Opinion of the Committee of the Regions on the 'Green Paper on the convergence of the telecommunications, media and information technology sectors and the implications for regulation: Towards an information society approach'
Date: 1998-09-17
Institutions: European Committee of the Regions
Subjects: approximation of laws, economic convergence, information technology, pluralism in the media, telecommunications

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4.9.
Finally, the Committee of the Regions would
emphasize that the pace of technological change is such
that new technology is constantly being introduced;
consequently, there is a continuous need for standard-
ization. In connection with this ongoing process, it is

important that the Committee of the Regions — which
represents the general public and political bodies at local
and regional level — should continue to be involved at
an early stage.

Brussels, 17 September 1998.

The President

of the Committee of the Regions

Manfred DAMMEYER

Opinion of the Committee of the Regions on the ‘Green Paper on the convergence of the
telecommunications, media and information technology sectors and the implications for
regulation: Towards an information society approach’

THE COMMITTEE OF THE REGIONS,

(98/C 373/05)

having regard to the Green Paper on the convergence of the telecommunications, media and
information technology sectors, and the implications for regulation: Towards an information
society approach (COM(97) 623 final);

having regard to the decision taken by the European Commission on 5 December 1997, under
the first paragraph of Article 198c of the Treaty establishing the European Community, to
consult the Committee of the Regions on the matter;

having regard to the decision taken by the Bureau of the Committee of the Regions on 13 May
1998 to instruct Commission 3 — Trans-European Networks, Transport, Information Society
— to draw up the relevant opinion;

having regard to the draft opinion (CdR 149/98 rev) adopted by Commission 3 on 7 July 1998
(rapporteurs: Mr Koivisto and Mr Nash),

adopted unanimously the following opinion at its 25th plenary session of 16 and 17 September
1998 (meeting of 17 September).

The Committee of the Regions

general social objectives; these objectives will undoubt-
edly accentuate the need for competition legislation;

considers the launch of a debate on the develop-
1)
ment of regulation in response to convergence to be of
the utmost importance;

endorses the Commission’s view that regulation

2)
should be kept to the bare minimum;

3)
believes that extensive international standard-
ization and the global competition it leads to is a
better option from the regional standpoint than market
protection based mainly on pan-European standards
and regulation;

notes that, while convergence entails risks for

5)
regions, it offers new opportunities for active players;

6)
in assessing the effects of convergence, draws
attention to the existence of large regional disparities as
regards media and infrastructure, a factor which does
not receive adequate attention in the green paper;

points out that the green paper places too much
4)
emphasis on market development and not enough on

7)
notes that it is considers the threat posed by
convergence to content production in Europe to be a
cause for serious concern;

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8)
does not believe that the positive effects of conver-
gence on the level of total employment will be significant,
although there are likely to be major changes in
the location of jobs within the sectors affected by
convergence;

cautions against overestimating the speed of devel-
9)
opment and stresses that the development of traditional
infrastructure in the sectors affected by convergence will
continue to be important for the majority of the
population for a long time to come;

1. Background

1.1.
The Commission’s Green Paper on the conver-
gence of the telecommunications, media and information
technology sectors and the implications for regulation
seeks the views of all the players in the communications
market with a view to deciding the scope and extent of
a regulatory framework to cover this whole area.

10)
hopes there will be recognition of the important
role played in fostering regional cohesion by research
projects which enable existing infrastructure to be
upgraded;

1.2.
The green paper responds to the requirement for
debate. It is deliberately interrogative. It analyses issues,
it identifies options and it poses questions for public
comment. It does not take positions at this stage nor
reach conclusions.

11)
highlights the need to develop a universally
applicable code of practice for all communication
services in place of legislation, particularly with regard
to the protection of privacy, the protection of minors
and other public interest objectives. Such a code must
go hand in hand with legislation penalizing such offences.
European rules may be necessary since it is doubtful
whether such legislation at national level will suffice;

reminds the Commission of

12)
the continuing
importance for remote regions of networks which use
analogue frequencies and of the reduced opportunities
for operators in a competitive environment to undertake
replacement investment in these regions, and hopes that
these special circumstances will be taken into account
when considering the future of frequencies in these
regions;

considers it important to ensure access to com-
13)
peting information network services in all regions in the
future by, for example developing the universal service
obligation and exploiting the opportunities offered by
convergence;

14)
stresses that, in public broadcasting in particular,
national and regional operators have far the best
information at their disposal for taking decisions on,
for example, licensing;

15)
believes that the best option in the adaptation of
existing regulation is to create a new framework for
many on-line and interactive services, to co-exist with
those currently applied and needed to be built on
to traditional telecommunications and broadcasting
services.

