RAY SUAREZ: For more on the funding request and how to spend the money, we get two perspectives. Richard Perle serves on the Defense Policy Board, which advises the secretary of defense, and was assistant secretary of defense under Ronald Reagan.

Medea Benjamin is founding director of Global Exchange, a San Francisco-based human rights organization. She recently visited Iraq with human rights organizations tracking the reconstruction.

Medea Benjamin, we all just heard Paul Bremer lay out the spending plan and the priorities for the Iraq reconstruction. Is it the right plan, and is it the right amount of money?

MEDEA BENJAMIN: No, it's not the right plan. Bremer doesn't have an idea what he's doing. I just came back from Iraq, it's a disaster, people don't have electricity, water, garbage collection, sewage collection, jobs. They're angry, they're bitter. They say the United States money is not getting down to the people, it's going to Halliburton, it's going to Bechtel. We should not approve this $87 billion, instead there should be immediate transition over to the United Nations and as soon as possible to Iraqi self rule.

Bremer's focus and spending priorities

RAY SUAREZ: Richard Perle, did Paul Bremer's plan sound right to you both in its focus and its spending priorities?

RICHARD PERLE: Yes, it did, and I find it a bit ironic to listen to someone say there's no electricity, there's no water, therefore we must not spend money on electricity and water. What we are attempting to do in Iraq is precisely restore essential services, as Ambassador Bremer indicated, provide security, and open the way to a decent Iraqi government and a private Iraqi economy.

MEDEA BENJAMIN: But we haven't been able to do it in six months.

RICHARD PERLE: Of course it can't be done in six months, no one is proposing that it could be done in six months--

MEDEA BENJAMIN: It certainly can and should have been done in six months. The electricity should be up and running, if the Iraqis were in charge they would have done it themselves. The water supply should be running, the telephone system should be up and running. There is no reason to have this chaos that's in Iraq right now. And it's because the U.S. Administration doesn't have a clue about what it's doing. That's why it needs to be an immediate transition the U. N., and then to the Iraqis who know how to rebuild their own economy much better than Paul Bremer.

RAY SUAREZ: Richard Perle.

RICHARD PERLE: Well, I certainly believe that the Iraqis should be involved in the rebuilding their economy, and they will be. Much of the work that will be done under this program will be carried out by Iraqi workers. I can't for the life of me see how adding the United Nations bureaucracy to this is going to expedite getting Iraqis to work, rebuilding their country.

The contested effectiveness of reconstruction

RAY SUAREZ: Let's return to the -- Ms. Benjamin, let me continue here. By many accounts inside the Senate there is no appetite for turning down this package. Can we look at the money that's been spent in Iraq already and see that it's been spent well so that there's some confidence that the next $87 billion might be spent well also?

MEDEA BENJAMIN: No, we can't at all. We've already spent $78 billion.

RAY SUAREZ: Let Richard Perle answer that question, then I'll give you a chance.

MEDEA BENJAMIN: Sure.

RICHARD PERLE: The amounts that have been spent on reconstruction up until now have been spent under extremely difficult circumstances. And I have no reason to believe that that money under those circumstances has not been spent reasonably or spent well. This is not a situation in which you can go out and offer contracts where contractors are free to employ work forces without security concerns. It's a very difficult situation. And so if one were to go back and do an audit, I suppose you'll find that some of the standards of peacetime stable societies didn't apply. But on the whole, given the circumstances, I think we've done rather well.

RAY SUAREZ: Medea Benjamin?

MEDEA BENJAMIN: Well, we've done miserably, Ray. Just think -- Halliburton is making $2 billion, Bechtel is making $1 billion. And they haven't been able to turn on the electricity or turn back the water supply. They can't do the job, plus they're wasting massive amounts of money. Even the governing council that was hand-appointed by the U.S. is saying that the money being spent is being wasted because it's U.S. companies in charge instead of Iraqis.

RAY SUAREZ: So you would suggest immediate turning over of authority to the U. N. Does the U. N. have a track record in these matters that's more encouraging than America's thus far?

