Solving Environmental Problems via Participatory Landscape Planning

Chapter 17 Solving Environmental Problems via Participatory Landscape Planning Emel BAYLAN INTRODUCTION Population growth, increase in land use demands, types of land use that do not consider the carrying capacity of the environment, consumption-oriented lifestyles, and intensifying agricultural and industrial activities have resulted in irreversible environmental degradations. Such environmental problems as habitat fragmentation, air, soil, and water pollution, and loss of biodiversity are some of the results of environmental degradations (von Haaren, 2002). Today, environmental problems have been felt at individual and societal levels. Due to the development efforts accelerated after the World War II, the negative consequences of industrialization appeared firstly in the “developed” countries which pioneered industrialization (Ünder, 1996). The current level of environmental problems threatens the vital benefits that nature provides to all living things, and also negatively affecting the quality of life (Daily, 1997; Carpenter et al., 2006). According to the United Nations Millennium Ecosystem Services Assessment (MEA) report, 15 of 24 ecosystem benefits are decreasing globally (MEA, 2005), and it is estimated that this could result adverse effects for humans and other living things in the future. As such, ecological processes and the landscapes in which these processes function to provide vital benefits to all living things must be protected for the present and future welfare of humans and all other living organisms (Carpenter et al., 2006; Cowling et al., 2008; Fisher et al., 2008; Brown et al., 2012). This state of ecosystem services and environmental problems have increased the awareness of researchers, bureaucrats, individuals, and communities regarding the environment and environmental issues compared to the years before 1990s in many countries (Schultz, 2002). Since the 1992 UN Earth Summit, which was based on the sustainability paradigm, the importance of the environment has been reflected in subsequent global and national policies and programs. Even in undeveloped and developing countries, people are interested in environmental issues in some instances considering protection of the environment more important than economic development (Dunlap et al., 2000; Schultz, 2002) which highlights the importance of individuals and stakeholders in a society for repairing and protecting the environment. Research and real-world experience have shown that is not possible to solve complex, multilateral environmental problems (due to their socio-cultural and economic dimensions) without fundamental structural changes to environmental policies and the associated decision-making processes (Bierle, 2002; Meadowcroft, 2002; Newig & Fritsch, 2009). It’s widely accepted by scientists, technocrats, and bureaucrats that a broader, holistic approach to decision making is needed to 241

Solving Environmental Problems via Participatory Landscape Planning  overcome and avoid environmental problems. Such an approach requires intensive cooperation and collaboration between different agencies, stakeholders, and governments to improve the quality of decision making via a process that is transparent and adaptable to changing conditions (Reed, 2008). These requirements have led the policy makers and planners to employ alternative approaches to the classical top-down decision-making and management methods in an effort to stem the tide of environmental degradation. As such, there has been a shift in environmental planning and decision making processes according to the sustainability paradigm and democracy demands (Eggenberger & Partidário, 2000). The growing emphasis since the late 1980s, on the link between the environment and democracy, and stakeholder participation in environmental management are based on the fact that decisions about the environment are not only scientific or technical but they are also political and social. Due to the complex and multidimensional characteristics—in terms of spatial and temporal scales—environmental problems simultaneously affect and emerge from the various activities of multiple stakeholders (Midlarsky, 1998; Meadowcroft, 2002; Newig & Fritsch, 2009). Stakeholder perspectives, priorities, and expectations concerning the environment and the approaches used to solve environmental problems vary according to the relationship between stakeholders and the landscapes or the environment in general. For example, while economic needs and objectives are privileged by local authorities, and local communities, environmental conservation and sustainability are the national and international priorities. The participation of various stakeholders in environmental decision-making and management has rich contributions in terms of experience, knowledge, competence and responsibility in environmental management (Newig & Fritsch, 2009). Therefore, inclusion of stakeholders that have different knowledge, values, interests and roles on the landscapes has been required during the decisionmaking and policy formulation processes on environment (Bierle, 2002). As such, public participation in decision-making on environment is one of the principles of international and legal legislations, particularly in the Aarhus Convention (UNECE, 1998). The multidimensional, complex nature of environmental problems require that their biophysical, socio-cultural, and economic dimensions and the interactions between them must be assessed and analyzed before land-use decisions are made. As for any planning process, for the future of land that has shaped by nature and man, sustainability has emerged and accepted as a main goal by a wide range of disciplines, policy areas and international institutions (Leitao & Ahern, 2002; Opdam et al., 2006; Belcáková, 2012). As such, “landscape” concept and landscape planning play a functional and inclusive role in the solution of existing environmental problems and the potential environmental risks. Landscape planning achieves these by the formulation of strategies and scenarios through analysis and assessment of the landscape structure and interactions between the components of the landscape system to produce a functional land-use plan based on sustainability (Roe, 2000; Leitao & Ahern, 2002). As a consequence of having the potential to provide multiple landscape services that are necessary to all living things, various land use demands reveal on landscapes due to the varying priorities, interests and expectations of different groups in the 242

