Tag Archives: COVID-19

The Pandemic, the Arctic and Me: A Levels of Analysis Discussion of Arctic Security Focusing on the 2020 Global Pandemic

The Covid-19 pandemic hit the world during the winter 2020. Still on-going, it impacts everyone’s everyday life on a great scale. The present paper was written in the fall 2020. Therefore, it must be noted that some facts related to the pandemic at that time may have evolved. It aims to provide an international relations based analysis of the pandemic in the Arctic, using the author’s personal experience as a starting point of a broad and objective analysis in order to identify and discuss major stakes of the pandemic as well as the opportunities it provides. Hereinafter, the author will provide a subjective point of view in order to bridge the level of analysis and to embed herself into the very structure of world politics being studied. The individual will be considered, in the following argumentation, as a stakeholder as well as an analytical level of importance. This is particularly relevant in the Arctic where, due to small-scale populations, individual contributions to governance and historical influence are visible. For these reasons, the author will provide a strictly subjective point of view in the introduction.

Introduction – IR, the Arctic and Me… and Covid-19

I discovered the Arctic, as a topic of research, during my last year of undergraduate studies. My international law professor at that time had prepared a special issue on the topic of the legal status of the Arctic. This gave me passion for both international law and the Arctic. Since then, I have managed to focus, at every occasion I could, on Arctic (or Antarctic) related topics for my research, until I decided to expand my knowledge to the daily and cultural side of the Arctic by coming to Iceland. While the academic year 2019-2020, as a student of the Polar Law program of the University of Akureyri, was such an achievement, it was also greatly disrupted due to the SARS-CoV-2 pandemic (hereinafter the Covid-19 pandemic).

The World Health Organization (WHO) defines a pandemic as “a worldwide spread of a new disease. An influenza pandemic occurs when a new influenza virus emerges and spreads around the world, and most people do not have immunity”.[1] Moreover, “viruses that have caused past pandemics typically originated from animal influenza viruses”.[2] The Covid-19 virus fulfils these observations: suspected at first to have emerged as a consequence of the consumption of pangolin meat[3] in China, the virus primarily spread across the city of Wuhan, contaminated China and rapidly spread all over the world. As I followed the news from my own country, I do not recall any major concern about the discovery of a new disease in China in November last year. It became so as the virus spread across the world a lot faster than adequate responses could be adopted, thus becoming an apparent threat.

I live (I purposely use the present tense here as the pandemic is still on-going) the Covid-19 pandemic as a student – abroad. Therefore, I notice an important gap between the news I follow from my home country and what I actually experience living in Iceland. While the virus was spreading during the winter, I followed how the crisis was, at first, probably underestimated. In fact, on January 24, the Minister of Health at that time, relying on recent monitoring of the activity of the virus, announced that, at this moment, the then epidemic had little chance to reach Europe, yet carefully acknowledging that the situation could certainly evolve. The virus reached the country shortly after, hurrying the response that was converted into the extreme measure of lockdown.[4]

Iceland was certainly less impacted by Covid-19 than other European countries,[5] at least during the ‘first wave’. Thus, measures taken by Iceland to avoid the spread the virus across the country were less restrictive than responses adopted elsewhere. Per se, while other countries had pronounced a general, Iceland had closed facilities that were not considered necessary (swimming pools, gyms, bars and restaurants, etc.), imposed a physical distancing and proceeded to isolate cases tested positive as well as potential contact cases. As a matter of fact, living with the pandemic in Iceland was certainly very much different than in my home country. Furthermore, Iceland was taken as an example for how efficient its responses to the crisis were. However, it should not be forgotten that an island of approximately 350,000 inhabitants would respond differently to the crisis than an inland country of several million inhabitants. Nonetheless, Covid-19 measures created a great wave of unemployment in Iceland just before the tourism season was supposed to start. Facing the cancellation of bookings for accommodations or tours, I have seen some of my friends losing their jobs. I myself had a hard time getting a job for the summer, being a foreigner in a situation of general unemployment.

