in July 2007, supported in part by a grant from the Community Building Fund of the Maine Community Foundation.
Hurricane Island is 10 miles southeast of Rockland and two miles southwest of Vinalhaven in the Fox Islands archipelago, Penobscot Bay, Maine. On Hurricane Island, both the Center for Science and Leadership and our Field Research Station initiatives work together to help students and scientists participate in authentic, hands-on field science and collaborative leadership programs and experiences. These programs reach public and private middle and high school students, college and university students, graduate researchers, undergraduate interns, amateur naturalists, scientists, sustainable engineers, and others.
Island Readers and Writers
Island Readers & Writers’ (IRW) mission is to inspire a passion for reading and learning among children living on Maine’s coastal and inland islands. IRW provides innovative book centered programs for children living in these unique places and engages children in hands-on science, art, music, and writing programs that encourages excitement for reading and the creative discovery it inspires. IRW encourages kids to focus on their own lives and the places where they live, with programs in their schools, in libraries and in other places where their families and community members join them in celebrating books and their stories.
LabVenture! GMRI
In GMRI’s LabVenture! Experience for 5th and 6th graders from Downeast to western Maine, students take on the role of scientist and conduct their own hands-on research to understand “Complex Systems”: How do five key species intersect in the Gulf of Main? As scientists and fishermen students discover the connections among cod, lobster, herring, plankton, and humans in the Gulf of Maine ecosystem. They examine food webs, behavior patterns, the economics and impacts of fishing, in order to uncover how these species are inextricably woven together.
Maine Maritime Academy
Maine Maritime Academy’s Corning School of Ocean Studies offers two Bachelor of Science degrees in Marine Biology and Marine Science. A five year dual-degree program is also offered which provides a Bachelor of Science degree in either Marine Biology or Marine Science plus an Associate of Science degree in Small Vessel Operations. The marine science program is a broad-based marine science curriculum encompassing the study of chemistry, biology, physics, geology, writing and communications, computer science, mathematics, humanities, and social sciences. Both programs prepare graduates for a diversity of career fields in ocean sciences including: state and federal agency work, fisheries, aquaculture, research, environmental protection or management, consulting, science education or graduate education.
Machias River Wigwams Program
The Downeast Salmon Federation and the Cobscook Community Learning Center offer a two week experience for Washington County teens interested in outdoor careers. The Machias River Wigwams crew may remove remnant log drive dams, survey culverts for fish passage for fish like endangered Atlantic Salmon, work repairing improving portage trails and campsites in the immediate vicinity of the Wigwams Rapids, and assist archaeologists in volunteer-friendly tasks such as clearing brush, moving dirt and sifting. As a long-term investment, this program works to instill a sense of stewardship in the next generation of Washington County guides and conservationists. These local teens may end up working in forestry where they would make harvest decisions that greatly impact salmon streams, or they may to decide to work as Registered Maine Guides. In either case, their love for and familiarity with the habitat and best practices will help to protect the watershed and inform the decisions of others.
Marine Pathways at Deer Isle-Stonington High School
The Marine Studies Pathway at Deer Isle-Stonington High School is a learning experience designed to engage and inspire students, while equipping them with the practical skills they will need to succeed in every area of their adult lives. Students in the Marine Studies Pathway program will learn in the community, on the shore, and on the water, working alongside teachers, scientists, fishermen, and local marine professionals. They will acquire the knowledge, skills, and work ethic they will need to succeed in college and in challenging modern careers.
Outer Islands Teaching and Learning Collaborative
The Outer Islands TLC (Teaching and Learning Collaborative) is a group of island educators who are committed to creating a virtual classroom community where teachers and students will have access to a rich and supportive inter-island peer network. The mission of the TLC is to improve the quality and ensure the sustainability of one- and two-room island schools by creating collaborative educational and social opportunities for students across islands via technology and face-to-face learning opportunities. The Outer Islands TLC includes the island schools of Cliff, Cranberry Isles, Frenchboro, Isle au Haut, Matinicus and Monhegan. The project is a program of the Island Institute based in Rockland, Maine and has also received support from the Maine Seacoast Mission, the Maine Community Foundation, the Stephen and Tabitha King Foundation.
The Salmon in the Schools Program
The Salmon in the Schools program, organized by the US Fish and Wildlife Service, is a big part of the Downeast Salmon Federation’s educational programming. The program takes place throughout the winter months, and into May. Participating schools raise 200 endangered Atlantic salmon eggs in the classroom, giving them the opportunity to care for an endangered species and see the young salmon transition from the egg lifestage in the winter, to young fry in the spring when they stock them into the river. Throughout this time, DSF staff work with local school groups in the classroom, at our hatchery facilities, and in the field. This gives the young students several opportunities to interact with fisheries professionals, and gives them an experience to remember and inspire continued education in the natural sciences.
Summer Field Institute
Summer Field Institute, taught by College of the Atlantic faculty, is a field-based immersion program in human ecology for high-school students and is eligible for college credit. In 2015 the course offered was Islands Thru Time for 16 students who spent a portion of their study out at COA’s Blair Research Station on Mount Desert Rock and the Eno Research Station on Great Duck Island, home to some of the largest known breeding populations of marine birds. Students are immerse in ecology, culture, and history of downeast Maine, learning from an interdisciplinary perspective. You will study and explore oceanography, marine biology, field ecology, history, literature, writing, music, and media studies.
Sustainable Ocean Studies
Sponsored jointly by Waynflete School and Chewonki Semester School, Sustainable Ocean Studies is a field-based, adventure filled, community-oriented experience open to students entering 10th, 11th, or 12th grade. Sustainable Ocean Studies blends hands-on learning with adventure as participants do important work on pressing issues related to ocean sustainability. Using the Gulf of Maine as a classroom and a laboratory, participants explore the Gulf and delve deeply into its rich ecology, economics, politics, and culture. SOS provides a fun, empowering, and relevant learning experience that cultivates important skills for academic success in post-secondary studies. This program challenges participants to make full use of both their creative problem-solving and critical thinking skills while studying ecological and cultural sustainability. SOS pays special attention to learning from local efforts in coastal Maine communities to preserve the marine resources on which those communities depend.
STEM
Maine Mathematics and Science Alliance (MMSA) is creating a new partnership with Axi-om Education and Training Center. The “STEM Guides Downeast” project will create partnership network in Downeast Maine that connects teachers, mentors, students (age 10 – 18) and their parents, so kids can participate in STEM activities, resources and pathways on a recreational basis. STEM Guides strives to increase visibility and opportunity for STEM related aspirations and jobs to kids growing up in Downeast Maine regardless of college level education goals.
University of Maine at Machias
The University of Maine at Machias offers a Marine Biology program of study. UMM’s location is ideal for courses related to marine biology, ecology, and mariculture. Students have direct access to inter-tidal and sub-tidal marine habitats and organisms, finfish and shellfish aquaculture sites and hatcheries, and commercial fishing ports. This access to marine environments gives UMM students unique field and laboratory experiences. UMM also offers a biology degree which can include a fisheries concentration as well as partner with both the Downeast Institute and the Downeast Salmon Federation so students can get hands on experience at active facilities.
Downeast Fisheries Partnership is a collaborative effort with a vision of re-establishing fisheries as a means of sustaining coastal communities for many future generations: the communities of eastern Maine will sustain themselves forever by fishing.
www.downeastfisheries.org
|
User Guide
W300D Wireless-N ADSL2+ Modem Router
Copyright Statement
Tenda® is the registered trademark of Shenzhen Tenda Technology Co., Ltd. All the products and product names mentioned herein are the trademarks or registered trademarks of their respective holders. Copyright of the whole product as integration, including its accessories and software, belongs to Shenzhen Tenda Technology Co., Ltd. Without the permission of Shenzhen Tenda Technology Co., Ltd, any individual or party is not allowed to copy, plagiarize, imitate or translate it into other languages. All the photos and product specifications mentioned in this manual are for references only. As the upgrade of software and hardware, there will be changes. And if there are changes, Tenda is not responsible for informing in advance. If you want to know more about our product information, please visit our website at www.tenda.cn.
# Content
Chapter 1: Product Overview ........................................... 1
1.1 Product Introduction ........................................... 1
1.2 Product Features ............................................... 2
1.3 Package Contents .............................................. 4
Chapter 2: Getting to Know the Router ............................... 5
2.1 Rear Panel and Port Description ............................. 5
2.2 Front Panel and LED Description ............................ 6
2.3 Hardware Installation ......................................... 7
Chapter 3: Getting to Connect the Broadband Router ............... 10
3.1 How to Set the Network Configurations for My Computer .... 10
3.2 How to Check the Network Connection ....................... 14
3.3 How to Access the Web-based Configuration Utility ......... 15
Chapter 4: DSL Setting .................................................. 17
4.1 DSL Setting ..................................................... 17
Chapter 5: Advanced Setting .......................................... 29
5.1 LAN Setting ..................................................... 29
5.2 MAC Address Clone ............................................. 30
5.3 DNS Settings ................................................... 32
Chapter 6: Wireless Settings ......................................... 33
6.1 Basic Setting ................................................... 33
6.2 Wireless Security Settings ................................... 36
6.2.1 Mixed WEP .................................................. 36
6.2.2 WPA- Personal ............................................. 38
6.2.3 WPA2-Personal .................................................. 39
6.2.4 WPA-Enterprise ................................................. 40
6.2.5 WPA2-Enterprise ............................................... 41
6.2.6 802.1X Authentication .......................................... 42
6.3 WPS Setting .......................................................... 44
6.4 WDS Setting .......................................................... 46
6.5 Advanced Wireless Setting ....................................... 48
6.6 Wireless Access Control .......................................... 50
6.7 Wireless Connection Status ..................................... 51
Chapter 7: DHCP Server .............................................. 52
7.1 DHCP Server Setting ........................................... 52
7.2 DHCP Client List .............................................. 53
Chapter 8: Virtual Server ............................................ 54
8.1 Single Port Forwarding ....................................... 54
8.2 Port Range Forwarding ....................................... 57
8.3 Port Trigger Setting .......................................... 59
8.4 ALG Service Setting .......................................... 59
8.5 DMZ Host ....................................................... 63
8.6 UPnP Setting ................................................... 64
Chapter 9: Traffic Control ........................................... 65
Chapter 10: Security Setting ........................................ 67
10.1 Client Filter Settings ....................................... 67
10.2 URL Filter .................................................... 69
10.3 MAC Address Filter .......................................... 71
10.4 Prevent Network Attack ..................................... 73
10.5 Remote Web Management ..................................... 74
10.6 Local Web Management ....................................... 76
10.7 WAN Ping ..................................................... 78
Chapter 11: Routing Setting ......................................... 79
11.1 Routing Table ................................................ 79
11.2 Static Routing .................................................. 80
Chapter 12: System Tools ........................................... 82
12.1 Time Setting .................................................... 82
12.2 DDNS ............................................................. 84
12.3 Backup/Restore Setting ...................................... 85
12.4 Firmware Upgrade ............................................. 87
12.5 Restore to Factory Default Settings ....................... 89
12.6 Reboot .......................................................... 90
12.7 Password Change .............................................. 91
12.8 System Log ..................................................... 92
Appendix I: Glossary ................................................ 93
Chapter 1: Product Overview
1.1 Product Introduction
W300D ADSL2+ 300M Wireless Broadband Router provides up to 24Mbps downstream rate and 1Mbps upstream rate, which integrates ADSL2+ Modem, wireless router, four-port LAN switch and firewall in one. W300D utilizes advanced MIMO technology and increases over 8 times of transmission range of ordinary 802.11g products. Compatible with IEEE802.11n (Draft 2.0) and IEEE802.11g/b standards, it can provide up to 300Mbps stable transmission rate.
It supports WDS (Wireless Distribution System) function for repeating and amplifying the signals to extend the wireless network coverage. Besides, it can disable SSID broadcast manually. WPS (PBC and PIN) encryption method, port filtering and MAC address filtering can protect your network from malicious attack. W300D can be managed through local/remote Web management interface anywhere.
Moreover, the WMM function can make your voice and video smoother. Powerful and exquisite, it is the best choice for SOHOs and small-sized enterprises to share the wireless network.
1.2 Product Features
- Integrates ADSL2+ Modem, wireless router, four-port LAN switch and firewall
- Complies with IEEE802.11n (Draft 2.0), IEEE802.11b and IEEE802.11g standards
- MIMO technology utilizes reflection signals to increase 8 times transmission distance of original 802.11g standard and reduces the "dead spots" in the wireless coverage area
- Provides 300Mbps receiving rate and 300Mbps sending rate
- Supports WMM to make your voice and video more smooth
- Supports 64/128-bit WEP, WPA, WPA2 encryption methods and 802.1x security authentication standard
- Supports ATM Forum UNI 3.0, 3.1 and 4.0 Permanent Virtual Circuits standard
Setup Wizard support for fast and easy configurations
WPS (PBC and PIN) encryption method to free you from remembering long passwords
Supports remote/local Web management
Supports wireless Roaming technology to ensure high-efficient wireless connections
Supports wireless SSID stealth mode and MAC address access control
Supports Auto MDI/MDIX
Provides system log to record the status of the router
Supports MAC address filtering, IP address filtering, URL filtering and NAT rules
Supports UPnP and DDNS
Supports access control over 30 MAC address entries
Supports DHCP server/client
Supports SNTP
Supports virtual server and DMZ host
Supports bandwidth control based on IP address range
Built-in firewall to prevent hacker attack
Supports auto wireless channel selection
Supports WDS function (Wireless Distribution System)
1.3 Package Contents
- One W300D Wireless-N ADSL2+ Modem Router
- One CD-ROM (User Guide, Setup Wizard, etc.)
- One Quick Installation Guide
- Two RJ11 Telephone Lines
- One RJ45 Ethernet Cable
- One Power Adapter
- One Voice Splitter
If any of listed items are missing or damaged, please contact the Tenda reseller from whom you purchased for replacement immediately.
Chapter 2: Getting to Know the Router
2.1 Rear Panel and Port Description
Rear Panel View:
Rear Panel Description:
| Rear Panel Interface | Description |
|----------------------|-------------|
| LAN(1-4) | Connect with your computer’s NIC or uplink to hub or switch. |
| Button | Description |
|-----------------|-----------------------------------------------------------------------------|
| RESET/WPS | Note: press this button for 7 seconds, the settings you configured will be deleted and restored to factory default setting. If press for 1 second, the WPS (PBC) is enabled. |
| DSL | Connect with DSL telephone line. |
| POWER | For AC12/1.0A connection |
### 2.2 Front Panel and LED Description
Some LED indicators on the front panel of W300D are located here, shown as below:
| LED Indicator | State | Description |
|---------------|---------|-----------------------------------------------------------------------------|
| POWER | Always ON | Indicates it is powered on well. |
| SYS | Blinking | Indicates the system works on well. |
| DSL | Always ON | Indicates it is connected with DSL termination well. |
| | Blinking | Indicates it is going on connection negotiation |
| WLAN | Always ON | Indicates the wireless module works well. |
| | Blinking | Indicates it is transmitting and/or receiving data. |
| LAN(1/2/3/4) | Always ON | Indicates it is connected well. |
| | Blinking | Indicates the router’s LAN port is transmitting and/or receiving data. |
| WPS | Blinking | Indicates the Router is negotiating with WPS clients in WPS Mode. |
### 2.3 Hardware Installation
Before the Router’s setting, please follow the next steps to connect with. For better wireless performance, please locate the Router in the center
of wireless coverage.
1. Connect to the Router’s DSL port with telephone line.
2. Use the delivery-attached power adapter to power the Router.
3. Connect the LAN port of the Router to the network adapter of your computer with one cable.
IMPORTANT:
Please use the included power adapter. Use of a different power adapter could cause damage and void the warranty for this product.
Chapter 3: Getting to Connect the Broadband Router
For easy and fast configuration, the following steps for network configuration are required.
3.1 How to Set the Network Configurations for My Computer
1. Right click “My Network Places” and select “Properties”.
2. Right click “Local Area Network Connection” and select “Properties”.
3. Select “Internet Protocol (TCP/IP)” and click “Properties”.
4. Select “Obtain an IP address automatically” and “Obtain DNS server address automatically”. Click “OK” to save the configurations.
Or select “Use the following IP address” and enter the IP address, Subnet mask, Default gateway as shown below. Of course, you need to input the DNS server address provided by your ISP. Otherwise, you can use the Router’s default gateway as the DNS proxy server. Click “OK” to save the configurations.
You can get IP settings assigned automatically if your network supports this capability. Otherwise, you need to ask your network administrator for the appropriate IP settings.
- Obtain an IP address automatically
- Use the following IP address:
- IP address: 192.168.0.2
- Subnet mask: 255.255.255.0
- Default gateway: 192.168.0.1
- Obtain DNS server address automatically
- Use the following DNS server addresses:
- Preferred DNS server: 192.168.0.1
- Alternate DNS server:
Advanced...
3.2 How to Check the Network Connection
1. Select Start—"Programs"—“Accessories”—“Command Prompt”.
2. Input the “ping 192.168.0.1” and press “Enter”. If the screen displays as the below figure, it means your PC is connected to your router successfully. If not, please make sure the hardware installation and network adapter are OK.
3.3 How to Access the Web-based Configuration Utility
1. To access the Router’s Web-based Utility, launch a web browser such as Internet Explorer or Firefox and enter the Router’s default IP address, http://192.168.0.1. Press “Enter”.
2. Input the “admin” in both User Name and Password. Click “OK”.
3. If you enter the correct user name and password, the following page appears.
Chapter 4: DSL Setting
This section deals with how to configure the Router’s basic setting via Web interface.
4.1 DSL Setting
This guide can assist you to configure the Router’s connection mode and basic parameters fast. The Router supports five common connection modes (Bridging, MER, IPoA, PPPoE, PPoA). Select one according your actual requirements.
DSL Settings
Internet Connection TYPE
Encapsulation: PPPoE
VC Settings
Encapsulation Mode: LLC
Virtual Circuit: 8 VPI (Range 0~255)
36 VCI (Range 32~65535)
DSL Modulation:
G.Dm G.lite TL.413 ADSL2
AnnexL ADSL2+ AnnexM
PPPoE Settings
Username:
Password:
Optional Settings
MTU: 1492 (256~1500, Do NOT Modify Unless Necessary)
Service Name: (Do NOT Modify Unless Necessary)
AC Name: (Do NOT Modify Unless Necessary)
Connect Automatically
Connect Manually
Connect on Demand
Max Idle Time [60] (60~3600)
Connect on Fixed Time
IMPORTANT: Please set the time in system Tools, before you select this Internet connection.
Time From [0] [0] to [0] [0]
Time format, Hours 0~23, Minute 0~59
Apply Cancel
After the setting is completed, please click “Apply”. The device will reboot and the settings will go into effect.
The device’s status will be refreshed in the following page:
Network Status:
Connection State:
To check if it is connected well with ISP
Connection Mode:
Show the connection mode for Internet access.
WAN IP, Subnet Mask, Gateway, Primary DNS Server, Secondary DNS Server:
After the Router connects well with ISP, the TCP/IP parameters are obtained. Or you can specify by manual.
Connection Time:
The communication time for the Router and ISP
DSL State:
Connection State:
Show If the DSL is connected well.
Virtual Circuit:
Show the VPI/VCI value.
Upstream Rate:
The upstream rate resulted from the negotiation between DSL and ISP.
Downstream Rate:
The downstream rate resulted from the negotiation between DSL and ISP.
Server State:
IP Address:
The IP address for the Router’s Web interface login.
DHCP Server、NAT、Firewall:
Enable or disable.
System Status:
System Time:
The running time of the Router.
System Date:
The system date of the Router.
Client: The client number connected with the device
→Connection Mode 1: Bridging
If you want to configure the device’s connection mode as Bridging, please select “Bridging” in the Encapsulation field under Internet Connection Mode.
Region selection: Country, City, Provider. If the city or ISP is not listed in the drop-down menu, you can enter the VPI and VCI value. “Encapsulation Mode”, “DSL Modulation” are suggested to select the default value. If there is something wrong, you can inquire your local ISP.
→Connection Mode 2: MER
If your ISP provides your connection way as Dynamic IP (it means you obtain different IP address each time to access the Internet), select “MER” in “Encapsulation” field and “Auto obtain IP address” in “WAN IP setting”.
Region selection: Country, City, Provider. If the city or ISP is not listed in the drop-down menu, you can enter the VPI and VCI value. “Encapsulation Mode”, “DSL Modulation” are suggested to select the default value. If there is something wrong, you can inquire your local ISP.
If your ISP provides your connection way as Dynamic
IP (it means you obtain different IP address each time to access the Internet), select “MER” in “Encapsulation” field and “Use the following IP address” in “WAN IP setting”. You need input the “IP address”, “Subnet Mask”, “Default Gateway”, “DNS Server”, “Secondary DNS Server” into the corresponding fields.
**Other Settings:**
**MTU:**
Maximum Transmission Unit. The default value is 1500. Don’t modify the default value unless necessary.
Connection Mode 3: IPoA
If your ISP provides your connection way as IPoA, select “IPoA” in “Encapsulation” field. You need input the “IP address”, “Subnet Mask”, “Default Gateway”, “DNS Server”, and “Secondary DNS Server” into the corresponding fields.
DSL Settings
Internet Connection TYPE
Encapsulation: IPoA
VC Settings
Encapsulation Mode: LLC
Virtual Circuit: 8 VPI (Range 0~255)
35 VCI (Range 32~65535)
DSL Modulation: G.Dm G.lite TL.413 ADSL2
AnnexL ADSL2+ AnnexM
WAN IP Settings
Internet IP Address:
Subnet Mask:
Default Gateway:
Primary DNS:
Secondary DNS: (optional)
Optional Settings
MTU: 1500 (256~1500, Do NOT Modify Unless Necessary)
Region selection: Country, City, Provider. If the city or ISP is not listed in the drop-down menu, you can enter the VPI and VCI value. “Encapsulation Mode”, “DSL Modulation” are suggested to select the default value. If there is something wrong, you can inquire your local ISP.
Other Settings:
MTU:
Maximum Transmission Unit. The default value is 1500. Don’t modify the default value unless necessary.
Connection Mode 4: PPPoE
If your ISP provides your connection way as PPPoE, select “PPPoE” in “Encapsulation” field. You need input your user name and password provided by ISP or network administrator in “PPPoE Setting” corresponding fields.
DSL Settings
Country --Country-- City --City-- Provider --Provider--
Internet Connection TYPE
Encapsulation: PPPoE
VC Settings
Encapsulation Mode: LLC VC
Virtual Circuit: VPI (Range 0-255)
35 VCI (Range 32-65535)
DSL Modulation: G.Dm G.lite TL.413 ADSL2
AnnexL ADSL2+ AnnexM
PPPoE Settings
Username:
Password:
Optional Settings
MTU: 1492 (256-1500, Do NOT Modify Unless Necessary)
Service Name: (Do NOT Modify Unless Necessary)
AC Name: (Do NOT Modify Unless Necessary)
Connect Automatically
Connect Manually
Connect on Demand
Max Idle Time 60 (60-3600)
Connect on Fixed Time
IMPORTANT: Please set the time in system Tools, before you select this Internet connection.
Time From 0 0 to 0 0
Time format, Hours 0-23; Minute 0-59
Apply Cancel
Region selection: Country, City, Provider. If the city or ISP is not listed in the drop-down menu, you can enter the VPI and VCI value. “Encapsulation Mode”, “DSL Modulation” are suggested to select the default value. If there is something wrong, you can inquire your local ISP.
Other Settings:
MTU: Maximum Transmission Unit. The default value is 1492. Don’t modify the default value unless necessary.
Service Name:
The current PPPoE connection name. Don’t modify the default value unless necessary.
Server Name:
The Server’s name. Don’t modify the default value unless necessary.
Connect Automatically:
When the device is powered on or disconnected, it connects automatically.
Connect by manual:
When it is disconnected, connect again by manual.
Connect on Demand:
When the data access the device, connect automatically.
Connect on Fixed Time:
Connect to the Internet on fixed time.
Note:
Only you have set the current time in Time Setting, then “Connect on Fixed Time” can be used.
→Connection Mode 5: PPPoA
If your ISP provides your connection way as PPPoA, select “PPPoA” in “Encapsulation” field. You need input your user name and password provided by ISP or network administrator in “PPPoA Setting” corresponding fields.
Dial-up Timeout:
During a fixed time, if the auto dial-up fails, the dial-up will stop.
Ideal Timeout:
If there is no communication in the fixed time, the link will be disconnected.
Region selection:
Country, City, Provider. If the city or ISP is not listed in the drop-down menu, you can enter the VPI and VCI value.
“Encapsulation Mode”, “DSL Modulation” are suggested to select the default value. If there is something wrong, you can inquire your local ISP.
Other Settings:
MTU: Maximum Transmission Unit. The default value is 1500. Don’t modify the default value unless necessary.
Note:
It is recommended using the Setup Wizard to configure the five connection modes: Bridging, MER, IPoA, PPPoE and PPPoA.
Chapter 5: Advanced Setting
This section will guide you to configure the Router’s advanced settings, including LAN setting, MAC address clone and DNS setting.
5.1 LAN Setting
This page focuses on how to configure LAN Setting.
MAC Address:
The Router’s physical MAC address as seen on your local network, which is unchangeable.
IP Address:
The Router’s LAN IP address (not your PC’s IP address). Once you modify the IP address, you need to remember it for the Web-based Utility login next time. 192.168.0.1 is the default value.
Note:
If you have changed the IP address, you need to use the new IP address to log in to the Router’s Web interface next time, and the default gateway of all computers in the LAN must be via this IP address to access the Internet.
Subnet Mask:
The Router’s subnet mask for measurement of the network size. 255.255.255.0 is the default value.
5.2 MAC Address Clone
Some ISPs require end-user's MAC address to access their network. This feature copies the MAC address of your network device to the Router. Input the MAC address to be registered in the field, click “Apply” to implement this feature.
MAC Address Clone
WAN MAC Address Clone.
MAC Address: 00:10:18:01:01:6F
Restore Default MAC Clone MAC Address
Apply Cancel
**MAC Address:**
The MAC address to be registered with your Internet service provider.
**Clone MAC Address:**
Register your PC's MAC address.
**Restore Default MAC Address:**
Restore the default hardware MAC address.
5.3 DNS Settings
DNS is short for Domain Name System (or Service), an Internet service that translates domain names into IP addresses which are provided by your Internet Service Provider. Please consult your Internet Service Provider for details if you do not have them.
**DNS Setting:**
Click the checkbox to enable the DNS server. The Router’s DHCP server then will assign the DNS for client’s request.
**Primary DNS Address:**
Enter the necessary address provided by your ISP.
**Secondary DNS Address:**
Enter the second address if your ISP provides, which is optional.
**For example:**
Your ISP provides the following address:
- **Primary DNS Address:** 188.8.131.52
- **Secondary DNS Address:** 184.108.40.206
Chapter 6: Wireless Settings
This section mainly deals with the wireless settings, including Basic Settings, Security Setting, Access Control and Advanced Settings.
6.1 Basic Setting
Network Mode:
Select one mode from the following:
802.11b/g mixed, 802.11b, 802.11g and 802.11b/g/n mixed.
Main SSID:
SSID (Service Set Identifier) is the unique
name of the wireless network. This device has two SSIDs and the main SSID is necessary.
**Minor SSID:**
Minor Service Set Identifier. It is optional.
**Broadcast (SSID):**
Select “enable” to enable the device’s SSID to be visible by wireless clients.
**AP Isolation:**
When this feature is enabled, each of your wireless clients will be in its own virtual network and will not be able to communicate with each other. This feature is deployed when you have many guests that frequent your wireless network. For example, configure main SSID as AP1, minor SSID as AP2. PC1 connects to AP1 via wireless adapter; PC2 connecting to AP2. After the feature is enabled, two PCs can not communicate and share network resource each other. (It is essential to enable two SSID before the feature is enabled.) The default AP isolation is disabled.
MBSSID AP Isolation:
When it is enabled, the wireless clients connected with AP can not access each other to isolate completely access control in WLAN.
BSSID:
Business Service Set Identifier of wireless network. In IEEE802.11, BSSID is the MAC address of wireless access point.
Channel:
Specify the effective channel (from 1 to 14) of the wireless network.
Extension Channel:
To increase data throughput of wireless network, the extension channel range is used in 11n mode.
Channel Bandwidth:
Select channel bandwidth to improve wireless performance. If the wireless network has 11b/g or 11n-compliance, select bandwidth as 40M; if there is no 11n-compliant client, select 20M.
6.2 Wireless Security Settings
This page is used to configure the device’s network security setting. Here presents the common six encryption methods, including Mixed WEP, WPA-personal, WPA-enterprise, WPA2-personal, WPA2-enterprise, etc. It is recommended to use WPA2-personal encryption method.
6.2.1 Mixed WEP
WEP (Wired Equivalent Privacy), a basic encryption method, usually encrypts wireless data using a series of digital keys (64 bits or 128 bits in length). By using the same keys on each of your wireless network devices, you can prevent unauthorized wireless devices from monitoring your transmissions or using your wireless resources. WEP is based on RSA algorithm from RC4. It is the original and weak encryption method, so it is recommended not to use this method. Select Mixed WEP to enter the following window:
SSID Choice:
Select the SSID (main SSID or minor SSID) to configure security setting from the drop-down menu.
Security Mode:
From the drop-down menu select the corresponding security encryption modes.
WEP Key:
Set the WEP key with the format of ASCII and Hex.
Key Description:
Enter ASCII code (5 or 13 ASCII characters. Illegal character as “/” is not allowed.) or 10/26 hex characters.
Default Key:
Select one key from the four configured keys as the current available one.
6.2.2 WPA- Personal
WPA (Wi-Fi Protected Access), a Wi-Fi standard, is a more recent wireless encryption scheme, designed to improve the security features of WEP. Select “WPA-personal” from the drop-down menu to enter the following window:
**Security Settings**
| SSID Choice | Tenda |
|-------------|-------|
| Security Mode -- "Tenda" | |
| Security Mode | WPA - Personal |
| WPA Algorithms | TKIP |
| Pass Phrase | AECSF32F |
| Key Renewal Interval | 3600 second |
**WPA Algorithms:**
Select one encryption type, AES or TKIP. (AES is stronger than TKIP.)
**Pass Phrase:**
Enter the key which must have 8-63 ASCII characters.
**Key Renewal Interval:**
Enter the key renewal period. It is to tell the Router how often to change the keys.
6.2.3 WPA2-Personal
WPA2 (Wi-Fi Protected Access version 2), It’s more secure than Wired Equivalent Privacy (WEP) and easy to set up.
**Security Settings**
- **SSID Choice**: Tenda
- **Security Mode**: WPA2 - Personal
- **WPA Algorithms**: TKIP
- **Pass Phrase**: AECSF32F
- **Key Renewal Interval**: 3600 second
**WPA Algorithms:**
Select key Algorithms such as TKIP, AES and TKIP&AES.
**Pass Phrase:**
Enter the key which must have 8-63 ASCII characters.
**Key Renewal Interval:**
Enter the key renewal period. It is to tell the Router how often to change the keys.
6.2.4 WPA-Enterprise
This security mode is used when a RADIUS server is connected to the device. Select “WPA-enterprise” from the drop-down menu to enter the following window:
**Radius IP Address:**
Enter the IP address of the Radius server.
**Radius Port:**
Enter the authentication port of the Radius server. The default is 1812.
**Shared Key:**
Enter the shared key for authentication server with 8~63 ASCII characters.
**Session Timeout:**
The authentication interval period between AP and authentication server. The default is
6.2.5 WPA2-Enterprise
This security mode is also used when a RADIUS server is connected to the Router.
**Radius IP Address:**
Enter the IP address of the Radius server.
**Radius Port:**
Enter the authentication port of the Radius server. The default is 1812.
**Shared Key:**
Enter the shared key for authentication server with 8~63 ASCII characters.
**Session Timeout:**
The authentication interval period between AP and authentication server. The default is 3600s.
6.2.6 802.1X Authentication
This security mode is used when a RADIUS server is connected to the device. 802.1x, a kind of Port-based authentication protocol, is an authentication type and strategy for users. The port can be either a physical port or logic port (such as VLAN). For wireless LAN users, a port is just a channel. The final purpose of 802.11x authentication is to check if the port can be used. If the port is authenticated successfully, you can open this port which allows all the messages to pass. If the port isn’t authenticated successfully, you can keep this port “disable” which just allows 802.1x authentication protocol message to pass. Select “802.1x” from the drop-down menu to enter the following window:
WEP:
Click “Enable/Disable” to enable or disable the WEP algorithm.
Radius IP Address:
Enter the IP address of the Radius server.
Radius Port:
Enter the authentication port of the Radius server. The default is 1812.
Shared Key:
Enter the shared key for authentication server with 8~63 ASCII characters.
Session Timeout:
The authentication interval period between AP and authentication server. The default is 3600s.
⚠️ NOTE:
To improve security level, do not use those words which can be found in a dictionary or too easy to remember! Wireless clients will remember the WEP key, so you only have to input the WEP key on wireless client once, and it is worth to use complicated WEP key to improve security level.
6.3 WPS Setting
WPS (Wi-Fi Protected Setting) can be easy and quick to establish the connection between the wireless network clients and the Router through encrypted contents. The users only enter the PIN code to configure without selecting encryption method and entering secret keys by manual.
**WPS Config**
You could setup security easily by choosing PIN or PBC method to do Wi-Fi Protected Setup.
- **WPS Settings:** Disable, Enable
- **WPS mode:** PBC, PIN
**WPS Summary**
| WPS Current Status: | Not used |
|---------------------|----------|
| WPS Configured: | No |
| WPS SSID: | Tenda |
| WPS Auth Mode: | WPA2-PSK |
| WPS Encrypt Type: | AES |
| WPS Default Key Index: | 2 |
| WPS Key(ASCII): | PlsChangeMe |
| AP PIN: | 658263 |
**WPS Setting:**
To enable or disable WPS function. The default is to disable.
**WPS Mode:**
Supports two ways to configure WPS
settings: PBC (Push-Button Configuration) and PIN code
**PBC:**
Select the PBC or press the WPS button on the front panel of the device for one second (Press the button for one second and WPS indicator will be blinking for 2 minutes, which means the WPS is enabled. During the blinking time, you can enable another device to implement the WPS/PBC negotiation between them. At present, the WPS only supports up to 32 clients access. Two minutes later, the WPS indicator will be off. If more clients are added, repeat the above steps).
**PIN:**
If this option is enabled, you need to enter a wireless client’s PIN code in the field and keep the same code in the client.
**WPS Summary:**
Show Wi-Fi current protection state, authentication mode, encryption method, etc.
⚠️ **Note:**
Press the WPS/Reset button for 1 second on the front panel to run PBC. Press for 7 seconds, the device’s setting will restore to default setting. The access client has to support WPS.
6.4 WDS Setting
WDS (Wireless Distribution System) can be used to expand your current wireless network coverage. The Router supports three modes: Lazy, Bridge and Repeater.
**Lazy:**
In this mode, the connected wireless device should be in Bridge or Repeater mode, and select the Router’s BSSID to implement wireless connection.
**Bridge:**
In this mode, you can connect two or more wired networks via wireless signals. In this mode, you need add the Wireless MAC address of the connecting device into the
Router's AP MAC address table or select one from the scanning table.
**Repeater:**
In this mode, you need add the MAC address of the connecting device into the Router's AP MAC address table to amplify and repeat wireless signals.
**Encrypt Type:**
You can select WEP mode, TKIP mode, AES mode for security here.
**Key:**
Enter the encryption key for the connecting devices.
**AP MAC Address:**
Input the MAC address of the connected wireless device.
⚠️ **NOTE:**
Two wireless routers must use the same band, channel number, and security settings!
6.5 Advanced Wireless Setting
This section is to configure the advanced wireless setting of the Router, including the Radio Preamble, 802.11g/n Rate, Fragmentation Threshold, RTS Threshold, Beacon Period and DTIM Interval.
**BG Protection Mode:**
For 11b/g wireless client, it is easier to connect with 11n wireless device. The default is “Auto”.
**Basic Data Rates:**
In terms of different requirements, you can select one of the suitable Basic Data Rates from the drop-down menu. Here, default
value is (1-2-5.5-11Mbps...).
**Beacon Interval:**
The frequency interval of the beacon, which is a packet broadcast by a router to synchronize a wireless network. The default value is 100 ms. It is recommended not to modify the default value.
**Fragment Threshold:**
The fragmentation threshold defines the maximum transmission packet size in bytes. The packet will be fragmented if the arrival is bigger than the threshold setting. The default size is 2346 bytes.
**RTS Threshold:**
RTS stands for “Request to Send”. This parameter controls what size data packet the frequency protocol issues to RTS packet. If the device works in SoHo, do not modify the default value.
**TX Power:**
Set the wireless output power level. The default value is 100.
**WMM Capable:**
To enhance wireless multimedia transfer performance (On-line video and voice). If you are not clear about this, enable it.
**APSD Capable:**
It is used for auto power-saved service. The default is disabled.
6.6 Wireless Access Control
To secure your wireless LAN, the wireless access control is actually based on the MAC address management. Select “Wireless Setting-Access Control” to popup the following window:
**MAC Address Filter:**
Enable/disable MAC address filter. Select “Off” to malfunction MAC address; “Block” to prevent the MAC addresses in the list from accessing the wireless network; “Allow” to allow the MAC address in the list to access the wireless network.
**MAC Address Management:**
Input the MAC address to implement the filter policy. Click “Add” to finish the MAC adding operation.
**MAC Address List:**
Show the added MAC address. You can add or delete them.
6.7 Wireless Connection Status
This page is to show the current wireless access status. Click “Refresh” to update the wireless connection information.
| NO. | MAC Address | Bandwidth |
|-----|-----------------|-----------|
| 0 | 00:0C:43:31:31:78 | 20M |
**MAC Address:**
Shows the connecting PC’s MAC address.
**Bandwidth:**
Shows the channel bandwidth of the host to be connected.
Chapter 7: DHCP Server
7.1 DHCP Server Setting
DHCP (Dynamic Host Control Protocol) is to assign an IP address to the computers on the LAN/private network. When you enable the DHCP Server, the DHCP Server will allocate automatically an unused IP address from the IP address pool to the requesting computer in premise of activating “Obtain an IP Address Automatically”. So specifying the starting and ending address of the IP Address pool is needed.
**DHCP Server:**
Activate the checkbox to enable server.
**IP Address Start/End:**
Enter the range of IP address for DHCP server assignment.
**Lease Time:**
The time length of the IP address lease.
For example: set the lease time as one hour. Then the DHCP server will recycle and assign the IP address again.
7.2 DHCP Client List
The Static IP assignment is to add one specific static IP address to the assigned MAC address. You can view the related information in the DHCP server list.
**IP Address:**
Enter one IP address for the computer on the LAN network.
**MAC Address:**
Enter the MAC address of the computer you want to assign the above IP address. Click “Add” to add the entry in the list.
**Hostname:**
The name of the computer which is added a new IP address.
**Lease Time:**
The time length of the corresponding IP address lease.
Chapter 8: Virtual Server
8.1 Single Port Forwarding
The Router can be configured as a virtual server on behalf of local services behind the LAN port. The given remote requests will be re-directed to the local servers via the virtual server. This section deals with the single port forwarding mainly. The Single Port Forwarding allows you to set up kinds of public services such as web servers, ftp, e-mail and other specialized Internet applications on your network.
Single Port Forwarding
The Router can be configured as a virtual server on behalf of local services behind the LAN port. The given remote requests will be re-directed to the local servers via the virtual server. This section deals with the single port forwarding mainly. The Single Port Forwarding allows you to set up kinds of public services such as web servers, ftp, e-mail and other specialized Internet applications on your network.
Note: the virtual server uses known host-name or public IP address.
| NO | External-Internal Port | To IP Address | Protocol | Enable | Delete |
|----|------------------------|--------------|----------|--------|--------|
| 1 | 40 | 192.168.0.10 | Both | ✓ | |
| 2 | | | TCP | | |
| 3 | | | TCP | | |
| 4 | | | TCP | | |
| 5 | | | TCP | | |
| 6 | | | TCP | | |
| 7 | | | TCP | | |
| 8 | | | TCP | | |
| 9 | | | TCP | | |
| 10 | | | TCP | | |
Well-Known Service Port: FTP(21) Add ID: 1
Apply Cancel
External Port:
This is the external port number for server or Internet application, for example, port 21 for ftp service.
Internal Port:
This is the port number of LAN computer set by the Router. The Internet traffic from the external port will forward to the internal port. For example, you can set the internal port NO.66 to act as the external port NO.21 for ftp service.
IP Address:
Enter the IP address of the PC where you want to set the applications.
Protocol:
Select the protocol (TCP/UDP/Both) for the application.
Enable:
Only click this option to make this rule go into effect.
Delete: To delete this rule.
In Well-known Service Port, list the common ports, you can select one from them and add one ID number from the drop-down menu, click “Add” to add the port in the above table. If the port does not list in the Well-known service port drop-down menu, you
can add it by manual.
**Add:**
To add the well-know port to ID you selected.
If the host with IP address 192.168.0.10 in the LAN provides Web service via port 80, and you want to forward this service to port 40, configure it as the above setting.
⚠️ **NOTE:**
If you set the virtual server of the service port as 80, you must set the Web management port on Remote Web Management page to be any value except 80 such as 8080. Otherwise, there will be a conflict to disable the virtual server.
8.2 Port Range Forwarding
This section deals with the port range forwarding. The Port Range Forwarding allows you to set up a range of public services such as web servers, ftp, e-mail and other specialized Internet applications to an assigned IP address on your LAN.
Start/End Port:
Enter the start/end port number which ranges the External ports used to set the server or Internet applications.
IP Address:
Enter the IP address of the PC where you want to set the applications.
Protocol:
Select the protocol (TCP/UDP/Both) for the application.
Well-Known Service Port:
Select the well-known services as DNS, FTP from the drop-down menu to add to the configured one above.
Delete/Enable:
Click to check it for corresponding operation.
In Well-known Service Port, list the common ports, you can select one from them and add one ID number from the drop-down menu, click “Add” to add the port in the above table. If the port does not list in the Well-known service port drop-down menu, you can add it by manual.
Add: To add the well-know port to ID you selected. If the host with IP address 192.168.0.10 in the LAN provides Web service via port 80, and you want to forward this service to port 40, configure it as the above setting.
⚠️ NOTE:
If you set the virtual server of the service port as 80, you must set the Web management port on Remote Web Management page to be any value except 80 such as 8080. Otherwise, there will be a conflict to disable the virtual server.
8.3 Port Trigger Setting
When internal clients have access to external server in the Internet for some application, the clients request to connect with servers, and the server will also ask to connect with client. But in the default setting, router will refuse to accept any request from WAN, which will bring communication halt. The port triggering is used to define triggering rules. So when clients have access to the server, the device will open the port through which the server sends the request to client.
**IP Range:**
The internal IP address range for requesting external server application.
**Trigger Port:**
The port range through which the internal
clients send request traffics to external server with the range of 1 ~ 65535. Note that the low number first and two blanks can keep the same number if needed.
**External Port:**
The port range through which the external server sends request traffics to internal clients with the range of 1 ~ 65535. Note that the low number first and two blanks can keep the same number if needed.
**Apply:**
To enable or disable the rule.
**Add:**
After editing the rule, click the “add” button to add the current entry to the port triggering list.
**Apply:**
Click “Apply” to activate the current rule.
**Cancel:**
Click “Cancel” to drop all settings saved last time.
It is allowed to delete or modify the previous rules in the list table.
**Note:**
The special application can be only used in one PC. If there is more than one PC to open the same triggering port, the external port will be
connected to the last PC for the application.
8.4 ALG Service Setting
ALG (Application Layer Gateway) in the context of computer networking, an ALG or application layer gateway consists of a security component that augments a firewall or NAT employed in a computer network. It allows customized NAT traversal filters to be plugged into the gateway to support address and port translation for certain application layer "control/data" protocols such as FTP, Bit Torrent, SIP, RTSP, file transfer applications etc.
In order for these protocols to work through NAT or a firewall, either the application has to know about an address/port number combination that allows incoming packets, or the NAT has to monitor the control traffic and open up port mappings (firewall
pinhole) dynamically as required. Legitimate application data can thus be passed through the security checks of the firewall or NAT that would have otherwise restricted the traffic for not meeting its limited filter criteria.
Usually allowing client applications to use dynamic ephemeral TCP/UDP ports to communicate with the known ports used by the server applications, even though a firewall-configuration may allow only a limited number of known ports. In the absence of an ALG, either the ports would get blocked or the network administrator would need to explicitly open up a large number of ports in the firewall; rendering the network vulnerable to attacks on those ports.
In the default ALG settings, the following protocols have enabled. It is recommended to keep the settings unchanged.
1, FTP
2, TFTP
3, PPTP
4, IPSec
5, L2TP
8.5 DMZ Host
The DMZ function is to allow one computer in LAN to be exposed to the Internet for a special-purpose service as Internet gaming or videoconferencing.
**DMZ Settings**
IMPORTANT: When enabled the DMZ host, the firewall settings of the computer will not function.
| DMZ host IP | 192.168.0.10 |
|-------------|---------------|
| Enable | |
**DMZ Host IP Address:**
The IP address of the computer you want to expose.
**Enable:** Click the checkbox to enable the DMZ host.
**IMPORTANT:**
When enabled the DMZ host, the firewall settings of the DMZ host will not function.
8.6 UPnP Setting
It supports latest Universal Plug and Play. This function goes into effect on Windows XP or Windows ME or this function would go into effect if you have installed software that supports UPnP. With the UPnP function, host in LAN can request the router to process some special port switching so as to enable host outside to visit the resources in the internal host.
Enable UPnP: Click the checkbox to enable the UPnP.
Chapter 9: Traffic Control
Traffic control is used to limit communication speed in the LAN and WAN. Up to 20 entries can be supported with the capability for at most 254 PCs' speed control, including for IP address range configuration.
Enable Traffic Control:
To enable or disable the internal IP bandwidth control.
Interface:
To limit the uploading and downloading bandwidth in WAN port.
Service:
To select the controlled service type, such as HTTP service.
**IP Starting Address:**
The first IP address for traffic control.
**IP Ending Address:**
The last IP address for traffic control.
**Uploading/Downloading:**
To specify the traffic heading way for the selected IP addresses: uploading or downloading.
**Bandwidth:**
To specify the uploading/downloading Min./Max. traffic speed (KB/s), which can not exceed the WAN speed.
**Apply:**
To enable the current editing rule. If not, the rule will be disabled.
**Add:**
After edit the rule, click the “add to list” button to add the current rule to rule list.
**Save:**
Click “Save” to activate the current rule.
**Cancel:**
Click “Cancel” to drop all setting saved last time. It is allowed to delete or modify the
Chapter 10: Security Setting
10.1 Client Filter Settings
To benefit your further management to the computers in the LAN, you can control some ports access to Internet by data packet filter function.
Client Filter:
Client Filtering Settings
Access Policy: 10
Enable: ✓ Delete the Policy: Clear
Filtering Mode:
- Disable
- Enable
Policy Name: notag
Start IP: 192.168.0.10
End IP: 192.168.0.10
Port: 80
Type: TCP
Times: 8:00 ~ 18:00
Date: ✓ Everyday, Sun, Mon, Tue, Wed, Thu, Fri, Sat
Apply Cancel
Check to enable client filter.
**Access Policy:**
Select one number from the drop-down menu.
**Enable:**
Check to enable the access policy.
**Clear the Policy:**
Click “Clear” button to clear all settings for the policy.
**Filter Mode:**
Click one radio button to enable or disable to access the Internet.
**Policy Name:**
Enter a name for the access policy selected.
**IP Start/End:**
Enter the starting/ending IP address.
**Port No.:**
Enter the port range based over the protocol for access policy.
**Protocol:**
Select one protocol (TCP/UDP/Both) from the drop-down menu.
**Times:** Select the time range of client filter.
**Days:** Select the day(s) to run the access policy.
**For example:**
If you set the IP address 192.168.0.10 not
to access the Internet at 8:00-18:00 each day, please configure it as the above page.
10.2 URL Filter
In order to control the computer to have access to websites, you can use URL filtering to allow the computer to have access to certain websites at fixed time and forbids it having access to certain websites at fixed time.
URL Filter: Check to enable URL filter.
Access Policy:
Select one number from the drop-down menu.
Enable:
Check to enable the access policy.
Filter Mode:
Click one radio button to enable or disable to access the Internet.
Policy Name:
Enter a name for the access policy selected.
Start/End IP:
Enter the starting/ending IP address.
URL Strings:
Specify the text strings or keywords in the DNS. If any part of the URL contains these strings or words, the web page will not be accessible and display.
Times:
Select the time range of client filter.
Days:
Select the day(s) to run the access policy.
Apply:
Click to make the settings go into effect.
For example:
If you configure the host with IP address 192.168.0.11 not to access the website containing text strings like “Sex”, please set it as the above page.
10.3 MAC Address Filter
In order to manage the computers in LAN better, you could control the computer’s access to Internet by MAC Address Filter.
MAC Address Filter:
Check to enable MAC address filter.
Access Policy:
Select one number from the drop-down menu.
Enable:
Check to enable the access policy.
Filter Mode:
Click one radio button to enable or disable to access the Internet.
Policy Name:
Enter a name for the access policy selected.
MAC Address:
Enter the MAC address you want to run the access policy.
Times: Select the time range of client filter.
Days: Select the day(s) to run the access policy.
Apply: Click to make the settings go into effect.
For example:
If you want to configure the host with MAC address 00:C0:9F:AD:FF:C5 not to access the Internet at 8:00-18:00, you need to set it as above.
10.4 Prevent Network Attack
This section is to protect the internal network from exotic attack such as SYN Flooding attack, Smurf attack, LAND attack, etc. Once detecting the unknown attack, the Router will restrict its bandwidth automatically. The attacker’s IP address can be found from the “System Log”.
Prevent Network Attack:
Check to enable it for attack prevention.
10.5 Remote Web Management
This section is to allow the network administrator to manage the Router remotely. If you want to access the Router from outside the local network, please select the “Enable”.
**Enable:**
Check to enable remote web management.
**Port:**
The management port open to outside access. The default value is 80.
**WAN IP Address:**
Specify the range of the WAN IP address for remote management.
**Note:**
If you want to login the device’s Web-based interface via port 8080, you need use the format of WAN IP address: port
(for example http://220.127.116.11:8080) to implement remote login.
If your WAN IP address starts and ends with 0.0.0.0, it means all hosts in WAN can implement remote Web management. If you change the WAN IP address as 18.104.22.168-22.214.171.124, then only the IP addresses as 126.96.36.199, 188.8.131.52 and 184.108.40.206 can access the Router.
For example:
If you want to configure the IP address 220.127.116.11 to access the device’s web interface, please set it as above.
10.6 Local Web Management
Local web management, the alternative to remote web management, is to allow the network administrator to manage the Router in LAN. Any PC in the LAN can access the Web management utility by default. So you can enter the specific MAC address of the LAN computer to function.
**Local Web Management**
| Enable | ☑ |
|--------|---|
| The MAC Address Format (ab:cd:ef:12:34:11) |
| MAC1: 00:11:22:33:4E:5F | MAC2: [ ] |
| MAC3: [ ] | MAC4: [ ] |
| MAC5: [ ] | MAC6: [ ] |
**Enable:** Check to enable the local web management
**MAC1/2/3...:**
Enter the MAC addresses of LAN computers.
Note:
1. In the default state, this feature is not enabled. All computers in the LAN can login the Web.
2. For example, if you only allow the MAC address with 00:11:22:33:4E:5F to access the Web, please set it as above.
3. If you just check the frame to enable this feature and not to add any MAC address, all computers cannot access the Router’s interface via Web.
10.7 WAN Ping
The ping test is to check the status of your internet connection. When disabling the test, the system will ignore the ping test from WAN.
Ignore Ping from WAN:
Check to ignore the ping request and give no reply.
Chapter 11: Routing Setting
11.1 Routing Table
The main duty for a router is to look for a best path for every data frame, and transfer this data frame to a destination. So, it’s essential for the router to choose the best path, i.e. routing arithmetic. In order to finish this function, many transferring paths, i.e. routing table, are saved in the router, for choosing when needed.
| Routing Table |
|---------------|
| Destination IP | Subnet Mask | Gateway | Metric | Interface |
|----------------|-------------|---------|--------|-----------|
| 192.168.0.0 | 255.255.255.0 | 0.0.0.0 | 0 | b10 |
Refresh
11.2 Static Routing
This page is used to configure the Router’s static routing.
**Destination LAN IP:**
The address of the remote host with which you want to construct a static route.
**Subnet Mask:**
The network portion of the Destination LAN IP.
**Gateway:**
The gateway of the next hop, usually the Router or host’s IP address.
**Tip:** Static Route is set by system administrator in advance. Usually, It would not be subjected to network structure’s change.
Note:
1. The gateway must keep the same segment with the Router’s LAN IP address.
2. If the destination IP address is one host’s IP address, the Subnet mask should be 255.255.255.255.
3. If the destination IP address is an IP address range, the subnet mask should match the IP address. For example, if the IP is 10.0.0.0, subnet mask should be 255.0.0.0; if the IP is 10.1.2.0, subnet mask should be 255.255.255.0.
Chapter 12: System Tools
12.1 Time Setting
This section is to select the time zone for your location. If you turn off the Router, the settings for time disappear. However, the Router will automatically obtain the GMT time again once it has access to the Internet.
Time Zone:
Select your time zone from the drop-down menu.
Customized time:
Enter the time you customize.
Note:
When the Router is powered off, the time setting will be lost. Before the Router will obtain GMT time automatically, you need connect with the Internet and obtain the GMT time, or set the time on this page first. Then the time in other features (e.g. firewall) can be go into effect.
12.2 DDNS
The DDNS (Dynamic Domain Name System) is supported in this router. It is to assign a fixed host and domain name to a dynamic Internet IP address, which is used to monitor hosting website, FTP server and so on behind the Router. If you want to activate this function, please select “Enable” and a DDNS service provider to sign up.
**DDNS:**
Click the radio button to enable or disable the DDNS service.
**Service Provider:**
Select one from the drop-down menu and press “Sign up” for registration.
**User Name:**
Enter the user name the same as the registration name.
Password:
Enter the password you set.
Domain Name:
Enter the domain name which is optional.
12.3 Backup/Restore Setting
The device provides backup/restore settings, so you need to set a directory to keep these parameters.
Backup Setting
Click “Backup” button to back up the Router’s settings and select the path for save.
Restore Setting:
Click “Browse” button to select the backup files.
Click “Restore” button to restore previous settings.
12.4 Firmware Upgrade
The Router provides the firmware upgrade by clicking the “Upgrade” after browsing the firmware upgrade packet which you can download from www.tenda.cn. After the upgrade is completed, the Router will reboot automatically.
Through upgrading the Router’s software, you can gain more stable performance and value-added features. You can download the latest upgrade file and TFTP Server from the website www.tenda.cn. After the upgrade file is downloaded, put the de-condensed upgrade files and TFTP in same directory file.
When your computer connects with the Router’s LAN port, and obtain the IP address assigned by the Router, please run the TFTP Server, and keep the “Firmware File Name” same with the upgrade file name. Click “Upgrade” to start the firmware upgrading.
**IMPORTANT:**
Do not power off the system during the
firmware upgrade to avoid damaging the device. The Router will reboot after the upgrade.
12.5 Restore to Factory Default Settings
This button is to reset all settings to the default values. It means the Router will lose all the settings you have set. So please Note down the related settings if necessary.
**Restore:**
Click this button to restore to default settings.
**Factory Default Settings:**
- User Name: admin
- Password: admin
- IP Address: 192.168.0.1
- Subnet Mask: 255.255.255.0
⚠️ **NOTE:**
After restoring to default settings, please restart the device, then the default settings can go into effect.
12.6 Reboot
Rebooting the Router makes the settings configured go into effect or to set the Router again if setting failure happens.
**Reboot the router:**
Click this button to reboot the device.
12.7 Password Change
This section is to set a new user name and password to better secure your router and network.
User Name:
Enter a new user name for the device.
Old Password:
Enter the old password.
New Password:
Enter a new password.
Re-enter to Confirm:
Re-enter to confirm the new password.
⚠️NOTE:
It is highly recommended to change the password to secure your network and the Router.
12.8 System Log
The section is to view the system log. Click the “Refresh” to update the log. Click “Clear” to clear all shown information. If the log is over 150 records, it will clear them automatically.
| | Date | Type | Content |
|---|------------|------|------------------|
| 1 | 2007-03-29 | System | system start. |
**Refresh:**
Click this button to update the log.
**Clear:**
Click this button to clear the current shown log.
Appendix I: Glossary
Access Point (AP):
Any entity that has station functionality and provides access to the distribution services, via the wireless medium (WM) for associated stations.
Channel:
An instance of medium use for the purpose of passing protocol data units (PDUs) that may be used simultaneously, in the same volume of space, with other instances of medium use (on other channels) by other instances of the same physical layer (PHY), with an acceptably low frame error ratio (FER) due to mutual interference.
SSID:
Service Set identifier. An SSID is the network name shared by all devices in a wireless network. Your network’s SSID should be unique to your network and identical for all devices within the network. It is case-sensitive and must not exceed 20 characters (use any of the characters on the
keyboard). Make sure this setting is the same for all devices in your wireless network.
**WEP:**
Wired Equivalent Privacy (WEP) is the method for secure wireless data transmission. WEP adds data encryption to every single packet transmitted in the wireless network. The 40bit and 64bit encryption are the same because out 64 bits, 40 bits are private. Conversely, 104 and 128 bit are the same. WEP uses a common KEY to encode the data. Therefore, all devices on a wireless network must use the same key and same type of encryption. There are 2 methods for entering the KEY; one is to enter a 16-bit HEX digit. Using this method, users must enter a 10-digit number (for 64-bit) or 26-digit number (for 128-bit) in the KEY field. Users must select the same key number for all devices. The other method is to enter a text and let the computer generate the WEP key for you. However, since each product use different method for key generation, it
might not work for different products. Therefore, it is NOT recommend using.
**WPA/WPA2:**
A security protocol for wireless networks that builds on the basic foundations of WEP. It secures wireless data transmission by using a key similar to WEP, but the added strength of WPA is that the key changes dynamically. The changing key makes it much more difficult for a hacker to learn the key and gain access to the network. WPA2 is the second generation of WPA security and provides a stronger encryption mechanism through Advanced Encryption Standard (AES), which is a requirement for some government users.
**ADSL:**
Short for Asymmetric Digital Subscriber Line -- A method for moving data over regular phone lines. An ADSL circuit is much faster than a regular phone connection, and the wires coming into the subscriber's premises are the same (copper) wires used for regular phone service. A commonly discussed configuration of ADSL would allow
a subscriber to receive data (download) at speeds of up to 1.544 megabits (not megabytes) per second, and to send (upload) data at speeds of 128 kilobits per second. Thus the "Asymmetric" part of the acronym.
**ATM:**
ATM stands for Asynchronous Transfer Mode. A transmission protocol that breaks down user traffic into small fixed-sized cells, before reassembling them after transmission. During transmission, cells from different users are asynchronously intermixed, thereby maximizing network resources. The ATM advantages voice and video stream and data transmission in single network.
**VPI:**
Stands for "Virtual Path Identifier." The VPI is an 8-bit header inside each ATM cell that indicates where the cell should be routed. It is used to identify the virtual path (a bundle of virtual channels that have the same endpoint) to which the cell belongs as it travels through an ATM network. As an ATM
cell moves across a network, it typically passes through several ATM switches. The VPI tells the switches where to route the packet of information, or what path to take. Hence the name, "virtual path identifier." The VPI is used in conjunction with the VCI, or virtual channel identifier.
**VCI:**
Stands for "Virtual Channel Identifier." The VCI indicates where an ATM cell is to travel over a network. The VCI within each ATM cell defines the fixed channel on which the packet of information should be sent. It is a 16-bit field, compared to the VPI, which is only 8 bits. Since this numerical tag specifies the virtual channel that each packet belongs to, it prevents interference with other data being sent across the network.
**Bridging:**
Here is related to the well-known RFC1483 bridging protocol. This feature is working on the basic bridging protocol and physical layer. In this device, Modem serves as a bridge device, and does not provide any
protocol transfer and address filtering features. In this case, the Modem actually plays the role as Hub.
**IPoA:**
It is related to RFC1577. Usually the data packets are transferred via ATM network. In this connection mode, user must have static IP address, subnet mask and other parameters. Lack of user name and password authentication, it can not implement network administration and QoS features, so this access way will not prevail any more.
**PPPoA:**
Short for Point-to-Point Protocol over Asynchronous Transfer Mode (ATM). PPPoA relies on two widely accepted standards: PPP and ATM. It is an end-to-end asymmetric digital subscriber line (ADSL) architecture. IP packets travel from the PC over Ethernet to the DSL modem, called the ADSL transceiver unit-remote (ATU-R). The ATU-R adds the PPP protocol to the IP packets and transports them to the carrier's Digital Subscriber Line Access Multiple
(DSLAM) via ATM. It is a technology becoming more popular with DSL providers.
**PPPoE:**
Acronym for Point-to-Point Protocol over Ethernet. PPPoE relies on two widely accepted standards: PPP and Ethernet. PPPoE is a specification for connecting the users on an Ethernet to the Internet through a common broadband medium, such as a single DSL line, wireless device or cable modem. All the users over the Ethernet share a common connection, so the Ethernet principles supporting multiple users in a LAN combine with the principles of PPP, which apply to serial connections.
|
EXTRA CARE AND SUPPORTED LIVING
GUIDANCE DOCUMENT
December 2020
## Contents
| Section | Page |
|------------------------------------------------------------------------|------|
| Summary: Testing for Extra Care and Supported Living settings | 2 |
| Which settings are able to access test kits? | 3 |
| What do you do if you have an outbreak? | 5 |
| End to end testing process: | 6 |
| - Service summary | |
| - Re-testing timetable | |
| - Unique Organisation Number | |
| - Ordering test kits | |
| - Preparing your setting | |
| - Delivery & Storage | |
| - Conducting the test | |
| - Registering the test | |
| - Returning the test kits | |
| - Results | |
| Where to go for help | 39 |
| Appendix | 43 |
Summary: Testing in extra care and supported living settings
What is the service?
- To make regular COVID 19 testing available to Extra Care and Supported Living settings that meet certain criteria
- All staff and residents should be offered tests in these settings, including care staff, housing staff, and all residents, whether they receive personal care or not.
- From 9th December, testing coordinators should order tests every 28 days for their setting
- Each member of staff should conduct a test each week and each resident should be tested monthly
- Completed tests can be sent back via priority post box or collected via a courier
- Results will be received within 2 to 4 days by email and text message (SMS)
- The testing coordinator is the person that orders tests for the setting and has oversight of the overall testing process
Why is testing important?
- Identifies staff and residents who currently have Covid-19 so they are able to self-isolate if their result is positive
- Protects those receiving care from infection passed to them by staff who are confirmed positive
- Prevents and controls the spread of the virus by identifying asymptomatic cases
Join our webinars
We would like to invite you to our regular Extra Care and Supported Living testing webinars. We welcome Local Authorities and all staff at the Extra Care and Supported Living settings to this webinar series.
The webinars will last 1 hour and give detailed information about all aspects of testing, including:
1. Ordering tests
2. Preparing for testing
3. Test kit delivery
4. The testing process itself
5. Registering completed test kits
6. How to send test kits back to our labs
7. Results and what they mean for your organisation
The content of the webinars will largely be the same for each session, however, will include key updates on testing so is subject to change. We will announce any key updates via this bulletin also.
The session will include a Q&A with representatives from the testing team, who will be able to answer your questions and address any concerns in the session.
To sign up to attend our new Extra Care and Supported Living testing webinars, click here:
https://event.webcasts.com/starthere.jsp?ei=1380165&tp_key=dfecd07a9d
Which settings are able to access test kits?
My setting meets the following eligibility criteria:
- The setting is a closed community with substantial facilities shared between multiple people, and
- Where most residents receive the kind of personal care that is CQC regulated (rather than help with cooking, cleaning and shopping)
- Your Local Authority has identified you as eligible for Extra Care and Supported Living testing and you will have received an email inviting you to order test kits from the following email address: firstname.lastname@example.org
My setting meets the criteria, but I have not been identified by my Local Authority:
- The ‘self referral portal’ can support you from 11th December
- The aim of this portal is to ensure that all eligible settings are able to access testing
- The portal will allow settings to put themselves forward for testing without having to be referred by Local Authorities, meaning that the process will be faster for providers
- The next slide walks through the self referral process
Self referral portal
We are planning that from the 11th December, all eligible settings (which have not already been set up to apply for test kits (onboarded)) will need to complete the following steps to refer their setting:
1. Provider navigates to: https://request-onboarding.test-for-coronavirus.service.gov.uk/
2. Provider inputs the ‘DHSC Referrer Unique Organisation Number’ which is 99874802. You will only need to use this code once, the UON cannot be used to order test kits.
3. Provider completes eligibility questions
4. Provider inputs the information for the setting, including delivery address and contact details
5. Submit referral
6. Referral is sent to LA for approval
7. LA assesses if the setting/s meets the eligibility criteria, and confirms or denies the referral request/s
8. If eligible, setting is on-boarded onto our systems and will be eligible to place an order for test kits
This process can take up to 2 weeks for eligible settings to be onboarded
What to do if you have an outbreak
Outbreak testing may be available through your local Health Protection Team (HPT)
You must alert your HPT immediately if a confirmed case of coronavirus occurs in your setting
Staff with symptoms should not be in work and should not come into work for testing. They should be tested via the home testing portal
To find out which public health team covers your area visit: https://www.gov.uk/health-protection-team
New or current outbreak
Report to Health Protection Team (HPT) / Directors of Public Health
They will undertake an initial risk assessment, provide advice on outbreak management and decide what testing is needed
No outbreak
We are now rolling out the re-testing of staff and residents in Extra Care and Supported Living settings which meet certain risk-based criteria
Local Directors of Public Health will determine which extra care and supported living settings meet the criteria
The end-to-end testing process
Summary: Testing in extra care and supported living settings
Testing manager receives Unique Organisation Number (UON) and orders test kits
Testing manager ensures setting is prepared for testing
Testing manager takes delivery of the kits and books courier if testing 9 or more people
Staff tested weekly, residents every 28 days
All completed tests must be registered online
Courier collects completed test kits or tests can be returned via your nearest priority post box if testing less than 8 people
Results received via email and text message (SMS)
Follow testing schedule each week
If you have any queries with any of the steps please call the national coronavirus contact centre on 119
Re-testing timetable
From 9th December, Extra Care and Supported Living settings in England should conduct repeat testing over a period of 4 weeks.
All Extra Care and Supported Living homes can apply for regular re-testing at: https://request-testing.test-for-coronavirus.service.gov.uk
When we process the order for kits, the Extra Care or Supported Living setting will be provided with the following test kits:
- 4 x all staff
- 1 x all residents
You can apply for more test kits after 21 days have elapsed from your previous order being processed. You will receive an email with the subject line ‘COVID-19: Organisation test kit order – delivery confirmed’
Extra Care and Supported Living settings are advised to follow the following testing timetable:
Repeat testing process every 4 weeks
Week one
Test all residents and staff
Week two
Test all staff
Week three
Test all staff
Week four
Test all staff and apply for more kits on day 21
Unique Organisation Number
To use all services, organisations are assigned an 8 digit Unique Organisation Number (UON)
Why have I been assigned a UON?
Each setting has been assigned their own UON so that test kit orders, courier bookings and test kit registrations can all be tracked back to an individual setting.
Through the use of UONs our systems can uniquely identify each setting.
Better data helps us to better understand the risk posed by the virus – all of the testing we do supports an array of scientific research, which needs up-to-date and robust data.
How do I find out my UON?
Once on-boarded, an email will be sent to organisation informing them of their new UON number from email@example.com
The email will come with the subject title ‘COVID-19: Your new Unique Organisation Number (UON)’
Eligible settings will only receive a UON once your Local Authority is on-boarded.
If your setting is eligible and have been on-boarded, but haven’t received your UON, please call 119.
Ordering test kits
Ordering test kits
The testing manager is responsible for ordering test kits for the setting.
You must register for test kits using this link (https://request-testing.test-for-coronavirus.service.gov.uk).
In order to apply, you will need:
1. Your Unique Organisation Number (UON)
2. Total number of residents and whether they are displaying coronavirus symptoms
3. Total number of staff, including agency staff, and whether they are displaying coronavirus symptoms
4. Their contact details
Once you have placed an order, you will receive a confirmatory email from the following address: firstname.lastname@example.org
Preparing your setting
Preparation is key to successful testing. You should start to plan for how you will conduct testing in your setting as soon as you order your test kits.
Make sure your facility is fully prepared
Schedule:
- Testing can be scheduled over multiple days, taking into account various shift patterns and courier timings
- Testing can take place over the weekend too – note that on Sundays you cannot use the Royal Mail postage return option unless your nearest priority post box states it has a Sunday collection. You do not have to test everyone on one day
Communication:
- Making all staff and residents aware of testing plans and what the tests are for
Consent
- Obtaining written consent from all staff and residents to be tested in line with your normal policies and procedures. Consent form templates can be obtained from your local authority if required
Create a template to record completed tests
- Prepare the record keeping template for your own records
- You can use the template available on our government guidance page https://www.gov.uk/government/publications/organisation-testing-registration-record-of-users/unique-organisation-number-uon-and-multiple-registration-guidance
- Make sure you have a clear record of which barcode belong to each person
You should not begin testing on the day of delivery. You must have a courier booked if you plan to test 9 or more people.
Delivery and storage
What to do
- Accept the test kit delivery
- Follow guidance in delivery confirmation email and printed instructions with your test kits
- Store test kits in a safe place at room temperature (between 5 and 22 degrees Celsius)
- If you have any spare test kits, they should be stored between 5 and 22 degrees Celsius until their expiry date, which is displayed on the swabs
What not to do
- Don’t store test kits in the fridge
- Don’t mix with test kits from your local HPT, as this may lead to complications with test kit registration
- Sharing test kits between settings may lead to issues with test kit registration, courier collection and also contact tracing
Conducting a test
Taking the test
You will conduct a combined throat and nose self-swab for the test.
Follow the instructional video on how to do a throat and nasal swab:
https://www.gov.uk/government/publications/covid-19-guidance-for-taking-swab-samples/how-to-use-the-self-swabbing-kit-for-a-combined-throat-and-nose-swab-video
Instructional video for self swabbing
The link to your test kit guidance document will be in your delivery confirmation email.
You will also receive printed instructions with your test kits.
This is a service for asymptomatic individuals, anyone that is symptomatic can get a test here:
https://www.gov.uk/get-coronavirus-test
The test kit
The test kit contains the following items when delivered.
Please note that test kits will arrive in boxes of 40, along with printed guidance booklets.
1. Plastic tube, containing a small amount of liquid. The liquid must stay in the tube.
2. Swab, inside sealed wrapper
3. Spare barcode
4. Absorbent pad
5. Zip-lock bag
6. Biohazard bag with silver seal
7. Return box
8. Security seal, for the return box
9. Royal Mail return label
An example test kit
What if someone can’t tolerate a throat swab?
If a throat swab is not possible, a double nasal swab can be done.
For double-nasal swabs it is recommended that you also take into account the individual’s circumstances when interpreting results.
For example, when looking at a negative result for a double-nasal swab, you also need to take into account if the person was symptomatic, and if so err on the side of caution, isolate and retest. It could be that the swab may not have collected enough virus to be detectable.
Conversely, if the result is negative and the person seems well, no need to do anything. If you take a double-nasal swab you should note this down and keep this information to refer back to.
Registering completed tests
You must register each test kit after completing the test using the link given to you in your delivery confirmation email.
Multiple registration upload – tips for success
• For guidance on how to use our multiple upload portal and to download the record keeping spreadsheet, please click here: https://www.gov.uk/government/publications/organisation-testing-registration-record-of-users/unique-organisation-number-uon-and-multiple-registration-guidance
• Watch our multiple upload portal webinars: https://event.webcasts.com/viewer/event.jsp?ei=1381611&tp_key=6a1298b186
• The excel document should not be altered. Barcode, date and time of the swabs should be entered after the spreadsheet is uploaded. Should not be digitally entered into the excel spreadsheet.
• The excel document cannot be scanned into the computer – it must be a digital copy.
• Grey cells and columns A and B should not be filled in (unless printing a copy and manually filling in for your own records). Cells should only be grey if you do not have to fill in that particular cell.
• If the bulk upload feature is not working, please register the test kits individually.
Registering a single kit online
Steps to register a test kit:
These are the key steps, for full step-by-step instructions please see the appendix.
Each week you should register your test after you have completed your test.
1. Please go to https://organisations.test-for-coronavirus.service.gov.uk/register-organisation-tests
2. Enter your Unique Organisation Number
3. Enter or scan test kit barcode, please enter carefully and do not copy and paste
4. Enter personal details:
- Name
- Whether they are a service user or staff member
- Whether they have symptoms or not
- Gender
- Date of birth
- Email address (for results)
- Phone number (for results)
- Home postcode
- NHS number (optional, note that this is important to update the subjects' NHS records)
5. Check your answers
6. Test kit registration confirmed
7. You will receive confirmation of registration via email
If there are any problems with registering a test kit, please call 119
Screenshot of entering a UON
Returning test kits
RETURN METHOD 1:
Courier collection of test kits (9 or more test kits a day)
Book at:
https://test-kit-collection.test-for-coronavirus.service.gov.uk/
• You will need your Unique Organisation Number and postcode to register
• You can book a courier 24 hours after your order is ‘confirmed’
• You must book for next day before 5pm for the 9am – 1pm courier collection slot
• You must book for next day before 7pm for the 4pm – 9pm courier collection slot
• You can book up to 28 days in advance
• You can book ad hoc courier collections through this portal
RETURN METHOD 1:
Courier collection of test kits (9 or more test kits a day)
What you must do – courier collection
• Place individual completed tests into the cardboard box (right)
• Ensure you have a UN3373 label on the return outer box that you use to comply with safety regulations
• You can use your own box if you place the UN3373 label on it (print or in pen)
• Store kits between 5 - 22 degrees Celsius
• Make sure all staff know the courier is arriving so they can hand the kits over quickly
RETURN METHOD 1: COURIER
Courier timeslot 1: 4pm – 9pm on the day of testing
Conduct testing until 3pm
Register kits after testing
Collection between 4pm - 9pm
If courier has not arrived, please contact the Coronavirus Testing Contact Centre the following morning on 119
RETURN METHOD 1: COURIER
Courier timeslot 2: 9am–1pm the day after testing
Site / service open hours
Conduct testing
Day 1
Test all day
Register kits after testing
9am-1pm
Collect test kits from day 1
Day 2
Collection the following morning*
*Test kits completed on day 1 will be collected on day 2, etc.
If courier has not arrived by 3pm, please contact Coronavirus Testing Contact Centre on 119
RETURN METHOD 2:
Priority post box returns (8 or less test kits a day)
You will have ready paid return labels. Please attach these to the delivery alongside the security seal.
You will find your nearest priority post box and its collection times at www.royalmail.com/services-near-you and tick ‘show my nearest priority post boxes’
Please be aware of the following key points to ensure samples reach the laboratories in time:
• Only use a Royal Mail priority post box. It will be labelled with the below sign Priority Box sign and one of the regional NHS logos. Please do not enter any Post Office with the kit.
![Logos on priority post boxes]
• Do not put any completed tests in a priority box on Sunday unless your nearest priority postbox states it has a Sunday collection (or unless you have a courier collection booked, otherwise no testing should be conducted on a Sunday)
• Please drop the kits one hour before the last collection time to ensure that is not missed
If you have any issues with using the post box please contact 119
RETURN METHOD 2
Timeline for day of testing: Priority post box (8 tests or less)
Start testing on the day of posting
Conduct testing
1 hour before last priority post box collection - stop testing and post completed kits*
Test kit collected by Royal Mail priority post
Register all kits after testing
*Last collection times vary by local authority.
Please go to https://www.royalmail.com/services-near-you/#/ and tick ‘show my nearest priority post boxes’
Nothing should change in your setting while you wait for results, unless a person displays symptoms.
Results
Receiving results
The person tested will receive:
1. An email
2. A text message (if a mobile phone number was provided at registration)
The results will also include guidance on next steps for the person tested. We have included example guidance in the next few slides for your information.
Staff should inform their employer of a **positive result** immediately so that they can protect others that they may have come into contact with at work.
Find out more about what to do when you get your results [https://www.nhs.uk/conditions/coronavirus-covid-19/testing-and-tracing/what-your-test-result-means/](https://www.nhs.uk/conditions/coronavirus-covid-19/testing-and-tracing/what-your-test-result-means/)
The Infection Control Fund (ICF) can be used to pay the wages of staff who have to self-isolate. Further details are on the website noted below:
[https://www.gov.uk/government/news/more-than-500-million-for-social-care-to-reduce-coronavirus-transmission-over-winter](https://www.gov.uk/government/news/more-than-500-million-for-social-care-to-reduce-coronavirus-transmission-over-winter)
Examples of email containing results
There are 3 possible results – Negative, Positive and Unclear
**Negative**
| From | NHS COVID-19 Notification |
|------|----------------------------|
| To | email address |
| Subject | NHS COVID-19 Notification |
Dear (Full Name)
Birth date – (Date of Birth)
(Date of test)
Your coronavirus test result is negative. You did not have the virus when the test was done.
You only need to self-isolate if:
- you get symptoms of coronavirus (you’ll need a new test)
- you’re going into hospital (self-isolate until the date you go in)
- someone you live with tests positive
- you’ve been traced as a contact of someone who tested positive
For advice on how long to self-isolate, go to www.nhs.uk/coronavirus and read ‘Self-isolation and treating symptoms’.
Otherwise, you may return to work if you’ve not had a high temperature for 48 hours and feel well. Talk to your employer first.
For a care home resident, follow the care homes guidance. If the resident still has symptoms, they may need a repeat test.
Contact 111 if you need medical help.
In an emergency, dial 999.
Help the NHS with coronavirus vaccine research
Sign up below to be contacted about taking part in coronavirus vaccine studies.
www.nhs.uk/researchcontact/testing
**Positive**
| From | NHS COVID-19 Notification |
|------|----------------------------|
| To | email address |
| Subject | NHS COVID-19 Notification |
Dear (Full name)
Birth date – (Date of Birth)
(Date of test)
Your coronavirus test result is positive. It means you had the virus when the test was done.
Try not to worry. You can often ease symptoms at home until you recover.
You may be contacted for contact tracing.
You must, by law, self-isolate for 10 days from your symptoms starting. If you’ve not had symptoms, self-isolate for 10 days from your test.
You may return to work on day 11 if you’ve not had a high temperature for 48 hours and are well. Talk to your employer first.
People you live with should self-isolate for 14 days from your symptoms starting or 10 days from their symptoms starting.
For a care home resident, follow relevant guidelines.
For a child or staff at school or nursery, tell the school/nursery.
For medical help, contact 111. In an emergency dial 999.
More advice: www.gov.uk/coronavirus
Help the NHS with coronavirus vaccine research
Sign up below to be contacted about taking part in coronavirus vaccine studies.
www.nhs.uk/researchcontact/testing
**Unclear**
| From | NHS COVID-19 Notification |
|------|----------------------------|
| To | email address |
| Subject | NHS COVID-19 Notification |
Dear (Full Name)
Birth date – (Date of Birth)
(Date of test)
We could not read your coronavirus test sample. This means it’s not possible to say if you had the virus when the test was done.
We’re sorry, but you’ll need to get another test as soon as possible.
Keep self-isolating (and stay off work if relevant) if:
- you have or develop symptoms of coronavirus
- someone you live with has symptoms or tests positive
- you’ve been traced as a contact of someone who tested positive
For advice on how long to self-isolate in these situations, go to www.nhs.uk/coronavirus and read ‘Self-isolation and treating symptoms’. You can end your self-isolation period early if your new test result says to stop self-isolating.
For a child or staff at school or nursery, tell the school/nursery.
Contact 111 if you need medical help. In an emergency dial 999.
Help the NHS with coronavirus vaccine research
Sign up below to be contacted about taking part in coronavirus vaccine studies.
www.nhs.uk/researchcontact/testing
Examples of text message containing results
There are 3 possible results – Negative, Positive and Unclear
**Negative**
Your coronavirus test result is negative. You did not have the virus when the test was done. You only need to self isolate if:
- You get symptoms of coronavirus (you’ll need a new test)
- You’re going into hospital (self-isolating until the date you go in)
- Someone you live with tests positive
- You’ve been traced as a contact of someone who tested positive
For advice on how long to self isolate, go to [www.nhs.uk/coronavirus](http://www.nhs.uk/coronavirus) and read ‘Self-isolation and treating symptoms’
Otherwise, you may return to work if you’ve not had a high temperature for 48 hours and feel well. Talk to your employer first.
For a care home resident, follow the care home guidance. If the resident still has symptoms, they may need a repeat test.
Contact 111 if you need medical help.
In an emergency, dial 999.
**Positive**
Your coronavirus test result is positive. It means you had the virus when the test was done.
Try not to worry. You can often ease symptoms at home until you recover. You may be contacted for contact tracing.
You must, by law, self-isolate for 10 days from your symptoms starting. If you’ve not had symptoms, self-isolate for 10 days from your test.
You may return to work on day 11 if you’ve not had a high temperature for 48 hours and are well. Talk to your employer first. People you live with should self-isolate for 14 days from your symptoms stating or 10 days from their symptoms starting.
For a care home resident, follow relevant guidelines
For a child or staff at school or nursery, tell the school/nursery.
For medical help, Contact 111. In an emergency, dial 999.
**Unclear**
We could not read your coronavirus test sample. This means it’s not possible to say if you had the virus when the test was done. We’re sorry, but you’ll need to get another test as soon as possible.
Keep self-isolating (and care worker off work if relevant) if:
- You have or develop symptoms of coronavirus.
- Someone you live with has symptoms or tests positive.
- You’ve been traced as a contact of someone who tested positive.
For advice on how long to self-isolate in these situations go to [www.nhs.uk/coronavirus](http://www.nhs.uk/coronavirus) and read ‘Self-isolation and treating symptoms’. You can end your self-isolation period early if your new test results says to stop self-isolating.
For a child or staff at school or nursery, tell the school/nursery.
Contact 111 if you need medical help. In an emergency, dial 999.
## What if a test comes back positive
| Symptomatic | Asymptomatic |
|------------------------------------------------------------------------------|-------------------------------------------------------------------------------|
| **Residents** | **Asymptomatic** |
| Continue to isolate for 14 days from the day that symptoms started | Isolate for 14 days from the day the test was taken |
| **Staff** | **Asymptomatic** |
| Continue to self isolate for 10 days from the day of symptoms | Self isolate for 10 days from the day the test was taken. |
| Staff with symptoms should not come into the facility | Staff can return to work on day 11 if they have no symptoms |
- You must have written consent from the individual if you plan to have results returned to a different person.
- If a resident or staff member who has previously tested positive develops new symptoms, then please re-test after 90 days of the initial test.
- Staff who are symptomatic should be off work and should be tested through the home testing channel. They will be able to return to work after isolating when well and test through this programme. Symptoms are defined here: [https://www.nhs.uk/conditions/coronavirus-covid-19/](https://www.nhs.uk/conditions/coronavirus-covid-19/)
- It is your responsibility to inform your local Public Health authority of a positive result.
- More information can be found here: [https://www.gov.uk/government/publications/covid-19-management-of-exposed-healthcare-workers-and-patients-in-hospital-settings](https://www.gov.uk/government/publications/covid-19-management-of-exposed-healthcare-workers-and-patients-in-hospital-settings)
What if a test comes back negative?
• You do not need to isolate if there are no symptoms and a negative COVID-19 result
• If someone subsequently develops symptoms, they should isolate and order a test through the NHS symptomatic portal unless advised otherwise by local Health Protection Team
What if a test comes back as unclear, also known as ‘we could not read your sample’?
• If symptomatic, treat tests as positive and isolate the resident or staff member
• Residents should be retested using spare test kits to get a conclusive result. Staff can be retested using spare kits only if they are not displaying any symptoms
• No symptoms and a ‘we could not read your sample’ result means that staff can continue to work but should be retested immediately
• If you don’t have enough spare kits, call the Coronavirus Testing Contact Centre on 119 (England)
Where to go for support
Support
Online: Visit www.gov.uk/guidance/coronavirus-covid-19-getting-tested#care-home for complete guidance and https://www.gov.uk/government/publications/supported-living-services-during-coronavirus-covid-19/covid-19-guidance-for-supported-living
Watch the instructional videos: https://www.youtube.com/watch?v=1l0jcv37WzI and https://www.gov.uk/government/publications/covid-19-guidance-for-taking-swab-samples/how-to-use-the-self-swabbing-kit-for-a-combined-throat-and-nose-swab-video
Complete the competency assessment: available at www.genqa.org/carehomes
Contact your Local Authority - https://www.gov.uk/find-local-council
Coronavirus Testing Contact Centre: please call 119 (England)
Lines are open from 7am –11pm daily. After selecting your country, language requirements and data preferences, press ‘1’ for calling from an organisation who receives test kits directly from the national testing programme
Resources Available
- Consent form templates that can be used for staff and residents have been shared with Local Authorities.
- Guidance on testing people who lack mental capacity can be found here: https://www.gov.uk/government/publications/coronavirus-covid-19-looking-after-people-who-lack-mental-capacity/the-mental-capacity-act-2005-mca-and-deprivation-of-liberty-safeguards-dols-during-the-coronavirus-covid-19-pandemic-additional-guidancea
- Learning disability specific guidance and videos can be found here: https://www.youtube.com/watch?v=iEGnsy_ABJo&list=PLfVgWWNgce45o8XjfHNcVJCjJiMfU8u-&index=16 and https://www.gov.uk/government/publications/covid-19-supporting-adults-with-learning-disabilities-and-autistic-adults
- Easy reads on Coronavirus and testing
1. https://www.gov.uk/government/publications/testing-for-coronavirus-at-home
2. https://www.gov.uk/government/publications/social-care-sector-covid-19-support-taskforce-report-on-first-phase-of-covid-19-pandemic
3. https://www.gov.uk/government/publications/supported-living-services-during-coronavirus-covid-19
Appendix
Step-by-step guide to register their kits after completing a test
Please refer to slide 24 for initial registration instructions / links
**STEP 1:** Confirmation of consent
Confirm you have consent
- I confirm that I’ve got consent from each person to register them
- I confirm that I’ve got consent for the results to go to the contact details entered for them
Continue
**STEP 2:** Select other
Which type of organisation are you?
- Care home
- GP surgery
- Dental surgery
- Prison
- Other
Continue
**STEP 3:** Enter your 8 digit UON
What's your organisation number?
This is the 8 digit number provided to you by the National Testing Programme. For example 12345678.
What to do if you cannot find your organisation number
Continue
STEP 4: Select ‘add each person’s details one by one’
How do you want to register tests?
- Use our spreadsheet to add a list of patients
Enter and upload details for up to 50 people at a time
- Add each person’s details one by one
Use an online form to enter their details
Continue
STEP 5: Select non-staff or staff
Who are you registering?
- Non-staff (for example residents or patients)
- Staff
Continue
STEP 6: Enter your name
What’s the person's name?
First name
Last name
Continue
STEP 7: Enter your date of birth
What’s Peter Smith’s date of birth?
For example, 31 3 1980
Day Month Year
Continue
STEP 8: Enter your gender
What’s Pete Smith’s gender?
- Male
- Female
Continue
STEP 9: Enter your ethnicity. You can select prefer not to say
What is Peter Smith's ethnic group?
This will help us understand how coronavirus is affecting people of different ethnic backgrounds.
- Asian or Asian British
Includes any Asian background, for example, Bangladeshi, Chinese, Indian, Pakistani
- Black, African, Black British or Caribbean
Includes any Black background
- Mixed or multiple ethnic groups
Includes any Mixed background
- White
Includes any White background
- Another ethnic group
Includes any other ethnic group, for example, Arab
- Prefer not to say
Continue
STEP 10: Enter your work status.
Is Peter Smith currently in work?
This will help us understand more about the spread of the virus.
- Yes, and for the last 2 weeks I’ve worked from home
- Yes, and for the last 2 weeks I’ve travelled to work
- No
- Prefer not to say
Continue
STEP 11: Enter your area of work.
Select Peter Smith's area of work
This helps us understand how coronavirus is affecting people in different workplaces.
- Teaching and education
- Health and social care
- Transport
- Retail
- Hospitality
- Hair and beauty professionals
- Information and communication
- Financial services and insurance
- Manufacturing or construction
- Civil services or local government
- Arts, entertainment or recreation
- Other
- Prefer not to say
Continue
STEP 12: Enter your occupation. You must select an option from drop down menu but you can say that you are unable to find the correct occupation.
What is Peter Smith's occupation?
This helps us track which occupations are more at risk from coronavirus.
Start typing and select their occupation from the drop down. If their occupation is not displayed select 'Other'.
Occupation
I cannot find the correct occupation
Continue
STEP 13: Enter the name of your employer.
What is the name of Peter Smith's employer?
This helps us trace their work colleagues if they test positive for coronavirus.
Employer Name
Continue
Prefer not to say
STEP 14: Enter the country you live in.
What country does Peter Smith live in?
England
Scotland
Northern Ireland
Wales
Continue
STEP 15: Enter your home postcode. An additional question will ask for the first line of your address.
What's Peter Smith's home postcode?
For residents, enter the organisation’s postcode.
For patients of a GP or dental surgery, enter their personal home postcode.
For staff, enter their personal home postcode.
Postcode
Continue
STEP 16: Enter your NHS number, if you know it. This is used to link the result to your patient record.
STEP 17: Select Yes or No depending on whether you have symptoms.
STEP 18: Enter date of onset of symptoms, if you see this page.
STEP 19: Enter the test kit barcode.
STEP 20: Enter the date and time the test was completed. This date and time can be in the past
STEP 21: Enter your email address. Results will be sent to this email address.
Registration service update
The service for registering test kits for your organisation is changing on Wednesday, 25th November.
There’ll be an additional step on the single registration service (Image A). This will follow the step shown in image B, as follows:
**Image A (new step)**
Are you a care home taking part in the return box tracking pilot?
This is a research study with 14 care homes, to track the return of test kits boxes to the lab.
- Yes
- No
Continue
**Image B (what you’ll see before the new step above)**
Do you want to add a mobile number?
We’ll also send their test result to this mobile phone number.
If the mobile phone number does not belong to the person being registered, make sure you have got their consent for their results to go to someone else’s mobile phone number.
- Yes, I want to add a mobile phone number
- No, I do not want to add a mobile phone number
Continue
This new step is only for care homes taking part in the return box tracking pilot.
If you’re not taking part in the return box tracking pilot, please click ‘No’ when you come to this page.
STEP 22: Enter your mobile phone number if you’d like to receive text notification of your result. If you do not have a mobile or do not want to receive a text, select ‘No’.
Do you want to add a mobile number?
We’ll also send their test result to this mobile phone number.
If the mobile phone number does not belong to the person being registered, make sure you have got their consent for their results to go to someone else’s mobile phone number.
- Yes, I want to add a mobile phone number
- No, I do not want to add a mobile phone number
Continue
STEP 23: Check your answers. You are able to change details at this stage.
Check your answers
| Full name | Change |
|-----------|--------|
| Date of birth | Change |
| Gender | Change |
| Ethnic group | Change |
| Ethnic background | Change |
| In work | Change |
| Area of work | Change |
| Occupation | Change |
| Employer name | Change |
| Country of residence | Change |
| Postcode | Change |
| NHS number known | Change |
| Do they have any symptoms? | Change |
| Date of symptoms onset | Change |
| Test kit barcode reference | Change |
| Test date and time | Change |
| Email | Change |
| Mobile | Change |
Submit answers
Your test will have now been registered.
The confirmation page also allows you to register more test kits should you need to.
Note: You will receive confirmation of registration via email. If you do not receive this, please contact 119 to check that you have registered successfully.
|
Vulnerable Light
So benumbed are we nowadays by electric lights that we have become utterly insensitive to the evils of excessive illumination.
— Jun’ichiro Tanizaki.\(^1\)
There is a deep, dark secret to photography, one of which most people are unaware. Photography is a practice of deceit, betrayal, and, inevitably, violation. But this has nothing to do with the photographic subject, nor with the photographer him or herself. This, rather, is a characteristic of the very medium and, as we all have been told, *the medium is the message*: “the camera is sold as a predatory weapon.”\(^2\)
If this is true, one must ask the necessary question: what is it that the camera preys upon? It is not the image, for the image is implicated in the act of appearance. At best one might argue that the *excerpting* of image from body or object constitutes the violation in this instance. Yet we have also been told that “it’s the object that wants to be photographed,”\(^3\) and that “everything today exists to end in a photograph.”\(^4\) Here one might accuse the object world of vanity, but this does not translate to an accusation against the medium itself. No, the betrayal of photography concerns something different, something neglected, something even – perhaps – unexpected. Photography, quite simply, is a practice of *betraying darkness* or it is nothing at all.
Consider that photography was not born out of the light at all, but out of the literal shadows – the camera obscura. The distinct ability of darkness to preserve an altered version of minute amounts of light that penetrate its domain. As we know, light tends to obliterate darkness, turning it into shadow (at best) or overexposed and flattened surfaces of opaquely whitewashed tonality. Darkness is more generous, allowing for the preservation of light itself, in all its distinctiveness – on the condition that it is content to merely appear and not to conquer. Yet, darkness is also more clever, for it has a tolerance threshold after which it disappears, goes into hiding, unable to brave the intolerant and imperialist interventions which destroy the intimacy it protects.
It is easy, in this spirit, to understand why ultimately photography is not in any way an optical discipline. Instead, photography is always about sensory deprivation – chasing back the light in order to allow for the possibilities that can only grow out of darkness itself. And that light is used in these instances is no argument against the prominence of darkness, for here it is merely the relationship between the two that assumes an entirely counter-intuitive form. It is not the light that masks out the darkness, but rather light that in a very literal – all too literal – sense, eats itself alive: “at the heart of the photographic image there’s a figure of nothingness, of absence, of unreality.”\(^5\)
Consider that the works of Isabelle Hayeur are, perhaps, not quite what they seem. Not, in other words, the faithful documentary companion that photography is so often made out to be. Instead, and on a merely formal level, these are literally recombinant images – spliced landscapes, not merely recombined or collaged but genetically engineered. Yes, one must be firm in assertions such as this, light indeed can be genetically engineered – and Hayeur’s images are proof. But what did you expect? Did you think that any recombinant phenomenon would stand up and declare itself as enhanced? No, the case is much more subtle, and in its subtlety much more sinister. The clone looks just like you – if it didn’t it would not be a clone. It is, of course, faster, better, stronger – as are Hayeur’s images – but it would never admit to it for it is also smarter, and it knows that it must at all costs remain convincing as a humble, flawed and personable image.
The vulnerability is a hoax.
Or perhaps not? Maybe, just maybe, these are images that seek to fit in, images that request rather than demand our trust, images that know they are hoaxes and ask us to engage nevertheless? Even fantasies want to be photographed, and yes, even fantasies – or perhaps especially fantasies – are vulnerable.
Here a subtly placed plastic bag, there the archeological lines of urban history. It takes a year for a tree to form a new ring on its inside, but for an image this always instead occurs at the speed of light itself. Or at the speed of darkness. But they have something in common, in the end, for in both instances it is a ruptured body – a body whose very condition of appearing is that a violence has been done to it. One must cut into the tree to see its lines; one must equally penetrate the landscape in order to see its innards. Consequently, a hypothesis: are Hayeur’s images not perhaps best describe as Frankenstein landscapes? Not simply because of their digital recompositing, but first and foremost because they are stolen body parts of the landscape itself.
One could, of course, put this more eloquently by referring to the age-old archetypes of beauty, the fetishized images of Zeuxis whose paintings borrowed from only the most beautiful women around him, and even then only in parts.
The most beautiful nose + the most beautiful eyes + the most beautiful chin = the most beautiful face. But this too is a horror story, no less sinister for its justification as sublime. But perhaps this is the fate of beauty in an age of cosmetic surgery and biotechnology – destroyed by becoming precisely literal. No more the glowing vitality of *living beauty* but now instead only at best a beauty that is resurrected, always at least partially decomposed, always spliced and recombined and streamlined and updated and, most importantly, *reanimated* as if its appearance were entirely natural. We know better. There is no more beauty in purity, no more romance of unity or of uncharted territory – in fact there is no more beauty that is not precisely a disavowal of the unity, the romance and the uncharted territories that have been its historical prison.
The analogy seems to hold equally well when it is the beauty of the landscape under consideration. And this is perhaps why Hayeur’s *Excavations* can be both so powerful, so mysterious and, ultimately, so terrifying. We always assumed that we were afraid of the dark, for it is in the darkness that the demons of our imaginations live. But perhaps, it has always been just the other way around? Perhaps in fact it has always been darkness that is the *excuse* for our fear when the real object of terror has been the imagination itself? The last thing that anyone wants is to see their nightmares in the light of day; much better to confine to the shadows that which we do not understand, for once set free it is the light itself that is made vulnerable. Indeed, for the most part, it would seem that the imaginary has been relegated to the dark side of living which is why there is something imminent, something disconcerting about *seeing* these recombinant forms, something that makes the light itself seem foreign and out of place.
And this is perhaps the overarching consequence of the emergence of digital media – an imaginative facilitator that is no less disjunctive for the convincing realities it offers to the eye. A matter of perspective, one might say, and yet the mystique of the digital is that it is able to precisely make apparent *perspectives that do not exist*. The recombinant image requires a recombinant gaze, implicating the viewer in the intensity of impossible appearance, and recombining our very visual sensorium in the process. Compare, for instance the angle of viewing across the several images that comprise Hayeur’s *Excavations*, in which one is either floating *above* the landscape or else literally *buried* beneath the feint suggestions.
of civilized light. This juxtaposition is important for it recombines not only the images themselves but we, as viewers too.
Succession. Isabelle Hayeur, 2005
Consider the (formally) twinned images, Blindsight and Aube, whose perspective places both camera and – consequently – viewer beneath the ground-level of civilized living. In this instance we are literally buried along with the image – buried alive, one might say – zombies waiting patiently for the unfortunate passer-by, or creatures of the night silently stalking the day itself. Is this not perhaps something like what the world would look like to the monsters under our beds, or to the newly awakened zombie or any of a host of other imaginary creatures? It is not by mistake that we, as a culture, bury our fears – whether those be spiritual fears of death, traumatically repressed fears of living, or any other manifestation that even existing in the darkness of conscience is nevertheless too bright, too present, too imminent to the daily enactments we carry on in willful disregard. Here as viewers we are, ourselves, literally emerging from underneath the light, stalking
the familiarity of the civilized world, hiding, waiting. We might be enticed by the archeological constructions – the seven layers of Hell perhaps – but it is we who have been placed *within* the darkness in these images.
Consider, then, on the other hand, a perspective of the opposite sort, the floating disembodied gaze of *Succession* and *Traces* which present the landscape from a perspective that is fully *ungrounded*. Here we are exactly airborn, ghostly presences hovering over a landscape that itself is strangely unfamiliar, unsynchronized and out-of-place. It is not that these landscapes are over-exposed, but that they seem to not belong to the illuminated world at all. It is telling, for instance, that the reflections do not quite match the contours of the landscape, that dirt sits awkwardly atop the striated layers of clay and stone, that in both cases the landscape itself seems strangely *abandoned*, despite the traces and suggestions of human presence. There is, in other words, a poignant sense of dislocation here that might suggest that which we already knew – these are not images of locations at all, but images of *dislocations* which refuse to succumb to the sublime of a “good little landscape,” which refuse to be represented and objectified and instead proclaim in no uncertain terms that they will be here long after we ourselves have gone. Not unlike the shifting landscapes of dreams themselves, Hayeur’s images refuse to stay in focus, refuse to be inhabited and instead precisely *inhabit us* – haunted landscapes, or better, *predatory* landscapes, and in their contemplation we become part of their predatory ecosystem – the imagination brought to light in such a way that it is not the imaginary that disappears but the reality of illuminated existence itself.
And, might one not say something similar for the works of Jennifer Long? Here it is not the recombinant spirit that is in play but something perhaps even stranger: an intimacy that might only be called *alienating*, and not because it is directed elsewhere. No, it is because it is *represented* that the intimacy particular to Long’s works can be so disconcerting, an intimacy of the sort normally only encountered behind closed doors, or in the imagination itself. These images, in other words, seem precisely *familiar* and yet their familiarity has *no image referent*. Instead, the referent is precisely imaginary – this is their paradox and their brilliance – a photographic moment of exactly that which can *never be photographed*, rarely even visually remembered for in intimate circumstance it is not sight but emotion that
reigns. These are not, consequently, images at all – not in any real sense. Instead, they are precisely fantasies – photographs of what those intimate moments which we can only feel would look like if represented.
The vulnerability is a hoax.
Hairworks: Liz. Jennifer Long, 2005
Or perhaps not? Maybe, just maybe, these are images that can be so poignant because they precisely give us what we do not expect? Even fantasies want to be photographed, and yes, even fantasies – or perhaps especially fantasies – are vulnerable.
The beauty and the transgression of Long’s images are that, in fact, they are *not made to be looked at*, and even less *to be shared*. They are, instead, made to be felt – that which is a photographic impossibility is represented here as the catalyst of seduction at its most poignant. If one might say that there is a *corporeal* effect associated with the dischord of Hayeur’s landscapes, it is precisely a displaced *tactility* that occupies the darkened imaginary of Jennifer Long’s imagery. A fragile strand of hair, or two or three… one would never know unless the lights were on. And yet, one cannot help but look at these images and wish that they were not… that the lights were off and the intimacy preserved from the arrogance of illumination itself. Not the soft touch of sensitized bodies, but exactly the opposite – here the intimacy can be so disconcerting because it is both evocatively immanent and coldly denied, denying us the satisfaction of simply perceiving the figures as we would expect to – as images. Instead, in a strange twist, these images resist the objectifying gaze so typical of figurative photography, reversing its directionality in such a way that it is not the represented figure rendered in vulnerable self-consciousness but we ourselves. These are images, in other words, that *objectify us*. Resisting their very descent into imagery, here these figures remain bodies; it is we who watch who have, in this instance, become precisely images.
But this perhaps is nothing new, in fact perhaps the natural fate of an image culture that has subsumed our everyday realities to begin with. For, isn’t the intrigue of televised romance, suspense and mellow-drama actually a tool for refashioning our own vicarious engagements with the world around us? And isn’t the charm of a good story precisely that it leaves us feeling that we *have been a part of something*, some event or adventure – represented somehow as sharing affinities with one character or another? And might one not push the analogy even further and suggest that whether fictive affinity or bodily contact, the result is different only in degrees? In both instances we are seduced without realizing it, caught in a moment that defies representation and consequently represented
ourselves through precisely the self-consciousness that comes from contextual immersion. Consequently, a hypothesis: are Long’s images not perhaps Medusae of sorts, sirens which seduce and compel only to end up themselves with the last laugh, trapping us in their cold intimacy which nevertheless provides a melodious and soothing descent into the latent darkness they seek to share? For darkness, as we know, cannot be seen – yet it can, nevertheless, be felt. And there is a tactility to Long’s images that speaks without speaking, though its doubled message is no less clear for the voiceless words.
Consider, for instance, the Hairworks series whose exposed, vaguely voyeuristic poses are tempered and amplified by a clearly anonymous framing. One can hardly call these images beautiful, and yet there is a disturbingly erotic touch to the wet hair, the upraised chins, the exposed torsos. These images are, in fact, confrontationally intimate and the effect is both poignant and seductive. Fundamentally paradoxical, these bodies might be erotic or humiliated, enticing or confrontational, confident or victimized – and there are no real clues as to which is more plausible. There is something obsessive about these images, something taboo – something that cannot be ignored. If these are images of intimacy, why the anonymity? If these are images of personalized bodies, why the newly washed and still-wet and entangled hair? If these are images of seduction, why the full-frontal pose? And why the series, the intentional homogenization of difference, the taxonomy of torsos – unless the camera is indeed in this case a serial predator? Why, in other words, are these images so fully disconcerting? Might it not be because it is not the camera which takes the role of predator here, but we ourselves? There is, one must insist, something ominous about these images, something that is unmistakably violent, but whose story resists engagement. These are not traumatic bodies, for trauma is always personal in nature and great lengths have been taken to ensure that each of these bodies is faceless, named only by title. These anonymous stories nevertheless implicate us, demanding that we acknowledge our own viewing perspective even though we never really understood the context. These images are unreadable, yet they are alive. And, it is we who read who are implicated by consequence.
If the Hairworks can be so disturbing because of the living unreadability, it is precisely the opposite case that is in play with Long’s other series: Wallflowers.
Here again the framing is of the utmost importance – surgical in its application, amputating in its rendering of the bodies themselves, but again strangely intimate, gentle and flowing in its composition. There is, however, nothing animated about these bodies, no suggestion of movement or gesture but merely the frozen moment of photographic certainty – a moment which here is disconcerting precisely because one cannot tell if it is in any way intentional. Strangely, while most excerpted bodies will suggest their off-frame continuation, this series of images precisely and explicitly does not. Not, in other words, windows into a moment of voyeuristic engagement but rather calculated representations whose very presentation would seem to hyper-objectify the bodies in question – voodoo fetish dolls of one sort or another, and it is only natural that such connotations should be disconcerting. These bodies are also mannequins, and the staticity of the poses themselves is amplified by the precision of both focus and framing. For
all their intimate connotations, for all their evocative beauty, there is something – in other words – very dead about these bodies. Certainly not *Wallflowers* in that high-school sense of waiting to dance, these bodies are explicitly lying down, floor-flowers perhaps, but perhaps more aptly pushing up emotional daisies. It would of course only clarify the images if there were a trickle of blood, a bruise or a blemish on these figures, but – what is perhaps even stranger – *it would not seem out of place*. That these markers are absent only intensifies the uncertainty of the images themselves – images which by all accounts were never meant to see the light.
Again, in other words, it is precisely the emergent imagination that makes these images vulnerable. That we cannot tell if they are nightmares or fantasies is part of the vulnerability. If not traumatized bodies then most certainly traumatized *images* – images that exceed the constraints of the subject, refusing to be preyed upon by the camera and instead turning to stone those who attempt to categorize their stories. Not vulnerable bodies, but *vulnerable light* – illumination is never more vulnerable than when subjected to the over-exposure of imaginative proliferation, and stories that do not tell themselves leave the light of their appearance vulnerable to the darkness of the imagination. What is intimate in darkness is, inevitably, vulnerable in light. We are no longer afraid that the photograph will steal our soul – we are rather afraid that it will reveal the fact that we have none. Or perhaps, in a strange twist of fate, it is the photograph itself that, by assuming the explicit *soulfulness* of the imaginary, fulfills its destiny as the liberator of darkness, the catalyst for possibilities both intimate and terrifying.
Photography has never been about light. Instead, it has always been exactly the darkness of the imaginary that haunts the photographic image – an image that immediately leaves its object behind, substituting an imaginary double for that moment or event, body or experience.
But what happens when we look to the *darkness* of photographic practice? Here we find the true romance of the image, not in the competitive illustrations of documentary accuracy, nor in the political power of mobilized message, but just the opposite. If a picture can be worth a thousand words, can it also be worth a thousand moments of silence? If photography can be about capturing the light,
can it not also be about the liberation of darkness? For, as we know, it is in darkness that the imagination grows, taking on epic proportions that can be both compelling and terrifying, since its real-world referent no longer rises to the stage to keep it in disciplinary check.
Behind every image then, one might posit an imaginary world, illuminated by precisely the dynamic of photographically liberated darkness. And, it is in this world of the darkened imaginary that light itself is made, for perhaps the first time, vulnerable.
Notes
1 Jun’ichiro Tanizaki. *In Praise of Shadows*. Stony Creek (CT): Leete’s Island Books, 1977. p. 36.
2 Susan Sontag. *On Photography*. London: Doubleday, 1989. p. 14.
3 Jean Baudrillard. “Objects, Images, and the Possibilities of Aesthetic Illusion.” In *Art and Artifact*. Nicholas Zurbrugg, ed. London: Sage, 1997. p. 14.
4 Susan Sontag. *On Photography*. London: Doubleday, 1989. p. 24.
5 Jean Baudrillard. *Paroxysm: Interviews with Philippe Petit*. Chris Turner, trans. London: Verso, 1998. p. 93.
Isabelle Hayeur (Montreal) completed a BFA in 1996 and a MFA in 2002 at Université du Québec à Montréal (UQAM). Her large-format digital montages have been exhibited across Canada and in Europe, United-States, Latin America and Japan.
Jennifer Long (Toronto) is originally from Vancouver Island. She studied at Ryerson University receiving her BAA in Photographic Arts (Honours) in 1998. Her photo-based work has been exhibited nationally and internationally.
Michael Turner (Vancouver) is the author of Company Town, Hard Core Logo, Kingsway, American Whiskey Bar, and The Pornographer’s Poem. His work has been adapted to radio, stage, television and feature-film, and translated in French, Russian, and Korean.
Tamsin Clark is a Victoria-based photographic artist and a lecturer in the Visual Arts Department of the University of Victoria.
Ted Hiebert is a Canadian visual artist and theorist and the editorial assistant for Ctheory at the University of Victoria.
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Experimental Study of Light Weight Interlocking Brick Based On Mixed Material Variation Design
Shubham N. Vairale ¹, Amit S. Gawande ², Dr. Satish K. Deshmukh ³
¹Post Graduate Student, Structural Engineering, College of Engineering & Technology, Akola, Maharashtra, India
²,³ Professor, Department of Civil Engineering, College of Engineering & Technology, Akola, Maharashtra, India
Abstract - In many foreign countries, interlocking brick masonry is rapidly becoming a preferred alternative to traditional bricks for environmentally friendly buildings. The researchers have always challenged to make interlocking brick light weight, low cost and improve the performance against aggressive environment. An experimental effort made in this concern. The experimental study gives the results of light weight interlocking brick based on mixed material variation for Dimension, Weight Test, Water Absorption Test, Compressive Strength Test and Density testing were carried out and the test result is compared with standard interlocking brick specimen which were subjected to prior research in the laboratory by using varying percentage of fly ash, stone dust with different mix proportion. In comparison of standard interlocking bricks specimen with light weight interlocking bricks has some advantages such as high compressive strength, less density, durability and low cost. It is eco-friendly. After the several researches project involving the strengthening and reducing the weight of interlocking bricks by using fly ash in the interlocking bricks. Then the test has shown improvements in strength, density, durability compared to standard interlocking brick specimen and Light weight interlocking bricks. The benefit of using fly ash is used to reduce the weight of interlocking bricks. The brick is moulded with dimension of (300 x 150 x 125mm) with curing continuously for 28 days. Then the brick was finally tested using a compression testing machine. The fly ash ash gives more compressive strength, less density and durability as compared to the standard interlocking brick specimen.
Key Words: Interlocking Bricks, Fly Ash, Compressive Strength, Water Absorption, Density.
1. INTRODUCTION
As per G20 2024 report India has emerged as the fastest developing major economy within the world. And together with that India's populace is developing quickly and is right now the foremost populated nation within the world. For India’s developing economy and populace requests to boost the public infrastructure speculation, an rise in family venture in genuine bequest and development industry.
A wide variety of materials are utilized within the development industry. When considering their application in divider components, customary burnt clay bricks are the foremost basic building materials for houses development. Be that as it may, the quick development in today's development industry has obliged the gracious engineers in looking for a modern building technique that will result in indeed more noteworthy economy, more effective and solid as an elective for the ordinary brick. In a tropical nation like India the burnt clay brick is the foremost fundamental building fabric for development of houses. It is detailed that the prerequisite of bricks for development movement sums to be more than 140 billion numbers yearly.
1.1 The aim of study
To do experimental study of light weight interlocking brick based on mixed material variation design.
1.2 The objective of study
1. To produce light weight interlocking brick. 2. To determine optimum compressive strength of light weight interlocking brick. 3. To determine water absorption of light weight interlocking brick. 4. To determine density of light weight interlocking brick.
1.3 The scope of study
The proposed interlocking light weight bricks allows for a quick and cost effective construction. It’s over comes the conventional clay bricks, which couldn’t bear the stress as they cannot transfer the seismic load across the structure equivalently. And act as a good earthquake resistance structure. It’s allowed exposed brick wall construction and gives good aesthetic view, improved constructability, performance and cost as well resulting to alternative for sustainable construction industry.
2. METHODOLOGY
2.1 Introduction of Methodology
The first step in studying is to schedule your study time. The activities were planning due to time required to make sure the product will be completed in schedule time. The point of the technique inquire about is to attain the destinations of consider as expressed in this chapter.
2.2 Material of Light Weight Interlocking Brick
In our study, we used three basic materials in order to produce the light weight interlocking brick that are Ordinary Portland cement (OPC), fly ash, fine aggregate (dust). These materials were fundamentally characterized in compliance with Indian standards. All materials are available locally in Maharashtra.
2.2.1 Cement
Cement is a material used in construction that binds other materials together by setting, hardening, and adhering to them. Ordinary Portland cement of 53 grade were used satisfying all the IS: 12269-1987 requirements was used in making the bricks.
2.2.2 Fly Ash
One of the industrial wastes is fly ash, fine-grained gray produced by burning coal, which is recovered from the final combustion of coal. In this study, Class F fly ash was used, and it contains low content of CaO and exhibit pozzolanic properties and having specific gravity of fly ash is 2.76 was used. The fly ash was collected in dry state from the Paras Thermal power station.
2.2.3 Stone dust
The finest kind of crushed stone is called stone dust, or stone screens. Stone dust creates a hard, water-resistant surface when applied alone. When used with a larger stone it acts as a binding agent because of its ability to form a strong, non porous surface. Powder form stone dust available locally used in moderate quantity for preparing the bricks. Its small size allows the bricks to maintain their correct form, especially the corners and edges.
2.2.3 Water
Plane Ordinary tap water was used for both mixing the constituents of the bricks as well as for the curing of bricks. Water requirements depend on the following factors:
- Production – water consumption depends on water-to-cement ratios
- Curing – depends on duration in days (minimum 7 days). The potential strength of any Ordinary Portland Cement (OPC) product will be maximized by curing under moist conditions. The highest rate of reaction (hydration) between cement and water takes place in the first three to seven days, which therefore require proper curing/attention (BS 5328-1:1997 and BS 5628 3:2005).
2.3 Material of Light Weight Interlocking Brick
The second steps in our project methodology, we used Hydraform shape which is the simplest type of interlocking brick see in fig. 1 in shape, when interlocked makes a tongue and grooved joint at the sides and top and bottom. Being free to slide along the course horizontally, it can be pushed along to achieve tighter perpends (vertical joints) see in fig. 2. Hydraform brick is moulded by pressing along its length from the ends. It is also a solid brick, The length, wider and thicker of the interlocking brick in size of (300 x 150 x 125mm). The stability of the wall built from the Hydraform bricks is not provided by the locking mechanism but by the width and weight (massiveness) of the brick. Moreover the compression must be sufficient to allow a fresh brick to withstand the squeezing forces occurring when it is manually moved from machine to the curing area.
2.4 Mix design for Light Weight Interlocking Brick
In this experimental study two standard specimen as per IS 2250:1981 was suitably designed for M5 grade, M3 grade of mortar and four sample mix design were used to identify the optimum mix design for Light weight interlocking brick. The mix design was done based on the proportion of various
materials like cement, fly ash and stone dust. The first standard specimen sample mix design for (1:6) contains 16.67% of cement and 83.33% of stone dust. This type of interlocking brick is named as S1. The second standard specimen sample mix design for (1:8) contains 12.50% of cement, 87.50% of stone dust. This type of interlocking brick is named as S2. The standard specimen mix design is given in Table no.1
**Table -1: Standard Interlocking brick Mix Designs**
| Sample Designation | Grade | Mix Design | Material Percentage |
|--------------------|-------|------------|--------------------|
| | | | Cement | Stone Dust |
| S1 | M5 | 1:6 | 16.67% | 83.33% |
| S2 | M3 | 1:8 | 12.50% | 87.50% |
The first sample mix design for (1:3:4) contains 12.50% of cement, 37.50% of fly ash and 50% of stone dust. This type of interlocking brick is named as A1. The second sample mix design for (1:3.4:3.6) contains 12.50% of cement, 42.50% of fly ash and 45% of stone dust. This type of interlocking brick is named as A2. The third sample mix design for (1:3.8:3.2) contains 12.50% of cement, 47.50% of fly ash and 40% of stone dust. This type of interlocking brick is named as A3. And fourth sample mix design for (1:4.2:2.8) contains 12.50% of cement, 52.50% of fly ash and 35% of stone dust. This type of interlocking brick is named as A4. The sample mix design is given in Table no.2
| Sample Designation | Mix Design | Material Percentage |
|--------------------|------------|--------------------|
| | | Cement | Fly Ash | Stone Dust |
| A1 | 1:3:4 | 12.50% | 37.50% | 50.00% |
| A2 | 1:3.4:3.6 | 12.50% | 42.50% | 45.00% |
| A3 | 1:3.8:3.2 | 12.50% | 47.50% | 40.00% |
| A4 | 1:4.2:2.8 | 12.50% | 52.50% | 35.00% |
### 2.5 Casting of Light Weight Interlocking Brick Specimen
After the collection and proportion of materials casting process is carried out. For casting of light weight interlocking brick the cement, fly ash and stone dust were used in varying mix proportions given in table no. 4 and table no. 5. The materials are proportioned by the weight batching. A pan mixer and hydraulic machine used for casting the bricks see in fig. 3. The mixer was thoroughly cleaned before the bricks were cast. To achieve the required workability, dry cement and stone dust were added, well mixed, and then clean drinking water was added. Following the pouring of the brick mix in a hydraulic machine, the bricks were removed and placed on a flat platform beneath the shed to dry. The blocks have geometric size of 300mmx150mmx125mm. This machine produces solid blocks of laterite composition mainly and stabilized with cement material.
### 2.6 Curing
Hardening of any concrete products requires the continued presence of water in the brick to enable cement to complete hydration process. After casting the bricks are allowed for surface dry for 24 hours in direct sunlight. Then cured normally for 28 days by spraying water four to five times in one day see in fig.4.
### 3. TESTING
The casted interlocking bricks were taken out from water one day prior to the testing and were tested for compressive strength after 28 days.
#### 3.1 Dimensions Test
The dimensions of the interlocking brick specimens measured by an Vernier Caliper on day 28 see in fig. 5. As per IS:1077:1992, tolerance for brick when measured 20 bricks by arranging one beside another for length, width and height separately is (40mm) the result of bricks dimensions test. The brick passes the dimension test if its dimensions are within tolerance; if not, it fails.
3.2 Weight Test
Weight of different proportions of interlocking bricks is measured with the help of digital weighing balance machine see in fig. 6.
**Fig -6:** Digital Weighing Balance Machine
3.3 Water Absorption Test
The bricks, when tested in accordance with the procedure laid down in IS 3495 (Part 2): 1992 after immersion in cold water for 24 hours, water absorption shall not be more than 20 percent by weight up to class 12.5 and 15 percent by weight for higher classes. The test specimens shall be completely immersed in water at room-temperature for 24 h. The specimens shall then be weighed, while suspended by a metal wire and completely submerged in water. They shall be removed from the water and allowed to drain for three minute by placing them on a 10 mm or coarser wire mesh, visible surface water being removed with a damp cloth and immediately weighed (W2). Subsequent to saturation, all specimens shall be dried in a ventilated oven machine at 100°C to 115°C for not less than 24h see in fig.7 and cool the bricks to room temperature and weight (W1). Formula to calculate water absorbed by the bricks, using following formula.
\[
\text{Water absorption in \% by weight} = \left( \frac{W2 - W1}{W1} \right) \times 100
\]
3.4 Compressive Strength Test
The specimen is then placed between plates of compression testing machine see in fig.8. Load is applied axially at uniform rate till failure. Maximum load at failure divided by average area of bed face gives us compressive strength.
\[
\text{Compressive strength in N/mm}^2 = \frac{\text{Maximum load at failure in N}}{\text{Average area of the bed faces in mm}^2}
\]
**Fig -8:** Specimen placed in CTM
3.5 Brick Density
Three bricks taken at random from the samples shall be dried to constant mass in a suitable oven heated to 100 C to find the Mass of brick, in kg approximately. After cooling the bricks to room temperature, the dimensions of each brick shall be measured in meter (to the nearest millimeter) and the overall volume computed in cubic meters. The brick shall then be weighed in kilograms and the density of each brick is calculated.
Density of brick (kg/m3) = \left( \frac{\text{Mass of the brick in kg}}{\text{Volume of specimen in m}^3} \right)
4. RESULT AND DISCUSSION
Different tests were conducted to study the behavior of interlocking brick and standard brick. This covers the behavior of specimen under each test.
4.1 Dimensions Test
The dimensions of the each interlocking brick specimens are measured to the nearest millimeter by an Vernier Caliper on day 28.
4.2 Weight Test
Weight of interlocking bricks are measured to the nearest gram and may be varied based on the different proportions of fly ash and stone dust.
4.3 Water Absorption Test
Graph -1: % of Water Absorption v/s % of Fly ash
It is observed in the graph shown in graph 1 the water absorption of bricks increases with the increase in fly ash content replacing stone dust. Among the four samples of interlocking brick A1, A2, A3 and A4 Compared with standard brick A1 sample mix design bricks absorb 11.9% of water only; it has less water absorption property. The average water absorption of A1 sample of interlocking blocks is found to be 11.9%, which is satisfied as per IS: 3495 (Part II) – 1992 which specifies the bricks should not absorb more than 20% of water and classified as 1st class bricks.
4.4 Compressive Strength Test
Graph -2: Compressive Strength N/mm² v/s % of Fly ash
The graph of average compressive strength of interlocking brick shown in graph 2 decreases with the increase in fly ash content replacing stone dust from 37.5% to 47.5%. The average compressive strength of A1 sample of interlocking brick is found to be 7.1 MPa, which is satisfied the minimum average compressive strength of standard sample S1 is to be 5.1 MPa. The average compressive strength of interlocking brick A1 sample which is 7.1 MPa which is found to be greater than the compressive strength of standard bricks S1 which is 5.1 MPa.
4.5 Brick Density
Graph -3: Density kg/m³ v/s % of Fly ash
It is observed that the water absorption and density are closely related to each other. As the water absorption of interlocking brick increases with the density of interlocking brick decreases. The graph of average density of interlocking brick shown in graph 3 decreases with the increase in fly ash content replacing stone dust. The average density of interlocking brick A3 sample is 1497.5 kg/m³ which is found to be lesser than the compressive strength of standard bricks S1 which is 1951.4 kg/m³. The density of interlocking bricks...
was found to be 23 percent lesser than that of the standard bricks.
5. CONCLUSIONS
Based on the experimental investigation reported in this study, following conclusions are drawn:
1) The dimensional test is conducted on light weight interlocking bricks and standard interlocking bricks. The dimensional errors are found to be relatively small and under tolerance in interlocking bricks as per IS -1077 (1992).
2) The water absorption of light weight interlocking bricks increases with the increased in % of fly ash content as compared to standard interlocking bricks but replacement of fly ash above 47.5%, water absorption decreases.
3) The average compressive strength of light weight interlocking bricks decreases with the increased in % of fly ash content as compared to standard interlocking bricks.
4) The density of light weight interlocking bricks decreases with the increased in % of fly ash content as compared to standard interlocking bricks but replacement of fly ash above 47.5%, density of interlocking bricks increases.
REFERENCES
[1] Mutune Samson Muinde, "An Investigation Into The Issues Influencing The Use of Interlocking Stabilised Soil Blocks In Kenya, A Case Study of Siaya County. A thesis report, University of Nairobi or any other University, 2013.
[2] Fajar Putra Mobiliu, Mursalin, Muhamad Jahja, Dewa Gede Eka Setiawan, Nugraha Oktofelly Dewaputu, Fachrul Latief, Nancy Noviana Lantapon, "Compressive Strength and Water Absorption Capacity on Brick Interlock with Fly Ash Addition," Computational and Experimental Research in Materials and Renewable Energy (CERiMRE), 2023, Volume 7, Issue 1, pp. 64-77.
[3] Santosh Bharathy.V, Arun Kumar.S, Sanjay.R, S.Karthik Raja, "Strength Characteristics Comparison Of Flyash And Acacia Ash Interlocking Bricks," International Journal of Pure and Applied Mathematics, 2018, Volume 119 No. 15 2018, pp. 1391-1402.
[4] G.Pavithra, R.Priyanka, L.Sahana Sree, V.Sarumathi, U.Sathish, K.S.Sowmiya, "Experimental Analysis of Interlocking Bricks by Using Sewage Sludge And Fly Ash," SSRG International Journal of Civil Engineering (SSRG-IJCE) – Special Issue ICETSST - April 2018.
[5] Fatheali A Shilar, S.S.Quadri, "Performance Evaluation Of Interlocking Bricks Using Granite Waste Powder," International Journal of Engineering Applied Sciences and Technology, 2019 Vol. 4, Issue 2, ISSN No. 2455-2143, pp 82-87.
[6] Amin Al-Fakih, Bashar S. Mohammed, Mohd Shahir Liew and Wesam S Alaloul, "Physical Properties of The Rubberized Interlocking Masonry Brick," International Journal of Civil Engineering and Technology (IJCIET) Volume 9, Issue 6, June 2018, pp. 656–664.
[7] R.Sayanthan, S.Ilamaran, Mohamed Rifdy and S.M.A Nanayakkara, "Development Of Interlocking Lightweight Cement Blocks," Special Session on Construction Materials & Systems, 4th International Conference on Structural Engineering and Construction Management 2013, Kandy, Sri Lanka, 13th, 14th & 15th Dec. 2013.
[8] L.Arun raja, M.Arumugam, K.Malaichamy, "Mechanical Properties Of Light Weight Bricks Using Perlite And Lime Material," SSRG International Journal of Civil Engineering- (ICRTCETM-2017) - Special Issue - April 2017.
[9] Heyder Ahmed, Sugini, "A study on interlocking brick innovation using recycled plastic waste to support the acoustic and thermal performance of a building," Jurnal Teknik Arsitektur, Volume 6 Issue 3, Dec. 2021.
[10] S. Kavipriya, K.J. Jegidha, Dr.S.Suresh Babu, "Experimental Study On Light Weight Interlocking Blocks," International Journal of Engineering and Techniques - Volume 7 Issue 2, March 2021.
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AN UMBILICAL CORD TO AFRICA
“We know the issues, now it’s about solutions. We’re hoping to mobilise more women, but also men who are champions.”
Emma Orefuwa, Honorary Graduate.
A RESEARCH POWERHOUSE
World-class research is taking place across every area of Liverpool School of Tropical Medicine.
SILVER ATHENA SWAN AWARD
LSTM was awarded the Athena Swan Silver Award for its ongoing work to promote gender equality, one of only 21 institutions in the UK to be awarded.
“There could and should be a better future for those paying the massive burden of tropical diseases.”
125 Campaign: Time to Shift the Power
125 YEARS
1898 - 2023
LSTM
LIVERPOOL SCHOOL OF TROPICAL MEDICINE
I would like to extend congratulations on behalf of everyone at LSTM to our graduating Class of 2022, and also our Classes of 2020 and 2021 for whom the COVID-19 pandemic prevented in-person ceremonies. We celebrate all their successes and will continue to follow their futures with keen interest.
This year has been a very busy and productive year for LSTM, and we were delighted to be ranked second for the impact of our research in the latest Research Excellence Framework (REF 2021), the UK’s system for assessing the quality of research in higher education. The results reflect the high-quality work undertaken across the institution, as well as within our numerous partnerships across the world.
Our research informs much of the teaching and education activities within LSTM, and it is important that we can demonstrate the benefit of those endeavours to the populations that we serve. Just one example of how our activities have real-world impact is our work with tsetse flies. Earlier this year the World Health Organization (WHO) declared Uganda free from Gambian sleeping sickness after the scale up of LSTM developed Tiny Targets, a vector control tool designed to reduce the population of the tsetse fly, which carry the disease. You can read full details about the impact of our work on Pages 6 & 7.
As we approach our 125th Anniversary in 2023, we are considering LSTM’s legacy as an institution whose founding is linked to colonial trade and exploitation, and the shape of the organisation for the future. Following the release of our first Race Equity Action Plan, we are committed to better understanding the experiences of, and acting to, eliminate the barriers that exist for staff, students and partners.
In October we were delighted to announce that we were awarded the Athena Swan Silver charter mark, for our ongoing work to promote gender equality. Earlier in the year we also signed up to an equitable authorship statement, to ensure that our partners, particularly those overseas, are credited for all the work that goes into the research that we carry out.
As a major global research institution, we have the power to tackle systemic injustice and inequity. Our future therefore lies in working through equitable partnerships around the world to tackle the major health challenges facing humanity. That is why we have launched a major 125th Anniversary Campaign, which will support a bold investment in this vision – you can read more about this on pages 2 & 3. I hope all our alumni, friends and supporters will join me in supporting this important initiative.
Professor David Lalloo
Director
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For over 25 years Malawi Liverpool Wellcome Trust (MLW) has continued to be a vital global partnership hub for LSTM. It is the only Wellcome Trust-funded research programme in a low-income country.
MLW was founded in 1997 with a grant from the Wellcome Trust, under the leadership of LSTM Professor and Honorary Graduate (2019), the late Malcolm Molyneux. MLW is a partnership between the Wellcome Trust, LSTM and the University of Liverpool and the Kamuzu University of Health Sciences to conduct high quality research to benefit health. Initially its focus was on severe malaria in children and HIV, but it has expanded over the last 25 years to include research leadership in Salmonella, meningitis, Rotavirus, Pneumococcus, Tuberculosis, and lung health. This work aims to impact positive health outcomes for communities in Malawi and other sub-Saharan African countries.
MLW has pioneered major interventions and managed large clinical trials, including a four-year trial of a modern rotavirus vaccine in 2011, which cut infant deaths from diarrhoeal disease in Malawi by 39%. Their work on HIV self-testing led to the first demonstration of feasibility and safety of this method, which ultimately influenced international HIV testing guidelines and improved access to HIV care and retroviral therapy worldwide.
MLW aims to expand its current work in six research groups: infection biology, vaccines, population health, experimental & clinical medicine, social science, and maternal, neonatal & child health over the coming years, with most run by resident Malawians, alongside international scientists. CREATOR building, opening in Blantyre in January 2024 aims to support this expansion by increasing research capacity by 30%.
Despite this huge success, there is still a critical need across the region for improved training and clinical research capacity. The average life expectancy in Malawi is 65.6 years (2019) compared to 80.9 in the UK. Since 2018, Malawi has 0.04 doctors and 0.44 nurses per 1,000 population.
This is essential for addressing the many emerging health threats facing Malawi and the world, but also to combat the persistent issue of ‘brain drain’ in a country with one of the most under-served patient populations in the world. There is a shortage of clinical specialists within Malawi who could provide training supervision, and a shortage of post-graduate training opportunities.
LSTM’s 125th Anniversary Campaign aims to support the next phase of MLW’s growth by investing in scientific capacity and leadership.
Find out more by visiting lstmed.ac.uk/125
The Liverpool School of Tropical Medicine was the first of its kind in the world – beginning our fight against disease more than a century ago.
Now, as we approach our 125th Anniversary, we’ve set a new course for the next 125 years – putting partnerships and equity at the heart of a mission to fight global health inequality.
LSTM was founded by the industrialists who prospered in colonial Britain through the global significance of Liverpool’s port. But now our goal is to end health inequality and social injustice by shifting the power.
Our vision is to take LSTM from being a UK organisation, which operates overseas, to a global research institution headquartered in Liverpool. It is a fundamental culture shift for us, and one which requires bold investment.
That is why we are launching our 125 Anniversary Campaign to support the development of scientific and health leadership in Sub-Saharan Africa and Asia.
These regions bear a disproportionately high burden of disease, but scientific priorities have historically been driven by those far removed from the challenges they face. It is time to shift this power.
We will establish a Global Leaders’ programme, with new research leadership positions at five key African hubs - in Malawi, Kenya, Cameroon, Zimbabwe and Tanzania. They will become part of a powerful network of multidisciplinary researchers, tackling some of the most pressing global health issues.
We will support a Global Fellowships Programme, where 25 of the most exceptional and promising researchers will access funding, mentoring and development to accelerate their careers.
And, we will fund many more Masters and PhD students – creating the kinds of extraordinary graduates who have already led the development of country strategies for Ebola and COVID-19.
In Liverpool, we will be part of this global research network with a new in-patient clinical trials facility – the largest in the UK – supporting the development of new drugs and vaccines which have global application.
All these initiatives will come together in a new Institute in Resilient Health Systems – a virtual entity designed to drive investment into research that is not just for the benefit of low resource countries, but led by them.
You can help us to make our vision a reality by supporting the Liverpool School of Tropical Medicine’s 125th Anniversary Campaign.
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LSTM celebrates its 125th anniversary by launching a campaign to help build resilience, skills, and capacity in lower income countries at the House of Commons.
When her Master’s supervisor suggested that she go to Nigeria, her father’s homeland, to conduct research on lymphatic filariasis, London-born Emma Orefuwa was sceptical. However, that supervisor understood the power of connecting with your ancestral country; an understanding that Emma has come to share. It led to her setting up the Pan-African Malaria Control Association (PAMCA), the leading authority on the control and elimination of vector-borne diseases in Africa, and to her being awarded an honorary degree by LSTM.
Family and heritage have played an important role in Emma’s education and success. “I’ve got a Nigerian father, and Nigerians are very big on education. Also, my maternal grandma was a very strong matriarch, very resilient.”
“A TURNKEY MOMENT…”
A degree in Biochemical Sciences was followed by a Master’s in Biology and Disease of Control Vectors, during which Emma undertook the research in Nigeria that would so radically alter her perspective. She was supervised by Professor Chris Curtis, London School of Hygiene and Tropical Medicine, who became her friend and life-long mentor.
“He inspired me - he was very keen in almost ‘repatriating’ those of us of African heritage back to our countries of origin to do good… Chris was a very supportive individual and really allowed me to see the potential of myself… PAMCA is a legacy of him – a vision of Africans contributing to addressing their own problems.”
An internship at the European Mosquito Control Association led to Emma helping to coordinate their conference in Turin in 2009. It was there that she gravitated towards African entomologist, Professor Charles Mbogo, who was to become her co-founder of PAMCA.
“Meeting Charles was amazing because he was the first African entomologist that I’d come across. Up until then I’d learned about vector-borne diseases from older white men, and it was just amazing to see that we do have African experts.”
The two bonded over their shared concerns, but also optimism, for the future of science and control of vector-borne diseases in Africa.
“It was clear that African expertise wasn’t being showcased. There was a power imbalance in terms of Africans having the voice to discuss the innovations and solutions they thought were necessary for combating vector-borne diseases in their continent, Charles had been thinking about the need to encourage more Africans to be involved in research. That’s basically how the Pan-African Mosquito Control Association came about.”
Today, PAMCA is a non-profit membership organisation headquartered in Kenya. It is a collective of vector biologists, public health professionals, policymakers, NGOs, industry and civil society members who have an interest in combatting vector-borne diseases on the continent. As well as chapters in 19 countries, PAMCA also has four Regional Centres of Excellence (RCE) - hubs of expertise which allow countries to utilise infrastructure, knowledge and resources to tackle disease through capacity building and knowledge transfer.
Current programmes include evidence generation to inform National Malaria Control Programme strategies in Burkina Faso, Cameroon and Tanzania, and training staff to identify a new malaria vector, carry out surveillance and collect data at the invitation of the Djibouti government. Africa CDC and WHO are also on board. PAMCA is growing – both in numbers and influence – and Emma is obviously proud of the organisation and her contribution to its success.
A two-day workshop involving women from 25 countries generated a list of problems but also recommendations which Emma hopes will translate into action and policy change.
“We know the issues, now it’s about solutions. We’re hoping to mobilise more women, but also men who are champions. We’ve launched a mentorship programme and started training. One idea is getting donors involved in an accountability mechanism.
This programme is still in its infancy but is already being described by those involved as ‘transformational’, providing a community for sharing, networking and giving women opportunities to advance their careers in vector control.
A MESSAGE FOR LSTM GRADUATES
What advice does Emma have for those embarking on their own careers?
“Think about everybody who has a stake. Why are you doing this, what are you doing, who does it serve? Are those people involved in the co-development of any activities? We often specialise in one area and become slightly myopic in our vision and what we think will make an impact. Everybody has a skill, everyone has a worth, and it really does take a village, so think outside the box.”
This need for meaningful connectivity ties back to that early advice from her Master’s supervisor:
“When I’m working on African initiatives there’s a different level of drive. It’s not just a job. It’s serving your own people, your community, and that’s where the passion comes from. There’s been many difficult junctures with PAMCA, but what’s kept me going is that connectivity, almost an umbilical cord to the continent. And that is something that really should be capitalised on more by those of us working in the UK.”
WOMEN IN VECTOR CONTROL
This new programme is based on PAMCA members’ own experiences of sexism, discrimination and sexual harassment – both professionally and in the home. Emma explains.
“We kept talking about women not being visible, being overlooked for positions, and living in a very patriarchal space, and this translates to society as a whole. There’s much talk about eliminating vector-borne diseases, but it’s not going to work if half the population aren’t involved. And how do we encourage women to pursue the sciences?”
Global scale-up of HIV self-testing
About 20 million people do not know that they are living with HIV-infection. If the disease is to be treated and eradicated, it is essential that infected people know their HIV status so that they can make informed decisions about their health needs. LSTM are working with the WHO on a Self-Testing in Africa (STAR) initiative which aims to stimulate the market for HIV self-test kits in Southern Africa. LSTM staff developed and rigorously evaluated delivery models in Malawi and a total of 88 countries now have HIV self-testing policies, and rapid scale-up has increased testing coverage among vulnerable, underserved and key populations worldwide.
Treatment and control of malaria in pregnancy
Malaria in pregnancy is a leading cause of adverse pregnancy outcomes. Research led by LSTM contributed directly to improved World Health Organisation (WHO) and endemic country policies and practices in sub-Saharan Africa and Asia-Pacific. Specifically, ministries of health in 36 African nations are now implementing a more effective malaria prevention strategy improving the outcome of approximately 32,000,000 pregnancies at risk annually and thereby the lives of mothers and their infants.
Health Systems and Workforce Strengthening Unit
Not all impactful research looks at disease. LSTM’s Health Systems and Workforce Strengthening Unit has been engaged in several projects which seek to strengthen health systems and make best use of available human resources.
While efforts are in place to address the global shortage of health workers, improving health workforce performance has been neglected. PERFORM2Scale sought to address this problem by scaling-up a previously successful management strengthening intervention (MSI) in Ghana, Malawi and Uganda - over five years. In Uganda, the team successfully integrated the MSI into the new nationwide Quality Improvement Framework which will have huge impact on the quality of health services throughout Uganda. The team learned an enormous amount about the facilitators and obstacles to successful scale-up which can be applied in other contexts.
Reducing malaria prevalence in Africa using innovative bed nets
Insecticide-treated nets (ITNs) are the main malaria prevention tool in Africa, but their efficacy is being impacted by mosquitoes’ resistance to the chemical used – pyrethroid. LSTM research which pinpointed the underlying molecular mechanisms of resistance has led to new classes of ITNs that can control resistant mosquito populations. By 2020, 13 of the 23 malaria-endemic countries in Africa included these new classes of nets in their national distribution campaigns, protecting more than 35,000,000 people. A large-scale trial in Uganda found that use of this new net class reduced malaria prevalence by 27%.
The Ministry of Health in Uganda and partners, including LSTM, are celebrating the elimination of Gambian sleeping sickness following the recent announcement from the World Health Organisation (WHO).
The milestone was marked with a ceremony in Kampala, Uganda, on the 21st October. The elimination of Gambian HAT (gHAT) has been achieved through an integrated approach with screening, treatment and vector control. The medical efforts have been implemented through the Ministry of Health, with support from Medicine Sans Frontières (MSF), Foundation for Innovative New Diagnostics (FIND) and WHO. Vector control has been implemented through the Coordinating Office for Control of Trypanosomiasis in Uganda (COCTU) with support from LSTM.
Until recently, vector control for Gambian HAT was not widely used because the available tools were very costly and logistically demanding to deploy, this all changed with the development of Tiny Targets. An international team of researchers from multiple research institutions across Europe investigated the host-seeking behaviour of riverine tsetse, the vectors of gHAT. They discovered that in contrast to other tsetse species, smaller sized targets were more efficient at attracting riverine flies. Tiny Targets were first introduced in Uganda in 2011 in small scale trials, before being scaled-up to a full control programme in partnership with COCTU in 2014. The project covered 2,500km² in five districts in northwest Uganda, and there was further scale-up from 2017 with expansion to two additional districts.
The partnership between LSTM and COCTU on the Tiny Targets programme has made a significant contribution to the sleeping sickness elimination efforts.
Vector Biologist and Programme Manager, Andrew Hope, explains:
WE SAW AN 80% REDUCTION IN THE NUMBER OF TSETSE FLIES, ONCE TINY TARGETS HAD BEEN INTRODUCED. OUR MODELLING WORK SHOWS THAT TINY TARGETS HAVE REDUCED gHAT INCIDENCE BY 25% IN NORTHWEST UGANDA.”
The Tiny Targets team deployed these targets twice a year along the riverbanks, with a density of 20 targets, per kilometre. At some stages in the project the team was putting up about 35,000 targets a year, which was a huge logistical operation.
Andrew Hope thinks these efforts were well worth it: “I think this announcement is really important, it’s an incredible achievement for Uganda. The Ministry of Health and COCTU should be very proud of this success. It is also a wonderful moment for my colleagues at LSTM who have been part of this work and I particularly congratulate Professor Steve Torr who has led the programme at LSTM for most of the last decade.”
Professor Torr added: “Other countries using Tiny Targets have also eliminated gHAT as a public health problem (Cote d’Ivoire) or are on track to do so (Chad, Guinea, DRC). Looking ahead, we are working with many partners to achieve WHO’s goal of eliminating transmission of gHAT by 2030.”
The announcement by WHO follows decades of work to eliminate the disease. Large numbers of gHAT cases were recorded at the beginning of the 21st century and WHO prioritised the control and elimination of gHAT in countries where the disease was endemic. Case numbers decreased, eventually falling below 1000 annually for the first time in 2018.
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When most people in the global north fall ill with what is often referred to as ‘a stomach bug’ they feel rotten for a few days but quickly return to health without requiring antibiotic treatment. This is not the case in many parts of sub-Saharan Africa, including Kenya, where a bout of something like non-typhoidal Salmonella can be fatal, especially among young children. The question that challenged the young Sam Kariuki was why this was the case – was there something different about food-borne diseases in Kenya?
This fascination with diseases and how they are transmitted and treated has been a life’s work for Sam which has led to him being awarded an honorary degree by LSTM. He came to epidemiology by way of a degree in Veterinary Medicine and a Master’s in Pharmacology and Toxicology, both from the University of Nairobi. Early plans to study human medicine were abandoned with the realisation that, ‘I never like to work at night, and in veterinary medicine nobody would wake me up to go and do clinical duties at night.’ Plans to become a vet also disappeared with the realisation that he really wanted to focus on research.
This early exposure to both human and animal medicine gave rise to an understanding in Sam that the two were inextricably linked and fuelled a curiosity to explore that connection. This was at a time when the concept of One Health (the recognition that the health of humans, animals, plants, and the wider environment are interdependent) was not widely held.
He was also driven by a desire to understand how medicines work, what is happening when they do not work, and how we can intervene. His interest in antimicrobial resistance (AMR) – when the organisms that cause infection evolve to survive antibiotic treatments – was also born. It is an area of study that has been brought into sharp focus by COVID-19.
“Probably the scariest things facing us are diseases emanating from the animals we interact with. In my institution [KEMRI] we have put an emphasis on pathogen discovery… to be able to detect early and understand the pathogens of pandemic potential.”
ACADEMIC SUCCESS
After securing a post at the Centre for Microbiology Research at KEMRI (Kenya Medical Research Institute) Sam worked with a team looking at AMR and secondary infections in HIV. After three years he had impressed his supervisor enough to receive a call to follow him to LSTM to undertake a PhD.
So began a relationship which benefitted – and continues to benefit - both parties, but which has had an even greater impact on the people of Kenya and the surrounding region.
Throughout his academic career, Sam has been fascinated by technology and its potential to help tackle certain diseases, particularly those he saw at home in Kenya. He says of his PhD studies:
“I really wanted to work towards understanding how enteric bacteria, especially Salmonella, were causing such severe disease in young children yet in the western world they were just causing self-limiting diarrhoeal disease.”
His work to address this question - utilising PCR technology and whole genome sequencing - revealed that Kenya was actually dealing with a very specific strain of Salmonella typhimurium (ST313) that was different from that which causes disease in developed countries. His paper was published in the Journal of Medical Microbiology and through that study Sam was awarded the Pfizer Award for the Best African Scientist of the Year in 2012. It was the first of many awards and accolades.
Around this time Sam was also successful in securing funding from the Wellcome Trust for a post-doctoral fellowship on invasive non-typhoidal salmonellosis, which is endemic in sub-Saharan Africa. Sam hypothesised that person-to-person, rather than zoonotic transmission (from animals), was playing a major role in the disease’s transmission and, despite scepticism from some scientists, this has proven to be correct.
Since then, his work and reputation have blossomed. Sam has researched and published extensively on the epidemiology and genomics of AMR and the surveillance of food-borne enteric pathogens. This work has contributed extensively to policy change in the treatment and management of those infections and in understanding AMR. His work has undoubtedly helped prevent much illness and saved many lives.
Today, Sam is the Director of Research and Development and Acting Director General at KEMRI, a Fellow of the African Academy of Sciences, an honorary faculty member at the Wellcome Sanger Institute, and a visiting Professor of Tropical Microbiology at the University of Oxford. He is also a World Health Organization consultant providing technical advice around food safety, AMR and infectious disease surveillance.
Looking to future collaborations with LSTM, Sam hopes that some of the technologies and expertise developed at the School can be transferred to the field in Kenya, improving disease diagnostics, surveillance and management. He also has hopes for the young scientists in both institutions:
“We are looking towards the kind of collaboration where we host the students from LSTM and some of our students can spend time in Liverpool - that would really be enriching for our young scientists in terms of experience and outlook in a global sense.”
MENTORING THE NEXT GENERATION
Despite these accolades and titles, Sam remains committed to the science and to the young scientists in his charge. He says:
“My motivation was always my desire to be able to mentor young people and to be able to form a core group of scientists that research on antimicrobial resistance and enteric diseases epidemiology. It inspires me that they will probably become a mentor to someone else, and be able to build that critical mass of scientists and really help the country realise its potential in research, but also be a resource for the region.”
Over the years, many students and junior staff passed through his lab at KEMRI; a facility that the World Health Organization recognises as a centre of excellence. Almost all have gone on to join institutions, either in Kenya or abroad, where they are carrying the scientific baton.
AN ENDURING RELATIONSHIP
Sam’s time as a PhD student at LSTM was one which he recognises as providing the foundations for his future success.
“That was the beginning of my post-doctoral and research career journey – the genesis of me being more independent in my research. I think my career pathway wouldn’t have happened if I hadn’t had a proper grounding at my post-graduate level.”
It also proved to be just the beginning. Before leaving LSTM, Sam and LSTM mentor, the late Professor Tony Hart, secured funding to conduct what proved to be a highly-successful enteric diseases One Health programme in Kenya to better understand livestock and human interactions. That work continues today with funding from the UK Department of Health and is still building capacity in epidemiology and surveillance of AMR.
And his advice for those young researchers?
“If you get the opportunity then come into settings like ours and see field conditions as they are. Understand where diseases originate and how they get transmitted. You can never, ever learn that from books or from lectures. And that enrichment sticks with you forever and it keeps you motivated to be able to do the best research.”
Forming a critical part of LSTM’s ambitious 125 Campaign (see pages 2 & 3), LSTM aims to support the most exceptional and promising researchers who have the potential to become leaders in their field. Through this support we will be able to provide funding, mentoring and development to accelerate their careers and support cutting-edge scientific research, with genuine impact for their communities and regions.
**Dr Tinashe Nyazika**
(PhD, Clinical Sciences, 2020)
Tinashe is a medical microbiologist with major interests in host-pathogen interaction, HIV/AIDS and mucosal and viral immunology and biomarker discover. He has strong interests in diagnostic and research skills and a solid understanding of experimental research methods, analyses, and manuscript writing.
**WHAT ARE YOU CURRENTLY RESEARCHING?**
I am a Postdoc for the Liverpool Vaccine group and currently I am the lead microbiologist in largest controlled human infection challenge model (CHIM) in the UK. Our work involves investigating the effect of the 13-valent pneumococcal conjugate vaccine and the 23-valent pneumococcal polysaccharide vaccine on pneumococcal colonisation.
**WHAT ATTRACTED YOU TO THIS AREA OF RESEARCH?**
It’s the love for translational science, the cutting-edge science we are doing as a group and the unique controlled human infection challenge model work, we are doing which helps to accelerates the finding of newer vaccines in a shorter time. The other thing was the comradeship within our team.
---
**Susan Gould**
(DTM&H, 2014)
Clinical Research Associate
Susan’s background is in clinical medicine, most recently working as a registrar in infectious diseases and medical microbiology in Liverpool. After completing a MBChB at The University of Edinburgh, Susan worked in Scotland for a few years before gradually moving further south.
Susan is currently a Medical student funded by the HPRU-EZI and the READ-It group. Her work mostly centres around the transmission of HCIDs in particular aerobiology.
**WHAT ARE YOU CURRENTLY RESEARCHING?**
I worked on the clinical teams caring for patients with Monkeypox within the HCID network in 2018 and 2021. The previous experience in COVID investigations enabled a rapid response to investigating environmental contamination in rooms occupied by patients with monkeypox in May 2022. We adapted our covid protocols for monkeypox and successfully applied for grants from the TPI.
**WHAT IMPACT WILL YOUR RESEARCH HAVE?**
My research will provide and increased understanding of routes of transmission for pathogens can contribute to evidence base from which guidelines for infection prevention and control (IPC) can draw. Effective IPC can help reduce transmission. Understanding what may increase or decrease risk in healthcare settings permits delivery of care while protecting healthcare workers. The findings from our environmental sampling work are applicable to a variety of different settings.
In October 2022, LSTM was awarded the Athena Swan Silver Award for its ongoing work to promote gender equality, one of only 21 institutions in the UK to be awarded.
The Athena Swan Charter is a framework that is used across the globe, to support and transform gender equality in higher education (HE) and research. The charter was originally set up in 2005 to recognise the advancement of careers for women, in science, technology, engineering, maths and medicine (STEMM) roles. It now addresses broad gender and intersecting equality, and their impact on individual and institutional success.
Key successes that contributed to the school winning the award include: increases in numbers of senior female staff; a new anonymous reporting mechanism for bullying and harassment; reductions in our gender pay gap and fixed-term contract use and increased staff retention; greater staff satisfaction with work-life balance and flexibility; an enhanced package of COVID-19 support; career development, especially benefiting female early career researchers; gender equity and improved transparency in promotion and progression; and, gender benchmarks achieved in education.
"Receiving an Athena Swan Silver award is hugely important for LSTM as it recognises our commitment to gender equality. These awards don’t come easily, producing a high-quality submission requires qualitative and quantitative analysis of five years’ worth of data, and an openness to honest, critical self-reflection across the whole organisation. This marks a major milestone for LSTM, and I see it as part of wider culture change – that willingness to face up to challenging issues which were previously not given the credence that they perhaps should have been; its relatively new for LSTM and it is really difficult work."
Our silver submission was also assessed on the action plan that we developed, based on our analysis and self-reflection, for the next five years. The plan lays out actions to address the gender imbalance in senior level roles (63% of LSTM staff are female, yet only 40% of our senior leaders are) and in our management, committees, and the board of trustees. There is also a focus on making sure that we build awareness and trust in systems and processes to deal with bullying, harassment and discrimination and create a culture where these behaviours are not tolerated. We also have actions to enhance the collection and use of data and information on gender, ethnicity, and other characteristics to help us track our progress and feed into future action planning; to understand and address the barriers to men and women’s progression at key career points and to build a more inclusive workplace.
Ultimately the silver award is a key milestone along the path towards creating a better and stronger institution, which benefits from the talents of all individuals, regardless of their gender. I am confident that LSTM will maintain and even accelerate progress as we work towards a Gold award in the coming years.
Edd Crittenden is LSTM’s Animal Technician and Herpetologist at the Centre for Snakebite Research and Interventions (CSRI) and Named Animal Care and Welfare Officer (NACWO). Edd provides specialist care for one of the largest and most diverse collections of venomous snakes in Europe.
I do what I do because...
I have always had a passion and drive to work with animals. My main interest is in the cognitive abilities of animals not seen as ‘intelligent’, behaviour, and welfare. The work I do in CSRI allows me to enhance and constantly learn more about the animals in my care, as well have an impact to the wider world of snakebite envenoming.
How do you want to see the sector change in the next five years?
It is important that we see more collaborations in different areas of science to achieve a common goal, especially with partners that are sometimes overlooked due to lack of experience, or the institution isn’t as recognised on the international stage.
Your proudest achievement at work was...
Either my first venom extraction or getting my NACWO certification, both at age 22! NACWO was a career goal for me and to be offered the position for the institution was a big sense of pride in my work and abilities. Venom extraction, I think that speaks for itself!
The biggest challenge facing global health is...
Access to the appropriate care facilities and medication in more remote areas. Within snakebite it’s not uncommon for victims to spend hours travelling to health clinics that don’t hold the antivenom.
At work I’m always learning that...
Animals will always impress you. Even if you’ve spent countless hours around them, you’ll still be learning more about them daily. My understanding of snake behaviour is constantly evolving, seeing the individual personalities, routines, and behaviour traits in animals is always a highpoint of my career.
If I could go back 10 years and meet my former self, I’d tell them:
Not to put as much pressure on yourself to go the traditional route into academia. Experience in the right fields can be more valuable to future possibilities. You’ll always be learning more and never know it all, embrace that and keep chasing more knowledge and information that interests you.
What is the best part of your job?
Seeing the impact of my work and skills being translated into publications which can go onto helping steer public health decisions in countries where it matters. It’s also nice to see my work in talks, I’ve got pretty good at identifying my dissection style from pictures.
“YOU’LL ALWAYS BE LEARNING MORE AND NEVER KNOW IT ALL.”
What makes you smile?
Finishing a tour of the Herpetarium with people who were terrified of the snakes before coming in and them leaving with a new sense of understanding about the animals they never had before. Doesn’t stop the fear, but the right information can do wonders to overcoming the unknown elements.
Finally, what is your prediction for the future of global health in the years to come?
New technology will have a big impact on the Neglected Tropical Diseases (NTD’s) fields. Things like drones, 3D printing, and cheaper more accessible technology will help us get a better understanding of the world we live in and how we can progress to minimise the impacts of NTDs on communities.
Whitney Mwangi
(MSc Global Health, 2021)
Tell us about your time at LSTM
“My long-term career goal was to attain a MSc in Global Health and Public Policy. LSTM’s MSc Global Health curriculum offered an opportunity to venture into both areas in a way that can advance my professional and educational objectives. It was, a perfect fit. Being part of the programme exceeded my expectations as I had to unlearn several practices, especially social determinants for health, global diplomacy, community mobilisation, and how they all tie into policy-making. The quality of my work has improved overall since I now understand the foundational principles of addressing global health issues and how to apply them.”
What three words do you most associate with your experience of LSTM?
Foundational, Fruitful and Transformative.
Giri Shan Rajahram
(DTM&H 2017)
Tell us about your time at LSTM
“While studying at this world-class institution I was able to gain the skills necessary to address a locally relevant niche in training and scientific knowledge while fully embracing the experience and expertise of world-renowned experts and opinion leaders. Building upon my previous professional and academic knowledge, I was able to leverage peer learning with rich contextual experience, a paradigm shift in understanding perspectives of health systems outside my country. Some of the friendships built at LSTM have lasted well beyond the course, professionally and socially.”
What was your fondest memory from your time in Liverpool?
The charming city and its wonderfully generous people. The passionate fans of Liverpool Football Club, appreciating its legacy. Following the journey of the Beatles from Penny Lane through the Cavern Club and Strawberry Fields.
Dr Sarah Rylance
(PhD, 2020)
Tell us about your time at LSTM
“I first studied at LSTM in 2004, taking the Professional Diploma in Tropical Medicine and Hygiene. 13 years later I returned, seeking a new challenge and a pathway to develop my career in global health, having spent a number of years working clinically. I signed up for a PhD as part of the Doctoral Training Programme, exploring lung health in Malawi, including both epidemiological and clinical research.
I gained valuable experience in research design, developed my communication skills through scientific writing and oral presentations, and strengthened my professional networks. I was awarded my Doctorate in 2020. Following an introduction to the Non Communicable Disease Department at WHO Headquarters, I am proud to say I have relocated to Geneva and now work as the Medical Officer for Chronic Respiratory Diseases. Moving from Blantyre, Malawi to Geneva, in the midst of COVID, seemed like madness, but je ne regrette rien. The opportunity to impact global respiratory health in my daily work is a true privilege.”
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| AP139KDR | Equipped with a galvanized steel wear strip to prolong the life of your shovel | 13.9" | 27.90 |
| NP139KD | Nordic - Designed to clear away narrow surfaces such as stairs, entrances and paved walkways | 13.9" | 19.90 |
| GP110TSKDV | Equipped of a telescopic sturdy handle, this shovel is small enough not to encumber your car but strong enough to help you in case of need. | 10.75" | 20.90 |
## Snow Brushes
| Part No. | Description | Length | Price |
|--------------|------------------------------------------------------------------------------|--------|--------|
| BZ35SBV | Blizzard - ABS ice scraper, aluminum handle, in shelf display, comfort foam grip | 35" | 10.90 |
| G36SBMSV | Garant - EVA foam complete head, in display Clear away snow without leaving scratches with the new Garant snow brush! | 36" | 22.90 |
| G52PSBT | Garant - Pivoting Eva head, display of 12 A technology that is much gentler on the body of your car Telescopic 52" | Telescopic 52" | 33.90 |
## Snow Pushers
| Part No. | Description | Blade Width | Price |
|------------|------------------------------------------------------------------------------|-------------|--------|
| NPP21KD | Nordic - wood handle An ideal product for clearing snow from your asphalt or paving stone driveway | 21" | 19.90 |
| APP21KDR | Equipped with a galvanized steel wear strip to prolong the life of your shovel Nordic - wood handle | 21" | 27.90 |
| NPP26KD | An ideal product for clearing snow from your asphalt or paving stone driveway | 26" | 27.90 |
## Ice Scraper, 7" Blade, 48" Wood Handle, Nordic
- It is equipped with a stamped and tempered steel blade for maximum strength.
## Aluminum Scoop Shovel
- This tool is equipped with a 13" (33 cm) aluminum blade and a 29" (73.6 cm) varnished ash handle.
## Snow Roof Rake, 24" Blade, Telescopic Handle, Garant
- This tool has a light and resistant polyethylene blade that does not damage roofs.
## Big Blade Scraper
- 10" head, durable plastic handle.
## 24" force snow brush
- Molded contour grip and FORCE™ blade ice chippers to cut through thick ice.
## 26" Cool Force Snowbrush
- Curved handle and foam grip for ergonomic and comfort design.
## 36" Telescoping Snow Broom
- 23 to 36" handle, 7" brush/squeegee combination head
- Highest quality and most economical price.
## Long Reach Pivot Head Sport Telebroom with 10" Head
- Foam comfort grip handle, unbreakable ice ripping scraper and a large surface pivoting brush head for moving snow.
## 35" Maxx Snow Broom
- Strong ice scraper and thick, full brush
- Extra-long, lightweight aluminium pole.
## 50" Telescopic Crossover Snowbroom
- Push button pivoting head can be used as a brush or a broom
- Quick locking handle extends reach up to 50-in
- Wide scraper blade removes frost and ice easily.
**MÄKTIG**
**Nitrite Dipped Winter Gloves**
- Acrylic inside liner for warmth
- Sandy Finish Texture for grip
- Polyester Nitrite 15 gauge outside liner.
| Part No. | Size | Price |
|------------|------|-------|
| 903046-M | M | 7.39 |
| 903046-L | L | |
| 903046-XL | XL | |
| 903046-XXL | XXL | |
**Winter Leather Fitter Gloves**
- Premium cowhide leather provides quality and durability
- 600 g Extra plush pile liner for added warmth
- High quality rubberized cuff.
| Part No. | Size | Price |
|--------------|------|-------|
| 9030943-XL | XL | 11.90 |
| 9030943-XXL | XXL | |
| 9030943-XXXL | XXXL | |
**JACKSON**
**QWIKGRIP Ice Cleats**
- Adjustable high-visibility reflective elastic strap for added safety
- 8 tungsten carbide spikes per pair, help provide stable grip on icy walking surfaces.
| Part No. | Description | Price |
|------------------|----------------------|-------|
| V355270-0/S | Mid Profile Heel | 15.90 |
| V355170-0/S | Non-Defined Heel | |
**Hand Warmers**
- Pack of 2 warmers.
V20541100S
$0.99
**Toe Warmers**
- Pack of 2 warmers.
V20543100S
$1.39
**DCAP**
**Headlight Restoration Spray**
- 3 oz
- 10 oz
DTR241
$16.90
DTR265
$39.90
**Ceramic Windshield Coating**
DTR289
$20.90
**Ceramic Windshield Coating Professional Kit**
DTR272
$139.00
**NEW!**
**NEW!**
**NEW!**
**Snappi-Hooker Heavy-Duty Tie Down**
- Blue cold weather EPDM rubber, good to -40°C
- Extra-thick tie-down with TTS hooks.
| Part No. | Length (in) | Price |
|----------|-------------|-------|
| 647-431 | 15" | 4.99 |
| 647-432 | 20" | 5.99 |
| 647-433 | 30" | 7.99 |
**MILWAUKEE**
**M12™ Heated TOUGHSHIELD™ Jacket**
WHILE SUPPLIES LAST
| Part No. | Size | Price |
|------------|------|-------|
| 204B-21M | M | 278.00|
| 204B-21L | L | |
| 204B-21XL | XL | |
| 204B-212X | XXL | |
**M12 12V Li-Ion Cordless Black Heated Hoodie/Sweater**
WHILE SUPPLIES LAST
| Part No. | Size | Price |
|--------------|------|-------|
| 306B-21M | M | 218.00|
| 306B-21L | L | |
| 306B-21XL | XL | |
| 306B-212X | XXL | |
### Pre-Mixed 50/50 Vehicle Engine Coolant, 3.78L
| Part No. | Type | Price |
|--------------|-----------------------------|-------|
| 36-184BHUSI | Honda 50/50 (Blue) | $14.90|
| 36-184TUSI | Toyota 50/50 (Pink) | $14.90|
| 36-324BEUSI | Euro 50/50 (Blue) | $15.90|
| 36-324PWUSI | VW 50/50 (Pink) | $15.90|
| 36-384GRHUSI | Asian 50/50 (Green) | $14.90|
| 36-384OGMUSI | GM 50/50 (Orange) | $13.70|
| 36-384RTUSI | Toyota 50/50 (Red) | $14.90|
| 36-834GFCUSI | Ford/Chrysler 50/50 (Gold) | $13.70|
### Anti-Gel Cold Weather Diesel Treatment
- Lucas Anti-Gel Cold Weather Diesel Treatment is specifically designed to prevent cold filter plugging in diesel and bio-diesel fuels.
| Part No. | Size | Price |
|----------|---------|-------|
| 20865 | 946 ml | $11.90|
| 20866 | 1.89 L | $19.90|
### Gumout Carb & Choke Cleaner
- Super Jet Spray quickly cuts and removes grease, gum and varnish
- 170 g.
#### Part No. 36090
**Price:** $6.99
### Lock-De-Icer
- Instantly de-freezes all types of locks and lubricates internal lock mechanism
- Safe on all automotive finishes
- 18 g.
#### Part No. 612
**Price:** $3.49
### Safe-T-Brake Air Brake Anti-Freeze
- Contains Anti-corrosive agent to protects all steel, rubber and brake line parts against corrosion and to minimize wear
- 950 ml.
#### Part No. 509
**Price:** $6.99
### Supreme Gas Line Anti-Freeze
- Prevents frozen gas lines during winter and vapour lock during summer
- 150 ml.
#### Part No. 409
**Price:** $2.49
### Low Sulphur Diesel Fuel Conditioner
- Helps restore lost lubrication from the use of low sulphur diesel fuels
- 1 L.
#### Part No. 963
**Price:** $10.90
### Diesel Fuel Conditioner
- Removes varnish and sludge
- Reduces corrosion
- Prevents stalling and frozen fuel lines.
| Part No. | Size | Price |
|----------|---------|-------|
| 991 | 150 ml | $2.99 |
| 993 | 1 L | $9.99 |
### WD40 Multi-Purpose Lubricant
- 3.78 L can.
#### Part No. 01110
**Price:** $48.90
### WD40 Penetrant Oil
- 311 g.
#### Part No. 01111
**Price:** $8.99
### WD40 Rust Release Penetrant
- 311 g.
#### Part No. 01178
**Price:** $9.99
### WD40 Multi Use Product Smart Straw
- 326 g.
#### Part No. 02272
**Price:** $9.99
**In-Sight® Center-Pull Towel Dispenser**
- 09335
- 60.90
**Scott™ Center-Pull Towels**
- 55423
- 65.90
**Scott™ Shop Towels Original**
- Blue, 55 towels per roll, 12 rolls per case.
- 75147
- 39.90
**Scott™ XTREME WIPES**
- 75 counts, 6 canister per case.
- 54591
- 77.90
**PURELL® Advanced Hand Sanitizer**
- 236 ml bottle.
- 9652-12CAN00
- 5.39
**Scrubbing Wet Wipes**
- Extra-large moist towels, dual textured (scrub with one side, wipe with the other)
- Contains skin conditioners
- Fresh citrus scent
- Pack of 72.
- 6396-06
- 16.90
**Fast Orange™ Hand Cleaner/Lotion with Pumice**
- Fortified with aloe, lanolin, glycerin and other skin conditioners
- Fine pumice formula for the toughest dirt
- Low profile 3, 78 L with pump.
- 25219
- 17.90
**CB 100™ Ultra-Powerful Natural Cleaner/Degreaser**
- Non-carcinotic, biodegradable, non-hazardous, phosphate-free, and butyl-free.
- 53G165
- 35.70
- 53G167
- 155.00
**Industrial Garbage Bags, Black**
- Degradable within 12-24 months when disposed of in a landfill
- UL Ecologo® 126 certified product (Environment Canada Program), less harmful to the environment and performs as well as “non-green” product
- Suitable for automotive, industrial, office, school, hotel, hospital use, and more.
| Part No. | Grade | Size (in) | Qty | Price |
|----------------|-----------|-----------|-----|-------|
| FC202215BL06 | Utility | 20 x 22 | 500 | 16.90 |
| FC303823BL04 | Strong | 30 x 38 | 200 | 25.90 |
| FC303832BL03 | Extra-Strong | 30 x 38 | 150 | 26.90 |
| FC355023BL04 | Strong | 35 x 50 | 200 | 39.90 |
| FC355032BL03 | Extra-Strong | 35 x 50 | 150 | 40.90 |
| FC424823BL04 | Strong | 42 x 48 | 200 | 44.90 |
| FC424832BL03 | Extra-Strong | 42 x 48 | 150 | 46.90 |
**Mop Head**
- Type: Synthetic wet mop
- Capacity: 24 oz.
| Part No. | Description | Color | Price |
|----------|------------------------------|-------|-------|
| 3088 | Cut end, narrow band | White | 7.39 |
| 3092 | Looped end, narrow band | Blue | 7.99 |
**Double Moss Squeegee**
- 22" head
- Tapered handle opening
- Designed to dig deep into crevices and uneven surfaces.
- 4090
- 9.99
**Tapered Squeegee Handle**
- 54" wooden handle, 1-1/8" diameter.
- 4073
- 10.90
**Quick Release Mop Handle**
- 54" fiberglass handle.
- 3119
- 15.90
- 60" fiberglass handle.
- 3120
- 16.90
**Mop Bucket with Wringer**
- 35 quart downpress bucket
- Compact design, heavy-duty polymer construction.
- 3078Y
- 139.00
### Heavy-Duty Pistol Grip Grease Gun
- **Part No.:** 1133
- **Price:** $63.90
### Heavy-Duty Grease Gun
- **Part No.:** 1142
- **Price:** $40.90
### 20V Li-Ion Powerluber® Grease Gun Kit (Dual Battery)
- **Part No.:** 1884
- **Price:** $449.00
### 12V Lithium-Ion PowerLuber®
- **Part No.:** 1264
- **Price:** $315.00
### Value Series Hose Reel Assembly
- **3/8" x 50'**
- **Part No.:** 83753
- **Price:** $299.00
- **1/2" x 50'**
- **Part No.:** 83754
- **Price:** $334.00
### Air-Operated 50:1 Portable Grease Pump Package
- Time-tested, 2-1/2", 50:1, air-operated, double-acting grease pump
- Heavy-duty control valve and universal swivel
- Standard follower wipes
- 120 lb. drum slides clean and keeps the pump primed
- Four-wheel dolly.
- **Part No.:** 917
- **Price:** Call Us
### Used Fluid Drain/Evacuator Combo
- 23-gallon welded steel tank supported by heavy-duty 4" swivel casters and 6" fixed-axle wheels
- Powerful compressed-air operated venturi vacuum quickly draws fluids from reservoirs
- Includes six evacuation wands of varying flexibility, diameter and length.
- **Part No.:** 36339
- **Price:** $830.00
### 1.5 L Fluid Extractor/Dispenser
- Simple to use and clean, easy to disassemble
- Durable, serviceable, does not leak.
- **Part No.:** 616
- **Price:** $79.00
### Fluid Evacuator/Dispenser
| Part No. | Size | Price |
|----------|--------|--------|
| MV7102 | 2.5 L | $285.00|
| MV7105 | 5 L | $305.00|
| MV7110 | 10 L | $304.00|
| MV7120 | 20 L | $335.00|
### Grease Filler Pump
- Complete unit includes zinc plated 18" (457 mm) pump with zinc die cast pump head and cast aluminum adjusting flange, 12" (310 mm) drum cover, follower plate (rubber lining) and female loader fitting.
- For 25-50 lb / 5-gallon / 20-30 kg containers.
- **Part No.:** 600450
- **Price:** $85.90
### 304 Stainless Steel Rotary Drum Pump
- For use with 15-55 gallon drums
- Dual directional operation & delivers up to 1 gallon per 20 turns
- Pumps water-based media, antifreeze, acids, chemicals, detergents, lacquer, thinners, petroleum based media, DEF, etc.
- **Part No.:** 600549
- **Price:** $425.00
### Rotary Drum Pump
- Dual Directional Operation which allows the pump to both empty, as well as refill containers
- Sturdy cast iron pump body with precisely machined cast iron vanes for better draw & smoother delivery
- For 15 to 55-gallon (50 to 205 L) barrels.
- **Part No.:** 600545
- **Price:** $99.90
### Professional Lever Grease Gun
- Flip-style rubber follower for use with grease cartridges and bulk grease
- Develops 10,000 psi (690 Bar)
- Complete with 6" (150 mm) steel extension & professional 4-jaw coupler.
- **Part No.:** 600022
- **Price:** $34.90
### Mini-Pistol Grip Grease Gun (Deluxe)
- One hand pistol grip grease gun with convenient pull type operating mechanism
- Capacity: 3 oz. (85 g) grease cartridge.
- **Part No.:** 600032
- **Price:** $49.90
### Pistol Grip Grease Gun, 14 oz
- Head fitted with steel block nut
- Flip-over follower
- Develops up to 5,000 psi
- Includes 18" flexible hose extension and coupler.
- **Part No.:** 600034
- **Price:** $22.90
### 16 L Drain Pan
- **Part No.:** 14022
- **Price:** $20.90
### Offset Funnel
- 4-3/4" x 3-5/8".
- **Part No.:** 13007
- **Price:** $13.90
### 2-in-1 Flex Spout Funnel
- **Part No.:** 14015
- **Price:** $4.99
### Grease Fitting Assortment
- 100 pieces.
| Part No. | Sizes | Price |
|----------|-------|--------|
| 00112 | 6 | $20.90 |
| 00108 | 9 | $20.90 |
### Lock On Grease Coupler Small Barrel
- **Part No.:** UC2121
- **Price:** $43.90
### Pressurized Used Fluid Receiver
- Equipped with 2x 4" casters, 2x 10" wheels and draining hose with J hook.
- **Part No.:** 600620
- **Price:** $299.00
**Puller**
- The puller is forged from high quality CR-V steel, heat treated, and subjected to rigorous tests which exceed their rated capacity.
- 2 Ton.
602403 $39.90
- 5 Ton.
602404 $57.90
**7 Pc Ball Joint Kit**
- Drop forged steel with black coating treatment to resist corrosion for lifelong performance.
602411 $99.90
**Ball Joint Separator Kit**
- Includes 4 interchangeable fork sizes (24mm/27mm/32mm/ 36mm).
602410 $229.00
**Exhaust Pipe Stretcher Kit**
- Collet sets expand pipes from 1-5/8” to 4-1/4”, aluminum to stainless steel
- 28mm size bolt head drives the tool and collet sets to expand pipes from 1-5/8” to 4-1/4”.
602430 $219.00
**Snap Ring Plier Set**
- Operates both internal and external rings
- Comfortable insulated vinyl handles
- Heat treated chromium-molybdenum steel.
602414 $69.90
**Exhaust Tail Pipe Cutter**
- 15 hardened steel cutting blades slice through tail pipes with just 90° rotation
- Cuts exhaust pipes from 3-3/4” to 3-1/4” diameter.
602431 $49.90
**3 Pc Hose Pinch Pliers**
- Sizes 8” (1.5” jaw contact area), 10” (1.75” jaw contact area), and 12” (2” jaw contact area).
602413 $69.90
---
**29-Piece Jet-Kut Black and Gold Drill Bit Set**
- Split-point, jobber length drill bit set
- Premium quality.
570146 $117.00
**55-Piece SAE/Metric Socket Wrench Set**
- 6-point sockets, 1/2” drive
- High quality Chrome Vanadium Steel
- TORQUE DRIVE® sockets (reduce corner rounding and allows 20% more torque).
600341 $359.00
**42-Piece S.A.E/Metric Socket Wrench Set**
- 6-point sockets, 1/4” drive
- High quality Chrome Vanadium steel
- TORQUE DRIVE® extra-long deep sockets.
600125 $129.00
**6-Piece Jet-Kut Premium Carbide Bur Set**
- General purpose, double cut tungsten carbide burs, 1/4” shank.
534202 $109.00
**4-Piece Jet-Kut GP Carbide Bur Set**
534192 $86.90
**10-Piece 3/8-inch Drive Tamperproof TORX Bits Socket Sets**
- 1/4” DR 1-1/2” (Overall Length).
601801 $52.90
**11-Piece 1/4” & 3/8” Torx Bit Socket Set**
- Includes 1/4” drive x 1-1/2” long sizes: T10, T15, T20, T25, T27, T30, and 3/8” drive x 2” long sizes: T40, T45, T47, T50, T55.
601806 $53.90
**Torque Wrench Standard Duty**
- 24-tooth Chrome Vanadium ratchet gear
- Reversible ratchet
- Dual ft-lb and Nm scales
- Patented lock ring
- Comfortable ergonomic handle grip.
- 1/2” Drive 250 ft-lb.
718912 $259.00
- 3/4” Drive 600 ft-lb.
718918 $839.00
**Reversible Ratcheting Wrench Set**
- Reversing lever on ratcheting box end
- Exclusive TORQUE DRIVE non-slip open ends.
- RCWS-12MR - 12 Piece.
700372 $259.00
- RCWS-13SR - 13 Piece.
700322 $359.00
### PRO
#### MÄKTIG™
**Multipurpose Digital Multimeter**
- DC Voltage: Up to 1000 V
- AC Voltage: Up to 750 V
- DC current: 2000µA to 10A
- Resistance: 200 Ohms to 200K Ohms.
**602500**
**2790**
**NEW!**
---
#### OTC
**Cylinder Leakage Tester Kit**
- Quickly diagnose internal engine problems such as bad rings, valves and leaking head gaskets.
- Includes 10, 12 and 18 mm thread adapters.
**5609**
**15400**
---
#### AUTEL
**MaxiSYS MS906PROTS Diagnostics Tablet**
- The MS906 Pro’s Octa-core processor, Android 7 operating system, and 128 GB of memory enable the tablet to perform advanced diagnostics, access comprehensive repair information, conduct battery and electrical system analysis and ADAS calibrations. Includes TPMS.
**MS906PROTS**
**CALL US**
---
**ALL in one Autel MaxiIM IM608 PRO II Key Programming Tool,**
- Autel IM608 PRO II is the most advanced key programming tool which combines IMMO and programming functions with OE-level diagnostics and advanced service functions in one tablet.
**IM608PROIIKP**
**CALL US**
---
**OBD2 Heavy Duty Diagnostic Scanner**
- Extraordinarily powerful Cortex-A9 quad-core processor
- Internal reliable and fast 32 GB Solid State Drive for better performance
- Built-in 5-megapixel rear camera with autofocus and flashlight.
**MS908CVII**
**CALL US**
---
**MaxiIM KM100 - KM100 Key Generator**
**KM100**
**65500**
---
**MAXIBAS BT608 Battery Tester**
- Comprehensive battery and electrical system diagnostics tool featuring Adaptive Conductance technology to identify low-capacity batteries and reduce battery misdiagnosis. The Android-based tablet tool displays a quick battery health status, enables an automatic battery registration and features Bluetooth connectivity and ScanWiFi functionality. The tool features a built-in thermal printer and one year warranty.
**BT608**
**64900**
---
**MaxiBAS BT609 Battery Tester**
- Test 12-volt batteries: 100 – 3000 CCA
- Test Flooded, AGM, AGM Spiral, EFB and GEL batteries.
**BT609**
**94900**
---
**AL529 Autolink Pro Service Tool**
- Compatible with domestic, Asian and European vehicles, 1996 and newer OBD II/EOBD compatible vehicles. Retrieves generic (p0, p2, p3 and u0), manufacturer-specific (p1, p3 and u1) and pending codes
- Autowin function for quick manufacturer-specific code identification.
**AL529**
**13900**
---
**ABS/SRS/Engine/Transmission Code Reader**
- Compatible with domestic, Asian and European vehicle, 1996 and newer
- Read/erase codes on four systems: ABS, SRS, engine / transmission systems
- Performs I/M readiness (emissions) testing.
**AL629**
**21400**
---
**MD808P All Code Reader with EPB/SAS/DPF Services**
- The MD808P is an advanced all systems code reader. It can access all modules in all systems, performs AutoSCAN, and currently has 6 service functions. The MD808P can graph/record/playback live data, display live and freeze frame data, and supports all 10 OBDII test modes. It has enhanced Mode 6 diagnostics, I/M readiness/emissions testing, and programmable generation. The MD808P is updatable via PC and includes an OBDII cable and a 4-inch color screen. A 1-year tool warranty and free lifetime software updates are available with purchase.
**MD808P**
**35900**
---
#### INNOVA®
**Auto-Ranging Digital Multimeter, 10 MegOhm**
- Auto-ranging scales
- Safe for automotive and household uses
- Large, color-coded LED digital display
- Designed to test AC or DC voltage, batteries, AC and DC currents, resistance, diodes and continuity
- Color-coded LED’s display battery quick check.
**3320**
**3790**
---
**Test Light/Circuit Tester**
- Helps to quickly identify if there is voltage present on wiring and circuits
- Ergonomic grip design and 6-foot test leads.
**3410**
**1090**
---
**Professional Timing Light**
- Shockproof housing, molded boots, built-in hand guard for protection, detachable 6-foot leads with metal inductive pickup
- Patented skip circuit that runs up to 9,000 RPM, compatible with 12-volt negative-ground vehicles, distributorless ignition systems, and all timing systems
- Switches from 2 to 4 cycles.
**5568**
**14900**
---
**Carscan Advisor Pro Diagnostic Tool (2022)**
- 3.375” LCD all-in-one display
- Allows you to scan and graph ABS, SRS and Powertrain Live Data parameters
- Transmits direct and free RepairSolution2 app
- Many additional professional features.
**5210**
**13090**
---
**Smart Test Light / Circuit Tester**
- Designed to safely check voltage and/or ground on several electronic systems, including wiring, fuses, battery, cabling, sensors, switches, relays etc.
- Cigarette lighter power plug connection, ergonomic grip design and 6-ft test leads.
**3420**
**1990**
---
**Fuel Injection Pressure Tester**
- Large, easy-to-read 2-1/2” dial face with 0-100 psi scale
- 16” gauge hose and 6’ bleed-off hose with solid brass fittings, with adapters for domestic and import vehicles.
**3640**
**4090**
**G350-540/510 Medalist Classic**
- Heavy duty construction
- One cutting attachment for all fuel gases (with proper tip)
- G350-540
- Regulators with large 2.5” gauges.
**Mig Wire**
- For general purpose MIG welding
- Designed to be used on mild steel
- DC reverse polarity.
| Part No. | Type | Spool Size | Wire Size | Price |
|----------|---------------|------------|-----------|-------|
| 1440-0210| | 2 lbs | .023" | 1790 |
| 1440-0211| | 11 lbs | .023" | 4990 |
| 1440-0215| ER70S-6 | 2 lbs | .030" | 1390 |
| 1440-0216| MIG Wire Solid| 11 lbs | .030" | 4690 |
| 1440-0220| | 2 lbs | .035" | 1190 |
| 1440-0221| | 11 lbs | .035" | 4390 |
| 1440-0222| | 33 lbs | .035" | 10990 |
| 1440-0230| E71T-GS | 2 lbs | .030" | 4090 |
| 1440-0235| Flux Cored | 2 lbs | .035" | 3490 |
| 1440-0236| | 10 lbs | .035" | 13490 |
**Thermal Dynamics Cutmaster 30+ Plasma Cutter**
- 120/240V
- Lightweight design with three handles for easy transportation.
**Esab Rogue EM140 Welder**
Inverter-based MIG/MAG welding system
- The system features industrial-grade arc performance and full featured controls that allow the welder to fine tune arc characteristics based on the material they are welding.
**Esab Rogue EM125 Welder**
- Versatile inverter-based MIG welding system that caters to a wide range of welding projects, including light fabrication, repairs, and maintenance tasks.
- IP23S rated for indoor/outdoor use.
**Spark Lighter**
- Easy ignition, resists rust and corrosion
- Single Flint.
**Tweco MIG Velocity Contact Tips**
| Part No. | Design | Price |
|----------|----------------|-------|
| 1444-0890| 23 Contact Tips| 299 |
| 1444-0891| 30 Contact Tips| 299 |
| 1444-0892| 35 Contact Tips| 299 |
**Welding Helmet**
| Part No. | Design | Price |
|----------|----------------|-------|
| 1441-0085| Pinstripe | 1990 |
| 1441-0086| Piston & plug | |
| 1441-0088| Skull | |
**Welding Electrodes**
| Part No. | Type | Size Type | Applications | Polarity | Tensile Strength | Box | Price |
|----------|---------------|----------------------------|---------------------------------------------------|---------------------|------------------|-----|-------|
| 1440-0107| 6011 | 1/8", mild steel type | All position electrode | AC or DC Reverse polarity | 60,000 psi | 10 lbs | 3790 |
| 1440-0116| 6011 | 3/32", mild steel type | Deep penetration, welds through rust, scale, oil and dirt | AC or DC Reverse polarity | 60,000 psi | 5 lbs | 2290 |
| 1440-0135| 6013 | 1/8" mild steel type | All position electrode | AC or DC Either polarity | 70,000 psi | 5 lbs | 1890 |
| 1440-0182| 7018 | 5/32", low hydrogen type | Designed for general purpose, excellent for low heat | AC or DC Either polarity | 70,000 psi | 10 lbs | 3990 |
| 1440-0186| 7018 | 1/8", low hydrogen type | Medium penetration | AC or DC Either polarity | 70,000 psi | 5 lbs | 1990 |
| 1440-0187| 7018 | 1/8", low hydrogen type | | AC or DC Either polarity | 70,000 psi | 10 lbs | 3590 |
**Century FC90 Fluxed-Cored Wire Welder**
- Portable, 120 V welder
- Offers versatile welding output and welds 18-gauge to 1/4” in a single pass.
**AC225™ Stick Welder**
- The AC225 compact stick welder produces an extremely smooth AC arc for welding a wide variety of materials including carbon, low alloy, and stainless steels as well as cast iron.
**Century Oxy-acet Outfit**
- Brass torch handle includes built-in reverse flow check valves
- Cutting attachment includes solid forged brass head, tail and stainless steel tubes
- Regulators feature a brass body.
**Flux Core Wire**
- 2 lb roll, pack of 2.
- - 0.030 caliber.
- - 0.035 caliber.
**Flux Core Wire**
- 2 lb roll, pack of 2.
- - 0.030 caliber.
- - 0.035 caliber.
**Flux Core Wire**
- 0.035 caliber
- 10 lb roll.
**Petrol Based Flux Paste**
1lb
| Part No. | Price |
|----------|-------|
| ED561137B2PK | 4490 |
| ED561138B2PK | 4290 |
| ED561137 | 3490 |
| ED561138 | 3290 |
| ED561320 | 7790 |
| SCPF1 | 1890 |
BUY ONE OF THESE SHOCKWAVE IMPACT DUTY™ SOCKET SETS
29-Piece ShockWave Impact Duty™ Socket Set
- 1/2" drive deep 6-point sockets
- High-strength forged steel sockets with long-lasting, ink-filled markings.
- SAE.
49-66-7015 $249.00
- Metric.
49-66-7016 $249.00
43-Piece ShockWave Impact Duty™ Socket Set - SAE and Metric
- 3/8" drive deep 6-point sockets
- High-strength forged steel sockets with long-lasting, ink-filled markings.
49-66-7009 $199.00
14-Piece ShockWave Impact Duty™ Metric Standard 6 Point Socket Set
- 1/4" Drive.
ITEM 49-66-7002
- 3/8" Drive.
ITEM 49-66-7007
FREE
M12 FUEL™ INSIDER™ Extended Reach Box Ratchet
- Unrivaled Access with INSIDER™ Box Ratchet Sockets
- Ultimate Versatility to get more jobs done with one tool.
3050-20 $398.00
M18™ Dual Bay Super Charger
- Delivers up to 6x Faster charging to 80% for more productivity.
48-59-1815 $339.00
M18™ 18-Volt REDLITHIUM™ FORGE™ Batterie lithium-ion haute performance 6,0 Ah
- Delivers HIGH OUTPUT™ 12.0 power in a smaller size and lighter weight
- 15 min Supercharge to 80% with the NEW M18™ Dual-Bay Simultaneous Super Charger.
48-11-1861 $279.00
M12™ Auto Technician Borescope
- 4-Level zoom adjustment
- 3" camera cable.
3150-20 $599.00
38-Piece Tap & Die PACKOUT™ Set with Hex-LOK™ 2-in-1 Handle
Hex-LOK™ 2-in-1 Handle is the most versatile threading solution designed for tap and die threading.
- SAE.
49-22-5604 $240.00
- Metric.
49-22-5603 $240.00
Long Reach Hose Grip Pliers Set
- Deep-reach cross handles: increased reach in tight spaces
- Forged alloy steel for maximum tool strength and durability.
- 2-Piece
48-22-6542 $89.00
- 3-Piece
48-22-6563 $144.00
9-Piece Snap Ring Pliers Set
- Easier Conversion: Anti-Slip Dial.
48-22-6539 $247.00
M18™ 70,000 BTU Forced Air Propane Heater
- Run time: 8 hours
- User interface on top of unit for easy access & quick ignition.
.0801-20C $298.00
### EPDM Rubber Air Hose
- 300 psi
- Hose I.D & O.D: 9.5*16.5 mm.
| Part No. | Hose (in x ft) | Price |
|----------|----------------|-------|
| 801065 | 3/8" x 50' | 54.90 |
| 801067 | 3/8" x 100' | 91.90 |
### Coiled Air Hose
- Hose 1/4" x 50"
| Part No. | Hose (in x ft) | Price |
|----------|----------------|-------|
| 800104 | 3/8" x 50' | 219.00|
| 800105 | 1/2" x 50' | 229.00|
### Air Hose Reel
- Nitrile butadiene, oil-resistant rubber air hose
- 8-position locking system
- Adjustable 5-position roller guide arm.
### 2-in-1 High Volume Hydro and Air Power Cleaning Wand
#### NEW!
171-NF01 61.90
### Aeroblade® 24 Extension Reach Nozzle Air Blow Gun
#### NEW!
158-AB24 49.90
### Blow Gun
- 1/4" NPT brass air inlet, 16.5 SCFM, 90 psi.
S-174KIT 28.90
### Straight Foot Dual Head Chuck Inflator Gage
S-516 84.90
### 5 HP Compressor
- 20-gallon air compressor
- Durable oil lubricated pump
- 125 psi maximum ASME safety valve
- 14.5 AMP
- Comes with wheels for easy manoeuvrability.
8498 369.00
### 5.5 Peak Hp 20 Gallon Air Compressor
- 2 cylinder cast iron single stage oil lubricated pump
- 50 PSI Max pressure for optimum tool performance.
KC-205H2 774.00
### 24 Gallon Air Compressor
- 5.5 PEAK HP
- 2 cylinder cast iron single stage oil lubricated pump.
- 150 PSI Max pressure for optimum tool performance
- ASME registered tank.
KC-3124V2 899.00
### 1/4" Mini Angle Grinder
- Speed : 22,500 RPM.
CP875 124.00
### 3/8" Air Impact Wrench
- 50 ft-lb / 68 Nm maximum torque.
CP886 144.00
### Dual Action Sander
- General-duty sander with rotary or random orbital options
- PSA sanding pad
- Intuitive grip and lock off throttle
- Power regulator.
CP870 124.00
### 1/2" Heavy-Duty Air Impact Wrench
- 715 ft-lbs (970 Nm) max in reverse
- Suited for all maintenance applications: light vehicles tire charging operations, light welding, mechanical repair, MRO applications
- 15% lighter than its former version (CP7736).
CP7741 259.00
### Pistol Needle Scaler
- General purpose pistol needle scaler
- Rubber sleeve on handle for better comfort
- Delivered with 2 sets of needles.
CP7125 334.00
### Needle Scaler
- General maintenance needle scaler easily convertible to a weld flux chipping hammer
- Adjustable sleeve, 19 x 1/8" (3 mm) steel needles and 1.37" (35 mm) width chisel with high resistance to wear.
CP7120 354.00
### Replacement Needle Set for CP7120 7" Needle Scaler
8940159860 17.90
### 3M™ File Belt Sander
- 1/2 in x 18 in.
| Part No. | Grit | Price |
|---------|------|-------|
| 31650 | 80 | |
| 31651 | 120 | |
| 31653 | 180 | |
| 31656 | 320 | |
### Cubitron II Net Abrasive
- Our fastest-cutting, longest-lasting, dust capture abrasive
- 6" discs, roll of 50.
| Part No. | Grit | Price |
|---------|------|-------|
| 31650 | 80 | |
| 31651 | 120 | |
| 31653 | 180 | |
| 31656 | 320 | |
### Performance Spray Gun System
- Precision spray performance with high transfer efficiency and large, adjustable fan pattern
- Includes gun, mixing cups with lids, pressure gauge, caps and quick-change replaceable atomizing heads.
### Sanding Discs with Stikit™ Attachment, Pack of 10
- Clog Resistant
- Cuts Fast
- Super Strong Abrasive.
| Part No. | Grit | Size (in) | Price |
|---------|------|-----------|-------|
| 31446 | 320 | 6 (15.2 cm) | 9.99 |
| 31448 | 180 | 6 (15.2 cm) | 9.99 |
| 31451 | 80 | 6 (15.2 cm) | 9.99 |
### Yellow Masking Tape
- Offers solvent and moisture resistance that minimizes bleed through
- Delivers a controlled unwind that makes tape easier to handle
- Produces sharp, clean, quality paint jobs.
| Part No. | Size | Price |
|---------|---------------|-------|
| 06652 | 18mm x 55m | 4.99 |
| 06654 | 36mm x 55m | 9.99 |
| 06656 | 48mm x 55m | 12.99 |
### 233+ Automotive Masking Tape, Green
| Part No. | Size | Price |
|---------|---------------|-------|
| 03431C | 0.7" x 10'4" (18mm x 32m) | 4.59 |
| 03433C | 1.4" x 10'4" (32mm x 32m) | 9.99 |
### Set of 3 Plastic Spreaders
- Reusable
- Highly flexible
- Includes 3 different sizes.
### Glass-Reinforced Filler
- Includes cream hardener
- Waterproof
- 20 minute sand time
### Bondo® Body Repair Kit
- Includes: 1 pint can body filler, red cream hardener, self-adhesive metal body patch and spreader.
### Bondo® Fiberglass Resin Repair Kit
- Includes: Fiberglass resin (1/2 pint), liquid hardener, plastic spreader, fiberglass cloth, mixing stick and mixing tray.
---
**A2A Exhaust Accessories**
**FLEX TUBE WITH INTERLOCK - HEAVY DUTY**
- The interlock design reduces noise and vibration
- Better durability lowering the wear and deformation of the braid
- Produced with premium grade 304 stainless steel
- Better resistance to corrosion
**POR-15® 45004 Rust Preventative Coating**
- Gloss Black
- 1 Quart.
| Part No. | Size | Price |
|---------|------|-------|
| 57-245004 | 6290 |
**POR-15® 49204 Tank Sealer**
- 1 Quart.
| Part No. | Size | Price |
|---------|------|-------|
| 57-249204 | 5490 |
**POR-15® 40104 Cleaner Degreaser**
- 32 oz.
| Part No. | Size | Price |
|---------|------|-------|
| 57-240104 | 1490 |
**POR-15® 40204 Metal Prep**
- 32 oz.
| Part No. | Size | Price |
|---------|------|-------|
| 57-240204 | 2190 |
**Rubberset® White China Bristle Paint Brush**
| Part No. | Size | Price |
|---------|------|-------|
| 99060310 | 1" | 099 |
| 99060320 | 2" | 139 |
| 99060330 | 3" | 199 |
**Krylon ColorAll® General Purpose Enamel Paint**
- 283 g.
- Gloss black.
- Flat black.
| Part No. | Size | Price |
|---------|------|-------|
| B460505 | 639 |
| B460507 | 639 |
**Shake and Shoot Bedliner Kit Black**
- VOC compliant, every kit comes with a free gun and regulator.
- Easy to use, simply pour Part B into Part A to the fill line, shake for 2 minutes and “shoot”.
- 4 L.
- 3.6 L.
| Part No. | Size | Price |
|---------|------|-------|
| BSSBL | 17400 |
| BSSBLT | 17400 |
**Urethane Auto Glass Adhesive Sealant**
- Powerful adhesion to glass and metal
- 300 ml, black.
| Part No. | Size | Price |
|---------|------|-------|
| CUS | 1390 |
| CUSF | 1390 |
**Paint-Off Hand Cleaner**
- Waterless hand cleaner formulated with natural ingredients and pumice scrubbers to gently remove products from your skin
- 500 ml.
| Part No. | Size | Price |
|---------|------|-------|
| CUSO | 1190 |
**6 mil Disposable Nitrile Gloves**
- Superior puncture and abrasion resistance
- Fully textured grip, beaded cuff and ambidextrous fit
- Powder and latex free
- Black, 9” length.
| Part No. | Size | Gloves Per Box | Price |
|---------|------|----------------|-------|
| 903013 | M | 100 | 1690 |
| 903014 | L | 100 | 1690 |
| 903015 | XL | 90 | 1690 |
| 903016 | XXL | 90 | 1690 |
**Body Clip Removal Kit**
| Part No. | Description | Piece | Price |
|---------|-------------|-------|-------|
| 602300 | Auto body clip removal plier set | 3-Piece | 3190 |
| 602302 | Automotive trim panel removal tool set | 5-Piece | 2490 |
| 602303 | Automotive trim removal tool set | 11-Piece | 1890 |
Heavy Duty Dual Action Grease Gun
59.90
MAKTIG 449/MTL - 600060
Big Wheel Creeper
177.00
- Heavy-duty creeper with extra long 40" bed
- Four 5" swivel industrial-grade wheels, sturdy gloss black powder-coat finish frame, high-density foam covered in vinyl
- 400lb distributed weight capacity.
JET 784/JEQ - 355116
Ice-Off® Spray De-icer
6.99
- 340 g.
CRC 218/CRC - 75346
POR-15® Stop Rust Kit
27.90
- POR-15 3-Step Stop Rust Kit provide permanent rust protection in 3 steps!
- Covers a 6 sq. ft. area with two coats
- Ideal for small projects.
376/ACM - 57-240909
Multi-Purpose Genius Chargers
Introducing NOCO's improved Genius 6/12 V battery charger and maintainer perfect for lead-acid and lithium-ion batteries
Start-up current sensor detects dead batteries as low as 1 volt
All-new Force Mode allows manual charging for extreme dead batteries all the way down to zero volts
Built-in battery desulfator, reverse polarity and incompatibility detection, and much more!
| Part No. | Amps | Price |
|---------|------|---------|
| GENIUS1 | 1 | 39.90 |
| GENIUS2 | 2 | 66.90 |
| GENIUS5 | 5 | 92.90 |
| GENIUS10| 10 | 134.00 |
NOCO 183/NCO
Propane Fuel Cylinder
11.90
- 16.9 oz.
TX9
MAP-Pro Fuel Cylinder
16.90
- 14.1 oz Map-Pro cylinder.
324786
Regulated Self-Lighting Propane Torch
41.90
- Triple point flame.
MT535C
BERNZOMATIC 854/BZM
We are striving to maintain enough quantities of advertised items to supply the demand. However, if an item is sold out, please accept our apologies. Some items may not be as illustrated. Some part numbers may differ from one region to another, but they represent the same product or an equivalent quality. BUMPER TO BUMPER makes no warranty and is not responsible for any error or omissions in this document or in any corresponding price list. Freight charges may apply on some items. Prices may change without notice and some promotions may end before the advertised date.
BUMPER TO BUMPER IS A TRADEMARK OF UNI-SELECT INC.
ALL RIGHTS RESERVED.
MIX Paper from responsible sources
FSC® C108927
**Packout™**
- **Rolling Tool Chest**
- 250 lbs weight capacity.
- 48-22-8428
**M18™ Packout™ LIGHT**
- 18 V Lithium-Ion Cordless PACKOUT 3000 Lumens LED Light with Built-In Charger, Integrated M18™ and USB device charging. Three independent pivoting light heads. 9 Light Output Modes. Up to 31 hours of run-time (with Back/Front Lights)
- Bare Tool.
- 2357-20
**M18 Rover™**
- **Mounting Flood Light**
- Provides up to 1500 lm of Trueview™ high definition light
- 2” reinforced clamp
- Up to 20 hours of runtime
- Equipped with hang holes, powerful magnets, a 2” reinforced spring-loaded clamp and a 360° rotating foldable head
- Bare Tool.
- 2365-20
**Packout™**
- **Cabinet 20 x 15 x 15”**
- 50 lbs weight capacity.
- 48-22-8445
**Redlithium™ USB BEACON™ Hard Hat Light**
- 5 light output modes:
- Hybrid Spot/Flood: 600-Lumens – 2 hours
- Flood High: 400-Lumens – 4 hours
- Flood Medium: 200-Lumens – 8 hours
- Flood Low: 25-Lumens – 20 hours
- Spot High: 400-Lumens – 4 hours
- BEACON™ Light: 30+ hours.
- 2116-21
**Redlithium™ USB Low-Profile Headlamp**
- 4 light output modes:
- Flood High mode: 600-Lumens – 2 hours
- Medium mode: 350-Lumens – 6 hours
- Low mode: 125 –Lumens – 10 hours
- Eco mode: 25-Lumens - 27 hours.
- 2115-21
**Redlithium™ USB Hard Hat Headlamp**
- 5 Output Modes:
- Hybrid: 600-Lumens – 5 Hours
- Flood High: 400-Lumens – 9 Hours
- Flood Low: 100-Lumens – 20 Hours
- Spot High: 400-Lumens – 9 Hours
- Spot Low: 100-Lumens – 20 Hours.
- 2163-21
**M18™ Rover™ Flood Light**
- Provides up to 1300 lm of Trueview™ high-definition light
- Up to 8 hours of runtime
- Corrosion-resistant, waterproof and drop-rated body and lens
- Equipped with an swivel octogonal support and hang holes
- Bare Tool.
- 2361-20
**12-Piece Demolition Sawzall® Blade Set**
- Heavy-Duty blade assortment for metal, wood and heavy cutting jobs.
- 49-22-3329
**M18™ Redlithium™ High Output™ XC8.0 Battery**
- 48-11-1880
**M18™ Dual Bay Rapid Charger**
- 48-59-1802
**M12™ Redlithium™ XC 6.0 Battery Pack**
- 48-11-2460
**M12™ 2.0 Starter Kit**
- 48-59-2420
We are striving to maintain enough quantities of advertised items to supply the demand. However, if an item is sold out, please accept our apologies. Some items may not be as illustrated. Some part numbers may differ from one region to another, but they represent the same product or an equivalent quality. BUMPER TO BUMPER makes no warranty and is not responsible for any error or omissions in this document or in any corresponding price list. Freight charges may apply on some items. Prices may change without notice and some promotions may end before the advertised date.
BUMPER TO BUMPER IS A TRADEMARK OF UNI-SELECT INC.
ALL RIGHTS RESERVED.
MIX Paper from responsible sources
FSC® C108927
|
ROTNEST EXPRESS
GROUPS, CONFERENCES & INCENTIVES
**COMPANY PROFILE**
Rottnest Island is one of WA’s best kept secrets, boasting spectacular white sandy beaches and secluded bays. The island is also home to unique wildlife, including the famous quokka, a small wallaby-like marsupial.
Escorted or self-guided day tours to choose from, a variety of on-island activities and an array of lunch options, it provides the perfect destination for your next group getaway.
Rottnest Express is the island’s largest and most experienced cruise company, operating daily year round services from both Perth and Fremantle. Rottnest Express has a fleet of three high-speed ocean going ferries that have been specially designed for the local sea conditions and are widely known for their smooth, fast and safe crossings.
**THE REGION**
Rottnest Island sits just offshore from the city of Perth, in Western Australia. A protected nature reserve, it’s famous for being the home to the quokka, a small wallaby-like marsupial. White-sand beaches and secluded coves include The Basin, with its beautiful turquoise waters; Bathers Bay, the main hub and ferry port; Strickland Bay is known for its surf breaks, while reef breaks occur at Radar Reef, off the island’s far western tip.
**WHEN TO VISIT**
**SEPTEMBER – APRIL**
Most popular time to visit the island for swimming, snorkelling and other outdoor pursuits. Whales can often be spotted from September to mid-November.
**MAY – AUGUST**
Temperatures are still fairly mild in winter. Winter is relatively cool and wet but often a few degrees warmer than it is on the mainland.
**GROUP BOOKINGS**
Our group specialists are here to assist - no matter how large or small your group may be. We can assist at any stage of the journey and design travel plans to match your specific needs. We offer discounted ferry and tour options to all kinds of groups; there are endless opportunities for corporate, social and special interest groups to take their events to Rottnest.
**PRIVATE CHARTERS**
Let our groups specialists assist you in arranging a private charter, no matter how large or small your group visit to Rottnest Island may be. Rottnest Express has a fleet of vessels to cater to your needs and with regular services departing daily, let us plan your perfect getaway.
**OUR LOCATIONS**
Rottnest Express has three convenient locations, a daily morning departure from Elizabeth Quay in Perth which runs non-stop to Rottnest Island, B Shed Ferry Terminal which offers a number of departures every morning and is just a 10 minute walk from the train station and the centre of Fremantle. Also our Northam Ferry Terminal offers large bus parking if required.
**CONTACT US**
Contact our groups specialists via firstname.lastname@example.org
ROTNTNEST ISLAND MAP
DIRECT SERVICES FROM PERTH!
Rottnest is 1km in length and 4.5kms at its widest point. Suggested bike rides:
- Ride 1: 10km (1 – 2 hours)
- Ride 2: 10km (1.5 – 3 hours)
- Ride 3: 22km (3 – 5 hours)
EXPERIENCE ROTNTNEST
BICYCLE AND SNORKELLING PACKAGES YEAR ROUND
GET ACTIVE...
Unleash your adventurous spirit as you feel the breeze in your hair using pedal power to cycle your way around the island or combine both bike and snorkel for an unforgettable land and sea experience.
PACKAGE INCLUSIONS
- Return ferry transfers to Rottnest Island
- Bike Hire with helmet
- Rottnest Island Admission Fee
- Hotel transfers from most metropolitan accommodation, subject to availability
- Swan River Cruise with commentary (from Perth only)
- Lunch (optional extra)
- Snorkel set (optional extra)
- Optional Free Guided Quokka Walk (delivered by the Rottnest Island Volunteer Guide)
TIPS
1. There is no drinking water or food available outside the Thomson Bay and the Geordie Bay settlement areas. Don’t forget your supplies—water, lunch, sun cream, batteries, towel and camera are essentials!
2. During summer days on the south coast, particularly in the morning, there is a strong southerly wind. By midday the famous Fremantle Doctor comes in from the south-west making the bays to the north such as The Basin, Parakeet Bay and Little Armstrong Bay the most enjoyable.
3. The island is 1km long by 4km wide and takes approximately 3-5 hours to ride around.
DISCOVER ROTTNEST
BUS TOUR PACKAGE
YEAR ROUND
RELAX AND DISCOVER...
Explore the beauty and tranquillity of Rottnest as you sit back and relax in the comfort of an air conditioned coach. This 90-minute tour around the island takes you to some of Rottnest’s most spectacular locations including the Wadjemup Lighthouse and the rugged West End and provides you with a complete interpretation of the island through our passionate and knowledgeable guides.
This tour will provide you with an insight into Rottnest’s cultural and historical heritage, diverse wildlife and fauna and social heritage. You will also have a chance to step outside and have a stroll along the boardwalk at the majestic look-out point at West End.
PACKAGE INCLUSIONS
- Return ferry transfers to Rottnest Island
- 90-minute Discover Rottnest Coach Tour
- Rottnest Island Admission Fee
- Hotel transfers from most metropolitan accommodation, subject to availability
- Swan River Cruise with commentary (from Perth only)
- Lunch (optional extra)
- Optional Free Guided Quokka Walk (delivered by the Rottnest Island Volunteer Guides)
TIPS
1. Make sure you take a stroll along the boardwalk at West End and keep your eyes open for the Humpback Whales! Sept - Nov
2. Don’t forget your camera.
ADVENTURE ROTTNEST
ADVENTURE BOAT PACKAGE
SEPTEMBER TO APRIL
AN ADVENTURE FOR NATURE LOVERS...
Jump onboard our purpose-built, high-powered vessel for the adventure of a lifetime as the Eco Express takes you for a 90-minute journey to the island’s wild side. Explore Rottnest’s rugged coastline and witness the beauty of its wildlife up close, including the migrating humpback whales (June to November) and the delightful antics of the New Zealand fur seal colony (all year round) at Cathedral Rocks. This is the ultimate thrill ride for nature lovers.
Our knowledgeable, friendly crew know all of the best spots to go to see all of Rottnest’s finned, furred and feathered residents, and provide expert commentary along the journey.
PACKAGE INCLUSIONS
- Return ferry transfers to Rottnest Island
- 90-minute Adventure Boat Tour (aboard the open air Eco-Express) to see New Zealand fur seals and marine life
- Rottnest Island Admission Fee
- Hotel transfers from most metropolitan accommodation, subject to availability
- On-board commentary from our expert guides
- Purpose built 42 seat vessel providing you with an exclusive up close encounter with the wildlife!
THRILL RIDE
THRILL RIDE PACKAGE
SEPTEMBER TO APRIL
BE ADVENTUROUS...
Take a high-powered spin of Rottnest Island on the 45-minute Thrill Ride, safely aboard our purpose built, high powered vessel, the Eco Express. A faster, more adrenaline-charged experience than the 90-minute Adventure Tour, this is a chance to explore the island’s rugged coastline and feel the salt spray on your skin.
On this full day tour, you’ll also have plenty of time to explore the island, meet the quokkas and enjoy a bite to eat while taking in the beautiful scenery (lunch at own expense).
PACKAGE INCLUSIONS
- Return ferry transfers to Rottnest Island
- 45-minute Thrill Ride (aboard the open air Eco Express)
- Rottnest Island Admission Fee
- Hotel transfers from most metropolitan accommodation, subject to availability
- Plenty of free time to explore the island and meet the resident quokkas.
LOOKING FOR MORE INSPIRATION? TRY THESE FUN IDEAS.
WADJEMUP WALKING TRAIL
Get active and discover the Island’s natural beauty and rich history along the spectacular Wadjemup Walk Trail. There are currently 4 completed sections of the walk trail to enjoy, each boasting a unique experience and breathtaking scenery. You can opt for the 9km walk to Oliver Hill, discover the salt lakes on a 10km loop and many more!
HISTORIC ROTTNEST
Join us aboard the Captain Hussey for a scenic train ride to picturesque Oliver Hill, as we take you on a guided tour of Rottnest’s military history. Still preserved to this day, Rottnest’s WWII-era guns and tunnels stand as a stoic reminder of a pivotal moment in time. These military artefacts are part of the rich and diverse timeline of Rottnest Island.
CYCLING TOURS
With limited vehicles, Rottnest Island enjoys a tranquillity like no other. Take advantage of this and discover the beautiful bays and beaches and cycle to your heart’s content! Take your time and ride at your own pace, or let us assist you with an Island Bike Tour – where you can learn about the history of the Island along the way.
OLIVER HILL AND TUNNEL TOUR
Enjoy a train ride from the Settlement Railway Station to Oliver Hill on the Island’s 64-seat Captain Hussey train, where you can admire the beauty of the Island’s south-side and experience the military history of Rottnest.
CORPORATE VOLUNTEER
Your team can help Rottnest Island stay beautiful by participating in these conservation efforts – Sea spurge, Tree Guard, Beach clean-up, 1000 foot journey.
SEAFOOD ADVENTURES
Enjoy Rottnest Cruises seafood and fishing charter and become part of the action while you watch fresh seafood being caught and cooked straight from the ocean to your plate.
GOLF & LAWN BOWLS
Take your next corporate day to the greens! Complete golf and lawn bowls packages available, whether for a special celebration or a corporate activity.
SEGWAY TOURS
Easy as a walk in the park...without the walk. A unique and unforgettable experience as you’re lead on a journey of discovery and exploration into the Island’s most hidden treasures.
SCENIC JOY FLIGHTS & SEA PLANE TOURS
Take a breathtaking scenic joy flight over Rottnest for stunning aerial views of the whole island.
SKYDIVE GERONIMO
If you’re feeling brave, get the heart pumping with an adrenaline rushing skydive!
MEET OUR FLEET
DESIGNED FOR SPEED AND COMFORT.
STARFLYTE
LENGTH OVERALL 38.92 m
TOP SPEED 26 knots
TIME TO ROTTNEST 25 min
MAX # OF PASSENGERS 485
EAGLE EXPRESS
LENGTH OVERALL 34.75 m
TOP SPEED 32 knots
TIME TO ROTTNEST 25 min
MAX # OF PASSENGERS 319
SEA EAGLE
LENGTH OVERALL 30 m
TOP SPEED 30 knots
TIME TO ROTTNEST 25 min
MAX # OF PASSENGERS 220
ECO EXPRESS
ADVENTURE BOAT AND THRILL RIDE TOUR VESSEL
LENGTH OVERALL 12 m
TOP SPEED 35 knots
MAX # OF PASSENGERS
42 – Adventure Tour
42 – Thrillride
TOUR BUSES
SIT BACK, RELAX AND ENJOY OUR GUIDED TOURS IN OUR AIR-CONDITIONED AND HEATED COACHES, SEATING A MAXIMUM OF 32 PASSENGERS.
BIKES FOR HIRE
WE OFFER BIKES FOR HIRE TO OUR ROTTNEST EXPRESS CUSTOMERS; THESE BIKES ARE PURPOSE BUILT FOR THE TERRAIN AT ROTTNEST ISLAND AND INCLUDE HELMET HIRE.
DINING VENUES & CATERING OPTIONS
To tantalise the taste buds, Rottnest offers a range of lunch options. Please note more options are available upon enquiry.
**THOMSONS**
P: (08) 9292 5171 | E: email@example.com
www.thomsonserrottnest.com.au
**KARMA ROTTNEST**
P: (08) 9292 5161 | E: firstname.lastname@example.org
**HOTEL ROTTNEST**
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PA Newsletter
MAY 2021
Past Due Invoices
BOA Statement Payment
FAQ
Past Due Invoices
What it is and how to pay it
Have you ever received an invoice and struggled to determine if it was past due or not? Don’t worry, we’ve all been there! All payments to non-governmental and privately owned businesses for the purchase of goods and services must be due dated. Agencies should assign a payment due date 30 calendar days after receipt of the goods, services, or invoice, whichever is later, or the due date specified in the vendor’s contract.
Once you’ve verified that the invoice is past due, you have two options for payment:
1. Submit a payment voucher through Cardinal or EDI Payment
2. Submit a Past Due Invoice payment request to CCA
If you’ve chosen option 2, here’s some things you should know. CAPP 20355 requires one of the following:
- A copy of the invoice, with date stamp (showing the date the invoice was received)
- Email approval from the cardholder’s supervisor that provides detailed information to include: Invoice Date, Invoice Amount, Vendor Name, Invoice Received Date, Due Date and reason invoice is being paid late.
But CCA! Many of us still have not returned to the office and aren’t receiving physical mail. Can an email from the vendor providing the invoice as an attachment be considered the received date?
Absolutely!
If you are still working remotely and have not received a physical invoice in the mail, an email from the vendor with the invoice attached can be considered the received date.
Here’s some other things to know:
- Cardholders have a responsibility to follow-up with vendors for invoices that are outstanding. If you have received the goods/services, but not an invoice, reach out to the vendor.
- Cardholders have a responsibility to follow-up with vendors for payments that have not posted within 2 weeks of payment information that has been provided.
- Cardholders should be monitoring their transactions in WORKS, at least, on a weekly basis. Outstanding payments will be easy to catch if you monitor your transactions.
- CAPP 20315 provides information on Prompt Pay and Due Date Practices
- CCA Database is used to submit your Past Due Invoice requests.
BOA Statement Payments
How to pay, what to pay, when to pay
Making sure your payments are received in a timely manner to the correct account like the rock star you are!
Have you received an email from CCA regarding an issue with your payments? We have a solution for that.
- Make sure you provide the 16 digit account number in the Payment Message field. Do not use hyphens spaces, or alpha characters.
- Make sure to use Bank of America’s Vendor ID: 0000042877
- Select Location: MAIN (for SPCC Payments)
- Select Location: EDI-88 (for Travel Card)
- Change the Pay Terms field to 00PP
- Enter the Payment Date of the 7th (MM/07/YY). Payments can be earlier than the 7th but no later than the 7th.
- Pay the full amount reflected in the Current Balance Due section of the charge card statement. Disputed amounts and Fraud credit will appear on subsequent invoices.
- Do not reduce monthly invoices by unapplied credits
| **Business Unit** | |
|-------------------|---|
| **Voucher ID** | NEXT |
| **Voucher Style** | Regular Voucher |
| **Total Amount** | 0.00 |
| **Supplier Name** | Bank of America |
**Payment Information**
- **Payment 1**
- **Remit to**: 0000042877
- **Location**: MAIN
- **Address**: 5
**Bank of America**
P O BOX 15731
WILMINGTON, DE 19886-5731
**Payment Options**
- **Bank**: 3100
- **Account**: TR01
- **Method**: EFT
- **Message**: 1234567891234567
*Netting*: Not Applicable
**Invoice Information**
- **Invoice No**: AFR2021PCG
- **Invoice Date**: 04/15/2021
- **Action**: Incomplete Voucher
- **Pay Terms**: 00PP
- **Due Now PP**: 00PP
**Payment Options**
- **Pay Group**:
- **Handling**: Regular Payments
- **Hold Reason**:
**Scheduled Due**: 05/07/2021
**Net Due**: 05/07/2021
**Discount Due**:
**Accounting Date**:
**Actions**:
FAQ
If a cardholder has not utilized their card in 12+ months, do I have to cancel the card?
- Yes, all cards that have not been utilized in 12+ months should be cancelled, along with the user profile if not needed.
What is an Authorized Signatory?
- Authorized Signatory is anyone who has been designated by the Agency Head and who has signed the DOA Authorized Signatory Form (DA-04-121-Cardinal). Authorized Signatories are required to sign the Program Administrator Request Form and Gold Card Request Form.
As a Backup PA, can I perform the same duties as the Primary PA?
- Yes, both Primary and Backup PA’s have the same roles, responsibilities and access.
Is an Exception Request needed for all permanent restriction lifts or for requests with an extended period of time?
- Yes, Exceptions Requests are required for all permanent removals on an annual basis, due May 31st. If a request for an extended period of time is granted (case by case basis) this must also be placed on an exception request.
When should a Program Administrator be removed from the program?
- Program Administrators should be removed on the last working day at the Agency. Requests to remove a Program Administrator must be submitted no later than the last working day of the Program Administrator to ensure program security.
Can an IL Travel Card be used to pay for the travel needs for anyone other than the cardholder?
- No, IL Travel Cards are intended to be used by the cardholder ONLY for official business travel needs.
How do I find out why a card is declining?
- You can see declining transactions by looking at the Authorization Log within Works. On the Home screen, click the carrot under “Account ID” and choose “View Auth Log”.
- Below are a few declining codes:
- Declined by Score 1 Fraud Strategy
- Individual MCCG Excluded MCCG has been excluded
- Bad Pin Invalid PIN number used
- Account Amount Limit Exceeded Amount exceeds limits set
Your Bank of America cards are getting a new look
Throughout the months of May and June, we will be transitioning our card products to the Bank of America brand. As the transition is completed in each region, new cardholders will receive cards with the rebranded design and enhanced features. Existing cardholders can continue to use their current card without interruption and will receive new cards when the current card expires.
**Card features:**
- New cards will differentiate each card type by color
- New cards will have account details flat printed on the back of the card
- New cards will have an extended expiration date of five years
- New cards will have contactless capabilities
- All cards (current and new) can be loaded into mobile wallet
*Sample Core Cards (Note: Your card/product type and Visa or Mastercard association will remain the same.)*
*Sample Logo Card and reverse side of cards (Note: Your card product type and association will remain the same.)*
**Frequently Asked Questions:**
**Do I need to take any action in order to receive a redesigned card?**
No action is needed.
**When will we receive redesigned cards?**
Existing cardholders will receive a new card when their current card expires. New cardholders will be issued a redesigned card when the rebrand transition is complete in region.
**Will my company logo and/or other custom images carry over to the new design?**
Yes. Logos and/or custom images currently located on the front of your card have been transferred to the new design.
We hope that you and your cardholders enjoy the updated details and features.
Warm regards,
Bank of America Commercial Card
Learn more about Executive Explorer
Learn more about Mobile Wallet
Learn more about Contactless
Log into Global Card Access
General Disclaimer for Bank of America
©2021 Bank of America Corporation. All rights reserved.
REMINDERS:
- Please use the CCA Automated Online Forms Request System. Email requests for paying late invoices, credit limit increases, temporary restriction removal, and submission of annual certifications will not be accepted effective July 1, 2016.
- Troubleshooting - if you are having issues logging on to https://cca.doa.virginia.gov/Login.cfm, please contact firstname.lastname@example.org.
- DOA offers Monthly Program Administrator Training for all new PA’s as well as those who need a refresher beginning April 5, 2016. Training will be offered via WebEx on the first Tuesday of each month. Each monthly training session will be from 8:00 am to 12:00 pm. To register, please email email@example.com. This monthly training will allow PA’s to receive detailed instructions about their responsibilities and day-to-day functions as a Program Administrator.
- The Commonwealth has a package relationship with NAPCP in order to get a (discounted) $99 membership rate. When you sign-up initially or renew your membership to this organization, please contact DOA for coupon code to receive your discounted membership rate.
- When contacting CCA, please call 804-786-0874 to leave a voicemail or email firstname.lastname@example.org. Email is the best way to contact us. If your request is urgent, please mark it accordingly when sending an email. Do not send maintenance requests to individuals within the unit.
- When contacting Emily Ruzumma or Company Level Support at BOA, please email email@example.com. Please include your company number in all correspondence.
- DOA will be reviewing IL Travel cards monthly and PAs will be informed if the cardholder is past due more than one day. Program Administrators must review the delinquency reports in Works at least every two weeks to ensure cardholders are making timely payment for their IL cards.
- Effective March 2021, CAPP 20360 states:
- **Past Due 31 Days**: The TPA is required to suspend the IL Travel Card of any cardholder that becomes 31 days delinquent.
- **Past Due 61 Days**: The TPA is required to cancel any IL Travel Card that has become 61 days past due.
- State policy dictates at this point the agency will deduct the entire outstanding past due balance from the cardholder’s pay.
- If the Cardholder has separated from the Agency and obtained employment with another State Agency, the TPA should reach out to the new employer’s payroll department, providing a copy of the signed Employee Agreement and the outstanding balance still owed.
- If the Cardholder has separated from the Agency seeking employment outside of the Commonwealth the outstanding balance should be submitted to Comptroller’s Debt Set-off.
(CDS) https://www.doa.virginia.gov/reference/generalAccounting/index.shtml#Comptroller
- Agencies should evaluate the number of CL and STL increase requests and ensure the limits are in line with the cardholder’s needs. If you find that the cardholder regularly goes over the cycle limit, card limit, or single transaction limit, please review the need for a Gold Card at your agency.
- For information on Virtual Payables, please visit https://www.doa.virginia.gov/reference.shtml#vp or email firstname.lastname@example.org (NEW)
Contact Information for CCA: email@example.com 804-786-0874 (HOTLINE)
|
How similar is similar? Exploring the binary and ternary solid solution landscapes of p-methyl/chloro/bromo-benzyl alcohols
This is the final peer-reviewed author’s accepted manuscript (postprint) of the following publication:
Published Version:
Romasanta, A., Braga, D., Duarte, M., Grepioni, F. (2017). How similar is similar? Exploring the binary and ternary solid solution landscapes of p-methyl/chloro/bromo-benzyl alcohols. CRYSTENGCOMM, 19(4), 653-660 [10.1039/c6ce02282k].
Availability:
This version is available at: https://hdl.handle.net/11585/579822 since: 2017-03-03
Published:
DOI: http://doi.org/10.1039/c6ce02282k
Terms of use:
Some rights reserved. The terms and conditions for the reuse of this version of the manuscript are specified in the publishing policy. For all terms of use and more information see the publisher's website.
This item was downloaded from IRIS Università di Bologna (https://cris.unibo.it/).
When citing, please refer to the published version.
(Article begins on next page)
This is the final peer-reviewed accepted manuscript of:
A.K.S. Romasanta, D. Braga, M.T. Duarte, F. Grepioni, How similar is similar? Exploring the binary and ternary solid solution landscapes of p-methyl/chloro/bromo-benzyl alcohols, *CrystEngComm*, 2017, 19, 653-660
The final published version is available online at: [http://dx.doi.org/10.1039/c6ce02282k](http://dx.doi.org/10.1039/c6ce02282k)
Rights / License:
The terms and conditions for the reuse of this version of the manuscript are specified in the publishing policy. For all terms of use and more information see the publisher's website.
*This item was downloaded from IRIS Università di Bologna ([https://cris.unibo.it/](https://cris.unibo.it/))*
*When citing, please refer to the published version.*
How similar is similar? Exploring the binary and ternary solid solution landscapes of $p$-methyl/chloro/bromo-benzyl alcohols†
A. K. S. Romasanta, D. Braga, M. T. Duarte and F. Grepioni*
New binary and ternary solid solutions formed by $p$-chlorobenzyl alcohol ($p$-CIBA), $p$-bromobenzyl alcohol ($p$-BrBA) and their quasi-isostructural compound $p$-methylbenzyl alcohol ($p$-MeBA) have been prepared and characterized by DSC and powder X-ray diffraction. The binary and ternary solid solutions were synthesized by co-melting of $p$-MeBA/$p$-CIBA, $p$-MeBA/$p$-BrBA and $p$-CIBA/$p$-BrBA and by co-melting of $p$-MeBA/$p$-CIBA/$p$-BrBA in various molar ratios. By varying the relative concentrations, it has been possible to observe the consequent variations of the melting points of the solid solutions. For the binary 1:1 $p$-MeBA/$p$-BrBA and $p$-CIBA/$p$-BrBA compounds, single crystals were grown from solution and their structures were investigated by X-ray diffraction.
Multicomponent solids are attractive targets in the quest for novel specialized materials.\textsuperscript{1} Crystal engineering\textsuperscript{2} provides efficient tools to exploit the knowledge of crystal packing and of the forces acting between molecules to design new multicomponent materials with desirable structural and/or physico-chemical characteristics. The basic idea is that of being able to tune solid state properties such as melting point, hygroscopicity, solubility, stability, refractive index, thermal conductivity, surface activity, density, and electrostatic, mechanical and optical properties \textit{via} a careful choice of molecular/ionic building blocks.\textsuperscript{3} Clearly, the occurrence of polymorphism, \textit{i.e.} the possibility of more than one result in the aggregation of the same molecules resulting in unforeseeable differences in solid state properties, needs also to be kept in mind.\textsuperscript{4}
Co-crystals are stoichiometric multi-component crystalline materials formed by components that are solid under ambient conditions.\textsuperscript{5} Co-crystallization has also proven to be a method to further explore, hence extend, the intellectual property right protection of active pharmaceutical ingredients (API) giving access to novel and/or improved properties provided that the API is co-crystallized with molecules\textsuperscript{6} acceptable in the pharmacopoeia.\textsuperscript{7}
More recently, the field has been expanded with the systematic preparation of ionic co-crystals,\textsuperscript{8} where neutral organic molecules, including active pharmaceutical ingredients (APIs), are co-crystallized with an inorganic salt (typically halides of the first and second groups).
On the other hand, when multiple components combine in a single crystalline phase in nonstoichiometric ratios,\textsuperscript{9} mixed crystals are formed with random occupancy of unit cell sites, which also currently find applications in the pharmaceutical field.\textsuperscript{10} By not being limited to integral stoichiometry, a wide range of properties of the resulting solid can be controlled just by adding or decreasing the amount of a certain component.\textsuperscript{11}
Clearly, miscibility of the components is the prerequisite for the formation of a solid solution. Miscibility depends very much on two related concepts, namely, structural mimicry,\textsuperscript{12} and crystal isomorphism. Two crystals are said to be
\begin{figure}[h]
\centering
\includegraphics[width=\textwidth]{scheme1.png}
\caption{Solid solutions formed by quasi-isostructural molecules crystallizing in isomorphous crystals.}
\end{figure}
isomorphous if “(a) both have the same space group and unit-cell dimensions and (b) the types and the positions of atoms in both are the same except for a replacement of one or more atoms in one structure with different types of atoms in the other [...] or the presence of one or more additional atoms in one of them [...]. Isomorphous crystals can form solid solutions.”\textsuperscript{11,13} Molecules forming isomorphous crystals may crystallize together into a single lattice, randomly replacing one another within the crystal as represented schematically in Scheme 1. In the case of molecules that do not form isomorphous crystals, however, their quasi-isostructurality can still allow formation of multicomponent crystals, which are usually isomorphous with one of the two parent crystals.\textsuperscript{14}
These principles can be illustrated by the chloro-methyl exchange,\textsuperscript{15} which pertains to quasi-isostructural molecules differing by a chlorine group replacing a methyl group or \textit{vice versa}. Methyl- and chloro- groups have been known to possess similar shape and size, with van der Waals volumes of ca. 19 Å\textsuperscript{3} and 21 Å\textsuperscript{3}, respectively.\textsuperscript{16} Taking this into account, it has been shown that it is possible for molecules with these groups in equivalent sites to be interchangeable in a crystal structure. In fact, a survey of the Cambridge Crystallographic Database has shown that approximately 30% of molecular pairs only differing by a methyl group replacing a chloro group crystallize with isostructural packing arrangements.\textsuperscript{17} This scheme has been the basis for the preparation of new multicomponent crystals (Scheme 1).\textsuperscript{18}
Following this approach,\textsuperscript{19} we have reported, together with others, a structural and solid state NMR study of solid solutions of \textit{para}-methylbenzyl alcohol (\textit{p}-MeBA) and \textit{para}-chlorobenzyl alcohol (\textit{p}-CIBA).\textsuperscript{14} In order to explore the solid solution space of \textit{p}-MeBA and \textit{p}-CIBA, isomorphous crystals of \textit{p}-MeBa I were first prepared by seeding a solution of the known form II of \textit{p}-MeBA with crystals of \textit{p}-CIBA, by taking advantage of the large difference in solubility in hexane of the two species. The procedure used in that investigation is schematically represented in Scheme 2.
The \textit{heteroseeding} procedure, therefore, also provides viable routes to the preparation of a desired solid form when it is possible to exploit shape mimicry. Jones \textit{et al.}\textsuperscript{19} reported that a solid solution can be obtained from the crystallization of chlorine cyclopentanone with the methyl derivative: through structural mimicry, the methyl derivative was induced to adopt molecular conformation, crystal structure and solid state reactivity of the chlorine analog.
A major drawback in the preparation of solid solutions of molecular crystals is that, for many systems, there is only a limited composition range wherein a homogenous phase is observed.\textsuperscript{20} As interest in solid solutions of organic molecules has just started to develop, this is one of the many challenges that crystal engineers face in the synthesis of solid solutions with desired properties. For instance, in an attempt to circumvent this problem, a third component can be added to facilitate the mixing of two incompatible components. Anthracene and phenazine usually crystallize as separate phases; however, in the presence of acridine, which is miscible in both, a mixed crystal can be formed.\textsuperscript{21}
In this study, we extend our approach to binary solid solutions of \textit{p}-MeBA and \textit{p}-CIBA with the bromine equivalent, \textit{p}-BrBA, and also explore the preparation and thermal behaviour of three-component solid solutions consisting of the methyl-, chloro- and bromo-benzyl alcohols (see Scheme 3).
The mixed crystals have been investigated by a combined use of differential scanning calorimetry (DSC) and powder and single crystal diffraction measurements. The combined use of these methods has made possible a mapping of the solid-solution landscape and showed how the composition affects the melting temperature of the mixed systems with respect to the pure parent materials.
**Experimental section**
All reagents and solvents were purchased from Sigma-Aldrich and used without further purification.
**Solid solutions by co-melting**
To obtain binary and ternary solid solutions, \textit{p}-MeBA, \textit{p}-CIBA and \textit{p}-BrBA were melted with stirring at the desired molar ratio. The melts were allowed to cool slowly to room temperature. The resulting powders were characterized by XRPD and DSC.
**X-ray powder diffraction**
X-ray powder diffraction (XRPD) patterns were collected at room temperature using a PANalytical XPert PRO automated
---
\begin{figure}[h]
\centering
\includegraphics[width=\textwidth]{scheme_2.png}
\caption{Schematic illustration of heteroseeding to generate a new polymorphic form of \textit{p}-MeBA isomorphous with the crystals of \textit{p}-CIBA.}
\end{figure}
\begin{figure}[h]
\centering
\includegraphics[width=\textwidth]{scheme_3.png}
\caption{Formulae of the solid compounds used to prepare binary and ternary solid solutions: \textit{p}-methylbenzyl alcohol (\textit{p}-MeBA, form II), \textit{p}-chlorobenzyl alcohol (\textit{p}-CIBA), and \textit{p}-bromobenzyl alcohol (\textit{p}-BrBA).}
\end{figure}
diffractometer equipped with an X’celerator detector in the $2\theta$ range of 3–50° (step size 0.011, time/step 50 s, $V \times A \ 40 \times 40$).
**Differential scanning calorimetry**
DSC measurements were carried out using a Perkin-Elmer Diamond equipped with a model ULSP90 intracooler. The samples (3–5 mg) were placed in aluminum open pans. Heating was carried out at 5 °C min$^{-1}$.
**Crystal structure determination**
Single crystals for X-ray diffraction were obtained by slow evaporation of EtOH solutions. Single crystal X-ray data for $p$-BrBA, $p$-MeBA$_{0.5}$BrBA$_{0.5}$ and $p$-ClBA$_{0.5}$BrBA$_{0.5}$ were collected at room temperature using an Oxford X’Calibur S CCD diffractometer equipped with a graphite monochromator (Mo-K$\alpha$ radiation, $\lambda = 0.71073$ Å). Crystal data and details of the measurement are listed in Table S1.$^\dagger$ The Me group and the Br atom in MeBA$_{0.5}$BrBA$_{0.5}$ and the Cl and Br atoms in $p$-ClBA$_{0.5}$BrBA$_{0.5}$ were treated as disordered 50:50 over two positions; the occupancy factor was first refined by keeping the isotropic thermal parameters fixed, then the occupancy factor was fixed and both C and Br or Cl and Br atoms were refined anisotropically. All non-hydrogen atoms were refined anisotropically; H atoms were added in calculated positions and refined riding on their respective carbon or oxygen atoms. In both mixed crystals, the phenyl rings were treated as rigid groups. SHELX97 (ref. 22a) was used for structure solution and refinement on $F^2$; Schakal99 (ref. 22b) was used for molecular graphics; Mercury$^{22c}$ was used to simulate powder patterns on the basis of single crystal data. The CCDC numbers are 1513379 ($p$-BrBA), 1513380 ($p$-MeBA$_{0.5}$BrBA$_{0.5}$) and 1513381 ($p$-ClBA$_{0.5}$BrBA$_{0.5}$).
Before proceeding with the discussion, a word of caution is in order. If taken separately, the results of single crystal X-ray diffraction, powder X-ray diffraction, and DSC measurements, in view of their complexity, are not sufficient *per se* to characterize the mixed systems with the desired degree of confidence. For instance, the existence of crystals of different compositions within the powder samples or the presence of block disorder in the single crystals cannot be entirely ruled out. It should be kept in mind that X-ray diffraction operates an average over space (and time, but this aspect is less relevant in the context of this paper), and that this average affects the sample in a different way in the case of single crystals than in the case of powder samples. Analogously, DSC results are affected by particle size distribution, sample homogeneity, and phase purity among other factors. It is only the concurrent output of these methods that provides a coherent picture.
**Results and discussion**
The crystal structures of $p$-MeBA, $p$-ClBA and $p$-BrBA have been studied extensively in the past. Here we only need to summarize some of the key aspects. The commercially available form of $p$-MeBA, form II, crystallizes in the monoclinic system $P2_1$ with three independent molecules in the asymmetric unit,$^{23}$ while $p$-ClBA contains only one independent molecule in the asymmetric unit.$^{24}$ Both $p$-ClBA and $p$-MeBA II show the presence of infinite hydrogen bonded chains in their solids. Form I of $p$-MeBA (XABREY06), isomorphous with $p$-ClBA, was previously synthesized by hetero-seeding a solution of form II with crystals of $p$-ClBA.$^{14}$ The hetero-seeding product $p$-MeBA I was found to be a metastable form that converted into the thermodynamically stable $p$-MeBA II in one week.$^{14}$ It is also interesting to note that this runs contrary to the hypothesis that the lower $Z'$ in $p$-MeBA I ($Z' = 1$) should make it more stable than $p$-MeBA II ($Z' = 3$).$^{25}$ Only one form is known for $p$-BrBA, and it is isomorphous with $p$-ClBA.$^{26}$ Fig. 1 shows the main packing motif, with infinite chains of molecules connected *via* OH···O$_{\text{OH}}$ hydrogen bonds, in $p$-MeBA, $p$-ClBA and $p$-BrBA.
**Binary solid solutions: $p$-MeBA$_{1-x}$BrBA$_x$ and $p$-ClBA$_{1-x}$BrBA$_x$**
The preparation of the solid solutions of $p$-MeBA$_{1-x}$BrBA$_x$ and $p$-ClBA$_{1-x}$BrBA$_x$ was based on co-melting, *viz.* on melting of the mixture of pure components, followed by slow cooling to room temperature. The solid mixtures were characterized by DSC and X-ray powder diffraction. In some cases, single crystals were grown from ethanol solutions in the presence of seeds. The results of the binary crystals will be compared also with reference to the binary solid solutions of $p$-MeBA and $p$-ClBA, previously reported.$^{14}$
Since the $p$-BrBA molecule is isostructural with $p$-MeBA and $p$-ClBA and their crystals are isomorphous, it is can be expected that $p$-BrBA may be able to form binary solid solutions with either $p$-MeBA or $p$-ClBA. Melting together $p$-MeBA and $p$-BrBA in various stoichiometric ratios yields solid solutions, as confirmed by DSC and XRPD. The DSC of each product shows only one peak, pertaining to the formed solid solution and not to the reagents. The melting point trend in the phase diagram of $p$-MeBA$_{1-x}$BrBA$_x$ is analogous to the one observed for $p$-MeBA$_{1-x}$ClBA$_x$, with a pronounced minimum covering a fairly large compositional range, as shown in Fig. 2.
A comparison of the experimental X-ray powder diffraction patterns measured at room temperature on $p$-MeBA$_{1-x}$BrBA$_x$ solid solutions is shown in Fig. 3. It can be appreciated how the patterns progressively change between those of the isomorphous pure compounds in the $P2_1/c$ structures, reflecting the change in cell volume.
The solid solutions obtained *via* co-melting were in most cases recrystallized from solution, in order to attempt growth of single crystals for X-ray structural characterization. Only in the case of $p$-MeBA$_{0.5}$BrBA$_{0.5}$ we succeeded in growing single crystals for structural characterization.
Crystalline MeBA$_{0.5}$BrBA$_{0.5}$ is isomorphous with $p$-MeBA I and $p$-BrBA, and the methyl group and the bromine atoms show a 50% positional disorder, as shown in Fig. 4.
Analogous investigation was carried out on solid solutions of $p$-ClBA/$p$-BrBA. However, contrary to what was observed for
the mixtures containing $p$-MeBA, the melting points of the solid solutions are approximately all in between the values of the pure components (see Fig. 5).
A comparison of the experimental X-ray powder diffraction patterns measured at room temperature on $p$-MeBA$_{1-x}$BrBA$_x$ solid solutions is shown in Fig. 6. As observed for the $p$-MeBA$_{1-x}$BrBA$_x$ solid solutions, the patterns progressively, although not linearly, change between those of the isomorphous pure compounds in the $P2_1/c$ structures; for the sake of clarity, only the ($-1\ 0\ 2$) reflection (compare with Fig. 3) is been monitored here; a comparison of the XRPD patterns in the whole $2\theta$ range is reported in the ESI†
Single crystals for a detailed structural analysis could be grown from solution only in the case of $p$-ClBA$_{0.5}$BrBA$_{0.5}$ (see Fig. 7). Single crystals grown from a solution with Cl:Br in a 10:90 ratio turned out to be the pure $p$-BrBA compound, for which no room temperature data were available in the literature. A good quality structure was refined and structural details have been deposited in the CSD (see the ESI† and Fig. 1).
It is worth mentioning, on passing, that the unit cell parameters for the mixed systems are in between those for...
Fig. 5 Melting points (DSC peak temperatures) of the $p$-CIBA$_{1-x}$BrBA$_x$ solid solutions obtained by co-melting.
Fig. 6 Comparison of experimental X-ray powder patterns for $p$-CIBA$_{1-x}$BrBA$_x$ solid solutions, showing a slight average shift of the (−1 0 2) reflection towards higher 2$\theta$ angle on passing from the bromine derivative (bottom line, calculated pattern) to the chlorine derivative (upper line, calculated pattern).
The pure compounds, thus following the well-known Vegard’s rule (see the ESI†).27
The behaviours with temperature of the three binary solid solutions obtained by co-melting are compared schematically in Fig. 8. All three pairs represent solid solution systems with complete miscibility. In the case of $p$-CIBA$_{1-x}$BrBA$_x$, the phase diagram is the simplest possible one, with the solidus line decreasing smoothly on decreasing amount of chlorine in the solution (see Fig. 8a)
Solid solutions with complete miscibility, however, can also exhibit a thermal minimum, as shown in Fig. 8b: this is the case of $p$-MeBA$_{1-x}$ClBA$_x$ (ref. 14) and $p$-MeBA$_{1-x}$BrBA$_x$, for which the melting points reach a minimum for $x \approx 0.5$ and $x \approx 0.25$, respectively. It is important to stress, however, that this minimum is an indifferent point, not a triple point, as only two phases (the solid solution and the liquid) exist in equilibrium, and the liquidus curve is tangential to the solidus curve (see inlet in Fig. 8, bottom).26
Ternary solid solutions: $p$-MeBA$_{1-x-y}$ClBA$_x$BrBA$_y$ solid solutions
As a natural extension of our study on two-component solid solutions of the three isomorphous solids $p$-MeBA, $p$-CIBA and $p$-BrBA, the propensity of these systems to form three-component solid solutions was also investigated. We
expected, however, increasing difficulties in the solid state characterization of the possible products, because of the higher complexity of the systems. The ternary 1:1:1 solid solution prepared, as in the case of the binary solid solutions, by co-melting showed distinct peaks in the XRPD pattern (Fig. 9), which could be attributed to the formation of the ternary phase, isomorphous with the parent ones. DSC measurements were instrumental in confirming the formation of the ternary solution, as only one peak was observed, at a different temperature with respect to the previously analysed solid solutions. Fig. 9 shows a comparison of the experimental pattern for the ternary 1:1:1 solid solution and the calculated patterns at room temperature for the pure parent compounds; the behaviour of the $(-1\ 0\ 2)$ reflection is followed, as in Fig. 3 and 6 (a comparison over the whole $2\theta$ range is reported in the ESI†).
Growing single crystals of the ternary solid solution, however, via dissolution in ethanol followed by slow evaporation, proved, up to now, to be a frustrating effort; all single crystals used for structural determination turned out to be either the pure chlorine derivative or crystals of low quality and difficult to refine.
Solid solutions of $p$-MeBA/$p$-ClBA/$p$-BrBA were also prepared at various stoichiometric ratios. DSC measurements of the solid solutions at various ratios revealed only one phase for each composition. Varying the concentration of one component while leaving the two other components to be equimolar resulted in slight changes in the corresponding XRPD patterns (see ESI†).
In order to investigate the melting point behavior of the ternary system, a large number of DSC measurements were carried out (see the ESI†). Fig. 10 provides a visual representation of the results. Generally, the melting points of the solid solutions were lower than those of the pure coformers; the lowest melting points for the ternary solid solutions were found at excess $p$-MeBA, with the $p$-MeBA$_{0.5y}$ClBA$_{0.25}$BrBA$_{0.25}$ solid solution showing the lowest one.
**Conclusions**
In this paper we have extended our previous work on solid solutions of $p$-MeBA and $p$-ClBA to the bromine analogue $p$-BrBA, obtaining new binary solid solutions from $p$-MeBA/$p$-BrBA and $p$-ClBA/$p$-BrBA. These crystalline materials demonstrated to be particularly well suited for this benchmarking study, permitting facile preparation by co-melting of the solid solutions, characterization by powder diffraction and isolation from solution of 50:50 products in the form of single crystals. The new mixed crystals were successfully synthesized with various molar ratios. In view of the quasi isostructurality...
of the three compounds and of the fact that all compounds crystallize in isomorphous crystals, preparation of ternary solid solutions from \( p \)-MeBA/\( p \)-ClBA/\( p \)-BrBA has also been attempted and successfully carried out.
The study showed that the melting points of the solid solutions formed by molecular crystals synthesized changed according to the composition chosen for the preparation of the solid mixtures prior to co-melting. The three binary solid solutions showed two different types of trends with respect to the melting points. Solid solutions of \( p \)-MeBA/\( p \)-ClBA and \( p \)-MeBA/\( p \)-BrBA show minima at different compositions some 18 °C lower than that of the lowest melting substance, e.g. \( p \)-MeBA form II, while the \( p \)-ClBA/\( p \)-BrBA solid solutions melt at a temperature systematically lower than those obtained by linear averaging but comprised between the melting points of the two pure components. The ternary \( p \)-MeBA/\( p \)-ClBA/\( p \)-BrBA solutions also show isomorphismicity with the \( P2_1/c \) parent structures, while the melting points are systematically lower than those obtained by weighted average of the components.
It is interesting to note that in the presence of polymorphic modifications, the metastable form of \( p \)-MeBA is preferred, showing the “adaptive capacity” of the packing of \( p \)-MeBA when mixed with \( p \)-ClBA and \( p \)-BrBA.
Having been successful with these model molecules, research will proceed with more complex molecules, in order to understand to which extent the ternary replacement is exploitable. Our aim is to extend our approach to systems where properties can be adapted to the target by a change in solid solution composition.
**Acknowledgements**
We acknowledge financial support from the University of Bologna. COST Action CM1402 (Crystallize) is also acknowledged. We thank Dr. Katia Rubini for her assistance with DSC measurements.
**Notes and references**
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|
June 17, 2019
TO BE FILED UNDER SEAL
By ECF & Hand Delivery
The Honorable Jack B. Weinstein
United States District Court
Eastern District of New York
225 Cadman Plaza East
Brooklyn, New York 11201
Re: United States v. Jane Doe
Criminal Docket No. 17-48 (JBW)
Criminal Docket No. 19-117 (JBW)
Dear Judge Weinstein:
The government submits this letter under seal\(^1\) in advance of defendant Sinmyah Amera Ceasar’s sentencing in the above-captioned cases, which is scheduled for June 24, 2019, at 10:30 a.m.\(^2\) The defendant has pleaded guilty to two separate crimes: conspiring to
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\(^1\) On March 13, 2019, the government filed a motion under seal in case Docket No. 17-CR-48 seeking the following relief: (1) that the defendant’s true name Sinmyah Amera Ceasar be substituted in place of “Jane Doe” on the Court’s public docket; (2) that the criminal complaint and information be unsealed; and (3) that the defendant be held by the Bureau of Prisons under her true name. The Court has indicated that it will address these issues at the time of sentencing. Should the Court grant the government’s motion, the government will file a redacted version of this sentencing letter on the public docket that protects the sensitive information in this memorandum regarding the defendant’s cooperation with the government and other sensitive personal and health related matters.
\(^2\) At sentencing, the government expects to call two witnesses to provide expert testimony relevant to the Court’s sentencing determination. Dr. Lorenzo Vidino will testify as an expert on international terrorism and provide background to the Court on ISIS, the role of U.S.-based ISIS recruiters and facilitators, the significance of certain language used by the defendant in her commission of both offenses, and some of the central factors that experts in
provide material support to the Islamic State of Iraq and al-Sham (“ISIS”) and then, while on release pending sentencing, obstructing justice by deleting numerous electronic communications she had with other individuals, including ISIS supporters, in order to prevent their detection by the government and the Court.
As this Court rightly observed when sentencing a different defendant in a terrorism case several years ago, among the many sentencing factors the Court must weigh in such cases, “[a]bove all, the court must consider how best to protect the public.” For all the reasons set forth herein, and in particular the need to protect the community from further criminal conduct by the defendant – who to this day remains unrepentant for her actions – the government respectfully requests a sentence within the advisory Sentencing Guidelines range of 360 to 600 months’ imprisonment.
I. Introduction
It is important to begin with who the defendant is not. She is not a so-called “ISIS Bride,” several of whom recently received significant media attention for leaving – or attempting to leave – the United States or other Western countries to join ISIS abroad, only to have a change of heart and seek to return to their home countries. Moreover, the defendant was not convicted of a “cybercrime” or for talking to the wrong people, as she has repeatedly claimed. Nor, finally, is the defendant a victim of religious persecution, prosecuted for standing up for her religious beliefs or her First Amendment rights, claims she continues to make despite having pleaded guilty to two felony offenses.
On the contrary, from at least January 2016 until her November 2016 arrest, the defendant provided material support to ISIS. She did so as a committed recruiter and self-described “assistant” to the terrorist group, connecting ISIS supporters in the United States to ISIS facilitators and operatives abroad. Specifically, the defendant repeatedly used numerous social media accounts and other electronic communication platforms to proclaim her support for ISIS and violent jihad, to recruit for ISIS and to attempt to help others join and fight for the group. During this same period, the defendant also expressed her own desire to travel to ISIS-
the field use to assess an individual’s disengagement from a terrorist organization/extremist ideology. A copy of Dr. Vidino’s expert report and his C/V are attached hereto as Exhibits 1 and 1A, respectively.
The government will also call forensic psychologist Dr. Kostas Katsavdakis to testify about his examination of the defendant and his clinical assessment of her. A copy of Dr. Katsavdakis’s expert report and C/V are attached hereto as Exhibits 2 and 2A, respectively.
3 United States v. John Doe, Crim. No. 14-612, 323 F. Supp. 3d 368, 371 (E.D.N.Y. 2018) (JBW).
4 See, e.g., https://www.cnn.com/2019/02/26/opinions/isis-bride-hoda-muthana-citizenship-callan/index.html.
controlled territory and join the group and die as a martyr. She also created and disseminated on social media her own ISIS propaganda, including the ISIS logo next to a photo of then-President Obama with an exploding gun next to his temple. And the defendant did all of this knowing – indeed while openly celebrating – the fact that ISIS and its followers brutally murder people in the United States and around the world. The defendant pleaded guilty to all of this conduct in February 2017, after agreeing to cooperate with the government which, for a certain period, she did.
Then, in 2018, when released on bail prior to sentencing, despite explicit orders from the Court not to do so, the defendant violated the terms of her release and her cooperation agreement by covertly re-connecting and attempting to re-connect with numerous people she herself had identified as supporters of ISIS and other extremist groups, and by seeking out the same pro-ISIS propaganda that she relied on and spread when recruiting for ISIS. The defendant also committed a new crime by attempting to cover up her conduct by deleting her electronic communications to avoid detection by the government and this Court. Finally, when given the opportunity to explain her conduct, the defendant repeatedly lied to the government. For these actions, the defendant was charged with and pleaded guilty to the obstruction of justice offense on March 7, 2019.
And yet, the defendant persists in denying the gravity of her crimes and her responsibility for committing them. Instead, she blames the government, her lawyers, “spies,” and “dar al kufr”\(^5\) for her predicament. For example, in December 2018 the defendant said the following about her case:
I didn’t know it was a conspiracy if you just know the information and talking to officials. It just basically, just how do you say, your first amendment is being violated basically and just because I’m Muslim they even charged me with it because they was saying that I can’t talk to those officials or whatever, but my friends on Facebook and us we was all, like, you know, you know what I mean like we all was supporting whatever because like there was a lot of stuff going on with Islam now these days so they charged me with conspiracy, but I’m fighting it and my lawyers trying to tell the Judge and stuff like that, but they made
\(^5\) The term “dar al kufr” refers to all lands not governed by what jihadists deem to be the correct interpretation of the sharia, a “land of disbelief.” See Vidino Rpt. at 25. The word “kuffar” or “kufr” is a deeply pejorative term frequently used by the defendant to attack others. The term is commonly translated as meaning infidel, rejecter or disbeliever and refers to people “who do not believe in Allah and reject Muhammad’s prophecy.” Id.
Indeed, as recently as February 24, 2019, the defendant wrote an email to an associate stating: “I did not do anything wrong as a Muslim but a cyber crime in social media which is a violation in USA to support certain shari’ah islaamia so al maghreb tul horriya.” See Exhibit 3.
II. Procedural and Factual Background
On November 15, 2016, the defendant was arrested at John F. Kennedy International Airport and charged in a criminal complaint with attempting and conspiring to provide material support and resources to a foreign terrorist organization, to wit, ISIS, in violation of 18 U.S.C. § 2339B(a). From November 18, 2016, forward, the defendant was detained at the Metropolitan Detention Center in Brooklyn, New York (“MDC”).
On February 13, 2017, pursuant to a cooperation agreement with the government, the defendant pleaded guilty to one count of conspiracy to provide material support to a foreign terrorist organization (the “Material Support Offense”). In April 2018, based on the claim that her health was deteriorating at the MDC, the defendant sought release on bail pending sentencing, which this Court granted, subject to stringent conditions. Within months, the defendant violated numerous terms of her release and materially breached her cooperation agreement by, among other things, committing a new crime and making multiple false and misleading statements to the government about her conduct while on release. As a result, the government was released from its obligations under the cooperation agreement and will not file a motion seeking any sentence reduction pursuant to U.S.S.G. § 5K1.1, all of which was previously noticed to the defendant.
On March 7, 2019, the defendant pleaded guilty to one count of obstruction of an official proceeding (the “Obstruction of Justice Offense”), in violation of 18 U.S.C. § 1512(c)(1), a crime which, as noted above, the defendant committed while on release pending sentencing on the Material Support Offense.
The defendant now faces sentencing before this Court for both the Material Support Offense and the Obstruction of Justice Offense. Additionally, because the defendant committed the Obstruction of Justice Offense while on bail, she faces an additional mandatory punishment pursuant to 18 U.S.C. § 3147.
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6 The defendant made these statements during a recorded jail call to an associate on December 14, 2018.
7 This exhibit, along with several others referenced herein, are provided as illustrative and non-exhaustive examples of the defendant’s conduct and her denial of responsibility for her crimes. Copies of the exhibits will be provided in hard copy to the Court and defense counsel under separate cover.
A. The Material Support Offense
The Court is well-versed in the facts of the defendant’s Material Support Offense, which are set forth in detail in the Presentence Investigation Report (PSR) prepared by the United States Probation Department (Probation). See PSR ¶¶ 5-40. It is nevertheless important to focus on the critical aspects of the defendant’s criminal conduct.
The record – including her own allocution at her 2017 guilty plea hearing – is unambiguous; the defendant did not limit herself to merely expressing support for ISIS or its violence, or associating with “her friends” who happen to support ISIS. Rather, for at least 11 months until her arrest in November 2016, the defendant actively sought to support and assist ISIS and conspired with others to do so. Here is how the defendant described her conduct in her 2017 allocution:
The Court: Okay. All right. So, can you tell me, in your own words, what you did that makes your guilty of the charge?
Defendant: Yes, I will. From January 2016 to November 15 -- 2016, I knowingly and intentionally agreed with others to provide material support to foreign terrorist organization, that I know is run by Dawla or Islamic State.
This is the same organization that the U.S. Government calls “ISIS” or “ISIL.” At the time, I agreed with others to provide material support to Dawla. I was aware that they’re engaged in terrorist activity and that the U.S. government had this (inaudible) as a terrorist organization.
Specifically, I was aware that ISIL had claimed responsibility for the attacks in Paris and in Brussels that happened in 2015 of November and March 2016. I am aware that these attacks involved the use of firearms and explosives, and that they were intending, and, did endanger the safety of one or more individuals. I worked as an assistant to the other members more than once. I put U.S. based individuals who wanted to make [Hijrah] or migration to the Dawla in touch with the other members who were based overseas. I did this by passing the [T]elegram contact information of the other members to these U.S. based individuals, telegram is sent encrypted messaging application. I put these U.S. based individuals in
touch with all the members on [T]elegram[] so that they would have contacts in Dawla, who could help them travel overseas to the territory controlled by Dawla.
I believed that if these individuals made it to Dawla, they would join the group and work under its directions and control. I personally spoke on a [T]elegram and other social network applications to Dawla members whose contact information I passed to these individuals. When I passed the information on [T]elegram to contact the Dawla members, I was in the United States, Brooklyn, at the time. I also intended to make [Hijrah] to Dawla to join the group. First, I was going to -- to move to Swede to get married to a Dawla supporter, and after that we agreed to get married in -- to go to make [Hijrah] to Dawla to control the territory.
Feb. 2017 Plea Tr. at 25:16 – 27:7.
It is crucial to understand the meaning of the Arabic word “hijrah” or “hijra” as used by the defendant. She repeatedly used the term during her work for ISIS in 2016. As explained by Dr. Vidino:
*Hijrah* in the Qur’an refers to the prophet Muhammad’s (and his followers’) migration from Mecca—his place of birth and upbringing—to Medina in 622 CE to flee persecution. Those who followed Muhammad were the first converts and followers of Islam and demonstrated their faith by fleeing with Muhammad before fighting alongside him and helping establish the first Islamic society.
For jihadists, *hijrah* is a term used predominantly for supporters/followers in countries outside the operational zones of the jihadist group to travel to those zones and join the group. To make *hijrah* is to travel from a “land of disbelief” (see later) to a territory where a jihadist group has created or seeks to create what it deems a perfect Islamic society.
Vidino Rpt. at 23.
There is no ambiguity about which meaning of “hijrah” the defendant intended while providing material support to ISIS. It was not the innocuous version. She and her associates, including those with whom she conspired to provide material support, repeatedly
used the term in conjunction with joining ISIS, waging jihad and committing violence. For example, on February 21, 2016, the defendant posted on Facebook, in Arabic, “Let’s go . . . let’s go like the soldiers.” This post was accompanied by emoticons of a knife, a gun and a bomb. Moreover, in a series of Facebook posts in around June 2016, in which the defendant was discussing her search for a husband and her desire to get out of “dar ul kufr,” the defendant wrote, “I want to complete everything before I die in jihad” and then, regarding the type of husband she was searching for “… I want a mujahid who wants jihad and hijra.” See Exhibit 4.
In another Facebook post from the same period, the defendant wrote “… y’all need to wake up ummah fear Allah and do hijrah and jihaad our ummah is dying and we will establish tawheed. . . . Allahu Akbar.”
In yet another Facebook post, the defendant wrote, “If a brother says he want to do hijrah but don’t want fight or kill kufar . . . hmmm is he a coconut8???” In other words, in the defendant’s warped view, a man who wanted to make “hijrah” without wanting to kill “kufar” – unbelievers – is not a true Muslim.
These – and the many other similar posts written by the defendant – did not occur in a vacuum. On the contrary, she wrote in support of making hijrah to join ISIS and killing non-believers and dying as a martyr while ISIS and its followers were committing acts of brutal violence around the world, and while she herself was providing material support to the group by recruiting and facilitating for it.
Moreover, in lengthy Mirandized interviews following her November 2016 arrest, the defendant described her conduct in detail, making clear that she considered herself an important person in helping people to join ISIS. At one point, when explaining why someone who wanted to make hijrah and join ISIS would come to her for help, the defendant explained that she is “a good router” who could ask one of her contacts in ISIS “what gates are open and what gates are closed,”9 referring to access points into ISIS-controlled territory.
At another point in her interview, the defendant was asked how law enforcement could know that she was telling the truth about her work for ISIS. The defendant immediately
8 “Coconut” is a derogatory term used by jihadists to describe a Muslim who is not truly dedicated to Islam; a Muslim is a “coconut” if they are “brown (true in faith) on the outside, white (disbeliever) on the inside.” Vidino Rpt. at 27.
9 The defendant made this statement during a video-recorded interview by the FBI on November 16, 2016.
responded, “Give me a phone, let me sign up, let me sign back in on Facebook and on Telegram . . . I’ll show ya’ll proof.”\(^{10}\)
By her own account – as well as a wealth of corroborating evidence – the defendant sought to aid at least five people join ISIS abroad; each is discussed in turn.
1. **Facebook User 1**
In February 2016, the defendant used one of her many Facebook accounts to post the following quotation attributed to now-deceased al-Qaeda in the Arabian Peninsula (“AQAP”) leader Anwar al-Awlaki: “Running away from Jihad will not save you from death, You can die as a coward or you can die as a Martyr!”\(^{11}\) Another Facebook user who expressed extremist pro-ISIS views online (“Facebook User 1”) commented in response to this post: “True I would love to die as a shaheed it a big honor.”\(^{12}\) If there were any question as to the defendant’s use of the word hijrah and her intent to help ISIS commit violence, even if she herself did not commit it, she answered it when she responded, “Then do hijrah.” See Exhibit 5.
The defendant then helped Facebook User 1 try to join ISIS. She posted a screenshot of an ISIS operative (“ISIS Operative 1”) and instructed Facebook User 1 to “Add him he will guide you,” meaning guide Facebook User 1 to join ISIS. See id. This response was followed by an emoticon of an airplane, further demonstrating the defendant’s intent to facilitate Facebook User 1’s travel to ISIS-controlled territory to join ISIS. The defendant also admitted in her post arrest statements to law enforcement that she was attempting to connect Facebook User 1 to ISIS Operative 1 so that Facebook User 1 could join ISIS.\(^{13}\)
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\(^{10}\) The defendant made this statement during a video-recorded interview by the FBI on November 17, 2016.
\(^{11}\) Before his death, al-Awlaki was an influential American-born Islamic lecturer who and leader of AQAP, a designated foreign terrorist organization, who espoused violent jihad against Westerners and encouraged the emigration of foreign fighters to lands around the world where Muslims were perceived to be under attack. He died on or about September 30, 2011.
\(^{12}\) “Shuhada” is the concept of martyrdom (death by fighting in jihad), encompassing an act of testimony of one’s belief through martyrdom. A “Shaheed” is a person who has achieved martyrdom. While the term conceptually is not specific to jihadist groups, jihadists have seized shuhada as a term reserved for their fighters. In particular, someone who engages in a suicide operation, or an attack operation where the outcome is near-certain death, is a shaheed. Vidino Rpt. at 23.
\(^{13}\) The defendant made this statement during her November 30, 2016 proffer with the government.
There is no mystery here; the defendant was talking to Facebook User 1 about violent jihad, and encouraging him to engage in it. Then, the defendant put action behind her words by providing to Facebook User 1 the contact information for ISIS Operative 1. After her 2016 arrest, the defendant identified ISIS Operative 1 as an individual she believed to be in Libya who wanted to help people travel to join ISIS. As context, prior to her arrest in 2016, after the defendant used Facebook to post a news article about a new automatic weapon being sold, ISIS Operative 1 wrote in response, “I love it I wish I can have 3 of it for the future use on the taghout head.”\(^{14}\)
The defendant also admitted that after ISIS Operative 1 changed his Facebook user name to a new name, she provided the new name to Facebook User 1. The defendant also told the government that she eventually stopped talking to ISIS Operative 1 because she believed he was going to war.
Disturbingly, in June 2018, while on release pending sentencing the defendant attempted to re-establish contact with ISIS Operative 1 but was unable to reach him.\(^{15}\)
2. “Abu Talib”
In April 2016, unbeknownst to the defendant, a confidential source working at the direction and under the supervision of the FBI contacted the defendant posing as a U.S.-based male with the persona “Abu Talib” seeking to travel overseas to join ISIS. In a series of text exchanges in April 2016, the defendant instructed Abu Talib on the best routes for making hijrah to ISIS-controlled territory. The defendant then provided Abu Talib with the contact information for Abu Sa’ad al-Sudani, also known as “Abu Isa Al Amriki,” (“Abu Isa”) on an Internet messaging application used by the defendant for ISIS-related communications throughout 2016. The defendant described Abu Isa to Talib as the “head master for the mujahideen” and “head master For t brothers in Libya or turkey etc” who was in charge of “Khalifah News.”\(^{16}\) The defendant then told Abu Talib “No you need to listen to me unless you want to go to jail” and then “U need routes and good route and trust nobody.”
\(^{14}\) “Taghout” is an Arabic word often denoting idols, Satan and “jinn,” a bad or evil spirit.
\(^{15}\) The defendant admitted this during her January 2, 2019 interview with the government at which her defense attorneys were also present.
\(^{16}\) “Khilafah” means “Caliphate,” and the term is commonly used by ISIS supporters to refer to areas under ISIS’s control. “Khilafah News” is the name of both a website and an internal private messaging group on OCS, which the defendant previously used to communicate with ISIS supporters and which she described in detail as a significant source of news about the group, including links to jihadist material and information about ISIS links to terrorist attacks. The defendant has used several alternative spellings of the term, including “Khalifah” and “Khilafa.”
passing on Abu Isa’s contact information to Abu Talib, the defendant told Abu Talib, “He will lead you.” See Exhibit 6.
As context, Abu Isa was an ISIS operative and external attack planner based in Syria who, along with his wife, Shadi Jabar Khalil Mohammad, also known as “Umm Isa al-Amriki” (“Umm Isa”), actively recruited and communicated with potential ISIS recruits. In May 2016, the United States Department of Defense (the “DOD”) announced that Abu Isa and Umm Isa were killed by coalition airstrikes near Al-Bab, Syria.\(^{17}\) The DOD identified Abu Isa and Umm Isa as “involved in planning attacks against the United States, Canada and the United Kingdom” and “active in recruiting foreign fighters in efforts to inspire attacks against Western interests.”\(^{18}\) In 2016, the defendant exchanged hundreds of electronic communications with Umm Isa.
To cite just one example of Abu Isa’s work for ISIS, on January 17, 2017, Emanuel Luchtman was sentenced in federal court in the Northern District of New York to 20 years’ imprisonment and 50 years’ supervised release for conspiring with Abu Isa to provide material support to ISIS by conducting a terrorist attack in Rochester, New York.\(^{19}\) Luchtman admitted to conspiring with Abu Isa and planning to “conduct an attack against civilians using knives and a machete on New Year’s Eve in 2015.” Id. Luchtman “intended to conduct an attack that could be claimed by [ISIS] and that could also help him gain membership into [ISIS] when he thereafter traveled overseas to join the terrorist organization.” Id.
Abu Isa also played a pivotal role in radicalizing Abdulrahman El Bahnasawy, a Canadian citizen who in 2018 was convicted of terrorism offenses in the United States. Abu Isa encouraged El Bahnasawy to participate in an attack for ISIS in the United States that Abu Isa was coordinating, and in May 2016, El Bahnasawy was arrested while traveling to New York City to conduct an attack there. Specifically, El Bahnasawy had planned to detonate bombs in Times Square and the New York City subway system and to shoot civilians at concert venues. El Bahnasawy subsequently pleaded guilty in the Southern District of New York to multiple terrorism offenses and, on December 18, 2018, was sentenced to 40 years’ imprisonment and a lifetime of supervised release.\(^{20}\)
\(^{17}\) See https://dod.defense.gov/News/Transcripts/Transcript-View/Article/752789/department-of-defense-press-briefing-by-pentagon-press-secretary-peter-cook-in/.
\(^{18}\) Id.
\(^{19}\) See https://www.justice.gov/opa/pr/new-york-man-sentenced-20-years-conspiring-provide-material-support-isil-connection-planned.
\(^{20}\) See https://www.justice.gov/opa/pr/abdulrahman-el-bahnasawy-sentenced-40-years-prison-plotting-carry-out-terrorist-attacks-new.
Once the defendant connected them in April 2016, Abu Isa and Abu Talib began communicating via an Internet messaging application. Abu Isa ultimately connected Abu Talib to El Bahnasawy,\(^{21}\) who was residing in Canada at the time. After exchanging a series of communications over an Internet messaging service, El Bahnasawy sent Abu Talib bomb making instructions and encouraged Abu Talib to conduct an attack on the New York City subway system.
The defendant was no passive bystander to all this; she actively attempted to facilitate Abu Talib’s travel to ISIS-controlled territory in order to join ISIS and connected Abu Talib to Abu Isa, a bona fide ISIS operative who, before he was killed in coalition airstrikes, issued directives to individuals to carry out attacks in the United States. After providing Abu Isa’s contact information to Abu Talib, the defendant further advised Abu Talib on how to connect with the operatives. This included the defendant instructing Abu Talib on what to say when ISIS operatives asked him questions to test him. The defendant also sought to help Abu Talib avoid detection by law enforcement, warning him to “encrypt ur phone now because our devices record by kuffar.”\(^{22}\) Indeed, the defendant carried enough weight with ISIS that Abu Talib successfully used the defendant’s name to vouch for him when questioned about how he had received Abu Isa’s contact information. See PSR ¶¶ 19-24.
And the defendant went further still. In July 2016, after several months without contact, she proactively contacted Abu Talib via Facebook. At this point, the “Abu Talib” persona, previously played by a source working under FBI supervision, was now played by an undercover FBI agent. The defendant told Abu Talib, “I can get you visa for shams . . . My visa approve for shams to make hijrah . . . so they told me to tell you . . . you don’t have to send no money just get visa application and I send you invitation letter.” See Exhibit 7. In other words, the defendant sought out a man whom she believed wanted to travel abroad to join ISIS and promised to help him obtain a visa to do so.
The defendant also told Abu Talib that Abu Isa and Umm Isa had been killed in airstrikes. She then gave Abu Talib the contact information on an Internet messaging application for an individual with the display and user names “Manager” and “Eastern Standard” (hereinafter “Manager”). The defendant told Abu Talib that Manager and another ISIS facilitator abroad using the name “Centre”\(^{23}\) on the Internet messaging service had taken over for Abu Isa and Umm Isa after their deaths. PSR ¶ 27. The defendant told Abu Talib,
\(^{21}\) El Bahnasawy is referred to as “ISIS Supporter 1” in both the filed criminal complaint and the PSR in this case.
\(^{22}\) “Kuffar” or “kufr,” a term frequently used by the defendant, refers to people “who do not believe in Allah and reject Muhammad’s prophecy. Some jihadists declare other Muslims, who disagree with their interpretation of the religion, as ‘Kuffar’ in a practice known as a ‘takfir.’” Vidino Rpt. at 25. The defendant sometimes spells this “kafir.”
\(^{23}\) The name “Centre” on the Internet messaging service is spelled several different ways, including “Senter” and “Center,” but is spelled “Centre” herein.
referring to her own role under Manager and Centre, “they put me as assistant to help them out because all gates are closed except for Afghanistan so we needs Muslimin.” See Exhibit 7. This exchange alone makes clear the defendant viewed herself as an “assistant” to ISIS facilitators abroad whose role was to help recruit people inside the U.S. travel to join the group. It is also exactly how the defendant described her role to the FBI after her 2016 arrest.
Indeed, as the defendant explained in detail in her post-arrest statements to the government, and as confirmed by the FBI, Manager was an ISIS facilitator operating in Pakistan, and Centre was an ISIS facilitator operating in Afghanistan.
The FBI has also confirmed that a telephone recovered from Centre contained the defendant’s name, address, and telephone number.\(^{25}\)
3. “Safiyya Mu”
In early 2016, a second confidential source working under the supervision of the FBI and using the female persona “Safiyya Mu” (“Mu”) initiated contact with the defendant via Facebook. The defendant and Mu discussed Mu’s desire to travel abroad to join ISIS. The defendant then provided Umm Isa’s contact information on an Internet messaging service and instructed Mu “if u serious about making hijrah then download [the Internet messaging application] and add the head sister committee leader.” The defendant told Mu that Umm Isa “helps sister and has to make sure ur not a spy.”\(^{26}\)
When Mu informed the defendant about difficulty contacting Umm Isa via the Internet messaging service, the defendant further assisted Mu by sending Mu a screenshot of Umm Isa’s Internet messaging service address/name/profile. Then, in May 2016, the defendant and Mu started communicating via the Internet messaging service. During one
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\(^{24}\) The defendant provided this information during her November 15, 2016 video-recorded statement to the FBI.
