Current Activities

Public Hearing DEFEAT BILL NO. 2017-22

The Santa Fe City Council will vote August 30 on a proposed ordinance that would strip away our rights to protect our health, safety, and property. It would enable the wireless industry to put cell tower transmitters on every block in front of people’s homes without their consent or their ability to object for any reason.
Bill No. 2017-22 would repeal most zoning regulations that now protect us. It would allow cell tower transmitters to be built
• on any street or sidewalk
• without a public hearing
• without notice to neighbors
• without notice to the public
• without an application
• without information regarding radio frequency radiation
• without proof of compliance with the FCC’s safety rules

Cities all over the country are opposing similar legislation. An Ohio law that repealed zoning regulations for wireless facilities throughout Ohio was challenged by 70 cities and was overturned by a court. A California bill that would do the same thing in California, S.B. 649, is being opposed by 216 cities, 34 counties, and 45 health, environmental, and consumer justice organizations.

Tell the Santa Fe City Council to VOTE NO
info: 471-0129


Reverend Barber Rocks Albuquerque at Poor People’s Campaign Moral Revival

Reverend Dr. William J. Barber, Jr., and the Poor People’s Campaign – A National Call for a Moral Revival, rocked the Central United Methodist Church on Tuesday night with singing, poetry, testimonials, and prayer to rekindle a prophetic moral vision for justice, social change and movement building.  With standing room only, the church was packed with more than 1,200 people, while many stood outside to listen

Speaking to the recent events in Charlottesville, Virginia, Rev. Barber highlighted the interrelatedness of the issues we are facing.  He said working in isolation no longer works and we must together build a just, sustainable and participatory society.  He reminded the audience that we pledge allegiance to “one nation under God with liberty and justice for all.”

Rev. Barber is a Protestant minister, based in North Carolina.  He is the President and Senior Lecturer of the Repairers of the Breach, and a NAACP board member.

The Poor People’s Campaign is a movement to address the challenges we are facing today, drawing on the wisdom of and moving beyond Dr. Martin Luther King’s campaign of 1967 and 1968.  That campaign’s tenants were to address systematic racism, poverty, militarism, and economic development. 

In March, 1968, Reis Tijerina, of the The Alianza Federal de Mercedes (Federal Alliance of Land Grants), attended a key meeting in Atlanta. In May, 1968, he joined the caravan from New Mexico to the Poor People’s March on the National Mall in Washington, DC.  People of all races gathered to demand economic justice.  The march was held on May 12th, following the tragic assassination of Dr. King in early April.

Albuquerque was the campaign’s second stop on a 25-state revival tour, with an additional stop in Washington, DC.  Fifteen regional trainings will be held for 1,000 committed people from each revival tour state to use civil disobedience the way Rosa Parks did.  Her protest on the bus changed the race narrative.  The next stops on the tour are Topeka; Milwaukee; and Detroit.  To learn more and to sign the pledge, go to

Testimonials focused on the four areas of the campaign were given by a diversity of speakers from New Mexico, including Samia Assed, a Muslim activist based in Albuquerque; Arturo Uribe, a resident of Mesquite, who lives near a dairy; Todd Wynard, a Mennonite working on watershed discipleship in the Taos area; Tina Cordova, co-founder of the Tularosa Basin Downwinders Consortium, working to obtain compensation and health care for the Trinity downwinders; and Monique Salab, an Iraq war veteran and member of the Veterans for Peace.  To view the livestream of the Albuquerque meeting go to or

Ms. Salab explained how her work for the abolition of war puts her in classrooms to talk about the lies of the military, the racism, the gender bias, and sexual bias.  She is particularly concerned about how the junior ROTC programs are “invading low income schools.”

Ms. Cordova received a standing ovation for her talk about the health, economic, and environmental impacts of the first atomic bomb test at the Trinity Site on July 16, 2017.  She explained that people have had to hold bake sales or sell cattle in order to pay for cancer treatment.

Mr. Wyndard, a Mennonite and a board member of New Mexico Interfaith Power and Light, said he was addicted to petroleum.  He called a “life destroying drug” and that we “sold creation for convenience.”

