Michael DeSa
Preston Ingram
It is too simple to define agricultural sustainability as the maintenance of a certain level of ecological health, especially in the face of a growing population and rising consumption. Therefore, we must focus on sustainability as a process of continuous improvement through the demonstration of marked incremental changes to the existing system.
Cotton’s reputation as a high consumer of resources makes it an ideal candidate for sustainable practices as growers face mounting internal and external pressures to improve resource use efficiency. Technology is opening the doors for the industry to do just that. Two major headwinds facing the adoption of more sustainable practices are rooted in the extensiveness of pesticide applications and the management of water use efficiency. The combination of precision agriculture and diverse soil management practices could help to spin a new chapter for cotton production.
Weeds: controlling the inevitable Weed control remains a daunting challenge for cotton producers as herbicide-resistant varieties of weeds increase and the cost of management continues to consume a large portion of input expenses. It is an unpopular message to have to tell growers that weed management will be more difficult, complex and expensive, according to Bryan Young, a Purdue University weed scientist.1 Beside glyphosate, amaranth species (pigweed, water hemp, etc.) are now resistant to eight different herbicide modes of action.2 Cracks are also starting to appear in dicamba according to a 2018 study which found that dicamba applications failed on approximately 40 Tennessee Xtend cotton fields, mostly barnyard grass or jungle rice.3
Not only are weeds becoming harder to kill, but they continue to make up a sizable portion of input costs for growers. According to Jeff Vinzant, agronomy services manager for Norder Supply, the application of glyphosate can cost between $30 to $80 per acre in northern U.S. states.4 Shannon Pickering, market development manager for Blue River Technology, commented that many 2017-18 cotton growers in Georgia spent ~$50 per acre on hand weeding, on top of combating weeds through seed selection and pre/post emergence herbicide treatments.
Advances in technology, both biological and physical, are providing cotton producers optionality around how to manage weed pressure more sustainably. Blue River Technology uses computer vision and artificial intelligence to distinguish between weeds and crops. “The technology began in lettuce cultivation and was used to thin unwanted plants by treating them with liquid nitrogen,” noted Pickering. “Once we proved the technology here, cotton was the obvious next step because of the tremendous weed pressure in the sector.”
Blue River’s “See & Spray” technology has the potential to treat individual weeds, reduce herbicide usage, slow the propagation of herbicide resistant weeds, and even allow growers to select a more natural cotton seed that has not been genetically engineered to resist broadleaf herbicide.
Fighting the disease – cotton root rot Cotton root rot (CRR) is caused by a soil-borne fungus that is crippling many cotton growers in the southern United States. The fungus spreads easily from plant to plant; with plant death often the first visible symptom of CRR, there is no practical way to cure infected plants.5
In the past few years, however, an emerging fungicide treatment (includes flutriafol) has proven effective at protecting against CRR.6 It is expensive, however, so growers are aiming to identify and treat only affected areas of their fields in order to limit the environmental impact and reduce input costs.
Remote sensing techniques have been used for decades to detect CRR, employing equipment such as high-resolution airborne cameras, colour infrared (CIR) photography and multispectral video imagery. While these methods produce detailed images of the desired areas, they are expensive to employ and complicated to compile into a usable product for the grower. To combat this, researchers are exploring the use of satellites (Sentinel-2A for example) in the fight against CRR.
A 2017 collaborative study by scientists from the Beijing Academy of Agriculture and Forestry Services and the USDA Agricultural Research Services in south Texas7 compared several satellite imaging systems to conventional airborne collection methods to gauge their efficiency in CRR identification. Figure 1 shows the comparison between airborne images as the Sentinel-2A satellite system for cotton fields in South Texas.
Although there were some slight differences in the percentage values between the green (subset Sentinel-2A images) and red (subset airborne images) lines in Fields 6, 10 and 22, the two tracked fairly closely for the other fields. The percentage value differences, however, for Fields 1 and 15 between the red and blue lines indicates a classification error where some small, non-infested fields were incorrectly classified as infested due to the Sentinel’s coarse spatial resolution.8
Figure 1 - Comparison of CRR for 24 Fields in South Texas in Different Classification Maps. / Source: Evaluation of Sentinel-2A Satellite Imagery for Mapping Cotton Root Rot Study
Water management Cotton also faces substantial pressure to reduce water usage. Outside of alfalfa, it is one of the greatest users of water per acre for U.S. crops. As agriculture in general looks to reduce its water footprint, cotton likely has one of the greatest opportunities for substantial change. Advances in manufacturing and materials technology coupled with field level data are revolutionizing the ability of cotton producers to reduce water usage.