MEDEA BENJAMIN: Well, it certainly has a track record that's more encouraging than the Americans. It's been six months since this occupation, and even the Iraqis who welcomed the U.S. with open arms and were so happy to get rid of Saddam Hussein are now extremely bitter and angry. The resentment will only grow unless the U.S. turns this over to a legitimate authority, which is the United Nations, which will have a quick time line for Iraqi self rule and that the money that is pledged by the U.S. and the international community -- and let's remember the international community will not pledge money unless it is in the hands of the United Nations -- and that money should go directly to Iraqis and not to companies like Halliburton and Bechtel that are profiteering from this war.

RICHARD PERLE: What you just heard is a tirade against American companies in the left-wing tradition that she represents. Her characterization of the situation in Iraq is not at all borne out by many conversations I've had with Iraqis, including members of the governing council she's been referring to.

MEDEA BENJAMIN: Well, I challenge to you go there with me, Mr. Perle, because I was there in July, I was there in August, I don't stay in the presidential palace, I don't go around with bodyguards and helicopters and sniffing dogs like Paul Bremer and Colin Powell. I challenge to you go with me, without any bodyguards and let's walk around the streets of the cities of Iraq and see what it looks like six months after the U.S. occupation.

RICHARD PERLE: With all due respect, your sojourns in the cities of Iraq are hardly the appropriate measure of how well we have done in restoring electricity and getting water back on track. I don't think --

MEDEA BENJAMIN: You know better sitting in Washington, D.C.?

RAY SUAREZ: Let him finish, please.

RICHARD PERLE: Let's be clear. This is a massive undertaking and very significant progress has been made, and it makes no sense for to you sit there and say nothing has been accomplished when a great deal has been accomplished.

MEDEA BENJAMIN: It's an absolute disaster, Mr. Perle, and I think you know it, but go with me and you'll see with your own eyes.

An eventual political price?

RAY SUAREZ: If we are in a situation where even by Paul Bremer's own admission, things are not where they wanted them to be by this point in the occupation, is there also a political price that's eventually paid -- as far as working with a civilian population that is becoming impatient, regardless of what happened before the invasion, but becoming impatient with American administration right there at the moment?

RICHARD PERLE: People are impatient when they can't get electricity. I was without it until earlier today. For four days. And I was awfully impatient, after the storm we had here. So it's perfectly understandable that people are impatient. It is also very clear that no one wants Saddam Hussein back. That was a regime of terror and we're well rid of it and the Iraqi people are well rid of it and they are a good deal more tolerant than some Americans, as we've just seen. They're prepared to work with us, they're eager to work with us and they are working with us, and the bitterness that I just heard described is not the prevailing sentiment in Iraq.

MEDEA BENJAMIN: Because you haven't been there - go on any street corner.

RAY SUAREZ: Did you see no electricity in evidence, no public utilities in evidence? I mean all the reporting that's coming out of Iraq shows that these things are sporadic, perhaps not as reliable as they should be, but in some evidence.

MEDEA BENJAMIN: The electricity is sporadic, it's less available than it was under Saddam Hussein. The streets are full of green bubbling sewage, there is no decent garbage collection. There is no decent access to water. There is an unemployment crisis because so many people have been thrown out of their jobs, and perhaps worst of all, there is no law and order. Women, particularly, are afraid to go out of their homes, afraid to go out on the streets.

There will be no law and order until the U.S. troops leave Iraq, it's turned over to the United Nations, and then becomes in the hands of the Iraqis themselves, that's the only way this situation is going to improve for the Iraqis themselves, and let's remember that many Americans feel there's a much better use of $87 billion to put into our schools, our health care system, our public transportation system, instead of spending it to put our boys and girls in harm's way in Iraq, a country where they don't want to be and a country where the Iraqis don't want us.

RICHARD PERLE: Now we've gone full circle. We've come from deploring the situation in Iraq, to saying that things have to be done to fix it, to saying we shouldn't spend any money to fix it. I think it's very clear that she's just not the least bit interested in the people of Iraq.

RAY SUAREZ: But can American policymakers expect the kind of help that they're looking for from the U.N. without ceding some oversight of the reconstruction?

RICHARD PERLE: I don't know what help we're looking for from the United Nations. You asked earlier about the track record of the United Nations. I had a conversation with a very senior Afghan official, a cabinet minister, just recently, who said to me everything the U. N. does in Afghanistan costs three times as much as what we are able to do for ourselves. We do it -

MEDEA BENJAMIN: The governing council in Iraq is saying that it's costing ten times…

RICHARD PERLE: Could I -

RAY SUAREZ: Let him finish, please.

