{"id":10766,"date":"2018-11-29T19:31:13","date_gmt":"2018-11-29T19:31:13","guid":{"rendered":"http:\/\/www.environment-hawaii.org\/?p=10766"},"modified":"2018-12-11T01:42:59","modified_gmt":"2018-12-11T01:42:59","slug":"hawaii-supreme-court-upholds-permit-to-allow-construction-of-tmt","status":"publish","type":"post","link":"https:\/\/environment-hawaii.org\/?p=10766","title":{"rendered":"Hawai\u2018i Supreme Court Upholds Permit to Allow Construction of TMT"},"content":{"rendered":"
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In a long-awaited decision issued on October 30, the Hawai\u2018i Supreme Court determined that the state Board of Land and Natural Resources did not err when it awarded a Conservation District Use Permit (CDUP) for construction of the Thirty Meter Telescope (TMT) near the summit of Mauna Kea.<\/p>\n

The opinion was not unanimous. The majority decision was signed by Chief Justice Mark E. Recktenwald, Associate Justice Sabrina S. McKenna, and 1st Circuit Judge Jeannette H. Castagnetti, filling in for Associate Justice Paula A. Nakayama, who recused herself. Associate Justice Richard W. Pollock concurred in part and concurred in the judgment of the majority. Associate Justice Michael D. Wilson joined with part of Pollock\u2019s opinion, but dissented from the conclusion of the majority.<\/p>\n

Before the high court were three consolidated appeals of the decision made more than a year earlier by the Land Board. On September 27, 2017, it had issued its Findings of Fact, Conclusions of Law, and Decision and Order (D&O for short) that contained 1,070 findings of fact and 512 conclusions of law. Altogether, the document ran to 271 pages.<\/p>\n

That document itself was the result of a contested case hearing that ran for more than 40 days in 2016 and 2017, with retired judge Riki May Amano presiding over the quasi-judicial proceeding. Amano drafted her own recommended D&O and presented it to the Land Board. In crafting the final decision, the board accepted many of Amano\u2019s proposed findings, but rejected some as well.<\/p>\n

Following the Land Board\u2019s decision to award the permit to the TMT, the 17 parties to the contested case who opposed the permit filed their appeals to the high court. (See separate box for a list of the parties who appealed the case.)<\/p>\n

It took just over a year for the court to reach its decision. But once it was released, there was little suspense in the outcome. By the third paragraph, the majority justices disclosed the outcome of their deliberations:<\/p>\n

\u201cIn this opinion, we address whether the BLNR properly applied the law in analyzing whether a permit should be issued for the TMT. Upon careful consideration of the written submissions, the applicable law, and the oral arguments, and for the reasons explained below, we now affirm the BLNR\u2019s decision authorizing issuance of a Conservation District Use Permit (CDUP) for the Thirty Meter Telescope (TMT).\u201d<\/p>\n

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The majority justices helpfully listed the \u201cpoints of error\u201d that were raised in the appeals, categorizing them in four general topics: disqualification issues; Native Hawaiian rights; public trust and land use; and other \u201cprocedural\u201d issues. The last of these concerns technical arguments about the conduct of the contested case hearing, for the most part. Nearly every point raised by the opponents in this category was quickly dispensed with by the justices.<\/p>\n

Disqualification Issues<\/strong><\/em><\/p>\n

The TMT opponents challenged the selection of Amano as the hearing officer, arguing that her membership in the \u2018Imiloa Astronomy Center compromised her ability to be impartial. The \u2018Imiloa is administratively attached to the University of Hawai\u2018i at Hilo, which was the applicant for the CDUP. Opponents noted that the TMT organization had made a substantial donation to the \u2018Imiloa as well.<\/p>\n

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In defending Amano\u2019s selection, the BLNR compared membership in the \u2018Imiloa to museum membership. The justices agreed.<\/p>\n