\(^{25}\) The information was contained in the “Notes” section of the cell phone.
\(^{26}\) The defendant frequently used the term “spies” throughout 2016 to refer to individuals who might try to undermine ISIS. For example, in March 2016, the defendant posted a screenshot titled “Anonymous Spy Wanted DEAD.” See Exhibit 8. The screenshot included a photograph of the targeted individual as well as his phone number, address and what appears to be a satellite image of the area around his home. The defendant called the person a “spy,” and a “filthy kafir in the U.S. trying to mess with Muslims and possibly get them arrested,” and asked people to “please share” the targeted individual’s information. The defendant reverted to this language again in 2018 while on presentence release.
exchange, the defendant asked Mu, “R u ready to make hijrah Inshallah because they need sister now. . . . asap.” When Mu asked what she should do, the defendant sent Mu a photo of Manager’s Internet messaging service account and stated that Manager “gives you help with anything.” Then, in June 2016, the defendant followed up and instructed Mu via the Internet messaging service that “Manager is looking for you,” and asked Mu “Why you don’t reply to him.” The defendant, in other words, repeatedly and proactively sought to connect Mu to Manager for the purpose of adding a new recruit for ISIS.
4. **Individual 2**
At the end of June 2016, the defendant began communicating via Facebook with a U.S.-based individual who was previously convicted in Florida state court for armed robbery and assault on police officers (“Individual 2”). Individual 2 was released from prison in or around February 2016. PSR ¶ 28.
The defendant and Individual 2 began discussing Individual 2’s desire to make hijrah to join ISIS, and the defendant provided Individual 2 with the contact information for ISIS facilitators Manager and Centre on the Internet messaging service. Specifically, on July 3, 2016, the defendant sent Individual 2 a series of messages about contacting Manager and Centre for the purpose of traveling abroad to support ISIS. She told Individual 2, “Now we can go to my contact for hijrah,” “They are serious,” “They don’t play games” and “You must add all groups to stay updated with dawla.” See Exhibit 9. The defendant then sent a list of chat groups on the Internet messaging service that she told Individual 2 to join in order to stay current with news from ISIS. PSR ¶¶ 29-30. Several of these groups, including “Khilafah News,” are the same virtual groups or versions of the same groups that the defendant re-joined or searched for while on presentence release in June 2018.
Then, on July 4, 2016, after a series of exchanges on the Internet messaging service, the defendant told Individual 2, “my contact ppl will text you later.” Later that day, the defendant sent to Individual 2 screen shots of the Internet messaging service pages for Manager and Centre and instructed him, “They said contact them directly” and “text them.” PSR ¶ 30. The defendant later followed up with Individual 2 via the Internet messaging service, inquiring what happened.
As a result of the defendant’s connecting them, Individual 2 engaged in a series of exchanges with Manager using the Internet messaging service during which they discussed Individual 2’s desire to make hijrah to ISIS-controlled territory. After making the initial connection, the defendant remained involved; on July 7, 2016, Individual 2 sent the defendant a screenshot of his conversation with Manager on the Internet messaging service in which Manager instructed Individual 2 that, because the travel to ISIS-controlled territory would take too long for Individual 2, “it would be better for u to do work there. Till then. And scare them.” PSR ¶ 31; Exhibit 9A. The defendant later told the government that she understood
Manager to be encouraging Individual 2 to do something for ISIS inside the United States, “like a robbery.”
Individual 2 also contacted Centre using the contact information provided by the defendant. Centre asked Individual 2 what he wanted to do and, using coded language, Individual 2 said he wanted to make hijrah to Iraq or Syria. Also Individual 2 also offered to send money in support of ISIS to Centre. PSR ¶ 31.
Two days later, on July 9, 2016, Individual 2 was arrested for violating the terms of his probation by traveling to New York, where he met with the defendant. Individual 2 was later sentenced in Florida state court to approximately five years’ imprisonment.
In August 2016, the defendant received approximately $250 through Western Union from an individual in Afghanistan and was later told by Centre, via the Internet messaging service, that the defendant received the money because “u did big work” PSR ¶ 33; see also Exhibit 10. The defendant likely received this payment from ISIS for her recruiting efforts.
The defendant provided this information during her November 15, 2016 video-recorded interview with the FBI.
B. The Defendant’s Plans to Join ISIS Abroad
In addition to her role as an ISIS recruiter and facilitator as described above, the defendant herself planned to travel abroad to join ISIS. PSR ¶¶ 35, 37. In her plea allocution quoted above, she stated that she “intended to make [Hijrah] to Dawla to join the group,” meaning ISIS. Feb. 2017 Plea Tr. at 27:3-7. At one point in 2016, she obtained a visa to travel to Afghanistan and communicated with Centre through the Internet messaging service about her plans to travel abroad to join ISIS. And, in a conversation using the Internet messaging service with another individual in approximately September 2016, the defendant expressed her desire to travel to Afghanistan in November to “fight for Allah and be shaheeda” – a martyr. The defendant also told the FBI following her arrest that in 2016 she obtained from Centre a visitation letter in support of her visa application to Afghanistan.
D. The Obstruction of Justice Offense
On March 7, 2019, the defendant pleaded guilty to the Obstruction of Justice Offense arising from her deletion of at least 1,000 electronic communications while released on bail. The defendant admitted that she deleted these messages with the intent to conceal them from the government. As part of her plea, she also admitted to knowingly and intentionally making multiple false statements when interviewed by the government on January 2, 2019 (the “January 2019 Interview”). See March 2019 Plea Tr. at 32:8-12; 35:17-36:25.
The Obstruction of Justice Offense – and the facts surrounding it – are significant and deeply troubling. Understanding the scope of the defendant’s conduct subsequent to her presentence release in April 2018 is essential to understanding both the new crime to which she pleaded guilty and the threat she continues to pose. That conduct is discussed here.
On April 27, 2018, while pending sentencing, the defendant made a bail application and was released on bond subject to stringent release conditions. Among other things, the defendant was barred from using any computer or mobile communication device without the prior notification to and consent of Pretrial Services and/or the FBI. Her computer usage was limited to educational and vocational research. She was also prohibited from knowingly contacting individuals or organizations affiliated with foreign terrorist organizations, or individuals or groups that promote violence for the purpose of effecting political change. Her cellular telephone use was limited to contacting her counsel, treatment providers, sureties, the residential staff of the location where she would be residing on pretrial release, the U.S. Attorney’s Office or the FBI, or to call for assistance in the event of a medical or other grave emergency. To facilitate the monitoring of her communications, the defendant’s presentence release terms required that all of her communications via telephone or computer be in English.
Within weeks of her release, the defendant violated her bond conditions by, among other things, obtaining and using a laptop without the knowledge or consent of Pretrial Services, downloading and using multiple cell phone applications without the knowledge or consent of Pretrial Services, and creating and using multiple Facebook accounts under various
pseudonyms to contact and attempt to contact numerous people, including individuals she previously identified to the FBI as supporters of ISIS or other extremist groups. On July 19, 2018, following a hearing on the violations, the Court revoked the defendant’s bond and remanded her to the Metropolitan Correctional Center (“MCC”).
The government conducted an extensive investigation into the scope and content of the defendant’s communications and activities while on presentence release. The investigation revealed that in just a couple of months, the defendant illicitly created numerous pseudonymous social media accounts, including at least three Facebook accounts, and used them to contact or attempt to contact at least seven people she previously identified to the FBI as supporting ISIS or other extremist groups.
The defendant also contacted or attempted to contact other individuals about whom she did not previously provide information to the government, but who have expressed support for ISIS or are associated with ISIS supporters.
The defendant also searched for and initiated Facebook communications with an individual whom she previously identified to the FBI as associated with United Kingdom-based ISIS supporters linked to terrorist attacks (“Facebook User 3”). Specifically, on June 13, 2018, after Facebook User 3 posted “Be very careful as to who you trust on here especially if they send you any links that maybe incriminating,” the defendant posted the following response on Subject 3’s Facebook page: “Yea that’s true that how I went to prison because some the Muslims were spies :(. See Exhibit 12.
The defendant also contacted another former associate via Facebook whom she previously identified to the government as an ISIS supporter (“Facebook User 4”). Facebook User 4, an admitted former ISIS supporter, pleaded guilty in the Eastern District of New York in 2017 to one count of access device fraud and is currently serving a term of probation in Florida.
The defendant also engaged in Facebook communications with an individual based in Belgium with whom the defendant had been in contact before her 2016 arrest.
As background, in February 2016, the defendant and Facebook User 5 engaged in a multi-user Facebook posting exchange with ISIS Operative 2 to whom, as set forth above, the defendant referred people for help traveling to ISIS-controlled territory. During her cooperation the defendant did not disclose her contact with Facebook User 5 to the government.
Following her presentence release in June 2018, the defendant again searched for and communicated with Facebook User 5 in an exchange conducted mostly in Arabic. In this conversation, the defendant told Facebook User 5 that she used to be with the Islamic State and had been in jail, to which Facebook User 5 responded, “Me too,” and stated that he had also been in jail. The defendant subsequently deleted from her own Facebook account all of her written communications with the Facebook User 5. Nevertheless, the government was able to obtain copies of the communications and learned that, in addition to their written exchanges, the defendant and Facebook User 5 also engaged in an approximately 40-minute-long voice call.
The defendant also “friended” Facebook User 8, whose posts dating back to 2016 demonstrate support for ISIS and contain numerous ISIS propaganda videos, including one stating, “May Allah grant victory to the Mujahideen and destroy the Tawagheet, Mishrikeen and Munafiqeen and all enemies of Islaam. Ameen!”
The defendant also admitted during the January 2019 Interview to unsuccessfully trying to contact a man she previously identified to the government as [redacted] (“ISIS Operative 3”). When asked during the January 2019 Interview why she attempted to re-contact ISIS Operative 3, the defendant said she did so to get information on the status of ISIS. When asked why she would contact ISIS Operative 3 for that purpose, the defendant responded that she was “curious.”
As part of her March 2019 plea to the Obstruction of Justice Offense, the defendant admitted to deleting her communications with numerous Facebook accounts to prevent Pretrial Services and the FBI from finding the messages because she knew the communications violated her bond conditions and the terms of her cooperation agreement. The defendant’s conduct was calculating and deceitful. On June 28, 2018, the day before she was to meet with Pretrial Services, she used Facebook to tell at least eight of her associates, including Facebook User 5, that she was about to delete her Facebook accounts. She did this because she knew if she did not delete them, Pretrial Services would find the messages the next day. The defendant also provided many of these people alternative means of contacting her, showing that she planned to use other communication platforms to continue her illicit contacts. The defendant also admitted to instructing others with whom she was
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29 The defendant provided this information to the government during proffer sessions on November 30 and December 7, 2016.
communicating via Facebook to delete their Facebook messaging conversations with the defendant from their own accounts, including Facebook User 4, described above.
E. The Defendant’s Re-Engagement With ISIS and Extremist Propaganda, and Her Denials of Responsibility
In addition to contacting and attempting to contact ISIS supporters with whom she previously communicated, the defendant also resumed consuming ISIS-related news and propaganda while on presentence release.
For example, the defendant searched for the internet group Khilafah News, which she previously used to communicate with ISIS supporters and which she described to the government as a significant source of news about the group, including links to jihadist material and information about ISIS links to terrorist attacks.
The defendant also searched for AMAQ News, an ISIS-linked news outlet that is often the first point of publication for claims of responsibility for ISIS attacks, and for Tawheed Network, which she previously described as a secret pro-ISIS Facebook group where she communicated with ISIS-supporters, including individuals she claimed were involved in the June 2017 London Bridge attacks.
The defendant’s cell phone records also indicate she was conducting searches for “iSlamic state videos,” that she downloaded the app “ISIS Watch,” which offers “full coverage of ISIS news,” and that she bookmarked on her cell phone’s internet browser the search results within the Al Jazeera website for “ISIS 2018.”
While on presentence release the defendant also sent numerous Facebook messages in which she indicated that her actions leading to her conviction for conspiring to provide material support to ISIS were not wrong and that she does not bear responsibility for them. For example, on June 13, 2018, the defendant wrote to another individual “I didn’t do any thing . . . they snitched on me.” That same day, the defendant also wrote, “I am praying for all muslimin locked up as I was once was a prisoner in dar ul kufr and won’t let anyone else put in jail ever... I will watch who is my true friends of jannah [smiley face emoji]”. The defendant also wrote “I’m not going to add spies,” again reverting to her pre-arrest trope of ISIS operating against a network of “spies” in the land of “kufr” or infidels. See Exhibit 13.
On June 25, 2018, the defendant wrote “…I didn’t do anything wrong under Islam but stand up for my deen and got arrested for what I believe in but you have Muslim here did dangerous crimes like drugs etc but they don’t want to say sh** isn’t bad but temptation of this dunya got all of us!! I’m focus to beware of what it is..” See Exhibit 14. In other words, more than a year after pleading guilty to providing material support to ISIS, and while she was in the middle of violating this Court’s conditions of release, the defendant was publicly denying responsibility for her actions and claiming that her only offense was standing up for her religious beliefs.
F. The Defendant’s False Statements to the Government
During the January 2019 Interview the defendant was given the opportunity to explain her conduct on presentence release. Instead, she lied and deceived, repeatedly. While truthful about certain activities, the defendant was evasive on numerous topics and provided many answers that were incomplete, inaccurate and intentionally false. Also, by the time of the January 2019 Interview, the defendant knew from the government’s in-court statements and filings related to her bond revocation that the government knew certain information about her activities on release and had already obtained evidence of some of her statements. Thus, at multiple points in her interview, the defendant admitted what she believed the government already knew and denied or attempted to mislead the government about new information that the government had not previously revealed in court.
The defendant’s most troubling lies during the January 2019 Interview were her claims that she never used the name “Umm Nutella” to identify herself to others while on presentence release in 2018. As background, throughout her work for ISIS in 2016, “Umm Nutella” was the defendant’s “kunya.” As Dr. Vidino explains in his report, in the jihadist world in which the defendant operates, a “kunya” is an adopted *nom de guerre*. Vidino Rpt. at 25-26. The name “Umm Nutella” was how the defendant identified herself to the other ISIS operatives and supporters with whom she communicated.
The defendant falsely told the government during the January 2019 Interview that she had not identified herself as “Umm Nutella” while on presentence release. To the contrary, at least twice the defendant identified herself on Facebook as “Umm Nutella.” Specifically, on June 13, 2018, the defendant contacted Facebook User 3 via Facebook and wrote, “I’m umm nutella” and “I’m staying on down low” and “lie in not going to go to prison for nobody anymore.” See Exhibit 15. As set forth above, the defendant previously identified Facebook 3 as an ISIS supporter.
That same day, the defendant identified herself as “Umm Nutella” to another Facebook User (“Facebook User 7”). Worse still, when interviewed by the government about this in January 2019, in addition to falsely denying that she identified herself as Umm Nutella, the defendant also denied any recollection of Facebook User 7’s name or of contacting the account, despite the fact that she *initiated the exchange* and began it by writing, “It me” and then “Do you remember” and “I’m umm Nutella” and then “The only one lol.” The defendant also wrote to Facebook User 7, “just got out of prison….and not going back never” and “I didn’t do anything. . . . They snitch on me.” See Exhibit 16.
Because the defendant illegally deleted so many of her Facebook communications, it is impossible to know how many other times she may have identified herself by her ISIS kunya while on presentence release.
The defendant admitted at her March 2019 plea hearing that she intentionally lied to the government during the January 2019 Interview about using her “Umm Nutella” ISIS kunya while on presentence release. See March 2019 Plea Tr. at 32, 35-37. These lies are significant and deeply troubling. The defendant has associated the name with her support for
ISIS since 2016 and told the government, unambiguously, that if she used the name “Umm Nutella” it would mean she was “back supporting ISIS.” And yet, in the January 2019 Interview, when asked at least five separate times whether she had used the “Umm Nutella” name while on presentence release, the defendant adamantly denied that she had.
The defendant also lied and provided misleading statements about numerous other matters during the January 2019 Interview, including her creation and use of a third pseudonymous Facebook account and her creation and use of an email account. The defendant used this third Facebook account to contact, among others, Facebook User 3 who, as set forth above, is an ISIS supporter based in the United Kingdom. She also provided false and misleading statements about her interactions with Facebook User 5 while on release. At first, the defendant denied any knowledge of Facebook User 5’s account, or the identity of its owner. When confronted with records indicating that she searched for the account and engaged in a lengthy exchange with Facebook User 5, the defendant stated she remembered the exchange but denied knowing who the owner of the account is. Then, when asked about writing to Facebook User 5 “I used to be with the Islamic State,” the defendant admitted to doing so and claimed that she then immediately followed up that statement by writing, in Arabic, that she no longer supported ISIS and was getting her life back together. This is false; there is no record of the defendant making any statement to Facebook User 5 disavowing her support for ISIS. Moreover, the defendant’s claim to not recall the identity of Facebook User 5 is belied by the fact that she interacted with the same account in 2016, and that Facebook records show a 40-minute voice call between her and Facebook User 5 after one of their written exchanges in 2018.
The defendant also provided false and misleading information about her contacts with ISIS-related propaganda outlets while on bail in 2018. Specifically, she denied any knowledge of or connection to the Facebook account “AQAH.” However, Facebook records show that the defendant became “friends” with the AQAH account in June 2018. Moreover, on several occasions the defendant used her Facebook account to “like” postings from the AQAH account. This is significant because at the time she was interacting with the AQAH Facebook account, the AQAH account was posting messages supporting ISIS, including one post that read “Waiting is over . . . Official announcement of Islamic State.”
The defendant likewise made misleading if not entirely false statements about her interactions with “ISIS Watch” app, described above. At first, the defendant denied any knowledge of the app. Then, when shown a record from the search of her cell phone indicating the defendant searched for and sought to download the app to her phone, she acknowledged that she might have viewed the app but denied downloading it. Again, the defendant’s shifting accounts appear aimed at avoiding accountability for interacting with ISIS material.
Records obtained from the cell phone the defendant used on presentence release revealed numerous examples of what appear to be extremist imagery stored on the phone. These included a photo of several individuals in military-style attire labeled “Green Birds,” a
potent symbol used by ISIS to describe those who die as martyrs for the group, and numerous other extremist-related photographs. When shown these photographs during the January 2019 Interview, the defendant could not explain their presence on her phone.
Finally, when given the opportunity during the January 2019 Interview to explain her statements made on presentence release in which she disavowed responsibility for her crime, the defendant at first denied making such statements. Then, when confronted with Facebook records containing such comments, the defendant claimed that any denials of accountability she made on Facebook were intended to cover up her cooperation with the government. The defendant’s self-serving explanation is not credible and is belied by, among other things, the fact that she has continued making similar statements well after her cooperation agreement was terminated. As just one example, as recently as February 28, 2019, the defendant engaged in a recorded telephone call while incarcerated at the MCC, which is excerpted below. In the call with her associate “JA,” a previously convicted felon, the defendant denied responsibility for her actions and equated her material support for ISIS with the legitimate practice of her religious beliefs, as follows:
JA: I know you didn’t do anything. I know that you’re innocent. I know you didn’t understand a lot of things…
…you were trying to survive, you weren’t trying to do anything wrong.
Defendant: Yeah. And I didn’t understand when, when I got arrested and he told me ‘oh you gotta enter a plea and plead guilty’ and I said why do I have to plead guilty, if I feel like I’ve not committed a crime, yes, I understood that United States don’t like certain religious beliefs and don’t allow you to exercise certain beliefs. I did understand that. That was something that was against the law. But I didn’t know it was a crime. You know what I mean? I didn’t know it was a cyber crime [interrupted] No. They said it was a cyber crime. I don’t understand.
---
30 See Vidino Rpt. at 24.
III. The Advisory Guidelines Sentencing Range
A. The Government’s Guidelines Calculation
The government submits that the Guidelines calculation below, which is different from the Guidelines calculation in the PSR, should be applied:
Docket No. 17-CR-48 Count One: Conspiracy to Provide Material Support to a Foreign Terrorist Organization
Base Offense Level (§ 2M5.3(a)) 26
Plus: Offense involved the provision of material support and resource with the intent that they be used to commit or assist in the commission of a violent act (§ 2M5.3(b)(1)(E)) +2
Plus: Terrorism Enhancement (§ 3A1.4(a)) +12
Total: 40
Docket No. 19-CR-117 Count One: Obstruction of an Official Proceeding
Base offense level (§ 2J1.2(a)(1)) 14
Plus: Defendant’s false statements and concealment of evidence resulted in substantial interference with administration of justice (§ 2J1.2(b)(2)) +3
Plus: Offense involved the destruction, alteration, or fabrication of a substantial number of records, documents, or tangible objects (§ 2J1.2(b)(3)(A)) +2
Plus: Defendant committed the offense while on bail (§ 3C1.3; 18 U.S.C. § 3147) +3
Less: Acceptance of responsibility (§ 3E1.1(a)) -2
Less: Acceptance of responsibility (§ 3E1.1(b)) -1
Total: 19
Because the total offense level of 19 calculated for the Obstruction of Justice Offense is more than nine levels less serious than the total offense level of 40 calculated for the Material
Support Offense, the offense level for the Obstruction of Justice Offense is disregarded and does not increase the applicable offense level for purposes of determining the defendant’s Guidelines sentencing range. See U.S.S.G. § 3D1.4(c).
Thus, the combined offense level is 40. Notably, the defendant stipulated as part of her March 2019 plea agreement with the government that her combined offense level is 40. (Mar. 2019 Plea Agreement ¶ 4).
In this case, the defendant’s offense level is enhanced by 12 levels and her Criminal History Category is set at VI as a result of the application of the terrorism enhancement pursuant to U.S.S.G. § 3A1.4(a). The defendant stipulated in her March 2019 plea agreement to the applicability of this enhancement. The terrorism enhancement is the result of legislation passed by Congress in 1994 that mandated that the Sentencing Commission establish a Guidelines enhancement for terrorism offenses to ensure that those convicted of such crimes receive punishment commensurate with the extraordinary nature of their conduct. See United States v. Stewart, 590 F.3d 93, 172 (2d Cir. 2009) (citing Violent Crime Control and Law Enforcement Act of 1994, Pub. L. 103-322, § 120004, 108 Stat. 1796, 2022). The resulting terrorism enhancement at U.S.S.G. § 3A1.4(a) reflects Congress’s intent that individuals convicted of terrorism offenses, like the defendant, serve sentences that are appropriate in light of the extreme dangerousness of their crimes and the unique risk of recidivism that they present. As Judge Walker explained in his concurrence in Stewart:
The import of this enhancement “could not be clearer”: It reflects Congress’ and the Commission’s policy judgment “that an act of terrorism represents a particularly grave threat because of the dangerousness of the crime and the difficulty of deterring and rehabilitating the criminal, and thus that terrorists and their supporters should be incapacitated for a longer period of time.”
Id. at 172-73 (quoting United States v. Meskini, 319 F.3d 88, 91-92 (2d Cir. 2003)). As the Second Circuit explained in Meskini, “even terrorists with no prior criminal behavior are unique among criminals in the likelihood of recidivism, the difficulty of rehabilitation, and the need for incapacitation.” Meskini, 319 F.3d at 92. Thus, the effect of the terrorism enhancement on the applicable Criminal History Category reflects the Sentencing Commission’s assessment of the high likelihood of recidivism, and the corresponding need for deterrence, in terrorism cases such as this one—an assessment the Second Circuit has endorsed. See Stewart, 590 F.3d at 143 (citing Meskini, 319 F.3d at 92).
Based upon the defendant’s Criminal History Category of VI, the advisory Guidelines sentencing range is 360 months’ to life imprisonment. However, because the statutory maximum sentence for the defendant’s Material Support Offense is 240 months’ imprisonment under 18 U.S.C. § 2339B(a)(1), and the statutory maximum sentence for her Obstruction of Justice Offense is 240 months’ imprisonment under 18 U.S.C. § 1512(c)(1), with an additional 120 months’ imprisonment authorized under 18 U.S.C. § 3147, which must
be imposed consecutive to any other sentence of imprisonment, the restricted Guidelines sentencing range is 360 to 600 months’ imprisonment. See U.S.S.G. § 5G1.2(d).
B. The Probation Department’s Errors in Calculating The Guidelines Range
The government’s Guidelines calculation differs from the Probation Department’s Guidelines calculation in two respects. First, the Probation Department erroneously applied the obstruction enhancement under § 3C1.1 to increase the defendant’s total offense level for the Material Support Offense by two levels to offense level 42 (PSR ¶¶ 58-59), and denied the defendant a three level reduction for acceptance of responsibility under § 3E1.1(a) and (b) for the Obstruction of Justice Offense. Notably, the government has not argued that the defendant obstructed the investigation of the Material Support Offense, and the defendant has timely accepted responsibility for the Obstruction of Justice Offense, even while denying responsibility for the Material Support Offense. Thus, the obstruction enhancement should not be applied in determining the offense level for the Material Support Offense and the calculation of the offense level for the Obstruction of Justice Offense should include a total reduction of three levels for the defendant’s timely acceptance of responsibility.
Second, in this case the defendant’s Guidelines sentencing range of 360 months’ to life imprisonment exceeds the statutory maximum sentence authorized for the defendant’s crimes of conviction, not one of which carries a maximum authorized term of life imprisonment. Because the defendant’s Guidelines range cannot exceed the maximum punishment authorized by statute for her counts of conviction, see U.S.S.G. § 5G1.2(b) & app. n.3, the Probation Department calculated the defendant’s restricted Guidelines sentencing range as 360 to 480 months’ imprisonment by combining the maximum sentences authorized for violations of 18 U.S.C. § 2339B(a)(1) and 18 U.S.C. § 1512(c)(1), but erroneously disregarded the additional ten-year term of imprisonment authorized by 18 U.S.C. § 3147. (PSR ¶ 104).
Application Note 3(A) to U.S.S.G. § 5G1.2(b), provides that
the court shall determine the total punishment (i.e., the combined length of the sentences to be imposed) and shall impose that total punishment on each such count, except to the extent otherwise required by law (such as where a statutorily required minimum sentence or a statutorily authorized maximum sentence otherwise requires).
In circumstances where the applicable Guidelines range is higher than the count carrying the highest statutorily authorized sentence, such that “the sentence imposed on the count carrying the highest statutory maximum is less than the total punishment,” then the Guidelines provide that “the sentence imposed on one or more of the other counts shall run consecutively, but only to the extent necessary to produce a combined sentence equal to the total punishment.” U.S.S.G. § 5G1.2(d). Thus, in calculating the restricted Guidelines sentencing range, the maximum authorized terms of imprisonment on each count are added together to determine the restricted upper limit of the Guidelines sentencing range.
The Probation Department followed this approach in calculating the restricted Guidelines range, but neglected to account for the additional term of imprisonment authorized by 18 U.S.C. § 3147, a sentencing enhancement applicable to the defendant’s Obstruction of Justice Offense because the defendant committed that offense while released on bail. Here, 18 U.S.C. § 3147 provides that “A person convicted of an offense committed while released under this chapter shall be sentenced, in addition to the sentence prescribed for the offense, to a term of imprisonment of not more than ten years if the offense is a felony,” and further mandated that “[a] term of imprisonment imposed under this section shall be consecutive to any other sentence of imprisonment.” Because 18 U.S.C. § 3147 authorizes the court to impose an additional 120 months’ imprisonment for the defendant’s Obstruction of Justice Offense beyond the 240 months’ imprisonment authorized by 18 U.S.C. § 1512(c)(1), the Probation Department’s determination of the restricted Guidelines sentencing range should have included that term of imprisonment in calculating the restricted upper limit of the Guidelines range. Accordingly, the correctly calculated restricted Guidelines sentencing range, including the term of imprisonment authorized by 18 U.S.C. § 3147, is 360 to 600 months’ imprisonment.
III. The Appropriate Sentence
Under § 3553(a), “[t]he Court shall impose a sentence sufficient, but not greater than necessary, to comply with the purposes” of sentencing. 18 U.S.C. § 3553(a). Those purposes are “(A) to reflect the seriousness of the offense, to promote respect for the law, and to provide just punishment for the offense; (B) to afford adequate deterrence to criminal conduct; (C) to protect the public from further crimes of the defendant; and (D) to provide the defendant with needed educational or vocational training, medical care, or other correctional treatment in the most effective manner.” 18 U.S.C. § 3553(a)(2). In determining that sentence, this Court must consider “the nature and circumstances of the offense and the history and characteristics of the defendant,” 18 U.S.C. § 3553(a)(1), “the kinds of sentences available,” § 3553(a)(3), the Guidelines and Guideline range, § 3553(a)(4), the Guidelines’ policy statements, § 3553(a)(5), “the need to avoid unwarranted sentence disparities among defendants with similar records who have been found guilty of similar conduct,” § 3553(a)(6), and “the need to provide restitution to any victims of the offense,” § 3553(a)(7).
Here, the statutory sentencing factors call for a sentence within the Guidelines.
A. The Nature and Seriousness of the Defendant’s Conduct, the Need for Just Punishment and the Need to Protect the Public From the Defendant Warrant a Guidelines Sentence
1. The Material Support Offense
The defendant’s Material Support Offense is unquestionably serious. For nearly a year, she devoted herself to and worked on behalf of ISIS, encouraging and attempting to assist in the extreme violence it perpetrates by providing recruits to the group. The defendant was not merely spewing hate from a basement computer or fantasizing about imaginary ties to
ISIS while never actually doing anything to support the group. On the contrary, she was actively involved in recruiting for it. She was, by her own admission, an “assistant” to ISIS and a “good router” who could get ISIS supporters in the United States in touch with the right people abroad. The defendant’s own contact information was found on the cell phone of a confirmed ISIS facilitator abroad. She even received payment from an overseas ISIS facilitator for doing “big work.”
And while her Material Support Offense did not result in a terrorist attack, it is clear the defendant knew she was operating in world and with people where catastrophic violence was not only possible, but often the express goal of the assistance she was providing. When Facebook User 1 posted that “I would love to die has a Shaheed it a big honor,” the defendant instructed him, “then do hijrah” and then connected him to ISIS Operative 1, an individual whom the defendant believed to be in Libya and who wanted to help people travel to join ISIS.
Reckoning with the severity of the offense requires understanding the context in which committed it. In her role as an ISIS recruiter, the defendant worked with extremely dangerous people. To be sure, she is not an El Bahnasawy or Emanuel Lutchman, described above; she did not herself plot to blow up the New York City subway system or attack people with knives. But she worked with Abu Isa, a confirmed ISIS plotter who the defendant herself called the “head master for the mujahideen” and who, before he was killed in an airstrike, helped radicalize El Bahnasawy and helped him and Lutchman plan their thwarted attacks. It is no credit to the defendant that “Abu Talib,” the potential recruit she connected to Abu Isa, was a law enforcement source; the defendant just as easily could have connected Abu Isa to another El Bahnasawy or Lutchman, bent on committing an act of mass murder in the name of ISIS. And the defendant did connect Individual 2, a convicted violent felon, to two ISIS facilitators, one of whom – as set forth above – encouraged Individual 2 that “it would be better for u to do work there” meaning take action in the United States, to “scare them.” See Exhibit 9A. It is, again, no credit to the defendant that Individual 2 was promptly arrested, thereby disrupting him from any potential attack.
Moreover, throughout the period the defendant was posting and writing ISIS propaganda and recruiting for the group, she was keenly aware of the group’s commission and encouragement of extreme violence. And she supported it. In her plea allocation, the defendant acknowledged her familiarity with the March 22, 2016 terrorist attacks in Brussels, for which ISIS claimed responsibility. Those attacks, bombings of a metro station and an airport, killed 32 people and injured hundreds.31 Just a few weeks later, the defendant was assisting Abu Talib to make hijrah to ISIS-controlled territory by connecting him to Abu Isa. She knew the risk this posed.
As another example, at approximately 8:30 p.m. on September 17, 2016, a homemade explosive device detonated on West 23rd Street in the Chelsea neighborhood of
31 See https://www.bbc.com/news/world-europe-35869985.
Manhattan, injuring numerous people and causing significant property damage. The bomb was planted by Ahmad Khan Rahimi, who also planted a similar device which exploded earlier that day in New Jersey, as well as another device in Chelsea which failed to detonate.\textsuperscript{32} On February 13, 2018, U.S. District Judge Richard Berman sentenced Rahimi to two terms of life imprisonment following his conviction at trial for setting off weapons of mass destruction and using explosives in furtherance of a violent crime.\textsuperscript{33}
At approximately 1:30 p.m. on September 18, 2016, less than 24 hours after the Chelsea explosion, the defendant sent news of the bombings, and her support for them, to one of her ISIS contacts abroad. PSR ¶ 35. Specifically, using her “Rita Daoudii” account on an Internet messaging application, the defendant initiated the following message exchange with Centre, one of the ISIS facilitators abroad with whom she worked:
\begin{quote}
9/18/2016 1:29:33 PM(UTC+0), \textbf{[Redacted]} (Rita Daoudii)
As salamualaykum.....
Hope you and mujahedeen is doing great inshaAllah khair....
NJ and NYC is under attack and everyone is wondering if it’s Islamic state so we can make duaa against kuffar
9/18/2016 3:35:14 PM(UTC+0), \textbf{[Redacted]} (Senter)
Walikimasalam....
Alhamdulliha....
Yes
plz send me original local details....
9/18/2016 3:35:45 PM(UTC+0), \textbf{[Redacted]} (Rita Daoudii)
Ok....
Hold on....
\end{quote}
\textsuperscript{32} See https://www.nbcnews.com/storyline/ny-nj-bombings/terror-timeline-ny-nj-bombings-first-blast-arrest-n650716.
\textsuperscript{33} See https://www.nytimes.com/2018/02/13/nyregion/bomber-chelsea-manhattan.html.
New York explosion: 29 injured in 'intentional bomb blast', with second device found in Manhattan
http://www.telegraph.co.uk/news/2016/09/18/explosion-in-new-york-city-25-reported-injuries/....
Also another state under us New Jersey yesterday
9/18/2016 3:38:17 PM(UTC+0), [Redacted] (Senter)
Alhamdulliha....
9/18/2016 3:38:43 PM(UTC+0), [Redacted] (Rita Daoudii)
So is it possible it Islamic state
9/18/2016 3:39:00 PM(UTC+0), [Redacted] (Senter)
sure
9/18/2016 3:39:17 PM(UTC+0), [Redacted] (Rita Daoudii)
Allahu Akbar
9/18/2016 3:39:28 PM(UTC+0), [Redacted] (Senter)
alhamdulliha
9/19/2016 3:48:07 PM(UTC+0), [Redacted] (Rita Daoudii)
Allahu Akbar
Excerpted and attached hereto as Exhibit 17.
The defendant’s words are unmistakable. Her immediate reaction to a violent terrorist attack in the city she lived in was not empathy or concern for the victims or questioning of her support for ISIS. Instead, the defendant tried to verify with one of her ISIS facilitators that the attack was ISIS-related. When she was told “sure,” she provided positive reinforcement with the phrase, “Allahu Akbar” or “God is great.” The defendant was rooting for the attack to be ISIS-related and reveling in the news that it was. Then, when Centre asked for local news coverage of the bombings, the defendant eagerly provided it.
Later that same day, Facebook User 4 (as described another U.S.-based supporter of ISIS with whom the defendant was in frequent contact), asked the defendant via an Internet messaging application whether the bombings were done by “our people,” meaning ISIS. The defendant wrote back, “My people saying they will check it out.” The next day, the
defendant followed up and wrote back “Yes it was ISIS…..Allahu Akbar….They told me…He did it bombing NJ nyc….Allah Akbar…..Takbeer [the best]…”
Then, on September 19, 2016, the defendant posted the following to one of her Facebook accounts:
So it was a Muslim brother who did bombing NJ and NYC too so . . . why they sent alerts to all our phones no Muslim will tell on him nope the FBI arrest him already SMH [shakes my head]…they already know #AhmedRahmi2016” and
Whoever snitch on a Muslim for kuffar can win then you are not from Ahlil Sunnah because you shouldn’t give up it brother and send him to kuffar custody [angry face emoji].
See Exhibit 18.
Again, in the wake of a violent terrorist attack the defendant identified herself with ISIS, took pride in the group’s association with the bombing, venerated the perpetrator and condemned as unfaithful Muslims anyone who may have assisted law enforcement in the investigation.
The defendant displayed a similarly chilling reaction following the June 12, 2016 massacre at the Pulse Nightclub in Orlando, Florida, which killed 49 people and wounded dozens more. As was widely reported at the time, during the attack on the gay nightclub the shooter called 911 and pledged his allegiance to ISIS.\(^{34}\) Within days of the attack, the defendant celebrated the shooting and linked it to her own extremist beliefs and association with ISIS. In one post on or about June 15, 2016, the defendant wrote “I seen 2 gay men on train and thought of Florida shooting and I wanted to blow them up…Baqiyya.” PSR ¶ 17.
Understanding the term “Baqiya” is critical here. It is a term commonly used as a greeting among ISIS supporters in conjunction with the phrase “Dawlatal Islamiya” and
\(^{34}\) See https://www.washingtonpost.com/news/post-nation/wp/2016/06/12/orlando-nightclub-shooting-about-20-dead-in-domestic-terrorism-incident-at-gay-club/?utm_term=.dd9151482cec
one which the defendant used in 2016 and to which she continues to gravitate now.\(^{35}\) Baqiya, or “remaining” is a
a concept that has been part of a concerted messaging campaign by Islamic State propagandists, and adopted by its followers, that the caliphate remains despite the many territorial losses suffered by the group. As early as 2015, when campaigns against ISIS were well underway, *baqiyah* slogans were deployed as a sign of resistance and as a message to followers/supporters to stand firm in the wake of territorial losses. *Baqiya wa tatamaddud*, or “remaining and expanding,” was one prominent iteration of this messaging campaign, which drew particularly on ISIS’s affiliates in countries outside of Syria and Iraq as a sign that it was not only remaining, but expanding.
Vidino Rpt. at 25.
In other words, in the wake of brutal massacre by a man who explicitly linked himself and his attack to ISIS, the defendant expressed her support for the attack and its relation to ISIS’s core “Baqiya” message of violent expansion and to her own desire, in this instance, to kill gay people in the name of Islam. If the defendant’s message were not clear enough, she wrote the following in another Facebook post after the Orlando attack:
“Dawla,” as the defendant stated in her plea allocution, means ISIS. In this case, ISIS doing “their thing” meant murdering 49 innocent people.
As the defendant was championing these ISIS-inspired attacks, she was actively working for ISIS as a facilitator or, in her own words, an “assistant.” She knew the group
\(^{35}\) As discussed herein, while on presentence release in 2018, the defendant friended the Facebook account of AQAH. This Facebook account expressed public support for ISIS and contained the word “baqqiya” on the profile page.
engaged in extreme violence, she celebrated that violence and she encouraged and assisted others in attempting to join the group to perpetrate more violence.
In short, the defendant’s Material Support Offense is indisputably serious and should be treated as such.
2. The Obstruction of Justice Offense
While categorically different from the Material Support Offense, the defendant’s obstruction of justice while under this Court’s supervision is serious. As set forth above, while on presentence release, she deleted at least 1,000 Facebook messages with numerous individuals. She did so for the explicit purpose of hiding them from this Court and from the government. The offense is particularly concerning because the underlying conduct – engaging in contact with individuals she is not supposed to talk to, including people she herself has identified as ISIS supporters – hues so closely to her Material Support Offense. Indeed, because she failed to delete all of her messages, and because the government was able to obtain certain messages through other means, we know that the defendant on at least two occasions during this short period used her ISIS kunya “Umm Nutella” to contact others, including contacting an ISIS supporter. And we know that, when asked repeatedly during the January 2019 Interview about whether she had used the name which she herself admitted indicates her support for ISIS, the defendant intentionally lied about it. There is no question this offense is serious, particularly because her commission of the offense shows she cannot be trusted to abide by conditions of this Court or to tell the truth.
B. The Defendant’s History and Characteristics Support a Guidelines Sentence
What brought the defendant before this Court is clear. Her criminal conduct, her support for ISIS and her adherence to a violent extremism bent on death and destruction, is all set forth above, often in the defendant’s own words. The central question now is: what sentence is necessary to, above all, protect the public. A significant part of the answer lies in the defendant’s history and characteristics, particularly as revealed through her conduct since her first guilty plea and its similarity to her actions that led to her arrest in 2016.
Throughout 2016, the defendant’s prolific social media posts and messages provided a window onto her twisted worldview, with support of ISIS at its rotten core. The defendant’s writings – and her hours of post-arrest interviews with the FBI – reveal an ideology built around “us” versus “them,” with the “us” being ISIS and its supporters, the true believers, and everyone else being the kuffar, or unbelievers. This 2016 post Facebook by the defendant – one among many – makes the point:
It is her belief in this poisonous, Manichaean ideology – and the violence it encourages and demands – that led the defendant to seek out a role assisting ISIS in recruiting people to join and fight for the group abroad. And it is the defendant’s refusal to disavow or separate herself from this destructive, hateful, violent ideology, or to even acknowledge the danger it poses, that causes such deep concern that when released, she will return to this world and begin supporting ISIS anew.
In his report, Dr. Vidino describes the “commonly cited signs” that experts look for in assessing an individual’s disengagement from terrorism. Vidino Rpt. at 21. While not an exhaustive list, these indicators are:
- Ending personal involvement in terrorism and related activities;
- Distancing oneself from terrorism and extremist activity by acknowledging the shortcomings of their actions;
- Distancing oneself from the group’s ideology;
- Breaking contact with individuals associated with the group or supporting its ideology; and
- Accepting the punishment for crimes committed
In the *John Doe* case, when grappling with the issue of how to assess a terrorist defendant’s likelihood of turning “back to radicalization,” this Court heard testimony from two experts who identified several of the same factors as Dr. Vidino. See *United States v. John Doe*, 323 F. Supp. 3d at 378-83. Factors common to all three of these experts – one of whom
testified for the defense – were the importance of voluntary disengagement from the terrorist organization, cooperation with law enforcement and a willingness to confront the ideology. See id. at 378-81.
In John Doe, this Court agreed with the experts and found that “the defendant has recognized the severity of his crimes and is not likely to move towards violent extremist behavior” and that the defendant “appeared credible and forthright at sentencing about his intention to leave his radical past behind and his desire to live a normal life.” Id. at 391. This was based on, inter alia, John Doe’s voluntary surrender to law enforcement, his admission of remorse for his crime, his four years’ of consistent and substantial cooperation with the government and his public appearances disavowing and condemning ISIS and his work discouraging others from doing the same. Id.
The comparison is here stark. The defendant has exhibited none of the positive factors relied on by this Court in deciding to sentence John Doe to an extended term of probation. Indeed, the Court gave the defendant a unique opportunity here, one rarely afforded to defendants in terrorism cases, when it released her on bail. She had the chance to show the Court she has changed, that she accepts responsibility for her criminal conduct, that she rejects her prior violent ideology, and that she is capable of choosing a different path.
The Court would face a far more difficult balancing question now had the defendant availed herself of this opportunity. But she did not. She has shown no contrition, taken no responsibility for her conduct, and failed to separate herself from the extremist world she reveled in before her 2016 arrest. Instead, as set forth above, she took advantage of the Court, violated its trust and committed a new crime. In so doing, she provided a preview of what she will do if released now. She utterly disregarded this Court’s orders regarding her bail conditions, connected and sought to connect with numerous people she herself identifies as ISIS supporters, including by using her ISIS name “Umm Nutella,” hunted for the same ISIS propaganda that she promulgated before, repeatedly expressed a total lack of remorse or acceptance of responsibility for her conduct, intentionally destroyed evidence to avoid detection and then, when given the chance to explain herself, repeatedly lied. At every turn, the defendant has demonstrated she cannot be trusted and remains a threat to return to her old ways.
What is most striking, and should most concern the Court, is the defendant’s return to espousing the same extremist, “us versus them” sentiments while also denying responsibility for her crimes, contacting and attempting to contact ISIS supporters and seeking out more ISIS propaganda, and then covering it up and lying about it. As Dr. Vidino explains, the defendant “repeatedly argues that the behaviors she engaged in in support of ISIS might be illegal under US law but, at the same time, are simply manifestations of good deen, of correct adherence to Islamic creed.” Vidino Rpt. at 27. Dr. Vidino points to several exemplars of this, including the following:
• The Facebook post from the defendant while she was on bail in June 2018 in which she wrote: “I didn’t do anything wrong under Islam but stand up for my deen and got arrested for what I believe in. See Exhibit 14.
• A February 22, 2019 email from the defendant in which she “America a is hard for Muslims to live if you want to practice deen ul islaam.”
• A February 28, 2019 email in which the defendant wrote “I understood that United States don’t like certain religious beliefs and don’t allow you to exercise certain beliefs.”
Dr. Vidino describes these and other similar recent statements of the defendant this way:
These statements do not indicate any abandonment of ISIS’ worldview. Rather, they strongly suggest that the defendant believes that adopting ISIS ideology and acting in its furtherance constitute correct Islamic behavior, following one’s *deen*. In substance, she equates being a good Muslim with supporting ISIS and, because American authorities arrest and prosecute ISIS supporters, a good Muslim cannot live in America. It is a position that only an ISIS supporter would hold and that the overwhelming majority of Muslims in America and worldwide would strongly oppose.
Also indicative of the defendant’s views are the various statements in which she disparages the US justice system. While negative views could be normal for any defendant, Jane Doe frames her criticism of the US justice system in religious terms by using the word kuffar, “infidels” (see email dated 2/22/2019 “win this case against these kuffar” and Facebook post 6/13/2018 “I was once a prisoner in dar ul kufr”). These statements indicate that the defendant does not recognize the legitimacy of the US legal system since it is not based on Islamic law but, rather, it is run by kuffar and based on laws other than sharia. It is, once again, a position that only somebody that believes in jihadist ideology would have.
Vidino Rpt. at 27-28.
The defendant also has repeatedly either minimized her crimes or entirely denied responsibility for them and claimed she has been persecuted because of her religion and/or because she is poor. As noted above, as recently as February 24, 2019, the defendant wrote “I did not do anything wrong as a Muslim but a cyber crime in social media which is a violation in USA to support certain shari’ah so al maghreb tul horriya.” On February 27, 2019, the defendant wrote “the truth it very simple it a conspiracy of material support knowing and
supporting propaganda internationally...it cyber crime on social media and most it private msggs and it how they can look into our stuff just like they do to other pppl and plus I’m poor.”
All of this is consistent with the conclusions of Dr. Katsavdakis, the forensic psychologist who examined the defendant and prepared the expert report which is attached hereto as Exhibit 2. The government will not rehash here Dr. Katsavdakis’s report; however, certain of his conclusions and the bases for them are critical to understanding the risks the defendant continues to pose. His central conclusion is that the defendant “poses a moderate risk for violent/extremist beliefs, further radicalization and possible acts.” Exhibit 2 at 15. This is based on, inter alia, his conclusion that the defendant demonstrates a “fixation or pathological preoccupation for extremist related causes,” one which continued into 2018 despite the defendant’s attempts to “cloak[]” this fixation in “curiosity.” Id. at 16. This is seen in the defendant’s conduct on presentence release in 2018 discussed in detail above, as well as in her more recent statements denying accountability for her actions and claiming, in essence, that all she ever did was stand up for her religion.
Dr. Katsavdakis’ report also highlights that the defendant is reluctant to seek out care, “repeatedly find[ing] reasons to negate potential benefits of treatment.” Id. And perhaps most disturbingly for the Court, Dr. Katsavdakis found that the defendant “demonstrated repeated instances of deceptive behavior, as well as a primitive attempt (e.g., denial) for engaging in behavior despite evidence to the contrary.” Id. at 17. The defendant exhibited this deception even during her time with Dr. Katsavdakis, answering “false” to his question about whether she ever lies to avoid getting into “tight situations.” Id. This answer from the defendant is of course belied by, among other things, her recent guilty plea to destroying numerous electronic messages to avoid their detection by law enforcement and her admission to the Court that she lied to the government during the January 2019 Interview.
C. The Need to Avoid Unwarranted Sentencing Disparities Supports the Imposition of a Guidelines Sentence
Sentencing comparisons to other Section 2339B defendants are of limited use here because the defendant and her conduct stand apart from other convicted terrorism defendants. She is sui generis. Indeed, the government is unaware of any other defendant who has pleaded guilty to providing material support to ISIS (or any other foreign terrorist organization) and been released on presentence release only to violate the terms of her cooperation agreement, reconnect with people she herself identified as ISIS supporters, lie to the government, destroy evidence of her conduct, and be convicted of a new felony offense.
The most meaningful comparison for the Court’s consideration is by way of contrast to this Court’s own sentencing in John Doe, discussed above. There, in weighing the paramount need to “protect the public from any further crimes by the defendant” and “the required general deterrence of others who might help ISIS here or abroad,”36 this Court rightly focused on the defendant’s acceptance of responsibility, his regret for his actions and his
36 John Doe, 323 F. Supp. 3d at 370.
repudiation of ISIS and its brutal and corrupt ideology. The Court quoted John Doe’s conclusion about ISIS, “‘It was . . . senseless. These people [,ISIS members,] are liars. These people are not Muslim. That’s not how Islam is or the Koran.’” *John Doe*, 323 F. Supp. 3d at 373 (quoting from sentencing transcript at 15:22-25).
But this Court did not rely solely on John Doe’s words for proof of his repudiation of ISIS and its hateful violence and his commitment to live a law-abiding life upon release. It did not have to. Because for indicators of what John Doe would do upon release, the Court could rely also on his actions, noting that for nearly four years after his arrest he provided extraordinary cooperation with the government’s counterterrorism efforts, including voluntary efforts such as making public statements denouncing ISIS, all at significant risk to his and his family’s safety. *Id.* at 375. In the end, the Court “believe[d] that [John Doe] has recognized the severity of his crimes and is not likely to move towards violent extremist behavior.” *Id.* at 391. It was for all these reasons that the Court concluded that further incarceration of John Doe would “not serve any legitimate penological goal” and that “neither retribution, rehabilitation, deterrence, nor recidivism” justify sentencing defendant to an additional term of incarceration.” *Id.* at 392.
As set forth above, the defendant here stands before this Court in total contrast to John Doe. She does not accept responsibility for her actions; rather she downplays the seriousness of her crimes and blames others for her getting caught and for persecuting her. She did not honor her cooperation agreement with the government; rather, she violated it repeatedly. She has not repudiated ISIS, its supporters or its brutal violence, which she previously celebrated; on the contrary, when released for just a brief period, she contacted and attempted to contact ISIS supporters and sought out more ISIS news and propaganda. She was not honest and forthright; instead, when given a chance to explain her conduct on presentence release the defendant lied, repeatedly, including about using her ISIS *nom du guerre*. She clings, still, to the hateful and divisive ‘us versus them’ dichotomy of true Muslims versus non-believing “kuffar.”
**D. A Guidelines Sentence Is Necessary To Afford Adequate Deterrence and To Promote Respect for the Law**
A Guidelines sentence is also necessary to adequately deter criminal conduct—in this case, terrorism aimed at harming Americans and American interests—and to promote respect for the law prohibiting such destructive conduct. *See* 18 U.S.C. § 3553(a)(2)(A)-(B). As Judge Walker stated in his concurrence in *Stewart*, “[i]n no area can the need for adequate deterrence be greater than in terrorism cases, with their potential for devastating loss of innocent life.” *Stewart*, 590 F.3d at 181.
The capacity of a terrorist organization like ISIS to thrive hinges in large part on its ability to grow its membership—to attract, indoctrinate, and enlist new followers, like the defendant, who are committed to advancing and serving ISIS’s murderous agenda or die trying. It is only through this support that ISIS and other terrorist groups are able to fulfill their missions of hate, murder, and violence. Deterring such conduct is particularly important
in today’s environment, when so many young people in the West, including in the United States, have become radicalized by jihadist propaganda online and have either traveled or tried to travel to the Middle East to join ISIS and other terrorist groups. It is vital for our country’s national security that other young men and women who reside in the United States, when exposed to hateful extremist teaching, be deterred from choosing to follow a path similar to the defendant and engaging in potentially devastating conduct in support of such groups. It is important for those contemplating joining a terrorist organization to know that the consequences for such conduct are serious. And it is important for the public to know that those who seek to join and support terrorist organizations will face serious punishment preventing them from causing harm to society. A Guidelines sentence is necessary and warranted in this case to serve the pressing need for general deterrence of such terrorism offenses.
Finally, a Guidelines sentence is also required to deter other individuals from engaging in the type of wanton obstruction and deception engaged in by the defendant after she pleaded guilty to the Material Support Offense and agreed to cooperate with the government. The importance of this cannot be overstated. Despite the serious nature of her terrorism offense, the government – as it must do to cooperate any defendant in order to pursue additional serious criminal activity – trusted the defendant and took a significant risk in doing so. The defendant, instead of embracing this extraordinarily rare opportunity to repay that trust with honesty, and thus chart a better course for herself, instead abused it. She lied and destroyed evidence to hide her actions from the government and this Court. In so doing, she jeopardized ongoing terrorism investigations. Moreover, the defendant made manifestly clear that she cannot be trusted to follow even the most basic conditions of supervision, including to tell the truth, let alone abandon the extremist ideology that she continues to espouse. It is thus vital that the Court send a message not only to this defendant, but also to future cooperating witnesses that their failure to honor their agreements, obey the law and comply with the Court’s orders will be punished severely.
IV. Conclusion
For the foregoing reasons, the government respectfully requests that the Court impose a sentence within the applicable Guidelines range of 360 to 600 months’ imprisonment
as such a sentence is sufficient but not greater than necessary to comply with the purposes of sentencing pursuant to 18 U.S.C. § 3553(a).
Respectfully submitted,
RICHARD P. DONOGHUE
United States Attorney
By: /s/_____________________
Josh Hafetz
Ian C. Richardson
Assistant U.S. Attorneys
(718) 254-7000
Enclosures (Exhibits)
cc: Clerk of Court (JBW) (by ECF) (without enclosures)
Deirdre D. von Dornum, Esq. and Samuel Jacobson, Esq. (by Email and ECF)
Shayna Bryant, Senior U.S. Probation Officer (by Email)
|
Drifting features: Detection and evaluation in the context of automatic RR Lyrae identification in the VVV
J. B. Cabral\textsuperscript{1,2}\textsuperscript{(\Letter)}, M. Lares\textsuperscript{2}\textsuperscript{(\Letter)}, S. Gurovich\textsuperscript{2}, D. Minniti\textsuperscript{3,4,5}, and P. M. Granitto\textsuperscript{1}\textsuperscript{(\Letter)}
\textsuperscript{1} Centro Internacional Franco Argentino de Ciencias de la Información y de Sistemas (CIFASIS, CONICET–UNR), Rosario, Argentina
\textsuperscript{2} Instituto De Astronomía Teórica y Experimental – Observatorio Astronómico Córdoba (IATE–OAC–UNC–CONICET), Córdoba, Argentina
\textsuperscript{3} Departamento de Física, Facultad de Ciencias Exactas, Universidad Andrés Bello, Av. Fernandez Concha 700, Las Condes, Santiago, Chile
\textsuperscript{4} Instituto Milenio de Astrofísica, Santiago 7500912, Chile
\textsuperscript{5} Vatican Observatory, 00120 Vatican City State, Italy
Received 4 May 2021 / Accepted 25 May 2021
ABSTRACT
Context. As most of the modern astronomical sky surveys produce data faster than humans can analyse it, machine learning (ML) has become a central tool in astronomy. Modern ML methods can be characterised as highly resistant to some experimental errors. However, small changes in the data over long angular distances or long periods of time, which cannot be easily detected by statistical methods, can be detrimental to these methods.
Aims. We develop a new strategy to cope with this problem, using ML methods in an innovative way to identify these potentially detrimental features.
Methods. We introduce and discuss the notion of drifting features, related with small changes in the properties as measured in the data features. We use the identification techniques of RR Lyrae variable objects (RRLLs) in the VVV based on an earlier work and introduce a method for detecting drifting features. For the VVV, each sky observation zone is called a tile. Our method forces the classifier to learn from the sources (mostly stellar ‘point sources’) which tile the source originated from and to select the features that are most relevant to the task of finding candidate drifting features.
Results. We show that this method can efficiently identify a reduced set of features that contains useful information about the tile of origin of the sources. For our particular example of detecting RRLLs in the VVV, we find that drifting features are mostly related to colour indices. On the other hand, we show that even if we have a clear set of drifting features in our problem, they are mostly insensitive to the identification of RRLLs.
Conclusions. Drifting features can be efficiently identified using ML methods. However, in our example removing drifting features does not improve the identification of RRLLs.
Key words. methods: data analysis – methods: statistical – surveys – catalogs – stars: variables: RR Lyrae – Galaxy: bulge
1. Introduction
Most of the modern astronomical sky surveys are characterised by fast-paced data ingestion, data intensive science cases, or automatic reduction pipelines (e.g., Feigelson & Babu 2012), which often lie on the verge of technological developments and analysis capabilities. This unprecedented availability of observations challenges the traditional approaches for data analysis, leading to a shift in the paradigm for knowledge discovery (Bell et al. 2009), which has notably become dominated by machine learning (ML) techniques (Ball & Brunner 2010). Despite the difficult mathematical and statistical foundations, a complex terminology driven by the confluence of several sciences, and the arduous interpretation of the results, the training of intelligent agents has become an everyday practice in astronomy. The accessibility of easy-to-use free software resources mostly written for R (Team R Core 2000) or Python (Van Rossum & Drake 2003) languages was fundamental to this step.
In most cases, ML methods can be separated into two basic steps. First, raw data are converted into a set of useful features that are relevant to the task at hand (e.g., periods or intensities), and then these features are fed to a classifier or a statistical method (see e.g., Mitchell 1997).
Machine learning methods have a number of limitations. For instance, they are highly susceptible to errors produced by the limitations of the datasets (Cai & Zhu 2015). The results can also be hampered by the role of the features, which is not fully understood (Duboue 2020) or by the biases introduced by improperly defined experiments (Domingos 2012). These facts are well known and have not been ignored in the astronomical community (Luo et al. 2020).
Here, we are interested in the role of some sources of noise that are present in commonly used features in astronomical research as well as their impact on the results of ML methods in this context. We use data from the synoptic survey Vista Variables in Via Láctea (VVV; Minniti et al. 2010), observed with the VISTA telescope (Sutherland et al. 2015), which pursues, among its main objectives, the production of a three-dimensional map of a large part of the Galactic centre (bulge) of the Milky Way and a fraction of the internal Galactic disk. The VVV
data are presented in units called ‘tiles’, which are rectangular areas of the sky surveyed over time. For each tile, the VVV data reduction pipeline (Emerson et al. 2004) provides a pre-processed image and a database of files with the positions, magnitudes, and colour indices of the light sources present in the image, which comprises the ‘photometric catalogue’. These catalogues are the main subject of this study.
The images are subject to two noise sources, namely experimental errors and observation conditions. The derived catalogues are also affected since the noise permeates all the survey information, which is composed of a set of features or observables. Atmospheric conditions, moon phases, maintenance of the camera and telescope, or modifications to the software, among many factors, can influence the observation or recording of the data. As a consequence, the derived measurements that are used as features for an ML analysis can also be prone, to different extents, to these errors and conditions.
Random measurement errors are present in all experimental or observational science. They are unavoidable, but each error typically affects only a single observation or a reduced set of observations; in particular, wide-field survey images can be affected by issues such as weather, astronomical conditions, and software updates. Machine learning methods can efficiently cope with these kinds of errors. For a large survey such as the VVV, observational conditions can change slightly (but not randomly) over long periods of time or for different regions in the sky. This problem is more difficult for ML methods. In many situations we want to train an intelligent agent using a well-known portion of the survey and then use it to predict other less-known zones when searching for a given astronomical phenomenon. Given the ML methodology, the agent will work efficiently on training data but will probably fail to generalise to other zones due to this slight change in observational conditions. Due to the diverse nature of the features extracted from the data (intensity, periods, colours, etc.), they will possibly reflect this effect in different proportions. It is thus interesting to ask whether it is possible to automatically detect which of the extracted features are more sensitive to these changes in observational conditions. Hereafter, we refer to the features in a dataset that are sensitive to observational conditions as ‘drifting features’. We aim at evaluating their influence over a large-scale ML experiment.
As a working example, we focus on the problem of detecting RR Lyrae variable objects (RRLs) in VVV data. That is, we train classifiers using data from some VVV tiles and evaluate how they conduct the task of identifying RRLs on other tiles.
Drifting features should be consistent within a limited zone of the sky (for instance, one tile or two consecutive tiles) but should show slight changes, almost undetectable by most simple statistics, between tiles that are separated from one another\(^1\). Those changes could potentially alter the capabilities of the classifier. To detect these features and their effect on automatic classification, we once again propose using ML methods. If we confront an ML method with the task of discriminating data from two tiles, it will be forced to learn the differences between the tiles that are present in the features. We can then use feature selection methods (Guyon et al. 2002) to evaluate the importance of each feature for this classifier that discriminates tiles and to mark highly relevant features as candidate drifting features. In other words, we propose learning a separate task (the tile of origin of a source), not because it is unknown or difficult but as a method for detecting which are the features that are most useful to this task: the features that contain information that changes with the tile of origin.
This work is divided into the following sections: In Sect. 2 we explain our experimental setup (data, feature extraction, model selection, etc.). In Sect. 3 we introduce our procedure for the identification of drifting features, and in Sect. 4 we evaluate the effect of these features on the task of RRL identification. Finally, in Sect. 5 we discuss our results and draw our conclusions.
## 2. Experimental setup
### 2.1. Data
One of the main objectives of the VVV is the creation of a three-dimensional map of the bulge and the Galactic centre (Minniti et al. 2010) for which the search for variable stars in general, and RRLs in particular, is important due to their use as standard candles (Bailey 1902). To this end, the survey relies on data from the VISTA Infrared Camera (VIRCAM), mounted on Visible and Infrared Survey Telescope for Astronomy (VISTA) of the European Southern Observatory (ESO; Sutherland et al. 2015), which at the time of its construction was the largest near-infrared camera, with 16 non-contiguous $2k \times 2k$ detectors. To complete a contiguous tile, VIRCAM simultaneously exposes its detectors six times with a suitable offset. Each of the exposures is called a ‘pawprint’, and the combination of the six overlapping pawprints is a tile. For this reason each pixel is observed in at least two pawprints and the edges are shared with the observations of the adjacent tiles. The survey observation plan was organised in two stages: During the first year the tile was observed in five astronomical filters, Z, Y, J, H, and Ks, separated by a few hours; then, in subsequent years, it was re-observed using the Ks band for variability studies. Only some tiles were observed in multi-band after the first year. The dataset used in this work is the one presented in Cabral et al. (2020), which consists of 62 features extracted with feets (Cabral et al. 2018) from light curves that were reconstructed from the photometric catalogues provided by the Cambridge Astronomical Survey Unit (CASU).
From the original dataset we selected eight tiles located at different zones of the bulge, as shown in Fig. 1. For each tile we extracted all the RRLs plus a uniform sample of 2000 unclassified, unsaturated, and non-faint sources (average magnitude between 12 and 16.5). From these selections, sources with invalid values were removed, leaving the final dataset for this work, described in Table 1.
We chose to use a reduced dataset with around 2000 sources for each tile in order to dramatically decrease the computational burden of our experiments. As shown in Cabral et al. (2020), the use of a reduced dataset can lead to optimistic estimations of the accuracy of the detections, but our main objective is to find and characterise the features that best represent the differences between the tiles and not the accuracy of the detection of the RRLs.
### 2.2. Error measures
We faced two different binary classification problems in this work. First, we tried to separate sources between two tiles; this
Table 1. Total number of sources, RRL and sample, taken in each tile used in this work.
| Tile | Total | RRL | Sample |
|--------|----------|-----|--------|
| b206 | 407720 | 47 | 2047 |
| b214 | 376822 | 35 | 2034 |
| b216 | 334773 | 43 | 2043 |
| b261 | 735838 | 253 | 2252 |
| b277 | 831323 | 430 | 2429 |
| b278 | 857887 | 437 | 2436 |
| b360 | 1029149 | 679 | 2669 |
| b396 | 729671 | 15 | 2015 |
was done in order to construct a tile classifier (TC) that allows the relevance of the features to be assessed. As stated in the Introduction, we used the TC as an auxiliary method that allows us to detect which features are candidate drifting features. Then, we built a source classifier (SC) that seeks to discriminate RRL sources from unknown sources. In the first problem both classes are nearly balanced in all cases. On the other hand, as discussed in Cabral et al. (2020), the identification of a few variable stars within a large set of unknown sources is usually a highly imbalanced problem that generates several inconveniences, such as those discussed in the recent work by Hosenie et al. (2020), and requires specific error measures.
In the RRL detection problem (SC), we define RRL samples as the positive class and the other sources as the negative class. In the tile identification problem (TC), both classes (the two tiles) are equivalent, so we arbitrarily call one of them positive and the other negative. All positive samples (in this case, either a source or a tile) that are correctly identified by the classifier are called true positives (TP); otherwise, if they are missed by the classifier they are called false negatives (FN). Negative samples that are wrongly classified are called false positives (FP), and those that are correctly identified are called true negatives (TN). Using a combination of these four outcomes, we can define two complementary performance measures, called ‘precision’ and ‘recall’, which are adequate to deal with unbalanced problems. The precision is defined as $TP/(TP + FP)$. It measures, for example, the fraction of real RRLs detected over all those retrieved by the classifier. The recall, on the other hand, is defined as $TP/(TP + FN)$. It measures, in the same example, the fraction of all RRLs that are detected by the classifier.
Many classifiers can change their decision outputs by adjusting the probability threshold that considers an observation to be positive or negative. A high threshold increases the precision and decreases the recall since fewer cases are classified as positive, while a low threshold generates the opposite effect. To evaluate precision and recall together, we consider the precision-recall curves (PR), where we plot a set of pairs of values corresponding to different thresholds. A curve that approaches the top-right corner is, in general, considered to represent a better classifier.
For balanced classification problems it is common to find more traditional metrics in the literature. As such, for the tile identification problem we also use ‘accuracy’, $(TP + TN)/(TP + FP + TN + FN)$, and the ‘area under the receiver operating characteristic curve’ (ROC-AUC) measures. The ROC curve is equivalent in concept to the precision-recall curve described above, and the area under it is a global measure of the performance of the classifier. The only difference between the two curves is that an ROC curve that approaches the top-left corner represents a better classifier.
2.3. Model selection
For the TC problem we evaluated four classifiers with diverse foundations – support vector machine (SVM) with a linear kernel (Vapnik 2013), SVM with a radial basis function (RBF) kernel, K-nearest neighbours (KNN; Mitchell 1997), and random forest (RF; Breiman 2001) – all implementations from the Scikit-Learn Python package (Pedregosa et al. 2011).
To determine the best hyper-parameters for every model, we executed a grid search of all possible combinations of values for each hyper-parameter over a fixed list. We used a five k-fold setup on a dataset with tiles b278 and b261, using precision as a performance measure. These tiles were chosen because they are not extreme in terms of their location or their balance, unlike b396 or b220.
With this setup, we selected the following hyper-parameter values:
- SVM-linear: $C = 100$,
- SVM-RBF: $C = 100$ and $\gamma = 0.003$,
- KNN: $K = 56$ with a Manhattan metric; also, the importance of the neighbour class was not weighted by distance.
RF: We created 500 decision trees with information gain as a metric; the maximum number of random selected features for each tree is 0.5 the total number of features, and the minimum number of observations in each leaf is five.
Using the optimal values for the hyper-parameters, we compared the four models on the same dataset using a ten-fold cross-validation setup. Table 2 shows the corresponding results using the default threshold (0.5) for all models. For all three metrics considered (precision, recall, and AUC), the SVM-linear classifier clearly outperformed all the other classifiers. More importantly, Fig. 2 shows the corresponding ROC and precision-recall curves, which show that SVM-linear also outperforms the other methods for all possible thresholds. Given these results, we selected SVM-linear as the classifier for the tile identification problem. For the SC problem, Cabral et al. (2020) already determined that RF is the classifier with the best performance for our dataset and general experimental setup.
### 2.4. Feature selection
Feature selection (Guyon & Elisseeff 2003) is the process of extracting some subsets of features from the entire set in order to optimise the classification performance and/or the computational complexity of the problem. We chose for this work the ‘recursive feature elimination’ (RFE) algorithm (Guyon et al. 2002). The method is widely adopted and is characterised by its good performance and simplicity. As a backward selection method, RFE starts with all the features and sequentially eliminates the unimportant features using a recursive process.
The RFE algorithm is integrated with a classification method, which provides, at each step of the recursion, the importance score of the features. It iteratively executes the underlying classifier and extracts the score for each variable; then the variable (or group of variables) with a worse performance (according to the score) is eliminated.
The method typically ends when the desired (fixed) number of features to select is reached. Another possibility is to monitor a performance metric for the subsets (for example, the accuracy on an independent validation set) and stop the recursion when the metric is optimal.
In this work we relied on the RFE implementation with k-fold Cross-Validation (RFECV) for the stopping criteria, which are provided by the Scikit-Learn package (Pedregosa et al. 2011). The RFECV produces $k$ replicated experiments ($k = 5$ in our work), each of which selects features over $(k - 1)$ folds and monitors the classification error $(1 - \text{accuracy})$ over the remaining fold. Then it determines the number of features to select, looking for the least average error throughout all the folds. In the last step, RFECV produces a final selection using the entire dataset to select the features, stopping at the previously selected point.
It is worth mentioning that the classifier embedded in the RFE in the feature selection stage may be different from the eventual method in the final classification stage.
### 3. Finding drifting features
As we stated in the Introduction, we propose using ML methods to detect drifting features, looking for features that are useful for determining the tile of origin of a given source (exclusively from features derived from the pawprint stack photometry, without any other header keyword data). With this goal, in this first experiment we considered all the sources in each tile together (RRLs and unknowns) and trained classifiers to learn the tile of origin of each source and not its astronomic type.
We applied the RFECV method, as described in the previous section, to 28 binary classification problems, each of which consisted in separating a different pair of tiles from the set of eight tiles in our dataset. Thus, for each SC problem (for example, separating tiles b206 and b214), we obtain from RFECV a subset of selected features for that problem. Each subset potentially has a different length, as discussed above.
Figure 3 shows the number of features selected for each problem. It is evident that there are two different behaviours. In some cases RFE selects just a few features, as for example tile b216 with any other except b206; on the other hand, in some other cases the selected subset contains a high number of features (tile b206 against b216, for example, or b396 against b277 or b278). However, the number of selected features by itself is not relevant; what is more important for identifying drifting features is how well they separate the two tiles.
We can arbitrarily divide the problem into two categories: ‘few features’ (four or fewer selected features) and ‘high number’ (more than four selected features). Figure 4 shows ROC curves for the 12 high-number problems as well as their relative locations in space. The figure shows curves for three classifiers: one trained with all the features in the dataset (‘all features’), a second trained using only those selected by RFE (i.e. our candidate drifting features), and a third one trained with those not selected by RFE (we call this the ‘stable’ subset). All the few-features subset cases (b216-b278 for example) produce trivial ROC curves that are saturated at the top-left corner for the three subsets, with AUC > 0.99, which we do not show.
Analysing the results, the first observation is that, as expected, the classifier trained with the drifting features (those chosen via feature selection) is always very similar in performance to the one trained with all the features. This result is a confirmation that RFECV does its work, selecting a subset of features that are responsible for the separation of the classes. The second result is that the performance of the models for the few-features problems is clearly superior to those shown in the figure (i.e. the high-number problems). This implies that the two behaviours shown in Fig. 3 correspond to problems that are easy to solve – where the separation is almost perfect and can be done with a few features – and problems that are harder – where the tiles cannot be fully separated and RFE selects bigger subsets.
It is interesting to note the different response of the classifiers trained on the stable subset on the ‘easy’ and ‘hard’ problems. In the hard problems, RFECV selects a high number of features, which means that there are features with no considerable information about the tile of origin of the source. After several features are selected by RFECV, the remaining features (the stable subset) contain much less information about the origin and produce a classifier with low performance. For the easy problems,
Fig. 2. ROC (left) and precision-recall (right) curves of the SVM (with linear and RBF kernels), RF, and KNN models for the prediction of the tile of a given source, using ten-fold cross-validation with tiles b278 and b261.
Fig. 3. Number of features selected by RFE for each binary TC problem. Each cell corresponds to the dataset that includes tile A (rows) and tile B (columns).
On the other hand, there are several features with a great deal of information about the tile of origin. Using just two to four features selected by RFECV is enough to produce an almost perfect classifier. The stable subset in this case contains plenty of features with good information about the origin, and it also produces a classifier with almost perfect performance. If we take the relative positions of each pair of tiles for the hard and easy problems into account, no definite pattern emerges. Most problems involving neighbour tiles, such as b277, b278, and b261, are hard, and most problems involving tiles in the bottom-right region are easy.
Another relevant analysis for a feature selection method is an analysis of which features are selected in each case. The upper half of Fig. 5 shows the number of times that each feature was selected by RFECV over the 28 TC problems, for all features that were selected at least two times (Table A.1 shows the list of features selected on each problem). The features related to pseudo-colour (Cabral et al. 2020) were the most frequently selected, appearing in at least half of the cases. Two such features (c89_hk_color and c09_hk_color) were selected in almost all cases. This information suggests that colour-related information in general is the most important characteristic for distinguishing tiles.
The two very different behaviours of hard and easy problems will complicate the evaluation of the real influence of drifting features on the TC problems because deleting only two features versus half of the features will lead to diverse scenarios. To allow for an easier and fairer comparison, we changed the feature selection method, using RFE with a fixed number of ten selected features.
The list of these selected features and their frequency is shown in the bottom half of Fig. 5. Only 15 features were selected in total over the 28 TC problems, of which the 11 most relevant are related to colour, probably with a high dependence on the location of the tile.
The overall performance of the classifiers trained with the full, drifting, and stable subsets for some exemplars of easy and hard datasets can be seen in Fig. 6. For the easy problems (bottom row), we used fewer features in the stable subset, leading to a lower performance. On the opposite side, for the hard problems (top row) we used more features in the stable subset, leading to a clear improvement in its performance. The rest of the TC problems show the same type of result (data not shown).
Using a fixed selection of features with RFE, we obtain, in all cases, a subset of ten features (the ‘drifting’ subset) that can discriminate the tile of origin with high accuracy as well as another subset (stable) with much less information about the tile of origin of the sources.
4. Evaluation of the influence of drifting features
In this section we evaluate the influence of the drifting subsets selected in the previous step on the SC problems (i.e. to discriminate between unknown sources and RRL variable stars).
For each pair of tiles we have three datasets, one with all the features (‘full’), a second with only ten drifting features selected by RFE, and finally one with the remaining features, the stable subset. Unlike the previous problem, we now have, for the SC
problem, two possibilities for each pair of tiles: First, we can train our classifiers in one of the tiles and searched for RRLs in the other, and second we can invert the tiles, training classifiers in the second tile of the pair and looking for RRLs in the first tile. Thus, for each of the 56 SC problems we trained corresponding RF classifiers and obtained three PR curves for the full, drifting, and stable classifiers.
The complete results are presented in Appendix B, while a summary of some representative cases can be seen in Fig. 7. A first result is that, clearly, the drifting subset shows lower perFig. 5. Total times that each feature was selected by RFECV over the 28 SC problems considered in this work. The different colours identify which of the three groups each feature belongs to: orange for those based on colour, blue for those based on period, and white for those based only on magnitude.
Fig. 6. Same as Fig. 4 but for a fixed RFE selection of ten features for the drifting subset. The top row shows two easy datasets, and the bottom row shows two hard datasets.
formance in all cases. This was expected as most drifting features are related to colour and Cabral et al. (2020) demonstrated that colour alone cannot clearly identify RRLs. More interestingly, if we compare the performance of the full datasets with the stable datasets, we can see that there is no clear advantage in eliminating the drifting features from the datasets. Full and stable curves are very similar in all cases. Differences are small, and there is no clear pattern indicating when eliminating drifting features would improve the performance of the ML methods.
5. Discussion
In this work we have introduced and discussed the concept of drifting features, in relation to the small changes in the properties measured by those features, which can potentially distort the results of ML methods in astronomy. Using the identification of RRLs in VVV as a working example, we have introduced a method for detecting drifting features using an indirect ML method. We forced a classifier to learn the tile of origin of diverse sources and to select the features most relevant to this task as candidate drifting features. We have shown that this method can efficiently identify a reduced set of features that contains useful information about the tile of origin of the sources. We have also shown that, for our particular example of detecting RRLs in the VVV, drifting features are mostly related to colour. On the other hand, we showed in Sect. 4 that even if we have a clear set of drifting features in our problem, they are almost harmless for the identification of RRLs.
In future work we will explore the influence of drifting features on the detection of other types of variable sources and other
large-scale ML experiments. We will also explore a different way of setting the number of selected features by RFE, considering all features that are relevant to the problem and not only the subset that shows the best performance for some metric or a fixed-length subset.
Acknowledgements. The authors would like to thank their families and friends, and also IATE astronomers for useful comments and suggestions. This work was partially supported by the Consejo Nacional de Investigaciones Científicas y Técnicas (CONICET, Argentina) and the Secretaría de Ciencia y Tecnología de la Universidad Nacional de Córdoba (SeCyT-UNC, Argentina). J. B. C. are supported by a fellowship from CONICET. Some processing was achieved with Argentine VO (NOVA) infrastructure, for which the authors express their gratitude. We gratefully acknowledge data from the ESO Public Survey program ID 179.B-2002 taken with the VISTA telescope and products from the Cambridge Astronomical Survey Unit (CASU). J. B. C. thanks to Maren Hempel by creating the template for the creation of the template on which the Fig. 1 is based, and finally Bruno Sánchez and Martín Beroiz for the continuous support and friendship. This research has made use of the http://adsabs.harvard.edu/, Cornell University xxx.arxiv.org repository, astdex (https://github.com/yymao/astdex), astropy and the Python programming language.
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Appendix B: Evaluation of the drifting features
Fig. B.1. First 28 precision-recall curves for all combinations of train-test tiles for three different classifiers: one with all the features (full), another only with the ten drifting features found in that combination of train-test tiles (RFE), and one using all the remaining features with the exception of the drifting features (No-RFE).
Fig. B.2. Last 28 precision-recall curves for all combinations of train-test tiles for three different classifiers: one with all the features (full), another with only the ten drifting features found in that combination of train-test tiles (RFE), and one using all the remaining features with the exception of the drifting features (No-RFE).
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Concrete Poetry in Canada
Steve McCaffery
[An excerpt from an unpublished essay, ca. 2011.]
It should be stated at the outset that Concrete Poetry in Canada did not emerge in the foundational decade of the 1950s. Those poems and documents (largely European and South American) as well as the majority of the avant-garde legacy remained historically unavailable in the formative years and hence unknown. Though a concrete orientated poetry in Canada can be traced back to the 1860s, its recent practice dates a century later to the 1960s. Unlike the Darmstadt Circle in Germany and the Noigandres group in Sao Paulo, Brazil, Canadian concrete poetry did not emerge as a group phenomenon; there is no centre of activity, no founding manifesto and all theorizing (if at all) was post facto.
Its roots lie in the linked but varied idiosyncratic impetus of primarily two young poets: Bill Bissett (born 1939) and Barrie Philip (bp) Nichol (1944–88). To name the first generation of Canadian concrete poets beyond these two is to name a small number: Lionel Kearns (born 1937), Judith Copithorne (born 1940), David UU (David W Harris) (1948–94) in Vancouver, Andrew Suknaski (born 1942) and his Elfin Plot Press in Saskatchewan, David Aylward (born 1943) and John Riddell (1940–2016) in Toronto, with Steve McCaffery (born 1947) and Hart Broudy (born 1945) ushering in a Toronto-based second generation in the latter part of the 1960s. Yet of the poets mentioned above Kearns’ contribution is a single poem,
Copithorne’s is, in *strictus senso*, a calligraphic poetry. Aylward’s exists in a couple of chapbooks, Riddell’s used concrete techniques as a vehicle for visual effects with narrative ends in mind, and Broudy’s was a hybrid practice of pictorial narrative and verbal-letter landscapes.
Emerging in the mid-sixties Canadian concrete poetry is best configured within a wider, international poetics of cultural unrest, expressed by many younger writers in a plurality of unorthodox literary forms around the world. More specifically, however, it arose out of a specific cultural need. A dominant, inward-looking, mythopoetic and largely nationalist aesthetic (expressed at its belligerent and stentorian in the prose of Robin Mathews) had been challenged in Vancouver by Tish, a young group of poets, founded in 1961 and largely gathered around ex-patriot American critic Warren Tallman. Embracing the new American physiologically-based poetics of projective verse, the Tish group offered a radical alternative to Canadian mainstream poetry: the pre-eminence of breath and the syllable in guiding poetic construction, the poem considered both as an open field and a high energy construct proved appealing to a younger generation of west coast Canadian poets. It was this initial ground-breaking intervention that facilitated the intervention of Canadian concrete-visual poetic practice and its articulation onto the wider, international movement to which Concrete Poetry aspired.
**Selected Highlights from the Collection**
**bill bissett / Blewointment**
[bill bissett, ed.]. *Blewointment*, Occupation Issew. August 1970.
Front and back covers. Top-stapled wrappers with paper tape.
bill bissett. *awake in th red desert!* Talon Books and See/Hear Productions, 1968.
Front and back covers. Wrappers. This is from an edition of 500 copies
bill bissett. *Drifting Into War*. Talonbooks, 1971.
Wrappers. Inscribed by bill bissett to Steve Clay.
bill bissett. *Lost Angel Mining Company*. Blewointment Press, 1969.
Front and back covers. Stapled wrappers with tape over spine. This is from an edition of 500 copies. Signed by the poet.
bill bissett. *Lunaria*. Granary Books, 2001.
Printed letterpress by Inge Bruggemann, then hand painted throughout by bissett. Bound in printed cloth over boards by Judith Ivry, contained in a cloth-covered clamshell box. Includes a CD of the poet reading the work. Edition of 42 of which 12 are hors commerce. Numbered and signed by the poet / artist. This is no. 5 of 12 hors commerce copies.
bill bissett. From *Ready for Framing*. Blewointment Press, 1982.
Loose sheets printed on one side in a printed envelope. This is from an edition of 300 copies.
bill bissett. *santh monkey*. Blewointment Press, 1980.
Wrappers. "A bed time coloring storee pome book." This is from an edition of 500 copies. Inscribed by bill bissett to Steve Clay.
bill bissett. *Sailor*. Talonbooks, 1978.
Wrappers.
bill bissett. *Sunday Work?* Blewointment Press, [1969].
Side-stapled wrappers with cloth tape over spine. Poetry, collage, and artwork bound together. Believed to be from an edition of 500 copies.
bill bissett. *th first snow.*
Blewointment Press, 1979.
Side-stapled wrappers. This is from an edition of 350 copies.
bill bissett. *th high green hill.*
Blewointment Press, 1972.
One of three books and 11 broadsides comprising *ICE*. Other books are *polar bear hunt* and *words in th fire*. This is from an edition of 400 copies.
Hart Broudy. *Language in Space: A Book of A*. Blewointment Press, 1974.
Wrappers. This is from an edition of 500 copies.
David UU. [David W. Harris]. *Pamplemousse: An Act*. Blewointment Press, [ca. 1968].
Side-stapled wrappers.
bpNichol, ed. *The Cosmic Chef Glee & Perloo Memorial Society Under the Direction of Captain Poetry Presents an Evening of Concrete*. Oberon Press, 1970.
Unbound pages in printed box with hinged lid. This is no. 498 and is initialed by bp. Contributors include Margaret Avison, David Aylward, Nelson Ball, Earle Birney, bill bissett, Barbara Caruso, Steve McCaffery, bpNichol, and Michael Ondaatje among others.
David W. Harris, bpNichol, and Rah Smith, eds. *grOnk*, [Series 1], no. 1. Jan. 1967.
Contributors are bill bissett, Jean-Francois Bory, Victor Coleman, Pierre Garnier, David W. Harris, bpNichol, Rah Smith, and D.R. Wagner. Cover by Jean-Francois Bory.
[bpNichol, ed.]. *grOnk*, Intermediate Series, no. 11. 1978.
Loose sheets in plastic folder. This whole issue publishes “Off’N’On Chains” by Opal L. Nations. Cover collage is by bpNichol. This is from an edition of 200 copies.
bpNichol. *grOnk*, Random Series, no. 4. Oct. 1984.
Saddle-stitched. This whole issue is devoted to publishing “Plates (to Accompany ‘The ‘Pata of Letter Feet’)” by bpNichol. This is from an edition of 50 copies.
[bpNichol, ed.]. *grOnk*, Series 7, no. 8. [ca. 1971].
Side-stapled wrappers. This whole issue is devoted to publishing “Other Americans” with contributions by Richard Latta, Michael Phillips, Richard Kostelanetz, and Amelia Ettinger. bpNichol contributes cover lettering within a graphic by Richard Latta.
[bpNichol, bill bissett, David UU, Steve McCaffery, and other eds.]. *grOnk*, Series 8, no. 6. [ca. 1972].
Stapled wrappers. This whole issue is devoted to publishing “Toronto Pomes” by Pedro Xisto.
bpNichol, ed. *Panelogic*, no. 2. Feb. 24, 1975.
Single sheet printed on both sides and folded once to make four pages. Published by Therafields Environmental Centre Limited. Cover is by John Liguore (top) & Gilles Morin. Includes bpNichol’s “Lonely Fred the Cowboy Hero” part 10.
bpNichol. *Sharp Facts: Some Selections from Translating Translating Apollinaire* 26. Membrane Press, 1980.
Wrappers.
David Aylward. *Crossword*. Seripress, 1975.
The “crossword” alphabet was created by the author. Three leaves in a card folder. This is from an edition of 100 signed by the author.
Nelson Ball and Barbara Caruso. *The Shore: A Poem*. Seripress, 1974.
A poem by Nelson Ball and two serigraph prints by Barbara Caruso. Three leaves laid into a card folder. The prints are signed and numbered by Barbara Caruso. This is no. 7 from an edition of 50 copies and is signed by Nelson Ball.
Barbara Caruso. *Colour Lock, Black Series*. Seripress, 1976.
Eight serigraphs printed in 5–7 colors. Ten leaves in a portfolio, in a slipcase. Each print numbered and signed by the artist. This is no. 2 from an edition of 20 copies.
bpNichol. *Aleph Unit*. Seripress, 1973.
Panel two from a series of eight: “Aleph Unit Opened.” Twelve leaves in a buckram folder. This is no. 46 from an edition of 70 signed by the author.
bpNichol. *Alphabet / Ilphabet*. Seripress, 1978.
Three leaves in a folder. Drawn and printed by Barbara Caruso. This is from an edition of 70 signed by the author.
bpNichol. *Door to Oz*. Seripress, 1979.
First panel from a series of eight. Ten leaves in a folder. This is no. 57 from an edition of 100 signed by the author.
bpNichol and Barbara Caruso. *H: An Excursion*. Seripress, 1976.
Panel from a serial poem silkscreen printed. Ten leaves in a folder. This is no. 36 from an edition of 60 signed by the authors.
bpNichol and Barbara Caruso. Pilot studies toward *The Adventures of Milt the Morph in Colour*. “And Yet?” (top) and “Oh” (bottom). Seripress, 1971.
There were 12 copies of “Oh” and 13 copies of “And Yet,” all uncirculated. “Oh” is no. 4 from an edition of six copies signed and dated by Barbara Caruso. “And Yet” is signed by Caruso on verso.
In addition to the pilot studies, the collection includes *The Adventures of Milt the Morph in Colour*. Seripress, 1972. Eleven leaves laid in a buckram folder. Of the eight serigraphs included, six are numbered and signed by the author and the artist, two are signed only by the artist, and all are dated 1971. The collection includes no. 3 of 25 and is signed by both bpNichol and Barbara Caruso.
Stephen Scobie. *Airwaves / Sealevel / Landlock*. Seripress, 1978.
A single leaf in a folder. This is from an edition of 100 copies signed by the author.
**jwcurry / Industrial Sabotage**
[jwcurry, ed.]. *Industrial Sabotage*, no. 3. 1979.
Side-stapled wrappers. Also issued as Curvd H&z, no. 8.
[jwcurry, ed.]. *Industrial Sabotage*, no. 13, March 1983.
Side-stapled wrappers. Also issued as Curvd H&z, no. 186, 1cent, no. 100, and Toybox, no. 3. Cover drawing by Joe Brouillette. Contributors include Joe Brouillette, jwcurry, Linda Davey, Mark Laba, bpNichol, Michael Ondaatje, Jim Shedden, and Steven Smith.
jwcurry and Mark Laba, eds. *Industrial Sabotage*, no. 21. Nov. 12, 1983.
Stapled wrappers. Also issued as Curvd H&z, no. 249. This a facsimile reissue of *Industrial Sabotage*, no. 12. This is no. 91 from an edition of 100 copies.
[jwcurry, ed.], *Industrial Sabotage*, no. 25, Dec. 29, 1983.
Single sheet folded three times to make eight panels. Contributors are jwcurry, M.B.Duggan, LeRoy Gorman, Mark Laba, and Steven Smith.
[jwcurry, ed.], *Industrial Sabotage*, no. 28, 1984.
Single sheet printed on both sides and folded to make a leaflet. Also issued as Coma Goats, no. 37, Gurvd H&z, no. 298, Elvis Car, no. 2, and In Tents, no. 6. Cover by Lillian “Emo” Necakov. “[P]ublished on the occasion of the unwavering trepidation of four young primates reading at Kontakte on Toronto’s fashionable Queen Street West October 27, 1984.”
jwcurry, ed. *Industrial Sabotage*, no. 51. June 1991.
Loose sheets laid in wrappers. Cover photograph by Chester Baker. Also issued as Curvd H&z, no. 423. This issue publishes “Sights for Sore Eyes” a collection of five scores.
jwcurry. *BeRzeRkeR hyPeRgRaPheR*. Canadian Small Change Association, 2014.
Saddle-stitched. Photos and text by jwcurry. This is from an edition of 100 copies.
jwcurry. *Can’t Afford No Kodak Instamatik Instamatik*. Curvd H&z, 1980.
Stapled upper left corner. Also issued as issued as Curvd H&z, no. 54 and Th Wrecking Ballzark, no. 16.
jwcurry, ed. *Running Head*. Underwhich Editions, 1983.
Loose sheets in a sleeve with an acetate window. Contributions by Mark Laba, Joe Brouillette, Peggy Leffler, bpNichol, George Swede and jwcurry. This is no. 38 from an edition of 50. copies. Each sheet is signed by contributor.
Til Nux Tse: An Optiphony
jwcurry and Peggy Lefler. *Til Nux Tse: An Optiphony*. Underwhich Editions, 1987.
Folding silkscreen printed card with silkscreen print tipped in. This is no. 46 from an edition of 51 copies signed by jwcurry and Peggy Lefler.
Assorted Canadian Concrete
Shant Basmajian. *Spare Change: Poems*. [Old Nun Publications], [1972].
Saddle-stitched. Photographs by Richard Gabinet.
Derek Beaulieu. *Flatland: A Romance of Many Dimensions*. Information as Material, 2007.
Wrappers. Afterword by Marjorie Perloff. Inscribed by Derek Beaulieu to Charles Bernstein.
Derek Beaulieu. [Letraset]. Poster, 23 1/2 x 33 inches. N.p., [2010].
Poster, 23 1/2 x 33 inches. Produced for Crimmitschau, Germany’s Atomino Experimental Art Festival in an edition of 100 copies. The 1st 50 of which were to be hung throughout the city by Crimmitschau’s Town Hall. The remaining 50 copies are signed and numbered. This is no. 23 from an edition of 50 signed copies.
Judith Copithorne. *Runes*. Coach House Press / Intermedia, 1970.
Stapled wrappers. This is from an edition of 500 copies.
Paul Dutton. *Right Hemisphere, Left Ear*. Coach House Press, 1979.
Wrappers.
Ken Lewis. *These! Encampments*. The Quarry Press, 1982.
Wrappers.
Owen Sound. *Specifications*. Wild Press, 1978.
Five loose pages printed on one side in printed wrappers. This is from an edition of 100 copies. Published on the occasion readings by the sound poetry group Owen Sound: Michael Dean, Steven Smith, Richard Truhlar, and David Penhale at Vivaxis, Toronto, May 12, 1978.
John Riddell. *Criss-Cross: A Text Book of Modern Composition*. Coach House Press, 1977.
Perfect bound. Review copy. Edited for the publisher by bpNichol.
Steven Smith and Steve McCaffery. *Edge*. Anonbeyond Press, 1975.
Side-stapled wrappers with tape over spine. This is from an edition of 100 copies. A "collaborative xerox composition" between Steve McCaffery and Steve Smith. This is McCaffery's first book. Inscribed by Steve McCaffery to Jackson Mac Low.
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Is global trade set to fade?
From the editor: We criss-cross the globe to answer this question, concluding that world trade and globalisation are here to stay as the world becomes increasingly intertwined. Risks are increasing though, both systemic and political, as austerity bites in the west. We interview Ian Goldin, Professor of Globalisation at Oxford University & Reinhard Lange, CEO of Kuehne + Nagel, and our tech, transport and commodities analysts dig into the world’s supply chains.
You can argue that there have been two golden eras of global trade; the 1871-1914 period and the period from the early 1980s to the present day. Today, the world has never been so large in terms of population, yet so small in terms of communication speed. Our lead article asks, has global trade peaked and is it set to reverse? At risk of ruining the surprise, we conclude that there are so many layers of interwoven complexity propping up globalisation and interconnectedness, and so many mutual benefits, that it is hard to see it being unwound.
But we do think it will be tested, sorely at times, over the next few years – the politics of slow economic growth may see some politicians advocate protectionist policies, ones that history implies cause economic damage. A bigger threat also looms: has globalisation ushered in a labyrinthine web of connectedness, creating disproportionate systemic risks that are neither fully understood nor easily controlled when tested? These issues are explored in our interviews with Professor Ian Goldin of Oxford University and also Reinhard Lange, CEO of Kuehne & Nagel.
We also look at the big new trade lanes (intra-Asian trade flows could be 9x bigger than US-Europe by 2030) and how the changing face of global trade is merely a reflection of a changing world. Our tech team outlines the key role of software in managing the increasingly complex supply chains that make key industries work. Jeff Currie discusses changing commodity flows, pointing out how the US has become less reliant on energy imports. We also show the supply chains for Apple and a Boeing 787 highlighting the global nature of manufacturing.
How the new world will flow
Containerised trade flows between regions of the world
Source: Drewry Research Market Summary, World Shipping council, Sea Asia 2011 conference, US MARAD, Goldman Sachs Research.
What’s inside
- Is global trade set to fade? our lead article on the resilience of and risks to global trade
- Interview with Reinhard Lange CEO of Kuehne + Nagel
- The new trade flows: Edouard Baldini charts the flows of the future
- Interview with Dr Ian Goldin: Professor of Globalisation at Oxford University
- Commodities networked: Jeff Currie on the changing shape of global commodity flows
- The brains behind global trade: Our tech analyst on the technology powering global supply chains
Is global trade set to fade?
Before we look at what’s next for global trade, we want to determine what the quantities and quantities of flows around the world are. In 2009, US$8.3 tn of industrial goods were exported globally, and US$2.3 tn of commodities were traded, whereas services exports accounted for US$3.3 tn and private capital for US$412 bn. Capital flows, for example, have dramatically increased as currency mechanisms have loosened post the Nixon Shock of 1971, leaving their gold anchors and increasingly their pegs to one another behind.
This liberalisation of capital (and increased tolerance of trade deficits) meant that it was able to flow around the world with impunity, chasing higher returns and levelling out differences in asset valuations. All of this meant that global trade became easier to fund, and consequently, trade barriers fell hand-in-hand with lower tariffs.
If capital has been a crucial stimulant and lubricant of global trade, then the western consumer has been equally important. The advent of containerisation (yet another innovation by the military, proving that adversity really is the mother of all invention!) meant that goods could be manufactured vast distances away from the point of consumption. This meant that the world could start using its resources (including labour) much more efficiently.
Containerised trade increased from 13.5 mn TEUs in 1980 to 68.7 mn in 2000, and to 138.9 mn in 2010. This was a very welcome disinflationary shock to the west, and spurred the prolonged consumer boom that was heralded by the slaying of inflation in the early 1980s (and arguably prolonged by the global savings glut of the 2000s which kept real interest rates very low – another example of globalisation at work). Taking 1980 as our starting point, the major trade lanes were US-Europe, US-Asia and Europe-Asia, basically circling the Northern hemisphere, with intra-Asian trade being very small. Roll forward thirty years and the major trade lanes have changed, with intra-Asia now the biggest trade lane, bigger than the Trans-Pacific trade. Some new lanes have sprung up too; for example Asia’s container trade with Africa, Latin America and Australia is expected to grow at rates well in excess of the world average (over 8% pa since 2008). This means, among other things, that supply chains will need to be reshaped, and that the average distance travelled by goods will fall.
The decline of inventory
Euro Stoxx 600 working capital vs. net sales
Source: Datastream.
The genuinely global supply chain
Falling trade barriers and technological advances have led to global supply chains being the norm. Just-in-time manufacturing, and global sourcing of components, raw materials and technology mean that whole regions can become factories without borders. Intra-Asian trade works in this way, with places such as Japan playing a crucial intermediate role in supply chains. Inventories are now very low versus history, meaning that capital has been removed from businesses, and manufacturing costs have been minimised, all of which contributed to the disinflationary 1990s.
However, inventories relative to sales probably can’t fall much further from here; can Nokia really shrink the 8 minutes on average that components spend in its own supply chain? The real cost of shipping has steadily fallen over the past thirty years as transport companies, especially shipping ones, have kept the market oversupplied, often for strategic reasons (mostly in Asia). This also happened in the previous big surge in global trade growth in the 19th century when shipping costs fell by over a quarter. Transportation costs have also fallen relative to the value of the cargo being carried, though in the last couple of years this has reversed a bit with the rising oil price. If oil prices increased meaningfully again and no offsetting technology was developed, then this could act as a brake.
China becoming an import story
Imported TEU (Twenty foot equivalent unit, millions)
Source: Goldman Sachs Research estimates, IMF, U.S. National Statistics, BEA, OECD, MDS Transmodal.
If transportation costs aren’t a likely brake, then what could reverse the globalisation of trade? Based on two recent traumatic events it could be credit or physical disruption. When credit evaporated in 2008, global trade saw some of the biggest falls ever seen. When letters of credit became unacceptable to the world’s traders and merchants, the trade system shut down on itself.
A super-efficient supply chain can result in very narrow points where concentration risk is very high, such that when a natural disaster happens, an entire supply chain is knocked out. The after shocks of the Tohoku Japan earthquake were felt in multiple industries around the world (this has also been true with the recent floods in Thailand). Because supply chains have become so complex, more often than not the supplier of a component doesn’t know who the person two nodes away is, who in turn doesn’t know who the person two nodes away from them is. This adds a lot of systemic risk and it may be that the world decides after one too many shocks that it wants to simplify.
Falling trade barriers
Weighted average tariff on trade products
Source: World Bank WDI.
This then provokes a broader question, 'are we entering an era when the concept of globalisation will be tested in a way it hasn't been for 30 years?' Will the austerity years result in shifts in political outlook and rhetoric that seek to impose blame for current circumstances on globalisation? Globalisation has meant that in lower value-added industries jobs have been relocated or outsourced to where costs are much lower. Labour has seen its share of revenues fall, relative to profits, with corporate profits at long-run high levels of GDP in the west. This, combined with real increases in commodity prices, is putting pressure on disposable incomes, in stark contrast to the 1980-2007 golden age.
The system threatens the system
If you layer onto this systemic shocks such as food shortages or the credit crunch, then support in the west for globalisation may suffer. This is what happened after the 1929 crash, when protectionism rose sharply around the world as governments sought to protect their domestic industries. On this basis, Messers Smoot and Hawley are labelled the midwives of the depression, as their eponymous, tariff-raising legislation became the most famous of a period when the world went backwards. Another crisis could convince politicians that a reversal of globalisation would be preferable, if it reduced potential for crises, even if it meant lower growth. This is probably the biggest threat to global trade growth.
However, the world of today is different from then. Its honeycomb complexity would have even the most industrious bee colony saluting in awe. Unwinding the massive cross-border investment that companies and governments have made is difficult, and as the CEO of Kuhne & Nagel says in our interview on page 6, when 95% of US footwear is imported, how do you substitute that?
A world retreat into rigid silos and trading blocks would be difficult but not impossible. We note the proliferation of bi-lateral trade treaties in recent years, which indicates a move away from global, multi-lateral treaties. But set against this is the recent signing of one the biggest ever trade treaties by the US and South Korea, Colombia and Panama. Aside from the substantial overseas investments and revenues at stake for the corporate sector, it would be an inefficient use of the world's resources at a time when resources are constrained rather than bountiful. And if the west were to become more protectionist and disengage from a connected world it would need to be mindful of where it is betting on its medium-term economic growth coming from (i.e. exports). Roll forward the world to 2030, and the west will need to substantially raise its export levels to offset glacial domestic demand.
If mercantilism ends in Asia and currencies float freely then this and labour costs may shift industry cost curves in the west's favour, so some manufacturing might relocate. But it is likely that China, for example, would invest heavily in automation and also cede some activities to lower-cost, reasonably proximate geographies (e.g. Vietnam). But you can see how countries like Mexico may see their relative unit cost position improve. Much has been made of some manufacturing returning to the US, but so far we'd describe it as more of a trickle than a flood.
Mutual benefits
Global stock of foreign assets as a percentage of global GDP
Source: IMF, Goldman Sachs Research.
So as we said at the start, our base case is that the world remains deeply connected, with multi-location manufacturing, and goods and capital unimpeded in their flows around the world. But we see challenges and tests as the imbalances in the world persist and the west copes with balance sheet consolidation. How to position for this? We believe that there are parts of the transport supply chain that have strategic value (e.g. ports), so we highlight AP Moller-Maersk. We also believe that the software companies making supply chain management possible are valuable – Dassault and Aeva are our preferred stocks. Rather than the asset owners, we prefer the managers and enablers of flows, i.e. we structurally prefer freight forwarders to asset providers like airlines.
Hugo Scott-Gall
Editor
email: email@example.com
Goldman Sachs International
Tel: +44 (0)20 7774 1916
Two charts of global interest
A selection of the world’s 20 fastest-growing trade lanes
>US$2 bn annually (2010), based on 2000-2010 CAGR of imports and exports in current US dollars (includes re-exports)
Source: United Nations Commodity Trade Statistics Database.
The world in motion
Selected system suppliers on the Boeing 787 Dreamliner
Boeing 787 Dreamliner
Selected components and system suppliers
Source: Company data (Boeing), Goldman Sachs Research.
Six charts on global trade
The world opens up
Global exports as a percentage of global GDP
Source: World Bank, IMF, Goldman Sachs Research.
What a difference 30 years makes
Market share of global exports
Source: UN comtrade.
Some signs of insourcing
US manufacturing outsourcing trend
Source: US BEA.
The web expands
Cross border economic transactions as a % of global GDP
Source: World Bank, BIS, IMF IFS.
Where China gets its imports from
China’s Imports: per country and as a percentage of market share
Source: China National Bureau of Statistics, UN comtrade.
Wages rise in the east especially China
Manufacturing labour cost
Source: US BEA.
Reinhard Lange has been CEO and Chairman of the Management Board of Kuehne + Nagel since January 2009. He started his international career with Kuehne + Nagel in Bremen in 1971 following his apprenticeship as a freight forwarder. In 1985, he accepted a new challenge in Hong Kong, where for six years he successfully developed the seafreight business in the Asia-Pacific region as a member of the regional management team.
Hugo Scott-Gall: How has global trade evolved since the birth of containerization in the 1950s?
Reinhard Lange: It started with Sea-Land in the 1950s, the birth of containerisation, between the USA and Europe. It very quickly developed and affected global trade, with Asia Pacific becoming a major region, forming the trading triad; meaning Asia Pacific, the Americas and Europe. Asia was the major beneficiary of containerisation, as it could escalate its low-cost manufacturing. The mix of goods also changed. While traditionally, investment goods moved between Europe and America, with some consumer goods moving from the US to Europe, that is not the case anymore. So containers were the major escalator of global trade and it changed the mix of goods traded.
Now, South America, the Middle East, and a big part of Africa are also involved in global containerisation. In terms of value, initially very low-end goods were shipped from Asia, but now we see high-end products, such as computers and pharma, which were flying earlier.
The key drivers... compared to a bulk vessel, containers allow for much faster loading and discharge of goods. Ships spend less time in ports. Smaller shipments for consumer goods mean less pilferage and damage.
Hugo Scott-Gall: Which are the trade lanes of tomorrow?
Reinhard Lange: Over the last couple of years, the intra-Asia lane has become the biggest container trade in the world, beating Asia-Europe and Asia-North America. The key drivers? A lot of European or US exporters are now serving their Asian clients not from their domestic hubs, but using a direct shipping concept. For example, a well known sports fashion company could ship directly to its customers in Japan, with goods manufactured in Shenzhen, China, which doesn’t hit Europe or the US.
Even in Europe, we see an increasing number of short sea services, which are competing with hinterland transportation. In LatAm, trade between countries in South America and Central America, and the US is growing. These are relatively new.
Hugo Scott-Gall: So distances are getting shorter...
Reinhard Lange: Yes. And we will see shorter average distances from here on.
The other important issue is the growth in inventory management. It really started in the mid 1980s, when customers outsourced their supply chain management, giving inventory management more and more to logistics companies. The 2009 crisis fuelled this further. This has of course reduced finance costs, which is what inventory management is all about. And for this, logistics companies have developed very high-end value-added IT systems. Already they control up to 95% of global air freight. To give you an example, in the early 1980s, forwarders or logistics companies controlled only 10% of container shipping, but with these tools, with these capabilities they have increased that today to 40%. So 60% is still with the shipping line itself, but the trend is very clear. While it may not reach 95%, like air freight, big steamship line companies can foresee a situation in which logistics companies could control more than 50% of the market in the years to come.
Over the last couple of years, the intra-Asia lane has become the biggest container trade in the world, beating Asia Europe and Asia-North America.
Hugo Scott-Gall: Are your clients re-in-sourcing their third-party logistics post the 2009 crisis?
Reinhard Lange: No, there is no trend of customers re-in-sourcing again. It happened during the crisis in 2008-09, when they had empty warehouses for other reasons. But outsourcing will continue. Not just in contract logistics, but also highly sophisticated inventory management systems, which will be the major driver for growth in logistics companies.
Hugo Scott-Gall: Are the new lean supply chains more vulnerable?
Reinhard Lange: Inventory management is very important. Very often, companies have too much inventory, but orders can’t be cancelled without additional costs etc. But logistics management has become highly sophisticated. We follow up with shippers, have alternative shipping modes, alert systems etc.
Hugo Scott-Gall: And as the supply chain gets more complex in emerging markets, they would need third-party logistics too?
Reinhard Lange: That’s 100% correct. In South America, for instance, logistics is controlled by the multinational customers who would have their hubs locally to deliver within LatAm. This is the clear trend. China is a little bit different, because freight is paid for mostly by the customers, who hence control the supply chain.
Hugo Scott-Gall: Given the current market volatility and fears of a double-dip, what is your view of the world?
Reinhard Lange: We cannot compare today’s situation with the crisis in 2008, 2009. Today’s environment is tougher, because it still has so many uncertainties. There will be an impact on the real economy. We are feeling this already, it started in May, June. It started in air freight, which is always an early indicator, because global air freight is almost 50% an unwanted business. And since May, global air freight has seen negative growth.
Whether we’ll have just a further softening of growth, or a big recession, is difficult to forecast I think. At least, at Kuehne & Nagel we are ready for any kind of development, able to cope with the changes. So we expect a difficult first half of 2012 and hope for an improvement in the second half.
The next phase of global transport flows
Our shipping analyst, Edouard Baldini, dissects the realignment of global trade and what it means for transport companies.
Since the maiden voyage of the SS Ideal-X from Newark to Houston in 1956, which marked the birth of containerization, global trade has evolved significantly, from the trading of basic consumer goods between the US and Europe to the boom of the IT trade from China to the western world, fuelled by a drop in trade tariffs and the free float of most main currencies. For the past couple of years, the menu du jour has rather focused on global trade realignment, with the birth of new trade lanes, mostly South-South and intra-regional. Who would have imagined 20 years ago that Intra-Asia trade would become the world’s largest, 1.5x busier than Asia-Europe or Asia-US? And who would imagine today that China could import more TEUs than the US by 2019? Some obstacles remain however, with the spectre of protectionism rising again, albeit moderately, and a significant lack of transportation infrastructure in some of the key growth markets.
**The four ages of global trade**
Global trade evolution is best analysed through the prism of “product life cycle” theory: four stages which help better understand how global trade has evolved, where the big flows are and where the new flows are (and will be).
(1) In the first phase, the product, or the country, goes through an import substitution period in which competitiveness is rising, but the country is using imports for substitutes (it has still not reached the point of benefiting from economies of scale through mass production; ICC between -1 and 0). Economies typically go through this phase as they emerge, as with India and Brazil currently. This explains the strong growth in the Asia-Latam; Mexico-Latam and Asia-India trades that we are currently witnessing. This trend is not to be under estimated - for instance Asia-Latam is now equivalent to 13% of Asia-Europe trade, and is growing double-digit.
(2) In the second phase, the country goes through an export period, where competitiveness rises with productivity, economies of scale appear and exports increase, (ICC of 0 to +1). Western Europe in the late 19th century and then the US in the early 20th century typically went through this “mass production” phase, resulting in a trade boom between the two regions (mainly consumer products). Japan won its status as “number one” in the post-oil crisis world, thanks to a different manufacturing model in which each product has its unique parts. This was very relevant to the transportation industry (e.g. Toyota). This dominance faded in the 1990s with the IT revolution and the emergence of Korea and ultimately China, with a move back to US-style, more modular manufacturing (i.e. different parts can be used on different products). This shift of competitiveness from West to East, and within the East, explains the boom of the Asia-Europe and Asia-US trade lanes of the past 40 years, and the emergence of the Intra-Asia trade later in the 1990s/2000s, (see below).
(3) In the third phase, a country matures, its export competitiveness is maintained but its relative advantage declines as other countries catch up and produce at a lower cost, (ICC falls to a 1-0 range). Competitiveness is maintained by specializing in higher value added products. In a way, Germany and Japan are still in this phase as they tend to specialize in products such as machine tools or transportation and specialized machinery.
From burgeon to wither the four stages of global trade
The international competitive coefficient (ICC) of certain products in India/Brazil/Japan/China/EU/US (1995-2010) - this measures the competitiveness of a traded good (calculated as exports-imports/exports+imports)
Source: UN Comtrade, Goldman Sachs Research.
(4) Finally, in the last phase, called "reverse import", the country loses competitiveness to low-cost imports from other countries. This is particularly the case for the US today.
**At a turning point: global trade realignment**
Analysing global trade from an international competitiveness angle (refined to certain key products) helps understand how global realignment is, and should continue to be, a key feature of international trade going forward:
1. **China should remain a significant exporter of manufactured goods in the near future:** Although its ICC has been steadily growing over the past decade, it remains below 1 for most products, indicating high competitiveness. As its economy, and its labour costs, keeps growing, it will have (and already has in certain areas) to specialize in more value-added products, and enter its maturing phase. Interestingly, and as an illustration of this point, the dollar value of a kilo exported from China has gone from US$0.5 in 1997 to more than US$2.6 today.
2. **But should also become the world’s largest importer…** For certain products however, China is already close to reaching its maturing phase (e.g. furniture, telecom, IT) and is being challenged by India and South East Asia. Consequently, and similar to what happened with Europe, the US and Japan, China should progressively move from its current role as an export machine to a significant importer of goods, underpinned by the growth of its middle class. We calculate that China currently imports the same number of TEU per household as the United States did in 1975, growing at a CAGR of 14% since 1996. If this ratio grows at a similar rate to that of the US historically, then it will import more TEUs than the US by 2019, and more than the EU by 2022, (see below), significantly boosting global trade.
3. **…which it will source from India, South East Asia and the Western world** (including Indonesia) and Latam, which are still in their import-substitution phases. As their competitiveness is rising, they should shift the balance of trade with China and the western world to become net exporters, starting with low value-added goods and then moving along the value chain. Western economies should also benefit, as a growing number of Chinese consumer can afford higher-value goods. As such, we expect Europe-Asia to grow much faster than Asia-Europe.
4. **Regional trades should grow faster than global trade:** As we go through this shift, South-South trades should grow faster than global trade, buoyed by further bilateral free trade agreements within and between trade blocs. As shown on the map, Intra-Asia is already the largest trade lane in the world (TEUs carried, not distance adjusted). We expect Intra-Asia, Asia-Latam and Asia-Africa to particularly benefit from this trend.
**Who will benefit among the supply chain movers?**
Third-party logistics providers should keep growing at a multiple of GDP: As global trade developed and supply chains became more complex in the West (e.g. IT), third-party logistics providers emerged; in 1980, only 10% of the world shipments were handled by freight forwarding companies, we are now closer to 40%. As companies in emerging economies go through the same process of internationalisation, they will need more than just port-to-port or terminal-to-terminal transportation, and should therefore outsource more of their logistics.
Transportation infrastructure a key challenge but also an area for growth: A key challenge to the global trade realignment thesis is the lack of infrastructure in some key emerging economies. According to the World Economic Forum’s global competitiveness report, India ranked in the mid 80s (of 142 countries) on the quality of its ports and road infrastructure. Indonesia and Vietnam’s port assets respectively were 103 and 110. As governments invest more to bridge that gap, they will need the expertise of foreign private companies, sharing the growth with the best positioned operators (e.g. DP World, Hutchison, APM Terminal). Given the strategic value of these assets, JVs are more likely we think.
Shrinking distances between consuming and producing areas will negatively impact demand: As South-South and intra regional trades enjoy above-market growth, overall distances will shrink. For instance, it takes five days to travel from Shenzhen to Jakarta, compared to 28/30 days to northern Europe.
**Can the world de-globalise?**
The recent vote of the Currency Exchange Rate Oversight Reform Act by the US Senate, which would allow any “fundamentally misaligned” currency to be subject to duty taxes, has renewed fears of post-1929-style protectionism. It is true that globalisation has been made possible by a significant decline in trade tariffs over the past forty years, and the free float of main currencies. And there is evidence that tariffs are rising for the first time since 1998 (from 1.7% in 2008 to 2% in 2010 in the US).
However these remain extremely low in absolute terms and in the context of history. And as the US is at a completely different stage of its “product life cycle” than China, repatriation of manufacturing activities would imply a fundamental industrial shift, with a significant impact on the consumer, as China’s manufacturing costs are still just 14% of the US’s. Rather, the US would source the same products from different low-cost regions. Mexico is often mentioned as a key beneficiary, and there has been some headline grabbing evidence of the US switching trade away from China to Central America. However, this evolution is marginal: for most of the 13 key products we analysed, China is still gaining significant share in the US market vs. Mexico, with the notable exception of vehicles and entertainment goods.
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Eduard Baldini
European Transport, Travel & Leisure analyst
Email: firstname.lastname@example.org
Goldman Sachs International
Tel: +44 (0) 20 7774 5715
Dr. Ian Goldin was the VP of the World Bank (2003-06) and prior to that the bank’s Director of Development Policy. He is a Professor of Globalisation and Development at Oxford University, holds a Professorial Fellowship at Balliol College, Oxford, and now serves as the first Director of the Oxford Martin School (www.oxfordmartin.ox.ac.uk), founded in 2005 to facilitate and innovative inter-disciplinary research on the problems, dangers and opportunities of the near future.
Hugo Scott-Gall: Does the world become more connected from here?
Ian Goldin: We’re more connected than ever in history, and there’s been a leap in the level of connectivity over the last 20 or so years. We’ve seen the fall of the Berlin Wall, the opening up of about 64 countries, from dictatorships to more open, more democratic economies, the implementation of a succession of trade rounds, which has pushed trade tariffs to well under a third of the level they were in the 60s and 70s, and the period subsequent to the 1990s. And, we’ve seen the effectiveness of capital account liberalisation through various reforms that the World Bank, IMF and others have engaged in.
On any metric you look at, be it flows of goods, services, telecommunications traffic, internet traffic obviously, you see this very, very steep incline in connectivity around the world. And not only in terms of the breadth of the different forms of connectivity, physical, virtual, but also the types, the ranges – not only bankers or the manufacturers of goods and services that are connected, but everyone. It’s the hip-hop dancers in Harlem connected with hip-hop dancers in Shanghai. What’s driving this? Things like containerisation and fibre optics have been incredibly powerful changes. Growth in incomes as a key driver, not least the rise of the emerging market middle class. We’re seeing a convergence of aspirations across the world. All this makes me optimistic that we’ll get more, not less connected from here, and see an unleashing of collective brain power that can be applied to global problem solving.
Hugo Scott-Gall: But globalisation isn’t working for everyone?
Ian Goldin: There’s an underbelly of people who are disconnected, because they’re geographically isolated or lack physical infrastructure. But most often it’s because their governments have disconnected them, by banning internet or not allowing connectivity, or because only a very small number of people in that country benefit, like, say in Angola. The big challenge is ensuring this globalisation process is inclusive, and that more people benefit. Most people have benefited, but there’s the bottom billion who are basically left out.
Hugo Scott-Gall: What about the systemic risks of connectivity?
Ian Goldin: First, it’s important to stress that globalisation has been the most progressive force in the history of humanity, in terms of its ability to transform for the better people’s lives around the world. But the other side of this integration is interdependency, and the very high level of systemic risk that has developed because of the increase in complexity and extent of connectivity. We have seen in the financial crisis the first very clear evidence of systemic risk, and how it’s going to propagate in many other ways in the future. Lehman Brothers was a node with a lot of traffic going through it, but that wasn’t fully understood, and that’s very characteristic of the problem. When, for whatever reason, that node becomes overwhelmed you get contagion, and risk that cascades very rapidly, that gets amplified very rapidly and jumps previously secure risk frontiers. This is characteristic of systemic crises, they quickly and completely overwhelm the regulatory and management capacity to deal with them. The financial crisis is the first of the 21st century systemic crises, and certainly not the last.
Hugo Scott-Gall: So it’s unavoidable, we become less stable?
Ian Goldin: When we’re building these super-connected systems, a source of our future wealth and well being on the planet, we must be mindful of the Achilles heel of this, which is that we’re also building a pathway for systemic risk. We’re going to become increasingly unstable unless we understand the new levels of complexity and risk and build resilience. Politically, we face the danger that if people see globalisation and integration as bringing unwanted and severely destabilising shocks, politically they will choose a potentially slower, but more predictable, growth path. And what you get politically out of a response to this is xenophobia, nationalism, protectionism, increasing trade barriers, blaming others for your problems and a belief that somehow you can go it alone.
Failure to manage systemic risk could lead to de-globalisation, and this would be absolutely disastrous in the short-term and the long-term, particularly for poor people who have not yet been able to benefit from globalisation, but more broadly for everyone. Even the middle classes may feel that there is more downside than upside for them from globalisation and so may push against it. So, we need to make the system much more robust, we need to become more mindful of the systemic risks.
Hugo Scott-Gall: It’s not just financial crises that worry you?
Ian Goldin: The thing I’m most worried about is pandemics. I believe that there will be another serious pandemic that could severely destabilise globalisation, and that could spill over into finance. I’m particularly worried about the rapidly evolving technology to develop man-made bio pathogens. I think this is a real threat, maybe not immediately, but certainly in the next 20 years, and what we do about it now is very, very important.
The reality of living in a global village is that the people that want to do the village harm have more powerful weapons now and that individual actors or small groups may be as threatening as nation states. I think about them as the new pirates - people who can strangle globalisation and destabilise it. In addition, we need to be concerned with climate change, and systemic risks associated with environmental and natural resource destruction, particularly damage to the atmosphere. This could lead to a reaction against growth and connectivity. Increasing weather instability, for example, could have serious, multi-layered consequences. Migration and the movement of people are absolutely intrinsic to connectivity. It is the most important part of this, and if people cannot move because of increasing xenophobia, protectionism and the view that connectivity brings more problems than benefits, globalisation will slow and the desire to keep out migrants will be among the first casualties. Societies that don’t absorb people will become ossified and unable to compete in the future world.
Hugo Scott-Gall: Who polices the inter-connected global system?
Ian Goldin: Unlike a traditional village, where you can rely on the village elders to solve problems and so sleep well at night, what hasn’t worked in the new age of globalisation is global leadership and global coordination of global problem solving. We are stuck with a 20th century, pre-1990s model created in a very different cold war world. This is a major problem since connectivity and integration has increased tenfold or more, depending on the flow one is measuring, while institutional evolution has maybe increased by a tiny fraction – the growing disconnect between connectivity and integrated global problem solving is the biggest challenge.
China’s role is very interesting; it has changed its level of connectivity most rapidly over this 20-year period. Will it become the global village elder? From my discussions with the Chinese there is a remarkable diffidence about being the global leader, it’s the opposite of the US where they say, ‘we are the global leader’. The Chinese say, ‘we were the global leaders some 300 years ago, and we’re coming back to what we used to be’. But China still has over 300 million people living in severe poverty. We have to meet our own economic, political and other needs at home first, before we can provide leadership outside China’. In China, as is the case elsewhere, the domestic trumps the global challenges.
Hugo Scott-Gall: Do you think events like the Japanese earthquake, which highlighted the fragility of interconnectivity, can become catalysts for de-globalisation?
Ian Goldin: Not necessarily, but we can learn from them. A chip manufacturer in Japan had 97% of world’s production in one of the affected places; that concentration should’ve never been allowed. It used to be illegal in the US to have that sort of corporate hold on any one production, but de-regulation has allowed concentration of production and that’s a major cause of the problem. One insurance is ensuring you’re not dependent on any one source in one place for any one product that’s key to your supply chains or your consumption chains. That’s a vital lesson, and we should seriously consider legislation and regulatory means to avoid monopolisation of critically important products. Secondly, business and accounting practices have placed extraordinary emphasis on ‘swearing assets’. Capital on balance sheets, stocks in warehouses and other ‘wasted’ assets. The incentives are all directed towards creating tighter supply chains and eliminating any spare capacity in the system. So when you get a shock at any point in the chain, it amplifies very quickly through the whole system and knocks out the whole supply chain. This doesn’t only apply in the private sector, the just in time concept now applies to public service utilities as well, including the food in your kitchen, the oxygen bottles in your hospitals, energy in the grids. You name it.
Hugo Scott-Gall: Could that make the world less efficient in its resource use though, for example, if import substitution rises?
Ian Goldin: I’m a fierce believer in freer trade. I believe that is not only optimally efficient, but also the better way of insuring against instability; I think it’s the most diversified strategy. The Central Limit Theorem informs my thinking. The more countries that participate in the market place, the more stable and diversified you are in terms of sources. The idea that when at home, you can somehow protect yourself by growing things is, I think, a Luddite concept. The US should not be growing cotton through subsidies which distort markets, and benefit well off farmers in the USA while ruining the employment and income opportunities of millions of poor farmers in Africa. Nor should the distortions of the European Union which have no economic rationale, are environmentally destructive, and which increase poverty in developing countries be condoned. There is a misuse of public resources and it accentuates poverty and price instability. The distortions of markets to support biofuel production is similarly inappropriate, not least as it may be counterproductive in terms of its carbon and energy input, with a range of negative spill-overs.
Hugo Scott-Gall: Are you, like consensus, gloomy on demographics?
Ian Goldin: Well, I’m an optimist on demography in general, I think the problem of 2050 is going to be too few people, not too many, particularly young people in key places where they are wanted. If you assume entry and exit ages to the labour force are more or less the same as they are now, the rapid change in demographics implies a decline in the OECD workforce of from about 800 mn to 600 mn people over this period. Current levels of migration into the OECD are about 10 mn, so even if there was an increase of ten times the migration levels, which is difficult to imagine, it still wouldn’t begin to compensate for the decline. Migration’s important for many reasons, but it won’t fully compensate for the dramatic decline in fertility rates in rich and developing countries.
I think we will abolish the concepts of retirement and pensions. Certainly, there are people who will work and think of their lifecycle in a different way – when the retirement system was developed about 7 years of pension were contemplated but now, life expectancy following retirement is approaching 30 years. If you’re healthy, if you feel you can still contribute to society, and if your savings are depleting and you’re only getting a 1% or 2% return on them, then you’re going to have to keep on working for a very long time. It has all sorts of other implications – your kids will only inherit your house when they’re 80.
Hugo Scott-Gall: And on life expectancy?
Ian Goldin: The big question here is on neuro-degeneration, as while there are major advances in physical regeneration and life extension, there is much slower progress on diseases of the brain, such as Parkinson’s, Alzheimer’s and dementia. One can see a transition period until we manage to meet many of the biggest challenges. I worry about the next 20, 30 years as they’re potentially a perfect storm period, for food, water and energy, and also for neurological disease reasons. I think physical regenerative capacities are leaping ahead of our own neuro-regenerative capacities. And that’s going to create an environment where we have rapidly increasing numbers of highly dependent old people. That’s going to have all sorts of consequences; one is a lot of helpers at great cost. The second is a whole new debate about euthanasia and who pulls the plug, when and why. By the time we get to 2050, I believe we’ll have conquered a lot of our neuro-degeneration problems and diseases. In that case, there’ll be an environment where 110 year olds are mentally and physically, on average, healthy and working. By then we will have also have climbed the big mountain that we face in terms of the management of rapidly growing demand for energy and natural resources and population will have stabilised. If we have not managed our global commons we will be in a dark period. But we are witnessing an unlocking of potential, with billions of newly educated people connected and aware, which I believe has the potential to help us meet our enormous challenges. If we can navigate through the perfect storm which is coming we can look forward to decades of declining population and reducing pressures in a world which by 2050 could be free of poverty and many of the diseases which afflict us today. Recent decades have demonstrated the benefits of globalisation and closer connectivity. Our challenge now is to understand how to build on this momentum and to mitigate the challenges arising from our success, not least with respect to the new systemic risks.
The high level of macro uncertainty that has engulfed markets recently has created significant concerns over the future of commodity demand in the US and Europe. This heightened concern overlooks a simple fact. Demand in these regions has been shrinking for many years now, as it must decline to make room for surging demand from the emerging markets. This is why, in the first half of 2008, oil prices surged to record levels despite the US and Europe already being in recession. These patterns have been seen across key commodity markets, but have been most profound in copper, where significant supply constraints have forced an unprecedented rationing of developed market consumption to make room for robust emerging market demand for infrastructure development.
EM have crowded out DM demand
Copper demand in 000 tonnes
Source: Brook Hunt, Goldman Sachs Global ECS Research.
We have long argued that the supply of key commodities such as crude oil and copper is inadequate for both developed and emerging market consumers to continue to consume at the same rate they had been doing. Accordingly, prices must rise to the point that causes consumers in the US and Europe to reduce demand sufficiently to accommodate the new and large appetite for commodities from the emerging markets. The key is that an emerging market consumer is willing to pay more for commodities than a developed market consumer, as the use in places such as China and India creates more economic value than it does in the US (which in many cases is simply commuting to the mall, or some other low-value activity). In other words, the marginal value of a barrel of oil consumed in China is far greater than the marginal value of the barrel of oil consumed in the US.
In 2009, we labelled this dynamic “resource realignment” – the need to reduce consumption of commodities in the developed markets to make room for robust economic growth in the emerging markets. To achieve this realignment prices need to rise to a level that creates demand “restraint” in the US, and other developed markets, generating an additional source of supply for emerging market consumers. The size of this realignment is substantial in many important commodity markets. For example, the US has 5% of the world’s population, but consumes roughly 25% of the world’s oil supplies, while China has 25% of the world’s population but consumes only around 10% of the world’s oil supplies. It is these numbers that need to be realigned over the next decade.
Clearly the primary effect of this dynamic is a sharp rise in commodity prices to levels that adequately reduce demand in the developed markets to free up commodity supplies, but there are significant secondary effects that we explore below, including slower economic growth in developed markets, a narrowing in developed market trade balances and lastly, and most importantly, significant investment in new technologies. And it is this last point that paradoxically suggests that commodity markets, the first and most globalized of all markets, are becoming more localized in the pursuit of becoming increasingly more self-sufficient, at least over the medium term.
Resource realignment is a supply shock to developed world
Outside a few temporary supply disruptions, such as in Iraq and Libya, the defining feature of the now decade-long rally in commodity prices is that it has been largely demand driven, and not due to a supply shock, as was observed in the 1970s. Instead of a sharp reduction in supply that dragged both demand and economic activity down, as occurred in the 1970s, in the current environment it was demand marching up a steep supply curve, or in some cases running headlong into supply constraints, that created the sharp rise in prices.
Middle East demand has capped exports while China gets an increasing share at the expense of the OECD
Middle East oil exports (000b/d)
Source: IEA, Goldman Sachs Global ECS Research.
While this demand driven interpretation is a global phenomena, it is less true locally, particularly for the developed markets where resource realignment has created a quasi supply shock that has and will continue to act as a drag on economic growth. We estimate that had we not seen the rise of emerging market demand for commodities in the 2000s, and had oil prices remained near US$20/bbl, US economic growth would have been 25-50 basis points higher each year on average over the past decade.
This creates a trade-off between growth in China and growth in the US, and this was very apparent in 2009 when a deep recession in the US and the developed markets allowed China to grow...
unimpeded, consuming unprecedented amounts of commodities. That year, China overtook the US as the largest buyer of Saudi Arabian oil, forever changing the trading patterns and the politics of oil. But equally important, not only was Chinese demand for oil rising rapidly, but so was Middle Eastern and Saudi Arabian demand for oil, such that exports from the region have been mostly flat since 2000, leaving less supply to be split between emerging and developed markets. Over the past decade, Saudi Arabian demand is up 70%, which alone has taken 1.1 million b/d of supply off global oil markets.
**Resource realignment improves the US trade position**
Not only has resource realignment created both a reduction in Middle East supplies and a redirection of supplies towards the east, but even the US has become a net exporter of oil products to Latin America, while Western Europe exports products to Eastern Europe and Africa, and even Japan exports products to China. As the developed markets import less and export more, this transition begins to have a significant impact on their current account positions, particularly for the US, where oil represented nearly 40% of the current account deficit in 2010.
The most recent data from the US suggests that since late 2006, net imports of oil and oil products into the US have declined by nearly a third. This impressive reduction in net imported oil was achieved through a combination of a significant reduction in demand, new and growing exports markets in Latin America and new domestic supply sources. Going forward, we expect that the US trade position will continue to improve as all three of these factors act to reduce US dependency on foreign oil.
**Resource realignment stimulates innovation**
This significant shift in oil flows away from the developed markets and towards the emerging markets was not simply achieved by a reduction in demand in the US and Europe, it was also achieved through technological innovation and investment in alternative energy sources such as oil and gas shale, biofuels and other renewable energy sources. The resulting high prices that create resource realignment also put a premium on a country being self-sufficient in commodity production, which stimulates investment into alternative domestic supply sources. This do-it-yourself dynamic has been most impressive within US domestic energy, particularly in oil and gas.
Although this process began in 2006 with significant development of biofuel supply sources (which have a whole host of problems on their own that are beyond the scope of this piece), the shale gas revolution that took hold in 2008 is what significantly changed the current energy position of the US. It illustrates an import theme we have emphasized in the past – don’t bet against an engineer, give them enough time and money and they will solve the problem. By 2010, these technologies were being applied to petroleum with the development of oil shale that has dramatically increased the ability for the US to grow oil supplies just as it demand is shrinking.
**Technological innovation will push US supplies to new highs, backing out more supplies to go to China**
US crude (conventional and non-conventional), NGL and renewables production (b/d)
Source: DOE, Goldman Sachs Global ECS Research.
**Globalisation leading to temporary localisation, but globalisation will prevail**
The irony of this is that commodity markets, the first truly globalised markets capable of efficient arbitrage to every corner of the planet, are now becoming more localised and in some cases entirely disconnecting from the rest of the rest of the world. This localisation is most dramatically captured by the US natural gas market, which has completely disconnected from the global gas market due to shale gas development. With US natural gas prices trading at a 65%-75% discount to global prices, the US now enjoys a substantial competitive advantage relative to the rest of the world that consumes much more costly natural gas.
However, this advantage will likely dissipate over the longer term, as infrastructure development will likely ultimately make the now local US supply available to the rest of the world at the same time that the threat of rising US shale natural gas and oil should motivate expansion of global supplies to the benefit of the world as producers strive to maintain market share. But in the meantime, resource realignment will likely continue to support commodity prices, which will give the engineers more time, and more money, to potentially create new revolutions that could further change global trading patterns.
Jeffrey Currie
Global Head of Commodities Research
Co-Head of European Economics, Commodities & Strategy Research
Email: email@example.com
Goldman Sachs International
Tel: +44 (20) 7774-6112
The software that enables trade
Mohammed Moawalla, our software analyst, explains the crucial role of collaboration software in making global supply chains work.
The roots of the collaboration software industry can be traced to the development of the wider applications software market. Approximately 20-25 years ago, large companies began implementing systems of record, such as ERP applications or systems of design such as CAD applications, to automate core processes. Approximately 15 years ago, additional investments were made in supply chain software systems, to better plan and optimise. Though these systems significantly improved the overall efficiencies of large enterprises, they still existed in separate silos (in part due to products built on differing code bases), limiting their full benefits.
It was not until the advent of middleware, data management and analytics tools in the last decade that companies were able to harness the information in these disparate sources. Today these systems have evolved into full collaboration suites and platforms, and are seeing wider adoption particularly among industries with meaningful supply chains and connectivity.
In essence a collaboration system manages the flow of information of a product and process among all the various participants. The basic elements of a collaboration platform include data management (the ability to extract and interchange data from disparate sources), product visualisation (team collaboration, conferencing tools and digital prototyping) and managing the engineering changes of components, configuration of products, document management and planning project resources, timescale and risk.
Collaboration across the entire value chain for the high tech industry
Technology changes (emergence of SOA and Cloud) facilitate even greater collaboration
Each technology cycle has facilitated an increased level of collaboration, and the shift to the internet has been a significant enabler. Phase 1 of the advent of the internet, the emergence of service oriented architectures (SOA) provided a common highway code on which applications for the internet are built – this process has enabled easier sharing of data between applications.
Phase 2, the evolution of the cloud infrastructure, has allowed the proliferation of new applications, access to multiple devices beyond the desktop, and we think greater consumerisation of IT. For example, Facebook, is probably the best example of a collaboration platform, fostered by the cloud.
We believe future enterprise applications and collaboration platforms will evolve to incorporate social media capabilities and mimic a lot of the features available on Facebook and Google+.
such as video conferencing, in-platform application running, messaging - both one-to-one and group-based, location-based services accessible across multiple devices.
**An emerging product category that is under-penetrated**
We expect the collaboration software market to grow at a 10% CAGR over the next 2 years; to put this in context, it is among the top quartile of growth categories within the broader software universe. The key drivers around the adoption of collaboration systems include more global proliferation of supply chains in industry, moves towards just-in-time inventory and production, reduced time to market, improved product quality, savings by avoiding duplication of data, better integration of engineering workflow and documentation to aid compliance with regulatory requirements. Collaboration systems are increasingly becoming the nerve centre or critical hub linking the tightly and loosely-coupled supply chains driving many industries. Hence, they must be scalable - for example Boeing estimates that during the design phase of the Boeing 777 programme, 1.9 petabytes of data was shared and transferred on its network. Unlike back office or design systems, collaboration systems touch a much wider user base in an organisation, and industry estimates peg a 5:1 user ratio for every ERP/Design seat.
**Industrials have been the early adopters**
The automotive, aerospace & defence and capital goods industries have been early adopters of collaboration software. Some of the common characteristics these industries share include complex products with multiple components, sourced in different locations, manufactured and assembled and sold in another location. For example, in a Boeing 777 there are 3 mn parts from 500 suppliers around the world. While these customers have deployed sophisticated design and simulation tools they only began rolling out collaboration platforms in the last 5-10 years. The early adopters in these industries have been the OEMs, and over time they have enforced the adoption of similar tools by their supply chain. Cangchun Railway Corporation has reduced its new product development cycle time by 30%, improved its on-time delivery rate by 20% and shortened its R&D cycle time by 30%.
Adoption among the supply chain has accelerated in the last 3-4 years as part of a process to distribute risk, reduce cost and increase agility. For example, Faurecia has moved from 30% common development processes to 80% thereby enabling globally spread design teams to work on a single unified platform. But most importantly, it has also allowed these companies to distribute risk across partners in high value projects - for example 80% of the production of the Boeing 787 was been outsourced – the largest for any aircraft built. These are expected to bring significant benefits, including a reduction in operating costs through better planning and optimisation of supply chain, reduction in design cycle times for new vehicle/aircraft models, implementation of the "platform" approach for vehicle design whereby existing design data can be re-used etc. For example Boeing 787 production assembly time was reduced by 75% to 3 days versus previous models.
**Energy, consumer products, retail & hi-tech are new adopters**
Collaboration tools are being increasingly adopted in newer verticals like CPG (consumer packaged goods), retail & apparel, life sciences and high technology/electronics. Increased global competition, and a need to create newer differentiating products faster, and to reduce new product development costs are the key factors driving this adoption.
As the industry leaders in these verticals expand their presence across geographies to drive newer revenue streams and source materials through their partners across the world, we believe that the need for collaboration tools will increase significantly in the near to medium term. Companies are using collaboration tools for varied enterprise functions including governance, global sourcing, IP lifecycle management and live collaboration to accelerate their innovation process by knowledge and work sharing with their partners and suppliers. One of the best examples to showcase use of collaboration/product data management tools is CPG leader P&G. P&G sells most of its products for less than US$10 each to more than 3.5 bn of its consumers worldwide. Hence, strict control of costs is key for profitability. P&G is now using ENOVIA (Dassault Systemes) as its firmwide standard to streamline its processes across product lines and partners to ensure highest standards of product quality are met.
The Corporate Standards System (CSS) at P&G based on ENOVIA is used by 12,000 P&G employees in the purchasing and development teams to centrally manage more than 1.2 mn specifications for its products worldwide, resulting in a savings of close to US$250 mn (on annual spend of $1.8 bn). Collaboration systems have also enabled P&G to reduce its review cycle times to 10 days from 30 days, thereby accelerating innovation.
**Complying with regulatory requirements the tipping point?**
Until now, the implementation of collaboration systems has been contingent on a large element of the back end infrastructure being in place (e.g. ERP, design and SCM systems) first. However, with increased regulatory scrutiny, we believe adoption of collaboration tools may have reached a tipping point. This is best seen in the oil & gas industry. One of Aveva’s major customers, BP, has begun to roll out its AVEVA NET product as it seeks to gain more visibility into the safety of its processes and to improve the maintenance and operation of existing assets. The catalyst behind this roll out was the Texas Refinery incident in 2005 and the Gulf of Mexico incident in 2010. For example, in the oil & gas industry, often the build and construction of an asset is by one vendor with the operation & maintenance conducted by another. With limited cooperation between the two, design and operations data is not shared, increasing risks and liabilities for the owner (in this case BP). Given increasing scrutiny of product data and significant possible liabilities for owners, adoption of this software is now at a tipping point, irrespective of if the back-end is implemented.
**Top Collaboration plays – Dassault Systemes & Aveva**
We believe Dassault Systemes and Aveva are excellent ways to play the theme of collaboration software. For both companies, collaboration software-related product cycles (ENOVIA V6 in the case of Dassault) and (AVEVA NET in the case of Aveva) form a key part of our investment thesis. We believe AVEVA NET has the potential to double Aveva’s revenues over the next five years and offers blue-sky value at the current share price. We note that 80% of Dassault’s CAD installed base does not use a collaboration tool, providing significant scope for cross-selling. As a result, success of the ENOVIA V6 product cycle adds an incremental 3-4 percentage points to Dassault’s medium-term revenue growth rate, underpinning our above-consensus estimates.
Mohammed Moawalla
European Technology analyst
email: firstname.lastname@example.org
Goldman Sachs International
Tel: +44 (0)20 7774 1728
Can it get any more global?
Simon Schafer uncovers the size, depth and importance of the supply chains that sit behind key consumer electronic products
The continued growth of consumer electronics products, especially that of Smartphone’s and “Tablet” computers, has also required an enormous expansion of the supply chain. Apple’s Supplier 2010 progress report included first-time audits of 97 facilities, in addition to comprehensive repeat audits of 30 facilities, for a total of 288 supplier facilities audited since 2007 alone. And that is just Apple. Apple’s latest 10-Q filing suggested that the company had outstanding off-balance sheet third-party manufacturing commitments and component purchase commitments of an astounding US$1bn on components.
Apple’s supply chain
| Europe (Chip Design) | US (Chip Design/Manufacturing) | Taiwan (Chip Manufacturing / Assembly) | China Assembly | Samsung (Components) | Japan (Chip Manufacturing) |
|---------------------|-------------------------------|----------------------------------------|----------------|----------------------|---------------------------|
| ARM Holdings (Chip IP) | Broadcom (Connectivity) | TSMC | Foxconn | Samsung | Elpida (DRAM) |
| Imagination Tech (Chip IP) | Cirrus Logic (Audio) | Foxconn | Hon Hai | Toshiba (NAND) |
| Dialog Semi (Power IC) | Qualcomm (Cellular) | Hon Hai | Catcher | Pegatron | Sony (Camera Module) |
| STMicro (Gyro IC) | Texas Instruments (Screen IC) | Catcher | Pegatron | Wintek | Murata (chip assembly) |
| | Intel Infineon (Cellular) | | | | |
| | Samsung Austin | | | | |
Source: Goldman Sachs Research.
Not only is spend on component supplies and assembly and manufacturing very sizeable, it is also extremely complex given its global nature and reliance on interconnected supplier agreements: Apple may design its iPhone 4s in Cupertino, CA, but final assembly is most likely to take place in China. But necessary components may have been designed the UK (including intellectual property from ARM Holdings and Imagination Technologies), in Germany (Dialog Semi’s power management chip for instance), or in France (STMicro’s accelerometer, for example). Those in turn are likely to be produced in Taiwan (at TSMC, the world’s largest semiconductor foundry), in Japan (including Memory chips from Toshiba and Elpida), or even in the US (at Korean vendor Samsung’s Austin TX plant), before being distributed to China for final product assembly. And all to be shipped (or even flown at some expense) back to London or San Francisco.
Finding the weakest link
Recent events have also highlighted how fragile global supply chains can become, and how one weak link can cause a range of problems and repercussions for availability and functionality of products to the end-consumer, as well as the entire supply chain.
Take the role of Renesas following large-scale damage to manufacturing capability in Japan following the March 2011 earthquake and tsunami. Renesas is the world’s largest manufacturer of microcontrollers for the automotive industry, with close to 40% market share (a crucial component in car and industrial electronics). Significant damage to output capability at its Naka plant caused two quarters’ worth of output delay at some of the world’s largest car makers, given the dependence on Renesas, impacting 2011 global car production by 5% according to our autos team (20% for Japan alone).
Take what was reportedly a faulty switch in a UK-based data centre at RIM in mid-October, the maker of Blackberry mobile devices: a single component fault that can cause broad-based service outages and delays over three days in Europe, the Middle East, India and Africa, 1.5 days in Latin America and Canada, and one day in the United States. Consider last week’s flooding in central and northern Thailand which is having a potentially large impact on the production of critical components for hard disc drives used in PCs. Nidec (75% global market share in lens coating materials for HDDs) has 20%-30% of the total lens-coating production in Thailand currently suspended, and Minebea and Alphana have also suspended production. Given relatively tight inventory management in the chain (perhaps four weeks’ worth of critical stocks), this is only manageable without much of an impact if production can restart efficiently within one month. Otherwise, component availability delays could adversely affect delivery schedules of hard disc drives (and therefore PCs) for the Christmas shopping season. And will we really be able to get one of Apple’s MacBook Pros’ for Christmas, given casing supplier Catcher’s ongoing dispute with frustrated neighbouring residents? Catcher’s Suzhou factories in China received local authority notices to halt some of its production processes because of pollution, impacting sales by an estimated 20% in October (and 40% in November if production cannot be re-started by the end of October).
Can Inventory management be “real time”?
A fragmented supply chain with multiple “connecting dots” has also often led to volatile swings in overall inventory along the chain, causing sharp swings in quarterly order patterns for chip manufacturers, distributor and assemblers. The semiconductor industry in particular (given its capital intensity and pace of continued innovation leading to quick obsolescence cycles), tends to respond quickly to quarterly inventory trends, causing large swings compared to “normalised” long-term trend growth of unit demand. While the amplitude of swings has improved since the burst of the technology bubble and the inventory glut of components that followed, they remain a feature of the industry.
As long as innovation cycles remain as rapid as they have been in the past, and capital intensity dictates an environment of “specialised division of labour”, the world’s supply chains are unlikely to become any simpler soon. This is globalisation at an extreme, manufacturing mobile devices with “always on” connectivity to allow greater interconnectedness.
Simon F. Schafer
European Technology analyst
email: email@example.com
Goldman Sachs International
Tel: +44 (20) 7552-3631
A world apart for GS SUSTAIN winners
Andrew Howard, from GS SUSTAIN argues that global growth and global exposure are key drivers of sustained competitive advantage.
The GS SUSTAIN team has today published "The whole world's the stage: Focus on global leaders", a report examining the importance of a global perspective to assessing companies' fundamental strengths. In our experience, most investors are constrained by regional mandates limiting exposure to global equity markets. However, the companies in which they invest compete in increasingly global industries and assessing their abilities sustain competitive advantage relative to global, rather than local, peers is critical to identifying those leaders well placed to maintain competitive advantage, superior cash returns and ultimately to deliver outperformance.
Ongoing concerns over the economic outlook, to which markets have re-based in recent months, reflect a microcosm of a long-term structural shift in the balance of global economic power that is driving realignment in equity market sales and operating assets.
While Goldman Sachs' economists have lowered their GDP growth estimates in recent weeks, with both France and Germany now forecast to slip into mild recessions, their 2012 real global growth forecast of 3.5% is virtually equivalent to the 10-year average pace. Economic concerns notwithstanding therefore, the key conclusion is that divergence in the pace of growth in today's advanced and emerging economies is accelerating.
This economic realignment is evident in the revenues and operating assets of global equities. The share of global sales generated in, and operating assets located in, emerging markets have roughly doubled to c.30% since 2005. Companies listed in every region have become increasingly reliant on emerging market revenues; while international sales represent only c.20% of the sales generated by European and North American companies, revenues from those international markets have contributed c.60% and 30% of the total top line growth in those regions since 2005, giving structural advantages to companies with global footprints.
While rising integration of global industries is yielding opportunities for companies exposed to growth markets, competitive challenges are also growing. Competition for growth in emerging markets – from domestic and international companies – is rising as developed economies slow: on average, Chinese companies have delivered faster revenue growth in their domestic market than European or North American companies have achieved in their Chinese sales. Similarly, European, North American and Japanese companies are losing ground to growing competition from international companies in their domestic markets.
Companies with top-quartile emerging market exposure in each global sector generate on average cash returns over 20% higher than their peers, and we forecast 50% faster growth over the next three years for those companies. Exposure to growth will remain a key element of sustained profitable growth in many industries, but identifying those companies able to successfully take advantage of that growth exposure through the strength of their competitive positions relative to global peers is ultimately critical for generating long-term outperformance.
While many investors are constrained by regional mandates and benchmarks, the companies in which they invest increasingly compete in global industries and in our view should be assessed accordingly. The relationship between country benchmarks and stock performances is declining as the importance of country impacts on performance become more muted. GS SUSTAIN provides an objective framework to compare companies on their abilities to sustain industry-leading cash returns vs. global peers.
Developed market companies are increasingly reliant on international sales, emerging market companies less so % of sales generated outside of the domestic region
Source: DataStream.
Comparison of the cash returns generated by companies in regional sectors highlights sizeable disparities in profitability across regional industries. Emerging market companies typically generate higher cash returns than their developed market peers. Across developed markets, Japanese companies on average generate lower cash returns than global sector averages in every industry, US companies are stronger on average, and are typically very strong in human capital, knowledge-intensive industries, while European companies lie between the two, with typically mediocre cash returns with few areas of global strength across the region. Within Europe, Scandinavian, Swiss and UK-listed companies on average generate stronger returns than Eurozone peers.
GS SUSTAIN is Goldman Sachs' long-term investment framework, applied across each global industry. It is based on globally consistent, objective measures of performance across three key elements of corporate performance:
- Cash returns: Proprietary measure of the cash flow companies generate relative to the capital invested in their business.
- Industry positioning: Objective measures of the strategic strength of companies' business models and structural drivers of cash returns.
- Management quality: Quantifiable analysis of the effectiveness with which companies recognize, address and manage the key environmental, social and governance issues facing their industry.
Companies with demonstrable leadership on all three of these dimensions, relative to global peers, are included in the GS SUSTAIN Focus List of companies well placed to deliver long-term outperformance through sustained competitive advantage, superior cash returns and sustainable growth. Since its launch in June 2007, the GS SUSTAIN focus list has outperformed the global MSCI ACWI benchmark by 40%.
Andrew Howard
GS SUSTAIN
email: firstname.lastname@example.org
Tel: +44 (20) 7552-5987
In our six of the best section, we pull together a pot pourri of charts that we hope you find interesting. They will be different in each edition but hopefully always of note.
**Our survey says...**
Survey from our European Pension & Insurance Conference
| Asset Class | Actual Overweight | Increase in 3 months time |
|-------------------|-------------------|---------------------------|
| Corporate Bonds | 28% | 23% |
| Bonds | 24% | 7% |
| Equities | 23% | 42% |
| Cash | 16% | 6% |
| Alternatives | 6% | 18% |
| Property | 3% | 4% |
Note: More than 100 investors replied to the questions: “In terms of asset allocation, which asset class are you most overweight in?” and, “Which asset class do you intend to increase most over the next 3 months?”
Source: Goldman Sachs Global ECS Research.
**Overseas investors prefer bonds**
Foreign ownership of US stocks and bonds
| Year | US Stocks | US Corporate | US Treasury Issues |
|----------|-----------|--------------|--------------------|
| 1982 | 5.7% | 13.5% | |
| 1990 | 6.9% | 12.8% | |
| 2011 Q2* | 11.5% | 21.5% | |
| 2011 Q2* | 15.4% | 17.8% | 45.7% |
Note:* Data for 2Q2011 are preliminary.
Source: Federal Reserve Board, Goldman Sachs Global Markets Institute.
**The regulatory squeeze**
Number of pieces of legislation introduced in the EU, by category
- Consumer protection
- Consumer representation
- Health protection
- Environment
Source: Europa.
**Androids take over**
Mobile OS market share
- BlackBerry OS
- Windows Mobile/Phone
- Android OS
- Symbian
- Apple OS
Source: Gartner, Global Mobile, World Bank, Goldman Sachs Research estimates.
**People power**
Number of citizens an MP represents
| Country | Number of Citizens |
|------------|--------------------|
| Portugal | 13,043 |
| Finland | 26,500 |
| Ireland | 26,549 |
| Sweden | 26,648 |
| Norway | 28,894 |
| Denmark | 30,728 |
| Greece | 37,667 |
| UK | 43,315 |
| Belgium | 48,774 |
| Italy | 49,409 |
| Netherlands| 65,490 |
| France | 71,135 |
| Spain | 74,919 |
| Germany | 118,551 |
| Brazil | 321,044 |
| China | 448,276 |
| US | 583,925 |
| India | 1,531,646 |
Note: Calculated using unicameral or bicameral MPs total when available.
Source: International Labour Organisation, Country data.
**The size of the state**
Number of public sector employees to the general population (%)
- India
- Brazil
- Italy
- Spain
- China
- Germany
- US
- Ireland
- Belgium
- Greece
- UK
- France
- Netherlands
- Finland
- Sweden
- Denmark
- Norway
Source: International Labor Organization, UN.
Four stocks with global flows
A.P. Moeller-Maersk
**Key data**
| | Current |
|----------------------|---------------|
| Price (Dkr) | 35,000.00 |
| 12 month price target (Dkr) | 50,000.00 |
| Upside/(downside) (%) | 43 |
| Market cap (Dkr mn) | 153,846.0 |
| Enterprise value (Dkr mn) | 364,469.8 |
| | 12/10 | 12/11E | 12/12E | 12/13E |
|----------------------|---------------|---------------|---------------|---------------|
| Revenue (Dkr mn) | 315,396.0 | 316,190.8 | 332,219.1 | 349,821.1 |
| EBIT (Dkr mn) | 55,396.0 | 50,632.2 | 58,238.9 | 61,478.6 |
| EPS (Dkr) | 5,155.16 | 3,123.44 | 4,909.74 | 6,547.30 |
| EV/EBITDA (X) | 4.6 | 4.6 | 4.0 | 3.8 |
| P/E (X) | 9.0 | 11.2 | 7.1 | 5.3 |
| Dividend yield (%) | 0.7 | 2.9 | 2.9 | 2.9 |
| FCF yield (%) | 13.9 | 0.8 | 11.1 | 11.6 |
| CROCI (%) | 11.7 | 8.3 | 9.1 | 9.9 |
| CROCI/WACC (X) | -- | -- | -- | -- |
| EV/GCI (X) | 0.7 | 0.6 | 0.5 | 0.5 |
The great Dane is back
AP Moeller-Maersk stands out as one of the best ways to play the global trade theme: more than 50% of its net income is from global trade derivatives businesses. The company owns Maersk Line, the largest container line in the world, APM Terminals (with interests in 60 ports, of which 56% are located in emerging markets), and Maersk Tankers, a large fleet of chemicals, crude and products tankers.
We have a Conviction Buy on the stock: after two quarters of sub-breakeven freight rates on main lanes on the containers side, we expect the industry to begin a self-healing process through supply adjustments, as in 1Q09. Then, supply declined by c.20%, lifting rates well above breakeven levels months before demand improved.
Supply adjustments are a key catalyst: (1) The number of lay-ups has been rising for the past couple of weeks and now stands at 2.3% of the fleet (vs. 12% in 2009). We expect this number rise further, driven by waning interest for re-lets and a depressed spot market (forcing liners with weaker balance sheets to idle their fleets). (2) Cascading of smaller ships from main lanes to secondary lanes. (3) More order delays/cancellations, as owners struggle to finance vessel orders placed at the peak of the cycle when asset values were 30% above current levels. In the Oil and Gas segment, we expect news on the commercial viability of the Chissonga (Angola) and Itaipu/Wahoo fields (Brazil) in 4Q11.
Maersk trades close to levels associated with its trough earnings and at book value multiples (in line with 1Q09) despite a higher oil price and stronger demand in containers. Our 12-month SOTP-based price target is Dkr50,000. The key risks to our price target are a lower oil price, a narrowing crack spread and an absence of supply adjustments in containers and trade tariffs.
Analyst details: Eduard Baldini, Tel: +44 (20) 7774-5715; email: email@example.com – Goldman Sachs International.
Prices as the close of October 19, 2011.
Aveva
**Key data**
| | Current |
|----------------------|---------------|
| Price (p) | 1,430 |
| 12 month price target (p) | 2,550 |
| Upside/(downside) (%) | 78 |
| Market cap (£ mn) | 975.2 |
| Enterprise value (£ mn) | 777.3 |
| | 3/11 | 3/12E | 3/13E | 3/14E |
|----------------------|---------------|---------------|---------------|---------------|
| Revenue (£ mn) | 174.0 | 207.2 | 258.1 | 318.3 |
| EBIT (£ mn) | 50.7 | 64.9 | 86.2 | 113.3 |
| EPS (p) | 49.00 | 69.20 | 92.21 | 120.89 |
| EV/EBITDA (X) | 14.7 | 11.2 | 8.0 | 5.7 |
| P/E (X) | 29.0 | 20.7 | 15.5 | 11.8 |
| Dividend yield (%) | 1.3 | 1.9 | 2.6 | 3.4 |
| FCF yield (%) | NM | NM | NM | NM |
| CROCI (%) | 42.5 | 77.6 | 83.5 | 98.3 |
| CROCI/WACC (X) | 4.4 | 8.0 | 8.6 | 10.1 |
| EV/GCI (X) | 9.6 | 10.0 | 8.6 | 7.1 |
Emerging market leader with best-in-class industry positioning
Aveva’s current valuation (13x 2012E P/E ex-cash) is at a c.10% discount to the PLM peer group, despite better structural revenue growth, operating margins and cash returns. Our 12-month price target of 2,550p is based on a 70% weighting to our core P/E-based valuation of 2,350p (26x FY12E PF EPS) and a 30% weighting to an M&A-based valuation of 3,030p. Aveva is a premier strategic asset in European software in our view and may appeal to many potential acquirers including PLM peers (Dassault Systems, Autodesk) and industrial vendors (Siemens, ABB).
We are significantly ahead of consensus, reflecting our positive view on Aveva’s best-in-class industry positioning and structural growth potential. In the near term, we expect multiple growth drivers, including adoption of design solutions across multiple emerging markets (Brazil, China, Russia, Middle East) and increased adoption of AVEVA NET in the Oil & Gas industry. In particular, we expect Aveva NET to become an industry standard in the product lifecycle segment in the medium term. We expect Aveva to deliver a c.22% revenue CAGR and a c.31% EPS CAGR over FY11-14E. We are 7%, 20% and 32% ahead of Bloomberg consensus for FY11, FY12, FY13 revenues respectively.
Aveva provides exposure to global themes, economic realignment and oil offshore expansion. Aveva’s dominant position in the attractive 3D plant design software market and high BRICs/emerging market exposure (c.65% of revenues) underpins its strong industry positioning. We expect Aveva to grow faster than the market’s 9% CAGR over the next few years. We believe Aveva NET is an important product differentiator for the company, and that it has the potential to double the group’s sales in the coming years, owing to the product’s unique positioning and regulatory demand. We expect Aveva NET to enable Aveva to gain incremental market share vs. its competitors, and capture a sizeable market opportunity. The company’s high recurring revenue model (c.65% of group sales) and predominantly organic growth enable it to generate the best returns in the sector. A high percentage of recurring revenue additionally provides strong top-line visibility. Aveva is on the Conviction Buy List, the UK Relative Value List, is a GS SUSTAIN Emerging Industry leader and is on the DOR Focus List. Risks to our price target include economic weakness in EM and exposure to cyclical end-market capex, particularly in marine technology, adoption rates, access to financing for Aveva’s customers, acquisitions and revenue concentration.
Analyst details: Mo Moawalla, Tel: +44 (20) 7774-1726; email: firstname.lastname@example.org – Goldman Sachs International
Price as the close of October 19, 2011.
**Intertek**
**Key data**
| | Current |
|----------------------|---------|
| Price (p) | 1,955 |
| 12 month price target (p) | 2,984 |
| Upside/(downside) (%) | 53 |
| Market cap (£ mn) | 3,114.3 |
| Enterprise value (£ mn) | 3,756.9 |
| | 12/10 | 12/11E | 12/12E | 12/13E |
|----------------------|---------|---------|---------|---------|
| Revenue (£ mn) | 1,374.2 | 1,705.9 | 1,973.6 | 2,170.9 |
| EBIT (£ mn) | 214.6 | 263.4 | 317.8 | 359.6 |
| EPS (p) | 90.96 | 105.06 | 126.51 | 145.32 |
| EV/EBITDA (X) | 9.7 | 11.1 | 8.4 | 7.4 |
| P/E (X) | 17.3 | 18.6 | 15.5 | 13.5 |
| Dividend yield (%) | 1.8 | 1.7 | 2.1 | 2.4 |
| FCF yield (%) | 5.1 | 4.7 | 6.3 | 7.0 |
| CROCI (%) | 21.0 | 18.7 | 16.7 | 18.9 |
| CROCI/WACC (X) | -- | -- | -- | -- |
| EV/GCI (X) | 2.3 | 2.1 | 1.9 | 1.7 |
**China risks overplayed, emerging market opportunity remains**: We believe China risks are overplayed for two main reasons: (1) The majority of China exposure is in consumer testing, where c.95% of samples tested are for products destined for western end-markets, and therefore not exposed to a potential GDP growth slowdown in China; (2) The sharp increase in Chinese wage inflation impacted Intertek’s consumer margin in 1H 2011, not because it inflated its own cost base, but because it forced its customers to find alternative low-cost manufacturing regions. This sudden shift reduced near-term utilisation and required a shift in lab capacity to these new geographies. In a normal high-inflation environment, ITRK is able to offset these pressures by gradually shifting capacity, and by filling existing capacity with higher-value testing as seen in 1H11. Longer term, we view China as an opportunity, with the growing middle class demanding increased consumer protection, and regulations which should drive further outsourced testing of products destined for the domestic market. **Intertek is a Conviction Buy**. *We have a 12-month price target of 2,984p*. ITRK is in the top quartile of business services stocks on our GS SUSTAIN-based framework analysis of growth, sustainability and returns. We value ITRK at 12.0x 2013E EV/EBITDA, discounted to present value. **Key risks to our price target** include sharp shifts in customer locations, lower capex from major energy and mining customers and a further slowdown in global trade (which accounts for c.30% of ITRK’s growth).
*Analyst details: John Woodman, Tel: +44(20)7552-3005; email: email@example.com – Goldman Sachs International*
---
**Visa Inc.**
**Key data**
| | Current |
|----------------------|---------|
| Price ($) | 90.08 |
| 12 month price target ($) | 106.00 |
| Market cap ($ mn) | 64,317.1|
| | 9/10 | 9/11E | 9/12E | 9/13E |
|----------------------|---------|--------|--------|--------|
| Revenue ($ mn) | 7,892.5 | 9,180.2| 9,891.2| 10,924.1|
| Net income ($ mn) | 2,859.1 | 3,544.1| 3,971.6| 4,495.3 |
| EPS ($) | 3.87 | 5.06 | 5.75 | 6.60 |
| P/E (X) | 23.2 | 18.0 | 17.7 | 13.6 |
| P/B (X) | 2.2 | 2.3 | 2.1 | 1.9 |
| ROA (%) | NM | NM | NM | NM |
| ROE (%) | NM | NM | NM | NM |
| Equity/assets (tang) (%) | 19.9 | 29.7 | 42.8 | 53.1 |
| Pretax margin (%) | 57.2 | 60.9 | 63.2 | 64.8 |
| | 6/11 | 9/11E | 12/11E | 3/12E |
|----------------------|---------|--------|--------|--------|
| EPS ($) | 1.26 | 1.28 | 1.43 | 1.42 |
Over the long term, we expect emerging payments to become an increasingly important driver given V’s dominant role in electronic payments. Simply put, any emerging payment technology will need to ride on existing current payment rails (including V, MA, AXP and DFS) in order to scale, which will only add incremental volume. **Robust FCF and margin profile makes model defensive**: We believe V’s industry-leading ROC (40%+ in FY12E), robust annual FCF (US$2 bn+), solid margin profile (60%+) and capital allocation stewardship will buffer EPS in a tepid economic environment and support the shares. **Our 12-month US$106 price target implies 17% upside potential** and is based on a weighted average model incorporating our sector-relative Investment Framework, CY12E P/E, and CY12E EV/EBITDA (implying a CY12E P/E of 18X). We expect to see continued multiple expansion as investors gradually shift their focus to fundamentals and away from regulatory uncertainty. We remain confident that V will deploy numerous mitigation strategies to protect its dominant share of the US debit market (+50%). In particular, we expect V’s recently announced pricing changes, increased focus on merchant incentives and product/technology innovation (the forthcoming V mobile wallet and the push for chip-based technology) to limit any market share loss in US debit. **Key risks to our price target** include lower volumes, slower cross-border growth, and new entrants.
*Analyst details: Julio C. Quinteros Jr., Tel: +001 (415)249-7488; email: firstname.lastname@example.org – Goldman Sachs & Co.*
Price as the close of October 19, 2011.
Investment list performance
The charts below show the performance of our four key investment lists. Our Conviction List represents our sector analysts’ highest conviction ideas (typically making up 10% of their coverage). We show its performance versus our entire coverage and against the MSCI Europe.
The Directors of Research Focus List comprises the “best of the best” Conviction ideas as selected by our Directors of Research. It represents their pick of our strongest Conviction calls and also contains GS SUSTAIN Focus List names.
The GS SUSTAIN Focus List brings together the leaders identified in each global sector, based on objective, quantifiable measures of returns, industry positioning and management quality. Since its launch in June 2007, the GS SUSTAIN Focus List has outperformed the MSCI All Country World index by 37%.
The UK Relative Value List is constructed using our UK conviction call ideas (ex small cap oil &P). Conviction Buys and Sells are matched against one another and the list looks to create an absolute return.
Conviction List performance
GS SUSTAIN Focus List performance
Directors of Research Focus List performance
UK Relative Value List performance
Source: Goldman Sachs Research.
Note: Results presented should not and cannot be viewed as an indicator of future performance. Performance is calculated on an equally weighted basis relative to the MSCI World index (market-cap-weighted total return series in US$). Performance calculations assume closing levels with no bid/ask spread and no commission.
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I, Jeffrey Currie, hereby certify that all of the views expressed in this report accurately reflect my personal views, which have not been influenced by considerations of the firm’s business or client relationships.
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Investment Profile
The Goldman Sachs Investment Profile provides investment context for a security by comparing key attributes of that security to its peer group and market. The four key attributes depicted are: growth, returns, multiple and volatility. Growth, returns and multiple are indexed based on composites of several methodologies to determine the stock's percentile ranking within the region's coverage universe.
The precise calculation of each metric may vary depending on the fiscal year, industry and region but the standard approach is as follows:
**Growth** is a composite of next year’s estimate over current year’s estimate, e.g. EPS, EBITDA, Revenue. **Return** is a year one prospective aggregate of various return on capital measures, e.g. CROCI, ROACE, and ROE. **Multiple** is a composite of one-year forward valuation ratios, e.g. P/E, dividend yield, EV/FCF, EV/EBITDA, EV/DACF, Price/Book. **Volatility** is measured as trailing twelve-month volatility adjusted for dividends.
Quantum
Quantum is Goldman Sachs' proprietary database providing access to detailed financial statement histories, forecasts and ratios. It can be used for in-depth analysis of a single company, or to make comparisons between companies in different sectors and markets.
Disclosures
**Coverage group(s) of stocks by primary analyst(s)**
Edouard Baldini: Europe-Transport, Europe-Travel & Leisure. Mohammed Moawalla: Europe-Software. Julio C. Quinteros Jr.: America-ATM/POS and Self-Service, America-IT Consulting and Outsourcing, America-Transaction Processors. John Woodman: Europe-Business Services.
America-ATM/POS and Self-Service: Diebold, Inc., NCR Corp., VeriFone Systems, Inc..
America-IT Consulting and Outsourcing: Accenture Plc, Amdocs Limited, CGI Group Inc., CGI Group Inc. (US), Cognizant Technology Solutions, Computer Sciences Corp., Convergys Corporation, CSG Systems International, Inc., ExlService Holdings, Inc., Fidelity National Information Svcs., Fiserv, Inc., Genpact Ltd., Lender Processing Services, Inc., Motricity, Inc., NeuStar, Inc., Pitney Bowes Inc., Sapient, Synchronoss Technologies, Inc., Towers Watson & Co., WNS (Holdings) Ltd..
America-Transaction Processors: Automatic Data Processing Inc., Equifax, Inc., FleetCor Technologies, Inc., Global Payments Inc., Green Dot Corp., Heartland Payment Systems, Inc., Higher One Holdings, Inc., Mastercard Inc., NetSpend Holdings, Inc., Paychex, Inc., Solera Holdings, Inc., Total System Services, Inc., Visa Inc., Western Union Co., Wright Express Corp..
Europe-Business Services: Adecco, Aggreko, Amadeus IT Holding SA, Austrian Post, Babcock International, Berendsen Plc, Brenntag AG, Bunzl, Bureau Veritas, Capita Group, Deutsche Post, Electrocomponents, Eurofins Scientific, Experian, G4S Plc, Hays plc, Intertek Group, Michael Page International, PostNL, Premier Farnell, Randstad Holdings, Regus Group PLC, Rentokil Initial, Rexel, Robert Walters, Securitas AB, Serco, SGS, STthree, TNT Express N.V., Travis Perkins, Wolsiefer.
Europe-Software: Autonomy, Aveva, Blinkx, Cegid, Dassault Systemes, Exact Holding, Fidessa, IFS, Micro Focus, Nemetschek, Opera Software, Orc Software, Sage Group, SAP (ADR), SAP (Ordinary Share), Software AG, Tekla, Temenos, Unit 4.
Europe-Transport: Aeroports de Paris, Brisa, DSV, FirstGroup, Flughafen Wien, Flughafen Zurich, Fraport AG, Frontline Ltd, Go-ahead, Golar LNG Ltd, Golden Ocean Group Ltd, Groupe Eurotunnel SA, National Express, Stagecoach.
Europe-Travel & Leisure: A.P. Moeller-Maersk, Accor, Aer Lingus, Air France-KLM, Compass Group, Easyjet, Edenred, Enterprise Inns plc, Finnair, Greene King, InterContinental Hotels Group PLC, International Consolidated Airlines Group, Kuehne & Nagel, Kuoni Reisen Holding, Ladbrokes, Lufthansa, Marston’s Plc, Millennium & Copthorne Hotels, Mitchells & Butlers Plc, Norwegian Air Shuttle, Panalpina, Punch Taverns plc, Rank Group, Ryanair, SAS Sverige, Sodexo, Spirit Pub Company PLC, Thomas Cook Group Plc, TUI AG, TUI Travel Plc, VTG, Wetherspoon (JD), Whitbread, William Hill.
**Company-specific regulatory disclosures**
The following disclosures relate to relationships between The Goldman Sachs Group, Inc. (with its affiliates, "Goldman Sachs") and companies covered by the Global Investment Research Division of Goldman Sachs and referred to in this research.
Goldman Sachs beneficially owned 1% or more of common equity (excluding positions managed by affiliates and business units not required to be aggregated under US securities law) as of the month end preceding this report: Aveva
Goldman Sachs expects to receive or intends to seek compensation for investment banking services in the next 3 months: A.P. Moeller-Maersk, Aveva, Intertek Group and Visa Inc.
Goldman Sachs has received compensation for non-investment banking services during the past 12 months: Visa Inc.
Goldman Sachs had an investment banking services client relationship during the past 12 months with: Aveva, Intertek Group and Visa Inc.
Goldman Sachs had a non-investment banking securities-related services client relationship during the past 12 months with: A.P. Moeller-Maersk and Visa Inc.
Goldman Sachs had a non-securities services client relationship during the past 12 months with: A.P. Moeller-Maersk and Visa Inc.
Goldman Sachs makes a market in the securities or derivatives thereof: Intertek Group and Visa Inc.
Goldman Sachs is a specialist in the relevant securities and will at any given time have an inventory position, "long" or "short," and may be on the opposite side of orders executed on the relevant exchange: Visa Inc.
Goldman Sachs International acts as corporate broker to: Aveva and Intertek Group
**Distribution of ratings/investment banking relationships**
Goldman Sachs Investment Research global coverage universe
| Rating distribution | Investment Banking Relationships |
|---------------------|---------------------------------|
| Buy | Hold | Sell | Buy | Hold | Sell |
| Global | 31% | 55% | 14% | 50% | 43% | 36% |
As of October 1, 2011, Goldman Sachs Global Investment Research had investment ratings on 3,198 equity securities. Goldman Sachs assigns stocks as Buys and Sells on various regional Investment Lists; stocks not so assigned are deemed Neutral. Such assignments equate to Buy, Hold and Sell for the purposes of the above disclosure required by NASD/NYSE rules. See 'Ratings, Coverage groups and views and related definitions' below.
**Price target and rating history chart(s)**
Aveva (AVVL)
Goldman Sachs rating and stock price target history
Source: Goldman Sachs Investment Research for ratings and price targets; FactSet closing prices as of 9/30/2011.
- Rating
- Price target
- Price target at removal
- FTSE World Europe (GBP)
The price targets shown should be considered in the context of all prior published Goldman Sachs research, which may or may not have included price targets, as well as developments relating to the company, its industry and financial markets.
Intertek Group (ITRK.L)
Goldman Sachs rating and stock price target history
Source: Goldman Sachs Investment Research for ratings and price targets; FactSet closing prices as of 9/30/2011.
- Rating
- Price target
- Price target at removal
- FTSE World Europe (GBP)
The price targets shown should be considered in the context of all prior published Goldman Sachs research, which may or may not have included price targets, as well as developments relating to the company, its industry and financial markets.
A.P. Moeller-Maersk (MABRSKb.CO)
Goldman Sachs rating and stock price target history
Source: Goldman Sachs Investment Research for ratings and price targets; FactSet closing prices as of 9/30/2011.
- Rating
- Price target
- Price target at removal
- FTSE World Europe (GBP)
The price targets shown should be considered in the context of all prior published Goldman Sachs research, which may or may not have included price targets, as well as developments relating to the company, its industry and financial markets.
Visa Inc. (V)
Goldman Sachs rating and stock price target history
Source: Goldman Sachs Investment Research for ratings and price targets; FactSet closing prices as of 9/30/2011.
- Rating
- Price target
- Price target at removal
- S&P 500
The price targets shown should be considered in the context of all prior published Goldman Sachs research, which may or may not have included price targets, as well as developments relating to the company, its industry and financial markets.
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Background and Need:
Energy efficiency is the most cost-effective strategy for reducing heating and cooling bills. Buildings account for roughly two-thirds of Vermont’s total energy needs and one-third of emissions. Efficiency saves consumers money while making homes and businesses more comfortable and easier to maintain. Energy efficiency is providing, and will continue to provide, regional cost savings and reliability benefits.
Another one-third of energy consumption in Vermont comes from transportation. For this reason, location is a crucial energy efficiency consideration. Housing in villages and towns provide a walkable lifestyle that reduces emissions because energy is saved when cars are driven fewer miles. Homes in compact settlement patterns in walking distance to daily needs is an old way of living that can achieve energy efficiency while providing more affordable housing options.
Getting Started:
Establish a Town Energy Committee.
All-volunteer committees help towns to focus their efficiency efforts. They work with municipal staff and officials, businesses and residents in their communities to implement energy-savings and clean energy projects. They help to weatherize town buildings, install solar on schools and homes, and advance transportation options.
Appoint a Town Energy Coordinator.
Vermont law enables municipalities to appoint town energy coordinators to advise select boards on energy issues. In his first 7 months on the job, Hartford’s Energy Coordinator saved the town enough money to cover his first year’s salary. (Source VT Energy Dashboard).
Follow guidance in your Municipal Plan.
Energy Use and Efficiency is addressed in a Town’s Municipal Plan. This section of the plan analyzes energy use, identifies efficiency opportunities, including land use and transportation strategies, and potential renewal energy resources.
Use the municipal zoning bylaw to implement energy efficiency based the community’s desires and needs.
Efficiency is ‘built-in’ traditional development patterns like the Village of Hyde Park’s
Energy Efficiency Delivers Community Benefits
- Avoided infrastructure costs
- reduced need for services
- healthier residents
- lower energy demand and reduced emissions
Using the Zoning Bylaw to Shrink the Community’s Energy Footprint:
Reducing distances people must drive lowers emissions and can make housing more affordable. Zoning regulations that support compact, walkable development may include standards for maximum lot sizes, shared driveways, parking behind buildings and space for pedestrian infrastructure in front of buildings, minimum building heights, front doors and windows that face the street, and requirements that new development connect to existing development and to planned pedestrian and bike networks.
Create and reinforce compact walkable development patterns. Fostering walkable downtowns, village centers and neighborhoods can revitalize existing communities, while preventing the development and fragmentation of farm and forest land and protecting natural resources. Vermont’s historic centers provide walkable access to schools, libraries, recreational facilities, stores, and restaurants.
Encourage compact efficient development on village and town lots. A compact 2-story house built to standard material dimensions requires a smaller foundation and is more cost-effective to build and to heat and cool. Duplexes and triplexes that share walls are even more efficient and cost-effective to construct and lowering the cost new housing makes it more affordable.
Address historic preservation. Include historic preservation and adaptive reuse provisions to allow for economically viable uses of historic structures and avoid their demolition. Vermont’s historic structures define the state’s character but also represent a wealth of ‘embodied energy’. Modern building materials, especially aluminum, vinyl and plastic, are much more energy consumptive than traditional materials such as masonry and wood. The embodied energy in existing historic structures has been spent, so replacing them with new buildings – especially new buildings constructed with modern materials – represents wasted energy.
Vermont’s historic buildings largely define the state’s traditional, and more efficient, settlement pattern. This greater efficiency is due to the compact nature, walkability, and ease for service by transit, in contrast to more contemporary, lower-density development patterns.
Strengthen agricultural and forest industries, minimize conflicts of development with these industries, and plan new development for efficient delivery of costly public services.
The flip-side of ‘smart growth’ is keeping the state’s rural landscape intact. Maintaining large tracts of healthy forests and productive farmland provides the contrast with the built environment that defines Vermont’s traditional settlement pattern and ensures long term access to local food supplies and forest products. The importance of these two land-based resources from an energy standpoint is an important means of addressing Vermont’s energy goals.
Include Planned Unit Development (PUD) or conservation subdivision standards to facilitate clustering, limit the amount of infrastructure and maintain a specified percentage of the property as open space. (50-80% is not uncommon in Vermont). Require a landscape design and maintenance plan to:
1. incorporate the use of deciduous trees on southern sides of buildings to avoid interference with solar access;
2. use low-impact-development (LID) stormwater management practices; and,
3. minimize irrigation, mechanized maintenance, and the application of chemical treatment.
Pursue Electrical and Thermal Efficiency at public buildings, properties and in Town-owned rights-of-ways (ROWs). Municipalities that lack zoning can implement electrical and thermal enhancements in publicly owned buildings and properties. The significant energy and cost savings this provides can demonstrate and model the benefits of these technologies and strategies. This may encourage political support for their more widespread use through adoption of an ordinance or zoning. Municipalities can:
- Conduct audits of building energy use, publicize findings and pay-back to implement the scope of recommendations;
- Convert streetlights to LEDs for energy savings, cost savings, improved lighting, and less light pollution;
- Install a public EV charging station at a municipally owned building;
- Install bike racks at public properties such as schools, libraries, Town Offices and gathering spaces like Town Commons;
- Plant street trees in public ROWs in Villages and Towns for shade and stormwater mitigation, more pleasant pedestrian conditions, and traffic calming (in State ROWs requires a Memorandum of Municipal Agreement with VTRANS).
Use the Zoning bylaw to address transportation efficiency. Standards can include:
- Installing public EV charging stations;
- requiring bicycle racks or lockers;
- ensuring connections to existing or planned sidewalks, bicycle lanes and paths;
- requiring transit shelters where appropriate.
Use the Zoning bylaw to provide energy-related site development standards. Since a significant portion of the state’s total energy demand comes from buildings, a zoning bylaw that incentivizes development to meet energy efficiency standards is a great step in reducing our total energy and climate footprint. State statute (24 V.S.A. § 3101) allows towns to create such codes and regulations. It is important to note that it is often easier to pass policies that incentivize energy efficiency, rather than policies that require it. These can include:
- Building location and orientation standards to maximize passive solar;
- Building fenestration (i.e., window and door openings) standards to maximize passive solar;
- Site standards to consider whether the developed site will be configured to accommodate renewable energy facilities (e.g., solar photovoltaic panels) in the future;
- Lighting standards to avoid overlighting and require the use of LEDs or other efficient fixtures.
Sustainable Design and Development Site Performance Standards: Passive Solar and Lighting Systems
- In passive systems, collection and storage of solar energy is built into the structure (no pumps or moving parts).
- Suitable for all locations, but easiest with new construction and in rural areas. (In village settings massing of existing buildings may limit solar access to neighboring properties, particularly in winter, to properties immediately to the north).
- Solar energy can also provide natural daylighting. Careful design and placement of windows and clerestory can greatly reduce the energy required for daytime lighting.
Buildings oriented close to true South (within 30 degrees) can use windows on the south wall, sunrooms, thermal mass (such as thick wall of concrete, brick, quarry tile, or water) that conducts heat slowly to the interior space, and adequate insulation to capture a building’s space heat.
Sustainable Design and Development Site Performance Standards: Active Solar Systems employs equipment such as collector panels, pumps, and fans. Suitable in all locations. Use zoning to maximize its effectiveness by encouraging/requiring:
- Massing of buildings that is considerate of solar access to neighboring properties, particularly allowing sun during winter to properties immediately to the north;
- Buildings of a size and orientation to minimize blocking of sunlight on public spaces such as sidewalks;
- Orient windows to make the best use of passive solar heating and provide cross ventilation.
- Encourage use of primary roof planes that face solar south to allow for installation or retrofit with solar panels.
- In villages and neighborhoods encourage development and redevelopment that consider how rooflines fit with the solar orientation of streets. Gable roofs and shorter buildings can be more appropriate on the south sides of streets while gable end roofs and taller buildings can be more suited to the north side.
- On retrofits, encourage solar systems to be integrated with a water-heating system already in place, so that the existing system can provide backup heating when there is not enough solar energy.
Sustainable Design and Development Site Performance Standards: Geothermal
Geothermal energy is appropriate for some sites. This approach uses heat pumps that take advantage of the relatively constant temperature below the frost line of 45-55 °F through use of water from a well or that has circulated through underground pipes. In winter, the heat pump “extracts” and upgrades heat from the water circulated by the pump and distributed throughout the building. The resulting cooled water is returned to the earth to be re-warmed. The system is reversed in the summer. When a single well can be drilled deep enough for sufficient heat exchange, this well commonly also serves as the domestic water well. Geothermal can work for larger commercial projects. However, multiple wells may be needed.
Geothermal Energy Planning Considerations:
- In some instances, installing an open loop system, the most common and efficient type of geothermal, can be as simple as drilling a new well or deepening an existing well.
- More typically, a geothermal system will be more costly to install than a conventional heating and cooling system. If dual use of the well for domestic water is feasible this difference is greatly reduced.
- The additional costs are typically paid back in 5-10 years in energy savings. System life is estimated at 25 years for the inside components and 50+ years for the well or ground loop.
- Ground source heat pumps greatly contribute to high efficiency building design, but they may be best suited to new-build projects.
Use the Zoning bylaw to provide incentives for renewable energy generation. Provide incentives, such as increased density, in exchange for on-site generation of renewable energy or compliance with certifiable energy efficiency standards (e.g., LEED).
Source: Form-based Overlay District Westford Land Use and Development Regulations
Source: Smartcode Module: Renewal Resources – Solar Energy https://transect.org/modules.html
Right Place, Right Technology.
Zoning according to a rural to urban transect provides a unified approach for integrating renewables in predictable and context-appropriate/sensitive ways in a municipality. Each zone along the transect has a distinct character, and component standards reinforce each other to intensify this character.
The table (above right) shows opportunities for the placement of types of solar-powered devices within the transect. Solar access should be protected in the T2 and T3 zones; this may be more difficult in T4-T5 density. At the community scale, solar orientation should be considered when planning a hamlet or village, so that each lot receives optimum exposure. If this is not feasible, the code may require a percentage of lots, especially in the T3 zone, to be oriented for solar energy. A solar dish engine system utilizes collectors tracking the sun on two axes, while concentrating the energy at the focal point of a separate dish.
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Georgia’s 2020 CLEAN 13
- Southwings
- Parsley’s Catering
- Yonah Mountain Vineyard
- Emory University
- Live Thrive Atlanta
- Chattahoochee Riverlands
- YKK AP
- Fall-Line Alliance for Clean Energy
- Sen. Freddie Powell Sims
- Georgia Farmers
- Golden Triangle RC&D Council
- Okefenokee Swamp Park
- Sen. William Ligon
Georgia Water Coalition’s Clean 13 Highlights Public and Private Efforts to Protect Georgia’s Water
For Georgia Water Coalition’s more than 260 member organizations half the battle of protecting Georgia’s water is helping Georgians understand and appreciate the state’s water resources.
For some organizations, that means taking a group kayaking on a local river; for others it means guiding school children on hikes along a stream; and for still others, it means getting local civic groups involved in a creek cleanup.
Coalition members understand that for people to care about protecting the state’s rivers, lakes, streams—along with the state’s groundwater resources and coastal areas—they must experience them firsthand.
Or as famed natural historian David Attenborough has noted: “No one will protect what they don’t care about and no one will care about what they have never experienced.”
Within the stories of each of the individuals, organizations and businesses highlighted in this year’s Clean 13 report runs that underlying theme: the need to help people enjoy, appreciate and take action to protect Georgia’s water.
From a bold plan to create a 120-mile multi-modal trail along the Chattahoochee River to introduce the river to a new generation of stewards to workshops for county road maintenance workers in Southwest Georgia aimed at addressing sedimentation from the region’s dirt roads, the entities included in this report are doing just that.
In the state’s capital, Live Thrive Atlanta’s Center for Hard to Recycle Material (CHaRM) offers residents a place to recycle everything from old paints to obsolete electronics. Since 2015, CHaRM has diverted more than 50 million pounds of hazardous chemicals and waste from landfills. CHaRM has helped Atlantans understand that recycling benefits urban streams and our rivers.
In Dublin, YKK AP, makers of aluminum windows, doors and architectural facades, is doing the same at the industrial level. While recycling all of its aluminum waste on site, YKK AP also recovers byproducts of its manufacturing process that are
repurposed on site or sold off-site for other uses. Its energy efficiency measures in its 1.2-million square-feet facility serve as an example of energy savings that can be realized by community-wide adoption of something as simple as LED lighting.
In North Georgia, Yonah Mountain Vineyards, one of Georgia’s growing number of wineries, is likewise setting a clean energy example with the installation in 2019 of a 360-panel solar array that powers much of the vineyard’s operation. The sommeliers of solar have also installed a 14-station Tesla Destination charging station for electric cars.
At Emory University, one of the country’s leading research universities, the WaterHub, a first of its kind facility in the U.S., is showing students—and even international leaders—the benefits of small-scale, onsite water treatment facilities. The WaterHub, which looks like a large greenhouse, treats up to 400,000 gallons of sewage daily and provides 40 percent of the campus’s daily water needs.
Across town in Marietta, Parsley’s Catering, a 40-year-old family-owned business, has adopted green initiatives and encourages others in the food service sector to follow their lead. One of the few Atlanta area food providers certified by the Green Restaurant Association, Parsley’s has embraced solar power and water-saving plumbing, converted to compostable and biodegradable plates and utensils and connected with local organic farms to provide its meats and produce.
In Southwest Georgia, the Golden Triangle Resource Conservation and Development Council, among many other initiatives, educates local county road crews on best practices for maintaining the region’s many dirt roads—an effort that keeps dirt out of streams and protects imperiled aquatic wildlife. The Council is also producing a series of educational videos promoting tourism along the Flint River.
Across state from the Flint, the private, non-profit, 74-year-old Okefenokee Swamp Park, is also embarking on a tourism marketing effort with other local swamp attractions to bring more people to the swamp and convert more of them to swamp lovers. The effort couldn’t be more timely as the swamp is now faced with new outside threats and needs all the defenders it can get.
Similarly, the Chattahoochee RiverLands project aims to make the Chattahoochee more accessible to communities across metro Atlanta. The proposed 120-mile multi-modal trail running from Buford Dam in Gwinnett County to Chattahoochee Bend State Park in Coweta County aims to bring citizens to the region’s “waterfront” and enlist a new generation of river stewards.
Flying above all this action on the ground is SouthWings, an Asheville, North Carolina-based non-profit that provides free flights to environmental organizations in Georgia. In 2019, SouthWings’ volunteer pilots flew 29 missions totaling
some 87 hours of flight time. The flights served to educate decision makers and the public about issues impacting our water, ranging from coal ash disposal to oil spills along the coast.
Finally, in this year’s Clean 13 report, the Georgia Water Coalition celebrates individuals and one organization that helped secure specific victories for Georgia’s water.
The Fall-Line Alliance for Clean Energy (FACE), based in Washington County, celebrated the end of a decade-long effort to stop a coal-fired power plant planned near Sandersville. Earlier this year, state regulators refused to extend permits for the project. Plant Washington was the only coal-fired power plant still currently under consideration in the U.S. Since 2010, more than 170 proposed coal-fired power plants have been cancelled across the country.
In the state legislature, Sen. William Ligon (R-White Oak) introduced and secured passage of SB 123, a measure that closes a loophole in Georgia’s coal ash disposal regulations. The new law will discourage out-of-state coal ash producers from dumping their waste in Georgia landfills. The retiring senator also leaves a legacy of protecting the Georgia coast and coastal rivers.
On the other side of the aisle, Sen. Freddie Powell Sims (D-Dawson) used her influence as the only Democratic senator representing a mostly rural district, to secure votes of the senate’s full Democratic caucus in the heated battle over HB 545, a measure that would have harmed rural constituents by inviting industrial-scale animal feeding operations to rural communities.
Influencing Sen. Sims to take a stand against the bill was a vocal group of farmers, including many from her district. While lobbyists from the agri-business sector wield much influence in Sims’ Southwest Georgia district, their endorsement of HB 545 was no match for these citizen activists, most of whom were traditionally, politically-right-leaning farmers. Forming an unlikely coalition with senate Democrats, they played an important role in defeating HB 545.
Together, the efforts of these “Clean 13” are adding up to cleaner rivers, stronger communities and a more sustainable future for Georgia.
The Georgia Water Coalition publishes this list not only to recognize these positive efforts on behalf of Georgia’s water but also as a call to action for our state’s leaders and citizens to review these success stories, borrow from them and emulate them.
The Georgia Water Coalition is a consortium of more than 260 conservation and environmental organizations, hunting and fishing groups, businesses, and faith-based organizations that have been working to protect Georgia’s water since 2002. Collectively, these organizations represent thousands of Georgians.
INTRODUCTION:
Live Thrive Atlanta’s Center for Hard to Recycle Materials (CHaRM) takes products that have ended their first useful life and repurposes or recycles them—everything from television sets to household chemicals. It is perhaps fitting then that the story of CHaRM’s birth begins with an ending. When founder Peggy Whitlow’s parents passed away she was left with an in-town home and Forsyth County farm—both filled with old household chemicals, garden pesticides and herbicides, not to mention the usual household appliances and other stuff accumulated over a lifetime. “I knew they shouldn’t just go in the trash, but I couldn’t find an outlet for them,” said Whitlow. Frustrated by the dawning reality that a landfill would be the final resting place for these common, but sometimes hazardous, household items, she was inspired. “This is bigger that just cleaning out a house and trying to do the right thing,” she said. And, thus her quest to recycle hard to dispose of materials began, taking her to recycling facilities from Athens, Georgia to Boulder, Colorado and back to Atlanta where CHaRM was born in 2010.
THE WATER BODIES:
The City of Atlanta is home to three rivers—the Chattahoochee, Flint, and South—plus countless neighborhood streams that feed these rivers. The Chattahoochee serves as the city’s primary water source and one of the primary repositories of its treated sewage. Both the Flint and South rivers rise as springs near East Point. The Flint flows in culverts beneath Hartsfield-Jackson Atlanta International Airport before coursing through Clayton, Fayette and Spalding counties; the South flows across South Atlanta, receiving the treated wastewater from much of Metro Atlanta on its journey to Jackson Lake and the Ocmulgee River. Life is rough for rivers and streams in urban areas—not just because of the treated sewage they receive. When greater than 20 percent of the land surface surrounding them is covered in concrete, asphalt and buildings, the health of these streams declines rapidly and they often become choked with litter that washes into them during rain events. Thus, the proper disposal, recycling or repurposing of common household products becomes critically important for stream health in urban locales like Atlanta.
THE CLEAN:
Before Live Thrive Atlanta opened its CHaRM facility in 2010, metro Atlanta residents had few alternatives for disposing of items like household cleaners, lawn pesticides and herbicides, paint products, tires, toilets, carpets and even mattresses. The landfill was typically their final resting place. Now, those unwanted items stashed in Atlanta area attics, closets and basements are finding new life.
Since 2015, CHaRM has diverted more than 50 million pounds of hazardous chemicals and waste from landfills. In fact, more than 94 percent of the materials Atlanta area residents bring to CHaRM are recycled, repurposed or reengineered.
That sports equipment you don’t use anymore? It goes to a thrift store and is used by someone new; tires? A local recycler incorporates them into asphalt that’s being used to fill potholes on city streets; Styrofoam? That packaging material is repurposed into home insulation; electronics? They’re broken down and mined for reusable material; paint? It’s repurposed for community graffiti cleanups; old carpets? They get turned into more carpet and even car parts!
CHaRM’s efforts support 120 manufacturers in Georgia that depend on recycled materials. Driven largely by the textile and paper industries, Georgia is number two in the nation when it comes to infrastructure for “end use” of recovered materials.
Recycling in Georgia is a $2.5 billion business that sustains more than 12,000 jobs and generates more than $200 million in state and local tax collections.
As Live Thrive Atlanta founder Peggy Whitlow said, “It’s dollars and cents. Recycling is not just for tree huggers.”
Despite all that money, however, the vagaries of the recycling markets make turning a profit in the recycling business difficult. CHaRM’s model depends on donations, volunteers and support from local governments, but its existence creates cleaner and more sustainable communities by diverting waste from landfills and reducing illegal dumping.
Before CHaRM began collecting tires, the City of Atlanta typically dealt with up to 200,000 illegally dumped tires annually; those numbers have now been reduced to 25,000 to 75,000 annually. Whitlow estimates that the recyclables CHaRM has diverted from Atlanta’s trash bins have saved the city $1.3 million in landfill tipping fees.
The original Hill Street CHaRM has been so successful that plans are underway to open a similar facility in DeKalb County. “People do care,” Whitlow said. “Given the opportunity, they want to do the right thing. Every city should have a CHaRM.”
For More Information Contact:
Peggy Whitlow, Founder & Executive Director,
404-771-5322, email@example.com
YKK AP
OCONEE RIVER
Dublin Manufacturer Stays On Sustainability Cutting Edge
INTRODUCTION:
Last year, when the Business Roundtable declared that the purpose of a corporation is not just to serve shareholders, but to “create value for all our stakeholders” it caused a stir. This statement from the country’s most influential group of corporate CEOs seemed to signal that, among other things, these corporations would put caring for the environment on equal footing with making money. To which, YKK Corporation of America President Jim Reed responded: “What took so long?” YKK—the world’s largest maker of zippers which operates facilities in Macon and Dublin—issued its first environmental pledge in 1994. Recently, it set sustainability goals for 2050 that include addressing climate change, water efficiency, waste reduction and protection of natural resources.
YKK’s Dublin Architectural Products (AP) facility, which makes aluminum windows, doors and other architectural facades, has long been on the cutting edge of sustainability practices, and now the company’s 2050 environmental vision has workers there pushing the envelope further.
THE WATER BODY:
Coursing through the heart of Dublin where YKK AP operates, the Oconee River flows some 220 miles through Middle and South Georgia from Athens to near Lumber City where it meets the Ocmulgee to form the Altamaha—the state’s largest river. The Altamaha system drains almost a quarter of Georgia’s land before reaching the Georgia coast and emptying into the Atlantic near Brunswick and the famed Golden Isles. Along the way, the Oconee provides drinking water for some 300,000 Georgians. It also receives treated wastewater from nearly 200 municipal, industrial, commercial and agricultural operations. From the playful shoals of the Middle Oconee in Athens that attract kayakers and tubers to the river’s oxbow lakes in the Coastal Plain that beckon anglers, it is a recreation hot spot.
THE CLEAN:
Since opening in 1992, engineers at YKK AP in Dublin have been on the cutting edge of sustainability. Rather than design a wastewater treatment system to Georgia’s regulatory requirements, YKK adopted standards that would pass muster in California.
Today, before sending its wastewater to the Dublin sewer system, it typically removes pollutants such as nickel, chrome and zinc to levels 80 to 90 percent below regulatory requirements. And, much of what is removed finds new life. For instance, aluminum byproducts from the waste stream are ultimately used in recycling paper.
Using less water has also been a priority. Within the past five years, YKK AP has adopted practices that have reduced water use by 16 percent.
Energy efficiency measures such as investing in LED lighting have reduced the 1.2-million square-foot facility’s monthly power bill by about 15 percent, and YKK AP realizes 50 percent savings on natural gas in its melting and casting operations by employing regenerative burners.
As for the facility’s primary raw material—aluminum—100 percent of aluminum waste is recycled on site, and workers there have reduced the amount of other waste sent to landfills by 40 percent. Since 2003, it has recycled 300 tons of waste paper.
For Chip Wilson, environmental group manager for YKK AP, who tracks water and energy use at the plant, the benefits are twofold. “When you see the meters ticking around here, it makes you think about it,” he said. “It starts with saving money, but you find there’s a lot of other byproducts that can be repurposed.”
Wilson points to the installation of the facility’s solvent still, an apparatus used to recover xylene, a paint solvent used in the manufacturing process. The still recoups 80 percent of the xylene for reuse in house while removing paint components that are incinerated off site for waste-to-energy use. Cost savings realized through the still paid for the initial investment in less than a year.
Now, engineers at the plant are exploring ways to recover and separate more of the elements in its wastewater stream for reuse in house or for sale to other industries. They’re also investigating on-site waste-to-energy programs.
Said Wilson: “We all want to be on the cutting edge, but nobody wants to stand on the blade.” If YKK AP’s Dublin facility isn’t standing on the blade, they are at least tip-toeing along it.
When workers are not in the factory, many of them can sometimes be found picking up trash at Oconee river landings or planting trees as part of YKK AP’s support for Rivers Alive and Keep Dublin-Laurens Beautiful.
For More Information Contact:
Chip Wilson, Environmental Group Manager,
YKK AP, 478-277-2510, firstname.lastname@example.org
Top: The wastewater treatment system at YKK AP typically removes most pollutants to levels 80 to 90 percent below regulatory requirements and many of the byproducts removed are repurposed or recycled. Above: Workers at YKK AP in Dublin have reduced the amount of waste they send to the landfill by 40 percent. Since 2003, the facility has recycled 300 tons of waste paper.
Yonah Mountain Vineyards
GEORGIA’S RIVERS
White County Vineyard Becomes Wine, Solar Destination
INTRODUCTION:
In 2005, when the Miller family purchased some 200 acres of land in White County with Yonah Mountain as a scenic backdrop, they intended to “harvest” sunlight to grow grapes and make wine. Now, 15 years later, they’re not only excelling at growing grapes and producing award-winning wines, they’re also harvesting the sun to provide much of their power needs. In 2019, Yonah Mountain Vineyards installed a 360-panel, $238,000 solar array that now meets more than half the business’s electricity needs and serves as a model for others looking to invest in clean energy.
THE WATER BODY:
Georgia’s rivers make power. At the state’s coal, gas and nuclear power plants, water withdrawn from the Chattahoochee, Coosa, Etowah, Savannah, Altamaha and Ocmulgee rivers serves as cooling water in the steam-driven power generation process. In fact, thermoelectric power plants are the largest users of water in Georgia, demanding more than two billion gallons a day. While these water withdrawals stress river systems on the supply side, power plants’ warm water discharges and toxins leading from coal ash ponds can harm the health of the rivers and aquatic wildlife. Meanwhile air emissions, especially from coal-fired power plants, contain tons of climate-warming greenhouse gases. Mercury is also released in these emissions and ultimately falls back to the ground. Once introduced to the environment, it enters the aquatic food chain, tainting the fish we eat with the toxin. Against these pollution problems and the growing demand for water for municipal supplies, clean energy like solar is playing an increasingly important role in protecting water resources.
THE CLEAN:
Georgia’s solar energy industry is booming. Across the state, more than 2,600 MW of solar panels are in operation, ranking the state 9th in total solar installed. That’s enough electricity to power more than 300,000 homes. The boom in solar is due in part to the falling cost of installation—a 38 percent drop in the last five years.
The Miller family of Yonah Mountain Vineyards is among those riding the wave of lower costs for clean energy. While their array helps eliminate impacts to the state’s rivers and reduce climate-warming pollutants, the installation is also a financial windfall. They expect to recoup their nearly quarter-million-dollar investment in utility bill savings within eight years.
“We know climate change is happening; we know it is real. So, there was no reason not to build the vineyard facilities so that it would help the planet,” said Eric Miller, general manager and the son of founders, Bob and Jane Miller.
The vineyard’s efforts at promoting clean energy don’t end with their solar array. The White County facility is also home to the largest Tesla Destination Charging location in North Georgia, offering 14 plug-in stations for electric vehicles, including some that are fed by the solar installation.
But solar is just part of the vineyard’s sustainability portfolio. Energy-efficient lighting in facilities, a partnership with the Georgia Beekeeping Association that maintains a bee farm on site, a bottle recycling program and a conservation easement to preserve the property are among the other practices the Miller family has employed.
With Georgia’s wine and solar industries simultaneously experiencing tremendous growth, the Millers now find themselves as advocates for both. A year after the install, the wine experts are not just sommeliers; they are sommoliers of solar.
Said Miller: “The quickest way to get people on board with solar is to talk about the financial incentives. If they don’t care about the planet they do care about the money.”
But, there’s still room for growth. Though expanding rapidly, solar power provides less than three percent of Georgia’s total electricity.
For More Information Contact:
Eric Miller, General Manager, Yonah Mountain Vineyards,
706-878-5522, email@example.com
Emory University
CHATTAHOOCHEE & SOUTH RIVERS
WaterHub Relieves Pressure on Water & Sewer Infrastructure
INTRODUCTION:
In the summer of 2008, Atlanta was reeling from two years of drought. As water use restrictions tightened, water supplies crept perilously close to running dry. It was a frightening wake up call for a metro region of some six million residents that depended on the diminutive Chattahoochee for its primary water supply. Of course, Emory University in DeKalb County, known as one of the leading research universities in the nation, was already ahead of the curve. Three years prior to that epic drought, the university had already set a goal of cutting its water use in half. By Earth Day 2015, officials were dedicating the school’s WaterHub, an on-campus water treatment/recycling facility that during the past five years has helped supply 40 percent of the school’s water needs. The first of its kind facility in the U.S., it now serves as a model for other communities looking to conserve water and reduce stress on water and sewer infrastructure.
THE WATER BODY:
Atlanta’s water supply and wastewater treatment systems rely heavily on the Chattahoochee and South rivers. The Chattahoochee supplies drinking water for 40 percent of Georgia’s citizens, including most of those living in metro Atlanta. In fact, no other major city in the U.S. depends upon a smaller river basin for its primary water source. Meanwhile both the Chattahoochee and South are the primary destination for effluent from sewage treatment facilities in DeKalb and Fulton counties. The Emory WaterHub relieves pressure on these rivers, and by removing and recycling sewage from the collection system, the Hub also contributes to the improved health of urban streams like Peachtree and Snapfinger Creeks, which are susceptible to sewage overflows during heavy rain events.
THE CLEAN:
Amidst Emory’s picturesque, tree-lined campus sits a sewage treatment plant, but you’d never recognize it as such. That’s because the odor-free WaterHub looks like an ordinary greenhouse, complete with tropical plants reaching up to the ceiling of the glass-roofed complex.
The WaterHub, operated by Sustainable Water, a water reclamation technology provider, diverts sewage from DeKalb County’s system and cleans it with the help of organisms that utilize biomimicry to break
down pollutants. The reclaimed water is then used to heat and cool campus buildings through the school’s steam and chiller plants and used for flushing toilets in some residence halls.
The University now supplies 40 percent of its water through the system.
The benefits of the system ripple through the campus and across Atlanta. Aside from slashing the University’s water and sewer bill by millions, the WaterHub reduces water withdrawal demand on the Chattahoochee River by up to 146 million gallons annually.
And, by treating up to 400,000 gallons of sewage daily, it also reduces the risk of sewage overflows in DeKalb County’s public sewage system—a problem that has long polluted streams like Snapfinger and Peachtree creeks.
The facility also accrues energy savings, and not just because it is partially powered by solar panels. Treating and moving water to customers is an energy intensive process and by recycling water on site, the Hub reduces power consumption and greenhouse gases.
It also serves as a teaching tool. Chemistry and public health students conduct lab work at the WaterHub, and the school provides regular tours of the facility, hosting everyone from school children to international leaders.
More than 5,000 people have toured the facility since 2015, and they are taking note. Last year, Duke University announced it would build its own WaterHub.
Emory wants more to follow their lead, for the WaterHub addresses not just water, sewer and energy challenges; it also tackles social justice and equity issues.
“Too often large wastewater infrastructure projects are placed in neighborhoods that are poor and voiceless. They’re unattractive and stinky and lower property values. This model shows that wastewater treatment doesn’t have to be that way,” said Ciannat Howett, Associate Vice President of Sustainability, Resilience and Economic Inclusion. “It’s our waste. We created it and we’re responsible for it. We’re not going to pollute someone else’s neighborhood.”
For More Information Contact:
Ciannat Howett, Associate Vice President of Sustainability, Resilience and Economic Inclusion,
404-313-4683, firstname.lastname@example.org, www.sustainability.emory.edu
Top: Though the Emory WaterHub is a sewage treatment facility, you’d never know it. The greenhouse-style structure is aesthetically pleasing and odor free. Left: The Emory WaterHub serves as an educational tool for the university. Chemistry and public health students conduct labs at the Hub. Above: Among those who have visited the WaterHub is former USEPA administrator, Gina McCarthy. Emory’s WaterHub tours have inspired others to adopt the model. Last year, Duke University announced plans to develop its own WaterHub.
INTRODUCTION:
The stage is a familiar one: the company picnic, family reunion or special event. The scene is all too common: after the big meal is served, the garbage receptacles overflow with discarded Styrofoam and plastic plates, cups and utensils. The drama ends predictably: in a landfill where the petroleum byproducts will live for generations.
Marietta-based Parsley’s Catering, which services hundreds of such events annually, has seen that play, and over the last two decades, the family-owned business has worked to change the narrative. The company has invested in recyclable and compostable serving products, clean energy installations, water saving plumbing fixtures, support of locally-produced and sustainable farm products and even “green” cleaning supplies. Today, Parsley’s is one of just a handful of Atlanta area food service providers certified by the Green Restaurant Association, a national organization that promotes sustainable practices amongst restaurants and caterers.
THE WATER BODY:
With more than 70,000 miles of rivers and streams and vast reserves of groundwater, Georgia is blessed with abundant water resources. These water bodies give us drinking water, assimilate municipal waste, power business and industry and provide us with countless recreational opportunities. In fact, the Outdoor Industry Association estimates that Georgia’s outdoor recreation economy generates $27.3 billion in consumer spending and $1.8 billion in state and local taxes annually, while supporting some 238,000 jobs. Yet, these play places are threatened, not simply by water withdrawals and sewage discharges. Plastic waste and litter can be found on virtually every waterway in Georgia, diminishing recreational experiences and posing a threat to wildlife and stream health.
THE CLEAN:
When Marc Sommers began working in his family’s catering operation in the early 2000s, he borrowed from his experiences in Portland,
Oregon where he worked in a pizza parlor that sourced its cheese locally and created its dough from spent grain generated at a local brewery. The sustainability-focused business atmosphere left its mark on him.
Upon returning to Georgia he found the sustainability movement behind the West Coast and decided to do something about it. “My goal was to create a company that was sustainable, was supporting the local economy and was focused on the bigger picture,” he said.
Out were Styrofoam and petroleum-based products; in were compostable and biodegradable plates and utensils. That was just the beginning.
Upon purchasing the Gardens at Kennesaw Mountain, a historic home and event venue on four acres near the base of Kennesaw Mountain, Parsley’s upgraded the facility with waterless urinals and water-saving sinks, toilets and dishwashing equipment. The company also installed a solar array to increase its reliance on clean energy, implemented a composting program to eliminate waste to landfills and converted to “green” cleaning products.
Parsley’s realizes water savings of more than 200,000 gallons annually and the solar panels have offset the equivalent of 23,000 pounds of greenhouse gases since their installation.
Borrowing a final page from his days in Portland, Sommers sought out local organic farms for his produce. Meats and cheeses now come from Riverview Farms near Resaca and Sequatchie Cove Creamery in Tennessee; vegetables come from Rise N’ Shine Farms near Calhoun.
These changes qualified Parsley’s Catering for two-star certification by the Green Restaurant Association, one of only a handful of Atlanta area eateries to qualify for such designation from the national organization.
Using his own business as an example, Sommers now encourages other restaurateurs and caterers to “go green.” “Our hope is to provide a road map for others,” he said. “Sustainable practices can translate into increased savings and increased revenue as more businesses require at least a minimum of sustainably-focused products.”
For More Information Contact:
Marc Sommers, Owner, Parsley’s Catering,
770-396-5361, email@example.com
Top: Workers prep food for another Parsley’s event. The Marietta-based caterer is one of just a handful of Atlanta area food service providers to qualify for certification by the national Green Restaurant Association, which promotes sustainability practices amongst caterers and restaurants. Left: A solar array at Parsley’s event venue in Marietta has offset the equivalent of 23,000 pounds of greenhouse gases since its installation. Above: Fresh tomatoes fill a plate during a Parsley’s Catering event. The Marietta-based caterer sources its vegetables, meats and cheeses from local, organic farms.
Golden Triangle RC&D Council
CHATTAHOOCHEE, FLINT & OCHLOCKONEE RIVERS
Locals Help Locals Protect Land and Water in Southwest Georgia
INTRODUCTION:
Since 1962 with the passage of the federal Food and Agriculture Act, Resource Conservation and Development projects have empowered locals to improve conditions in rural communities through better soil, water and land conservation practices. In 2011, budget cuts eliminated direct federal funding to the councils, but today many councils persist as non-profit organizations supported through contracts, state and federal grants and private funding. Georgia is home to 11 councils, but few are as active as the Golden Triangle RC&D which operates in 15 Southwest Georgia counties. The work of the staff at Golden Triangle—which ranges from mitigating erosion on the region’s many dirt roads to improving irrigation efficiency on local farms, has directly benefited the Flint, Chattahoochee and Ochlockonee rivers and improved the lives of their rural neighbors.
THE WATER BODY:
The Chattahoochee, Flint and Ochlockonee rivers—along with the Floridan aquifer that interacts with them—are critically-important to the agriculture-based economy of the Southwest Georgia, irrigating hundreds of thousands of acres in the region. Producers there grow a large share of the state’s more than $13 billion in annual farm products sales. The rivers and creeks of the area are home to several mussel species on the brink of extinction. Agricultural water withdrawals causing reduced stream flows and sedimentation from land uses that disrupt mussel habitat, reproduction and feeding are among the factors in the demise of these species. Aside from having colorful names like purple bankclimber and shirnyrayed pocketbook, these federally protected creatures play an important role in maintaining stream health by filtering nutrients from the water. They are yet another example of the nexus between sustainable water and land management and the health of Georgia’s rivers.
THE CLEAN:
Golden Triangle RC&D Council is the literal boots on the ground in Southwest Georgia addressing some of the most pressing land and water management issues impacting the region’s economy as well as stream health and imperiled aquatic species.
Among its programs is an effort to tackle erosion and sedimentation from unpaved roads that damages area streams—there’s upwards of 1500
dirt roads in the Golden Triangle’s 15-county service area. Under an agreement with the U.S. Fish & Wildlife Service and Georgia’s Environmental Protection Division, the Council conducts regular technical workshops with county road maintenance crews and completes erosion control projects to reduce the flow of dirt into streams.
Earlier this year, state regulators tasked the Council as the lead organization in updating the Georgia Better Back Road Field Manual, a guide to best management techniques for controlling sedimentation from dirt roads.
The Council has also secured grants to improve farm irrigation efficiency. This summer it embarked on a program to install soil moisture sensors on area farms to help producers adjust and target their irrigation, putting water only where it is needed. It’s a first step in more widespread use of this water-saving technology.
For the past nine years, the region’s imperiled mussels have also gotten the Council’s direct attention. Through a partnership with U.S. Fish & Wildlife Service and Georgia’s Environmental Protection Division, a stream flow augmentation facility is maintained on Spring Creek to protect endangered mussels.
While conducting these projects, Council staff is also involved in water resource education. It partners annually with Georgia Pacific for a Waterways Festival in Early County; supports a summer H2O camp for school children at the University of Georgia C.M. Stripling Irrigation Research Park in Mitchell County; participates in Rivers Alive cleanups; and partners with Flint Riverkeeper and the Flint RiverQuarium to enlist citizens in the state’s Adopt-A-Stream program.
Along the Chattahoochee River in Early County, it even developed an outdoor classroom and interpretive signs in Fannie Askew Williams Park at Coheelee Creek, site of one of Georgia’s remaining covered bridges.
Beginning last year, the Council embarked on a project to produce a series of videos highlighting the cultural and natural history of the Flint River basin. The goal is to educate communities about the importance of the river and promote tourism along its route. A partnership with the Georgia Water Planning & Policy Center at Albany State University and Flint Riverkeeper was created to accomplish this task.
Involved in water and land protection on multiple fronts, the Council is incrementally making a difference.
“It’s drop by drop; every drop counts. You get there one drop at a time,” said Rhonda Gordon, Executive Director. “A little here and a little there, it all adds up. Helping people understand why it’s important to keep the watershed clean—that’s important to us and we know we are making a difference.”
For More Information Contact:
Rhonda Gordon, Executive Director,
Golden Triangle RC&D Council, 229-995-2027,
firstname.lastname@example.org
Gordon Rogers, Flint Riverkeeper, 912-223-6761,
email@example.com
Top: Streambank restoration projects are one of the many ways that Golden Triangle RC&D staff are working to improve stream health and habitat for imperiled mussel species in Southwest Georgia. Left: Educating youth at the Georgia Pacific Waterways Festival in Early County, Golden Triangle RC&D Council works to teach school children about the importance of the region’s water resources.
INTRODUCTION:
Of Georgia’s seven natural wonders, the Okefenokee is the most vast, most wild and most fabled—some 440,000 acres of primeval wilderness—the largest wilderness area in Georgia and the largest National Wildlife Refuge in the eastern U.S. It is not a place conducive to drive-by tourism. To see and experience it, you must enter it—most easily by boat. Since 1946, Okefenokee Swamp Park, a private, non-profit organization created by swamp boosters from the Waycross area, has introduced millions of visitors from around the world to the swamp. The park provides boat and walking tours of the swamp, wildlife education programs and wildlife research. Recently, it has embarked on a marketing plan with the Okefenokee National Wildlife Refuge and Stephen C. Foster State Park to bring more people to the swamp to learn about and appreciate its wonders—a critical public education component as the health and beauty of the swamp is threatened by outside forces.
THE WATER BODY:
The “land of trembling earth,” the Okefenokee Swamp encompasses nearly 700 square miles of Clinch, Ware, and Charlton counties in Georgia and Baker County in Florida. Considered the largest blackwater wetland in the U.S., it has been protected by the federal government since 1937, has been named a Wetland of International Importance, designated as a National Natural Landmark and is listed as a tentative UNESCO World Heritage Site. A biological treasure trove, it harbors more than 600 species of plants, 40 mammals, 50 reptiles, and 60 amphibians. More than 200 species of birds have been identified within the swamp, including the federally protected red cockaded woodpecker and wood stork. Beneath the surface of the swamp’s tea-colored water can be found 34 species of fish. The swamp also holds the headwaters of the Suwannee and St. Marys Rivers. A place like no other, the Okefenokee is used by some 600,000 people annually who boat, bird, fish and hunt amongst its moss-draped cypress trees and lily-padded lakes.
THE CLEAN:
At Okefenokee Swamp Park, they are used to aweing visitors. Alligators bellow at one another; wood storks walk through blackwater on stilt-like legs; turtles bask on logs; frogs join a chorus of chirps and croaks.
“People tend to get real quiet when they enter the swamp,” said Kim Bednarek, the park’s Executive Director, “It’s a very magical place.”
Interestingly, despite the swamp’s uniqueness and the growing interest in “ecotourism,” annual visitorship at the park has declined noticeably since the 1970s when I-95 began syphoning Florida-bound tourists off U.S. 1 in Waycross which ran past the entrance to the park. The result of the changing transportation landscape is a reduction in the number of people who are aware of the swamp’s wonders and willing to advocate for its protection.
That’s one reason Okefenokee Swamp Park has begun partnering with the National Wildlife Refuge, Stephen C. Foster State Park and Valdosta State University to develop a comprehensive marketing strategy for swamp-based tourism. The effort dovetails with the park’s ultimate goal: “for the public to develop an appreciation for the wildlife, culture and natural beauty of the Land of Trembling Earth.”
Recently, that goal has taken on a sense of urgency with the proposed development of a titanium mine in Charlton County that could impact swamp water levels—and thus, swamp-based tourism.
As the Park works to bring more people to the swamp, it continues its tradition of education and research. In addition to adults and family groups, it annually hosts thousands of school children on field trips, presents daily live animal shows and boat excursions, and regularly conducts “Okefenokology” classes that highlight the natural and cultural history of the swamp.
The park’s core research project is conducted in partnership with the University of Georgia whose students and faculty track, observe and capture some of the swamp’s more than 10,000 alligators to expand knowledge of the animal’s behavior and genetics. Part of this research involves placing satellite trackers on the alligators.
Should you find yourself in southeast Georgia, Okefenokee Swamp Park’s boosters would urge you leave the superhighway and find your way to Waycross and the 74-year-old park. But, first prepare yourself to be awed.
For More Information Contact:
Kim Bednarek, Okefenokee Swamp Park Executive Director, 904-207-8057, firstname.lastname@example.org
Rena Peck, Georgia River Network Executive Director, 404-395-6250, email@example.com
Top: Boating trails leaving from Okefenokee Swamp Park provide entry into the nearly 700 square-miles of primeval wilderness. The park conducts daily boat tours into the swamp. Left: One of the Okefenokee’s more than 10,000 alligators. When Okefenokee Swamp Park first opened in 1946, alligators in the swamp had been hunted almost to extinction. Above: In addition to providing boat excursions into the swamp, Okefenokee Swamp Park maintains boardwalks for pedestrian access, including one to this observation tower, providing a bird’s eye view of the swamp.
INTRODUCTION:
New York City has the Hudson River; Miami has South Beach; Los Angeles—Venice Beach. For land-locked Atlanta, the Chattahoochee is the city’s water play place. From the days of the Ramblin’ Raft Race in the early 1970s to the development of the Chattahoochee River National Recreation Area into the 1980s, Atlantans have long had a love affair with the river…at least part of it. Downstream from the national park, sewage treatment plants discharge millions of gallons of treated waste to the river, and for decades metro Atlanta’s inadequate sewage infrastructure fouled the river. Until recently, Atlantans typically turned their backs to that section of river. Now, however, after years of progress in fixing sewer problems, the river is in recovery, and the Chattahoochee RiverLands vision now hopes to link those previously forgotten sections of the river with the long-beloved national park using a 125-mile multi-modal trail. The trail will stitch together communities from Gwinnett to Coweta counties, featuring parks, river access points and connecting trails that bring residents to the river’s edge.
THE WATER BODY:
Coursing 434 miles from the Blue Ridge Mountains to the Florida state line, the Chattahoochee is Georgia’s longest and most important river. It supplies drinking water for about 40 percent of the state’s population and carries away the treated waste of those same citizens. Its water generates electricity at multiple hydro-power dams as well as at gas and nuclear-powered facilities located along its banks. Paper mills and chicken processing plants, among other industries, also depend on its flow. Meanwhile it is home to an incredible array of wildlife: 104 fish species, 24 aquatic turtles and, historically, as many as 45 species of freshwater mussels. Especially for those in the metro area, it is an outdoor recreation mecca. The Chattahoohcee River National Recreation Area hosts more than three million visitors annually that float the river’s gentle rapids, cast for trout in its cold water and jog, walk and bike on riverside trails.
THE CLEAN:
With the revival of the river downstream of Atlanta, the Chattahoochee RiverLands vision has taken hold. A recently published $1.5 million study, funded by the Trust for Public Land, the Atlanta Regional Commission,
the City of Atlanta and Cobb County, lays out a road map for making some 100-miles of the Chattahoochee into “metro Atlanta’s defining public space.”
The plan calls for construction of a 125-mile multi-modal trail along the river, connecting to multiple public parks and to “tributary” trails—like the popular Silver Comet--that will link to nearby neighborhoods, cities and public transportation. Meanwhile, new river access points will be developed to extend the already existing 48-mile Chattahoochee River National Water Trail. These boat launches will make accessible some 56 miles of the river for boating, floating, fishing and swimming. When completed the greenway will be the largest of its kind in the state—the equivalent of four Atlanta BeltLines stitched together.
The first phases of the long-term vision are already taking shape as various stakeholders develop individual projects. Cobb County will soon construct nearly two miles of path between Mableton Parkway and Veterans Memorial Highway and a new boat launch near the confluence of Nickajack Creek and the Chattahoochee. Ultimately, 19 cities and seven counties will play roles in completing the RiverLands project which is estimated to cost about $1 billion—about the same cost as the new interchange that the state is currently building at Ga. 400 and I-285.
For the river, it’s a miraculous change of course. “Thirty years ago, you wouldn’t have wanted to be along the river downstream of Atlanta,” said Walt Ray, the Trust for Public Land’s Michael J. Egan Chattahoochee Conservation Fellow. “For that reason, the river has been well hidden. This project will allow metro Atlanta to discover its waterfront.”
For the Trust for Public Land (TPL), the project is a continuation of efforts that it began more than 25 years ago. Since the 1990s, TPL has protected some 18,000 acres along the river, including some 80 miles of riverfront for public use.
Aside from connecting communities and providing transportation and recreation alternatives, the RiverLands project ultimately aims to connect residents with the river—a goal summed up in the RiverLands report that borrows the words from famed natural historian, David Attenborough: “No one will protect what they don’t care about and no one will care about what they have never experienced.”
Said the TPL’s Ray: “That’s the genius of the RiverLands. It will introduce the river to a whole new generation of stewards.”
Top: In addition to the primary 120-mile trail, the Chattahoochee RiverLands project includes plans for “tributary trails” that will connect with neighborhoods and communities along the river. Left: The Chattahoochee is Georgia’s longest and most important river, supplying drinking water for about 40 percent of the state’s population. The Chattahoochee RiverLands project aims to enable more Georgians to experience the river in person. Above: Artist’s renderings of the Chattahoochee RiverLands project show the 120-mile trail running from Buford Dam in Gwinnett County to Chattahoochee Bend State Park in Coweta County.
For More Information Contact:
Walt Ray, Trust for Public Land Michael J. Egan Chattahoochee Conservation Fellow, 404-873-7306, firstname.lastname@example.org
SouthWings
GEORGIA’S WATER
Flight Program Provides Landscape-Scale Perspective on Water Issues
INTRODUCTION:
In 1968 during the first manned flight to the moon’s orbit, NASA astronaut Bill Anders snapped a photo of Earth that would come to be known as Earthrise—the first color image of the Earth shot from beyond it. That image forever changed our perspective on the planet. It was a portrait of our home so stunning and starkly beautiful that it is credited in part with propelling the environmental movement. Today, SouthWings, an Asheville, North Carolina-based organization, continues that tradition of perspective changing from the sky…though a little closer to home than the moon. The organization’s volunteer pilots carry advocates, journalists and decision makers on flights that provide a landscape-scale view of issues impacting our water, air and land. In Georgia, SouthWings pilots have provided dozens of flights in recent years addressing issues as diverse as coal ash disposal and mining near the Okefenokee Swamp. For members of the Georgia Water Coalition, the photographs, videos, and discussions with policy makers stemming from SouthWings flights have been critical tools in changing perspectives and protecting Georgia’s water.
THE WATER BODY:
As the Earthrise photograph so profoundly illustrated, Earth is the water planet. Water covers 71 percent of the Earth’s surface, yet less than one percent of the planet’s water is found in our rivers, lakes and streams. In Georgia, there are 14 major river basins, more than 70,000 miles of streams and rivers and 425,000 acres of lakes. The Georgia coast is home to 400,000 acres of coastal marshes that fringe five large estuaries where the fresh water of the Savannah, Ogeechee, Altamaha, Satilla and St. Marys mixes with the Atlantic Ocean. From the ground, the state’s vast network of water seems disconnected, but from the bird’s eye view afforded by SouthWings’ flights, the interconnectedness is revealed—between land and water, creek and river, river and ocean.
THE CLEAN:
In the last 15 years, SouthWings volunteer pilots have provided 179 free flights to assist Georgia organizations in protecting the state’s water, land and air. In the past year alone, SouthWings volunteer pilots conducted 29 flights in Georgia, logging 87 hours of flight time.
When the Golden Ray cargo ship capsized in St. Simons Sound, Altamaha Riverkeeper enlisted Southwings in flights to monitor the leaking ship and provide aerial perspective of the oil spill for journalists. When the Coosa River Basin Initiative needed to take legislators on an aerial tour of coal ash ponds, SouthWings took flight. When Georgia River Network and Suwannee Riverkeeper needed to check up on a proposed mining site threatening the Okefenokee, SouthWings provided the reconnaissance.
Whether monitoring active sites of pollution, showing legislators the impacts of policy decisions or giving media the opportunity to better understand an issue, SouthWings’ flights serve as a flying classroom.
“In one short flight, you get a full set of information and the inspiration you need to change things,” said Meredith Dowling, SouthWings Associate Executive Director. “It allows you to see things that weren’t previously visible.”
For Georgia’s environmental organizations, the service is a godsend. “They are awesome,” said Altamaha Riverkeeper Fletcher Sams. “Most of the work we do begins with them, and we would not be where we are today without them.”
In the past year, SouthWings has helped Altamaha Riverkeeper document issues associated with the Rayonier Advanced Materials chemical pulp mill in Jesup; Georgia Power Company’s Plant Scherer coal-fired power plant near Juliette; and the capsized Golden Ray cargo ship in St. Simons Sound.
While documenting pollution problems through photographs and video is integral to the organization’s mission, getting decision makers in the air can have an even greater impact.
“The ability to have conversations as we are looking at the issue from a landscape scale—that’s the magic of flying,” said Dowling. “You can’t see how vulnerable we are until you get above it.”
For Coosa River Basin Initiative Executive Director and Riverkeeper, Jesse Demonbreun-Chapman, who accompanied local legislators on flyovers in their districts that included views of coal ash ponds, the short aerial tours built relationships and awareness of issues. The flights paid dividends as local legislators supported important legislation regulating coal ash that ultimately was adopted.
Top: SouthWings provided aerial reconnaissance of coal-fired power plants from Plant Bowen in North Georgia to Plant Scherer in Middle Georgia in support of the Georgia Water Coalition’s efforts to introduce and adopt new legislation regulating coal ash. Left: SouthWings volunteer pilot Woody Beck with Rep. Matt Gambill, left, and Rep. Katie Dempsey during a day of flying in the Cartersville and Rome area. Coosa River Basin Initiative Executive Director Jesse Demonbreun-Chapman accompanied the legislators on a flyover of their districts, including views of coal ash ponds. The legislators later supported important coal ash regulations.
For More Information Contact:
Meredith Dowling, Associate Executive Director, SouthWings, 828-225-5949, email@example.com
Rena Peck, Executive Director, Georgia River Network, firstname.lastname@example.org
Fall-Line Alliance for a Clean Environment
OCONEE AND OGEECHEE RIVERS
Grassroots Citizens Group Halts Coal-Fired Power Plant in Middle Georgia
INTRODUCTION:
If an enterprising Hollywood screenwriter was looking for the next Erin Brockovich-style enviro-drama, they’d do well to investigate the saga of Plant Washington, a coal-fired power plant in Washington County originally proposed in 2008. It has it all. Power, corruption and a group of small-town activists who risked their standing amongst family, friends and neighbors in Sandersville to fend off what may be the last coal-fired power plant ever proposed in the U.S.. Earlier this year, activists with the Fall-Line Alliance for a Clean Environment (FACE) celebrated as state regulators pulled the plug on permits needed to begin construction on the 850-megawatt plant which has languished for years as financing for the project was withdrawn and its high-profile boosters became entangled in scandals. As power utilities shutter coal-fired plants in favor of cleaner and cheaper energy alternatives, Plant Washington was the only coal plant in the nation still under consideration.
THE WATER BODY:
Plant Washington would have been built between the Ogeechee and Oconee rivers and would have demanded some 16 million gallons of water a day—taken from groundwater that sustains flows in the Ogeechee or directly from the Oconee River via a 20-mile pipeline. Its coal ash waste would have been disposed of perilously close to wetlands feeding the Ogeechee. The blackwater Ogeechee remains one of Georgia’s only free-flowing rivers, having no dams along its mainstem as it winds some 245 miles to the Georgia coast at Ossabaw Island. Feeding a lush and vast floodplain and coastal marsh, nearly 25 percent of the land in the Ogeechee basin is considered wetlands. The Oconee is part of the larger Altamaha River basin. With its headwaters streams—the Middle and North Oconee—surrounding Athens, it flows some 220 miles to its confluence with the Ocmulgee near Lumber City to form the Altamaha.
THE CLEAN:
In 2008, Power4Georgians, the consortium of Electric Membership Corporations led by Cobb EMC, gathered local leaders in Washington County to announce its coal-powered project. At that meeting, Dean Alford of Allied Energy Services, the company tasked with building the plant, said, “There’ll be some push back from some environmentalists in Atlanta, but, don’t worry, we’re going to build this plant.”
Little did Alford know, among those at the meeting were local citizens that would soon find themselves as frontline “environmentalists.”
Within a few months, Katherine Cummings and Cathy Mayberry, who attended that initial meeting, were soon joined by other concerned citizens. Together, they organized standing-room only community meetings and local opposition was born.
It was not easy in small-town Sandersville, Georgia’s kaolin capital, where the community was hungry for new jobs and economic development. Backing the project was one of the town’s most powerful and influential families, the Tarbuttonss--kaolin and railroad barons who would profit from selling some of their land for the project and by hauling coal to the plant.
Cummings, who headed a non-profit organization supporting rural health initiatives and which depended on state support, was threatened with the loss of public funding. “I was told to decide between my job and fighting a coal plant on my own time,” she said. The local power brokers had influence at the state level. Others in the opposition were ostracized in social circles and even at church.
Yet, FACE members persevered. Working with a coalition of other groups, including Ogeechee Riverkeeper, Altamaha Riverkeeper, GreenLaw, Southern Environmental Law Center, Georgia Sierra Club, Southern Alliance for Clean Energy, Environment Georgia, Sapelo Foundation and the Rockefeller Family Fund, they appealed permits, testified at hearings and educated the community on the risks posed by the plant.
As electricity demand flattened and gas and renewables became cheaper, Electric Membership Corporations withdrew their support, leaving Cobb EMC and Allied Energy Services as the primary partners.
Dwight Brown, the Cobb EMC chief executive officer that formed Power4Georgians, was indicted on racketeering charges in 2011. Power4Georgians dissolved in 2017. Alford, a former state legislator and Governor-appointed member of the Board of Regents, was also charged with racketeering in 2019. The house of corruption backing Plant Washington crumbled under its own weight.
Cummings, who has now moved to the Atlanta area but whose family remains in Washington County, said of the experience: “It allowed all of us to be our best selves. It was an opportunity to live out our values in a very public way.”
In 2014, Washington County welcomed a $30-million, 40-acre solar project producing 7.7 megawatts. Cobb EMC is now the primary purchaser of the power. Since 2010, more than 170 proposed coal-fired power plants have been cancelled across the country. Meanwhile, FACE remains active in the Sandersville community.
For More Information Contact:
Katherine Cummings, Fall-Line Alliance for a Clean Environment,
478-232-8010, email@example.com
Top: FACE organized youth and adults to distribute information about Plant Washington at local events, including the Kaolin Festival in Sandersville. Left: Throughout the decade-long battle over Plant Washington, FACE educated the public about the impacts of coal-fired power plants, including the release of mercury to the aquatic food chain. “Clean Energy; No Coal Plant” yard signs could be seen all over the area.
INTRODUCTION:
A native of Glynn County, Sen. William Ligon, grew up amidst some of Georgia’s most treasured natural wonders. Bordered on the north by the state’s largest river—the Altamaha—and on the south by a blackwater beauty in the Little Satilla River, Glynn County sits squarely in the middle of Georgia’s coast and is home to the state’s fabled Golden Isles—St. Simons, Little St. Simons, Sea Island and Jekyll Island. It’s not surprising then that Ligon grew up loving the outdoors, fishing the coast’s blackwater streams and hunting the bottomland woods along those streams. And, it’s equally unsurprising that when he was elected to serve in the Georgia Senate in 2010, he became a leading advocate for the preservation and restoration of coastal Georgia.
THE WATER BODY:
Georgia’s coast stretches 100 miles, encompassing 14 major barrier islands, some 400,000 acres of tidal marshes and the estuaries of five major rivers: the Savannah, Ogeechee, Altamaha, Satilla and St. Marys. These coastal estuaries provide critically important habitat for seafood like shrimp, crabs and oysters, while the inland reaches of these waterways support countless industrial, agricultural and recreational uses. The natural beauty of the region makes it the state’s most popular tourist destination, attracting some 15 million visitors annually. Meanwhile, the coast is visited by many other special creatures. Federally endangered right whales come to coastal waters to give birth to their young while several protected species of sea turtles nest on the state’s beaches.
THE CLEAN:
Sen. William Ligon has learned in his ten years in the Georgia Senate that persistence pays off. In 2013, Ligon introduced a resolution urging the state to work with the U.S. Army Corps of Engineers to study the closing of Noyes Cut near the mouth of the Satilla River. Noyes and other cuts, artificial openings along the intracoastal waterway engineered in the 1930s and 40s, had for years been disrupting salinity levels in the river’s estuary. This, in turn, impacted the successful reproduction of crab, shrimp, oysters and several fish species, and also restricted boating access to several tidal creeks.
The timing of Ligon’s resolution could have been better. With the state still reeling from recession, funds for studies that Ligon’s resolution
called for were in short supply, but through persistence, Ligon secured that funding. Four years later, the study recommended closing the manmade cuts to restore historic flow patterns—an action that is expected to also restore important fisheries.
Within the year, work should begin to close the cuts.
But Ligon’s efforts on behalf of the coast don’t end there. Concerned about the possibilities of toxic contaminants in coal ash leaching into underground water supplies, Ligon introduced SB 123 during the most recent legislative session. The bill, which passed with nearly unanimous support in both chambers, closes a loophole in Georgia’s solid waste laws that encouraged out-of-state producers of coal ash to dump their waste in Georgia landfills.
Ligon was also a leading Senate proponent of HR 164, the “trust fund honesty” resolution. The resolution creates a constitutional amendment that, if approved by voters in November, will allow legislators to “dedicate” fees collected from citizens for specific purposes—like the state’s Solid Waste and Hazardous Waste Trust Funds. It is the first step toward ensuring that fees collected to support the cleanup of illegal tire dumps and hazardous waste sites will be used for those purposes.
During his tenure, Ligon also worked to protect state-owned Jekyll Island from inappropriate development; advocated to prevent oil and gas drilling along the Georgia coast; and encouraged and secured funding for the development of the Coastal Georgia Greenway, a recreational path stretching from Savannah to St. Marys.
Even when his bills weren’t adopted, Ligon’s legislative efforts have raised the profile of issues impacting Georgia’s coastal treasures. Such was the case this legislative session when, in response to a proposed landfill near his beloved Satilla River in Brantley County, he introduced legislation that would greatly restrict landfill development near blackwater rivers.
“They want to put a landfill in an area that is surrounded by wetlands,” he said. “You don’t put your trash can in the middle of your living room.”
Though the legislation was not adopted, it did elevate the fight to stop the landfill—a fight that is still ongoing. “A bill may not pass, but it may have a positive impact,” he said. “It can move the needle.”
You can expect the retiring senator to continue pushing the needle from the private sector, and you’ll also likely catch him more often on the Satilla, casting with his fly rod for redbreast and perch.
For More Information Contact:
Sen. William Ligon, 912-261-2263, firstname.lastname@example.org
Laura Early, Satilla Riverkeeper.
864-285-1636, email@example.com
Top: On hand to celebrate Sen. Ligon’s retirement from the Senate earlier this year were his parents, Pastor Bill and Dorothy Jean Ligon, shown here with their son and Lt. Gov. Geoff Duncan. Above: In the 2020 legislative session, Sen. William Ligon introduced and successfully passed legislation that will help prevent out-of-state coal ash from being dumped in Georgia landfills.
INTRODUCTION:
Sen. Freddie Powell Sims lives two dirt roads from a paved road in rural Terrell County. Her district includes the city of Albany, but spans across 11 predominantly rural counties where agriculture is king. Though a long-time educator, her family roots run back to farming. She, and especially many of her constituents, know a bit about agriculture. So, when the Georgia Farm Bureau, Georgia Poultry Federation, Georgia Forestry Association and Georgia Agribusiness Council back a bill, Sen. Sims and other legislators representing rural Georgians, usually line up behind them. But the 2020 legislative session saw something most peculiar happen. This is the story of the deceptively titled “Right to Farm” bill, designed to welcome industrial scale-agriculture—and the foul, fly-attracting manure lagoons that go with it—to Georgia, and how it was defeated by unlikely advocates in Sen. Sims and her farmer constituents.
THE WATER BODY:
Industrial-scale agriculture where animals are confined and animal waste is concentrated poses serious risks to streams, rivers and lakes wherever they operate. Georgia’s more than 70,000 miles of streams and rivers, 425,000 acres of lakes and vast stores of groundwater could all be threatened by such operations. In 1995, more than 10 million fish were killed in North Carolina’s New River when a hog farm waste lagoon ruptured. A similar incident occurred in Georgia the same year, when a lagoon failure sent 12 million gallons of liquid manure into tributaries of the Oconee River. The streams and rivers that flow through Georgia’s agriculture communities—and the groundwater that underlies those lands, not only irrigate those same farms and provide drinking water to countless communities, but are also part of the fabric of the state’s rural culture serving as places where residents fish, hunt and recreate.
THE CLEAN:
“Initially all of us thought it was OK,” said Sen. Freddie Powell Sims recounting her first impressions of HB 545, touted as the “Right To Farm” bill. “But if you dug deeper, you found out it did the total opposite. It takes away the right to defend the land we already own.”
HB 545 sought to limit a landowner’s legal recourse when a new agricultural operation moves into an area and begins fouling the air,
water and quality of life. The bill was fashioned after a measure adopted by the pro-hog-farm North Carolina legislature after rural residents successfully sued a large-scale industrial farm for being a nuisance.
Environmental groups—led by the Georgia Water Coalition—and trial attorneys lined up against HB 545, but it passed the House. On the Senate side, however, things stalled, and as *Atlanta Journal-Constitution* political reporter Jim Galloway astutely noted at the time: “legislation (in Georgia)...doesn’t usually stall because of opposition from environmentalists and trial lawyers,” especially when the bill has the backing of the state’s largest industry—agriculture.
It stalled because Sen. Sims began hearing from her constituents, fellow rural landowners and farmers themselves, many of them members of the same Georgia Farm Bureau backing the bill. HB 545 ultimately pitted farmers against farmers.
They stormed the capital, met with the Governor, Lt. Governor and most critically spoke before the 21-member Senate Democratic Caucus, urging them to read the bill’s fine print and vote to keep industrial-scale farms from fouling rural communities.
“Once these farmers came to speak to the caucus, it was a done deal,” said Sen. Sims. “They were passionate about the land.” As the only rural senator in the Democratic Caucus, Sen. Sims urged her colleagues to oppose the bill. They did in unanimity. With several Republicans already opposed to the bill, its fate in the Senate was sealed.
The powerful agriculture lobby kept the pressure on, but Sims was unwavering. “They tried some ugly tactics,” she said. “But I’m going to fight for what’s right, and I think they’ll respect that. If you can’t take a stand on something, you might as well just stay home.”
And, thus a coalition of farmers/landowners, environmentalists and trial lawyers—with a huge assist from a rural senator willing to take a stand—defeated a bad bill backed by some of the state’s most powerful and influential sectors.
Sims attributes the victory to the involvement of her constituents: “It’s (HB 545) no way to treat people that have been on their land for decades. This was a victory for those individuals who wanted nothing but to live without environmental destruction.”
For More Information Contact:
Sen. Freddie Powell Sims, 229-347-0251, firstname.lastname@example.org
Gordon Rogers, *Flint Riverkeeper*. 912-223-6761, email@example.com
Georgia Farmers
GEORGIA’S WATER
Farmers Protect Rural Communities, Streams, Rivers, Property Rights
INTRODUCTION:
During the 2019 Georgia General Assembly session when HB 545, the so-called “Right to Farm” bill, was introduced, the Georgia Water Coalition (GWC) immediately identified it as a threat to Georgia’s water. It was fashioned after legislation in North Carolina meant to protect industrial hog farms. When neighbors of these massive stench-filled farms won nuisance lawsuits, the pro-hog farm North Carolina legislature stepped into to prevent these lawsuits. HB 545, GWC member organizations argued, would invite to Georgia the kind of industrial-scale agriculture waste disposal that has decimated North Carolina communities.
The battle over HB 545 spilled into the 2020 legislative session, where something unexpected happened. A surprising coalition of farmers bucked a bill supported by the state’s most influential farm advocates in the Georgia Farm Bureau. That group of typically conservative-leaning farmers ultimately united with mostly urban Democratic state senators along with enough thoughtful Republicans to defeat HB 545. The effort was led by a passionate group from Southwest Georgia concerned about the fouling of rural communities by industrial animal waste lagoon operators. For them, the threat was not hypothetical; it was real.
THE WATER BODY:
Industrial-scale agriculture where animals are confined and animal waste is concentrated poses serious risks to streams, rivers and lakes where ever they operate. In 1995, more than 10 million fish were killed in North Carolina’s New River when a hog farm waste lagoon ruptured. A similar incident occurred in Georgia the same year, when a lagoon failure sent 12 million gallons of liquid manure into tributaries of the Oconee River. The streams and rivers that flow through Georgia’s agriculture communities—and the groundwater that underlies those lands, not only irrigate those same farms and provide drinking water to countless communities, but are also part of the fabric of the state’s rural culture serving as places where residents fish, hunt and recreate.
THE CLEAN:
Over the last decade, farmers and property owners in Southwest Georgia have become increasingly aware of the perils of industrial animal agriculture as they struggled to deal with the impacts of such operations. So, when HB 545 cropped up in the Georgia General Assembly they immediately recognized it as a proposition that would strip rights from other rural landowners in similar situations.
The measures included in the bill would greatly limit existing property owners’ ability to file nuisance lawsuits against this type operation after it moves into a rural community.
Countering the Georgia Farm Bureau and other agri-business lobbyists supporting the bill, a vocal group of Southwest Georgia farmers phoned and e-mailed legislators, contacted fellow farmers, took to social media, wrote letters to local newspapers and made multiple trips from Smithville, Sumter City, Albany and Leesburg to Atlanta to speak with legislators in person. A coalition of like-minded farmers from around the state soon joined in expressing their concerns.
At the invitation of Sen. Freddie Powell Sims (D-Dawson), Mark Israel, a self-described “hard, hard right” Republican and Sumter County farmer found himself in a most unlikely place—the Georgia Senate’s Democratic Caucus, made up of Sen. Sims and 20 urban legislators.
“I’m not like anyone in this room,” he told them. “We can choose one hundred subjects and we’d disagree on all of them, but we can agree on doing what’s right.”
Fellow Sumter County farmer Jenny Crisp echoed Israel’s sentiments and told the caucus that HB 545 was “just big ag. trying to muscle their way into Georgia.”
When the meeting was done, Sen. Sims, the lone senate Democrat representing a mostly rural district, secured the votes of the full caucus. With several key Republican senators already opposed, HB 545’s fate was sealed.
Marjie McRee, another Sumter County farmer involved in the fight, called the victory a “major miracle,” and said of the unlikely bipartisan coalition: “politics makes strange bedfellows.”
Among the Georgia agricultural producers and landowners who took significant action against HB 545 were: Rusty Bell (Pierce County), Robert Clay (Lee County), Mary Linda Cotten (Dougherty County), Charles and Claire Cox (Dodge County), Mike Green (Monroe and Upson counties), Charles Israel (Sumter County), Hal Israel (Sumter County), William and Lewis Webb (Sumter County), Christopher Kalejta (Peach County), Sammy Lee (Macon and Schley counties), John Marbury (Lee County), Mark Royal (Schley County), Robin Singletary (Mitchell County), Charlotte Swancy (Gordon County), Linda Turpin (Dougherty County), Cindy and Michael Reddish (Tattnall County) and Claire Williams (Chatham County).
At a time when political and social divides seem deeper than ever, the defeat of HB 545 secured by this unlikely coalition serves as a reminder that protecting Georgia’s water is common ground.
For More Information Contact:
Mark Israel, Sumter County farmer, 229-938-8943, firstname.lastname@example.org
Jenny Crisp, Lee County farmer, 229-869-4160, email@example.com
Marjie McRee, Lee & Sumter County farmer, 229-938-9496, firstname.lastname@example.org
Gordon Rogers, Flint Riverkeeper, 912-223-6761, email@example.com
Top: The 2020 legislative session saw an unlikely bipartisan coalition of rural, conservative-leaning farmers and urban Democratic senators defeat HB 545, a bill backed by Georgia’s most influential farm lobbyists. Marjie McRee, a Sumter County farmer, called the victory in the farmer versus farmer fight a “major miracle” and noted that “politics makes strange bedfellows.” Above: Sunflowers brighten the landscape on the Cornwell and William Webb farm in Southwest Georgia. The Webbs were some of the dozens of agricultural producers from around the state that spoke out to defeat HB 545.
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Numerical and experimental study on thermo-mechanical processing of medium-carbon steels at low temperatures for achieving ultrafine-structured bainite
Aarne Pohjonen\textsuperscript{a,}\textsuperscript{*}, Pentti Kaikkonen\textsuperscript{a}, Oskari Seppälä\textsuperscript{a}, Joonas Ilmola\textsuperscript{a}, Vahid Javaheri\textsuperscript{a}, Timo Manninen\textsuperscript{b}, Mahesh Somani\textsuperscript{a}
\textsuperscript{a} Materials and Mechanical Engineering, Centre for Advanced Steels Research, University of Oulu, yliopisto, Oulu 90014, Finland
\textsuperscript{b} Outokumpu Stainless Oy, Tornio 95400, Finland
\textbf{Article info}
\textbf{Keywords:}
Bainite
Austenite
Phase transformation
Simulation
Thermomechanical processing
\textbf{Abstract}
A combination of experimental and numerical approaches was applied for constructing a dynamic model for thermomechanical processing, which was used for simulating laboratory rolling and cooling, and for designing a cooling path to enable phase transformation from austenite to ultrafine (\(\sim 50–100\) nm) bainitic laths. Physical thermomechanical simulation experiments were used for calibrating the numerical models. Hot rolling and water cooling experiments were conducted and they were numerically simulated. The calibrated numerical models were used for simulating the main processing stages affecting the final microstructure evolution during a laboratory scale processing, i.e. the low temperature (500 °C) ausforming and subsequent cooling schedules leading to the decomposition of austenite into bainite and martensite. The fitted model parameters and simulation results are presented for the laboratory rolling and two different cooling paths: (i) air cooling to 350 °C temperature with subsequent holding for 1–1.5 h, and (ii) water cooling close to martensite start temperature, and furnace holding for 1–1.5 h. Microstructural analysis was carried out using scanning electron microscopy combined with electron backscatter diffraction as well as X-ray diffraction and the structures were corroborated with mechanical properties evaluated in respect of hardness, tensile and impact toughness properties. The achieved mechanical properties and microstructures were further interpreted with the numerical simulation results. The results show that the calibrated numerical simulations provide an effective tool for designing suitable thermomechanical processing paths leading to desired microstructure.
\section*{1. Introduction}
Isothermal, low-temperature transformation of suitably designed steel compositions with medium and high carbon contents have been studied comprehensively during past several years, essentially aimed at producing extremely refined ultrafine bainite besides retaining a small fraction of finely divided carbon-enriched austenite in order to achieve ultrahigh strength (> 1500 MPa) combined with adequate tensile ductility, good low-temperature toughness, and high strain hardening capacity. Micrographs revealing extremely fine (20–40 nm) bainite plates were first presented by Caballero et al. [1] and Caballero and Bhadeshia [2]. However, Garcia-Mateo et al. reported significant reduction in the isothermal holding times for high-carbon steels by prior austenite grain refinement and addition of suitable alloying elements, i.e. cobalt and aluminium without reducing the hardness that originated from the extremely refined bainite plates with thickness of the order of 30–40 nm [3]. The extraordinary combination of the tensile strength (1700–2200 MPa) originating from the fineness of the nanostructured bainite plates and the good fracture toughness (30–50 MPa m\(^{1/2}\)) resulting from the softer interlath retained austenite, had outstood every bainitic steel so far [4]. For instance, Yang et al. [5] investigated Si-Al-rich, 0.8C-steels and reported ultimate tensile strengths of 2080–2375 MPa combined with Charpy impact energies of 8–22 J at RT, owing essentially to the facilitation of nanostructured (38–57 nm) bainitic ferrite laths via low temperature (220–260 °C) isothermal transformation.
However, in order to reach ultrahigh strength in bainitic steels, a high content of C is needed (typically 0.8–1.1% C) for lowering of the martensite start (Ms) temperature significantly, thus enabling low temperature bainitic transformation by isothermal holding at temperatures in the range 200–300 °C for times ranging from a few hours to several days. Even reducing the temperature of ausforming to a significantly low temperature lowers the martensite start \((M_s)\) temperature marginally [6]. Possibilities of the occurrence of nanostructured bainite in low-carbon steels have been denied by several authors, for instance, based...
on the theory considering the difficulty of diffusion of substitutional alloying elements [7]. However, in recent studies, efforts have been made to shorten the isothermal holding time for bainitic transformation [8] as well as to lower the carbon content in order to improve the weldability and bendability without compromising on the mechanical properties. For example, Zhang et al. [9] reported that with optimized ausforming in the temperature range 300–600 °C and subsequent isothermal holding at a low temperature in the range 235–250 °C, medium-carbon steels did exhibit nanostructured bainitic laths finer than 100 nm with corresponding Vickers hardness of the order of 600–650 HV, which was close to the hardness of the traditional high-carbon bainitic steels. Tsuji et al. [10] illustrated that ausforming to a strain of 30–35% improved the strength of lower bainite in a spring wire, and despite the presence of relatively high retained austenite content, the ausformed lower bainite expressed a high hardness of 650 HV, much higher than the conventional tempered martensite [10].
Hu et al. [11] reported that ausforming the medium-carbon steels at ≤ 400 °C accelerated the bainite formation, whereas ausforming at 450 or 500 °C actually decelerated the kinetics of bainite formation. However, according to Kaikkonen et al. [12], 0.4C-steels expressed an intrinsic tendency to strain-induced accelerated transformation, when ausformed below 500 °C, especially at 300 and 400 °C, which led to significantly higher flow stresses and the need for higher rolling forces. Zorgani et al. [6] explained the role of ausforming in the stability of retained austenite in medium carbon steels, and reported that even a small amount of ausforming at 600 °C followed by isothermal holding above 350 °C enhanced the presence of blocky-shaped retained austenite, whereas at slightly lower holding temperature of 325 °C, the retained austenite was very stable regardless of the amount of strain imparted during ausforming. Wang et al. [13] investigated microstructure-property relationships in bainitic steels with different isothermal holding temperatures and reported nearly constant yield ratios (yield strength/tensile strength) regardless of retained austenite volume fractions. Besides, the blocky martensite/austenite (M/A) constituents that formed as a result of high temperature bainitic holding, had a deteriorating effect on the room temperature toughness.
Bainite formation has earlier been studied by several different numerical models, for example, using the Kolmogorov-Johnson-Mehl-Avrami (KJMA) [14], and Kirkaldy-Venugopal (KV) [15] models. Another somewhat different transformation kinetic curve is obtained by applying Austin-Rickett (AR) model [16], which describes autocatalytic reaction, or Kim-Lee (KL) model [17,18], which includes an additional parameter for impingement effects. The temperature dependent maximum transformation fraction has been included in modelling by Leblonde et al. [19]. These models are fitted to the experimental data, and though the effects of chemical and mechanical stabilization are not explicitly included in the model description, their effect is, however, included by the fitted parameters. Recently, a more physically-based model was described by Van Bohemen to explicitly describe the effects of mechanical stabilization and chemical driving force on the bainite formation [20]. For the transformation models to be useful in process design and simulation, they need to be fully coupled with heat transfer and conduction models for simulating the actual cooling processes. Since different physical mechanisms operate at different rates at different temperatures, it is important to quantify the accuracy of the model predictions for realistic thermal paths.
Physical simulation combined with numerical modelling enable quick, and rather inexpensive, process design and lead to fairly accurate estimation of resulting properties. Strip and plate products are used in many structural and functional applications, and their production based on optimized process design has been a subject of many earlier studies. For example, Han et al. [21] numerically simulated the entire chain of operations, viz., hot rolling, cooling and phase transformations, Faini et al. [22] demonstrated the capability of FE simulations in describing hot rolling process and Wang et al. [23] applied a heat transfer model to describe the cooling of a hot steel plate by the water jet. The effect of latent heat due to phase transition has been studied by Edalatpour et al. [24]. While the general modelling techniques are widely used for conventional processing, a comprehensive thermomechanical processing route aiming for producing highly refined bainite (~50–100 nm laths), however, has not been examined by combining numerical and physical simulations, and is the main focus of the current study.
The objective of this study is to apply the numerical modelling approach to describe the different processing stages: hot rolling, as described by Ilmola et al. [25] and the subsequent cooling as described by Pohjonen et al. [26,27] using coupled heat conduction and phase transformation models. Earlier, we did apply a similar methodology to simulate the phase transformations during induction heating and cooling [28] and coil cooling of a hot rolled steel strip [29]. To provide the fitted model parameter values in the current context of processing (ultra)fine structured bainite, and for discussing the recent improvements, the relevant parts are described in the current article. The models were fitted to the physical simulation (Gleeble,®) results. The aim is to design an optimal cooling path for producing (ultra)fine structured bainite in medium carbon steels and to simulate and optimize the laboratory-rolling and water cooling during the processing. Finally, the results predicted by the numerical simulations were compared to the actual rolling and cooling experiments.
The flowchart shown in Fig. 1 describes how the different parts of the current study are interconnected. The models and obtained parameters provide the capability to tailor the microstructure for a specific application purpose, most notably to the (ultra)fine structured bainite as demonstrated by the results of the current work.
### Table 1
Chemical compositions of the experimental steels (in wt.%, Fe balance).
| Steel | C | Si | Mn | Cr | Mo | V | Nb |
|-------|-----|-----|-----|-----|-----|-----|-----|
| 1 | 0.4 | 1.3 | 2.0 | 0.70| < 0.01 | 0.02 | < 0.01 |
| 2 | 0.4 | 1.3 | 2.0 | 0.70| 0.30 | 0.02 | 0.02 |
| 3 | 0.4 | 1.3 | 2.0 | 0.70| < 0.01 | 0.10 | 0.02 |
| 4 | 0.5 | 1.3 | 2.0 | 0.70| < 0.01 | 0.10 | 0.02 |
### 2. Experimental
#### 2.1. Materials
The chemical compositions of the steels investigated in the study are shown in Table 1. Steels 1–3 contained 0.4 wt.% C, whereas Steel 4 was alloyed with 0.5 wt.% C. Alloys were designed using the commercial IDS® (Inter-Dendritic-Segregation) and JMatPro v8.0® software, to minimize the chemical inhomogeneity after casting, while still achieving requisite hardenability by adding adequate Mn (2 wt.%) and Cr (0.7 wt.%) and enabling low temperature deformation of austenite as well as low transformation temperatures. Also, a high level of Si (1.3%) was added in all the steels to prevent carbide precipitation during isothermal holding. Besides, varying contents of Mo, V and Nb were added to analyse their effect on the transformation kinetics as well as strengthening, although Mo (and also Nb) is known to hinder the kinetics of bainite transformation, thus resulting in a high fraction of untempered, high-carbon martensite, as reported by Kaikkonen et al. [12].
The materials for rolling were received initially in the form of rough rolled and homogenized (1250 °C, for 24 h) blocks of 45 × 150 × 180 mm, from which the decarburized layer was milled off, leading to a thickness of 38 mm. The blocks were then cut in three pieces of 38 × 50 × 180 mm prior to laboratory rolling experiments.
#### 2.2. Physical simulation studies
A series of physical simulation experiments were designed based on the idea of low temperature ausforming followed by isothermal holding at various temperatures in order to optimize the parameters that would
lead to an extremely fine size of bainitic laths, preferably nanostructured bainite, in a reasonable length of time, besides retaining a small fraction of finely divided retained austenite essentially as fine interlath films. The rough-rolled and milled 38 mm block of each composition was hot rolled down to a 12 mm thick plate for the preparation of specimens of dimensions Ø6 × 9 mm for conducting thermomechanical simulations on a Gleeble 3800 thermomechanical simulator. The ausforming temperature was selected carefully based on certain prerequisites, as follows. Firstly, it should lie in the bay between ferrite and bainite C-curves and prevent any strain-induced ferrite or pearlite transformation [12]. Secondly, the flow stress of austenite should not be very high, so that a reasonable level of deformation could be achieved with the available rolling loads in order to impart enough pancaking and a high dislocation density, thus leading to the formation of a large number of deformation bands for facilitating enhanced nucleation sites for subsequent bainite formation. The transformed bainitic laths, therefore, would not only be highly refined, but also randomized (low texture) thus imparting good toughness in the steel. Thirdly, on subsequent holding at a desired temperature (or during slow cooling), due to the medium-temperature ausforming, the kinetics of bainite transformation should be somewhat accelerated depending on the composition, thus enabling stabilization of a reasonable fraction of retained austenite by partitioning the carbon rejected from the growing bainite sheaves into the adjacent austenite [12]. Being a medium carbon steel, there is a likelihood of competition with the possible formation of carbides that can be considerably delayed by the presence of high silicon in the steel, but cannot be prevented for ever, and therefore, the time of holding becomes extremely important. Inadequate carbon in the finely divided austenite may also result in subsequent decomposition during final cooling, thus leading to the formation of hard, untempered martensite that may influence the toughness. The process of selecting the deformation temperature (500°C) was discussed in detail by Kaikkonen et al. [12].
The simulation schedule (see Fig. 2) comprised of three main stages; (1) reheating to 1000 °C for 3 min, cooling at 10 °C/s to 850 °C and holding for 15 s (to correlate with other deformation temperatures in the project), prior to faster cooling at 25 °C/s to the deformation temperature $T_{\text{def}} = 500$ °C, (2) deformation at $T_{\text{def}}$ to a strain of 0.6 at 0.5 s$^{-1}$ and subsequent cooling to isothermal holding temperature and 3) isothermal holding in the range 300–400 °C (275–375 °C for 0.5C-steel) in steps of 25 °C for 60 min followed by cooling to room temperature (RT). Cooling at a linear rate of 25 °C/s was well above the critical cooling rate (2 °C/s) thus preventing the austenite decomposition prior to reaching the $M_s$ temperatures. Critical cooling rates were determined using the CCT diagrams constructed using the commercial JMatPro v8.0 software. [30]
Fig. 1. Flowchart showing the applied methodology, along with the relations of different parts of the current study. The methods, their application and obtained results are denoted by the corresponding article sections (2A, 2B, etc.) describing them.
Fig. 2. Physical simulation test scheme conducted on a Gleeble 3800 TM simulator.
2.3. Laboratory rolling and cooling
Preliminary microstructures and hardness data obtained on the test samples from the physical simulation experiments were used for designing the thermomechanical processing schedules that were achievable based on the capabilities of the laboratory rolling mill as well as the furnaces. In order to obtain refined final structure, the prior austenite grain size was subjected to recrystallization controlled rolling in the high temperature regime, although the effect of prior austenite grain size on the refinement of the bainite was reported to be controversial. Lan et al. pointed out that the width of bainitic ferrite was not affected by PAGS [31], whereas Zhao et al. reported that refinement of PAGS refined the size of bainite [32]. On the other hand, Singh et al. reported that finer PAGS actually caused an increase in bainitic lath thickness [33]. Ausforming in the low temperature regime flattened the austenite grain structure and yielded high dislocation density, which caused an increase in the bainite nucleation rate as well as the hardness of bainite [9]. In effect, these processes influence the formation of packets, blocks, sub-blocks and bainite laths. In particular, low temperature ausforming provides refinement of bainite laths [5,10]. Rolling trials were done in a two-high, reversing laboratory rolling mill, equipped with water spray cooling facilities (see Fig. 1). While the diameter of both upper and lower rolls was Ø 250 mm, the maximum rolling load was 1 MN. The water cooling section comprised four nozzles, two of them side by side, above the run-out table and the other two side by side, below the run-out table. In the laboratory rolling experiments, rough rolled and milled 38
mm blocks of experimental steels were processed via two different processing paths (termed as AC and WC) including ausforming (see Fig. 3). The sample blocks for rolling were soaked at 1250 °C (for Nb-alloyed steels 2–4) or 1200 °C (for Steel 1) for 90 min prior to three hot rolling passes of 0.05, 0.22 and 0.26 strain thus finishing at 19 mm thickness at slightly above 1000 °C, followed by water spray cooling at ~20 °C/s down to an ausforming temperature of ~500 °C. After performing two ausforming passes at ~500 °C, either 1) free air cooling (AC) was carried out imposing an average cooling rate of ~0.5 °C/s down to the isothermal holding temperature of 350 °C, or 2) water spray cooling (WC) was performed at 20 °C/s to the isothermal holding temperature of 300 °C. The samples were subsequently transferred to a furnace maintained at the desired isothermal holding temperature for facilitating bainite transformation and finally cooled to room temperature either at ~0.1 °C/s by moving the AC samples out of the furnace, and covering them with a 25 mm thick high temperature insulating wool or at ~0.01 °C/s by switching off the furnace in the case of WC samples. Finally, the plates that were in the furnace were then taken out after 15–16 h at ~100 °C. A schematic of the rolling pass schedules is shown in Table 2.
2.4. Metallographic examination
Standard metallographic methods were used for preparing cross-section surfaces of the specimens, including finish grinding and polishing with 3 and 1 μm diamond suspensions, respectively, and etching with 2% Nital solution. Samples were examined for microstructures in a Zeiss Sigma field emission scanning electron microscope (FESEM) operated at an accelerating voltage of 5 kV and fitted with an InLens detector. Select specimens were polished with a colloidal silica (0.04 μm) solution for conducting measurements with an EDAX electron backscatter diffraction (EBSD) device, equipped with the FESEM, along with an energy dispersive spectroscopy (EDS). For estimating the phase fractions, X-Ray diffraction (XRD) measurements were carried out with a Rikagu Smartlab X-Ray diffractometer, operated with a Co-Kα source at a scanning rate of 7° min⁻¹ over the 2θ range of 45–130°. Besides XRD, phase fractions were estimated by a point counting method on the micrographs according to ASTM E 562 standard [34], similarly, as described by Kaikkonen et al. [12]. EBSD scans were conducted at an accelerating voltage of 15 kV with an aperture size of 120 μm, while the scanned area was approximately 440 × 440 μm. The prior austenite grain size and the block boundaries of the bainitic ferrite microstructures were reconstructed from the EBSD data using the MATLAB software equipped with MTEx toolbox [35]. Nishiyama–Wassermann (N-W) orientation relationship between FCC austenite and BCC ferrite was used for the reconstruction. Further details of the reconstruction technique are given elsewhere [36,37].
2.5. Mechanical properties
Vickers hardness was measured on all the specimens polished to metallographic finish using a test load of 10 kgf (5 kgf for physical simulation samples). In order to determine the tensile properties, i.e., yield strength (R₀.2), ultimate tensile strength (Rₘₜ), as well as uniform (Aᵤ) and total (Aₜ) elongations of the lab rolled plates, round specimens of the gauge dimensions ø6 × 40 mm length were prepared according to EN 10002-1 standard and tensile tests were performed in a Zwick Roell tensile testing device. For the eight steel plates (four compositions × two cooling conditions of AC and WC), three tensile specimens each were extracted along the rolling direction. Charpy V-notch impact toughness specimens of dimensions 5 × 10 × 55 mm were prepared in longitudinal direction according to the EN ISO 148-1:2016 standard and the through-thickness notch was machined in the transverse direction.
3. Theory and numerical modelling
3.1. Numerical rolling simulation
Earlier, a finite element method (FEM) model was developed at authors’ laboratory to simulate the roughing rolling, as described by Seppälä et al. [38]. In this study, the same model has been modified for use on the laboratory rolling mill. The Abaqus® finite element software (by Dassault Systèmes) was used for numerical simulation. Thermal material properties were obtained by fitting a parametric equation to the experimental data obtained from the physical simulation studies (Section 2 B) in the same way as with the previous study [39]. The mechanical material model is based on the Hensel-Spittel equation, which has been earlier used by Opela et al. [40] and Spigarelli and El Mehtedi [41] with minor modifications, as shown in Eq. (1).
\[ k_f = k_{f0} + a_1 \cdot e^{a_2 \cdot \varepsilon^{a_3}} \cdot \exp(-a_4 T) \cdot \exp(a_5 \varepsilon) \cdot (1 + \varepsilon)^{a_6 T} \cdot e^{a_7 T} \cdot T^{a_8} \cdot \exp(a_9 / \varepsilon) \]
(1)
where \( k_f \) is flow stress, \( a_i \) are fitting parameters, \( \varepsilon \) is strain, \( \dot{\varepsilon} \) is strain rate and \( T \) is temperature. Yield stress was included as a fitting parameter \( k_{f0} \) in the model.
The rolling model is two-dimensional and symmetrical with respect to the pass line and is based on the previous work done at the authors’ laboratory, as described by Ilmola et al. [25]. To extend the model, plane strain conditions were applied. Fig. 4 shows the rolling configuration and the element mesh. The slab was meshed with CPE4RT elements so that 12 elements were present through the slab thickness, as described in the Abaqus user manual [42]. The same element size was used at tangential direction on work roll surface. The work roll was created by combining the core (inner ring) with a halo (outer ring).
3.2. Phase transformations, heat conduction and transfer
Phase transformation model was fully coupled with heat Eq. (2), by adding the latent heat produced by the transformation during a time-step to the source term \( s \), as described in [43,26]
\[ \frac{\partial \rho c}{\partial t} T = \frac{\partial}{\partial x} \left( k \frac{\partial T}{\partial x} \right) + s \]
(2)
where $T$ is temperature, $x$ is the position in the plate from top to bottom direction. The values for thermal conductivity $k$ and specific heat $c$ were calculated as in [44,45] and density $\rho$ as in [46]. The temperature gradient on the boundary $\frac{\partial T}{\partial x} = h_{eff}/(T - T_{ext})$, was defined at each time step by applying effective heat transfer coefficient $h_{eff}$, as described in [47]. For water cooling, corresponding function $h_{eff}$ was used and the external temperature $T_{ext}$ was the temperature of the cooling water. In the current study $h_{eff}$ was found to be 20% higher than in the calibration study [47], most likely because the plate width was smaller and cooling caused by the water spray was more effective on the plate corners. For air and furnace cooling, boundary conditions corresponding to the thermal radiation and convection were applied with $h_{eff} = \sigma_{SB}\epsilon_{em}(T^4 + T_{ext}^4)^{1/2} + T_{ext}^2(T + T^4) + h_c$, where $\epsilon_{SB}$ is the Stefan-Boltzmann coefficient, value $\epsilon_{em} = 0.7$ was used for emissivity, and the term $h_c = 14.0$ was applied corresponding to convection for air cooling (for furnace $h_c = 0$). Cooling from the plate sides was calculated by including additional sink term in the heat equation corresponding to the radiative cooling from the sides with emissivity of 0.7. The heat equation was solved using Galerkin finite element formulation [48].
The transformation was estimated to start when $\sum \Delta t/\tau(T) = 1$, where $\tau(T) = K_{1/5}(A_{1/5} - T)^{-m/5}\exp(\frac{Q_{1/5}}{R(T+273.15)})$, as described in [27,49]. For kinetics after the onset, we tested two different transformation models: Kolmogorov-Johnson-Mehl-Avrami (KJMA) type model used earlier by Pohjonen et al. [27], and an Austin-Rickett (AR) type model described by Starink [17]. Both of the models can be derived from the extended volume concept from a more general formula [18], $d\chi/d\chi_{ext} = (1 - \chi)^{1+c}$, where $c$ is a so-called impingement parameter and $\chi_{ext}$ the extended volume fraction. The value $c = 0$ yields the KJMA model, $\chi_t = [1 - \exp(-k(t-t_0)^n)]\chi_{b,max}$, and $c = 1$ yields the AR model, $\chi_t = (1 - \frac{1}{1+k(t-t_0)^n})\chi_{b,max}$, where the temperature dependent rate parameter $k = K(A-T)^m\exp(\frac{Q}{R(T+273.15)})$, $n$ is a constant exponent and $\chi_{b,max}$ the maximum fraction of bainite that can form at given temperature. The differential form for both the models can be obtained by assuming that the transformation rate depends only on the transformed fraction and temperature. For the KJMA model the differential form is given by Eq. (3)
$$\frac{d\chi_b}{dt} = (\chi_{b,max} - \chi_b)\left[\ln\left(\frac{\chi_{b,max}}{\chi_{b,max} - \chi_b}\right)\right]^{\frac{n-1}{n}}nk$$
as proposed by Leblond et al. [19] and applied by Pohjonen et al. [27] to describe bainite formation for arbitrary thermal paths. For the AR model the differential form is given by Eq. (4)
$$\frac{d\chi_b}{dT} = \chi_b\left(\frac{\chi_{b,max} - \chi_b}{\chi_{b,max}}\right)\left(\frac{\chi_{b,max} - \chi_b}{\chi_b}\right)^{1/n}nk$$
For austenite to martensite transformation, the Koistinen-Marburger Eq. (5) was used,
$$\chi_m = \chi_{m,max}(1 - \exp[-\eta(T_{KM} - T)])$$
where the maximum martensite fraction $\chi_{m,max} = 1 - \chi_b$ for each time step. Martensite only forms when temperature is below the $T_{KM}$ temperature and the lowest temperature that the material position has experienced in the simulation earlier. The martensite start temperature depends on the previously formed bainite fraction, in consistency with [50], as described in the results section. The latent heat of transformation $\Delta s = \rho_v L(\frac{d\chi_b}{dt} + \frac{d\chi_m}{dt})$ was added to the source term $s$ of Eq. (2) for each time step, where latent heat $L$ is calculated as in [43–45,51].
4. Results and discussion
4.1. Microstructures from physical simulation experiments
FESEM microstructures obtained by physical simulation experiments (300°C holding) in the Gleeble are presented in Fig. 5 along with corresponding Vickers hardness (HV5) values as well as retained austenite (RA%) fractions, as labelled on the micrographs. In each steel, only partial completion of bainite formation was recorded by the dilatometer during isothermal holding at 300°C for 1 h (90 min for Steel 4). The same could be interpreted from the FESEM microstructures, which corroborated a significant fraction of retained austenite (13.3–18.8%) as well as a small fraction of high carbon fresh martensite formed during the final cooling from 300 °C to RT in Steels 2–4, as also revealed by inflexions in the dilatation curves. The hardness values of the steels varied in a narrow range of 500–525 HV5; the Mo-Nb-alloyed Steel 2 presenting the highest hardness owing to its relatively fine bainitic structure with finely distributed retained austenite (18.8%), and practically no granular bainite formation. The most complete bainitic reaction was observed in Steel 1, which also showed the lowest fraction of retained austenite (13.4%), and practically no discernible high carbon fresh martensite formation, presumably due to the lack of Nb-microalloying, as even 0.012 % of Nb microalloying in medium-carbon steels might have a tendency to precipitate at typical hot rolling temperatures [52], thereby preventing grain growth due to the pinning of grain boundaries. It should, however, be emphasized that in the absence of any driving force for precipitation, Nb is still able to suppress grain coarsening by solute drag effect [53]. On the other hand, Nb is known to delay the bainite formation and
yet result in refinement of bainitic ferrite [54]. As a consequence of relatively coarse prior austenite grain size in Steel 1, the retained austenite was blocky and somewhat coarser than observed in the Nb-microalloyed steels 2–4.
