Moving from defence to offence: the judicialisation of the Alevi issue

7The Alevist movement emerged at the end of the 1980s in Turkey and initially mobilised forms of political action, including publications, public declarations, protests and petitions. It was only after a number of years that the movement turned to the law. However, the law was first used against the Alevis, who, at the beginning of the 1990s, were confronted with the administrative closure of organisations and lawsuits challenging the legality of their activities. It was thus in defence that the Alevist movement first got involved with the courts, which in turn revealed the existence of various legal opportunities. The Alevists consequently initiated a number of different legal cases, ultimately adding lawsuits to the movement’s action repertoire. This situation illustrates the “dual” use of the courts: while courts may bolster authoritarian states, they also create opportunities for activists to challenge state policies. [7] Although the authorities have wielded the law to preserve the status quo, Alevists have also tried to incorporate it as a tool to protest the current regime.

8The Alevist movement thus first found itself on the defensive with regard to the law. In fact, simply establishing an Alevi organisation was likely to provoke legal action: the 1983 law on associations prohibits founding an organisation whose activities are based on, or conducted in the name of, any region, race, social class, religion or faith, or which asserts the existence in Turkey of minorities based on racial, religious, denominational, cultural or linguistic differences. [8] Moreover, the Civil Code bars any organisation from registration if its purpose is “to support a particular political movement, race or denomination”. [9] Consequently, the majority of Alevi organisations avoid any explicit reference to Aleviness in their names and bylaws, instead choosing to express their affiliation indirectly or by allusion. Those organisations that dared to be more explicit ran the risk of being barred or facing lawsuits. The creation of the cultural foundation Semah, whose bylaws stipulate that it seeks to promote and disseminate Alevi culture, gave rise to a decade-long legal battle. [10] In the 1990s, the leaders of the most assertive Alevi organisations were prosecuted, receiving fines and sometimes even prison sentences for their public statements, the unauthorised meetings they held, the creation of organisations incompatible with the goals of the state, and even at times for “separatism”. [11] Here we see a legal arsenal and a court system working together to preserve state ideology. Consequently, the organisations or activities that challenged the regime’s ideological foundations, in particular the principles of unity and secularism, were frequently targeted by lawsuits [12] – as can be seen in the number of dissolution proceedings brought against anti-establishment political parties, in particular Kurdish nationalist, Islamist, and radical left-wing parties. [13] The law is thus largely wielded to control and sanction initiatives that challenge the national political project.

9The Alevists appealed, which led to the majority of the convictions against them being overturned. In their appeals, Alevi leaders played on their community’s uncertain status: since Aleviness was not recognised as a religion, the plaintiffs highlighted the cultural (and not religious), and thus legal, nature of the activities they conducted. Repeated appeals brought about changes in practice, especially in supreme courts. In 1999, after a lengthy trial, the Alevi-Bektashi Education Foundation (Alevi-Bektaşi Eğitim Vakfı) was authorised by the Court of Cassation (Yargıtay) to use the term “Alevi” in its name. The case brought against the Pir Sultan Abdal 2-July Foundation for Culture and Education in 1997 ultimately led to a conviction in 2000. But the Court of Cassation then ruled in the Foundation’s favour, stating that seeking to “serve Alevi philosophy” was not against the law. Likewise, at the end of 2001, the Afyon local court ruled for the dissolution of an association on account of its goal of founding a cemevi, a place where Alevi ceremonies take place. Referring to its 2000 decision, the Court of Cassation overturned this ruling because “an important part of our country’s population is Alevi, and the term cem refers to traditional Alevi meetings” – thus once again ignoring the religious dimension of Aleviness. The court thus concluded that organisations with the words cem or cemevi in their name should not be subject to legal proceedings. [14] However, this decision was not systematically implemented, since as early as the end of 2011 the Ankara prefecture ruled for the dissolution of an organisation, citing that it aimed to create a cemevi (see below). Numerous inconsistencies in jurisprudence can similarly be observed, especially with regard to tensions between the different levels of jurisdiction – a phenomenon that is not unique to the Alevi issue. [15]