Cotton is grown broadly across the south of the U.S., in both arid and higher rainfall climates where annual precipitation can range from greater than 50 inches to less than 20 inches. In the southeast, where rainfall amounts are higher, water issues are centered on timing crop needs; in the arid regions, the focus is on minimizing evaporation loss.
An efficient water system provides the plant the exact amount of water needed each day with minimal waste, an especially tall order for cotton growers as the plants need differing levels of water throughout its growth stages.
Evaporation is one the largest competitors for water as the plant must uptake enough water for its own needs, but also to overcome the loss from evaporation. Typical pivot irrigation methods in the eastern U.S., for example, distribute water through the air, losing between 10 and 40 percent in arid climates of available water through evaporation.9,10
The remaining water reaching the plant now faces cotton’s second major water competitor – transpiration - the exhalation of water vapour through the plant stoma. Figure 4 shows cotton’s evapotranspiration (the combined effect of water loss through evaporation and transpiration) water loss, adjusted for growth stage conditions (Kc), throughout a season.
Figure 4 – Crop Evapotranspiration (ETc) and Crop Coefficient (Kc) Function for Cotton in Stoneville, Mississippi. / Source: Cotton Incorporated
As is evidenced, cotton’s water requirements vary greatly throughout the season and are in a constant struggle for retention against evapotranspiration. These factors make it nearly impossible to exactly apply the right amount of water using a conventional, distributed irrigation plan.
Technology has made implementation of water reducing solutions more executable with the ability to tailor-fit irrigation schemes to the region, current climate and the plant’s growth stage. Real-time kinematics (RTK) and mapping advancements have allowed for a much more efficient design and construction of subsurface drip irrigation systems, allowing them to be more effective and less expensive. The systems are designed and installed for particular crop rotations, tillage systems, soil types and fertilization goals, and have been found to increase water efficiency by up to 50 percent.11 Manufacturing advances in plastic materials and filtration systems minimize maintenance and increase functional lifespans.
Sensors are also helping farmers make better decisions about the application of water. Thermal temporary thermometers (IRTs) are being utilized to predict when the plant begins to run out of water by measuring leaf temperature.12 Moisture probes and weather sensors are collecting above- and below-ground in-field data in order to better predict when to apply the right amount of water to maximize plant uptake. Additionally, Texas A&M University is developing an app for the Texas Rolling Plains Region to help producers better execute irrigation strategies.13
Like all solutions, there are trade-offs with incorporation. The time and expense associated with collecting the necessary images needed to train Blue River’s algorithms remains a predominant challenge. New herbicide treatments will continue to be encumbered by lengthy developmental timelines, off-target drift issues and concerns over yield drag at adoption. Growers have to consider the cost-benefit analysis of employing higher resolution, but more expensive aerial technology to that of lower resolution, more affordable satellite-based analysis for disease detection. Installation costs for precision irrigation technologies are falling, but still cost-prohibitive for many. Not to mention the cultural dynamics underpinning adoption with all of these technology solutions.
There are, however, technology solutions already at work in Mother Nature.
Nature’s “technology” solutions The challenges facing cotton growers with pesticides and water management have many university researchers and corporates advocating for a more holistic approach, one that incorporates nature’s “technology” to produce a more sustainable crop.
Figure 2 - Net Water Use Per Acre for Certain US Crops. / Source: US Davis Center for Watershed Sciences, California WaterBlog
New Ag International JUN/JUL 2020
In 2015, USDA-ARS and University of Illinois weed scientists released a study that emphasized long-term, effective weed management would require diverse management practices. “We need a lot of little hammers as opposed to one big hammer,” stated Travis Gustafson, a Syngenta agronomic service representative out of Nebraska.14 Gustafson is advising farmers to use herbicide in an integrated program that also includes strategies like canopy cover and crop rotation.