### 4.2. Numerical model parameterization
The mechanical material model, based on the modified Hensel-Spittel Eq. (1) is fitted to the experimental data described in [12], which was obtained by applying 0.6 strain at different strain rates 0.1, 1 and 10 s\(^{-1}\) as well as temperatures 500, 600, 700 and 800 °C. Table A.1 includes the obtained fitting parameters for steels 1, 2 and 4, for which the constitutive flow stress behaviours were evaluated earlier [12], and Fig. 6 shows a few examples of the experimental and fitted compression curves, measured at a strain rate of 1 s\(^{-1}\).
The bainite start (\(B_s\)) temperatures of the steels, which were used as the phase transformation model parameters \(A_{1\%}\) and \(A\), were calculated using the Van Bohemen’s equation for bainite start [55]. The other parameters, described in Section 3B, were fitted to the experimental data. The transformation onset parameters, \(K_{1\%}\), \(A_{1\%}\), \(m_{1\%}\), and \(Q_{1\%}\), for each steel are given in Table A.2.
In the case of model fitting for transformation kinetics, it was established that the AR model provided a better fit to the whole time-transformation data, while for the KJMA model, separate fits were required for the early and the later stages of transformation to achieve similar shape of the curve, as obtained experimentally. Although the total error in the numerical fitting for both of the models was roughly equal (even if no separate fits were made for the KJMA equation), the AR model systematically reproduced the slope of the latter part better without the need to do separate fittings for the earlier and later stages of transformation.
It is well known that the bainite transformation is limited by the incomplete transformation phenomena [56]. Both the mechanical [20] and chemical [57] effects stabilize the austenite against the formation of bainitic ferrite. To account for this effect, we fitted the maximum volume fraction of bainite that can form at each temperature by extrapolating the KJMA model that was fitted to the later stage of the transformation curve. The fitting was performed by varying \(\chi_{b,\text{max}}\) in Eq. (3) and minimizing the least squares of the residuals in comparison to the experimental data. The result of the fitting for steel 2 is illustrated in Fig. 7 (a).
The fitted maximum volume fractions of bainite at each holding temperature for the different steels are given in Table A.3. For the purpose of interpolating the data, so that it can be used in the coupled numerical simulations, the linear fit \(\chi_{b,\text{max}} = aT + b\) was used, since it provided a reasonable fit to the data (see Table A.4). It has been shown that at the low temperatures the mechanical stabilization limits the martensitic transformation [50]. Since the bainite transformation needs to displace the surrounding material, the mechanical stabilization also limits the bainitic transformation in a manner similar to the martensitic transformation [20,56]. On this basis, the maximum bainite fraction at a low temperature (\(\leq 300\)°C) was taken as 100 % - RA, where RA is the retained austenite, estimated using XRD measurements of the sample held at 300°C, followed by quenching to room temperature. In the case of Steel 1, there was some scatter in the estimated maximum bainite values, and for this reason we calculated an additional datapoint, i.e., the bainite start temperature, using the Van Bohemen’s equation [55].
Since the AR model provided a better fit to the data without the need to separately fit the model parameters for earlier and later parts of the transformation curve, it was chosen for describing the transformation behaviour in the coupled heat transfer, conduction and phase transforFig. 7. (a) Fitting of the later stage of the transformation curve using KJMA model along with the maximum fraction of bainite (dotted black line); Avrami plot for the fitting is shown in the inset. (b) the maximum bainite fractions as a function of temperature for steel 2. The dashed green line in (b) shows the total ferritic fraction transformed (100% - residual austenite (RA)) for the sample held for 1 h at 300 °C, followed by quenching to room temperature (For interpretation of the references to color in this figure legend, the reader is referred to the web version of this article.).
Fig. 8. Comparison of the fitted model (dashed lines) to experimental transformation data (solid line) for (a) steel 1, (b) steel 2, (c) steel 3 and (d) steel 4.
The phase transformation kinetic model parameters were fitted to the experimental data in the same way as described by Pohjonen et al. [27] for bainite transformation. The Koistinen-Marburger temperature $T_{KM}$ was determined from the experimental dilatometry measurements. The kinetic model parameters for each steel are given in Table A.5.
A comparison of the fitted model results to the experimentally determined data for isothermal holding in the thermomechanical simulation experiments, is shown in Fig. 8.
We observed that the martensite start temperature was lowered when bainite had formed. This is most likely caused by the mechanical and chemical stabilization of the austenite as shown by Van Bohemen [20,50]. Since the previously grown bainite is stronger than austenite, it hinders the growth of new martensite laths during cooling, and the carbon partitioning from bainitic ferrite stabilizes the remaining austenite [57]. In order to take in to account the stabilization phenomena in a simplified manner, we fitted a linear function to the data describing the martensite start temperature ($M_S$) dependence on the previously formed bainite fraction, as shown in Fig. 9. Since the Koistinen-Marburger temperature, $T_{KM}$, has similar dependence on the previous bainite fraction as the martensite start temperature $M_S$ [20], the dependence of $T_{KM}$ on the bainite fraction was calculated using the same linear trend as fitted for the $M_S$, but starting from the experimentally determined $T_{KM}$ value for the directly quenched austenite, i.e. for the case where no bainite had formed.
4.3. Laboratory rolling and subsequent cooling
Temperature data was collected from the numerical FEM simulations. The center line, quarter depth and the plate surface positions were tracked and the simulated temperature predictions were compared to the experimental temperature data obtained with a thermocouple located in the middle of the steel plate. Fig. 10 (a) shows the comparison
between the results during the second rolling pass. Two experimental results with the same setup are included.
The experimental data has been modified by including the temperature-time offsets to match the temperature at the time of roll contact exactly with FEM data in order to be able to compare the temperature rise during the rolling pass. The temperature increase during the rolling pass is similar for both the experimental cases and in the FEM simulation. The temperature drop in the interpass stage is faster in the experimental results. This could be due to some simulation issues caused by simplifications: The real plate is quite narrow, so the air-cooling from the plate sides can affect the result. This effect is not included in the 2D simulation. Also, the plate is in direct contact with initially room-temperature run-out table rolls during the interpass stages. Since the plate dimensions are small, the temperature drop caused by this contact could affect the result. The model is symmetrical with respect to the pass line, so this effect is completely ignored in the numerical simulation.
In the simulation, surface temperature drops radically (to $\sim 300^\circ$C) and then returns to almost the same temperature as middle and quarter depth. This drop in temperature can cause effects such as local martensitic transformations when rolling is performed at low temperatures. Transformation during rolling would cause the material to harden.
Fig. 11 shows the equivalent plastic strain $\bar{\varepsilon}^p = \int_0^t \sqrt{\frac{2}{3} \dot{\varepsilon}^p : \dot{\varepsilon}^p} dt$, which describes the cumulative plastic strain during the rolling passes [42]. On the left side of the figure both rolling passes are shown as a contour map with $\bar{\varepsilon}^p$ as output variable. Colour maps are configured so that blue is the starting value of $\bar{\varepsilon}^p$ and red is the maximum value during that pass. On the right side of the figure the $\varepsilon^{pl}$ values are shown as a function of position in plate thickness direction, at different locations. The thicker curves are at the end of each rolling pass and the thinner curves are obtained during the rolling pass.
The change of the prior austenite grain (PAG) aspect ratio was compared to the FEM plastic strains $e_{xx}$ and $e_{yy}$ in the middle of the steel plate. To see the effect of final rolling passes, the Prior Austenite Grain (PAG) structures were analysed. First, the PAG structure of the samples, which were quenched before conducting the final rolling passes in non-recrystallization ($T_{NR}$) regime, were analysed. Then the PAG structures of the samples that were completely rolled, including the $T_{NR}$ regime, were analysed. A grain size calculation tool that has been described in detail by Koskenniska et al. [58] was used to estimate the mean linear intercepts in rolling (x) and normal (y) directions, as shown in Fig. 10 (b). The grain structure prior to rolling was equiaxed, and after rolling, the mean linear intercepts, $L$, of the grains were $L_{1x} = 27.7$ µm and $L_{1y} = 14.0$ µm. Since the strains obtained from the FE simulations, $e_{xx} = 0.43$ and $e_{yy} = -0.45$ are related to the average elongation of the material by $e_{xx} = (L_{1x} - L_0)/L_0$ and $e_{yy} = (L_{1y} - L_0)/L_0$, the average aspect ratio of the grains after rolling is $L_{1x}/L_{1y} = (1 + e_{xx})/(1 + e_{yy})$. The experimentally determined mean linear intercepts give an aspect ratio $L_{1x}/L_{1y} = 2.0$, while the FE simulation strains yield the aspect ratio $(1 + e_{xx})/(1 + e_{yy}) = 2.5$. The difference between the experimental and the simulation results is most likely due to the fact that in reality the material has been able to expand in the transverse width direction, while it was constrained in the two-dimensional FE simulations.
The coupled heat conduction and phase transformation model was applied for designing and simulating a water-cooling schedule for the thermomechanical processing in order to achieve a fully lath-like lower bainitic microstructure in the centre of the plate. A comparison of typically applied cooling paths, including deformation at 500 °C, in physical simulation (parameterization) and laboratory rolling (validation) prior to isothermal holding at 300 °C are shown in Fig. 12. A remarkable difference in the cooling path after the deformation was recorded in AC compared to that of physical simulation and hence, microstructures related to those two experiments were not expected to be comparable. However, in the WC experiment, the cooling path in the physical simulation could be quite accurately adapted in the laboratory scale rolling by using the numerical model for designing the cooling schedule.
The numerically simulated temperature and bainite kinetics at the mid-thickness of the air-cooled plates are shown in Fig. 13. The furnace temperature is depicted by the dashed black horizontal line.
The numerically simulated temperature and the bainite kinetics during water cooling were calculated at different positions in the steel plate. The calculated values at upper surface, upper quarter- and mid-thickness of the water-cooled plates, in comparison to the experimentally measured temperatures in the middle of the steel plate are shown in Fig. 14. The heat transfer during the time interval between the water sprays emerged higher at lower temperature ($\leq \sim 320$ °C). This is because of the fact that at the lower temperature, the water was not completely evaporated on the upper surface immediately, and the shielding vapour layer became thinner at sufficiently low temperature. For this reason, the heat transfer below this temperature was significantly higher on the upper surface than on the lower surface, where the water falls off immediately after being exposed to the water spray, as described in [47].
The numerically simulated bainite kinetics and temperatures in the middle of the plate during holding in the furnace for the first 1 h, as well as the experimentally measured temperatures for the four steels, are shown in Fig. 15. The numerically simulated temperature rise due to the latent heat, released during the austenite to bainite transformation, is in agreement with the experimentally measured values, although it seems to be systematically somewhat higher than the experimental values. The furnace temperature, shown by the black dashed line, was set above the $M_S$ temperature.
The numerically simulated martensite and bainitic ferrite fractions after the furnace holding and after the slow cooling to room temperature for the water cooled plates are shown in Table 3. Only less than 3% of bainite formed during the water cooling. Hence, most of the bainite
| Steel | BF sim. | BF exp. | Martensite sim. | Martensite exp. |
|-------|---------|---------|-----------------|-----------------|
| 1 | 79.5 | 61 | 16.0 | 21 |
| 2 | 80.1 | 61 | 11.2 | 20 |
| 3 | 69.7 | 74 | 20.6 | 9 |
| 4 | 74.7 | 77 | 18.0 | 5 |
is almost fully formed during holding in the furnace and during the slow cooling after the furnace has been switched off. Relatively small amounts of bainite and martensite formed during the slow cooling of the furnace to room temperature. However, both the bainite and the carbon-enriched martensite that form at low temperatures are much finer and harder than the phases that form before and during the furnace holding, and for this reason they may have an important effect on the mechanical properties. This seems to be the reason for higher hardness of steel 4 compared to steel 3, as both steels have roughly equal amounts of bainite and martensite, but in the case of steel 4, larger amount of bainite and martensite form at lower temperatures.
A comparison with the experimentally observed phase fractions in the middle of the plates shows that for Steels 1 and 2, the numerical model overestimated the bainite fraction. The most likely explanation is that during furnace holding, the temperature rose due to the latent heat release (see Fig. 15), causing a relatively higher temperature than...
the isothermal holding temperature in the physical simulation (Gleeble) experiments, as shown in Fig. 8. Although at higher temperature, the maximum amount of bainite that can form is lower, the current model would predict the bainite to grow again, when the steel is slowly cooling, since $\chi_b$ is a function of temperature only. At higher temperature, the bainite formation leaves the untransformed austenite more like blocky-shaped, while in the case of transformation at lower temperature, the austenite is contained in thin films between the bainite platelets. This effect can be seen clearly for steel 2 by comparing Figs. 16 (d) to 5–2. It has been shown that due to a lower tendency of carbide formation in the blocky regions than in the films at the similar temperatures (400 °C), the blocky regions are more stable than the films [59]. In order to take these effects into account in future, a more detailed physically based model, which couples bainite formation, carbon partitioning, diffusion and precipitation, would be needed.
The calculated martensite fractions for steels 3 and 4 are higher than observed in the middle of the plates. Also, this may result from underestimation of the effect of chemical stabilization in the model in a similar way, and due to the non-uniform carbon distribution in the remaining austenite [60]. It should also be noted that there is always a variation in the experimentally determined local phase fractions, depending on where the microscope image is recorded, which may also account for some differences between the numerical and experimental results in both the experimental microstructures used in the model calibration, as well as the observed microstructures of the water- and air-cooled plates. To quantify how large this variation can be, we investigated different locations in the physical simulation samples for steel 2 using the SEM, which were later used for model calibration (Fig. 8). The standard deviation for the bainitic ferrite fractions in different microscope images of in the center of the plate was ±5.1 % units in average.
### 4.4. Microstructures of laboratory rolled plates
FESEM images of the microstructures of the laboratory rolled plates are presented in Fig. 16. Evolution of some of the microstructural features can be understood with the aid of realistic bainite formation temperatures including the temperature rise due to the latent heat, and accounting for the faster diffusion rates at higher temperatures.
It should be emphasized that the free air cooling (AC) from 500 to 350 °C took about five minutes at an average rate of ~0.5 °C/s (see Fig. 12) and thus, some amount of phase transformation occurred during continuous cooling prior to the start of furnace holding, as shown in Fig. 13. Most notably, for steel 1, about 30 % of bainite had already formed during the continuous AC thermal path before the plate was placed in the furnace. On the other hand, in the WC thermal path, the bainitic phase transformation does not occur to a noticeable extent prior to the start of isothermal holding in the furnace due to a significantly higher cooling rate for all the steels, as shown in Figs. 14 and 15. In the case of air-cooled plates, carbon partitioning from the upper bainite at higher temperature stabilized the remaining austenite. Also, some amounts of lower bainite and martensite formed during the subsequent slow cooling to room temperature following holding in the furnace. This is evident from Fig. 16 (a, c, e and g), which showed that all the microstructures obtained in AC condition were phase mixtures of a number of ferritic microconstituents formed in different temperature windows, including granular bainite (350–500 °C), coarse lath-like bainite (325–400 °C), fine lath-like bainite (300–325 °C) as well as high-carbon martensite (< 300 °C). BF in Fig. 16 refers to bainitic ferrite, M to martensite, RA to retained austenite block or film and M/A to martensite-austenite constituent.
The difference in coarseness of bainitic ferrite was most obvious in V-Nb-alloyed steels 3 and 4, while Steel 2 with the additions of Mo and Nb showed least differences, when comparing the microstructures in AC and WC conditions. For the air-cooled plates, the coarseness of the bainite is mainly due to the higher temperature during furnace holding (see Fig. 13) as compared to water-cooled plates (see Fig. 15), and to a lesser extent because of the slow cooling rate, except for steel 1 where about 30% of bainite formed already during the slow air cooling. Microstructures in WC conditions (Fig. 16 b, d, f and h) exhibited remarkably higher fractions of finely refined bainitic structure than in AC conditions, though similar ferritic (including coarse) constituents were found in the WC condition also, as noticed in the AC conditions. The ferritic constituents and its sizes are discussed in detail in chapter 4E,
both in terms of stability of the retained austenite, as well as the ferrite block sizes measured from the EBSD data. Numerical calculations suggest that for the water-cooled plates, some amount of transformation occurred also during slow cooling, following the switching off of the furnace. However, Sun et al. [61] reported that V carbides might form at 500 and 520 °C in high-carbon (0.8 wt.% C) steels, thus resulting in shorter incubation time of bainite formation, as V carbides act as nucleation sites for bainite. But the plate size of bainitic ferrite did not significantly differ from the sample in which carbides were not introduced. Also, compared to Mo-Nb alloyed steel, V-Nb alloying did not restrict grain growth exceptionally [62].
4.5. Mechanical properties
Mechanical properties measured on the laboratory rolled steels in both AC and WC conditions in terms of yield strength ($R_{p0.2}$), ultimate tensile strength ($R_m$), uniform elongation ($A_u$), total elongation ($A_t$), Charpy V impact toughness (IT) and Vickers hardness together with the retained austenite fraction (RA) are presented in Table 4. The highest ultimate tensile strength $R_m$ was recorded in Steel 4, reaching as high as 1910 MPa in AC and 1800 MPa in WC, owing to its relatively higher C content (0.5 wt.% C). Interestingly though, the $R_m$ values were generally higher in the AC condition rather than in the WC condition despite the greater extent of fineness of WC microstructures, except in the case Steel 2, which showed comparable $R_m$ (1570 MPa) as well as Vickers hardness (480 HV10) regardless of cooling path and higher $R_{p0.2}$ in WC condition (1070 MPa) in comparison to the AC condition (870 MPa). However, the lower $R_{p0.2}$ in the AC condition in Steel 2 is compensated by relatively higher uniform and total elongations (11.0% and 16.5%, respectively) compared to the WC condition (5.3% and 13%, respectively).
Steel 2 possessed similar microstructures irrespective of the cooling path (Fig. 16 (c) and (d)), which could explain the similarity in tensile strength and hardness. As a first impression, it may seem surprising that
even the hardness of Steel 2 was at the same level regardless of the cooling path. However, this observation can be understood by comparing the transformation during thermal cycles of the air-cooled plate (Fig. 13 (b)) and the water-cooled plate (Fig. 15 (b)). The resulting microstructure in the WC plate included both the coarse bainite that formed above 325 °C as well as the fine bainite that formed at lower temperatures. In the air-cooled plate of Steel 2, noticeable fraction of bainite (Fig. 13 (b)) forms below 360 °C, during the slow cooling to room temperature and for this reason, the microstructures and the hardness of the two samples are relatively similar.
Despite the existence of coarse bainitic features (see Fig. 16 (g)) and lower Vickers hardness of Steel 4 (0.5C-steel) in AC condition compared to that of WC condition (Fig. 16 (h)), the ultimate tensile strength ($R_{m}$) was surprisingly higher in AC condition. The same was true for the uniform elongation ($A_{u}$), though the WC condition displayed higher yield strength ($R_{p0.2}$) and total elongation ($A_{t}$) for this steel. To further investigate the microstructures of Steel 4, EBSD data was utilized to determine the average size of the ferritic bainite blocks, which were the regions delimited by high angle (≥ 15°) boundaries [63,64]. Long et al., [65] concluded that lower bainite has lower tensile strength and higher impact toughness than upper bainite, which was also true in the result of this study in terms of tensile strength.
Microstructures of Steel 4 in different conditions observed with FE-SEM deviated a lot from each other and hence, EBSD measurements
Table 4
Mechanical properties of different steels in AC and WC conditions.
| Steel Cond. | $R_{p,0.2}$ [MPa] | $R_m$ [MPa] | $A_e$ [%] | $A_t$ [%] | IT [J / cm$^2$] | Hardness [HV10] | RA [%] |
|-------------|------------------|-------------|-----------|-----------|----------------|-----------------|-------|
| | | | | | -20°C | 20°C | |
| 1 AC | 790 ± 60 | 1740 | 9.1 | 9.9 | NA | NA | 480 ± 3 | 21 |
| 2 AC | 870 ± 30 | 1570 ± 5 | 11.0 | 16.5 | NA | NA | 480 ± 8 | 20 |
| 3 AC | 760 ± 15 | 1630 ± 20 | 11.3 | 14.9 | NA | NA | 477 ± 6 | 21 |
| 4 AC | 820 ± 10 | 1910 ± 5 | 7.9 | 8.9 | NA | NA | 554 ± 8 | 23 |
| 1 WC | 1010* | 1600 ± 10 | 6.3 | 11.8 | 12.0* | 24.5 ± 3.7 | 469 ± 5 | 19 |
| 2 WC | 1070 ± 40 | 1570 ± 10 | 5.3 | 13.0 | 12.0* | 25.0 ± 2.4 | 480 ± 4 | 19 |
| 3 WC | 930 ± 20 | 1500 ± 2 | 5.4 | 12.8 | 12.0* | 21.5 ± 2.0 | 513 ± 7 | 17 |
| 4 WC | 960 ± 20 | 1800 ± 5 | 5.5 | 11.7 | 11.0* | 14.0 ± 3.3 | 576 ± 7 | 18 |
* Only one measurement.
were carried out to understand the differences. Inverse pole figures and corresponding bainitic ferrite block size distribution (ECD) extracted from the EBSD data of Steel 4 samples both from physical simulation as well as in AC and WC conditions are shown in Fig. 17. More than 50% of the scanned area in physical simulation sample was covered by ferrite blocks with size of $\leq 2 \mu m$, whereas in AC sample, approximately 50% of the area was covered by blocks of $\leq 10 \mu m$. However, it was difficult to distinguish the 50% limit for WC sample. Anyhow, it was obvious that the block size distribution of WC samples should be considered closely similar to that of the result of physical simulation sample because of similarity of processing (See Fig. 13). In general, there is a marginally high fraction of coarse blocks in AC sample (10% greater than 20 $\mu m$) compared to the WC sample (5% are greater than 20 $\mu m$). Nevertheless, mechanical behaviour could be related to microstructures not only due to the fineness of the bainitic ferrite laths, but also the high tensile strength originated from the fineness of the blocks of bainite [13], while the finer lath size increased the yield strength, hardness and total elongation. According to Bhadeshia [56], finer block size also improves toughness.
In general, retained austenite contents were slightly higher in air cooled (20–23%) samples rather than in water cooled (17–19%) samples, which could be a consequence of higher bainite formation temperature of the air cooled samples. Nevertheless, in steels 1 and 2 the difference was only 1–2%, whereas in steels 3 and 4 the difference was 4–5 %. However, the morphology seemed to be more blocky-shaped in the air cooled samples (Fig. 17) than in the water cooled samples, except Steel 4, which probably could stabilise more austenite than other steels due to its higher carbon content. The retained austenite fractions of water cooled samples were actually very close to the values of the Gleeble samples isothermally held at 300 °C, which was also not surprising, as the processing routes as well as the microstructures were, in general, quite similar. These results correlated well with those of Zorgani et al. [6], who also reported that ausforming at 600 °C and subsequent isothermal holding at above 350 °C led to less stable and more blocky retained austenite compared to that of lower temperature holding.
The role of retained austenite on the tensile properties was somewhat controversial; in AC samples of steels 1 and 4, higher RA% resulted in lower uniform and total elongations in comparison to the high elongation values recorded for the AC samples of steels 2 and 3, Table 4. Generally speaking, retained austenite content and its influence on enhancing strain hardening capacity have been considered as the main contributor to the ductility as well as transformation induced plasticity (TRIP) effect of bainitic steels. It was found by Garcia-Mateo and Caballero [66] that the chemical composition of the retained austenite contributed to the stability of the austenite more than its morphology, while they also reported that too stable retained austenite did not guarantee good results. Other than that, microalloying elements like Nb and V have been earlier found to enhance the TRIP effect by hindering the autocatalytic propagation of strain-induced martensite due to relatively higher yield strength of retained austenite, yet the effect was not significant [67], in agreement with the findings of this study. However, as AC samples presented better uniform elongation than WC samples, it could be concluded that the microstructure of AC samples provided a better TRIP effect [68], despite the coarseness of the bainitic ferrite or retained austenite.
5. Summary and conclusions
The thermomechanical processing comprising of ausforming at 500 °C and subsequent cooling to the isothermal holding temperature in the bainitic region, corresponding to coiling, were physically simulated for four high-Si, medium carbon steels. Numerical models for deformation and phase transformation were fitted to the physical simulation results and fully coupled with the heat conduction and transfer model. The incomplete reaction phenomenon was included in the model by determining the maximum bainite fraction for different temperatures. The effect of bainite on lowering the martensite start temperature was observed and included in the phase transformation model in a simplified manner.
Experimental laboratory rolling, the subsequent air and water cooling, holding in furnace, as well as slow cooling to room temperature were simulated numerically. The rise in simulated temperature during the rolling pass corresponded well to the experimental data. Using the fully coupled phase transformation-heat conduction model, a water-cooling schedule was designed and experimentally realized to produce (ultra)fine structured bainite. The rise in simulated temperature due to transformation latent heat release corresponded well to the experimental measurements. The slow cooling to room temperature, where the fraction of untransformed austenite decomposes into bainite and martensite, was numerically simulated.
The models provide a reasonable agreement with the prior austenite grain size and shape and phase evolution during cooling to the extent that it provides useful simulation tool for designing and interpreting the results from thermomechanical processing. The fitted rolling model could be used for virtual experimentation and design of the rolling practice and controlling the amount of cumulated plastic strain as well as flattening of the austenite grains. The fitted phase transformation model allows to quantitatively control the formation of upper and lower bainite as well as martensite during cooling. In future, a focused study on the effect of different amounts of plastic strain and strain rate at different temperatures on the phase transformation model would be needed in order to construct a model that takes these effects in to account, and thus enable a tool for complete virtual experimentation of the whole process in a coupled way. In the current study, the numerical modelling enabled the design of cooling strategy to avoid formation of coarse grained upper bainite or martensite in real water spray cooling in the middle of the plate, leading to the formation of the desired fine structured bainite during the furnace holding.
Out of the four investigated steels and the processing routes it was determined that Nb+V alloyed steel 3 was the most optimal in respect of achieving the desired ultrafine structured bainite following ausforming and controlled water cooling.
Lower bainite formation temperature in the WC condition compared to the AC condition not only refined the bainite in terms of block size, but also facilitated an increased fraction of bainite and consequently decreased fraction of retained austenite (20–23% vs. 17–19%) and martensite, as expected. However, the effect of the refinement of the bainitic ferrite on the mechanical properties could not be unambiguously addressed, as the fractions of different phases changed as well.
The computational phase transformation model could be further improved in future by considering the chemical and mechanical stabilization of austenite by detailed microstructure models, where local strains, diffusion fields and precipitation are calculated. Such improvements could improve the model prediction especially during the slow cooling to room temperature. Numerical hot rolling simulations could be improved by considering a complete three-dimensional model instead of the two-dimensional model.
**Data availability**
The raw/processed data required to reproduce these findings cannot be shared at this time as the data also forms part of an ongoing study.
**Declaration of Competing Interest**
The authors declare that they have no known competing financial interests or personal relationships that could have appeared to influence the work reported in this paper.
**Acknowledgements**
European commission funded this study under RFCS contract RFCS-2015-709607. A part of the funding of this research activity under the auspices of Genome of Steel (Profi3) project through grant #311934 by the Academy of Finland is gratefully acknowledged. Authors also sincerely acknowledge Mr. Jussi Paavola for conducting the laboratory rolling experiments and holding discussions, Mr. Juha Usitalo for carrying out the physical simulation experiments on the Gleeble simulator and Mr. Tun Tun Nyo for the sample preparation and the testing of the mechanical properties.
**Appendix A**
Fitted model parameters and related data
**Table A1**
Fitting parameters for the Hensel-Spittel Eq. (1).
| Parameter | Steel 1 | Steel 2 | Steel 4 |
|-----------|-------------|-------------|-------------|
| $k_{10}$ | 75.9921 | 74.8777 | 74.0779 |
| $a_1$ | $3.8042 \times 10^3$ | $3.8042 \times 10^3$ | $3.8101 \times 10^3$ |
| $a_2$ | $7.8745 \times 10^{-1}$ | $8.4501 \times 10^{-1}$ | $8.3137 \times 10^{-1}$ |
| $a_3$ | $-8.6206 \times 10^{-2}$ | $-2.4784 \times 10^{-2}$ | $-8.7507 \times 10^{-2}$ |
| $a_4$ | $2.3329 \times 10^{-3}$ | $1.7331 \times 10^{-3}$ | $1.8650 \times 10^{-3}$ |
| $a_5$ | $-3.0312 \times 10^{-1}$ | $-2.7991 \times 10^{-1}$ | $-2.1974 \times 10^{-1}$ |
| $a_6$ | $-3.0527 \times 10^{-3}$ | $-3.0203 \times 10^{-3}$ | $-3.2804 \times 10^{-3}$ |
| $a_7$ | $2.1411 \times 10^{-4}$ | $1.1025 \times 10^{-4}$ | $2.2418 \times 10^{-4}$ |
| $a_8$ | $9.2849 \times 10^{-2}$ | $4.5247 \times 10^{-2}$ | $5.5546 \times 10^{-2}$ |
| $a_9$ | $-3.2607 \times 10^{-5}$ | $-4.7384 \times 10^{-3}$ | $-1.8452 \times 10^{-3}$ |
**Table A2**
The bainite transformation onset parameters for different steels.
| Steel | $K_{1\%}$ | $A_{1\%} \text{[°C]}$ | $m_{1\%}$ | $Q_{1\%} \text{[kJ]}$ |
|-------|-----------|----------------------|-----------|---------------------|
| 1 | $7.30 \times 10^{-3}$ | 482 | 0.50 | 58.17 |
| 2 | $1.71 \times 10^{-1}$ | 459 | 0.56 | 44.75 |
| 3 | $1.60 \times 10^{-2}$ | 481 | 0.50 | 51.47 |
| 4 | 1.33 | 463 | 0.50 | 33.41 |
**Table A3**
Maximum bainite fractions at different holding temperatures.
| Steel | Temp. [°C] | 300 | 325 | 350 | 375 | 400 | 482 * |
|-------|------------|-----|-----|-----|-----|-----|-------|
| 1 | | 0.88| 0.77| 0.68| 0.71| 0.75| 0 |
| Steel | 2 | | | | | | |
| Temp. [°C] | 300 | 325 | 350 | 375 | 400 | |
| $\chi_{b,\text{max}}$ | 0.85 | 0.68 | 0.57 | 0.46 | 0.36 | |
| Steel | 3 | | | | | | |
| Temp. [°C] | 300 | 325 | 350 | 375 | 400 | |
| $\chi_{b,\text{max}}$ | 0.87 | 0.8 | 0.65 | 0.47 | 0.46 | |
| Steel | 4 | | | | | | |
| Temp. [°C] | 275 | 300 | 350 | 375 | | |
| $\chi_{b,\text{max}}$ | 0.83 | 0.68 | 0.45 | 0.23 | | |
* Calculated using the Van Bohemen equation for bainite start [55].
**Table A4**
Linear fit parameters of $\chi_{b,\text{max}} = aT + b$, obtained for each steel, the $R^2$ value of the fit and the maximum bainite fraction (100 % - RA) used in the model for temperatures below isothermal holding experiments.
| Steel | $a$ | $b$ | $R^2$ | 100 % - RA |
|-------|-------------|-------------|---------|------------|
| 1 | $-4.400 \times 10^{-3}$ | 2.268 | 0.800 | 86.6 |
| 2 | $-4.800 \times 10^{-3}$ | 2.278 | 0.988 | 81.2 |
| 3 | $-4.600 \times 10^{-3}$ | 2.260 | 0.949 | 82.7 |
| 4 | $-5.720 \times 10^{-3}$ | 2.407 | 0.985 | 81.3 |
**Table A5**
The transformation kinetic parameters for AR and Koistinen-Marburger models.
| Steel | $K$ | $A \text{[°C]}$ | $m$ | $Q \text{[kJ]}$ | $n$ | $T_{KM} \text{(°C)}$ | $\eta$ |
|-------|------------|-----------------|-----|-----------------|-----|----------------------|-------|
| 1 | $2.738 \times 10^{-1}$ | 482 | 1.0 | 47.62 | 1.782 | 285 | 0.011 |
| 2 | $1.123 \times 10^{-3}$ | 459 | 5.0 | 116.6 | 2.083 | 298 | 0.011 |
| 3 | $9.782 \times 10^{-3}$ | 481 | 1.0 | 31.70 | 1.951 | 295 | 0.011 |
| 4 | $1.666 \times 10^{-2}$ | 463 | 1.0 | 33.41 | 1.860 | 270 | 0.011 |
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Citrus College Automotive Technology Program Receives $10,000 Donation
GLENDORA - For the third consecutive year, the Citrus College Automotive Technology program received a $10,000 donation from the Greater Los Angeles New Car Dealers Association (GLANCDA).
Founded in 1907, GLANCDA is a philanthropic organization of factory-franchised dealers that provides educational assistance to communities in Los Angeles County.
“GLANCDA is proud to support Citrus College’s robust auto tech program,” said Bob Smith, GLANCDA’s executive director. “We are thrilled that this donation will help the college’s talented and hard-working students move one step closer to a successful career in automotive repair.”
Citrus College’s Automotive Technology program offers students a choice between two associate degrees and six certificates. The programs offered include an Associate of Science in Automotive Technology and an Associate of Science in Medium and Heavy-Duty Diesel Truck Technology. Certificate options include automotive service, diagnosis and repair - master technician and clean energy and vehicle electrification technology, among others.
The program also allows full-time employment as an entry-level technician during a student’s second year of training. Certified by the Automotive Service Excellence (ASE) Education Foundation, automotive technology has six full-time instructors who have worked in the automotive industry and are ASE master technicians.
“I am grateful to GLANCDA for their generous donation, which will have an enormous impact on the students in our automotive technology program,” said Dr. Geraldine M. Perri, superintendent/president of Citrus College. “I also want to commend our outstanding faculty, who have worked so hard to maintain this program’s outstanding reputation.”
The automotive technology program plans to use the grant funds to purchase new laptops and vehicle communication interfaces that will improve the program’s ability to connect to vehicles for diagnostics and network communication validation across all lab facilities. Ultimately, the improvements will better prepare Citrus College students to work in new car service centers.
“The Board of trustees wishes to thank GLANCDA for this donation and its longstanding support of Citrus College’s Automotive Technology program,” said Dr. Patricia A. Rasmussen, president of the Citrus Community College District Board of Trustees. “A gift like this makes it possible for students to have access to affordable, high-quality education that can lead directly to job placement.”
For more information about the college’s automotive technology program, visit www.citruscollege.edu/academics/programs/auto.
Full Street Closure Of Elwood Ave. At Railroad Crossing in Glendora
GLENDORA - Crews will be fully rebuilding the railroad crossing at Elwood Ave. in the city of Glendora, as part of the 9.1-mile Foothill Gold Line light rail project. This work requires a full closure of Elwood Ave. at the railroad crossing for approximately 3 months. From Monday, February 15th and continuing daily thru May 15th, 2021, Elwood Ave. will be fully closed to all traffic (vehicular and pedestrian) at the railroad crossing 24 hours a day / 7 days a week. Route 66 (just south of the crossing) and Lemon Ave. (north of the crossing) will remain open and accessible by way of detour routes, see map below.
Crews plan to work daily during double shift hours of 7:00 AM – 12:00 AM (Midnight), Monday - Saturday. Occasional longer work hours and construction on Sundays may be performed during the closure period.
Access to homes and businesses on Elwood Ave. within the closure area north and south of the railroad crossing will be maintained at all times. A detour route (see map) will be in place during the closure and signage will be posted to direct motorists and pedestrians.
Elwood Ave. will be fully closed to all traffic at the railroad crossing between Route 66 and Lemon Ave. Lorraine Ave. (northbound and southbound) will serve as the main detour route. Route 66 (eastbound and westbound) will remain open to all traffic. Lemon Ave. (eastbound and westbound) will remain open to all traffic.
Two More Emanate Health Physicians Named “Top Doctors” in Los Angeles
COVINA - Emanate Health Chief Medical Officer, Gurjeet Kalkat, MD, a pulmonologist by training, and Emergency Department physician, Kevin Hua, DO, of Emanate Health Inter-Community Hospital, have been named “Top Doctors” in the region by the Los Angeles Business Journal.
“Dr. Kalkat and Dr. Hua have both been on the front lines of Emanate Health’s response to the COVID-19 pandemic and have done a remarkable job,” said Rob Curry, chief executive officer of Emanate Health. “Dr. Kalkat has overseen our clinical response to the coronavirus including our pharmacy, laboratory and patient treatment. Dr. Hua faced the virus head on by treating patients in our Emergency Department during the height of the pandemic.”
The two doctors were selected from a field of approximately 150 physicians in 12 disciplines of focus from throughout Southern California based on their “good standing, reputation, leadership and success,” among other factors.
For four years, the Los Angeles Business Journal has recognized “Top Doctors” from health systems like Cedars-Sinai, UCLA Health, City of Hope, Kaiser Permanente, Keck Medicine of USC and Children’s Hospital Los Angeles, to name a few, in a special edition that has approximately 20,000 subscribers in the region.
Dr. Kalkat and Dr. Hua are also members of a select group of Emanate Health physicians that have been named “Top Doctors,” including Dr. Fahed Bitar in Cardiology, Dr. Augusto Cigliano in Emergency Medicine, Dr. Claudia Munoz in Neurology, Dr. Ankur Patel in Orthopedics and Dr. Edward Yangchitnob in Women’s Health.
“The selection of the two physicians helps to reinforce our mission: Emanate Health exists to help people keep well in body mind and spirit by providing quality health care services in a safe, compassionate, environment,” Curry said. “I applaud Dr. Kalkat and Dr. Hua for lending their hands, minds and hearts to deliver exceptional health care to our patients during these challenging times.”
West Covina Was Originally Called Pumpkin Center 1903-1908
The Beginning – 1903
In 1903 West Covina (WC) was essentially a huge area of land, about 72,000 acres, with natural vegetation. Only about 50 people inhabited what is now called WC, and most were attempting wheat and barley farming near what is now Azusa and Francisquito. No names are known for the few families who were living in WC at the time of 1903. To the north and east, Covina was a thriving, progressive town as it was on relatively high ground known then as the Highlands. This situation made sense since the creek or “Wash” that ran through low elevation WC flooded every year due to water runoff from the San Gabriel Mountains. Other than the few weeks a year that WC flooded it was hot, dry, and not suitable for much of any type of farming except cattle ranching.
All of this changed in 1903 when brothers, Max and Robert Dancer purchased land from E. F. “Lucky” Baldwin in Azusa. The land was located at the corner of what is now Merced and Orange. Part of their land is now Edgewood School. Little did the Dancer brothers know that they were about to birth a premier agricultural community to later be followed by an upscale suburban city of over 110,000 in population.
The Well – 1904
In 1904 the Dancer brothers succeeded in digging and establishing a water well on their newly purchased land. Almost immediately after the well’s discovery, a small group of entrepreneurial families bought land and settled near the water well. Their names were Payne, Bender, Robinson, Larsen, Maxson and Hurst. Exactly who the Dancers were and where they came from is unknown. It is generally believed that they highly suspected they could find water at the location of their land prior to their purchase. Although there are romantic tales of finding water with a forked “water stick” called a divining rod, the way most water wells were found was by red and green vegetation growing over a water table or spring. Water from underground will seep to the surface and spur plant growth. The Dancers saw green in the form of a pumpkin! Once the water was found the new settlers and some old ones pooled their money and started a company called the “La Puente Cooperative Water Company”. The purpose was to buy a steam pump to bring 120 inches of water a day to the surface so 200 acres could be irrigated.
The Trenches: 1904 – 1905
To irrigate the acreage around the well, trenches were dug to carry the water. Pumpkins were planted between the trenches and spawned the name, Pumpkin Center.
The Priceless Pumpkin – 1908
Farmers are not a picky bunch! If it will grow and someone will buy it, they’ll plant it. Just how the “first farmers” knew that pumpkins were so profitable is anyone’s guess. That said, thousands of pumpkins were grown and sold in WC. Some other crops like potatoes, beans, and wheat would grow in the rich, alluvial soil of WC, but the first farmers became rather wealthy by planting pumpkins. What happened to the pumpkin patch? The early WC farmers later found that walnuts paid better!!
Article and photos courtesy of Forest Tennant, Historical Society of West Covina
Looking for Love in 2021?
5 Tips for Successful Online Dating
Don’t continue to treat water. Take proactive steps now to date online with confidence.
Tiring out online dating for the first time or frustrated by the experience?
Below are five online dating tips from Andrea McGinty, premier dating expert and founder of 33 Thousand Dates, a coaching platform designed to help millennial and Gen X women and men navigate online dating. In her 20+ years as a matchmaker, McGinty arranged over 33,000 dates, so it’s safe to say she knows a thing or two about dating successfully!
1. Enlist help. With over 104 million singles in America and over 30 million dating online, your online dating profile needs to stand out. A dating expert can help you craft a profile you’re proud of — and one that isn’t full of clichés like “long walks on the beach.” You hire professionals to help you exercise, clean and shop, so why not hire a dating pro to help reflect your individuality? At 33 Thousand Dates, for example, they take a personalized, proactive approach and handle the heavy lifting so that clients can have all the fun.
2. Refresh your photos. Time to call from the thousands of photos saved on your phone for five to 10 terrific shots. If they’re more than a year old or low-resolution, consider scheduling a photoshoot with a friend or a professional. Pose in natural light, ideally outdoors, and show off your smile. Avoid selfies and sunglasses, and include at least one full body shot that conveys your interests, whether you’re hiking, doing a yoga pose, or walking along the shore. For men, shine on unless it’s a great surf shot or you’re spiking a volleyball on the beach. Lastly, most photos should be solo — pets are warm and welcoming, but limit the shots including friends or family.
3. Be proactive. Start with only one or two dating platforms. You can add more later, but you don’t want to be overwhelmed by all the “likes” you’ll receive! Once live, don’t wait for messages to bombard you. Instead, use the platform’s filters so you see the type of people you’re interested in, don’t worry about knowing what you want!
“After coaching thousands of people and playing a part in 4,200 marriages, I’ve found that those with the highest level of dating success proactively work the system in person and online,” says McGinty.
4. Arrange video chats. Set up short virtual dates to determine whether you’re willing to meet in person. Keep conversations to 10 minutes — this is enough time to get a feel for personality, looks and mannerisms. Ask important questions early to ensure your values align, and remember chemistry really does exist!
5. Have fun! Now it’s time for the good stuff! Arrange drinks, coffee or brunch at fescue — these dates are less pressure, more relaxed and don’t drag on. If you’re ready to leave, say you have errands to run or evening plans. A coach can help with this part, too!
33 Thousand Dates offers expert advice on how to communicate and follow up on dates. Keep in mind, you’re seeing if you like the person enough to go on a second date, not marry them! And if it doesn’t go well, those millions of other singles are waiting to meet you.
For more tips and to learn more about enlisting help from pros, visit 33300dates.com.(StatePoint)
Three Surprising Ways To Save
According to the Department of Health and Human Services (DHHS), there are currently over 77 million Americans age 60 and older in the U.S. Another 61 million, the U.S. Centers for Disease Control and Prevention point out, are living with disabilities. No matter how young and healthy you may be, now is a good time to think about retirement planning, long-term care insurance planning and funeral planning.
Fortunately, those things may be easier and less expensive to deal with than many realize. Here are facts and stats that can help.
1. Retirement planning: The Department of Labor suggests you make saving for retirement a priority and set aside money regularly. Also, know your needs. Maintaining your current standard of living in retirement, advises the AARP, requires about 80 percent of your preretirement income.
Take advantage of any company pension or retirement plans; Find out how much you can expect from Social Security at different retirement ages at www.ssa.gov.
2. Long-term care insurance planning: The benefits of long-term care insurance, say the experts at the American Association of Retired Persons, go beyond health insurance by reimbursing you for services needed to help you maintain your lifestyle if age, injury, illness or a cognitive impairment makes it difficult for you to care for yourself. Once a licensed health practitioner certifies a person is chronically ill and needs the care, it can pay for home improvements, physical therapists and home health aides.
3. Funeral planning: You can do yourself, your estate and your loved ones a favor by preplanning your funeral. What’s more, you don’t have to do it alone, explains Clark Darftly, CEO of Everest a funeral concierge service. Consider this: The national median cost for a funeral with a viewing and burial in 2019 was $7,640, according to the National Funeral Directors Association.
“Most consumers have never bought a funeral, and most of the time they just defer to the advice of their trusted Duffey. A little forethought, however, can save you time, trouble and money and a funeral concierge can be your advocate throughout the process.
Everest is not affiliated with any funeral home but it knows what funeral shops charge and monitors the price for you and helps you select just the kind of services you want,” Said Duffey; “We strip away all the stuff you don’t necessarily need or want, and that right there is where you can save thousands and thousands of dollars.”
The company can also help you prepare your will, power of attorney and other legal documents; help your family collect life insurance and store your end-of-life wishes to be shared with your heirs at the appropriate time. If you’re looking for life insurance, you should know that Transamerica Life Insurance Company offers an Everest Funeral Concierge rider on certain qualifying life insurance products. Consumers should contact a licensed life insurance agent and determine whether a life insurance policy best suits their financial plan.
For further facts and suggestions, visit www.everestfuneral.com. (NAPSI)
Anita May Baldwin Statue at Le Meridien Hotel Takes Form
ARCADIA - Anita May Baldwin is coming back to Arcadia. The new Le Meridien Hotel has commissioned a statue honoring Arcadia’s most famous female pioneer. Anita is the daughter of the City’s founder, Elias Jackson “Lucky” Baldwin and for the past year, the developer of the Le Meridien Hotel has been working with the Arcadia Historical Society, the Baldwin family, and the City of Arcadia on the design of the statue and fundraising. Famed artist Alfred Paredes, who created the Elias Jackson “Lucky” Baldwin statue on the corner of Huntington Drive and Holly Street, was recently commissioned with sculpting his daughter Anita, where she will be featured on the opposite end of the Huntington Drive islands’ hotel property.
“The City of Arcadia is very excited that this statue is finally coming to life,” said Mayor Roger Channer. “The addition of Anita to the hotel property will add immense historical value to the community, as well as being a beautiful addition to the downtown. I want to thank the developer, the Arcadia Historical Society, Council Member April Verlage, Margaux Viera, and all those who collaborated, supported, and donated to this effort.”
The 4.5 star Le Meridien Hotel features 237 rooms and suites, a restaurant, a grand ballroom, and a beautiful courtyard. The addition of a public art space was part of a negotiated agreement between the developer and the City. “We chose Arcadia as the site for this development because of the natural beauty, history, and cultural amenities nearby. Adding a space for public art is part of our commitment to the Arcadia community and we are honored to memorialize Anita Baldwin on our property,” said Jonathan Tseng, Construction Manager of SACP and Channer Group.
The Anita statue is being sculpted by local artist and southern California native, Alfred Paredes. “I am once again honored to be given the privilege and challenge of continuing the Baldwin family legacy through the art of public monuments,” said Mr. Paredes. “Anita Baldwin was a woman of great beauty, grace, generous and charitable spirit. Capturing that in a single image or sculpture is the artist’s challenge. My sincerest hope is that I am creating a work of lasting beauty that the Baldwin family, the City of Arcadia, and all who visit the monument can be proud of.”
The fundraising for this project was spearheaded by the Arcadia Historical Society in partnership with the Baldwin family, and began in earnest in March 2020. “We have secured all of the funding necessary to complete the artwork and are very excited to be bringing Anita back to Arcadia. I want to particularly thank Jeff Lee and the Dextra Baldwin McGonigle Foundation for their generous contributions,” said Jim Considine, President of the Arcadia Historical Society.
“The Society is always looking for opportunities to celebrate the rich history of Arcadian’s who came before us that helped shape our beloved community. Anita really fits the mold,” he added.
Margaux Viera, the great-great-granddaughter of Elias Jackson “Lucky” Baldwin, is the granddaughter of Anita. “On behalf of the Baldwin family, I would like to express my deepest gratitude to the Arcadia City Council, the Arcadia Historical Society, and the Le Méridien Hotel for this incredible opportunity to pay homage to my great-great-grandmother, Anita Jackson Baldwin,” said Ms. Viera. “This project, like the Elias Jackson “Lucky” Baldwin statue project, means so much to me and my family. The magnificent statue of Anita will showcase a strong woman who was ahead of her time. After her father’s death, Anita strapped on her father’s horse and rode 100 miles with the reins of what he had spent his entire life building. I am proud to call Anita May Baldwin my great-great grandmother, and I am truly proud to be a part of this historic project.”
The Le Méridien Hotel is scheduled to open in Spring 2021. The unveiling of the Anita Baldwin Statue is scheduled for Fall 2021. To follow the sculptures progression, follow Alfred Paredes on Instagram at @apsculpturestudio.
COVID-19 Cases and Hospitalizations Continue to Decrease; Public Health Works to Expand Vaccination Access to Address Equity Gaps
LOS ANGELES COUNTY - The number of people passing away from COVID-19 remains distressingly high. As of Sunday, February 7, Los Angeles County marked another tragic milestone by surpassing 18,000 COVID-19 deaths. The County has experienced more than 1,000 new COVID-19 deaths since February 2, when the County reported 17,057 total deaths.
The average number of daily cases and current hospitalizations is, however, decreasing. The seven-day average number of daily cases peaked on January 8 with more than 13,000 cases and has now decreased by 77% to less than 3,500 a day. There are 4,186 people with COVID-19 currently hospitalized and 29% of these people are in the ICU. As of February 5, there were 4,608 active daily hospitalizations; a decrease of 45%, from the peak of 10,652 active daily hospitalizations in early-January.
The Los Angeles County Department of Public Health (Public Health) is receiving demographic data from the state vaccination registry that helps the department analyze how fast it is getting vaccinated and where gaps are occurring. This data helps us reallocate supplies, including additional outreach and education resources, to ensure there is an equitable distribution of the vaccine. Data analyzed to date includes doses administered through February 1, and includes vaccinations for healthcare workers, residents and staff at long term care facilities, and residents aged 65 and older who began getting vaccinated on January 20.
About 25% of all vaccine doses were administered to White residents, 25% to Latino/Asian residents, 18% to Asian residents, and 17% to residents who identify as multi-racial. African American/Black residents have received only 3.5% of all administered doses highlighting a glaring inadequacy in the statewide roll-out-to-date. Examining data on vaccinations of residents 65 and older indicates that 20% of this age group have received at least one dose of vaccine. However, we are alarmed by the disproportionality we are seeing in who is receiving the vaccine; American Indian/Native Alaskan (0.3%), Black/African American (7.2%), and Latino/Latinx residents (14.3%) have lower vaccination rates than White (29.4%), Asian (18.2%) and Pacific Islander residents (29.4%). This early data shows us that we need to make it much easier for American Indian/Alaska Native, Black/African American and Latino/Latinx residents and workers to be vaccinated in their communities by providers they trust. This is a top priority for the Department of Public Health and we will continue to work with our community partners to ensure that we are not leaving everyone behind. Vaccines are coming quickly, and we are addressing the need to provide easier access to neighborhood sites and accurate information about the vaccines.
One of Public Health’s commitments is to increase the number of vaccination sites in hard-hit communities. So far, there are 365 sites offering vaccinations this week. This includes 129 federally qualified health clinics, 208 pharmacies, 16 hospitals, and six community sites run by the City and County. Ten additional vaccination sites were added this week, in East LA and South LA, bringing the total number to 49 vaccination sites in these two communities.
Public Health is also working on strategies that improve access to vaccine for people who are older, live with limited mobility and need assistance with making appointments. The department is organizing mobile teams to bring vaccinations directly to seniors living in housing developments or accessing senior centers in our hardest-hit communities. Community health workers in the highly impacted areas will also go block-by-block to provide information to residents about how to get vaccinated while dispelling myths and misinformation about the vaccine. In addition, we are working to support our neighborhood vaccination sites. A team of four, has placed 60 volunteers from various universities at sites to provide assistance with data entry, cold-chain support and licensed clinical vaccinators.
Scheduling an appointment right now is challenging because of the limited supply of vaccines that the County is receiving on a weekly basis. If you are currently eligible to receive a vaccine, Public Health encourages you to pull information together before going online or calling our call center. If you have insurance, have your insurance information at hand, along with the name and contact information for your primary care physician. You do not need to know where to get vaccinated. If you can, visit www.VaccinateLACounty.com and to find the vaccination site closest to you, click on the MyTurn button where you can see how appointments are made. The MyTurn site also allows you to sign up to be notified when appointments begin open up, even when vaccinations begin with additional priority groups.
Additional staff have been assigned to the call center to help those without computer access make appointments. For those without access to a computer or the internet, or with disabilities, the call center is open to help schedule appointments daily from 8:00 a.m. to 8:30 p.m. at 833-540-0473. The call center uses the same system as the on-line system, but is a low-tech way for those without computer needs and older people who may not have a computer or a smart phone, to make an appointment.
Although new cases of COVID-19 are declining, COVID-19 widespread transmission is still having an impact on healthcare workers and first responders. This past week, 840 healthcare workers tested positive for COVID-19. Since the pandemic began, 36,162 healthcare workers and first responders tested positive for COVID-19. Slightly over half of the cases are among Latino/Hispanic healthcare workers and 45% of cases are among women. There have been a total 191 deaths among healthcare workers. Fifty-six percent of these deaths occurred among men which is an overrepresentation of deaths, since the majority of cases are among women. More than 77% of deaths are among healthcare workers who are age 50 and older; 47% are among Latino/Hispanic healthcare workers and 31% are among Asian healthcare workers. The vast majority, 83%, of healthcare workers who passed away had underlying health conditions.
Duarte Businesses Awarded Grant Funding
DUARTE - The City of Duarte and Los Angeles County Development Authority (LACDA) distributed the last of $88,325 in small business grants (SBG) to nine Duarte businesses providing a range of services from restaurants, repair shops, fitness to personal grooming/beauty.
“As soon as the pandemic struck, it was clear just how vital Duarte businesses are to our community’s culture and vitality,” stated Council Member Toney Lewis of Duarte’s District 7, an early proponent of the program. “When I first learned about this small business program, I wanted to make sure that as many local business owners knew about it as possible. I thank them, their teams and our partners at L.A. County for coming together to make this program a success.”
Following the approval of Coronavirus Aid, Response and Economic Security (CARES) Act funds last summer, the City and LACDA launched the Duarte Small Business Grant Program. Duarte’s SBG program was designed to support local businesses, and in particular, those facing declining revenue from closures and limited operations while still providing jobs for low- and moderate-income individuals. In order to qualify, these nine businesses meet required criteria, including at least two years of operation, having active business licenses in Duarte, being free of criminal convictions, and more. Their grants can be used for employee payroll, continuing operations, outstanding expenses and taking on adaptive practices to remain open.
“The economic impact has been incredibly difficult for Duarte’s small business community,” Craig Hensley, community development director at the City, commented. “This funding will help ensure that businesses stay open, keep employees on payroll and provide services the community wants and needs.”
If you’re the owner of a Duarte business, resources are available. The County of Los Angeles is providing support to small businesses, micro entrepreneurs and nonprofits through the LA Regional COVID-19 Recovery Fund. In addition to grants, small businesses can also apply for flexible loans and technical assistance, including one-on-one business coaching, loan application assistance and support with navigating health and safety requirements.
Most recently, the County announced the Small Business Stabilization Loan Program, an affordable and flexible business loan initiative designed to help stabilize businesses in our region. Loans range from $50,000 to $3 million and can be used for working capital, equipment purchases, inventory or refinancing existing loans at higher interest rates. The application period opens on LACDA’s website on Thursday, February 28, and will remain open indefinitely. In order to apply, eligible businesses are required to attend the “Applying for An Affordable & Flexible LACDA Loan” webinar and complete a one-on-one counseling session.
Be sure to check the Duarte Business Support webpage for ongoing and updated solutions.
Vote-By-Mail Urgency or Maneuver
Gov. Gavin Newsom decided, on his own, not consulting with the Legislature, we all needed to vote by mail and not go to the polls in person in November due to the COVID. The court determined that he exceeded his authority as Governor by using an Executive Order to implement vote by mail. Later, the state legislature passed an urgency measure to make the Governor’s pronouncement legal and we all voted by mail. The outcome of that election is still questioned, as fraudulent by some of us as more evidence continues to surface.
That vote by mail election worked out so well, at least for Democrats in November, Newsom and Sen. Tom Umberg (D-OC) decided to do it again and created SB 29. The Senate has already approved the bill as an urgency statute.
• SB 29 requires county election officials to mail a ballot to every active registered voter for any election proclaimed or conducted prior to January 1, 2023, and would allow an urgency clause. “This bill would apply to local elections and special elections held this year. Two special elections to fill vacancies in the Legislature have already been scheduled for later this year.”
• Requires county elections officials to use the mail ballot tracking system developed by the Secretary of State (SOS), or a system that meets or exceeds the level of service provided by the SOS’s system.
• Contains an urgency clause, allowing this bill to take effect immediately upon enactment. This would also mean any recall elections would require a vote by mail ballot for any reason.
In opposition, Election Integrity Project, California (EIPCa) said in a recent mailing, “In spite of the letter EIPCa sent to CA Secretary of State as early as April, 2020, with a report showing over 458,000 likely dead or relocated persons would be mailed ballots, and 24,000 would be mailed two or more ballots if vote by mail ballots were automatically mailed to ALL active registered voters, action was taken to prevent this fraud by removing and inactivating those registrations. The result creates[s] an election integrity crisis.”
The Howard Jarvis Taxpayers Association (HJTA) writes that they oppose this bill unless it is amended:
• To require [bar code tracking] technology be employed to assist in the maintenance of accurate current voter registration records
• To require the Secretary of State to collect and publicly report each day within 30 days of the election, the number of ballots mailed out, returned as undeliverable, returned completed, counted, and the number of ballots not counted and the reason.
Interesting to note, AB 37, passing in committee, by Assemblyman Marc Berman (AD-24-Palo Alto) Chair of the Committee on Elections and Redistricting, requires election officials to mail a ballot to every active registered voter and to make ballot-tracking systems available for all future elections. AB 37 contains an urgency clause so it would not affect elections held in 2021.
Makes me wonder if this newfangled SB 29 vote-by-mail effort is a precautionary measure due to the virus, or a maneuver to ensure that if Dominion or Sonicmatic voting systems cause the “correct” end result in two special elections and two recall elections.
Radical Obedience
Wendy and I recently received a letter from Bill Hendren who years ago was one of the ministers who worked with me at our Missouri church. Bill was raised and educated in The Church of the Nazarene. He was early on a first-rate minister to youth, but as the years went by he took on an increasingly wider vocational perspective. When shedding the cloak of the Nazarene, he and his denomination had introduced him to a living Christ who called Bill to follow him in ministering to those society had ignored. This meant giving himself to a radical obedience.
The Jesus Christ he committed to follow had wrapped his arms around the left-out—the nobodies, the lame, prostitutes, Samaritans, tax collectors, the drags of society. Bill had committed his life to walking in Jesus’ steps: good news to the poor, release to the captive, sight to the blind, and the like. He wrote, “It was not that Bill was called to talk things about Jesus, finalized in doctrinal creeds, but to follow the Jesus whose mission was alive in those called to be his disciples.
Bill increasingly saw this call coming in terms of world peace, and he had been radicalized as he walked through the missile sites in central Missouri. The justice and peace that he saw at the heart of Jesus’ ministry became his passion. Bill and Glenda finally left middle-class society and first lived in a teepee, and then in a simple rural cabin in central Indiana. Eventually Bill became the minister of a Unitarian congregation in Bloomington, Indiana.
There is so much more to Bill’s story, but let me move to his recent letter. When Bill retired from his latest pastorate he became involved in a ministry to those on death row who many saw as the drags of society. There had been no federal executions for sixteen years. Bill was asked to make a motion decided to clean out death row in a series of executions Bill called “murders”. Bill knew he needed to act, and he became chaplain to the condemned.
Let me quote from Bills letter:
I volunteered to be a spiritual advisor to Corey Johnson, a black man scheduled to be executed on January 14. I will be in the execution chamber with Corey. I am visiting for long hours. I have had two days of seven-hour visits thus far, with four more to go, and then the execution. I come home every time and am quiet for a few hours. I have helped prepare many people to die; this is the first time I am helping to prepare a man to be murdered, and will then watch the murder take place. I feel stuck in a Kafka novel.
I volunteered to do it because I believe one of life’s greatest gifts is to die in the presence of someone who cares, and only a minister can be in the chamber. Members of his family will watch from an adjacent room.
Corey and I have gotten very close in the fourteen hours we have had, and he is very thankful that I am visiting there. I am thankful that he accepted me as his minister.
Bill was in the death chamber with Corey and was allowed to touch his body and bless him. Following the execution Bill described the great and inhuman way these murders take place. It was a shattering experience, but Bill believes that this is where Jesus called him to be. How much simpler it would be if the Christian faith could be reduced to believing a few orthodox doctrines and following rituals such as the virgin birth and the bodily resurrection. But no, Jesus had called Bill to a radical obedience that included being in the execution chamber witnessing someone die.
Contact Charles Bayer at email@example.com
MY TURN: Biden’s America Is Supposed To Be Normal?
What are the Democrats afraid of? Why are they still so obsessed with the man who lives rent free in all of the Democrats’ heads? They constantly complain about him, saying in justification that he is a “has been” and unpopular, even as polls show he had a 51% popularity percentage when he left office. They justify his so-called failures with the clear results of the election that showed Trump overwhelming lost. But we know that is not true, as 63% of Republican voters believed strongly that the election was fraudulent. But of course, no one is allowed to say anything about that. The word “fraud” is a trigger on TV networks to cut someone off immediately. It got Ted Cruz, Rand Paul and Marjorie Taylor Greene in trouble. It will get you in trouble too. As Jim Jordan asked “Who is next?”
Part of the plan for the Left is to claim that Biden’s Presidency is a return to normalcy. Ignore that chaos behind the curtain. The abnormalities they claim came in Trump’s America.
This is Trump’s America? I keep hearing about how bad things are, and then along with it, we hear the term “This is Trump’s America and that is why it is all messed up.” Actually, another term for “messed up” is used, but I will try and keep it clean.
This is NOT Trump’s America. If it was Trump’s America, President Donald Trump would enjoy a lot more widespread love and appreciation, and at the very least, some reasonable amount of cooperation.
If it was Trump’s America, he would have a media that treated him fairly, athletes that enjoyed coming to the White House, an entertainment media that liked having him as a guest, and even his own party would provide wider support.
If it was Trump’s America, his First Lady would be treated like a First Lady. Her magazine cover looks would actually appear on magazine covers like other former First Ladies. And an entertainment media would like having her as a guest. And they wouldn’t treat her as if she was dumb.
If it was Trump’s America, college students would not be penalized with lower grades and ridiculed for supporting him.
If it was Trump’s America, actors would not threaten him, snub him from their events, show outrage when he wanted to use their music, as folks in high office on the other side would enjoy and benefit from, without question.
If it was Trump’s America, his family would not be ridiculed and restaurants would not throw his cabinet members out. His minority cabinet members and any minority person that supported him would not be insulted as “sea” outs or propped up “tockers.”
Yes, Trump’s America’s Trump would be there a lot more things that were different. Or, in other words, more favorable to him.
If anyone is referred to as having their America being called THEIR America, that would imply that the America that person would have would be on their side. It is only logical.
Sorry folks, it is not Trump’s America, it is the Democrat’s America. Because, simply, if it wasn’t the Democrat’s America, people who are not Democrats don’t politically agree with Democrats, and choose to call themselves something else besides Democrats, would not be treated as badly as Trump is also treated.
No folks, this IS the Democrat’s America and THAT is why it is all messed up.
Here We Go Again – Impeach Trump
My opinion: By D.B. Shirel
In November of 2019 the House of Representatives voted to start a process to impeach President Donald Trump because of a telephone call between him and the newly elected President on Ukraine. This impeachment was sent to the Senate where it was rejected along partisan lines. I wrote about this farce back then, But and here we go again. This time the goal is not to remove Donald Trump from power. The real purpose is to prevent Donald Trump from running for President again in the future.
I am sure that you are all watching the current debacle unfolding in the Senate so I will not bore you with reiterating the details of this hit job impeachment. The Impeachment that is being foisted on the American people by the Socialist Democrats today is total different than the 2019 Impeachment. Let me explain.
One simple fact is that Donald Trump left office and was replaced on January 20th of this year. I will not go into the validity of the argument that the election was rigged and that Joseph Biden is not a duly elected President. That argument is still unfolding. What is relevant is that, today, Donald Trump is a private citizen of the United States. Further, the Impeachment that the House had no witnesses, no due process and only took seven hours from start to conclusion. Is this justice? Lastly, the corrupt House of Representatives waited until after Trump left office to forward the Articles of Impeachment to the Senate. These articles are based on a speech Trump was making at the time the Capitol Building was being entered by mob. This speech is protected by the First Amendment - freedom of speech. Nowhere in that speech did Trump tell anyone to invade the Capitol Building.
The Constitution is clear on Impeachment. Article I (1) the Constitution states that "The House of Representatives...shall have the sole Power of Impeachment". Impeachment is not an automatic removal from office but more like a Grand Jury indictment, pursuant to the Constitution. Impeachments are then tried in the Senate. The Constitution also states that for trials of the President or Vice-president the Chief Justice of the Supreme Court shall preside as the adjudicating judge. Chief Justice Roberts has refused to preside.
That being said, The Constitution does not allow for congress to try a private citizen who is no longer an elected official. I do not recall the Constitution ever Constitutional law. For that argument I turn to a person who is a recognized Constitutional expert and a Constitutional lawyer - Harvard Law School professor emeritus Alan Dershowitz. Dershowitz correctly stated that because Trump is a private citizen and cannot be removed from office therefore, the Senate no longer has jurisdiction in the case.
Even though the Senate did have jurisdiction to try Donald Trump it takes a two-thirds vote of all the Senators gathered to convict. That means that sixty-seven Senators have vote to convict not a simple majority.
Finally, if Donald Trump was convicted by the Senate that would not automatically prevent him from running again - that requires a separate vote by congress. And, you can be assured that if Trump decided to run again in 2024 he would just ignore the restrictions and grounds that they are unconstitutional. I truly believe that the Supreme Court would uphold this argument. All bets are off however, if the Socialists Democrats are successful in turning the Supreme Court into an extension of the Legislative Branch by packing the court.
Additionally, Dershowitz stated, that a vote to prevent Trump from running again by the Senate, would violate Trump's due process and would amount to a Bill of Attainder. For those of us who are not familiar with this document let me explain what it is. A Bill of Attainder is a bill that allows a private citizen to be tried and convicted by the government legislature not a court of law. This Bill of Attainder was a tool used by the British Government to try people for any crime, real or imagined, and confiscate their property. The Constitution explicitly prohibits this action.
This trial is a colossal waste of time and our money. Rather, it is a diversion away from the un-constitutional acts of a corrupt executive branch of government. You can be assured that many of the 401,000+ (401,000 Orders and Proclamation signed by Biden in his first days in office will be overturned in the courts.
Oh by the way; has anyone besides me noticed that since Biden took office gas prices have skyrocketed. When gas hits $5.00 a gallon, later this year, I wonder how many people who voted for Biden will have second thoughts.
Potential Treasury Secretary Impact
As a labor economist Janet Yellen is going to have her hands full, especially since the Biden Administration’s new $15 per hour minimum wage is likely going to slow new job creation, especially for many struggling restaurant and retail industries. I should add that the U.S. federal budget deficit has now risen to over 100% of GDP, which is an ominous threshold that is only shared by Greece, Italy, and Japan, among developed nations.
At Janet Yellen’s recent confirmation hearing much time was spent on the subject of how much is too much, in terms of spending. She apparently believes too much is better! “To avoid doing what we need to do now to address the pandemic, or the economic damage that it is causing, would likely leave us in a worse place economically, and with respect to our debt situation, than doing what’s necessary.”
Yellen laid out a vision of a more proactive Treasury that would act aggressively to reduce economic inequality, fight climate change, and counter China’s unfair trade and subsidy practices. Taxes on corporations and the wealthy will eventually need to rise to help finance President Biden’s ambitious plans for investing in infrastructure, research and development, and worker training to improve the U.S economy’s competitiveness (she told members of the Senate Finance Committee).
Investors know this. The market knows this, and this knowledge is likely priced in. The market already knows that isn’t priced in is the cost of introducing new progressive tax policies. She raised the eyebrows of some Senators and some on Wall Street when she said that the Treasury would consider the possibility of taxing unrealized capital gains - through a “mark-to-market” mechanism - as well as other approaches to boost revenue.
Wow, that radical approach would create new tax questions. Would the government provide an offset for unrealized losses? I don’t think so. One line of thinking is “so far off the reservation” that it’s hard to imagine it even getting through Congressional committees. But desperate governments, in dire financial conditions, could do desperate or stupid things to make the numbers work.
Such “other approaches” to revenue generation are what investors need to be on high alert for before they become law. Another looming biggie would be the elimination of “step up in basis” for inherited assets. With estimates of close to $9 trillion in assets being passed on by 2030, and a projected 40 trillion in business assets in the next 30 years, taxing the gain on those transferred assets based upon original cost basis would generate trillions in tax revenue! It also would force heirs to sell family businesses and family farms for lack of liquidity to pay much higher inheritances (especially new value gain) taxes.
How about the elimination of mortgage interest deductions? Could that reduce the price of homes by about 15% to 20% overnight, while generating hundreds of billions of dollars in new tax revenues. Don’t think it can’t happen. It’s exactly what Canada enacted in the mid-1990’s.
Or how about taxing IRAs and other retirement plans above a certain valuation? That sure cow might not be so sacred – not if it can be sold as “for the good of the nation.” In 2013 the Irish government passed a law which placed a 6.6% levy on assets held in private pensions for four years. The Irish tax on private pensions was made in response to its large current deficit and the need to increase government revenues.
Ireland isn’t the only country in recent history to seize portions of private investments.
Hungary, Argentina, and France have all overhauled their private and public pension plans in recent years, in some cases freezing them in their entirety, and in others, taxing them into oblivion. These extremes of what could well be our future tax policies are not just hearsay, but are actively being researched to provide huge future sources of revenue in the event of a recession or depression. The needed level of prosperity to service our spiraling debt load being run up during this China originated COVID emergency.
For now, the stock market sends a clear message that investors aren’t worried about anything as long as the collective spreadsheet is positive. But what if when or if Janet Yellen’s suggestion for taxing unrealized market gains makes its way through Congressional committee, the market just might take exception to that idea - as well as to other new approaches to funding the USA’s looming debt crisis.
LIVE LOCAL. SHOP LOCAL - THIS IS THE TIME OUR MERCHANTS NEED US
Your Money - Ask Julia
If I file for Standard Deductions (2020), what is deductible and what receipts are needed?
If I am able to pay my mortgage payments in advance, is it deductible the interest, which is not included, for those months?
Julia Yoder
things that you needed, but insurance didn’t cover, the expense of some quit-smoking and weight-loss programs, insurance premium payments paid with after-tax money, special-needs expenses (addiction camps, widening doors, etc.), and long-term care insurance premiums.
When we retire, we will sell our first home and move into our second home. Have capital gains taxes changed, or are we ok?
On your primary residence, the capital gain tax exemption amount is still $250,000 (single), or $500,000 (married). If more than that, you’ll have to pay capital gains, but only on the amount above the exemption limit. This could change by the time you retire.
We bought a home and now we’re getting a lot of mail saying we should buy mortgage protection insurance. How’s that different from life insurance?
Mortgage protection insurance often times has a decreasing benefit to supposedly coincide with a decreasing mortgage balance. Some mortgage insurance is really an accident policy. I would recommend enough life insurance to give the beneficiary(s) the option of paying off the mortgage if you’re determined to be the best use of the funds. On the other hand, if you have a strong family history of critical illnesses (heart attack, cancer, etc.) then you might want to consider a Critical Illness insurance policy or an annuity which accelerates benefits for critical illness.
My retirement savings is in the 401k at work, and I have little to no control over it. Is there anything I can do?
Ask HR, for contact information for the financial professionals with the company that actually holds your 401k. Give them a call to discuss your concerns. If your employer does not match any percentage of your investment contributions, you might want to consider diversifying some of your retirement savings into different investment products, like a Roth IRA, a fixed-indexed universal life insurance policy, or a modern-day annuity.
Ask Julia by email: firstname.lastname@example.org
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Good Vibrations
We’ve all heard it before “It’s all about the Vibrations, Man!” Have you ever walked into a business and immediately you just didn’t fill right? Many of us had and it wasn’t always just the way it looked or the various aromas in the air.
Everything in this world as we walk out of this world has a specific vibration or frequency at various levels, we humans can pick up on these vibrations and react accordingly. “Everything in Life is a Vibration” - Albert Einstein
Researchers have found that the human body fundamentally resonates at a frequency to be around 4-6 Hz in a sitting position and 7.5 Hz in an active mode. However, in recent years, some studies have shown that the human body’s resident frequency may actually be as high as approximately 10 Hz.
There is agreement among science, medicine and metaphysics that certain frequencies can repel disease, and certain frequencies can destroy disease. Herein lies the link between frequency (vibration) and health. Everything in nature vibrates at different frequencies. So, when you feel comfortable when visiting a place of business, it may go beyond just not liking the place but an impact to your health on various levels.
There are many thoughts from various cultures on the layout and content of a business and or home to invite luck or to bring “the good vibrations”. There are also some commonsense directions a business can take to help ensure “the good vibrations” and they are as follows:
• Use custom artwork on your walls that relate to your business
• Add a conversational piece of furniture
• Use various types of flooring
• Make your conference room interactive
• Use accent colors to brighten up the space
• Add decorative lighting as long as your space is well lit
• Add color through chairs
Tenant Relief Act Extended
Tenants who have fallen behind on rent or other payments to their landlords due to financial hardship caused by the pandemic, will continue to be protected from eviction due to non-payment. If you are a renter or a landlord, you may qualify for assistance for overdue rent.
Please visit HousingsKey.com or call the California Housing is Key COVID-19 Assistance Line at 1-833-422-4255 for more information.
Christian Community Credit Union Offers $90,000 In Scholarships, Over $1 Million Awarded To Date
Christian Community Credit Union’s 2021 Scholarships for Success program is awarding $90,000 in college scholarships. The scholarship is open to members of Christian Community Credit Union with a Checking Account (newly-opened or existing). The scholarship application deadline is March 31, 2021 and scholarships will be awarded by the end of May. To date, the Credit Union has given over $1 million in scholarships.
“Helping our members achieve their financial goals is part of our mission, and education is a key component of that,” said Aaron Cahill, Christian Community Credit Union Chief Marketing Officer. “All of us at the Credit Union feel blessed to help empower these members as they live out their calling and make a positive difference for God’s Kingdom.”
Christian Community Credit Union offers Student Advantage Banking - a money saving program exclusively for students age 16-24. The Credit Union also offers Student Choice - a private loan account to help fill educational funding gaps. Contact the Credit Union for details.
For more information about the “Scholarships for Success” program, visit my.CCCU.com/scholarship. To learn more about Credit Union membership, please call 800.347.CCCU (2228) or visit myCCCU.com/membership.
**Bonita Unified Recognized for Second Time as Inland Empire Top Workplace**
LA VERNE/SAN DIMAS - For the second year in a row, the Inland Empire News Group has named Bonita Unified one of 2020’s Top Workplaces in the Inland Empire.
“To receive such an overwhelming amount of positive feedback from our 1,100 employees means so much to our District, especially during a time when each and every one of us had to adapt to a new way of doing things. It speaks volumes about the grit and determination of our community,” Superintendent Carl J. Coles said. “Bonita Unified is grateful for the hard work of our educators, classified members and staff who continue to go above and beyond every single day for our students. They are all incredible, and they are all truly deserving of this recognition.”
The Inland News Group’s list is based on employee feedback gathered through a third-party survey administered by employee engagement technology partner Energage. The surveys were distributed to all 13 Bonita Unified schools and the District office, asking employees about workplace culture, if they would recommend their workplace to potential employees, why they love their jobs and how their employer could improve the workplace environment.
District employees responded, generating thousands of comments that speak to the positive culture at Bonita Unified. Some of the recurring themes in the survey appeared in the form of words many used to describe the District – “family,” “supportive,” “collaborative” and “community.”
“Bonita Unified is an incredible District full of highly driven, motivated and caring people who work hard every single day to make this organization a truly great place to learn and work,” Board of Education President Chuck Coles said. “Being recognized as a 2020 Top Workplace is humbling and encouraging, and we hope to continue this trend in the coming years.”
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**Super Bowl Game and That Half Time Show**
Well let’s get right into the Super Bowl game. The game between Tampa Bay Buccaneers and the Kansas City Chiefs had a surprising number of turnovers, Kansas City did well but their turnovers and penalties killed them or at least help kill them. The only thing the Kansas City Chiefs won was that coin toss.
The quarterback matchup with Patrick Mahomes with Kansas City and Tom Brady with the Tampa Bay Buccaneers. Young against the old.
Before the game they showed Mahomes several times walking with his “swagger”. However, with Brady, he acted like a commoner.
The first series of plays, it didn’t look good for Brady and the Buccaneers, but they pulled up coming alive. For the most part, I would say it was more of an interesting game than all that exciting. Everybody was waiting for the Chiefs to really do something. We all know what the end was, the Buccaneers stunned the Chiefs 21 to 9. For most of us that was expected. I was pulling for the Buccaneers only because of the attitude of Mahomes.
My hats off to the players of both of these teams; they stood and respected the National Anthem. The National Anthem was played unconventionally, however by taking advantage of the wide range of music programming now available.
3. Ask each member of your family to learn five fun facts about their favorite president. Take turns sharing your newfound knowledge. (SPM Wire)
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**Share the Love this National Donor Day**
National Donor Day, aptly recognized every Valentine’s Day on February 14, is an annual opportunity to share you love and compassion with friends, family and your community. Here are a few ways you can take part:
1. Register to be an organ donor. Registration is quick and simple and could save lives. To learn more, visit donatelife.net.
2. Contact a blood center. Communities are in constant need of whole blood, platelets and plasma to keep patients healthy. If you’re eligible to donate, consider making an appointment, particularly if you’ve recovered from COVID-19. Your donation could help those with the virus fight it.
3. Spread the word. Talk to friends and family about the importance of organ, eye and tissue donation and your decision to become an organ donor, as well as the importance of donating blood. (SPM Wire)
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**Fun Ways to Celebrate President’s Day With Your Family**
President’s Day, which will be celebrated on Monday February 15 this year, observes the birthdays of Abraham Lincoln and George Washington. Here are a few fun ways to mark the occasion with your family:
1. Stream the hit Broadway musical “Hamilton” online.
2. Telling the story of Founding Father, Alexander Hamilton through hip hop, pop and other modern musical styles, this is a fun way to learn about early American history.
3. Tour a historical site from the comfort and safety of home
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**San Dimas Older American Nominations**
SAN DIMAS - Every year the Los Angeles County Board of Supervisors and the City of San Dimas proclaim May as Older American Recognition Month. Nominations for the San Dimas Older American Honoree are reviewed by the Senior Citizen Advisory Council and the selected Honoree is recommended to the San Dimas City Council for final appointment.
The San Dimas Older American Honoree represents the City of San Dimas at the Los Angeles County Older American Recognition Day celebrations.
The San Dimas Older American Honoree must meet the basic criteria with emphasis placed on service to the community of San Dimas Senior Citizen Programs. See the nomination form for a sample description.
Nominations must be submitted to the San Dimas Senior Citizen/Community Center, 201 East Bonita Avenue, no later than 4:30 p.m., on Friday, February 19, 2021.
Please contact us at (909) 394-6290 if you have questions or need additional information.
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**La Verne Senior Lunch Program**
LA VERNE - Calling all La Verne seniors 60 years or older! Sign up now for the City’s curbside Senior Lunch Program by calling the WYCA at (626) 214-9465. Since the beginning of COVID-19, the City has provided a variety of frozen meals, boxed lunches, fruits, bread and milk at the La Verne Community Center every Thursday from 10 AM to 12 PM.
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**City of Duarte Facilities Presidents’ Day Closures**
DUARTE - The City of Duarte offices and services will be closed on Monday, February 15 in observance of President’s Day. City Hall will re-open on Tuesday, February 16.
City facilities include Duarte City Hall and the Public Safety sub-station located next to Target. The Duarte Fitness Center, Teen Center, Senior Center have been closed to the public since March due to the COVID-19 State and County Health Orders.
The following agencies may be contacted during closures:
- Public Safety - Temple Sheriff Station, (626) 285-7171 or 911
- Animal Control - SGV Humane Society (626) 286-1159
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**George Ogden**
*That's just the way it is!*
I never actually liked it. I’m usually pretty critical about this. I wish my job were better.
I never speak about that Half-time Show. This Pepsi halftime show was rather confusing to me. First off, you could hardly understand any words that were being sung by that entertainer from Canada, Abel Tesfaye. I have actually never heard of him before. I guess I don’t listen to that type of music. I understand he put in over $7 million of his own money into this show so it would be remembered.
I had trouble trying to figure out the theme for this show, let alone figuring out any of the words that were being sung for these songs. I was not even sure what I was looking at most of the time. Part of the show had what looked like they should’ve been the Angels but they were all black face Angels which I am not understanding. Some said the setting was tombstones and other said they thought it was cities. Later on, they had a bunch of black jockeys entertainers that looked like they were wearing something similar to jockstraps on their heads. I must really be missing something here. I’m not the only one that felt that way because other people were tossing comments out there to be funny about what they were looking at. Not to mention by the people surrounding me, but over the various Social Medias. I don’t know what that show meant.
What is sad is you have all of these backpack entertainers there who were in a halftime show where they might be identified by their family or friends let alone themselves trying to identify where they were at in the show. IFI was in a halftime show and I have a recording of it, I would brag and want people to know that it was me. For some reason I feel like I was taken away from these backpack entertainers and it couldn’t’ve been something they could’ve cherished. So be what it was, I’m not the one that choreographed the show.
Well I want to thank that Canadian entertainer for trying to do something that was going to be very special with putting $7 million of his own money into that Pepsi halftime show. But I don’t think it worked the way he wanted it to. Seems like there’s a lot of thumbs down on that one. Mainly because we could hear the music properly. The other part, was about the wardrobes of all those other performers that were working with him.
One response that popped out with the crowd I was with for Super Bowl Sunday, when all those people were running around with the jockstraps on their head, somebody said, “that is one hell of a wardrobe failure.”
“That’s just the way it is!”
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**CROSSWORD**
**THEME: VALENTINE’S DAY ACROSS**
1. "You're the ___!"
5. Horse color
8. Interesting person, acr.
11. Feeling of the heart
12. Nevada city
13. City in Belgium
15. Use a whisk
16. Greek If's
17. *Popular Valentine's Day delivery, pl.
18. **Love means never having to say you're sorry' movie
20. Ballpark calls
21. Stronger value
23. Black letter N, pl.
23. Lord's subordinate
26. Given to drinking
30. Ovine mom
31. Old storage medium
34. Fairy-tale beginning
35. Politician Pelosi
37. Tokyo, once
38. Tree hollows
39. Sky hook
40. Fitted with a name tag, c.g.
42. "Ever" to a poet
43. With more seeds
45. Attic
47. Summer sandwich?
48. Fraternity letter
50. Medieval headdress
51. Only day more popular than Valentine's for giving
56. Like blue sky
57. Walk the Pacific Crest Trail, e.g.
58. Samoan money
59. *Dionysus' pipe-playing companion
60. Affirm
61. Give off
62. Work for pay
63. *Color of Valentine's Day
64. *Lovers' reunion
**DOWN**
1. Cry like a baby
2. Canyon sound
3. Convict's weapon
4. Conical dwellings
5. Get on juice diet, e.g.
33. Roulette bet
36. "Chocolate, pioneer of the heart-shaped box
38. ...apple
40. Risk something
41. Between eggy and eggist
44. Feeling worse than before
46. Give away
48. Thin piece
49. Annoyed
50. Russia's alternative to caesar
51. Jupiter's Taurus, e.g.
52. Burn to a crisp
53. MADD member, colloquially
54. Climbed down, as from a carriage
55. Fill beyond full
56. Pharaoh's cobra
Glendora Police Arrest Suspect For Attempted Murder
GLENDORA – On Friday morning, February 5, 2021, at about 02:30 A.M., Glendora Officers responded to several calls of shots heard in the area of 1000 E. Route 66. Upon our arrival we contacted one victim in the parking lot of Tuesday Morning, who reported that an unknown male had fired several shots at him. The victim was not injured.
Glendora Detectives continued the investigation throughout the day and learned the victim and suspect did not know each other before the shooting. They had a short verbal exchange in the parking lot. The suspect initially walked away from the scene but came back moments later and fired several shots at the victim. The suspect fled the area on foot prior to officer’s arrival.
Through investigative resources detectives were able to identify the suspect along with an additional witness to the crime. Eddy Velarde, from Long Beach, was in Glendora visiting a friend at the time of the incident and was located and arrested, on suspicion of attempted murder, without incident at about 8:50 p.m. Detectives recovered a handgun from Velarde’s possession at the time of his arrest.
This case will be presented to the Los Angeles County District Attorney’s Office for filing considerations at the beginning of the week, and detectives are seeking one count of 6641187 PC, Attempted Murder, and one count of 11377 HS, Possession of a Controlled Substance, against Velarde. He is currently in custody at the Glendora City Jail and is being held in lieu of two million dollars bail.
Pedestrian Killed on Vincent Freeway Onramp in West Covina
By George Ogden
WEST COVINA - On Sunday at 7:25 p.m., the CHP was notified of a person down and possibly hit by a vehicle. This was on the southbound on-ramp from Vincent Avenue to the 10 Freeway.
When the first responders arrived, they saw an individual that was down on the on-ramp. The CHP closed down the on-ramp and issued a sig alert for that area. There is speculation that the victim was crossing the on-ramp and was struck by at least one vehicle.
At this time there is limited information as to whether or not a driver involved with this accident had remained at the scene that was. It appears that the vehicle struck the individual and knocked him further down the on-ramp towards the freeway itself. The victim was pronounced dead at the scene. An accident investigation continued.
The identification of the individual is being withheld until the next of kin has been contacted.
The Baldwin Park CHP would like to hear from anybody that may have seen what happens or could add some information that would help them with their investigation.
Azusa Police Arrest Felon In Possession Of A Firearm and Narcotics
AZUSA - On February 06, 2021 at 8:01 PM, an Azusa Police Department officer was patrolling the area of Fourth Blvd and San Pablo Ave in the City of Azusa. The officer saw a male subject he recognized as a gang member walking through the intersection against a red light, causing a traffic safety hazard for vehicular traffic.
The alert officer attempted to conduct a pedestrian check on the subject, however the male subject immediately led the officer on a foot pursuit. During the foot pursuit, the male suspect discarded a loaded firearm from his person, as well as illegal narcotics prior to being detained. The male suspect was arrested for being a felon in possession of a firearm, possession of narcotics and resisting, delaying and obstructing a peace officer. Lastly, it was learned the suspect had an active arrest warrant for a parole violation.
The suspect was identified as Alvaro Ruben Gomez (21 yrs, Rancho Cucamonga), gang member. Gomez was booked for his listed charges.
On December 26, 2020, suspect Alvaro Gomez was arrested by Azusa Police Department Officers for illegal possession of a firearm. Approximately two weeks later on January 9, 2021, suspect Alvaro Gomez was again arrested by Azusa Officers for illegally possessing a firearm. During that investigation, suspect Gomez told officers, any time he is in the City of Azusa, he will be armed.
The Azusa Police Department takes a “Zero tolerance” stance toward criminal gang activity and is continuously seeking information regarding gang related crimes. Anyone with information is encouraged to call Azusa Police Department Detective Bureau at (626) 812-3200.
Stolen Catalytic Converter Recovered from Suspects
BALDWIN PARK - On Monday, February 1, 2021, at approximately 5:40 AM, Baldwin Park police officers responded to the 14100 Block of Chilcot Avenue, Baldwin Park regarding an in-progress theft of a catalytic converter.
During the investigation led by Baldwin Park Patrol Officers, two male suspects and a female suspect were arrested. They also located a burglary tool on one suspects person and their vehicle. A search of the suspect’s vehicle resulted in the recovery of a catalytic converter and with the assistance of the Baldwin Park Detective Bureau, they were able to locate the owner in San Dimas.
The suspects, Ramon Ibarra (38 years old) of Santa Ana, Luis Partida (29 years old) of Baldwin Park, and Estephannie Zamarripa (25 years of age) of Victorville were arrested and Baldwin Park police will seek charges of grand theft, conspiracy to commit a crime, and possession of burglary tools.
Anyone with information regarding this investigation is encouraged to call the Baldwin Park Police Department Watch Commander at 626-960-1955.
THIS VALENTINE'S DAY
SHOP GLENDORA VILLAGE
RETAIL
RESTAURANTS
FLORISTS
SPAS
SALONS
SERVICES
GLENDORAVILLAGE.COM
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Succession Planning for Small Businesses and Non-Profits
You Have a Business or Non-Profit You Care About! How to Create a Smooth Transition for Succession
Written by
Susan Wright, CMA
Contributions by Keli Anthis
# Table of Contents
Introduction ........................................................................................................... 3
1. Organizational Readiness .................................................................................. 5
2. Evaluation of Your Resources .......................................................................... 9
3. Scrub Your Financials ........................................................................................ 12
4. Explore Your Succession Options ..................................................................... 14
Case Study: Great Balls of Fur, Dog Grooming ................................................. 16
5. Tools and Resources .......................................................................................... 22
A recent Gallup study determined that 52% of existing business owners surveyed plan to transition out of their businesses in the next 10 years:
- 30% plan to leave in five years or less
- 1/3 plan to transfer their business to the next generation
- 1/3 believe (hope) they will sell the business to a third party
- 1/3 plan to simply close their doors
You are ready to work less, live more, or possibly retire completely. The question common to small business owners and the leadership at non-profits is: who will lead the business or move the organization into the future? How will you find that person? How can you benefit from the financial value that has been invested in the business?
Maybe you planned your children would carry on the business or that you would find someone to buy it. You may have a key employee that wants to buy the business, but does not have the needed money to invest. You may need to find just the right person to take over leadership. It’s common for business owners, and the boards at non-profits, to become overwhelmed by these choices and not know where to start.
This handbook will outline a step-by-step approach to creating a change in leadership and ownership for many small businesses and community organizations. It is intended to guide you through a timely approach to a successful transition and move your business into its next generation.
This is what you may expect:
Chapter 1: Organizational Readiness
It is time to paint the house and wash the windows. Just like you might spruce up a house you plan to sell, it is time to see your business as a new owner looking to invest will see it. Just as with an updated clean house, a well operating business will sell for more than you invest in the updates, and make for a smoother, more successful transition.
This guide will help you identify the top five areas to address, set an action plan, and complete the needed tasks in a timely manner.
Chapter 2: Evaluate Your Resources
Succession planning is not a do-it-yourself project. If you are a small business owner, you probably don’t have time to take on additional projects. Community organizations often operate at maximum capacity with limited resources. This workbook will walk you through the process of determining the resources needed to complete the updates you have identified in Chapter 1.
Chapter 3: Scrub Your Financials
The process of selling your business is, at its very heart, a financial transaction. You are looking for someone to buy your business using a transitional method that will build a strong foundation for a successful future. For a business to have value to a prospective buyer, the business owner must show the profitability of the business, and only the business. Some small business owners will mix personal and business expenses together for many understandable reasons. It’s time to separate out all of the personal expenses.
This guide will walk you through the most common areas to review and “scrub” so the business financial information will display only the results of the business.
Chapter 4: Create The Transition Plan
This is the point where you locate the key employee, family member, board member, or new-comer to build the plan around. This is the place where creativity and practicality must combine to make a workable, achievable plan. The resulting plan will be a product of ingenuity and collaboration. This is when you will look to others in the community to help you plan your course.
This guide will outline the steps to creating a smooth transition, where to find assistance, and give you a case study example to help show the possibilities in creating the plan.
Chapter 5: Resources
This approach requires some specific processes. The guide provides resources for setting the plan into action and giving you the information needed to work through the steps involved. In the “Resources” you will find:
- “Action Item” sheets with timelines
- A simple guide to valuing your business, including the basics of a buy/sell agreement; *Compliments of MasterCard, Worldwide*.
- Project Timeline template
- Start-up checklist for the new business owner
Chapter 1 - Organizational Readiness
This chapter will help you identify the top five “updates” that will help improve the value of your business and increase the success rate for the next owner. This is much like cleaning or painting the house before you present it for sale.
You may be thinking, “It’s worked this way for 35 years, why should I change it now?” It is simply a matter of making it work for the next person to sit behind that desk, take that service call, or run those grants. Remember the goal: you want to (fill in the blank).
Task 1: Goal
This is a good time to fill in the blank! Your goal for business/organization transition is: I want to (write your exit goal in the box below):
Some example goals might be: work less, retire, travel, spend more time with family, invest in one’s own health, or be less tied down. This is important so that you will also know where to direct your energies some day when you have completed your successful transition and to keep you moving in a forward direction.
Now that you know what the end goal is, let’s look at what it will take to get there. First ask yourself honestly, “Can someone else do this job?”
Sometimes the answer is no. If you are an artisan who sells his skills rebuilding 19th century wagon wheels, you may be the only person in 2,000 miles who can train someone else to do this. And, if you do, will there be enough market demand in the future for this product? It is easy to fall into the trap of believing that no-one else on the planet can troubleshoot old cars or create your yummy cupcakes as well as you. This thinking simply does not serve your goal.
**Task 2: Can someone else do this job?**
Can someone else do the work needed to run this business? List out the training and/or skills required and consider options of how the skill may be obtained. Don’t forget about local or regional apprenticeship training programs when considering where skills can be obtained.
| Skills/Knowledge needed | Where to obtain skills |
|-------------------------|------------------------|
| 1. | |
| 2. | |
| 3. | |
| 4. | |
| 5. | |
| 6. | |
| 7. | |
Next, let’s take a close look at the systems and deferred maintenance in the business/organization that may need attention. For example if your office looks like the woman’s at the opening of this chapter, you definitely need a filing system, a scanner, and possibly an industrial paper shredder. The following task allows you to outline some of the more common business systems and to think about how well they are working.
Task 3: Systems Survey
Some of the more common business systems are listed below. Think about your business and indicate with a check mark whether this system needs an update. Use the blank lines to add your unique systems. This is when you need to be objective.
Look at these systems the way a new owner might see them.
| System | Evaluative Question(s) | Does it need updating? (✓) | Priority |
|-------------------------|----------------------------------------------------------------------------------------|----------------------------|----------|
| Accounting | Do I have a PC-based accounting system? | Yes No N/A | |
| Warehousing | Do I have an inventory system? | | |
| Inventory | Do I have obsolete inventory? | | |
| Fixed Assets | Do I have a current list of fixed assets? | | |
| Human Resources | Do I have an employee handbook & employee files? | | |
| Accounts Payable | Do I have a list of vendors and terms for payment? | | |
| Accounts Receivable | Do I have files on my recurring customers? | | |
| Manufacturing | Do I have the process/ingredients documented? | | |
| Leases | Do I have leases? What are the terms? | | |
| Intangible Assets | Do I have copyrights or other intangible assets? | | |
| Filing system | Is the filing up-to-date? | | |
| Website Development | Do you have a website? Is it current? | | |
| Funding (Non-Profits) | Do we have a comprehensive list of funding sources, grant deadlines, etc? | | |
Note that the questions shown are intended to provoke thought, but they are not representative of all the questions that could be asked.
Once you have finished the list, fill in the priority column. Indicate by number the most important tasks; the MOST important will be number “1,” the second most important number “2,” and so on.
You will begin your work with the top five priorities. This will help to provide a manageable list. When those are nearing completion, consider tackling the remaining items on the list.
**Task 4: Action**
In the “Resources” section of this handbook you will find a sheet called the “Action Item.” Five of these sheets are numbered 1 through 5 and one does not have a number. The intent of this workbook is to tackle the top five, but if you need or want to add to the list, there is an Action Sheet with no number that you may copy and continue to use.
Action Item 1 will be the first priority from the list completed in Task 3. Begin each Action Sheet with its corresponding System from the list. For Example:
Let’s say you noted that Inventory was your first priority for improvement. The Action Sheet will start out looking like this:
| START DATE | DUE DATE | WHAT | WHO | IN PROGRESS | DONE |
|------------|------------|----------------------------------------------------------------------|-------------------|-------------|------------|
| 9/1/2014 | 11/05/2014 | Identify and segregate obsolete inventory | Warehouseman | | |
| 11/05/14 | 11/07/2014 | List all obsolete items on E-bay (Craigslist) for sale; discount them to cost or below | Owner | | |
| 11/08/2014 | 11/09/2014 | Notify customers of items for sale on E-bay (or Craigslist) | Owner’s Assistant | | |
| 11/15/2014 | 11/15/2014 | Ship out sold items; donate the remainder | Warehouseman & Owner | | 11/20/2014 |
You may not have a Warehouse Director or Assistant. This is an opportunity to contact the Local EDD, a Temp agency, your local Community College, or job board. You may be able to hire someone on a temporary basis to help. Some College programs can place students who help you while meeting their requirement for unpaid internship hours.
Chapter 2 - Evaluate Your Resources
Task 1: Key Employees
If you have employees, you no doubt know them quite well. As small business owners, or working in a community organization, you spend a lot of time with your co-workers. Now is the time to step back and evaluate if there is someone in that group you consider to be a “key employee.” The best situation often occurs when you can identify an employee who has the potential to take over some day or has indicated an interest to someday buy the business.
A key employee is someone who shows promise to be the next *you!* He or she is usually your “go-to” person – the one you can always count on to accomplish the task. This person is often quite an integral part of the success of the business.
This person may be a relative, a sibling, an in-law, a friend, a board member, an acquaintance, a professional advisor, or one of your current employees.
Next, consider whether or not this person may have potential for someday running and owning your business. Remember your goal as stated in Chapter 1! To get there you will need to think of that day when you are no longer at the helm of your ship.
You may find a combination of several employees that have talents in various areas that together might make a good fit for your business transition. One may be an expert in sales, another in purchasing, and a third for customer service and accounting. Diversity does make a business stronger.
Of course keep in mind the work you did in Task 2 of Chapter 1. If your replacement must have a license, special training, or certain skills, you will need to consider this in your evaluation.
If you do not have a likely candidate, consider looking to the following resources:
- Registered Apprenticeships, Community Colleges, and Universities with training programs that fit your business
- Local job placement agencies – someone with management experience that fits your business
- Economic Development Corporations
- Business Recruitment Firms
- Business Brokers
- Real Estate Agents with clients moving to the area for a lifestyle change
- People you meet and know in social, trade, and local civic groups
- A competitor looking to increase his market share by buying yours
Your goal is to get the notion out that you are looking to hire a key management type employee. If you are going to be public about it, be sure to talk with your existing employees to quell their concerns or fears.
Additional sources:
Some Community Colleges operate business transition programs. If that service is available locally, it will be a big help to you in your transition. They may have a person to help you facilitate your business transition.
Look for Entrepreneurship programs that are focused on placement for graduates ready to work for business owners as their mentee.
**Task 2: Assess Your Need for Help and Find It**
It’s fairly simple. Many businesses are run entirely by one person or a couple. You will need to find skilled help to accomplish your “fix-it” list identified earlier. This is also the time to start assessing the possibilities for the person who may become the next business owner.
You may want to hire your first employee or retain an unpaid intern to help you make the improvements you identified in Chapter 1. This person may not necessarily be your future key employee. This will simply be the help you need to accomplish the task.
Example:
You are a plumber. You have never created a website, but you identified this as something that should be accomplished and have prioritized it as one of your top five projects. It may benefit you to contact the local college for students that desire or need
work experience (or internship hours) and are proficient in website development. This may provide you with the help you need to quickly check this off your list.
Additional Tools:
Some organizations find assessment tools useful in helping them identify the talents needed in their employees and to build a team that functions well together. You may wish to consider a tool that measures an individual’s strengths and talents.
The Gallup Research team created the *science* of strengths from more than 50 years of research and incorporated this collective knowledge into their bestselling books and assessment tool, the Gallup “StrengthsFinder.” These surveys have helped millions of people and business owners discover what they do best. They have developed a tool to help you measure your teams’ talents and strengths. The results will help you to look for individuals that have the talents that fit your business and will facilitate your Exit Strategy.
They have also expanded this research to develop the “Entrepreneurial StrengthsFinder.” This product is aimed at helping people identify their entrepreneurial talents.
These and other products are low in cost (about $10 per StrengthsFinder assessment), easy to facilitate, and available to everyone that has access to their online products.
You may learn more at their website:
**Gallup’s Strength Center.com**
Another useful tool is the Keirsey Temperament assessment. The Keirsey tool is the modern version of a Myers-Briggs style personality assessment combined with a Holland RIASEC style career inventory.
What makes the Keirsey unique is the assessment report provides active links to the web databases ONet and Career Builder based on individual career results. It can be used not only to build awareness about one’s strengths and skills in the workplace, but also what types of work environments and activities one is most suited to based on personality patterns.
You may learn more at their website:
**http://www.keirsey.com**
Chapter 3 - Scrub your Financials and Approximate the Value of Your Business
Most business owners operate their businesses year-to-year with two goals:
1. Maximize benefits to ownership: Income, assets, owner benefits.
2. Minimize tax liability: Reduce reported taxable income even to a taxable loss through purchases, leases, benefits, depreciation, and other deductible expenses.
The business owner needs to take a different financial approach to successfully:
- sell the business
- maximize the sales price
- provide financing for the buyer
Task 1: Review Your Financial Data
Ideally, for three years prior to selling your business through this exit transition, the business may need to consider implementing the following changes in financial policy:
- Maximize sales and net income (often this is already an ongoing goal)
- Demonstrate opportunity for growth with historical growth trends in profits
- Reduce expenses by:
- Removing questionable expenses (example: inventory you took home for personal use)
- Reduce or remove excess owner compensation, benefits and discretionary spending (paying for an owner’s club membership or personal debt)
- Report all income even if the owners have not done so in the past and
- Separate personal and business spending
Start today!
If you are not sure where to start or if this is even necessary, have a discussion about this topic with your tax preparer, accountant, or bookkeeper. Let this person know you want to show all the profits that this business actually will earn.
This work may be done at the same time you are working through the steps in Chapters 1 and 2. It takes time because you are not going backward, you are moving forward.
*Tip:* You do not want to change historical financial information if you have already filed a tax return or provided the information to other partners, board members, or lenders. If you have not done any of these, it is acceptable to revise the current year’s financials to meet this goal.
You may understand this concept but feel you need a more compelling argument. Here it is:
1. Not including personal or questionable business expenses in your financial statements is the correct approach to business finances
2. It accurately depicts the true income that the business can produce
3. It demonstrates to a prospective owner the opportunity for growth and income
4. It has been proven that you will obtain a higher selling price. This will more than compensate for higher taxes resulting from a higher taxable income, and
5. It helps a new business owner to obtain financing.
To help you better understand the effect income has upon the selling price of your business, it is time to consider how to value a business for sale.
**Task 2: Estimate value of the business**
Refer to the Resources section of this manual and review the document provided by MasterCard Worldwide titled, “Buying and Selling a Small Business.” It provides an easy step-by-step approach to obtaining a value for your business. This document is also available online at this address:
http://www.mastercard.com/us/business/en/pdf/MasterCard_BuySell_Sept21.pdf
**MasterCard Worldwide Buying and Selling A Small Business**
You may decide to enlist “help” with this project. If so, return to Chapter 2 and review the list of possible resources that may work on this with you.
Chapter 4 - Exploring Your Succession Options
Whether you are considering selling your business outright, creating a family business transition, creating an opportunity for a key employee, planning a change in leadership, or facilitating a succession plan that includes a major expansion, you will need a plan. This may be referred to as a Business Plan, an Exit Strategy, or a Succession Plan. Any or all will work as long as it addresses your goal (Remember The Goal - Chapter 1?).
Your assignment in this chapter involves:
- Being creative – Rely on the instincts you have developed about your business/organization
- Being open – There are so many ways to achieve this goal – consider all possibilities with an open mind
- Being realistic – If your only child is now a Physician practicing in Boston, it is unlikely he or she will want to return home and run the family’s plumbing business.
The numbers are almost too large to comprehend. Think about 50% to 70% of the businesses in your community right now. Next consider what your community looks like if half of those were to close in the next few years. That’s the magnitude of what communities are facing as early as 2017. Combined with much tighter lending requirements, less available financing, and a lagging economy, it’s clear small business owners need help like never before, and to stay viable non-profits need long-term leadership plans. If this wave is not addressed aggressively in each community, it can start a downward spiral that will ripple outward and affect entire regions. It’s already begun. But it can also be a great opportunity for owners and for young entrepreneurs – with planning and action now, it can be a win-win situation. That’s why it’s so important to use the tools in this guide to help your business continue even when you no longer wish to run it.
A short recap:
- In Chapter 1 you established your personal goal and took a critical look at the work that should be completed while preparing to transition.
- In Chapter 2 we examined the resources you will need and ways to evaluate your current and future workforce to create the team for the future.
- In Chapter 3 we looked at some of the financial scrubbing to help show your business’s true worth and potential.
In this chapter we will establish the Succession Plan.
Hopefully by now you have identified some potential successors. They may be key employees, future key employees, family members, non-family members, strangers, or you may just have “nothing.”
If you were not able to identify a key employee, you are probably looking at a traditional sale of your business. The best approach to finding an outlet for selling your business is to find a qualified broker who specializes in selling your type of business.
The good work you have done up to this point is still valid and will help you to more easily sell your business. Much of what you have done will provide the basis of the information your broker will ask you to provide.
If you are in a leadership role in a non-profit corporation, the remaining work will not be as oriented towards the financial compensation, but in creating the plan to find and train the new leadership.
For the remaining business owners, the fun is starting.
**Task 1: Create a Transition Plan**
- Consider options: outright purchase, gift/bequest, or a combination of these if you are looking to help a family member or friend.
- If the business is to be purchased, consider financing options including financing from an external party or from the retiring owners on a payment basis over time.
- Establish a timeline for implementation of the succession plan. A timeline tool has been included in the Resources chapter.
- Incorporate mentoring, job shadowing, and realistic timelines for the transition.
- Stress the importance of “follow up” after the transition.
Not every family business will survive and many do fail, primarily due to differing family interests and the inability of the next generation to grow the business. Taking these five steps now will save money and time and will help assure the continued success of your business.
Use “case studies” and successful mentors whenever possible. Business people are often willing to share their success, challenges, and failures to assist others in the process.
Keep in mind that a succession plan can take many different forms. At this point it is a very creative process. Let’s look at a case study that details just one of the many possible plans.
Case Study
Great Balls of Fur Dog Grooming
This dog grooming business was started in 1984 by its owner, Wanda Waybright. Wanda has been saving for retirement and is ready to sell her business so that she may spend more time with her grandchildren.
This has been a tough decision for Wanda. She loves dogs and has a steady clientele. Many of her dog owner clients have been using her services since she opened. Wanda recognizes that when she is no longer involved with the business, she may not stay connected with the customers she considers friends. It has been a tough decision that is motivated by her desire to do something else (Goal: spend more time with grandchildren). It will help Wanda to keep her goal in mind as she moves forward with her decision.
Chapter 1; Task 1 – Goal:
Sell my business so that I will have time to spend with my grandchildren and travel with my family...
With her goal set, Wanda spoke to her bookkeeper about the best way to accomplish this goal. The bookkeeper referred her to the Economic Workforce Development Director at Feather River College. They were able to give Wanda ideas, direction, and provide a succession planning advisor to help her down the path of exiting her business.
She met with the advisor and was provided a manual (Succession Planning for Small Business). She began following the steps and was somewhat surprised that there was a little more involved than she expected. However, her years as a successful business owner had given her the confidence to know she was up to the challenge and was very grateful to have a clear path to follow. She already had her goal, so next she answered the question:
Chapter 1; Task 2 - Can someone else run this business?
Luckily for Wanda the answer was a strong yes! There was a pet grooming program at their local community college and she had often employed interns from this program. One of the interns was quick to learn and very good with both the animals and their owners. Wanda hired her on the spot. Julie Ryan had been working for Wanda for just over seven years. She was well trained as a groomer, but did not have much experience running a business. Another option available to Wanda was the local college Entrepreneurship Program. There was a steady supply of graduates every year. Wanda considered this as some additional reinforcement that, yes, someone else could definitely run this business.
The next task was somewhat difficult. Wanda had to take a critical look at her business systems. She spoke with her bookkeeper to learn a little more about the kind of information already tracked and what the possibilities for improvement were. She determined that her business could use some work in the following five areas (in priority order):
**Chapter 1; Task 3 – Areas for improving the business and its value**
1. Website – Great Balls of Fur did not have a website
2. Customer tracking – Even though it was possible to track the customers who frequented the business in her “QuickBooks” accounting software, Wanda had never done so.
3. Inventory – The business sold some supplies. If tracked in the QuickBooks inventory, it would also document where she purchased these items.
4. Email – Wanda decided that it made sense to begin reaching out to customers via email to let them know about new products or last minute openings for appointments.
5. Improve and update signage; the strip mall location was bland and difficult to find on a customer’s first visit.
**Chapter 1; Task 4 – Create action sheets for each project**
She then created Action Sheets for each of these projects.
Moving on to assessing her resources, Wanda spoke with her planning advisor, Clint Westwood, on the best approach for talking to an employee about the idea of buying the business.
**Chapter 2; Task 1 - Key Employee**
Wanda’s Succession Planning Advisor suggested she first reassure the employee that her job was safe and simply offer her the option of considering becoming the next owner of the grooming business. Give the person some time to think it over and discuss it with her close advisors. In some instances, it may be prudent to ask the employee to maintain confidentiality about the conversation.
This is not a time to get into specifics or discuss pricing. It is a time to explore the option and discover whether or not there is an interest.
In Wanda’s case, Julie was excited at the opportunity but felt she could never afford to buy it. Wanda said she understood the concern and hoped that it could be addressed in a way that would benefit them both.
Wanda came away with the potential for a key employee business transition. If this had not been the case, then Wanda would have started looking for other sources of potential buyers (refer to Chapter 2 for sources).
In the meantime Wanda and her team began working on the improvement Action Items.
Chapter 2; Task 2 – Locate skilled help
Wanda knew how to use the Internet but was not at all familiar with how to create her own website. Clint, her Succession Planning Advisor, connected her with the college’s Entrepreneurship program where they helped her find an intern who could help. Ivy Leaguer, a student in the program, worked with Wanda to develop content, purpose, and marketing focus for the site. She also showed Wanda how to easily update the content any time. The intern also introduced her to Constant Contact, an email marketing service (Action Items 1 and 4).
Wanda’s bookkeeper helped create forms for obtaining customer information, along with a system for notating customers’ names on the sales receipts so that their names and information could be entered into QuickBooks. This will be an ongoing process as clients visit the shop (Action Item 2).
Starting inventory in QuickBooks has been a fairly involved project. She had assistance from her bookkeeper and Julie Ryan. First, they created an inventory code system and notated the items sold by code and description on the sales receipt. In time, they had all of the items they sold entered in QuickBooks and inventory updated on a regular basis as the bookkeeper entered the sales receipts and purchase invoices (Action Item 3).
Once the other four priorities had been completed or were in steady progress, Wanda met with a local sign company and contracted to have new signs made. She was able to tie the look of the new signs together with the updated look of the new website (Action Item 5).
At first, Wanda felt this task would be overwhelming, but once she identified the help she needed and broke the steps down on the Action Sheets, everything moved along very smoothly.
Wanda had a standing appointment once each month to meet with her bookkeeper to go over her financial statements. She had decided early on that she would not have time to groom dogs and do all of the bookkeeping for the business. At first the financial statements made little sense, but over the years her bookkeepers taught her what she needed to know.
Chapter 3; Task 1 – Review your financial data.
Wanda met with the bookkeeper, Heather Chambers, to specifically discuss this concept of scrubbing the books. Heather was quite familiar with the concept as she had done this before with other clients. Heather confirmed for Wanda that there would not be much needed in this process because Wanda had always been quite careful about keeping personal and business transactions separate. Wanda wondered why all business owners would not do that.
Heather explained that some business owners are highly focused on minimizing their tax liability, so they bill as much as possible to their businesses to lower net taxable income. Wanda asked if it was illegal to do so. Heather explained that sometimes it is
blatantly wrong, such as paying for a child’s ballet lessons and calling it an expense to their grocery store business. However other times it is very gray, so some bookkeepers and business owners choose to take the deduction as an expense even if it is unclear whether it is actually deductible.
She cited the example of the same grocery store owner who often took groceries home for the family but did not “buy” them from the store. Technically, he did “buy” the groceries when he stocked his store. However this is a good example of the type of expenses that should be “scrubbed” from the financial statements when readying a business for sale. This expense will effectively cease when a new owner takes over, so start now and show the true revenue and net income that the business is making.
Wanda understood the explanation and asked Heather to look carefully at all expenses. Heather said she would let Wanda know if she found anything that should no longer be paid for by the business.
**Chapter 3; Task 2 – Business Value**
Wanda supplied Heather Chambers (bookkeeper) with the MasterCard guide to determining the buying or selling price of a business. Heather worked through the process using the business’ financial data and asset listings. The two also spent time identifying assets that were not recorded anywhere.
Heather used various Internet sites to attach values to used equipment and discounted the cost of older inventory. After some work, they concluded that the business value was approximately $75,000.
**Chapter 4; Task 1 – Create a Transition Plan**
Wanda met with her **Succession Planning Advisor** at Feather River College. Her advisor, Clint Westwood, assisted her by explaining how a Mentor/Mentee relationship may be created with an incoming business owner that is (or could become) a key employee. Wanda expressed Julie’s Ryan’s concern that she could not afford to buy the business and asked about business loans from banks. Clint suggested that as part of the process to creating the transition plan, Wanda and Julie meet with a business consultant at their local Small Business Development Center (SBDC) who could advise them on the various funding options available to them.
The result of the plan that Julie and Wanda agreed to was this:
Business selling price: $75,000
Julie would agree to a regular payroll withholding equal to $2.00 per hour to be paid into an escrow account for the purchase of the business. Julie works 2,000 hours per year and would accumulate $12,000 in three years.
Wanda would begin mentoring Julie in all aspects of how to run the business. Clint Westwood helped them work out the timeline and details of the Mentor/Mentee relationship.
Wanda had an attorney draw up a buy/sell agreement that provided the following:
- Confidentiality Statement
- Purchase Price ($75,000)
- Goals and objectives for the next three years
- Partnership % would be awarded at the end of year 1 for 5% in exchange for the payment of $4,000 then accumulated in the escrow account. This would be repeated at the end of the next two years. By the end of year 3, Julie would be a 15% owner and sharing income at that percentage.
- By the end of year 3 Julie would have been a partial owner for two years and demonstrated her ability to run the business profitably. She would meet the bank’s criteria to be eligible for a small business loan.
- The SBDC Consultant prepared them for the possibility that the bank may only wish to loan 70% of the purchase price (75,000 x 70% = $52,500). At the completion of 3 years Julie needs $63,000 ($75,000 – 12,000 paid from payroll withholding) to finalize the purchase of the business. Wanda agreed to work as a consultant by phone for two years at a rate of $500 per month to make up the difference between what Julie needed to pay her and the bank was willing to loan ($500 x 24 months = $12,000). This meant that Wanda received slightly more than $75,000 for the total price (an additional $1,500).
| Selling Price: | $ 75,000 |
|----------------|-----------|
| 5% Payment Year 1 | $ (4,000) |
| 5% Payment Year 2 | $ (4,000) |
| 5% Payment Year 3 | $ (4,000) |
| Needed from a bank loan | $ 63,000 |
| Actual Bank Loan | $(52,500) |
| Shortfall | $ 10,500 |
| Wanda's Consulting Agreement | $ 12,000 |
| 2 years at $500 per month: | $ - |
| Amount Remaining Due: | $ - |
| Actual Selling Price Paid to Wanda | $ 75,000 |
| Difference between Amount owed by Julie and Bank Loan | $ 1,500 |
| Wanda's Consulting Agreement ($12,000-10,500) | $ 1,500 |
| Total consideration received by Wanda | $ 76,500 |
Wanda’s consulting retainer made her available to Julie to answer questions over the first 24 months that Julie was a full owner, but allowed Wanda the complete flexibility to travel and spend time with her grandchildren.
Wanda also agreed to a non-compete for the 24 months following the sale. She also agreed to “fill-in” as a paid employee when employees might be unavailable due to vacation or illness for as long as she pleases. This gave Wanda a way to occasionally see and be seen by long-time customers.
Wanda admits that without the assistance of the Succession Planning Advisor at Feather River College she would not have developed this succession plan.
Julie never dreamed she would someday be the owner of business where she had been happily employed.
Conclusion: A Positive Economic Impact
Due to the commitment of the team to make this business transition work, the local community benefited in the following ways:
1. A healthy profitable business with a business plan that helped them grow
2. A bank loan and additional investment into the business
3. Retention of two full-time jobs
4. Enough growth to add two additional groomers placed through the local community college program, and
5. A happy retired business owner who is travelling and spending more time with her grandchildren.
Chapter 5 – Resources
Reference files – To be printed
- “Action Item” sheets with timelines
- A simple guide to valuing your business, including the basics of a buy/sell agreement; *Compliments of MasterCard, Worldwide.*
- Project Timeline template
- Start-up checklist for the new business owner
- Checklist for closing a business entity
Feather River Community College:
This project was funded and sponsored by a collaboration between The New World of Work at Feather River College, The Coleman Foundation, the National Community College Association of Entrepreneur Education, and the California Community Colleges’ Chancellor’s Office.
About the Author:
Susan Wright is a Certified Management Accountant and Principle Partner in Partners Plus Consulting. She has over thirty years’ experience working in and for businesses in the Northern CA region. She specializes in all areas of small business finance, accounting, organizational management, and business plan development. She lives in Redding with her husband, two cats, and a dog. She may be reached at firstname.lastname@example.org. 7/23/2014
SUCCESSION PLANNING FOR SMALL BUSINESS
|
The SMHI Large Ensemble (SMHI-LENS) with EC-Earth3.3.1
Klaus Wyser¹, Torben Koenigk¹,², Uwe Fladrich¹, Ramon Fuentes-Franco¹, Mehdi Pasha Karami¹, Tim Kruschke¹
¹Rossby Centre, Swedish Meteorological and Hydrological Institute (SMHI), 601 76 Norrköping, Sweden
²Bolin Centre for Climate Research, Stockholm University, 106 91 Stockholm, Sweden
Correspondence to: Klaus Wyser (email@example.com)
Abstract. The Swedish Meteorological and Hydrological Institute used the global climate model EC-Earth3 to perform a large ensemble of simulations (SMHI-LENS). It consists of 50 members, covers the period 1970 to 2100 and comprises the SSP1-1.9, SSP3-3.4, SSP5-3.4-OS and SSP5-8.5 scenarios. Thus, it is currently the only large ensemble that allows for analyzing the effect of delayed mitigation actions versus no mitigation efforts and versus earlier efforts leading to similar radiative forcing at year 2100. We describe the set-up of the SMHI-LENS in detail and provide first examples for its application. The ensemble mean future changes of key variables in atmosphere and ocean are analyzed and compared against the variability across the ensemble members. In agreement with other large ensemble simulations, we find that the future changes in the near surface temperature are more robust than those for precipitation or sea level pressure. As an example for a possible application of the SMHI-LENS, we analyse the probability of exceeding specific global surface warming levels in the different scenarios. None of the scenarios is able to keep global warming in the 21st century below 1.5 °C. In SSP1-1.9 there is a probability of approximately 70 % to stay below 2 °C warming while all other SSPs exceed this target in every single member of SMHI-LENS during the course of the century. We also investigate the point in time when the SSP5-8.5 and SSP5-3.4 ensembles separate, i.e. when their differences become significant, and likewise when the SSP5-3.4-OS and SSP4-3.4 ensembles become similar. Last, we show that the time of emergence of a separation between different scenarios can vary by several decades when reducing the ensemble size to 10 members.
1 Introduction
Global climate is changing due to anthropogenic greenhouse gas emissions (Stocker et al. 2013), and global mean temperature has already increased by more than 1 °C compared to pre-industrial temperature levels. However, the observed temperature time series show large variations on top of the warming trend, resulting in periods of up to decades with reduced or accelerated temperature increase. Changes in climate forcing parameters such as solar irradiance or aerosols and internal climate variability contribute to this observed variability. Especially at the regional level, internal variability leads to large uncertainties on time scales up to several decades (e.g. Hawkins and Sutton 2009, Hawkins 2011). Long-term station observations at different places across Europe show large internal variability of temperature (Moberg et al. 2000). Observations from Uppsala in Sweden, Europe’s longest continuous temperature time-series, show that 30-year mean winter
temperature has varied by several degrees between different observed 30-year periods (Moberg and Bergström 1997). Internal climate variability contributes also to uncertainties in future climate projections. At the regional scale, the variability of temperature and particularly precipitation and atmospheric circulation can be as large or even larger as the trends for several decades ahead (Knutti and Sedlacek 2012, Hawkins and Sutton 2012, Deser et al. 2012, Deser et al. 2014, Fischer et al. 2014, von Trentini et al. 2019, Suarez-Gutierrez 2018, Bengtsson and Hodges 2019, Rondeau-Genesse and Braun 2019, Koenigk et al. 2020). In recent studies with large ensembles of CMIP5 models Maher et al. (2020) show that temperature trends in the near-future are largely dominated by internal variability. In agreement with this, Marotzke (2019) found that internal variability masks most of the effects of an efficient implementation of the Paris Agreement until year 2035.
The main source for internal atmospheric variability in middle and high latitudes is the variability of annular modes of circulation (Deser et al. 2012, Horton et al. 2015). Dai and Bloecker (2019) identified the Inter-decadal Pacific Oscillation and Arctic sea ice as main sources for internal climate variability. To robustly distinguish trends in precipitation and atmospheric circulation due to greenhouse gas emissions from internal variability and to better cover the range of possible future climate paths and their extremes in future climate projections, a large ensemble of climate model simulations is necessary. Large ensemble simulations with global coupled models are therefore an important tool. Already in the context of the Coupled Model Intercomparison Project Phase 5 (CMIP5) several global modelling centers performed large ensembles (LENS); 30 members and more have been performed with the following global climate models: CanESM2 (Kirchmeier and Young 2017), MPI-ESM1.1 (Maher et al. 2019), CSIRO-MK3-6 (Jeffrey et al. 2013) and CESM1 (Kay et al. 2015). The MPI Grand Ensemble (MPI-GE) consists of historical and different future projection simulations (rcp26, rcp45, rcp85) while the other ensembles cover parts or the entire historical period and focus on the rcp8.5-scenario. Lehner et al. (2020) used all of these single model LENS to analyse the contribution of internal variability to uncertainties in future climate change. They found that these LENS-simulations provide a good representation of the entire CMIP5 model diversity in many situations.
Also for CMIP6, a few modelling centres have already performed LENS simulations. Ensemble simulations with 30 or more members for at least the historical time period have been performed with CanESM5 (Swart et al. 2019), CNRM-CM6-1 (Voldoire et al. 2019), GISS-E2-1-G (Kelley et al. 2020), IPSL-CM6A-LR (Boucher et al. 2020), NorCPM1 (Bethke et al. 2019), MIROC6 (Tatebe et al. 2019), and SPEAR (Delworth et al. 2020).
An overview on all existing larger ensemble simulations is provided by the Multi Model Large Ensemble Archive (https://www.cesm.ucar.edu/projects/community-projects/MMLEA/ (last accessed 2021-05-09), Deser et al. 2020), which is part of the US CLIVAR Working Group on Large Ensembles. A large number of interesting studies based on large ensembles has already been published (see https://esd.copernicus.org/articles/special_issue1037.html (last accessed 2021-05-09) and Maher et al 2021 for an excellent overview). Examples for the use of large ensembles are studies of the internal variability to obtain robust estimates of extremes (e.g. Kirchmeyer-Young et al. 2017, Haugen et al. 2018) as we intend to do in future studies; or the disentanglement of internal variability and scenario uncertainty (e.g. Marotzke 2019, Lehner et al. 2020, Maher et al. 2020) that is important for the detection of a forced climate change.
In this study, we present and describe the Swedish Meteorological and Hydrological Institute Large Ensemble (SMHI-LENS), performed with the EC-Earth3 model. The simulations follow the CMIP6-protocol (Eyring et al. 2016) and a particular focus is on the effect of mitigation actions for climate change. Thus, the SMHI-LENS comprises the SSP1-1.9, SSP3-3.4, SSP5-3.4-OS and SSP5-8.5. With the exception of SSP5-8.5 these are all Tier-2 scenarios from ScenarioMIP (O’Neill et al. 2016). The wider EC-Earth consortium has already started to contribute ensemble members to the Tier-1 scenarios and it is planned to extend the SMHI-LENS with the Tier-1 scenarios provided access to sufficient computing resources. The Tier-2 scenarios done here are an important extension that allow e.g. for analyzing the effect of delayed mitigation actions versus no mitigation efforts (SSP5-3.4-OS versus SSP5-8.5) and versus earlier efforts leading to similar radiative forcing at year 2100 (SSP5-3.4-OS versus SSP3-3.4). To our knowledge, to date no LENS simulations of SSP4-3.4 and SSP5-3.4-OS exist. The inclusion of SSP1-1.9 allows for analyzing in detail the climate change signal in a world following roughly the Paris agreement. The effect of an overshoot in the forcing has been investigated previously in a smaller ensemble with the CESM model based on CMIP5 forcing (Sanderson et al. 2018). Sanderson et al. (2017) find some impact on land temperature at the time when the difference between the overshoot and steadily increasing forcing are largest, yet the differences are not significant at the gridpoint level. The differences in sea level and Arctic sea-ice are found to be not significant even during the overshoot, and there is no evidence for a long-term climate impact of the overshoot at the end of the 21st century and beyond.
Another motivation of performing the SMHI-LENS was to provide boundary conditions for downscaling simulations with regional models that include a large part of the internal variability. Several studies with regional climate models with boundary forcing from a single model large ensemble have already been published (e.g. Leduc et al. 2019, von Trentini et al. 2019, Mankin et al. 2020, Böhnisch et al. 2020, von Trentini et al. 2020). Through clever selection of members from the large ensemble almost the entire range of uncertainty due to internal variability within a certain region or for certain processes can be spun up with a relatively small number of regional downscalings.
2 Model and simulations
2.1 Model description
The SMHI-LENS was generated with EC-Earth3 version 3.3.1 that has been used in the GCM configuration that comprises IFS cy36r4 for the atmosphere and NEMO3.6 including the sea ice model LIM3 for the ocean (Döscher et al. 2021). The atmosphere model uses the spectral truncation T255 combined with a linearly reduced Gauss grid with a resolution of about 80 km (N128), and the ocean model uses the tri-polar ORCA1 grid with a 1-deg resolution over large parts of the globe and a mesh refinement at the equator. In the vertical there are 91 levels in the atmosphere with the top level at 1 Pa, and 75 layers in the ocean with an upper level of about 1 m and 24 levels distributed over the uppermost 100 m.
The time step is 45 minutes in the atmosphere and ocean, and the coupling between atmosphere and ocean is done at every time step.
The forcing for all simulations is identical to what has been used for making the EC-Earth3 contribution to CMIP6. In particular we use the GHG concentrations, solar radiation, stratospheric ozone concentration and stratospheric aerosols (volcanoes) for CMIP6. The anthropogenic aerosol forcing MACv2-SP (Stevens et al. 2017) has been implemented in EC-Earth3 and is used in combination with a climatological pre-industrial aerosol background. Time varying land use is accounted for by using pre-computed vegetation cover, type and leaf area indices; these forcings have been obtained from previous historical and scenario simulations with EC-Earth3-Veg, the model configuration that includes the dynamic vegetation model LPJ-Guess.
2.2 Initial conditions
To create the set of initial conditions for SMHI-LENS we start from 6 members (r1-3, r7-9) of the historical experiment for CMIP6 that was done with EC-Earth3-Veg. From each of the 6 members we branch off breeding simulations on Jan 1, 1970. These 6 breeding simulations are each run for 20 years with constant forcing. From these 6 breeding runs we then select 50 initial states for the atmosphere and the ocean as initial conditions for the large ensemble (Table 1). The initial date for each member of the large ensemble is set to Jan 1, 1970.
To check the ensemble spread after initialization and whether it captures the full intra-model variability, we compare the ensemble spread in SMHI-LENS in year 1970 (annual mean) to EC-Earth3 historical simulations for CMIP6 (23 members) which have been integrated independently for already 120 model years at this point (Fig. 1). There are differences between the two ensembles but these are not significant (at the 5% level) neither for the means nor for the variances of the two ensembles and therefore the two ensembles can be considered independent samples of the same distribution.
2.3 Simulations
The 50 members of the historical ensemble were started in 1970 from the 50 initial conditions, using the forcing provided for the historical experiment for CMIP6. The historical simulations run until the end of 2014 followed by several scenarios that cover the 2015-2100 period with forcings according to ScenarioMIP. Each of the scenarios comprises 50 members that start from the end of the corresponding member of the historical experiment. The following scenarios are included in the large ensemble:
- SSP5-8.5 is a high-end scenario that yields a strong warming signal, marking the upper end of a plausible evolution of the climate
- SSP5-3.4-OS is an overshoot scenario with a strong warming until 2040 (using the same forcing as SSP5-8.5 until 2040), followed by a curbing and net-negative emissions after 2060 resulting in a radiative forcing of 3.4 W m\(^{-2}\) in 2100. The difference between SSP5-8.5 and SSP5-3.4-OS will tell about the efficacy of mitigation measures that set in around the mid-century. Following the CMIP6 protocol, the SSP5-3.4-OS experiment branches off from the SSP5-8.5 experiment in 2040 which means results for SSP5-3.4-OS are only available for the 2040-2100 period.
• SSP4-3.4 also has a radiative forcing of 3.4 W m$^{-2}$ in 2100, but without the peak and decline of SSP5-3.4-OS. Differences between these two scenarios can tell us about the impact of a previous overshoot and possible non-reversible effects when the forcing at the end of the century is similar.
• SSP1-1.9 is the low-end scenario addressing the needs of the Paris Agreement to reach the 1.5 degree warming level, marking the lower end of a plausible evolution of the climate.
All these scenarios except SSP5-8.5 are from Tier-2 of ScenarioMIP. The wider EC-Earth community is planning to provide between 20 and 30 members of the Tier-1 scenarios, and therefore it was considered more valuable to extend the EC-Earth contribution to CMIP6 with Tier-2 scenarios. Furthermore, the selection of scenarios for the large ensemble was guided by questions about the impact of mitigation and overshoot. Nevertheless, the low- and high-end scenarios of the SMHI-LENS span the full range of possible futures.
2.4 Data output
Limitations on storage capacity do not allow us to save the full model output as it has been done for CMIP6. Instead we select a subset of variables from ocean and atmosphere, and save only daily and monthly means. Tables 2 and 3 list the variables for atmosphere and ocean, respectively. All data from the large ensemble are CMIP6 compliant and are available from any ESGF data portal as part of the CMIP6 data holding. Realisation_id’s r101 to r150 from the EC-Earth3 model have been reserved for the large ensemble.
The limited output does not allow for any in-depth analysis of extreme events such as strong storms or an extreme precipitation event on sub-daily timescales. We therefore plan to re-run selected periods with full output and, for this purpose, have saved the full model state on Jan 1 of each year, for each member and for each scenario.
3 Results
The aim of this work is to provide an overview of SMHI-LENS and we therefore focus only on main characteristics of major variables. To benefit from the large number of ensemble members, we not only look at ensemble means but also at the ensemble spread as a measure of the internal variability, both in global mean timeseries as well as in the analysis of regional climate change patterns. More detailed studies with the data from SMHI-LENS are in preparation.
3.1 Timeseries
Timeseries of global annual mean temperature and precipitation are displayed in Fig. 2, together with timeseries of AMOC and the Arctic minimum sea ice extent. The ensemble spread is illustrated by the shaded area that shows the full spread, minimum to maximum of the ensemble. The scenarios continue the historical experiment after 2014 with little differences among the different scenarios. They start diverging first around year 2040 for three out of four variables considered here. The exception is the Arctic sea ice minimum where the reduction in SSP5-8.5 is stronger than in the other scenarios already
after year 2030 (Fig. 2d). The temperature timeseries (Fig 2a) shows the anticipated warming of the different scenarios with a strong warming signal in SSP5-8.5 that keeps increasing throughout the 21st century while SSP1-1.9 first overshoots slightly and then stabilises around the mid-century at a level only slightly higher than the present-day climate. Increasing temperatures lead to a more vigorous hydrological cycle with increased global precipitation (Fig 2b) and a decrease in the Arctic sea ice minimum (Fig 2d). We also find a distinct impact on the AMOC that first weakens compared to present-day conditions but partly recovers in all scenarios except for the high end SSP5-8.5 scenario (Fig 2c). The ensemble spread in AMOC is high for the historical period but shows a reduction in all scenarios after the middle of the 21st century. The AMOC is closely connected to the oceanic convection in the Labrador Sea and its variability (Brodeau and Koenigk 2016, Koenigk et al. 2021). The convection in the Labrador Sea becomes weaker in all scenarios until the middle of the 21st century (not shown), which reduces the ensemble mean and ensemble spread of AMOC. The mitigation measures as represented in SSP5-3.4-OS lead to more or less immediate impacts on global mean temperature and precipitation while an imprint onto the AMOC becomes visible with a delay of approx. 20 years.
3.2 Regional patterns
The ensemble mean annual mean 2m air temperature (tas) averaged over 1995-2014 shows the well-known north south gradients with minimum values below -20°C in the polar regions and up to 30°C in the tropics (Fig. 3 a). The typical discrepancies from the zonality, for example the tongue of warm air in the northeastern North Atlantic and North Pacific and colder tas over the parts of the northern hemispheric continents are well reproduced. Details on biases in the mean climate in EC-Earth3 are provided by Döscher et al. (2021). The standard deviation of tas, averaged over 1995-2014, across model members shows substantial internal variability with largest variability near the ice edges of the North Atlantic Arctic sector where one standard deviation reaches values of 3 K and higher. Also, mid and high latitude regions of the northern hemispheric continents and the ice regions around Antarctica experience high internal tas variability. In subtropical and tropical areas, one standard deviation of tas variability is generally below 0.5 K.
The ensemble mean temperature change until the middle of the 21st century shows a clear Arctic amplification with the largest warming rates in regions where even winter sea ice disappears, especially in the Barents and Kara Seas. Here, warming exceeds 5 K in all scenarios until 2040-2059, and reaches even more than 10 K in the SSP5-3.4-OS and SSP5-8.5 scenarios. Over the continents, the warming is generally larger than over the oceans, and is smallest over the mid-latitude oceans of the southern hemisphere with warming rates below 1 K.
The general warming patterns are similar in the different scenarios. The warming until 2040-2059 is somewhat more pronounced in SSP5-3.4-OS and SSP5-8.5 compared to SSP4-3.4 and SSP1-1.9. The difference between the scenarios increases until the end of the century. While especially SSP5-8.5 shows an accelerated tas increase until 2080-2099, tas in SSP1-1.9 does not increase any more compared to 2040-2059. The tas increase in SSP5-3.4-OS is small after 2040-2059 compared to SSP5-8.5, and is similar to the one in SSP4-3.4 by the end of the century. This shows the impact of the strongly decreasing greenhouse gas emissions in SSP5-3.4-OS after 2040.
Figs. 3 k-n display the ratio between mean tas change and internal variability. The ensemble mean tas change is divided by one standard deviation of tas change across the ensemble members. The tas change has been calculated separately for each ensemble member by subtracting tas in 2040-2059 (2080-2099) from 1995-2014 in the same ensemble member. If this signal-to-noise ratio is 2 – meaning that the change signal exceeds two standard deviations of variability of tas change - would indicate that around 97.5 % of all members show a warming signal. The spatial pattern of one standard deviation of variability of tas change across members (not shown) is very similar to the standard deviation of tas in 1995-2014 (Fig. 3 b) but the amplitude is slightly higher, particularly for the change until 2040-2059 (not shown). The variability of tas changes until 2080-2099 is slightly smaller than until 2040-2059 (not shown) because of compensating decadal scale periods of internal variability (Koenigk et al. 2020).
The ratio between mean tas change until 2040-2059 in SSP1-1.9 and variability exceeds 2 for most regions of the world except for the northern North Atlantic and the Southern Ocean around Antarctica. Also, parts of western and northern Europe show a comparatively small ratio. At the end of the century, the ratio between mean tas change and variability of change in SSP1-1.9 increases in many regions, mainly due to the larger signal under stronger forcing. Under the SSP5-8.5 scenario, the ratio is substantially higher than in SSP1-1.9 - only the subpolar gyre regions and Nordic Seas show a ratio between mean change until 2040-2059 and variability of change below 2. At the end of the century, the ratio is 2.5 - 5 in the northern North Atlantic and exceeds 10 in most areas of the world, showing the clear dominance of the change signal over the variability. The small signal to noise ratio in the northern North Atlantic can be linked to the reduction in the AMOC (compare Fig. 2c) and the related northward heat transport into the North Atlantic.
The spatial annual mean precipitation (pr) distribution in EC-Earth3 is dominated by low values in polar regions and subtropical regions and high pr in the tropics, in maritime mid-latitude regions and along mountain ranges (Fig. 4 a). EC-Earth3 generally well reproduces the observed pr pattern but it shows a double intertropical convergence zone bias, dry biases over some parts of central and western Eurasia and wet biases over parts of the polar regions and the subtropical oceans of the southern hemisphere (for details see Döscher et al. 2021).
The largest variability of annual mean pr averaged over 1995-2014 across model members occurs in the tropics, along the Gulf Stream and North Atlantic Current as well as in the subpolar gyre and along the ice edges of the North Atlantic Arctic sector. These are also some of the areas that show the largest projected pr changes: pr is significantly increased over the tropical oceans, except for the tropical Atlantic where both regions with increased and decreased pr occur, and in the polar regions, particularly along the ice edges. Over the tropical land regions, the signal is noisy with both positive and negative signals. The Sahel zone shows increased pr. Further, it generally gets wetter over most of mid and high latitudes. In most of the subtropical ocean regions of the southern hemisphere, pr is significantly decreased. The change pattern agrees well across the different emission scenarios. As for tas change, the amplitude of pr change until 2040-2059 is somewhat larger in SSP5-3.4-OS and SSP5-8.5 compared to SSP4-3.4 and SSP1-1.9. Until the end of the century, P-changes substantially increase in SSP5-8.5 and the differences across scenarios become more pronounced. SSP4-3.4 shows also further amplified
pr changes while the additional changes in SSP5-3.4-OS and particularly in SSP1-1.9 are small. As for tas, SSP5-3.4-OS shows similar P-changes as SSP4-3.4 at the end of the century.
Note that we discuss absolute values of P-change and not values in percentage. In percentage, the largest changes occur over the northern hemispheric polar regions with up to 50-100% increase in SSP5-8.5 at the end of the century compared to 1995-2014 (not shown). Here, the ratio of the mean P-change versus variability of the trend across members (Figs. 4k-n) is largest and exceeds 2 in SSP1-1.9 in 2040-2059 and reaches up to 10 in SSP5-8.5 in 2080-2099. In SSP5-8.5, the mean P-change dominates over the variability in southern polar and tropical regions as well. However, in many mid and sub-tropical regions, the variability is larger than the mean change signal in all scenarios and even for changes until the end of the 21st century.
The atmospheric circulation and its potential future changes are highly relevant for the spatial distribution of tas and pr and their future changes. To characterize the circulation, we analyse the sea level pressure (psl, Fig. 5). The mean psl in the period 1995-2014 represents well the observed psl and biases in EC-Earth3 are between -1 and +1 hPa in most areas of the world (Döscher et al. 2021). In the North Pacific, the Aleutian Low is slightly too pronounced, in the subpolar North Atlantic, psl biases of up to 2 hPa exist and over parts of the Antarctic, psl is up to 2 hPa too high compared to ERA5-reanalysis data. The standard deviation in these regions is considerably smaller than the differences to ERA5 and therefore the biases are consistent among the majority of ensemble members in the sense that they have the same sign. The psl variability across members is generally largest in mid and high latitudes of both hemispheres, and one standard deviation of psl variability reaches here up to around 1 hPa (Fig. 5 b). In the tropics, the psl variability is small and one standard deviation is below 0.2 hPa.
The change of psl until 2040-2059 is small and not significant at the 95% significance level in many areas. The change in psl is asymmetric, more pronounced in southern hemispheric mid-latitudes and some subtropical and tropical regions where changes are positive and can reach up to 1 hPa in SSP1-1.9 and SSP3-3.4-OS and up to 1.5 hPa in SSP5-3.4-OS and SSP5-8.5. Over the tropical Pacific Ocean, the mean zonal circulation weakens in the SMHI-LENS future scenarios with slightly increased psl over the west Pacific, in comparison to the psl over the east side of the Pacific, therefore showing an eastward shift of the Walker Circulation, and negative values of the Southern Oscillation Index (SOI: difference in psl between Tahiti in the eastern Pacific and Darwin in northern Australia). These future changes in the mean circulation observed in all the scenarios, show a very similar pattern to the positive phase of El Niño Southern Oscillation variability, when the Walker circulation weakens and the rising branch over the Maritime Continent shifts to the east in comparison to neutral conditions. A shift towards more El Niño-like conditions under global warming agrees with the majority of previous CMIP3 and CMIP5 projections (Vecchi et al. 2006, 2007; Bayr et al. 2014) although Kohyama et al. (2017) find that also a more La Niña–like trend could be a physically consistent response to warming.
In polar regions, psl generally decreases in all scenarios in both hemispheres. The spatial psl change pattern remains similar in 2080-2099 compared to 2040-2059. However, as for tas and P, the amplitude of psl change in SSP5-8.5 is strongly enhanced compared to the period 2040-2059. In polar regions, psl is reduced by more than 3 hPa and it is increased by up to 3 hPa in southern hemisphere mid-latitudes. In contrast to the other SSPs, SSP5-8.5 shows significantly increased psl in most
northern hemispheric ocean regions as well. Despite these larger changes until 2080-2099 in SSP5-8.5, the variability strongly dominates over the mean change in all polar regions and in most of Eurasia, North Africa and North America as well as over the North Atlantic. In SSP1-1.9, the mean change is only robust across model members in larger parts of the area between $10^\circ$ N and $40^\circ$ S.
3.3 Probability of exceeding specific surface warming levels
An important question of climate adaptation is the likelihood for passing a specific surface warming level (SWL). The large ensemble allows for a quantitative estimate of the probability of surpassing a given temperature. It is common practice to express the warming relative to pre-industrial levels, in other words the difference between the global mean temperature in the future scenarios and the global mean pre-industrial temperature. The pre-industrial temperature is computed as the ensemble mean of 23 realisations of the historical EC-Earth3 experiments for the 1850-1870 period that have been published on the ESGF. For each year we then compute the fraction of the SMHI-LENS members that exceed a given warming threshold.
The probability for exceeding three different SWLs in the four scenarios is shown in Fig 6. All members of SSP5-8.5 exceed SWL3 after 2060 (Fig 6a). SSP5-3.4-OS that branches off from SSP5-8.5 after 2040 reaches only about 20% probability for exceeding SWL3 during 2060-2080 and shows lower probability thereafter, demonstrating clearly the impact of the mitigation that is underlying this specific scenario. SWL2 and SWL1.5 are tightly linked to the Paris Agreement that aims at avoiding warming above 2 or 1.5 degrees. Our results with the 4 scenarios used here reveal that only SSP1-1.9 is likely to keep the warming below 2 degrees (Fig 6b). There still is an almost 40% probability for exceeding SWL2 even in SSP1-1.9 around the middle of the century after which the probability becomes lower again. In the other scenarios the likelihood to pass SWL2 reaches 100% around year 2040 in SSP5-8.5 and about 20 years later in SSP4-3.4. The more ambitious 1.5 degrees warming target cannot be reached by any of the scenarios used here, the likelihood to exceed SWL1.5 reaches 100% before 2040 with little variation among the scenarios which makes them almost indistinguishable in Fig 6c. The future analysis of SMHI-LENS will include a more thorough investigation of the impact from an overshoot in the climate trajectory.
3.4 Separation of scenarios
Experiments SSP5-3.4-OS and SSP4-3.4 both end with an approximately equal climate forcing of 3.4 W m$^{-2}$ in 2100 yet their pathway is rather different (Fig. 2) with SSP5-3.4-OS showing an overshoot in the middle of the century while SSP4-3.4 shows a constantly increasing temperature response. The question arises if and when SSP5-3.4-OS becomes different from SSP5-8.5, and when SSP5-3.4-OS approaches and becomes similar to SSP4-3.4. To answer these questions, we compare the ensembles of the annual mean temperature from each of these experiments and decide when and where the differences between the ensembles are statistically significant with help of a Student’s t-test. The t-score between two ensembles is calculated as
where \( m \) denotes the ensemble mean, \( s \) the std deviation and \( n \) the number of members in each ensemble. The difference between the two ensembles with 50 members each is significant at the 95% level when \( t \) exceeds \( t^*(0.95,49) = 2.009 \) for the two-sided 95% confidence level and 49 degrees of freedom.
We apply Eq (1) to the annual temperature means of the SSP5-8.5 and SSP5-3.4-OS experiments to compute the t-score in each gridpoint and for each year. The t-scores are then smoothed with a 5-yr running mean. Fig. 7a displays the year after which the smoothed t-scores become larger than \( t^*(0.95,49) \), indicating the year after which the differences between SSP5-8.5 and SSP5-3.4-OS have diverged enough for their difference being statistically significant. Similarly, Fig. 7b shows the year after which the difference between SSP5-3.4-OS and SSP4-3.4 is not significant any longer, telling when the two scenarios have converged.
The differences in annual mean temperature between SSP5-8.5 and SSP5-3.4-OS emerge in most regions between 2050 and 2060, with the exception of Antarctica and the Southern Ocean, Africa south of the Sahara, India and central Australia where the differences become significant after 2060 (Fig 7a). The temperature differences between SSP5-3.4-OS and SSP4-3.4 show larger spatial variability (Fig 7b). There is a hint of a North-South gradient in the year when the difference between these two scenarios ceases to be significantly different. In the Northern Hemisphere the last year with a significant difference occurs during the 2060-2080 period in most gridpoints, with notable exceptions in Northern Canada and Greenland. In the Southern Hemisphere the temperature differences are significant until 2080-2100 over large areas of the Oceans, Africa and Antarctica. Over South America and Australia the temperature difference between SSP5-3.4-OS and SSP4-3.4 ceases to be significant in the 2070-2080 period.
How does this result depend on the ensemble size? The t-score that is used to assess if the temperature differences between 2 scenarios are significant is proportional to the square root of the ensemble size. Furthermore, the \( t^* \) value for testing significance depends on the degrees of freedom that in turn depend on the number of ensemble members. Let us now assume that for each of the scenarios used here we have a hypothetical ensemble with the same mean and variance as the large ensemble, but only 30 (or 10) members. The t-scores for the difference between two scenarios are first scaled by \( \sqrt{3} \) (\( \sqrt{5} \)) and then compared to \( t^*(0.95,29) = 2.045 \) (\( t^*(0.95,9) = 2.262 \)) to assess significance at the 95% level. This approach reflects the larger uncertainty that follows from the smaller sample size. The results for the time of detection of significant differences between SSP5-8.5 and SSP5-3.4-OS and the time of cessation of significant differences between SSP5-3.4-OS and SSP4-34 are shown in Figs. 7c and d for 30 members, and Figs. 7e and f for 10 members. Comparing Figs. 7a, c and e we find that the difference between SSP5-8.5 and SSP5-3.4-OS would become detectable about a decade later if the ensemble consisted of only 10 members instead of 30 or 50. The impact of a reduction of the ensemble size is more drastic when it comes to the differences between SSP5-3.4-OS and SSP4-34 (Figs. 7b, d and f). The time of emergence and cessation of significant differences doesn’t differ much between 50 and 30 members, the large differences appear first when
the ensemble size is reduced to 10 members. Many regions and most notably the Northern Hemisphere continental areas do not show any significant temperature differences between these two scenarios during the 21st century if only 10 ensemble members were available. And even in regions where differences between SSP5-3.4-OS and SSP4-3.4 would still be significant, the differences would stop being significant several decades ahead of the time when it happens with 50 or 30 members, thus reducing the period where the two scenarios can be considered to be distinct from each other. This would be a clear drawback for any studies of the impact from the overshoot in SSP5-3.4-OS as the number of available years for such an analysis would be limited. Fig. 7 is a clear example for the need of sufficiently large ensembles when assessing differences between certain scenarios to assess the impacts of mitigation measures.
The analysis of the emergence/cessation of significant differences between different experiments could be expanded to all scenarios, this would however be beyond the scope of the present paper to provide an overview over SMHI-LENS and will be saved for future studies.
4 Discussion and conclusions
Here we have presented an overview of the SMHI Large Ensemble that consists of 50 members done with the EC-Earth3 model. We described the process of creating a large set of initial conditions for 1970 starting from 6 members of the ensemble of the historical experiment that in turn had branched off at various points in time from the piControl experiment. The future projections, following the ScenarioMIP-protocol, have shown the anticipated results: a strong warming with SSP5-8.5, an overshoot in the warming with SSP5-3.4-OS in the middle of the century followed by a negative warming trend towards the end of the century, a continuously increasing warming with SSP4-3.4 reaching the same level of warming as SSP5-3.4-OS towards 2100, and a limited warming with SSP1-1.9. Not surprisingly, the projections in the large ensemble are in line with other CMIP6 results, the advantage of the large ensemble being that it allows us to better quantify the impact of internal variability on the changes and thus derive results subject to reduced uncertainty.
When comparing the mean future change against the variability of the change across the ensemble we have found that the future changes in the near surface temperature are significant almost everywhere but not for precipitation or sea level pressure. This result agrees qualitatively with earlier studies involving large ensembles yet there are regional differences between SMHI-LENS and large ensembles from other models. Deser et al. (2012) show in agreement to our results that the mean temperature change signal is much more robust than pr and psl change signals. For pr and psl, they found similar regions with large and small ratios between mean change and internal variability as this study. Both regions and amplitudes of standard deviation of tas, psl and pr trends agree relatively well with our results. Compared to results from the MPI-ESM1.1 Grand Ensemble (MPI-GE, Maher et al. 2019), the variability of psl changes until the end of the 21st century is comparable in pattern and amplitude as well. However, the mean psl change signal differs somewhat. While most regions show small psl change in MPI-GE similar to SMHI-LENS, Maher et al. (2019) found two areas with stronger responses as in SMHI-LENS: psl increases from Greenland across the northeastern North Atlantic to central and southern Europe and a
strong negative signal over the Bering Sea region. On the other hand, the psl decrease over the Arctic seems to be smaller in MPI-GE.
The slightly reduced internal variability for tas and pr changes until the end of the century (2080-2099) compared to the middle of the century (2040-2059) in SMHI-LENS is in line with findings for Europe by Koenigk et al. (2020) based on the MPI-GE and the CanESM2-Large Ensemble. They linked this reduced internal variability to compensating decadal scale periods of internal variability, which enhance and slow down the mean trend due to greenhouse gas emissions.
An important application for large ensembles is risk assessment; as an example, we analyze the probability for exceeding a specific warming level in a given scenario. Many impact studies have looked at the effects when a certain warming is passed (e.g. Donnelly et al. (2017), Teichmann et al. (2018), Koutroulis et al. (2018)), but only few studies so far have analysed the probability itself for passing a specific warming level. We show that none of the scenarios used here is able to keep global warming in the 21st century below 1.5 degrees. In SSP1-1.9 there is an approximately 70% probability for the warming to stay below 2 degrees warming while all other SSPs exceed this target during the course of the century. SSP5-8.5 is the only one of the used scenarios to definitely pass even a 3-degree warming. SSP5-3.4-OS has a 20-40% chance to exceed SWL3 temporarily during the 2050-2090 period, but at the end of the century the risk of warming beyond this threshold is very small. For comparison, based on the CMIP5 model ensemble, Jiang et al. (2016) show that the probability to exceed the 2 °C global warming level before the year 2100 is 26, 86, and 100% for the Representative Concentration Pathways 2.6 (RCP2.6), 4.5 (RCP4.5), and 8.5 (RCP8.5) scenarios, respectively, with the median years of 2054 for RCP4.5 and 2042 for RCP8.5.
To demonstrate the importance of a sufficiently large ensemble we look at the point in time when the differences between the SSP5-8.5 and SSP5-3.4-OS ensembles become significant, and when the SSP5-3.4-OS and SSP4-3.4 ensembles become similar. When assuming that the ensemble would retain the mean and variance but with only 10 members, we show that the time of emergence of a separation between SSP5-8.5 and SSP5-3.4-OS can vary by several decades. The impact of the ensemble size is even more apparent when looking at the time when SSP5-3.4-OS and SSP4-3.4 stop being significantly different. With 50 members this happens in the 2nd half of the 21st century implying that the overshoot and the gradually increasing scenario really lead to distinct responses in the temperature. With only 10 members the overshoot becomes much less detectable and there are large regions where the temperatures in SSP5-3.4-OS and SSP4-3.4 are indistinguishable.
A major reason for making large ensemble simulations is to assess the natural variability and thereby obtain an estimate for the uncertainty in future projections. It is common practice to take the ensemble spread as an estimate for the natural variability. However, the internal variability differs between models and thus the ensemble spread will also be different for ensembles created with different models (Lehner et al 2020). The EC-Earth3 model is among the models with highest variability in the piControl run (Parsons et al. 2020) for reasons not yet fully understood. Thus, SMHI-LENS likely has a large ensemble spread which implies that the uncertainty estimates such as confidence intervals get wider. Furthermore, the difference between ensembles for the scenarios needs to be bigger for their clear separation which has an impact on the time when scenarios are similar or significantly different. The results presented here are thus model dependent and could look different for other large ensembles done with a different model.
The results presented here are just examples for what kind of analyses and risk assessment are possible with a large ensemble. In the future it is planned to extend this kind of work to regional warming signals, the frequency of occurrence of extreme events (e.g. heat waves), detection and attribution studies, and other variables (e.g. precipitation, sea-ice).
**Code availability**
The EC-Earth model is restricted to institutes that have signed a memorandum of understanding or letter of intent with the EC-Earth consortium and a software license agreement with the ECMWF. Confidential access to the code and to the data used to produce the simulations described in this paper can be granted for editors and reviewers; please use the contact form at http://www.ec-earth.org/about/contact.
**Data availability**
All results from SMHI-LENS are available from any ESGF datanode as part of CMIP6, search for `<model_id>` EC-Earth3 and `<variant_label>` in the range r101i1p1f1 and r150i1p1f1.
**Author contribution**
All authors contributed to the design of the experiments. KW performed the simulations. TK and KW performed the analyses, prepared the figures and an initial draft of the manuscript. All authors contributed to the discussion of the results and the final manuscript.
**Competing interests**
The authors declare that they have no conflict of interest.
**Acknowledgements**
The computations were enabled by resources provided by the Swedish National Infrastructure for Computing (SNIC) at the National Supercomputer Centre at Linköping University, partially funded by the Swedish Research Council through grant agreement no. 2018-05973. We’d like to thank the editor and two anonymous reviewers for their valuable comments and suggestions that helped us to improve the manuscript.
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19
| parent_id of CMIP6 historical EC-Earth3-Veg from which breed experiment branches off at 1970-1-1 | branch_time in breed experiment | SMHI-LENS variant_label_id |
|---|---|---|
| r<n>ilp1fl | 1990-1-1 | r<n+100>ilp1fl |
| | 1988-1-1 | r<n+106>ilp1fl |
| | 1986-1-1 | r<n+112>ilp1fl |
| | 1984-1-1 | r<n+118>ilp1fl |
| | 1982-1-1 | r<n+124>ilp1fl |
| | 1980-1-1 | r<n+130>ilp1fl |
| | 1978-1-1 | r<n+136>ilp1fl |
| | 1976-1-1 | r<n+142>ilp1fl |
| | 1974-1-1 | r<n+148>ilp1fl |
Table 1: Relationship between the members of the CMIP6 historical experiment done with EC-Earth3-Veg and the members of the SMHI-LENS. <n> is the realisation_id (member) of the CMIP6 historical experiment (1-6). The branch_time 1974-1-1 is only used for r1 and r2 of the CMIP6 historical experiment, yielding members 149 and 150 of the large ensemble.
| Short name | Name | Type | Frequency |
|------------|---------------|------|-----------------|
| ta | Temperature | PL | monthly + daily |
| ua | Zonal wind | PL | monthly + daily |
| va | Meridional wind | PL | monthly + daily |
| hus | Specific humidity | PL | monthly |
| zg | Geopotential | PL | monthly + daily |
| tas | 2m temperature| SFC | monthly + daily |
| Variable | Description | Level | Frequency |
|----------|------------------------------|--------|-----------------|
| tasmax | 2m minimum temp | SFC | monthly + daily |
| tasmin | 2m maximum temp | SFC | monthly + daily |
| hurs | 2m relative humidity | SFC | monthly + daily |
| huss | 2m specific humidity | SFC | monthly + daily |
| pr | Total precipitation | SFC | monthly + daily |
| prc | Convective precipitation | SFC | daily |
| prsn | Snowfall | SFC | monthly + daily |
| evpsbl | Evaporation | SFC | monthly |
| sfcWind | 10m wind speed | SFC | monthly + daily |
| uas | 10m wind component | SFC | daily |
| vas | 10m wind component | SFC | daily |
| clt | Total cloud cover | SFC | monthly |
| clwvi | Liquid water path | SFC | monthly |
| clivi | Ice water path | SFC | monthly |
| prw | Precipitable water | SFC | monthly |
| psl | Mean sea level pressure | SFC | monthly + daily |
| snw | Snow water equivalent | SFC | monthly |
| mrro | Runoff | SFC | monthly |
| rsds | SW flux downward | SFC | monthly + daily |
| rsus | SW flux upward | SFC | monthly |
| Short name | Name | Type | Frequency |
|------------|-----------------------|-------|---------------|
| rlds | LW flux downward | SFC | monthly + daily |
| rlus | LW flux upward | SFC | monthly |
| hfls | Latent heat flux | SFC | monthly |
| hfss | Sensible heat flux | SFC | monthly |
| rsdt | SW flux downward | TOA | monthly |
| rsut | SW flux upward | TOA | monthly |
| rlut | LW flux upward | TOA | monthly |
| tsl | Soil temperature | Soil | monthly |
| mrso | Soil moisture | Soil | monthly |
Table 2: Saved atmosphere variables. The column labelled “Type” indicates if a variable is saved at the surface (SFC), at top of the atmosphere (TOA), in the soil or on pressure levels (PL). Monthly means are saved on 19 pressure levels (plev19 in the CMIP6 tables) and daily means/maxima on 3 pressure levels (plev3).
| Short name | Name | Type | Frequency |
|------------|-----------------------|-------|-----------|
| tos | Sea surface temperature | SFC | monthly |
| zos | Sea surface height | SFC | monthly |
| sos | Sea surface salinity | SFC | monthly |
| siconc | Sea ice cover | SFC | monthly |
| sivol | Sea ice volume | SFC | monthly |
| siu | Sea ice zonal velocity| SFC | monthly |
| siv | Sea ice meridional velocity | SFC | monthly |
| Variable | Description | Level | Frequency |
|----------|--------------------------------------------------|-------|-----------|
| mlotst | Mixed layer depth | SFC | monthly |
| hfx | Zonal heat flux (vertically integrated) | SFC | monthly |
| hfy | Meridional heat flux (vertically integrated) | SFC | monthly |
| thetao | Temperature | 3-D | monthly |
| so | Salinity | 3-D | monthly |
| uo | Zonal velocity | 3-D | monthly |
| vo | Meridional velocity | 3-D | monthly |
Table 3: As Table 1 but for saved ocean variables. All ocean variables are saved as monthly means. 3-D variables are provided on the native 75 levels of the ORCA1L75 grid.
Figure 1: Ensemble spread in the first year after the initialization of the large ensemble (red), compared to the ensemble spread of the regular EC-Earth3 ensemble for year 1970 of the historical experiment for CMIP6 (blue). The whiskers denote the full ensemble spread (min-max), the boxes the 25- to 75-percentile range, and the stars the median of the distribution. Tas and pr are the annual global mean near surface temperature and precipitation, respectively. AMOC is the annual average of the monthly maximum Atlantic Meridional Overturning Circulation at 26.5 deg N. Nino34 is the annual average SST in the Nino3.4 region (5N-5S, 170W-120W).
Figure 2: Timeseries of global annual mean near surface temperature, precipitation, AMOC and minimum Arctic sea ice extent in the historical and scenario experiments. Thick lines denote the ensemble means and shaded area the full ensemble width. The scenarios branch off from the historical experiment in 2015 except for SSP5-3.4-OS that branches off from SSP5-8.5 in 2040. The magenta lines marked with plus signs denote the ERA5 re-analysis (Hersbach et al. 2020) for temperature and precipitation, and the OSI-450 sea-ice observations (Lavergne et al. 2019).
Figure 3: a) Ensemble mean annual mean 2m air temperature, averaged over 1995-2014.
b) One standard deviation of annual mean 2 m air temperature, averaged over 1995-2014, across ensemble members.
c) - f) Ensemble mean 2m air temperature change between 2040-2059 and 1995-2014 for SSP1-1.9, SSP4-3.4, SSP5-3.4-OS and SSP5-8.5. All coloured areas show significant changes at the 95% significance level based on a two-sided student t-test.
g)- j) Same as c) - f) but for changes until 2080-2099.
k) - n) Ratio between mean 2m air temperature change between 2040-2059 (2080-2099 in m and n) and 1995-2014 and one standard deviation of the variability of temperature change across ensemble members in SSP1-1.9 (k and m) and SSP5-8.5 (l, n). The change is calculated for each individual ensemble member as the difference between temperature in the future period (average over 2040-2059 or 2080-2099) and temperature of the reference period (average over 1995-2014) in the same ensemble member.
Figure 4: Same as Fig. 3 but for annual mean precipitation. Precipitation changes that are not marked coloured are either not significant at the 95% significance level or small (below +/- 1mm/month).
Figure 5: As Fig. 3 but for sea level pressure. Sea level pressure changes that are not marked coloured are either not significant at the 95% significance level or small (below +/- 0.2 hPa).
Figure 6: Probability for exceeding a given Surface Warming Level (SWL) in the different scenarios. The SSP5-3.4OS experiment branches off from SSP5-8.5 in 2040 according to the CMIP6 experimental protocol and thus there are no data for this scenario before 2040. The shaded area denotes the 95% confidence interval obtained from bootstrapping with 1000 repetitions.
Figure 7: Year of emergence of significant temperature differences between SSP5-8.5 and SSP5-3.4-OS (a,c,e), and the year when the temperature differences between SSP4-3.4 and SSP5-8.5-OS ceases to be significantly different (b,d,f). The results for the full ensemble (50 members) are shown in (a) and (b). The results assuming ensembles with the same ensemble mean and variance are shown in (c) and (d) assuming 30 members, and in (e) and (f) assuming 10 members. White colour denotes regions where the differences between SSP4-3.4 and SSP5-8.5-OS are never significant.
|
JULY 21, PICNIC AT USUAL SPOT UNDER THE BIG OAK
From The Prez
July seems to be when I add more iris to my garden than I have room for. I am sure that many of you have the same problem. I now take the under performers, slow growers, non-bloomers and “ugly” ones and banish them from my yard. Karin and I have set up a “probation” bed with room for 30 new rhizomes. First impressions are a must and those that do not impress us are getting the chop.
On the road to becoming a judge, I have finished my Student status and Alleah Haley, the ARVP of Region 14, has moved me to Apprentice. I attended a 2 hour judges training class in Sacramento this month and hopefully will gain more experience as the year progresses. I am learning quite a bit about iris and also how the region and national parent organizations work. I never knew that growing iris would take me this far.
Do not forget—no meeting this month, just the annual picnic. I hope to see you there! ☺️Craig
2018 Calendar
Annual July Picnic
Saturday, July 21... 11:00 A.M.–3:00 P.M.
Harvey West Park
Potluck and Auction
Annual Sale
Dig ........................................ Joe’s Ranch
Thursday, August 2nd ... 9 A.M.–1:00 P.M.
Sale .... Deer Park Shopping Center
Saturday, August 4th . 9 A.M.–12:00 P.M
Sale ... Cabrillo/Aptos Farmer Mkt
Saturday, August 11th 8 A.M.–12:00 P.M
Sale MPC/Monterey Farmer Mkt
Friday, August 17th .... 9 A.M.–12:00 P.M
Regular Meeting
Friday, August 17....................... 7:30 P.M.
TBA
Refreshments
potluck
If you have iris for the August sales and need help digging them please contact Charley for an email sent to request help.
Bring good recent iris to the picnic! See page 3 for ideas. The better the iris the better the raffle!
July Birthdays
Barbara Wiles July 2
Fred Valentine July 11
Pat Wisdom July 14
Henry Rojas July 15
Tiffany Rush July 28
Culture Tips
The summer months are time to dig and replant your irises. But in our climate you can continue to replant into the early fall.
This is the time to cut out or snap out the spent stalks and clean out any weeds that compete with the iris rhizomes for nutrients. If you want a neater garden, clean out the dead leaves and cut off diseased parts of leaves.
All incoming new rhizomes—and even those you are replanting—should be dipped in a bleach drench made up of 1 part bleach to 9 parts water. Submerge at least to well above the “bulb” base of the rhizome. Leave in the solution for 10–15 minutes. Then, some suggest to clean them off in clear water. I have found this isn’t really necessary, but, this part is: The rhizomes MUST be completely dry when you replant them. The chlorine must be completely evaporated or your new spring growth will be all wrinkled and the bloom not normal.
Keep your newly replanted irises wet enough. A deep watering will last about a week. Keep your newly replanted irises watered until the rhizome show four full new leaves, then you can cut back to less frequent watering. If you plant late, the fall rains should do the job.
A comment on the bane of iris growing—and over 200 specie—is mustard seed fungus. It was rarely a problem in our mild climate but it now is the number one disease we face. That is why dipping is so important. It kills any spores on the plant, but does help little if you have it in the garden since mustard seed is soil borne. It makes its appearance in late spring into the summer. It shows as a creamy rot at the base of the fan and has no smell. Small spores—the size of mustard seeds—show in the rot. Immediately dig the plant, clean out the infected area and dip in the bleach solution. I found it best not to replant these rhizomes for a couple of weeks so you can be sure the rhizome is “clean”.
Since the fungus spores can be viable for years, remove the soil where the plant was growing and get rid of it. Replanting a “clean” rhizome in the same soil, exposes it to getting the fungus. Always get rid of any showing any signs of the telltale white webbing. Also dusting the resulting hole with a chlorine cleanser (Comet) before refilling is helpful. Joe
Upcoming Meetings
At the upcoming events, when you talk about our meetings, be sure to mention the programs. For the September meeting Joe will be doing his usual “Bearded Other Than Tall” talk. The October meeting will be PCI. When we know the subject of the August meeting, we will let you know.
Board of Directors 2018
President
Craig Tarr firstname.lastname@example.org 408 425-7207
Past President/Vice President
Barbara Hanson email@example.com 831 335-4949
Treasurer
Larissa Daniel firstname.lastname@example.org 831 724-9162
Secretary
Brenda Wood email@example.com 831 724-5415
Jim Cummins firstname.lastname@example.org 831 438-1369
Show Chair
Charley Kearns email@example.com 408 315-1520
Newsletter
Joe Ghio firstname.lastname@example.org 831 423-3656
Ann Pike email@example.com 831 426-8855
1 Year Board
Riley Probst Catt Porter
Rosa Radicchi Karin Tarr
Joan Scanlon Kathy Wood
2 Year Board
Contacts
Hospitality & Refreshments
Shirley Trio firstname.lastname@example.org 209 551-6323
Birthday List
Wayne Crabbs email@example.com 408 353-4089
MBIS 2nd Iris Sale
When Saturday, August 11th, 2017
Where Aptos Farmers’s Market
Cabrillo College
Set up Time 7:30 a.m. We need help for the set up.
We hope you will help us sell during the morning. We will need additional iris for this sale, so if you have iris and did not get them to Joe’s Ranch or the Deer Park Sale, get them here to Cabrillo or drop them by a member’s house!
Sale Time 9:00 – to noon (or sell out).
MBIS 3rd Iris Sale
When Friday, August 17th, 2018
Where Monterey Farmers’s Market
Monterey Peninsula College
Set up Time 8:30 a.m. We need help for the set up.
We hope you will help us sell during the morning. We will need additional iris for this sale, so if you have iris and did not get them to Joe’s Ranch or the Deer Park Sale, get them here to MPC or drop them by a Craig’s house!
Sale Time 10:00 – to 2 (or sell out).
Iris for Picnic
It is time to dig some of the increase from the iris you won as door prizes last year, and bring them to the July picnic. If you are a new member, these irises should be available at the picnic so be sure to be there. Members share their best irises at this picnic. Here is a list of the door prizes collected at last year’s picnic. If you have these bring some of their increase. Please check the newsletter page of our website for a complete description of these iris. If you have purchased newer iris and have increases please bring those. If you are a new member plan on purchasing a lot of chances to win some good iris!
Door prize iris from last year’s picnic: 1. Adriatic Noble, Bashful Love, Berry Blast, Black Mirror, Blood Moon, Blue Me Away, Boundary Waters, Bring Me Diamonds, Close to My Heart, Color Fling, Color Wheel, Cosmic Voyage, Dark Storm, Deeper Meaning, Dressed to Impress, Electric Blast, Express Yourself, Feel the Thunder, First Prize, Folies Bergere, Framed, Fuse, Handful of Magic, I like Pretty Things, In the Moment, Into the Wild, Island Drumbeat, Ivory Castle, Just Before Sunrise, Late Hours, Mammoth Orange, Marital Bliss, Marry the Night, Milk in My Coffee, Mood Ring, Morning World, Optic Overload, Pink Sugar, Point of Interest, Positive Attitude, Priceless Memories, Restless Spirit, Rocket Fuel, Rum is the Reason, Rustic Charm, Sherbet Bomb, Shy Girl, Slice of Heaven, Soft Elegance, Star Maker, Tantalizing, Triple Take, Variety Show, and Who Did It.
Other recent door prize iris are: A Grape Fit, Absolute Crush, Adoranova, Affair to Remember, Ancient Airs, Are We In Love, Avenue of Dreams, Ayes Alert, Barbara Rider, Bet the Farm, Big Picture, Billowing Waves, Bold Pattern, Born This Way, Boston Cream, Caramel n Chocolate, Catch My Breath, Celtic Tartan, Century Bound, Cozy Cotton, Cross My Heart, Custom Rim, Danse Macabre, Decked Out, Destination Fabulous, Double Wedding, Down to the Wire, Dueling Bands, Electric Burst, Espionage, Far Engine, Football Hero, For Veronica, FX Schreiner, Gentle Soul, Go Berserka, Gracious Me, Grafenau Remembered, High School Honey, Hospitality, Jimmy G, Julia My Dear, Lavender Lemon Cake, Layer Cake, Lemon Jade, Let’s Fly, Little Marilyn Brown Baby, Magic Mirror, Make Mine Magic, Makin’ Good Time, Marrying Kind, Passion For Fashion, Power Down, Puzzled, Quiet Content, Rainbow Sunset, Restless Tide, Ruby Red Dress, Servin’ Up Sparkle, Serving Wench, Shivaree, Spirit of Alejandro, Splendid Spring, Sudden Bliss, Ten All Round, Tickle My Fancy, User Friendly, Valley of Dreams, Vibrato, Western Edge, Mego, What a Beauty, and Wingman.
Door Prize Iris
There are a few items that didn’t increase well, overbloomed, or had other problems due to this spring’s odd weather, so some substitutions will be necessary this year.
Show Bonus Iris
If you helped out at the show, you will receive an iris from this year’s door-prizes. A ticket has been put in the hat for each shift you worked during the show, the more shifts you worked, the more tickets with your name on it are in the hat. So, the more shifts you worked, the better your chances of getting an early choice. Joe is selecting iris for this drawing. Each helper will come away with an iris. If you are not able to be at the picnic, please ask someone to choose for you and bring you that iris.
Picnic Memos
We are back this year to our original site for our Picnic at Harvey West Park. It is the middle picnic area opposite the baseball field and rest rooms on Coral Street.
If you can not attend the picnic be sure to ask someone to pick up the iris you won during the year’s meetings. Unclaimed iris are put into the auction.
Picnic, Raffle and Auction
Area B Harvey West Park, Santa Cruz
July 21st, 2018, 11:00 a.m.
Area B is in the center of the picnic area under the big oak tree.
Door Prizes
This is the time to pick up the door prize irises you won during the year and also the iris for the show workers. If you can’t make the picnic, have someone pick them up for you or they will be auctioned off. Repeat! All iris not claimed will be auctioned!
Directions to Park
Coming toward Santa Cruz on Hwy 17 or Hwy 1, follow the signs to Half Moon Bay. At the first light turn northwest on Hwy 9 towards Felton. Turn left at the first possible turn, left again at the stop sign on Limekiln Ln.; it turns into Coral St.; follow it to the end. Turn right on Evergreen and go straight ahead to the park. Look for the picnic tables under the big oak tree, and for the MBIS banner on the left of the road.
Food and Beverages
Bring a dish to share with 10–20 others (salad, veggies, main dish or dessert) and whatever you would like to drink.
What Else to Bring
Your own plate, utensils, and glass. A table cloth if you want to cover the table. Paper bags for your new irises. A hat if you like, chair to be more comfortable, money or checkbook to pay for incredible iris bargains, and last, but not least bring iris! Bring increases of last year’s door prizes and any other newer varieties. You don’t need to cut the fans. Please write the names with a permanent marker on the lower part of the middle leaf.
Iris Dig for August Sale
We will be digging iris for the sale at Joe’s ranch on Thursday, August 2nd from 9:30 a.m. until we are finished (about noon or 1 p.m.). All members are encouraged to attend! Take Freedom Blvd and make a left Corralitos Rd (by Aladdin’s Nursery). Pass the school on the left side of the road, then slow down and after 2 houses you will see the field of iris behind the row of roses. Park on the shoulder of the road.
Please bring permanent markers, scissors, shovels, a folding chair, folding table if you have one, comfortable shoes, a sun hat, something to drink, and many, big!! cardboard boxes! Also bring the irises you are donating for the sale. Generous donations of rhizomes from our members are what makes this sale a success. We need your healthy, well grown, named increases. If you don’t have time to write their name, you may bring the clumps in paper bags with the name written on the bag. They can be cut and named at the ranch.
If you cannot come to the ranch, please send them with another member or bring them early to the sale named.
Prizes—we will have a raffle, everyone will go home with a recent introduction!
Bring food and we can have lunch!
We will also need reliable volunteers with trucks/vans/pickups to take the irises, keep them until Saturday and bring them to the sale.
Dig Help Needed
Jim plans on digging at the Cummins’ house Tuesday July 31st before Joe’s on Thursday, and could use help cutting and labeling. Please let Jim know if you can help. Sherry may also have a dig. Please contact her if you can help at her home.
MBIS Annual Iris Sale
When
Saturday, August 4th, 2018
Where
Deer Park Shopping Center, courtyard in front of the Red Apple Café
Set up Time
7:30 a.m. We need help for the set up. We hope you will help us sell during the morning. If you did not take the irises you are donating to Joe’s ranch on Thursday, Please cut the fans to about 12”, cut roots to 5” or 6”, print the name clearly on the middle leaf with a permanent marker, and write the color if possible. If you bring varieties other than TBs, please mark IB (intermediate), BB (border), SDB, (standard dwarf), MDB (miniature dwarf, MTB (miniature tall).
Sale Time
9:00— to noon (or sell out).
If you cannot get to Deer Park early, please drop your donation iris at the home of a member who will be there for set up.
Please bring brown grocery bags if you have any, comfortable shoes, and lots of friends to buy our iris.
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Transforming Socio-Technical Security Requirements in SecBPMN Security Policies
Mattia Salnitri and Paolo Giorgini
University of Trento, Italy
\{mattia.salnitri, paolo.giorgini\}@unitn.it
Abstract. Socio-Technical Systems (STSs) are complex systems composed of both social (i.e., humans and organizations) and technical (i.e., hardware and software) elements. Security requirements for STSs define constraints for the socio-technical interactions and can be specified as a set of security policies that have to be satisfied by the components of the system during their interactions. In this paper, we present how security requirements molded in STS-ml are transformed in security policies expressed in SecBPMN, an extension of BPMN with security annotations.
1 Introduction
Socio-Technical Systems (STSs) are complex systems where both social and technical components interact one another to achieve shared goals. Smart cities, health care, Air Traffic Management (ATM) systems are only few examples of STSs. In STSs, security requirements identify constraints interactions that have to be satisfied by the components of the system during their activities. STS-ml [2] is a diagrammatic language which allows analysts to model socio-technical security requirements. For example, in a ATM system, a socio-technical security requirement may specify that, if a Flying Object (FO), which is responsible of creating the flight plan to land in airport, delegates the control tower of an airport, the control tower shall not repudiate such a delegation.
STS can be modeled in terms of business processes, where activities are assigned and executed by single components and the control flows regulate their interactions. SecBPMN [5] (Secure BPMN) is a modeling language, based on Business Process Modelling and Notation (BPMN), which allows analysts to (i) model business processes with security annotations; (ii) define security policies, i.e., security constraints in terms of SecBPMN concepts. For example, the flight plan can be negotiated following a SecBPMN business process which specifies the interactions between the FO and the control tower. A SecBPMN security policy may specify that the information about the flight plan shall be exchanged between the FO and the control tower only after the execution of the activity which starts the negotiation.
STS-ml and SecBPMN models express different aspects of STSs, in particular SecBPMN models specify STS-ml models, hence both models are needed to fully characterize STSs. Specifying STS-ml security requirements in terms of SecBPMN security policies is a complex and time consuming activity that calls for automated support. This is particularly true in STSs where the high number of security requirements and their
complexity make very hard and error prone this activity. In this paper, we propose a set of transformation rules to partially automate the specification STS-ml security requirements in SecBPMN security policies.
The paper is structured as follows. Section 2 describes STS-ml and SecBPMN while Section 3 contains the transformation rules. Section 4 concludes the paper and proposes possible future work.
2 Baseline
This Section briefly describes STS-ml and SecBPMN, i.e. the two languages we used to model socio-technical security requirements and security policies.
2.1 STS-ml
Many security requirements modeling languages have been proposed so far. For example, SI* [3] and Secure Tropos [4] aim at modeling security needs. We choose STS-ml [2] (Socio-Technical Security-modeling language), a goal-oriented language for STSs, in which security requirements constrain the interactions between actors.
In STS-ml, requirements models are expressed by three views: (i) the social view describes the main actors, their rationale, goal delegations, and document provisions; (ii) the information view defines the relationship between information and documents; and (iii) the authorization view represents the authorizations about information that actors grant one to another. Figure 1 shows an example of STS-ml model of an airport scenario.
**Fig. 1.** STS-ml model of an ATM scenario
**Social view.** Two types of actors are modeled: agents—concrete entities that are known at design-time (e.g., *Immigration office*)—and roles—that can be played by different
agents at runtime (e.g., *Web-Service*). An actor’s rationale is an AND/OR goal tree (e.g., the root goal of the *Immigration Office* is to be *Immigration monitored*). To achieve their goals, actors need, modify, and produce documents (e.g., *Immigration Office* needs document *Visa* to achieve goal *Visa checked*). Two social relationships link couples of actors: goal delegation and document provision. Both relations can be subject to security requirements (e.g., integrity, availability, …).
**Information view.** Documents and information are linked one to another. The “Tangible by” relation indicates that an information is represented by a document. In Figure 1, *Citizen SSN* (Social Security Number) is made tangible by document *Visa*. Ownership relates an actor to the information that she owns.
**Authorization view.** It represents the permissions on information that actors grant one to another. An authorization box details the granted permissions (*Use*, *Modify*, *Produce*, *Distribute*) on documents representing specific information. Authorizations can be limited by defining a scope: one or more goals for whose fulfillment the permissions are granted. In Figure 1, the *Web-Service* authorizes the *Immigration Office* to use *Citizen SSN* in the scope of goal *Visa checked*.
### 2.2 SecBPMN
SecBPMN [5] is a framework aimed to model business processes with security aspects, to model security policies and to verify if such security policies are satisfied by the business processes. It is composed by: SecBPMN-ml (SecBPMN-modeling language), SecBPMN-Q (SecBPMN-Query) and a software component.
SecBPMN-ml extends BPMN with security concepts about information assurance and security defined in [1]. In the literature there are a number of modeling languages that extend BPMN with security concepts, but they can represent only a restricted set of security concepts, while SecBPMN-ml covers, as far as our knowledge goes, the most comprehensive set of security concepts. Each SecBPMN-ml security annotation is represented with an icon with a solid orange circle, and is detailed by a predicate which specifies further details on the security aspects represented by the annotation. Security annotations can be used as patterns or anti-patterns, depending on the exigencies of security designers.
Figure 2 shows part of a SecBPMN-ml model of a business process used in an airport information system where users can use different web-interfaces to select the best option for a flight, buy tickets and perform most of the bureaucratic processes required to take the flight.
SecBPMN-Q is a graphical query language which permits to define security policies in terms of SecBPMN-ml elements. Figure 3 shows an example of the textual policy “*The visa document must be sent through a secure channel, which assures the information will not be modified by third parties*”, modeled with SecBPMN-Q. The graphical security policy is composed by two activities labeled “@X” and “@Y”. “@” symbol is used match any activities. The two activities are linked with a path relation (the arrow with two slashes in the middle) which matches all the paths between the source and target activity. The security policy is enriched with a message flow (represented as a dashed arrow) which transports data object called “*Visa*”. When executed, this security
policy will match any message flow between any two activities which exchange the “Visa” data object. The “Visa” data object is linked to an integrity annotation, which means that has to be protected by unauthorized modifications.
3 Transformation rules
This section describes a set of transformation rules, that are used to specify all types of STS-ml security requirements in SecBPMN security policies. STS-ml and SecBPMN modeling languages have different scopes and, hence, they model different set of concepts. Therefore, for each transformation rule we define one or more mapping relations which link STS-ml concepts with SecBPMN concepts.
In the rest of the section, for each STS-ml security requirement, we describe its semantic (the first sentence) and the transformation rule we defined. Table 1 shows the transformation rules and the mapping needed for the transformations. The first four transformations create anti-patterns, i.e. the security policy shall not be satisfied in any business processes, the other transformations create patterns, i.e. the security policy shall be satisfied by all business process. Such transformation rules can be used to partially automate the transition from STS-ml to SecBPMN models, in order to help security designers in the specification of SecBPMN models and security policies from STS-ml models. For example the security policy in Figure 3 is derived from the transformation rule of integrity security requirement, with the mapping $g \Rightarrow Visa$.
**Non-disclosure(Goal g, Document d)** The document $d$ shall not be disclosed in order to achieve $g$, to unauthorized actors. The transformation consists in defining a security policy that matches all the message flows, from ACT and transmit the document $d$.
**Non-usage(Goal g, Document d)** The document $d$ shall not be used (i.e. read) to achieve goal $g$. We created a transformation rule which creates a security policy which the data object mapped to $d$, i.e. DO, is read by the activity mapped to $g$, i.e. ACT.
Non-modification(Goal g, Document d) The document d shall not be modified in order to achieve g. We transformed it in a security policy which contains an activity which reads and writes the same data object, i.e. it modifies the data object.
Non-production(Goal g, Document d) The document d shall not be created in order to achieve g. It’s transformed in a policy which contains an activity which writes the data object DO.
Non-repudiation(Delegation(Goal g)) The acceptance of the delegation of goal g shall not be repudiated. It is transformed in a policy which contains an activity ACT, that is mapped to goal g, linked to a non-repudiation security annotation.
Redundancy(Goal g, Type t) Goal g shall be achieved with a redundancy strategy t. STS-ml defines two types of redundancy strategies: fall-back redundancy and true redundancy. We specified it in two security policies. For fall-back redundancy we define a policy which is satisfied by a path where there is at least an exclusive gateway between the main and the backup activities, which represents the decision to use the backup activity. For the true redundancy we define a policy which is satisfied when the two activities are executed in parallel paths. These policies require a mapping of g to two activities: a main activity the backup one.
Integrity(Document d) The document d shall not be modified by unauthorized users. We transformed it in a security policy which requires the integrity security annotation attached to the data objects that corresponds to the document d.
Availability(Goal g, Float a) The percentage of time g is achieved over of the total times that is requested, shall be higher than a. We transformed it in a policy which contains an activity linked to an availability security annotation. The level of availability a, is specified in the predicate which details the security annotation.
Trustworthiness(Goal g, Int t) Goal g shall be achieved by an actor with a level of trustworthiness greater than t. This is transformed in a policy which contains an activity linked to an authenticity security annotation. The trustworthiness level t is specified by the predicate which details the security annotation.
Non-delegation(Goal g, Actor a) Goal g shall not be delegated, by a, to other actors. This security requirement cannot be transformed in a security policy, because in SecBPMN there is no concept that can be mapped to actor.
Need to know(Document d, Goal g) All operations on document d shall be executed only for the purpose of achieving g. As the previous security requirement, this cannot be specified as a security policy, but it is implicitly verified when the the security policies of non-usage, non-modification and non-production are verified.
Bind of duty(Role r1,r2) and Separation of duty(Role r1,r2) All actors that play r1 shall (not) play also r2. These security requirements cannot be specified in security policies, because in SecBPMN there is no concept that can be mapped to actor.
4 Conclusions and future work
In this paper, we have proposed a set of rules to transform security requirements, expressed with STS-ml, into security policies, expressed with SecBPMN. These transformation rules are intended to automatize the specification activity and then support the analyst in the security requirements engineering process for STSs.
As part of our future work, we will develop a software tool to automatically transform security requirements into security policies and we will define a language to support security analysts in defining their own transformation rules.
**Acknowledgement**
The research leading to these results has received funding from the European Union Seventh Framework Programme (FP7/2007-2013) under grant no 257930 (Aniketos).
**References**
1. Y. Cherdantseva and J. Hilton. A reference model of information assurance and security. In *Proc. of ARES ’13*, pages 546–555.
2. F. Dalpiaz, E. Paja, and P. Giorgini. Security Requirements Engineering via Commitments. In *Proc. of STAST’11*, 2011.
3. P. Giorgini, F. Massacci, J. Mylopoulos, and N. Zannone. Modeling Security Requirements through Ownership, Permission and Delegation. In *Proc. of RE’05*, pages 167–176, 2005.
4. H. Mouratidis and P. Giorgini. Secure Tropos: A Security-Oriented Extension of the Tropos methodology. *IJSEKE*, pages 285–309, 2007.
5. M. Salnitri, F. Dalpiaz, and P. Giorgini. Modeling and verifying security policies in business processes. *In Proc. of BPMDS’14*.
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Hedgerows have contrasting effects on pollinators and natural enemies and limited spillover effects on apple production
Gabriella A. Bishop*, Thijs P.M. Fijen, Brooke N. Desposato, Jeroen Scheper, David Kleijn
Plant Ecology and Nature Conservation Group, Wageningen University, Droevendaalsesteeg 3a, 6708PB Wageningen, the Netherlands
ARTICLE INFO
Keywords:
Hedgerows
Pollinators
Natural enemies
Ecological intensification
Ecosystem services
ABSTRACT
Agricultural intensification has resulted in a decline in insect biodiversity and threatens the provision of valuable ecosystem services. Agri-environment schemes (AESs) have been implemented in an effort to conserve biodiversity on farmland and increase agricultural sustainability, but their effectiveness can vary widely. To better determine which factors influence AES effectiveness, the relative roles of local habitat features, habitat quality, and landscape context need to be further explored. The aim of this study was to determine the most important factors influencing field margin AES effectiveness in commercial apple orchards, in terms of arthropod biodiversity conservation and ecosystem service provision. We surveyed wild bees and aphid natural enemies in field margins and apple trees in 20 orchards, ten bordered by hedgerow field margins (an AES) and ten with herbaceous field margins (no hedgerows present, not an AES). We considered field margin floral resources and the cover of semi-natural habitat in the surrounding landscape as indicators of local habitat quality and landscape context, respectively. We furthermore quantified pollination and pest control as measures of ecosystem service delivery and the relationship between arthropod communities and apple yield (initial and final fruit set) and quality. We found that hedgerow presence strongly predicted both pollinator and natural enemy communities and that these relationships were more pronounced than those with local habitat quality and landscape context. Hedgerows were negatively related to wild bee richness and abundance within the orchard, and positively related to natural enemy richness and abundance at the field margin but not within the orchard. We found no relationships between local and landscape factors and ecosystem service delivery, and no relationship between wild bee communities and apple yield, suggesting that apple is not pollen limited in our study system. There was, however, a negative relationship between natural enemy richness and initial fruit set. We conclude that annually cut hedgerows can benefit the conservation of natural enemies, but have limited arthropod-mediated private benefits for apple production, and likely need to be supplemented with additional local habitat resources for the conservation of wild bees. Our findings indicate that local habitat factors can strongly influence biodiversity regardless of landscape context, but that AESs likely need to be designed with separate biodiversity and ecosystem service targets, and specific taxonomic groups, in mind.
1. Introduction
The intensification of agriculture is one of the major contributors to biodiversity decline (Foley et al., 2005; Habel et al., 2019; Kleijn et al., 2009). While mechanization and the use of fertilizers and agrochemicals has greatly increased crop production, these trends are also coupled with widespread habitat loss, fragmentation, and pollution within agricultural landscapes (Robinson and Sutherland, 2002; Tscharnike et al., 2005). These impacts have resulted in a marked decrease in insect biodiversity (Potts et al., 2010; Sánchez-Bayo and Wyckhuys, 2019; Seibold et al., 2019), which in turn threatens the provision of economically valuable ecosystem services, such as pollination and pest control (Dainese et al., 2019; IPBES, 2016; Klein et al., 2007). Ecological intensification has been proposed as a solution to support biodiversity while maintaining high crop yields by partially replacing external agricultural inputs with the enhancement of ecosystem services (Bommarco et al., 2013; Kleijn et al., 2019). Several strategies aimed at biodiversity conservation and sustainable agricultural production have been widely implemented and are often subsidized by governments in the form of agri-environment schemes (AESs) in an effort to mitigate the
negative effects of intensive agriculture (Batáry et al., 2015). However, farmer uptake remains low, especially of schemes with greater potential to support biodiversity (Cole et al., 2020), so an understanding of how AESs can be designed to better incentivize adoption by farmers is still needed.
Many widespread AESs targeting biodiversity conservation in agricultural landscapes aim to maintain or create field margin habitats, such as flower strips or hedgerows (Albrecht et al., 2020). Field margins provide permanent habitats for biodiversity in otherwise highly disturbed landscapes, and can make up most of the permanent habitats in intensive landscapes with few natural areas. Historically, permanent field margin habitats provided benefits to farmers, such as field delineation and fencing (Forman and Baudry, 1984; Robinson and Sutherland, 2002). With the intensification of agriculture, field sizes have increased and alternatives to natural field margins, such as wire fencing, have become widely available, so the need for these permanent field margins has decreased and their extent has subsequently been reduced (Robinson and Sutherland, 2002). The subsidization of habitats as AESs that would otherwise be removed or abandoned can replace the lost incentive and allows their biodiversity conservation benefits to be maintained (Kleijn et al., 2011). If field margin AESs additionally provided benefits to farmers, for example through improved ecosystem service delivery or crop yield, this could further incentivize and motivate farmers to conserve or implement them (Fijen et al., 2022; Morandin et al., 2016). Field margin AESs have been shown to benefit pollinator and natural enemy biodiversity and ecosystem service delivery in various crop systems (Blaauw and Isaacs, 2014, 2015; Morandin et al., 2014; Williams et al., 2015), which can carry over to crop production with demonstrable economic impact (Morandin et al., 2016). However, the effectiveness of AESs can vary, and their benefits do not consistently spill over into the crop field (Albrecht et al., 2020; Lowe et al., 2021; Zamorano et al., 2020). Recent meta-analyses highlight that factors influencing the effectiveness of AESs need to be further examined (Albrecht et al., 2020), especially those determining effects on ecosystem service delivery (Lowe et al., 2021), if adequate design and implementation of AESs are to be achieved.
At the local scale, the quality of a habitat, which may be indicated by the resources (e.g., food or shelter) it provides, can affect its ability to support biodiversity, so the relative quality of AESs may explain the variation in their effectiveness for biodiversity and ecosystem service enhancement (Albrecht et al., 2020; Scheper et al., 2013). For example, greater wild bee species richness and abundance are associated with wildflower strips that have high plant species richness and that provide more pollen and nectar resources (Schubert et al., 2022). Similarly, hedgerows with high plant species diversity and fewer gaps in them have higher bumblebee and spider abundance (Garratt et al., 2017), and hedges supplemented with flowers in the understory perform better than standard hedges in supporting bumblebee richness and abundance when compared to herbaceous field margins (von Königslow et al., 2021). Even when flower richness explains arthropod abundance and ecosystem service provision, wildflower strips sown as an AES that fail to enhance floral diversity beyond the level present in the pre-existing field margin may result in an ineffective AES (Mei et al., 2021). Understanding the relative role of habitat quality in AES effectiveness for biodiversity conservation could thus contribute to the targeted design of AESs.
The effectiveness of an AES can also be influenced by landscape context (Batary et al., 2011; Scheper et al., 2013). The amount, type, or configuration of natural and semi-natural habitats surrounding crop fields plays a role in determining the makeup of arthropod communities found within those fields (Chaplin-Kramer et al., 2011; Kennedy et al., 2013; Martin et al., 2019). Arthropods thus often respond positively to the improvement of both local and landscape habitat conditions (Gonthier et al., 2014). As a result of these findings, it has been recommended to implement conservation measures on multiple scales (Kennedy et al., 2013). When adopting AESs, however, farmers cannot control the context of the landscape in which their farms are located, despite the fact this context may ultimately affect the success of an AES. For example, an AES in a complex landscape may not have strong effects on pollinator communities due to the existing high coverage of natural habitats, but neither will one in an extremely simplified, or cleared, landscape due to the lack of source populations (Scheper et al., 2013). Altering landscape context is not a practical or actionable recommendation for an individual farmer, but increasing the local habitat quality of AESs would be. To design AESs that address relevant conservation goals while also incentivizing uptake by farmers, an understanding of the relative importance of local and landscape factors and how they interact to determine AES effectiveness is needed.
To determine the most important factors influencing field margin habitat effectiveness, we examined the individual and interactive effects of local and landscape factors on pollinators and natural enemies within apple orchards in south Limburg, the Netherlands. Commercial apple cultivation benefits from multiple arthropod-provided ecosystem services, namely pollination and biological pest control (Cross et al., 2015; Pardo and Borges, 2020). Orchards furthermore are often bordered by hedgerows, a type of field margin habitat that can act as valuable wind breaks (Norton, 1988) but that also is a culturally and historically important agricultural landscape feature (Forman and Baudry, 1984). Hedgerows in our study area are considered an AES as their maintenance is often subsidized by the government, and while they are not managed specifically for arthropod conservation, hedgerows in general provide resources for arthropods as well as other animals (Batary et al., 2010; Dondina et al., 2016; Ponisio et al., 2016). We examined the effects of hedgerow presence and habitat quality, using field margin floral resources as a habitat quality measure, on pollinator and natural enemy richness and abundance and on pollination and pest control ecosystem service delivery within apple orchards. We additionally tested if landscape context moderated the effects of these local habitat factors. Subsequently, we examined the relationship between arthropod biodiversity and ecosystem service measures and apple yield and quality. Specifically, we asked 1) How do hedgerow presence, field margin floral resources, and landscape context affect arthropod biodiversity in apple orchard field margins; 2) How do these factors affect arthropod communities and ecosystem service delivery within apple orchards; 3) Do these effects carry over to apple yield and quality?
2. Methods
2.1. Study sites
Twenty conventionally managed apple orchards were selected in the region of south Limburg, the Netherlands (50.763–50.877 N, 5.729–5.971 E). Study orchards ranged from 0.4 to 8.5 ha in size (mean ± SD = 2.7 ± 0.45 ha), but were often situated within a larger grouping of orchards. Orchards included seven apple varieties (Boskoop, Elstar, Evelina, Joly Red, Jonagold, Junami, and Wellant) and were on loam or silty loam textured soils. Ten orchards had a hedgerow on one or more sides of the orchard (aspect of hedgerows varied), and ten orchards (controls) had no hedgerow on any side but only had herbaceous field margins (Fig. 1). All sites were at minimum 1 km in distance from any other study site (mean ± SD = 2.07 ± 0.91 km), which is greater than the typical foraging distance of most wild bee species, the most mobile group in our study (Zurbuchen et al., 2010). The cover of semi-natural habitat was calculated within a 500 m radius and did not significantly differ between sites with and without a hedgerow field margin (Table A.1; Netherlands national land use, Hazeu et al., 2020). Hedgerows at study sites are subsidized for their cultural, aesthetic, and wildlife (e.g., birds and small mammals) conservation value, but are not specifically managed for arthropod biodiversity. They contained one or a mix of the following species: *Crataegus monogyna* (Jacq.) (common hawthorn), *Carpinus betulus* (L.) (European hornbeam), and *Alnus glutinosa* (L.) (common alder). Hedgerows were approximately 1–2 m in height and 1–1.5 m in width and are cut every year.
2.2. Arthropod community and habitat quality surveys
We chose wild bee pollinators and aphid natural enemies as our focal arthropod groups since both groups provide ecosystem services to apple production. Bees make up the large majority of apple pollinators, which also include hoverflies and to a much lesser extent other groups (e.g., Lepidoptera, Hemiptera, and Coleoptera) (Pardo and Borges, 2020). We limited our pollinator surveys to bees because hoverflies typically have low visitation rates to apple and have significantly lower apple pollination success compared to bees (Bernauer et al., 2022; Garratt et al., 2016). We did, however, include hoverflies as pest enemies in our study. Several groups of pests such as moths, mites, and leaf miners threaten apple production (Agnello, 2004), but aphids (in particular the rosy apple aphid, Dysaphis plantaginis (Passerini)) are among the major pests that cause economic losses (Blommers et al., 2004) due to leaf curling and fruit deformation (Agnello, 2004). European earwigs (Forficula auricularia (L.)) are a primary contributor to aphid biological control in apple orchards (Dib et al., 2010; Mueller et al., 1988), but several other groups predate or parasitize aphids in this study system (e.g., Coccinellidae, Syrphidae, and Braconidae; Dib et al., 2010).
The arthropod community and habitat quality surveys are described in the following two sub-sections. For an illustrative overview of all sampling locations within study orchards, see Figure A.1.
2.2.1. Surveys within field margins
18.104.22.168. Wild bees. We measured wild bee communities during apple bloom (April-May) in 2021. To record the richness and abundance of wild bees in apple orchard field margins, we established 150 m$^2$ transects along a field margin at each site. Field margins were selected that were at minimum 100 m in length with intact vegetation and that were accessible. At sites with hedgerows, the transect was established directly next to the hedgerow, and included its undergrowth. Hedgerows in our study area are intensively managed so that they seldom flower, so these transects were comparable to those at control sites in that they were established within herbaceous groundcover. Transect surveys (Westphal et al., 2008) using butterfly nets were conducted for an observation period of 15 min, during which all bees utilizing the habitat within the transect were recorded, excluding catching and handling time. Specimens were either identified to species in the field where possible or collected into vials containing paper wetted with ethyl acetate for later pinning and identification using relevant taxonomic keys (Falk and Lewington, 2016; Anon, 2020, 2016). Surveys were carried out between the hours of 10:00 and 18:00, and due to the cold and rainy spring, they were conducted both under optimal (> 15 °C, wind < 3 Beaufort (< 12 km/h), clear to low cloud cover) and sub-optimal (9–15 °C, wind ≤ 3 Beaufort (up to 19 km/h), low to moderate cloud cover) conditions, though always conducted on dry days. Sites were all surveyed twice, once each in the morning and afternoon. Apis mellifera (L.) individuals were recorded but were not considered wild pollinators as there are no feral populations in our study system and because their presence is strongly influenced by hive placement by farmers within their orchards. In the Netherlands, Bombus terrestris (L.) and B. lucorum (L.) workers and queens cannot be readily separated without molecular techniques (Alferink et al., 2020) and were thus grouped into one complex.
22.214.171.124. Natural enemies. We measured natural enemy communities after apple bloom (June-July) in 2021, since pest pressure is greatest during the fruit development period (Agnello, 2004). To record the richness and abundance of natural enemies in apple orchard field margins, sweep samples (Morandin et al., 2014) were collected at three locations along the field margin transect: in the center, and midway between the center and each edge. Ten 180° sweeps were made into the vegetation at each sample location using a 35 cm diameter net. When a hedgerow was present, sweeps were made simultaneously into the hedge vegetation and the herbaceous undergrowth. Surveys were conducted between 10:00 and 18:00 on dry days with low to moderate cloud cover, temperature > 13 °C, and wind < 3 Beaufort (< 12 km/h). Sites were all surveyed twice, once each in the morning and afternoon. Samples were transferred to labelled and sealed bags and placed in a cooler before being frozen and stored in 70% ethanol for later identification. Identification to species level (except for lacewings and parasitoid wasps, which were identified to family or superfamily) was performed with relevant taxonomic keys (Bot and Van de Meutter, 2020; Krediet et al., 2022; Roy and Brown, 2021). Spiders and harvestmen were identified by a local expert (Aart Noordam).
126.96.36.199. Floral resources. Floral resources were recorded in the same field margin transects during each bee and natural enemy survey (except for five sites, where one floral survey represented both bee rounds) according to the methods of Schepers et al. (2015). All flowering species within the transect were identified using Obsidentify and relevant taxonomic keys (Rose, 2006; Streeter and Hart-Davies, 2016) and individual flower units were counted. The flower cover of each species was calculated as the total number of flower units * the mean surface area of one flower unit, divided by the transect area. The cover of all species was summed and multiplied by 100 to calculate total % flower cover of the transect. Thus, two measures of floral resources were recorded: flower richness and flower cover.
2.2.2. Surveys within apple trees
188.8.131.52. Wild bees. To record the richness and abundance of wild bees visiting apple flowers, three transects were conducted along tree rows, one at each of three increasing distances from the focal field margin: 10, 30, and 50 m (see Figure A.1). Transects were 75 m in length and 7.5 min in observation duration, and only one side of a tree row was surveyed in each transect. When tree rows were oriented perpendicularly to the focal field margin, we split transects at each distance class into ten consecutive segments of 7.5 m that were each surveyed for 45 s. All bees observed to make contact with an apple flower stigma were recorded and if necessary caught for later identification. One site used microcolonies of B. terrestris workers as managed pollinators, so at this site B. terrestris/lucorum workers (but not queens) on apple flowers were not considered as wild bees.
184.108.40.206. Bee visitation rate. Surveys of bee visitation rate, a widely used indicator of pollination services to crops (Kleijn et al., 2015), were conducted on six apple trees per site, with two trees (minimum 20 m apart) from within the pre-established transects at each distance class. During visitation surveys, we simultaneously observed one low (approximately 1–1.5 m in height) and one high (approximately 1.5–2 m in height) branch on each tree. All bee visits with stigma contact to the flowers on the focal branches were recorded during a period of 20 min (Fijen and Kleijn, 2017). Branches were marked with colored tape so that the same branches at each site were observed during both sampling rounds. The number of open flowers on each branch was...
recorded prior to the start of each survey. Flower counts for the focal branches were used to calculate percentage bloom by dividing the number of open flowers by the total number of individual (not composite) buds counted at the first survey. This value was then averaged across the 12 branches to yield an estimate of percentage bloom of the apple orchard during each sampling round, as the stage of bloom might affect the abundance and visitation of bees.
The visitation rate per flower was calculated separately for wild bees and managed (*A. mellifera* and in the case of one site, *B. terrestris/lucorum* workers, see above) bees by dividing the number of visits by the number of open flowers for each branch. Visitation rate was calculated separately for these two groups because it was assumed that only wild bees would be affected by the environmental variables examined in this study, whereas managed bees are primarily affected by placement of hives within the orchards by the farmers. Managed bee visitation was still calculated, however, as it is an additional indicator of pollination services relevant for apple production.
### 220.127.116.11. Natural enemies and pests
To record natural enemies and pest infestation within apple trees, we combined visual surveys with tap sampling (Happe et al., 2019). Twelve trees were surveyed at each site, with four trees from within the pre-established transects at each distance class. Two branches (one low, one high) were surveyed per tree. Branches were inspected for aphid colonies. The number of colonies was recorded and the number of individuals in each aphid colony was counted; exceptionally large colonies (e.g., when entire leaves were curled due to infestation) were collected for later counting. Aphids on apple trees included the woolly apple aphid (*Eriosoma lanigerum* (Haussm.)), the rosy apple aphid (*D. plantaginæa*), and the green apple aphid (*Aphis pomi* (De Geer)). In the case of the woolly apple aphid, whose wool makes counting individuals difficult, the size (cm$^2$) was visually estimated and the number of individuals was calculated according to Gontijo et al. (2013). Branches were tapped thrice over a 35 cm diameter net and captured natural enemies were collected into vials. Natural enemies were placed into a cooler before being frozen and stored in 70% ethanol for later identification. Earwigs made up a large proportion of observations (82.4%), so natural enemy abundances within apple trees were split into earwig and non-earwig counts.
### 18.104.22.168. Aphid predation rate
Aphid predation rate was estimated with aphid sentinel prey cards (Boetzl et al., 2020; Geiger et al., 2010). Ten adult pea aphids (*Acyrthosiphon pismum* (Harr.)) were affixed to one side of a 5 × 5 cm piece of black fine-grained sandpaper using clear nail polish. After drying, the cards were used within 36 h. Nine cards were placed at each site, with three cards on three different trees from within the pre-established transects at each of the three distance classes. At each distance class, two cards were placed on the two trees previously marked for the bee visitation surveys, and a third card was placed on a tree between these two trees. Cards were attached to a branch with twisties and were collected after 24 h, when the number of remaining aphids on each card was recorded. Predation rate was calculated as the number of aphids removed from the card divided by the total number of aphids placed on the card.
### 2.3. Apple yield and quality
To investigate the relationship between arthropod communities and apple yield, we measured apple yield and quality from the same 12 branches for which we measured bee visitation rate in each orchard. Shortly after initial fruit development, the total number of apples on each focal branch was counted (initial fruit set). The count was performed a second time at harvest (final fruit set). Fruit set was calculated as the count of fruit divided by the total number of individual (not composite) buds recorded for that branch at the beginning of the flowering period. Five apples were harvested from each focal branch, if there were at least five apples present (mean ± SD = 3.9 ± 1.6 apples). For these apples, the weight, maximum diameter, seed set, and symmetry were recorded. Symmetry was visually assessed and if moderate or severe asymmetry was present (see de Groot et al., 2015), the apple was marked as not symmetrical. Symmetry was then calculated as the number of symmetrical apples divided by the total number of apples. These indicators were chosen because they are related to pollination success and are important to commercial yield and quality (Garratt et al., 2014; Pardo and Borges, 2020). One control site was harvested by the farmer prior to final yield data collection, so this site was excluded from all yield analyses.
### 2.4. Statistical analysis
#### 2.4.1. Arthropod communities
We used linear models and a multi-model inference approach (Grueber et al., 2011; Harrison et al., 2018) in R version 4.1.2 (R Core Team, 2021) to analyze the effects of local and landscape factors on several response variables. Response variables included wild bee and natural enemy richness and abundance in field margins and apple trees, and wild bee visitation and aphid predation in apple trees. To determine the relative influence of local and landscape factors, we considered hedgerow presence, flower richness, and flower cover as local habitat factors, and the percentage of semi-natural habitat in the surrounding 500 m as a landscape habitat factor. These variables comprised model fixed effects, and all two-way interactions between local and landscape variables were included. Hedgerow presence did not affect field margin flower richness and cover on average (Table A.5), so the effects of these factors on arthropod communities could be considered independently. For models of data collected on apple trees, preliminary analyses showed that distance into the orchard did not significantly predict any response variable ($p > 0.10$ for all models), so we removed this factor and pooled data by summing within sites for each round (except for visitation rate, which was averaged across branches). Additional covariates of interest, including temperature, percentage bloom of apple trees, aphid infestation (total number of individuals across all species), and time of predation card deployment, were also included as candidate fixed effects when relevant to response variables. Due to the right-skewness of the flower cover and aphid infestation data, these variables were log transformed. Predictor variables were standardized according to Gelman (2008) using the arm package (Gelman and Su, 2021) in order to obtain directly comparable model coefficients and to interpret model-averaged main effects in the presence of interactions. All variables were averaged across sampling rounds to remove the element of pseudoreplication from the data.
Full model averaging was performed using the MuMIn package (Barton, 2020) on a candidate model set where the maximum number of predictors was set to four to limit model overparameterization, with the difference in Akaike information criterion corrected for small sample size (AICc) between the best model and the other candidate models limited to four (Burnham et al., 2011). We validated model assumptions on a model representing the fullest possible model in the model set (Hoeting et al., 1999) using the DHARMa package (Hartig, 2021) and checked for predictor collinearity using the performance package (Lüdecke et al., 2021). Spatial autocorrelation was checked using the DHARMa package, and no models exhibited significant spatial autocorrelation. Response variables were square root or log + 1 transformed when necessary to improve residual scatter. Model-averaged beta coefficients were considered ‘strong’ predictors of response variables if their 95% confidence intervals did not overlap zero. For wild bee visitation rate, a single outlier had high influence within the model on the effect of flower cover and was removed, but model averaging results including the outlier are presented in Table A.17.
#### 2.4.2. Apple yield and quality
As a secondary analysis step, to determine if differences in arthropod communities in turn impacted apple production, we investigated the effect of species richness (apple tree wild bee and natural enemy richness) and ecosystem service delivery (wild bee visitation rate, managed bee visitation rate, and aphid predation rate) on the measured apple yield and quality indicators (see
Section 2.3) with linear models. We chose to not include arthropod abundances in addition to the selected predictor variables as abundance and richness were highly correlated (r = 0.80 and 0.53 for bees and natural enemies, respectively). Within models, natural enemy richness showed collinearity with both aphid predation rate and wild bee visitation rate (model variance inflation factors > 3) and so models containing its combination with either of these respective predictor variables were excluded from the candidate model set. Because yield parameters depend on apple variety, we estimated the influence of apple variety as a fixed effect. To do so, only varieties represented by at least three sites were included in the analyses (N = 14 sites). Predictor variables were averaged across sampling rounds and then standardized by subtracting the mean and dividing by the standard deviation (i.e., z-scores) prior to analyses. Response variables were averaged within site. The model of final fruit set showed remaining residual heteroskedasticity, so the response variable was reciprocal transformed. Model averaging was performed using the same procedure as described above, with variety being specified as a constant fixed effect within all models.
3. Results
3.1. Arthropod communities and habitat quality
In total 475 wild bee and 926 natural enemy individuals were recorded, comprising 40 and 51 species, respectively (Tables A.3-A.4). Natural enemies included spiders (Araneae), harvestmen (Opiliones), ladybird beetles (Coccinellidae), earwigs (Dermaptera), lacewings (Chrysopidae), parasitic wasps (Braconidae and Chalcidoidea), and hoverflies (Syrphidae). Other aphid predators were not encountered. The most abundant wild bee species was *B. terrestris/lucorum* (workers and queens combined), while the most abundant natural enemy species was *F. auricularia* (European earwig). A greater number of species of both wild bees and natural enemies were observed in field margins than within apple trees (33 bee species and 34 natural enemy species; and 21 bee species and 30 natural enemy species, respectively). The large difference in the number of bee species between the field margins and apple trees was primarily due to the presence in the field margins of non-crop pollinating species such as *Nomada* cuckoo bees (Table A.3). More *Nomada* species were observed in control field margins (9 species) than in field margins with hedgerows (4 species). Natural enemies collected in apple trees were primarily earwigs, ladybird beetles, spiders, and harvestmen, while in field margins hoverflies and parasitic wasps were also recorded (Table A.4). More spider species were found in hedgerow field margins (16 species) compared to control field margins (8 species), which mainly drove the overall difference in natural enemy richness between field margin types. Average abundances for wild bees and natural enemies in field margins and apple trees are presented in Table A.2.
Floral richness and cover did not significantly differ between hedgerow and control field margins during both bee and natural enemy surveys (Table A.5). On average, during bee surveys there were 8.4 ± 0.9 and 8.6 ± 0.9 (mean ± SE) flowering plant species in hedgerow and control field margins, respectively, and during natural enemy surveys there were 9.1 ± 0.9 and 8.4 ± 0.9 (mean ± SE) species, respectively. Flower cover was relatively higher for both hedgerow and control field margins during the bee surveys (0.419 ± 0.103% and 0.656 ± 0.161% mean ± SE, respectively) compared to during the natural enemy surveys (0.116 ± 0.047% and 0.135 ± 0.056% mean ± SE, respectively). For a list of all floral species recorded see Table A.6.
3.1.1. Arthropod communities within field margins. Wild bee richness and abundance in apple orchard field margins were not strongly related to any local or landscape habitat factor (Table 1). Natural enemy richness and abundance, on the other hand, were strongly positively predicted by hedgerow presence and flower cover (Fig. 2), with hedgerow presence having a relatively larger effect compared to flower cover (Table 1). There was no strong evidence of moderating effects between landscape and local habitat factors (no strong two-way interactions).
3.1.2. Arthropod communities within apple trees. Wild bee richness and abundance within apple orchards were strongly negatively predicted by hedgerow presence (Fig. 3), but not by landscape context or other local habitat factors. Natural enemy communities in apple trees, as well as bee visitation rate to apple flowers and aphid predation rate within apple trees, were not strongly predicted by any habitat factor. There was furthermore no strong evidence of moderating effects between landscape and local habitat factors (no strong two-way interactions).
3.2. Apple yield and quality
Initial fruit set was strongly negatively predicted by natural enemy richness (Table 2, Fig. 4), but no other yield or quality measure was predicted by arthropod species richness or ecosystem service measures.
4. Discussion
Hedgerows are a commonly implemented field margin AES in northwestern Europe and have been shown to positively affect bees and natural enemies within agricultural environments (Castle et al., 2019; Dainese et al., 2017; Hannon and Sisk, 2009; Kremen et al., 2019), with greater effects being realized by hedgerows higher in quality (e.g., more species- or flower-rich) (Garratt et al., 2017; von Königslow et al., 2021).
### Table 1
Standardized full model-averaged coefficients (beta values) of all arthropod community models.*
| Predictor | Response: Field margin | Response: Apple trees |
|--------------------|------------------------|-----------------------|
| | Bee rich | Bee abun | NE rich | NE abun | Bee rich | Bee abun | Bee visits | NE rich | EW abun | NE abun | Aphid pred |
| Flower richness | 0.0284 | 0.1077 | -0.0103 | -0.0523 | 0.0108 | 0.0089 | 0.0060 | 0.0459 | -0.3423 | 0.0259 | 0.0166 |
| Flower cover | 0.2649 | 0.3376 | **0.5012** | **2.9537** | 0.0169 | -0.0026 | 0.0052 | 0.0375 | -2.1678 | 0.0568 | -0.0621 |
| % SNH | 1.1472 | 0.5120 | -0.0009 | -0.0748 | 0.0307 | -0.0025 | 0.0005 | 0.0162 | 0.0047 | -0.0257 | -0.0038 |
| Hedgerow | -0.6641 | -0.2096 | **0.6176** | **3.9867** | -0.9303 | -0.4793 | 0.0004 | 0.0022 | -4.8180 | -0.0239 | 0.0015 |
| Aphids | – | – | – | – | – | – | 0.1738 | -0.1899 | 0.3380 | – | -0.0195 |
| % Bloom | – | – | – | – | -0.0666 | -0.0144 | -0.0004 | – | – | – | – |
| Temperature | -0.1190 | -0.1421 | -0.0405 | -0.0923 | 0.0141 | 0.0281 | 0.0022 | -0.1188 | -0.4218 | 0.0150 | – |
| Daytime | – | – | – | – | – | – | – | – | – | – | -0.0003 |
| % SNH * Hedgerow | -0.2452 | -0.0103 | – | – | – | – | – | – | – | – | – |
| % SNH * Flower richness | – | – | – | – | – | – | 0.0036 | – | – | – | – |
| % SNH * Flower cover | – | 0.0341 | – | – | – | – | – | – | – | – | – |
* Presence of a coefficient indicates that the predictor variable was retained in the model averaging process. Bold coefficient values indicate that the 95% confidence interval does not include zero. Wild bee abundance beta coefficients are on the log scale, and those for margin natural enemy richness and apple tree abundance are on the square-root scale. Bee rich = wild bee richness; bee abun = wild bee abundance; bee visits = wild bee visitation rate per flower; NE rich = natural enemy richness; EW abun = earwig abundance; NE abun = natural enemy abundance (excluding earwigs on apple trees); aphid pred = aphid sentinel prey card predation rate; %SNH = percentage semi-natural habitat; hedgerow = hedgerow presence; aphids = total aphid infestation; % bloom = percentage bloom of apple orchard; daytime = time of day of predation card deployment. For coefficients and their confidence intervals from all models in the model averaging sets see tables A.7-A.18.
Here we demonstrate that relatively small, annually cut hedgerows can have contrasting effects on different arthropod groups. Additionally, the effects of local habitat factors differed between arthropod taxa as well as between field margin and apple tree arthropod communities. Orchards bordered by hedgerows had lower wild bee richness and abundance within apple trees, but had higher natural enemy richness and abundance in the field margin. We found no effects of local and landscape factors on ecosystem service delivery, and limited spillover effects on crop yield. Overall, local habitat factors, as opposed to landscape context, most strongly and consistently predicted arthropod communities in apple orchards, but these effects likely only have implications for the effectiveness of field margin AESs as conservation measures and not as ecological intensification measures, since we did not observe clear impacts on ecosystem services and apple production.
4.1. Arthropod communities within field margins
Typically hedgerows provide enhanced floral resources that can support wild bees (Castle et al., 2019; Kremen et al., 2019). However, this is not the case in our study system because farmers manage their hedgerows to limit flowering due to the risk of fire blight (*Erwinia amylovora* (Burrill)) (Schouten, 1992), a widespread pome fruit disease (EPPO, 2014). Hedgerow margins did not have greater floral resources than control margins, which may explain why hedgerows did not support more bees. In addition, compared to field margins with hedgerows, control field margins had relatively higher richness and abundance of ground-nesting solitary and kleptoparasitic bee species, which might suggest that these sites harbored more suitable nesting locations, for example due to more soil exposure (Sardinas et al., 2016). Natural enemies, on the other hand, likely benefited from the vegetation structural diversity provided by the woody hedge species (Bartual et al., 2019). Flower cover in field margins also strongly predicted field margin natural enemy richness and abundance, likely due to the increased provision of nectar to necitivorous natural enemies (Landis et al., 2000; Morandin et al., 2014) but potentially also due to structural diversity provided by flowering species in herbaceous ground cover (Mateos–Fierro et al., 2021). These combined effects support previous studies that demonstrate the benefits of both woody and herbaceous habitats for natural enemies (Bartual et al., 2019; Bianchi et al., 2006), and indicate the importance of local habitat characteristics, since landscape context did not predict field margin natural enemy communities. These findings also might indicate that natural enemy communities in field margins are more limited by floral resource availability compared to bee communities, as bees were not strongly predicted by floral resources. However, as abundant alternative floral resources (apple trees) were available for bees during the bee sampling period, this finding should be interpreted with care.
It is commonly observed that landscapes with greater proportions of natural habitat support larger wild bee communities (Boetzl et al., 2021; Kennedy et al., 2013). While landscape context was generally positively correlated with field margin wild bee richness and abundance, this effect was not strong, possibly indicating that other unmeasured factors additionally determined bee communities. Furthermore, the effects of local habitat factors on arthropod communities were not dependent on landscape context, which supports the findings of a recent meta-analysis (Albrecht et al., 2020) and suggests that farmers can influence arthropod communities within field margins regardless of the type of landscape their farm is within. However, our study was limited by only considering the percentage of surrounding semi-natural habitat, while other measures such as landscape habitat richness or configuration may also influence pollinator and natural enemy dynamics (Haan et al., 2020; Senapathi et al., 2017), and thus may not have been captured in our results.
Table 2
Standardized full model-averaged coefficients (beta values) of all apple yield and quality models.\(^a\)
| Predictor | Response |
|--------------------|---------------------------|
| Wild bee richness | Initial fruit set |
| | Final fruit set |
| | Seed set |
| | Diameter |
| | Weight |
| | Symmetry |
| Wild bee richness | 1.8843 |
| NE richness | -10.8752 |
| Wild bee visits | – |
| Managed bee visits | -2.6767 |
| Aphid predation | – |
\(^a\) Presence of a coefficient indicates that the predictor variable was retained in the model averaging process. Bold coefficient values indicate that the 95% confidence interval does not include zero. NE richness = natural enemy richness. For coefficients and their confidence intervals from all models in the model averaging sets and for the individual apple varieties see tables A.19-A.24.
**Fig. 4.** Model-averaged predictions and 95% confidence interval of the marginal effect of natural enemy richness on initial fruit set. Points represent data averaged over site. Predictions are over the most frequent apple variety (Elstar).
### 4.2. Arthropod communities within apple trees
Arthropod communities within apple trees were overall less predicted by local and landscape factors compared to those in the field margin. However, wild bee communities were strongly negatively predicted by hedgerow presence. In addition to potentially providing fewer nesting resources, hedgerows may have influenced bee movement patterns. Linear landscape elements act as guides to bee movement (Van Geert et al., 2010), and thus bees are more likely to fly parallel to and alongside hedges than perpendicular to them (Cranmer et al., 2012). Due to this movement behavior, dispersal is significantly lower into fields when bees have to move away from a hedgerow as opposed to along it, and nearly zero when bees have to cross a hedgerow (Klaus et al., 2015). This effect combined with the lack of additional floral resources provided by hedgerows in our study system might explain why our results do not align with the positive effects observed in previous studies (Castle et al., 2019; Kremen et al., 2019). Furthermore, wild bees found on apple trees were not affected by landscape context, which contrasts with previous studies that show that crop fields in landscapes with high coverage of natural habitats have greater bee richness and abundance (Kennedy et al., 2013; Marini et al., 2012; Martins et al., 2015). Orchards represent the only major mass-flowering crops in our study area, and as bee sampling took place during apple and pear bloom, this likely influenced the measured relationship between landscape context and wild bee communities on apple trees (Fijen et al., 2019; Galpern et al., 2021). A high proportion of mass-flowering crops in a landscape can also dilute bee densities within mass-flowering crop fields, obscuring the effect of surrounding semi-natural habitat (Holschuh et al., 2016).
Natural enemies in apple trees were not strongly predicted by hedgerow presence or by other local and landscape factors. This may be due to the relatively low movement of natural enemies between hedgerow and orchard habitat (Lefebvre et al., 2017). The orchards in our study are intensively managed and receive multiple insecticide applications per year, which likely strongly mediates the effects of local and landscape habitat context on natural enemy communities (Happe et al., 2019; Ricci et al., 2019; Tscharnitke et al., 2016; Veres et al., 2013) and could explain why natural enemies within apple trees were not predicted by these factors. Additionally, orchards are relatively stable and undisturbed environments compared to arable fields, meaning that landscape context could play a lesser role in influencing natural enemy communities within this study system (Stutz and Entling, 2011) compared with the positive effect of landscape complexity that is typically observed across crop types (Chaplin-Kramer et al., 2011).
### 4.3. Ecosystem service delivery and apple yield
Although local habitat characteristics predicted arthropod communities in field margins and within orchards, they did not predict ecosystem service delivery to apple trees. One possible outcome of field margin AEIs is an ‘exporter’, or spillover, effect of arthropod communities and their associated services into the crop field (Morandin and Kremen, 2013). Our findings indicate a lack of spillover effects from the field margin onto measures important to crop production, which supports previous studies (Albrecht et al., 2020; Zamorano et al., 2020). In turn, apple tree arthropod species richness and ecosystem service delivery largely did not affect apple yield and quality, suggesting that variation in arthropod communities due to environmental factors does not carry over to crop yield. Crop management practices have a relatively large contribution to yield (Gervais et al., 2021; Sutter et al., 2017) and thus may mask the effects of arthropod communities (Dainese et al., 2019). Furthermore, while several studies have recorded positive effects of bee communities on apple yield (Blitzer et al., 2016; Pardo and Borges, 2020; Pérez-Méndez et al., 2020), it has been previously shown in the Netherlands that supplemental hand pollination does not increase apple yield or quality compared to standard insect pollination, suggesting that apples are not pollen-limited in this study system (de Groot et al., 2015; Garratt et al., 2021). Our findings may indicate support for this conclusion, since the recorded variation in bee richness and visitation rates did not correspond to any relationship with yield measures. However, visitation rate alone does not take into account other factors of pollination success, such as per-visit pollen deposition, which in apple differs across pollinator species and thus may influence the relationship between ecosystem service delivery and yield measures (Park et al., 2016).
Although wild bee abundance within apple trees was lower in orchards with hedgerows, this difference was not observed in wild bee visitation rate to apple flowers, suggesting that hedgerow presence did not in turn influence apple pollination services. On average, the difference in wild bee abundance between hedgerow and control sites was primarily due to a difference in solitary bee abundance, and to a much lesser extent in bumblebee abundance (Table A.25). A higher relative abundance of bumblebees within orchards with hedgerows could have compensated in overall visitation rate, since bumblebees spend less time per individual flower visit compared to solitary bees (Park et al., 2016). Alternatively, pollinators might have altered their foraging behavior due to decreased resource competition (Balfour et al., 2015) and visited more flowers with the reduction in competitors (Inouye, 1978).
The negative relationship observed between natural enemy richness
and initial fruit set may indirectly indicate a dependence of natural enemies on pest densities (Martin et al., 2016), although natural enemy communities on apple trees were not strongly predicted by aphid abundance in our models. Natural enemies in apple orchards have been shown to be very sensitive to pesticide use (McKerchar et al., 2020; Porcel et al., 2018), so an indirect effect of pesticide use, where higher toxicity loads reduced natural enemy and pest communities simultaneously and resulted in positive effects on yield, could explain this finding. However, while all orchards in this study were conventionally managed, we did not explicitly measure pesticide use.
5. Conclusions
We demonstrate that overall, local habitat factors, as opposed to landscape context, most strongly predict arthropod community richness and abundance in apple orchards. Differences in arthropod communities were mainly associated with hedgerow presence; however, this association was positive for natural enemies in field margins, and negative for wild bees in apple trees. To mitigate these potentially negative impacts, our findings suggest that field margins with hedgerows should be enhanced in other ways, for example by increasing ground-nesting resources. Enhancing floral resources within the ground cover along hedgerows, for example by reducing mowing frequency, likely would additionally support both bees and natural enemies. Our findings furthermore indicate that arthropods within habitats such as field margins are more affected by habitat context than those within the crop field, possibly due to the intensive management practices within crop fields. This implies that even if local factors more strongly affect arthropod communities than landscape factors, which is advantageous to farmers from a practical perspective, ultimately field margin AESs may have limited private benefits for farmers. Hedgerows in our study system have other benefits, such as historic, cultural, and aesthetic services and the conservation of other taxa such as birds and mammals, and thus they should remain subsidized. However, our study does indicate that the provision of arthropod-mediated ecosystem services to apple might not be included among these benefits. Our study points to the need to design AESs with separate conservation and ecosystem service delivery goals in mind (Ekroos et al., 2014; Kleijn et al., 2011; Macfadyen et al., 2012; Senapathi et al., 2015), and potentially also different species groups in mind. While field margin AESs may effectively promote biodiversity conservation, other AES strategies, such as enhancing habitats in orchard alleyways, may be better suited for ecosystem service delivery (Mateos-Fierro et al., 2021; Saunders and Luck, 2018), and should be continually studied to incorporate them into subsidization schemes.
Funding
This work was supported by the European Union’s Horizon 2020 research and innovation programme under grant agreement no. 862480, SHOWCASE project (SHOWCASing synergies between agriculture, biodiversity and ecosystem services to help farmers capitalising on native biodiversity, https://showcase-project.eu/). This article reflects only the views of the authors. The funding source had no role in the completion of the study or the creation of the article and is not responsible for any use that may be made of the information this article contains.
Declaration of Competing Interest
The authors declare that they have no known competing financial interests or personal relationships that could have appeared to influence the work reported in this paper.
Data availability
Data underlying this publication are available at https://doi.org/10.5061/dryad.sqv9s4n6s.
Acknowledgements
We would like to thank Aart Noordam for identifying the spiders and harvestmen, and the apple growers for their participation in the study.
Appendix A. Supporting information
Supplementary data associated with this article can be found in the online version at doi:10.1016/j.agee.2023.108364.
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|
Plenary Session 1
Induced Mutations in Food and Agriculture
The Role of Induced Mutations in World Food Security
M C Kharkwal\textsuperscript{1,*} & Q Y Shu\textsuperscript{2}
Abstract
Physical availability and economic accessibility of food are the most important criteria of food security. Induced mutations have played a great role in increasing world food security, since new food crop varieties embedded with various induced mutations have contributed to the significant increase of crop production at locations people could directly access. In this paper, the worldwide use of new varieties, derived directly or indirectly from induced mutants, was reviewed. Some highlights are: rice in China, Thailand, Vietnam, and the USA; barley in European countries and Peru, durum wheat in Bulgaria and Italy, wheat in China, soybean in China and Vietnam, as well as other food legumes in India and Pakistan. An exact estimate of the area covered by commercially released mutant cultivars in a large number of countries is not readily available, but the limited information gathered clearly indicates that they have played a very significant role in solving food and nutritional security problems in many countries.
Introduction
Ever since the epoch-making discoveries made by Muller [1] and Stadler [2] eighty years ago, a large amount of genetic variability has been induced by various mutagens and contributed to modern plant breeding. The use of induced mutations over the past five decades has played a major role in the development of superior plant varieties all over the world (Fig. 1a). Among the mutant varieties, the majority are food crops (Fig. 1b).
Declaration on World Food Security [4] on food plan action observed that, “Food security at the individual, household, national and global level exists where all people at all times have physical and economic access to sufficient, safe and nutritious food to meet their dietary needs and food preferences for an active and healthy life”. In both definitions, emphasis has been given to physical availability and economic accessibility of food to the people. The mutant varieties are often grown by farmers in their fields, and any increase of food production resulted from the cultivation of the mutant varieties could be translated into increased food security, since this should be accessible for the people in need.
A detailed review on the global impact of mutation-derived varieties developed and released in major crops all over the world has been published by Ahloowalia, et al. [5]. Several papers presented in this Symposium have also elaborated the contribution of induced mutations to food security in either a particular country or a particular crop. Herewith, we present the overall role of induced mutations worldwide, by continent and country, with emphasis on those countries not already discussed in papers which are included in this book.
ASIA
According to the FAO/IAEA database [6], more than half of the mutant derived varieties were developed in Asia (Fig. 1); China, India, and Japan are the three countries that released the largest number of mutant varieties in the world. Some important achievements are summarized here.
China
In China, the mutant rice variety ‘Zhefu 802’ deriving from var. ‘Simei No. 2’, induced by Gamma-rays, has a short growing period (105 to 108 days), high yield potential even under poor management and infertile conditions, wide adaptability, high resistance to rice blast, and tolerance to cold [5]. Therefore, it was the most extensively planted conventional rice variety between 1986 and 1994. Its cumulative planted area reached 10.6 million ha during that period [7]. Two other mutant rice varieties, Yuanfengzao (1970’s) and Yangdao \# 6 (2000’s), developed and released before and after Zhefu 802, are further mutant varieties that had been grown on annual scales up to one million ha (Ministry of Agriculture, China, unpublished data). Using a pollen irradiation technique, two new high-quality, high-yield, and early maturity mutant varieties – Jiahezazhan and Jiafuzhan, resistant to blast and plant-hopper, as well as endowed with a wide adaptability - were developed and are now planted annually on 363,000 ha in Fujian province of China [8].
China has also been successful in breeding soybean varieties using mutation techniques. For example, the mutant soybean varieties developed by the Genetics Institute of the Chinese Academy of Sciences possess different excellent traits such as high yield, good grain quality, disease/insect resistance, or drought/salt tolerance. The total area planted with these varieties was more than $1 \times 10^7$ ha. [9]. The “Henong series” soybean mutant cultivars, developed and released by the Soybean Institute of Heilongjiang Academy of Agricultural Sciences, as well...
as another variety, Tiefeng18, were grown on an area of more than 2.33x10⁶ ha and 4x10⁶ ha respectively (Ministry of Agriculture, China, unpublished data).
China has developed and released a large number of high yielding groundnut mutant varieties during the last few decades. The cumulative cultivated area of the more than 35 mutant cultivars released accounts for about 20% of the total area under groundnut in China [10].
In India, sustained efforts for crop improvement through induced mutations were initiated during the second half of the 1950s, although the world’s very first mutant variety of cotton, MA-9 induced by X-rays, endowed with drought tolerance, was released in 1948 by India [11]. The Indian Agricultural Research Institute (IARI) in New Delhi; Bhabha Atomic Research Center (BARC) in Mumbai, Tamil Nadu Agricultural University (TNAU) in Coimbatore, and the National Botanical Research Institute (NBRI) in Lucknow, are some of the major research centers actively engaged in mutation breeding for several crops and have contributed substantially to the development and release of a large number of mutant varieties. Kharkwal, et al. [11] in 2004 listed a total of 309 mutant cultivars of crops, belonging to 56 plant species that were approved and/or released in India by the end of the twentieth century. An updated list of 343 mutant cultivars released in India is given in Table 1. The largest number of mutant cultivars have been produced in ornamentals (119), followed closely by legumes (85) and cereals (74).
The mutant cultivars have contributed immensely in augmenting the efforts of Indian plant breeders in achieving the target of food self-sufficiency and strong economic growth. Mutation breeding has thus significantly contributed to the increased production of rice, groundnut, chickpea, mungbean, urdbean, and castor in the Indian sub-continent. While authentic information on the area covered under these cultivars is unfortunately lacking in general, some data is available as summarized below.
The mungbean varieties Co-4, Pant Mung-2, and TAP-7, though released in the early 1980s, are still being grown widely around the country. The variety TARM-1, resistant to powdery mildew and YMV diseases, is the first of its kind to be released for *rabi* rice fallow cultivation. Four of the nine mutant varieties of blackgram (urdbean) released in India have been developed at the Bhabha Atomic Research Centre (BARC) in Mumbai. One of these mutant varieties, TAU-1, has become the most popular variety in Maharashtra State, occupying an area of about 500,000 hectares (over 95% of the total area under urdbean cultivation in Maharashtra). Since 1990, the Maharashtra State Seed Corporation, Akola, has distributed about 200,000 quintals of certified seeds of TAU-1 to the farmers, which has resulted in an additional production of about 129,000 quintals of urdbean annually in Maharashtra. The notional income generated by additional production amounts to Rs. 300 crores (about 60 million US dollars) annually [11].
Several high-yielding rice mutants were released under the ‘PNR’ series; some of these were also early in maturity and had short height [12]. Among these, two early ripening and aromatic mutation-derived rice varieties, ‘PNR-381’ and ‘PNR-102’, were very popular with farmers in Haryana and Uttar Pradesh States. No data is available on the actual area planted with these varieties. However, based on the rate of fresh seed replacement by farmers and the distribution of breeder seed, foundation seed, and certified seed, as well as on the basis of data obtained from IARI, the value of rice (paddy) production would be 1,748 million US dollars per year [5].
**Chickpea:** The four high yielding and Ascochyta blight and wilt disease resistant chickpea mutant varieties Pusa – 408 (Ajay), Pusa – 413 (Atul), Pusa – 417 (Girnar), and Pusa – 547, developed at I.A.R.I., New Delhi, and released by the Indian government for commercial cultivation, are the first examples of direct use of induced micro-mutants in a legume crop in the world. Beside high yield performance under late sown crop, chickpea mutant variety Pusa – 547, released in 2006 for farmers’ cultivation, has attractive bold seeds, thin testa, and good cooking quality [11, 13, 14, 15].
The success of mutant varieties released is also evident from the large quantities of breeder seed of several mutant varieties at the national level (Table 2).
### Table 1. Number of released mutant varieties in 57 crop species in India
| SN | Latin name | Common name | No. of varieties |
|----|------------------------------------------------|-----------------|------------------|
| 1 | *Abelmoschus esculentus* L. Moench | Okra | 2 |
| 2 | *Arachis hypogaea* L. | Groundnut | 18 |
| 3 | *Bougainvillea spectabilis* Wild | Bougainvillea | 13 |
| 4 | *Brassica juncea* L. | Mustard | 9 |
| 5 | *Cajanus cajan* L. Millsp. | Pigeonpea | 5 |
| 6 | *Capsicum annuum* L. | Green pepper | 1 |
| 7 | *Carica papaya* L. | Papaya | 1 |
| 8 | *Chrysanthemum* sp. | Chrysanthemum | 49 |
| 9 | *Cicer arietinum* L. | Chickpea | 8 |
| 10 | *Corchorus capsularis* L. | White jute | 2 |
| 11 | *Corchorus olitorius* L. | Tossa jute | 3 |
| 12 | *Curcuma domestica* Val. | Turmeric | 2 |
| 13 | *Cymbopogon winterianus* Jowitt. | Citronella | 9 |
| 14 | *Cyamopsis tetragonoloba* L. | Cluster bean | 1 |
| 15 | *Dahlia* sp. | Dahlia | 11 |
| 16 | *Dolichos lablab* L. | Hyacinth bean | 2 |
| 17 | *Eleusine coracana* L. | Finger millet | 7 |
| 18 | *Gladiolus* L. | Gladiolus | 2 |
| 19 | *Glycine max* L. Merr. | Soybean | 7 |
| 20 | *Gossypium arboreum* L. | Desi cotton | 1 |
| 21 | *Gossypium hirsutum* L. | American cotton | 8 |
| 22 | *Helianthus annus* L. | Sunflower | 1 |
| 23 | *Hibiscus sinensis* L. | Hibiscus | 2 |
| 24 | *Hordeum vulgare* L. | Barley | 13 |
| 25 | *Hyocamus niger* | Indian henbane | 1 |
| 26 | *Lantana depressa* L. | Wild sage | 3 |
| 27 | *Lens culinaris* Medik. | Lentil | 3 |
| 28 | *Luffa acutangula* Roxb. | Ridged gourd | 1 |
| 29 | *Lycopersicon esculentum* M. | Tomato | 4 |
| 30 | *Matricaria camomilla* | Germen chamomile| 1 |
| 31 | *Mentha spicata* | Spearmint | 1 |
| 32 | *Momordica charantia* L. | Bitter gourd | 1 |
| 33 | *Morus alba* L. | Mulberry | 1 |
| 34 | *Nicotiana tabacum* L. | Tobacco | 1 |
| 35 | *Oryza sativa* L. | Rice | 42 |
| 36 | *Papaver somniferum* L. | Opium poppy | 2 |
| 37 | *Pennisetum typhoides* L. | Pearl millet | 5 |
| 38 | *Phaseolus vulgaris* L. | French bean | 1 |
| 39 | *Pisum sativum* L. | Pea | 1 |
| 40 | *Plantago ovata* L. | Isabgol | 2 |
| 41 | *Polyanthus tuberosa* L. | Tuberose | 2 |
| 42 | *Portulaca grandiflora* L. | Portulaca | 11 |
| 43 | *Ricinus communis* L. | Castor | 4 |
| 44 | *Rosa* sp. | Rose | 16 |
| 45 | *Saccharum officinarum* L. | Sugarcane | 9 |
| 46 | *Sesamum indicum* L. | Sesame | 5 |
| 47 | *Setaria italica* L. | Foxtail millet | 1 |
| 48 | *Solanum khasianum* Clarke | Khasianum | 1 |
| 49 | *Solanum melongena* L. | Brinjal | 1 |
| 50 | *Solenostemon rotundifolius* | Coleus | 1 |
| 51 | *Trichosanthes anguina* L. | Snake gourd | 1 |
| 52 | *Trifolium alexandrum* L. | Egyptian clover | 1 |
| 53 | *Triticum aestivum* L. | Wheat | 4 |
| 54 | *Vigna aconitifolia* Jacq. M. | Moth bean | 5 |
| 55 | *Vigna mungo* L. Hepper | Blackgram | 9 |
| 56 | *Vigna radiata* L. Wiczek | Mungbean | 15 |
| 57 | *Vigna unguiculata* L. Walp. | Cowpea | 10 |
**Total** 343
The release of ‘TG’ (Trombay groundnut) cultivars of groundnut in India has contributed millions of dollars to the Indian economy. Detailed information on the great success of mutation breeding of groundnut and legumes, as well as their contribution to food security in India, can be found in another paper in this book [16].
| S.No. | Crop | Mutant variety | BS (kg) | Period |
|-------|----------|----------------|---------|--------|
| 1 | Groundnut| TAG-24 | 427,500 | 5 yr |
| 2 | Groundnut| TG-26 | 78,600 | 5 yr |
| 3 | Groundnut| TPG-41 | 37,100 | 2 yr |
| 4 | Barley | RD-2035 | 53,600 | 4 yr |
| 5 | Soybean | NRC-7 | 50,200 | 5 yr |
| 6 | Chickpea | Pusa-547 | 9,100 | 1 yr |
Japan
More than 200 direct-use mutant varieties generated through gamma irradiation, chemical mutagenesis, and somaclonal variations, have been registered in Japan [17]. About 61% of these were developed through mutation induction by Gamma-ray irradiation at the Institute of Radiation Breeding. In 2005, two direct-use cultivars and 97 indirect-use cultivars made up for approximately 12.4% of the total cultivated area in Japan. More information about mutant varieties and their contribution to food production in Japan is available in Nakagawa’s paper in this book [17].
Thailand
The contribution of induced mutation to food production in Thailand is best reflected by the work on rice. Two aromatic *indica* type varieties of rice, ‘RD6’ and ‘RD15’, released in 1977 and 1978 respectively, were derived from gamma irradiated progeny of the popular rice variety ‘Khao Dawk Mali 105’ (“KDM1 105”). RD6 has glutinous endosperm and retained all other grain traits, including the aroma of the parent variety. RD15, on the other hand, is non-glutinous and aromatic like the parent, but ripens 10 days earlier than the parent, which is a major advantage for harvesting before the onset of the rainy season in the respective areas. Even 30 years after their release these two varieties are still grown extensively in Thailand, covering 80% of the rice fields in north-eastern Thailand. According to the Bureau of Economic and Agricultural Statistics, during 1995-96, RD 6 was grown on 2,429,361 ha, covering 26.4% of the area under rice in Thailand, producing 4,343,549 tons paddy [5, 18], and in 2006 was still cultivated on an area of more than one million ha (S. Taprab, personal communication, July 2007). Thailand is the largest exporter of aromatic rice to the world market. Thus, the impact of the two rice mutant varieties is far beyond the farm gate with a major contribution to the export earnings. Between 1989 and 1998, the contribution of RD6 paddy was 4.76 billion US dollars, of milled rice 15.3 billion US dollars, and that of RD15 485.6 million US dollars for paddy, and 1.6 billion US dollars for milled rice. Hence, from 1989-98, the two varieties RD6 and RD15 yielded a total of 42.0 million tons paddy or 26.9 million tons milled rice worth 16.9 billion US dollars [5].
Other Asian countries
Induced mutations have also been widely used in many other Asian countries for breeding new varieties and in turn contributed to food security. Detailed information for Pakistan [19] and Vietnam [20] can be found elsewhere in this book.
In the Republic of Korea, sesame (*Sesamum indicum*) yield has been increased more than twice (from 283 kg/ha to 720 kg/ha) due to development and release of 15 improved determinate type, high oil content mutant varieties having phytophthora blight resistance and good cooking quality. These mutants occupied 55% of the national acreage during the last two decades in Korea [21].
In Bangladesh, mutation breeding has resulted in the release of more than 40 mutant varieties belonging to more than 12 crop species. The Bangladesh Institute of Nuclear Agriculture (BINA), Mymensingh, is the major center of mutation breeding, and has released 16 mutant varieties of pulses, 11 of oilseeds, seven of rice, and five of tomato. Rice mutant var. Binasail, Iratom-24, Binadhan-6, all planted in a cumulative area of 795,000 ha, and mungbean mutant variety Binamoog-5, cultivated in 15,000 ha as a summer crop, have contributed substantially towards food security in Bangladesh [Ali Azam, personal communication, April 2008].
In Myanmar, the rice mutant variety ‘Shwewartun’ was developed and released in 1975 after irradiation of ‘IR5’ seeds in 1970. The improvement in grain quality, seed yield, and early maturity of the mutant compared to its parent variety, led to its large-scale planting. Between 1989-1993, it covered annually more than 0.8 million ha - 17% of the 4.8 million ha area under rice in Myanmar [5].
During the past decade, Vietnam has become an icon for the success of mutation breeding. Though it used to import 2-3 million tons of food annually in the decade of 1970-1980, Vietnam exported 4.3 million tons of rice, becoming the world’s second-largest exporter of rice. The wide use of high yielding crop varieties including dozens of mutant varieties contributed substantially to this transformation into food self-sufficiency. For example, the mutant rice variety VND-95-20, grown on more than 300,000 ha/year, has become the top variety in southern Vietnam, both as an export variety and in terms of growing area. More information about mutant varieties and their great importance for the food security in Vietnam today, can be found in another paper in this book [20].
EUROPE
Induced mutations have become an inherent component of many current plant varieties in Europe, particularly for barley and durum wheat. Mutation techniques are also widely used in the breeding of flowers and horticulture cultivars, although it is not the topic of this paper. A few examples are given here, while the situation in Sweden is available elsewhere in this book [22].
Czech Republic and Slovakia (former Czechoslovakia)
The Gamma-ray induced cultivar Diamant was officially released in Czechoslovakia in 1965. Diamant was 15cm shorter than the parent cultivar ‘Valticky’, and had an increased grain yield of around 12%. In 1972, 43% of 600,000 ha of spring barley in Czechoslovakia were planted under either Diamant or mutant cultivars derived from Diamant. Roughly estimated, the total increase in grain yield was about 1,486,000 tons. During the same year, the spring barley cultivars that had mutated Diamant’s *denso* gene in their pedigree were grown all over Europe on an area of 2.86 million ha [23].
The high-yielding, short-height barley mutants Diamant and Golden Promise were a major impact on the brewing industry in Europe; they added billions of US dollars to the value of the brewing and malting industry. More than 150 cultivars of malting barley in Europe, North America, and Asia were derived from crosses involving Diamant [5].
Finland
Balder J, a high yielding barley mutant released in Finland, had higher yield, greater drought resistance, better sprouting resistance, and greater 1,000 kernel weight. Nearly 1 million kg of ‘Balder J’ seed were sold by Jokioinen Seed Center [24]. Oat stiff straw mutant cultivar Ryhti occupied up to 41% of the total area of oat in Finland during 1970-80. Another stiff straw oat mutant cultivar, Puhti, released in 1970, occupied 30% of the oat planting area in Finland. Many new varieties now grown are derived from crosses with these mutant varieties [25].
Germany
Trumpf, the best-known barley mutant cultivar obtained after crossing with cultivar Diamant occupied more than 70% of the barley planting area in Germany. The mutant had a yield increased by 15% and better disease resistance. Used extensively in crossbreeding, Trumpf became incorporated into many barley breeding programmes in a large number of countries [25].
Italy
Mutant cultivar Creso of durum wheat was grown in about one-third of the total area of durum wheat in Italy. During a period of 10 years, in Italy alone, an extra economic profit of 1.8 billion US dollars was obtained by growing this cultivar. Castelporziano and Castelfusano high-yielding durum wheat mutants had shorter culms and spike length, better resistance to lodging, but higher numbers of grain per spikelet. Planted in sizable areas, they contributed notably to the national economy of Italy. Both mutants were also used in extensive crossbreeding [5, 24].
NORTH AMERICA
In North America, the USA is one of the world pioneering countries in the exploitation of induced mutation for plant improvement and has had many extraordinary successes. Significant progress has also been reported from Canada, and more recently Mexico.
USA
Wheat: Stadler, a high-yielding wheat mutant released in Missouri, had early maturity, resistance to races of leaf rust and loose smut, as well as better lodging resistance. It was once grown on two million acres annually in the USA [24].
Barley: Luther, a barley mutant, had 20% increased yield, shorter straw, higher tillering, and better lodging resistance. About 120,000 acres were planted annually in three states of the USA - a gain of an estimated 1.1 million US dollars in one year. It was used extensively in cross-breeding and several mutants were released. Pennrad, a high yielding winter barley mutant was released in Pennsylvania, had winter hardiness, early ripening and better lodging resistance. It was grown on about 100,000 ha in the USA [24].
Beans: Sanilac, a high-yielding Navy pea bean mutant cultivar, developed after irradiation with X-rays and released in Michigan, was grown on more than 87,000 ha. Similarly, about 160,000 ha were planted with common bean cultivars Gratiot and Sea-way, developed likewise by cross-breeding with a Michelite mutant [5, 24].
Rice: The semi dwarf gene allele sdl, which was induced through Gamma-ray mutagenesis, has enabled the American version of the “Green Revolution” in rice. Details of the sdl allele and its contribution to the rice production in the USA (as well as in Egypt and Australia) are shown in this book [26].
Two grapefruit varieties, Star Ruby and Rio Red, both developed through thermal neutron mutagenesis [27], have become a widely grown variety during the past two decades. The fruits of both cultivars are sold under the trademark ‘Rio Star.’ Rio Star’ grapefruit is currently grown on 75% of the grapefruit planting area in Texas. The development of the two radiation induced mutant cultivars is considered as the most significant breakthrough in grapefruit growing in Texas since the discovery of Ruby Red in 1929 [5].
Canada
Rapeseed-Canola (Double zero rapeseed): Canola is Canada’s third most important grain export, after wheat and barley. Contribution of Canola cultivars to the Canadian economy has been outstanding. In 2000, Canada planted 5,564,000 ha under canola and earned 350.5 million US dollars. Mutant cultivars with low erucic acid and very low (more than 30μm/g) glucosinolates have been developed and released in Canada [5].
The strongest modification of oil composition with induced mutations has been the development and release of linseed cultivars of the ‘linola’ type in Australia and Canada. Zero is the low-linolenic acid genotype derived by EMS (ethyl methanesulphonate) mutagenesis of the Australian linseed cultivar Glenelg and recombination of two mutated genes [28].
Mexico
In Mexico, promotion of radio-induced mutation breeding started in 1974. Two new wheat varieties, ‘Centauro’ and ‘Bajio Plus,’ were derived from ‘Salamanca’ seeds irradiated at 500Gy; they showed increased yield and tolerance to lodging. Two soybean varieties, ‘Hector’ and ‘Esperanza,’ were obtained by irradiation of seeds from variety ‘Suaqui 86’ at 150Gy. These new varieties exhibit an increased yield and reduction in dehiscence and lodging, being tolerant to white fly. ‘SalCer’ is another new soybean variety obtained through irradiation of seeds from line ISAEGBM₂ at 200Gy. Its improved traits are higher yields and increased height to first pod [29].
LATIN AMERICA
Argentina
Colorado Irradiado, a groundnut mutant with high yield and fat content, induced by X-rays, occupied more than 80% of the groundnut area (280,000 ha) in Argentina in the 1970s [Prina, A.R., Personal communication, August 2008]. Puita INTA-CL, a rice mutant with high yield and herbicide resistance, released in 2005, has occupied more than 18% of the rice growing area (32,400 ha) in Argentina since then[Prina, A.R., Personal communication, August 2008]. Also planted in Brazil, Costa Rica, Paraguay and Bolivia, this mutant variety has contributed significantly to these Latin American countries’ economies and their food security.
Cuba
Rice: Attempts to obtain a rice mutant variety with good agronomical characteristics and salinity tolerance have been successful in Cuba. The first mutant released from in vitro mutagenesis using proton radiations in Cuba is ‘GINEs,’ which shows the best performance under saline conditions, and has been successfully introduced in rural areas of Pinar del Rio and Havana provinces [30].
Tomato: The very first tomato mutant released in Cuba, ‘Maybel,’ has shown very high performance under drought conditions and has been introduced in rural areas of different provinces of Cuba [31].
Peru
Mutation breeding has been very successfully used in breeding barley, the fourth most important food crop in terms of area in Peru. Centenario, a barley mutant with high yield (37% over the parent cultivar), earliness (18 days), higher protein (10.3%), better test weight and resistance to yellow rust, was released in 2006, is replacing the traditional cultivars of the central highlands of Peru, and contributes significantly to the food security of the country [32].
Kiwicha (Amaranthus caudatus) is a native and ancient crop of the Andean Region. Centenario (MSA-011), a mutant with high yield, earliness (45 days), tolerance to salinity, wide adaptability, better grain color and size, as well as higher market price, was released in 2006 and has covered 40% of the total Peruvian land dedicated to kiwicha crops [32].
AUSTRALIA
Rice: Nine rice varieties - ‘Amaroo’ (1987), ‘Bogan’ (1987), ‘Echua’ (1989), ‘Harra’ (1991), ‘Illabong’ (1993), ‘Jarrah’ (1993), ‘Langi’ (1994), ‘Millin’ (1995), and ‘Namaga’ (1997) - have been introduced in Australia. Rice mutant variety Amaroo has covered 60–70% of the rice cultivation area of Australia, and on average yielded 8.9 t/ha grain with a potential of 13.3 t/ha [33].
**Lupine:** Spontaneous mutation has been discovered and utilized in domestication of narrow-leaved lupine (*Lupinus angustifolius* L.). As the result of the domestication, lupine has become a dominant grain legume crop in Western Australia. Facing the new challenge of developing herbicide-tolerant cultivars, chemical mutagenesis has been used to create new tolerance to herbicide. The two lupine mutants (Tanjil-AZ-33 and Tanjil-AZ-55) are highly tolerant, six times more tolerant to metribuzin herbicide than the original parental cultivar Tanjil. This mutant Tanjil-AZ-33 is the most tolerant germplasm in narrow-leaved lupine. Both mutants also maintain the high yield and resistance to the disease anthracnose as cv Tanjil. These facts indicate that the mutation process has created tolerance to metribuzin in Tanjil, but has not altered Tanjil’s yield capacity and anthracnose resistance. Induced mutation proves to be an effective tool in lupine improvement [34].
**AFRICA**
**Egypt**
As a result of the introduction of the two semi-dwarf mutant varieties, ‘Giza 176’ (1989) and ‘Sakha 101’ (1997) in Egypt, the average yield of rice in Egypt increased to 8.9 t/ha, compared with 3.8 t/ha in the rest of the world. Of these two, ‘Giza 176’ became the leading variety, with a potential yield of 10 t/ha [35].
**Sudan**
Mutation breeding in Sudan was effectively started about 20 years ago and covered crops like cotton, sugarcane, sesame, banana, tomato, groundnuts, and cereals. A banana mutant cultivar (Albeely) was released in the year 2003. Albeely excelled the yield of the existing cultivars by 40% and has better crop stand and fruit quality. Albeely is becoming popular and is widely preferred by farmers. A drought tolerant groundnut mutant (Barberton-B-30-3) and a number of promising mutants resistant to tomato yellow leaf curl virus (TYLCV) are being evaluated in multi-location trials, in preparation for their commercial release. Cotton germplasm has been enriched with a number of useful mutants carrying resistance for bacterial blight and fusarium wilt disease, in addition to mutants for weak fiber attachments, high ginning out turn, and lint percentage. These mutants are being used in the breeding programme, and promising lines are under field evaluation for release [36].
**Ghana**
Over two decades of application of induced mutation techniques toward crop improvement in Ghana have led to the production of improved mutant varieties in two crops. In cassava (*Manihot esculenta* Crantz), irradiation of stem cuttings using gamma irradiation resulted in the production of “Tek bankye,” a mutant variety with high dry matter content (40%) and good poundability from the parental line, which was a segregant of a hybrid between the Nigerian landrace Isunikanikani (ISU) and the breeder’s line TMS4(2)1425, both from IITA, Nigeria. Similarly, irradiation of vegetative buds of ‘Amelonado’ (P30), ‘Trinitario’ (K.5), and ‘Upper Amazon’ (T85/799) cocoa varieties resulted in the production of a mutant variety resistant to the Cocoa Swollen Shoot Virus (CSSV). Multi-location on-farm trials of the mutant line indicate significant increases in yield for farmers, without symptoms of the disease [37].
**Perspectives**
World food security deteriorated very sharply in the 1960’s when developing countries like India, Pakistan, and Indonesia were desperately short of food grains. Fortunately, agricultural scientists responded with a new production technology, which has popularly been described as “Green Revolution Technology.” This helped to avoid large-scale starvation for around 40 years. However, the food security problem has again seen a major deterioration in the last few years; food prices are rising sharply and once again the poor people of the world are threatened with serious malnutrition. The underlining causes that drove to food security deterioration, i.e. rising fuel and fertilizer prices, climate change related erratic rain falls, sudden and severe drought conditions, excessive floods, divert of food grains into bio-fuel production, will remain for the years to come. Food security will even get worse since population is still growing while no significant expansion of arable lands is foreseen. FAO estimates that world food production should increase by more than 75% in the next 30 years to feed about eight billion people by 2025 [38]. Therefore, a new “Green Revolution” is desperately needed to solve the food security issue in the years to come.
The massive advent of plant molecular biology is anticipated to provide a sound solution to further increase food production by both increasing yield potential and stability. In this regard, induced mutagenesis is gaining importance in plant molecular biology as a tool to identify and isolate genes, and to study their structure and function. Several papers in this book report the progress being made in this area. Recently mutation techniques have also been integrated with other molecular technologies, such as molecular marker techniques or high throughput mutation screening techniques; mutation techniques are becoming more powerful and effective in breeding crop varieties. Mutation breeding is entering into a new era: molecular mutation breeding. Therefore, induced mutations will continue to play a significant role for improving world food security in the coming years and decades.
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Eighty Years of Scandinavian Barley Mutation Genetics and Breeding
U Lundqvist
Abstract
In 1928, the Swedish geneticists H. Nilsson-Ehle and Å. Gustafsson started on their suggestion experiments with induced mutations using a diploid barley species. The experiments started with X-rays and UV-irradiations, soon the first chlorophyll mutations were obtained followed by the first ‘vital’ mutations ‘Erectoides.’ Several other valuable mutants were considered: high-yielding, early maturity, lodging resistance and with changed ecological adaption. Soon the X-ray experiments expanded with different pre- and after-treatments, also using other types of irradiation, such as neutrons, positrons etc., and finally with chemical mutagens, starting with mustard gas and concluding with the inorganic sodium azide. The research brought a wealth of observations of general biological importance, high increased mutation frequencies, differences in the mutation spectrum and to direct mutagenesis for specific genes. This Scandinavian mutation research was non-commercial even if some mutants have become of some agronomic value. The peak of its activities was during the 1950s, 1960s and 1970s. Barley has been the main experimental material, but also other species were included in the programme. Over the years a rather large collection of morphological and physiological mutations (10,000 different mutant genes) with a broad variation were collected and several characters have been analyzed in more detail genetically and with regard to mutagen specificity. Most effort has been made on the Early maturity mutants, the Six-row (hexastichon) and Intermedium mutant group, the Surface wax coating Eceriferum (Waxless) mutants, Dense spike mutants and others.
The first mutation experiments
Swedish research on induced mutations started in a small scale at Svalöf 80 years ago, initiated by the eminent Swedish geneticists H. Nilsson-Ehle and Å. Gustafsson. Already in 1927, the North American geneticist and later Nobel laureate, H.J. Muller, using successful experiments could show that ionizing radiation could increase the mutation frequency in the fruit fly Drosophila [1, 2]. He drew the conclusion that induced mutations were similar to spontaneous mutations forming the basis for natural selection and evolution. Soon, in 1930, the equally famous American geneticist and plant breeder, L.J.Stadler [3], published data on induced mutations in several species of cultivated plants which he interpreted with much pessimism. In his opinion, no practical progress could be expected from artificial gene changes. But Nilsson-Ehle and Gustafsson did not share this pessimism and on Gustafsson’s suggestion experiments were initiated with induced mutations in plant material.
The first treatments with X-rays and ultraviolet irradiation were commenced in barley, using the Svalöf cultivar ‘Gull.’ Instead of measuring exact dosages of radiation, different durations of radiations were applied. Also different types of pre-treatments were tested since it was known from Stadler’s investigations that the mutation frequency increases if the seeds are soaked in water before irradiation. The first chromosome aberrations were observed, mainly chromosome fragmentations, fusions and translocations [4]. The first genotypical changes in the seedlings, chlorophyll mutations, most of them sublethal, occurred. Three distinct main categories were established: albina seedlings, viridis seedlings, a very heterogeneous group, and rare mutations (xantha, two-coloured, striped and zoned). These chlorophyll mutations were a useful material for laboratory studies and were the first indications of how successful the treatment was. The mutation frequency was calculated according to the “spike progeny method” introduced by Gustafsson, and served as the standard method for measuring the induced mutagenic effects [5, 6].
Very soon, in the mid-1930s, the first viable mutations appeared and already at that time it was possible to distinguish two sub-groups: Morphological and Physiological mutations. The most common group of viable mutations at that time consisted of the so-called erectoides mutants that are characterized by typical compact or dense spikes in contrast to the nutans spike of most barley cultivars. In the following years many of the mutants produced were considered extremely valuable for future theoretical genetic studies and for breeding. Several of them are worth mentioning: high-yielding, early maturity, tillering capacity, straw-stiffness, seed-size, seed-color, changed spike formation and others [7, 8].
The Swedish group for theoretical and applied mutation research
The results from these early experiments looked so promising, even for plant breeding, that in 1940, the Swedish Seed Association at Svalöf started to support this research with funding from the Swedish milling industry. This rendered it possible to extend the experiments considerably. In addition, other species such as wheat, oats, flax, peas, faba beans and oil crops were included in the programme, and it became possible to integrate theoretical and practical results. In 1948, the Wallenberg Foundation incorporated mutation activities into its research programme, and a group of specialists were gathered to carry on the research work on a wider front. Finally, in 1953, at the instigation of the Swedish Government the Group for Theoretical and Applied Mutation Research’ was established, with the aim of studying basic research problems in order to influence and improve the methods for breeding of cultivated plants. The Agricultural Research Council had provided funding for most of the Mutation Group’s scientific activities approved by the Swedish Parliament. Its peaks of activities were during the 1950s, 1960s and 1970s. Barley was used as main model crop since it is a diploid self-fertilizing species, easy to handle, gives a sufficiently large progeny from a single plant and outcrosses only rarely [9, 10].
Applying different mutagenic treatments
X-irradiation on dry seeds was used as a standard method for studying the mutation process, but soon other types of irradiation such as γ-rays (acute and chronic), neutrons (fast and thermal), electrons, protons, α-rays from radon, β-rays from Phosphorus 32 and Sulphur 35 were included in the experiments. The application of pre-treatments with different soaking times of the seeds, both before and after irradiation
was studied. Not only the water content of the seeds was an important trait in relation to radiation sensitivity, but also different environmental conditions [11, 12]. The two irradiation types, sparsely versus densely ionizing radiation, were compared in the following properties: (1) the number of chromosome disturbances in the germinating seeds, (2) field germination, (3) number of mature harvested plants, (4) the mutation rate determined from the number of various chlorophyll-deficient mutants, and (5) different types of vital mutants determined on field material in the second generation. When comparing the two irradiation types it can be summarized as follows: The injurious action of neutrons differs from that of X-rays in several respects. The seeds are 20–30 times more sensitive in neutrons than to X-rays and germinating seeds are two to three times more sensitive to neutrons than dormant seeds. Neutrons are approximately 10 times as effective as X-rays in producing chromosome disturbances and about 50–100 times more effective in increasing the mutation rate in the second generation. Neutrons produce relatively more chlorophyll mutations than X-rays. Observations also showed that while X-irradiated seeds die at a very early stage of development, the neutron-treated seeds which received a lethal dose often start germination, not dying until cell divisions become of critical importance for their further growth [13, 14].
Already in the mid-1940s chemical mutagenesis started to be included in experiments together with irradiation. The idea was to influence not only the mutation rate but also the types of mutations. The real work on chemical mutagenesis in crop plants began with the effects of mustard gas followed by many different compounds such as various alkylating and oxidizing agents, epoxides and epimines, purines, organic sulphates and sulphonates, nitroso compounds, purine and acridine derivatives and many others [15–23]. Finally, in the mid-1970s, the first experiments were started with the inorganic chemical mutagen ‘Sodium azide’ that in Swedish experiments was mostly used for isolation of viable mutants for practical agronomical purposes [10, 24, 25]. For chemical mutagens the mutation frequency increased rapidly up to 80%; they were 20 times more effective than irradiation. Significant differences between the actions of ionizing radiation and chemical mutagens were demonstrated. In this respect, neutrons and sodium azide form two extremes: neutrons induce a relatively large number of chromosome and chromatid changes, whereas sodium azide primarily causes gene mutations at the nucleotide level. Differences in the mutation spectrum were noticed especially with regard to chlorophyll mutants as they were studied most intensively. Neutrons induce a higher rate of albina seedlings than X-rays and chemical mutagens. The chemical mutagens are superior in inducing the large heterogeneous group of viridis seedlings. Also in some morphological mutation groups and mutants useful for plant breeding it was possible to observe differences in the mutation spectrum. The aim was to control the direction of mutagenesis [10, 26].
The Swedish mutation research was non-commercial, despite that some mutants have been used in practice – directly or after recombination breeding [27]. The mutation programme brought a wealth of observations of general biological importance: chronology of chromosome reproduction, sensitivity of different mitotic stages, the importance of heterochromatin, mutations in polyploids, the variation of irradiation sensitivity in different species and competition between various elements in plant tissues.
**The Swedish collection of barley mutants**
Genetic diversity is an important feature in plant breeding and the breeder can use the artificially induced mutants for further improvement of his cultivars. A methodical work will sooner or later lead to positive results.
Over the years a large collection of morphological and physiological mutations (10,000 different mutant alleles) with a broad variation range have been brought together and have been genetically and agronomically studied. They consist of 10 main categories with 116 different subtypes (Table 1). So far, about half of these mutants have been analyzed genetically in more or less detail, but they form only a minor part of the range of mutant types. This collection forms an outstanding material for investigations within radiobiology, genealogy, gene physiology, ultrastructural research and plant biochemistry, and physiology. It is a major source for future gene mapping and is valuable for molecular genetical analyses of cloned mutant genes. This Swedish collection is unique since all the alleles of the investigated genes are conserved at the Nordic Genetic Resource Center (former Nordic Gene Bank) and available for research and breeding. The mutant groups shown in the table below were studied in detail genetically and with regard to mutagen specificity. These studies have increased our knowledge of the mutation process and the genetic architecture of the different characters. In this presentation a few of these groups are presented in more detail (Table 2) [10, 28–31].
| Table 1. Survey of the main mutant categories |
|-----------------------------------------------|
| 1. Changes in spike and spikelets |
| 2. Changes in culm length and culm composition |
| 3. Changes in growth type |
| 4. Changed kernel development and formation |
| 5. Physiological mutants |
| 6. Awn changes |
| 7. Changes in leaf blades |
| 8. Changed pigmentation |
| 9. Different chlorophyll development |
| 10. Resistance to powdery mildew |
| Table 2. Survey of the genetically investigated Scandinavian mutant groups |
|-----------------------------------------------------------------------------|
| Mutant group | Number of alleles | Number of loci |
|-------------------------------------------------------------------------------|------------------|----------------|
| Praematurum (Early maturity) | 195 | 9 |
| Erectoides | 205 | 26 |
| Breviaristatum (Short awns) | 184 | 19 |
| Eceriferum (Waxless, Glossy) | 1580 | 79 |
| Hexastichon (Six rowed spike) | 65 | 1 |
| Intermedium | 80 | 10 |
| Lemmalike glumes (Macrolepis) | 40 | 1 |
| Third outer glume (Bracteatum) | 10 | 3 |
| Calcaroides | 21 | 5 |
| Anthocyanin mutants | 766 | 31 |
| Liguleless (Auricleless and Exiligulum) | 24 | 2 |
| Albino lemma (Eburatum) | 5 | 1 |
| Orange lemma (Robiginosum) | 7 | 1 |
| Mildew resistance | 77 | several |
| Chlorophyll synthesis and chloroplast development | 357 | 105 |
**Praematurum (early maturity) mutants**
The demand for early cultivars has increased why earliness has become an important goal for Swedish plant breeding. Already in the 1940s, it was found that maturity in barley could easily be changed by X-rays, in either direction of both increased earliness and increased lateness. The time of heading was chosen as a safe character for the selection of induced early mutants, but early heading and early ripening are characters where environmental influences, especially climatic conditions may hamper a safe classification [32].
