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Friday, August 26, 2016

Another Biotech Apple That Can Help Change The Conversation About "GMO Crops"

A picture of the Arctic Granny that appeared in a great article in the trade magazine, Growing Produce last year.

Non-browning apples and potatoes are part of a second wave of biotech crop improvements which I believe will change the public conversation about "GMO crops" in a positive way.  A third Arctic Apple cultivar (Fuji) is currently going through the USDA deregulation step which will open the way for commercial production over the next few years.  Apparently the public comments to USDA have been overwhelmingly positive.  I decided to add my own comment because I've had the opportunity to meet the great folks at Okanagan Specialty Fruits who developed these apples, and the folks at Intrexon who are supporting the commercial phase.  I am very impressed with what they have accomplished and the plans they have for bringing these great products to consumers.

I've copied below the text of the comment I submitted to USDA today.  If you would like to comment you can do so at this link:

My Comment to USDA About The Arctic Fuji, Non-Browning Apple

"I am writing in full support of this particular deregulation of the Arctic Fuji apple.  I do this as an agricultural scientist, as a long-term observer of crop biotechnology (40 years), as a consumer, and as a grandfather.  USDA-APHIS is completely justified in concluding that this RNAi-based, non-browning trait represents no "plant pest issues" so that commercial planting can proceed.  The "genetic contamination" issue that is sometimes raised is meaningless for a crop like apples that is never grown from seed but which is vegetatively propagated and which is commonly pollinated with crab apple.  Pollen movement presents no problems for apple growers or for consumers.  As a plant pathologist I concur with the conclusion from field tests which indicate that the trait has no effect, positive or negative, on the pest resistance profile of apples.

What this trait does provide is a combination of food waste reduction and opportunities for desirable consumer options such as full flavor and aroma sliced apples, no-sulfite dried apples and, use in smoothies etc.  I've tasted examples of all these uses with previous cultivars and can highly recommend them to my fellow consumers.

I have had the opportunity to share a box of a previously deregulated cultivar, Golden Delicious, with friends at a pot luck dinner last November.  I offered slices that had been prepared 4 hours before the event and showed how they were still white and aromatic while the conventional slices were browned to the point that no one wanted to take more than one comparison taste.  The non-browning Arctic apples truly "changed the conversation about GMOs" because it was a concrete example of how biotechnology can provide a meaningful consumer trait.  As Fuji is my favorite apple variety I am particularly enthused about being able to buy and share this next cultivar when the production is ramped up.  As many children do, my grand daughter loves apples, and I see this product as a way to further encourage that healthy inclination.

I fully realize that some of our international trading partners have irrational and problematic attitudes about biotech crops, but with a fully "identity preserved" crop like apples, there should not be a risk to our export business.  I am confident in the plan that OSF and Intrexon have for stewarding the main sliced product line and the co-product lines.  I believe that a timely deregulation of this and subsequent cultivars will send the appropriate message to the global market for apples.

Finally, I believe that this trait demonstrates that even a small commercial entity can navigate both the technological and regulatory path to biotech product development.  The vast majority of the work even with this cultivar was done by a company with around 8 employees!  While our system would benefit by some stream-lining and greater emphasis on product over process, this remains an important precedent.

So again, I want to express my whole-hearted support for this deregulation decision.

Steve Savage, Ph.D."

My grand daughter holding a Fuji apple she picked in
my yard a couple of years ago (unfortunately the browning kind)
You are welcome to comment here and/or to email me at

Monday, June 13, 2016

The Non-GMO Food Label Is A Lie

(This post originally appeared on Forbes 6/11/16)
You may have noticed more and more food items being marketed as “Non-GMO Certified.” As Americans, we are familiar with food being sold for what it is not, so we don’t think much about the fundamental absurdity of this new labeling.
After decades of being sold “non-fat,” “zero cholesterol” or more recently “gluten-free,” this looks like just one more marketing claim. In fact, the non-GMO label is fundamentally different because it is based on an entirely false assumption.
The truth is, virtually all the foods we eat have been “genetically modified,” and often in dramatic ways. The widespread belief that our food still resembles what our ancestors domesticated out of “nature” is only a demonstration of how little we understand history and science. However, the Princess Bride meme above is pertinent, because this new appeal to our ignorance is definitely coming from “someone who is selling something.”
How some crops looked before they were domesticated.  Lots of genetic modification involved, just not understood when it was done

Recently, I saw an ad in a trade magazine that compelled me to go tilt with the windmill that is “non-GMO” labeling. The ad was promoting the potential “Texas-Sized Sales” of bags of Sweet Scarlett’s grapefruits. I love those grapefruits. They are tasty and sweet, a beautiful red color, and seedless. I’m happy that my favorite stores carry this excellent product. But at the bottom of this particular ad, I noticed the logo declaring that these are “Non-GMO Project Verified.” That crossed a line for me.