MEDEA BENJAMIN: … to give to the U.S. what would be used in Iraq.

RICHARD PERLE: We -- we do agree on one point, which is that the sooner the people of Iraq are in control of their own destiny, the better. And the way to facilitate that is by providing a jump start, by providing some money that will start the reconstruction. This is a country in which there was virtually no investment for three decades, there was nothing but tyranny and murder. And so it is at the beginning in every respect, with respect to electricity, with respect to water, with respect to --

MEDEA BENJAMIN: Well, there's less electricity, there's less water, there's less jobs available. People are miserable, Mr. Perle. This is not working, it is I quagmire, we need the world community to invest funds into Iraq because we can't do it alone and the only way we're going to get that help from the international community is if we turn the situation over to the United Nations, the only legitimate authority to oversee the transition to Iraqi self rule.

RAY SUAREZ: We have to end it there. Medea Benjamin, Richard Perle, thank you both.

Men always praise the ancient times and find fault with the present, but not always with good reason; and they are such partisans of things past, that they celebrate not only that age which has been recalled to their memory by known writers, but those also which they remember having seen in their youth. And when this opinion of theirs is false, as it is most of the times, I am persuaded the reasons by which they are led to such deception are various. And the first I believe is that the whole truth which would bring out the infamy of those times, and they amplify and magnify those others that could bring forth their glory. Moreover, the greater number of writers so obey the fortune of the winners that, in order to make their victories glorious, they not only exaggerate that which is gotten by their own virtu, but they also exaggerate the actions of the enemies; so that whoever afterwards is born in either of the two provinces, both the victorious and the defeated ones, has cause to marvel at those men and times, and is forced summarily to praise and love them. In addition to this, men hating things either from fear or envy, these two reasons for hating past events come to be extinguished, as they are not able to offend or give cause for envy of them. But the contrary happens with those things that are in operation and are seen, which because you have a complete knowledge of them as they are not in any way hidden from you; and knowing the good together with the many other things which are displeasing to you, you are constrained to judge the present more inferior than the past, although in truth the present might merit much more of that glory and fame; I do not discuss matters pertaining to the arts, which shine so much by themselves, which time cannot take away or add a little more glory which they merit by themselves; but I speak of those matters pertinent to the lives and customs of men, of which such clear evidences are not seen.

I repeat, therefore, that the custom of praising and blaming as mentioned above is true, but it is not true that you err in doing it. For sometimes of necessity our judgment is the truth, as human affairs are always in motion, either ascending or descending. And we see a City or a Province well-organized in its government by some excellent man, and for a time always progressing toward the better through the virtu of that organizer. He who is born in that state, and praises the past more than the present, deceives himself; and his deception is caused by those things mentioned above. But if they are born in that City or province after the time when it has begun to descend to its bad times, then he does not deceive himself. And in thinking of how these things go on, I judge that the world has always been in the same condition, and that there is as much good as there is bad in it; but this bad and good vary from province to province, as is seen by the historian of those ancient Kingdoms which varied from one another because of the variations in customs, while the world remained the same: the only difference was, that where virtu first found a place in Assyria, it then to Media, afterwards to Persia, and from there came to Italy and Rome: and if after the Roman Empire no other Empire followed which endured, and where the world kept together all its virtu, none the less it is seen to be scattered in many nations where people lived with virtu, as it was in the Kingdom of the Franks, the Kingdom of the Turks, that of the Soldan (of Egypt), and today the people of Germany, and before then that Saracen Sect which accomplished such great things and occupied so much of the world after having destroyed the Eastern Roman Empire. In all these provinces, therefore, after the Romans fell, the Sects possessed, and yet possess in part, that virtu which is desired and lauded with true praise. And whoever is born in them and praises the times past more than the present, may deceive himself: but whoever is born in Italy and Greece, and has not become either an Ultramontane in Italy or a Turk in Greece, has reason to find fault with his times and to praise the others, for in the past there are many things that make him marvel, but now there is not anything that will compensate for the extreme misery, infamy, and disgrace in these times where there is no observance of religion, of laws, or of military discipline, but are stained by every brutish reasoning. And these vices are even more detestable as they exist more in those who sit in the tribunals, commanding everyone, and desiring to be adored.

