Procedure and House Affairs Committee on April 8th, 2014

[The Chair, Conservative, Joe Preston]

I call to order meeting number 29 of the Standing Committee on Procedure and House Affairs, pursuant to the order of reference of Monday, February 10, 2014, for the study of Bill C-23, an act to amend the Canada Elections Act and other acts and to make consequential amendments to certain acts.

We have Monsieur Lortie with us this morning. Mr. Conacher is supposed to be joining us, but I'll let Monsieur Lortie go ahead with his opening statement and if, by then, Mr. Conacher has come, he can give his opening statement. If not, we'll proceed with questions, and put Mr. Conacher on the next panel, I think.

Monsieur Lortie, welcome. It's great to have you here today. If you have an opening statement, we'd love you to give it now.

[Pierre Lortie, Senior Business Advisor, Dentons Canada, As an Individual]

Mr. Chairman, first I'd like to thank you for the invitation to testify before your committee.

The Canada Elections Act is one of the few federal statutes that is consulted and used by a large number of Canadians. Whenever elections are held, thousands of Canadians must be able to understand this legislation, which sets out the procedures for the registration of voters, the administration of the vote and the conduct of election campaigns.

The scale and scope of such an operation must not be underestimated: there were 66,146 polling stations in the election of May 2, 2011, including 1,669 mobile polling stations, and approximately 350,000 volunteers and temporary election officers participated in the process.

In my opinion, any amendments to the Canada Elections Act must reflect the values upon which Canadian society is founded and must flow from the fundamental principles that characterize a sound electoral democracy. One of those key principles is guaranteeing and promoting citizens’ right to vote.

During the 1980s, Canada took pride in the fact that the average proportion of citizens who participated in federal elections was 75%—a voter turnout rate far in excess of those reported in many western democracies, including the United States. Unfortunately, this is no longer the case: the average voter participation rate for the five federal elections held since the year 2000 is only 61.9%, which is not much higher than the participation rates for U.S. presidential elections. This is a shamefully low voter turnout rate. Any properly thought out reform of our electoral statutes and regulations must, first and foremost, seek to correct this situation.

The provisions of the bill extending the voting period at advance polling stations constitute a measure that meets this fundamental objective. Unfortunately, other measures, such as those concerning the use of voter information cards as proof of identity and the practice of one elector vouching for the identity of another, are ill advised. This last provision undoubtedly contravenes the provisions of the Canadian Charter of Rights and Freedoms. The Charter is unequivocal on this issue. It says: “Every citizen of Canada has the right to vote...” It has been clearly established in case law that a right guaranteed under the Charter can only be restricted insofar as an overriding public interest is demonstrated and, in that case, only insofar as the imposed restrictions are justified within the meaning of section 1 of the Charter and have a minimal adverse effect on a fundamental right enjoyed by Canadian citizens.

Banning, for specious reasons, these practices that have not so far been the subject of widespread complaints from candidates across Canada and which the Chief Electoral Officer of Canada considers essential for allowing thousands of Canadians to exercise their right to vote, does not meet the criterion of proportionality and is not consistent with the sense of ethics that must prevail when such matters relating to the very pillars of our democracy are being considered.

The second key principle is ensuring the fair and equitable nature of the electoral process. To ensure that the electoral process remains fair and equitable, the Canada Elections Act imposes spending limits on all who participate in election campaigns, including private individuals and groups who are independent of the candidates and parties. Bill C-23 does not call into question these basic provisions, the just and reasonable nature of which has been confirmed in decisions by the Supreme Court of Canada. However, this goal is undermined when ambiguous provisions, encouraging circumvention of the rules and undermining Elections Canada’s ability to verify and confirm that the practices adopted do not contravene the Act, are incorporated into the legislation. This is the case with section 376(3), which makes it possible to exclude from election expenses the commercial value of services provided to a registered party for the purpose of soliciting contributions from individuals who contributed at least $20 in the five years preceding the date of the vote.

I do not deny that it would be worthwhile for a party to solicit individuals who have previously supported a party or one of its candidates. However, if the cost of this activity is too high to fit under the expenditure ceiling, transparency should be exercised and the ceiling raised by a reasonable amount, rather than undermining Canadians’ confidence in our electoral system by adopting provisions that encourage reprehensible behaviour and imposing additional persnickety rules on our parties.