2. Content of the green paper

2.1.
Convergence in the field of communications is
defined at its simplest as the ability of different network
platforms to carry essentially similar kinds of services,
or the coming together of consumer devices such as the
telephone, television and personal computer.

2.2.
Perhaps the most radical examples of the diversity
of convergence in the telecommunications area is the
Internet. The green paper points out that the Internet is
both the symbolic and prime driver of convergence. It is
a vehicle for the delivery to users of both existing services
(electronic mail, video, sound voice telephones and
completely new services, e.g. the Worldwide Web). In
this context it is interesting to note that the Internet is
doubling its number of users each year.

2.3.
The Internet has developed differently from
traditional broadcasting and the telecommunications
services.
It has essentially been user-driven. The
decentralized nature of the Internet is seen by many as
the single main reason for its success. Its convergence of
separate communication systems is exemplified in its
broadcast content, which is traditionally regulated, and
private communication, which is traditionally unregu-
lated. These different traditions constitute one of the
main challenges of Internet regulation.

Recommends,

16)
in respect of the options put
forward by the Commission, a combination of option 1
and option 2, i.e. the creation of a new framework for
on-line and interactive services to co-exist with those
currently applied and needed still to be built on.

2.4.
In the area of economic and industrial competi-
tiveness the green paper points out the danger that if
Europe fails to take advantage of the opportunities
provided by convergence it could be left behind, as other
major trading blocks reap the benefits of a more positive
approach.

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2.5.
The green paper points out that the EU needs to
strengthen the competitiveness of its companies so that
the public can get the most out of opportunities offered
by the media, and so that market growth can be
transformed into jobs.

It also points out the need for greater staff
2.6.
training so that people can be provided with the right
mix of skills in an ever changing telecommunications
workplace.

2.7. One example that the green paper gives is the
regulatory uncertainty that arose during the last French
general election campaign, where rules prohibiting the
publication of opinion polls one week prior to the
election applied to off-line media but not to polls
published on the Internet. A number of editors in these
circumstances ignored the ban which placed traditional
media at a disadvantage.

2.8.
It is feared that the process of obtaining regulat-
ory clearance in all Member States and potentially from
different regulatory bodies for a particular package of
services may create substantial overheads for those
wanting to operate on a pan-European basis.

The green paper identifies some regulatory bar-

2.9.
riers. These are:

1) definitions;

2) market entry and licensing;

— independent and effective regulators will be central

to a converging environment.

3. General comments

3.1.
The Committee of the Regions congratulates the
European Commission for launching this very important
debate. Although a term of recent origin, convergence
is proving to be one of the key concepts of the information
society.

Convergence in both markets and technologies
3.2.
is an intrinsic part of the development of the information
society which must be accepted as such, along with its
benefits and drawbacks, and which in terms of the form
it takes and the regulatory issues it raises does not differ
essentially from, for example, the changes currently
under way in the financial sector.

Like the information society in general, conver-
3.3.
gence implies major structural changes at local and
regional level, with a potentially adverse impact on
regional development.

But like the information society too, convergence

3.4.
offers regions new tools and opportunities.

3) access to networks, to conditional access systems

and to content;

4) access to frequency spectrum;

3.5.
The primary objective of Union measures to be
drawn up on the basis of the green paper and the
feedback it generates should be to find a balanced
approach which, on the one hand,

5) standards;

6) pricing;

7) individual consumer interests.

2.10.
The green paper offers a set of five principles
which could offer a common basis for the future
approaches in the sectors affected by convergence. These
are:

a) guarantees cultural development and the competi-
tiveness of markets and the relevant sectors in
Europe;

b) but which, on the other hand, ensures that regions
are able through their own action, backed up where
necessary by EU regional policy, to exploit the
opportunities provided by convergence and the
development of the information society in general.