10Such differences are not limited to legal decisions, but also occur within the institutional and political spheres. When establishing the position of various courts within the legal production line, we must take into account the aftermath of judicial decisions by examining their political impact, thus also considering the reaction of governments. Upon the creation in 2000 of the ABKB (Alevi-Bektaşi Kuruluşları Birliği Kültür Derneği – Cultural Association of the Union of Alevi-Bektashi Organisations), the Ministry of the Interior, consulted by the Ankara prefecture, ruled that the objective of “establishing cemevi” and “facilitating cooperation between Alevi-Bektashi organisations” violated the law on associations. Following the organisation’s refusal to eliminate these objectives from its mission statement, it was dissolved by the civil court of first instance in 2002 for threatening the indivisible unity of the nation and the state. The Diyanet likewise ruled that associations looking to co-ordinate “Alevi-Bektashi organisations” or encouraging research on Alevi culture should not be authorised, as they would lead to separatism. Conversely, the Constitutional Court, the Council of State, and the Ministry of Culture all expressed their disapproval, the latter arguing that such organisations reflected the country’s cultural richness. The organisation appealed, still maintaining that Aleviness was not a religion. At the end of 2002, the Court of Cassation overturned the conviction by a narrow majority, arguing that an association could not be banned as long as it did not effectively promote activities specific to a religion or religious group. Following this ruling, the court of first instance modified its decision, also by a narrow majority.

11The existence of inconsistencies in case law reveals that legal recourse can be successful and that the possibility of “challenging the law” is real. [16] In this context, plaintiffs are not discouraged by a negative verdict, but instead diversify their legal options, addressing their appeals to multiple levels of authority both within and outside of the judicial system. This in turn reveals that the system is represented as a many-layered institution with diverse and possibly conflicting agendas, but also anchored in a broader political context. [17] Noting that such uncertainties could be viewed as opportunities, Alevist leaders slowly began to turn to the judicial system to achieve their ends. This process was reactive – to use the distinction established by Charles Tilly [18] – chosen to redress the grievances suffered from acts of discrimination or defamation, whose illegality could be established within the context of the principles of national unity and the equality of citizens. In February 1997, Alevist leaders took legal action against the Minister of Justice who belonged to the Islamist Prosperity Party for “overt incitement to hatred and enmity”, [19] because he had alluded to alleged Alevi ritual orgies. They likewise sought redress in October 1998 against the leader of the Islamist Virtue Party, who had described Syrian Alawites – who display a number of similarities with Alevis – as “deviants”. [20]

12While Alevist groups first used legal action to defend themselves, they gradually drew on the judicial system for more offensive ends, to obtain equal treatment, new rights, and possible legal recognition (especially for the exemption of Alevi students from religious culture and morality classes), in particular towards the end of the 1990s. First employed by the most pro-active groups, lawsuits were progressively adopted by other, more moderate organisations. In 2005, the CEM Foundation, [21] otherwise a rather legitimist organisation, launched a series of judicial appeals. On the one hand, it sent a petition to the Office of the Prime Minister signed by 2,000 people, asking for cemevi to be classified as places of worship, for part of the state’s budget to be attributed to Alevis, and for positions to be created in the Diyanet for Alevi religious leaders, in the name of the constitutional principle of religious freedom. Faced with rejection, on the grounds that Alevis were Muslims and thus already represented, the CEM Foundation summoned the Office of the Prime Minister to Ankara’s administrative court. [22] In 2008, this court unanimously rejected the plaintiffs’ case, finding that they had not proven the discrimination supposedly faced by Alevis, nor any violation of state neutrality with regard to religious matters. [23] Similarly, at the end of 2005, the CEM Foundation launched proceedings before the administrative court against the Ministry of Education, asking for the mandatory “religious culture and morality” classes to accommodate Alevi beliefs and include Alevi religious leaders in their preparation. The court unanimously rejected this petition, a decision confirmed in turn by the Council of State’s denial of the appeal.