As a student, I saw my friends leaving Iceland in a hurry after the university had closed and before their own countries would shut their borders. I saw them making the choice of leaving Iceland to take the chance to get home. Being a student during the peak of the pandemic was also facing the change of the school schedules: a course was cancelled due to the impossibility for the professor to come to Iceland; the format of several assignments was modified; there were difficulties accessing a work place and satisfying documentation as both the university and the public library were closed, etc. I also discovered online education, which I was not used to. In this regard, the university responded immediately by providing satisfying materials and adapting the academic schedules despite the complexity of the situation. Perhaps such an efficient response was allowed by Iceland’s experience in remote teaching, culture of innovation and performing infrastructure.

Using the levels of analysis, this paper will discuss the unfolding impacts of, and responses to, the global pandemic in the Arctic. The author’s personal experience of the pandemic will hereinafter be analysed according to international relations principles. For this purpose, the paper will focus on the Scandinavian region in its broad spectrum (Iceland, Denmark, Norway, Sweden and Finland). Parallels will be made with other regions of the Arctic when deemed necessary for the argumentation. Applying the levels of analysis to the Scandinavian region aims to demonstrate how responses to the pandemic were adopted, taking into account the needs of the populations and groups of population, including indigenous peoples, and how international cooperation has and/or could implement further responses to a crisis that is not over yet (I). The author’s experience as a student will also be used as an occasion to examine the role of new technologies and the impact of the “cyber-sphere” during the Covid-19 crisis. Perhaps such analysis would lead to a better understanding of the trends and challenges the Arctic, as a region and a place of enhancing cooperation, will face in the near future (II). Concluding remarks will underline the uncertainty of this near future, not only in the Arctic but in the entire World, due to the global impact of the pandemic.

I. The Covid-19 Pandemic: a Level of Analysis applied to Scandinavia

While keeping in mind David Singer’s remarks on the accuracy of the levels of analysis method in international relations[6] and, for the purpose of analysing the effects of the Covid-19 pandemic on international relations in the Arctic, this method will be, hereinafter, applied to levels relevant to the Arctic; namely: the international level; the regional level; the national level; and the community level. The following comments will be organized according to the scope of institutionalism as Anne-Marie Slaughter defines it,[7] as such an approach corresponds to my own knowledge of international law. On the opposite, the view of realists, who “assume that all States possess some military capacity”,[8] does not suit the Arctic where interests have gone far beyond the unique game of hard powers.

1. The international level

At the international level, the main actor in the Covid-19 crisis is, without a doubt, the World Health Organization (WHO). As the international reference in terms of health matters, the WHO holds a major role in the international response to the crisis for several reasons.[9] Indeed, the WHO is at the heart of the action responding to the crisis caused by the pandemic, in conducting and organising the international response. It first organises and proceeds worldwide surveillance and monitoring of Covid-19 related matters. The WHO also published several sets of recommendations and guidelines for individuals, as well as for its members. For the purpose of the latter, the WHO has adopted a Covid-19 Strategic Preparedness and Response Plan[10] and created, for its implementation, a Covid-19 Solidarity Fund that has already collected more than 233 million dollars.[11] The WHO also ensures an equitable supply to its members’ health teams and participates to the training of health professionals. Furthermore, it shares Covid-19-related knowledge through its worldwide network of experts, and supports and sets priorities for scientific research, notably in order to develop a vaccine.[12]

However, the recent announcement of US President Trump’s intention to withdraw from WHO in the middle of the crisis is worrisome. Indeed, “the President had made his intention clear in late May, accusing the WHO of being under China’s control in the wake of the coronavirus pandemic”.[13] Therefore, the current tensions between the US and the People’s Republic of China could perhaps affect and interfere with WHO’s global effectiveness. The US being the main financial contributor to WHO,[14] such “funding shortfall would gut the WHO’s ability to respond to global emergencies – such as the current one – by reducing the resources for providing vaccines and tracing outbreaks”.[15] Even if the recent outcomes of the presidential election in the US may overturn the process of withdrawal, as “Joe Biden has pledged his support for the WHO”,[16] such threat certainly weakens the capacity of WHO to provide global and effective response to the current and future pandemics. Furthermore, the US being an Arctic State, this would also perhaps affect the Arctic.

