Former head of California Farm Bureau Federation played instrumental part in many ag issues
California Ag Today enjoyed a recent conversation with Bill Pauli who farms wine grapes and Bartlett pears in Mendocino County on the North Coast.
Pauli was one of many that interviewed at the California Farm Bureau Federation’s 98th annual Conference in Monterey earlier this month.
Pauli served as President of the California Farm Bureau Federation during some very challenging times. “I started clear back in 1981 as a vice-president of the California Farm Bureau, and culminated with president in 2005.
“During that period, I was heavily involved with CALFED and the Delta issues, which are so important to us and for which we’re seeing the issues today with the Delta and water supply and water management and availability,” Pauli said.
CALFED was created because of the importance of the Delta to California. The majority of the state’s water runs through the Delta and into aqueducts and pipelines that distribute it to 25 million Californians throughout the state, making it the single largest and most important source of water for drinking, irrigation and industry.
“I was also involved in a lot of the worker compensation issues, because when Governor Schwarzenegger came in, that was the big issue, or rates and what we were paying. That was always the important issue for me. We had all the other issues related to labor over that period of time, along with the environmental issues that continue to expand.
It’s not news that California Farm Bureau carries the water for almost all the other farming organizations in many ways noted Pauli.
“The thing that’s so unique about the California Farm Bureau, and our county farm bureaus in every county of the state, is that we represent all of agriculture.
CFBF represents 450 different commodities for the individual grower all the way down to the local ag level in California.
We have the big, broad-picture issues, but there’s also the local issues that are so important to the individual producer,” Pauli said.
Ruling in Favor of Army Corps is Game Changer for Agriculture
By Patrick Cavanaugh, Farm News Director and Laurie Greene, Editor
Startling California family farmer, John Duarte, president of Duarte Nursery, Inc., his attorneys, and others who have also kept a close watch on the case, Duarte was dealt a serious blow recently in the biggest fight of his life—the right to farm his own property. This legal outcome may portend a game changer for American agriculture as a whole.
Duarte Nursery and the U.S. Army Corps of Engineers (Army Corps) have been engaged in a long legal dispute over private property rights since the family purchased a 450-acre agricultural property in Tehama County in 2012 and planted wheat that fall.
As reported in, “Duarte Farmland Under Siege,” (California Ag Today, March 11, 2016), John Duarte recalled, “The property is in some slightly rolling grasslands, and has some minor wetlands on it, vernal pools, vernal swales. Like most grasslands, wheat areas and wheat plantings, we had a local contractor go out and plow the field for us, 4-7 inches deep, and we flew on some wheat seed for a winter wheat crop in 2012.”
The U.S. Army Corp of Engineers accused the farm of “deep ripping” the property (three feet deep), “which we were not,” Duarte said. Legal action ensued with the Army Corps issuing a cease and desist notice in early 2013, according to Duarte, without evidence or basis for their accusation. Duarte Nursery attorneys, under the Freedom of Information Act, requested evidence of deep ripping, the assumption that apparently warranted a cease and desist notice.
Without responding, according to Duarte, the Army Corps sustained the cease-and-desist notice without a hearing and without evidence. “They obstructed our farming operations indefinitely,” Duarte said in March 2016.
On behalf of Duarte Nursery, Pacific Legal Foundation attorneys havemoved for reconsideration or certification for immediate appeal on several Clean Water Act issues. “We expect a decision from the court any day on this motion, which will determine whether Duarte Nursery can immediately address the trial court’s legal errors in the appellate court, or will have to go through a trial first on whether the government is entitled to a penalty.” (Source: “Duarte Nursery seeks immediate appeals in Clean Water Act case,” Tony Francois, Pacific Legal Foundation, June 30, 2016)
Reaction to the Ruling
California Farm Bureau Federation and Pacific Legal Foundation attorneys had great confidence that Duarte would be vindicated in the action brought by the Army Corps several years ago. “They are just astounded,” Duarte said. “I thought we might have to go to trial on some of our issues, but I did not think we would lose our issues and have the judge rule against us on the other side,” he said.
Duarte clarified, “We are talking about farming activity that only occurred on rolling land—land with dismal vernal pools and flails.” Duarte noted there is no controversy as to whether this tillage was four to six inches deep. “Both sides agreed this is four to six inch deep tillage. Both sides agree that this property had farmed wheat before,” he said.
