Week 1
Law and Regulation
Regulatory governance are the policies, processes, and institutions involved in developing, implementing, and
enforcing regulations, aiming at managing risks and behaviors through standard-setting, monitoring, and be-
havior modification.
Modern society is deeply influenced by regulatory frameworks that govern various aspects of life, including the quality
of water, food, air, social media, and transportation. Regulations shape our daily routines and decisions, often in subtle
ways.
E.g., governments and regulatory bodies establish rules for food labeling, requiring manufacturers to include information such as
nutritional content, ingredients, and expiration dates. Expiration dates (e.g., ‘best before’ or ‘use by’) guide consumers on
when food is safe to eat, even if the food appears fine. Many people discard food past these dates to avoid potential health
risks, even when it might still be edible. Labels like ‘low fat,’ ‘no added sugar,’ or sustainability ratings influence purchasing de-
cisions by appealing to health-conscious or environmentally aware consumers, leading people to prioritize certain products
over others based on perceived quality or safety.
E.g., environmental regulations require companies to reduce waste, use recyclable materials, or label products as ‘eco-friendly’ or
‘biodegradable.’ Consumers may choose products with eco-friendly packaging over others to feel they are contributing to sus-
tainability efforts. These regulations also encourage manufacturers to adopt greener practices to meet legal standards and
appeal to environmentally conscious buyers.
E.g., traffic laws govern behavior on roads through mechanisms like traffic lights, speed limits, stop signs, and pedestrian crossings.
Drivers stop at red lights or adhere to speed limits even when there’s no visible enforcement (e.g., no police or cameras). These
rules create order and safety on roads, reducing accidents and ensuring smooth traffic flow. Over time, adherence to traffic
rules becomes habitual. For instance, stopping at a red light becomes automatic behavior, even when logic might suggest it’s
unnecessary (e.g., no other cars or pedestrians are present).
As societal norms evolve and new risks emerge (e.g., technological advancements, environmental challenges), regulato-
ry frameworks must adapt to address these changes effectively. Administrative law is in a state of constant evolution.
(John S. Bell)
The study of regulation has become a well-established academic field. It is a multi- and interdisciplinary endeavor,
drawing from various fields such as:
• Human welfare
• Social norms
• Human psychology
• Risk assessment
• Legal studies
• Political and institutional cultures
Administrative law provides the framework for organizing and governing the relationship between the state
and its citizens, including principles and rules that guide how public authorities operate and interact with the
public, protecting citizens from potential abuses by the state (administrative law is designed to regulate and
limit issues such as inefficiencies or abuses resulting from bureaucracy), providing mechanisms for challenging
administrative actions (e.g., appeals and judicial reviews).
State-based regulation involves public authorities, entities empowered by the state to enforce laws and regulations.
They can include government agencies, ministries, regulatory bodies, and other institutions that have the authority to
create and enforce legally binding rules. When public authorities issue rules, they are acting as regulators. These regula-
tions are designed to influence or change behavior by setting standards, monitoring compliance, and enforcing penalties
for non-compliance.
E.g., environmental regulations might require companies to reduce emissions, influencing their operational practices.
• Sometimes, state regulators may not provide adequate protection for citizens. This can occur when regulations
are weak, outdated, or not effectively enforced.
• State regulators may lack the necessary resources (financial, technological, or human) or specialized knowledge
to regulate effectively.
Our behavior is also shaped by non-state regulators, (industry associations, NGOs, private companies) through stand-
,ards, codes of conduct, or certifications. Non-State Regulation is driven by gaps in state capacity or willingness to regu-
late (e.g., forestry standards set by NGOs and firms).
• Civil society groups and corporations collaborate to set rules.
• Industry associations like the International Organization for Standardization (ISO) create global norms
(e.g., product safety standards) that guide corporate practices.
• NGOs leverage public pressure to push companies to adopt ethical practices.
E.g., industry-derived codes of conduct or certification schemes (e.g., organic food labels) can guide consumer choices and
business practices without being directly enforced by the state.
Co-Regulation is a hybrid model where state and private actors collaborate to achieve regulatory goals:
• Combines legal frameworks (state) with market-driven compliance (private). The state sets frameworks,
while private actors enforce standards.
• Combines state legitimacy with industry expertise, reducing costs for governments while ensuring account-
ability.
