Embarking on the Water Act 2013 with the funding support of Swiss Agency for Development and Cooperation (SDC) the Swiss Red Cross (SRC) in association with Development Association for Self-Reliance Communication and Health (DASCOH) Foundation and in collaboration with Water Resource Planning Organisation WARPO implemented the Integrated Water Resource Management (IWRM) Project in partnership with 39 Union Parishads and 3 Paurashavas in Rajshahi, Chapai Nawabganj and Naogaon districts – the lowest tier of local government that are legally mandated to ensure and regulate water related services. With priority to address the needs of disadvantaged groups the IWRM project covered a total of 106,743 households and 488, 845 population. The project’s prime focus was based on 4R principle e.g., 1. Reduction of over-abstraction and water pollution 2. Reuse of rainwater 3. Recycling water resources 4. Restoring water safety.  It was expected that the project will contribute to a paradigm shift to cross-sectoral integrated management of water resources from a sub-sectoral focus on improved water access.

The IWRM Project consists of two complementary components which are

(i) the ‘National Component’ implemented by Water Resources Planning Organization (WARPO) of Ministry of Water Resources (MoWR) and

(ii) the ‘Sub-National Component’ implemented by SRC in association with DASCOH Foundation.

The National Component’s focus was to further develop the national regulatory framework and operationalize the institutional mechanisms foreseen in the Bangladesh Water Act, 2013. The Sub-National Component of IWRM Project was complementing the National IWRM Project by focusing on sub-national government level. Besides supporting national component in developing water rules and organizing and conducting various consultation events intervention strategies applied by the sub-national component were:

• Awareness creation among stakeholders on the importance of IWRM adaptation
• Community based planning, implementation and monitoring through formation and facilitation of WRMCs and their associations.
• Community-led advocacy to UPs in addressing priority needs of meeting the water crisis identified by the WRMCs.
• Comprehensive input to the UP to establish a functional Union IWRM committee and perform their functions assigned by the BWR, 2018 and Union IWRM Guidelines.

The frequency of droughts, cyclones, floods, and other natural calamities across the globe is a stark reminder of the potential threats to human life. It is imperative for us to rise and protect our future. The IWRM project in the Barind area of Bangladesh is playing a crucial role in this endeavour.

Based on its practice generated lessons and learnings SRC and DASCOH believes that the approaches and methodologies have been implemented by the IWRM project   have an incredible potential to be replicated nationwide towards promotion of inclusive water governance in a sustainable manner. CLTS Foundation Global-India has undertaken the responsibility of assessing the impact of IWRM project and documenting its implementation process to further enhance the impact of IWRM in Barind area of Bangladesh.

The   objective of the study was to assess the impact created by the IWRM project; document the institutional process, strengths and weaknesses and implementation processes applied in the IWRM project. This was also focused to determine the way forward.

The study was carried out between 14^th – 24^th July 2023. During these 10 days intensive study by a three-member team from CLTS Foundation accompanied by staff from DASCOH Foundation and Swiss Red Cross (SRC) travelled to villages, Union Parishads, Upazilas and Districts of Barind area namely Nagaon, Chapai Nawabganj and Rajshahi. During the entire study, the team members used participatory approaches in eliciting the information from the community members and other stakeholders while visiting various project areas. Additionally, 4 male and 4 female national enumerators were engaged in gathering household data and other allied information through a questionnaire survey.  In line with the research ethics, both primary and secondary sources of data including quantitative and qualitative information, opinions and ideas were gathered from relevant stakeholders. Apart from the survey the following participatory tools were used:

• Focused Group Discussions.
• Key Informant Interviews
• Workshops with Union Parishads and Municipalities
• Direct Observations
• Site visits with transect walk and discussions with farmers and water users in the field; and
• Review of videos, and documents.

It was evident from the analysis of data and information, opinions and ideas offered by the beneficiaries at different level that the IWRM project has created significant and lasting impacts. Impact of the IWRM project can be grouped under four broad categories which are institutional impact, social impact, impact on water resource conservation and climate change adaptation.

The impact on climate change cannot be easily measured without rigorous scientific study. Nevertheless, a notable transformation in the vegetation landscape of the project area is evident through the expansion of mango and other orchards. The project has successfully heightened awareness and promoted practices in water resource conservation, resulting in the preservation of billions of litres of groundwater annually. According to the perception of local citizens, the IWRM project’s major impact include the diversification of crop cultivation, improvement of soil texture, and enhancement of biodiversity.