“The Army Corps’ position is they don’t know how long is too long, but at some point if you haven’t farmed wheat, you lose your ability to continue farming wheat,” Duarte continued. “As it is a rangeland, you cannot plow your ground without a permit from the Army Corps, which they’re not going to grant because there are wetlands,” he said.
“All of the Food Security Act protections for farming—our ability to idle ground and then bring it back into production—to ensure available food production resources—are gone,” Duarte said. “This is a very extreme ruling. It’s extreme of the law in a lot of different ways. It’s a game changer for agriculture. We’re meeting with Paul Wenger, the president of the California Farm Bureau and seeing what they want to do. I think it’s on a lot of folks’ radar,” said Duarte.
“According to the Clean Water Rule definition of “Waters of the United States” (WOTUS), everything is a wetland and farmers are not exempt,” Duarte stated. “Any tillage that the Army Corps, by their own standards, does not deem to be an ongoing agricultural operation, farmers have liability. Their settlement discussions were in the $5 million to $6 million range, and we’re talking about shallow tillage through vernal pools that covered maybe fourteen or sixteen acres over this property. We can show that those vernal pools are completely intact,” noted Duarte.
Duarte noted that consultants have been at the land to inspect the vernal pool wetlands that concern the Army Corps of Engineers, and have confirmed that all the biology has been restored. “It’s all wetland plants across the vernal pools. They’re not topographically damaged,” said Duarte. “We didn’t re-contour them, we didn’t till them, we didn’t grade them, we didn’t deep rip them such that the restrictive layers of soil no longer perched water—none of that,” he emphasized.
A Game Changer for Ag
“Every property owner should be concerned,” Duarte warned. “Basically, what they’re saying is if wheat is profitable for a window of time because of whatever market or geopolitical reasons, you can farm wheat. If you stop farming wheat for a decade because it’s not profitable, or because you have a lease with a cattleman who’s paying you decent money, or you just don’t have the capital to plant wheat, or you just don’t want to plant wheat, then you will lose the right to farm it in the future. You cannot adjust your farming enterprises to the markets or to your business plans or you will lose your right to farm.”
Duarte believes that the ultimate goal of the Army Corps of Engineers is to be able to tell you what you can and can’t do with your land on any given day. “They want simple control over how you use your property and discretion over what property is put into permanent habitat and what property remains rangeland. They do not believe that private landowners have any inherent right to farm their property to meet market demands.”
As for the ruling, Duarte said he plans to appeal it. “This ruling is in many ways right in the face of several completions that have come down in court last week,” he said. “A lot of this ruling hinges on the opinion in Rapanos v. United States, where senior Associate Justice of the Supreme Court of the United States Anthony Kennedy said wetlands either have to be navigable waters of the United States or tributaries or related.
The significant nexus test requires a determination of whether the water in question – alone or in aggregation with other similarly situated waters in the region – significantly affects the chemical, physical or biological integrity of a traditionally navigable or interstate water or the territorial sea (with “significant” meaning “more than speculative or insubstantial.”). The “region” is the watershed that drains to the nearest traditionally navigable or interstate water or the territorial sea, and waters are “similarly situated” when they function alike and are sufficiently close to function together in affecting downstream waters.
“That was one judge, who had none of the other eight judges agreeing with him,” said Duarte. Nevertheless, Duarte said Justice Kennedy was not correct. “We had four judges that said navigable is navigable. If the Clean Water Act says it exempts, it defines what jurisdictional waters are navigable waters in the United States, and then it defines what jurisdictional waters are. If you look in the Clean Water Act, it says that plowing shall never result in a discharge into waters of the United States,” said Duarte.
“The language in the exclusion of the Clean Water Act is very clear. What this case tells us is that no regulatory legislation can be created with language that is durable to give private parties any protection with the government,” Duarte explained. “There’s no language clear enough that over time will be undermined by agency rule making and judges that give American public any protection against the government.”
“I don’t know how we will solve problems legislatively in the future,” he remarked. “I don’t know that any responsible Congress can pass a law that restricts activity, no matter what the protections,” Duarte said, clearly frustrated. “The Clean Water Act’s protections are incredibly clear. It is not badly worded. The protections are in there. The protections are careful; they’re clearly articulated; they’re very strong, and they’re completely obliterated,” he said.