2. The regional levels

Two actors are here particularly relevant concerning Scandinavia: Europe (i.e. the European Union and the European Economic Area (EEA)) and the Arctic Council. The European Centre for Disease Prevention and Control (ECDC), a specialized agency of the European Union, “is closely monitoring the outbreak and issuing regular epidemiological updates and risk assessment” of the Covid-19 pandemic in the EU/EEA, including the UK. The last Rapid Risk Assessment, published on August 10th, acknowledging that “the COVID-19 pandemic continues to pose a major public health threat to EU/EEA countries and the UK and to countries worldwide”[17] – especially since the relaxation or removal of several measures created a subsequent increase in Covid-19 cases[18] – suggests several options for response. As such, the ECDC advocates the elaboration of ‘strategic planning for different scenarios’; continuous and permanent ‘monitoring evaluation’; the elaboration of a ‘testing strategy’ based on, among other things, accessibility, efficiency and rapid contact tracing and quarantining; a rigorous ‘contact tracing’ so as to “promptly identify and manage contacts of Covid-19 cases in order to reduce the risk of them contributing to further onward transmission before they have been identified and quarantined”;[19] the promotion of ‘general measures’ such as hygiene measures, physical distancing and limiting gatherings, the use of face masks, teleworking, isolation and quarantine, protection of vulnerable populations, travel restriction, etc.; and the prevention through  continuous ‘risk communication’.

The Arctic Council is believed “well-positioned to play a leadership role in better understanding the impact of Covid-19 in the Arctic and spearheading activities to respond to the pandemic in the short-, medium- and longer-term”.[20] As “Covid-19 has reminded the world how vulnerable societies can be in the face of infectious diseases”[21] and given the rural nature and remoteness of communities in the Arctic, Sustainable Development Working Group (SDWG) overtook its responsibility in gathering the Senior Arctic Officials on May 7th for the purpose of establishing a plan for a response to the pandemic in the Arctic. Acknowledging that the pandemic “uniquely impacts the Arctic”[22] and “underscore[s] existing vulnerabilities”,[23] SDWG conducted an open and collaborative approach for the Arctic Council’s action, along with the Arctic Senior Officials, more than 50 experts, and 17 scholars.[24] Involving the input of all the Arctic States as well as the Permanent Participants, the report, produced in a very rapid time, focuses on the unique conditions and characteristics of the pandemic management in the Arctic, the direct and indirect impacts on Arctic communities, and identifies opportunities for action in the short-, medium- and longer term. As such, the report values international cooperation to support research and policy action; notices the necessity to ensure that Arctic people participate to fully respond to the needs of their communities (in this regard, the report also mentions the opportunity to take in account the value and the relevance of indigenous practices to respond to the pandemic);[25] gives a great importance to the impacts of fragile, substandard or absent physical or social infrastructures on the management of the pandemic in the Arctic; and promotes the information and data sharing, coordinated research and the involvement of locals and communities in these activities. The report generally insists on the importance of international cooperation as the pandemic is global and not specific to the Arctic. However, the report recalls the necessity to focus on characteristics specific to the Arctic in the response to the pandemic. As a matter of fact, the pandemic could be the opportunity for the Arctic Council to reaffirm its leadership in supporting the resilience of Arctic communities and of the Arctic environment in a broader sense. While failures in US public health policy, and some recent tensions in the Arctic Council over climate change, could create an Arctic Council-specific challenge associated with a pan-Arctic approach, the recent outcome of the US presidential elections allow to soften such concerns. Indeed, Joe Biden is likely to pursue efforts in continuity with the Obama administration, which was certainly committed into Arctic affairs.

3. The national level

As David Singer outlines, “as the nation-as-actor focus permits us to avoid the inaccurate homogenization which often flows from the systemic focus, it also may lead us into the opposite type of distortion – a marked exaggeration of the differences among our sub-systemic actors”.[26] In other words, an analysis comparing state actors’ behaviour could be biased. Therefore, this paragraph will solely mention how different Scandinavian countries responded to the crisis.

While Iceland did not proceed to a complete lockdown of the country, but instead imposed a rule of physical distancing and closed so-considered unnecessary facilities, Norway and Finland processed to a general lockdown of their territory. Sweden did not observe such strict rules. Statistics have shown Sweden’s strategy weaknesses while Norway, Denmark and Finland showed frustration and defiance towards their neighbour and did not open their borders to its citizens until recently. Iceland, congratulated by its management of the crisis abroad, fearing its economy, relying on tourism for its bigger part, would collapse, rapidly chose as a priority to attract tourists again (Icelandair advertisements, testing at the borders, no quarantine, etc.). As a result, Covid-19 made it back to Iceland and the complete and definitive opening of facilities, including schools, was continuously postponed. The current wave hits Iceland particularly hard, with an infection rate per capita among the highest of Europe.[27]