The third principle is that of bolstering the primacy of political parties in Canada’s political system.

Political parties play a vital role in our parliamentary democracy, in particular through the profound influence they have over access to the House of Commons. The erosion of Canadians’ confidence in political parties, as evinced, among other things, by how difficult it is for parties to recruit new members, does not bode well for the future. Although this phenomenon is only a partial reflection of current social trends that find expression in so many other ways, political parties are not helping their situation by refusing to conform to social standards that are perceived as normal requirements in an advanced society.

Bill C-23 would have made a useful contribution in this regard if provisions had been added to ensure that political parties were required to produce documents in support of their spending reports. Parties received more than $30 million in public funds in 2011. Also, political parties should be subject to rules concerning the protection and use of personal information. Such requirements are imposed on businesses, and rightfully so. No legitimate reason exists to exclude political parties and their associations from a similar requirement.

The final principle is that of boosting Canadians’ confidence in the integrity of the electoral process. In its work, the Royal Commission clearly identified the need for a mechanism that would allow the Chief Electoral Officer to issue interpretation notes and guidelines on the application of that act. Such a mechanism is included in the electoral legislation of many of the world’s leading democracies, and the resulting benefits are well documented. Consequently, Bill C-23’s establishment of such a mechanism is to be commended.

As to the detailed terms and conditions involved, I believe your committee would do well to examine how other democracies, such as the United Kingdom, for example, fared in their implementation of such provisions.

Bill C-23 fills another important gap in the existing legislation by adding provisions concerning elector calling services. Overall, the proposed measures are consistent with the recommendations of the groups of experts who studied this issue, particularly those formulated by the IRPP. You have already heard suggestions for improving the new regime, in particular with regard to the information retention period and the advisability of adding to the list information that must be kept, such as the telephone numbers that have been called. In any case, it is crucial that the mechanism concerning calling services be in force when the next election is held.

The proposed regime does not prevent a third party from signing an agreement with an elector calling service provider; it frames this activity. That being said, I think it would definitely be preferable for the cost of such a service to be expressly recognized in the definition of election advertising expenses.

In conclusion, I would like to say that Bill C-23 concerns several other fundamental aspects of our democratic regime, some of which I could not touch upon in the amount of time allotted to me. I would of course be pleased to discuss them during the question period, should you deem it appropriate to bring them up.

[The Chair, Conservative, Joe Preston]

Thank you, Mr. Lortie.

Mr. Conacher, it's great to see you again. If you have an opening statement, we'll hear from you now.

[Duff Conacher, Co-Founder and Board Member, Democracy Watch]

Thank you very much for this opportunity to testify on this very important bill. I'm especially honoured to be testifying beside Monsieur Lortie.

I really need to practice my French.

There are many technical terms with regard to this proposed legislation, so I will make my remarks in English. I welcome your questions afterwards.

Democracy Watch's position is that there are 10 measures in Bill C-23, the so-called fair elections act, that are of concern that will actually make federal elections more unfair. I'm going to focus on six priorities that we've identified and summarize those. I'll go through a few measures that the bill fails to include, and those measures are needed to make federal elections more fair.

The six really unfair measures in Bill C-23 are as follows.

As Monsieur Lortie highlighted, there's the prohibition of one voter vouching for the identity of one other voter, and the prohibition on the voter registration card ever being certified as a piece of valid ID. Together, these changes will make it more difficult for hundreds of thousands of voters to vote, and so they should be removed from Bill C-23.

Instead, the voter registration card should be added to the list of valid ID. To solve the problem of irregularities with vouching that has been documented, Elections Canada should be empowered and provided with adequate funding to hire and fully train all election workers well before each election, and to also make the voter registration list and ID checking even more accurate. I'm quite sure there is a compromise, as other jurisdictions have found on this issue, that will remove and not increase barriers for hundreds of thousands of people voting.

The second area of concern for Democracy Watch is the failure of the bill overall to democratize the federal political finance system by reducing the annual donation and loan limits to an amount an average voter can afford, and the failure to re-start the annual per-vote funding for parties, which was the most democratic aspect of the political finance system, given that it was based on votes received by each party.