Duarte is disappointed and has a long way to go in the appeals process. “All I can say is: Warning to all farmers across the land—this is what can happen. We’re just not strong enough, nor is it right for us to carry this entire thing; my family has already spent $1.5 million defending this case, and it’s likely to go to $2 million. We are going to be looking for help.”
Terry Stark’s Final Speech to CAPCA Conference Attendees
By Patrick Cavanaugh, Editor
“They wouldn’t give me a walk-around microphone because they were afraid I would preach, so you guys lucked out,” noted Terry Stark, the feisty, fun-loving professional CEO and President of the California Association of Pest Control Advisers (CAPCA), who led the organization for 10 years.
Stark spoke to CAPCA attendees during the final session of the 40th Annual CAPCA Conference and Agri-Expo in Anaheim, in October.
“And I don’t have a PowerPoint, so you’re going to luck out even more,” he said.
“I am going to talk to you briefly about some of the programs going forward, and how you, as CAPCA members, can make a huge contribution. You heard California Farm Bureau President Paul Wenger and the other general session speakers talk about investment, involvement and belonging; we need you to step up and do that,’ said Stark.
Tell People What You Do!
“With 3,000 PCAs in CAPCA, we’re the third largest association in the state of California, next to the Farm Bureau and Western Growers Association. Commodity boards or mandated programs; and you come to CAPCA because you want to come—because you’re volunteers—and the future will be how you mentor the future PCA generation.”
“How do you do that?” he continued. “You heard two of our speakers say, ‘tell somebody what you do, why you do it, and why you love to do it,'” noted Stark.
“The CAPCA Board was very generous in moving $100,000 dollars three months ago to the Stanley W. Stew Education Fund, Inc. to start the first CAPCA Leadership Institute. We have staff that has been challenged to find champions to go out and raise funds; I don’t care if it is one dollar or one million dollars, to develop a leadership program.
“I love this place. The CAPCA Leadership Institute will inspire plant science students to get their PCA license. And how we’re going do that is that? We’re going to have to our chapters, to our members, and when they talk to anyone with a dollar in their pocket, to make the contribution to the Stanley W. Stew Foundation; its a [501(C)(3)] corporation, its a tax write-off. And Steve Bickley (CAPCA Board NorCal) and I have the project management to develop the protocols on how we’re going to run this,” noted Stark.
“Well, I’m not stupid; we have Shannon Douglas, our coordinator to our Pathway to PCA program, to help out. In fact, we have two dozen-plus PCAs in the room who attended the Leadership Foundation programs up and down the state. We’re going to take that knowledge from the young farmers and ranchers and from the Farm Bureau, we’ll take that Ag leadership, and we’ll make a program in which at least one dozen PCAs on an annual business basis will learn how to conduct themselves around legislators, supervisors, and school boards. In other words, how do you tell someone that you are important?” Stark said.
How to Fix Stupid?
Stark noted that his board is asking a critical question of the candidates for my job, “Can you fix stupid? What I mean by that is when I sit down and talk to PCAs, it’s clear who the smartest person in the room is, and it’s not me,” Stark said.
“So, if you get tapped to be a champion to raise money for the CAPCA Leadership Institute, if you say “no,” I will come back from Texas and hound you until you get your wallet out. I truly believe that that’s going to be the program of the future, it will allow us to reinvest in the `Pathway to PCA’ program.
“When the program headed up by Shannon Douglas was to sunset three years ago, our Ag retailers and basic manufacturers stepped up and funded $300,000 to continue the work. And through those efforts, we have about a 50 PCA license-gain over where we were five years ago. It’s an important program so that we make sure young professionals get that crop protection and crop science education to have a career that can go from 35-40 years. It’s very important,” Stark said.
“When I got on the Board of Directors, I was the oldest guy on the Board. You’ve been in business for 40 years and you’ve done certain things the same way for 30 years, and my job was to help point that ship in a direction where you could have another 40 years. And one of the accomplishments, again, is the generations have changed and we’ve got a younger board of directors now. We have the enthusiasm of a younger board now, and through the leadership of Gary Silveria (CAPCA Vision Planning Committee Chairman), we have crop teams on the table now.
