Pandora Report 11.22.2024

This week’s edition of the Pandora Report includes updates from the Biodefense Graduate Program, information on the upcoming BWC Working Group meeting, updates on mpox and avian influenza in California, and much more.

Mazanec Moving Up at ASPR

Brian Mazanec, Biodefense PhD ’14 and adjunct professor at the Schar School, has started a new role as Deputy Assistant Secretary and Director of the U.S. Department of Health and Human Services (HHS) Coordination Operations and Response Element (H-CORE) within the Administration for Strategic Preparedness and Response (ASPR). H-CORE was born out of Operation Warp Speed– the COVID-19 medical countermeasures response led by HHS and the Department of Defense which transitioned to ASPR in 2021. H-CORE’s mission today is to lead and enable agile, data-driven operational coordination, logistics readiness, and scalable response for public health emergencies and disasters, including infectious disease outbreaks and cyber attacks. H-CORE also now includes the Office of Cybersecurity and Infrastructure Protection, Secretary’s Operation Center, and Office of Data, Analytics, and Information Advantage.

Pandora Report Hosting the Gryphon Scientific Biosecurity Collection

The Pandora Report is now hosting a collection of papers published by Gryphon Scientific. This page serves as a repository for a selection of reports and publications from Gryphon Scientific, a research and policy consultancy that performed cutting-edge work in biosafety, biosecurity, and all-hazards preparedness and response. Over the past two decades, Gryphon supported senior decision makers within government and the commercial sector in evaluating emerging technologies and understanding how to enable their rapid development while safeguarding against their associated risks. Notably, Gryphon was commissioned by the NIH in 2016 to conduct an extensive risk-benefit analysis of gain-of-function research with potential pandemic pathogens. Gryphon was also at the forefront of AI safety, with a particular focus on the intersection of AI and biological and chemical threats. Gryphon is now continuing and expanding its work as part of Deloitte Consulting LLP. 

Transforming Defense with Biotechnology: Insights From DARPA’s Dr. Michael Koeris

Biotechnology is playing an increasingly pivotal role in strengthening national defense, with the potential to enhance military capabilities and address emerging security challenges. On November 13, the Biodefense Graduate Program at the Schar School of Policy and Government at George Mason University hosted a lecture by Dr. Michael Koeris, the recently appointed director of DARPA’s Biological Technologies Office (BTO). Dr. Koeris’ talk offered attendees a look into the cutting-edge research being done at BTO to revolutionize U.S. military capabilities through biotechnology. With a focus on warfighter readiness and operational biotechnology, Dr. Koeris shared how DARPA is developing next-generation solutions to enhance military personnel’s health and performance in increasingly complex environments. The discussion provided a unique opportunity to delve into the innovative technologies that DARPA is developing, from optimizing warfighter stamina in their AWARE (Alert Warfighter Enablement) program to their GOLDEVAC (Golden Hour Extended Evacuation) program, which is designed to provide wounded warfighters with expert-level care in austere environments when medical evacuation is delayed.

Dr. Michael Koeris

DARPA, created after the Sputnik crisis in 1957, was designed to prevent technological surprise by pushing the United States to the forefront of military innovation. DARPA focuses on strategic, high-yield programs that align with the latest technological realities, especially in fields like AI and biotechnology. DARPA intentionally pursues extremely risky programs, seeking transformational change over incremental progress, and often learns just as much from their failures. When projects do succeed—such as the development of self-driving vehicles, drones, and mRNA vaccines—they have had worldwide impacts. The agency aims to develop breakthrough technologies by maintaining agility and leveraging short program timelines to stay ahead of global technological developments. These technologies strengthen military readiness, enhance medical responses to biosecurity threats, and ensure peak performance under combat conditions. One of the main challenges discussed by Dr. Koeris was the global “data race,” especially in the field of biological data. While the United States is making progress, China’s aggressive collection of genetic and biological data has put it ahead in developing foundational biological models. This data gap poses risks to U.S. national security, as high-quality biological data is essential for AI and biotechnology advancements. To remain competitive, the United States must focus on generating diverse, original biological data to feed AI models and drive further innovation in biotechnology. As Dr. Koeris emphasized in his lecture, DARPA is committed to ensuring that the United States remains a global leader in biotechnology and national security. By strengthening its position in both data collection and its application in biotechnology, the United States can ensure it stays ahead in the race to shape the future of national defense. The lecture by Dr. Koeris shed light on the challenges and opportunities that lie ahead, leaving us better informed about the potential contributions that advances in biotechnology can make to national security.

