Center Pivot Irrigation Management Short Courses in February
Getting the most value from your irrigation water will be the focus of University of Nebraska-Lincoln Extension Center Pivot Irrigation Management Short Courses in early February in Norfolk, Bridgeport and Broken Bow. Topics include sprinkler package selection, soil water management, and pumping plant performance. Also, irrigation industry representatives will be available to discuss the latest in center pivot irrigation technology. Dates, locations and contact numbers for registration are:
- Feb. 4, Norfolk: Lifelong Learning Center; call 402-370-4000
- Feb. 6, Bridgeport: Prairie Winds Community Center; call 308-632-1276 or email pmartin2@unl.edu
- Feb. 15, Broken Bow: Mid-Plains Community College; call 308-872-6831 or email custer-county@unl.edu
At each location, registration begins at 9 a.m., with a welcome at 9:30 a.m. Lunch will be provided. The workshops will conclude by 3:15 p.m.
Speakers will include:
- Derrel Martin, UNL Water and irrigation resources specialist
- Simon van Donk, UNL water and irrigation resources specialist
- Bill Kranz, UNL irrigation specialist
- Tyler Smith, UNL water resources research technologist
These short courses are sponsored by UNL Extension, Reinke, Valley, T-L Irrigation, Lindsay, and the Nebraska Environmental Trust Fund. The program is free, but participants are asked to preregister so adequate materials and meals will be available.
February Nebraska Agribusiness Club meeting to feature Extension’s new Dean
Join us for the upcoming Lunch & Learn Meeting of the Nebraska Agribusiness Club on February 4th, 2013 at the Lancaster Extension Education Center, 444 Cherrycreek Road in Lincoln.
The new Dean of Extension from UNL, Chuck Hibberd, will be speaking. Buffet lunch will begin at 11:30 a.m., with the program starting at 12:20 p.m. Meeting registration, which includes lunch, is $10 per person (unless you have already paid for the inclusive membership).
Hibberd is a Lexington, Neb. native and UNL graduate. He was named Dean of Extension after being director of Extension and associate dean of agriculture at Purdue University since 2007. Previously, he was director of the Panhandle center at Scottsbluff for 13 years. Hibberd received his bachelor's degree in agriculture, with an animal science major and his master's and Ph.D. degrees from Oklahoma State University in animal science and animal nutrition, respectively. He was a faculty member at OSU from 1982-94.
Please RSVP for this great meeting speaker today! Go to http://nebraskaagribusinessclub.wordpress.com/2013/01/17/february-meeting-to-feature-extensions-new-dean/ for more details and RSVP.
Consider Forages This Spring if Water is Limited
Bruce Anderson, UNL Extension Forage Specialist
Drought, declining water tables, and legal issues are limiting the amount of irrigation water available. If you don't have enough for a good grain crop, consider planting forages this spring.
Many irrigated acres may not receive enough water this summer to grow a good grain or root crop. Sometimes you can combine water allocated for several fields onto one field to get a crop, but that still leaves the other acres with little or no water.
Forage crops also need water for highest production, but at least some useful yield can be gathered when total water available is very low.
Forage Options
If you expect water limits will continue for several years, a perennial forage would eliminate the cost and time of establishing a new crop each year. Switchgrass is a good choice because it’s less expensive to plant, its primary water needs occur in early summer when water usually is available, and it can be managed for hay or pasture. Other warm-season grass options include big or sand bluestem and indiangrass, especially for grazing. With limited irrigation some wheatgrasses, bromegrasses, and alfalfa can work, but these cool-season plants respond best to water applied during spring. For some irrigators, water isn't available until after this most efficient time has passed.
For spring forage, if moisture is available, consider small grains like oats and spring-type varieties of rye, barley, and triticale. Of course, annual forages like pearl and foxtail millet, cane, teff, and sorghum-sudangrass are relatively water efficient and will yield proportionately to the amount of water they receive.
If water’s limited in your area this year, forages may be a good way to make the best of a bad situation.
Young Farmers and Ranchers to Gather in Norfolk Jan. 25-26
Nebraska’s younger generation of farmers and ranchers will gather Jan. 25-26 for workshops, tours and information sessions designed to enhance both their personal and professional skills as part of Nebraska Farm Bureau’s Young Farmers and Ranchers Conference. This year’s event will be held at the Divots Conference Center in Norfolk, Neb., and will provide a chance for networking, information sharing and fun.