These delicious grapefruit varieties are a textbook example of how crops were genetically modified back in the 1960s and '70s using a method called “mutagenesis breeding.” Basically, seeds (or in this case pieces of budwood) were exposed to gamma radiation in substantial doses, and then sifted through to find ones with mutations to their DNA that had desirable qualities. You don’t get much more “genetically modified” than that! That positive plant breeding story could certainly be made to sound scary in terms of unintended consequences, but in fact, thousands of modern plant varieties were modified this way. To date there is no track record of bad effects on consumers. There are now far more precise and controlled ways to genetically modify crops, but only certain new methods have been singled out for opposition as “GMOs,” while clumsy old methods, like mutagenesis breeding, escape this demonization.

So my problem with calling these grapefruits “non-GMO” is simple. These fruits are absolutely “genetically modified." To call this product non-GMO is a lie. That is true for most other non-GMO labels. These are also lies that dovetail with another long-term lie that has been widely disseminated in the Internet age - a “lie with pictures.” I'm talking about the widely used, stock-photo images illustrate of ready to eat fruits and vegetables stuck full of large hypodermic needles that are used in campaigns against “GMO food” Those images bear absolutely no resemblance to how plants are genetically engineered, but they are a powerful lie that has been quite effectively used to manipulate consumers.
What is truly disappointing is that the non-GMO “labeling lie,” and its inevitable connection to the photo-lie, is officially sanctioned by the very federal agency charged with truth in labeling for foods. In its guidance document on the subject, the FDA says that while it “prefers” more accurate wording on labels, it “will not pursue enforcement actions” with regard to the use of the “non-GMO” terminology. Thanks for protecting us from inaccurate labeling, FDA.

The disease that threatens these grapefruits and all citrus is already in Texas

There is another reason that this particular kind of disinformation is a problem. The grapefruit farmers in Texas are facing a threat that is common to all citrus growers. Already, an exotic bacterial disease spread by a newly introduced insect (Asian Citrus Psyllid) has destroyed half of the oranges in Florida. The pathogen and vector have already made it to many other states, including Texas and California, and even with intensive efforts to contain the threat, it is probably only a matter of time before other citrus crops go into decline. For me, this intensifies the absurdity of marketing a very much “genetically modified” crop as non-GMO, because one of the best hopes for saving citrus crops is through modern genetic engineering – the kind where you actually know what you are doing to the genes. How will the marketers then back-track on their implicit message that “GMO” is a bad thing? Most likely the bacteria will win and the farmers and consumers will lose.
I have spent a vast amount of my own time over the last seven years writing blogs and articles defending modern agriculture against disinformation. I have great respect for the farmers who produce our food and for companies like Wonderful Citrus who clean, pack and ship that food to consumers. Thus, I’m uncomfortable calling out this and other food/produce companies who have jumped on the non-GMO labeling train. Even so, I feel compelled to do that, not just in the case of this “Texas Sized” lie, but also across the board. I challenge the food industry to reject this kind of marketing even if it is FDA sanctioned and highly appealing to your marketing folks. I’ll leave you with another thought that has been well articulated by “the Dread Pirate Robert.”

You are welcome to comment here and/or to email me at  I have tried to contact the marketing company for these grapefruits and have gotten no response.  I have contacted the non-GMO certification group, but they have yet to put me in contact with anyone willing to discuss the science related to their certification of this or other crops.  I don't know who to talk to at the FDA about this. If you know a good contact there, please let me know.