Opponents also argued that Amano\u2019s behavior in the contested case amounted to prejudice against them and was improper and that she had connections with a deputy attorney general (Amano attended law school with his wife).<\/p>\n

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The justices rejected the arguments.<\/p>\n

\u201cMembership [in \u2018Imiloa] alone does not lead to a conclusion that a member supports a mission to build the TMT, even assuming that this is \u2018Imiloa\u2019s mission,\u201d they found.<\/p>\n

TMT opponents had asked the BLNR to disqualify the deputy attorneys general who advised the board in the first contested case and appeal from having any advisory role in the more recent contested case. Again, the justices rejected the argu- ment. The deputy attorneys general \u201chave always been required to assist the BLNR in a manner to enable the board to perform its duties faithfully,\u201d they wrote. \u201cTheir duty never changed, and they have consistently represented the interests of the BLNR.\u201d<\/p>\n

Finally, as to the matter of disqualifications, the justices considered the opponents\u2019 arguments that two Land Board members \u2013 Chris Yuen and Samuel Gon \u2013 should not have been allowed to vote on the contested case.<\/p>\n

In the case of Yuen, they pointed to a 1998 interview he gave to Environment Hawai\u2018i, in which he discussed telescopes atop Mauna Kea, among many other things. The opponents focused in on his statement that \u201cI don\u2019t see what difference it would make to have a few more telescopes up there as long as you site them properly.\u201d<\/p>\n

The justices noted, however, that Yuen\u2019s comments \u201calso contained criticism of telescope projects\u201d and that he \u201calso stated that any future telescope project would need, at minimum, to be \u2018site[d] … properly,\u2019 meet the demands of good stewardship, and leave intact habitat and archaeological and cultural sites.\u201d<\/p>\n

\u201cThus,\u201d they found, \u201cYuen\u2019s comments, made in 1998, did not indicate he would approve all future telescope applications\u201d and there was nothing to \u201creasonably cast suspicion on Yuen\u2019s impartiality.\u201d (The full interview appears in the July 1998 edition of Environment Hawai\u2018i.)<\/p>\n

As to Yuen\u2019s participation on the panel that selected Amano to be hearing officer, the justices found there to be \u201cno due process violation.\u201d<\/p>\n

Gon, the opponents argued, should have been disqualified because he had voted to approve the permit for the TMT the first time that it came before the Land Board. The justices dismissed this argument, noting that Mauna Kea I remanded the case \u201cfor a second contested case hearing \u2018before the board or a new hearing officer,\u2019 not a new board. Moreover, there is no legal authority requiring a board member to be disqualified because he had approved a decision that is later vacated and remanded. If such authority existed, no vacated decision could ever be remanded to the same board or lower court judge.\u201d<\/p>\n

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Native Hawaiian Rights<\/strong><\/em><\/p>\n

One of the most seminal decisions in the evolving history of Native Hawaiian rights is Ka Pa\u2018akai o Ka \u2018Aina, which requires agencies to identify cultural resources and determine the extent to which Native Hawaiian rights are exercised in a given area, determine how those rights will be affected by a given action, and describe \u201cthe feasible action, if any,\u201d that the agency will take to protect such rights if they are found to exist.<\/p>\n

\u201cThe BLNR found no evidence … of Native Hawaiian cultural resources, including traditional and customary practices, within the TMT observatory site area and the access way,\u201d the justices noted.<\/p>\n

In 2015, two ahu were erected by protesters on the unpaved road leading to the TMT site, but the \u201cBLNR concluded that the two ahu … did not constitute a traditional and customary right or practice.\u201d A third ahu, consisting of a single upright stone and several support stones, was also of recent vintage. The justices agreed that the structures \u201care not protected as Native Hawaiian traditional or customary rights.\u201d<\/p>\n

As for the Native Hawaiian practices at the summit, the BLNR determined in its findings of fact that cultural and\/or spiritual practices had co-existed with astronomy facilities and that those practices would not be affected by the TMT, to be built 600 feet below the summit ridge.<\/p>\n