“The whole purpose of the event is to bring information and different experiences to younger generations in agriculture. Things are always changing and one of the ways farmers adapt is by having a good understanding of not just their operation, but how their farm or ranch fits in the bigger picture of making food and fiber,” said Cathy Day, Nebraska Farm Bureau director of special programs. “That’s why we spend the first day touring local industries.”
Attendees to the conference will have the chance to tour Affiliated Foods Midwest, Producers Hybrids, Manzer Tractor Testing at Northeast Community College, Nucor Steel, Cuthills Winery, Louis Dryfus Ethanol Plant and the Four Corners Feedlot.
“We also spend part of the conference helping attendees identify how they can deal with some of the issues and challenges they face today and will continue to face in the future,” said Day.
Workshops at this year’s conference will focus on topics such as helping communicate what happens on the farm to those less familiar with today’s farming practices, getting ideas on how to transition the farm or ranch from one generation to the next, as well as receive updates on current policy issues that affect farmers’ and ranchers’ bottom lines.
“The reason the conference numbers continue to grow each year is not just because the tours and workshops are interesting, but because we also know how to have fun. This year we’ll hold a competition called the Ultimate Farmer/Rancher Challenge and close out the conference with a comedic hypnotist,” said Day.
For more information visit www.nefb.org or for registration information contact Cathy Day at 402-421-4750.
Statement by Steve Nelson, President, Nebraska Farm Bureau Federation, on Impact of Proposed NE Tax Plan on Farmers and Ranchers
“While we share an interest in job creation and growing Nebraska’s economy, we do not believe you can have a comprehensive tax reform conversation without including property taxes. For farm and ranch families and many Nebraskans, property taxes must be included in the discussion. We are very open to a conversation about Nebraska tax policy and tax reform, however, what was proposed in the Governor’s plan is disappointing in that it reflects a huge tax increase on farm and ranch families.”
“It is widely understood that Nebraska and its citizens have weathered the nation's economic troubles better than the rest of the country due to the strength of agriculture, our state’s number one industry. It is difficult to see how raising taxes on families involved in farming and ranching can help grow the state's economy.”
“Furthermore, Nebraska farmers and ranchers face the prospect of a second year of drought and higher input costs. Agriculture is a cyclical business, and decisions about agriculture’s treatment in our state’s tax policy should be based on historical performance and not simply a few good years.”
“If this conversation is truly about job creation, agriculture and associated businesses are a primary job creator in our state, accounting for one out of every four jobs. Tax policy that harms agriculture will cost the state jobs and will not be good for Nebraska.”
Center for Rural Affairs joins opposition to tax proposal
Nebraska Governor Dave Heineman delivered the details of his proposed tax plan at a press conference here today. The Center for Rural Affairs responded with caution, voicing concerns about the impact the tax plan will have on the state’s ability to invest in building a better future for all Nebraskans.
“An initial review leads us to one conclusion: middle class Nebraskans had better watch their wallets,” said Jon Bailey with the Center for Rural Affairs. “This is a tax shift, not a tax cut.”
According to Bailey, there is plenty of data to show that middle class Nebraskans bear a greater burden from the state sales tax, and this plan increases that burden.
“Additionally, the plan will raise taxes on hospitals, education, small businesses and important community institutions,” said Bailey. “This is not a way to move Nebraska forward.”
Bailey went on to note that now that details of the tax plan have been released, the plan can be fully analyzed for its effects on middle class Nebraskans and for unintended consequences.
Four Finalists for NCTA Dean Job to Interview
Four candidates for dean of the Nebraska College of Technical Agriculture in Curtis will be interviewed later this month and in February. The interviews will include sessions on NCTA's campus and in North Platte. The seminars will be live-streamed. More details will be available at ncta.unl.edu.
Candidates for the position are: Peter Camfield, dean of the School of Agriculture at Oklahoma Panhandle State University; Dann Husmann, associate dean of student affairs for UNL's College of Agricultural Sciences and Natural Resources and professor of agricultural leadership, education and communication; Ron Rosati, provost of Southeast Missouri State University; and Jack Whittier, professor and extension beef specialist at Colorado State University.
The candidates are vying to replace Weldon Sleight, who retired last December.