Thursday, June 2, 2016

Enjoying Genetically Modified Beauty

Just a few of the uniquely shaped and colored flowers on display at the nursery
(This post originally appeared on Forbes on 6/2/16)

On Memorial Day my sister and brother-in-law took me to visit an extraordinary commercial nursery West of Chicago called “The Planter’s Pallet.” There I saw a huge and diverse collection of ornamental species and varieties destined to grace the yards and gardens of local plant lovers. I was inspired both by the astonishing range of form that nature provides, but also by the co-creative role of mankind in amplifying that diversity in ways that appeal to our human enjoyment of color, shape, texture, aroma and even sense of humor. As someone who often wrestles with weighty questions like the role of “GMOs” in the future of the food supply, it was a delight and a relief to be reminded that humanity has a long tradition of tapping into, and “messing with” nature’s diverse offerings – in this case for purely esthetic enjoyment.

It wasn't just about color.  Shape and texture can be interesting as well.

None of the beautiful and interesting specimens I saw in that nursery today had been “genetically engineered” using the tools of transgenesis that were first developed in the 1980s, but most of the examples had certainly been “genetically modified” using a variety of other, “conventional” methods, resulting in far more dramatic changes at the DNA level – changes that no one has probably ever even tried to document. I doubt that some of these plants would even survive on their own for long under natural competition and stresses without human care. They won’t need to. I’m quite sure that none have been safety tested in any way or scrutinized for their potential to become invasive weeds. No one was asked to justify why many of the varieties are patented or sold under exclusive brands. Indeed - this delightful nursery seemed to be “controversy free.”

I certainly wouldn’t want to see these examples of genetic modification become controversial. I’m just glad to have been able to enjoy and celebrate these beautiful, desirable examples of the synergy between long-term evolutionary diversification and relatively recent human ingenuity. Genetic modification can certainly be fun and beautiful.
I'll be doing a series on this topic to talk about other examples of how we humans have done many creative and useful things via genetic change.

As always you are welcome to comment here and/or to email me at

Saturday, April 30, 2016

Pests Bugging You? You're Not Alone

Some of the pests you would rather not find around the home

(This article originally appeared on Forbes 4/29/16

April has been declared “National Pest Control Month,” so this is a good time to talk about one of those annoying realities of life – pests! Pests are something you will deal with whether you are a farmer, an organic farmer, a gardener, a home-owner, an apartment dweller, a hotelier, a restaurant owner or just about any other role. Sometimes they just a nuisance.  Sometimes there are real health issues. As I’ve written before, pests are simply part of the natural order, and they even plague plants growing in the most pristine wilderness areas.
The question isn’t whether we have to deal with pests. It's only how. I’d like to talk about a few statistics I’ve come across that give us a window on how we are all dealing with our pest challenges – particularly the 98+% of us who are not farmers.
Perhaps fittingly, as I sit down to write this post, I’ve just had to deal with three kinds of pests in my own suburban yard. I found some mosquito larvae swimming in a bit of standing water from a recent rain. In the age of Zika virus, that was definitely not OK! I then pulled some of endless weeds that somehow defeat my mulching efforts. Then I had to fish a dead gopher out of the pool. The critter has been mining my back yard and garden, so I can’t say that I was sad about its demise.
Pests I found in my yard just today
One good indicator of the reality of pests is a quick look down the pest control product aisle at your local hardware or garden store. One source projects that the US home and garden pest control market is on track to reach $2.4 billion by 2020 growing at 3% per year. Obviously, many take a DIY approach to at least some pest problems.

There is also a large, professional, pest control sector. We can get some feel for the scale of that industry from a trade association web page that lists the top 100 such companies in North America. The list includes 11 companies over with over $100MM in revenues in 2014, and 54 more with at least $10MM.

An interesting window on professional
pest control activity
One indication of the level of activity in the pest control business is given in some information shared for Pest Control Month by a company called Fleetmatics. They provide fleet tracking technology for many service sector businesses – the focus being efficient deployment and routing of vehicles and manpower. Their data shows that the pest control business is particularly busy. The 5,500 pest control vehicles they track made 11.5 million customer stops in 2015, averaging 10 stops per vehicle per day.  Apparently, that is 37% more stops than for other service-based fleets (e.g. plumbers, electricians, internet service providers…).  During the peak, summer season, the average stops/day frequently tops 13. At least for this company’s clients, the states with most pest control activity are spread broadly across the US. The top 10 states are shown on the infographic, but no state gets a pass from pests!
Fleetmatics put me in touch with Tyler Helton who runs a company in California called Knock Em Out Pest Control.

