Intolerance and the reinstatement of former native species, Oct 2018


I was contacted by David late in 2012 to tell me about the beavers that were living free in the Tay River catchment in Scotland, and which he said were under threat of removal by Scottish National Heritage (SNH) as their presence was considered to be unauthorised. David was shrewd enough to know he was dangling in front of me the opportunity for an article about these beaver. He put me on to Louise and Paul who were organising local opposition against the capture, their motivation coming from having experience of keeping beaver in an enclosure on their estate (1). They would shortly found the Scottish Wild Beavers Group (SWBG) as an action group to monitor beaver in the Tay catchment, and to lobby for their continued presence as an opportunity to study dispersal and impact (2). While official attention was mostly focussed on the authorised trial release of beaver in Knapdale, the repeated failure of SNH to capture and remove the Tay beavers, plus the cogent arguments being put forward by SWBG and their actions in exposing the low population count assumed by SNH, resulted in a decision by the Scottish Government that the Tay beavers would be left in place and monitored until the end of the Knapdale beaver trial in 2015 (2). A decision would then be made about the future re-introduction of beavers to Scotland as a whole.

We don’t encourage lethal control

The clamour for a cull of the Tay beavers grew more strident, a key issue of discussion being whether the free-living beaver would be covered by the strict protection afforded by the EU Habitats Directive and, even then, would there be an allowance under that Directive for managing beaver in circumstances where there were impacts on public health, public safety, or for other reasons of overriding public interest, including those of a social or economic nature (2). Some in the rural communities where beaver had distributed took no notice of any legal or moral imperative, blaming beaver for flooding, but cutting down all the trees and bushes along watercourses to deny beaver a foothold, and slaughtering beaver with impunity (3). The best an SNH manager could come up with in response to the evidence of this slaughter was “We don’t encourage lethal control”(4)

It took until November 2016 for the Scottish Government to make the momentous decision that the beavers in Scotland were there to stay and be allowed to expand their range naturally (5,6). While pointing out that this was the first time a mammal had been officially reintroduced to the UK, the overall tenor of the press release was about active management – “Species set to receive protection, but will require careful management” (6). This management, it explained, was by way of techniques up to and including lethal control that were available under the Habitats Regulations. It noted that work had begun to ensure beavers would be added to Scotland’s list of protected species, which required completion of a Habitats Regulations Assessment and a Strategic Environmental Assessment, and thus implying that protection under the Directive would be contingent on the two assessments. There was also a commitment from the Scottish Government that advice and assistance would be provided to farmers in helping them implement mitigation and prevention measures. Some interim advice on beaver management was provided almost a year later, and which stated that SNH "strongly discouraged lethal control" (7). However, the advice primarily covered highly interventionist measures like removing a lodge, blocking a burrow, and “humane dispatch”. Advice was provide for the latter on firearms and munitions, and offered this cynical wheeze that the tendency of beavers to “repair dams that have been breached makes the position of the beaver more predictable and allows for a stable firing position at an appropriate range”. Clearly, there would be no inhibition amongst rural communities to continue with their absolute intolerance of the presence of beaver, rather than learning to tolerate a certain amount of beaver influence on their land (3,8).

In late 2017, the Scottish Government announced that the two assessments had been carried out, but that it was to consult over a three-month period on whether the Environmental Report of the Strategic Environmental Assessment had correctly identified potential impacts and appropriate mitigation measures in the reintroduction of beavers to Scotland (9). A Government policy statement provided a summary of events to that point, and then laid out the final requirement of a Scottish Statutory Instrument that was needed to put in place protection for beavers by adding them to Schedule 2 of the Conservation (Natural Habitats, &c.) Regulations 1994 so that they became a European Protected Species (10). It noted that it would then be an offence to kill or injure any beaver, or deliberately disturb a beaver during breeding or rearing periods, and that the breeding and resting places of beavers would also be protected. There then followed something that should at least have been in place and widely publicised when the announcement was made of the acceptance of reinstatement of beaver, if not before. The Scottish Government called on land managers to exercise restraint in managing beavers until they were given fully protected status. Advice could be sought from SNH, but that land managers were to proceed as though legal protection was in place. However, if there was evidence that this advice was not being followed on a particular landholdings, there would be the option for a Scottish Ministers to issue Nature Conservation Orders. These Orders may prohibit specified activities in specified areas and at specified times, including it was suggested prohibiting the shooting of beavers (11). Breach of such an Order is a criminal offence with a fine of up to £40,000 under summary procedure and an unlimited fine on indictment (12). At last there would appear from then on to have been some force behind the weak imprecation not to cull these beaver (see above). However, these orders refer to activities only in designated protected areas (11) and, while the River Tay Special Area of Conservation may have covered most of the beaver colonies, it would be hard to use these orders to forestall culling those beaver that may have distributed outside of it (13). I see no evidence anyway that any Nature Conservation Orders had been issued in respect of beaver being killed (14-16).

