comprehensive land use plan

Swinomish Cooperative Land Use Program

Year

Based on a memorandum of agreement between the Tribe and Skagit County, the Swinomish Cooperative Land Use Program provides a framework for conducting permitting activities within the boundaries of the "checkerboarded" reservation and offers a forum for resolving potential conflicts. The process, which began in the mid-1980s, was the first of its kind in the United States and illustrates a promising alternative in land use conflict resolution by promoting between-government jurisdictional coordination. Since 1996, the tribal and county governments have jointly adopted a Comprehensive Land Use Plan and procedures to administer the plan, which together foster a mutually beneficial government-to-government relationship. Significantly, the model also has served to improve relationships between the Tribe and other contiguous local governments. To date, the Swinomish Indian Tribal Community has instituted more than a dozen separate agreements with federal, state, county, and municipal authorities in the areas of land use, public safety, public health, environmental protection, and utility regulation.

Resource Type
Citation

"Swinomish Cooperative Land Use Program." Honoring Nations: 2000 Honoree. Harvard Project on American Indian Economic Development, John F. Kennedy School of Government, Harvard University. Cambridge, Massachusetts. 2001. Report.

Permissions

This Honoring Nations report is featured on the Indigenous Governance Database with the permission of the Harvard Project on American Indian Economic Development.

Honoring Nations: Charlie O'Hara: Developing Productive Government-to-Government Relations: Swinomish Cooperative Land Use Program

Producer
Harvard Project on American Indian Economic Development
Year

Charlie O'Hara discusses the Swinomish Cooperative Land Use Program and the importance of developing productive mutually beneficial government-to-government relations.

Resource Type
Citation

O'Hara, Charlie. "Developing Productive Government-to-Government Relations: Swinomish Cooperative Land Use Program." Honoring Nations symposium. Harvard Project on American Indian Economic Development, John F. Kennedy School of Government, Harvard University. Sante Fe, New Mexico. February 7, 2002. Presentation.

Andrew Lee:

"Our final presentation from an Honoring Nations winner today is Charlie O'Hara, who's going to be talking about developing productive government-to-government relationships. Charlie's from the Swinomish Tribe in Washington State, which is about 80 miles north of Seattle. And they deal with a problem that many of your nations face as well, which is how to deal with checker-boarded reservations and how that impacts land use planning. In 2000, the Swinomish Tribe won an Honoring Nations award for their cooperative land use program. It's really a model that I know lots of folks around the country have looked to for inspiration in developing good sovereign-to-sovereign relationships on reservations that are highly checker boarded. Charlie, good to see you here. Ready to hear and learn from you today."

Charlie O'Hara:

"You notice Andrew tilts the mic the whole time to accommodate his six -oot height. Thank you very much. I generally don't need a mic that much.

Let me first start off by saying that I'm a recent employee at the Swinomish Indian Tribal Community. And the work that was done to actually gain this award was done by my predecessor, and much of the credit goes to the tribal senate. Fortunately, I have my tribal chairman here, who can correct me when I make some errors in this presentation, but he and his predecessors deserve much of the credit because this was really a process that took place over a long period of time. It was roughly 15 years, I believe, in terms of the tribe's recognition of the issue and that is the land-use regulation in a checkerboarded reservation and how to best deal with that. The tribe took the position that they had land use jurisdiction over all lands on the reservation. Of course the county's position was, ‘No, you only have land use regulation over the trust portions of the reservation.' So there was a disagreement obviously.

There were options. They could have gone to litigation. The tribe and the county instead chose to try to work out through cooperative agreements a mechanism for dealing with this disagreement. Initially there was a period of mutual education where, through extensive meetings, there was actually a building bridges process that took place of some rather intense workshops to mutually educate both the county and the tribal members regarding each other's concerns, each other's issues in how they might seek some way of accommodating those kinds of concerns. Eventually, out of that process there was an agreement reached as to some basic understandings of the different approaches and how they might be bridged. Ultimately, it ended up with a cooperative agreement that talks about sharing responsibilities for dealing with land use regulation on the fee lands within the reservation. The tribe still exercises complete jurisdiction over trust properties, but it shares responsibilities with the county on the fee lands.