13Not satisfied with simply bringing lawsuits, Alevist organisations also started to offer individual legal assistance, at times even encouraging individual legal action, as was the case with the CEM Foundation in 2005. Consequently, the Alevi-Bektashi Federation, the largest Alevist group in Turkey, encouraged parents to engage in litigation so that their children could be exempted from the mandatory “religious culture and morality” classes. Several individual lawsuits have been mounted in this regard since the 2000s, which have given rise to differing rulings in courts of first instance: while some agreed to exempt Alevi children (in Antalya, Ankara and Istanbul), others refused to do so (Istanbul). Some lawsuits begun by individuals were in turn monitored and supported, even brought about by organisations. Legal recourse was thus integrated into the Alevi action repertoire, [24] and became increasingly significant over the years. Ultimately, the treatment of a political problem was increasingly displaced to the legal/judicial sphere. [25]

14The timing of this process of judicialisation is noteworthy: it corresponds to a decline in Alevist mobilisation and an impasse in the thinking about how to deal politically with the Alevi issue – or at the very least, the belief that such thinking was possible. After a first enthusiastic phase, the movement experienced some fatigue, reinforced by the differences between organisations that erupted publicly. The Sivas event in 1993 [26] marked an important turning point: despite the ruling coalition’s rather favourable stance towards Alevis, not only were the deaths of 37 persons not avoided, but the treatment of the Alevi issue had not produced satisfactory results for the complainants. Even after the subsequent mass mobilisation, Alevi demands were barely taken up by politicians, if at all, due to political constraints. [27] The second half of the 1990s thus saw a decline in Alevi mobilisation and belief in the ability to find a political solution to the issue. From this perspective, judicialisation can also be seen as an Alevi tactic, since it did not require mass mobilisation at a point when the latter had proven to be ineffective and, in addition, was dwindling. [28] Moreover, it was during this same period of time, and perhaps for similar reasons, that Alevists began to engage in lobbying more regularly.

15The judicialisation of the Alevi issue also perhaps stemmed from the non-political, but exclusively legal, treatment the authorities reserved for the Sivas and Gazi attacks [29] even though the offence was in both cases political. As a result, both the Sivas and Gazi court cases triggered significant mobilisations, ultimately becoming “dayanışma davası”, or “solidarity cases” where numerous lawyers (600 for the Sivas case) participated pro bono, out of conviction and to defend a principle. By virtue of their large numbers, they thus sought to exercise pressure on the court and its ruling. [30] Beyond the judgment itself, the legal arena was used as a forum to define a public problem. [31] The increased visibility in turn engaged public opinion, sometimes finding allies in journalists or intellectuals. During this solidarity case, Alevist organisations contacted a number of lawyers, thus establishing exploitable connections and allowing for transfers of legal skills.

16The movement’s growing judicialisation to an extent continued its previous approach: in incorporating the law, Alevists continued to make demands legitimately, without breaking the rules of the game. In fact, this mobilisation was characterised by a fundamentally legitimist stance, for a number of reasons. On the one hand, in a unitary context where particularism is illegitimate and criminalised, the movement sought to obtain legitimacy by distancing itself from more overtly controversial actors, in particular Kurdish nationalists, to whom its identity-based claims might otherwise connect it. [32] The Alevi cause was thus mainly framed in terms of defending non-particularist, but universal values (equality, secularism, religious freedom, non-discrimination), which allowed the movement to obtain legitimacy as a champion of shared values, which were also the official values of the Republic. [33] Consequently, legal recourse was made possible by the existence of real contradictions between certain institutional practices and certain official principles such as religious freedom and egalitarianism. Such legal recourse thus consisted in advancing the cause “in the shadow of favourable legal norms and threats of judicial intervention”. [34] By turning to the law, the Alevist movement illustrated its wish not to overturn the legal system, but on the contrary to hold it to its promises. Finally, this stance is likewise the manifestation of the sociology of the actors involved.

The activist rationale behind legal recourse

17Increasing recourse to the law and court system also had a certain activist rationale behind it, largely linked to the influence of lawyers within Alevist organisations, which was in turn due to the activist selection and conversion processes. The notion of careers is particularly important here, allowing us to establish a dialectic relationship between context and individual stories, and to connect changes in the realm of activist involvement with changes in professional and personal careers. [35] In the 1990s, the majority of Alevist leaders were men from modest backgrounds, the second generation of the rural exodus; they had largely been associated with the left in the 1970s and thus suffered repression with the 1980 coup d’état. The fact that they had completed higher education and experienced significant upward social mobility “marked” them for Alevi leadership. [36] In fact, when getting involved with the cause became possible again at the end of the 1980s, these individuals had acquired important social capital and exercised occupations that were socially valued, as lawyers, [37] civil servants and engineers. Far from directly opposing the regime, these individuals got involved with largely professional, non-radical organisations (chambers of lawyers and engineers in particular). They thus re-engaged with the social arena under a priori non-political guises, exploiting their recently acquired resources.