Mr. Uribe spoke of the negatives impacts of the 148 dairies to communities throughout New Mexico, including flies, dust, concerns about the safety of the drinking water, and the smells that prevent summer cookouts and other outdoor activities.  He also spoke about the nuisance lawsuit brought by attorneys who took advantage of the people and benefitted the most.  Despite it all, he said he is “proud and humble” and has a life “rich in family values.”

Ms. Assed bore witness as a privileged settler of sacred land and spoke about systematic racism.  Through her work opposing the Muslim ban and protecting freedom of speech, she has created bonds with brown and black mothers around the world.  She concluded by saying her “freedom is tied to everyone in America.”

The host committee for Tuesday’s fabulous community event was Dr. Harold Bailey, of the Albuquerque NAACP; the Rev. Holly Beaumont, of Interfaith Worker Justice – New Mexico; Sr. Joan Brown, of New Mexico Interfaith Power and Light; and Joan Lamunyon Sanford, of New Mexico Religious Coalition for Reproductive Choice.

#poorpeoplescampaign #moralresistance #unitethepoor #repairerofthebreach #concernedcitizensfornuclearsafety


Activists Invite Livermore Lab Director to Join Them at Nagasaki Commemoration to Discuss Nuclear Weapon Ban Treaty

Members from more than three-dozen Tri-Valley, Tracy and Bay Area peace, justice and environmental organizations and communities of faith invited the Lawrence Livermore National Laboratory Director to join them at the West Gate to discuss the new Treaty on the Prohibition of Nuclear Weapons.  The activists visited the Livermore Lab Main Site on Wednesday, August 9th to commemorate the victims of the U.S. bombing of Nagasaki, Japan with an atomic bomb on that day in 1945.  It was the second U.S. wartime bombing; the first was on Hiroshima, Japan on August 6th.

Just last month, on July 7th, 122 countries, or state parties, adopted the historic treaty at the United Nations in New York City.  (The English version of the 10-page treaty begins on p. 17.)  One state abstained, and one voted no.  The U.S. did not participate in the final negotiations or the vote.

A new global majority took the steps necessary to establish an important new law and a new global norm.  The treaty prohibits the development, testing, production, manufacture, acquisition, possession or stockpiling of nuclear weapons, which is exactly what the Livermore Lab does.

In fact, 88.5 percent, or over $1,230,000,000, of Livermore’s budget request for fiscal year 2018 is for nuclear weapons activities.  These activities include developing a new W80-4 warhead for a new Long-Range Stand Off weapon and the new Interoperable Warhead-1.

Anticipating resistance from the Lab to meet, the activists acknowledged that national policies and behaviors do change over time.  They cited how South Africa, after coming under global pressure, dismantled its apartheid systems and rose in stature in the world.  They wrote, “So, too, may the U.S. and other nuclear weapons states accede to the treaty and come into compliance at a not-too-distant date.”

The Lab Director, William Goldstein, replied to the invitation saying he respectfully declined.  He wrote, “This topic is best discussed with the U.S. Government representatives at the UN.”

Marylia Kelley, of Tri-Valley Communities Against a Radioactive Environment, or Tri-Valley CARES, replied that the UN is not the sole forum for discussing U.S. nuclear weapons policy and disarmament obligations.  She wrote, “Livermore Lab is a proper and necessary forum to discuss nuclear disarmament in general and the implications of the Treaty on the Prohibition of Nuclear Weapons in particular.  Indeed, the nuclear weapons activities that Livermore Lab conducts at its Main Site in Livermore … make it not merely an appropriate location but an imperative location for this discussion.”

About 200 people attended the commemoration event, which was filled with speakers, poetry, music, and a die-in at the West Gate.  Forty-seven were arrested and given a court date of September 11th, 2017.


CCNS is very concerned with increasing tensions between the U.S. and North Korea


“I’d like to de-nuke the world,” said Trump, the same afternoon in which he claimed his prior threat to bring “fire and fury” upon North Korea “wasn’t tough enough.” The president said that until such a day, the U.S. “will be most powerful nuclear power by far” with the “biggest, finest” nuclear arsenal. “Nobody is going to be threatening us with anything,” said Trump.

CCNS is very concerned with increasing tensions between the U.S. and North Korea.  Please support our work and spread the following tweets:

Ivanka, please rein in your father on North Korea.  Life is too precious to waste on a nuclear war.

Melania, please rein in your husband on North Korea.  Life is too precious to waste on a nuclear war.