E.g., the EU’s Audiovisual Media Services Directive (AVMSD) requires platforms like YouTube to protect minors from harmful
content, but implementation is encouraged via co-regulation (governments set rules, platforms design measures). In me-
dia, the EU promotes co-regulation to harmonize rules across member states while involving stakeholders.
E.g., the primary regulator involved in the Theranos case was the U.S. Food and Drug Administration (FDA). Theranos' products
fell under the FDA's purview as medical devices. The FDA is responsible for ensuring the safety and efficacy of medical de-
vices, regulating them through a classification system based on risk:
• Class I: Low-risk devices (e.g., manual stethoscopes).
• Class II: Moderate-risk devices (e.g., some diagnostic tests).
• Class III: High-risk devices (e.g., implantable pacemakers).
Theranos claimed its device was a Class I medical device, but it should have been classified as a Class II device, which re-
quires more stringent regulatory oversight. Additionally, Theranos' tests were considered Laboratory Developed Tests
(LDTs), which are not subject to pre-market review by the FDA under current regulations. This loophole allowed Theranos
to avoid rigorous FDA scrutiny for most of its tests. Theranos engaged in lobbying efforts, particularly in Arizona, where
they supported legislation allowing patients to order blood tests without a doctor's note. This legislation benefited
Theranos by expanding its market access.
To prevent the issues that arose with Theranos, the regulator (FDA) could have…
…enforced stricter oversight of LDTs, requiring pre-market review to ensure their safety and efficacy. This would
have potentially caught Theranos' misrepresentations earlier.
…ensured that Theranos' devices were correctly classified as Class II devices would have necessitated more rig-
orous testing and regulatory approval before they could be marketed.
…identified quality control issues sooner. CMS did eventually revoke Theranos' CLIA certification, but earlier ac-
tion might have prevented harm to patients.
…passed legislation like the VALID Act, which aims to regulate LDTs more closely, could help prevent similar sit-
uations in the future.
Historical development of regulatory governance
Significant increase in statutory regulation. Laws were passed to regulate economic
16th – 17th matters, enforce religious changes, and address social issues like poverty.
Centuries
⬇
The 16th and 17th centuries saw efforts to consolidate royal power and bring order to
governance, leading to the development of more systematic administrative practices.
The Declaration of the Rights of Man and of the Citizen (1789) established the princi-
ple of separation of powers in Article 16, laying the groundwork for a new administra-
tive order, leading to the creation of distinct administrative and judicial authorities, as
codified in the laws of August 16 and 24, 1790. The revolutionary concept that ‘to judge
18th the administration is still to administer’ (‘Juger l'administration, c'est encore admin-
Century istrer’) became a cornerstone of French administrative law: ⬇
• Prevented the judiciary from adjudicating cases involving the administration.
• Established the administration as an independent and separate branch of the state.
The Conseil d'État, founded in 1799 under Napoleon Bonaparte:
• Initially serving as an advisory body to the government.
, • Quickly entrusted with preparing drafts of decisions for legal conflicts involving the ad-
ministration.
• Gradually evolved from a consultative role to a jurisdictional one:
• Drafts began to be accepted without modification.
• Eventually recognized as a full jurisdictional organ for administrative matters.
• The Conseil d'État, through case-by-case adjudication, developed autonomous princi-
ples and rules applicable specifically to the administration.
• This body of law, known as droit administratif, became distinct from ordinary civil law.
• It focused on the proper functioning of government and the public good, rather than
constraining the government
Prosper Weil's analysis of early French administrative law:
Primacy of the Individual dogma:
aims to limit administrative discretion and ensure that administrative actions are strictly
bound by law, reflecting the ideals of the rule of law and democratic governance.
Public Service dogma:
recognizes that the administration requires certain privileges and prerogatives to fulfill its
public service mission effectively.
The tension between these two dogmas creates a paradox in administrative law.
In the early 19th century, German states began adopting constitutions while maintain-
ing monarchical rule. The concept of monarchical constitutionalism (monarchischer
Konstitutionalismus) emerged, balancing monarchical authority with constitutional
principles.
