Tallgrass Prairie Tallgrass Prairie National Preserve Legislative History, 1920-1996

Throughout the 1970s, Congressman Winn continued to champion a national prairie park in Kansas, while Kansans became increasingly divided on the prospect. In 1973, Winn introduced another bill for a 60,000-acre park, after which the Special Committee on Environmental Protection of the Kansas House of Representatives called a public hearing to listen to what Kansans had to say.[55] At the August 30th hearing, the Kansas Livestock Association, the Kansas Farm Bureau, and the Kansas Association of Conservation Districts lined up with the KGA to oppose a large prairie park. The KGA also offered a counter suggestion that the federal government transfer land from the Fort Riley Military Reservation and around several Corps of Engineers reservoirs to the NPS for park purposes. The Kansas Association of Commerce and Industry, Kansas Association of Garden Clubs, and Kansas City Junior Leagues lined up with STP in favor of a large park. Speaking on behalf of the STP, Patricia Duncan announced that the group had identified a suitable 60,000-acre tract south of Emporia. Clif Barron and the Kansas Park and Recreation Authority endorsed the prairie parkway concept. And the Kansas Hotel and Motel Association went on record in favor of a large park developed similar to Disneyland.[56]

The Special Committee on Environmental Protection, which was charged with recommending a position that the Kansas Legislature could support to the congressional delegation, debated its options for two months trying to find consensus. When it finally reported back to the legislature in late October, it recommended a cautious position stating that "should the federal government choose to preserve [the natural] heritage" of the Flint Hills, "full consideration should be given to the possibility of utilizing the Ft. Riley federal enclave and other federal lands to accomplish these purposes." The committee also recommended that the Kansas Legislature "reserve further consideration of a tall grass prairie park until after completion of a feasibility study by the U.S. Park Service." [57]

Larry Winn remained the sole member of the Kansas congressional delegation supporting a tallgrass prairie park. Despite lack of support from other members of the delegation, Winn continued the campaign. His determination did not spring from "extreme" environmentalism, though. Rather, he just believed that the Flint Hills "was some of the most beautiful land in the country" and that Kansans "ought to do something to put it into some kind of park or preserve." [58] After learning that the Department of the Army had virtually no land at Fort Riley that it was willing to give up, Winn suggested to park proponents that private entities begin buying land in the Flint Hills for eventual transfer to the NPS.[59]

As 1973 drew to a close, six members of the congressional delegation did come together to support yet another feasibility study by the NPS. Secretary of the Interior Rogers C.B. Morton agreed to another study at the request of Senators Pearson and Dole and Congressman Winn, joined by Rep. Garner E. Shriver [R], Rep. Keith G. Sebelius [R], and Rep. Bill Roy [D]. Congressman Joe Skubitz, still the ranking Republican member of the National Park Subcommittee of the House Interior and Insular Affairs Committee, did not join in the request. In yielding to the request, Secretary Morton warned that any proposal for a prairie national park in Kansas "would remain dormant until Kansans ended their division and presented a united front...." [60]

Both sides continued posturing while Winn's bill remained stalled in committee. In the Kansas Legislature the issue headed toward polarization. To counter the proposed concurrent resolution sought by the Special Committee on Environmental Protection, Kansas State Senator Frank Gaines [D- Augusta] introduced a resolution early in 1974 requesting that Congress reject any bill to establish a tallgrass prairie park in the Flint Hills. In so doing, he defended ranchers in his Flint Hills district, who were "do[ing] a better job of keeping [the prairie] up than the federal government could." [61] Gaines's proposed resolution directly opposed the recommendation of the Special Committee on Environmental Protection, which essentially requested that the state legislature adopt a wait-and-see approach until the NPS had finished a new feasibility study.