“Ok, you’ve heard crop teams talked about by Jeremy Brisco (CAPCA Executive Committee Chairman) yesterday. Not everyone can leave the field, leave their office, drive to Sacramento, sit in a room for an hour and a half, and drive back to San Diego or Desert Valley or up to Chico. So, how do we get our intellectual knowledge moved forward and yet still be recognized by who you are and why you do what you do?” said Stark.
“We’ll start with 8 areas of crop teams, but the ideal is we’re inclusive. We’re going to use Skype and Go to Meeting technology, and you don’t have to drive five hours to get there. This is the educational gap change that the younger guys and women can do so much better than us older guys,” Stark noted.
The Right Champions in Place
“But we recognized that gap, pre-drought, when we had the legislative bore, and there was no money in the budgets, no taxes. You know the University of California is going through the same attrition, and all of a sudden, counties couldn’t send their Ag Commissioners to meetings and Extension people couldn’t travel, or we couldn’t replace their expertise,” Stark noted. “We’ve got 3,000 experts. You will travel, you will provide the leadership and you will succeed. My goal in making this happen for the board of directors is that we have the right people in place. Gary Silveria has put the right champions in place on these crop teams, so if you get asked, `do you want to help with almonds, or do you want to help with strawberries,’ the answer is `Yes, I want to help!’”
“And I guarantee you we will be—CAPCA will be—in 3-5 years—the go-to expert at any of those crop protection incidents that will occur. And you will be standing side-by-side with UC Agricultural and Natural Resources Extension people and the commodity board research folks in fighting the problems. That’s what you will accomplish. That is innovative! I know some of my chapters are going to say, `what are the chapters going to do?’ and I’ll say this, `you have a purpose!’”
“Find that purpose. I’m not going to tell you what your purpose is…. you find your purpose. And you make the crop teams successful. And you make the Pathway to PCA successful. It’s all about being positive; one of our speakers said, `don’t say anything you can’t do.’ Hell, I’ve never said I can’t do anything, said Stark.
As people have become more interested in the sources of their food, they have also become more interested in reading about where their food originates and about the people who produce it: That was the concept behind a seminar conducted in San Francisco last week titled “Journalism: The Agriculture Beat Resurgence.”
Hosted by the Commonwealth Club, the event featured three Bay Area-based reporters and editors who write about agriculture for regional or nationwide audiences.
The discussion provided insights into how the reporters view their work, and into the overall interest in agricultural reporting itself: The seminar attracted a nearly full-house audience of about 80 people on a Wednesday night.
It also underlined the continuing importance of Farm Bureau’s efforts to reach out to members, reporters and the general audience through all forms of media.
The moderator of the panel discussion, KQED Radio reporter/anchor Rachael Myrow, described the agriculture beat as “the intersection between fashion, health and politics.”
The panelists agreed, noting how agricultural news can be classified as a business story, an environmental story, a cultural story.
“Every story is an agricultural story,” said Andy Wright, deputy editor of Modern Farmer, which produces a quarterly publication and daily website updates aimed at an audience she described as young, urban and aspirational.
Where do they find story ideas? The reporters said they talk to farmers at farmers markets, talk to chefs, scan trade publications and websites, and listen to story pitches from farmers and people in the food business.
“Farmers are getting a lot more media savvy,” Wright said. “They’re on Facebook and Twitter. They understand the importance of connecting.”
Naomi Starkman of Civil Eats—a Web-based news service that says it aims to “shift the conversation around sustainable agriculture in an effort to build economically and socially just communities”—called social-media tools “essential” to promoting stories, and encouraged farmers to hire someone on their staff who does social media and other outreach as a part of their job.
Myrow noted that much of the current reporting on agriculture focuses on “small, niche” farms.
“Are too many publications chasing the foodies instead of informing the general public about their food?” she asked.
“What’s unproductive,” Wright responded, “is to pit big ag vs. small agriculture. What’s more important is to focus on what’s working.”
During part of the program devoted to audience questions, the panelists were asked if they consider themselves to have a mission to try to change people’s behavior.
Tara Duggan, a food writer for the San Francisco Chronicle, said she considered it her mission to “understand what readers are most interested in,” which, in her case, tended to be topics such as nutrition and sustainability.
In her case, Wright said, “I don’t know that it’s my role as a journalist to promote one way of eating vs. another. My role is to get stories to as wide an audience as possible.”