But returning to our argument, I say that, if the judgment of men is corrupt in deciding whether the present or the ancient age is better, in those things where because of their antiquity they cannot have a perfect knowledge as they have of their own times, the old men ought not to corrupt themselves in judging the times of their youth and their old age, they having known and seen the latter and the former equally. Which thing would be true if men throughout all the periods of their lives had the same judgment and the same appetites. But as these vary, things cannot appear the same to those men who have other appetites, other delights, and other considerations in their old age than in their youth. For as men wane in strength but grow in judgment and prudence, so it is that those things which in their youth appeared supportable and good, will turn out unsupportable and bad, and where they ought to blame their judgment, they blame the times. In addition to this, human appetites being insatiable because by nature they have to be able to and want to desire everything, and to be able to effect little for themselves because of fortune, there arises a continuous discontent in the human mind, and a weariness of the things they possess; which makes them find fault with the present times, praise the past, and desire the future, although in doing this they are not moved by any reasonable cause. I do not know, therefore, whether I merit to be numbered among those who deceive themselves, if in these Discourses of mine I shall laud too much the times of the ancient Romans and censure ours. And truly, if the virtu that then reigned and the vice that now reigns should not be as clear as the Sun, I would be more restrained in talking, being apprehensive of falling into that deception of which I accuse others. But the matter being so manifest that everyone sees it, I shall be bold in saying openly that which I learned of those times and these, so that the minds of the young men who may read my writings can avoid the latter and imitate the of the former, whenever fortune should give them the opportunity. For it is the office of a good man to show others that good which because of the malignity of the times and of fortune, he has not been able to accomplish, so that some of those more loved by Heaven can accomplish them.

[Federal Register: September 16, 2003 (Volume 68, Number 179)]
[Notices]
[Page 54233-54234]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr16se03-60]

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DEPARTMENT OF HEALTH AND HUMAN SERVICES

Food and Drug Administration

[Docket No. 2003D-0186]

Guidance for Industry on Use of Material From Deer and Elk in
Animal Feed; Availability

AGENCY: Food and Drug Administration, HHS.

ACTION: Notice.

-----------------------------------------------------------------------

SUMMARY: The Food and Drug Administration (FDA) is announcing the
availability of a guidance ([numsign]158) entitled ``Use of Material
From Deer and Elk in Animal Feed.'' This guidance document describes
FDA's recommendations regarding the use in all animal feed of all
material from deer and elk that are positive for chronic wasting
disease (CWD) or are considered at high risk for CWD.

DATES: Submit written or electronic comments on agency guidances at any
time.

ADDRESSES: Submit written comments on this guidance document to the
Division of Dockets Management (HFA-305), Food and Drug Administration,
5630 Fishers Lane, rm. 1061, Rockville, MD 20855. Submit electronic
comments to http://www.fda.gov/dockets/ecomments. Comments should be
identified with the full title of the guidance document and the docket
number found in the heading of this document. See the SUPPLEMENTARY
INFORMATION section for electronic access to the guidance document.
Submit written requests for single copies of this guidance document
to the Communications Staff (HFV-12), Center for Veterinary Medicine,
Food and Drug Administration, 7519 Standish Pl., Rockville, MD 20855.
Send one self-addressed adhesive label to assist that office in
processing your requests.

FOR FURTHER INFORMATION CONTACT: Burt Pritchett, Center for Veterinary
Medicine (HFV-222), Food and Drug Administration, 7500 Standish Pl.,
Rockville, MD 20855, 301-827-0177, e-mail: bpritche@cvm.fda.gov.
SUPPLEMENTARY INFORMATION:

I. Background

In the Federal Register of May 16, 2003 (68 FR 26628), FDA
published a notice of availability for a draft guidance entitled ``Use
of Material from Deer and Elk in Animal Feed'' giving interested
persons until June 16, 2003, to submit comments. FDA considered all
comments received.

II. Paperwork Reduction Act of 1995

FDA concludes that this guidance contains no collections of
information. Therefore, clearance by the Office of Management and
Budget under the Paperwork Reduction Act of 1995 is not required.

III. Significance of Guidance

This level 1 guidance document is being issued consistent with
FDA's good guidance practices regulation (21 CFR 10.115). This guidance
document represents the agency's current thinking on the topic. It does
not create or confer any rights for or on any person and does not
operate to bind FDA or the public. An alternative method may be used as
long as it satisfies the requirements of applicable statutes and
regulations.