Emel Baylan communities. As such, the foundations of multidimensional environmental problems and of the activities that may result degradation of landscape functions and conflicts between stakeholders are laid by land-use decisions (Pinto-Correia et al., 2006; Selman, 2009; Willemen et al., 2010). Ignorance of or token style inclusion of stakeholders in the planning processes for landscapes may result in stakeholder problems ranging from being unresponsive to environmental problems, oppositions to environmental targets and being on the side that threatens the sustainability and livability of landscapes in the long term (MEA, 2005; Roe, 2000; Fagerholm et al., 2013). Furthermore, decisions and associated implementations that neglect values, needs and expectations of local people and other stakeholders from the landscapes may damage the distinctive and unique local characteristics, meanings and values of the landscapes. All of these may also result disconnections between communities and their history (Antrop, 2005; Stephenson 2008). Therefore, during the environmental decision making it is required to consider and include the local and/or regional differences, expectations, interests and priorities of different groups as well as the attachments they have established with the landscape. Within this regard, the purpose of this chapter is to explain the role of participatory landscape planning on the basis of physical planning process with a focus on environment, landscape and landscape quality objectives concepts to adress the environmental problems. ENVIRONMENT and LANDSCAPE "Environment" is all the external conditions that affects and influences an organism or the surrounding that has formed by these conditions (Moran, 1986; Kocataş, 1994; Steiner, 2000). Due to the diversity of both all living and non-living components, natural and cultural cycles and the diversity of interactions between these, environment has a dynamic and complex character. As such, environment is regarded as a “system”. This system consists human, natural and cultural environment (Moran, 1986). In this dynamic system, the components and the cycles that form environment shape and alter the characteristics of each other and, the total characteristics of the environment. Past and present changes and, the current conditions of the natural environment reveal that the role of human in the interactions and alterations in the environment has been in a distinct status compared to the other factors in the system. Appearance of human in the living world, does not mean the introduction of any species into the ecological system. Different from other living things, human communities has led to significant permanent and devastating changes in the biosphere. Unlike from the other living things, due to having the ability to symbolize and through improving language, humans transform his experiences that have been gained through the interactions with nature and with the other human beings to knowledge. As such, cultural development history of humans and his environment have started by the accumulation of knowledge through experiences (Tekeli, 2000). Human beings do not only live in a physical space formed by natural environment but also live in a mental-conceptual space. During the psycho-social evolution process, human beings have created the conceptual space through perceptions, feelings, thoughts, beliefs, and values. As stated by Jantsh (1975), this

