Our Voice

ALC Quarterly Update

The Agricultural Law Center team has been busy in the second quarter of 2018.  We’ve launched multi-episode video project Our Water Our Land, hired Anna Jordan to act as Policy and Outreach Coordinator, travelled to Cuba, prepared to host the 2018 SOIL Conference, and much more!

May

Director Neil Hamilton launched the weekly educational video series Our Water Our Land, which is now up to 19 episodes. The series is featured on Youtube, Facebook, and Twitter.

June

Hamilton and Assistant Director Jennifer Zwagerman spent five days in Cuba participating in the International Congress on Agrarian Law.  The conference was attended by over 90 lawyers from at least 15 nations. Hamilton was honored by the Cubans for his work in agricultural law and received an award from the Cuban Agrarian Law Society. Hamilton presented on the topic of “Feeding Our Future: Reflections on Forty Years of Agricultural Law in a Changing Agriculture,” which was then translated and published by journals in Cuba and Argentina.

July

Hamilton and Policy and Outreach Coordinator Anna Jordan continued drafting on new installments for the “Landowners Legal Guide” video series being funded with a grant from the USDA Natural Resources Conservation Service.

August

Hamilton spent several days at the University of Arkansas Law School in Fayetteville teaching the introductory class on food and agricultural law to the new LLM students.

Looking Forward

On September 19, the Center will sponsor SOIL 2018: Turning Our Vision for Iowa’s Water and Land in to Action, at the Olmsted Center.  The conference is the third in the series of SOIL – Sustaining Our Iowa Land conferences organized by the Center. To register, click here.

In October, Hamilton will visit Harvard Law School to take part in the First Annual Conference on Food Law and Policy, organized by the Academy of Food Law and Policy, for which he is a founding board member.  Later in October he and Assistant Director Jennifer Zwagerman, AALA President, will attend the American Agricultural Law Association conference in Portland, Oregon. Hamilton will participate on a panel on the topic of Sustainability in Agriculture: Legal & Policy Considerations for Economic and Community Development.

 

 

 

 

 

An Introduction from the Center’s Newest Staff Member–Anna Jordan

Greetings! I hope this post finds you enjoying a beautiful summer day. I am writing to introduce myself as the newest member of the Drake Agricultural Law Center staff. My name is Anna Jordan and I am excited to be working as the Center’s Policy & Outreach Coordinator! While my position with the Center is new, I am well acquainted with Drake Law School and the Agricultural Law Center—I recently graduated from Drake Law in December 2017, with certificates in Food & Agricultural Law, Public Service, and Environmental & Sustainability Law.

Raised on a farm near Centerville, Iowa, I have long had a love and appreciation for the land and the people it sustains. I took this passion to Iowa State University where I studied Agricultural Business and Economics. My personal and educational background in agriculture spurred an aspiration to gain a deeper understanding of the intricate agricultural and food systems of our world. I began to consider graduate and professional programs that would help achieve this ambition. I became impressed with the malleability of a legal education, and chose to attend Drake Law School based on the outstanding reputation of Agricultural Law Center and curriculum.

The education and experiences I gained while in law school exceeded my expectations. I learned legal fundamentals and had the opportunity to take classes such as agricultural law, environmental law, food law, and land tenure law. Working as an editorial staff member on the Drake Journal of Agricultural Law, I was challenged to develop my research and writing skills while writing a student note, which I am honored to have published in the Journal. Drake also provided an array of experiences outside of the classroom. I completed internships with the Iowa Natural Heritage Foundation, Iowa Legislature, and the Drake Agricultural Law Center. By hosting the Student Food Law Leadership Summit and supporting student attendance at the annual American Agricultural Law Association conferences, the Agricultural Law Center connected me with hundreds of food law students and agricultural law professionals from across the country.

The legal education, internships, and networking experiences from Drake give me confidence as I begin my professional career. I successfully passed the Iowa Bar Exam and was sworn in as an attorney in May. I and am eager to continue my journey with Drake and work with Professor Hamilton on producing and distributing important agricultural law resources!

All the best,

Anna

ALC to Issue Guide for Farmers and Landowners on Navigating Public Programs to Improve Water Quality

The Drake University Agricultural Law Center will release a new report “How to Improve Water Quality on Iowa Farms: A Step-by-Step Guide for Navigating Conservation Programs for Farmers and Landowners” next week. The 65-page report will be available for download from the Center’s web site at http://aglawcenter.wp.drake.edu/research/.