A fairly distinct impact has also been noticed on the livelihood of the people living in the Barind area particularly those who benefitted from the IWRM project. Simultaneously, a negative impact has been noticed in the reduction of opportunity in the seasonal income of the tribal women force due to sharp reduction of more than 75% in the cultivable areas of rice which was replaced by orchard. The tribal women labourer who used to engaged themselves in different stages of rice cultivation (transplanting, weeding, harvesting, thrashing, storage) in large number has been reduced sharply. Although the individual women labour earns more under the orcharding activities, the number getting income opportunity has sharply been dropped as compared to rice cultivation.

The evaluation put forward the approach applied by the IWRM project embody an ample value to be replicated thus deserves more attention and support from the Government of Bangladesh (GoB).

The challenges in achieving a coordinated planning at all level through convergence of targeted interventions of all relevant ministries, departments and agencies engaged in water, agriculture, land and other relevant resource management. Achieving convergence of land and water use plans is also crucial in IWRM still remains a challenge.  Another challenge is to have government’s concrete plan and action on the ground. The GoB are yet to officially declare categories of water stress areas and to layout its concrete policy-plans and actions to reduce this serious disaster risk. Although Barind is a home for many ethnic populations, the ownership of most of the land belongs to the elite Bengalis who shifted to orcharding from the traditional rice cultivation. As a result of this shift a few genders negative impact has been noticed on the life of disadvantaged ethnic women.  In the context of protection of livelihood land ownership and decision of crop cultivation by landlords often affects the livelihood of marginalized ethnic women which is a new challenge for these women.

Visit to the intervention area of IWRM project

Triangulating ideas and opinions gathered by the study and in consideration of above-stated challenges; the evaluation put across following recommendation for more meaningful way forward:

• Intensify advocacy interventions by developing an advocacy strategic plan to advocate the Barind water issue to higher-level politicians and decision-makers.
• Design and implement special Water Disaster Risk Reduction (WDRR) projects for those Unions and Upazilas under severe threat of water crisis
• Consider a special programme for the promotion of alternative livelihood for disadvantaged ethnic communities.
• Raise stakeholders’ awareness on land use policy and planning
• Introduce participatory water quality monitoring and result sharing
• Continued training and capacity building for the UP Chairmen and Members
• Development of IWRM Training Curriculum
• Intensify interventions related to improve sanitation and waste management
• Encouraging WRMCs to create self-help savings and revolving fund:
• Conservation of surface runoff and rainwater for domestic and irrigation purposes
• Evaluate performance of Rajshahi Divisional WARPO office: Identify performance gaps; and then determine needs to be addressed to make the divisional WARPO office more functional and effective
• Scaling up through horizontal learning and sharing

The IWRM project strategies and methodology applied by WARPO, SRC and DASCOH is highly laudable for its effectiveness and efficiency to promote equitable water governance. However, in terms of sustainability of process it would have been more efficient if the gradual phase-out strategies and framework were an inbuilt component. The project is ending soon but it seems that there remains an ambiguity on the sustainability of the institutionalization process initiated. As an when the project support is withdrawn with the withdrawal of facilitation support by SRC-DASCOH it is likely that the sustainability will suffer a jerk. There is no doubt that institutionalization of IWRM approach require continuation of facilitation input from SRC-DASCOH and WARPO until the established IWRMC at Upazila is ready to perform similar roles. The evaluation recommends WARPO, SRC and DASCOH to develop capacity of Upazila ad Union IWRMCs towards gradual shifting of role to them which are being performed by SRC-DASCOH at the moment. There are examples of self-initiated and voluntary budgetary allocations by several municipalities and UPs for the continuity and sustainability of effort.

DASCOH and SRC could strategize to implement above –stated recommendations by tapping funding from various funding and development agencies to carry on the activities.  The major learning from this project could also be disseminated to other areas of Bangladesh and elsewhere through national and regional workshops followed by documentation of the proceedings including case studies of the project areas.

Employment generation, creating a positive impact on nature, and among managing sustainable goals through water resource management, tree plantation, and community-scale workshops, the project is addressing the challenge of water scarcity in a drought-prone area. It not only provides fresh air but also contributes to the improvement of the cost-of-living expenses for the local population. Now, more than ever, it is essential for us to take action and work towards a sustainable and resilient future.