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Solving Environmental Problems via Participatory Landscape Planning  conceptual space is a place of cultural artifacts and values that range from mystical, philosophical, artistic and religious to scientific creation. With the tangible and intangible components, this place reflects the human beings’ and communities’ journey and the status for finding the meaning and purpose of life. As such, this conceptual socio-cultural place consists more than the quantitative features of physical space (Naveh & Liberman, 1990). In this socio-cultural conceptual dimension, humans assign importance and meanings to the environment that they are surrounded by according to the individual and societal needs such as identity and attachment. As such, physical environment has been transformed to “landscape” both through the human activities and, the symbols and meanings assigned to environment. These symbols and meanings that are filtered through value and belief systems in individuals and communities also reflect the human - environment relations (Greider and Garkovich 1994). According to these relations, in the combination and intersection of the spatial and temporal layers, landscape defined as a “natural and cultural palimpsest” by Steiner (2000). As defined in Art. 1 by European Landscape Convention (ELC) that is concerned to contribute to the sustainable development, the term landscape designates “an area, as perceived by people, whose character is the result of the action and interaction of natural and/or human factors’’ (Council of Europe (CE), 2000). By including perception that is shaped by beliefs, memories, values and interests of individuals and communities, this “landscape” term means more than a physical area and more than a scenery. According to the ELC, landscape is “an essential component of people’s surroundings, an expression of the diversity of their shared cultural and natural heritage, and a foundation of their identity’’ and “an important part of the quality of life for people everywhere: in urban areas and in the countryside, in degraded areas as well as in areas of high quality, in areas recognized as being of outstanding beauty as well as everyday areas” (EC, 2000). According to Noss & Scott (1997), most important factors that lead to environmental problems via degradation and impairment of ecological cycles and landscapes are the varying and conflicting land-use types and management approaches that are based on national, regional and local level land use decisions (Brody, 2003). As such, one of the leading processes that shape the land-use and related human activities is the spatial planning. In order to avoid and overcome the environmental problems in landscapes, landscape planning must be applied during the spatial planning. SPATIAL PLANNING and STAKEHOLDER DIMENSIONS in ENVIRONMENTAL PROBLEMS Planning, in general, may be described as a systematic preparation of future action to attain an objective best at certain frame condition. As a process that is oriented towards future, planning involves formulating future alternatives that are based on the use of scientific, technical and other organized information, knowledge and analysis of past and current conditions as well as impacts and conflicts. This continuous and objective oriented decision making process is also a political process which aims to meet the needs and interests of different stakeholders that hold power in varying degrees and, in different contexts and scales. As such, determinants of planning are; the current state and problems, conditions of the planning subject,

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Emel Baylan expected future conditions, related policy objectives, legal and administrative structure, conflict situations, consensus and the capacities of planning bodies and stakeholders (Friedman, 1993; Steiner, 2000; Ersoy, 2008). Physical/spatial policy and planning, social and economic planning are the main sectors of planning as stated by Ahern (1999) according to Fabos (1985). Among these four sectors, physical planning plays a particular role in environmental problems with regard to the short and long term environmental results and outputs of the spatial organizations for various land uses and demands of societies on landscapes. In order to meet these demands and needs within the different spatial scales and goals, rational comprehensive (synoptic, traditional; top-down; command-control) planning approach and, participatory (communicative; bottom-up) planning approach are the two of the main approaches in physical planning (Ersoy, 2008). Since the mid 1970s, with regard to the rational approach, planning was performed mainly as a technocratic procedure of solving problems, spatial organization of land use types, natural resources management and environmental planning. During this approach and the associated actions, centralism and depoliticized decision making processes and procedures have been the dominant in which technical experts and bureaucrats have been the rule maker and commander. Described as a top-down process in decision making and implementation of decisions, it has been assumed that it would be enough to have experts and bureaucrats involved in the formulation and achievement of the objectives for ensuring efficient management during rational planning. As such, there has been any or minimum public involvement during this kind of planning (Selin & Chavez, 1995; Innes & Booher, 2000; Healey, 2003 2006; Pissourios, 2014). The main characteristics of rational comprehensive planning are; rationality and comprehensiveness. According to rationality, in order to make the most rational decisions, the issues or problems have examined and addressed within the scope of systems view by using the conceptual or mathematical models that have been dominated by quantitative data and analysis (Hudson, 1979). In terms of comprehensiveness, it has been attempted to satisfy all goals of various interest groups with an assumption that demands and desires of all groups are common. In this approach, it has been accepted that the more comprehensive analysis of the problem results the better plan. The basics assumptions of rational planning are;  Clear objectives could be identified,  Full costs of alternative strategies could be identified,  Alternative strategies could be implemented,  Detailed monitoring of selected strategies is possible (Hudson 1979). However, scientific research and experiences have shown that the natural and cultural system is more complex, interrelated and ambiguous than it is considered (Chiras& Reganold 2010) and invalidates the above mentioned assumptions. Plans that have been developed through the centralized- top-down planning approach often ignores the environmental and social risks, the local values and the diversity of local conditions or unexpected and unusual circumstances that might occur in the landscapes. As a consequence, there have been failures to reflect and include the local conditions and knowledge and, the needs and expectations of stakeholders. These may result inadequacy in representation of stakeholders, particularly of the locals, and in 245