Duggan noted that writing for a general-interest publication such as the Chronicle presents challenges in presenting stories about farming and environmental topics. For example, she said, “With the California drought, I feel people have reached the saturation point, even though it’s a really important story.”
As the event’s organizers pointed out, the agriculture beat was once a key area of coverage for large media outlets but, as the staffs of mainstream media outlets have shrunk, agricultural reporting has been dispersed among writers who regularly handle business stories, environmental stories or general-assignment reporting.
Still, there’s significant interest in stories about farming and food among both the general media and the specialty publications, websites, blogs and other outlets that have proliferated in the last few years.
We’ve seen that here at the California Farm Bureau, where we respond to more than 450 news media inquiries a year. During 2014, driven by interest in the impact of drought on farmers and ranchers, we have spoken with reporters from throughout California and the nation, as well as to media outlets from Canada, Germany, Switzerland, France, Japan, Singapore and Australia.
For Farm Bureau, communicating with members and the non-farm audience has always been a core function, using all forms of media. That’s why, for example, stories from Ag Alert® appear not only in the newspaper, but online and as Facebook posts and tweets, as well.
Our California Bountiful® television program—produced for a non-farm audience—can be found on the air and also online and on YouTube. The TV program and California Bountiful magazine also reach out to general audiences via Facebook, Twitter, Pinterest and Instagram.
None of the outreach that Farm Bureau does would be possible without the support and cooperation of Farm Bureau members, who give of their time to talk to reporters from our media outlets and from other television, radio, newspaper and online news media every day.
As the San Francisco event showed, people are interested in what farmers and ranchers do, how they do it, and why. Only by telling their stories themselves can farmers and ranchers assure that others don’t tell their stories for them.
Discussion has intensified about proposed changes to the Federal Clean Water Act. As farmers and ranchers express increasing concern about enhanced permitting requirements, land-use restrictions and legal liability that the proposal could cause, the U.S. Environmental Protection Agency launched its own campaign to defend the proposal.
Agricultural leaders want the EPA to scrap the proposed rule changes, terming them a poorly orchestrated attempt to expand agency jurisdiction. The proposed rule was published in April, and remains open to public comment until October.
County Farm Bureaus in California are joining the national push to have the proposed rule changes withdrawn, reaching out to members of the state’s congressional delegation and urging the proposal be stopped.
Meanwhile, the EPA called its proposals merely an effort to clarify regulatory jurisdiction, which was called for in two U.S. Supreme Court decisions that ruled against the agency’s attempt to expand its jurisdiction over “waters of the United States.” EPA said the proposed rule would have minimal economic impact and would not affect many acres—only about 1,300 acres nationwide.
The American Farm Bureau Federation called that assertion “laughable,” considering the amount of land nationwide that has the capacity to retain seasonal moisture, a condition covered by the proposed rule. Under the proposal, legal experts say, wet spots could be deemed “waters of the U.S.”
AFBF said the EPA effort to expand its jurisdictional authority over most types of waters and lands is regulatory overreach that has the potential to impose costly and time-consuming federal permit requirements, as well as place limits on routine farming practices, such as building a fence across a ditch or pulling weeds. Essentially, EPA has proposed regulations that fundamentally redefine “waters of the U.S.” and eliminate the term “navigable” from the law, AFBF said.
“We’re urging Congress to take a look at the proposed rules and we’re urging the agency to withdraw both of them,” California Farm Bureau Federation Federal Policy Manager Rayne Pegg said, referring to both the main EPA proposal redefining “waters of the U.S.” and an “interpretive rule” that focuses on agricultural activities.
Pegg stressed that farmers recognize the need to protect water quality, and already abide by a number of water-quality regulations.
“Adding another layer of regulation does not mean you will get better results,” she said. “Instead, the rule will create more paperwork. It’s a poorly conceived rule. EPA should meet with farmers and listen to its own Scientific Advisory Board to craft something that is practical.”
There are a number of things going on in Congress right now related to these rules, she said, and CFBF has been responding to questions from members of congressional committees—including the House Appropriations Committee, which is considering legislation to remove funding for implementation of the proposed waters of the U.S. rule.
In response to the uproar over the proposal, EPA Administrator Gina McCarthy took to the road last week—touring a Missouri farm and meeting with a number of Kansas farm groups. She acknowledged during a lunch discussion with agricultural leaders the waters of the U.S. proposal has “fallen flat on its face.”
