Issuu

The Kenyan Government following the water sector reforms introduced a new legal and institutional framework in the sub-sector of water and sanitation service provision. Among the key principles of the reform was a focus on poverty orientation and the human right to water and sanitation. The new legal framework established new and more professionally working sector institutions and developed national pro-poor sector policies and strategies. The objective of this publication is to highlight key provisions in the Water Act 2002, the National Water Services Strategy (20072015), the National Water Resources Management Strategy (20072009) and the Pro-Poor Implementation Plan for Water Supply and Sanitation (PPIP - WSS) 2007. The main purpose of this publication to familiarise civil society groups, including community based groups and non-governmental organisations with the basic principles of the human right approach to water and sanitation, and to outline key principles and commitments by Government to implement the right to water and sanitation in Kenya. The publication does not however assess the Government’s implementation of the right to water and sanitation or make a determination as to whether existing policies are appropriate to fulﬁl the Governments obligations to the realise the right to water and sanitation.

For more information on the right to water and sanitation contact:

Hakijamii

Hakijamii Trust, P.O. Box 11356 – 00100, 2nd Floor, Golf Course Commercial Centre, Kenyatta Market, Nairobi, Kenya, Tel: +254.020.273.1667 / 272.0751, Fax: +254.020.272.6023 Email: esrc@hakijamii.com

A Summary of

The Water Act 2002, The National Water Services Strategy, The National Water Resources Management Strategy and The Pro-Poor Implementation Plan for Water Supply and Sanitation

For more information on the right to water and sanitation contact:

Hakijamii

A Summary of

The Water Act 2002, The National Water Services Strategy, The National Water Resources Management Strategy and The Pro-Poor Implementation Plan for Water Supply and Sanitation

Contents

What is the right to water and sanitation? .....................2 The Water Act 2002 ...............................................................5 The National Water Services Strategy 2007 -2015........13 National Water Resources Management Strategy (2007 â€“ 2009) ................................19 The Pro-Poor Implementation Plan for Water Supply and Sanitation (PPIP - WSS) 2007 .........24

What is the right to water and sanitation? The human right to water entitles everyone to sufficient, safe, acceptable, physically accessible and affordable water for personal and domestic uses in or near their homes, workplace or educational institution. Equally, every person is entitled to access to safe, adequate and affordable sanitation in or near their homes, workplace or educational institution. As with all human rights, the right to water and sanitation is guided by a set of common principles that are grounded in widely ratified human rights treaties, namely, non-discrimination, inclusion of vulnerable and marginalised groups, access to information and participation, and transparency and accountability. The definition of the right to water and sanitation is provided by the General Comment 15: The Right to Water adopted by the United Nations Committee on Economic, Social and Cultural Rights in 2002 and the Guidelines for the Realization of the Right to Drinking Water Supply and Sanitation adopted by the UN SubCommission on the Promotion and Protection of Human Rights. These two documents, taken together, indicate that the right comprises the following: 2

•

• •

Sufﬁcient water. An adequate quantity of water supply must be available for personal and domestic uses, which includes drinking, personal sanitation, washing of clothes, food preparation, personal and household hygiene. This normally means 50-100 litres, and an absolute minimum of 20 litres per person per day. The allocation of water resources must give priority to essential personal and domestic uses. Water sources must be protected to ensure safe water for present and future generations. Safe water. Water that, in particular, is free from harmful substances that could endanger human health, and whose colour, odour and taste are acceptable to users. Sanitation must be hygienic and not pose a threat to the environment. It must be able to effectively prevent human, animal and insect contact with excreta. Accessible water and sanitation. Water and sanitation services and facilities must be within safe physical reach, in or near the house, school, work place or health facility, in a secure location and address the needs of different groups, in particular threats to the physical security of women. Affordable water and sanitation. Water and sanitation must be affordable, without reducing the individuals or household’s capacity to acquire other essential goods and services. Water availability, allocation and sustainability. The allocation of water resources must give priority to essential personal and domestic uses. Water sources must be protected against degradation and pollution to ensure safe water for present and future generations. 3