Camfield also serves as director of Oklahoma Panhandle State University's school farm and formerly worked at Monsanto Choice-Genetics, conducting swine feeding trials and serving as director of the meat quality research program. Camfield received his doctorate in animal breeding and genetics and meat science from the University of Arkansas; his master's in meat science from West Texas State University; and his bachelor's in animal science from Sul Ross State University.
Camfield's interview will take place Feb. 7-8. He will present a seminar at NCTA at 10 a.m. Feb. 7.
In addition to his associate dean role, Husmann teaches undergraduate courses in teacher preparation with emphasis in mechanized systems/management and appropriate graduate courses. Husmann formerly taught career and technical education at South Dakota State University. Husmann received his doctorate in community and human resources from UNL; his master's in agricultural education from Kansas State; and his bachelor's in agricultural education from UNL.
Husmann's interview will be Jan. 28-29. He will present a seminar at NCTA at 10 a.m. Jan. 28.
Before becoming provost at Southeast Missouri State, Rosati served as provost of Alfred State College, State University of New York; dean of the College of Agriculture, Natural Resources and Human Sciences at Texas A&M in Kingsville; and numerous other positions at A&M. He received his doctorate in agricultural education from Iowa State University and his master's and bachelor's in agricultural education from Cornell University.
Rosati's interview will be Jan. 31-Feb. 1. He will present a seminar at NCTA at 10 a.m. Jan. 31.
Whittier's teaching, research and extension work is in bovine reproductive management and nutrition. Before working at Colorado State, he was at the University of Missouri, UNL and Utah State University. He received his doctorate in ruminant nutrition from UNL and his master's and bachelor's in animal science from Utah State.
Whittier's interview will be Feb. 11-12. He will present a seminar at NCTA at 10 a.m. Feb. 11.
OCIA 2013 Annual General Membership Meeting
Be sure to mark your calendars for OCIA's 2013 Annual General Membership Meeting, February 13th-16th in Nebraska City at the Lied Lodge. The blocked room rate for this hotel is $93 (US) per room for single occupancy and $103 (US) per room for double occupancy. Please call 1-800-546-5433 to make your guest room reservation.
The Lied Lodge operates an airport shuttle service to and from the Eppley Airfield in Omaha, NE. The cost for the shuttle is $27 per person, per trip.
Lied Lodge & Conference Center is located on the 260-acre Arbor Day Farm, just outside of Nebraska City (population appx. 7,000). It will inspire you with timbered meeting and guest rooms, exceptional guest service, and award winning food, all in a natural setting.
All proceeds from Arbor Day Farm and Lied Lodge & Conference Center encourage sustainable development practices around the globe and promote conservation and healthier communities through tree planting.
More information here... http://www.ocia.org/news-and-events/news/ocia-2013-annual-general-membership-meeting.
Dr. Huber Featured Speaker at OCIA Meeting
Organic Crop Improvement Association (OCIA) Research and Education invites people to hear Dr. Donald Huber speak at its 2013 Annual Meeting in Nebraska City, Neb. He will be speaking at 7:30 p.m. on Feb. 14 in the West C Corridor of the Lied Lodge & Conference Center. His presentation, which discusses the impacts of glyphosate and GMO's on our food and its link to disease, is free to the public.
Dr. Huber received his B.S. and M.S. from the University of Idaho and his PhD in 1963 from Michigan State University. He has also been formally trained by the U.S. Army military service in sensitive areas such as global epidemiology, national production capabilities and national security.
Among an impressive career focused on plant physiology, microbiology and pathology, Dr. Huber has taught at Purdue University for 25 years as Professor of Plant Pathology. Professor Huber became interested in glyphosate because of the commonly observed increase in the take all disease of wheat following application of glyphosate burn-down herbicide. In the early 1980's, he had established a close correlation of all of the known conditions affecting take-all with an availability of manganese to the plant and its physiological effect on resistance to this pathogen.
Please contact Angie Tunink, Executive Director of OCIA Research and Education, at atunink@ocia.org if you would like to attend this complimentary event. More information can be read about Dr. Don M. Huber online at www.nvlv.nl/downloads/Dr_Huber_bio.pdf.
IFB President Re-elected to National Farm Bureau
Iowa Farm Bureau Federation (IFBF) President Craig Hill was re-elected this week to a two-year term on the American Farm Bureau Federation (AFBF) Board of Directors.