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Another aspect of Ka Pa\u2018akai prevents agencies from improperly delegating their duties to protect Native Hawaiian rights and practices to others. TMT opponents argued that two of the conditions approved in the BLNR\u2019s decision did just this by requiring the university to consult with Kahu Ku Mauna, a group of Hawaiians that advises the university\u2019s Office of Mauna Kea Management. The justices determined, however, that while these conditions \u201cmay appear to be delegations, they are not; they are outside and in addition to Ka Pa\u2018akai requirements, and were imposed to ensure that Native Hawaiian practices in the Mauna Kea area will continue to be protected.\u201d<\/p>\n

The Kihoi appellants argued that the TMT would impair their constitutional rights to practice their religion, amount to a violation of the Religious Freedom Restoration Act, and the Religious Land Use and Institutionalized Persons Act of 2000. None of those arguments were compelling to the justices, who dismissed them as meritless.<\/p>\n

The Temple of Lono argued that Amano erred when it refused to disqualify the University of Hawai\u2018i at Hilo as the applicant, inasmuch as the university had disrespected it with offensive statements that showed a hostility to what it claimed was traditional Hawaiian faith.<\/p>\n

\u201cThe Temple\u2019s opening brief does not quote the allegedly offending language,\u201d the justices wrote, but they seem to have found it in one of the university\u2019s briefs.<\/p>\n<\/div>\n

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In that brief, the university appears to accuse the Temple of fundamentalism, going on to note that the \u201cproblem with fundamentalism in religion \u2013 any religion \u2013 is its intolerance and inability to compromise… The Temple wants a religious servitude over all of Mauna Kea, for the purpose of advancing its own religious agenda.\u201d<\/p>\n

While the university argued that Mauna Kea could accommodate both the TMT and traditional Native Hawaiian Religion, \u201cthe Temple rejects that sharing of Mauna Kea,\u201d the justices noted.<\/p>\n

Neither the hearing officer nor the BLNR were required to disqualify the university as applicant, they went on to write. Still, they issued a mild reproof: \u201cthe tenor of the language in [UHH\u2019s] memorandum was unnecessary.\u201d<\/p>\n

One of the arguments raised frequently, and vainly, in the contested case had to do with the legitimacy of the current government of Hawai\u2018i. On appeal, Harry Fergerstrom challenged the dismissal of his efforts to raise this point.<\/p>\n

He had no better luck with the Supreme Court: \u201cThe BLNR is bound by the United States Supreme Court\u2019s and this court\u2019s precedents regarding the legal status of the state of Hawai\u2018i,\u201d the justices wrote. \u201cTherefore, the hearing officer did not err by excluding the proposed evidence.\u201d<\/p>\n

Public Trust and Land Issues<\/strong><\/em><\/p>\n

Sixteen pages of the majority opinion are given over to discussion of public trust and land issues. First the justices considered the Conservation District permit and BLNR decision in light of Article XI, Section 1 of the Hawai\u2018i Constitution and public trust principles. Next they held them up against the BLNR\u2019s own administrative rules governing permitted uses in the Conservation District.<\/p>\n

Near the outset of the discussion, the justices make a definitive statement: \u201cThe plain language of Article XI, Section 1 provides that all public natural resources, including land, are held in trust by the state for the benefit of the people. We therefore now hold that conservation district lands owned by the state, such as the lands in the summit area of Mauna Kea, are public resources held in trust for the benefit of the people pursuant to Article XI, Section 1.\u201d<\/p>\n

The same constitutional provision also \u201crequires a balancing between the requirements of conservation and protection of public natural resources, on the one hand, and the development and utilization of these resources on the other in a manner consistent with their conservation.\u201d<\/p>\n

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The Land Board rejected the opponents\u2019 argument that the use of the land by the TMT, a private organization, violated the presumption that favors public use, access, and enjoyment \u2013 established in the Supreme Court\u2019s Waiahole I decision in 1994.<\/p>\n