18These individuals were in turn the first to become involved with the Alevist cause, before the general rush of mobilisation, with some of them founding organisations. Being simultaneously well-respected and endowed with social capital and activist knowledge, they were also “solicited” by new organisations looking to establish themselves legally, which was far from easy. The legal skills of lawyers were immediately exploited to create and defend organisations: “We have founded an [Alevi] organisation. Among its goals, the desire to ‘revitalise Alevi culture’ was stated, but the word ‘Alevi’ was banned. I was in charge of this case for three years.” [38] Endowed with vital expertise for such organisations, these lawyers quickly found themselves in leadership positions, where they have often remained to this day. Thus, among the high-ranking members of the Pir Sultan Abdal organisation, many are lawyers. The founder and director of the CEM Foundation is a law professor. [39] These activist organisations are therefore structured around groups of professionals that they field on the frontlines. [40] These individuals consequently respond to such solicitations because they bolster their self-worth, and their professional skills lend themselves well to cause lawyering. As a result of their modest backgrounds, they are newcomers to the law, which has become increasingly competitive as lawyers have become more numerous; as a result of their trajectories, they have more ties with the political world than the business world.

19The nested relationship between activism and professional careers allows activist engagement and the professional practice of the law to co-exist. Here we begin to see the outline of the social spaces where the cost of transitioning from a professional career to an activist engagement is relatively low, and where skills and resources can be successfully imported and adapted. [41] As lawyers constituted the initial core of Alevist leaders, the movement’s judicialisation increasingly refocused organisations around them. Lawsuits, often initiated by organisation leaders, revealed the shift towards the professionalisation of organisations.

Judicialisation as a strategy inscribed in power relations

20The Alevist movement seems to be a rather classic case of judicialisation as described by McCann: the law is mobilised by a disadvantaged group to challenge the established order of things and contest discriminatory practices. [42] Mobilising the law thus constitutes a form of participation through which the limits of the legitimate political sphere are renegotiated. [43] Should we, however, believe that judicialisation almost automatically benefits minority rights, by challenging the historical privilege of majority religions? Contrary to this approach which favours institutional and legal reasoning (the culture of precedents, the influence of doctrine and jurisprudence, etc.), realist and strategic theories emphasise the political power relations involved in all processes of judicialisation. Such theories consider that the role of the courts is contingent and fluctuates according to politico-religious constellations, and thus highlight extra-legal reasoning (the ideological positions and values of judges, social and political contexts, etc.). [44]

21I have adopted this realist approach, which is likewise largely dominant in works on the sociology of the law in Turkey. [45] In the same vein as Dahl, [46] such studies agree on the politicised nature of the judicial system and emphasise the embeddedness of the courts within the political system. They likewise tend to consider legal rulings as the products of power relations. The courts, in particular in cases with high political stakes, take into account the balance of power between the relevant political actors. [47] The inconsistencies in the courts’ decisions reveal a judicial system that is linked to political influence and manipulation and sensitive to local configurations. [48] In Turkey, the judicial system is widely seen as highly politicised. According to one recent study, the individuals surveyed did not believe in the independence and impartiality of the judicial system, which they saw as dominated by a “statist” vision, favouritism, and power relations. [49]

22However, this politicisation does not mean that the law systematically follows the government’s position. On the contrary, Ceren Belge has shown that the 1961 Constitution, adopted following the coup d’état in 1960 supported by Kemalist officers, had established a certain number of institutions above the political realm, designed to protect the highest interests of the state, including with regard to democratically elected power. In other words, a political coalition sought to put certain principles outside of the reach of politics, where it was dominated or likely to become so. From this perspective, the autonomy of the judiciary was thus paradoxically a kind of power grab by a political camp that was dominated or likely to be dominated in the future. Consequently, justice, and especially the supreme courts, remained a Kemalist bastion for a long time. Belge shows that the Constitutional Court created at that time, while institutionally autonomous, held selective political positions which were restrictive towards movements that threatened its vision of state order (primarily Kurdish nationalists and Islamists), and more favourable towards political freedoms at certain times, depending on the existing coalitions. This perspective allows us to clarify the rulings handed down by supreme courts regarding Alevi matters. The vast majority of such rulings have occurred since the AKP (Adalet ve Kalkınma Partisi - the Justice and Development Party) came to power in 2002, at a time when the justice system, already divided on the matter, became a political battleground. The Kemalist coalition grew closer to the Alevis, which it touted as a bulwark against the rise of political Islam. On the flipside, for electoral reasons, Kemalist parties have never truly taken up the Alevist claims. To the extent that the justice system has partially resisted the AKP’s power, we may interpret the positions of some supreme courts as a counter-offensive to Islamists via the Alevi cause. [50] Conversely, courts of first instance are more engaged with social changes and do not necessarily follow the verdicts pronounced by the supreme courts. It is in this politicised and divided judicial context that the judicialisation of the Alevi issue is currently playing out in Turkey.

