If you look at the fine print in the published "Guidelines for implementing Net Neutratily" [1] linked in the article you will see that there are 3 exceptions to the rule (a,b,c). Being "c" the one that should fear us most:
EXCEPTIONS
a) "comply with Union legislative acts (...) b) preserve the integrity and security of the network, of services provided via that network, and of the terminal equipment of end-users; c) prevent impending network congestion and mitigate the effects of exceptional or temporary network congestion, provided that equivalent categories of traffic are treated equally.This last one ruins the whole law. And this is not what me as European wanted. ISPs won :(
[1] http://berec.europa.eu/eng/document_register/subject_matter/...
[EDIT] typos
> -> meaning that a court order can change Net Neutrality, hmmm ok.
It would be weird for a court to order anyone to break net neutrality.
> -> meaning that in order to guarantee the security of the network Net Neutrality may be avoided. I'm so-so on this one.
The intention here seems to be to allow (D)DOS attack mitigation etc.
> -> Meaning that ISPs can throttle specific categories of traffic at their own will.
Note that the law is very clear that this only is allowed "provided that equivalent categories of traffic are treated equally."
Back to square 1.
They can, for instance, slow down P2P traffic. What do you think about that?
Recital 15, attached to the article 3(3)c, goes to great length defining what exceptional means, that such traffic may be managed, temporarily, only if it was unpredictable, unavoidable, and short duration, or it damages network reactivity. It clearly states that such management is not a replacement for upgrading bandwidth, both mobile and fixed. And even then they cannot prejudice specific traffic, just an entire class of it, again, only temporarily.
The recitals are awesome! I wish USAmerica would use this type of exposition in their legalese.
Hm, this is all I found so far about the practice: https://web.archive.org/web/20130622043635/http://eur-lex.eu...
Recital 15
==========
Third, measures going beyond such reasonable traffic management
measures might also be necessary to prevent impending network
congestion, that is, situations where congestion is about to
materialise, and to mitigate the effects of network congestion, where
such congestion occurs only temporarily or in exceptional
circumstances. The principle of proportionality requires that traffic
management measures based on that exception treat equivalent
categories of traffic equally. Temporary congestion should be
understood as referring to specific situations of short duration,
where a sudden increase in the number of users in addition to the
regular users, or a sudden increase in demand for specific content,
applications or services, may overflow the transmission capacity of
some elements of the network and make the rest of the network less
reactive. Temporary congestion might occur especially in mobile
networks, which are subject to more variable conditions, such as
physical obstructions, lower indoor coverage, or a variable number of
active users with changing location. While it may be predictable that
such temporary congestion might occur from time to time at certain
points in the network – such that it cannot be regarded as exceptional
– it might not recur so often or for such extensive periods that a
capacity expansion would be economically justified. Exceptional
congestion should be understood as referring to unpredictable and
unavoidable situations of congestion, both in mobile and fixed
networks. Possible causes of those situations include a technical
failure such as a service outage due to broken cables or other
infrastructure elements, unexpected changes in routing of traffic or
large increases in network traffic due to emergency or other
situations beyond the control of providers of internet access
services. Such congestion problems are likely to be infrequent but may
be severe, and are not necessarily of short duration. The need to
apply traffic management measures going beyond the reasonable traffic
management measures in order to prevent or mitigate the effects of
temporary or exceptional network congestion should not give providers
of internet access services the possibility to circumvent the general
prohibition on blocking, slowing down, altering, restricting,
interfering with, degrading or discriminating between specific
content, applications or services, or specific categories
thereof. Recurrent and more long-lasting network congestion which is
neither exceptional nor temporary should not benefit from that
exception but should rather be tackled through expansion of network
capacity.Then only we could measure that they do offer the same bandwidth with Netflix and Vimeo as they advertise. Net neutrality at its best.
Edit: Of course the number will be very low because they have to (God forbid!) provision their network to serve this bandwidth to all customers during peak hours. But what we're looking for is not a huge number - we're looking for a number that allows meaningful comparison with competitors.
As an ISP how would you _guarantee_ the bandwidth for each endpoint? You would have to provision for the maximal capacity all over your network. Given that most people only utilize their channel 1% of the time, this is a huge waste!
