Science and the Endangered Species Act

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This page was last updated in October 2022. The Endangered Species Act requires that listing decisions be based on "the best scientific and commercial data available."

Once a species is listed as endangered or threatened, the U.S. Fish and Wildlife Service imposes regulations to protect those species. These regulations may include a prohibition against taking listed species, which directly affects private property use and restrictions on federally permitted or funded actions. Because of the social, environmental, and economic effects of Endangered Species Act decisions, the adequacy of the science supporting Endangered Species Act decisions is frequently debated.

HIGHLIGHTS

While scientific information helps gauge whether a species' chance of survival is at risk, policy tries to determine whether conservation is a worthwhile goal and what conservation measures may be appropriate in light of their costs and trade-offs.

There are challenges with the use of scientific data that can make the decision to list or delist a species difficult. Sometimes the available data are not extensive, the time and costs of acquiring more data are high, or the particular status of a species' whereabouts or threats to its survival are not well-known.

Other challenges associated with the use of science in Endangered Species Act decisions include alleged political interference with scientific data, the use of flawed scientific opinions, the disputed taxonomy of certain species to be listed, and the public availability of data.

Background

The National Academy of Sciences defines science as "a particular way of knowing about the world. In science, explanations are limited to those based on observations and experiments that can be substantiated by other scientists. Explanations that cannot be based on empirical evidence are not a part of science."

Under the Endangered Species Act, the federal government must list species as endangered or threatened based on "the best scientific and commercial data available" at the time the government makes the decision. The scientific basis of Endangered Species Act decisions is important because the act gives strong legal tools to the federal government for the protection of listed species, including regulations on land use and federally authorized projects. Science must also identify which species are in need of federal protection and how severe the threats to a species are.

How science is used in the ESA

Scientific data is used to list species, to consult on federally permitted projects, to designate critical habitat for listed species, and to develop recovery plans. Federal scientists can use informal information, such as oral or anecdotal information, as well as peer-reviewed scientific studies, as long as the information represents "the best scientific and commercial data available." At various points, business groups, environmental organizations, property rights groups, and other interests have criticized the scientific basis of certain Endangered Species Act decisions. The reasons for the criticism vary depending on the political agenda of these groups.

Biologists and researchers decide whether a species is endangered or threatened based on any of the following factors:

“	the present or threatened destruction, modification, or curtailment of its habitat or range; overutilization for commercial, recreational, scientific, or educational purposes; disease or predation; the inadequacy of existing regulatory mechanisms; other natural or manmade factors affecting its survival.	”
—U.S. Fish and Wildlife Service

Federal endangered species scientists work with staff from other federal agencies, state natural resource departments, academia, conservation groups, and other private groups to identify which species could be listed. If the U.S. Fish and Wildlife Service receives a petition to list a species, the agency often requests scientific information to supplement its own data. Fish and Wildlife Service field offices partner with state and local scientists to conduct surveys determining the presence and distribution of a species within a certain area.

Once a species is listed as endangered, the U.S. Fish and Wildlife Service must apply the full protections of the Endangered Species Act. These protections include the prohibition of taking a listed species. To "take" a species means "to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct." Since the 1990s, the service has expanded the definition of "taking" a species to include "significant habitat modification or degradation that actually kills or injures wildlife." The Fish and Wildlife Service has discretion only in regulating the taking of threatened species and in designating critical habitat.

Critics of the law's implementation have argued that the Fish and Wildlife Service should be granted more discretion to apply different kinds of protection on a per-species basis. The listing process would remain unchanged, and the service would decide which species should receive certain protections. Proponents of this view have argued that the science supporting the listing of a species would become less politicized because the listing would no longer involve the Endangered Species Act's full regulatory controls. Those who support listing a species in order to implement strong regulatory controls would have less of an incentive to support listing the species if the full regulatory controls are not guaranteed. Instead, the decision to list a species would include not solely scientific concerns but economic and social concerns. Proponents of this view have argued that the Endangered Species Act as originally written cannot guarantee a completely scientific approach to listing species because such an approach must necessarily include economic, social, and other non-scientific factors. Further, these proponents argue that the listing process should reflect those non-scientific factors.