I learned several interesting things from Tyler:
  • A majority of professional pest control customers are homeowners (60-65%), many are property managers or rental owners, and the remainder include restaurants, schools etc.

  • The service calls are about evenly split between scheduled service visits and emergency/issue-driven requests.

  • Rodents (rats and mice) are the biggest single pest driver, at least for this company, but bedbugs are an increasingly important issue. A company’s ability to deal with them is a differentiator in the market.

  • The professional pest control business is growing, and smaller players are definitely able to make in-roads in the market.

Obviously, pesticides are a key part of the solution for these problems, but as in agriculture, they are only one part of an integrated system that includes several other tools (one of my most-read blog posts is titled “5 Ways That Farmers Control Pests Other Than Pesticides”).

For homes and businesses, the expert identification and blocking of entry points is an important strategy. Repellants are an attractive option. Trapping technologies are very important as a way to avoid unwanted exposure of people or pets to toxic agents. Traps are also widely used as a way to detect a new infestation so that it can be dealt with early before it becomes a big problem. One state-of-the-art approach is traps that can communicate back to the control company (e.g. via SMS) so that those busy service vans can be even more efficiently deployed.

One reason to talk about this annoying issue of pests is specifically to acknowledge that it is part of our common experience and something we need to address as best we can and without stigma. I recently heard a lecture about bedbug issues in schools while attending the 2016 Conference for the New Jersey Environmental Health Association.  Apparently bedbugs are quite proficient at traveling between homes and schools by hitching rides on kid’s backpacks. The speaker strongly emphasized  the importance of not stigmatizing the finding of these pests because their presence has no reflection on the cleanliness of a home. If a family discovers bedbugs, the best thing is to immediately inform the whole class so that other families can check for infestations. So with that example, I’ll leave you with the following advice from once my favorite characters, Wesley.

Specifically not "as you wish"

Tuesday, March 29, 2016

Vermont-Driven GMO Labeling Could Have Troubling Unintended Consequences

This small state may soon alter the food supply for all Americans

(This post originally appeared on Forbes on 3/26/16)

Over the past week and a half, Mars, General Mills, ConAgra Foods and Kellogg announced that they had decided to start labeling whether their products contain GMOs nationwide, in compliance with a pending Vermont statute. They see this as a way to avoid the cost of maintaining multiple systems for different states.

These companies clearly state that they agree with the scientific consensus that there are no safety issues with biotechnology as it has been applied to crops. Nonetheless, many observers believe that the ultimate impact of the Vermont labeling law will be to encourage companies to seek to use more non-GMO ingredients. That would, of course, be a major victory for the organizations that have promoted labeling and who are actually quite transparent about their agenda of eliminating use of the technology all together.

However this scenario plays out, there are three interesting questions to consider.
  1. Why do so many consumers say they want GMO labeling?
  2. Why was anyone against labeling in the first place?
  3. What might be the long-term effects of this labeling requirement on our food supply?

Why do so many consumers say they want GMO labeling?

This has much to do with how you ask the question.  The term "GMO" is a misleading title made up by anti-GMO activists in Europe in the mid 1990s.  It stands for "Genetically Modified Organism," which isn't a very good term to use since virtually every crop and animal used for food today has had its genetics dramatically modified from what ever it once was in the wild.  However, since few consumers realize this, the term "GMO" has the negative emotive effect that was intended.

The genetic modifications of these plants were vastly 
more dramatic than any modern “GMO crop”

If you use emotive language to ask people about other scary-sounding foods, you can get the same reaction. I've asked many people, "do you think cloned fruit should be labeled?" Virtually everyone says "yes!" Then I explain that all fruit is "cloned" in the sense that it is vegetatively propagated by budding or from cuttings because if you grew it from seed you wouldn't get the same variety. People have been doing this for millennia, but if I use the emotive term "cloned" I can get a "label it" response.

I also sometimes ask, "do you think that food grown with products made from animal excrement should be labeled?"  Most people again say "yes" because I used an emotive term. In that case there is a small, but finite food safety risk associated with manures and composts, but we don't label it.

In any case, after 20 years of active efforts to create fear around plant biotechnology, the label is nearly guaranteed to be seen as a negative by many consumers. Again, that is exactly what certain parties hope.

Why was anyone against labeling in the first place?