There are still loopholes that are left by the bill on gifts and donations to certain types of candidates. The hike in the donations limit for individuals in Bill C-23 are huge hikes in some cases and hugely undemocratic. An average Canadian cannot afford $3,000 a year. That would be the new maximum limit when you combine the donation to parties and the combined donation that's allowed to riding associations of each party.

Certainly, many candidates will not be able to afford to donate $5,000 to their own campaign, or as a party leadership candidate, $25,000 to their own campaign. If you're going to uphold the fundamental democratic principle of one person, one vote, donation limits must be set at a limit that an average person can afford; otherwise, you're allowing wealthy people to use money to have unethical and undemocratic influence over parties and candidates.

In the area of loans, while the loan limits on individuals are good, allowing banks to make unlimited loans to parties and candidates is dangerously undemocratic, as well. Banks are federally regulated and they will be able to pick and choose candidates to support with loans. That's a huge favour for a candidate, even though the candidate has to pay it back.

If the candidate wins, just the fact that they were boosted by a bank loan will be a favour that will put that MP, if they're elected, in a conflict of interest. It's better if all candidates have to reach out to as many voters as possible and build a democratic base of support, not a base of support from wealthy interests and banks.

The third area of concern is the change, as Monsieur Lortie also highlighted, to not count the amount spent on communications for fundraising purposes in the total amount parties are allowed to spend during election campaigns.

This is the first loophole that has been created in spending or donation limits since spending limits were first established in 1974. Forty years have passed and the trend through the whole 40 years has been to close loopholes. This is the first loophole that has been actually created, and like any loophole, it will very likely be abused to hide millions of dollars of unaccountable spending.

The failure to empower Elections Canada in the bill to appoint the auditors for all the parties, riding associations and candidates, and allowing these entities to choose their own auditors is the fourth area of concern, and relates to the spending loophole because Elections Canada will not have the right to all the documentation needed to ensure that loophole has not been exploited to exceed the legal campaign spending limits. This is essentially allowing the parties, candidates, and riding associations to audit themselves, and in combination with this loophole, is essentially a recipe for corruption.

The fifth area of concern is the failure to empower Elections Canada to appoint all election workers, and instead move in the other direction by extending the dangerously unethical power of political parties and candidates who won or came second in the previous election to force returning officers to appoint even more front-line election workers.

The sixth area of concern is the failure to require that the Commissioner of Canada Elections and the Director of Public Prosecutions disclose all of their rulings on all complaints. Instead, the bill requires them to keep all of that information secret. This will make it impossible to hold the commissioner and the director accountable if they make unfair, biased, or improper rulings or enforcement decisions.

Overall, even if these six changes that we're calling for were made, there are other areas that need to be addressed to make federal elections actually fair. We need an honesty in politics law so that parties and candidates can't bait voters with false promises or break promises after elections. We need to change the voting system so that it is more fair and gives parties the number of MPs based on actual voter support, regulate nomination races, have Elections Canada run the debates, and overall give all of the watchdogs more powers, and more clear powers, to ensure compliance and investigate.

I'll leave it at that. I welcome your questions on this very important bill that, unfortunately, includes many measures to make federal elections more unfair, and only a few measures—the registration of robocalls, the limits on loans, and the increasing of fines—that will make elections more fair. There are many more measures that make elections unfair and also fail to address current flaws in our federal elections system.

Thank you very much.

[The Chair, Conservative, Joe Preston]

Thank you, Mr. Conacher.

We will go to a seven-minute round to start off with.

Mr. Reid, you're first.

[Scott Reid, Conservative, Lanark—Frontenac—Lennox and Addington, ON]

I will start with a couple of questions for Mr. Lortie, if I could.

I want to start by going back to page three of your report. I think it's also page three in the French version. You cite section 3 of the Charter of Rights, which I'm going to read here. It says:

Democratic Rights Every citizen of Canada has the right to vote in an election of members of the House of Commons or of a legislative assembly and to be qualified for membership therein.

There has been a debate in the Supreme Court going back to a number of decisions, as far back as the 1990s, as to what this right means and whether it should be interpreted narrowly or broadly. I think the chief justice has incorrectly tried to interpret it narrowly. The majority in the case of Opitz v. Wrzesnewskyj felt that it should be interpreted broadly. They didn't actually address the constitutional question overtly, but they indicated that merely technical or bookkeeping violations of the Elections Act ought not to invalidate a vote, thereby indicating that voting is a right, not a privilege, that the right cannot be restricted for bookkeeping reasons without legitimate overriding concerns. I think all of that fits in neatly with the Oakes test, the normal application of our constitutional rights as being purposive and therefore subject to a larger liberal as opposed to a narrow technical interpretation.