— regulation should be limited to what is strictly
necessary to achieve clearly identified objectives;

— future regulatory approaches should respond to the

needs of users;

— regulatory decisions should be guided by a need for

a clear and predictable framework;

— ensuring full participation in a converged environ-

ment;

Although convergence has major implications
3.6.
for Europe’s regions in particular, the green paper takes
no account at all of the regional viewpoint, not even the
very marked regional differences in the way the services
of the sectors affected by convergence are used. Some
studies show that at national level alone the share of the
press in the media markets of Member States ranges
from 25 % to 75 %, that of television from 9 % to 62 %
and that of radio from 3 % to 17 %. Differences between
Member States and regions as regards use of the Internet
are even larger.

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4. General implications of convergence for regions

4.1.
The Committee of the Regions notes that conver-
gence could have a negative impact on regions and
regional cohesion in Europe if:

a)

large global companies operating in the content and
communications sectors gain a position where they
alone can determine the content of information
society services and geographical access to these
services, in accordance with their own commercial
needs;

b) regulation continues to develop solely on the basis
of broadcasting and communications technologies;

c)

job losses in traditional sectors affected by conver-
gence (radio, television, press) exceed the capacity
of mainly small firms to create new jobs in these
sectors.

4.2.
In the view of the Committee of the Regions,
convergence affords regions new opportunities such as:

a) access to the same services via different user inter-
faces, thus enabling regions to utilize the solution
which is the best possible from the point of view of
the consumer and the region, such as for example:

— access to the Internet via a computer, television
and/or mobile telephone using a fixed data
network, a telephone network, satellites, a cable
TV network and/or networks originally intended
for energy distribution;

— the Internet’s driving force in promoting conver-
gence, with the development of new capacity in
telecommunications networks and other techni-
cal solutions has become an increasingly diversi-
fied tool;

b) regardless of location, both private and public
producers of information can reach larger numbers
of consumers because the options for accessing these
services are increasing;

c) convergence is forecast to lead to the setting-up of
numerous new small firms whose activities will not
be dependent on location.

of its position as regards the kind of information society
it would like to see Europe guided towards through,
inter alia, regulation of convergence.

5.2.
In the green paper the Commission gives clear
priority to the general market interest whereas public
interest objectives are frequently seen as barriers or
factors which passively adapt. Even this is an acceptable
starting point, because it is essential for employment
that the business sector can respond quickly to change
on global markets. The Committee of the Regions
nevertheless feels that the easiest way to give shape and
substance to regulation would be to state from the outset
what kind of information society it is wished to achieve
in Europe.

6. Question 1: The nature and impact of convergence

today

6.1.
The green paper describes the many forms which
the convergence phenomenon takes. While, of course,
these are indicative of the direction of change, overall
the volumes involved are still small. The Committee of
the Regions notes that it is very difficult on the basis of
current trends to forecast consumer behaviour, although
ultimately it is the latter which determines the substance
and speed of change. Convergence is currently impacting
on the behaviour of individuals and businesses at many
different levels and in different ways, but having no
impact at all on the behaviour of the major part of the
population.

6.2.
The Committee of the Regions considers the
weakened position of European content in the sectors
affected by convergence to be a worrying development.
Indeed, one of the key issues of the debate is how to
secure European content in the light of convergence
characterized as a largely market-driven process.

7. Question 2: The socio-economic, business and con-

sumer impact of convergence

7.1.
The Committee of the Regions considers the
job-creation impact of convergence to be a very short-
lived phenomenon. It is nonetheless clear that conver-
gence will lead to major changes as regards the location
of jobs. It is equally clear that many traditional occu-
pations in the sectors affected by convergence will
eventually disappear.

5. Convergence and the European Information Society

5.1.
The Committee wishes to draw special attention
to the fact that in formulating the questions serving as
a basis for debate the Commission gives no indication

7.2. On the other hand, convergence is conducive to
conditions which make it easier for very small but
flexible firms to enter the sectors concerned and operate
successfully. The cycle of change in the business world
is likely to accelerate among the smallest and largest

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firms; it is unlikely that a significant number of medium-
sized firms will be able to operate in the sectors affected
by convergence for a prolonged period in the future.