Has the Government of Kenya Recognised the Right to Water and Sanitation? The Government has the primary duty of ensuring that the right to water and sanitation is fulďŹ lled for everyone. Following the water sector reforms in Kenya, the Government of Kenya revised its laws and developed policies that are consistent with the right to water and sanitation. The Water Act was gazetted in October 2002 and came into force in 2003. Although the right to water and sanitation is not explicitly provided in the Water Act, the right to water and sanitation has been formally recognised in a number of national water sector policies. These include the National Water Services Strategy, the National Water Resources Management Strategy, the Water Services Regulatory Board Tariff Guidelines and Model and the ProPoor Implementation Plan for Water Supply and Sanitation. From these documents the Government recognises that the right to water entitles person to have access to sufďŹ cient, affordable water and sanitation of acceptable quality for personal and domestic use. In 2007, the Ministry of Water and Irrigation (MWI) declared that human rights principles (namely, non-discrimination, inclusion of vulnerable and marginalised groups, access to information and participation, and transparency and accountability) together with the MDG orientation shall guide the water sector reform process in Kenya. [See Ministry of Water and Irrigation, Water Sector Reform and the Human Right to Water in Kenya (2007)]. 4

The Water Act 2002 The Water Act 2002 is the main legislation that regulates the water sector in Kenya, this therefore means that all policies, regulations and by-laws, directives and administrative actions from the ministry, strategic plans and all activities by water sector institutions must be done in accordance with and be consistent with the provisions and content of the Water Act 2002. The Water Act which came into force in 2003 was passed with various objectives: •

• •

The Act was meant to clearly differentiate the roles of various actors in water sector i.e. the government, local government, the private sector and the public into two main areas, water resources management and water services and supply The Act also had the intention of entrenching public participation and involvement in water services and water resources management The Act also intended to clearly deﬁne water rights and legislate ways in which water resources can be utilised 5

The Water Act introduced new water management institutions to govern water and sanitation. The Water Services Regulatory Board (WASREB) to set standards and regulate the sub-sector; the Water Appeal Board (WAB) to adjudicate on disputes; eight Water Services Boards (WSBs) to be responsible for the management of efficient and economical provision of water and sewerage services; Water Services Providers (WSPs) to act as agents of the Water Services Boards (WSBs) in the actual provision of water and sewerage services; the Water Services Trust Fund (WSTF) to finance pro-poor investments; and the Water Resources Management Authority (WRMA) to manage and protect Kenya’s water resources. Catchment Area Advisory Committees (CAAC) support the WRMAs at the regional Level. Water Resource Users Associations (WRUA) were established as a medium for cooperative management of water resources and conflict resolution at sub-catchment level. The Ministry of Water and Irrigation (MWI) is vested with the responsibility for overall sector oversight including policy formulation, coordination and resource mobilisation.

Highlights of the Water Act 2002 State ownership of all water resources •

• 6

The Act vests all water resources in the state and the water resources are to be managed and utilised in accordance with the Act. This means that the State has ownership of all water resources in Kenya. The Act provides that exploitation of water resources

requires authority granted through the issuance of a water permit. Stakeholder participation and involvement in management of water resources •

•

The Act creates the Water Resources Management Authority (WRMA) that is meant to regulate and manage water resources in Kenya. One of the main duties of the authority is to come up with strategies that provide mechanisms and facilities for enabling the public and communities to participate in the managing the water resources in each catchment The Act provides for the formation of the Catchment Area Advisory Committee whose membership is drawn from representatives of groups population in the catchment area such as pastoralists, farmers, business community etc the committee is meant to advise the WRMA on water resources conservation, use and apportionment of water resources within a particular catchment area The Act provides for community water projects where members of the community may start water projects with the consent of the WRMA for community purposes (an example of public participation in the actual provision of water services) The Act provides for public consultation in the grant of a permit or water use, it therefore ensures that there is public participation in the grant of permits for use of water resources 7

•

The Act provides that there has to be a process of public consultation before an area with ground water is gazetted as a ground water conservation area and the application of licences for provision of water services. The Act speciﬁcally provides for public consultation in the development of national strategies such as the National Water Resources Management Strategy, the National Water Services Strategy and Catchment Management Strategy The Act provides for representation of water users in boards of all water sector institutions this includes membership of the WASREB, CAAC, WSB, WASREB and WRMA.