Over the years, about 1,250 different early maturity mutants have been isolated and studied after various mutagenic treatments. The mutants can be grouped into three categories according to their heading and maturity time with a variation between one and 10 days. Long term studies made it possible to establish nine *mat* loci among 195 localized mutants (Table 3) [10].
| Locus | mat-a | mat-b | mat-c | mat-d | mat-e | mat-f | mat-g | mat-h | mat-i | Total |
|-------|-------|-------|-------|-------|-------|-------|-------|-------|-------|-------|
| Mutants | 85 | 49 | 31 | 2 | 9 | 7 | 4 | 2 | 6 | 195 |
The different loci in general show quite distinct phenotypic characters. The mutations selected for earliness also change other properties of agricultural value. Significantly shorter straw with lower internode number is found in the extreme early mutant loci, *mat-a*, *mat-b* and *mat-c*. Mutants of locus *mat-a* are generally more resistant to lodging than mutants in locus *mat-b*. Among these loci, *Praenaturum* (*mat-a.8*) mutant, a drastic early mutant, heads 8 to 10 days earlier than its mother cultivar ‘Bonus’. It was approved and released as a commercial Swedish cultivar under the name of ‘Marí’ in 1960, and was intended to replace early Swedish six-row cultivars. It was widely grown, as far north as Iceland and it was included in the breeding programme at Cymmit, Mexico [33]. Not until the mid-1960’s it was found that *mat-a.8* had a special property that distinguished it from the ‘Bonus’ parent, namely, a profound change in the photo- and thermoperiod reaction, making it heading and seed fertile also at eight hours of daylight (short-day tolerant). During the 1960’s, large phytotron experiments were carried out in Stockholm under different photoperiod conditions to compare different mutants and cultivars [34–36]. Later, when labour costs got too expensive, a darkening arrangement, using a special plastic tissue, was used in ordinary glasshouses with natural light lasting for eight hours. This type of arrangement was used for many years for identifying short day neutral mutants. It was possible to distinguish three genotype categories under the extreme short day conditions of eight hours of light: (1) genotypes with complete and early heading and good seed set; (2) genotypes with incomplete and late heading and seed set; and (3) genotypes that never headed remaining in a purely vegetative often luxurious stage. The mutants in *mat-c* and *mat-e* loci, are characterized by delayed heading and thus, a less pronounced short-day neutrality. The mutants in all other *mat* loci are long-day adapted like the parent cultivars [37]. Concerning the mutagenic treatments, there is a concentration of short-day adapted mutants under sulfonate treatments whereas the long-day adapted cases seem to accumulate when ethylene imine is applied. Other observations indicate that sodium azide is less efficient in producing day-length neutral mutants.
**Six-row (*hexastichon*) and *intermedium* mutants**
Genetic variability in barley has been of great importance and has long been studied in great detail. The Russian geneticist N.I. Vavilov felt it necessary to explore the total genetic diversity of crop plants throughout the world as well as diversity of related wild species. Barley is one of the oldest cultivated crops [38]. The number of rows of the spikelets is a key character in inferring the origin of barley. For at least 100 years, it has been discussed whether the progenitor of cultivated barley was six-rowed, two-rowed or both. Recently, the two-rowed progenitor hypothesis was supported by archeological specimens showing the existence of domesticated two-rowed remains that were older than six-rowed. The six-row (*hexastichon*) and *intermedium* mutants affect the development of the lateral spikelets with genetic interaction leading to synergistic enhancements. This research has given an insight into rather complex genetics of kernel rows in barley. Normal two-row barley carries, on opposite sides of the spike, central spikelets, with two reduced, sterile lateral spikelets. The two-row barley is able to produce six-row barley in a single mutational step. These mutants have well developed lateral spikelets, fully fertile and with long awns. All the 45 isolated cases have been localized to only one locus, the *hex-v* (*vrs1*), located in the long arm of chromosome 2H [39]. Recently this sixrowed spike 1 (*vrs1*) gene was cloned by the Japanese research group (Komatsuda, *et al.*, 2007). It is indicated that it is a homeodomain-leucine zipper I-class homeobox gene. Expression of the *Vrs1* was strictly localized in the lateral spikelet primordial of immature spikes and suggests that the VRS1 protein suppresses development of lateral spikelets [40].
But two-row barley may also produce mutants with spike development intermediate between the two-row and the six-row states. These mutants have enlarged lateral spikelets with characteristic awn and kernel development, not only among mutants, but also depending on environmental conditions. A total of 126 such *intermedium* mutants have been isolated and 103 of them have been localized to 11 different *int*-gene loci and studied in more detail (Table 4) [41].
| Locus | -a | -b | -c | -d | -e | -f | -h | -i | -k | -l | -m |
|-------|----|----|----|----|----|----|----|----|----|----|----|
| Number | 33 | 3 | 23 | 21 | 14 | 1 | 4 | 1 | 1 | 1 | 1 |
The *hexastichon* (*hex-v*) mutants have six-rowed spikes with fully fertile, well developed, and long-awned lateral spikelets and thus resemble normal six-rowed barley. The *intermedium spike-d* (*Int-d*) mutants produce sterile or partially fertile lateral spikelets with variable awn length which appears intermediate to those of two-rowed barley. Allelism of these mutants showed that these two loci are closely linked to one another on chromosome 2HL and are more or less dominant. Komatsuda, *et al.* (2007) showed that the *Int-d* mutants are the same gene and morphological changes in the mutants can be attributed to changes in the *Vrs1* gene [40]. All other 10 *int* loci are recessive and showed independent inheritance. Both radiation types and most of the used chemical mutagens have been involved but no gene preference to the type of mutagen applied has been found [10].
**Surface wax mutants: *Eceriferum* (*waxless*)**
Presence of wax coating reduces evaporation of water from the plant and helps protect it against pathogens. Most surface wax mutants, the *eceriferum* and *glossy* loci affect the presence and type of epicuticular waxes on the leaf blades and sheaths, culms and spikes. When the wax coating is completely absent, various organs appear as a bright, glossy green color. Cooperation between Swedish and Danish researchers has made this mutant type probably the best known character complex of any cultivated plant. The mutants have been gene localized, their influence on yield studied, electron microscopy and biochemical analyses done, different loci mapped in chromosomes, and their reactions to various climates studied in the phytotron. Phenotypically three different organs of the barley plant were studied in regard to wax coating and composition and led to five phenotypic categories: spike and leaf sheath, spike and leaf sheath partially, spike, leaf blade, and spike, leaf sheath and leaf blade [42, 43]. A total of 1,580 such *eceriferum* mutants have been localized to 79 loci, 78 of them are recessive and one is dominant. Seven types of mutagenic treatments have been applied. It is obvious that different loci show markedly differing mutagen specific reactions. (1) There are particularly large mutagenic differences between chemicals and ionizing radiation, especially neutrons; (2) No significant differences among various kinds of organic chemicals can be established; (3) There are significant differences between organic chemicals and sodium azide; (4) The combined treatment (sulfonate + X- or γ-rays) does not differ from treatment with sulfonates alone, but differs from the treatment with exclusively X-rays. No difference to sodium azide can be demonstrated; (5) Sodium azide differs strongly from X-rays and still more from neutrons; (6) There are clear differences between the two kinds of treatments with ionizing radiation; sparsely ionizing X-rays and densely ionizing neutrons having different effects on the target DNA molecule. In summary, the wealth of alleles distributed on a large number of cer loci has provided important insights into the mutation process. Obviously, different gene loci have different mutabilities. It is equally obvious that different loci show markedly differing mutagen specific reactions. These insights into the mutation process combined with knowledge of the localization of the different genes in the genome will add to our understanding of the mechanisms of mutagenesis and the organization of the eukaryotic genome [10, 44].
**Dense spike mutants**
The dense spike (erectoides) mutants were the first of the viable mutants induced by irradiation and the most commonly induced morphological changes. They are characterized by compact, dense spikes, implying that the spike rachis internodes are shorter than in the mother strain. They generally possess a very stiff and often short straw. The first uppermost internode of the culm is generally longer than in the mother cultivar and the basal ones being shorter. In all, about 1,270 such mutants have been isolated and studied intensively. Twenty-six gene loci could be established among 205 investigated mutants. Most of the loci have distinct phenotypic characteristics, one of them is dominant and all the others recessive. Several loci have been mapped spread over the seven barley chromosomes. Differences in the mutation spectrum could be noticed. Three of these loci could be identified as mutagen specific, where more than 80, 70% and 50%, respectively, of the alleles were induced by irradiation [45-48]. Most of these erectoides mutants are fully viable and promising from a practical point of view. The most outstanding of these mutants is erectoides 32 in locus ert-k that became released as a new cultivar ‘Pallas’ in 1958 [49].
**Breeding aspects**
Since work with artificial induction of mutations began, it was evident that mutation programmes should be regularly included in breeding programmes of crop plants. The application of mutation research in plant breeding was the most important stimulus. It was shown already in the 1950s and 1960s that the work at Svalöf can be used as an example how mutation breeding can be employed in a crop improvement programme. The main interest was focused on macromutations [50]. Both simple and rather complex characters such as straw-stiffness, earliness, higher yields, protein content and disease resistance are of interest. Not only new direct mutants, but also the indirect use of induced mutations was applied. In the latter case breeding work tried to change modifying systems by crossing mutants with various established cultivars and selecting the best recombinants homozygous for the mutations. In the Swedish programme, this use of macromutations in conventional cross-breeding programmes has proved to be more successful than recurrent mutagenic treatments [51].
Through the joint work with barley breeders and other scientists at Svalöf, a rather large number of mutant cultivars of two-row barley were registered as originals and commercially released. Two of these cultivars Pallas, a straw-stiff, lodging resistant and high-yielding erectoides mutant, and Mari, an extremely early, photo- and thermo-insensitive mutant, were produced directly by X-irradiation. All other cultivars derive from crosses and backcrosses, where the original breeding material was based on three primary high-yielding Swedish X-ray mutant cultivars: Pallas, Sv 44/3, both extreme lodging resistant, and Mari, extremely early. A series of cultivars obtained after crossing, (Table 5) were tested and found to be agriculturally suitable to various parts of Scandinavia and other parts of the world. The aim of this work was to demonstrate that original mutant materials can be used successfully in recombined breeding programme in the hands of skilful breeders. It has set a positive trend, in fact, as positive and progressive as any other method of plant breeding [52]. Today, with modern technology, different methods ought to be used together, adding to the results of ordinary crossing and selection.
Useful mutations in barley include a wide range of economically important characters that influence morphological as well as the physiological and biochemical properties. The use of the mutation method is of importance in providing a detailed understanding of the genetic composition of the barley genome, especially if combined with detailed chromosomal and genetic analyses of linkage and biochemical studies of the DNA constitution and the amino acid composition.
| Table 5. Survey of induced barley mutants and their derivates, approved and released at Svalöf (after Gustafsson, 1986) |
|---------------------------------------------------------------|
| **Parent strains** | **Derivates** |
| 'Gull' | (1) Primary mutant varieties |
| 'Bonus' | 44/3: extremely lodging resistant |
| 'Pallas' (ert-k.32) approved 1958 |
| 'Mari' (mat-a.8) approved 1960 |
| **Mutant crosses** | (2) Varieties approved |
| Herta x Pallas | 'Hellias', approved 1967 |
| Domen x Mari | 'Kristina', approved 1969 |
| Mari x Monte Cristo | 'Mona', approved 1970 |
| Birgitta x Mari | 'Eva' and 'Salve', approved 1973 and 1974 respectively |
| 44/3 x Birgitta | 'Gunilla', approved 1970 |
| (Birgitta x Mari) x Gunilla | 'Pernilla', approved 1979 |
| **Complex mutant crosses** | (3) Varieties approved |
| (Pallas x Triple awn lemma) x Pallas<sup>cv</sup> | 'Visir', approved 1970 |
| (Triple awn lemma x Pallas<sup>cv</sup>) x Hellas | 'Senat', approved 1974 |
| Å 61657 x (Mari<sup>cv</sup> x Triple awn lemma) | 'Troja', but withdrawn 1981 |
| Kristina x (Hellas<sup>cv</sup> x (Pallas<sup>cv</sup> x Rupee)) | 'Jenny', approved 1980 |
| Lofa x (Å 6564 x (Mari<sup>cv</sup> x Mutan)) | 'Lina', approved 1982 |
In conclusion, Å. Gustafsson’s words from his last paper in 1986 [53] are summarized as follows: “Induced mutations in the hands of skilful breeders will be an important future tool in progressive plant breeding. This will be even more so when the chemistry of the gene has been studied more thoroughly. Genetic instruments of artificial selection will increase the power and capacity of the plant breeder. It seems rather strange that also today there is a certain negative attitude towards the use of mutations in plant breeding or in most experiments concerning the general evolutionary theory. Such negative ideas are often associated with the view that mutationists ignore the natural sources of genetic variability and oppose the breeding value of primitive biotype collections.”
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The Induced *sd1* Mutant and Other Useful Mutant Genes in Modern Rice Varieties
J N Rutger
**Abstract**
Induced mutation was accelerated in the USA with the release in California in 1976 of Calrose 76, the nation’s first semidwarf table rice variety. Success was due not only to induction of mutants but also to their evaluation and integration into cross-breeding programmes. Thus the evaluation of Calrose 76 showed that its *sd1* gene was allelic to *sd1* in the indica Green Revolution varieties DGWG, TN(1) and IR8, and that semidwarfism conferred a yield advantage of 14% over the 6mt/ha yield level of the tall japonicas. Immediate integration of the Calrose 76 source of semidwarfism into cross-breeding has resulted in 25 semidwarf varieties that trace their ancestral source of semidwarfism to Calrose 76: 13 in California, 10 in Australia, and 2 in Egypt. Calrose 76 ancestry also appears in the pedigrees of numerous additional California cultivars derived from crossing the Calrose 76 source with the IR8 source of semidwarfism. In the late 1990s 12 semidwarf mutants were induced in tall tropical japonica varieties at the Dale Bumpers National Rice Research Center in Arkansas. The semidwarfing gene in each of these 12 germplasms was found to be nonallelic to *sd1*. Although selected for productivity, none of the 12 consistently showed yield increases typical of *sd1* sources. The *sd1* source, whether from induced mutation or from the indica source, is truly associated with enhanced productivity. Other induced mutants were found for early flowering, low phytic acid, giant embryo, and marker genes such as gold leaf and extreme dwarfism. The early flowering mutants were recovered in temperate japonicas, in tropical japonicas, and most recently in indicas. The early flowering indica mutants are quite interesting since they provide high-yielding or blast disease-resistant indica germplasm which will mature in the USA.
**Introduction**
The author’s experiences with induced mutation for rice improvement have had two parts: First, from 1970-1988 as a Research Geneticist with the U. S. Department of Agriculture, Agricultural Research Service (USDA-ARS) at Davis, California, working on temperate japonica rice; and second, from 1993-2005 as Director of the USDA-ARS Dale Bumpers National Rice Research Center (DB NRRC) at Stuttgart, Arkansas, working on tropical japonica and on indica rice. Following a final period as Chief Scientist at the DB NRRC the author retired in January 2007 and moved back to California. Throughout his career the author has concentrated on selecting agronomically useful mutants such as semidwarfism and early flowering, with occasional detours into male steriles and marker genes as genetic tools. Keys to the success of the work have been, first the induction of mutants in very good varietal backgrounds, second their evaluation both agronomically and genetically, and third, immediate integration into conventional cross-breeding programmes by rice breeding colleagues.
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Retired Chief Scientist, Dale Bumpers National Rice Research Center, Stuttgart, Arkansas 72160 USA; 1989 Witham Drive, Woodland, California 95776 USA.
E-mail: firstname.lastname@example.org
**Figure 1** The induced mutant Calrose 76, released in 1976, was the first semidwarf table rice variety in the USA. It was about 25% shorter than its parent and the closely related tall check variety CS-M3 [7]
**Figure 2** Averaged over nitrogen fertilizer rates from 60 to 180 lb/acre (67 to 202 kg/ha), the two semidwarf varieties Calrose 76 and M7 yielded 14% more grain and 13% less straw than the tall cultivar CS-M3 [2]
**Temperate japonicas**
Induced mutation work in the early 1970s resulted in the induction and direct release of Calrose 76, the first semidwarf table rice variety in the United States [1]. The work was a cooperative effort involving an IAEA-sponsored visiting scientist from Taiwan, Dr. Chao-hwa Hu, several
University of California Scientists, and the author. Following the induction of the semidwarf mutant, it was evaluated in yield trials where it was shown to be about 25% shorter than its parent and the closely related tall check variety CS-M3 (Fig. 1), and to produce 14% more grain and 13% less straw than the tall check (Fig. 2) [2]. Genetic evaluation showed that the semidwarfing gene in Calrose 76 was allelic to sd1 from DGWG [3]. However, the greatest application of Calrose 76 was its integration into cross-breeding efforts. For example, the semidwarf, early maturing variety M-101 [4] was developed from the pedigree CS-M3/Calrose76/D31, where D31, another mutant from Calrose [5], contributed early maturity. The most popular Calrose 76 derivative semidwarf was M7, from the cross Calrose 76/CS-M3 [6]. Altogether, Calrose 76, usually through the derivative glabrous leaf variety M7, has served as the ancestral source of semidwarfism for numerous varieties: 13 in California (Table 1), 2 in Egypt [18], and 10 in Australia (R. Reinke, Rice Breeder, Yanco Agricultural Institute, personal communication, December 21, 2005).
| Variety | Year | Pedigree | Reference |
|------------------|------|-----------------------------------------------|-----------|
| Calrose 76 | 1976 | Induced mutant of Calrose | [1] |
| M7 | 1978 | Calrose 76/CS-M3 | [6] |
| M-101 | 1979 | CS-M3/Calrose 76/D31 | [4] |
| M-301 | 1980 | Calrose 76/CS-M3/M5 | [8] |
| S-201 | 1980 | Calrose 76/CS-M3/S6 | [9] |
| M-302 | 1981 | Calrose 76/CS-M3/M5 | [10] |
| Calmochi-101 | 1985 | Tatsumimochi//M7/S6 | [11] |
| S-101 | 1988 | 70-6526/R26/Toyohikari/3/M7/74-Y-89/SD7/73-221 | [12] |
| M-103 | 1989 | 78-D-18347/M-302 | [13] |
| S-301 | 1990 | SD7/730221/M7P-1/3/M7P-5 | [14] |
| S-102 | 1996 | Calpearl/Calmochi-101/Calpearl | [15] |
| Cahikari-201 | 1999 | Koshihikari/(Koshihikari/S-101)*2 | [16] |
| Calamylow-201 | 2006 | Induced low amylose mutant of Cahikari-201 | [17] |
Calrose 76 ancestry also appears in the pedigrees of many additional California varieties resulting from crosses between the Calrose 76 source and the indica sources IR8 or DGWG (K.S. McKenzie, Director of California Cooperative Rice Research Foundation (CCRRF), (personal communication, August 22, 2005). Molecular technology now makes it possible to determine exactly which parent contributed the semidwarf allele gene in such semidwarf x semidwarf crosses. For example, the most successful variety in California for the last two decades, M-202 [19], derived from crossing the Calrose 76 source with the IR8 source, was recently shown to carry sd1 from IR8, while S-101, another variety resulting from crossing the two sources, carries sd1 from Calrose 76 (T. H. Tai, Rice Geneticist, Davis, California, personal communication, October 17, 2006). Another recent report confirms that M-202 carries sd1 from IR8 rather than from Calrose 76 [20].
A measure of how extensively the CCRRF rice breeders have used mutants in their programme can be gleaned from perusal of their 26 mutant or mutant-derived varieties in the mvgs.iaea.org database [21]. As well as using the ancestral Calrose 76 sd1 source of semidwarfism in cross-breeding the CCRRF has made direct releases of four independent mutant varieties:
- Calmochi-201, a waxy endosperm mutant of the variety S6 [22].
- M-401, a semidwarf mutant of the premium grain variety Terso [23].
- M-203, an early maturity mutant of M-401 [24].
- Calamylow-201, a speciality low amylose (about 6%) mutant of Calihikari-201 [17]. Calamylow-201 thus has two mutant genes, sd1 from its Calihikari-201 parent, and the newly induced gene for low amylose.
The CCRRF also has developed aromatic varieties through use of basmati semidwarf mutants [25]:
- A-201, includes a basmati semidwarf, PI457920, in its parentage [26]
- Calmati-201, includes another basmati semidwarf, PI457918, in its parentage [27]
- Calmati-202, another basmati semidwarf, with A-201 as a parent (K.S. McKenzie, Director of California Cooperative Rice Research Foundation, personal communication, June 1, 2008).
**Tropical japonicas**
Upon becoming Director of the DB NRRC in Arkansas in 1993, the author launched a programme to induce semidwarf mutants in Arkansas tall, tropical japonica, varieties, since at that time no semidwarf varieties had been released in Arkansas. Inheritance studies showed that each of the 12 mutants induced had a recessive gene for semidwarfism [28, 29, 30]. When crossed with a known source of the Calrose 76 semidwarfing gene, each of the new semidwarfs was found to be nonallelic to sd1. Intercrosses among the 12 sources were not done, so it not known how many separate genes were involved. Each semidwarf was selected to be competitive with its tall parent, but none consistently exceeded the yield of its parent, as had been the case with sd1 in California. Although not useful for direct release as mutant varieties, the 12 new semidwarfs were released as improved germplasm to interested breeders and other scientists.
Other tropical japonica mutants induced during the Arkansas period included: the KBNT ipa 1-1 low phytic acid mutant, with a 45% reduction in phytic acid [31]; the LGRU ef early flowering mutant [32]; and two dominant and one recessive genetic male sterile mutants [33]. The low phytic acid mutant also was crossed to a related variety carrying the goldhull (gh) gene to produce goldhull low phytic acid germplasm (GLPA) that could be identified by its goldhull marker gene in the field, in the farm truck, and in the grain elevator [34].
**Indicas**
By the mid-1990s, it was well established that indica germplasm, if sufficiently early in maturity, significantly outyielded the tropical japonicas in the southern USA [35]. Therefore the author began crossing a very early, bold grain, variety from China, Zhe 733, with six improved indica germplasms from IRRI, resulting in the release of nine indica germplasms, indica-1 to indica-9, with yield and maturity similar to southern varieties and grain quality approaching USA long grain standards [36]. Grain quality of the IRRI parents was almost identical to USA long grains, but the IRRI parents were about a month too late in maturity for USA environments. Therefore a programme was initiated to induce early maturity in the IRRI indicas, resulting in the release of six early flowering germplasms, indica-10 to indica-15 [37, 38]. Typical of these was indica-12, which was 28 days earlier than its indica parent, making it almost as early as local tropical japonica varieties (Fig. 3). Another indica of interest was the famous blast resistant variety from Colombia, Oryzica llanos 5, which also was a month too late for Arkansas. Therefore, early maturity mutants were induced in this variety, resulting in the release of three improved germplasms, indica-16 to indica-18, which were 24 to 36 days earlier than the parent and retained its blast resistance [39].
Other indica mutants induced during the Arkansas years included: the Guichao 2 eui mutant [40], which is allelic to the temperate japonica eui mutant found in California some 24 years earlier [41]; four indica genetic stocks, for apoptosis, narrow leaf, extreme dwarf, and gold leaf [42]; and four more genetic stocks, including: the long grain giant embryo mutant GSOR 25; a population segregating for albinos, GSOR 26, for elementary school teaching demonstrations; and two double-dwarf mutants, GSOR 27 and 28, which are 15 to 20cm shorter than their respective single-dwarf parents [43].
A japonica/indica mapping population of 353 F10/11 lines was produced by crossing the japonica KBNT ipa 1-1 mutant with the indica variety Zhe 733 [44]. This material, designated the K/Z mapping population, has been placed in the GSOR [43] collection at the DB NRRRC, where it has become an often-requested population by geneticists and other scientists.
While in Arkansas the author also participated in an IAEA programme on Multi-location yield trials of rice mutants in 6 countries in the Latin American region: Brazil, Colombia, Costa Rica, Cuba, Guatemala and Uruguay. In this programme eight mutant lines were identified as potentially suitable for cultivation in cooperating countries and were incorporated into national rice trials [45]. In addition, desirable mutated characteristics were found which could be transferred through crossing programmes: earliness, salinity tolerance, blast resistance, resistance to shattering, translucent grain, high milling yield, plant height, and high yield potential.
Another achievement in Arkansas was the development of *aromatic* se germplasm as a semidwarf (s), early maturing (e) recombinant from the cross between a late maturing semidwarf mutant, DM 107-4, and the early maturing tall variety Kashmir Basmati [46]. Both of the parents were induced mutants of Basmati 370, developed by M. A. Awan in Pakistan [25]. Although *aromatic* se retains the aroma and cooking quality of the original basmati source, yield has been low relative to conventional Arkansas varieties [46]. Efforts to develop additional aromatic varieties through induction and inter-crossing of mutants are underway.
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Induced Mutations in Plant Breeding and Biological Researches in Japan
H Nakagawa
Abstract
Two hundred and forty two direct-use mutant varieties generated by using irradiation, chemical mutagenesis and somaclonal variations, have been registered in Japan. About 61% of these were induced by Gamma-ray irradiation, largely due to successful collaboration with the Institute of Radiation Breeding. This high percentage of Gamma-ray irradiated mutants indicates that mutation breeding via Gamma-ray irradiation is an effective and highly successful approach for the generation of commercial cultivars. Some mutant cultivars of Japanese pear exhibiting resistance to diseases induced by Gamma-ray irradiation and development of a unique bioassay by using toxins of fungi was discussed. In addition, 228 indirect-use (hybrid) mutant varieties primarily generated in rice and soybean have found value as parental breeding germplasm resources in Japan. In 2005, two direct-use cultivars and 97 indirect-use cultivars of rice contributed approximately 12.4% of the total area of rice cultivation in Japan. The semi-dwarf gene (sd-1) generated in rice is perhaps one of the most significant contributions. For soybean, similar Gamma-ray induced mutants comprised nearly 9.4% of the total cultivation area of soybean in Japan. Molecular genetic studies focused on genome sequencing have become an extremely powerful tool for identifying the genes and for selecting mutants exhibiting specific phenotypes. It is anticipated that molecular genetic interaction will complement gains in mutation breeding on a dramatic scale. Chronic irradiation in the Gamma Field is also considered to be a useful tool for generating mutant resources for future molecular studies especially in rice, and expand its use into the other graminaceous crops which have genomic synteny to rice. There are interesting reports concerning mutations in rice, such as low glutenin content, in which the size and location of deletions and the mechanisms and phenotypes of low glutenin content were elucidated. Chronic irradiation in the Gamma Field is useful to generate mutant resources for molecular researches.
Introduction
After the construction of the Gamma Field, now considered the world’s largest radiation field (Fig. 1, 100m radius with an 88.8 TBq $^{60}$Co source at the center), the Gamma Room and the Gamma Greenhouse in the Institute of Radiation Breeding (IRB) in 1960’s, mutation breeding was accelerated by cooperative research with national and prefectural breeding laboratories, private companies and universities in Japan [1].
In *The New York Times* (*In “Useful Mutants, Bred With Radiation”* by William J. Broad, August 27, 2007), Dr. P. J. L. Lagoda of the Joint FAO/IAEA was quoted to say, “Spontaneous mutations are the motor of evolution. We are mimicking nature in this. We’re concentrating time and space for the breeder so he can do the job in his lifetime. We concentrate on how often mutants appear - going through 10,000 to one million - to select just the right one.”
The concept and objectives of the IRB’s Gamma Field has the same goals for the plant breeder. The facility is used to artificially induce mutations at a higher frequency than it occurs in nature. The radiation dose at the nearest point of the field (10m from the center, ca. 2Gy/day) is estimated to be about 300,000 times that of normal and natural background radiation. At the farthest point (100m from the center, ca. 0.01Gy /day), the radiation dosage is about 2,000 times that of normal background radiation. This means that growing plants at the nearest point to the Gamma-ray sources are being treated to a 1,000 year’s of accumulated normal background rates of radiation per day. Although we do not know all the genes or mechanism of mutations, radiation breeding has produced many useful mutant cultivars and contributed greatly to the farmers and industries of Japan.
In 1991, the Ministry of Agriculture, Forestry and Fisheries (MAFF) of Japan launched the Rice Genome Research Programme (RGP), with the aim of fully decoding the rice genome in three phases over a 21-year period. With the cooperation of 10 participating countries [2], the genome sequencing of 12 rice chromosomes was completed in 2005 [3]. Following this achievement, molecular genetic studies based on the results of the genome sequencing project became the most powerful tool for selecting mutants of certain characteristics in rice. This is anticipated to revolutionize mutation breeding success in rice, and become applicable to a number of other important crop species.
In this report, the mutant cultivars developed mainly by Gamma-rays are discussed. In addition, their economic impacts in Japan, as well as molecular studies performed to elucidate the mutation at the DNA level are described.
Mutation breeding and released cultivars in Japan
In a 2007 search regarding the number of induced mutation varieties in the IAEA database, China is first in the number of described induced
mutation varieties at 638; India is second listing 272 varieties; and Japan is third with 233 varieties. The total number of mutant cultivars, including direct-use mutant cultivars and indirect-use cultivars, exceed these totals. A selection of mutant cultivars developed in Japan, including the economic impact of these cultivars, and their characteristics are reviewed here.
The number of cultivars developed by mutation breeding
Figure 2 shows the number of direct-use and indirect-use (hybrid) mutant cultivars registered in Japan in each five-year period from 1960 to 2005. The number of direct-use cultivars had been rapidly increasing until 1995, when 67 cultivars were registered in five years (about 13 cultivars per year). This number fell from 2001 to 2005, with only 41 cultivars being registered (about 8 cultivars per year). The number of indirect-use cultivars primarily generated in rice has steadily increased over time and 68 cultivars were registered from 2001 to 2005. This number can be increased if agronomically useful, direct-use cultivars, such as “Reimei” with the *sd1* dwarf gene for rice are developed.
Two hundred and forty two direct-use mutant cultivars comprising 61 species generated through irradiation utilizing Gamma-ray, X-ray and ion beams, chemical mutagenesis and *in vitro* culture (somaclonal variation), have been registered and released in Japan (Fig. 3). More than 61% of these were induced by Gamma-ray irradiation and those induced by somaclonal variation and chemical mutagen, not including those with double chromosome numbers through colchicine treatment, are 15.7% and 6.6%, respectively. Recently, the development of mutant flower cultivars, generated by ion beam irradiation, has been a growing area of mutation induction in Japan.
Table 1 shows the number of registered mutant cultivars of some crops developed by radiation, Gamma-rays, and those irradiated at the IRB, NIAS [4]. There are 50 mutant cultivars of chrysanthemum, 31 of rice, 16 of soybean, 10 of rose, etc. Among them, 100 cultivars have been generated at the IRB and these contributions of the IRB regarding the development and release of superior mutant induced cultivars has been extensive. This high percentage of Gamma-ray irradiated mutants indicates that mutation breeding via Gamma-ray irradiation is an effective and highly successful approach for the generation of commercial cultivars.
The first mutant rice cultivar is “Reimei,” which means “dawn” in Japanese, was the first irradiation induced mutant cultivar that illustrated the potential of utilizing Gamma-rays for breeding improvements in Japan. Reduction of plant height, including dwarfism and semi-dwarfism is one of the characteristics that can be induced with high frequency by irradiation and can be easily detected in the field. “Reimei,” registered in 1966 [5] was a successful case of an irradiation induced semi-dwarf mutant. This cultivar exhibits a mutation of the *sd1* locus [6] and shows a culm 15cm shorter than the original cultivar “Fujimiori.” The semi-dwarf is associated with the high-yielding ability and recorded the highest yield in Japan in 1967 [5].
| Table 1. Number of registered mutant cultivars developed by radiation, Gamma-rays, and those irradiated in the Institute of Radiation Breeding, NIAS [4] |
|---------------------------------|-----------------|-----------------|-----------------|-----------------|
| Mutant cultivars¹ | Radiation | Gamma-rays | IRB² |
| 61 Crops | 242 | 188 | 146 | 100 |
| Rice | 31 | 14 | 12 | 11 |
| Wheat | 4 | 2 | 2 | 0 |
| Barley | 4 | 4 | 3 | 0 |
| Soybean | 16 | 16 | 15 | 9 |
| Chrysanthemum | 50 | 46 | 32 | 29 |
| Rose | 10 | 7 | 7 | 6 |
| Sea pink (Limonium) | 6 | 6 | 6 | 0 |
| Cytisus | 8 | 8 | 8 | 8 |
| Apple | 2 | 2 | 2 | 2 |
| Japanese Pear | 3 | 3 | 3 | 3 |
| Others | 108 | 80 | 56 | 32 |
¹ Total number of mutant cultivars developed by radiation (Gamma-ray, X-ray and ion beams), chemicals (Excluding colchicine treatment), somaclonal variation
² Number of mutant cultivars irradiated in the Institute of Radiation Breeding (IRB)
Table 2. Number of indirect use mutant cultivars in Japan (2008)
| Rice | Wheat | Barley | Soybean | Tomato | Others | Total |
|------|-------|--------|---------|--------|--------|-------|
| 198 | 3 | 7 | 9 | 3 | 7 | 228 |
In Japan, the total number of indirect-use mutant cultivars is 228, which includes 198 rice, 9 soybean, 7 barley, 3 wheat, 3 tomato, 4 lettuce, 1 eggplant, 1 Japanese lawnglass, 1 mat rush, and 1 mushroom cultivar in 2008 (Table 2). Interestingly, among the 198 indirect-use mutant cultivars in 2008, 89 cultivars (44.9%) were derived from the “Reimei” or its offspring. This suggests that agronomically useful mutations can be utilized as parental lines to develop new varieties with this characteristic and transferred efficiently to the farmers’ field.
The Economic impact of mutant cultivars in Japan
Figure 4 shows the increase of mutant rice cultivars, which were derived from mutants generated by Gamma-rays, planted in farmers’ fields in Japan since 1960. “Reimei” was first cultivated on 61,598 ha in 1968,
(http://ineweb.narcc.afrc.go.jp/). The number of mutant cultivars has been increasing and 99 mutant cultivars (2 direct-use and 97 indirect-use cultivars) were in cultivation in 2005 [4].
**Figure 4** Total number of mutant rice cultivars, which are derived from mutants generated by Gamma-rays, cultivated in farmers’ field from 1960 to 2005 in Japan [4].
**Figure 5** Total areas of mutant rice cultivars, which are derived from mutants generated by Gamma-rays, cultivated in farmers’ field from 1960 to 2005 in Japan [4].
**Figure 5** shows the total cultivated field of the mutant cultivars, which are derived from mutants generated by Gamma-rays, from 1961 to 2005. This increased after “Reimei” was released for cultivation in 1968. The peak use of mutant induced cultivars reached 250,000 ha in 1986 and was slightly more than 200,000 ha from 1994 to 2005. In 2005, the total cultivated area of mutant cultivars was 210,692 ha, which is 12.4% of total cultivated area of paddy rice (1,702,000 ha) in Japan [4].
The total crude income of farmers selling the brown rice of mutant cultivars also has been increasing as the increase of the cultivated area, although the price of the grain is different in each year. The amount of total income is estimated to be approximately 250 billion Yen (2.34 billion US dollars) in 2005 [4]). The mutant cultivars, which are derived from mutants generated by Gamma-rays and have been cultivated on more than 5,000 ha from 2001 to 2005, are the following 17 cultivars, “Kinuhikari (263,223ha)”; “Haenuki (219,734ha)”; “Tsugaru-roman (106,423ha)”; “Yume-akari (66,491ha)”; “Yume-tsukushi (58,893ha)”; “Aichi-no-kaoi (53,697ha)”; “Asahi-no-yume (51,049ha)”; “Mutsuhomare (46,959 ha)”; “Dontokoi (17,008ha)”; “Yume-shizuku (14,076ha)”; “Mine-asahi (10,698 ha)”; “Yume-hitachi (10,440ha)”; “Yume-minori (9,957ha)”; Aki-geshiki (7,510ha)”; “Aki-roman (7,450ha)”; “Miyama-nishiki (7,242 ha)”; and “Tsukushi-roman (5,533 ha).” The mutant cultivars, which have been cultivated in more than 100000ha of farmers’ fields are the following 5 cultivars, “Akhikari (1,410,810ha)”; “Reimei (886,188ha)”; “Kinuhikari (263,223ha)”; Haenuki (219,734ha); and “Tsugaru-roman (106,423ha).” Among them, “Reimei” is a direct-use mutation cultivar and the others are indirect-use cultivars [4].
There are 16 direct-use mutant cultivars of soybean registered in Japan since “Raiden” and “Raikou” were developed by Gamma-ray irradiation in 1960. The improved characteristics were early-maturity and late-maturity, yellow hilum, seed-coat color, short-stem, and the number of pods/stem, lipoxygenase-free, low allergen etc. Among them, one cultivar was induced by X-ray and the other 15 were induced by Gamma-rays. The number of indirect-use cultivars is 10. The total cultivated area of mutant cultivars cultivated in the farmers’ fields came to 13,283 ha (9.4% of total cultivated area (142,000ha) of soybean in Japan in 2005) and total farmers’ crude income was 5.56 billion Yen (ca. 52 million US dollars) [4]. As a result, economic impact of mutant cultivars is huge in Japan.
Some useful mutant varieties by using various screening methods
**Rice**
Although rice is not a high protein grain crop, the protein content is ca. 7% when the white rice is cooked. A mutant line with a low content of glutelin was obtained from the ethyleneimine (EI) treatment to “Nihonmasari.” The “LGC-1” was developed from back-crossing this mutant with the original “Nihonmasari” to eliminate undesirable characteristics, such as semi-sterility and semi-dwarfism [7]. The seed protein of the “LGC-1” is composed of mainly of a low amount of digestible glutelin and high amount of indigestible prolamine. This construction of protein is disadvantageous for the digestion of rice grains in humans, though the total amount of protein is mostly similar to the original cultivar. As a result, the “LGC-1” is useful as “low protein rice,” and some clinical trials on patients with kidney disease indicate that the variety is a useful and effective daily food for such patients [8]. The defect of the “LGC-1” is its eating quality, and there are the other loci that control the biosynthesis of digestible protein, such as globulin. Therefore, Nishimura, et al. [9] induced a mutant named “89WPKG30-433” with a deficiency in globulin from the leading Japanese cultivar “Koshihikari” through Gamma-ray irradiation. They hybridized it with the “LGC-1” and selected “LGC-Katsu” and “LGC-Jun” from the hybrids, whose globulin content was as low as the “LGC-1,” where the globulin content is zero. The total digestible protein content tested to about 30% of ordinary rice. As the eating quality is highly improved and digestible protein content is lower than “LGC-1,” these two cultivars will greatly help in the dietary management of proteins with chronic renal failure.
**Soybean**
Takagi [10] identified two major genes, which control radio-sensitivity, in some soybean varieties. When the 50% reduction rate (RD$_{50}$) of root length was determined with acute irradiation to the seeds or the chronic irradiation to the plants for the entire growth period, radio-sensitivity of a sensitive cultivar, “Shimejirio,” is more than twice that of the resistant variety, “Tachisuzunari.” The differences in radio-sensitivity between the varieties to the chronic irradiation in the Gamma Field were controlled by a single recessive gene, $rs1$. Besides, the second recessive gene $rs2$, which was discovered in “Goishishirobana,” whose activity is only expressed following acute seed radiation.
**Figure 6** Metabolic pathway and key genes of fatty acid in soybean [13] (courtesy of Prof. Y. Takagi).
Soybean is the most widely used source of edible oil for human consumption. Fatty acids of soybean seeds consist of palmitic acid, stearic acid, oleic acid, linoleic acid, and linolenic acid (Fig. 6). Altered unsaturated fatty acid content (elevated oleic acid and reduced linolenic acid) increase the oxidative stability that provides health benefits and improvement of fatty acid contents. This has been one of the most important breeding objectives of soybean. As natural genetic diversity in soybean is limited, mutation induction is one effective approach to induce modification. Through the use of X-rays or chemical mutagens, mutants with different fatty acid compositions, such as reduced and elevated palmitic acid, elevated stearic acid, elevated oleic acid (50%), and reduced linolenic acid (3%) content were isolated and found to be controlled by major genes (Fig. 6; [11-13]).
Soybean seed has three lipoxygenases called $L$-$1$, $L$-$2$ and $L$-$3$, respectively [14]. The lipoxygenases are the main factors of the grassy-beany flavor of the products. Soybean lines lacking each of the three genes have been developed. However, no line lacking all three genes has been obtained because of tight linkage between $L$-$1$ and $L$-$2$ [15]. The F$_2$ seeds derived from a cross between a line without $L$-$1$, $L$-$3$ and a line without $L$-$2$, $L$-$3$ were irradiated with Gamma-rays. After surveying 1,813 M3 seeds by using SDS/PAGE, one mutant seed lacking all $L$-$1$, $L$-$2$, and $L$-$3$ was selected [16]. A new cultivar “Ichihime” with this unique characteristic was registered and released in 1994 [17].
**Italian ryegrass**
Mutation breeding has been mainly established in seed propagated, self-pollinated species. Although several methods have been widely used for the screening of mutants in self-pollinated species by the single-seed descent approach [18,19] and by single seed descent (one-plant-one-grain method, Yoshida [20]), these methods have not been applied to cross-pollinated species. Ukai [21] developed a new method for obtaining mutants of cross-pollinated species efficiently in a temperate forage grass, Italian ryegrass (*Lolium multiflorum* L.). The method was called the “Crossing-within-Spike-Progenies Method.” This method is composed of 1) taking seeds separately from each spike from a population of plants irradiated with Gamma-rays, 2) sowing the seeds in a hill plot as a spike-progeny, 3) isolating each hill from others at the time of flowering and allowing the open-pollination of plants within hills, and 4) taking seeds from each of the hills and sowing the seeds in hill progenies for the screening of mutants. This procedure is repeated each year. When 300Gy of Gamma-ray was irradiated to the seed, the frequency of chlorophyll mutations was approximately 70.6% per hill progeny and 1.87% per plant. In contrast, open-pollinated populations exhibited that only 10% per progeny and 0.12% per plant, respectively. This method will be applied to the other wind- or insect-pollinating outcrossing crop species.
**Chrysanthemum**
In general, it is very difficult to isolate mutants from mutation sectors in vegetatively propagated crops although the maintenance of mutant genotypes is easier than the seed-propagated species. It has been shown that the combined method of chronic Gamma-ray irradiation and tissue culture is very effective in solving this problem. By tissue culturing the floral organs of chrysanthemum (*Chrysanthemum morifolium* Ramat.) plants chronically irradiated in the Gamma Field from the seedling to the flowering stages, many non-chimeric mutants, with various flower colors and shapes, are obtained [22]. From these mutant lines, 10 cultivars were registered. The technology, given the term “radiobiotechnology,” is not only effective in obtaining non-chimeric mutants but also effective in producing high mutation frequencies. The method has been utilized to induce mutations in various vegetatively propagated crops and many mutant cultivars have been registered.
**Japanese pear and apple resistant to *Alternaria* disease**
A popular cultivar of Japanese pear (*Pyrus serotina* Rehd. var. *culta* Rehd.), “Nijisseiki,” which was a leading variety, occupied 28% of the total cultivated area of Japanese pear in 1990 in Japan. The cultivar, however, is highly susceptible to the black spot disease, *Alternaria alternata* (Fr.) Keissier (= *Alternaria kikuchiana* Tanaka), one of the most serious diseases of pear [23]. Growers are required to spray fungicides several times during the growing season to counter the disease. To induce mutations resistant to the disease by Gamma-ray irradiation, small plants of the cv. “Nijisseiki” were planted at every 4 meters from 37 m to 63 m from the $^{60}$Co source in 1962 and chronic Gamma-ray irradiation was applied (30 x 10-2Gy - 4 x 10-2Gy /day) in the Gamma Field [24]. In 1981, nearly 20 years after the planting, a twig without the symptom of the disease was found in a plant planted at a distance of 53 m from the irradiation source. As it was ascertained that there was no difference in other agronomic characteristics between the mutant and the original variety except for the resistance to the black spot disease, it was registered and released in 1991 with the name “Gold Nijisseiki”[24]. It was registered as the same name in Australia in 2004 (Certificate Number 2533).
Dr. Sanada, one of the breeders of this cultivar, mentioned, “The situation of mutation breeding on fruit trees has been severely criticized because there have been no successful results.” Although it took them nearly 20 years to identify a useful mutation and 30 years for the registration, the release of “Gold Nijisseiki” is a monumental achievement for the Gamma Field.
**Figure 7** Bioassay of resistant to the black spot disease by using the AK-toxin obtained from the culture of the fungus. Upper to lower leaf disc(1 – 5) means 1 (young) to 5 (older) leaf; cv.“Chojuro”, highly resistant; cv. “Nijisseiki”, highly susceptible; cv. “Gold Nijisseiki”, resistant.
At the same time an easy and effective method for the screening of resistance to the fungus has been developed by treating leaf discs (7 mm in diameter) by the AK-toxin produced by the fungus [25]. It was coincidental and lucky for the breeders that Nakashima, *et al.* [26,27] isolated and identified the chemical structure of the toxin named “AK-toxin” produced by the fungus of black spot disease and generating the symptom of black spots on leaves at the same time. As a consequence, the breeding group entered into a cooperative research programme with the chemistry group and established this unique method. When the leaf discs are placed on the filter paper soaked with AK-toxin obtained either from the extract of the fungal body or artificial synthesis in a Petri dish, and kept for two or three days, susceptible leaves turned to black and resistant leaves stayed green (Fig. 7). After the development of this method, two new mutant varieties, “Osa-Gold [28,29]” and “Kotobuki Shinsui [30]”
were developed in a short period of time by using this screening method. The economic effect of this research has been great [4].
These researches suggest that the breeding of fruit trees requires patience and that development of easy and precise screening methods is a very important addition to the development of methods for mutation induction.
**Achievement of biological researches on mutations induced by Gamma-ray irradiation**
**Deletion size generated by Gamma-ray**
Naito, *et al.* [31] studied the deletion sizes of transmissible and non-transmissible mutations induced with Gamma-ray and carbon ion beam irradiation by the sophisticated pollen-irradiation methods in *Arabidopsis*. It has been revealed that most mutants induced with these ionizing irradiations possess extremely large deletions (more than 6 Mbp), most of which are not transmittable to the next generation, as well as small deletions (1 or 4 bp), which are normally transmissible.
In rice, the same tendency was observed in transmissible mutants. Morita (unpublished) researched the frequency of transmission of different mutations possessing different deletion sizes as obtained with Gamma-ray irradiation in rice. Among 11 Gamma-ray induced mutants, one *GluA2* mutant exhibited 1 base pair (bp) substitution, and among 10 mutants with a deletion, the deletion size of 6 mutants, which include *CAO* (*chlorophyllide-a oxygenase*), *GA3os* (*GA3-beta-hydroxylase*), *GluA1* (*glutelin A1*), and *GluA2* (*glutelin A2*) are 1 bp deletion, and those of the other *CAO mutants* and *PLA1* (*Plastochron1*) are 3 and 5 bp deletions, respectively. Those of *GluB4/5* (*Glutelin B4/5*), two α-globulin mutants are more than 10 kbp, 15 kbp, and 90 kbp, respectively. It is very interesting that the Gamma-ray induced mutations transmittable to the next generation are primarily classified into 2 groups, the one with extremely a large deletion and the other with small deletions (1 to 5 bp). We are not sure whether or not it is very difficult to obtain mutants with medium deletion size by Gamma-ray irradiations. However, we are accumulating data to elucidate it.
**Different size and location of deletion generates different kinds of phenotypes**
In the course of plant evolution, genes are often duplicated in tandem, resulting in a functional redundancy. The analysis of function of these genes by developing double mutants might be difficult because they would be very tightly linked. Mutants of such tandem duplicated genes were investigated for their genotypes and phenotypes. There are reversely repeated two loci, which both codes for mRNA of glutelin production. There are various mutants that exhibit low glutelin contents isolated by SDS-PAGE [7, 32]. The mechanisms of low glutelin contents of mutants that have been studied suggest that the size and the position of deletions generate different characteristics of mutations. Some act as dominant genes or recessive genes, and those relationships between genotypes and phenotypes, etc. are provided as example below.
**Mechanism of low glutelin content in the “LGC-1” mutant**
The *Low glutelin content* (*Lgc-1*) is a dominant mutation that reduces glutelin content in the rice grain. Glutelin is a major digestible seed storage protein encoded by a multigene family. Kusaba, *et al.* [33] reported that in *Lgc-1* homozygotes, there is a 3.5 kbp deletion between two highly similar glutelin genes that forms a tail-to-tail inverted repeat, that might produce a double stranded RNA molecule, a potent inducer of RNA silencing (Fig. 8). As a result, glutelin synthesis is suppressed and the glutelin content is lowered. The *Lgc-1* provides an interesting example of RNA silencing occurring among genes that exhibit various levels of similarity to an RNA-silencing-inducing gene. This was the first report that shows the mechanism of a mutation was RNAi.
**Mechanism of low glutelin content in the “glu1” mutant**
The “*glu1*” is a gamma-ray-induced rice mutant, which lacks an acidic subunit of glutelin, a major seed storage protein. Morita, *et al.* [34] elucidated that the *glu1* harbors a 129.7 kbp deletion involving two highly similar and tandem repeated glutelin genes, *GluB5* and *GluB4*. The deletion eliminated the entire *GluB5* and *GluB4* gene except half of the first exon of *GluB5*. As a result, the phenotype of the *glu1* gene is a complete lack of the acidic subunit of glutelin and acts as a recessive gene for low glutelin content in rice grains (Fig. 9).
**Conclusion**
The above examples illustrate that the position and the size of deletions in the same loci have the capacity to dramatically alter the phenotype of mutants through the process of transcription and translation. The *glu1*, which has a large 129.7 kbp deletion, acts as a recessive gene, while the *LGC1*, which has 3.5 kbp deletion including probably a terminal signal of the transcript region acts as a dominant gene.
Furthermore, the *GluB5* and the *GluB4* have the same amino acid sequence in their acidic subunit, suggesting that only the mutation involving both *GluB5* and *GluB4* result in the resultant phenotype. That is the lack of the glutelin acidic subunit deleted in the “*glu1*” mutant. It probably is very difficult to knock out both loci by chemical treatment or transposon techniques. Sequenced plant genomes exhibited more that 14% of the genes formed tandem array [3, 35]. This finding, however, suggests that Gamma-rays can be an effective mutagen to generate knock-out mutants of both loci and to analyze tandem repeated and functionally redundant genes.
---
**Figure 8** Mechanism of low glutelin in LGC-1 through a deletion at the transcription termination signal and produced double-stranded RNA suppress the glutelin synthesis by RNAi [33] (by courtesy of Prof. M. Kusaba, Hiroshima University).
**Figure 9** Comparison of phenotype, mode of inheritance and mechanism of mutation character between glu1 and Lgc-1 mutation with different size and place of deletion in the same region of 2 loci, GluB4 and GluB5 (by courtesy of Dr. R. Morita, IRB, NIAS). glu1, Morita *et al.* [34]; Lgc1, Kusaba *et al.* [33]
Genetic studies by the useful mutations induced with Gamma-ray chronic irradiation
As the history has shown, spontaneous and induced mutation resources have played an important role not only for mutation breeding but also genetic studies and the elucidation of gene functions.
**Phytochrome**
Takano, *et al.* [36] have isolated *phytochrome B* (*phyB*) and *phy C* mutants from rice and have produced all combinations of double mutants. Seedlings of *phy B* and *phyB phyC* mutants exhibited a partial loss of sensitivity to continuous red light but still showed significant deetiolation responses. The responses to red light were completely canceled in *phyA phyB* double mutants. These results indicate that *phyA* and *phyB* act in a highly redundant manner to control deetiolation under red light. They also found that mutations in either *phyB* or *phyC* locus causes moderate early flowering under a long-day photoperiod, while monogenic *phyA* mutations had little effect on flowering time. The *phyA* mutation, however, in combination with *phyB* or *phyC* mutation caused dramatic early flowering. Early flowering mutants were generated by chronic Gamma-ray irradiation with dose rates ranging between 3 and 6Gy/day [36].
**Aluminum tolerance**
Ma, *et al.* [37] isolated a mutant with highly sensitivity to aluminum concentration from cv. Koshihikari of japonica rice, which has an aluminum resistance [38]. The mutant was induced with chronic Gamma-ray irradiation and exhibited the same phenotype to the wild type with the absence of aluminum. That is, M₁ plants were irradiated in the Gamma Field from seven days before heading to two days after heading under 20Gy/day for eight days. The root elongation of the mutant, however, was highly inhibited in the presence of 10 µM Al. The mutant also exhibited poorer root growth in acid soil. Genetic analysis showed that the high sensitivity to Al is controlled by a single recessive gene. The gene was mapped to the long arm of chromosome 6.
**Conclusion**
The Gamma Phytotron was established in Korea in 2005 and the Gamma Greenhouse, approximately doubled the size of the Gamma Greenhouse located at the IRB, Japan, was established in Malaysia in 2008. Both facilities are focused on the induction of mutation by chronic Gamma-ray irradiation to growing plants of important crop species. As described earlier in this report, chronic irradiation is a useful tool for the generation of mutant genome resources that have application toward molecular analysis as well as conventional breeding.
**Conclusions**
A. M. van Harten [39] describes in “Mutation Breeding -Theory and practical application,”
“An explanation for the decreasing interest in mutation breeding, at least in most “developed” countries, may be that during the past two decades attention has become more and more directed towards studying the possibilities offered to plant breeding by various new molecular technologies…As a result of these developments mutation breeding seems to have lost part of its previous attraction for young researchers.”
It is not necessary to mention, however, that mutation breeding is still a very interesting and useful technology for isolating genes and for elucidating gene mechanisms and metabolic pathways in various crops.
The record has also shown that mutation induction is a very useful conventional breeding tool for developing superior cultivars. Today, site-directed mutagenesis *in vivo* or *in vitro* cell can be envisioned and many researchers are conducting programmes in this direction.
New fields of science and technologies were developed on the basis of achievements of traditional or classic methods. It is highly desirable that the IRB continues their work while incorporating the new knowledge and technologies. The IRB is well equipped with appropriate facilities and equipment that will contribute to the future mutation breeding developments and be a contributor in solving the problems mentioned in this review.
**ACKNOWLEDGEMENTS**
Author would like to express his sincere thanks to Dr. Bryan Kindiger, USDA, ARS-SR, Grazinglands Research Laboratory for his critical reading of the manuscript.
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Mutation Breeding in Oilseeds and Grain Legumes in India: Accomplishments and Socio-Economic Impact
S F D’Souza*, K S Reddy, A M Badigannavar, J G Manjaya & S J Jambhulkar
Abstract
In India, oilseed and legume crops are important food components as they are major contributors to dietary oils and proteins. In order to generate genetic variability in these crops, mutation research is extensively carried out at Bhabha Atomic Research Centre (BARC), Mumbai for the past half a century. Besides cytogenetic studies, the era of direct mutants as crop varieties began in groundnut, mustard, pigeonpea and mungbean. Induction of modified traits and their incorporation in an ideal genotype was achieved by judicious use of induced mutation and hybridization techniques. So far, 110 varieties in oilseed and legumes have been developed in India by incorporating desirable traits like large seed, semi-dwarf habit, high harvest index, better partitioning, fresh seed dormancy, yellow seed color, drought tolerance, resistance to powdery mildew, yellow mosaic virus, and bacterial pustule diseases. Many of the national/state breeding programmes have been utilizing these varieties as parental materials/donors and developed several improved varieties. Several of these varieties have high patronage from the farming community and are extensively grown in the country. Groundnut varieties have made considerable impact by giving record yields across the country. Further, mungbean varieties were also surging ahead by virtue of their resistance to yellow mosaic virus, *Rhizoctonia* root-rot and powdery mildew diseases with suitability to rice fallow situations. Blackgram variety ‘TAU-1’ has occupied maximum blackgram area in Maharashtra state. These varieties also facilitated farmers to develop newer cropping systems. Thus, induced mutation research remained in the forefront of Indian agricultural research by developing popular varieties with higher productivity potential in oilseeds and legumes.
Introduction
India produces variety of oilseeds and grain legumes, which constitute around 12% and 7% of the total food grain production, respectively [1]. Large proportion of Indian population relies on grain legumes as a dietary source of proteins due to economic or cultural reasons. India is the fifth largest oilseed producer accounting for 8% of the global oilseed production. Soybean contributes 31.4%, rapeseed/mustard 28.2%, groundnut 27.7% and sunflower 4.8% to Indian oilseed production [1, 2]. Among the food legumes, chickpea is the major Indian legume contributing 40.2% to country’s total legume production by pigeonpea (17.4%), blackgram (10.6%) and mungbean (8.6%) [1]. National productivity levels compare poorly with rest of the world. In 2006, India imported 4.17 million tonnes of edible oils and 1.61 million tonnes of legumes worth of 2.57 billion USD [1]. Annual consumption of these is expected to increase further with increased urbanization, higher disposable incomes and burgeoning population, necessitating more imports. Many of the issues attributed to lower productivity were narrow genetic base, lack of tolerance to biotic and abiotic stresses, lack of quality seeds of improved varieties and restriction of these crops on marginal areas with poor inputs.
Development of mutant varieties in oilseeds and grain legumes
Mutation breeding has played a significant role in the last 75 years by releasing around 2,672 mutant varieties for commercial cultivation in the world [3]. The major contribution is from cereals followed by ornamentals, legumes and oilseeds. Most of mutant varieties were released in China (27.7%), India (12.7%), Russia (9.8%), Japan (8.7%), Germany (6.5%), Netherlands (6.5%), USA (4.7%) and others (22.9%). Many induced mutants were released directly as new varieties, others used as parents to derive new varieties. Nearly 400 mutant varieties have been released in oilseeds and legumes in the world, of these 110 varieties were released from India.
In India, mutation breeding is being carried out in several national/state universities/institutes like Bhabha Atomic Research Centre (BARC), Indian Agricultural Research Institute (IARI), National Botanical Research Institute (NBRI), Tamil Nadu, Agricultural University (TNAU), etc. Under the peaceful uses of atomic energy in agriculture, BARC had initiated radiation based mutation techniques for the genetic enhancement of oilseeds and legumes more than five decades back. At present, BARC has been concentrating on major oilseeds of country’s interest like groundnut, mustard, soybean, sunflower and legumes such as pigeonpea, mungbean, blackgram and cowpea [4]. Initial research activities focused on the effect of radiation on oilseeds and legumes, induction of wide spectrum of mutants for various traits, and genetical and cyto-genetical studies of mutant traits. In most of the mutation experiments, the objectives were to develop high-yielding varieties with early maturity, large seed, high oil content, moderate seed dormancy, ideal ideotype, tolerance to biotic and abiotic stresses and improved seed quality traits. Both chemical and physical mutagens were used for induced mutagenesis in oilseeds and legumes. Initial germplasm used for mutagen treatment was seeds of cultivar, mutant, selection, hybrids or advanced lines. Induced mutants are utilized directly for varietal development or in recombination breeding by hybridizing mutant X mutant, mutant X cultivar, mutant derivative X mutant or mutant derivative X cultivar. Varietal development using mutation with recombination breeding in oilseeds and grain legumes and their accomplishments and societal impact is briefly discussed here.
Sustained induced mutagenesis in oilseeds and grain legumes using X-rays, beta rays, Gamma-rays, fast neutrons, ethyl methane sulphonate and sodium azide resulted in wide spectrum of mutants affecting various traits (Table 1). Of these, six mutants of groundnut, three of sesame and one of sunflower were registered with National Bureau of Plant Genetic Resources (NBPGR), New Delhi for their mutant traits. First groundnut mutant, TG 1 with superior agronomic performance was released for commercial cultivation in 1973 [5]. Later research efforts with the initial X-ray irradiation followed by intermittent gamma irradiation and cross breeding exploited interaction of mutant X mutant, mutant X cultivar, mutant X breeding line genomes in turn resulted in wide spectrum of
genetically diverse, agronomically important breeding lines. Planned irradiation had broken undesirable linkages and enhanced favorable recombinants. As a result, traits like large seed, increased harvest index, assimilate partitioning, semi-dwarf habit, earliness, new ideotypes, improved seed quality, and enhanced disease resistance were incorporated in oilseeds and legumes.
The effective blend of mutation and recombination breeding at our and other institutes resulted in the release of 50 oilseeds and 60 legume varieties for commercial cultivation in the country (Table 2). Among these, 33 varieties have been released by BARC [4]. These varieties were evolved by incorporating desirable agronomic features like large seed in TG 1, TKG 19A, Somnath (TGS 1), TPG 41 and TLG 45 (groundnut); TAT 10 and TT 6 (pigeonpea); TAP 7, TM 96-2 and TMB 37 (mungbean); TAU 2 (urdbean); semi dwarf habit, high harvest index and better partitioning in TAG 24 (groundnut), TRC 77-4 (cowpea); fresh seed dormancy in TG 22 and TG 26 and drought tolerance in TG 37A (groundnut). Additionally, powdery mildew resistance in TARM 1, TARM 2, TARM 18, TM 96-2; powdery mildew and yellow mosaic resistance in TMB 37 and TJM 3 (mungbean), bacterial pustule resistance in TAMS 38 and multiple pest resistance in TAMS 98-21 (soybean); yellow mosaic virus resistance in TU 94-2 (urdbean) were also introduced in these varieties. Mutant varieties like Aruna of castor, Pusa 408 (Ajay), Pusa-413 (Atul), Pusa-417 (Girnar) of chickpea, Co-4, MaruMoth-1 of mothbean are among the important varieties of economic significance released in India.
### Table 1. Spectrum of mutants in oilseeds and grain legumes maintained at BARC, Mumbai, India
| Crop | Botanical name | No of mutants | Traits mutated | Mutagen used |
|---------------|--------------------|---------------|--------------------------------------------------------------------------------|-------------------------------|
| Groundnut | *Arachis hypogaea* | 176 | Plant height, leaf, pod, seed, disease, oil, salinity tolerance | X rays, gamma rays, EMS, Sodium azide |
| Soybean | *Glycine max* | 55 | Plant height, leaf, protein traits, fatty acid, root noduleation, flower colour, trypsin inhibitor | Gamma rays |
| Mustard | *Brassica juncea* | 12 | Earliness, seed colour, low erucic acid, high oil, leaf type and colour, appressed pods, powdery mildew tolerance | Beta rays, gamma rays |
| Sunflower | *Helianthus annuus*| 10 | Plant height, leaf colour, seed colour, male sterility, high oil, less ray florets | Gamma rays |
| Mungbean | *Vigna radiata* | 124 | Plant height, leaf, branches, flowering, pod, seed, yield, disease resistance, drought tolerance, resistance to pre-harvest sprouting | X rays, gamma rays, EMS |
| Blackgram | *Vigna mungo* | 74 | Plant height, leaf, branches, flowering, pod, seed, yield, pod shattering resistance, disease resistance | X rays, gamma rays, EMS, Sodium azide. |
| Pigeonpea | *Cajanus cajan* | 25 | Plant height, leaf, branches, flowering, pod, seed, yield, disease resistance | Gamma rays, fast neutrons, EMS |
| Cowpea | *Vigna unguiculata*| 34 | Plant height, leaf, branches, flowering, pod, seed, yield, disease resistance, drought tolerance | X rays, gamma rays, EMS, Sodium azide. |
### Table 2. Mutant varieties of oilseeds and grain legumes released for commercial cultivation in India
| Crop | Botanical name | No of varieties | Mutagen | Traits improved |
|---------------|--------------------|-----------------|--------------------------|--------------------------------------------------------------------------------|
| Groundnut | *Arachis hypogaea* | 28 | X-rays, Gamma rays, Sodium azide. | Large seed, early maturity, seed dormancy, high shelling out-turn, high harvest index, drought tolerance |
| Soybean | *Glycine max* | 7 | Gamma rays | Dwarf, earliness, bacterial leaf pustule resistance |
| Mustard | *Brassica juncea* | 7 | X-rays, beta rays, gamma rays | Earliness, large seed, high oil, seed coat colour |
| Castor | *Ricinus communis* | 4 | Fast neutrons, Gamma rays | Early, high yield, drought tolerance |
| Sesame | *Sesamum indicum* | 3 | Gamma rays, EMS | Dwarf, high yield, Cercospora leaf spot (CLS) tolerance |
| Sunflower | *Helianthus annuus*| 1 | Gamma rays | Seed coat colour |
| Mungbean | *Vigna radiata* | 8 | Gamma rays, DMS | Earliness, green fodder, high yield, fodder |
| Cowpea | *Vigna unguiculata*| 8 | Gamma rays, DMS | High yield, profuse branching, Fusarium wilt resistance, robust plant type, salinity tolerance |
| Chickpea | *Cicer arietinum* | 7 | Gamma rays, Fast neutrons | High yield, large seed, profuse branching, wilt resistance |
| Blackgram | *Vigna mungo* | 7 | Gamma rays, X-rays | Large seed, terminal podding, tolerance to PM and YMV |
| Pigeonpea | *Cajanus cajan* | 6 | X-rays, Fast neutrons, Gamma rays, EMS | High yield, large seed, profuse branching, wilt resistance |
| Mothbean | *Vigna aconitifolia*| 5 | Gamma rays, EMS | High yield, YMV resistance, high protein, high harvest index |
| Lentil | *Lens culinaris* | 3 | Gamma rays | Large seed, protein content |
| Field bean | *Dolichos lablab* | 2 | Gamma rays | Large seed, Photo-insensitiveness |
| Pea | *Pisum sativum* | 1 | E I | Semi-erect, high yield |
| French bean | *Phaseolus vulgaris*| 1 | X-rays | Earliness, YMV resistance |
| Others | | 3 | Gamma rays | High yield, earliness, large seed |
**Socio-economic impact of mutant varieties**
The majority of the mutant varieties not only benefited the Indian farming community, but are also being used as genetic resource material in national/state breeding programmes. Among the groundnut varieties, TAG 24, TG 26, TG 37A in normal seed class and TKG 19A and TPG 41 in large seed class, became popular among the farming community in India. These are being used as check varieties in the respective national and state varietal trials. As a first step to transfer the benefits of these varieties to the farmers, large-scale breeder seed production programmes were undertaken.
by involving several national institutes and state agricultural universities. In the last decade (1998-2008) 1,022 metric tons of breeder seed of these groundnut varieties worth 1.18 million US dollars was produced and supplied to various National and State Seed Corporations, State Agricultural Universities, seed companies, non-governmental organizations, farmers, etc. Based on the feedback received from National Seed Corporation, Pune, they supplied 1,190 metric tons worth 1.3 million US dollars of certified seed of TG varieties to farmers in the last five years. Further, several millions worth trading of groundnut mutant varieties has been taking place in most of the groundnut markets.
Farmers have been realizing the high-yielding ability of groundnut varieties by harvesting record groundnut yields in many parts of the country. By cultivating these mutant varieties, the groundnut productivity in major groundnut states like, Gujarat, Andhra Pradesh, Maharashtra, Karnataka, Orissa and Rajasthan has been almost doubled. Hundreds of farmers were harvesting significantly improved productivity even up to seven tonnes/ha and earning a net profit up to 1,200 US dollars/ha, when recently released groundnut varieties were introduced in these states [6]. Progressive farmers had harvested a record yield of more than 10 tonnes/ha dry pods in TAG 24 and TG 26 varieties by growing them under suitable agro-ecology such as summer environment, balanced nutrition and uninterrupted but controlled irrigation to achieve record yields in groundnut [7]. TAG 24 and TG 26 comprised most of the ideal morpho-physiological traits defined for groundnut. Both the varieties were grown at Field Research Laboratory, Leh at an altitude of 3,505 meters above mean sea level using polythene mulch. This might be the world’s first report of groundnut cultivation at that altitude. According to Valls, et al. [8], some of the wild *Arachis* species are grown at an altitude of almost 1,600 meters. A drought tolerant variety, TG 37A has rekindled groundnut cultivation in desert areas of Rajashtan state. Existing large seed varieties were with long duration, longer seed dormancy and low productivity. However the recent release of large seed mutant varieties like TPG 41 and TLG 45 benefited many farmers, traders and exporters by virtue of their earliness, moderate seed dormancy and superior productivity.
Looking into advantages of these varieties, several organizations were conducting large-scale field demonstrations and many seed companies have taken up large-scale seed multiplication in order to reach larger pockets of farming community. Directorate of Oilseeds Development, Hyderabad had allocated 9,700 minikits of TG 37A and TPG 41 in major groundnut growing states. Trombay varieties also facilitated farmers to develop newer cropping systems like intercropping groundnut with sweet corn, Bt cotton, sugarcane; polythene mulch technology in groundnut. Our own estimates, breeder seed demand and feedback received from various agencies indicate Trombay groundnut varieties cover around 25% area of groundnut in the country.
In mungbean, BARC has made major break through in developing disease resistant varieties. TARM 1, TARM 2 and TARM 18 were the varieties released for the first time with powdery mildew resistance for southern and central zones of India [9]. TMB-37 has been released for summer season, having early maturity (55-59 days) and yellow mosaic disease resistance that made available an additional area for mungbean cultivation under crop diversity programme. Another mungbean variety TJM 3 is the first variety with multiple disease resistance for powdery mildew, yellow mosaic virus and *Rhizoctonia* root-rot diseases. The recently released mungbean variety TM 96-2 is the first variety for rice fallow cultivation in India, which has powdery mildew resistance and synchronous maturity which are the essential traits for rice fallow cultivation, where nearly four million hectares of rice fallow area is available in India and considered prime area under crop diversity programme. Disease resistance in Trombay mungbean varieties not only enhanced the productivity but also benefited in recovering quality seeds. Based on the breeder production during last few years, Trombay mungbean varieties are estimated to cover around 10% (300,000ha) of mungbean area in the country.
Urdbean mutant varieties TAU 1 and TU 94-2 are very popular varieties in central and southern zones of India. TAU 1 ranks first for breeder seed demand every year. Based on the feedback received from Maharashtra State Seed Corporation, Akola and National Seed Corporation, Pune, they supplied 21,013 metric tons worth 18.5 million US dollars of certified seed of TAU 1 to farmers. Recently released soybean varieties, TAMS 38 and TAMS 98-21 are becoming popular among the farmers in Vidarbha region of Maharashtra state and are being cultivated on around 150,000 hectares [10].
**Conclusion**
Our experiences have shown that induced mutation has come to stay as an efficient plant breeding method towards improvement of oilseeds and legumes and development of commercial varieties for our farming community. Evidently, this methodology has benefited the farmers, traders, exporters and end-users and will continue to play a significant role in addressing food and nutritional security. In the present genomic era, induced mutants would be ideal genetic material for future functional genomic studies.
**ACKNOWLEDGEMENTS**
We thank Dr. S. Banerjee, Director, Bhabha Atomic Research Center and Dr. K.B. Sainis, Director, Biomedical Group for their keen interest and encouragement.
**BIBLIOGRAPHY**
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6. Murty, G.S.S. *et al.* Impact of new trombay groundnut varieties, *Nuclear India* **41**(03-04), 13 (2007).
7. Kale, D.M. High yields with ideal idotypes of groundnut varieties tag 24 and tg 26. *International Arachis Newsl.* **22** 13 (2002).
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9. Reddy, K.S. *et al.* Inheritance Of Powdery Mildew (*Erysiphe Polygoni* DC) Resistance In Mungbean (*Vigna Radiata* L. Wilczek). *Theor. Appl. Genet.* **88**, 945 (1994).
10. Manjaya, J.G. Genetic improvement of soybean through induced mutations. *IANCAS VI/4*, 319 (2007).
Achievements of Grain Legume Variety Improvement Using Induced Mutation of the IAEA/RAS/5/040 Project in Thailand
S Srisombun\textsuperscript{1,*}, P Srinives\textsuperscript{2}, C Yathaputanon\textsuperscript{1}, S Dangpradub\textsuperscript{1}, A Malipan\textsuperscript{1}, W Srithongchai\textsuperscript{1}, B Kumsueb\textsuperscript{1}, V Tepjun\textsuperscript{1}, S Ngampongsai\textsuperscript{1}, A Kornthong\textsuperscript{1} & S Impithuksa\textsuperscript{1}
Abstract
IAEA/RAS/5/040 project aims to form a regional cooperation network of mutation germplasm with emphasis on seed-propagated crops among the Member States in Asia and Pacific commencing in 2002 and ending in 2006. It comprised of two components, the establishment and implementation of mutant multi-location trials and the establishment of mutation germplasm network. Thailand participated with two major grain legume crops, soybean and mungbean, of both components. Significant achievements are summarized.
**Soybean mutant multi-location trials:** Two introduced mutants, DT84 from Vietnam and Bangsakong from Korea were well adapted in the upper and lower north of Thailand. DT84 produced similar yield and matured 18 days earlier than Chiang Mai 60 whereas Bangsakong gave 11% greater yield with 12 days earlier than Sukhothai.
**Soybean mutants resistant to Soybean Crinkle Leaf:** The disease, caused by virus, is a major disease in Thailand. It is transmitted by whitely (\textit{Bemisia tabaci}). Seed of a soybean line cmn9238-54-1(ST) was irradiated with 200 gray. A number of mutant lines were selected under natural field infections and tested in laboratory. Six mutant lines resistant to the disease were finally selected.
**Soybean mutants with high grain protein:** The government policy is to increase grain protein soybean for soy food products. Seeds of three soybean varieties namely Chiang Mai 60, SSRSN19-35-4 and EHP275 were irradiated with 200 gray. Pedigree method of selection was used and grain protein of the mutants was analysed. Thirty two mutant lines were selected. The result of a preliminary trial showed that the lines gave average grain protein of 0.8, 2.0 and 1.0% higher than the original parents of 41.8, 40.3 and 41.9%, respectively.
**Soybean mutants with high seed germination and vigor:** Chiang Mai 60, a high yielding soybean variety, has a poor character of seed germination and vigor. Seed of Chiang Mai 60 was irradiated with 100 gray. Pedigree method of selection was used in late generations. Accelerated Aging Test was also used to test the seed vigour of the mutant lines. In dry season trial, eight mutant lines had seed germination of 65-75% compared with the parent of 30%. In rainy season, 12 mutant lines had seed germination of 75-89% whereas the parent had only 41%.
**Mungbean mutant multi-location trials:** The highest yielding variety across five trials during 2003-2005 was a Thai mutant, Chai Nat 72. It produced large seed of 70g/1,000 seeds which is a desirable trait for Thai and international markets. However, this mutant is susceptible to powdery mildew disease. An introduction from the Philippines, LM19-Native Variety, showed resistant to the disease. It can be utilized for mungbean breeding programme.
**Novel mungbean germplasm derived from induced mutation; variegated leaf:** All F\textsubscript{1} plants from the cross between variegated mutant and normal leaf parent showed normal green leaves without reciprocal while the F\textsubscript{2} plants segregated well in a 3:1 ratio. The number of F\textsubscript{3} lines showing all green plants, segregating, all variegated plants fitted well with the 1:2:1 ratio. The variegated leaf character is controlled by a single recessive gene.
**Multiple leaflet:** A mutant with small pentafoilate was crossed with a large heptafoilate mutant to study the inheritance. It was found that their F\textsubscript{2} plants segregated in the ratio of 9,3,4 with tri (N\textsubscript{1}-N\textsubscript{2}-), penta (N1-n2n2) and heptafoilate (n,n,N\textsubscript{2}- and n,n,n,n,n\textsubscript{2}-). The n\textsubscript{2} may be closely linked to the gene controlling leaf size as well. There are three AFLP markers linked to number of leaflets per leaf and all of them corresponded to the n\textsubscript{2} locus. The mutants of soybean and mungbean will be utilized for further breeding programme and demonstrated in farmers’ field.
Introduction
IAEA/RAS/5/040 project, Enhancement of Genetic Diversity in Food, Pulses and Oil Crops and Establishment of Mutant Germplasm Network, aims to form a regional cooperation network of mutation germplasm with emphasis on seed-propagated crops among the Member States in Asia and Pacific. The project was first approved in 2002 and ended in 2006. It comprised of two components, the establishment and implementation of mutant multi-location trials and the establishment of mutation germplasm network. Thailand participated in two major grain legume crops, soybean (\textit{Glycine max} L. Merrill) and mungbean (\textit{Vigna radiata} L. Wilczek), of both components. Soybean is the most important grain legume in Thailand. The annual planted area during the past five years of 2002-2006 was 156,000ha with an annual production of about 232,000t [1], only 15% of the country’s demand. Presently, 70% of the domestic demand is used for vegetable oil extraction and 10% is used for food products. Thai government policy is to increase the national productivity and improve grain quality of high protein for domestic consumption and for exports of soy food products. Mungbean is the second most important grain legume, occupying an annual planted area about 210,000ha during 2002-2006 with an annual production of 151,000t [1]. It can be cultivated three seasons of the year, the late rainy season commencing between late August and September is strongly recommended. Most of the annual mungbean production is used for bean sprouts. Therefore, germination and sprout quality are very important. Then bold seed is a preferred trait for domestic use and exports. Significant achievements of the research project are summarized.
**Soybean mutant multi-location trials**
The objective of this study was to evaluate grain yield and adaptability of introduced soybean mutants and their parents. The experiment was conducted at Chiang Mai Field Crops Research Center (FCRC) (18°14'N lat., 99°30'E lon., 316 m alt.) and Sukhothai Plant Production and Technical Service Center (PPTSC) (17°10'N lat., 99°52'E lon., 54 m alt.), the representative areas of the main soybean production in northern Thailand. RCB design was used with three replicates. A total number of 15 varieties included three mutants from Indonesia (GH-7, M-220, I-209), one parent and two mutants from Korea (Kumkangdaerip, KEX-2, Bangsakong), two mutants from Vietnam (M103, DT84), two parents and two mutants from China (HC18, HC18M, AJMD, AJMMD), and a parent (Chiang Mai 60), a mutant (CM60-10KR-71-PS-21) and a
local check (Sukhothai 2) from Thailand. Plant population density was about 30-40 plants/m² with 50 cm between rows, 20 cm between hills and three to four plants per hill. Seed was inoculated with *Bradyrhizobium* at Chiang Mai FCRC. Fertilizer grade of 12-24-12 at a rate of 156 kg/ha was applied during 15-25 days after sowing (DAS). Pre-emergence herbicide was sprayed plus hand weeding prior to flowering. Insecticides were sprayed to control key insect pests, beanfly, whitefly, pod borers and bugs. Soybean was planted during either rainy or dry seasons. The amounts of rainfall during the crop duration in rainy season at Chiang Mai FCRC were 488 mm, 649 mm and 1,007 mm in 2003, 2004 and 2005 and at Sukhothai PPTSC were 546 mm and 672 mm in 2004 and 2005, respectively. In dry season 2004 and 2005, the plots were irrigated by flood-furrow system five times at Chiang Mai FCRC. In dry season 2005 at Sukhothai PPTSC, the plots were sprinkled six times with a total amount of 300 mm of water. Plants were harvested at 95% of pods reach their maturity.
### Table 1. Soybean traits of exotic mutants compared with Thai varieties
| Area/ variety | Grain yield (t/ha) | Days to maturity<sup>2</sup> | 100 seed wt. (g) |
|---------------|--------------------|-----------------------------|------------------|
| Upper north (5 trials, 2003-2005) | | | |
| DT84 | 1.74 | 83 | 15.2 |
| Chiang Mai 60<sup>1</sup> | 1.69 | 101 | 13.7 |
| Lower north (2 trials, 2005) | | | |
| Bangsakong | 2.08 | 82 | 15.0 |
| Sukhothai 2<sup>1</sup> | 1.89 | 94 | 14.5 |
<sup>1</sup> Thai check varieties
<sup>2</sup> days after sowing
At Chiang Mai FCRC, Chiang Mai 60, the most popular variety among Thai farmers in the upper north and central region, gave an average grain yield of 1.69 t/ha (Table 1), compared to the national average yield of 1.53 t/ha during 2003-2005 [1]. In general, the later days to maturity of the soybean, the greater the yield produced [2]. A mutant DT84 from Vietnam matured 18 days earlier than that of Chiang Mai 60, 101 DAS. However, it gave average grain yield of 1.74 t/ha, similar to that of Chiang Mai 60 (Table 1). In addition, DT84 had 11% larger seed size than Chiang Mai 60, 13.7 g/100 seeds. Desirable soybean grain of the Thai market for food products should have similar or larger seed size than Chiang Mai 60. DT84 is suitable to be grown in the rice-based cropping system and it is very promising for farmers in the upper northern area of the country [3].
At Sukhothai PPTSC, no introduction gave better yield than Thai variety Sukhothai 2, except a mutant Bangsakong from Korea produced the highest grain yield of 2.08 t/ha averaged from the 2005 trials, 11% higher than that of Sukhothai 2 (Table 1). Bangsakong matured 12 days earlier than Sukhothai 2, 94 DAS (Table 1). It produced similar seed size with Sukhothai 2, 14.5 g/100 seeds. Bangsakong is also a promising mutant for farmers grown in rice-based cropping system in the lower north of Thailand [3].
During 2006-2007, mutant varieties DT84 and Bangsakong were improved by the method of mass selection at Chiang Mai FCRC. The seed of two varieties was also multiplied for further test of their performance in farmers’ fields prior to released.
### Soybean mutants resistant to Soybean Crinkle Leaf
Soybean Crinkle Leaf (SCL) disease, caused by a virus, is a major disease in Thailand. It was first found in Thailand in 1979 [4]. It is transmitted by whitefly (*Bemisia tabaci*). Since 1998, the disease has been found in most main soybean-producing areas, in all growing seasons, and currently is a major constraint to soybean production [5]. Grain yield of soybean can not be produced if the disease infects at the early stage of growth to flowering. Several insecticides are recommended to control whitefly. However, it is costly and not environmentally friendly. cm9238-54-1(ST) is a soybean promising line, it gave 5-10% higher grain yield than cv Chiang Mai 60. But the line is susceptible to SCL disease. Then seed of the line cm9238-54-1(ST) was irradiated with 200 gray. Pedigree method of selection was used from $M_2$-$M_4$. A number of mutant lines were selected under natural field infections at Lop Buri PPTSC and tested in laboratory at the Department of Agriculture, Bangkok. In laboratory, virus-free whitefly was transferred to infected soybean plants for a day. Then the disease agent was transmitted by releasing 30-40 whiteflies per plant for two days on $M_4$ seedlings lines. Thirty plants were used per line. The plants showing SCL symptom were observed at 40 days after transmission. Yield trials were conducted in 2005 and 2006 at Lop Buri PPTSC. In the 2005 trials, no insecticide was sprayed from emergence to flowering for free whitefly infestations. Later it was sprayed three times after flowering till full seed development to control pod borers and bugs. In the 2006 trial, insecticide was sprayed nine times from emergence to full seed filling stage to completely control whitefly and other insect pests.
Six mutant lines resistant to the disease were finally selected. The disease reaction under the laboratory test is shown in Table 2 compared with the original parent and two check cultivars. The results from the 2005 trials, the six lines gave average grain yield of 2.24-2.33 t/ha, 74-81% higher than that of the original parent under natural disease infections (Table 2). The yield reduction of the parent and check cultivars was due to the susceptibility to the disease leading to a decrease in the number of seeds per pod. Under no SCL disease symptom in the 2006 trial, the original parent gave the highest yield of 3.76 t/ha resulted from the highest number of pods per plant. However, the six mutants produced higher grain yield than the check cultivars. The mutant lines are being tested for their adaptability in farmers’ fields.
### Table 2. Grain yield and disease reaction of soybean mutant lines resistant to SCL disease in 2005 and grain yield under no disease symptom in 2006, Lop Buri PPTSC, Thailand
| Mutant line/variety | Grain yield (t/ha) | SCL disease reaction |
|---------------------|--------------------|----------------------|
| | dry season 2005 | rainy season 2005 | mean | rainy season 2006 | |
| 1-4 | 1.95 abc | 2.54 ab | 2.24 | 3.32 b | R |
| 16-42 | 1.81 bc | 2.66 a | 2.24 | 3.28 b | MR |
| 18-46 | 2.06 ab | 2.59 a | 2.33 | 2.80 c | R |
| 19-49 | 2.02 ab | 2.58 a | 2.30 | 3.38 b | MR |
| 20-50 | 2.14 a | 2.36 b | 2.25 | 3.26 b | R |
| 30-1 | 2.04 ab | 2.61 a | 2.32 | 3.31 b | R |
| CM9238-54-1(ST) | 1.76 c | 0.82 d | 1.29 | 3.76 a | S |
| Chiang Mai 6<sup>1</sup> | 0.52 d | 0.92 d | 0.72 | 2.24 d | VS |
| Sukhothai<sup>1</sup> | 0.64 c | 1.21 c | 0.92 | 2.49 d | S |
| Mean | 1.66 | 2.03 | 1.84 | 3.09 | - |
| CV (%) | 7.6 | 8.1 | 7.9 | 6.0 | - |
| Sowing dates | 10 Jan | 29 Jul | - | 6 Jul | - |
Means followed by a common letter are not significantly different at 5% level by BMRT. Grain yield at 12% moisture. Season 2005 = Variety infestation is significant. Laboratory test of SCL disease, R = resistant, all plants showed no symptom; MR = moderately resistant, 1-10% of plants showed symptom; S = susceptible, 11-50% of plants showed symptom; VS = very susceptible, >60% of plants showed symptom. <sup>1</sup> = check varieties.
### Soybean mutants with high grain protein
The most popular soybean variety of Thai farmers is Chiang Mai 60. It gives about 36-38% of grain protein depending on locations and seasons.
The government policy is to increase grain protein of soybean for soy food products. Then soybean variety improvement to increase grain protein content was initiated. The seed of three soybean varieties namely Chiang Mai 60, SSRSN19-35-4 and EHP275 were irradiated with 200 gray. Pedigree method of selection was used at Nakhon Ratchasima FCRC and grain protein of the mutants was analyzed in laboratory at the Department of Agriculture, Bangkok [6].
A number of 32 mutant lines were selected. The result of a preliminary trial at Nakhorn Ratchasima FCRC in 2007 showed that the lines gave average grain protein of 0.8, 2.0 and 1.0% higher than the original parents of 41.8, 40.3 and 41.9%, respectively [7]. Then it is possible to enhance grain protein percentage with similar or higher yield in the soybean varieties using induced mutation. The promising mutant lines will be further tested for their protein yield in farmer fields.
**Soybean mutants with high seed germination and vigor**
Chiang Mai 60 is a high yielding soybean variety in Thailand. However, it has a poor character of seed germination and vigor. Then induced mutation was used to improve seed quality of the variety, seed of Chiang Mai 60 was irradiated with 100 gray. Pedigree method of selection was used in late generations of M₄–M₆ at Chiang Mai FCRC. Accelerated Aging Test was also used to test the seed vigor of the mutant lines.
A total number of 23 mutant lines were finally selected. In preliminary trials conducted in dry season 2006, eight mutant lines had seed germination of 65–80% compared with the original parent of 30%, whereas in rainy season 2006, 12 mutant lines had seed germination of 75–89%, and the parent gave only 41% [8]. The selected mutant lines are being tested for their yield in standard trials.
**Mungbean mutant multi-location trials**
The objective of this study was to evaluate grain yield and adaptability of introduced mungbean mutants and their parents. A total number of 18 mungbean accessions including introduced mutants, their parents and three Thai check varieties were tested for their yield and adaptability in the central region of the Kingdom, Chai Nat FCRC (15°15′N lat., 100°15′E lon., 16m alt.) and Kasetsart University, Kamphaeng Saen Campus (14°01′N lat., 99°58′E lon., 5 m alt.). Details of experiment carried out are shown in [9].
The highest yielding variety across five trials during 2003–2005 was a Thai mutant, Chai Nat 72. It produced large seed of 70 g per 1,000 seeds which is a desirable trait for Thai and international markets. However, this mutant is susceptible to powdery mildew disease. An introduction from the Philippines, LM19-Native Variety, showed resistance to the disease. It can be utilized for further mungbean breeding programme in Thailand [9].
**Novel mungbean germplasm derived from induced mutation**
**Variegated leaf**
Variegated mutant was obtained from Gamma-rays irradiation at a rate of 500 gray. All F₁ plants from the cross between the variegated mutant and the normal leaf parent showed normal green leaves without reciprocal, while the F₂ plants segregated well in a 3 : 1 ratio. The number of F₁ lines showing all green plants, segregating, all variegated plants fitted well with the 1 : 2 : 1 ratio. Thus it can be inferred that the variegated leaf character is controlled by a single recessive nuclear-encoded gene. We propose *var1* as the gene symbol [10].
**Multiple leaflet**
Two new multiple leaflet mungbean mutants were also obtained from Gamma-rays irradiation. A mutant with small pentafoliate was crossed with a large heptafoliate mutant to study the inheritance at Kasetsart University, Kamphaeng Saen Campus. AFLP markers were also screened to make a partial linkage map around the genes controlling multifoliate leaflets. The number of F₂ plants was tested against a 3, 1 ratio for segregation in a single locus and 9 : 3 : 3 : 1 for 2 independent loci using the Chi-square goodness of fit test. The heterogeneity among the F₁ families was also tested accordingly. Crossing between 7 large leaflet (L-7) and 5 small leaflet (S-5) mungbean mutants resulted in the normal-trifoliate (N) F₁. The F₂ can be classified into number of leaflet per leaf and leaflet size with large-trifoliate (*N₁*-N₂-), small-pentafoliate (*N₁*-n₂-n₂-), large-heptafoliate (*n₁,n₁,N₂-*) and small-heptafoliate (*n₁,p₁,n₂,n₂*) at the dihybrid ratio of 9 : 3 : 3 : 1. The finding is thus evident that leaflet number was controlled by n₁ locus and leaflet size was controlled by n₂ locus of genes, respectively. However, all three AFLP markers associated with leaflet number in this study corresponded to n₁ locus only. The n₂ locus can have a pleiotropic effect upon the leaflet size such that the N₁ allele controls large leaflet size as well. Another hypothesis is that the n₂ locus might be closely linked with the s locus so that there was no progenies with large pentafoliate leaflet (hypothetically carrying N₁- n₂ n₂ S-genotype). [10]
**BIBLIOGRAPHY**
1. Office Of Agricultural Economics. *Agricultural Statistics Of Thailand 2006*. Ministry Of Agriculture And Co-operatives, Bangkok, Thailand (2007).
2. Srisombun S. *et al.* The potential productivity of late maturity varieties of soybeans in Thailand. (Eds., Janprasert, W. et al.) In: Proceedings Of The National Soybean Research Conference VI. September 3-6, 1996. Chiang Mai, Thailand 97-105 (1997).
3. Dangpradub, S. *et al.* Soybean mutants regional trials. *Thai Agricultural Research Journal* **26**, 2-8 (2008).
4. Iwaki M. *et al.* Soybean crinkle leaf, new whitefly-borne disease of soybean. *Plant Disease* **67**, 546-548 (1983).
5. Srisombun, S. *et al.* Soybean mutants resistant to soybean crinkle leaf disease. IAEA/RCA Project Final Review Meeting On Ras/5/040 Project. Jan 15-19, 2007. Mumbai, India (2007).
6. Kumsueb, B. *et al.* Selection of high protein soybean mutants. Proceedings Of The First National Grain Legume Research Conference, Aug. 28-30, 2006. Chiang Rai, Thailand (2007).
7. Yathuputanon, C. *et al.* Protein content in high protein soybean mutants in Thailand. International Symposium On Induced Mutation In Plants. Aug. 12-25, 2008. Vienna, Austria (In This Proceedings) (2008).
8. Tepjun, V. *et al.* Soybean variety improvement for seed germination and vigor in cv Chiang Mai 60 Using Gamma Irradiation. The 2008 Chiang Mai Field Crops Research Center Annual Meeting (2008).
9. Ngamponsai, S. *et al.* Current status of mungbean and the use of mutation breeding in Thailand. International Symposium On Induced Mutation In Plants. Aug. 12-25, 2008. Vienna, Austria (In This Proceedings) (2008).
10. Srinives, P. *et al.* Novel mungbean germplasm derived from induced mutation. IAEA/RCA Project Final Review Meeting On Ras/5/040 Project. Jan 15-19, 2007. Mumbai, India (2007).
Development of Mutant Varieties of Crop Plants at NIAB and the Impact on Agricultural Production in Pakistan
M A Haq
Abstract
The Nuclear Institute for Agriculture and Biology is the prime institute of Pakistan Atomic Energy Commission in the agricultural sector. It began to function in 1969. The main objective of the institute is to conduct research in agricultural and biological problems, especially in those areas where nuclear techniques have an edge over conventional methods. The institute has been conducting research and development work related to crop improvement through mutation breeding. Mutation breeding involves the use of induced beneficial changes for practical plant breeding purposes both directly as well as indirectly. The main objectives have been to confer specific changes such as improvement of plant architecture, earliness in maturity, resistance against diseases and pests, and improved physiological characters, i.e. heat tolerance, cold tolerance, uniform maturity, photoperiod insensitivity etc., in the native well adapted crop varieties/exotic lines to make them more productive. The use of induced mutations for crop improvement has lead to the development of 24 improved varieties of different crops at NIAB which clearly indicates the potential of this technique. In addition, a wealth of genetic variability has been developed for use in the cross breeding programmes and a few varieties of cotton and chickpea have been developed in Pakistan by using induced mutants as one of the parents. These improved crop varieties in Pakistan have played a significant role in increasing agricultural production with positive impact on the economy of the country. The estimated additional income accounted by the selected varieties of NIAB was 1.744 billion US dollars up to 2005.
Introduction
Nuclear Institute for Agriculture and Biology (NIAB), Faisalabad is a prime agricultural institute of Pakistan Atomic Energy Commission. NIAB is one of the four agricultural research centers of the Commission and it now constitutes an important element in the infra structure of scientific research in the country. NIAB has made an indelible mark in the field of agricultural research in the country. Its output in terms of both basic and applied research has more than justified the modest expenditure on its establishment and operation. The main objective of NIAB is to promote peaceful applications of atomic energy in the biological research in general and agricultural research in particular. It was established to demonstrate how modern and advanced nuclear techniques could contribute to major improvement in agricultural output both in quantity and quality, and thereby bringing the economic benefits of atomic energy to the people of Pakistan, 80% of whom earn their livelihood through agriculture.
By a very careful selection of research projects, NIAB has concentrated on devising methods and evolving crop varieties for increasing agricultural productivity and on conservation of inputs and produce. It has been able to make a significant contribution not only in agricultural research but also in understanding some relevant basic biological processes. It has clearly established a role for radiation induced mutations in crop improvement and has succeeded in evolving better germplasm of selected key crops. Work on improvement of cotton, rice, and grain legumes is in progress through the use of mutation breeding, conventional breeding and wide hybridization techniques. The prime strategy in mutation-based plant breeding has been to upgrade the well-adapted varieties by altering one or two major traits. These include characters such as plant height, maturity, seed shattering, and disease resistance, which contribute to increased yield and quality traits [1]. In several mutation-derived varieties, the changed traits have resulted in synergistic effect on increasing the yield and quality of the crop, improving agronomic inputs, crop rotation and consumer acceptance [1]. The breeding efforts have resulted in the development of 24 improved varieties of crop, including six varieties of cotton, two of rice, four of chickpea, 10 of mungbean and two of lentil. In addition, many mutants of these crops are at advanced stages of testing.
In the present paper the development of induced mutants and mutation-derived varieties at NIAB is discussed and their economic impact presented.
Materials and Methods
The research work at NIAB was started during 1969. In crop improvement programme the self-pollinated crops i.e., cotton, rice, chickpea, mungbean and lentil were selected. Mutation breeding involves the use of induced beneficial changes for practical plant breeding purposes, both directly as well as indirectly coupled with the conventional hybridization in some cases. The main objectives have been to confer specific changes such as improvement of plant architecture, earliness in maturity, resistance against diseases and pests, and improved physiological characters i.e. heat tolerance, cold tolerance, uniform maturity, photoperiod insensitivity etc., in the native well adapted crop varieties/exotic lines to make them more productive. The strategy in mutation breeding was to upgrade the well-adapted varieties by altering one or two major traits. Gamma radiation treatments and different EMS concentrations have been tried depending upon radio sensitivity tests. As a result of these breeding efforts different varieties of these five mandate crops have been developed at NIAB.
Results and Discussion
The efforts at NIAB have resulted in evolving 24 improved varieties of cotton, rice, chickpea, mungbean and lentil (Table 1). These self-pollinated crops were selected because of little variability available in them to improvement through conventional techniques. The area and additional income from selected varieties of NIAB during 2004-05 is given in Table 2. Some of the salient results have been described here.
Cotton
The mutation breeding programme in cotton was initiated in 1970 to create genetic variability for development of early maturing, high yielding varieties and germplasm having resistance to diseases, insects and other stresses with better fiber qualities.
Crosses were made between a local (AC 134) and an exotic variety (Delta pine) followed by the irradiation of F₁ hybrid. From the selections, line NIAB 78 had the desired fiber quality and gave the highest yield. It was released as a commercial variety in 1983. It has proved to be adapted to the different agroclimatic areas of the country. Since its introduction cotton, production registered a quantum jump in Pakistan [2]. The cumulative additional income to the farmers because of this variety was 612.4 million US dollars from 1882-83 to 2005 (Table 2). The insect resistant and high yielding variety NIAB 86 was evolved as the result of a cross between a pest resistant mutant H 1-9-6-2 and a long staple mutant SP 16. It was released as commercial variety in 1990. Crossing of mutant line with an exotic germplasm having nectariless leaf resulted in the development of NIAB 26 which was released in 1992.
The onset of CLCuV disease in early nineties resulted in a sharp decline in cotton production inflicting severe set back to our economy. This necessitated incorporation and/or induction of CLCuV resistance into the adapted cotton cultivars. Besides induction of mutations, various sources of CLCuV disease resistance tried to achieve the desired objectives. A nectariless line that had tolerance to heat and leaf curl virus disease was released as a commercial variety ‘NIAB Karishma’ in 1996. NIAB Karishma brought farmers US $ 294.4 million additional income since 1997-98 to 2005. Moreover, a number of elite mutants viz., NIAB-92 (Stoneville), NIAB 313/12 (*G. barbadense* x *G. hirsutum*), Hi (PIMA x *G. hirsutum*), St-3, Hi-9, M 555, Mutant Chandni and Mutant 39 have been developed with specific characteristics of economic value. These mutants proved an asset as a number of varieties viz. Shaheen, NIAB-86, CIM-109, SLS-1 and CRIS-9 have been evolved by various organizations in the country by employing these mutants in their breeding programme [3].
Mutant NIAB-999 has been derived from H1 x LRA 5166 cross combination followed by 300Gy of F₁ seed. It has heat resistance, early maturity, high yield and wider adaptability. Its earliness makes it suitable to fit in wheat-cotton-wheat rotation system. It was approved for general cultivation during 2003. Another mutant strain NIAB-111 has been derived from the intraspecific hybridization, NIAB-313/12 (ISM) x CIM-1100 followed by F₁ seed treatment with 300Gy. It is a high yielding, CLCuV resistant, superior fiber and heat tolerant variety of cotton approved for general cultivation during 2004.
**Rice**
Rice is the third largest crop after wheat and cotton in Pakistan. It is high value cash crop and is also major export item. It accounts for 5.7% in value added in agriculture and 1.2% in GDP. It is grown on an area of 2,621 thousand ha producing 5,547 thousand tons with paddy yield of 2116 kg ha⁻¹. Pakistan grows enough high quality rice to meet both domestic and export demands. Different varieties of rice are grown in Pakistan, viz. Super Basmati, Basmati 385, Irri-6, Niab-Irri-9, KS-282 and KS 133, etc. Pakistan is primarily known for its aromatic rice. Two types of rice dominate the market: Basmati, which is mainly grown in the Punjab province and Irri types, which is mainly grown in Punjab and Sindh provinces. Genetic diversity for early maturity, disease tolerance, semi-dwarfism etc. needs to evolve in Basmati rice for its sustainable production. The IRRI varieties introduced in Pakistan have higher yields than the traditional cultivars but their grain quality does not meet the consumers’ demand.
A research programme was initiated at NIAB for creation of genetic variability in Basmati and IRRI background through induced mutations and hybridization. The objectives for Basmati improvement were to evolve early maturing, short statured, high-yielding, good quality and salt tolerant lines while grain quality improvements were desired in the IRRI varieties.
Earlier research efforts resulted in the release of an early maturing mutant Kashmir Basmati (derivative of Basmati 370) as a variety for general cultivation in Azad Kashmir during 1977. A number of short statured mutants were also developed [4,5]. Several semi dwarf mutants were selected from basmati varieties and used in genetic studies [6]. Studies to identify new gene sources of early maturity and dwarfism in the adapted Basmati background revealed that early maturity gene in Kashmir Basmati was non allelic to that in variety C-622. Similarly, the gene for dwarfness in mutant DM 107-4 was found non allelic to that in IR-6 [7]. The information thus obtained was utilized in the development of short statured and early maturing varieties of Basmati rice. Among other mutants, NIAB-6 proved to be salt-tolerant producing high yields at salinity levels of ECe 10 dSm⁻¹. NIAB-6 was approved and designated as “Niab-Irri-9” by the government of Punjab during 1999 for general cultivation. Niab-Irri-9 is a non-aromatic, fine grain, salt tolerant and high yielding mutant line (derived from IR-6). This variety occupies about 64% area under non-aromatic rice in Punjab and gave 2.43 million US dollars additional income to the farmers during 2004-05 and 16.18 million US dollars from 1999-2000 to 2005 (Table 2). Some of extra long grain mutants namely EL-30-2-1, EL-30-2-2 in Basmati Pak background having grain length and width of 10 and 1.60 mm respectively and elongation of more than 18 mm are being utilized in cross breeding and a number of recombinants with desired traits have been selected.
**Chickpea**
Pakistan ranks second in terms of acreage and third in terms of chickpea production. With protein content nearly twice that of cereals, it is a cheap source of quality protein that complements the proteins in cereals thus enhancing the nutritional value of cereal-dominated diet. Chickpea is of two main types, desi and kabuli. Both are botanically similar, but there are strong consumer preferences in one or the other. The contribution of kabuli to the production is 15%, which is declining due to its greater susceptibility to various stresses than desi type. As a result the price of kabuli remains high and we have to spend more than 250 million rupees annually on its import. In Pakistan, the crop is grown on more than 1.0 million hectares with an annual production of 0.58 million tones. Low yield is due to low yield potential of land races and poor crop management. *Ascochyta* blight and *Fusarium* wilt diseases are also major constraints to its production. To develop high-yielding, widely adapted and disease resistant varieties, a programme at NIAB was initiated in 1974, where an integrated approach to chickpea improvement is being pursued. A high priority has been given to screening of segregating material and advanced mutants for *Ascochyta* blight and *Fusarium* wilt resistance. Yield testing of new mutants/varieties is conducted in cooperation with various national and international agencies.
Every year at NIAB, seeds of at least two chickpea genotypes (one desi and one kabuli) are treated with mutagens for the creation of genetic variability. During last 34 years, 29 genotypes/ varieties have been treated with at least two doses of gamma irradiation and ethyl methane sulphonate (EMS). Mutation breeding requires an effective mutagen treatment and an efficient way of selection [8]. For gamma radiation treatments, dose range of 150 to 750Gy and for EMS treatments, concentrations ranging from 0.1-0.5% have been tried depending upon radio sensitivity tests.
An achievement of these efforts has been the evolution and release of an *Ascochyta* blight resistant and high-yielding variety of chickpea namely cm 72 in 1983. Air-dried seed of blight susceptible but high yielding genotype 6153 were exposed to gamma radiation treatment of 150Gy in 1974; selections made in M₂-M₄ generations [9]. This mutant cultivar covered more than 40% chickpea growing area in the country in 1987 and has helped greatly to stabilize chickpea production.
As a result of efforts to induce blight resistance in different genetic backgrounds other than 6153 to produce alternate sources of resistance,
a blight resistant and wilt tolerant mutant cm 88 was derived from variety C 727 and released in 1994. Air-dried seed of C 727 were exposed to gamma radiation treatment of 100Gy in 1977-78. The M2 was screened in the *Ascochyta* Blight Nursery (ABN) in 1978-79 and resistant plants were selected. The resistant plant progenies were further evaluated in the ABN and also evaluated for various morpho-agronomic traits and yielding ability in Preliminary, Cooperative and National Yield Trials in the successive generations. cm 88 proved to be higher yielding and resistant to *Ascochyta* blight and *Fusarium* wilt [10].
K850 is a bold seeded high yielding variety but it is highly susceptible to *Ascochyta* blight. Efforts were therefore made to rectify this through induced mutation. Seeds of this variety were treated with different doses of Gamma-rays and screening for disease resistance in $M_3$ generation was done in the nursery by artificially creating disease epiphytotic conditions. Selected progenies of resistant $M_3$ plants were studied for agronomic characteristics and samples of each line were tested for disease resistance. Based on yield potential, bold seed and *Ascochyta* blight and *Fusarium* wilt resistance; cm 31-1/85 was selected and released as a variety cm-98 in 1998 [11]. The release of this variety meets the consumer’s demand/preference for large seed size variety.
Large scale cultivation of these high yielding and disease resistant varieties has helped greatly to stabilize/increase chickpea production in the country and since their release no serious blight epidemic has been reported [11].
Many good sources of *Ascochyta* blight resistance are available in the exotic germplasm especially from ICARDA. However, they are not well adapted in Pakistan and are badly affected by Fusarium wilt. The breeding work on kabuli chickpea has resulted in the release of a high-yielding and disease-resistant variety cm2000 in 2000. This variety has been evolved by creating genetic variability in an exotic variety ILC 195 using 150Gy gamma radiation [12]. It is recommended for cultivation in rainfed and irrigated areas of Punjab. Large-scale cultivation of cm 2000 greatly helped in increasing the kabuli chickpea production in the country.
The current area covered by these mutant cultivars is more than 30% of the total area under chickpea. The additional income to the farmers has been estimated at 11.76 million US dollars during 2004-05 and 752.3 million US dollars from 1997-98 to 2005 (Table. 2).
To induce resistance against wilt disease in susceptible kabuli variety (Pb.1), seeds were treated with different doses/concentrations of physical and chemical mutagens and screening for wilt resistance in $M_2$ generation was done in the natural wilt sick field. From $M_3$, segregating populations and subsequent generations cm94/99 was selected and evaluated in various yield trials. This mutant exhibited 38.0 and 66.8% increased yield than check variety cm2000 in Chickpea National Uniform Yield Trials (CNUYT)- kabuli during the years 2003-04 and 2004-05, respectively. The candidate line cm94/99 was cleared by the technical experts in the spot examination during March, 2008 and will be discussed in the meeting of Punjab seed council for approval as a commercial variety for general cultivation.
As a result of mutation breeding efforts, an excellent asset of genetic variability has been created in both types (desi and kabuli) of chickpea through induced mutations. More than 600 disease-resistant (*Ascochyta* blight, *Fusarium* wilt) and morphological mutants affecting most parts, such as leaf, flower, plant height, plant type, pods, maturity and seed were selected from $M_3$ and subsequent generations. Most of the selected mutants have been confirmed for mutational traits and evaluated for various morpho-agronomic traits. The true breeding mutants have been added to the gene pool being maintained at NIAB, Faisalabad and PGRI, Islamabad. This variability is supplied as germplasm to various national and international organizations for use in breeding programmes. Interspecific hybridization between different cultivated varieties and annual wild *Cicer* species has provided useful genetic variability.
**Mungbean**
The work on mungbean improvement was initiated at NIAB in 1970s. The main objective of the mungbean improvement programme was to create genetic variability through induced mutations and hybridization, to evolve high-yielding and disease-resistant varieties having compact plant type, earliness and uniform maturity. Since then 10 high-yielding, early-maturing and disease-resistant varieties have been released. Of these, five varieties viz. NM 28, NM 13-1, NM 19-19, NM 20-21, and NM 121-25 are derivatives of small seeded, local adapted germplasm whereas the large seeded varieties viz. NM 51, NM 54 resulted from hybridization between exotic and local germplasm [3]. The most popular bold seeded variety NM 92 was released in 1996 and a medium seeded variety NM 98, having shiny seed coat color was released in 1998 [13]. During 2006, another bold seeded variety NIAB Mung 2006, a derivative of an exotic AVRDC accession VC 1560D and an adapted variety NM-92 having high seed yield, purple hypocotyls and stem, synchronous pod maturity, higher number of pods per plant, and resistance to *Cercospora* Leaf Spot (CLS) and Mungbean Yellow Mosaic Virus (MYMV) diseases has been approved by the Provincial Seed Council for growing in the irrigated tract of the Punjab province. Purple hypocotyle and stem colour can be used as morphological markers for varietal identification. Varieties NM 92, NM 98 and NM 2006 have been under cultivation on more than 70% of mungbean acreage in Punjab province. NM 92 and NM 98 was grown on an area of 181 thousand hectares and brought 7.56 million US dollars addition income to farmers in 2004-05 and 68.8 million US dollars from 1996-97 to 2005 (Table 2).
**Lentil**
The improvement work on lentil through induced mutations and conventional breeding techniques was started in 1986. Research efforts have culminated in the development of two lentil varieties. NIAB Masoor 2002, a high-yielding, disease-resistant and early-maturing variety was released for cotton based cropping pattern. NIAB Masoor 2002 matures one month earlier than Masoor 93, and farmers of cotton area can grow cotton easily after the harvest of this variety. It is the result of hybridization between an exotic Argentinian variety Precoz and a local cultivar Masoor 85. Punjab Seed Council has approved this variety in the year 2002 for cotton growing areas of the Punjab province.
Another high-yielding and disease-resistant variety, NIAB Masoor 2006, has been developed through induced mutation (ILL 2580 exposed to 200Gy ) and was approved by Punjab Seed Council for traditional lentil growing areas of the Punjab province during 2006.
The discovery that ionizing radiations and chemical mutagens can cause genetic changes and modify linkages offered promise to the improvement of crop plants. Mutation breeding involves the use of induced beneficial changes for practical plant breeding purpose both directly as well as indirectly. Mutation breeding can be used to complement and supplement existing germplasm resources [14]. The prime strategy in mutation-based plant breeding has been to upgrade the well-adapted varieties by altering one or two major traits and these include characters such as plant height, maturity, seed shattering, and disease resistance, which contribute to increased yield and quality traits [1]. Induced mutations have been used in the improvement of major crops such as wheat, rice, barley, cotton, peanuts, beans, which are seed propagated [15]. More than 1,800 cultivars obtained either as direct mutants or derived from their crosses have been released worldwide in 50 countries [16]. Among the mutant varieties released, cereals are at the top followed by legumes, demonstrating the economics of the mutation breeding techniques.
In Pakistan, the use of mutation breeding technique for the improvement of crops has led to the development of 59 cultivars of cotton, rice, wheat, chickpea, mungbean and rapeseed which have played a significant role in increasing crop production in the country.
Conclusion
The use of induced mutations for crop improvement has lead to the development of 24 improved varieties of different crops at NIAB which clearly indicates the potential of this technique. In addition, a wealth of genetic variability has been developed for use in the cross breeding programmes and a few varieties of cotton and chickpea have been developed in Pakistan by using induced mutants as one of the parents. These improved crops varieties in Pakistan have played significant role in increasing agricultural production with positive impact on the economy of the country.
BIBLIOGRAPHY
1. Ahloowalia, B.S., Maluszynski, M., Nichterlein, K. Global impact of mutation-derived varieties. *Euphytica*, **135**, 187-204 (2004).
2. Iqbal, R.M.S., Chaudhry, M.B., Aslam, M., Bandesha, A.A. Economic and agricultural impact of mutation breeding in cotton in Pakistan - a review. In: Plant Mutation Breeding For Crop Improvement, Vienna, IAEA, 187-201 (1991).
3. Nuclear Institute for Agriculture and Biology. Twenty years of Niab. 4th five-year report. Faisalabad, Pakistan, Niab, 203 (1992).
4. Nuclear Institute for Agriculture and Biology. Five years of Niab. 1st five-year report. Faisalabad, Pakistan, Niab, 160 (1977).
5. Nuclear Institute for Agriculture and Biology. Ten years of Niab. 2nd five-year report. Faisalabad, Pakistan, Niab, 166 (1982).
6. Awan, M.A., Cheema, A.A., Tahir, G.R. Induced mutations for genetic analysis in rice. In: Rice Genetics, Irri, Philippines, 697-705 (1986).
7. Nuclear Institute for Agriculture and Biology. Fifteen years of Niab. 3rd five-year report. Faisalabad, Pakistan, Niab, 202 (1987).
8. Micke, A. Mutation breeding of grain legumes. *Euphytica* **152**, 81-85 (1993).
9. Haq, M.A., Sadiq, M., Hassan, M. Induction of ascochyta blight resistance in chickpea through induced mutations. In: Proc. 4th FAO/IAEA Res. Cord. Meet. On The Use Of Induced Mutations For Improvement Of Grain Legume Production, Faisalabad. 3-7 March, (1984).
10. Haq, M.A., Hassan, M., Sadiq, M. ‘Cm 88’ – a multiple disease resistant chickpea mutant variety. IAEA, Vienna. *Mutation Breeding Newsletter*, **45**, 5-6 (2001).
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Socio-Economic Impacts of Mutant Rice Varieties in Southern Vietnam
K T Do
Abstract
Rice production plays an important role in the socio-economic development of Vietnam, especially in the Mekong River Delta (MRD) region, which is responsible for more than half of the total and 90% of the national rice export. Before 1995, no mutant rice varieties (MRVs) were cultivated in the MRD. At present, rice variety improvement is the main focus of the national breeding programme and 8 rice mutants have been developed, occupying 10.3% of the total modern varieties in Southern Vietnam. The mutant varieties developed so far have better resistance to lodging, disease and insect damages, higher tolerance to soil stresses such as acid sulphate soil, drought etc., and also exhibit earliness and higher yield potential. Some of the best mutant varieties, namely VND95-19, VND95-20, VND99-3, TNDB-100 have already been released for large-scale production in the MRD. VND95-20 has become one of the top 5 exported varieties and is grown annually on more than 300,000 ha in Southern Vietnam.
Some of these mutants have given promising recombinants through hybridization and in particular the varieties VN121, VN124, OM2717 and OM2718 have been released into production. A successful combination of aromatic characteristics, short duration, high yield, tolerance to new diseases (GSV & RSV) and insects (BPH), and consequent reduction of spraying times of pesticide per crop, have greatly benefitted health & environmental protection.
During the past 8 years under the IAEA Technical Co-operation (TC) project, the total cultivated area of MRVs in Southern Vietnam has been more than 2.54 millions ha. Until 2008, the 8 rice mutant varieties produced an added return of 374 million USD over the previous years and continue to produce added return for farmers. More specifically, VND95-20, VND99-3, TNDB100, VND95-19, OM2717, OM2718, VN121 and VN124 returned 300.00, 9.0, 37.5, 6.0, 12.0, 8.4, 0.8 and 0.7 million USD, respectively. The application of MRVs reduced spraying times per crop two- to three-fold due to their tolerance to diseases & insects.
MRVs are used in the strategy programme ‘Eradicate hunger and alleviate poverty’ of different national projects, particularly for the ethnic minorities in mountainous and remote regions of Southern Vietnam. Due to the significant contribution of MRVs to socio-economic development, their development has received many prizes by the national & local Government.
Introduction
Vietnam is an agricultural country and 73.5% of its population lives in rural areas. In 2006, Vietnam’s Gross Domestic Product (GDP) was valued at 973,790 billion VND (Vietnamese dong) (at current prices, equivalent to 60.86 billion USD). Agriculture & forestry GDP shared 12.39 billion USD, which occupied 20.36% of the total national GDP [1].
Rice plays an important role in the socio-economic development of Vietnam. The country has made great achievements in paddy production and has become the second largest rice exporting country in the world since 1989. Paddy production is a traditional activity of Vietnamese farmers, hence it always holds the central role in Vietnam’s agriculture and socio-economic issues. The rice sector accounted approximately for 37.0% of agricultural GDP and 26.0% of the agricultural product export value between 2000–2004.
In 2006, the paddy land and sown areas were approximately 4.2 million ha and 7.3 million ha, respectively, occupying 16.9% of the agricultural and 65.3% of the annual crop land areas.
In 2007, total rice production was 36.0 million tons, of which 4.5 million tones was exported (valued at about 1.5 billion USD). The Mekong River Delta (MRD) produced 18.73 million tones (52% occupation) and exported 4.0 million tones (90% of the total rice export). Over the past 20 years, Vietnam has exported 60 million tones of rice to different continents of the world, averaging 4.5 million tones per year for the period between 2002–2007. This has been achieved thanks to the reformed Government policy and the innovative technologies used. Breeding of modern varieties has played an important role in agriculture and increasing the income for farmers.
Between 1987–2006, 78 rice varieties were released in Southern Vietnam: 32 by introduction (41.0%); 33 by hybridization (42.3%); 8 by mutation (10.3%); and 5 by pure line selection (6.4%). Before 1995, there were no mutant rice varieties in production, in Southern Vietnam. Consequently, the rice varieties delivered solely by introduction and hybridization could not meet the production requirements, particularly concerning varieties having traits with high tolerance to adverse conditions, high yield & good quality.
Since 1992 rice mutation breeding combined with other methods has been undertaken, leading to the successful creation of mutant varieties with distinct characteristics, which have significantly affected the socio-economic issues of Southern Vietnam. Some of the best mutant varieties, VND95-19, VND95-20, VND99-3, TNDB-100, OM2717 and OM2718 have been released for large-scale production in the MRD region. Among them, VND95-20 has become one of the top 5 exported rice varieties and is grown on more than 300,000 ha in Southern Vietnam [2]. Some mutants gave promising recombinants in aroma, tolerance to BPH, Grassy Stunt Virus (GSV) & Ragged Stunt Virus (RSV) diseases. Selected varieties such as VN121, VN124 have been released into production in recent time [3].
Breeding, development and production of mutant varieties
Mutation breeding
Since 1993, under the IAEA Technical Co-operation (TC) project since 1997, the mutation breeding programme was initiated for rice. The breeding programme used introduced varieties (IR64, IR50404), local varieties (Nang Huong, Tam Xoan, Tai Nguyen and Tep Hanh) and mutants (VND31, VND22-36) as genetic material to be induced with
mutations and combined with hybridization. After 5-6 years, the best mutants were released into production. Methodically, dry and germinated seeds were exposed to gamma rays of a $^{60}$Co source at the Nuclear Research Institute, Dalat city, Southern Vietnam. The doses of 200 and 300Gy were applied for seed treatments. Populations of 10,000 – 15,000 M$_n$ plants were established and evaluated from M$_n$ to M$_4$ generations. The best lines were tested, released and approved as temporary and national varieties by the Ministry of Agriculture & Rural Development (MARD).
**Development and production of mutant varieties**
IR64 is good quality variety but has a rather long duration, and is not suitable for the wet season. VND95-20 is a mutant variety derived from IR64. The variety inherited the main good characteristics of IR64 and added some desired characteristics through mutation.
VND95-20 was released into production & approved as a national variety by MARD in 1999. Since 2000, VND95-20 has been developed in 21 provinces over 280,000 – 350,000 ha per year. The variety is cultivated in Dong Thap, Long An, Tien Giang, Can Tho, Tra Vinh, An Giang, Vinh Long (Mekong River Delta), Dong Nai, Lam Dong, Tay Ninh, Baria-Vung Tau (East-Southern VN), Daklak and Gialai (Highland area). Recently, VND95-20 has been the key variety for production and export. Advantages of this mutant variety is short duration 90-100 days (7 days shorter than the original variety IR64), high adaptation and can be cultivated in diverse seasons and locations. Generally, mutant varieties are tolerant to intermediate acidic soil. This characteristic is very important because the acidic soil in the Mekong River Delta region covers more than 41% of the total cultivated land.
VND95-19 (another mutant from IR64) has high yielding potential (can yield 11 tons /ha), high tolerance to acidic soil and adverse conditions. The variety is resistant to Brown Plant Hopper (BPH) and Blast disease (BL), and is developed in several provinces: Soc Trang, Bac Lieu, Kien Giang, Dong Nai and the Highland area [4]. During 1997-2000 its cultivated area covered about 20,000ha per year. However, due to high chalkiness, the variety is only for domestic consumption.
VND99-3 is a mutant variety obtained from the Nang Huong variety, a local aromatic variety. The Nang Huong variety has long duration, low yield, photoperiodic sensitivity and is limited in production. VND99-3 was approved as a national variety in 2006. It is highly accepted due to having short duration (92-100 days), high tolerance to adverse conditions such as acid sulphate and drought conditions in Southern Vietnam. These improvements combined with iron toxicity tolerance, show that the mutant variety has inherited desirable traits from the parent local variety and shows similar characteristics or better than the original variety. Presently VND99-3 covers 15,000-18,000 ha per year of cultivated area in Southern Vietnam and continues to spread widely in Southern Vietnam [5].
TNDB100 is an induced mutation from the Tai Nguyen local variety, generated by gamma rays. The variety has very short duration (95-100 days), good quality, high yield (5-8t/ha) and intermediate tolerance to BPH and BL. TNDB100 was released by Cuu Long Delta Rice Research Institute (CLRRI) in 1997 and developed 50,000 ha/year during 2000 – 2005 [6].
VN121 is a new variety which was generated from mutation induction combined with hybridization. VN121 is widely accepted by farmers, because of its characteristic short duration, high yield, good quality (aroma, long grain, no chalkiness) and its tolerant to BPH, BL and GSV. The variety has been expanded in some Southern provinces: Tien Giang, Long An, Ba Ria - Vung Tau, Dong Nai, Tay Ninh & Dak Lak.
The VN124 variety has also been accepted for production due to its very short duration, aroma, good quality for export, tolerant to BPH, BL and GSV. The variety has been sharply expanded in Long An, Tay Ninh, Dong Nai and other provinces.
**Socio-economic and environment impacts**
**Socio - economic impacts**
Before 1995, in Southern Vietnam, many had thought that mutation breeding had very little hope and also that mutant varieties could not be stable in production. Through the developments of recent years, however, it has been proven that mutation breeding is a very good way to obtain novel varieties and that mutant varieties have a prolonged production life (more than ten years in the case of VND95-20). Nowadays, through practical approaches, many leaders and junior scientists have changed their doubtful thinking and have started to believe in the significant role of mutation breeding.
In general, mutation breeding has the advantage of saving 30% of the breeding programme time compared to hybridization techniques, especially in local varieties. While breeding new varieties takes 8-9 years or more, new varieties through mutation breeding takes only 5-6 years [7]. Mutation breeding is a very useful tool that can be applied in institutions that lack infrastructure such as green houses, field areas etc.
The rice mutation breeding programme of IAS and CLRRI have an annual budget of about 20,000 USD, so 300,000 USD from 1992 up to 2007. A quick calculation for the variety VND95-20 that is cultivated on average over an area of 250,000 ha (from 200,000-340,000 ha/year) x 8 years (from 1999 – 2007) x a yield of 6.0t/ha x 10% added return (in practical production it gets a higher yield than 10%) x 4 million VND/ton of rough rice (VND/t is price for ordinary paddy) gives us 4,800 billion VND (equivalent to 300 million USD). Exported rice is usually 20-25% higher in price than the ordinary domestic rice.
A similar calculation for VND99-3’s added return, 15,000 ha x 4 years x a yield of 6.0t/ha x 10% added return x 4 millions /t gives us 144 billion VND (equivalent to 9.0 million USD). In the case of the varieties like TNDB100, VND95-19, OM2717, OM2718, VN121 and VN124 the produced added return reaches 37.5, 6.0, 12.0, 8.4, 0.8 and 0.7 million USD, respectively (Table 1). Support from international programmes (IAEA and others) and investments in the rice project of the IAS and the CLRRI was about 400,000 USD. With an added return of 374.0 million USD from 8 mutant varieties in Southern Vietnam makes this project a very effective investment. For poor countries, the influx of money depends greatly on agricultural activities, at a significant level, particularly for farmers and rice exporters. These mutant varieties will continue to produce valuable return in coming years. For the past 8 years, the total sown area of the mutant varieties has been about 2.45 millions ha in Southern Vietnam.
Due to their high adaptation in large-scale production, different seasons and tolerance to adverse conditions, the mutant varieties were the main varieties selected in many national projects of “Eradicate hunger and alleviate poverty” programmes of the Vietnam Government in Southern Vietnam. These mutant varieties have contributed food security for the ethnic minorities such as Ragley, St’cieng, Nung, K’ho, Kh’me leading to better condition for forest protection in mountainous regions.
For example, the large number of Ragley ethnic people in the Khanh Dong hamlet, the Khanh Vinh district and the Khanh Hoa province usually have the conventional habit to collect forest products and exchange them for food as they do not know cultivation. Every year, the local government offers assistance for food and necessary items to the inhabitants, but it can not resolve the basic problem because hunger and poverty remain. To resolve the problem, we cooperated with local collaborators to conduct a project for technology transfer including the adoption of new rice varieties by the poor ethnic groups during 2003-2005. After 2 years into the project, ethnic people had cultivated VND95-20 and VND95-19 with high yield (6.4 t/ha) in comparison to other varieties that yielded only 4.4t/ha. Due to VND95-20’s high adaptation, and good quality, local people preferred to grow this variety for two crops per year. Consequently, local people escaped from hunger, poverty diminished
and deforestation stopped. Now they have a sustainable base to improve living conditions, beginning from having enough and surplus food.
Another example related to mutant rice varieties was the 2006-2007 outbreak of the Grassy Stunt Virus disease in the Southern areas, transmitted by Brown Plant Hopper. The Vietnam Government organized a campaign to mobilize different actions to control the pest. Our role was to transfer new tolerant varieties into production. In some provinces we supplied new varieties (including mutant as VND95-20, VND99-9, VN121 and VN124) and guided the production procedure in adverse conditions. As a result, in the Tay Ninh province and the Ben Cau district during the rainy season of 2007, the mutants yielded on average 5.1 t/ha compared to the local varieties that yielded only 4.1t/ha. Due to farmers having reduced insecticides, fertilizers and seed rate with a total spending reduction of 27.0% (about 175 USD/ha) in the production model of the mutant varieties, the added return from the use of mutants increased by 437.5 USD/ha over the concurrent ordinary varieties.
**Environmental impacts**
Mutant varieties have high tolerance to insects and diseases, so pesticides were applied two- to three-fold less during production in comparison to that for susceptible varieties. This not only saves investment capital and improves the safety of the rice products, but also strongly protects human and animal health.
**Economic impacts**
- Over the past 8 years, the total cultivated area of MRVs in Southern Vietnam has reached about 2.54 million ha.
- The mutant varieties contributed for production have produced added returns of (in millions USD): VND95-20 (300.0); VND 99-3 (9.0); TNDB 100 (37.5); VND95-19 (6.0); OM 2717 (12.0); OM 2718 (8.4); VND 121 (0.8) & VN124 (0.7).
- 8 mutant varieties contributed an added return of 374 million USD over the past years and will continue to provide valuable return for farmers in future crops.
- The new mutant varieties are tolerant to new diseases and insects, have replaced susceptible varieties and will continue to have a significant impact on sustainable rice cropping systems in the future.
**Innovative techniques of MRVs**
- Higher yield of more than 10% in comparison to control varieties.
- Very short growth duration: MRVs can be cultivated for 2-3 crops per year, escaping early flooding.
- Tolerance to adverse conditions, large adaptation allowing MRVs to be cultivated in different areas (acid soil, alluvial, affected salinity, wet season).
| No. | Mutant variety | The year of release | Cultivated area since release (ha) | Added return since release time (million USD) | Main superior characters |
|-----|----------------|---------------------|-----------------------------------|---------------------------------------------|--------------------------|
| 1 | VND95-20 | 1999 | 2,000,000 | 300 | Large-scale adaptation, good quality, Tolerant to acid soil, good plant type |
| 2 | VND 99-3 | 2004 | 60,000 | 9.0 | Good quality, short duration |
| 3 | TNDB100 | 1997 | 250,000 | 37.5 | Tolerant to acid soil, good plant type |
| 4 | VND95-19 | 1999 | 50,000 | 6.0 | Tolerant to acid soil, good plant type |
| 5 | OM2717 | 2004 | 100,000 | 12.0 | Tolerant to BPH, short duration |
| 6 | OM2718 | 2004 | 70,000 | 8.4 | Tolerant to BPH, short duration |
| 7 | VN121 | 2007 | 5000 | 0.8 | Aromatic, tolerant to BPH, GSV |
| 8 | VN124 | 2007 | 5000 | 0.7 | Aromatic, tolerant to BPH, GSV |
Prizes for achievement from mutant varieties in Southern Vietnam
Due to the significant contributions to socio-economic development, the development of mutant rice varieties has received many prizes by from national & local governments and they are as follows:
1. First prize and Second prize in the Technology Creative Competition in Ho Chi Minh City, 1998
2. 2 Gold medals in the Fair of “International Green Week” exhibition in Vietnam, 2000
3. 1 Golden Panicle Prize in the International Agriculture Fair organized in Can Tho, 1999
4. The National Prize on Science & Technology for Significant Contribution for Socio-economic issues of the country, 2005
5. Prizes for 30 Typical Science & Technology Achievements during the 30 years of the HCM City, 2005
6. The Golden Cup for Agriculture Products contributed to the country, National Agriculture Fair in 2006
7. The Creative Labor medal awarded by the Vietnam government, 2007
**Conclusion**
In brief focus, some significant impacts of the mutant rice varieties in Southern Vietnam are described below.
- Successful combination of aromatic characteristics with short duration, high yield, tolerant to diseases (BL, GSV & RSV) and insects (BPH).
- Shorter breeding times, reaching 30% reduction compared to hybridization methods.
- Confirmation that doses of gamma ray $^{60}$Co treatment induces high mutation.
**Socio–Environmental impacts**
- MRVs are resistant to insects & diseases: Two- to three-fold reduction of spraying times per crop, saves production investment capital and protects from pesticide over-usage.
- Contributed to the strategy programme of “Eradicate hunger and alleviate poverty” and “Deforestation reduction” of different national and local projects, particularly for the ethnic minorities in mountainous and remote areas.
**BIBLIOGRAPHY**
1. Statistical Publishing House. Statistical year book 2006, Socialist Republic of Vietnam, General Statistical Office, Ha Noi.
2. Ministry of Agriculture & Rural Development. Introduction of rice varieties and seeding times in Mekong Rive Delta, Agriculture Publishing House, HCM city, 2006.
3. Thinh Do Khac, Dao Minh So *et al.* Application of radiation mutation combined with hybridization to breed rice varieties having short duration, resistance to insects, diseases and high quality for export, Report in International conference on New Results of Rice Research organized by IRRI & CLRRI, 8 – September, 2007, Can Tho.
4. Thinh Do Khac, Hung Phi Oanh, Nguyen Thi Cuc *et al.* Improvement of introduced rice varieties through radiation induced mutation for cultivation in Southern Vietnam, reported at FAO/IAEA seminar on Mutation Techniques and Molecular Genetics for Tropical & Sub-tropical Plant Improvement in Asia / The Pacific region, Philippines, 11-15 Oct. 1999.
5. Thinh Do Khac, Dao Minh So, Truong Quoc Anh *et al.* Breeding & Development of Mutant Variety VND99-3 reported in Scientific Conference Ministry of Agriculture & RD, March 1–3, 2005 in Ho Chi Minh city.
6. Ro Pham Van, Two Promising Mutant Rice Varieties in Results of Scientific Research, 1977-1997, Institute of Cuu Long Delta Rice Research, Omon – Cantho, Vietnam, Pub. House of Agriculture 1998.
7. Thinh Do Khac *et al.*, Rice mutation Improvement for short growth duration, high yield and tolerance to adverse conditions in Mekong River Delta of Vietnam; reported at FAO/IAEA/RCA Strategic Meeting on Nuclear Techniques for Rice Improvement in Asia, 4-7 November 2004, Tokyo & Tsukuba, JAPAN.
|
Top 5 Considerations When Implementing an IDaaS Platform
# Top 5 Considerations When Implementing an IDaaS Platform
## Table of Contents
| Section | Page |
|------------------------------------------------------------------------|------|
| Introduction | 3 |
| A Transforming Workplace | 4 |
| 1. Digital Transformation | 4 |
| 2. IT Teams’ Need for Efficiency & Productivity | 4 |
| 3. Stolen Identities & Credentials | 6 |
| The Top 5 Considerations | 6 |
| 1. User Experience | 7 |
| 2. Security | 7 |
| 3. Self-Service & Automation | 8 |
| 4. Platform Management | 8 |
| 5. Compliance & Audit | 9 |
| IDaaS | 10 |
| 1. Introducing IDaaS | 10 |
| 2. Wallix Trustelem | 11 |
| Conclusion | 13 |
---
**Wallix**
Cybersecurity Simplified
INTRODUCTION
Digital transformation has changed the way we think about identity. A digital identity is, in many varied and complex ways, different from a physical one and comes with a unique set of challenges regarding identification – and security. With the events of 2020 sending the already growing trend of remote working into overdrive, IT teams have a bigger task than ever when it comes to accurately identifying who is accessing their corporate systems.
By May 2020, it was reported in Forbes that as many as half of all employed Americans were working from home\(^1\). And with the increasing use of external contractors and third-party service providers, more people than ever need remote access to corporate data.
Consider the identity and access challenges facing a hypothetical company operating in 2020. They likely have a mixture of permanent and 3rd party staff working from their physical office, from home or remote offices, and even other countries. On top of this, their staff will all need access to different applications depending on their role, which may change over time. Enrollment and unenrollment processes are complex as administrators manage ID turnover and evolutions. Employees come and go, and roles and access needs change.
The sheer number of people requiring access to a modern organization’s systems and applications make accurate identification paramount. And when time is money, both users and the companies they work for expect systems and access to be just as efficient from outside the office as within. Speed and agility are key in a constantly evolving digital work environment.
Security will always remain an indispensable consideration when discussing identity management. In 2019, 75% of cyberattacks were due to failures in Identity and Access Security practice\(^2\). 60% of cyberattacks exploit weak passwords and credentials. Simplifying access to corporate applications necessitates securing the user identities accessing them.
With the boom in diversity among digital identities accessing corporate data and applications, a robust and secure Identity and Access Security framework has never been more important.
---
1. https://www.forbes.com/sites/johnkoetsier/2020/03/20/58-of-american-knowledge-workers-are-now-working-remotely/#23c536153303
2. https://enterprise.verizon.com/resources/reports/dbir/
A Transforming Workplace
1. Digital Transformation
Return to the hypothetical company. In 2000, employees would access corporate data from within the office on company hardware protected by a firewall. The IT team had on-site visibility over who was logging into corporate systems within the office, and complete control over the hardware and software that employees used.
Today, things are more complex. In 2020, employees may be based anywhere, and internal mobility means roles and access requirements are always changing. At the same time, people expect access to corporate data quickly and easily via systems and applications which run the gamut from clunky, legacy in-house software to the latest modern cloud-based platforms.
Adding complexity to the pursuit of identity management is that data and applications are increasingly being accessed through cloud-based applications. SaaS applications offer ease and flexibility for users as well as cost-savings for businesses. However, as businesses take on more SaaS applications and move operations to the cloud, there are more instances where identity needs to be verified.
For employees, it can get confusing to juggle multiple logins for an ever-widening array of cloud-based and on-premise applications. For IT teams, this headache is multiplied even further, as they need to consider every password for every app for every person. The result is a massive risk surface, and the likelihood of a compromised password starts looking like an inevitability rather than a possibility.
In effect, the traditional security perimeters have been scattered far and wide and across a heterogenous (and growing) set of corporate applications. Remote access is here to stay with the digital transformation, and keeping track of a geographically dispersed workforce brings a whole new dimension to identity management where access, interoperability, and mobility intersect.
2. IT Teams’ Need for Efficiency and Productivity
The increase in digital identities across a multiplicity of cloud-based and in-house applications becoming too much for the IT team to manage is a strong motivator for implementing an IDaaS solution. The right identity management platform can consolidate multiple active directories, manage users’ rights and access for all applications, simplify provisioning and de-provisioning, streamline connections for users, and offer visibility over usage.
With an increasingly diverse – and evolving – set of users at hand, IT administrators’ bandwidth is
The increase in digital identities across a multiplicity of cloud-based and in-house applications becoming too much for the IT team to manage is a strong motivator for implementing an IDaaS solution.
quickly consumed by onboarding new users, assigning access rights, removing access to no-longer needed platforms, removing users, updating access as roles change, and doing all this for 3, 4, or a dozen applications which may vary according to profile. Simplifying these time-consuming tasks is a key driver of IDaaS implementation. Not to mention the time and hassle for users with logins and passwords for dozens of applications.
And yet, there is a key balance that needs to be struck between simplicity and security. The Identity and Access Security solution needs to be simple and provide an effective but safe user experience for IT teams and end-users alike to effectively streamline identity management and eliminate the hassle of login credentials for a multitude of applications.
3. Stolen Identities & Credentials
According to Verizon’s 2020 Data Breach Investigations Report (DBIR), 22% of breaches in 2019 involved phishing. They also reported that hackers are relying more heavily on the credentials stolen via phishing attacks to access sensitive systems and data. In other words, fraudulent identification. Over 80% of data breaches come from stolen, default, or weak passwords. This is hardly surprising when over 21% of people have 10+ year old passwords – and it only takes 20 milliseconds to crack a 7-character password.
With more people accessing corporate data, the risk of data breaches has never been higher. According to IBM’s 2020 Cost of a Data Breach Report, the average cost per compromised record has steadily increased over the last three years. Now, the total average breach costs organizations $3.92 million.
On top of the financial and reputational damage caused by a breach, organizations can find themselves in violation of increasingly strict regulations. Privacy regulations like the EU’s GDPR are easy to violate if access and identity are handled incorrectly – manual, error-prone systems simply won’t cut it. And with stolen credentials, lateral moves across the network provide access to any amount of sensitive data which should be protected.
Finding an Identity Management solution is critical to the efficiency, security, and compliance of the entire organization in the face of modern, digital transformation challenges.
The Top 5 Considerations
With an Identity and Access Security solution in place, the time, effort, and cost of managing access is decreased. In addition, the risks of external and internal data breaches are greatly reduced. This can provide peace of mind when it comes to regulatory compliance, and significant return on investment. Identity management solutions enforce best practices in password and identity management and mitigate the risk of insider threat by protecting user access to corporate systems. And they can do all of this while maintaining ease-of-use for the end-user. The key is for businesses to embrace an IDaaS – Identity-as-a-Service – solution with a zero-trust
framework and SSO and MFA technologies to render a complex issue simple. So, what are the main concerns to consider when selecting the right IDaaS solution?
1. **User Experience**
First and foremost, an Identity and Access Security solution should provide a seamless user experience. It should centralize and simplify connections to everyday corporate applications to make users’ lives easier. If connecting to resources is complicated, hampering efficiency or daily workflows, users will look for loopholes. From a user’s perspective, remembering multiple passwords for multiple applications and having to regularly change them can be frustrating, which often leads to bad password hygiene and, ultimately, security vulnerabilities.
Authentication is important, but making employees go through it every time they need to use an application can impact productivity. A single-sign-on (SSO) solution, where users can verify their identity once and gain access to several related systems, is ideal. SSO means users no longer need to remember multiple sets of log-in details, nor do they have to log in repeatedly. With the proliferation of SaaS and cloud-based apps, this saves a user having to go through a separate authentication process every time they need to accomplish a basic work task.
Using SSO within an Identity and Access Security framework dramatically simplifies employees’ workflows and improves productivity. Thanks to the Single-Sign On solution, all corporate applications are successfully centralized into one, unique entry point. Highly convenient for the user, but not so secure for the organization as it also centralizes security risk into one, significant vulnerability.
2. **Security**
Once centralized, securing this one, singular access point becomes paramount. Simplicity and user experience are great – but only if security is kept to the same high standard. Multi-factor Authentication (MFA) enables heightened security without impeding the SSO’s simplicity. When a user logs in and attempts to access multiple applications, accurate authentication is key. The best way to do this is through two-factor (2FA) or MFA. Adding additional factors on top of a basic username/password combination can provide an organization with a high level of certainty of a user’s identity.
The combination of multiple forms of identification verification ensures the highest level of confidence that a user is who they claim to be. Using a combination of factors from different “families” of factors is the most secure way of authenticating digital identity:
- **Something you know:**
- The most common form of authentication, typically a password or pin code. This is never enough to authenticate a remote user and should be combined with at least one other factor.
• **Something you have:**
This involves an item that a user has that is unique to them. For example, a notification generated by a mobile phone app or a one-time password (OTP) generated by a physical or digital token.
• **Something you are:**
Biometrics are part of a person’s physical identity and offer a powerfully unique form of authentication. Examples include fingerprints, face ID, and even voice recognition.
This extra step of authentication can, however, be balanced to facilitate user experience. Context can be leveraged to decide on the best way to identify users. For example, workers in the office may just need their password, but remote workers outside the corporate network might need a token to fully access their applications. This is known as contextual authentication, where the number and level of authentications required can be adapted to the situation and nature of the application.
3. **Self-Service & Automation**
Self-service via web portals enables users to register themselves for application access, create accounts and passwords, and recover lost credentials. Additional self-service capabilities include:
- Profile management
- Password management
- JIT Provisioning & Deprovisioning
A self-service portal means users are not waiting around for support when their passwords need to be reset. They’re able to sort it out for themselves, quickly and securely. In turn, this also saves IT teams time and effort, as they won’t end up overwhelmed with such a commonly occurring user request. For a business, this leads to savings in both time and money.
It’s vital that modern organizations are transparent about their data practices and are able to give users control over their own data. This is something else that can be made possible through secure and easy-to-use self-service account management.
With the right solution, not only are users able to help themselves, but provisioning can be handled automatically, as well. When a new user is added to the directory, access to key applications can be automatically provisioned, according to their role and needs. And when a user requests access to a new application, the IDaaS solution will analyze their role and create the appropriate access or generate an approval workflow for validation.
Provisioning – and deprovisioning – are critical but tedious, time-consuming tasks for IT administrators. Centralizing not only corporate applications access but also user management can have great benefits as users constantly arrive, depart, and change roles and access needs.
4. **Platform Management**
Identity-as-a-Service solutions make things simple for IT teams. It gives them a centralized and secure
system to keep track of all access, permissions, and users. Organizations can integrate IDaaS solutions with their existing infrastructure and directories so that the right authorizations are applied to the right users. They can also customize identity control with their own authentication policies and access rules, and script their own security behaviors.
When staff and technology change over time, identities and access can be flexibly managed as users move through their ‘lifecycle’, by allowing for users to be easily added, removed, or amended via one centralized platform for an entire web of applications. Centralizing Active Directory, LDAP, and other directory sources to funnel into one aggregated solution greatly simplifies the work of IT teams. Digital identities and access can be monitored and changed as employees join, leave, and move roles within the organization, assigning appropriate permissions to any number of in-house, legacy, or cloud-based applications via an array of standard protocols. This eliminates ‘privilege creep’, where people accumulate rights and privileges as they move around within a company. Or worse, when ex-employees still retain access to sensitive corporate data.
The most effective IDaaS solutions are easy for IT admins to manage and agile in an evolving context. If the administration of the system is complicated or spread across several different resources, it won’t be as effective. This idea applies to the end-user experience too.
5. Compliance & Audit
Knowing who has access to which services and systems is a key requirement of many cybersecurity and data privacy regulations. A centralized solution makes it simple to respond to auditors who need to know who has access to your corporate applications and data. And knowing how corporate applications are used – or not used – down to individual user accounts enables IT teams to better manage costs and improve the ROI of the services they enlist.
A robust IDaaS solution delivers complete and thorough oversight of precisely which users have access to which applications, and with what level of privileges they are able to access to these platforms. With government and industry-level cybersecurity and privacy regulations requiring high standards of access management, it becomes imperative to control and enforce governance policies – and offer proof of compliance when
necessary. Integrating a solution with a SIEM solution can provide clear visualization and analysis of rich user access activity data.
Regulators are not the only ones to benefit from audit capabilities. With hundreds or thousands or more users each with access to a multitude of applications, IT teams struggle to maintain visibility over their budget, costs, and usage. IDaaS systems generate valuable data (i.e., logging events and reporting on which users accessed what information and when) to better understand, monitor, and improve identity management and access provisioning. Centralized identity management crossed with detailed logs empower administrators to optimize their costs, reduce waste where licenses are unused, and better attribute resources where they’re needed most.
* Bonus: High Availability & Performance
Like any SaaS solution, it’s important to consider the platform’s stability. When an entire organization’s operations are depending on access to corporate applications, high availability is mandatory and performance is more important than ever. To optimize centralization and management, the system needs to be reliable, stable and secure. Otherwise, even a couple of hours of downtime could result in chaos across an organization.
Considering the service level agreement offered by an IDaaS provider is an important step in choosing the best solution. What level of platform availability and stability does the solution commit to? What should you expect in terms of recovery time in case of platform failure or downtime? What is the organization’s track record of platform uptime and performance?
The right provider should guarantee service recovery and data recovery within 24 hours or less, a service level to which they can be held accountable in the event of an outage. Cloud-based solutions, known for their scalability and flexibility, should also commit to near-perfect uptime, allowing the system to be down for a maximum of just a few hours across an entire year. These guarantees ensure that corporate applications and operations can continue seamlessly.
**IDaaS**
Organizations might be keen to experience the benefits of identity management for a variety of reasons as their digital transformation advances. Identity-as-a-Service solutions deliver simple, secure identity management to improve and streamline both user experience and IT administration.
1. **Introducing IDaaS**
Identity as a service (IDaaS) offers identity and access security functions as a cloud-based application. This allows all users, whether internal employees, remote workers, or third-party providers to connect easily and securely to company applications. Essentially, it’s Identity and Access Security delivered as SaaS. For many
businesses, IDaaS offers the perfect way to get effective and secure Identity and Access Security up and running.
The essential identity management capabilities a business needs are covered by IDaaS:
- Directory management
- Identity federation
- Single-Sign-On (SSO)
- Multi-Factor Authentication (MFA)
- Contextual authentication
- Self-service account management
- Audit
With hardware, network, development, and expertise costs to consider, maintaining in-house identity management systems can be a major investment. IDaaS solutions on the other hand, deliver critical Identity and Access Security capabilities with the flexibility and simplicity of a cloud-based application.
It can also handle more advanced capabilities. For example, IDaaS systems can collect intelligence (i.e., logging events and reporting on which users accessed what information and when) to better understand, monitor, and improve identity management and access provisioning.
Crucially for time and resource-pressed IT teams, an IDaaS solution can be easily integrated with an organization’s existing infrastructure and workflows. It offers secure collaboration with 3rd party contractors thanks to directory integration capabilities, plus easy integration with pre-defined secure access rules. IDaaS can also greatly reduce an organization’s Capex and Opex investments when compared to building an in-house Identity and Access Security solution.
Choosing the right IDaaS provider is important. A business needs to be sure the provider they are choosing embodies the key components of Identity and Access Security: simplicity and security.
2. WALLIX Trustelem
WALLIX Trustelem is an IDaaS Service platform offering simple and secure identity management. WALLIX Trustelem centralizes and manages identities from Active Directory and other sources, and federates identity and access permissions to all corporate applications via standard protocols. With both single-sign on and multi-factor authentication, WALLIX Trustelem takes care of identity management simply and securely, allowing corporate applications (both in-house and cloud-based) to simply be service providers.
WALLIX Trustelem protects company assets and data, and blocks attacks by strengthening identity and access security. This reduces the attack surface available to hackers using phishing or social engineering. In turn, this leads to better compliance with security regulations.
In addition, Trustelem unifies, secures, and simplifies user access to applications, and streamlines identity management for IT admins. It offers centralized authentication for applications and efficient admin tools to facilitate user
experience and security for all. The centralization of Identity and Access Security is invaluable, enabling organizations to:
• **Connect different sources of identity** and synchronize Active Directories with Trustelem AD Connect
• **Simplify user access** through SSO connections and identity federation
• **Increase efficiency** through the centralized implementation of access control policies on user groups
• **Simplify the management of access to applications** from both internal employees and third parties
• **Apply secure and contextual authentication** to protect corporate assets
• **Save budget** by reducing the time-consuming task of manual, dispersed identity management and associated support costs
• **Improve control and awareness of application usage and access** to regulate costs and licensing
Conclusion
The digital transformation represents a continuous and increasing shift in the way organizations work. With advances in technologies, an expanding array of cloud-based applications, and employees connecting to corporate assets remotely, organizations need a solution to manage identities safely. WALLIX Trustelem secures the digital transformation, centralizing and streamlining access to company applications for users and simplifying administration for IT teams.
When looking to implement an Identity-as-a-Service solution, simplicity and security are key. WALLIX Trustelem offers best-of-breed identity and access security for a secure digital future.
WALLIX Group is a cybersecurity software vendor dedicated to defending and fostering organizations’ success and renown against the cyberthreats they are facing. For over a decade, WALLIX has strived to protect companies, public organizations, as well as service providers’ most critical IT and strategic assets against data breaches, making it the European expert in Privileged Access Management.
WWW.WALLIX.COM
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Constraint-Based Type Inference for Guarded Algebraic Data Types
Vincent Simonet, François Pottier
To cite this version:
Vincent Simonet, François Pottier. Constraint-Based Type Inference for Guarded Algebraic Data Types. [Research Report] RR-5462, INRIA. 2005, pp.65. <inria-00070544>
Constraint-Based Type Inference for Guarded Algebraic Data Types
Vincent Simonet — François Pottier
N° 5462
Janvier 2005
Thème SYM
Rapport de recherche
Constraint-Based Type Inference for Guarded Algebraic Data Types
Vincent Simonet, François Pottier
Thème SYM — Systèmes symboliques
Projet Cristal
Rapport de recherche n° 5462 — Janvier 2005 — 65 pages
Abstract: Guarded algebraic data types subsume the concepts known in the literature as indexed types, guarded recursive datatype constructors, and first-class phantom types, and are closely related to inductive types. They have the distinguishing feature that, when typechecking a function defined by cases, every branch may be checked under different assumptions about the type variables in scope. This mechanism allows exploiting the presence of dynamic tests in the code to produce extra static type information.
We propose an extension of the constraint-based type system HM(X) with deep pattern matching, guarded algebraic data types, and polymorphic recursion. We prove that the type system is sound and that, provided recursive function definitions carry a type annotation, type inference may be reduced to constraint solving. Then, because solving arbitrary constraints is expensive, we further restrict the form of type annotations and prove that this allows producing so-called tractable constraints. Last, in the specific setting of equality, we explain how to solve tractable constraints.
To the best of our knowledge, this is the first generic and comprehensive account of type inference in the presence of guarded algebraic data types.
Key-words: guarded algebraic data types, typechecking, constraints, pattern matching, type inference
Inférence de types à base de contraintes pour les types de données algébriques gardés
Résumé : Les types de données algébriques gardés généralisent les concepts connus dans la littérature sous les noms de types indexés, constructeurs de types de données récursifs gardés et types fantômes de première classe, et sont intimement liés aux types inductifs. Ils ont pour trait caractéristique le fait que, lors du typage d'une fonction définie par cas, chaque branche peut être typée sous des hypothèses différentes à propos des variables de types connues. Ce mécanisme permet d'exploiter la présence de tests dynamiques dans le code pour produire une information de typage statique supplémentaire.
Nous proposons une extension du système de types à base de contraintes HM(X) avec filtrage profond, types de données algébriques gardés et récursivité polymorphe. Nous démontrons que ce système de types est sûr et que, pourvu que les définitions de fonctions récursives soient annotées par un schéma de types, l'inférence de types se réduit à la résolution de contraintes. Ensuite, parce que la résolution de contraintes arbitraires est coûteuse, nous restreignons la forme des annotations autorisées et démontrons que cela permet de produire des contraintes dites gérables. Enfin, dans le cas particulier de l'égalité, nous expliquons comment résoudre les contraintes gérables.
À notre connaissance, ceci est le premier traité générique et exhaustif de l'inférence de types en présence de types de données algébriques gardés.
Mots-clés : types de données algébriques gardés, typage, contraintes, filtrage, inférence de types
1 Introduction
Programming languages in the ML family are equipped with algebraic data types and with pattern matching, which provide high-level facilities for defining and manipulating data structures. They also have type inference in the style of Hindley (1969) and Milner (1978), keeping mandatory type annotations to a minimum. The purpose of the present paper is to conservatively extend these languages with guarded algebraic data types. Type inference should be preserved: while programs that exploit guarded algebraic data types may require some type annotations, existing ML programs must not. In fact, for much greater generality, we extend not only ML, but the generic constraint-based type system HM(X) (Odersky et al., 1999).
This introduction begins with a description of guarded algebraic data types (§1.1) and a review of some of their applications (§1.2), provides some details about our approach and a comparison with related work (§1.3), and ends with an outline of the paper (§1.4).
1.1 From algebraic data types to guarded algebraic data types
Let us first recall how algebraic data types are defined, and explain the more general notion of guarded algebraic data types.
Algebraic data types Let \( \varepsilon \) be an algebraic data type, parameterized by a vector of distinct type variables \( \bar{\alpha} \). Let \( K \) be one of the data constructors associated with \( \varepsilon \). The (closed) type scheme assigned to \( K \), which may be derived from the declaration of \( \varepsilon \), must be of the form
\[
K :: \forall \bar{\alpha}. \tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha}),
\]
(1)
where \( n \) is the arity of \( K \). Then, the typing discipline for pattern matching may be summed up as follows: if the pattern \( K x_1 \cdots x_n \) matches a value of type \( \varepsilon(\bar{\alpha}) \), then the variable \( x_i \) becomes bound to a value of type \( \tau_i \).
For instance, an algebraic data type \( \text{tree}(\alpha) \), describing binary trees whose internal nodes are labeled with values of type \( \alpha \), might consist of the following data constructors:
\[
\begin{align*}
\text{Leaf} & :: \forall \alpha. \text{tree}(\alpha), \\
\text{Node} & :: \forall \alpha. \text{tree}(\alpha) \cdot \alpha \cdot \text{tree}(\alpha) \rightarrow \text{tree}(\alpha).
\end{align*}
\]
The arities of \( \text{Leaf} \) and \( \text{Node} \) are respectively 0 and 3 (we use the symbol \( \cdot \) to separate the types of constructor’s arguments). Matching a value of type \( \text{tree}(\alpha) \) against the pattern \( \text{Leaf} \) binds no variables. Matching such a value against the pattern \( \text{Node}(l, v, r) \) binds the variables \( l, v, \) and \( r \) to values of types \( \text{tree}(\alpha), \alpha, \) and \( \text{tree}(\alpha) \), respectively.
Läuger-Odersky-style existential types It is possible to imagine extensions of ML that allow more liberal forms of algebraic data type declarations. Consider, for instance, Läuger and Odersky’s extension of ML with existential types (1994). There, the type scheme associated with a data constructor may be of the form
\[
K :: \forall \bar{\alpha}.\bar{\beta}. \tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha}).
\]
(2)
The novelty resides in the fact that the argument types \( \tau_1 \cdots \tau_n \) may contain type variables, namely \( \bar{\beta} \), that are not parameters of the algebraic data type constructor \( \varepsilon \). Then, the typing discipline
for pattern matching becomes: if the pattern $K\,x_1 \cdots x_n$ matches a value of type $\varepsilon(\bar{\alpha})$, then there exist unknown types $\bar{\beta}$ such that the variable $x_i$ becomes bound to a value of type $\tau_i$.
For instance, an algebraic data type key, describing pairs of a key and a function from keys to integers, where the type of keys remains abstract, might be declared as follows:
$$Key :: \forall \beta.\beta \cdot (\beta \rightarrow int) \rightarrow key.$$
The values $Key(3,\lambda x.5)$ and $Key((1;2;3),length)$ both have type $key$. Matching either of them against the pattern $Key(v,f)$ binds the variables $v$ and $f$ to values of type $\beta$ and $\beta \rightarrow int$, for a fresh $\beta$, which allows, say, evaluating $(f\,v)$, but prevents viewing $v$ as an integer or as a list of integers—either of which would be unsafe.
**Guarded algebraic data types** Let us now go one step further by allowing data constructors to be assigned constrained type schemes:
$$K :: \forall \bar{\alpha}\bar{\beta}[D].\tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha}). \quad (3)$$
Here, $D$ is a constraint, that is, a first-order formula built out of a fixed set of predicates on types. The value $K(v_1, \ldots, v_n)$, where every $v_i$ has type $\tau_i$, is well-typed, and has type $\varepsilon(\bar{\alpha})$, only if the type variables $\bar{\alpha}\bar{\beta}$ satisfy the constraint $D$. In exchange for this restricted construction rule, the typing discipline for destruction—that is, pattern matching—becomes more flexible: if the pattern $K\,x_1 \cdots x_n$ matches a value of type $\varepsilon(\bar{\alpha})$, then there exist unknown types $\bar{\beta}$ that satisfy $D$ such that the variable $x_i$ becomes bound to a value of type $\tau_i$. Thus, the success of a dynamic test, namely pattern matching, now allows extra static type information, expressed by $D$, to be recovered within the scope of a branch. We defer a more concrete illustration of this mechanism to §2. We refer to this flavor of algebraic data types as guarded, because their data constructors have guarded (constrained) type schemes.
### 1.2 Applications of guarded algebraic data types
Guarded algebraic data types are a fairly general concept. This is due, in particular, to the fact that the constraint language in which $D$ is expressed is not fixed a priori. On the contrary, many choices are possible; let us suggest a few.
**Unification** In the simplest case, $D$ must be a unification constraint, that is, a conjunction of type equations. Then, the data constructors associated with guarded algebraic data types may in fact be assigned type schemes of the form
$$K :: \forall \bar{\beta}.\tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\tau}). \quad (4)$$
In this form, no constraint is specified, but the type constructor $\varepsilon$ may be applied to a vector of arbitrary types, rather than to a vector of distinct type variables $\bar{\alpha}$. It is not difficult to check that the forms (3) and (4) are equivalent. On the one hand, a declaration of the form (4) may be written
$$K :: \forall \bar{\alpha}\bar{\beta}[\bar{\alpha} = \bar{\tau}].\tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha}),$$
an instance of (3). Conversely, because every satisfiable unification constraint admits a most general unifier, a declaration of the form (3) either has no instance (making $K$ inapplicable, a pathological case) or may be written under the form (4); we omit the details.
We sometimes refer to data types introduced by declarations of the form (4) as *inductive types* because they are strongly reminiscent of those found in the Calculus of Inductive Constructions (Paulin-Mohring, 1992; Werner, 1994). (The only difference lies in the fact that true inductive types come with a positivity restriction, which ensures logical consistency, whereas, in a programming-language setting, no such restriction is necessary.) They are also referred to as *guarded recursive datatype constructors* by Xi et al. (2003) and as *first-class phantom types* by Cheney and Hinze (2003). An instance of this mechanism was earlier proposed by Crary, Weirich and Morrisett (2002). A basic example of their use is given in §2.1.
**Arithmetic**
Assume that, in addition to type equations, the constraint language contains a decidable fragment of first-order arithmetic, such as Presburger arithmetic. Then, constraints contain variables of two kinds: variables of the first kind stand for types, while variables of the second kind stand for integers. In such a setting, guarded algebraic data types are of great interest.
For instance, one may declare the type of integers, $\text{int}$, as a unary guarded algebraic data type constructor, whose parameter is of integer kind, and whose data constructors are the integer constants:
$$k :: \forall \alpha [\alpha = k].\text{int}(\alpha) \quad (k \in \mathbb{Z})$$
This is usually known as a *singleton type*, because only the data constructor $k$ has type $\text{int}(k)$.
**Remark 1.1.** One should note that, although it is pleasant to view $\text{int}$ as an algebraic data type, this only leads us half of the way. Indeed, because pattern matching for algebraic data types only allows matching an unknown term against a *fixed* pattern, it only allows encoding equality tests between an integer variable and a constant. Ordering comparisons, or comparisons between two integer variables, still require a special-purpose extension of the programming language. A similar remark applies to the singleton type constructor $\text{level}$ in §2.3, where ordering comparisons between two level variables are needed.
In the present paper, we only deal with the usual notion of pattern matching for algebraic data types, and do not consider these additional elimination constructs for singleton types. The basic typechecking and type inference techniques that they require are the same. ◊
To go further, one may declare the type of lists, $\text{list}$, as a binary guarded algebraic data type constructor, whose parameters are respectively of type and integer kinds:
$$\begin{align*}
Nil &:: \forall \alpha \beta [\beta = 0].\text{list}(\alpha, \beta) \\
Cons &:: \forall \alpha \beta_1 \beta_2 [1 + \beta_1 = \beta_2].\alpha \cdot (\text{list}(\alpha, \beta_1)) \rightarrow \text{list}(\alpha, \beta_2)
\end{align*}$$
The idea is that, while the parameter $\alpha$ is the type of the elements of the list, the parameter $\beta$ reflects the length of the list, so that only lists of length $k$ have type $\text{list}(\tau, k)$. Type systems that allow dealing with lists in this manner include Zenger’s *indexed types* (Zenger, 1997, 1998) as well as Xi and Pfenning’s so-called *dependent types* (Xi, 1998; Xi and Pfenning, 1999). Both are constraint-based type systems, where typechecking relies on the decidability of constraint entailment, as opposed to true dependent type systems, where typechecking involves deciding *term* equality. The use of indexed types is further illustrated in §2.2.
Subtyping Guarded algebraic data types subsume the guarded existential types studied by the first author (Simonet, 2003a) with information flow analysis in mind. In this case, types contain atomic security levels, which belong to a fixed lattice, and induce a structural subtyping relation. More details are given in §2.3.
1.3 Extending ML with guarded algebraic data types
We have tried to convince the reader that guarded algebraic data types are a very general notion and subsume several existing type-theoretic mechanisms. Their usefulness is two-fold. On the one hand, increasing the expressiveness of the type system means accepting more programs, thus making new programming idioms available; see, for instance, how inductive types are put to use (Xi et al., 2003; Cheney and Hinze, 2003; Pottier and Gauthier, 2004). On the other hand, it also allows more precise type specifications to be written, thus rejecting some (safe, but incorrect) programs, in the spirit of refinement types (Freeman and Pfenning, 1991; Zenger, 1997, 1998; Xi, 1998; Xi and Pfenning, 1999). Thus, it is tempting to augment ML with guarded algebraic data types, and to do so in a generic fashion, so that all of the applications mentioned in §1.2 become instances of a common framework. This is the purpose of the present paper.
One must be careful, however, not to pursue contradictory goals. On the one hand, inductive types form a strict extension of ML, in the sense that every well-typed ML program remains well-typed in their presence, and some new programs become well-typed. On the other hand, refinement types refine ML, in the sense that every program that is well-typed in their presence is a well-typed ML program in the first place. These properties are mutually exclusive. Because we aim to include inductive types, we must aim for a strict extension of ML. As a result, although our type system also includes indexed types in the style of Zenger and dependent types in the style of Xi and Pfenning, it does not refine ML in the above sense.
In the next few paragraphs, we give more details about this issue and motivate our work by comparing it with related efforts.
In Zenger’s work (1997; 1998), there is an important distinction between indices, which are taken from some abstract domain, and types, which are first-order terms that carry indices. The logical interpretation of constraints is defined in a careful way, so as to ensure that the type system restricts ML. More specifically, with every constraint, Zenger associates two interpretations (Zenger, 1998, Definition 19). The former tells whether the constraint is satisfied, as usual, while the latter tells whether it is structurally consistent, that is, roughly speaking, whether it would be satisfied if all indices were erased. The former depends on the latter, as follows: for an implication $C_1 \Rightarrow C_2$ to be satisfied, not only must the satisfaction of $C_1$ imply that of $C_2$, as usual, but also must the constraint $C_2$ be structurally consistent, regardless of whether $C_1$ is satisfied. As a result of this definition, a constraint of the form $C \Rightarrow \alpha_1 = list(\alpha_2, \beta)$ is equivalent to $\exists \alpha'_2 \beta' (\alpha_1 = list(\alpha'_2, \beta') \land C \Rightarrow (\alpha_2 = \alpha'_2 \land \beta = \beta'))$—that is, $\alpha_1$ must be a list, regardless of whether $C_1$ is satisfied.
In the present paper, we cannot follow Zenger’s approach, because inductive types, as described above, require implication to be interpreted in a standard way. Indeed, in the setting of inductive types, there are no indices: we are dealing with equations between standard ML types. Thus, Zenger’s interpretation of implication would equate $C_1 \Rightarrow C_2$ with $C_2$, effectively disallowing the use of implication and making guarded algebraic data types useless. For instance, in the case of print (§2.1), the two branches would unconditionally be required to produce values of the same
type, leading to a type error, exactly as in ML. For this reason, we adopt a standard interpretation of implication, and employ constraint solving algorithms that must differ from Zenger’s. As a result, our type system is not a refinement type system—that is, it does not restrict ML; in fact, it extends it. Every program that is well-typed in Zenger’s system is also well-typed in ours, with the same type; however, we accept more programs, because of our more liberal interpretation of implication.
Some other differences between Zenger’s work and ours is that Zenger does not allow subtyping or nested patterns, while we suppress these restrictions. In spite of these differences, Zenger’s work remains very close in spirit to ours: in particular, type inference is reduced to constraint solving.
The type system DML(C) (Xi, 1998; Xi and Pfenning, 1999), which was developed independently, is a close cousin of Zenger’s. It entertains a similar distinction between indices and types, and interprets implication in a similar manner (Xi, 1998, Section 4.1.1), so as to refine ML. Its implementation, Dependent ML (Xi, 2001), includes a type inference process, known as elaboration (Xi, 1998, Section 4.2). Because Dependent ML features first-class universal and existential types, the elaboration algorithm isn’t an extension of ML’s type inference algorithm. Instead, it is bidirectional: it alternates between type verification and type synthesis phases. For this reason, some well-typed ML programs appear to require extra type annotations before they can be accepted by Dependent ML. One may view this fact as a misfeature. Like Zenger’s, Xi’s elaboration algorithm does, in the end, produce a constraint, whose satisfiability must then be determined.
Previous accounts of guarded algebraic data types are written with type checking, as opposed to type inference, in mind. This includes Cheney and Hinze’s (2003), Xi et al.’s (2003), as well as Xi’s applied type system (2004). The latter, which was written concurrently with the present paper, is nevertheless interesting, because of its generality: it removes the distinction between indices and types, and keeps only (multiple sorts of) types; furthermore, it is parameterized with an arbitrary (decidable) constraint domain. These are also features of the type system presented in this paper.
To sum up, we are interested in extending ML with a general form of guarded algebraic data types, so as to encompass all of the applications described in §1.2 in a single, abstract framework. Furthermore, we aim to extend ML’s type inference discipline in a conservative manner, so that existing ML programs remain well-typed without requiring extra type annotations. To achieve these goals, we start with the generic type system HM(X) (Odersky et al., 1999), a constraint-based extension of ML, which in fact coincides with ML when constraints are made up of type equations only. We enrich HM(X) with guarded algebraic data types, pattern matching, and polymorphic recursion, and refer to this extension as HMG(X). Type inference for HMG(X) is reduced to constraint solving in such a way that, for programs that do not involve guarded algebraic data types, constraint generation is entirely standard.
In contrast with DML(C) (Xi, 1998; Xi and Pfenning, 1999), HMG(X) does not have first-class existential or universal types with implicit introduction and elimination forms. HMG(X) does have first-class existential types, since they can be encoded using guarded algebraic data types (§1.1). However, in this encoding, creating an existential package amounts to applying a data constructor, while opening it amounts to performing case analysis; both operations must be made explicit in the program. First-class universal types with explicit introduction and elimination forms could be added to HMG(X) in the same manner; see, for instance, Rémy (1994), Jones (1995), Odersky and Läuger (1996), or Simonet (2003a).
1.4 Road map
The paper is laid out as follows. We first illustrate several instances of $\text{HMG}(X)$, namely: inductive types (§2.1), indexed types (§2.2), and dynamic security levels (§2.3) in the context of an information flow analysis—a novel application, which involves structural subtyping. Our formal development begins with a presentation of the untyped calculus, a call-by-value $\lambda$-calculus featuring data constructors and pattern matching (§3). We then define the type system $\text{HMG}(X)$, and establish subject reduction and progress theorems (§4). The constraint-based nature of the system makes it easy to reason about type inference: we show that, provided recursive function definitions carry a type annotation, type inference may be reduced to constraint solving (§5). Then, because solving arbitrary constraints is expensive, we further restrict the form of type annotations and prove that this allows producing so-called tractable constraints (§6.1). Last, in the specific setting of equality, we explain how to solve tractable constraints (§6.2).
2 Examples
We now give concrete program fragments that are well-typed in several distinct instances of $\text{HMG}(X)$, obtained by specializing the constraint logic $X$. This highlights the usefulness and versatility of guarded algebraic data types. All program fragments but one (\texttt{rmap\_f} in §2.2) carry sufficient type annotations to be accepted by the type inference algorithm of §6. The syntax of our examples mimics that of Objective Caml (Leroy et al., 2004). We assume that a few standard library functions, such as \texttt{print\_int} and \texttt{print\_string}, are available.
2.1 Inductive types
We first illustrate how \textit{inductive types}, introduced by Xi et al. under the name \textit{guarded recursive datatypes} (Xi et al., 2003), are dealt with in $\text{HMG}(X)$. Here, types are interpreted as finite trees, and constraints are \textit{type equations}, as in constraint-based presentations of ML. We assume that the type constructors for integers and (binary) pairs, \texttt{int} and $\times$, are declared as in ML (they are algebraic data type constructors, too). Then, following Crary et al. (2002) and Xi et al. (2003), we introduce a unary guarded algebraic data type constructor $\text{ty}$, and associate the following data constructors with it:
\begin{align*}
\text{Int} &:: \forall \alpha [\alpha = \text{int}] . \text{ty}(\alpha) \\
\text{Pair} &:: \forall \alpha_1 \beta_1 \beta_2 [\alpha = \beta_1 \times \beta_2] . \text{ty}(\beta_1) \cdot \text{ty}(\beta_2) \rightarrow \text{ty}(\alpha)
\end{align*}
This declaration is of the form (3) (§1.1), which is the form used in our theory. In concrete syntax, one could (and should) allow programmers to use the form (4) (§1.2), that is, to write:
\begin{align*}
\text{Int} &:: \text{ty}(\text{int}) \\
\text{Pair} &:: \forall \beta_1 \beta_2 . \text{ty}(\beta_1) \cdot \text{ty}(\beta_2) \rightarrow \text{ty}(\beta_1 \times \beta_2)
\end{align*}
For the sake of brevity, we associate only two data constructors, \text{Int} and \text{Pair}, with the type constructor $\text{ty}$. In a practical application, it could have more.
The motivation for this definition is the following: \textit{we may interpret $\text{ty}(\tau)$ as a singleton type whose only value is a runtime representation of $\tau$} (Crary et al., 2002). The constraints carried by the above declarations capture the relationship between the structure of a value $v$ whose type is
\(ty(\tau)\) and that of the type \(\tau\). Indeed, if \(v\) is \(Int\), then \(\tau\) must be \(int\); if \(v\) is \(Pair\ v_1\ v_2\), then \(\tau\) must be of the form \(\tau_1 \times \tau_2\), where \(v_i\) has type \(ty(\tau_i)\). Thus, by examining \(v\), one may gain knowledge about \(\tau\). This is particularly useful when \(\tau\) is a type variable, or has free type variables: the branches of a \texttt{match} construct that examines \(v\) may be typechecked under additional assumptions about these type variables. This is illustrated by the definition of \texttt{print}, a generic printing function:
```ocaml
let rec print : \(\forall \alpha.ty(\alpha) \rightarrow \alpha \rightarrow unit = fun t ->
match t with
| Int ->
fun x -> print_int x
| Pair (t1, t2) ->
fun (x1, x2) -> print t1 x1; print_string " * "; print t2 x2
```
For an arbitrary \(\alpha\), \texttt{print} accepts a runtime representation of the type \(\alpha\), that is, a value \(t\) of type \(ty(\alpha)\), as well as a value \(x\) of type \(\alpha\), and prints out a human-readable representation of \(x\). The function first examines the structure of \(t\), so as to gain knowledge about \(\alpha\). Indeed, each branch is typechecked under additional static knowledge. For instance, in the first branch, the assumption \(\alpha = int\) is available, so that \(x\) may be passed to the standard library function \texttt{print\_int}, which has type \(int \rightarrow unit\). Similarly, in the second branch, we have \(\alpha = \beta_1 \times \beta_2\), where \(\beta_1\) and \(\beta_2\) are abstract, so that \(x\) must in fact be a pair \((x1, x2)\).
In the second branch, \texttt{print} recursively invokes itself in order to display \(x1\) and \(x2\). There is a need for polymorphic recursion: the recursive calls to \texttt{print} use two different instances of its type scheme, namely \(\beta_i \rightarrow ty(\beta_i) \rightarrow \beta_i \rightarrow unit\), for \(i \in \{1, 2\}\). In the presence of polymorphic recursion, type inference is known to be undecidable, unless an explicit type annotation is given (Henglein, 1993). For this reason, the type scheme \(\forall \alpha.ty(\alpha) \rightarrow \alpha \rightarrow unit\) must be explicitly supplied by the programmer. The constraint generation algorithm given in §6 also exploits this type annotation in order to analyze the \texttt{match} construct, which eliminates a guarded algebraic data type. Thus, in this case, a single type annotation suffices. We believe this pattern to be common.
Let us go on with a generic comparison function, which is similar to \texttt{print}, but simultaneously analyzes \textit{two} runtime type representations:
```ocaml
let rec equal : \(\forall \alpha \beta.ty(\alpha) \rightarrow ty(\beta) \rightarrow \alpha \rightarrow \beta \rightarrow bool = fun t u ->
match t, u with
| Int, Int ->
fun x y -> x = y
| Pair (t1, t2), Pair (u1, u2) ->
fun (x1, x2) (y1, y2) -> (equal t1 u1 x1 y1) && (equal t2 u2 x2 y2)
| _, _ ->
false
```
The values \(x\) and \(y\) are structurally compared if they have the same type, otherwise they are considered different. More generally, it is possible to define a \textit{type cast} operator that relies on a \textit{dynamic} comparison between type representations:
```ocaml
let rec cast : \(\forall \alpha \beta.ty(\alpha) \rightarrow ty(\beta) \rightarrow \alpha \rightarrow \beta = fun t u ->
match t, u with
| Int, Int ->
fun x -> x
| Pair (t1, t2), Pair (u1, u2) ->
fun (x1, x2) -> (cast t1 u1 x1, cast t2 u2 x2)
```
| _, _ ->
raise CastException
If the type representations \( t \) and \( u \) match, then `cast t u x` returns the value \( x \), otherwise it raises the exception `CastException`. A more elaborate version of such a cast operator has been suggested by Weirich (2000).
More examples of the use of inductive types are given by Xi et al. (2003) and by Cheney and Hinze (2003). Furthermore, some recent works suggest not individual examples, but general programming patterns that exploit inductive types. For instance, Pottier and Gauthier (2004) show that inductive types allow expressing defunctionalization. This means that some ML programs whose well-typedness crucially relies on the use of higher-order functions, such as Danvy’s version of `printf` (1998), can now be modified to use algebraic data structures instead. This is important, because data structures are often easier to reason about than first-class functions, and are less opaque: a function can only be applied, while a data structure may be analyzed, traversed, modified, etc. in more than one way.
The type system described here is an instance of HMG\((X)\): in fact, it is its simplest instance. The constraint generation and constraint solving algorithms given in this paper apply.
### 2.2 Indexed types
We now consider so-called *indexed* types. The constraint language is that of §2.1, extended with a decidable fragment of first-order arithmetic. We use the binary guarded algebraic data type constructor `list` introduced in §1.2. Following Objective Caml syntax, the data constructors `Nil` and `Cons` are written `[]` and `::`.
Our first example is `combine`, a function that transforms a pair of lists of matching length into a list of pairs. It is taken from Objective Caml’s standard library.
```ocaml
let rec combine : ∀αβγ. list(α, γ) → list(β, γ) → list(α × β, γ) = fun l1 l2 ->
match l1, l2 with
| [], [] ->
[]
| a1 :: l1, a2 :: l2 ->
(a1, a2) :: (combine l1 l2)
```
The type scheme supplied by the programmer specifies that the two input lists must have the same length, represented by the variable \( \gamma \), and that the list that is returned has the same length as well.
It is worth noting that the implementation of `combine` in Objective Caml’s standard library includes an additional safety clause:
```ocaml
| _, _ ->
invalid_arg "List.combine"
```
which is executed when `combine` is applied to lists of incompatible lengths. Here, this clause is unnecessary. Indeed, because of the type scheme that was explicitly assigned to `combine`, this clause is typechecked under inconsistent assumptions: in other words, the type system is able to prove that it is dead code, and, for this reason, allows it to be omitted. More details are given in §4.7.
Our second example is `rev_map`, a function that reverses a list and at the same time applies a transformation to each of its elements, also taken from Objective Caml’s standard library.
```ocaml
let rev_map f l =
let rec rmap_f : ∃αβ.∀γ₁γ₂. list(β, γ₁) → list(α, γ₂) → list(β, γ₁ + γ₂) =
fun accu -> function
| [] ->
accu
| a :: l ->
rmap_f ((f a) :: accu) l
in
rmap_f [] l
```
The principal type scheme of `rev_map` is `∀αβγ.(α → β) → list(α, γ) → list(β, γ)`, which reflects that the function’s input and output lists have the same length.
Here, the internal auxiliary function `rmap_f` must be explicitly annotated, because it involves polymorphic recursion, and because it involves pattern matching over a guarded algebraic data type. However, it does not have a closed type scheme: the variables α and β, which we have existentially quantified in the type annotation, occur in the type of f, and cannot be universally quantified.
For this reason, this code is *not* accepted by the simple type inference algorithm of §6, which essentially requires annotations to be *closed* type schemes, even though it is well-typed under the rules of HMG(X). Currently, the only workaround is to modify the code so that f is passed as an argument to `rmap_f`, which may incur a runtime penalty. This illustrates a situation where requiring annotations to be closed type schemes is too restrictive. So far, we believe such a situation to be uncommon, but this remains to be backed with experience.
The type system described here is an instance of HMG(X). The constraint generation algorithm given in this paper applies. We do not address constraint solving, but we believe it is possible to reduce it to solving arithmetic formulae, as in Xi’s works (1998; 2001). The reduction is not quite the same as Xi’s, because our interpretations of implication differ (§1.3).
### 2.3 Dynamic security levels
Our last series of examples introduces a novel use of guarded algebraic data types. The type system discussed here is not exactly an instance of HMG(X): it combines the treatment of guarded algebraic data types, as found in HMG(X), with an information flow analysis for ML, as described elsewhere by the authors (Pottier & Simonet, 2003) and implemented in Flow Caml (Simonet, 2003b). Our point is that guarded algebraic data types, together with dedicated forms of pattern matching, allow modeling *dynamic security levels*.
Because information flow analysis is not the central topic of this paper, our exposition remains informal and omits many details that are relevant to the correctness of the analysis, but not the type inference mechanism. (In particular, the type constructor `level`, which is introduced below, should carry not one, but two, parameters.)
As usual in information flow analyses, types carry *security levels*, which are either atoms, taken from some fixed lattice L, or variables. (Thus, security levels are types, of a distinguished kind.) For instance, the integer type constructor `int` is now unary and covariant: its parameter is of security level kind. (It should not be confused with the singleton type `int` of §1.2, whose parameter
is of integer kind.) The ordering on atoms gives rise to an ordering on types, which is referred to as structural subtyping, because any two comparable types must have the same structure and may differ only in their security levels.
The lattice of security levels may be used to model principals and sets thereof. For instance, assume we are writing software for a bank. Then, each of the bank’s clients may be represented by a distinct security level (alice, bob, ...). The set of all European clients and the set of all clients worldwide may also be encoded as security levels, say europe and world. Then, the security lattice is defined so as to reflect membership in these sets: for instance, alice ≤ world and europe ≤ world hold.
Dynamic security levels (Myers, 1999) are runtime representations of security levels. They allow decisions about the dissemination of information to be made at runtime, while maintaining a strong security guarantee. In the bank example, dynamic security levels are useful because they allow building heterogeneous data structures, such as a list of client records, where every element has a different security level. In the absence of dynamic security levels, all elements of a list must have the same security level.
Zheng and Myers (2004) explain dynamic security levels in terms of dependent types, while Tse and Zdancewic (2004) study the closely related notion of dynamic principals using singleton types. The technique that we suggest here is also based on singleton types, which guarded algebraic data types subsume, as pointed out in §1.2. It is very close to Tse and Zdancewic’s work.
Let us introduce a unary guarded algebraic data type constructor level, whose data constructors are the constant security levels ℓ, that is, all elements of the security lattice L:
\[ \ell :: \forall \alpha [\alpha = \ell].level(\alpha) \quad (\ell \in L) \]
We require level to be an invariant type constructor: that is, level(α) ≤ level(α′) entails α = α′. Then, for every ℓ ∈ L, only one value has type level(ℓ), namely the constant security level ℓ. Thus, level is a singleton type constructor, just like int in §1.2.
Back to the bank example, a client record may be represented using the guarded algebraic data type record, whose only data constructor, Record, is declared as follows:
\[ Record :: \forall \beta [\beta \leq \text{world}].int(\beta) \cdot level(\beta) \rightarrow \text{record} \]
The type variable β represents the security level associated with this client. It is not a parameter of the type constructor record. As a result, the type record is isomorphic to the bounded existential type \( \exists \beta [\beta \leq \text{world}].int(\beta) \times level(\beta) \). A value of type record contains two pieces of data, namely the account’s balance, an integer value, and a dynamic security level, which allows telling, at runtime, which principals should have access to this information.
Because the type record isn’t parameterized, it is possible to build a list of client records, whose type is list(record). This list is heterogeneous, in the sense that every record may contain an integer value of a different security level. Thanks to the use of an existential type, the type system views it as a homogeneous list. A function that accepts such a list and computes the total amount of money available to the bank may be written as follows:
```ocaml
let rec total : list(record) → int(world) = function
| [] →
0
| (Record (x, id)) :: records →
x + total records
```
This function is well-typed, even though the security level of the integer \( x \) is an abstract type variable \( \beta \), because \( \beta \) carries the bound \( \beta \leq \text{world} \), so \( x \) also has type \( \text{int}(\text{world}) \), and the addition may be performed at this type. The function’s return type \( \text{int}(\text{world}) \) correctly reflects the fact that its result may reveal information about any client.
One may wish to compute the sum over a strict subset of the list, instead of over the entire list of records. One way to do so is to examine the dynamic security level that each record contains. We parameterize the function \( \text{total} \) by a dynamic security level \( \text{region} \), and include in the sum only those clients whose associated security level is below \( \text{region} \):
\[
\begin{align*}
\text{let rec subtotal : } & \forall \alpha [\alpha \leq \text{world}], \text{level}(\alpha) \rightarrow \text{list(record)} \rightarrow \text{int}(\alpha) = \\
& \text{fun region records} \rightarrow \\
& \quad \text{match records with} \\
& \quad | [] \rightarrow \\
& \quad \quad 0 \\
& \quad | (\text{Record}(x, \text{level})) :: \text{records'} \text{ when level } \leq \text{region} \rightarrow \\
& \quad \quad x + \text{subtotal region records'} \\
& \quad | _ :: \text{records'} \rightarrow \\
& \quad \quad \text{subtotal region records'}
\end{align*}
\]
The hypothetical syntax \( \text{when level } \leq \text{region} \) performs a dynamic comparison between two dynamic security levels. Such a construct is common in type systems with singleton types: for instance, DML (Xi, 1998, 2001) has integer comparisons, and Tse and Zdancewic (2004) allow comparing dynamic principals. Our formal development does not deal with two-way comparisons (see Remark 1.1), but it is straightforward to imagine how they could be added. Here, \( \text{level} \) has type \( \text{level}(\beta) \), for some abstract \( \beta \) known to satisfy \( \beta \leq \text{world} \), while \( \text{region} \) has type \( \text{level}(\alpha) \). The success of the \( \text{dynamic} \) comparison between \( \text{level} \) and \( \text{region} \) allows the \( \text{static} \) hypothesis \( \beta \leq \alpha \) to be made available in the second branch. Because the type constructor \( \text{int} \) is covariant, the variable \( x \), which has type \( \text{int}(\beta) \), also has type \( \text{int}(\alpha) \), and the addition may be performed at this type. The function’s return type, namely \( \text{int}(\alpha) \), reflects the fact that the function’s result may reveal information about clients whose security level is at most \( \alpha \). For instance, applying \( \text{subtotal} \) to the constant security level \( \text{europe} \), whose type is \( \text{level}(\text{europe}) \), yields a specialized function of type \( \text{list(record)} \rightarrow \text{int}(\text{europe}) \), whose result reveals information about European clients only.
The type system described here is not an instance of HMG\((X)\), because its typing rules are modified to keep track of information flow, and because two-way comparisons at singleton types, such as \( \text{level } \leq \text{region} \), are not part of the pattern language considered in this paper. Nevertheless, the machinery set up in this paper could easily be adapted to define an information flow analysis with dynamic security levels. Type inference would then be reduced to constraint solving in a fragment of the first-order theory of structural subtyping, which has been studied by the first author (Simonet, 2003c). Even though this type system is not an instance of HMG\((X)\), this was one of our motivations for introducing subtyping in HMG\((X)\), instead of focusing on the case of equality.
### 3 The untyped calculus
This section introduces a call-by-value \( \lambda \)-calculus featuring data constructors and pattern matching. It is entirely standard, hence we do not explain it in depth.
\begin{align*}
\text{dpv}(0) &= \emptyset \\
\text{dpv}(1) &= \emptyset \\
\text{dpv}(x) &= \{x\} \\
\text{dpv}(p_1 \land p_2) &= \text{dpv}(p_1) \uplus \text{dpv}(p_2) \\
\text{dpv}(p_1 \lor p_2) &= \text{dpv}(p_1) = \text{dpv}(p_2) & \text{if } \text{dpv}(p_1) = \text{dpv}(p_2) \\
\text{dpv}(K\,p_1 \cdots p_n) &= \text{dpv}(p_1) \uplus \cdots \uplus \text{dpv}(p_n)
\end{align*}
Figure 1: The variables defined by a pattern
\begin{align*}
[1 \mapsto v] &= \emptyset \\
[p_1 \land p_2 \mapsto v] &= [p_1 \mapsto v] \otimes [p_2 \mapsto v] \\
[p_1 \lor p_2 \mapsto v] &= [p_1 \mapsto v] \oplus [p_2 \mapsto v] \\
[K\,p_1 \cdots p_n \mapsto K\,v_1 \cdots v_n] &= [p_1 \mapsto v_1] \otimes \cdots \otimes [p_n \mapsto v_n]
\end{align*}
Figure 2: Extended substitution
### 3.1 Syntax
Let $x$ and $K$ range over disjoint denumerable sets of *variables* and *data constructors*, respectively. For every data constructor $K$, we assume a fixed nonnegative *arity*. Then *patterns*, *expressions*, *clauses*, and *values* are defined as follows:
\begin{align*}
p ::= & 0 \mid 1 \mid x \mid p \land p \mid p \lor p \mid K\,\bar{p} \\
e ::= & x \mid \lambda e \mid K\,\bar{e} \mid e\,e \mid \mu x.e \mid \text{let } x = e \text{ in } e \\
e ::= & p.e \\
v ::= & \lambda \bar{c} \mid K\,\bar{v}
\end{align*}
Patterns include the empty pattern 0, the wildcard pattern 1, variables, conjunction and disjunction patterns, and data constructor applications. To a pattern $p$, we associate a set of *defined program variables* $\text{dpv}(p)$, as specified in Figure 1. (The operator $\uplus$ stands for set-theoretic union $\cup$, but is defined only if its operands are disjoint.) The pattern $p$ is considered ill-formed if $\text{dpv}(p)$ is undefined, thus ruling out nonlinear patterns. Expressions include variables, functions, data constructor or function applications, recursive definitions, and local variable definitions. Functions are defined by cases: a $\lambda$-abstraction, written $\lambda(c_1, \ldots, c_n)$, consists of a sequence of *clauses*. A clause $c$ is made up of a pattern $p$ and an expression $e$ and is written $p.e$; the variables in $\text{dpv}(p)$ are bound within $e$. We occasionally use $ce$ to stand for a clause or an expression. Values include functions and data structures, that is, applications of a data constructor to values. Within patterns, expressions, and values, all applications of a data constructor must respect its arity; data constructors cannot be partially applied.
### 3.2 Semantics
Whether a pattern $p$ *matches* a value $v$ is defined by an *extended substitution* $[p \mapsto v]$ that is either undefined, which means that $p$ does not match $v$, or a mapping of $\text{dpv}(p)$ to values, which means that $p$ does match $v$ and describes how its variables become bound. Of course, when $p$ is a variable $x$, the extended substitution $[x \mapsto v]$ coincides with the ordinary substitution $[x \mapsto v]$,
\[
\lambda(p_1, e_1 \cdots p_n, e_n) \ v \rightarrow \bigoplus_{i=1}^{n} [p_i \mapsto v]e_i \quad (\beta)
\]
\[
\mu x.v \rightarrow [x \mapsto \mu x.v]v \quad (\mu)
\]
\[
\text{let } x = v \text{ in } e \rightarrow [x \mapsto v]e \quad (\text{let})
\]
\[
E[e] \rightarrow E[e'] \quad \text{if } e \rightarrow e' \quad (\text{context})
\]
Figure 3: Operational semantics
\[
K \bar{p} (p_1 \lor p_2) \bar{p}' \leadsto K \bar{p} p_1 \bar{p}' \lor K \bar{p} p_2 \bar{p}'
\]
\[
(p_1 \lor p_2) \land p \leadsto (p_1 \land p) \lor (p_2 \land p')
\]
\[
K p_1 \cdots p_n \land K' p'_1 \cdots p'_n \leadsto K (p_1 \land p'_1) \cdots (p_n \land p'_n)
\]
\[
K p_1 \cdots p_n \land K' p'_1 \cdots p'_n \leadsto 0 \quad \text{if } K \neq K'
\]
\[
K \bar{p} \bar{p}' \leadsto 0
\]
\[
p \lor 0 \leadsto p
\]
\[
0 \lor p \leadsto p
\]
\[
0 \land p \leadsto 0
\]
Figure 4: Normalizing patterns
which justifies our abuse of notation. Extended substitution for other pattern forms is defined in Figure 2. Let us briefly review the definition. The pattern $0$ matches no value, so $[0 \mapsto v]$ is always undefined. Conversely, the pattern $1$ matches every value, but binds no variables, so $[1 \mapsto v]$ is the empty substitution. In the case of conjunction patterns, $\otimes$ stands for (disjoint) set-theoretic union, so that the bindings produced by $p_1 \land p_2$ are the union of those independently produced by $p_1$ and $p_2$. The operator $\oplus$ is strict—that is, its result is undefined if either of its operands is undefined—which means that a conjunction pattern matches a value if and only if both of its members do. In the case of disjunction patterns, $\oplus$ stands for a nonstrict, angelic choice operator with left bias; when $o_1$ and $o_2$ are two possibly undefined mathematical objects that belong to the same space when defined, $o_1 \oplus o_2$ stands for $o_1$ if it is defined and for $o_2$ otherwise. As a result, a disjunction pattern matches a value if and only if either of its members does. The set of bindings thus produced is that produced by $p_1$, if defined, otherwise that produced by $p_2$. Last, the pattern $K p_1 \cdots p_n$ matches values of the form $K v_1 \cdots v_n$ only; it matches such a value if and only if $p_i$ matches $v_i$ for every $i \in \{1, \ldots, n\}$.
The call-by-value small-step semantics, written $\rightarrow$, is defined by the rules of Figure 3. It is standard. Rule $(\beta)$ governs function application and pattern-matching: $\lambda(p_1, e_1 \cdots p_n, e_n) \ v$ reduces to $[p_i \mapsto v_i]e_i$, where $i$ is the least element of $\{1, \ldots, n\}$ such that $p_i$ matches $v$. Note that this expression is stuck (does not reduce) when no such $i$ exists. The last rule lifts reduction to arbitrary evaluation contexts, whose grammar is the following:
\[E ::= K \bar{v} \parallel \bar{e} \mid \parallel e \mid v \mid \text{let } x = \parallel \text{ in } e\]
3.3 Properties of patterns
We define a notion of equivalence between patterns as follows: $p_1$ and $p_2$ are equivalent, which we write $p_1 \equiv p_2$, if and only if they give rise to the same extended substitutions, that is, if and only if the functions $[p_1 \mapsto \cdot]$ and $[p_2 \mapsto \cdot]$ coincide.
It is possible to normalize a pattern using the reduction rules given in Figure 4, applied modulo associativity and commutativity of $\land$, modulo associativity of $\lor$, and under arbitrary contexts. (Note that $\lor$ cannot be considered commutative, since $p_1 \lor p_2 \equiv p_2 \lor p_1$ may not hold when $p_1$ and $p_2$ bind variables.) This process is terminating and meaning-preserving:
**Lemma 3.1.** The relation $\leadsto$ is strongly normalizing. □
**Lemma 3.2.** $p_1 \leadsto p_2$ implies $p_1 \equiv p_2$. □
Normalization may be exploited to decide whether a pattern is empty:
**Lemma 3.3.** $p \equiv 0$ holds if and only if $p \leadsto^* 0$ holds. □
Thus, if a pattern is empty, then one of its normal forms is 0. (In fact, the previous lemmas imply that it then has no normal form other than 0.) The interaction between normalizing patterns and the type system is discussed in §4.7.
4 The type system
We now equip our core calculus with a constraint-based type system featuring guarded algebraic data types. As argued, for instance, by Pottier and Rémy (2005), the introduction of constraints is beneficial for at least two reasons: (i) it is pleasant to reduce type inference to constraint solving, even when working within the basic setting of ML, where constraints involve type equations only; and (ii) this allows easily moving to much more general settings, where constraints may involve type class membership predicates, as in Haskell (Wadler and Blott, 1989), Presburger arithmetic, as in DML (Xi, 1998), polynomials, as in Zenger’s work (1997), subtyping, etc. We present our type system as a conservative extension of HM($X$) (Odersky et al., 1999), and refer to it as HMG($X$).
In §4.1, we introduce the syntactic objects involved in the definition of the type system, namely type variables, types, constraints, type schemes, environments, and environment fragments. All but the last are inherited from HM($X$). Environment fragments are a new entity, used to describe the static knowledge that is gained by successfully matching a value against a pattern. In §4.2, we explain how these syntactic objects are interpreted in a logical model.
In order to guarantee type soundness, some requirements must be placed on the model: they are expressed in §4.3. Some of them concern the (guarded) algebraic data types defined by the programmer, so the syntax of algebraic data type definitions is also made precise in §4.3.
In §4.4, we introduce a few tools that allow manipulating environment fragments. Then, we review the typing judgments (§4.5) and typing rules (§4.6) of HMG($X$), and prove that type soundness holds (§4.7).
4.1 Syntax
In keeping with the HM($X$) tradition, the type system is parameterized by a first-order constraint logic $X$, whose variables, terms, and formulas are respectively called *type variables*, *types*, and *constraints*.
Type variables $\alpha$, $\beta$, $\gamma$ are drawn from a denumerable set. Given two sets of variables $\bar{\alpha}$ and $\bar{\beta}$, we write $\bar{\alpha} \neq \bar{\beta}$ for $\bar{\alpha} \cap \bar{\beta} = \emptyset$. If $o$ is a syntactic object, we write $\text{ftv}(o)$ for the free type variables of $o$. We say that $\bar{\alpha}$ is fresh for $o$ if and only if $\bar{\alpha} \neq \text{ftv}(o)$ holds.
In some proofs, we use renamings $\theta$, which are total, bijective mappings from type variables to type variables with finite domain. The domain $\text{dom}(\theta)$ of a renaming $\theta$ is the set of type variables $\alpha$ such that $\alpha$ and $\theta(\alpha)$ differ. We say that $\theta$ is fresh for an object $o$ if and only if $\text{dom}(\theta) \neq \text{ftv}(o)$ holds, or equivalently, if $\theta(o)$ is $o$. When proving a theorem $T$, we say that a hypothesis $H$ may be assumed without loss of generality (w.l.o.g.) if the theorem $T$ follows from the theorem $H \Rightarrow T$ via a renaming argument, which is usually left implicit.
We assume a fixed, arbitrary set of algebraic data type constructors $\varepsilon$, each of which is equipped with a nonnegative arity. Then, types $\tau$ are built out of type variables using a distinguished arrow type constructor $\rightarrow$ and algebraic data type constructors (whose arity must be obeyed).
Constraints $C, D$ are built out of types using basic predicates $\pi$ and the standard first-order connectives.
\[
\begin{align*}
\tau ::= & \; \alpha \mid \tau \rightarrow \tau \mid \varepsilon(\tau_1, \ldots, \tau_n) \\
C, D ::= & \; \pi \bar{\tau} \mid C \land C \mid \exists \alpha.C \mid \neg C
\end{align*}
\]
The set of basic predicates $\pi$ is left unspecified, which allows the system to be instantiated in many ways. Every predicate is assumed to have a fixed arity. We assume that a distinguished binary predicate $\leq$ is given, and write $\tau_1 \leq \tau_2$ (read: $\tau_1$ is a subtype of $\tau_2$) for $\leq \tau_1 \tau_2$. Via some syntactic sugar, it is possible to view equality $\tau = \tau$, truth true, falsity false, universal quantification $\forall \alpha.C$, disjunction $C \lor C$, and implication $C \Rightarrow C$ as part of the constraint language.
Remark 4.1. In many applications, it is necessary to partition types into several sorts. Doing so does not introduce any fundamental complication, so, for the sake of simplicity, we ignore this aspect and assume that there is only one sort.
Remark 4.2. Negation $\neg C$ was not considered part of the constraint language by Odersky et al. (1999). In the present paper, we exploit the connectives $\forall$, $\lor$, and $\Rightarrow$. The latter contains negation, so introducing these three connectives is equivalent to introducing negation alone. The presence of full negation does not affect the type soundness proof (\S 4) or the reduction of type inference to constraint solving (\S 5). However, we do find it necessary to restrict its use in order for the reduction to produce tractable constraints (\S 6).
As in HM($X$), a (constrained) type scheme $\sigma$ is a pair of a constraint $C$ and a type $\tau$, wrapped within a set of universal quantifiers $\alpha$; we write $\sigma ::= \forall \bar{\alpha}[C].\tau$. By abuse of notation, a type $\tau$ may be viewed as the type scheme $\forall \emptyset[\text{true}].\tau$, so types form a subset of type schemes.
An environment $\Gamma$ is a finite mapping from variables to type schemes. An environment is simple if it maps variables to types. We write $\text{dom}(\Gamma)$ for the domain of $\Gamma$.
An environment fragment $\Delta$ is a pair of a constraint $D$ and a simple environment $\Gamma$, wrapped within a set of existential quantifiers $\beta$; we write $\Delta ::= \exists \bar{\beta}[D]\Gamma$. The domain of $\Delta$ is that of $\Gamma$. This notion is new in HMG($X$). Environment fragments appear in judgments about patterns (\S 4.5) and are meant to describe the static knowledge that is gained by successfully matching a value against a pattern. The reader may wish to peek ahead at Example 4.21.
4.2 Interpretation
The logic is interpreted in a model \((T, \leq)\), a nonempty, partially ordered set whose elements \(t\) are referred to as ground types and whose ordering is used to interpret the basic predicate \(\leq\). Keep in mind that this ordering may in fact be equality: in such a case, the type system does not have subtyping.
Because syntactic objects may have free type variables, they are interpreted under a ground assignment \(\rho\), a total mapping of the type variables to ground types. The interpretation of a type variable \(\alpha\) under \(\rho\) is simply \(\rho(\alpha)\). The interpretation of a type \(\tau\) under \(\rho\), written \(\rho(\tau)\), is then defined in a compositional manner. For instance, \(\rho(\tau_1 \rightarrow \tau_2)\) is \(\rho(\tau_1) \rightarrow \rho(\tau_2)\), where the second \(\rightarrow\) symbol denotes a fixed, unspecified total mapping of \(T^2\) into \(T\). The interpretation of every type constructor \(\varepsilon\) is defined similarly.
The interpretation of a constraint \(C\) under \(\rho\) is a truth value: we write \(\rho \vdash C\) when \(\rho\) satisfies \(C\). The partial ordering on \(T\) is used to interpret subtyping constraints: that is, \(\rho \vdash \tau_1 \leq \tau_2\) is defined as \(\rho(\tau_1) \leq \rho(\tau_2)\). The interpretation of the other basic predicates \(\pi\) is unspecified. The interpretation of the first-order connectives \(\land, \exists\) and \(\neg\) is standard. We write \(C_1 \models C_2\) (read: \(C_1\) entails \(C_2\)) if and only if, for every ground assignment \(\rho\), \(\rho \vdash C_1\) implies \(\rho \vdash C_2\). We write \(C_1 \equiv C_2\) (read: \(C_1\) and \(C_2\) are equivalent) if and only if both \(C_1 \models C_2\) and \(C_2 \models C_1\) hold.
A constraint \(C\) determines a set of type variables \(\bar{\alpha}\) if and only if any two ground assignments that satisfy \(C\) and that coincide outside \(\bar{\alpha}\) must coincide on \(\bar{\alpha}\) as well. This standard notion (Pottier and Rémy, 2005) is exploited in §6. It enjoys the following property:
**Lemma 4.3.** Assume \(C_1\) determines \(\bar{\alpha}\). Then, \(\exists \bar{\alpha}.C_1 \land \forall \bar{\alpha}.C_1 \Rightarrow C_2\) is equivalent to \(\exists \bar{\alpha}.(C_1 \land C_2)\).
In order to guarantee type soundness, the model must satisfy a number of requirements, which we state in §4.3. Before doing so, however, we interpret type schemes and environment fragments, and explain how this gives rise to orderings on these objects. (In fact, they are only preorders, but we stick to the word “ordering.”)
As in HM\((X)\), a type scheme is interpreted as an upward-closed set of ground types. This is standard: see, for instance, Trifonov and Smith (1996) or Sulzmann (2000).
**Definition 4.4.** The interpretation \(\rho(\forall \bar{\alpha}[D], \tau)\) of the type scheme \(\forall \bar{\alpha}[D], \tau\) under \(\rho\) is the set of ground types \(\{ t \mid \exists \bar{l} \cdot \rho[\bar{\alpha} \mapsto \bar{l}] \vdash D \land \rho[\bar{\alpha} \mapsto \bar{l}](\sigma) \leq t \}\). It may also be written \(\uparrow \{\rho[\bar{\alpha} \mapsto \bar{l}](\sigma) \mid \rho[\bar{\alpha} \mapsto \bar{l}] \vdash D\}\), where \(\uparrow\) is the upward closure operator.
This definition gives rise to an ordering on type schemes, which extends the ordering on types. It is defined as follows. Given two type schemes \(\sigma\) and \(\sigma'\), we consider \(\sigma \leq \sigma'\) to be a valid constraint, which we interpret by defining \(\rho \vdash \sigma \leq \sigma'\) as \(\rho(\sigma) \supseteq \rho(\sigma')\).
As a sanity check, one may verify that the type scheme \(\forall \alpha.\alpha\) is a least element in this ordering; indeed, its interpretation under every ground assignment is the full model \(T\), so every constraint of the form \((\forall \alpha.\alpha) \leq \sigma\) is a tautology. One may also check that \(\forall \alpha.\sigma\) is more general than \(\sigma\), that is, every constraint of the form \((\forall \alpha.\sigma) \leq \sigma\) is a tautology. Thus, the ordering allows a universally quantified type variable to be instantiated (to become free).
The following property is also useful on a few occasions:
**Lemma 4.5.** \(D \vdash \forall \bar{\alpha}[D]. \tau \leq \tau\).
It is well-known that ordering constraints on type schemes may also be viewed as syntactic sugar for constraints that involve the ordering on types. This is stated by the following lemma:
**Lemma 4.6.** Let $\sigma$ and $\sigma'$ stand for $\forall \alpha[D],\tau$ and $\forall \alpha'[D'],\tau'$, respectively. Let $\bar{\alpha}' \neq \text{ftv}(\sigma)$. Then, $\sigma \leq \sigma' \equiv \forall \alpha'.D' \Rightarrow \sigma \leq \tau'$ holds. Furthermore, let $\bar{\alpha} \neq \text{ftv}(\tau')$. Then, $\sigma \leq \tau' \equiv \exists \alpha.(D \land \tau \leq \tau')$ holds.
We write $\exists \sigma$ for $\exists \alpha.(\sigma \leq \alpha)$, where $\alpha$ is fresh for $\sigma$. This constraint, which requires $\sigma$ to denote a nonempty set of ground types, is used in VAR (§4.6).
The ordering on type schemes may be extended pointwise to an ordering on environments. Thus, when $\Gamma$ and $\Gamma'$ are environments with a common domain, we consider $\Gamma' \leq \Gamma$ to be syntactic sugar for the conjunction of the constraints $\Gamma'(x) \leq \Gamma(x)$, where $x$ ranges over the domain of $\Gamma$ and $\Gamma'$.
Let us now turn to the interpretation of environment fragments. Let a *ground environment* $g$ be a finite mapping from variables to ground types. Given a ground assignment $\rho$ and a simple environment $\Gamma$, let $\rho(\Gamma)$ stand for the ground environment that maps every $x \in \text{dom}(\Gamma)$ to $\rho(\Gamma(x))$. The ordering on ground types is extended pointwise to ground environments with a common domain. Then, an environment fragment is interpreted as a downward-closed set of ground environments, as follows:
**Definition 4.7.** The interpretation of the environment fragment $\exists \bar{\beta}[D]\Gamma$ under the ground assignment $\rho$, written $\rho(\exists \bar{\beta}[D]\Gamma)$, is the set of ground environments $\{ g / \exists \bar{t}. \rho[\bar{\beta} \mapsto \bar{t}] \vdash D \land g \leq \rho[\bar{\beta} \mapsto \bar{t}](\Gamma) \}$. It may also be written $\downarrow \{ \rho[\bar{\beta} \mapsto \bar{t}](\Gamma) / \rho[\bar{\beta} \mapsto \bar{t}] \vdash D \}$, where $\downarrow$ is the downward closure operator.
Again, this definition gives rise to an ordering on environment fragments, which extends the ordering on simple environments. Given two environment fragments $\Delta$ and $\Delta'$ with a common domain, we consider $\Delta' \leq \Delta$ to be a valid constraint, which we interpret by defining $\rho \vdash \Delta' \leq \Delta$ as $\rho(\Delta') \subseteq \rho(\Delta)$.
As a sanity check, one may verify that the environment fragment $\exists \beta.(x : \beta)$ is a greatest element among the environment fragments of domain $\{ x \}$. We also prove below (see rule F-HIDE in Figure 5) that $\Delta$ is more general than $\exists \alpha.\Delta$, that is, every constraint of the form $\Delta \leq \exists \alpha.\Delta$ is a tautology. Thus, the ordering allows a free type variable to become abstract (existentially quantified).
The interpretation of environment fragments, and the definition of their ordering, are dual to those of type schemes: $\uparrow$ and $\supseteq$ are replaced with $\downarrow$ and $\subseteq$, respectively. These changes reflect the dual nature of the $\forall$ and $\exists$ quantifiers.
As in the case of type schemes, ordering constraints on environment fragments may be viewed as syntactic sugar for constraints that involve the ordering on types. This is stated by the following lemma:
**Lemma 4.8.** Let $\Delta$ and $\Delta'$ stand for $\exists \bar{\beta}[D]\Gamma$ and $\exists \bar{\beta}'[D']\Gamma'$, respectively. Let $\bar{\beta} \neq \text{ftv}(\Gamma')$ and $\bar{\beta}' \neq \text{ftv}(\Delta)$. Then, we have $\Delta' \leq \Delta \equiv \forall \bar{\beta}'.D' \Rightarrow \exists \bar{\beta}.(D \land \Gamma' \leq \Gamma)$. As a corollary, if, in addition, $\bar{\beta}' \neq \text{ftv}(C)$ holds, then $C \vdash \Delta' \leq \Delta$ is equivalent to $C \land D' \vdash \exists \bar{\beta}.(D \land \Gamma' \leq \Gamma)$.
### 4.3 Requirements on the model
So far, the ordering $\leq$ on ground types, as well as the interpretation of the type constructors $\rightarrow$ and $\varepsilon$, have been left unspecified. This is intended to offer a great deal of flexibility when
defining instances of $\text{HMG}(X)$. However, in order to establish type soundness, we must make a few assumptions about them.
First, subtyping assertions that involve an arrow type and an algebraic data type, or two algebraic data types with distinct head symbols, must be unsatisfiable. This is required for progress to hold (Lemma 4.40 and Theorem 4.42).
**Requirement 4.9.** Every constraint of the form $\tau_1 \to \tau_2 \leq \varepsilon(\bar{\tau})$ or $\varepsilon(\bar{\tau}) \leq \tau_1 \to \tau_2$ or $\varepsilon(\bar{\tau}) \leq \varepsilon'(\bar{\tau}')$, where $\varepsilon$ and $\varepsilon'$ are distinct, is unsatisfiable. ◊
Second, the arrow type constructor must be contravariant in its domain and covariant in its codomain. This is required for subject reduction to hold (Lemma 4.34). This requirement appears in all type systems equipped with subtyping.
**Requirement 4.10.** $\tau_1 \to \tau_2 \leq \tau'_1 \to \tau'_2$ entails $\tau'_1 \leq \tau_1 \land \tau_2 \leq \tau'_2$. ◊
Last, we must make similar **variance** requirements about every algebraic data type constructor $\varepsilon$. The requirements that bear on $\varepsilon$ depend on its definition, however; so, before stating these requirements, we must recall how (guarded) algebraic data types are defined.
In keeping with the ML tradition, algebraic data types are explicitly defined, as part of the program text. As a simplifying assumption, we assume that all such definitions are placed in a prologue, so that they are available to the typechecker when it starts examining the program’s body (an expression). A prologue consists of a series of *data constructor declarations*, each of which assigns a closed type scheme to a (distinct) data constructor $K$, as follows:
$$K :: \forall \bar{\alpha} \bar{\beta}[D], \tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})$$
This is the form (3) of §1.1. Here, $n$ must be the arity of $K$, and $\bar{\alpha}$ must be a vector of distinct type variables. When $K$ is declared in such a way, we say that it is *associated* with the algebraic data type constructor $\varepsilon$.
We may now state the variance requirements that bear on algebraic data type constructors. They are necessary to establish subject reduction and progress (Lemmas 4.37 and 4.40), and are standard in type systems featuring both subtyping and isorecursive types: see, for instance, Pottier and Rémy (2005) or Simonet (2003a).
**Requirement 4.11.** For every data constructor $K$, if $K :: \forall \bar{\alpha} \bar{\beta}[D], \tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})$ and $K :: \forall \bar{\alpha}' \bar{\beta}'[D'], \tau'_1 \cdots \tau'_n \rightarrow \varepsilon(\bar{\alpha}')$ are two $\alpha$-equivalent versions of $K$’s declaration, and if $\beta$ is fresh for every $\tau'_i$, then $D' \land \varepsilon(\bar{\alpha}') \leq \varepsilon(\bar{\alpha}) \vdash \exists \bar{\beta}.(D \land \tau_i \leq \tau_i)$ must hold. ◊
(Throughout the paper, we write $C \land_i C_i$ for $C \land C_1 \land \ldots \land C_n$.) Although these requirements are standard, they may conceivably seem cryptic. Here is a brief and informal attempt at explaining them. Assigning $K$ the type scheme $\forall \bar{\alpha} \bar{\beta}[D], \tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})$ amounts to declaring that the abstract data type $\varepsilon(\bar{\alpha})$ is *isomorphic* to a sum type of the form $\exists \bar{\beta}[D](\tau_1 \cdots \tau_n) + \ldots$. A similar statement can be made about the $\alpha$-equivalent declaration $K :: \forall \bar{\alpha}' \bar{\beta}'[D'], \tau'_1 \cdots \tau'_n \rightarrow \varepsilon(\bar{\alpha}')$. Now, for this isomorphism, which is declared as part of the prologue, to be consistent with the model, which defines the interpretation of $\varepsilon$ and of $\leq$, the existence of a subtyping relationship between the abstract types $\varepsilon(\bar{\alpha}')$ and $\varepsilon(\bar{\alpha})$ must entail the existence of an analogous relationship between their concrete representations $\exists \bar{\beta}'[D'](r'_1 \cdots r'_n) + \ldots$ and $\exists \bar{\beta}[D](\tau_1 \cdots \tau_n) + \ldots$. In other words, since the sum type constructor $+$ is covariant, the law $\varepsilon(\bar{\alpha}') \leq \varepsilon(\bar{\alpha}) \vdash \exists \bar{\beta}'[D'](r'_1 \cdots r'_n) \leq \exists \bar{\beta}[D](\tau_1 \cdots \tau_n)$
must hold. In fact, the variance requirement could conceivably be stated in this manner. Under the hypothesis that $\beta$ is fresh for every $\tau'_i$, however, one may prove, by exploiting Lemma 4.8, that a consequence of this law is $D' \land \varepsilon(\bar{\alpha}') \leq \varepsilon(\bar{\alpha}) \vdash \exists \beta.(D \land_i \tau'_i \leq \tau_i)$. This more basic formulation is the one adopted in the statement of Requirement 4.11.
**Remark 4.12.** If the model is defined in such a way that every algebraic data type constructor $\varepsilon$ is invariant in every parameter, then Requirement 4.11 is met. The proof of this assertion is not difficult, and relies on the fact that, in this case, $\varepsilon(\bar{\alpha}') \leq \varepsilon(\bar{\alpha})$ entails $\bar{\alpha}' = \bar{\alpha}$. In particular, in a type system without subtyping, where every type constructor is invariant, Requirement 4.11 is always met. The requirement becomes nontrivial only when subtyping is interpreted in a nontrivial way.
**Remark 4.13.** We have assumed that the model preexists, and only then required the program’s prologue to be consistent with it. In practice, it is more natural to let the prologue influence the construction of the model, so that the two are consistent by design. As far as the present paper is concerned, the distinction is irrelevant.
### 4.4 Environment fragments
Before we attack the definition of the type system, we must introduce a few operations on environment fragments. The first operation enriches an environment fragment $\Delta$ with a constraint $C$, yielding a (more precise) environment fragment $[C]\Delta$. The second one abstracts a set of type variables $\bar{\alpha}$ out of an environment fragment $\Delta$, yielding a (less precise) environment fragment $\exists \bar{\alpha}.C$. The two operations are defined at once below.
**Definition 4.14.** If $\Delta$ is $\exists \beta.(D)\Gamma$ and $\beta \not\# \text{ftv}(\bar{\alpha}, C)$ holds, then we write $\exists \bar{\alpha}[C]\Delta$ for the environment fragment $\exists \bar{\alpha}.\beta[C \land D]\Gamma$. We write $\exists \bar{\alpha}.\Delta$ for $\exists \bar{\alpha}[\text{true}]\Delta$ and $[C]\Delta$ for $\exists \bar{\alpha}[C]\Delta$.
The next lemma provides an interpretation of the composite operation. This is a low-level result, used only in the proof of more elaborate laws (see Lemma 4.20 and Figure 5).
**Lemma 4.15.** $\rho(\exists \bar{\alpha}[C]\Delta)$ is $\cup \{\rho[\bar{\alpha} \mapsto \bar{t}](\Delta) / \rho[\bar{\alpha} \mapsto \bar{t}] \vdash C\}$.
The next two operations are binary. Given two environment fragments $\Delta_1$ and $\Delta_2$, they produce a new environment fragment. They are intended to reflect the effect of conjunction and disjunction patterns, respectively. Although their syntactic definitions, which follow, are rather heavy, their interpretations, given by the two lemmas that follow, are simple.
**Definition 4.16.** Given two simple environments $\Gamma_1$ and $\Gamma_2$ with disjoint domains, their conjunction $\Gamma_1 \times \Gamma_2$ is their set-theoretic union. (Recall that a simple environment is a partial mapping of variables to types.) Given two environment fragments $\Delta_1$ and $\Delta_2$ with disjoint domains, their conjunction $\Delta_1 \times \Delta_2$ is the environment fragment $\exists \beta_1.\beta_2.(D_1 \land D_2)(\Gamma_1 \times \Gamma_2)$, provided $\Delta_i$ is $\exists \beta_i.(D_i)\Gamma_i$ and provided $\beta_1 \not\# \beta_2$, $\beta_1 \not\# \text{ftv}(\Delta_2)$, and $\beta_2 \not\# \text{ftv}(\Delta_1)$ hold.
**Definition 4.17.** Given two environment fragments $\Delta_1$ and $\Delta_2$ with a common domain, their disjunction $\Delta_1 + \Delta_2$ is the environment fragment $\exists \beta_1.\beta_2\bar{\alpha}((D_1 \land \Gamma \leq \Gamma_1) \lor (D_2 \land \Gamma \leq \Gamma_2))\Gamma$, provided $\Delta_i$ is $\exists \beta_i.(D_i)\Gamma_i$, provided $\beta_1 \not\# \beta_2$, $\beta_1 \not\# \text{ftv}(\Delta_2)$, and $\beta_2 \not\# \text{ftv}(\Delta_1)$ hold, and provided the environment $\Gamma$, whose domain is that of $\Gamma_1$ and $\Gamma_2$, maps every variable to a distinct type variable in $\bar{\alpha}$, where $\bar{\alpha} \not\# \text{ftv}(\beta_1,\beta_2,\Delta_1,\Delta_2)$ holds.
The next two lemmas are also low-level results, used only in the proof of the laws in Figure 5. To state the first of these lemmas, we must define conjunction of ground environments and of sets thereof. (The disjunction of two sets of ground environments is simply their set-theoretic union.) Given two ground environments $g_1$ and $g_2$ of disjoint domains, we let $g_1 \times g_2$ stand for their set-theoretic union, that is, the ground environment $\rho$ of domain $\text{dom}(g_1) \cup \text{dom}(g_2)$ that maps $x$ to $g_i(x)$ if $x \in \text{dom}(g_i)$ and $i \in \{1, 2\}$. If $G_1$ and $G_2$ are two sets of ground environments, we let $G_1 \times G_2$ stand for $\{g_1 \times g_2 / g_1 \in G_1 \land g_2 \in G_2\}$.
**Lemma 4.18.** $\rho(\Delta_1 \times \Delta_2)$ is $\rho(\Delta_1) \times \rho(\Delta_2)$.
**Lemma 4.19.** $\rho(\Delta_1 + \Delta_2)$ is $\rho(\Delta_1) \cup \rho(\Delta_2)$.
The previous lemmas allow establishing a number of laws about environment fragments, which are useful when reasoning about the correctness and completeness of the constraint generation rules (§5).
**Lemma 4.20.** The entailment laws in Figure 5 are valid.
### 4.5 Typing judgments
The type system features three distinct judgment forms, corresponding to patterns, expressions, and clauses.
Judgments about patterns are written $C \vdash p : \tau \leadsto \exists \beta D \Gamma$, where the domain of $\Gamma$ is $\text{dpv}(p)$. Such a judgment may be read: *under assumption C, it is legal to match a value of type $\tau$ against p; furthermore, if successful, this test guarantees that there exist types $\beta$ that satisfy D such that $\Gamma$ is a valid description of the values that the variables in $\text{dpv}(p)$ receive.*
If the system only had ordinary (as opposed to guarded) algebraic data types, then there would be no need for $\beta$ and $D$. In other words, it would be possible to identify environment fragments $\Delta$ with simple environments $\Gamma$. For instance, assuming $K :: \forall \bar{\alpha}, \tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})$, the familiar judgment $\text{true} \vdash K x_1 \cdots x_n : \varepsilon(\bar{\alpha}) \leadsto (\bar{x}_1 \mapsto \tau_1, \ldots, \bar{x}_n \mapsto \tau_n)$ holds: when matching a value of type $\varepsilon(\bar{\alpha})$, the pattern $K x_1 \cdots x_n$ binds the variable $x_i$ to a value of type $\tau_i$, for every $i \in \{1, \ldots, n\}$.
If the system only had existential types in the style of Läuger and Odersky (1994), then environment fragments would be of the form $\exists \beta.\Gamma$. For instance, imagine we have $K :: \forall \bar{\alpha}, \beta, \tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})$. Then, because the type variables $\beta$ do not appear in the data constructor’s result type, the type constructor $\varepsilon$ behaves as an existential type: applying $K$ amounts to creating an existential
package, while matching against $K$ amounts to opening such a package. Thus, matching against $K$ locally introduces $\beta$ as a vector of abstract types. In our system, this is reflected by the judgment
$$\text{true} \vdash K \ x_1 \cdots x_n : \varepsilon(\bar{\alpha}) \rightsquigarrow \exists \bar{\beta}.(x_1 \mapsto \tau_1, \ldots, x_n \mapsto \tau_n).$$
In the full system, the declaration of a data constructor $K$ may involve a constraint $D$, which bears on the type variables $\bar{\alpha}$ and $\bar{\beta}$. Then, a successful match against $K$ not only introduces the abstract types $\bar{\beta}$, but also guarantees that $D$ holds. To keep track of this information, we allow fragments to carry a constraint. For instance, if $K :: \forall \bar{\alpha} \bar{\beta}[D].\tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})$ holds, then we have
$$\text{true} \vdash K \ x_1 \cdots x_n : \varepsilon(\bar{\alpha}) \rightsquigarrow \exists \bar{\beta}[D](x_1 \mapsto \tau_1, \ldots, x_n \mapsto \tau_n).$$
Judgments about expressions retain the same form as in HM($X$): they are written $C, \Gamma \vdash e : \sigma$, where $C$ represents an assumption about the judgment’s free type variables, $\Gamma$ assigns type schemes to variables, and $\sigma$ is the type scheme assigned to $e$. Judgments about clauses, of the form $C, \Gamma \vdash c : \tau$, are to be interpreted in a similar way.
As in HM($X$), all judgments are identified up to constraint equivalence: for instance, the judgments $C_1, \Gamma \vdash e : \sigma$ and $C_2, \Gamma \vdash e : \sigma$ are considered interchangeable when $C_1 \equiv C_2$ holds. In a valid judgment $C, \Gamma \vdash e : \sigma$, the constraint $C$ may well be unsatisfiable. A closed expression $e$ is well-typed if and only if $C, \emptyset \vdash e : \sigma$ holds for some satisfiable constraint $C$.
### 4.6 Typing rules
Whether a judgment is valid is defined by the rules in Figure 6, which we now review, beginning with the rules that concern patterns.
P-Empty and P-Wild tell that the patterns 0 and 1 may be used at any type, and bind no variables. Because matching against 0 never succeeds, the environment fragment produced in P-Empty includes the absurd constraint false. Conversely, because matching against 1 always succeeds, it provides no information; hence, the environment fragment produced in P-Wild includes the tautology true.
P-Var is similar to P-Wild, except the environment fragment has nonempty domain. The rule may be read: *if the pattern $x$ matches a value of type $\tau$, then the variable $x$ becomes bound to a value of type $\tau$.*
P-And requires both $p_1$ and $p_2$ to match values of type $\tau$, producing two environment fragments $\Delta_1$ and $\Delta_2$ of disjoint domains, because the pattern $p_1 \land p_2$ is well-formed; thus, the conjunction $\Delta_1 \times \Delta_2$ is defined.
Similarly, P-Or requires both $p_1$ and $p_2$ to match values of type $\tau$. Furthermore, it requires both to produce the same environment fragment $\Delta$, so that it becomes possible to state that the pattern $p_1 \lor p_2$ gives rise to $\Delta$, without knowing which of $p_1$ or $p_2$ leads to a successful match.
P-Cstr looks up the declaration of the data constructor $K$ and introduces the type variables $\bar{\beta}$. These type variables are chosen fresh (indeed, the reader may check that they cannot appear free in the rule’s conclusion), so as to play the role of abstract types. Every $p_i$ is typechecked under a hypothesis augmented with $D$, a constraint that bears on $\bar{\alpha}$ and $\bar{\beta}$, and is found in the declaration of $K$. Thus, the type information gained by ensuring that the value at hand is indeed an application of $K$ becomes available when checking that every subpattern is well-typed. In other words, new type information is propagated top-down through the pattern. The environment fragment associated with the entire pattern is obtained by fusing the environment fragments associated with its subpatterns, as in the case of conjunction, and by incorporating
Patterns (syntax-directed)
\[
\begin{align*}
\text{p-EMPTY} & \quad C \vdash 0 : \tau \leadsto \exists \emptyset[\text{false}] \emptyset \\
\text{p-WILD} & \quad C \vdash 1 : \tau \leadsto \exists \emptyset[\text{true}] \emptyset \\
\text{p-VAR} & \quad C \vdash x : \tau \leadsto \exists \emptyset[\text{true}](x \mapsto \tau) \\
\text{p-AND} & \quad \forall i \quad C \vdash p_i : \tau \leadsto \Delta_i \\
& \quad C \vdash p_1 \land p_2 : \tau \leadsto \Delta_1 \times \Delta_2 \\
\text{p-OR} & \quad \forall i \quad C \vdash p_i : \tau \leadsto \Delta \\
& \quad C \vdash p_1 \lor p_2 : \tau \leadsto \Delta \\
\text{p-CSTR} & \quad \forall i \quad C \land D \vdash p_i : \tau_i \leadsto \Delta_i \\
& \quad K :: \forall \bar{\alpha}.\beta[D], \tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha}) \\
& \quad \beta \# \text{ftv}(C) \\
& \quad C \vdash K.p_1 \cdots p_n : \varepsilon(\bar{\alpha}) \leadsto \exists \beta[D](\Delta_1 \times \cdots \times \Delta_n)
\end{align*}
\]
Patterns (non-syntax-directed)
\[
\begin{align*}
\text{p-EQIN} & \quad C \vdash p : \tau' \leadsto \Delta \\
& \quad C \vdash \tau = \tau' \\
& \quad C \vdash p : \tau \leadsto \Delta \\
\text{p-SubOut} & \quad C \vdash p : \tau \leadsto \Delta' \\
& \quad C \vdash \Delta' \leq \Delta \\
& \quad C \vdash p : \tau \leadsto \Delta \\
\text{p-HIDE} & \quad \bar{\alpha} \# \text{ftv}(\tau, \Delta) \\
& \quad \exists \bar{\alpha}.C \vdash p : \tau \leadsto \Delta
\end{align*}
\]
Expressions (syntax-directed)
\[
\begin{align*}
\text{VAR} & \quad \Gamma(x) = \sigma \\
& \quad C \vdash \exists \sigma \\
& \quad C, \Gamma \vdash x : \sigma \\
\text{CSTR} & \quad \forall i \quad C, \Gamma \vdash e_i : \tau_i \\
& \quad K :: \forall \bar{\alpha}.\beta[D], \tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha}) \\
& \quad C, \Gamma \vdash K.e_1 \cdots e_n : \varepsilon(\bar{\alpha}) \\
& \quad C \vdash D \\
& \quad C, \Gamma \vdash \lambda(e_1 \cdots e_n) : \tau \\
\text{APP} & \quad C, \Gamma \vdash e_1 : \tau' \rightarrow \tau \\
& \quad C, \Gamma \vdash e_2 : \tau' \\
& \quad C, \Gamma \vdash e_1 e_2 : \tau \\
\text{FIX} & \quad C, \Gamma[x \mapsto \sigma] \vdash v : \sigma \\
& \quad C, \Gamma \vdash \mu x.v : \sigma \\
\text{LET} & \quad C, \Gamma \vdash e_1 : \sigma' \\
& \quad C, \Gamma[x \mapsto \sigma'] \vdash e_2 : \sigma \\
& \quad C, \Gamma \vdash \text{let } x = e_1 \text{ in } e_2 : \sigma
\end{align*}
\]
Expressions (non-syntax-directed)
\[
\begin{align*}
\text{Gen} & \quad C \land D, \Gamma \vdash e : \tau \\
& \quad \bar{\alpha} \# \text{ftv}(\Gamma, C) \\
& \quad C \land \exists \bar{\alpha}.D, \Gamma \vdash e : \forall \bar{\alpha}[D].\tau \\
\text{Inst} & \quad C, \Gamma \vdash e : \forall \bar{\alpha}[D].\tau \\
& \quad C \vdash D \\
& \quad C, \Gamma \vdash e : \tau \\
\text{Sub} & \quad C, \Gamma \vdash e : \tau' \\
& \quad C \vdash \tau' \leq \tau \\
& \quad C, \Gamma \vdash e : \tau \\
\text{Hide} & \quad C, \Gamma \vdash e : \sigma \\
& \quad \bar{\alpha} \# \text{ftv}(\Gamma, \sigma) \\
& \quad \exists \bar{\alpha}.C, \Gamma \vdash e : \sigma
\end{align*}
\]
Clauses
\[
\begin{align*}
\text{Clause} & \quad C \vdash p : \tau' \leadsto \exists \beta[D]\Gamma' \\
& \quad C \land D, \Gamma', \Gamma \vdash e : \tau \\
& \quad \beta \# \text{ftv}(C, \Gamma, \tau) \\
& \quad C, \Gamma \vdash p.e : \tau' \rightarrow \tau
\end{align*}
\]
Figure 6: Typing rules
the guarded (bounded) existential quantification $\exists \beta[D][]$, which ensures that the abstract type variables $\beta$ remain local.
- **p-EqIN** allows replacing the type $\tau$ with an arbitrary type $\tau'$, provided they are provably equal under $C$. We require $\tau = \tau'$, rather than $\tau \leq \tau'$ only: although the latter condition does not compromise type safety, it appears to create complications with type inference.
- **p-SubOUT** allows weakening the environment fragment produced by a pattern, in accordance with the subsumption ordering defined earlier.
- **p-Hide** makes some type variables local to a subderivation, which helps manage names: it is analogous to **Hide**.
**Example 4.21.** The following is a valid derivation:
\[
\frac{\text{Int} :: \forall \alpha[\alpha = \text{int}], \text{ty}(\alpha)}{\text{true} \vdash \text{Int} : \text{ty}(\alpha) \leadsto \exists \emptyset[\alpha = \text{int}] \emptyset} \quad \text{p-Cstr}
\]
Its conclusion may be read as follows. First, it is valid to match a value of type $\text{ty}(\alpha)$ against the pattern $\text{Int}$. Furthermore, if successful, this test guarantees that $\alpha$ is $\text{int}$. The pattern $\text{Int}$ does not introduce any abstract type variables or bind any variables. In the next example, we refer to this derivation as $(d_1)$.
Here is another valid derivation:
\[
\frac{\forall i \in \{1, 2\} \quad \alpha = \beta_1 \times \beta_2 \vdash t_i : \text{ty}(\beta_i) \leadsto (t_i : \text{ty}(\beta_i))}{\text{Pair} :: \forall \alpha \beta_1 \beta_2 [\alpha = \beta_1 \times \beta_2]. \text{ty}(\beta_1) \cdot \text{ty}(\beta_2) \rightarrow \text{ty}(\alpha)} \quad \text{true} \vdash \text{Pair} (t_1, t_2) : \text{ty}(\alpha) \leadsto \exists \beta_1 \beta_2 [\alpha = \beta_1 \times \beta_2] (t_1 : \text{ty}(\beta_1); t_2 : \text{ty}(\beta_2)) \quad \text{p-Cstr}
\]
Its conclusion may be read as follows. First, it is valid to match a value of type $\text{ty}(\alpha)$ against the pattern $\text{Pair} (t_1, t_2)$. Furthermore, if successful, this test guarantees that there exist types $\beta_1$ and $\beta_2$ such that $\alpha$ is $\beta_1 \times \beta_2$ and the variables $t_1$ and $t_2$ are bound to values of types $\text{ty}(\beta_1)$ and $\text{ty}(\beta_2)$, respectively. In the next example, we refer to this derivation as $(d_2)$.
Let us now briefly review the rules that concern expressions. They are standard, that is, identical to those of $\text{HML}(X)$, up to minor cosmetic differences; see, for instance, Odersky et al. (1999) or Pottier and Rémy (2005). Our version of $\text{Fix}$ allows *polymorphic recursion*, often an essential feature in programs that involve guarded algebraic data types, as illustrated in §2. $\text{Gen}$ performs generalization, turning a type into a type scheme, while $\text{Inst}$ performs the converse operation. $\text{Sub}$ allows replacing a type $\tau'$ with an arbitrary type $\tau$, provided the latter is provably a supertype of the former under $C$. $\text{Hide}$ makes some type variables local to a subderivation, which helps manage names.
There remains to explain $\text{Clause}$, which assigns a function type $\tau' \rightarrow \tau$ to a clause $p.e$. The pattern $p$ is checked against the argument type $\tau'$, yielding an environment fragment $\exists \beta[D]\Gamma'$. Then, the expression $e$ is required to have type $\tau$, under an assumption augmented with $D$ and an environment augmented with $\Gamma'$. By requiring the type variables $\beta$ to be fresh, the third premise ensures that they remain abstract within $e$; this condition is identical to that found in the elimination construct for existential types (Läuer and Odersky, 1994). A key point, here, is the fact that $e$ is typechecked under the augmented constraint $C \land D$. In other words, the type system exploits the presence of a *dynamic* check, namely pattern matching, to obtain new *static* information. As a result, in a function defined by cases, each clause may be typechecked assuming *different* constraints.
Example 4.22. Here is a valid derivation for the first clause in the definition of print, the generic printing function defined in §2.1. We assume that the environment $\Gamma$ assigns type $int \rightarrow unit$ to the variable $\text{print\_int}$ and exploit the derivation $(d_1)$ of Example 4.21.
\[
\begin{align*}
&\ldots \\
&\alpha = int, \Gamma \vdash \lambda x.\text{print\_int} \ x : int \rightarrow unit \\
&\alpha = int \vdash int \rightarrow unit \leq \alpha \rightarrow unit \\
&\text{true}, \Gamma \vdash \text{Int}.\lambda x.\text{print\_int} \ x : ty(\alpha) \rightarrow \alpha \rightarrow unit \quad \text{CLAUSE}
\end{align*}
\]
The assumption $\alpha = int$, which appears in the conclusion of $(d_1)$, is made available in the second premise of CLAUSE, and is exploited by SUB. The derivation concludes that the clause $\text{Int}.\lambda x.\text{print\_int} \ x$ has type $ty(\alpha) \rightarrow \alpha \rightarrow unit$, where $\alpha$ is unconstrained: indeed, the hypothesis $\alpha = int$, which is necessary to typecheck the right-hand side of the clause, is local.
Here is a valid derivation for the second clause that defines print. (The intermediate call to $\text{print\_string}$ is omitted for brevity.) We assume that the environment $\Gamma$ assigns type scheme $\forall \alpha.ty(\alpha) \rightarrow \alpha \rightarrow unit$ to $\text{print}$, so as to be able to typecheck the recursive calls to $\text{print}$. We write $\Gamma'$ for the environment $(t_1 : ty(\beta_1); t_2 : ty(\beta_2))$.
\[
\begin{align*}
&\ldots \\
&\alpha = \beta_1 \times \beta_2, \Gamma' \vdash \lambda(x_1, x_2).\langle \text{print } t_1 \ x_1; \text{print } t_2 \ x_2 \rangle : \beta_1 \times \beta_2 \rightarrow unit \\
&\alpha = \beta_1 \times \beta_2 \vdash \beta_1 \times \beta_2 \rightarrow unit \leq \alpha \rightarrow unit \\
&\text{true}, \Gamma \vdash \text{Pair}(t_1, t_2).\lambda(x_1, x_2).\langle \text{print } t_1 \ x_1; \text{print } t_2 \ x_2 \rangle : ty(\alpha) \rightarrow \alpha \rightarrow unit \quad \text{CLAUSE}
\end{align*}
\]
This derivation has identical structure. The type variables $\beta_1$ and $\beta_2$ do not appear in its conclusion: they are local to the subderivation rooted at CLAUSE’s second premise. The hypothesis $\alpha = \beta_1 \times \beta_2$ is also local to this subderivation.
By starting with the above two derivations and applying Abs, Gen, and Fix, it is straightforward to derive $\text{true}, \Gamma_0 \vdash \mu \text{print}.\ldots : \forall \alpha.ty(\alpha) \rightarrow \alpha \rightarrow unit$, where $\Gamma_0$ assigns type $int \rightarrow unit$ to $\text{print\_int}$ and where the dots stand for the body of $\text{print}$’s definition. Thus, the function $\text{print}$, as defined in §2, is well-typed in (all instances of) HMG($X$).
We now conclude our description of the typing rules with a number of technical remarks concerning the formulation of the rules.
Remark 4.23. One could define another version of p-Or, whose premises produce two distinct environment fragments $\Delta_1$ and $\Delta_2$, and whose conclusion produces the disjunction $\Delta_1 + \Delta_2$. By reflexivity of $+$, by F-LUB, and by p-SUBOUT, the two formulations are equivalent. Disjunction is explicitly used in the constraint generation rules (§5).
Remark 4.24. Some dialects of ML, such as Objective Caml, allow disjunction patterns to bind variables (as we do here). These programming languages provide the user with a choice between writing several clauses that have a common right-hand side, say $(K_1 \ x).e$ and $(K_2 \ x).e$, or writing a single clause, such as $(K_1 \ x \lor K_2 \ x).e$. In Objective Caml, the two idioms are semantically equivalent, but the latter admits fewer typings, because it requires both occurrences of $x$ to have
a common type. By contrast, one may check that, in $\text{HMG}(X)$, the two idioms do admit the same typings. Thus, our treatment of disjunction patterns is more precise than that of Objective Caml, even when no guarded algebraic data types are involved.
This seems to be the most natural way of dealing with disjunction patterns in $\text{HMG}(X)$. It is somewhat costly, because it requires either generating a disjunction constraint (§5), thus reflecting the two possible manners in which $x$ is defined, or textually duplicating $e$ prior to type inference, as suggested above. Either method basically amounts to typechecking $e$ twice. Fortunately, in the common case where $p_1$ and $p_2$ bind no variables and are associated with an ordinary (as opposed to guarded) algebraic data type, the disjunction is trivial (its members are identical), so $e$ needs only be typechecked once.
\begin{remark}
The reader might be surprised by the fact that $\text{P-CSTR}$’s conclusion assigns type $\varepsilon(\bar{\alpha})$ to the pattern, thus requiring the type constructor $\varepsilon$ to be applied to a vector of distinct type variables $\bar{\alpha}$, rather than to a vector of arbitrary types $\bar{\tau}$. In fact, by exploiting the non-syntax-directed rules $\text{P-EQLN}$, $\text{P-SUBOUT}$, and $\text{P-HIDE}$, as well as a weakening lemma (Lemma 4.30), it is possible to prove that this causes no loss of expressiveness.
The same technique is used in the formulation of $\text{INST}$, where a type scheme may be instantiated only with a vector of distinct type variables $\bar{\alpha}$, as opposed to a vector of arbitrary types $\bar{\tau}$. By exploiting $\text{SUB}$, $\text{HIDE}$, and Lemma 4.30, it is possible to prove that this causes no loss of expressiveness. This technique is standard: see, for instance, Sulzmann et al. (1999).
\end{remark}
\begin{remark}
One might wonder whether some non-syntax-directed rules such as $\text{P-SUBOUT}$ and $\text{P-HIDE}$ are really useful, that is, whether they really make the type system more expressive. Indeed, one may prove that these rules enjoy a few normalization properties, such as the following three. (A \textit{shape} is a term whose nodes are names of typing rules and whose leaves are holes. We say that a shape \textit{may be replaced} with a new shape if and only if, for every typing derivation that ends with an instance of the former, there exists a derivation of the same judgment that ends with an instance of the latter and otherwise has the same structure.)
- the shape $\text{P-CSTR(P-SUBOUT}(\cdot)\text{)}$ may be replaced with $\text{P-SUBOUT(P-CSTR}(\cdot)\text{)}$;
- the shape $\text{CLAUSE(P-SUBOUT}(\cdot)\text{)}$ may be replaced with $\text{CLAUSE}$, modulo a weakening of the environment in $\text{CLAUSE}$’s second premise;
- the shape $\text{CLAUSE(P-HIDE}(\cdot)\text{)}$ may be replaced with $\text{HIDE(CLAUSE}(\cdot)\text{)}$.
One might hope to establish, by proving enough normalization properties in this style, that all uses of $\text{P-SUBOUT}$, of $\text{P-HIDE}$, or of both rules, can be eliminated. However, this is not true in general. This is essentially due to the following two negative properties:
- the shape $\text{P-CSTR(P-HIDE}(\cdot)\text{)}$ may \textit{not} in general be replaced with $\text{P-HIDE(P-CSTR}(\cdot)\text{)}$: such a replacement is possible when only ordinary algebraic data types are involved (see Remark 4.29);
- the shape $\text{P-HIDE(P-SUBOUT}(\cdot)\text{)}$ may \textit{not} in general be replaced with $\text{P-SUBOUT(P-HIDE}(\cdot)\text{)}$.
For these reasons, it is not obvious that the present definition of $\text{HMG}(X)$ can be made simpler.\footnote{In fact, it is not even clear that the present definition of $\text{HMG}(X)$ is optimal.}
Remark 4.27. The analogue of p-EqIN is missing in Xi et al.’s treatment (2003). In fact, in their typing rules for patterns (Xi et al., 2003, Figure 3), no rule allows exploiting the type equations contained in the assumption $\Delta_0$. This causes some safe programs that involve nested patterns to be rejected.
Remark 4.28. It is worth noting that p-CSTR propagates type information in a top-down manner, as previously pointed out, but not sideways. That is, the information gained by ensuring that $p_1, \ldots, p_i$ match cannot be exploited to prove that $p_{i+1}, \ldots, p_n$ are well-typed. This is apparent in the fact that every $p_i$ is checked under the same assumption, namely $C \land D$.
As a result of this decision, some programs that might seem natural are ill-typed. Consider, for instance, an uncurried version of print:
```ocaml
let rec print : ∀α.ty(α) × α → unit = fun tx ->
match tx with
| (Int, x) ->
print_int x
| (Pair (t1, t2), (x1, x2)) ->
print t1 x1; print_string " * "; print t2 x2
```
This version of print expects a pair of a runtime type representation and a value. If the first component of the pair is Int, then the second component must be an integer value $x$; if the first component is an application of Pair, then the second component must be a pair $(x_1, x_2)$. So, the code appears to make perfect sense, and is perhaps even easier to read than in its original curried form.
It is, however, ill-typed in our system, because the second component of the pair $tx$ must unconditionally be both an integer and a pair. It would be well-typed under a more liberal version of p-CSTR where type information is propagated in a left-to-right fashion: then, $tx$’s second component would be required to be an integer (resp. a pair) only when $tx$’s first component is an application of Int (resp. Pair).
It would be possible to prove that this relaxed version of p-CSTR is still consistent with the operational semantics given in §3, that is, it does not compromise type safety. So, why do we reject it?
The reason is as follows: suppose we adopt the relaxed rule, and view the above version of print as well-typed. Then, we must ensure that the compiler does not generate code that begins by examining the second component of the pair $tx$ and blindly dereferences it, without checking whether it is an integer or a pair, to access $x_1$ and $x_2$. There seem to be two ways of guaranteeing this:
- either specify, in some way, that tuples are examined in a left-to-right manner;
- or allow integers and pairs to be distinguished at runtime.
The first option appears ad hoc (why left-to-right, rather than right-to-left, or some other strategy?). The second option requires every value to carry a type tag at runtime, which is unnecessary in ML, and undesirable for efficiency reasons.
One should perhaps point out that the semantics of pattern matching given in §3 does assume that values have unambiguous runtime representations, since (for instance) it specifies that $K_1$ does not match $K_2$, even if these (distinct) data constructors belong to distinct algebraic data types.
In ML, however, the type system enjoys the often unstated property that one never attempts, at runtime, to match $K_1$ against $K_2$ unless both are associated with the same algebraic data type. This property, which is stated by Lemma 4.40 in the present paper, is the reason why values need not carry runtime tags that identify their type. Although adopting the second option above would preserve type safety, it would violate this property, leading to a less efficient compilation scheme.
These somewhat subtle considerations are the reason why we stick to the strict version of p-Cstr. This choice in turn has implications on the design of the type inference algorithm. Indeed, adopting the relaxed version of p-Cstr would lead to different, perhaps simpler, constraint generation rules.
One should also point out that none of these problems arises if the language does not have nested patterns. Indeed, in a language where patterns are shallow, the above version of print cannot be written. Instead of a single, complex test, the programmer is in fact forced to perform a cascade of simple tests, where the ordering between tests is explicit. This eliminates the problem.
**Remark 4.29.** It is interesting to study how the type system degenerates when all data types are ordinary (as opposed to guarded) algebraic data types, that is, when every data constructor has a declaration of the form $K :: \forall \alpha.\tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})$. Then, in every instance of p-Cstr, $\beta$ and $D$ must be $\emptyset$ and true, respectively, so that the rule may be written:
\[
\frac{\text{p-Cstr}}{\forall i \quad C \vdash p_i : \tau_i \leadsto \Delta_i \quad K :: \forall \bar{\alpha}.\tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})}{C \vdash K p_1 \cdots p_n : \varepsilon(\bar{\alpha}) \leadsto (\Delta_1 \times \cdots \times \Delta_n)}
\]
Then, by exploiting the properties stated in Remark 4.26, one may prove that p-SubOut and p-Hide may be suppressed from the type system without affecting the set of valid judgments about expressions.
Let us also remove the pattern 0 from the language, since it does not exist in ML. Then, in the absence of 0 and of p-SubOut, and under the simplified version of p-Cstr above, all environment fragments must have the form $\exists \beta[\text{true}] \Gamma$. Thus, judgments about patterns may take the simplified form $C \vdash p : \tau \leadsto \Gamma$, where $\Gamma$ is a simple environment. This in turn allows simplifying Clause as follows:
\[
\frac{\text{Clause}}{C \vdash p : \tau' \leadsto \Gamma' \quad C, \Gamma \vdash e : \tau}{C, \Gamma \vdash p.e : \tau' \rightarrow \tau}
\]
This is a standard rule in HM(X): the expression $e$ is typechecked in an environment extended with new bindings, but no fresh type variables are introduced, and the constraint assumption remains unchanged.
**4.7 Type soundness**
We now establish several properties of the type system HMG($X$), beginning with some standard weakening and normalization lemmas, and culminating with subject reduction and progress theorems.
**Lemma 4.30 (Weakening).** Assume $C_1 \vdash C_2$. If $C_2 \vdash p : \tau \leadsto \Delta$ (resp. $C_2, \Gamma \vdash ce : \sigma$) is derivable, then there exists a derivation of $C_1 \vdash p : \tau \leadsto \Delta$ (resp. $C_1, \Gamma \vdash ce : \sigma$) of the same structure.
Lemma 4.31. \( C, \Gamma \vdash e : \sigma \) implies \( C \vdash \exists \sigma \).
Next come three auxiliary normalization lemmas. They are standard: they come unmodified from the theory of HM\((X)\). The terminology employed in these statements was defined in Remark 4.26.
Lemma 4.32. The shape \( \text{Inst}(\text{Gen}(\cdot)) \) may be replaced with \( \text{Hide}(\text{Sub}(\cdot)) \).
Lemma 4.33. The shape \( \text{Hide}(\text{Gen}(\cdot)) \) may be replaced with \( \text{Gen}(\text{Hide}(\cdot)) \).
Lemma 4.34. \( \text{App}(\text{Sub}(\text{Abs}(\cdot_1)), \cdot_2) \) may be replaced with \( \text{Sub}(\text{App}(\text{Abs}(\cdot_1), \text{Sub}(\cdot_2))) \).
Building upon these lemmas, we now establish the main normalization result. An instance of \( \text{Inst} \) or \( \text{Gen} \) is trivial if its conclusion is identical to its premise. A typing derivation is normal if and only if (a) there are no trivial instances of \( \text{Inst} \) or \( \text{Gen} \); (b) every instance of \( \text{Gen} \) appears either at the root of the derivation or as a premise of a syntax-directed rule; (c) every instance of \( \text{Hide} \) appears either at the root of the derivation or as a premise of \( \text{GEN} \); and (d) at every subexpression of the form \( (\lambda \bar{x})e \), \( \text{ABS} \) and \( \text{APP} \) are consecutive, that is, they are never separated by an instance of a non-syntax-directed rule.
Lemma 4.35 (Normalization). Every valid typing judgment admits a normal derivation.
We now prove that HMG\((X)\) is sound, via Wright and Felleisen’s syntactic approach (1994). We establish a few technical results, then give subject reduction and progress theorems. We begin with a basic substitution lemma, whose proof is straightforward:
Lemma 4.36 (Substitution). \( C, \Gamma \vdash [x \mapsto \sigma'] ce : \sigma \) and \( C, \emptyset \vdash e : \sigma' \) imply \( C, \Gamma \vdash [x \mapsto c]ce : \sigma \).
Next comes the key technical lemma that helps establishing subject reduction for pattern matching. We state it first, and explain it next.
Lemma 4.37. Assume \( v \) matches \( p \) and \( C, \emptyset \vdash v : \tau \) and \( C \vdash p : \tau \leadsto \Delta \) hold. Write \( \Delta \) as \( \exists \bar{\beta}(D)\Gamma \), where \( \bar{\beta} \neq \text{ftv}(C) \). Then, there exists a constraint \( H \) such that \( H \vdash D \) and \( C \equiv \exists \bar{\beta}.H \) and, for every \( x \in \text{dpv}(p) \), \( H, \emptyset \vdash [p \mapsto v]x : \Gamma(x) \) holds.
To explain this complex statement, it is best to first consider the simple case where \( \bar{\beta} \) is empty and \( D \) is true. In that case, we have \( C \equiv H \). Thus, the lemma’s statement may be specialized as follows: if \( v \) matches \( p \) and \( C, \emptyset \vdash v : \tau \) and \( C \vdash p : \tau \leadsto \Gamma \) hold, then, for every \( x \in \text{dpv}(p) \), \( C, \emptyset \vdash [p \mapsto v]x : \Gamma(x) \) holds. In other words, the value that \( x \) receives when matching \( v \) against \( p \) does indeed have the type that was predicted.
In the general case, the idea remains the same, but the statement must account for the abstract types \( \bar{\beta} \). It still holds that \( [p \mapsto v]x \) has type \( \Gamma(x) \), albeit under a constraint \( H \), which extends \( C \) with information about the type variables \( \bar{\beta} \), as stated by the property \( C \equiv \exists \bar{\beta}.H \). The exact amount of extra information carried by \( H \) is unknown, but is strong enough to guarantee that \( D \) holds, as stated by the property \( H \vdash D \).
\[
\begin{align*}
\neg 0 &= 1 \\
\neg 1 &= 0 \\
\neg x &= 0 \\
\neg(K \ p_1 \cdots p_n) &= (\bigvee_{i \in [1, n]} K \ 1 \cdots 1 \cdot \neg p_i \cdot 1 \cdots 1) \\
&\quad \lor (\bigvee_{K' \sim K, K' \neq K} K' \ 1 \cdots 1) \\
\neg(p_1 \lor p_2) &= \neg p_1 \land \neg p_2 \\
\neg(p_1 \land p_2) &= \neg p_1 \lor \neg p_2
\end{align*}
\]
Figure 7: Computing the complement of a pattern
**Remark 4.38.** The statement of Lemma 4.37 guarantees that \( H \vdash C \land D \) holds. One might wonder whether it could be simplified by requiring \( H \) to coincide with \( C \land D \). It turns out that it cannot. Consider, for instance, an unparameterized algebraic data type \( \varepsilon \), whose sole data constructor is \( K : \forall \beta. \beta \rightarrow \varepsilon \). (The type \( \varepsilon \) is an encoding of the existential type \( \exists \beta. \beta \) in the style of Läuer and Odersky (1994).) Let \( v \) be \( K \ 3 \), where \( 3 \) has type \( \text{int} \); let \( p \) be \( K \ x \); let \( C \) and \( D \) be \( \text{true} \); let \( \tau \) be \( \varepsilon \); let \( \Delta \) be \( \exists \beta.(x : \beta) \). Then, the hypotheses of Lemma 4.37 are met, so there must exist a constraint \( H \) such that \( H, \emptyset \vdash 3 : \beta \) holds. It is obvious that taking \( H \equiv C \land D \equiv \text{true} \) will not do, because \( 3 \) does not have type \( \beta \) for an arbitrary \( \beta \). In fact, the weakest choice that meets this requirement is \( H \equiv \text{int} \leq \beta \). This choice turns out to be acceptable. Indeed, the other two goals of the lemma, namely \( \text{int} \leq \beta \vdash \text{true} \) and \( \exists \beta.(\text{int} \leq \beta) \equiv \text{true} \), are also met. In short, the constraint \( H \) provides a link between the abstract type (here, the type variable \( \beta \)) and its underlying concrete representation (here, the type \( \text{int} \)).
Using the previous lemmas, it is possible to give a reasonably concise proof of subject reduction.
**Theorem 4.39 (Subject reduction).** \( C, \emptyset \vdash e : \sigma \) and \( e \rightarrow e' \) imply \( C, \emptyset \vdash e' : \sigma \).
We now turn to the proof of the progress theorem. In programming languages equipped with pattern matching, such as ML, it is well-known that well-typedness alone does not ensure progress: indeed, a well-typed \( \beta \)-redex \( (\lambda p_1.e_1 \cdots p_n.e_n)\ v \) may still be irreducible if none of \( p_1, \ldots, p_n \) matches \( v \). For this reason, we first establish progress under the assumption that every case analysis is exhaustive, as determined by a simple syntactic criterion. Then, we show how, in the presence of guarded algebraic data types, this criterion may be refined so as to take type information into account.
Our syntactic criterion for exhaustiveness is standard: it is, in fact, identical to that of ML. It uses almost no type information: it only requires being able to determine whether two data constructors \( K \) and \( K' \) are associated with the same algebraic data type \( \varepsilon \). (We write \( K \sim K' \) when they are.) It relies on the notion of complement of a pattern, which is standard (Xi, 2003) and whose definition is recalled in Figure 7. A case analysis \( \lambda(p_1.e_1 \cdots p_n.e_n) \) is said to be exhaustive if and only if the pattern \( \neg(p_1 \lor \cdots \lor p_n) \) is empty. How to determine whether a pattern is empty was discussed in §3.3.
It is important to note that the pattern \( p \lor \neg p \) is in general not equivalent to 1: this is due to the definition of \( \neg(K \ p_1 \cdots p_n) \), where only the data constructors compatible with \( K \) are enumerated. For instance, because the two data constructors associated with the algebraic data type constructor \( \text{ty} \) are \( \text{Int} \) and \( \text{Pair} \) (§2.1), we have \( \text{Int} \lor \neg \text{Int} = \text{Int} \lor \text{Pair} \ 1 \cdot 1 \neq 1 \).
The next lemma uses the type system to work around this difficulty. It guarantees that, if $p$ has type $\tau$, then $p \lor \neg p$ matches every value of type $\tau$. In other words, in a well-typed program, the values that are matched against a pattern $p$ cannot be arbitrary: they are guaranteed to match $p \lor \neg p$. This property allows dispensing with runtime type tags; this issue was discussed in Remark 4.28.
The hypotheses of the lemma are analogous to those of Lemma 4.37. It is, however, oriented towards proving progress, rather than subject reduction.
**Lemma 4.40.** If $C, \emptyset \vdash v : \tau$ and $C \vdash p : \tau \leadsto \Delta$ hold, where $C$ is satisfiable, then $v$ matches $p \lor \neg p$.
It is now straightforward to establish progress, under the hypothesis that every case analysis is exhaustive.
**Lemma 4.41.** If $E[e]$ is well-typed, then so is $e$.
**Theorem 4.42 (Progress).** If $e$ is well-typed and contains exhaustive case analyses only, then it is either reducible or a value.
A closed expression $e$ is **stuck** if it is neither reducible nor a value; it is said to **go wrong** if it reduces to a stuck expression. We may now state a first type soundness result:
**Theorem 4.43 (Type Soundness).** If $e$ is well-typed and contains exhaustive case analyses only, then it does not go wrong.
As promised earlier, we now turn to the definition of a more precise exhaustiveness criterion. In ML, nonexhaustive case analyses are either rejected or silently made exhaustive by extending them with a default clause whose right-hand side triggers a runtime error. In the presence of guarded algebraic data types, however, this purely syntactic criterion becomes unsatisfactory: although it remains correct, one can do better.
Indeed, the type assigned to a function may allow determining that some branches can never be taken: this is what Xi (1999) refers to as **dead code elimination**. For instance, the function $\lambda \text{Int}.3$ is not exhaustive, as per our syntactic criterion, because $\neg \text{Int}$ is $\text{Pair} \cdot 1 \cdot 1$, which is nonempty. However, if the function is declared to have type $\text{ty}(\text{int}) \rightarrow \text{int}$, then pattern matching cannot fail, because no value of type $\text{ty}(\text{int})$ matches $\text{Pair} \cdot 1 \cdot 1$. If we were to extend the function with a clause guarded by the pattern $\text{Pair} \cdot 1 \cdot 1$, then the right-hand side of that clause would be typechecked under the assumption $\exists \beta_1 \beta_2. (\text{int} = \beta_1 \times \beta_2)$, which is absurd, that is, equivalent to $\text{false}$. This allows the typechecker to recognize that such a clause is superfluous.
Thus, we proceed as follows: prior to typechecking, we automatically complete every case analysis with a default clause, so as to make it exhaustive. The right-hand side of every default clause consists of a special expression $\bot$, which is irreducible, but not a value: it is stuck, and models a runtime error. To statically prevent these runtime errors and preserve type safety, we ensure that $\bot$ is never well-typed: its associated typing rule is
$$\begin{array}{c}
\text{Dead} \\
\text{false}, \Gamma \vdash \bot : \sigma
\end{array}$$
Thus, checking that the completed case analysis, as a whole, is well-typed, guarantees that the newly inserted default clause can never be selected at runtime. This in turn means that no code needs be generated for it: it only exists in the typechecker’s eyes, not in the compiler’s.
To formalize this discussion, let $[\cdot]$ be the procedure that completes every case analysis with a default clause, defined by letting
$$[\lambda(p_1.e_1 \cdots p_n.e_n)] = \lambda(p_1.[e_1] \cdots p_n.[e_n] \cdot \neg (p_1 \lor \cdots \lor p_n).\bot)$$
and letting $[\cdot]$ be a homomorphism with respect to all other expression forms. Then, we may revisit the type soundness result as follows:
**Theorem 4.44 (Progress revisited).** If $[e]$ is well-typed, then $e$ is either reducible or a value.
**Theorem 4.45 (Type soundness revisited).** If $[e]$ is well-typed then $e$ does not go wrong.
Let us stress that, according to Theorem 4.45, typechecking the modified program $[e]$, where every case analysis has been completed with a default clause, guarantees type soundness for the original program $e$. The syntactic notion of exhaustiveness defined earlier is no longer involved in this statement.
The ideas presented here are not new: see Xi (1999; 2003). However, a formal type soundness statement for a type system equipped with guarded algebraic data types and pattern matching does not seem to exist in the literature; Theorem 4.45 fills this gap.
**Remark 4.46.** One issue was left implicit in the above discussion: is our new, type-based criterion always at least as precise as the previous, syntactic one? The answer is positive, provided the pattern $\neg (p_1 \lor \cdots \lor p_n)$, which guards the default clause in the definition of $[\cdot]$, is *normalized* as per the rules of Figure 4. Indeed, consider a function $e = \lambda(p_1.e_1 \cdots p_n.e_n)$, and assume it is exhaustive, that is, $\neg (p_1 \lor \cdots \lor p_n)$ is empty. Then, applying the above procedure, we have $\neg (p_1 \lor \cdots \lor p_n) \leadsto^* 0$, so $[e]$ is $\lambda(p_1.[e_1] \cdots p_n.[e_n] \cdot 0.\bot)$. Then, because $C, \Gamma \vdash 0.\bot : \tau_1 \rightarrow \tau_2$ holds for all $C$, $\Gamma$, $\tau_1$ and $\tau_2$, one may check that $e$ and $[e]$ admit the same typings.
**Remark 4.47.** More generally, normalizing patterns and *resolving sequentiality* (Xi, 2003) may improve the accuracy of type checking in the presence of guarded algebraic data types. These transformations may, however, cause an exponential increase in the size of patterns, and introduce many new disjunction patterns, so it is unclear whether they should be performed automatically or upon request of the programmer.
**Remark 4.48.** In practice, $[e]$ may be ill-typed because the typechecker is unable to prove that some of the inserted $\bot$’s are unreachable. In that case, one can choose to accept the program, provided these instances of $\bot$ are compiled down to code that generates a runtime error. In ML, this concerns all instances of $\bot$, except those that are guarded by the pattern 0. In HMG($X$), branches guarded by patterns other than 0 may be recognized by the typechecker as dead code: indeed, any pattern that gives rise to an empty environment fragment (one that contains the constraint false) qualifies.
## 5 Type inference
We now turn to type inference, with the aim of reducing type inference to constraint solving.
Due to the presence of polymorphic recursion, well-typedness in HMG($X$) is undecidable (Henglein, 1993). Thus, to begin, we restrict the language by requiring every $\mu$-bound variable to be
explicitly annotated with a type scheme. This restriction is not necessary for type soundness, which explains why it was not made earlier.
Furthermore, looking ahead towards §6, it is also useful to require that every $\lambda$-abstraction carry an explicit type annotation. A cheap way of achieving this effect is to merge the $\mu$ and $\lambda$ binders into a single construct, so that only one type annotation has to be written. Since, in practice, the $\mu$ binder is mainly used to define functions, this design choice seems acceptable.
**Remark 5.1.** Instead of merging $\mu$ and $\lambda$ into a single construct, one could also keep them separate and require each of them to carry a type annotation. A simple form of *local type inference* (Pierce and Turner, 2000) could then be used to propagate a type annotation from one to the other when they are adjacent, allowing the user to provide only one type annotation in that case. We come back to this point in Remark 6.11. ◊
Thus, the language of expressions becomes:
$$e ::= x \mid \mu(x : \exists \beta.\sigma).\lambda \bar{e} \mid K \bar{e} \mid e \ e \mid \text{let } x = e \text{ in } e$$
Without loss of generality, we require the type scheme $\sigma$ carried by every $\mu$ construct to be of the form $\forall \gamma[C],\tau_1 \rightarrow \tau_2$, that is, to syntactically present an arrow type. We do *not* require $\sigma$ to be closed. Instead, $\sigma$ may have free type variables, which must be included in $\beta$, so that the type annotation $\exists \beta.\sigma$ is closed. (It would be straightforward to suppress the prefix $\exists \beta$, allowing $\sigma$’s free type variables to be bound elsewhere. This is an orthogonal issue.)
Not requiring $\sigma$ to be closed seems important, for a couple of different reasons. The main reason is that this allows defining $\mu.x.\lambda \bar{e}$ as syntactic sugar for $\mu(x : \exists \beta_1 \beta_2.\beta_1 \rightarrow \beta_2).\lambda \bar{e}$. In other words, unannotated functions are still part of the language. They carry the uninformative type annotation $\exists \beta_1 \beta_2.\beta_1 \rightarrow \beta_2$, which means *same (monomorphic) function type*. Note, however, that functions that exploit polymorphic recursion must carry a truly explicit, nontrivial type annotation. The second reason is that some functions do not admit a closed type scheme. This is often the case for functions that are nested inside another, larger function: see, for instance, `rmap_f` in §2. Unfortunately, in §6, we shall be led to further restrict the shape of type annotations, causing `rmap_f` to be rejected.
The typing rules Abs and Fix are replaced with the following new rule, a combination of Abs, Gen, and Fix, where the type scheme assigned to $x$ is taken from the annotation instead of being guessed. This is the key point that makes type inference decidable again.
$$\frac{\text{FixAbs}}{\forall i, \ C \land D, \Gamma[x \mapsto \sigma] \vdash c_i : \tau \quad \bar{\alpha} \neq \text{ftv}(C,\Gamma) \quad \sigma = \forall \bar{\alpha}[D].\tau}{C \land \exists \bar{\alpha}.D, \Gamma \vdash \mu(x : \exists \beta.\sigma).\lambda \bar{e} : \sigma}$$
Because the modified type system is a restriction of the original one, it is still sound. In the following, we show that type inference for it may be reduced to constraint solving.
### 5.1 Patterns
We begin our treatment of type inference by defining a procedure that computes principal typing judgments for patterns. It consists of two functions of a pattern $p$ and a type $\tau$, given in Figure 8. As usual, the new type variables that appear in the right-hand side of an equation must be chosen...
Patterns (constraint generation)
\[
\begin{align*}
\langle 0 \downarrow \tau \rangle &= \text{true} \\
\langle 1 \downarrow \tau \rangle &= \text{true} \\
\langle x \downarrow \tau \rangle &= \text{true} \\
\langle p_1 \land p_2 \downarrow \tau \rangle &= \langle p_1 \downarrow \tau \rangle \land \langle p_2 \downarrow \tau \rangle \\
\langle p_1 \lor p_2 \downarrow \tau \rangle &= \langle p_1 \downarrow \tau \rangle \land \langle p_2 \downarrow \tau \rangle \\
\langle K p_1 \cdots p_n \downarrow \tau \rangle &= \exists \bar{\alpha}.(\varepsilon(\bar{\alpha}) = \tau \land \forall \bar{\beta}.D \Rightarrow \land_i \langle p_i \downarrow \tau_i \rangle) \\
&\quad \text{where } K :: \forall \bar{\alpha}\bar{\beta}[D].\tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})
\end{align*}
\]
Patterns (environment fragment generation)
\[
\begin{align*}
\langle 0 \uparrow \tau \rangle &= \exists \bar{\sigma}[\text{false}] \bar{\sigma} \\
\langle 1 \uparrow \tau \rangle &= \exists \bar{\sigma}[\text{true}] \bar{\sigma} \\
\langle x \uparrow \tau \rangle &= \exists \bar{\sigma}[\text{true}](x \mapsto \tau) \\
\langle p_1 \land p_2 \uparrow \tau \rangle &= \langle p_1 \uparrow \tau \rangle \times \langle p_2 \uparrow \tau \rangle \\
\langle p_1 \lor p_2 \uparrow \tau \rangle &= \langle p_1 \uparrow \tau \rangle + \langle p_2 \uparrow \tau \rangle \\
\langle K p_1 \cdots p_n \uparrow \tau \rangle &= \exists \bar{\alpha}\bar{\beta}[\varepsilon(\bar{\alpha}) = \tau \land D](\times_i \langle p_i \uparrow \tau_i \rangle) \\
&\quad \text{where } K :: \forall \bar{\alpha}\bar{\beta}[D].\tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})
\end{align*}
\]
Figure 8: Type inference for patterns
fresh for the parameters that appear on its left-hand side. Here, in the last equation of each group, $\bar{\alpha}$ and $\bar{\beta}$ must be fresh for $\tau$.
The constraint $\langle p \downarrow \tau \rangle$ asserts that it is legal to match a value of type $\tau$ against $p$, while the environment fragment $\langle p \uparrow \tau \rangle$ represents knowledge about the bindings that arise when such a test succeeds. (Note that our use of $\downarrow$ and $\uparrow$ has nothing to do with bidirectional type inference (Pierce and Turner, 2000).)
The first three rules of each group directly reflect p-Empty, p-Wild, and p-Var.
The fourth rules of the first and second groups directly reflect p-And. The former states that it is legal to match a value of type $\tau$ against $p_1 \land p_2$ if and only if it is legal to match such a value against $p_1$ and against $p_2$ separately. The latter rule states that the knowledge thus obtained is the conjunction of the knowledge obtained by matching against $p_1$ and $p_2$ separately.
The fifth rules of the first and second groups reflect p-Or. More precisely, they directly reflect the variant of p-Or that was alluded to in Remark 4.23. The latter states that the knowledge obtained by matching a value against $p_1 \lor p_2$ is the disjunction of the knowledge obtained by matching against $p_1$ and $p_2$ separately. This is our first use of the fragment disjunction operator $+$.
The last rule of the first group may be read as follows: it is legal to match a value of type $\tau$ against $K p_1 \cdots p_n$ if and only if, for some types $\bar{\alpha}$, $\tau$ is of the form $\varepsilon(\bar{\alpha})$ and, for all types $\bar{\beta}$ that satisfy $D$ and for every $i \in \{1, \ldots, n\}$, it is legal to match a value of type $\tau_i$ against $p_i$. The use of
universal quantification and of implication encodes the fact that the types $\beta$ must be considered abstract, but may safely be assumed to satisfy $D$.
The last rule of the second group records the knowledge that, if $Kp_1 \cdots p_n$ matches a value of type $\tau$, then, for some types $\alpha$ and $\beta$, $\tau$ is of the form $\varepsilon(\alpha)$ and $D$ is satisfied. This knowledge is combined, using the fragment conjunction operator, with that obtained by successfully matching the value against the subpatterns $p_i$.
The last two rules may be simplified when the expected type $\tau$ happens to be of the desired form, that is, of the form $\varepsilon(\alpha)$. This is stated by the next lemma.
**Lemma 5.2.** Assume $K :: \forall \alpha.\beta[D],\tau_1 \cdots \tau_n \rightarrow \varepsilon(\alpha)$. Then, the two constraints $\langle Kp_1 \cdots p_n \downarrow \varepsilon(\alpha) \rangle$ and $\forall \beta.D \Rightarrow \wedge_i \langle p_i \downarrow \tau_i \rangle$ are equivalent. Furthermore, the two environment fragments $(Kp_1 \cdots p_n \downarrow \varepsilon(\alpha))$ and $\exists \beta[D](\times_i \langle p_i \downarrow \tau_i \rangle)$ are equivalent.
**Example 5.3.** It is easy to check that the constraint $\langle Int \downarrow ty(\alpha) \rangle$ is equivalent to true. Thus, it is legal to match a value of type $ty(\alpha)$ against the pattern $Int$, for an arbitrary $\alpha$. Furthermore, the environment fragment $\langle Int \downarrow ty(\alpha) \rangle$ is $\exists \alpha'[ty(\alpha') = ty(\alpha) \land \alpha' = int]\emptyset$, which is in fact equivalent to $\exists \alpha[\alpha = int]\emptyset$. These results are consistent with the first derivation given in Example 4.21.
Here is another example. By Lemma 5.2, we find that $\langle Pair(t_1,t_2) \downarrow ty(\alpha) \rangle$ is equivalent to
$$\forall \beta_1.\beta_2.(\alpha = \beta_1 \times \beta_2) \Rightarrow (\langle t_1 \downarrow ty(\beta_1) \rangle \land \langle t_2 \downarrow ty(\beta_2) \rangle)$$
Since every $\langle t_i \downarrow ty(\beta_i) \rangle$ is true, the whole constraint is equivalent to true. Thus, it is valid to match a value of type $ty(\alpha)$ against the pattern $Pair(t_1,t_2)$. Similarly, $\langle Pair(t_1,t_2) \uparrow ty(\alpha) \rangle$ is equivalent to $\exists \beta_1.\beta_2[\alpha = \beta_1 \times \beta_2](t_1 : ty(\beta_1);t_2 : ty(\beta_2))$. These results are, again, consistent with the second derivation in Example 4.21.
Lemmas 5.4 and 5.6 state that the rules give rise to judgments that are both correct and complete (that is, principal), respectively. To establish completeness, we exploit the auxiliary Lemma 5.5, which states that, under the assumption that $\tau$ and $\tau'$ are equal, they are interchangeable for the purposes of constraint generation.
**Lemma 5.4 (Correctness).** $\langle p \downarrow \tau \rangle \vdash p : \tau \leadsto \langle p \uparrow \tau \rangle$.
**Lemma 5.5.** $\tau = \tau' \land \langle p \downarrow \tau \rangle \vdash \langle p \downarrow \tau' \rangle$ and $\tau = \tau' \vdash \langle p \uparrow \tau \rangle \leq \langle p \uparrow \tau' \rangle$ hold.
**Lemma 5.6 (Completeness).** $C \vdash p : \tau \leadsto \Delta$ implies $C \vdash \langle p \downarrow \tau \rangle$ and $C \vdash \langle p \uparrow \tau \rangle \leq \Delta$.