IV. Comments

As with all of FDA's guidances, the public is encouraged to submit
written or electronic comments with new data or other new information
pertinent to this guidance. FDA periodically will review the comments
in the docket and, where appropriate, will amend the guidance. The
agency will notify the public any such amendments through a notice in
the Federal Register.
Interested persons may submit to the Division of Dockets Management
(see ADDRESSES) written or electronic comments on the final guidance at
any time. Comments should be identified with the docket number found in
brackets in the heading of this document. A copy of the document and
received comments are available for public examination in the Division
of Dockets Management between 9 a.m. and 4 p.m., Monday through Friday.

V. Electronic Access

Persons with access to the Internet may obtain a copy of the final
guidance document entitled ``Use of Material From Deer and Elk in
Animal Feed'' from the Center for Veterinary Medicine home page at
http://www.fda.gov/cvm.

[[Page 54234]]

Dated: August 29, 2003.
Jeffrey Shuren,
Assistant Commissioner for Policy.
[FR Doc. 03-23559 Filed 9-15-03; 8:45 am]

BILLING CODE 4160-01-S

from: http://www.ccianet.org/letters/dhs_030827.pdf

August 27, 2003
The Honorable Tom Ridge
Secretary
U.S. Department of Homeland Security
Washington, D.C. 20528

Dear Secretary Ridge:

In light of last week’s events revealing additional serious flaws in
the Windows software bundle, I am writing concerning the Department
of Homeland Security’s choice of Microsoft as the preferred supplier
of desktop and server software for its computing needs. I strongly
urge you to reconsider this decision.

The Computer & Communications Industry Association (CCIA) is an
association of computer, communications, Internet and technology
companies that range from small entrepreneurial firms to some of the
largest members of the industry. CCIA was founded over 30 years ago
and our members include equipment manufacturers, software
developers, providers of electronic commerce, networking,
telecommunications and online services, resellers, systems
integrators, and third-party vendors. Our member companies employ
nearly one million people and generate annual revenues exceeding
$200 billion. Although we have always supported open, industry-wide
fair and efficient procurement policies, we do not represent
companies in the bidding and procurement process.

CCIA also has a long history of advocacy and expertise in the area
of cybersecurity. We recently pointed out in submissions sent to the
Administration and the Congress the importance of security testing,
the dangers of relying on single suppliers for information
technology, the inherent risks associated with homogenous systems,
and the need for “biodiversity” among software components and
applications.

We believe that for software to be truly secure it must be well
written from the outset with security considerations given a high
priority. Unfortunately, there is ample evidence that for many years
economic, marketing, and even anticompetitive goals were far more
important considerations than security for Microsoft’s software
developers, and these broader objectives were often achieved at the
cost of adequate security. Also, from a security standpoint, the
lack of diversity within a networked system amplifies the risk
emanating from any vulnerabilities that do exist. But diversity is
difficult without interoperability, and the benefits of
interoperating with more robust systems can be blocked if any
dominant player does not cooperate in fostering interoperability.
Unfortunately, numerous courts and government enforcement bodies,
including the United States Department of Justice, have formally
found that Microsoft has used technical barriers to inhibit
interoperability with, and competition from, other software
platforms and applications.

We are currently engaged in extensive security research in this area
and our preliminary findings indicate the severity of the security
problems relating to some Microsoft software is substantial. The
news from the last few weeks demonstrates that this problem is not
just theoretical, but real and immediate and one that imperils
homeland security.

In just the last two weeks, Microsoft products have been attacked by
a virus and worm -- Sobig.F and Blaster -- but these are only the
most recent examples of major security failure created by
vulnerabilities in Microsoft’s dominant software portfolio. The
damage caused by these attacks is significant and has caused
millions of dollars of harm to our economy, but security experts
agree the damage could easily have been much worse. According to the
Washington Post, Blaster and its associated counter-measures were
responsible for the temporary closure of Maryland’s Department of
Motor Vehicles offices, failure of the passenger check-in system at
Air Canada, an intrusion on the Navy-Marine intranet, and
cancellations and suspensions of service on the CSX railroad. Of
even greater concern are recent reports of an April e-mail to the
Nuclear Regulatory Commission from FirstEnergy detailing how a
previous worm directed at Microsoft servers, Slammer, disabled a
safety monitoring system at an offline nuclear power plant for close
to five hours. Fortunately, the plant was not operational during the
failure, there was no safety hazard, but this incident could have
just as easily occurred with an online plant. All of these failures
are unfortunately predictable and we can expect to continue to see
similar problems in the future.

