Water Management

Why EPA Says Farmers and Ranchers Won't Need a Lawyer to Understand the Newly Proposed WOTUS Rule

Fri, 21 Nov 2025 16:10:31 GMT

Agricultural groups have been asking for a new WOTUS rule that eliminates red tape and clears up confusion for farmers and ranchers. As EPA unveiled its latest proposed Waters of the U.S. (WOTUS) rule this week , Deputy Administrator David Fotouhi says the agency’s goal was simple: clarity, consistency and fewer regulatory headaches for farmers and ranchers.

Fotouhi joined “U.S. Farm Report” for an exclusive interview to break down what this new rule means and why EPA believes it hits the mark.

A Rule He Says Brings Clarity and Certainty

Fotouhi says the agency’s top priority is eliminating uncertainty farmers have faced under previous interpretations of WOTUS.

“We really emphasize the need for farmers, ranchers and all stakeholders to have clarity in terms of how broad or narrow federal regulation of waters is in this country,” he says. “From Day 1, we start working on a proposed rule to bring that clarity and certainty to landowners across the country. On Monday, we are able to announce a proposal that is consistent with the law, that provides needed clarity on the extent of federal regulation, and that recognizes the primary jurisdiction of states and localities because they know their resources best.”

He adds that the proposal strikes what he calls a good balance.

“We think we really strike a good balance between protecting our nation’s waters and making sure farmers and ranchers can do the work that feeds Americans and produces the fuel this country relies on — without adding unnecessary regulatory burden to their day-to-day life,” he says.

EPA Says Farmers “Won’t Need a Lawyer” to Understand the New Rule

Fotouhi stresses one of EPA’s biggest priorities in rewriting WOTUS was ensuring farmers no longer need legal help just to determine whether they can work their own ground. He says the agency intentionally crafted the language to be plain, practical and rooted in the realities producers face every day.

“We take a fresh look at the Supreme Court’s direction and try to apply that in language that is easily understandable. Producers should not need a lawyer to understand how this rule applies to their property. We write it in a way that lets farmers look at their land and have a clear sense of whether federal permits are required.”

Fotouhi explains past WOTUS rules often included terminology that was vague, overly technical or open to interpretation, something EPA heard repeatedly during outreach with farm groups.

He says the agency makes a conscious effort to eliminate that ambiguity.

“We listen to farmers tell us repeatedly that the rule has to be understandable,” he says. “So instead of broad definitions that leave too much room for interpretation, we focus on concrete, workable language. We take geographic differences into account, we remove subjective criteria and we make exclusions, like the groundwater exemption, explicit so there’s no second-guessing.”

Fotouhi says that level of clarity is a direct response to years of frustration in rural America.

“We know farmers need certainty,” he says. “They need to know what they can and can’t do without waiting months for an answer. That’s why we put so much effort into making this rule clear, transparent and grounded in what the Supreme Court actually tells us to do.”

EPA Pushes Back on Claims the Proposal Overpromises

Some critics argue the agency risks overpromising. Fotouhi strongly rejects that idea.

“We take a fresh look at all the critical issues the Supreme Court lays out in the Sackett decision,” he says. “We think the previous administration does not faithfully implement that decision when they revise the rule, so we come back, reassess everything and come up with a definition that fully implements what the Court tells EPA and the Army Corps to do.”

He notes the agency made readability a priority.

“We try to apply the Court’s direction in language that is easily understandable, that takes geographic differences into account, and that doesn’t impose unnecessary burdens on farmers when they’re trying to decide if they need a permit,” he says.

Groundwater Exclusion: “We Want It Crystal Clear”

One standout change is the explicit exclusion of groundwater — language EPA says is included to eliminate confusion.

“Groundwater has never been part of the Waters of the United States, but we think it is absolutely necessary to make that exemption clear as day so there is no confusion about whether someone would need a permit for a discharge that may impact groundwater,” Fotouhi says.

He says repeated questions from stakeholders and newer case law convinced the agency to spell it out directly.

“Based on the case law that’s come out in the last few years and the general confusion we hear from stakeholders, we think it is incumbent on us to clarify this as clearly as we can,” he adds.

Final Rule Expected in Early 2026

EPA filed the proposal with the Federal Register , which means the rule’s comment period is officially underway.

