The Big Apple Just Got Leaner – New York City Bans Trans Fats in Restaurants

On December 5, 2006, the New York City Board of Health voted to ban the use of almost all artificial trans fat in the city’s more than 11,000 restaurants and fast food outlets. Harold Goldstein, the executive director of the California Center for Public Health Advocacy, told the New York Times that, “New York City has set a national standard” and already several cities and states have introduced similar legislation.

On December 5, 2006, the New York City Board of Health voted to ban the use of almost all artificial trans fat in the city’s more than 11,000 restaurants and fast food outlets. Harold Goldstein, the executive director of the California Center for Public Health Advocacy, told the New York Times that, “New York City has set a national standard” and already several cities and states have introduced similar legislation.How did New York City decide to act on trans fats and what are the lessons for health advocates engaged in other efforts to control corporate practices that harm health? First, some background: trans fats are used to enhance the crispness, stability, flavor and shelf life of many processed foods. Trans fats provide food companies with flexibility in food storage and preparation, thus contributing to profitability. By the late 1990s, about 40% of US supermarket products contained trans fats, showing how pervasive exposure was to the public at large.

In 1994, the Center for Science in the Public Interest (CSPI), a national advocacy organization, petitioned the Food and Drug Administration (FDA) to require that food manufacturers label the trans fat content of their food products. The petition was based on research showing that replacing trans fat with healthier oils could prevent between 30,000 and 100,000 premature cardiovascular deaths in the United States each year. Some researchers have suggested that replacing trans fats with healthier alternatives could also significantly reduce the incidence of Type 2 diabetes in the US.

In 1999, despite the opposition of the food industry, the FDA proposed to include the trans fat content of food on the standard food label. The agency claimed that strengthening food labeling was likely to yield significant health and economic benefits, including saving up to 5,600 lives and $8 billion a year.1 Three years later, the Institute of Medicine concluded that they could not determine a healthful limit of trans fat and urged action to reduce its presence in the American diet.2 In January 2006, the FDA rule requiring food labels to include information on trans fats went into effect, but the FDA has turned down requests to ban the product altogether.

New York City took on trans fat in 2005. According to the New York City Department of Health and Mental Hygiene (NYC DOHMH) Health Commissioner Thomas R. Frieden, “New Yorkers are consuming a hazardous artificial substance without their knowledge or consent. Trans fat causes heart disease. Like lead in paint, artificial trans fat is invisible and dangerous, and it can be replaced. While it may take some effort, restaurants can replace trans fat without changing the taste or cost of food. No one will miss it when it is gone.”

The department began its efforts with a year long education campaign to help restaurants voluntarily reduce trans fats. However, a survey before and after this voluntary educational campaign showed that overall use of trans fat did not decline at all. As a result, the Commissioner proposed the ban. Speaking on behalf of the ban, Dr. Walter Willett, Chair of the Department of Nutrition at the Harvard School of Public health noted, “If New Yorkers replace all sources of artificial trans fat, by even the most conservative estimates, at least 500 deaths from heart disease would be prevented each year in New York City — more than the number of people killed annually in motor vehicle crashes. Based on long term studies, the number of preventable deaths may be many times higher. Trans fat from partially hydrogenated vegetable oil is a toxic substance that does not belong in food.”

Some in the food industry supported the ban. Carnegie Deli owner Sanford Levine said, “We’ve been using 100% canola oil for 20 years because it has a better taste and is better for customers. It’s easy to replace artificial trans fat, it costs the same, and the food tastes great. Our cakes and other baked goods are already trans fat free. If we can do it, so can other restaurants.”

But others in the food and restaurant industry vigorously opposed the ban. Although no New Yorker ever walked into a restaurant to order a portion of trans fat, some argued that the ban would interfere with New Yorkers’ freedom. In an op-ed in the Daily News, Richard Berman, a food lobbyist and executive director of the Center for Consumer Freedom wrote, “the proposal to eradicate all artificial trans fats from every restaurant in the city is nothing short of hysterical.” It subjects the restaurant industry to a terrible case of regulatory whiplash. “If they can declare New York City a trans fat free nanny state by bureaucratic fiat, what can’t Commissioner Thomas Frieden and his minions ban?.. Maybe the radical solution is to let consumers not bureaucrats dictate what restaurants do.