Save the Tallgrass Prairie, Inc. monitored developments in the state legislature. It also mobilized a petition drive among college students to press for passage of H.R. 8726, Winn's consolidated bill, which was referred to the House Committee on Interior and Insular Affairs. In April 1974, a group of students, representing various colleges and universities in Kansas, staged a much- publicized caravan to Washington, D.C. where they presented signed petitions, reportedly bearing 18,000-25,000 signatures, to Rep. Winn. Douglas Wheeler, a deputy assistant secretary in the Department of the Interior, and Richard Curry, NPS associate director for legislation, were on hand for the presentation. [62] STP also attempted to generate stronger support among environmentalists by publicizing the threat that the energy crisis of the 1970s posed for the Flint Hills. Pointing to controversy surrounding the proposed Wolf Creek nuclear generating station, STP posited that a new electric power transmission corridor through the Flint Hills, which would be needed for this project, might be the first of many such corridors as private utility companies scrambled to meet projected energy consumption for the year 2000 and beyond. STP also "watched with alarm" as one Flint Hills rancher plowed up several thousand acres of land and planted it with fescue, a non-native species of grass.[63]

The Tallgrass Prairie Conference of 1974, held in Elmdale, Kansas, appeared to signal an easing of tensions between the two sides. Co-sponsored by STP, the Kansas Group of the Sierra Club, Burroughs Audubon Society, Citizens Environmental Council, and the Sierra Club Southern Plains Regional Conservation Committee, the two-day Elmdale Conference sounded a conciliatory note. Former Secretary of Interior Stewart Udall, a keynote speaker, received a much friendlier reception this time. For the press, Udall defended a 60,000-acre tallgrass prairie park in the Flint Hills to "fill the last gap in the nation's park system." He also noted that even though the park campaign was still alive, a "major obstacle" to passing legislation was a weak conservation movement in Kansas and lack of aggressive support from mainstream national conservation organizations.[64] Representatives of the Kansas Grassroots Association who attended the Elmdale Conference gave statements to the press maintaining their opposition but admitting that "things have been easing up on both sides when the two groups get together."[65] Even though both sides held their positions, the rhetoric began to soften. The event, which drew more than 300 people for a packed agenda of speakers, workshops, and field trips, appeared to lay the groundwork for negotiations leading to successful legislation. [66]

Any possible rapprochement was short-lived, however. In the spring of 1975 the Kansas Legislature passed, by substantial majorities in both houses, House Committee Resolution (HCR) 2013, authored by Rep. Robert Whittaker [R-Augusta]. HCR 2013, like the resolution introduced the previous year by Whittaker's counterpart in the Kansas Senate, Frank Gaines, requested that Congress reject any bill authorizing the establishment of a tallgrass prairie national park in the Flint Hills. The language amplified arguments routinely put forth by agricultural interests: the federal government already controlled "a vast amount of property in Kansas," a reference primarily to Fort Riley Military Reservation and several multipurpose reservoirs administered by the Corps of Engineers; a national park would remove too much land from the property tax rolls, seriously hampering school financing; and "the loss of vast grazing areas in the grasslands" would impair Kansas beef production in an "era of nationwide food shortages." [67]

The leadership of STP, which had been working the halls of the state capitol to defeat the measure, redoubled its efforts. The organization's media campaign had already succeeded in gaining a modest level of national attention through the pages of magazines and newspapers with large national circulations, such as Smithsonian Magazine and the Wall Street Journal. Now STP formed an honorary board of prominent men and women to help advance the cause. Chaired by Dr. Karl Menninger, the board included Stewart Udall; philanthropist Katherine Ordway, then active in preserving prairies throughout the Midwest; David Brower, president of Friends of the Earth and past president of the Sierra Club; Charles Callison, executive vice president of the National Audubon Society; Loren Eiseley, Professor of Anthropology at the University of Pennsylvania and author of The Immense Journey; and several other influential people in environmental affairs. [68]

The park proposal finally had the endorsement of nationally recognized names. With a new level of support, Rep. Winn reintroduced legislation in July 1975. This time he picked up bi-partisan co- sponsors, twenty-one in all, but none of them was from Kansas. Even so, the co-sponsors, who included Rep. Morris Udall [D-Arizona], Claude Pepper [D-Florida], Larry Pressler [R-South Dakota], Shirley Pettis [R-California], and Bella Abzug [D-New York], reflected the political spectrum. STP backed them up with petitions bearing more than 34,000 signatures.[69]

It was still not enough to overcome the opposition. Despite a pledge of "total support" from Michael McCloskey, executive director of the national Sierra Club, at the 1975 Elmdale conference, Rep. Winn told the assembled proponents that they were facing "a virtually impossible mission." [70] Winn was "not even slightly optimistic" that his bill would pass. In an open letter to park proponents, he noted that the "action of the Kansas State Legislature in approving resolutions opposing the park dealt a virtual death blow to the proposal, which was already reeling under the impacts of Congressional delegation disunity." Winn also cited "an abundance of other park proposals before the Congress" and "growing opposition to big government and deficit spending" as additional obstacles. [71]