Lethal control is a last resort when all other mitigation methods have been exhausted

Recognising that this was a really critical moment for beavers in Scotland, SWBG reminded all of its contacts in mid-February of the consultation, and its deadline in early March 2018, in an effort to bolster a high and positive response. To make responding to the five questions easier, a summary was provided of the answers that SWBG had given to the consultation (17). After reading those and the consultation documents provided, I submitted my response, but confined the detail of my comments to the question of whether the re-introduction policy and the Environmental Report had correctly identified the potential impacts and appropriate mitigation (18). It seemed to me that natural justice required that the de facto reinstatement of beaver to parts of its former native range in Scotland be given official recognition, and that their presence be legally protected (19). Given the distributive nature of wild animals, the policy was correct in accepting and allowing beaver to expand their range naturally. I was less happy about the wording in the Policy Statement that beavers should be actively managed to minimise adverse impacts on farmers and other land owners, and that the Scottish Government aimed to promote proactive management of beavers to mitigate negative impacts on land use activities (10). While an explanation was eventually given in the Policy Statement that many management actions could be carried out with no adverse effects on animal welfare, and without any need for a licence, the terms used of active/proactive management would always be associated with population control by lethal means, and which is never the intention of providing exceptions to strict protection.

I felt there also needed to be more clarity about what actions would need to licenced. The Policy Statement implied that actions that would otherwise be unlawful under the regulations (e.g. killing, trapping, destruction of dams or lodges) could be carried out under licence from SNH for specified purposes, including protection of crops, livestock, timber or public health (10). However, it noted that before a licence could be issued, the EU Habitats Directive required SNH to be satisfied that there was no satisfactory alternative to the requested intervention and that the action would not have a detrimental effect on the conservation status of the species. The Environmental Report was even less clear in distinguishing between what it called “generic” management and the licenced approaches to practical measures for mitigation, when only physical removal and exclusion were seen to require an SNH licence (Sections 5.3 & 5.4 in (18)). I noted that there claimed to have been development of a fit-for-purpose scheme of licensing appropriate derogations to enable legal management that can reduce or eliminate impacts from beaver activity, and that this would be available when legal protection is enacted (table 5.7.1 in (18)) The latter was also the case for when there would be guidance from SNH on appropriate techniques to manage for the presence of beavers, or eliminate or reduce unwanted impacts (table 5.7.1 in (18)). I felt it would have been much better if, in the first case, there had been some indication of the outline structure of the licensing scheme within the documents presented for the consultation. Moreover, it would have been important to stress again, as was noted in the Policy Statement, that under the rules for derogation in the Habitats Directive, lethal control is a last resort when all other mitigation methods have been exhausted.

There was an interesting and valuable exercise in the Environmental Report of assessing the benefits and risks of four alternative policy scenarios: full removal of beavers from the wild; allowing beavers to expand from their current range, but restricting movement into specific catchments to keep them free of beaver; widespread colonisation that could eventually include new release sites outside of the existing two; and accelerated colonisation where proposals for new releases could be considered immediately (Section 6.1 in (18)). I recommended a bold approach to a positive future for beaver in its natural range in Scotland through the choice of option 3, and which was one of the two options – 2 and 3 - that had informed the policy agreed by Scottish Minister. I think my reason for choosing option 3 rather than option 4 was to allow some time for a greater shakeout in attitudes to the existence of beaver; that tolerance might flourish with greater familiarity; and that land users would accept the public responsibility of having a protected species on their land.