So for example, let me give you an example of how that works. If an individual is going to get a clearing and grading permit, for example, he has a choice of either going to the county or to the tribe. We have mutual processes...similar processes and that individual can go to either place. If he comes to the tribe, I have five days to forward that permit application to the county. They then have 15 days to respond and tell me if there's a problem with it. Likewise, if he were to go to the county, I would have that same opportunity. My response...I might have an issue, for example, because of concern over cultural resources in that particular area or other specifically tribal kinds of concerns. But basically, we use the same UPC, we use the same codes in other words, and we share expertise in a variety of areas. That's kind of the guts of the thing. I'd like to kind of talk a little bit if you don't mind about some of the more abstract aspects of government-to-government relations and effective government-to-government relations.

There's basically three types of relationships you can have with the outsiders, the non-Indians, and that seems to be isolation, litigation or adversarial kind of relationship, or some kind of cooperative relationship. All of them have their applications. In other words, some of them have our appropriate but different kinds of situations. Let me give you an example. For example, on certain cultural practices, isolation may be the best approach where a tribe has no interest in sharing a particular, whether it be ceremonies or practices, with non-Indian community. Isolation, in that case, would probably be the best kind of approach. And quite honestly I think that's probably the approach, is that fair to say at Swinomish with the smoke house? No interest in what the county's doing or anything else. It doesn't impact them. Litigation is often, too often probably, a situation where it ends up being the only avenue in order to protect essential tribal rights and so litigation becomes the only method of resolving an issue. The problem with litigation is often that it's very costly both in terms of financial resources as well as staff resources, it's lengthy, and you never know what the outcome is. It's a crapshoot in other words. And one of the other parts of the problem with that kind of an adversarial relationship is it tends to color other issues and you may be litigating only on one issue but all of a sudden you find that negative atmosphere spreads out over other issues that you're trying to deal with and so it gets less than productive in that sense. Cooperative relations, on the other hand, can be productive, but there needs to be in those cases perceived balance of power relations. Too often, you see groups pulled into cooperative or collaborative situations where the power isn't equal and, I would argue, that those are difficult situations for tribes to be in. One situation for example that I particularly don't care for is those kinds of cooperative or collaborative efforts where tribes are viewed as another stakeholder. Often, the situations involve trust responsibilities, treaty rights, other things where tribes are not just another stakeholder. And in those cases it really requires a defined government-to-government relationship and tribes shouldn't be treated as just another stakeholder. So I guess my point is that each of these approaches have their application.

The Swinomish Tribe has a culture of respect for all people and a willingness to try to find a cooperative way of working through issues. It's probably the most respectful group of people I've ever had the privilege to work with and I really enjoy that opportunity. The cooperative relationships can be the most productive however, when that perceived power relationship is balanced. And that can often require a lengthy mutual education process and that's often necessary. And that's the process that the tribe went through with Skagit County so that they could both understand their issues. Often we feel that our issue is the right issue and whoever we're talking with, their issue doesn't have value. Typically for cooperative relationships to work, there needs to be some kind of mutual respect development. Like I said, cooperative relationships can be most productive, because like the adversarial relationship it can spread and it tends to resolve other issues.

I want to allude here for a minute to Jon Cooley's remarks about the cooperative agreement with [U.S.] Fish and Wildlife. In a prior life, I worked with White Mountain Apache Tribe as well, and so I had the opportunity to work on that issue. And just because it's a nice thing to talk about, that statement of, what actually turned out to be a statement of relationship developed out of a meeting between the chairman of the White Mountain Apache Tribe and the director of the U.S. Fish and Wildlife Service; one-on-one in a neutral location with a ground rule that no lawyers were allowed. Interestingly enough, that meeting was brokered by Joe Kalt. Joe Kalt recognized the conflict that the tribe was in with U.S. Fish and Wildlife Service and I happened to be seeing him and he asked me, ‘Do you think Chairman [Ronnie] Lupe would meet with Molly Beattie?' And fortunately Chairman Lupe agreed and it was a most productive meeting. The interesting part of that though was that we had been thoroughly engaged in a conflict situation; we had been spending all of our resources fighting with U.S. Fish and Wildlife Service. When the statement of relationship concluded, all of a sudden the whole thing changed and we were working hand-in-hand in the field, doing things on the ground to improve the situation for endangered species. So it was an interesting experience. But like that experience, it rested on an agreement to disagree. The Chairman emphatically stated that the Endangered Species Act does not apply on Indian lands. Molly Beattie said, ‘I have to...my job is to implement the Endangered Species Act. We don't agree.' They said, ‘Fine, we don't agree, but let's set that aside and see how we can move forward.' Likewise, in the case with the Swinomish Tribe and Skagit County there was an agreement: ‘We don't agree on who has jurisdiction over fee land, but let's set that disagreement aside so we can move forward productively.' Those kinds of mutual respect and agreements to disagree are necessary for cooperative relationships because you're not going to agree on everything.