Cover crops are nature’s way to sequester sunlight from weeds before they germinate while others inhibit weed seed germination by releasing chemicals from their roots, stated Anita Dille, a Kansas State University Agronomist.15 Pickering from Blue River Technology noted that winter rye as a cover crop in cotton provides a thatch to shade the row while the roots exude a natural inhibitor that reduces the germination of pigweed seeds.16 A 2013-14 study by KSU also found that winter rye cover crop suppressed 94-96 percent of the winter annual marestail.
The use of biological control methods for the effective management of soilborne diseases has been a long-term goal in sustainable agriculture. Biofumigation, for example, is the process of grinding a cover crop (in this case, Brassica) planted during the fallow period to then be incorporated as chopped biomass into the soil.17 These Brassica-introduced organic compounds mimic those released during the development of certain plant species as a defense mechanism, ultimately killing between 50 and 58 percent of the CRR fungus discovered in preliminary tests and are also thought to reduce the severity of the disease on succeeding cotton crops.18 The application of chelated trace elements, such as powdered sulphur and iron, are also thought to suppress and reduce the occurrence of CRR, respectively.
Figure 3 - 2019 Cotton Yields in Pounds and Change from Previous Forecasts. / Source: NASS USDA Charts and Maps
Soil has a dual role to play in water management; acting as a sponge to both absorb and hold water and nutrients for plant use. In nature, this is accomplished through soil organic matter, living roots and a thatch layer to prevent bare ground. Implementation of these soil health principals will allow the soil to use the water made available to it through irrigation and rainfall.
The integration of man-made technology solutions with that of nature’s biological processes can be a more sustainable way to combat pesticide and water challenges facing cotton growers.
The future is one of complementary strengths With the impacts of COVID-19 on the input supply chain (many of the macronutrients and active ingredients for ag inputs are concentrated in China), the need to employ more sustainably based, technologically supported solutions are more paramount now than ever before.
Weed control methodologies remains expensive and require multi-step solutions, but incorporating regenerative practices such as cover cropping may help slow the spread of this problem. Aerial imaging technology, currently used for disease detection, could be used to support the precise placement of biofumigation efforts and beneficial micronutrients. Improved water management through the application of irrigation mapping and environmental sensors can have the added benefit of improving overall soil health.
Finding the symbiotic relationship between man and nature’s technology solutions will be the challenge of our modern-day growers.
Primary Author – Michael DeSa is the Founder/Managing Director of AGD Consulting, a veteran-owned, strategic agribusiness advisory firm servicing the global food/agriculture investment and technology sectors. Clients include asset managers, private equity funds, agtech start-ups and growers to which AGD provides diligence/business development services and access to growth capital. www.DeSaConsultingLLC.com
Contributing Author – Preston Ingram is a Relationship Manager with Texas Farm Credit and is responsible for financing agriculture across every crop, livestock type, and agribusinesses. Prior to Farm Credit he was the Director of Agriculture Operations for a 30,000-acre row crop and beef cattle operation in Northeast Texas.
REFERENCES 1Gullickson, Gil. “The New Math of Weed Management.” Successful Farming, Successful Farming, 13 Jan. 2020, www.agriculture.com/the-new-math-of-weed-management, accessed March 26, 2020. 1Ibid, accessed March 24, 2020. 2Bomgardner, Melody M. “Palmer Amaranth, the King of Weeds, Cripples New Herbicides.” Chemical & Engineering News, American Chemical Society, 1 Aug. 2019, cen.acs.org/business/specialty-chemicals/Palmer-amaranth-king-weeds-cripples/97/i31, accessed April 5, 2020. 3Gullickson, Gil. “The New Math of Weed Management.” Successful Farming, Successful Farming, 13 Jan. 2020, www.agriculture.com/the-new-math-of-weed-management, accessed March 26, 2020. 4Ibid, accessed March 24, 2020. 5T. Wang, J.A. Thomasson, D.A. Cope, C. Yang, R.L Nichols, 2017, “Delineation of Cotton Root Rot in Individual Crop Rows Based on UAV Remote Sensing”, 2017 Beltwide Cotton Conference, Dallas, Texas, accessed March 28, 2020, http://www.cotton.org/beltwide/proceedings/2005-2019/data/conferences/2017/papers/17903.pdf. 6Thomasson, J. Alex, et al. “Disease Detection and Mitigation in a Cotton Crop with UAV Remote Sensing.” Search the World's Largest Collection of Optics and Photonics Applied Research., International Society for Optics and Photonics, 15 May 2018, www.spiedigitallibrary.org/conference-proceedings-of-spie/10664/106640L/Disease-detection-and-mitigation-in-a-cotton-crop-with-UAV/10.1117/12.2307018.short?SSO=1&tab=ArticleLink, accessed March 28, 2020. 7Xiaoyu, et al. “Evaluation of Sentinel-2A Satellite Imagery for Mapping Cotton Root Rot.” MDPI, Multidisciplinary Digital Publishing Institute, 31 Aug. 2017, www.mdpi.com/2072-4292/9/9/906/htm, accessed March 28, 2020. 8Ibid, accessed March 28, 2020. 9Danny Rogers, Jonathan Aguilar, Isaya Kisekka, Freddie, Lamm, 2017, “Center Pivot Irrigation System Losses and Efficiency”, Proceedings of the 29th Annual Central Plains Irrigation Conference, Burlington Colorado, accessed April 4, 2020, https://www.ksre.k-state.edu/irrigate/reports/r17/Rogers17.pdf.