In the months leading up to the vote, dozens of New Yorkers wrote impassioned letters to the editor on the subject, newspaper editorial boards took opposing sides on the issue, and hundreds of New Yorkers submitted documents or testified at public hearings on the subject.

In the proposal approved in December, the Board of Health made some concessions to the food industry, extending the time restaurants had to comply with the new rules. In the weeks and months following the New York City debate on phasing out artificial trans fat, several national companies announced their intention to eliminate trans fat from some or all of their product lines. These included KFC, Red Lobster, Olive Garden, Crisco, and Starbucks.

Lessons Learned for Changing Corporate Practices that Harm Health

So what lessons does New York City’s ban on trans fat in restaurants offer for public health professionals and advocates concerned about protecting the public against harmful corporate practices?

Local health departments can play a leading role in challenging harmful corporate practices. The campaign to phase out artificial trans fats was initiated and led by the local health department, which defined its mission as protecting the health of the public against significant threats. While advocates, researchers and health professionals played important supporting roles, the success of the effort depended on a Mayor and Health Commissioner who made public health a priority and were willing to engage in some battles to achieve their goals. Similar efforts in other jurisdictions to control smoking, restrict access to handguns, and reduce exposure to lead paint show the important role local officials can play in protecting public health against health damaging corporate practices.

Voluntary educational campaigns may be a useful starting point.

The health department was able to win over public support for the phase out in part because they first tried a voluntary campaign and were able to demonstrate that this effort was not sufficient to achieve desired public health goals. In some cases, voluntary educational campaigns may work, but beginning with this activity may help to mobilize support for stronger action should it fail.

Framing the issue as protecting people against involuntary threats helps to mobilize people. In the health department’s aggressive media campaign to win support for the proposal to phase out artificial trans fat, spokespeople emphasized that New Yorkers did not choose to eat trans fat. Since the product was neither labeled nor disclosed, the argument that consumers were choosing this product was harder to make. Comparing trans fat to lead paint and labeling it a toxic product was also a clever strategy, since New Yorkers had debated regulation of lead paint for more than 20 years and most New Yorkers understood and strongly supported government action to protect children against lead paint poisoning. Thus, framing policy debates in local terms may help to generate support.

Creating controversy can help to advance public health.

Debate about trans fat received extensive coverage in local newspapers, television and other media for several weeks. While food industry defenders and some libertarians opposed the proposal, many New Yorkers supported it. In the course of the debate, the topic changed from whether to ban trans fat to how best to do it and on what timetable. The conflict provoked discussion and engaged diverse constituencies in the issue.

Some public health professionals have a predictable approach to conflict: partnerships with all stakeholders, compromise, and a willingness to be “reasonable”. By staking out a principled position and sticking to it, the NYC Department of Health achieved its goals, educated the public and set an example for other local health departments across the country.

Forceful advocacy sets the stage for subsequent victories.

While the New York City Department of Health took the lead on this issue, its campaign to phase out artificial trans fat stood on the shoulders of previous advocacy. In 1994, the Center for Science in the Public Interest began a 12 year effort to win the FDA requirement for trans fat labeling on store-bought foods. In 2003, Denmark passed a law that made it illegal for any food to contain more than 2% transfat. A May 2003 lawsuit by Ban Trans Fat against multinational food company Kraft led to a settlement in which Kraft agreed to produce trans fat free Oreo cookies for school markets. Ban Trans Fat also sued McDonalds for false advertising regarding its use of reduced trans fat cooking oil. In 2005, McDonalds settled the case by agreeing to act to limit trans fat and to pay the American Heart Association to sponsor public education on trans fats. In 2006, the American Heart Association became the first major medical organization to urge a specific limit on trans fat in the diet. In 2006, the New England Journal of Medicine published a study that concluded that daily consumption of 5 grams or more of trans fats raised the risk of heart attacks by 25% and that many of the “large” size fast food meals served by McDonalds and KFC exceeded this 5 gram limit. (The study also found that a New York City McDonalds meal had the highest trans fat content of any site in the 20 countries tested around the world.)3

These various efforts helped to educate the public about trans fats, to convince policy makers that it was an issue that deserved attention and set the stage for more assertive actions such as the New York City ban.