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According to the latest WHO data, published in 2020 diarrhoeal disease deaths in South Sudan reached 7,270 or 8.67% of total deaths. The age- adjusted death rate is 89.87 per 100,000 of population ranks South Sudan 9^th in the world.

Communicable diseases remain a major public health problem and are the leading cause of death. Malaria, diarrhoea, and pneumonia constitute about 77% of the total OPD diagnoses for children under five. Other causes of morbidity and mortality include maternal deaths; severe acute malnutrition; TB/HIV where TB prevalence is at 146 per 100,000 and HIV/AIDS prevalence is estimated at 2.6%, hence classified as a generalized epidemic.

All of these could be curable provided there is a political will supported by budgetary contributions to public health at the national level.

Achieving ODF targets by 2030 will require a quintuple (fivefold) of current rates of progress. If South Sudan progresses in the current way, it will become an ODF country by 2065.

To scale up CLTS in South Sudan, a training of trainer’s was conducted in Torit, from 11^th – 17^th February 2023. The training brought together 77 participants from Government, INGOs, NGOs and other WASH stakeholders. A team from CLTS Foundation Global led by Dr Kamal Kar was invited by Mentor Initiative to implement the training workshop in Torit. The workshop was implemented by CLTS Foundation Global with support from MENTOR Initiative and UNICEF South Sudan. After the five days training workshop in Torit, a one-day national-level institutional triggering event was held in capital city of Juba on 20th February.

Some of the recommendations which emerged after the training and institutional triggering event were mainly focused towards enhancing community participation, ownership, and institutionalisation of CLTS with appropriate policy adjustments resulting in high quality and effective CLTS implementation at an accelerated speed.

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The learning event was supported and facilitated by UNICEF Regional Office for South Asia (ROSA), CLTS Foundation Global, Bill and Melinda Gates Foundation (BMGF) and Regional Sanitation Center (RSC) for South Asia, wherein internationally recognized sanitation experts were invited. SanLearn 2022 intended to bring together senior government officials, key decision-makers and technical staff from different countries to engage in discussion and seek common solutions to eliminate open defecation and scale up access to safely managed sanitation.

The CLTS Foundation Global was engaged by the Nepal Country Office to undertake a comprehensive analysis and an evaluation of the ODF programme and to also identify lessons learned to help better planning and designing interventions for ensuring ODF sustainability. They had also been tasked with assessing how effectively gender and equity dimensions have been addressed. All these elements were a key focus of the SanLearn conference which is a regional knowledge sharing and capacity development event. CLTS Foundation Global’s findings from Nepal were critically important learnings for participants attending the event to develop their capacities and in helping them achieving SDG 6.2 in South Asia, where tremendous strides have been made in eliminating ODF, but with a lot more yet to be done.

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The local rural communities burn wood in primitive three stone stoves or Sost Gulichas. These outdated cooking methods are very wasteful and most of the heat from burning the firewood is lost and very little is actually utilized. The alternative to Sost Gulichas is a modernized version of simple stove called ICS or Improved Cook Stoves, made of reinforced cement and iron rods and which costs at least 350 Birr or around 6 US Dollars. Now, the problem is that most ofthe population in this region is very poor and cannot afford to pay the money upfrontDevelopment of the approach of ‘Community Led Total Adoption of Improved CookStoves (CLT-Stoves)’ was initiated in the year 2018 and was jointly led by Vita and CLTSFoundation Global in rural Ethiopia.Number of government andnon-government partners collaborated in the initiative. The objective of this initiative was to facilitate the local population to adopt Improved Cookstoves. They were trained on cleaner and efficient methods of cooking.

A training of trainers on improved cookstove was conducted in Arba Minch in of May 2022. This training was participated by woreda and zonal level officials from the Government Departments of Women and Children Affairs; Environment,Forest,and Climate Change; Water, Irrigation and Energy, staff members of Vita, lecturers and teachers fromArba Minch University, Women cooperative leaders and community members from theketenas that were triggered as a part of the training.

The training was facilitated by Vita and CLTS Foundation Global. The purpose of this training workshop was to train the govt. and zonal level officials on the importance of CLT-S approach and how to empower the local population for smooth and fast transition from Sost Gulichas to Improved Cook Stoves.