Science and policy

Science and policy are distinct but often intertwined. In the context of the Endangered Species Act's implementation, scientists offer a hypothesis about the future of a species and its environment, while policymakers decide whether to dedicate resources to protect that species. While scientific information helps gauge whether a species' chance of survival is at risk, policy tries to determine whether conservation is a worthwhile goal and what conservation measures may be appropriate in light of their costs and trade-offs. Policy decisions reflect the differing political, economic, scientific, and environmental views and goals of scientists and policymakers, while scientific information is supported by empirical facts and repeatable observation.

The Endangered Species Act mandates that the decision to list a species be based solely on scientific information. As a result, the U.S. Fish and Wildlife Service does not have discretion in determining the protections for endangered species if the best scientific data support the listing of that species. The service does have discretion in considering economic and social effects in the designation of critical habitat. When a species is federally listed, property use and federally permitted activities are regulated to avoid causing harm to a listed species. Consequently, science and its effect on policy decisions can affect private individuals and groups.

Scientific challenges

Challenges associated with scientific data can make the decision to list or delist a species difficult. Sometimes the available scientific data are not extensive or the time and costs of acquiring more data are high. Some endangered species are difficult to locate, and thus little data exist about them or few sufficient experts can provide peer reviews. Additionally, the impartiality of scientists can be questioned if economic factors are involved. For example, research funding or employment could influence a decision to list a species.

Below are some of the common scientific challenges associated with endangered species policy:

• The distribution of a species is sometimes poorly known because the species is rare. Moreover, time and resources may not be available to engage in surveys or monitor a species.
• A subspecies' taxonomic status is a disputable issue. Taxonomy refers to the classification of species, and the biological distinction between "subspecies," which is a classification included within the Endangered Species Act's definition of species, is strongly debated among scientists because the category of subspecies is often subjective. As a result, the debate has centered on how to classify subspecies based on different categories, such as geography or genetic differentiation.
• Some species may reappear on their own in an area they once occupied, raising questions about whether land use restrictions should apply in that area.
• Political and other non-scientific factors influence listing decisions in addition to the scientific data.
• Landowners have an incentive to keep scientists from conducting research on their private land out of concern that property regulations would ensue if a rare animal or plant species was found. According to a 2003 study from the journal Conservation Biology, many landowners refused to allow scientists onto their land to research a rare mouse population out of concern that property restrictions would result if a mouse were found.

Major issues

The science behind Endangered Species Act decisions—including the prohibition on taking listed species and the restrictions on federally permitted or funded activities and projects—can affect individuals. Science is used to support the protection of species that may be vulnerable to decline or extinction. Below are some of the major issues associated with the use of science in Endangered Species Act decisions. These examples cover alleged political interference with scientific data, the use of flawed scientific opinions, disputed taxonomic classification of species, and the public availability of scientific data.

Alleged political interference with scientific data

A U.S. Fish and Wildlife Service official under George W. Bush opposed listing the Sacramento splittail fish as threatened on scientific grounds in 2003, a decision that was criticized as political by an environmental group but was supported by scientists in the Obama administration.

Charges of political interference with scientific data emerged during the George W. Bush administration. The deputy assistant secretary for Fish and Wildlife and Parks was criticized for interfering with critical habitat designations for listed species for non-scientific reasons. The environmental group Center for Biological Diversity accused the official—Julie MacDonald—of overruling the opinions of scientists at the U.S. Fish and Wildlife Service. Specifically, MacDonald was critical of designating critical habitat for listed species. Critical habitats are specific geographic areas, whether occupied by listed species or not, that are determined to be essential for the conservation and management of listed species.

The standards for critical habitat designation for occupied and unoccupied habitat are different under the Endangered Species Act. The standard for designating occupied habitat requires designating areas that contain the physical and biological features essential to the species' conservation. The standard for designating unoccupied habitat requires that the area itself be considered essential to the species' conservation. The standard for designating unoccupied critical habitat is considered more demanding than the standard for occupied habitat. Critics of the designation process, such as MacDonald, have argued that the U.S. Fish and Wildlife Service has often taken more broader, less scientifically rigorous approach to designating unoccupied critical habitat that ignores the economic impact of the designations. Property rights groups have argued that the designation process should be more rigorous in basing certain designations on adequate scientific data, while environmental groups have argued that the designation process does not go far enough in establishing critical habitats for the protection of species. Meanwhile, the Union of Concerned Scientists, a nonprofit political advocacy organization, said MacDonald's activities represented "specific instances where endangered species data has been compromised," while certain staff complained that their scientific conclusions were "overruled or disparaged" by MacDonald. In March 2007, the inspector general of the Interior Department found that MacDonald broke federal rules by leaking non-public federal information about endangered species to private nonprofit groups, such as the California Farm Bureau Federation and the Pacific Legal Foundation.