But during a speech in Kansas City, she charged that the EPA proposal has been beset by “D.C. myths.”
“Misinformation is becoming the story, while the legitimate, serious issues that we need to talk about are taking the back seat,” McCarthy said.
At the same time McCarthy visited the Midwest, the Natural Resources Defense Council—an environmental organization—took out advertisements supporting the EPA proposal.
Confusion about what the proposed rule may actually cover and conflicting interpretations of the rule changes may leave political leaders with the impression the proposal is benign and that farmers don’t need to worry, said CFBF associate counsel Kari Fisher.
“EPA would like political leaders and the public to believe that all farmers need to do is go ahead with normal farming practices and not worry about the proposed changes,” she said. “Unfortunately, that’s incorrect.”
Fisher said the interpretive rule on agriculture would require certain farming practices—such as putting in a new fence or maintaining a ditch—to comply with U.S. Department of Agriculture standards administered by the Natural Resources Conservation Service. She noted that the interpretive rule would apply only to Section 404 of the Clean Water Act, which covers dredging and infilling land that could affect wetlands.
But the proposed rule to expand the definition of “navigable waters” applies to the entire Clean Water Act, she said, and would expand EPA jurisdiction over water.
“If the proposed rule redefining waters of the U.S. is adopted, farmers with land that features a depression or low spot that’s adjacent to a tributary flowing to navigable water could be brought under the rule’s jurisdiction,” Fisher said.
Although the interpretive rule might provide a limited layer of protection for farming and ranching activities from the need to obtain Section 404 permits, she said, “it will not provide protection from other necessary Clean Water Act permits, such as those for the discharge of pollutants.”
Farm Bureau leaders continue to urge members to help prevent the proposed rule from becoming final by commenting about the impact the proposal would have on their farms and ranches.
For information on arranging local farm tours, grower roundtables and informational meetings with members and staff of California’s congressional delegation, contact county Farm Bureau offices or the CFBF Federal Policy Division at 916-561-5610.
Source: Eddie Hughes; Fresno State News and Fresno County Farm Bureau
Fresno State senior Levy Randolph of Hemet earned the individual state championship in the California Farm Bureau Federation’s Young Farmers and Ranchers Collegiate Discussion Meet on March 1 in Visalia.
The discussion meet competition was designed for young members of the farm bureau to participate in a progressive and collaborative discussion. Participants are judged on content, cooperative attitude, presentation and knowledge of the pre-determined speaking topics.
Competitors discuss pressing issues of the agriculture industry and strive to cultivate solutions from their 20-minute discussion.
This was Fresno State’s fourth team championship all-time and Randolph will be the fifth Bulldog to represent California at the national competition.
Randolph’s winnings included an expense-paid trip to the national competition and a cash prize of $1,250.
Joining Randolph in the final round of competition was Fresno State Agricultural Communications major Jodi Raley of Tollhouse. Raley earned a $500 cash prize. Audra Roland, an Agricultural Business major from Tollhouse, made it to the semifinals.
Dr. Steven Rocca, professor of Agricultural Education and Communications, has coached the competition since 2006. “Our students’ hard work and dedication led to the overall team win,” Rocca said. “We are thrilled that one of our students earned the state championship, enabling our team to become back-to-back champs. The skills these students learn will be valuable tools in their future as our agricultural leaders.”
Additional members of the team include: Ana Lopez, an Animal Science/Pre-Veterinary major from Tulare; Victor Evans, an Agricultural Education-Teacher Preparation major from Fresno; Kyle Mendes, an Agricultural Education-Teacher Preparation major from Modesto; Rachel Wright, an Agricultural Communications major from Tollhouse; and Mallory Harrison an Agricultural Communications major from Bakersfield.
The Young Farmers and Ranchers are active agriculturalists, ages 18 to 35. Members develop leadership skills through community service, service-learning and maintaining active involvement in their county farm bureaus.
The Jordan College of Agricultural Sciences and Technology (JCAST) offers education needed to be a leader in agriculture and related sciences. They offer programs in the traditional areas of agriculture, including animal science, plant science, agricultural education, viticulture and agricultural business.
JCAST also offers excellent programs in areas uniquely related to agriculture, including industrial technology, food science and nutrition, enology, child development, family science and fashion merchandising.