The reasonwas to piggyback on CLTS approach for increasing the uptake of fuel-efficient cook stoves through reinforcing the basic principles ofattitude& behaviour change of CLTS.

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Though most of Nepal now has access to proper sanitation facilities and most districts have stopped the practice of open defecation, some small clusters are yet to adopt the CLTS approach. Thus, a follow up evaluation visit was organized in the month of April 2022. The evaluation examined the performance of the sanitation programmes through the lenses of human rights, gender and equity.

This assessment was conducted in consortium with UNICEF Nepal and Citizen Development Solution P Ltd Nepal. Around twenty data collectors or enumerators were trained for the purpose of data collection from the field. They went from household to household and gathered information from the locals in the concerned districts. A survey questionnaire was prepared by CLTS Foundation Global and a copy of which was given to each enumerator. The questionnaire consisted of carefully thought-out questions that would make it easier to assess the existing sanitation situation as whole.

In most other approaches the outsiders lecture and advise the community members on the right approach, whereas CLTS approach empowers them to decide what is good or bad from the perspective of community health and hygiene. The concept of TOTAL (in Community Led Total Sanitation Approach) confirms leaving no one behind including marginalized and vulnerable groups.

The purpose of this visit was to contribute to enhance UNICEF’S sanitation programme. The evaluation will bring forward valuable information which will be used to analyse what steps should be taken next. Some objectives of the visit were to evaluate the performance of sanitation programmes thus far, assess and compile the positive lessons learned till now and to provide feasible recommendations for the future.

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Gosaba Block of Bali Island is an isolated island in the mouth of Vidya river falling into Bay of Bengal. The island is disconnected from the main land of West Bengal and is totally isolated without any connectivity by road or any other means other than water transport. There are ferry launches those shuttle between Bali and Godhkhali, which are not only very few in number but also uncertain in their services that depends mainly on the weather conditions. However, the connectivity by water transport including small private motor boats and private launches is far better in winter and summer months as compared to monsoon and rainy season July – September. Cyclonic storms and high tides make the connections difficult and the people of Bali island mostly depend on the market and other basic facilities available in the island. There is no regular supply of electricity from the main land. However solar lights and generators are being used by private business enterprises and tourist establishments. Bali island is mainly famous for the purpose of tourism in and around Sundarbans. This is the entry point of tourist visiting the Sundarbans delta, its unique mangroves, flora, fauna and bird sanctuaries.  There are 102 small islands in the Bay of Bengal delta comprising mostly Sundarbans of which 54 islands have human habitations and the rest are forest area. In general the people living in these islands depends on rain-fed agriculture, fisheries, honey collections, catching fish and crabs and inland fisheries. Most of the 250 households scattered in Bali (Gram panchayat 1 and 2) have small ponds and ditches in their homesteads. Mostly Indian Major Carp: Catla (Catla catla) Mrigal (Cirrhinus cirrhosis) and Rohu /Rui (Labeo rohita)  and a few other fishes are cultivated in these ponds for domestic use and occasional sale in the market. The dyke of most of these ponds have high density plantation of banana, lemon, elephant food yam and seasonal vegetable (cabbage, tomato, chillies, potatoes and different gourds). Overall the village looks lush green around the homesteads.

The agricultural land of Bali is mostly mono crop area where only rice is grown during rain-fed Kharif season. Due to shortage and uncertainty of irrigation, winter crops like Boro rice, mustard, potatoes or such other crops are not grown by the farmers largely. The old practice of inter cropping with Khesari dal, which is broadcasted before the harvest of kharif rice is a common practise by the farmers. In more than 25% of the crop land the traditional variety of rice is still grown. These varieties have the capacity of tolerating flash floods and deep water logging. As the water level grows the rice crop also grows and the panicles of rice plant stays above the water level.

As a result the straw of such variety of rice is very long, which remains submerged in the water at least for three months. Often the rice is harvested using boats. When the water recedes, these half rotten paddy straws which is unfit for consumption of cattle are stored for the purpose of using them as fuel. These straws also can be used for thatching houses. Since the roof thatching has mostly become obsolete and most houses have concrete, Corrugated Galvanised Iron or asbestos roof. Some farmers burn the straw right in the field in order to reduce the labour cost to bring them all the way to homesteads. These farmers use threshing machine right into the field and bring paddy home and leave the straw in the field. The farmers do as there is no second or third crop is grown in the same field due to lack of irrigation.