Barron, please rein in your father on North Korea.  Life is too precious to waste on a nuclear war.

To learn more about about the U.S. relationship with North Korea and the fact that the Korean War continues to this day, please visit the Korea Policy Institute at  “KPI is an independent research and educational institute whose mission is to provide timely analysis of United States policies toward Korea and developments on the Korean peninsula, and to educate U.S. policymakers, media and the public.   Support KPI’s efforts to provide the information and analysis needed to inform a U.S. policy that respects the Korean peoples’ desire for peace, sovereignty, reconciliation, and the reunification of Korea.”

For an informed conversation about what North Korea wants (it wants peace), please listen to the August 8, 2017 interview of Christine Hong, an Associate Professor of Literature at UC Santa Cruz and KPI Board member, on KPFA-FM at  It begins at 33.40.


CARD and AFES Cite NMED Discriminatory Public Process for WCS Ground Water Permit

Citing a discriminatory public process involving the proposed ground water discharge permit for Waste Control Specialists (WCS), Citizens for Alternatives to Radioactive Dumping (CARD), and the Alliance for Environmental Strategies, recently requested that the New Mexico Environment Department stop the permitting process.  The Environment Department responded by terminating the public comment period.  Comments were due to the Environment Department by August 8th.  The Department plans to reissue the public notice in both English and Spanish soon, thus starting the public comment period again.

The draft permit would allow WCS, a limited liability corporation, to discharge an theoretical maximum of 170,500,000 gallons per day from the 14,900-acre radioactive and hazardous waste storage and disposal facility located in Texas on the Texas-New Mexico border, five miles east of Eunice, New Mexico.  d_WCS_GWDP_1817_060917

The Environment Department’s discriminatory practices include the omission of a public notice in Spanish, the dominant language in the Eunice area; and the omission of a study about the potentially affected local communities.  Further, the Environment Department did not provide inclusive public participation opportunities as required by their January 19, 2017 Settlement Agreement with the Environmental Protection Agency (EPA).  That agreement resolved a 2003 civil rights complaint filed by CARD about the discriminatory practices involved in the permit process for the Triassic Park Hazardous Waste Treatment and Disposal Facility, located east of Roswell.  EPA_FINALResolutionLetterandAgreement_TriassicPark_Complainant_011917

CARD, an Albuquerque-based non-governmental organization, filed the complaint with EPA alleging violations of Title VI of the 1964 Civil Rights Act based on race and national origin.  CARD claimed the Environment Department “failed to require or perform a scientific investigation into possible disparate impacts; failed to ensure that limited-English proficient Spanish speaking residents were provided a meaningful opportunity for effective public participation in the permitting process; and has a statewide pattern and practice of similar discriminatory permitting and lack of access for limited-English proficient residents to the public participation and permitting process.”  Fourteen years later, the Environment Department continues the same practices.

Noel Marquez, of the Artesia-based Alliance for Environmental Strategies, wrote the Environment Department, stating, “When it comes to issues of contamination of our lands, water and air regarding our southeastern region of New Mexico, the people will always come first.”

Marquez explained, “Our water is precious and many of us operate small farms and we will not allow the state or nuclear industry to threaten or stigmatize our home lands with radioactive dumps and their toxic effects.  The EPA has also noticed [the Environment Department’s lack of] outreach to the public and we hope that our communities will be better served in the future.”


CCNS Decries Lack of Water Protection in NMED and LANL Agreement

Recently the Department of Energy and the New Mexico Environment Department (NMED) announced a settlement concerning leaking nuclear waste dumps at Los Alamos National Laboratory (LANL) that will not protect regional drinking water supplies from toxic, hazardous and radioactive pollution.  The Settlement Agreement begins on p. 21 at  The settlement perpetuates the myth that alternative groundwater monitoring requirements are as protective as the hazardous waste laws and regulation.  Unfortunately, alternative requirements have allowed pollution to continue to migrate to the regional drinking water aquifer below LANL.

Under the terms of the settlement, LANL submitted a hazardous waste permit modification request to the Environment Department for the three dumpsites at Technical Area 54 (TA-54).  The Environment Department Hazardous Waste Permit is available at  and the 312-page permit modification request is available at

The dumps are, Area G, an operational 63-acre dump for radioactive, hazardous and toxic waste; Area H, a non-operating dump with nine deep shafts containing toxic, hazardous and explosive chemicals; and Area L, a non-operating 2.6 acre dump contaminated with fast-moving liquids, volatile organic compounds and radioactive tritium.