10 Roger Ashley, William Neibling, and Bradley King, Irrigation Scheduling: Using Water-use Tables, University of Idaho College of Agriculture, Cooperative Extension System, accessed April 4, 2020, https://www.extension.uidaho.edu/publishing/pdf/CIS/CIS1039.pdf. 11 Steve Amosson, Lal Almas, Jnaneshwar Girase, Nicholas Kenny, Bridget Guerrero, Kumar Vimlesh, and Thomas Marek, “Economics of Irrigation Systems”, AgriLIFE Extension Texas A&M System, http://amarillo.tamu.edu/files/2011/10/Irrigation-Bulletin-FINAL-B6113.pdf, accessed April 4, 2020. 12 D.F. Wanjura, et al, “Scanned and spot measure canopy temperatures of cotton and corn”, USDA-ARD, Plant Stress & Water Conservation Research Lab, 2004, https://naldc.nal.usda.gov/download/2378/PDF, accessed April 4, 2020. 13 Ledbetter, Kay. “App Being Developed to Aid Crop Irrigation Management.” AgriLife Today, 13 Feb. 2020, agrilifetoday.tamu.edu/2020/02/12/new-app-development-could-aid-crop-irrigation-management, accessed April 4, 2020. 14 Gullickson, Gil. “The New Math of Weed Management.” Successful Farming, Successful Farming, 13 Jan. 2020, www.agriculture.com/the-new-math-of-weed-management, accessed Mar 24, 2020. 15 Ibid, accessed March 24, 2020. 16 Shannon Pickering, Blue River Technology, Personal Interview, March 17, 2020. 17 “Biofumigation.” Page D'accueil, dicoagroecologie.fr/en/encyclopedia/biofumigation, accessed March 28, 2020. 18 Matocha, John. “New Technologies in Cotton Root Rot Control.” Farm Progress, 9 Dec. 2018, www.farmprogress.com/new-technologies-cotton-root-rot-control, accessed Mar 28, 2020.
Arama Kukutai
Last year (2019) was a stellar year for ag-tech investments. This year, however, looks to have been blown off track by Covid-19, but there are plenty of reasons to be optimistic in a space that is playing catch-up in terms of capital investments. In this exclusive, Luke Hutson, Editor-in-Chief of New Ag International, spoke with Arama Kukutai, Co-Founder and Partner, Finistere Ventures, who is based at the company’s office in San Diego, California.
The first question needs to be asked if only to clear up any misconceptions – what does venture capital do?
“Sure, there’s the misconception that we’re constantly throwing money on a bonfire, as it might appear,” says Kukutai, who has moved to the U.S. from his native New Zealand.
Essentially, venture capital (VC) is looking for a growth opportunity, in what is often called disruptive and deep technology. But Kukutai adds another ingredient – a committed founder, an entrepreneur with a vision, someone who is unassailable when it comes to making it happen.
“That second piece – unassailable – is essential. We’re investing in people to transform an industry.”
So, what levels of investment are we seeing? By the end of 2019, global ag-tech VC deal activity reached an accumulated value of $2.7 billion, according to the 2019 Finistere PitchBook AgriFood Tech Investment Review. This was invested across 289 venture financing rounds, with the data stretching back to 2010.