In 2009, the Center for Biological Diversity formally apologized to MacDonald as part of a settlement of a defamation suit that MacDonald filed. The group accused MacDonald of being personally responsible for what it considered an "illegal" decision in 2003 to remove the Sacramento splittail fish from the list of threatened species during the Bush administration. MacDonald and scientists argued that the best scientific information available did not support listing the fish as threatened. The U.S. Fish and Wildlife Service under the Obama administration agreed with MacDonald and scientists in 2010 that the fish did not warrant Endangered Species Act protection and removed the fish from the federal list. The center posted an apology on its website in which executive director Kieran Suckling said that the center "retracts and apologizes for any statements ... that you alone were personally responsible for what CBD asserts was the government's illegal splittail decision." According to Suckling, the center's comments "were not intended to impugn" MacDonald's character.

Adoption of flawed scientific opinions

The Upper Klamath Lake in Oregon is an important water resource for agriculture, commercial fishing, and endangered species management. In 2001, scientific decisions about water use for federally protected fish species led to water cuts for nearby farms.

The federal government may rely on scientific opinions that are later determined to be flawed. Erroneous scientific opinions can also result in restrictions on private individuals and local land use, resulting in economic costs for residents. In 2001, the U.S. Fish and Wildlife Service recommended higher water levels in the Klamath River Basin, a region along the California-Oregon border, to protect federally-listed fish species. As a result, not enough water was available to irrigate the region's farms, and water users estimated that the surrounding economy would lose between $106.7 million and $222 million for the 2001 crop year from water cuts. A May 2001 study from Oregon State University's Agricultural and Resource Economics Department found that water restrictions would reduce personal income in the Klamath area by $70 million and reduce total gross sales in the area by $157 million in 2001 alone. Klamath Basin farmers argued that the irrigation water cuts benefiting the species "were not scientifically justifiable." The U.S. Secretary of the Interior recruited the National Research Council (NRC), a part of the U.S. National Academy of Sciences, to review the science.

The NRC found that there was no sound scientific basis to keep more lake water for the listed species. Specifically, the NRC did not find a link between low lake levels and fish mortality. Moreover, although more water might have benefited the fish, there was no evidence that more lake water would have helped the federally listed species recover faster. Although the Endangered Species Act requires agencies to use the "best scientific data available" to avoid jeopardizing listed species, the scientific reports were written without extensive monitoring or scientific experimentation to justify them, according to the Congressional Research Service.

Disputed taxonomy

Taxonomy refers to the classification of species, and the biological distinction between "subspecies," which is a classification included within the Endangered Species Act's definition of species, is strongly debated among scientists because the category of subspecies is typically subjective. As a result, the debate has centered on how to classify subspecies based on different categories, such as geography or genetic differentiation. Some of the federal government's taxonomic status of subspecies have been criticized as arbitrary or based on debatable science—the coastal California gnatcatcher and the gray wolf, for example.

California gnatcatcher

The coastal California gnatcatcher case demonstrates that the U.S. Fish and Wildlife Service sometimes does not reverse its listing decisions even if new scientific information related to the taxonomic classification of certain subspecies supports delisting the species. The U.S. Fish and Wildlife Service listed the coastal California gnatcatcher in 1993 as a threatened species. Since then, the service has received petitions to delist the species due to emerging scientific evidence showing that the gnatcatcher was the same bird as the gnatcatcher found in Baja California, Mexico. A scientist at the University of Minnesota performed a nuclear DNA analysis showing the similarity between the birds. As a result, the petition stated that the Fish and Wildlife Service erred in classifying the coastal California gnatcatcher as a subspecies since the millions of gnatcatchers inhabiting Baja California demonstrated that the gnatcatcher did not warrant protection under the Endangered Species Act. The petition also cited the U.S. Fish and Wildlife Service's estimate that the listing of the gnatcatcher had approximately $1 billion in negative economic impacts affecting private landowners and individuals. In December 2014, the service announced that the petition to delist the coastal California gnatcatcher contained substantial scientific information suggesting that the bird should be delisted. As of November 2016, the species remained listed as a threatened species.