Hill, a Milo livestock farmer, will represent the Midwest Region for the national Farm Bureau board. Other state Farm Bureau leaders elected to represent the region include Kevin Paap of Minnesota, Don Villwock of Indiana and Wayne Wood of Michigan. "I'm honored to have the opportunity to represent Iowa farmers at the national level and be able to work with the American Farm Bureau board once again," Hill said after the election January 15th in Nashville at the AFBF annual convention.
Fourteen other state Farm Bureau leaders were re-elected to represent their regions at the national level of the nation's largest grassroots farm organization. As an AFBF regional board president, Hill will help formulate and direct lobbying of grassroots policies and direct services and programs for the national organization. More than five million Americans in 50 states and Puerto Rico are Farm Bureau members.
Clear Sailing for DDGS
It's official. The classification of U.S. distiller's dried grains with solubles (DDGS) as a non-hazardous cargo became final and mandatory under the code of the International Maritime Organization (IMO) on Jan. 1, 2013. This was the culmination of a process initiated by the U.S. Grains Council in 2010 in coordination with DDGS producers and shippers and the U.S. Coast Guard, which is the official U.S. representative to the IMO.
Actually, the recommendation of the relevant IMO subcommittee and acceptance of that recommendation by the responsible committee of the IMO were obtained in 2010 and 2011. But turning a proposal into a mandatory classification is a multi-year process, said Erick Erickson, USGC director of global strategies.
"Previously, DDGS had not been classified by the IMO. But as DDGS trade grew, several insurance organizations communicated their opinion that DDGS was a hazardous cargo, raising the prospect that DDGS cargoes would be required to be shipped on vessels equipped with special fire suppression equipment – thus raising the cost of DDGS shipments," said Erickson.
Accordingly, in November 2010, after the IMO subcommittee accepted the U.S. proposal to classify DDGS as non-hazardous, the U.S. Coast Guard issued a letter to the Council affirming that the Coast Guard would consider DDGS as non-hazardous. Since that date DDGS has been loaded as a non-hazardous cargo on the authority of that letter. Beginning Jan. 1, the letter is no longer needed as the classification of DDGS as non-hazardous is now final, official and mandatory in the IMO code.
"The Council successfully organized the effort to classify DDGS as a non-hazardous material. That classification ensured lower freight costs to me, in turn increasing returns to ethanol plants," said Steve Markham of Council member CHS Inc.
Following on the success with DDGS classification, the industry asked the Council to take on the issue of corn gluten feed (CGF) and corn gluten meal (CGM). Both of these products were classified as hazardous cargoes in the general category of seedcake. But traders and shippers believed that classification was incorrect. Following a similar pattern as with DDGS, the Council organized the testing of samples and collection of information that enabled the U.S. Coast Guard to prepare a U.S. proposal that CGF and CGM be re-classified as non-hazardous. The IMO subcommittee accepted the proposal in 2012 and the new classification for CGM and CGF will be published in the IMO code in 2014, becoming mandatory in 2015.
An Outlook for Meat Exports in 2013 – Part 1: Top 5 Opportunities
Philip Seng, USMEF President and CEO
After a year of challenges – highlighted by the worst drought in more than a half-century – the U.S. red meat (beef, pork and lamb) industry is focusing on 2013 as a year of great opportunities to increase the value those agricultural exports bring to exporters, processors, producers and the broad American agricultural industry that supports them.
The impact of the 2012 drought – which continues into 2013 – cannot be minimized. An estimated 80 percent of U.S. agricultural land was affected, according to USDA reports. Corn production dipped nearly 13 percent below the 2011-12 crop year and was the smallest since 2003-04 with the lowest yields since 1995-96. Soybean production was down 2.5 percent with yields down 6 percent.
A shortage of livestock feed and the high cost of what was available contributed to herd culling and reduced product availability.
With that dismal scenario as a backdrop, the international markets carried their weight in 2012 in terms of returning value to the red meat production chain. With statistics in for the first 11 months of the year, pork exports continue to exceed 2011’s record highs for both volume and value. And although beef exports are down 11 percent in volume, the value of those products is at an all-time high.
As we continue to explore new market niches and expand the spectrum of U.S. red meat products sold internationally, it is gratifying to see the per-head export values for American beef and pork at record highs: $56.12 per head for pork and $214.64 for beef.