I say all of this because I want to set up the fundamental problem that I think exists with regard to the whole issue of vouching, and it's this. I think we suffer from a database issue here. Elections Canada has, following the law, shifted from doing an enumeration that provided it with a fairly up-to-date database of information—very few people had moved and could not be recorded when the old system was used—to a new system based on what we thought back in the 1990s would be systems that would allow us to keep up with where people are. It hasn't worked out, and we know from Elections Canada's reports that they have an error rate in excess of 20% in 10 ridings across Canada. They won't tell us which ones those are. For the country as a whole, the preliminary voters list has an error rate of 17% with regard to people's addresses. But the preliminary list is what's used for voter information cards. That indicates that they largely don't know where people live.

The question is, how do you deal with this?

They have not unreasonably said that there are going to be fewer fraudulent voters or even mistaken voters who go to a poll where they couldn't legitimately vote than legitimate voters who aren't on the list. Therefore we try to expand things as broadly as we can to allow as many people to come in to vote. We try to find ways of facilitating that, thus the long list of ID, thus the proposed use of the voter information card nationwide as an identity card that can be used. All you need to do is turn up.

It doesn't get away from the fact that the card has a 17% error rate, higher in certain ridings and it doesn't get away from the fact that vouching also has problems, one of which is that it actually can't be used in many places where people are least able to have ID, such as people in long-term residential care.

All of this makes me think that the real solution here is to move away from vouching or the use of the voter information card for identity purposes to something else. One of the ideas that has been discussed on a number of occasions in this committee by witnesses is the idea that we would move to a model that's used in a number of jurisdictions. It's been described here as the Queensland model because I gather they use it in the Australian state of Queensland. If you show up and you don't have proper ID, your ballot is treated as it would be if it was a mail-in ballot. It's placed into a blank envelope to ensure anonymity. It is then placed into a second envelope upon which some sort of declaration of identity is made. Then afterwards there's an attempt to match this up with the voter. This allows people to show up who don't have proper ID. It allows a kind of post-fact enumeration of people who were left off the list. It essentially prevents the possibility of an invalid vote being cast, whether fraudulently or by accident.

Accidents can happen. I tell everybody the story of my ex-wife being told to go vote at a different poll from me, in a different riding, even though we lived at the same house.

What would your view be? Mr. Conacher, you can answer this as well, seeing as I've used up almost all of my time. What would your view be as to whether this system would work to resolve the problems that would exist if vouching and the voter information card were both removed as possible uses of identifying people's names and addresses?

[Pierre Lortie]

I think the issue of vouching and the issue of the information card or whatever are two different issues. In the case of vouching the person vouching needs to be identified as to their own identity and so on. In essence every head of an electoral commission would basically tell you that vouching is important.

The fact of the matter is candidates and parties also have people in the polling stations. To a large extent that is a safeguard that you cannot just eliminate from any discussion. There is a series of safeguards, if you want, around that.

To a large extent I don't think we have seen people in Canada coming out as we had with the robocalls and so on and saying that there is a scandal about using vouching or using the card. That's just not happening. In essence if you have a charter that tells you have the right to vote, bureaucratic measures don't trump that.

To say you have a list of 13 or whatever pieces of paper does not address that issue. If you have safeguards around, that's fine, but on the other hand you also have to ensure that the process works.

One of the issues with a lot of the paperwork being required is that it blocks the process. It is not necessarily true that all the paperwork we ask for is important. As a matter of fact in this bill you say we don't want the date of birth anymore; we want the year of birth. Does it really matter if it's November or whatever?

It's not true that everything we're requiring that is imposing issues is truly required. On the other hand, at least on the vouching, I don't think you can say you'll take it out and tough luck if you cannot vote. That ain't going to work; I'm sorry.

[The Chair, Conservative, Joe Preston]

Thank you, Mr. Lortie.

Mr. Reid you're past the time.

Mr. Scott, for seven minutes please.

[Craig Scott, NDP, Toronto—Danforth, ON]

Thank you to both witnesses. I have several questions, and I'm just going to state them at one time, and then you can decide which ones you might like to touch on.