On the surface this seems like a logical question, but there were rational reasons to oppose these labels. The FDA wants to reserve the exercise of its labeling authority for things with real, documented risk issues such as food allergies, not for something like biotech crops for which extensive studies show no unique risk.  Realistically, this has become a moot point. By allowing "non-GMO" and "GMO-free" labels, consumers are already being successfully recruited to buy this next example of "non-existence" food, following trends like "gluten-free," "fat-free," "zero cholesterol" and the like.  American consumers are so used to buying food for what it is not that we don't even see the absurdity.

Much of the non-GMO labeling is for products
from crops which have no commercial biotech versions anyway

The reason that the processed food industry opposed labeling for biotech crops has to do with the costs and liabilities associated with maintaining distinct product flows in these very large scale, very low profit margin businesses. It costs money to clean out all the equipment, bins, trains and trucks used for bulk handling.
Grain harvesting equipment and later handling 
are not conducive to easy segregation

Depending on tolerances, it also opens companies up to liabilities for "adventitious presence.”  In the absence of real risk, the costs just don’t make sense. “Identity preservation” of high value crops like apples, oranges or wine grapes is far more feasible, and it is routinely done, but for issues that matter like variety, appellation etc.

What might be long-term effects of labeling on the food supply?

This really depends on whether food companies have the courage to trust their customers enough to continue to use biotech-improved items even in the face of activist pressure. Will they stand-up for their decision (as the Girl Scouts have), or will they give in and start shifting to non-GMO ingredients?

Evidence suggest that many players will take the latter path and that will mean asking farmers to forgo crop traits that they have found to be very helpful. Returning to non-biotech will also make it harder for farmers to use environmentally-sound approaches like minimum-tillage. It will increase the need to spray for insect pests once controlled by Bt traits in the crops. The cost of those non-GMO ingredients will be higher, partly because of these disadvantages, but also because of what it will take to "identity preserve" the non-GMO harvest all the way down the handling, storage and processing stream.

Of greater concern is the possibility that food companies will be tempted to source cheaper version of these non-GMO ingredients from other countries. This has happened all too often for organic.  That will open up the U.S. consumer to environmental pollutants (e.g. heavy metals) and to pesticides that have long been banned here, but which are still made and used in places like China and India.  It will also mean getting items from regions that are much less attuned to the need to detect and exclude dangerous mycotoxins from the food supply.

If Vermont ends up initiating a trend towards more non-GMO products, we should be asking participating food companies to go on record promising that they won't import the ingredients if they are available from the U.S. or other countries that enjoy a general context of sound environmental, food safety, and pesticide regulation. Without such assurances, we could have a serious case of unintended consequences.

You are welcome to comment here and/or to email me at

Tuesday, March 22, 2016

Why I Don't Buy Organic, And Why You Might Not Want To As Well

Some delicious, conventional Asian Pears

Originally Posted On Forbes 3/19
I don’t buy organic foods. In fact I specifically avoid doing so. It’s not my place to tell anyone else what to do, but I’d like to lay out three, seriously considered factors that have shaped my personal stance on organic:

  1. Informed confidence that we are safe buying “conventional” foods
  2. Recognizing that some of the best farming practices from an environmental perspective are not always allowed or practical under the organic rules
  3. An ethical problem with the tactics that some organic advocates and marketers employ which seriously misrepresents their “conventional” competition
For the last 40 years my wife and I have shared the shopping and cooking for our mostly home-based meals. We have always gardened, but also buy much of our fruit- and vegetable-rich diet from stores. When I say I don’t buy organic, that involves frequent decisions.

By all rights I should be an enthusiastic advocate and consumer of organic. I was a child of the generation influenced by “Silent Spring.” I was a dues-paying member of the Wilderness Society in high school. I grew up helping my beloved grandfather in his organic garden in the 1960s.  Some of our best friends in the late 1970s were pioneers in the development of the commercial organic industry. I’ve spent a significant proportion of my career developing biological and natural product-based pesticides which are applicable to organic. I fully appreciate the contribution that the organic movement made in the early 20th century when it highlighted the importance of fostering soil health. My problems with institutional organic are not at all about its founding ideals or about organic farmers, but rather about organic's self-imposed limitations and about the ethics of a sub-set of its promoters.