Interview with Reverend Jessie Brown

Reverend Jessie Brown is minister of two congregations in Philadelphia and a community leader who successfully fought the introduction of Uptown cigarettes in Philadelphia in 1991. Working with National Association of African Americans for Positive Imagery (NAAPI), of which Reverend Brown is the founder and executive director, he and other community leaders charged R.J. Reynolds with creating and marketing a new tobacco product specifically to African Americans. Because of their campaign, R.J. Reynolds pulled Uptown Cigarettes from the market. Today Reverend Brown continues to work nationally in tobacco control. He was the lead plaintiff in a lawsuit brought by NAAPI against the tobacco industries for marketing menthol cigarettes to African Americans. His work has been featured on many major news outlets and broadcasted throughout the world. Reverend Brown is also the chair of the US World No Tobacco Day Committee.

CHW: How did you start working in tobacco control?

JBROWN: In 1989, R.J. Reynolds Tobacco Company announced that they were coming to Philadelphia to create a new cigarette that was going to be specifically targeted to African Americans. And Philadelphia was going to be the test market site for that cigarette. We formed a community opposition group that thwarted their efforts to promote this. In fact, they withdrew the cigarette totally. It never reached the market.

CHW:: This was the “Uptown Cigarette,” correct?

JBROWN: Right, that was Uptown. R.J. Reynolds proudly announced that they were going to create a cigarette that was going to be specifically for African Americans and they thought they were being sensitive by telling everybody that they are now paying attention to the African American community. Of course, what they’re failing to do — which a cigarette company always fails to do — is to articulate the deadly nature of its product. So they treated it as if they were selling graham crackers rather than selling something that was highly addictive and highly dangerous to the African American community. So yes, they announced it in the Wall Street Journal in December 1989. By January 19, 1990, R.J. Reynolds formerly announced that it was going to withdraw that cigarette.

CHW: So, no packs of Uptown cigarettes were ever sold. Is that right?

JBROWN: None were ever sold. That’s correct.

CHW: Did you ever actually see the cigarettes?

JBROWN: Yes, I have a pack.

CHW: How was Uptown specifically targeted toward the African American community?

JBROWN: The color [used in the packaging] is red, black, and green — African Liberation colors — with the predominant color being black; and, of course, the green and red stripes. Secondly, we believe (this is our interpretation) that the majority of people who probably would be using it were laborers and did not like to get their hands on the filters to make them dirty. They packed them upside down so that you didn’t have to flip them over, just knock them out, and you pick it up from the end that you generally light, and stick it in your mouth.

CHW: What strategies do you think contributed to the success of the campaign?

JBROWN: One, we moved very quickly to consolidate the medical interests, community interests, as well as the church interests in our opposing what R.J. Reynolds was doing. And in doing so, we beat them to the punch, garnering most of the support in Philadelphia to oppose them on the product, including getting Ebony Magazine who also put out a statement that they were not going to market the product. This kind of stuff had never happened before, period. No one in the tobacco control movement had ever stopped the industry from marketing a cigarette. We were the first.

CHW: Did you do most of your community organizing through the churches?

JBROWN: Well, a combination. We already had identified from previous campaigns, churches who were sympathetic to the mission of health promotion. And some of the city council members became involved, the local agencies — heart, lung, and cancer locally — took a high backup role and put their resources, time, money, and energy and staff into making certain that this campaign came off well.

CHW: What kinds of successful tactics did you use in the Uptown Campaign?

JBROWN: We took black paint and painted over cigarette billboards in neighborhoods and communities. And, of course, that was to get a message out that we did not want that kind of advertising in our neighborhoods. And billboards are the kind of thing you can’t turn off. They’re always on. And the only way we were going to get the upper hand on this was that those things be taken out of our community. We also had T-shirts and cap exchange programs. That was where we would take T-shirts and caps that had an alcohol or tobacco logo, or other kinds of paraphernalia and exchange it for a T-shirt or a cap that had a positive message. We did that in a number of places, and particularly around me going to court since I was the only one arrested for the “black washing” [billboard alteration]. That gave us an activity, and a way to attract people to come down to the courthouse.

CHW: You got arrested for altering the billboards? And you got people to come down to the courtroom?

JBROWN: Yes. We filled up the courtroom. And the outdoor advertising industry or the tobacco industry was not interested in really prosecuting, so all the charges were eventually dropped. But while they were shaking their sabers, we decided to use it for an opportunity for education — community education. And it was extremely successful. And a number of other groups around the country also picked up on the idea, and did it themselves as well.