“We publish the rule today, and it will be out for public comment for 45 days,” he says. “We know there is an absolute need for certainty and clarity and one nationwide standard, so we move quickly. We are hopeful that in the first few months of 2026, we can have a final rule out for the public.”

RFS: EPA Reviewing Comments, Aims for Certainty

Fotouhi also discusses EPA’s proposed Renewable Fuel Standard volumes, including record-setting biomass-based diesel levels.

“We understand how important it is to get this exactly right. From day one, Administrator Zeldin is laser-focused on ensuring the RFS strikes the right balance,” he says. “We know farmers and all stakeholders implicated by this program need certainty. We are working as quickly as we can to take final action.”

EPA’s Deregulatory Push: More Actions to Come

Fotouhi says the agency’s deregulatory actions announced earlier this year will have significant impact on agriculture.

“Reducing the cost of energy is one of our biggest focuses,” he says. “Many of the actions we identify are aimed at reducing energy prices for farmers, ranchers and manufacturers so we can reduce input costs and ultimately reduce the cost of the products they produce.”

This is evident through their efforts on WOTUS.

“The WOTUS proposal is a prime example; it’s designed to reduce unnecessary and illegal regulatory burden, and we are undertaking a score of additional actions across offices, working with USDA, the Department of Energy and the Interior Department, to identify ways to reduce input costs for agriculture,” Fotouhi says. “A thriving agricultural sector is a priority for the president, and lowering consumer prices is something we have to achieve.”

Breaking News: EPA Backs Existing Wastewater Regulations, Prevents Catastrophe for Processors and Producers

Sat, 30 Aug 2025 20:37:08 GMT

The longstanding Meat and Poultry (MPP) Effluent Guidelines and Standards will stand, announced Environmental Protection Agency (EPA) Administrator Lee Zeldin on Aug. 30. He says the proposed changes to the regulation are unnecessary.

EPA determined existing federal wastewater regulations under the Clean Water Act are effective and the burdens proposed changes would inflict on meat and poultry processors are unwarranted.

“The National Pork Producers Council (NPPC) applauds the Trump administration and EPA Administrator Zeldin for taking a common sense approach on the Meat & Poultry Processing Rule,” says Duane Stateler, NPPC president and pork producer from McComb, Ohio. “As proposed by the previous administration, this rule—which provides no environmental benefits—would have been devastating to small- and medium-sized meat processors across the country and the livestock farmers who rely on them as markets for their animals.”

EPA’s action will save not only the nearly 100 local meat processors that EPA itself identified would have to close down but also the thousands of family farmers who rely on them to stay in livestock production, Stateler points out.

“It will help ensure affordable, nutritious American-grown pork can continue to be served on dinner tables across the country,” Stateler says.

Moving Forward
The decision closes the book on a nearly two-year comment and consideration process in which NPPC and other stakeholders have worked with EPA to better inform the agency’s decision and preempt unnecessary harm.

“Under the prior proposal, if it were finalized, major pork processors would have faced significant costs to install new waste water management systems,” explains Michael Formica, NPPC chief legal strategist. “During that period of construction, some plants would likely have needed to temporarily shut down. Others might have had to cut back on how many shifts they run.”

EPA’s internal analysis showed that dozens of facilities, likely small and medium-sized, would be forced to shut down because they would be unable to afford the cost of the technology required to comply, Formica says. Overall, the industry would have realized additional costs estimated at greater than $1 billion a year.

“Producers who rely on those processors would have then been without a market for their livestock,” Formica adds.

Unnecessary Expansions
The Meat and Poultry Products Effluent Guidelines and Standards was enacted in 1974 by the EPA and amended in 2004 to cover wastewater directly discharged by processing facilities. NPPC says the proposed amendment would have established more stringent technological requirements for controlling discharges from processors and significantly increased the scope of plants that were covered by the rules.

While the agricultural industry and the meat and poultry processing sectors support clean water efforts, EPA found these expansions were unnecessary.

NPPC says it appreciates EPA taking no action on the proposal, which would have disrupted packing capacity and livestock markets, in turn inflicting additional financial harm on producers and leading to further industry concentration and the loss of independent farmers.

The Meat Institute says the proposed rule would have also harmed the relationship between meat and poultry processing (MPP) facilities and publicly-owned treatment works (POTWs).