As 1975 came to a close, proponents and opponents were as divided as ever. Into this divide the NPS dropped the feasibility study that the Kansas congressional delegation, except Rep. Skubitz, had requested two years earlier. The 1975 preliminary environmental assessment contained an analysis of seven areas in the Flint Hills, all of them by now fairly familiar to residents of eastern Kansas and northeastern Oklahoma: Pottawatomie, Elk, Chase North, Chase South, Wabaunsee East, Wabaunsee West, and Osage. The NPS advised that three areas met the criteria for "nationally significant" tallgrass prairie areas?Wabaunsee West, Chase South, and Osage?and recommended them for further study. [72] Considering the audience to whom the document was addressed, the NPS stressed that the purpose of the information was "to aid decisionmakers in determining whether?and if so how best?to preserve a segment of the tallgrass-prairie region," and further, that the "final decision" would be made by the "the Administration, the Congress, and the public...."[73]

To aid in that process, the NPS laid out four different land acquisition and management concepts in the 1975 assessment. All of them had been discussed before, and repeatedly, but the report presented them side-by-side as viable alternatives without advocating any as better or more desirable. One was the "traditional" park concept whereby the federal government would acquire a large area of land and administer it solely. Another was the Cherokee Strip concept, whereby NPS would acquire and preserve a "core" of "pure parkland." This would be surrounded by a zone where "compatible agricultural uses" would be allowed to continue but where "incompatible uses" would be prohibited. The third concept was to protect the prairie "landscape" by acquiring scenic easements or by other less-than-fee agreements. This was the Clif Barron concept. The fourth concept was simply the "no action" alternative required under the guidelines and regulations implementing the 1969 National Environmental Policy Act.[74]

Elsewhere in the 1975 assessment, NPS planners also slipped a fifth concept into the discussion: a Flint Hills Agricultural Reserve. Based on British national park constructs, the Flint Hills Agricultural Reserve idea envisioned regional management of privately owned land based on a "unified effort, beginning at county and state levels...." In promoting the regional management concept, the NPS stressed the distinctive cultural as well as natural history of the Flint Hills prairie landscape, ranking it as "truly unique" alongside "the beautiful New England townscapes, the stark Black Hills of South Dakota, and the majestic Quetico-Superior region of Minnesota and Ontario [Canada]."[75] For the first time, a prairie park study seriously considered the archaeology, history, sociology, and economics of the Flint Hills region, and suggested a land-management concept that could recognize as well as perpetuate regional culture.

The stalemate that developed in 1973-1974 continued for the remainder of the decade, the only noticeable change being that the field of opponents and proponents widened. Agricultural opposition groups now had the backing of a majority of Kansas state legislators, and park advocates attracted increasing support from mainstream conservation organizations. Rep. Winn reintroduced legislation in 1977 and 1979; both bills would have significantly expanded the size of the proposed park. They met the same fate as his previous attempts. By now, the controversy seemed to have acquired a life of its own.

Save the Tallgrass Prairie, Inc. carried on as the chief park advocacy group. To keep up momentum, STP produced or supported several media events and public information efforts. Patricia Duncan's photographic exhibition "The Tallgrass Prairie: An American Landscape," sponsored by the Smithsonian, opened in Kansas City in August 1976 before it began a two-year tour around the nation. To maximize publicity, the Tallgrass Prairie Foundation, a tax-exempt educational arm of STP, hosted the opening. Friends of the Earth president David Brower gave the keynote address. The new foundation, incorporated June 1976, also distributed information to members of the press who covered the 1976 Republican National Convention, held in Kansas City. [76]

In addition to maintaining a library of films and slide shows for presentation at schools, community groups, and public gatherings, STP continued to establish new chapters throughout Kansas, publish a quarterly newsletter, and gather petition signatures, which now totaled about 40,000. In November 1976, STP gained national publicity when one of its leaders, attorney Larry Wagner, debated the prairie park issue with Bill House, former president of the American Cattlemen's Association, on PBS's Robert MacNeil Report. STP subsequently distributed the 30-minute debate on video cassette. [77]