This event summary was authored by Biodefense MS Student Katie Groves.

BWC Update
The fifth session of the Working Group on the Strengthening of the Biological Weapons Convention will take place from 2 to 13 December 2024 in Geneva, Switzerland. The agenda of the Working Group, as adopted at its first session, is available online as document BWC/WG/1/1. Details about the meeting, official documents, and side events can be found here.

Further reading:

Bonus: Check out NTI | bio’s two December 2024 BWC Meetings here (one of these is a hybrid event).

California Announces Suspected Avian Flu Case in Child

The California Department of Public Health (CDPH) announced this week that testing has identified a suspected avian influenza infection in a child in Alameda County. The child had mild upper respiratory symptoms and no known contact with any infected animals. The child is recovering at home, and CDPH says that the positive test “showed a low-level detection of the virus, indicating the child was not likely infectious to others.” Repeat testing four days later was negative. Furthermore, the child was found to also be positive for other respiratory viruses that may have caused the mild symptoms. No person-to-person spread has been detected nor is it suspected.

Further reading: “The World Is Watching the U.S. Deal With Bird Flu, and It’s Scary,” The New York Times, Tulio de Oliveira

California Confirms First Known US Clade I Mpox Case

CDPH also reported this week that it detected the first known US case of Clade I mpox. The case was identified in a person who recently traveled from Africa and it is related to the ongoing outbreak in Central and East Africa. The case has been reported to the Centers for Disease Control and Prevention. The person received care in San Mateo County and is now isolating and recovering at home. Those who had close contact with this person are being contacted by public health workers, but there is currently no concern nor evidence that clade I mpox is spreading between people in California or the US in general.

Jay Bhattacharya Reportedly Top Candidate to Lead NIH

Jay Bhattacharya, a Stanford University physician and economist who drew sharp criticism from the likes of Francis S. Collins for his “fringe” ideas about COVID-19 in the letter known as the Great Barrington Declaration, appears poised to be nominated to a top government health role. Bhattacharya is reportedly on the shortlist of contenders to lead the NIH compiled by RFK Jr., President-Elect Trump’s nominee for HHS Secretary. According to the The Washington Post, “Bhattacharya, who has said he was a victim of what felt like a “propaganda attack” led by public health experts after the Great Barrington Declaration, has testified in Congress, met with lawmakers in both parties, and offered advice to Florida Gov. Ron DeSantis (R) and other leaders navigating the pandemic. Republicans have hailed him as a truth-teller, contrasting the Stanford physician with government officials whom they blame for an overly stringent response to the health crisis.”

Bhattacharya has no experience in a senior government role nor in a role overseeing a large bureaucratic organization. This position requires Senate confirmation. Read more about Bhattacharya’s previous experience and comments about the organization he may soon lead here.

Further reading: “Global Health Experts Sound Alarm Over RFK Jr., Citing Samoa Outbreak,” The Washington Post, Sammy Westfall and Lena H. Sun

Survey of Biosafety and Biosecurity Laws in G20 Nations
The Library of Congress has published a comprehensive overview of biosafety and biosecurity laws for the member of the Group of 20 (G20) as well as a comparative analysis of these laws. According to the report, “Among the G20 nations’ laws discussed in this report, the methods for defining the terms “biosafety” and “biosecurity” generally fall into one of four categories. In the first category, “biosafety” and “biosecurity” are clearly defined in legislation or regulations, with specific distinctions. In the second set of jurisdictions, the term “biosecurity” is applied generally to topics such as laboratory safety, protecting the environment, and guarding against criminal activity involving biological agents that may harm people, plants, animals, and the environment. In other nations, laws may include one identified term, but government strategy statements or publications by government-related scientific organizations supplement the available legal definitions with more detailed descriptions of “biosafety” and “biosecurity.” The remaining nations addressed in this report have enacted laws addressing biosecurity matters, but these laws contain no legal definitions for “biosafety,” “biosecurity,” or similar terminology.”