“Indirect discharging MPP facilities often make significant financial investments in maintaining and upgrading the POTW or shouldering major surcharges for the POTW’s continued operation and maintenance, which reduce public treatment costs for residential ratepayers and improve the quality of local and downstream waters,” the Meat Institute wrote in a statement.

Equipment Malfunction Causes Manure Spill in Ohio, Sparks Vital Lessons for Farmers

Tue, 19 Aug 2025 20:06:09 GMT

A farming equipment malfunction is the cause of a manure spill that turned a creek red in Wyandot County, Ohio, reports the Ohio Environmental Protection Agency (Ohio EPA).

According to Glen Arnold, field specialist and manure nutrient management systems professor at Ohio State University Extension, a part broke on the irrigation system that allowed the manure to flow into nearby Carey Creek, also known as Poverty Run. An alarm system should have indicated a problem did not work properly. Ohio EPA reports that the red color stemmed from a discharge of liquid manure that was pulled from an anaerobic manure lagoon on a nearby hog farm.

“As soon as it was discovered, the farmers shut the manure source off and took steps to pump the manure-contaminated water back out of the creek,” Arnold explains. “This time of the year in Ohio, we are at a minimum flow time. We haven’t had much rain, so the creeks wouldn’t have much water to carry manure downstream.”

An example of equipment being positioned to remove manure from a ditch.

(Glen Arnold)

This means the manure-contaminated water wouldn’t travel very far, he says.

Carey Creek is not a drinking water source, Ohio EPA reports. It flows into Tymochtee Creek then the Sandusky River.

Fortunately, no impacts to wildlife have been reported, Ohio EPA says. Cleanup is underway by a contractor hired by the farm. The farm is working closely with Ohio EPA, Ohio Department of Agriculture, Ohio Department of Natural Resources Division of Wildlife, and the Local Soil and Water District. Ohio EPA will continue to oversee cleanup until the issue is resolved.

Why Did the Water Turn Red?
Reports said the creek turned a light red to a pink color. Although this may seem odd to most people, for those who understand anerobic lagoons, this is anything but weird.

“That would be pretty standard for a manure lagoon,” Arnold says. “In lagoon situations, you’re hoping the bacteria will break down the solids that are in that manure pond or lagoon. You don’t generally pump it all the way out, you basically pump liquids off the top on a regular basis. Because of the bacteria that are working together to make that lagoon work as it should, the liquids generally have a red tint.”

For the most part, liquids are being pumped off the top of the manure pond or lagoon, he explains.

“It’s low-nutrient water – most of the high nutrients are down in the bottom,” Arnold says. “In that situation, that red tint that was in the manure pond then gets transferred into the creek. It’s not more toxic or more dangerous in any way, but that was the color of the original liquid manure.”

Ohio EPA reports this red tinted color is caused by purple sulfur bacteria commonly found in anaerobic manure lagoons. This color means the lagoon is working properly.

How Should You Handle a Manure Spill?
If a spill occurs, Arnold says the first thing producers should do is contact the local authorities. In Ohio, it’s generally the Soil and Water Conservation Service District, but some larger permitted farms can call the Ohio Department of Agriculture directly.

“Malfunctions happen,” Arnold points out. “Anytime a problem like this occurs, quick action is the best way to go. Get the situation mitigated as quickly as possible. Get the source stopped, get the creek or river dammed up, contain the spill, and then we can pump it back out.”

A manure tanker sucking up liquid manure from a emergency sump hole dug in a corn field.

(Glen Arnold)

He says it’s important to remember that you can’t rely 100% on technology at all times.

“You have to put eyes on the manure application process,” Arnold says. “You have to put eyes on the field tile. You’ve got to put eyes on surface ditches and be sure they’re not allowing the manure to escape from a field. It’s important producers give thought to their first line of defense and second line of defense to prevent these things from happening.”

After everything has been done to pump the water out, Arnold says the next step is to mitigate or improve the quality of the water through aerification.

“Aerification is where we shoot the water up in the air to let ammonia get out of the water, and to add oxygen to the water,” he says. “We can put bubblers in the water to bubble air into it to improve the water quality or add some additional water from a source like a fire truck or water tanker to get fresh water into the creek or ditch.”

He says this is important because manure contains ammonia, and ammonia will bind with the oxygen in the water, making it unavailable for fish, crawdads and other aquatic life.