Gray wolf

The proposed delisting of the gray wolf in 2013 was criticized for being based on debatable scientific conclusions. In June 2013, the U.S. Fish and Wildlife Service proposed removing gray wolves from the federal list based on the scientific conclusions of an October 2012 paper called "An Account of the Taxonomy of North American Wolves From Morphological and Genetic Analyses." The paper, which was published in the service's official journal, North American Fauna, concluded that populations of wolves in eastern North America were a distinct species from the gray wolf species found in western North America. In the paper Fish and Wildlife Service biologists states that if the eastern wolves could not be classified as gray wolves, then the gray wolves were closer to recovery than previously expected, and thus could be proposed for delisting. If the eastern wolves were similar to gray wolves, then the question of whether the gray wolf species had recovered remained open.

A February 2014 National Center for Ecological Analysis and Synthesis independent report challenged the Fish and Wildlife Service's scientific conclusion that eastern wolves were distinct from western gray wolves. They argued that wildlife biologists did not agree on the Fish and Wildlife Service's conclusion. Responding to these challenges, the Fish and Wildlife Service reopened the public comment process on its gray wolf delisting proposal in February 2014. Fish and Wildlife Service director Dan Ashe said, "We are incorporating the peer review report into the public record for the proposed rulemaking, and accordingly, reopening the public comment period to provide the public with the opportunity for input." The Center for Biological Diversity, which opposed the gray wolf's proposed delisting in 2013, endorsed the conclusions of the February 2014 independent report: "The nation's top wolf scientists today confirmed what we and millions of Americans have been saying for months: The job of wolf recovery is far from complete. ... This peer review is a major blow to the Obama administration's highly political effort to prematurely remove protections for wolves."

Public availability of data

See also: Transparency and the Endangered Species Act

Federal guidelines do not require the public release of the raw scientific data used in Endangered Species Act decisions. The studies that are publicly available usually contain summaries of the scientific data, and the federal government is not required to release the raw data. Supporters of these guidelines argue that raw data should be handled only by relevant experts to discourage misuse or political interference. Supporters also argue that making some data publicly available would reveal the location of vulnerable species and encourage poaching or habitat destruction. Critics argue that these guidelines allow policy decisions to be made without an independent or critical analysis of all the data.

According to a former science advisor to the U.S. Department of the Interior, if other scientists cannot test the scientific data or if other scientists cannot reproduce the scientific results, then the public cannot know whether policy decisions are based on well-tested scientific information or based solely on the opinions of a few scientists. An opinion may or may not pass more rigorous scientific review.

Supporters of current policy argue that requiring the publication of raw data would increase the Fish and Wildlife Service's unfunded liabilities or allow those who are not experts in the relevant fields to misuse the data. The data may also contain the location of some endangered species, making them vulnerable to collecting or poaching. Supporters also argue that scientists may be less likely to contribute their research to the federal government if their unpublished data or any data that have not been peer-reviewed were released publicly.

Critics, including a former science advisor to the U.S. Department of the Interior, argued that the public release of data would be "neither difficult, nor costly." Critics have said the Fish and Wildlife Service could archive data in online, library, and/or museum databases before the data are used to support policy decisions. As a result, critics say, peer reviewers would then have greater access to data, which would encourage more scientific debate. Additionally, to prevent the threat of poaching, critics propose that narrow exceptions could be made to protect more vulnerable species while keeping the majority of scientific data publicly available. In 2014, Rep. Doc Hastings (R) introduced the Endangered Species Transparency and Reasonableness Act in Congress. The bill would require the Fish and Wildlife Service to publicize the underlying data of a listing.

Global warming and climate change

The National Marine Fisheries Service listed the bearded seal as threatened, citing climate models indicating a substantial decline in the species by the year 2095, a decision that was considered by some critics as based on speculation and not hard scientific data.

