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News

Farm to School & ECE Support in New Pandemic Relief and FY 2021 Spending Bill

NFSN Staff Tuesday, December 22, 2020

By Karen Spangler, NFSN Policy Director

In a late-night sprint on Monday, Congress passed a combined bill of $900 billion in coronavirus relief aid and $1.4 trillion in spending for fiscal year (FY) 2021. While the need for economic, nutrition, and public health relief is far greater than the scope of the relief provided, it nevertheless contains some wins for farm to school and farm to early care and education (ECE), and much-needed funds for our farmers and communities.

Highlights of the COVID relief measures include:
  • Relief for CACFP providers, replacing 55 percent of the total reimbursement funding lost for each claiming month from April 2020 to June 2020, plus half of March 2020.
  • A similar relief measure for schools participating in federal Child Nutrition Programs.
  • Expanded Pandemic EBT (P-EBT) to all income-eligible children under six years old.
  • Relief funding for a number of local food systems programs, and reduction of the matching funds requirements (note: unfortunately this does not include the Farm to School Grant Program) and measures to better tailor direct agricultural payments to specialty producers.

The FY 2021 spending bill also contains a number of big wins for farm to school and farm to ECE: 
  • The highest-ever level of funding for the Farm to School Grant Program – $17 million total!
  • $500,000 allocated for a regional institute to disseminate farm to school and ECE research and technical assistance.
  • $2 million in Centers for Disease Control (CDC) funding for farm to ECE work.
  • Robust funding for other CDC programs promoting nutrition and addressing racial health equity, such as $63 million in funding for the Racial and Ethnic Aspects of Community Health (REACH) grants, of which $22 million is set aside for Native communities. 
Update: These measures were passed in the Consolidated Appropriations Act of 2021, which was signed into law on December 27, 2020.

Our 116th Congress Policy Wins

NFSN Staff Monday, December 14, 2020

By Karen Spangler, Policy Director

2020 has been a tumultuous year for so many of us – educators, farmers and fishers, school nutrition professionals, and of course children and families affected by the pandemic and its impact on the economy. While these crises are ongoing and there is still much work to be done, we want to take a moment to recognize the hard-won progress that our movement has made, together, in federal farm to school and farm to early care and education (ECE) policy during the 116th Congress. In particular, there have been numerous important marker bills introduced in both the US House and Senate since this Congress convened in January 2019, including:

  • Small Farm to School Act: Would create an eight state pilot program of local procurement incentives providing extra reimbursement under the National School Lunch Program.
  • Farm to School Act: Would expand funding and eligibility for the USDA Farm to School Grant Program, and increase equity by prioritizing grants that engage diverse farmers, serve high-need schools, and increase partnerships between tribal schools and tribal producers.
  • Kids Eat Local Act: Would allow schools to require local procurement for child nutrition programs, rather than including geographic preference as just one factor in the overall bid.
  • Universal School Meals Program Act of 2019: Would establish free breakfast, lunch, and summer food service available to all children in school and early care and education, including an incentive to procure at least 30% of ingredients locally.
  • Justice for Black Farmers Act: Would address discriminatory practices in USDA policies, including establishing independent civil rights oversight, creating a land grant system for Black farmers, and banning anti-competitive practices in livestock and poultry.
  • School Food Modernization Act: Would provide grants, loan guarantees, and technical assistance to help school nutrition professionals have the infrastructure and equipment they need to prepare meals with more fresh and unprocessed ingredients.
  • Improving Training for School Food Service Workers Act: Would require that USDA-provided training for local food service personnel take place during regularly scheduled, paid hours, and use hands-on methods whenever possible.
  • Food and Nutrition Education Act: Would establish a pilot program to support local education agencies to hire full-time food and nutrition educators, school gardens, and other hands-on nutrition learning opportunities for students.
  • Local School Foods Expansion Act: Would establish the Pilot Project for Procurement of Unprocessed Fresh Fruits and Vegetables as a permanent program and expand it to more states.
You can read more about each of these bills and see who co-sponsored them here.

Despite the difficulties of this year, these are shining bright spots that can set us up for significant federal policy opportunities with the new 117th Congress in 2021. To make that happen, your legislators need to hear from you that these marker bills are important!