The Supreme Court agreed with the Land Board. \u201cThe TMT project does not involve the irrevocable transfer of public land to a private party,\u201d it found, going on to note that the TMT\u2019s use of the land is for a limited term. Other conditions imposed by the board require it to under- take improvements to natural resources, including funding of the \u201cre-naturalization\u201d of the closed road on Pu\u2018u Poli\u2018ahu, among other things. Off-site benefits associated with the project, the justices noted, include a \u201csubstantial community benefits package\u201d and a \u201cworkforce pipeline program.\u201d<\/p>\n

On the matter of compliance with the administrative rules setting forth eight criteria that need to be met for Conservation District Use Permits, the justices note that the Land Board \u201cmade extensive FOFs [findings of fact] and COLs [conclusions of law]\u201d regarding each criterion.<\/p>\n

Opponents\u2019 arguments focused on alleged violations of three of those: the fourth condition, which prohibits a proposed use if it will cause \u201csubstantial adverse impact to existing natural resources;\u201d the fifth condition, which addresses the proposed use\u2019s compatibility with its surroundings; and the sixth condition, requiring that the \u201cexisting physical and environmental aspects of the land … will be preserved or improved upon.\u201d<\/p>\n

The fourth condition, the Land Board found, was addressed inasmuch as the TMT would be improving much of the area that, over the years, had been damaged by development and the university was agreeing to remove two additional telescopes and not seek permits for other telescopes to replace any of the total of five telescopes that are to be taken out of service.<\/p>\n

In light of these findings, the justices wrote, \u201cthe BLNR did not clearly err in concluding that the TMT will not have a substantial adverse impact to natural resources within the surrounding area…\u201d<\/p>\n

Regarding the fifth condition \u2013 compatibility with surroundings \u2013 the BLNR found that the TMT would be sited half a mile from the summit area and near 11 other astronomy facilities. \u201cTherefore, on these facts,\u201d the justices wrote, \u201cwe cannot say that the BLNR erred\u201d on this point.<\/p>\n

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The sixth condition, requiring the proposed project not degrade the natural beauty or open space of a site, was deemed to have been met by the board inasmuch as the university \u201cformally committed that this is the last new area of Mauna Kea where a telescope project would be sought.\u201d Here again the justices determined that the Land Board\u2019s findings \u201care not clearly erroneous.\u201d<\/p>\n

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Pollock Would Expand Public Trust Protections<\/h4>\n

Associate Justice Richard W. Pollock agreed with the three Hawai\u2018i Supreme Court justices who authored the opinion approving the Board of Land and Natural Resources\u2019 award of a Conservation District Use Permit for building the Thirty Meter Telescope.<\/p>\n

Agreed \u2013 to a point.<\/p>\n

In a separate opinion, concurring in part but also concurring in the judgment, Pollock described his views on where the majority justices failed in their analysis of the principles at issue in the litigation over the CDUP.<\/p>\n

The focus of Pollock\u2019s attention in his 37-page opinion is the reach of the public trust doctrine, especially its applicability to land in the Conservation District. In Pollock\u2019s opinion, the majority justices did not go far enough in describing the public-trust protections for such land, even though they have fully framed those same safeguards as they applied to water. The result, as Pollock expresses it, is \u201cdifferent measures of protection\u201d for land as opposed to water.<\/p>\n

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\u201cBut,\u201d he continues, \u201cneither the text nor the history of Article XI, Section 1 [of the Hawai\u2018i Constitution] provides for differing levels of protection for individual natural resources … and this court should not establish artificial distinctions without a compelling basis for doing so.\u201d<\/p>\n

The high court was in effect refusing \u201cto demarcate the outer limits of the public trust doctrine\u201d and was, instead, \u201capplying the fundamental principles … through case-by-case adjudication.\u201d When water resources were concerned, he argues, the court did rise to the occasion in a case it decided four years ago: \u201cOur evolving caselaw applying constitutional public trust principles to water usage was collected and summarized by this court in Kaua\u2018i Springs… [W]e distilled from our precedents a framework of inter-related principles applicable to agencies and applicants in discharging their respective obligations.\u201d<\/p>\n