Solving Environmental Problems via Participatory Landscape Planning  the enhancement of plan decisions that might be more sensitive to sustainability of local natural and cultural domains. Lack of communication between the planners and subjects to the plans on conflicting concerns and expectations from the landscapes, and the deterioration of livelihoods as a result of environmental degradation have increased the distance between the planners and the associated interest groups in the landscapes. Since this distance interrupts the dialogue, information sharing and negotiation between the interest groups, it cause disputes (Luz, 2000; Lachapelle et al., 2003; Peterson et al., 2003; Pahl-Wostl, 2009). As a result of the above mentioned weaknesses, it has been widely accepted that rational –top-down- approach is an unsatisfying approach to deal with the challenges of present and future environmental problems as well as to deal with the demands for democracy, equality and sustainability (Selin & Chavez, 1995, Wondolleck & Yafee, 2000; Gleick, 2003; Giordana et al., 2007; Pahl-Wostl et al., 2009). As such, in order to meet the diverse and complex ecological, social, democratic and, economic needs and demands, deliberative and participatory decision making processes that involve the wide-range of landscape stakeholders, especially those that may be directly affected by the related decisions on the landscapes have been needed (Jones & Stenseke 2011). Therefore, in order to prevent and eliminate the environmental problems and to meet the societies’ needs, the local environmental and social conditions and risks should be taken into account during the spatial planning process. As such, the top-down -rational - planning and decision making approach that was dominating the environmental management until the early 1980s has begun to be replaced by the communicative –participatory- planning approach, especially since the late 1990s by the global impact of the Brundtland Report (1987) and the 1992 Earth Summit. According to Friedmann (1993), if a good dialogue established between planners and those who are subject to the plan and, if focused to eliminate the causes instead the impacts of the problem, the planning could be transformed to a process that is capable of responding to the needs and problems through experience and social learning. This approach has been related with Habermas’s the Theory of Communicative Action by many researchers. Habermasian theory examines and criticizes the concept of rationality to provide alternative forms of rationality and focuses on discursive communities to shape their futures through intersubjective and democratic communicative practice (Allmendinger & Tewdwr-Jones, 2002, Allmendinger, 2005; Innes & Booher, 2010). Forester (1989) has adapted Habermas’s theory into the planning and emphasized the importance of communication and consensus that are based on comprehensive, objective and subjective truth and correctness in the planning process (Schroth, 2010). As such, plans, defined decisions and associated strategies must be the results and the outcomes of this communicative process between multiple stakeholders. In this context, the only communication should not be through "plan" after “the planning" phase has completed. But rather, planning should be a process that planners and other parties are in dialogue and a shared working process from the beginning until the completion stage of the plan (Friedman 1993; Innes & Booher, 2000, 2010; Healey, 2003, 2006; Luz, 2000; Allmendinger & Tewdwr-Jones, 2002; Allmendinger, 2005). As such, the communicative-participatory- planning approach characterised by; 246

Emel Baylan  an interactive and interpretative process between planners and the stakeholders affected by plans,  diverse stakeholders and participants with their varying interests,  participants that are encouraged to find ways of practically achieving their planning desires,  interpersonal and intercultural dialogue that provides interaction and mutual learning,  incorporating traditional knowledge,  focusing on the challenging issues via various participatory platforms and techniques where problems, strategies, and values are identified, discussed, evaluated and conflicts are mediated,  development of stakeholders’ and organizations’ reflective and evaluation capacity,  encouragement of partnership building to change the existing conditions (Friedman, 1993; Innes & Booher, 2000, 2010; Healey, 2003; 2006; Luz, 2000; Allmendinger & Tewdwr-Jones, 2002; Allmendinger, 2005). Within this approach, planners, scientists, experts and bureaucrats are assumed as one of the actors of the planning and management processes, instead of being the only actor of the processes. As a result, there has been a shift in the role of planners and managers from the ruler and expert towards the mediator and negotiator in environmental decision making and management (Wondolleck & Yaffee, 2000). In connection with these developments, communicative- participatory- approaches and techniques have also come into practice in the decision making and management for landscapes. As such, participatory landscape planning is an important operational tool to guide the environmental and natural resource management and so, to solve the environmental problems. LANDSCAPE PLANNING’S CONTRIBUTION to SUSTAINABLE ENVIRONMENT THROUGH PARTICIPATION and FORMULATION of LANDSCAPE QUALITY OBJECTIVES