ACTION: Take 2 minutes to scan the list of co-sponsors of these bills, identify if any are your members of Congress, and give them a call at the Capitol switchboard [202-224-3121] to thank them for their leadership. Then, take a second to thank yourself and your fellow farm to school advocates for your own hard work that has laid the foundation for these policy wins to be possible.

When the 117th Congress begins on January 3, 2021, we will need legislative champions to advance the priorities of farm to school and farm to ECE, including re-introducing bills like these and passing the critical COVID-19 relief measures our communities need. (Read more about the COVID-19 federal measures we’re pushing for here.) Your voices have never been more necessary to thank federal farm to school champions and forge ahead on policies towards a just food system.

P.S. Your donations make our policy work possible and will help us continue important farm to school and ECE advocacy with the next Congress. Will you make an end of year, tax-deductible donation today to support our ongoing policy efforts? Thank you!

2021 Transition Recommendations for USDA

NFSN Staff Monday, November 23, 2020


By Karen Spangler, NFSN Policy Director

The transition to a new Presidential administration comes with a change in leadership at important federal agencies, including the U.S. Department of Agriculture (USDA). This moment can be an inflection point, where farm to school and farm to early care and education (ECE) advocates can call for new leadership in how policies and programs are administered. While the federal Farm to School Grant Program has escaped major regulatory attacks over the last four years, it relies on and supports other programs within USDA that have suffered from agency actions. A new administration, in addition to undoing harm, has the opportunity to elevate farm to school and ECE as a proven strategy aligned with USDA’s multi-faceted mission of nourishing children and families and providing economic opportunities for farmers and communities. Additionally, the following recommendations are steps to advance the strategic goal of the National Farm to School Network: By 2025, 100% of communities will hold power in a racially just food system.

Actions for the new administration specific to farm to school and ECE:
  • Withdraw the proposed rule on Broad Based Categorical Eligibility, and revisit USDA rules that may negatively impact participation in school meals. Any attempts to restrict school meal or CACFP participation should be corrected.
  • Develop more formal guidance for school food authorities (SFAs) on using a values-aligned procurement framework (in addition to strictly geographically local preference) for RFPs and the bidding process.
  • Initiate agency legal research into statutory barriers to further values-aligned purchasing.
  • Research USDA authority to issue waivers for greater cash in lieu of USDA commodity foods, if SFAs applied with proposals to increase their local and/or values-aligned purchasing.
  • Initiate research on increasing transparency within the USDA Foods supply chain, and assess what would be needed to apply more stringent conservation compliance and fair labor standards within that supply network.
  • Research barriers that prevent producers from participating as a vendor in DoD Fresh procurement. Recommend policy changes if necessary to reduce barriers for small local and regional producers, to increase the ability of SFAs to procure locally through DoD Fresh.
  • Continue and expand the AMS and FNS administered successful Pilot Project for the Procurement of Unprocessed Fruit and Vegetables, an alternative to USDA Foods and DoD Fresh for USDA purchases, authorized in the 2014 Farm Bill.
  • Conduct research on administrative and overhead savings provided by pursuing a universal approach to school meal and child nutrition programs. Additionally, assess the potential economic impact of local and values-aligned procurement for the farm economy as part of such an approach.
  • Identify regulatory and other barriers related to developing farm to school programs, including direct and indirect compliance costs of production and marketing to schools and early care and education programs, barriers to local and regional market access for small-scale production, barriers to funding projects which might otherwise be eligible for a federal Farm to School Grant, barriers to funding Tribal projects under farm to school programs, and barriers to local and regional market access for Tribal farmers and ranchers.

Actions for the new administration for a just food system:
  • Resume the farm labor prevailing wage survey, and ensure that H2-A agricultural workers receive the very modest protections the program currently has.
  • Take immediate action to protect food and farm workers at risk from the COVID-19 pandemic, and enforce occupational safety and health rules in our food system.
  • Restore the antitrust and competitive practices protections in the livestock and poultry industry, which are rife with unfair practices that exploit producers and lead to more consolidation in our food system.
  • Rebuild the personnel capacity of USDA’s Economic Research Service and the National Institute of Food and Agriculture to collect, analyze, and release important data.
  • Work with small producers to understand and reduce the regulatory barriers of compliance with the Food Safety Modernization Act.
  • Scrutinize programs that have been authorized, but not funded, to include in the President's budget request. Programs such as the Beginning Farmer and Rancher Individual Development Account, which would provide matching savings for beginning producers, require no additional authorizing authority and could get funds directly into the hands of producers who need it most.