To show just what he means, Pollock cites a finding of the hearing officer, Riki May Amano. Amano, Pollock writes, \u201cstated that \u2018the scope of the public trust doctrine has traditionally been limited to water resources, and the reliable, credible and substantial evidence establishes that the TMT project will not restrict or otherwise impair any water resources.\u2019\u201d On that basis, he says, \u201cthe hearing examiner concluded that \u2018the public trust doctrine does not apply to consideration of the TMT project.\u2019\u201d<\/p>\n

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Amano\u2019s conclusion runs up against an earlier Supreme Court decision, Zimring<\/em>, in which the court determined that public trust principles apply to public land, Pollock contends.<\/p>\n

In any event, the Land Board rejected this conclusion of Amano\u2019s, making it unnecessary for the court to consider it.<\/p>\n

However, Pollock goes on to say the Land Board itself \u201cmade a number of conclusions that are not wholly consistent with established law,\u201d including its conflation of language relating to the ceded land trust, the University of Hawai\u2018i trust, and the public trust relating to manage- ment of natural resources. \u201c[I]n some instances,\u201d Pollock opines, \u201cthe trusts may share assets in common, as in the present case … But each of the three trusts is distinct… Accordingly, when a contemplated action may affect property in which multiple trusts hold common title, the state is obligated to consider the impact of its actions on the separate purposes of each trust that is implicated.\u201d<\/p>\n

Basically, by holding up the proposed use of the land against the language of its administrative rules rather than against that of the public trust doctrine as expressed in the state Constitution, the Land Board fell short of undertaking the appropriate analysis, Pollock seems to argue.<\/p>\n

Pollock does not disagree with the final decision of the majority justices. But, as a consequence of what he sees as their failure to provide a framework for determining compliance with public trust protections, he describes as \u201cunclear\u201d the basis for the finding that the BLNR fulfilled its constitutional public trust obligations.<\/p>\n

In addition, he seems to have a problem with the manner in which the Land Board \u2013 and his colleagues \u2013 pointed to the TMT\u2019s promise of off-site benefits in justifying the decision that its construction would not violate the constitutional protection of public trust resources or Conservation District rules.<\/p>\n<\/div>\n

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\u201cIn addressing the presumption in favor of public use, access, enjoyment, and resource protection,\u201d he writes, referring to the presumption expressed in Article XI, Section 1, \u201cthe majority cites the vari- ous grants, scholarships, and career train- ing the operators of the TMT will offer the community… as well as the sublease rent that will be paid to the university of Hawai\u2018i. … Although donations or payments to the state and community that are unrelated to the actual use of a resource may be somewhat relevant to whether the proposed use of the conservation land is being put to a reasonable and a beneficial use, they have no bearing on whether the proposed use is itself public in nature. Were this not the case, virtually any use of a natural resource could be converted to a public use … simply by coupling it with sufficient auxiliary payments to the state or community.\u201d<\/p>\n

Pollock nonetheless concurred with the majority opinion. \u201cAlthough it misconstrued its duties under Article XI, Section 1, the findings and conclusions that the BLNR made regarding the public trust and other matters are sufficient to evaluate whether the board satisfied the obligations outlined in the Kaua\u2018i Springs framework,\u201d Pollock writes. \u201cBLNR\u2019s factual findings on these issues appear to be supported by substantial evidence and thus are not clearly erroneous and an appellate court is therefore obliged to accept them.\u201d<\/p>\n

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Justice Wilson\u2019s Dissent: \u2018The Degradation Principle\u2019<\/h4>\n

