A Jewish priestess may, according to Kohenet, act as a rabbi, but the two roles are not the same. In 2006, the Committee on Jewish Law and Standards of Conservative Judaism adopted three responsa on the subject of niddah, which reaffirmed an obligation of Conservative women to abstain from sexual relations during and following menstruation and to immerse in a mikvah prior to resumption, while liberalizing observance requirements including shortening the length of the niddah period, lifting restrictions on non-sexual contact during niddah, and reducing the circumstances under which spotting and similar conditions would mandate abstinence. Also in 2006, Susan Wehle became the first American female cantor ordained in Jewish Renewal; however she died in 2009. In June 2009, Avi Weiss ordained Sara Hurwitz with the title "maharat" (an acronym of "manhiga hilkhatit rukhanit Toranit") rather than "Rabbi". In February 2010, Weiss announced that he was changing "maharat" to a more familiar-sounding title "rabba". The goal of this shift was to clarify Hurwitz's position as a full member of the Hebrew Institute of Riverdale rabbinic staff. The change was criticised by both Agudath Yisrael and the Rabbinical Council of America, who called the move "beyond the pale of Orthodox Judaism". Weiss announced amidst criticism that the term "Rabba" would not be used anymore for his future students. Hurwitz will continue to use the title Rabba and is considered by some to be the first female Orthodox rabbi. However Weiss said other graduates of Yeshivat Maharat, which he founded, would not receive the "rabba" title, but the "maharat" smicha. But in 2015 Yaffa Epstein was ordained as Rabba by the Yeshivat Maharat. Also in 2015, Lila Kagedan was ordained as Rabbi by that same organization, making her their first graduate to take the title Rabbi. Also in 2009 Tannoz Bahremand Foruzanfar, who was born in Iran, became the first Persian woman to be ordained as a cantor in the United States. Also in 2009, Alysa Stanton became the first African-American woman ordained as a rabbi. In 2010 the first American women to be ordained as cantors in Jewish Renewal after Susan Wehle's ordination, Michal Rubin and Abbe Lyons, were both ordained.