STP also pressed for completion of the preliminary environmental assessment that had been issued by the NPS in October 1975. [78] Internal briefing documents prepared for Sen. James Pearson reveal that the assessment had been "halted mid-stream... as a result of the extreme anti-park pressure of Congressman Skubitz." As of early 1977 the unfinished study was "dormant due to a lack of funds" and the NPS predicted that "unless there was a significant influx of pro-park political pressure, either from Congress or the Administration," the study would remain in limbo. [79]

If there was encouraging news for park proponents in 1977 it was that Congressman Skubitz planned to retire after completing his current term and that two conservation-minded members of the House had assumed key committee positions. Morris Udall now chaired the House Committee on Interior and Insular Affairs, and Phillip Burton [D-California] now chaired the Parks and Recreation Subcommittee under it. Additionally, in 1976 Congress had passed P.L. 94-565, which authorized the Secretary of the Interior to make in-lieu payments to local governments to offset the loss of tax revenue from public lands within their jurisdictions. Passage of this law invalidated one of the strongest arguments against a prairie park.[80] Friends of the Earth also gave the prairie park proposal more attention, listing it among the organization's top four priorities for inclusion in President Carter's national parks program. [81]

Rep. Winn kept the park proposal before Congress by reintroducing legislation in September 1977. Winn's latest bill, H.R. 9120, differed substantially from its predecessors. First, the bill identified specific park boundaries that expanded the Chase South study area to incorporate additional lands from which oil and natural gas were being extracted, a total of 187,000 acres located south of Emporia. The site-specific bill was a result of discussions between STP and Sierra Club lobbyist Linda Billings, who encouraged the group to study the areas covered in the 1975 NPS preliminary environmental assessment and arrive at its own conclusions. (Billings also promoted a national tallgrass prairie park in the Sierra Club Bulletin.) STP subsequently appointed Dr. E. Raymond Hall; Dr. Lloyd Hulbert, professor of ecology at Kansas State University; Dr. Dwight Platt, professor of biology at Bethel College in Newton, Kansas; and attorney Lawrence R. Wagner as the site-selection committee. [82] H.R. 9120 also stipulated that about 58 percent of the acreage would be designated as "park" and the remaining 42 percent as "preserve," where oil and natural gas production would be permitted to continue until the resources were exhausted. Additionally, the bill contained a provision that gave the Department of the Interior authority to allow ranching, farming, and cattle grazing to continue at its discretion. Winn's bill was backed by various environmental organizations, and a letter-writing campaign initiated by STP produced sixteen co-sponsors by November.[83]

Other key developments in 1977 included an announcement by Sen. James Pearson that he, too, would retire at the expiration of his term in 1978. STP urged him to introduce a companion bill in the Senate before he retired, but Pearson did not do so. The Department of the Interior, however, responding to shifts in administration politics, ranked the tallgrass prairie third on its priority list of nationally significant areas for possible inclusion in the national park system. Likewise, the Midwest Regional Advisory Committee to the NPS recommended that the agency advance its planning for a national prairie park.[84]

Throughout 1978 park advocates and opponents kept confronting one another. Representatives of the Kansas Grassroots Association challenged pro-park speakers at a prairie symposium held at Ottawa. Proponents and opponents debated at the Pittsburg Prairie Day. The Kansas Advisory Council on Environmental Education gave STP and KGA equal time for presentations at one of its meetings. KGA presented a slide show about cowboy lifestyles; STP countered with a slide show emphasizing that a tallgrass prairie park was a national concern. [85]

STP and the Tallgrass Prairie Foundation likewise continued their media and educational campaigns. The Foundation produced a scenic route map of the Flint Hills and sponsored a bus tour of the Chase South site. STP worked to get publicity out through mass circulation magazines, including Time and National Geographic, and through children's publications such as My Weekly Reader and the National Wildlife Federation's Ranger Rick magazine. Patricia Duncan was interviewed by the CBS radio affiliate in Chicago, station WIND. She also published Tallgrass Prairie: The Inland Sea and donated a share of the profit to STP. All of these activities, plus the usual lobbying trips to Washington, D.C., were designed to keep up the pressure on Congress to hold hearings on H.R. 9120, which STP considered "its" bill.[86]