Because the dumps received waste after July 26, 1982, they are “regulated units” under the hazardous waste regulations.  Owners and operators of regulated units must establish groundwater programs for detecting, characterizing and responding to pollution releases that reach the uppermost aquifer, “as well as lower aquifers that are hydraulically interconnected with this aquifer within the facility’s property boundary.” 40 CFR §260.10.

As documented by Robert H. Gilkeson, an independent registered geologist, the groundwater wells LANL drilled to characterize the geology near the dumps are defective and cannot detect, characterize and respond to pollutants that leak from the dumps.  See Gilkeson Cleanup Documents, Groundwater Documents,  Groundwater Wells, National Academy of Sciences Review of LANL Groundwater Plans and Practices (2007), and Buckman Direct Diversion Project at

A case in point is the regional well, R-22, located 500 feet east of Area G downgradient of the boundary, along the direction of groundwater travel from beneath Area G to the property of the Pueblo de San Ildefonso, the Rio Grande, and the Buckman Wellfield, an important source of water for Santa Fe.

In 2004, pentachlorophenol was detected at six times the drinking water standard.  Pentachlorophenol is a pesticide and wood preservative.  The Environmental Protection Agency set a zero maximum contaminant level goal because of the serious health issues caused by exposure, including cancer and damage to the central nervous system, reproductive system, liver and kidneys.

Under the regulations, the Environment Department was required to order LANL to install more advanced groundwater monitoring.  But they did not.  No upgraded monitoring system was installed, nor was well R-22 replaced.  The settlement perpetuates the use of alternative requirements that do not work to protect the drinking water aquifer.  See Section 1.4.2 Integration with Consent Order, and Section MDAs G, H, and L at pp. 181 and 182 at compared to 40 CFR §§264.90 – 100.

Joni Arends, of CCNS, said, “As we’ve seen with the LANL’s repeated failures to protect its own staff and contractors from unsafe working conditions, we also see its failure to live up to its responsibility to protect its neighbors and our drinking water from these truly dangerous chemicals – and NMED’s complicity in allowing it do so.”  See Center for Public Integrity Nuclear Negligence five-part series at

CCNS is a party to the hazardous waste permit litigation, but did not sign the settlement.  CCNS is represented by the New Mexico Environmental Law Center.

Please note:  LANL/DOE is hosting a public meeting about their permit modification request on Wednesday, August 30, 2017 at Fuller Lodge, 2132 Central Avenue, Los Alamos, from 5:30 to 7:30 pm.

Comments are due to the New Mexico Environment Department by September 22, 2017.  CCNS is preparing sample public comments you can use to develop your comments.  We will let you know when they are ready by email and on social media.


Annual Sackcloth and Ashes Hiroshima Day Peace Vigil at Los Alamos, NM – Saturday, August 5, 2017 2:00 pm

On Saturday, August 5th, people will gather at 2:00 p.m. at Ashley Pond Park in Los Alamos, NM for the annual sackcloth and ashes peace vigil to commemorate Hiroshima Day.

There will be a quiet walk, then sitting in sackcloth and ashes for 30 minutes, then returning to the park, where we will reflect together on the experience as well as the current United Nations movement to outlaw nuclear weapons.  On July 7th, 122 countries voted for the United Nations to adopt the Treaty on the Prohibition of Nuclear Weapons.  Countries can sign the Treaty when the United Nations General Assembly meets at its Annual Meeting, beginning on September 20, 2017.  

Rev. John Dear, and Jay Coghlan of Nuclear Watch New Mexico, will be speaking at the Peace Vigil.

Please bring water, an umbrella and a peace sign.  Sackcloths and ashes will be provided.

For info, contact Bud Ryan at

Please help spread this announcement!


Congressman Ben Ray Luján is a RECA Champion for All New Mexicans

After nearly 600 luminarias were lit on the Tularosa Little League field, U.S. Congressman Ben Ray Luján expressed his apologies to those who are suffering from or have died of illnesses caused by exposure to the first atomic bomb test on July 16, 1945, at the Trinity Site.  The bomb contained 13 pounds of plutonium, but only three pounds fissioned.  The remaining plutonium and toxic ash fell out over fields, gardens, houses, and mountains, eventually flowing into cisterns and waterways.  The people, now called “Trinity Downwinders,” were not notified of the danger, nor were they evacuated.