What's sensible to ask ISPs to do is: (a) Communicate historically experienced bandwith at each region (b) Provided certified, standartized measurement facilities (software / hardware?!) that can be used to monitor of the link utilization/saturation levels. (d) Refund policy, when agreed service level targets (as measured in b) were not hit. (This should be legally mandated)
There are mathematical models that describe the probability of a new call coming in at any given time. Add the system in terms of how many connections it can have active and how many it can queue, and you can calculate your required sizing for a given quality level.
As a sidenode, this is also why ISDN flatrates were doomed, because the always-connected nature of them broke the models the system was based on. And why new phone companies renting capacity from established ones could offer cheaper connections, they simply rented at a much higher allowed connection error rate.
Using similar, well, maybe even much easier math, you can calculate that your current system at your desired maximum utilization level allows for 432KiB/s downstream for every customer, but if the overall network is underutilized you can achieve up to the n MiB/s your connection is rated for.
Then you add for example hierarchical traffic shaping where queues are allowed to borrow unused bandwidth from other queues. But it is a huge investment, no doubt.
Also, guaranteed bandwidth is imho not that different from a service level target in Bit. You'll have to refund if you break the SLA, the same as if you break your promise.
We're currently in place that is completely unacceptable towards customers. Now you don't have to go completely in the other direction but when you advertise and sell someone a contract involving a certain amount of bandwidth, you should have to provide that 99% of the time modulo schedule downtime. I think that would be perfectly achievable and fair to ISPs and it wouldn't require them to provision for maximal capacity either. I mean it's not like you should be able to sue them into the ground when they only manage 89.9999% or something.
You guarantee that you will obtain x mbps of peering/transit per customer, per network. Then you advertise x as your minimum speed, even if off-peak usage can spike to 30 times x.
When I still lived in Slovenia, I had 20/20 FTTH. Fiber went directly into a router in my bedroom. My bandwidth was always exactly 20/20. No matter what.
Now I have Comcast. Speedtest says I get 80/6. On Friday and Saturday evenings Netflix and Facebook and many other things often experience issues. Now I can't confirm any of this. If you run speedtest, it's fine. If you ping something, there's no packet loss. But it just doesn't feel very fast and reliable under normal use.
Agreed, everybody loves the idea of fixed allocation, but never seem to consider how much that costs. If you could buy overprovisioned 25mbps @ $50/mo, or fixed allocation 25mbps @ $5,000/mo, which do you think most people would go for...
The real kicker is that the regulator has actually defined acceptable minimum speeds.
Minimum speeds can be stated either as an average or a range. Acceptable averages are at least 50% of the advertised maximum speed measured during any 4 hour period. If stated as a range, 40% of the maximum speed as a lower bound at any time is acceptable.
http://fin.afterdawn.com/uutiset/artikkeli.cfm/2016/08/17/st... (in Finnish only though)
Obviously nobody can offer any guarantees for off-net traffic.
With fiber, yes, that's possible. They're not advertising it in commercials but the website of my ISP has a page with those data. It matches what I experience with fiber.
Source: http://motherboard.vice.com/read/wikipedia-zero-facebook-fre...
That would hardly have been expected: in the first six months of being a Commissioner, Oettinger met with two NGO representatives but with 44 corporate lobbyists [1].
[1] http://www.spiegel.de/wirtschaft/soziales/guenther-oettinger...
And this is why Brexit is so heart-breaking. I'm surrounded by people in my personal life who think it's a fantastic idea, but they're not the most... informed? Likewise for local politicians.
(Side note to my rant: I have this theory that the rise of the iPhone, and the fact that it is such a big part of people's lives now, has fooled regular folks into believing that they're experts on technology. I have no more than anecdotal evidence for this).
I strongly suspect that local legislators will see no conflict whatsoever with scrapping these laws when the exit finally comes, and it saddens me that I'm surrounded by a lot of people that will be cheering when it happens.
This is from a real conversation I had this week:
"What it boils down to is do you want to have us control our own laws and decisions and borders, or have to take orders from some bureaucrat in Brussels that doesn't understand us?"
Yes, I would rather have decisions made by people in Brussels that understand what they're doing.
>Yes, I would rather have decisions made by people in Brussels that understand what they're doing.
Yay structural unemployment in the eurozone! The folks at the commission and at the ECB sure know as hell what they are doing since the EU is a sui generis structure and the non-accelerating inflation rate of unemployment absolutely did not hurt western economies and destroyed the industrial tissue of those countries. I am being sarcastic.