The local variety of rice that is grown are Dudheshwar and Masuri. It seems that the farmers having 1-2 bigha (1.6 acres approximately) of land can easily produce their annual household requirement of rice or at least 10 months stock of rice depending on the size of the family. Often the farmers sell the finer variety of rice Dudheshwar to open market and keep the coarse variety of rice (Miniket) for home consumption.

Along with  agriculture most houses have smaller livestock like Bengal goats, sheep, poultry, country chicken and ducks. Local breed of Bengal cattle (Zebu)   is also maintained by some families. The castrated male of these cattle are used for  ploughing (bullocks) and the female calf are reared to meet the household requirement of milk. As the availability of fodder is abundant because of vast grazing land and luxuriant growth of grass along the aisles of the crop land. The availability of green fodder is assured to some extent during the wet season. The cow and poultry manure is used in the crop field.

Mangrove ecosystem is a very special environment that exists between the  upland and the sea and the low lying land rolling into the sea in the tropical and subtropical regions. It is a transitional ecotone which supports a unique variety of plant community collectively known as the mangrove. The mangrove plants are specially adapted to thrive under varying salinity,

recurrent tidal inundation and periodic desiccation. The mangrove forests with their typical root-system play an important role in protecting and extending the coastline, by trapping sediments and binding the soils. The mangrove ecosystem is also known to support fishery, by developing a detritus-based food-web and help regulating regional climate. It is the natural abode of many groups of animals and large number of species are known to feed, breed and take shelter in this ecosystem.

The CLTS Foundation Global team left from Kolkata to Gadkhali by road and then by a boat to the Bali Island. From Gadkhali the team travelled for two hours by motorboat and reach Bali Island. The team stayed at the remote location in Bali for two days in a guest house. After arriving at the island, the team had to walk down a kilometer to a small private guest house. The road which led to the guest house was in fact the embankment on Vidya river to protect the adjoining villages from flood and saline water. The path on the embankment was quite rough, uneven and had the mark of recurrent flood damage. During their stay the team had the opportunity to walk around the block consisting of GP 1 and GP 2 to have an initial understanding of the community, their cropping systems, livelihood pattern and the ecology of the area.

The area of intervention is a remote location, by road it is not feasible to visit the place. During the team’s visit to the place it was understood that it is an agrarian community which mainly practices monocropping. At the moment the primary need of the area is ensured supply of irrigation water during the dry season for the farmers to grow different crops and increase the cropping area of winter rice. If the supply of fresh water is available then other economic and social issues of the community will get resolved. Supply of fresh water for irrigation can help the community adapt to modern agriculture technology to intensify agriculture production. Though the government has done a few interventions like installation of solar lights, construction of household and community toilets and construction of barrages and boat landing station (Kheya Ghat), sadly its deteriorating due to lack of maintenance.

Some of the major observations were that each block had about 250 households with each household having at least 1-2 (32 decimals is a bigha) bighas of land. All households had their own pond and uses wood, cow dung and crop residues as their main sources of fuel. Though few households still used cooking gas, it was sparingly used only to warm and heat food as cooking gas was considered quite a luxury as it is expensive. On the contrary wood is available in abundance which is harvested mostly from local bushes and forest to meet their fuel needs round the year except in the rainy season. During the wet season the better off families resort to cooking stoves.

Only a few households who had land near the canal could grow multiple crops. Some households practiced boro rice cultivation as a second crop. Rain-fed Kharif rice cultivation is the major cropping system, dykes of ponds were used for cultivating seasonal vegetables. In some lowline areas flood and saline tolerant deep-water paddy was being cultivated along with HYV (High Yielding Variety) of rice by some farmers in the Rabi season with irrigation.

Knol-khol (Kohlrabi), cabbage, onions, chilies, spinach, brinjal, ladies’ finger and numerous other summer and winter vegetables are grown. However, the farmers don’t get a lucrative price for their produce. The major hurdle in getting a good price for their agricultural produce is the difficulty in transportation and communication with the main land. The producers are compelled to sell their produce in the local daily and weekly market. The weekly market is larger and is organized two times in a week. The wholesale purchasers from the nearby towns/cities purchase the produce in bulk from the local producers and take them away for sale in urban markets. This way the major chunk of the profit is taken away by middlemen. Developing a farmer friendly market channel would immensely benefit the local producers who could sell their crops and vegetables at the farm gate and improve their economy by reducing the exploitation by middlemen to some extent.