Mr. Lortie, you said that section 376(3) was problematic because it encourages the circumvention of the rules and undermines the ability of Elections Canada to verify and confirm that the practices adopted do not contravene the act. You also said that that section makes it possible to exclude from election expenses the commercial value of services provided to a registered party for the purpose of soliciting contributions from individuals who contributed at least $20 in the five years preceding the date of the vote.

In the bill, why was the wording “at least $20” chosen? If a donation is under $20, it can be anonymous. The wording is not “over $20”, but rather “$20 or more”.

The second question is, Mr. Lortie, in your original massive and incredibly helpful report from the late 1980s, at one point it says:

The Canada Elections Act must not impede the appropriate use of new technologies in the electoral process as they become available; this will help to ensure that the voting process remains user friendly and cost effective. Specific developments in communications technologies may be difficult to anticipate, however. The Act should not freeze voting and other election procedures at the level allowed by current technologies; but at the same time the integrity of the electoral system must be maintained.

I'm not sure if you're aware, but in the bill there is a special singling out of electronic voting so that this is the sole alternative voting process that Elections Canada now cannot do without having the full agreement of the House of Commons and the Senate. For any other alternative procedure, it goes to the appropriate committee, this one in the House and a committee in the Senate. That's the current law. They're creating a huge obstacle for this one form of voting without allowing Elections Canada to engage in its own tests. I'm wondering if you have any comments on if it's appropriate to add that extra obstacle.

The last two questions will be short.

It's true that there's an extension of the politicization of appointing of election day workers, but the most serious addition is adding central poll supervisors as the first-place party or candidate from the last election's appointment. The current system ostensibly has this so-called balance, because deputy returning officers and poll clerks are appointed by the first-place and second-place parties. Is there any conceivable reason why at this point in time the first-place party should now also be given this additional appointment, apart from the fact, and I totally agree, that political parties should not be involved in the first place?

Last, Mr. Conacher, you mentioned the $5,000 donations to one's own campaign. It in fact could end up being $8,000. You can give $5,000; you can give $1,500 to your EDA; and you can give $1,500 to the national party that one way or another might make its way back to you, although you can't make that deal in the first place.

I'm just wondering if you could each comment on any one of those points that you like.

[Pierre Lortie]

On the question about the exception, the exception is not about the amount; it is about the fact that an activity that is going to take place during an electoral campaign that is fundamentally about politics is being excluded. That is what is wrong. Given the almost impossibility to really narrow it only to that, what you're giving rise to is people playing games, and that in itself is wrong. If you need the money, raise the ceiling, but for Christ's sake do it straightforwardly and do not invite people to play games. That's my first point.

With respect to the second issue about the candidates or nominating people and so on, the fact of the matter is that an election is a huge undertaking that requires basically almost 200,000 people to be engaged. To think that Elections Canada can have that list alone and supply all those bodies, I don't think is reasonable. I don't think that's practical and I don't think that's true.

The other point is that it's not because somebody has participated in a party or whatever that he has no merit. It's not because you engage in politics that you don't have merit or qualities. Elections Canada chooses people on the basis of merit, and that's fine. But basically to say because a candidate recommended someone, the person doesn't have merit, I think that's wrong. Basically you need to place Elections Canada in a position where it can choose, but it is normal and I think it's right for the parties and the candidates to be able to suggest names for those positions.

[Duff Conacher]

I agree with that. In case there was a misunderstanding, when I'm saying that Elections Canada should appoint all the workers, parties could still suggest people. It's just that now the returning officer has no choice under the bill but to appoint the person if the party or candidate—

[Craig Scott, NDP, Toronto—Danforth, ON]

That's not the point of the question. The question's about central poll supervisors staying on.

[Duff Conacher]

Yes, but there's no reason to add to this partisanship with this new position being appointed by the ruling party. No party should be able to force the returning officer to appoint a certain person. They should have the power, of course, to suggest anyone. There would be an application process where people would come forward, or the parties would put the people forward, but the returning officer and Elections Canada would be free to appoint whom they want, because there'd likely be several applications.

I agree also with Mr. Lortie that the problem is creating this loophole in the spending disclosure. That's the overall problem. However you structured it, it would be a problem because it's a loophole and it goes against the last four-year trend of closing loopholes.