4. The community level

“Indigenous peoples of the Arctic have historically almost always been severely impacted by pandemics and have shown a higher mortality rate than communities further South”.[28] A recent survey of the Arctic Council collected testimonies of the impacts of the Covid-19 pandemic on several Arctic communities: Aleut, Athabaskan, Inuit, communities of the Russian Arctic, and Saami. In general, representatives of these communities recall the vulnerability of elder populations, already significantly affected by other diseases, the remoteness and the lack of infrastructures allowing testing and urgent health care, the importance of social gatherings for these communities and the subsequent isolation when these gatherings are either prohibited or impossible because of closed borders, and the local economic loss. For the Saami people, the impossibility to maintain their handcraft market and to hold festivals, conferences and seminars, has resulted in an important loss of income.[29] More specifically, according to a recent interview of Christina Henriksen, President of the Saami Council, “so, far, there have been few Covid-19 cases in the Saami area, except in Russia, and Norrbotten in Sweden. Thus, there is relatively little experience of the disease in Sápmi and we have yet to test the health service and infrastructure when put under pressure of an outbreak peak”.[30] Furthermore, even though the Saami people benefits, in theory, from an equal access to health services, the remoteness of some communities, the few infrastructures and medical equipment available, and the lack of Saami speaking health professionals, can weaken the response to the pandemic for the Saami people.[31]

As a more positive point, all indigenous representatives mention the satisfying effectiveness of the measures adopted and their participation in the elaboration of regional strategy through the Arctic Council, as well as the prevention allowed by better and faster communication. Concerning the Saami people, Christina Henriksen mentions that prevention campaigns and recommendations have been translated in several Saami languages and are available in national media, Saami media, as well as on the Saami Parliaments websites.[32] Moreover, indigenous representatives all greet the signs of resilience of their communities, especially in term of self-supply by traditional ways.[33] The reindeer husbandry in Northern Scandinavia was allowed to derogate to lockdown measures[34] and did not suffer from tourism this season.[35] As a matter of fact, national measures had both negative and positive impacts on the Saami people activities. Scandinavian countries, as land of the Saami people, adapted their measures to them, like the derogation to border controls demonstrates. In the same way, some initiatives use the Covid-19 pandemic as an opportunity to promote their culture, such as the International Sámi Film Institute that invited “Saami film makers to apply for a small grant to make short film about the Covid-19 situation”.[36]

II. The Covid-19 pandemic as an opportunity to enhance resilience in the Arctic

The report published after the Senior Arctic officials meeting insisted on the pandemic to be used as an “opportunity to explore, understand and support resilience of Arctic communities and of the Arctic environment”.[37] Two major remarks could be exposed in this regard: the successful use of new technologies as a way of maintaining communication and cooperation; and the major concerns about side-effects of the Covid-19 pandemic on Arctic populations, especially regarding mental health issues.

As a student, I directly experienced the use of cyber technologies during the first peak of the pandemic in the spring of 2020. The settlement of online teaching by the University was particularly efficient, as well as the quality of teaching materials. Such rapid and efficient response could come from the fact that Iceland has been using remote-teaching tools since a long time. The popularisation of online teaching before the pandemic surely contributed to speeding the transition and improving the outcome in the context of the pandemic. Indeed, professors were already using cyber tools in order to share their class with students abroad, such as in Greenland or in the Faroe Islands, or were recording their classes in order to provide the students a better availability and flexibility in their education. Therefore, the pandemic did not require from universities to settle new tools of teaching, they just had to generalize those they were already occasionally using. This positions Iceland as a leader in Arctic international education. Unfortunately, there is a great gap between Iceland and other countries in term of the use of these technologies. In my home country, the transition towards cyber teaching proved difficult, as the use of new technologies in education, especially online-teaching, is uncommon.

In the same way, some international events or conferences could be maintained through Zoom, such as the Arctic Science Summit Week 2020 that was scheduled to be held in Akureyri, Iceland, last winter, or the meeting of the Senior Arctic officials mentioned earlier. In this regard, Zoom and other online tools definitely keep Arctic cooperation on-going. Yet, this does not suit bigger events or cultural demonstrations, such as the Saami festivals or the Arctic Circle that has recently been cancelled. However, this shows great future opportunities for Arctic cooperation and Arctic culture sharing.