At the Eighth Annual Candlelight Vigil on Saturday, July 15th , Congressman Luján said, “Back in 1945 when that bomb was set off here, it set off a chain of events and that wrong has never been made right.  Families were impacted in a negative way, from those that had windows broken on their homes to those who saw the light (from the bomb) go off, to those who had to deal with the dust and ash that collected through the area.”

Unlike downwinders in Arizona, Nevada, and Utah, the Trinity Downwinders have never been included in the federal Radiation Exposure Compensation Act (RECA).  It provides medical care and compensation to those exposed to atmospheric nuclear tests and uranium industry workers, some of which worked in New Mexico.  Since 1990, over $2 billion has been awarded to claimants.

Congressman Luján is leading to amend RECA to include the Trinity Downwinders, the Post ‘71 uranium workers, and New Mexicans exposed to radioactive contaminants living downwind and downstream of the national laboratories.

Last week Congressman Luján introduced an amendment to the National Defense Authorization Act stating the U.S. should compensate and recognize uranium workers, downwinders, and others.  It passed the House. and

The Tularosa Basin Downwinders Consortium organized the vigil.  They have been working diligently for 12 years to ensure that the Trinity Downwinders are included in the proposed amendments.

Tina Cordova, a co-founder of the Consortium, said, “This community cannot thank Congressman Luján enough for his dedication to our efforts.”

She added, “It is heartbreaking every year when we add names to the list of people we’ve lost as we light luminarias and call out names. We look forward to the occasion when we can announce that the amendments to RECA have passed and people can finally receive much needed help.  The hearings in the Senate Judiciary Committee are a big first step.”

Recently they learned the Senate Judiciary Committee scheduled an oversight hearing about RECA for the last week of July.  The hearing has been postponed to September.  To contribute to sending Consortium representatives to the hearing in Washington, DC, please visit

Disclosure:  CCNS serves as the Consortium’s fiscal agent and Joni Arends, CCNS Executive Director, serves on the Steering Committee.


UN Adopts Treaty for a World Without Nuclear Weapons

Our world is different today as a result of a historic vote on Friday, July 7th at the United Nations when 122 State Parties, or countries, voted yes to adopt the 10-page Treaty on the Prohibition of Nuclear Weapons.  It comprehensively prohibits nuclear weapons, leading towards their eventual elimination.  It stigmatizes nuclear weapons in a fashion similar to the international treaties that prohibit chemical weapons, biological weapons, anti-personnel landmines and cluster munitions.

The Treaty is based on international humanitarian law.  It prohibits State Parties from developing, testing, producing, manufacturing, transferring, possessing, stockpiling, using or threatening to use nuclear weapons.  It also prohibits State Parties from assisting, encouraging or inducing anyone to engage in any of those activities.  Further, States must not allow nuclear weapons to be stationed or deployed within their borders.  For more information, please visit the International Campaign to Abolish Nuclear Weapons at and Reaching Critical Will, a project of the Women’s International League for Peace and Freedom (WILPF), at

Non-governmental organizations and individuals around the world have been working since the summer of 1945 to ban nuclear weapons when the United States first tested an atomic plutonium bomb at the Trinity Site in New Mexico, and used atomic bombs on Hiroshima and Nagasaki, Japan.  The entire nuclear cycle, from uranium mining and milling; to research, development and testing; to the mountains of pollution and waste created with no place to go, results in catastrophic consequences.

In April, the International Red Cross and Red Crescent Movement met in Nagasaki to reaffirm their long opposition to nuclear weapons and work for their elimination.  They wrote, “Achieving a world without nuclear weapons is an obligation to future generations and imperative to preserve our common humanity.  Weapons that risk catastrophic humanitarian consequences cannot possibly be viewed as providing peoples’ security.  Protecting humanity requires courage, commitment and concerted action:  it is time to put humanity first by prohibiting and completely eliminating nuclear weapons.”

Their appeal came true despite the 69 State Parties, including the United States, who did not participate in the negotiations or the vote.  In the end, The Netherlands, a NATO member, voted no and Singapore abstained.