ISAB Report on PRC, MCF, and Biotechnology
The Secretary of State’s International Security Advisory Board (ISAB) has released a new report on the biotechnology components of the People’s Republic of China’s (PRC) Military-Civil Fusion (MCF) Strategy, with a focus on biotechnology development objectives, implementation, and implications for international biosecurity. ISAB provides the Department with a continuing source of independent insight, advice, and innovation on all aspects of arms control, disarmament, nonproliferation, outer space, critical infrastructure, cybersecurity, the national security aspects of emerging technologies, international security, and related aspects of public diplomacy.  The ISAB’s goal is to advise the State Department and other federal agencies on how the United States can adapt to the changing global biotech landscape, particularly in the context of strategic competition with PRC. The report proposes that the Department of State and other U.S. government agencies take steps to develop a global biotech system in which a broad range of partners cooperates on scientific research and trade. This requires a long-term strategic approach, and the leadership of the Department of State, to build this global environment that aligns with U.S. interests.

“WHO Technical Advisory Group on the Responsible Use of the Life Sciences and Dual-Use Research: Report of the Meeting, 25 June 2024”

From WHO: “The World Health Organization (WHO) Technical Advisory Group on the Responsible Use of the Life Sciences and Dual-Use Research (TAG-RULS DUR) (1) was established to provide independent advice to WHO on the monitoring and mitigation of biorisks, the advances in the life sciences and related technologies, the governance of dual-use research and the responsible use of the life sciences.””

“This meeting was the second virtual meeting and third overall meeting of 2024. Over the course of the meeting, participants discussed and provided feedback on the first draft of the BioRisk Implementation and Evaluation Framework (BRIEF) Tool, were briefed on the draft WHO course on Dual-Use Research and the Responsible Use of the Life Sciences and delivered updates on activities of the TAG’s four working groups.”

“The TAG-RULS DUR and its working groups will continue to undertake activities on the key topics identified. The group agreed that its next meeting will be held in October 2024.”

Read the meeting report here.

“Age of Biology Requires American Leadership”

Sen. Todd Young, Chair of the National Security Commission on Emerging Biotechnology, recently authored this opinion piece for Roll Call in which he discusses a forthcoming report from the Commission discussing actions needed to “maintain and strengthen America’s global leadership position” in biotechnology. He explains in this piece that “Congress must enact policies that accelerate innovations at home, onshore our supply chains, create data-sharing agreements with our allies, and support our military’s use of novel biotechnologies. Broadly, this will be the focus of the NSCEB’s forthcoming Final Report in 2025. Policymakers must protect and promote American biotechnology to ensure the United States leads the Age of Biology, and I am confident the NSCEB will contribute to these efforts.”

“Guidance for Human Genome Data Collection, Access, Use and Sharing”

From WHO: “The ethical, legal, and equitable sharing of human genomic data is critical to advancing global health research and ensuring fair access to the benefits of genomics. The WHO’s new document outlines a comprehensive set of globally applicable principles designed to guide stakeholders in the responsible collection, use, and sharing of human genome data. This document serves as a key resource to navigate complex issues surrounding data governance, with the aim of fostering transparency, promoting equity, and safeguarding individual and collective rights. These principles are intended to support the implementation of best practices across diverse settings, thereby enhancing the global capacity for genomic research and its translation into health benefits for all.”

“The Superbug Fight Needs a Better Business Model”

Annalies Winny published this piece in Global Health Now discussing the dearth of antibiotic research, writing in part “Researchers say that the current business model for developing antibiotics—and getting them to where they’re needed most—isn’t fit for purpose. Countries are starting to get behind incentives that absorb some of the risk, and offer a significant return on investment. But funding for these programs still lags far behind what’s needed to save millions of lives, and billions of dollars in health care costs, and there are doubts about whether incentives led by wealthy nations will satisfy needs in low- and middle-income countries.”

“Gaza Bombardment Worsens Superbug Outbreaks”

Misbah Khan published this piece for The Bureau of Investigative Journalism describing the growing public health crisis in Gaza. She writes in part, “There is a growing and dire public health crisis taking place in Gaza. Israeli blockades and hospital bombings are fuelling a superbug emergency, with civilians who survive starvation and injury later facing untreatable, life-threatening infections…Doctors on the ground told the Bureau of Investigative Journalism (TBIJ) they were treating wounds infested with maggots and using vinegar to fight infections.”