### 5.2 Expressions and clauses
Let us now turn to expressions and clauses. Given an environment $\Gamma$, an expression $e$ and an expected type $\tau$, the constraint $(\Gamma \vdash e : \tau)$ is intended to represent a necessary and sufficient condition for $e$ to have type $\tau$ under environment $\Gamma$. Its definition appears in Figure 9. Again, the new type variables that appear in the right-hand side of an equation must be chosen fresh for the parameters that appear on its left-hand side.
The rules that govern expressions are standard: see, for instance, Sulzmann et al. (1999), Simonet (2003a), or Pottier & Rémy (2005).
The first rule, which deals with a variable $x$, requires the expected type $\tau$ to be an instance of the type scheme $\Gamma(x)$.
**Expressions**
\[
\langle \Gamma \vdash x : \tau \rangle = \Gamma(x) \leq \tau
\]
\[
\langle \Gamma \vdash e_1 \cdot e_2 : \tau \rangle = \exists \alpha. (\langle \Gamma \vdash e_1 : \alpha \rightarrow \tau \rangle \land \langle \Gamma \vdash e_2 : \alpha \rangle)
\]
\[
\langle \Gamma \vdash K \ e_1 \cdots e_n : \tau \rangle = \exists \bar{\alpha} \bar{\beta}. (\wedge_i \langle \Gamma \vdash e_i : \tau_i \rangle \land D \land \varepsilon(\bar{\alpha}) \leq \tau)
\]
where \(K : \forall \bar{\alpha} \bar{\beta}[D]. \tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})\)
\[
\langle \Gamma \vdash \text{let } x = e_1 \text{ in } e_2 : \tau \rangle = \langle \Gamma[x \mapsto \forall \alpha[C], \alpha] \vdash e_2 : \tau \rangle \land \exists \alpha.C
\]
where \(C\) is \(\{\Gamma \vdash e_1 : \alpha\}\)
\[
\langle \Gamma \vdash \mu(x : \exists \bar{\beta}, \sigma). \lambda \bar{c} : \tau \rangle = \exists \bar{\beta}. (\langle \forall \bar{\gamma}, C \Rightarrow \Gamma[x \mapsto \sigma] \vdash \bar{c} : \tau_1 \rightarrow \tau_2 \rangle) \land \sigma \leq \tau
\]
where \(\sigma\) is \(\forall \bar{\gamma}[C]. \tau_1 \rightarrow \tau_2\)
**Clauses**
\[
\langle \Gamma \vdash p.e : \tau_1 \rightarrow \tau_2 \rangle = [p \downarrow \tau_1] \land \forall \bar{\beta}. D \Rightarrow \langle \Gamma' \vdash e : \tau_2 \rangle
\]
where \(\exists \bar{\beta}[D]\Gamma'\) is \([p \uparrow \tau_1]\)
---
Figure 9: Type inference for expressions and clauses
The second rule, which deals with an application \(e_1 \cdot e_2\), ensures that the domain type of the function \(e_1\) matches the type of the argument \(e_2\) by using the fresh type variable \(\alpha\) to stand for both of them.
The third rule may be viewed as a particular case of the previous two. Indeed, a data constructor application is dealt with in the same way as an application of a variable to \(n\) arguments. The only difference resides in the fact that the type scheme associated with \(K\) is fixed instead of found in the environment \(\Gamma\).
The fourth rule deals with let-polymorphism. It typechecks \(e_2\) in an environment extended with a binding of \(x\) to the type scheme \(\forall \alpha.(\langle \Gamma \vdash e_1 : \alpha \rangle).\alpha\), which is a principal type scheme for \(e_1\).
In the fifth rule, we write \(\langle \Gamma \vdash \bar{c} : \tau_1 \rightarrow \tau_2 \rangle\) for \(\wedge_i \langle \Gamma \vdash c_i : \tau_1 \rightarrow \tau_2 \rangle\) when \(\bar{c}\) is \((c_1, \ldots, c_n)\). The rule implements polymorphic recursion by ensuring that the clauses \(c\) have type scheme \(\sigma\) under the hypothesis that \(x\) has type scheme \(\sigma\). The context \(\forall \bar{\gamma}, C \Rightarrow []\) is used to encode this requirement. The expected type \(\tau\) is required to be an instance of \(\sigma\). The type variables \(\bar{\beta}\), whose value was not specified by the user, are existentially bound, so it is up to the constraint solver to determine their value.
**Remark 5.7.** For unannotated functions of the form \(\mu x.\lambda \bar{c}\), which were defined to be syntactic sugar for \(\mu(x : \exists \bar{\beta}_1 \bar{\beta}_2, \beta_1 \rightarrow \beta_2). \lambda \bar{c}\), this gives rise to the following derived rule:
\[
\langle \Gamma \vdash \mu x.\lambda \bar{c} : \tau \rangle = \exists \bar{\beta}_1 \bar{\beta}_2. (\langle \Gamma[x \mapsto \beta_1 \rightarrow \beta_2] \vdash \bar{c} : \beta_1 \rightarrow \beta_2 \rangle \land \beta_1 \rightarrow \beta_2 \leq \tau)
\]
This is a standard rule for monomorphic, recursive functions.
We now turn to the last rule, which deals with clauses, and where most of the novelty resides. First, the function’s domain type is required to match the pattern’s type, via the constraint \([p \downarrow \tau_1]\). Then, the clause’s right-hand side \(e\) is required to have type \(\tau_2\) under a context extended with new abstract types \(\bar{\beta}\) and a new typing hypothesis \(D\) and under an extended environment \(\Gamma'\), all three of which are obtained by evaluating \([p \uparrow \tau_1]\).
Remark 5.8. This rule does not exploit the presence of a type annotation at every $\lambda$-abstraction. Indeed, its parameters are $\tau_1$ and $\tau_2$ only. The information carried by $\bar{\gamma}$ and $C$, which are also supplied by the programmer at every “$\mu\lambda$” construct, is not used. The modified constraint generation rules in §6 do take advantage of this extra information.
Example 5.9. Here is the constraint generated for the first clause in the definition of print, at type $ty(\alpha) \rightarrow \alpha \rightarrow unit$. As in Example 4.22, we assume that the environment $\Gamma$ assigns type $int \rightarrow unit$ to the variable $print\_int$. We implicitly exploit the results of Example 5.3. We write $e_1$ for $\lambda x.print\_int x$.
$$\langle \Gamma \vdash Int.e_1 : ty(\alpha) \rightarrow \alpha \rightarrow unit \rangle$$
$$\equiv \text{true} \land \alpha = int \Rightarrow \langle \Gamma \vdash e_1 : \alpha \rightarrow unit \rangle$$
It is easy to check that the subconstraint $\langle \Gamma \vdash \lambda x.print\_int x : \alpha \rightarrow unit \rangle$ is equivalent to $\alpha \leq int$. Indeed, for $x$ to be a valid argument to $print\_int$, its type must be a subtype of $int$. So, the above constraint reduces to $\alpha = int \Rightarrow \alpha \leq int$, which is equivalent to true.
Next, here is the constraint generated for the second clause in the definition of print, at type $ty(\alpha) \rightarrow \alpha \rightarrow unit$. (As in Example 4.22, the intermediate call to $print\_string$ is omitted for brevity.) We assume that the environment $\Gamma$ assigns type scheme $\forall \alpha.ty(\alpha) \rightarrow \alpha \rightarrow unit$ to $print$, so as to be able to typecheck the recursive calls to $print$, and again implicitly exploit the results of Example 5.3. We write $e_2$ for $\lambda(x_1,x_2).(print t_1 x_1; print t_2 x_2)$.
$$\langle \Gamma \vdash Pair(t_1,t_2).e_2 : ty(\alpha) \rightarrow \alpha \rightarrow unit \rangle$$
$$\equiv \text{true} \land \forall \beta_1 \beta_2.\alpha = \beta_1 \times \beta_2 \Rightarrow \langle \Gamma \vdash e_2 : \alpha \rightarrow unit \rangle$$
Again, it can be checked that this constraint is equivalent to true.
The constraint generated for the entire function $\mu print.\ldots.$, in the environment $\Gamma_0$ of Example 4.22 and at a fresh type variable $\gamma$, is the following:
$$\langle \Gamma_0 \vdash \mu print.\ldots : \gamma \rangle \equiv \quad \forall \alpha.(\alpha = int \Rightarrow \langle \Gamma \vdash e_1 : \alpha \rightarrow unit \rangle$$
$$\land \forall \beta_1 \beta_2.\alpha = \beta_1 \times \beta_2 \Rightarrow \langle \Gamma \vdash e_2 : \alpha \rightarrow unit \rangle)$$
$$\land \exists \alpha.ty(\alpha) \rightarrow \alpha \rightarrow unit \leq \gamma$$
The first part of the constraint, delimited by the universal quantifier $\forall \alpha$, ensures that the function admits the type scheme provided by the programmer, that is, $\forall \alpha.ty(\alpha) \rightarrow \alpha \rightarrow unit$. Each implication corresponds to one clause of the function. The second part of the constraint, delimited by the existential quantifier $\exists \alpha$, constrains the expected type $\gamma$ to be an instance of this type scheme.
There remains to prove that the constraint generation rules for expressions and clauses are correct and complete. Correctness is straightforward:
**Theorem 5.10 (Correctness).** $\langle \Gamma \vdash ce : \tau \rangle, \Gamma \vdash ce : \tau$.
The next two auxiliary lemmas state that $\langle \Gamma \vdash ce : \tau \rangle$ is contravariant in $\Gamma$ and covariant in $\tau$. In other words, if the expected type is less precise, or if the environment is more precise, then the generated constraint is less restrictive.
**Lemma 5.11.** $\langle \Gamma \vdash ce : \tau \rangle \land \tau \leq \tau' \vdash \langle \Gamma \vdash ce : \tau' \rangle$.
Lemma 5.12. \( \Gamma' \leq \Gamma \land (\Gamma \vdash ce : \tau) \vdash (\Gamma' \vdash ce : \tau) \).
The next auxiliary lemma states that the rule that deals with clauses exploits the environment fragment generated by invoking \((p \uparrow \tau_1)\) in a contravariant manner. In other words, if the environment fragment is more precise, then the generated constraint is less restrictive.
Lemma 5.13. Assume \( \bar{\beta}_1 \bar{\beta}_2 \neq \text{ftv}(\Gamma, \tau) \). We have \( \exists \bar{\beta}_1[D_1] \Gamma_1 \leq \exists \bar{\beta}_2[D_2] \Gamma_2 \land \forall \bar{\beta}_2.D_2 \Rightarrow (\Gamma \Gamma_2 \vdash e : \tau) \vdash \forall \bar{\beta}_1.D_1 \Rightarrow (\Gamma \Gamma_1 \vdash e : \tau) \).
These lemmas allow establishing completeness:
Theorem 5.14 (Completeness). \( C, \Gamma \vdash ce : \forall \bar{\alpha}[D], \tau \) and \( \bar{\alpha} \neq \text{ftv}(\Gamma) \) imply \( C \vdash \forall \bar{\alpha}.D \Rightarrow (\Gamma \vdash ce : \tau) \).
Using Theorems 5.10 and 5.14, as well as Lemma 4.31, it is easy to prove that \( e \) is well-typed under environment \( \Gamma \) if and only if the constraint \( \exists \alpha.(\Gamma \vdash e : \alpha) \), where \( \alpha \) is fresh for \( \Gamma \), is satisfiable. Thus, we have reduced type inference to constraint solving.
Type inference for HM\((X)\) is usually reduced to constraint solving for a logic that includes basic predicates (such as subtyping), conjunction, and existential quantification. Here, we make use of more first-order connectives, including universal quantification and implication.
Nevertheless, this is enough to show that type inference for some instances of HMG\((X)\) is decidable. For instance, assuming no basic predicates other than subtyping are available, and assuming subtyping is structural, constraint solving is decidable (Kuncak and Rinard, 2003). This includes the important case where subtyping is in fact interpreted as equality.
However, such a result remains weak, because the complexity of constraint solving for the first-order theory of equality is nonelementary (Vorobyov, 1996). To strengthen our result, we must work a bit more and ensure that we actually generate tractable constraints. This is the topic of §6.
## 6 Tractable type inference
Roughly speaking, one may identify three sources of complexity in the constraints that we generate.
One is that we have made the entire constraint language available to the programmer. Indeed, the constraints supplied by the programmer as part of data constructor declarations or type annotations eventually become components of the constraint generated by the type inference algorithm. Fortunately, we are willing to restrict the constraint language that is available to the programmer, so this source of complexity is easily eliminated.
Another is our use of logical disjunction \( \lor \), hidden inside the fragment disjunction operator \( + \), in the treatment of disjunction patterns. By construction, every such use of disjunction appears inside the left component of an implication. As a result, it is possible to lift it up and out of the implication, turning it into a conjunction: \( \forall \bar{\beta}.(D_1 \lor D_2) \Rightarrow C \) is equivalent to \( (\forall \bar{\beta}.D_1 \Rightarrow C) \land (\forall \bar{\beta}.D_2 \Rightarrow C) \). This operation, which duplicates the constraint \( C \), corresponds to eliminating disjunction patterns in the source program, at the cost of some (possibly exponential) code duplication, as done by Xi (2003). In our constraint-based approach, the worst-case behavior is still exponential; however, an efficient constraint solver might simplify \( C \) before duplicating it, thus sharing much of the work. In an approach based on textual duplication of source expressions, every copy must be typechecked separately.
The last source of complexity, which is most problematic, is our frequent use of combined universal quantification and implication contexts, of the form $\forall \beta.D \Rightarrow []$. If uncontrolled, these allow encoding negation, since $\neg D$ is $D \Rightarrow \text{false}$. The bulk of this section is devoted to establishing that it is possible to use only rigid implication, of the form $\forall \beta.D \Rightarrow []$, where $\text{ftv}(D)$ is a subset of $\beta$. A look at Figures 8 and 9 shows that none of the implication constructs that the current rules generate is, in general, rigid.
More precisely, we plan to reformulate the constraint generation rules so as to produce constraints that conform to the following restricted grammar:
\[
L ::= R \mid L \land L \mid L \lor L \\
R ::= \pi \bar{\tau} \mid R \land R \mid \exists \bar{\alpha}.R \mid \forall \bar{\beta}.L \Rightarrow R \quad \text{where } \text{ftv}(L) \subseteq \bar{\beta}
\]
We refer to constraints of the form $R$ as tractable. They are made up of basic predicate application, conjunction, existential quantification, and rigid implication, of the form $\forall \beta.L \Rightarrow R$, where every type variable that appears free in $L$ is locally quantified, i.e. $\text{ftv}(L) \subseteq \bar{\beta}$. The left-hand side of an implication, of the form $L$, may involve nested conjunctions and disjunctions of tractable constraints.
In order to be able to generate tractable constraints, we must require the type annotations supplied by the programmer to contain sufficient information. This requirement, as well as the modified constraint generation rules, are given in §6.1. Then, we argue that so-called tractable constraints are indeed easier to solve than arbitrary constraints, and define a constraint solving algorithm in the specific case of equality (§6.2).
### 6.1 Generating tractable constraints
As announced above, we restrict the constraint language available in data constructor declarations.
**Requirement 6.1.** In every declaration of the form $K :: \forall \bar{\alpha}.\bar{\beta}[D].\tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})$, the constraint $D$ must in fact be of the form $R$.
Because we wish to define a conservative extension of HM($X$), and, more generally, of its extension with existential types in the style of Läufér and Odersky (1994), we cannot require programs that lie in this fragment of the language to carry type annotations. In other words, type annotations must be required only at functions that exploit polymorphic recursion or analyze a guarded algebraic data type. This leads us to begin with a precise definition of what it means for an algebraic data type to be guarded.
**Definition 6.2.** The data constructor $K :: \forall \bar{\alpha}.\bar{\beta}[D].\tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})$ is guarded if and only if $\bar{\alpha} \cap \text{ftv}(D) \neq \emptyset$. The algebraic data type constructor $\varepsilon$ is guarded if and only if at least one of the data constructors associated with $\varepsilon$ is guarded. A pattern $p$ is guarded if and only if some data constructor that occurs in $p$ is associated with a guarded algebraic data type. A clause $p.c$ is guarded if and only if $p$ is guarded. A vector of clauses $\bar{c}$ is guarded if and only if one of its elements is guarded.
Algebraic data types that are not guarded in the above sense are ordinary algebraic data types or encodings of existential types in the style of Läufér and Odersky (1994).
We are now able to express our requirement concerning type annotations:
**Requirement 6.3.** Every expression \( \mu (x : \exists \bar{\beta}. \forall \bar{\gamma}[C], \tau_1 \rightarrow \tau_2). \lambda \bar{c} \) must satisfy:
(i) \( C \) is of the form \( R \);
(ii) \( \text{ftv}(C) \subseteq \bar{\gamma} \);
(iii) if \( \bar{c} \) is guarded, then \( \text{ftv}(\tau_1) \subseteq \bar{\gamma} \).
Condition (i) restricts the constraint language that is available to the programmer, as announced earlier. Condition (ii) guarantees that the implication \( \forall \bar{\gamma}. C \Rightarrow [] \), which appears in the constraint generation rule for \( \mu \) constructs (Figure 9), is rigid. The effect of condition (iii) is more technical, and is explained below when we describe the new constraint generation rules.
What are the practical implications of this requirement? Roughly speaking, it leads to distinguishing three cases. First, functions that do not involve polymorphic recursion and that do not perform case analysis on a guarded algebraic data type may carry no annotation—that is, they may carry the uninformative annotation \( \exists \bar{\beta}_1 \bar{\beta}_2. \bar{\beta}_1 \rightarrow \bar{\beta}_2 \). Second, functions that do involve polymorphic recursion, but not guarded algebraic data types, must carry an annotation, subject to conditions (i) and (ii). Because these conditions are fulfilled when \( C \) is true, these functions may in particular carry any annotation of the form \( \exists \bar{\beta}. \forall \bar{\gamma}. \tau_1 \rightarrow \tau_2 \). Third, functions that do perform case analysis on a guarded algebraic data type must carry an annotation that satisfies all three conditions above. In such a case, only \( \tau_2 \) may contain occurrences of the type variables \( \bar{\beta} \). Experience seems to suggest that the extra flexibility afforded by this feature is minimal: not much expressiveness would be lost by requiring the type annotation to be closed (that is, to be of the form \( \forall \bar{\gamma}[C], \tau_1 \rightarrow \tau_2 \)) in that case.
**Remark 6.4.** Requirement 6.3 may sound rather drastic. In fact, we spent considerable time exploring a more flexible approach, which turned out to be much more complex, for a marginal benefit. Some experience with an actual implementation seems necessary to tell whether the present restriction is acceptable in practice. Among the examples given in §2, only rmap_f violates the requirement.
We are now ready to reformulate the constraint generation rules, focusing on the third case above, where the novelty lies, since the former two do not involve guarded algebraic data types. How do we, in that case, massage the existing rules so that they produce rigid implications only?
The main idea is to fuse adjacent implications. For instance, consider the context \( \forall \bar{\gamma}. C \Rightarrow \forall \bar{\beta}. D \Rightarrow [] \), where \( \text{ftv}(C) \subseteq \bar{\gamma} \) and \( \text{ftv}(D) \subseteq \bar{\gamma} \bar{\beta} \) hold. Then, while the first implication is rigid, the second one isn’t. However, this context is equivalent to \( \forall \bar{\gamma} \bar{\beta}. (C \land D) \Rightarrow [] \), a rigid implication. More generally, we wish to fuse implications that are nested, but not adjacent, because some other connector lies in between. When this connector is a conjunction, we may push the external (rigid) implication into each component of the conjunction, by rewriting \( \forall \bar{\gamma}. C \Rightarrow ([]_1 \land []_2) \) into \( (\forall \bar{\gamma}. C \Rightarrow []_1) \land (\forall \bar{\gamma}. C \Rightarrow []_2) \). When it is an existential quantifier, we are, in general, stuck. However, if this existentially quantified constraint happens to be of the particular form \( \exists \bar{a}. (\varepsilon(\bar{a}) = \tau \land []) \), where \( \bar{a} \) is fresh for \( \tau \), then, by Lemma 4.3, it may also be written \( \exists \bar{a}. (\varepsilon(\bar{a}) = \tau) \land \forall \bar{a}. (\varepsilon(\bar{a}) = \tau) \Rightarrow [] \). In this new formulation, no existential quantifier lies on the path from the root to the hole \( [] \), so fusing can again take place.
We now propose a modified version of the constraint generation rules that incorporates these ideas, so as to directly produce tractable constraints. The modified rule set is given in Figure 10. (Again, the new type variables that appear in the right-hand side of an equation must be chosen fresh for the parameters that appear on its left-hand side.) In order to distinguish between the old and new rule sets, we now use square brackets \( [\cdots] \) instead of bananas \( \langle \cdots \rangle \).
Patterns
\[
\begin{align*}
[0 \downarrow \forall \bar{\gamma}[C], \tau] &= \text{true} \\
[1 \downarrow \forall \bar{\gamma}[C], \tau] &= \text{true} \\
[x \downarrow \forall \bar{\gamma}[C], \tau] &= \text{true} \\
[p_1 \land p_2 \downarrow \forall \bar{\gamma}[C], \tau] &= [p_1 \downarrow \forall \bar{\gamma}[C], \tau] \land [p_2 \downarrow \forall \bar{\gamma}[C], \tau] \\
[p_1 \lor p_2 \downarrow \forall \bar{\gamma}[C], \tau] &= [p_1 \downarrow \forall \bar{\gamma}[C], \tau] \land [p_2 \downarrow \forall \bar{\gamma}[C], \tau] \\
[K p_1 \cdots p_n \downarrow \forall \bar{\gamma}[C], \tau] &= (\forall \bar{\gamma}, C \Rightarrow \exists \bar{\alpha}, \varepsilon(\bar{\alpha}) = \tau) \land_i [p_i \downarrow \forall \bar{\gamma}\bar{\alpha}\bar{\beta}[C \land \varepsilon(\bar{\alpha}) = \tau \land D], \tau_i]
\end{align*}
\]
where \( K :: \forall \bar{\alpha}\bar{\beta}[D], \tau_1 \rightarrow \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha}) \)
Clauses
\[
[\Gamma \vdash p.e : \forall \bar{\gamma}[C], \tau_1 \rightarrow \tau_2] = [p \downarrow \forall \bar{\gamma}[C], \tau_1] \land \forall \bar{\gamma}\bar{\beta}.(C \land D) \Rightarrow [\Gamma \Gamma' \vdash e : \tau_2]
\]
where \( \exists \bar{\beta}[D]\Gamma' \) is \( (p \uparrow \tau_1) \)
Expressions
\[
[\Gamma \vdash \mu(x : \exists \bar{\beta}, \sigma).\lambda \bar{c} : \tau] = \begin{cases}
\exists \bar{\beta}.([\Gamma[x \mapsto \sigma] \vdash \bar{c} : \sigma] \land \sigma \leq \tau) & \text{if } \bar{c} \text{ is guarded} \\
\{\text{omitted}\} & \text{otherwise}
\end{cases}
\]
Figure 10: Constraint generation, revisited
The new rules that associate constraints to patterns are parameterized not only by a type \( \tau \), as in Figure 8, but also by a set of so-called rigid type variables \( \bar{\gamma} \) and a constraint \( C \). The rules expect and preserve the invariant \( \text{ftv}(C, \tau) \subseteq \bar{\gamma} \). The idea is to perform constraint generation and to fuse the context \( \forall \bar{\gamma}, C \Rightarrow [] \) at once. This is made precise by the next lemma, which relates the old and new rules.
**Lemma 6.5.** \( [p \downarrow \forall \bar{\gamma}[C], \tau] \) is equivalent to \( \forall \bar{\gamma}, C \Rightarrow (p \downarrow \tau) \).
**Lemma 6.6.** If \( \text{ftv}(C, \tau) \subseteq \bar{\gamma} \) holds, then \( [p \downarrow \forall \bar{\gamma}[C], \tau] \) is tractable.
The rules that associate environment fragments to patterns need not be modified: they already produce tractable constraints.
Similarly, the new rule that deals with clauses is parameterized not only by a type \( \tau_1 \rightarrow \tau_2 \), but by a type scheme \( \forall \bar{\gamma}[C], \tau_1 \rightarrow \tau_2 \), which comes directly from the type annotation carried by the enclosing function. The components \( \bar{\gamma}, C, \) and \( \tau_1 \) are used to associate a constraint with the pattern at hand. Conditions (ii) and (iii) of Requirement 6.3 guarantee \( \text{ftv}(C, \tau_1) \subseteq \bar{\gamma} \), which is the invariant expected by the rules that deal with patterns. The (rigid) implication associated with the type annotation, of the form \( \forall \bar{\gamma}, C \Rightarrow [] \), is fused with the implication associated with pattern matching, of the form \( \forall \bar{\beta}, D \Rightarrow [] \). This yields an implication of the form \( \forall \bar{\gamma}\bar{\beta}.(C \land D) \Rightarrow [] \), which is rigid. Indeed, by construction, we have \( \text{ftv}(D) \subseteq \bar{\beta} \cup \text{ftv}(\tau_1) \), which, together with conditions (ii) and (iii) of Requirement 6.3, implies \( \text{ftv}(C \land D) \subseteq \bar{\gamma}\bar{\beta} \).
The new rule for functions distinguishes two cases, depending on whether \( \bar{c} \) is guarded. If it is (that is, if the case analysis involves a guarded algebraic data type), then the type scheme
found in the type annotation is used to associate a constraint with every clause, as described above. Otherwise, the function may be dealt with “as usual,” so, for the sake of brevity, we omit the corresponding constraint generation rules (see Remark 6.7). The rules that concern all other expression forms remain identical to those given in Figure 8, except bananas \( \langle \cdots \rangle \) are replaced with square brackets \( [\cdots] \).
**Remark 6.7.** Technically, the rules that we omit are those that govern case analysis in an extension of HM\((X)\) with polymorphic recursion, pattern matching with nested patterns, and (bounded) existential types in the style of Läuer and Odersky (1994). Although, to the best of our knowledge, these rules do not appear in the literature, they may be considered folklore, and are off topic in the present paper, where we wish to concentrate on guarded algebraic data types.
Unfortunately, the constraint generation rules given in §5 do not produce tractable constraints, even when only ordinary algebraic data types are involved. On the other hand, the rules given in Figure 10 do produce tractable constraints, but require \( \text{fvt}(\tau_1) \subseteq \bar{\gamma} \), so they cannot handle unannotated functions. This explains why, in order to produce tractable constraints, we end up with two independent rule sets, namely the rule set of Figure 10, which deals with functions that analyze a guarded algebraic data type, and the omitted rule set mentioned in the previous paragraph, which deals with ordinary functions.
This is a dark area in our presentation: despite substantial efforts, we have not been able to devise a (reasonably simple) rule set that covers both cases at once.
**Example 6.8.** The constraint generated for \( \mu \text{print}.\ldots \) in Example 5.9 is not tractable. Indeed, the left-hand side of each implication mentions the type variable \( \alpha \), which is certainly universally bound, but not locally: a conjunction lies on the path from the \( \forall \alpha \) quantifier to the implication.
On the other hand, the new rule set does produce a tractable constraint:
\[
[\Gamma \vdash \mu \text{print}.\ldots : \bar{\gamma}] = \begin{array}{l}
\forall \alpha. \alpha = \text{int} \Rightarrow [\Gamma \vdash e_1 : \alpha \rightarrow \text{unit}] \\
\land \forall \alpha \beta_1 \beta_2. \alpha = \beta_1 \times \beta_2 \Rightarrow [\Gamma \vdash e_2 : \alpha \rightarrow \text{unit}] \\
\land \exists \alpha. \text{ty}(\alpha) \rightarrow \alpha \rightarrow \text{unit} \leq \bar{\gamma}
\end{array}
\]
In comparison with the constraint produced in Example 5.9, the universal quantifier \( \forall \alpha \) has been pushed into both components of the conjunction. Then, inside the second component, it has been fused with the quantifier \( \forall \beta_1 \beta_2 \).
The constraint generation rules of Figure 10 are equivalent to those of Figures 8 and 9, which ensures that they still define a correct and complete type inference algorithm. Furthermore, they produce tractable constraints.
**Theorem 6.9 (Equivalence).** \( [\Gamma \vdash c : \forall \bar{\gamma}[C].\tau_1 \rightarrow \tau_2] \) is equivalent to \( \forall \bar{\gamma}. C \Rightarrow [\Gamma \vdash c : \tau_1 \rightarrow \tau_2] \). \( [\Gamma \vdash e : \bar{\tau}] \) is equivalent to \( [\Gamma \vdash e : \tau] \).
**Theorem 6.10.** \( [\Gamma \vdash c : \forall \bar{\gamma}[C].\tau_1 \rightarrow \tau_2] \) is tractable. \( [\Gamma \vdash e : \bar{\tau}] \) is tractable.
**Remark 6.11.** For the sake of simplicity, our “\( \mu X \)” construct combines recursion, abstraction, and case analysis. In other words, in a direct implementation of our framework, every function that analyzes a guarded algebraic data type must be of the restricted form:
```ocaml
let rec f : σ =
fun x -> match x with
...
```
(We are assuming, for simplicity, that $\sigma$ must be closed.) In practice, it is possible to relax this restriction slightly. For instance, one might allow $f$ to accept multiple parameters and to analyze several of them at once, a common Objective Caml idiom:
```ocaml
let rec f : $\sigma$ =
fun $x_1 \ldots x_n$ ->
match $(x_{i_1}, \ldots, x_{i_k})$ with
...
```
It is straightforward to associate a tractable constraint with this composite construct. The key reason is that *the types of the parameters $x_1, \ldots, x_n$ are known*, since they are given by the type annotation $\sigma$. Thus, these types need not be inferred, which, in terms of constraints, means that no existential quantifier needs appear between the initial universal quantifier (which corresponds to the annotated `let rec` construct) and the implications (which correspond to the `match` construct). If such an existential quantifier did occur, it would prevent fusing the universal quantifier with the implications, so as to produce rigid implications, so we would be unable to produce a tractable constraint.
It is possible to further relax the syntax of functions that analyze a guarded algebraic data type. The rule that “no existential quantifier must arise between `let rec` and `match`” means that *no type inference can take place* between these constructs. Thus, by requiring these functions to exhibit simple structure, and by locally disallowing true type inference, we are really performing a kind of *local type inference* (Pierce and Turner, 2000). This was predicted by Remark 5.1. $\diamond$
### 6.2 Solving tractable constraints in the case of equality
Why should so-called tractable constraints be easier to solve than arbitrary constraints? In particular, why should rigid implications be more tractable than arbitrary implications?
Let us begin with an informal explanation. One may say that the trouble with implication is that it involves a choice: satisfying an implication construct requires either refuting its left-hand side or satisfying its right-hand side. In the case of a rigid implication $\forall \beta.L \Rightarrow R$, it is easy to resolve this choice. Indeed, because the constraint $\exists \beta.L$ is closed, it must be equivalent to either `false` or `true`, and the solver is effectively able to tell which. If it is `false`, then the entire construct is equivalent to `true` and may be discarded. If it is `true`, the right-hand side $R$ must be examined, under the simplifying assumption that $L$, which is satisfiable, has been rewritten to a solved form.
In the following, we give a more formal justification for the tractability of these constraints by describing a constraint solving algorithm, *in the specific case where no basic predicates other than equality are available*. It is difficult to argue about the general case, because the design of a constraint solver heavily depends on the basic predicates $\pi$ at hand. Nevertheless, we do believe that the notion of rigid implication may be of interest in other cases: for instance, the first author has developed a similar notion, together with a constraint solving procedure, in the setting of structural subtyping (Simonet, 2003a).
From here on, we assume that the only basic predicate $\pi$ is equality. Thus, we are looking at a particular instance of HMG($X$), which we refer to as HMG($=$). It is well-known that the corresponding instance of HM($X$), namely HM($=$), coincides with Hindley and Milner’s type system (Pottier and Rémy, 2005). Thus, HMG($=$) is an extension of Hindley and Milner’s type system with guarded algebraic data types, as illustrated in §2.1.
Let us now explain how to solve tractable constraints in this particular case. We assume that a standard algorithm for first-order unification under a mixed prefix is given. That is, we assume that a constraint solving procedure is available for constraints defined by the following grammar:
\[ U ::= \text{false} \mid \tau = \tau \mid U \land U \mid \exists \bar{\alpha}.U \mid \forall \bar{\alpha}.U \]
The constraints \( U \) form a subset of the tractable constraints \( R \), provided \( \forall \bar{\alpha}.U \) is read as \( \forall \bar{\alpha}.\text{true} \Rightarrow U \). We assume that the unification algorithm consists of a reduction relation \( \rightarrow_u \) on constraints \( U \), specified by the following definition.
**Definition 6.12.** Let \( \rightarrow_u \) be a relation on constraints \( U \) such that:
(i) \( \rightarrow_u \) is strongly normalizing;
(ii) \( \rightarrow_u \) is meaning preserving, that is, \( U_1 \rightarrow_u U_2 \) implies \( U_1 \equiv U_2 \);
(iii) every normal form for \( \rightarrow_u \) is either satisfiable or false;
(iv) if \( U \) is a satisfiable normal form for \( \rightarrow_u \), then there exist \( \bar{\beta} \) such that \( U \) determines \( \bar{\beta} \) and \( \exists \bar{\beta}.U \) is equivalent to true.
Conditions (i) to (iii) ensure that \( \rightarrow_u \) is indeed a constraint solving procedure. Condition (iv) characterizes the structure of solved forms: in short, it states that, for every assignment of the type variables other than \( \bar{\beta} \), there exists a unique assignment of \( \bar{\beta} \) that satisfies \( U \). The type variables \( \beta \) are referred to as *eliminable* by Lassez, Maher, and Marriott (1988), while the type variables other than \( \beta \) are known as *parameters*. We do not give more details about first-order unification under a mixed prefix, because it is standard.
We now intend to show that the unification algorithm \( \rightarrow_u \) may be extended to solve tractable constraints of the form \( R \). We present the extended algorithm as a reduction relation \( \rightarrow \) on constraints, whose definition appears in Figure 11. Rewriting is performed modulo commutativity of conjunction and modulo an arbitrary context.
The definition of the extended algorithm may be explained as follows. Rule S-UNIF states that \( \rightarrow \) contains \( \rightarrow_u \), allowing the underlying unification algorithm to be invoked at any time. Rules S-AND-OR and S-ALL-OR eliminate disjunctions by lifting them up through conjunctions and implications. As noted earlier, because S-ALL-OR duplicates the right-hand side \( R \), an efficient strategy should rewrite \( R \) to a solved form first. Rules S-ALL-FALSE and S-ALL eliminate rigid implications. S-ALL-FALSE deals with implications whose left-hand side is unsatisfiable. According to the constraint generation rules given in §6.1, this situation indicates the presence of a dead
clause in the program, so one may wish to issue a warning whenever this rule is applied, unless the dead clause was automatically generated by the scheme described in §4.7. S-ALL deals with implications whose left-hand side is satisfiable, and has been reduced to a solved form. Its side conditions ensure that, when an assignment of $\beta_1$ is fixed, there exists a unique assignment of $\beta_2$ that satisfies $R_1$, so that $\forall \beta_2 . R_1 \Rightarrow []$ is in fact equivalent to $\exists \beta_2 . (R_1 \land [])$. Note that S-ALL’s right-hand side no longer contains an implication.
**Example 6.13.** Consider the rigid implication $\forall \alpha \beta_1 \beta_2 . (\alpha = \beta_1 \times \beta_2) \Rightarrow R$. The left-hand side $\alpha = \beta_1 \times \beta_2$ is a solved form, where $\alpha$ is eliminable and $\beta_1$ and $\beta_2$ are parameters. In other words, $\exists \alpha . (\alpha = \beta_1 \times \beta_2)$ is equivalent to true and $\alpha = \beta_1 \times \beta_2$ determines $\alpha$. Thus, S-ALL is applicable, and yields $\forall \beta_1 \beta_2 . \exists \alpha . (\alpha = \beta_1 \times \beta_2 \land R)$, eliminating the implication.
It is worth noting that the latter constraint is equivalent to $\forall \beta_1 \beta_2 . [\alpha \mapsto \beta_1 \times \beta_2] R$, where the substitution $[\alpha \mapsto \beta_1 \times \beta_2]$, a most general unifier of the constraint $\alpha = \beta_1 \times \beta_2$, is applied to $R$. Indeed, it would be possible to give a version of S-ALL where a most general unifier of $R_1$ is applied to $R_2$. Our presentation is equivalent, but purely constraint-based, which makes it more faithful to an efficient implementation. (Indeed, presentations that rely on substitutions do not allow reasoning about sharing. For instance, compare Robinson’s substitution-based unification algorithm (1965), whose complexity is exponential, with Huet’s graph-based algorithm (1976), whose complexity is quasi-linear, and whose most natural specification is constraint-based (Jouannaud and Kirchner, 1990; Pottier and Rémy, 2005).)
The extended algorithm fulfills the exact same specification as the standard unification algorithm which we started with, as stated by the next theorem. This proves that $\rightarrow$ provides a constraint solving algorithm for so-called tractable constraints.
**Theorem 6.14.** The reduction relation $\rightarrow$ satisfies Definition 6.12, where every occurrence of the meta-variable $U$ is replaced with $R$.
Let us stress that the structure of solved forms is the same for the extended algorithm and for the standard algorithm. In the context of type inference, this means that the structure of type schemes is the same in HMG(=) as in HM(=): that is, they are standard Hindley-Milner type schemes. In other words, extending ML with guarded algebraic data types does not affect the grammar of type schemes—an important point for programmers.
The complexity of constraint solving is exponential in the worst case, due to the presence of disjunctions. In their absence, we believe (but have not proved) that it is quasi-linear, as in the case of unification.
## Conclusion
We have attempted to give a comprehensive account of the introduction of guarded algebraic data types into a typed programming language of the Hindley-Milner family. For the sake of generality, we have adopted a constraint-based approach, in the style of HM($X$), so that type systems based on equality constraints, on subtyping constraints, or on arithmetic constraints, for example, are instances of our framework.
We have proved, in this very general setting, that the type system is sound (§4) and that, provided $\mu$ constructs carry a type annotation, type inference may be reduced to constraint solving
Then, because solving arbitrary constraints is expensive, we have further restricted the form of type annotations and proved that this allows producing so-called *tractable* constraints (§6.1). Last, in the specific setting of equality, we have explained how to solve tractable constraints (§6.2).
One of the strong points of our work is a clear separation of concerns. We have considered type soundness, decidable type inference, and tractable type inference as distinct goals, and gradually imposed the requirements necessary to reach each of them. In particular, our results show that, as far as *decidable* type inference is concerned, guarded algebraic data types do not introduce new difficulties beyond those already caused by polymorphic recursion. They do pose a new difficulty when pursuing *tractable* type inference: then, it appears necessary to request new type information, by placing more requirements on the form of type annotations.
We have chosen to deal with deep (nested) patterns, as opposed to only a shallow *case* construct, which solely examines the root of a term. This sometimes raises unexpectedly subtle issues (see Remark 4.28), and makes a few proofs significantly more involved (see e.g. Lemma 4.37).
A few weak points remain to be addressed. For instance, the requirement placed on type annotations in order to generate tractable constraints (Requirement 6.3) is strong: roughly speaking, functions that analyze a guarded algebraic data type must explicitly carry a closed type scheme. One might wonder whether this requirement is acceptable in practice, and to what extent it can be relaxed. Another inelegant aspect is the fact that our type inference algorithm uses two separate rule sets to deal with functions that analyze ordinary (Läuer–Odersky-style) algebraic data types, on the one hand, and with those that analyze guarded algebraic data types, on the other hand (see Remark 6.7).
We are currently working on a prototype implementation of HMG(=), that is, of an extension of ML with guarded algebraic data types. We hope to report on our experience in a later paper.
## A Proofs
**Proof of Lemma 3.1.** Define the *weight* of a pattern as follows:
\[
\begin{align*}
w(0) &= w(1) = w(x) = 3 \\
w(p_1 \land p_2) &= w(p_1) \times w(p_2) \\
w(p_1 \lor p_2) &= w(p_1) + 2 + w(p_2) \\
w(K\ p_1 \cdots p_n) &= 3(1 + w(p_1) \times \cdots \times w(p_n))
\end{align*}
\]
It is straightforward to check that every pattern has weight at least 3 and that each of the rules in Figure 4 is weight-decreasing. Furthermore, weight is preserved by associativity and commutativity of $\land$, by associativity of $\lor$, and is monotone with respect to arbitrary contexts. This proves that the length of any reduction sequence for $\rightarrow$ is bounded by the weight of its initial term. We note that the weight of a pattern is at most exponential in its size. □
**Proof of Lemma 3.2.** By examination of each normalization rule (Figure 4) and by definition of extended substitution (Figure 2). □
**Proof of Lemma 3.3.** We begin with an analysis of the structure of the normal forms for $\rightarrow$. It is straightforward to check that every normal form must be either 0 or a (multi-way) disjunction of one or more *definite patterns*, where a definite pattern is a (multi-way) conjunction of variables, 1’s, and *at most one* data constructor pattern, whose subpatterns are again definite.
By structural induction, it is immediate that every definite pattern matches at least one value. Similarly, so does every disjunction of one or more definite patterns.
Now, assume \( p \equiv 0 \) holds. By Lemma 3.1, \( p \) has a normal form \( p' \). By Lemma 3.2, \( p' \equiv 0 \) holds as well, so \( p' \) matches no value. By the previous paragraph, \( p' \) cannot be a disjunction of one or more definite patterns. So, by the first paragraph, \( p' \) must be 0. This proves that \( p \leadsto^* 0 \) holds. (In fact, it proves that every normal form for \( p \) is 0, which is stronger and more useful, since \( \leadsto \) is not confluent.)
Conversely, by Lemma 3.2, \( p \leadsto^* 0 \) implies \( p \equiv 0 \).
Proof of Lemma 4.3. It is clear that \( \exists \bar{\alpha}. C_1 \land \forall \bar{\alpha}. C_1 \Rightarrow C_2 \) entails \( \exists \bar{\alpha}. (C_1 \land C_2) \). Conversely, assume \( C_1 \) determines \( \bar{\alpha} \) (1). Let \( \rho \) satisfy \( \exists \bar{\alpha}. (C_1 \land C_2) \). Then, there exists a ground assignment \( \rho'' \) that coincides with \( \rho \) outside \( \bar{\alpha} \) and satisfies \( C_1 \land C_2 \). Now, pick an arbitrary ground assignment \( \rho' \) that coincides with \( \rho \) outside \( \bar{\alpha} \) and satisfies \( C_1 \). Now, \( \rho' \) and \( \rho'' \) both satisfy \( C_1 \), and coincide outside \( \bar{\alpha} \), so, by (1), \( \rho' \) and \( \rho'' \) must in fact coincide. Thus, \( \rho' \) satisfies \( C_2 \). Since this holds for an arbitrary \( \rho' \), we have in fact proved that \( \rho \) satisfies \( \forall \bar{\alpha}. C_1 \Rightarrow C_2 \). Since this holds for an arbitrary \( \rho \), we have proved that \( \exists \bar{\alpha}. (C_1 \land C_2) \) entails \( \forall \bar{\alpha}. C_1 \Rightarrow C_2 \).
Proof of Lemma 4.5. Let \( \rho \) satisfy \( D \). Then, by Definition 4.4, \( \rho(\forall \bar{\alpha}[D], \tau) \) is a superset of \( \{ \rho(\tau) \} \). Thus, \( \rho \) satisfies \( \forall \bar{\alpha}[D]. \tau \leq \tau \).
Proof of Lemma 4.6. Left to the reader. One may consult the proof of Lemma 4.8, which follows, and is dual.
Proof of Lemma 4.8. We have
\[
\rho \vdash \Delta' \leq \Delta \\
\iff \downarrow \{ \rho[\bar{\beta}' \mapsto \bar{t}'](\Gamma') / \rho[\bar{\beta}' \mapsto \bar{t}'] \vdash D' \} \subseteq \downarrow \{ \rho[\bar{\beta} \mapsto \bar{t}](\Gamma) / \rho[\bar{\beta} \mapsto \bar{t}] \vdash D \} \\
\text{by definition of } \rho \vdash \Delta' \leq \Delta \text{ of } \rho(\Delta'), \text{ and of } \rho(\Delta) \\
\iff \{ \rho[\bar{\beta}' \mapsto \bar{t}'](\Gamma') / \rho[\bar{\beta}' \mapsto \bar{t}'] \vdash D' \} \subseteq \downarrow \{ \rho[\bar{\beta} \mapsto \bar{t}](\Gamma) / \rho[\bar{\beta} \mapsto \bar{t}] \vdash D \} \\
\text{by definition of } \downarrow \\
\iff \forall \bar{t}' \quad \rho[\bar{\beta}' \mapsto \bar{t}'] \vdash D' \Rightarrow \exists \bar{t} \quad (\rho[\bar{\beta} \mapsto \bar{t}] \vdash D) \land (\rho[\bar{\beta}' \mapsto \bar{t}'](\Gamma') \leq \rho[\bar{\beta} \mapsto \bar{t}](\Gamma)) \\
\iff \forall \bar{t}' \quad \rho[\bar{\beta}' \mapsto \bar{t}'] \vdash D' \Rightarrow \exists \bar{t} \quad \rho[\bar{\beta}' \mapsto \bar{t}][\bar{\beta} \mapsto \bar{t}] \vdash (D \land \Gamma' \leq \Gamma) \\
\text{by exploiting } \bar{\beta} \not\in \text{ftv}(\Gamma') \text{ and } \bar{\beta}' \not\in \text{ftv}(\Delta) \\
\iff \rho \vdash \forall \bar{\beta}'. D' \Rightarrow \exists \bar{t}.(D \land \Gamma' \leq \Gamma)
\]
As a corollary, \( C \vdash \Delta' \leq \Delta \) is equivalent to \( C \vdash \forall \bar{\beta}'. D' \Rightarrow \exists \bar{t}.(D \land \Gamma' \leq \Gamma) \). If \( \bar{\beta}' \not\in \text{ftv}(C) \) holds, then, by lifting the \( \forall \bar{\beta}' \) quantifier up through the entailment symbol \( \vdash \), this may be written \( C \vdash D' \Rightarrow \exists \bar{t}.(D \land \Gamma' \leq \Gamma) \), that is, \( C \land D' \vdash \exists \bar{t}.(D \land \Gamma' \leq \Gamma) \).
Proof of Lemma 4.15. Assume \( \Delta \) is \( \exists \bar{\beta}[D]\Gamma \) (1), where \( \bar{\beta} \not\in \text{ftv}(\bar{\alpha}, C) \) (2). We have
\[
\rho(\exists \bar{\alpha}[C]\Delta) \\
= \rho(\exists \bar{\alpha}\bar{\beta}[C \land D]\Gamma) \\
\text{by (1), (2), and Definition 4.14} \\
= \downarrow \{ \rho[\bar{\alpha} \mapsto \bar{t}, \bar{\beta} \mapsto \bar{t}'](\Gamma) / \rho[\bar{\alpha} \mapsto \bar{t}, \bar{\beta} \mapsto \bar{t}'] \vdash C \land D \} \\
\text{by Definition 4.7} \\
= \downarrow \{ \rho[\bar{\alpha} \mapsto \bar{t}][\bar{\beta} \mapsto \bar{t}'](\Gamma) / \rho[\bar{\alpha} \mapsto \bar{t}][\bar{\beta} \mapsto \bar{t}] \vdash D \land \rho[\bar{\alpha} \mapsto \bar{t}] \vdash C \} \\
\text{by (2)} \\
= \cup \{ \rho[\bar{\alpha} \mapsto \bar{t}](\Delta) / \rho[\bar{\alpha} \mapsto \bar{t}] \vdash C \} \\
\text{by (1) and Definition 4.7}
\]
**Proof of Lemma 4.18.** Assume $\Delta_1$ and $\Delta_2$ have disjoint domains, so that $\Delta_1 \times \Delta_2$ is defined. Assume $\Delta_1$ is $\exists \beta_1 [D_1] \Gamma_1$ (1) and $\Delta_2$ is $\exists \beta_2 [D_2] \Gamma_2$, (2) where $\beta_1 \neq \beta_2$ (3), $\beta_1 \neq \text{ftv}(D_2, \Gamma_2)$ (4), and $\beta_2 \neq \text{ftv}(D_1, \Gamma_1)$ (5) hold. We have
\[
\rho(\Delta_1 \times \Delta_2)
= \rho(\exists \beta_1 \beta_2 [D_1 \land D_2] (\Gamma_1 \times \Gamma_2))
\]
by (1)-(5) and Definition 4.16
\[
= \downarrow \{\rho[\beta_1 \mapsto \bar{t}_1, \beta_2 \mapsto \bar{t}_2](\Gamma_1 \times \Gamma_2) / \rho[\beta_1 \mapsto \bar{t}_1, \beta_2 \mapsto \bar{t}_2] \vdash D_1 \land D_2\}
\]
by Definition 4.7
\[
= \downarrow \{\rho[\beta_1 \mapsto \bar{t}_1](\Gamma_1) \times \rho[\beta_2 \mapsto \bar{t}_2](\Gamma_2) / \rho[\beta_1 \mapsto \bar{t}_1] \vdash D_1 \land \rho[\beta_2 \mapsto \bar{t}_2] \vdash D_2\}
\]
by (4) and (5)
\[
= \downarrow \{\rho[\beta_1 \mapsto \bar{t}_1](\Gamma_1) / \rho[\beta_1 \mapsto \bar{t}_1] \vdash D_1\} \times \downarrow \{\rho[\beta_2 \mapsto \bar{t}_2](\Gamma_2) / \rho[\beta_2 \mapsto \bar{t}_2] \vdash D_2\}
\]
by definition of $\times$ and by distributivity of $\downarrow$ with respect to $\times$
\[
= \rho(\Delta_1) \times \rho(\Delta_2)
\]
by (1), (2), and Definition 4.7
**Proof of Lemma 4.19.** Assume $\Delta_1$ and $\Delta_2$ have a common domain, so that $\Delta_1 + \Delta_2$ is defined. Assume $\Delta_1$ is $\exists \beta_1 [D_1] \Gamma_1$ (1) and $\Delta_2$ is $\exists \beta_2 [D_2] \Gamma_2$ (2), where $\beta_1 \neq \beta_2$ (3), $\beta_1 \neq \text{ftv}(D_2, \Gamma_2)$ (4), and $\beta_2 \neq \text{ftv}(D_1, \Gamma_1)$ (5) hold. Let $\Gamma$ map every variable in the domain of $\Delta_1$ and $\Delta_2$ to a distinct type variable in $\alpha$ (6), where $\bar{\alpha} \neq \text{ftv}(\beta_1, \beta_2, D_1, D_2, \Gamma_1, \Gamma_2)$ (7) holds. We have
\[
\rho(\Delta_1 + \Delta_2)
= \rho(\exists \beta_1 \beta_2 \bar{\alpha}[(D_1 \land \Gamma \leq \Gamma_1) \lor (D_2 \land \Gamma \leq \Gamma_2)]\Gamma)
\]
by (1)-(7) and Definition 4.17
\[
= \downarrow \{\rho'(\Gamma) / \rho' \vdash \forall_i (D_i \land \Gamma \leq \Gamma_i)\}
\]
where $\rho'$ stands for $\rho[\beta_1 \mapsto \bar{t}_1, \beta_2 \mapsto \bar{t}_2, \bar{\alpha} \mapsto \bar{t}]$
by Definition 4.7
\[
= \cup_i \downarrow \{\rho'(\Gamma) / \rho' \vdash D_i \land \Gamma \leq \Gamma_i\}
\]
by the interpretation of disjunction
\[
= \cup_i \downarrow \{\bar{t} / \rho[\beta_1 \mapsto \bar{t}_1] \vdash D_i \land \bar{t} \leq \rho[\beta_1 \mapsto \bar{t}_1](\Gamma_i)\}
\]
by (4), (5), (6), and (7)
\[
= \cup_i \downarrow \{\rho[\beta_1 \mapsto \bar{t}_1](\Gamma_i) / \rho[\beta_1 \mapsto \bar{t}_1] \vdash D_i\}
\]
by definition of $\downarrow$
\[
= \cup_i \rho(\Delta_2)
\]
by idempotency of $\downarrow$, then by (1), (2), and Definition 4.7
**Proof of Lemma 4.20.** By Lemmas 4.15, 4.18, and 4.19.
**Proof of Lemma 4.30.** By structural induction.
**Proof of Lemma 4.31.** By structural induction.
**Proof of Lemma 4.32.** Consider a derivation that ends with $\text{Inst}(\text{GEN}(\cdot))$. Its conclusion is $C, \Gamma \vdash e : \tau$ (1). The premises of $\text{Inst}$ are $C, \Gamma \vdash e : \forall \bar{\alpha}[D], \tau$ (2) and $C \vdash D$ (3). The derivation of (2) ends with an instance of $\text{GEN}$ whose premises are $C' \land \theta D, \Gamma \vdash e : \theta \tau$ (4) and $\theta \bar{\alpha} \neq \text{ftv}(\Gamma, C')$
(5), where \( C \equiv C' \land \exists \bar{\alpha}.D \) (6) holds and the renaming \( \theta \) is fresh for \( \forall \bar{\alpha}[D],\tau \) (7). (By introducing \( \theta \), we account for the fact that GEN’s conclusion might mention an arbitrary \( \alpha \)-variant of the type scheme \( \forall \bar{\alpha}[D],\tau \), namely \( \forall (\theta \bar{\alpha})[\theta D],\theta \tau \).) Up to a renaming of GEN’s premises, we may require \( \theta \bar{\alpha} \neq \text{ftv}(D,\tau) \) (8). By Lemma 4.30, (4) yields \( C' \land \theta D \land \theta \bar{\alpha} = \bar{\alpha}, \Gamma \vdash e : \theta \tau \) (9). By (7), we have \( (\theta D \land \theta \bar{\alpha} = \bar{\alpha}) \equiv (D \land \theta \bar{\alpha} = \bar{\alpha}) \) (10) and \( \theta \bar{\alpha} = \bar{\alpha} \vdash \theta \tau = \tau \) (11). By (9), (10), (11), and by SUB, we obtain \( C' \land D \land \theta \bar{\alpha} = \bar{\alpha}, \Gamma \vdash e : \tau \) (12). By (5), (8), and HIDE, (12) leads to \( C' \land D \land \exists(\theta \bar{\alpha}).(\theta \bar{\alpha} = \bar{\alpha}), \Gamma \vdash e : \tau \) (13). Because \( \theta \) is a renaming, the conjunct \( \exists(\theta \bar{\alpha}).(\theta \bar{\alpha} = \bar{\alpha}) \) is a tautology. Furthermore, according to (3) and (6), \( C \equiv C' \land D \) holds. Thus, (13) is the goal (1).
**Proof of Lemma 4.33.** Consider a derivation that ends with HIDE(GEN(\( \cdot \))). Its conclusion is \( \exists \bar{\alpha}_1.C_1, \Gamma \vdash e : \sigma \) (1). The premises of HIDE are \( C_1, \Gamma \vdash e : \sigma \) (2) and \( \bar{\alpha}_1 \neq \text{ftv}(\Gamma,\sigma) \) (3). The derivation of (2) ends with an instance of GEN whose premises are \( C'_1 \land D, \Gamma \vdash e : \tau \) (4) and \( \bar{\alpha} \neq \text{ftv}(\Gamma,C'_1) \) (5) with \( C_1 \equiv C'_1 \land \exists \bar{\alpha}.D \) and \( \sigma = \forall \bar{\alpha}[D],\tau \). Up to a renaming of GEN’s premises, we may require \( \bar{\alpha}_1 \neq \bar{\alpha} \) (6). By (3) and (6), we have \( \bar{\alpha}_1 \neq \text{ftv}(\Gamma,\tau) \) (7). By HIDE, (4) and (7) imply \( \exists \bar{\alpha}_1.(C'_1 \land D), \Gamma \vdash e : \tau \) (8). By (3) and (6) again, we have \( \bar{\alpha}_1 \neq \text{ftv}(D) \), so (8) may be written \( \exists \bar{\alpha}_1.C'_1 \land D, \Gamma \vdash e : \tau \). By (5) and GEN, this yields \( \exists \bar{\alpha}_1.C'_1 \land \exists \bar{\alpha}.D, \Gamma \vdash e : \sigma \) (9). The constraint \( \exists \bar{\alpha}_1.C'_1 \land \exists \bar{\alpha}.D \) may be written \( \exists \bar{\alpha}_1.(C'_1 \land \exists \bar{\alpha}.D) \), that is, \( \exists \bar{\alpha}_1.C_1 \). Thus, (9) is the goal (1).
**Proof of Lemma 4.34.** Consider a derivation of shape APP(SUB(Abs(\( \cdot \))),\(_2\)). Its conclusion is \( C, \Gamma \vdash (\lambda \bar{c})e : \tau \) (1). The premises of APP are \( C, \Gamma \vdash \lambda \bar{c} : \tau' \rightarrow \tau \) (2) and \( C, \Gamma \vdash e : \tau' \) (3). The derivation of (2) ends with an instance of SUB whose premises are \( C, \Gamma \vdash \lambda \bar{c} : \tau'_1 \rightarrow \tau_1 \) (4) and \( C \vdash \tau'_1 \rightarrow \tau_1 \leq \tau' \rightarrow \tau \) (5). (Because the judgment (4) is a consequence of ABS, it must exhibit an arrow type \( \tau'_1 \rightarrow \tau_1 \).) By Requirement 4.10, (5) implies \( C \vdash \tau' \leq \tau'_1 \) (6) and \( C \vdash \tau_1 \leq \tau \) (7). By (3), (6), and SUB, we have \( C, \Gamma \vdash e : \tau'_1 \) (8). By (4), (8), and APP, we obtain \( C, \Gamma \vdash (\lambda \bar{c})e : \tau_1 \) (9). By (9), (7), and SUB, we reach the goal (1).
**Proof of Lemma 4.35.** Let us consider an arbitrary typing derivation. Of course, every trivial instance of GEN or INST may be suppressed, yielding a derivation that satisfies (a). Now, a nontrivial instance of GEN must be followed by either a syntax-directed rule or one of INST, HIDE. Furthermore, by Lemmas 4.32 and 4.33, GEN may be suppressed when it appears above INST and pushed down when it appears above HIDE. As a result, the derivation may be rewritten so as to satisfy (a) and (b). Next, by inspection of the rules in Figure 6, it is straightforward to check that, up to renamings of subderivations, HIDE may be pushed down through every rule other than GEN while preserving (a) and (b). Furthermore, any number of consecutive instances of HIDE may be collapsed into a single one. As a result, the derivation may be rewritten so as to satisfy (a), (b), and (c). At this point, one may check that, at every subexpression of the form \( (\lambda \bar{c})e \), ABS and APP may be separated only by zero or more instances of SUB. If there is one or more, then, by transitivity of subtyping, they may be collapsed to a single instance of SUB, which, by Lemma 4.34, may be eliminated without compromising (a), (b), or (c). Thus, the final derivation satisfies all four criteria.
**Proof of Lemma 4.36.** By structural induction. All cases are straightforward. We give one of them, for the sake of illustration.
- **Case Clause.** ce is p.e' and \( \sigma \) is \( \tau' \rightarrow \tau \). We may assume, w.l.o.g., that \( x \not\in \text{dvp}(p) \) (1), so that \([x \mapsto e]ce\) is \( p,[x \mapsto e]e' \). Clause’s premises are \( C \vdash p : \tau' \rightarrow \exists \beta[D]\Gamma \) (2) and
\( C \land D, \Gamma[x \mapsto \sigma']\Gamma' \vdash e' : \tau \) (3) and \( \beta \not\# \text{fiv}(C, \Gamma, \sigma, \tau) \) (4). By (1), \( \Gamma[x \mapsto \sigma']\Gamma' = \Pi\Gamma'[x \mapsto \sigma'] \), so (3) may be written \( C \land D, \Pi\Gamma'[x \mapsto \sigma'] \vdash e : \tau \) (5). By Lemma 4.30, the hypothesis \( C, \emptyset \vdash e : \sigma' \) yields \( C \land D, \emptyset \vdash e : \sigma' \) (6). Applying the induction hypothesis to (5) and (6), we obtain \( C \land D, \Pi\Gamma' \vdash [x \mapsto e]e' : \tau \) (7). The goal follows by Clause from (2), (7), and (4).
**Proof of Lemma 4.37.** To begin, let us prove that, if the above statement holds for a particular choice of \( \beta, D, \) and \( \Gamma \), then it holds for every such choice, that is, for every \( \beta', D', \) and \( \Gamma' \) such that \( \exists \beta[D]\Gamma \) and \( \exists \beta'[D']\Gamma' \) are \( \alpha \)-equivalent and \( \beta' \not\# \text{fiv}(C) \) holds. Indeed, let \( \theta \) be the renaming that swaps \( \beta \) with \( \beta' \). \( \theta \) maps \( D \) and \( \Gamma \) to \( D' \) and \( \Gamma' \), respectively. Thus, the property \( H \vdash D \) implies \( \theta H \vdash D' \). Furthermore, according to our freshness hypotheses, \( \theta \) is fresh for \( C \). Thus, we have \( C \equiv \theta C \equiv \exists(\theta \beta)\theta H \equiv \exists \beta'\theta H \), where the central step is permitted by applying \( \theta \) to both sides of the property \( C \equiv \exists \beta.H \). Similarly, by applying \( \theta \) to the property \( H, \emptyset \vdash [p \mapsto v]x : \Gamma(x) \), we obtain \( \theta H, \emptyset \vdash [p \mapsto v]x : \Gamma'(x) \). Thus, we have proved that the statement holds for \( \beta', D', \) and \( \Gamma' \), with \( \theta H \) as a witness. This initial remark is used several times later in the proof.
Next, we note that, since the proof of the present lemma is constructive, the witness \( H \) must satisfy, by construction, \( \text{fiv}(H) \subseteq \text{fiv}(C, \tau, \Delta, \beta) \). This fact is used below to control the free type variables of the witnesses produced by invocations of the induction hypothesis.
By Lemma 4.35, we may assume, w.l.o.g., that the derivation of \( C, \emptyset \vdash v : \tau \) is normal. The proof proceeds with a structural induction on this derivation, where \( \text{Hide} \) forms the inductive case and all other cases are base cases.
- **Case Hide.** Our hypotheses are \( \exists \alpha.C, \emptyset \vdash v : \tau \) (1) and \( \exists \alpha.C \vdash p : \tau \leadsto \Delta \) (2). The judgment (1) follows from an instance of \( \text{Hide} \) whose premises are \( C, \emptyset \vdash v : \tau \) (3) and \( \alpha \not\# \text{fiv}(\tau) \) (4). We may assume, w.l.o.g., \( \alpha \not\# \text{fiv}(D, \Gamma) \) (5). Because \( C \) entails \( \exists \alpha.C \), applying Lemma 4.30 to (2) yields \( C \vdash p : \tau \leadsto \Delta \) (6). Then, applying the induction hypothesis to (3) and (6) yields a constraint \( H \) such that \( H \vdash D \) (7) and \( C \equiv \exists \beta.H \) (8) and, for every \( x \in \text{dvp}(p) \), \( H, \emptyset \vdash [p \mapsto v]x : \Gamma(x) \) (9) holds. By placing (7) within the context \( \exists \alpha.[] \) and exploiting (5), we obtain \( \exists \alpha.H \vdash D \). Furthermore, (8) implies \( \exists \alpha.C \equiv \exists \beta.\exists \alpha.H \). Last, by applying \( \text{Hide} \) to (9) and (5), we obtain \( \exists \alpha.H, \emptyset \vdash [p \mapsto v]x : \Gamma(x) \). Thus, \( \exists \alpha.H \) is the desired witness.
We now reach the base case, where the derivation of \( C, \emptyset \vdash v : \tau \) is normal and does not end with \( \text{Hide} \). We proceed by induction on the derivation of \( C \vdash p : \tau \leadsto \Delta \).
- **Case p-Empty.** Because the first hypothesis states that \( v \) matches \( p \), this case cannot arise.
- **Case p-Wild.** Our hypotheses are \( C, \emptyset \vdash v : \tau \) and \( C \vdash p : \tau \leadsto \exists \emptyset[\text{true}] \emptyset \). Let our witness be \( C \); then, it is immediate to check that the goal holds.
- **Case p-Var.** Our hypotheses are \( C, \emptyset \vdash v : \tau \) and \( C \vdash x : \tau \leadsto \exists \emptyset[\text{true}](x \mapsto \tau) \). Let our witness be \( C \); then, it is immediate to check that the goal holds. In particular, the third goal is the hypothesis \( C, \emptyset \vdash v : \tau \).
- **Case p-And.** Our hypotheses are \( C, \emptyset \vdash v : \tau \) (1) and \( C \vdash p_1 \land p_2 : \tau \leadsto \Delta \) (2). The derivation (2) ends with an instance of \( p \)-And whose premises are, for all \( i \in \{1, 2\} \), \( C \vdash p_i : \tau \leadsto \Delta_i \) (3) where \( \Delta \) is \( \Delta_1 \times \Delta_2 \) (4). Let us write \( \Delta_i \) as \( \exists \beta_i[D_i]\Gamma_i \) (5), where \( \beta_i \not\# \text{fiv}(C, \tau, \Delta_1, \Delta_2) \) (6) and \( \beta_1 \not\# \beta_2 \) (7); according to (4), and by (6) and (7), \( \Delta \) is \( \exists \beta_1 \beta_2[D_1 \land D_2](\Gamma_1 \times \Gamma_2) \) (8). According to our initial remark, it is sufficient to establish the statement for this particular representation of \( \Delta \). By (5), applying the induction hypothesis to (1), (3) and (6), we obtain, for every \( i \in \{1, 2\} \), a constraint \( H_i \) such that \( H_i \vdash D_i \) (9), \( C \equiv \exists \beta_i.H_i \) (10) and, for every \( x \in \text{dvp}(p_i) \), \( H_i, \emptyset \vdash [p_i \mapsto v]x : \Gamma_i(x) \) (11). We also have, by construction, \( \text{fiv}(H_i) \subseteq \text{fiv}(C, \tau, \Delta_i, \beta_i) \), which by (6) and (7) implies \( \beta_j \not\# \text{fiv}(H_i) \) when \( \{i, j\} = \{1, 2\} \) (12).
Let us define $H$ as $H_1 \land H_2$ and check that all three goals are met. The first goal is $H \vdash D_1 \land D_2$, which follows from (9). The second goal is $C \equiv \exists \beta_1 \beta_2.(H_1 \land H_2)$, which follows from (10) and (12). Last, consider $x \in \text{dpv}(p_1 \land p_2)$. There exists a unique $i \in \{1, 2\}$ such that $x \in \text{dpv}(p_i)$. Then, $[v \mapsto x]p = [v \mapsto x]p_i$ and $(\Gamma_1 \times \Gamma_2)(x) = \Gamma_i(x)$. Applying Lemma 4.30 to (11), we obtain $H_1 \land H_2, \emptyset \vdash [p \mapsto v]x : \Gamma(x)$, which is the third goal.
- **Case p-Or.** Our hypotheses are $C, \emptyset \vdash v : \tau$ (1) and $C \vdash p_1 \lor p_2 : \tau \leadsto \Delta$ (2). Because $v$ matches $p_1 \lor p_2$, there exists $i \in \{1, 2\}$ such that $v$ matches $p_i$ and $[p_1 \lor p_2 \mapsto v]$ is $[p_i \mapsto v]$. The derivation (2) ends with an instance of p-Or among whose premises we have $C \vdash p_i : \tau \leadsto \Delta$ (3). Then, applying the induction hypothesis to (1) and (3) yields the result.
- **Case p-CStr.** Because a value that matches $K p_1 \cdots p_n$ must be of the form $K v_1 \cdots v_n$, our hypotheses are $C, \emptyset \vdash K v_1 \cdots v_n : \varepsilon(\bar{\alpha})$ (1) and $C \vdash K p_1 \cdots p_n : \varepsilon(\bar{\alpha}) \leadsto \Delta$ (2).
Because the derivation of (1) is normal and does not end with Hide, it must end with the shape $\text{Sub}(\text{CStr}(\cdot))$. (Indeed, any number of consecutive occurrences of Sub may be expanded or collapsed to a single one.) Then, a straightforward analysis shows that Sub’s second premise must be $C \vdash \varepsilon(\bar{\alpha}') \leq \varepsilon(\bar{\alpha})$ (3), while CStr’s premises are $C, \emptyset \vdash v_i : \tau'_i$ (4), for every $i \in \{1, \ldots, n\}$, $K :: \bar{\alpha}' \bar{\beta}'[D']^n, \tau'_1 \cdots \tau'_n \rightarrow \varepsilon(\bar{\alpha}')$ (5), and $C \vdash D'$ (6).
The derivation of (2) ends with an instance of p-CStr whose premises are $C \land D \vdash p_i : \tau_i \leadsto \Delta_i$ (7), for every $i \in \{1, \ldots, n\}$, $K :: \bar{\alpha}\bar{\beta}[D], \tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})$ (8), and $\bar{\beta} \neq \text{ftv}(C)$ (9), where $\Delta$ is $\exists \bar{\beta}[D](\Delta_1 \times \cdots \times \Delta_n)$. Up to a renaming of p-CStr’s premises, we may assume $\bar{\beta} \neq \bar{\alpha}' \bar{\beta}'$ (10). Let us write $\Delta_i$ as $\exists \bar{\beta}_i[D_i]\Gamma_i$, where $\bar{\beta}_i \neq \text{ftv}(C, \bar{\alpha}, \bar{\beta}, \bar{\alpha}', \bar{\beta}', \Delta_j, \bar{\beta}_j)$ (11) holds when $i \neq j$. Then, $\Delta$ is $\exists \bar{\beta}_1 \bar{\beta}_2 \cdots \bar{\beta}_n.(D \land_i D_i \cup_i \Gamma_i)$ (12). According to our initial remark, it is sufficient to establish the statement for this particular representation of $\Delta$.
By Lemma 4.30 and Sub, (4) yields $C \land D \land \tau'_i \leq \tau_i, \emptyset \vdash v_i : \tau_i$ (13). By Lemma 4.30 again, (7) yields $C \land D \land \tau'_i \leq \tau_i \vdash p_i : \tau_i \leadsto \Delta_i$ (14). Applying the induction hypothesis to (13) and (14), we obtain a constraint $H_i$ such that $H_i \vdash D_i$ (15) and $C \land D \land \tau'_i \leq \tau_i \equiv \exists \bar{\beta}_i.H_i$ (16) and, for every $x \in \text{dpv}(p_i)$, $H_i, \emptyset \vdash [p_i \mapsto v_i]x : \Gamma_i(x)$ (17). We also have, by construction, $\text{ftv}(H_i) \subseteq \text{ftv}(C, D, \tau'_i, \tau_i, \Delta_i, \bar{\beta}_i) \subseteq \text{ftv}(C, \bar{\alpha}, \bar{\beta}, \bar{\alpha}', \bar{\beta}', \Delta_j, \bar{\beta}_j)$, which by (11) implies $\bar{\beta}_j \neq \text{ftv}(H_i)$ when $i \neq j$ (18). By Requirement 4.11, (5), (8), and (10) imply $D' \leq \varepsilon(\bar{\alpha}') \leq \varepsilon(\bar{\alpha}) \vdash \exists \bar{\beta}.(D \land_i \tau'_i \leq \tau_i)$ (19). Together with (6) and (3), this implies $C \vdash \exists \bar{\beta}.(D \land_i \tau'_i \leq \tau_i)$ (20). Let us now define $H$ as $D \land_i H_i$ and check that all three goals are met.
According to (12), the first goal is $H \vdash D \land_i D_i$. It follows immediately from the definition of $H$ and from (15).
According to (12), the second goal is $C \equiv \exists \bar{\beta}\bar{\beta}_1 \cdots \bar{\beta}_n.H$. Indeed, we have
$$C \equiv \exists \bar{\beta}.(C \land D \land_i \tau'_i \leq \tau_i) \quad (21)$$
$$\equiv \exists \bar{\beta}.(D \land_i \exists \bar{\beta}_i.H_i) \quad (22)$$
$$\equiv \exists \bar{\beta}\bar{\beta}_1 \cdots \bar{\beta}_n.H \quad (23)$$
where (21) follows from (20) and (9); (22) follows from (16); (23) follows from (11), (18), and from the definition of $H$.
Last, consider $x$ in $\text{dpv}(p)$. There exists a unique $i$ such that $x \in \text{dpv}(p_i)$. Then, $[p \mapsto v]x$ is $[p_i \mapsto v_i]x$ and $(\cup_i \Gamma_i)(x)$ is $\Gamma_i(x)$. Applying Lemma 4.30 to (17), we obtain $H, \emptyset \vdash [p \mapsto v]x : (\cup_i \Gamma_i)(x)$, which is the third goal.
- **Case p-EqIn.** Our hypotheses are $C, \emptyset \vdash v : \tau$ (1) and $C \vdash p : \tau \leadsto \Delta$ (2). p-EqIn’s premises are $C \vdash p : \tau' \leadsto \Delta$ (3) and $C \vdash \tau = \tau'$ (4). Applying Sub to (1) and (4) yields a derivation of
\( C, \emptyset \vdash v : \tau' \) (5), which still is normal and does not end with \( \text{Hide} \). There remains to apply the induction hypothesis to (5) and (3).
- **Case p-SUBOUT.** Our hypotheses are \( C, \emptyset \vdash v : \tau \) (1) and \( C \vdash p : \tau \leadsto \Delta \) (2). p-SUBOUT’s premises are \( C \vdash p : \tau \leadsto \Delta' \) (3) and \( C \vdash \Delta' \leq \Delta \) (4). By hypothesis, \( \Delta \) is written \( \exists \beta | D | \Gamma \), where \( \beta \not\# \text{fv}(C) \) (5). Thanks to our initial remark, we may further require, w.l.o.g., \( \beta \not\# \text{fv}(\tau, \Delta') \) (6). Let us write \( \Delta' \) as \( \exists \beta' | D' | \Gamma' \), where \( \beta' \not\# \text{fv}(C, \Delta, \beta) \) (7). Note that (6) and (7) imply \( \beta \not\# \text{fv}(\Gamma') \) (8), \( \beta' \not\# \text{fv}(D) \) (9), and \( \beta' \not\# \text{fv}(\Gamma) \) (10).
The induction hypothesis, applied to (1) and (3), yields a constraint \( H' \) such that \( H' \vdash D' \) (11) and \( C \equiv \exists \beta' | H' | \) (12), and for every \( x \in \text{dpv}(p) \), \( H', \emptyset \vdash [p \mapsto v]x : \Gamma'(x) \) (13) holds. We also have, by construction, \( \text{fv}(H') \subseteq \text{fv}(C, \tau, \Delta', \beta') \), which by (5), (6), and (7) implies \( \beta \not\# \text{fv}(H') \) (14). Note also that (11) and (12) imply \( H' \vdash C \land D' \) (15).
Let us now define \( H \) as \( D \land \exists \beta' .(H' \land \Gamma' \leq \Gamma) \) and check that all three goals are met. The first goal, namely \( H \vdash D \), is immediate. Second, by Lemma 4.8, (4), (7), and (8) imply \( C \land D' \vdash \exists \beta .(D \land \Gamma' \leq \Gamma) \) (16). So, we have
\[
\begin{align*}
C &\equiv \exists \beta' .H' & (17) \\
&\equiv \exists \beta' .(H' \land \exists \beta .(D \land \Gamma' \leq \Gamma)) & (18) \\
&\equiv \exists \beta .(D \land \exists \beta' .(H' \land \Gamma' \leq \Gamma)) & (19) \\
&\equiv \exists \beta .H & (20)
\end{align*}
\]
where (17) is exactly (12); (18) follows from (15) and (16); (19) is by (14) and (9); (20) is by definition of \( H \). Thus, the second goal is met. Last, by Lemma 4.30 and SUB, (13) implies \( H' \land \Gamma' \leq \Gamma \), \( \emptyset \vdash [p \mapsto v]x : \Gamma(x) \). By (10) and \( \text{Hide} \), this implies \( \exists \beta' .(H' \land \Gamma' \leq \Gamma) \), \( \emptyset \vdash [p \mapsto v]x : \Gamma(x) \). The third goal follows by Lemma 4.30 and by definition of \( H \).
- **Case p-HIDE.** Our hypotheses are \( \exists \overline{\alpha}.C, \emptyset \vdash v : \tau \) (1) and \( \exists \overline{\alpha}.C \vdash p : \tau \leadsto \Delta \) (2). By hypothesis, \( \Delta \) is written \( \exists \beta | D | \Gamma \), where \( \beta \not\# \text{fv}(\exists \overline{\alpha}.C) \) (3). The judgment (2) follows from an instance of p-HIDE whose premises are \( C \vdash p : \tau \leadsto \Delta \) (4) and \( \overline{\alpha} \not\# \text{fv}(\tau, \Delta) \) (5). We may assume, w.l.o.g., that \( \alpha \) is fresh for \( \beta \) (6). Together, (3) and (6) imply \( \beta \not\# \text{fv}(C) \) (7), while (5) and (6) imply \( \overline{\alpha} \not\# \text{fv}(D, \Gamma) \) (8). Because \( C \) entails \( \exists \overline{\alpha}.C \), applying Lemma 4.30 to (1) yields \( C, \emptyset \vdash v : \tau \) (9). Then, applying the induction hypothesis to (9), (4), and (7) yields a constraint \( H \) such that \( H \vdash D \) (10) and \( C \equiv \exists \beta .H \) (11) and, for every \( x \in \text{dpv}(p) \), \( H, \emptyset \vdash [p \mapsto v]x : \Gamma(x) \) (12) holds. By placing (10) within the context \( \exists \overline{\alpha}.[] \) and exploiting (8), we obtain \( \exists \overline{\alpha}.H \vdash D \). Furthermore, (11) implies \( \exists \overline{\alpha}.C \equiv \exists \beta .\exists \overline{\alpha}.H \). Last, by applying \( \text{Hide} \) to (12) and (8), we obtain \( \exists \overline{\alpha}.H, \emptyset \vdash [p \mapsto v]x : \Gamma(x) \). Thus, \( \exists \overline{\alpha}.H \) is the desired witness.
**Proof of Theorem 4.39.** By Lemma 4.35, we may assume that the derivation of \( C, \emptyset \vdash e : \sigma \) (1) is normal. Moreover, we may restrict our attention to the case where it ends with an instance of a syntax-directed rule; indeed, the general case follows immediately. We proceed by induction on the derivation of \( e \to e' \).
- **Case (\( \beta \)).** \( e \) is \( (p_1.e_1 \cdots p_n.e_n)v \) and \( e' \) is \( [p_i \mapsto v]e_i \), for some \( i \in \{1, \ldots, n\} \). The derivation of (1) ends with an instance of App whose premises are \( C, \emptyset \vdash \lambda(p_1.e_1 \cdots p_n.e_n) : \tau' \to \tau \) (2) and \( C, \emptyset \vdash v : \tau' \) (3), where \( \sigma \) is \( \tau \). The derivation of (2) must end with an instance of Abs, whose premises include \( C, \emptyset \vdash p_i.e_i : \tau' \to \tau \) (4). The derivation of (4) ends with an instance of Clause whose premises are \( C \vdash p_i : \tau' \leadsto \exists \beta | D | \Gamma \) (5) and \( C \land D, \Gamma \vdash e_i : \tau \) (6) and \( \beta \not\# \text{fv}(C, \tau) \) (7). By (3), (5), (7), and Lemma 4.37, there exists \( H \) such that \( H \vdash D \) (8) and \( C \equiv \exists \beta .H \) (9) and, for every \( x \in \text{dpv}(p_i) \), \( H, \emptyset \vdash [p_i \mapsto v_i]x : \Gamma(x) \) (10) holds. By (9), we have \( H \vdash C \); together with
(8), this implies $H \vdash C \land D$. Thus, applying Lemma 4.30 to (6), we find $H, \Gamma \vdash e_i : \tau$ (11). By Lemma 4.36, (10) and (11) imply $H, \emptyset \vdash [p_i \mapsto v_i]e_i : \tau$ (12). Applying $\text{Hide}$ to (12) and (7) and exploiting (9), we obtain $C, \emptyset \vdash [p_i \mapsto v_i]e_i : \tau$.
- **Case** ($\mu$). $e$ is $\mu x.v$ and $e'$ is $[x \mapsto \mu x.v]v$. The derivation of (1) ends with an instance of $\text{Fix}$ whose premise is $C, (x \mapsto \sigma) \vdash v : \sigma$. The result follows by Lemma 4.36.
- **Case** (let). $e$ is $\text{let } x = v \text{ in } e_1$ and $e'$ is $[x \mapsto v]e_1$. The derivation of (1) must end with an instance of $\text{Let}$, whose premises are $C, \emptyset \vdash v : \sigma'$ and $C, (x \mapsto \sigma') \vdash e_1 : \sigma$. The result follows by Lemma 4.36.
- **Case** (context). By the induction hypothesis.
**Proof of Lemma 4.40.** By Lemma 4.35, we may assume, w.l.o.g., that the derivation of $C, \emptyset \vdash v : \tau$ is normal. The proof proceeds with a structural induction on this derivation, where $\text{Hide}$ forms the inductive case and all other cases are base cases.
- **Case** $\text{Hide}$. Our hypotheses are $\exists \bar{\alpha}.C, \emptyset \vdash v : \tau$ (1) and $\exists \bar{\alpha}.C \vdash p : \tau \leadsto \Delta$ (2), where $\exists \bar{\alpha}.C$ is satisfiable. The judgment (1) follows from an instance of $\text{Hide}$ whose first premise is $C, \emptyset \vdash v : \tau$ (3). Because $C$ entails $\exists \bar{\alpha}.C$, applying Lemma 4.30 to (2) yields $C \vdash p : \tau \leadsto \Delta$ (4). Because $\exists \bar{\alpha}.C$ is satisfiable, $C$ is satisfiable as well. Applying the induction hypothesis to (3) and (4) yields the result.
We now reach the base case, where the derivation of $C, \emptyset \vdash v : \tau$ is normal and does not end with $\text{Hide}$. We proceed by induction on the derivation of $C \vdash p : \tau \leadsto \Delta$.
- **Cases** $\text{p-Empty}$. Then, $p$ is $0$, $\neg p$ is $1$, so $v$ matches $\neg p$.
- **Cases** $\text{p-Wild}, \text{p-Var}$. Then, $v$ matches $p$.
- **Case** $\text{p-And}$. Our hypotheses are $C, \emptyset \vdash v : \tau$ (1) and $C \vdash p_1 \land p_2 : \tau \leadsto \Delta$ (2). The derivation of (2) ends with an instance of $\text{p-And}$ whose premises are, for every $i \in \{1, 2\}$, $C \vdash p_i : \tau \leadsto \Delta_i$ (3), where $\Delta$ is $\Delta_1 \times \Delta_2$. By the induction hypothesis, applied to (1) and (3), $v$ matches $p_i \lor \neg p_i$, for every $i \in \{1, 2\}$. We conclude that $v$ must match $\neg p_1 \lor \neg p_2 \lor (p_1 \land p_2)$, that is, $(p_1 \land p_2) \lor \neg(p_1 \land p_2)$.
- **Case** $\text{p-Or}$. Our hypotheses are $C, \emptyset \vdash v : \tau$ (1) and $C \vdash p_1 \lor p_2 : \tau \leadsto \Delta$ (2). The derivation of (2) ends with an instance of $\text{p-Or}$ whose premises are, for every $i \in \{1, 2\}$, $C \vdash p_i : \tau \leadsto \Delta_i$ (3). By the induction hypothesis, applied to (1) and (3), $v$ matches $p_i \lor \neg p_i$, for every $i \in \{1, 2\}$. We conclude that $v$ must match $p_1 \lor p_2 \lor (\neg p_1 \land \neg p_2)$, that is, $(p_1 \lor p_2) \lor \neg(p_1 \lor p_2)$.
- **Case** $\text{p-Cstr}$. Then, $p$ is $Kp_1 \cdots p_n$ and $\tau$ is $\varepsilon(\bar{\alpha})$. Because the derivation of $C, \emptyset \vdash v : \varepsilon(\bar{\alpha})$ is normal and does not end with $\text{Hide}$, it must end with a syntax-directed rule, followed by $\text{Sub}$. (Indeed, any number of consecutive occurrences of $\text{Sub}$ may be expanded or collapsed to a single one.) However, it cannot end with $\text{Sub(Abs(\cdot))}$, because then an assertion of the form $C \vdash \tau_1 \rightarrow \tau_2 \leq \varepsilon(\bar{\alpha})$ would hold—a contradiction, by Requirement 4.9, since $C$ is satisfiable. So, it must end with $\text{Sub(Cstr(\cdot))}$. As a result, $v$ must be of the form $K'v_1 \cdots v_n$. The data constructors $K$ and $K'$ cannot be associated with distinct data type declarations, because then an assertion of the form $C \vdash \varepsilon'(\bar{\alpha}') \leq \varepsilon(\bar{\alpha})$, where $\varepsilon$ and $\varepsilon'$ are distinct, would hold—again, a contradiction. So, $K'$ is associated with the data type $\varepsilon$.
If $K$ and $K'$ are distinct, then the pattern $K'1 \cdots 1$ appears among the disjuncts in the definition of $\neg p$, so $v$ matches $\neg p$.
Otherwise, $K$ and $n$ coincide with $K'$ and $n'$. $\text{Sub}$’s second premise is $C \vdash \varepsilon(\bar{\alpha}') \leq \varepsilon(\bar{\alpha})$ (1), while $\text{Cstr}'$’s premises are $C, \emptyset \vdash v_i : \tau'_i$ (2), for every $i \in \{1, \ldots, n\}$, $K' :: \forall \bar{\alpha}'.\bar{\beta}'[D'].\tau'_1 \cdots \tau'_n \rightarrow \varepsilon(\bar{\alpha}')$ (3), and $C \vdash D'$ (4). The derivation of $C \vdash p : \tau \leadsto \Delta$ ends with an instance of $\text{p-Cstr}$
whose premises are $C \land D \vdash p_i : \tau_i \leadsto \Delta_i$ (5), for every $i \in \{1, \ldots, n\}$, $K :: \forall \bar{\alpha} \beta [D], \tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha})$ (6), and $\beta \neq \text{ftv}(C)$ (7). We may further require, w.l.o.g., $\beta \neq \alpha' \beta'$ (8). By Requirement 4.11, (3), (6), and (8) imply $D' \land \varepsilon(\bar{\alpha}') \leq \varepsilon(\bar{\alpha}) \vdash \exists \beta. (D \land \alpha_i \tau'_i \leq \tau_i)$ (9). Together, (4), (1), (9), and (7) yield $C \vdash \exists \beta. (C \land D \land \alpha_i \tau'_i \leq \tau_i)$. Because $C$ is satisfiable, this proves that $C \land D \land \alpha_i \tau'_i \leq \tau_i$ is satisfiable as well. Now, by Lemma 4.30 and by Sub, (2) and (5) yield $C \land D \land \alpha_i \tau'_i \leq \tau_i$, $\emptyset \vdash v_i : \tau_i$ and $C \land D \land \alpha_i \tau'_i \leq \tau_i \vdash p_i : \tau_i \leadsto \Delta_i$, respectively. Applying the induction hypothesis to these judgments, we find that $v$ matches $p_i \lor \neg p_i$, for every $i \in \{1, \ldots, n\}$. Thus, $v$ matches $K (p_1 \lor \neg p_1) \cdots (p_n \lor \neg p_n)$, which is contained in $p \lor \neg p$.
- Case p-EqIn. Our hypotheses are $C, \emptyset \vdash v : \tau$ (1) and $C \vdash p : \tau \leadsto \Delta$ (2). p-EqIn’s premises are $C \vdash p : \tau' \leadsto \Delta$ (3) and $C \vdash \tau = \tau'$ (4). Applying Sub to (1) and (4) yields a derivation of $C, \emptyset \vdash v : \tau'$ (5), which still is normal and does not end with Hide. There remains to apply the induction hypothesis to (5) and (3).
- Case p-SubOut. Our hypotheses are $C, \emptyset \vdash v : \tau$ (1) and $C \vdash p : \tau \leadsto \Delta$ (2). p-SubOut’s first premise is $C \vdash p : \tau \leadsto \Delta'$ (3). There remains to apply the induction hypothesis to (1) and (3).
- Case p-Hide. Our hypotheses are $\exists \bar{\alpha}. C, \emptyset \vdash v : \tau$ (1) and $\exists \bar{\alpha}. C \vdash p : \tau \leadsto \Delta$ (2), where $\exists \bar{\alpha}. C$ is satisfiable. The judgment (2) follows from an instance of p-Hide whose first premise is $C \vdash p : \tau \leadsto \Delta$ (3). Because $C$ entails $\exists \bar{\alpha}. C$, applying Lemma 4.30 to (1) yields $C, \emptyset \vdash v : \tau$ (4). Because $\exists \bar{\alpha}. C$ is satisfiable, $C$ is satisfiable as well. Applying the induction hypothesis to (4) and (3) yields the result.
Proof of Lemma 4.41. Left to the reader.
Proof of Theorem 4.42. Suppose $C, \emptyset \vdash e : \sigma$ (1) where $C$ is a satisfiable constraint. We may assume, w.l.o.g., that the derivation of (1) is normal and ends with an instance of a syntax-directed-rule. The proof is by induction on the structure of $e$.
- Case $e$ is $x$. Because well-typed expressions are closed, this case cannot occur.
- Case $e$ is $\lambda(c_1 \cdots c_n). e$. $e$ is a value.
- Case $e$ is $e_1 e_2$. Because $e$ is well-typed, so are $e_1$ and $e_2$. By the induction hypothesis, $e_1$ is either reducible or a value. In the former case, because $\parallel e_2$ is an evaluation context, $e$ is reducible as well. Let us now assume the latter case. Then, by the induction hypothesis again, $e_2$ is either reducible or a value. In the former case, because $e_1$ is a value, $e_1 \parallel$ is an evaluation context, so $e$ is reducible. Let us now assume the latter case. The derivation of (1) ends with an instance of App whose premises are of the form $C, \emptyset \vdash e_1 : \tau' \rightarrow \tau$ (2) and $C, \emptyset \vdash e_2 : \tau'$ (3) for some satisfiable constraint $C$. We now reason by cases on the structure of the value $e_1$.
- Sub-case $e_1$ is $x$. Again, this case cannot occur.
- Sub-case $e_1$ is $K v_1 \cdots v_n$. Because any number of consecutive occurrences of Sub may be expanded or collapsed to a single one, we may assume that the derivation of (2) ends with the shape Sub(Cstr($\parallel$)). Sub’s second premise must then be of the form $C \vdash \varepsilon(\bar{\alpha}) \leq \tau' \rightarrow \tau$, a contradiction, by Requirement 4.9, since $C$ is satisfiable.
- Sub-case $e_1$ is $\lambda(p_1, e'_1 \cdots p_n, e'_n)$. This case analysis must be exhaustive, which means that $\neg p_1 \land \cdots \land \neg p_n$ is empty. Thus, there exists $i \in \{1, \ldots, n\}$ such that the value $e_2$ does not match $\neg p_i$ (4). The derivation of (2) must end with an instance of Abs, preceded by instances of Clause, among whose premises we find $C \vdash p_i : \tau' \leadsto \Delta$ (5) for some $\Delta$. Then, given (3), (5), and the satisfiability of $C$, Lemma 4.40 guarantees that $e_2$ matches $p_i \lor \neg p_i$ (6). Together, (4) and (6) show that $e_2$ matches $p_i$, which implies that $e$ is reducible by ($\beta$).
Case e is \( \mu x.v \). e is reducible by (\( \mu \)).
Case e is \( \text{let} \, x = e_1 \) in \( e_2 \). Because e is well-typed, so is \( e_1 \). By the induction hypothesis, \( e_1 \) is either reducible or a value. In the former case, because \( \text{let} \, x = [] \) in \( e_2 \) is an evaluation context, e is reducible as well. In the latter case, e is reducible by (let).
Proof of Theorem 4.43. Suppose e reduces to \( e' \). By Theorem 4.39, \( e' \) is well-typed. Because reduction preserves the property that all case analyses are exhaustive, Theorem 4.42 is applicable and guarantees that \( e' \) is not stuck.
Proof of Theorem 4.44. Let \( [e] \) be well-typed. Because, for every pattern p, \( \neg p \land \neg \neg p \) is empty, every case analysis in \( [e] \) is exhaustive. Thus, by Theorem 4.42, \( [e] \) is either reducible or a value.
If \( [e] \) is reducible, then it is straightforward to check that either e itself is reducible, or e is stuck and \( [e] \) reduces to an expression of the form \( E^*[\bot] \), where \( E^* \) stands for a stack of nested evaluation contexts. The latter case cannot arise, however, because \( [e] \) is well-typed, while, by Lemma 4.41, \( E^*[\bot] \) is not, contradicting the subject reduction property (Theorem 4.39). So, e is reducible.
If \( [e] \) is a value, then it is straightforward to check, by induction on the definition of \( [\cdot] \) that e is also a value.
Proof of Theorem 4.45. Suppose e reduces to \( e' \). In that case, it is straightforward to check that \( [e] \) reduces to \( [e'] \), so, by Theorem 4.39, \( [e'] \) is well-typed. Then, Theorem 4.44 guarantees that \( e' \) is not stuck.
Proof of Lemma 5.2. Left to the reader.
Proof of Lemma 5.4. By induction on the structure of p.
Cases p is 0, 1, or \( x \). The goal follows immediately from P-Empty, P-Wild, or P-Var.
Case p is \( p_1 \land p_2 \). By the induction hypothesis, for every \( i \in \{1, 2\} \), we have \( \langle p_i \downarrow \tau \rangle \vdash p_i : \tau \leadsto \langle p_i \uparrow \tau \rangle \). By Lemma 4.30 and by P-And, this implies the goal \( \langle p_1 \downarrow \tau \rangle \land \langle p_2 \downarrow \tau \rangle \vdash p_1 \land p_2 : \tau \leadsto \langle p_1 \uparrow \tau \rangle \times \langle p_2 \uparrow \tau \rangle \).
Case p is \( p_1 \lor p_2 \). By the induction hypothesis, for every \( i \in \{1, 2\} \), we have \( \langle p_i \downarrow \tau \rangle \vdash p_i : \tau \leadsto \langle p_i \uparrow \tau \rangle \). By P-Lub and P-SubOut, \( \langle p_2 \downarrow \tau \rangle \vdash p_2 : \tau \leadsto \langle p_1 \uparrow \tau \rangle + \langle p_2 \uparrow \tau \rangle \) follows. By Lemma 4.30 and by P-Or, this implies the goal \( \langle p_1 \downarrow \tau \rangle \land \langle p_2 \downarrow \tau \rangle \vdash p_1 \lor p_2 : \tau \leadsto \langle p_1 \uparrow \tau \rangle + \langle p_2 \uparrow \tau \rangle \).
Case p is \( Kp_1 \cdots p_n \). Let \( K :: \forall \vec{\alpha}.\beta[D].\tau_1 \cdots \tau_n \rightarrow \varepsilon(\vec{\alpha}) \) (1), where \( \vec{\alpha},\beta \neq \text{fv}(\tau) \) (2). By the induction hypothesis, for every \( i \in \{1, \ldots, n\} \), we have \( \langle p_i \downarrow \tau_i \rangle \vdash p_i : \tau_i \leadsto \langle p_i \uparrow \tau_i \rangle \) (3). Let C stand for \( \langle p_1 \downarrow \tau_1 \rangle \land \cdots \land \langle p_n \downarrow \tau_n \rangle \). We have \( D \land \forall \beta.D \Rightarrow C \vdash C \vdash \langle p_1 \downarrow \tau_1 \rangle \) (4), where the left-hand entailment assertion is a logical tautology, while the right-hand assertion is by definition of C. Applying Lemma 4.30 to (3) and (4), we obtain \( D \land \forall \beta.D \Rightarrow C \vdash p_i : \tau_i \leadsto \langle p_i \uparrow \tau_i \rangle \) (5). By P-Cstr, (5) and (1) imply \( \forall \beta.D \Rightarrow C \vdash p : \varepsilon(\vec{\alpha}) \leadsto \exists \beta[D]\Delta \) (6), where Δ stands for \( \langle p_1 \uparrow \tau_1 \rangle \times \cdots \times \langle p_n \uparrow \tau_n \rangle \). Applying Lemma 4.30 and P-EqlN to (6), we find \( \varepsilon(\vec{\alpha}) = \tau \land \forall \beta.D \Rightarrow C \vdash p : \tau \leadsto \exists \beta[D]\Delta \) (7).
Now, by F-Impl, we have \( \tau = \varepsilon(\vec{\alpha}) \vdash [D]\Delta \leq [D \land \tau = \varepsilon(\vec{\alpha})]\Delta \). By F-Hide and by transitivity of \( \leq \), this implies \( \tau = \varepsilon(\vec{\alpha}) \vdash [D]\Delta \leq \exists \alpha[D \land \tau = \varepsilon(\vec{\alpha})]\Delta \). By (2), \( \beta \) does not occur free in the left-hand side of this entailment assertion, which may thus be written \( \tau = \varepsilon(\vec{\alpha}) \vdash \forall \beta.([D]\Delta \leq \exists \alpha[D \land \tau = \varepsilon(\vec{\alpha})]\Delta) \). By F-Ex and by transitivity of entailment, this implies \( \tau = \varepsilon(\vec{\alpha}) \vdash \exists \beta[D]\Delta \leq \exists \alpha[\beta(D \land \tau = \varepsilon(\vec{\alpha}))\Delta] \), that is, \( \tau = \varepsilon(\vec{\alpha}) \vdash \exists \beta[D]\Delta \leq \langle p \uparrow \tau \rangle \) (8).
By p-SubOut, (7) and (8) yield \( \tau = \varepsilon(\bar{\alpha}) \land \forall \bar{\beta}. D \Rightarrow C \vdash p : \tau \leadsto \langle p \uparrow \tau \rangle \). By (2) and p-Hide, this entails \( \exists \bar{\alpha}. (\tau = \varepsilon(\bar{\alpha}) \land \forall \bar{\beta}. D \Rightarrow C) \vdash p : \tau \leadsto \langle p \uparrow \tau \rangle \), that is, \( \langle p \downarrow \tau \rangle \vdash p : \tau \leadsto \langle p \uparrow \tau \rangle \).
**Proof of Lemma 5.5.** By structural induction on \( p \).
**Proof of Lemma 5.6.** By induction on the derivation of \( C \vdash p : \tau \leadsto \Delta \) (\( \mathcal{H} \)).
- **Cases p-Empty, p-Wild, p-Var.** \( \langle p \uparrow \tau \rangle \) is true, so the first goal is a tautology. Furthermore, \( \langle p \uparrow \tau \rangle \) and \( \Delta \) coincide, so the second goal follows from the reflexivity of \( \leq \).
- **Case p-And.** (\( \mathcal{H} \)) is \( C \vdash p_1 \land p_2 : \tau \leadsto \Delta_1 \land \Delta_2 \). p-And’s premises are \( C \vdash p_i : \tau \leadsto \Delta_i \) (1), for every \( i \in \{1, 2\} \). By the induction hypothesis, (1) implies \( C \vdash \langle p_i \downarrow \tau \rangle \) (2) and \( C \vdash \langle p_i \uparrow \tau \rangle \leq \Delta_i \) (3). The first goal, \( C \vdash \langle p_1 \uparrow \tau \rangle \land \langle p_2 \downarrow \tau \rangle \), follows from (2). The second goal, namely \( C \vdash \langle p_1 \uparrow \tau \rangle \times \langle p_2 \uparrow \tau \rangle \leq \Delta_1 \times \Delta_2 \), follows from (3) by r-And.
- **Case p-Or.** (\( \mathcal{H} \)) is \( C \vdash p_1 \lor p_2 : \tau \leadsto \Delta \). p-Or’s premises are \( C \vdash p_i : \tau \leadsto \Delta_i \) (1), for every \( i \in \{1, 2\} \). By the induction hypothesis, (1) implies \( C \vdash \langle p_i \downarrow \tau \rangle \) (2) and \( C \vdash \langle p_i \uparrow \tau \rangle \leq \Delta \) (3). The first goal, \( C \vdash \langle p_1 \downarrow \tau \rangle \land \langle p_2 \downarrow \tau \rangle \), follows from (2). The second goal, namely \( C \vdash \langle p_1 \uparrow \tau \rangle + \langle p_2 \uparrow \tau \rangle \leq \Delta \), follows from (3) by r-GLB.
- **Case p-Cstr.** (\( \mathcal{H} \)) is \( C \vdash K p_1 \cdots p_n : \varepsilon(\bar{\alpha}) \leadsto \exists \bar{\beta}[D](\Delta_1 \times \cdots \times \Delta_n) \). p-Cstr’s premises are \( C \vdash p_i : \tau_i \leadsto \Delta_i \) (1), for every \( i \in \{1, \ldots, n\} \), \( K :: \forall \bar{\alpha}[\bar{\beta}[D], \tau_1 \cdots \tau_n \leadsto \varepsilon(\bar{\alpha}) \) (2) and \( \bar{\beta} \neq \text{fiv}(C) \) (3). By the induction hypothesis, (1) implies \( C \land D \vdash \langle p_i \downarrow \tau_i \rangle \) (4) and \( C \land D \vdash \langle p_i \uparrow \tau_i \rangle \leq \Delta_i \) (5).
The assertions (4), where \( i \) ranges over \( \{1, \ldots, n\} \), imply \( C \land D \vdash \land_i \langle p_i \downarrow \tau_i \rangle \). This may be written \( C \vdash D \Rightarrow \land_i \langle p_i \downarrow \tau_i \rangle \), and, by (3), \( C \vdash \forall \bar{\beta}. D \Rightarrow \land_i \langle p_i \downarrow \tau_i \rangle \). By Lemma 5.2, this is exactly the first goal \( C \vdash \langle K p_1 \cdots p_n \downarrow \varepsilon(\bar{\alpha}) \rangle \).
The assertions (5), where \( i \) ranges over \( \{1, \ldots, n\} \), together with r-And, imply \( C \land D \vdash \land_i \langle p_i \uparrow \tau_i \rangle \leq \times_i \Delta_i \). By r-Enrich, this implies \( C \vdash D \vdash \langle \times_i \langle p_i \uparrow \tau_i \rangle \rangle \leq \langle \times_i \Delta_i \rangle \). By (3), this may be written \( C \vdash \forall \bar{\beta}. \langle D \rangle \langle \times_i \langle p_i \uparrow \tau_i \rangle \rangle \leq \langle D \rangle \langle \times_i \Delta_i \rangle \). By r-Ex and by transitivity of entailment, \( C \vdash \exists \bar{\beta}[D] \langle \times_i \langle p_i \uparrow \tau_i \rangle \rangle \leq \exists \bar{\beta}[D] \langle \times_i \Delta_i \rangle \) follows. By Lemma 5.2, this is exactly the second goal \( C \vdash \langle K p_1 \cdots p_n \uparrow \varepsilon(\bar{\alpha}) \rangle \leq \exists \bar{\beta}[D] \langle \times_i \Delta_i \rangle \).
- **Case p-EqIn.** p-EqIn’s premises are \( C \vdash p : \tau' \leadsto \Delta \) (1) and \( C \vdash \tau = \tau' \) (2). By the induction hypothesis, (1) implies \( C \vdash \langle p \downarrow \tau' \rangle \) (3) and \( C \vdash \langle p \uparrow \tau' \rangle \leq \Delta \) (4). By Lemma 5.5, we have \( \tau = \tau' \land \langle p \downarrow \tau' \rangle \vdash \langle p \uparrow \tau \rangle \) (5) and \( \tau = \tau' \vdash \langle p \uparrow \tau' \rangle \leq \langle p \uparrow \tau \rangle \) (6). By (2), (3) and (5), we obtain the first goal \( C \vdash \langle p \downarrow \tau \rangle \). By (2) and (6), we get \( C \vdash \langle p \uparrow \tau \rangle \leq \langle p \uparrow \tau' \rangle \), which, combined with (4), yields the second goal \( C \vdash \langle p \uparrow \tau \rangle \leq \Delta \).
- **Case p-SubOut.** p-SubOut’s premises are \( C \vdash p : \tau \leadsto \Delta' \) (1) and \( C \vdash \Delta' \leq \Delta \) (2). By the induction hypothesis, (1) implies \( C \vdash \langle p \downarrow \tau \rangle \) (3) and \( C \vdash \langle p \uparrow \tau \rangle \leq \Delta' \) (4). By Lemma 5.5, we have \( \tau = \tau' \land \langle p \downarrow \tau' \rangle \vdash \langle p \uparrow \tau \rangle \) (5) and \( \tau = \tau' \vdash \langle p \uparrow \tau' \rangle \leq \langle p \uparrow \tau \rangle \) (6). By (2), (3) and (5), we obtain the first goal \( C \vdash \langle p \downarrow \tau \rangle \). By (2) and (6), we get \( C \vdash \langle p \uparrow \tau \rangle \leq \langle p \uparrow \tau' \rangle \), which, combined with (4), yields the second goal \( C \vdash \langle p \uparrow \tau \rangle \leq \Delta \).
- **Case p-Hide.** (\( \mathcal{H} \)) is \( \exists \bar{\alpha}. C \vdash p : \tau \leadsto \Delta \). p-Hide’s premises are \( C \vdash p : \tau \leadsto \Delta \) (1) and \( \bar{\alpha} \neq \text{fiv}(\tau, \Delta) \) (2). By the induction hypothesis, (1) implies \( C \vdash \langle p \downarrow \tau \rangle \) (3) and \( C \vdash \langle p \uparrow \tau \rangle \leq \Delta' \) (4). By (2), \( \bar{\alpha} \) does not occur free in the right-hand sides of these entailment assertions. As a result, (3) and (4) respectively imply \( \exists \bar{\alpha}. C \vdash \langle p \downarrow \tau \rangle \) and \( \exists \bar{\alpha}. C \vdash \langle p \uparrow \tau \rangle \leq \Delta \), which are the first and second goals.
**Proof of Lemma 5.10.** By induction on the structure of \( cc \).
- **Case ce is \( x \).** Write \( \Gamma(x) = \forall \bar{\alpha}[D], \tau' \), where \( \bar{\alpha} \neq \text{fiv}(\Gamma, \tau) \) (1). By Var, Inst, and Sub, we have \( D \land \tau' \leq \tau, \Gamma \vdash x : \tau \). By (1) and Hide, this implies \( \exists \bar{\alpha}. (D \land \tau' \leq \tau), \Gamma \vdash x : \tau \), which is precisely the goal \( \Gamma(x) \leq \tau, \Gamma \vdash x : \tau \).
Case ce is \( e_1 \cdot e_2 \). Let \( \alpha \neq \text{ftv}(\Gamma, \tau) \) (1). By the induction hypothesis, we have \( \{\Gamma \vdash e_1 : \alpha \rightarrow \tau\}, \Gamma \vdash e_1 : \alpha \rightarrow \tau \) and \( \{\Gamma \vdash e_2 : \alpha\}, \Gamma \vdash e_2 : \alpha \). By Lemma 4.30 and App, this yields \( \{\Gamma \vdash e_1 : \alpha \rightarrow \tau\} \land \{\Gamma \vdash e_2 : \alpha\}, \Gamma \vdash e_1 \cdot e_2 : \tau \). The result follows by (1) and Hide.
Case ce is \( K e_1 \cdots e_n \). Let \( K : \forall \bar{\alpha}[D].\tau_1 \cdots \tau_n \rightarrow \varepsilon(\bar{\alpha}) \) (1), where \( \bar{\alpha} \neq \text{ftv}(\Gamma, \tau) \) (2). By the induction hypothesis, \( \{\Gamma \vdash e_i : \tau_i\}, \Gamma \vdash e_i : \tau_i \) holds for every \( i \in \{1, \ldots, n\} \). By Lemma 4.30, \( \land_i \{\Gamma \vdash e_i : \tau_i\} \land D \land \varepsilon(\bar{\alpha}) \leq \tau, \Gamma \vdash e_i : \tau_i \) (3) follows. Applying Cstr to (3), where \( i \) ranges over \( \{1, \ldots, n\} \), and to (1), we obtain \( \land_i \{\Gamma \vdash e_i : \tau_i\} \land D \land \varepsilon(\bar{\alpha}) \leq \tau, \Gamma \vdash K e_1 \cdots e_n : \varepsilon(\bar{\alpha}) \). By Sub, (2), and Hide, this implies \( \exists \bar{\alpha}. \bar{\beta}. (\land_i \{\Gamma \vdash e_i : \tau_i\} \land D \land \varepsilon(\bar{\alpha}) \leq \tau), \Gamma \vdash K e_1 \cdots e_n : \tau \), that is, \( \{\Gamma \vdash e_1 \cdots e_n : \tau\}, \Gamma \vdash K e_1 \cdots e_n : \tau \).
Case ce is let \( x = e_1 \) in \( e_2 \). Let \( \alpha \neq \text{ftv}(\Gamma, \tau) \) (1). Let \( C \) and \( \sigma \) stand respectively for \( \{\Gamma \vdash e_1 : \alpha\} \) and \( \forall \bar{\alpha}[C].\alpha \). By the induction hypothesis, we have \( C, \Gamma \vdash e_1 : \alpha \) (2) and \( \{\Gamma[x \mapsto \sigma] \vdash e_2 : \tau\}, \Gamma[x \mapsto \sigma] \vdash e_2 : \tau \) (3). Applying Gen to (2) and (1) yields \( \exists \alpha. C, \Gamma \vdash e_1 : \sigma \) (4). The goal follows from (3) and (4) by Lemma 4.30 and Let.
Case ce is \( \mu(x : \exists \beta.\sigma).\lambda(c_1, \ldots, c_n) \). Up to a renaming of \( \bar{\beta} \) and \( \sigma \), we may assume, w.l.o.g., \( \bar{\beta} \neq \text{ftv}(\Gamma, \tau) \) (1). Write \( \sigma \) as \( \forall \bar{\gamma}[C].\tau_1 \rightarrow \tau_2 \), where \( \bar{\gamma} \neq \text{ftv}(\Gamma) \) (2). By the induction hypothesis, we have, for every \( i \in \{1, \ldots, n\} \), \( \{\Gamma[x \mapsto \sigma] \vdash c_i : \tau_1 \rightarrow \tau_2\}, \Gamma[x \mapsto \sigma] \vdash c_i : \tau_1 \rightarrow \tau_2 \) (3). Let \( D \) stand for \( \forall \bar{\gamma}. C \Rightarrow \{\Gamma[x \mapsto \sigma] \vdash c_i : \tau_1 \rightarrow \tau_2\} \). Then, \( C \land D \) entails \( \{\Gamma[x \mapsto \sigma] \vdash c_i : \tau_1 \rightarrow \tau_2\} \), so, by Lemma 4.30, (3) implies \( C \land D, \Gamma[x \mapsto \sigma] \vdash c_i : \tau_1 \rightarrow \tau_2 \) (4). Furthermore, we have \( \bar{\gamma} \neq \text{ftv}(D) \) (5). By (4), (2), (5), and FixAbs, we obtain \( \exists \bar{\gamma}. C \land D, \Gamma \vdash \mu(x : \exists \bar{\beta}.\sigma).\lambda \bar{c} : \sigma \) (6). Because \( \sigma \leq \tau \) entails \( \exists \bar{\gamma}. C \) (6) and Lemma 4.30 yield \( \sigma \leq \tau \land D, \Gamma \vdash \mu(x : \exists \bar{\beta}.\sigma).\lambda \bar{c} : \tau \) (7). By Inst, Sub, and Hide, (7) implies \( \sigma \leq \tau \land D, \Gamma \vdash \mu(x : \exists \bar{\beta}.\sigma).\lambda \bar{c} : \tau \) (8). By (8), (1), and Hide, we obtain \( \exists \bar{\beta}. (\sigma \leq \tau \land D), \Gamma \vdash \mu(x : \exists \bar{\beta}.\sigma).\lambda \bar{c} : \tau \), which by definition of \( D \) is the goal.
Case ce is \( p.e \). Then, \( \tau \) is of the form \( \tau_1 \rightarrow \tau_2 \). Write \( \{\bar{p} \downarrow \tau_1\} \) as \( \exists \bar{\beta}[D]\Gamma' \), where \( \bar{\beta} \neq \text{ftv}(\Gamma, \tau_1, \tau_2) \) (1). By the induction hypothesis, \( \{\Gamma' \vdash e : \tau_2\}, \Gamma' \vdash e : \tau_2 \) (2) holds. Furthermore, by Lemma 5.4, we have \( \{\bar{p} \downarrow \tau_1\} \vdash p : \tau_1 \sim \exists \bar{\beta}[D]\Gamma' \) (3). Now, recall that, by definition, \( \{\Gamma \vdash ce : \tau\} \) is \( \{\bar{p} \downarrow \tau_1\} \land \forall \bar{\beta}_2. D \Rightarrow \{\Gamma' \vdash e : \tau_2\} \). As a result, by Lemma 4.30, (2) and (3) respectively imply \( \{\Gamma \vdash ce : \tau\} \land D, \Gamma' \vdash e : \tau_2 \) (4) and \( \{\Gamma \vdash ce : \tau\} \vdash p : \tau_1 \rightarrow \exists \bar{\beta}[D]\Gamma' \) (5). By (4), (5), (1), and Clause, we obtain the goal \( \{\Gamma \vdash ce : \tau\}, \Gamma \vdash p.e : \tau_1 \rightarrow \tau_2 \).
Proof of Lemma 5.11. By induction on the structure of ce.
Proof of Lemma 5.12. By induction on the structure of ce.
Proof of Lemma 5.13. We assume \( \bar{\beta}_1 \bar{\beta}_2 \neq \text{ftv}(\Gamma, \tau) \) (1). Up to a renaming of the goal, we may assume, w.l.o.g., \( \bar{\beta}_1 \neq \text{ftv}(\exists \bar{\beta}_2[D_2]\Gamma_2) \) (2) and \( \bar{\beta}_2 \neq \Gamma_1 \) (3). By Lemma 5.12, we have \( \Gamma_1 \leq \Gamma_2 \land \{\Gamma_2 \vdash e : \tau\} \vdash \{\Gamma_1 \vdash e : \tau\} \). By (1) and (3), \( \bar{\beta}_2 \) does not appear in the right-hand-side of this entailment assertion, so it can be existentially quantified in its left-hand-side, which yields \( \exists \bar{\beta}_2. (\Gamma_1 \leq \Gamma_2 \land \{\Gamma_2 \vdash e : \tau\}) \vdash \{\Gamma_1 \vdash e : \tau\} \) (4). By (2) and (3), we have \( \exists \bar{\beta}_1[D_1]\Gamma_1 \leq \exists \bar{\beta}_2[D_2]\Gamma_2 \land D_1 \land \exists \bar{\beta}_2. (D_2 \land \Gamma_1 \leq \Gamma_2) \); then \( \exists \bar{\beta}_1[D_1]\Gamma_1 \leq \exists \bar{\beta}_2[D_2]\Gamma_2 \land D_1 \land \forall \bar{\beta}_2. D_2 \Rightarrow \{\Gamma_1 \vdash e : \tau\} \vdash \exists \bar{\beta}_2. (\Gamma_1 \leq \Gamma_2 \land \{\Gamma_2 \vdash e : \tau\}) \). By transitivity with (4), \( \exists \bar{\beta}_1[D_1]\Gamma_1 \leq \exists \bar{\beta}_2[D_2]\Gamma_2 \land D_1 \land \forall \bar{\beta}_2. D_2 \Rightarrow \{\Gamma_2 \vdash e : \tau\} \vdash \{\Gamma_1 \vdash e : \tau\} \) (5) follows. By (1), (2) and (3), \( \bar{\beta}_1 \neq \text{ftv}(\exists \bar{\beta}_1[D_1]\Gamma_1 \leq \exists \bar{\beta}_2[D_2]\Gamma_2 \land \forall \bar{\beta}_2. D_2 \Rightarrow \{\Gamma_2 \vdash e : \tau\}) \), so (4) can be rewritten into \( \exists \bar{\beta}_1[D_1]\Gamma_1 \leq \exists \bar{\beta}_2[D_2]\Gamma_2 \land \forall \bar{\beta}_2. D_2 \Rightarrow \{\Gamma_2 \vdash e : \tau\} \vdash \forall \bar{\beta}_1. D_1 \Rightarrow \{\Gamma_1 \vdash e : \tau\} \), which is the goal.
Proof of Theorem 5.14. We proceed by induction on the derivation of \( C, \Gamma \vdash ce : \forall \bar{\alpha}[D].\tau \) (H'). Let \( \sigma = \forall \bar{\alpha}[D].\tau \). Because \( \bar{\alpha} \) is \( \alpha \)-convertible in the statement of the theorem, we may assume,
w.l.o.g., $\bar{\alpha} \not\# \text{ftv}(C)$, so that the goal is equivalent to $C \land D \vdash (\Gamma \vdash ce : \tau)$. For the same reason, in cases FixAbs and Gen below, we may assume that $\bar{\alpha}$ coincides with the vector of type variables that appears in the rule’s premises.
- **Case Var.** Var’s first premise is $\Gamma(x) = \forall \bar{\alpha}[D].\tau$. The goal $C \land D \vdash \Gamma(x) \leq \tau$ follows from Lemma 4.5.
- **Case Cstr.** ($H$) is $C, \Gamma \vdash K e_1 \cdots e_n : \varepsilon(\bar{\alpha})$. Cstr’s premises are $C, \Gamma \vdash e_i : \tau_i$ (1), for every $i \in \{1, \ldots, n\}$, $K :: \forall \bar{\alpha}.\bar{\beta}[D].\tau_1 \cdots \tau_n \vdash \varepsilon(\bar{\alpha})$ (2) and $C \vdash D$ (3). By the induction hypothesis, (1) implies $C \vdash (\Gamma \vdash e_i : \tau_i)$ (4). By (4) and (3), we obtain $C \vdash \land_i (\Gamma \vdash e_i : \tau_i) \land D$, whence $C \vdash \exists \bar{\beta}.(\land_i (\Gamma \vdash e_i : \tau_i)) \land D$ (5). Furthermore, we let the reader check that, by definition of constraint generation, $\exists \bar{\beta}.(\land_i (\Gamma \vdash e_i : \tau_i) \land D)$ entails $(\Gamma \vdash K e_1 \cdots e_n : \varepsilon(\bar{\alpha}))$ (6). Combining (5) and (6) yields the goal $C \vdash (\Gamma \vdash K e_1 \cdots e_n : \varepsilon(\bar{\alpha}))$.
- **Case App.** ($H$) is $C, \Gamma \vdash e_1 e_2 : \tau$. App’s premises are $C, \Gamma \vdash e_1 : \tau' \rightarrow \tau$ (1) and $C, \Gamma \vdash e_2 : \tau'$ (2). By the induction hypothesis, (1) and (2) imply $C \vdash (\Gamma \vdash e_1 : \tau' \rightarrow \tau) \land (\Gamma \vdash e_2 : \tau')$ (3). Pick $\sigma \not\in \text{ftv}(\Gamma, C, \tau', \tau)$ (4). By (4), we have $C \vdash \exists \alpha.(\land \alpha = \tau')$ (5). Furthermore, by Lemma 5.11, (3) implies $C \land \alpha = \tau' \vdash (\Gamma \vdash e_1 : \alpha \rightarrow \tau) \land (\Gamma \vdash e_2 : \alpha)$ (6). Combining (5) and (6), we obtain $C \vdash (\forall \alpha.(\Gamma \vdash e_1 : \alpha \rightarrow \tau) \land (\Gamma \vdash e_2 : \alpha))$, that is, $C \vdash (\Gamma \vdash e_1 e_2 : \tau)$.
- **Case FixAbs.** ($H$) is $C \land \exists \bar{\alpha}.D, \Gamma \vdash \mu(x : \exists \bar{\beta}.\sigma).\lambda e : \sigma$. FixAbs’s premises are $C \land D, \Gamma[x \mapsto \sigma] \vdash e : \tau_1 \rightarrow \tau_2$ (1), $\bar{\alpha} \not\# \text{ftv}(C, \Gamma)$ (2), and $\sigma = \forall \bar{\alpha}[D].\tau_1 \rightarrow \tau_2$ (3). By the induction hypothesis, (1) implies $C \land D \vdash (\Gamma[x \mapsto \sigma] \vdash e : \tau_1 \rightarrow \tau_2)$, which, by (2), may be written $C \vdash \forall \bar{\alpha}.D \Rightarrow (\Gamma[x \mapsto \sigma] \vdash e : \tau_1 \rightarrow \tau_2)$ (4). Furthermore, by (3) and by Lemma 4.5, we have $D \vdash \sigma \leq \tau_1 \rightarrow \tau_2$ (5). Combining (4) and (5), we obtain $C \land D \vdash (\forall \bar{\alpha}.D \Rightarrow (\Gamma[x \mapsto \sigma] \vdash e : \tau_1 \rightarrow \tau_2)) \land \sigma \leq \tau_1 \rightarrow \tau_2$ (6). We let the reader check that, by definition of constraint generation, the right-hand side of (6) entails $(\Gamma \vdash \mu(x : \exists \bar{\beta}.\sigma).\lambda e : \tau_1 \rightarrow \tau_2)$. The goal follows.
- **Case Let.** ($H$) is $C, \Gamma \vdash \text{let } x = e_1 \text{ in } e_2 : \sigma$. Let’s premises are $C, \Gamma \vdash e_1 : \sigma'$ (1) and $C, \Gamma[x \mapsto \sigma'] \vdash e_2 : \sigma$ (2). Write $\sigma$ as $\forall \bar{\alpha}[D].\tau$, where $\bar{\alpha} \not\# \text{ftv}(\Gamma, C)$ (3). By the induction hypothesis, (1) and (4) imply $C \land D \vdash (\Gamma \vdash e_1 : \tau')$ (5), while (2) and (3) imply $C \land D \vdash (\Gamma[x \mapsto \sigma'] \vdash e_2 : \tau)$ (6). Pick $\alpha \not\in \text{ftv}(\Gamma, \tau, \tau')$ (7). Let $H$ stand for $(\Gamma \vdash e_1 : \alpha)$. By (7), the constraint $(\Gamma \vdash e_1 : \tau')$ entails $\exists \alpha.((\Gamma \vdash e_1 : \tau') \land \alpha = \tau')$, which by Lemma 5.11 entails $\exists \alpha.(H \land \alpha \leq \tau')$. Combining this fact with (5), we obtain $C \land D \vdash \exists \alpha.(H \land \alpha \leq \tau')$. By (4), this may be written $C \vdash \forall \bar{\alpha}.D' \Rightarrow \exists \alpha.(H \land \alpha \leq \tau')$, which by (7) is $C \vdash \forall \alpha[H].\alpha \leq \tau'$ (8). By (6), (8), and Lemma 5.12, we obtain $C \land D \vdash (\Gamma[x \mapsto \forall \alpha[H].\alpha] \vdash e_2 : \tau)$ (9). By Lemma 4.31, (1) implies $C \vdash \exists \bar{\alpha}'.D'$, which, together with (8), yields $C \vdash \exists \alpha.H$ (10). The goal $C \land D \vdash (\Gamma \vdash \text{let } x = e_1 \text{ in } e_2 : \tau)$ follows from (9) and (10).
- **Case Clause.** ($H$) is $C, \Gamma \vdash p.e : \tau_1 \rightarrow \tau_2$. Clause’s premises are $C \vdash \tau_1 \rightsquigarrow \exists \bar{\beta}[D]\Gamma'$ (1), $C \land D, \Gamma'\vdash e : \tau_2$ (2), and $\bar{\beta} \not\# \text{ftv}(C, \Gamma, \tau_2)$ (3). Up to a renaming of Clause’s second premise, we may further assume, w.l.o.g., $\bar{\beta} \not\# \text{ftv}(\tau_1)$ (4). By applying Lemma 5.6 to (1), we obtain $C \vdash (\downarrow p \vdash \tau_1)$ (5) and $C \vdash (\downarrow p \uparrow \tau_1) \leq \exists \bar{\beta}[D]\Gamma'$ (6). By the induction hypothesis, (2) implies $C \land D \vdash (\Gamma'\vdash e : \tau_2)$, which, by (3), may be written $C \vdash \forall \bar{\beta}.D \Rightarrow (\Gamma'\vdash e : \tau_2)$ (7). Write $(\downarrow p \uparrow \tau_1)$ as $\exists \beta_1[D_1\Gamma'_1]$, where $\beta_1 \not\# \text{ftv}(\Gamma, C, \tau_1, \tau_2, \bar{\beta})$ (8). By (3) and (8), $\beta_1 \beta_1 \not\# \text{ftv}(\Gamma, \tau_2)$ (9) holds. Applying Lemma 5.13 to (9) and combining the result with (6) and (7), we find $C \vdash \forall \beta_1.D_1 \Rightarrow (\Gamma'\vdash e : \tau_2)$ (10). Combining (5) and (10), we obtain $C \vdash (\downarrow p \vdash \tau_1) \land \forall \beta_1.D_1 \Rightarrow (\Gamma'\vdash e : \tau_2)$. By (8), this is the goal $C \vdash (\Gamma \vdash p.e : \tau_1 \rightarrow \tau_2)$.
- **Case Gen.** ($H$) is $C \land \exists \bar{\alpha}.D, \Gamma \vdash ce : \forall \bar{\alpha}[D].\tau$. Gen’s first premise is $C \land D, \Gamma \vdash ce : \tau$. By the induction hypothesis, this implies $C \land D \vdash (\Gamma \vdash ce : \tau)$, which is precisely the goal.
Case Inst. \((\mathcal{H})\) is \(C, \Gamma \vdash ce : \tau\). Inst’s premises are \(C, \Gamma \vdash ce : \forall \bar{\alpha}[D], \tau\) (1) and \(C \vdash D\) (2). Let \(\theta\) be a renaming of \(\bar{\alpha}\) such that \(\theta\) is fresh for \(\forall \bar{\alpha}[D], \tau\) (3) and \(\theta \bar{\alpha} \neq \text{ftv}(\Gamma)\) (4). By (3), (1) may be written \(C, \Gamma \vdash ce : \forall (\theta \bar{\alpha})[\theta D] \cdot \theta \tau\), which by (4) and by the induction hypothesis implies \(C \vdash \forall \theta \bar{\alpha}. \theta D \Rightarrow (\Gamma \vdash ce : \theta \tau)\). We let the reader check that, using (2), the goal \(C \vdash (\Gamma \vdash ce : \tau)\) follows.
Case Sub. \((\mathcal{H})\) is \(C, \Gamma \vdash ce : \tau\). Sub’s premises are \(C, \Gamma \vdash ce : \tau'\) (1) and \(C \vdash \tau' \leq \tau\) (2). By the induction hypothesis, (1) implies \(C \vdash (\Gamma \vdash ce : \tau')\) (3). Combining (3) and (2) and applying Lemma 5.11 yields the goal \(C \vdash (\Gamma \vdash ce : \tau)\).
Case Hide. \((\mathcal{H})\) is \(\exists \bar{\beta}. C, \Gamma \vdash ce : \sigma\). Hide’s premises are \(C, \Gamma \vdash ce : \sigma\) (1) and \(\bar{\beta} \neq \text{ftv}(\Gamma, \sigma)\) (2). Write \(\sigma\) as \(\forall \bar{\alpha}[D], \tau\), where \(\bar{\alpha} \neq \text{ftv}\). By the induction hypothesis, (1) implies \(C \vdash \forall \bar{\alpha}. D \Rightarrow (\Gamma \vdash ce : \tau)\) (3). By (2), \(\bar{\beta}\) does not occur free in the right-hand side of this entailment assertion. Thus, (3) implies the goal \(\exists \bar{\beta}. C \vdash \forall \bar{\alpha}. D \Rightarrow (\Gamma \vdash ce : \tau)\).
Proof of Lemma 6.5. By structural induction on \(p\). If \(p\) is 0, 1 or \(x\), the goal is the tautology \(\text{true} \equiv \forall \gamma. C \Rightarrow \text{true}\). If \(p\) is \(p_1 \land p_2\) or \(p_1 \lor p_2\), the goal follows from the induction hypothesis and from the distributivity of \(\Rightarrow\) and \(\forall\) with respect to \(\land\). If \(p\) is \(K p_1 \cdots p_n\), the goal follows from the induction hypothesis, Lemma 4.3, and the distributivity of \(\Rightarrow\) and \(\forall\) with respect to \(\land\).
Proof of Lemma 6.6. By structural induction on \(p\) and by inspection of the rules in Figure 10. Requirement 6.1 is exploited.
Proof of Theorem 6.9. By structural induction on clauses and expressions. If \(c\) is \(p.e\), the goal follows from Lemma 6.5, the induction hypothesis, and the distributivity of \(\Rightarrow\) and \(\forall\) with respect to \(\land\). If \(e\) is \(\mu(x : \exists \bar{\beta}. \sigma).\lambda \bar{c}\), where \(\bar{c}\) is guarded, the goal follows from the induction hypothesis and the distributivity of \(\Rightarrow\) and \(\forall\) with respect to \(\land\). In all other cases, the goal is an immediate consequence of the induction hypothesis.
Proof of Theorem 6.10. By structural induction on clauses and expressions, by inspection of the rules in Figure 10, and by Lemma 6.6. Requirements 6.1 and 6.3 is exploited.
Proof of Theorem 6.14. Point (i). Define the weight of a tractable constraint by:
\[
\begin{align*}
w(\text{true}) &= w(\text{false}) = w(\tau_1 = \tau_2) = 2 \\
w(L_1 \lor L_2) &= w(L_1) + w(L_2) + 2 \\
w(L_1 \land L_2) &= w(L_1) \times w(L_2) - 2 \\
w(\exists \bar{\alpha}. R) &= w(R) \\
w(\forall \bar{\beta}. L \Rightarrow R) &= w(R)w(L)^{-1}
\end{align*}
\]
For every constraint \(L\), we have \(w(L) \geq 2\) and, for every unification constraint \(U\), \(w(U) = 2\) holds. Using these properties, it is straightforward to check that s-AND-OR and s-ALL-OR are weight decreasing, while the remaining rules are non-weight increasing. Thus, it is sufficient to check that s-UNIF, s-ALL-FALSE and s-ALL form a strongly normalizing system. The last two rules strictly decrease the number of implication constructs, which is preserved by s-UNIF. So, the result follows from point (i) of Definition 6.12.
Point (ii). It is sufficient to separately prove that every rule in Figure 11 is meaning preserving. All cases are straightforward, excepted that of s-ALL, which we now detail. Assume \(\exists \bar{\beta}_2.R_1 \equiv \text{true}\).
and $R_1$ determines $\beta_2$. Then, by Lemma 4.3, we have $\forall \beta_1.R_1 \Rightarrow R_2 \equiv \exists \beta_2.(R_1 \land R_2)$. This implies $\forall \beta_1.\beta_2.R_1 \Rightarrow R_2 \equiv \forall \beta_1.\exists \beta_2.(R_1 \land R_2)$, which is the goal.
Points (iii) and (iv). Let $R$ be a normal form for $\neg_u$. Assume, by way of contradiction, that $R$ is not a standard unification constraint, that is, not of the form $U$. Then, $R$ must contain a rigid implication construct. Let us consider the innermost such construct. It must be of the form $\forall \beta.L \Rightarrow R'$, where $L$ is not true (otherwise this is a plain universal quantification construct). Because neither s-and-or nor s-all-or is applicable, $L$ cannot contain a disjunction; so, it must be a unification constraint $U$. Because s-unif is not applicable, $U$ must be a normal form for $\neg_u$. Then, by points (iii) and (iv) of Definition 6.12, one of s-all-false and s-all must be applicable, a contradiction. We conclude that $R$ is in fact a standard unification constraint. Because it is a normal form for s-unif, it must be a normal form for $\neg_u$. Then, the result follows from points (iii) and (iv) of Definition 6.12. □
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Fitness levels may predict cancer risk
BY PATRICE WENDLING
IMNG Medical News
Measured levels of cardiorespiratory fitness appear to be as predictive of cancer risk and survival as they are of heart disease risk and survival, according to a 20-year, prospective study of more than 17,000 men.
The risks of lung and colorectal cancer were reduced 68% and 38%, respectively, in men with the highest level of cardiorespiratory fitness, compared with those who were the least fit.
Cardiorespiratory fitness did not significantly reduce prostate cancer risk, but the risk of dying was significantly lower among men with prostate, lung, or colorectal cancer if they were more fit in middle age (P < .001).
Prior studies have shown that being physically active is protective against cancer, but this study is unique because it looked at a very specific marker – cardiorespiratory fitness as measured by maximal exercise tolerance testing, Dr. Susan G. Lakoski said during a briefing highlighting research at the upcoming American Society of Clinical Oncology meeting.
“Fitness as formal measurement is known to prevent cardiovascular disease, and it’s also known that it
See Exercise • page 7
SLEEP STRATEGIES: Apnea, obesity often mix in an alarming way
Meet ‘obesity hypoventilation syndrome.’
Obesity, as defined by a body mass index greater than 30 kg/m², has become a global epidemic and one of the leading causes of disability around the world.
If the obesity trend continues, it is projected that 65 million additional obese patients will live in United States by 2030 (Wang et al. Lancet 2011;378(9805): 815). The problem has become so severe that medicine has had to develop two additional terms to describe progressive obesity: morbid obesity (BMI > 40 kg/m²) and super obesity (BMI > 50 kg/m²); the prevalence of both of these conditions is also increasing at an alarming rate.
Obesity hypoventilation syndrome (OHS) is a condition defined by the concomitant existence of obesity, daytime hypercapnia (PCO₂ > 45 mm Hg), and sleep-disordered breathing, most commonly in the form of obstructive sleep apnea (OSA), in the absence of any other cause of CO₂ retention (eg, obstructive or restrictive lung disease, neuromuscular weakness, or hypothyroidism). Given the dramatic increase in the prevalence of obesity, it is reasonable to assume that the prevalence of OHS is also on the rise. The exact
See Syndrome • page 23
COMMENTARY: What’s new in HIPAA?
BY JOSEPH S. EASTERN, M.D.
I’m hearing a lot of concern about the impending changes in the Health Insurance Portability and Accountability Act (HIPAA) – which is understandable, since the Department of Health and Human Services has presented them as “the most sweeping … since [the Act] was first implemented.”
But after a careful perusal of the new rules – all 150 three-column pages of them – I can say with a modest degree of confidence that for most physicians, compliance will not be as challenging as some (such as those trying to sell you compliance-related materials) have warned.
However, you can’t simply ignore the new regulations;
See Changes • page 4
Have we come far enough in PAH patient outcomes?
Despite advances, patients’ long-term outcomes remain poor
Significant progress has been made in PAH treatment over the past 2 decades, yet patient morbidity and mortality remain high.\textsuperscript{1} There is limited information on the long-term effects of PAH-specific therapies, and many patients continue to experience death, hospitalizations, and the need for additional therapies.\textsuperscript{1,2}
Now is the time for a new perspective in PAH. Experts are calling for future PAH studies to deliver data on the long-term effect of therapy on clinical outcomes, such as hospitalizations and mortality.\textsuperscript{1-3} Actelion is committed to investigating this evolving perspective in PAH.
References: \textsuperscript{1}. Galiè N, Manes A, Negro L, Palazzini M, Bacchi-Reggiani M, Branzi A. A meta-analysis of randomized controlled trials in pulmonary arterial hypertension. \textit{Eur Heart J}. 2009;30:394-403. \textsuperscript{2}. Gomberg-Maitland M, Dufton C, Oudiz RJ, Benza RL. Convincing evidence of long-term outcomes in pulmonary arterial hypertension? \textit{J Am Coll Cardiol}. 2011;57:1053-1061. \textsuperscript{3}. McLaughlin VV, Badescu DB, Delcroix M, et al. End points and surgical indications in pulmonary arterial hypertension. \textit{Circulation}. 2008;118:S54-S97-S107. \textsuperscript{4}. Therrien J, D’Alonzo GE, Sherrill S, et al. Barst RJ, Ayres SM, et al. A US registry for pulmonary arterial hypertension. (1985-2004). \textit{Eur Respir J}. 2007;30:1103-1110. \textsuperscript{5}. D’Alonzo GE, Barst RJ, Ayres SM, et al. Survival in patients with primary pulmonary hypertension. Results from a national prospective registry. \textit{Ann Intern Med}. 1991;115:343-349.
© 2013 Actelion Pharmaceuticals US, Inc. All rights reserved. ACT-00250
Survival in PAH, 1988 and 2006*4,5
*Survival observed over periods from 1981-1988 and 1982-2006, respectively.
Learn more by visiting: PAHChangePerspective.com/outcomes
Heads up: New HIPAA requirements
Changes from page 1
Definitions will be more complex, security breaches more liberally defined, and potential penalties will be stiffer. Herewith, the salient points:
- **Business associates.** The criteria for identifying “business associates” (BAs) remain the same: nonemployees, performing “functions or activities” on behalf of the “covered entity” (your practice), that involve “creating, receiving, maintaining, or transmitting” personal health information (PHI).
Typical BAs include answering and billing services, independent transcriptionists, hardware and software companies, and any other vendors involved in creating or maintaining your medical records. Practice management consultants, attorneys, companies that store or microfilm medical records, and record-shredding services are BAs if they must have direct access to PHI to do their jobs.
Mail carriers, package-delivery people, cleaning services, copier repairmen, bank employees, and the like are *not* considered BAs, even though they might conceivably come in contact with PHI on occasion. You are required to use “reasonable diligence” in limiting the PHI that these folks may encounter, but you do not need to enter into written BA agreements with them.
Independent contractors who work within your practice – aestheticians and physical therapists, for example – are not considered BAs either, and do not need to sign a BA agreement; just train them, as you do your employees.
What is new is the additional onus placed on physicians for confidentiality breaches committed by their BAs. It’s not enough to simply have a BA contract. You are expected to use “reasonable diligence” in monitoring the work of your BAs. BAs and their subcontractors are directly responsible for their own actions, but the primary responsibility is ours.
Let’s say that a contractor you hire to shred old medical records throws them into a trash bin instead; under the new rules, you must assume the worst-case scenario. Previously, you would have to notify affected patients (and the government) only if there was a “significant risk of financial or reputational harm,” but now, any incident involving patient records is assumed to be a breach, and must be reported. Failure to do so could subject your practice, as well as the contractor, to significant fines – as high as $1 million in egregious cases.
- **New patient rights.** Patients will now be able to restrict the PHI shared with third-party insurers and health plans if they pay for the services themselves. They also have the right to request copies of their electronic health records, and you can bill the actual costs of responding to such a request. If you have EHR, now might be a good time to work out a system for doing this, because the response time has been decreased from 90 to 30 days – even less in some states.
- **Marketing limitations.** The new rule prohibits third-party-funded marketing to patients for products and services without their prior written authorization. You do not need prior authorization to market your own products and services, even when the communication is funded by a third party, but if there is any such funding, you will need to disclose it.
- **Notice of privacy practices (NPP).** You will need to revise your NPP to explain your relationships with BAs, and their status under the new rules. You will need to explain the breach notification process, too, as well as the new patient rights mentioned above. You must post your revised NPP in your office, and make copies available there, but you need not mail a copy to every patient.
- **Get on it.** The rules specify Sept. 23 as the effective date for the new regulations, although you have a year beyond that to revise your existing BA agreements. Extensions are possible, even likely.
Dr. Eastern practices dermatology and dermatologic surgery in Belleville, N.J. He writes about practice management for IMNG Medical Media.
**VIEW ON THE NEWS**
Dr. Stuart M. Garay, FCCP, comments: While the business of medicine continues to get tougher, so do the rules regulating this business. Privacy issues continue to draw significant scrutiny by the public at large as well as the government. The Health Insurance Portability and Accountability Act (HIPAA) has been upgraded with new regulations: Definitions are more complex, security breaches are more broadly defined, and the potential penalties are greater. Don’t ignore these new rules. Neither ignorance nor delay is a legitimate excuse.
Telavancin gets nosocomial pneumonia indication
Only S. aureus infections tagged in new approval.
BY ELIZABETH MECHCatie
IMNG Medical News
The teloglycopeptide antibiotic telavancin has been approved for treating patients with hospital-acquired or ventilator-associated bacterial pneumonia caused by susceptible isolates of *Staphylococcus aureus*, the Food and Drug Administration has announced.
Telavancin, marketed as Vibativ by Theravance, “should be used for the treatment of HABP/VABP only when alternative treatments are not suitable,” the FDA said in a June statement announcing the approval.
Among those patients with pre-existing kidney disease, mortality was higher for those taking telavancin – information that is now included in the boxed warning for telavancin.
It is not approved to treat other bacteria that cause pneumonia, the statement pointed out. It is administered once a day.
Approval of the expanded indication was based on the safety and effectiveness of telavancin in two studies of 1,532 patients with HABP/VABP which compared treatment with telavancin to vancomycin, according to the FDA.
In a statement, the manufacturer said that, in the two noninferiority studies, ATTAIN I and ATTAIN II, patients received either telavancin (10 mg/kg IV once a day) or vancomycin (1 g IV every 12 hours).
All-cause mortality 28 days after treatment started was comparable between the two groups, but among those patients with pre-existing kidney disease, mortality was higher for those taking telavancin – information that is now included in the boxed warning for telavancin, according to the FDA.
The most common adverse effect associated with treatment in the trials was diarrhea.
Telavancin should be considered for patients with pre-existing moderate to severe renal impairment (creatinine clearance of 50 mL/min or less) “only when the anticipated benefit to the patient outweighs the potential risk,” according to Theravance.
Telavancin was initially approved in 2009 as a treatment for complicated skin and skin structure infections caused by susceptible isolates of gram-positive bacteria, including both methicillin-susceptible (MSSA) and methicillin-resistant (MRSA) strains of *S. aureus*, with a boxed warning about the fetal risks of treatment.
In a statement, the company said that telavancin would be made available to wholesalers for purchase for the pneumonia indication in the third quarter of 2013.
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FDA: No starch solutions for critically ill, CPB patients
BY ELIZABETH MECHCATIE
IMNG Medical News
The Food and Drug Administration is warning that hydroxyethyl starch solutions should no longer be used in the treatment of critically ill adult patients – including patients with sepsis and those admitted to an intensive care unit – after completing an analysis of data that found an increase in the risk of death and renal injury in these groups.
In a statement, the agency also recommended that the use of hydroxyethyl starch (HES) solutions, used as plasma volume expanders, be avoided in patients who are having open heart surgery with cardiopulmonary bypass (CPB), because of an increased risk of excessive bleeding.
The FDA is making these recommendations after completing an analysis of data from randomized controlled trials, meta-analyses, and observational studies in thousands of critically ill patients, and from a meta-analysis of 18 randomized controlled trials of almost 1,000 patients undergoing open heart surgery with cardiopulmonary bypass.
The data on critically ill adults included three double-blind, multicenter, randomized controlled studies published in 2012, which compared HES with saline solution or Ringer’s acetate, in patients with severe sepsis (two studies), or patients in the ICU who had sepsis, had undergone elective surgery, and had an APACHE II score of at least 25. In these studies, which monitored patients for 90 days, HES was associated with increased mortality and/or renal injury requiring RRT, the FDA statements said. The results of meta-analyses and observational studies in similar populations lend additional support to these findings, the statement added.
In the meta-analysis of studies of patients undergoing open heart surgery with cardiopulmonary bypass, the “use of different HES products, irrespective of molecular weight or degree of molar substitution, was associated with increased bleeding,” according to the statement. The meta-analysis was published in 2012 (J. Thoracic Cardiovasc. Surg. 2012;144;223-30).
A boxed warning about the risk in ICU and septic patients is being added to the labels of HES products, and the information about the excessive bleeding risk in open heart surgery patients is being added to the warnings and precautions section.
There are four FDA-approved HES products for treating and preventing hypovolemia: HESPAN (6% HES 450/0.7 in sodium chloride injection); Hestastarch (6% in 0.9% sodium chloride injection), a generic equivalent of Hespan; Hextend (6% HES 450/0.7 in physiologic solution); and Voluven (6% HES 130/0.4 in normal saline).
The advisory is available at fda.gov/BiologicsBloodVaccines/SafetyAvailability/ucm358271.htm. Adverse events related to HES solutions should be reported to the FDA’s MedWatch program at fda.gov/Safety/MedWatch/HowToReport/default.htm or 800-332-1088.
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Fitness may predict cancer risk
Exercise from page 1
helps in terms of survival risk; but what hasn’t been known is, Does it prevent incident cancer and mortality after cancer diagnosis? That’s what’s elucidated in the current study,” said Dr. Lakoski, director of the cardiovascular prevention program for cancer patients at the University of Vermont, Burlington.
She noted that several organizations, including the President’s Council on Fitness, Sports & Nutrition, are trying to measure fitness formally and that the American Heart Association has issued policy statements that fitness should be measured and normative values developed to determine cardiovascular risk.
“Fitness is a formal measurement: It’s sort of like measuring your LDL cholesterol; you get a very specific number to target,” Dr. Lakoski said. “When you ask someone about their physical activity, you don’t get that information.”
The 17,049 men in the study underwent exercise tolerance testing with a treadmill or bicycle and risk factor assessment at an average age of 50 years as part of the Cooper Center Longitudinal Study in Dallas. Metabolic equivalents (METs) were used to record the men’s cardiorespiratory fitness (CRF) and to place them into five CRF quintiles. Lung, colorectal, and prostate cancers were assessed using Medicare claims data at Medicare age, and cause-specific mortality was determined after cancer diagnosis.
Over the 20 years of follow-up, 2,885 men were diagnosed with prostate, lung, or colorectal cancer, and 769 of them died.
Compared with men in the lowest CRF quintile, hazard ratios (HR) for incident lung, colorectal, and prostate cancer among men in the highest quintile were 0.32 ($P < .001$), 0.62 ($P = .05$), and 1.13 ($P = .14$), after researchers adjusted for such risk factors as smoking, body mass index, and age, Dr. Lakoski reported.
In men who developed cancer, both cancer-specific mortality and cardiovascular-specific mortality declined across increasing CRF quintiles ($P < .0001$).
Even a single MET increase reduced the risk of dying from cancer and cardiovascular disease by 14% and 23%, respectively (HR, 0.86; HR, 0.77; $P < .001$ for both measures), Dr. Lakoski said.
Another striking finding is that even if men aren’t obese, they still have an increased risk of cancer if they aren’t fit, “which suggests that everyone can benefit from improving their fitness,” Dr. Sandra Swain, ASCO president and medical director of the Washington (D.C.) Cancer Institute, told reporters.
“The findings make clear that patients should be advised that they need to achieve a certain fitness level, and not just be told that they need to exercise,” Dr. Swain noted in a statement.
“Fitness is a key risk factor for survival, and based on this study, an important factor to measure to assess future cancer risk and prognosis in men,” Dr. Lakoski said in an interview.
The study did not evaluate whether a particular type of exercise contributed more consistently to cardiovascular fitness, but in general, activities performed at high intensity, regardless of type, are the best way to improve fitness, she said.
More research is needed to determine fitness and cancer risk in women, and fitness and risk of all major site-specific cancers, Dr. Lakoski observed.
She reported having no relevant financial disclosures.
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Dr. Darcy D. Marciniuk, FCCP, comments: In this 20-year longitudinal observational cohort, high levels of fitness in men were associated with adjusted risk reductions of 68% in lung cancer and 38% in colorectal cancer incidence. The magnitude of those associations and the concordant objective reduction in mortality are truly impactful, particularly for two common and deadly malignancies.
If these results (which were formally documented by cardiopulmonary exercise test) were noted with any other intervention, it would (deservedly so) be front page news!
The message is clear: It is time for all physicians to get or stay fit, and importantly, actively enable our patients to do the same. Let’s save some lives!
Annual PAH screening recommended for systemic sclerosis
BY MITCHEL L. ZOLER
IMNG Medical News
MADRID – Patients with systemic sclerosis should undergo annual screening for pulmonary arterial hypertension using a combination of transthoracic echocardiography and pulmonary function tests, an international expert panel said.
These are the first evidence- and consensus-based recommendations for pulmonary arterial hypertension (PAH) screening in patients with systemic sclerosis, and the panel also called for screening patients with mixed or other connective tissue diseases with scleroderma features.
“About 5%-15% of patients with systemic sclerosis develop PAH, and once PAH occurs, up to 30% of patients will die within 3 years, Dr. Dinesh Khanna said at the annual European Congress of Rheumatology.
In an interview, Dr. Khanna, director of the scleroderma program at the University of Michigan, Ann Arbor, said that despite there being approved drugs to treat systemic sclerosis and other scleroderma-spectrum disorder connective tissue diseases, these treatments “have not had a huge impact on survival. The only thing we can offer patients is screening, followed by early diagnosis and treatment.”
The new recommendations say that patients with a tricuspid regurgitant velocity measured by transthoracic echocardiography greater than 2.8 m/s require assessment for PAH by right heart catheterization. Right heart catheterization is also needed for patients with a tricuspid regurgitant velocity of 2.5-2.8 m/s if they also have signs or symptoms of PAH such as dyspnea, fatigue, chest pain, dizziness, loud pulmonary sound, or peripheral edema. The key measures on pulmonary function tests that trigger right heart catheterization is a forced vital capacity (FVC) to diffusion capacity of lungs for carbon monoxide (DLCO) ratio of more than 1.6, or a DLCO of less than 60% if either appears in the setting of PAH signs or symptoms. Alternatively, meeting either of these pulmonary criteria should lead to right heart catheterization regardless of signs and symptoms if the patient’s most recent blood level of N-terminal pro-brain natriuretic peptide (NT-ProBNP) was greater than twice the upper limit of normal.
The panel also said patients should undergo right heart catheterization regardless of PAH signs if they fulfill the screening algorithm developed for the DETECT study (Ann. Rheum. Dis. 2013 May 18 [doi:10.1036/annrheumdis-2013-203301]).
The panel recommended annual transthoracic echo and pulmonary function test screening, or more frequently if a patient shows new signs or symptoms. Measurement of NT-ProBNP should happen at baseline, and then be repeated if new signs or symptoms of PAH appear. They also recommended applying the full DETECT screening algorithm in patients diagnosed with systemic sclerosis or other scleroderma spectrum connective-tissue disease for more than 3 years and a DLCO that is less than 60%. Right heart catheterization is mandatory to definitively diagnose PAH, Dr. Khanna stressed. The panel also said screening is not needed in patients with mixed- or other connective tissue disorders who did not have scleroderma-like features.
The task force was supported by the Scleroderma Foundation and the Pulmonary Hypertension Association. Dr. Khanna has been a consultant to several drug companies including Actelion, Bayer, Genentech/Roche, Gilead, Merck, and DIGNA.
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A multidisciplinary postoperative care program of patient and staff education, early patient mobilization, and pulmonary interventions has begun to reduce the excessive rate of postsurgical pulmonary complications at a large urban safety-net hospital, according to a report in JAMA Surgery.
“We are eager to monitor our outcomes over a longer period, and we are stimulated by the possibility that postoperative complications may be diminished by adherence to simple, inexpensive, easily performed patient care strategies,” said Dr. Michael R. Cassidy of the department of surgery, Boston University Medical Center, and his associates.
When data collected in the National Surgical Quality Improvement Program revealed that their center “was a high outlier for all measured postoperative pulmonary complications,” the investigators formed a multidisciplinary group to address the problem. “It was disturbing to discover that our hospital was a high outlier in all NSQIP-defined adverse pulmonary outcomes, but we regarded this as an opportunity to improve care,” they said.
BUMC is the largest safety-net facility in New England. The annual income of more than half of its patients is below $20,420, approximately 25% of its patients do not speak English, and 70% belong to racial or ethnic minorities, the investigators noted.
I COUGH included brochures, a video, and posters to educate patients, families, nurses, and physicians about the importance of pulmonary care. Proper use of incentive spirometry was demonstrated, the use of mouthwash and toothbrushing was recommended at least twice a day, and elevation of the head of the bed to at least 30 degrees was advocated. All this information was reinforced at preoperative clinic visits and in the preoperative holding area just before surgery. Nursing staff also reiterated the information after the procedures, as did surgeons, attending physicians, and house staff during rounds.
The effort also included standardized electronic physician order sets with “specific and detailed orders for all elements of the I COUGH program.” These included instructions for patients to perform deep breathing and coughing every 2 hours; for patients to perform incentive spirometry 10 times every hour while awake; for nurses to document incentive spirometry volume every 4 hours and to ensure that the head of the patient’s bed was elevated to at least 30 degrees; for patients to walk at least once on the day of operation unless contraindicated; and for patients to get out of bed and sit in a chair for a while at least 3 times per day.
Dr. Cassidy and his associates then compared data collected during the year before I COUGH was implemented to that collected during the year afterward.
Before I COUGH, 80% of 250 patients were in bed at the time of the audit, with only 19.6% seated in a chair or walking. After I COUGH, 69.1% of 250 patients were out of bed. Before I COUGH, only 52.8% of patients had an incentive spirometer within reach and an unknown number were using it appropriately, whereas afterward 77.2% of patients had the device within reach and were using it appropriately. Both findings were statistically significant.
The incidence of postoperative pneumonia was 2.6% before I COUGH, which dropped to 1.6% in the year afterward (P = .09). Similarly, the incidence of unplanned intubations was 2.0% before I COUGH, which decreased to 1.2% afterward, the authors reported [JAMA Surg. 2013 June 5 [doi: 10.1001/jamasurg.2013.358]).
These successes are due in part to the involvement of the multidisciplinary team at all stages of development of the I COUGH program, the investigators said.
“We have not imposed a standard of care by mandate, but instead have involved nursing leadership and practicing ward and ICU nurses in the process of redefining the culture.”
“We found that involvement of representatives of each discipline significantly increased acceptance of the I COUGH program, and instilled a sense of commitment and pride.”
Steven Q. Simpson, FCCP, comments: This article illustrates some key points about quality improvement and patient outcomes. First, it is not rocket science, i.e., the interventions can be simple, yet potent. Second, it requires interprofessional teamwork. And third, it requires measuring and accepting that our care is not as good as we thought it was, along with measuring to see whether the changes we make are just change or change for the better. The sorts of efforts taken by these authors can be undertaken in any hospital, large or small, and for any clinical problem.
The authors set an excellent example for us all.
Cardiac rehab benefits elderly heart failure patients
BY MITCHEL L. ZOLER
IMNG Medical News
ROME – A multiweek program of cardiac rehabilitation is as beneficial in elderly patients with chronic heart failure as it is in younger heart failure patients, according to a review of 243 patients at one Belgium center.
“Although they have lower exercise capacity at baseline, older patients have at least as much benefit from an exercise program as younger patients with chronic heart failure,” Sofie Pardaens reported in a poster at the annual meeting of the European Association for Cardiovascular Prevention and Rehabilitation. She is a physiotherapist and PhD student in the department of internal medicine at Ghent (Belgium) University.
Ms. Pardaens and her associates’ assessment of cardiac rehabilitation relative to a patient’s age included 243 patients who participated in a rehabilitation program at Ghent University, who had chronic heart failure, and who had an amino-terminal pro-B-type natriuretic peptide value of at least 400 pg/mL, a level very suggestive of heart failure (Circulation 2011;123:2015-9). The group included 43 patients (18%) who were at least 75 years old (average, 78 years) and 68 patients younger than 60 (average, 51 years), with the remaining 132 patients evenly distributed across the range of 60-74 years old.
All participants had just been hospitalized, for an ACS event, cardiac surgery, or heart failure.
The hospital-based rehabilitation program combined aerobic and strength training, and was designed to bring a patient’s heart rate to his anaerobic threshold during each session. Sessions occurred two or three times a week, and the full program included 45 sessions over a period of 4-5 months. The patients studied averaged 34 sessions each; patients aged 75 or older averaged 32 sessions each, while those younger than 60 averaged 35 sessions each.
The researchers measured peak exercise capacity using cardiopulmonary exercise testing at baseline and at the end of the rehabilitation session sequence, and found that the 16% average level of improvement among patients at least 75 years old closely matched the average 19% improvement among the patients younger than 60, and the 17% average improvement among everyone else, Ms. Pardaens and her associates reported. All age groups also showed similar improvements in their average ventilatory equivalence ratio, as well as their average 6-minute walk distance; however, the 29% average increased distance among patients younger than 60 years significantly exceeded the 19% average increase among those aged 75 or older.
A second analysis by Ms. Pardaens and her associates, reported in a separate poster, focused on 371 patients who underwent cardiac rehabilitation at Ghent University during January 2010 through May 2012 from among the 1,253 patients hospitalized during this period for an acute coronary syndrome event, cardiac surgery, or heart failure. In this pool of more than 1,000 patients who were potentially eligible to participate, only 30% actually enrolled in the rehabilitation program. The cardiac rehabilitation program again involved two to three sessions per week, with a goal for patients to complete 45 sessions within 5 months.
The sign-up rate for rehabilitation lagged even more among the 428 patients from the larger group whose index hospitalization had been for heart failure, with 37 of the acute heart failure patients (9%) actually engaging in rehabilitation. Rehabilitation participation was highest, a 56% rate, among the 358 patients who had been hospitalized for cardiac surgery, with a 28% uptake rate among 467 patients who had an ACS event.
Despite the low, 9% uptake of cardiac rehabilitation in heart failure patients, their benefit from participation closely tracked the benefit seen in surgery and ACS patients. Improvement in peak exercise capacity over baseline at the end of rehabilitation averaged 19% in the heart failure patients, 17% in the ACS patients, and 24% in the surgery patients, differences that were not statistically significant, reported Ms. Pardaens. All three subgroups also had similar average improvements in their 6-minute walk distance, which rose by an average of 21% in the heart failure patients and by averages of 27% and 28% in the other two subgroups.
Ms. Pardaens and her associates said they had no relevant financial disclosures.
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Dr. Jun Chiong, FCCP, comments: Cardiac rehabilitation is undoubtedly an essential component of the contemporary treatment of patients with coronary disease and heart failure.
Exercise training has the potential to act as a catalyst for promoting other aspects of rehabilitation, including risk factor modification through therapeutic lifestyle changes and optimization of psychosocial support. Similarly, among patients who are elderly, such outcome measures may include the achievement of functional independence, the prevention of premature disability, and a reduction in the need for custodial care.
Despite limited data, older patients have shown improvement in their exercise tolerance comparable to that of younger patients participating in equivalent exercise programs. In addition, the safety of exercise within cardiac rehabilitation programs is well accepted and established.
Oxygen debt is linchpin in multiple organ dysfunction
The level of perioperative tissue debt has a direct relationship on postoperative morbidity, mortality.
BY DOUG BRUNK
IMNG Medical News
SAN FRANCISCO – In the opinion of Dr. Larry H. Hollier, multiple organ dysfunction syndrome is a condition “underappreciated” by many of today’s clinicians, as optimal ways to treat it remain elusive.
At the Society for Vascular Surgery Annual Meeting, Dr. Hollier, professor of surgery and chancellor of the Louisiana State University Health Sciences Center, New Orleans, defined multiple organ dysfunction syndrome (MODS) as altered organ functions in an acutely ill patient requiring intervention to achieve homeostasis. “That’s a pretty broad definition, but it’s one of the most common causes of death in surgical intensive care units,” he said. “Numerous precipitating factors classically described in multiple organ dysfunction syndrome include sepsis, trauma, cardiac arrest, visceral ischemia, burns, pancreatitis, shock, and major surgery with postoperative instability.”
The pathophysiology of MODS “is fairly straightforward,” he continued. “Some event results in ischemia and tissue hypoxia. Reperfusion occurs with the activation of cytokines, and an exaggerated inflammatory response generates oxygen-free radicals, tissue damage, and then organ dysfunction.” Dr. Hollier discussed these issues as the invited speaker for the prestigious John Homans Lectureship of the SVS.
The major underlying issue in MODS stems from uncorrected oxygen debt in tissues. In fact, the level of perioperative tissue debt has a direct relationship on postoperative morbidity and mortality. According to Dr. Hollier, the predicted outcome by acutely accumulated oxygen debt in the first 4 hours post injury works like this: 8 L/m² leads to a severe flu-like syndrome (mild systemic inflammatory response syndrome); 26 L/m² leads to multiple organ dysfunction syndrome; and 33 L/m² or more leads to death. “The uncorrected oxygen debt in tissues that is initiated is not the end of it,” he said. “There’s an accumulating oxygen debt that amasses to keep biomass viable during low oxygen delivery. After resuscitation, there’s increased oxygen required above the basal rate, because explosive oxygen needs occur in order to fuel the inflammation of reperfusion injury.”
Conventional therapies for MODS include volume resuscitation, ionotropic agents to improve cardiac performance and increase oxygen delivery, and ventilator support to improve oxygen input. Multiple experimental therapies have also been used, including steroids, antientodotoxin monoclonal antibodies, IL-1 receptor antagonists, anti-TNF antibodies, antioxidants, inhibition of nitric oxide, and oxygen manipulation in the form of extracorporeal support and perfluorocarbons. “While there is some research experience, in the clinical arena, there has universally not been a treatment that reverses the multiple organ dysfunction syndrome,” he said. “Early diagnosis and prompt treatment of organ hypoperfusion and hypoxia are of utmost importance. The major goal is to increase oxygen delivery as soon as possible.”
Dr. Hollier said that he had no relevant financial disclosures to make.
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Current but not past smokers at postoperative risk
Surgery teams should take advantage of their ‘teachable environment’ to help patients quit.
BY MARY ANN MOON
IMNG Medical News
Current smoking is associated with an increased risk of mortality and other adverse outcomes following major surgery, but past smoking is not, according to a report in JAMA Surgery.
Current smoking correlates with these adverse outcomes even in patients who don’t have obvious smoking-related disease such cardiovascular disease, chronic pulmonary disorders, or cancer, which suggests that smoking may exert its deleterious effects through acute or subclinical chronic vascular and respiratory pathologic mechanisms, said Dr. Khaled M. Musallam of the American University of Beirut (Lebanon) Medical Center and his associates.
Since smoking cessation has clear benefits on morbidity and mortality in the surgical setting, “surgical teams should be more involved in the ongoing efforts to optimize measures for smoking control,” they wrote.
“Surgery provides a teachable environment for smoking cessation. Unlike the long-term consequences of smoking, the acute consequences of smoking on patients’ postoperative outcomes can provide a strong motive for quitting,” the investigators said.
Dr. Musallam and his colleagues examined the effect of smoking on surgical outcomes using data from the American College of Surgeons National Surgical Quality Improvement Program (NSQIP), which includes a registry that provides feedback to participating hospitals regarding 30-day risk-adjusted surgical morbidity and mortality.
For this study, they analyzed data on 607,558 patients undergoing major surgery at more than 200 participating hospitals during a 2-year period in the United States, Canada, Lebanon, and the United Arab Emirates. The mean age of the patients was 56 years (range, 16-90 years); 43% were men and 57% were women.
A total of 125,192 patients (21%) were current smokers and 78,763 (13%) were past smokers who had quit at least 1 year before surgery. The remaining patients had never smoked.
Only current smokers showed an increased likelihood of 30-day mortality. They also were at greater risk for adverse arterial events such as MI or stroke, as well as for adverse respiratory events such as pneumonia, need for intubation, and need for a ventilator, within 30 days of surgery, the investigators said [JAMA Surg. 2013 June 19 [doi:10.1001/jamasurg.2013.2360]].
The higher risk of these adverse outcomes occurred with smokers across all age groups but was particularly notable among those older than age 40 years. It was seen in both sexes, among those undergoing inpatient as well as outpatient procedures, in patients who had general as well as other types of anesthesia, across a variety of surgical subspecialties, and in both elective and emergency surgery cases.
The association between current smoking and adverse outcomes also remained robust in a sensitivity analysis, Dr. Musallam and his associates said.
There was a dose-response effect in an analysis of patients’ smoking history, with the likelihood of adverse arterial and respiratory events increasing in tandem with increasing pack-years of smoking, but even current ‘light’ smokers who had fewer than 10 pack-years of smoking history were at increased risk for postoperative mortality and morbidity.
“These findings encourage ongoing efforts to implement smoking cessation programs,” Dr. Musallam and his associates said.
“Early intervention in heavy smokers is warranted, especially because the effect of smoking on postoperative arterial and respiratory morbidity seems to be dose dependent. However, because smokers with a cigarette smoking history of less than 10 pack-years are also at risk of postoperative death, recent and light smokers should also be targeted,” they suggested.
Dr. Musallam and his associates reported no financial conflicts of interest.
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Dr. Marcos I. Restrepo, FCCP, comments: This is another message showing the deleterious effects of smoking, this time on patients undergoing major surgery. The need for major surgery is the perfect moment to stop smoking. Please do not miss this opportunity!
Inhaled adrenaline akin to saline for acute bronchiolitis
BY MARY ANN MOON
IMNG Medical News
Inhaled racemic adrenaline is no more effective than inhaled saline for infants hospitalized with acute bronchiolitis, a study has shown.
In the multicenter, double-blind randomized trial involving 404 infants in Norway, hospital length of stay was no shorter for patients who received inhaled adrenaline than for those who received inhaled saline. The need for nasogastric-tube feeding, supplemental oxygen, or ventilatory support also was no different between the two groups, said Dr. Havard Ove Skjerven of Oslo University Hospital and his associates.
The findings were published in the New England Journal of Medicine.
Adrenaline inhalation, which reduces mucosal swelling, is used frequently for acute bronchiolitis in the outpatient setting, chiefly because it has been shown to improve symptoms and prevent the need for hospitalization. “Among inpatients, however, adrenaline has not been found to reduce the length of hospital stay,” the investigators noted.
They studied the issue in babies aged younger than 1 year (mean age, 4 months) who were admitted to the pediatric departments of eight hospitals during a 1-year period. A total of 102 infants were randomly assigned to receive inhaled adrenaline on demand, 101 to receive inhaled adrenaline on a fixed schedule, 98 to receive saline on demand, and 103 to receive saline on a fixed schedule.
The primary outcome was length of hospital stay. The mean length of stay for the entire study population was 80 hours.
There was no significant difference in length of hospital stay between the infants treated with adrenaline (78.7 hours) and those treated with saline (81.8 hours).
There also were no significant between-group differences in the need for feeding using a nasogastric tube, supplemental oxygen, or ventilatory support, the researchers said (N. Engl. J. Med. 2013 June 12 [doi:10.1056/NEJMoa1301839]).
In addition, the infants were scored on a measure of clinical appearance, which took into account their general condition, skin color, findings on auscultation, respiratory rate, and chest retractions. These scores also did not differ significantly between infants given their first dose of inhaled adrenaline and those given their first dose of inhaled saline.
The two study groups also were similar in the number of children who discontinued the study medication. No serious adverse events were reported.
These findings did not change in a subgroup analysis that categorized the infants by age (younger vs. older than 3 months). They also remained robust regardless of whether the patients had a history of atopic eczema or wheezing, or a family history of atopy.
However, it was notable that among the youngest patients (less than 3 months of age), length of hospital stay was significantly shorter and secondary outcomes were better for those who received either adrenaline or saline inhalation on demand than for those who received either drug on a fixed schedule. Because the on-demand groups received a mean of 5 (30%) fewer inhalations than the fixed-schedule groups, this suggests that “minimal handling” – allowing infants to sleep, with minimal interruptions – is the preferred approach for this age group, Dr. Skjerven and his associates said.
This study was supported by Medicines for Children, a publicly funded group administered by Haukeland University Hospital. Dr. Skjerven reported no relevant financial disclosures; his associates reported ties to numerous industry sources.
Device cuts DVT risk, saves stroke patients’ lives
Compression sleeve led to significantly fewer proximal events; ensuring eligible patient access is next step.
BY SARA FREEMAN
IMMG Medical News
LONDON – Intermittent pneumatic compression reduced the absolute risk of proximal deep vein thrombosis in patients who had suffered a stroke and were immobile by 3.6% in a large, randomized trial published recently.
The incidence of proximal DVT at 30 days in the CLOTS 3 study was 8.5% with intermittent pneumatic compression (IPC) and 12.1% with routine poststroke care alone \((P = .001)\). The adjusted odds ratio was 0.65. There was also a 14% reduction in the risk of death seen at 6 months favoring IPC use over routine care alone \((P = .042)\). This was a surprising finding, said principal investigator Dr. Martin Dennis of the University of Edinburgh’s clinical neurosciences division and Western General Hospital in Edinburgh. He is a professor of stroke medicine.
Importantly, IPC appears to be effective across a variety of prespecified subgroups, including both ischemic and hemorrhagic stroke.
Findings will change practice
The findings, which were published online in *The Lancet* (2013 May 31 [doi: 10.1016/S0140-6736(13)61050-8]) to coincide with their presentation at the annual European Stroke Conference, are practice changing and suggest that national stroke guidelines need to be updated.
“This study is a major breakthrough, showing how a simple and safe treatment can save lives,” Dr. Tony Rudd, a consultant stroke physician at Guy’s and St. Thomas’ NHS Foundation Trust, London, said in a statement issued by the University of Edinburgh.
“The challenge now will be to ensure that all patients who might benefit are offered treatment,” added Dr. Rudd, who chairs the Royal College of Physicians’ Intercollegiate Stroke Working Party. “It is one of the most important research studies to emerge in the field of stroke in recent years,” he noted.
Dr. Christine Roffe, consultant in stroke medicine and professor of medicine at Keele University in Stoke-on-Trent, England, also praised the study’s results. “That something as simple as a compressive sleeve saves lives after stroke is fascinating,” she said in an interview at the conference. Dr. Roffe was not involved in the study.
The CLOTS 3 study
CLOTS 3 follows on from two other trials performed by the CLOTS (Clots in Legs or Stockings After Stroke) Trials Collaboration, in which compression stockings were examined as a possible means of preventing thrombotic complications in patients who had suffered a stroke. Results of CLOTS 1 (*Lancet* 2009;373:1958-65) and CLOTS 2 were negative, however, and no benefit of compression stockings was seen in stroke patients.
Between December 2008 and September 2012, a total of 2,876 patients were enrolled in CLOTS 3. For inclusion, patients had to be immobile and randomized within 0-3 days of having had a stroke. Immobility was defined as being unable to walk to the bathroom without the help of another person.
Patients were randomized to receive either routine poststroke care alone or with additional IPC delivered by Covidien’s Kendall SCD Express Sequential Compression System. The latter involved wearing thigh-high, inflatable sleeves continuously for up to 30 days, during which time the device automatically provided IPC depending on the position of the patient. The mean and median durations of wear were 12.5 days and 9.0 days, respectively.
DVT was assessed using duplex ultrasound at 7-10 days and again at 25-30 days if possible. Both patient groups wore compression sleeves to ensure that the ultrasound technicians remained blinded to the treatment group.
Follow-up was at 6 months via postal questionnaires sent to patients’ primary care physicians asking about vital status and the occurrence of venous thromboembolism since hospital discharge. Patients were also sent a postal questionnaire and telephoned if they did not respond.
Risk reduction
The effect on proximal DVT at 30 days was the primary outcome measure, but IPC also reduced the incidence of symptomatic DVT (4.6% vs. 6.3%; \(P = .0045\)) and any DVT (16.2% vs. 21.1%; \(P = .001\)) versus routine care. There was no significant difference in the incidence of pulmonary embolism between study arms (2.0% vs. 2.4%, respectively, \(P = .453\)).
In terms of safety, there was no difference between the treatment groups in the number of falls with injury or fractures as a result of constantly wearing the compression sleeves. There was a significant difference in skin ulcers (3.1% with IPC vs. 1.4% without, \(P = .002\)), but close inspection of the data suggested that only 10 (0.7%) cases were due to IPC.
“During the study, [the manufacturers of the IPC device] brought out a new comfort sleeve,” Dr. Dennis noted in an interview.
“Normally these sleeves were being used for short periods in surgical patients, but we were using them for longer periods, so they brought out a softer sleeve,” he observed. Anecdotally, he conceded that some people found the sleeves uncomfortable, too hot, or the system “noisy” to use.
The bottom line is that “intermittent pneumatic compression in people who are immobile with stroke reduces the risk of deep vein thrombosis,” Dr. Dennis said.
He emphasized that “IPC is feasible in stroke patients, and it is relatively safe. It is an effective means of reducing venous thromboembolism after stroke, with a number needed to treat of about 28 for proximal DVT.”
Intriguingly, it may also improve overall survival, “although we weren’t expecting to see that effect,” Dr. Dennis said. The number needed to treat to prevent one death in 30 days was 43.
Dr. Dennis, Dr. Rudd, and Dr. Roffe had no relevant disclosures. The University of Edinburgh and NHS Lothian sponsored the study with funding from the Chief Scientist Office of the Scottish Government, the National Institute of Health Research Health Technology Assessment Programme, and the Scottish Stroke Research Network. Covidien provided the equipment used in the study free of charge.
VIEW ON THE NEWS
Dr. Robert Pendleton, FACP, comments: Venous thromboembolism is a common cause of hospital-related morbidity. Anticoagulants (e.g., heparin, low-molecular-weight heparin [LMWH]) reduce VTE with acceptable safety. Stroke patients have a high risk of VTE, but also a heightened bleeding risk in the setting of anticoagulants. Mechanical devices (elastic stockings, sequential compression devices) are attractive alternatives, but efficacy is unproven in many settings. Unlike previous trials that demonstrated a lack of efficacy of elastic stockings, the CLOTS 3 study provides convincing evidence that sequential compression devices (SCDs) reduce VTE and decrease mortality in patients with a stroke. Although encouraging, VTE event rates remained high, 8.5%, in contrast to VTE rates of 4.8% in a prior study of enoxaparin in stroke patients.
Together, these findings support recommendations by the American College of Chest Physicians: In patients with acute ischemic stroke and restricted mobility, use prophylactic-dose subcutaneous heparin or LMWH or intermittent SCDs as opposed to no prophylaxis.
Dr. Pendleton is chief medical quality officer for University of Utah Health Care, Salt Lake City.
Antiemetic cuts pneumonia in intubated stroke patients
BY SARA FREEMAN
IMNG Medical News
LONDON – Metoclopramide significantly reduced the incidence of pneumonia in intubated stroke patients and was associated with improved mortality in a single-center, randomized controlled study.
A total of 34 of 60 (57%) patients in the trial developed pneumonia, of whom the majority (87%) received a placebo, while only 8 (27%) cases occurred in patients who received the antiemetic therapy.
A third of the cohort died by 30 days, but of these 20 deaths, 12 occurred in the placebo group versus 8 in the metoclopramide arm.
Neurological improvement also was seen in the patients given metoclopramide, Dr. Anushka Warusevitane of University Hospital of North Staffordshire in Stoke-on-Trent, England, reported at the annual European Stroke Conference.
For the whole group, National Institutes of Health Stroke Scale (NIHSS) scores were 19.3 at baseline, indicating moderate to severe stroke, 16.8 at 1 week, 17.4 at 2 weeks, and 19.6 at 3 weeks post stroke.
In the trial, adult patients admitted to the acute stroke unit within 7 days of having a stroke and who needed a nasogastric tube fitted for more than 24 hours were randomized to receive metoclopramide 10 mg three times a day or the same volume of a similar-looking placebo for a maximum of 3 weeks. All patients received standard stroke care.
The average age of the 60 patients finally recruited was 78 years, 63% were female, and 93% had cerebral infarcts.
Pneumonia was diagnosed according to four criteria outlined by the British Thoracic Society: acute lower respiratory tract infection symptoms; new focal chest signs; fever (more than 38°C), chills and rigors, elevated white cell count, or increased inflammatory markers; and new radiological shadowing.
Dr. Warusevitane reported that all of the episodes of pneumonia occurred within 10 days of the initiation of nasogastric feeds. The average time for pneumonia to develop was significantly longer in the metoclopramide group (4 days versus 2 days for placebo). Significantly shorter periods of antibiotic use were noted in the active versus placebo arm, at a mean of 2 days and 8 days, respectively.
Only 1 patient given metoclopramide had an episode of aspiration, which was witnessed by a health care professional, compared with 14 patients given placebo. There was evidence that once the nasogastric tube was removed, the actively treated patients had a better swallowing response.
“I’m convinced enough to change practice locally,” senior study author Dr. Christine Roffe said in an interview. Dr. Roffe, professor of medicine at Keele University, England, conceded that a single-center study of just 60 patients might not convince the wider stroke community.
Dr. Warusevitane and Dr. Roffe reported having no disclosures.
Wedge resection in NSCLC: Is 15 mm the magic margin?
BY PATRICE WENDLING
IMNG Medical News
MINNEAPOLIS – Increasing the surgical margin length up to 15 mm during wedge resection of small lung cancer tumors significantly lowered the risk of local recurrence among 474 consecutive patients.
No additional benefit was observed, however, beyond 15 mm, said Dr. Kamran Mohiuddin, a surgical research fellow at Brigham and Women’s Hospital, Boston.
Compared with a margin length of 5 mm, the adjusted risk of local recurrence was estimated to be 45% lower with a margin length of 10 mm (hazard ratio, 0.55), 59% lower with a 15-mm margin (HR, 0.41), and 54% lower with a 20-mm margin (HR, 0.46).
“The downward trend flattens out, indicating diminished benefit of increasing the margin length,” he said at the annual meeting of the American Association for Thoracic Surgery.
Currently, the data are unclear regarding the optimal margin length for wedge resection of small non–small cell lung cancer (NSCLC) tumors of less than 2 cm. Wedge resections are associated with margins less than 1 cm and a high risk for locoregional recurrence (Ann. Surg. Oncol. 2007;14:2400-5), with a multicenter, prospective study suggesting that the optimal margin length should be larger than the maximum tumor diameter (Ann. Thorac. Surg. 2004;77:415-20).
When asked during a discussion of the analysis whether a more aggressive resection or segmentectomy would be performed if margins are found in the operating room to be inadequate based on the current results, senior author Dr. Scott J. Swanson, director of minimally invasive thoracic surgery at the hospital, said they are taking the results forward into practice, but that it’s unclear whether 15 mm is the optimal number to target.
“Is 15 mm the correct margin? I am not sure we know the answer in all cases, but it is a useful number to keep in the surgeon’s head when we are doing resections for tumors that are 2 cm or less,” he said in an interview. “A 15-mm margin seems to be a better target to aim for than margin length to tumor diameter ratio of greater than 1, as suggested by other investigators.”
The current analysis included data from all patients, aged 21-85 years, who underwent wedge resection for NSCLC 2 cm or less at their institution between January 2001 and August 2011. Margin length, defined as the distance from the tumor to the closest stapled resection margin, was 0.1-0.5 cm in 36%, 0.6-1.0 cm in 25.5%, 1.1-2.0 cm in 28.5%, and greater than 2 cm in 10%.
The mean tumor size was 1.33 cm, the location of the tumor was the right upper lobe in the majority (36%), and video-assisted thoracic surgery (VATS) was used in 57.5%. The patients’ mean forced expiratory volume in 1 second (FEV₁) was 79.8%, and the mean age was 68.5 years.
Perioperative death occurred in 1 patient and at least one major complication in 41 patients, Dr. Mohiuddin said.
The local recurrence rate was 5.8% at 1 year, 11.3% at 2 years, and 16.8% at 3 years. Median follow-up was 3.9 years.
In multivariate regression analysis, increased margin length was significantly associated with a lower risk of local recurrence, with evidence of diminished additional benefit beyond a length of 15 mm (P = .031), he said. The analysis adjusted for FEV₁, chronic obstructive pulmonary disease, smoking, diabetes, tumor size, tumor lobe location, location within the hemithorax, surgeon, whether VATS or open surgery was used, and whether or not nodes were sampled.
Dr. Mohiuddin and his coauthors reported having no financial disclosures.
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ACP restates 140- to 200-mg/dL blood glucose target
BY M. ALEXANDER OTTO
IMNG Medical News
Blood glucose levels should be targeted to 140-200 mg/dL in surgical or medical ICU patients on insulin therapy, according to advice the American College of Physicians published in the American Journal of Medical Quality.
Also, “clinicians should avoid targets less than … 140 mg/dL because harms are likely to increase with lower blood glucose targets,” the group said (Am. J. Med. Qual. 2013 [doi:10.1177/1062860613489339]).
The advice isn’t new, but instead a restatement of ACP’s 2011 inpatient glycemic control guidelines reissued as part of its “Best Practice Advice” campaign, said Paul G. Shekelle, Ph.D., senior author of both the advice paper and guidelines (Ann. Intern. Med. 2011;154:260-7).
“This is based on the prior guidelines, so there’s nothing new here in that sense. The Best Practice Advice series sometimes runs in parallel to the guidelines, sometimes it is something completely different than any ACP guidelines, and sometimes, like this case, it runs asynchronous to the guidelines. Ideally, these will be more synchronous in the future,” Dr. Shekelle, director of the RAND Corporation’s Southern California Evidence-Based Practice Center, said in an interview.
ACP’s advice is largely in keeping with glucose control recommendations from other groups, which have tended toward liberalization in recent years amid evidence that aggressive, euglycemic control in hospitalized patients, even if they have diabetes, doesn’t improve outcomes and carries too high a risk of hypoglycemia and its attendant problems.
“Nobody is advocating tight glycemic control anymore in the hospital. It isn’t necessary and may be harmful,” said Dr. Ette S. Moghissi, the lead author on a 2009 inpatient glycemic control consensus statement issued by the American Association of Clinical Endocrinologists and American Diabetes Association (Diabetes Care 2009;32:1119-31).
The consensus statement recommended an upper limit of 180 mg/dL based on the pivotal NICE-SUGAR study, instead of 200 mg/dL, which Dr. Shekelle said ACP chose because it was the upper target limit in several of the additional studies upon which the group based its 2011 guidelines (N. Engl. J. Med. 2009;360:1283-97).
But Dr. Moghissi, who is with the department of medicine at the University of California, Los Angeles, said she’s concerned that 200 mg/dL might be too high.
“We know that when we set targets, people do not achieve them. So when we set a higher target, most of the time people go above that. The concern” is that a target of 200 mg/dL “may be perceived [as meaning that] a little bit over 200 mg/dL is okay,” but “above 200 mg/dL, usually there are issues with increased risk of infection, poor wound healing, volume depletion,” and other problems, she said in an interview.
Dr. Shekelle and Dr. Moghissi said they have no relevant disclosures.
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Empiric echinocandin deemed best for candidemia
BY M. ALEXANDER OTTO
IMNG Medical News
LAS VEGAS – An echinocandin should be used for empiric therapy in critically ill candidemia patients awaiting culture results, according to investigators from Wayne State University in Detroit.
The reason is that *Candida glabrata* is on the rise in the critically ill, and it’s often resistant to fluconazole, the usual empiric choice, said Dr. Lisa Flynn, a vascular surgeon in the department of surgery at the university.
Dr. Flynn and her colleagues came to their conclusion after reviewing outcomes in 91 critically ill candidemia patients. Just 40% (36) had the historic cause of candidemia, *C. albicans*, which remains generally susceptible to fluconazole; 25% (23) had *C. glabrata*; and the rest had *C. parapsilosis* or other species.
Before those results were known, 53% (48) of patients were treated empirically with fluconazole and 36% (33), with the echinocandin micafungin. Most of the others received no treatment.
Seventy percent (16) of *C. glabrata* patients got fluconazole, the highest rate in the study of inappropriate initial antifungal therapy; probably not coincidently, 56% (13) of the *C. glabrata* patients died; the mortality rate in patients with other candida species was 32% (22). On univariate analysis, mortality increased from 18% to 37% if *C. glabrata* was cultured.
“When we looked at *glabrata* versus all other candida species, we found significant increases in in-hospital mortality” that corresponded to a greater likelihood of inappropriate initial treatment, she said at the annual meeting of the Surgical Infection Society.
For that reason, “we are proposing that initial empiric antifungal therapy start with an echinocandin in the critically ill patient and then de-escalate to fluconazole if [indicated by] culture data,” she said.
It’s sound advice to use empiric antifungal therapy starting with an echinocandin in the critically ill patient and then de-escalating to fluconazole if indicated by culture data, so long as “your incidence of *Candida glabrata* is high,” session moderator Dr. Addison May said after the presentation.
“It really depends on your hospital’s rate, and how frequently it’s [isolated]. It’s important to understand what you need to empirically treat with,” but also important to use newer agents like micafungin judiciously, to prevent resistance, said Dr. May, professor of surgery and anesthesiology at Vanderbilt University in Nashville, Tenn.
*C. glabrata* patients were more likely than others to be over 60 years old; they had longer hospital and ICU stays, as well.
The mean APACHE II (Acute Physiology and Chronic Health Evaluation II) score in the study was 25, and the mean age was 57 years; 54% (49) of patients were men, and 68% (62) were black. In the previous month, almost half had surgery and a quarter had been on total parenteral nutrition.
Central lines were the source of infection in 84% (76).
On multivariate analysis, inappropriate initial antifungal treatment, vasopressor therapy, mechanical ventilation, and end-stage renal disease were all significant risk factors for death.
Dr. May and Dr. Flynn said they had no relevant financial disclosures.
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VIEW ON THE NEWS
Dr. Steven Q. Simpson, FCCP, comments: This article underscores the need for understanding our local fungal isolates and their resistance profiles, and it doesn’t even mention the additional problem of fluconazole resistance among *C. albicans* isolates. The question that is more difficult to answer is that of when, in the course of changing resistance patterns, it is important to change empiric therapy. We will face this issue more and more in the future, since anti-infective development is slow-paced and almost nonexistent, while resistance development seemingly proceeds at a gallop. How do we balance the risk for an individual patient with the ultimate risk to all patients?
Among the myriad efforts at performance improvement in our hospital system, none loom larger than those aimed at preventing readmissions. While clinicians have long known that patients’ outcomes suffer when they are readmitted to the acute care hospital, now hospital outcomes will also suffer – financially, by up to 2% of Medicare billings for FY 2014, with greater penalties in future years.
Our system expects to lose $575,000 for FY 2013, when the penalty is a more modest 1% of Medicare billings. Efforts to prevent readmissions to date have focused primarily on finding and eliminating process gaps: Have we adequately educated the patient and family about medications, treatments, follow-up appointments? Are there transportation challenges? Can the patient afford and obtain medications?
National efforts have addressed the most common gaps. These efforts are very effective for the patient whose illness trajectory is one of slow and steady improvement.
As patients enter the final phase of a serious illness, the trajectory is progressive decline, despite available treatments. Trajectory of decline is characterized by functional decline, loss of lean body mass, and the need for frequent medical care (hospitalization, ED and physician visits). These patients have multiple transitions between and among health care settings. Recent analysis of data from the Centers for Medicare and Medicaid Services was discouraging: Though hospice at time of death doubled between 2000 and 2009, nearly a third of those patients were in hospice 3 or fewer days. Forty percent of those short-stay patients were discharged to hospice from an ICU. Fourteen percent of Medicare decedents in 2009 had at least one transition of care in the last 3 days of life (JAMA 309:470-77).
On the palliative care service, we encounter a group of patients who are frequently readmitted, not because of process gaps, but because they are too ill to live well outside of the hospital without significant assistance. For these patients, the readmission is a symptom, not the problem.
The problem is that the patient is dying. How can we better manage the transition away from acute care for the patient whose death is expected? Often these patients are readmitted because we have not provided an alternative to hospital admission for the next crisis. Medicare skilled nursing facilities, and long-term acute care and rehabilitation hospitals, are designed to care for patients whose conditions are improving, and as a result, they rapidly transfer declining patients back to the acute care hospital.
Hospice, as an interdisciplinary 24-hour model of care, is uniquely positioned to treat symptoms and assist the patient and family to cope with distress and grief. Hospices are required to provide respite to caregivers as well as options for inpatient care when the patient’s symptoms cannot be reasonably managed in another setting. Hospice admission within 30 days of death significantly reduces the likelihood of 30-day readmission, subsequent ICU admission, and death in the hospital (Health Aff. 2013;32:552-61). Greater reduction in the likelihood of these outcomes is seen with hospice admission at least 53 days before death. Ironically, hospice patients have demonstrated longer life expectancy than their disease-matched counterparts (J. Pain Symptom Manage. 2007;33:238-46).
Patients with serious, progressive illness need concrete information about the natural history of the illness, its expected course and prognosis, and the potential impact of proposed treatments on morbidity as well as mortality. Understanding what is expected in the illness often alters the choices patients make about treatment and postacute care. After disease education, a patient and family can select goals of care and treatment options that align with their preferences. When asked, most laypersons prefer to die at home, comfortably, with their family. For these patients, the question is not “Do you want to die?” but “How do you want to die?” These conversations are difficult for all involved (physician, patient, family), but allow patients to make truly informed decisions about their care, and to decide what is most important as death approaches.
Lacking complete information, patients are often subjected to a merry-go-round of transfers between the acute and postacute environments, with increased caregiver stress. Attention to goals of care results in fewer readmissions, higher satisfaction, and better outcomes for patients and health care organizations.
Palliative care teams can provide consultative assistance with these conversations, and may be available to provide additional training to health care providers as well. If your institution does not have a palliative care team, look to a board-certified palliative medicine clinician in your community (often the hospice medical director) for consultation and guidance.
Dr. Fredholm and Dr. Bekanich are codirectors of Seton Health Palliative Care, part of the University of Texas Southwestern Residency Programs in Austin.
Dr. Paul A. Selecky, FCCP, comments: Our palliative care colleagues make an interesting point on the growing concerns about preventing readmissions for flares of chronic disease. Some of our patients might be eligible for hospice care, an underutilized resource to treat a long life of suffering. Palliative care teams are uniquely qualified by providing a multidisciplinary approach to these patients, ideally done before the need for hospitalization.
FROM THE PRESIDENT: CHEST World Congress 2014 – New, innovative, forward-thinking, Madrid …
BY DR. DARCY D. MARCINIUK, FCCP
I want to share with you the latest news about the CHEST World Congress (CWC) 2014 to be held in Madrid on March 21-24, 2014. This educational conference is definitely creating some excitement. The preparations for CWC 2014 are proceeding rapidly with an enthusiastic commitment to assemble the best clinical educational offering possible.
Dr. Mark J. Rosen, FCCP, Director of Global Education and Strategic Development, and ACCP Past President (2006-2007), is keeping you well informed about how the program is developed in this issue of CHEST Physician (see page 18).
The Scientific Program Committee is composed of more than 25 international experts and is led by co-chairs Drs. Richard Irwin and Joan Soriano. I confirm that they are doing an extraordinary job. It is truly inspiring to see so many world leaders and experts work diligently, devoted to putting together the very best possible program for attendees from around the world.
New heights …
CWC 2014 isn’t the first international conference held outside the United States or Canada by the ACCP. The list of venues is impressive: Rio De Janeiro 1952, Barcelona 1954, Colombia 1956, New Delhi 1958, Vienna 1960, Mexico City 1964, Copenhagen 1966, Lausanne 1970, and London 1974. ACCP meetings were held in Rome twice: the first in 1950, and again in 1977. The ACCP holding first-rate conferences around the world is nothing new, but what is new is that CWC 2014 will reach new heights of educational excellence and be a truly unique and refreshing opportunity.
CWC 2014 builds on the proven expertise and commitment to clinical education of both the ACCP and SEPAR (Sociedad Española de Neumología y Cirugía Torácica – our colleagues from Spain). I just returned from the annual SEPAR Congress in Barcelona, a conference with a long and proud tradition. It was extremely well attended and was fortified with leading experts in areas covering the entire spectrum of our field. Quite simply, the goal of the ACCP-SEPAR partnership is to put together the very best educational conference possible. CWC 2014 will take the best from both the ACCP and SEPAR and achieve that goal by providing a new international platform for chest medicine that allows the genuine sharing of ideas and expertise with clinical colleagues from around the world.
Innovative …
From the start, CWC 2014 is designed to be an international conference very different from traditional meetings. Innovative and varied educational methods and techniques will be used to create unique learning experiences for everyone. There will, of course, be lectures from world experts and pro/con debates on controversial topics in clinical medicine, along with smaller sessions allowing you to get close to leading professors. But there will also be an abundance of lively interactive sessions, enabling you to actively participate in your learning throughout the conference. Be prepared for true high-fidelity, simulation-based clinical learning scenarios and immersive experiences. Look for advanced case-and problem-based sessions and small-group interactive discussions. And completely new to other international conferences, there will be a variety of self-study stations available throughout the venue, further complementing the entire CWC 2014 program.
Forward-thinking …
At the direction of Drs. Irwin and Soriano, the vision for the Congress is to look forward and anticipate the future, and to prepare today’s practicing clinician for tomorrow. The Scientific Programme Committee designed the scientific program accordingly to ensure that you, the practicing clinician, are standing at the vanguard of clinical chest medicine, and improving what matters most - the very best care for your patients. You’ll also share this experience with clinical colleagues from the United States, Canada, and countries around the world.
Madrid, Spain …
I’ve visited Madrid and Spain a number of times, and each visit was better than the last. Spain is rich in tradition and culture, and the warmth and hospitality of the Spanish people will make you feel comfortable the moment you arrive. Madrid has so much to see and offer - the world-famous Prado museum, incredible architecture, flamenco dancing, mouth-watering cuisines (... I can never get enough paella!), and exceptional wines. Plenty of exceptional wines!
My wife Carla and son Jeff accompanied me on my trips to Barcelona and to Madrid, and we shared a wonderful experience, one that I recommend for you and your family.
Learn more about CHEST World Congress 2014 at chestnet.org/Education/CHEST-Meetings/CHEST-World-Congress-2014/, and consider submitting an abstract or case report (CHEST World Congress Topic Submission: www.surveymonkey.com/s/CWC2014) to have another reason to attend the CWC 2014.
New, innovative, forward-thinking, Madrid – that is CWC 2014! All from your trusted source for the very best clinical education in pulmonary, critical care, and sleep medicine. Now you can see why CWC 2014 is creating so much excitement!
Recent honors for ACCP Presidents, current and past
Founders Award
Dr. Darcy Marciniuk, FCCP, current ACCP President, was recently honored by the Canadian Lung Association, which presented him with its highest honor, the Founders Award. The presentation took place during the Respiriety State of the Art Conference, in Saskatoon, Canada, on June 1, 2013.
The Founders Award honors individuals who have devoted themselves to the affairs of the Lung Association and to the cause of respiratory health. Dr. Marciniuk is a well-recognized and respected world leader in lung health and a pioneer in implementing the concept of chronic disease management for COPD. “This award, which recognizes exemplary innovation or commitment toward lung health, is conferred once every 2 years, and we were pleased to celebrate and recognize Dr. Marciniuk,” says Dr. Brian Graham, president and CEO of the Lung Association of Saskatchewan.
Pioneering Spirit Award
Dr. Richard S. Irwin, Master FCCP, CHEST Editor in Chief, and Past President of the ACCP, was recently presented with one of the American Association of Critical-Care Nurses’ highest national honors, the Pioneering Spirit Award, at the AACN’s National Teaching Institute & Critical Care Exposition. The award was presented by two of his longstanding colleagues, Dorrie Fontaine, RN, PhD; and Kathleen McCauley, PhD, RN, ACNS-BC, both past presidents of AACN.
Dr. Irwin was honored for his pioneering and visionary advocacy of collaborative leadership and interdisciplinary practice between medicine and nursing. The Pioneering Spirit Award from the AACN is supported by GE Healthcare and recognizes significant contributions that influence high acuity and critical care nursing and relate to the association’s mission, vision, and values.
Planning for CHEST World Congress 2014
BY DR. MARK J. ROSEN, FCCP
Director, Global Education and Strategic Development, American College of Chest Physicians
A small group of physicians and staff representing the ACCP and SEPAR are working in the background to coordinate the planning and complex activities that produce a meeting of the scale of CHEST World Congress (CWC) 2014. To that end, an Executive Program Committee was appointed, in Barcelona, Spain, on June 13. The Committee was charged with assembling a program for the general sessions, using a process modeled after the annual CHEST meeting. As for CHEST, an open call for topics yielded over 200 submissions from around the world, and the Committee selected 62 of them for general sessions. An international array of outstanding faculty is featured. After his splendid work chairing the Program Committee session for this year’s CHEST meeting in Chicago, Dr. Jack Buckley, FCCP, agreed to take on moderating the CWC Program Committee.
The group set out to develop a program that offers international perspectives on the future of chest medicine presented by an expert international faculty. To achieve this, the Program Committee consists of participants representing not only the United States, Canada, and Spain, but also Latin America, Italy, Greece, India, and China. Most had no experience planning for CHEST, but under Dr. Buckley’s guidance, they put together a schedule for CWC that spans 3 days, offers international “star” faculty to cover a wide menu of topics, and is constructed carefully to avoid similar topics competing for the same time period.
As leaders in chest medicine themselves, the Committee members were also not shy about putting forward strong opinions and ideas. Dr. Buckley skillfully kept the group on task, and at the end of the day, we had a very strong program.
The Call for Abstracts and Case Reports is underway until August 12. The process of submission and selection is also following the CHEST model, and we urge you to take the opportunity to participate. All of the information about the Congress, including the link to submit topics and case reports, is found at the official website: chestworldcongress2014.org.
We look forward to your contribution to the Congress and to seeing you in Madrid next March.
CHEST 2013: Come for just 1 day, or make a whole weekend of it
If you’d like to attend CHEST 2013 but have trouble scheduling time away from your practice, consider the 1-day registration.
Register for any given day, Sunday through Thursday. Or, attend for the weekend by registering for a postgraduate course on Saturday and 1 day on Sunday. If you come for the weekend, consider bringing your family. There’s so much to do for everyone in Chicago.
Postgraduate Courses
Saturday, October 26
Enhance your learning at any of the postgraduate courses, focusing on specific topics to deliver the relevant clinical information you need to make informed decisions with your patients. Postgraduate courses include:
- A Case-Based Review of Critical Care: Why Didn’t They Tell Me This in Fellowship?
- Advanced Critical Care Echocardiography
- Interventional Therapy for Pleural Disease: Evidence-Based Practice
- Pulmonary Literature Review
- Sleep Medicine Literature Review
- 21st Annual Assembly of the American Association for Bronchology and Interventional Pulmonology
Program Highlights
The CHEST 2013 program will connect you to education opportunities that optimize the clinical decisions you make. The relevant sessions and community of innovative problem-solvers in attendance promise to inspire and energize you. Don’t miss these highlights:
General Sessions
Sunday, October 27 - Thursday, October 31
Choose from more than 300 sessions, offered in a variety of instructional formats.
Opening Sessions
Sunday, October 27 - Monday, October 28
Attend opening sessions featuring keynote speakers, Jim Collins and Chris Draft.
ACCP Simulation Center
Sunday, October 27 - Wednesday, October 30
Practice your clinical skills in a hands-on learning environment.
Ticketed Sessions
Clinical Resource Center
Monday, October 28 - Wednesday, October 30
Don’t miss the showcase of diagnostic and treatment solutions for optimal patient care.
Play Time!
Fall is the perfect time to visit Chicago. Fewer crowds, colorful scenery, and cooler temperatures make it a popular destination during the vibrant, autumn months. And, it’s family friendly. If you have free time during CHEST, be sure to check out what the city has to offer at ChooseChicago.com.
Learn more about CHEST 2013 and registration opportunities at chestmeeting.chestnet.org.
This Month in CHEST: Editor’s Picks
BY DR. RICHARD S. IRWIN, MASTER FCCP
Posttraumatic Stress Disorder in Survivors of Acute Lung Injury: Evaluating the Impact of Event Scale-Revised. By Dr. O. J. Bienvenu et al.
Ventilator-Associated Tracheobronchitis in a Mixed Medical/Surgical Pediatric ICU. By Dr. V. S. Simpson et al.
Does Autotitrating Positive Airway Pressure Therapy Improve Postoperative Outcome in Patients at Risk for Obstructive Sleep Apnea Syndrome? A Randomized Controlled Clinical Trial. By Dr. S. M. O’Gorman et al.
SPECIAL FEATURE
COPD Surveillance—United States, 1999-2011. By Dr. E. S. Ford et al.
POINT/COUNTERPOINT EDITORIAL
Should Board Certification Be Required for Sleep Test Interpretation?
Yes – Dr. S. A. Fleishman et al.
No – Dr. Richard D. Simon Jr.
Rebuttal from Dr. Fleishman et al.
Rebuttal from Dr. Simon.
Research outcomes, Choosing Wisely, Home Care
Clinical Research
Identifying good outcomes for clinical research
For clinicians and patients, the appropriate selection of endpoints or outcomes in clinical research is important. Positive, or in certain circumstances negative, results, provide evidence about the efficacy, safety, and risks and benefit ratio of potential treatments for the disease in question.
Outcome selection is usually influenced by the study design and the resources allocated for the study and should be selected in a manner that maximizes the usefulness and interpretation of the results. In addition, outcome selection should be balanced with the natural scientific desire to achieve faster results, safety and efficacy issues, and the need to obtain meaningful data that are internally and externally valid. Endpoints that are less definitive may allow for shorter studies and easier ascertainment but may not yield useful or meaningful information in regards to how the study intervention would save lives and decrease morbidity by promoting health.
Historically, we have relied primarily on traditional biomedical measures, such as the results of laboratory tests and changes in other metrics or crude outcomes, such as mortality, to try to determine whether a health intervention is necessary and whether it is successful. We have discovered, however, that when we use only these measures, we and the scientific community may miss many of the outcomes that may also matter most to patients. Hence, outcomes in clinical research must also measure how patients function and their experiences with care. Over the last decade, we have observed a trend toward researchers selecting outcomes that matter to patients such as: the quality of life, functionality, and cognition (Mikkelsen et al. *Am J Respir Crit Care Med.* 2012;185[12]:1307).
For the future, it is imperative that researchers design studies that will have a high yield in these domains as much as on mere survival.
The scientific method demands a rigorous approach. Identifying problems and testable hypotheses is important, but at the time of obtaining meaningful results that matter to patients, choosing the right outcomes becomes of vital importance.
Dr. Fred Rincon, FCCP
Steering Committee Member
Critical Care
Choosing Wisely ... in critical care medicine
The Choosing Wisely campaign is an effort sponsored by the American Board of Internal Medicine (ABIM) Foundation to “help physicians and patients engage in conversations about the overuse of tests and procedures and support physician efforts to help patients make smart and effective care choices.” Major physician professional societies have partnered with consumer groups, led by *Consumer Reports*, in this attempt to improve the quality and safety of health care in America.
Representatives of physician professional societies gather to create Top 5 lists, which consist of five specific evidence-based recommendations of things physicians and patients should question in order to make wise care decisions on an individualized basis. For example, the list of the American College of Physicians includes a recommendation that internists “Don’t obtain preoperative chest radiography in the absence of a clinical suspicion for intrathoracic pathology.” The first of these lists was released in April 2012.
In the fall of 2012, under the leadership of Dr. Scott Halpern of the University of Pennsylvania, representatives of the American College of Chest Physicians, the Society of Critical Care Medicine, and the American Thoracic Society gathered to begin work on a Top 5 list for critical care medicine. Representing the College
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were Drs. Curt Sessler of Virginia Commonwealth University and Dr. Robert Hyzy of the University of Michigan. Over the next few months, through the leadership of Dr. Halpern, an initial list of more than 12 potential recommendations was whittled down to a list of five final recommendations.
The recommendations were reviewed and later endorsed by each participating professional society, including the Critical Care NetWork of the ACCP. The ABIM plans to announce the list, along with the lists of several other medical specialties, this fall. Look for a lively and engaging session in Chicago at CHEST 2013 entitled Choosing Wisely in Critical Care Medicine, which is being chaired by Dr. Halpern. For additional details on the Choosing Wisely campaign, see choosingwisely.org.
Dr. Robert Hyzy, FCCP
Steering Committee Member
Home Care
Acute care to home
Envision the use of bundled payments to address physician myopia, bringing home care into focus:
In a fee-for-service world, US health care institutions are encouraged to provide services without regard to cost or outcomes. In 2009, the Jencks report highlighted that COPD and pneumonia were important medical diagnoses driving high 30-day readmission rates.\(^1\) Since that time, multiple care transition plans have been investigated. One example, the “DASH” program in western Pennsylvania, reports a reduction in 30-day readmission rates for COPD from 25% to less than 5%.\(^2\) This plan integrates the hospitals, postacute care facilities, and home health care in a “pull in” model of empowerment to address symptoms and maintain self-care. There is a focus on home-based care using respiratory therapists, pulmonary rehabilitation, and durable medical equipment providers.
This year, *JAMA* published three trials studying these issues on a larger stage. These studies emphasized the need to create better patient center models of care limiting fragmentation to support a transition from acute care to home. These studies highlight that the current system is myopic, with care providers that are incentivized to develop care plans that look no further than the room in which they sit.\(^3\)
This month, The Medicare Payment Advisory Commission released a report with a new vision for providing home-based medical care. It emphasizes a limitation of traditional fee-for-service care replacing it with bundled payments encouraging hospitals to partner with post-acute care and home care providers to provide care plans for patients with chronic illness focused on ultimate success in a home environment.\(^4\)
Dr. Lisa Wolfe, FCCP Chair
References
1. Jencks SF, Williams MV, Coleman EA. Rehospitalizations among patients in the Medicare fee-for-service program. *N Engl J Med*. 2009; 360(14):1418-1428.
2. Carlin B, Wiles K, Easley D, Rees N. Transition of care and rehospitalization rates for patients with COPD and CHF who require supplemental oxygen therapy. *Chest*. 2012;142(4-MeetingAbstracts):139A.
3. Williams MV. A requirement to reduce readmissions: take care of the patient, not just the disease. *JAMA*. 2013;309(4):394-396.
4. Report to Congress: Medicare and the Health Care Delivery System 2013. Accessed Sept 16, 2013. Available at medpac.gov/documents/Jun13_EntireReport.pdf.
Cement your place in ACCP history with an entrance paver
In early 2014, the ACCP will move into a 48,500 square foot Silver LEED-certified headquarters in Glenview, Illinois, moving the College to a new model of educational delivery that is hands-on, in-depth, and flexible. With a year-round center for immersive training and innovation, as well as on-demand access to tools for physicians, the ACCP will have a platform to advance chest medicine and the wellness of your patients.
With the help of members, friends, and supporters, the ACCP can take the next great leap in advancing chest medicine and wellness — one whose effects will be felt well beyond its walls. Philanthropy will enable the ACCP to realize this goal and advance lung and heart health for patients everywhere. A distinctive way to assist the ACCP and “cement” your place in ACCP history is to purchase a customizable brick.
The ACCP designed a section of customizable bricks located near the entrance to the new building that will reflect donors’ commitment while displaying messages that memorialize, pay tribute to, or lend support to the fight for better lung health. There are only a limited number of bricks available, so purchase yours today. Distinctive donor recognition options are available for donors of $1,000, $5,000 and $10,000 and above, beginning with sidewalk pavers at the $1,000 level.
For more information and to purchase a paver, contact email@example.com.
CHEST ‘Impact Factor’ increases
The new Thomson Reuters Journal Citation Report Impact Factor (IF) numbers 2012 were released in mid-June, and show that the *CHEST* IF for 2012 increased from 5.25 to 5.85, ranking 4th for respiratory journals and 3rd in critical care in those categories.
*CHEST* was particularly pleased to see that it ranks first in the Immediacy Index in both categories. This is a measure of how quickly articles from a journal are cited by other sources. In only its second year in the Critical Care category, *CHEST* is ranked third for overall impact and second for 5-Year Impact Factor, Article Influence Score, Total Citations, and Eigenfactor Score.
Read more at “About CHEST” on the Journal site.
See the graphic below for numbers for *CHEST* from this year’s Journal Citation Report.
| Measurement | Value | Rank in Respiratory | Rank in Critical Care |
|----------------------|---------|---------------------|-----------------------|
| Impact Factor | 5.85 | 4th | 3rd |
| 5-Year Impact Factor | 6.420 | 3rd | 2nd |
| Immediacy Index | 3.394 | 1st | 1st |
| Article Influence Score | 2.188 | 3rd | 2nd |
| Total Citations | 44,596 | 2nd | 2nd |
| Eigenfactor Score* | 0.08109 | 2nd | 2nd |
* The Eigenfactor Score calculation adjusts for self-citations.
NORTH CAROLINA
Wilson
Board Certified/Eligible Pulmonologist sought for independent specialty group with hospital support. Competitive salary / Benefits. Desired start date fall 2013, 2 years to partnership. Very nice lifestyle, good schools, Raleigh area and close to coast. Beautiful office. Future option to open separate practice with support of oncologist if desired.
Please send CV to:
firstname.lastname@example.org
EXCELLENT CRITICAL CARE/INTENSIVIST OPPORTUNITY
Well respected private practice group is seeking BC/BE Critical Care/Intensivist. This group provides coverage for ICU’s in the Kettering Health Network at Sycamore Medical Center, Kettering Medical Center, and Soin Medical Center. Voted one of the Greater Dayton Areas Top 20 Workplaces, this group enjoys a very collegial atmosphere. Qualified candidates will enjoy a full benefits package and competitive salary. Kettering Health Network has been a Thomson Reuters Top 10 Hospital System 3 years in a row and is focused on quality patient care!
This busy group is growing to meet demanding community needs. The Greater Dayton Area is a fantastic place to raise a family and offers all the warmth and charm you can find only in the Midwest. There’s plenty to see and do locally, including the hometown favorite Dayton Dragons baseball team, the world-class Schuster Performing Arts Center, Wright Patterson Air Force Museum and a variety of prestigious championship golf courses. Dayton truly has the best of both worlds…community charm with metropolitan amenities.
Not a J-1 Visa opportunity
For more information contact: Sandy Jones
937-395-8290 (office) / Fax CV to 937-522-7329
email CV to email@example.com
MAINE, Portland
Pulmonary/Critical Care/Sleep Medicine. Mercy Hospital, a 170-bed community hospital in seaside Portland, Maine, seeks BC/BE Pulmonary/Critical Care/Sleep Physician to join an established, hospital-based practice. This practice oversees a 7-bed open ICU, full time Hospice and Sleep Services, in-patient care. Call is shared among four physicians. A competitive compensation with full benefits is offered. FMI:
firstname.lastname@example.org or 800-546-4090
NORTH CALIFORNIA
Pulmonology Opportunity. Sutter Health-affiliated Gould Medical Group is seeking a General Pulmonologist for its Tracy, California office. Inpatient and Critical Care is at Sutter Tracy Community Hospital, an 82-bed facility also affiliated with Sutter Health, and clinic is across the street. Call is every other week.
C.V. Allen, M.D.
Ph (866) 454-6853 Fax (209) 550-4892
email@example.com
www.suttergould.org/doctors
WESTERN NORTH CAROLINA
PHYSICIAN, PULMONOLOGY – Employment opportunity for a fellowship trained, board certified physician in the specialty of pulmonary disease. Join this established multi-disciplinary team of cancer care physicians in Western North Carolina. You will provide comprehensive, outpatient pulmonary care with limited critical care service. We offer competitive salary, including bonus potential, paid medical malpractice, a relocation package, 401(K) retirement and excellent health benefits for you and your family.
Just 30 minutes from Asheville, come live and work in Western North Carolina, where you can start your day with views of the beautiful mountain vistas of the Smoky Mountains. Enjoy the charms of quaint historic towns in places of natural beauty or explore the culturally diverse city of Asheville. The area is known for its temperate climate with pleasant summer days and cool nights.
Send CV to:
firstname.lastname@example.org
or call 954-540-8505
Disclaimer Chest Physician assumes the statements made in classified advertisements are accurate, but cannot investigate the statements and assumes no responsibility or liability concerning their content. The Publisher reserves the right to decline, withdraw, or edit advertisements. Every effort will be made to avoid mistakes, but responsibility cannot be accepted for clerical or printer errors.
GEORGIA, Atlanta
The Atlanta VA Medical Center and Division of Pulmonary, Allergy & Critical Care Medicine at Emory University are seeking a physician-scientist or clinician-investigator to lead the VA Pulmonary Section. Candidates should be Assistant or Associate Professor with demonstrated success in laboratory or clinical research and a strong commitment to mentoring fellows and junior faculty. The VA Pulmonary Section includes 7 physicians with NIH and VA funded research and 3 VA career development awardees. The successful candidate will assume a leadership role integrating clinical and academic functions, with the 50 full-time faculty and NIH funded training program of the Pulmonary Division in the Department of Medicine. Atlanta is a thriving metropolitan area. The VA Medical Center is adjacent to the campuses of Emory University and the Centers for Disease Control. Interested applicants should contact:
David M. Guidot, MD, Division Director, at 404-712-2970 or email@example.com and apply online at www.usajobs.gov, announcement JV-13-238CW-874134 for consideration.
CONTINUING EDUCATION
19th Annual UCLA Symposium
Pulmonary Function and Exercise Testing
October 10-11, 2013
Newport Beach Marriott Hotel, California
$550 physicians; $400 non-physicians
www.cme.ucla.edu/courses
<http://www.cme.ucla.edu/courses>
Early adenotonsillectomy does not improve attention
BY MARY ANN MOON
IMNG Medical News
Compared with watchful waiting, early adenotonsillectomy did not significantly improve attention or executive function as measured by neuropsychological testing in school-aged children with obstructive sleep apnea syndrome, according to a new report.
However, early surgery did markedly improve polysomnographic abnormalities, as well as parent- and teacher-reported measures of behavior, executive function, and sleep symptoms, compared with watchful waiting, said Dr. Carole L. Marcus, director of the sleep center at Children’s Hospital of Philadelphia, and her associates.
“We observed no significant difference between the two groups in the change from baseline to follow-up in our primary outcome, the attention and executive-function score of the NEPSY [Developmental NeuroPsychological Assessment]; thus, our trial is a negative one. However, other tests showed evidence of changes in behavior,” noted Dr. Marcus and her associates in the Childhood Adenotonsillectomy Trial (CHAT).
The findings were published online in the New England Journal of Medicine (2013 May 21 [doi:10.1056/NEJMoa1215881]).
CHAT involved 453 children aged 5–9 years treated at seven academic sleep centers, who underwent standardized polysomnographic assessments and extensive neuropsychological testing and answered sleep and quality of life–related questionnaires.
The children were randomly assigned to undergo adenotonsillectomy within 1 month (226 patients) or to be followed with watchful waiting (227 control subjects), and were formally assessed 7 months later. Their cognitive and behavioral scores were close to population means. A similar number of children in each group used nasal glucocorticoids or montelukast for allergic rhinitis or asthma. About half of the children in each group were overweight or obese.
The change in the attention and executive-function score on the NEPSY (primary outcome) was greater in children who underwent adenotonsillectomy than in controls, but the difference did not reach statistical significance. However, outcomes were significantly better with surgery than with watchful waiting on measures of obstructive apnea-hypopnea, oxygen desaturation index, hypercapnia, sleep arousal index, and percentage of sleep time in light sleep. More children who underwent early adenotonsillectomy (79%) achieved normalization of the obstructive sleep apnea syndrome, compared with control subjects (46%).
Adenotonsillectomy improved outcomes to a significantly greater degree than did watchful waiting on the Conners’ Rating Scale assessing restlessness, impulsiveness, and emotional lability, and on all other measures of behavior and quality of life. Changes were clinically significant.
CHAT was supported by the National Institutes of Health. Dr. Marcus reported receiving research equipment from Philips Respironics and Ventus Medical; her associates reported ties to industry sources.
prevalence of OHS varies widely between different studies, and current data are most likely to be an underestimation because many cases of the disease remain unrecognized. According to a recent review, the overall prevalence of OHS varies between 10 and 20% in outpatient populations (Mokhlesi et al. *Chest*. 2007;132[4]:1322) but is reported to be as high as 31% among hospitalized patients (Nowbar et al. *Am J Med*. 2004;116[1]:1).
The reason why less than one-third of morbidly obese patients with OSA develop diurnal hypercapnia remains unclear. Possible contributors to disease development include both altered central respiratory drive and increased mechanical load on the respiratory muscles due to severe obesity. Patients with OHS have been noted to have increased levels of leptin compared with their eucapnic counterparts. This is despite the fact that this protein acts as a respiratory stimulant, suggesting that leptin resistance may contribute to their hypoventilation. In addition, there is evidence that chronic severe OSA can induce minute but progressively greater effects on renal bicarbonate retention over time, leading to impaired ventilatory compensation for carbon dioxide retention (Norman et al. *J Appl Physiol*. 2006;100[5]:1733).
**Screening for OHS**
Because arterial blood gas (ABG) sampling is not routinely performed in obese patients unless physicians have a high clinical suspicion for OHS, less invasive screening modalities are needed in order to aid in the early diagnosis of disease. Serum bicarbonate may be one option since levels are elevated in patients with OHS secondary to their chronic respiratory acidosis and is readily available as part of a basic chemistry panel. In one study of OSA patients, a serum bicarbonate >27 mEq/L was found to have a high sensitivity of predicting OHS (92%) but a low specificity (50%) (Mokhlesi et al. *Sleep Breath*. 2007;11[2]:117). Only two polysomnographic parameters were associated with a statistically significant increased risk of OHS, apnea-hypopnea index (AHI), and nadir oxygen saturation during sleep. Combining all of these variables into one prediction rule did not achieve a positive predictive value of greater than 50% for OHS, indicating that patients in a high-risk group still need formal evaluation by ABG.
Another attractive option is transcutaneous CO₂ monitoring, which is becoming increasingly available in sleep labs. The role of this modality in screening for OHS has not been extensively studied, though readings seem to correlate well with arterial PCO₂ in obese patients. Current recommendations state that transcutaneous PCO₂ values should be confirmed with arterial blood gas testing (Berry RB et al. *J Clin Sleep Med*. 2010;6[5]:491). At this time, routine use during diagnostic polysomnography is probably not appropriate as a mechanism for diagnosing hypoventilation. Based upon available data, it seems appropriate to perform ABG analysis to confirm the presence of hypercapnia in obese patients with sleep-disordered breathing who have a bicarbonate level above 27 mEq/L and/or diurnal hypoxemia (pulse oximetry < 94%). In superobese patients (BMI > 50 kg/m²) who are scheduled for bariatric surgery (Mechanick JL et al. *Obesity*. 2009;17: S3), a thorough evaluation including laboratory testing (complete blood count, thyroid-stimulating hormone), chest radiographs, and complete pulmonary function tests should also be performed to exclude other etiologies, which could contribute to CO₂ retention in these subjects.
**OHS-associated morbidity and mortality**
The risk of cardiovascular events is elevated in obese patients with OSA, and the presence of OHS in these patients leads to a further increase in morbidity and mortality (Berg et al. *Chest*. 2001;120[2]:377). Compared with patients with OSA alone, patients with OHS are sleepier during the day and are more likely to have severe exertional dyspnea, lower extremity edema, pulmonary hypertension, and cor pulmonale at the time of initial diagnosis (Kessler et al. *Chest*. 2001;120:369). Patients with OHS use great quantities of health-care resources and have high rates of ICU admission, mechanical ventilation, and long-term care; 18 months after hospitalization, mortality was more than doubled in patients with OHS compared with obese control subjects (23% vs 9%) (Nowbar et al. *Am J Med*. 2004;116[1]:1). Alarmingly, despite having received a diagnosis of OHS while hospitalized, only 13% of these patients were discharged using positive airway pressure therapy (PAP) therapy for their disease.
**The role of positive airway pressure in OHS**
PAP (both as CPAP and bilevel pressure) is the most-studied and well-proven therapy for patients with OHS. This treatment corrects sleep disordered breathing and may partially reverse nocturnal hypoventilation by improving carbon dioxide clearance from inadequately ventilated alveoli. When implementing therapy for stable patients with OHS during in-lab titration, CPAP is initiated first, with levels increased to eliminate any evidence of airway obstruction (including flow limitation), though CPAP alone may not be sufficient to alleviate nocturnal hypoventilation. If oxygen saturation remains below 90% despite resolution of obstructive events, patients can be switched to bilevel PAP, with inspiratory pressure increased over the CPAP until oxygen saturation improves; a pressure difference of at least 6 to 7 cm H₂O is generally required. Other indications for bilevel pressure include patients presenting with an acute decompensation of their chronic respiratory failure and patients who are intolerant of the level of CPAP required to completely alleviate their obstructive physiologic condition. Oxygen supplementation can be considered if pressure support needs to exceed 8 to 10 cm H₂O. The role of transcutaneous carbon dioxide monitoring during PAP titration in patients with OHS has not been well-studied but would seem to be a reasonable option to help identify the most appropriate level of therapy (Chau et al. *Clin Sleep Med*. 2013;8[1]:135).
Average volume-assured pressure support (AVAPS, Philips-Respironics) is a newer bilevel PAP modality with a variable inspiratory pressure, which varies between a preset minimum and maximum level to deliver a targeted tidal volume (usually set at 8 mL/kg ideal body weight), using a built-in algorithm. While AVAPS has been shown to provide better ventilation and gas exchange compared with standard bilevel PAP therapy, no other clear advantage to patients has been demonstrated (Murphy et al. *Thorax*. 2012;67:727). Further studies are needed to identify predictors, which could identify patients with OHS who can be adequately treated with CPAP, as opposed to those who benefit more from bilevel pressure or AVAPS.
**Improved outcomes with positive airway pressure**
PAP therapy improves diurnal gas exchange, daytime sleepiness, and quality of life, as well as sleep quality (Piper et al. *Thorax*. 2008;5:63:395); therapy also leads to a decrease in health-care utilization and hospitalization rates (Berg et al. *Chest*. 2001;120[2]:377) and improves survival, with 1-, 2-, and 5-year survival rates of 97.5%, 93%, and 77.3%, respectively (Priou et al. *Chest*. 2010;138[1]:84). A recent prospective study examined the role of protocolized bilevel PAP therapy in patients with acute hypercapnic respiratory failure caused by OHS (Carrillo et al. *Am J Respir Crit Care Med*. 2012;186[12]:1279); compared with those with COPD, patients with OHS had a lower rate of late PAP failure (13% vs 7%, $P = .037$), hospital mortality (18% vs 6%, $P < .001$), and higher 1-year survival (odds ratio = 1.83, $P = .002$). Despite the proven benefit, only 55% of the patients with OHS were discharged with PAP therapy, once again demonstrating the importance of appropriate treatment and follow-up in these patients.
**Conclusion**
Despite signs of increasing prevalence, OHS remains an underrecognized and undertreated condition. Though there are recent data confirming the advantages of treatment with PAP therapy in affected patients, the percentage receiving therapy remains alarmingly low; whether this is due to a lack of recognition or a lack of awareness of the benefits of therapy is unclear. As sleep specialists, we need to be more aggressive at diagnosing and treating this condition, leading to better outcomes for our sickest patients.
Dr. Andreae Antonescu-Turcu, FCCP
Associate Professor,
Pulmonary-Critical Care, Sleep Medicine
Medical College of Wisconsin
Interim Chief of Medicine, Zablocki VA Medical Center, Milwaukee, WI
This advertisement is not available for the digital edition.
|
3-1-1946
UA12/2/1 College Heights Herald, Vol. 22, No. 9
WKU Student Affairs
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WKU Student Affairs, "UA12/2/1 College Heights Herald, Vol. 22, No. 9" (1946). WKU Archives Records. Paper 4537.
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ROTC Announces Opportunities For Veterans
The Department of Military Science and Tactics under Colonel R. H. Agnew is offering returned veterans an opportunity to receive Second Lieutenants commissions in the Officers' Reserve Corps.
In order that there be no reluctance or hesitancy on the part of the returned veterans to enroll for ROTC work, Requirements and benefits are hereby outlined.
I — Pre-Requisite:
1. Age — 19 to 27 years at time of admission to course (must not have passed 27th birthday).
2. Physical Standards — The same as required for appointment in Officers' Reserve Corps (Correctible physical defects will be given due allowance).
3. Mental And Educational Standards —
a. Minimum Army General Classification Test score of 110 required (Army General Classification Test will be given by the Military Department).
b. College enrollment to constitute satisfaction of educational requirements.
c. At least two years study must remain before satisfaction of requirements for graduation or if a graduate student must require a like period to complete all work for an advanced degree. (Completion of the Advanced Course will require two school years plus one summer camp of about six weeks duration).
4. Credit For Active Service If Honorably Discharged —
a. For not less than six months active service in the Army, Navy, Marine Corps or Coast Guard, credit in lieu of the first year basic course.
b. For not less than one year of such active service credit in lieu of the entire basic course.
5. Must not now be holding a commission in the AUS, Regular Army or Organized Reserves (those who are enlisted men in the organized reserves are eligible.)
II — Benefits Received By Accepted Students —
1. A monetary allowance in lieu of subsistence, equivalent to
(Continued on Page 8)
Pre-Revolution Relic Is Prize Of Kentucky Collection
By Jeanne Payne
One of the most valuable relics found in the Kentucky Library was almost destroyed as so much waste a few years ago. This is a letter of pre-Revolutionary days, written by one George Mercer from London to his brother James in the colonies. Written on old-fashioned rag-paper, and in stately manuscript, the letter, dated March 11, 1764, gives an insight into the problems of the colonists and of life in England, as interpreted by a Virginian, however, its main interest lies in the sidelight given on the character of George Washington.
According to Mrs. Mary Moore, Kentucky librarian, the letter was obtained from Bethel College, Russellville, in the early 1930's, when material for the library first began to be collected. When old Bethel College ceased to function, Mrs. Moore and assistants found many valuable volumes in an abandoned attic there. On departing she noticed a mass of bandoned trash, and glancing hurriedly through it, found a soot-blackened letter book, in which letters were kept before the modern filing system was inaugurated. Thus the George Mercer letter was saved from destruction.
Mercer, not so widely known as his famed contemporary, General Washington, was nevertheless, quite a personage in his day. London agent of the Ohio Company of Virginia, which had large business and landed interests in Virginia and Ireland, he represented Frederick County in the Virginia House of Burgesses, 1761-63, along with Washington. He was "side-decamp" to Washington during the French and Indian War.
Mercer, whose dignity of style shows his good education, dislikes London, dubbing its merchants as "the most conceited, impertinent fellows I ever saw." Of the climate there, he says, "On my honor the sun has not shone two days together since I have been in England." He laments the mistreatment of American boys sent to England for education. Mercer would be rather excess baggage to the female species, in this age of manpower shortage, for of matrimony he says vehemently, "I have conceived a greater aversion, if possible, than ever to matrimony since I came to England."
The letter's highlight in interest comes in Mercer's remarks concerning Washington. Apparently, the General had borrowed from Mercer a valuable surveyor's chain, and failed, over a long period, to return it. Mercer says: "You may tell Colonel Washington that the very same excuse which he made you—that he believed he could find the things and would return them—has been given me at every settlement that I have made with him for eight years past. I have dunned him three or four times since for the money . . . Thank God I have done with him, and if he will pay off the account, I am sure I never desire to deal with him for sixpence again."
Readers should peruse Mercer's remarks about "the father of our Country" with several grains of salt, not allowing them to dimish his timeless fame. However, everyone should read George Mercer's account of the trials of pre-Revolutionary days, and he will find there the keynote to the indomitable quality of a typical American today.
MEMORIAL HONORS PROF. MCMURTRY
A memorial program honoring the late Professor Horace McMurtry was held during the chapel exercises in Van Meter Auditorium, on Tuesday morning February 19, at 10 a.m.
Memorial talks were given by Dr. Lee F. Jones, head of the department of education, and Dr. N. O. Taft, head of the department of economics or sociology.
The Rev. Charles E. Hawkins, pastor of the State Street Methodist church, gave the devotional and benediction. Mr. McMurtry was a member of the State Street church.
A mixed chorus from the music department, under the direction of Mr. Claude Rose sang "Cherubin Song," Bortnionasky, and "Jesu, Priceless Treasure," Bach.
At the time of his death January 30, Mr. McMurtry was associate professor of education.
Noted Pianist To Be Heard In Chapel Program
Katherine Johnson, one of the leading pianists of the Northwest and a native South Dakota, will give a concert at Western assembly on Tuesday, March 5, in Van Meter auditorium.
Donald Dame To Highlight Community Concert Series
Donald Dame, famed Metropolitan Opera tenor, will be presented at Van Meter auditorium, Wednesday evening, March 6, in the third of a series of Community Concerts presented in Bowling Green this year.
The noted tenor received double tribute from New York's music critics in a single season—in his debut with the Metropolitan Opera Association, December 3, 1943, and for his Town Hall recital, April 24, 1944. Since beginning his career, he has sung with the New Opera Company in New York, the Cleveland Opera, Detroit, Chautauqua and Trenton Operas. He has been soloist with the Indianapolis, Cleveland, and Chautauqua Symphony Orchestras.
His broadcast schedule last season included: Chorale, "Jesus, Joy of Man's Desiring," (Bach, arranged by Myra Hess); "Mazurka, Op. 17, No. 4" (Chopin); "Etude, Op. 25, No. 12" (Chopin); Les Collines d'Anacapri," (Debussy); "La Cathedrale Engloutie" (Debussy); "Recit du Pecheur" and "Danse Rituelle du Feu (Defalla); Ballet "El Amor Brujo."
Vets Lobby For Subsistence Bill
A committee of veterans from nine of the colleges in Kentucky met in Frankfort on February 14 to discuss the state veterans subsistence bill.
The committee met at the Franklin County courthouse at 11 a.m. and elected James Brock of the University of Kentucky as temporary chairman. The subsistence bill was discussed and plans were made for members of the committee to contact members of the legislature. It was decided that another meeting would be held in Louisville at the Jefferson Post of the American Legion on Saturday, February 23, to plan further action pertaining to the bill and to set up the structure for a state-wide college veterans association.
The members of the committee representing Western were Edward Ellis, Field McChesney, W. J. Cannon, and William B. Barnes. Ellis went to Frankfort on Tuesday, the other three representatives on Thursday.
The schools represented were Western, University of Kentucky, Murray, Eastern, Morehead, Georgetown, Bowling Green Business University, Kentucky State Industrial College, and University of Louisville.
Katherine Johnson
Since completing her early musical education at Northern State Teachers College at Aberdeen she has continued her studies with Egon Petri and Countess Helena Morzstyn. Three times winner of the district contest for young artists sponsored by the National Federation of Music Clubs, she represented the states of Minnesota, Nebraska, North and South Dakota in national contests at Baltimore, Los Angeles, and New York City.
Mrs. Johnson has played extensively in the Dakotas. Recently she appeared in concerts in Minneapolis and Duluth, Minnesota, and at the school for executives of the American Association of Teachers Colleges. Jackson's Mill, Virginia, Hywel C. Rowland of the University of North Dakota, Grand Forks, said of her, "She can be lyrical, dramatic and poetic... An artist beyond doubt."
39 TRAILER UNITS EXPECTED IN SPRING
In addition to the 33 prefabricated housing units already set up on the campus, 39 trailer units have been assigned to Western. 30 of the units are single and will house one family each. In the center of the group will be erected a laundry house and a bath house. The other nine units will be double, with separate bathroom facilities and will house two families each, according to Mrs. L. T. Smith of the industrial arts department.
The units are scheduled for arrival in late spring. The singles will be shipped from Oak Ridge, Tennessee, and the doubles will come from Willow Run, Michigan.
Furniture was installed in the prefab houses on February 25. Eight of the units are scheduled for occupation this week.
FHA OFFICIAL MEETS WITH PRES. GARRETT
D. D. Meredith, construction engineer and architect of the Federal Housing Administration in Cleveland, was in Bowling Green, Monday, February 18, conferring with President Paul L. Garrett, L. T. Smith, head of the industrial arts department, and other college officials in connection with the 30 additional housing units which have been allotted to Western.
The new units will be located in the same general area of the 33 prefabricated houses already set up on Seventeenth street, between Normal boulevard and the Russellville road.
The new units, which will be in the form of Standard trailers, along with houses already received and the nine double trailers to be received from Willow Run, Michigan, will furnish housing for 81 veterans and their families.
WESTERNERS GIVE ROTARY PROGRAM
Western presented the program at the weekly meeting of the Rotary club at the Helm hotel, Wednesday, February 20. A trio from the music department and Coaches Diddle and Hornback, with the basketball team, were introduced by President Paul L. Garrett.
Coach Diddle presented the team and made a short talk. William Alexander, of the music department, introduced Leroy Fritz, Marjorie Stinnett, and Betty Seaver. The trio, composed of violin, 'cello, and piano, presented several selections.
The staff of the College Heights Herald extends its sympathy to Ruth Britton on the death of her father, John W. Britton, on February 21.
Navy Commends Dr. Johnson
Dr. Lillian M. Johnson, a lieutenant in the U. S. Naval Reserve, has been highly commended for her service to the Navy during World War II, according to a letter from Commander J. B. Dow of the Navy Department Bureau of Ships, recently received by President Paul L. Garrett.
"As an officer in the United States Naval Reserve, Miss Johnson served in the Electronics Division from December, 1942 to November, 1945 in administrative and personnel duties. She was responsible for the procurement of qualified officers for the development of electronics equipment. She planned and determined the requirements of personnel necessary for the post-war electronics organization. Her skill, devotion to duty, and effort constituted a valuable contribution to carrying on the work of the division under the trying circumstances of war time."
Dr. Johnson is on leave of absence from the faculty of the department of psychology of Western. She received the AB degree from Western in 1929, the MS from the University of Chicago in 1932, and the Ph.D. from the same institution in 1938. Dr. Johnson has been a member of the Western faculty since 1932.
Nelson Shares Commendation
Edward B. Nelson, now on leave from the physics department teaching staff, has been included among those commended by the War Department for their part in the development of the atomic energy project. President Paul L. Garrett recently received a letter from Dr. Frank D. Packenthall, acting president of Columbia university, New York City, which told of the presentation of the commendatory scrolls to Columbia and the two other universities serving as centers of research and development for the project. In a presentation speech, Major General Leslie R. Groves acknowledge the contributions of other institutions in lending their men to the work.
Nelson worked at Columbia under the Manhattan project. He has been a member of the Western staff since 1943.
30 copies of the Talkman are still for sale. Orders will be filled in May and should be sent now to Elizabeth Hale or Helen Henry, Business Managers.
College Heights Herald
The College Heights Herald is the official newspaper of the Western Kentucky State Teachers College. It is published every other Friday under the general management of Sterett Cuthbertson and the staff is composed of students of the journalism classes taught by Miss Frances Richards.
Member of Associated Collegiate Press
Represented for National Advertising by National Advertising Service, Inc.
College Publishers Representative
420 Madison Ave. New York, N.Y.
Chicago Boston Los Angeles San Francisco
Marjorie Rickman Editor-in-Chief
Helen Henry Business Manager
Editorial Board
Mary Choncoff, Field McChesney, Rae Shepherd, And Carroll Franklin
Feature Editor Jo Ann Lawton
Society Editor Jo Fish
Sports Editor Edward Ellis
Typist Jeannie Haddix
Reportorial Staff
Thomas Boone, Evelyne Banks, Jeanne ayne, Betty Jo Cook, Berkley Barnes, Anna Jo Cook, Betty Jo Lloyd, Raymond Reeder, Vernon Shuffett, Mary Sue McNally and Jo Cottrell.
Marianne Melton Circulation Manager
Entered at the Postoffice as Second Class Mail Matter.
Bowling Green, Kentucky, Friday, March 1, 1946
TO ALL WESTERN STUDENTS
There is always in youth a spirit of rebellion and no amount of pressure, in a democracy at least, can quell it. The conflict between youth and age is recognized by sociologists, parents and educators. Resentment against rules and immutable laws that even the very rash would have to admit are essential is prevalent during youth and in later years even the most horrible monument to our resentment will be gradually reduced in magnitude.
However, to complainers here we make this blanket statement: This is your school and no one will attempt to discount that fact in the final analysis. The things you would like to see done, the needed changes—and again no one, not even the most insipid will declare that any one thing is perfect—will be made only if you are sincere, steadfast in your convictions, and informed enough to know the workability of your ideas.
Interest plays a part here also—if you have a pattern for reformation. In the classrooms, the laboratories, and most of the school functions you are voiceless to a degree. The people who manage those activities know far more than you, or situations would be forced to reverse. But there are certain phases of the college that you should and could have a definite part in. Delve into those things and take from this institution more than mere textbook quotations and theories.
This is not a reactionary editorial. Nothing worthwhile was ever purposely obtained through hurried or impetuous action. Neither will lethargy, disinterest or inane quibbling bring much other than frustration, confusion, and further realization of ineffectiveness. Instead we should evidence our interest and right to participation by keeping ourselves informed through the various channels of the school, by showing our eagerness to help through attending all school functions in which we can show our powers of leadership, initiative, and sense of responsibility. And, after all, why are we here?
WORLD STUDENT SERVICE FUND
Hundreds of thousands of guiltless students have suffered grievously in body, mind, and spirit in long years of total war in ravaged Europe and Asia—as fighters, prisoners of war, victims in concentration camps, or in compulsory labor battalions, as refugees, as displaced persons, as stateless persons, as resisters in underground movements, and as migratory students in bombed-out evacuated universities. These fellow students need help in physical and mental rehabilitation for the resumption of their interrupted studies in the restored, reopened, and emancipated universities and for the intellectual and moral solidarity essential to a rational and humane society.
The Far Eastern Student Service Fund was established in the United States in 1937, by the National Intercollegiate Christian Council. Its activities were extended to Europe in 1939 with the outbreak of war. In the meantime, the University Commission of the Council of Church Boards of Education (student denominational groups) had become co-sponsor of the organization which took its present name in 1940.
In addition to the original sponsors, the present sponsors are the Student Volunteer Movement which combines with the groups mentioned above to form the United Student Christian Council. There are also several cooperating organizations, created for the period of the war and the critical post-war rehabilitation and reconstruction period.
Its officers are distinguished American educators, of whom President Edmund E. Day of Cornell university is president. Chairman of the General Committee is Sidney Lovett, Chaplain of Yale university. The governing body of the W. S. S. F. is the General Committee, composed of representatives appointed by its sponsoring and cooperating organizations. The W. S. S. F. is a registered agency with the President's Control Board Number 564 and is a member of the American Council of Voluntary Agencies for Foreign Service. It is one of the international organizations having its headquarters, on invitation, in the new Willkie Memorial Building in New York City.
In addition to the officers and executive staff of the W. S. S. F., the executives of the sponsoring organizations, nationally, regionally, and in the colleges and universities, participate actively in responsible leadership.
The W. S. S. F. is the opportunity and responsibility of all American students and professors to engage in the uniquely world-wide student task of rehabilitation and reconstruction on the basis of human need and without any reference whatsoever, at home or abroad, to race, nationality, religion, or politics.
World-wide student needs are conservatively estimated at $2,000,000, and that amount is set for 1945-46. It is expected that one-half of this fund will be met by students and professors in the United States. The goal, however, is being totaled from quota commitments being assumed by individual colleges and universities. It is with such an organization as this that Western is asked to cooperate in the coming drive. The quota set by the group working on this campus will be made public following the weeks' drive set for sometime next quarter. This is a test of Western students—our foresight, our sympathy, our willingness to cooperate.
IN THESE TIMES
In these stirring times, when any seemingly insignificant event may be of world importance, Western students would benefit greatly if given the opportunity of hearing nationally known men lecture.
We believe that the school could, by charging the students a nominal fee, secure several well known speakers. These speeches could be presented at chapel or in the evenings and, with a more mature student body on the campus than at any previous time, would probably hit a new high in student interest.
There are from time to time good visiting speakers in our auditorium and certainly we can recruit many from our own institution, but, the calibre of those who do the lecturing to us must not be commensurate with the level of our institution.
The opportunity to listen to great men speak has always been a part of learning. Current interest is running at high speed along lines of nationally and internationally important topics. An informed student body is the prelude to an understanding and intelligent citizenry with a working knowledge with which to meet the problems that confront an adult world.
SHOULD THIS END HERE?
Taking advantage of this increased interest in things academic we'd like to revive an old subject—favorite of former Herald editors—the case of the scholastic honorary.
It has long been the contention of the more thinking people, connected with our institutions of learning, that so-called extra curricular activities are crowding scholarship out of its rightful place of honor in the collegiate picture. Bigger and more glamorous opportunities are offered the students in other phases of campus life with the result that book learnin' is allowed to go by the boards in favor of body blocks, free throws, rug-cutting and similar manifestations of things non-scholastic. Indeed, it has gotten to the state where knowledge gained has been almost entirely subordinated to activities engaged in and a student is judged more by his position on the glee club or tract team than by what he has picked up in algebra 102 or analytics 241.
Establishment of some kind of an honor society for those students whose scholastic attainment has reached a certain level is seen here as a means of supplying impetus in the other direction and should help to turn the efforts and midnight oil of all of us into more constructive channels. Of course, the idea of scholarship for recognition alone is absurd but there is no reason why it should not be made as attractive as possible and why the scholar's deeds should remain unsung or drowned out by the acclaim given other campus heroes.
Just what type of organization we would create will have to be decided upon by the students and faculty. Just what the requirements would be to be included on its rolls is something else to be settled. Also whether it would be made up of juniors and seniors or of all classes is another point in question.
Perhaps there are other items about which there will have to be decisions made before the final structure of our proposed organization is completed. Whatever their solution is there should be such an organization started so that scholarship may assume its rightful place of honor and prestige on the campus.
Let the Herald editorial staff know what you think of the idea.
F. M.
YOUTH ANSWERS THE CALL
In the Nineteenth Century, Alfred, Lord Tennyson published the poem, "Locksley Hall" in which he typified youth as feeling despair in the present and hope for the future. Perhaps this is as it should be, perhaps youth has felt this personal despair since the beginning of time. But the time has come when youth is finding it difficult to feel very optimistic toward what the future may hold. This is a very dangerous frame of mind and a more dangerous state of affairs. It is not cynicism, it is hopelessness, and it is not a lack of ambition, it is despair. Despair bred and born of failure, yes, but not personal failure, rather failure of those who have gone before. And not one failure, but many.
To try to place the blame is unjust and such a procedure offers no solution. But to ignore the situation is stupid. To say to our youth of today "let your heart receive messages of beauty, cheer, courage and grandeur" sounds very nice. But there is no beauty on a battlefield, no cheer in false hope, no courage when you are going down for the third time, and no grandeur in graft. It is ridiculous to say to a man who is starving for bread, "Pay no attention to the gnawing in your stomach and you won't be hungry." And it is equally ridiculous to say to the man whose soul is starving, "Pay no attention to failures in the future and you won't be discouraged."
Every day youth hears the expression, "You are the leaders of tomorrow." A true enough expression but in order to be qualified leaders youth must be trained, must be taught to feel responsible for mistakes, and must be taught the value of selfless motives. Only in this way can he hope to do away with graft, ignorance, stupidity and worst of all, selfishness in the future.
R. S.
DEFINITELY LOST?
The crusading Herald of 1941 under the editorship of Bert Borrone carried in the issue that came off the press April 11, a column entitled A FEW LOST CAUSES THAT STUDENTS COULD DO SOMETHING ABOUT, causes which they hoped would see materialization the year following their campaign. The next year the world was at war and college enrollment dropped off, taking with it the necessary numbers for a successful follow-through of their ideas. Now that things are seeking to get back on an even keel, we believe that those ideas advanced by the editorial staff of 1941 need reviving. For that reason we are reprinting them, begging for comments from the student body. We state them merely as topics; most of them still need promoting.
A joint-club banquet (an effort to join the clubs in order to have a "name" speaker), the tennis court situation (trouble with court-hoggers which will bother us come spring), a play exchange, a debating team, an attempt to obliterate the lackadaisical class election attitude (ever present), a new streamlined plan for collecting class dues, virile action to establish some sort of scholastic honorary (approached elsewhere on this page), the pep club dream (a plan which died in infancy with the 1945-46 staff), the attempt to inaugurate a page of opinion in the Herald, the ten- (now 15!) year-old battle to make the Herald a weekly.
It is interesting and most disheartening to observe that the 1941 editorial group, composed of a much larger staff than our present one, gained little headway—not one of their projects getting recognition or appreciable results during their seasonal effort. We put it up to the student body. We invite written expressions of opinion—show your interest in the progressive welfare of Western—if enough interest is shown—results will be forthcoming.
QUOTATIONS:
Peace is the happy, natural state of man; war, his corruption, his disgrace.—James Thompson.
Business is never so healthy as when, like a chicken, it must do a certain amount of scratching for what it gets.—Henry Ford.
We may be personally defeated, but our principles never.—William Garrison.
It is ridiculous for any man to criticize the works of another if he has not distinguished himself by his own performances.—Addison.
The strength of criticism lies only in the weakness of the thing criticised.—Longfellow.
Kentucky Building News
Two interesting programs have recently been broadcast from the Kentucky Building on its weekly radio program on February 15. Miss Maggie Helm, college librarian, discussed the Sally George Blakey collection of antique glass. This collection of antique glass was donated to the Kentucky Museum by Churchill Blakey, nephew of the late Miss George Blakey of Hopkinsville.
On February 22, Mrs. Mary T. Moore, Kentucky librarian, read extracts from eight letters written by a freed slave to his former mistress, Mrs. Charlotte Stephens Bell of Ohio county. The former slave, known only by her letters as Rachel, was one of several hundred slaves sent to the Clay-Ashland colony in Africa, which was sponsored under the auspices of a Colonization society.
Rachel and her husband, Sandy, were extremely dissatisfied with their new home where they suffered untold hardships. All of their family were sick and four out of their seven children eventually died from malnutrition and disease. Rachel's husband finally left her and was never heard from again.
This collection of letters vividly portrays the hardships endured by Negroes who tried to better themselves by going back to Africa.
Students of Western and citizens of Bowling Green and surrounding areas owe a deep debt of gratitude to radio station WLBJ for making possible the weekly broadcasts from the Kentucky Building. The broadcasts are made by remote control from the Kentucky Building every Friday afternoon at 4:15. These Kentucky Building programs are a public service feature of station WLBJ and are given without charge to the school.
* * *
From October 1, 1945 until February 3, 1946, 1,139 people were shown through the Kentucky Museum. There were visitors from 34 states, the District of Columbia, Canada, South America and China. During this same period 1,344 books were checked out of the Kentucky Library.
The Kentucky Library has recently received a four volume history of Kentucky by Frank Tapp and Fredrick Wallas. The first portion of this set of books deals with the history of Kentucky and the latter part consists of cumulative biographies of prominent Kentuckians.
The history was written by Mr. Tapp and Mr. Wallas supervised the collection of the biographies.
* * *
Lt. Jean Beath, United States Navy, recently sent the Kentucky Library a collection of four papers published in Manila the day that the Japanese envoy arrived to discuss peace with MacArthur. All four of these daily papers were printed in tabloid form with much news and very few advertisements.
A George Washington party was held by the eighth grade of the Training School on Monday night, February 18 in the gymnasium. The decorations were in keeping with the traditions of the birthday of George Washington. About twenty-two enjoyed games and dancing from 7:30 to 10:00. Misses Mary Francis Eaton and Fannie Holland were chaperons.
June Corman visited her parents in Louisville the week end of February 22-24.
College High Student Awarded Medal By DAR
Mary Sue McNally, college high senior, was one of three Warren county students winners of Good Citizenship awards presented recently by the Samuel Davies chapter of Daughters of the American Revolution. The awards are made annually by the D. A. R. Nominees were selected by the senior classes and winners were selected by each faculty on the basis of dependability, leadership, service, and patriotism. Good citizenship pins were awarded the trio.
Speech Students Present Recital
Speech students, under the direction of Miss Jane Rae, of the English department, presented a recital in the Little theater, February 27, at 4:30 p.m. The public participating were Jennie Foster, Jeanne Baskett, Maxine DuBarry, Carolyn Kimbler, and William Pudlo.
According to Miss Rae, these recitals, representing work of the speech classes will be presented frequently.
Westerner To Represent Kentucky In Contest
Miss Frances Hildreth, a student on the Hill, has been chosen to represent Kentucky in a beauty contest conducted by the "Torch", Beta Sigma Phi sorority magazine, and to be judged by Actress Rita Hayworth.
Frances, a daughter of Mr. and Mrs. L. H. Hildreth, Smiths Grove, was chosen one of 48 winners from among 600 entries. She is a junior at Western and is majoring in music.
Former Student Named Regular Powers Model
Martha Jane Fleenor, former Western student, has completed the course at the John Robert Powers Finishing School in New York and was one of two girls selected as regular Powers models.
Miss Fleenor attended Western and the Business university and later was employed at Tyndall Field, Florida. She went to New York to study radio work but the class was filled and she entered the finishing school. While in New York, Miss Fleenor is living at the Savoy Plaza hotel.
YWA's Sing At Hospital
Twelve members of the College YWA entertained the patients at the tuberculosis sanitorium near Richardsville last Sunday afternoon. The girls sang a number of songs.
Members of the group were Doris Darter, Geneva Lafferty, Jennie Foster, Ruth Wilson, Inez Haley, Elizabeth Standford, Marjorie Davidson, Marguerite Huffaker, Lena Huffaker, Ranny Hensley, Noye Line, and Martha Gregory.
Thumb-Nail Sketches
By "Shotgun"
Jennie Haddix
Type, type, upye! Fingers flying, Jennie bangs away continually, running out copy for the Herald and the education department. To keep her hair from flying away while she's pounding the machine, she ties it in pigtails and foes bobbing along her merry way.
An English major, Jennie is a junior. She transferred to the Hill from Eastern this year. She hails from Richmond and is a resident of Potter Hall, at least as of last Saturday. A rather short gal, Jennie has brown hair, blue eyes, and the friendliest grin around. Rather undecided about a career, she's changed her major three times, but seems to have settled herself at last in the English channel.
Walter Morris
Sir Walter comes from Dawson Springs, and his antics on the Hill during the past couple of years have become famous in the annals of campus capers. A party guy through and through, Walt has managed to be in on all the social activities since hitting town in January '44. Just ask George about the little incident of diving out the second floor window.
A junior pre-med student, Walt is now in the throes of comparatives. He takes his lab work seriously, often deciding to do a little homework on the shark, frog or necturus, much to the olfactory despair of his fellow tenants and the indignation of lab partners, since he is just a wee bit forgetful at times.
Soon to depart for the fields of medical learning, the Western career of this tall, lanky fellow will not be soon forgotten.
Louise Markham
Another delver into the lore of biological learning, Louise is completing requirements for entrance to a medical school this year. She too is exploring the comparative studies of the shark, necturus and turtle, and like all true friends, she has affectionately named the formaldehydeous specimens. The shark being of the masculine gender, she called his "Dexter", and since the necturus was decidedly on the distaff side she christened her "Chloe."
This tall, blonde emporio hen medic hails from Logan county, near Russellville. A roommate of that well-known campus character, Minnie Skaggs, Markham has had several little altercation with her over the disputed presence of such little biological souvenirs as shark tails, eye lenses, and necturus eggs.
Louise, a senior, will receive the BS degree in chemistry-biology in June.
Walton Plummer
Another Ohio county river rat is Plummer, who hails from the great city of Beaver Dam. A quiet, calm-looking guy, his exploits have startled the most blaz characters on the Hill. He's not so big, but his curly hair and slow drawl are enough to intrigue the swoon-goons. Living with some of the gayest dogs around, he has acquired the nonchalance and polish essential to the man about the campus.
Plummer has a serious side too, and he is preparing to study dentistry when he finishes the prep course at Western. His experiences with th cat familiar to all mammalian anatomists are as usual, they make the blood run cold.
A loyal Hilltopper, Plummer follows his team all over the state, and he and the other Wallace Wolves have plenty of gruesome yarns to spin when they hit B. G. after a trip to some wide-open Kentucky metropolis.
Dr. Robert T. Daniel, professor of testament theology and interpretation at the Southwestern Baptist Theological Seminary, Fort Worth, Texas, will speak during chapel exercises, Tuesday, March 12.
A native of Georgia, Dr. Daniel received the AB degree from Mercer University, Macon, Georgia; the MA degree from Texas Christian University; the Th.M. and Th.D. degrees from the Southwestern seminary. In addition he has done special graduate work at the University of North Carolina and at Northwestern University.
WESTERNER OF THE WEEK
CLYDE POOL
A senior industrial arts major from Crofton, Pool will receive the BS degree in August. He is sergeant-at-arms of the class of '46, and has served as officer in the Arts and Crafts Club. His minor is physics.
Portrait By Franklin
FRANKLIN'S STUDIO
830½ State Street
Phone 212
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Miss Margaret's Specialty Home-Baked Pies In Your All-Time Flavor Favorites Tender, Flaky Crusts Delicious Fillings
THE WESTERN LUNCH ROOM At The Foot of The Hill
DRINK Coca-Cola
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Book Marks
You atomic age students will be happy to learn how complete the college library is. One of Western's veterans said that he searched in vain through every camp library and city library he visited for a certain book on radio. A few weeks ago he returned to the Hill and found that book in Western's library.
If you want books as new as atomic bombs, read about atoms. Here are three new books on that subject: Atomic Energy, Smyth; Atom Smashers, Yates; and Atomic Energy In the Coming Era, David Dietz.
Other books so new they make news are Plastics, Fleck; The Navy's War, Pratt; The Long Ships Passing, Havighurst's story of the Great Lakes; The War Poets, an anthology of 20th century war poetry edited by Oscar Williams; and History of the Second World War, arranged in campaigns by Commager.
Two new books concerning peace are The Killing of the Peace, Cranston's diary from history of the birth and death of the League of Nations as far as the United States was concerned; and Durable Peace, Hoffman's study of the American National Policy.
First Lieut. Dallas Arnold, USMC, returned to the states recently from China. Saturday he reported to the separation center at Great Lakes. Formerly with the First Marine Division, the former Western grid star plans to return to Western this March. He is married to Marion Pettus, Western graduate.
Second Lieut. John Milton has been transferred from Midland, Texas, to Dayton, Ohio. He was home recently on leave. He's in the Air Corps.
Visiting on the Hill in civilian clothes this week has been George Updegraff, former major in the Army. He was the commanding officer of the 321st Cadet Training Detachment at Western, and was sent from Western to Alaska. He has been discharged since December 13 and visited in Bowling Green while en route from California to New York.
Another of the 321st C. T. D. permanent party to visit here has been Capt. Alfred Collins, who was here last week end. He is now on terminal leave and plans to matriculate soon at Georgetown University.
James Stickles, son of Dr. A. M. Stickles, head of the history department at Western, is discharged and now at home. The former infantryman who returned from Europe last summer plans to enroll at Western next quarter.
Capt. Mark Sisk visited on the Hill this week. He returned from Europe about a month ago. After his coming separation from the Army he plans to go into the newspaper business in his hometown, Dawson Springs.
Lieut. Col. Frank Whaley of Long Island, New York, visited friends on the Hill recently.
Ed Neel, Western student whose terminal leave expired January 29, was promoted to the rank of captain just before that time.
James M. Logan, who served in the Navy Medical Corps attached to the Marines, is back at Western after having served in Hawaii, New Caledonia, New Georgia, Guadalcanal, Saipan, Tinian, and Japan.
Crawford Jenk, former Westerner who was wounded at Guadalcanal, has been discharged and is living at Madisonville.
Charles "Carlos" Hayes is expected to arrive in Bowling Green sometime today. He completed boot camp at Great Lakes Naval Training station on Tuesday.
Lieut. (sg) Harold Hughes is expected to arrive soon from Astoria, Oregon. He was recently promoted and has been placed on terminal leave. The officer, who was head of the public relations department of the Navy in the Oregon city, received the B. S. degree from Western in 1940. He is the son-in-law of Dr. Gordon Wilson.
Wallace "Sonny" Barr was discharged from the Army last Tuesday. He and his wife are now visiting Mrs. Barr's parents in Orangeburg, South Carolina and will soon return to Bowling Green.
Jake A. Evans, AB '39, formerly of Bowling Green has entered the radar school of the National Broadcasting Company at Columbia university, New York City. He is teaching piano and instrumental music at the New York School of Music. Evans is the son of Mrs. Margaret Evans, formerly superintendent of buildings at Western.
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Col. Agnew Announces Marksmanship Scores
Col R. A. Agnew, PMS&T, has announced the rifle marksmanship scores of the first year basic course. The firing was held on the R.O.T.C. rifle range in the physical education building, February 5.
Qualifying for expert were John D. Copeland and Sam Tuggle; for sharpshooter: Adrian du Barry, Paul Tillman, James Corbett, Maurice Hale, W. G. Woosley, Jack R. Day; for marksman: Murrill Woosley and William M. Walker.
Frances Mills, freshman, was the guest of her parents in Clinton recently.
Mercer-Goode
Mr. and Mrs. Claude Mercer Fisher, announce the marriage of their daughter, Claudia, to Petty Officer Johnny Goode, son of Mr. and Mrs. John Goode, Leitchfield. The wedding took place on January 23 in Hardinsburg.
The bride is a former Westerner, attending school as a freshman last year.
Harrison-Harvey
Mr. and Mrs. C. A. Harrison of the Nashville road, have announced the marriage of their daughter, Mary Lois Harrison, to Edwin Harvey, son of B. D. Harvey, of Summer Shade, which took place on Sunday, February 17, at the Broadway Methodist church parsonage, with the Rev. R. B. Prentis performing the double ceremony. Sylvia Proctor and Lowell Harrison were the attendants.
Mrs. Harvey is a graduate of College High school and is a senior at Western. Mr. Harvey was graduated from Lindsey Wilson Junior college before entering the Army Air Forces. He returned from duty in the Pacific in January and has received his discharge. He will resume his education at Western.
Kessler-Taylor
Mr. and Mrs Owen Kessler, Lebanon, announce the marriage of their daughter, Cattie Elizabeth, to Ernest Coleman Taylor, of Kenton, Tennessee, on December 22 in Bowling Green.
Mrs. Taylor graduated from Western in 1943 with AB degree in English. Since that time she has been employed as librarian at Campbellsville college.
Berry-Paddock
Mr. and Mrs. W R Berry, of Morganfield, announce the marriage of their daughter, Lutha Margaret, to Lynn Allen Paddock, son of Mr. and Mrs. R. G. Paddock, of Ponder, Texas. The wedding took place Sunday, January 20 at the the Baptist church, the Reverend George H Riggs officiating.
Mrs. Paddock is a graduate of Morganfield High school and Western, AB 44. For six years she taught in the schools of Sturgis and Morganfield and has recently been employed in the Post Finance Office of Camp Carson, Colorado.
McPherson-Hartley
Announcement has been made of the marriage of Dorothy McPherson, Greenville, and Robert A Hartley, of California, which took place Sunday, January 20 at the Episcopal church, New Albany, Indiana.
Mrs. Hartley attended Western 1943-45 where she was majoring in biology. She received the BA degree from Norton's Infirmary in Louisville and is now employed as technician there.
Campus Calendar
March 6—Chemistry-Physics Club Kentucky Building
7—English Club Kentucky Building
7—Katherine Johnson, at Chapel
12—Iva Scott Club, Kentucky Building
12—Dr R. T. Daniel, at Chapel
13—Biology Club, Kentucky Building
14—History Club, Kentucky Building
19—Educational Council, Kentucky Building
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Club Notes
Veterans Club
At a special meeting of the Veterans Club on Monday, February 18, a move to organize a state-wide Veterans Association was started.
Marietta Helton Silvers, former Western student, was graduated Saturday from the University of Louisville with the A.B. degree.
Mary Chonoff spent last week end at her home in Gary, Indiana. She was accompanied by Pam Bledsoe, former Western student of Louisville.
Jean French spent last week at her home in Elizabethtown.
Johnnie McCullough had as guests recently Joy McGuffee and LaVone Smith, students at Murray.
Mozelle Stone spent last week end with her parents at Greenville.
Among those Westerners attending the KIAC Tournament in Louisville last week end were Field McChesney, Carroll Franklin, Billy Pride, Jimmy Taylor, Cotton Cromwell, Lynn Waller, Jan Lawton, Jeanette Warren, Jean Ward, Anna Jo Cooke, Betty Jo Cooke, Mayme Johnson, Bob Daugherty, Harold Logsdon, Joan Dienes, Ed Ellis, Wilda Bennett, Ellen Ricketts, Linda Hayes, Charlie Irwin, Buck Atkinson, Bill Thompson, Evelyn Banks, Nancy Drew, Harriet Spalding, Bob Richardson, Mary Sparks, Alma Stevens, Irby Hummer, J. D. Taylor, Bill Seams, and James Blackburn.
Rita Morelle Swindle, Jean Bassett, Brenda Kitchen, Frank Baker, Betty Joyner, Joe Latimer, Cliff Colman, Jean Wayne, Bill Wayne Asher, Mary Barber, Solon Mitchell, Elizabeth Hale, Mat Lynch, W. J. Cannon, Bill Barnes, Marianna McChesney, Nina Waller and John Haynes.
Charlie Ruter and Charlie Labhardt, former Western basketball players, attended the KIAC tournament in Louisville last week end.
Dallas Arnold, former football player for Western, was in Louisville for the KIAC tournament.
Mildred Neatherly, Nancy Rawlings, and Carolyn Kimbler spent last week end in Madisonville as the guests of Hope Wilkie and her family.
Former Westerners on hand to cheer for the Hilltoppers included Tip Downing, Charlie Ruter, Charlie Labhart, Deacon Jones, Red McCrocklin, H. T. Cooper, Max Reed, Dick Latimer, Russ Daugherty, Harry Hardin, Mr. and Mrs. James Shrewsbury and Mr. and Mrs Clemens Rich.
Sara Ann Delauden spent the week end of February 16-17 with her parents in Mayfield.
Gilbert Wooden has returned to school after a four weeks illness.
Jim Taylor were appointed members of the membership committee. The constitutional amendment to have bi-weekly meetings was passed.
History Club
Members of the history club presented a program on the United Nations Organization in chapel yesterday.
Joe Robertson, president of the club, introduced the speakers who discussed the advantages and disadvantages of the UNO. Members of the club on the program were Nola Ree Tinsley, Wilbur Wade, and Lowell Harrison.
Education Council
The Education Council, president Frances Dossett in charge, held its monthly meeting in the Faculty room of the Kentucky building Tuesday night, February 19. The program was conducted as a Dr. I. Q. Quiz, Truth or Consequences, and Take It or Leave It.
Lieut. Col. Roy Kelly left by plane from Washington, D.C. for Germany a week ago. He will serve as an engineer for the Army of occupation. He has been in the states for two months.
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Western Falls From KIAC Throne, Loses To Seacards In First Round
Another KIAC Tournament has come to an end and with it the prizes and surprises that make for grand entertainment. Although Western was defeated in their first game of the tourney, they gave Louisville a taste of what the Seacards might expect from the other contestants for the basketball crown. The Seacards were finalists with Eastern, losing the tilt to the newly-grown Maroons.
In the opening few minutes of the Western-Louisville game, the Hilltoppers took a 6-2 lead that became 9-4 when the first five minutes of playing time had ticked off. At the end of ten minutes, the Cards had tied the count 9-all and at half time, the Diddle men trailed 17-25. However, in the first part of the second half, the Toppers were able to tie the score at 28 points before the Seacards moved out to post the final margin.
Had the Western team been able to hit during any stage of the last half, they might have turned back the U. of L. 'netters.
George Hauptfuhrer, big Louisville center who scored 19 points to pace the scoring of either team, left the game on personal fouls with five minutes left to play. Western's Chalmers Embry also left the game via the same route.
The Hilltoppers showed signs of old time form in the first part of the second period when they knotted the count at 28-all. After five minutes of playing time had elapsed, Hauptfuhrer put the Cards in the lead with a free throw after which the Louisville boys were never headed.
With nine minutes left in the game, the Diddle men trailed 39-37. It was at this stage of the game that Louisville spurred ahead to a 46-36 lead with the time rapidly running out, the final tally showing the Cards on the top side of a 50-43 score. The defeat marked the first time a Western team had gone down to defeat in the first round of the Kentucky tourney.
Diddlemen Lose Second To Eastern
Saturday, February 16, saw at Richmond a contest between two of the nation's top scorers when Chalmers Embry of Western and All-American Fred Lewis of Eastern fought it out for top honors in the scoring. Lewis polled 20 of Eastern's 46 points, but Western's star guard was held to 11 points.
Eastern's victory marked the first time a Rankin-coached team had ever beaten Western on the Eastern hardwood.
Trailing 28-14 at the half time, the Diddle men came back to swish the netting for 10 points on 4 field goals and 2 foul shots in four minutes' and the score was soon tied at 30-30.
The KIAC champs took control again midway in the final half to surge to a 44-35 lead and then Western did it again with only 40 seconds to go to bring the final score to a 46-44 total as the game ended with Eastern in control of the ball.
Morehead Evens Record For '45-'46
The Morehead Eagles, seeking revenge for an earlier defeat, handed Western a trouncing by a close margin of 53-49 Monday, February 18, on their home floor.
The Eagles had to battle all the way to win and at one time Western had a seven point lead. Fighting hard, the Eagles overcame this in record time when Pobst and Miller came back in the second half with a barrage of field goals that gave Morehead the lead with 12 minutes left to play. Hanging on grimly, the big gold staved off a Western victory to win with a 4 point margin. Parsley led all scoring with 20 points, while Morehead's Pobst racked up 15.
W. D. Croft, captain of Western's football team in 1922, was on the campus with his basketball team from Bolton high school near Memphis, Tennessee on February, 19-20. The Bolton team played College High on Tuesday.
DIDDLE ORGANIZES COMMUNITY SPORTS
Hilltopper Coach Ed Diddle has inaugurated an athletic program for the youngsters of Bowling Green who, otherwise, would have no opportunity to work out in the hardwood game. The program makes the Western gym open to those boys between the ages 10 and 16, who are not participating in organized sport. The boys, under the supervision and instruction of College High's Coach, Dero Downing, are allowed to use the floor every Sunday afternoon from 2 o'clock until 4 o'clock.
Goal shooting, dribbling, free-throw pitching, defense and offense are taught in acquainting the boys with the fundamentals of the game. It's a real break for the kids and the eagerness and interest shown by the boys is reward enough for the efforts of Western's Athletic Department.
A Word To The Ladies!
If your husband or boy friend can't find the men's wear that he wants... Be patient with him... It's no fault of his or ours either. However, before long conditions will change and there will be enough men's wear to supply the demand.
Each week we receive small shipments of suits and other men's wear. So tell him when he's down town—Drop in.
Editor's Note: These tributes to the life of a friend and fellow teacher were paid to the late Professor McMurtry by Dr. Lee F. Jones and Dr. N. O. Taff in a memorial chapel in Van Meter Auditorium, Tuesday, February 15.
Some Elements Of Greatness
He did not set forth in glowing terms great philosophies of education. He was not to be the self-announced prophet of a new day in education. He did not through his writings nor through the spoken word become the evangelist of the new day to mold public opinion and to move legislatures to action. But though this type of greatness was not his, he was great in his capacity to make great philosophies his own in his capacity for adopting and adapting procedures and techniques which help to make dreams come true and visions to take on substance and reality.
He accepted and made his own the belief in the improvable of man and held an abiding faith in public education as being the chief agency through which and by means of which this improvement might be accelerated. He accepted and made his own the philosophy that a democracy such as ours could be self-perpetuated only as popular intelligence was developed and as popular virtue was inculcated.
While we may say with truth that Horace McMurtry expounded no new philosophy of life and education, we may say with equal truth that the way of life and the philosophy of education which he made manifest through the years was truly his own because he took it and made it his own—just as you or I are free to make any great cause, any great philosophy or way of life our own. He took the great humanitarian philosophy of Pestalozzi and the Jeffersonian philosophy of education in a democracy and made them truly his own because he made them dynamic in his own life as a teacher.
Not a genius in the formulation of great theories, his greatness lay in being able to translate theory into practical and dynamic action. We need not wait, you and I, in order to achieve fame, until we are able to propound a philosophy of life not yet propounded. Like him, we can take to ourselves great philosophies, better still we can allay ourselves, as did he, to great causes. The cause of rural education needs its champions now more than ever since his passing. His call to us is not for lip service alone, and not alone for faith in rural education, but for works as well. We need to subscribe, now as in other times to the belief that the job of education is to tap the deep-lying sources of the streams of leadership, to bring to light the hidden springs of ability that democracy may be self-perpetuating, and we need to translate into action and reality these nobler dreams of mankind. His greatness in these matters is a challenge to all teachers and would-be teachers, for the opportunity which he seized is ours as well.
He was great as a teacher in his humility. Not his that sure sign of mediocrity, an undue craving for recognition, but rather a self-effacement which led to tardy though sure recognition. He took an honest pride and joy in the fact that in the last few years there came the realization that his contributions to rural education, to this institution, to prospective teachers in his classroom and to actual teachers in the field, were, though largely unheralded, of lasting worth. We who have worked so long by his side can testify to his lasting worth, and administrators and teachers out in the field who looked to him for guidance in taking the needed next steps in his praise during the last few years.
He was great as a teacher because of his knowledge of methodology—because of his ability to use it as a means to an end, with the saving grace of not becoming a slave to methodology as an end in itself. He had sat at the feet of one of the greatest methodologists of all times, and as a teacher of prospective teachers he passed on the McMurtry tradition. In his work with students who had need of skilled teaching he used the skill of a master teacher as the master surgeon uses all the skill of his profession. As a great teacher, Horace McMurtry had missionary zeal to help those in his classes who found the way toward teaching a somewhat difficult one. He could inspire those who had no real need of a teacher to their best efforts, but his greatest service was to those of his students who because of his teaching came to success when without his patient guidance they would have come to failure. Any teacher can bask in the reflected brilliance of his great students—the master teacher has his reward in the satisfaction that comes from the realization that he has had a major part in raising the level of his students who are upon the lower levels. A large part of his success with such students may be attributed to his capacity for work, the indispensable catalytic agent of the various in redirects of success in any endeavor.
His contributions as a teacher through his classes on the Hill were notable in character, and his contributions in the field to the cause of rural education were equally notable. His success in both of these areas led to an increasing number of students who came to Western folk. Tennessee had not, in 1887, had time to change from the traditions of a recent slave economy and to repair the ravages wrought by the War between the States, of which Middle Tennessee had been a major battle ground. His parents were children of that era and were limited by the conditions that it produced.
Mr. Mc was born and grew to young manhood between eras, much of the old, something of the new. A definite handicap for him was the limited and poor rural schools. He had the experiences of the average rural boy in these schools and came through with an indifferent elementary training, a little skill in the three R's. Nothing in his early education pointed to nor inspired him to be what he later became. Thus he came to young manhood apparently destined for a simple rural life on the farm or that of a laborer in the rapidly developing southern state.
The most obvious and immediate aim of education to him meant becoming a teacher. Fortunately, for his temperament, this was an ideal calling. He then turned his face resolutely to the long road and began the difficult journey to his goal. His career was marked by the usual steps out and upward. First three was the struggle for a certificate and then experience in the rural schools of Tennessee and North Georgia. Further educational preparation in the Middle Tennessee Normal School and summer work at the University of Tennessee gave him the principalship of a small town school. All the time his educational aims and ideals were growing and possible opportunities enlarging. He began his studies at Peabody College from which he received his Bachelor's Degree in 1922.
The influences of a college education are many and varied. It may be a moot question as to whether college creates traits of character or merely gives them a chance to grow. One thing is almost certain to be revealed in one's college life, namely, the level at which one will live in his community whatever or wherever it is. He will reveal and express his capacity for leadership and his willingness to be a good or a poor follower. Mr. Mc was no exception to the rule. He was as generally useful and efficient on his college campus as a student as he was later as teacher. His ability to capture a scholarship and an invitation from a great institution to go on for a higher degree reveal almost exactly the kind of estimate that we place on him after a career of almost 23 years.