Now, without any offense, you sound like someone who has red a wikipedia page about the European Union and who nows consider everyone having dissenting opinion to be a stinky redneck who does not deserve a voice.
Maybe that's not what you wanted to convey, in that case I apologise, but to be honest, at this point, I have met so many pseudo-smartass people who think they understand everything that I have very little hope you don't fall into that category of people. Thinking technocracy will magically solves all your problems is lazy, at best.
How could shifting more towards Ordoliberalism (=government regulation to maximize competition plus a social safety net) be a bad thing? Quality of life is rather high in Germany after all.
Is there in fact evidence that unemployment is intentionally maintained in order to suppress inflation?
Even if your assertions are true, how would Brexit address any of these things and generally how would a balkanized Europe be more prosperous let alone more globally competitive than a unified Europe?
To summarize though:
1) I don't believe I know any better than anyone else, it's just that I feel this was the wrong decision for a variety of reasons, and I'm very scared for the future based on this result.
2) I am a smug jackass that knows significantly less than he thinks he does, and I use long words in a futile attempt to disguise this. But I am not a pseudo smart-ass. Frank that works across from me is, and no-one sits with Frank at lunch.
3) I think the EU makes terrible decisions. I just think that they try to make the correct ones with the best of intentions and fail. I think this is vastly preferable to making the wrong decisions for questionable reasons and succeeding.
That requires having people in Brussels who understand what they're doing - at least better than local politicians. But I'm not sure how exactly you ensure that. If we assume you are right that the people around you (excepting you, of course) are woefully misinformed and so are local politicians, where would the enlightened folks in Brussels come from, who would elect and appoint them? If you plan to keep the democracy around and not replace it with absolute monarchy with people as well informed as yourself at the helm (how do you ensure that btw?), I don't see how exactly that may work.
It is a great delusion that democratic mechanisms and limited federalized government are the way to put the best people on top and manage the system most efficiently. They are not. They are the safety valve to mitigate the effect of so-so and worse people being on top. And this mechanism is necessary because there's no viable solution so far that can identify "best" people (whatever that may mean, we have no idea for that either) and put them on top.
I utterly agree with all of the points made above, I simply feel that if it's a case of "better the devil you know than the devil you don't", then I would choose "don't" any day of the week based on a lifetime of experiencing local politics.
Honestly, the thought of any increase in power to local politicians terrifies me, based on their track record alone.
That is not that important because the people on top can only prescribe, the population has to substantiate the plans. Therefore it is important that the population can be informed beforehand to agree with the plans.
> Yes, I would rather have decisions made by people in Brussels that understand what they're doing.
Julia Reda is a MP inside the EU parliament. She was voted in their and is not some bureaucrat. The voter turnout in Great Britain was 36 % in 2014, so it is partly their own fault if the do not feel represented by their representatives.
Günther Oettinger however was rescued from an historic loss of the conservative CDU against the Greens in the state of Baden-Württemberg [0] where he was minister-president (governor in the US). It was the first time the Greens were the big partner in a coalition to govern a German state. Oettinger screwed up a big project to rebuild a train station followed by many protests, police scandals and so on [1]. His genius argument why Stuttgart should not have a terminal station, when Paris has one, is that there are no people living west of Paris. The CDU lost the election on the topic of nuclear energy and Oettinger was then of all places appointed to be Commissioner of Energy. People also ask themselves why Germany sends the one person with the worst English skills to an international parliament and make fun of it [2].
So yeah, you could definitely argue, that the commission could benefit from directly elected members. Although it is not undemocratic: The members are appointed by the governments. Great Britain also had nice, prestigious positions: Commissioner of Foreign Affairs (10-14) and Commissioner of Finances (today), while Germany only got energy and internet.
[0] https://en.wikipedia.org/wiki/Politics_of_Baden-W%C3%BCrttem...
If everything is a human right, nothing is. At this point, what's the difference between a "human right" and a nice thing?
>Yes, I would rather have decisions made by people in Brussels that understand what they're doing.
The thing about centralized government is that it's great when you agree with what they're doing, but it's terrible when you don't. Ask yourself how happy you would be with European governance if they primarily didn't implement policies that you personally considered wise.