Public Consultation in Applications or Actions For any application or action that requires public consultation the Water Act provides that a notice is published in the Kenya Gazette, at least one national newspaper and at least one radio station broadcasting in the location affected. The notice must provide a summary of the application or action, where the details of the application or action may be inspected and call for comments or objections. The notice must further who to address the comments or objections and the date by which any objections and comments may be made. Documents relating to the application or proposed action should be available to the public at a reasonable fee. Comments or objections can also be received at an organised public meeting for such purpose. Once comments or objections are 8

received they must be considered in the ﬁnal determination of the application or action. National monitoring and information •

The Act requires the development of a national monitoring and information system on water resources and water services. Any member of the public can have access to information contained in any national information system.

Equitable allocation of water for all Kenyans •

•

• •

The Act ensures availability of water through regulating the amount of water that can be supplied in bulk by a licensee or a water service provider so that water supply to domestic water consumers is not affected The Act provides that water service providers have a legal duty of providing water services to the people and also ensuring that associated works and facilities are provided, maintained and progressively improved The Act prioritises the allocation of water resources for essential domestic uses over other uses such as industrial use The Act provides for a response system for the provision of basic water and sanitation services in emergencies

Social objectives including supplying the poor with water to be achieved by other means including Government subsidy •

•

The Water Services Regulatory Board (WASREB) has one of its core functions as developing guidelines for the ﬁxing of tariffs for the provision of water services, which is geared towards ensuring that water services reach the water consumers at an affordable cost The Act provides that the National Water Services Strategy must outline plans for extension of water services to underserved areas such as rural areas, arid and semi arid land and informal settlements

Accelerating supply and distribution of water and sanitation in rural and poor urban areas through special funding •

•

The Act establishes the Water Services Trust Fund whose main objective is to assist in the ﬁnancing of provision of water supplies in the areas that are not adequately provided with water services in urban and rural areas. The Water Services Trust Fund is allowed under the Act to receive grants and donations that will enable the fund to fulﬁl its core mandate

Development of sector strategies for management and development of the sector • 10

The Act provides for the formulation of a national water services strategy whose main objectives are to ensure that

in every area in Kenya, there is a water service provider who is able to effectively provide water services. The national water services strategy has the further objective of ensuring progressive extension of sewerage services to every centre of population in Kenya. The national water services strategy identiﬁes areas that do not have water supply with a view of ensuring that these areas receive water services Protection of the quality of water resources •

• •

•

The Act creates the Water Resources Management Authority and specifies one of the functions to be the regulation and protection of water resources quality form adverse impact The Act also provides for the classification of water resources quality objectives in order to preserve the water quality of each resource The Act makes it an offence for a person to in any way cause pollution in a water course or water resource by throwing, conveying or permitting to be thrown any rubbish, dirt, refuse, effluent, trade waste or other offensive material into the river or water resource. This controls the pollution of water resources and ensuring effective disincentives and penalties for pollution The Act further provides that a licensee may construct and maintain drains, sewers and other works for intercepting, treating or disposing of any foul water arising or flowing upon such land or otherwise for preventing water from 11

•

being polluted WRUAs and CAACs are mandated to monitor the pollution of water resources in their areas.

Cost recovery as a means of sustainable service provision •

•

The Act emphasises cost recovery as a means of sustainable service provision meaning that all costs incurred in water services delivery have to be recovered from the price that the water is sold. For instance the Act provides that WASREB must develop guidelines for and provide advice on cost effective and efﬁcient management and operation of water services. All water supply and sewerage services must be run by commercially oriented providers.