By geography, U.S.-based companies received 66 percent of all ag-tech VC in 2019, with European ag-tech companies doubling the capital received. By sector, crop protection and input management were the leaders with 37 percent, seeing an inflow of around $1 billion.
Riding the curve Referencing the classic industry S-curve, VC tends to serve what the Harvard Business Reviews refers to as the “adolescents”’, the middle part of the curve where there is accelerating growth. Typically, VC plays a role in the stage after basic innovation – this is when a company begins to commercialize its innovation.
This was borne out in 2019, when over 70 percent of all capital invested into ag-tech was allocated into later-stage venture deals. This was highlighted by funding for crop protection and input management where 95 percent of capital was invested in later-stage companies, the report stated.
So, if we look at that S-curve for the agricultural biological companies, it seems pretty fragmented at the bottom of the curve. Why is that?
Kukutai boils it down to what might be called the intrinsic nature of the products – their various modes of action and efficacy that is often dependent on specific location.
“Understanding consistent performance and doing so in different locations; understanding shelf-life, deployment, can they survive irrigation and application by drone. There’s lots of technical work. Holding field trials, proving out technologies, which all takes time,” says Kukutai.
The development of new business to effective deployment takes a lot of money, and these are large barriers to entry. But as Kukutai points out, these companies are attracting capital because the problems they are solving are huge. In some cases, it might need to be “patient capital”.
The crop protection industry alone is worth around $60 billion per year, offering plenty of opportunities for those companies that can focus on field trials and prove out their technologies. The time periods involved here could be one explanation for the fragmented base of companies, and the trend towards later stage financing when companies are ready to scale-up commercially.
“A well thought out trialling budget should be one of the first items to allocate within a budget primarily because it is a key driver of business development, not separate from it,” stated Finistere Ventures Partner and Chief Agronomist Michael Pereira in the AgriFood Tech Investment Review.
Kukutai expects that as companies, investors and farmers pay closer attention to field results, we will see improved growth and adoption rates in digital ag and crop protection segments in future years. So, where does this leave biostimulants? Speaking as someone with a background in agronomy, Kukutai can cut straight to the chase.
“It’s going to be simple. Does it work? What value does it add? The problem with biostimulants is that they work somewhere, sometime. And farmers are expecting it to work quickly. If it doesn’t do that, this is a barrier to adoption, and the results need to be significant. But the good news in agriculture is that a yield increase of five percent can be good for the bottom line.”
Michael Pereira
Gathering data takes time, whether for a registration application or field trial results. This is where start-ups can have an advantage in being nimble and fast. Value creation requires data, and the quicker you can generate that data the better.
Finistere has Chief Agronomist Michael Pereira, formerly with Syngenta’s and Limagrain’s global seed production organizations. Kukutai echoes Pereira’s advice. Get going early with the trials and answer the central questions – does it work, can you prove it?
Finding a niche Despite ag-tech recording year-on-year (yoy) investments, it is still a niche sector in the VC world. From the AgriFood Tech Investment Review, in 2010, $35 million was invested in all ag-tech, and this has grown by nearly 58 percent yoy, reaching the cumulative total of $2.7 billion in 2019.
In comparison, the total VC investment in the U.S. for a single year was around $117 billion in 2019, according to data from TechCrunch. Kukutai estimates that fintech and insurance might be a multiple of x8 compared with ag-tech.
“It’s clear that ag-tech has arrived as a VC commodity,” says Kukutai. “Even fertilizer companies have innovation tech, and retailers are now playing innovators.”
Kukutai sees this as an unprecedented time. “This is catch-up. Other industries have had examples of mass disruption. Ag-tech will have the capital to catch-up in the next decade.”
He says this is not dissimilar to when pharma jumped from being dominated by the chemical to the biological. Currently, the fertilizer world is very much stuck in the chemical world.
Where’s the exit? One comment that resonates from the AgriFood Tech Investment Review is that “exit potential has yet to truly materialize.” How much of this is to do with the sector and the broader commodity markets?
“Fair question – bit of both,” says Kukutai. He cites the poor crop prices and reiterates that new ag-tech takes time to show efficiency, and that’s even more the case in life sciences.
Kukutai comes back to the point about the sector catching up, and how there is now a healthy pipeline similar to that in the biotech sector. “Investments are more capital effective when [a company] is ready to take to market. The best of those companies will be the most disruptive. They might not be acquired, but go to the public market.”