During the second half of the 19th century, German constitutional thought centered on
the concept of Rechtsstaat and efforts to control political power:
19th • The Rechtsstaat principle emphasized the supremacy of law and legal accountability of
Century state actions. ⬇
• This focus was partly a response to the failed revolution of 1848, which had attempted
to establish a more democratic system
• Unlike democracies (e.g., France or the U.S.), where sovereignty resides in the people,
the Rechtsstaat focused on limiting state power through formal legal structures rather
than popular sovereignty.
• The Rechtsstaat prioritized legal predictability and judicial review over democratic gov-
ernance. Courts controlled administrative actions, but political participation (e.g., vot-
ing rights) was excluded.
Rapid industrialization led to economic concentration and the rise of large corpora-
tions, creating concerns about monopolies and unfair business practices, prompting
calls for government intervention.
The Industrial Revolution in Britain led to significant changes in labor laws (1833-1856):
• Factory Act (1833) aimed at regulating the labor of children and young persons in textile
mills. It prohibited the employment of children under nine years old (except in silk mills),
limited working hours for children aged 9-13 to 48 hours per week, and required children
Late 19th under 18 to not work at night. Children aged 9-13 had to work no more than 8 hours a day
Century with a lunch break, while those aged 14-18 were limited to 12 hours a day. ⬇
• Ten Hours Act (1847) further reduced the working hours for women and children. It lim-
ited the working day for women and children to ten hours, which was a significant im-
provement from previous conditions
• Mines Act (1842) banned children under the age of ten and women from working under-
ground in mines. It was a response to the dangerous conditions and moral concerns about
women and children working in such environments.
The need for regulation arose due to the harsh working conditions.
, The concept of independent regulatory agencies began to take shape in the late 19th
century. The Interstate Commerce Commission (ICC), established in 1887, was the first
such agency. It was designed to regulate railroads and ensure fair practices, marking a
shift towards more centralized regulatory control.
The Sherman Antitrust Act of 1890 was enacted to address the ‘curse of bigness’ by
prohibiting trusts, monopolies, and cartels that restrained interstate or international
trade. It aimed to promote competition and prevent economic concentration.
The Federal Reserve System (1913) was established in response to financial instability.
The Federal Reserve Board oversees a decentralized central banking system designed
to stabilize the financial system, manage monetary policy, and provide liquidity during
Early 20th crises.
Century
⬇
Federal Trade Commission (FTC) (1914) was created to address concerns about unfair
business practices and monopolies, building on the Sherman Act. It was part of a
broader movement to protect consumers and promote competition.
The Stock Market Crash led to the Great Depression, a period of severe economic
downturn marked by high unemployment, widespread poverty, and a sharp decline in
industrial production, highlighting the need for government intervention to stabilize the
economy and protect citizens from financial ruin.
1930s ⬇
The New Deal, initiated by President Franklin D. Roosevelt, involved a series of pro-
grams, policies, and reforms designed to stimulate economic recovery and prevent fu-
ture crises. Several regulatory agencies were established like the FDIC, SEC, FCC, NLRB,
TVA etc.
The period saw a broadening of regulatory activities to encompass health, safety, envi-
ronmental preservation, and social inequality. New regulations were implemented in
1970s
the areas of motor vehicle safety, product design, pollution and environmental preser-
⬇
vation, occupational health and safety.
In the UK, independent regulatory agencies began to emerge, particularly in areas like
Late 1970s broadcasting and aviation. The privatization of state-owned enterprises in the UK was
– 1980s a key driver of that. Thatcher's government recognized the need for regulatory over-
⬇
sight to ensure that newly privatized monopolies did not exploit consumers.
The deregulation movement in the United States gained momentum in the late 1970s
and continued through the 1980s, particularly under the Reagan Administration (1981-
1989).
• Reagan issued executive orders aimed at reducing regulatory oversight and requiring
cost-benefit analyses for new regulations.
• Supported legislation that deregulated various sectors, including financial services and
transportation.
1980s ⬇
Regulatory agencies faced criticism for being overly bureaucratic and inefficient, leading
to calls for reducing regulatory burdens on businesses:
• Agencies were seen as slow to adapt and overly complex.
• Industries were influencing regulatory policies to serve their own interests rather than
the public's. (regulatory capture)
• Regulations were blamed for contributing to rising prices and stifling competition.
The Single European Act (SEA) in the EU's internal market integration aimed to com-
1980s –
1990s
plete the internal market by 1992, which involved removing barriers to the free move- ⬇
ment of goods, services, capital, and people.