“Our goal is to make it easier for Iowa farmers and landowners to understand the public cost-sharing programs available to protect our soil and water,” said Professor Neil Hamilton, director of the Center. The Guide was developed under a 2017 grant from the Leopold Center at Iowa State University, which is now coordinated by the Iowa Nutrient Center.

Matt Russell, who helped create the Guide in his role as the Resilient Agriculture Coordinator with Drake, noted, “Iowa has a wide range of programs to assist those interested in putting conservation on the land, but being able to understand who administers the programs and the process for applying can be confusing.”

The Guide examines the programs in two ways: first, the discussion describes various conservation and water quality practices available—such as cover crops or installing grass waterway—and lists which federal or state agencies have financial assistance programs that can help support each practice. Secondly, the report takes a detailed look at federal and state conservation and water quality programs to explain how they actually work for interested farmers and landowners.

Popular federal efforts such as the Conservation Stewardship Program (CSP), the Environmental Quality Incentives Program (EQIP) and the Conservation Reserve Program (CRP) are explained in detail. Similarly, various state cost sharing programs such as the Water Quality Initiative, Financial Incentive Program for Soil Erosion Control, and the Iowa conservation practices revolving fund are explained, including how they are administered. The Guide uniquely features a set of common questions for each program, including who is eligible, how one applies, what documents are required, how selections are made, how practices are implemented, how payments happen, and how programs are enforced.

“If we expect farmers and landowners to use public programs to protect soil and water, we feel it is important to take the mystery out of how to actually apply to use them,” Hamilton said.

The Guide explains how many programs are delivered through the county Soil and Water Conservation Districts. It gives suggestions for working with the districts, especially the value of developing a personal relationship with the conservation professionals so an effective plan can be developed for a farm.

The final section of the Guide covers Private Conservation Initiatives. These are typically programs where a private business involved with food or agriculture works with farmers to implement a soil or water conservation project. The Guide is one of the first efforts to evaluate and discuss the potential these programs may have for providing additional support for soil and water conservation.  A case study of how one Iowa farm is using both public and private programs to improve soil health and water quality is used to demonstrate this potential.

For more information and to find other resources for farmers and landowners, visit http://aglawcenter.wp.drake.edu/research/

Farewell from Matt Russell

For the past six weeks, Pat and I have been trying to burn some pasture at our Coyote Run Farm. Finally, on Easter Sunday, we were able to get the job done.  The Easter holiday seemed like a terrible day to try to do this big job, but with good weather and family and friends coming together, burning off the dead prairie of last year and celebrating the new life that will poke out of the blackened earth turned out to be perfectly timed.

Just like burning the pasture brought an end and a new beginning, tomorrow marks the end of 12 years of working at the Drake University Agricultural Law Center and a new beginning as the Executive Director of Iowa Interfaith Power & Light. Iowa Interfaith Power & Light is a statewide organization mobilizing the religious community to become leaders in the movement for climate action. My new position combines my life’s work in faith, sustainability, public policy and agriculture with my passion for the value non-profits bring to individuals, communities and the greater good. My work and colleagues at Drake have prepared me well to lead efforts to find hopeful, empowering, unexpected solutions to the great challenges of climate change.

As I reflect on these years of serving farmers and landowners, I’m honored to have helped key agriculture stakeholders make profitable and sustainable decisions regarding our nation’s land and agricultural production alongside our director Neil Hamilton.

The list of interesting projects I got to work on is long and diverse.  Some of my favorites include exploring rural community ownership of grocery stores, coordinating Central Iowa’s Buy Fresh Buy Local campaign, developing a tool to help farmers craft fair manure management agreements, identifying opportunities for the state of Iowa to purchase more food from Iowa farmers, promoting food policy councils, educating landowners and farmers about crafting leases to put more conservation on farms and increasing agricultural opportunities for under-severed farmers.

I am proud that I was able to help Neil host more than a dozen statewide and national conferences.  We filmed and produced scores of videos. I was able to travel to Cuba—twice.  Whenever an opportunity came to go speak about agriculture, rural communities, or conservation, Neil’s response was always yes, and he always found the resources to make it possible for me to go.