A complete absence of fresh beaver signs

In the short run, that was a naïve expectation on my part, as SWBG were reported in a newspaper article in June 2018, a few months after the consultation ended, that it had “hard evidence” of “systematic shootings” of beaver in the local area; that farmers and landowners in Tayside had already started killing beavers on their land and neighbouring waterways (20). Disappointment was expressed by SWBG at the length of time it was taking in granting beavers legal protection; that the delay potentially exposed dependent kits to a slow death by starvation in their burrows if their lactating mothers were shot during another breeding season of April to September when female beavers may have dependent young. The Chairman of National Farmers Union (NFU) Scotland’s Environment and Land Use committee was quoted as saying that it was imperative that any beaver colony was properly managed so that its addition to the landscape did not negatively affect agricultural practices and land use. There is no nuance here, just a sense of entitlement, the implication being that farmers wanted to exercise population management, rather than the sliding scale of measures in mitigation that was the approach in the Environmental Report (Sections 5.3 & 5.4 in (18)). Cabinet Secretary Roseanna Cunningham, MSP for Perthshire South and Kinross-shire, confirmed that measures would be put in place to safeguard the growing population of beavers later this year, and that a survey on changes to the distribution and density of the wild beaver population in Scotland between 2012 and 2018 would be published by SNH also later this year. The article offered that it was thought that as many as 100 beaver were now living in Tayside.

Within a week of each other in mid-October, two reports came out on Scottish beaver, the first being that report on a survey of the change in beaver distribution and population, although Cunningham had been misleading in that it was focussed solely on beavers originating in the Tay catchment (21) and the second was an analysis of responses to the consultation on the Environmental Report (22). The survey report noted that a previous survey conducted in 2012 had estimated there were 38-39 groups of beavers present in the Tay catchment, equating to approximately 146 individual beavers (range 106 - 187)(21). The newspaper article (above) must have been working on those figures from 2012 when it said that as many as 100 beaver were now living in Tayside, because this new survey identified that there were 114 active beaver territorial zones, giving a conservatively estimated number of approximately 433 beavers (range 319 – 547). This is a stunning increase in both beaver distribution and density compared to the 2012 survey, and with evidence that beavers were spreading beyond the Tay catchment and into the Forth catchment from Loch Achray in the Trossachs, parts of River Teith and Devon, to the main stem of Forth River near Stirling (see Fig. 13b & Fig. 15b in (21)). However, there was disturbing evidence of a spatial variability in terms of areas of change, as indicated by around ten areas that exhibited a decreased field sign density compared to the 2012 survey, and in some cases a complete absence of fresh beaver signs indicating that beaver were no longer present (see Fig. 14 in (21)). These negative changes in densities of signs were in parts of the lower River Earn and River Isla, and which are associated with prime agricultural land-use. The survey reports authors ventured that these areas of seeming habitat abandonment were potentially the result of culling – “culling in some areas has undoubtedly removed animals and therefore created vacant territories” (21). They noted that such activity had prevented the carrying capacity for beaver being reached so that there was no population dynamic that would cause a burgeoning young population to redistribute into new territories. Instead, a response to this culling could lead to beaver changing their reproductive patterns through breeding as yearlings rather than as two-year olds.

As you may expect, this disturbing potential evidence of slaughter did not go unnoticed. Susan Davies, director of conservation at the Scottish Wildlife Trust, said in a BBC News article - "It is alarming that there are a number of areas where beavers are absent due to unregulated culls. We believe it is time for the Scottish government to complete the steps required to give beavers protected status. This was promised at the end of 2016 but progress has been too slow. Granting legal protection would ensure that beavers are allowed to thrive across Scotland" (23). Davies was to make other important points elsewhere – “Until such time that beavers receive protected status in Scotland this unregulated culling will continue to limit the return of beavers and leads to some concerns for animal welfare. Unfortunately progress in protecting beavers has been too slow and has not matched the pace of their expanding range and numbers” (24). You can get an idea of the slippage by the expectation given in the first (and only?) Scottish Beaver Form newsletter that beavers would become a European Protected Species in Scotland in 2017 (25). Given instead this glacial pace of progress, I wonder if there is some feet dragging by the Scottish Government because the imminent withdrawal of the UK from the EU throws into confusion whether it is worth proceeding with European Protected Species status? It begs the question though of what will be the replacement in legislative protection for wild species.