Law and Regulation
Regulatory governance are the policies, processes, and institutions involved in developing, implementing, and
enforcing regulations, aiming at managing risks and behaviors through standard-setting, monitoring, and be-
havior modification.
Modern society is deeply influenced by regulatory frameworks that govern various aspects of life, including the quality
of water, food, air, social media, and transportation. Regulations shape our daily routines and decisions, often in subtle
ways.
E.g., governments and regulatory bodies establish rules for food labeling, requiring manufacturers to include information such as
nutritional content, ingredients, and expiration dates. Expiration dates (e.g., ‘best before’ or ‘use by’) guide consumers on
when food is safe to eat, even if the food appears fine. Many people discard food past these dates to avoid potential health
risks, even when it might still be edible. Labels like ‘low fat,’ ‘no added sugar,’ or sustainability ratings influence purchasing de-
cisions by appealing to health-conscious or environmentally aware consumers, leading people to prioritize certain products
over others based on perceived quality or safety.
E.g., environmental regulations require companies to reduce waste, use recyclable materials, or label products as ‘eco-friendly’ or
‘biodegradable.’ Consumers may choose products with eco-friendly packaging over others to feel they are contributing to sus-
tainability efforts. These regulations also encourage manufacturers to adopt greener practices to meet legal standards and
appeal to environmentally conscious buyers.
E.g., traffic laws govern behavior on roads through mechanisms like traffic lights, speed limits, stop signs, and pedestrian crossings.
Drivers stop at red lights or adhere to speed limits even when there’s no visible enforcement (e.g., no police or cameras). These
rules create order and safety on roads, reducing accidents and ensuring smooth traffic flow. Over time, adherence to traffic
rules becomes habitual. For instance, stopping at a red light becomes automatic behavior, even when logic might suggest it’s
unnecessary (e.g., no other cars or pedestrians are present).
As societal norms evolve and new risks emerge (e.g., technological advancements, environmental challenges), regulato-
ry frameworks must adapt to address these changes effectively. Administrative law is in a state of constant evolution.
(John S. Bell)
The study of regulation has become a well-established academic field. It is a multi- and interdisciplinary endeavor,
drawing from various fields such as:
• Human welfare
• Social norms
• Human psychology
• Risk assessment
• Legal studies
• Political and institutional cultures
Administrative law provides the framework for organizing and governing the relationship between the state
and its citizens, including principles and rules that guide how public authorities operate and interact with the
public, protecting citizens from potential abuses by the state (administrative law is designed to regulate and
limit issues such as inefficiencies or abuses resulting from bureaucracy), providing mechanisms for challenging
administrative actions (e.g., appeals and judicial reviews).
State-based regulation involves public authorities, entities empowered by the state to enforce laws and regulations.
They can include government agencies, ministries, regulatory bodies, and other institutions that have the authority to
create and enforce legally binding rules. When public authorities issue rules, they are acting as regulators. These regula-
tions are designed to influence or change behavior by setting standards, monitoring compliance, and enforcing penalties
for non-compliance.
E.g., environmental regulations might require companies to reduce emissions, influencing their operational practices.
• Sometimes, state regulators may not provide adequate protection for citizens. This can occur when regulations
are weak, outdated, or not effectively enforced.
• State regulators may lack the necessary resources (financial, technological, or human) or specialized knowledge
to regulate effectively.
Our behavior is also shaped by non-state regulators, (industry associations, NGOs, private companies) through stand-
,ards, codes of conduct, or certifications. Non-State Regulation is driven by gaps in state capacity or willingness to regu-
late (e.g., forestry standards set by NGOs and firms).
• Civil society groups and corporations collaborate to set rules.
• Industry associations like the International Organization for Standardization (ISO) create global norms
(e.g., product safety standards) that guide corporate practices.
• NGOs leverage public pressure to push companies to adopt ethical practices.
E.g., industry-derived codes of conduct or certification schemes (e.g., organic food labels) can guide consumer choices and
business practices without being directly enforced by the state.
Co-Regulation is a hybrid model where state and private actors collaborate to achieve regulatory goals:
• Combines legal frameworks (state) with market-driven compliance (private). The state sets frameworks,
while private actors enforce standards.
• Combines state legitimacy with industry expertise, reducing costs for governments while ensuring account-
ability.