I guess I'm going to try to close. But currently we're involved right now in both the litigation and the cooperative relationship mode and it's going to be interesting to see how that works out. But the one interesting fact, although it's rather contentious litigation and it has to do with treaty rights and endangered species and natural resource management and the tribe protecting those rights, nonetheless the cooperative agreement regarding land use regulation has stood up and it is still a touchstone that we go back to to demonstrate that on some things we can cooperate and we can proceed in a cooperative manner.

So I guess in conclusion, I guess effective government-to-government relationships require mutual respect, they require some level of technical expertise whether it be on fish and game issues or whether it be in the case of land use planning. In the case of the statement of relationship, U.S. Fish and Wildlife Service recognized that the White Mountain Apache Tribe had really good wildlife biology program and management program. In the case of the Swinomish Tribe, they recognized that they had good land use planning and good policies in effect. Those are kind of important, that technical underpinning of those agreements. Third, there has to be a consistency of policy. In other words, when you reach an agreement, then that agreement has to be maintained. It can't be re-read, redefined for every issue. Fourth, there needs to be open communications. That's one thing that we really need to work on is continuing communication with Skagit County. Often, if you don't have an issue, you don't communicate. And then when you have a negative issue the communications can really go sour quickly. Finally, for any of these things to work there has to be political will. If you don't have the will of the senate or in our case the tribal senate or in most cases tribal councils, these things won't stand up. And really, when we talk about what does it take for exemplary governance, it takes a lot of political will on the part of the elected leadership of tribes. Thank you."

Joseph P. Kalt:

"Charlie, as you know, the purpose of the Honoring Nations program is to provide a mechanism by which tribes can learn from each other. And as you know, the Swinomish example is now being used explicitly. I was at Nez Perce just 10 days ago and trying to provide examples to other situations in other tribes to learn from your successes. I have two questions about this; basically it's one question. Is it working? Specifically, two parts to this: one of the things that's been done so much at Swinomish is something that we see nations around the world doing when they don't share a government. That is they both think they're sovereign, they both assert their sovereignty. You all have used these techniques of ‘You have .3 members, I have .3 members and we'll pick a neutral' and that's actually very common in governments around the world is the sign of the exercise of sovereignty. I'd like to know whether that specific mechanism, how it works and then secondly I'd like to know more generally, are these cooperative agreements working? Let me tell you why. When I talk to you or I talk to Ned, one version is, ‘Wow, man it's nothing but trouble. We're negotiating all the time.' And I don't know whether to interpret that as they aren't working or is it like me complaining, ‘My university doesn't work, this thing called Harvard...it doesn't work at all because I'm fighting with my dean.' Well, of course it works at one level. So in other words, does it work? And when I hear you say it doesn't work, does that mean it's not working [unintelligible]?

Charlie O'Hara:

"Let me answer the first one first, which is, ‘Does that mechanism set-up of the advisory group work?' We haven't had an issue of enough significance to call it into being. Quite honestly, that's a shortcoming and I'll take blame for that because we really should be working that group in the event that we do have a big issue. We're likely to have one fairly soon."

Brian Cladoosby:

"Let me add just a little bit. I'm Brian Cladoosby. I'm the chairman at Swinomish. Now, this board is set up: if I as a fee-land owner give a permit, bring it to the county, the county sends it to Swinomish and Swinomish says, ‘No, that goes all against everything that we want to do at Swinomish,' then it goes to the deal board. The deal board hasn't had to hear any of these...Swinomish hasn't denied, county hasn't denied. So basically the board...everything that we do is so unified as far as land use that this board hasn't had to have been used in the couple years since it's been set up. So, in a sense, they're there in case we appeal within the county issues or the county appeals to things that we issue. So the board is there, but we haven't had to use it."