According to von Haaren (2002) “modern landscape planning is the process of understanding and directing the changing relationship between human kind and nature” with the goal that “the landscape represents its multi-functionality, that it provides and preserves the conditions for the great variety of needs for both human and non-human life”. This is a complex and multi-dimensional process defined briefly as a "strong forward looking action to enhance, restore or create landscapes” in ELC (CE 2000). During landscape planning, existing bio-physical and socio-cultural structures and capacities should be explored and assessed in terms of sustainability to understand the relationship between humans and nature in the subject landscape in order to inform the physical planning. To guide this relationship, landscape planning develops alternatives for land-use types, scenarios and technical solutions for the optimal and efficient organization of various land-uses in the spatial context through taking into consideration the ecological, socio-economic and cultural aspects of landscapes. As such, on one hand, landscape planning is a technocratic process dealing with the bio-physical and socio-cultural dimensions of landscapes and on the other hand, it should be a social process that transforms the knowledge on the bio247

Solving Environmental Problems via Participatory Landscape Planning  physical, socio-cultural and economic domains to action through creation –spatial planning and design- processes. Within this context, landscape planning should have a strong aspect that deals with communication between stakeholders to involve them into the decision making and implementation processes (von Haaren, 2002; Jones & Stenseke, 2011). Since 2000, the comprehensive definition of landscape in ELC and the overall context of the Convention promote innovative and integrated approaches in landscape planning, design and management at different scales ranging from national, regional and local. The emphasis given to “perception” and to the inclusion of stakeholders together with public authorities into the decision making processes about landscapes reveal that one of the basic principles and approaches of ELC is participation (Jones, 2007, Jones & Stenseke, 2011). Public participation means “to involve those who are affected by a decision in the decision-making process. It promotes sustainable decisions by providing participants with the information they need to be involved in a meaningful way, and it communicates to participants how their input affects the decision” (IAP2 2015). As such, participatory landscape planning is both a shared responsibility and joint action area of varying stakeholders and groups ranging from authorities, land owners, local people, farmers to visitors that have varying connections with the landscapes. As stated by Luz (2000), the information flow and exchange of opinions are from local people to planners –bottom-up- in contrast to top-down planning. This kind of communication and information sharing between stakeholders is one of the basic characteristics of participatory landscape planning. Participatory decision making process through procedures that allow communication, joint working, negotiation and consensus of stakeholders for the future of the subject landscape is another important characteristic of the participatory landscape planning. In the light of all of these characteristics, participatory landscape planning expresses a democratic process (EC, 2000; Jones & Stenseke, 2011) for sustainable landscapes. One of the guiding outputs of the participatory landscape planning process to address current and future environmental problems are the shared landscape quality objectives (LQOs) that are formulated through joint analysis, diagnosis, prognosis and syntheresis phases of landscape planning. Phases of the landscape planning and the stakeholder participation during these phases are given in general context by Figure 1. According to ELC, LQOs are a full list of approved/recognized characteristics and aspirations that the local people and the other stakeholders look forward to and demand for in a specific landscape (CE, 2000; Luginbühl, 2006). Based on the sustainability of the landscapes, these objectives define the future conditions and characteristics of the subject landscape according to the current strengths, weaknesses, opportunities, threats as well as to the shared aspirations of stakeholders on the landscape. The defined qualities may express the desired future characteristics ranging from tangible to intangible such as cultural heritage, identity, visual qualities or characteristics about management structure or characteristics of landscape functions and services. During the formulation of LQOs and the formulation of the scenarios to achieve these objectives, besides bio-physical charateristics, socio-cultural and economic features of the subject landscape and stakeholders’ connections with the landscape 248

Figure 1: Landscape planning and stakeholder input through participation (adapted from Botequilha Leitão et al., 2006).