What are the characteristics or traits that made Mr. Mc the outstanding and lovable personality he was and is? First, he had a good mind. He was not a genius in any sense, but he quickly thought straight and true on questions with which he was concerned. Intensity and persistency were complementary and apparently equal principles of his mind. His help and advice were sought because he knew the problems of his field. His scholarship, admittedly limited to the field of education, was sound. This soundness is manifested in his interest and belief in areas of learning of which he had only slight acquaintance. He fully appreciated content education and realized that education theory without sound and varied experience in fields of science, social science and the humanities is vain.
Finally, if there is any good in this kind of service, it must be to the living. All attempts to honor the departed are an acknowledgement of a debt we owe. Are we to pay or default? This is a memorial not a forgetting. We shall pay our debt by remembering wisely and working diligently to attain his aims in his spirit. No one can do this alone, but collectively our possibilities are great. There is a story in Holy Writ of a teacher and a pupil on a last walk together. Both knew it was the last, for the master was to be taken away. When the Master asked what shall I give you when I depart, the pupil replied, "a double portion of your spirit." "You have asked a hard thing," said the master, "but it shall be granted if you see me go." I do not know why the question in the master's mind, but I wonder if it was not a doubt as to the ability of the pupil to receive. The departing master dropped his mantle, the disciple picked it up and the master's work went on because his spirit rested on the pupil. Let it be our earnest hope that we in the College and all whom he has taught may receive a portion, at least, of his spirit and that his work shall go on as he would wish.
—DR. N. O. TAFF.
Horace McMurtry—The Man
Allen Horace McMurtry sprang from the great middle class of rural America. He was born on an upland farm of Middle Tennessee. His parents were poor in wealth and cultural background, but rich in health and the vitality of country
Letter To The Alumni
From H. W. Wilkey, President
W.K.T.C. Alumni Association
Dear fellow Alumnus:
When you graduated from Western, you took a great deal of Western away with you and you left a part of yourself with Western. Are you trying to strengthen that tie, make your stay there as an experience which will be kept vivid in your memory?
Some of us are hoping to make our Alumni Association an even greater force for good in our own lives and in the state as a whole. It can be done only with you in it. An effort that has already met with success in some counties is being made to organize county associations which would have at least one dinner meeting per year at which faculty members and fellow alumni from other sections would be invited.
Won't some alumnus with an interest in this movement volunteer in counties where no organization is being attempted? Write to "Uncle Billy" for membership cards and enroll those eligible as members. The $1.00 fee covers the cost of the College Heights Herald as well as membership dues. If there is not a sufficient number of teachers and others for an organization in the county, you would still be doing a good job by enrolling them in the Association.
You want to keep in contact with Western, and Western wants to follow your career. "Don't wait on MR. A" was the advice Dr. Cherry gave us. I urge you to heed that advice now.
Sincerely
H. W. WILKEY,
President Alumni Association.
ROTC OPPORTUNITIES
(Continued from page 1)
the current value of the garison ration to be paid monthly (current ration is $0.68 per day) less the period of Advanced summer camp. This allowance will be paid in addition to authorized benefits of the GI Bill of Rights. The total period will not exceed 2 calendar years.
2. During summer camp students receive the pay of the seventh enlisted grade (buck private — now $50.00 per month). Each student attending summer camp will also be paid $0.5 per mile as travel pay from Bowling Green to camp.
3. Each student will be furnished an officer type uniform to be retained by the government after completion of the advanced course or at time the student is discharged from ROTC for convenience of the government.
4. ROTC texts will be furnished on a loan basis. Certain designated texts may be retained by the student.
III — Summer Camp
Students will be required to complete summer camp (6 weeks duration) before receiving their Reserve Officers' commission. First camp for Western Kentucky State Teachers College will be held during th summer of 1947.
IV — The Course —
1a. For the spring quarter course 201 (beginners advance course) will be offered. This course includes — Drill and Ceremonies, Principals of Leadership, Organization of the Army, Health of Personnel, Methods of Instruction, Reconnaissance and Security, Infantry Weapons.
b. Class hours (tentatively scheduled): 10:00 a.m. on Mondays Wednesdays and Fridays; 1:00 p.m. on Tuesdays and Thursdays. Each period for 50 minutes.
2a. For the summer quarter course 203 will be given. Students who have completed 201 or 202 will be eligible.
b. Class hours for summer quarter are tentatively scheduled to begin at 9:10 a.m. for 75 minute periods for four days a week. Full schedule will be announced later by the college.
V — "The Contract"
The contract signed by each student will not specify that the advance course must be pursued without interruption. However, the contract will be cancelled if the course is interrupted for two calendar years.
Roland Smith, BS '39, visited the Hill Friday, February 15. A former physics major here, he was for a time a student and teacher at Northwestern University. Smith is now connected with General Electric Company, Schenectady, New York.
Alumni Flashes
By
RAYMOND C. HORNBACK
Route 4, Louisville, Ky.
LETTERS
W. R. Hammond, '29, head of the department of Social Sciences at Northeast Junior College, Louisiana State University, writes:
"I, too, read your column before perusing the rest of the paper. I notice most of the contributions are either from graduates of recent years or those of distant days beyond our remembrance. I would like to see more of the record of those who spent the years of the late 1920's on the Hilltop.
I would very much desire that you turn the pages of your 1929 annual and see if you can get some of our classmates to say where they are and what they are doing. When I was teaching on the Hill in the summer of 1938, I located a few of them. We really had a fine class and some of these days, now that the war is over, we should have a reunion."
Since leaving Western, Bill has done graduate work at the University of Chicago, Louisiana State University, Vanderbilt, and Peabody. He finished his Ph. D. at the last named institution in August, 1945. He has been in his present position for fourteen years.
It's A FOURTH TERM FOR EUGENE B. WHALIN
We feel sure all residents of the Raceland school district as well as practically all others all over the country will welcome the news that Mr. E. B. Whalin has been elected to a fourth four-year term as superintendent of the Raceland schools.
We have always felt that Greenup County gave the proper recognition to a man of talent and ability; certainly this is the case here. For during the past 12 years, under Mr. Whalin's guidance, the Raceland schools have made splendid progress. He can well feel proud of that record; the community, too, can well feel proud of it.
We know that Mr. Whalin is not content to merely sit still and let matters go smoothly along; he's always seeking progress, even though that means much work and worry on his part. We know that right now he has plans for a nice addition to Raceland High; and we know, too, that his plans will reach fulfillment.
Congratulations, Mr. Whalin, on your splendid achievements. And congratulations, members of the Raceland Board of Education, for re-electing him, and also for the cooperation you have given him.
D. D. Kirkland, Superintendent of the McAlester schools, McAlester, Oklahoma, entered Bowling Green college in 1917. He became a superintendent at the age of twenty. This will complete his 27th year of superintendency, 25 of which have been spent in Oklahoma. He has been superintendent of McAlester City Schools for the past five years. McAlester's population is now larger than 23,000. He enjoys his profession very much, as every year affords a challenge. He has served in every capacity of the Oklahoma Education Association for School Administrators. He took the lead in organizing the Oklahoma Teachers' Retirement System, of which he has been president of the board of trustees ever since it was organized.
He writes that it will be a pleasure to visit Western and his friends.
Your Columnist would appreciate a letter from each of the following Western graduates in Kentucky but not engaged in teaching: Franklin Hays, '30, lawyer, Louisville; Ruth Lytle, '43, home economist, Princeton; Benis Lawrence, P. B. I., Louisville; Paul Chitwood, '41, chem., B. F. Goodrich Co., Louisville; Mr. and Mrs. LeRoy Underwood, '39, Glasgow, city mail carrier and first grade teacher, respectively; Herbert Crick, '24, U. S. Internal Revenue, Owensboro; Mary Render Berry, '43, National Park Concessions, Mammoth Cave; Mary Johnston, occupational therapist, Louisville; Mrs. George (Sue Braun) Bennett, '43, child welfare work, Louisville; Eleanor Whittinghill, home demonstration agent, Cadiz; George Riggs, attending the Baptist Seminary in Louisville; Clem W. Russell, '28, Farm Security Adm., Russellville; Robert Traylor, '33, Vocational Rehabilitation, Madisonville; Mrs. E. C. W. Stapleton, '38, supt. of nurses, Dayton; Joe L. Price, grad of the Southern Normal, circuit judge, Paducah.
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Annual Report
New Direction and Growth
2022 / 2023
# TABLE OF CONTENTS
| Section | Page |
|------------------------------------------------------------------------|------|
| Message from the Chair | 4 |
| Message from the CEO | 5 |
| A Year’s Overview: Where We Are Now | 6-7 |
| Organizational Growth and Development | 8-9 |
| Strategic Plan 2023-2028 | 10-11|
| Financial Report | 12-13|
| FNMWC Framework Implementation | 14-15|
| Building Capacity of Mental Wellness Teams | 16-26|
| Communications Analytics | 27 |
| Partnerships, Advocacy, Support and Capacity Building | 28-31|
| Research Partnerships | 32 |
| Working Groups and Committees | 33 |
| Conferences and Presentations | 34-35|
| Looking Forward: Working to Create Systems Change | 36 |
Released July 2023
MESSAGE FROM THE CHAIR
Taanishi. It is with pleasure that I invite you to explore the annual report and work carried out by FPWC in 2022-2023. In my inaugural year as Chair of the Board, we worked alongside the staff to create key documents and activities to guide the work of FPWC into the future. A strong foundation had been provided by retired chair, Dr. Bill Mussell and the team. At FPWC, we have embraced the role of a Thought Leader to support staff and the Board, and we’re incredibly privileged to have Dr. Bill Mussell fulfill this important role.
We all worked incredibly hard to develop a new 5-year strategic plan that will guide the work, relationships and activities for 2023-2028. I want to extend my appreciation to our partners, stakeholders and staff for contributing to this important document by sharing your experiences and best advice to assist us in creating a document that will guide the work we do into 2028. I hope as you review the key components of the strategic plan that you will recognize this work as an opportunity to strive together to improve the wellbeing of our nations and communities.
I’m exceptionally proud of the growth and development that FPWC has made in the last four years to build the capacity of the organization to respond and support the development of the mental wellness and trauma specialist workforce in First Nation and Indigenous communities. In the annual report, we’ve highlighted some of our long-term projects that we are preparing to release and implement in 2023-2024, as well as introduce new and exciting work underway. Some projects are responsive to the needs and priorities of regional mental wellness services, such as the New Brunswick cultural safety and anti-Indigenous racism work that will culminate with a helping bundle to support communities. The bundle will be a tool to determine the competency of external service providers to meet community needs. Other projects, like the Indigenous Crisis Debriefing Model will support the workforce to have tools to respond to our communities who continue to experience trauma, loss and grief in devastating circumstances.
This past year, the Board and staff have also worked on enhancing our policies to match the growth and development and development of the organization. The Board of Directors gathered in March 2023 to discuss many relevant areas for advancement of FPWC, including board recruitment, FPWC’s position on anti-Indigenous racism and how to create trusting and reciprocal relationships with First Nation, Inuit and Métis people.
Looking forward, FPWC will work alongside partners to provide national messages on anti-Indigenous racism and the importance of allyship, supporting coordination of mental wellness priorities across turtle island, implementation of the Framework, preparing for the establishment of a First Nation Mental Wellness Association, with attention to youth voice, and most importantly, working with the dedicated people who deliver mental wellness services in our communities. I am confident we will continue this work in good cultural ways with our stakeholders guiding the way.
Maarsi
Denise McCuaig
Chair of the Board
This year has been both an exciting and challenging year for FPWC. We have seen incredible growth in the organization. We’ve expanded our team, increased our responsibilities to our stakeholders and with our partners, introduced the role of Thought Leader to our board and built a new 5-year strategic plan! This has allowed us to explore new projects and funding sources with the goal of seeking new initiatives to implement the key elements of the First Nation Mental Wellness Continuum Framework. It has also allowed us to dream, to believe and to be creative. But it has also been a challenging year. We recognize with growth comes development and transitions which has required us to be strategic, to plan and to support people through transition. It has reminded us of the importance of listening to the voices of our stakeholders, our partners, and our staff. It has challenged us to build an organization that is responsive and not reactive, is grounded in inclusion and empowerment, and to always work in relational ways that values the strengths and gifts of everyone and everything. It has meant we’ve sometimes had to be okay with crawling and not running, to take the baby steps so we can learn to walk firmly and confidently. As we wind up this year though, it has brought about new learnings, new experiences and new opportunities and allowed us to look forward with anticipation and excitement.
I’m exceptionally proud to work alongside so many talented and gifted people from our Board, to our Thought Leader, our staff, our partners and our stakeholders. The work we have created this year has focused on supporting the workforce. It has meant the creation of training and resources to build skills to ensure a healthy workforce and has also led us to explore strategies that would increase our ability to advocate for the equity of the workforce. We’ve been reminded over and over about the critical importance of the work that the mental wellness and trauma specialist workforces do in our communities. We’ve been inspired by their dedication and passion to use their gifts and the strengths of our culture, language and land to bring healing to the communities. We’re humbled by the opportunity to work with the trauma specialist workforce, known as Indian Residential School Resolution Health Support and Cultural Support Workers, and learn about the services they deliver. We hope to use this information to advocate for sustainability of this essential program and to create knowledge exchange opportunities that can further enhance their scope of work.
I’m especially excited about FPWC’s new 5-year strategic plan. It’s built on the values of Purpose, Hope, Meaning and Belonging with four main objectives. This strategic plan provides a roadmap for advancing work on mental wellness that is grounded in Indigenous knowledge, evidence and practices. It is balanced to focus on internal and external development and stresses the importance of relationships.
I encourage you to spend time learning about who we are, what we do and where we plan to go in the coming year through the pages of our annual report.
Brenda M Restoule, Ph.D., C.Psych
Chief Executive Officer
The 2021-2022 fiscal year was a big year for FPWC. While we continued to provide capacity building opportunities to our stakeholders, we fostered internal capacity by onboarding many new team members and saw our team grow from five to 16 strong. This meant further development of internal processes for the organization to ensure efficient and effective service delivery that meets the needs of our stakeholders.
FPWC’s biggest accomplishment was the development of our new 5-year strategic plan. We’re excited to share our new Purpose, Hope and Meaning. These guide our four main objectives of Growth, The Framework, Relationships and Collective Intelligence.
The team who supports Mental Wellness Teams had a busy year in knowledge exchange. We have continued with the strategy of offering webinars and learning series in a virtual format to make these opportunities more accessible for workers. This year we introduced the Facilitation of Care learning that uses a case study model to highlight the use of a two-eyed seeing approach to address a range of mental wellness needs that Mental Wellness Teams (MWT) and Crisis Response Teams (CST) may encounter in their daily work. The team has also created an online Resource Hub that will be launched in the upcoming year to increase accessibility to resources while promoting a culture of sharing and increased networking between the MWTs.
What guides us
**PURPOSE**
To walk with and support First Peoples and communities to share collective intelligence for healing, peace-making, and to live a good life.
**HOPE**
A nation where First Peoples and our communities experience holistic health and wellness, through living our diverse cultural values, beliefs, and practices.
**MEANING**
The FPWC advocates for collaborative transformative change to create pathways to wellness and whole health for First Peoples shaped by diverse Indigenous cultural lenses.
The creation of new teams at FPWC has increased activity throughout the organization and with our partners and stakeholders. The Special Projects team worked to gather data about the current needs, realities, challenges, strengths and priorities of the trauma specialist workforce. This information will be used to develop knowledge exchange activities and resources that can support capacity development in the upcoming year for this essential workforce. They have secured other funding sources to build resources to support the wellbeing of the mental wellness workforce and to address anti-Indigenous racism in the mental health system. The REP team created processes to increase the capacity for FPWC to engage in research, policy development and evaluation that will ensure our work is grounded and led by evidence that uses a two-eyed seeing approach. FPWC has fostered research partnerships in the last year that will provide data to support the sustainability of the mental wellness workforce.
Partnerships and relationship development and enhancement continue to be critical to our work. We continue to design initiatives with our sister organizations, Thunderbird Partnership Foundation and First Nation Health Managers Association, which collectively advance our vision of healthy First Nation communities, families and individuals. We have spent time on committee and working group tables to ensure Indigenous stories are being shared and that equity can be realized for Indigenous communities. Our CEO continues to build relationships through opportunities to give presentations and keynote addresses that focus on the work of FPWC and highlight the innovation of the mental wellness workforce.
And finally, we look forward. FPWC is moving into the final year of its 5-year funding cycle. We are poised to deliver many different types of knowledge exchange activities to advance the capacity of the mental wellness and trauma specialist workforces. Opportunities to co-develop and support various research initiatives will assist in the collection of data that builds evidence of the impacts these workforces have in Indigenous communities. Ultimately, all of this work is intended to build healthy, thriving Indigenous communities by supporting our greatest asset, the workforce.
FPWC has worked hard this last year to continue to build internal capacity to do the work we have been mandated to complete. Over the past year we have actively focused on the recruitment of new staff and have built up teams that allow us to have a broader focus and more efficiently meet our deliverables and be responsive to the needs of our stakeholders. We have hired new senior leadership, including a Director of Strategic Initiatives and Programs and an Operations Manager to take on the day to day activities of the organization. We’re pleased to have Despina Papadopoulos join as the Director of Strategic Initiatives and Programs and Claire Scanlan as the Operations Manager. Both bring a wealth of experience and knowledge to their roles and have helped build internal capacity with policies and processes to improve workflow and ensure we are taking care of the wellbeing of the FPWC workforce. The addition of senior leadership also ensures support for internal change and risk management as we witnessed a significant growth within the organization.
We also strengthened the organization by creating three new internal teams. Over the past two years FPWC has taken on shorter-term projects that expand implementation of the Framework. These projects have required dedicated resources to ensure deliverables are met, so we added a Special Projects Team and welcomed Maxine Peltier, Special Projects Manager and Trisha Trudeau, Program Support Officer. This team came onboard with the expectation of supporting the ongoing work related to the Indian Residential School workforce which included the submission of a successful proposal to support capacity building for this trauma specialist workforce, known as Resolution Health Support and Cultural Support Workers.
In the upcoming year, we plan to offer knowledge exchange activities and networking opportunities that will allow new members of this workforce to access training and resources to support the ever-increasing demand for these services in our communities.
**Special Projects: Additional Funding Proposals**
This team has also secured two additional funding proposals; one will have them work alongside our team that supports Mental Wellness Teams to build resources that can support this workforce by reducing the risk and impacts of the pandemic. This two year project funded by the Public Health Agency of Canada, seeks to create Worker Wellness Bundles that will have a number of resources that can support team members to ensure their wellbeing and reduce risk of fatigue (decision-making, pandemic and compassion), vicarious trauma and burnout. The second new project, funded by Health Canada, will focus on addressing anti-Indigenous racism in the mental health system. We have partnered with Mental Wellness Teams in New Brunswick to create a cultural safety training curriculum that will attend to oppression, privilege and allyship through reflective practices and understanding local history and reality that can increase their competence. This project will target psychologists and social workers in New Brunswick and is intended to wrap up in early 2024.
Our second team is the REP team (Research, Evaluation and Policy). This team is responsible for supporting many of the implementation activities of the Framework and is tasked with ensuring we build an evidence-based approach to all of our work. The REP team spent this past fiscal year producing a roadmap that is aligned with FPWC’s new Strategic Plan with the intention of implementation in the upcoming fiscal year. This team has brought three new staff into FPWC; Dr. Emily Kirk (Principal Researcher), Catherine Graham (Evaluator) and Becky Carpenter (Policy Analyst).
A Senior Communications Lead, Haley Laronde, was added to the Operations Team to provide internal capacity to manage the day to day communications needs of the organization including our website, social media accounts and supporting the creation/branding of any resources and other documents produced by FPWC. This position is critical to ensuring FPWC can communicate effectively about the work we do and to support larger initiatives such as the *Rise Above Racism* campaign that we are partnering on with our sister organizations, Thunderbird Partnership Foundation and First Nation Health Managers Association.
Finally, we’ve enhanced our MWT Supports Team by adding a Workforce Development Lead, Keith Martin, and a Support Officer, Melissa Dedumus. They will support the continued rollout of the recommendations from the *Comprehensive Needs Assessment (2019)*, and implement a workforce strategy and create platforms that will support networking and sharing of resources amongst teams to improve standards of care.
A new 5-year strategic plan was created with input from stakeholders, partners and staff that reflects our new mandate, growth and accountability to our stakeholders. The graphic on pages 10 and 11 outlines FPWC’s new strategic direction and plan.
In October 2022, our team (pictured above) gathered in Ottawa at a Staff Retreat to build relationships, explore their role in the organization and to contribute to the organizational growth plan of FPWC. The Staff Retreat was supported by knowledge keepers, Perry and Laurie McLeod-Shabogesic, who shared teachings to guide the FPWC team to manage change and transition within the organization. Some of the elements of FPWC that staff felt were critical to its sustainability included being guided by culture and teachings and the principles of the Framework; using a decolonizing lens in our work; valuing the skills, knowledge and wellness of its staff; ensuring equity and diversity in our work; providing a safe and supportive work environment that supports a healthy work-life balance; and is fluid and evolving. As FPWC is a remote organization, ongoing efforts to build relationships and support a healthy workplace culture were necessary to support the growth and transition of FPWC.
Purpose
The reason that we exist.
To walk with and support First Peoples and communities to share collective intelligence for healing, peace-making, and to live a good life.
Hope
Our vision for a better future.
A nation where First Peoples and communities experience holistic health and wellness, through living diverse cultural values, beliefs, and practices.
Meaning
The work we do to achieve our hoped-for future.
The FPWC advocates for collaborative transformative change to create pathways to wellness and whole health for First Peoples shaped by diverse Indigenous cultural lenses.
Belonging
We are all connected; these are the lenses through which we understand our relationships to the communities we serve, the work we do, and the world.
- Environments, communities, families, and individuals intersect and interrelate in complex, historical and dynamic ways – they are more than the sum of their parts;
- A cultural lens is the key to making meaning of Indigenous lived experience;
- Indigenous knowledge is the foundation for transformative change for First Peoples;
- A cultural lens and Indigenous knowledge are grounded in a holistic worldview;
- Sharing and building on a cultural lens and Indigenous knowledge leads to strengths-based actions and transformative change;
- Holistic approaches are relational – they honour relationships to the land and all other things of the Creator. Population health and health determinants are appropriate working tools;
- At all times, ceremonial and seasonal activities are important ways in which we acknowledge our relationships with all of Creation and the Creator;
- All people possess the ability to modify self and by finding their own voice can serve as effective advocates for change at the individual, family, and community levels;
- Fairness and justice for all are priority values; First Peoples’ programs and services should be resourced equitably and reflect a deep understanding of anti-Indigenous racism and the ongoing impacts of generational trauma.
Enablers
1. Diversified sustainable funding.
2. More robust communication, branding, marketing.
3. Accountability and Quality Assurance
4. Operations – Human Resource Support, Workplace Wellness (Internal and External)
Objectives and Priorities
1. Growth
a. Provide mentorship and resources to mental wellness and crisis support teams and related workforce, building from ongoing needs
b. Continue to build the capacity of mental wellness and crisis support teams
c. Create a central resource hub to share wise practices and new and existing resources and tools
d. Expand membership by designing and executing a membership growth campaign within and beyond First Nation mental wellness workforce and organizations
2. The Framework\(^1\)
a. Implement the First Nations Mental Wellness Continuum Framework into everything we do, internally and externally.
3. Relationships
a. Build and expand relationships with Indigenous groups, scholars, and organizations and/or governing bodies to support wellness, healing and peace-making using Indigenous knowledge, including taking action on anti-Indigenous racism
b. Develop criteria for relationships that are in (or out) of scope for FPWC:
1. Provide clarity around expectations
2. Manage external requests
c. Continue to plan and deliver training with Thunderbird Partnership Foundation (TPF) to meet the needs of mental wellness and crisis support teams and related workforce
d. Build relationships with non-Indigenous organizations, grounded in reciprocity, to work together to create equity and advance Indigenous mental wellness
4. Collective Intelligence
a. Develop a research agenda that builds on the strength of Indigenous knowledge and evidence
b. Share the wise practices of the workforce
c. Influence policy makers and policy change to improve equitable access to services
d. Advocate for strategies around peace-making, healing, life promotion and wellness amongst First Peoples communities and those with whom we interact
e. Create an accredited Circle of Indigenous Knowledge and Relational Practices that supports lifelong learning and the sharing of collective intelligence
\(^1\) First Nations Mental Wellness Continuum (FNMWC) Framework
FPWC is in the final year of its 5-year funding agreement with Indigenous Services Canada’s First Nations and Inuit Health Branch (FNHIB). Negotiations for the next funding agreement will be undertaken this fall.
The 2022-2023 Fiscal Budget included funds from the Ministry of Education, to continue the development of student resources. Over the year, FPWC developed and submitted several project proposals. We are delighted to announce that FPWC was successful in its endeavor and was awarded the funding for these projects:
- **Indigenous Services Canada:**
- **Indian Residential School Resolution Health Support Program Workforce Wellness**
This project started in March 2023, and will conclude on March 31, 2024.
- **Health Canada:**
- **First Nations Knowledge and Evidence: Taking Action on Systemic Racism Through Cultural Safety**
This project started in November 2022, and will conclude on March 31, 2024.
Additional revenues were generated through several service contracts for consultations and collaborations with FPWC.
Mr. Tony McGregor, Freelandt Caldwell Reilly LLP presented the Audited Financial Statements for the fiscal period ending March 31, 2022, to the FPWC Board of Directors on July 19, 2022. Mr. McGregor reported a clean audit with no significant findings. Subsequently, the Auditor’s report was accepted by the Board of Directors as presented. The Audited Financial Statements for this fiscal period ending March 31, 2023, will be presented to the Board of Directors on July 11, 2023, during the Annual General Meeting.
The Audited Financial Statements are available upon request to Claire Scanlan, Operations Manager at firstname.lastname@example.org.
FPWC is a co-chair of the First Nations Mental Wellness Continuum Framework (Framework) Implementation Team (IT) and the Secretariat. The Framework IT Secretariat is a group of representatives from First Nations organizations and government partners that work collaboratively to promote health and wellbeing among First Nations people in Canada through the implementation of the Framework. Representatives include FPWC, Thunderbird Partnership Foundation (Thunderbird), Assembly of First Nations (AFN), We Matter, Canadian Roots Exchange (CRE), as well as government partners Indigenous Services Canada (ISC) and Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC). Two specific activities undertaken by the Framework IT Secretariat throughout the 2022/2023 fiscal year include:
**FNMWCF Orientation Training**
The purpose of the Framework Orientation Training is to help orient audiences who work within the mental wellness landscape, such as employees at First Nations and non-First Nations organizations, members of government and other partners and stakeholders to the Framework. The training works to enhance participants’ overall understanding of the Framework, its history and importance, how it can be applied to participants’ work and community, and how it can be used to support systems-level change. The training uses a variety of methods, including case studies, reflection questions and group discussion questions to support and guide the learning process. It is a flexible approach, seeking to meet participants where they are with their knowledge and understanding. The materials will also incorporate youth insight and feedback. To complete this work, FPWC works collaboratively with Thought Leader and Elder Dr. Bill Mussell, Lead Author Dr. Nancy Stevens, Project Lead, Mariette Sutherland, as well as Thunderbird Partnership Foundation, We Matter, AFN and ISC. The materials are currently being finalized, and the training will be piloted with different community groups and partners in the 2023-2024 fiscal year.
**Evaluation Model**
In addition to presenting “a shared vision for the future of First Nations mental wellness programs and services and practical steps toward achieving that vision,” the Framework provides us with an opportunity to reflect on the work that we do in a manner that promotes growth and accountability. The evaluation model and accompanying learning modules seek to accomplish this by providing communities, organizations, and others with the tools they need to monitor and evaluate the work that they do using the Framework. Like the Framework, the evaluation model centres culture as a foundation and seeks to support transformative change at the community and systemic levels. Most importantly, it grounds evaluation in local knowledge and culture and supports the application of indicators that are prioritized by First Nations communities. The model and training modules will be piloted and finalized in 2023.
The FNMWCF IT Secretariat is a group of representatives from First Nations organizations and government partners that work collaboratively to promote health and wellbeing among First Nations people in Canada through the implementation of the FNMWCF.
BUILDING CAPACITY OF MENTAL WELLNESS TEAMS
Mental Wellness Supports Team Year in Review
It has been another busy and exciting year for the Mental Wellness Supports Team. Over the course of the year, our team grew and we welcomed a Workforce Development Lead, whose primary role will be completing and implementing the *Workforce Wellness Strategy*. The Workforce Development Lead will be supported by a Support Officer, whose primary role is the development, promotion and maintenance of the *Resource Hub*.
With the growth of the team and with that, our own capacity, our focus continued to be on supporting capacity building of the Mental Wellness Teams by creating opportunities for knowledge exchange, sharing of wise practices, networking with peers and the development and delivery of training, tools, and resources based on Indigenous knowledge and evidence.
The Mental Wellness Supports Team moved a number of initiatives forward that will reach completion and launch by the end of 2023, including The Mental Wellness Team Toolkit, *An Introduction to First Nation Mental Wellness*, *Workplace Well-Being Training*, and a *Virtual Care Toolkit*. We also started new projects that include the Workforce Wellness Strategy, Resource Hub and *Mental Wellness Workforce Peer Directory*.
Notably, we welcomed the opportunity to gather in person once again and supported and presented at a number of regional gatherings.
Knowledge Exchange
FPWC is committed to enhancing the capacity of Mental Wellness Teams and others to support First Nation individuals, families, and communities to achieve their self-determined visions for Hope, Belonging, Meaning, and Purpose. To do so, FPWC hosts a variety of professional development opportunities that aim to meet identified learning needs of the Mental Wellness Workforce (Mental Wellness Teams, Crisis Response Teams, Indian Residential School (IRS) Resolution Health Support Program) through a variety of mechanisms, including the *MWT Comprehensive Needs Assessment* that was published in June 2019. Most of these opportunities are delivered virtually through the Facilitation of Care Learning Series (FCLS) and FPWC Learning Circles.
The FCLS utilizes a case consultation model that brings together clinicians, Elders and Cultural practitioners to share wise and promising practices. The Series embraces a two-eyed seeing approach by bridging the perspectives of traditional and Western healing modalities and practices to explore issues and treatment approaches in caring for communities.
The Mental Wellness Toolkit objectives are:
- To provide Mental Wellness and Crisis Support Teams (MW/CST) with a collection of resources to assist in initial start-up and ongoing development
- To respond to needs as identified in the Comprehensive Needs Assessment (2019) completed by FPWC and supports implementation of the FNMWC Framework
- To use a balanced approach that considers context and structure of the team and the stages of team growth and development focused on serving their communities
In total, 262 people registered across five FCLS events during fiscal year 2022-2023. FCLS topics included: Western Healing Journey Part One (57), Western Healing Journey Part Two (78), Trauma & Indigenous Application (45), Life Promotion (53), and Breaking the Cycle: Healing from Family Violence (29).
Learning Circles provide the Mental Wellness Workforce opportunities to listen to presentations made by experts from a diversity of backgrounds on topics ranging from those related to supporting innovative ways to support clients to the importance of self-care for those in the helping profession. One of the more notable Learning Circle events this last fiscal year featured Dr. Gabor Maté who provided a presentation titled “When the Body Says No: Mind/Body Unity and the Stress-Disease Connection” to a virtual audience of 300.
Over 650 people registered across eight Learning Circle events during the fiscal year 2022-2023. Topics included: Weaving in Cultural Revitalization (35), Building Helper Safety for Better Client Outcomes (52), Practical Strategies for Supporting Youth Mental Health (30), When The Body Says No (300), Eight Point Star Teaching (77), Self-Care Through Movement (65), Self-Care: Healing-Informed Strategies for Working With Youth and Families (48), and Self-Care: Expressive Writing for Health and Wellness (66).
Upon completion of their participation in these professional development events, attendees were given the opportunity to reflect on their experience and provide feedback by completing a short online survey.
This is some of what we heard:
- 80% of attendees who completed the survey reported an increase in awareness or understanding related to at least one of the advertised learning objectives linked to the particular virtual event
- 91.5% of attendees who completed the survey felt that the event achieved the advertised learning objectives
- 100% of attendees who completed the survey indicated that they would recommend the virtual event to colleagues
Over 650 people registered across eight Learning Circle events during the fiscal year 2022-2023.
**FPWC Learning Circles Attendance and Registration**
| Event | Registrants |
|----------------------------------------------------------------------|-------------|
| Practical Strategies for Supporting Youth Mental Health | 30 |
| Building Helper Safety for Better Client Outcomes | 52 |
| Weaving in Cultural Revitalization | 35 |
| When the Body Says No | 300 |
| Eight Point Star Teaching | 77 |
| Self-Care Through Movement | 65 |
| Self-Care: Expressive Writing for Health and Wellness | 66 |
| Self-Care: Healing Informed Strategies for Working with Youth and Families | 48 |
**Thunderbird Partnership Foundation Training**
In addition to providing direct professional development opportunities, FPWC also ensures that Mental Wellness Teams have access to other training such as those provided by the Thunderbird Partnership Foundation (TPF). During the 2022-2023 fiscal year, 166 members of Mental Wellness Teams from across Canada participated in TPF hosted training on a variety of topics including training on the application of the First Nations Mental Wellness Continuum Framework.
In the future, FPWC hopes to expand its professional development offerings as it begins the process of working with its sister organizations to establish a First Nations Mental Wellness Association.
This association will provide accredited training that is grounded in core competencies that are specific to ensuring that workers are able to support communities in a trauma informed and culturally safe manner.
Other information: A total of 174 (166 MWT & 8 IRS) participants registered for TPF training sessions. TPF offered 26 training sessions in 2022-2023 that MWT & IRS could register for, there were participants in 17 of those training sessions. The MWT and IRS were 26% of the total participants. Most attended training sessions by MWT: Pharmacology (34), Community Crisis Response (30), Land for Healing (29), Culture As Foundation (23).
New Brunswick Regional Mental Wellness Team Gathering
While FPWC focuses much of its efforts on providing broad based professional development opportunities on a national scale, it also understands that worker needs can vary between and across geographic regions. As such, the organization supports and collaborates with Mental Wellness Teams to deliver face-to-face opportunities when time and resources permit.
For example, in 2022 First Peoples Wellness Circle collaborated with the three Mental Wellness Teams in New Brunswick; the Mawlugutineg MWT, the Wolastoqewi MWT and the Oeliangitasoltigo MWT, to host a three-day gathering. The event was attended by 31 team members who came together to share work experiences and participate in self care activities.
**Self-Care:** Resting Our Minds, Nourishing Our Bodies, Strengthening Our Spirit & Cherishing Our Emotions. Invitees had the chance to participate in self-care workshops, networking opportunities, capacity supporting presentations and traditional ceremonies.
**Self-Care Workshops:** Medicine Pouch Making, Baby Moccasins Making, Beading, Quill Work, Energy Healing, Painting
**Activities included:** Ax Throwing, Cribbage Tournament, Shared Meals
### Most Attended Training Sessions
| Session | Attendees |
|-------------------------------|-----------|
| Pharmacology | 34 |
| Community Crisis Response | 30 |
| Land for Healing | 29 |
| Culture as Foundation | 23 |
- **166 MWT**
- **174 Registered Participants**
- **8 IRS**
- **17 Training Sessions**
Workforce Wellness Strategy
Findings from First Peoples Wellness Circle (FPWC)’s report Comprehensive Needs Assessment for Mental Wellness Teams (2019) indicated that there needs to be a strategy developed that focuses on supporting the wellbeing of Mental Wellness Service Providers that serve First Nation communities.
FPWC engaged with a consulting company to define a wellness strategy for the workforce recognizing that the pandemic impacts had a significant impact on wellbeing, recruitment and retention.
Consistent with the First Nations Mental Wellness Continuum Framework (FNMWCF) and the focus on Kinship, Elders, Clan and Community, the Workforce Wellness Strategy is grounded in the principles of collective responsibility and accountability and includes three focused wellness outcomes (Individual, Organizational and Environmental, and Systemic and Political) to prioritize service provider wellness.
The report and implementation plan will be released in 2023 that will identify some practical strategies for employers and FPWC to support the retention of the workforce.
The process was a nationwide engagement and included:
- Guidance by a working group comprised primarily of Mental Wellness Service Providers
- A comprehensive literature review of the most current publications around Mental Wellness from an Indigenous perspective
- A nationwide survey of Mental Wellness Service Providers that serve First Nation communities
- Nationwide focus groups to expand on the literature review and survey
The Workforce Wellness Strategy aims to:
- Support the wellness of the workers who comprise the First Nations Mental Wellness Workforce (FNMWW), which includes Mental Wellness Teams, Crisis Support Teams, and other specialized wellness workforces (such as the Indian Residential School Resolution Health Support Program)
- Be reflective of those workers and the current realities they work in
- Contain strategies that can be implemented in meaningful ways
- The final draft is currently being reviewed, and once completed, it will be formatted and shared along with an implementation plan
Workplace Well-Being Training Pilot
A Workplace Well-Being training was developed in response to the pandemic where many front line workers became overwhelmed with increased caseloads and, as a result, many experienced burnout and fatigue. The pilot training was well received, and FPWC is looking forward to delivering this training in the near future to Mental Wellness frontline workers, managers and supervisors.
What participants of the pilot training thought:
“I really enjoyed this module and especially the parts about recognizing warning signs in yourself. I think this is a really important skill and connecting with ourselves can help to utilize the other teachings from this course.”
“I thought the content was relevant and it was well delivered.”
“This module was really helpful and it was interesting to learn and understand the different ways we grieve and how individual this is. I enjoyed hearing others’ perspectives.”
“Overall, I thought it was interesting and I learned from it.”
“I really liked how we all worked together to brainstorm strategies and how that may look in practice. Great module.”
“I enjoyed the discussions and I think everyone was able to openly discuss some of their personal and workplace stresses and potential solutions. It was valuable to hear others’ opinions and ideas. I think the module was well done and I feel that I learned everything I was hoping to.”
Resource Hub
The FPWC Resource Hub will serve as a critical component to knowledge exchange and resource sharing amongst the First Nation Mental Wellness Workforce (Mental Wellness Teams, Crisis Response Teams, Indian Residential School (IRS) Resolution Health Support Program and other Indigenous Mental Wellness workforces. The Resource Hub is designed to be an easy-to-use, accessible platform where the Mental Wellness Workforce can access and share policies and resources, find training opportunities, articles and studies, and information and research about wise practices.
This past year, the online platform for the Resource Hub has been in development, which includes courses adapted from some of FPWC’s published reports and tools, as well as a collection of culturally relevant resources. In 2023, the Resource Hub will be piloted and then launched to the network. The Resource Hub will support the capacity building of MW/CS Teams and be a leading source of information and resources about Indigenous mental wellness.
The Mental Wellness Workforce Peer Network
The Mental Wellness Workforce Peer Directory is a tool for the Mental Wellness Workforce to improve awareness, collaborations, and relationships amongst teams across Turtle Island. The goal is to gather and share information (with free, prior, and informed consent) about the Mental Wellness Workforce that includes the communities being served, mandate, contact information, areas of expertise, and more. The directory is currently under development and will be integrated into the Resource Hub.
Three briefing notes were developed to assist Indigenous and non-Indigenous partners, governments and leadership in using wise practices to support the First Nations workforce in the context of community crises. The briefing notes focus on the Indigenous Crisis Debriefing Model, strategies to care for the First Nations workforce before, during and after a crisis, and using the First Nations Mental Wellness Continuum Framework to enhance coordination of care.
Indian Residential School Resolution Health Support Program (IRS RHSP)
Two documents were created for the dissemination of the IRS RHSP Qualitative Assessment – an Executive Summary and Summary Report. Translated versions of these documents were also completed. FPWC continues to disseminate these documents in print and electronic copies.
Following the completion of the IRS RHSP Qualitative Assessment, the Working Group called for a formative analysis to explore the current and projected needs of the RHSP.
Data collection for the IRS RHSP Formative Analysis began with the distribution of surveys to RHSP Contribution Agreement holders. Focus groups are being conducted with the RHSP frontline staff from coast to coast to coast; to date a total of five focus groups with 71 participants have been conducted to date. This trauma-specialist workforce has been called to support survivors and their families during the Papal visit and commemorative events, as well as supporting communities and leadership during the recovery of unmarked graves at former Indian Residential Schools. We continue to collect this information during a period of intense work and engagement for this workforce with the national gatherings hosted by the Special Interlocutor to gather information that will assist in crafting recommendations for a new federal framework to identify, preserve and protect unmarked graves, which created a delay in response to the call for survey and focus group participation. Completion of this project is expected in the fall of 2023.
To view the IRS RHSP Qualitative Assessment Summary Report, click the link below:
https://fpwc.ca/projects/indian-residential-school-irs-resolution-health-support-and-cultural-support-program-stories
Indigenous Crisis Debriefing Model (ICDM)
With the exceptional stressors associated with the COVID-19 crisis, and the unmarked graves at former Indian Residential School sites, communities were met with intense grief and loss. Frontline mental health workers and natural helpers received an overwhelming increase in calls for support.
The current level of support for the many different helpers and responders in communities is seen as insufficient. There is a need for culturally-based support services that can assist staff in navigating new challenges or crises, and that understand the complex and multi-layered lived experiences of stress or trauma that workers have themselves experienced as part of current or past events.
FPWC invited a group of Indigenous leaders in culturally based mental wellness services to participate in an Advisory Committee to guide and support the development of an Indigenous Crisis Debriefing Model. The model will incorporate the importance of being grounded in place and the land and must be built on cultural strengths and an understanding of spiritual wellness.
As directed by the Advisory Committee, focus groups are being held with Elders, Knowledge Keepers, and language speakers from coast to coast to coast. This approach invites Elders and Knowledge Keepers to share their knowledge and allows us to learn about traditional methods of caring for the community in times of need. The knowledge shared in the focus groups will support the development of a strengths-based model to support worker wellness.
FPWC continues to collect input from the Elder focus groups and the Advisory Committee to support the development of the ICDM, which is expected to be completed in the fall of 2023.
The people for whom we are designing the ICDM model includes:
1. Indigenous people, specifically First Nations and Métis people
2. Frontline providers and leadership, who respond to crises and come with multiple roles in their communities
3. Natural helpers and other supportive community members, such as knowledge keepers and Elders
4. Volunteers who often include cultural support workers/elders
Indigenous Student Wellness Toolkits
FPWC began the development of school-based resources related to Indigenous student mental wellness for Ontario school boards. These resources will provide school administrators, teachers and support staff with tools, strategies and resources to attend to school conditions and improve school personnel’s knowledge and capacity to support Indigenous students. An additional resource was also created for Indigenous parents and caregivers to enhance their knowledge and skills to advocate and support their children in the educational system.
The launch of these resources is anticipated for 2024.
An Indigenous Student Resource Review Committee, made up of Indigenous student supports within Ontario schools, was created to inform resource development. Feedback received from the review committee was incorporated throughout the draft writing process. Current drafts are in the final stages of review.
Indian Residential School Resolution Health Support Program — Workforce Wellness
FPWC has been successful in receiving funding for the Indian Residential School Resolution Health Support Program (IRS RHSP) Workforce Wellness Project. Early phases of project preparation began in this fiscal year, with the majority of the work being completed in the next fiscal cycle. This project will focus on Workforce Wellness and creating space for IRS RHSP Workers to gather for training and capacity building on models of care when working with survivors and families of colonial traumas. This project will integrate training and virtual learning opportunities, including: theory, best practices, peer mentorship, traditional knowledge sharing and skill building to support the IRS workforce that will highlight cultural practices in healing-centered care.
- Theory and skill building
- Best practices
- Peer mentorship
- Traditional knowledge sharing
Addressing Racism and Discrimination in Canada’s Health Systems: Anti-Indigenous Racism and Cultural Safety (AIR) Project
FPWC has been successful in receiving funding from Health Canada to develop a project which will work to address racism and discrimination in Canada’s Health System. This project will consist of a partnership between FPWC and two Mental Wellness Teams (MWT) of New Brunswick (Mawlugutineg and Wolastoqewi) to co-lead and co-develop a cultural safety initiative targeted at the mental health system in 2023-2024.
Early preparation work for the project included the finalization of the budget, workplan and the establishment of a Working Group comprised of mental health experts directly involved in Indigenous mental health and wellness. This project will consist of the early stages of co-designing culturally safe tools and resources targeted at the culture of the institutions, its leaders and mental health professionals.
Evaluation data collected throughout this project will inform the creation of a helping bundle for participating First Nations that can be used to define the steps to cultural safety and to measure cultural competency of organizations and practitioners.
COMMUNICATIONS ANALYTICS
FPWC Website
In August 2022, FPWC launched a new website developed collaboratively with Design de Plume. This new website is an essential step in enhancing FPWC’s online presence and will serve as a hub for our resources, initiatives, projects and training offerings. The website will also feature our latest news and upcoming events. Our online presence enables us to connect with our community and stakeholders more effectively.
The FPWC website will not only be a source of information, it will be a platform for engagement, collaboration, and shared learning. It will serve as a landing point for individuals and organizations seeking to learn more about the work of FPWC and Indigenous wellness. FPWC also offers membership to any individual who is committed to our goal of improving the lives of Canada’s First Peoples by addressing healing, wellness and other mental health challenges with a focus on Indigenous knowledge and worldviews.
To visit the FPWC website and learn more about our work, visit: www.fpwc.ca
Social Media Channels
- Facebook
www.facebook.com/firstpeopleswellnesscircle
- Twitter
@FPWellnessC
- LinkedIn
www.linkedin.com/company/fpwc
- Instagram
@firstpeopleswellnesscircle
PARTNERSHIPS, ADVOCACY, SUPPORT AND CAPACITY BUILDING
FPWC seeks to build and expand relationships with Indigenous groups, scholars, organizations, and governing bodies to support wellness, healing, and peace-making using Indigenous knowledge. FPWC works with sister organizations on projects and strategies in addition to those that are aimed at advancing the Framework. For example, FPWC serves as a key member and co-chair of AFN’s Mental Wellness Committee. This participation provides FPWC with a vehicle to advance its own policy and advocacy work while supporting the essential work that is being undertaken by the AFN and regional partners.
FPWC also partnered with sister organizations First Nations Health Managers Association (FNHMA) and Thunderbird Partnership Foundation to collectively create the Rise Above Racism campaign that aims to eliminate anti-Indigenous racism in Canada’s Health Care System by raising awareness and promoting critical allyship among non-Indigenous individuals and organizations. FPWC was also privileged to have had Dr. Brenda Restoule present at AFN’s Winter Assembly and at FNHA’s annual conference, where FPWC also sponsored the gala dinner.
Perhaps the closest of FPWC Sister Organizations is Thunderbird Partnership Foundation. They have provided guidance and support during times of growth and continue to support FPWC in all of its work. This relationship exemplifies the principle of reciprocity which is apparent in the key initiatives that we have partnered with or have supported in the last year. Along with collaborative work related to the Rise Above Racism campaign, co-leading implementation of the Framework and delivered training, FPWC supported the planning of and served as co-host for two events in 2023.
About the RAR Campaign
The Rise Above Racism (RAR) Campaign brings to the forefront the issue of anti-Indigenous racism within the Canadian Healthcare system and the startling fact that 78% of Indigenous people have experienced racism in healthcare must be addressed. We are calling on allies across Canada to help make it right.
RiseAboveRacism.ca
The Community Safety Planning and Mental Wellness Summit held in Toronto February 28 - March 2, 2023, focused on learning about the connection between mental wellness and community safety planning to support ongoing program development for Public Safety Canada. Over 100 frontline workers on community safety planning attended the event and identified critical factors such as culture to promote community safety in First Nation communities.
The First Nations Substance Use Summit was held in Toronto March 28-30, 2023. Over 100 participants joined in person or virtually to learn about innovative practices to address substance misuse and define core competencies in addressing substance use.
FPWC and TPF also worked together to support a delegation of youth (pictured below) who attended and presented at the International Initiative for Mental Health Leadership (IIMHL) that took place in Washington from October 26-27, 2022. These youth were integral throughout the gathering where they performed MC duties, participated in panel presentations and led a workshop that defined competencies for youth in Indigenous mental wellness leadership. It is anticipated that this presentation will assist with revising the Wharerātā Declaration to include youth considerations.
Among the recommendations that emerged for the hackathon was the need to enhance communication about the Framework through technological innovations and the recognition of “the importance of, and the needed continued work towards the inclusion of 2SLGBTQQIA+ people, their lived experiences, as well as broader intersectionality in the work that we do.”
For example, FPWC has supported the inclusion of First Nations youth, through engagement with We Matter in the ongoing development of Orientation training materials related to the Framework which has led to the development of a youth-specific case study that will be included in the training tool.
FPWC also sponsored and supported an Indigenous youth policy hackathon that was hosted by the Canadian Roots Exchange. Among the recommendations that emerged for the hackathon was the need to enhance communication about the Framework through technological innovations and the recognition of “the importance of, and the needed continued work towards the inclusion of 2SLGBTQQIA+ people, their lived experiences, as well as broader intersectionality in the work that we do.” This important work has prepared FPWC to take some important next steps in its efforts to engage First Nations youth. These steps include working with Thunderbird Partnership Foundation to establish a youth council. FPWC will also seek to identify a youth thought leader who will work alongside fellow thought leaders to guide FPWC as it continues to grow and flourish.
While the majority of FPWC’s relationships are national in scope, the organization does work closely with Mental Wellness Teams, along with committed organizations and individuals at the regional and local levels. For example, the organization worked with Mental Wellness Teams in New Brunswick along with two registered Psychologists to facilitate a one-day cultural awareness event in September 2022 that was aimed at supporting Psychologists to develop an understanding of the important role that the delivery of culturally competent and safe services to First Nations plays in overall community wellbeing.
This relationship continues to grow as FPWC secured funding from Health Canada to build upon this work which will include the development and piloting of regionalized curriculum that will foster mentorship and support mental wellness professionals to understand and engage in critical allyship with a goal of potentially scaling the project to other regions across Canada.
FPWC also works to build relationships with non-Indigenous organizations that are grounded in reciprocity and advance First Nations mental wellness in a way that creates equity. In addition to funding organizations including government agencies such as Health Canada, Indigenous Services Canada, and Public Health Agency of Canada, FPWC has been working to strengthen its relationships with organizations such as Healthcare Excellence Canada and School Mental Health Ontario (SMHO). In our work with SMHO, Dr. Brenda Restoule acted in a co-chair role to review and provide recommendations on creating a culturally adapted social-emotional learning curriculum that culminated in a report that was submitted to the Ontario Ministry of Education.
COVID-19 Public Health Working Group on Isolated and Remote Communities
FPWC is a co-chair for the Task Group on Mental Wellness (Task Group), part of the COVID-19 Public Health Working Group on Remote and Isolated Communities. The Task Group was assembled in 2020 to better understand and address the impacts of COVID-19 on First Nations, Inuit, and Métis peoples’ mental wellness across Canada, focusing on remote and isolated communities. Through extensive community engagement as well as engagement with various government partners, the Task Group has developed four reports focusing on the following key areas:
- Substance Use Treatment and Land-based Healing;
- Life Promotion and Suicide Prevention
- Workforce Wellness
- Family Violence Prevention
Each report provides community-led wise practices and recommendations on how to support mental wellness and enhance workforce and service equity for rural and isolated communities. Once finalized, the reports will be housed on the National Collaborating Centre for Indigenous Health’s website. This work is set to continue and will include developing a summary document of all four reports and ways to monitor and provide guidance on implementing the recommendations.
FPWC continues to engage in research partnerships that work to advance mental wellness outcomes for First Nations people and communities across Canada. Throughout 2022/2023, FPWC worked on numerous research projects and also hired a Principal Researcher to focus on partnership development and the strategic direction of research at FPWC. Throughout the fiscal year, the Principal Researcher developed a long-term Research Roadmap that provides guidance on how FPWC can enhance its research capacity to help achieve its Strategic Plan.
FPWC is currently working on a Realist Review in collaboration with research partners at the University of Western Ontario (Dr. Victoria Smye), Thunderbird Partnership Foundation, and FNHMA. The aim of this review will be to collect data from literature and legislative reviews to gather evidence-based recommendations for building and ensuring equity for the First Nations mental wellness workforce in Canada. This includes recommendations for programs, funding, and policies.
FPWC also partners with the Network Environments for Indigenous Health Research (NEIHR) Program. The NEIHR Program is a national network of nine centres located throughout the country, and works to provide opportunities and support for community-based health research led by Indigenous people and grounded in Indigenous worldviews and values. FPWC works within two networks, the Ontario NEIHR, led by Dr. Suzanne Stewart and the Saskatchewan NEIHR led by Dr. Bobby Henry. Within the Ontario NEIHR, FPWC is working with research partners from the “Healing from Trauma and Reducing Addictions” group. Some of the ongoing work of this group includes “Conversations with Indigenous Psychologists: Navigating Trauma on the Front Lines of Care in Communities”. This work follows OCAP principles, as well as other Indigenous research ethics, to conduct podcast sessions with Indigenous psychologists to identify challenges and successes they encounter working in Indigenous communities. This group is also working towards the creation of a manual to address Indigenous health and wellbeing through the guidance of community members in British Columbia, Saskatchewan and Ontario.
Other work in the Ontario NEIHR focused on strategies to address suicide prevention, build life promotion activities and respond to crisis for First Nation workforce. FPWC continues to partner with University of Toronto (Dr. Jeffrey Ansloos and his lab) and the Centre for Addictions and Mental Health (Dr. Rene Linklater and Shkaabe Makwa) to collect further evidence on innovative community practices related to complex crisis response including loss from premature unnatural death.
FPWC continues to act as a community partner with the Anishinabek Nation and McMaster University on the development of a First Nation dementia assessment tool. This work, led by Dr. Jennifer Walker, seeks to pilot the tool for reliability and validity and support uptake by the First Nation workforce. FPWC’s role includes supporting learning about dementia and offering subject matter expertise on mental wellness as it relates to dementia. Continued research on the Aanish Naa Gegii: the Children’s Health and Well-being Measure (ACHWM) to determine it as an early intervention tool with Dr. Nancy Young (CHEO) is also another research project that FPWC supports as a community partner.
WORKING GROUPS AND COMMITTEES
Working Groups
- Co-chair of the First Nations Mental Wellness Continuum Framework (Framework) Implementation Team and Secretariat
- Member co-chair of the Assembly of First Nations Mental Wellness Committee
- Co-chair of the Mental Wellness Task Group for the COVID-19 Public Health Working Group on Isolated and Remote Communities
- Member of the Framework Orientation Working Group
- Member of the First Nations Mental Wellness Data Working Group and planning subcommittee
- Member of Indigenous Services Canada Mental Wellness Evaluation Working Group
- Member of the KDE Hub Resource Collaborative on Mental Health Promotion
- Member of the Canadian Network of School Mental Health Leadership group
- Steering Committee Member of the Mental Health Inequities report (led by Public Health Agency of Canada)
Total Working Groups: 16
- Member of the Mental Health and Substance Use Standards Collaborative and co-chair of Integrated Youth Services Working Group (led by Standards Council of Canada)
- Member of Provincial Indigenous Clinical Advisory Table - Depression and Anxiety Related Disorders (led by Ontario’s Mental Health and Addictions Centre of Excellence)
- Co-chair of Culturally Adapted Social Emotional Learning Advisory Table
- Member of Thunderbird Partnership Foundation’s Life Promotion Working Group
- Co-chair Indigenous School Mental Health Advisory Circle
- Member of Canadian Academy of Health Sciences Indigenous Health Human Resource subcommittee
- Member of 988 Advisory Committee
CONFERENCES AND PRESENTATIONS 2022-2023
- Youth Policy Hackathon on the First Nations Mental Wellness Continuum Framework: Overview of the First Nations Mental Wellness Continuum Framework
- National Summit on Indigenous Mental Wellness: Plenary Panel on Workforce Wellness; Concurrent session on The First Nations Mental Wellness Continuum Framework; Poster session on Northern Public Health Working Group on Indigenous Mental Wellness
- First Nations Health Managers Association National Conference: Keynote speaker on strategies and recommendations for supporting Workforce Wellness
- First Nations Substance Use Summit: Opening Address
- Assembly of First Nations Special Chiefs Assembly: Life Promotion & Suicide Prevention
- COVID-19 Public Health Working Group on Isolated and Remote Communities: Workforce Wellness and Family Violence Prevention
- Health Science North: Cultural Safety presentation to Board of Directors (x2)
- Government of Canada: Belonging - A Relational Experience of Wellbeing (with Dr. William Mussell)
- United Nations Committee on the Rights of the Child: Key Reflections
- Expert Witness at the Devon Freeman Inquest
- New Brunswick Psychologists: Cultural Safety and Supporting Indigenous Wellbeing
- School Mental Health: Indigenous Network Circle - Overview of FPWC services
- FPWC FCLS series: Western Doorway Healing Journey Part 1 & 2
- Toronto School Board: Indigenous Education from Theory to Change
- New Brunswick MWT Gathering: Beyond Yoga and Meditation, Wellbeing in the Workforce
- AFN Education Forum: Student wellness for First Nation children and youth
- Kinoomaadziwin Education Body: Building Hope Through the Lessons of Our Ancestors
- Guest Host: Mino Biimadzawi Thunderbird Podcast on Healing from Trauma
- Saskatchewan Health Partners meeting: MWTF Life Promotion and Suicide Prevention report
- Council of Yukon First Nations keynote on Culture to Address Indigenous Trauma
- Ontario Police Recruitment Officer: Indigenous wellbeing
- Quebec Health and Social Service Commission: Overview of FPWC program and services
- Anishinabek Nation: Coping During the Holidays
- Federation of Sovereign Indigenous Nations Community Wellness Conference
- AFN Chiefs Committee on Health: MWTF Life Promotion and Suicide Prevention report
- Southern Chief’s Organization Crisis Response Team gathering: Wellbeing in the Workforce
- Atlantic Policy Congress Keynote: The Land is a Source of Life and Healing
- Public Health Working Group and ISC Senior Management Committee presentations on MWTF reports Worker wellness and Family Violence
- Interview with Xero Accounting Software
Events and Meetings
- United Nations Committee on the Rights of the Child
- National Dialogue on Data to Address Anti-Indigenous Racism in Canada’s Health Systems
- Ontario Network Environments for Indigenous Health Research (NEIHR) Annual Symposium
- International Initiative for Mental Health Leadership Exchange
First Nations Health Managers Association National Conference
National Gathering for Unmarked Burials
Northwest Territories/Nunavut (NT/NU) Council of Friendship Centres
Southern Chiefs’ Organization Mobile Crisis Response Team Wellness Gathering
First Nations Mental Wellness and Community Safety Planning
Chiefs of Ontario 17th Annual Health Forum
National Gathering for Unmarked Burials
First Nations Substance Use Summit
Assembly of First Nations Mental Wellness Committee Meeting
New Brunswick Mental Wellness Team’s Regional Gathering
Federation of Sovereign Indigenous Nations Community Wellness Conference: Empowering Communities for a Healthier Tomorrow
Victoria, BC
Vancouver, BC
Edmonton, AB
Winnipeg, MB
Toronto, ON
Mississauga, ON
Ottawa, ON
Fredericton, NB
Virtual
In the upcoming year, FPWC will be focused on finalizing a number of its projects and resources. As part of our ongoing relationship with Thunderbird we will create a joint youth advisory council that will be tasked with providing guidance and advice to ensure youth voice is centered and grounded in the work of our organizations. We will also invest more human resources into the implementation of the Framework and look forward to building regional capacity that can be supported at a national level. Finally, together we will explore the creation of a National Mental Wellness Association that will define competencies and standards of care. Over the course of the year we will seek guidance and input into the cornerstones for the development of the Association and we anticipate the competencies and standards of care will provide a roadmap around training and skills development that will create a foundation for care in First Nation mental wellness.
We’re excited by the release of the Rise Above Racism campaign to address anti-Indigenous racism in the Canadian healthcare system with our sister organizations, FNHMA and Thunderbird Partnership Foundation. We are geared to have discussions on how to address racism in the mental health system and what is required to build allies throughout Canada.
Our work with the mental wellness and trauma specialist workforces will continue as we introduce new tools and resources, build capacity and lift the innovation and exceptional work they do in their respective territories to improve the wellbeing of all nations. Finally, we will build our research agenda to build equity and advance evidence in Indigenous mental wellness.
Throughout the year we will be guided by our new 5-year Strategic Plan to advance our work and support discussions about renewed funding, to advance implementation of the Framework, promote systems change and build capacity and equity in the mental wellness workforce. FPWC is poised for a year of change and new adventures with the support of our partners and stakeholders.
“A reminder that systems change takes time, but change is a promised state”
— Grandmother Moon Teaching
First Peoples Wellness Circle
857 Yellek Trail, Nipissing First Nation
North Bay, ON, P1B 8G5
www.fpwc.ca
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Date: 17/02/2022 Organization of Blood Donation Camp by NSS Unit
Department of Children's University Vidyaniketan, N. S. S. Date: 17 February 2022 Blood donation camp was organized by the unit. In the time of corona epidemic, thalassemia-afflicted children are in great need of blood, for this social responsibility, the chairpersons of all the departments of the university, teachers, as well as the university staff, N. S. Volunteers of S. and some employees of the Secretariat also joined the blood donation camp and donated blood enthusiastically. In which the expert doctors and staff of blood bank of Gandhinagar Civil Hospital provided service in the university premises. Registering for blood donation, students of Children's University donating blood, N. S. S. volunteers
Registering for blood donation N. S. S. volunteers
Children's University under Azadi ka Amrit Mahotsav N. S. S. Organization of tree plantation program by the unit Date: 29/06/2022
Children's University N. S. S. Tree plantation was done by the unit on Wednesday 29/06/2020 at 05:30 pm in the university premises and outside the university. In which a total of 1000 trees of various types were planted. In which respected university Chancellor Harshad Patel Sahib and devotee poet Narsingh Mehta University Chancellor Chenatbhai Trivedi were also present and planted trees. And the General Secretary of the University and all the staff of the University and volunteers of the National Service Scheme, students joined. This program was organized under the guidance of respected Kulpatishree. Reverend Chancellor planting trees. Dr. Harshad Patel Sahib and Bhakti Narsingh Mehta University Chancellor Dr. Chetan Trivedi sir.
 
 
11th July World Population Day.
Children's University Gandhinagar N. N. S. On the occasion of World Population Day, World Population Day was celebrated in Children's University premises in a joint initiative by the Unit and Department of Social Affairs. As the expert speaker Dr. Assistant Professor of Economics, Government College of Science and Technology, Bavla. Bridgen Sureshbhai Patel was present. He delivered an interesting lecture on population growth as a matter of concern and not celebration as the number and quality of world population plays a very important role in today's development world.
On 08/07/2022, 123 students of the university and 29 faculty members of the university visited the Mahatma temple exhibition by Children's University Gandhinagar today. Students were given detailed information about digital technology by experts from different states.
University staff and volunteers at Mahatma Mandir
Yuva Madar Mohotsav, 2022 Children’s University, Date: 27/8/2022
By Children's University Student Aid, Cultural & Welfare Branch Dated: 27th August 2022 09 students from various departments of Children's University participated in category (B) in relation to the theme “Make Election Process Inclusive, Facilitated and Participatory”. In which poster design, slogans and slogans were kept as themes. Whose photos are as follows.
Children's University National Service Scheme First Special Camp Date : 01/11/2022 to 07/11/2022
A joint initiative of Children's University, Gandhinagar and Gir Foundation Indroda Prakriti Udyan, Gandhinagar organized a seven day National Seva Yojana Special Annual Camp at Aranya Udyan, Shapur from Date: 01/11/2022 to 07/11/2022. In which 25 volunteers from social work, psychology and home science subjects of the university joined the Rashtriya Seva Yojana special annual camp. In which, on the first day of the camp, a team of volunteers was given information about the camp for seven days. And introduced Shrialap Saheb, Program Officer of Gir Foundation, all the volunteers introduced themselves. Conducted a forest tour to the volunteers in the forest where they got to know about different plants, different birds, different trees and gave information about the forest to the volunteers to save the natural environment and introduced the camp site. It is man who harms nature. We need to understand our nature and culture. Pre-preparation for drama for further activities in the evening. Various experts were called and volunteers came to impart knowledge on social service, sanitation, natural environment, Prabhat Ferry, natural farming, understanding and conservation.
N. S. Special camp Aranya Udyan, Shapur Hon'ble Chancellor Dr. Harshad Patel sir, Keynote Speaker Sriramesh Tanna sir and Deputy Director of Gir Foundation Srirupak Solanki sir were present. And Director of Center of Training, Saptdhara Branch Head and University staff were present.
**Voter Awareness Rally Basan Village N. S. S. Volunteers Date: 14/11/2022**
A vote awareness rally was taken out by Rashtriya Seva Yojana volunteers from Children's University, Gandhinagar to sensitize the society about voting. In which 28 students from various departments of Psychology, Social Work and Home Science of the university joined.
Voting awareness rally at Yuva Madar Mohotsav in Shapur village Date: 15/1182022
Citizens of Gandhinagar district should be made aware of voting in celebration of the great festival of democracy being held in the state of Gujarat. A voting awareness rally was organized by the volunteers of the university in Shapurgam as part of the voting awareness program of Gujarat Assembly General Election 2022.
G20 Half Marathon Date: 28/03/2023
Children's University Gandhinagar N. N. S. A 'Half Marathon' was organized by the unit on 28/03/2023 March under the one-day G20 theme “Environment and Climate Change”. In which 45 volunteers of the university joined.
Volunteers and staff going to the rally from the university campus
NSS of Children’s University The volunteers and MSW department created awareness about corona in the vaccination camp from their residence of the volunteers.
Program-2
NSS of Children’s University the volunteers and MSW department In an effort to create awareness about Corona, a mask distribution program was organized for the villagers.
International Yoga Day
Program-4
Children's University n. S. A cleanliness campaign was organized in the premises of Ramdevpir temple and its surrounding area at S, Unit and Borij village.
Children's University, Gandhinagar N.S.S. A tree plantation program was organized in the university premises as part of the celebration of Amrit Mohotsav of Azadi by the unit.
Program-6
Fit India Freedom Run 2.0
Children’s University n. S. S. In order to develop awareness and interest towards the National Service Scheme by the unit, various questionnaires were organized through Google form on this day.
Program-8
Director of School of Accreditation of “Swachh Bharat Plow Run” University Dr. Sanjay Gupta Saheb and Director of School of Child, Youth and Family Development Dr. Rakesh Patel Saheb N. S. Program Officer Dr. Shilpa vala Children’s University, Gandhinagar N. of S. S. S. Volunteers of the unit
Registering for blood donation, students of Children's University donating blood, N. S. S. Volunteers and Hon'ble Chancellor Harshadbhai Shah Saheb and Children's University Staff
Program-10
Respected Chancellor Harshad Patel Saheb and Chairman Dr. Prashantbhai Patel N. S. S. Coordinator Dr. Shilpa vala, and University staff and volunteers
Program-11
Children's University Gandhinagar N. N. S. On the occasion of World Population Day, World Population Day was celebrated in Children's University premises in a joint initiative by the Unit and Department of Social Affairs. As the expert speaker Dr. Assistant Professor of Economics, Government College of Science and Technology, Bavla. Bridgen Sureshbhai Patel was present.
A four days u-11, u-9 Athletic meet organized on Children's University Gandhinagar and sports university Nadiad sports complex.
**Program-13**
Vidyaniketan Department Chairman and NSS. Coordinator Dr. Shilpa Wala and Vishalbhai of Forest Department informed the students about nature.
**Program-14**
Celebration of Har Ghar Tiranga Programme
“Make Election Process Inclusive, Facilitated and Participatory”. In which poster design, slogans and slogans were kept as themes. Whose photos are as follows.
Program-16
N. S. S. Reverend Chancellor Dr. in the group photo of the annual camp. Harshad Patel Saheb and Keynote Speaker Ramesh Tanna Saheb, Rupak Solanki Saheb, Director of the University, Professor Gan and Rashtriya Seva Yojana Swayamsevak
Program-17
Voter Awareness Rally Basan Village N. S. S. volunteers
Program-18
Voting Awareness Rally at Yuva Matdar Mohotsav, Shapur Village
G20 Half Marathon
Children's University Gandhinagar N. N. S. A 'Half Marathon' was organized by the unit on 28/03/2023 March under the one-day G20 theme "Environment and Climate Change". In which 45 volunteers of the university joined.
Children's University Hon. Vice Chancellor Mr. Harshad Patel Mr. Nodal Officer of G20 Dr. Dharmashu Vaidya and N. S. S. Program Officer Dr. Sculptors and volunteers
NSS of Children’s University The volunteers and MSW department created awareness about corona in the vaccination camp from their residence of the volunteers.
Program-2
NSS of Children’s University the volunteers and MSW department In an effort to create awareness about Corona, a mask distribution program was organized for the villagers.
International Yoga Day
Program-4
Children's University n. S. A cleanliness campaign was organized in the premises of Ramdevpir temple and its surrounding area at S, Unit and Borij village.
Children's University, Gandhinagar N.S.S. A tree plantation program was organized in the university premises as part of the celebration of Amrit Mohotsav of Azadi by the unit.
Program-6
Fit India Freedom Run 2.0
Children’s University n. S. S. In order to develop awareness and interest towards the National Service Scheme by the unit, various questionnaires were organized through Google form on this day.
Program-8
Director of School of Accreditation of “Swachh Bharat Plow Run” University Dr. Sanjay Gupta Saheb and Director of School of Child, Youth and Family Development Dr. Rakesh Patel Saheb N. S. Program Officer Dr. Shilpa vala Children’s University, Gandhinagar N. of S. S. S. Volunteers of the unit
Registering for blood donation, students of Children's University donating blood, N. S. S. Volunteers and Hon'ble Chancellor Harshadbhai Shah Saheb and Children's University Staff
Program-10
Respected Chancellor Harshad Patel Saheb and Chairman Dr. Prashantbhai Patel N. S. S. Coordinator Dr. Shilpa vala, and University staff and volunteers
Program-11
Children's University Gandhinagar N. N. S. On the occasion of World Population Day, World Population Day was celebrated in Children's University premises in a joint initiative by the Unit and Department of Social Affairs. As the expert speaker Dr. Assistant Professor of Economics, Government College of Science and Technology, Bavla. Bridgen Sureshbhai Patel was present.
A four days u-11, u-9 Athletic meet organized on Children's University Gandhinagar and sports university Nadiad sports complex.
**Program-13**
Vidyaniketan Department Chairman and NSS. Coordinator Dr. Shilpa Wala and Vishalbhai of Forest Department informed the students about nature.
**Program-14**
Celebration of Har Ghar Tiranga Programme
“Make Election Process Inclusive, Facilitated and Participatory”. In which poster design, slogans and slogans were kept as themes. Whose photos are as follows.
Program-16
N. S. S. Reverend Chancellor Dr. in the group photo of the annual camp. Harshad Patel Saheb and Keynote Speaker Ramesh Tanna Saheb, Rupak Solanki Saheb, Director of the University, Professor Gan and Rashtriya Seva Yojana Swayamsevak
Program-17
Voter Awareness Rally Basan Village N. S. S. volunteers
Program-18
Voting Awareness Rally at Yuva Matdar Mohotsav, Shapur Village
G20 Half Marathon
Children's University Gandhinagar N. N. S. A 'Half Marathon' was organized by the unit on 28/03/2023 March under the one-day G20 theme "Environment and Climate Change". In which 45 volunteers of the university joined.
Children's University Hon. Vice Chancellor Mr. Harshad Patel Mr. Nodal Officer of G20 Dr. Dharmashu Vaidya and N. S. S. Program Officer Dr. Sculptors and volunteers
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IMPORTANT NOTICE:
This week, Canons Fehrenbacher and Silvey are away in Italy for the Institute’s Annual General Chapter August 28-Sept 3. Rev. Fr. Dave Ireland, an associate priest of the Institute of Christ the King, will be “in residence” at the Oratory. In case of Sacramental Emergency (Last Rites), please call the Oratory office number, (520)883-4360.
Pray for your Priests of the Institute of Christ the King!
PLEASE NOTE THE SPECIAL SCHEDULE THIS WEEK DUE to the CANONS’ ABSENCE:
Sunday-Wednesday, Aug 28-31
Usual Mass & Confession Schedule, See pg. 2
First Thursday, Sept 1
5:00pm: Eucharistic Adoration with Prayers for Priests, Religious, & More Vocations
5:05-5:40pm: Confessions
6:00pm: Low Mass
First Friday, Sept 2
(NB: No morning Confessions, Noon Mass, or Eucharistic Adoration)
5:00-5:50pm: Confessions
6:00pm: High Mass
First Saturday, Sept 3
7:15-7:50am : Confessions
8:00am : High Mass
(No First Saturday Morning Retreat)
First Sunday, Sept 4
Regular Mass schedule
6:00pm: Solemn Sunday Vespers
Friday, Sept. 9th
Society of the Sacred Heart Meeting
6:00pm Spiritual Talk
“Introduction to the Devout Life Part II”
6:45pm Potluck Dinner
7:30pm Sung Compline in the church
Men of the Holy League
Thurs, Sept 15th
Conference Topic:
How Our Lady will make you a better man!
5:00pm Eucharistic Adoration, Benediction & Confessions
6:00pm Low Mass followed by 15-min Conference
Dinner will be provided. BYOB and cigars.
All men 18 and over are invited.
PLEASE RSVP by email or Flocknote by Sept. 11th
Saint Gianna Oratory
Extraordinary Form of the Roman Rite,
“Traditional Latin Mass”
Mailing Address: Saint Gianna Oratory
P.O. Box 87350, Tucson, AZ 85754
Telephone: (520) 883-4360
Office Hours: Wed & Fri 10am – 4pm
(NB: St. Gianna Oratory office is not located at the church)
Email: firstname.lastname@example.org
Oratory Staff
Canon Jonathon Fehrenbacher, Rector
Canon Bryan Silvey, Vicar
Mrs. Teri Gauger, Oratory Secretary
Mr. Matthew Lancaster, Music Director
Website & Online Bulletin: saintgianna.net
“Join our Flocknote” from our website to receive email updates on other important information.
FOR DONATIONS:
1) Please write check to Institute of Christ the King and mail or drop into the collection.
2) or donate securely using the DONATE button on our website
Sun. 8/28
8:30am Low Mass
10:30am High Mass
5:00pm Low Mass
ST. AUGUSTINE (PATRON OF DIOCESE OF TUCSON) / 1st class / White
Mass (In medio): Gloria, Comm. of 12th Sunday after Pent. & pro Papa, Credo, Common Preface, Last Gospel of 12th Sunday after Pent.
Mon. 8/29
5:30pm Low Mass
Beheading of St. John the Baptist / 3rd class / Red
Mass (Loquebar): Gloria, Comm. of St. Sabina & pro Papa, Com. Preface
Tue. 8/30
8:00am Low Mass
St. Rose of Lima, Virgin / 3rd class / White
Mass (Dilexisti): Gloria, Comm. of Ss. Felix and Adauctus & pro Papa, Common Preface
Wed. 8/31
8:00am Low Mass
St. Raymond Nonnatus, Confessor / 3rd class / White
Mass (Os justi): Gloria, Comm. pro Papa, Common Preface
Wednesday Devotions to St. Joseph
1st Thur. 9/1
5:00pm Adoration
6:00pm Low Mass
Votive Mass of Jesus Christ Sovereign Priest / 3rd class / White
Mass (Juravit): Gloria, Comm. of St. Gilles & pro Papa, Pref. of the Cross
1st Fri. 9/2
6:00pm High Mass
Abstinence
Votive Mass of the Sacred Heart / 3rd class / White
Mass (Cogitationes): Gloria, Comm. of St. Stephen & pro Papa, Preface of the Most Sacred Heart
1st Sat. 9/3
8:00am High Mass
Votive Mass of the Immaculate Heart / 3rd class / White
Mass (Adeamus): Gloria, Comm. of St. Pius X & pro Papa, Pref. of B.V. Devotion to Our Lady of Sorrows
1st Sun. 9/4
8:30am Low Mass
10:30am High Mass
5:00pm Low Mass
6:00pm Vespers
13TH SUNDAY AFT. PENTECOST / 2nd class / Green
Mass (Respice): Gloria, Comm. pro Papa, Credo, Pref. of Trinity
CF Canon Bryan Silvey
by Tom & Dolores Taleck
CF Pro populo
CF †Sandra & Tony Molina
by Frank & Lisa De La Ossa
FI Canon Fehrenbacher
by Jackie Fehrenbacher
CS Kathleen R. Hart
by Colette Markham
FI Melanie Mullen
by Bobbie Mullen
CS †Anita Davis
by Lisa De La Ossa
CS Claire Theisinger
by the Gauger Family
FI †Larry Westenhaven
by Lisa De La Ossa
CS Matthew Taleck Family
by Tom & Dolores Taleck
FI Richard & Diana Maas
by Dean & Arden Maas
CS Matthew Taleck Family
by Tom & Dolores Taleck
FI Amy Maas
by Dean & Arden Maas
CS †Margareth Lucas
by Russell & Irene Hanam
FI †Souls in Purgatory
by Lourdes Orozco
CS Intentions of Prior General
by Canon Silvey
CS †Charlene Gauger
by the Gauger Family
CS Pro populo
CS †John Allechorne
by Angela Jamison
CONFessions TIMES THIS WEEK
Sun, 8/28
8:00-8:20am
9:45-10:20am
4:30-4:50pm
Thurs, 9/1
5:05-5:40pm
Fri, 9/2
5:00-5:50pm
Sat, 9/3
7:15-7:50am
Sun, 9/4
8:00-8:20am
9:45-10:20am
4:30-4:50pm
Please Remember in Your Prayers:
Deceased: Rosemary Shillue; Rose Coneeny; Mitchell Awana; John & Agnes Pfeiffer; Peter Meis; Daniel Mullen; John Ward
Healing: Donald Perkins; Shirley Louie; Gregory Schneider; Joseph Wypych, Jr.; Marlene Luhr O’Connor; Greg & Sadie Schuller; Ruby Wilson; Thaddeus Stypa; Jerry & Lassie Lewis; Maureen LoManto; Nancy Gorman; William Linley; Steve Shikles; Joe De La Fuente; Deborah Schultz; Bayleyn Maldonado; Deana Lewis; Tom Atwood; Swift Burch; Andy Stropko; Canon Fragelli
From the Rector’s Desk:
My Dear Faithful,
I strongly encourage everyone to make the Devotions of the 1st Fridays and 1st Saturdays both in reparation for the many sins committed against the Sacred Heart of Jesus and the Immaculate Heart of Mary and because of the wonderful promises attached to these devotions.
**1st FRIDAY PROMISES OF THE SACRED HEART:**
1. I will give them all the graces necessary for their state in life.
2. I will establish peace in their families.
3. I will comfort them in their trials.
4. I will be their secure refuge during life, and, above all, in death.
5. I will shed abundant blessings on all their undertakings.
6. Sinners will find in My Heart an infinite ocean of mercy.
7. Lukewarm souls will become fervent.
8. Fervent souls will rapidly grow in holiness and perfection.
9. I will bless every place where an image of My Heart shall be exposed and honored.
10. I will give to priests the gift of touching the most hardened hearts.
11. The names of those who promote this devotion will be written in My Heart, never to be blotted out.
12. I promise thee, in the excessive mercy of My Heart, that My all-powerful love will grant to all those who receive Holy Communion on the First Friday of nine consecutive months, the grace of final penitence; they shall not die in My disgrace nor without receiving their Sacraments; My Divine Heart shall be their safe refuge in this last moment.
**CONDITIONS FOR THE 1st FRIDAY DEVOTION:**
The specific conditions to receive the Great Promises of the Sacred Heart as given to St. Margaret Mary Alacoque are:
1. Receive Holy Communion on 9 consecutive 1st Fridays of the month (this assumes that the person is in a state of grace, having made a sacramental confession for any mortal sins prior to receiving communion).
2. Having the intention, at least implicitly, of making reparation to the Sacred Heart for all the sinfulness and ingratitude of men.
**FIVE 1st SATURDAYS OF REPARATION TO THE IMMACULATE HEART OF MARY & 4 CONDITIONS:**
Our Lady revealed to Sr. Lucia, one of the Fatima seers: “Look My daughter, at my heart, surrounded with thorns with which ungrateful men pierce me at every moment by their blasphemies and ingratitude. You, at least, try to console me, and announce in my Name that I promise to assist at the hour of death with all the graces necessary for salvation, all those who on the 1st Saturdays of 5 consecutive months:
1) confess*,
2) receive Holy Communion,
3) recite the Rosary, and
4) keep me company for fifteen minutes while meditating on the fifteen mysteries of the Rosary with the intention of making reparation to me.”
*NB: Confession may be a few days before or after the 1st Saturday; so long as Communion is received in a state of grace.
Our Lord later explained to Sr. Lucia that the reason for the five Saturdays is because of the five types of offenses and blasphemies committed against the Immaculate Heart of Mary:
1. Blasphemies against the Immaculate Conception.
2. Blasphemies against her Perpetual Virginity.
3. Blasphemies against her Divine Maternity, refusing at the same time to recognize her as the Mother of men.
4. The blasphemies of those who publicly seek to sow in the hearts of children indifference, scorn, or even hatred of the Immaculate Mother.
5. The offenses of those who outrage her directly in her holy images.
In the Sacred Heart of Christ our King & the Immaculate Heart of Mary our Queen,
Canon Jonathon Fehrenbacher
Upcoming Events
- Sept 9 Society of the Sacred Heart Meeting
- Sept 10 Catechism classes begin
- Sept 11 2022-2023 Events Planning Meeting
- Sept 14 Exaltation of the Holy Cross
- Sept 15 Men of the Holy League (Resumed)
- Sept 25 Michaelmas Outing on Mt. Lemmon
- Sept 29 St. Michael Archangel
- Oct 3 St. Therese of Lisieux
- Oct 9 “Maternity of Our Lady” Tea Party
2022 - 2023 Events Planning Meeting
Sunday, Sept 11 @ 12Noon
Open to all volunteers willing to help us plan and organize events for the upcoming year.
Thought from St. Francis de Sales:
In the opinion of the great Saint Thomas Aquinas, it is not expedient to consult much and deliberate long about an inclination to enter a good and well-regulated religious order. It is sufficient to have a serious discussion with a few people who are truly prudent and capable in such matters. They will be able to help us come to a simple, sure answer to our question. But as soon as we have deliberated and decided, we must be firm and unchanging; we must never let ourselves be shaken by any hint whatsoever of a greater good.
(T.L.G. Book 8, Ch. 11; O. V, p. 95)
St. Augustine, Bishop, Confessor, Doctor of the Church (Comm. of the 12th Sunday after Pentecost)
Introit: Ecclus 15:5 In the midst of the assembly he opened his mouth; and the Lord filled him with the spirit of wisdom and understanding; He clothed him with a robe of glory. Ps 91:2 It is good to give thanks to the Lord, to sing praise to Thy name, Most High. Glory be….In the midst of the assembly….
Collect: Give heed to our humble prayers, almighty God, and through the intercession of blessed Augustine, Thy Confessor and Bishop, kindly grant Thine oft-given mercy to those upon whom Thou bestow great hope in Thy forgiveness. Through Jesus Christ.
Collect (12th Sunday after Pent): O Almighty and merciful God, of Whose gift it cometh that Thy faithful do unto Thee worthy and laudable service: grant us, we beseech Thee, that we may run without stumbling towards the attainment of Thy promises. Through our Lord…
Lesson: 2Tim. 4:1-8 Beloved: I charge you, in the sight of God and Christ Jesus, Who will judge the living and the dead by His coming and by His kingdom, preach the word, be urgent in season, out of season; reprove, entreat, rebuke with all patience and teaching. For there will come a time when they will not endure the sound doctrine; but having itching ears, will heap up to themselves teachers according to their lusts, and they will turn away their hearing from the truth and turn aside rather to fables. But be watchful in all things, bear with tribulation patiently, work as a preacher of the Gospel, fulfill your ministry. As for me, I am already being poured out in sacrifice, and the time of my deliverance is at hand. I have fought the good fight, I have finished the course, I have kept the faith. For the rest, there is laid up for me a crown of justice, which the Lord, the just Judge, will give to me in that day; yet not to me only, but also to those who love His coming.
Gradual: Ps.36:30-31 The mouth of the just man tells of wisdom, and his tongue utters what is right. The law of his God is in his heart, and his steps do not falter.
Alleluia: Ps 88:21 I have found David, My servant; with My holy oil I have anointed him. Alleluia.
Gospel: Matt 5:13-19 At that time, Jesus said to His disciples: “You are the salt of the earth; but if the salt loses its strength, what shall it be salted with? It is no longer of any use but to be thrown out and trodden underfoot by men. You are the light of the world. A city set on a mountain cannot be hidden. Neither do men light a lamp and put it under the measure, but upon the lampstand, so as to give light to all in the house. Even so let your light shine before men, in order that they may see your good works and give glory to your Father in heaven. Do not think that I have come to destroy the Law or the Prophets. I have not come to destroy, but to fulfill. For amen I say to you, till heaven and earth pass away, not one jot or one tittle shall be lost from the Law till all things have been accomplished. Therefore whoever does away with one of these least commandments, and so teaches men, shall be called least in the kingdom of heaven; but whoever carries them out and teaches them, he shall be called great in the kingdom of heaven.
Offertory: Ps 91:13 The just shall flourish like the palm tree; like a cedar of Libanus shall he grow.
Secret: May the loving prayer of blessed Augustine, Thy Bishop and Doctor, fail us never, O Lord; may it commend our offerings and ever secure for us Thy forgiveness. Through Jesus Christ.
Secret (12th Sunday after Pent): Graciously look upon the offerings, we beseech Thee, O Lord, which we present upon Thine altar: that while they obtain pardon for us, they may give honor to Thy name. Through Our Lord.
Communion: Luke 12:42 The faithful and prudent servant whom the master will set over his household to give them their ration of grain in due time.
Postcommunion: So that Thy sacrificial rites may grant us salvation; we pray Thee, O Lord, that blessed Augustine, Thy Bishop and illustrious teacher, may draw nigh as our intercessor. Through Jesus Christ.
Postcommunion (12th Sunday after Pent): May the holy reception of this mystery quicken us, we beseech Thee, O Lord: and may it win for us both pardon and protection. Through our Lord...
Last Gospel (12th Sun after Pent): Lk. 10: 23-27 At that time, Jesus said to His disciples: Blessed are the eyes that see the things which you see. For I say to you, that many prophets and kings have desired to see the things that you see, and have not seen them; and to hear the things that you hear, and have not heard them. And behold a certain lawyer stood up, tempting Him, and saying: Master, what must I do to possess eternal life? But He said to him: What is written in the law? How readest thou? He answering, said: Thou shalt love the Lord thy God with thy whole heart, and with thy whole soul, and with all thy strength, and with all thy mind; and thy neighbor as thyself. And He said to him: Thou hast answered rightly: this do, and thou shalt live. But he, willing to justify himself, said to Jesus: And who is my neighbor? And Jesus answering, said: A certain man went down from Jerusalem to Jericho, and fell among robbers, who also stripped him, and having wounded him went away, leaving him half dead. And it chanced that a certain priest went down the same way, and seeing him, passed by. In like manner also a Levite, when he was near the place and saw him, passed by. But a certain Samaritan being on his journey, came near him, and seeing him, was moved with compassion, and going up to him, bound up his wounds, pouring in oil and wine; and setting him upon his own beast, brought him to an inn, and took care of him. And the next day he took out two pence, and gave to the host, and said: Take care of him, and whatsoever thou shalt spend over and above, I, at my return, will repay thee. Which of these three, in thine opinion, was neighbor to him that fell among robbers? But he said: He that showed mercy to him. And Jesus said to him: Go and do thou in like manner.
Prayers of St. Augustine
Too late have I loved you, O Beauty so ancient, O Beauty so new. Too late have I loved you! You were within me but I was outside myself, and there I sought you! In my weakness I ran after the beauty of the things you have made. You were with me, and I was not with you. The things you have made kept me from you – the things which would have no being unless they existed in you! You have called, you have cried, and you have pierced my deafness. You have radiated forth, you have shined out brightly, and you have dispelled my blindness. You have sent forth your fragrance, and I have breathed it in, and I long for you. I have tasted you, and I hunger and thirst for you. You have touched me, and I ardently desire your peace. Confessions, X, 27, 38
Breathe in me, O Holy Spirit, That my thoughts may all be holy.
Act in me, O Holy Spirit, That my work, too, may be holy.
Draw my heart, O Holy Spirit, That I love but what is holy.
Strengthen me, O Holy Spirit, To defend all that is holy.
Guard me, then, O Holy Spirit, That I always may be holy. Amen.
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ARM-FPGA-based platform for reconfigurable wireless communication systems using partial reconfiguration
Mohamad-Al-Fadl Rihani, Mohamad Mroue, Jean-Christophe Prévotet, Fabienne Nouvel, Yasser Mohanna
To cite this version:
Mohamad-Al-Fadl Rihani, Mohamad Mroue, Jean-Christophe Prévotet, Fabienne Nouvel, Yasser Mohanna. ARM-FPGA-based platform for reconfigurable wireless communication systems using partial reconfiguration. EURASIP Journal on Embedded Systems, 2017, 2017 (1), pp.35. 10.1186/s13639-017-0083-9. hal-01684551
HAL Id: hal-01684551
https://univ-rennes.hal.science/hal-01684551v1
Submitted on 22 Jun 2018
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Distributed under a Creative Commons Attribution 4.0 International License
ARM-FPGA-based platform for reconfigurable wireless communication systems using partial reconfiguration
Mohamad-Al-Fadl Rihani\textsuperscript{1,2,*}, Mohamad Mroue\textsuperscript{2}, Jean-Christophe Prévotet\textsuperscript{1}, Fabienne Nouvel\textsuperscript{1} and Yasser Mohanna\textsuperscript{3}
Abstract
Today, wireless devices generally feature multiple radio access technologies (LTE, WIFI, WiMAX, ...) to handle a rich variety of standards or technologies. These devices should be intelligent and autonomous enough in order to either reach a given level of performance or automatically select the best available wireless technology according to standards availability. On the hardware side, system on chip (SoC) devices integrate processors and field-programmable gate array (FPGA) logic fabrics on the same chip with fast inter-connection. This allows designing software/hardware systems and implementing new techniques and methodologies that greatly improve the performance of communication systems. In these devices, Dynamic partial reconfiguration (DPR) constitutes a well-known technique for reconfiguring only a specific area within the FPGA while other parts continue to operate independently. To evaluate when it is advantageous to perform DPR, adaptive techniques have been proposed. They consist in reconfiguring parts of the system automatically according to specific parameters. In this paper, an intelligent wireless communication system aiming at implementing an adaptive OFDM-based transmitter and performing a vertical handover in heterogeneous networks is presented. An unified physical layer for WIFI-WiMAX networks is also proposed. The system was implemented and tested on a ZedBoard which features a Xilinx Zynq-7000-SoC. The performance of the system is described, and simulation results are presented in order to validate the proposed architecture.
Keywords: FPGA, SoC, Partial reconfiguration, Adaptive technique, Vertical handover algorithm
1 Introduction
In the last decade, wireless communication systems have greatly evolved in terms of mobility, covered range, and throughput. A lot of standards with different specifications, both in the PHY (bandwidth, throughput, and modulation encoding techniques) and MAC layers, have been provided to meet different technical requirements and give access to new services. In this context, it has become very interesting to consider a multi-standards device, capable of implementing several MAC/PHY layers within the same chip. In general, this is performed by implementing several radio access technologies, in parallel, within the same chip. This solution is obviously very costly and not satisfactory in terms of hardware resources usage. Moreover, only few protocols can be handled in this case.
Today, users are facing a huge diversity of communication networks and protocols that are generally very complex and heterogeneous. This is especially true for mobile devices that have to deal with multiple radio access technologies (Multi-RAT), during their mobility.
Adaptive techniques enable applying modifications in real-time to both PHY or MAC layers of a wireless system. Using these techniques, modifications are performed according to specific conditions and to the state of the communication channel within the overall network. This allows achieving the best performance by adapting and reconfiguring the communication system in real-time without interruption. The operation of switching...
between radio access technologies is denoted as vertical handover.
Hardware reconfiguration of wireless communication systems is the most interesting solution for implementing adaptive techniques and vertical handover algorithm (VHA). In this case, some system functions may be modified during runtime, while other functions continue to run without any interruption. Field-programmable gate arrays (FPGAs) constitute the ideal circuits to implement such reconfigurable systems. Such devices are now sufficiently mature to implement very complex systems with a high level of performance. Partial reconfiguration (PR) is one of the interesting features that has been added by FPGAs’ vendors to ensure even more flexibility. Furthermore, partial reconfiguration decreases the time needed to reconfigure parts of the circuit and reduces its power consumption by considering only partial bit-streams instead of complete ones.
Another interesting feature in recent FPGA devices is the presence of embedded hard processor cores that are implemented with the hardware FPGA fabric, in the same chip. For example, the ZYNQ SoC devices from Xilinx feature a dual-core ARM Cortex-A9 based Processing System (PS) as well as a programmable logic (PL) within a single device. Compared to their soft-core processor counterparts, these processors offer much more computing power and speed. SoC devices are appropriate for designing joint software and hardware (SW/HW) systems. The existence of such systems in the end devices allows designing high-performance smart communication objects.
In this work, we present an ARM-FPGA-based platform for reconfigurable wireless communication systems that benefits from the partial reconfiguration technique. The baseband functions of the wireless system are implemented within the FPGA fabric, whereas the reconfiguration of the different functional blocks is managed by processes running on the ARM processor. The role of these processes is to take decisions and manage the reconfiguration process of the concerned modules. A custom micro-kernel that is dedicated to partial reconfiguration [1] is used to schedule and share resources among processes.
The main contributions of the paper are as follows:
1. Designing an original FPGA reconfiguration manager based on a custom micro-kernel that concurrently executes several independent tasks.
2. Proposing a vertical handover algorithm based on a scoring system that makes it possible to switch between two standards according to predefined metrics.
3. Quantitative evaluation of the system performance based on a case study.
This paper is organized as follows: Section 2 deals with the related works on reconfigurable radio systems using the partial reconfiguration technique, vertical handover algorithms for heterogeneous (Multi-RAT). Section 3 describes the general system model, i.e., the proposed SW/HW platform for reconfigurable wireless systems. In Section 4, an implementation study of an adaptive reconfigurable OFDM transmitter is provided. In Section 5, VHA in WIFI-WIMAX networks is applied to the proposed system. Section 6 presents the experimental results and demonstrates the feasibility of the proposed approach. Finally, we conclude the paper in Section 7.
2 Background and related works
This section discusses background concepts and related works in the context of reconfigurable radios and adaptive techniques. The use of PR in reconfigurable radios, as well as VHAs for heterogeneous networks, is also described in this section.
2.1 Adaptive techniques
Increasing the performance of wireless communication systems has always been one of the first objectives of designers. Due to the characteristics of wireless channels (path loss, fading, shadowing ...), the multiplicity of standards, frequency allocations, and mobility features provided by wireless devices, the operating environment has become more and more complex to comprehend.
In this context, researchers have proposed adaptive mechanisms to allow wireless systems to adapt waveforms according to the channel properties. Such systems may sense, learn, and decide to reconfigure themselves dynamically. Various low-level parameters such as the received signal strength indicator (RSSI), signal-to-noise ratio (SNR), and bit error rate (BER) have been used to guarantee adaptability. Other high-level parameters, such as resource allocation, quality of service (QoS), and power consumption, have also been investigated to decide and appropriately adapt the system to the environment in real-time. The main benefit of the adaptive techniques consists in maximizing the channel capacity while minimizing the power consumption.
Adaptive modulation is one of the techniques that has been proposed to set up the best constellation scheme according to the channel conditions [2–4]. Adaptive channel encoding and code rate is another adaptive technique that has been proposed to select the best encoder or the code rate according to the channel status, as presented in [5–7].
Other algorithms and methodologies have also been proposed to deal with bandwidth adaptation. In this case, the system is able to adapt the bandwidth according to
the spectrum status. For example, in OFDM systems, fast Fourier transforms (FFT) and sub-carrier mapper modules can be adapted according to parameters provided by the device and network, as presented in [8] and [9]. In [10] and [11], the authors show that it is crucial to adapt the FFT size with respect to power consumption. These two papers describe how power consumption increases as the FFT size increases. These different studies show that many parameters may be taken into account in an adaptive system. In our work, we consider multiple adaptive algorithms that are operating in parallel in order to reconfigure several modules in a wireless system. The SW/HW platform proposed in this paper aims at managing and scheduling multiple processes based on adaptive algorithms to decide when partial reconfiguration should be applied to hardware.
2.2 Reconfigurable radios using PR
Numerous studies that were proposed for reconfigurable wireless communication systems and cognitive radio (CR) have already taken the advantage of the partial reconfiguration technique in FPGAs. In [12], a review of these techniques in wireless communication systems is presented. The authors suggest benefiting from partial reconfiguration to design and implement a Multi Carrier Code Division Multiple Access (MC-CDMA) system which combines both OFDM and CDMA without presenting the technical details of the proposed system.
In [13] and [14], the authors propose M-Phase Shift Modulation (M-PSK) and M-Quadrature Amplitude Modulation (M-QAM) modems implemented in FPGA. These modems are implemented with reconfigurable modulation and demodulation modules based on the partial reconfiguration technique for software-defined radio (SDR) and CR applications. Also, in [15], the author continued his work by proposing a partially reconfigurable OFDM transmitter. The DPR technique is applied by reconfiguring the modulation and encoding modules. In this work, a microblaze soft-core processor implemented in FPGA has been used to manage the PR process. In [16], the authors propose a full reconfigurable OFDM transmitter, in which most of the modules (modulator, encoder, and FTT) of the OFDM are partially reconfigured. However, they do not describe how partial reconfiguration is managed and controlled in real-time. Also, they do not explain under which conditions the system decides to apply the PR process.
In [17], a similar work based on the DPR concept is discussed. It consists in applying DPR on the modulation and encoder modules of the IEEE 802.11g physical layer. Nevertheless, the authors do not describe how they manage the PR process and do not mention the required real-time control.
In [18], the authors describe an adaptive reconfigurable transmitter for OFDM-based cognitive radio. In this transmitter, the modulation module is adapted according to the SNR value. The authors implement a simple configuration controller but do not describe how the bitstream is transferred to the FPGA. Moreover, it is not clear whether the system can run multiple adaptive processes in parallel or not.
The authors in [19] and [20] benefit from the PR technique to propose reconfigurable radio systems. PR management is controlled by a microblaze soft processor implemented in FPGA with an Internal Configuration Access Port (ICAP) controller. In this case, additional resources in the FPGA are used for both the microblaze processor and for the ICAP IP. In our proposed system, we are using the ARM embedded core and the Processor Configuration Access Port (PCAP) interface is used instead of ICAP. In this case, no additional resources in the FPGA are required.
2.3 VHAs for heterogeneous networks
In the context of vertical handover in heterogeneous networks, several works can be mentioned. In [21], the authors proposed an algorithm composed of two steps. In the first step, the handover is triggered according to the data rate requested by the user. Before starting the handover, the system evaluates the speed of the node. If the speed is higher than a certain threshold that does not allow benefiting efficiently from switching to another system, the handover is canceled and considered as unnecessary. Otherwise, if the speed is appropriate, the available networks are compared according to five parameters: the bandwidth, jitter, delay, cost, and bit error rate. Then, the best standard is selected and the vertical handover is performed if necessary.
The authors in [22] propose an adaptive network scanning algorithm in the context of heterogeneous wireless networks. In this paper, the main idea is to prevent unnecessary scanning processes. The power consumption is then reduced. The device speed is the main parameter that the algorithm considers to adapt the scanning period. A speed limit is defined for every wireless standard.
In [23], the authors propose a vertical handover algorithm between LTE and WLAN consisting of three steps. The first step aims to initiate the handover based on RSS (received signal strength). In the second step, a fuzzy logic system compares four parameters provided by the two networks (bandwidth, SNR, battery life, and network load) to decide which network provides the best connectivity. In the third step, a seamless vertical handover is executed.
Based on the signal to interference plus noise ratio (SINR), the authors in [24] propose a vertical handover between WIFI and WIMAX. According to a custom mathematical function, the equivalent SINR value for each
network is computed and compared. The handover decision is based on the best equivalent SINR value.
In the context of creating a unified architecture for two standards, interesting studies for WIMAX and WIFI systems are proposed in [25–27]. The similarities and differences between WIMAX and WIFI physical layers are shown in these articles. The studies describe how WIMAX and WIFI physical layers are quite similar in their global architecture with only few differences in specific modules. Note that it can be appropriate to apply the PR technique to switch between these two standards by considering only these specific modules.
In our work, we aim to provide a complete study for using the PR technique on ARM-FPGA systems in the context of reconfigurable radios. This article briefly explains the tasks and modules that are executed on the processor, and how partial reconfiguration is managed. All the proposed tasks run on top of a light and custom micro-kernel dedicated to partial reconfiguration. We will also discuss more about the PR design for reconfigurable architectures and focus on the switching between multiple wireless standards. In addition to evaluating the needed reconfiguration time and reserved resources of the proposed reconfigurable architecture, we will also estimate the additional power consumption due to the reconfiguration process.
3 General system model
The proposed system can be divided into two parts: the first part is running on the ARM processor, whereas the second part is executed in the FPGA logic. The general system design is presented in Fig. 1.
3.1 Overview for ARM-FPGA platform
The ARM-FPGA platform is based on the Zynq-7000 device. This SoC integrates both software (PS) and hardware (PL) parts within the same chip. The PL part, which is equivalent to a classic FPGA fabric, is ideal for implementing high-speed logic arithmetic and data flow subsystems. On the other hand, the PS part supports software algorithms and operating systems. A high-speed connection between both parts is achieved using the Advanced Extensible Interface (AXI) interconnection [28].
Partial reconfiguration can be applied to the FPGA through two interfaces. ICAP is the first interface, in which the controller is an intellectual property (IP) entity implemented in the FPGA. The second one is the PCAP interface, which enables the ARM processor to partially reconfigure the FPGA in real-time. In this case, the PS uses the Device Configuration Interface (DevCfg) integrated on the ZYNQ device. The PCAP interface is driven by a 100-MHz clock and deals with a word width of 32 bits. The theoretical throughput is 3.2 Gbit/s, but due to the speed limit of transferring bit-streams from RAM, the interface speed is limited to 1.2 Gbit/s. In our case, we use the PCAP interface for its better compatibility with software applications and because it does not require additional logic resources in the FPGA.
In addition to providing more flexibility, one of the benefits of partial reconfiguration is the cost reduction. This is achieved by implementing multiple functions within the same region of the FPGA and modifying their functionality on demand. It then allows reducing the amount
of required resources when modules are implemented concurrently.
3.2 Processing system modules
The proposed modules running on the ARM are the configuration controller, parameter provider, and hardware updater. All these modules run as tasks in the user-space of a custom micro-kernel.
3.2.1 Micro-kernel
Ker-ONE is a lightweight micro-kernel that provides paravirtualization on ARM embedded systems. In this work, it is seen as a simple kernel that may implement several isolated tasks at user level. Since Ker-ONE is very simple, it only provides fundamental functions such as round-robin scheduling, inter-process communication (IPC), and memory management. It ends up with a small trust computing base (TCB) as described in [1]. In the proposed system, multiple adaptive processes run concurrently on the top of the kernel. Each task may access the DevCfg in order to reconfigure specific hardware blocks in the PL region of the FPGA. Note that all the mechanisms that deal with reconfiguration management are implemented in different isolated tasks: the configuration controller, parameters provider, and hardware updater.
3.2.2 Configuration controller
The configuration controller has two main objectives. The first objective consists in transferring partial bit-streams to the FPGA. For additional security reasons, the partial bit-streams memory locations are only accessible from the configuration controller. This controller eliminates any conflict that may occur when several user processes decide to access the DevCfg at the same time. In this case, it transfers the bit-streams consecutively. The adaptive processes do not manage the bit transfer operations but only send requests and provide the memory addresses to the configuration controller that performs the operation.
The configuration controller module can also configure the concerned hardware modules by updating their input parameters in real-time. This operation is called parametric reconfiguration. In this case, the system reconfigures the hardware either by updating the input parameters of the concerned module or by sending a new version (bit-stream) of the reconfigurable module. As an example, we can consider the IFFT module which can be reconfigured in real-time either by modifying the IFFT size parameter or by applying PR. This enables to combine both methods of reconfiguration (partial and parametric reconfiguration) to create a reconfigurable system. Choosing the configuration method depends on the architecture of the hardware module. Another important task of the configuration controller is to control the data flow during partial reconfiguration. When a system is divided into a set of configurable modules, it is mandatory to make sure that the reconfiguration does not cause any loss of data in the reconfigurable modules during the PR process. An example of the control management is described in Fig. 2 where the second process (Process3) is requesting to modify the third module (Block3). In this case, the configuration controller suspends all the precedent modules (Block1 and Block2) that produce inputs to the reconfigured module (Block3). Note that the reconfiguration time of the concerned module is provided to the controller. This helps the controller to determine the time during which the modules should be suspended. The hardware
blocks data flow is controlled through the general purpose input output (GPIO) ports connecting the PS and PL.
3.2.3 Parameter provider
The parameter provider is another important task running on the micro-kernel. It is considered as an interface for all the parameters of the system. This task provides all the required parameters to the user processes in order to take a decision regarding the configuration of a specific module. The parameters are collected from different layers in the system.
3.2.4 Hardware updater
The third module running on the processor is the hardware updater. In this module, we benefit from one of the advantages of the partial reconfiguration that makes it possible to implement new versions of modules or even update other available modules during runtime. In a partial reconfiguration system design, reconfigurable modules are defined as black boxes with predetermined input and output ports. This means that all the versions of the reconfigurable module must have the same input and output ports.
Many partial bit-streams can be generated but only one is transferred to the FPGA at a time. The other partial bit-streams are transferred to the reconfigurable module on demand. In such designs, we have the possibility to reconfigure any reconfigurable module without reconfiguring all the hardware chain.
The task of the hardware updater is to check for any new update or new version of a reconfigurable modules. If any update is available, a module retrieves the new partial bit-stream in a secure way. The idea is similar to updating or sending patches to a software process, but applied to hardware.
3.3 Reconfigurable chain on programmable logic
On the FPGA, let us assume having a reconfigurable chain for processing wireless standards. The reconfigurable chain may be reconfigured during runtime either by transferring partial bit-streams or by parametric reconfiguration. According to the decision made by the adaptive processes, one or multiple modules are reconfigured to adapt the waveform to fit the new system status. In [29], we have proposed and compared several reconfigurable architectures to switch between multiple wireless standards. In a first approach, we have considered the full chain as an unique reconfigurable block. Switching between standards consists in transferring a single large partial bit-stream. This architecture is called one reconfigurable block architecture (ORBA). The second approach is the multiple reconfigurable blocks architecture (MRBA). In this architecture, multiple blocks of the chain are reconfigured to switch from a standard to another. As shown in [29], MRBA is better in case of switching between standards with similarities in their physical layer. On the other hand, ORBA is easier and more suitable when wireless standards have many differences in their physical layer.
3.4 Data flow control
Partial reconfiguration process needs time to be achieved which leads to an interruption in the hardware chain. Compared to the parallel implementation design, PR design decreases the overall hardware resources and power consumption. On the other hand, the reconfiguration time must be considered in PR design compared to parallel design one. The additional reconfiguration time is related to the size of the reconfigurable module. The configuration controller, proposed in our design, handles the data flow during the partial reconfiguration process as explained above. FIFOs implemented between the reconfigurable modules buffer the data flow during the PR process without causing an interruption at the upper layers. In case of switching between multiple wireless standards, there are two possible designs as explained before. In MRBA, the system is formed by multiple small reconfigurable blocks. However, in ORBA, the system includes only one large reconfigurable block. In both designs, the reconfiguration time is acceptable since the handover between multiple wireless standards depends also on signaling from the upper layers. To avoid losing any data, a FIFO buffers data from the upper layer until the PR process is achieved.
4 Auto adaptive OFDM transmitter
To study the impact of applying partial reconfiguration in the context of reconfigurable radios, we have implemented an auto-adaptive OFDM transmitter in the proposed system. The OFDM is an advanced multi-carrier modulation technique used in the new generations of fixed and mobile wireless communication systems (ex: Wifi, LTE, ...). This technique divides high-rate data streams into multiple low-rate data streams. The information is then modulated and transmitted over multiple sub-carriers.
4.1 Reconfigurable hardware
The OFDM transmitter is composed of an encoder, a modulator, a mapper, and an IFFT (see Fig. 3). Based on the Xilinx Vivado tool, multiple partial bit-streams have been generated for these modules. The different versions of the reconfigurable modules and the parameters used in the transmitter are given in Table 1. The OFDM transmitter has been tested and implemented on the ZedBoard. The data path operates on the FPGA as follows: A random bit source generator provides random data to the encoder. Then, data are encoded and
provided to the modulator in which frequency domain symbols are generated. The symbols are mapped into sub-carriers in the IFFT module through the mapper. Finally, ten OFDM symbols with the corresponding cyclic prefix are generated by the IFFT module and concatenated with pilot bits to build a frame. The frame is then ready to be transferred to the Radio Frequency (RF) module.
The reconfigurable regions on the FPGA (Pblocks) are selected using the floor-planning tool. Selecting a Pblock with an amount of resources larger than necessary leads to larger partial bit-streams. Therefore, the selected Pblocks are tuned to the maximum resource utilization that is required by the different versions of the reconfigurable modules. Figure 4 shows the floorplan design of the reconfigurable and static modules of the OFDM transmitter. As required in a PR design, the different versions of the reconfigurable modules should have the same interface (input and output ports).
For example, if a 4-QAM modulator has a 2-bit input whereas a 256-QAM modulator has an 8-bit input, then the reconfigurable modulator will match the largest module with 8-bit input. Therefore, 6 bits will be unused in the data input port of the 4-QAM. A similar concept is applied to all the reconfigurable modules in the chain. Note that these additional bits have no impact since they are likely to disappear in the optimization process of the design flow.
Figure 5 presents the adaptive OFDM transmitter implemented in the proposed platform. The modulator, encoder, and IFFT blocks are reconfigurable modules whereas the other blocks remain static. The partial bit-streams corresponding to multiple versions of each reconfigurable module are located in memory, and transferred to FPGA on demand by the configuration controller. Note that in some cases, such as for the (I)FFT architectures, the concerned module can be reconfigured by parametric reconfiguration without initiating the DPR process and transferring a bit-stream from memory. This can be applied by simply modifying the input size parameter of the module. This situation is also taken into account in the configuration controller.
### 4.2 Adaptive processes
The Xilinx SDK tool has been used to implement three adaptive processes running on the ARM processor. The processes are implemented in C code and run in parallel on top of the micro-kernel.
The first (*adaptive_mod*) process is based on the adaptive modulation technique and aims to monitor the SNR value to select the best modulation scheme. The role if this process is to reconfigure the modulation block during run-time. The second process, *adaptive_encoder*, is based on the adaptive channel coding technique. This process reads the BER and SNR values to obtain the wireless channel status in order to select the best coding rate or the efficient encoder type. This second process reconfigures the encoder module of the OFDM chain. The purpose of the third process, *adaptive_IFFT*, is to modify the IFFT size according to the power consumption and energy left in the battery of the system. It is then given the permission to access this metric from a sensor.
Based on offline experiments, we found out that this is the most power consuming module in the hardware design. This process monitors the power consumption in order to select the efficient IFFT size. The three adaptive processes are executed as user processes. In this work, we have considered a realistic scenario in which all the three processes are based on theoretical adaptive techniques and reconfigurable wireless system methodologies as proposed in [2, 7, 10].
The implemented *adaptive_mod* process can be explained as follows. The process is first initialized (for example with a value corresponding to a 4-QAM modulation) then it waits until another SNR value is received. Once it is received, it will be analyzed to check if it belongs to the current range. If the new value is within...
this range, the process returns to a waiting state. Otherwise, a new version of the modulation block is selected according to the new range. The partial bit-stream of the selected version is then transferred to the modulator. Finally, the SNR range is updated and the process waits for another SNR value.
The adaptive coding process, *adaptive_encoder*, is similar to the *adaptive_mod* process. It uses the BER parameter to select the best encoder. Similarly, the *adaptive_IFFT* process monitors the power consumption parameter of the system to select the appropriate IFFT size. This process can monitor a power regulator to read power values from the device through the parameters provider. Note that the *adaptive_mod* process and the *adaptive_encoder* process can read the latest SNR and BER values from the parameters provider at the same time.
5 Switching between WIFI and WiMax
In heterogeneous networks, during their mobility, end-node devices may detect multiple wireless standards such
as mobile broadband wireless access (3G, 3.5G, and 4G) and Wireless Local Area Network (WLAN). Each radio access technology features different specifications in terms of supported Uplink and DownLink data rate and coverage distance. For example, WIFI 802.11a supports shared data rate up to 54 Mbit/s in 100 m coverage distance. On the other hand, WIMAX supports shared data rate up to 70 Mbit/s and ranges up to 10 km. Both WIFI and WIMAX standards support the Internet Protocol (IP) that is widely used nowadays for voice, data, and video streaming. More details on both standards are given in [30].
In this section, PR was used to switch between multiple wireless standards. In the proposed scenario, an heterogeneous network composed of both WIMAX and WIFI networks is considered. An ARM-FPGA end-node features a custom VHA running on the PS part and an unified partially reconfigurable WIMAX-WIFI physical layer chain implemented in the FPGA.
### 5.1 Vertical handover algorithm
Vertical handover algorithms read different parameters to learn, study, and then decide whether to perform a vertical handover or keep communicating through the current standard. The key of taking a good decision is driven by the collected and studied parameters from the environment. The known parameters can be divided into four categories:
1. **Wireless channel parameters**: Reading parameters from the wireless channel to inform the VHA about the channel status. RSS, SNR, and BER are examples of such parameters.
2. **Network information parameters**: These parameters inform the VHA about the network status. This category includes the number of connected nodes to the access point, data rate, delay, jitter, and cost.
3. **User parameters**: These parameters reflect user’s data requirements at the application layer such as required data rate and high priority data.
4. **System parameters**: Such type of parameters provides the algorithm with the device status. These parameters may deal with power consumption, battery level, and device speed.
The proposed VHA for an WIMAX–WIFI network is composed of three stages: an Handover Trigger, an Initial Decision and a Final Decision. The algorithm identifies two execution contexts. In the first context, the system communicates through the WIMAX standard, whereas in the second case, the system is initially operating with WIFI.
The handover algorithm that switches from WIMAX to WIFI is illustrated in Fig. 6. The trigger is initiated as soon as the handover process detects a RSS_WIFI value greater than RSS_WIMAX. The Initial decision state is used to make fast decisions and detect fake handover. Fake handover is detected if the speed of the device is greater than WIFI_max_speed_limit.
If the initial decision state is successfully passed, the system goes into the final decision stage. In this final
stage, an adaptive scoring system reads multiple parameters to decide which network is the best according to the user preferences. If the scoring system decides that WIFI is better than WIMAX, then vertical handover occurs.
The handover algorithm from WIFI to WIMAX is illustrated in Fig. 7. Since the initial state is WIFI, the trigger is initiated when the handover process detects that RSS_WIMAX is greater than RSS_WIFI. The Initial Decision state explores two conditions. The first condition consists in checking if the battery level is less than the battery_low_level_limit. The second condition makes sure that RSS_WIFI is less than RSS_WIFI_limit. These two conditions should be verified; otherwise, the handover is canceled.
If the initial decision state is successfully passed, the system reaches the final decision stage. At this stage, an adaptive scoring system reads multiple parameters to decide which network is suitable according to the user application processes preferences. If the scoring system decides that WIMAX is better than WIFI, then vertical handover occurs.
An example dealing with the operation of the proposed scoring system is shown in Table 2, where each parameter is assigned different points. The scoring system operates as follows: If a standard provides a better behavior regarding a given parameter (ex. SNR, BER), then points related to this concerned parameter are added to the score of the corresponding network. For example, if the data rate parameter is assigned 3 points, and WIFI provides better throughput than WIMAX, then 3 points are added to the WIFI score. On the other hand, if the delay in WIMAX is less than that in WIFI, 4 points are added to WIMAX. Finally, the network with the highest score is selected.
Adding adaptivity to the scoring system improves the efficiency of the system. In this case, it will be possible to adapt the weight of each parameter in the scoring system according to the user preferences. As shown in Table 3, the points attributed to a given parameter may change according to the type of the running application. For example, when running a voice over IP (VoIP) application, the required data rate, delay, and jitter parameters have more weights than in case of running a browsing application.
The same concept can be applied to the power consumption parameter. In this case, the weight of this parameter may increase as the battery level decreases. Therefore, selecting the best network is not only related to the user applications requirements but also to the power status of the system.
5.2 Unified physical layer for WIFI-WIMAX
Using PR technique, we aim to design a unified reconfigurable physical layer for WIFI and WIMAX standards. In this section, we study the similarities and differences in the physical layer of the two standards. A unified reconfigurable architecture based on PR is then proposed and described in details. The corresponding design flow is also presented.
IEEE defines the PHY layer and MAC layer specifications for both WIFI and WIMAX. The physical layer of these two standards is based on the OFDM modulation.
Table 2 Example of a scoring system
| Parameter | WIFI | WiMAX |
|-----------------|------|-------|
| Data rate (3) | 3 | – |
| Delay (4) | – | 4 |
| Jitter (3) | – | 3 |
| SNR (3) | – | 3 |
| BER (3) | – | 3 |
| Power consumption (5) | 5 | – |
| Total score | 8 | 13 |
scheme. The main modules are Scrambler/Descrambler, Forward Error Correction (FEC) Encoder/Decoder, Interleaver/De-Interleaver, Mapper/De-Mapper, Pilot Guard Insertion/Removal, IFFT/FFT, and Cyclic Prefix Insertion/Removal. The differences in the transmitter architectures are illustrated in Fig. 8.
As shown in Fig. 8, the physical layer architectures of both standards are quite similar with few differences in the functionality of some modules. For example, WiMAX uses a Reed-Solomon FEC with a convolution encoder whereas WIFI uses the convolution encoder only. The differences in the receiver are similar to those in the transmitter. Based on this, it seems suitable to apply PR with the multiple reconfigurable blocks architecture (or MRBA) method.
Applying PR in the system design using MRBA requires to divide the system into two parts, static and dynamic. The static part consists of shared blocks used in both standards. During the switching process between standards, this part of the system remains unchanged. The dynamic part is composed of modules that can be reconfigured when necessary. Multiple versions of these reconfigurable modules are stored in memory.
To test the system, the choice has been made to reconfigure the Scrambler, Interleaver, FEC, and IFFT blocks in order to perform vertical handover during runtime. The configuration controller reconfigures these modules according to the VHA requests.
5.3 Unified receiver chain with adaptive scanning period
Scanning available wireless networks is important to retrieve the required information and decide which wireless standard to select. To allow implementing a unified receiver chain and scanning multiple standards within a short delay at the same time, the receiver should support reconfiguring itself rapidly to switch from a standard to another. Similar to the approach proposed in [22], an adaptive and specific scanning period has been provided to sense the available standards. In this case, a unified receiver chain is implemented in the FPGA. At a specific time, the receiver chain is reconfigured to sense the network. The sensing period is given by the adaptive scanning algorithm which directly depends on the speed of the device. After collecting some parameters, the receiver chain is reconfigured back to the initial operating standard. The VHA uses the collected parameters to decide which standard to select.
6 Experimental results
This section is divided into three parts. The first one focuses on the additional power consumption related to PR. The second part presents the results obtained from the adaptive OFDM transmitter scenario whereas the third part presents the results of the WIFI-WiMAX vertical handover scenario. In the last two parts, the results are described in terms of the time needed to reconfigure the dynamic modules, partial bit-streams size, power consumption and reserved resources by each version of the modules. Finally, a Gantt chart is presented to illustrate the behavior of the system according to the input parameters’ variations. From the obtained results, we aim to show how much hardware resources are used and evaluate the corresponding power consumption as well as the reconfiguration time.
6.1 Additional power consumption related to PR
To measure the additional power consumption when applying PR on the FPGA, real-time power measurements on the board had been performed during partial bit-stream transfer (see [31]). The power measurements were performed on the PL and PS parts during the PR operation. An increase of 0.125 mW/ms in the average power consumption had been detected on the PS auxiliary circuits when initiating a DPR process. However, no additional power had been noticed on the PL part of the FPGA. These results were obtained by reconfiguring the FPGA through the PCAP interface, from the processor, and not using ICAP that requires internal mechanisms in the PL part.
Using ICAP with MicroBlaze processor IPs increases both the used resources and the power consumption on the FPGA. While using ARM processor and PCAP increases the overall power consumption of the system (SoC) but with no additional resources and power consumption on the FPGA. In [32], the authors measured the additional power consumption when applying partial reconfiguration on Virtex 5 FPGAs. MicroBlaze and ICAP were used to apply partial reconfiguration and results...
showed that the additional power consumption does not exceed 160 mw, while it was shown that using PCAP the additional power consumption does not exceed 25 mw.
### 6.2 Adaptive OFDM transmitter
In the adaptive OFDM scenario, we consider three reconfigurable modules: the modulator, encoder and IFFT. The results presented in Table 4 include the partial bit-stream size and the time required to reconfigure a module. As mentioned earlier, the size of the partial bit-stream is related to the size of the reconfigurable module implemented in the FPGA. This size is selected to fit the largest version of the concerned reconfigurable module among all the possible ones.
As noticed in Table 4, the time needed to transfer a bit-stream to hardware using the PCAP interface depends on the size of the partial bit-stream file. In our work, the reconfiguration time is computed by counting all the clock cycles needed to complete the partial bit-stream transfer. Then, the number of clock cycles is multiplied by the clock period (1/Frequency of processor). The partial bit-stream size is related to the floorplan design, as shown in Fig. 4, where the IFFT module occupies more resources on the FPGA compared to the modulation module. Vivado power and utilization estimation tools have been used to estimate the power consumption and the resources used by the different versions of the reconfigurable modules. Vivado power tools are only used to estimate static power for different versions of each module. These results are then used to compare the static power of the PR-based design to that of the parallel-based one. For both cases, the dynamic power has not been taken into account since it is closely related to the input stimuli provided during timing simulation. These stimuli are similar for both the reconfigurable and parallel architectures. The architecture of the IFFT used in this scenario is the pipeline streaming IFFT (from the Xilinx Intellectual Property (IP) library). This IFFT module allows performing a continuous computation.
In order to analyze the power consumption in the FPGA, Table 5 shows the differences between the IFFT, encoder, and modulation blocks in terms of utilized resources and power consumption. These resources and the on-chip power consumption are almost identical for the different modulation versions. This observation is also true for the convolution encoders. The Turbo encoder clearly consumes much power and occupies more resources on the FPGA than the convolution encoders do. As for the different versions of the IFFT blocks, it is obvious that the power consumption and the utilized resources increase as the IFFT size increases.
Also, it is important to analyze the running process through a Gantt chart as depicted in Fig. 9. As shown in
| Module | Partial bit stream size (KB) | Reconfiguration time (ms) |
|----------|------------------------------|---------------------------|
| IFFT | 188 | 1.48 |
| Encoder | 106 | 0.834 |
| Modulation | 30 | 0.236 |
Table 5 Size and power consumption of the considered blocks
| Module | Power (mW) | FPGA resources (LUT-REG-RAM-DSP) |
|-------------------------|------------|----------------------------------|
| 4-QAM | Less than 0.1 | 15 - 8 - 0 - 0 |
| 8-QAM | Less than 0.1 | 16 - 10 - 0 - 0 |
| 16-QAM | Less than 0.1 | 18 - 15 - 0 - 0 |
| 32-QAM | Less than 0.1 | 20 - 19 - 0 - 0 |
| 64-QAM | Less than 0.1 | 22 - 20 - 0 - 0 |
| Convolution 1/2 | Less than 0.1 | 24 - 29 - 0 - 0 |
| Convolution 1/3 | Less than 0.1 | 25 - 31 - 0 - 0 |
| Convolution 1/4 | Less than 0.1 | 26 - 32 - 0 - 0 |
| Convolution 1/5 | Less than 0.1 | 28 - 35 - 0 - 0 |
| Turbo-Encoder 1/3 | 2 | 311 - 555 - 0 - 0 |
| 16-point IFFT | 9 | 191 - 1299 - 0.5 - 3 |
| 1024-point IFFT | 29 | 2245 - 3554 - 3 - 12 |
In this figure, three adaptive processes run in parallel on the PS part, sense their own parameters and finally detect any change. If necessary, the partial reconfiguration is applied on the appropriate block in order to adapt the system to the new environment. As an example, we consider the scenario illustrated in Fig. 9. During initialization, a default configuration is implemented in the FPGA: an 8-QAM modulator, a turbo-encoder and a 1024-point IFFT. At time $t = t_1$, the *adaptive_modulation* process detects a high SNR. According to the algorithm described for the *adaptive_modulation* process, a partial reconfiguration is launched by the configuration controller that implements a 64-QAM in order to increase the throughput. A partial reconfiguration takes place and a new configuration is effective at time $t = t_1 + 0.236$ ms. Meanwhile the encoder block pauses for 0.236 ms.
At time $t = t_2$, the *adaptive_coding* process detects a decrease in the BER. Therefore, a partial bit-stream of the convolution encoder is transferred to the encoder module. The transfer is done at $t = t_2 + 0.834$ ms. Since the encoder is the first module in the chain, the other modules keep on running during the partial reconfiguration operation.
At $t = t_3$, the *adaptive_FFT* process that senses the power regulators on the device detects a high power consumption with a low battery voltage level. Therefore, this process reconfigures the IFFT module and reduces its size. This leads to reducing the power consumption of the system. The operation takes 1.48 ms and all the precedent modules are suspended during the partial bit-stream transfer operation in order to avoid any data loss.
It may be noticed that the time needed to reconfigure the IFFT module is longer than that of the coding and modulation modules. This is due to the difference in the partial bit-streams size. During partial reconfiguration, the precedent modules in the chain are suspended as clearly shown in Fig. 9. The suspension time depends on the size of the transferred partial bit-streams. As noticed, the suspension overhead only affects the precedent modules of the chain.
Fig. 9 Adaptive processes reconfiguring the OFDM transmitter during runtime
As a result of applying partial reconfiguration, the FPGA power consumption and used resources are reduced. As an alternative to this technique, all versions of the different modules may be implemented in the FPGA, with additional multiplexers to select the desired module. This typically requires a lot of resources on the FPGA. As a consequence, the static and dynamic power consumption of the chip would be relatively high compared to PR-based systems. Table 6 shows the amount of resources that is used when applying the PR technique compared to the case where PR is not adopted. It may be seen that there is approximately a factor of 4 between the two cases. Moreover, in the PR case, the resource gain makes it possible to use the remaining parts of the FPGA to implement additional processing units. The percentage of the LUTs, REGs and DSPs used on the SoC is 19.3, 15.9, and 25.9%, respectively when all blocks are implemented in parallel. When using PR technique, the percentage of used resources is 4.8, 3.8, and 5.45%, respectively.
### 6.3 Handover in WIFI-WiMAX networks
The results of the WIFI-WiMAX vertical handover scenario are presented in this section. The reconfigurable modules in the WiMAX-WIFI scenario are the Scrambler, Interleaver, FEC Encoder, and IFFT. The results presented in Table 7 include the partial bit-stream size, and the time required to reconfigure each module.
In Table 7, the obtained results show that the time needed to transfer a bit-stream to the FPGA using the PCAP interface depends on the size of the partial bit-stream. The time needed to reconfigure the chain from WIFI to WiMAX is equal to the sum of the reconfiguration times needed to reconfigure all the concerned modules. The last row of Table 7 shows the time needed to reconfigure the entire chain. In this case, the entire chain is considered as a single PR module. Reconfiguring only the PR modules is more efficient since some modules are similar in both standards and they do not need to be modified.
As a conclusion, reconfiguring the entire chain can be considered as unnecessary and leads to a waste of time and power. Therefore, it is advantageous to consider reconfiguring the concerned modules separately.
Vivado power and utilization estimation tools had been used to estimate the power consumption and the reserved resources of the different versions of the reconfigurable modules.
Table 8 shows the resources utilization and the estimated power consumption of each version of the reconfigurable blocks. As a result of applying the partial reconfiguration, the power consumption and the used resources on FPGA are reduced. As an alternative, both WIFI and WIMAX standards would be implemented in parallel. This typically requires a lot of resources on FPGA. As a consequence, additional static and dynamic power would be consumed in the chip.
Table 9 shows the amount of used resources in two cases: first, when a unified chain is implemented for both standards, and second, when they are implemented in parallel. For the transmitter, the results show that the used resources are reduced approximately by a factor of 1.7, when the partially reconfigured unified chain is used. The percentage of used resources when both standards are implemented is 6.9, 5.6, and 6.81% for LUTS, REGS, and DSPs, respectively; on the other hand, the percentage is 4.18, 3.17, and 4.09% when an unified chain is used for both standards.
Figure 10 illustrates a scenario that shows the state of the reconfigurable modules implemented on FPGA when VHA is applied. The chart is drawn according to the measured reconfiguration times and reflects how the unified chain switches from one standard to another. As shown in the figure, the modules are reconfigured sequentially in an...
Table 9 Comparison of hardware resources usage
| | LUTs | REGs | DSPs |
|--------------------------------|--------|--------|------|
| Unified chain for both standards | 2229 | 3376 | 9 |
| Both standards implemented | 3967 | 6027 | 15 |
| Available on ZYNQ | 53,200 | 106,460| 220 |
order that is related to their position in the chain. The time needed to achieve switching from one standard to another is the sum of the reconfiguration times required by each module.
As noticed, when a module is reconfigured, the data flow is paused until the subsequent modules are also reconfigured. As mentioned earlier, the time needed to reconfigure a block is related to its size. This is illustrated in Fig. 10 in which the time needed to reconfigure the IFFT block is greater than that required by the other ones. The switching from WIFI to WIMAX is achieved when the last module (for ex. IFFT) is reconfigured successfully. Finally, data are transferred through the WIMAX standard until another VHA occurs.
7 Conclusions
In this paper, an ARM-FPGA-based system was proposed for self-reconfigurable wireless communication systems. The partial reconfiguration technique that is available in the recent FPGA devices has been adopted to reconfigure wireless system modules in real-time. The proposed HW/SW platform is based on a custom micro-kernel that has been developed in our laboratory. Its role consists in managing and controlling the partial reconfiguration process. The proposed architecture enables implementing adaptive wireless systems with custom algorithms to manage and perform switching between multiple wireless standards in heterogeneous networks. Two different cases were considered in this study. First, an adaptive OFDM-based transmitter was implemented and described. Second, an intelligent system aiming at performing a vertical handover in heterogeneous networks was designed. In this paper, we considered two use-cases standards: WIFI and WIMAX. The algorithms implementing the PR process were presented and described for both cases. These algorithms run on an ARM processor and aim at getting knowledge of the environment conditions. This is performed by requesting parameters from the parameters provider service of the micro-kernel. In our work, partial reconfiguration in the FPGA was implemented through the PCAP interface. The sizes of the partial bit-streams were optimized in order to minimize the time overhead caused by PR. Moreover, to avoid data loss when performing a vertical handover or during PR, the data flow was controlled conveniently by the configuration controller. This was made possible by temporarily suspending some blocks of the wireless communication chain. The obtained results show that implementing the PR technique reduces the global on-chip power consumption and saves hardware resources in the FPGA. This study gives an important information about the impact of adopting the PR technique in the context of reconfigurable wireless communication systems.
Fig. 10 State of the reconfigurable modules during VHA
Funding
This work has received funding from the Lebanese University. Also, MR has been partially supported by Rennes Metropole program for PhD students.
Authors’ contributions
MR, MM, JCP, FN, and YM jointly developed the theoretical and practical solutions described in this paper, analyzed the results, and evolved the proposed system model. MR took care of all the implementations and collected all the simulation and measurement results. The five authors actively participated in proposing the techniques presented in Sections 3, 4, and 5. Finally, the five authors contributed in similar amounts to the writing and reviewing of the manuscript. All authors read and approved the final manuscript.
Competing interests
The authors declare that they have no competing interests.
Publisher’s Note
Springer Nature remains neutral with regard to jurisdictional claims in published maps and institutional affiliations.
Author details
1 ETR-INSa, 20 Avenue des Buttes de Coesmes, 35708 Rennes, France. 2 Faculty of Engineering III, Lebanese University, Hadath Campus, Beirut, Lebanon. 3 Faculty of Science I, Lebanese University, Hadath Campus, Beirut, Lebanon.
Received: 15 June 2017 Accepted: 17 December 2017
Published online: 29 December 2017
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14. KAA Kumar, in 2013 Annual International Conference on Emerging Research Areas and 2013 International Conference on Microelectronics, Communications and Renewable Energy. FPGA implementation of QAM modems using PR for reconfigurable wireless radios, (2013), pp. 1–6. doi:10.1109/AICERA-ICMiCR.2013.6575999
15. KAA Kumar, in 2013 Annual International Conference on Emerging Research Areas and 2013 International Conference on Microelectronics, Communications and Renewable Energy. FPGA implementation of QAM modems using pr for reconfigurable wireless radios, (2013), pp. 1–6. doi:10.1109/AICERA-ICMiCR.2013.6575999
16. KAA Kumar, in 2014 3rd International Conference on Eco-friendly Computing and Communication Systems. An ofdm transmitter implementation using cordic based partially reconfigurable ifft module, (2014), pp. 266–270. doi:10.1109/Eco-friendly.2014.61
17. S Sivananthan, R Adarsh, S Bhargav, KJ Naidu, Partial reconfigurable implementation of IEEE802. 11g OFDM. Indian J. Sci. Technol. 7(4), 63–70 (2014)
18. C Vennila, K Suresh, R Rather, G Lakshminarayanan, S-B Ko, in 2013 26th IEEE Canadian Conference on Electrical and Computer Engineering (CCECE). Dynamic partial reconfigurable adaptive transceiver for OFDM based cognitive radio, (2013), pp. 1–4. doi:10.1109/CCECE.2013.6567749
19. JP Delahaye, J Palicot, C Moy, P Leray, in 2007 16th IST Mobile and Wireless Communications Summit. Partial reconfiguration of FPGAs for dynamical reconfiguration of a software radio platform, (2007), pp. 1–5. doi:10.1109/ISTMW.C.2007.4299250
20. J Delorme, J Martin, A Nafkha, C Moy, F Clermidy, P Leray, J Palicot, in 2008 Joint 6th International IEEE Northeast Workshop on Circuits and Systems and TAISA Conference. A fpga partial reconfiguration design approach for cognitive radio based on noc architecture, (2008), pp. 355–358. doi:10.1109/NEWCAS.2008.4606394
21. M Khan, CJ Jung, PC Uzoh, C Zhenbo, JK Kim, Y Yoon, A Nadeem, K Han, in 2015 International Wireless Communications and Mobile Computing Conference (IWCMC). Enabling vertical handover management based on decision making in heterogeneous wireless networks, (2015), pp. 952–957. doi:10.1109/IWCMC.2015.7289211
22. I Joe, S Hong, in Proceedings of the 4th International Conference on Ubiquitous Information Technologies Applications. An adaptive network scanning algorithm in hybrid wireless networks, (2009), pp. 1–4. doi:10.1109/CUT.2009.5405738
23. A Aziz, S Rizvi, NM Saad, in 2010 International Conference on Intelligent and Advanced Systems. Fuzzy logic based vertical handover algorithm between LTE and WLAN, (2010), pp. 1–4. doi:10.1109/ICIAS.2010.5716261
24. A Bathich, M Baba, M Ibrahim, in 2012 IEEE Symposium on Computers Informatics (ISCI). IEEE 802.21 based vertical handover in WiFi and WiMAX networks, (2012), pp. 140–144. doi:10.1109/ISCI.2012.6222682
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|
FairShake
REENTRY RESOURCE CENTER
REENTRY PACKET
National Web-based Reentry Resource Center
www.fairshake.net
PO Box 63, Westby, WI 54667
The willingness to accept responsibility for one's own life is the source from which self-respect springs.
~ Joan Didion
We cannot think of being acceptable to others until we have first proven acceptable to ourselves.
~ Malcolm X
The curious paradox is that when I accept myself just as I am, then I can change.
~ Carl Rogers
THANK YOU!
Fair Shake is grateful for donations of expertise, time and financial support in the creation of this publication. Several notable professionals have donated materials to share freely with the incarcerated community and the stakeholders who support them. Many eyes have read the content and shared their critiques and suggestions. (I hope you will feel comfortable sharing yours.) Thanks to our donors (many of whom are incarcerated!) who have made it possible for us to put this Reentry Packet into your hands.
Fair Shake Reentry Packet: Copyright © 2017 Fair Shake except where noted.
Please contact Fair Shake, or specific authors, for permission to use material found in this packet.
# Table of Contents
## Get The Most From Fair Shake
- Are You Ready for a Fair Shake? 1
- FS Reentry Community Center 3
- Website Quick Start Guide 7
- FS Resource Directory 11
- National Reentry Resources 13
- Computer Basics 14
- FS Personal Web Page 15
- Benefits of Free Membership 17
- Educate Yourself! 19
- What is the Purpose of Education? 21
## Choose Your Perspective
- FS Ownership Manual 25
- Freedom 29
- Culture Shock! 31
- Transition Tips 35
- Relationships: Proceed With Caution 37
- Dealing With Rejection 41
- Handling Frustration 42
- Motivation Tips 43
- Managing Anger 45
- Resisting Influence 49
- Working Through Depression 57
- Swellness 63
- Ubuntu: Building Social Fabric 67
- How to Watch TV 69
## Worksheets And Checklists
- Prepare for Release and First Week Checklist 73
- Sample Birth Certificate Application 78
- Sample Driver’s License Application 79
- Build a Budget Worksheet 81
## Employment
- Find a Job / Prepare for Work 83
- White House Fair Chance Businesses 85
- Employment Tips 87
- Interview Tips 89
- Sample Job Application 90
- Sample Interview Questions 91
- Interview Questions for You to Ask 94
- Employer Support Sheet 95
- Resume Guide 97
- Favorite Verbs for Your Resume 106
- Accomplishments and Skills Worksheet 107
- Cover Letter 111
- Thank you Letter 112
- Self-Employment 113
- Mini Computer Guide 115
- Suggested Reading 117
Fair Shake Website and Software Home Page
Fair Shake Reentry Tool Kit
- Resource Directory
- Reentry Packet
- Ownership Manual
- Building Computer Skills
- Find a Job
- Become a Member!
- Educate Yourself!
For Formerly and Currently Incarcerated People
You have big hurdles. We have powerful tools to help you get beyond them!
For Property Managers
Successful reentry is not possible without a place to live.
For Corrections / Reentry Professionals
We have a number of tools for you to help incarcerated people prepare to return to the community.
For Family and Friends
Special support for special relationships
For Employers
We have tools to support you in making informed, careful hiring decisions.
For Community
Neighbors, Students, Advocates. We all play an important role in reentry.
Reentry News
- Bureau of Prisons commits to Prison Reform
Click on our link to find a summary of the most significant reforms at the BOP, starting from arrival and continuing until the return home. And call this toll-free reentry hotline for resources and support 877-895-9196
- The Baltimore Sun: Port Covington should commit to hiring ex-offenders
What can be done to keep people from cycling back into the system? Let's start with jobs. Sustainable employment may be our single best opportunity to significantly reduce recidivism.
- CA Voters Choice: End Death Penalty, or Speed It Up
Voters will decide between Prop 67, which would end the death penalty, and Prop 66, which would speed up executions.
More news in our archives
Videos
- Damon Horowitz - Philosophy in Prison
Damon Horowitz teaches philosophy through the Prison University Project.
- Benefits of Fair Shake Membership
Fair Shake has created several FREE tools exclusively for those coming home.
- Victor Frankl - Why to Believe in Others
Victor Frankl, author of Man's Search for Meaning shares his perspective on having faith in humanity.
Hi. I’m Sue Kastensen and I’m the founder and director of Fair Shake, a resource center for everyone involved in supporting successful reentry. (Which includes everyone.)
I understand that those coming home from prison have a huge hurdle to overcome in making a successful transition to life-after-prison. We have created unique tools for you and also for those who support you. I believe we have something for everyone.
**Just a few of Fair Shake’s FREE tools:**
- The nation’s largest reentry Resource Directory, with over 14,500 entries and 300+ reentry guides
- Employment tools for both formerly incarcerated people *and* employers
- An Educate Yourself! section with links to many free web-based education resources
- FREE Member-only tools: incl. document storage, email account and a Personal Web Page
**Finding your specific resources while you are incarcerated:**
I cannot do this for you; I’m busy driving all over the country! I created Fair Shake to be a self-service reentry center so anyone can access the Resource Directory, print a Reentry Packet, check out the employment and employer page (bonding, tax incentives, ban the box info), and much more. Create a ‘wish list’ for a family member, a friend, a mentor, your case manager or other support person to find resources for you on our website. (Find out more on the Resource Directory pages in this packet.) They can access the directory for free! And then they simply click on the resources, save them, print them and mail them (or hand them) to you. They can print the state and local reentry guides as well.
**The entire website is available offline in a Software Application**
Several institutions are now utilizing our free software application so incarcerated individuals can look through the website and Resource Directory for themselves. In addition to searching through the Resource Directory, users can learn to use a computer and understand how to find information on large, informational websites. The software application can be used on any stand-alone computer and is often accessed on computers within a library, the reentry office, Career Resource Center or computer lab. We hope you will share this information with educators, reentry clerks, etc.
**Fair Shake is not for everyone.**
Getting a fair shake does not come without effort. Fair Shake is for doers, builders, busybodies, thinkers and planners! It’s like a huge reentry hardware store with a wide variety of information. At Fair Shake, you design and construct your reentry project!
Reentry is not a one-size-fits-all uniform transition. ‘What Works’ is different for each unique individual.
It will take time to get through the options in our website so it’s like a gift that keeps on giving. And when you’re ready, you can give back to Fair Shake - which will be a gift to everyone else - by sharing your prerelease reentry studies and preparation, your resources (and reviews!), and your post-release joys, challenges, tips or ideas from your transition for those coming behind you. We can create our own reentry safety net, best practices and evidence… and we need YOU to make it possible.
Please continue to revisit Fair Shake for information for as long as you like. You might need employment support or temporary housing right away. You might wish to store documents on our server. Once the excitement of the transition is over you might want to look at the *Working Through Depression* document again. And in 6 months you might be ready to check out the Educate Yourself! area. We’re here for you.
We are all given different opportunities and challenges throughout our lives. Through awareness, desire, willingness and support we can increase our opportunities and decrease our challenges. The transition won’t be easy, but nothing worthwhile ever is. A fair shake is not given to us, it’s something we must create. So let’s create it together! Ubuntu!
To Our Successful Transitions,
Sue Kastensen
Founder and Director
SUE KASTENSEN’S BIO:
This is the information I submit to various organizations before I present Fair Shake.
Sue is the founder and director of Fair Shake, a web-based prisoner reentry resource center. She holds a bachelor’s degree in Individualized Learning from Viterbo University in La Crosse, WI, which she received 26 years after graduating from Walden III, an alternative high school in Racine, WI. She is currently a student in the Masters of Education program at Rutgers University in New Brunswick, NJ.
Sue created Sue’s Amazing Lip Stuff and Sun Dog Hemp Body Care in 1993 which she sold to Dr. Bronner’s Magic Soaps in 2005. She founded of Fair World Project in 2008 and formally organized Fair Shake in 2009. Sue is the former board chair of the Domestic Fair Trade Association, the Viroqua Food Coop and the Midwest Organic Services Association. In 2015, Sue received the Correctional Education Association’s Ralph Kaplan Award for Technological Advancement in Correctional Education Setting. In 2014, she was recognized by the White House Office of Science and Technology Policy for using technology in a prison setting, and recognized again by the White House in 2016 as a Champion of Change for Fair Chance Opportunities.
QUALIFICATIONS FOR REENTRY WORK: This is my history before and moving into the above. My history has made me who I am today and has given me my unique qualifications to create Fair Shake.
June 3rd, 1963: Born in Milwaukee, WI. Given up for adoption by 19 year old parents.
Late Sept. 1963: Adopted by family in Racine, WI. K – 3 Attended public school
Age 10: Grade 4 - Switched to Catholic school. Age 12: Started running away, first group home.
Age 13: Entered ‘the system’. 1976 – 1981 spent in group homes, foster homes, jail, reform school, and running away. Graduated from Walden III H.S. and released from the system on my 18th birthday.
1983: took Native American Ethnobotony in college; started making many things including lip balm.
1986: Moved to mountains in CO with my young family
1987 – 1994 Snowmaker in winter. Lived without running water, cooked and heated wood, amateur competitor snowboarder in the halfpipe.
1993 – Started lip balm company and made DARE to Think bumper stickers; sold both on Grateful Dead tour.
1999: Sue’s Amazing Lip Stuff / Sun Dog in full swing. An employee asked if I would consider hiring a friend coming home from prison soon. Over the next 5 years I educated myself anew about the criminal justice system that I vowed as a child to never again be a part of.
During the 6 formative years that I spent involved in the juvenile justice system I did a great deal of raising myself alongside my young ‘delinquent’ peers. With little or no family support, sent far away from friends and familiar surroundings, we shaped our identities, determined our boundaries and became responsible for our actions and aspirations. By the time I ran away at 16, I felt like I should have been an emancipated adult. By the time I started having kids - at 19 - I felt like I was 25. (Fortunately the ‘age-extending’ stopped in my mid-30’s and I have managed to continue to feel like I’m in my mid-30’s ever since. ~ : )
The life I’ve lived, the choices I’ve made, and the things I’ve committed myself to learning have given me great tools for starting Fair Shake, building the Reentry Packet, and coming into prisons to talk about reentry. Since I had to ‘be myself’ as I moved through all of those environments, I became comfortable being uncomfortable. I believe it is this particular characteristic that gives me a space to look at myself and know that I don’t have it all ‘together’- and that’s okay. I believe this is true for everyone. We have enough contributions and questions to move forward and that’s all we need. We become more capable as we go. We’re never complete. Count on me to keep trying, building, improving, problem-solving, learning and connecting to construct the lasting change we all seek. I hope you will join me!
Fair Shake Reentry Community Center
We often receive letters and email messages from people expressing gratitude for what we offer here through Fair Shake. We want you to know that we are grateful for what you contribute to Fair Shake, too! We can only solve this reentry puzzle - and reduce the 76.6% recidivism rate - together. The stronger we become, the stronger our society becomes. We need your help to educate our citizens - our neighbors, families, educators, business leaders, and especially the next generation – about people like you who are rejoining society ready for a fair chance!
What do you think they need - or want - to see to get a ‘fair understanding’ of people coming home? What attributes demonstrate prosocial intentions?
In the past year we have seen significant growth in our BOP Trulincs readership and also in our communications with people incarcerated in state institutions. We have added many new pages to the website and the Reentry Packet in response to requests and ideas. Many thanks to those who share our information with others, and also to those who share information with us!
We would like to think of a way to regularly and freely (as in: no cost, if possible) engage with people in state facilities who are interested in joining a conversation about reentry ideas. Hopefully this paragraph will inspire creative readers to start working on this problem right away. I’ll keep thinking on it, too!
We need to remember that diverse groups of people working towards a common goal is not an easy task under any circumstances. We often have to sort through individual agendas and barriers created within a community. As we grow our commitment to improving reentry outcomes, so must we grow in our abilities to listen to each other and think as creatively and constructively as we possibly can. After all, as Einstein reminded us: “We cannot solve our problems using the same thinking we used when we created them”.
As we engage in conversations around creating ways to demonstrate prosocial intentions, we hope to shine the light of intentional and engaged thinking into the darkness of hesitation, fear, reluctance and confusion. We must create - even in the tiniest increments - positive change. Please let us know what’s working and what’s not. What helps people feel strong, engaged, valued, thoughtful and intentional? What seems to bring people down about reentry planning? And then how can we get or do more of the first and less of the second?
ONLY YOU CAN CREATE - AND PROVIDE - THE EVIDENCE FOR ‘WHAT WORKS’.
We can collaboratively craft a powerful cultural shift around successful reentry on the inside that can carry over and be well understood by those on the outside.
Our goal is to find ways to prove pro-social behaviors and intentions while people are incarcerated so they have the proof they need for society ready when they come home. I think we can figure it out, but it will take working together…which will take time.
Peer learning through discussion groups and workshops could facilitate ideas, make great strides toward ‘proving pro-social’ intentions, and also perhaps provide a way to communicate with larger national reentry conversations. What do you think? I’m just brainstorming; but this seems a decent place to start.
I encourage you to reflect, philosophize, share ideas, ask questions and build this community!
Ubuntu!
There is absolutely no inevitability as long as there is a willingness to contemplate what is happening.
~ Marshall McLuhan
Building the Reentry Community Center There are many ways to engage ~
Volunteer!
While incarcerated:
- Please share your resources with us to build our directory for everyone!
- Also, please share your experiences contacting resources so we can keep our Directory current and accurate. (Returned letter? Great / lousy experience?)
- What kind of ‘best practices’ are going on that we could learn from and share with others? Are you involved in reentry studies or groups?
- If Fair Shake has not been to your facility, or if our software is not there currently, would you share our information with educators and/or reentry coordinators?
After incarceration:
- Please share your reviews of the resources/organizations you’ve encountered.
- Share additional resources, and volunteer to locate more resources for the packet.
- Write your thoughts, advice, how things weren’t like you’d expected them to be and how they were…or were even better than you expected?
- Make a list of ‘What Worked’ with your Reentry Preparation
- What do we need to add to the packet? To our software? To our website?
Join The Conversation!
While in the BOP:
We send out a newsy email at least once per month and we often ask our readers to share their opinions so we can share with the group and all learn more together. Our readership - as of Jan 2017 - is around 370 and our readers are located in every area of the country.
Connect with us through Trulincs at: firstname.lastname@example.org
Sign us up as Fair Shake (instead of a person’s name)
While in a State or Private Facility:
We receive letters from peer facilitators, adult educators and reentry study groups hoping to get involved but we have not yet figured out how to communicate with state people on a monthly or bi-weekly basis. But we want to!
We’ve been asked to communicate with individuals who have JPay. I’m not sure what I will do with this query just yet, either. Does JPay allow for ‘newsletters’?
Please help us think through this one: how can we share ‘best practices’ or even ‘trial and success/error’ practices, reentry study ideas and personal development ideas with people in state facilities?
We hope you will share your ‘Best Practices’ and ideas for reengaging with your family, friends and neighbors ~
Please support us so we can support you! Donate individually or as a group.
Fair Shake exists because of you. We receive 100% of our funding through donations. We must remain free for all incarcerated people, and their supporters, to create paths for successful reentry. Money cannot be a barrier to access the packet or resources.
It is important that we remain FREE TO:
- Maintain America’s largest resource data base - FREE FOR EVERYONE TO USE - without ‘referrals’, ‘contracts’, partners’ or other ‘strings’
- Mail our Reentry Packet to anyone who asks for one
- Provide computer learning opportunities to acclimate people to technology
- Be a national Community Center for ideas originating in prisons around the country
- Listen and respond to the needs, questions and suggestions of the incarcerated
- Support confidence-, strength- and capability-building while deconstructing institutionalization
- Bring reentry stakeholders together to unify a vision of successful reentry
- Construct What Works with those who will provide the PROOF (you).
- Debunk the Myths They All Come Out The Same and They Only Become Better Criminals
- Present Fair Shake LIVE in institutions around the country.
And
FREE FROM:
- Data mining, counting heads or claiming your success as our success. (see Conflicts above)
- Advertising
- Conformity, Homogenization
- Political or Religious Agendas; Fair Shake is Inclusive.
- Conflicts of Interest
- Becoming Marketers and Sales People instead of listeners and community builders
THANK YOU, DONORS, FOR KEEPING FAIR SHAKE GOING!
What are all of Fair Shake’s services and tools worth to you?
$1 per month? $10 for a year? $25 for you and the person with no money or family?
The only way we can stay free to be creative, free from outside control, free of advertisements is through YOUR SUPPORT. Check this out:
If everyone going home this year: 600,000 people donated 1 MP3 song: x $2
Fair Shake’s income: $1,200,000…could last for more than 6 years!
We need to keep everything FREE so that anyone who is looking for support, resources, information or even advice, can find it in our community. Charging for services excludes people. It also turns those who are serving the community into Sales People instead of Community Service Providers. We want to be FREE to hear your requests and ideas! Let’s discuss ways to fuel Fair Shake. Like all aspects of Reentry, we can do this better together!
Please send checks of any size (we receive stamps sometimes, too!) to:
Fair Shake PO Box 63 Westby, WI 54667
We also accept credit card donations through our website: www.fairshake.net
Fair Shake is a 501(c)(3) non-profit. All donations are tax deductible.
Building Our Community
I drive around the country to introduce Fair Shake in prisons and to have reentry conversations with those inside. I have a ‘Bubble Truck’ which basically means I wear my heart on my sleeve: I do what pleases me and over the past decade I’ve found out it pleases others, too. Since I have people’s attention with my unique design, I thought I would push the envelope a little to engage them in what I’m doing, too! My camper says: *Ubuntu. I am because we are.* on all four sides. On the back of the truck, next to the Fair Shake logo and website address, I have written:
*Our Criminal Justice System is Broken. Who Can We Trust To Fix It? We ALL Deserve A Fair Shake.*
What do you think?
I want people all over the country to check us out on their gizmos (phone, tablet, etc) and become familiar with the concept of reentry to help us ALL stop the ‘revolving door’. (The most recent BJS study (2010) showed a shocking 76.6% recidivism rate within 5 years of release.)
New Pages on our Website:
**Incarcerated and Formerly Incarcerated Authors**
We created an Incarcerated and Formerly Incarcerated Authors page on our website/software to showcase the literary accomplishments of incarcerated people. It is no easy feat to write a book in prison! We want our website visitors and all stakeholders to have access to these works as we learn about them and have the opportunity to review them. We hope that by listing the books, the public will learn more about the skills and creativity found in our prisons, and we also hope to inspire more writers!
Our criteria for listing book listed is as follows:
- The author must be currently or formerly incarcerated.
- The titles we list must have been written during incarceration.
- The book must have a positive message over all
- The book must be purchasable through Amazon or other DOC/BOP approved sellers.
**Other pages include:**
- Greif, Gratitude, Ubuntu, Cognitive Biases, Belief (we will add these to the next packet!)
- Veterans Page
- LBGTQIA Page
- Entrepreneurship Programs
- Sex Offense Reentry Support
- Plus huge additions to the Formerly and Currently Incarcerated Page!
- Several pages on managing your health: Diabetes, Heart Condition, High Blood pressure, etc
- Self-Study and Peer Learning Reentry Packet Study Guide
**Pages to Add (to the website and the packet!)**
We hope you will share your ideas about what should go on these pages.
- Native People’s Page
- Women’s page
- Youth page
And many more to come! What pages do you think we should add?
WELCOME TO FAIR SHAKE!
Fair Shake is loaded with all kinds of reentry information. It’s like a hardware store for reentry that includes resources, information and even tools and materials for building bridges of transformation and trust. You can find everything you are looking for from the home page; this guide will show you how!
Three important items for you to remember:
1. If you ever get lost on our website, click on our logo (upper left corner) and you will return to the home page.
2. All words in blue are links! Click on them to look at pages on our website, to visit other valuable websites or read documents that you can also print.
3. Icon Key:
- available offline and online
- available online only
Now, what are you looking for?
In this document:
1. Reentry Resources
State and Local Reentry Guides
2. Employment Support
3. Building Computer Skills
4. Educate Yourself!
5. Finding Specific Pages
1. REENTRY RESOURCES:
...for job training, staffing agencies, felony-friendly employers, housing, family support, medical and dental health care, food, financial literacy, mental health support, voting and licensing information, opportunities to volunteer and much more!
1. Below the photo, under the words Fair Shake Reentry Tool Kit, click on the words Resource Directory
2. In the search form, enter your state and city – or your zip code – and the distance you are willing to travel to find resources (5 – 100 miles) and click on Search Resources
3. Below the search area you will now see the cities, state and national resources we have identified in your search area. The resources are inside the folders you see on the page.
4. Click on a folder and it will open to show you resources in that category. If you would like to save a resource to print – or save for later – click on + save.
5. Continue to open all of the files that interest you...in the state and national listings too. The resources in the state and national folders are available in your area!
6. When you’ve saved all the resources you want to follow up on, go to the top of the page to see the tabs above the search area. Click on the tab that says Print Saved Resources.
7. Review the resources you have saved. If you selected resources you no longer want to keep, click on Delete (on the right side of the page) and remove it from your list.
8. When you are ready to Print or Save selected resources, click on (Print or Save Resources) on the upper right. You can then save the page to your computer or print your resources to carry with you.
STATE AND LOCAL REENTRY GUIDES:
1. On the Resource Directory page, directly below the search form, you can see the words STATE AND LOCAL REENTRY GUIDES
2. Click on the box that says ‘all’ to select your state or
3. Scroll down the page to get to your state and see what other guides have to offer too!
2. EMPLOYMENT SUPPORT:
If you’ve come to Fair Shake to build your resume, prepare for an interview, get bonding and tax incentive information that you can offer employers, and utilize some super-great FREE tools available only to formerly incarcerated people, this is the page for you.
1. Below the photo, under the words Fair Shake Reentry Tool Kit, click on Preparing for Work
2. Scroll down the page to find what all types of employment related documents, website links, videos and more. ALL OF THE BLUE WORDS ARE LINKS TO PAGES, DOCUMENTS, WEBSITES and VIDEOS.
3. Create a Personal Web Page profile to share details about your skills and characteristics which will supplement your resume and job applications.
4. If you’d like to improve your computer skills, scroll down the middle of the page to find the New to Computers? link on the right side of the page.
5. Please remember that job training, staffing agencies, felony-friendly employers, workforce development and more are found in our Resource Directory (see above)
3. TO LEARN HOW TO USE COMPUTERS:
Fair Shake has created a self-paced interactive computer tutorial to prepare learners to use a mouse and a keyboard, learn needed skills to take the GED online, and also create and store documents and files for employment.
Once you understand the basics, Fair Shake has more information as you move into the next level of using your computer. We offer information on organizing data, keyboard shortcuts, protecting yourself online and tutorials for our member tools such as using email, data storage and creating a personal web page.
1. Below the photo, under the words Fair Shake Reentry Tool Kit, click on the Building Computer Skills page.
2. For beginners or newer users, click on the Computer Basics tutorial
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The Identification and Tracking of Volcanic Ash using the Meteosat Second Generation (MSG) Spinning Enhanced Visible and Infra-Red Imager (SEVIRI)
Aaron R. Naeger\textsuperscript{1} and Sundar A. Christopher\textsuperscript{1,2}
\textsuperscript{1}Earth System Science Center, UAHuntsville, 320 Sparkman Drive
Huntsville, AL, 35805
\textsuperscript{2}Department of Atmospheric Sciences, UAHuntsville, 320 Sparkman Drive
Huntsville, AL 35805
Submitted to:
Atmospheric Measurement Techniques
May 2013
Abstract
In this paper, we develop an algorithm based on combining spectral, spatial, and temporal thresholds from the geostationary Spinning Enhanced Visible and InfraRed Imager (SEVIRI) daytime measurements to identify and track different aerosol types, primarily volcanic ash. Contemporary methods typically do not use temporal information to identify ash. We focus not only on the identification and tracking of volcanic ash during the Eyjafjallajökull volcanic eruption period beginning 14 April to 17 May 2010 but a pixel level classification method for separating various classes in the SEVIRI images.
Three case studies on 13 May, 16 May, and 17 May are analyzed in extensive detail with other satellite data including the Moderate Resolution Imaging Spectroradiometer (MODIS), Multi-angle Imaging Spectroradiometer (MISR), and Facility for Airborne Atmospheric Measurements (FAAM) BAe146 aircraft data to verify the aerosol spatial distribution maps generated by the SEVIRI algorithm. Our results indicate that the SEVIRI algorithm is able to track volcanic ash when the solar zenith angle is lower than about 65°. Furthermore, the BAe146 aircraft data shows that the SEVIRI algorithm detects nearly all ash regions when AOD > 0.2. However, the algorithm has higher uncertainties when AOD is < 0.1 over water and AOD < 0.2 over land. The ash spatial distributions provided by this algorithm can be used as a critical input and validation for atmospheric dispersion models simulated by Volcanic Ash Advisory Centers (VAACs). Identifying volcanic ash is an important first step before quantitative retrievals of ash concentration can be made.
1. Introduction
The Eyjafjallajökull volcano located on the southern coast of Iceland (63.6°N, 19.6°W) began emitting ash into the atmosphere on 14 April 2010. Although only a mid-size eruption (Gudmundsson et al., 2013), the volcano had a tremendous impact on air traffic as the strong atmospheric winds transported the ash southeasterly towards Europe (Ansmann et al., 2010a). By 16 April 2010, an ash plume was observed across Central Europe by Aerosol Robotic Network (AERONET) Sun photometers and ground based lidars (Ansmann et al., 2010b). The presence of ash caused nearly a week-long stoppage in air travel over many parts of Europe since volcanic ash can have damaging effects on commercial airplanes (Casadevall, 1992). Flight cancellations that occurred over the ensuing week proved extremely costly to the airline industry as monetary losses were over 1 billion U.S. dollars (Christopher et al., 2012). Therefore, it is critical that we accurately track volcanic ash during an eruption period.
To track the spatial distribution of volcanic ash, satellite remote sensing is important as the spatial distribution of ash varies strongly especially after an eruption. Ground based stations are inadequate for understanding the spatial distribution as they only provide point measurements. Satellites are also an important tool for verifying models that predict ash concentrations and spatial distributions (Millington et al., 2012). These models are usually high resolution dispersion models that predict height dependent ash concentrations used by Volcanic Ash Advisory Centers (VAACs). Although polar orbiting satellites such as the Moderate Resolution Imaging Spectroradiometer (MODIS) can provide high spatial resolution of volcanic ash plumes (Sigmundsson et al., 2010), their temporal resolution is insufficient to track ash plumes being transported long distances over relatively short time scales. Thus, geostationary satellite sensors such as the Spinning Enhanced Visible and InfraRed Imager (SEVIRI) are critical for assessing the spatial distributions of ash due to their high temporal resolutions (Prata and Kerkmann, 2007, Christopher, et al., 2012).
Ultimately it is important to know the vertical distribution of ash concentrations before important decisions can be made regarding commercial flights during eruptions. However the first task is to detect the volcanic ash on a pixel-by-pixel basis. The first limitation to note is the SEVIRI cannot detect ash below thick clouds which is a common
issue for passive satellite data sets that operate in the visible to the infrared part of the electromagnetic spectrum. However, the repeated temporal information and the large spatial coverage make SEVIRI an excellent tool for understanding the spatial distribution of volcanic ash over large areas. One common method is to simply assign separate channels to the red, green, and blue and visually examine the ash by looking for certain colors. This is often problematic since clouds can be confused as ash and not all aerosols appear to have the same color; therefore, it is important to develop an algorithm that separates an image into various classes, such as cloud and aerosol, for further studies that may involve calculation of ash concentrations.
Prata (1989) presented a very commonly used technique that exploits the brightness temperature difference (BTD) between the 11 and 12 µm channels (BTD 11-12). The limitations with this simple technique are well known and discussed in Prata et al. (2001) where one major limitation is that high water vapor amounts can mask the negative BTD signal which the technique relies on ash detection. Pergola et al. (2004) developed a more sophisticated ash detection technique that compares a measured satellite signal to a reference field computed from long-term historical records. In particular, they use three channels centered at approximately 3.75, 11.0, and 12.0 µm from the Advanced Very High Resolution (AVHRR) to compute the reference fields and they show that this Robust AVHRR Technique (RAT) is more accurate in detecting volcanic ash than the simple BTD technique presented in Prata (1989). However, this approach requires multiple years of data over a region to compute the reference fields. Pavolonis et al. (2006) developed a four-channel ash detection algorithm that utilizes the 0.65, 3.75, 11.0, and 12.0 µm channels and does not rely on a reference field but instead uses spectral tests and a spatial filtering routine. They showed that this four-channel algorithm is much better at detecting volcanic ash regions compared to the BTD approach with less false detections. We take a different approach by developing an algorithm using SEVIRI measurements that exploits temporal thresholds along with spectral and spatial thresholds to classify each pixel into various classes (e.g., cloud, land, and aerosol). This algorithm uses seven different SEVIRI channels to produce detailed spatial distribution maps of cloud and aerosol.
Although the SEVIRI instrument is not equipped with near ultraviolet (UV) channels, it is important to note the ability of the near-UV channels in detecting volcanic ash. Torres et al. (1998) used the near-UV channels of 340 and 380 nm from the Total Ozone Mapping Spectrometer (TOMS) instrument to detect volcanic ash, and they found that these two channels have great success in detecting ash over snow/ice or above clouds. This is an important advantage of using the near-UV channels as detection techniques using channels from the visible to infrared spectrums, such as the RAT and our SEVIRI algorithm, do not possess the same capability of detecting ash over snow/ice or above clouds (Pergola et al., 2004). In addition, Krotkov et al. (1999) showed that the near-UV channels of the TOMS instrument can detect the optically opaque, very fresh ash which is often missed by the visible and infrared techniques.
This study tracks the ash plumes emitted from the Eyjafjallajökull volcano from its initial eruption on 14 April until the end of the eruption period on 23 May using the high temporal resolution measurements of SEVIRI onboard the Meteosat Second Generation (MSG-2) satellite. Since we use the visible along with the infrared channels of SEVIRI, the algorithm developed in this study can only track the ash plumes during the daylight periods for volcanic ash in cloud-free conditions. We present results from the SEVIRI algorithm throughout the eruption period but place special emphasis on six days in May 2010 when the Facility for Airborne Atmospheric Measurements (FAAM) BAe146 research aircraft measurements was available (Johnson et al., 2012). We use the FAAM BAe146 aircraft measurements as validation for the SEVIRI algorithm developed in this study. Other sources of verification data used in this study to assess the spatial distribution of the aerosols detected by the SEVIRI algorithm include the MODIS, and the Multi-angle Imaging SpectroRadiometer (MISR).
2. Data
The goal of the paper is to develop a pixel level algorithm from SEVIRI reflectance and temperature measurements using temporal threshold tests along with spatial and spectral threshold tests. It is important to note that the retrieval of ash concentrations and aerosol particle size information is beyond the scope of this study. We have already noted that the use of temporal thresholds and some of the spatial
thresholds used in this paper is not routinely done by standard algorithms (i.e. Prata, 1989). After classifying the volcanic ash pixels, we need to determine the accuracy of the algorithm but this is a difficult task to accomplish. We have chosen to intercompare the SEVIRI algorithm results with MODIS and MISR products by making the assumption that their identification is correct. We take this a step further by comparing our results with aircraft data but not many data points can be obtained with such a comparison. This is not a unique problem to our study since all validation methods have to use a verification source and then provide results and analysis.
Table 1 shows the SEVIRI channels with the center, minimum, and maximum wavelengths for each channel. These channels have a sampling distance of 3 km at sub-satellite point (Schmetz et al., 2002). The channels used to develop the SEVIRI algorithm are highlighted while the channels ignored are primarily used for water vapor, ozone, and carbon dioxide detection. Thus, the SEVIRI algorithm uses three channels in the solar spectrum and four channels in the infrared spectrum.
The MODIS onboard the Terra and Aqua polar orbiter satellites have 36 channels over the spectral range from 0.4-14.4 µm with spatial resolutions of 250 m, 500 m, and 1 km (Savtchenko et al., 2004). A Level 2 aerosol optical thickness (AOT) operational product over both ocean and non bright land surfaces is provided by MODIS at a spatial resolution of 10 km (at nadir) by comparing measured reflectances to a lookup table of computed reflectances from a radiative transfer model (Remer, et al., 2005). The reported uncertainties over ocean and non bright surfaces are ±0.03 ± 0.05τ and ±0.05 ± 0.15τ, respectively, where τ is aerosol optical depth (AOD) or AOT (Remer, et al., 2005). Additionally, the MODIS Deep Blue Algorithm provides AOT values over deserts and other bright surfaces where the reported uncertainties are approximately 20-30% (Hsu et al., 2006). The Multi-angle Imaging SpectroRadiometer (MISR) instrument onboard the Terra satellite measures upwelling shortwave radiance in four spectral channels (446, 558, 672, and 867 nm) with nine view angles and spatial resolutions of about 250 m to 1.1 km. To produce the MISR Level 2 product (MIL2SAE, F12, 22) with a spatial resolution of 17.6 km, top-of-atmosphere radiances from 16 x 16 pixel areas of 1.1 km resolution are analyzed (Diner et al. (1999). The multispectral and multiangle instrument retrieves accurate AOT values, even over bright deserts (Christopher and Wang, 2004,
Kahn et al., 2005), with expected uncertainties of ±0.05 for AOT<0.5 and ±10% for AOT>0.5 (Martonchik et al., 1998). We use the aerosol spatial distribution from MODIS and MISR to help verify the SEVIRI results that we have developed in this paper.
A valuable validation data set used in this study is from the FAAM BAe146 research aircraft data that retrieves detailed volcanic ash measurements from the Leosphere 355 nm Lidar, the Passive Cavity Aerosol Spectrometer Probe (PCASP), and the Cloud and Aerosol Spectrometer (CAS) (Marenco et al., 2011). The FAAM BAe146 aircraft flew on six days in May 2010 where aerosol extinction and AOTs at 355 nm were retrieved along with ash mass concentrations and size distributions (Marenco et al., 2011). This study focuses on 16 May and 17 May since the volcanic ash was associated with higher AOTs on these days. We utilized the AOT measurements at 355 nm retrieved from the lidar which samples the atmosphere from 2 km above the surface to 300 m below the aircraft. Thus, the lidar AOTs exclude any boundary layer contribution, except for the 17 May case where boundary layer aerosols contribute less than 0.05 to the AOT. After integrating the AOT measurements over every minute, each retrieved AOT value corresponded to an along-track distance of 8-10 km. Note that AOT can still be derived in the presence of clouds by using the instruments onboard the BAe146 aircraft to detect and mask the cloud contaminated areas in the vertical column of air beneath the aircraft. The usefulness of BAe146 aircraft measurements has been shown in a number of papers where the aircraft measurements were analyzed along with satellite measurements (Johnson et al., 2012, Christopher et al., 2009, Naeger et al., 2013).
3. Methodology
There is a rich heritage of classification algorithms with the most common ones using the concept of spectral signatures where for example clouds ‘look different’ based on spectral signatures in some wavelengths when compared to aerosols and land. A classic paper by Saunders and Kriebel (1988) used spectral and some spatial signatures to separate pixels into cloud-free, partly cloudy, or overcast scenes. Using spectral thresholds alone can cause uncertainties in image classification since there could be spectral overlap between and among classes. Thus, it is not possible to accurately separate various classes based on limited information from spectral signatures alone.
For example, Fig. 1 is a SEVIRI RGB image on 17 May 2010 at 1330 UTC over Europe and the Atlantic Ocean where we carefully hand picked 28 samples representing volcanic ash, cloud, and clear sky ocean and land surfaces. We do not show a typical dust RGB (e.g. Francis et al., 2012) in Fig. 1 because regions of cloud can be difficult to visually separate from the underlying surface in the dust RGB. Instead, the RGB image in Fig. 1 was produced by assigning the BTD 12.0-10.8 values as the red component, the 0.6 µm reflectance as the green component, and the BTD 10.8-8.7 as the blue component. By using the 0.6 µm channel we could more easily see where small scale clouds were located over both land and ocean allowing us to pick better samples. Note that we also hand picked 28 samples on two other days during the Eyjafjallajökull volcanic eruption period, 7 May at 1100 UTC and 18 May at 1600 UTC. Overall, we hand picked 18 samples of ash over water, 6 samples of ash over land, 30 samples of cloud, and 30 samples of clear sky ocean and land.
Fig. 2a is a wavelength versus reflectivity plot for the three SEVIRI reflectivity channels showing the mean along with minimum and maximum reflectance for the 80 extracted samples where the ocean is blue, land is green, ash over water is red, ash over land is pink, ash above cloud is light blue, and cloud is black. Fig. 2b is the same as Fig. 2a except wavelength versus temperature for four SEVIRI temperature channels is displayed. For the reflectivity channels, the cloudy samples generally have a much higher reflectivity than the ocean while the mean reflectivity of ash over water is only about 5-10% higher than the ocean. However, note the large variation in the reflectance of the cloud and ash samples that make it difficult to use spectral tests alone to separate these features. Nonetheless, in general, the reflectance is staying rather constant or increasing for the cloudy samples when moving from the 0.6 to 1.6 µm channels while the reflectance is decreasing for the ash over water samples. The mean ash reflectivity drops to only about 6% at 1.6 µm which is mostly due to the fact that the majority of ash particles are generally smaller than this channel wavelength (Weber et al., 2012). Thus, spectral tests using the difference of two reflectivity channels can be used to better separate features. When analyzing the temperature trend between the 10.8 and 12.0 µm channels in Fig. 2b, the temperature generally increases with wavelength for ash but decreases for
the other features which is due to the unique characteristic of the ash imaginary refractive index being higher at 12.0 than at 10.8 µm causing the slightly lower temperatures at 12.0 µm (Prata, 1998). However, once again a large variation in the temperatures of the various features exists which makes it difficult to use only spectral tests for developing an accurate classification algorithm. Martins et al. (2002) showed the utility of using spatial (textural) measures to separate aerosols from clouds over oceans due to the mean and standard deviation for a group of aerosol pixels being different than clouds. Spatial measures are a form of texture identification where a group of aerosol pixels appear different than clouds due to several measures and one example being their homogeneity. Therefore, combining spectral and spatial information reduces the frequency of misclassifications within an image.
In this paper, we take this a step further by using temporal information along with spectral and spatial information as the high temporal resolution of geostationary satellite sensors permits the use of these tests, but only a handful of studies have actually used temporal tests (Calle et al., 2006, de Wildt et al., 2007). Calle et al. (2006) proposed a fire detection technique that utilized temporal information from the 3.9 µm SEVIRI channel and showed that false alarm rates were lower than when detecting fires without using any temporal information. Typically the temperature from the 3.9 µm channel does not encounter large variations with time, but Calle et al. (2006) found that large increases occur with the onset of fires which helps better detection of fires. Cloud detection can also be improved when using temporal information since the temporal variation of the reflectance and temperature of a pixel is usually greatly impacted by the presence of clouds. For example, when analyzing the reflectance of the 0.6 µm SEVIRI channel for a pixel over a period of time, the variation in the reflectance will be minimal in most clear sky cases but rather large for most cases where clouds are present since clouds are typically much more heterogeneous than the underlying land surface. Then, de Wildt et al. (2007) developed temporal tests using reflectance and temperature channels from SEVIRI and found that these tests helped mask clouds and cloud shadows which ultimately led to more accurate detection of snow cover. Although the temporal tests detected most clouds due to their heterogeneity, they had to rely on the spectral tests to detect the water clouds that were rather homogeneous since the reflectance and
temperature channels showed little temporal variation. Another issue that often arises when using temporal techniques is the overestimation of cloud cover especially in areas near cloud edges and in areas over broken clouds where a pixel may be cloud free in the current time-step but cloudy in the previous one. This situation can cause a significant increase in the variation of reflectance and temperature with time for a cloud free pixel.
Furthermore, freshly emitted volcanic ash may be detected as cloud when using temporal techniques since the reflectance and temperature of the pixel can vary significantly with time. Therefore, even though temporal techniques have been used successfully for detecting fires and clouds, they also encounter problems that are investigated further in this study. For instance, freshly emitted volcanic ash plumes can cause large temporal variations.
3.1 General flow of algorithm
For our algorithm, we first identify pixels that are land (or over land) and pixels that are water (or over water) to make the algorithm efficient and save computational time. This is necessary since the thresholds used to identify aerosols and clouds are different over water than over land. Classification methods are usually easier over water since water has a low visible reflectance and warmer infrared temperatures when compared to aerosols and clouds. However, over land spectral tests pose challenges since the surface reflectance and temperatures can be highly variable. After separating land and water pixels, we identify feature pixels through a temporal test over all surfaces along with a spectral test over only water. Feature pixels are simply pixels that are contaminated with any type of aerosol or cloud. Then, all pixels labeled as feature are fed into the second part of the algorithm that identifies cloudy pixels through spectral, spatial, and temporal tests. If the feature pixel passes any one of these tests, then it is labeled as cloud. If the pixel fails all of these tests, then the pixel is labeled as aerosol. Since the aerosol spatial distribution maps can be produced every 5 minutes when using SEVIRI, they can provide near real-time information on the location of volcanic ash which is a major aviation concern (Casadevall, 1992). Also, understanding the spatial distribution of aerosol and cloud is very important as this is the first step to accurately quantifying the cloud and aerosol radiative forcing (Kaufman et al., 2002).
3.2 Input data for algorithm
The U.S. Geological Survey (USGS) global land cover characteristics database version 2.0, SEVIRI viewing and solar zenith angles, and the SEVIRI channels highlighted in Table 1 are input into our algorithm. SEVIRI viewing and solar zenith angles are primarily used for masking sun glint regions while the SEVIRI channels provide the critical reflectivity and temperature values for each pixel. The USGS global land cover data is used immediately in the algorithm to separate land and water pixels and to find bright (e.g. desert) and non-bright (e.g. vegetation) pixels over land since certain threshold tests are not valid over bright surfaces with high reflectivity. Next, we develop a clear sky reflectance map by finding the minimum top of atmosphere (TOA) 0.6 µm reflectance for each pixel over a 14 day period (Jolivet, et al., 2008). In order for this algorithm to be used operationally, the 14 days prior to the time of interest is used to find the minimum TOA reflectance for a pixel. For example, if analyzing a 1300 UTC SEVIRI image on 19 April 2010, then we find the minimum 0.6 µm reflectance from 5 April until 19 April at 1300 UTC for each pixel which generates the clear sky reflectance map. For bright surfaces determined by the USGS global land cover map, we find the highest 10.8 µm temperature during the 14 day period and then extract the 0.6 µm reflectance from this particular pixel. Dust over desert regions can reduce the observed TOA reflectance below the actual clear-sky reflectance since dust is slightly absorbing at 0.6 µm (Patadia et al., 2009).
3.3 Algorithm Over Land
After generating the clear sky reflectance maps, the algorithm over land begins with a snow detection scheme (not shown in Table 2) so that these bright pixels can be ignored throughout the remainder of the algorithm. This snow detection scheme uses the normalized difference snow index (NDSI), which takes advantage of snow being more reflective at 0.6 µm than at 1.6 µm (Riggs and Hall, 2004), along with other temporal tests. For all the temporal tests used in Table 2, the standard deviation (\(\sigma\)) of three successive 15 minute SEVIRI images centered on the current image is computed for the highlighted channels in Table 1. Temporal tests help reduce the frequency of falsely detected clouds as snow (Riggs and Hall, 2004), and for this study we use the \(\sigma\) of the 1.6 and 10.8 µm as the reflectance and temperature of snow generally varies slowly with time (de Wildt et al., 2007). However, we will not go any further into the specifics of the
snow detection scheme because it is not critical to the main goal of the algorithm and the results of this paper.
The first test in Table 2, which uses the 0.6 µm clear sky reflectance maps to determine whether a pixel is a feature, is the most important to the success of the algorithm. If the difference between the 0.6 µm reflectance for the current SEVIRI pixel and its clear sky reflectance is greater than 1.5% (i.e. \(|0.6 \text{ µm}_{\text{cur}} - 0.6 \text{ µm}_{\text{clr}}| > 1.5\%\)) in Table 2), then the pixel is classified as a feature. The 0.6 µm_{cur}–0.6 µm_{clr} test detects features well since in the presence of an atmospheric feature such as ash where the 0.6 µm reflectance is typically higher than in clear sky conditions. Fig. 3 shows bispectral plots for the SEVIRI channels of most interest to this study from the samples used to produce Fig. 2. The colors represent the same features as in Fig. 2. Fig. 3a shows the 0.6 µm_{cur}–0.6 µm_{clr} values on the x-axis and the BTD10.8-12.0 values on the y-axis. The ocean (blue) and land (green) samples have 0.6 µm_{cur}–0.6 µm_{clr} values mostly less than 1.5%. There are a few land pixels with values slightly higher than 1.5% which is likely due to some cloud contamination occurring within the land samples as the persistent cloud cover over land made it difficult to hand pick completely clear sky samples. Nonetheless, there is quite good separation between the clear sky samples and the atmospheric feature samples when analyzing the 0.6 µm_{cur}–0.6 µm_{clr} values alone which gives us confidence in using this test. However, there is some significant overlap between the ash (red and pink) and cloud (black) samples which is why this test is only used to separate clear sky and atmospheric feature pixels. Note that we introduce the absolute value in this first test in order to account for scenarios over bright land surfaces where the higher 0.6 µm clear sky reflectance over these surfaces can completely mask the cloud or aerosol signal. In fact, the presence of an absorbing ash or dust layer over a bright surface can actually reduce the 0.6 µm reflectance below the clear sky reflectance.
The second test in Table 2 which uses the BTD between the 8.7 and 10.8 µm channels (BTD 8.7-10.8) along with BTD 10.8-12.0 has been shown to detect ice clouds quite accurately (Zhang et al., 2006). Thus, this test is specifically used to detect clouds in our study over all pixels including the feature pixels just detected by the first test. Fig. 3b shows the BTD 8.7-10.8 on the x-axis and BTD 10.8-12.0 on the yaxis where there is not as good separation between the various sample types as in Fig. 3a. However, these tests have some utility in separating atmospheric features as the samples with BTD 8.7-10.8 > -2 K and BTD10.8-12.0 > 0 K are nearly all cloud pixels. As a result, we use these threshold values in this test to detect clouds. Also, note that the ash samples (red) that are associated with BTD 8.7-10.8 > -2 K have BTD 10.8-12.0 values primarily less than 0 K which means most ash pixels will not be classified as cloud by this test.
Next, the algorithm separates the feature pixels as cloud or aerosol by using a series of cloud detection tests. If a feature pixel is not labeled as cloud by the cloud detection tests, then the pixel is labeled as aerosol. The first cloud detection test labels pixels as cloud when the 10.8 µm < 240 K and BTD 10.8-12.0 > -0.5 K. Freshly emitted volcanic ash can have a temperature that is closely related to its height so it is possible that the 10.8 µm temperature can be less than 240 K for ash. Therefore, we also include the BTD 10.8-12.0 µm test since freshly emitted volcanic ash will typically have strongly negative values. Fig. 3b shows an example of the strongly negative BTD 10.8-12.0 values that can occur with freshly emitted ash where the fresh ash samples have a BTD 10.8-12.0 µm around -1 K and BTD 8.7-10.8 near 0 K. Then, we apply a test that labels a pixel as cloud if the 1.6 µm > 30% and BTD 10.8-12.0 > -0.5 K. This study found that even the thickest ash regions will typically have 1.6 µm < 30% after picking samples of the freshly emitted ash nearby the Eyjafjallajökull volcano on 7 May. is a scatter plot with the 1.6 µm on the x-axis and BTD 10.8-12.0 on the y-axis which clearly shows that all our samples with 1.6 µm > 30% are cloud contaminated. The next cloud test simply labels the pixel as cloud if the BTD 10.8-12.0 > 1.5 K. Fig. 3c shows the utility of this test as ash samples all have BTD 10.8-12.0 < 1.5 K while the cloudy samples are dominant above this threshold. Thin ash (AOD < 0.2) can have very similar BTD 10.8-12.0 as the land surface since areas of thin ash will have minimal impact on terrestrial radiation. Consequently, thin ash regions can potentially be labeled as cloud by this test but only if the |0.6 µm_{cur}-0.6 µm_{clt}| test labels it as a feature. These thin ash regions do not pose a threat to aviation so it is not a major issue if thin ash is missed by our algorithm.
The remaining cloud detection tests in Table 2 utilize either spatial or temporal techniques. In this study, the temporal tests take three successive 15 minute SEVIRI scans and calculate the $\sigma$ for each pixel which is referred to as a $\sigma$T test throughout the remainder of the paper. We decided to use only 3 successive SEVIRI images to calculate $\sigma$ because using more successive images increases the likelihood that both aerosol and cloud could be included in the $\sigma$ computation for a pixel where aerosol and cloud reside nearby, and we want to limit these scenarios as much as possible. Also, by using only 3 successive images, this algorithm can be used in time sensitive situations, such as volcanic ash plumes interfering with air traffic, that require real-time decision making. We use $\sigma$T tests with the 1.6 $\mu$m channel where the appropriate thresholds were chosen based on analyzing the scatter plot in. All the ash over land samples (pink) were associated with $\sigma$T 1.6 $\mu$m < 1.5% while cloudy samples were dominant above this threshold. Ash plumes are generally more homogeneous than clouds which is the reason for the fairly good separation between ash and cloud samples in Fig. 3d. However, a portion of the cloud samples have very low $\sigma$T 1.6 $\mu$m and cannot be labeled as cloud by this test.
The next test in Table 2 uses the $|0.6 \mu m_{cur} - 0.6 \mu m_{clr}|$ technique along with BTD 10.8-12.0 since we observed good separation between the ash and cloud samples in this multi-spectral space as revealed by Fig. 3a. This test labels clouds when the $|0.6 \mu m_{cur} - 0.6 \mu m_{clr}| > 3.5\%$ and BTD 10.8-12.0 > 0 K. We include the BTD 10.8-12.0 technique in this test since moderate (AOD > 0.5) and thick (AOD > 1.0) ash regions with BTD 10.8-12.0 < 0 K can have $|0.6 \mu m_{cur} - 0.6 \mu m_{clr}| > 3.5\%$. Thus, by including the BTD 10.8-12.0 technique the moderate and thick ash plumes will generally not be labeled as cloud. In fact, Fig. 3a shows that as the $|0.6 \mu m_{cur} - 0.6 \mu m_{clr}|$ increases beyond 3.5% the BTD 10.8-12.0 primarily decreases with increasing $|0.6 \mu m_{cur} - 0.6 \mu m_{clr}|$. Fig. 3a suggests that this test can be quite powerful in accurately labeling atmospheric features (e.g. cloud and dust) correctly.
The final two tests utilize spatial techniques along with the BTD 10.8-12.0 technique once again. The spatial techniques (i.e. $\sigma$s tests) compute the $\sigma$ over a 3 X 3 pixel region. For the first test, if $\sigma$s 12.0 $\mu$m > 1.5 K and the BTD 10.8-12.0 > 0 K, then the center pixel of the 3 X 3 pixel group is classified as a cloud. The $\sigma$s and $\sigma$T tests
work on the similar principles of cloud typically being more heterogeneous than aerosol except that the $\sigma$s test operates in space instead of time. This is demonstrated in Fig. 3e where the cloudy samples tend to have higher $\sigma$s 12.0 $\mu$m values than shown for the ash pixels, but there is considerable overlap between a portion of the cloudy samples and the ash samples. Consequently, we introduce one more spatial test that has the ability to detect many of these cloudy samples that went undetected by the $\sigma$s 12.0 $\mu$m test. This second spatial test labels cloud when the $\sigma$s 1.2 $\mu$m > 1.2% and BTD 10.8-12.0 > 0 K, and the scatter plot that shows the separation of the various samples in this multi-spectral space is displayed in Fig. 3f. We see that the cloudy samples that were associated with very low $\sigma$s 12.0 $\mu$m and BTD 10.8-12.0 near 0 K in Fig. 3e are detectable when using the $\sigma$s 1.6 $\mu$m technique. There is more scatter with the ash samples in Fig. 3f but these ash samples with $\sigma$s 1.6 $\mu$m > 1.2% have mostly BTD 10.8-12.0 < 0 K which means that they will not be labeled as cloud by this test. These are likely thick ash plumes (AOD > 1.0) that tend to be more heterogeneous. However, we do notice that a few ash samples will be incorrectly labeled as cloud since they have BTD 10.8-12.0 > 0 K and $\sigma$s 1.6 $\mu$m > 1.2%. These ash samples were actually taken near the boundaries of thick ash plumes which means this spatial test can encounter problems due to strong boundaries occurring in SEVIRI imagery. Lastly, the feature pixels that fail all of the final cloud detection tests are labeled as aerosol. Note that we do show ash above cloud samples (light blue) in the panels in Fig. 3, but we do not discuss them in the preceding paragraphs. The main point for showing the ash above cloud samples is to stress that it is extremely difficult to separate the ash above cloud from the ash-free cloud samples. The other possible way to separate the ash above cloud from the ash-free cloud samples is by using the BTD 10.8-12.0 technique which our algorithm is using in nearly all the tests. Therefore, this algorithm is capable of detecting ash above cloud samples only if the ash influences a negative BTD 10.8-12.0 value. We will show examples of our algorithm detecting ash above cloud in Section 4.
3.4 Over Water Algorithm
We briefly discuss the over water algorithm since it has many similarities to the over land algorithm. The only differences between the land and water algorithms are
the slightly lower thresholds that are used to detect clouds for the $\sigma$s 1.6 $\mu$m and $\sigma$s 12 $\mu$m techniques and the inclusion of the 1.6 $\mu$m – 0.6 $\mu$m technique. The threshold is lowered to 1% for the $\sigma$s 1.6 $\mu$m test and 1.0 K for the $\sigma$s 12 $\mu$m test due to the relative homogeneity of the water. The 1.6 $\mu$m – 0.6 $\mu$m test can be quite powerful over the homogeneous water surface as indicated in Fig. 3g where 1.6 $\mu$m – 0.6 $\mu$m is on the x-axis and the BTD 10.8-12.0 on the y-axis. The clear-sky ocean samples (blue) and ash over water samples (red) have very similar 1.6 $\mu$m – 0.6 $\mu$m values ranging mostly from -7% to -3%. Even the thick ash samples with BTD 10.8-12.0 near -2.0 K have 1.6 $\mu$m – 0.6 $\mu$m values no larger than -3%. Nevertheless, we include the BTD 10.8-12.0 technique in this test to ensure that thick ash does not get labeled as cloud. The pixel is labeled as cloud by this test when the 1.6 $\mu$m – 0.6 $\mu$m > -2% and BTD 10.8-12.0 > -1 K. Similar to the over land algorithm, after applying all the cloud detection tests to the feature pixels, the pixels that fail all the tests and remain as features are labeled as aerosol.
4. Results and Discussion
4.1 13 May 2010 Case
Fig. 4a is a SEVIRI dust RGB image on 13 April 2010 at 1200 UTC when a substantial amount of ash was being emitted from the Eyjafjallajökull volcano. The dust RGB image was produced by assigning the BTD 12.0-10.8 values as the red component, the BTD 10.8-8.7 as the green component, and the BTD 10.8 $\mu$m as the blue component. The volcanic ash is identified in the SEVIRI dust RGB image by the reddish colors extending eastward from Iceland. Fig. 4b is a SEVIRI 0.6 $\mu$m visible image where the clouds appear white against a dark background. The visible image shows extensive cloud coverage across the domain with clouds evident in the location of the volcanic ash plume. This ash plume is primarily associated with BTD 10.8-12.0 < 0 K with strongly negative values of -4 K within the core of the plume (i.e. Fig. 4c). Note that a substantial amount of pixels not associated with the main ash plume also possess negative BTD 10.8-12.0 as revealed by the reddish colors in Fig. 4c. According to the SEVIRI dust RGB and the visible image, these pixels are primarily cloudy pixels that do not appear to be associated with any ash. For
instance, the clouds to the southwest of Iceland have a BTD 10.8-12.0 as low as -0.4 K. The final results of the SEVIRI algorithm are in Fig. 4d with the pixels labeled as clear sky (white), cloud (gray), and aerosol (orange). Our algorithm is able to identify the ash plume even though clouds reside beneath it since many of the cloud tests in Table 2 include the BTD 10.8-12.0 technique. Also, the ash free cloudy pixels that were associated with the negative BTD 10.8-12.0 in Fig. 4c are labeled as cloud by our algorithm. Therefore, overall the algorithm performs well for this particular case.
A few pixels are labeled as aerosol outside of the main ash plume which we further investigate by analyzing the MISR and MODIS Aqua AOD around the time of interest (~1300 UTC) on 13 May. Note that MISR has limited spatial coverage due to its limited field of view, but the MISR transect occurring near the center of the domain passes over the eastern section of the ash plume (Fig. 4e). The MISR fails to retrieve any significant area of AOD for the ash plume due to the fact that the retrieval algorithm recognizes the plume as mostly cloud. The MODIS also has difficulty retrieving any AOD for the ash plume due to the extensive cloud coverage in this region. The lack of MISR and MODIS AOD retrievals of the ash plume is not surprising since their algorithms attempt to retrieve AOD for cloud-free regions only. However, the MODIS retrieves AOD where our SEVIRI algorithm labels clear sky pixels across much of the domain. Much of the MODIS AOD across the domain is less than about 0.15 which suggests that the aerosol concentrations are very low. Volcanic ash with low concentrations (< 0.2 g m$^{-2}$) pose no threat to aviation. Therefore, the fact that our algorithm is not detecting these areas of low AOD is not problematic. Some limited areas of AOD > 0.2 appear just south of Great Britain and southeast of Iceland in the MODIS AOD image which our algorithm mostly identifies as cloud or clear sky. The fact that some of these areas of AOD > 0.2 reside among clouds as seen in the SEVIRI dust RGB and visible image suggest that these may be bad retrievals. For instance, the AOD > 0.2 to the southeast of Iceland is retrieved in a dominantly cloudy region. The retrievals of AOD > 0.2 just south of Great Britain are also occurring either among cloud or adjacent to clouds. It is known that the MODIS AOD tends to have a high bias
when the retrievals are adjacent to clouds (Zhang et al., 2006). Nonetheless, a close inspection of the SEVIRI dust RGB reveals pinkish colors over the ocean just to the south of Great Britain which implies that some ash may be present here. The fact that our algorithm labels some pixels as aerosol in this same location suggests that the MODIS AOD > 0.2 in this particular region may be real. Fig. 4d also reveals that our algorithm may falsely detect aerosols along cloud edges. These false detections are difficult to see in Fig. 4d but there are a few occurrences among the cloud edges to the south of Iceland.
4.2 16 and 17 May 2010 Case
Figs. 5a-f are similar to Figs. 4a-f except that the former pertain to the 17 May 2010 case study at 1300 UTC where a significant area of volcanic ash resided over the North Sea around 56°N and 7°W (Turnbull et al., 2012). This ash plume is not as apparent on the SEVIRI dust RGB due to the fallout of ash particles during its transport from Iceland. In fact, it is difficult to decipher the ash plume from the low level clouds (yellowish colors) across the domain. Analyzing both the dust RGB and visible image along with the BTD 10.8-12.0 map (i.e. Fig. 5c) helps better understand where the potential ash regions are located. The pink to yellow colors associated with the ash plume in the dust RGB appear darker than the whiter clouds in the visible image across the North Sea. By this time, the ash plume has become only slightly more reflective than the background ocean. There are some clouds among the ash plume that are only noticeable when closely inspecting the visible image which shows the utility of analyzing both the dust RGB and visible image. The BTD 10.8-12.0 map shows a considerable area over the North Sea and Norwegian Sea that has BTD 10.8-12.0 < -1 K suggesting that ash is present across the area. Our algorithm is easily able to identify these areas where the BTD 10.8-12.0 < -1 K and thick ash is likely present. According to the dust RGB and visible image, our algorithm successfully disregards cloud contaminated areas within the ash plume region over the North Sea. For example, clouds are shown off the coast of the Netherlands (~56°N, 5°E) and this area is labeled as cloud by our algorithm. Overall, our algorithm appears to identify clouds very well across the domain which is critical as the final aerosol spatial distribution maps depend on the success of the cloud detection. Moreover,
our algorithm identifies aerosol in locations across the North Sea that have BTD 10.8-12.0 > 0 K and appear to be cloud-free. These results are in fairly good agreement to the spatial distribution of MODIS AOD across the North Sea which implies that our algorithm is performing accurately on this day. MODIS retrieves AOD primarily ranging from 0.2 to 0.4 across the North Sea with the exception of a few higher AOD regions where values near 0.7 are present. The location of the higher AOD regions coincide with BTD 10.8-12.0 < -1 K while the AOD from 0.2 to 0.4 coincide with near zero to positive BTD 10.8-12.0 values. The MISR AOD agrees fairly well with MODIS in the limited locations of MISR availability over the North Sea and Norwegian Sea which gives us better confidence that the MODIS retrievals are good on this day. Although our algorithm is able to detect these areas of optically thinner ash identified by MODIS and MISR, it is likely that they are below the mass concentration threshold of 0.2 g m$^{-2}$ and do not pose a threat to aviation (Francis et al., 2012; Prata and Prata, 2012). Again, our algorithm mostly misses the very low AOD regions below about 0.2 that are detected by MODIS and MISR. For example, our algorithm labels the area just north of Great Britain as clear sky while the MISR and MODIS retrieves AOD around 0.15. Finally, note that our algorithm is able to detect the thick ash over the Norwegian Sea (~64°N, 0°E) even though it is above a considerable area of clouds according to the SEVIRI visible image. Once again, this shows the ability of our algorithm to detect thick ash above cloud which can pose a threat to aviation.
The FAAM BAe146 aircraft flights on 16 and 17 May are very helpful for verifying the proposed SEVIRI algorithm. Fig. 6c is a SEVIRI RGB image on 16 May at 1500 UTC with the intricate BAe146 aircraft flight track shown in white. The BAe146 aircraft took off in southeast England (52.1°N, 0.3°W) at approximately 1255 UTC and landed in northwestern France (47.7°N, 2.1°W) at about 1810 UTC. Fig. 6a has 355 nm AOD from the BAe146 aircraft in red with the corresponding AOD scale on the right y-axis and SEVIRI BTD10.8-12.0 in black with its scale on the left y-axis. The dots along the black line indicate the results from the SEVIRI algorithm along the aircraft flight with green, blue, and red denoting clear, cloud, and aerosol, respectively. Fig. 6b shows SEVIRI BTD10.8-12.0 again in black along with 0.6 µm reflectivity in blue with its scale
on the y-axis from 0 to 50%. A nearest pixel approach is used to collocate SEVIRI to the BAe146 aircraft in space while we find the closest SEVIRI overpass time to each point along the BAe146 aircraft track to collocate in time. Thus, 15 minute SEVIRI scans beginning 1130 UTC and ending 1700 UTC were used to produce Fig. 6a-b even though only the 1500 UTC SEVIRI RGB imagery is in Fig. 6c.
The aircraft flight began in cloudy conditions across southeastern England and then headed northwest into an ash plume with scattered clouds as shown by Fig. 6c where the ash is highlighted by the pinkish colors and clouds by the green and yellowish colors. Since clouds were the dominant feature in southern England, AOD was not reported but as the aircraft tracked northwestward the AOD jumped to about 0.2 until thick ash was measured at about 55°N and 4.3°W with an AOD of nearly 0.9. The SEVIRI algorithm accurately classifies clouds in southern England, but then classifies a mix of clear skies, clouds, and aerosols where the low AOD of 0.2 is measured which again suggests that the SEVIRI algorithm has uncertainties in detecting optically thin aerosol regions. However, Fig. 6b shows several significant increases in 0.6 µm reflectivity in the low AOD region which hints at cloud contamination. Furthermore, the aerosol extinction coefficient profiles from the BAe146 aircraft on 16 May shown in Marenco et al. (2011) reveal some low level clouds in the low AOD region which suggests the SEVIRI algorithm is classifying clouds properly in this region. When the AOD reaches nearly 0.9, the SEVIRI algorithm classifies nearly all aerosol pixels adequately except for a few pixels which are associated with 0.6 µm > 40% indicating possible cloud contamination. The aerosol extinction coefficient profiles in Marenco et al. (2011) also indicate low level cloud contamination below the thick ash. Thus, according to the BAe146 aircraft data, the SEVIRI algorithm is accurate in labeling a few cloud pixels among the ash. Then, another region of low AOD is measured by the aircraft before flying over thicker ash around 55.2°N and 3.9°W with an AOD of about 0.7. The aerosol is almost entirely missed by the SEVIRI algorithm in this low AOD region as the algorithm classifies mostly clouds. The highly varying 0.6 µm reflectivity among the low AOD suggests that clouds are a dominant feature in this region. In Marenco et al. (2011), low level clouds are revealed all along this section of the BAe146 flight track further hinting at the accuracy of the SEVIRI algorithm. The algorithm classifies some aerosol pixels in the
higher AOD region, but clouds are classified more frequently here as the 0.6 µm reflectivity has a significant increase near the minimum in BTD10.8-12.0 indicating the presence of clouds among the thick ash. Also, fairly thick lower level clouds are shown along the aerosol extinction profiles in Marenco et al. (2011) with this thicker ash region. Next, the aircraft encounters very thin ash along its track as AOD drops to near zero values. As expected the SEVIRI algorithm fails to detect any of this ash and classifies mostly clear skies along this portion of the aircraft track. The aircraft flies over one more noteworthy ash region as AOD jumps to about 0.4 and then quickly drops to 0.2 at about 53.8°N and 2.2°W. The ash associated with the AOD of 0.4 is successfully detected by the algorithm which appears to be cloud-free from analyzing the 0.6 µm reflectivity and aerosol extinction profiles in Marenco et al. (2011). However, immediately as the AOD decreases clouds become an issue once again as the 0.6 µm reflectivity jumps to about 35%.
The 17 May BAe146 aircraft flight is overlaid in white on the SEVIRI RGB image from 1400 UTC on that same day in Fig. 7c. However, for this flight, the aircraft started in northwestern France at 1126 UTC and landed in southeast England at 1658 UTC. As seen in the RGB image, the aircraft encountered the main ash plume over the North Sea while scattered clouds impacted the flight over England and Scotland. Fig. 7a-b are the same as Fig. 6a-b except the aircraft AOD and SEVIRI measurements from 17 May are shown. The times when the aircraft were above the scattered clouds over land are clearly seen in Fig. 7b by the very significant increases in 0.6 µm reflectivity, and the SEVIRI algorithm successfully classifies these regions as cloud. After the first period of scattered clouds over land, the aircraft flies over ocean (~53°N, 2.5°W) before making a west to east path over land. When the aircraft is over the ocean, the SEVIRI algorithm classifies mostly clear skies with a mix of some cloud and aerosol. At this time, 355 nm AOD from the aircraft is very low with most values being less than 0.1 which suggests the SEVIRI algorithm has difficulty detecting aerosol over water when the AOD is < 0.1. The aircraft measures AOD near 0.2 during its brief west-east transect over land, but the SEVIRI algorithm classifies cloud in this region, and the algorithm appears to be correct according to the strong peak in 0.6 µm reflectivity and the BAe146 aerosol extinction profiles along this section of the aircraft track in Marenco et al. (2011). After traversing
land, the aircraft immediately encounters the main ash plume when flying over the North Sea as indicated by the large increase in 355 nm AOD to about 0.6 in Fig. 7a. However, the aircraft then descends beneath the ash plume which is why the AOD drops to zero while the SEVIRI algorithm detects aerosols. When the aircraft ascends, it measures the ash plume again as the AOD increases to nearly 0.4 before descending and measuring zero AOD the remainder of its flight path. From analyzing the SEVIRI 0.6 µm reflectivity along with the SEVIRI RGB image, it appears that cloud contamination is very minimal across the main ash plume region. Thus, the algorithm performs very well over the ash plume region as only one cloud pixel is detected amongst the aerosol pixels.
4.3 Validation experiment
In order to obtain a better understanding of the accuracy of our SEVIRI algorithm, we perform an additional experiment where we choose 28 independent samples for three different days and times (i.e. 7 May at 1100 UTC, 11 May at 1300 UTC, and 18 May at 1600 UTC) during the Eyjafjallajökull volcanic eruption period. An example of the 28 samples chosen for the 7 May at 1100 UTC case is shown in Fig. 8a where boxes 1-4 are clear sky ocean, 5-12 are volcanic ash, and 13-28 are clouds. We had very limited clear sky land pixels available on this day which explains why we did not choose any samples of clear sky land. The 84 samples taken on these three days represent the truth. Then, we run our SEVIRI algorithm for these three cases and compare the results against truth samples. Overall, we picked 30 ash over water samples on these three days which gave a total of 1080 individual ash pixels to compare against our algorithm results as the size of the each sample spanned 6 by 6 boxes. According to the truth samples, the algorithm performed very well as 936 of the 1080 pixels were accurately labeled as ash by our algorithm giving a success rate of 87%. Not surprisingly, our algorithm performed even better with identifying clouds. Overall, the 60 samples of clouds that we picked provided us with 2160 individual cloud pixels as truth. Our algorithm successfully labeled 2127 of these truth pixels as cloud which gives a 98% success rate for cloud identification. Of course, when performing a validation experiment where we are carefully hand picking truth samples, it is easy to make an algorithm appear more accurate than reality by choosing samples that should be easy for the algorithm to
handle. For this validation experiment, we chose samples that, in our opinion, would be easy to very difficult for the algorithm to identify. Finally, we present the SEVIRI algorithm results for the 7 May at 1100 UTC case where the majority of the ash plume is accurately labeled by the algorithm. This is another case where ash resided above clouds which can make it difficult to identify the ash due to the presence of the cloud. In fact, our algorithm is not able to identify the full extent of the ash plume since the BTD 10.8-12.0 values increase to near or above 0 K. As a result, our algorithm recognizes parts of the ash plume as cloud.
5. Conclusions
In this study we have developed a unique algorithm combining spectral, spatial, and temporal threshold tests using SEVIRI measurements to separate between clear skies, clouds, and aerosols. The algorithm is capable of detecting both dust and ash, but for this paper we only focus on the Eyjafjallajokull volcanic eruption period during April and May 2010 where substantial ash was transported from the volcano to over the North Sea and Europe. Aerosol (e.g. ash) spatial distribution maps were generated every hour during the daytime beginning with the initial eruption on 14 April and ending on 23 May. In this paper we focus specifically on the daytime volcanic ash cases on 13 May, 16 May, and 17 May when numerous sources of validation data were available. By using MODIS, MISR, and BAe146 aircraft data as verification data, we show that the algorithm is capable of generating accurate aerosol spatial distribution maps for solar zenith angles < 65°. First, the SEVIRI aerosol spatial distribution maps show important similarities to the MODIS and MISR AOD products which suggests that the proposed algorithm works well. Second, the BAe146 aircraft shows that the SEVIRI algorithm detects nearly all ash regions over both land and water when AOD > 0.2. However, the MODIS, MISR, and BAe146 aircraft data suggests that the algorithm may encounter some problems detecting ash when AOD < 0.1 over water and AOD < 0.2 over land. We noticed that at solar zenith angles > 65° the aerosol plumes that were once identified by our algorithm begin converting to cloud. Another major limitation of this algorithm is that it can only be applied during daytime, and for these high latitude regions daytime hours can be severely limited.
Since the damaging effects of volcanic ash to commercial airplanes can be life threatening, accurately tracking ash during volcanic eruption periods is vital. Polar orbiting satellite sensors do not have the temporal resolution to effectively track volcanic ash. Thus, geostationary sensors, such as SEVIRI, are absolutely critical for tracking volcanic ash and ensuring the safety of people onboard commercial airplanes. The accurate aerosol spatial distribution maps which can be generated every 15 minutes by the proposed SEVIRI algorithm can serve as an extremely important tool during volcanic eruptions.
Acknowledgements. This research is sponsored by NASA’s Radiation Sciences, and ACMAP programs. Special thanks to Jim Haywood, Ben Johnson, and Franco Marenco for the aircraft data used in this paper.
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(a) BTD10.8–12.0 (K)
(b) AOD (355 nm)
(c) Latitude Longitude
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Fig. 1. SEVIRI RGB image (see text for details) on 17 May 2010 at 1330 UTC over Europe and the Atlantic Ocean where the 28 boxes indicate the location of extracted samples for various scenes of clear sky water (boxes 1-4), clear sky land (boxes 4-8), ash over water (boxes 9-14), and cloud (boxes 15-28).
Fig. 2. a) Wavelength versus reflectivity plot for the three SEVIRI reflectivity channels showing the mean along with minimum and maximum reflectance for the 80 extracted samples where the ocean is blue, land is green, ash over water is red, ash over land is pink, ash above cloud is light blue, and cloud is black. b) Same as panel (a) except wavelength versus temperature for four SEVIRI temperature channels is displayed.
Fig. 3. Bispectral plots for the SEVIRI channels of most interest to this study from the samples in Fig. 2 where ocean is blue, land is green, ash over water is red, ash over land is pink, ash above cloud is light blue, and cloud is black. a) $0.6 \mu m_{cur} - 0.6 \mu m_{clr}$ versus BTD 10.8-12.0, b) BTD 8.7-10.8 versus BTD 10.8-12.0, c) 1.6 $\mu m$ versus BTD 10.8-12.0, d) $\sigma T$ 1.6 $\mu m$ versus BTD 10.8-12.0, e) $\sigma s$ 12.0 $\mu m$ versus BTD 10.8-12.0, e) $\sigma s$ 0.6 $\mu m$ versus BTD 10.8-12.0, and f) 1.6 $\mu m$ – 0.6 $\mu m$ versus BTD 10.8-12.0.
Fig. 4. a) SEVIRI dust RGB image on 13 May 2010 at 1200 UTC when a substantial amount of ash was being emitted from the Eyjafjallajökull volcano. The volcanic ash is identified in the SEVIRI RGB image by the reddish colors extending east of Iceland. b) SEVIRI 0.6 $\mu m$ visible image where clouds appear white against a dark background. c) BTD 10.8-12.0 map. d) Final results of the SEVIRI algorithm with the pixels labeled as clear sky (white), cloud (gray), and aerosol (orange). e) MODIS Aqua AOD results for 13 May where MODIS pixels with cloud fraction larger than 80% are removed. f) MISR AOD across the region on this day.
Fig. 5. Panels (a)-(f) are same as in Fig. 4 except that this is a SEVIRI RGB image on 17 May 2010 at 1300 UTC where a significant area of volcanic ash resided over the North Sea around 56°N and 7°W.
Fig. 6. a) 355 nm AOD from the BAe146 aircraft in red with the corresponding AOD scale on the right y-axis and SEVIRI BTD10.8-12.0 in black with its scale on the left y-axis. The dots along the black line indicate the results from the SEVIRI algorithm along
the aircraft flight with green, blue, and red denoting clear, cloud, and aerosol, respectively. b) SEVIRI BTD10.8-12.0 again in black along with 0.6 µm reflectivity in blue with its scale on the y-axis from 0 to 50%. c) SEVIRI RGB image on 16 May at 1500 UTC with the intricate BAe146 aircraft flight track shown in white. The BAe146 aircraft took off in southeast England (52.1°N, 0.3°W) at approximately 1255 UTC and landed in northwestern France (47.7°N, 2.1°W) at about 1810 UTC.
**Fig. 7.** Panels a-b) are the same as panels a-b) in Fig. 6 except the aircraft AOD and SEVIRI measurements from 17 May are shown here. c) The 17 May BAe146 aircraft flight is overlaid in white on the SEVIRI RGB image from 1400 UTC where the aircraft took off in northwestern France at 1126 UTC and landed in southeast England at 1658 UTC.
**Fig. 8.** a) SEVIRI RGB image on 7 May 2010 at 1100 UTC over Europe and the Atlantic Ocean where the 28 boxes indicate the location of extracted samples for various scenes of clear sky water (boxes 1-4), ash above cloud (boxes 5-12), and ash free cloud (boxes 13-28). b) SEVIRI algorithm results for this 7 May case.
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| Channel | Center (µm) | Min (µm) | Max (µm) |
|---------|-------------|----------|----------|
| 1 | 0.635 | 0.56 | 0.71 |
| 2 | 0.81 | 0.74 | 0.88 |
| 3 | 1.64 | 1.5 | 1.78 |
| 4 | 3.9 | 3.48 | 4.36 |
| 5 | 6.25 | 5.35 | 7.15 |
| 6 | 7.35 | 6.85 | 7.85 |
| 7 | 8.7 | 8.3 | 9.1 |
| 8 | 9.66 | 9.38 | 9.94 |
| 9 | 10.8 | 9.8 | 11.8 |
| 10 | 12 | 11 | 13 |
| 11 | 13.4 | 12.4 | 14.4 |
Table 1. SEVIRI channels with the center, minimum, and maximum wavelengths where the channels used in the SEVIRI algorithm are highlighted in red.
| Tests |
|-------|
| **Feature Tests** |
| $|0.6 \mu m_{CUR} - 0.6 \mu m_{CLR}| > 1.5\%$ |
| **Cloud Tests** |
| BTD 8.7-10.8 > -2 K and BTD 10.8-12.0 > 0 K |
| $10.8 \mu m < 240$ K and BTD 10.8-12.0 > -0.5 K |
| $1.6 \mu m > 30\%$ and BTD 10.8-12.0 > -0.5 K |
| BTD 10.8-12.0 > 1.5 K |
| $\sigma T$ 1.6 $\mu m > 1.5\%$ and BTD 10.8-12.0 > 0 K |
| $|0.6 \mu m_{CUR} - 0.6 \mu m_{CLR}| > 3.5\%$ and BTD 10.8-12.0 > 0 K |
| $\sigma s$ 1.6 $\mu m > 2.5\%$ and BTD 10.8-12.0 > 0 K |
| $\sigma s$ 12.0 $\mu m > 1.5$ K and BTD 10.8-12.0 > 0 K |
Table 2. Outline of the algorithm applied over land which shows the various thresholds used for the feature tests and cloud tests.
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Western Australian business confidence has risen to its highest level in 13 years, according to the December edition of the CCIWA Business Confidence Survey. The sharp improvement in confidence across industries was primarily driven by strength in the mining sector. Other factors boosting confidence include the safe reopening of interstate borders with ‘very low risk’ States and news of global vaccine progress, as well as continued support from government stimulus measures and record low interest rates.
At the same time, businesses remain concerned about the availability of skilled labour, rising international trade tensions and the possibility that WA or other States could suffer a new outbreak of COVID-19, triggering the return of social distancing measures and ‘hard’ border restrictions.
**Short-term outlook surges as interstate borders reopen**
Confidence in the short-term (3 months) outlook is at its highest level since December 2007, driven by a significant rise in the proportion of WA businesses expecting stronger economic conditions.
**Business Confidence - December 2020**
- **Short-term confidence highest level since December 2007**
- **1 out of 3 (35%) businesses identified skilled labour shortages as the largest barrier to growth** over the coming year. Including 52% businesses in the resource sector
- **2 out of 3 (67%) construction and retail businesses rely to a ‘high’ extent on the success of WA’s mining industry**
- On average, 40% of resources businesses’ annual revenue is dependent on trade with China
Source: CCIWA (2020)
The resources sector is leading confidence in the economy, with four out of five (80%) businesses anticipating stronger economic conditions over the coming quarter.
Three out of five (61%) WA businesses believe conditions will improve over the next three months, up 30 percentage points since last quarter. At the same time, one out of ten (13%) anticipate weaker conditions – down 21 percentage points. The remaining 26 per cent anticipate no change.
**Short-Term Index up**
21 Index Points over the quarter to 145.3
**Longer-term outlook boosted by vaccine news and low interest rates**
The longer-term (12 months) outlook has also improved, rising to its highest level on record.
Two out of three (66%) businesses expect the WA economy to improve over the year ahead, up 33 percentage points since last quarter. One out of five (20%) anticipate no change over the next twelve months, while 14 per cent believe conditions will deteriorate – down 7 percentage points since this time last year (December 2019).
**Longer-Term Index up**
20.6 Index Points over the quarter to 127.6
**The industries driving short-term confidence**
A higher proportion of businesses in every industry expect conditions to improve rather than worsen over the next three months.
The resources sector is leading confidence in the economy, with four out of five (80%) businesses anticipating stronger economic conditions over the coming quarter. This strength in confidence likely reflects expectations that demand for Western Australian mineral commodities, like iron ore and gold, will remain strong leading into the New Year. Businesses in the LNG industry may also be more optimistic about the future, as global vaccine breakthroughs signal that an end to the lockdown era is in sight – lifting the demand profile for energy commodities.
Around two out of three businesses in the professional services (69%) and health care (65%) sectors are expecting stronger economic conditions over the next three months. Confidence in health care may reflect sustained evidence that WA has remained free of community based COVID-19 transmission and recent news of global vaccine breakthroughs. Heightened confidence in professional services may reflect the State Government’s decision to transition to a controlled border, allowing businesses to travel interstate to meet with clients and pitch for work.
Other sectors with a relatively higher proportion of businesses expecting conditions to improve include real estate (67%) and manufacturing (61%). As outlined in the following sections, the clear majority of businesses in these sectors are heavily reliant on the success of WA’s mining industry. Additionally, real estate businesses are continuing to see strong demand for their services as construction stimulus payments flow through the housing sector and Western Australians return home from overseas, boosting demand for properties.
At the same time, confidence appears relatively lower in other sectors. Two out of three (67%) businesses in retail are expecting conditions to either weaken or remain unchanged over the next three months, while the remaining 33 per cent anticipate conditions to improve.
**Barriers to business**
One out of three (35%) businesses identified skilled labour shortages as the largest barrier to growing their business over the coming year, including one out of two (52%) businesses in resources – up 20 percentage points since last quarter. Other industries with a relatively higher proportion of businesses reporting concerns around the availability of skilled labour include health care (50%), professional...
services (46%) and construction (46%). Looking to the regions, skilled labour shortages affected almost three out of five (55%) businesses in the Mid-West & Gascoyne and one out of two (50%) in the Kimberley.
One out of five (21%) businesses reported an uncontrolled outbreak of COVID-19 in WA as the largest barrier to growing their business, including almost half (46%) per cent of those in the accommodation & food services industry.
**The dependency of WA businesses on trade with China**
In recent months, the Chinese Government has imposed import restrictions on a range of Australian agricultural goods, including barley, wine and lobsters. In this survey, we asked businesses to identify the proportion (%) of their annual revenue that is dependent on trade with China.
- Businesses in the resources sector are most dependent on trade with China, with 40 per cent of their annual revenue dependent on China trade on average.
- Retail and manufacturing businesses are relatively more dependent on our largest trading partner, with just over one-fifth of their annual revenues’ dependent on China trade. Businesses in the retail sector may rely on the revenue generated by Chinese tourists or students travelling to WA.
- Other sectors that are relatively more dependent on trade with China include agriculture, accommodation & food services and, to a lesser extent, construction. For businesses in agriculture and food services, China remains a significant market for key agricultural commodities and packaged foodstuffs. Businesses in the construction sector may depend on Chinese families, investors or businesses choosing to either invest in WA’s property market or relocate here.
- On the other hand, health care and professional services businesses are relatively less dependent on China trade.
**WA’s Reliance on the Mining Sector**
WA has never been more reliant on the success of a single industry. Last month, the ABS’ annual State Accounts found that mining accounted for 43 per cent of WA’s economy in 2019-20 – a record high. In this section, we identify the industries that are most reliant on the success of WA’s mining industry.
- Two out of three (67%) businesses in the construction and retail industries reported
---
**Industries most reliant on WA’s mining industry***
Proportion reliant to a ‘high’ extent
*excluding resources
More than six out of ten (62%) businesses in the real estate industry identified they rely to a high extent on the success of WA’s mining industry.
For businesses in the retail sector, strength in mining tends to drive interstate and overseas migration as people move to WA to fill newly created, higher paying roles. The upshot of more people and higher average wages is an increase in spending within the domestic economy, particularly in sectors like retail and hospitality.
- More than six out of ten (62%) businesses in the real estate industry identified they rely to a high extent on the success of WA’s mining industry. This likely reflects two trends: increased demand for commercial premises as mining-related businesses scale-up operations or relocate their HQ to Perth; and increased demand for residential properties, as families relocate to WA to take up new employment opportunities in the mining industry.
**Border restrictions**
On 14 November, the State Government transitioned to a controlled border and eased mandatory quarantine restrictions for ‘very low risk’ States (which have had no community based COVID-19 transmission for 28 days). While this decision is a welcome step, there remains a risk that new outbreaks in other States could trigger a return to ‘hard’ border restrictions.
We asked WA businesses to identify the Australian jurisdictions that it is important to have relaxed border arrangements with in order to conduct business.
Looking to the results, WA businesses considered Victoria, New South Wales, Queensland, and South Australia as the most important States to have relaxed border arrangements with. A detailed breakdown of the results is illustrated in the infographic below.
### States that businesses consider important to have relaxed border arrangements with to conduct business
| Victoria | New South Wales | Queensland | South Australia | Tasmania |
|----------|-----------------|------------|-----------------|----------|
| Identified by 45% as important
Sectors most likely to consider Victoria as important:
• Accom & Food (73%)
• Retail Trade (62%)
• Agriculture (62%) | Identified by 44% as important
Sectors most likely to consider New South Wales as important:
• Accom & Food (67%)
• Construction (63%)
• Real Estate (52%) | Identified by 37% as important
Sectors most likely to consider Queensland as important:
• Construction (54%)
• Resources (52%)
• Manufacturing (47%) | Identified by 31% as important
Sectors most likely to consider South Australia as important:
• Resources (48%)
• Accom & Food (47%)
• Construction (38%) | Identified by 11% as important
Sectors most likely to consider Tasmania as important:
• Accom & Food (27%)
• Resources (19%)
• Construction (17%) |
### Key results from the survey
| Indicator (Index) | Actual | Expected |
|-------------------|--------|----------|
| **Economy** | | |
| WA Economic Conditions | 111.3 | 127.3 |
| | 127.3 | 144.8 |
| | 145.3 | 127.6 |
| **Operating Conditions** | | |
| Employment | 81.3 | 101.3 |
| | 121.1 | 121.9 |
| Labour Costs | 96.2 | 108.4 |
| | 122.4 | 123.6 |
| Anticipated CAPEX | - | - |
| | 121.3 | - |
| Profitability | 76.6 | 95.4 |
| | 103.2 | 108.1 |
Index figures may have changed from previous editions of Business Confidence due to changes in index calculation methodology. The index has been rebased to the average score of respondents over the 2016/17 financial year. The value of the index in any period can be interpreted as the percentage change in average business expectations in that period compared with average business expectations in 2016/17. For example, the index for current economic conditions in December 2020 is 144.8, which suggests that the average score of survey respondents for economic conditions in December 2020 is 44.8 per cent higher than the average response in 2016/17.
### Sample:
| Industry | Percentage |
|----------|------------|
| Manufacturing | 21% |
| Construction | 10% |
| Resources | 9% |
| Real Estate | 9% |
| Health Care and Social Assistance | 8% |
| Agriculture | 5% |
| Professional Services | 5% |
| Other | 33% |
| Business Size | Percentage |
|---------------|------------|
| Small (1-10) | 25% |
| Medium (11-100) | 56% |
| Large (100+) | 19% |
|
Influence of an Electric-field on the Topological Stability of the Neutral Lithium Dimer
Xinxin Feng\textsuperscript{1}, Alireza Azizi\textsuperscript{2}, Tianlv Xu\textsuperscript{1}, Wenjing Yu\textsuperscript{1}, Xiaopeng Mi\textsuperscript{1}, Hui Lu\textsuperscript{1}, Herbert Früchtl\textsuperscript{1}, Tanja van Mourik\textsuperscript{3}, Steven R. Kirk\textsuperscript{*1} and Samantha Jenkins\textsuperscript{*1}
\textsuperscript{1}Key Laboratory of Chemical Biology and Traditional Chinese Medicine Research and Key Laboratory of Resource National and Local Joint Engineering Laboratory for New Petro-chemical Materials and Fine Utilization of Resources, College of Chemistry and Chemical Engineering, Hunan Normal University, Changsha, Hunan 410081, China
\textsuperscript{2}State Key Laboratory of Powder Metallurgy, School of Materials Science & Engineering, Central South University, Changsha, Hunan 410083, China
\textsuperscript{3}EaStCHEM School of Chemistry, University of Saint Andrews, North Haugh, St Andrews, Fife KY16 9ST, Scotland, United Kingdom.
Email: firstname.lastname@example.org
Email: email@example.com
In this investigation we seek to understand the role of non-nuclear attractors (NNAs) of the neutral Li\textsubscript{2} dimer subjected to an electric ($\pm E$) field that is directed parallel ($\pm E_x$) and perpendicular ($\pm E_y$) to the bond-path. The $\pm E_x$-fields and $\pm E_y$-fields are separately applied to the Li\textsubscript{2} molecular graph until the bond ruptures. The next generation quantum theory of atoms in molecules (NG-QTAIM) interpretation of bonding was constructed with the stress tensor $\sigma(r)$ eigenvectors on the Hessian of $\rho(r)$ molecular graph. The asymmetry induced by both the $\pm E_y$-field and $\pm E_x$-field was detected in terms of the rotation of the orthogonal triad of stress tensor $\sigma(r)$ eigenvectors $\{\underline{e}_{1\sigma}, \underline{e}_{2\sigma}, \underline{e}_{3\sigma}\}$ relative to the Cartesian coordinate frame. The orthogonal triad of Hessian of $\rho(r)$ eigenvectors $\{\underline{e}_1, \underline{e}_2, \underline{e}_3\}$ however, were only able to detect rotation induced by the high degree of asymmetry present for bent bond-paths induced by the $\pm E_y$-fields. Larger movement of the NNAs along the bond-path correlated with greater bond critical point (BCP) bond metallicity $\xi(r_b)$. The effect of applying the $\pm E_x$-field was compared with unpublished results on neutral Li\textsubscript{2} subject to a stretching distortion. The lack of NNA motion along the bond-path for the stretching distortion correlated with a lower degree of bond metallicity $\xi(r_b)$. The stress tensor $\sigma(r)$ eigenvectors have a unique ability to detect rotation relative to the Cartesian coordinate frame for high bond-path symmetry occurring for the bond-stretching distortion and application of the $\pm E_x$-field. Suggestions for future work are provided.
1. Introduction
Previously we investigated the presence of non-nuclear attractors (NNAs) in small neutral lithium clusters Li$_m$ ($m = 2-5$) [1]. NNAs were found to be present for all relaxed geometries corresponding to the Hessian of the molecular electron density $\rho(\mathbf{r})$, commonly referred to as QTAIM (Quantum Theory of Atoms in Molecules) molecular graphs. None of the corresponding molecular graphs for the Ehrenfest Force $\mathbf{F}(\mathbf{r})$ partitioning contained NNAs. This finding is in agreement with a recent thorough investigation by Terrabuio and Teodoro et al. where NNAs were discovered in all cases for the Hessian of $\rho(\mathbf{r})$ molecular graphs and none were found on any of the Ehrenfest Force $\mathbf{F}(\mathbf{r})$ molecular graphs [2]. This work of Terrabuio and Teodoro et al. also provided evidence that a small difference in the polarizability between the Li atoms in the Li$_2$ cluster is an important feature that favors the occurrence of NNAs. The quantum stress tensor $\sigma(\mathbf{r})$, using Bader’s definition, was used in our earlier investigation [3], obtained within the QTAIM Hessian of $\rho(\mathbf{r})$ [4] partitioning. The quantum stress tensor $\sigma(\mathbf{r})$ directly relates to the Ehrenfest force $\mathbf{F}(\mathbf{r})$ by the virial theorem and so provides a useful physical explanation into the molecular structural rearrangements that occur during chemical reactions and low frequency normal vibrational modes [5]–[13]. The Ehrenfest Force $\mathbf{F}(\mathbf{r})$ partitioning scheme relates the net force exerted on $\rho(\mathbf{r})$ at a given point $\mathbf{r}$, by summing the forces of attraction by all the nuclei and forces of repulsion by the average electron density [5], [14], thereby providing a physical basis of understanding. As a consequence of the Ehrenfest $\mathbf{F}(\mathbf{r}) = -\nabla \cdot \sigma(\mathbf{r}) = 0$, formed from the dot product $(\cdot)$ of the gradient $(\nabla)$ operator and the stress tensor $(\sigma(\mathbf{r}))$ where the position of the stress tensor $\sigma(\mathbf{r})$ bond critical point (BCP) will coincide with the Ehrenfest Force $\mathbf{F}(\mathbf{r})$ BCPS.
In this investigation we will use next generation QTAIM (NG-QTAIM) [15]. The origins of NG-QTAIM arose from discovering that the $e_2$ and $e_1$ eigenvectors indicate the most and least preferred directions of $\rho(\mathbf{r}_b)$ motion, accumulation and subsequent direction of the BCP bond displacement[16] when a molecular structure is subjected to an external force or field. In this previous investigation of neutral lithium, the three-stranded interpretation of the bond by NG-QTAIM was used, where the stress tensor $\sigma(\mathbf{r})$ version $\mathbb{B}_\sigma$ is constructed using the least preferred ($e_{2\alpha}$) and most preferred ($e_{1\alpha}$) directions of charge density $\rho(\mathbf{r})$ accumulation, along with the bond-path $(r)$, obtained from the stress tensor eigenvectors. The $\mathbb{B}_\sigma$ was then transplanted on both the Hessian of $\rho(\mathbf{r})$ and Ehrenfest Force $\mathbf{F}(\mathbf{r})$ molecular graphs and compared. We found that the $\mathbb{B}_\sigma$ using the stress tensor $\sigma(\mathbf{r})$ eigenvectors on the Hessian of $\rho(\mathbf{r})$ molecular graph was comparable to the $\mathbb{B}_{\sigma F}$ that used the stress tensor $\sigma(\mathbf{r})$ eigenvectors on the Ehrenfest Force $\mathbf{F}(\mathbf{r})$ molecular graph.
We therefore provide a method to examine NNAs whilst providing insight from the Ehrenfest Force $\mathbf{F}(\mathbf{r})$ without the difficulty of calculating the Ehrenfest Force $\mathbf{F}(\mathbf{r})$, which requires very large basis sets.
Simple insight into the effect of the NNA on the topological stability of the neutral Li$_2$ dimer was gained by performing a stretching distortion that led to a large increase in the degree of asymmetry of the $\mathbb{B}_\sigma$ and $\mathbb{B}_{\sigma F}$, which was apparent as persistent bond-path torsions. Sufficient stretching of the Li$_2$ bond-path annihilated the
$NNA$ and appeared to increase the degree of bond-path twisting, which led us to hypothesize that prior to rupture the $NNA$ provided a topologically stabilizing effect by inhibiting the bond-path twisting.
In the current investigation on neutral Li$_2$ we will use the stress tensor $\sigma(\mathbf{r})$, which is sensitive to changes in topology, and will use NG-QTAIM to determine the effects of an applied electric ($\pm E$) field, see Scheme 1.
Scheme 1. The numbering scheme of the relaxed structure of the neutral lithium (Li$_2$) molecular graph is shown, where the purple spheres (Li1 and Li2) represent the lithium nuclear critical points (NCPs), the pale-blue sphere (NN43) and green spheres (BCP1 and BCP2), non-nuclear attractor (NNA) and the bond critical points (BCPs), respectively. The Cartesian axes correspond to the electric (=E$_x$, ±E$_y$ and ±E$_z$) field directions.
In particular, we seek to explain and quantify the origins of torsions of the $\{p\sigma, p'\sigma\}$ path-packets, associated with the Li$_2$ bond, that occurred when the Li$_2$ bond was stretched; these were previously only observed [1]. This will be undertaken by quantifying the metallic character and topological stability of the bond critical points (BCPs) and non-nuclear attractors (NNAs). Understanding of the topological stability involves tracking the creation and/or annihilation of the BCPs and NNAs. The values of the E-field used will be large enough to rupture the neutral Li$_2$ bond, i.e. to separate the two Li nuclei. The E-field will be applied to the symmetry inequivalent directions: parallel ($±E_x$) and perpendicular ($±E_y$) to the bond-path. We will compare the effect of the $±E_x$ field with previously unpublished results from the Li$_2$ subject to the bond-stretching distortion, up to 12 a.u., where due to the axial symmetry the ellipticity $\varepsilon$ remained zero along the entire bond-path. Therefore, in this investigation we will use the ellipticity $\varepsilon_{\text{GH}}$ of the stress tensor $\sigma(r)$ to scale the $B_\sigma$ within the Hessian of $\rho(r)$ partitioning, which is able to detect changes in symmetry [17], [18]. This is due to the mismatch in positions of $-\nabla \cdot \sigma(r) = 0$ for the stress tensor $\sigma(r)$ calculated on the Hessian of $\rho(r)$ partitioning.
2. Theoretical Background and Computational Details
Scalar QTAIM, critical points, metallicity $\xi(r_b)$ and the total local energy density $H(r_b)$
The four types of QTAIM critical points are labeled using the notation $(R, \omega)$, where $R$ is the rank of the Hessian matrix, i.e., the number of distinct non-zero eigenvalues, and $\omega$ is the signature (the algebraic sum of the signs of the eigenvalues); the (3, -3) [nuclear critical point (NCP), a local maximum], (3, -1) and (3, 1) [saddle points, referred to as bond critical points (BCPs) and ring critical points (RCPs), respectively] and (3, 3) [the cage critical points (CCPs)]. Another category of (3, -3) local maximum are non-nuclear attractors (NNA), which will be considered in this investigation. Additional background on QTAIM and the stress tensor $\sigma(r)$ are provided in the Supplementary Materials S1.
The earlier observation for a tendency of $\rho(r)$ to remain at a closed-shell BCP rather than moving towards the atomic basins, which resulted in lower positive values of the Laplacian $\nabla^2\rho(r_b)$, where $r_b$ indicates the position of the BCP, led directly to the concept of metallicity $\xi(r_b)$. The Laplacian $\nabla^2\rho(r_b)$ for a closed-shell BCP and
a shared-shell $BCP$ is always positive and negative, respectively. This relative tendency for the charge to remain at or move away from a closed-shell $BCP$ is defined as the metallicity $\xi(r_b)$:
$$\xi(r_b) = \rho(r_b)/\nabla^2\rho(r_b) \geq 1 \text{ for } \nabla^2\rho(r_b) > 0$$
(1)
Values of the metallicity $\xi(r_b) \leq 1$ from equation (1) for closed-shell $BCPs$ correspond to non-metallic or insulating $BCPs$. We earlier examined the metallicity $\xi(r_b)$ for very high pressure ice X [19] and intramolecular proton transfer [20]. Values of the metallicity $\xi(r_b)$ for a wide range of elements and compounds [21] were examined and it was discovered that $\xi(r_b)$ relates inversely to “nearsightedness” of the first-order density matrix and is suitable for closed-shell systems [22]. Note the concept of metallicity $\xi(r_b)$ relates to the relative delocalization of the total electronic charge density $\rho(r_b)$ [22]. The metallicity $\xi(r_b)$ will be calculated on a $BCP$ by $BCP$ basis to enable the understanding of local changes to $\xi(r_b)$ along the Li1-L2 bond-path i.e. the metallicity $\xi(r_b)$ will not be summed.
A property associated with $BCPs$ possessing metallicity $\xi(r_b)$ is that for high values of the metallicity $\xi(r_b) > 1$, the total local energy density $H(r_b) < 0$ for closed-shell $BCP$ interactions. The total local energy density $H(r_b)$ is defined as:
$$H(r_b) = G(r_b) + V(r_b)$$
(2)
Where $G(r_b)$ and $V(r_b)$ correspond to the local kinetic energy density and the potential energy density, respectively. A previous QTAIM investigation into unusually strong hydrogen bonding found that hydrogen-bond $BCPs$ with values $H(r_b) < 0$, possess a degree of covalent character [23], [24].
**The NG-QTAIM vector-based interpretation of the chemical bond**
The bond-path framework set $B_\sigma$ is the NG-QTAIM interpretation of the chemical bond using the stress tensor $\sigma(r)$ on the Hessian of $\rho(r)$ bond-path $r$ (black-line) molecular graph, see equation (3) and Figure 1. Note, the orthogonal triad of stress tensor eigenvectors $\{\underline{e}_{1\sigma}, \underline{e}_{2\sigma}, \underline{e}_{3\sigma}\}$ and Hessian of $\rho(r)$ eigenvectors $\{\underline{e}_1, \underline{e}_2, \underline{e}_{3\sigma}\}$ are referred to as bond-path frameworks.
Bader’s definition [3], [25] of the stress tensor $\sigma(r)$ is used in this work as it has been successfully used before to provide physical insight into low frequency vibrational modes associated with internal molecular rearrangement [26]–[28] and is directly related to the Ehrenfest force by the virial theorem. The usual criterion for topologically stable $BCPs$ is two negative eigenvalues and one positive eigenvalue directed perpendicular and parallel to the bond-path respectively. For topologically unstable $BCPs$ however, there may be three
negative eigenvalues when the stress tensor $\sigma(r)$ is used [18]. The stress tensor $\sigma(r)$ ellipticity $\varepsilon_{\text{ell}}$ is used as a scaling factor in the construction of the $\{p_\sigma, p'_\sigma\}$ path-packets in equation (3), due to how $r$ is constructed from $(e_2)$ using the Hessian of $\rho(r)$:
$$p_\sigma = r_i + \varepsilon_{\text{ell}} e_{2\sigma,i}, \quad p'_\sigma = r_i - \varepsilon_{\text{ell}} e_{2\sigma,i}$$
(3)
‘Path-packet’ refers to the orbital-like packet shapes that the pair of $p_\sigma, p'_\sigma$ paths form along the bond-path ($r$) that will be on a Hessian of $\rho(r)$ molecular graph, but has earlier been superimposed onto an Ehrenfest Force $F(r)$ molecular graph [1]. The $\{p_\sigma, p'_\sigma\}$ path-packets will be used to quantify the resistance to the applied electric-field ($\pm E_x$) and ($\pm E_y$) due to the $\{p_\sigma, p'_\sigma\}$ being constructed from $e_{2\sigma}$, the least preferred direction of electronic charge density motion $\rho(r)$ for the stress tensor $\sigma(r)$.
**Computational Details**
The molecular structure was optimized with ‘verytight’ convergence criteria within Gaussian 09 v.E.01 [29] using the CAM-B3LYP [30]/ANO-RCC [31], [32] DFT functional and basis set. We chose this theory level to enable comparison with results, in particular unpublished metallicity $\xi(r_b)$ values, from our previous investigation on the neutral Li$_2$ cluster [1]. Gaussian’s ‘superfine’ DFT integration grid was used for all calculations, with an accuracy setting of $10^{-14}$ for the two-electron integrals. Geometry-optimization and single-point SCF calculations were performed with the aforementioned DFT settings, with the convergence criteria of $< 10^{-12}$ RMS change in the density matrix and $< 10^{-10}$ maximum change in the density matrix, with a range of external electric field values applied. These calculations yielded the wavefunctions needed for QTAIM and NG-QTAIM analysis. Calculations of the molecular graphs and critical point properties were performed using AIMAll [33], and NG-QTAIM calculations and visualization were performed using our QuantVec [34] code; the ‘topviz’ visualization component of QuantVec being based on the Mayavi [35] toolkit.
**3. Results and Discussions**
**3.1 The Torsion of the Bond-Path Framework Set $B_\sigma$, Metallicity $\xi(r_b)$ and BCP-NNA Separations**
Inspection of the Hessian of $\rho(r)$ bond-path framework sets $B$ reveal $\{p,p'\}$ and $\{q,q'\}$ path-packets that are featureless as a consequence of the application of the electric fields $\pm E_x$ and ($\pm E_y = \pm E_z$). These featureless Hessian of $\rho(r)$ path-packets do not enable the investigation of the origins of the bond-path torsion previously
observed [1] for the $\pm E_x$-field due to the complete absence of ellipticity $\varepsilon$, see **Scheme 1** and the **Supplementary Materials S2**. The stress tensor $B_\sigma$ will therefore be used to track the effect of the applied $\pm E_x$ and $\pm E_y$ scaled with the Hessian of $\rho(r)$ version of the stress tensor $\sigma(r)$ ellipticity $\varepsilon_{\sigma H} = |\lambda_{1\sigma}|/|\lambda_{2\sigma}| - 1$, which is not featureless along the bond-path, see the **Supplementary Materials S3**.
The stress tensor $\{p_\sigma, p'_\sigma\}$ path-packet forms a single envelope around all three critical points, $BCP1$, $NN43$ and $BCP2$, for the $E$-field = 0, see **Figure 1**. The stress tensor $e_{2\sigma}$ eigenvector was used for displaying the $\{p_\sigma, p'_\sigma\}$ path-packets because once the $\pm E$-field was applied, it remained aligned exactly with one of the Cartesian $y$ or $z$ directions for both the $\pm E_x$ and $\pm E_y$. Conversely, the stress tensor $e_{1\sigma}$ eigenvector was misaligned with any of the Cartesian axes for $\pm E_y$ due to fractional rotation of the bond-path framework $\{e_{1\sigma}, e_{2\sigma}, e_{3\sigma}\}$, see the **Supplementary Materials S4**.
Examination of the Cartesian $x$, $y$, $z$ axes of the stress tensor $\sigma(r)$ eigenvectors $\{e_{1\sigma}, e_{2\sigma}, e_{3\sigma}\}$ for the $E$-field = 0 demonstrates that the $e_{1\sigma}$ is aligned with the Cartesian $x$-axis, i.e. the bond-path, instead of the usual case of $e_{3\sigma}$ being aligned with bond-path. At $E$-field = 0 the orthogonal set of stress tensor eigenvector bond-path framework $\{e_{1\sigma}, e_{2\sigma}, e_{3\sigma}\}$ was rotated by $\pi/2$ radians relative to the Cartesian coordinate frame, compared with that of the Hessian of $\rho(r)$, which was aligned with the Cartesian coordinate frame. The stress tensor eigenvectors $\sigma(r)$ were oriented $\{e_{1\sigma} \rightarrow x, e_{2\sigma} \rightarrow y, e_{3\sigma} \rightarrow z\}$ compared with the Hessian of $\rho(r)\{e_1 \rightarrow y, e_2 \rightarrow z, e_3 \rightarrow x\}$ where $x$, $y$, $z$ correspond to the Cartesian axes where $x$ is aligned with the bond-path, see **Figure 1**. The eigenvectors $\{e_1, e_2, e_3\}$ of the Hessian of $\rho(r)$ for $E$-field = 0 however, possess a positive $\lambda_3$ eigenvalue associated with the bond-path, where the Hessian of $\rho(r)$ eigenvector $e_3$ is aligned with bond-path as in most molecular graphs, see the **Supplementary Materials S5**.
**Figure 1.** The neutral Li$_2$ lithium molecular graph displaying the stress tensor $\{p_\sigma$(blue), $p'_\sigma$(cyan)\} path-packets on the Li1-Li2 bond-path ($r$), for values of the electric field, $E$-field = 0, see **Scheme 1** for the $\pm E_x$, $\pm E_y$ and $\pm E_z$ directions.
The effect on the $\{p_\sigma, p'_\sigma\}$ path-packets of the $\pm E_x$ and $\pm E_y$ electric fields, with magnitudes up to $\pm 100.0 \times 10^{-4}$ a.u., are presented in **Figure 2** and **Figure 3**, respectively. The corresponding $\{p_\sigma, p'_\sigma\}$ path-packets for the largest $\pm E_x$ and $\pm E_y$ electric fields before bond-path rupture are presented in **Figure 4** and **Figure 5** respectively.
Additional views in the $x-z$ plane of the $\{p_\sigma, p'_\sigma\}$ path-packets subjected to the $\pm E_x$ and $\pm E_y$ electric fields are provided in the **Supplementary Materials S6**.
The stress tensor $\{p_{\sigma}, p'_{\sigma}\}$ path-packets subject to the $\pm E_x$-field for $E = 0$ and some low field values, surround both $BCPs$ in a single envelope, which separated into two envelopes as the magnitude of the $\pm E_x$-field increased. These envelopes surrounding the $BCPs$ persisted in the vicinity of the $NNA$ after the $BCP$ had ruptured. A single envelope persisted with application of the $\pm E_y$-field, until the bond had ruptured.
For all values of $\pm E_x$-field the $\underline{e}_3$ eigenvector of the Hessian of $\rho(\mathbf{r})$ remained aligned with the bond-path, whereas the Cartesian directions of the $\underline{e}_1$ and $\underline{e}_2$ swap, due to the consistently zero ellipticity $\varepsilon$ values rendering $\underline{e}_1$ and $\underline{e}_2$ equivalent. The eigenvectors of the Hessian of $\rho(\mathbf{r})$ were initially in a topologically stable configuration, but were destabilized by the application of the $\pm E_y$-field and reoriented to a stable configuration for the highest $E$-field values before bond rupture. There is continuous rotation of the Hessian of $\rho(\mathbf{r})$ bond-path framework with increase in $\pm E_y$-field. This results in the $\underline{e}_3$ eigenvectors of $BCP1$ and $BCP2$ at $\pm E_y = \pm 160.0 \times 10^{-4}$ a.u. of the Hessian of $\rho(\mathbf{r})$ bond-path framework, which was initially orientated along the $z$-axis, rotating to realign with the $x$-axis. This rotation of the Hessian of $\rho(\mathbf{r})$ bond-path framework from initial alignment of the $\underline{e}_3$ eigenvector with the $x$-axis to alignment with the $z$-axis coincides with the maximum value of the metallicity $\xi(r_b)$ for the $\pm E_y$-field, Figure 7(b) and the Supplementary Materials S7. All instances of metallic character, i.e. $\xi(r_b) \geq 1$, also possess small negative values of the total local energy density $H(r_b)$. Finally, just before bond rupture, the Hessian of $\rho(\mathbf{r})$ bond-path framework rotates back to the initial configuration along the $x$-axis.
Significant differences in the effect on the path-packet morphology and orientation are clearly seen in the stress tensor $\{p_{\sigma}, p'_{\sigma}\}$ for the $+E_x$ and $-E_x$ directions of the $E$-field for both the lower and higher values of $\pm E_x$, see Figure 2 and Figure 4, respectively. There are also differences in the $\{p_{\sigma}, p'_{\sigma}\}$ path-packet morphology and orientation as a function of the magnitude of the $\pm E_x$-field. The origins of these differences in the $\{p_{\sigma}, p'_{\sigma}\}$ path-packet morphologies are explained by the changing orientation of the stress tensor $\sigma(\mathbf{r})$ bond-path framework constructed from the orthogonal set $\{\underline{e}_{1\sigma}, \underline{e}_{2\sigma}, \underline{e}_{3\sigma}\}$. Significant differences in the $\{p_{\sigma}, p'_{\sigma}\}$ are not apparent for the corresponding $+E_y$ and $-E_y$ directions of the $E$-field; however the bond-paths for higher $+E_y$ and $-E_y$ values bend significantly along the $+y$ and $-y$ Cartesian directions, respectively, see Figure 3 and Figure 5.
An $NNA$-$NNA$ $BCP$ exists for values of the $\pm E_y$-field $= \pm 255.0 \times 10^{-4}$ a.u. to $\pm 269.0 \times 10^{-4}$ a.u., which is a unique topological feature that has an associated non-rotated bond-path framework $\{\underline{e}_{1\sigma}, \underline{e}_{2\sigma}, \underline{e}_{3\sigma}\}$, i.e. $\underline{e}_{3\sigma}$ is aligned with the bond-path and the $x$-axis, see Figure 5(c). $NNAs$ were absent and only a single $BCP$ remained for the Li$_2$ molecular graphs just before the rupture of the bond-path for both the $\pm E_x$ and $\pm E_y$ fields.
Figure 2. The $\{p_\alpha p'_\alpha\}$ stress tensor path-packets for values of the electric field, for (+$E_x$) are presented in the left and right (-$E_x$) panels respectively. Values of the $E_x$-field (in a.u.) = ±20.0x10^{-4}, ±40.0x10^{-4}, ±60.0x10^{-4}, ±80.0x10^{-4}, ±100.0x10^{-4} correspond to sub-figures (a-e), respectively. See Figure 1 for the $E = 0$ $\{p_\alpha p'_\alpha\}$ path-packets and Scheme 1 for the E-field directions.
Figure 3. The stress tensor $\{p_\sigma, p'_\sigma\}$ path-packets for values of (+$E_y$) are presented in the left and right (-$E_y$) panels respectively, for values of the $\pm E_y$-field (in a.u.) = ±20.0x10^{-4}, ±40.0x10^{-4}, ±60.0x10^{-4}, ±80.0x10^{-4}, ±100.0x10^{-4} correspond to sub-figures (a-e), respectively. See Figure 2 for further details.
(a)
(b)
(c)
(d)
(e)
Figure 4. The stress tensor $\{p_{\sigma}, p'_{\sigma}\}$ path-packets for values of (+$E_x$) are presented in the left and right (-$E_x$) panels respectively. The values of the electric field, ±$E_x$-field (in a.u.) = ±110.0x10^{-4}, ±120.0x10^{-4}, ±130.0x10^{-4}, ±140.0x10^{-4}, ±141.0x10^{-4}, ±142.0x10^{-4}, ±143.0x10^{-4}, ±144.0x10^{-4}$ correspond to sub-figures (a-h), respectively. See Figure 2 for further details.
Figure 5. The stress tensor $\{p_{\alpha}, p'_{\alpha}\}$ path-packets for (+$E_y$) are presented in the left and right (-$E_y$) panel respectively. Values for ±$E_y$-field (in a.u.) = ±255.0x10^{-4}, ±256.0x10^{-4}, ±257.0x10^{-4}, ±269.0x10^{-4}, ±270.0x10^{-4}$ and ±294.0x10^{-4} correspond to sub-figures (a-f), respectively, see Figure 2 for further details.
The $NNA$ is generally more mobile, i.e. possesses larger Li-$CP$ separations, than the $BCPs$ along the bond-path for both the $\pm E_x$-field and $\pm E_y$-fields, see Figure 6. Comparing the effect of the $\pm E_x$-field and $\pm E_y$-field, the mobility of the $NNA$ is significantly higher, although the $BCPs$ possess generally similar mobility for both E-field directions. These differences in the mobility of the $NNA$ for the $\pm E_x$-field and $\pm E_y$-field direction may account for the corresponding differences in the $BCP$ metallicity $\xi(r_b)$, see Figure 7. The metallicity $\xi(r_b)$ attains much higher values for the $\pm E_x$-field compared with the $\pm E_y$-field direction, where $BCP1$ and $BCP2$ possess mirror image values of $\xi(r_b)$ for the $\pm E_x$-field direction.
Figure 6. Plots of the variation of the Li-$CP$ separation with $\pm E_x$ are presented in sub-figures (a) and (b). Critical points ($CP$s) correspond to the bond critical points ($BCPs$) and non-nuclear attractors ($NNAs$). The $NNA3$ and $NNA4$ are shown surrounding the central $BCP$ on the Li$_2$ molecular graph in Figure 5(c), also see Scheme 1. The corresponding plots for the variations of $\pm E_y$ are presented in sub-figures (c) and (d).
Figure 7. The variation of $BCP$ metallicity $\xi(r_b)$ with the $\pm E_x$-field and $\pm E_y$-field of the Li$_2$ molecular graph are presented in sub-figures (a-b), respectively. a.u. units are used throughout. Notice the log$_{10}$ scale for sub-figure (a), see Scheme 1 for further details.
Comparison can be made with previously overlooked and unpublished results from our earlier investigation into stretching distortions of neutral Li$_2$, in the absence of an $E$-field, with the effects of the $\pm E_x$-field. The Hessian of $\rho(r)$ results, including $\rho(r_b)$, Laplacian $\nabla^2 \rho(r_b)$ and $BCP$ metallicity $\xi(r_b)$ corresponding to the neutral Li$_2$ stretching distortions, were not previously published; only the geometric bond-length (GBL) was previously published [1].
For a $\pm E_x$-field value of $\pm 144.0 \times 10^{-4}$ a.u. the $NNA$ is annihilated and the BPL is 6.406 a.u. The Li$_2$ bond-path ruptures for a value of the $\pm E_x$-field = $\pm 145.0 \times 10^{-4}$ a.u. The critical points are not positioned symmetrically for all values of the applied $\pm E_x$-field, see Figure 6(a-b) where it can be seen that the $NNAs$ are significantly more mobile on the bond-path than the $BCPs$, see the Supplementary Materials S8. Significant values of the metallicity $\xi(r_b)$ occur for a wide range of $\pm E_x$-field values.
In comparison, the neutral Li$_2$ subjected to the stretching distortion exists until the bond-path length (BPL = GBL) is 12.1 a.u., although values of the Laplacian $\nabla^2 \rho(r_b)$ are insignificant beyond 10.1 a.u. and the $NNA$ is annihilated when the BPL is 7.1 a.u. Additional new results for the stretched neutral Li$_2$ include the eigenvectors $\{\underline{e}_1, \underline{e}_2, \underline{e}_3\}$ of the Hessian of $\rho(r)$ and the stress tensor $\sigma(r)$ eigenvectors $\{\underline{e}_{1\sigma}, \underline{e}_{2\sigma}, \underline{e}_{3\sigma}\}$, see the Supplementary Materials S9. For all values of the stretching distortion the critical points are positioned symmetrically about the geometric centre of the Li1-Li2 bond-path and the $NNA$ remains fixed at the centre of the bond-path for all stretching distortions. A significant value of the metallicity $\xi(r_b)$, i.e. $\xi(r_b) = 40.1$ a.u., only occurs for a Li1-Li2 separation of 6.1 a.u., which may be explained by the lack of mobility of the $NNA$ for the stretching distortions. The stress tensor eigenvalue $\lambda_{3\sigma}$ for the stretching distortion was negative up to
an extension of 6.1 a.u., where there were two $BCPs$. All longer extensions were associated with a single $BCP$ and a positive value of stress tensor eigenvalue $\lambda_{3\sigma}$.
4. Conclusions
In this investigation we set out to better understand the underlying causes, firstly of torsion of the $\{p_\alpha, p'_\alpha\}$ path-packets, and secondly changes to the critical point topology of the molecular graph of neutral Li$_2$ as a consequence of applying an electric ($\pm E$)-field, both parallel ($\pm E_x$) and perpendicular ($\pm E_y$) to the bond-path. We have used NG-QTAIM with the stress tensor $\sigma(r)$ to understand the directional properties associated with the eigenvectors of scalar QTAIM and the Hessian of $\rho(r)$. In addition, the stress tensor ellipticity $\varepsilon_{\text{EH}}$ was non-zero for the application of the $\pm E$-field, in contrast with the Hessian of $\rho(r)$, which had two associated negative $BCPs$.
The scalar QTAIM properties were used to obtain the neutral Li$_2$ molecular graph, $BCPs$, $NNAs$ etc. and metallicity $\xi(r_b)$ using the Hessian of $\rho(r)$ partitioning, since the stress tensor $\sigma(r)$ lacks an associated scalar-or vector-field partitioning scheme. The rotation of stress tensor bond-path framework $\{\underline{e}_{1\sigma}, \underline{e}_{2\sigma}, \underline{e}_{3\sigma}\}$ due to the application of both the $\pm E_x$ and $\pm E_y$-field occurred despite the absence of structural asymmetry induced by the $\pm E_x$-field. This finding indicates that the stress tensor $\sigma(r)$ eigenvectors can be used to detect the presence of the bond-path framework $\{\underline{e}_{1\sigma}, \underline{e}_{2\sigma}, \underline{e}_{3\sigma}\}$ rotation, i.e. topological instability, regardless of the induced bond-path asymmetry caused by bond-path bending. This topological instability can be explained by the presence of three negative $BCP$ stress tensor eigenvalues, which is characteristic of topologically unstable $BCPs$ [18].
The Hessian of $\rho(r)$ bond-path framework $\{\underline{e}_1, \underline{e}_2, \underline{e}_3\}$ did not rotate in response to the application of the $\pm E_x$-field, due to the lack of bond bending, i.e. asymmetry induced by the $\pm E_y$-field.
For the highest $\pm E_x$-field values before bond rupture, the $\{p_\alpha, p'_\alpha\}$ path-packets persisted in the vicinity of the $NNA$ after the $BCP$ had ruptured, which is an indicator of the topologically stabilizing effect of the $NNA$. For the $\pm E_y$-field a single $\{p_\alpha, p'_\alpha\}$ envelope with the largest extent surrounding the $NNAs$ persisted until the bond ruptured, which also indicated a topologically stabilizing effect of the $NNA$.
An $NNA$-$NNA$ $BCP$ was uniquely present as an adaptation to the higher values of the $\pm E_y$-field = $\pm 255.0 \times 10^{-4}$ a.u. to $\pm 269.0 \times 10^{-4}$ a.u., which resulted in significant neutral Li$_2$ $BCP$ bond-path bending. This can be explained by the $NNA$-$NNA$ $BCP$ possessing a positive stress tensor eigenvalue $\lambda_{3\sigma}$, which is associated with topologically stable $BCPs$. The $NNAs$ shifted along the bond-path more for the applied $\pm E_x$-field than the $\pm E_y$-field, which can explain the presence of higher values of the metallicity $\xi(r_b)$ for the $\pm E_x$-field compared with the $\pm E_y$-field.
The overall directional effect of the applied $\pm E_x$ and $\pm E_y$-fields is to reorient the stress tensor $\sigma(r)$ eigenvectors with increase in $\pm E$-field until just before the bond rupture, where the stress tensor $\underline{e}_{3\sigma}$ eigenvector is finally orientated along the bond-path with a single $BCP$ and no $NNAs$. The overall scalar effect induced by the
applied \( \pm E_x \) and \( \pm E_y \)-fields is to increase the values of the metallicity \( \xi(r_b) \) and motion of the NNAs along the bond-path.
Comparison of the stretching distortion of neutral Li\(_2\) in the absence of an applied \( \pm E_x \)-field was made. The stretching distortion resulted in the GBL being approximately twice (\( \approx 12 \) a.u.) that of the neutral Li\(_2\) subject to the \( \pm E_x \)-field (\( \approx 6 \) a.u.) before bond rupture. This difference could be explained by the greater motion of the NNAs and higher metallicity \( \xi(r_b) \) present for the Li\(_2\) subjected to the \( \pm E_x \)-field, which causes the bond to rupture at shorter lengths compared with the Li\(_2\) stretching distortion. Our work here is consistent with the work of Terrabuio and Teodoro et al. since the polarization effect induced by the applied \( \pm E_x \)-field, induced a greater stabilization, up to and including values of \( \pm E_x \)-field = \( \pm 143.0 \times 10^{-4} \) a.u., of the NNAs. This stabilization effect took the form of the reorientation of the stress tensor \( \sigma(r) \) bond-path framework \( \{ \underline{\sigma}_1, \underline{\sigma}_2, \underline{\sigma}_3 \} \) and Hessian of \( \rho(r) \) bond-path framework \( \{ \underline{\sigma}_1, \underline{\sigma}_2, \underline{\sigma}_3 \} \).
Future investigations with NG-QTAIM and lithium clusters could include charged species and manipulation of the positions and existence of the NNAs using linearly polarized non-ionizing ultra-fast laser irradiation. The laser irradiation would be on sufficiently fast timescales to avoid disrupting the lithium nuclei positions.
**Conflict of Interests Statement**
The authors have no conflict of interests to declare.
**Funding:** The Hunan Natural Science Foundation of China project gratefully acknowledged approval number: 2022JJ30029. The One Hundred Talents Foundation of Hunan Province is also gratefully acknowledged for the support of S.J. and S.R.K.
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[33] T. A. Keith, AIMAll (19.10.12), TK Gristmill Software, Overland Park KS, USA (http://aim.tkgristmill.com). TK Gristmill Software, Overland Park KS, USA, 2019.
[34] S. R. Kirk, S. Jenkins, QuantVec. BEACON Research Group, College of Chemistry and Chemical Engineering, Hunan Normal University, Changsha, Hunan, P.R. China, 2021.
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May is Older Americans Month
"Time Together with Time to Spare"
(M) Sunday, May 2, 2:00 p.m.
The unforgettable melodies of "West Side Story," along with favorites from the Great American Songbook, are featured in this lively cabaret show featuring singer Yvette Malvet-Blum, accompanied by Bob Boucher on piano and guitar and Brian Wishin on percussion. Yvette will sing her singing career at Manhattan's Triad Theater. She has appeared at many clubs throughout Manhattan and Queens, debuting her first solo show at the popular club Don't Tell Mama. She has performed at Danny's Skylight Room and Rose's Turn in Manhattan. On Long Island Yvette has performed at the Vanderbilt Mansion, at Brookhaven National Laboratory, and at private functions and clubs. Registration is required at either library building or online. (NENA174)
Medicare Update
(N) Wednesday, May 12, 2:00 p.m.
A representative from the Suffolk County Office for the Aging will provide information on Medicare (Parts A, B, C, and D) and highlight some of the changes that begin in 2010. Information about programs that can help save money on Medicare costs will also be presented. Resources, contacts, and reference material will be distributed. Registration begins May 1 at either library building or online. (NENA174)
Healthy Living for Seniors
(N) Thursday, May 20, 3:00 p.m.
Make the most of your prime years! Dr. Robert S. Newman, a Certified Clinical Nutritionist and Doctor of Chiropractic, will explore specific lifestyle practices to help you develop a healthy, high-vitality life. He will discuss diet, specific supplements, exercise, stress reduction, and the most current research in the study of gerontology. No registration required.
Silver Star Coupon Booklet
Attention seniors! Use your Library card and save money! If you are age 60 or older, the Northport-East Northport Library has something special for you! The Library has compiled this year’s Silver Star Coupon Booklet in recognition of you, our nation’s fastest growing population. The booklet provides discount coupons for the Library Café, photocopies, bus trips, overdue fines, and other Library services. Just come to the Circulation Desk at either library building with your Library card and proof of age—and pick up your Silver Star Coupon Booklet!
If you’ve answered yes to any of these questions, The Retirement Resources Directory can help you in your research process. Compiled by Suffolk Libraries’ Career and Resource Exchange (CARE), this comprehensive directory lists contact information on jobs and careers, continuing education, and senior services organizations, and more. A Retirement Resources Directory can be picked up at the Reference Desk or may be accessed online at http://scla.net/rasd/retirement.pdf.
Beethoven: The Man & The Music, Part 2
(N) Thursday, May 13, 7:30 p.m.
In this fascinating multi-media presentation, Beethoven expert and York College professor Dr. Stuart Ballin will continue his fascinating discussion of the life and music of Ludwig van Beethoven. Dr. Ballin will explore Beethoven’s complicated and obsessive relationship with his mother, his personal pilgrimage in Vienna during his life, and more. Dr. Ballin’s passion for Beethoven’s life and music will inspire and enlightened audiences throughout the New York area. No registration required.
New York, New York: The World in a City
(N) Thursday, May 6, 7:30 p.m.
New York’s five boroughs are “melting pots” of many nationalities—Russian, Chinese, Indonesian, Japanese, Lebanese, Greek, Moroccan, and Italian, among many others. Pat Sommerstad will introduce the amazing variety of ethnic neighborhoods for you to discover less than 60 miles away, with a particular emphasis on the best food destinations. Detailed itineraries for visiting these “communities” within the five boroughs will be provided, along with all the information you’ll need to experience the food and culture of each. Registration is now underway at either library building or online. (NENA175)
Friday Movies for Adults
Avatar
(EN) Friday, May 7, 10:00 a.m.
(EN) Friday, May 14, 1:30 p.m.
James Cameron’s science fiction epic received Oscars for visual effects and cinematography. Rated PG-13. 162 min.
Invictus
(EN) Friday, May 21, 10:00 a.m.
(EN) Friday, May 28, 1:30 p.m.
Matt Damon and Morgan Freeman star in this story about Nelson Mandela’s attempt to bring his people together through the universal language of sport. Rated PG-13. 133 min.
The 5 Ps of Successful Home Improvement
(N) Thursday, May 5, 7:30 p.m.
Whether you’re a do-it-yourselfer looking to complete some small projects or a homeowner gearing up for a major renovation, you need some basic information to get the job done. Join Gary Dymski, former Home Work columnist at Newsday. From paint, insulation, products to the most up-to-date technology, he will guide homeowners through the right steps. The result is that you’ll be sure to approach your next project with more confidence. No registration required.
Kayaking on Long Island
(N) Wednesday, June 2, 7:30 p.m.
With more than 1,600 miles of coastline including ocean, bays, and rivers, Long Island is an ideal place for kayaking. This tranquil, fun activity that provides excellent upper body and aerobic exercise. Nick DeNezzo, president of the Long Island Kayak Club, will talk about the many different types of kayaks and which one is right for you. He will cover basic strokes and rescues, how to choose equipment, and where to kayak. No registration required.
Northport Arts Coalition presents A Showcase Cameo Special
(N) Wednesday, May 12, 7:00 p.m.
The Northport Arts Coalition, in cooperation with the Library, presents a showcase of the talented musicians who will be performing in this year’s “Happenings on Main Street.” Join them for an evening of jazz, folk, bluegrass, and popular music. No registration required.
How to Write Business Letters That Succeed
(N) Tuesday, May 11, 7:00 p.m.
When your writing succeeds, you succeed. Whether you need a compelling cover letter for a job application or want to introduce yourself to a prospective employer, or for an appointment, obtain a loan, or travel abroad, or say thank you, you are often make-or-break opportunities. Learn how to write 2010-style business letters that work, while sharpening your overall writing and communication skills for both print and electronic media. Workshop leader Natalie Canavor is a journalist, business writer, and co-author of The Truth About the New Rules of Business Writing, just published by Pearson/FTP Press. No registration required.
Cutting: A Discussion About a Teenage Epidemic
(EN) Tuesday, May 18, 7:30 p.m.
An act of self-harming behavior, cutting is a way some teenagers try to cope with the pain of strong emotions, intense pressure, or upsetting relationship problems. It may be used as a way to end a love affair, reject a parent, or punish oneself. Karen Koenig is a Licensed Clinical Social Worker who has worked with suicidal and self-harming adolescents. She will explore the epidemic of cutting among teens and discuss treatment modalities that replace self-harming behavior with more effective coping skills. No registration is required.
Internet Basics
(EN) Thursday, May 6, 7:30 p.m.
Learn the fundamentals of Internet access at this monthly program. No registration required.
Computer Fourth Grade
(EN) Thursday, May 13, 7:00-9:00 p.m.
Registration begins May 1 at either library or online. This hands-on class provides an overview of Windows file management. (NENC012)
Current Events in Perspective
(N) Wednesday, May 19, 7:30 p.m.
Join Michael Libresco-D’Innocenzo, professor of history at Hofstra University, to explore significant national and international developments. All attending the program are welcome to share their views.
Digital Photography 102
(N) Tuesday, May 18, 6:30-8:30 p.m.
Registration begins May 3 at either library or online. This class is the sequel to the Digital 101 class. The class will cover color settings, white balance, exposure control, depth of field, and techniques to get the best photos out of your camera. (NENC020)
Book-A-Trip to The Michener Art Museum, in Doylestown, PA
Thursday, May 20, 2010
Departure: 7:00 a.m. from the William J. Brosnan building parking lot (across from Northport Library)
Return: 7:30 p.m.
Cost: $88 per person (check only, non-refundable, payable to Northport-East Northport Public Library)
Itinerary: Join us for a guided tour of the James A. Michener Art Museum in beautiful Bucks County. Named for the Pulitzer Prize-winning writer, the museum is housed in the former Bucks County prison. Featured and rotating collections are works from New Hope’s early 20th century Impressionist art colony. Following lunch at the Lambertville Station Restaurant on the banks of the Delaware River, we will have time to shop in Peddler’s Village.
Advanced Microsoft Word 2007
(EN) Thursday, May 20, 7:00-9:00 p.m.
Registration begins May 3 at either library or online. This workshop will cover slide animation and graphics, transitions, formatting, and more. (NENC022)
Introduction to Photoshop Elements
(EN) Tuesday, May 25, 7:00-9:00 p.m.
Registration begins May 3 at either library or online. This basic workshop will give you an overview of the workspace, tools, options bar, and palettes. (NENC051)
Intermediate Microsoft Excel 2007
(EN) Thursday, May 27, 7:00-9:00 p.m.
Registration begins May 13 at either library or online. Topics will include working with functions, ranges, columns and rows, and more. (NENC071)
Intermediate Microsoft Word 2007
(EN) Thursday, May 27, 7:00-9:00 p.m.
Registration begins May 3 at either library or online. This class will cover formatting, working with columns and tables, and more. (NENC069)
Intermediate PowerPoint
(EN) Thursday, May 27, 7:00-9:00 p.m.
Registration begins May 20 at either library or online. This workshop will cover slide animation and graphics, transitions, formatting, and more. (NENC022)
Intermediate Microsoft Word 2007
(EN) Monday, May 10, 7:00 p.m.
This month we take a look at Run by Ann Patchett. Please pick up your copy of the book at the Northport Library Circulation Desk.
Page Turners
(N) Thursday, May 13, 2:00 p.m.
*Limit of one coupon booklet per patron per year (NENA178)
Retirement Resources Directory
Are you retired or thinking about retirement? Want to explore your options? Interested in developing new skills? Concerned about your financial future? Considering relocation?
If you’ve answered yes to any of these questions, The Retirement Resources Directory can help you in your research process. Compiled by Suffolk Libraries’ Career and Resource Exchange (CARE), this comprehensive directory lists contact information on jobs and careers, continuing education, senior services organizations, and more. A Retirement Resources Directory can be picked up at the Reference Desk or may be accessed online at http://scla.net/rasd/retirement.pdf.
Grandparenting
Museum Cove FOR CHILDREN
Fairy Houses
(N) Saturday, May 8, 10:00 a.m.
Children in grades K-5 with adult; siblings welcome
We have all heard stories about fairies, but do you know where they live? Join an educator from the Seautuck Environmental Association and learn about some of the different types of fairies and what kinds of houses they live in. Then we will go outside to the Library Courtyard and each family will create a fairy masterpiece. (90 min.) Registration begins April 24 at either library building or online. (NENJ279)
Newbery Book Club
(N) Thursday, May 6, 7:00 p.m.
Children in grades 4 and up
Children and tweens meet throughout the year to discuss recently published children’s books. Their opinions are posted on the Newbery Book Club website. Attendance at the meeting is not a requirement for participation. Children interested in learning more about the Newbery Book Club can meet with Children’s Librarian Mrs. Gebel Thursday evenings at the Northport Library.
Class Visits and Library Tours
Ain’t Life Grand! A Treasury for Grandmothers by Mary Engelbreit
All My Bad Habits I Learned from Grandpa by Laurel Siler Brunvoll
All My Good Habits I Learned from Grandma by Laurel Siler Brunvoll
Bein’ a Grandparent Ain’t for Wimps: Loving, Spoiling, and Sending Your Grandkids Home by Karen O’Connor
Chicken Soup for the Soul: Grand and Great by Jack Canfield
Connect with Your Grandkids: Fun Ways to Bridge the Miles by Chen Fuller
Extreme Grandparenting: The Ride of Your Life! by Tim Kimmel
Eye of My Heart: 27 Writers Reveal the Hidden Pleasures and Perils of Being a Grandmother edited by Barbara Graham
52 ELF Activities to Make You the Best Grandparent: Easy, Low Cost, Fun Once-a-Week Activities and Ideas to Connect with Grandkids Near or Far by David Brisco
Good Granny/Bad Granny by Mary McHugh
Grandloving: Making Memories with Your Grandchildren by Sue Johnson
Grandma Rules: Notes on the World’s Best Job by Jill Milligan
The Grandmas’ Book: For the Grandma Who’s Best At Everything by Alison Maloney
Grandparenting by The Grandparents’ Association
Grandparenting a Child with Special Needs by Charlotte E. Thompson
Grandparents Handbook: Games, Activities, Tips, How-tos, and All-Around Fun by Elizabeth LaBan
Grandparents Rock: the Grandparenting Guide for the Rock-n-Roll Generation by Pat Burns
The Granny Diaries:An Insider’s Guide for New Grandmothers by Adair Lara
FOR CHILDREN
Can’t Get Enough of the Greek Myths?