Charlie O'Hara:

"And in answer to the second part of that question is, I guess it depends on what day you ask me because sometimes you're optimistic and sometimes you're not. Right now, for example, the tribe...it's what's called the buffer case, meaning that the tribes have been pushing farmers in Skagit County to create bigger buffers on streams to protect salmon habitat. That, of course, cuts into the farmland so you've got farmers up in arms and they tend to be the political power brokers in Skagit County. And so it's very contentious. The tribes have gone to court; the tribes have won consistently in court. The county has tried to get the tribes to back off that position and used a number of mechanisms, intimidation in holding up fee-to-trust applications and a number of other arm-twisting mechanisms. But, surprisingly, it has not affected the land-use agreement and we've had a couple of issues arise, particularly one most recently involving cultural resources or the potential of cultural resources being on a piece of property that was being developed. And the landowner, being a particularly contentious person that claimed he had a cultural survey done, and there was nothing there. So the tribe said, ‘Fine. Show it to us.' He refused. The county then said, ‘Look, if you don't show us this survey, we're not going to go forward.' And so he reluctantly turned it over to the county. He wouldn't turn it over to the tribe. The county then turned it over to us and everything worked out okay. But the point was that it was tested and it worked. And so I guess I'm feeling optimistic today so yeah."

Audience member:

"Let's turn the question around another way. One supposes that good relations between potentially conflicting groups need to be constantly renewed. So are you actively thinking about ways to show as you're doing just today that it's working and celebrating the cooperation that exists against the day when you may have a conflict and you'll need to draw upon the reserve of good will that you're hoping to build up."

Charlie O'Hara:

"Probably not enough to be quite honest with you. But, for example, we've shared like breakfasts with the Skagit County permitting people and brought our cultural resources planner there to explain cultural resource issues and how they can be better sensitive to when they may run into cultural issue resource issues when they're doing projects. We've participated jointly in some conferences but it's never enough. It's something that has to be continually worked."

Honoring Nations: Cedric Kuwaninvaya: The Hopi Land Team

Producer
Harvard Project on American Indian Economic Development
Year

Former Chairman of the Hopi Land Team Cedric Kuwaninvaya presents an overview of the tribal subcommittee's work to the Honoring Nations Board of Governors in conjunction with the 2005 Honoring Nations Awards.

Native Nations
Resource Type
Citation

Kuwaninvaya, Cedric. "The Hopi Land Team." Honoring Nations Awards event. Harvard Project on American Indian Economic Development, John F. Kennedy School of Government, Harvard University. Tulsa, Oklahoma. November 1, 2005. Presentation.

Cedric Kuwaninvaya:

"[Hopi language]. Greetings from the Hopi Tribe to the Honoring Nations Advisory Board and honored guests. It is with great honor and privilege to deliver our final presentation to you. The Hopi Land Team is a subcommittee of the Hopi Tribal Council and has delegated authority to develop land policy, to explore and administer the best and most favorable uses of our natural and water resources and to seek and purchase viable business and land opportunities. I would like to recognize the current Hopi Land Team members: Ms. Marilyn Masayesva from the village of Bacavi who's our Vice Chair, Denny Humetewa from the upper village of Moenkopi, Jack Harding, Jr. from the village of Kykotsmovi, John Polela from the village of First Mesa, Leon Carew from the village of Mishongovi, and Wayne Taylor, Jr. who is the Chairman of the Hopi Tribe. My name is Cedric Kuwaninvaya. I am from the great village of Sipaulovi and the Chairman for the Land Team here.

A fundamental principle consistently exercised by the Hopi Tribal Council is our innate responsibility to preserving our homeland as an act of inherent sovereignty. As the original inhabitants of the isolated desert terrain of our aboriginal lands in the Southwest, the Hopi Land Team has focused its efforts on the restoration of our aboriginal lands, to restore free access to shrines, culture and religious sites balanced with contemporary goals of economic development and tribal self-sufficiency. The Hopi Tribe will soon be transferring up to 420,264 acres of acquired lands into trust. Since the passage of the Hopi-Navajo Land Settlement Act in 1996, much thought and planning has taken place to select fee, state and U.S. Forest, BLM lands that lie within our aboriginal lands. Although these lands do not encompass the original extent of our aboriginal lands, the acquisition of these lands symbolically replenish lost lands and more importantly regain our inherent land stewardship responsibility handed down since time immemorial. Moreover, these acts of the Hopi Tribe strategically lay the path to search new opportunities for economic development and to build a promising future for the Hopi people.