CHW: I’ve spoken with someone who does research in Harlem about billboard ads and point of sale marketing, and she says that a lot of folks just sort of casually do this now, and if they see an alcohol ad, they’ll just tear it down off the phone booth, or paint over it, or put a sticker over it. Do you see a relationship between that and the activities you guys did?

JBROWN: Sure. We’ve given people permission to take charge of their environment and their community. You know, not everybody is willing to take charge of that. And in some places, it could literally be deemed vandalism or there could be of legal consequences to that, but at some level, communities should be in charge of the images that come into their community — not corporate America. And when corporations don’t do what they need to do in the best interest of the community, particularly tobacco and alcohol, then the community needs to take control of that process for themselves.

CHW: So it seems that public opinion of the tobacco industry has worsened.

JBROWN: But, it won’t stay there.

CHW: You don’t think so?

JBROWN: No. We have to make sure it stays there. Corporations, like everything else, have the ability to advertise their way out of this. We don’t have the advertising dollars that they do. They spend billions. We spend a few — you know — for every billion dollars they spend, we may spend a thousand dollars on advertising. So we’re talking about equal partners in this process. And over time, if we are not vigilant, they’ll be able to raise their image, cause nobody stays down on any organization forever. And we also have this mixed message thing going sometimes that somehow they’re doing the right thing. And some people buy into that.

CHW: You mean in terms of the so-called “tobacco education” that they do?

JBROWN: Yeah, but we know — for those of us who are directly involved with them, we see their advertising campaigns, and we know that they are still going after young people. And we know that it’s in their best interest to do so because they would have no customers in fairly short order if they didn’t replace the ones that they lose.

CHW: So, what do you think the impact the “Uptown” campaign was on folks in Philadelphia?

JBROWN: Oh, I think it was more than just in Philadelphia. It was across the country. I think it did send a message to young people that the industry is out to get them. They were upset that the industry would come in and appropriate their culture, their language, and stuff like the Uptown Theater — one reason why they chose Philadelphia was because the Uptown Theater was a way to talk about fun. It has a historical context and perspective here. And a lot of young people were not too happy with that.

CHW: So the Uptown Campaign had a pretty significant effect…

JBROWN: Uptown, for a little bit, turned into a cottage industry to talk about the old community organizing, what we did, how it carried off, what the communities did. It is now part of some textbooks, as I understand it. They now teach about the fiasco of R.J. Reynolds in trying to market the Uptown Cigarette. And it’s used as a lesson learned in some schools, marketing schools. So it had a huge impact in a number of areas in addition to an impact on educating the community.

CHW: What kind of press did you get?

JBROWN: We had literally hundreds and hundreds of interviews done by our Media team; and what we did was identify six spokespersons who had it. You know, for instance, Dr. Bob Robertson was our statistics person. He knew the statistics. We all knew them, of course, but someone called and said they wanted to talk about statistical information, we’d put him up. I was kind of the community person, and I would talk about the community organizing part of it. We had a medical doctor talk about the medical issues around it. We had a politician talk about the political fallout that ensues from such promotion activities. So we chose our spokespeople well to meet various general media needs, but we did it based on what kind of message we wanted to get out, not necessarily what the media wanted to say.

CHW: And so how long did it take before R.J. Reynolds made the announcement that they were removing the cigarette?

JBROWN: In reality, thirteen days. That’s what we officially say. It was actually nine from the time that we formally organized to the time that R.J. Reynolds withdrew.

CHW: Tell me a little more about NAAAPI’s focus.

JBROWN: NAAAPI’s original notion was that we would deal with advertising images that were negative to the community which included tobacco, alcohol, and the media. As tobacco control money became available, and a lot of NAAAPI’s work then went into tobacco control.

CHW: So it has evolved into more of an organization that does campaigns directed towards the tobacco industry?

JBROWN: Correct. I would say tobacco and alcohol because we did a number of alcohol initiatives as well, and they’re on the website, too.

CHW: What do you think the similarities between the alcohol industry and the tobacco industries are in terms of targeting specific communities?

JBROWN: They’re working from the same playbook essentially. Their marketing techniques [of] wrapping themselves around community and social concerns and needs in order to sell their product is exactly the same between the two. Both of their products take a heavy toll on the community.