“It’s always difficult once a manure spill has occurred to think clearly and follow a plan,” he says. “I would encourage producers to think through the steps they would take if a spill occurred. Who would you need to contact? Do you have their cell phones handy? What equipment would you need to get your hands on?”

Respect Authorities When a Manure Spill Occurs
It probably goes without saying, but it’s important to cooperate with the authorities when a spill occurs, Arnold adds.

“The agency people have a job to do,” he says. “I know how it feels – you are partly embarrassed because you’re the center of attention, and farmers rarely want to be the center of attention. You’re partly mad at the equipment that broke, or the unexpected clay tile that allowed the manure off the field that you didn’t know about in advance, or the fact that the neighbors are going to be watching you now.”

Manure being sucked from a ditch after a spill.

(Glen Arnold)

If you’ve got a solid track record and are upfront about what happened, the authorities will generally work with you to resolve it, Arnold says.

“But if someone shows a bad attitude or has a history of repeated manure escapes or spills, that’s a very different situation. The best thing you can do is demonstrate that you’re taking responsibility and making every effort to do the right thing.”

Tips for Smooth Manure Application
The old adage that ‘an ounce of prevention is worth a pound of cure’ is true, especially when it comes to manure management.

“We don’t want to make mistakes when handling manure,” he says.

Although manure is an organic product that breaks down rapidly and does not last long in the environment, having a manure spill is disruptive, troublesome and costly.

Remember to look closely at fields this time of year before you apply manure, Arnold says.

A temporary dam built in a corn field to stop swine from manure escaping after an equipment pumping failure.

(Glen Arnold)

“Because of our clay content in our soil, we’re going to have a lot of cracks,” he says. “We use tillage to disrupt those preferential flows, the worm holes, the cracks in the soil, crawdad holes, and those types of things.”

He also urges producers to understand the tile structure in the field where manure is being applied. Check the weather forecast before applying manure, and of course, apply manure at the proper rate.

“Farmers live as close to their hog buildings as anyone in the community,” Arnold says. “The same groundwater and surface water that their families drink is the water we all depend on. Pork producers want to do right because they hope their children and grandchildren will remain on the land and be part of the farm’s future. Protecting water is not only about farming responsibly — it’s about safeguarding our own families and neighbors.”

Cheryl Day, Ohio Pork Council executive vice president, says producers are already doing a responsible job managing nutrients, but no one can afford complacency.

“Every decision we make on manure handling and application matters,” Day says. “One mistake can set back the progress our industry has made and risk both water quality and community trust. Stewardship isn’t optional — it’s our responsibility, and it must remain our highest priority.”

No one plans for a spill, but planning for the unexpected makes all the difference. Farmers who know their tile maps, watch the forecast, and have response plans ready are protecting more than their farms — they’re protecting their communities.

EPA To Address ‘Government Overreach’ on Defining WOTUS

Thu, 13 Mar 2025 20:49:01 GMT

EPA Administrator Lee Zeldin announced on Wednesday the agency will undertake 31 historic actions “to advance President Trump’s day one executive orders and power the great American comeback.”

Among the announcements, Zeldin said EPA will work with the United States Army Corps of Engineers to deliver on President Donald Trump’s promise to review the definition of Waters of the United States (WOTUS).

“The agencies will move quickly to ensure that a revised definition follows the law, reduces red tape, cuts overall permitting costs, and lowers the cost of doing business in communities across the country while protecting the nation’s navigable waters from pollution,” Zeldin said in a prepared statement.

“Given the U.S. Supreme Court’s watershed decision in Sackett v. Environmental Protection Agency, it is time for EPA to finally address this issue once and for all in a way that provides American farmers, landowners, businesses, and states with clear and simplified direction,” he added.

Zeldin’s announcement was an important step forward in correcting what the Supreme Court had ruled in 2023 as EPA’s overreach in defining WOTUS. At the time, the agency had charged ahead ignoring concerns raised by the Supreme Court, 26 states, and farmers and ranchers across the country, according to American Farm Bureau Federation (AFBF) President Zippy Duvall.

“The Supreme Court clearly ruled, almost two years ago, that the government overreached in its interpretation of what waters fell under federal jurisdiction, but inaction and vague implementation guidelines by EPA led to permitting delays, litigation and uncertainty,” Duvall said in a prepared statement on Wednesday.