E.g., the EU’s Audiovisual Media Services Directive (AVMSD) requires platforms like YouTube to protect minors from harmful
content, but implementation is encouraged via co-regulation (governments set rules, platforms design measures). In me-
dia, the EU promotes co-regulation to harmonize rules across member states while involving stakeholders.
E.g., the primary regulator involved in the Theranos case was the U.S. Food and Drug Administration (FDA). Theranos' products
fell under the FDA's purview as medical devices. The FDA is responsible for ensuring the safety and efficacy of medical de-
vices, regulating them through a classification system based on risk:
• Class I: Low-risk devices (e.g., manual stethoscopes).
• Class II: Moderate-risk devices (e.g., some diagnostic tests).
• Class III: High-risk devices (e.g., implantable pacemakers).
Theranos claimed its device was a Class I medical device, but it should have been classified as a Class II device, which re-
quires more stringent regulatory oversight. Additionally, Theranos' tests were considered Laboratory Developed Tests
(LDTs), which are not subject to pre-market review by the FDA under current regulations. This loophole allowed Theranos
to avoid rigorous FDA scrutiny for most of its tests. Theranos engaged in lobbying efforts, particularly in Arizona, where
they supported legislation allowing patients to order blood tests without a doctor's note. This legislation benefited
Theranos by expanding its market access.
To prevent the issues that arose with Theranos, the regulator (FDA) could have…
…enforced stricter oversight of LDTs, requiring pre-market review to ensure their safety and efficacy. This would
have potentially caught Theranos' misrepresentations earlier.
…ensured that Theranos' devices were correctly classified as Class II devices would have necessitated more rig-
orous testing and regulatory approval before they could be marketed.
…identified quality control issues sooner. CMS did eventually revoke Theranos' CLIA certification, but earlier ac-
tion might have prevented harm to patients.
…passed legislation like the VALID Act, which aims to regulate LDTs more closely, could help prevent similar sit-
uations in the future.
Historical development of regulatory governance
Significant increase in statutory regulation. Laws were passed to regulate economic
16th – 17th matters, enforce religious changes, and address social issues like poverty.
Centuries
⬇
The 16th and 17th centuries saw efforts to consolidate royal power and bring order to
governance, leading to the development of more systematic administrative practices.
The Declaration of the Rights of Man and of the Citizen (1789) established the princi-
ple of separation of powers in Article 16, laying the groundwork for a new administra-
tive order, leading to the creation of distinct administrative and judicial authorities, as
codified in the laws of August 16 and 24, 1790. The revolutionary concept that ‘to judge
18th the administration is still to administer’ (‘Juger l'administration, c'est encore admin-
Century istrer’) became a cornerstone of French administrative law: ⬇
• Prevented the judiciary from adjudicating cases involving the administration.
• Established the administration as an independent and separate branch of the state.
The Conseil d'État, founded in 1799 under Napoleon Bonaparte:
• Initially serving as an advisory body to the government.
, • Quickly entrusted with preparing drafts of decisions for legal conflicts involving the ad-
ministration.
• Gradually evolved from a consultative role to a jurisdictional one:
• Drafts began to be accepted without modification.
• Eventually recognized as a full jurisdictional organ for administrative matters.
• The Conseil d'État, through case-by-case adjudication, developed autonomous princi-
ples and rules applicable specifically to the administration.
• This body of law, known as droit administratif, became distinct from ordinary civil law.
• It focused on the proper functioning of government and the public good, rather than
constraining the government
Prosper Weil's analysis of early French administrative law:
Primacy of the Individual dogma:
aims to limit administrative discretion and ensure that administrative actions are strictly
bound by law, reflecting the ideals of the rule of law and democratic governance.
Public Service dogma:
recognizes that the administration requires certain privileges and prerogatives to fulfill its
public service mission effectively.
The tension between these two dogmas creates a paradox in administrative law.
In the early 19th century, German states began adopting constitutions while maintain-
ing monarchical rule. The concept of monarchical constitutionalism (monarchischer
Konstitutionalismus) emerged, balancing monarchical authority with constitutional
principles.