The National Water Services Strategy 2007 -2015 The Water Act, 2002 provides for the formulation of a national water services strategy to design a programme to ensure the progressive extension of water and sanitation services to everyone in Kenya and ensure that all areas in the country are adequately serviced. The Act provides that the strategy must detail the existing water services in the country, the number and location of persons who are currently underserved or not served at all, and the plans to extend water services to these underserved areas. The Act further provides that the national water services strategy must indicate details of the timeframe for expansion and extension of services and the investment programme. In 2007, the Government published its ďŹ rst national water services strategy. The overall goal of the National Water Services Strategy (NWSS) is to ensure sustainable access to safe water and basic sanitation to all Kenyans. The NWSS recognises that sustainable access to safe water and basic sanitation is a human right. Under the NWSS water and sanitation are recognised as 13

both a social and economic good. The Strategy provides that water and sanitation service provision for the poor shall be enabled by social tariffs that provide for a minimum of 20 litres of water per person per day. It also provides that users of water and sanitation must pay according to their consumption. The NWSS is guided by speciﬁc principles that apply to water supply and sanitation in the urban and rural setting. Water supply in urban settings The NWSS strategy require the following actions • • • • • • 14

That all water service providers perform water quality testing at outlets and water sources according to requirements. That the public is able to receive information from Water Service Boards and Providers on applicable tariffs, water testing results. That water supply is assured by each consumer groups being offered a service level that can be sustained. That the poor do not pay more for the supply of water from public/communal outlets than those who enjoy supply at household connections. That when investing in service extension the Water Service Boards must give ﬁrst priority to areas that are poor and are not covered. That the efﬁcient management of water supply systems

• •

is given priority over the increasing supply. This means attention must be given first to promoting efficient water use, water metering, billing, effective collection, network repair etc. That in areas such as informal settlements where household connections may not be possible in the short term, public or communal outlets such as water kiosks are promoted. That all consumption is metered to reduce unaccounted for water, curb wastages and provide justified bills.

Water supply in rural settings • • •

• •

That all rural water supply programs must promote health and hygiene awareness and implement components of sanitation. That water service provision should increasingly move to ensure that water supply systems are able to recover the costs of their operations. That were technological options are being introduced, the community should be consulted and determine the choice of technology based on its appropriateness to the area and users. That there is increased and mandatory water quality monitoring at agreed intervals. That the protection of water sources and the rehabilitation of water point installations have priority over developing new infrastructure.

Sanitation (sewerage and basic sanitation) • • • • • • • •

•

That sewerage systems are rehabilitated, extended or built wherever technically and commercially feasible and conditions for sustainability are proven. That to promote sustainability users shall be consulted in the choice of technology for basic sanitation to ensure ownership and acceptance by the household. That where existing sewerage networks with household connections cannot be rehabilitated, extended or established, basic sanitation is shall be promoted. That the promotion of basic sanitation shall be undertaken in areas where the biggest impact on public health is expected such as informal settlements. New solutions are sufﬁciently tested before large scale implementation. That all water sector institutions and organisations are actively engaged in the implementation and promotion of sanitation according to their capacity. That the not more than 4 households shall share a basic sanitation installation. That public sanitation installations shall be available and sustainable at all public places such as schools, markets, government institutions, etc. with a sustainable arrangement for O+M coverage. That ecological sanitation (ecosan) shall be promoted whenever socially accepted.

The main goals of the NWSS can be summarised as follows; 1.

Establishing a national minimum standard and target on proximity to water source. The NWSS hopes to meet the Millennium Development Goals (MDG) on water by reducing by half, the proportion of people without sustainable access to safe drinking water and basic sanitation by the year 2015. The reduction will cover both rural and urban areas; currently, more than a half of the urban population in Kenya (60%) have access to safe drinking water and the government hopes to increase this to 80% by 2015, the government also hopes to put in place mechanisms that will ensure that people will only spend at most 30 minutes to and from the house when going to get water. In rural areas of Kenya, access to safe drinking water is low compared to urban areas (40%) the government hopes to improve this to 75% by 2015 and also ensure that the farthest distance to a communal water point is 2 kilometres only in rural areas Improving the efďŹ ciency of piped water delivery. Currently, more than a half of the water (60%) that is meant for use is lost through burst water pipes, illegal connections, spills and other forms of wastage to water (collectively referred to as unaccounted for water / non revenue water), the policy hopes to put plans in place that will ensure that this wastage is reduced to only 30% by the year 2015. Improving the ďŹ nancial management of water and sewerage service systems. The NWSS hopes to ensure 17