Since overall job losses will depend primarily on
7.3.
how easily new small firms can enter the sectors and
perhaps on the ability of individuals who lose their jobs
to find work on a self-employed basis, a crucial question
here is whether the red tape associated with regulation
in the sectors will pose insurmountable barriers for new
entrants. Looked at from this perspective, ease of entry
could mean less regulation (in terms of licensing, etc.)
but also stricter regulation, particularly as regards
public interest objectives. In that case a comprehensive
approach, for example with regard to protection of
privacy, will help new businesses and the sectors in
general
these
to better understand the content of
objectives.

7.4.
Given the major differences that exist between
Europe’s regions in terms of usage rates and patterns
for television, radio, the press, new network services
etc., it is only natural that the effects of convergence
vary greatly as well. In the case of technological
infrastructure (broadband data, cable TV and mobile
telephone networks) convergence can be expected to be
most rapid and widespread in regions with the highest
usage rates.

7.5.
The Committee of the Regions draws the Com-
mission’s attention to the great differences that currently
exist between Member States, and hence regions, as
regards use of various means of communication.

7.6. Not even in the most advanced countries do
multimedia computers and the Internet enjoy a dominant
position, and it is possible that the present rate of growth
will level off in the future. Although Europe must remain
competitive in this area, the Committee of the Regions
takes the view that the definition of objectives and
values at enterprise or individual level must not, for a
long time yet, be made solely in terms of a business
world based on information networks.

7.8.
As regards the large differences which exist
between regions, the Committee of the Regions attaches
particular importance to RTD projects which enable
better use to be made of investment that has already
been carried out rather than to projects which,
if
implemented on a wide scale, would require the expendi-
ture of exorbitant sums on infrastructure. It is therefore
interesting to note in this context the work which has
been done to upgrade the transmission speed of ordinary
copper telephone cable to the level required by multi-
media.

8. Question 3: Barriers to convergence

The green paper discusses both existing and
8.1.
potential barriers to convergence. The Committee of
the Regions has nothing to add to this list, but would
stress that some barriers, such as, for example, fragmen-
tation of public broadcasting and licensing issues in
general, are, from the regional point of view, often key
factors influencing the supply of content and can with
equal justification be regarded as social requirements
for convergence.

9. Question 4: The impact of current regulation on

convergence

9.1. Market forces are certain to continue to play a
key role in regulating development, and convergence
both provides an opportunity and imposes an obligation
for convergence in legislation and thereby a reduction
in legislation. If, as is to be hoped, priority is given to
public interest objectives, this is likely to increase the
need for competition legislation.

The green paper gives examples of how the
9.2.
regulatory treatment of a given service differs according
to the technology used to deliver it to the consumer.
This shows that many of the underlying principles of
regulation will have to be called into question. The
Committee of the Regions would nevertheless emphasize
that, even in the sectors affected by convergence, there
are fundamental differences between products so that
changing existing principles through convergence in
regulation could have undesirable effects.

10. Question 5: Overcoming the barriers — Getting
the right regulatory framework for business and
for consumers

7.7.
The Committee of the Regions stresses that it
must not be forgotten in the debate on convergence in
telecommunications that traditional media forms are
still very important for Union citizens and democracy,
for example. It is therefore necessary to invest in the
development of communications media such as digital
radio and television as well, and not just in information
networks.

10.1.
The Committee of the Regions takes the view
that the technical definitions cited as barriers in the
green paper will have to be developed on an ongoing
basis by, for example, responding to the convergence
process and ensuring that, as far as possible, the same
content is accorded the same treatment regardless of the
technology which is used to deliver it. The Committee
would nevertheless stress that for some means of

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communication the latter consideration may be less
important from the regulatory point of view than the
specific features of the sector concerned.

— public broadcasting;

— ensuring privacy and data protection;

10.2.
The Committee of the Regions would stress
that the EU’s most important regulatory task is to
establish an explicit code of practice which would make
it easy for businesses, among others, to take on board
e.g. requirements relating to the protection of data
affecting personal privacy.

10.3.
The green paper proposes giving consideration
to the setting of a clear timetable for the termination of
analogue services. However, in many regions analogue
networks have a long history and are operated by
telecommunications firms which are in a monopoly
position and whose operating licences or the relevant
regulation also include responsibility for geographical
coverage. For this reason their geographical coverage is
often the most extensive. Moreover, with the liberal-
ization of telecommunications, the new digital wireless
services have so far been concentrated mainly in areas
where user volumes are highest. Up till now, there has
been no indication in countries which have extensive
analogue mobile telephone networks that digital services
are rapidly replacing analogue services in the most
remote regions. The Committee of the Regions therefore
considers it to be of the utmost importance to retain the
frequencies of analogue networks for the time being
whilst deploying the available means to speed up the
spread of digital services to those regions which market
operators have not considered sufficiently attractive.
Rather than set a specific date the timing of the
changeover should be linked to the situation prevailing
in different regions.