After speaking at different events and writing many articles, including an article on agriculture and climate change for the Drake Journal of Agricultural Law, I am prepared for my last day tomorrow and my new career at Iowa Interfaith Power & Light.

I am fired up for the work ahead, because I believe we can solve climate change. Iowans can lead the world in finding the solutions, and Iowa farmers can innovate on our farms to sequester carbon and reduce emissions.

Looking back, I have so many fond memories of the exciting work and inspiring people at Drake.  Looking forward, I can see Drake Agricultural Law Center has prepared me well for this new leadership position.

ALC Quarterly Update

The Agricultural Law Center team has been busy in the first quarter of 2018.  We’ve traveled north of the Arctic Circle, spoken at numerous conferences, appeared in stories in multiple media outlets, screened a new documentary film and even hosted a former U.S. ambassador.

January

Associate Director Jennifer Zwagerman is quoted in an Event Driven article, BG/ADM: Soybean Crushing and Grain Handling Markets Raise Antitrust Questions on January 24.  She also spoke to Farm World about food safety and regulatory oversite.

In January, Resilient Agriculture Coordinator Matt Russell gave an interview to Harvest Public Media about the need for farmers to partner with others to ensure conservation, disaster assistance, and nutrition assistance are supported in the 2018 farm bill.

February

Director Neil Hamilton was a guest on Iowa Public Radio’s River to River on February 20.  The hour-long program explored the history of the Supplemental Nutrition Assistance Program (SNAP) and implications of implementing America’s Harvest Box.  He argued the proposed change to SNAP looks like a solution in search of a problem.

The Center collaborated with the Drake University College of Arts and Sciences on their 2018 Engaged Citizen Experience Conference, Nourishing the World, on Feb. 22-23.  Neil facilitated a panel discussion following the screening of the new film “Farmers for America.”

At the Engaged Citizen Conference, Matt invited Jennifer Terry, executive director of the Iowa Environmental Council, to help lead the breakout session “Iowa Agriculture Reality Check—Environmental Sustainability.”  Drake University alumna and former Ambassador Darci Vetter gave the keynote address.  She is a strategic consultant on International Trade and Agriculture, diplomat in residence at the University of Nebraska—Lincoln and the former chief agricultural negotiator for the Office of the U.S. Trade Representative.

March

Neil traveled near the North Pole to pay homage to thousands of years of agricultural development and a million seeds stored at the Global Seed Vault in Svalbard, Norway, on March 2.

“Being inside the Vault makes real the stories I have read,” Neil said. “It also brings a new appreciation and understanding of the work of many people – the plant collectors, the seed breeders, the farmers, and the gene bank officials who have collected, improved and saved these seeds.  One does not need to be a person of faith to feel a visit to the Vault is moving in a spiritual way.”

Matt spoke at the 9th Annual Feed Greater Des Moines conference about local food policy and advocacy on March 3.  He also spoke about working-land conservation programs, CSP and EQIP at the National Farmers Union convention in Kansas City on March 5.

Looking Forward

Our project, Guide on How to Improve Water Quality on Iowa Farms, will be published in the next month.

Stay up to date on all of our actions by liking us on Facebook!

A Visit to the Global Seed Vault: Part II

Once we reach the entrance to the Vault, we are met by the representative from NordGen, the gene bank of the five Nordic countries who operate the Vault and approved our visit.  Once the outer door closes, we are briefed in the vestibule.  Then, we enter through a second door leading to the 100-meter-long tunnel descending into the mountain. Through the tunnel, a third door brings us into the anteroom in front of the three 30′ by 90′ chambers carved out of rock.  Only the middle room is now in use, but its shelves are 85% full of deposits, so soon another room will be active.  In this room, we can see the actual frost and ice covered door leading into the Vault.  Once this door is secured behind us, the final door is opened and we enter the actual vault.  It is here that the nearly one million deposits are stored, boxed as originally received and prepared to NordGen’s exacting standards. Each box is labeled with the name of the owner, barcodes and other identifying information to keep track of the deposits.

It is only now as we stand in this small frigid space no larger than a classroom, does the magnitude of what it holds strike you.  Collected in this room are seeds gathered from around the world – and over the time of our existence – representing the food crops upon which our lives are formed. It is not the gold bullion of Ft. Knox or the priceless art works secreted away in a Swiss bank – instead, it is the simple seeds we plant.  They reflect the cumulative results of nature, evolution, and humans’ efforts to identify and improve our food crops.