Some environmental activists have argued that listing a species as endangered or threatened should take into account the potential future effects of human-caused emissions of carbon dioxide. These effects would take place decades in the future, and thus there is strong scientific debate over the appropriateness of listing species based on these potential effects. In 2008, the U.S. Fish and Wildlife Service listed the polar bear as threatened based on climate change and population models suggesting the species' future decline caused by melting sea ice. This decision, the first time a listing was based on the effects of global warming, came despite the bear's 2008 population, which totaled 25,000 bears, which was the highest number in recorded history at the time. Critics of the decision argued that the listing effectively changed the Endangered Species Act to allow for any species with a habitat at risk to be listed without scientific evidence showing that the species is in decline.

In October 2016, the United States Court of Appeals for the Ninth Circuit upheld a decision by the National Marine Fisheries Service to list a population of bearded seals. The decision cited computer climate models from the United Nations' Intergovernmental Panel on Climate Change predicting that the seal would decline substantially before the year 2095 due to reduced sea ice. The court found that the federal agency "need not wait until a species’ habitat is destroyed to determine that habitat loss may facilitate extinction." The ruling reversed a district court in Alaska, which ruled that the agency relied on conjecture and speculation to list the species. Some environmental groups supported the ruling, arguing that the ruling should spur the listing of other species, such as salmon and other fish potentially affected by droughts or warming rivers. Further, these groups argued that federal scientists should consider climate models and other predictions of potential species decline when listing a species. Property rights and business groups opposed the ruling, arguing that the decision sets a precedent for listing species despite little to no evidence that the species are currently threatened or endangered. Further, these groups argued that the decisions would be used to limit economic activity, such as logging and mining, despite no present threats to a species.

Critical habitat

A U.S. circuit court upheld the U.S. Fish and Wildlife Service's decision to regulate unoccupied areas of land as critical habitat for the dusky gopher frog.

Decisions regarding the designation of critical habitat, which are specific geographic areas that are determined to be essential for the conservation and management of listed species, are frequently debated on scientific grounds. For example, the U.S. Fish and Wildlife Service designated 1,554 acres of private timber land in Louisiana in 2012 for the dusky gopher frog, an amphibian found in the southern United States. The service argued that it could regulate the land until it became usable and accessible for the frog's conservation. Critics of the decision argued that the land did not contain the physical and biological characteristics needed for the frog's survival as required by the Endangered Species Act. Further, the designation was estimated to cost private landowners approximately $33.9 million in lost profit from potential timber production. The designation was challenged in the United States Court of Appeals for the 5th Circuit, which ruled in favor of the Fish and Wildlife Service by a two-to-one vote. The court majority agreed with the service's determination that the agency can designate areas as critical habitat even if the areas do not qualify as critical habitat, would not serve as critical habitat in the future, and are unoccupied by the species. By contrast, the dissenting judge, calling the ruling "unprecedented and sweeping," argued that there was no evidence suggesting that the land could become essential the frog's conservation and that the areas did not meet the statutory definition of critical habitat.

Proposed reforms

Several scientists have recommended improving or reforming how science is used to implement the Endangered Species Act.

Independent peer review of listing

Some have argued that the science behind the decisions to list a species should be more carefully scrutinized. To improve the listing process, some scientists have suggested that a peer review system should be administered independently of the U.S. Fish and Wildlife Service. The reviews would focus on whether the available science is enough to support a listing decision.

Landowner compensation

Some property rights advocates have favored compensation to landowners for the cost of Endangered Species Act land use regulations. These advocates have said that compensating landowners whose land is unavailable for development due to species conservation would ensure that the public as a whole and not a select few would pay for the benefits of species conservation. According to property rights advocates, the U.S. Constitution reflects the principle that individuals should not pay a disproportionate amount in exchange for a public benefit. These advocates have argued that compensation would also reduce the politicization of Endangered Species Act decisions. Individuals who oppose listing a species because their land would be devalued would no longer have an incentive to politicize the science on the listing because they would be compensated. Further, the compensation would put a more accurate cost on land use regulations, give landowners an incentive to allow scientists to conduct research on their property, and provide landowners with the incentive to keep their property hospitable to potentially endangered species.

Science-based listing system

The Endangered Species Act requires that any petition to list a species be addressed by the Fish and Wildlife Service within 12 months. Critics of this system have argued that the deadline pressures the service to accept insufficient scientific data or focus more time and resources on a petition rather than on a species already listed. A backlog of listing petitions then accumulates, which permits private groups to sue the government for failing to respond to the petitions. According to some, a "science-based priority system" would allow field scientists to interact more with the public and to make the listing decisions without concern for legal deadlines.