A PDF version of these recommendations is available here. For more information, please contact Karen Spangler, NFSN Policy Director, at karen@farmtoschool.org or 248-535-3709.

A Fresh Take on Dietary Guidelines Points to Need for Farm to School

NFSN Staff Monday, August 31, 2020
By Karen Spangler, NFSN Policy Director

In August, National Farm to School Network submitted comments on the Scientific Report of the 2020 Dietary Guidelines for Americans Advisory Committee, which reviews new scientific evidence about diet's impact on health. The Dietary Guidelines for Americans (DGA), reviewed by an advisory committee every five years, provide the foundation for the federal government’s recommendations to the public about eating patterns that lead to better health outcomes. 

The DGA are crucially important because their recommendations to promote or limit certain types of foods inform the nutrition standards for federal programs, including child nutrition programs.The Healthy Hunger-Free Kids Act of 2010 ensured that school meal program standards are aligned with the DGA. Over the last ten years, as school menus have changed to meet the DGA standards, school meals have included more fruit, more servings and varieties of vegetables, more whole grains, and less saturated fat and sodium. A recent summary of research from the Robert Wood Johnson Foundation highlights the impact of these changes on short-term and long-term health and educational performance, particularly for low-income students. 

This review of the scientific evidence from the Advisory Committee offers recommendations to the United States Department of Agriculture (USDA) and Health and Human Services (HHS) for updating the existing dietary guidelines. We’re excited by these new areas of focus, and in our comments have highlighted for the Secretaries that farm to school and farm to early care and education (ECE) activities can help achieve these recommendations. 

Focus on Overall Dietary Pattern
The report notes a dietary approach that promotes holistic, lifelong positive overall dietary quality leads to better long-term health. The Committee comments that, in general, healthy dietary patterns emphasize vegetables, fruits, legumes, whole grains, and seafood, all of which are currently under-consumed by Americans. Farm to school and farm to ECE activities offer proven strategies to increase immediate fruit and vegetable consumption. Research shows participation in farm to school and ECE activities increases children’s fruit and vegetable consumption by up to 1.3 servings per day. As the Committee notes, the flexibility within these patterns offers opportunities to incorporate traditional and culturally relevant foods, which connect children with their local food system and strengthen cultural and social connections in the community. Similarly, exploring local and seasonal foods through nutrition education and food service encourages kids to meet the dietary objectives recommended by the Committee within an accessible, culturally relevant frame.

Recognition of Early Childhood as a Key Developmental Period
For the first time, the Committee focused its review on nutrition in the earliest stages of life, concluding that this period of development is crucial to health later in life. The food environment in early childhood impacts long-term health directly, through key nutrients, and indirectly through shaping taste preferences and food choices. We know that farm to ECE activities can help with both of these aspects. In addition to local food procurement, educational and hands-on activities also  increase students’ willingness to choose healthier options at school meals and influence healthier food behaviors throughout their lifespan and in home environments.

Health Implications of Racial Injustice in the Food System
Commendably, the Committee notes the persistent health problems that food insecurity presents for our country. In addition to calling on USDA and HHS to support programs that provide low-income people with the resources to meet DGA, in our comments, we highlighted the historic and ongoing racial injustice in our food system that leads to these health inequities. We knew before the Covid-19 pandemic and recent Black Lives Matter protests that our food system is rife with racial inequities and that the current public health crisis has only exacerbated them. Our nation’s economy and our agricultural system are built on a foundation of racism and exploitation. These inequities in our food system contribute to economic and health inequalities: the same people that provide labor in our food system often can’t afford nourishing food for themselves and their families. As a result, Black, Latinx, and Native American communities are significantly more likely to face hunger and food insecurity than White individuals, and to suffer from diet-related diseases like diabetes. The Committee chose not to review scientific evidence on how the food environment and the overall food system impact health, which present a major shortcoming of their final report. Food system factors, including systemic racism and environmental justice, are key to dietary health.

The next step is for USDA and HHS to consider the evidence reviewed by the Committee and turn this scientific review into actionable recommendations for federal programs and for the general public. We have encouraged USDA and HHS to consider farm to school activities as a proven strategy for helping child nutrition programs meet these goals, and to foster healthier lives for our kids and communities. 