“Potential Research Priorities to Inform U.S. Readiness and Response to Avian Influenza A (H5N1)”

From NASEM: “Avian Influenza A (H5) viruses have circulated globally for decades among migratory bird populations. The recent emergence of Avian Influenza A (H5N1) in U.S. dairy cattle has led to challenges in managing and controlling the spread of H5 viruses between livestock, wildlife, and companion animals, as well as to humans from infected animals. The National Academies hosted a public workshop in October 2024 to explore potential research priorities that could inform readiness and response to the outbreak. Discussions followed an interdisciplinary One Health approach, bringing together experts from across human, veterinary, plant, and environmental health disciplines, and builds on published federal research priorities for H5N1 to include perspectives beyond basic translational clinical sciences, to social sciences, veterinary health, agricultural economics, and occupational health, among others.”

Read the proceeding of this workshop here.

“Diagnosis in the Era of Digital Health and Artificial Intelligence: Proceedings of a Workshop-in Brief”

From NASEM: “To explore the opportunities and challenges of using artificial intelligence (AI) and digital health technologies to improve diagnostic processes and outcomes, the National Academies Forum on Advancing Diagnostic Excellence hosted a public workshop in July 2024. Speakers highlighted the role of these technologies throughout the diagnostic process and their impact on the patient experience, including to gain understanding of a patient’s onset of symptoms, to improve information gathering and patient-clinician communication, and to support clinical decision making. Discussions also emphasized the importance of ensuring these technologies do not perpetuate existing health disparities.”

Read the proceedings here.

“OPCW Investigation Confirms Russia’s Likely Use of Chemical Weapons Against Ukraine”

Andrea Stricker authored this analysis of recent OPCW findings regarding Russia’s likely use of CW in Ukraine. She explains that “Russia’s consistent denials that its military forces have deployed illegal chemical weapons in Ukraine were dealt a serious blow on November 18, when the Organization for the Prohibition of Chemical Weapons (OPCW) announced that it had recently conducted a Technical Assistance Visit to Ukraine and established evidence of chemical weapons use. While the OPCW stopped short of attributing responsibility to Russia, a growing body of evidence points to numerous Russian chemical weapon attacks against Ukrainian front-line troops in violation of the 1997 Chemical Weapons Convention, to which Moscow is a party.”

“Research and Development Areas to the North of Hamhung”

Read the latest installment of RUSI’s Project Anthracite analysis of the DPRK’s chemical industry and CW program: “The area to the north of the city of Hamhung is home to academic institutions and research and development (R&D) facilities. Furthermore, there are access tunnels to likely underground areas in the vicinity, and the wider region is home to significant chemical industry. Although literature on these facilities is limited, satellite imagery has been analysed to determine whether it is possible to discern any linkages with or provide insight on North Korea’s chemical industry or chemical weapons (CW) programme. Although evidence was circumstantial and no direct linkages could be identified on imagery, the analysis was able to confirm the location of several academic and R&D facilities and contribute to baselining potential academic and R&D facilities in the area.”

“While the location of at least part of a CW programme in or around these facilities cannot be ruled out, there were no features that would indicate the likely presence of a CW programme in these facilities.”

“NNSA celebrating 50 years of the Nuclear Emergency Support Team – NEST”

“This month, NNSA is observing the 50th anniversary of what is now called the Nuclear Emergency Support Team – or NEST. During a recent ceremony at Joint Base Andrews in Maryland, leaders from around the government gathered to celebrate the birthday of one its most diverse and capable assets…NEST, created by President Ford in 1974, has a mission to provide federal emergency response in case of a radiological or nuclear threat, incident or accident.”

Read more about NEST, its formation, and its future here.

NEW: DC Biosecurity Happy Hour

From DC Biosecurity Professionals Across Academia, Industry, and Think Tanks: “Please join us for the Biosecurity Happy Hour, an informal event for biosecurity professionals in DC to get to know each other outside of Zoom calls and talk about new ideas in this space. Please note that drinks will be at attendee’s own expense!”

This event will take place on December 5 from 6:30-8 pm EST at Dacha Beer Garden in Washington, DC. Learn more and reserve a spot here.