In short, we have seen these most recent worms and viruses directed
at Microsoft slow down, delay, and disable systems handling critical
transportation, military and energy functions. Though certainly the
creator of these malicious attacks must bear the brunt of blame,
Microsoft is also largely responsible for continuing to create
software riddled with obvious and easily exploited vulnerabilities.
This problem is compounded when new or separate products and
functionalities are intricately bundled, sometimes illegally, into
Windows. As the Washington Post editorialized:

[T]he main cause of virus prevalence, say computer experts, is
poorly designed software. The Blaster worm was created to take
advantage of a vulnerability in Microsoft’s operating system,
particularly targeting Windows XP, Windows 2000, Windows NT, and
Windows Server 2003. Such vulnerabilities exist because software is
distributed without appropriate amounts of testing and because
software vendors increasingly create new functionalities that invite
infection[.]

Because of these recent developments, historical experience, and the
inherent risks associated with lack of diversity, we ask that you
reconsider your heavy reliance upon a single, flawed software
platform to protect our national security. The latest round of worms
has shown in dramatic fashion the economic damage and danger to our
safety that can occur because of reliance on a single vendor who has
failed to demonstrate a core commitment to security. Our hope is
that you fully consider these critical concerns when implementing
security and information technology in the Department.

Sincerely,
Ed Black
President & CEO

Presidential Documents

Title 3--
The President

[[Page 53011]]

Proclamation 7701 of September 4, 2003

National Days of Prayer and Remembrance, 2003

By the President of the United States of America

A Proclamation

As we approach the second anniversary of September 11,
2001, we remember all that we lost as Americans and
recognize all that we have witnessed about the
character of America. During these National Days of
Prayer and Remembrance, we honor those who were killed
and their families, and we ask God for strength and
wisdom as we carry out the noble mission that our
Nation began that morning.

The passage of time cannot erase the pain and
devastation that were inflicted on our people. We will
always remember those who were brutally taken from us.
And we ask God to comfort the loved ones left behind;
their courage and determination have inspired our
Nation.

We thank God for the unity and compassion Americans
have demonstrated since September 11, 2001. The great
strength of America is the heart and soul of the
American people. And we will continue to help those who
are hurting or are in need.

We pray that God watch over our brave men and women in
uniform. We are grateful to them, and to their
families, for their service and sacrifice. We pray for
peace and ask God for patience and resolve in our war
against terror and evil.

This conflict was begun on the timing and terms of
others. It will end in a way, and at an hour, of our
choosing.

NOW, THEREFORE, I, GEORGE W. BUSH, President of the
United States of America, by virtue of the authority
vested in me by the Constitution and laws of the United
States, do hereby proclaim Friday, September 5, through
Sunday, September 7, 2003, as National Days of Prayer
and Remembrance. I ask that the people of the United
States and places of worship mark these National Days
of Prayer and Remembrance with memorial services, the
ringing of bells, and evening candlelight remembrance
vigils. I invite the people of the world to share in
these Days of Prayer and Remembrance.

IN WITNESS WHEREOF, I have hereunto set my hand this
fourth day of September, in the year of our Lord two
thousand three, and of the

[[Page 53012]]

Independence of the United States of America the two
hundred and twenty-eighth.

(Presidential Sig.)B

Commercializing the Mall

Friday, September 5, 2003; Page A20

The Post's Sept. 3 editorial expressing anguish over the crass commercialization of the Mall missed something fundamental about modern America.

Our core values no longer focus on family or community but on the marketing and consumption of products and services.

Instead of erecting affordable housing or inspiring public works, we build malls and sports complexes, the temples at which we can worship our capitalist gods such as Nike, Pepsi and Microsoft. Thus, converting the Mall into another consumerist spectacle represents more accurately what America has become.

We should applaud the National Park Service and the Department of the Interior for openly endorsing the new realities.

MICHAEL BRIAN SCHIFFER