Being in the presence of the seeds makes one think about not just the human history they contain, but the fragile nature of our very existence.  Walking the aisles you read the labels of the seed banks from every corner of the world.  We can’t see inside the boxes – even NordGen officials cannot open them.  But we know they are filled with envelopes, each holding 250-500 seeds of a distinct crop variety selected by a seed bank for safe keeping.  Over 150,000 varieties of rice and 160,000 of wheat join the thousands more representing over 150 food crops important to people somewhere.

Being inside the Vault makes real the stories I have read.  It also brings a new appreciation and understanding of the work of many people – the plant collectors, the seed breeders, the farmers, and the gene bank officials who have collected, improved, and saved these seeds.  One does not need to be a person of faith to feel a visit to the Vault is moving in a spiritual way.

Next week, the story of our visit will conclude with thoughts on what the Seed Vault may mean for the future of agriculture and humanity.

A Visit to the Global Seed Vault: Part I

Who visits Svalbard the Norwegian archipelago 600 miles north of the Arctic Circle?  In the 1800s, it was Russian walrus hunters and Dutch whalers.  In the 1900s, it was coal miners who left visible scars on the fragile landscape still visible in 2018. Today, those filling our plane from Tromsø on a blustery February day are adventure seekers, Norwegians visiting their most remote outpost and scientists staffing the research stations to study the effects of climate change on the polar ice.

But one other group makes the flight to Longyearbyen – representatives from the world’s seed banks: officials charged with safe guarding the genetic resources on which all human life depends.

Svalbard is home to the Global Seed Vault, perhaps the world’s most vital storehouse, the depository of our evolutionary history for food crops.  It began in the late 90s as an idea of Cary Fowler, a visionary scientist from Tennessee then working in Rome on international genetic protection.  Working with Norwegian counterparts, he helped bring into reality the dream of creating a secure seed storage vault deep inside a remote Arctic mountainside to serve as a depository for the seeds being held around the world in hundreds of national and international gene banks.

The Vault, opened in 2008, serves as the world’s genetic back-up – the place where depositors send duplicate sets of the seed varieties they store locally.  Today, the vault has received deposits of over 1 million distinct plant varieties representing a significant portion of the world’s food crops. Seeds have come from gene banks in over 100 nations, including thousands of varieties from USDA’s National Plant Germplasm System in Ft. Collins.

Iowans should be proud to know the only private non-governmental organization or NGO with the foresight to place seeds in Svalbard is our Seed Savers Exchange or SSE from Decorah.  As a long-time board member of SSE, it was a special thrill to receive Cary’s invitation to come to Svalbard as SSE made our latest deposit on the vault’s 10th anniversary.

Don’t mess with SNAP

In the 1980s, my brother, sister, and I participated in a federal nutrition program.  My parents scrambled to continue to farm.  Our bank had failed.  The family was in crisis.  I assumed I’d have to sell my horse and mule and move with my family to some far-off city.  Fortunately for my family, the Grapes of Wrath-type scenarios didn’t happen.

For numerous reasons, many of them stemming from farm bill policies, my family’s farm survived the 1980s farm crisis. Today, my brother and sister-in-law are farming with my parents on the farm where I grew up.  My husband and I own and operate our own farm.

One of the things that made a real difference for my family during the 1980s farm crisis was free school lunch.  Over the few years we participated, those free lunches freed up a couple thousand dollars.  My family spent that money on non-food necessities and much of it at local stores.

I’ll always remember our superintendent who encouraged families to sign up for free lunch. He said participate—it helps your family and also benefits the school.  His reasoning was something about a reimbursement formula. A lot of families from my hometown applied and used the program because we were all told it was the right thing to do. It was, and it still is.

Fast forward to 2018.  President Trump’s budget includes a radical proposal to remake the Supplemental Nutrition Assistance Program (SNAP), what used to be known as the food stamp program.  Termed “America’s Harvest Box,” the program would cut roughly half of SNAP dollars and replace them with a box of shelf-stable foods delivered to individuals and families participating in SNAP.  Secretary of Agriculture Sonny Perdue is now vigorously defending this proposal.