Davies offered some practical insight into measures for mitigation of beaver activity. She suggested that farmers, foresters and other land managers could prepare for the return of beaver by re-establishing or improving narrow strips of woodland habitat about 20m wide along rivers – “These riparian strips would create a buffer between the beavers preferred habitat and their land management activities. Steps can also be taken to protect essential trees, crops or infrastructure. Forward thinking land managers could also consider allowing small areas of land to be given over to beaver wetland habitats that will in turn encourage a wide range of biodiversity” (24). I noted above that there had been a commitment in the Environmental report that there would be guidance from SNH on appropriate techniques to manage for the presence of beavers, or eliminate or reduce unwanted impacts. That this has still not seen the light of day is evident from the BBC News article where Nick Halfhide, SNH director of sustainable growth, is quoted as saying (yet again) that SNH would be setting up a scheme to support farmers who are said to be angered by the damage beavers were causing (23). This mitigation scheme would be based on input from a range of interest groups such as NFU Scotland through the Scottish Beaver Forum, with trial techniques being developed to help farmers deal with any problems they encounter.

The majority of respondents (83%) agreed with the reintroduction policy

That second report in October, on an analysis of the consultation responses, reported that 533 had been received, most being from individuals (494) as well as key stakeholder organisations (39)(22). The majority of respondents (83%) agreed with the reintroduction policy that beaver populations in Scotland should be allowed to remain, that they should receive strong legal protection and were content that appropriate mitigation measures had been identified. The main concern among those who disagreed with the reintroduction policy was whether there would be long-term funding and a management framework for the mitigation measures to support farmers and land managers prevent serious damage to land uses (agriculture, forestry & fisheries). Farmers and land managers also thought that the impacts of the reintroduction policy had been underestimated within the report and that the arable land in Tayside would be considerably affected by potential drain blocking and flooding caused by beavers. A number of respondents noted that there were no longer any natural predators in Scotland so that there would be some circumstances when beaver management will be required. In a question that I didn’t respond to, on whether there were any other environmental effects that had not been considered, 87 out of the 332 respondents to this question thought that the creation of riparian buffer zones with beaver wetlands could provide a critical solution for the reduction of agricultural run-off in intensely farmed areas.

I see no response yet from either the Scottish Government, or from farming sector organisations like NFU Scotland, to the analyses of responses to the consultation, although it is still early days yet after its publication. One thing I hadn’t considered when I originally responded to this consultation was that it did not necessarily seek to delineate respondents by some stakeholder assignment, such as farmer, land owner, land manager, a geographic association with the Tay catchment, or any other affiliation that would separate the ordinary citizen like me from those that would have direct experience of the impact of the beaver. As it was, while the consultation did ask whether the response was from an organisation or an individual, the analysis of responses made little effort to separate out different stakeholders. NFU Scotland has a track record of resisting legitimising the reintroduction of beavers in Tayside (26) and then arguing for appropriate (robust) management to minimise the risk of unacceptable impacts on agriculture and other land uses once it was decided that the Tay beavers were there to stay (27). Given that, you would have thought that NFU Scotland would have seized on the notion that the outcome of the consultation was flawed as it is likely that an overwhelming proportion of respondents didn’t have direct experience of beaver impact, nor that they would have to deal with it.

Respondents are asked to assess chilling statements

I have written before about the privileged opportunity for consultation that NFU members had in response to the trial (re-)release of beavers into the River Otter in Devon (28). I was forwarded very recently a webpage from Farmers Weekly that had a link to an astonishing questionnaire on lynx reintroduction in Britain. I can’t find this webpage on the Farmers Weekly website, and so I think it came by way of a subscriber’s webpage, but I have since found a link to the survey on a dedicated Facebook page (29). The survey is the usual strength of agreement/disagreement with a set of statements, but it has a major assumption that it is primarily farmers responding –“The aim of this study is to survey the views of UK farmers on a potential reintroduction of Lynx to the UK” (30). It opens with these contrasting, coupled statements:

‘I have positive feelings towards a potential reintroduction of Lynx to the UK’

‘Having Lynx in the UK would be a bad thing’

‘It is important for future generations to have Lynx in the UK’

‘The UK's natural environment would benefit from the presence of lynx’

‘Lynx would harm the UK’s farming community’

‘I would be afraid of walking in the countryside if Lynx were present’

‘I am knowledgeable about Lynx’