Read our full comments here. 

Action Alert: Senate Must Do More For Kids, Farmers & Schools

NFSN Staff Tuesday, July 28, 2020

Late yesterday afternoon, the Senate released their latest set of COVID-19 relief bills, a $1 trillion bundle of legislation covering business aid, money for schools and agricultural aid funding. Included in the legislation is $70 billion for K-12 schools ($46 billion is reserved for costs of reopening in-person school this fall), tax credits and Payroll Protection Program Extensions, and $20 billion in agricultural aid funding with no additional guardrails to correct the shortcomings of USDA’s Coronavirus Food Assistance Program (see here and here). While we’re glad that Senators have recognized that our schools and farmers are in urgent need of critical funding support, this proposed legislation from the Senate falls far short of targeting the actual needs of our kids, farmers, educators and school nutrition professionals. 

We need targeted policies that match the scale of this current crisis. Specifically, we need policies that directly support Black, Indigenous and small scale farmers, early care and education providers, and school food service operators – they all play a critical role in feeding and caring for our communities, and especially so during this pandemic. That’s why, as the Senate and House work out the details of this next round of COVID-19 relief, we’re calling on policymakers to: 
  • Fully fund universal free school meals, informed by these values, this next school year. 
  • Provide immediate funding support to early care and education centers.
  • Create a set-aside small business relief fund for farmers of color.
  • Waive the non-federal match requirement for local food and agriculture programs, including the USDA Farm to School Grant Program, for the next two years.
We are pleased to see some of these bold solutions already coming from the champions in the House and Senate. Rep. Antonio Delgado (D-NY) and Rep. Jim Sensenbrenner (R-WI) yesterday introduced the Small Farm to School Act, a bipartisan bill to pilot increased reimbursement for local procurement. Sen. Cory Booker (D-NJ) has included targeted support for Black, Indigenous and other farmers of color who grow vegetables and fruit, and a waiver of the non-federal match for USDA Farm to School Grants, in his Local Food Assistance and Resilient Markets Act. Bills like these should be leading this round of COVID-19 relief from Congress. 

It’s essential that your Senators hear from you about what your community needs right now to support kids, educators, farmers and school nutrition professionals. This legislation is expected to move quickly, so don’t wait - take this quick 5 minute action right now!

Call your Senators TODAY and tell them you want to see more support for kids, farmers and educators in your community included in the HEALS Act. Here’s how: Step 1: Call the Capitol Switchboard at (202) 224-3121. Step 2: Ask to be connected with your Senator's office. Not sure who your Senators are? (You have 2!) Give the Switchboard your zip code and they can connect you to the correct offices. Step 3: Leave a message for your Senators like this: Hi, my name is ____ and I’m a constituent and a ____ [parent, teacher, farmer, etc.]. I’d like to ask [your Senator’s name] to advocate for the following things to be included in next round of COVID-19 relief legislation:Fully fund universal free school meals this next school year. Provide immediate funding support to early care and education centers.Create a set-aside small business relief fund for farmers of color. Support the Local FARM Act (S. 4140). These issues matter to me because ____ [tell your story!]. Thank you!

Already made your two calls? Sign-on to endorse our COVID-19 Federal Policy Platform that includes more measures we think the Senate must include to ensure immediate relief for the people most impacted by this crisis, while building towards longer-term policies that strengthen a resilient, just food system.

If you work for a government agency or university and cannot lobby, you can still make a difference! Instead of calling your Senators to discuss specific policies, share general information about farm to school experiences and needs in your community. Sharing information is not lobbying - it’s education, which we can all do! 

Taking action right now, while this relief bill is in discussion, is especially crucial.  Make your calls, sign-on to the platform, and forward this message to a friend. THANK YOU for taking a few minutes out of your day to make your voice heard. 

The Last Mile

NFSN Staff Wednesday, July 22, 2020

By Karen Spangler, Policy Director, and Erika Rincon, Program and Policy Assistant

Whether you’re a farmer, food bank or school serving meals to-go during the COVID-19 pandemic, the last mile is frequently the hardest equation to solve. It’s one that the USDA “Farmers to Families” program has aimed to cover, with $3 billion in contracts with vendors to provide nonprofits with “truck to trunk” food distribution. But as food banks and other community organizations apply for deliveries from the approved vendors, that last mile – getting the delivered food into the hands of the hungry – is turning out to be a considerable barrier. The CEO at the Food Bank of the Rockies says that distributing food donated through the Farmers to Families program is costing $40,000 per month just for transportation. Since May 15, the San Antonio Food Bank has spent more than $83,000 to store and distribute the food they’ve received from an event company that was awarded the USDA contract for the region.