The Harvest Box contrasts the innovations in the SNAP program from the 2014 farm bill designed to incentivize eating more fruits and vegetables.  Our farm participates in Iowa’s Double Up Food Bucks to encourage SNAP participants to purchase fresh fruits and vegetables from local farmers.  The “Harvest Box” would remove the ability of SNAP beneficiaries to choose. They lose the opportunity to select healthier foods, purchase from farmers and retailers in their local community, and decide when and where to use the benefit as they need.  In lieu of the flexibility, SNAP families and individuals would see those opportunities slashed and replaced by a box of “shelf-stable milk, juice, grains, ready-eat cereals, pasta, peanut butter, beans, canned meat, poultry or fish, and canned fruits and vegetables”.

Neil Hamilton, director of the Agricultural Law Center, was a guest earlier this week on Iowa Public Radio’s River to River.  The hour-long program explored the history of SNAP and implications of implementing America’s Harvest Box.  Neil argued this proposed change to SNAP looks like a solution in search of a problem.

Kathie Obradovich devoted her political column in Monday’s Des Moines Register to the Harvest Box.  She claimed the proposal, if implemented, would have a spiraling downward effect on Iowa’s economy. Food prices would rise, Iowa retail sales would drop, and federal farm programs on which Iowa farmers depend would lose support.

To be fair, some of her criticism was sardonic. She said, “Everything I’ve read suggests Congress has as much interest in the Harvest Box as the average 5-year-old has in canned spinach.”

However, by mid-week, Politico’s Morning Ag reported that Secretary Perdue “has a message for all the ‘America’s Harvest Box’ haters: We’re serious. So serious that Perdue tells POLITICO that House Agriculture Committee Chairman Mike Conaway is open to considering a small-scale pilot of the program in the 2018 farm bill.”

As the politics of the policy development around the Harvest Box play out, there’s a very important message farmers need be sending to SNAP participants.

Thank you for using SNAP to help your family, for spending those benefits in your communities, and for responding to our commodity marketing campaigns by purchasing the food we raise such as our beef, milk, pork, poultry, produce, and grains.

For over half a century political forces interested in making sure all Americans have enough to eat and political forces interested in making sure American farmers are economically able to grow that food have joined forces in federal farm policy.  These proposed changes to SNAP threaten a coalition of urban and rural lawmakers working together to insure both goals.

My participation in a federal nutrition program is more the norm than the exception.  They are well-directed, efficient, good for families and local communities, and an excellent tool for helping families navigate a crisis like mine did.  Federal nutrition programs also provide effective and efficient services to those with chronic needs like the disabled and elderly.  America’s Harvest Box seems to fall short on every measure of good government.  But maybe that’s the real point of the proposal: to undermine the effectiveness of a good government program.

As a farmer, when the going gets tough, I have depended on government programs. They’ve helped me throughout my entire life, from free school lunches as a farm boy in the 1980s to the Livestock Forage Program (LFP) during the Iowa drought last summer.  As a farmer, I am well served standing with fellow Americans using SNAP. As a farmer, I must not stay silent while political forces redesign one of the most popular and efficient government programs to become less effective and less beneficial to the people it is supposed to serve.

 

Farmers Claim Cost of Health Insurance Most Serious Threat

You might not realize health care is a critical issue for farmers if you have only been reading the agriculture press headlines this year. Tax reform—especially the estate tax, Waters of the United States (WOTUS), and trade policy remained in the limelight for the duration of Trump’s first year in office.

However, according to a new study published by the Agricultural and Applied Economics Association, “65% of commercial farmers identified the cost of health insurance as the most serious threat to their farm, more significant than the cost of land, inputs, market conditions, or development pressure.”

With a majority of farmers finding the cost of insurance to be a serious threat to their livelihood, the agriculture industry needs to advocate for more affordable health care for farmers and rural communities.

Between 2015 and 2017, the researchers used case studies from 10 states and collected surveys from 1062 farming households.  Researchers found that about 90% of those involved in the study had health insurance, but the sources of insurance varied widely, even within the same household.

According to the study, the Affordable Care Act (ACA) broadened farming family insurance options since its inception in 2010.  The authors report about one out of five farmers in the study claimed ACA marketplace health insurance allowed them to enroll in health insurance for the first time.