Another opportunity of understanding and enhancing Arctic resilience could be found in longer-term impacts of the Covid-19 crisis. As such, the impact of the pandemic on mental health issues, particularly affecting Arctic indigenous communities, constitutes a major concern for the Arctic Council. Per se, the Inuit Circumpolar Council recently recalled “suicide was a pandemic in the Arctic before covid-19 came along and after is dealt with, suicide prevention will remain a priority for ICC and other Arctic Indigenous peoples”.[38] In other words, “as the current pandemic evolves, the focus on the health effects of the coronavirus widens. While nations around the globe implement strict measures to flatten the curve of infections, concerns are rising that the virus and the measures taken to combat it, will cause long-term mental health issues”.[39] While this is not a concern particular to the Arctic since lockdown has already proved to have certain negative effects on some groups of people, especially of particular needs, mental health issues were already a great concern in the Arctic. These impacts are not to be neglected, as “the economic consequences of lost wages and rising debt, or social effects of being isolated from family, friends, and other important contacts”[40] could particularly affect Indigenous communities. They “may result in depression, anxiety and possibly enhanced suicidal risk in vulnerable populations”.[41] Therefore, according to SDWG, “in the months and years after the pandemic, a holistic approach to mental health and suicide prevention will be key”.[42] As an example of these dramatic effects, a survey conducted in Akureyri by Dr. Sveinbjarnardottir showed:

“‘We have now the first results and they are devastating.’ Of the students that had answered the survey, 85 per cent agreed and totally agreed that they were experiencing anxiety because of covid-19. More than 70 per cent were experiencing depression symptoms, and 87 per cent stated that they were experiencing more stress that was affecting their educational performance”.[43]

As a conclusion to her research, Dr. Sveinbjarnardottir urgently recommends “the local governments to invest funds into mental health after we flattened the curve”.[44] Yet, there are certainly many ways to invest in mental health: as an interesting example, the increased embrace of online collaboration, such as Zoom meetings, could contribute to greater connectedness and improved mental health.


The level-of-analysis applied in this essay demonstrated how the Covid-19 pandemic impacted and continues to impact Arctic inhabitants. Whilst the Arctic shares global concerns with the rest of the World, some trends and challenges remain proper to the region. Per se, Indigenous peoples specificities, the remoteness of the region, the other health issues that are already to tackle in the region, its models of economy, but also the capacity it shows to respond to the crisis with an efficient regional cooperation as well as the involvement of Arctic communities and their own knowledge and practices, the resilience it shows, etc. All these elements surely participate to (re) affirm the “Arctic exceptionalism”. Accessibility, functioning of facilities, especially health structures, education and culture sharing, require the need of a permanent and continuous cooperation involving all Arctic actors to face the uncertainty of the near future.


[1] ‘WHO | What Is a Pandemic?’ (WHO) <http://www.who.int/csr/disease/swineflu/frequently_asked_questions/pandemic/en/> accessed 2 August 2020.

[2] Ibid.

[3] This allegation is currently being questioned. See David Quammen, ‘Did Pangolin Trafficking Cause the Coronavirus Pandemic?’ (The New Yorker) <https://www.newyorker.com/magazine/2020/08/31/did-pangolins-start-the-coronavirus-pandemic> accessed 27 October 2020.

[4] ‘Coronavirus : Agnès Buzyn a-t-elle sous-estimé le risque de propagation en France ?’ (Franceinfo, 9 March 2020) <https://www.francetvinfo.fr/replay-radio/le-vrai-du-faux/coronavirus-agnes-buzyn-a-t-elle-sous-estime-le-risque-de-propagation-en-france_3851495.html> accessed 27 October 2020.

[5] France has registered 141 919 confirmed cases and rate of 41,1 deaths per 100 000 inhabitants, while Iceland has registered 1802 confirmed cases for a rate of 2,83 deaths per 100 000 inhabitants. ‘Coronavirus Nombre de Cas Pour l’Europe | En Direct’ (Coronavirus Statistiques) <https://www.coronavirus-statistiques.com/stats-continent/coronavirus-nombre-de-cas-europe/> accessed 17 August 2020.

[6] J. David Singer, ‘The Level-of-Analysis Problem in International Relations’ (1961) 14 World Politics 77.