Like food banks, schools all over the country have drastically altered how they feed kids during this pandemic, pivoting to outdoor distribution, grab-and-go pre-packaged food and social distancing in their kitchens. But the last mile for students – between food distribution sites and their front doors –  can be the hardest. In the first few weeks of distribution this spring, some schools saw only a fraction of their usual free and reduced-price eligible students showing up to collect meals, sometimes attributing this to lack of transportation. So some schools mobilized their dormant fleet of school buses and drivers to deliver meals to distribution locations throughout their districts.

For low-income families who rely on the Supplemental Nutrition Assistance Program (SNAP) or who have received Pandemic EBT (P-EBT) to feed their kids while school meals are unavailable, the expansion of online EBT purchases offers the potential to make purchases without risking exposure. However, in most states this expedited pilot includes only a few big retailers, leaving out local and regional producers who could serve this market. Moreover, online EBT customers do not have the option for pickup in many states, but delivery fees can’t be covered by SNAP or P-EBT funds (which must be used only for food). Immediate measures to help smaller retailers deliver during the pandemic, as well as long-term solutions to make sure all eligible retailers can accept online SNAP, have been proposed in Congress but not yet passed.  

For those who are able to stay home, delivery services spare customers exposure from going into grocery stores with long lines or tight spaces. But the increasing reliance on convenient delivery means that the last mile – from the warehouse, grocery store, or restaurant – is served by workers who are risking exposure. 

Food banks and local food pantries also face their own challenges in the last mile, the miles that patrons have to travel to access these distribution sites. A recent survey by Feeding America, the nation’s largest network of food banks, reported that 40% of clients are getting help from a food bank for the first time. For these new customers, first identifying and then traveling to a distribution location can be challenging, especially when avoiding public transportation. Some food banks have undertaken mapping projects to link customers with resources and help them find out what’s available in their area. 

Farmers who relied on institutional sales to restaurants or schools have been left with a surplus in their fields, but for them, the last mile to the food bank is expensive and time-consuming. The cost of harvest, transportation, and navigating the patchwork of operating hours of local food pantries – often narrow windows of time, constrained by volunteers (many of whom are elderly at at high-risk) and a lack of storage capability at the distribution site – means extra difficulty in getting excess produce to its destination. New York state is trying to solve this problem through $5,000 refundable tax credits to farmers for donating crops, and $25 million in funds for food banks to buy from local and regional producers and invest in storage capacity. This approach is faster, more flexible, and more cost-effective than the federal Farmers to Families approach.

The “last mile” is often an afterthought in government programs, as evidenced by the Farmers to Families dilemma. COVID-19 has given us the opportunity to evaluate our supply chain and the security of our food system. During and after this public health crisis, public investments should increase the capacity of local and regional food systems to bridge that last mile. 

Federal Policy Update: A Big Budget Win & More Opportunities to Champion Farm to School Through COVID-19

NFSN Staff Thursday, July 16, 2020



By Karen Spangler, Policy Director


On July 9, the House Appropriations Committee advanced its agricultural spending bill for Fiscal Year 2021. The package provides $12 million in funding for the USDA Farm to School Grant Program, a discretionary bump of $7 million above the annual mandatory $5 million level. In addition, it allocates discretionary funding for school kitchen equipment grants, outreach to socially disadvantaged farmers and ranchers, the Local Agriculture Market Program (LAMP), and the Food Safety Outreach Program. This is a huge win for farm to school, and follows USDA’s recent announcement of a record 159 Farm to School Grant awards, made possible by the additional funding secured by our Congressional champions through appropriations bills for fiscal years 2018 and 2019. The Senate is currently working on its own set of FY2021 spending priorities, which it must negotiate with the House before passing a final spending bill for the President’s signature. After those steps, this increased funding for farm to school will be official. 
 