Emel Baylan

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Solving Environmental Problems via Participatory Landscape Planning  have to be investigated and defined. These investigations and definitions that are based on qualitative and quantitative analyses are used to understand the drivers, pressures, state, impacts and potentials on the landscapes and to understand the aspirations of public toward the landscapes. Aspirations of landscape stakeholders are shaped by and vary according to the benefits they supply from the landscapes, individual and societal needs, problems and also according to the assigned importance and meanings to the landscapes (Oliveira & Dineboska, 2004; Stewart et al., 2004; Oñate & Peco, 2005; Luginbühl, 2006). As such, the refined landscape definition and participatory approach of ELC, require detailed information on the perceptions, feelings, values and other associations of stakeholders with the landscapes. These requirements direct the landscape planners to indepth and interactive investigations and, joint working with stakeholders during the planning and management through participatory tools. Therefore, participatory landscape planning should be a joint working and joint decision making process of key landscape stakeholders from Focus to Syntheresis phases. The goal of participation may range from informing to consultation to active involvement and often a combination of these three levels of participation in different phases of landscape planning. Participatory platforms, techniques and tools are necessary to apply during the different phases of landscape planning and management in order to achieve and facilitate the stakeholder participation as well as to establish a good dialogue among planners and the key stakeholders. These procedures and tools should be functional and facilitative in transferring the local knowledge and stakeholders’ opinions, perceptions and evaluations into the visual and spatial forms of information (Brown 2005, 2009). Some of the platforms, procedures and tools that may contribute and facilitate the communication and collaboration between stakeholders and landscape planners to perform a participatory landscape planning process are given in Table 1. CONCLUSION Intensifying environmental problems force the affected parties, science and practices to make shifts in environmental management and connected decision making approaches. Although the evident benefits of rationalism and associated top-down management process, there are also significant need and reasons for participatory approaches in environmental decision-making. Promoted by sustainability paradigm and democracy demands, there are many successful cases for participatory environmental decision making at different spatial scales in the different countries. However, there is not a consensus or a widely accepted approach and procedure to solve the continuously increasing environmental problems and disputes between stakeholders. While, landscape planning provides a strategic basis for sustainability and for addressing environmental problems, participatory landscape planning is a rather new topic and approach in environmental issues and disputes. There are still legislative, institutional, individual and societal capacity gaps for participatory landscape planning. Most regulations and incentives related to the environment and landscapes are still defined in central administration, at national level, without the flexibility to adapt to the changing local circumstances.

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Emel Baylan Table 1: The platforms, procedures and tools for participatory landscape planning and management Participation platform/ tool/ technique Landscape planning phase Action planning Syntheresis Analysis of emotional history Analysis Analysis of perceptions Analysis Analysis of values/ emotions attached to landscape Analysis Asking for feedback techniques F., An., Pr., Synth. Brainstorming Focus, Prognosis Citizen juries Prognosis Conflict analysis and management tools Di., Pr., Synth. Consensus approaches Prognosis, Syntheresis Consultative meetings, commitees Focus, Analysis, Prognosis Community think tank, citizen juries Syntheresis Cost/Benefit Analysis Diagnosis, Prognosis Delphi Technique Analysis, Diagnosis Design exercises Prognosis Focus group meetings Focus, Analysis Interactive display Analysis, Diagnosis, Prognosis Internet: tele-voting, e-discussion forums Focus, Analysis, Prognosis Joint site & problem analysis with local people Focus, Analysis Matrix scoring and ranking Diagnosis, Prognosis Mediation/negotiation Prognosis, Syntheresis Multi-voting; Priority dots Analysis, Prognosis Nominal group techniques F., An., Di., Prognosis Negotiation and consensus building Prognosis, Syntheresis Participatory (P) mapping, P. Geographic Information Focus, Analysis System (PGIS) applications Photo visioning Prognosis Polling Analysis, Prognosis Round tables Focus, Analysis, Prognosis Ranking exercise/preference ranking Analysis, Diagnosis, Prognosis Sense of place analysis Analysis Stakeholder assessments Analysis, Diagnosis SWOT Focus, Analysis Town hall meetings, village meetings Focus, Analysis, Prognosis Visualization; Modelling, Visual preference surveys Analysis, Prognosis Workshop(s): planning day; planning weekend Focus, Analysis, Prognosis Focus: F., Analysis: An., Diagnosis: Di., Prognosis: Pr., Syntheresis: Synth.

Although the participatory practices are rather new and, need more time and more effort when compared to the top-down interventions, they are innovative and promising for the complex environmental issues through sharing the ownership and responsibility of problems and the landscapes. In the light of these, participatory approaches and techniques should be encouraged and promoted by national and local level legislations on environment and landscapes. As such, due to the evident power of top-down management, participatory landscape planning approach should be integrated into the legislations on national and 251

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