The purchase of lands is balanced with the purchases of business concerns such as commercial retail properties, a cattle-ranching business providing a product to the premium beef market, a bed-and-breakfast business, and a full truck stop serving the traveling public and commercial fleets off Interstate 40. Since the year 1998, these businesses have returned approximately three million dollars in profits to the general fund of the Hopi Tribe, which comprise approximately two percent of the annual general fund budget each year. The funds are then allocated to the Hopi villages for village projects such as elder and youth programs and to the Hopi tribal government for its operations. A comprehensive land management plan will govern the development of the newly acquired lands. The resources on these lands include hunting, fishing, boating, cattle grazing leases, recreation, power line rights of ways, management of cultural sites, a utility-scale wind energy farm and a potential utility-scale solar energy farm. These new economic development opportunities will generate revenue, create jobs, and enhance the portfolio of the Hopi Tribe.

The long-term goals of the Hopi Tribe and the plans to manage the development of the newly acquired lands and business concerns will be overseen by the Hopi Economic Development Corporation, a chartered corporation. In addition, our Wildlife Endowment Fund will provide the core funding for wildlife management on all Hopi lands. More importantly, as the picture shows, the most significant opportunity is the strengthening of the Hopi Tribe's ability to continue the practice of long-held religious, cultural and traditional practices. As the lands acquired formally aboriginal lands include eagle shrines, cultural sites, sacred trails, access to herbs, plants and wildlife used in our religious ceremonies. The future of the Hopi rests on its resources. Therefore the Land Team drives forward the concept that land is the foundation for Hopi beliefs and values and in the modern context an investment in the future. The growth and stability of the Hopi people rests on the proper activities of the Hopi tribal government and the Land Team serving as the enforcer for the tribe's responsibilities and vision. We remain committed to preserving our homeland and stand strong on the principle of preserving the good things of Hopi life and dealing with the modern problems with the United States government and with the outside world. [Hopi language]."

Alfreda Mitre:

"First of all, I want to say I'm very jealous of the Hopi Tribe's exclusive right to identify and select and purchase land and then have that land transferred into a trust status. Not many tribes have that opportunity. As a tribe, a small tribe in Nevada, we struggle very hard to acquire our traditional lands back so I want to first of all congratulate the Hopi Tribe and the team here for all of their work. Out in...throughout the United States you have tribes that are purchasing back their homelands and often are accused of ‘reservation shopping,' looking for convenient locations for economic development. Could you elaborate a little bit on how the selection of lands to be purchased or acquired are made?"

Cedric Kuwaninvaya:

"In Hopi, our elders have always told us where our lands had extended previously into the four western states and so with that knowledge when we were having a dispute with our neighboring tribe there, we had this dispute for over 100 years, and how we got acquisition of our lands back, we went to court and fought over this trying to get our aboriginal lands back. So through a congressional act we acquired...the Congress allowed us to get up to 500,000 acres that we could put into trust. So through the congressional mandate, that's what happened with our tribe. And once when we were given the authority to go out buying land, we looked at the land, what was on the land -- including water rights -- because we needed water to survive and look at that in terms of putting an investment into the future for our young people."

Alfreda Mitre:

"The next part of the question is, given that there aren't too many tribes that have the same opportunity that the Hopi's have, what advice would you have to tribes in terms, should this opportunity become available to them, what advice do you have for them?"

Cedric Kuwaninvaya:

"I guess the advice I have for them is make sure you know your culture, your traditions because everything hinges on that and the places where you're going to identify that maybe once identified to your people. Be aggressive, pursue it because we all know that the federal government took our lands away and because of treaties or other tribes that are under the IRS or IRA [Indian Reorganization Act], they owe us a lot so I would advise that the people in the tribes pursue it aggressively."

Elsie Meeks:

"I have a question for you. Congratulations on being one of the finalists and for the work you've done. What do you see as the next phase in this process? What are your next goals? Is it more land purchase, is it trying to get businesses profitable or what..."