People have different ideas about what's fair. The hinge of democracy is the simplicity by which a people can make their will known and have that will executed, at least within their own region.
More local governance makes individual will much more important. Consider that a representative's attention is evenly divided by the quantity of his constituents, because each constituent has an equal quantity of votes. Thus, a smaller quantity of constituents means more individual influence in government. That's generally a positive thing. Therefore, jurisdictions should be broken into the smallest workable units, and the amount of power concentrated within a jurisdiction should be correlated with its localness.
Nice thing: iPhone 6+
Human right: freedom of movement
Nice thing: Maserati
See the difference?
---
As for your second part about localization of politics, the tyranny of the majority is much more severe in hyper-local settings. Global issues like human rights cannot be entrusted to local governments whose local majorities are prone to divisiveness and discrimination.
Because even at this point, Net Neutrality is still less well protected by the EU than it was under our own national legislation.
I cannot in all good conscience support a union that has the power to undermine our civil rights. If Brits don't want those civil rights, that's their choice.
Brussels is not a force for good simply because in this case it would be an improvement for the Brits.
If you have concrete examples of poor civil rights in the UK, by all means share them, I'm not pretending things are perfect here, and would be happy to get a better grasp of where things could be improved.
Wishful thinking.
The European vision of capitalism is where you can own, say, a cafe or mobile app, and do what you want with it. However, something like a telecoms network or search engine is too important to be kept in the hands of ruthless big business, and the state needs to step in to control who said businesses deal with.
They talk about preventing monopoly, but even with infrastructure, technological shifts mean any purported monopoly constantly faces real competition. (Witness how IBM lost out to Microsoft, which lost out to the internet companies).
Private investment and private innovation is the best way to build infrastructure, and if the state wants to control how the infrastructure is used (and prevents the owners from cutting special deals with their largest potential customers), investment money stays away.
This has happened with pharmaceuticals - one reason there's been so much investment in viagra and plastic surgery is that more useful medical patents tend to be seized by government. It's also happening in the case of European telecoms: the net neutrality rules provide a disincentive to invest in 5G.
http://www.theverge.com/2016/7/10/12139700/telecom-companies...
(That article is negatively slanted, but gives a decent overview). Here's the actual report by the telcos:
http://ec.europa.eu/newsroom/dae/document.cfm?action=display...
Yes, I would rather have decisions made by people in Brussels that understand what they're doing.
I'd be happy to swap my overpriced RCN internet with TalkTalk or not have to get a new wheel on my bike every year thanks to the pot-holed roads of New York.
"In this context we must highlight the danger of restrictive Net Neutrality rules, in the context of 5G technologies, business applications and beyond. 5G introduces the concept of “Network Slicing” to accommodate a wide-variety of industry verticals’ business models on a common platform, at scale and with services guarantees.
Automated driving, smart grid control, virtual reality and public safety services are examples of use- cases with distinguished characteristics which call for a flexible and elastic configuration of resources in networks and platforms, on a continuous basis, depending on demand, context and the nature of the service. According to the telecom industry, BEREC’s draft proposal of implementation rules is excessively prescriptive and could make telcos risk-averse thus hampering the exploitation of 5G, ignoring the fundamental agility and elastic nature of 5G Network Slicing to adapt in real time to changes in end-user / application and traffic demand. The 5G objective of creating new business opportunities and satisfying future end-user needs would be at risk, with a regulation not coherent with the market demand evolution.
It is paramount to ensure 5G monetisation to drive investments. Monetisation can take place across the entire value chain with end-users, service providers and industry verticals in order to ensure fair returns, speed up adoption by end-users and ensure consumers are not alone in picking up the bill for the innovation that will help the business cases of the service providers. Operators should also be free to mix and manage different technology generations, mobile or otherwise, that are enabling 5G mobile technology to serve their customers optimally."
https://savetheinternet.eu/en/
However, according to Julia Reda above, the policies around zero-rating are still pretty unclear, and it seems they will be decided on a case-by-case basis (not great, but may be a little better than in the U.S., where the FCC seems to have no interest in dealing with zero rating at all).
It does cover this (search for zero-rating) although in a way that I find hard to summarise.
http://berec.europa.eu/eng/document_register/subject_matter/...