that water and sewerage services systems are able to meet the costs of operations and maintenance by 2010. Improving the efďŹ ciency of water and sewerage service systems. Currently, sewage collection, treatment and disposal are inefďŹ cient in rural and urban areas. The NWSS hopes to improve from 30% to 40% in urban areas and 5% to 10% in the rural areas by the year 2015. Improving sustainability of water resources and protecting water catchment areas. To ensure that efďŹ‚uent discharge that threatens water resources through pollution meets relevant national standards and standards set by the Environmental Management and Coordination Act. Improving Ministerial Coordination. The Ministry of Water and Irrigation also hopes to work with other ministries such as the Ministry of Public Health and Sanitation in order to improve access to basic sanitation from slightly over a half to 77.5% in urban areas and from slightly below half to 72.5% by the year 2015

National Water Resources Management Strategy (2007 – 2009) The Water Act 2002 outlines the objectives for managing Kenya’s water resources. The Water Act provides that following public consultation, the Minister for Water and Irrigation shall publish a national water resources management strategy in accordance with which the resources of Kenya shall be managed, protected, used, developed, conserved and controlled. The Water Act further provides that the strategy must address the principles, objectives, procedures and institutional setting for the conservation and control of water resources which include the classification of water resources, the determination of requirements of the reserve of each water resource and the identification of areas designated as protected and groundwater conservation areas. In January 2007, the Government published its first national water resources management strategy. The National Water Resources Management Strategy outlines the Governments development strategy for the managing, assessing, maintaining and developing of Kenya’s available and renewable fresh water 19

resources. Kenya is a water-scarce country, with surface water coverage of only 2%, registering a water scarce category of 647m3 per capita against the global benchmark of 1000m3. Kenya faces a number of challenges; the National Water Resources Management Strategy identiﬁes the following; •

• • • • • • •

Water scarcity (An area is experiencing water stress when annual water supplies drop below 1 700 m3 per person. When annual water supplies drop below 1 000 m3 per person, the population faces water scarcity. Sources: UNPD, UNEP, World Bank, and WRI, 2000.) Underdeveloped water resources Climate change including changing rainfall patterns, flooding and droughts that have been experienced in the past Catchment degradation that leads to flash floods, reduced water infiltration, soil erosion and siltation. Lack of adequate water resources assessment and monitoring. Management and use of transboundary water resources like the Lake Victoria Basin shared between Kenya and its neighbouring countries. Degradation of water resources through the unsustainable use of surface water, pollution and inappropriate land use. The inability of the Government to provide safe and affordable water to those affected and infected with HIV/ AIDS leading to an increase in water borne diseases.

The overall management of our countries resources is therefore of great importance. Goals and Objectives of the National Water Resources Management Strategy Inadequate access to water and sanitation contributes to poverty. The lack of access to water and sanitation impacts on the health, education and working opportunities of poor, vulnerable and marginalised communities that often have inadequate water and sanitation services. The inadequate access to water and sanitation, speciﬁcally the safe disposal of excreta, has been linked to increased child mortality, higher prevalence of disease and to environmental degradation. This situation deprives many individuals from resources, capabilities, choices, security and power. The overall goal of the National Water Resources Management Strategy is to eradicate poverty by ensuring that everyone has access to safe water for human consumption and for productive use. The speciﬁc objectives of the strategy are broadly to: • •

To improve the assessment of water resources for more accurate information of the quantity of water produced per year from underground and surface water sources. To put in place mechanisms that promotes equal access to water for all Kenyans through the participation and 21