Confidence in the Conventional Food Supply
The USDA, which oversees the foods labeled as "Certified Organic", states quite clearly on its website about its role in organic,  that "Our regulations do not address food safety or nutrition."  Foods labelled "Certified Organic" must adhere to certain rules and regulations but aren't endowed with any particular nutritional or safety features. However, many consumers believe that the Organic label means the food has superior nutrition and is safer, especially in regard to pesticide residues.  This is not true. Studies have shown no appreciable difference in nutrition between crops grown either organically or conventionally.

As for the safety issue. When most people hear the word “pesticide,” they imagine something scary in terms of toxicity to humans and the environment. The reality is that modern agriculture employs an integrated suite of non-pesticidal control measures, and the actual pesticides used today are mostly relatively non-toxic to humans. Organic farmers also use pesticides, and the products they are allowed to use are constrained with few exceptions by whether they can be considered “natural.” That is not a safety standard since many of the most toxic chemicals known are “natural.” Like all pesticides, these natural options are subject to EPA scrutiny, and so the pesticides that organic farmers are allowed to use are “safe when used according to the label requirements” which is the same standard for synthetic pesticides allowed on conventional crops. When it comes to pesticide residues on our food, there is a USDA testing program that demonstrates year after year that the pesticide residues on both organic and conventional foods are at such low levels that we need not worry about them. I confidently buy non-organic foods based on this public data that demonstrates that our system is working and that we consumers are well-protected.
My granddaughter enjoying "conventional" raspberries (yes, she did then eat them)

What the USDA data demonstrates is that the environmental movement was not a failure - it effected real change over the past 5 decades! We don’t have a two-tiered food supply in terms of safety in which only those who can afford the premiums get safe food. I also believe the global scientific consensus that“GMO” foods are safe, and so I don’t need to buy organic to avoid those.
This No-Till Field is good for the environment and the food supply 
Environmental Idealism

I have always been concerned about the human impact on the environment, and particularly about the impact of farming since that industry has the largest “footprint” in terms of land area. I spend a lot of time reading the scientific literature concerning agriculture and the environment. Some of the farming practices that are commonly employed on organic farms are very positive from an environmental perspective, but those practices are also used by progressive “conventional” growers. There are also quite a few farming practices with excellent environmental profiles which are difficult to implement under the organic farming rules (e.g. no-till farming, spoon-feeding of nutrients via irrigation). Compost, which is a major input for organic farms, has a shockingly high “carbon footprint” because of methane emissions. The carbon footprint of “synthetic” fertilizer is much smaller.
From an environmental perspective, the biggest issue for organic is that it requires significantly more land to achieve the same level of production. Were organic to become more than a niche category, this yield gap would be highly problematic from an environmental point of view.  I would much rather buy food from "land-sparing" farmingsystems.

Organic yields are substantially lower for many major crops

Ethical Issues

My third reason for not buying organic has to do with ethics. Organic exists as a sort of “super brand” that transcends anyone marketing under that banner. Unfortunately, within the organic realm there are certain major marketers (and advocacy groups they fund) who employ fear-based and falsehood-based messages to demonize “conventional” foods.  They use these methods as a means to promote organic. One of the most egregious examples is the “Old McDonald/New McDonald” video funded by Only Organic – a consortium of very large organic marketers. This bizarre publicity piece exploits children to depict a completely distorted view of mainstream farming.  I consider it to be "hate speech for profit."

Another example is the organic-industry-funded Environmental Working Group which grossly distorts that transparent, USDA, public database documenting the safety of the food supply and turns it into a “dirty dozen list” designed to drive organic sales. These are extreme examples, but the organic marketing community as a whole quietly benefits from this sort of propaganda and does nothing to correct the “convenient fiction” that organic means no pesticides. I realize that only part of the organic industry funds and promotes the most vicious sort of disinformation, but I rarely see organic representatives standing up and objecting to the sort of fear-mongering that ultimately benefits the sales for the entire super-brand.

The fear-based messaging drives the intense social pressure, that parents in particular feel, about whether they need to buy organic. I don’t want any part in rewarding this sort of fear/shame-based marketing. In the absence of a significant objection from more of the organic community, I don't want to support the "super brand."

So, these are my reasons for not buying organic products. I feel perfectly comfortable buying the alternatives that align with my practical, idealistic and ethical standards.

Please feel free to comment here and/or to email me at