10.4.
is in
The Committee would stress that
no-one’s interest to protect one’s own markets by means
of standardization. Rather, standardization must take
place globally, in particular so as to ensure the provision
of services to consumers at an affordable price.

it

Since in principle convergence allows the same
10.5.
services to be accessed via different types of interface, it
has already had a positive impact on the possibilities
of various user groups (for example, people with
disabilities) to use these services. Clearly, convergence
which is driven by market forces is not, as such, receptive
to the special needs of small user groups but with public
funding the development of these services will become
technically easier and cheaper.

— data security, e.g. encryption and digital signatures;

— cultural diversity;

— protection of minors;

— public order.

11.2.
In the view of the Committee of the Regions
general regulatory frameworks based on codes of good
practice should be developed, particularly with regard
to public interest objectives such as data protection,
cultural diversity and protection of minors. These
rules would be universally known and adopted as key
principles by all operators in the sectors affected by
convergence. As loopholes are continually coming to
light in existing regulation, convergence can help to
remedy this situation and at the same time meet public
interest objectives.

11.3.
The Committee considers achievement of uni-
versal service to be a key requirement for the information
society in Europe. Convergence offers new ways of
achieving this objective by enabling the same services to
be accessed easily via different user interfaces and
networks.

11.4.
Convergence has two implications as regards
definitional issues: on the one hand the need to define
universal service in terms of a specific technology will
diminish; on the other hand in some fields, notably data
security, there will be a need for more detailed definitions
than at present.

A considerable number of public service objec-
11.5.
tives are such that the responsibility for them must be
borne uniformly and equally by all operators. The
Committee of the Regions also considers it important
that in the future the universal service obligation be
widened to include at least two genuinely competing
options. From the regional point of view, there will
continue to be a major need for public broadcasting
networks in the future, but these same networks could
be put at the disposal of an ever-increasing number of
service providers.

11. Question 6: Securing public interest objectives in

the light of convergence

11.1.
green paper include:

The public interest objectives mentioned in the

— universal service, i.e. the universal availability of

specified services at an affordable price;

11.6.
The Committee of the Regions would especially
like to draw the Commission’s attention to the contradic-
tion which exists in the sectors affected by convergence
between free competition and the universal service
obligation and hopes that workable definitions can be
developed in this regard. For example, some operators
are subject to regional obligations while others are free
to focus on the best and most lucrative markets. One

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option might be to make wider and systematic use of
regional policy instruments, such as the Structural
Funds, to ensure wide coverage of universal service, in
which case it could be decided at regional level what
universal service means in each region. Examples of
the use of Structural Funds resources to support the
implementation of universal service can be found in at
least the cohesion countries and Objective 6 regions in
Sweden.

Existing tax systems could be revamped to bring
11.7.
the sectors affected by convergence better within their
scope with a view to using public funds to fulfil the
universal service obligation and create alternative jobs.

12. Question 7: The future shape of regulation

12.1.
The Committee of the Regions agrees with the
Commission on the need for a reassessment of regulation.
The green paper discusses the different levels of regu-
lation from a number of angles. Perhaps the key issue
here is whether to regulate primarily on the basis of the
technology used to deliver services (data network, radio,
telephone, television, etc.) or the content of services, in
which case the principles related to, for example, data
protection, content, intellectual property rights and even
commerce and consumer protection would, as far as
possible, be independent of the means of delivery. In the
view of the Committee of the Regions, regulation which
is directed mainly at the technology used to deliver
services is quickly losing its relevance as convergence
gathers pace.

12.2.
In many Member States regulation is based
on principles which are old and partly outmoded.
Development of the regulatory framework must, of
course, take account of the effects of convergence, as
indeed has already been done to some extent. Clearly,
each Member State can itself decide on a solution
which is the best and most effective in relation to its
administrative structures.