[The Chair, Conservative, Joe Preston]

Thank you, Mr. Conacher. Thank you, Mr. Scott.

We'll go to Mr. Lamoureux, for seven minutes.

[Kevin Lamoureux, Liberal, Winnipeg North, MB]

Mr. Lortie, I must say that I'm a very passionate person when it comes to our election laws. I can only imagine, given your history with the Royal Commission on Electoral Reform and Party Financing, and so forth, that you must be a man of very strong conviction with a passion for democracy in our election laws.

What offends me the most about this legislation is the fact that the government of the day, one political entity, has decided to change the laws. No consultation was done. No other political party supports what's being done. Elections Canada's current commissioner doesn't like what he is seeing. The past commissioner has raised serious concerns with regard to this. The Commissioner for Canada Elections is saying he should be staying within Elections Canada and not be taken out.

A hundred-plus political academics from coast to coast to coast are condemning the legislation, and this is a first. It seems to me no one is coming onside and saying this legislation should be passed.

I'm appealing to you to respond, and we'll put aside what's inside the legislation right now. When you want to change an election law, is this the way you should change it, or is there a better way to make the change? What should happen when it comes time to change an election law? In your opinion what should be done?

[Pierre Lortie]

I think historically the major changes from an ethical point of view were brought when ceilings were put on expenditures. At that time it was a minority government, so you had to have the backing of other parties to do it.

That came out of the Watergate hearings in the U.S. It was in the same period. Canada did the right thing. It basically put a ceiling on expenditures. The U.S. went the other way, trying to cap the amount of contributions. The bottom line is if you cap the amount of contributions, you're going to have runaway election expenses. The only way to have elections that are competitive and fair is to have a cap, a ceiling that represents the cost. We have to stop being naive. An election across Canada costs a lot of money, so the cap has to be reasonable in that sense, but the cap makes sure you don't have runaway expenses. In that sense Canada did the right thing. In essence it came about at that time from cooperation between the parties.

[Kevin Lamoureux, Liberal, Winnipeg North, MB]

Should one political party have the right to take it upon itself to change the election laws in complete opposition to all the other stakeholders?

[Pierre Lortie]

There is a difference between what would be preferable and what you can do. This is a law, and Parliament decides.

[Kevin Lamoureux, Liberal, Winnipeg North, MB]

Okay, what would be preferable from your experience?

[Pierre Lortie]

I think these hearings are useful in that sense. In some areas it would have been useful to have better research to back up some of the decisions. Some was done with respect to the robocalls, and I think the reports by the experts and so on have been very helpful in guiding the legislation in the right direction.

[Kevin Lamoureux, Liberal, Winnipeg North, MB]

Do you think the governing political party should have the moral authority to be able to say they're going to change the election laws and they don't care what other political parties or the different independent organizations have to say?

[Pierre Lortie]

I think that's your problem as an MP.

[Kevin Lamoureux, Liberal, Winnipeg North, MB]

It is a problem, no doubt.

Elections Canada wanted us to have the ability to compel witnesses, believing at the end of the day if we or Elections Canada doesn't have the ability to compel a witness there will be people in Canada who will ignore our election laws because they know they don't have to testify.

Do you think this is a shortcoming? Should we have responded positively to Elections Canada's request to compel witnesses?

[Pierre Lortie]

I think I would take the question more broadly. I'm quite neutral about the issue of bringing the commissioner under the Director of Public Prosecutions. I don't think the arguments that have been made against that hold a lot of water.

There are two issues that could be corrected simply. The first one is that there have to be provisions in the law that give a flow of information between Elections Canada and the commissioner. Second, the powers of the commissioner should be the same as those that are given to other people under the Director of Public Prosecutions. It is clear and normal that the powers of inquiry of the equivalent commissioner with respect to the combines law, which is basically for economic crime, are more extensive than the ones you give for crime against our electoral system. That is wrong.

I think there's a good argument to bring them together, to bring them under the Director of Public Prosecutions, but basically it should be the same powers for everybody under that organization. It would be a simple change—

[Kevin Lamoureux, Liberal, Winnipeg North, MB]

I agree that compelling the witness is absolutely critical.

We only have another 40 seconds to go, so another thing is in regard to Elections Canada's ability to communicate on issues such as studies and to do outreach.

Do you have any thoughts on that particular issue?