The second section of statements is prefaced on an assumption that I have never heard or seen articulated in any official arena. Thus it says that “To conserve the reintroduced Lynx, the species would be listed as a game species, with an open hunting season (an annual period when restrictions on the culling of certain types of wildlife are lifted)”. This is certainly not the case for lynx under the strict protection that would be afforded by the EU Habitats Directive, in the same way that it is for beaver (Articles 3 &13, Annexes II & IV in (31)). Respondents are then asked to assess the following, chilling statements, imagining that this hypothetical scenario of lynx reintroduction had occurred in the UK. Note the differentiation between farming and non-farming community:

‘If Lynx were present in my area, they would kill my farm animals’

‘If Lynx were killing my farm animals, culling Lynx would be an effective way of protecting my farm animals’

‘In the scenario mentioned earlier, protecting my farm animals from Lynx would be a high priority compared with other jobs on my farm’

‘Culling Lynx would be beneficial for my farm’

‘In this scenario, my local farming community would approve of me culling Lynx’

Behaving how my local farming community expects me to is important to me’

‘In this scenario, my local non-farming community would approve of me culling Lynx’

‘Behaving how my local non-farming community expects me to is important to me’

‘In this scenario, I would feel under social pressure to cull Lynx’

‘I have access to a gun’

‘Having access to a gun would enable me to cull Lynx’

‘I have access to poison’

'Having access to poison would enable me to cull Lynx’

‘I have access to traps’

‘Having access to traps would enable me to cull Lynx’

‘I am confident that I could successfully cull Lynx if I wanted to’

‘In this scenario I would cull Lynx’

I would be interested in what reaction you may have to this ever articulated right, this entitlement that rural communities assert over population control of inconvenient species? Can there ever be a legitimate exception to strict protection that will always satisfy rural communities in Britain? Will farmers and land users ever understand that the reason behind strict protection is to allow reinstated or existing endangered species to reach what is termed Favourable Conservation Status, indicating that they are occupying their natural range and in numbers that ensures long term survival (see Article 1.e in (31)).

The auguries above are not good, and are reinforced by a recent report from Finland that analysed the wolf hunting permits granted during the years 2016–2017 by the Finnish Wildlife Agency that were allowed as exceptions (derogations) from strict protection (32). The licenced mitigation activity of killing beaver would be the same thing (see above). The report wanted to establish if all plausible non-lethal alternatives were being effectively considered and implemented by the Finnish authorities before hunting permits were granted. The short answer is that the effort to seek alternative methods had been weak, especially so in the willingness to approve alternatives to mitigate social harm such as fear. The latter was one of the main reasons for applying for a wolf hunting permit in Southern Finland, each permit seeking the killing of one or two wolves. Don’t you think it odd that a fear of wolves is legitimising their culling, even though the report noted that no person had been killed by wolves for over a century in Finland? The report also noted that the Finnish wolf population had not yet reached favourable conservation status, which argued that exceptions from protection should not lightly be approved. It also raised the issue of poaching (illegal hunting) of wolves. It was considered that the ministerial decree on hunting had intimated that legitimation of culling through exceptions would result in greater social acceptance and less illegal hunting. The authors asserted that it was questionable whether the status of the wolf in Finland was improved by this liberalising of derogation-based hunting – “tolerance hunting” - when the opposite may well be true, as there was evidence that granting management flexibility for endangered species to address the illegal behaviour of poaching may promote such behaviour and lead instead to increased illegal hunting.

A solution that is independent of licencing

Given that some land users in Scotland have been slaughtering out beaver with impunity, irrespective of the repeated weak inculcations from SNH not to do so, will they go through the rigours of applying for a licence once beaver are strictly protected, when it is highly likely that the circumstances they cite in justification wouldn’t meet the criteria? Would a certain liberalisation of licence granting assuage these people that they had some control over beaver populations? What will be the replacement in legislative protection after the UK leaves the EU?