Since there are also no standard ferry services between Bali and Gadkhali (mainland) which requires around 2 and a half hours by motor launch, the overall development of this island is stuck due to lack of easy transportation and communication. Only a few motor launch operate in the area mainly for tourists who hire them privately. The condition of the health and education system is no better, although there is a primary health centre on the island, for any serious health complications the patient must be taken to Gosaba hospital which is about one and a half hours from Bali. The village primary school caters to the immediate education of the children however, only one primary school in the village provides basic primary education after which the children must travel outside the village for their secondary or higher education.

Sanitation is an issue here also, open defecation is just practiced by some individuals. Most families have their own toilets. However, other basic hygiene behaviour was not practiced by the people at large as a result of which dysentery and diarrhoea was rampant among the families.

There are almost 20 self-help groups in each block. ‘Narikalyan Mahila Samiti’ is one of them, it provides financial aid to villagers in the form of small loans/credit.

As mentioned earlier the Haldi canal offers a great potentiality to boost up agriculture and local economy. The natural canal is silted and has reduced in size considerably over the years. This Haldi canal offers a great potential to the community of Bali and with some external investment and local contribution the canal has the potentiality to double the cropping intensity.

Apart from lack of transportation & sanitation the community also faces major challenges due to scarcity of water. There is an inadequacy of irrigation water and on top of that rainwater which is the main source of fresh water is also not harvested adequately to meet water requirements in the lean season. Due to this scarcity of water only one crop is grown in a year, if two crops can be grown in a year it will help the social and economic upliftment of the households.

As farming is the main occupation and only one crop is cultivated in a year, the women of the community have plenty of free time during the lean agricultural season. The work load is high during three- four months of peak cultivation in a year.

Cyclones are also not uncommon in these areas, most storms and cyclones from the Bay of Bengal affect these areas every monsoon and recently cyclone Amphan has wreaked havoc in the area. And if that wasn’t enough man-eating Royal Bengal Tigers roam from the nearby core forest area and may sometimes wander into settlements and attack villagers and livestock. Though the last tiger attack was 5 years ago the fear of another tiger attack is always looming in the minds of the people. Even if the villagers survives the man-eating tigers and the cyclones they still have to worry about disease such as dysentery and diarrhoea which arise due to open defecation.

Poverty runs rampant in these lands, in order to enhance the income from agriculture and animal husbandry the Bali island has many options. Semi-intensive livestock farming through selective breeding for improving/upgrading the local breed of cattle, goat and sheep may be organized. Specially selected breeding bulls, bucks and rams may be kept with the selected farmers whose services should be made available to interested farmers who would like to upgrade their livestock by paying a token service charge. This could be arranged and organized by local villagers with the help of animal resource department and NGOs. This upgradation program with the local selection will not only restore the genetic potential of livestock of Sundarbans but boost up the local economy from milk, meat and wool. It is important to keep in mind that introduction of exotic breeds to upgrade the local livestock haphazardly might destroy the strong genetic potential appropriate for this ecosystem evolved over hundreds of years. Apart from animal husbandry introduction of processing, packaging and marketing of local honey could offer a huge revenue for livelihood development of the local people.

As the concept of eco-tourism is rapidly becoming popular, selected families could be trained on eco-tourism. Detailed information about the local flora, fauna, aquatic life, wildlife, animal behaviour, man animal conflict, environmental conservation and indigenous biodiversity protection could be given to interested tourists. Selected families and youth could be trained on eco-tourism, these trained youth could organize specialized tours for interested tourists. Some interested youths could even provide homestays for tourists who are more interested in living closely with the local environment and population.

In conclusion the Sundarbans of West Bengal offers a great opportunity to develop this fragile ecosystem with its unique flora and fauna many of which is at the margin of extinction. This could be a global example of harmonious man and nature coexistence.

While CLTS Foundation Global is committed to extend support for the cause of protecting and restoring the unique biodiversity including the reduction in man-environment conflict.  We welcome any help and support from interested institutions/ individuals.

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