NEW: A New Paradigm for Threat Agnostic Biodetection: Biological Intelligence (BIOINT)

From PNNL: “Please join us in welcoming Swati Sureka, Strategy and Policy Analyst at Arctic Slope Regional Corporation (ASRC) Federal, where she supports the Office of the Deputy Assistant Secretary of Defense for Health Readiness Policy and Oversight. Her talk, titled “A New Paradigm for Threat Agnostic Biodetection: Biological Intelligence (BIOINT),” will take place on Tuesday, December 10th, at noon PT.”

Learn more and RSVP here.

NEW: Cyberbiosecurity Summit

From Johns Hopkins APL and Bio-ISAC: “Advancements in biomanufacturing and biotechnology drive the science we need to thrive, everything from apples to vaccines. The Cyberbiosecurity Summit 2025 convenes leading experts in biotechnology, biosecurity, and cybersecurity to explore the intersection of these fields and discuss the strategies to create a safe, secure future for us all.”
This event will take place February 25-26 in Laurel, MD. Register here and review the call for sessions here.

One Health and the Politics of COVID-19 Book Launch

The Writer’s Center is hosting a book launch for Dr. Laura Kahn’s new book, One Health and the Politics of COVID-19 (blurb below) on November 23 at 2 pm EST in Bethesda, MD. Learn more and RSVP here.

One Health and the Politics of COVID-19 unpacks the mysteries of COVID-19’s origins to impart important lessons for future outbreaks. The One Health concept recognizes the interconnected links among the health of humans, animals, plants, and the environment. By comparing the history, science, and clinical presentations of three different coronaviruses—SARS-CoV-1, MERS, and SARS-CoV-2 (COVID-19)—Kahn uncovers insights with important repercussions for how to prepare and avoid future pandemics. The One Health approach provides a useful framework for examining the COVID-19 pandemic. Understanding the origins of this zoonotic disease requires investigating the environmental and molecular biological factors that allowed the virus to spread to humans. The book explores the many ways in which the wild animal trade, wet markets, and the camel industry contributed to the spread of the earlier SARS-CoV-1 and MERS coronaviruses. For SARS-CoV-2 (COVID-19), Kahn examines the biosafety, biosecurity, and bioethics implications of gain-of-function research on pandemic potential pathogens. This book is a must read to understand the geopolitics of the COVID-19 pandemic.”

2024 CBD S&T Conference

From DTRA: “The CBD S&T Conference brings together the most innovative and influential chemical and biological defense community members from around the globe to share insights and collaborate on the emerging chem-bio threats of tomorrow.”

“Join the Defense Threat Reduction Agency’s (DTRA) Chemical and Biological Technologies Department in its role as the Joint Science and Technology Office (JSTO) for Chemical and Biological Defense, an integral component of the Chemical and Biological Defense Program, as we Focus Forward to uncover novel concepts and examine groundbreaking discoveries within the chem-bio defense landscape.”

“The 2024 CBD S&T Conference will be held at the Broward County Convention Center, December 2–5, 2024.”

Learn more and register here.

Health Security Intelligence: Managing Threats Risks and Hazards Post-Covid 19
“As  the acute impact of the COVID-19 pandemic recedes, many unaddressed questions remain for Australia about how to better prepare for the next likely health threat, risk or hazard.”

“In addition to how we enhance national public health capacity, what are the important lessons we can learn from the pandemic from national security and biosecurity perspectives?”

“Given the likelihood of another pandemic at some point, an increasingly uncertain geo-political order and the potential exploitation of biotechnology by bad actors how does Australia and its allies better prepare for a future of increasingly complex health security and biological security threats, risks and hazards?”

“This event is for all health security intelligence stakeholders (policy-makers, national security staff, scientists, researchers and clinicians) who work across the one health continuum and national security agencies.”

“It will introduce participants to Charles Sturt’s extensive research agenda across the one health biosecurity, health and biological security and discuss both their national security and scientific implications.  You will hear briefings from key researchers across both STEM and social sciences disciplines working on assessing key health security threats, risks and hazards relevant to your work.”

This event will take place in-person and over livestream on December 4 from 2-4 pm AEDT. Learn more and register here.

Enhancing the Resilience of Healthcare and Public Health Critical Infrastructure: A Workshop

From NASEM: “Healthcare and public health infrastructure, technology, and operations are rapidly changing and are increasingly interdependent and interconnected. Threats to the nation’s critical social and physical infrastructure systems are also rapidly evolving and highly complex—posing potentially new or growing risks of disruption and challenging the assumptions used to design and protect these systems.”