Here’s a solution that is independent of licencing. Unlike farmers, wolves don’t need a licence to go hunting beaver - a recent review of predation of beavers by wolves observed that during the ice-free season, beavers were vulnerable to predation and can be the primary or secondary prey of wolves (33). Higher beaver abundance can increase wolf pup survival, as well as being a substitute prey for wolves during periods of reduced ungulate abundance. The reinstatement of wolves to free living here will, of course, plunge us straight back into the issue of tolerance, and you can imagine the outcry of farmers in needing to feel that they can control the wolf population. Would there be greater tolerance of the presence of wolves if farmers were allowed to trap and shoot them? If there is a will to reinstate former native species, as there was with the beaver, then what has happened with the Tayside beavers shows that we just aren’t sufficiently ready as an island to accept other free living and ranging former native species. We never will be if our system of authorising releases for reinstatement by statutory agencies are reactive to piecemeal applications, rather than being proactive their selves in taking a national view that assumes responsibility for the preparedness in accepting those reinstatements.

Mark Fisher 31 October 2018

(1) The Tayside beavers - living wild and free in Scotland, Self-willed land December 2012

(2) Tay beavers to stay free and living wild, Self-willed land May 2012

(3) Big areas for ecological restoration, Self-willed land December 2015

(4) DAMBUSTERS: 21 Bavarian beavers shot dead in Scotland, Joe Stenson Deadline News 25 November 2015

(5) A clear view of the landscape, Self-willed land December 2016

(6) Beavers to remain in Scotland, Scottish Government news 24 November 2016

(7) Interim Beaver Management Advice, SCottish Natural Heritage October 2017

(8) Breaking the pattern, Self-willed land October 2016

(9) A Consultation on the Beavers in Scotland Strategic Environmental Assessment Environmental Report, Scottish Government 12 December 2017

(10) Beavers in Scotland, Scottish Government Policy Statement

(11) Nature conservation orders, Section 23, Nature Conservation (Scotland) Act 2004

(12) Offences in relation to nature conservation orders, Section 27, Nature Conservation (Scotland) Act 2004

(13) River Tay Special Area of Conservation, Joint Nature Conservation Committee

(14) Nature conservation order, Scottish Natural Heritage

(15) Annual Report and Accounts 2015/16, Scottish Natural Heritage

(16) Annual Report and Accounts 2016/17, Scottish Natural Heritage

(17) Scottish Government – Public consultation on beavers, Scottish Wild Beaver Group February 13, 2018

(18) Beavers in Scotland. Strategic Environmental Assessment Environmental Report, Scottish Government May 2017

(19) Response 962479880 - Dr Mark Fisher. A Consultation on the Beavers in Scotland Strategic Environmental Assessment Environmental Report, Scottish Government

(20) Calls for urgent protection of Tayside beavers amid reports of ‘systematic shootings’, Jamie Buchan, The Courier 6 June 2018

(21) Campbell-Palmer, R., Puttock, A., Graham, H., Wilson, K., Schwab, G., Gaywood, M.J. & Brazier, R.E. 2018. Survey of the Tayside area beaver population 2017-2018. Scottish Natural Heritage Commissioned Report No. 1013

(22) Report on the Consultation of the Beavers in Scotland – Strategic Environment Assessment Environmental Report Analysis of Responses June 2018. Scottish Government October 2018

(23) Rising beaver numbers in Tayside worry farmers, BBC News Tayside and Central Scotland 12 October 2018

(24) Scotland’s beavers need protection to allow them to thrive, Susan Davies, Scottish Wildlife Trust Blog 12 October 2018

(25) Beavers in Scotland: Scottish Beaver Forum Newsletter, August 2017 An Update. August 2017

(26) Union Reiterates Opposition to Reintroduction of Beavers on Tayside Following SNH Report. NFU Scotland News Article No.: 77/15, 29/04/2015

(27) Robust Management of Beaver Population Essential.  NFU Scotland News Article No.: 256/16, 24/11/2016

(28) Lynx UK Trust lets the cat out of the bag, April 2015

(29) UK Farmers Lynx Survey, Facebook 21 October 2018

(30) A Consultation of UK Farmers on the Reintroduction of Lynx to the UK

(31) COUNCIL DIRECTIVE 92 /43 /EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora

(32) KEEPING THE WOLF FROM THE DOOR: Analysis of derogation-based wolf hunting permits in Finland, Luonto-Liiton susiryhmä / The Wolf Action Group, 2018

(33) Gable, T. D., Windels, S. K., Romanski, M. C., & Rosell, F. (2018). The forgotten prey of an iconic predator: a review of interactions between grey wolves Canis lupus and beavers Castor spp. Mammal Review, 48(2), 123-138.