23From a realist perspective, the success of legal mobilisation largely depends on the resources the plaintiffs can exploit. Consequently, increasing recourse to the ECHR which has accompanied – with a few years’ lag – this process of judicialisation, as well as the recognition of Aleviness as a religious community in Germany (even if this was obtained without legal action), have altered the existing power relations.

When judicialisation is not necessary: the institutional recognition of Alevis in Germany

25In Germany, religion and the state have a co-operative relationship, especially with regard to education, since the recognised religions are taught in the public school system. The recognised religious groups thus enjoy a legal status, in particular that of a “religious community” (Religionsgemeinschaft), which opens the doors to providing religious instruction in public schools; obtaining this recognition is thus at the heart of their mobilisations. Nevertheless, for a long time Alevist organisations did not even consider this possibility. In fact, no migrant group had obtained religious status until 1998, when Berlin’s administrative court first granted the status of religious community to a Muslim organisation, [51] Berlin’s Islamic Federation (IFB). Created in 1980 with the goal of representing Berlin’s Muslim population and eventually taking responsibility for the teaching of Islam in schools, this organisation had repeatedly applied for religious community status to no avail, before turning to legal remedies. In 1998, Berlin’s administrative court refuted one by one the arguments that the authorities had thitherto employed against the IFB and granted it religious community status. [52] How can we explain why an organisation linked with Milli Görüş – the Turkish Islamist movement – and considered as dangerous by the federal government was granted the right to teach Islam in public schools, even though such teachings are primarily, according to German authorities, supposed to promote integration and bar the way to fundamentalism? Some observers have noted that the treatment of Islam in Germany is marked by its political non-problematisation (linked to skittish public opinion, unpredictable political profitability, and the lack of electoral stakes) and its unique judicial treatment. [53] The largest immigrant religious community was thus recognised in the judicial arena, despite its presence being accepted with difficulty by political authorities. Here we can observe the role of the law in challenging the historical privileges of majority religions.

26As a knock-on effect, Alevist organisations did not have recourse to the courts. A few weeks after the IFB’s new status was confirmed during a 2000 appeal, the main Alevist organisation in Berlin, the Cultural Centre for Anatolian Alevis (AAKM, Anadolu Alevileri Kültür Merkezi) submitted a claim to benefit from the same status. Filed in 2000, this claim was accepted in principle in less than two months. And yet the criteria that had long plagued the IFB’s petition could very well have been applied to the AAKM as well, as the organisation had similar shortcomings. [54] It can be argued that it was to counteract the rights obtained by the IFB that Berlin’s Senate ruled in favour of the AAKM’s claim. In fact, several studies have illustrated a pro-Alevi bias among German authorities and the German population as a whole, who view Alevis as “liberal Muslims”, tolerant and close to German values. [55] In August 2000, the AABF (Almanya Alevi Birlikleri Federasyonu), the principal German Alevi federation, used Berlin’s ruling as a “precedent” and launched a campaign to obtain religious community status in the main Länder where Alevis were present, a campaign which it also co-ordinated. In 2004, and after consulting two academics (a professor of canon law and a professor of Islamic studies) on the nature of Aleviness, the Ministry granted the AABF religious community status in four Länder, and thus the right to teach Aleviness in public schools.