Of course, farm to school activities can’t take place without the strong foundations of a viable local and regional food system, school meal programs and CACFP sites that actually have the resources to invest in farm to school, and educators who are supported in using farm to school activities with kids. We’re pleased to have such strong champions in House Appropriations Subcommittee on Agriculture, including Chair Sanford Bishop (D-GA) and Ranking Member Jeff Fortenberry (R-NE), who help make possible this important additional support. But to make the most of this future funding, we must address the immediate needs of stakeholders across the farm to school community that need relief now, and that will need support to rebuild in the years to come.
 
That’s why National Farm to School Network was pleased to endorse the Local FARMS Act, introduced July 2 by Sen. Cory Booker (D-NJ). This bill would waive the non-federal match required for USDA Farm to School Grants, covering 100% of project costs instead of the current 75%. As state and local budgets are squeezed in the wake of the COVID-19 pandemic, finding scarce matching funds will no longer be a barrier to accessing these grants. The Local FARMs Act would also support local food systems as producers rebuild, in particular directing 50% of bonus Specialty Crop Block Grants to purchase crops from women, veterans, and people of color.
 
School meal programs and early care and education providers who participate in CACFP have borne the responsibility of transforming their operations to continue feeding kids, even as reduced reimbursements from federal programs put programs in the red at a median level of $200,000. The HEROES Act, passed by the House in May, contains two provisions that would help somewhat, offering funding to cover some operational costs and make up for declining reimbursements. But as the uncertainty and burdens of the COVID-19 crisis drag on, more groups are looking to universal free meals in the 2020-2021 school year, including the School Nutrition Association, the Robert Wood Johnson Foundation, and a new joint campaign, School Lunch for All, led by Urban School Food Alliance and Student Voice. Universal free meals would not only help ensure health and educational equity for low-income children, but would also allow school nutrition staff to focus on nourishing kids rather than worry about reimbursement paperwork in the midst of a crisis. National Farm to School Network is supportive of these calls for universal free meals, and urges that any new policies to emerge be rooted in racial equity and justice. 
 
What’s next? Senate leaders face growing pressure to take action and pass more COVID relief legislation as the costs and uncertainty of this pandemic drag on. The good news is that there’s still time to shape what’s in this package - including many of the policy needs cited here in this post. 


You can take action by:
1) Signing NFSN’s COVID-19 platform on federal policy response.

2) Urging your Senators to support the Local FARMS Act.

3) Telling your Senators that relief for school meal programs and CACFP sites must be part of any new legislation. (Need support reaching out to your Senator? Just let us know!)

4) Joining forces with groups pushing for immediate universal free school meals in the 2020-2021 school year.

USDA Coronavirus Food Assistance Program and Local Food

NFSN Staff Monday, April 27, 2020

On Friday, April 17, USDA announced the USDA Coronavirus Food Assistance Program. While there is still much unknown about how the program will be implemented, it may be an opportunity for local product to make its way to emergency feeding programs, addressing a vital need for market opportunities for local producers and food access needs in communities. The program aims to support producers and consumers with two approaches:

  • Direct Support for Farmers and Ranchers
  • USDA Purchase and Distribution 
What You Need to Know 
  • Direct Support for Farmers and Ranchers - USDA is in the process of developing rules for how support will be distributed and who will be eligible. NFSN and partners are working to ensure all farmers are able to access this program by pushing USDA to target local and regional producers and to outline the measures it will take to equitably include producers of color. What you can do: We anticipate a brief rulemaking process to direct how this money will be distributed. We encourage partners to be prepared to submit comments. We also encourage partners to work with their state departments of agriculture to put pressure on USDA to commit to the measures the National Sustainable Agriculture Coalition outlines.
  • USDA Purchase and Distribution - On Friday, April 24, USDA opened solicitations (view RFP here) for regional and local distributors who can coordinate purchase of agricultural products, the assembly of commodity boxes and delivery to identified non-profit organizations that can receive, store and distribute food items. Included in the application is a request for applicants to describe how they intend to support small farmers and those serving local and regional markets. Applicants are also responsible for identifying non-profit organizations for distribution, and this could potentially include schools and early care sites. What you can do: Share relevant information (see links below) with local food hubs, intermediaries, producers, and relevant food businesses. Awardees are expected to capitalize on exisiting networks and relationships, so this is a vital opportunity for local and regional food networks to activitate local distribution chains.  
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