CHW: In terms of health?

JBROWN: In terms of health and life and quality of life. Because we know that, particularly with alcohol, and even with tobacco, the stresses that are placed on families create issues of domestic violence and neglect so even the quality of life is diminished by the product. You’ve got children who may be exposed, and the stress it puts on the family with kids who are sick, constantly sick; not to mention the prenatal issues that mothers have around giving birth and low birth weight babies.

CHW: I read a recent Washington Post article about new marketing used by the tobacco industry that involves naming cigarettes — alcohol flavored cigarettes — using gambling lingo. “Screwdriver Slots,” “Blackjack Gin.” Have you heard of this?

JBROWN: Yes. It’s par for the course. Again, all of those industries. The alcohol industry, itself, is trying to do that by taking some of its brand nicknames and making wine coolers using similar names, so that they would then break down the sensitivity, particularly of young people, to the aversion of alcohol, and get them involved. Again, they got to replace the customer base that’s dying off. Again, they’re working from the same playbook. And if they can crosspollinate each other, and sell cigarettes and alcohol and gambling, then that’s what they’ll do.

CHW: So, do you think there’s any conscious collaboration between the alcohol and the tobacco industry?

JBROWN: Well, it’s conscious in the advertising companies that they use, yeah. If you’ll look behind the scenes, you’ll find that a number of the advertising companies that advertise alcohol also advertise tobacco. They’re collaborating in that sense. They may not be holding meetings together, and I’m not so sure that they won’t, or are not; but I wouldn’t be a bit surprised if they did.

CHW: Is there any documentation of the alcohol industry’s marketing techniques?

JBROWN: Oh, absolutely. Go on the website. You’ll see Power Master Malt Liquor – targeted to young black men. We stopped them from advertising their product and that product [was] withdrawn from the market. That was a high alcoholic content beverage. Yes, alcohol does the exact same thing. They still do it. They just get away with it more often right now.

CHW: Do you see any similarities between the role of tobacco and alcohol corporations and food corporations in the black community?

JBROWN: The answer is “Yes, in one sense of the word.” And this is one of those things where I think the greater weight lies with personal responsibility as opposed to corporate responsibility. A soda, if taken in moderation, will not kill you. Unlike a cigarette, don’t matter how you take it, it could catch up with you somewhere down the line. I mean, you know, it’s that kind of thing. But I think we can win the battle. I would tone down the industry’s promotion of their product, and force them to better tell the truth in their marketing promotion. I also think we need a public promotion campaign that really promotes healthy lifestyles, health living, and its benefits. If we get just as good at talking about the benefits and promoting a healthy lifestyle as the industry does at promoting fast foods, or promoting alcohol, or promoting tobacco, then I think we can easily win the battle. It’s like, one of the things we were promoting, way back when, was if the tobacco industry was going to continue to advertise, they had to turn over a quarter to one third of all billboard advertising to public health messages about tobacco, which we would design and put up there. They didn’t want to do that. And the reason is simple. Our one good message would outdo three of theirs any day.

CHW: They’d rather have nothing up there.

JBROWN: They would rather have nothing up there. Correct. Because they can then go to putting it in magazines, and continue to give away T-Shirts and caps. They’re getting a lot of what we call “unpaid walking billboards.” You know, those whole campaigns.

CHW: Apparently, a lot of young people wear these items.

JBROWN: Yes. That’s why we had the T-Shirt/Cap exchange.

CHW: It was mostly young people that you did this with?

JBROWN: Oh, no. We actually got them from everybody. We did this in front of the police department. You know, the police department came out there and were bringing alcohol advertising off the walls of the police department to exchange. It was wonderful. And you actually get more adults who readily take this up than you do young people. Young people always take free stuff, but here we’ll get adults exchanging stuff with us, more than we did the kids. But the point was, we’re taking advertising off the street.

CHW: The tobacco industry has a history of financial involvement in the African American community, as well. Is that correct?

JBROWN: That’s correct.

CHW: So, in your own experience in Philadelphia, have campaigns and awareness and public education had an affect on how community groups and businesses deal financially with the tobacco industry?