Cedric Kuwaninvaya:

"Right now, we have a limit of acquiring up to 500,000 acres to put into trust so we're still going to be looking for lands cause it's still available to us. The other part is also looking at economic opportunities. Right now we have established an economic development corporation and all of the purchases that we've made will transition into that corporation, so they're the experts at doing business so that part will be transitioned. The other part is, yes, a lot of education needs to be done at our local level because all of these years we've had our lands taken away and the Hopi people have been stretched out, put a lot of money into trying to get our lands back, a lot of time and effort has been put into that. Now they need to feel relaxed and there needs to be a lot of educating at the local village level whereby we tell them, ‘Yes, we are gaining our aboriginal lands back and you can make use of it of how you made uses of them before, a long time ago.' There's still a lot of challenges and opportunities out there for the Hopi people."

Oren Lyons:

"The land dispute between Navajo and Hopi is an old one. What was it that made the breakthrough to work together? How did you do that?"

Cedric Kuwaninvaya:

"There's one that's called the 1882 Land Case. That one we went to Congress to settle. Then there's another one that's called the 1934 Case. That one has been in court for a lot of years, but I think what the tribes decided to do was rather than having the court settle it because the courts don't know how we live on Hopi, how the Navajos live their lives. We came together with the Navajo Tribe and said, ‘This is our land, these are our people, we know what's going on with our lives. We don't want the federal government or the courts to settle this.' So we came together and we...what happened from that was we had a compact on the different areas where the tribe goes into the other tribe's lands to get herbs or do religious activities there. So that's how this one came about and right now the Hopi Tribe has approved the 1934 compact and it's before the Navajo tribal council. So if they approve it then that's the end of our land disputes that we have."

David Gipp:

"Where is the bed-and-breakfast ranch that John Wayne used to own?"

Cedric Kuwaninvaya:

"That's located in Eager, by Springerville in Arizona. I understand John Wayne turned several times in his grave when he heard that the Indians had conquered his ranch."

Agreement Signed Between Navajo Nation & San Juan County Utah

Author
Year

Navajo Nation President Ben Shelly signed a groundbreaking agreement San Juan County Commissioners Tuesday morning. President Shelly and the commissioners entered into a memorandum of agreement focused on planning collaboration to develop land use recommendations for state and federal lands within San Juan County of Utah.

Native Nations
Resource Type
Citation

San Juan County, Utah, & Navajo Nation. (2012). Memorandum of Understanding. (https://www.roundriver.org/wp-content/uploads/pubs/navajo/..., accessed February 28, 2023)

Gitanyow Nation: Land Use Planning to Protect their Territories

Producer
National Centre for First Nations Governance
Year

Gitanyow citizens, a nation with a strong system of hereditary chiefs, talk about the impacts of development on their traditional lands and how their land use plan has helped protect their territories.

Native Nations
Citation

"Gitanyow Nation: Land Use Planning to Protect their Territories." Bear Image Productions. National Centre for First Nations Governance. Canada. Film. 2011. (https://www.youtube.com/watch?v=tTytpgFeofQ&feature=plcp, accessed May 16, 2023).

The Last Stand: the Quinault Indian Nation's Path to Sovereignty and the Case of Tribal Forestry

Year

This case tells a story of forestry management policies on the Quinault Reservation. In the early years, the Office of Indian Affairs (OIA) and later the Bureau of Indian Affairs (BIA) acted like a landlord, allocating large timber sales to non-Indian timber companies. The Dawes Act fragmented the Quinault Reservation into many small individually owned allotments: the Tribe retained little for the general purpose. Years of mismanagement of Reservation forest lands by the BIA left devastated lands and waters. Legislation and actions by leaders like Joe De La Cruz pushed the envelope to reform the U.S. tribal trust relationship, eventually returning land use decision-making to the Quinault Indian Nation. The Tribe took over planning, timber sales, and decision-making for forestry as they came to work in partnership with the BIA and neighboring agencies. The challenge was great--large areas of the landbase were cut-over. New decisions about forestry management were made to acquire allotted lands and to transfer them into the tribal ownership so they could be restored...

Native Nations
Citation

Stumpff, Linda Moon. "The Last Stand: the Quinault Indian Nation's Path to Sovereignty and the Case of Tribal Forestry." Enduring Legacies Native Cases Initiative, The Evergreen State College. Olympia, Washington. 2007. Teaching Case Study. (https://nativecases.evergreen.edu/collection/cases/last-stand-quinault, accessed February 12, 2024)