But it starts well:
>This Regulation aims to establish common rules to safeguard equal and non-discriminatory treatment of traffic in the provision of internet access services and related end-users’ rights. It aims to protect end-users and simultaneously to guarantee the continued functioning of the internet ecosystem as an engine of innovation.
Any source for this? I've only ever seen providers offer free Spotify membership, not free data.
Edit: Thanks for the responses. I had no idea this was happening.
They stopped offering this to new customers on August 2nd, 2016.
[1] https://www.telekom.de/hilfe/mobilfunk-mobiles-internet/mobi... (in German)
https://www.engadget.com/2013/01/21/spotify-signs-deal-with-...
[1] http://www.golem.de/news/netzneutralitaet-telekom-fuehrt-dro...
http://www.o2.cz/osobni/spotify/ (in czech)
http://www.wtf.pt/ Look for "APPS COM TRÁFEGO ILIMITADO" (Free data apps). You can see the apps below.
or
http://www.yorn.net/YORN/tarifario/yorn-x/index.htm#apps
I'm not even sure it's legal, but people don't really care/see it as a problem.
https://www.drei.at/portal/de/privat/services-und-apps/zusae...
"Kein Datenverbrauch" == Zero Rating.
https://www.podcat.com/podcasts/i63zqo-untether-tv-mobile-st...
That's why we have laws that forbid companies to pollute the environment, restrict child labor and the like. Consumers will choose the short term benefits for themselves over the long term benefits for the society.
I think you're missing the implication of the point.
If there is 'a lot of competition' - it makes cartel-like or colluding behaviour among carriers difficult, thereby facilitating de-facto net-neutrality.
Customers don't have to be aware of it.
And it's a reasonable argument: ensuring healthy and fair competition is almost always better than legislative controls, usually because regulations are often poorly conceived and effectuated, or at least, the market changes rapidly and the regulations fail to adapt.
I think that a reasonable net-neutrality law should probably be made both in Europe and in the US, that said, I'm weary of it being too onerous.
My position is also pragmatic: 'more competition' is unlikely in an industry with such massive barriers to entry etc..
This honestly isn't true, because if we had a marketplace for ISPs, most consumers would pick the cheapest option, which would probably be the one that subsidizes it's revenue from charging companies like Netflix. Some smaller companies that don't care about full market access wouldn't pay, and then you're at a tiered internet structure not unlike cable packages.
He's only saying it's a "red herring" because ISP monopolies and net neutrality are different issues.
The marketplace doesn't work that way. Neither Netflix or any other content provider has any interest in paying any ISP for the pleasure of serving their customers. Netflix would just refuse to pay the low cost ISP and tell it's customers to change ISPs if they complain.
The only reason Netflix is paying Comcast is because Comcast has enough market power and captive users to blackmail Netflix into paying them, lest Netflix be denied access. If there was any alternative to Comcast, Netflix would just say screw that.
The general idea is that a free market is more flexible and quicker to react than the government. It would be quicker to shape itself to the demands of the consumers. This could cover issues like net neutrality, antiquated infrastructure not being upgraded, etc. Prices would also probably go down.
I think this is an important issue alongside net neutrality. I also believe that some extra government regulation is necessary for utilities and essential services, so I'm not against government interference.
In general, the consumer benefits most when an industry has a lot of competition in it.
The thing to understand about net neutrality is it's a transfer of power from business to government. The devil is in the detail. If you look closely at the laws involved there are vague clauses that allow for extra government censorship and control in the future.
In basic terms, net neutrality sort-of makes sense in the US and makes less sense in the EU. It's a poisoned chalice created and pushed by do-gooders.
And is the common people the group who is the victim of the poisoned chalice?
The example of US federal government does not exactly support this point.
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX...
Driverless cars Medical applications (remote operations rooms were mentioned)
You have to give to telecoms - they built the infrastructure and are desperate to design some services that could become additional source of revenues. For now, it seems, the door is shut - maybe with the new automation coming they could dig it up - akin to "you don't want your house to send fire warning to city grid too slow, do you?".
Meteor http://www.killbiller.com/blog/2016/6/16/free-facebook-insta...
Eir: https://www.siliconrepublic.com/life/eir-meteor-mobile-socia...
These are the first 9, the other 10 are here: https://gist.github.com/daveloyall/a1112bb70412d77bebc809090...