Kukutai uses nitrogen-fixing technology as an example. If a company can beat the costs of the incumbent producers and biologicals are part of that novel form of fertilizer, it could be possible to build enough depth in a stand-up company. As the market share grows, capital will be returned.
Another option might be M&A, but if a company has a high enough margin to remain private, it can keep reusing capital for growth, negating the need to go public.
So for Kukutai, it is very much a “horses for courses” approach. Going public provides access to capital in large multiples and access to liquidity. “In agriculture, the incumbent is consolidated, the customer is fragmented, so M&A provides access to the tech and all the customers.”
By creating its own distribution channel, a company could add significant value to any possible suitor, and there is one notable company out there trying to do this. Plant microbiome innovator Indigo Agriculture is aiming to become an ag-tech product distributor and digital platform. “The channel is more valuable than the commodity,” Kukutai notes.
2020 vision What can we expect to see in terms of VC activity in 2020? With the economic realities of Covid-19 starting to bite, it now seems there is little chance of the continuance of a 58 percent yoy growth rate. Kukutai estimates the number of deals could be down by around 25 percent.
“There are still lots of opportunities; many may not be consummated until 2021,” he says. “And there’s a lot we can do remotely. Here’s a moment to lock arms with colleagues and companies, and move the ball down the pitch.”
Travel restrictions are one of the bigger barriers. “Would you invest in a company you have never met? This is a high-touch business. So that funding window has to be impacted, but to continue the sporting analogy – it’s just going to take longer to score.”
Field trials on wheat by Kansas State University using MPXA – a humic and fulvic acid based chelating agent – resulted in an average 29 percent increase in bushels per acre.
Developed through extensive testing and chelation research, MPXA is known for enhancing stronger growth in crops though stimulating oxygen uptake, increasing chlorophyll content and increasing the availability of macro and micronutrients to plant roots. However, trials have revealed that MXPA is particularly effective with wheat crops.
Manufactured by California plant research-based agricultural production company FARMCo Affiliates LLC, MPXA has been producing remarkable results in wheat trials. A study by the Oklahoma Panhandle Research and Extension Centre using MPXA produced an increase in bushels per acre of 18 percent over the control site. And a study by Kansas State University yielded an average increase of 29 percent over the control.
According to Henry Johnson, sales manager at ExNonProfit Consulting Ltd, the distributor for MPXA, FARMCo’s proprietary process creates high-performing humic and fulvic acids that produce significant increases in yields or reductions in starter fertilizers across a wide range of crops, including wheat, maize, soybean, sorghum, strawberry and even tree nursery seedlings.
“It is 100 percent soluble, which means that it can easily be applied via standard watering, fertigation and foliar spraying practices,” notes Johnson. “Coupled with a low cost per acre, MPXA is driving significant returns on investment for agricultural holdings.”
The majority of the customer base is in the U.S. and Canada; however, the company now has major producers in the Ukraine and Estonia trialling MPXA on winter and spring cereal crops, and the company is inviting more international companies to do the same”.
Johnson says MPXA is different in that it chelates micronutrients at much higher rates (94-100 percent) compared to chemical based products such as EDTA. Formulated from naturally occurring leonardite ore, MPXA’s humic and fulvic acids contain millions of bonding sites that capture micronutrients in either acid or alkaline environments. This makes for an effective chelating agent that improves plants ability for micronutrient uptake. The company says the resulting increase in metabolism produces significantly more new root tissue, creating a stronger base for crops. MPXA also supports the mycorrhizal zone where symbiotic plant biologicals can thrive and support plant growth.
Among the many challenges thrown down by the global COVID-19 pandemic, one has been to the food supply chain. In Europe, the challenge presented itself as a shift in demand from hotels and restaurants to increased demand for products in supermarkets. In some cases, such as flour, this meant there was not always enough of the required packaging size. But overall, the supply chain has been maintained, from farmers and growers, through to supermarket staff who have kept working while many countries temporarily shut down large parts of their economies.
Informa Connect Life Sciences conducted a survey (14-22 April 2020) of professionals from across the agricultural supply chain, asking those involved in the industry their experiences of the COVID-19 crisis, its impact on their sector, and their thoughts for how it will shape the industry in the years ahead. This report details the results of the 291 responses.