On September 20, 2017, the State Parties, including the United States, will have their first opportunity to sign the Treaty during the annual United Nations General Assembly in New York City.  The Treaty is not yet in force.  It will become international law ninety days after fifty State Parties sign and ratify it.

Now that the Treaty has been adopted, CCNS believes it is time for New Mexicans to discuss a collective future that is not dependent upon the nuclear weapons industry.  How do we use the Treaty to create a sustainable, renewable, contamination-free future that supports life, well-being and community? Send us your comments and join the discussion on Facebook.


Friday, July 7th Deadline for Comments to DNFSB about LANL Plutonium Operations

Public comments about the safety of the Plutonium Facility at Los Alamos National Laboratory (LANL) are due to the Defense Nuclear Facilities Safety Board on Friday, July 7th.  CCNS prepared sample public comments you can use to craft your comments.  Word Doc: SampleDNFSBpubliccomments07072017 PDF: SampleDNFSBpubliccomments07072017 Please submit them to

The Board held a public hearing in Santa Fe on June 7th about reducing the risk of current and future plutonium inventories at LANL’s Plutonium Facility.  It is the only place in the United States where plutonium triggers, or pits, for nuclear warheads are manufactured.  It is located in wildfire and seismic zones, above regional surface and ground water drinking water supplies.  Operations began in 1978, but have been down for almost three years due to radiation criticality issues.  Nevertheless, the President proposed a $180 million budget increase to ramp up manufacturing.

The frequency of accidents and incidents at LANL is increasing.  In April, a fire involving plutonium occurred in the Plutonium Facility.  A worker was burned.  In May, hazardous waste was shipped to Colorado for treatment with an inaccurate description of its acidic characteristics.  And last month, plutonium was shipped by commercial air cargo in improper containers, which are not designed to withstand pressure changes, to two Department of Energy (DOE) sites, one in South Carolina and the other, in California.  Such shipments must be shipped by ground transport.  The potential harm could have been much greater than what occurred.  Nevertheless, these events are not “normal,” and public should not become comfortable with them.

These events and others are documented in the excellent five-part “Nuclear Negligence” series by The Center for Public Integrity.  The series documents a “litany of mishaps” that have harmed workers, while the contractors who manage and operate the DOE nuclear weapons facilities annually reap millions of dollars in performance bonuses.  Journalists Patrick Malone and R. Jeffrey Smith describe the cycle of abuse that has been created by the lack of proper DOE oversight of the contractors that manage the 10 sites across the country.  Bonuses are awarded based on contractor performance, which in many cases places worker health and safety at risk in order to accelerate work in order to gain the bonus.  And if whistleblowers come forward to complain, DOE will reimburse the contractors for trying to silence the brave workers.  The cycle perpetuates itself to the detriment of downwind and downstream communities of these facilities and the American taxpayer who is paying once, twice and sometimes three times for the mishaps of DOE and its contractors.

To learn more, please check out the five-part “Nuclear Negligence” series at The Center for Public Integrity website:

Part One:  A near-disaster at a federal nuclear weapons laboratory takes a hidden toll on America’s arsenal – Repeated safety lapses hobble Los Alamos National Laboratory’s work on the cores of U.S. nuclear warheads.

Part Two:  Safety problems at a Los Alamos laboratory delay U.S. nuclear warhead testing and production – A facility that handles the cores of U.S. nuclear weapons has been mostly closed since 2013 over its inability to control worker safety risks.

Part Three:  Light penalties and lax oversight encourage weak safety culture at nuclear weapons labs – Explosions, fires, and radioactive exposures are among the workplace hazards that fail to make a serious dent in private contractor profits.

Part Four:  More than 30 nuclear experts inhale uranium after radiation alarms at a weapons site are switched off – Most were not told about it until months later, and other mishaps at the Nevada nuclear test site followed.

Part Five:  Repeated radiation warnings go unheeded at sensitive Idaho nuclear plant – The inhalation of plutonium by 16 workers is preceded and followed by other contamination incidents but the private contractor in charge suffers only a light penalty. 

To view the testimony of the DOE and LANL officials at the Board’s public hearing, please visit   A key document to review is the Board’s September 2015 Technical Report,  entitled, “Opportunities for Risk Reduction at the Los Alamos National Laboratory Plutonium Facility Through the Minimization of Material-at-Risk,” DNFSB/TECH-39.