Recital 1 =========
This Regulation aims to establish common rules to safeguard equal and non-discriminatory treatment of traffic in the provision of internet access services and related end-users’ rights. It aims to protect end-users and simultaneously to guarantee the continued functioning of the internet ecosystem as an engine of innovation.
Recital 2 =========
The measures provided for in this Regulation respect the principle of technological neutrality, that is to say they neither impose nor discriminate in favour of the use of a particular type of technology.
Recital 3 =========
The internet has developed over the past decades as an open platform for innovation with low access barriers for end-users, providers of content, applications and services and providers of internet access services. The existing regulatory framework aims to promote the ability of end-users to access and distribute information or run applications and services of their choice. However, a significant number of end-users are affected by traffic management practices which block or slow down specific applications or services. Those tendencies require common rules at the Union level to ensure the openness of the internet and to avoid fragmentation of the internal market resulting from measures adopted by individual Member States.
Recital 4 =========
An internet access service provides access to the internet, and in principle to all the end-points thereof, irrespective of the network technology and terminal equipment used by end-users. However, for reasons outside the control of providers of internet access services, certain end points of the internet may not always be accessible. Therefore, such providers should be deemed to have complied with their obligations related to the provision of an internet access service within the meaning of this Regulation when that service provides connectivity to virtually all end points of the internet. Providers of internet access services should therefore not restrict connectivity to any accessible end-points of the internet.
Recital 5 =========
When accessing the internet, end-users should be free to choose between various types of terminal equipment as defined in Commission Directive 2008/63/EC (1). Providers of internet access services should not impose restrictions on the use of terminal equipment connecting to the network in addition to those imposed by manufacturers or distributors of terminal equipment in accordance with Union law.
Recital 6 =========
End-users should have the right to access and distribute information and content, and to use and provide applications and services without discrimination, via their internet access service. The exercise of this right should be without prejudice to Union law, or national law that complies with Union law, regarding the lawfulness of content, applications or services. This Regulation does not seek to regulate the lawfulness of the content, applications or services, nor does it seek to regulate the procedures, requirements and safeguards related thereto. Those matters therefore remain subject to Union law, or national law that complies with Union law.
Recital 7 =========
In order to exercise their rights to access and distribute information and content and to use and provide applications and services of their choice, end-users should be free to agree with providers of internet access services on tariffs for specific data volumes and speeds of the internet access service. Such agreements, as well as any commercial practices of providers of internet access services, should not limit the exercise of those rights and thus circumvent provisions of this Regulation safeguarding open internet access. National regulatory and other competent authorities should be empowered to intervene against agreements or commercial practices which, by reason of their scale, lead to situations where end-users’ choice is materially reduced in practice. To this end, the assessment of agreements and commercial practices should, inter alia, take into account the respective market positions of those providers of internet access services, and of the providers of content, applications and services, that are involved. National regulatory and other competent authorities should be required, as part of their monitoring and enforcement function, to intervene when agreements or commercial practices would result in the undermining of the essence of the end-users’ rights.
Recital 8 =========
When providing internet access services, providers of those services should treat all traffic equally, without discrimination, restriction or interference, independently of its sender or receiver, content, application or service, or terminal equipment. According to general principles of Union law and settled case-law, comparable situations should not be treated differently and different situations should not be treated in the same way unless such treatment is objectively justified.
Recital 9 =========
The objective of reasonable traffic management is to contribute to an efficient use of network resources and to an optimisation of overall transmission quality responding to the objectively different technical quality of service requirements of specific categories of traffic, and thus of the content, applications and services transmitted. Reasonable traffic management measures applied by providers of internet access services should be transparent, non-discriminatory and proportionate, and should not be based on commercial considerations. The requirement for traffic management measures to be non-discriminatory does not preclude providers of internet access services from implementing, in order to optimise the overall transmission quality, traffic management measures which differentiate between objectively different categories of traffic. Any such differentiation should, in order to optimise overall quality and user experience, be permitted only on the basis of objectively different technical quality of service requirements (for example, in terms of latency, jitter, packet loss, and bandwidth) of the specific categories of traffic, and not on the basis of commercial considerations. Such differentiating measures should be proportionate in relation to the purpose of overall quality optimisation and should treat equivalent traffic equally. Such measures should not be maintained for longer than necessary.