During the second half of the 19th century, German constitutional thought centered on
the concept of Rechtsstaat and efforts to control political power:
19th • The Rechtsstaat principle emphasized the supremacy of law and legal accountability of
Century state actions. ⬇
• This focus was partly a response to the failed revolution of 1848, which had attempted
to establish a more democratic system
• Unlike democracies (e.g., France or the U.S.), where sovereignty resides in the people,
the Rechtsstaat focused on limiting state power through formal legal structures rather
than popular sovereignty.
• The Rechtsstaat prioritized legal predictability and judicial review over democratic gov-
ernance. Courts controlled administrative actions, but political participation (e.g., vot-
ing rights) was excluded.
Rapid industrialization led to economic concentration and the rise of large corpora-
tions, creating concerns about monopolies and unfair business practices, prompting
calls for government intervention.
The Industrial Revolution in Britain led to significant changes in labor laws (1833-1856):
• Factory Act (1833) aimed at regulating the labor of children and young persons in textile
mills. It prohibited the employment of children under nine years old (except in silk mills),
limited working hours for children aged 9-13 to 48 hours per week, and required children
Late 19th under 18 to not work at night. Children aged 9-13 had to work no more than 8 hours a day
Century with a lunch break, while those aged 14-18 were limited to 12 hours a day. ⬇
• Ten Hours Act (1847) further reduced the working hours for women and children. It lim-
ited the working day for women and children to ten hours, which was a significant im-
provement from previous conditions
• Mines Act (1842) banned children under the age of ten and women from working under-
ground in mines. It was a response to the dangerous conditions and moral concerns about
women and children working in such environments.
The need for regulation arose due to the harsh working conditions.
, The concept of independent regulatory agencies began to take shape in the late 19th
century. The Interstate Commerce Commission (ICC), established in 1887, was the first
such agency. It was designed to regulate railroads and ensure fair practices, marking a
shift towards more centralized regulatory control.
The Sherman Antitrust Act of 1890 was enacted to address the ‘curse of bigness’ by
prohibiting trusts, monopolies, and cartels that restrained interstate or international
trade. It aimed to promote competition and prevent economic concentration.
The Federal Reserve System (1913) was established in response to financial instability.
The Federal Reserve Board oversees a decentralized central banking system designed
to stabilize the financial system, manage monetary policy, and provide liquidity during
Early 20th crises.
Century
⬇
Federal Trade Commission (FTC) (1914) was created to address concerns about unfair
business practices and monopolies, building on the Sherman Act. It was part of a
broader movement to protect consumers and promote competition.
The Stock Market Crash led to the Great Depression, a period of severe economic
downturn marked by high unemployment, widespread poverty, and a sharp decline in
industrial production, highlighting the need for government intervention to stabilize the
economy and protect citizens from financial ruin.
1930s ⬇
The New Deal, initiated by President Franklin D. Roosevelt, involved a series of pro-
grams, policies, and reforms designed to stimulate economic recovery and prevent fu-
ture crises. Several regulatory agencies were established like the FDIC, SEC, FCC, NLRB,
TVA etc.
The period saw a broadening of regulatory activities to encompass health, safety, envi-
ronmental preservation, and social inequality. New regulations were implemented in
1970s
the areas of motor vehicle safety, product design, pollution and environmental preser-
⬇
vation, occupational health and safety.
In the UK, independent regulatory agencies began to emerge, particularly in areas like
Late 1970s broadcasting and aviation. The privatization of state-owned enterprises in the UK was
– 1980s a key driver of that. Thatcher's government recognized the need for regulatory over-
⬇
sight to ensure that newly privatized monopolies did not exploit consumers.
The deregulation movement in the United States gained momentum in the late 1970s
and continued through the 1980s, particularly under the Reagan Administration (1981-
1989).
• Reagan issued executive orders aimed at reducing regulatory oversight and requiring
cost-benefit analyses for new regulations.
• Supported legislation that deregulated various sectors, including financial services and
transportation.
1980s ⬇
Regulatory agencies faced criticism for being overly bureaucratic and inefficient, leading
to calls for reducing regulatory burdens on businesses:
• Agencies were seen as slow to adapt and overly complex.
• Industries were influencing regulatory policies to serve their own interests rather than
the public's. (regulatory capture)
• Regulations were blamed for contributing to rising prices and stifling competition.
The Single European Act (SEA) in the EU's internal market integration aimed to com-
1980s –
1990s
plete the internal market by 1992, which involved removing barriers to the free move- ⬇
ment of goods, services, capital, and people.