The research included an example of a ranching family with five children who experienced how the ACA improved their access to healthcare. It said, “their three oldest children had never gone to the doctor because they had no health insurance. After the ACA implementation, the two younger children had preventative well-child visits and the family had access to a wider range of health services.”

According to the study, farmers can especially benefit from the ACA because the health care law uses income rather than assets to determine eligibility for Medicaid and market subsidies. As the Agricultural Law Center has pointed out in the past, the economic model for American agriculture incentivizes asset or wealth accumulation and discourages income generation.

The researchers point to a provision in the ACA, which “decouples the family from the assets of the enterprise and addresses the ‘land rich, cash poor’ conundrum farmers often face.”

This study suggests that farmers, like all Americans, continue to struggle with access to affordable health care. Almost three quarters of the participants in the study said they had a desire that the USDA “represent their unique needs in national health insurance policy discussions.” Hopefully those advocating for farmers and rural communities will read this report and pay attention to the findings.

Governor’s Water Quality Law Is Not Enough

The issue of water quality continues to increase in political importance.  Candidates, on both sides of the aisle, from areas rural and urban, are running on platforms of water quality.  Two Republicans, Craig Lang and Ray Gaesser, are currently running for Iowa Secretary of Agriculture focused on water quality and soil health.

Last November, Des Moines voters elected Josh Mandelbaum to the city council.  “Protecting Public Health and Standing Up for Water Quality” was one of the pillars of his campaign.

Governor Kim Reynolds set water quality as a high priority during her Condition of the State address last month.  On January 31, Reynolds signed SF 512 into law.  Clearly, Reynolds saw value in having the water quality bill be the first signed this session, thus making it the first law for her to sign as governor of Iowa.

SF 512 is projected to produce $270.2 million for water quality projects over the next 11 years, according to Iowa’s nonpartisan data agency.

According the Cedar Rapids Gazette, “The money will come from converting an existing sales tax on metered water to an excise tax and, as Vision Iowa bonds are repaid, using those funds, too.”

The water quality law will not generate new money for the state, which means under the law the state will fund water quality efforts by reducing money currently being used to fund other programs.

The level of water quality action does not appear to match its political attention. The state needs to address more questions, engage more interests, and leverage more money to attack the enormous problems with water quality in Iowa.

Several Iowa organizations argue the solution that has been signed into law is not adequate.  They claim Iowans expect more significant action on water quality.

  •  “Where are the voices of environment, habitat, conservation, watershed planning, public health and sustainable agriculture in this process and in this bill?”
    -Iowa Environmental Council Executive Director Jen Terry
  • “Senate File 512 represents a timid response to a vital need for establishing widespread, sustained and measurable progress on an issue important to farmers and all Iowans.” Iowa Soybean Association (ISA)  ISA CEO Kirk Leeds adds, “It’s nibbling around the edges of what’s truly needed. While some additional funding continues to point us in the right direction, it doesn’t get us too much further down the road in achieving the kind of results we all know are attainable and necessary.”
  • “We appreciate the Legislature’s continued attention to water quality, but this effort is incomplete.  There remains much more work to be done. The cost of the nutrient reduction strategy is estimated at over $4 billion and Iowa needs immediate, substantial, dedicated funding and a collaborative watershed approach to adequately implement that strategy.”
    Iowa’s Water and Land Legacy (IWILL) Coalition

According to the IWILL Coalition, Iowa voters overwhelmingly support funding the Natural Resources and Outdoor Recreation Trust Fund: 83 percent support the Trust and 69 percent support raising the sales tax 3/8 of a penny to fund the Trust.  IWILL further argues almost 90 percent of likely Iowa voters describe pollution of rivers, lakes and streams as a serious problem in Iowa.

Iowa voters created The Natural Resources and Outdoor Recreation Trust Fund in 2010. It is a permanent and constitutionally protected funding source to ensure these natural spaces are preserved for generations to come. However, the legislature has not yet funded it. IWILL advocates raising the sales tax 3/8 of a penny to fund the Trust Fund.

Hopefully, Governor Reynold’s signature is the beginning of the discussion surrounding water quality in this legislative session and not the end.  There is still much more work to be done to clean up Iowa’s water.
—-

The Agricultural Law Center continues to engage in this debate with Our Water and other resources, like Director Neil Hamilton’s presentation “High Hopes Meet Hard Truths: Facing the Reality of Iowa’s Water Quality Policy.”