JBROWN: Yes. For a number of those groups it has been “Hush money.” And some of the civic and social organizations that have traditionally led battles to stop the exploitation of African Americans were silent or in some cases even promoted the interests of the tobacco industry or the alcohol industry. Even Ebony magazine has not done due diligence in providing ongoing information about the effects of tobacco, even with the huge effect tobacco has on the black community. And, of course, they didn’t do it because they were receiving ad revenues from the tobacco companies. In the millions and millions of dollars.

CHW: Does your organization accept funding from tobacco corporations?

JBROWN: Absolutely not. Matter of fact, if a group receives tobacco money in any way, shape, or form — or alcohol money, we will not directly work with that organization.

CHW: What do you think the role of the tobacco industry and their policies and practices in exacerbating health disparities?

JBROWN: A high percentage of African Americans smoke mentholated cigarettes. And until we made a big noise in the last few years, no one had even tested the notion of whether or not menthol contributed to a higher disease rate which would impact African Americans more highly than others. We believe it does because all of the studies, even the industry studies, show that menthol in a burned form is, in itself, a carcinogen. So African Americans may have been deliberately targeted by the industry with a more addictive and more deadly product.

CHW: In closing, I’d like to ask, what are your thoughts on the potential of the tobacco industry to be held accountable for its impact on the health of the Africa American community, or the public health in general?

JBROWN: Well, there are two things that I think that can make that happen. One is that people really get upset over it. And two, we put a Congress in there who actually do their jobs to protect the public interest around these issues. And we haven’t had a Congress that has been out there to protect the public’s interest around this. And you know, they get a lot of money from the industry, as well. So they formulate their opinions based on how much money they get. And regardless of what they say, we know that the vast majority of legislators that are receiving $50,000 — even $5,000. It doesn’t take much, apparently, to buy off a legislator. They have been extremely solid. They have not protected America’s interests.

Resources Update: Windfall Medicare Profits for Drug Companies

In January 2006, when the new Medicare Part D drug program went into effect, pharmaceutical companies’ profits were estimated to exceed $2 billion or more annually. The transfer into Medicare of millions of low-income people previously covered under Medicaid provided pharmaceuticals companies with a new source of profit. The Part D proviso that prohibited the federal government from negotiating directly for the lowest available prices further raised profits. In contrast, states have been able to negotiate and receive the lowest available prices for drugs for their Medicaid recipients. However, with the recent elections that gave Democrats control of the Congress, pharmaceutical companies are poised to do battle, as Democrats gear up to eliminate the restriction against the federal government’s ability to negotiate for lowest prices on behalf of Medicare recipients.

Leading Big Pharma’s defense is former Representative Billy Tauzin, who left the House in 2003 after helping to pass the new Medicare Bill to accept an annual salary of more than $2 million as President of the Pharmaceutical Research and Manufacturers of America. Another heavyweight drug lobbyist is Thomas Scully, who served as the Bush Administration’s Medicare expert and helped steer the drug subsidy bill to passage before accepting his lobbyist position in 2003.

GAO Calls for Improvements in FDA Oversight of Direct-to-Consumer Drug Advertising

Tauzin also made the news recently in urging voluntary guidelines for direct-to-consumer (DTC) advertising by the pharmaceutical industry. In a speech to venture capitalists last spring, he observed that, “It would be naive to not acknowledge the fact that D.T.C. advertising is also a lightening-rod in the health care debate in this country.”

Between 1997 and 2005, consumer drug advertising jumped from $1.1 billion a year to $4.2 billion. A recent report to Congress by the Government Accountability Office on FDA oversight of DTC advertising recommended improvements. Congress recently held hearings on the issue. In rejecting Tauzin’s call for voluntary guidelines, Senator Edward Kennedy noted that, “Patients deserve the best and most accurate information about the medicines they take. An essential part of any drug safety proposal must be to give the F.D.A. the authority and resources it needs to oversee direct-to-consumer advertising, and to allow the FDA to impose conditions or limits on that advertising, where needed to protect the public health.”

GAO: Number of New Drugs is Declining

While profits and advertising are up, the number of new drugs is declining, according to another recent report from the U.S. Government Accountability Office. The GAO found that while annual spending for research and development increased by 147 percent, the number of new drug applications grew only by 38 percent. Furthermore, the new applications were for drugs that represented modifications to existing medicines, not new medicines. Such a disparity raises doubts about the pharmaceutical industry claim that rising drug prices are a reflection of new drug development.