In his 36-page dissent, Justice Michael Wilson posits what he calls \u201cthe degradation principle\u201d and argues that this is what the Land Board employed when approving the Conservation District Use Permit for the Thirty Meter Telescope. The moniker is a play on the principle of non-degradation that has been formulated to defend natural resources against further harm when they have already suffered substantial degradation.<\/p>\n<\/div>\n

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\u201cThe degradation principle portends environmental and cultural damage to cherished natural and cultural resources,\u201d Wilson writes in his dissent, filed 10 days after the majority justices published their opinions.<\/p>\n

(As an aside, the opponents had 10 days in which to file a request for the court to reconsider its decision. Because Wilson had announced his dissent but had not published it, the opponents asked the court to extend the period in which they could file their request for reconsideration. The Supreme Court granted the request, extending the period for filing by another 10 days. The requests were filed November 19.)<\/p>\n

In a footnote, Wilson calls out what he sees as a contradiction in the majority opinion: \u201cThe majority states that the \u2018BLNR does not have license to endlessly approve permits for construction in conservation districts, based purely on the rationale that every additional facility is purely incremental. It cannot be the case that the presence of one facility necessarily renders all additional facilities as an incremental addition.\u2019\u201d But despite this, Wilson continues, \u201cthe increment with the great impact of all telescopes, TMT, is deemed not to cause a substantial adverse impact because prior increments of telescope construction cumulatively caused a substantial adverse impact.\u201d<\/p>\n

Wilson also says that the majority decision violates the principle of \u201cintergenerational equity.\u201d<\/p>\n

\u201cThe degradation principle removes the need to consider the impacts of TMT on the existing resource. … In this way the BLNR ignores the rights of future generations to the protections specifically afforded them\u201d by the Land Board\u2019s administrative rules, he states.<\/p>\n

\u2014 Patricia Tummons<\/strong><\/em><\/p>\n<\/div>\n

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 <\/p>\n

The Appellants<\/h3>\n

The Supreme Court consolidated three separate appeals made by the parties who were admitted as petitioners to the Thirty Meter Telescope contested case hearing. Here is the breakdown:<\/p>\n

Appellants Mauna Kea Anaina Hou, Kealoha Pisciotta, Clarence Kukauakahi Ching, the Flores-Case Ohana, Deborah Ward, Paul Neves, and KAHEA: The Hawaiian Environmental Alliance. They were represented before the high court by Richard Naiwieha Wurdeman. (Wurdeman had also represented them in motions before the contested case began, but dropped out before it started.) These were the same parties who appealed the BLNR\u2019s decision to grant the CDUP in April 2013. That appeal resulted in the Supreme Court\u2019s first decision on this subject, Mauna Kea I, handed up on December 2, 2015. In that decision, the court remanded the matter to the Land Board, determining that it had erred by voting on the permit before holding a contested case hearing.<\/p>\n

Appellants Temple of Lono, Mehana Kihoi, Joseph Kuali\u2018i Camara, Leina\u2018ala Slightholm, Kalikolehua Kanaele, Tiffnie Kakalia, Brannon Kamahana Kealoha, Cindy Freitas, and William Freitas were represented by Gary Z. Zamber.<\/p>\n

Intervenor-Appellant Harry Fergerstrom represented himself.<\/p>\n

Dwight J. Vicente, one of the parties to the contested case, also filed an appeal, but was dismissed from the case owing to his failure to file an opening brief.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

In a long-awaited decision issued on October 30, the Hawai‘i Supreme Court determined that the state Board of Land and Natural Resources did not err when it awarded a Conservation District Use Permit (CDUP) for construction of the Thirty Meter … Continued<\/a><\/p>\n","protected":false},"author":1,"featured_media":10057,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[444],"tags":[],"class_list":["post-10766","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-december-2018"],"_links":{"self":[{"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=\/wp\/v2\/posts\/10766","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=10766"}],"version-history":[{"count":0,"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=\/wp\/v2\/posts\/10766\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=\/wp\/v2\/media\/10057"}],"wp:attachment":[{"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=10766"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=10766"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=10766"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}