Listening Sessions Are Being Scheduled By EPA
Mary-Thomas Hart, chief counsel for the National Cattlemen’s Beef Association (NCBA), told AgriTalk Host Chip Flory on Thursday the Supreme Court had ruled EPA’s overreach on WOTUS in 2023 amounted to a violation of a landowners’ constitutional rights.

“Because there are criminal liabilities that attach to violation of the Clean Water Act, a landowner has to be able to know when they look at their land or when they look at a water feature, what is or isn’t WOTUS,” Hart said.

A priority for the Trump Administration moving forward will be working cooperatively with state partners, empowering them and local officials to protect water bodies while accelerating economic opportunity. As a result, “decisions will be made efficiently and effectively while benefiting from local knowledge and expertise,” EPA’s Zeldin said.

To inform those decisions, EPA has issued a request for information from stakeholders about how they’re impacted by WOTUS and will host a series of listening sessions from late March through April 2025, according to information on the agency’s website.

EPA will hold at least six listening sessions, with two open to all stakeholders, one open to States, one open to Tribes, one open to industry and agricultural stakeholders, and one open to environmental and conservational stakeholders.

The agency said registration instructions and dates will be forthcoming at the following website: https://www.epa.gov/wotus/public-outreach-and-stakeholder-engagement-activities.

Persons or organizations wishing to provide verbal recommendations during the listening sessions will be selected on a first-come, first-serve basis. Due to the expected number of participants, EPA said individuals will be asked to limit their spoken presentation to three minutes. Once the speaking slots are filled, participants may be placed on a standby list to speak or continue to register to listen to the recommendations.

Listen to the AgriTalk discussion on WOTUS with NCBA’s Mary-Thomas Hart here:

Online Estimators to Help You Reduce Energy Use

Wed, 21 Sep 2022 02:45:40 GMT

Still trying to nail down a good New Year’s resolution? How about pledging to use less energy on your farm in 2011?

With some help from the Natural Resources Conservation Service (NRCS), you should be able to do just that. NRCS has developed four online energy tools designed to help you understand where you are spending your energy dollars and help you reduce those costs.

The tools allow you to input your farm-specific information which generates recommended modifications that can save you money.

The four different energy estimators cover:

Animal Housing
This estimator applies to swine, poultry or dairy cattle housing operations. It evaluates major energy costs in lighting, ventilation, heating, milk cooling, water heating and milk harvesting.

Irrigation
Pumping water for irrigation can be a major drain on the pocketbook. With this estimator, you can analyze your irrigation costs based on your current energy prices, the type of crop and pumping requirements.

Nitrogen
Fertilizer is a high enough input cost, no one wants to contribute any extra dollars to it. With this estimator, you can calculate the costs and potential savings for nitrogen use on your farm. You input the crop you’re growing and the form of N you will use, along with your application rate and price. The estimator then provides you with predicted savings based on alternative application methods and rates.

Tillage
How much money would you save if you switched from conventional tillage to ridge-till or no-till? This energy estimator tells you just that. Simply enter your crop acres and local diesel fuel price and see which tillage system pays off for you.

For additional assistance on energy savings, you can contact your local NRCS office. Access the tools online at http://energytools.sc.egov.usda.gov/

The Next Chapter of WOTUS

Tue, 07 Dec 2021 22:26:51 GMT

EPA and the U.S. Army Corps of Engineers published a rule in the Federal Register on Tuesday, initiating updates to the pre-2015 regulatory definition of the Waters of the United States (WOTUS) rule.

A June 2021 statement made by the Biden administration detailed plans to repeal the Trump administration’s Navigable Waters Protection Rule (NWPR) promulgated under WOTUS in 2020. New regulations defining federally protected waterways under the Clean Water Act were then announced in November by EPA and the Army Corps of Engineers.

This transition was made possible in August, following a federal judge in Arizona vacating the Trump-era NWPR due to the rule violating the WOTUS objective “to restore and maintain the chemical, physical, and biological integrity of the Nation’s waters.”

EPA Administrator Michael Regan says the proposed transition was created to bring clarity and consistency to WOTUS: “Through our engagement with stakeholders across the country, we’ve heard overwhelming calls for a durable definition of WOTUS that protects the environment and that is grounded in the experience of those who steward our waters.”