So with 2012’s drought and sluggish global economic results as a backdrop, what is the outlook for 2013?
Entering into any new year, USMEF must evaluate not only market conditions in the United States, but economic, industry and political factors in each of our major international markets. In subsequent installments, I will discuss some of the challenges and question marks that could affect 2013’s export outlook. With the information we have at hand, here is our current viewpoint:
2013 U.S. Pork Export Forecast
With one month missing from last year’s totals, we project pork exports for 2012 to reach 2.27 million metric tons (5 billion pounds) valued at $6.35 billion – both new records. For 2013, we forecast volume and value of pork exports to increase 5 percent, reaching 2.39 million metric tons (5.27 billion pounds) valued at $6.6 billion.
2013 U.S. Beef Export Forecast
With November’s data in hand, USMEF projects beef exports for 2012 to reach 1.13 million metric tons (2.49 billion pounds) valued at $5.5 billion, setting a new value record. For 2013, we forecast exports of 1.24 million metric tons (2.73 billion pounds) valued at $6.2 billion – increases of more than 9 percent in volume and 13 percent in value over 2012 and setting new records for both.
2013 Opportunities – Top 5
There are a multitude of factors that go into an annual export projection. Here are what I would consider the top five markets of opportunity for this year:
No. 1 – Increased Beef Access to Japan: Japan’s Ministry of Health, Labor & Welfare (MHLW) is in the final stages of approving expanded access for U.S. beef – from the current 20-month cutoff to 30 months. An announcement could come as early as the end of this month. While the specific logistical details on resolving access issues must be addressed, this single change, expected to be finalized in the first half of 2013, will provide a major boost to U.S. beef exports.
In 2000, U.S. exports to Japan reached 524,224 metric tons (1.16 billion pounds) valued at $1.77 billion – accounting for 43 percent by volume and 50 percent of the value of all U.S. beef exports that year. At the same time, the U.S. was supplying 53 percent of Japan’s beef imports. Interestingly, the majority of the lost volume of U.S. beef sales to Japan was not picked up by other beef-exporting nations selling primarily grass-fed beef, so the void in the Japan market (2012 imports from all suppliers will be roughly 575,000 metric tons compared to 857,715 metric tons in 2000) is an opportunity for the U.S. to regain lost sales to the highest margin market in the world.
No. 2 – China/Hong Kong: Even without access to mainland China, U.S. beef sales to this region (including Vietnam) have seen steady growth and are expected to rise in the future. While the global beef market stalled in 2012, exports to this region were up about 20 percent to nearly 500,000 metric tons and this does not include the growing volumes of water buffalo from India to Vietnam.
We cannot talk about China without talking about pork. China is both the world’s largest producer and consumer of pork, and over the past few years it has increasingly turned to international suppliers to fill plates at home.
In 2012, China/Hong Kong pork imports remained close to the 2011 record levels, even in the face of an increase in Chinese pork production. Through November the region imported 1.5 million metric tons of pork and variety meats, down just 4 percent from 2012. The U.S. accounts for roughly one-third of the region’s pork imports. China’s rebound in 2012 pork production was no doubt inspired by record-high pork prices (and profitability) in 2011 and China’s increasingly large-scale hog producers likely continued to make money in 2012, with large total hog inventory numbers going into 2013.
USMEF projects solid export volumes to China again in 2013, although price trends – particularly after the Chinese New Year in February – will be a key indicator.
No. 3 – Mexico: Already the No. 1 volume market for U.S. pork, Mexico shows no sign of losing its appetite for U.S. hams, picnics, Boston butts, trimmings and variety meat. The growth of American pork exports to Mexico far exceeded last year’s industry trend. Through 11 months of 2012, Mexico purchased 550,408 metric tons (1.2 billion pounds) of U.S. pork valued at $1.03 billion – increases of 15 percent and 11 percent, respectively, over 2011 and on a pace to set new records. That trend is expected to continue in 2013 as Mexican consumers look for more high-quality, affordable protein to feed a booming population and a growing middle class. And since per capita pork consumption in Mexico is only about 25 pounds per year compared to 47 pounds in the U.S., there is great growth potential.