(EN) Monday, May 10, 7:00 p.m.
Children in grades 4 and up
Join us for a fascinating evening with illustrator and graphic novelist George O’Connor who will talk about his new ongoing series *The Olympians*. While preparing these tales of the “original superhero stories,” Mr. O’Connor referred to many original sources of classic Greek myths. In addition to his graphic novel career, Mr. O’Connor has published several children’s picture books. Copies of two books in *The Olympians* series, *Zeus and Athena*, will be available for purchasing and signing. Registration begins May 1 at either library building or online. (NENJ321)
Tales at Ten
(N) Fridays, May 7, 14, 21, 28, June 4, 11, 18, 10:00 a.m.
Children birth-5 years not yet in kindergarten with adult; siblings welcome
Did you know that during the month of May many classes from local nursery schools visit the library for tours, research, and storytimes? Classes from local elementary schools also come to the Library to get Library cards, learn how to use library materials, and to tour the buildings.
Registration for the following series programs begins May 4 at either library building or online.
• Programs are offered according to age on a monthly basis.
• Please ensure your child meets the specific age criteria of the particular program for which you are registering. Programs are designed with these age specifications in mind.
• Your child may register for one series program per month. If the program you want is full, you may place your child’s name on one wait list only.
• Please use your child’s library card to register and be sure to provide all necessary information in the “note to instructor” field.
Book to Movie Matinee: *Hoot*
(N) Saturday, May 15, 2:00 p.m.
New to his small Florida community, Roy becomes involved in the town boys’ attempt to save a colony of burrowing owls from a proposed construction site. Based on the book by Carl Hiaasen. Rated PG. (90 min.) No registration required.
Northport High School Fashion Show:
Sparkle, Shimmer, Shine
(N) Monday, May 17, 7:00-8:00 p.m.
Meet the students from Northport High School’s fashion design and illustration class taught by Robin O’Neill-Gonzalez. Let them dazzle you with their creations inspired by the theme of “Sparkle, Shimmer, Shine.” No registration is required.
Rock-a-Bye Readers
Babies not yet walking with adult; no siblings
Learn Mother Goose rhymes and poems, share songs and fingerplays, and read board books together. (30 min.) (NENJ322)
(EN) Wednesdays, 9:30 a.m.
May 12, 19, 26, June 2
Storytime Backpacks
Can’t get to the Library for Storytime? Check out a Storytime Backpack. Themed packs for “A Walk in the Woods,” “A Trip to the Beach,” “Picnics and Playgrounds,” and “Witches!” contain books and music and all the tools needed for a storytime. The Storytime Backpacks are educational and fun. Ask a Children’s Librarian for details. (NENY165)
FOR TEENS
Chess Club
(N) Thursday, May 20, 7:00 p.m.
Children in grades 3-6
Research has shown that playing chess at a young age helps children develop visualization, concentration, planning, and problem-solving skills. Join us and have some fun, learn to better your game, and practice good sportsmanship! (45 min.) No registration required.
Boy Scout Computer Merit Badge
(N) Thursdays, May 13 & 27, 7:00-8:30 p.m.
Students in grades 6-12
Learn to use computer resources at the Library while you complete the requirements to earn your Boy Scout Computer Merit Badge. You must attend both sessions. Registration begins May 4 at either library building or online. (NENY165)
Teen Writer’s Club
(N) Friday, May 21, 4:00-5:00 p.m.
Do you love to write? Stop by and hang out with fellow writers to discuss your ideas and get feedback on your work. Registration begins May 4 at either library building or online. (NENY164)
Teen Volunteer Opportunities
Teen volunteer opportunities are open to students in grades 7-12. Please choose one volunteer opportunity.
Bingo Board Volunteers
(EN) Tuesday, May 4, 4:00-5:00 p.m. (NENY116)
(EN) Tuesday, May 11, 4:00-5:00 p.m. (NENY117)
Help assemble ocean bingo boards for summer children’s programs. Registration is now underway. Please choose one session.
Helping Hands
(EN) Tuesday, May 18, 4:00-5:00 p.m.
Create seasonal decorations to send to Atria Assisted Living Facility and the Dolan Center and receive volunteer credit. Registration begins May 4 at either library building or online. (NENY114)
Chess Club Volunteers
(N) Thursday, May 20, 4:45-5:00 p.m.
Help children learn to play chess. A basic knowledge of the game is needed. Registration begins May 4 at either library building or online. (NENY115)
Libraries Change Lives
Our patrons share comments about how the Library has changed their lives.
Where do I begin? For thirty-five years, I was a patron of the East Northport Library. My children were “raised” there; my son Jay, during his teenage years, was a page there. He not only learned the responsibility of a job but also profited from a self-directed education reading a wide variety of books and plays. As a candidate for a Master’s Degree, I relied on the help of the staff to guide me on a course of study that was new to me. My experiences at Northport Library actually began before I moved and became a patron. As a longtime English teacher in the Northport-East Northport School district, I brought my students to the library for research projects and for the presentations by authors during the spring and fall.
For the past eleven years, I have been a patron of the Northport Library. Much to my delight, I have been able to bring my grandchildren to the library and share the children’s section with them. My husband and I have enjoyed the *Northport Magazine*, *American programs and Americans Who Have Shaped America series as well. We’ve attended the jazz recitals and lectures with great satisfaction.
The most remarkable experience I have had and continue to have revolves around the fact that I am now visually impaired and have a variety of other general or neurological limitations. It is difficult for a retired English teacher to give up the written word. I am indebted to the staff, not only to the director, but also to the reference division and the accommodating personnel at the circulation desk. I am deeply indebted to all. Thank you.
— Myrna Rabinowitz
Inside this issue:
“Time Together with Time to Spare” 2
Medicare Update 2
Beethoven, Part 2 3
Bus Trip to The Michener Art Museum 3
Computer Programs 4
Grandparenting 6
Children’s Programs 7-8
Teen Programs 8
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The New Normal
As we continue to battle the COVID-19 pandemic, our MCG Urology team has worked to keep ourselves & our patients safe with extra precautions, telemedicine visits, & taking shifts on the COVID-19 screening phone lines. We are preparing for a virtual resident Match.
The New Residents
The 2019 Match was our first year matching 3 new residents into the intern class. We also recruited an additional resident at the PGY2 level. See inside for an introduction to these as well as a final salute to our graduating chief residents.
The New Faculty
We welcome two new faculty members in 2020. One we recruited from just down the highway and the other from the other side of the country! Find out more about these fantastic additions to our team inside this issue.
VIRTUAL RINKER-WITHERINGTON SYMPOSIUM
Friday September 11, 2020 - Saturday September 12, 2020
Due to the COVID-19 Pandemic, the Annual Rinker Symposium will be held on-line this year. See inside for details.
Our distinguished speaker is J. Stuart Wolf, Jr., MD, FACS, Associate Chair for Clinical Integration and Operations, Chief, Division of Surgical Specialties, Department of Surgery and Perioperative Care, Dell Medical School of the University of Texas at Austin.
2020 Rinker-Witherington Society Meeting
The 2020 Rinker Witherington Society Annual Meeting will be held beginning the afternoon of Friday, September 11, 2020 and on Saturday, September 12, 2020.
Due to the COVID-19 pandemic, the meeting will be held online rather than in person.
If you wish to attend our Virtual Rinker-Witherington Program please contact Kim Maddox (firstname.lastname@example.org) from your business email address or call 706-721-9977. We will email you the link prior to the meeting.
We will be recording the meeting as well and will post on our YouTube channel. Search YouTube.com for MCG Urology to see all of the video tours, advice, and education we have already posted for medical students applying in urology who are not able to participate in visiting rotations or in-person interviews due to pandemic restrictions.
The Rinker Lectureship
In 1988, an endowment was established in the Medical College of Georgia Foundation to fund an annual John Robert Rinker Lectureship. 1989 marked the beginning of this activity, which is open to all faculty, residents and students within the School of Medicine. Our guest speaker this year is Dr. J. Stuart Wolf, Jr., Associate Chair for Clinical Integration and Operations Chief, Division of Surgical Specialties at Dell Medical School of the University of Texas at Austin.
Dr. Wolf currently sits on the Board of Directors of the Texas Urological Society. He chaired the American Urological Association (AUA) Practice Guidelines Committee, and was the inaugural chair of the AUA Science & Quality Council. At the University of Michigan, Dr. Wolf received the Silver Cystoscope Award for Urology Residency Teaching Excellence 3 times (1999, 2002 and 2005). He was appointed the inaugural David A. Bloom Professor of Urology in 2006. The Department of Urology awarded him the Faculty Service Award in 2011 and the Outstanding Achievement Award in 2012. He was inducted into the League of Educational Excellence of the University of Michigan Medical School in 2015, and that year he also received the inaugural Program Director’s Award from the Endourological Society. In 2010, Dr. Wolf was elected to the American Association of Genitourinary Surgeons. In 2018, he started a 6-year term as a Trustee of the American Board of Urology. In 2019, Dr. Wolf received a Distinguished Service Award from the AUA.
Accreditation
The Medical College of Georgia at Augusta University is accredited by the Accreditation Council for Continuing Medical Education to provide continuing medical education for physicians.
Designation
The Medical College of Georgia at Augusta University designates this live activity for a maximum of 10 AMA PRA Category 1 Credits™. Physicians should claim only the credit commensurate with the extent of their participation in the activity. Zoom Link: Will be provided to the business or given email, this will be a virtual event.
New Residents
Michael Oberle, DO
Originally from Vermillion, South Dakota, Dr. Oberle attended Black Hills State University, graduating in 2013 with a BS in Environmental and Cellular Biology (Summa Cum Laude) and obtaining his Masters in May of 2015 in Integrative Genomics. He then moved on to pursue his medical education at Edward via College of Osteopathic Medicine – Auburn. After graduating in 2019, he completed a General Surgery internship at Vanderbilt University Medical Center before joining us as a PGY2 resident in 2020. He is a fantastic addition to our strong PGY2 team.
Catherine Wallace, MD
Dr. Wallace calls Decatur, Georgia her home although she has lived many places. She attended the Georgia Institute of Technology where she obtained a BS in May of 2016 in Biomedical Engineering. She then went on to pursue her medical education at the Medical College of Georgia at Augusta University, graduating M.D in May of 2020. We are delighted she is staying here for residency.
Merry Ma, MD, PhD
Dr. Ma is an Augusta native, who pursued her Undergraduate Education at the University of Georgia, studying Biology, Psychology, and Statistics. She graduated in 2012 with a BS. She returned to Augusta to begin her medical education at the Medical College of Georgia at Augusta University, where she graduated with her MD and PhD degree in May of 2020. The future is bright for this surgeon scientist!
Kyle Cline, MD
Dr. Cline is from Daytona Beach, Florida. He graduated with a BS from Harding University in Scarcy, Arizona followed by a Masters degree in Biomolecular Science from Lipscomb University in Nashville, Tennessee. He attended medical school at the University of Arkansas as well as completing a research fellowship at the University of Tennessee. He has already impressed us early in his residency.
Fond Farewell
Daniel Belew, MD
Dr. Belew has joined a large private practice group, Georgia Urology, in Atlanta, Georgia.
Dr. Greg Simpson, DO
Dr. Simpson has joined a private practice group, Augusta Urology Associates, here in Augusta. He will also be working our residents by offering them a 1 month elective.
Congratulations!
Welcome
Pablo J. Santamaria, MD
Dr. Santamaria attended the University of California School of Medicine, in San Diego, California. He went on to complete his Urology Residency at Emory University in Atlanta, Georgia and remained in Georgia to provide urology care in many of our neighboring communities. He joins our faculty to provide expertise in the treatment kidney stones as well as lead our outreach to Georgia communities lacking in urologic care.
Matthew N. Simmons, MD, PhD
Dr. Simmons received his PhD from the University of Florida. He then attended the Stanford University School of Medicine, in Stanford California where he actually worked as a medical student on the urology service with Dr. Terris when she was junior faculty there. He graduated in 2003 and completed his Urology Residency training at the Cleveland Clinic, in Cleveland Ohio. He has built on his training with experience in robotic reconstruction and general urology while practicing in Bend, Oregon. Our team is fortunate that he wants to return to academic urology with us!
Accomplishments
Martha K. Terris, MD
Dr. Terris, Witherington Distinguished Professor and Chair, Chief of MCG Urology at Augusta University, currently serves as a Trustee of the American Board of Urology. She was selected as a member of the American Association of Genitourinary Surgeons.
Zachary Klaassen, MD, MSc
Assistant Professor of Urology, Ronald W. Lewis, MD Endowed Chair for Urology Education, and Director of Clinical Urological Research was appointed the Residency Program Director in May 2020. As an alumnus of this program, he brings to the program many new insights and passion.
Lynn Almond, NP
Lynn Allmond has been appointed to the American Urological Association Advanced Practice Providers Speaker’s Bureau which provides AUA Sections and specialty groups with a list of vetted APPs who may be able to speak on specific topics at their meetings.
Bradley Morganstern, MD
Assistant Professor of Urology, Director of Pediatric Urology and oversees all urology medical student rotations has assumed the role of academic/career advising for medical students in the MCG Office of Academic Affairs.
The most famous image of 2020, the CDC’s depiction of the COVID-19 virus, was created by Alissa Eckert, who obtained her master’s in medical illustration from MCG.
Support our Residents!!
This year our applicant pool was one of the largest we have ever experienced. More and more medical students are hearing about the MCG Urology training program and demand is high to be a part of it. As our program grows, so does our need to support our residents. Please join your fellow trainees and make a donation to support our residents for things such as research projects, travel to conferences, surgical equipment, and study materials.
Please make checks payable to: MCG Foundation with a notation that funding is for the MCG Urology Residents Fund. Mail checks to: Kim Maddox Augusta University Division of Urology 1120 15th St., Room BA-8415 Augusta, GA 30912-4050. Alternatively, you may wish to support our other funding opportunities listed below.
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Funds Available for Contributions
Urology Residency Fund #8245: Supports educational, research, and clinical activities for residents in urology.
Roy Witherington MD Chair Fund #8192: Supports a chair in urology
Quentin T. Lawson MD Urology Research and Education Fund #8049: Provides funding to residents in the urology residency for the purpose of travel related expenses including transportation, accommodation, registration, and incidentals when presenting at national or regional meetings.
Rinker-Witherington Urologic Society Fund #8179: Supports the Rinker-Witherington Symposium and Lectureship.
Ronald W. Lewis MD Chair Fund #8248: Supports the urology residency program director and resident expenses for travel, research, and projects.
Rudolph Bell Urological Fellowship Fund #8153: Provides financial support to urology interns and residents committed to the practice of urology.
Psychological distress associated with active surveillance in patients younger than 70 with a small renal mass. Goldberg H, Aajaj R, Cáceres JOH, Berlin A, Chandrasekar T, Klaassen Z, Wallis CJD, Ahmad AE, Leao R, Petrella AR, Kachura JR, Fleshner N, Matthew A, Finelli A, Jewett MAS, Hamilton RJ. Urol Oncol. 2020 Jun;38(6):603.e17-603.e25.
Diagnostic utility of axial imaging in the evaluation of hematuria: A systematic review and critical appraisal of the literature. Wallis CJD, Sayyid RK, Manyevitch R, Perlis N, Lokeshwar VB, Fleshner NE, Terris MK, Nielsen ME, Klaassen Z. Can Urol Assoc J. 2020 Jul 27.
Re-operation within 30 days of radical cystectomy: Identifying high-risk patients and complications using ACS-NSQIP database. Sayyid RK, Magee D, Hird AE, Harper BT, Webb E, Fratino KL, Terris MK, Madi R, Satkunasivam R, Wallis CJD, Klaassen Z. Can Urol Assoc J. 2020 Jul 17
Obese men undergoing radical prostatectomy: Is robotic or retropubic better to limit positive surgical margins? Results from SEARCH. Nik-Ahd F, Howard LE, Aronson WJ, Terris MK, Klaassen Z, Cooperberg MR, Amling CL, Kane CJ, Freedland SJ. Int J Urol. 2020 Jul 17.
Promotion of epithelial hyperplasia by interleukin-8-CXCR axis in human prostate. Smith DK, Hasanali SL, Wang J, Kallifatidis G, Morera DS, Jordan AR, Terris MK, Klaassen Z, Bollag R, Lokeshwar VB, Lokeshwar BL. Prostate. 2020 Sep;80(12):938-949
Skene's Gland Adenocarcinoma: Borrowing from Prostate Cancer Experience for the Evaluation and Management of a Rare Malignancy. Kaufman ME, Miller DT, Ullah A, White J, Singh G, Kolhe R, Williams H, Mittal P, Parikh J, Terris MK. Urology. 2020 Jun 3
Obesity, race, and long-term prostate cancer outcomes. Vidal AC, Oyekunle T, Howard LE, De Hoedt AM, Kane CJ, Terris MK, Cooperberg MR, Amling CL, Klaassen Z, Freedland SJ, Aronson WJ. Cancer. 2020 Aug 15;126(16):3733-3741.
Retzius-sparing robotic-assisted laparoscopic radical prostatectomy: racial considerations for 250 consecutive cases. Sayyid RK, Sherwood D, Simpson WG, Terris MK, Klaassen Z, Madi R. J Robot Surg. 2020 May 29.
Molecular targeting of renal cell carcinoma by an oral combination. Jordan AR, Wang J, Yates TJ, Hasanali SL, Lokeshwar SD, Morera DS, Shamaladevi N, Li CS, Klaassen Z, Terris MK, Thangaraju M, Singh AB, Soloway MS, Lokeshwar VB. Oncogenesis. 2020 May 19;9(5):52
Race does not predict skeletal-related events and all-cause mortality in men with castration-resistant prostate cancer. Patel DN, Howard LE, De Hoedt AM, Amling CL, Aronson WJ, Cooperberg MR, Kane CJ, Klaassen ZW, Terris MK, Freedland SJ. Cancer. 2020 Jul 15;126(14):3274-3280.
Elevated suicide risk among patients with urologic malignancies. Sayyid RK, Wallis CJD, Dymanus K, Jazzar U, Goldberg H, Williams SB, Klaassen Z. Ann Transl Med. 2020 Mar;8(6):272
Relation between surgeon age and postoperative outcomes: a population-based cohort study. Satkunasivam R, Klaassen Z, Ravi B, Fok KH, Menser T, Kash B, Miles BJ, Bass B, Detsky AS, Wallis CJD. CMAJ. 2020 Apr 14;192(15):E385-E392.
Metastatic Hormone-sensitive Prostate Cancer: Current Perspective on the Evolving Therapeutic Landscape. Hall ME, Huelster HL, Luckenbaugh AN, Laviana AA, Keegan KA, Klaassen Z, Moses KA, Wallis CJD. Onco Targets Ther. 2020 Apr 29;13:3571-3581
Martha K. Terris, MD
Urologic Oncology
Georgia Cancer Center
Appointments/Referrals (706)721-0248/(706)-721-6744
Fax: (706) 721-8776
Zachary Klaassen, MD
Urologic Oncology
Georgia Cancer Center
Appointments/Referrals (706)721-0248/(706)-721-6744
Fax: (706) 721-8776
Bradley Morganstern, MD
Pediatric Urology
Medical Office Building 3rd Floor
Appointments/Referrals (706)721-3042
Fax: (706) 721-5550
Rabii Madi, MD
Urologic Oncology and Robotic Surgery
Georgia Cancer Center
Appointments/Referrals (706)721-0248/(706)-721-6744
Fax: (706) 721-8776
Sherita King, MD
Prosthetics and Sexual
Medical Office Building 4th Floor
Appointments/Referrals (706)721-7000
Fax: (706) 721-4444
Pablo Santamaria, MD
General Urology, Stones
Medical Office Building 4th Floor
Appointments/Referrals (706)721-7000
Fax: (706) 721-4444
Lynn Allmond, NP
General Urology
Medical Office Building 4th Floor
Appointments/Referrals (706)721-7000
Fax: (706) 721-4444
Regina Canty, NP
Urologic Oncology
Georgia Cancer Center
Appointments/Referrals (706)721-0248/(706)-721-6744
Fax: (706) 721-8776
Miranda Wood, NP
Pediatric Urology
Medical Office Building 3rd Floor
Appointments/Referrals (706)721-3042
Fax: (706) 721-5550
|
Experimental evaluation of natural hydraulic lime renders with nanoclay and nanolime to protect raw earth building surfaces
Francesca Stazi\textsuperscript{a,}\textsuperscript{*}, Nicola Pierandrei\textsuperscript{a}, Costanzo Di Perna\textsuperscript{b}, Francesca Tittarelli\textsuperscript{a}
\textsuperscript{a} Department of Materials, Environmental Sciences and Urban Planning (SIMAU), Università Politecnica delle Marche, Italy
\textsuperscript{b} Department of Industrial Engineering and Mathematical Sciences (DIISM), Università Politecnica delle Marche, Italy
**Keywords:**
Natural hydraulic lime
Earth
Nanoclay
Nanolime
Renders
**Abstract**
In this study Natural Hydraulic Lime (NHL) was combined with clay and lime, the main cementitious materials used in ancient buildings, to develop a new render more suitable for applications on raw earth substrates. Nanoclay and nanolime have been separately added to a commercial NHL-based ready-mixed powder. Pure and nano-additivated NHL renders have been compared in terms of microstructure (by SEM and mercury porosimetry), mechanical performance (by dynamic elastic modulus, flexural and compressive strength tests), adhesion to the substrate (by shear strength and pull-off tests), erosion resistance (by pressure spray test), and thermo-hygrometric performance (by water absorption and thermal conductivity tests). The obtained results demonstrate that both nanoparticles increase the water absorption and decrease the mechanical properties of the render but enhance the adhesion with the earthen support and the protection against water erosion. Among the two nanoparticles, the addition of nanoclay was found to be preferable since it gives to the render the highest mechanical compatibility with the underlying layer and the best durability against erosion.
1. Introduction
Hydraulic lime, intended as a mix of lime and pozzolan set through hydration, has been used as a binding material for mortar production since ancient times, especially in humid areas with a high availability of limestone naturally containing clay impurities [1]. Between the 18th and 19th centuries, the field of hydraulic binders evolved with the production of NHL, obtained through a rapid hydration process by burning argillaceous or siliceous limestones, below the sintering point (at temperatures of 850–1000 °C), and the subsequent reduction to powder by slaking [2,3].
With the advent of Portland cement in the 19th century, NHLs production strongly decreased because the harder compressive strengths and water resistance of Portland cement were considered superior qualities. However, in recent years, cement-free NHL based mortars, have gained a renewed interest for applications in masonry bricklaying, internal plastering, and external rendering for different reasons. Compared to cement-based mortars, they have a lower environmental impact owing to reduced burning temperature. Moreover, they show a higher compatibility with historic masonries or raw earth surfaces because they have a greater ability to exchange water vapor thus preventing moisture condensation and because they present thermal expansion and mechanical elasticity values closer to the supporting material, thus allowing the accommodation of movements [3].
\* Corresponding author.
E-mail addresses: email@example.com (F. Stazi), firstname.lastname@example.org (N. Pierandrei), email@example.com (C. Di Perna), firstname.lastname@example.org (F. Tittarelli).
https://doi.org/10.1016/j.cscm.2022.e01564
Received 1 April 2022; Received in revised form 20 September 2022; Accepted 11 October 2022
Available online 13 October 2022
2214-5095/© 2022 The Authors. Published by Elsevier Ltd. This is an open access article under the CC BY-NC-ND license (http://creativecommons.org/licenses/by-nc-nd/4.0/).
In contrast to non-hydraulic limes, which harden by reaction with carbon dioxide in the air, hydraulic limes are characterized by the ability to harden with water and under high humidity conditions [4] as well as by faster and higher achievement of mechanical strength [5]. They also have the ability to improve their performance over time; when exposed to air, they react with atmospheric carbon dioxide by carbonation thus completing the hardening process [2], and behaving as CO$_2$ capturing materials. Moreover, because the carbonation process is long-lasting, they achieve higher strength in the long term than in the early stage, ensuring durable mechanical performance.
Owing to these advantages, NHL was successfully used in raw earth materials and blocks as stabilizer [6] and as binder in eco-friendly cement-free mortars. Moreover, it is increasingly used as a sacrificial breathable surface for the restoration and protection of walls [7] with damp and salt deposits and as a viable alternative to earthen mortars for plastering and rendering of raw earth walls of different types (adobe, cob, extruded bricks, rammed earth, and compressed earth blocks). Moreover, a recent use of NHL-based mortars concerns their application on the surfaces of extruded earthen claddings placed externally and internally in wooden panels of lightweight timber framed buildings [8] (Fig. 1). These claddings, which are made of unbaked and extruded earth blocks, are secured to external fir boards through metal anchors [9].
The literature on NHL rendering and plastering mortars mainly relates to the mix design optimization, and to the exploration of the effects of additives on the long-term performance of the final products.
Research on the mix design choice mainly considers the binder-to-sand ratio, water-to-binder ratio, sizes/packing density of aggregates and type of binder, all of which are found to play an important role in the mechanical and physical performance of NHL-based products [2,5]. This encouraged the proposal of a comprehensive framework to support the multiparametric mix design of NHL mortars [3]. Other authors, focusing on premixed mortars, stressed the different behavior due to unequal underlying substrate and curing conditions [10].
As far the influence of additives is concerned, several studies addressed different optimization purposes of hydraulic mortars: for waterproofing, for example using siloxane [11] or natural herbs [12]); for water retention, for example with cellulose ethers additions [13]; to enhance the compatibility between historic masonries and restoration materials, for instance through siliceous sand and crushed brick [14]; to optimize the sound absorption through lightweight pumice aggregates [15]; to increase the mechanical performance and simultaneously tailor the water adsorption through ceramic residues [16] and waste graphite powder [17].
Formulations of NHL with expanded glass aggregates have been demonstrated to enhance the depolluting abilities of NHL mortars [18]. The addition of metakaolin to NHL mortars has been found to improve its strength characteristics especially under humid curing conditions but the pozzolanic compounds showed some instability with ageing determining a decrease of strength [19].
Few studies have suggested the adoption of nanotechnology to enhance natural hydraulic lime mortars. Among them, rather recent studies addressed the incorporation if graphene oxide in NHL mortars achieving a slight improvement of mechanical and physical characteristics [20]. The addition of nano-SiO$_2$ (2–3% by weight) has given an improvement of the mechanical properties, durability and compatibility with the masonry [21,22]. The addition of TiO$_2$ (3% by weight) has been found to: enhance the mortar-masonry compatibility, increase the elasticity modulus as well as humidity retention and, consequently, improve the adhesive capacity [23] and antifungal properties [24]. The addition of nano-TiO$_2$ and perlite to lime-metakaolin mortars has been demonstrated to lower the structure density with a decrease in mechanical properties but, conversely, an enhancement of salt decay resistance and thermal insulating properties [25]. The addition of nanofibers (for example cellulose fibers) to NHL has been found to have a positive effect on water resistance and render-support compatibility, but also to reduce the mechanical strength [26]. Moreover, most additions have been demonstrated to induce changes in the color and texture of hardened NHL pastes or mortars, making them unsuitable for heritage buildings.
Nanolime and nanoclay were selected in this study for their morphological and color compatibility with historic and earthy-based substrates and for their proven ability to provide hosting materials with enhanced mechanical properties. Indeed, nanoclay has been demonstrated to provide improved performance in terms of tensile strength and reduced microcracks in cement-based materials [27, 28] and also to guarantee effective protection for highly porous stones and marbles [29]. Similarly, nanolimes have been shown to confer long-lasting antibacterial effects with promising applications in the cultural heritage field [30], and to increase both mechanical
and water resistance properties when applied to lime mortar substrates [31,32]. However, to the best of the authors’ knowledge, no studies have addressed the adoption of nanoclay or nanolime in natural hydraulic lime renderings. Their contribution to the mechanical, and thermophysical performance of NLH is still not fully understood. Moreover, the durability of NHL respect the destructive action of weathering has been addressed for mortar joints in masonries bricklaying [10,33,34] while rarer are the studies on surface rendering materials. This latter issue is becoming increasingly important in light of the recent increasing occurrence of extreme rainfall events due to the well-known worldwide climate change. More studies on the development of natural cement-free rendering solutions, compatible with buildings of historical interest and earthen substrates that are able to protect external surfaces against weathering are needed.
Therefore, the aim of this study was to contribute to fill the identified open issues by evaluating the effectiveness of the addition of nanolime or nanoclay to Natural Hydraulic Lime (NHL) renderings, to protect underlaying raw earth substrates. To this end, pure and additivated specimens were compared in terms of microstructure by SEM and mercury porosimetry, mechanical performance by dynamic elastic modulus, flexural and compressive strength, adhesion to the substrate by shear strength and pull-off tests, erosion resistance by pressure spray test, and thermo-hygrometric performance in terms of water absorption and thermal conductivity.
2. Materials
2.1. Rendering mortars formulation
A commercial ready-mixed powder, Kerakoll Biocalce, was used in the experimentation. According to the technical datasheet it contains 20% of pure NHL 3.5, 1–2.5% of ultra-thin pozzolanic additives, 2.5–10% of silica sand with two different grain size fractions (0.1–1 mm and 0.1–0.5 mm), and 50–75% of a medium sized powder (0–2.5 mm) of dolomitic limestone. The apparent density of the adopted ready-mixed powder is reported as 1.28 kg/dm$^3$. The binder is classified as NHL 3.5, (moderately hydraulic) according to EN 459-1:2015 [35], where the number stands for the minimum compressive strength at 28 days of hardening in N/mm$^2$. The more hydraulic the lime is, the faster it sets, and the higher its final strength. NHL 3.5 was selected because it is frequently used for external works and it is expected to be more ‘breathable’ and more flexible than NHL5.
The base mortar (CA) was obtained by adding the powder to clean water following the amounts suggested by the technical data sheet (25 kg of ready premixed powder in 5.1 l of water), corresponding to a water/lime ratio by weight of about 1.
The fresh mortar was then mixed manually with a trowel for 5 min, until a uniform mix. The consistency was determined using a flow table test according to EN 1015–3 obtaining a final flow value of 170 mm corresponding to a soft consistency. The apparent density of the dry hardened mortar was 1.6 kg/dm$^3$.
Two different nanoparticles were added separately to the base mortar: nanoclay and nanolime. The nanoparticles were added in an amount equal to 2% of the dry weight of premixed powder (Table 1).
In the case of nanoclay (CC), a commercial hydrophilic bentonite (Sigma-Aldrich) clay was used. According to the data sheet, it consists of $\sim 1$ nm thick aluminosilicate layers surface-substituted with metal cations and stacked in $\sim 10$ µm-sized multilayer stacks; the relative density is 2.400 g/cm$^3$.
The particles were previously added to the powder in dry state, and then clean water was incorporated through a trowel for 5 min.
In the case of nanolime (CL), only nanolime suspensions in alcohols were commercially available. In this case commercial colloidal nano-particles of lime hydrate suspended in ethanol, with a concentration of 25 g/l, typically adopted for stone and plaster consolidation, were used (CaLoSil, IBZ-Salzchemie & Co.KG). According to the data sheet, the particles sizes are between 50 nm and 250 nm with an average value of 150 nm. Ethanol was previously separated by a simple distillation process by heating the solution at $T = 78 \pm 2$ °C. A small ethanol portion (4% of dry lime weight) was maintained to avoid the onset of the carbonation process of nanolime in contact with air and to favor the particle dispersion through mechanical mixing. Subsequently, the components were manually mixed with water and the render was smoothened with a trowel.
The final mixes are reported in Table 1.
2.2. Rendering mortar specimens
Different types of rendering mortar specimens were realized:
- Specimens applied to walls or to single clay blocks.
| N° | Name | Composition | NHL (g)$^a$ | (%)$^b$ | Nanoclay (g)$^c$ | (%)$^d$ | Nanolime (g)$^e$ | (%)$^f$ | Ethanol (g)$^g$ | (%)$^h$ |
|----|--------|-----------------------------|-------------|---------|------------------|---------|------------------|---------|----------------|---------|
| 1 | CA | Natural hydraulic lime (NHL)| 1000 | 79 | – | – | – | – | – | – |
| 2 | CC | NHL + nanoclay | 1000 | 77 | 20 | 2 | – | – | – | – |
| 3 | CL | NHL + nanolime | 1000 | 77 | – | – | 20 | 2 | 40 | 4 |
$^a$ Dry mass.
$^b$ Percentage by mass of NHL.
Specimens with sizes according to the test standards, not applied to the support.
The first group of specimens consisted of a uniform layer of 20 mm thick as suggested by EN 1015-12:2016 [36] and also by [37] and [38]. The undelaying application area of the wall was cleaned with a brush and wetted with a water spray. The renders were then applied and smoothed to the wall with a trowel and shaped with the aid of steel molds. The application envisaged a single layer of mortar as suggested by the manufacturer.
The specimens belonging to the second group were produced by casting and compacting mortar in standard steel molds.
All the renders (either single specimens or those applied on earthen walls) were covered with polyethylene films in the first week of curing and subsequently left 21 days under laboratory conditions \((T = 20 \, ^\circ C \pm 3 \, ^\circ C; \, RH = 60 \pm 5\%)\) by removing the plastic protections.
The specimen dimensions and numbers are summarized in Table 2.
### 2.3. Earth walls substrate
Four earth walls were built as substrate for applying the renders, equal to those used for external massive claddings in timber-framed buildings (Fig. 1). Therefore, masonry with unfired and extruded raw earth blocks was selected. The block composition was based on a matrix of clayey soil (70%) and wooden fibers (30%) as natural stabilizers. Each earth block had nominal dimensions of \(215 \, \text{mm} \times 230 \, \text{mm} \times 115 \, \text{mm}\). Laterally, the dovetail joints served as a guide for aligning the blocks and ensuring their mechanical connection.
The dimensions of the 4 walls were \(45 \, \text{cm} \times 70 \, \text{cm} \times 10 \, \text{cm}\). Their realization involved the following steps: (i) clay was mixed with water at a ratio of 2:1; (ii) the lateral and lower surfaces of each block were uniformly wetted in this clay-based mortar; and (iii) each block was layed by sliding it vertically along the dovetail joints.
The walls were cured for three months in a controlled laboratory environment \((T = 20 \, ^\circ C \pm 3 \, ^\circ C; \, RH = 60 \pm 5\%)\).
### 3. Experimental methods
#### 3.1. Render characterization
Mortar characterization analyses were conducted by SEM and mercury porosimetry test.
*SEM* was used to evaluate the microstructure of the samples (Instrument Model: VEGA with accelerating voltage from 200 V to 30 kV and resolution of 3 nm at 30 kV). Three samples of \(10 \, \text{mm} \times 10 \, \text{mm} \times 10 \, \text{mm}\) were analyzed for each formulation. They were obtained from the fragments of the specimens that have previously been subjected to mechanical tests. To prevent the accumulation of electrostatic charges at the surface, the samples were coated with an ultrathin coating of gold by high-vacuum evaporation.
*Mercury porosimetry analyses* were used to obtain the percentage of open porosity and dimensional distribution of the pores of the samples immersed in a mercury bath with increasing pressure (Instrument Pascal 140/240, ThermoFisher). Three samples of \(10 \, \text{mm} \times 10 \, \text{mm} \times 10 \, \text{mm}\) obtained from the fragments of the specimens that have previously been subjected to mechanical tests, were analysed for each formulation. The Washburn equation [39] was used to relate the applied pressure to the pore radius. A contact angle of 135°, a Hg surface tension of 0.56 N/m and a pressure ranging from 0 to 200 MPa were adopted.
#### 3.2. Render mechanical strength and adhesion to the substrate
The mechanical performance of the renders and their adhesion to the substrate were evaluated through mechanical strength tests (dynamic elastic modulus, flexural strength, and compressive strength) and shear/pull off test. For each mechanical test, the experiments involved the casting of three specimens \((40 \, \text{mm} \times 40 \, \text{mm} \times 160 \, \text{mm})\) in steel molds.
*The dynamic elastic modulus* \(E_d\) (N/mm²) was evaluated through Pundit ultrasonic tester by measuring the wave propagation speed in the mortar specimens (Fig. 2a), according to EN 12504-4:2021 [40].
*The flexural* (Fig. 2b) and *compressive strengths* (Fig. 2c) were assessed through a 400 kN hydraulic press (Galdabini, Italy) according to EN 1015-11:2019 [41].
| Test | CA | CC | CL | Size |
|-------------------------------------------|------|------|------|-----------------------------|
| Scanning Electronic Microscopy (SEM) | 3 | 3 | 3 | \(10 \, \text{mm} \times 10 \, \text{mm} \times 10 \, \text{mm}\) |
| Mercury Porosimetry | 3 | 3 | 3 | \(10 \, \text{mm} \times 10 \, \text{mm} \times 10 \, \text{mm}\) |
| Compression Tests | 3 | 3 | 3 | \(40 \, \text{mm} \times 40 \, \text{mm} \times 160 \, \text{mm}\) |
| Shear Test | 5 | 5 | 5 | \(50 \, \text{mm} \times 40 \, \text{mm} \times 20 \, \text{mm}\) |
| Pull-off Test | 5 | 5 | 5 | \(d = 50 \, \text{mm}, \, t = 20 \, \text{mm}\) |
| Karsten Pipe Test | 3 | 3 | 3 | \(250 \, \text{mm} \times 250 \, \text{mm} \times 20 \, \text{mm}\) |
| Heat Flow Meter Test | 3\(^a\) | 3\(^a\) | 3\(^a\) | \(300 \, \text{mm} \times 300 \, \text{mm} \times 30 \, \text{mm}\) |
| Erosion Test | 3\(^a\) | 3\(^a\) | 3\(^a\) | \(250 \, \text{mm} \times 250 \, \text{mm} \times 20 \, \text{mm}\) |
\(^a\) Three different measurement points on one specimen.
To determine the flexural strength, a load was applied at a uniform rate of 10 N/s providing the failure occurrence within a period of 30–90 s.
The compressive strength was measured by applying an increasing load at a speed of 100 N/s (according to Annex B, Category CS II) until failure on specimens with nominal cross section area of 1600 mm$^2$. The strength of each specimen was recorded at the nearest 0.05 N/mm$^2$. The category of each mortar was classified according to EN 998-1:2016 [42] by averaging the values of the three specimens and approximating the results to the nearest 0.1 N/mm$^2$.
*The adhesive strength* was evaluated through shear test according to the procedure proposed by Hamard et al. [37]. For each render formulation, 5 specimens (50 mm × 40 mm × 20 mm) were applied on the wall panels for a total of 15 specimens (Fig. 2d). After curing, the specimens were loaded until failure by increments of 0.5 kg applied for 15 s. Some adaptations were applied to the wooden loading device proposed by Hamard, as the insertion of a metal sheet frame, owing to higher loads. Once the failure mass is recorded, the average shear strength ($\tau_{max}$, N/mm$^2$) was calculated as follows:
$$\tau_{max} = \frac{m_f \cdot g}{S}$$
(1)
where $m_f$ is the failure mass (kg), $g$ is the gravitational acceleration = 9.81 m/s$^2$, and $S$ is the specimen surface area (mm$^2$).
*The adhesive strength was also evaluated using a pull-off test* (Fig. 2e) according to EN 1015-12:2016 [36] with the aid of a Pull-off tester Controls 58-C0215. Five specimens were prepared for each render formulation, for a total of 15 specimens, and were applied to the unbaked clay blocks. The diameter of the renders was 50 mm, and the thickness was 20 mm. After curing, the pull-head was glued centrally on the test area. A load without shock was applied at a uniform rate of 0.011 N/mm$^2$s, so that failure occurred between 20 and 60 s.
Individual adhesive strengths were recorded at the nearest 0.05 N/mm$^2$. The adhesive strength was calculated as the mean value of the individual values of the five specimens for each type of render mortar to the nearest 0.1 N/mm$^2$.
3.3. Thermo-hygrometric tests
Thermo-hygrometric tests included water absorption and thermal conductivity tests.
*Water absorption by capillarity* was evaluated using the Karsten pipe method with a tool designed according to EN 16302:2013 [43] and referring to [44] for adaptations and simplifications. The Karsten pipe is a tube graduated to the $10^{th}$ of a millimeter provided, at the lower end, with an aperture of 500 mm$^2$ internal area. The pipe was sealed to the sample with mastic and then filled with water. The initial water column, 92 mm high, exerted a pressure of 900 Pa in the contact area between the pipe and specimen surface. The tests were carried out on three specimens, 250 mm $\times$ 250 mm $\times$ 20 mm in size, applied to the wall panels in raw earth. For each render formulation, the water absorption rate was evaluated at two test points, with readings of the reduction in the water level every minute for 15 min.
*Thermal conductivity* was evaluated using the heat flow meter method according to UNI EN 12664:2002 [45]. For each render formulation, one specimen was realized with dimensions of 300 mm $\times$ 300 mm $\times$ 30 mm for a total of three specimens. The samples were poured into steel molds. The test system (Fig. 3) was composed of a box of insulating material that was closed during the execution of the test to ensure an adiabatic internal environment. A unidirectional constant heat flow was generated by adopting a hot and cold plate connected to thermostatically controlled water baths at T = 25 °C and T = 15 °C, respectively. Temperature probes and flowmeters on both sides of the specimen were used to measure the thermal gradient and crossing heat flux in three different sample points and the final data were obtained as average values. Initially, the system was calibrated using a panel with known thermal conductivity. The test duration was 24 h for all the samples.
3.4. Erosion test
The aim of the test was to comparatively measure the durability of the rendering mortars as sacrificial surfaces under the worst conditions represented by the eventuality of eroded topcoat finishing. *Water erosion resistance* was evaluated using the pressure spray method (Fig. 4), according to the New Zealand Standard NZS 4298:2020 [46] and a previous study by our research group for adaptations and simplifications [38] also in consideration of the higher strength of the tested material respect to clay materials for which the standard is specifically focused. The test was carried out with a tool designed according to the standard on three specimens of size 250 mm $\times$ 250 mm $\times$ 20 mm, applied as in the current technique in a unique layer (20 mm thick) to the earthen wall panels. The test lasted for 60 min, and the erosion depth ($D$, mm) was measured every 15 min. The water jet was projected by a distance of 470 mm at a pressure of 50 kPa, simulating the accelerated aging by means of the action exerted by the wind-driven rain.
4. Results and discussions
The following subsections present the results of the experimental tests. The data are summarized in Table 3.
4.1. Render characterization
The SEM observations (Figs. 5–7) showed that in CA and CL, the microstructure was heterogeneous with flat hexagonal portlandite crystals, needle-like hydration products and aggregates. On the other hand, portlandite crystals were not present in CC, probably because of the pozzolanic reaction between clay and lime hydroxide, which also gave a more homogeneous and compact microstructure.
The addition of 2% of nanoclay (CC) created a denser microstructure than the reference CA because the nanoparticles filled the voids thanks also to the pozzolanic reaction. This result confirms the findings of Farzadnia et al. [47], who evaluated the properties and microstructure of cementitious mortars with different percentages of nanoclay. The authors highlighted that nanoclay addition led to a more homogeneous microstructure with enhanced properties owing to the consumption of portlandite in the cement matrix because of the pozzolanic reaction, even with swelling drawbacks.
**Table 3**
Results obtained with the tests carried out on the different mortars.
| Parameters | Mean values (standard deviation) | Tool/Standard |
|-------------------------------------------------|----------------------------------|--------------------------------|
| | CA | CC | CL |
| Total open porosity (%) | 39 (± 2) | 24 (± 1) | 36 (± 2) | Mercury Porosimeter |
| Average Pore diameter (µm) | 0.195 (± 0.004) | 0.372 (± 0.005) | 0.192 (± 0.004) | |
| Dynamic elastic modulus $E_d$ (N/mm²) | 3705 (± 24) | 2440 (± 39) | 2764 (± 46) | Pundit Ultrasonic test/ |
| Flexural strength $f$ (N/mm²) | 1.60 (± 0.22) | 0.80 (± 0.08) | 1.00 (± 0.22) | EN 12504:4:2021 |
| Compressive strength $\sigma$ (N/mm²) | 3.50 (± 0.29) | 2.00 (± 0.10) | 2.40 (± 0.04) | Hydraulic press/ |
| | | | | EN 1015–11:2019 |
| Shear strength $\tau_{max}$ (N/mm²) | 0.197 (± 0.01) | 0.176 (± 0.01) | 0.173 (± 0.01) | Shear test [37] |
| Pull off strength $f_p$ (N/mm²) | 0.24 (± 0.01) | 0.18 (± 0.01) | 0.16 (± 0.01) | EN 1015-12:2016 |
| Water absorption rate $C_{KB10min}$ (g/m²s⁻¹) | 0.46 (± 0.04) | 1.33 (± 0.01) | 0.71 (± 0.04) | Karsten pipe method/ |
| | | | | EN 16302:2013 |
| Thermal conductivity $\lambda$ (W/(mK)) | 0.10 (± 0.01) | 0.11 (± 0.01) | 0.11 (± 0.01) | Heat flow meter method/ |
| | | | | UNI EN 12664:2002 |
| Erosion rate $D$ (mm) | 3 (± 0.5) | 0 (± 0.0) | 2 (± 0.5) | Water erosion test/ |
| | | | | NZS 4298:2020 |
| Bulk density of the dry hardened mortar (kg/m³) | 1580 (± 16) | 1704 (± 8) | 1634 (± 15) | EN 1015–10 |
**Fig. 5.** SEM Observations: CA mortar.
*Mercury porosimetry tests* showed that the percentage of total open porosity decreased with the nanoparticles in the mixture (*Fig. 8*). The CA base render achieved a total open porosity value of 39% (*Table 3*). The most significant porosity decrease was obtained by CC formulation, with a value of 24%, confirming the SEM observations where CC microstructure appeared the most compact. CL instead recorded porosity values much closer to the reference render (both around 36%).
Even if nanoparticle addition decreased the total porosity of mortars, especially in nanoclay it slightly increased the average pore diameter, with values ranging from $d_{av} = 0.195 \mu m$ for CA to $d_{av} = 0.372 \mu m$ for CC.
The results were compared with the findings of other authors [14] relating to the restoration of a historic stone wall in Crete using a render mortar based on natural hydraulic lime. The cumulative volume (approximately 140 mm$^3$/g) as well as the open porosity value of 26%, recorded for the mortar in their work were very similar to the values obtained in the present work by CC (130 mm$^3$/g and 24%).
Nanoparticles, as nanolime and nanoclay, are often introduced into cement-based materials to optimize the pore structure thanks to their physical action (filler action), which partially closes the porosity paths, and their ability to act as additional nucleation sites (nucleation effect) for the formation of new hydration products (C-S-H), accelerating the binder hydration [48], due to their high specific surface area [49–51]. Both these effects gave a closer and more compact structure, as SEM observations and the measured density values suggest. In addition, in the case of nanoclays, as reported above, the formation of secondary CSH produced by the pozzolanic reaction with calcium hydroxide, further contributed in giving a more closer and compact structure, as demonstrated for other types of formulations by [52–54].
However, unexpectedly, in the case of CC, even with a lower total open porosity, the average pore size was slightly increased. Due to its hydrophilic nature, the bentonite clay shows dramatic shrink and swell properties on hydration due to 2:1 layer arrangement of aluminosilicates [55]. The bentonite clay particles swell in the fresh mortar mix due to the absorption of water in their interlayer and release water and shrink during aging under low humidity, generating additional voids at the interface. These voids do not provide any resistance to the cracks development under loading and reduce the mechanical strength. As a matter of fact, pre-swelled bentonite slurry is also used as a pore forming agent in cement pastes [56].
4.2. Render mechanical strength and adhesion
The values of the Young’s modulus ranged from 3705 N/mm² for CA to 2440 N/mm² for CC (Table 3). As specified by Hamard et al. [37] the best render is the one with the elastic modulus closest to (or lower than) that of the masonry; thus, the stresses are supported by the latter, thus preventing cracks or splits of the coating. Therefore, in the present work, the best render is that with 2% nanoclay additives because it has the lowest value and is closest to that of the raw earth masonry used as a support, as obtained in a previous study ($E_d = 700$ N/mm²) [57].
Regarding the mechanical performance, the addition of the nanoparticles lowered both the *flexural* and *compressive strength* (Table 3) values of the render with respect to the reference render CA. However, all the renders remained within the CS II category (with regard to compression), falling in the range set by UNI EN 998-1:2016 [42]. In all cases, the nanoclayed CC mortar exhibited the lowest value; even if this sample showed the closest and most compact structure it was characterized by the presence of bigger pores than the other formulations (see Table 3) thus giving lower final strength values.
The results obtained from the adhesion tests showed that addition of nanoparticles did not produce a significant decrease in adhesion strength with the substrate, with values obtained by *shear tests* ranging from 0.197 N/mm² for CA to 0.173 N/mm² for CL (Table 3). In all the cases, a shear force equal to 10 times the render own weight was reached (a safety coefficient of 10 was assumed) [37].
*Adhesion strength* was also evaluated through the *pull-off* test, which recorded a slight decrease owing to the addition of...
nanoparticles. However, this performance reduction is negligible since, as suggested by UNI EN 1015-12:2016 [26], all the values can be approximated to 0.20 N/mm$^2$, satisfying in all cases the limit of 0.20 N/mm$^2$ set by UNI EN 998-1:2016 [42] (Table 3). For both the adhesion tests, the cracks occurred at the support-render interface. In summary, the renders showed similar behavior with regard to adhesion.
### 4.3. Thermo-hygrometric tests
The water absorption rates of the functionalized renders CC and CL (respectively of 1.33 g/m$^2$s$^{-1}$ and 0.71 g/m$^2$s$^{-1}$) resulted greater than that of the reference render CA (equal to 0.46 g/m$^2$s$^{-1}$) (Fig. 9 and Table 3). The highest water absorption rate shown by CC is due to the larger average size of the pores, as demonstrated by the mercury porosimetry test and probably also to the ability of clay particles to adsorb water. Therefore this formulation is more prone to swelling due to the entrapment of water within its layers [14], increasing the probability of penetration of aggressive substances. The increase of water absorption with nanoclay has also been demonstrated for cement-based mortars [58].
For these mortars, an increase in water absorption, when the total open porosity increases and the dry density decreases, has been reported in the literature [59], confirming the results obtained in the present work.
The thermal conductivity of the renders with nanoparticles (Table 3) showed only a slight increase compared to the reference render, with a value of 0.10 W/(mK) for CA, 0.11 W/(mK) for CC and 0.11 W/(mK) for CL. However, the thermal resistance values (Fig. 9 b) remained within the limits set by the UNI EN 12664:2002 [45] (R $\geq$ 0.1 m$^2$K/W).
In summary, the thermal conductivity test demonstrated that both nanoparticle additions resulted in only negligible reductions in thermal performance. This result is confirmed by other researchers’ study [17], that found an increase of the thermal conductivity of a natural hydraulic lime (NHL) after the addition of 2% graphite powder.
This can be explained with the densification of the samples with additives (see Table 3) that are therefore subjected to increased conductive thermal flow.
### 4.4. Erosion test
The results of the erosion tests are shown in Fig. 10 and Table 3. This test is particularly important for conservative purposes because it characterizes the ability of the renders to protect the underlying supports. After an exposure to accelerated weathering for 60 min, the CC specimen showed the best outcome with no erosion, demonstrating excellent resistance. The other render types exhibited a low erosion depth. Although erosion occurred, the values were within the limits set by the NZS 4298: 2020 ($I = 1$).
In summary, the data demonstrated the best properties of the nanoclayed formulation compared to the others. High water absorbing materials are less prone to natural rain surface erosion. Moreover its low total open porosity and denser microstructure that the other coatings make its surface smoother and lesser liable to water erosion [60].
## 5. Conclusions
This study compares the effects of nanoclay and nanolime additions on the mechanical and durability properties of a commercial ready mixed render based on NHL used as protective layer for a raw earth masonry.
The outcomes can be summarized as follows:
- The nanoparticles improve the compatibility of the plaster with the earth masonry, thanks to the reduction of its dynamic elastic modulus up to 34%. This makes the stiffness of the protective layer closer to that of the substrate, so that stresses are supported by the latter during the service life, thus preventing cracks or splits of the render.
- Both nano-additions give to the NHL render an increased resistance against erosion due to atmospheric agents; the erosion depth decreased from 3 mm (in the reference formulation) to 2 mm with nanolime and to 0 mm with nanoclay. This is due to the nucleation effect of both nanofillers that gives a less porous and more compact structure to the render.
- An increase in the water absorption of the render is observed if both types of nanoparticles are added, with values more than doubled for nanoclay. This is due to the increase of the average pore size of the render in the presence of nanoparticles, even if with a decrease in the total porosity.
- The increase of the average pore size of the render with the addition of nanoparticles is responsible for the slight reduction of its mechanical properties in terms of flexural strength ($-50\%$ and $-37\%$ with nanoclay and nanolime additions, respectively), compression strength ($-40\%$ and $-30\%$ for nanoclay and nanolime additions, respectively) and adhesion to the wall ($-10\%$ reduction in shear strength for suspended loads with both nanoparticles).
In summary, comparing the effect of the two types of nanoparticles, the addition of nano-clay to the NHL render is to be preferred to preserve the raw earth support, since it gives to the render the best mechanical compatibility with the underlying earthen masonry and the highest durability against erosion by atmospheric agents. Compatibility of materials and durability against atmospheric agents are two fundamental aspects in the protection and conservation of eco-friendly earthen building envelopes.
Since the resulting poor effect of the tested nanoparticles on the mechanical performance of plasters was quite unexpected, further studies on this topic are needed by increasing the fillers dosages and by investigating the effect of the selected nanoparticles also on the performance of clay-based coatings.
Funding
The study was supported by Athenaeum Basic Research.
Ethical compliance
No human participants were involved in the study.
Declaration of Competing Interest
The authors declare that they have no known competing financial interests or personal relationships that could have appeared to influence the work reported in this paper.
Data availability
The data that has been used is confidential.
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|
YOUR GUIDE TO Having Surgery
APPOINTMENT
Surgery Date: _______________________
Arrival Time: _______________________
You will receive a call in the afternoon the day before confirming your arrival time.
Location: ___________________________
_______________________________
Marshall Medical has given you this brochure to answer questions you may have about your surgery. It will guide you and your family through the entire process, from pre-op (before surgery) to surgery, hospitalization, and recovery. Understanding what will happen can help you prepare for your hospital stay and speed your recovery.
Your questions and concerns are important to us. Please feel free to discuss them with anyone on your health care team. We look forward to serving you.
Surgery Information
Your Surgeon: _______________________
Phone Number: _______________________
Marshall Medical Center ...... (530) 622-1441
PAT Nurse ........................................... (530) 626-2782
Pre-anesthesia Testing
Social Services ................................. (530) 626-2633
# TABLE OF CONTENTS
Your Hospital Stay ................................................................. 4
Before Surgery ........................................................................ 4
Preparing the Skin Before Surgery ................................. 5
Tips for a Safer Surgery ......................................................... 6
The Day of Surgery ............................................................... 6
Anesthesia Care ...................................................................... 7
The Operating Room ............................................................. 8
Post-operative Care .............................................................. 8
Incision & Dressing Care .................................................... 9
Going Home ........................................................................... 9
Marshall Medical Center Policy Statement .................. 10
Advance Directive Information ........................................ 10
Additional Resources .......................................................... 10
Some Useful Terms .............................................................. 11
Patient Rights ........................................................................ 12
Map & Directions ................................................................ 14
Notes & Reminders .............................................................. 15
YOUR HOSPITAL STAY
You and your doctor have decided that you need surgery. This may be a new experience for you. You are not alone — each year millions of people have surgery.
We provide the full range of services your surgery requires. Our staff of highly skilled professionals will care for your physical and emotional needs. Your health care team will perform the tests you need, follow your progress, and answer your questions.
Depending on your surgery, you will enter in as an:
- Inpatient
- Outpatient
Inpatients will spend at least one night in the hospital. They are admitted the day of surgery.
Outpatients will enter the hospital the day of surgery and leave the same day. Sometimes you may need to be admitted to the hospital for more treatment or observation. If you need to stay, your surgeon will discuss the reason with you.
BEFORE SURGERY
Pre-anesthesia Testing (PAT)
If you need lab work or other diagnostic tests before surgery, you will need to make a PAT appointment for a health screening, or one may have been made for you by your doctor. For some surgeries or procedures, the health screening may be handled by phone. Your pre-op visit will last approximately 30 minutes, depending on your procedure, personalized education plan and the tests your doctor requests. During your PAT visit you may:
- Fill out the hospital admission forms.
- Talk with a registered nurse to plan your hospital stay.
- Get lab work and other physician-ordered testing done.
- Find out where and when to arrive on the day of surgery.
- Plan for your care when you leave the hospital after surgery.
What to Bring to Your PAT Appointment
- Your health insurance card and photo ID.
- All of your prescription and over the counter medications in their original containers.
- Any paperwork your doctor may have asked you to bring to the hospital, such as physician’s orders, lab results, or x-rays.
- A copy of your completed “Advance Medical Directive”.
Your Role in Preparing for Surgery
Taking these simple steps can help to ensure a safe surgery and quick recovery. Check the steps below that you need to do before surgery.
- If you smoke, quit or at least cut down before surgery. People who don’t smoke heal faster than people who smoke.
- Stop drinking alcohol (liquor, beer and wine) at least 2 days before surgery.
- Consult your surgeon about stopping Aspirin and blood thinners (including ibuprofen) prior to surgery.
- If you get a fever, cold, or rash, call your doctor. Your surgery may need to be postponed.
- During your visit with your PAT nurse, you will be told when to stop eating and drinking, including gum, mints, candy, and using chewing tobacco.
- NOTHING to eat or drink (including water) after MIDNIGHT unless otherwise indicated by your doctor.
- Ask your doctor about taking your regular medications, including diabetes and blood thinning medications.
- Arrange for someone to pick you up from the hospital and stay with you for the first 12 hours after you go home.
- You will receive a call the next business day.
PREPARING THE SKIN BEFORE SURGERY
To reduce risk of infection at your surgical site; Marshall Hospital has chosen 2% Chlorhexidine Gluconate (CHG) antiseptic solution disposable wipes.
WARNINGS
- Do not use the CHG cloths if you are allergic to Chlorhexidine instead use a NEW container of liquid soap (non-fragrant, no other additives) for your shower.
- Stop using if redness or irritation occurs
- Avoid using wipes on your face & genital area. Dispose of wipes in trash, not toilet.
- Do not shave any part of your body (this may cause infection).
Two Nights Before Surgery: ____________
Before Bed:
- Take out all ear and body piercings before proceeding
- Shower, wash your hair and rinse thoroughly.
- Dry off with a clean towel.
- Allow your skin to dry for 15 minutes before applying the wipes.
- Take one wipe:
Starting at your neck, down to your hips, front and back.
Wipe skin back and forth for 3 minutes (do not scrub too hard—that may cause irritation).
Pay special attention to carefully cleaning your surgical site.
- With the second wipe:
Wipe starting at your hips, cleaning down to toes, front and back. Avoid genital area.
Wipe skin back and forth for 3 minutes (do not scrub too hard—that may cause irritation).
Pay special attention to carefully cleaning your surgical site.
- Allow your skin to air dry.
- Do not apply anything to your skin after prepping. (Lotion, moisturizer, deodorant, powder, or make-up, sunscreen.)
- Dress in clean sleepwear.
The Night Before Surgery: ____________
Before Bed:
- Repeat steps 1-9 (above).
- Dress in clean sleepwear and sleep on clean sheets.
The Day Of Surgery: ____________
Before Arriving at the Hospital:
- Shower, rinse and dry off with a clean towel. Dress in clean clothes.
- DO NOT apply lotion, moisturizer, deodorant, powder, face/body make-up or jewelry.
TIPS FOR A SAFER SURGERY
Avoiding Infection
- **Pre-op shower/bathe** with antibacterial cloths
- If your doctor determines you need antibiotics before surgery: They will be given within 60 minutes before surgery and should be stopped within 24 hours in most cases. Given properly, antibiotics can greatly lower your chances of getting an infection after surgery.
- **Do not shave the surgery area**. Using a razor to remove hair before surgery can cause infections because of the risk of leaving small cuts on the skin. Once in surgery, your doctor or nurse will use clippers to remove hair if needed at the site of your surgery.
Avoiding Blood Clots
- When you have surgery, you are at risk of getting blood clots because you do not move while under anesthesia. The more complicated your surgery, the higher your risk. Your doctor will know your risk for blood clots and steps that will prevent them, such as giving you the right medicine before surgery and using special stockings during and after your procedure.
Avoiding a Heart Attack
- Taking certain medicines together can cause problems. Tell your doctor about all the medicines you are taking, including heart disease medicine, and any over-the-counter drugs like aspirin and herbal remedies. Your doctor or nurse will tell you which medicines you should continue to take and which you should stop before surgery.
THE DAY OF SURGERY
It is important for your stomach to be empty at the time of your surgery. For your safety, please follow the instructions given to you by the PAT nurse. If you do not follow these guidelines, your surgery may be cancelled or rescheduled.
Scheduled procedure/surgery times can change due to cancellations or emergencies. Please provide a phone number, other than your home, where we may reach you the day of your procedure/surgery if we need you to come in earlier or inform you of delays.
Before You Arrive at the Hospital
- All body piercings must be removed before arrival at the hospital.
- Shower or bathe – do not apply lotion, oil, or powder.
- Do not shave the area of the body where you will have surgery.
- Remove contact lenses, hairpins, lipstick, and other makeup.
- Wear comfortable, loose clothing.
- Leave valuables, such as jewelry, watches, cash, and credit cards at home.
- Bring your eye drops and inhalers if you use these.
- Bring CPAP machine if you use one.
- Diabetic patients should follow their doctor’s instructions regarding medication.
- Patients on blood thinners should follow their doctor’s instructions regarding medications.
On the Day of Surgery
- Take medications as instructed with a small sip of water. Most heart, lung, and blood pressure medications are continued until the time of surgery, but ask if you are uncertain.
What to Bring With You
- A parent or legal guardian, if the patient is under 18.
- Robe and toiletries for overnight stays.
- This booklet.
Checking In
• You will fill out registration insurance forms and sign a surgery consent form if you haven’t done so already. If you are a minor, your parent or guardian will fill these out. Be sure to ask questions that you have about these forms.
• You will be taken to a surgery preparation area. Your family and friends may be able to wait there with you after preparation is complete.
• You will be asked to change into a hospital gown and wear an ID bracelet until you go home.
• If you wear glasses, hearing aids, or dentures, ask if you should wear them.
• If an overnight stay is expected, your personal belongings should be given to a relative or friend. For those having outpatient procedures, your personal belongings will be kept in the outpatient surgery locker.
ANESTHESIA CARE
Anesthesia is medication that keeps you comfortable during surgery. It is given by a highly trained specialist, either an anesthesiologist or a nurse anesthetist. You will meet with him or her before surgery to discuss what type of anesthesia is best for you. Let us know if you have had nausea or vomiting after previous surgery or if you get motion sickness. We can take steps to prevent this problem or treat it early.
Types of Anesthesia
There are three main types of anesthesia: general, regional or local, and monitored sedation. Depending on the type of anesthesia given, the anesthesiologist, nurse anesthetist, or registered nurse will watch your condition and provide medication as needed.
• **General Anesthesia.** With general anesthesia you are totally asleep and aware of nothing.
• **Regional or Local Anesthesia.** Regional or local anesthesia numbs certain areas of the body so you do not feel pain. You might also receive additional medications to relax you.
• **Monitored Sedation.** With monitored sedation, you are kept relaxed and comfortable. You may remain awake and aware throughout the surgery, or you may be drowsy or in a light sleep.
Notes to family and friends.
• The surgeon may speak to you when the patient has arrived in the recovery room.
• It’s OK to ask questions about the patient’s recovery.
PREOPERATIVE/OPERATING ROOM
Your Preoperative Experience
- An intravenous (IV) line will be started in an arm or hand vein in our pre-op area.
- A cuff will be placed on your arm to monitor your blood pressure during surgery.
- Pads placed on your chest will monitor your heart’s function.
- A clip placed on your finger will measure the oxygen level in your blood.
The operating room (OR) provides a safe and comfortable place for your surgery. You will be taken into the operating room on a gurney.
Your Surgical Team
Your surgeon leads the OR team. Other surgical team members usually include nurses, an anesthesiologist or nurse anesthetist, and a surgical assistant.
POST-OPERATIVE CARE
After surgery, you will be taken to a recovery room: the PACU (post anesthesia care unit), the ICU (intensive care unit), or you may return to the outpatient surgery area where you will be discharged. Wherever you recover, you will be closely monitored as the anesthesia wears off.
- You will have some discomfort during your recovery. You will be given medications and other treatment to assist with your pain. Notify your nurse when you start to feel pain or discomfort. Do not wait until you are in severe pain to ask for medications because it takes time for the medications to work. You will be asked to rate your pain on a scale of 0-10 (0 being no pain and 10 being the worst pain you have ever had).
NO pain after surgery is an unrealistic expectation. You and your nurse will work to achieve a reasonable pain goal after surgery. Multiple approaches may be considered in treating post op pain. You and your nurse may discuss: Ice, heat, compression, massage, elevation, music, along with medications to treat pain.
Severe pain and or anxiety may cause extreme discomfort that:
- Prevents sleep
- Makes it hard to cough and take deep breaths
- Cause your heart to beat fast
- Increase the risk of constipation and bloating
- Decrease wound healing
- May result in depression and a feeling of helplessness
- If you are being admitted, you might have patient-controlled analgesia (PCA), which allows you to control your own pain medication or an epidural.
- Please notify your nurse if you have nausea or vomiting after surgery. We will give you medications to help you feel better.
- You might have a mild sore throat if an airway tube was placed in your windpipe during surgery to help you breathe. Throat lozenges commonly help with this.
- You may wake up with a small tube (catheter) in your bladder to drain urine. This is usually temporary.
Your Role in Recovery
You should become more active as soon as the doctor says it is all right. Rest when you feel tired. To speed recovery, you will be asked to breathe deeply, cough, possibly use an incentive spirometer, and do some simple exercises. Be sure to follow your post-op instructions.
- Deep breathing, coughing, and using an incentive spirometer (IS), a breathing tool, can help clear your lungs, aid circulation, and can also help prevent pneumonia. Depending on your surgery, you may try holding a pillow over the incision for support. A respiratory
therapist will instruct you on the importance of the incentive spirometer and how to use it.
- **Range-of-motion exercises and moving your legs** while you are in bed will help your circulation and help prevent serious complications.
- **Walking** will help your circulation as well as help your body functions return to normal. You will be assisted the first time you walk.
- **Healthy eating** can help speed your recovery. If you are in the hospital, you may have an IV. Your diet will be advanced slowly from liquids to solids. If you are recovering at home, start by eating small amounts of easy-to-digest foods. If you are given a special diet, be sure to follow it.
- **Managing your pain** can actually speed up your recovery. If your pain is not relieved, or gets worse, notify your doctor. Most oral pain medications take 20 minutes to take effect; do not wait until the pain gets severe to take them.
- **Constipation** is a common side effect with some pain medications. Eating fruits and vegetables can help, as well as drinking extra fluids, unless you are instructed not to. Check with your doctor about stool softeners and laxatives.
- **Nozins** will be used two times per day (am/pm) for 4 days following surgery. They will be given to you upon discharge with instructions.
**INCISION AND DRESSING CARE**
When you go home, you may have a dressing over your incision. You will be shown how to care for your incision and the dressing. Do the following things to help your incision heal quickly.
- Keep the incision clean and dry. You will be told when it is safe to shower.
- If the incision is on your leg, arm or head, you may be told to keep it elevated.
- Wash your hands before and after touching the incision area. This helps prevent infection.
- If you have a drainage tube, follow your written instructions.
- It’s normal to run a slight fever and for the incision to be slightly pink and swollen the day after surgery.
**Call Your Surgeon If:**
- You have a fever over 100° F (37.5° C).
- Your incision becomes more red, swollen, or painful, or has a foul discharge.
- Your incision bleeds a lot or opens.
- You feel too sleepy, dizzy, or groggy. (The medication may be too strong.)
- You have side effects from your medications such as nausea, vomiting, redness, rash, or itching.
- Your pain is uncontrolled by current pain medication.
- You are unable to urinate after eight hours.
**GOING HOME**
**Discharge**
Your doctor will tell you when you will be discharged. Ask a friend or family member to help you during your recovery. Both of you should listen to your post-op instructions. Be sure that you both understand the instruction and that your questions are answered.
**Notes to family and friends.**
Your care and concerns can help speed recovery. Ask the patient and nurse what you can do. Here are some suggestions:
- Learn all you can about the patient’s health problem and surgery.
- Offer to run errands such as grocery shopping.
- Help with cooking, laundry and other household chores.
You will be given a written copy of these instructions to take home with you.
You will be given a list of medications and instructions about how to take them once you go home.
**Be Sure to Ask About:**
- Stitches, staples and incisions care.
- When to resume medications.
- Bathing and showering.
- Pain (what to expect, what to do).
- What to eat.
- Physical activity.
- Resuming sexual relations.
- Driving.
**Visiting Hours**
Visiting Hours are from 12pm to 8pm daily.
**MARSHALL MEDICAL CENTER POLICY STATEMENT**
**Marshall Hospital Outpatient Surgery**
We want to provide you with the very best care. We would like you to know that in an outpatient setting, even if you have an Advance Directive for Healthcare, we will provide immediate medical treatment if you have an emergency medical condition.
**ADVANCE DIRECTIVE INFORMATION**
The following websites are helpful in understanding and completing an Advance Directive or a POLST (Physician Order for Life Sustaining Treatment):
- www.marshallmedical.org
- www.nlm.nih.gov/medlineplus/advancedirectives/html
- www.capolst.org
Advance Directive forms are also available in the Admitting Department at the entry of the hospital.
**ADDITIONAL RESOURCES**
**For information on preparing for surgery:**
www.ahrq.gov/consumer/surgery/surgery.htm
This site offers additional questions to ask your physician and surgeon about your surgery.
**For information on quality of hospital care, visit Hospital Compare at:**
www.hospitalcompare.hhs.gov
This site includes information on how often hospitals provide some of the recommended care to get the best results for most patients.
**For information on the Joint Commission’s Speak Up™ Program:**
www.jointcommission.org/patientsafety/speakup
This site includes safety tips for surgical patients and infection prevention.
**For patient information concerning anesthesia:**
www.asahq.org/patienteducation.htm
**For more information regarding surgery, visit the American College of Surgeons:**
www.facs.org/public_info/ppserv.html
**If you do not have access to a computer:**
The Community Health Library Staff are available for assistance. They are located at:
3581 Palmer Drive
Suite 101
Cameron Park, CA
530-626-2778
**To sign up for MyChart, visit:**
Marshallmedical.org/mychart
SOME USEFUL TERMS
**Advance Medical Directive**
A formal document stating your choices for healthcare, or naming someone to make those choices if you cannot.
**Anesthesia**
Medication to prevent pain during surgery and medical procedures. There are three different types: general, regional or local, and monitored sedation.
**Anesthesiologist**
A doctor who specializes in administering anesthesia medications.
**Drainage Tube**
A tube that has been temporarily inserted at the incision site to drain excess fluid.
**ECG or EKG**
Electrocardiogram. A test that gives information about how the heart is working.
**Epidural**
Medication is delivered through a catheter – a very thin, flexible, hollow tube – that’s inserted into the epidural space just outside the membrane that surrounds your spinal cord and spinal fluid.
**Health Care Provider**
A doctor, nurse, or other trained medical person.
**ICU**
Intensive care unit. Section of the hospital that is equipped for patients who need constant, close monitoring.
**Incentive Spirometer (IS)**
A very important tool for you to use to keep your lungs clear, strengthen your breathing muscles, and help prevent postoperative complications such as pneumonia.
**Inpatient**
A patient who will spend at least one night in the hospital. Inpatients are admitted to the hospital the day of surgery.
**Intravenous or IV Line**
A thin tube that delivers medications, fluids, or blood directly into a vein.
**OR**
Operating room. The room where surgery is performed.
**Outpatient**
A patient admitted and discharged the day of surgery.
**PACU**
Post-anesthesia care unit. The recovery room where patients may stay until their anesthesia wears off.
**PAT**
Pre-anesthesia testing. A screening done to identify possible risks before surgery. It includes an interview with a PAT nurse (to review allergies, medications, medical history), blood test, xray, and an EKG.
**PCA**
Patient-controlled analgesia. A pain relief method in which the patient pushes a button to get pain medication through an IV line.
**Pneumonia**
A serious lung disease that sometimes occurs after surgery. Deep breathing and coughing can help prevent it.
**Surgery Consent**
A legal form the patient signs before surgery, after discussing the risks and benefits of surgery with the doctor.
PATIENT RIGHTS
1. Considerate and respectful care, and to be made comfortable. You have the right to respect for your cultural, psychosocial, spiritual, and personal values, beliefs and preferences.
2. Have a family member (or other representative of your choosing) and your own physician notified promptly of your admission to the hospital.
3. Know the name of the licensed health care practitioner acting within the scope of his or her professional licensure who has primary responsibility for coordinating your care, and the names and professional relationships of physicians and nonphysicians who will see you.
4. Receive information about your health status, diagnosis, prognosis, course of treatment, prospects for recovery and outcomes of care (including unanticipated outcomes) in terms you can understand. You have the right to effective communication and to participate in the development and implementation of your plan of care. You have the right to participate in ethical questions that arise in the course of your care, including issues of conflict resolution, withholding resuscitative services, and forgoing or withdrawing life-sustaining treatment.
5. Make decisions regarding medical care, and receive as much information about any proposed treatment or procedure as you may need in order to give informed consent or to refuse a course of treatment. Except in emergencies, this information shall include a description of the procedure or treatment, the medically significant risks involved, alternate courses of treatment or nontreatment and the risks involved in each, and the name of the person who will carry out the procedure or treatment.
6. Request or refuse treatment, to the extent permitted by law. However, you do not have the right to demand inappropriate or medically unnecessary treatment or services. You have the right to leave the hospital even against the advice of members of the medical staff, to the extent permitted by law.
7. Be advised if the hospital/licensed health care practitioner acting within the scope of his or her professional licensure proposes to engage in or perform human experimentation affecting your care or treatment. You have the right to refuse to participate in such research projects.
8. Reasonable responses to any reasonable requests made for service.
9. Appropriate assessment and management of your pain, information about pain, pain relief measures and to participate in pain management decisions. You may request or reject the use of any or all modalities to relieve pain, including opiate medication, if you suffer from severe chronic intractable pain. The doctor may refuse to prescribe the opiate medication, but if so, must inform you that there are physicians who specialize in the treatment of pain with methods that include the use of opiates.
10. Formulate advance directives. This includes designating a decision maker if you become incapable of understanding a proposed treatment or become unable to communicate your wishes regarding care. Hospital staff and practitioners who provide care in the hospital shall comply with these directives. All patients’ rights apply to the person who has legal responsibility to make decisions regarding medical care on your behalf.
11. Have personal privacy respected. Case discussion, consultation, examination and treatment are confidential and should be conducted discreetly. You have the right to be told the reason for the presence of any individual. You have the right to have visitors leave prior to an examination and when treatment issues are being discussed. Privacy curtains will be used in semi-private rooms.
12. Confidential treatment of all communications and records pertaining to your care and stay in the hospital. You will receive a separate “Notice of Privacy Practices” that explains your privacy rights in detail and how we may use and disclose your protected health information.
13. Receive care in a safe setting, free from mental, physical, sexual or verbal abuse and neglect, exploitation or harassment. You have the right to access protective and advocacy services including notifying government agencies of neglect or abuse.
14. Be free from restraints and seclusion of any form used as a means of coercion, discipline, convenience or retaliation by staff.
15. Reasonable continuity of care and to know in advance the time and location of appointments as well as the identity of the persons providing the care.
16. Be informed by the physician, or a delegate of the physician, of continuing health care requirements and options following discharge from the hospital. You have the right to be involved in the development and implementation of your discharge plan. Upon your request, a friend or family member may be provided this information also.
17. Know which hospital rules and policies apply to your conduct while a patient.
PATIENT RIGHTS
18. Designate a support person as well as visitors of your choosing, if you have decision-making capacity, whether or not the visitor is related by blood, marriage, or registered domestic partner status, unless:
- No visitors are allowed.
- The facility reasonably determines that the presence of a particular visitor would endanger the health or safety of a patient, a member of the health facility staff, or other visitor to the health facility, or would significantly disrupt the operations of the facility.
- You have told the health facility staff that you no longer want a particular person to visit.
However, a health facility may establish reasonable restrictions upon visitation, including restrictions upon the hours of visitation and number of visitors. The health facility must inform you (or your support person, where appropriate) of your visitation rights, including any clinical restrictions or limitations. The health facility is not permitted to restrict, limit, or otherwise deny visitation privileges on the basis of race, color, national origin, religion, sex, gender identity, sexual orientation, or disability.
19. Have your wishes considered, if you lack decision-making capacity, for the purposes of determining who may visit. The method of that consideration will comply with federal law and be disclosed in the hospital policy on visitation. At a minimum, the hospital shall include any persons living in your household and any support person pursuant to federal law.
20. Examine and receive an explanation of the hospital’s bill regardless of the source of payment.
21. Exercise these rights without regard to sex, economic status, educational background, race, color, religion, ancestry, national origin, sexual orientation, gender identity/expression, disability, medical condition, marital status, age, registered domestic partner status, genetic information, citizenship, primary language, immigration status (except as required by federal law) or the source of payment for care. If you believe that these rights have been denied to you, you may file a grievance with this hospital or you can file a grievance with the Office for Civil Rights, by writing or calling:
U.S. Department of Health & Human Services
Office for Civil Rights – Region IX
90 7th Street, Suite 4-10
San Francisco, CA 94103
(800) 368-1019
(800) 537-7697 TDD
22. File a grievance. If you want to file a grievance with this hospital, you may do so by writing or by calling:
Marshall Medical Center Patient Advocate
1100 Marshall Way
Placerville, CA 95667
(530) 344-5428
The grievance committee will review each grievance and provide you with a written response within 30 days. The written response will contain the name of a person to contact at the hospital, the steps taken to investigate the grievance, the results of the grievance process, and the date of completion of the grievance process. Concerns regarding quality of care or premature discharge will also be referred to the appropriate Utilization and Quality Control Peer Review Organization (PRO).
23. File a complaint with the California Department of Public Health regardless of whether you use the hospital’s grievance process. The California Department of Public Health’s phone number and address is:
California Department of Public Health
Licensing and Certification
3901 Lennane Drive, Suite 210
Sacramento, CA 95815
(916) 263-5800
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BIN1 is a key regulator of proinflammatory and neurodegeneration-related activation in microglia
Ari Sudwarts\textsuperscript{1,2}, Supriya Ramesha\textsuperscript{3}, Tianwen Gao\textsuperscript{3}, Moorthi Ponnusamy\textsuperscript{1,2}, Shuai Wang\textsuperscript{1,2}, Mitchell Hansen\textsuperscript{1,2}, Alena Kozlova\textsuperscript{4}, Sara Bitarafan\textsuperscript{5}, Prateek Kumar\textsuperscript{3}, David Beaulieu-Abdelahad\textsuperscript{1,2}, Xiaolin Zhang\textsuperscript{1,2}, Lisa Collier\textsuperscript{1,2}, Charles Szekeres\textsuperscript{2}, Levi B. Wood\textsuperscript{5}, Jubao Duan\textsuperscript{4,6}, Gopal Thinakaran\textsuperscript{1,2*} and Srikant Rangaraju\textsuperscript{3*}
Abstract
**Background:** The \textit{BIN1} locus contains the second-most significant genetic risk factor for late-onset Alzheimer’s disease. \textit{BIN1} undergoes alternate splicing to generate tissue- and cell-type-specific BIN1 isoforms, which regulate membrane dynamics in a range of crucial cellular processes. Whilst the expression of BIN1 in the brain has been characterized in neurons and oligodendrocytes in detail, information regarding microglial BIN1 expression is mainly limited to large-scale transcriptomic and proteomic data. Notably, BIN1 protein expression and its functional roles in microglia, a cell type most relevant to Alzheimer’s disease, have not been examined in depth.
**Methods:** Microglial BIN1 expression was analyzed by immunostaining mouse and human brain, as well as by immunoblot and RT-PCR assays of isolated microglia or human iPSC-derived microglial cells. \textit{Bin1} expression was ablated by siRNA knockdown in primary microglial cultures in vitro and Cre-lox mediated conditional deletion in adult mouse brain microglia in vivo. Regulation of neuroinflammatory microglial signatures by BIN1 in vitro and in vivo was characterized using NanoString gene panels and flow cytometry methods. The transcriptome data was explored by in silico pathway analysis and validated by complementary molecular approaches.
**Results:** Here, we characterized microglial BIN1 expression in vitro and in vivo and ascertained microglia expressed BIN1 isoforms. By silencing \textit{Bin1} expression in primary microglial cultures, we demonstrate that BIN1 regulates the activation of proinflammatory and disease-associated responses in microglia as measured by gene expression and cytokine production. Our transcriptomic profiling revealed key homeostatic and lipopolysaccharide (LPS)-induced inflammatory response pathways, as well as transcription factors PU.1 and IRF1 that are regulated by BIN1. Microglia-specific \textit{Bin1} conditional knockout in vivo revealed novel roles of BIN1 in regulating the expression of disease-associated genes while counteracting CX3CR1 signaling. The consensus from in vitro and in vivo findings showed that loss of \textit{Bin1} impaired the ability of microglia to mount type 1 interferon responses to proinflammatory challenge, particularly the upregulation of a critical type 1 immune response gene, \textit{Ifitm3}.
**Conclusions:** Our convergent findings provide novel insights into microglial BIN1 function and demonstrate an essential role of microglial BIN1 in regulating brain inflammatory response and microglial phenotypic changes.
*Correspondence: firstname.lastname@example.org; email@example.com
\textsuperscript{1} Byrd Alzheimer’s Center and Research Institute, University of South Florida, Tampa, FL 33613, USA
\textsuperscript{3} Department of Neurology, Emory University, Atlanta, GA 30322, USA
Full list of author information is available at the end of the article
Moreover, for the first time, our study shows a regulatory relationship between *Bin1* and *Ifitm3*, two Alzheimer’s disease-related genes in microglia. The requirement for BIN1 to regulate *Ifitm3* upregulation during inflammation has important implications for inflammatory responses during the pathogenesis and progression of many neurodegenerative diseases.
**Keywords:** BIN1, Alzheimer’s disease, Neuroinflammation, Microglia, Innate immunity, GWAS risk factor, LPS, IRF1, IRF7, PU.1, IFITM3, CX3CR1
**Graphical Abstract**
**Background**
Bridging Integrator 1 (*BIN1*) is a significant genetic risk factor locus for late-onset Alzheimer’s disease (LOAD) identified by genome-wide association studies [1–3]. Tissue- and cell-type-specific alternate splicing of seven out of the twenty *BIN1* exons generates multiple BIN1 isoforms, which vary in functional domains and differ in their subcellular localization [4]. BIN1 isoforms participate in a range of functions, including membrane remodeling, endocytosis, cytoskeleton regulation, and cell cycle [4]. Neuronal BIN1 localizes to presynaptic terminals in the mouse brain and plays an indispensable role in excitatory neurotransmission by regulating synaptic vesicle dynamics [5]. A central Clathrin-Associated Protein binding region (CLAP domain), present only in neuronal isoforms, confers BIN1’s ability to interact with the endocytic protein clathrin and its adaptor protein AP-2 [6]. Despite the importance of the endosomal pathway in β-amyloid production, the loss of neuronal BIN1 expression does not modulate β-amyloid pathology in a mouse model of Alzheimer’s disease (AD) amyloidosis [7]. Additionally, BIN1 can bind to tau and BIN1 overexpression induces tau-dependent network hyperexcitability in cultured neurons [8, 9], indicating that BIN1 may promote AD risk through tau pathogenesis. BIN1 has also been shown to limit the inter-neuronal spread of pathogenic tau in cultured neurons [10]. Moreover, independent studies have reported a significant decrease in neuronal BIN1 expression in individuals with AD [11, 12]. These latter findings are at odds with the suggestion that an increase in BIN1 expression contributes to tangle pathology. One possible explanation for this seeming
inconsistency may be drawn from the observations that reduction in the neuronal isoform (iso 1) coincides with an increase in the ubiquitous isoform (iso 9) [11, 13].
In the CNS, ubiquitous BIN1 isoforms lacking the CLAP domain are expressed in neurons and non-neuronal cells, most prominently in oligodendrocytes within human brain white matter [11, 14, 15]. Interestingly, high-level *Bin1* transcript and protein expression have been reported in large-scale datasets of acutely isolated mouse and human brain microglia (Fig. S1) [16–18]. Moreover, in wild-type mice and mouse models of AD pathology, *Bin1* was in the top 20th percentile of abundant microglial proteins as assayed by quantitative mass spectrometry [19–21]. Still, it was found to be lower in abundance in phagocytic microglia isolated from mouse brain injected with apoptotic neurons [22], consistent with a potential homeostatic role of BIN1.
In human brain proteomic studies, Multi-marker Analysis of GenoMic Annotation (MAGMA) highlighted that protein co-expression modules enriched in microglia markers were also enriched in AD risk genes, implicating microglial dysfunction in LOAD pathogenesis [23]. Microglia are resident immune cells in the CNS with critical roles in brain development and function, including synapse pruning, neurogenesis, and immune surveillance of the brain [24]. Additionally, microglia play vital and complex disease-modifying roles in neuroinflammatory and neurodegenerative disorders, including AD, and transform from homeostatic states to disease-associated microglia (DAM) phenotypes through an immune checkpoint regulated by TREM2 [22, 25]. A recent network analysis of mouse microglial transcriptomic datasets also revealed heterogeneity within DAM phenotypes, namely proinflammatory and anti-inflammatory DAM sub-profiles [26]. In this framework of homeostatic microglia, pro- and anti-inflammatory DAM in AD, we found that *Bin1* has the highest module membership among AD-associated genes in a homeostatic gene module, raising the possibility that BIN1 may play functional and AD-relevant roles in microglia [21].
Phagocytosis and proliferation are hallmark microglial responses to AD-like pathologies [27, 28]. Despite the potential for BIN1 to regulate crucial cellular pathways and microglial functions under homeostatic and pathological conditions, studies to date have largely neglected to characterize microglial BIN1 expression. Seemingly, this oversight stems from unsuccessful efforts in previous investigations to visualize BIN1 immunoreactivity in microglia in an unambiguous manner. In this regard, high-level BIN1 expression in oligodendrocytes, myelin, and synapses results in the labeling of diverse cell populations; thus, slender BIN1-positive processes that densely overlap with each other are tightly packed throughout the depth of the histological sections [5, 11, 15]. BIN1 immunoreactivity in the relatively small microglial cells is therefore obscured by the more intense staining of oligodendrocyte and neuronal processes, posing technical challenges for a clear demonstration of microglial BIN1 protein expression *in situ*.
In light of myriad findings of microglial dysfunction and DAM transformation in AD pathogenesis [29, 30], it is critical to investigate microglial BIN1 expression and function. The present article achieves the first-layer analysis by documenting microglial BIN1 protein in the mouse brain and characterizing microglial BIN1 isoforms. Subsequently, we explored the functional role of BIN1 by silencing *Bin1* expression in primary mouse microglia and conditional knockout mice (cKO) via selective ablation of *Bin1* alleles in microglia. Utilizing neuroinflammatory transcriptomic profiling, we have identified BIN1 as a homeostatic microglial regulator that has a non-redundant role in the activation of proinflammatory responses upstream of *Apoe*, *Trem2*, and *Tyrobp*, and upstream of PU.1 and IRF1, both master regulators of microglial gene expression and transition to DAM [31, 32]. Loss of *Bin1* in vitro profoundly impaired microglial ability to respond to LPS, resulting in a blunted proinflammatory response as measured by cytokine production and gene expression. In vivo, loss of microglial *Bin1* in the systemic LPS-induced neuroinflammatory model also blunted proinflammatory gene expression changes in addition to diminishing the upregulation of several DAM genes. Consistent across *in vitro* and *in vivo Bin1* manipulation studies, BIN1 was predicted to regulate type 1 interferon response in microglia. Importantly, BIN1 was found to regulate inflammation-induced expression of *Ifitm3*, an interferon-response gene recently associated with AD-related mechanisms [33]. IFITM3 facilitates lysosome acidification [34, 35] and limits immune-response cytokine production [36, 37]. Notably, IFITM3 gene networks are enriched in brains and peripheral blood mononuclear cells of AD patients [38], suggesting that IFITM3 plays a role in microglial inflammatory responses to AD pathology. Collectively, these findings provide important insights into BIN1 expression and function in microglia, demonstrating the significance of microglial BIN1 expression in brain inflammatory response.
**Methods**
**Animals, drug administration, and harvest**
All experiments involving animals were conducted in accordance with the IACUC guidelines at the University of South Florida. *Bin1*<sup>fl/fl</sup> strain was obtained from Dr. George C. Prendergast (Lankenau Institute for Medical Research) [39]. *Emx1*-IRES-Cre (JAX stock #005628) and *Cx3cr1*<sup>tm2.1(cre/ERT2)Litt/WganJ</sup> (JAX stock 021160;
heterozygous mice are referred to as *Cx3cr1*<sup>CreER</sup>) lines were purchased from The Jackson Laboratory (Bar Harbor, ME). *Bin1*<sup>fl/fl</sup> mice were crossed with *Emx1*-IRES-Cre or *Cx3cr1*<sup>CreER</sup> animals to generate *Emx1*<sup>Cre</sup>*-Bin1*<sup>fl/fl</sup> (*Emx*<sup>Cre</sup>*-Bin1* cKO) and *Cx3cr1*<sup>CreER</sup>*-Bin1*<sup>fl/fl</sup> (*Cx3cr1*<sup>CreER</sup>*-Bin1* cKO) animals [5]. The mice were maintained on a C57BL/6/J background.
Tamoxifen (10 mg/mL, prepared in a 10% ethanol and 90% sunflower seed oil solution by vortexing and sonication) was administered through intraperitoneal injections (100 mg/kg) on 5 consecutive days. Mice were then rested for 4 weeks to allow the re-population of peripheral monocytes. Subsequently, LPS (dissolved in sterile saline at 250 μg/mL and filtered through a 0.22 μm syringe filter) was injected (750 μg/kg) on four consecutive days. The animals were sacrificed 24 h after the final injection. Mice were weighed prior to each LPS injection and monitored for sickness and weight loss. All animals were terminally anaesthetised with isoflurane overdose and perfused with ice-cold PBS. Brain tissue was dissected out and divided for microglial isolation and immunostaining.
**Immunofluorescence staining and imaging**
Brain tissue was post-fixed at 4 °C for 24 h in PBS containing 4% paraformaldehyde and processed for paraffin embedding. Five μm-thick sections were deparaffinised in xylene, hydrated through an ethanol series, and subjected to antigen retrieval at 90 °C (in 10 mM sodium citrate containing 0.05% Tween 20, pH6). After washing and permeabilization in 0.25% Triton X-100, non-specific binding sites were blocked by incubation at room temperature for 1 hour in a buffer containing 10% donkey serum, 3% BSA, and 0.1% Triton X-100 in TBS. The antibodies used for immunostaining are listed in Supplementary Table 5. Primary antibodies were diluted in 1% BSA (in TBS + 0.1% Triton X-100), added to slides, and incubated overnight at 4 °C. After washing, fluorescence-labeled secondary antibodies were added to slides and incubated for 2 h at room temperature. Alternatively, immunostaining was processed on an IntelliPATH FLX automated staining system (Biocare Medical) following epitope retrieval and blocking non-specific binding sites according to the manufacturer’s instructions. The slides were sequentially incubated with each primary and secondary antibody for 1 h at room temperature. Sections were washed and dried at room temperature prior to mounting coverslips with VectorShield mounting medium. Images were acquired on an automated Nikon Eclipse Ti2 microscope fitted with the Yokogawa spinning disk field scanning confocal system and Photometrics PRIME 95B sCMOS camera, using 20X and 100X objectives. High magnification z-stack images were deconvolved in NIS-Elements software (Nikon), processed using Fiji/ImageJ, and converted into 2D projections by smooth manifold extraction plug-in [40].
**Fluorescence-activated microglial cell sorting**
Mouse brain microglia were isolated by flow cytometry, as previously described [41]. Briefly, harvested brain tissue was minced on ice and passed through a 40 μm nylon cell strainer with ice-cold filtered PBS. The dispersed cell suspension was centrifuged at 800 x g, at 4 °C, for 5 mins, and pellet suspended in 35% isotonic Percoll solution containing 1x HBSS. Myelin was separated by centrifugation (800 x g, at 15 °C, for 25 mins) and removed from the top of the cell suspension. The Percoll solution was diluted > 10-fold in ice-cold PBS and centrifuged at 800 x g, at 4 °C, for 5 mins. The microglial cell pellet was resuspended in 300 μl ice-cold PBS. Dead cells were labeled with 7-aminoactinomycin D [1:1000] in PBS at room temperature for 30 mins. Cells were then labeled with APC-Cy7 rat α-CD11b[M1/70] (BD Pharmingen 557,657), PE-Cy7 rat α-mouse CD45[30-F11] (BD Pharmingen 552,848), and BV421 Armenian hamster α-CD11c[N418] (BD Horizon 565,452) [all diluted 1:100] in PBS for 30 mins, then washed twice with PBS. Flow cytometry was performed on a BD FACS Melody cell sorter. Live cells were gated by 7-aminoactinomycin D-negative staining. Mononuclear cells were gated by FSC-A/SSC-A and single cells by FSC-A/FSC-H. Microglial cells were isolated as CD11b<sup>+</sup> and CD45<sup>int</sup> population and collected in PBS and centrifuged at 1000 x g for 2 mins to sediment the cells. Cell pellets used for immunoblot analysis were snap-frozen on dry ice and stored at −80 °C until further processing. Cell pellets used for NanoString analysis were immediately lysed in RLT buffer (Qiagen), snap-frozen on dry ice, and stored at −80 °C.
**Primary neonatal microglia isolation**
Primary mouse microglial cultures were established using established isolation and enrichment protocols [42, 43]. As described previously [31], C57BL/6J mice (P0-3) were euthanized, and brains were dissected then digested with Trypsin for 15 min at 37 °C. After quenching the Trypsin with 20 ml DMEM (Dulbecco’s Modified Eagle Medium)/10% fetal bovine serum (FBS) and 1% penicillin-streptomycin-glutamine, the cellular pellet was washed, and myelin debris was removed. The remaining cell suspension was filtered through a 40 μm strainer followed by CD11b<sup>+</sup> positive selection using the mini-MACS (Miltenyi Biotec Cat#130-042-201) column. CD11b<sup>+</sup> enrichment resulted in >90%
pure CD11b\(^+\) microglia as previously validated by flow cytometry [42]. Cells were then seeded in poly-L-lysine-coated wells and cultured in DMEM. After 24h, the medium was replaced with a fresh medium, after which cells were used for experimentation.
**Human iPSC-derived microglia-like cells**
The generation of human iPSC lines from human blood cells and their characterization have been previously described [44, 45]. Human iPSCs were differentiated into primitive macrophage precursors and then to microglia (iMG) essentially as described [44, 46]. Final differentiation of primitive macrophage precursors into iMG occurred over 10 days, and cells were maintained in culture for at least 1 month before harvesting for immunoblot and RT-PCR analyses.
**Generation of Bin1 KO BV2 pools**
BV2 cells were cultured in DMEM supplemented with 10% fetal bovine serum, 4mM-L-glutamine, 100U/ml penicillin, and 100µg/ml streptomycin, at 37°C and 5% CO\(_2\). Cells were transduced with lentiviruses generated using pLentiCRISPRv2 plasmids (Genscript) expressing *Bin1* sgRNA (GAAGGATCTTCGGACCTATC) or non-target sgRNA. Stably transduced pools were selected in puromycin, and *Bin1* deletion was assessed by PCR amplification across the gRNA target site (F-primer: ACT GAGTGGTGCGCTGACAAG; R-primer: TGAGTGCCA GAGAATCAGCG) and sequencing. PCR products were also cloned into pGEM-T Easy (Promega), and four individual clones from each pool were sequenced to confirm deletions within the target region. WT and KO pools grown to 60 -70% confluency were serum-starved for 16h and treated with LPS (0.5µg/mL) for a further 16h before harvesting for RNA isolation or lysate preparation.
**Bin1 small interfering RNA (siRNA) transfection study**
*Bin1* was silenced with *Bin1* siRNA (sc-29,805 Santa Cruz Biotechnology), and equal amounts of non-specific sham siRNA (sc-37,007) were used for control. Primary microglia were transfected with 40nM (final concentration) of siRNA using Lipofectamine™ RNAiMAX (Invitrogen) and Opti-MEM (Invitrogen). After 48h, the efficiency of siRNA-mediated gene silencing was confirmed by qRT-PCR. LPS (10ng/ml or 100ng/ml, Sigma-Aldrich Cat#L4391, *E. coli* O111:B4) was added after 24h of siRNA exposure to activate microglia. The cells were collected after 24h of activation for qRT-PCR, NanoString, and phagocytosis studies, while supernatants were collected for cytokine assays. The viability of *Bin1* siRNA-treated cells was measured by flow cytometric assay by LIVE/DEAD Dye staining (Invitrogen) with heat-treated cells as a positive control.
**Immunoblot**
Protein was extracted from whole-brain samples by homogenizing in lysis buffer (150 mM NaCl, 50 mM Tris-HCl, 0.5% NP-40, 0.5% SDS) supplemented with 1x Roche cComplete protease inhibitors, 250µM PMSF. DNA was sheared by sonication using a probe sonicator. Protein was extracted from microglia isolated by flow cytometry and cultured human iMG by trituration in lysis buffer. Aliquots of protein samples were electrophoresed through 4-20% Bis-Tris gels, and blots were probed with rabbit anti-BIN1 (Proteintech 14,647-1-AP, 1:1000) and mouse anti-β-actin (Proteintech 66,009-1-Ig, 1:50,000) antibodies. The blots were developed with IR680- and IR800-conjugated secondary antibodies and imaged with the Odyssey Infrared Imaging System (Li-COR Biosciences).
**RT-PCR and isoform quantification**
RNA was extracted from tissue and cells using the DirectZol kit (Zymo), per the manufacturer’s instructions. RNA was reverse transcribed using Superscript IV (Invitrogen), and PCRs were performed using Phusion polymerase (NEB). The PCR primers were designed to span exon 7 (6-F: GGATGAAGCCAAAATTGCCAA; 10-R: CATCATTGAGGTTCTGATTGAGC), the CLAP domain and exon 17 (12-F: AF690_CATCCCCAAGTCCCACATC; 19-R: AATACCAACAACACACATCGC), or exon 11 (10-F: TCAATGTATGTCCCTGGTCAGC; 12-R: GCTCATGGTTTCACTCTGATC). Primers were also designed to amplify across the human exon 11 sequence (Hu_exon 10-F: AGAACCTCAATGATGTGCTGG; Hu_exon 12-R: TCGTGGTITGACTCTGATCTCGG). Amplified DNA fragments were electrophoresed through 7.5% acrylamide gels. The gels were stained using SYTO™ 60 dye (Invitrogen) and visualized on an infrared Odyssey scanner (LICOR). PCR products amplified using Alexa flour 690-modified forward primer were scanned without staining to allow semi-quantification of DNA based on fluorescence intensity relative to the molecular load.
For isoform frequency calculation, FACS-isolated microglial cDNA was used for PCR amplification using primers 12-F and 19-R. The products were purified and cloned in pGEM-T Easy vector (Promega) and transformed into JM109 cells. DNA isolated from individual colonies was re-amplified by PCR and electrophoresed through 5% acrylamide TBE gels to distinguish splicing by the insert length. All larger inserts and a selection of the most frequent (and readily distinguishable, smallest) inserts were analyzed by sequencing to identify the four isoforms expressed in mouse brain microglia (Fig. S2B). The relative frequency of clones corresponding to each
of the four isoforms was calculated, and the data are presented in Fig. 1H.
**Quantitative reverse transcriptase PCR (qRT-PCR)**
RNA extraction and cDNA synthesis were performed as described previously [47]. Quantitative real-time PCR was performed on 7500 Fast Real-time PCR System using TaqMan PCR master mix (Applied Biosystems). The following gene-specific TaqMan probes were used: *Trem2* (Mm04209424_g1), *Apoe* (Mm01307193_g1), *Tyrobp* (Mm00449152_m1), *Spp1* (Mm00436767_m1), *Gm1* (Mm00433848_m1), *Lamp1* (Mm00495262_m1), *Bin1* (Mm00437457_m1), and *Gapdh* (Mm99999915_g1). Each sample was analyzed in duplicates, and the relative gene expression analysis was calculated using the $2^{-\Delta \Delta Ct}$ method compared to the housekeeping gene *Gapdh* [31]. Alternatively, RNA extraction and cDNA synthesis were conducted in the same manner described for RT-PCR. qRT-PCR was then conducted using a QuantStudio™3 Real-Time PCR System (Applied Biosystems). Samples were amplified using technical triplicates (using primer sequences listed in Supplementary Table 6). Relative gene expression analysis was calculated using the $2^{-\Delta \Delta Ct}$ method, normalised to *Cotl1*.
**Quantitative NanoString neuroinflammatory gene expression and data analysis**
Microglia were exposed to siRNAs against *Bin1* for 24 h, followed by LPS treatment (10 ng/ml) for an additional 24 h, after which cells were lysed in TRIzol (Invitrogen). RNA was then isolated using the nCounter low RNA input kit (NanoString LOW-RNA-48). Quality control checks were performed on all samples to determine RNA concentration and integrity (RIN scores > 8.8 for all samples), and 50 ng of each sample was used for the NanoString assay using the NanoString Neuroinflammation panel (770 selected genes) [48]. Gene expression was measured using the NanoString, and the genes with counts two standard deviations above the negative control geometric mean were included in the final analysis. Of 770 genes represented in the panel, 681 genes met this criterion. The counts per gene were then normalized to the geometric mean of 8 housekeeping genes included in the panel. Principal component analysis (PCA) of the expression dataset was first performed to determine whether experimental conditions clustered together and to identify the Bin1 and LPS effect on the dataset. K-means cluster analysis was performed using Morpheus software (Broad Institute). As an orthogonal clustering approach, tSNE was also performed on the NanoString expression data. The agreement between K-means and tSNE clusters was determined by overlaying the two-dimensional tSNE scatter plot with K-means cluster membership (SPSS Version 24). Group-wise analysis of variance (ANOVA) followed by post-hoc Tukey’s test was performed for comparisons across groups. Gene ontology (GO) analysis was performed to identify enriched GO terms, Wikipathways, and KEGG pathways within each cluster using all 681 included genes as the reference list (GOElite, Version 1.2.5) [48, 49].
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(See figure on next page.)
**Fig. 1** Characterization of BIN1 in the mouse brain and human iPSC-derived microglia. **A** Five μm-thick paraffin sections were stained with antibodies against BIN1 (green) and IBA1 (magenta). Images of the cortex and hippocampus from a WT animal show BIN1 expression in IBA1-positive microglia (top panel). By genetically ablating Bin1 expression from excitatory neurons and oligodendrocytes, microglial BIN1 expression is confirmed in Bin1 cKO mice (bottom panel). An asterisk indicates the expected unperturbed BIN1 expression in the thalamus beneath the dentate gyrus in the cKO brain [5]. **B** Line-scan analysis shows the concordance of BIN1 and IBA1 signal intensities in a subset of cells (in WT) and indicates the expression of BIN1 in IBA1+ microglia. The removal of BIN1 expression in excitatory neurons and oligodendrocytes demonstrates that the high-intensity profile of the microglial marker (IBA1) overlaps with that of BIN1, affirming microglial BIN1 expression. **C** Higher magnification images evidence BIN1 localization in the perinuclear regions of the microglial soma in Bin1 cKO and Emx<sup>Cre</sup> littermates. Microglial BIN1 localization is readily apparent in the Bin1 cKO mouse brain, where BIN1 immunoreactivity could be seen permeating into cells’ ramifications (bottom panels). **D** Human post-mortem brain sections were stained with antibodies against BIN1 (green) and IBA1 (magenta). Overlapping morphological homogeneity of immunofluorescence unambiguously demonstrates BIN1 expression in human microglia. **E** Line-scan analysis exemplifies the overlapping expression of the two channels in D. Peaks in both channels represent microglial BIN1 expression, BIN1 only peaks reflect signals from oligodendrocyte cell bodies. The single isolated IBA1 peak suggests a lack of BIN1 expression in the nucleus of microglia. **F** Immunoblot analysis of BIN1 expression in whole-brain homogenates shows higher levels of BIN1 isoforms containing the CLAP domain (BIN1: H) and lower levels of BIN1:L isoforms. In contrast, FACS-isolated mouse microglia and human iPSC-derived iMG predominantly express BIN1 isoforms lacking the CLAP domain (BIN1: L). **G** RT-PCR analyses of FACS-isolated microglia demonstrate that exon 7 (left) and the CLAP domain (right) are excluded in the majority of microglial Bin1 transcripts. We detected no relative change in Bin1 isoforms following LPS administration (see Figs. S2A and S5H). An asterisk indicates a non-specific PCR product. **H** Microglial Bin1 isoforms generated by alternative splicing. Cloning and individual analysis of the PCR products allowed the Bin1 isoform frequency to be calculated. Approximately 90% of mouse microglial Bin1 transcripts code for isoform 10, with isoforms 9, 12, and 6 together, accounting for approximately 10% of Bin1 transcripts. Exon 7 (within the BAR domain), exon 11 (PI domain; see Fig. S3A), and exons 14–16 (within the CLAP domain) were not present in any microglial isoforms screened.
Fluorescent polystyrene microsphere phagocytosis flow Cytometric assay
Phycoerythrin (PE)-conjugated polystyrene microspheres (Thermo-Fisher Fluorospheres, Cat#F13083) were added to primary microglia [41, 50]. Cells were exposed to 5 μl microspheres (∼200 microspheres/cell) for 1 h at 37 °C followed by trypsin incubation for 10 min at 37 °C to detach the cells, after which DMEM with 10% fetal bovine serum was added. The cells were harvested while on ice to halt phagocytic activity. The cells were washed with ice-cold PBS and then labeled with fluorophore-conjugated CD45 (CD45-BV421, BD Biosciences Cat#563890) for 30 min at room temperature, followed by washing prior to flow cytometry. Phagocytic characteristics were assayed by flow cytometry as previously described [50]. All flow cytometric data were analyzed using FlowJo version 10, and proportions of cells demonstrating phagocytic uptake of > 1 bead/cell were determined as an index of phagocytic activity. Phagocytic uptake of > 2 beads/cell was regarded as high-level phagocytosis.
Phagocytosis was assessed in adult mouse brain cells (containing unpurified microglia) following processing in the same manner described for fluorescence-activated microglial cell sorting. Following myelin removal, cells
were incubated with 1 µl yellow-green polystyrene beads (Sigma, Cat#L4655) in 100 µl PBS and incubated in a humidified incubator at 37 °C with 5% CO₂ for 1 h. Cells were then washed twice with PBS, stained with APC-Cy7 rat α-CD11b and PE-Cy7 rat α-CD45, and flow cytometry gated as described for fluorescence-activated microglial cell sorting.
**Fluorescent Fibrillar Aβ42 phagocytosis flow Cytometric assay**
Fibrillar fluorescent Aβ42 conjugated to HiLyte Fluor 488 (fAβ42-488) was prepared by mixing 100 µg of peptide (Anaspec Cat#AS-60479) in 20 µl 1% NH₄OH and immediately diluted with 1XPBS to prepare a 100 µM stock. The mixture was incubated at room temperature for 6 days and then used for phagocytosis assays as described previously [41, 50]. After in-vitro exposure to siRNA and/or inflammatory stimuli, fAβ42-488 (2 µM final concentration) was added for 1 h at 37 °C. Cells were harvested as discussed above, and then the washed cells were labeled with fluorophore-conjugated anti-CD45 mAb (CD45-PE-Cy7, BD Biosciences Cat#552848). Compensation experiments were performed using compensation beads. Phagocytic uptake of fluorescent fAβ42-488 within live CD45⁺ microglia was measured as a proportion of fluorescent cells. We have already previously shown that this peak of fluorescence is inhibited by cytochalasin D treatment, confirming that our assay measures actin-dependent phagocytic processes [50].
**Multiplex immunoassays of cytokines and chemokines (Meso scale discovery platform V-PLEX)**
Culture supernatants were collected prior to harvesting cells for transcriptomic studies. Supernatants were centrifuged to remove debris and then 120 µl was used for multiplex immunoassays (MSD V-PLEX Proinflammatory panel: IFN-γ, IL-10, IL-12p70, IL-1β, IL-2, IL-4, IL-5, IL-6, KC/GRO, TNF-α), per manufacturer’s instructions. These experiments were performed at the Emory Multiplexed Immunoassay Core (EMIC), and all samples were run in duplicate. Standard curves were created for each cytokine. Cytokine data were normalized to the overall mean and represented as a heat map (Morpheus software, Broad Institute). Group-wise ANOVA and post-hoc pairwise statistical comparisons were performed. The same samples were also assayed using a Luminex cytokine panel (EMD Millipore, 15-plex cytokine kit: GM-CSF, IFN-γ, IL-10, IL-1α, IL-2, IL-4, IL-6, IP-10/CXCL10, MCP-1/CCL2, MIP-1α/CCL3, TNFα, M-CSF, VEGF-A, G-CSF, RANTES for in vitro studies). We also measured levels of 32 cytokines (EMD Millipore, 32-plex cytokine kit: G-CSF, Eotaxin, GM-CSF, IFN-g, IL-1α, IL-1b, IL-2, IL-4, IL-3, IL-5, IL-6, IL-7, IL-9, IL-10, IL-12p40, IL-12p70, LIF, IL-13, LIX, IL-15, IL-17, IP-10, KC, MCP-1, MIP-1α, MIP-1b, M-CSF, MIP-2, MIG, RANTES, VEGF, TNF-a, for in vivo studies). These assays were performed per the manufacturer’s protocols and read out on a MAGPIX instrument.
**Microglial morphology analysis**
Mouse brains were post-fixed with 4% PFA at 4 °C, then equilibrated in 30% sucrose until the brains sank. Frozen sections (25 µm) were stained with goat α-IBA1 antibody (Novus Biologicals) for 40 h at 4 °C. Secondary antibody (Alexa fluor 555 donkey α-goat, Invitrogen) was incubated for 3 h, and nuclei were stained with Hoechst for 30 mins. Micrographs of whole-brain sections were acquired as 4.5 µm-thick z-stacks (at 0.5 µm intervals) using a Nikon Eclipse Ti2 microscope with a 20X objective. Image tiles were stitched together and deconvolved using NIS Elements software (Nikon). Maximum intensity projections of the stacked images were generated and converted into binary masks in Fiji/ImageJ. Individual IBA1⁺ cells within (specific regions primary somatosensory cortex, CA1, and hypothalamus) were selected as regions of interest. Morphometric analysis was conducted in Fiji/ImageJ using the FracLac plugin’s region of interest scan function [51]. Output images were inspected manually (by a blinded researcher) to ensure that convex hull detection by FracLac resembled the original maximum intensity projections. Hull and circle morphometric data were analysed with SPSS software.
**Statistical analyses**
GraphPad Prism version 8.0, Microsoft Excel version 2017, SPSS version 24, and R (version 3.5.1) were used for data analyses and data representation. Data are shown as mean ± standard error of the mean (SEM). Student’s t-test (two-tailed, assuming equal variance) was used for pairwise comparisons, with statistical significance set at p < 0.05 unless otherwise specified. All other statistical considerations are discussed in the relevant sections above.
**Results**
**BIN1 expression and subcellular localization in mouse and human brain microglia**
Initially, we sought to unambiguously identify BIN1 protein expression in microglia in the mouse brain. We immunostained wild-type (WT) mouse brain sections with antibodies against BIN1 and IBA1 and found several cells positive for both proteins in the cortex and hippocampus (Fig. 1A, upper panel). However, the blanket
of synaptic BIN1 throughout the brain parenchyma shrouded the entire field of view in the micrographs, producing poor contrast to identify cell specificity by morphology. In order to definitively confirm BIN1 expression in IBA1-positive microglial cells, we generated *Emx*<sup>Cre</sup>*:Bin1<sup>dfl/dfl</sup> mice in which *Bin1* alleles were deleted from excitatory neurons and oligodendrocytes of the hippocampi and cortices [5], providing better contrast for detection of BIN1 in unaffected cell populations (i.e., microglia). As expected, only low-level BIN1 immunoreactivity (likely in inhibitory synapses) was detected in the neuropil of the cortex and hippocampus of *Emx*<sup>Cre</sup>*:Bin1* cKO using a BIN1-specific antibody [5] (Fig. 1A, lower panel). In contrast, a typical BIN1 expression profile in oligodendrocytes and myelinated fiber tracts was evident in the midbrain (Fig. 1A, indicated by an asterisk). Unlike the cellular BIN1 immunofluorescence staining in both IBA1<sup>+</sup> and IBA1<sup>−</sup> cells in WT mice, BIN1 cellular staining in the cortex and hippocampus of cKO mice was limited to IBA1<sup>+</sup> microglial cells. The cellular co-expression of BIN1 and IBA1 was assessed by line scan analyses of the two-channel images (Fig. 1B). In the WT, whilst there is a clear overlap of BIN1 and IBA1 signals in a subset of high-intensity peaks signifying microglial BIN1 expression, other BIN1 peaks were devoid of IBA1 signal, indicating BIN1 expression in other cell types (such as oligodendrocytes, which express high levels of BIN1 [4]). In comparison with *Emx*<sup>Cre</sup>*:Bin1* cKO, the high level of parenchymal BIN1 signal was evident in WT mice. Importantly, measurements from the cKO showed a near-perfect alignment of BIN1 and IBA1 signals in high-intensity peaks, demonstrating BIN1 protein expression within the microglia (Fig. 1B). At higher magnification, intense BIN1 immunoreactivity in the perinuclear regions and ramified processes were visible in microglia of *Emx*<sup>Cre</sup>*:Bin1* cKO mice and *Emx*<sup>Cre</sup> littermates (Fig. 1C). To relate this finding to human microglia, we immunostained post-mortem frontal cortex sections from non-diseased humans in the same manner. BIN1 immunoreactivity was observed in the neuropil and the soma of many cells, some of which were identified as IBA1<sup>+</sup> microglia. As with mouse brain microglia, BIN1 was localised to perinuclear regions of microglia and the processes in the human brain (Fig. 1D). A line scan across the soma of microglia confirmed the overlap and concomitant intensity changes in the two channels (Fig. 1E). Together, these immunohistochemical studies unequivocally confirm microglial BIN1 expression in both human and mouse brains.
**Characterization of microglial BIN1 isoforms**
To identify microglial BIN1 isoforms, we probed immunoblots of lysates from mouse whole-brain homogenates and adult mouse brain-derived CD11b<sup>+</sup>CD45<sup>int</sup> FACS-purified microglia [41]. In accordance with previous analyses of BIN1 isoforms [5, 11], the blots of mouse brain homogenates revealed predominantly higher molecular weight (~75-80 kDa) BIN1 isoforms, representing those containing the CLAP domain (henceforth referred to as BIN1:H), with low-level detection of lower molecular weight (~50-55 kDa) isoforms, which lack the CLAP domain (henceforth referred as BIN1:L) (Fig. 1F). In contrast, BIN1 in fluorescence-activated cell sorting (FACS)-isolated microglial lysates corresponded to BIN1:L, with an almost complete lack of the CLAP domain-containing isoforms. Some low-level expression of proteins that migrated between the dominant BIN1:H and BIN1:L isoforms was evident in microglia. These intermediate-sized proteins may represent a post-translational modification of BIN1:L isoforms or possibly low-level alternate splicing of one or more exons that constitute the CLAP domain.
In order to elucidate *Bin1* isoform expression, we performed RT–PCR analysis of FACS-isolated mouse brain-derived microglia and mouse brain. Results from a set of reactions spanning exons 6-10 demonstrated that exon 7 within the BAR domain is excluded in microglial *Bin1* transcripts (Fig. 1G, left). Furthermore, the skeletal muscle-specific exon 11, which codes for a polybasic sequence that confers binding to phosphoinositides and is essential for BIN1-induced membrane tubulation [52], is spliced out from *Bin1* transcripts in adult mouse brain microglia and human induced iPSCs-derived microglia (Fig. S2A). In concurrence with our immunoblot data, RT-PCR across the region spanning exons 12-19 revealed that microglial *Bin1* transcripts predominantly exclude the exons 13-16 corresponding to the CLAP domain, with some level of alternative splicing in this region (Fig. 1G, right). As expected, isoforms containing the CLAP domain and those lacking this domain were amplified in whole-brain RT–PCR (Fig. 1G). We verified our interpretation of *Bin1* splicing in microglia by cloning the microglial RT–PCR products and analysing the amplified regions in individual clones by gel electrophoresis (for predominant splice pattern) and/or sequencing (predominant and non-predominant splice patterns). The vast majority of clones lacked exons 13-17 (∆ CLAP, ∆ exon 17), accounting for ~90% of *Bin1* transcripts (isoform 10), with low-frequency inclusion of exons 13 and 17 (isoforms 6, 12, and 9; Figs. 1H and S2B).
In order to relate the above findings from murine microglia to human expression, we generated
differentiated microglia-like cells (iMG) from human induced pluripotent stem cells (iPSC) [44–46] and extracted protein lysates. Immunoblot analysis demonstrated the presence of BIN1:L isoforms, the lack of BIN1:H isoforms, and the presence of some intermediate-size BIN1-related polypeptides. These cross-species investigations show that the general pattern of BIN1 isoforms expressed in human iPSC-derived microglial cells resembles the BIN1 isoforms found in FACS-isolated adult mouse brain microglia (Fig. 1F).
**BIN1 is a regulator of proinflammatory activation, cytokine production, and neurodegeneration-associated gene expression in primary mouse microglia**
Neuroinflammation and microglial activation are common pathological features of several neurodegenerative diseases, including AD. Cultured microglia initiate a robust proinflammatory response when exposed to LPS, an agonist of toll-like receptors, resulting in an altered gene signature and release of proinflammatory cytokines (e.g., IL1b, TNF, and IL6), which are implicated in neurodegenerative diseases [53, 54]. To investigate
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**Fig. 2** *Bin1* KD in primary microglia dysregulates proinflammatory and PU.1-dependent genes. **A** *Bin1* siRNA transfection resulted in >80% reduction in Bin1 transcripts, as confirmed by qRT-PCR. **B** PCA identified two PCs, which accounted for 71% of the variance in the dataset. PC1 captured the effect of Bin1 loss (42%), while PC3 captured the LPS effect (29%). The LPS effect shown by PC2 was blunted in the absence of Bin1. **C** Both PCs were increased by LPS stimulation. Bin1 KD caused a significant increase in PC1 in resting and LPS-stimulated microglia; Bin1 KD only decreased PC2 during LPS stimulation (*p < 0.05, **p < 0.01, ***p < 0.001, Dunn’s). **D** K-means clustering identified six gene clusters, of which five showed distinct patterns of expression based on in vitro manipulations. Cluster 1 was positively regulated by BIN1 in homeostasis, and LPS-stimulated up-regulation was BIN1-dependent. Cluster 2 was positively regulated by BIN1 during LPS stimulation, but its homeostatic regulation was not affected by BIN1. Cluster 3 was positively regulated by BIN1 (during homeostasis and LPS stimulation) but downregulated during LPS stimulation. Cluster 5 was negatively regulated by BIN1 and unaffected by LPS stimulation. Cluster 4 was not regulated by BIN1 but was upregulated during LPS stimulation (not shown in the figure). **E** Gene ontology enrichment analyses (GO, KEGG, WikiPathways included) identified key inflammatory and immune (clusters 1 & 2), homeostatic microglial (cluster 3), and non-microglial-specific (cluster 5) pathways affected by in vitro manipulation of primary microglial cultures. Predicted upstream transcriptional regulators for each cluster are shown, among which *Sfpi1* (PU.1) was shared across clusters 1, 2, and 3.
the potential role of microglial BIN1 in the regulation of homeostatic signaling and inflammatory responses, we manipulated primary microglia in culture. Mouse postnatal microglial cultures were treated with *Bin1* siRNA (or sham siRNA) for 48h and then with or without LPS (100ng/ml) for an additional 24h, and their neuroinflammatory profile was assessed (770-gene NanoString neuroinflammatory gene panel) [31, 48, 55]. LPS stimulation caused a significant upregulation of *Bin1* transcripts (Fig. S3B). *Bin1* siRNA treatment substantially suppressed *Bin1* transcript levels (> 80%, Fig. 2A) without impacting cell viability or morphological response to LPS (Fig. S3A and data not shown). Of 681 genes included in the final analysis (Supplemental Table 1), 513 were differentially expressed at the unadjusted level (ANOVA $p < 0.05$) and 498 genes at the adjusted level (FDR < 5%). The first two principal components (PCs) collectively explained 71% of the variance in the dataset. PC1 predominantly accounted for the *Bin1* knockdown (KD) effect (42% variance), which was largely independent of the LPS effect (Fig. 2B-C). PC2 accounted for the LPS effect (29% variance) and, furthermore, showed that the LPS effect was dampened following the loss of *Bin1* (Fig. 2B-C).
K-means clustering revealed 6 clusters of affected genes, of which 5 showed distinct patterns of regulation by LPS and BIN1 (Fig. 2D). Cluster 1, positively regulated by BIN1 under both resting and LPS-stimulated conditions, was enriched in genes (including *Siglec1*,
C3ar1, Fcgr1, and Tmem119) involved in innate immune response, regulation of type I interferon production and signaling, lipid binding, antigen binding, and localization in membrane rafts (Fig. 2E and Fig. S4C). This cluster also contained Bin1, confirming the effect of Bin1 siRNA. Cluster 2 genes were upregulated by LPS and positively regulated by BIN1 and included canonical proinflammatory genes (including Il1b, Marco, C3, and Irak3), involved in the regulation of NF-κB signaling, cytokine production, and NLRP3 inflammasome function. Cluster 3 genes were downregulated by LPS and positively regulated by BIN1 and included homeostatic (Cx3cr1, Gpr34) and DAM genes (Trem2, Tyrobp, Spp1, and Apoe) [25] involved in endo-lysosomal function, lipid metabolism, adhesion, and TGFβ signaling (see Fig. S4E). Cluster 4 contained genes upregulated by LPS but independent of BIN1, which are involved in ubiquitin-mediated proteolysis, ribosome and epigenetic regulation, and histone methylation, reflecting the profound effect LPS has on microglia. Cluster 5 genes were generally expressed at lower levels, were negatively regulated by BIN1 independent of LPS stimulation, and included genes involved in synaptic transmission, typically expressed in neurons (see Fig. S4F).
**Fig. 4** Functional analyses demonstrate BIN1 facilitates inflammation-induced cytokine production, as well as phagocytosis, in primary microglial cultures. **A–B** Bin1 siRNA treatment did not affect cytokine secretion in unchallenged microglial cultures. LPS exposure increased secretion, which was attenuated by the KD of Bin1. **C–D** Flow cytometric analysis of the fluorescent microsphere phagocytosis found that Bin1 reduction impeded the phagocytic capacity of primary microglia, both unchallenged and following LPS stimulation. **E** Phagocytosis of fibrillar Aβ$_{42}$ was unaffected by Bin1 silencing. *, $p < 0.05$; **, $p < 0.01$; ***, $p < 0.001$, by post-hoc t-test with Bonferroni correction for multiple comparisons. Phagocytosis data plotted as mean ± SEM.
We also visualized our gene expression data using T-distributed stochastic neighbor embedding (tSNE) analysis to demonstrate better broad groups of genes positively regulated by BIN1 (overlapped with clusters 1, 2, and 3) and negatively regulated by BIN1 (clusters 4 and 5), identified above by hierarchical clustering analysis (Fig. 3A). In cluster 3 of our dataset, BIN1 positively regulated several DAM genes (Fig. 3C) previously identified by single-cell RNAseq of microglia from mouse models of AD pathology [25]. To ascertain the significance of microglial BIN1-regulated genes in AD pathology, we performed MAGMA of AD-associated genetic risk factors [23]. This analysis revealed substantial overlap with our dataset (Fig. 3B), indicating that several AD risk genes act downstream of BIN1 in microglia. Interestingly, risk genes with high homeostatic expression in microglia (*Apoe*, *Trem2*, *Cd33*, and *Ms4a4a*) were positively regulated by BIN1, whereas neuronal AD risk genes (*Cnn2* and *Gria1*) and autophagy genes (*Sgstm1*) were negatively regulated by BIN1. To validate the regulation of DAM genes by BIN1 in microglia, we performed a qRT-PCR analysis of primary microglia using identical conditions to those used for NanoString studies. We confirmed that BIN1 positively regulated several selected DAM genes, including *Apoe*, *Trem2*, *Grn*, *Tyrobp*, *Spp1*, and *Lamp1* (Fig. 3D and Fig. S3C).
Pathway analysis identified important transcription factors as potential upstream regulators of BIN1-regulated gene clusters (Fig. 2E). PU.1 – a master transcriptional regulator of both microglial development and DAM transition – was predicted upstream of Clusters 1, 2, and 3 genes. Additionally, Cluster 2 genes are known to be regulated by NF-κB, STAT1, IRF1, and HDAC1. Pathway analysis of DAM genes positively regulated by BIN1 indicates ATF3 as an upstream regulator. BIN1 also directly affects *Atf3* transcription in our data, suggesting that ATF3 may serve as an intermediary in BIN1’s control of DAM gene expression. Finally, our *in vitro* qRT-PCR experiments demonstrate that BIN1 positively regulates transcription of *Sfp1l* (coding PU.1) and *Irf1* (Fig. 3E), two regulators which control numerous microglial genes under homeostatic and inflammatory conditions. Interestingly, we also uncovered a reciprocal relationship between PU.1 and BIN1 (Fig. 3F), adding another layer of complexity to BIN1’s involvement in pathogenic signal dysregulation.
In light of BIN1’s transcriptional regulation of cytokine gene expression (Fig. 2E, Fig. S4, and Supplemental Tables S1 and S2), we sought to confirm this observation at a functional level. Primary microglia were assayed for cytokine secretion following *Bin1* KD and LPS exposure. We found no differences in cytokine secretion under basal conditions following *Bin1* KD; however, the diminution of *Bin1* expression attenuated LPS-induced increases in the levels of secreted proinflammatory cytokines (i.e., TNF, RANTES, and IL6) across two different assay platforms (MSD and Luminex; Fig. 4A-B). Analysis of transcript levels from the six cytokines included in our NanoString panel demonstrated a similar pattern (Cluster 2) for five of these (*Il1b*, *Tnf*, *Ccl2*, *Ccl3*, *Ccl5*). Of further functional importance, several proteins coded by Cluster 3 genes (*Trem2*, *Tyrobp*, *Cd68*, and *Apoe*; see Fig. 3C) regulate phagocytosis in microglia. To investigate the functional significance of these gene expression changes, we analyzed the phagocytic capacity of
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**Fig. 5** In vivo deletion of *Bin1* affects surface CD11c expression. **A** Experimental strategy for in vivo experiments involved three groups of mice: Bin1\textsuperscript{fl/fl} (WT equivalent), Cx3cr1\textsuperscript{CreER}, Bin1 cKO (experimental group). Mice were injected with tamoxifen for 5 consecutive days, then rested for four weeks to allow replenishment of Bin1 expression in peripheral monocytes. Mice then received saline or LPS for four consecutive days, and brains were harvested for flow cytometry / FACS, IHC, and cytokine assays, 24 h after the final injection. **B** Immunofluorescence staining in the piriform cortex demonstrates BIN1 expression in microglia (yellow arrows), oligodendrocytes (asterisks), and synapses (unlabelled) in mice with normal BIN1 expression (Cx3cr1\textsuperscript{CreER}, Bin1 was deleted from the microglia of experimental mice (Cx3cr1\textsuperscript{CreER}, Bin1 cKO), whilst oligodendrocytes and synaptic BIN1 were unaffected. **C** Mouse brain cells were labelled with APC-Cy7 α-CD11b, PE-Cy7 α-CD45, and BV421 α-CD11c. Single, mononuclear, live cells were gated, and microglia were sorted as CD11b\textsuperscript{+}CD45\textsuperscript{hi} population. **D** A representative flow cytometric image of each experimental group is depicted. **E** Flow cytometric analysis demonstrates that LPS administration in vivo caused an increase in the proportion of cells with high surface CD11c expression in all genotypes. The LPS effect was augmented by Cx3cr1 haploinsufficiency (Cx3cr1\textsuperscript{CreB}),; this additional increase was blunted by microglial Bin1 deletion (Cx3cr1\textsuperscript{CreER}, Bin1 cKO). Two-way ANOVA found main effects for genotype ($F_{2,17} = 32.98, p < 0.001$) and LPS ($F_{1,17} = 100.9, p < 0.001$). There was a significant genotype*LPS interaction ($F_{2,17} = 16.87, p < 0.001$). **F** NanoString mRNA counts show that LPS increased Itgax transcript numbers ($F_{1,16} = 27.014, p < 0.001$). No differences between genotypes ($F_{1,16} = 3.065, p = 0.075$) and no genotype*LPS interactions ($F_{2,16} = 1.052, p = 0.372$) were found. Bin1 deletion did not attenuate Itgax transcript numbers. **G** NanoString analysis of mRNA from sorted microglia demonstrates that our cKO system resulted in approximately 50% decrease in microglial Bin1 expression ($F_{2,17} = 13.14, p < 0.001$), which was not affected by LPS ($F_{2,17} = 0.712, p = 0.505$), despite the main effect for LPS increasing Bin1 transcripts ($F_{1,17} = 5.893, p = 0.027$). Analysis of Cx3cr1 transcript numbers found a main effect for genotype ($F_{2,17} = 43.802, p < 0.001$), with post-hoc differences between Bin1\textsuperscript{fl/fl} with Cx3cr1\textsuperscript{CreER} ($p < 0.001$), Bin1\textsuperscript{fl/fl} with Cx3cr1\textsuperscript{CreER}, Bin1 cKO ($p < 0.001$), and Cx3cr1\textsuperscript{CreER}, Bin1 cKO ($p = 0.043$) demonstrating that the reduction in Cx3cr1 expression in the Cre line was partially attenuated by Bin1 deletion. No main effect for LPS treatment ($F_{1,17} = 0.303, p = 0.589$) and no genotype*LPS interaction ($F_{2,17} = 0.515, p = 0.606$) were found. All by two-way ANOVA. *, $p < 0.05$; **, $p < 0.01$; ***, $p < 0.001$; by post-hoc t-test with Bonferroni correction for multiple comparisons. All data plotted as mean ± SEM.
primary microglia following *Bin1* KD (Fig. 4C-D). Reduced *Bin1* expression resulted in a decrease in phagocytosis of fluorescent microspheres and augmented the impairment induced by high-dose LPS exposure. However, we observed no effect for *Bin1* loss on the ability of primary microglia to phagocytose fluorescent Aβ$_{42}$ fibrils (Fig. 4E). Overall, our in vitro studies suggest that BIN1 regulates proinflammatory responses, the expression of several neurodegenerative disease-relevant genes, and cytokine production in primary mouse microglia.
**Fig. 5** (See legend on previous page.)
Microglia-specific ablation of *Bin1* mitigates LPS-mediated proinflammatory activation and DAM gene expression profile in vivo
Considering the differences in microglial phenotypes between culture conditions and in vivo, we proceeded to investigate the effects of microglia-specific *Bin1* deletion on the mouse brain microglial transcriptome under homeostatic and inflammatory (systemic LPS) conditions. We employed an inducible conditional *Bin1* knockout strategy by crossing *Cx3cr1*^*tm2.1lcreERT2*^Litt^+/Wgan^ [56] (heterozygous animals of this line are referred to as *Cx3cr1*^CreER^) with *Bin1*^fl/fl^ mice. Experimental groups included *Bin1*^fl/fl^ as the wild-type equivalent, *Cx3cr1*^CreER^ as the primary reference group (as these mice only have one functional *Cx3cr1* allele), and *Cx3cr1*^CreER^-*Bin1*^fl/fl^ (*Cx3cr1*^CreER^-*Bin1* cKO) as the experimental group. Following 5 days of daily tamoxifen injections, mice were rested for a four-week interval to allow replenishment of peripheral monocytes/macrophages (which also express *Cx3cr1*). Following this, LPS was administered for four consecutive days to induce a well-characterised proinflammatory microglial response [57, 58], and mice were euthanized 24 h after the final injection (Fig. 5A). As expected, LPS induced a sickness response of hypothermia and weight loss. Interestingly, we observed a trend towards dampened hypothermic responses in *Bin1* cKO mice without affecting weight loss (Fig. S5B-E).
LPS administration did not cause a significant change in *Bin1* expression in FACS-isolated brain microglia as quantified by NanoString analysis (Fig. S5G), and no change in *Bin1* splicing was detected by RT-PCR (Figs. 1G, S2A, and S5H). Using immunofluorescence staining, we confirmed BIN1 expression in IBA1^+^ microglia of *Cx3cr1*^CreER^ but not *Cx3cr1*^CreER^-*Bin1* cKO mice (Fig. 5B). Whilst LPS administration induced a morphological transition into an amoeboid phenotype in WT (*Bin1*^fl/fl^) microglia, *Cx3cr1* haploinsufficient microglia presented a hyper-ramified morphology in response to LPS (Fig. S6A). Strikingly, *Cx3cr1*^CreER^-*Bin1* cKO microglia appeared to fully retain resting morphology (Fig. S6A), suggesting a functional inability to respond to inflammatory conditions. However, key parameters of microglial morphology were not significantly affected, demonstrating the highly variable morphological response of these heterogeneous cells, with significant differences between brain regions (Fig. S6B-C). LPS administration did not seem to affect BIN1 expression or localization in microglia, as detected by immunofluorescence histology staining of *Bin1*^fl/fl^ mouse brains (Fig. S5F).
Flow cytometry was performed on mononuclear cells isolated from brains to measure the surface expression of CD11b, CD45, CD11c, and Ly6c. CD11b^+^CD45^int^ microglia were FACS-purified and processed for NanoString transcriptomic profiling (Fig. 5A and C). Based on Iba1 immunofluorescence staining and flow cytometry studies, we observed no difference in microglial density or numbers across the genotypes (Fig. S6A and data not shown). Amongst CD11b^+^CD45^int^ microglia, there was a significant increase in the proportion of CD11c^+^ microglia following LPS treatment, which was most apparent in *Cx3cr1*^CreER^ mice (Fig. 5D and E), likely attributable to *Cx3cr1* haploinsufficiency. In contrast to *Cx3cr1*^CreER^ mice, the additional loss of *Bin1* (*Cx3cr1*^CreER^-*Bin1* cKO) abrogated this LPS effect (Fig. 5D and E). Thus, high-level surface CD11c expression, a feature of microglial activation and signature of the DAM phenotype [21, 25, 59] (several genes of which are upregulated following LPS exposure [60]), becomes apparent in microglia in the LPS-induced neuroinflammation model and appears to be moderated by CX3CR1 signaling. Collectively, these findings indicate that BIN1 positively regulates cell surface CD11c levels in microglia and may control the induction of the DAM phenotype following systemic LPS administration.
Inflammatory gene expression data from FACS-purified microglia were then analyzed for 511 transcripts (Supplemental Table S3). Microglia isolated from *Cx3cr1*^CreER^-*Bin1* cKO animals had approximately 50% lower *Bin1* levels than *Cx3cr1*^CreER^ controls (Fig. 5G). The efficiency of *Bin1* loss did not vary between sexes.
(See figure on next page.)
**Fig. 6** In vivo microglia-specific loss of *Bin1* dampens the proinflammatory microglial response. **A** PCA of gene expression data from FACS-purified mouse brain microglia from in vivo *Bin1* cKO studies identified two PCs which accounted for 42% of the variance in the data. **B** PC1 (effect of LPS regardless of genotype) explained 29.9% of the variance, whilst PC2 (LPS effect impacted by genotype) explained 12.4% of the variance and exemplified the pattern of *Bin1* cKO mitigating dysregulation by *Cx3cr1* haploinsufficiency. **C** K-means clustering identified five clusters of genes affected in our dataset. Cluster 1 genes were upregulated during LPS stimulation, dependant on BIN1. Cluster 2 was upregulated by LPS stimulation and positively regulated by BIN1 (downregulated by *Bin1* cKO). Cluster 3 was upregulated by LPS independent of BIN1. Cluster 4 was downregulated by LPS and positively regulated by BIN1 in unstimulated conditions. Cluster 5 genes were negatively regulated by BIN1, counter to CX3CR1. **D** Gene ontology enrichment analysis identified interferon-response pathways regulated by cluster 1 genes. **E** Thirteen microglial genes were suppressed by BIN1 (upregulated by *Bin1* cKO) independent of LPS inflammation, including homeostatic genes *P2ry12*, *Tmem119*, and *Tgfbr1*. **F** Pathway analysis suggests STAT1 signaling may regulate expression of cluster 1 genes (nature of the interaction between genes is shown based on color scheme shown in the key). **G** Analysis of microglia numbers found no main effects for genotype ($F_{2,21} = 2.614, p = 0.097$), LPS treatment ($F_{1,21} = 0.002, p = 0.966$), or no genotype*LPS interaction ($F_{2,21} = 1.192, p = 0.323$) (by two-way ANOVA). Phagocytic capacity was not affected by LPS ($F_{1,21} = 1.939, p = 0.178$) or genotype ($F_{2,21} = 0.121, p = 0.887$) in *Bin1* cKO studies, and no genotype*LPS interactions was found ($F_{2,21} = 0.101, p = 0.904$) (by two-way ANOVA). Data plotted as mean ± SEM. For associated physiological data and immunohistochemistry data, see Fig. S5B-F.
or by LPS-treatment (data not shown and Fig. 5G). As expected, microglia from *Cx3cr1*^CreER^ mice showed lower *Cx3cr1* expression, demonstrating the *Cx3cr1* haplo-insufficiency of this mouse line (Fig. 5G). PCA showed that two PCs explained 43% of the variance in the data (PC1 29.9%, PC2 12.4%) (Fig. 6A). PC1 captured the LPS effect that was relatively similar across all three genotypes. PC2 captured LPS responses that were modified by...
Cx3cr1 genotype as well as by Bin1 deletion. At baseline, Cx3cr1CreER mice showed higher levels of activation when compared with WT (Bin1fl/fl) mice. The LPS response captured by PC2 was most pronounced in Cx3cr1CreER mice, consistent with the previous characterization that signaling through CX3CR1 controls microglial activation [61]. Interestingly, the loss of Bin1 mitigated the heightened LPS response elicited by Cx3cr1 haploinsufficiency. These high-level transcriptomic findings align with our flow cytometric results suggesting that, during inflammation, the CD11c+ DAM phenotype is facilitated by BIN1.
Of 511 genes included in the analysis, 164 genes show group-wise differential expression (ANOVA \( p < 0.05 \), Supplemental Table S3). K-means clustering of these differentially expressed genes identified 5 clusters with distinct patterns of expression (Fig. 6C). Cluster 1, which contains proinflammatory genes (including C4a, Il1b, Ccl2, Ifi7, and Stat1), was upregulated following LPS, while the loss of Bin1 suppressed this response. Therefore, cluster 1 genes were positively regulated by BIN1 specifically under proinflammatory conditions, corroborating the aforementioned in vitro phenotype from Bin1 siRNA KD. Cluster 2 genes demonstrated a uniform LPS effect across all genotypes and included some canonical proinflammatory genes known to be upregulated by LPS (e.g., Tlr2, Il1a, and Fcgrr3), as well as Apoe, the e4 allele variant of which is the highest predictor of LOAD risk [62]. Cluster 3 genes showed a pattern similar to Cluster 2 without an apparent BIN1 dependence, and included Itgax (which encodes CD11c), Tyrobp, and Rpl9. While increased Itgax expression by LPS was consistent with flow cytometric findings of an increase of CD11c+ microglia in LPS-treated mice (Fig. 5D and E), the unabating expression of Itgax following Bin1 deletion despite a decrease of CD11c+ microglia was surprising (Fig. 5F). This finding suggests that post-transcriptional or post-translational control of CD11c expression, or surface localization, requires BIN1 function. Cluster 4 genes were suppressed by LPS and showed amelioration with the additional Bin1 deletion, indicative of positive regulation by BIN1 during inflammation. Cluster 5 contains genes that were negatively regulated by both BIN1 and CX3CR1, irrespective of LPS treatment. A summary of overall trajectories of changes in gene expression at the cluster level is presented in Fig. S7A-B. Additionally, we identified 13 genes (including Olfrn3, Tmem119, Mertk, Trem2, and P2ry12) regulated by BIN1 independent of the state (Fig. 6E).
Gene set enrichment analyses of Cluster 1 genes suggested positive regulation of type 1 interferon (\(\alpha/\beta\)) expression and production (Fig. 6D). In addition, the BIN1-regulated Cluster 1 was enriched in ribosomal genes (Rpl28, Rpl29, Rps10, and Rps9), cytokines, and response to IFN\(\gamma\) genes (Il1b, Ccl2, Ccl5, and Stat1), as well as regulation of oxidoreductase activity (Apoe, Il1b, and Slamf8). Thirty-three of the LPS-upregulated genes were suppressed at least 1.5-fold following Bin1 deletion. An analysis of the known interactions between these genes and their encoded proteins is shown in Fig. 6F.
Overall, our in vivo studies suggest that BIN1 somewhat counteracts Cx3cr1 haploinsufficiency. The loss of CX3CR1 signaling has previously been shown to increase phagocytosis of fluorescent microspheres [63]. We, therefore, sought to relate the loss of Bin1 in microglia with microglial functionality, focusing on their ability to phagocytose fluorescent microspheres [50] and asked whether the additional loss of Bin1 was sufficient to reverse the effect of Cx3cr1 haploinsufficiency. However, we found that neither Cx3cr1 haploinsufficiency nor deletion of microglial Bin1 had any impact on phagocytosis under the assay conditions employed in this study, and LPS also failed to impact this cellular function (Fig. 6G). The lack of any observed effect of FACS-sorted microglia lacking Bin1 on phagocytosis was somewhat consistent with the modest effects observed in cultured microglia following Bin1 siRNA KD.
We also measured inflammatory cytokine levels in brain homogenates (sampled from the frontal cortex) from all experimental mice by Luminex (32 cytokine panel) (Fig. S7C). LPS increased eotaxin, MIG, and IP-10 levels in all genotypes with no effect of Bin1 loss. While the effect of Bin1 deletion within unstimulated and LPS-stimulated groups was not statistically significant, we observed global effects of Bin1 deletion, independent of LPS treatment. As compared to Cx3cr1CreER mice, Cx3cr1CreER-Bin1 cKO mice had higher levels of IFN\(\gamma\) (\(p = 0.017\)), IL4 (\(p = 0.026\)) and IL7 (\(p = 0.014\)).
**BIN1 may mediate its transcriptomic effects in microglia by impacting type 1 interferon signaling**
Our in vitro studies showed robust effects of Bin1 loss on microglial gene expression and inflammatory cytokine production. However, post-natal microglia do not entirely recapitulate adult microglial responses [64]. While our in vivo experiments overcome these limitations of in vitro studies, the effect of Cx3cr1 haploinsufficiency complicates interpretations from in vivo microglia-selective Bin1 deletion. Despite these limitations, we observed notable overlap in gene ontologies and patterns of BIN1-mediated gene regulation from in vitro and in vivo studies. In order to identify the most robust and concordant findings emerging from our in vitro and in vivo data, we performed a combined analysis of NanoString datasets derived from both sets of experiments. A set of 498 genes with expression above threshold across both datasets were included.
in this analysis. The Venn diagrams show the number of shared DEGs under basal and LPS-stimulated conditions in the in vitro and in vivo datasets (Fig. 7A). PCA of these shared gene sets revealed suppression of LPS-induced transcriptomic changes in microglia following LPS stimulation as the common feature following the reduction of *Bin1* expression (Figs. 7B and C). Under non-stimulated conditions (sham siRNA vs. *Bin1* siRNA in vitro, and *Cx3cr1CreER* vs. *Cx3cr1CreER-Bin1* cKO microglia from in vivo studies, all without LPS treatment), we observed few concordant genes regulated by *Bin1* in both datasets (Fig. 7D). However, under LPS stimulated conditions (sham siRNA+LPS vs. *Bin1* siRNA+LPS in vitro, and *Cx3cr1CreER*+LPS vs. *Cx3cr1CreER-Bin1* cKO+LPS microglia from in vivo studies), we observed greater concordance between the two model systems (Fig. 7D). We combined these concordant lists of BIN1-regulated genes (31 genes positively regulated including *Cd69*, *Ccl2*, *Ifn7*, and *Iftm3*; and 13 genes negatively regulated including *Cables1* and *Tmem100*) and performed GO enrichment analysis to identify BIN1-regulated ontologies in microglia. BIN1 was found to be a positive regulator of carbohydrate binding, type I interferon and immune pathways, antigen presentation via MHC-I, and a negative regulator of cell proliferation. BIN1 also negatively regulated genes located at cell projection, cell junction, and membrane (Fig. 7E). Specific BIN1-regulated genes involved...
in type 1 interferon signaling included *Ddx58*, *Ifih1*, *Irf7*, *Ifi30*, and *Ifitm3* (Fig. 7F).
**Inflammatory upregulation of Ifitm3 is dependent on Bin1 expression**
In light of the profound effect of *Bin1* deletion on gene transcription, we validated key homeostatic and DAM genes identified in our NanoString panel – as well as *Cst7*, a DAM gene – by qRT-PCR (Fig. 8A and Fig. S8). We also found that inflammatory upregulation of transcription factor *Sfp1* (identified by network analysis) depended on BIN1 (Fig. 8A and Fig. S8). Based on its localization in the cytosol and processes, we reasoned that microglial BIN1 likely functions as a cytosolic adaptor protein that regulates receptor dynamics in the context of endocytosis and recycling, rather than a transcriptional regulator. We, therefore, sought to determine whether BIN1 regulates signaling via type 1 interferon pathways. One key gene uncovered in our datasets is the lysosome-associated restriction factor *Interferon Induced TransMembrane protein 3* (*Ifitm3*), whose expression is activated by type I and type II interferon signaling. To validate our NanoString data from FACS-isolated microglia (Fig. 8A-B), we performed a qRT-PCR analysis of whole-brain RNA isolated from *Cx3cr1CreER* and *Cx3cr1CreER;Bin1* cKO mice following LPS challenge (or saline injection). We found an LPS-induced upregulation of *Ifitm3* transcripts in *Cx3cr1CreER* mice, which was significantly attenuated by *Bin1* deletion (Fig. 8A-C). We further validated this finding at the protein level in immunoblot analysis of whole-brain protein lysates (Fig. 8D). Transcript levels from cultured microglia quantified by NanoString analysis confirmed that the *Ifitm3* upregulation is blunted by *Bin1* knockdown in the absence of *Cx3cr1* haploinsufficiency (Fig. 8E). In order to further validate this effect without the limitations of *Cx3cr1* haploinsufficiency (in vivo) or incomplete transient *Bin1* reduction (siRNA KD), we generated stable pools of *Bin1* KO microglial cells by CRISPR/Cas9-mediated gene editing in the BV2 cell line (Fig. S9). *Bin1* KO cells displayed a remarkably blunted *Ifitm3* response to LPS treatment (Fig. 8F). Strikingly, immunofluorescence labelling of mouse brain sections with an IFITM3 antibody demonstrated intense IFITM3 immunoreactivity throughout the microglial soma and ramifications of *Cx3cr1CreER* mice following LPS challenge, with little, if any, LPS-mediated upregulation in the absence of BIN1 expression (Fig. 8G).
Collectively, our congruent findings derived from transcriptomic profiling of microglia and experimental validation studies show that microglial BIN1 positively regulates key elements of DAM phenotype transformation and type 1 interferon networks, which are likely to be independent of in vitro versus in vivo differences and independent of *Cx3cr1* haploinsufficiency.
**Discussion**
Our study demonstrates, for the first time, that BIN1 is a key regulator of microglial gene expression and functionality, both in homeostatic and inflammatory conditions. By transcriptional profiling of cultured microglia challenged with LPS, we identify BIN1 as a regulator of proinflammatory activation, cytokine production, and
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(See figure on next page.)
**Fig. 8** LPS-induced up-regulation of IFITM3 in microglia is dependent on BIN1. **A** qRT-PCR analysis of whole-brain cDNA found inflammation-induced upregulation of key homeostatic and DAM genes are dependent on BIN1. Upregulation of a crucial myeloid transcription factor (*Sfp1*), as well as an interferon-induced innate immune gene (*Ifitm3*), were also BIN1-dependent. Raw dataset is provided in Fig. S8. **B** NanoString analysis of transcripts in FACS-isolated microglia demonstrates an up-regulation of *Ifitm3* following in vivo LPS injections. This effect is augmented in *Cx3cr1CreER* microglia and is dependent on BIN1. Main effects were found for genotype ($F_{2,16} = 26.538, p < 0.001$) and LPS treatment ($F_{1,16} = 66.105, p < 0.001$), and a significant genotype*LPS interaction was found ($F_{2,16} = 20.609, p < 0.001$) (by two-way ANOVA). Post-hoc pairwise comparisons found *Cx3cr1CreER* to be different from both *Bin1* $^{1/0}$ ($p < 0.001$) and *Cx3cr1CreER;Bin1* cKO ($p < 0.001$) (with Fisher’s LSD applied). **C** qRT-PCR analysis of whole-brain transcripts validated the pattern of microglial expression. A main effect for LPS treatment was found ($F_{1,18} = 17.497, p < 0.001$), but the effect for genotype ($F_{2,18} = 3.189, p = 0.065$) and the genotype*LPS interaction ($F_{2,18} = 2.734, p = 0.092$) failed to reach significance (by two-way ANOVA). Despite this, post-hoc pairwise comparisons found *Cx3cr1CreER* to be different from *Cx3cr1CreER;Bin1* cKO ($p = 0.036$). However, the comparison with *Bin1* $^{1/0}$ genotype failed to reach significance ($p = 0.051$) (with Fisher’s LSD applied). **D** Immunoblot analysis of whole-brain lysates confirmed the transcriptional regulation results in similar IFITM3 protein level changes. Whilst a main effect for LPS treatment was found ($F_{1,8} = 6.156, p = 0.038$), genotype ($F_{1,8} = 4.788, p = 0.06$) and the genotype*LPS interaction ($F_{1,8} = 4.126, p = 0.077$) failed to reach significance in our data (by two-way ANOVA). **E** NanoString analysis of transcripts in primary cultured microglia shows *Ifitm3* expression is blunted in Bin1 KD cells. Main effects for siRNA treatment ($F_{1,18} = 53.326, p < 0.001$) and LPS ($F_{1,18} = 43.226, p < 0.001$) were found. There was no siRNA*LPS interaction ($F_{1,8} = 3.137, p = 0.115$). **F** CRISPR-edited BIN1 BV2 KO microglia validate that *Ifitm3* upregulation in response to LPS stimulation is impaired in Bin1 KO cells, with main effects for *Bin1* ($F_{1,20} = 44.503, p < 0.001$) and LPS ($F_{1,20} = 23.945, p < 0.001$), and a significant *Bin1*LPS interaction ($F_{1,20} = 16.023, p < 0.001$). **G** Immunofluorescence detection of IFITM3 in mouse brain demonstrates that IFITM3 expression throughout the LPS-treated *Cx3cr1CreER* microglia but not in *Cx3cr1CreER;Bin1* cKO. Note that microglia are indicated by white arrows, and IFITM3 labelling of blood vessels is indicated by small yellow arrowheads. *, $p < 0.05$; **, $p < 0.01$; ***, $p < 0.001$; by post-hoc t-test with Bonferroni correction for multiple comparisons. All data plotted as mean ± SEM.
neurodegeneration-associated gene expression. The in vitro results were confirmed by analysing FACS-isolated adult brain microglia from WT and cKO mice and showing that microglial BIN1 is a key regulator of LPS-mediated proinflammatory activation and DAM gene expression in vivo.
Fig. 8 (See legend on previous page.)
High-level BIN1 expression in microglial transcriptomics and proteomics datasets has been reported previously [16–18]. Still, there have been only two reports of cellular co-localization of BIN1 with microglial markers. One identified IBA1-positive cells expressing BIN1 in immunohistochemical analysis of post-mortem brain tissue from patients with AD [8]. Another study reported detection of BIN1 isoforms 12 and 6 in the nucleus of CD45+ microglia using antibodies raised against BIN1 exons 11 and 13; notably, the major microglial BIN1 isoform 10 lacking both exons 11 and 13 was not observed by immunostaining in the previous study [65]. In this regard, it is worth mentioning that exon 11, which codes for a polybasic sequence that confers binding to phosphoinositides and is essential for BIN1-induced membrane tubulation [66], is spliced out from *Bin1* transcripts in adult mouse brain microglia and human induced iPSCs-derived microglia (Fig. S2A). By generating mice lacking BIN1 expression in excitatory neurons and oligodendrocytes, we have unequivocally demonstrated BIN1 expression in microglia. The identification of BIN1 isoform 10 in our study as the most abundant *Bin1* transcript in mouse brain microglia is consistent with the human brain microglia RNAseq data imputed to BIN1 isoforms [65]. However, our demonstration of BIN1 localization in the perinuclear region and microglial processes is at odds with the earlier report of BIN1 in microglial nuclei [65]. The analyses of BIN1 in *Emx*<sup>Cre</sup>-*Bin1* cKO mice by immunostaining (this study) and immunoblots [5] indicate that microglial BIN1 accounts for only a minor fraction of all BIN1 expressed in the brain. Nevertheless, it is worth noting that a large-scale cell-type-specific promoter–enhancer interaction study identified a microglia-specific enhancer in the human *BIN1* gene, which contains the AD-risk variant rs6733839 [67]. A more recent study predicted the risk variant rs6733839 to facilitate the binding of the transcription factor MEF2C to the *BIN1* enhancer in microglia, increasing *BIN1* expression [68]. Thus, the AD association signal at BIN1 appears to be microglial cell-type-specific.
Specific BIN1 isoforms might participate in divergent functions in relation to membrane dynamics, including endocytosis. Neuronal BIN1 regulates synaptic vesicle release [5] and limits the inter-neuronal tau spread in cultured neurons by regulating endocytic uptake of pathogenic tau [10]. Compared to neuronal BIN1 isoforms, mouse brain microglial BIN1 and human iPSC-derived microglial BIN1 isoforms lack the central CLAP domain, a region conserved between BIN1 and its homolog Amphiphysin 1, which contains the sites for clathrin and AP2 adaptor binding [69]. The CLAP domain is important for BIN1’s function in clathrin-mediated endocytosis; however, all microglial BIN1 isoforms have an SH3 domain, which can interact with the proline-rich domain of dynamin I [70]. Thus, a role for microglial BIN1 in endocytosis could not be excluded solely based on the lack of the CLAP domain. In non-neuronal cells, the depletion of BIN1 does not impede transferrin uptake by endocytosis but rather delays endocytic recycling [71, 72]. Our finding that the loss of BIN1 expression has little effect on microglial phagocytosis shows congruence with a previous study that assessed phagocytosis in *Bin1* KO macrophages and found that BIN1 did not have a functional role in endocytosis or phagocytosis in these immunoregulatory cells [71]. The inclusion of exon 13 (referred to as exon 12A in earlier publications) and exon 17 sequences in a subset of microglial *Bin1* transcripts (albeit at low frequency) may have implications for cell cycle regulation. Indeed, it has previously been reported that the inclusion of exon 13 abrogates BIN1’s binding to the transcription factor E2F1, inhibiting cell cycle progression [73, 74]. Furthermore, exon 13 contains a class I SH3-binding motif (PxxP), which can engage in an intramolecular interaction with BIN1’s own SH3 domain, thereby sequestering its interactions with cMYC [75], as well as potentially impeding interactions with other SH3 domain-dependent partners (e.g., dynamin and tau). Additionally, exon 17 encodes half of the c-MYC binding motif of BIN1, which regulates c-MYC-mediated transformation and apoptosis [76]. The microglia-specific functions of individual BIN1 isoforms, including the minor isoforms containing exons 13 and 17, presents an exciting area for future functional investigations.
Results of our neuroinflammatory transcriptional profiling indicate that BIN1 is a homeostatic microglial regulator that has a non-redundant role in the activation of immune responses upstream of the transcription factor PU.1, which is crucial for microglial viability [77]. PU.1 is a master regulator of microglial gene expression and transition to DAM phenotypes [32, 78–81]. Moreover, PU.1 regulates the expression of several AD-related microglial genes [32], and lower PU.1 expression in myeloid cells has been reported to delay AD onset [82]. Importantly, we have shown that BIN1 regulates *Sfpi1*, which codes PU.1. Interestingly, our consensus in vitro and in vivo finding that BIN1 did not affect microglia numbers suggests that BIN1 function might not be essential for microglial maintenance and survival. Overall, our finding that BIN1 positively regulates PU.1 transcription may suggest that BIN1 expression could be a significant determinant of microglial phenotype and pathology outcomes, particularly in AD, a hypothesis that warrants future investigations.
A limitation of our in vivo model system relates to the inherent *Cx3cr1* haploinsufficiency in *Cx3cr1*<sup>CreER</sup> mice which by itself is known to impact microglia via premature upregulation of an aging transcriptomic phenotype, inclusive of some disease-associated microglial genes observed in AD pathology [83]. This is exemplified by the differences between *Cx3cr1*<sup>CreER</sup> mice and the WT
equivalent (\textit{Bin1}^{fl/fl}) group. This effect of \textit{Cx3cr1} haploinsufficiency may partly explain some lack of concordance between in vitro and in vivo effects of \textit{Bin1} loss in microglia observed in our studies. Differences in responses between primary post-natal microglia in culture versus adult microglia in their native state in the brain, as well as direct effects of LPS on microglia in vitro, and indirect effects of LPS on microglia in vivo, may have also contributed to differences between the in vitro and in vivo experimental paradigms. Despite these differences, we observed several LPS-induced inflammatory genes and pathways that were BIN1-dependent in both model systems (Fig. 7A and D). This consensus analysis of our in vitro and in vivo transcriptomic findings identified a novel role for BIN1 in regulating the type 1 interferon response in microglia. We found that manipulating BIN1 in microglia impacted the expression of interferon regulatory factors (IRFs). IRFs are a family of transcriptional regulatory proteins that translocate to the nucleus in response to signalling events triggered by pathogen recognition receptors. Nuclear-translocated IRFs then regulate the expression of distinct groups of genes involved in immune responses and immune cell development. For example, IRF1, IRF5, and IRF8 play essential roles in proinflammatory responses [84–88], whereas IRF2 and IRF4 regulate anti-inflammatory responses [89]. IRF8 is a critical regulator of microglial motility [90], and IRF7 and IRF8 regulate microglial homeostasis and reactivity [87, 91]. IRF7 is a master signaling regulator of the interferon-dependent immune response [92]. The interferon signaling pathway is activated concomitantly with neuroinflammation in multiple mouse models of AD amyloid pathology [93]. Moreover, IRF7 expression in the human brain is highly correlated with AD clinical dementia, Braak score, and neuritic amyloid burden [93]. In our in vitro studies, we found that loss of BIN1 in microglia decreased expression of IRF1 and IRF7 genes without affecting IRF, IRF3, IRF4, and IRF8 expression. In vivo, loss of microglial BIN1 dampened the upregulation of IRF7 by systemic LPS, mirroring in vitro findings, providing a link between BIN1 function and type 1 interferon signaling in microglia.
Our results further show that \textit{Ifitm3} – one of the genes stimulated by type I interferons, as well as by proinflammatory cytokines that are critical mediators of the host innate immune response, including IL-1b, IL-6, and TNF [35] – is positively regulated by BIN1, both in vitro and in vivo. A recent publication found IFITM3 gene networks to be enriched in tau tangle-containing neurons and peripheral mononuclear cells from AD patients [38]. Expression of IFITM3 is also upregulated in microglia of a transgenic model of AD amyloid pathogenesis [33, 94]. In addition, IFITM3 is upregulated in a transient ‘interferon responsive’ microglial subset that expands during cortical remapping in a partial whisker lesion model. In this microglial population, IFITM3 localised to early phagosomes and was found necessary for phagosome maturation [94]. Interestingly, IFITM3 is necessary for lysosome acidification in macrophages [34, 35]. Further, lysosomes in homeostatic microglia are weakly acidic (~pH6) compared to peripheral macrophages (~pH5), and inflammatory activation causes acidification of microglial lysosomes, allowing them to degrade fibrillar Aβ [95]. Thus, an investigation into the functional role of IFITM3 in microglial lysosomes is imperative to elucidate pathology-specific cellular functions regulated by BIN1.
Of crucial importance, several genes transcriptionally regulated by BIN1 both in vitro and in vivo have been independently linked to AD pathogeneses. In particular, BIN1 positively regulates the transcription of critical AD-related genes (including \textit{Apoe}, \textit{Trem2}, and \textit{Tyroph}) under homeostatic conditions. This regulatory interaction between BIN1 and other AD-associated genes illustrates the complexities of multi-aetiological disorders and the challenge of pinpointing specific genetic variations which account for the entire spectrum of pathologies associated with AD. However, BIN1’s involvement in both homeostasis- and inflammation-specific signal regulation suggests that BIN1 may act as a central regulator of microglial activation status, with implications for mediating the kaleidoscope of DAM transcriptional profiles. BIN1’s known function in membrane remodelling and endocytic trafficking is consistent with such a broad role in regulating phenotypic changes. Indeed, this is exemplified by our findings that BIN1 regulates surface expression of CD11c in response to LPS administration, independent of \textit{Itgax} transcript levels (assayed in from the same FACS-isolated cell samples). Unravelling the potential co-operative role(s) played by BIN1 and microglial surface receptors in DAM transformation presents a crucial area for future investigations. However, BIN1’s relationship with surface receptors appears more complex than the singular function of endocytosis or endosome recycling, as exemplified by our findings of CX3CR1 dysregulation.
Despite some limitations due to the loss of one functional \textit{Cx3cr1} allele, by utilising the \textit{Cx3cr1}^{Cre} driver line, we fortuitously found that BIN1 counteracts changes elicited by \textit{Cx3cr1} haploinsufficiency, demonstrating BIN1’s involvement with another central regulator of microglial function. Compared with \textit{Bin1}^{fl/fl} mice having normal \textit{Cx3cr1} expression, \textit{Cx3cr1}^{CreER} mice exhibited an exaggerated response to systemic LPS challenge, consistent with prior observations [96]. As \textit{Cx3cr1} is downregulated during Stage I DAM transition [25], the microglia in the \textit{Cx3cr1}^{CreER} driver line may be primed
towards DAM transition. When *Bin1* was deleted in *Cx3cr1*^CreER^ mice, we observed an attenuation of the effect caused by *Cx3cr1* haploinsufficiency. This finding suggests that BIN1 may serve as a mediator of CX3CR1 receptor activation in the CX3CL1 (fractalkine)-CX3CR1 signaling axis. This conclusion is supported by the microglial cell population data showing a significant LPS-induced increase of DAM CD11c^+ (CD11b^+CD45^int^) in *Cx3cr1*^CreER^ mice, which is abrogated following the deletion of *Bin1* alleles in microglia. Our *in vivo* transcriptional dataset revealed *Bin1* to regulate gene transcripts in a manner inverse to *Cx3cr1*. Ongoing investigations of microglia-specific BIN1 deletion using the *Tmem119*^CreER^T2 driver [97] in models of AD pathologies will help determine whether microglial BIN1 may function to protect against both amyloid and tau aggregations.
**Conclusions**
Our study demonstrates that BIN1 regulates crucial elements of inflammatory response in microglia. Importantly, key characteristics of microglial phenotypic transition, including the upregulation of *Ifitm3* and surface expression of CD11c, are BIN1-dependent. We conclude that BIN1 expression is central for appropriate microglial responses to CNS challenge, and that AD risk may arise through impaired BIN1 functionality in microglia.
**Abbreviations**
Aβ: Amyloid-β; AD: Alzheimer’s disease; ANOVA: Analysis of variance; BAR: BIN/ amphiphysin/Rvs binding region; BIN1: Bridging integrator 1; cKO: Conditional knockout; CLAP: Clathrin-associated protein binding region; DAM: Disease-associated microglia; FACS: Fluorescence-activated cell sorting; FDR: False discovery rate; iPSC: Induced pluripotent stem cells; iMG: Induced microglial-like cell; IRFs: Interferon regulatory factors; Iso: Isoform; KD: Knockdown; LOAD: Late-onset Alzheimer’s disease; LPS: Lipopolysaccharide; MACS: Magnetic-activated cell sorting; MAGMA: Multi-marker analysis of genomic annotation; PC: Principal component; SH3: SRC homology 3 domain; siRNA: Small interfering RNA; tSNE: T-distributed stochastic neighbor embedding; WT: Wild-type.
**Supplementary Information**
The online version contains supplementary material available at https://doi.org/10.1186/s13024-022-00535-x.
**Additional file 1: Fig. S1.** BIN1 expression in mouse and human microglia from transcriptomic and proteomic datasets. **(A-B)** BIN1 transcript and protein levels in brain cells reported in large-scale datasets. **(A)** Transcript abundances from purified neural cells were described by Zhang et al. [16]. OPC, oligodendrocyte precursor cells; NF Ol, newly-formed oligodendrocytes; Myel Ol, myelinating oligodendrocytes; End, endothelial cells. **(B)** Comparison of protein abundance data (log2 transformed abundance values from label-free quantitative studies) from purified mouse neural cell types [20]. **(C)** A comparison of microglial protein levels of BIN1 (percentile rank abundance) between humans (aged post-mortem human brain-derived microglia) and several mouse models. The plotted data was compiled from several independent quantitative mass spectrometry datasets: CD11b+ magnetic-activated cell sorting (MACS) from 6 to 7-month-old female C57BL/6J mice that received vehicle or LPS (4 daily i.p. doses), or a transgenic mouse model of AD pathology (5XFAD); CD11b+ microglia from 3-mo-old C57BL6J mice purified by MACS, or fluorescent activated cell sorting (FACS), and immortalised microglial BV2 cells (untreated or LPS-treated for 24 h) [26, 98, 99]. **(D)** Single nucleus RNA sequencing data demonstrates the high level of BIN1 transcripts found in microglia and oligodendrocytes in fresh-frozen post-mortem human brain tissue [100]. **(E)** RNA sequencing mRNA abundance (log2 transformed) from isolated human microglia across different age groups shows high-level BIN1 mRNA abundance in microglia across the life span in the human brain [101].
**Additional file 2: Fig. S2.** Exon 11 splicing in microglia. **(A)** RT-PCR across exon 11 found no inclusion of exon 11 in FACS-isolated microglia from mouse brain, with no change in splicing following LPS injections (left). iMG cells differentiated from human iPSCs showed negligible inclusion of exon 11 (right). Some low-level inclusion of exon 11 is evident in the grey matter sample of human post-mortem brain tissue. **(B)** Schematic of BIN1 exons and primer locations for RT-PCR amplification across exon 7, exon 11, and the CLAP domain / exon 17. The strategy used to discern alternate splicing of exons 13–17 is indicated. The four mouse microglial Bin1 isoforms identified in this study are depicted at the bottom. BAR, the BIN-amphiphysin/Rvs domain; PI, the phosphoinositide binding motif (encoded by the muscle-specific exon 11), CLAP, the clathrin and AP2 binding domain, SH3, the Src homology 3 domain.
**Additional file 3: Fig. S3.** *Bin1* siRNA treatment of primary microglia dysregulates DAM gene transcripts without affecting cell viability. CD11b+ enriched primary mouse microglia (p0-3) were cultured for 48h in the presence of either sham siRNA or Bin1 siRNA (equimolar concentrations). **(A)** Cell viability within the CD45+ microglia population was assessed by flow cytometry (Live/Dead Fixable Blue viability dye). *N = 3* independent experiments were performed per condition. **(B)** Bin1 transcript levels (NanoString) increase following LPS stimulation of cultured microglia. **(C)** Volcano plot showing key genes differentially expressed following Bin1 KD. **(D)** Transcript expression of key AD-related microglial genes are dysregulated following the loss of Bin1 expression, an effect augmented by LPS-induced inflammatory signaling.
**Additional file 4: Fig. S4.** Transcript cluster analysis of in vitro dataset demonstrates the extent of transcriptional dysregulation by *Bin1* KD in primary cultured microglia. **(A)** Volcano plot of transcript expression following LPS exposure identifies several AD- and DAM-related genes affected by this endotoxin. The color scheme depicted is based on microglial gene co-expression module assignment, as described in Rangaraju et al. [21]. **(B)** Volcano plot illustrating genes regulated by BIN1 following LPS exposure highlights several inflammatory genes dysregulated by Bin1 siRNA. **(C-F)** Gene ontology expression analysis identified important cellular functions affected by misexpressed gene clusters.
**Additional file 5: Fig. S5.** Flow cytometry gating strategy for mouse brain-isolated microglia, weight, and temperature analysis during LPS injections. **(A)** Cells isolated from mouse brains were gated by scatter (single mononuclear cells) and fluorescence (CD11b+CD45^int^) to sort microglial populations. **(B-C)** LPS-injected mice lost significant weight during injections. Reduced Cx3cr1 expression (in Cx3cr1^CreER^) augmented the LPS-induced weight-loss recorded in control (Bin1^f/f^) animals, which was attenuated by the additional deletion of microglial Bin1 (Cx3cr1^CreER^Bin1 cKO). **(D-E)** LPS had no effect on body temperature before or after injection. **(F)** Immunofluorescence staining of Bin1^f/f^ mouse brains suggests that peripheral LPS injections did not affect the microglial expression or localization of BIN1. **(G)** NanoString analysis of mRNA transcripts found no change in Bin1 expression following LPS injections. **(H)** Relative levels of Bin1 iso10 mRNA transcripts quantified from FACS-isolated microglia, following saline or LPS injections.
**Additional file 6: Fig. S6.** Deletion of microglial *Bin1* does not impact cell morphology. **(A)** Following the deletion of *Bin1* from microglia (*Cx3cr1*^CreER^Bin1 cKO), no obvious change in microglial morphology was observed. There didn’t seem to be any effect on LPS administration. **(B)** Quantification of FraClac hull and circle morphometric analysis of microglia from LPS-injected mice. Microglia in the primary somatosensory cortex (SSp) of Cx3cr1^CreER^Bin1 f/f KO mice had larger spine ratios than Cx3cr1^CreER^ control mice. *, p < 0.05; by Mann-Whitney U test. **(C)** Representative images of data presented in b. All data plotted as mean ± SEM.
**Additional file 7: Fig. S7.** Summary of in vivo transcriptional changes and cytokine production. (A-B) Genes which are positively (A) and negatively (B) regulated by BIN1 (i.e., decrease and increase respectively with Bin1 knockout) are summarised from the in vivo NanoString dataset by raw transcript counts (top panel) and normalized expression (relative to Bin1\textsuperscript{+/+} as the WT equivalent; bottom panel). (C) Summary of cytokine expression in brain lysates (measured by Luminex). Data plotted as mean ± SEM.
**Additional file 8: Fig. S8.** Whole-brain qRT-PCR analysis of selected homeostatic- and DAM-related genes, and master myeloid-regulating transcription factor. Raw dataset for the analysis summarised in Fig. 8A. Transcript levels of genes encoding homeostatic proteins (P2ry12, Tmem119), DAM proteins (Itgax, Cst7, Cd68, Trem2, Spp1), and transcription factor (Sfp1) were analysed by qRT-PCR. With the exception of the DAM-related gene Spp1, all were upregulated following LPS stimulation in a BIN1-dependent manner. *, \( p < 0.05 \); **, \( p < 0.01 \); by unpaired t-test. Data plotted as mean ± SEM. *, \( p < 0.05 \).
**Additional file 9: Fig. S9.** Generation of BV2 KO microglia lacking BIN1 expression by CRISPR/Cas9 gene editing. (A) Lentiviral constructs expressing a sgRNA targeting a region within the \textit{Bin1} invariant exon 3 (KO) or a non-target sgRNA were used to generate stably transduced pools of BV2 KO and control (WT) cells. Two independent pools of WT and KO were further characterized. Sequencing (using a reverse primer) across the target sequence of the two KO pools as well as the sequences of individual cloned inserts from the PCR products are aligned to \textit{Bin1} exon 3 sequence. Numbering is based on the RefSeq NM_009666.2. (B) WT control and Bin1 KO pools retain similar morphology. (C) Immunoblot analysis demonstrates that stable \textit{Bin1} KO BV2 pools do not express BIN1 protein under basal conditions or following LPS stimulation.
**Additional file 10: Supplementary Tables S1-6.**
**Acknowledgments**
We like to thank Ha-Na Shim and Jeffrey Lenz for their assistance in mouse colony maintenance and histology.
**Authors’ contributions**
AS, SRamesha (SRA), GT, and SRangaraju (SRu) designed all in vivo experiments and analysed data. SRu, TG, PK, and SRu designed and performed all in vitro primary culture experiments and analysed data. SRA and SRu performed NanoString assays and analyzed the data. AS, MP, and GT performed immunoblabelling, image acquisition, and image analyses. AS and SW performed immunoblots and qRT-PCR. MH, XZ, LC, and AS performed mouse breeding and injections. MH, AS, and CS performed FACS isolation of mouse brain microglia. SRA and SRu analyzed flow cytometry data. AK and JD generated human iPSC and performed iMG differentiation. SW generated CRISPR-edited BV2 cells. SW, DBA, and AS performed BV2 experiments. SB and LBW performed Luminex and MSD assays. SRu and GT performed bioinformatic analyses. AS, GT, and SRu wrote the manuscript, and LBW and JD edited the manuscript. All authors read and approved the final manuscript.
**Funding**
This work was supported by National Institutes of Health Grants RF1 AG054223 and RF1 AG056061 (to G.T.), R01 NS114130-01A1, R01 AG071587, and K08 NS099474 (to S.R.), R01 AG063175 (to J.D. and G.T.), R01 MH106575 (to J.D.), and R01 R01NS115994 (to L.W.), and National Science Foundation CAREER 1944053 (to L.W.).
**Availability of data and materials**
All data generated and analysed during this study are included in this published article and its supplementary information files.
**Declarations**
**Ethics approval and consent to participate**
All animal experiments were approved and conducted in accordance with IACUC regulations at Emory University and the University of South Florida.
**Consent for publication**
Not applicable.
**Competing interests**
The authors declare that they have no competing interests.
**Author details**
\(^1\)Byrd Alzheimer’s Center and Research Institute, University of South Florida, Tampa, FL 33613, USA. \(^2\)Department of Molecular Medicine, Morsani College of Medicine, University of South Florida, Tampa, FL 33620, USA. \(^3\)Department of Neurology, Emory University, Atlanta, GA 30322, USA. \(^4\)Center for Psychiatric Genetics, North Shore University Health System, Evanston, IL 60201, USA. \(^5\)Parker H. Petit Institute for Bioengineering and Bioscience, Wallace H. Coulter Department of Biomedical Engineering, and Georgia W. Woodruff School of Mechanical Engineering, Georgia Institute of Technology, Atlanta, GA 30332, USA. \(^6\)Department of Psychiatry and Behavioral Neuroscience, University of Chicago, Chicago, IL 60637, USA.
**Received:** 23 November 2021
**Accepted:** 30 March 2022
**Published:** 7 May 2022
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Zukal, Jan; Bandouchova, Hana; and Brichta, Jiri, "White-nose syndrome without borders: Pseudogymnoascus destructans infection tolerated in Europe and Palearctic Asia but not in North America" (2016). KIP Articles. 5666.
https://digitalcommons.usf.edu/kip_articles/5666
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White-nose syndrome without borders: *Pseudogymnoascus destructans* infection tolerated in Europe and Palearctic Asia but not in North America
Jan Zukal\textsuperscript{1,2,*}, Hana Bandouchova\textsuperscript{3,*}, Jiri Brichta\textsuperscript{3}, Adela Cmokova\textsuperscript{4}, Kamil S. Jaron\textsuperscript{1}, Miroslav Kolarik\textsuperscript{4}, Veronika Kovacova\textsuperscript{3}, Alena Kubátová\textsuperscript{5}, Alena Nováková\textsuperscript{4}, Oleg Orlov\textsuperscript{6,7}, Jiri Pikula\textsuperscript{3}, Primož Presetnik\textsuperscript{8}, Jurģis Šuba\textsuperscript{9}, Alexandra Zahradníková Jr.\textsuperscript{10} & Natália Martínková\textsuperscript{1,11}
A striking feature of white-nose syndrome, a fungal infection of hibernating bats, is the difference in infection outcome between North America and Europe. Here we show high WNS prevalence both in Europe and on the West Siberian Plain in Asia. Palearctic bat communities tolerate similar fungal loads of *Pseudogymnoascus destructans* infection as their Nearctic counterparts and histopathology indicates equal focal skin tissue invasiveness pathognomonic for WNS lesions. Fungal load positively correlates with disease intensity and it reaches highest values at intermediate latitudes. Prevalence and fungal load dynamics in Palearctic bats remained persistent and high between 2012 and 2014. Dominant haplotypes of five genes are widespread in North America, Europe and Asia, expanding the source region of white-nose syndrome to non-European hibernacula. Our data provides evidence for both endemicty and tolerance to this persistent virulent fungus in the Palearctic, suggesting that host-pathogen interaction equilibrium has been established.
Emerging wildlife infections are a threat to global biodiversity\textsuperscript{1}, yet the emergence and transmission of such infectious diseases may also be a function of ecosystem quality and biodiversity\textsuperscript{2}. Moreover, anthropogenic disturbance and introductions have been highlighted as contributing considerably to such disease outbreaks\textsuperscript{3,4}. The majority of emerging wildlife pathogens are of viral origin but fungal infections have also been recognised across a diverse range of taxa, including plants and poikilothermic animals\textsuperscript{5}. Relatively few fungal species cause severe diseases in mammals due to their high body temperature and effective immune system\textsuperscript{6–7}.
Prevalence of pathogens may be high in bat populations\textsuperscript{8,9}. Despite this, bats have been reported to survive infections that are lethal to other taxa\textsuperscript{10–12}. Bat’s capacity to carry pathogens may result from its ability to tolerate damage caused by the agent or the associated immune response\textsuperscript{13–15}. Understanding the mechanisms that...
underlie any trade-off between tolerance and resistance to infectious agents in reservoir hosts is of utmost importance for effective disease control\textsuperscript{16}.
Most bats in temperate regions enter seasonal hibernation, at which time they reduce their metabolic rate and decrease body temperature until it approaches the ambient temperature of the hibernaculum, which may alter immune response to pathogens\textsuperscript{17,18}. During hibernation, bats are vulnerable to infection by the psychrophilic fungus \textit{Pseudogymnoascus destructans} [formerly \textit{Geomyces destructans}]\textsuperscript{19}, which emerged as a novel pathogen in eastern North America in 2006\textsuperscript{20}. The \textit{P. destructans} fungus is the causative agent of white-nose syndrome (WNS)\textsuperscript{20–23}. Considered an epidemic of major conservation concern in North America, WNS is responsible for an unprecedented decline in bat populations\textsuperscript{24–26}. WNS combines some of the worst possible epidemiological characteristics, including a highly virulent pathogen\textsuperscript{23,27} with density- and frequency-dependent transmission\textsuperscript{28}, an environmental reservoir\textsuperscript{19}, long-term persistence in hibernacula\textsuperscript{29,30} and susceptibility of multiple hosts\textsuperscript{19,26,31}.
The origin of WNS in North America remains unknown and current research focuses on identifying the infectious agent’s source and identifying whether the agent is an introduced pathogen. Six main lines of evidence support introduction of WNS into North America: 1) Fungal communities associated with bats and their hibernacula in eastern North America comprise a diverse range of \textit{P. destructans} allies\textsuperscript{22,32}; phylogenetic evaluation, however, indicates that none of these is closely related to \textit{P. destructans}\textsuperscript{22}. 2) Previous studies have demonstrated clonal dispersal of a single \textit{P. destructans} genotype among WNS-infected bats in the United States\textsuperscript{33,34}. 3) Spread of WNS in North America follows a clear invasion front with varying survival rate since first appearance of the disease\textsuperscript{24,35–37}. 4) Presence of \textit{P. destructans} has been confirmed in many European countries\textsuperscript{38–41} but with no reports of mass mortality\textsuperscript{38}. 5) European \textit{P. destructans} isolates are pathogenic for North American bats\textsuperscript{33}. Further, virulent skin infections producing focally severe lesions pathognomonic for WNS have been documented in European bats under natural infection conditions\textsuperscript{42}. 6) While only one heterothallic fungal mating type has been recorded in North American \textit{P. destructans} populations, two types have been found coexisting in European hibernacula. Effective recombination during sexual reproduction results in genetic variability and may be linked with virulence\textsuperscript{43}. These indirect sources of evidence tend to support the introduced pathogen hypothesis, suggesting WNS may have originated outside of North America\textsuperscript{22,23,43,44}. Comparative studies between North America and Europe have been proposed to explain the origin and differential manifestation of the fungal infection\textsuperscript{3,40,42,45}.
Although some authors speculate on a non-European origin\textsuperscript{4,25}, Europe is believed to be the likely source of WNS\textsuperscript{34}. Supporting evidence for long exposure to the WNS fungus based on old European photographs, which appear to show a white cutaneous fungal infection\textsuperscript{38,40}, lacks specificity for WNS. Another dermatophyte, \textit{Trichophyton redelli}, produces a similar gross appearance in hibernating bats\textsuperscript{46} and the photographs might represent either. On the contrary, presence of WNS in multiple and diverse hosts\textsuperscript{31} indicates that the WNS fungus could persist across their ranges in the Palearctic.
To date, WNS diagnostic skin lesions have only been reported from the Czech Republic, Europe, with almost half of all species being WNS positive and prevalence based on histopathology reaching 55% in bats emerging from hibernacula in spring\textsuperscript{4,42}. Occurrence of WNS in distantly related bat species with diverse ecologies, however, suggests the pathogen is a generalist and that all bats hibernating within the distribution range of \textit{P. destructans} may be at risk of infection\textsuperscript{31}. If we assume that \textit{P. destructans} range expansion and its concurrent WNS epidemic occurred unnoticed in Europe in the past, we expect that WNS should be found at any site in Europe with conditions favourable for the pathogen and could extend to non-European hibernacula of the Palearctic region. We tested the following four hypotheses. First, \textit{P. destructans} is present in European and non-European Palearctic hibernacula and, if the fungus is present in a hibernaculum, bats would test positive for WNS under histopathology. Second, an endemic steady-state of \textit{P. destructans} infection in the Palearctic would be reflected in a persistent high prevalence among bats with no associated population declines. Third, given that the differences in population size changes in WNS-positive regions\textsuperscript{24,38} are explained as WNS resistance in Europe, Palearctic bats will display a lower pathogen load and smaller size of cupping erosions diagnostic for WNS than Nearctic species. Fourth, in regions with endemic pathogen occurrence, \textit{P. destructans} load will be influenced by geographic location, sampling date and bat community structure.
**Results**
**WNS in the Palearctic.** We sampled and examined bats from sites in geographically distant regions (the Czech Republic, Slovenia, Latvia and Russia; \( n = 481 \)) to assess occurrence of WNS in the Palearctic (Table 1, Supplementary Table S1). We found WNS-positive bats from multiple species at all sites, including the West Siberian Plain in Russia. At each site, all of the following criteria categorised the site as WNS positive: suspected fungal growth (Fig. 1), characteristic curved conidia of \textit{P. destructans} observed on an adhesive tape imprint (Fig. 2A), \textit{P. destructans} confirmed by DNA sequencing and qPCR using a species-specific probe, and definitive diagnosis confirmed through histopathology of biopsy punches from wing membrane lesions targeted by UV trans-illumination (Fig. 2B).
Histopathological findings matching WNS diagnostic criteria were present in 100 bats of 13 different species (Table 1). Two species were newly identified as positive for WNS, \textit{Miniopterus schreibersii} and \textit{Rhinolophus euryale}. Species-specific prevalence, using qPCR to detect \textit{P. destructans} and UV trans-illumination to detect lesions indicative of WNS, ranged from 64 to 100% (overall prevalence = 83.1%) and 14 to 100% (overall prevalence = 51.9%), respectively (Table 1).
In order to evaluate \textit{P. destructans} genetic variability, we sequenced six loci resulting in 254 new sequences. Two alleles were found in \textit{TUB2}, \textit{MAT1-1-1}, \textit{MAT1-2-1} and \textit{CAM} loci, four alleles in \textit{TEF1α} and three in \textit{ITS} (Fig. 3). The most frequent alleles from all loci were found in both European and Asian \textit{P. destructans} isolates. In \textit{ITS} and \textit{TEF1α} from Asia, we sampled isolates with one substitution difference from the most frequent allele. The dominant haplotype from the concatenated sequence of four genes (\textit{TUB2}, \textit{CAM}, \textit{TEF1α}, \textit{ITS}) is widespread in North America, Europe and Asia (Fig. 3E). Three divergent concatenated haplotypes were found in the Czech
Republic and one local to Asian Russia. The *P. destructans* mating type proportion was 27 (*MAT1-1-1*) to 19 (*MAT1-2-1*) ($\chi^2 = 1.391, P = 0.238$).
**Quantitative comparison of WNS on bats.** The fungal load on qPCR-positive bats ranged from 0.21 pg to 3.41 µg across the surface of the left wing (Supplementary Fig. S1, see Table 1 for sample sizes). This range included fungal loads reported from Nearctic bat species (Supplementary Fig. S1). Log-transformed fungal load was not lower on Palearctic bats than on Nearctic bats (Wilcoxon $W = 68030, P = 1, n = 413$ and 247, respectively), even assuming that fungal load on Nearctic bats could vary up to ten-times due to the difference in sample collection method between continents (Wilcoxon $W = 50910, P = 0.484$).
In order to account for body size differences between Palearctic bat species, we used log-transformed fungal load per cm$^2$ of wing area (henceforth referred to as fungal load, unless specified otherwise). Fungal load differed significantly between regions (Kruskal–Wallis $\chi^2 = 94.2, P < 0.001; \text{Fig. 4}$) and species (Kruskal–Wallis $\chi^2 = 221.2, P < 0.001; \text{Fig. 5}$), with highest values recorded in the Czech Republic and two euryvalent bat species, *Myotis myotis* and *Myotis nattereri*, respectively. In frequently captured *M. myotis*, fungal load did not change between 2012 and 2014 (ANOVA: $F_{2,146} = 1.209, P = 0.301$). Prevalence dynamics of nine species captured in multiple years was statistically equal between years ($\chi^2$ test: $P > 0.05$; Czech Republic). The sampled regions contained multiple species with varying fungal loads (Fig. 5), and some species were present in multiple regions (Table 1). The observed difference of fungal load can be caused by a different set of species or different environmental conditions.
---
**Table 1. Prevalence of white-nose syndrome and *Pseudogymnoascus destructans* infection in bat species from the Holarctic region.** Screened = number of bats captured and examined by PCR (to detect the pathogen), UV light trans-illumination or histopathology (to detect WNS lesions). + = percentage of positive bats from the number screened by the method. NA = not available. Samples subjected for histopathology examination were suspect lesions selected under field conditions based on UV trans-illumination and thus prevalence on histopathology is not based on a randomized sample. It rather reflects qualitative information that WNS was confirmed in the species with histopathology.
Figure 1. Fungal growth on hibernating bats from Russia. (a) A hibernating cluster of pond bats *Myotis dasycneme* in a cave near Yekaterinburg, Russia, in May 2014. Black and white arrows indicate fungal growth on the muzzle and forearm, respectively. (b) A pond bat from the same hibernaculum showing visible fungal growths on the uropatagium, pelvic limb toes, plagiopatagium and the ears and muzzle (white arrows). Photo: Jiří Pikula.
Figure 2. White-nose syndrome on a pond bat *Myotis dasycneme* near Yekaterinburg, Russia, in May 2014. (A) Microscopic identification of the characteristic curved conidia of *Pseudogymnoascus destructans* (black arrow). (B) Invasive fungal growth penetrating the full-thickness of the wing membrane (black arrows), with several inflammatory cells (neutrophils) situated at both margins of the lesion (white arrows). (C) Packed fungal hyphae of cupping erosions (black arrows) sequestered by neutrophils (white arrows). (D) Histopathological finding from a WNS-positive Nearctic *Myotis lucifugus*, identical to that found in Palearctic Asia. Skin sections stained with periodic acid-Schiff stain.
In sampled regions. Therefore, we separated the effect of the two variables on fungal load by correcting for the random effect of species and region. This had no impact on significance of the comparison between regions or species. The phylogenetic signal of mean species fungal load was significant (Blomberg’s $K = 0.892$, $P = 0.002$), meaning that closely related taxa had more similar mean fungal loads in the Palearctic than expected by chance.
Fungal load was significantly correlated with the number of WNS lesions (Spearman’s rank correlation: $r = 0.61$, $P < 0.001$). Phylogenetic generalised least-squares, which accounts for intra-specific variability and
Figure 3. Median-joining networks for *Pseudogymnoascus destructans* DNA sequences. Node centroid distances correspond to the number of substitutions between haplotypes and the node size to the number of isolates sharing the haplotype. Isolate origin is signified through different colours based on the inset map. The map was modified from http://www.amcharts.com/visited_countries/ (last accessed on 9 October, 2015). (A) *TUB2* (*n* = 46), (B) *ITS* (*n* = 203), (C) *CAM* (*n* = 47), (D) *TEF1α* (*n* = 51), (E) sequences concatenated with *TUB2*, *ITS*, *CAM* and *TEF1α* (*n* = 34); haplotypes pooled according to the available sequence and gaps treated as missing data, (F) *MAT1-1-1* (*n* = 27), (G) *MAT1-2-1* (*n* = 19).
Figure 4. Fungal load and number of WNS lesions in Europe (Czech Republic, Latvia, Slovenia) and in Asia (Russia). Fungal load is quantified as *P. destructans*-specific DNA per cm$^2$ of wing area (established through quantitative PCR) and number of WNS lesions is counted on the same wing (using UV light trans-illumination).
Species phylogenetic relationships, indicated that the number of WNS lesions increased with increasing fungal load across bat diversity in this study (intercept = −0.058, slope = 0.177; Fig. 6). No significant phylogenetic signal was detected in the mean number of WNS lesions by species (Blomberg’s $K = 0.511$, $P = 0.073$).
Microscopic WNS cupping erosion width ranged between 28.6 and 397.2 μm (median = 86.34 μm, $n = 105$) and depth between 11.3 and 91.8 μm (median = 31.29 μm), this also being the WNS-lesion size range detectable photographically as individual spots using UV trans-illumination. Size of WNS lesion (log-transformed) did not differ significantly between species (Kruskal–Wallis $\chi^2 = 20.7$, $P = 0.079$, $n = 14$ species across the Holarctic;
Fig. 7, see Table 1 for sample sizes). Phylogenetic signal for mean species-specific WNS lesion size was also not significant (Blomberg’s $K = 0.448$, $P = 0.177$) and there was no significant difference observed between Palearctic and Nearctic bats (phylogenetic ANOVA: $F = 0.43$, $P = 0.292$).
The number of WNS lesions in animals positive over UV ranged from 1 to 805 (median = 13) and differed significantly between Palearctic regions (log-transformed per cm$^2$; Kruskal–Wallis $\chi^2 = 33.6$, $P < 0.001$; Fig. 4) and species (Kruskal–Wallis $\chi^2 = 76.7$, $P < 0.001$; Fig. 5; correction did not influence significance). The fungal load from UV-negative individuals (median = $3.78 \times 10^{-5}$ µg) overlapped that from UV-positive individuals (median = $7.46 \times 10^{-4}$ µg; Fig. 8).
Comparison of AIC values indicated that the best fitting model for fungal load across regions included geographic coordinates (95% confidence interval of parameter estimates: longitude: $-0.07 – (-0.03)$, latitude: 0.16–0.36), sampling date (0.002–0.02) and structure of common bat species community found in the respective region ($-3.86 – (-2.24)$) (Supplementary Table S2). On the other hand, disease intensity, quantified as number of WNS lesions, was best modelled using fungal load (0.18–0.28) and sampling date ($-0.007 – 0.0003$), though addition or removal of other variables did not change the relationship between WNS-lesion number and fungal load significantly (0.18–0.27). In both cases, species was treated as a random effect. Values predicted from the optimal model for both fungal load and number of WNS lesions were highest in the Czech Republic (Fig. 4). Lowest values were predicted in Slovenia and intermediate values in Latvia and Russia.
**Discussion**
Here we show WNS infection in Palearctic bat communities within and beyond the borders of Europe, greatly extending the distribution range of *P. destructans* and confirming its generalist nature. Furthermore, we confirm WNS skin lesions in two more bat species, belonging to families Mniotteridae and Rhinolophidae.
Histopathology of skin sections is presently considered the ‘gold standard’ for diagnosing WNS\(^{47}\). The microscopically identified WNS in bat species sampled in Russia was consistent with WNS histopathological criteria\(^{42,47}\). These included characteristic cup-shaped epidermal erosions, *P. destructans*-infected hair follicles, associated sebaceous glands and regional connective tissues, and invasive fungal growth throughout the wing-membrane thickness (Fig. 2). Our results demonstrate that *P. destructans* is virulent for Palearctic bats under natural infectious conditions, as previously shown in the Czech Republic\(^{31,42}\). Local invasiveness and WNS-lesion severity in wing membranes of bats collected in the Palearctic was comparable with that of Nearctic bats (Figs 2 and 8), with
Figure 6. Phylogenetic generalised least-squares for number of WNS lesions, dependent on fungal load and accounting for within-species variation and relatedness. The dotted line represents the linear regression without phylogenetic correction.
Figure 7. Variation in focal tissue invasiveness among hibernating bat species infected by *Pseudogymnoascus destructans*. A series of 80 periodic acid–Schiff stained sections from each bat's wing membrane biopsy were used to determine mean maximum size of WNS-diagnostic cupping erosions (log$_{10}$(µm$^2$)). See Table 1 for sample sizes.
Diagnostic features ranging from cupping erosions to full-thickness fungal invasion found on all continents. In our experience, detection of WNS-positive bats was greatly enhanced by the use of a UV lamp combined with non-lethal punch biopsies of suspected skin lesions\textsuperscript{35}. The effectiveness of this method enabled us to identify seven species as WNS-positive in multiple regions, i.e. *Myotis brandtii*, *Myotis daycyname*, *Myotis daubentonii*, *Myotis emarginatus*, *M. myotis*, *Eptesicus nilsoni* and *Plecotus auritus* (Table 1). As predicted\textsuperscript{31}, *M. schreibersii* and *R. euryale* were confirmed positive for skin lesions. These are thermophilic species that only hibernate in...
the northern part of their ranges. *Miniopterus schreibersii*, a long-distance migrant, forms large mixed colonies with other cave-dwelling bat species\textsuperscript{49} and such characteristics make the species another effective candidate for pathogen dispersal.
Theoretically, WNS spread is limited by conditions prevalent in underground hibernacula being favourable to *P. destructans* and presence of susceptible hibernating bats\textsuperscript{50}. *Pseudogymnoascus destructans*, being a generalist pathogen, could infect any bat species hibernating under the right microclimatic conditions and ecological and evolutionary differences in the hibernating bats would not pose a barrier\textsuperscript{31}. Distribution ranges of multiple WNS-positive bat species (*E. nilssonii, M. dasycneme, M. daubentonii, M. brandtii, P. auritus*) extend across Palearctic Asia and overlap with their sister species or ecological counterparts (e.g. *Myotis petax, Myotis sibiricus*). As bats can form multi-species clusters at hibernation sites, there is a good chance that *P. destructans* could switch host species to presently WNS-negative taxa (e.g. *Myotis ikonnikovi, M. petax, M. sibiricus*). This suggests that WNS may be present throughout the Palearctic where suitable environmental conditions occur and in all bat species that utilise such sites. In fact, a paper published ahead of print during review of this article corroborates our conclusions with one *M. petax* found positive for WNS in North China\textsuperscript{51}.
Given the tragic impact of WNS on bat biodiversity in North America\textsuperscript{24}, it is important to identify the source of possible introduction\textsuperscript{4}. However, *P. destructans* exhibits notoriously low genetic diversity in both the clonal North American populations\textsuperscript{33,34,43} and the sexually reproducing populations of Europe\textsuperscript{44}, effectively thwarting efforts to pinpoint the source region. Our study further exacerbates the enigma of where the North American *P. destructans* strain originates as the North American haplotype was found in all non-mating gene types in Palearctic Asia, thereby expanding the putative source region (Fig. 3). Additionally, the search for a source region should shift to markers with a faster mutation rate and better resolution for *P. destructans* phylogeography, as the low genetic variability in markers routinely used in fungal population studies indicates a relatively recent origin or expansion of the Palearctic population.
Theory suggests that if a disease is detectable at high prevalence it is probably mild and unlikely to be a major problem\textsuperscript{52}. Two methods were used to establish prevalence in this study: qPCR, used to quantify the pathogen on wing skin\textsuperscript{53}, and UV trans-illumination of the wing membrane, which enables detection of fluorescing lesions associated with WNS skin infection\textsuperscript{48}. Both methods provided comparable results of high prevalence, and, together with stable or increasing host population sizes\textsuperscript{54}, our data strongly suggest endemicity of *P. destructans* within Palearctic bat populations. Persistent high prevalence and pathogen load with absence of population declines in the Palearctic are in sharp contrast to the situation in the Nearctic. In Midwestern United States, high prevalence of *P. destructans* infection was followed by a decrease in number of hibernating bats\textsuperscript{55}. Some form of host-pathogen equilibrium, analogous to the amphibian chytrid fungus observed in post-decline frog communities\textsuperscript{56}, may already have occurred in the Palearctic but not in the Nearctic.
Pathogen load indicates both exposure to the infectious agent and suitability of the host for pathogen replication\textsuperscript{57}. *Pseudogymnoascus destructans* fungal load can be evaluated using swab samples from wing membranes\textsuperscript{53}. Although swabs do not sample fungus invasion deep in the wing tissue, our results show that fungal load sampled in this way is positively correlated with the number of WNS lesions (Fig. 6). Hence, fungal load from swabs may be assumed to approximate the total load associated with the skin infection. Fungal loads determined across the Palearctic were similar to those observed in Nearctic species (Supplementary Fig. S1). The swabbing technique used in the North American studies\textsuperscript{19,58,59}, however, does not allow standardisation of *P. destructans* load per cm\textsuperscript{2}.
and thus detailed statistical comparisons cannot be made. Nevertheless, fungal loads in Nearctic bats are similar to the observed fungal load of Palearctic bats (Supplementary Fig. S1), even if the former were underestimated ten-fold with the different swabbing technique.
In the Palearctic study area, fungal load differed regionally (Fig. 4) and between species (Fig. 5) with no reported mass decline in bat populations attributable to WNS\textsuperscript{38,54}. Fungal load increased with increasing northing and westing, sampling day (load increasing later in the year) and in regions where phylogenetically closely-related hibernating bats predominated (Fig. 4). The driving factor that best modelled the number of WNS lesions observed using UV trans-illumination in the Palearctic was the fungal load. Increasing fungal load positively correlated with disease intensity across species diversity indicates that hyphae are more likely to invade deep tissues and cause WNS lesions with heavy fungal growth on bat wings (Fig. 5). However, with overlap of fungal loads in UV-negative and UV-positive bats, no clear fungal load threshold defines the pathogen pressure where development of WNS lesions starts.
With persistent and similar fungal load (Supplementary Fig. S1) and cupping erosion size (Fig. 7) on bats from the Palearctic and the Nearctic, the difference in population size response is striking. While population sizes dropped dramatically under the WNS epidemic in the Nearctic\textsuperscript{24}, population size changes remained within normal inter-annual fluctuation levels in the Palearctic\textsuperscript{38,54,60}. Our data suggest that, once the hibernacula are contaminated by the fungus, Palearctic bats are exposed to high pathogen pressure and the infection is continuously present to a high level, i.e. the so-called hyperendemic condition. The difference in infection outcome is therefore a function of adaptation to pathogen pressure.
While reduction of pathogen load is a function of host resistance, the ability to limit the harm caused by a given load is a result of tolerance\textsuperscript{61,62}. These two alternative and complementary forms of defence may have profound effects on the epidemiology of infectious diseases and on host-pathogen coevolution\textsuperscript{62}. Resistance protects the host at the expense of the pathogen and tolerance saves the host from harm without direct negative effects on the infectious agent. Evolution of resistance, therefore, should also reduce the prevalence of the pathogen in host populations. On the other hand, tolerance is expected to have a neutral, or even positive, effect on prevalence of the pathogen. Lack of resistance to WNS infection in hibernating European bats has been demonstrated in 13 species\textsuperscript{3,12} that exhibit stable or increasing population sizes\textsuperscript{54}. Yet, prevalence of \textit{P. destructans}-positive bats reached 100% in the Palearctic. In light of the above arguments, it would appear that mechanisms promoting tolerance to \textit{P. destructans} infection are in operation in the area studied. Palearctic bat species tolerate comparable fungal loads and WNS-lesion size to their Nearctic counterparts suffering population declines. We hypothesise that the balance between tolerance and resistance mechanisms changes with transition of bats from hibernation to euthermia.
Our results provide evidence of \textit{P. destructans} and pathognomonic WNS skin lesions in hibernating bats sampled from the West Siberian Plain of Russian Asia and indicate endemicity of this virulent fungus in the Palearctic region. Data suggesting bat tolerance imply lowered risk following establishment of equilibrium in the host-pathogen interaction. The extensive spatial distribution of the agent may pose a threat, however, representing a continued source of introduction to other regions with naïve bats not yet exposed to the pathogen. Classical models employing the disease triangle concept suggest that the epidemiological outcome of an infection depends on determinants of the pathogen, host(s) and the environment. Alterations in any of these determinants may trigger shifts in the complex host-pathogen system, as seen here by infection tolerance in hibernating Palearctic bats.
**Methods**
**Material collection.** Between 2012 and 2014, we sampled 481 bats (15 species) at 20 sites in Slovenia, the Czech Republic, Latvia and Russia (West Siberian Plain, Asia; Table 1, Fig. 3). Samples were taken as late in the hibernation or as early in the post-hibernation season as possible (February–May) to minimise the impact of disturbance to specific bat species. Following capture, the wings, ears and muzzle were swabbed with a nylon (FLOQ Swabs, Copan Flock Technologies srl, Brescia, Italy) or cotton swab (Plain swab sterile plastic applicator, Copan) in a standardised manner in order to collect fungal biomass from the whole skin area for fungal detection (dorsal side of left wing only for qPCR). The bats were photographed over a 368 nm wavelength UV lamp and wing punch biopsies of suspect tissue collected in 10% formalin for histopathological examination. All bats were then released at the site.
WNS was diagnosed according to current standards\textsuperscript{47}, i.e. \textit{P. destructans} presence was confirmed with qPCR\textsuperscript{53} and selected orange-yellow spots observed over UV were sampled. A series of 80 periodic acid-Schiff stained sections embedded in paraffin were obtained from each wing membrane biopsy. These were then observed under an Olympus BX51 light microscope (Olympus Corporation, Tokyo, Japan). Fungal cell walls were stained magenta under the periodic acid-Schiff stain, which allowed measurement of cupping erosions packed with hyphae. Using cellSense Software tools (Olympus Soft Imaging, GmbH, Münster, Germany), we measured total area (size) of cupping erosions. Trans-illuminated photographs of the left wing membrane stretched over a UV lamp were used to manually enumerate yellow-orange fluorescing pinpoints indicative of WNS lesions\textsuperscript{48}, using the individual object counting tool of ImageJ\textsuperscript{63}.
Bats were considered WNS-positive if qPCR confirmed \textit{P. destructans} infection, wings exhibited characteristic UV fluorescence\textsuperscript{48} and cupping erosions packed with fungal hyphae or a full thickness fungal invasion of the wing membrane were observed under histopathology\textsuperscript{47}. Additional swabs taken from the wings and muzzle after sampling for qPCR were used for cultivation on Sabouraud dextrose agar plates and isolation of the fungus in pure cultures\textsuperscript{38}. Representative isolates were deposited at the Culture Collection of Fungi, Charles University in Prague, Czech Republic.
Field work and sampling in the Czech Republic was performed in accordance with Czech Law No. 114/1992 on Nature and Landscape Protection, based on permits 01662/MK/2012S/00775/MK/2012, 866/JS/2012 and 00356/KK/2008/AOPK issued by the Agency for Nature Conservation and Landscape Protection of the Czech
Republic. Experimental procedures were approved by the Ethical Committee of the Academy of Sciences of the Czech Republic (No. 169/2011). Sampling in Latvia was approved by the Nature Conservation Agency (No. 3.15/146/2014-N), in Slovenia by the Ministry of Environment and Spatial Planning of the Slovenian Republic, Slovenian Environment Agency (No. 35601-35/2010-6) and in Russia by the Institute of Plant and Animal Ecology, Ural Division of the Russian Academy of Sciences (No. 16353–2115/325). The authors were authorised to handle free-living bats according to the Czech Certificate of Competency (No. CZ01341; §17, Act No. 246/1992 Coll.) and a permit approved by the Latvian Nature Conservation Agency (No. 05/2014).
**DNA isolation.** Total DNA was isolated from swabs using the QIAamp DNA Mini Kit (Qiagen, Halden, Germany). Swabs were placed in tissue lysis buffer with proteinase K and incubated at 56 °C for two hours. Lysis buffer was added and the samples incubated for a further 10 min. After this step, we followed the Qiagen Buccal Swab Spin Protocol according to the manufacturer’s recommendations.
**Quantitative PCR.** We performed quantitative PCR\(^{53}\) (qPCR) using TaqMan® Universal Master Mix II with UNG (Life Technologies, Foster City, CA, USA). To optimise the PCR reaction, we added bovine serum albumin and Platinum® Taq DNA Polymerase (Life Technologies) in final concentrations of 0.05 mg/μl and 0.025 U/μl, respectively. We used both forward and reverse primers (0.3 μM each) and species-specific genus-specific fluorescently-labelled custom probes were used for quantification of the PCR product. The reaction mix was prepared on ice and three replicates were prepared for each DNA sample. We performed real-time PCR reaction on a LightCycler 480 PCR platform (Life Technologies) with initial inactivation at 50 °C for 2 min and a hot start at 96 °C for 10 min. Nine cycles with a denaturation step at 95 °C for 15 sec and annealing at 62 °C for 1 min were followed by 43 identical cycles with quantification detection. qPCR was finalised by dissociation at 95–60–95 °C for 15 sec each and cooling to 40 °C for 10 min. DNA isolated from CCF3937 culture\(^{33}\) and water were used as positive and negative controls and as concentration references for each run.
**Fungal load on Palearctic bats.** We calculated a DNA concentration calibration curve using a CCF3937 dilution series. Exact DNA concentrations (ng μl\(^{-1}\)) in the dilution series were determined using Qubit HS fluorometry via the manufacturer’s protocol. Effectivity of qPCR was 1.96. We used this dilution series to estimate the relationship between fungal load and qPCR cycle, calculating \(P.\ destructans\) DNA concentration in the sample using custom scripts in R\(^{64}\) with the equation \(\log(q_{DNA}) = 3.194 - 0.287\ Cp\) (\(R^2 = 0.9719\)), where \(q\) is the DNA concentration and \(Cp\) the cycle. Each result was converted to fungal load based on the positive control and overall elution of DNA.
**Fungal load on Nearctic bats.** We downloaded previously published \(P.\ destructans\) loads from natural infections\(^{39,58}\) or recalculated loads from mean \(Cp\) values according to the authors’ equation\(^{39}\). In one case, we plotted means as individual data points as the authors\(^{39}\) included species means per site (plus standard error) but fungal loads per individual were not published. The sample sizes for Nearctic bat species sampled within the dates used in this study were: *Corynorhinus rafinesquii* (\(n = 2\)), *Eptesicus fuscus* (\(n = 6\)), *Lasiorus borealis* (\(n = 2\)), *Myotis grisescens* (\(n = 11\)), *M. leibii* (\(n = 1\)), *M. lucifugus* (\(n = 36\)), *M. septentrionalis* (\(n = 4\)), *M. sodalis* (\(n = 13\)) and *Perimyotis fuscus* (\(n = 172\)). None of the North American studies specified sampled area on the bat with sufficient precision to enable standardisation to cm\(^2\) or universal statistical comparison.
**Molecular genetic variability of \(P.\ destructans\).** To assess genetic variability, we used a set of isolates collected between 2009 and 2014 in the Czech Republic\(^{38,65}\) and isolates from this study. The isolates were characterised using ITS and five other nuclear gene sequences using previously published primers (Supplementary Table S3). Chromatograms were assembled to DNA sequences in Geneious 6 (Biomatters, Auckland, New Zealand) and submitted to the European Nucleotide Archive (LN871244–LN871428). These were checked with blast and \(P.\ destructans\) was confirmed at all sites with a sequence identity to previously sequenced strains >99% in all markers. We then downloaded previously published \(P.\ destructans\) sequences of the respective genes from GenBank. Sequence haplotypes were identified based on available nucleotide residues, with gaps and unresolved bases treated as missing data. We estimated relationships between haplotypes using median-joining networks\(^{66}\).
**Individual-based linear mixed models.** We modelled intensity of WNS infection using fungal load on the dorsal side of the left wing and the number of WNS lesions on the same wing visualised over UV in \(^{64}\). UV-detectable lesions correspond with cupping erosions diagnostic for WNS in Europe and North America, thereby reflecting disease intensity\(^{47,48}\). Our previous experience in the Czech Republic has shown that wing damage tends to be localised and that lesions do not usually merge\(^{31}\), allowing them to be counted. The yellow-orange fluorescent spots were counted by a researcher with no knowledge of the qPCR and histopathology results for the samples. We scaled variables to 1 cm\(^2\) of wing area\(^{67}\) and log-transformed them in order to account for body-size differences between species. We included latitude and longitude, sampling day (from the beginning of the calendar year) and scores for the first two principal components (characterising dominant hibernating bat community in each region; Supplementary Fig. S2) as fixed-effect variables and species as a random effect. Microclimate at a specific bat roost might influence fungal load and disease intensity on an individual through a compound effect of optimizing growth conditions for the pathogen and hibernation conditions for the host. We used geographic coordinates as a proxy for possible general site microclimate (mean annual temperature, elevation, humidity) under the assumption that fungal load and number of WNS lesions would increase at higher latitudes and with longitudinal shift from oceanic to more continental climate. Similarly, we expected day of sampling to be reflected in the dependent variables as increased time for fungus propagation might increase its loading. As such,
geographic location, combined with sampling date, can be understood as a proxy for cave microclimate, which would influence growth of the WNS fungus\textsuperscript{30,68}.
Both relatedness and species assemblage differences at hibernacula in a given region could skew regional fungal load and disease intensity in favour of those areas where severely infested species co-occur. We estimated bat communities present at hibernacula from local surveys. Relatedness of species recorded was assessed using mean phylogenetic distance and mean nearest taxon distance (both with weighted abundance) and UniFrac metric measuring the percentage of phylogeny shared by a given community. We used these metrics for principal components analysis. We used backward stepwise variable selection to develop the model, which was assessed using the Akaike Information Criterion (AIC).
**Species-level phylogenetically-informed model.** Previously published phylogenetic trees for European bats\textsuperscript{31} based on multilocus sequence data were rescaled as an ultrametric tree using penalised likelihood\textsuperscript{69,70} with $\lambda$ and root height = 1. We used R\textsuperscript{70,71} to calculate phylogenetic signal in species means and phylogenetic ANOVA\textsuperscript{71,72}. We used the phylogenetic generalised least-squares method\textsuperscript{72,73} to explain the number of visible WNS lesions on a UV trans-illuminated wing based on \textit{P. destructans} fungal load.
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**Acknowledgements**
This study was supported through a grant from the Czech Science Foundation (Grant No. P506-12-1064). We are grateful to Tomáš Bartonička, Hana Berková and Masha Orlova for invaluable field assistance, to Matej Dolinay, Jiří C. Moravec, Patriciá Pečnerová and Aneta Reichová for laboratory assistance and to Gregory G. Turner for biopsy samples from Nearctic bats.
Author Contributions
J.Z., J.P. and N.M. designed the study and participated in field research, with help from H.B., J.B., V.K., O.O., P.P. and J.S. H.B., A.C., A.K., A.N., J.P. and A.Z. performed the laboratory analyses. K.S.J., M.K., J.P. and N.M. analysed the data. J.Z., J.P. and N.M. wrote the manuscript, with contributions from all authors.
Additional Information
Supplementary information accompanies this paper at http://www.nature.com/srep
Competing financial interests: The authors declare no competing financial interests.
How to cite this article: Zukal, J. et al. White-nose syndrome without borders: *Pseudogymnoascus destructans* infection tolerated in Europe and Palearctic Asia but not in North America. *Sci. Rep.* 6, 19829; doi: 10.1038/srep19829 (2016).
This work is licensed under a Creative Commons Attribution 4.0 International License. The images or other third party material in this article are included in the article’s Creative Commons license, unless indicated otherwise in the credit line; if the material is not included under the Creative Commons license, users will need to obtain permission from the license holder to reproduce the material. To view a copy of this license, visit http://creativecommons.org/licenses/by/4.0/
Corrigendum: White-nose syndrome without borders: *Pseudogymnoascus destructans* infection tolerated in Europe and Palearctic Asia but not in North America
Jan Zukal, Hana Bandouchova, Jiri Brichta, Adela Cmokova, Kamil S. Jaron, Miroslav Kolarik, Veronika Kovacova, Alena Kubatová, Alena Nováková, Oleg Orlov, Jiri Pikula, Primož Presetnik, Jurgis Šuba, Alexandra Zahradníková Jr. & Natália Martínková
*Scientific Reports* 6:19829; doi: 10.1038/srep19829; published online 29 January 2016; updated on 20 May 2016
This Article contains typographical errors.
In the Results section under subheading ‘Quantitative comparison of WNS on bats’,
“The fungal load on qPCR-positive bats ranged from 0.21 pg to 3.41 μg across the surface of the left wing (Supplementary Fig. S1, see Table 1 for sample sizes)”.
should read:
“The fungal load on qPCR-positive bats ranged from 0.21 fg to 3.41 ng across the surface of the left wing (Supplementary Fig. S1, see Table 1 for sample sizes).”
“The fungal load from UV-negative individuals (median = $3.78 \times 10^{-5} \mu g$) overlapped that from UV-positive individuals (median = $7.46 \times 10^{-4} \mu g$; Fig. 8)”.
should read:
“The fungal load from UV-negative individuals (median = $3.78 \times 10^{-5}$ ng) overlapped that from UV-positive individuals (median = $7.46 \times 10^{-4}$ ng; Fig. 8).
In the upper panel of Figure 4, the y-axis ‘Fungal load per cm$^2$ ($\log_{10}$(ng))’ was incorrectly given as ‘Fungal load per cm$^2$ ($\log_{10}$(μg))’
In the upper panel of Figure 5, the y-axis ‘*P. destructans* load per cm$^2$ ($\log_{10}$(ng))’ was incorrectly given as ‘*P. destructans* load per cm$^2$ ($\log_{10}$(μg))’
In Figure 6, the x-axis ‘*P. destructans* load per cm$^2$ ($\log_{10}$(ng))’ was incorrectly given as ‘*P. destructans* load per cm$^2$ ($\log_{10}$(μg))’
In Figure 8, the x-axis ‘Fungal load per cm$^2$ ($\log_{10}$(ng))’ was incorrectly given as ‘Fungal load per cm$^2$ ($\log_{10}$(μg))’
In the legend of Figure 8,
“Bats were identified as positive (grey; $n = 255$) and negative (orange; $n = 151$) using UV trans-illumination”.
should read:
“Bats were identified as positive (orange; $n = 255$) and negative (grey; $n = 151$) using UV trans-illumination”.
The correct Figures 4, 5, 6 and 8 appear below as Figures 1, 2, 3 and 4 respectively.
Figure 1.
Figure 2.
Figure 3.
Figure 4.
This work is licensed under a Creative Commons Attribution 4.0 International License. The images or other third party material in this article are included in the article’s Creative Commons license, unless indicated otherwise in the credit line; if the material is not included under the Creative Commons license, users will need to obtain permission from the license holder to reproduce the material. To view a copy of this license, visit http://creativecommons.org/licenses/by/4.0/
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MODEL 600039-SP
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Adhere to state and/or local certification and regulations for operation of forklift and/or pallet jack. Cargo is extremely heavy, be sure to have the necessary manpower as well as equipment to successfully unload shipment from transport. We recommend a forklift and/or pallet jack with the capacity to lift up to 2000 lbs. to remove cargo from transport.
The forklift can be used to unload receiving products safely by placing the load on the floor, maneuvering the forklift into position, tilting the mast forward to vertical position so the load will be level, lowering the load, and smoothly backing away without dragging. Once cargo is unloaded, positioning equipment for installation will once again require a forklift. Read all manual and note on installation of the unit before attempting installing.
The pallet jack can be used (with a loading dock and maneuverability on and off the transport vehicle) to unload receiving products safely. Maneuvering the pallet jack into position (in the appropriate position within the pallet), lifting the pallet then driving the pallet jack off the transport and safely into the place of installation.
**Range of Environmental Condition**
Mortech Manufacturing, Inc. equipment shall be placed in a controlled environment (housing or housed unit) hindering the weathering effects on the installed units. The equipment will have minimal corrosive and eroding factors that can break down the stability and operation of Mortech Manufacturing Inc. equipment. The impact on the equipment by the operator utilizing water or corrosives in the medical procedures can be controlled and responsibility for the cleaning and maintenance placed upon that person. The effects of anthropogenic (man-made) gasses on the environment, such as carbon dioxide (CO2) that will be omitted from the unit should be minimal.
*Due to continuous innovation and product development this installation guide is subject to change without notice.*
Please save these instructions for later use.
The carrier is designed to ensure your safety and efficiency while transporting discreetly. It can be instrumental in reducing injuries during transferring and transporting.
**STANDARD DESIGN FEATURES**
- Top tray fabricated from 14 gauge stainless steel
- Sturdy, lightweight removable aluminum top frame works in conjunction with flip down side rails to conceal cadaver
- Fabricated cover made of launderable cloth
- Replacement cover available
- The large wheel mobility can reduce start-up force up to 50 percent and steering effort up to 60 percent.
- The motorized drive system virtually eliminates manual pushing
- The motorized drive handles activate the drive system with a gentle squeeze and push of the handles for effortless transport
- Brakes on all casters lock both rotation and swivel for superior security. Brake controls are located at the foot and head end for quick and easy accessibility.
- Hydraulic Controls For quick accessibility and efficiency, hydraulic lift controls are located on either side of the stretcher
**Certifications**
- 87VL Medical Electrical Equipment, UL 60601-1, CAN/CSA C22.2 No. 601.1, cULus (classified), CE
Deceased removal hydraulic carrier base should be placed in lowest position. Aluminum canopy assembly should be set in place and siderails in the raised position over deceased. Cover should be placed over aluminum canopy assembly and siderails.
Aluminum canopy assembly is removed and siderails in the lowered position.
**HAND CONTROLS**
**On/Drive-Off/Manual Switch**
Turn the switch to the ON (ON/Drive) position to engage the drive wheel, OFF/Manual will disengage.
**Motorized Drive System Handles with Motion Release Switches**
Unplug the power cord, engage the drive wheel by pushing the Brake/Steer Control Pedal to the steer position (Green).
- While continually squeezing the switch(es), push away from you or pull towards you to initiate motion in that direction. The speed will increase proportionally to the amount of force to the drive handles. The carrier will maintain speed and direction with no extra force.
- To slow down push or pull the handles in the opposite direction.
- To STOP release the switch on the handles.
**Retractable Cord Reel for Recharging the Carrier with a 125V Hospital Grade Plug**
Pull to extend the cord to the desired length. Plug into any fully grounded hospital grade power source.
**UNPLUG BEFORE TRANSPORTING OR CLEANING**
**To Place The Motorized Drive System Handles in the Stored Position,**
- Lift Upward, then the Drive System Handles will collapse inward.
**Battery Power Gauge indicates the charge of the (2) 12V Batteries. Fully charge the carrier for proper function. When fully discharged, the batteries require approximately (8) hours charging time to recharge.**
**NOTE:** The drive wheel does not pivot. The carrier cannot be moved directly sideways with the drive wheel engaged. With the drive wheel pedal in the neutral position and the carrier’s brake released, the carrier can be moved in any direction including sideways.
**CAUTION**
If large fluid spills occur in the area of the circuit board or motor, immediately unplug the power cord from the power source and rotate the “ON/Drive - OFF/Manual” switch to the OFF/Manual position. Fluid can damage causing the carrier to function erratically and cause personal injury.
To lower the carrier push downward on the Uni-Lower Pedal. The stainless steel top will lower.
Break/Steer Control Pedal
Steer Position GREEN
To elevate the stainless steel top push the Pump Pedal in a downward motion and release until desired height is achieved.
Break/Steer Control Pedal
Brake Position RED
Downward Motion
Remove the Removable Aluminum Canopy Assembly by lifting upward.
Direct the carrier into a parallel position with the hospital bed. Place the Break/Steer Control Pedal to the Brake Position (RED).
Lower the Siderails. Lift upward on the Siderail Release Lever and push downward toward the head of the carrier.
Remove the cloth cover.
Transfer the deceased to the stainless steel top. Reposition the Siderails, Removable Aluminum Canopy Assembly and the cloth cover. You are now ready to transport discreetly throughout your facility.
Unit will not drive in either direction
Verify the brake/steer/neutral pedal is engaged in the drive position
Verify the manual override switch is in the on position
Verify the handle switches are not stuck (it should display green when the stretcher can drive and orange if it cannot)
Verify the coil communication cord is securely fastened to PCB box assembly & CSI box
NO
Are batteries charged above 24Volts?
YES
Plug in 110 Volts (LED should start flashing) to charge batteries
Does battery voltage start rising when AC is plugged in?
Checkable connections going to CSI Box
Check power connection for 110 volts
Try stretcher after it is charged above 26 Volts
If 110 Volts is going into CSI Box, replace CSI Box
Unplug battery cables to reset the system. Check for damaged pins. Plug cables back into batteries and test system.
Proceed with electronic component troubleshooting
Verify the Coil Communication Cord pins are straight, not recessed, nor broken off.
Verify continuity of Carr Micro Switch (When its engaged)
Check manual override switch (blue box housing) for continuity in the ON position. (All connections are straight through).
Verify the four D8g cables going to the display board PCB box are all plugged in correctly and not damaged.
Verify the Zoom motor connector pins are OK and have a good connection (red connector)
Verify the CSI box electrical enclosure connector pins are OK and have a good connection (black connector)
Verify manual override switch input pins are OK and have a good connection (2 pin white connector)
Verify motor temperature switch input pins are OK and have a good connection (4 pin white connector)
Return to Service
600039-SP Hydraulic Self Propelled Covered Cadaver Carrier
**Fully charged batteries drain very quickly**
- Battery gauge LEDs are not working correctly
- Verify connections on back of display board
- Verify connector pins are not damaged on display board and cables
- Replace display board
- Unit will only drive in one direction
- Check for obstructions between the handles
- Does it slow down?
- YES
- Replace load cell and test the system
- NO
- Replace display board
- Return to Service
- Replace the CSI box
- Return to Service
- Unit is driving slow
- Are batteries charged above 24 Volts?
- YES
- Plug in 110 Volts (LED should start flashing) to charge batteries
- NO
- Check cable connections going to CSI box and display board
- Replace the load cell and test the system
- Replace the display board and test the system
- Return to Service
- Replace batteries only after verifying stretcher is plugged in when not in use.
- Does battery voltage start using when AC is plugged in?
- YES
- Try stretcher after it is charged above 26 Volts
- NO
- Check cable connections going to CSI Box
- Replace the load cell and test the system
- Replace the display board and test the system
- Return to Service
- Check power connection for 110Volts
- If 110 Volts going into CSI Box, replace CSI Box
- Return to Service
FEBRUARY 2013 MFGISO DOC. #OM600039SP (REV A)
CLEANING
These instructions are intended to provide recommended cleaning methods for this carrier.
**DO NOT** steam clean, pressure wash, hose off, or ultrasonically clean the carrier.
Recommended Cleaning Methods
- Follow the cleaning solution manufacturer’s dilution recommendations exactly.
- Remove any cloth, debris prior to washing the carrier.
- Follow the cleaning solution manufacturer’s dilution recommendations exactly.
- Dry thoroughly.
CAUTION
Before returning the carrier to service, verify all labels are intact, verify the brake/steer pedal locks properly in both positions and check all components for proper lubrication.
CAUTION
- **DO NOT USE CLEANERS CONTAINING CHLORINE WHEN CLEANING STAINLESS STEEL.**
- Cleaning any Metal and/or Stainless Steel refer to Mortech Manufacturing Inc. “Equipment Maintenance” section in this manual.
- Must have maintenance performed after a minimum of every fifth washing.
- Failure to comply with these instructions may invalidate any/all warranties.
- Do not use abrasive cleaners to clean stainless steel and any display enclosure including the optional scale system.
- Do not allow cleaning solutions or other fluids to pool on the display unit.
- Wipe dry all surfaces after spills or cleaning.
- Hand wash with disinfecting soap and warm water. Rinse well with clear water and dry with a towel. (Clean on a regular basis to prolong work life).
Other cleaners for carriers surface (not Stainless Steel)
Quaternary Cleaners (active ingredient - ammonia chloride)
Phenolic Cleaners (active ingredient - o-phenylphenol)
Chlorinated Bleach Solution (5.25% - less than 1 part bleach to 100 parts water)
Avoid over saturation and ensure that the product does not stay wet longer than recommended by the chemical manufacturer’s guideline for proper disinfecting.
Preventative Maintenance Checklist
Making sure:
- All fasteners secure
- Siderails move and latch properly
- Engage brake pedal and push on the carrier to ensure all casters lock securely
- All casters secure and swivel properly
- Ground chain intact
- No leaks at hydraulic connections
- Hydraulic jacks holding properly
- Hydraulic drop rate set properly
- Hydraulic oil level sufficient
- Lubricate where required
- Accessories and mounting hardware in good condition and working properly
- Steer function working properly
- No excess play in drive handles
- Press handle switches - does not move unless engaged
- Press handle switches - move handles back and forth to verify responsiveness
- Power cord and plug free of damage
NOTE
Preventative maintenance should be performed at a minimum of annually. A preventative maintenance program should be established for all IVD and Medical equipment. Preventative maintenance may need to be performed more frequently based on the usage level of the product.
Covered Cadaver Carrier
MAINTENANCE INSTRUCTIONS
The unit requires regular maintenance and follow the manufacturer's directions.
DISINFECTING AND CLEANING
Clean all surfaces of the stainless steel with a hard surface disinfectant/cleaner such as Sheila Shine® or SaniZene®. Follow instructions on container.
DISINFECTING, CLEANING COMPONENTS & ACCESSORIES
Hand wash with disinfecting soap and warm water. Rinse well with clear water and dry with a towel. (Clean on a regular basis to prolong work life).
WARNING
Improper maintenance can cause injury. Maintain only as prescribed in this manual. Overall, it is very simple to maintain. If you use for its intended purpose, it will provide many years of reliable service.
CARE OF STAINLESS STEEL
Stainless steel products have a directional #4 brushed finish. This finish is produced using a very fine abrasive cloth. Dragging heavy equipment across the stainless steel surfaces will cause noticeable scratching. Pitting/ corrosion can occur when carbon steel products are allowed to remain in contact with the stainless steel in the presence of moisture. (Examples- Steel Wool pads left in the bottom of the sink). Stainless steel can be damaged by exposure to acids.
TYPES OF SURFACE CONTAMINANTS
• Dirt - Consist of accumulated dust and a variety of contaminants. Warm water with or without a gentle detergent is sufficient. Next in order are mild non-abrasive powders such as typical household cleaners. These can be used with warm water, bristle brushes, sponges, or cleaning cloths. (Do not use carbon steel brushes or steel wool they may leave particles embedded on the surface which can lead to RUSTING.) For more aggressive cleaning, a small amount of vinegar can be added to the scouring powder. When water contains mineral solids, which leave water spots, it is advisable to wipe the surface completely with dry towels.
• Fingerprints and Stains - Fingerprints and mild stains resulting from normal use are the most common surface contaminants. This affects the appearance and seldom have an effect on corrosion resistance. They can be removed with a glass cleaner or by gentle rubbing with a paste of soda ash (sodium carbonate) and water applied with a soft rag. Followed by a thorough warm water rinse and towel dry.
• Shop Oil and Grease - These soils may be corrosive and may not allow the surface to maintain passivity, and so removal is a necessity. Soap or detergent and water may be used or a combination of detergent and water plus a solvent.
TYPES OF CLEANERS AND METHODS
• General Precautions
Avoid using abrasive cleaners unless absolutely necessary. A "soft abrasive," such as pumice, should be used. Many cleaners contain corrosive ingredients, rinse with clean water.
• Clean Water and Wipe - A soft cloth and clean warm water should always be the first choice for mild stains, loose dirt and soils. A final rinse with clean water and a dry wipe will eliminate the possibility of water stains.
• Solvent Cleaning - Organic solvents can be used to remove fresh fingerprints, oils and greases that have not had time to oxidize or decompose. The preferred solvent is one that does not contain chlorine, such as acetone, methyl alcohol, and mineral spirits.
EFFECTIVE CLEANING METHODS
Commercial Cleaners - Many commercial cleaners compounded from phosphates, synthetic detergents, and alkalis are available for the cleaning of severely soiled or stained stainless surfaces. When used with a variety of cleaning methods, these cleaners can safely provide effective cleaning.
SCRATCH REPAIR
Surface scratches can be repaired using the following technique. Depending on the severity of the scratch, it may be possible to completely remove it. Sand the scratch using 120 grit emery cloth or paper and firm pressure. Always sand in the direction of the grain. Avoid the natural tendency to sand in an arc, instead sand in a perfectly straight line. Sand until the scratch is gone.
Polish using 3M Scotch Brite pads - Very Fine Grade. Use the same motions as with sanding. Polish until the original finish is restored. Wash and wipe the surface completely with dry towels.
RUST REMOVAL
Rust can be repaired using the following technique. Sand the scratch using 120 grit emery cloth or paper and firm pressure. Always sand in the direction of the grain. Avoid the natural tendency to sand in an arc, instead sand in a perfectly straight line. Sand until the rust is gone.
Polish using 3M Scotch Brite pads - Very Fine Grade. Use the same motions as with sanding. Polish until the original finish is restored. Wash and wipe the surface completely with dry towels.
5 Stainless Steel Mistakes NOT to Make When Cleaning
1. Do not use abrasive cleaners that will scratch the surface. Depending on the surface finish of your stainless steel, abrasive cleaners can cause scratching. A dull finish, probably will not show scratching as much as mirror or highly polished finishes. Test the cleaner in a hidden spot. It’s also a good idea to work from the least risky type (water) of cleaning to the heavy duty stuff.
2. Do not forget to rinse. Gritty or dirty water can leave a residue on your finish. It can also stain or pit the surface of your stainless steel. Rinse completely. Residue from cleaning solutions left on a stainless steel surface can stain or damage finish.
3. DO NOT USE CLEANERS CONTAINING CHLORINE. While it may be second nature to bleach everything, stainless steel and chlorine do not mix. Stay away from the bleach when you clean stainless steel. Be aware that bleach can be included in different types of cleaners. If you accidentally get a cleaner on your stainless steel you’ll need to rinse it off and quickly.
4. DO NOT USE STEEL WOOL OR STAINLESS BRUSHES
These products leave little particles in the surface of the steel and inevitably these particles begin rusting and staining the surface of the steel. They also can excessively scratch the surface of your stainless steel. Stay completely away from steel wool and steel brushes.
5. Do not assume it’s the cleaner. If you do have some spotting or staining, and you’ve followed all of the rules, it may not be the stainless steel cleaner. Water, especially hard water, can leave spotting and staining on stainless steel surfaces. Towel dry after rinsing can end the problem. Sometimes, even water is an enemy to stainless steel.
WARRANTY
Mortech Manufacturing, Inc. warrants all fabrications to be free of defects due to its own workmanship and materials.
Repair and/or replacement of materials furnished that may develop such defects, will be warranted for a period of one year from the date of shipment.
Items not manufactured by Mortech Manufacturing, Inc. will receive the manufacturer’s warranty.
PARTS AND SERVICE
Customer relations and product support are important aspects of Mortech Manufacturing, Inc.
For assistance with this or any of our fine products please contact us below:
Mortech Manufacturing, Inc.
411 North Aerojet Avenue
Azusa, CA 91702
TEL (626) 334-1471
FAX (626) 334-1704
www.mortechmfg.com
firstname.lastname@example.org
© COPYRIGHT MORTECH MANUFACTURING, INC., ALL RIGHTS RESERVED.
IMPORTANT
BEFORE INSTALLATION AND OPERATION OF THE UNIT, CHECK ANY ENCLOSURE PANELS AND PLUMBING FIXTURES THAT MIGHT HAVE LOOSENED DURING SHIPPING.
ATTENTION
All images and Drawing in this manual may not represent your model. Refer to your particular project for exact specifications.
DISCLAIMER
This manual contains general instructions for the use, operation, and care of this product. The instructions are not all inclusive. Safe and proper use of this product is solely at the discretion of the user. Safety information is included as a service to the user. All other safety measures taken by the user should be within and under consideration of applicable regulations. It is recommended that training on the proper use of this product be provided before using this product in and actual situation.
Retain this manual for future reference. Include it with the product in the event of transfer to new users. Additional free copies are available upon request from Customer Relations.
Mortech Manufacturing, Inc. has made every effort to ensure that this Manual is accurate; Mortech Manufacturing, Inc. abdicate liability for any inaccuracies or omissions that may have occurred.
Information in this Manual is subject to change without notice and does not represent a commitment on the part of Mortech Manufacturing, Inc. Mortech Manufacturing, Inc. assumes no responsibility for any inaccuracies that may be contained in this Manual. Mortech Manufacturing, Inc. makes no commitment to update or keep current the information in this Manual, and reserves the right to make improvements to this Manual and/or to the products described in this Manual, at any time without notice.
If you find information in this manual that is incorrect, misleading, or incomplete, we would appreciate your comments and suggestions.
PROPRIETARY NOTICE
The information in this manual is the property of Mortech Manufacturing, Inc. Mortech Manufacturing, Inc. reserves all patent rights, proprietary design rights, manufacturing rights, reproductions rights, and sales use rights thereto, and to any article disclosed therein except to the extent those rights are expressly granted to others or where not applicable to vendor proprietary parts.
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Androgen receptor splice variants activating the full-length receptor in mediating resistance to androgen-directed therapy
Bo Cao\textsuperscript{1,2,*}, Yanfeng Qi\textsuperscript{1,*}, Guanyi Zhang\textsuperscript{2,3}, Duo Xu\textsuperscript{1,2}, Yang Zhan\textsuperscript{1}, Xavier Alvarez\textsuperscript{4}, Zhiyong Guo\textsuperscript{5}, Xueqi Fu\textsuperscript{2}, Stephen R. Plymate\textsuperscript{6,7}, Oliver Sartor\textsuperscript{8,9}, Haitao Zhang\textsuperscript{2,3}, and Yan Dong\textsuperscript{1,10}
\textsuperscript{1} Department of Structural and Cellular Biology, Tulane University School of Medicine, Tulane Cancer Center, New Orleans, LA
\textsuperscript{2} College of Life Sciences, Jilin University, China
\textsuperscript{3} Department of Pathology and Laboratory Medicine, Tulane University School of Medicine, Tulane Cancer Center, New Orleans, LA
\textsuperscript{4} Tulane National Primate Research Center, Covington, LA
\textsuperscript{5} Department of Pharmacology, University of Maryland School of Medicine, Baltimore, MD
\textsuperscript{6} Departments of Medicine, University of Washington School of Medicine, Seattle, WA
\textsuperscript{7} Department of Urology, University of Washington School of Medicine, Seattle, WA
\textsuperscript{8} Department of Urology, Tulane University School of Medicine, Tulane Cancer Center, New Orleans, LA
\textsuperscript{9} Department of Medicine, Tulane University School of Medicine, Tulane Cancer Center, New Orleans, LA
\textsuperscript{10} National Engineering Laboratory for AIDS Vaccine, College of Life Sciences, Jilin University, China
* These authors contributed equally; in alphabetical order
Correspondence to: Yan Dong, email: firstname.lastname@example.org; Haitao Zhang, email: email@example.com
Keywords: androgen receptor, splice variant, prostate cancer, castration resistance, enzalutamide
Received: February 18, 2014 Accepted: March 2, 2014 Published: March 4, 2014
This is an open-access article distributed under the terms of the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original author and source are credited.
ABSTRACT:
Upregulation of constitutively-active androgen receptor splice variants (AR-Vs) has been implicated in AR-driven tumor progression in castration-resistant prostate cancer. To date, functional studies of AR-Vs have been focused mainly on their ability to regulate gene expression independent of the full-length AR (AR-FL). Here, we showed that AR-V7 and AR\textsuperscript{v567es}, two major AR-Vs, both facilitated AR-FL nuclear localization in the absence of androgen and mitigated the ability of the antiandrogen enzalutamide to inhibit AR-FL nuclear trafficking. AR-V bound to the promoter of its specific target without AR-FL, but co-occupied the promoter of canonical AR target with AR-FL in a mutually-dependent manner. AR-V expression attenuated both androgen and enzalutamide modulation of AR-FL activity/cell growth, and mitigated the \textit{in vivo} antitumor efficacy of enzalutamide. Furthermore, AR\textsuperscript{v567es} levels were upregulated in xenograft tumors that had acquired enzalutamide resistance. Collectively, this study highlights a dual function of AR-Vs in mediating castration resistance. In addition to trans-activating target genes independent of AR-FL, AR-Vs can serve as a “rheostat” to control the degree of response of AR-FL to androgen-directed therapy via activating AR-FL in an androgen-independent manner. The findings shed new insights into the mechanisms of AR-V-mediated castration resistance and have significant therapeutic implications.
INTRODUCTION
Androgen deprivation therapy, which disrupts androgen receptor (AR) signaling through androgen ablation or AR antagonists, is the first-line treatment for disseminated prostate cancer. While this regimen is effective initially, progression to the presently incurable and lethal stage, termed castration-resistant prostate...
cancer (CRPC), invariably occurs [1,2]. Resurgent AR activity is an established driver of therapeutic failure and castration-resistant progression [1,2]. A number of ligand-dependent and -independent mechanisms have been proposed to underlie AR reactivation after androgen-directed therapies [1,2]. For example, overexpression of the full-length AR (AR-FL) was shown to convert prostate cancer growth from a castration-sensitive to a castration-resistant stage [3]. In addition, CRPC tissues were shown to exhibit persistent levels of androgens despite androgen deprivation [1,2]. These led to the development of the potent AR antagonist enzalutamide (MDV3100) and the androgen biosynthesis inhibitor abiraterone for treatment of metastatic CRPC [4,5]. They heralded a new era of prostate cancer therapy. However, many patients presented with therapy-resistant disease, and most initial responders developed acquired resistance within months of therapy initiation, again accompanied by increased prostate-specific antigen (PSA), indicating reactivated AR signaling [4,5]. Emerging evidences indicate that prostate tumors can adapt to these androgen-directed therapies, including the new agents, by signaling through constitutively-active AR splice variants (AR-Vs) that lack the functional ligand-binding domain [6-16].
AR-Vs are upregulated in most CRPCs compared to hormone-naïve cancers [6,7,13-17]. Intriguingly, there is a significant discrepancy between the relative abundance of AR-V mRNAs and that of AR-V proteins in clinical specimens. While the level of AR-V mRNAs is low relative to that of the AR-FL, the AR-V proteins are expressed at a level comparable to that of AR-FL in a considerable portion of metastatic CRPC tissues [6,16]. In addition, the absolute levels of AR-Vs may not be as important as that of AR-FL for their respective activity. This is because AR-FL is located in the cytoplasm in the absence of ligand and translocates to the nucleus and activates target-gene expression upon ligand binding, whereas constitutively-active AR-Vs localize to the nucleus and activate target-gene expression in the absence of ligand [13-15,18-20]. AR-V7 (aka AR3) and AR\textsuperscript{v567es} are two major AR-Vs expressed in clinical specimens [6,7,13-15]. Strikingly, patients with high levels of expression of AR-V7 or detectable expression of AR\textsuperscript{v567es} have a significantly shorter survival than other CRPC patients [6], indicating an association between AR-V expression and a more lethal form of prostate cancer.
Preclinical studies have pointed to an important role of AR-Vs in mediating castration resistance. Ectopic expression of AR-V7 or AR\textsuperscript{v567es} confers castration-resistant growth of LNCaP xenograft tumors [13,15,20]. Conversely, knockdown of AR-V7 attenuates the growth of castration-resistant 22Rv1 xenograft tumors [13]. AR-Vs have also been shown to confer resistance to enzalutamide in preclinical studies. Knockdown of AR-Vs sensitizes 22Rv1 cells and NFrE p52-transfected LNCaP cells to enzalutamide inhibition of growth [8,11]. Reducing AR-V levels with small-molecule drugs improves enzalutamide efficacy against the growth of 22Rv1 cells and xenografts [21]. Thus, AR-V upregulation appears to be a mechanism for prostate cancer cells to evade androgen-directed therapies. A comprehension of mechanisms of AR-V action is paramount for developing effective means to suppress AR-V signaling.
Gene expression profiling showed that AR-Vs regulate the expression of both canonical androgen-responsive genes and a distinct set of targets enriched for cell-cycle function [7,13,15]. The ability of AR-Vs to regulate target-gene expression has been attributed largely to their AR-FL-independent activity [7,8,12-15,19]. However, AR-FL and AR-V7 immunohistochemistry staining of adjacent sections of CRPC specimens showed that AR-V is often co-expressed with AR-FL [7]. We reason that, in addition to binding to chromatin sites and regulating gene expression independent of AR-FL, AR-Vs may bind to chromatin as a complex with AR-FL. Combined, these two activities may account for the expanded AR-V transcriptome. In fact, AR\textsuperscript{v567es} has been shown to coimmunoprecipitate with AR-FL and facilitate AR-FL nuclear localization in the absence of androgen [15]. In the present study, we dissected the interplay between AR-Vs and AR-FL in regulating gene expression and mediating resistance to androgen-directed therapies.
**RESULTS**
**AR-V mitigates enzalutamide inhibition of AR-FL nuclear localization**
Both AR\textsuperscript{v567es} and AR-V7 can reside constitutively in the nucleus [14,15,18], and AR\textsuperscript{v567es} has been shown to facilitate AR-FL nuclear localization in the absence of androgen [15]. Enzalutamide is known to attenuate androgen-induced AR-FL nuclear localization in cells expressing AR-FL alone [22]. To assess the effect of AR-V7 on AR-FL subcellular localization and the impact of AR-Vs on enzalutamide modulation of AR-FL localization, we expressed AR-FL-green-fluorescent-protein (AR-FL-GFP) with or without AR-V7-turbo-red-fluorescent-protein (AR-V7-TurboFP) or AR\textsuperscript{v567es}-TurboFP in the AR-null COS-7 cells. Consistent with previous reports [14,15,18], as shown in Figure 1A, both AR-Vs were found primarily in the nucleus, whereas AR-FL localized predominantly in the cytoplasm in androgen-deprived conditions. Enzalutamide caused ~50% reduction of androgen-induced AR-FL nuclear localization, but had no effect on AR-V localization or AR-FL localization in the absence of androgen.
When co-expressed with AR-V7 or AR\textsuperscript{v567es} (Figure 1B), AR-FL could localize to the nucleus in the absence of androgen. The nuclear localization was unaffected by
enzalutamide. Strikingly, although addition of androgen further induced AR-FL nuclear localization, enzalutamide could not retain AR-FL in the cytoplasm when AR-V was present. Moreover, AR-V localization was not affected by androgen or enzalutamide even when co-expressed with AR-FL. A similar result was obtained in the PC-3 prostate cancer cells (Supplementary Figure 1). Taken together, the data suggest that AR-Vs facilitate AR-FL nuclear localization in the absence of androgen and mitigate the ability of enzalutamide to inhibit androgen-induced AR-FL nuclear localization.
**AR-V and AR-FL co-occupy the target-gene promoter**
Although AR-V-mediated AR-FL nuclear localization may not necessarily entail a physical interaction between AR-V and AR-FL, AR\textsuperscript{v567es} has been shown to coimmunoprecipitate with AR-FL, indicating AR-V can form a complex with AR-FL [15]. To find out whether they bind to target promoters as a complex, we performed sequential chromatin immunoprecipitation (Re-ChIP) analysis with an AR-V7 antibody followed by an AR-FL antibody in 22Rv1 cells, which express endogenous AR-V7 and are in part driven by AR-V7 [23]. We had to limit the analysis to AR-V7 because it is the only AR-V to which a specific antibody has been developed. As shown in Figure 2A, we detected co-occupancy of AR-V7 and AR-FL on the promoter of the PSA gene, and the co-occupancy was unaffected by androgen or enzalutamide treatment. In contrast, the promoter of ubiquitin-conjugating enzyme E2C (UBE2C) is only bound by AR-V7 (Figure 2A and 2B), and ChIP assay showed that AR-FL knockdown (shFL) did not significantly affect the binding (Figure 2B). This is consistent with UBE2C as an AR-V-specific target [6,7]. We then conducted a ChIP assay on the PSA promoter in 22Rv1 cells with or without specific knockdown of AR-FL or AR-V7 in androgen-deprived condition. As shown in Figure 2C, AR-FL knockdown diminished AR-V7 binding to the PSA promoter. Similarly, AR-V7 knockdown (shV7) reduced androgen-independent AR-FL binding to the promoter (Figure 2D). Collectively, the data indicate that,
---
**Figure 1:** **AR-V facilitates AR-FL nuclear localization in the absence of androgen and mitigates enzalutamide inhibition of androgen-induced AR-FL nuclear localization.** A & B. Confocal fluorescence microscopy of AR-FL and AR-V subcellular localization when expressed alone (A) or when co-expressed with AR-V (B) in COS-7 cells. Right panels, quantitation of % of cells with predominantly nuclear, equally nuclear and cytoplasmic, or predominantly cytoplasmic expression. DRAQ5, nuclear stain. Cells cultured in androgen-deprived condition were pre-treated with 10 μM enzalutamide (Enz) for 2 hr, followed by treatment with or without 1 nM R1881 for 3 hr. *, P < 0.05.
in the absence of androgen, AR-V and AR-FL co-occupy the promoter of canonical androgen-responsive gene, but not AR-V-specific target, in a mutually-dependent manner.
**AR-V attenuates androgen-induced AR-FL transactivation**
To determine the impact of promoter co-occupancy on target gene expression, we measured the mRNA levels of both canonical androgen-responsive genes (PSA and TMPRSS2) and AR-V-specific targets (CCNA2 and UBE2C) in 22Rv1 cells in response to AR-FL or AR-V7 knockdown (Figure 3A). While knockdown of AR-FL and AR-V7 both reduced androgen-independent expression of PSA and TMPRSS2, only AR-V7 knockdown downregulated CCNA2 and UBE2C. Notably, although AR-V7 knockdown diminished basal PSA and TMPRSS2 levels, the levels after androgen stimulation were essentially the same in control and AR-V7-knockdown cells. AR-V7 knockdown thus led to a higher magnitude of androgen induction of PSA (2.7-fold vs. 1.7-fold) and TMPRSS2 (2.6-fold vs. 1.4-fold), and enzalutamide was very effective in blocking the induction. Conversely, ectopic expression of AR-V7 or AR\textsuperscript{V567es} in LNCaP cells dose-dependently induced basal PSA and TMPRSS2 expression and diminished the degree of response of PSA and TMPRSS2 to androgen (Figure 3B and Supplementary Figure 2). Taken together, the data indicate that, in addition to \textit{trans}-activating a distinct set of genes, AR-Vs activate AR-FL in an androgen-independent manner to induce the expression of their shared targets. In doing so, AR-Vs could serve as “rheostats” to control the degree of response of AR-FL to androgen and to androgen-directed therapy. Interestingly, while ectopic co-expression of AR-V7 or AR\textsuperscript{V567es} rendered enzalutamide ineffective against androgen-induced AR-FL nuclear localization (Figure 1B), the presence of AR-V7 did not affect the ability of enzalutamide to inhibit androgen-dependent expression of PSA and TMPRSS2 (Figure 3A and Supplementary Figure 2). Collectively, these results suggest that AR-Vs could facilitate the nuclear localization of AR-FL in the presence of enzalutamide, but are unable to overcome the suppression of ligand-activated AR-FL transactivation by enzalutamide.
**AR-V mitigates androgen and enzalutamide modulation of cell growth**
We proceeded to characterize the effect of AR-V7 knockdown on androgen and enzalutamide modulation
A. Sequential ChIP analysis in 22Rv1 cells with an AR-V7 antibody followed by an AR-FL antibody showing co-occupancy of the PSA, but not UBE2C, promoter by AR-V7 and AR-FL. Enzalutamide (Enz), 10 μM. DHT, 1 nM. B. AR-V7 ChIP analysis in 22Rv1 cells showing AR-V7 binding to the UBE2C promoter. C. AR-V7 ChIP analysis in 22Rv1 cells showing AR-FL knockdown diminishes AR-V7 binding to the PSA promoter. D. AR-FL ChIP analysis in 22Rv1 cells showing AR-V7 knockdown reduces AR-FL binding to the PSA promoter. The values of the IgG samples are set as 1, and the ChIP results are presented as relative fold of IgG. *; P < 0.05. Western blots showed the knockdown efficacy of AR-FL and AR-V7.
of the growth of 22Rv1 cells. Congruent with the mRNA data, after AR-V7 knockdown, the cells became more sensitive to DHT induction of growth (Figure 4A; ~2-fold in AR-V7-knockdown cells vs. 1.3-fold in control cells). Consequently, the knockdown cells were more responsive to enzalutamide growth inhibition than the control cells. We next inoculated AR-V7-knockdown cells or control cells in nude mice, and characterized the response of the ensuing tumors to enzalutamide. As shown in Figure 4B, growth inhibition by enzalutamide was more pronounced after AR-V7 knockdown (the tumor growth curves are presented in Supplementary Figure 3). Collectively, the data suggest that AR-V may contribute to enzalutamide resistance by dampening the response of the cells to androgen induction of growth.
**Increased AR-Vs in tumors that had developed acquired resistance to enzalutamide**
Enzalutamide has been demonstrated to be very effective against the growth of castration-resistant AR-FL-overexpressing LNCaP xenografts [22]. As shown in Figure 5A, we observed the same phenomenon in xenografts established by inoculating LNCaP cells that were transduced with wild-type-AR-FL-encoding lentivirus into castrated nude mice. Some tumors resumed growth with prolonged treatment (after 7-17 weeks) (Figure 5B). We serially passaged the relapsed Tumor #1 and #2 (Figure 5B) in castrated mice treated with enzalutamide, and considered tumors from the second to fourth passages as enzalutamide resistant. RNA-seq analysis of four enzalutamide-sensitive tumors and six enzalutamide-resistant tumors showed that none of the tumors carried the AR F876L missense mutation (Figure 5C), which was identified in enzalutamide-resistant LNCaP cells and shown to confer agonist activity to enzalutamide [24-26]. Instead, the transcripts of AR\textsuperscript{V567ex} and AR-V7 (trending toward significance) were upregulated in enzalutamide-resistant tumors, while the levels of AR-V4 or AR-FL transcript did not differ (Figure 6A-D). The upregulation of AR-V was also reflected at the protein level (Figure 6E). Interestingly, all the enzalutamide-resistant tumors that showed higher AR-V protein expression also express increased levels of glucocorticoid receptor (Supplementary Figure 4), the upregulation of which has been shown to be a mechanism of acquired resistance to enzalutamide [27]. The data indicate that these tumors may use multiple mechanisms to evade enzalutamide treatment.
**Figure 3: AR-V attenuates androgen and enzalutamide modulation of AR-target expression.** A. qRT-PCR analysis showing reduced androgen-independent expression of PSA and TMPRSS2 after knockdown of either AR-FL or AR-V7 (left panel) and reduced expression of CCNA2 and UBE2C only after AR-V7 knockdown (right panel). AR-V7 knockdown also renders 22Rv1 cells more sensitive to DHT and enzalutamide modulation of PSA and TMPRSS2 expression. B. qRT-PCR analysis showing that AR-V transfection dose-dependently attenuates DHT induction of PSA and TMPRSS2 in LNCaP cells. Treatment duration, 8 hr (A); 4 hr (B). Enzalutamide (Enz), 10 µM. DHT, 1 nM. *, P < 0.05. #, P < 0.05 from untreated control-shRNA cells.
Figure 4: AR-V attenuates androgen and enzalutamide modulation of cell growth. A. AR-V7 knockdown enhances the response of 22Rv1 cells to androgen and enzalutamide modulation of cell growth. B. Enzalutamide inhibition of 22Rv1 tumor growth becomes more pronounced after AR-V7 knockdown. Data are expressed as % of inhibition by enzalutamide. *, $P < 0.05$. Enzalutamide (Enz), 10 mg/kg/day. n = 8.
Figure 5: Absence of AR F876L mutation in LNCaP tumors that have developed acquired resistance to enzalutamide. A. Enzalutamide (Enz) inhibits the growth of castration-resistant LNCaP tumors initially. LNCaP cells were transduced with lentivirus encoding wild-type (wt) AR-FL before inoculated into castrated mice. *, $P < 0.05$ from the control group. n = 5. B. LNCaP tumors resume growth after 7-17 weeks of enzalutamide treatment. The mean tumor volumes were presented as % of original tumor size at Day 0 of treatment. C. Integrative Genomics Viewer (IGV) plot of RNA-seq data showing no detection of F876L mutation in the AR gene in enzalutamide-sensitive and –resistant LNCaP tumors. The brown boxes represent the relative frequencies of T877A-mutated AR that is present in the LNCaP tumors. The relative frequencies of the transduced wt AR remained in the tumors are denoted by the green boxes and tabbed on the right. Allele frequency threshold was set at 0.01.
DISCUSSION
To date, the ability of AR-Vs to contribute to castration resistance has been attributed largely to their AR-FL-independent constitutive activity in regulating gene expression. Here, we identified what we believe to be a novel mechanism of AR-V action. We showed that AR-V7 and AR\textsuperscript{v567es}, two major AR-Vs, not only facilitate AR-FL nuclear localization in the absence of androgen but also mitigate the ability of the antiandrogen enzalutamide to inhibit androgen-induced AR-FL nuclear localization. In the nucleus, AR-V7 binds to the promoter of its specific target without AR-FL, but co-occupies the promoter of canonical androgen-responsive gene with AR-FL in a mutually-dependent manner. The co-occupancy is not affected by androgen or enzalutamide. Concordantly, knockdown of AR-FL and AR-V7 both result in reduced androgen-independent expression of canonical androgen-responsive genes, but only AR-V7 knockdown downregulates AR-V-specific targets. Notably, although basal levels of canonical androgen-responsive genes are diminished after AR-V7 knockdown, or elevated after AR-V7 or AR\textsuperscript{v567es} overexpression, the levels after androgen stimulation are unaffected. Thus, AR-Vs appear to repress the degree of response of AR-FL to androgen by activating AR-FL to induce target expression in an androgen-independent manner. This is further supported by the improved sensitivity of the cells to androgen induction of cell growth and enzalutamide inhibition of cell growth after AR-V7 knockdown. These collective findings suggest that, in addition to AR-FL-independent constitutive transactivation, AR-Vs may serve as “rheostats” to control the degree of response of AR-FL to androgen and to androgen-directed therapy.
In the present study, we also showed that enzalutamide becomes more potent in thwarting the growth of 22Rv1 xenograft tumors after AR-V7 knockdown, indicating that targeting both AR-Vs and AR-FL is needed to achieve complete AR blockade. While corroborating the \textit{in vitro} observations from Li \textit{et al.} [8] and Nadiminty \textit{et al.} [11], the data contrast the finding from Watson \textit{et al.} that ectopic expression of AR-V7 in AR-FL-overexpressing LNCaP xenograft tumors does not affect the growth inhibitory efficacy of enzalutamide [20]. A plausible explanation for the discrepancy is that, in the context of AR overexpression, the growth of LNCaP tumors may be driven mainly by the AR-FL signaling, making enzalutamide highly effective irrespective of AR-V expression. Nonetheless, we showed that, when the ectopically-expressed AR-FL is lost in these tumors, they can become resistant to enzalutamide. The resistance is
**Figure 6:** \textbf{Increased AR-V expression in LNCaP tumors that have developed acquired resistance to enzalutamide.} A-D. qRT-PCR analysis of the levels of AR-V transcripts. Fold changes are calculated from the difference in mean $\Delta C_t$ between the enzalutamide-sensitive and enzalutamide-resistant groups ($2^{-\Delta\Delta CT}$). E. Western blot analysis of the levels of AR-FL and AR-V proteins.
accompanied by increased expression of AR\textsuperscript{v567es}. Thus, these tumors may also evade enzalutamide treatment through shifting towards AR-V-mediated signaling.
The significance of our finding that AR-Vs activate AR-FL to induce target-gene expression in an androgen-independent manner is based on the premise that AR-Vs and AR-FL are often co-expressed in biological contexts. This is supported by overlapping AR-FL and AR-V7 immunohistochemistry staining of adjacent sections of CRPC specimens [7]. This is also supported by the finding that androgen deprivation coordinately increases AR-FL and AR-V mRNAs by inducing the transcription of the AR gene and thereby increasing the recruitment of splicing factors to AR pre-mRNA to splice both AR-FL and AR-V mRNAs [9]. AR-V expression may also be a result of AR gene rearrangements [28,29], and gene-arrangement-caused AR-V production appears to occur at the expense of AR-FL [29]. However, a clonal selection process is required for gene-rearrangement-mediated AR-V production to be manifested at the level of tumor tissues. This appears to be in contrast to the rather rapid change of AR-V levels observed in xenograft tumors after androgen ablation or androgen replacement [15,20]. Further, different AR-Vs can be expressed in the same tissues. Clonal expansion of cells with one type of gene arrangement could lead to expression of one specific AR-V but may not be able to account for the expression of different AR-Vs. Finally, our data showing co-occupancy of AR-V7 and AR-FL on the PSA promoter in a mutually-dependent manner and increased response of AR-FL to androgen after AR-V7 knockdown provided further support to the co-expression of AR-FL and AR-V in the same cells. Thus, the ability of AR-Vs to activate AR-FL in an androgen-independent manner could be as important as their AR-FL-independent \textit{trans}-activating activity in mediating castration resistance.
Our finding of AR-V and AR-FL co-regulating the expression of canonical androgen-responsive genes in androgen-deprived condition is reminiscent of the transcriptome data from Hu \textit{et al.} that knockout of AR-FL in AR-V-transfected LNCaP cells almost completely abolishes the expression of at least a subset of canonical androgen-responsive genes [7]. In addition to regulating canonical androgen-responsive genes, AR-Vs have also been shown to regulate a distinct set of targets enriched for cell-cycle function [6,7,13]. This is further corroborated by our ChIP data showing the promoter of UBE2C is bound by AR-V7 but not AR-FL. Receptor dimerization is a crucial step of AR-FL activation [30]. AR\textsuperscript{v567es} has been shown to co-immunoprecipitate with AR-FL [15]. Here, we showed that AR-V7 and AR-FL co-reside on the promoter of their shared target. AR-V7 and AR\textsuperscript{v567es} can localize constitutively to the nucleus, and facilitate AR-FL nuclear localization in the absence of androgen. It is therefore possible that AR-V7 and AR\textsuperscript{v567es} dimerize with AR-FL in the cytoplasm in an androgen-independent manner, and the heterodimer translocates to the nucleus and binds to regulatory elements of their shared targets to regulate the transcription of these targets. It remains unknown as to whether dimerization is required for AR-Vs to regulate their specific targets. Future studies are needed to define the dimeric nature of AR-Vs in regulating gene expression.
In summary, our study provides further evidence to support AR-V upregulation as a means for prostate cancer cells to evade all androgen-directed therapies currently accepted in the clinic. Mechanistically, we identified a novel mechanism by which AR-Vs mediate castration-resistant progression. We showed that AR-Vs can activate AR-FL to induce target expression in an androgen-independent manner. By doing so, AR-Vs may serve as “rheostats” to control the degree of response of AR-FL to androgen and to androgen-directed therapy. Since AR-Vs are often co-expressed with AR-FL in biological contexts, this mechanism of AR-V action may be equally important as its AR-FL-independent activity to castration resistance. These findings underscore a critical need to develop effective means to target both AR-Vs and AR-FL to achieve complete AR blockade for more effective combat of these clinically challenging tumors. Several natural or synthetic compounds have been shown pre-clinically to inhibit AR-V and AR-FL actions [17,21,31-35]. Proof of efficacy in clinical trials is keenly awaited.
**METHODS**
**Cell Lines and Reagents**
LNCaP, 22Rv1, COS-7, and PC-3 cells were obtained from American Type Culture Collection at Passage 4. Cells used in this study were within 20 passages (~3 months of non-continuous culturing). All cell lines were tested and authenticated by the method of short tandem repeat profiling. Enzalutamide was purchased from Selleck Chemicals (Houston, TX), and the purity of >99% was confirmed by Nuclear Magnetic Resonance. The following antibodies were used in Western blot analysis: anti-glyceraldehyde-3-phosphate dehydrogenase (GAPDH, Millipore), anti-AR (N-terminus-directed; PG-21, Millipore), and anti-AR-V7 (Precision Antibody). Cell growth was determined by the Sulforhodamine assay.
**Subcellular Localization**
AR subcellular localization is detected by confocal fluorescence microscopy. The pTurboFP-AR-V7 and pTurboFP-AR\textsuperscript{v567es} plasmids were generated by cloning the cDNA fragments for AR-V7 and AR\textsuperscript{v567es}, respectively, into the pCMV-TurboFP635 vector. COS-7 or PC-3 cells were transfected with indicated plasmids and cultured in phenol
red-free RPMI-1640 supplemented with 10% charcoal-stripped fetal bovine serum. At 40 hr after transfection, cells were pre-treated with or without 10 μM enzalutamide for 2 hr, followed by treatment with or without 1 nM R1881 for 3 hr. The COS-7 cells were then fixed with 2% paraformaldehyde, and the nuclei stained with 2.5 μM DRAQ5 (Cell Signaling). The PC-3 cells were then fixed with 70% ethanol, and the nuclei stained with DAPI. Confocal images were obtained by using a Leica TCS SP2 system with a 63X oil-immersion objective on a Z-stage, and an average of 6 fields with ~10 cells per field was captured for each group. Data quantitation was performed as described [18].
**qRT-PCR**
qRT-PCR was performed as described [36]. The qPCR primer-probe sets for PSA, transmembrane protease, serine 2 (TMPRSS2), cyclin A2 (CCNA2), and UBE2C were from IDT. The primer sequences for AR isoforms were as described [13].
**ChIP and Re-ChIP**
ChIP and Re-ChIP were performed as described [37]. The following antibodies were used: mouse IgG2a (ab18413, abcam), rabbit IgG (ab46540, abcam), AR-FL-specific antibody (C-terminus-directed; C-19, sc-815 x, Santa Cruz Biotech), AR-V7-specific antibody (AG10008, Precision Antibody). The PSA promoter P2-ARE primers described by Guo *et al.* [13] and the UBE2C promoter primers described by Wang *et al.* [38] were used for qPCR analysis of ChIP or re-ChIP DNA. The RPL30 exon 3 control region (Cell Signaling) was used as a negative control.
**Tumor Xenografts**
Xenograft studies were conducted essentially as described [22,32]. LNCaP cells (4x10^6) infected with lentivirus encoding AR-FL or 22Rv1 cells infected with lentivirus encoding control shRNA or AR-V7 shRNA were inoculated into castrated or intact nude mice (Charles River), respectively. The cells were mixed with 50% Matrigel and inoculated subcutaneously on the right dorsal flank. Tumor volume was calculated as $0.524 \times width^2 \times length$ [39]. When the tumor size reached ~100 mm^3, the mice were randomized to daily treatment with vehicle or 10 mg/kg/day enzalutamide through oral gavage as described [22].
For the development of enzalutamide-resistant tumors, two LNCaP tumors that relapsed after enzalutamide treatment were resected, and ~20 mm^3 pieces of the tumors were transplanted into castrated nude mice. When the tumor bits grew to 100–200 mm^3, the mice started to receive 10 mg/kg/day enzalutamide through oral gavage. The tumors were harvested when they reached ~800 mm^3 and serially passaged in castrated nude mice following the same protocol. The second to fourth passages of tumors were considered as enzalutamide-resistant. All animal procedures were approved by the Tulane University Institutional Animal Care and Use Committee.
**Statistical Analysis**
The Student’s two-tailed t test was used to determine the mean differences between two groups. $P < 0.05$ is considered significant. Data are presented as mean ± SEM.
**ACKNOWLEDGEMENTS**
We are grateful to Dr. Yun Qiu for AR-FL and AR-V7 cDNA and shRNA constructs, and Drs. Jun Luo, and Sanjiv Gambhir for pEGFP-AR and pCMV-TurboFP635 constructs, respectively. This work was supported by the following grants: NCI K01CA114252, ACS RSG-07-218-01-TBE, DOD W81XWH-12-1-0112 and W81XWH-12-1-0275, Louisiana Board-of-Regents Grant LEQSF(2012-15)-RD-A-25, Louisiana Cancer Research Consortium Fund, National Natural Science Foundation of China 81272851. S.R.P. was funded by P01-CA163227-01A1, DOD-W81XWH-13-2-0093, 2 P50 CA 097186-12, and Veterans Affairs Research Service.
**Editorial note:**
This paper has been accepted based in part on peer-review conducted by another journal and the authors’ response and revisions as well as expedited peer-review in Oncotarget
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VOCUSGROUP
ABOUT THIS REPORT
This is the third annual sustainability report prepared for Vocus Group Limited (“Vocus”), reviewing our performance from 1 July 2017 to 30 June 2018. This report has been prepared in accordance with the GRI Standards: Core option. We have not sought external assurance over this report. This and our previous reports can be found online via http://vocusgroup.com.au/sustainability/sustainability-report/. We welcome feedback on the report, which may be sent to firstname.lastname@example.org.
CONTENTS
01 Chair & CEO Letter
02 About Vocus
04 Priorities and Achievements
06 How We Create Value
07 Stakeholder Engagement
08 Ethics, Integrity and Governance
09 Environment
12 Social Sustainability – Team
15 Social Sustainability – Product Responsibility
18 Community
20 Management Approach: Identified Material Aspects and Boundaries
21 Appendix
Dear Shareholders,
On behalf of the Board and our Team, we are pleased to present to you our third annual Sustainability Report.
Sustainability reporting is increasingly in focus as investors, customers and potential and current team members look to how a company performs beyond its financial statements. We are proud to be a company that seeks to perform well sustainably and motivates its team members to be actively involved in its communities.
Throughout what has been a very busy year, we have made significant and tangible changes that will re-invigorate Vocus and enable us to deliver the growth we are focused on achieving. Our primary focus going forward is sustainable, profitable growth. Key to the success of the future strategy of the business is having the right team in place. We have been fortunate to be able to attract a number of highly experienced executives who know how to win in their markets and are excited by the opportunity presented by Vocus. We have also made a number of internal changes and together these provide a platform for us to achieve our goal.
FY18 saw a focus on discipline on operating and capital expenditure across the business. Within these constraints, we concentrated our efforts on areas where we could make a difference.
Our Team’s sustainability activity in FY18 was commendable. Achievements included an increase of 196% in the number of team members volunteering their time to support those in need; several awards won in our Enterprise & Wholesale segment for our initiatives and commitment to customer service excellence; and the continued training and development of our team members through our Leadership Development and Mentoring Programs. Details on the main activities we undertook, our business and our impact, is contained within this report.
We invite you to review our sustainability activity and welcome your feedback via email@example.com.
Kevin Russell
Group MD & CEO
Bob Mansfield
Chairman
ABOUT VOCUS
We are proud to have built a world class telecommunications infrastructure platform across Australia and New Zealand to support the rapid growth in demand for increasingly resilient, secure and reliable network connectivity. Our Australian fibre network connects capital mainland cities with Auckland, stretching across the Tasman and connecting north and south islands of New Zealand, and to the United States, Singapore and Hong Kong.
We are Australia’s fourth largest telecommunications provider and New Zealand’s third largest by revenues. Vocus is listed on the Australian Securities Exchange under the ticker VOC and is headquartered in Melbourne.
Our electricity for supply to customers is sourced from the grid via the Australian Electricity Market Operator, and our gas for supply to customers is purchased from upstream suppliers; we do not own any generation or distribution assets.
Further details of our financial position and performance are included in our FY18 Annual Report at https://vocusgroup.com.au/investors/company-performance/annual-reports/.
There have been no significant changes to our organisation or its supply chain during FY18.
VOCUS GROUP
Vocus operates across all states and territories of Australia and across the North and South Islands of New Zealand. Our primary go-to-market brands and services are shown in the following table. Our employment statistics are included in section 6.
AUSTRALIA
CONSUMER
dodo
A promise to deliver simplicity and fairness to our customers.
iPrimus was one of Australia’s first true broadband challengers.
ENTERPRISE & WHOLESALE
VOCUS communications
Strong, reliable connectivity
engin
Leading IP voice provider
COMMANDER
Business Communications
5,500 buildings on-net
7,000KM fibre network in NZ
23 Data Centres in Aus and NZ
More than 2,800 team members in the Philippines, employed through a business process outsourcing partner
**NEW ZEALAND**
**CONSUMER**
- **Slingshot**: Broadband for Kiwi families
- **Flip**: Cheap and cheerful broadband
- **Switch Utilities Ltd**: Energy services to larger asset owners
- **Orcon**: Driving innovation in the NZ market
**ENTERPRISE & WHOLESALE**
- **Vocus Communications**: For Businesses, Government and Wholesale
- **Talk**: Provider of VoIP
PRIORITIES AND ACHIEVEMENTS
FY18 ACHIEVEMENTS
**Community**
Against our target of increasing Volunteering by 5%, we achieved:
- An increase in the number of team members giving their time of 196%;
- An increase in the number of hours given to charities of 148%.