Historically, the original 1986 regulations have been implemented by every administration since their inception 35 years ago, apart from the Reagan and Trump administrations.

EPA and the Army Corps of Engineers are seeking public comment on the proposed rule, to be submitted here .

Dan Murphy: H2OMG!

Fri, 20 Nov 2020 05:49:40 GMT

It’s seemingly abundant, yet surprisingly scarce; rarely prioritized in public policy, yet as essential as oil for supporting our lifestyles. And if water ‘runs out,’ it could signal the ultimate disaster.

Water.

We grow up, having survived middle school science classes, believing that water is an absolutely abundant element on Earth. After all, the oceans cover more than 70% of the Earth’s surface, and if there’s one fact I’ve retained from all those long-ago lessons in Mr. Moynihan’s 7th grade science course, it’s that Mt. Everest could easily fit into the Mariana Trench, and still be thousands of feet underwater.

The Pacific Ocean is one seriously large body of water, occupying more than 40% of the Earth’s surface.

Heck, the human body is about two-thirds water, and if you live in the Pacific Northwest, the air itself is pretty much two-thirds water.

But in reality, the amount of water available for human use is startlingly small, particularly the amount of fresh water available for farming. As the author and researcher Steven Solomon, details in his book, “Water: The Epic Struggle for Wealth, Power and Civilization,” only about 2.5% of all the water on Earth is fresh water, and two-thirds of that total is locked away in polar ice caps and mountaintop glaciers.

Plus, of the already miniscule amount of planetary fresh water not locked away as ice, nearly all of the rest exists in underground aquifers, most of which are either inaccessible or difficult to tap. To be specific, less than three-tenths of one percent — 0.03% — of the planet’s fresh water exists in liquid form on the Earth’s surface and even a significant percentage of that water is contained in permafrost, soil moisture and atmospheric water vapor.

(A typical fluffy white cumulus cloud floating across the sky on a sunny day weighs between 600 and 800 tons).

A crisis to come

Thus, the amount of fresh water available in liquid form in rivers and lakes is but a tiny fraction of all the H2O we consider to be so incredibly abundant on Earth — and if that’s not daunting enough, consider that more than 2.5 billion people alive today live in semiarid climates that receive less than 8% of the total precipitation that falls to the ground annually.

As a result, water — not oil — is the world’s most precious resource, and in the decades to come the geo-political struggles to obtain it, control it and utilize it efficiently will become ever more contentious.

In fact, the most significant socio-economic transformation in human history — even bigger than the introduction of the iPhone X — was the harnessing of that approximately 0.01% of the world’s available freshwater to support the cultivation of cereal crops.

Ironically, that transformative event took place thousands of years ago in a region now characterized as a sun-baked, sand-infested hellhole: Mesopotamia, aka, the Middle East.

The development several millennia ago of agricultural practices using irrigation was able to produce perennial surpluses of grain that could be stored as a hedge against years of drought or one of those pesky plagues of locusts. Such food security — humanity’s first — supplanted the hunter-gather societies and gave rise to culture and the emergence of the arts, beginning with spoken language and the written word.

Of course, the initial application of written words was to create laws, the first of which was the imposition of taxes.

As a lifelong journalist who’s made his living using the written word … you’re welcome.

The point of these statistics is that the food security we take for granted is not universally shared by most countries. As world population increases, and climate disruptions exacerbates both debilitating droughts and devastating floods, water scarcity will become as contentious as the sectarian violence that currently plagues so much of the world.

That makes agricultural productivity in North America, one of the few places on Earth where relatively abundant water for irrigation is available, among the most critical factors for policymakers. If farm productivity is compromised here, the world would suffer unimaginable hunger, famine and starvation.

Yet ask average Americans what they consider to be essential national policies, and support for animal agriculture and food production doesn’t even make the top ten.

To generate traction for prioritizing the livestock and crop production that feeds so much of the world and to convince government at all levels to protect land use and preserve water resources, it falls to the people actually involved in those industries to raise agriculture’s profile on the national agenda.

And unfortunately, the percentage of the population involved in food production is even smaller than those calculations of how much the world’s water farmers and producers get to use.

The opinions in this commentary are those of Dan Murphy, an award-winning journalist and commentator.

Dan Murphy: A Bad Move By USDA

Dan Murphy: We’re ‘Awash In B.S.’