Make data publicly available

Some scientists have argued that scientific information and decisions should be available to Congress and the public. Scientists and researchers, they say, should be allowed to share their work publicly even if some research is controversial or could affect federal policy. Furthermore, others have argued that "whistleblowers" who expose efforts "to alter or suppress research or technical information" should be protected from retaliation. In 2014, Rep. Doc Hastings (R) introduced the Endangered Species Transparency and Reasonableness Act, which would require the Fish and Wildlife Service to publicize the underlying data of a listing.

Encourage more participation by scientists

Some have argued that scientists and researchers should have the right to review, amend, and/or comment publicly about all federal documents that rely on their research. These scientists would be identified as authors or contributors and be able to represent their scientific opinion in public. While non-scientist federal employees may edit these documents, scientists would have the right to the final review to ensure scientific integrity is maintained.

Political context

Different groups react differently to Endangered Species Act decisions depending on their policy goals and political agenda. Those who face potential economic loss due to the economic impact of listing species on private property use have argued that the federal government should be certain of a species' presence and threatened status before it is listed, also making sure that the species is protected no longer than is necessary or prudent. These groups tend to be critical of the Endangered Species Act and its enforcement. Those involved in some scientific or environmental organizations have argued that the federal government should step in and protect species to avoid the irreversible extinction of species and to safeguard biodiversity, even if complete scientific information is unavailable. These groups tend to be Endangered Species Act advocates.

The relationship between science and politics is an ongoing debate. Many groups on the left and the right have criticized what is called the "politicization" of science. This politicization can include the manipulation of science for political reasons; the selective interpretation of scientific information in support of political, economic, and environmental goals; and the way in which political decisions are disguised as science. Both environmental and property rights groups have argued that science has been misused to support political decisions. Further, environmental and property rights groups do not necessarily align with the politics of a particular presidential administration. For example, pro-Endangered Species Act environmental groups and property rights groups have criticized actions during both the George W. Bush and the Barack Obama administrations. Environmental groups have sometimes argued that Bush administration decisions were based on political considerations and not scientific data. These groups have also said that Obama administration decisions, such as the decision not to list the sage grouse, were unsupported by scientific data. Similarly, property rights groups have criticized actions taken during the Bush administration, including the decision to list the polar bear as threatened and the decision to limit farmers and municipalities' water usage in order to conserve the delta smelt. These groups argued that the polar bear decision was based on speculation and not scientific data and that the water usage limits would harm farmers and individuals and at the same time do little to conserve the delta smelt.

Democrats

Democrats have generally supported the Endangered Species Act as an effective tool to prevent the extinction of species. The party has generally opposed legislative changes to the way the law is written or implemented, arguing that the Endangered Species Act is working as it was designed. Furthermore, Democrats have argued that the law's requirement that Endangered Species Act decisions to be made based on the "best scientific and commercial data available" has been implemented successfully and does not require revision. Congressional Democrats have largely opposed Republican-led legislative proposals that would require the federal government to use scientific data that state and local governments submit. Democrats have also opposed a Republican-led proposal allowing state and congressional consent before species are listed or delisted, arguing that such a proposal would undermine the use of science.

Republicans

Though Republicans have supported protection for species threatened with global extinction, Republicans have generally argued that the Endangered Species Act has not been effective at achieving this goal. Republicans have argued that the law has been often used to pursue policy goals, and that Endangered Species Act decisions have not been based upon "sound science." Furthermore, Republicans have contended that Endangered Species Act decisions have not been balanced with the costs of compliance and private property rights. Congressional Republicans have introduced proposals requiring that the scientific data used to determine that certain species is endangered be made publicly available. Another proposal would require that the federal government take into account the scientific data that state and local governments submit. Republicans have argued these proposals would increase transparency and improve the federal government's use of science.

See also

• 

  Environmental policy in the U.S.

• 

  Energy policy in the U.S.

• 

  Endangered species policy in the U.S.

• Endangered Species Act
• Implementation of the Endangered Species Act
• U.S. Fish and Wildlife Service
• Endangered species

External links

• U.S. Fish and Wildlife Service website
• U.S. National Oceanic and Atmospheric Service

Footnotes

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