27Two explanations can be provided for the low level of judicialisation of the Alevi issue in Germany: on the one hand, the sociology of the activists was one factor. Lawyers did not have the same status among Alevist leaders that they enjoyed in Turkey. The founders and leaders of Alevist organisations in Germany had followed different trajectories, often working for foreigners’ rights and the recognition of differences; they were, and mostly continue to be, relatively lacking in legal skills. [56] But this explanation seems secondary if we analyse how recognition was obtained. Unlike the Sunnis, the Alevis did not turn to the legal system but limited themselves to politico-administrative procedures, taking advantage of their cause’s greater legitimacy. Indirectly, the judicialisation of Islam in Germany spared them the need for legal remedies: they were thus the indirect beneficiaries of third-party judicialisation. The obtainment of recognition in Germany without legal recourse supports the realist hypothesis according to which this process is first and foremost political.

Appealing to the supranational sphere: The European Court of Human Rights (ECHR)

28The judicialisation of the Alevi issue in Turkey has, since the beginning of the 2000s, been accompanied by legal actions brought before the ECHR against Turkey for discriminatory practices. Recourse to this supranational court allows actors to circumvent the national framework to appeal their case. So far, the ECHR has ruled in favour of the plaintiffs in all Alevi matters brought before it, thus providing much more evident success than the legal claims made in Turkey; as a result, it has come to play a central role in the judicialisation process. In this section, I shall not only describe how recourse to the ECHR has unfolded, but also contextualise it with regard to Turkish affairs and the jurisdiction of the Court in a general sense – although few studies exist on the identity, strategies, objectives and coalitions of plaintiffs against Turkey, as well as on the recourse of minority groups to the ECHR. [57]

The results of judicialisation

37How should we gauge the effects of the multi-localised judicialisation of the Alevi issue? The possibilities of change through litigation are real: in particular, organisations have gained the right to exist and to create cemevi, and the mandatory religious classes have been deemed discriminatory. Even if these legal successes are limited and have at times been challenged, they are more tangible than the – almost non-existent – ones achieved by political means. It is possible that the courts, as they are not subject to electoral constraints, are more likely to drive change. [74] Yet, research has highlighted how complex it can be to evaluate legal successes. In particular, Gerald Rosenberg has argued that such successes are often illusory, since courts are not in a position to ensure their effective implementation or disrupt the inertia of dominant social norms. [75] This conclusion applies to the Alevi issue, as a number of rulings were never applied and the Alevi population is still subject to much discrimination.

38However, Michael McCann emphasises that the effectiveness of legal activism goes beyond favourable verdicts and their immediate impact, and should be evaluated more broadly by taking into account the indirect and long-lasting repercussions of such decisions. Even small changes can encourage breakthroughs that are not limited to individual cases. It seems all the more important to point this out in the context of a movement to obtain recognition for an ostracised and taboo group, lacking any legal basis, and whose identity and legitimacy are far from self-evident. Consequently, rulings that were favourable to the Alevi cause largely strengthened the group’s feeling of being within its rights, and legitimised its struggle. In this case as in others, the abstract rhetoric of the law and its universalising effects facilitated the movement’s spread and raised collective awareness of an injustice. The language of the law and recourse to judicial bodies were thus important pillars of support in the movement’s development, enabling the transition from individual grievances to a collective cause. For the Alevis, the newly legitimate repertoire of legal action and the resulting expectations certainly encouraged collective action. Mobilisation intensified again in the 2000s, alongside the rise in judicialisation. In addition, unlike in Rosenberg’s analysis in which activists who were convinced that they had achieved success subsequently lost enthusiasm, legal victories for the Alevi cause, especially at the ECHR level, and even when they were not implemented, raised hopes for reform. When rulings were not applied, this was sometimes even cause for pride and greater mobilisation, as it “proved” the group’s victim status and justified their struggle. Finally, McCann emphasises leverage effects: as soon as a mobilisation can claim a legal victory, references to legality become a useable pressure tactic. Although such tactics have not been very effective in Turkey so far, due to the difficulty of establishing precedent, they can be quite successful in other arenas, especially internationally.

“Legal globalisation”? Limits, impasses and resistance

39The case studied here allows us to compare two different forms of legal “globalisation” or internationalisation, via the ECHR and via migration, and to investigate the potential connections between these different judicial arenas. First, let us examine the ECHR from two different angles: on the one hand, analysing the continuity between the legal actions undertaken in Turkey and then brought before the ECHR; on the other, following a relatively traditional line of enquiry in terms of how the ECHR’s rulings were adapted in Turkey. Finally, we shall investigate the existence of “horizontal” connections across national levels.