The outlook for beef exports to Mexico is more reserved due to high prices that are an issue in this cost-sensitive market. Mexico remains the No. 1 volume destination for U.S. beef exports, but growth will be hard to come by as market conditions keep prices high and product scarce, including Mexico’s domestic beef supply.
No. 4 – South Korea: The Korean market was sluggish for all red meat imports in 2012, as the combination of an economic downturn and a brisk rebound in Korean domestic livestock herds after the 2011 foot-and-mouth (FMD) disease outbreak created challenging conditions.
Korea’s domestic beef and pork production are expected to stabilize in 2013, and year two of the Korea-U.S. free trade agreement will bring additional tariff reductions that will enhance opportunities for exports. Even with the challenging conditions of 2012, Korea remained the No. 4 market for U.S. beef exports when measured by value (No. 5 in volume) and the No. 5 pork market. The U.S. also gained market share, accounting for 33 percent of Korea’s pork imports.
No. 5 – Taiwan: This island nation has been a valued trading partner for both the U.S. beef and pork industries, but controversy surrounding the use of the growth promotant ractopamine interrupted exports for much of 2012. With Taiwan’s adoption of the Codex Alimentarius maximum residue limit (MRL) for ractopamine in imported as well as domestic beef, exports of U.S. beef are returning to the point where they were in 2011 when Taiwan was the No. 6 market for U.S. beef.
The controversy has not been resolved for pork, however. While Taiwan’s adoption of the MRL for beef was a very positive step, similar action for pork is still needed. Since Taiwan’s pork sector is, by far, the biggest and most influential sector of agriculture in that country and pork producers have more political clout, resolution of the issue will be more complex.
There are many more opportunities for growth of U.S. red meat exports in the coming year. Pork to Australia. Both beef and pork to Central and South America. Beef to the Middle East. The potential for expanding access for U.S. lamb to key markets currently closed, including Japan.
In the next installment, we will discuss the Top 5 Obstacles to maintaining or growing U.S. red meat exports in the coming year.
Japan's Age Limit for Beef May Rise
Japan's age limit on U.S. and Canadian beef may rise from 20 to 30 months as soon as the end of February. On Jan. 28, the Ministry of Health, Labor and Welfare's Pharmaceutical Affairs and Food Sanitation Council will start studying recommendations regarding raising the age limit. If the council acknowledges the recommendations, within two weeks it will start procedures to raise the age limit. The age limit will then go up to 30 months between late February and early April. Meat from French and Dutch cattle, banned because of bovine spongiform encephalopathy (BSE, also known as mad cow disease), will also be let back in, but with an age limit of 20 months. Also because of BSE, Japan banned beef from the European Union in 2000.
Japan banned beef from the U.S. and Canada in 2003 because of BSE. Beef from both countries started coming back in 2007, limited to meat from cattle aged 20 months or younger, as an anti-BSE measure. The Japanese Cabinet's Food Safety Commission recommended last October the easing of the anti-BSE measures on beef from the U.S., Canada, France and Holland.
U.S. & Canada Agree on Animal Disease Zoning
Canada and the United States are to recognize each other's zoning measures during highly contagious foreign animal disease outbreaks.
Although foreign animal disease outbreaks are very rare in North America, this arrangement will help to minimize trade disruptions while still preventing the spread of disease, should an outbreak occur.
"Cross-border trade in live animals, meat and other animal products and by-products contributes billions of dollars each year to Canada's economy," said Canada's Agriculture Minister Gerry Ritz. "This arrangement will keep U.S. market opportunities open for Canadian producers should a foreign animal disease outbreak occur, all while protecting human and animal health."
This initiative fulfills a commitment made in the December 2011 Joint Action Plan of the Canada-United States Regulatory Cooperation Council, which is aimed at better aligning the two countries' regulations.
The main goal of the RCC is to enhance the economic competitiveness and well-being of the Canada and the U.S., while maintaining high standards of animal health, public health and safety and environmental protection.
Under the arrangement, each country intends to accept each other's decisions on establishing, maintaining and releasing a disease control and eradication zone if an outbreak of a foreign animal disease, such as foot-and-mouth disease or classical swine fever, occurs.
A detailed guidance framework, outlining exactly how the arrangement will work, is under development. The framework will lay out agreed-upon processes and conditions for zoning recognition, and will involve extensive consultation with industry groups, states and provinces.
No comments:
Post a Comment