Rep. Winn introduced his last tallgrass prairie bill in 1979. H.R. 5592, co-sponsored by Morris Udall, was the result of deliberations initiated in November 1978 when STP and a loose coalition of mainstream conservation groups formed a working group for the purpose of crafting legislative guidelines. The NPS followed developments closely, but from a distance. Although Winn and Udall did not introduce their bill until October of 1979, the basic framework was in place by January. Working with STP to prepare draft legislation were the NPCA, the National Audubon Society, the Sierra Club, Friends of the Earth, the Wilderness Society, and the Izaak Walton League. The coalition's concept borrowed from the NPS's 1965 tourway-parkway proposal. It also echoed the "agricultural reserve" idea outlined in the 1975 preliminary environmental assessment whereby the federal government, instead of acquiring entire parks through purchase or condemnation, would enter into cooperative agreements with state and local governments as well as private citizens in order to preserve large areas of national concern. [87]

H.R. 5592 set out three "core-park units" in the Flint Hills?Wabaunsee, Chase South, and Osage?each surrounded by an intermediate prairie perimeter, or "preserve," with all three linked by interconnecting "parkways" to an outer perimeter "reserve" area. The whole conceivably could encompass as much as 3.5 million acres of the Flint Hills in Kansas and Oklahoma. A fifteen-member commission would oversee the "reserve" and "through cooperation would seek to integrate local governmental activity by land use planning into a positive force for the protection of prairie resources not immediate to the park-core(s)." The "preserves" and "parkways" would be "controlled by conservation easements to restrict timbering, quarrying, subdivision, plowing of virgin prairie, etc." The core-park units would be acquired by the federal government, or by an intermediary for the federal government, "on a willing seller-willing buyer basis."[88]

In discussions with the NPS, STP spokespersons estimated that it would take a minimum of fifty years before the core areas (approximately 300,000 acres) could be acquired. Conceivably, acquisition could take as much as 150 years based on various alternatives to condemnation that environmentalists were now willing to extend to landowners, the most generous being the right to transfer land ownership through immediate family members for an unlimited number of generations. In return for such concessions, STP and its coalition partners felt they were entitled to ask for a truly vast (2.5-3.5 million acres) "reserve" area.[89]

Because the environmental coalition's legislative guidelines incorporated provisions that the NPS was not inclined to accept, based on its park land-acquisition criteria and its land-management philosophy, NPS Director William Whalen requested that the Midwest Regional Office (MWR) formulate a counter set of recommendations.[90] After reviewing information from various conservation organizations and additional fieldwork by staff, the MWR regional director issued a memorandum in April 1979 recommending that the proposed park consist of approximately 100,000 acres, "all of which would be acquired in fee" and "subject to eminent domain" in order to achieve this objective. Rejecting the complex reserve-preserve-core unit concept as too costly and too difficult to manage, the MWR gave the Chase South area preference over the Osage area. If necessary, the MWR advised, the NPS could consider a "buffer zone averaging no more than three miles in width" in order to maintain scenic values, but it did not feel that such a zone was essential. As for a parkway, the MWR "no longer favored" this element.[91]

The April 1979 memo explained what the MWR understood to be a "basic conflict" between its position and "that of the conservationists." Whereas the environmental coalition groups were "seeking to preserve most of the remaining unplowed prairie in the Flint Hills," the MWR felt that "the appropriate role of the Federal Government should be limited to preserving a representative portion of the remaining prairie" that was "easily accessible to visitors" and "returned to its historic character... as quickly as possible." The MWR also considered the conservationists' proposal to restrict the federal government's use of eminent domain to be "unrealistic." Based on prior experience, the MWR anticipated that park opponents would not cease their opposition once legislation was passed. Instead, they would initially refuse to sell their land and then after a period of time "seek de-authorization on the grounds that the Service is simply not going to be able to do the job." [92]

When Winn and Udall introduced H.R. 5592 on October 15, 1979, it was based on the complex "reserve-preserve-core park" concept, which the MWR had rejected as unfeasible. [93] The Winn-Udall bill proposed three "reserves" or "special conservation areas" connected by a "prairie national parkway" between Marysville, Kansas, and Pawhuska, Oklahoma. Proposed as "reserves" were 73,000 acres in Wabaunsee County, 150,000 acres in the Chase South area along the Kansas Turnpike, and 151,000 acres in the Osage area along the Kansas-Oklahoma border. The "reserve" designation was key to the whole concept. It permitted federal purchase of land and scenic conservation easements only on a willing seller-willing buyer basis. No condemnation under eminent domain would be allowed. If and when private land went on the market, the Department of the Interior would have the right of first refusal at the landowner's offering price. If the federal government refused the offer, the landowner was free to sell it on the open market. This meant that it might, and probably would, take a long time for the Department of the Interior to acquire large units of land, but when that happened the NPS would be free to designate such units either as parks or preserves. [94]