The Committee of the Regions considers that a
12.3.
common regulatory approach is still required in areas
such as, for example, allocation of frequencies and
licensing so as to ensure smooth and balanced develop-
ment and that, in principle, existing levels of adminis-
tration are appropriate for this purpose. Nor should any
restrictions be placed on the possibility of local and
regional authorities to take decisions pertaining to, for
example, providers of services over cable TV networks
as authorities at this level have the best knowledge as
regards consumer needs.

13. Question 8: The international aspects of conver-

gence

13.1.
In the view of the Committee of the Regions,
the effects of new regulatory measures will be minimal,
although they could have a negative impact on the
competitiveness of Europe if they are not applied on a
global basis.

13.2.
In connection with planning additional steps,
the Committee of the Regions wishes to draw the
Commission’s attention to the central role played by
local and regional operators in realizing the information
society in Europe. The Committee has set out arguments
in support of this view in a number of opinions on the
information society.

13.3.
Consequently, cooperation between EU regions
and regions in eastern and central European countries
and support for such activities are one of the most
important ways of encouraging these countries to exploit
the opportunities offered by convergence.

14. Question 9: Principles and possible approaches in

the light of convergence

14.1.
The Committee of the Regions takes the view
that convergence will create an entirely new basis for
regulation over the next few years and at the same
time partly undermine the justification for existing
sector-specific regulation.

14.2.
The Committee of the Regions would also like
to point out that there are several other regulatory
mechanisms at work within the Community which have
a major impact on convergence but which are not
mentioned in the green paper. The most important of
these is, of course, taxation.

14.3.
The green paper concludes by presenting three
options for the development of regulation, given that it is
judged that convergence requires adaptation of existing
regulatory approaches:

a) seek to build on, and if appropriate, extend existing

frameworks, rather than create new ones;

b) create a new framework for many on-line and
interactive services, to co-exist with those currently
telecommunications and
applied to traditional
broadcasting activities;

c) seek to create a comprehensive framework applying
similar regulatory approaches to all three sectors.

14.4.
As far as public broadcasting is concerned, the
Committee of the Regions notes that there is no
justification for the transfer to Community level of
decision-making powers which currently lie with
national and, to some extent, regional authorities.

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14.5.
A considerable part of existing legislation, or at
least the principles underpinning it, is directly applicable
to electronic services in areas such as intellectual property
rights, privacy protection, etc. Similarly, consumer
protection requirements in electronic commerce do not
differ significantly from those governed by existing rules
in other areas.

14.6.
The Committee of the Regions considers a
combination of the first and second approaches to be
the best solution, namely to create the new framework
for many on-line and interactive services, to co-exist
with those currently applied and needed still to be built
on.

Brussels, 17 September 1998.

The President

of the Committee of the Regions

Manfred DAMMEYER

Opinion of the Committee of the Regions on ‘The significance of the intra-EU duty free
regime to the regions’

(98/C 373/06)

THE COMMITTEE OF THE REGIONS,

having regard to Council Directives 91/680/EEC (1) of 16 December 1991 and 92/12/ECC (2)
of 25 February 1992 as they relate to the abolition of the intra-EU duty free regime on 30 June
1999;

having regard to its Bureau decision taken on 12 March 1998, under the fourth paragraph of
Article 198c of the Treaty establishing the European Community, to draw up an own-initiative
opinion on the subject and to direct Commission 6 — to undertake the preparatory work;

having regard to the EP’s Directorate General for Research’s Working Document of October
1997 on ‘The Economic and Social Consequences of Abolishing Duty Free with the EU’ (3);

having regard to the conclusions of the EP public hearing on duty free held on 29 October
1997;

having regard to the 3 April 1998 EP Resolution on the abolition of duty free sales (4);

having regard to the draft opinion (CdR 109/98 rev.) adopted by Commission 6 on 20 July
1998 (Rapporteur: Mrs McCarthy-Fry, Co-rapporteur: Mr Cummins);

whereas the Committee of the Regions has already drawn attention to the importance of
tourism and transport infrastructures to the regions, in for example, the following opinions:

(1) OJ L 376, 31.12.1991.
(2) OJ L 76, 23.3.1992.
(3) EP’s Directorate General for Research’s Working Document of October 1997 on ‘The Economic and

Social Consequences of Abolishing Duty Free with the EU’ (ref. PE 167.048, W-30).

(4) European Parliament Resolution of 3.4.1998 (ref. PE 268/233).