“The National Academies Forum on Medical and Public Health Preparedness for Disasters and Emergencies will host a hybrid public workshop to explore strategies, policies, and innovative actions to improve the resilience of healthcare and public health (HPH) critical infrastructure to impacts from disasters and other emergencies.”

This event will take place in DC on December 9 and 10. Register here.

Resilience in the Face of Global Risks

From CSR: “The Council on Strategic Risks (CSR) cordially invites you to our first annual CSR symposium, Resilience in the Face of Global Risks, scheduled for Tuesday, December 10, 2024. This is the first event bringing together all three of CSR’s institutions—the Center for Climate & Security, the Converging Risks Lab, and the Janne E. Nolan Center on Strategic Weapons—to engage with leaders across our mission sets.”

“The United States and its allies face a complex global security landscape where systemic risks like climate and ecological crisis, nuclear proliferation, and biological threats are blending with war, geopolitical competition, and human insecurity in new and profound ways. While there has been tremendous leadership—and meaningful progress—across these overlapping risk areas, they require persistent innovation in community building to meet the modern risk landscape.”

“The symposium will dive into the progress our communities have made—and how our passionate communities can better work together to help shape the future.”

“In addition to a keynote address, guests will hear from panels, take part in breakout sessions showcasing important issues and new ideas, plus engage with thought leaders between sessions. It will be a widely attended gathering, free to attendees.”

“As we enter a new year with an exceptionally dynamic security environment, we hope CSR’s December event will inspire and build a stronger community across professionals dedicated to anticipating and addressing the world’s greatest risks. We appreciate your consideration and hope you will be able to join us on the 10th of December.”

RSVP here.

NEW: Call for Nominees: National Biodefense Science Board
From Global Biodefense: “The Administration for Strategic Preparedness and Response (ASPR), part of the U.S. Department of Health and Human Services (HHS), is currently seeking applications from qualified individuals to fill 7 vacancies on the National Biodefense Science Board (NBSB).”

“The NBSB advises the HHS Secretary or the ASPR on current and future trends, challenges, and opportunities presented by advances in biological and life sciences, biotechnology, and genetic engineering with respect to threats posed by naturally occurring infectious diseases and chemical, biological, radiological, and nuclear agents.”

Read more and access ASPR’s call for nominees here.

“New Public Health Cybersecurity Readiness Survey Set to Boost Preparedness Against Cyber Threats”

“The co-chairs of the Joint Public Health Cybersecurity Task Group of the Healthcare and Public Health Sector Coordinating Council (HSCC) published a special announcement letter announcing the launch of the Public Health Cybersecurity Readiness Survey. The move aims to enhance the cybersecurity preparedness of state, local, tribal, and territorial (SLTT) public health agencies. Participants can expect the anonymous survey to take about 15 minutes to complete, and it will be open until Monday, Dec. 2, 2024.”

Read more and access the survey here.

The Schar School is Hiring!

The Schar School of Policy and Government at George Mason University is hiring a tenure-track assistant professor. Expertise in international security, national security, homeland security, emergency management, artificial intelligence, cybersecurity, the defense industrial base, or transnational crime and corruption will be regarded positively. Candidates whose work focuses on climate security, technological change, and the future of warfare, or domestic extremism are also encouraged to apply, as are candidates with regional expertise. Details can be found here: https://listings.jobs.gmu.edu/jobs/assistant-professor-fairfax-va-virginia-united-states-other.

US AI Safety Institute Issues RFI on Responsible Development of Chem-Bio Models

From AISI: “The U.S. Artificial Intelligence Safety Institute (U.S. AISI), housed within the U.S. Department of Commerce’s National Institute of Standards and Technology (NIST), released a Request for Information seeking insight from stakeholders regarding the responsible development and use of chemical and biological (chem-bio) AI models.”

“Input from a broad range of experts in this field will help the U.S. AISI to develop well-informed approaches to assess and mitigate the potential risks of chem-bio AI models, while enabling safe and responsible innovation.”

“Respondents are encouraged to provide concrete examples, best practices, case studies, and actionable recommendations where possible. The full RFI can be found here.”

“The comment period is now open and will close on December 3, 2024, at 11:59PM Eastern Time. Comments can be submitted online at www.regulations.gov, under docket no. 240920-0247.”

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