[7] Slaughter Anne-Marie and Hale Thomas, ‘International Relations, Principal Theories’ in Slaughter Anne-Marie and Hale Thomas, Max Planck Encyclopedia of Public International Law (Oxford University Press 2013) paras 8–13.

[8] Ibid 4.

[9] ‘Cinq raisons qui expliquent le rôle essentiel de l’OMS pour lutter contre le Covid-19’ (ONU Info, 9 April 2020) <https://news.un.org/fr/story/2020/04/1066332> accessed 2 August 2020.

[10] ‘Strategic Preparedness and Response Plan for the Novel Coronavirus’ (WHO) <https://www.who.int/publications-detail-redirect/strategic-preparedness-and-response-plan-for-the-new-coronavirus> accessed 17 August 2020.

[11] ‘Fonds de réponse solidaire à la COVID-19 pour l’OMS’ <https://covid19responsefund.org/fr/> accessed 17 August 2020.

[12] ‘Cinq raisons qui expliquent le rôle essentiel de l’OMS pour lutter contre le Covid-19’ (n 9).

[13] ‘Coronavirus: Trump Moves to Pull US out of World Health Organization’ BBC News (7 July 2020) <https://www.bbc.com/news/world-us-canada-53327906> accessed 12 October 2020.

[14] ‘The United States of American and the World Health Organization: Partners in Global Health’ (WHO) <https://www.who.int/about/funding/contributors/usa> accessed 27 October 2020.

[15] ‘Here’s What We’ll Lose If the U.S. Cuts Ties with the WHO’ (National Geographic) <https://www.nationalgeographic.com/science/2020/07/what-we-will-lose-if-united-states-cuts-ties-with-world-health-organization/> accessed 27 October 2020.

[16] Ibid.

[17] European Centre for Disease Prevention and Control, ‘Rapid Risk Assessment – Coronavirus Disease 2019 (COVID-19) in the EU/EEA and the UK – Eleventh Update’ (2019) 1.

[18] ‘COVID-19 Pandemic’ (European Centre for Disease Prevention and Control) <https://www.ecdc.europa.eu/en/covid-19-pandemic> accessed 14 August 2020.

[19] European Centre for Disease Prevention and Control (n 17) 16.

[20] ‘Covid-19 in the Arctic: A Briefing Document for Senior Arctic Officials’ (Arctic Council) <https://arctic-council.org/en/news/covid-19-in-the-arctic-a-briefing-document-for-senior-arctic-officials/> accessed 17 August 2020.

[21] Ibid.

[22] Arctic Council, ‘Covid-19 in the Arctic’ (16 July 2020) <https://vimeo.com/438905383> accessed 17 August 2020.

[23] Ibid.

[24] Ibid.

[25] ‘The Impact of Covid-19 on Indigenous Peoples in the Arctic’ (Arctic Council) <https://arctic-council.org/en/news/the-impact-of-covid-19-on-indigenous-peoples-in-the-arctic/> accessed 17 August 2020.

[26] Singer (n 6) 83.

[27] ‘20201012-Weekly-Epi-Update-9.Pdf’ <https://www.who.int/docs/default-source/coronaviruse/situation-reports/20201012-weekly-epi-update-9.pdf> accessed 12 November 2020.

[28] ‘The Impact of Covid-19 on Indigenous Peoples in the Arctic’ (n 25).

[29] ‘The Impact of Covid-19 on Saami Communities’ (Arctic Council) <https://arctic-council.org/en/news/the-impact-of-covid-19-on-saami-communities/> accessed 14 August 2020.

[30] Ibid.

[31] Ibid.

[32] Ibid.

[33] ‘The Impact of Covid-19 on Indigenous Peoples in the Arctic’ (n 25).

[34] ‘The Impact of Covid-19 on Saami Communities’ (n 29).

[35] Ibid.

[36] Ibid.

[37] Arctic Council (n 22).

[38] ‘The Coronavirus in the Arctic: Spotlight on Mental Health’ (Arctic Council) <https://arctic-council.org/en/news/the-coronavirus-in-the-arctic-spotlight-on-mental-health/> accessed 2 August 2020.

[39] Ibid.

[40] Ibid.

[41] Ibid.

[42] Ibid.

[43] Ibid.

[44] Ibid.