**Suppliers**
Introduction of a Procurement Team with roadmap to supplier screening to ensure standards of environmental and social governance are met and that, as far as possible, we source from companies that meet our criteria.
**Environment**
We achieved a reduction in customer invoice printing of 0.2%.
**Diversity**
While our gender diversity statistics reflected a decline at the senior leadership level at the end of the period, a number of appointments after 30 June improve this balance and reflect on the commitment of the new management team to diversity.
**Team**
75 team members participated in our Leadership Development Program and 32 participated in our Mentoring Program.
Won Customer Service Team of the Year (small) in our Enterprise & Wholesale segment.
FY19 PRIORITIES
We will aim to maintain this high level of charitable activity and increase the number of team members participating in skilled volunteering by 5%.
Review supply to ensure that, where possible, we are making the best choice to meet the needs of our environment and stakeholders.
We commit to improving the gender balance at the senior leadership level in FY19.
We have recruited an Executive dedicated to People and Culture, starting in September 2018, to optimise the substantial asset that is our team.
In addition to a number of initiatives in place to improve our customer service in FY19, we have promoted our GM of Assurance and Delivery to the Executive Team, ensuring that our Customer has a seat at the Executive table.
1. HOW WE CREATE VALUE
$1.9b Revenue
More than 2000 team members in Australia & New Zealand
10% Almost 10% of team members participate in Workplace Giving
274 team members participated in volunteering and giving back to the community
$366.1m Underlying EBITDA
We invest in our leaders and graduated the next round of team members from our Leadership Development Training
$47,000 More than $47,000 raised through workplace giving
Our commitment to our customer experience was awarded by the Customer Service Institute of Australia
FINANCIAL IMPLICATIONS AND OTHER RISKS AND OPPORTUNITIES DUE TO CLIMATE CHANGE
The company has not yet identified any material financial implications, risks or opportunities arising in relation to climate change.
DEFINED BENEFIT PLAN OBLIGATIONS AND OTHER RETIREMENT PLANS
Vocus has no defined benefit plan obligations.
FINANCIAL ASSISTANCE RECEIVED FROM GOVERNMENT
Vocus has not received any material financial assistance from government other than research and development tax credits generally available to Australian businesses.
2. STAKEHOLDER ENGAGEMENT
Our stakeholders are our shareholders, our customers, our suppliers, the governing bodies of our industry and our Team. We engage with stakeholders regularly in the ordinary course of business and through dedicated requests for feedback in a manner appropriate to each group.
**STAKEHOLDER ENGAGEMENT**
**Team**
We recognise the value of our Team Members and the positive impact – both internally and externally – of an engaged and motivated Team.
Our Team Members have multiple avenues to provide feedback on their work, workplace, benefits and levels of engagement throughout the year.
We conduct weekly Team surveys via an online engagement tool which provides real-time, anonymous feedback to managers in their team and which also provides the opportunity for managers to respond to that feedback immediately.
We communicate regularly with Team Members through methods including a private social network for Vocus Team Members, an e-mail newsletter, face to face briefings with our CEO and Executive Team and recorded video messages to brief Team Members on major events occurring in the business.
The aim of our communication strategy is to keep team members informed, provide the opportunity for a two-way conversation and ensure understanding of our goals and priorities.
**Shareholders**
Our investor relations team aims to ensure all shareholders receive information in an equal and timely manner and encourages an open dialogue with investors through a variety of forums.
Our Annual General Meeting (“AGM”) provides shareholders the opportunity to discuss the financial, operational, and ESG performance of the business with directors and management. We endeavour to make this opportunity available to all shareholders and interested parties through an audio webcast of the event. From time to time we hold Investor Days which are also made available for shareholders to view and interact via a webcast. Shareholders can also pose questions through our dedicated investor email address (firstname.lastname@example.org).
Our CEO and at times, management team, also engage in institutional and equity analyst events, presentations to brokers and investor briefings.
Any presentation containing new information about the company or its performance is released to the ASX.
**Suppliers**
We value our supplier relationships and meet regularly with our major suppliers. As detailed in the Product Responsibility section of this report, in FY18 we established Procurement function to lead a coordinated and consistent approach to achieve the best possible commercial outcomes.
**Customers**
An overview of our engagement with our wide range of customers is included in the Social Sustainability section.
**Regulators**
We aim to have an open and constructive relationship with all regulators.
3. ETHICS, INTEGRITY AND GOVERNANCE
Vocus is committed to a sound corporate governance framework. We believe in transparency, accountability and integrity for the benefit of our shareholders, team members, customers and all other interested stakeholders.
Our corporate governance policies and charters are published on our website and are reviewed at least annually in reference to the Corporate Governance Principles and Recommendations, as developed by the ASX Corporate Governance Council.
The FY18 Annual Report contains details of our governance structure and is also available at http://vocusgroup.com.au/about-us/corporate-governance/. The Audit and Risk Committee, as described in its charter, is responsible for advising the board in relation to the management of risks which may impact on the community or environment in which Vocus operates.
CODE OF CONDUCT
Vocus has adopted a Code of Conduct which describes the company’s expectations of its Team Members, management and directors in relation to ethical behaviour, the treatment of conflict of interests, confidentiality and the use of company resources. We have also established a whistle-blower policy, providing a procedure for reportable conduct.
ANTI-BRIBERY AND CORRUPTION POLICY
We have adopted an Anti-Bribery and Corruption Policy providing to Team Members plain language guidance on what is and is not acceptable conduct when negotiating with suppliers, customers and other interested parties. This policy is available to all team members on our external website as well as on our intranet. Where Vocus is conducting procurement on behalf of the Commonwealth, we have adopted Fraud Control strategy to manage compliance with the Commonwealth Fraud Control Framework.
ONLINE TRAINING
Through our online Learning Centre we have produced and implemented a number of compliance modules to train team members on their responsibilities and our guidelines in the areas most crucial to our operations, including privacy and information security, workplace health and safety, anti-bullying and harassment. All permanent team members are required to complete this training and it is refreshed annually.
4. ENVIRONMENT
A. ENERGY CONSUMPTION – OFFICES AND DATA CENTRES
Our data centres are the primary source of electricity usage across the group, with our office spaces representing a secondary pool of electricity usage.
As large consumers of electricity, Vocus Data Centres continually reviews its operations to ensure we can operate our facilities in the most efficient manner possible. To minimise our energy usage and impact on the environment in this area, we have implemented the following measures:
- micro misting solutions to cool ambient temperature and reducing cooling infrastructure power usage
- use of Heatpump technology to reduce traditional heating, resulting in significant power usage reductions
- continued participation in an e-waste recycling program for old legacy hardware (after securely erasing confidential information)
- Hot and Cold Aisle separation to the data halls. By separating the supply and return air, the cooling plant operates in a more efficient manner, thereby reducing the load for each facility whilst also providing a more stable environment for clients. In addition, blanking panels are utilised in all data halls to ensure that the facility air separation is as effective as possible
- Adoption of cooling recommendations from ASHRAE (American Society of Heating, Refrigerating and Air-Conditioning Engineers) throughout all facilities nationally allowing for an environment acceptable to modern computing equipment whilst also reducing the total power consumption required to meet the standards
- the use of best-in-class cooling technology such as PowerPax and Uniflair Chillers with Turbocor compressor technology reducing power consumption
- Investment in class leading Air Conditioning technology with Variable speed compressors and EC Fans to minimise power consumption
- Ongoing automation of Air Conditioning strategies via our DCIM (Data Centre Infrastructure Management) systems to ensure that redundancy is maintained whilst also reducing power consumption
- Replacement & consolidation of legacy UPS systems resulting in significantly reduced electrical system losses
In relation to our office spaces, we work to secure locations with a high energy efficiency rating. Our Sydney, Melbourne and Perth offices have 5 star or above NABERS Energy ratings. We continue to use our premium quality video conferencing equipment throughout our offices as an alternative to travelling, reducing our emissions while maintaining face to face meetings.
We have commenced the collation of data to analyse energy usage across our business, and in our 2019 report we plan on publishing data in accordance with GRI Disclosure 302-1.
B. PRODUCTS AND SERVICES – SALE OF ELECTRICITY
In addition to the usage of electricity in our operations, we are also a retailer of electricity and gas through our Dodo and Commander brands in Australia and Slingshot and Switch brands in New Zealand.
Australia
Our licenses to sell energy products are held in the M2 Energy entity. We offer customers the opportunity to purchase 10% or 100% green energy. M2 Energy (through our Dodo Power & Gas brand) is an accredited GreenPower supplier, and provides 10% and 100% GreenPower options to its customers, supporting clean and renewable sources of electricity such as solar biogas, biomass, hydro, and wind generation. When a customer chooses 10% or 100% Dodo GreenPower, that percentage of their electricity consumption is abated with Accredited Renewable Energy Certificates created from renewable electricity that has already been supplied into the electricity grid. This electricity replaces the same amount of energy that would otherwise have been sourced from fossil fuels such as coal.
In respect of the 2017 compliance year we purchased over 187,000 Renewable Energy Certificates (2016 compliance year: purchased 239,000 Renewable Energy Certificates) in order to acquit our liabilities under the various clean energy schemes.
M2 Energy also participates in the Commonwealth’s Renewable Energy Target, New South Wales Energy Saving Scheme, the Victorian Energy Efficiency Target and the South Australia Retailer Energy Efficiency Scheme.
New Zealand
New Zealand, which in 2014 ranked in the top five countries in the world for its percentage of renewable energy generation, uses hydro, thermal, geothermal, wind and, where necessary, cogeneration for wholesale market supply. Approximately 80% of electricity generated in New Zealand was through renewable sources in 2014\(^1\), where supply of electricity isn’t elected by the type of generation.
Following the launch of our telco and electricity bundle offering to New Zealand residential customers in FY17, in FY18 Vocus was amongst the fastest growing energy retailers in New Zealand.
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1. Source: Electricity in New Zealand, New Zealand Electricity Authority, https://www.ea.govt.nz/
Vocus Sustainability Report 2018
C. MINIMISING OUR IMPACT – CONSTRUCTION OF THE AUSTRALIA SINGAPORE CABLE
The Australia Singapore Cable (ASC) is a ~4,600km undersea cable linking Perth to Singapore and Indonesia.
During FY18, in partnership with Alcatel Lucent Submarine Networks we substantially completed the construction of this new sub-sea cable. In early FY19, the lay of the cable was completed and the cable progressed to Ready For Service stage, beginning to service our customers in early September.
The cable offers an approximate 30% redundancy in latency from Sydney to Singapore, compared with alternative routes.
Environmental Impact
During the project’s planning phase, an environmental assessment was carried in relation to the cable route through Australian waters. The scope of the assessment included:
- an assessment of the impacts of the proposed works on the environment and the impacts of the environment on the proposed works;
- Identification of relevant aspects of the existing environment that may affect the placement or long term integrity of the submarine cable, or may be potentially impacted by the proposed cable placement and maintenance activities; and
- Identification of specific environmental management principles which should be adopted in the placement and maintenance of the cable in order to avoid or mitigate any potentially adverse impacts; and take into account comments and/or issues raised in the consultation process.
The potential impact of the cable laying activities were assessed in relation to the physical environment (including water depths, currents and sea bed conditions), biological environment (impacts on marine habitats, areas of conservation significance, impacts on fisheries, diving and other cables), natural and cultural heritage (maritime archaeological items and Aboriginal heritage); and social and economic issues.
As a result of the assessment, various safeguards were identified to minimise the environmental impact of the project. These safeguards and recommendations have been adopted in the management of the ASC project.
D. MINIMISING WASTE – HARDWARE
In our offices and warehouses we support Mobile Muster as means of reclaiming materials from recycled mobile phones. We also routinely recycle all cardboard waste from our warehouses.
We participate in electronic product stewardship and are members of the Electronics Product Stewardship Australasia NCTRS co-regulatory arrangement. Through this arrangement we share in the responsibility for minimising damage to the environment through the recycling of computers, televisions and other used electronic equipment.
Our Pendo business was discontinued during the course of FY18. It previously sold mobile phones, tablet computers, televisions and smart watches through national retailers and through the Pendo website.
E. PRINTING REDUCING PAPER WASTE
Printing of customer invoices in our Australian consumer brands is one of our most significant uses of paper resources across the organisation. We are working to reduce the incidence of paper invoices, and though this option will always be available upon request, our default billing option for new customers signing up to a telco or energy plan is to receive invoices in an electronic format. By June 2018, 8.2% of our Consumer and Small Business invoices were printed, in comparison to 8.4% of all invoices which were generated in a paper format a year ago.
In FY18, all paper purchased for use within the business was carbon neutral and from 20% recycled materials. To further minimise our paper waste, we use DocuSign, an electronic document signing tool, and have rolled it out across many parts of our business including lease renewals, franchise agreements, dealer agreements and terminations and insurance proposals as well as for internal purposes such as employment agreements.
5. SOCIAL SUSTAINABILITY – TEAM
A. DIVERSITY AND EQUAL OPPORTUNITY
Vocus values and encourages diversity in the workforce. We recognise the benefit gained from having a diverse range of individuals involved in our organisation and business activities. We acknowledge that a range of perspectives is imperative to making good, balanced decisions that are in the interests of our Company as a whole. A diverse workplace promotes Vocus as an employer of choice, which in turn attracts key talent at all levels. We are committed to providing an environment in which our entire team is treated fairly and with respect, with equal opportunity and access to available opportunities. In respect of gender diversity, female participation in the workplace adds value and as such, we are committed to implementing and supporting initiatives and processes to help facilitate equal gender participation and opportunity in our business.
Vocus will not permit discrimination, intimidation or harassment of, or by, team members on the basis of race, gender, marital status, national origin or religious beliefs, or on the basis of any other personal characteristics protected by law. We recognise the importance of valuing the many differences in background, culture and demographic characteristics of our team members.
In relation to equality in gender pay, we complete an annual gender pay equality review to work towards avoiding the opportunity for any unconscious bias in remuneration decisions.
Our Team by the Numbers
At 30 June 2018:
| Employment Status | Male | % of total | Female | % of total | Total | % of total |
|-------------------------|--------|------------|--------|------------|-------|------------|
| Permanent full time | 1,393 | 93.3% | 481 | 81.1% | 1,874 | 89.8% |
| Permanent part time | 22 | 1.5% | 48 | 8.1% | 70 | 3.4% |
| Contractor | 30 | 2.0% | 31 | 5.2% | 61 | 2.9% |
| Casual | 48 | 3.2% | 33 | 5.6% | 81 | 3.9% |
| **Total** | **1,493** | **95.5%** | **593** | **95.3%** | **2,086** | **100.0%** |
Gender diversity
| | Number of females | % of total |
|----------------------|-------------------|------------|
| Board | 2 | 25% |
| Executive Leadership Team | 2 | 29% |
| Senior Leadership Team | 10 | 21% |
At 30 June 2017:
| Employment Status | Male | % of total | Female | % of total | Total | % of total |
|-------------------------|--------|------------|--------|------------|-------|------------|
| Permanent full time | 1,447 | 91.8% | 545 | 80.4% | 1,992 | 88.4% |
| Permanent part time | 26 | 1.6% | 46 | 6.8% | 72 | 3.2% |
| Contractor | 16 | 1.0% | 20 | 2.9% | 36 | 1.6% |
| Casual | 87 | 5.5% | 67 | 9.9% | 154 | 6.8% |
| **Total** | **1,576** | **95.5%** | **678** | **95.3%** | **2,254** | **100.0%** |
Gender diversity
| | Number of females | % of total |
|----------------------|-------------------|------------|
| Board | 1 | 17% |
| Executive Leadership Team | 1 | 14% |
| Senior Leadership Team | 17 | 29% |
A range of functions supporting the Consumer and Commander business are provided by a workforce in the Philippines who are employed by a third-party business process outsourcing partner. These functions include inbound and outbound sales teams, customer service, technical support, provisioning and credit control.
B. MANAGEMENT RELATIONS/SUPPORTING OUR TEAM
In the event of an operational change impacting our team members, we provide the team with reasonable notice of any change. Where appropriate, we offer outplacement counselling and the option to apply for other vacant roles within the organisation including the payment of a relocation allowance in some instances.
The number of team members who are subject to a collective agreement is not material.
C. WORKPLACE HEALTH AND SAFETY
As part of our Team Benefits program, our Team Members have access to fresh fruit and breakfast daily. To further support team health and reduce risks associated with a sedentary lifestyle, all Team Members in our Melbourne and Sydney offices have access to standing desks. In FY18 we have also started to introduce Fitness Passport to team members in some states, and will complete the roll out to the remainder of our team members this calendar year, allowing team members to benefit from a subsidised health club membership for themselves and their immediate family.
As part of our Sustainability Principles, we are committed to the establishment of a safe place of work, safe working practices and procedures and the provision of safe plant and equipment. We have workplace health and safety committees to give team members a forum to raise concerns about any aspect of safety in the workplace. This is in addition to online training covering WHS topics such as anti-bullying and harassment.
In FY18 we have created a new Field WHS role to assist us in providing safe work practices for our field-based team.
In the year to 30 June 2018 we have not experienced any significant lost time injuries and believe that our experience of injuries, as evidenced by our WorkCover premium rates, in line with or better than industry norms.
D. TRAINING AND EDUCATION
We continue to invest in training for Team Members across all areas of the business, using the 70:20:10 philosophy of learning and development. 10% of training is delivered face to face in a classroom environment, 20% of training is delivered through coaching, 360 degree feedback surveys, networking and mentoring, and 70% of training is delivered through on the job practice, work assignments and projects.
5. SOCIAL SUSTAINABILITY – TEAM / CONTINUED
E. INVESTING IN OUR LEADERS
Leadership Development Program
We have continued our partnership with the Australian Institute of Management and delivered 6 full days of leadership training which took place over 8 months. 75 leaders participated in this round of the Vocus Leadership Development Program (LDP).
The program represents an investment of 3,375 training hours. The aim of the program is to develop the current and next generation of Vocus leaders by developing leadership skills and knowledge underpinned throughout the course by a reinforcement of the Vocus values. Participants were selected by nomination from all areas of the business including Consumer, Legal & Human Resources, Technology, Enterprise & Wholesale.
We also have dedicated training resources attached to a wide variety of teams across the business including our Dodo Connect kiosks, Commander brand, Vocus Corporate and Wholesale team and attached to our sales and customer service team in Manila. All Team Members can access the Vocus Learning Centre, learning platform where a variety of internal training programs are uploaded, including compliance training.
F. SUPPORTING FAMILIES
We recognise the importance of family in the happiness and wellbeing of our Team, and the importance of support for family. Other ways that we support families includes:
- Our Purchased Leave program, allowing our Team Members to purchase up to two additional weeks of annual leave per year
- Our “Five for Five” policy which grants an additional week of annual leave each year to all Team Members with 5 years’ service
- The option for our Australia-based Team Members to take Long Service Leave at half pay to double the leave time, subject to operational requirements
- Paid Parental leave
- The right for anyone to request flexible working hours or arrangements, subject to operational requirements
- An Employee Assistance Program that provides professional counselling on demand to Team Members
VOCUS MENTOR PROGRAM
We run an inhouse mentor program which currently has 32 mentors and mentees learning from each other. The mentees gain great insight into areas outside their area of expertise and benefit from an experienced leader. This is a mutually beneficial arrangement which has received positive feedback on engagement and development from both mentors and mentees.
Lynda.com
Every team member at Vocus has a subscription to Lynda.com whose training platform has 10,000 training videos. The Lynda.com library covers a wide range of topics from technical skills, time management to career development and leadership. In the 12-month period from April 2017 – May 2018, Vocus team members spent 2,403 hours taking part in online training and have completed over 600 courses.
Study Assistance
We offer study leave, study days and study support to team members where the course undertaken is relevant to their role and the business. Where possible, team members are encouraged to use Vocus projects as part of their course.
6. SOCIAL SUSTAINABILITY – PRODUCT RESPONSIBILITY
A. CUSTOMER SATISFACTION AND EXPERIENCE
We recognise the importance of our customers and their experience with us, and we constantly look for ways to improve our customer experience.
We pride ourselves on dealing with our customers via their preferred method, whether by phone, online chat or account management tools.
In the past year, our focus on customer satisfaction in our Consumer segment has led to the following activities:
- Detailed analysis of the operating rhythm for our consumer contact centres. The resulting improvements focused on enhanced change management, optimisation of workforce management and cross-departmental communication. We also introduced new quality models, agent scorecards and revised agent metrics with a stronger focus on quality as well as productivity.
- Implementation of comprehensive agent soft skill workshops to reduce jargon and a focus on understanding customer needs that helped drive shorter calls, faster responses to customers and improved first call resolution.
- Relaunch of our iPrimus brand with new flexible plan options and a new online self-service toolbox with enhanced features.
- Implementation of Salesforce customer relationship management software in iPrimus, which improved case management and customer analytics and reporting. It also enabled the introduction of a comprehensive knowledge management system to enhance agent knowledge and customer experience.
In October 2017, our Enterprise & Wholesale Australia Service Delivery Team was awarded the Team of Year at the Customer Service Industry of Australia awards, along with several individual awards for Manager of the Year, Customer Advocate of the Year and the Service Hero award for our Voice of the Customer program. These awards recognised Vocus for their focus and commitment in their journey towards service excellence.
As part of our iPrimus relaunch, we introduced Pause For Us Time and Pause Your Bill.
We listened to our customers and introduced Pause for Us Time: the ability for customers to pause internet access on devices in their homes in order to allow for more family time. At the same time, we introduced Pause Your Bill: the ability for customers to pause their internet (and billing) while away on holidays.
Customer Engagement and Dialogue
Understanding our customers is key to our success. We continue to use customer satisfaction surveys and use Net Promoter Score to monitor customer satisfaction.
In both Australia and New Zealand, we survey customers at various points during their time with us to provide opportunity for feedback on satisfaction and actively identify any issues, enabling a dialogue as well as direct communication of customer happiness.
As part of our award-winning Voice of the Customer program, we survey all customers at the end of each interaction. We gather transactional net promoter score and customer satisfaction measures as well as providing customers the opportunity to provide additional real-time feedback. The feedback is used to recognise our high performing team members who are consistently achieving a high level of customer service, and drive business improvement initiatives where required.
6. SOCIAL SUSTAINABILITY – PRODUCT RESPONSIBILITY / CONTINUED
Procurement
During FY18 Vocus has established a procurement office covering both telecommunications and technology purchases and other goods and services.
We have developed a request for proposal (“RFP”) process designed to open up participation in our procurement to a wide pool of potential suppliers, though due to the highly specialist nature of the goods being purchased and in part due to regulatory requirements we have limited ability to seek out locally based suppliers or promote economic inclusion. We offer fixed payment terms to all suppliers. The Procurement function is in the early stages of introduction and process improvement, following which it will build into our RFP process a requirement for suppliers to comply with our Sustainability Principles.
B. MARKETING COMMUNICATIONS
Vocus adopts rigorous review processes to ensure that the marketing campaigns undertaken by its business units comply with all relevant laws and codes, including both the Competition and Consumer Act and the Telecommunications Code of Practice.
NBN speeds have been a focus of the industry over 2017 and 2018 and this focus will continue. In FY18, Vocus undertook a review of the speeds attainable by our customers on the NBN and found that in a small number of cases, the FTTN and FTTB services were not capable of achieving the customer’s chosen speed plan. Vocus has voluntarily provided an Enforceable Undertaking to the Australian Consumer and Competition Commission (“ACCC”) in respect of these customers in the Dodo, iPrimus and Commander brands and has proactively contacted these customer to offer compensation and options for going forward. Vocus has also committed to performing speed checks on newly connected NBN services in order to ensure that the service provided matches that which has been requested. Vocus is also cooperating with the Australian Communications and Media Authority (“ACMA”) in relation to an investigation into whether Dodo and iPrimus comply with the requirements of the Do Not Call Register Act and the Telemarketing and Research Industry Standard.
C. CUSTOMER PRIVACY
Vocus is committed to maintaining the privacy of all personal information collected and retained within the business for the safety and security of our customers and in accordance with our compliance obligations. Vocus is regulated by the Australian Privacy Principles and has provided a detailed Privacy Policy on each of our customer-facing websites setting out the ways in which we collect personal information and how it is used. We place contractual obligations to maintain privacy of customer information in all relevant contracts, for example with our BPO partner in Manila. This year, at the commencement of the Notifiable Data Breach Reporting Scheme, we provided face to face training to team members and refreshed our Data Breach Response Plan.
D. PUBLIC POLICY
Vocus did not make any cash or in kind political contributions in FY18.
Vocus participation in public policy development or lobbying is primarily under the auspices of our membership of the Communications Alliance, a lobbying group representing interests in the telecommunications industry. We have participated in working groups on subjects including the Telecommunications Sector Security Reforms, information security and privacy issues.
Vocus Sustainability Report 2018 | 17
7. COMMUNITY
Vocus is active in local communities in a variety of ways and supports a number of charities. Below are the highlights of our charitable and community activity in FY18.
A. TELCO TOGETHER FOUNDATION
Our national partner for charitable and volunteering activity is the Telco Together Foundation (TTF). (“TTF”) was seeded in 2011 by our former Chairman, Vaughan Bowen. TTF unites Australian IT&T companies for the purpose of fundraising for a number of key charities that support communities in need, focussing on mental health, homelessness, food insecurity and indigenous communities. All leading Australian telecommunications companies are members of the TTF.
Our General Counsel Ashe-lee Jegatheesan is a member of the advisory board. We supply the TTF with office space and supplies and pay a yearly membership fee of $50,000.
Other avenues through which the Vocus Team supports fundraising for the TTF include nominating the Foundation as its charitable partner for its annual Commander Channel Partner Conference, and through our Workplace Giving Program.
B. WORKPLACE VOLUNTEERING AND GIVING
Vocus offers to all permanent Team Members the right to spend two days doing paid voluntary work each year.
We also run a workplace giving scheme where Team Members can make a regular charitable donation to the Telco Together Foundation through our payroll. We have generated over $47,000 of donations through this scheme in FY18.
Vocus team from across Australian offices have made a significant contribution by volunteering with a number of charities including Ronald MacDonald House, Foodbank and the Salvos providing much needed time in their facilities to support disadvantaged communities.
In FY18 against our target of increasing Team Volunteering by 5%, we achieved an increase in the number of team members giving their time of 196% and an increase in the number of hours given to charities of 148%.
C. SMALL CHANGE BIG CHANGE
Small Change Big Change (SCBC) is an on bill donation initiative to increase the fund raising capacity of the non-profit sector by leveraging the reach of the telecommunications industry.
From 2013 – 2016 TTF partnered with Commander/Vocus to scope and then undertake a pilot. Since then they have continued to support this initiative, with 100% of the donations raised distributed to the Telco Together community charity partners. To date SCBC through donations from Commander customers has raised $200K to support disadvantaged Australians.
D. PROVISION OF INTERNET CONNECTIVITY TO THE TIWI ISLANDS
In FY18 Vocus agreed to work with the Northern Territory government to provide at cost a new source of internet connectivity to the Tiwi islands, 80km north of Darwin. This new connection will be provided as a spur of the North Western cable system and will replace the existing ageing infrastructure and provide more resilient and faster internet speeds for residents.
E. VOCUS PARTNERSHIP WITH STARLIGHT FOUNDATION
Proudly supporting
Starlight children’s foundation
We continued our partnership with the Starlight Children’s Foundation to support and raise funds to aid in brightening the lives of sick kids across Australia. We provide funding for remote paediatric clinic visits, and a ‘fly in/fly out’ clinic in partnership with the Northern Territory Department of Health which provides specialist paediatric care to remote indigenous communities, with the fun, interactive and educational presence of the Starlight Captains. We also support the Starlight Foundation’s Bush Week, a series of shows with health and lifestyle messages delivered to schools in remote communities that Starlight visits in partnership with NT Health Department paediatricians.
F. VOCUS SCHOLARSHIP WITH CHARLES DARWIN UNIVERSITY
We have funded two scholarships of $5,000 each for students enrolled in IT subjects at Charles Darwin University. The scholarship is intended to cover course fees and laptops, and we also provide a broadband connection to scholarship recipients for the duration of their course. We also offer a paid work experience placement of a minimum of two weeks to help the recipients in developing their workplace skills and networks.
G. CHARITABLE CONTRIBUTIONS IN MANILA
We have a significant number of team members in Manila, employed via our BPO partner Acquire as the largest base of our customer service and inside sales teams. They have participated in the following community activities this year:
Christmas outreach program
During December 2017 Acquire invited over 160 children from the Children’s Joy Foundation to have a Jollibee Christmas Party throughout all of our sites. Our employees are then able to make cash donations to this foundation which cares for orphans and abandoned children as part of a non-government organisation based in Manila. In December Php172,174.00 of donations were made from our employees.
Dare to care: Mayon Volcano Relief Mission
One of this year’s Dear to Care Projects was to help support the 22,398 families who were left homeless due to the phreatomagmatic eruption that occurred on the 13 January 2018. Employees sponsors under the Acquire Dare to Care program volunteered to assist with the repacking of relief goods at the department of Social Welfare & Development centre.
Dare to care: Bridgada Eskwela
This Dare to Care project was to help prepare 6 classrooms at a local public school Pateros Elementary School which was assigned to Acquire BPO. The team was tasked with helping to repainting, repairing and cleaning of the classrooms in time for the opening of the classes in June. This was to ensure that the start of the new school year provided a warm and inviting learning environment for both students and teachers.
H. THE VISIBILITY PROJECT
Connecting Cultures
The Visibility Project is committed to increasing the visibility of positive Indigenous role models.
In its first year, The Visibility Project sought to:
- increase the visibility of Indigenous excellence and contributions to current culture
- increase the visibility of a successful Indigenous Australian, via a culturally important avenue of music and dance
- increase the connection of non-Indigenous Australians with Indigenous language and culture
In FY18, The Visibility Project supported a young musician, dancer and former community health advocate from Arnhem Land. Danzal Baker, aka Baker Boy, writes and performs music in Yolngu Matha language and his single Marryuna is the first Indigenous language rap to be added to regular rotation on Australian radio.
8. MANAGEMENT APPROACH: IDENTIFIED MATERIAL ASPECTS AND BOUNDARIES
When determining materiality, we consider external stakeholder perspectives as well as internal business impact, within the context of the GRI 103 “Management Approach”.
The following aspects have been identified as material to Vocus while defining the content of this Sustainability report:
| Category | Material Aspects |
|---------------------------------|-------------------------------------------------------|
| Environmental | Use of materials |
| | Energy consumption |
| | Products and services |
| Social – labour practices | Employment |
| | Labour/management relations |
| | Workplace health and safety |
| | Diversity, equal opportunity and non-discrimination |
| | Training and education |
| Social – product responsibility | Customer satisfaction |
| | Marketing communications |
| | Customer privacy |
| | Public policy |
| Economic | Economic performance: this aspect is discussed in the Annual Financial Report. |
A list of all entities included in the Vocus consolidated financial report is included in the notes to the accounts of the FY18 Annual Report.
## APPENDIX: REQUIRED DISCLOSURES FOR REPORTS PREPARED USING THE CORE APPROACH TO THE GRI STANDARDS
| Required criteria | Core option |
|-----------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------|
| Use the correct claim (statement of use) in any published materials with disclosures based on the GRI Standards | Include the following statement: ‘This report has been prepared in accordance with the GRI Standards: Core option’ |
| Use GRI 101: Foundation to follow the basic process for preparing a sustainability report | Comply with all requirements in Section 2 of GRI 101: Foundation ('Using the GRI Standards for sustainability reporting') |
| Use GRI 102: General Disclosures to report contextual information about the organisation | Comply with all reporting requirements for the following disclosures from GRI 102: General Disclosures:
- Disclosures 102-1 to 102-13 (Organisational profile)
- Disclosure 102-14 (Strategy)
- Disclosure 102-16 (Ethics and integrity)
- Disclosure 102-18 (Governance)
- Disclosures 102-40 to 102-44 (Stakeholder engagement)
- Disclosures 102-45 to 102-56 (Reporting practice) |
| Use GRI 103: Management Approach to report the management approach and the topic Boundary for all material topics | For each material topic, comply with all reporting requirements from GRI 103: Management Approach. Reasons for omission are only permitted for Disclosures 103-2 and 103-3 (see clause 3.2) |
| Use the topic-specific GRI Standards (series 200, 300, 400) to report on material topics | For each material topic covered by a topic-specific GRI Standard:
- comply with all reporting requirements in the 'Management approach disclosures' section
- comply with all reporting requirements for at least one topic-specific disclosure
For each material topic not covered by a GRI Standard, it is recommended to report other appropriate disclosures for that topic (see clause 2.5.3)
Reasons for omission are permitted for all topic-specific disclosures (see clause 3.2) |
| Ensure that reasons for omission are used correctly, if applicable | Comply with all requirements in clause 3.2 (Reasons for omission) |
VOCUS GROUP
|
Mutants of lactobacillus casei defective in carbon catabolism regulation
The invention relates to the use of mutants of L. casei having at least a mutation impairing the regulation of a carbon catabolite repression (CCR) mechanism involving the PTS protein HPr, for the preparation of a food product.
The use of said mutants allows for instance to impart to said food products an improved texture and flavor, and/or a higher content in aroma compounds.
Description
[0001] The present invention relates to mutant strains of bacteria of the group *Lactobacillus casei* defective in a carbon catabolism regulation pathway, and to their use in the processing of fermented foods.
[0002] As defined herein, the group *Lactobacillus casei* includes the species *L. casei*, as well as the species *L. paracasei* (formerly *L. casei* subsp. *paracasei*), *L. rhamnosus* (formerly *L. casei* subsp. *rhamnosus*) and *L. zeei*. Those species are phylogenetically very closely related to each other and their respective 16S and 23S rDNA genes always show a similarity greater than 97.5% [MORI et al., Int. J. Syst. Bacteriol., 47, 59-57, (1997)].
[0003] *L. casei* is recognized as a probiotic, i.e. a live microbial feed supplement having a positive effect on the health of the consumer, and is widely used as a starter in dairy industry and in the preparation of fermented food, more specifically food containing living ferment.
[0004] Carbon catabolite repression (CCR) is a regulatory mechanism allowing bacteria to choose between different carbon sources according to their metabolic value and to switch from a carbon source to another depending on their availability in the growth medium. A well-known manifestation of catabolic repression is the diauxic growth that occurs when bacteria are grown in presence of both glucose and lactose. Diauxic growth curves show two distinct phases of exponential growth, separated by a lag phase. During the first phase of growth, glucose represses the synthesis of the enzymes necessary for lactose utilisation, and is therefore the only source of energy of the bacteria. When all the glucose is exhausted occurs the lag phase, during which the enzymes for lactose utilisation are synthesised, allowing lactose to be used as a source of energy during the second phase of growth.
[0005] A main target of catabolite repression is the transport of sugars into the bacterial cell. In *L. casei*, this transport is predominantly performed by the phosphoenolpyruvate:carbohydrate phosphotransferase system (PTS).
[0006] The PTS of gram-positive bacteria has been studied mainly in *Bacillus subtilis*; it has been shown that it effects the phosphorylation of sugars and their transfer into the cell through a cascade of phosphorylations involving the general non-sugar-specific enzymes EIa, EIIb, and EIIIc. The first step is the phosphorylation of EI from phosphoenolpyruvate (PEP). The phosphorylated EI (E-I-P) catalyses the phosphorylation of HPr, at the catalytic His-15. HPr phosphorylated at His-15 (designated as P-His-HPr) transfers its phosphoryl group to EIia, which in turn phosphorylates EIIb. Phosphorylated EIIb (P-EIIb) associated with the membrane protein EIIc, catalyses the simultaneous uptake and phosphorylation of a specific carbohydrate.
[0007] It has been shown that components of the PTS, and more specifically the enzyme HPr, are also involved in other regulatory pathways.
[0008] For instance, P-His-HPr can transfer its phosphoryl group also to non-PTS proteins, such as glycerol kinase [CHARRIER et al., J. Biol. Chem., 272, 14166-14174, (1997)] or antiterminators and transcriptional activators possessing the PTS regulation domain (PRD) which contains several phosphorylation sites recognised by P-His-HPr [TORTOSA et al., J. Biol. Chem., 272, 17230-17237, (1997); STÜLKE et al., Mol. Microbiol., 28, 865-874, (1998); LINDNER et al., Mol. Microbiol., 31, 995-1006, (1999)]. In all cases, P-His-HPr-dependent phosphorylation leads to the activation of the function of the non-PTS proteins and this phosphorylation has been shown to serve as a secondary carbon catabolite repression mechanism in Gram-positive bacteria [DEUTSCHER et al., J. Bacteriol., 175, 3730-3733, (1993); KRÜGER et al., J. Bacteriol., 178, 2637-2644, (1996); MARTIN-VERSTRAETE et al., Mol. Microbiol., 28, 293-303, (1998)]. In *Lactobacillus casei*, the antiterminator LacT, which regulates the expression of the *lac* operon, contains two PRD and seems to be controlled by this mechanism.
[0009] In Gram-positive bacteria, HPr may also be phosphorylated by the bifunctional HPr kinase/phosphatase HprK [GALINIER et al., Proc. Natl. Acad. Sci. USA, 95, 1623-1628, (1998); REIZER et al., Mol. Microbiol., 27, 1157-1169, (1998); BROCHU and VADEBONCOEUR, J. Bacteriol., 181, 709-717, (1999); KRAVANJA et al., Mol. Microbiol., 31, 59-68, (1999)]. In *Bacillus subtilis*, this phosphorylation, which occurs at the regulatory Ser-46 [DEUTSCHER et al., Biochemistry, 25, 6543-6551, (1986)], is stimulated by fructose-1,6-bisphosphate and inhibited by inorganic phosphate [GALINIER et al., Proc. Natl. Acad. Sci. USA, 95, 1823-1828, (1998)]. HPr phosphorylated at Ser-46 (designated as P-Ser-HPr), participates in the major mechanism of CCR/carbon catabolite adivation operative in bacilli and presumably other Gram-positive bacteria [DEUTSCHER et al., Mol. Microbiol., 42, 171-178, (1997)]. It functions as corepressor for the catabolite control protein CcpA, a member of the LacI/GalR family of transcriptional repressors/activators [HENKIN et al., Mol. Microbiol., 5, 575-584, (1991)]. The complex formed between CcpA and P-Ser-HPr has been shown to bind to catabolite response elements (*cre*) [FUJITA and MIWA, J. Bacteriol., 176, 511-513, (1994); GOSSERINGER et al., J. Mol. Biol., 266, 665-676, (1997); KIM et al., Proc. Natl. Acad. Sci. USA, 95, 9590-9595, (1998); GALINIER et al., J. Mol. Biol., 286, 307-314, (1999); MARTIN-VERSTRAETE et al., Mol. Microbiol., 28, 293-303, (1999)], operator sites preceding or overlapping the promoters or being located within the 5' region of catabolite repressed genes and operons [HUECK et al., Res. Microbiol., 145, 503-518, (1994)]. For instance, a functional *cre* element is found in the promoter region of the lactose operon *lacTEGF* of *L. casei*, which comprises the genes *lacE* and *lacF* encoding respectively the lactose transport enzymes EIIICb<sub>Lac</sub> and EIIIA<sub>Lac</sub> together with genes encoding an antiterminator protein (*lacT*), and a phospho-beta-galactosidase (*lacG*) [GOSALBES et al., J. Bacteriol., 181, 3928-3934, (1999)].
Genes encoding components of CCR system, and more specifically genes related to the PTS, such as *ptsI* and *ptsH* encoding respectively the enzymes EI and HPr of the PTS system, *hprK* encoding the HPr kinase/phosphatase, and *ccpA* have been characterised in some species of Gram-positive bacteria.
The gene *ccpA* [MONEDERO et al., J. Bacteriol., 179, 6657-6664, (1997)], and the genes *lacT*, *lacE*, *lacG* and *lacF* [GOSALBES et al., referred above; POTER and CHASSY, Gene, 62, 263-276, (1988); ALPERT and CHASSY, Gene, 62, 277-288, (1988); ALPERT and CHASSY, J. Biol. Chem., 265, 22561-22568, (1990); ALPERT and SIEBERS, J. Bacteriol., 179, 1555-1562, (1997)], have been cloned and characterised until now.
The inventors have recently identified, cloned and sequenced the *ptsI*, *ptsH* and *hprK* genes of *L. casei*.
The nucleotide sequence of the *ptsHI* operon, and the peptidic sequences of HPr and EI of *L. casei* are respectively disclosed in the enclosed sequence listing under the identifiers SEQ ID NO: 1, SEQ ID NO: 2, and SEQ ID NO: 3. The sequence of the *hprK* gene is available in GENBANK under the access number Y18948.
The inventors have now studied the effect of mutations in *ptsI*, *ptsH* and *hprK*, as well as the effect of mutations in *ccpA* on growth and metabolic properties of *L. casei*. They found that, surprisingly, *L. casei* strains having mutations impairing the regulation of carbon catabolite repression mechanisms involving the PTS enzyme HPr, and more specifically mutations impairing the regulation of the PTS, and/or mutations impairing the transcriptional regulation of catabolite repressed genes through the binding of the complex CcpA/P-Ser-HPr, possess an improved capacity to produce compounds useful in the food industry, such as aroma compounds and/or polysaccharides.
An object of the present invention is the use of a mutant of *L. casei* having at least a mutation impairing the regulation of a carbon catabolite repression mechanism involving the PTS enzyme HPr, for the preparation of a food product.
Preferably, said mutant is selected from the group consisting of:
a) mutants having at least a mutation impairing the regulation of CCR through P-His-HPr;
b) mutants having at least a mutation impairing the regulation of CCR through P-Ser-HPr.
Mutations of sub-group a) include in particular:
- mutations in genes encoding the components of the PTS, for instance: any mutation in the *ptsH* gene impairing the ability of HPr to be phosphorylated at His-15, or to phosphorylate EIa; any mutation in the *ptsI* gene impairing the ability of EI to phosphorylate HPr at His-15; any mutation in a gene encoding an enzyme EIa, EIb, or EIc impairing the transfer of a phosphoryl group to a carbohydrate;
- mutations in genes encoding antiterminators or transcriptional activators having the PTS regulation domain, for instance any mutation impairing the phosphorylation of any of these antiterminators or transcriptional activators by P-His-HPr and/or by P-EIb or mimicking the phosphorylated form of the antiterminator (for example phosphorylatable histidyl residues mutated to Asp or Glu);
- mutations destroying terminators located in front of genes regulated by antiterminators which are phosphorylated and controlled by P-His-HPr and/or by P-EIb.
Mutations of sub-group b) include in particular: any mutation in the *ptsH* gene impairing the ability of HPr to be phosphorylated at Ser-46; any mutation in the *hprK* gene impairing the ability of HprK to phosphorylate HPr at Ser-46; any mutation in the *ptsH* gene or in the *ccpA* gene impairing the formation of a complex between CcpA and P-Ser-HPr or the binding of said complex to cre elements; any mutation in said cre elements impairing their ability to bind said CcpA/P-Ser-HPr complex.
Non-limitative examples of mutants of *L. casei* which can be used according to the invention are:
- mutants having at least a mutation in the *ptsI* gene resulting in the lack of expression of enzyme EI, or in the expression of an enzyme EI devoid of at least an active domain of wild-type EI. For instance, a mutant of the invention may be obtained by introduction of a frameshift mutation at location 870 of the sequence SEQ ID NO: 1. The insertion of four nucleotides (sequence AATT) at this location results in a stop codon four codons after the site of insertion. This results in the expression of a truncated EI protein devoid of at least aminoacids 110 to 574 of wild-type EI, with the addition of four new codons before the first translational stop codon.
- mutants having at least a mutation in the *hprK* gene resulting in the lack of expression of HprK or in the expression of a HprK devoid of at least an active domain of wild-type HprK. For instance, a mutant of the invention may be devoid of at least aminoacids 208 to 319 of wild-type HprK.
- mutants having at least a mutation in the *ccpA* gene resulting in the lack of expression of CcpA or in the expression of a CcpA devoid of at least an active domain of wild-type CcpA. For instance, a mutant of the invention may be obtained by introduction of a frameshift mutation at location 710 of the sequence U28137 of GENBANK. The insertion of four nucleotides (sequence AATT) at this location results in a stop codon five codons after the site of insertion,
and in the expression of a CcpA devoid of at least aminoacids 134 to 333 of wild-type CcpA.
- mutants in the *ptsH* gene having at least a mutation resulting in the lack of expression of HPr or in the expression of a HPr having at least one amino-acid substitution at position 15 and/or at position 46 and/or at position 47 of wild-type HPr, and/or at least a mutation resulting in the expression of a HPr deleted of at least one of amino-acids 15, 46, and/or 47 of wild-type HPr.
[0020] The invention also provides:
- mutants of *L. casei* having at least one mutation in at least one of *ptsI*, or *ptsH* genes, wherein said mutation impairs at least one of the functions of the product of said gene;
- food-grade mutants of *L. casei*, having at least one mutation impairing at least one of the functions of a gene involved in the regulation of a carbon catabolite repression mechanism through the PTS enzyme HPr. This includes more particularly food-grade mutants having at least one mutation in any of *ptsI*, *ptsH*, *hprK*, or *ccpA* genes.
[0021] “Food-grade mutants” are herein defined as mutant bacteria acceptable for use in preparation of food. To be food-grade, the mutants must not comprise sequences derived from microorganisms other than the ones used in food industry. Preferably, they must not comprise sequences derived from microorganisms other than those belonging to the species from which the mutant derives. Also they must not comprise potentially harmful DNA sequences such as antibiotic resistance genes.
[0022] *L. casei* mutants of *ccpA* gene [MONEDERO et al., J. Bacteriol., 179, 6657-6664, (1997)] were already known in the art; however they were not food-grade mutants.
[0023] Mutants of the invention may be obtained by the conventional molecular biology methods. From the sequences of *L. casei* genes such as *ptsI*, *ptsH*, *hprK* or other *L. casei* genes known in the art, such as *ccpA*, the skilled artisan can easily design tools allowing to perform the desired mutations through directed mutagenesis. Said mutations may be obtained by the insertion, deletion, and/or substitution of one nucleotide or of several nucleotides, adjacent or not.
[0024] Said mutations may for instance be obtained by the deletion of said regulatory DNA sequence or of the said insertion, deletion, and/or substitution of one nucleotide or of several nucleotides, adjacent or not.
[0025] Such mutations include in particular any mutation resulting in the production of a protein having at least one deletion, insertion, or non-conservative substitutions of one or several amino acid residues in a domain essential for the biological activity of said protein.
[0026] The mutant gene thus obtained is then cloned into a vector, preferably an expression vector, and used to transform *L. casei* host cells by any appropriate method, known in itself. Methods and vectors suitable for the transformation of *L. casei* are for instance disclosed by POSNO et al. [Appl. Environ. Microbiol., 57, 1822-1828, (1991)].
[0027] By way of example, one can use an extrachromosomal vector able to replicate in *L. casei*. However, in order to obtain stable mutants, a vector allowing the integration of the mutant gene into the chromosome of *L. casei* will be preferred.
[0028] Integration of the mutant gene into the bacterial chromosome occurs by recombination of the vector genetic material at a homologous site (generally the wild-type allele of the mutant gene) on the bacterial chromosome. Integration may result from a single or double recombination event. Single recombination events result in integration of the entire vector. Double recombination events lead to the excision of the exogenous vector sequences.
[0029] By way of example, a method for integration of a mutant *lacT*, *lacE*, or *lacF* gene in the chromosome of *L. casei* is disclosed by GOSALBES et al.: [J. Bacteriol., 181, 3928-3934, (1999)]. This method includes cloning a wild-type gene in an integrative plasmid (pRV300, having an Erm<sup>R</sup> marker), inducing a mutation in the cloned gene (for example by cutting the gene with a restriction enzyme and by introducing a mutation by making the restriction site blunt-end), transforming *L. casei* with the plasmid comprising the mutated gene, culturing the bacteria in selective medium containing erythromycin in order to select the bacteria having integrated the plasmid by a single recombination event (which are Erm<sup>R</sup>). Further cultivation of these Erm<sup>R</sup> bacteria in non-selective medium (i.e. without erythromycin) allows to obtain bacteria having undergone a double recombination event leading to the excision of the vector sequences.
[0030] Such a method can be used, for instance, for obtaining food-grade mutants wherein the function of EI, HPr, HprK, or CcpA is completely or partially impaired. This method comprises:
- transforming *L. casei* with an integrative vector comprising a mutated gene selected among *ptsI*, *ptsH*, *hprK*, or *ccpA*, and further comprising a selective marker gene;
- culturing the bacteria under selective conditions for the marker gene (for instance, if the marker gene is an antibiotic resistance gene, in presence of the corresponding antibiotic) and recovering the bacteria able to grow in these conditions, i.e. having integrated the vector into their chromosome by a single recombination event;
- culturing said bacteria under non-selective conditions for the marker gene in order to obtain bacteria having undergone a double recombination event leading to the excision of the vector sequences.
This double recombination event produces bacteria having a wild-type phenotype and bacteria having the desired mutation. The latter can then be screened on the basis of their phenotypic properties, and/or by PCR amplification of the chromosomal region wherein the mutation was targeted and analysis of the amplification products (for instance comparison of the restriction profiles). The presence of the desired mutation can further be confirmed by DNA sequencing.
A preferred method for obtaining food-grade mutants wherein the catalytic function of HPr is only slightly impaired comprises:
- transforming a mutant strain of *L. casei* wherein the *ptsI* gene is inactivated in such a way that function of EI is totally impaired, with an integrative vector comprising a *ptsH* operon consisting of a wild type *ptsI* gene and the mutant *ptsH* gene, and further comprising a selective marker gene;
- culturing the transformed bacteria on lactose under selective conditions for the marker gene, and recovering the bacteria having integrated the vector into their chromosome by a single recombination event;
- culturing the selected bacteria on lactose and under non-selective conditions for the marker gene in order to obtain bacteria having undergone a double recombination event leading to the excision of the vector sequences.
Clones containing an intact *ptsI* gene and a mutated *ptsH* gene can be selected on the basis of their slightly reduced growth on lactose. The presence of the mutation can be confirmed by DNA sequencing.
Mutant strains of the invention can also be obtained from wild-type strains of *L. casei* through classical mutation methods, for instance chemical or UV induced mutagenesis. They can also be naturally occurring mutants isolated from *L. casei* populations.
For instances, reporter gene fusions to catabolite repressed or activated genes could be used to identify *ccpA*, *ptsH* or *hprK* mutants defective in carbon catabolite repression or carbon catabolite activation.
Mutant strains of the invention may also be selected on the basis of their metabolic properties. For instance: mutants in the *ptsI* or *ptsH* gene may be selected on the basis of their resistance to 2-deoxy glucose. Mutants in the *ptsI* gene or mutants in the *ptsH* gene having an inactive EI or HPr, respectively, may also be selected on the basis of their ability to grow on non-PTS sugar but not on PTS sugars.
The invention also provides a process for preparing a food product or food additive wherein said process comprises fermenting a food substrate with a mutant strain of *L. casei*, as defined above.
Preferably said food product is a dairy product.
According to a preferred embodiment, the process of the invention comprises preparing a food product enriched with aroma compounds (such as acetate, acetoin, diacetyl, hydroxy-3-pentanone, propionate) by fermenting a food substrate with a strain of *L. casei* having a mutation impairing the function of CcpA.
According to another preferred embodiment, the process of the invention comprises preparing a food product having an improved texture and flavor by fermenting a food substrate with a strain of *L. casei* having a mutation impairing the function of EI.
The invention also provides fermented food products obtainable by the process of the invention, and, in particular fermented food products comprising at least a mutant strain of *L. casei* as defined above.
The present invention will be further illustrated by the additional description which follows, which refers to examples of construction and use of mutant strains of *L. casei* of the invention. It should be understood however that these examples are given only by way of illustration of the invention and do not constitute in any way a limitation thereof.
**EXAMPLE 1: CHARACTERISATION OF *L. CASEI* ptsH AND ptsI GENES**
Strains, plasmids and culture conditions
The *L. casei* strains and plasmids used for the characterisation of *ptsH* and *ptsI* genes and construction of mutants thereof are listed in Table 1a and 1b below.
| STRAIN | GENOTYPE | ORIGIN |
|--------|----------|--------|
| (*L. casei*) | | |
| BL23 | wild-type | Bruce Chassy |
| BL30 | man | (VEYRAT et al., 1994) |
| BL71 | ccpA | (MONEDERO et al., 1997) |
| BL72 | man ccpA | (GOSALBES et al., 1997) |
### STRAIN
| GENOTYPE | ORIGIN |
|-------------------|--------------|
| (L. casei) | |
| BL121 | ptsH1 (S46AHPr) | This work |
| BL122 | ptsH2 (S46THPr) | This work |
| BL123 | ptsH3 (147THPr) | This work |
| BL124 | ptsl: pVME800 | This work |
| BL126 | ptsl/′ (frameshift introduced into the first EcoRI site of ptsl) | This work |
### TABLE 1b
| PLASMID | PROPERTIES | ORIGIN |
|-----------|-----------------------------------------------------------------------------|-------------------------|
| pUC18 | pBluescript SK- with the pAMβ1 EmiR gene | PHARMACIA-BIOTECH |
| pRV300 | pUC18 with 1.6 kb PCR fragment with part of ptsH and ptsl | (LELOUP et al., 1997) |
| pUCR-HI | pRV300 with a 865 bp EcoRI internal ptsl fragment | This work |
| pVME800 | pRV300 with 9 kb fragment downstream from ptsl | This work |
| pVM51 | pRV300 with part of ptsl, complete ptsH and 105 bp upstream from ptsH | This work |
| pVMH1 | pVMH1 derivative (codon 46 of ptsH is GCT for Ala) | This work |
| pVMH2 | pVMH1 derivative (codon 46 of ptsH is ACT for Thr) | This work |
| pVMH3 | pVMH1 derivative (codon 46 of ptsH is GAT for Asp) | This work |
| pVMH4 | pVMH1 derivative (codon 47 of ptsH is ACC for Thr) | This work |
| pVMH5 | pVMH1 derivative with a frameshift in the first EcoRI site of ptsl. | This work |
[0044] L. casei cells were grown at 37°C under static conditions in MRS medium (OXOID) or MRS fermentation medium (ADSA-MICRO, Scharlau S.A., Barcelona, Spain) containing 0.5% of the indicated carbohydrates.
[0045] For diauxic growth experiments, L. casei strains were grown in MRS basal medium containing in 1:1 polypeptone (DIFCO), 10 g; meat extract (DIFCO), 10 g; yeast extract (DIFCO), 5 g; K₂HPO₄·3H₂O, 2 g; sodium acetate, 5 g; diammonium citrate, 2 g; MgSO₄, 0.1 g; MnSO₄, 0.05 g and TWEEN 80, 1 ml. The basal medium was supplemented with different sugars at a final concentration of 0.5%, but for the diauxic growth experiments the sugar concentrations were changed as indicated in the text. E. coli DH5α was grown with shaking at 37°C in Luria-Bertani (LB) medium. Transformed bacteria were plated on the respective solid media containing 1.5% agar. The concentrations of antibiotics used for the selection of E. coli transformants were 100 µg per ml ampicillin, and 300 µg per ml erythromycin and for the selection of L. casei/integrants 5 µg per ml erythromycin. The sugar utilization pattern of certain strains was determined with the API50-CH galeries (BIOMERIEUX, Marcy l’Etoile, France).
**Purification of HPr**
[0046] Cells from an over-night culture (1 1 of MRS medium) were centrifuged and washed twice with 20 mM Tris-HCl, pH 7.4. The cells were resuspended in 20 mM ammonium bicarbonate buffer, pH 8 (2 ml per gram of cell pellet), sonicated (BRANSON SONIFIER 250) and then centrifuged to remove the cell debris. As HPr resists to heat treatment, the supernatant was kept at 70°C for 5 min to precipitate most of the other proteins. An additional centrifugation step was performed to remove the heat-denatured proteins. The supernatant was loaded on a Sephadex G-75 column (42 cm x 1.6 cm) equilibrated with 20 mM ammonium bicarbonate, pH 8, which was eluted with the same buffer, and fractions of 1.5 ml were collected. To test for the presence of HPr in these fractions, a mutant complementation assay with the S. aureus ptsH mutant strain S797A was carried out [HENGSTENBERG et al., J. Bacteriol., 99, 383-388, (1969)]. HPr activity was detected in fractions 48 to 56. These fractions were pooled and concentrated to a final volume of 500 µl.
[0047] Half of the partially purified HPr was separated by reverse phase chromatography on a VYDAC C-18 HPLC
column (300 Å, 250 mm x 4.6 mm; TOUZART ET MATIGNON, France). Solvent A was an aqueous solution of 0.1% (v/v) of trifluoroacetic acid and solvent B contained 80% acetonitrile and 0.04% trifluoroacetic acid. Proteins were eluted with a linear gradient from 5 to 100% of solvent B in 60 min at a flow rate of 500 µL/min. Fractions with a volume of about 500 µL were collected manually. The presence of HPr in the fractions was tested by a PEP-dependent phosphorylation assay containing 10 mM MgCl₂, 50 mM Tris-HCl, pH 7.4, 10 µL aliquots of the fractions, 10 µM [³²P]PEP and 1.5 µg of *B. subtilis* enzyme ([HIs]₆). Enzyme ([HIs]₆ and HPr([HIs]₆ of *B. subtilis*) were purified by ion chelate chromatography on a Ni-NTA SEPHAROSE column (QIAGEN) after expression from plasmids pAG3 and pAG2, respectively [GALINIER et al., Proc Natl Acad Sci USA 94, 8439-8444, (1997)]. HPr([HIs]₆ from *B. subtilis*) was used as a standard in the phosphorylation reactions. [³²P]PEP was prepared from [³²P]ATP via the pyruvate kinase exchange reaction [ROOSSIEN et al., Biochim. Biophys. Acta., 760, 185-187, (1983)]. The assay mixtures were incubated 10 minutes at 37 °C and separated on 15% polyacrylamide gels containing 1% SDS [LAEMMLI, Nature, 227, 680-685, (1970)]. After drying the gels, radiolabelled proteins were detected by autoradiography. HPr was found to elute at 60% acetonitrile in fractions 44 to 46. These fractions were pooled, lyophilised and aliquots corresponding to approximately 0.5 nmol of HPr were used to determine the first 21 N-terminal amino-acids of HPr by automated Edman degradation on a 473A APPLIED BIOSYSTEMS microsequencer.
**Cloning of PCR-amplified *L. casei* ptsH fragments.**
[0048] To amplify *L. casei* DNA fragments containing *ptsH* and part of *ptsI*, the following degenerate oligonucleotides were designed based on the N-terminal sequence of HPr and on strongly conserved regions in enzyme I which were detected by carrying out an alignment of different enzyme I sequences:
PTS-H2 (5'-ATG GAA AAR CGN GAR TTY AAY-3') (MEKREFN);
PTS-I3 (5'-GCC ATN GTR TAY TGR ATY ARR TCR TT-3') (NDLQYTMNA);
PTS-I4 (5'-CCR TCN SAN GGN GCR ATN CC-3') (GIAASDG);
where R stands for A or G, Y for C or T, S for C or G and N for any nucleotide. Shown underlined in parentheses are the N-terminal amino acid sequence of HPr and the conserved enzyme I sequences which served to design the primers.
[0049] PCR amplification of the two fragments comprising part of the *ptsH* operon, was performed with a PROGENE thermocycler (REAL, S.L., Valencia, Spain) programmed for 30 cycles including the following three steps: 30 sec at 95 °C, 30 sec at 50 °C and 1 min at 72 °C, followed by a final extension cycle at 72 °C for 5 min.
[0050] Two combinations of primers (PTS-H2/PTS-I3 and PTS-H2/PTS-I4) gave PCR-amplified fragments of 1.6 kb and 0.3 kb, respectively. Sequencing of the PCR products revealed that the deduced amino acid sequences exhibited strong similarity to the sequences of known enzyme I and HPr. As expected, both DNA fragments began with the 5' end of *ptsH* and extended to the region in *ptsI* encoding the conserved sequence chosen as basis for the second primer. The larger of the two fragments obtained with primer PTS-I3 was cloned into pUC18, providing plasmid pUCR-H1. Cloning of PCR fragments was achieved with the SURECLONE Ligation Kit (PHARMACIA BIOTECH, Ltd., Uppsala, Sweden).
[0051] A 865 bp *EcoRI* fragment which contained an internal part of the *ptsI* gene was obtained from plasmid pUCR-H1 and subcloned into the suicide vector pRV300 [LELOUP et al., Appl. Environm. Microbiol., 63, 2117-2123, (1997)], providing plasmid pVMEB00.
[0052] This plasmid was used to transform the *L. casei* wild-type strain BL23 and integration of the plasmid at the correct location (*ptsI*:pVMEB00) was verified by PCR and southern blot.
[0053] Restriction analysis of the *ptsH* region was carried out by southern hybridisation using DNA isolated from one integrant (BL124) with the aim to identify restriction enzymes allowing cloning of the *ptsH* and *ptsI* genes together with their flanking regions.
[0054] Cloning of the regions flanking the insertion site of plasmid pRV300 was performed as follows: DNA (10 µg) from *L. casei* BL124 was digested with SacI or HindIII, diluted 500-fold, religated with T4 DNA ligase and different aliquots were used to transform *E. coli* DH5α. Plasmid DNA was isolated from several transformants and subsequently sequenced.
[0055] Digestion of BL124 DNA with SacI and religation of the obtained DNA fragments allowed to isolate plasmid pVMS1 carrying an about 9 kb insert. Partial sequencing of this insert revealed that it contained the 3' part of *ptsI* and its downstream region. The same experiment carried out with HindIII allowed to isolate plasmid pVMH1 carrying a 2.4 kb insert comprising the complete *ptsH* gene together with part of its promoter region and the 5' part of *ptsI*.
[0056] The sequence containing the complete *ptsH* promoter and 560 bp of the upstream region was subsequently obtained by reverse PCR. For this purpose, DNA isolated from the *L. casei* wild-type strain BL23 was cut with PstI and religated with T4 DNA ligase (GIBCO-BRL), 20 ng of the ligated DNA and two primers derived from the 5' part of *ptsH* and oriented in opposite directions were used to specifically amplify by PCR a 2.3 kb fragment containing the upstream region of *ptsH*. The sequence comprising 560 bp upstream from the *ptsH* promoter has been determined in this fragment.
[0057] In total, a continuous stretch of 4150 bp has been sequenced. It contained the complete *ptsH* and *ptsI* genes
and an open reading frame (ORF) located downstream of *ptsI*. The stop codon of *ptsH* was found to overlap with the initiation codon of *ptsI* by 1 bp, suggesting that these two genes are organised in an operon. Whereas the encoded *L. casei* HPr and enzyme I exhibited sequence similarities ranging from 65 to 85% when compared to their homologues in *B. subtilis*, *Lactococcus lactis*, *Lactobacillus sakei*, *Streptococcus salivarius* or *Enterococcus faecalis*, the protein encoded by the ORF located downstream of *ptsI* exhibited similarity to the sugar permeases XylE [DAVIS and HENDERSON, J. Biol. Chem., 262, 13928-13932, (1987)] and GalP [PAO et al., Microbiol. Mol. Biol. Rev., 62, 1-34, (1998)] from *Escherichia coli*. No ORF could be detected in the 560 bp region upstream from the *ptsH* promoter.
[0058] Figure 1 is a schematic representation of the sequenced chromosomal *L. casei* DNA fragment containing the *ptsH* operon. Indicated are the three ORFs detected in this fragment, the promoter and terminator of the *ptsH* operon and several important restriction sites. The initially isolated PCR fragments H2/4 and H2/3 (flanked by inverted arrows) and the 865 bp EcoRI fragment, which was called E800 and subcloned into pRV300, are shown above the schematic presentation of the total DNA fragment.
**Transcriptional analysis of the *L. casei* ptsH operon**
[0059] To determine the size of the *ptsH* transcripts and to test the effect of a *man* (prevents the uptake of glucose via the PTS) and a *ccpA* mutation on *ptsH* expression, Northern blots were performed with RNA isolated not only from the *L. casei* wild-type BL23, but also from the mutant strains BL30 (*man*) [VEYRAT et al., Microbiology, 140, 1141-1149, (1994)], BL71 (*ccpA*) [MONEDERO et al., J. Bacteriol., 179, 6657-6664, (1997)] and BL72 (*man ccpA*) [GOSALBES et al., FEMS Microbiol. Lett., 148, 83-89, (1997)], which were grown in medium containing either glucose, lactose or ribose.
[0060] *L. casei* strains were grown in MRS fermentation medium supplemented with 0.5% of the different sugars to an OD at 550 nm between 0.8 and 1. Cells from a 10 ml culture were collected by centrifugation, washed with 50 mM EDTA and resuspended in 1 ml of TRIZOL (GIBCO BRL). 1 g of glass beads (diameter 0.1 mm) was added and the cells were broken by shaking the cell suspension in a FASTPREP apparatus (BIOSPEC, Bartlesville, OK, USA) two times for 45 s. RNA was isolated according to the procedure recommended by the manufacturer of TRIZOL, separated by formaldehyde-agarose gel electrophoresis and transferred to HYBOND-N membranes (AMERSHAM).
[0061] Hybridisation experiments were carried out with either *ptsH*- or *ptsI*-specific probes. With both probes, a mRNA band of about 2.1 kb could be detected, which is in good agreement with the size expected for the combined *ptsH* and *ptsI* genes, confirming that these two genes are organised in an operon and that transcription stops at the stem loop structure located downstream of *ptsI*.
[0062] Densitometric measurement of the hybridising bands in the RNA isolated from cells of the different mutants grown in glucose-, lactose-, or ribose-containing medium showed that expression of the *ptsH* operon was moderately induced by glucose in the wild type and *ccpA* mutant, while this effect was less pronounced in the strains carrying the *man* mutation.
**EXAMPLE 2: CONSTRUCTION AND CHARACTERISATION OF ptsH AND ptsI MUTANTS**
**I- Construction and characterisation of ptsI mutants**
**Mutant BL124**
[0063] This mutant results from transformation of *L. casei* wild-type strain BL23 with plasmid pVME800, as described in Example 1 above.
[0064] In contrast to the wild-type strain, this mutant can no longer produce acid from fructose, mannose, mannitol, sorbose, sorbitol, amygdalin, arbutine, salicine, cellobiose, lactose, tagatose, trehalose and turanose. However, it can still metabolise ribose, galactose, glucose, N-acetylglucosamine, aesculin, maltose and gluconate, suggesting that in *L. casei* PTS-independent transport systems exist for this second class of sugars.
**Mutant BL126**
[0065] Plasmid pVMH1 was partially digested with *EcoRI* and made blunt end (filled in with the Klenow fragment) before it was religated and used to transform *E. coli* DH5α. From one of the resulting transformants, a plasmid (pVMR10) could be isolated bearing a frame-shift mutation at the *EcoRI* site located at nucleotide 327 of the *ptsI* gene, as was confirmed by restriction analysis and DNA sequencing (insertion of 4 additional base pairs). Plasmid pVMR10 was subsequently used to transform *L. casei* BL23 and an erythromycin-resistant *ptsI*<sup>+</sup> integrant resulting from a Campbell-like recombination was isolated.
[0066] From this strain, a *ptsI* mutant (*ptsI*<sup>-</sup>, BL126) could be obtained by a second recombination. BL126 was erythromycin-sensitive and exhibited a fermentation pattern identical to that found for the *ptsI*::pVME800 mutant BL124.
Interestingly, no *ptsH* mRNA could be detected in BL126 by Northern blot analysis.
II- Construction of *ptsH* mutants altered at Ser-46 or Ile-47
[0067] PCR-based site directed mutagenesis was carried out with the *L. casei* *ptsH* gene present in plasmid pVMH1 (Table 1) to replace either Ser-46 with alanine, aspartic acid or threonine, or Ile-47 with threonine.
[0068] Site-directed mutagenesis was performed in order to replace the codon for Ser-46 of *L. casei* *ptsH* with a codon for Ala, Asp or Thr and the codon for Ile-47 with a codon for Thr.
[0069] For this purpose, PCR amplification was carried out using as template the plasmid pVMH1 containing the *L. casei* wild-type *ptsH* gene as well as the 5' part of the *ptsI* gene and as primers the reverse primer of pBLUESCRIPT (STRATAGENE) and one of the following oligonucleotides:
5' *ptsH*#46A (5'-AAG AGC GTT AAC TTG AAG GCT ATC ATG GCC G-3');
5' *ptsH*#46T (5'-AAG AGC GTT AAC TTG AAG ACT ATC ATG GCC G-3');
5' *ptsH*#46D (5'-AAG AGC GTT AAC TTG AAG GAT ATC ATG GCC G-3');
5' *ptsH*#47T (5'-AAG AGC GTT AAC TTG AAG TCT ACC ATG GCC G-3').
[0070] In these oligonucleotides, the codons for Ser-46 or Ile-47 were replaced by the indicated codon (underlined).
[0071] The resulting 1.4 kb PCR fragments containing the *ptsH* alleles (from codon 40) and the 5' part of *ptsI* were digested with *HpaII* (the *HpaII* site present in *ptsH* before codon 46 is indicated in italics in the above primers) and SacI and used to replace the wild-type 1.4 kb *BamHI/SacI* fragment in pVMH1.
[0072] In order to confirm the presence of the mutations, the sequence of the *ptsH* alleles was determined in the four constructed plasmids. To eliminate mutations possibly introduced in the *ptsI* gene by the PCR amplification, the 1.35 kb *BamHI/SacI* fragment from pVMH1 was used to replace the corresponding fragment in each of the four plasmids containing the various *ptsH* alleles. A unique *BamI* site is present 27 bp behind codon 46 of *L. casei* *ptsH* in pVMH1 and the pVMH1 derivatives carrying the different *ptsH* alleles.
[0073] The four resulting plasmids carrying the various *ptsH* alleles were named pVMH2, pVMH3, pVMH4 and pVMH5, respectively (Table 1), and were used to transform the *L. casei* *ptsI* mutant BL126.
[0074] Figure 2 is a schematic presentation of possible recombination events during the construction of *ptsH* mutants with the *ptsI*† strain BL126 and the pVMH plasmids containing the various *ptsH* alleles. Integration of a pVMH plasmid carrying a mutation in *ptsH* (indicated by the filled circle) into the chromosome of BL126 carrying a frame shift mutation in *ptsI* (indicated by the filled triangle) by Campbell-like recombination could take place at three different locations (before the *ptsH* mutation, between the *ptsH* and *ptsI* mutations and after the *ptsI* mutation) resulting in the three different DNA arrangements presented under: "1st recombination".
[0075] Integrants obtained by the first (1) and second (2) type of recombination exhibited a lac- phenotype, whereas integrants obtained by the third type of recombination (3) could slowly ferment lactose (probably due to a readthrough from a plasmid-located promoter).
[0076] The three different DNA arrangements presented on Figure 2 under: "2nd recombination" are obtained from type 3 integrants after a second recombination event leading to the excision of the pVMH plasmid. 3a provides a lac- strain having a frame shift mutation in *ptsI*. 3b provides a wild-type strain (lac+); 3c provides the desired *ptsH* mutant(lac+).
[0077] Transformation or the *L. casei* *ptsI* mutant BL126 with pVMH2, pVMH3, pVMH4 or pVMH5 resulted in erythromycin-resistant recombinants generated by the first recombination.
[0078] Type 3 integrants obtained with each of the three pVMH plasmids were grown for 200 generations without selective pressure to allow the second recombination leading to the excision of the pVMH plasmids. Erythromycin-sensitive clones able to ferment lactose were therefore isolated.
[0079] Two types of erythromycin-sensitive lactose-fermenting recombinants were obtained which exhibited slightly different growth characteristics. Using appropriate primers, the *ptsH* alleles of two clones of the slower and faster growing recombinants were amplified by PCR and sequenced. For each *ptsH* allele, the two faster growing clones contained the wild-type *ptsH*, whereas the slightly slower growing strains carried either the Ser-46-Ala (*ptsH*†, BL121), the Ser-46-Thr (*ptsH*2, BL122) or the Ile-47-Thr *ptsH* mutation (*ptsH*3, BL123).
[0080] No strain synthesising Ser-46-Asp mutant HPr could be obtained with this method, although PCR amplification followed by DNA sequencing was carried out with fifteen erythromycin-sensitive clones constructed with plasmid pVMH4.
The *ptsH* mutations affect CCR and diauxic growth
[0081] In order to test the effect of the different amino acid substitutions in HPr on diauxie, the growth behaviour of the mutants on basal MRS broth supplemented with 0.1% glucose and 0.2% lactose was compared to that of the wild-type and a *ccpA* mutant.
[0082] Figure 3 represents the growth behaviour of *L. casei* wild-type and *ccpA* and *ptsH* mutant strains in MRS basal medium containing 0.1% glucose and 0.2% lactose. The symbols represent: filled circles, wild-type BL23; filled squares,
ccpA mutant BL71; open circles, ptsH1 mutant BL121; filled triangles, ptsH2 mutant BL122; open triangles, ptsH3 mutant BL123.
[0083] As previously demonstrated [VEYRAT et al., Microbiology, 140, 1141-1149, (1994); GOSALBES et al., FEMS Microbiol. Lett., 148, 83-89, (1997); GOSALBES et al., J. Bacteriol., 181, 3928-3934, (1999)], the L. casei wild-type strain exhibited strong diauxic growth in the presence of these two sugars with a lag phase of about 15 h separating the growth phases on glucose and lactose, whereas in the ccpA mutant strain this lag phase was reduced to 6 h. The diauxic growth observed with the ptsH546T mutant was very similar to that of the wild-type strain. By contrast, the lag phase was only about 6 h for the ptsH546A mutant and in between wild-type and ptsH546A mutant for the ptsH447T (10 h).
[0084] A similar gradation was found when the relief from glucose-mediated repression of N-acetylglucosaminidase activity was investigated.
[0085] For the N-acetylglucosaminidase assays, permeabilized L. casei cells were prepared following a previously described method [CHASSY and THOMPSON, J. Bacteriol., 154, 1195-1203, (1983)]. The N-acetylglucosaminidase assays were carried out at 37°C in a volume of 250 µl containing 10 mM potassium phosphate, pH 6.8, 1 mM MgCl₂, 5 mM p-nitrophenyl N-acetyl-β-D-glucosaminide (SIGMA) and 5 µl of permeabilized cells. The reaction was stopped with 250 µl of 5% Na₂CO₃ and the OD₄₂₀ was measured. Protein concentrations were determined with the BIO-RAD dye-binding assay.
[0086] Figure 4 shows the effect of the various ptsH mutations on CCR of N-acetylglucosaminidase. The N-acetylglucosaminidase activities expressed in nmoles of product formed per min and mg of protein and determined in the L. casei wild-type (wt) and the ccpA, ptsH1 (S46A), ptsH2 (S46T) and ptsH3 (I47T) mutant strains grown in MRS basal medium containing 0.5% glucose or ribose are presented.
[0087] Whereas high activity of this enzyme could be measured in ribose-grown wild-type cells, glucose was found to inhibit its activity about 10-fold. Similar as in the ccpA mutant, the repressive effect of glucose on N-acetylglucosaminidase had completely disappeared in the ptsH546A mutant. Inhibition of N-acetylglucosaminidase activity by the presence of glucose in the growth medium was also clearly diminished in the two other ptsH mutants (about 2-fold inhibition in the ptsH447T mutant and 2.5-fold inhibition in the ptsH546T mutant), confirming the importance of Ser-46 phosphorylation of HPr and of the amino acids in the vicinity of Ser-46 for CCR in L. casei.
[0088] Therefore, these two tests indicated that there was a remarkable and progressive loss of catabolite repression in the different mutants: wild-type < ptsH2 < ptsH3 < ptsH1 < ccpA.
The ptsH mutations affect inducer exclusion in L. casei
[0089] When L. casei wild-type cells were grown in a medium containing glucose and either ribose or maltose, a diauxic growth behaviour similar to that obtained with cells growing in the presence of glucose and lactose was observed. However, whereas the lag time of the diauxic growth in the presence of glucose and lactose was not or only partly reduced in the ptsH mutants, the diauxic growth completely disappeared when the ptsH strains were grown in a medium containing glucose and either maltose or ribose. These results suggested that phosphorylation of HPr at Ser-46 plays an important role in regulation of the utilization of these two non-PTS sugars by L. casei.
[0090] In order to distinguish whether this effect was mediated via interaction of the CcpA/P-Ser-HPr complex with cre sequences or via interaction of P-Ser-HPr with a sugar permease according to the proposed mechanism of inducer exclusion [YE et al., Proc. Natl. Acad. Sci. USA, 91, 3102-3106, (1994); YE et al., J. Bacteriol., 176, 3484-3492, (1994); YE and SAIER, Proc. Natl. Acad. Sci. USA, 92, 417-421, (1995); YE and SAIER, J. Bacteriol., 177, 1900-1902, (1995)], sugar transport experiments were performed.
[0091] Cells were grown to mid-exponential phase in MRS fermentation broth containing 0.5% of the indicated sugars. Subsequently, glucose was added to a final concentration of 0.5% and cells were grown for a further 30 min to allow the synthesis of the glucose-specific PTS transport proteins. Cells were washed twice with 50 mM sodium phosphate buffer, pH 7, containing 10 mM MgCl₂ and resuspended in 50 mM Tris-maleate buffer, pH 7.2, containing 5 mM MgCl₂. Transport assays were carried out in 1 ml of this latter buffer containing 1% peptone and 0.6 mg of cells (dry weight). Samples were preincubated for 5 min at 37°C prior to adding [¹⁴C]-labelled sugars (0.5 mCi/mmol, ISOTOPCHIM, Garagobie-Peyrus, France) to a final concentration of 1 mM. Samples of 100 µl were withdrawn at different time intervals, rapidly filtered through 0.45 µm pore-size filters, washed twice with 5 ml of cold Tris-maleate buffer and the radioactivity retained was determined by liquid scintillation counting.
[0092] Figure 5 shows the effect of glucose and 2-deoxy-D-glucose on maltose and ribose uptake by wild-type and ptsH mutant cells. Ribose transport by the L. casei wild-type strain BL23 was measured in the absence and presence of glucose and 2-deoxy-D-glucose (A). Maltose transport in the absence and presence of glucose or 2-deoxy-D-glucose was determined in the L. casei wild-type strain BL23 (B), the ptsH1 mutant BL121 (C), the ptsH2 mutant BL122 (D), the ptsH3 mutant BL123 (E) and the ptsI mutant BL126 (F). The symbols represent: squares, ribose or maltose uptake in the absence of other sugars; diamonds, ribose or maltose uptake with glucose (10 mM final concentration) added after 10 or 4 min, respectively; circles, ribose or maltose uptake with 2-deoxy-D-glucose (10 mM final concentration) added
after 10 or 4 min, respectively; triangles, the cells were incubated for 10 min in the presence of 20 mM glucose before the maltose uptake reaction was started.
[0093] The uptake of ribose by ribose-grown *L. casei* wild-type cells is shown in Fig. 5A. The addition of glucose to ribose-transporting wild-type cells caused no inhibition of ribose uptake but instead increased the transport about four-fold. The addition of the glucose analogue 2-deoxy-D-glucose completely abolished ribose uptake. It is most likely that the depletion of energy caused by the transport and accumulation of the non-metabolizable glucose analogue is responsible for the inhibitory effect of 2-deoxy-D-glucose on ribose transport.
[0094] In contrast to the stimulatory effect exerted by glucose on ribose uptake, maltose transport was found to be instantaneously arrested when glucose or 2-deoxyglucose was added to *L. casei* wild-type cells transporting maltose. Maltose uptake was also completely abolished when glucose or 2-deoxyglucose was added to the cell suspension 10 minutes before the addition of maltose (Fig. 5B). The *ptsH1* (S46AHPr) mutant showed a completely different behaviour to the wild type strain (Fig. 5C). Maltose uptake in this strain was slightly higher, and the addition of glucose caused a further increase of the maltose transport rate. A similar, but less pronounced stimulatory effect of glucose on maltose transport was found for the *ptsH2* (S46THPr) mutant (Fig. 5D), whereas no change of the maltose transport rate following glucose addition was observed for the *ptsH3* (I47THPr) mutant (Fig. 5E). In the *ptsI* mutant BL126, which is unable to transport glucose and 2-deoxy-D-glucose via the PTS, the presence of glucose exerted no inhibitory effect on maltose uptake (Fig. 5F).
[0095] The measure of glucose uptake in the *ptsI* mutant BL126 shows that glucose is transported 10-times slower than the wild-type strain (data not shown). A slower glucose uptake and metabolism is most likely responsible for the failure of glucose to elicit inducer exclusion in the *ptsI* mutant strain. By contrast, in a *ccpA* mutant strain, glucose exerts an inhibitory effect on maltose uptake identical to that observed with the wild-type strain. This result clearly establishes that CcpA is not involved in glucose-triggered maltose exclusion.
[0096] To make sure that growing the cells for 30 min in glucose-containing medium had no drastic effect on expression of the maltose genes, inducer exclusion experiments were carried out with cells which had not been exposed to glucose. Under these conditions, addition of glucose to maltose transporting cells exerts a strong inhibitory effect on maltose uptake in the wild-type and *ccpA* mutant strains, although maltose continues to be slowly taken up by these cells after the addition of glucose. By contrast, the presence of glucose completely arrests maltose uptake by cells which have been grown on glucose for 30 min. However, with the *ptsH1*, *ptsH2* and *ptsH3* mutants grown only on maltose, glucose exerts no inhibitory effect at all on maltose uptake, clearly establishing that the failure of glucose to inhibit maltose transport in the *ptsH* mutant strains is not related to pregrowing the cells in glucose-containing medium.
[0097] The observed inhibition of maltose transport could have been due to elevated secretion of maltose fermentation products when glucose was added to wild-type cells. In the *ptsH* mutants, this glucose effect might have been less pronounced. To exclude this possibility, we also measured sugar consumption by resting cells which had been grown on maltose and for the last 30 min before harvesting the cells on maltose and glucose. In order to follow the sugar consumption by the *L. casei* wild-type and *ptsH1* mutant strains, cells were grown and harvested as described for the transport studies and 18 mg of cells (dry weight) were resuspended in 5 ml of 50 mM sodium phosphate buffer, pH 7. After a 5 min incubation at 37 °C, maltose and glucose were added to a final concentration of 0.04 and 0.2%, respectively. Samples of 300 µl were withdrawn at different time intervals, boiled for 10 min and clarified by centrifugation. The sugar content in the supernatant was determined with a coupled spectrophotometric test using α-glucosidase and hexokinase/glucose-6-P dehydrogenase as recommended by the supplier (BOEHRINGER-MANNHEIM, Germany).
[0098] Figure 6 shows maltose consumption by resting cells of the *L. casei* wild-type strain BL23 and the *ptsH1* mutant BL121 in the presence or absence of glucose. The symbols represent: squares, maltose concentration in the medium in experiments without glucose, diamonds, maltose concentration and circles, glucose concentration in the medium when glucose was added three minutes after the experiment had been started.
[0099] The results presented in Fig. 6A confirm that maltose is not utilised in the presence of glucose by *L. casei* wild-type cells. Maltose consumption stopped immediately when glucose was added and the maltose concentration remained constant in the medium as long as glucose was present. Maltose consumption re-started only when glucose had completely disappeared from the medium. By contrast, the addition of glucose to *ptsH1* mutant cells taking up maltose caused only a short transient inhibition of maltose consumption, which was followed by the simultaneous utilization of both sugars (Fig. 6B). Reduced uptake of glucose by the *ptsH1* mutant does not seem to be responsible for the absence of the inhibitory effect of glucose, as in this strain glucose was utilized slightly faster compared to the wild-type strain. These results suggest that phosphorylation of Ser-46 in HPr is necessary for the exclusion of maltose from *L. casei* cells by glucose and probably other rapidly metabolisable carbon sources and that P-Ser-HPr plays an important role in the regulatory phenomenon called inducer exclusion [YE et al., Proc. Natl. Acad. Sci. USA, 91, 3102-3106, (1994); YE et al., J. Bacteriol., 176, 3484-3492, (1994); YE and SAIER, Proc. Natl. Acad. Sci. USA, 92, 417-421, (1995); YE and SAIER, J. Bacteriol., 177, 1900-1902, (1995)].
EXAMPLE 3: CLONING AND CHARACTERISATION OF *L. CASEI* *hprK* GENE Strains, plasmids and culture conditions
[0100] The *L. casei* strain ATCC 393, cured of plasmid pLZ15, and the mutant strains *ccpA::erm* [MONEDERO et al., J. Bacteriol., 179, 6657-6664, (1997)], *ptsH1* (Ser46Ala) and *ptsH2* (Ser46Thr) were used. Bacteria were grown under static conditions at 37 °C in MRS medium (DIFCO Laboratories, Detroit, Mich.) or MRS fermentation medium (SCHARLAU S.A., Barcelona, Spain). For diauxic growth experiments, *L. casei* strains were pregrown in an overnight culture of MRS basal medium containing in 1 l: peptone, 10 g; meat extract, 10 g; yeast extract, 5 g (all from Difco Laboratories); K₂HPO₄·3H₂O, 2 g; sodium acetate, 5 g; dibasic ammonium citrate, 2 g; MgSO₄·0.1 g; MnSO₄, 0.05 g, TWEEN 80, 1 ml and glucose, 5 g. The overnight culture was used to inoculate 30 ml fresh basal medium containing 0.05% glucose and either 0.05% lactose or 0.05% maltose at an OD₅₅₀ = 0.05. The inoculated medium was subsequently incubated at 37 °C. Samples of 1 ml were withdrawn at the indicated time intervals to follow growth by measuring the OD₅₅₀.
[0101] *Escherichia coli* NM522 (APPLIGENE ONCOR LIFESCREEN, Watford, UK) was grown with shaking at 37 °C in Luria-Bertani (LB) medium. Standard cloning procedures were carried out with *E. coli* NM522 cells, and transformed bacteria were plated on solid media containing 1.5% agar. The antibiotic concentrations for selecting *E. coli* transformants were 100 μg per ml ampicillin or 25 μg per ml kanamycin and 5 μg per ml erythromycin for the selection of *L. casei* integrants.
[0102] The plasmids used in this study were pBC KS* (STRATAGENE, La Jolla, Calif.), pQE30 (QIAGEN, Chatsworth, Calif.) and the integrative vector pRV300.
**Cloning of *hprK* gene**
**DNA Amplification by PCR**
[0103] Polymerase chain reactions (PCR) aimed to obtain fragments of the *L. casei* *hprK* gene were carried out with Taq DNA polymerase (APPLIGENE) by using chromosomal *L. casei* DNA as a template and one of the following pairs of oligonucleotides:
i)
*ohprKLc1* (5'-GGNRTNGGNAARAGYGRAC-3')
*ohprKLc2* (5'-RAARTNNCCCANCNGNC-3')
ii)
*ohprKLc3* (5'-ATAAAAGCTTGGARMTGACNGNTNAYTTTYRAYTWYTA-3');
*ohprKLc4* (5'-ATTGAAAAGAGCCTCGGATTAAGTGTCT-3).
*ohprKLc3* and *ohprKLc4* contain restriction sites for HindIII and SacI, respectively, which are indicated in italics.
[0104] Oligonucleotide *ohprKLc4* corresponds to the sequence located 9 - 35 bp downstream of the *hprK* stop codon. The C at position 10 of this sequence was replaced with an A and the A in position 12 with a C to allow the creation of the SacI site. To exclude errors introduced by PCR, each DNA fragment was amplified in at least two independent experiments, cloned into pBC KS* (STRATAGENE) (cut with EcoRV or HindIII and SacI) providing plasmids pHKLc1 and pHKLc2, respectively, and sequenced on a PERKIN ELMER ABI PRISM 373 automated sequencer. The fragment of the *hprK* gene in pHKLc1 was oriented in the same direction as the *lacZ* fragment.
[0105] By using these two primers and *L. casei* DNA as a template, a 879 bp fragment could be amplified by PCR. The PCR fragment was cloned into pBC KS* digested with EcoRV providing plasmid pHKLc1 and the insert was sequenced. Analysis of the sequence data suggested that the PCR fragment encodes the 162 C-terminal amino acids of HprK and the 129 N-terminal amino acids of Lgt.
[0106] To obtain part of the missing sequence of the presumed *L. casei* *hprK*, a PCR was carried out using *L. casei* DNA as a template and the oligonucleotides *ohprKLc3*, and *ohprKLc4*. The obtained 87/5 bp PCR fragment was digested with HindIII and SacI and was cloned into pBC KS* cut with the same enzymes providing plasmid pHKLc2. DNA sequencing and comparison with known HprK sequences suggested that the amplified DNA fragment encodes amino acids 40 to 319 of *L. casei* HprK.
**Construction of a *L. casei* *hprK* mutant and cloning of the entire *hprK***
[0107] A point mutation was introduced into the *hprK* gene of *L. casei* by replacing the leucine-encoding codon 208 (with respect to the complete *hprK* gene) with an amber codon.
[0108] A PCR was carried out using plasmid pHKLc2 as a template and the two oligonucleotides:
*ohprKLc5* (5'-CCCCTCGAGGTCGACGCGTATGGTAAAGCTTGA-3');
which contains part of the multiple cloning site of pHKLc2 including a *Sall* restriction site (in italics) and a replacement of the C in position 21 by a G (underlined) destroying the *ClaI* site and:
*ohprK*Lc6 5'-CATGACATCGATAATGCCCTAGCCACGAATTTC-3').
**[0109]** Oligonucleotide *ohprK*Lc6 is based on the DNA sequence from position 610 to 643 of *L. casei* hprK containing a *ClaI* site (in italics). In position 20 of *ohprK*Lc6, a T is present instead of an A, changing the leucine-encoding TTG triplet (in position 208 of *hprK*) to an amber codon (underlined).
**[0110]** The resulting 522 bp PCR fragment was digested with *Sall* and *ClaI* and cloned into pHKLc1 cut with the same enzymes, thus providing pHKLc3 containing the 3' part of *hprK* with the amber mutation and the 5' part of *lgt*. Plasmid pHKLc3 was digested with HindIII and SacI and the resulting 1312 bp fragment was cloned into the integrative vector pRV300 cut with the same enzymes to give the 4.8 kb plasmid pHKLc208(Am)
**[0111]** Erythromycin-resistant *L. casei* clones were obtained. In eight clones, the integration of pHKLc208(Am) was tested by Southern blots using as a probe a 590 bp internal *hprK* fragment. Only one HindIII fragment of 5.2 kb could be detected with DNA from wild-type *L. casei* ATCC 393, whereas seven of the eight erythromycin-resistant clones gave two bands with a size of 3.6 and 6.5 kb (data not shown), suggesting that plasmid pHKLc208(Am), which contains a single HindIII site, had been integrated in the chromosome of these transformants. In the remaining eighth erythromycin-resistant clone, two copies of pHKLc208(Am) seemed to be integrated in tandem, as three fragments of 3.6, 6.5 and 4.6 kb could be detected on the Southern blot.
**[0112]** Campbell-like recombination of pHKLc208(Am) with the *L. casei* chromosome can occur at two different sites with respect to the position of the PCR-introduced amber codon, giving rise to two types of integrants exhibiting either an HprK+ or HprK- phenotype.
**[0113]** One of the mutants in which the presence of the *hprK*208(Am) mutation has been confirmed by DNA sequencing of appropriate PCR products was named LcG102 and used for further studies. Chromosomal DNA of LcG102 was isolated, digested with HindIII, religated, transformed into *E. coli* NM522 and 3 ampicillin-resistant clones were chosen for further experiments. The plasmids present in the 3 clones were purified and found to carry an about 3.2 kb insert. DNA sequencing of the plasmid pHKLcUS from one of the transformants revealed that the insert contained in addition to the insert of pHKLc208(Am) the 5' part of the presumed *hprK*, its promoter region and two complete and one incomplete ORF located upstream of *hprK* (Fig. 1). The proteins encoded by these three ORF's exhibited 23, 22 and 36% sequence identity, respectively, when compared to the proteins encoded by the *B. subtilis* yvIB, yvIC and yvID genes [KUNST et al., Nature, 390, 249-256, (1997)].
**[0114]** The presumed *L. casei* hprK gene consists of 957 bp and encodes a protein of 35349 Da composed of 319 amino acids, which exhibits 50% sequence identity when compared to the *B. subtilis* HprK. As in all other known HprK, the A-motif of nucleotide binding proteins (GX$_4$GKS) is present around position 160. The presumed *hprK* gene starts with an ATG, which is preceded by a putative ribosome binding site (AAGAAAGG) located 8 bp upstream of the start codon. Downstream of *hprK* and separated from *hprK* by only 1 bp begins the *lgt* gene. The cloned *lgt* fragment encodes the first 129 amino acids of *L. casei* Lgt which exhibit 53% sequence identity when compared to the corresponding N-terminal part of *B. subtilis* Lgt.
EXAMPLE 4: CHARACTERISATION OF WILD TYPE AND MUTANT HprK
*L. casei* HprK is a bifunctional enzyme regulated by FBP and Pi
**[0115]** In order to confirm that the presumed *hprK* gene encodes indeed *L. casei* HprK and to test whether it exhibits both HPr kinase and P-Ser-HPr phosphatase activities similar to the *B. subtilis* and *Enterococcus faecalis* enzymes, His-tagged *L. casei* HprK was purified.
**[0116]** To purify *L. casei* HprK carrying a His-tag, PCR amplification was carried out using chromosomal *L. casei* DNA as a template and the two oligonucleotides:
5'-GTGGGATCCATGGCAAGACAGCGC-3' and
5'-TACGGTACCAAATGACTTCCA-3'
containing a BamHI and a KpnI restriction site, respectively (in italics). The resulting 1033 bp fragment containing the complete *hprK* gene was cut with BamHI and KpnI and cloned into plasmid pQE30 (QIAGEN) cut with the same restriction enzymes to give pQEHKLc. The correct sequence of the amplified *hprK* was confirmed by DNA sequencing.
**[0117]** In order to purify His-tagged *L. casei* HprK, *E. coli* strain M15[pREP4] (QIAGEN) was transformed with plasmid pQEHKLc. A resulting transformant was isolated and grown in 1 l of LB medium (DIFCO) at 37 °C until it reached an OD$_{595}$ of about 0.7. Subsequently, expression was induced by addition of 1 mM IPTG. Cells were grown for an additional 3 h before they were centrifuged, washed twice with 100 mM Tris-HCl buffer, pH 7.4, and broken by sonication (BRANSON SONIFIER 251). Cell debris was removed by centrifugation and the resulting supernatant was loaded onto a Ni-NTA-agarose column (QIAGEN) equilibrated with buffer A (50 mM Tris-HCl, pH 7.4, 15% glycerol and 50 mM Na$_2$SO$_4$). After washing with 30 mM imidazole, HprK was eluted with the equilibration buffer containing 300 mM imidazole. HprKcontaining fractions were pooled, dialyzed against 50 mM Tris-HCl buffer, pH 7.4, containing 0.1 mM DTT and 0.1 mM PMSF and subsequently stored at -80 °C.
[0118] His-tagged *B. subtilis* and its seryl-phosphorylated derivative were prepared as described in [GALINIER et al., Proc. Natl. Acad. Sci. USA, 95, 1823-1828, (1998)]. For the preparation of P-Ser-HPr, HPr kinase present in the phosphorylation mixture was inactivated by keeping it for 5 min at 65 °C once the phosphorylation reaction was terminated. To completely remove ATP and FBP from the P-Ser-HPr preparation it was desalted on a 10 ml SEPHADEX G-10 column. His-tagged *B. subtilis* HprK was overproduced and purified as described in [GALINIER et al., Proc. Natl. Acad. Sci. USA, 95, 1823-1828, (1998)], and *B. subtilis* Ser-46-Ala mutant HPr was obtained as described in [EISERMANN et al., J. Biol. Chem., 263, 17050-17054, (1998)].
[0119] Using HPr(His)$_6$ or P-Ser-HPr(His)$_6$ from *B. subtilis* as substrates, HprK of *L. casei* was indeed found to be bifunctional.
[0120] The effects of FBP and inorganic phosphate (P$_i$) on HPr kinase and P-Ser-HPr phosphatase activities of purified *L. casei* HprK(His)$_6$ were measured. The assay mixtures contained in a total volume of 20 µl 0.005, 0.02 or 0.05 µg HprK(His)$_6$, 5 mM MgCl$_2$, 50 mM Tris-HCl, pH 7.4 and in addition for the kinase assays 2.5 µg *B. subtilis* P-Ser-HPr(His)$_6$ and varying concentrations of sodium phosphate and were incubated for 5 min at 37 °C. The reactions were stopped by heating the assay mixtures for 5 min at 65 °C. Equal volumes of sample buffer were added to the assay mixtures before separating HPr and P-Ser-HPr on a 12.5% non-denaturing polyacrylamide gel.
[0121] ATP-dependent HPr phosphorylation was slightly stimulated by FBP at concentrations higher than 1 mM, whereas the P-Ser-HPr phosphatase activity was clearly stimulated by 0.2 mM and higher concentrations of P$_i$. Stimulation of ATP-dependent HPr phosphorylation by FBP was more evident when the HPr kinase assays were carried out in the presence of P$_i$. With 1 mM P$_i$, no HPr phosphorylation could be observed in the absence of FBP, whereas in the presence of 20 mM FBP a strong HPr kinase activity could be detected. When using 8 mM P$_i$, FBP had almost completely lost its stimulating effect on HPr phosphorylation. HprK-catalyzed phosphorylation occurs at Ser-46 of HPr, as *B. subtilis* Ser-46-Ala mutant HPr was not phosphorylated by the *L. casei* HprK.
[0122] HPr kinase and P-Ser-HPr phosphatase activities were determined in crude extracts of *L. casei* wild-type and pHrK208(Am) integrants.
[0123] Cells were grown in 10 ml MRS medium, harvested by centrifugation and washed twice with 50 mM Tris-HCl buffer, pH 7.4. The pellet was resuspended in 800 µl of the same buffer, cells were broken by sonication (BRANSON SONIFIER 250) and cell debris was removed by centrifugation.
[0124] To demonstrate HPr kinase activity in *L. casei* crude extracts, ATP-dependent phosphorylation assays were carried out in the presence or absence of 1.5 µg *B. subtilis* HPr(His)$_6$ in a total volume of 20 µl containing 5 µl crude extract, 25 µM [γ-³²P]ATP (0.5 µCi), 10 mM MgCl$_2$, 50 mM Tris-HCl, pH 7.4 and 20 mM FBP. The phosphorylation reaction was stopped by adding an equal volume of sample buffer [LAEMMLI, Nature, 227, 680-685, (1970)] to the assay mixtures before loading them onto a 15% polyacrylamide gel containing 0.1% SDS. After electrophoresis, gels were treated for 5 min with boiling 18% trichloroacetic acid before they were dried and exposed to autoradiography (BIOMAX MR, Kodak). Control experiments were carried out with 0.5 µg of purified *B. subtilis* HprK(His)$_6$ and 1.5 µg HPr(His)$_6$.
[0125] No HPr kinase activity was detected in crude extracts of hprK208(Am) mutant strain.
[0126] To test whether this mutant was also devoid of P-Ser-HPr phosphatase activity, crude extracts of *L. casei* wild-type and the hprK208(Am) mutant strain were prepared and their capacity to dephosphorylate P-Ser-HPr was assayed in the presence of 20 mM P$_i$.
[0127] P-Ser-HPr phosphatase assays were carried out by incubating a 20 µl assay mixture containing 10 µl crude extract, 2.5 µg *B. subtilis* P-Ser-HPr(His)$_6$, 20 mM sodium phosphate, pH 7.2, 10 mM MgCl$_2$ and 50 mM Tris-HCl, pH 7.4, for 10 min at 37 °C. The dephosphorylation reaction was stopped by heat inactivation at 65 °C for 5 min. An equal volume of sample buffer was added to the assay mixtures before separating HPr and P-Ser-HPr on a 12.5% non-denaturing polyacrylamide gel.
[0128] Whereas P-Ser-HPr phosphatase activity could be easily seen with crude extracts of the wild type strain, no activity could be detected with this test in crude extracts of the hprK208(Am) mutant LcG102. Even increasing the incubation time from 10 to 30 min did not allow to detect dephosphorylated HPr in the P-Ser-HPr phosphatase assay with crude extracts of the hprK208(Am) mutant.
**The hprK208(Am) mutation affects CCR**
[0129] To determine whether similar to *B. subtilis* HprK, *L. casei* HprK is also involved in CCR, the repressive effect of glucose on N-acetylglucosaminidase activity was measured in the hprK208(Am) mutant and compared to the activity found in wild-type and ccpA, ptsH1 and hprK208(Am) mutant strains.
[0130] Wild-type and ccpA, ptsH1 and hprK208(Am) mutant cells were grown in 10 ml MRS fermentation medium to an OD$_{595}$ between 0.7 and 0.9, centrifuged and washed twice with 10 mM sodium phosphate buffer, pH 7.2. Permeabilized
*L. casei* cells were obtained as described in [CHASSY et al., J. Bacteriol., 154, 1195-1203, (1983)]. To measure N-acetylglucosaminidase activity, a 500 µl assay mixture containing 10 µl de permeabilized cells, 10 mM sodium phosphate, pH 6.8, 1 mM MgCl$_2$ and 5 mM p-nitrophenyl-N-acetyl-β-D-glucosamine (SIGMA) was incubated for 10 min at 37°C. The reaction was stopped with 500 µl of 5% Na$_2$CO$_3$, and the OD$_{420}$ was measured.
[0131] In the wild-type strain ATCC 393, N-acetylglucosaminidase activity was repressed 18-fold by the presence of glucose, whereas N-acetylglucoamidinase activity was derepressed in ribose-grown cells (Table 2). Similar as in *L. casei* *ccpA* or *ptsH1* mutants CCR of N-acetylglucosaminidase activity was strongly diminished in the *hprK208(Am)* mutant LcG102 (Table 2).
| Strains | N-acetylglucosaminidase activity a |
|-------------|-----------------------------------|
| | Glucose | Ribose |
| wild-type | 2.0 ± 0.9 | 37.6 ± 6.7|
| *hprK208(Am)* | 26.3 ± 1.7 | 31.5 ± 4.5|
| *ptsH1* | 26.7 ± 6.5 | 35.3 ± 7.2|
| *ccpA* | 19.4 ± 0.7 | 30.6 ± 4.3|
a: N-acetylglucosaminidase activity was determined using p-nitrophenyl-N-acetyl-β-D-glucosamine as substrate. Activity is expressed in nmoles per min per mg of cells (dry weight)
The *hprK208(Am)* mutation affects diauxic growth
[0132] Growth of the *hprK208(Am)* mutant LcG102 in MRS medium containing 0.05% glucose and either 0.05% lactose or 0.05% maltose was compared to the growth behaviour of the wild-type strain ATCC 393. Wild-type *L. casei* grown in media containing mixtures of glucose and lactose or glucose and maltose exhibited a diauxic growth curve characterized by two distinct growth phases separated by a lag phase of about 8 h for cells growing on glucose/lactose and 7 h for cells growing on glucose/maltose medium. In the *hprK208(Am)* mutant LcG102, the lag phase was reduced to less than 3 h for cells grown in either glucose and lactose- or glucose and maltose-containing medium.
**The *hprK208(Am)* mutation prevents the exclusion of maltose by glucose**
[0133] It is shown above that replacement of Ser-46 in *L. casei* HPr with alanine or threonine or replacement of Ile-47 with threonine prevents the exclusion of maltose by glucose. To ensure that the observed effect of the *ptsH* mutations is indeed due to the absence of ATP-dependent, HPr-catalyzed phosphorylation of HPr in the *ptsH* mutants and not due to structural changes of HPr caused by the mutations, we studied glucose-triggered maltose exclusion in the *hprK208 (Am)* mutant strain LcG102. Maltose uptake by wild-type cells was instantaneously arrested when glucose was added to the transport medium. By contrast, when an identical experiment was carried out with the *hprK208(Am)* mutant LcG102, maltose uptake was not inhibited but rather slightly stimulated by the presence of glucose. The absence of glucose-triggered maltose exclusion in the *hprK208(Am)* mutant was confirmed by measuring maltose consumption in the presence and absence of 0.15% glucose with *L. casei* wild-type and *hprK208(Am)* mutant strains. In the wild-type strain, maltose was not utilized as long as glucose was present in the growth medium, whereas maltose and glucose were simultaneously consumed by the *hprK208(Am)* mutant LcG102.
**EXAMPLE 5: CONSTRUCTION AND CHARACTERISATION OF FOOD-GRADE *ptsI* AND *ccpA* MUTANTS**
[0134] Food grade mutants of *ptsI* or *ccpA* genes were constructed in the industrial strain of *L. paracasei* subsp. paracasei CNCM I-1518; this strain is disclosed in EP 0 794 707.
**Construction of a *ptsI* mutant**
[0135] This mutant was constructed using the method of Example 2.
[0136] Plasmid pVMR10 was used to transform *L. casei* CNCM I-1518.
[0137] The transformed strain was grown in MRS medium comprising 5 µg/ml erythromycin. An erythromycin-resistant
ptsI* integrant was isolated. This integrant was grown for 200 generations in MRS medium without erythromycin to allow the second recombination leading to the excision of the pVMR10 plasmid.
[0138] An erythromycin-sensitive Lac- clone was isolated as disclosed by Example 2 above, checked by PCR and its ptsI gene sequenced. The fermentation pattern of this clone in API-CH50L showed that, when compared to the wild type CNCMI I-1518, this mutant could no longer use adonitol, fructose, mannose, sorbose, mannitol, sorbitol, amygdaline, arbutine, salicine, cellobiose, sucrose and trehalose.
[0139] This mutant was grown at 37 °C in low-fat milk (13 g fat/kg) or skim milk. In skim milk, a pH of 4.45 was reached after 34 h (under the same conditions a pH of 4.45 was reached after 30 h with the wild-type strain CNCM I-1518).
[0140] In another series of tests, standardized milk having 170 g protein/kg, 13 g fat/kg, and supplemented with 50 g glucose/kg was used.
[0141] The fermented products obtained from standardized milk supplemented with glucose with the mutant strain ptsI have a gel-strength lower of about 15-25% than the fermented products obtained from the wild-type strain. This allows to obtain a more elastic gel of about 15-25%, and to reduce syneresis.
[0142] They also have a slightly lower viscosity than the fermented products obtained with the wild-type strain. However, the loss of viscosity under shearing is less important in the case of the products obtained with the mutant strain. This property allows a better conservation of the texture during industrial processes wherein shearing may occur, such as the preparation of stirred fermented milk.
[0143] The fermented products obtained with the mutant strain had a more creamy flavour than the fermented products obtained with the wild-type strain. This is related to a higher content in C4, C6, C8, C12, C14, and C16 fatty acids.
Construction of a ccpA mutant
[0144] Mutants in *L. casei* BL23 and CNCM I-1518 were constructed with the following procedure:
[0145] Plasmid pJDC9 [CHEN and MORRISON, Gene, 64, 155-164, (1988)] carrying a SalI restriction fragment of 2.6 kb that included ccpA gene and flanking regions, was digested with EcoRI, made blunt end (filled in with the Klenow enzyme), ligated and transformed in *E. coli* DH5α. This plasmid (pJ-ccpA) was used to transform both *L. casei* strains.
[0146] The transformed strains were grown in MRS medium comprising 5 μg/ml erythromycin and erythromycin-resistant integrants were isolated.
[0147] Then, one integrant of each transformation event was grown for 200 generations in MRS medium without erythromycin leading to the excision of the plasmid. Erythromycin-sensitive colonies showing slower growth were screened by PCR amplification of ccpA, followed by digestion with EcoRI. Strains where the amplified fragment was not digested by EcoRI were further analysed by sequencing the ccpA gene. Sequencing of the ccpA mutant gene showed that an insertion of four nucleotides (AATT) had occurred at position 710 of the sequence U28137 of GENBANK. This insertion generated a stop codon 5 codons after the mutation site and resulted in a truncated CcpA protein of 143 amino acids that is inactive.
[0148] When this mutant was grown at 37 °C in skim milk, a pH of 4.45 was reached after 45 h.
[0149] The fermented products obtained with the mutant strain from standardized milk supplemented with glucose had a content in acetic acid, succinic acid, and formic acid twice higher than the fermented products obtained from the wild-type strain. They also contained the same quantity of lactate than the products obtained from the wild-type strain. They contained less citrate, due to a citrate consumption by the ccpA mutant 10 times higher than by the wild-type strain.
[0150] They had also a higher content in acetoin (4 to 6 times higher) than the fermented products obtained from the wild-type strain.
[0151] The overproduction of acetoin by the ccpA mutant indicates that it is potentially able to overproduce diacetyl under appropriate conditions (i.e. oxidative conditions which promotes the conversion of α-acetolactate into diacetyl rather than into acetoin).
EXAMPLE 6: POST-ACIDIFICATION PROPERTIES OF FOOD GRADE ptsI AND ccpA MUTANTS
[0152] The ptsI and ccpA mutants of Example 5 were grown as described above on standardized milk supplemented with glucose until a pH of about 4.55.
[0153] The fermented milks thus obtained are stored at 4 °C, 8 °C, or 13 °C, and the pH is measured after 7, 14, 21, or 28 days of storage.
[0154] Figure 7 represents the post-acidification during storage at different temperatures for fermented milks obtained with the wild-type strain or with the ccpA or ptsI mutant.
[0155] Legend of Figure 7:
-•-: wild type strain 4 °C
-▲-: wild type strain 8 °C
-♦-: wild type strain 13°C
-○-: ccpA mutant 4°C
-Δ-: ccpA mutant 8°C
-◇-: ccpA mutant 13°C
-•-: ptsI mutant 4°C
-▲-: ptsI mutant 8°C
-♦-: ptsI mutant 13°C
[0156] These results show that in every case, the ccpA and ptsI mutants have a reduced post-acidification compared with the wild-type strain.
[0157] This reduced post-acidification is not due to a lower survival of the mutant strains. This was controlled by measuring the survival rate at 28 days. It is higher than 60% for the ccpA and ptsI mutants as well as for the wild-type strain.
Annex to the application documents - subsequently filed sequences listing
[0158]
SEQUENCE LISTING
<110> CNRS
CSIC
COMPAGNIE GERVAIS DANONE
DELFACHER, Jürgen
PEREZ BUITINER, Gaspar
MONEDERO GARCIA, Vicente
VIANA BALLESTER, Rosa
BENBADIS, Laurent
PIERSON, Jean
FARGUE, Jean-Michel
<120> MUTANTS OF LACTOBACILLUS CASEI DEFECTIVE IN CARBON
CATABOLISM REGULATION
<130> MJPcb191-171
<140>
<141>
<150> EP 00400894.2
<151> 2000-03-31
<160> 3
<170> Patentin Ver. 2.1
<210> 1
<211> 4150
<212> DNA
<213> Lactobacillus casei
<220>
<221> CDS
<222> (273)..(536)
<223> Product: Hpr
<220>
<221> CDS
<222> (539)..(2263)
<223> Product: Enzyme I
<400> 1
gtgacgccaag aaacgttcat gcgcgtttcgc gcgccatgga cgaattatcc tgatctgtgaa 60
gagatcgtgg gaatggctaa acgtgtatgg ttg ctattgaat accattatcg atcagtgtat 120
tctctgttaat atagccgcca aattctgatgt ggcgttgtg acaaagcttca aaaaatggta 180
aggtttcacat gaattgtttt gggtacgaat ggcgcacacaa actattcggga aaaaaaactag 240
aaatctagtt aatacgaagg agcagatcag tc atg gaa aaa cgc gaa ttt aat 293
Met Glu Lys Arg Glu Phe Asn
1 5
att att gca gaa acc ggg atc cac gca cgt ccg gca acc ttg ttg gta 341
Ile Ile Ala Glu Thr Gly Ile His Ala Arg Pro Ala Thr Leu Leu Val
10 15 20
cag gca gca agc aag ttc aac tca gat atc aac ttg gaa tac aag ggt 389
Gln Ala Ala Ser Lys Phe Asn Ser Asp Ile Asn Leu Glu Tyr Lys Gly
25 30 35
aag agc gtt aac ttg aag tct atc atg ggc gtc atg agt ttg ggt gtt 437
Lys Ser Val Asn Leu Lys Ser Ile Met Gly Val Met Ser Leu Gly Val
40 45 50 55
ggc caa ggt gcc gat gtt acc att tct gct gaa ggt gca gac gag gct Gly Glu Gly Ala Asp Val Thr Ile Ser Ala Glu Gly Ala Asp Glu Ala 60 65 70
gat gct atc gct gct att aca gac aca atg aaa aag gaa ggc ttg gct Asp Ala Ile Ala Ala Ile Thr Asp Thr Met Lys Lys Glu Gly Leu Ala 75 80 85
gaa ta atg gct gaa cat ttg aag gga atc gct gct agt gat ggg atc Glu Met Ala Glu His Leu Lys Gly Ile Ala Ala Ser Asp Gly Ile 90 95 100
gcc aca gcg aag gcc tat tta ctg gtt caa cct gat ttg tca ttc caa Ala Thr Ala Lys Ala Tyr Leu Val Glu Pro Asp Leu Ser Phe Glu 105 110 115
aaa aag acg gtt gat gat cct tca aag gaa atc gat cgc ctg aag cag Lys Lys Thr Val Asp Asp Pro Ser Lys Glu Ile Asp Arg Leu Lys Gln 120 125 130
tca ctt gat caa agt aat gat gag tta aag gtt att cga gca aag gcc Ser Leu Asp Glu Ser Asp Asp Glu Leu Lys Val Ile Arg Ala Lys Ala 135 140 145
gct gaa tcg ctt ggc gaa gaa gag gct cag gtt ttt gat gcg cac atg Ala Glu Ser Leu Gly Glu Glu Glu Ala Glu Val Phe Asp Ala His Met 155 160 165
atg att ttg gct gat cct gac tt act ggt cag gta gag act aag atc Met Ile Leu Ala Asp Pro Asp Phe Thr Gly Glu Val Glu Thr Lys Ile 170 175 180
aag gat gaa aaa gtc aat gct gag cag gct ttg aaa gaa gtc tcc gaa Lys Asp Glu Lys Val Asn Ala Glu Glu Ala Leu Lys Glu Val Ser Glu 185 190 195
ttc ttt att aag aca ttc gaa ggt atg acc gac aat cca tat atg cag Phe Phe Ile Lys Thr Phe Glu Gly Met Thr Asp Asn Pro Tyr Met Glu 200 205 210
gaa cgt ggc gct gat gtc cgc gac gtg aca aag cgg atc atg gca cac Glu Arg Ala Ala Asp Val Arg Asp Val Thr Lys Arg Ile Met Ala His 215 220 225 230
ttg ctc ggt cgc aat ttg cca aat cca gca tta att gat gaa gaa gtc Leu Leu Gly Arg Asn Leu Pro Asn Pro Ala Leu Ile Asp Glu Glu val 235 240 245
gtt gtg gtt gcg cat gac tgt acc cct tcg gat acc gca caa ttg aat Val Val Val Ala His Asp Leu Thr Pro Ser Asp Thr Ala Glu Leu Asn 250 255 260
aag aag tat gtc aaa gca ttt gtc acg gat att ggc ggt cgg act gcg Lys Lys Tyr Val Lys Ala Phe Val Thr Asp Ile Gly Gly Arg Thr Ala 265 270 275
cac agt gcg att atg gca cgt tcg ttg gaa att ccg gct gtt gtt ggg His Ser Ala Ile Met Ala Arg Ser Leu Glu Ile Pro Ala Val Val Gly 280 285 290
aca gat gac att acc aag aag gct aat aac ggt gat ctt att tcc gtt Thr Asp Asp Ile Thr Lys Lys Ala Asn Asn Gly Asp Leu Ile Ser Val 295 300 305 310
gat ggc tta act ggt gaa gtt gtt gat ccg acc gat gat gaa gta Asp Gly Leu Thr Gly Glu Val Val Val Pro Thr Asp Asp Glu Val 315 320 325
gct aag ttc aag cag gat gct gaa gca ttt gct aag caa aaa gct gaa 1300
Ala Lys Phe Lys Gln Asp Ala Glu Ala Phe Ala Lys Gln Lys Ala Glu
330 335 340
tgg gct ctt ttg aag acg gcc aaa tca atc aca gct gat ggc aaa cac 1348
Trp Ala Leu Leu Lys Thr Ala Lys Ser Ile Thr Ala Asp Gly Lys His
345 350 355
ttt gat gtt gct gcc aac atc gcc acg cca aag gat ctt gat ggt gto 1396
Phe Asp Val Ala Ala Asn Ile Gly Thr Pro Lys Asp Leu Asp Gly Val
360 365 370
ctg gca aac ggt gct gaa ggt atc ggt ttg tat cgg aca gag ttc ttg 1444
Leu Ala Asn Gly Ala Glu Gly Ile Gly Leu Tyr Arg Thr Glu Phe Leu
375 380 385 390
tac atg gat tct gct gaa tta ccg acc gaa gac gat caa ttc gag gcc 1492
Tyr Met Asp Ser Ala Glu Leu Pro Thr Glu Asp Asp Gln Phe Glu Ala
395 400 405
tac aag aag gtt gtc gaa acc atg agt ccg aag cct gtt gtt cgg 1540
Tyr Lys Lys Val Val Glu Thr Met Ser Pro Lys Pro Val Val Val Arg
410 415 420
acg atg gat att ggt ggg gat aaa cat ctg cca tat ttg cca ctt cct 1588
Thr Met Asp Ile Gly Gly Asp Lys His Leu Pro Tyr Leu Pro Leu Pro
425 430 435
gaa gaa cag aac cca ttc ttg ggt tat cgt ggc att cgg atc agt ctt 1636
Glu Glu Gln Asn Pro Phe Leu Gly Tyr Arg Ala Ile Arg Ile Ser Leu
440 445 450
gat cgc caa gat atc ttc cgg aca cag ttg cgc gcc ttg ttg cgt gga 1684
Asp Arg Gln Asp Ile Phe Arg Thr Glu Leu Arg Ala Leu Leu Arg Ala
455 460 465 470
tct gcc ttt ggc aat ctg cgg atc atg ttc cct atg att gct acc att 1732
Ser Ala Phe Gly Asn Leu Arg Ile Met Phe Pro Met Ile Ala Thr Ile
475 480 485
gct gaa ttc aag caa gca agg cag att ttc act gaa gaa aaa gat aag 1780
Ala Glu Phe Lys Gln Ala Arg Gln Ile Phe Thr Glu Glu Lys Asp Lys
490 495 500
tta gtc aag gat ggc gtc aaa gta tct gat gat atc caa ctt ggc att 1828
Leu Val Lys Asp Gly Val Lys Val Ser Asp Asp Ile Gln Leu Gly Ile
505 510 515
atg atc gaa att cct gca gct gca gtt ttg gct gat cag ttt gct aag 1876
Met Ile Glu Ile Pro Ala Ala Ala Val Leu Ala Asp Gln Phe Ala Lys
520 525 530
tat gtt gac ttc ttc tcc att ggt aca atg gac tgt atc cag tac tct 1924
Tyr Val Asp Phe Phe Ser Ile Gly Thr Asn Asp Leu Ile Gln Tyr Ser
535 540 545 550
atg gcc gct gat cgt ggg aac gag cat gtt tcc tac ctg tat cag cca 1972
Met Ala Ala Asp Arg Gly Asn Glu His Val Ser Tyr Leu Tyr Gln Pro
555 560 565
tac aac cca tcc atc ctt cgc cta atc aag cac gtg att gat tcg gca 2020
Tyr Asn Pro Ser Ile Leu Arg Leu Ile Lys His Val Ile Asp Ser Ala
570 575 580
cat aag gaa ggc aag tgg gcc ggt atg tgt ggc gaa gct gct ggt gat 2068
His Lys Glu Gly Lys Trp Ala Gly Met Cys Gly Glu Ala Ala Gly Asp
585 590 595
| Position | Sequence | Description |
|----------|---------------------------------|------------------------------|
| 2116 | cca atc atg gta cca ctg ttg ctt ggt atg ggt ctt gac gaa tac tca | Pro Ile Met Val Pro Leu Leu Gly Met Gly Leu Asp Glu Tyr Ser |
| 600 | | |
| 610 | | |
| 2164 | atg tcc gca act tct gtc ctt aaa gta cgc agc ttg atg aag aag ctt | Met Ser Ala Thr Ser Val Leu Lys Val Arg Ser Leu Met Lys Lys Leu |
| 615 | | |
| 620 | | |
| 625 | | |
| 2212 | tcg aca gct gat atg gct aag atg gac gaa att gct ttg aac caa aat | Ser Thr Ala Met Ala Lys Met Asp Glu Ile Ala Leu Asn Gln Asn |
| 635 | | |
| 640 | | |
| 645 | | |
| 2260 | atc act aat gat gaa aac gct gat ctg gtt aag aaa aca act ggt cag | Ile Thr Asn Asp Glu Asn Ala Asp Leu Val Lys Lys Thr Thr Gly Glu |
| 650 | | |
| 655 | | |
| 660 | | |
| 2313 | aaa taacatttca ttatcagaaa gagttcatttg actgaataa tgtacggctt | Lys |
| 2373 | ctttttttga ccaaaatttg attttgatcg tgctcgcctag cattgatttt tctgaaacc | |
| 2433 | gctcgaaaat gggaaccttat ctttgccat caaaaaaggt attcggcac tattttgcgg | |
| 2493 | catctgaaca gtgactgact gcagactttt cagaaaaagt ttaaggttat tatgtaaact | |
| 2553 | aaaaatttag ttaactgattc atggtatggc actgtgagcg gtggttcatt tggacttgta | |
| 2613 | gggggaattt catgtatcaa tcaaaaaaac aacaatcag atttacggt caccttgoga | |
| 2673 | gtgccaagac acggttgcgg cttagtagcat tgatttcaac gatgggttgcc tgcctttttg | |
| 2733 | gctatgacac tggggttgatc aatggcgcat tgccctttat ttcttcgaa ctgaaacttg | |
| 2793 | ccccttggtac acagggtttg gtcacagcta gcttgacgct ggggtcgct ttttggtgca | |
| 2853 | tcttagtcgg tcttttttaagt gatcctgatg ggcgcagggc gcttactcaccc atgttgacgg | |
| 2913 | gctttttttt tctggcaacg gtacgctctcg cactttttccc gaagtgtggtc tggctgtatgg | |
| 2973 | ggcgacggtc gatctttgga tttagcggttt gcgcgcgttc ttgtctgtttt ccaacgtttt | |
| 3033 | tagcagagat tgccccaaac agtcatcgctg ggcggtttagt cacacaaaat gagctgtatgg | |
| 3093 | tctgtgactgg ccgatctactt gctttttgttc tcaatgccttt tttaggaacc acttttttggtta | |
| 3153 | acgtttcctgg tatctggcgc tggatgtatgg tatggcaggt cattccggca atttatctag | |
| 3213 | gtatcgggac tattttttgtt ccggaacttc ctctgtgtgtt aatgtatgaa ggacgcccgg | |
| 3273 | cagcgcacgct tcaagtttgt gaagttgtgc gatctgtctgc tgaagtgcca gcagagatttg | |
| 3333 | accatttgaa acagaatttt gccgaagatg cttaacataaa gcagggcgagt gttcgagcat | |
| 3393 | tgaaaaaccaa atgtatttcgc cgactggttc tgatgtgcat cgyccttaggc gtcatttcaag | |
| 3453 | aaatttgctgg tatcaaatgtc atgatgtatt atggcaccttc aatttttacaa atgacgggtt | |
| 3513 | ttggcgcaga taagcgccttg atgcgcaaca ttgcaaatgg ggttacttgcc gttgtctgcaa | |
| 3573 | cgattgtgac gttgcaatgg ttgaagcatg ttccgcggcg gccaatgtgty attttgggat | |
| 3633 | tgatttgcttc aaccgtggtcg attactgttg tcacctttgc taatcgacta ccagcgggtt | |
| 3693 | cgccatttcgg ggcattttgc acaatcggga tgatgtgct gtttcttgcc ttctttcaag | |
| 3753 | gcgctatcag tccaatgtact tggtctgtga tgctctgaat ctttccctgaa caggttcgcc | |
| 3813 | gcatagggat ggggcgctgca acctcttcgt tgtgtggttg taacttttggt gttgtcgcttc | |
tgtttccgat tgtcttggcc caaatagga tgtcttgac attcgtttgc ttcatcgga 3873
caaaatttgat ttcatgtct ttctgttcta tttttgtgcc gaaacggct ggacgctccc 3933
tcgaaacctt gcaccgagaq gagaagcccc gccttaatca ttaatgacaa cgcatttgtt 3993
caagacaaa aagtgtgcgt ttacaaaaag ttgtgatcca taaaggtgta tcaacaattc 4053
gatgaacctt cacaaaaggg agccattgqc tgagaacggg gaaacccgga cccttcgaac 4113
ctgtctgtta atgcgagcgt agggatttgt gaatgtt 4150
<210> 2
<211> 88
<212> PRT
<213> Lactobacillus casei
<400> 2
Met Glu Lys Arg Glu Phe Asn Ile Ile Ala Glu Thr Gly Ile His Ala
1 5 10 15
Arg Pro Ala Thr Leu Leu Val Gln Ala Ala Ser Lys Phe Asn Ser Asp
20 25 30
Ile Asn Leu Glu Tyr Lys Gly Lys Ser Val Asn Leu Lys Ser Ile Met
35 40 45
Gly Val Met Ser Leu Gly Val Gly Gln Gly Ala Asp Val Thr Ile Ser
50 55 60
Ala Glu Gly Ala Asp Glu Ala Asp Ala Ile Ala Ala Ile Thr Asp Thr
65 70 75
Met Lys Lys Glu Gly Leu Ala Glu
85
<210> 3
<211> 575
<212> PRT
<213> Lactobacillus casei
<400> 3
Met Ala Glu His Leu Lys Gly Ile Ala Ala Ser Asp Gly Ile Ala Thr
1 5 10 15
Ala Lys Ala Tyr Leu Leu Val Gln Pro Asp Leu Ser Phe Gln Lys Lys
20 25 30
Thr Val Asp Asp Pro Ser Lys Gly Ile Asp Asp Arg Leu Lys Gln Ser Leu
35 40 45
Asp Gln Ser Asn Asp Glu Leu Lys Val Ile Arg Ala Lys Ala Ala Glu
50 55 60
Ser Leu Gly Glu Glu Ala Gln Val Phe Asp Ala His Met Met Ile
65 70 75
Leu Ala Asp Pro Asp Phe Thr Gly Gln Val Glu Thr Lys Ile Lys Asp
85 90 95
Glu Lys Val Asn Ala Glu Gln Ala Leu Lys Glu Val Ser Glu Phe Phe
100 105 110
Ile Lys Thr Phe Glu Gly Met Thr Asp Asn Pro Tyr Met Gln Glu Arg
115 120 125
Ala Ala Asp Val Arg Asp Val Thr Lys Arg Ile Met Ala His Leu Leu
130 135 140
Gly Arg Asn Leu Pro Asp Pro Ala Leu Ile Asp Glu Glu Val Val Val
145 150 155
Val Ala His Asp Thr Pro Ser Asp Thr Ala Gln Leu Asn Lys Lys
165 170 175
Tyr Val Lys Ala Phe Val Thr Asp Ile Gly Gly Arg Thr Ala His Ser
180 185 190
Ala Ile Met Ala Arg Ser Leu Glu Ile Pro Ala Val Val Gly Thr Asp
195 200 205
Asp Ile Thr Lys Lys Ala Asn Asn Gly Asp Leu Ile Ser Val Asp Gly
210 215 220
Leu Thr Gly Glu Val Val Val Asp Pro Thr Asp Asp Glu Val Ala Lys 225 230 235 240
Phe Lys Gln Asp Ala Glu Ala Phe Ala Lys Gln Lys Ala Glu Trp Ala 245 250 255
5 Leu Leu Lys Thr Ala Lys Ser Ile Thr Ala Asp Gly Lys His Phe Asp 260 265 270
Val Ala Ala Asn Ile Gly Thr Pro Lys Asp Leu Asp Gly Val Leu Ala 275 280 285
Asn Gly Ala Glu Gly Ile Gly Leu Tyr Arg Thr Glu Phe Leu Tyr Met 290 295 300
10 Asp Ser Ala Glu Leu Pro Thr Glu Asp Asp Gln Phe Glu Ala Tyr Lys 305 310 315 320
Lys Val Val Glu Thr Met Ser Pro Lys Pro Val Val Val Arg Thr Met 325 330 335
Asp Ile Gly Gly Asp Lys His Leu Pro Tyr Leu Pro Leu Pro Glu Glu 340 345 350
Gln Asn Pro Phe Leu Gly Tyr Arg Ala Ile Arg Ile Ser Leu Asp Arg 355 360 365
15 Gln Asp Ile Phe Arg Thr Gln Leu Arg Ala Leu Leu Arg Ala Ser Ala 370 375 380
Phe Gly Asn Leu Arg Ile Met Phe Pro Met Ile Ala Thr Ile Ala Glu 385 390 395 400
Phe Lys Gln Ala Arg Gln Ile Phe Thr Glu Glu Lys Asp Lys Leu Val 405 410 415
Lys Asp Gly Val Lys Val Ser Asp Ile Gln Leu Gly Ile Met Ile 420 425 430
Glu Ile Pro Ala Ala Ala Val Leu Ala Asp Gln Phe Ala Lys Tyr Val 435 440 445
20 Asp Phe Phe Ser Ile Gly Thr Asn Asp Leu Ile Gln Tyr Ser Met Ala 450 455 460
Ala Asp Arg Gly Asn Glu His Val Ser Tyr Leu Tyr Gln Pro Tyr Asn 465 470 475 480
Pro Ser Ile Leu Arg Leu Ile Lys His Val Ile Asp Ser Ala His Lys 485 490 495
Glu Gly Lys Trp Ala Gly Met Cys Gly Glu Ala Ala Gly Asp Pro Ile 500 505 510
Met Val Pro Leu Leu Leu Gly Met Gly Leu Asp Glu Tyr Ser Met Ser 515 520 525
30 Ala Thr Ser Val Leu Lys Val Arg Ser Leu Met Lys Lys Leu Ser Thr 530 535 540
Ala Asp Met Ala Lys Met Asp Glu Ile Ala Leu Asn Gln Asn Ile Thr 545 550 555 560
Asn Asp Glu Asn Ala Asp Leu Val Lys Lys Thr Thr Gly Glu Lys 565 570 575
SEQUENCE LISTING
<110> CNRS
CSIC
COMPAGNIE GERVAIS DANONE
DEUTSCHER, Josef
PEREZ MARTINEZ, Gaspar
MONEDERO GARCIA, Vicente
VIANA BALLESTER, Rosa
BENBADIS, Laurent
PIERSON, Anne
FAURIE, Jean-Michel
<120> MUTANTS OF LACTOBACILLUS CASEI DEFECTIVE IN CARBON CATABOLISM REGULATION
<130> VMaah191-171EPl
<140> EP 06022678.4
<141> 2006-10-31
<160> 23
<170> PatentIn version 3.3
<210> 1
<211> 4150
<212> DNA
<213> Lactobacillus casei
<220>
<221> CDS
<222> (273)..(536)
<220>
<221> CDS
<222> (539)..(2263)
<400> 1
gtgacgcccag aaacgttcat ggcgtttcgc gcggcatgga cgaattatcc tgatcgtgaa 60
gagatcgctg gaatgctaa acgtgatggt gtcattgaat accattatcg atcagttgat 120
ttctcgtaat atagggcaca aatctgatgt ggccgtttgtg acaagcttca aaaaatggtta 180
aggtttacat gaattgtttt gggtacgaat gcgcacacaa actattcggta aaaaaacttag 240
aatcttagtt aatacgaagg agcagatcag tc atg gaa aaa cgc gaa ttt aat 293
Met Glu Lys Arg Glu Phe Asn
1 5
att att gca gaa acc ggg atc cac gca cgt ccg gca acc ttg ttg gta 341
Ile Ile Ala Glu Thr Gly Ile His Ala Arg Pro Ala Thr Leu Leu Val
10 15 20
cag gca gca agc aag ttc aac tca gat atc aac ttg gaa tac aag ggt 389
Gln Ala Ala Ser Lys Phe Asn Ser Asp Ile Asn Leu Glu Tyr Lys Gly
25 30 35
aag agc gtt aac ttg aag tct atc atg ggc gtc atg agt ttg ggt gtt 437
Lys Ser Val Asn Leu Lys Ser Ile Met Gly Val Met Ser Leu Gly Val
40 45 50 55
ggc caa ggt gcc gat gtt acc att tct gct gaa ggt gca gac gag gct
Gly Gln Gly Ala Asp Val Thr Ile Ser Ala Glu Gly Ala Asp Glu Ala
60 65 70
gat gct atc gct gct att aca gac aca atg aaa aag gaa ggc ttg gct
Asp Ala Ile Ala Ala Ile Thr Asp Thr Met Lys Lys Glu Gly Leu Ala
75 80 85
gaa ta atg gct gaa cat ttg aag gga atc gct gct agt gat ggg atc
Glu Met Ala Glu His Leu Lys Gly Ile Ala Ala Ser Asp Gly Ile
90 95 100
gcc aca gcg aag gcc tat tta ctg gtt caa cct gat ttg tca ttc caa
Ala Thr Ala Lys Ala Tyr Leu Leu Val Pro Asp Leu Ser Phe Gln
105 110 115
aaa aag acg gtt gat gat cct tca aag gaa atc gat cgc ctg aag cag
Lys Lys Thr Val Asp Asp Pro Ser Lys Glu Ile Asp Arg Leu Lys Gln
120 125 130
tca ctt gat caa agt aat gat gag tta aag gtt att cga gca aag gcc
Ser Leu Asp Gln Ser Asn Asp Glu Leu Lys Val Ile Arg Ala Lys Ala
135 140 145 150
gct gaa tcg ctt ggc gaa gaa gag gct cag gtt ttt gat ggc cac atg
Ala Glu Ser Leu Glu Glu Glu Ala Glu Val Phe Asp Ala His Met
155 160 165
atg att ttg gct gat cct gac ttt act gtt cag gta gac act aag atc
Met Ile Leu Ala Asp Pro Asp Phe Thr Gly Glu Val Glu Thr Lys Ile
170 175 180
aag gat gaa aaa gtc aat gct gag cag gct ttg aaa gaa gtc tcc gaa
Lys Asp Glu Lys Val Asn Ala Glu Glu Ala Leu Lys Glu Val Ser Glu
185 190 195
ttc ttt att aag aca ttc gaa ggt atg acc gac aat cca tat atg cag
Phe Phe Ile Lys Thr Phe Glu Gly Met Thr Asp Asn Pro Tyr Met Gln
200 205 210
gaa cgt ggc gct gat gtc cgc gac gtg aca aag cgg atc atg gca cac
Glu Arg Ala Ala Asp Val Arg Asp Val Thr Lys Arg Ile Met Ala His
215 220 225 230
ttg ctc ggt cgc aat ttg cca aat cca gca tta att gat gaa gaa gtc
Leu Leu Gly Arg Asn Leu Pro Asn Pro Ala Leu Ile Asp Glu Glu Val
235 240 245
gtt gtg gtt ggc cat gac ctg acc cct tcg gat acc gca caa ttg aat
Val Val Val Ala His Asp Leu Thr Pro Ser Asp Thr Ala Gln Leu Asn
250 255 260
aag aag tat gtc aaa gca ttt gtc acg gat att ggc ggt cgg act gcg
Lys Lys Tyr Val Lys Ala Phe Val Thr Asp Ile Gly Gly Arg Thr Ala
265 270 275
cac agt ggc att atg gca cgt tcg ttg gaa att ccg gct gtt gtt ggg
His Ser Ala Ile Met Ala Arg Ser Leu Glu Ile Pro Ala Val Val Gly
| | Sequence | Amino Acids |
|---|----------|-------------|
| 5 | aca gat gac att acc aag aag gct aat aac ggt gat ctt att tcc gtt | Thr Asp Asp Ile Thr Lys Lys Ala Asn Asn Gly Asp Leu Ile Ser Val |
| | 295 | 300 | 305 | 310 |
| | gat ggc tta act ggt gaa gtt gtt gtt gat ccg acc gat gat gaa gta | Asp Gly Leu Thr Gly Glu Val Val Val Pro Thr Asp Asp Glu Val |
| | 315 | 320 | 325 |
| 10| gct aag ttc aag cag gat gct gaa gca ttt gct aag caa aaa gct gaa | Ala Lys Phe Lys Gln Asp Ala Glu Ala Phe Ala Lys Lys Ala Glu |
| | 330 | 335 | 340 |
| 15| tgg gct ctt ttg aag acg gcc aaa tca atc aca gct gat ggc aaa cac | Trp Ala Leu Leu Lys Thr Ala Lys Ser Ile Thr Ala Asp Gly Lys His |
| | 345 | 350 | 355 |
| 20| ttt gat gtt gct gcc aac atc gcg acc cca aag gat ctt gat ggt gtg | Phe Asp Val Ala Ala Asn Ile Gly Thr Pro Lys Asp Leu Asp Gly Val |
| | 360 | 365 | 370 |
| 25| ctg gca aac ggt gct gaa ggt atc ggt ttg tat cgg aca gag ttc ttg | Leu Ala Asn Gly Ala Glu Gly Ile Gly Leu Tyr Arg Thr Glu Phe Leu |
| | 375 | 380 | 385 | 390 |
| 30| tac atg gat tct gct gaa tta ccg acc gaa gac gat caa ttc gag gcc | Tyr Met Asp Ser Ala Glu Leu Pro Thr Glu Asp Asp Gln Phe Glu Ala |
| | 395 | 400 | 405 |
| 35| tac aag aag gtt gtc gaa acg atg agt ccg aag cct gtt gtt gtt cgg | Tyr Lys Lys Val Val Glu Thr Met Ser Pro Lys Pro Val Val Val Arg |
| | 410 | 415 | 420 |
| 40| acg atg gat att ggt ggg gat aaa cat ctg cca tat ttg cca ctt cct | Thr Met Asp Ile Gly Gly Asp Lys His Leu Pro Tyr Leu Pro Leu Pro |
| | 425 | 430 | 435 |
| 45| gaa gaa cag aac cca ttc ttg ggt tat cgt gcc att cgg atc agt ctt | Glu Glu Gln Asn Pro Phe Leu Gly Tyr Arg Ala Ile Arg Ile Ser Leu |
| | 440 | 445 | 450 |
| 50| gat cgc caa gat atc ttc cgg aca cag ttg cgc gcc ttg ttg cgt gca | Asp Arg Gln Asp Ile Phe Arg Thr Gln Leu Arg Ala Leu Leu Arg Ala |
| | 455 | 460 | 465 | 470 |
| 55| tct gcc ttt ggc aat ctg cgg atc atg ttc cct atg att gct acc att | Ser Ala Phe Gly Asn Leu Arg Ile Met Phe Pro Met Ile Ala Thr Ile |
| | 475 | 480 | 485 |
| 60| gct gaa ttc aag caa gca agg cag att ttc act gaa gaa aaa gat aag | Ala Glu Phe Lys Gln Ala Arg Gln Ile Phe Thr Glu Lys Asp Lys |
| | 490 | 495 | 500 |
| 65| tta gtc aag gat ggc gtc aaa gta tct gat gat atc caa ctt ggc att | Leu Val Lys Asp Gly Val Lys Val Ser Asp Asp Ile Gln Leu Gly Ile |
| | 505 | 510 | 515 |
| 70| atg atc gaa att cct gca gct gca gtt ttg gct gat cag ttt gct aag | Met Ile Glu Ile Pro Ala Ala Ala Val Leu Ala Asp Gln Phe Ala Lys |
| | 520 | 525 | 530 |
tat gtt gac ttc ttc tcc att ggt aca aat gac ttg atc cag tac tct 1924
Tyr Val Asp Phe Phe Ser Ile Gly Thr Asn Asp Leu Ile Glu Tyr Ser
535 540 545 550
atg gcc gct gat cgt ggg aac gag cat gtt tcc tac ctg tat cag cca 1972
Met Ala Ala Asp Arg Gly Asn Glu His Val Ser Tyr Leu Tyr Gln Pro
555 560 565
tac aac cca tcc atc ctt cgc cta atc aag cac gtg att gat tcg gca 2020
Tyr Asn Pro Ser Ile Leu Arg Leu Ile Lys His Val Ile Asp Ser Ala
570 575 580
cat aag gaa ggc aag tgg gcc ggt atg tgt ggc gaa gct gct ggt gat 2068
His Lys Glu Gly Lys Trp Ala Gly Met Cys Gly Glu Ala Ala Gly Asp
585 590 595
cca act atg gta cca ctg ttg ctt ggt atg ggt ctt gac gaa tac tca 2116
Pro Ile Met Val Pro Leu Leu Gly Met Gly Leu Asp Glu Tyr Ser
600 605 610
atg tcc gca act tct gtc ctt aaa gta cgc agc ttg atq aag aag ctt 2164
Met Ser Ala Thr Ser Val Leu Lys Val Arg Ser Leu Met Lys Lys Leu
615 620 625 630
tcg aca gct gat atg gct aag atg gac gaa att gct ttg aac caa at 2212
Ser Thr Ala Asp Met Ala Lys Met Asp Glu Ile Ala Leu Asn Gln Asn
635 640 645
atc act aat gat gaa aac gct gat ctg gtt aag aaa aca act ggt cag 2260
Ile Thr Asn Asp Glu Asn Ala Asp Leu Val Lys Lys Thr Thr Gly Gln
650 655 660
aaa taaactttca ttatcagaa gagtctattg actgaataag ttgacggctt 2313
Lys
ctttttttga ccaaaatttg attttgtcgt tgctcgctag cattgatttt tctgaaaccc 2373
gctcgaaaat gggaaccttat ctttgccatg caaaaaagtg attgcgcgac tatttgctgg 2433
catctgaaca gtgactgact gcagactttt cagaaaaagt ttaaggttat tatgttaaac 2493
aaaaatttag ttactgattc atggtatggc actgtgacgc gtgttctatt tggaacttga 2553
gggggaattg catgtatcaa tcaaaacac acaaatcatcg atttaccggt cacctttgcga 2613
gtgcaagaac acggttgccg ctatgtagcat tgatttcac acgtggtggc ctgcttttttg 2673
gctatgacac tggggtgatc aatggccat gcctcttttat tccttccgaa ctgaaacttg 2733
cccctggatc acagggttgg gtcacccgta gcctgacgct gggtgctgct tttggtgcta 2793
tcttagtcgg tcgtttaagt gatcgctatg ggccgaggcg gctcatcacc atgttagcgg 2853
gctttatttt tcttgccaaacg gtacgctgtg cactttcccc gatgtgctggc tggtctgattg 2913
gogcaacggt gatccttgga ttacgctgtg gccggtcttc tgtgtctgtt ccaagcttttt 2973
tagcagagat tgccccaac agtcatctg ggcggttagt cacacaaat gagctgtatgg 3033
tcgtgactgg ccagtacttt gcttttgctc tcaatgcctt tttaggaacc acttttgta 3093
acgttctcggt tatcttgccg tggatgttg tatttgcaagt cattccggca attatatctag 3153
gtatcgggac ttattttgtt ccggaatctc ctccgttggtt aatgtgaaaa ggacggccgg 3213
cagcagcacg ttcaagtttg gaagtgtgac gatctgctgc tgaagtgcaca gcagagattg 3273
accatttgaa acagaatctt gccgaagatg ctaaacataaa gcagggcaggt gttcgagcat 3333
tgaaaaccaa atggattcgc cgactgggtc tgatttgccat cggccctaggc gtcattcagc 3393
aaattgctgg tatcaatgtc atgatgtatt atggcacctc aattttacaa atgacggttt 3453
ttgggcgagaa tagccgcttg atcgccaaca ttgccaatgg ggttactgccc gttgctgcaa 3513
cgattgtgac gtgcaaatg ttgaagcatg ttccgcggcg gccaatgctg atttgtggaat 3573
tgatttgcttc aaccgtggcg attactgttg tcaccttcgc tagtgcacta ccagcgggtt 3633
cgccatctcc ggcatttgccg acaattcggga tgatgtgctc gtctcttgccg ttcttccaag 3693
gogctatcag tccaatgtact tggtctgctga tgtctgaaat ctccctcga caggttcggg 3753
gcataagggg gggcgtgcga acctttctgtc tgtgttgtae taactttggt gtggcgttcc 3813
tgttcccgat tggtcttgccc caaatagcga tgttttgac attcgtttgc ttcatcggga 3873
caaatttgat ttcatttgctt ttgctttcga ttttttgtcc ggaaacggct ggacgctccc 3933
tcgaaacattt gcacccgagag gagaagcccc gctttaaatca ttaatgacaa gcgatttgtt 3993
caagacaaaa aagtttgctt ttcaaaaaag ttgtatcca taaaggtgta tcaacaattc 4053
gatgaacctt cacaaagggg agccatttgcc tgagaaacggg gaaacccgga cccttcgaac 4113
ctgttcgtta atgcgagcgt agggattttgt gaatgt 4150
<210> 2
<211> 88
<212> PRT
<213> Lactobacillus casei
<400> 2
Met Glu Lys Arg Glu Phe Asn Ile Ile Ala Glu Thr Gly Ile His Ala
1 5 10 15
Arg Pro Ala Thr Leu Leu Val Gln Ala Ala Ser Lys Phe Asn Ser Asp
20 25 30
Ile Asn Leu Glu Tyr Lys Gly Lys Ser Val Asn Leu Lys Ser Ile Met
35 40 45
Gly Val Met Ser Leu Gly Val Gly Gln Gly Ala Asp Val Thr Ile Ser
50 55 60
Ala Glu Gly Ala Asp Glu Ala Asp Ala Ile Ala Ala Ile Thr Asp Thr
65 70 75 80
Met Lys Lys Glu Gly Leu Ala Glu
85
<210> 3
<211> 575
<212> PRT
<213> Lactobacillus casei
<400> 3
Met Ala Glu His Leu Lys Gly Ile Ala Ala Ser Asp Gly Ile Ala Thr
1 5 10 15
Ala Lys Ala Tyr Leu Leu Val Gln Pro Asp Leu Ser Phe Gln Lys Lys
20 25 30
Thr Val Asp Asp Pro Ser Lys Glu Ile Asp Arg Leu Lys Gln Ser Leu
35 40 45
Asp Gln Ser Asn Asp Glu Leu Lys Val Ile Arg Ala Lys Ala Ala Glu
50 55 60
Ser Leu Gly Glu Glu Ala Gln Val Phe Asp Ala His Met Met Ile
65 70 75 80
Leu Ala Asp Pro Asp Phe Thr Gly Gln Val Glu Thr Lys Ile Lys Asp
85 90 95
Glu Lys Val Asn Ala Glu Gln Ala Leu Lys Glu Val Ser Glu Phe Phe
100 105 110
Ile Lys Thr Phe Glu Gly Met Thr Asp Asn Pro Tyr Met Gln Glu Arg
115 120 125
Ala Ala Asp Val Arg Asp Val Thr Lys Arg Ile Met Ala His Leu Leu
130 135 140
Gly Arg Asn Leu Pro Asn Pro Ala Leu Ile Asp Glu Glu Val Val Val
145 150 155 160
Val Ala His Asp Leu Thr Pro Ser Asp Thr Ala Gln Leu Asn Lys Lys
165 170 175
Tyr Val Lys Ala Phe Val Thr Asp Ile Gly Gly Arg Thr Ala His Ser
| | Sequence |
|---|----------|
| 5 | Ala Ile Met Ala Arg Ser Leu Glu Ile Pro Ala Val Val Gly Thr Asp |
| 10 | Asp Ile Thr Lys Lys Ala Asn Asn Gly Asp Leu Ile Ser Val Asp Gly |
| 15 | Leu Thr Gly Glu Val Val Val Asp Pro Thr Asp Asp Glu Val Ala Lys |
| 20 | Phe Lys Gln Asp Ala Glu Ala Phe Ala Lys Gln Lys Ala Glu Trp Ala |
| 25 | Leu Leu Lys Thr Ala Lys Ser Ile Thr Ala Asp Gly Lys His Phe Asp |
| 30 | Val Ala Ala Asn Ile Gly Thr Pro Lys Asp Leu Asp Gly Val Leu Ala |
| 35 | Asn Gly Ala Glu Gly Ile Gly Leu Tyr Arg Thr Glu Phe Leu Tyr Met |
| 40 | Asp Ser Ala Glu Leu Pro Thr Glu Asp Asp Gln Phe Glu Ala Tyr Lys |
| 45 | Lys Val Val Glu Thr Met Ser Pro Lys Pro Val Val Val Arg Thr Met |
| 50 | Asp Ile Gly Gly Asp Lys His Leu Pro Tyr Leu Pro Leu Pro Glu Glu |
| 55 | Gln Asn Pro Phe Leu Gly Tyr Arg Ala Ile Arg Ile Ser Leu Asp Arg |
Continued on next page...
Glu Ile Pro Ala Ala Ala Val Leu Ala Asp Gln Phe Ala Lys Tyr Val
435 440 445
Asp Phe Phe Ser Ile Gly Thr Asn Asp Leu Ile Gln Tyr Ser Met Ala
450 455 460
Ala Asp Arg Gly Asn Glu His Val Ser Tyr Leu Tyr Gln Pro Tyr Asn
465 470 475 480
Pro Ser Ile Leu Arg Leu Ile Lys His Val Ile Asp Ser Ala His Lys
485 490 495
Glu Gly Lys Trp Ala Gly Met Cys Gly Glu Ala Ala Gly Asp Pro Ile
500 505 510
Met Val Pro Leu Leu Leu Gly Met Gly Leu Asp Glu Tyr Ser Met Ser
515 520 525
Ala Thr Ser Val Leu Lys Val Arg Ser Leu Met Lys Lys Leu Ser Thr
530 535 540
Ala Asp Met Ala Lys Met Asp Glu Ile Ala Leu Asn Gln Asn Ile Thr
545 550 555 560
Asn Asp Glu Asn Ala Asp Leu Val Lys Lys Thr Thr Gly Gln Lys
565 570 575
<210> 4
<211> 21
<212> DNA
<213> Lactobacillus casei
<220>
<221> misc_feature
<222> (9)..(9)
<223> r is a or g
<220>
<221> misc_feature
<222> (12)..(12)
<223> n is a, c, g, or t
<220>
<221> misc_feature
<222> (15)..(15)
<223> r is a or g
<220>
<221> misc_feature
<220>
<221> misc_feature
<222> (21)..(21)
<223> y is c or t
<400> 4
atgaaaaarc gngarttyaa y
<210> 5
<211> 7
<212> PRT
<213> Lactobacillus casei
<400> 5
Met Glu Lys Arg Glu Phe Asn
1 5
<210> 6
<211> 26
<212> DNA
<213> Lactobacillus casei
<220>
<221> misc_feature
<222> (6)..(6)
<223> n is a, c, g, or t
<220>
<221> misc_feature
<222> (9)..(9)
<223> r is a or g
<220>
<221> misc_feature
<222> (12)..(12)
<223> y is c or t
<220>
<221> misc_feature
<222> (15)..(15)
<223> r is a or g
<220>
<221> misc_feature
<222> (18)..(18)
<223> y is c or t
<220>
<221> misc_feature
<222> (20)..(21)
<223> r is a or g
<220>
<221> misc_feature
<222> (24)..(24)
<223> r is a or g
<400> 6
gccatngtrt aytgratyar rtcrtt
<210> 7
<211> 9
<212> PRT
<213> Lactobacillus casei
<400> 7
Asn Asp Leu Ile Gln Tyr Thr Met Ala
1 5
<210> 8
<211> 20
<212> DNA
<213> Lactobacillus casei
<220>
<221> misc_feature
<222> (3)..(3)
<223> r is a or g
<220>
<221> misc_feature
<222> (6)..(6)
<223> n is a, c, g, or t
<220>
<221> misc_feature
<222> (7)..(7)
<223> s is c or g
<220>
<221> misc_feature
<222> (9)..(9)
<223> n is a, c, g, or t
<220>
<221> misc_feature
<222> (12)..(12)
<223> n is a, c, g, or t
<220>
<221> misc_feature
<222> (15)..(15)
<223> r is a or g
<220>
<221> misc_feature
<222> (18)..(18)
<223> n is a, c, g, or t
<400> 8
ccrtcnsang cngratncc
<210> 9
<211> 7
<212> PRT
<213> Lactobacillus casei
<400> 9
Gly Ile Ala Ala Ser Asp Gly
1 5
<210> 10
<211> 31
<212> DNA
<213> Artificial
<220>
<223> Oligonucléotides
<400> 10
aagagcgtta acttgaaggc tatcatgggc g 31
<210> 11
<211> 31
<212> DNA
<213> Artificial
<220>
<223> Oligonucléotides
<400> 11
aagagcgtta acttgaagac tatcatgggc g 31
<210> 12
<211> 30
<212> DNA
<213> Artificial
<220>
<223> Oligonucléotides
<400> 12
aagagcgtta acttgaagga tatcatgggc 30
<210> 13
<211> 31
<212> DNA
<213> Artificial
<220>
<223> Oligonucléotides
<400> 13
aagagcgtta acttgaagtc taccatgggc g 31
<210> 14
<211> 20
<212> DNA
<213> Artificial
<220>
<223> Oligonucléotides
<220>
<221> misc_feature
<222> (3)..(3)
<223> n is a, c, g, or t
<220>
<221> misc_feature
<222> (4)..(4)
<223> r is a or g
<220>
<221> misc_feature
<222> (6)..(6)
<223> n is a, c, g, or t
<220>
<221> misc_feature
<222> (9)..(9)
<223> n is a, c, g, or t
<220>
<221> misc_feature
<222> (12)..(12)
<223> r is a or g
<220>
<221> misc_feature
<222> (15)..(15)
<223> y is c or t
<220>
<221> misc_feature
<222> (18)..(18)
<223> r is a or g
<400> 14
ggnrtnggna aragygarac
<210> 15
<211> 18
<212> DNA
<213> Artificial
<220>
<223> Oligonucléotides
<220>
<221> misc_feature
<222> (1)..(1)
<223> r is a or g
misc_feature
(4)..(4)
r is a or g
misc_feature
(7)..(7)
n is a, c, g, or t
misc_feature
(13)..(13)
n is a, c, g, or t
misc_feature
(16)..(16)
n is a, c, g, or t
15
raarttnccc cancgnc
16
35
DNA
Artificial
Oligonucléotides
misc_feature
(12)..(12)
r is a or g
misc_feature
(13)..(13)
m is a or c
misc_feature
(18)..(18)
n is a, c, g, or t
misc_feature
(21)..(21)
n is a, c, g, or t
misc_feature
(24)..(24)
y is c or t
misc_feature
<220> (27)..(27)
<223> y is c or t
<220>
<221> misc_feature
<222> (28)..(28)
<223> r is a or g
<220>
<221> misc_feature
<222> (30)..(30)
<223> y is c or t
<220>
<221> misc_feature
<222> (32)..(32)
<223> w is a or t
<220>
<221> misc_feature
<222> (33)..(33)
<223> y is c or t
<400> 16
ataaagcttg armtgacngg ntayttyray twyta
<210> 17
<211> 26
<212> DNA
<213> Artificial
<220>
<223> Oligonucléotides
<400> 17
attgaaaaga gctcggatta agtgct
<210> 18
<211> 32
<212> DNA
<213> Artificial
<220>
<223> Oligonucléotide ohprKLC5
<400> 18
cccctcgagg tcgacggtat ggataagctt ga
<210> 19
<211> 33
<212> DNA
<213> Artificial
<220>
<223> Oligonucléotide ohprKLC6
<400> 19
catgacatcg ataatgccct agccacgaat ttc
<210> 20
<211> 22
<212> DNA
<213> Artificial
<220>
<223> Oligonucléotide
<400> 20
gtgggatcca tggcagacag cg
<210> 21
<211> 21
<212> DNA
<213> Artificial
<220>
<223> Oligonucléotide
<400> 21
tacggtacca atgaacctcc a
<210> 22
<211> 601
<212> DNA
<213> Lactobacillus casei
<220>
<221> CDS
<222> (273)..(536)
<220>
<221> CDS
<222> (539)..(601)
<400> 22
gtgacgccaag aaacgttcat ggcgtttcgc gcggcatgga cgaatttatcc tgatcgtgaa
gagatcgttg gaatgctaa acgtgatggt gtcattgaat accattatcg atcagttgtat
tctcgttaat ataggcgcca aatctgtatg ggcgcttgtg acaagcttca aaaaatggtaa
aggtttacat gaattgtttt gggtacgaat gcgcacacaa actattcggta aaaaaacttag
aatctagtt aatacgaagg agcagatcag tc atg gaa aaa cgc gaa ttt aat
Met Glu Lys Arg Glu Phe Asn
Ile Ile Ala Glu Thr Gly Ile His Ala Arg Pro Ala Thr Leu Leu Val
cag gca gca agc aag ttc aac tca gat atc aac ttg gaa tac aag ggt
Gln Ala Ala Ser Lys Phe Asn Ser Asp Ile Asn Glu Tyr Lys Gly
aag agc gtt aac ttg aag tct atc atg ggc gtc atg agt ttg ggt gtt 437
Lys Ser Val Asn Leu Lys Ser Ile Met Gly Val Met Ser Leu Gly Val
40 45 50 55
ggc caa ggt gcc gat gtt acc att tct gct qaa ggt gca gac gag gct 485
Gly Gln Gly Ala Asp Val Thr Ile Ser Ala Glu Gly Ala Asp Glu Ala
60 65 70
gat gct atc gct gct att aca gac aca atg aaa aag gaa ggc ttg gct 533
Asp Ala Ile Ala Ala Ile Thr Asp Thr Met Lys Lys Glu Gly Leu Ala
75 80 85
gaa ta atg gct gaa cat ttg aag gga atc gct gct agt gat ggg atc 580
Glu Met Ala Glu His Leu Lys Gly Ile Ala Ala Ser Asp Gly Ile
90 95 100
gcc aca gcc aag gcc tat tta 601
Ala Thr Ala Lys Ala Tyr Leu
105
<210> 23
<211> 109
<212> PRT
<213> Lactobacillus casei
<400> 23
Met Glu Lys Arg Glu Phe Asn Ile Ile Ala Glu Thr Gly Ile His Ala
1 5 10 15
Arg Pro Ala Thr Leu Leu Val Gln Ala Ala Ser Lys Phe Asn Ser Asp
20 25 30
Ile Asn Leu Glu Tyr Lys Gly Lys Ser Val Asn Leu Lys Ser Ile Met
35 40 45
Gly Val Met Ser Leu Gly Val Gly Gln Gly Ala Asp Val Thr Ile Ser
50 55 60
Ala Glu Gly Ala Asp Glu Ala Asp Ala Ile Ala Ala Ile Thr Asp Thr
65 70 75 80
Met Lys Lys Glu Gly Leu Ala Glu Met Ala Glu His Leu Lys Gly Ile
85 90 95
Ala Ala Ser Asp Gly Ile Ala Thr Ala Lys Ala Tyr Leu
100 105
Claims
1. Use of a mutant of *L. casei* having at least a mutation in the *ptsH* gene, wherein said mutation impairs the regulation of a carbon catabolite repression (CCR) mechanism involving the PTS protein HP, for the preparation of a food
2. The use of claim 1, wherein said mutant has at least a mutation selected in the group consisting of:
- any mutation in the *ptsH* gene impairing the ability of HPr to be phosphorylated at His-15, or to phosphorylate EIIA; and
- any mutation in the *ptsH* gene, impairing the ability of HPr to be phosphorylated at Ser-46.
3. The use of claim 1 or claim 2, wherein said mutant is selected in the group consisting of mutants in the *ptsH* gene having at least a mutation resulting in the expression of a HPr having at least one amino-acid substitution at position 15 and/or at position 46 and/or at position 47 of wild-type HPr, and/or at least a mutation resulting in the expression of a HPr deleted of at least one of amino-acids 15, 46, and/or 47 of wild-type HPr.
4. A mutant of *L. casei* having at least one mutation in at least the *ptsH* gene, wherein said mutation impairs at least one of the functions of the product of said gene.
5. A food-grade mutant of *L. casei*, having at least one mutation in the *ptsH* gene, wherein said mutation impairs at least one of the functions of the product of said gene.
6. A method for obtaining a food-grade mutant of claim 5, wherein said method comprises:
- transforming *L. casei* with an integrative vector comprising a mutated *ptsH* gene, wherein said mutation impairs at least one of the functions of the product of said gene, and further comprising a selective marker gene;
- culturing the bacteria under selective conditions for the marker gene in order to obtain the bacteria having integrated the plasmid into their chromosome by a single recombination event;
- culturing said bacteria under non-selective conditions for the marker gene in order to obtain bacteria having undergone a double recombination event leading to the excision of the vector sequences.
7. A method for obtaining a food-grade mutant of *L. casei* in which the catalytic function of HPr is only slightly impaired, wherein said method comprises:
- providing a mutant strain of *L. casei* in which the *ptsI* gene is inactivated in such a way that the function of EI is totally impaired;
- transforming said mutant strain with an integrative vector comprising a *ptsHI* operon consisting of a wild type *ptsI* gene and the mutant *ptsH* gene, and further comprising a selective marker gene;
- culturing the bacteria on lactose under selective conditions for the marker gene, and recovering the bacteria having integrated the vector into their chromosome by a single recombination event;
- culturing the selected bacteria on lactose and under non-selective conditions for the marker gene in order to obtain bacteria having undergone a double recombination event leading to the excision of the vector sequences.
8. A process for preparing a food product or food additive wherein said process comprises fermenting a food substrate with a mutant of *L. casei*, as defined in any of claims 1 to 5.
9. A process of claim 8, wherein said food product is a dairy product.
10. A process of any of claims 8 or 9, for preparing a food product enriched with aroma compounds, comprising fermenting a food substrate with a strain of *L. casei* having a mutation impairing the function of CcpA.
11. A fermented food product comprising at least a mutant of *L. casei*, as defined in any of claims 1 to 5.
1st recombination
1. \[ \text{H} \quad E \quad E \quad \text{erm} \quad H \quad E \quad \text{Lac -} \]
2. \[ \text{H} \quad E \quad E \quad \text{erm} \quad H \quad E \quad \text{Lac -} \]
3. \[ \text{H} \quad E \quad \text{erm} \quad H \quad E \quad \text{Lac +/-} \]
2nd recombination
3a. \[ \text{Lac -} \]
3b. \[ \text{wt Lac +} \]
3c. \[ \text{Lac +} \]
Figure 2
Figure 3
OD550nm
t (hours)
Figure 4
N-acetylglucosaminidase
| | glucose | ribose |
|-------|---------|--------|
| wt | | |
| S46A | | |
| S46T | | |
| I47T | | |
| CCPA | | |
nmol/min mg dw
Figure 5A
nmol/mg dry weight
t (min)
Figure 5B
t (sec)
Figure 5
nmol/mg dry weight
Figure 5C
Figure 5D
Figure 5 (cont.)
Figure 5E
Figure 5F
Figure 5 (cont.)
Figure 6
Figure 6A
Figure 6B
FIGURE 7
Time (days)
REFERENCES CITED IN THE DESCRIPTION
This list of references cited by the applicant is for the reader's convenience only. It does not form part of the European patent document. Even though great care has been taken in compiling the references, errors or omissions cannot be excluded and the EPO disclaims all liability in this regard.
Patent documents cited in the description
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|
NEWS YOU NEED TO KNOW
- Open House – Bring-A-Friend-Day – May 31
CALENDAR OF UPCOMING EVENTS
May 31 Open House - Bring-A-Friend Day – Brian Stoops
June 7 CCSC Board Meeting – 9:30 AM
June 11-22 Contests: 126 & Region 6 South – Rolf Hegele
June 14 SSD Board Meeting – 9:30 AM
July 5 CCSC Board Meeting – 9:30 AM
July 6-12 Youth Camp- Steve McManus
July 12 SSD Board Meeting – 9:30 AM
Aug 11-15 Adult Camp- Dan Reagan
Aug 30-Sep 1 Labor Day Event
Nov 11 Annual meeting and election
BRING-A-FRIEND DAY - OPEN HOUSE, MAY 31
Because our first attempt to hold an Open House was rained out, another attempt will be made on Saturday May 31, 2014. Bring your friends out! A flier was emailed to each member by John Lubon. You are encouraged to use that flier to invite people. (Normal fees will apply.)
Grillmaster Brian Stoops
Grillmaster Gary Adams
TREE TRIMMING COMPLETED, NOW THE BONFIRE!
The work pruning trees in the campground area is now finished. A good amount of branches need to be hauled to the west end of the runway. When we get the tractor back we will move the bigger logs. Anybody willing to help can contact Bob Miller at 937-776-4508 or just come and use the Kabota and the black trailer in the red barn. The hope is to finish removing the brush before the open house this weekend, so your help is needed.
WEDNESDAY– 5/21
It was cloudy all day, but Bob Root still inspired four flights for currency and training.
MEMORIAL DAY FUN FLY, MAY 23-26
The weather was great for soaring on Friday, so seven members took advantage. A 500 kilometer (310 mile) flight was attempted by Tony Bonser, Joe Simmers, John Lubon, Jim Marks and Dan Reagan. Tony was trying to complete his diamond badge. The group made it to Pike County Airport and headed for Belfontaine, but the lift weakened and no one attempted crossing north of Dayton airspace to New Castle, IN. It was a good flight and, although there were not any 500K distances, everyone made it home.
Saturday the group headed out again. While Tony, John, Joe and Jim made the triangle attempted the previous day, Dan Reagan set off to the north to the shore line of Lake Erie. He made his turn for home over Zeigler Landing and returned to CCSC after a total of 7 hours. The official flight data posted to OLC show that not-only did Tony Bonser achieve his goal, flying 535 km at an average speed of 70 km/hr, but also John Lubon, Joe Simmers and Dan Reagan did as well, with distances/speeds of 657/93, 568/88 and 539/77 respectively. Jim Marks flew 461 km and his higher speed of 81 km/hr put him ahead of Dan in OLC points. Poul Pedersen and Dieter Schmidt also had long flights of over 300 km at average speeds over 70 km/hr. Way to go guys!
Saturday was also a great day for our Fun Fly. There were 33 member flights and 6 guest rides. Sunday the excellent flying weather continued and there were 26 flights, including 2 guest rides. One new student pilot joined the club, taking two instructional flights. Thanks to Dieter Schmidt and Rich Perry who stepped in to pilot our tow planes and to Bill Gabbard for providing instruction to our new member. The one-hour limit was waived for crew members as thanks for their faithful service. Upon landing pilots and passengers were
rewarded with over-cooked hot dogs and hamburgers.
Overall, it was a great weekend at one of the best spots in Ohio.
Guest Jason Beck with Joe Jackson
Guest Kim Beck with Brian Stoops
Richard Ziplinger enjoyed his birthday gift ride with Brian Stoops
John Murray, Casey Hildenbrand and Larry Kirkbride tend to the trim adjustment and indicator cable in CC
Rolf Hegele with ASW20 after thwarted 500K attempt
As for the Fun Fly contest… the problem was the weather. Both Saturday and Sunday were a MAJOR BUST! Yep, the weather just was terrible and that accounted for four 500km flights and one long legged soloist, Dan Reagan, getting to Lake Erie…and back. The thermal activity was so good that nobody wanted to try the Inner-Course and since nobody was landing, there were no spot landing attempts recorded. (That does not mean they weren’t attempted, just not recorded.) Steve Statkus himself confesses to being one of those pilots who could not resist the urge to circle until motion sickness set in and on both of his attempts at the Inner-Course he caved in to the temptation to get to cloud base, whilst showing the whole county his under-wing message.
Two pilots attempted the course, Bob Anderson in the Red Wing’s 1-26 and Richard Ceder with Rich Carraway in a 2-33. Bob made four turn points and documented them via cell phone as required. His time was estimated to be 30 minutes. The two Richards were actually conducting a flight review but managed to make two turn points in an estimated (12 minutes). No photo documentation but both of these guys are “stand up” types so we’ll take their word for it. Bob’s track was from release to Stolies, the dam, Cubby’s, Stolies and back to CCSC for a distance of 18.1 miles and an average speed of 36.2 mph. Richards’ route was release, the dam and Cubby’s for a total distance of 6.8 miles and an average speed of 34 mph. In summery, Bob Anderson wins the 23/1 challenge for 2014 and Richard Cedar comes in second.
Monday John and Laura Lubon moved brush from the campground and Larry Kirkbride was on standby to tow. John took a break from brush removal to fly twice with Mark Schababerly.
FRIENDLY REMINDER
Please fill out flight your flight cards completely. Several have recently been turned in with missing the aircraft, altitude, date, etc. Noelle tries to avoid overcharging anyone, but you will be charged for the most expensive aircraft if you fail to indicate which one.
CCSC MEMBERS INVITED TO CONTEST ACTIVITIES – RSVP REQUIRED
This year we are having catered meals for the contest personnel which will be served in the Towplane Hanger. The schedule and menu as currently planned:
- Friday, June 13 – 1-26 Championships Practice Day 2 - Mexican ($15) - Fix your own Chicken and Barbacoa Tacos and Bowls, Rice, Beans, Salsa, Chips, Taco Shells, Flour Tortillas.
- Sunday, June 14 – 1-26 Championships Contest Day 2; Region 6 South Practice Day - Hog Roast ($15) - Hickory Smoked Hog and Shredded Smoked Turkey, Au Gratin Potatoes, Herbed Green Beans, Desert - Entertainment: Soggy Runway Boys.
- Tuesday, June 16 – 1-26 Championships Contest Day 4, Region 6 South Contest Day 2 - Chicken Fettuccini Alfredo, Spaghetti and Meatballs, Vegetarian Lasagna, Salad and Bread, Desert ($15).
- Thursday, June 18 – 1-26 Championships Contest Day 6, Region 6 South Contest Day 4 - Fried Chicken, Mashed Potatoes, Corn, Desert ($15).
- Saturday, June 20 – 1-26 Championships Contest Day 8, Region 6 South Contest Day 6 – Pizza, all you can eat ($10) – Region 6 South Awards.
- Sunday – 1-26 Championships Awards Breakfast - Biscuits and Sausage Gravy, Sausage Links, Donuts, Muffins, Danish, Denver Egg Bake, Fresh Fruit Salad, coffee, water, and juices.
All club members are invited to attend any of the events, however, we do need a RSVP in order to make sure we have the right amount of food ordered. Please RSVP your plans to Rolf at firstname.lastname@example.org.
CCSC TRUSTEE BOARD MINUTES
Available on website. The password is printed on your monthly bill.
CCSC IS ON FACEBOOK
https://www.facebook.com/CaesarCreekSoaringClub. Help promote our sport and our club by uploading your favorite photographs, videos and stories.
EVENT WITH LOUISVILLE SOARING CLUB & CENTRAL INDIANA SOARING SOCIETY
CCSC has received an invitation from members of the Louisville Soaring Club to join with them and members of the Central Indiana Soaring Society for fun weekend. The proposal is 4th of July weekend at the Madison, IN airport (KIMS) because that is also the weekend Madison hosts the Regatta of jet boat races on the Ohio River. More details are available. Be thinking about whether you would like to participate.
FOR SALE
2009 SparrowHawk, Dittel Radio with External Antenna, Ideal Trailer custom built by MM Fabrication, ballistic parachute, wing and tail dollies, Price: $45,000. Contact: Dave, 859-356-0501, email@example.com or Charlie, 937-435-9229, 937-626-2000, firstname.lastname@example.org
LAK 12 glider and trailer. 50/1. It's big. Price negotiable. Located on the field. Interested parties should contact Wally Detert, 937-667-6950 or John Biernacki.
"6V" ASW 15. Cambridge 302 Vario and moving map Flight Computer. Dittal radio. 1/3 share is For Sale. Contact Chuck Lohre 513-260-9025, email@example.com
CCSC GROUND CREWS:
1ST SATURDAY
CC: Steve Fenstermaker (cell: 937-581-7713), ACC: Tow Pilots: John Armor, Mark Schababerle, Richard Perry, Instructor: Paul McClaskey, Bill Gabbard, Tom McDonald. Crew: Waseem Jamali, Courtney Schulker, Gerry Daugherty, Kevin Price, John Raines.
1ST SUNDAY
CC: Mike Karaker (cell: 937-830-0627), ACC: Mark Miller, Tow Pilots: Manfred Mauer, Norb Mauer, Dieter Schmidt, Andy Swanson, Bob Miller. Instructor, Bob Miller, Rich Carraway. Crew: Don Burns, Dave Rawson, Stephen Kleine, Joe Zeis, Chad Runyon, Jack Runyon, Jacob Moore, David Evans.
2ND SATURDAY
CC:Bob Root (cell: 513-630-8761), ACC: Dan Staarmann. Tow Pilots: Bob Anderson, Haskell Simpkins©. Instructor: Chris Giacomo, Bob Anderson, Jim Price. Crew: John Antrim, John Biernacki, Pat DeNaples©, Dick Holzwarth, Jim Hurst ©, Jim Marks, Jim Grueninger.
2ND SUNDAY
CC: Dave Menchen (cell: 513-313-2315), ACC: Lucy McKosky, Tow Pilots: Tom Rudolf, Lorrie Penner, Gordon Penner, Jim Goebel Instructor: Gordon Penner, Jim Goebel, Tom Rudolf, Crew: Alyssa Engeseth, Mike McKosky, Katie Menchen, Tom Geygan, Fred Hawk, Dave Conrad.
3RD SATURDAY
CC:Maury Drummey (cell: 513-543-1906), ACC:Rolf Hegele, Tow Pilots: Don Green, Steve McManus. Dick Scheper. Instructor: Dick Eslinger, Charlie DeBerry, Kat McManus. Crew: Gary Adams, Eric Cochran, Jeff Crawford, Jim Dudley, John Dudley, Norm Leet, Poul Pederson, Charlie Richardson, Brian Stoops©, Chris Uhl ©, Chad Daughters, Chandler Demler, Jake Click, Micah Ferguson.
3RD SUNDAY
CC: Tom Bonser (cell: 513-673-7746), ACC:. Tow Pilots: Tony Bonser©, Tim Christman, Mike Hutchison, Richard Perry. Instructor: Dick Eckels, Bill Miley, Chad Ryther, Bill Gabbard.
Crew: Marcos Aranha, Jack Morari, Eran Moscona, Paul Schuette, Glen McDonald, Mary Towers.
4TH SATURDAY:
CC: Chuck Lohre (cell: 513-260-9025). ACC: Ethan Saladin. Tow Pilots: John Atkins©, Guy Byars, Bernie Fullenkamp©. Instructor: John Atkins, Joe Jackson, Larry Kirkbride. Crew: Henry Meyerrose, Tom Bales ©, Ross Bales, John Murray ©, Casey Hildenbrand.
4TH SUNDAY
CC: Steve Statkus (cell: 513-720-8955), ACC: Todd Dockum. Tow Pilots: Matt Davis, Frank Paynter, Ron Blume, Tim Morris. Instructor: Lynn Alexander, Frank Paynter, John Lubon. Crew; Richard Cedar, Barry Clark©, Pat DeNaples©, Tyler Dockum, Rik Ghai, Scott Mayer, Dan Reagan, Pete Schradin, Adam Wilson, Josh Young, Shelby Estell, Philip Carl, Kaitlin Gossett, David Meyer, Chandler Beckwith, Kindall Sanders.
2014 ADDITIONAL CREW DAYS:
March 29 – 2nd Sat Crew
March 30 – 2nd Sun Crew
May 31 – 3rd Sat Crew
June 29 – 3rd Sun Crew
Aug 30 – 4th Sat Crew
Aug 31 – 4th Sun Crew
Nov. 29 – 1st Sat Crew
Nov 30 – 1st Sun Crew
POINTS OF CONTACT:
CCSC PRES: Frank Paynter, cell: 614-638-6749
CHIEF TOW PILOT: Tim Christman, hm: 937-475-1445
SAFETY OFFICER: Paul McClaskey, hm: 614-245-8129
DIR OF OPS: Brian Stoops, 937-203-6997 (c)
DIR OF FACILITIES: Bob Miller, 937-882-6012
TOW PLANE MAINT: Tim Christman, hm 937-475-1445
GLIDER MAINT: Steve Statkus, 513-576-9080
SSD PRES: John Lubon, hm: 513-870-0994
BUSINESS MANAGER: Noelle Stewart, cell: 808-286-2373, firstname.lastname@example.org
FREQUENT FLYER EDITOR: Jim Dudley
|
The Value of Real-Time Visibility and Predictive Intelligence for Supply Chains
An IDC InfoBrief, sponsored by TransVoyant | October 2016
Big data analytics value proposition for supply chains
Real-Time Visibility Enabled by Big Data and IoT
Ability to see the real-time movement of shipments and orders anywhere on the globe from foreign supplier to customer door, end-to-end across all modes.
Predictive Intelligence Enabled by Analytics
Ability to predict and avoid supply chain disruptions from external events such as weather, port congestion, road traffic, natural disasters, human behavior, etc.
Information and the ability to create actionable insight from massive amounts of data has become a key element in competitive differentiation.
IDC Prediction: By 2020, organizations able to analyze all relevant data and deliver actionable information will achieve an extra $430 billion in productivity benefits over their less analytically oriented peers.
Innovative technologies enable real-time visibility and deliver predictive intelligence
**Traditional SCV (EDI)**
- **REACTIVE**
- Inbound/Outbound Shipments
- Latent EDI status updates tell BCOs where their shipments were hours / days ago.
**Real-Time Visibility (Big Data and IoT)**
- **LIVE**
- Inbound/Outbound Shipments
- Real-time big data tells BCOs where their shipments are right now.
**Predictive Intelligence (Analytics)**
- **PREDICTIVE**
- Inbound/Outbound Shipments
- Predictive analytics tell BCOs where their shipments are going to be in the future and identify future disruptions so they can be avoided.
Conveyance / Journey → Assumed / Known / Predicted Location of Goods □
Actual Location of Goods ●
Disruption !
Supply chains must look beyond traditional EDI based visibility towards real-time actionable insight and predictive analytics.
EDI for in-transit shipment tracking is ok, but for true real-time visibility supply chains must move beyond EDI and leverage the tremendous value of the Internet of Things (IoT).
- Ocean Freight EDI often has days of latency between transmissions
- Road Freight EDI has hours of latency
- Air Freight is transmitting on departure and arrival, but not real-time in-transit
- In addition to latency, EDI does not capture true behavior and can miss unscheduled route changes
The proliferation of IoT devices across supply chains has created the opportunity for supply chains to connect, in real time, to multiple sources of the data to obtain a real-time accurate view of assets in motion.
Real-time visibility provides real value in the supply chain such as:
- Improved understanding of actual supply chain behavior and model against real activity
- Reduced transit lead time
- Reduced buffer stock
- Improved supply chain planning
- Enabled use of dynamic routing
- Improved downstream scheduling accuracy
- Improved customer service
- Reduced cost
- Extended definition of “inventory on-hand” to include incoming shipments
The IoT is enabling companies to deliver on the promise of real-time visibility with **real-time analytics** for the supply chain at a reasonable cost!
IoT deployments deliver real supply chain results
Know where shipments are in real time to:
- Rapidly respond to change
- Achieve up to 99% ETA accuracy
- Improve warehouse and labor productivity by 10%-30%
Provide better customer service to:
- Increase customer loyalty
- Reduce customer service costs
- Increase sales
- Improve customer service (OTIF) by up to 2 percentage points
Gain real-time visibility of inventory to:
- Improve inventory utilization
- Reduce buffer stock by as much as 20%
- Leverage inventory in-transit as available
Real-time supply chain visibility can:
- Reduce expedited freight costs between 5% - 50%
- Reduce transit related lead time buffer
- Reduce excess inventory and related costs
% of executives citing performance improvements from IoT across specific business areas
44% Shipment Tracking
42% Inventory Availability
37% Improved Customer Service
32% Overall Supply Chain Visibility
Source: IDC 2016 Supply Chain Survey (N=501)
Real-time visibility into in-transit assets enables retail supply chains to improve
The retail industry has been going through a period of drastic transformation as digitally connected customers increasingly demand a high mix of products available for near immediate fulfillment across a range of fulfillment methods, at times demanding last-minute product and delivery changes, in a transformative and highly competitive environment.
Leveraging IoT and advanced analytics in the logistics function of the retail supply chain enables retailers to adapt to disruption and deliver value such as:
- Improve customer service by quoting accurate ETAs and consistently meeting promised delivery dates
- Allocate inventory in-transit within short product life cycle environments (fast fashion)
- Accurately predict ETA of shipments to improve downstream operations
- Improve cross-docking capabilities
- Deliver on dynamic routing
- Improve overall inventory management
- Drive revenue and sales
- Gain complete supply chain view, including risk, supplier behavior, and external forces impacting their ability to deliver
72% of retail supply chain executives believe IoT is important or very important to how they run the supply chain of the future.
Source: IDC 2016 Supply Chain Survey
Advanced analytics and IoT are driving change and value in the manufacturing supply chain
The manufacturing industry covers a broad base of business, but what they all have in common is the increasing adoption of IoT and advanced analytics across the business. Greater than 68% of manufacturing supply chain executives agree that IoT will be important or very important to how they run the supply chain of the future.
Manufacturing supply chain executives who agree IoT/advanced analytics are integral to driving business improvements across the following areas:
- Increase Agility: 41%
- Improve Business Planning: 53%
- Improve Productivity: 53%
- Increase Visibility/traceability: 53%
- Improve Service Level: 58%
- Reduce Costs: 65%
Shipment tracking and inventory availability are the top two areas where manufacturing supply chains are delivering business value through IoT at 41.2% and 40.3%, respectively.
Source: IDC 2016 Supply Chain Survey
Life sciences is ripe for digital transformation through the application of IoT and advanced analytics
Life sciences supply chains are incredibly complex having to manage robust distribution networks, complex regulatory requirements, product handling and storage, and security challenges among other complexities.
The life sciences industry, especially within the supply chain, is ripe for digital transformation and has the opportunity to deliver tremendous value through the application of IoT and advanced analytics as a lever to provide real-time in-transit visibility and predictive analytics. As life sciences companies leverage these modern technologies they can expect to:
- Improve route planning and transportation asset planning to more efficiently move temperature controlled and non-temperature controlled products
- Significantly improve inventory management
- Enhance traceability throughout the supply chain
- Reduce transportation related costs
- Drive downstream operational efficiencies
The life sciences industry, especially within the supply chain, is ripe for digital transformation.
In addition to value creation, IoT and advanced analytics is a lever for risk avoidance in the supply chain.
Supply chain disruption is frequent, expensive, and avoidable.
- Supply chain disruption has caused 60% OF COMPANIES to experience a 3% or greater increase in total supply chain costs¹
- $56 BILLION value of goods stolen, lost, and damaged globally due to supply chain disruption in 2015
- $7 BILLION the cost to U.S. retailers in 2015 as a result of West Coast Port Delays
3 OUT OF 4 COMPANIES SUFFERED SUPPLY CHAIN DISRUPTION IN 2015
Supply chain exposure to risk can be reduced with real-time visibility and predictive intelligence.
¹ PWC / MIT Report: Making the Right Risk Decisions to Strengthen Operations Performance
IDC supply chain risk and resiliency maturity distribution across stages
40% of companies surveyed are responsive while only 4% of companies are predictive relative to supply chain risk and resiliency.
Top performers are those companies capable of predicting and avoiding supply chain disruptions.
| Stage | Percentage |
|-------------|------------|
| Repeatable | 40% |
| Opportunistic | 29% |
| Ad Hoc | 3% |
| Siloed | |
| Reactive | 25% |
| Proactive | 4% |
| Predictive | |
Siloed: Conflicting, often opposing, ability to effectively assess risk and respond cohesively.
Reactive: Limited ability to assess and identify risks means that disruptions are often a "surprise" resulting in suboptimized responses.
Responsive: Ability to assess risk is improved, but still not comprehensive, resulting in average performance versus competitors.
Proactive: Comprehensive risk assessment and active risk mitigation provides a competitive advantage versus competitors.
Predictive: Best-in-class risk assessment and resiliency allows the business to "win limited available opportunities" when disruption occurs.
Source: IDC's Supply Chain Risk and Resiliency MaturityScape Benchmark Survey, 2016
Predictive intelligence enables supply chains to avoid disruptions rather than respond to them.
Benefits of Predictive Disruption Avoidance:
- Reduction in lost sales revenue
- Reduction in expedited freight
- Improvement in cycle times
- Improvement in customer service
- Reduction in safety stock
- Reduced exposure to disruption
- Enables rapid response
- Reduced lead times
- Optimized transportation routing
- Improved downstream planning and operations
Accurate Real-Time Visibility Enables Predictive Response:
- Leverage big data and advanced analytics to predict when and where disruption may occur
- Select routes predicted to be free of disruption upfront
- Re-route assets in-transit to avoid predicted disruptions that are unfolding in real time
- Re-plan downstream operations to account for predicted late arrival of goods in transit
The IoT will fundamentally alter supply chain management. Is your supply chain ready?
IDC forecasts over 29.5 billion IoT connected end points by 2020. For supply chains, this creates an abundance of data points from which to conduct advanced analytics and gain predictive insights. Companies that effectively utilize advanced analytics on top of IoT data will significantly outperform their peers that do not over the coming years.
44.6% of companies are researching/evaluating, purchasing, and/or upgrading IoT and sensors for supply chain orchestration in 2016.
69.3% of supply chain professionals view the IoT as important or very important to the supply chain of the future.
IoT is not just about the data, it’s about the ability to draw predictive actionable insights through advanced analytics.
Essential guidance for embarking on your IoT and advanced analytics journey
1. While IoT and advanced analytics must be part of the long-term strategy, start small and near term in order to build the business case for a more robust long-term plan.
2. Identify use case-driven quick win opportunities where IoT, big data, and advanced analytics can deliver quantifiable business value.
3. Evaluate purpose-built IoT applications capable of delivering rapid results that have proven use case examples and can help build the case for future investment.
4. Leverage small-scale implementations of technology to prove the business case and help in securing funding and approvals for future strategy and planning.
5. Think of small-scale projects as learning opportunities and the building blocks to working towards evolving the business to meet the needs of tomorrow.
6. Remember, it is not all about the data but rather the ability to draw actionable intelligence out of the data.
|
Cell culture media and reagents
Designed to enable reproducibility and performance for results you can count on every day
Gibco cell culture media—over 60 years of cell culture expertise
Gibco™ media, sera, supplements, cells, and cell culture reagents are designed to deliver reproducibility and performance, for results you can count on.
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Gibco media bottle
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Sustainable solutions
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Gibco media are a reliable solution
Gibco media are the most cited media* in global scientific journals
Our media account for 52% of all global media citations (nearly 442,000 citations and counting)
- Americas: 49.5% (188,890)
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56% of publications in top-tier journals cite the use of Gibco media*
Cell, Nature, Science, New England Journal of Medicine, and BMJ
Gibco media are the most cited media in the research areas* of
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Constant innovation for cutting-edge cell culture, from our research labs to yours
You need a partner dedicated to helping you confidently forge new paths. Our team of skilled R&D scientists and our unwavering investment in innovation make Gibco™ cell culture media the trusted choice of boundary-pushing scientists around the world.
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* According to market research conducted by HDMZ in early 2023 from articles published within the last 10 years.
Cell culture media
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**DMEM**
Gibco™ Dulbecco’s Modified Eagle Medium (DMEM) is a widely used basal medium for supporting the growth of many different mammalian cells. Cells successfully cultured in DMEM include primary fibroblasts, neurons, glial cells, HUVECs, and smooth muscle cells, as well as cell lines such as HEK293, Cos-7, and PC12.
**DMEM/F-12**
Gibco™ Dulbecco’s Modified Eagle Medium: Nutrient Mixture F-12 (DMEM/F-12) is a widely used basal medium for supporting the growth of many different mammalian cells including MDCK cells, glial cells, human fibroblasts, human endothelial cells, and rat fibroblasts.
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Gibco™ Roswell Park Memorial Institute (RPMI) 1640 Medium is unique from other media because it contains the reducing agent glutathione and high concentrations of vitamins, including certain vitamins not found in Eagle’s Minimum Essential Medium (EMEM) or DMEM. Gibco RPMI 1640 Medium is suitable for a variety of mammalian cells, including Jurkat, MCF-7, and PC12 cells, as well as PBMCs, astrocytes, and carcinomas.
**MEM**
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**Serum-free media**
Serum-free media formulations are available for many primary cultures and cell lines, including recombinant protein-producing Chinese hamster ovary (CHO) cell lines, hybridoma cell lines, and cell lines acting as hosts for viral production (e.g., HEK293, Vero, MDCK, MDBK).
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Add or remove components, create customized packaging options, select QC tests, and more. Formulations available for customization include classical basal media, protein expression media, stem cell media, and cell and gene therapy (CGT) media.
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Discover the differences between our key custom media manufacturing services
| Gibco™ rapid prototyping | GMP production |
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| **Batch volumes** | **Batch volumes** |
| 1–200 L liquid medium | 10–10,000 L liquid medium |
| 1–10 kg powder medium | 1–3,500 kg powder medium |
| 1–8 kg Gibco™ Advanced Granulation Technology™ (AGT™) format medium | 50–6,000 kg AGT format medium |
| **Packaging options** | **Packaging options** |
| Standard packaging available | Standard and custom packaging options available |
| **Product testing** | **Product testing** |
| Limited testing available for a fee: | Price includes the following tests: |
| Liquid medium | Powder medium |
| • pH | • pH |
| • Osmolality | • Osmolality |
| • Sterility | • Solubility |
| • Endotoxin | • Endotoxin |
| Results are provided without a CoA. | Additional tests available. Results are provided with a CoA. |
Gibco Media Formulation Tool
We are dedicated to providing quality cell culture media products that meet your research needs. Use the interactive Gibco™ Media Formulation Tool to compare classical basal media side-by-side. First choose your media, then choose specific modifications to find the right match for your experiment.
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Innovative formulations
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**Advanced media**
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**FluoroBrite DMEM**
Gibco™ FluoroBrite™ DMEM is a DMEM-based formulation with 90% lower background fluorescence than that emitted by standard phenol red–free DMEM. With this alternative to phenol red–free media, researchers can visualize even the weakest fluorescent events in an environment that is amenable to cell health. FluoroBrite DMEM is:
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**BenchStable media**
Engineered for flexibility and convenience, Gibco™ BenchStable™ media enable storage at room temperature, thereby saving your lab’s valuable cold storage space. Available in the most used basal media formulations: DMEM, DMEM/F-12, MEM, and RPMI 1640.
- **Stable at room temperature**—No need to refrigerate means the media temperature is just right when you are ready to use it
- **A greener option**—BenchStable media have more sustainable packaging and help reduce energy consumption by promoting the efficient use of cold storage compared to traditional media
Learn more at [thermofisher.com/benchstable](http://thermofisher.com/benchstable)
GlutaMAX Supplement
L-glutamine spontaneously degrades in cell culture media generating ammonia and pyrrolidine carboxylic acid as byproducts. Gibco™ GlutaMAX™ Supplement is a stabilized form of L-glutamine, the dipeptide L-alanyl-L-glutamine, that prevents degradation and ammonia buildup even during long-term culture.
- **Easy to use**—GlutaMAX Supplement is a direct substitute for L-glutamine at equimolar concentrations in your current cell culture media formulation
- **Minimizes toxic ammonia buildup**—Extremely stable in aqueous solution, the dipeptide does not degrade in storage or during incubation
Learn more at [thermofisher.com/glutamax](http://thermofisher.com/glutamax)
GlutaMAX media
We offer many media formulations in which the GlutaMAX dipeptide substitutes for L-glutamine. Options include DMEM, MEM, RPMI, Opti-MEM, and other basal media.
Suitable for both adherent and suspension mammalian cell cultures, including:
- Cultures requiring long periods of incubation without feeding (e.g., cloning assays)
- Cultures used in long-term studies requiring optimum standardization of media (e.g., use of cancer cell lines, long-term cultures passaged over time, toxicity testing)
- Culture systems sensitive to ammonia (e.g., high-density bioreactors)
Learn more at [thermofisher.com/glutamax](http://thermofisher.com/glutamax)
TrypLE reagents
Gibco™ TrypLE™ reagents are highly purified, recombinant cell-dissociation enzymes that replace porcine trypsin. These reagents are ideal for dissociating attachment-dependent cell lines in both serum-containing and serum-free conditions, and can be directly substituted for trypsin without protocol changes.
- **Gentle on cells**—Protect your cells’ surface proteins
- **Stable at room temperature**—No need to freeze means the reagents are ready when you need them
- **Animal origin–free**—Important if you’re looking for a product without animal-derived components
Learn more at [thermofisher.com/tryple](http://thermofisher.com/tryple)
Recovery cell freezing medium
Whenever you are banking precious cells, make sure they are ready to get back to work when you are. Gibco™ Recovery™ Cell Culture Freezing Medium is a complete cryopreservation technology for mammalian cell culture, offering:
- **Improved cell recovery**—Increased viability after thawing from cryostorage
- **Fast results**—More viable cells, so you can start your experiments sooner
- **Ready-to-use freezing mix**—No need to combine multiple products
- **Added safety**—No need to handle and mix DMSO
Learn more at [thermofisher.com/freezingmedia](http://thermofisher.com/freezingmedia)
Designed to enable reproducibility, Gibco cell culture reagents are infused with quality, customer-focused innovation, and service excellence from beginning to end. From the most basic formulations to the newest innovations, Gibco reagents and supplements provide exceptional quality, consistency, and performance—for results you can count on every day.
**Cell dissociation**
Gibco™ dissociation solutions—including Gibco™ Trypsin and TrypLE™ Express solutions—are used widely for tissues and cell monolayers. Available in a wide variety of formats to help meet the diverse needs of researchers performing adherent cell culture.
Learn more at [thermofisher.com/celldissociation](http://thermofisher.com/celldissociation)
**Recombinant proteins**
Whether conducting basic research or developing next-generation cell therapies, you rely on the quality and integrity of the recombinant proteins used in your experiments. Thermo Fisher Scientific offers a large selection of high-quality Invitrogen™ and Gibco™ recombinant proteins, including Gibco™ PeproTech™ proteins, to help meet these needs.
Learn more at [thermofisher.com/recombinantproteins](http://thermofisher.com/recombinantproteins)
**Balanced salt solutions**
Trust Gibco™ balanced salt solutions to provide an isotonic buffer system that keeps your cells in the physiological pH range and helps to maintain viability during short-term incubations. Available in many formulations and formats, both liquid and powder.
Learn more at [thermofisher.com/balancedsalts](http://thermofisher.com/balancedsalts)
**Antibiotics**
Proper supplementation of cell culture media with antibiotics can help protect your cells from contamination. We offer a wide range of antibiotics and antimycotics that help control or eliminate cell culture contamination.
Selection guides are available to choose antibiotics for contamination, or selection and cell line development.
Learn more at [thermofisher.com/antibiotics](http://thermofisher.com/antibiotics)
**Other Gibco cell culture reagents and supplements:**
- 2-Mercaptoethanol
- Amino acid solutions
- Cholesterol supplements
- HAT Supplement
- HEPES buffers
- HT Supplement
- Insulin-Transferrin-Selenium
- L-glutamine
- MEM Vitamin Solution
- Phytohemagglutinin
- Pluronic™ F-68 surfactant
- Sodium Bicarbonate
- Sodium Pyruvate
- Trypan Blue Solution
- Water for Injection (WFI) and cell culture-grade water
Thermo Scientific™, Invitrogen™, and Gibco™ products are optimized and evaluated to enable improved productivity.
Explore our wide selection of cell culture products designed to help you achieve successful research outcomes.
**FBS**
Gibco™ FBS can help provide the cell health, maintenance, and viability critical for optimal performance and cell growth in your culture medium. Discover the differences that Gibco FBS can deliver for your research and production today.
Learn more at [thermofisher.com/fbs](http://thermofisher.com/fbs)
**Transfection**
Our high-quality products for lipid-based transfection and electroporation are useful across a wide variety of cell types and applications. Invitrogen™ Lipofectamine™ products are widely used reagents that provide consistent and highly efficient gene delivery in many cell types. The Invitrogen™ Neon™ NxT Electroporation System is an innovative device able to achieve high efficiency transfection and increased cell viability, even in hard-to-transfect cell types.
Learn more at [thermofisher.com/transfection](http://thermofisher.com/transfection)
**Biological safety cabinets**
Thermo Scientific™ biological safety cabinets (BSCs) use less energy while helping reduce costs. Our BSCs offer the certified performance and protection you can rely on every day.
Learn more at [thermofisher.com/bsc](http://thermofisher.com/bsc)
**Cold storage**
We offer proven cold storage sample protection and preparation solutions for a variety of sample types, from vaccines to cryogenically preserved specimens. Our portfolio ranges from 4°C high-performance lab refrigerators to −196°C cryogenic freezers.
Learn more at [thermofisher.com/coldstorage](http://thermofisher.com/coldstorage)
**Cell culture plastics**
Thermo Scientific™ Nunc™ cell culture plastics offer a solution for every step of your workflow, and are validated with Gibco products across multiple cell lines and applications. Easily find your cell plastics by searching by surface, format, or other application need.
Learn more at [thermofisher.com/cellcultureplastics](http://thermofisher.com/cellcultureplastics)
**Cell counters**
We offer two high-performance automated cell counters designed to meet the needs of a cell culture lab. Invitrogen™ Countess™ 3 and Countess™ 3 FL Automated Cell Counters contain advanced autofocusing and counting algorithms to allow you to quickly and accurately identify and count cells within a population. Applications include cell counting, viability, and transfection efficiency.
Learn more at [thermofisher.com/countess](http://thermofisher.com/countess)
**CO₂ incubators**
Protect your valuable cell cultures with Thermo Scientific™ CO₂ incubators, which afford proven reliability, exceptional contamination prevention, and optimal growing conditions.
Learn more at [thermofisher.com/co2](http://thermofisher.com/co2)
**Liquid handling**
Our portfolio of liquid handling instruments offers quality and performance vital to your research—from a full range of manual and electronic pipetting consumables to automated liquid handlers, reagent dispensers, and pipette tips.
Learn more at [thermofisher.com/liquidhandling](http://thermofisher.com/liquidhandling)
Primary cell culture
Get closer to *in vivo* predictions with Gibco cell culture systems. These systems allow you to closely mimic the *in vivo* state and generate more physiologically relevant data. Each lot of primary cells is performance tested for viability and growth potential.
Learn more at [thermofisher.com/primarycells](http://thermofisher.com/primarycells)
Stem cell culture
An extensive selection of high-quality media products are available for pluripotent stem cells, neural stem cells, mesenchymal stem cells, hematopoietic stem cells, and stem cell therapy applications.
Learn more at [thermofisher.com/stemcellculture](http://thermofisher.com/stemcellculture)
Neuronal cell culture
Gibco™ neuronal and neural cell media are optimized for the growth and support of primary neuronal and neural cell cultures. These media are cited in applications involving primary neurons, glial cells, and disease models.
Learn more at [thermofisher.com/neuralculture](http://thermofisher.com/neuralculture)
Protein expression
Gibco media formulations are available as components of our protein expression systems, supporting the creation of recombinant proteins for further use, including functional and therapeutic studies.
Learn more at [thermofisher.com/proteinexpression](http://thermofisher.com/proteinexpression)
Organoid, spheroid, and 3D cell culture
Gibco media products have been used in a range of organoid, spheroid, and 3D culture studies, allowing for a more physiologically relevant understanding of complex biology compared to 2D cell culture.
Learn more at [thermofisher.com/3dculture](http://thermofisher.com/3dculture)
Cell therapy applications
Gibco™ Cell Therapy Systems™ (CTS™) media products, designed for use in cell therapy applications, are manufactured to GMP standards and undergo extensive testing to help ensure sterility and safety.
Learn more at [thermofisher.com/celltherapysystems](http://thermofisher.com/celltherapysystems)
Cell culture scale-up
From basic formulations to our latest innovations, Gibco cell culture products for bioprocessing provide high quality, consistency, and performance for your scale-up needs.
Learn more at [thermofisher.com/gibcobioprocessing](http://thermofisher.com/gibcobioprocessing)
Cytogenetics
Specially formulated Gibco media are available for use in standard clinical cytogenetic protocols, with products optimized for analysis of amniotic fluid cells, chorionic villus samples, bone marrow cells, or peripheral blood lymphocytes.
Learn more at [thermofisher.com/cytogenetics](http://thermofisher.com/cytogenetics)
Every cell culture requires analysis to check on cell health and growth
Compiling data sets from multiple cell analysis investigations can enable scientists to better understand, predict, and—ultimately—influence the factors that underlie cell health, proliferation, function, and death.
We offer a broad range of cell analysis research solutions, including Invitrogen™ labeling and detection technologies, antibodies, and immunoassays; Invitrogen™ EVOS™ cell imaging systems; and Invitrogen™ Attune™ acoustic focusing flow cytometers.
Find cell analysis solutions at [thermofisher.com/cellanalysis](http://thermofisher.com/cellanalysis)
Gibco Education
Gibco Education connects you with free-to-use materials, webinars, handbooks, virtual reality trainings, expertise, and the hands-on courses you need to help gain confidence in the lab and progress your career.
Whether you’re learning new skills or revisiting familiar techniques, expanding your horizons, or transitioning between disciplines, explore our cross-application resources—from cell culture and transfection basics to protein expression and stem cell innovations.
Learn more at thermofisher.com/gibcoeducation
Gibco virtual learning
Enhance your lab skills with our library of virtual training courses. Explore virtual laboratories and eLearning modules, developed by our technical experts, across a variety of applications.
Browse virtual learning modules at thermofisher.com/gibcovirtuallearning
Gibco cell culture basics
Did you know that understanding cell culture is essential for the life of your work? Ensuring consistently healthy cells can be the critical factor in your experiments producing the outcomes you’re hoping for. Gibco cell culture basics connects you to everything from laboratory setup to safety and aseptic techniques, as well as basic methods for passaging, freezing, and thawing cultured cells, and more.
Explore the Gibco™ cell culture basics virtual lab and test your cell culture knowledge or refresh on best practices.
The Gibco™ cell culture basics handbook is the ideal lab partner. This companion handbook introduces the fundamentals of cell culture, and is designed and organized to help you master cell culture basics and achieve consistent results. Download a copy to keep as a frequent reference guide.
Find these tools and more at thermofisher.com/cellculturebasics
# Cell culture lab checklist
## Cell culture media and reagents
- [ ] Cell types ___________________________
- [ ] Classical media formulations
- [ ] DMEM
- [ ] DMEM/F-12
- [ ] MEM
- [ ] RPMI
- [ ] IMDM
- [ ] Other: ___________________________
- [ ] Innovative media formulations
- [ ] Advanced Media
- [ ] Opti-MEM Reduced Serum Media
- [ ] BenchStable media
- [ ] FluoroBrite DMEM
- [ ] GlutaMAX media
- [ ] Recovery freezing medium
- [ ] Supplements
- [ ] Antibiotics
- [ ] L-glutamine
- [ ] GlutaMAX dipeptide
- [ ] Cell culture buffers
- [ ] Other: ___________________________
- [ ] Reagents
- [ ] Balanced salt solutions
- [ ] Trypsin
- [ ] TrypLE Express Enzymes
- [ ] Other: ___________________________
- [ ] FBS
- [ ] Value: ___________________________
- [ ] Premium: _________________________
- [ ] Specialty: _________________________
- [ ] Extracellular matrices ___________________________
## Cell culture plastics
- [ ] Flasks
- [ ] 25 cm²
- [ ] 75 cm²
- [ ] 175 cm²
- [ ] 225 cm²
- [ ] 500 cm²
- [ ] Vent or filter cap
- [ ] Surface ___________________________
- [ ] Plates
- [ ] 4-well
- [ ] 6-well
- [ ] 12-well
- [ ] 48-well
- [ ] 96-well
- [ ] Surface ___________________________
- [ ] Dishes
- [ ] 35 cm²
- [ ] 60 cm²
- [ ] 90 cm²
- [ ] 100 cm²
- [ ] 150 cm²
- [ ] Surface ___________________________
- [ ] Glass-bottom dishes ___________________________
- [ ] Conical centrifuge tubes
- [ ] 15 mL conical tube
- [ ] 50 mL conical tube
- [ ] 50 mL bioreactor tube
- [ ] 250 mL conical tube
- [ ] 500 mL conical tube
- [ ] Serological pipettes
- [ ] 2 mL
- [ ] 5 mL
- [ ] 10 mL
- [ ] 25 mL
- [ ] Other: ___________________________
- [ ] Chamber slides ___________________________
- [ ] Cell culture inserts ___________________________
## Surface guide
**Thermo Scientific™ Nunclon™ Delta Surface**
A cell culture–treated surface modification that enhances the hydrophilicity of the polystyrene surface of your culture vessel, promoting maximum adhesion for a broad range of cell types.
**Thermo Scientific™ UpCell™ Surface**
Designed for culture passaging, single-cell analyses, and cell transplantation research, the UpCell surface comes with supportive membrane options and enables harvesting of cell sheets and the creation of 3D tissue models.
| Surface | Flasks | Plates | Dishes |
|------------------|--------|--------|--------|
| Nunclon Delta Surface | • | • | • |
| UpCell Surface | | • | • |
| Nontreated | • | • | • |
Learn more at [thermofisher.com/mammaliancellculture](http://thermofisher.com/mammaliancellculture)
|
Texas State University
Public Administration Magazine
2013-2014
Dear Alumni and Friends,
We celebrate our accomplishments and look forward to our future growth.
This spring marked the 40th Anniversary of the Texas State MPA program. Under the leadership of Dr. Howard Balanoff, we celebrated this anniversary and honored our distinguished alumni. The mission of the MPA program has historically been to educate public managers and administrators in Central Texas. And of course this is still a major part of our mission. Today, we now aim to cultivate a cadre of practical, research-oriented public managers and administrators. Administrative leaders are now tasked to be more creative and data driven than ever as they seek out innovative solutions to today’s complex challenges. During this year we will work on two major initiatives that will strengthen public administration at Texas State.
First, the MPA program will expand course offerings on the Round Rock Campus to better serve communities between the Austin and DFW metropolitan areas. No public university offers the MPA between these major population centers. This vacuum creates a great opportunity for our program.
Second, we will work with public sector employers and enlist their support in revising our BPA program curriculum along a co-operative education model. This work will support a general increase in the level of engagement of MPA faculty with the BPA program. Starting fall 2016, the BPA minor will be offered on the Round Rock Campus.
This magazine documents faculty and student scholarship and recognizes some of the many achievements of our faculty, students and alumni over the past year. In 2013-2014 faculty published over 14 articles, three books, and 11 book chapters. We look forward to a productive and successful 2014-2015 Academic Year!
Dr. Tom Longoria, MPA Director
CONTENTS
Program News ........................................... 3
Alumni Updates ................................. 4
MPA Celebrates 40 Years............. 6
CPM Program ................................. 8
International Engagement .... 10
Research Spotlight....................... 11
Faculty Publications .................... 12
ARPs Cited ................................. 14
Program Faculty......................... 15
New Faculty Welcome .............. 15
Internship Information............ 17
Internship Partners .................. 17
Center for Research, Public Policy and Training
The Center for Research, Public Policy, and Training has been active over the last year writing research grant proposals and organizing community engagement events. The Center has been contracted to conduct a national survey of Metropolitan Planning Organizations, in order to examine the impact of the complete streets policies through the Southwest Region University Transportation Center and the University of New Orleans Transportation Institute. In addition to this research, the Center is conducting a community survey for the City of Hutto, and is working with the City of Kyle to evaluate city budgeting.
The Center has also been active in the community through a series of local and national events. The Center co-hosted a legal public policy symposium in June, 2014, with the law firm of Denton, Navarro, Rocha, Bernal, Hyde & Zeck, P.C. In addition, the Center co-hosted Accessibility for All Ages and Abilities: Opportunities for Austin in 2013 with BikeAustin. Center Director Billy Fields also participated in a set of national policy round tables. In February, 2014, Dr. Fields participated in a national webinar on the future of urban interstates sponsored by the State Smart Transportation Institute at the University of Wisconsin, Madison. Dr. Fields also participated, for the second year, in the Harvard School of Public Health Prevention Research Center national stakeholder meeting for the Childhood Obesity Intervention Cost-Effectiveness Study (CHOICES) in Boston in June, 2014. The Center will continue to pursue grant and community engagement activities during the coming year. Events will be publicized through the Center website. www.crppt.polisci.txstate.edu
Charles “Chuck” Pinto, Receives Lifetime Achievement Award
On June 27, 2014, Chuck Pinto, Texas State University Distinguished MPA alumnus and new political science department adjunct faculty member, received the Lifetime Achievement Award from the Texas City Management Association (TCMA), which recognizes the city management professional who has made significant contributions to the field of local government management for more than twenty years. Recipients of this award are nominated by TCMA members and chosen by the TCMA Board of Directors, which is made up of municipal administrators from across the state.
Chuck Pinto recently retired as the City Manager of Seabrook, Texas, after a career of more than thirty years in local government law enforcement and city management.
During the fall, 2014 semester, Chuck will serve as an adjunct professor and will teach one state and local government course for the Department of Political Science. He will also be responsible for coordinating the Certified Public Manager (CPM) Program in San Antonio, Texas.
In Memoriam, Dr. Maxwell Cole Murphy
Dr. Cole Murphy, Adjunct Professor of Public Administration and Criminal Justice at Texas State University passed away at the age of 91 on August 21, 2014. Dr. Murphy taught leadership and management courses in Texas State University’s Master’s in Public Administration Program and the Department of Criminal Justice. He began his teaching career in 1972 while he worked for the Texas Rehabilitation Commission as its Budget and Planning Director. Dr. Murphy retired from teaching in 2000.
A veteran of World War II, Cole Murphy was a graduate of The West Point Academy and served 30 years as an officer in the United States Army. He retired from the Army at the rank of full Colonel. His favorite sport was baseball and he spent 30 years as a volunteer umpire in the Little Leagues in Austin, Texas and was selected to umpire in several little league College World Series games.
A Memorial Service was held at Austin Baptist Church at 7016 Ribelin Ranch Drive in Austin, Texas on Sunday, August 24, 2014. Donations in his memory may be made to the Austin Humane Society at 124 West Anderson Lane, Austin, TX 78752.
1985
Brent Stroman, M.P.A., is currently Chief of Police for the Waco Texas Police Department. Chief Stroman’s is a member of multiple Texas police associations: Region 9 Director for the Texas Police Chief’s Association, State Representative for Local and County Law Enforcement Agencies on the FBI’s Advisory Policy Board, Past President of the Central Texas Police Chiefs, and Sheriff Association, and Founding Member of the McLennan 100 Club.
2000
Sue Lee Flores, M.P.A., is a Program Analyst at the Workforce Technical Assistance and Child Care division of the Texas Workforce Commission. She also serves on the Library Board for the City of Pflugerville, and on the Parent Teacher Organization Board of the Pflugerville Middle School. Sue is honored to have received a Star Award from her agency this summer.
2005
Jennifer Sallee, Ph.D., is a school principal, overseeing pre-kindergarten through eighth Grade. Dr. Sallee completed her dissertation and earned her Doctorate in Education Leadership this year. She is also the mother of two beautiful girls.
2007
Rebecca Kennedy, M.P.A., is currently the Municipal Civil Service Administrator for the City of Austin. In November 2012, the residents of Austin passed a Charter Amendment restructuring the City’s personnel system to Municipal Civil Service. Rebecca became administrator over this new division in July, 2013. She has spent the past year writing and revising the Municipal Civil Service Rules. The Austin City Council passed the Rules in June, 2014, and she is now part of the implementation team for the roll out of the rules to 8,500 covered employees. Rebecca is the mother of two children, Jaxon (2 years) and Karen (8 months.)
James Quintero, M.P.A., was highlighted in last year’s newsletter for his work as Director of the Center for Local Governance at the Texas Public Policy Foundation. This year he reports the biggest change for him is welcoming a new member to the Quintero family, a baby girl, due in October, 2014.
2009
Floyd William Holder, IV, M.P.A., is currently a Government Instructor at Western Texas College in Snyder, TX.
2011
Amber Conrad, M.P.A., is currently an editor in the Executive Division of the Teacher Retirement System of Texas. This summer she received a TRS agency-wide award for excellence. Her current projects include working on the organization’s new social media strategy. She currently lives in Austin.
Amanda Couch, M.P.A., is currently employed as a Senior Planner in the Planning and Development Review Department, City of Austin.
Lori Donley, M.P.A., is the Executive Director of Literacy Texas, a statewide literacy coalition. Before joining Literacy Texas, she worked in Family Initiatives for the Texas Attorney General and, prior to that, was Leadership Development Coordinator for the Texas Classroom Teachers Association. Lori is a passionate community leader and currently serves on the Greenlights 501Council. She is a Past President of the Young Women’s Alliance and Club Red of Central Texas for the American Red Cross.
Chad L. Nolte, M.P.A., works as a Contract Specialist for the Texas School Safety Center, at Texas State University. Chad was also elected this year to serve on the Planning Commission Board for the City of New Braunfels.
Alaric H. Robertson, M.P.A., is a Process Improvement and Analytics Specialist in the Texas Department of Licensing and Regulation (TDLR). Alaric moved to this position after receiving his Master of Public Administration degree from Texas State University. Alaric has enjoyed some martial arts success as well, having recently received his Black Belt Six Sigma certification.
Mitch Sellars, M.P.A., is currently a Ph.D. candidate at the University of Florida, and has reached all-but-dissertation (A.B.D.) status. Mitch reports three forthcoming publications; one in Political Research Quarterly on voter id laws, and two in an edited volume entitled Transgender Rights and Politics. This past April, Mitch won the H. Douglas Price Award and Best Graduate Student Paper Award from the University of Florida.
John Sone, Col., USA (ret.), M.P.A., is now City Manager of Woodcreek, TX. He discontinued his work as a Government Relations consultant to concentrate on his new duties.
Andrew Thompson, 1st Lt., M.P.A., works in the Management Development Program of GEICO and is commissioned as a First Lieutenant in the Texas Army National Guard. He lives in Houston, TX.
Travis Whetsell, M.P.A., is currently pursuing a PhD at The Ohio State University, The John Glenn School of Public Affairs. Travis worked with Dr. Patricia Shields to publish an article in a military sociology book. Travis also published an article on positivism. He is currently working for Dr. Caroline Wagner at the Battelle Center for Science and Technology Policy, and has one article under review with her, and another with Jos. C.N. Raadschelders.
2012
Christy Carter, M.P.A., holds two positions in Washington, D.C.: the Director of Membership at the Women’s Information Network and Program Assistant to the Director of Campaigns, and the Director of Public Outreach at Greenpeace USA.
Jeff Davis, M.P.A., was recently promoted to Assistant Chief of the Georgetown Fire Department. Jeff lives in Georgetown with Valerie, his wife of sixteen years.
Claire Moyers, M.P.A., is the Development Associate for the Texas Cultural Trust, a 501(c)3 non-profit organization whose mission is to promote and highlight the importance of the arts in educating children and sustaining the vibrant Texas economy. She is currently planning for the 2015 legislative advocacy campaign during the legislative session, which will focus on statewide funding for the arts. She is also facilitating the major donor and corporate sponsorships for the 2015 Texas Medal of Arts Awards, which will be held in February during the legislative session.
Genedine Aquino, M.P.A., is currently a Crime Statistician for the Texas Department of Public Safety. She was recently promoted to this position from Research Analyst. Genedine also played a role in creating the 2011, 2012 and 2013 Crime in Texas reports. Genedine’s ARP titled, *Texas National Guard and Reserve Members and Veterans: Post-Deployment and Reintegration Problems and the Services to Meet those Needs* was cited by the Center for Deployment Psychology in November, 2013.
Trent Kennedy, M.P.A., has served as the Executive Director of the McCarty Student Center since 2007. The center is a local nonprofit that supports, encourages, and assists college-aged students. Located across from undergraduate admissions at Texas State, the center’s focus is primarily ministering to the Texas State campus.
Keith O’Herrin, M.P.A., graduated last December and is now pursuing a Ph.D. in Urban Forestry at Virginia Tech University.
Jordan Peterson, M.P.A., is an independent petroleum landman in the Permian basin of West Texas. He has enjoyed wild-cutting success in his recent contract with Pioneer Natural Resources USA, Inc. Trent credits the Texas State M.P.A. program as perfect preparation for this type of work.
Lindsay Rose, M.P.A., is the Marketing Coordinator at Charity Dynamics, a career advancement from her previous position, Administrative Services Assistance. She also edits the official Charity Dynamics blog found at blog.charitydynamics.com.
The Texas State University MPA Program is proud of its thirty-seven graduates for the 2013-2014 Academic Year.
**December 2013**
- Genedine M. Aquino
- James A. Beck
- Karen D. Ferrell
- Adrienne H. Fischer
- Sarah M. Gomez
- Michael B. Grisham
- Kyle R. Harward
- Bridget R. Hinze
- Kai (Joshua) Kang
- Bridgett C. Lee
- Dana L. Mays
- Keith L. O’Herrin
- Kendrick M. Payne
- Jamyen J. Robinson
- William W. Teeter
- Jose A. Vargas
**May 2014**
- Sarah J. Bernier
- Flannery A. Bope
- Karen L. Carlson
- Bryce D. Cox
- Brittany D. Decker
- Jeremy L. Garrett
- Larry D. Gonzales
- James C. Hardin
- Sheri B. Hicks
- Collette D. Jamison
- James P. Jardine
- Curtis W. Leeth
- Ginger M. Lowe
- Dale S. Mantey
- Angelique M. Myers
- Charlie S. Nilmag
Rachel E. Saucier
David A. Serrins
Colin S. Smith
Dr. Longoria with Angelique Myers
The Celebration
On May 1, 2014 the CENTEX Chapter of the American Society for Public Administration (ASPA) held its annual Public Service Recognition Week Banquet at the historic Green Pastures Restaurant in Austin, Texas. Over one-hundred-and-forty individuals attended this year’s event, which celebrated the 40th anniversary of Texas State University’s Masters’ of Public Administration (MPA) Program. Featured at the event was the recognition of twenty-one outstanding Texas State University MPA distinguished alumni including John Sharp, Chancellor of Texas A&M University, Larry Gilley, City Manager of Abilene Texas, Past President of the Texas City Management Association (TCMA) and Dr. Dee Ellis, Executive Director/State Veterinarian of the Texas Animal Health Commission.
Featured Speaker
The featured speaker for the event was the Honorable Larry Gonzales, member of the Texas House of Representatives. Representative Gonzales received his Master of Public Administration from Texas State University in May, 2014 and spoke about importance of public administrators and public servants to the citizens of Texas.
Awards Ceremony
One of the awards presented was the Public Administrator of the Year Award, presented by MPA Director, Dr. Tom Longoria to Magdalena Blanco. Ms. Blanco is a graduate of the Texas State University MPA Program. Among her many contributions to public service, Ms. Blanco served as Chair of the City of Austin’s Independent Citizen’s Districting Commission and currently serves as a Director of the Travis County Strategic Finance Corporation.
Dr. Patricia Shields, Professor and former Texas State University MPA Director was honored by CENTEX ASPA as a Public Administration Educator of the Year. The CENTEX Chapter of ASPA also highlighted the accomplishments of faculty, students, and alumni of the Texas State University MPA Program, The University of Texas LBJ School of Public Affairs, and the Bush School of Government and Public Service at Texas A&M University.
All three universities recognized outstanding public administration educators and student research projects and named distinguished alumni. Each year, outstanding graduate student research is recognized by the James W. McGrew Research Award. Texas State University MPA McGrew Award recipients were Denise Dusek, whose research paper was entitled “An Ideal Model for Responding to Active Shooter Incidents in Schools” and Pam Tise, whose research paper was entitled, “A Fragile Legacy: The Contributions of Women in the United States Sanitary Commission to the United States Administrative State.”
Phi Alpha Alpha
In recognition of student scholarly achievements, Pi Alpha Alpha, the National Public Administration Honor Society, inducted six new student members into the Texas State University Chapter of the Honor Society.
The new inductees from Texas State University are:
Bryce Cox
Trinh Bartlett
Devin Bailey
Curtis Leeth
Janiece Crenwelge
Samantha Alexander
Scholarships
The Public Service Recognition Week Banquet offered an opportunity for CENTEX ASPA to reward the efforts of students pursing graduate degrees in public administration with financial support. A number of named scholarships in public administration were presented including:
The Dr. George Weinberger Scholarship. Dr. Weinberger recently retired as a professor in the Texas State University MPA Program and sponsored two CENTEX ASPA scholarships. The scholarships were presented to Jennifer Jendrzej and Jeremy Martin. Both Jennifer and Jeremy are graduate students at the LBJ School of Public Affairs.
The William P. Hobby Family Scholarship. This scholarship was offered by Texas State University and presented to MPA student Devan Gartman.
The Balanoff Family Scholarship. This scholarship was awarded to Texas State MPA student, Marta Ortiz.
The Frank Rich Scholarship. Two Frank Rich Scholarships, named in honor of the former Chair of the Political Science Department at Texas State University, were given to Texas State University students Samantha Alexander and Geronima Brady.
All five students receive scholarship awards at $1000 per semester for the 2014-15 academic year.
Distinguished Alumni
The evening concluded with the naming of Distinguished Alumni from the LBJ School, the Bush School, and the MPA Program at Texas State. Distinguished Texas State alumni recognized include:
Barry Bales, Assistant Dean for Professional Development, The LBJ School of Public Affairs, UT Austin
Brenda Branch, Director, City of Austin Public Library
Gary Coe, Texas State University’s CPM Program Faculty
Ron Davis, County Commissioner, Precinct #1 Travis County, TX
Mike Eastland, Executive Director, North Central Texas Council of Governments
Brenda Eivens, City Manager, Cedar Park, TX
Dee Ellis, Executive Director, Texas Animal Health Commission
Doug Faesler, City Manager, Sequin, TX
Larry Gilley, City Manager, Abilene, TX
Barney Knight, Principal, Barney Knight Law Firm, Former City Manager of Austin & Temple, TX
Charles Matthews, Former Chancellor of the Texas State University System and former Chair of Texas Railroad Commission
Eddie Molina, former Director of Administration, TCEQ
David MacCabe, former Director of Internal Auditing, Teachers’ Retirement System of TX
Chuck Pinto, former City Manager of New Braunfels, Live Oak, Seabrook and Orange, TX
Richard Ridings, Executive Vice President, HNTB Engineering, former Chief Executive Officer Oklahoma Turnpike Authority
Rudy Ruiz, Founder & President, Community Development Management Co., Lockhart, Texas
Phil Ruiz, Founder & Vice President, Community Development Management Co., Lockhart, Texas
Matthew Smith, City Manager, Live Oak, Texas
John Sharp, Chancellor, Texas A&M University System & former Comptroller of the State of Texas
Mike Tanner, former City Manager, Portland, Texas
Debbie Tucker, Executive Director, National Center on Domestic & Violence, Austin, TX
Distinguished Alumni
Designed for present and future leaders in public service, the Texas Certified Public Manager (CPM) program is the flagship program offered by Texas State University’s William P. Hobby Center for Public Service. Texas State has been designated to deliver the nationally accredited CPM program throughout Texas. The program is open to professionals, faculty and students from other countries. Texas is one of 40 U.S. states that offer the CPM program.
The William P. Hobby Center for Public Service works with public organizations, non-governmental organizations (NGOs) and charities throughout Texas and beyond. The center operates in cooperation with other universities, including Stephen F. Austin State University, Sam Houston State University, The University of Texas–Pan American, Texas Tech University and the University of Houston.
**2014 CPM Graduation**
Texas State University’s William P. Hobby Center for Public Service graduated thirty new Texas Certified Public Managers at the Texas State Capitol on Monday June 9, 2014.
The CPM graduates and their families came from CPM Programs at the following locations: San Marcos, Round Rock, Arlington, Houston and Nacogdoches Texas. The graduates participated in CPM Programs offered by the following universities, Texas State, Stephen F. Austin, Sam Houston State University and The University of Houston.
The CPM graduation speaker Brenda Eivens, City Manager of the City of Cedar Park, spoke about the need for public service and congratulated the graduates for their dedication to public service and for achieving their CPM certification. Ms. Eivens received her MPA degree from Texas State University. She was also presented with an honorary CPM Certification Certificate at the Graduation.
**2014 CPM Graduates by Location**
**Texas State University**
San Marcos, Round Rock and Arlington
- Alice Rocha
- Indira Rodriguez
- Tammer Elshahed
- Delores Hobbs
- Nanette Ann McCartan
- Joseph Florentino
- Matthew Garrett
- Greg Petrey
- Steven Santos
**Sam Houston State University**
Houston and Galveston
- Raymond Cooper
- Ursula Norman
- Kathryn Liberto
- Andre Mitchell
- JoAnne Perry
- Aricia Robinson
- Suzanne St. Michael
- Justin Taylor
- Raymond Tuttolimondo
- Kimberly Vaughn
- Modeane Walker
- Allan Warren
**University of Houston**
- Tim Buck
- Michael Kinlaw
- Sarah Korpita
- Jill Matzig
- David Oyler
**Stephen F. Austin State University**
- Lonny Cluck
- Olivia King
- James Perry
- Ana Sanchez
For additional information about the 2014 Texas CPM Conference and/or the Texas CPM Program contact:
Dr. Howard Balanoff
Political Science Professor
Chair of Texas State University’s William P. Hobby Center for Public Service
firstname.lastname@example.org
512.245.3453.
www.txstate.edu/cpm
Nearly 150 Texas CPM alumni, faculty, and students gathered in Round Rock, Texas on Friday April 11, 2014, to learn, share and network at the Annual Texas Certified Public Manager (CPM) Conference. The Conference, which was held at the Texas State University Avery Building, featured outstanding plenary speakers and breakout sessions on a variety of public administration and public policy topics, including the William P. Hobby Distinguished Lecture and the business meeting of the Texas Society of Certified Public Managers.
The Hobby Distinguished Lecture is always a highlight of the annual conference. This year’s plenary session was no exception, with the 2014 honoree Retired US Army General Montgomery Meigs, who gave a presentation on leadership in the public and not for profit sectors.”
General Meigs’ presentation engaged the audience in an interactive discussion about the importance of leadership skills to the establishment and maintenance of efficient and effective organizations. During a 35-year career in the U.S. Army, General Meigs served as Commander, U.S. Army Europe (1998-2002). For the first year of that assignment, he also served as Commander of SFOR, NATO’s peacekeeping force in Bosnia. In addition, he commanded the U.S. Army Combined Arms Center and was Commandant of the Army’s Staff College (1997-1998).
During his tour he revised the Staff College’s leadership curriculum and oversaw the writing of the Army’s leadership manual. He also led the 1st Infantry Division in its deployment enforcing the Dayton Treaty in Bosnia (1996-1997). He commanded the Iron Brigade of the 1st Armored Division in Operation Desert Storm and at Medina Ridge.
As a self-proclaimed “equal opportunity offender of both Democrats and Republicans,” Harvey’s observations are always candid, insightful and give us the opportunity to take a humorous look at ourselves, each other and Texas politics. During the Texas Society of Certified Public Managers conducted its business meeting and discussed the impact of the merger of the American Society of Public Administration (ASPA) and the American Academy of Certified Public Managers (AACPM) on members of the Texas CPM Society. In addition to the Texas CPM Society business meeting, morning and afternoon conference breakout sessions were informative, engaging and insightful.
**Conference Break Out Sessions, Topics and Speakers**
*From Chaos to Collaboration: New Approaches to engaging the Public in Productive and Proactive Ways*
Larry Schooler, John-Michael Cortez, Alex Sanchez, Bryce Bencivengo, Diane Miller
*Local Government Forecasting: Lessons from the City of Georgetown*
Chris Foster, Micki Rundell
*Structure, Function, Operation and Decision Making at the Texas Sunset Commission*
The Hon. Larry Gonzalez, Ken Levine
*Current Topics in Public Finance*
Dustin Traylor, Bob Henderson
*Local Government Major Incident after Action Process: Lessons from the Halloween Floor, City of Austin*
Otis J. Latin, Billy Atkins, Sean Shepard
*Social Media in Public Sector Organizations: Legal Impacts of Social Media on Public Sector Organizations*
Alan Bojorquez, Sherri Greenberg
*Structure, Function, Operation and Decision Making at the Texas Legislative Budget Board*
The Hon. John C. Otto, Ms. Ursula Parks
Texas State in Romania
This summer, Texas State Master of Public Administration faculty went international, attending a conference in the Eastern European nation of Romania. This exciting trip emphasizes the growing international reputation of the Texas State University MPA program.
From June 15-26, 2014, faculty from Texas State University joined faculty from other United States institutions and from around the world, traveling to Romania as participants in an International Public Administration Forum, sponsored by the American Society for Public Administration (ASPA) Section for Public Management Practice (SPMP). Texas State faculty delivering presentations at the conference included Dr. Billy Fields, Dr. Howard Balanoff, Dr. Emily Hanks, and Mrs. Marilyn Balanoff. In addition to participating in the forum, the Romanian hosts took a group of about thirty public managers on a tour of five Romanian cities. The American Society for Public Administration SPMP works with local administrators in Romania to improve local government practices. The section partnered with the Romanian Review of Local Government Administration to host the forum, which was held in Brasov, Romania.
Over one hundred local, regional, and national public administrators attended the forum. Attendees included public administrators from Lithuania, Latvia, South Africa, Turkey and the Netherlands. The event was organized and sponsored by Lonut Luria, editor-in-chief of the Journal of Local Government Administration and Cristina Mita, managing editor.
Section for Public Management Practice members also visited the Ministry of Regional Development and Public Administration, where they attended a presentation by senior officials on Romanian public administration: past, present and future. The group also visited the Palace of the Parliament and engaged in a surprisingly candid and lengthy conversation with five national senators. These senators were responsible for shepherding a controversial regionalization and decentralization plan through the legislature. Additional visits and exchanges occurred with various local government officials in the Romanian cities of Brasov, Bucharest, Pitești, Sinaia, and Tulcea.
The Romanian trip and forum followed two visits by a group of Romanian local government administrators to the United States. The first visit occurred in Orlando, Florida in October of 2013. During this trip, the University of Central Florida hosted a meeting that provided an opportunity for dialogue between the visiting administrators and SPMP. The second trip, to Washington, D.C., occurred in March 2014 during ASPA’s Annual Conference. During this meeting, SPMP conducted a one day forum attended by the Romanian administrators and staff on the Romanian Review of Local Government Administration.
Research Spotlight on Michael Grisham
by Dr. Emily Hanks
What’s next for your Applied Research Project (ARP)?
I pose this question each time that I have the opportunity to participate in an oral examination for graduating MPA students. As you might imagine, I receive a wide variety of responses. Last December, Michael Grisham replied that he wanted to publish his research and (spoiler-alert) his article “To partner or not to partner: That is a public manager question,” co-authored with Drs. Longoria and Hanks, will appear this fall in the peer-reviewed journal The Public Manager.
As the Community Partner Program Lead for the Texas Health and Human Services Commission, Michael directs a team charged with establishing partnerships between his agency and nonprofit organizations.
The first step in implementing such programs, notes Michael, is to determine which nonprofits have the capacity to be an effective partner. Unfortunately for Michael and other public managers, there was not much guidance on the issue. He decided to fill this gap; writing an ARP with the goal of assisting public managers to evaluate a nonprofit organization’s readiness to partner with government entities.
You are probably not surprised to learn that the rigorous requirements of the ARP process produced insights valuable to a broad audience. More striking, rather, was Michael’s ambition and enthusiasm to engage in the additional work required to publish his findings. Before he even had the chance to walk across the stage at graduation, Michael and his new co-authors (Dr. Tom Longoria and Dr. Emily Kay Hanks) begin adapting his ARP into a journal article.
During the revision two key decisions were made:
Because helping practicing public administrators was Michael’s original inspiration, we used the ARP to develop a tool, “The Nonprofit Readiness Checklist,” that practitioners would find easy to read, understand, and more importantly, apply; and concentrated on matching the content and practice-oriented spirit of the article with a journal embracing such an approach.
As a result, the article will appear in the fall 2014 issue of The Public Manager—a peer-reviewed journal that reaches more than 40,000 subscribers worldwide and is dedicated to publishing innovative ideas and practical applications of learning technologies.
Michael shared the following about the process: “I encourage any MPA student to use their research to help solve public management problems...a large part of our responsibility as aspiring or practicing public managers is make sure others have the opportunity to gain insight from our research and experiences.”
In conclusion, we hope to make the Spotlight a recurring feature of the Magazine. The M.P.A. faculty are dedicated to increasing the number of such collaborations and to empowering students by demystifying the publication process.
Before he even had the chance to walk across the stage at graduation, Michael and his new co-authors begin adapting his ARP into a journal article.
Books
Renne, J. & W. Fields. (2013). *Transport beyond oil: Policy choice for a multimodal future*. Island Press/Center for Resource Economics.
Shields, P., & Rangarajan, N. (2013). *A playbook for research methods: Integrating conceptual frameworks and project management*. Stillwater: New Forums Press.
Soeters, J., Shields, P., & Rietjens, S. (2014). *Routledge handbook of research methods in military studies*. Routledge.
Articles
Balanoff, E. K. (2013). A special, set-apart place no longer? Deconstructing the discourse of meaning and mission in nonprofit newsletters. *Administrative Theory & Praxis*, 35:11-27.
Balanoff, H.R. & Master, W. (2014). ASPA section participates in International public management forum. *PA Times*. Volume 37, Number 3. P. 15.
Farmer, J. L. (2014). County-nonprofit service arrangements: The roles of federalism and state fiscal involvement. *Publius: The Journal of Federalism*.
Fields, B. (2013). Confronting the wicked problem: Disaster planning in post-Katrina New Orleans. *Good Governance Worldwide: The Online Journal and Network of the American Society for Public Administration’s Section for Public Management Practice*.
Fields, B., Wagner, J., & Frisch, M. (2014). Placemaking and disaster recovery: Targeting place for recovery in post-Katrina New Orleans. *Journal of Urbanism: International Research on Placemaking and Urban Sustainability*, 1-19.
Grisham, M., Hanks, E., & Longoria, T. (2014). To partner or not to partner? That is the public manager question. *The Public Manager*, (43)2: 51-56.
Longoria, T. (2014). Are we all equal at death?: Death competence in municipal cemetery management. *Death Studies*, 38:355-364.
Longoria, T. (2014). Predicting use and solicitation of payments in lieu of taxes. *Nonprofit and Voluntary Sector Quarterly*, 43(2) 338-354.
Longoria, T., & Rangarajan, N. (Forthcoming). Measuring public manager cultural competence: the influence of public service. *Journal of Public Management and Social Policy*.
Rahm, D., & Reddick, C. G. (2013). Information and communication technology (ICT) for emergency services: A survey of Texas emergency services districts. *International Journal of E-Politics*, 30-43.
Tajalli, H., De Soto, W., & Dozier, A. (2013). Determinants of punitive attitudes of college students toward criminal offenders. *Journal of Criminal Justice Education*, 24(3): 339-356.
Tolford, T., Renne, J. L., & Fields, W. (2014). Development of a low-cost methodology for evaluating pedestrian safety in support of complete streets policy implementation. *Transportation Research Record: Journal of the Transportation Research Board*.
Wang, T., Shields, P., & Wang, Y. (2014). The effects of fiscal transparency on municipal bond issuance. *Municipal Finance Journal*, 25-44.
Whetsell, T. A., & Shields, P. M. (2013). The dynamics of positivism in the study of public administration: a brief intellectual history and reappraisal. *Administration & Society*.
Book Chapters
Balanoff, H. R., & Balanoff, E. K. (2013). The National Certified Public Manager (CPM)
Program: A model for public and nonprofit leaders and managers around the world. In G. Bouchaert, & M. S. de Vries (Eds.), *Training for leadership*. Brussels: Bruylant Publishers.
Bartle, J. R., & Shields, P. (2013). The practice of government finance. In M. Kelemen, & N. Rumens (Eds.), *American pragmatism and organization studies: Issues and controversies*. London: Gower Publishing.
Hanks, E. K. (Forthcoming). Nonprofit organizations: Communication. In M. J. Dubnick, & D. A. Bearfield (Eds.), *Encyclopedia of public administration and public policy*. New York, NY: Taylor and Francis.
Rahm, D. (2014). U.S. law and policy in environmental management. In D. Sarkar (Ed.), *An integrated approach to environmental management*. Wiley.
Rangarajan, N., & Rahm, D. (2013). San Antonio’s Mission Verde and leading by example initiatives. In S. M. Opp, & J. L. Osgood, Jr. (Eds.), *Local economic development and the environment: Finding common ground*. New York, NY: Taylor & Francis Group.
Shields, P., Hanks, E. K., & Whetsell, T. (2013). Pragmatism and public administration: Looking back, looking forward. In M. Kelemen, & N. Rumens (Eds.) *American pragmatism and organization studies: Issues and controversies*. London, UK: Gower Publishing Limited.
Whetsell, T., & Shields, P. (2013). Punctuation, continuity, and historicity: Traversing the in-between. In P. H. Crowley, & T. R. Zentall (Eds.), *Comparative decision making*. New York, NY: Oxford University Press.
Yun, H. J., Opheim, C., & Balanoff, E. K. (2014). Whose states are winning? The adoption and consequences of social media in political communication in the American states. In J. A. Hendricks, & D. Schill, *Presidential campaigning and social media: An analysis of the 2012 campaign*. New York: Oxford University Press.
As of January 2013, almost 400 Applied Research Projects (ARPs) have been downloaded 500,000 times, across more than 140 nations. This is only one measure of the growing academic reputation and national recognition of the Texas State University Master of Public Administration program.
Below is a brief list of recent ARP authors and where their work has been cited:
**Author: Heather Crosby**
ARP: *Explaining achievement: Factors affecting Native American college student success* (2011)
Cited: *Library services for multicultural patrons: Strategies to encourage library use* (2012), edited by Carol Smallwood and Kim Becnel.
**Author: Peggy Helton**
ARP: *A guidebook of resources for battering intervention and prevention programs in Texas to mitigate risk factors which increase the likelihood of participant drop out* (2011)
Cited: *Psychosocial intervention* (2013), by Montse Subirana-Malarret and Antonio Andrés-Pueyo
**Author: Kai Huang**
ARP: *Population and building factors that impact residential fire rates in large U.S. Cities* (2009)
Cited: *Crucible of fire* (2011), by Bruce Hensler
**Author: Mark Featherston**
ARP: *High-stakes testing policy in Texas: Describing the attitudes of young college graduates* (2011)
Cited: *Das zentralabitur im kontext der bildungsgerechtigkeit* (2013), by Ramona Lorenz
**Author: James Wilson**
ARP: *Policy actions of Texas Gulf Coast cities to mitigate hurricane damage: Perspectives of city officials* (2009)
Cited: *Pre hospital perspectives in emergency management*, Edith Cowan University
Cited: *Application of ICT in disaster management with emphasis on Indian subcontinent* (2012), by Sachin Kadam
Cited: *Design and evaluation of mass evacuation support systems using ontologies for improved situation awareness: A dissertation presented in partial fulfillment of the requirements for the degree of Doctor of Philosophy in Information Sciences at Massey University, Albany, New Zealand* (2012), by Yasir Javed
Cited: *Considering emergency and disaster management systems from a software architecture perspective* (2012), by Moumita Mukherjee Shukla and Jai Asundi
**Author: Melissa Whitmore**
ARP: *Success through succession: Implementing succession planning at the Texas Department of Insurance* (2006)
Cited: *Relationship between project planning and performance* (2014), by Shahab Ud Din and Syed Nisar Ahmed
**Author: Kevin Bailey**
ARP: *An evaluation of the impact of hurricane Katrina on crime in New Orleans, Louisiana* (2009)
Cited: *Analyzing the impact of one important unplanned exceptional event, hurricanes, on crime in Louisiana, U.S. Using a visual analytics approach* (2011), by Michael Leitner and Diansheng Guo.
**Author: Shaina L. Trial**
ARP: *Assessment of patient processing in emergency departments of hospitals* (2009)
Cited: *National perspective on in-hospital emergency units in Iraq* (2013), by Riyadh K. Lafta and Maha A. Al-Nuaimi
**Author: Jennifer Lindsey**
ARP: *Quality after school time: An evaluative study of the Eastside Story after school program in Austin, TX* (2010)
Cited: *Toward more equitable outcomes: A research synthesis on out-of-school time work with boys and young men of color* (2014), by Jon Gilgoff and Shawn Ginwright
**Author: Terry Jennings**
ARP: *A river runs through it: Assessing the attitudes of landowners along the Luling paddle trail* (2010)
Cited: *Funding sustainable paddle trail development: paddler perspectives, willingness to pay and management implications* (2011), by Carol Kline, David Cardenas, Lauren Duffy, & Jason R. Swanson
**Program Faculty**
**Howard Balanoff, Ed.D.**
Endowed Professor
Director of the Hobby Center
*Areas of Interest: Personnel Administration, Comparative Policy and Administration, Organizational Theory and Behavior, and Leadership*
**Christopher Brown, J.D.**
Associate Professor
*Areas of Interest: Environmental and Natural Resources Law and Administrative Law*
**Jayce Farmer, Ph.D.**
Assistant Professor
*Areas of interest: State and Local Government Fiscal Policy, Urban Policy, and Local Government Administration*
**Billy Fields, Ph.D.**
Assistant Professor
Director, Center for Research, Public Policy, and Training
*Areas of Interest: Environmental Policy and Management, Place Management, Hazard Mitigation, and Trans. Policy*
**Charles Garofalo, Ph.D.**
Professor
*Areas of Interest: Ethics in Public Administration, Public Policy, Government-Business Relations, and Globalization*
**Emily Hanks, Ph.D.**
Assistant Professor
*Areas of Interest: The Nonprofit and Voluntary Sector, Public Values, and Applied Communication*
**Dianne Rahm, Ph.D.**
Professor
*Areas of Interest: Environmental Policy, Science & Technology Policy, and Public Policy*
**Nandhini Rangarajan, Ph.D.**
Associate Professor
*Areas of Interest: Public Management and Organizational Creativity, and Research Methods*
**Thomas Longoria, Ph.D.**
Professor
Director of the MPA Program
*Areas of Interest: Local Government Policy and Administration, Urban Politics, and Non-Profit Management*
**Patricia Shields, Ph.D.**
Professor
Editor Armed Forces and Society
*Areas of Interest: Civil Military Relations, Pragmatism of Public Administration, and Research Methods*
**Stephanie Newbold, Ph.D.**
Associate Professor
*Areas of Interest: Intellectual History of Public Administration, Democratic-Constitutionalism, and the Administrative State*
**Hassan Tajalli, Ph.D.**
Associate Professor
*Areas of Interest: Research Methods, Statistics, Program Evaluation, and Public Policy*
---
**Welcome Dr. Newbold**
The M.P.A. Program is proud to welcome Dr. Stephanie Newbold to the faculty. Dr. Newbold specializes in the intellectual history of public administration, democratic-constitutionalism, judicial branch dynamics, and the intersection between the American Constitution and the administrative state.
Dr. Newbold’s research broadly examines the importance of connecting the constitutional and institutional values of American government to administrative theory and practice as well as carefully examining how important, intellectually significant figures of history shape the study and practice of democratic theory and public administration in contemporary times. The National Association of Schools of Public Affairs and Administration (NASPAA) recognized her research on Thomas Jefferson’s role in advancing U.S. public administration, as making significant contributions to the intellectual advancement of the field.
During the 2012 term, Dr. Newbold served as the U.S. Supreme Court Fellow in the Office of the Counselor to the Chief Justice. Largely regarded as one of the most prestigious fellowships in the United States for mid-career professionals, this experience afforded Dr. Newbold the opportunity to contribute to the administrative functions and responsibilities of the Supreme Court, and other judicial branch agencies. In this position, the U.S. Department of State recognized her for sustained support of its Public Diplomacy Rule of Law program.
Dr. Newbold has also worked for the Office of the White House Chief of Staff, and the International Center for Jefferson Studies at Monticello. She holds a B.A. in political science and public administration from Elon University, and an M.P.A and Ph.D. in public administration from Virginia Tech. Dr. Newbold previously worked as an Assistant Professor of Public Administration at American University before joining the M.P.A. Faculty at Texas State.
Welcome to Texas State University!
As the president of the Central Texas Chapter of the American Society for Public Administration (CenTex ASPA), it is my distinct pleasure to welcome you to Texas State as you begin your journey in the Masters of Public Administration program. CenTex ASPA is the local area chapter for the national American Society for Public Administration. The organization is the premier professional association for public administrators; public-sector and NGO professionals; and educators operating in this field. As the chapter representing the forty-two counties making up the central Texas region, including the cities of Waco, Austin and San Antonio, we represent the network of government professionals and educators in the heart of Texas.
Our chapter is one of the largest and strongest in the nation, and we want to provide you with this great resource. We welcome you to join our organization as you pursue your M.P.A. at Texas State. There are many benefits of participating in CenTex ASPA including: professional development workshops, speaker series, educational resources, and most importantly, networking and collaboration opportunities with area professionals. We are also proud to have many of your Texas State University faculty as chapter members, and many sit on the CenTex ASPA Council. Additionally, as a graduate from the Texas State M.P.A. program, and now President of CenTex ASPA, I can personally speak firsthand to how integral this organization has been to my professional development. I encourage you all to reach out for more information and become a part of our amazing network.
Your pursuit of an M.P.A. at Texas State has placed you in an incredible program full of exceptional faculty, students and resources. The knowledge and practical experience you will garner over the course of this program will be invaluable for your professional and academic development. I wish you all the best of luck on your academic endeavor. Go Bobcats!
Gabriel G. Sepulveda, President
CENTEX/ASPA
Welcome, Texas State Students.
As you begin your path in public administration and determine which emphasis to take, I want to take this opportunity to talk a little about local government, particularly city management and the Texas City Management Association (TCMA). As our 2014 TCMA President Mike Land states, “As city management professionals, we make decisions daily that help transform our communities into more than they are today through purposeful thought and actions.” We can be dream makers for our cities but also implement those dreams and visions through day to day operations to where we can see a difference being made.
“TCMA is an organization of local government professionals dedicated to promoting the highest standards of governance, service, leadership, ethics, and education while embracing individual and regional diversity for the benefit of our membership and the cities of Texas.”
“TCMA is member driven, ethical, and inclusive; committed to the council-manager form of government; dedicated to effective partnerships with elected officials; devoted to the professionalism of our organization and members; determined to provide quality service to our membership and the cities we serve.”
The TCMA state chapters are divided into regions that have their own regional chapters. Region 7 encompasses Hays County, including Texas State University. Our regional chapter has a lot to offer through its programs and membership and would like to extend an offer to assist in any way, whether networking, internships, mentoring, sponsorships to seminars and the annual conference, and our State and Region 7 chapters.
We are very excited and looking forward to working with Texas State University’s Public Administration Department by offering programs and learning opportunities for interested students. If you would like more information into TCMA, please visit www.tcma.org; please don’t hesitate to contact me.
Brian LaBorde, AICP, CPM
TCMA Region 7 President
The internship is primarily designed to provide practical experience to pre-service students. The academic component consists of part-time (paid or unpaid) employment in a public service entity, government-related office, or a non-profit organization. A maximum of three hours credit can be earned through an internship.
Normally the student will work an average of 20 hours per week, for a total of 300 hours. The academic component of the public service internship includes a required research paper and completion of assigned readings.
Our students are always seeking quality internship opportunities. If you would like to request an intern, please consider using the following website: http://www.polisci.txstate.edu/resources/Internship-Information.html or contact Dr. Longoria directly at email@example.com.
Texas State University Public Administration Programs rely heavily on internship partners, to provide real world experience for our students. We gratefully acknowledge all our partners, some of which are listed below.
Johns Adams Campaign for Texas State Representative District 45
City of San Marcos, City Manager’s Office
City of San Marcos, Auditor’s Office
Office of Councilman Fred Terry
City of Austin, Communications & Public Information Office
Texas Legislature, Representative Ryan Guillen (District 35)
Refugee Services of Texas
Travis County Intergovernmental Relations Office
City of Windcrest, Texas
National Credit Union Administration
Texas State University, Career Services
Texas Legislature, Representative Dr. J. D. Sheffield (District 59)
Texas Department of Public Safety, Auditor’s Office
Texas Legislature, Senator Shapiro’s Office
Texas Legislature, Senator Doggett’s Office
City of New Braunfels, Texas
Challenges to National Security in a Global Society
Central Texas Medical Center, Administration
Texas General Land Office
University of Texas System and Board of Regents, Office of Governmental Relations
Anne Hodge Campaign for Texas State Representative (District 132)
State of Texas Attorney General’s Office
Learn more about public administration at Texas State at http://mpa.polisci.txstate.edu/
Academic Programs
- Bachelor of Public Administration (BPA)
- Minor in Public Administration
- Master of Public Administration (MPA)
Concentration Areas
- Public Administration and Management
- Environmental Policy and Management
- Urban Policy and Planning
- Public Finance
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Chamber News & Events
**Chamber on Tour - A Three Vineyard Day - Aug. 3**
Chamber on Tour is visiting 3 beautiful Cowichan Valley wineries on Wed. Aug. 3:
- 1 pm: **Deol Vineyard**, 6645 Somenos Rd.
- 2:30 pm: **Averill Creek Vineyard**, 6552 North Rd.
- 4 pm: **Emandare Vineyard**, 6798 Norcross Rd.
Every summer Chamber on Tour provides an opportunity for members to have a behind-the-scenes tour of members' wineries and businesses. You'll meet owners, wine experts, and friendly, knowledgeable fellow members who will share their wine and their stories. Free to members and members guests. Transportation not provided - sample responsibility.
**Chamber on Tour - A Three Vineyard Day**
Wed. Aug. 3, Starting at 1 pm at Deol Vineyard
RSVP Req'd: 250.748.1111 | firstname.lastname@example.org
[Click to download map & schedule](https://ui.constantcontact.com/r/navmap/emcf/email/view?flow=view&camefrom=view&agent.uid=1125236763661)
*Transportation not provided - please sample responsibility.*
**Last Day to Register for China $2299 for Members - Deadline Today July 15**
Still a few seats left! We don't think you'll find a better price for 10 days in China that includes 5 star accommodation - double occupancy, all flights, ground transport, all meals, admissions, professional, full-time guide and more. Non-members accompanying or connected to Chamber members receive the member price of $2299. Non-members just $2399. We've partnered with the experts at Duncan Hill Travel who will coordinate visas, travel insurance, provide travel tips, and generally make things worry-free. Registration deadline July 15. Travellers will visit the Great Wall, Lingering Garden,
Temple of Heaven, the Forbidden City and more! Optional trip to see the Terracotta Warriors
**Chamber on Tour to China** - Oct. 4 - 14
Registration Deadline July 15
$2299 Members | $2399 Non-members
Email Sonja or Elizabeth at the Chamber or call us at 250.748.1111
**Single Occupancy – Travel Buddies**
We have two individuals who are travelling alone. Single occupancy for the hotel rooms is an additional $500. Thus both are seeking another lone traveller to share the room. If you're thinking of the China trip on your own, or a large group - and sharing a room suits your plans (not to mention saves $500) please contact the office.
Email Sonja or Elizabeth or call 250.748.1111
*Elizabeth & her family took the same tour in 2013. She is happy to chat with you about the experience.*
**Luncheon 5 Packs Now Available**
We introduced the Luncheon 5 Pack in 2015, and have been delighted with the response. We hold 7 luncheons during the year, and you can pre-purchase 5. Five Packs are $125 which is a 17% savings. Pre-purchasing helps keep a schedule organized, you only have to register once to buy the 5 Pack, and then just send Elizabeth an RSVP for the luncheon(s) you plan to attend. The 5 packs are flexible - anyone in your organization can use it, or bring a friend/colleague and cover it with your 5 Pack.
Here's what's lined up for the 2016/17 Event Season:
- Sept. 29: **Brent Evans of Vancouver Island Motor Sport Circuit** - on site at the Circuit
- **NB: Sept. 29 is almost full - Please RSVP as soon as you can**
- Oct. 21: **John Hankins, Manager of Nanaimo Economic Development**
- Nov. 24: **New Curriculum for the New Economy with SD79 Supt Rod Allen & Board Chair Candace Spilsbury**
- Jan. 26/17: **Marsha Walden, CEO Destination BC**
- Feb. TBA: **Avatar Grove - Transitioning from Logging to Tourism - the Port Renfrew Model**
We have confirmed Iain Black, Pres. & CEO of the Vancouver Board of Trade as a presenter, and are working on a date. We've reached out to a number of fabulous speakers and will share that information as soon as it comes available.
**Luncheon 5 Pack for 2016/17 - Save $17%**
$125 + $6.25 GST = $131.25
Contact Elizabeth Croft at the The Chamber email@example.com | 250.748.1111
**2016/17 Event Season**
**Luncheon - Vancouver Island Motorsport Circuit, Thurs. Sept. 29** - on location at the Motorsport Circuit!
We Have Visitor Guides!
It is time to top off your supply of Visitor Guides for your customers and guests? We have boxes on-site, ready to pick up. Just contact Visitor Services Coordinator Kirsty Grant to let her know how many you would like, and she'll have them ready for pick up. Each box contains 50 copies, partial cases also available
Cowichan Visitor Guides Available
Trans Canada Hwy & Bell McKinnon Rd.
Contact: Kirsty Grant | 250.746.4636
Jan's Restaurant Pic - The Royal Dar
If you love the character of a restaurant set in an old heritage home, you will be amazed with the rich fabrics and glistening chandeliers that welcome you to the Royal Dar, Vancouver Island's premier Indian Restaurant. The lovely gardens, bursting with flowers greeted us as we meandered up the walkway to the Royal doorway. Customizing the traditional Indian dishes to your preferred heat level is a lovely touch. The Butter Chicken was in a rich buttery cream sauce and the Seafood Goa, with prawns and snapper was cooked in southern, Indian style with ground coconut and coconut milk. We gobbled down the basket of homemade naan bread, baked on-site in a clay oven. It was so tasty, we used it to mop up the sauce on our lunch plates.
The Royal Dar
148 3rd Street
250.587.1483
Jan volunteers at the Cowichan Regional Visitor Centre & loves eating out at Cowichan restaurants.
This Weekend & Coming Soon
**Tons of fun at Downtown Duncan Day July 16!**
The big news this year is that Downtown Duncan Day is now a 1-day event happening this Sat. July 16 and downtown streets will be closed for one jam-packed day of family fun. Saturday's event includes traditional favourites like the Pancake breakfast, Kids' Parade, Free Rides and activities, the Fashion Show, and the [Duncan Farmers Market](#). Plus there's the [Cowichan Summer Grande Parade](#), presented by the [Duncan-Cowichan Festival Society](#) (DCFS), sponsored by RIBA Holdings Ltd. Then head to heady to City Square in the evening for more entertainment. There's a new Vintage & Classic Motorcycle Show & Shine on the streets of Downtown Duncan. Bring your bike down or just come to admire!
[Downtown Duncan Day](#)
Sat. July 16, ALL DAY
Through out Downtown Duncan
[Click here for more information or to register for any event](#)
**Harlequin Nature Graphics - Factory Sale - TOMORROW - July 15**
Harlequin Nature Graphics is having a factory blow out sale tomorrow - Sat. July 16. Blank T-Shirts start at $2.50 ea! All clothing is on sale including: men's ladies' and children's shirts. Blank t-shirts from $2.50, printed from $5.00 Jackets hoodies, sweatshirts, golf shirts, hats and more at clear out prices!
[Harlequin Nature Graphics](#) - Factory Blowout Sale
Sat. July 16, 9 am - 5 pm
#2 - 1340 Fisher Road (beside Creative Woodcraft) | 250.929.1181
**Fundraising Concert for Special Olympics at Glenora Farm - TOMORROW July 16**
Glenora Farm is pleased to partner with Special Olympics Cowichan Valley in support of more opportunities for athletes and their abilities. We have a great line up of musicians planned for our outdoor stage including local artists:
- [Amy and Tafadzwa Matamba of Mbira Spirit](#)
- Reyne and Andrew Cooper of King Tide celtic folk group with Paul Ruszel
- Glenora's famous Glenora Farm Hand Bell Ensemble
Hay bales seating. BYO blanket. Lots of room for everyone!
[Glenora Farm - Fundraising Concert for Special Olympics](#)
Sat. July 16 1 - 4 pm
4766 Waters Rd.
Snacks, Refreshments & Admission by donation.
Suggested entry donation: $20 Individuals | $30 Families | $5 SO athletes
**Massive Framing Sidewalk Sale at Excellent Frameworks - TOMORROW July 16**
Excellent Frameworks is putting their pre-made frames ON SALE - all shapes, styles and sizes! Do you have paintings, posters, photos that deserve framing but you just haven't got to it? NOW's the time, great prices and wonderful quality from Excellent Frameworks. Just one day - Sat. July 16, all day
Massive Framing Sidewalk Sale at Excellent Frameworks
Sat. July 16
28 Station St. | firstname.lastname@example.org
Read about Excellent Frameworks' first Group Show & more in their newsletter.
Antique Truck Show at BC Forest Discovery Centre All Wkend July 16 - 17 Reduced Admission
The Antique Truck Show comes to the BC Forest Discovery Centre this weekend, running all day Sat. and Sun. Just pay your admission once on Sat., and attend free on Sunday. Just $10 for adults, $8 for senior & children, Kids under 2 yr. are Free. Enjoy the eclectic collection of trucks, and catch a ride on the steam train too. Open 10 am - 4:30 pm both days.
Antique Truck Show at the BC Forest Discovery Ctr.
Sat. July 16 & Sun. July 17, 10 am - 4 pm
Trans Canada Hwy & Bell McKinnon Rd.
Single Admission covers both days: $10 Adults | $8 for Senior & Children | Kids under 2 yr. FREE
Rotary Club Summer Festival Pancake Breakfast - TOMORROW July 16
Start your day in Downtown Duncan with a Pancake Breakfast brought to you by the Rotary Club of Duncan. It's all you can eat, so be sure to arrive hungry. Adults $7, kids 10 & under $5. Look for tables stacked with steaming pancakes on Craig Street, in front of Just Jake's. Then stay downtown for the Farmers Market and more Festival fun.
Rotary Club Pancake Breakfast
Sat. July 16, 8 - 11 am
on Craig's Street by Just Jake's
$7 Adults | $5 Kids 10 and Under
All you can eat!
Tourism Association of Vancouver Island - Nominations for Board of Director Deadline July 18
If you are a stakeholder with the Tourism Association of Vancouver Island, you can nominate or stand for election to the Board. Nominations close July 18/16 at 12:59 pm. Follow the links for more information and to register.
Forms, Criteria, Corporate Docs, Business Plan & Background Information
Current Stakeholders
Become a Stakeholder
Hilary's Cheese Co Sunset Wine & Cheese Cruise - Every Fri. & Sat. July & Aug.
Join the Hilary's Cheese team for a very special wine and cheese evening the water. You'll enjoy a curated wine selection with perfect pairings of gourmet cheese. Along with the view and ambience, you'll enjoy an educational chat about the pairings. The Sunset Wine & Cheese Cruise departs every Fri. and Sat. evening throughout the summer. Meet at Hilary's Cheese Co. at 7:30 pm, cruise 8 - 9 pm.
Hilary's Cheese Co. Sunset Wine & Cheese Cruise
Fri. & Sat. Evenings in July & Aug., 7:30 - 9 pm
Mt. at Hilary's at 7:30 pm: 1725 Cowichan Bay Rd.
$50 | Payment only processed once cruise minimum number confirmed
100% Refund & Notice in case of inclement weather
Call to reserve: 250.748.5992
Jeanne Ross Retirement Event - July 19
Jeanne Ross, Manager of our neighbour Chemainus of Chamber of Commerce, is retiring. The Chemainus Chamber is hosting a wine and cheese event to on Tuesday, July 19th, from 5 to 7 pm to thank Jeanne for her commitment to the Chamber.
Chemainus & District Chamber - Jeanne Ross Retirement
Tues. July 19, 5 - 7 pm
102 - 9799 Waterwheel Crescent
WorksafeBC Employer Rate Consultation Session
The WorkSafeBC senior executive team travels the province annually, to talk with employers about WorkSafeBC’s insurance rates for the coming year. They will provide an overview of the proposed rates for 2017 and outline injury trends in British Columbia. There will also advise employers about reducing injuries, and claim costs and insurance rates. The WorksafeBC health and safety teams will also be on hand to answer questions about injury prevention, and provide resources to help employers protect their workers. The Island session is in Nanaimo on July 21.
WorksafeBC Employer Rate Consultation Session
Thurs. July 21, 1 - 11 am
Coast Bastion, 11 Bastion St., Nanaimo
Online Registration | 604.247/7333 | email@example.com
This Just In …
Vancouver Island Economic Alliance Announces Sharing Economy Panel for Oct. Summit
The sharing economy is on the rise. Driven by rapid technological, economic and social change, this form of collaborative consumption is a peer-to-peer based sharing of access to goods and services coordinated through community based online services. These digital services are disrupting established business models at an accelerated rate in virtually every industry, leaving traditional service providers threatened and government regulations lagging behind. What does this mean for the Vancouver Island economy? Expert panelists: Fez Rismani, Barbara Gray and Walt Judas
State of the Island Summit
Early Bird Registration Until Aug. 1
Tickets Now On Sale for United Way Kick Off Breakfast – Sept. 8
The annual United Way Kick Off Breakfast is Thurs. Sept. 8th at the Duncan Ramada, 7 am. This year’s theme is Together We Are Possibility. We need your help to raise funds for 82 effective, local programs. There will be a breakfast buffet, 50/50 tickets, the opportunity to learn more about United Way, networking and more.
United Way Cowichan - Kick Off Breakfast
Sept. 8, 7 am
Tickets are on sale now, click here to reserve your spot today! | 250-748-1312
Unable to attend the event? Sponsor a ticket for one of our funded program participants
Shape the Future Tourism in Cowichan
The Tourism Society is holding a workshop for tourism business, operators and organization to provide input on regional destination marketing.
• Explore the Destination BC brand and learn how our region can benefit
• Help shape a profile of the kinds of visitor that Cowichan wants to attract
• Provide input on a vision for Cowichan as a preferred destination
Destination Marketing for Cowichan - Workshop
Tues. Aug. 2, 1 pm 5 pm
Merridale, 1230 Merridale Rd.
RSVP: 250-510-5586 | firstname.lastname@example.org
BDC Request Business Input on Productivity & Efficiency – TODAY
BDC is conducting this study to gain insight into how private sector companies measure and benchmark productivity and efficiency. Complete the survey today (it only takes 8 minutes!), and you’ll get access to BDC’s upcoming productivity benchmarking tool in October.
Productivity & Efficiency Survey - Deadline TODAY
Duration: about 8 minutes
Webinar: Accessing the BC Job Grant to Build Employees Skills July 28
Find out how the BC Job Grant can help offset the cost of skills training and professional development for your employees. Businesses may be eligible for up to $10,000 per employee in grant funding or $15,000 when hiring an unemployed person.
The Webinar covers:
- Program eligibility criteria for employers, participants, trainers and courses
- Training and learning options, and which types of training are covered
- Application and reimbursement process
- Developing learning goals for your organization and training plans for your employees
**Building Employee Skills with the Canada BC Job Grant - Webinar**
Thurs. July 28, 10:30 am - Noon
FREE
[Register online here](#) or contact [email@example.com](mailto:firstname.lastname@example.org)
**Case Savings on Mix & Match Wines from Deol Vineyard**
Save 20% whenever you purchase wine by the case at Deol Vineyard. Or, if you'd rather mix & match when you buy 12 bottles, you save 15% on each bottle. Deol has 9 wines to choose from to make a case that's perfect for you!
**Deol Vineyard**
Open Wed. through Sun. 11 am - 5 pm
6645 Somenos Rd.
250-746-3967 | [email@example.com](mailto:firstname.lastname@example.org)
**MNP’s Chris Duncan Pens Feature Series in Truck Logger BC**
MNP Business Advisor Chris Duncan has written a four-part feature in the Business Matters section called *Cracking the Rate Model*. See this month's [Truck Logger BC](#) for the first installment. The article, *Depreciation & Amortization: The Forgotten Piece* is also available online.
**Depreciation & Amortization: The Forgotten Piece**
1st in a 4 part series by
Chris Duncan of MNP LLP
[email@example.com](mailto:firstname.lastname@example.org) | 250.748.3761
Chris Duncan, CPA, CA is a Forestry Services Business Advisor for MNP LLP
**Volunteer for Portals - Reception & Other Opportunities**
Do you enjoy greeting the public? Do you have a passion for the arts? Then becoming a PORTALS Host might be for you! Hosts have the opportunity to welcome the public, explain art exhibits or programs and help visitors make purchases. Weekly shifts are 2 to 3 hours long. Training is provided. Other volunteer positions available as well. Let us know what your interests are, and Portals will work to provide you with a position that fits your needs.
Portals - Volunteer Opportunities
For more information contact Dee Kinnee: 250.746.1633 or [e-mail](mailto:).
**Cowichan Chiropractic Job Posting - Part Time Receptionist**
Cowichan Chiropractic is looking for a receptionist to work Monday, Wednesdays and Fridays starting the first week of September. Training to start in August. The winning candidate will have the opportunity to expand their responsibilities and their wage. Please drop resumes and a handwritten cover letter to Cowichan Chiropractic during business hours.
Cowichan Chiropractic
#204-225 Canada Ave, Duncan,
Deadline to Apply: Tues. Aug. 2, 5 pm
**Job Opening at Canadian Haz-Mat Environmental - South Island**
Canadian Haz-Mat Environmental is looking for individuals who are experienced in asbestos abatement and would like an opportunity to further develop themselves within a fast growing company. [Click here for the complete posting.](#)
Canadian HAZ-MAT Environmental
Member News
**Agriculture Entrepreneurial Accelerator Program**
BC FoodWorks will help agrifood entrepreneurs accelerate their growth, creating new jobs and revenue and contributing to the growth of the province's Food Processing sector. Our emphasis is on rapid growth and successful product launch. BC FoodWorks is an Agriculture Entrepreneurial Accelerator Program which provides business training, advice, and support to eligible individuals who have the desire and determination to accelerate their business with a fully written, well researched and viable business plan. If you have a new product, are entering a new market and/or are encountering unexpected growth and would benefit from expert business training and support, BC FoodWorks can help position you for success.
Details and application online at: [BC FoodWorks Program](http://bcfoodworks.ethoscmg.com)
250.741.8116 Ext 21 | [email@example.com](mailto:firstname.lastname@example.org) | [email@example.com](mailto:firstname.lastname@example.org)
---
**Damali Lavender & Winery 9th Annual Lavenderfest - July 23 - And Summer Hours**
Damali is now open 7 days a week, 11 am - 4 pm - with extended hours for their Lavenderfest on July 23, 10 am - 4 pm. Indulge your senses at Damali’s Lavenderfest on Sat. July 23.
- Scents: Lavender uses, Live demos, crafts, U-pick lavender
- Flavours: Wine tasting, Food truck, Wine garden, Lavender ice cream
- Experiences: Live music, Marketplace, Wander the farm, Labyrinth
**Damali Lavender & Winery’s 9th Annual Lavenderfest**
Sat. July 23, 10 am - 4 pm
Regular Summer Hours are: 11 am - 4 pm 7 days a week
3500 Telegraph Rd.
$7 Adults | Seniors $5 | Kids 12 & Under FREE
250.743.4100 | [email@example.com](mailto:firstname.lastname@example.org)
All parking in lower field, off Telegraph Rd.
*Please note: limited wheelchair access*
---
**Summer Safety from St. John Ambulance**
St. John Ambulance has these tips to help you get SET for a safe summer:
1. **Learn first aid and CPR.** Whether you need basic training or something more extensive to care for your community, we have various options to get you set.
2. **Pack a Sport Kit when you’re on the go.** This portable kit is a winning way for you and your family to stay safe while at play.
3. **Get SET™ for an emergency with an Emergency Preparedness kit.** With kits for all places and all ages, we have you covered.
[St. John Ambulance - Get Set for Safety](http://www.stjohnambulance.ca)
---
**Summer at Resthouse - Summer Pillow Sale & Enter the BIG Raffle**
The Summer Pillow Sale at Resthouse Sleep Solutions is back by popular demand, and runs through July & August. Buy any organic head pillow or body pillow, and receive the second at 50% off (based on the pillow of lesser value). And you can enter Downtown Duncan’s [Big Raffle](http://www.downtownduncan.com/big-raffle) to win a Serenity mattress from Resthouse, with a Rocca Western Maple bed frame from Alternative Woodworks. Enter at participating stores in Downtown Duncan.
[Resthouse Sleep Solutions](http://www.resthousesleepsolutions.com)
Tourism Vancouver Island 53 Annual Conference Ucluelet Oct. 4 - 6
Early Bird pricing is available for the annual Tourism Vancouver Island Conference until Sept. 15/16. The Conference is in Ucluelet, Oct. 4 - 6. Follow the link for details and to register.
Tourism Vancouver Island Annual Conference
Ucluelet, Oct. 4 - 6/16
Early Bird Savings until Sept. 15/16
2017 Canadian Business Excellence Awards - Applications Open
Canada Excellence Award Applications are now being accepted for the 2017 Canadian Business Excellence Awards for Private Businesses. This national award recognises businesses from all industries for their ability to earn the loyalty and satisfaction of their customers, employees and other stakeholders. To be eligible to apply, businesses must be privately-held companies operating in Canada that have been business for at least three years and have more than $1 million in revenue. Details here.
Hilary's Cheese Co. - Job Opening
Hilary's Cheese Co. is looking for a vibrant, outgoing, quick-study individual to staff our Wine Tasting Bar, and present wines from TWO of the best known Cowichan Valley wineries. Each winery provides full, in-depth training. This is an immediate need-to-fill position. Hilary's Cheese Co. has a professional, fun and easy going crew offering the best Customer Service and some of the best Cheese varieties in the world. Please email cover letter and resume to: Sonja Todd: email@example.com
Hilary's Cheese Co.
firstname.lastname@example.org
Amazing Video
Definitely had days like this ... :)
https://youtu.be/gca0goOZ8wg
Submit Your Member News
The Chamber eNews is disseminated to the business community every Friday and carries Chamber and Member news. Please send your news to email@example.com by noon on Thurs. for the Fri. eNews. Fifty word maximum, voiced in 3rd person. Please be sure to include date, time, location, and price as appropriate. We include links, contact information & social media. Items may be edited for brevity & clarity. Images should be suitable for thumbnail size. Items run for 3 - 4 weeks.
Duncan Cowichan Chamber of Commerce
2896 Drinkwater Road
Duncan, BC V9L 6C2
E: firstname.lastname@example.org | T: 250.748.1111 | F: 250.746.8222
Duncan Cowichan Chamber of Commerce | 2896 Drinkwater Road | Duncan | BC | V9L 6C2 | Canada
|
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