The reserve concept represented a major concession to landowners in the Flint Hills. Winn and Udall called this "a necessary new approach...which recognizes the contributions of these private landowners...." The National Audubon Society pointed out that the "reserve" concept was "much more compatible with the interests of established ranchers." Save the Tallgrass Prairie called it an "innovative approach to land protection... that recognizes the significant contribution of the Flint Hills ranchers" and a "balanced approach between beef production, the major industry in the area, and land preservation...."[95]

Early in 1979, park proponents were optimistic that a compromise solution had been found. Conservation groups had reached agreement among themselves, and they had consulted with farmers, ranchers, and landowners "seeking their reactions" before the bill was introduced. Rep. Phillip Burton, chair of the Interior and Insular Affairs Subcommittee on Parks, was poised to move the bill forward in the House. Even though Robert Whittaker, the premier voice of opposition in the Kansas Legislature, had won election to the U.S. House of Representatives and landed a spot on the House Interior Committee, Rep. Winn did not consider him a serious threat to the bill's passage.[96]

After October 15th, however, optimism faded quickly. Della Wrae Blythe, secretary of the Kansas Grassroots Association, dismissed the concept as a ruse: "Preserve, reserve or whatever it's called, it's a park. We oppose a national park in Kansas." Rep. Whittaker "declared all-out war" in a press statement charging that the Flint Hills would either become an "uninhabited no-man's land" or a "tourist trap complete with curio shops and hot dog stands" if H.R. 5592 passed. [97] The immediate reaction from KGA and Whittaker was not unanticipated by Winn, but lack of support from other members of the Kansas congressional delegation once again doomed his bill. By the end of October, Reps. Jim Jeffries [R] and Keith Sebelius [R] had joined Whittaker in opposing H.R. 5592.[98] Rep. Dan Glickman [D] stated that he did not oppose the bill entirely, but listed enough reservations that it was clear he would not support it.[99] Senators Bob Dole and Nancy Kassebaum [R], who was elected to James Pearson's Senate vacated seat in 1978, also withheld support. They cited the proposed size, which had increased from 60,000 to 374,000 acres, and defended Flint Hills ranchers and farmers as "good stewards of the land." Dole and Kassebaum also expressed "serious reservations about the federal government accelerating...the trend from individual ownership," citing the Konza Prairie, purchased by the Nature Conservancy in 1977, and the Cimmaron National Grassland as examples. [100]

After Rep. Winn interviewed Secretary of the Interior James Watt on a radio-broadcast program in March of 1980, the Wichita Eagle-Beacon reported the "Prairie Park on Back Burner." Watt declared the Reagan administration to be "in the mainstream of the environmental movement" and stated that the Department of the Interior was asking Congress "for a moratorium on acquisitions."[101]

Rep. Whittaker welcomed Watt's remarks and told the press that the Reagan administration's position "should take care of the issue for a while...." [102] Winn conceded that although he had not given up on a prairie park completely, there was no longer any reason to reintroduce legislation "when we know that for the next four years the administration won't approve it."[103] A post-mortem offered by the Kansas City Times cited as reasons for failure an unwarranted optimism among conservationists when Rep. Joe Skubitz retired from Congress in 1978, the inability of Kansas environmentalists to present a united front, Rep. Phillip Burton's reluctance to hold hearings on the bill as long as Senators Dole and Kassebaum opposed it, and, behind all this, entrenched opposition from Flint Hills ranchers and farmers. [104]

Winn, who remained in Congress until January 1985, summed up the legislative efforts of the 1970s in much the same way. He consulted with the various park advocate groups involved in the effort, during which they weighed Secretary Watt's remarks, Reagan's approach to the economy, and the critical lack of support from other members of the Kansas congressional delegation. After a decade of trying, he decided that introducing further legislation was futile, and advocate groups decided not to press him.[105]