•

• • •

• •

involvement of stakeholders in planning and development of water resources. To enhance and strengthen roles of gender in water resources management by ensuring that men, women children and the disabled actively participate in resource management. To create mechanisms for an integrated approach to land and water resources planning and management on a catchment basis. Create mechanisms for catchment conservation and management with land users are being made fully aware of the issues, concepts and principles in catchment planning To put in place measures that enhance the availability of water resources of suitable quality and quantity where and when it is needed. The Strategy seeks to ensure that water polluters reduce the practices and adopt other alternative for waste disposal. In addition the Strategy also intends to seek ways of cleaning already contaminated water sources and also adopt rules that will ensure deterrence form further pollution such as the polluter pays principles in cases of industrial efﬂuent charges To put in place strategies that will promote the production of accurate data on water use and demand for both surface water and groundwater To develop water pricing policies and mechanisms which recognise water as an economic good. The strategy recognises that water has over the past been considered a social good rather than an economic good. The low tariffs for both rural and urban water supplies do not promote the

•

• • •

efﬁcient utilisation of water, environmental conservation and preservation. Provide guidelines and incentives such as tax rebates and penalties for adoption and implementation of rainwater harvesting through artiﬁcial ground water recharge and direct use To develop policies and mechanisms on disaster management To promote integration of the sector and regional water policies To promote harmonisation and integration of transboundary water resource use

The Pro-Poor Implementation Plan for Water Supply and Sanitation (PPIP - WSS) 2007 In 2007 the GoK published the Pro-Poor Implementation Plan (PPIP) for Water Supply and Sanitation. The PPIP sets out the actions which need to be undertaken by water sector institutions, water and sanitation service providers, development partners and civil society among other stakeholders to streamline their actions towards a national approach aiming to achieve the Millennium Development Goals (MDGs) for water and sanitation: â€œto half by 2015 the proportion of people without sustainable access to safe drinking water and sanitationâ€?. A pro poor approach is one that ensures that the preparation, planning and implementation of activities focuses on poor, vulnerable or marginalised groups. The focus with respect to water and sanitation means that the poor for example those living in informal settlements are given priority in extending water and sanitation supply.

By implementing a pro poor plan, the GoK undertakes to ensure that all key activities to be carried out in the water sector must be aimed at and beneďŹ t the poor and those that are underserved as quickly as possible. For example one of the main objectives of the PPIP is to increase the number of persons who have access to safe water and basic sanitation annually. Under the PPIP all institutions are expected to: 1. 2. 3. 4.

5. 6. 7.

Use a pro-poor approach in orientation of all sector institutions and service providers. Fast track actions to increase water and sanitation coverage nationally by concentrating on low cost technology and settlements of the urban poor. Offer appropriate low cost technology and management systems that ensure sustainability and compliance to minimum requirements. Development partners such as Donors and NGOs follow national policies, strategies and concepts that are based on pro-poor approach and the human right to water and sanitation. To promote accountability of all water and sanitation providers through the development and enforcement of regulations that comply with human rights standards. Improve data collection and information systems. Ensure that sanitation receives higher priority in efforts to increase the number of people who have access to sustainable basic sanitation. 25

8. 9.

Improvement of good governance, especially corporate governance. Mobilizing of more funds and use of the WSTF for improved aid efﬁciency.

The PPIP also provides that in addition to water sector institutions, development partners including the NGOs shall be accountable for their contributions to the national pro-poor concept and PPIP. The progress of water sector institutions in implementing the PPIP is assessed annually and the results reported during the annual water sector conference that usually takes place between October and November.

Highlights •

• •

GoK through the Ministry of Water and Irrigation commits to move as fast and effectively as possible towards the meeting the MDGs and to fulﬁl the human rights to water and sanitation. Stresses the need to ensure that all Kenyans have access to water and sanitation services that meet minimum standards and are sustainable. Focus on the establishment of infrastructure e.g. networks, onsite sanitation, and the management of such infrastructure e.g. public outlets such as water kiosk and public sanitation facilities.

Access • • •

Promotes the use of low cost installations such as water kiosks and basic onsite sanitation. Focuses on increasing access of the poor and emphasises the need to increase investments in settlements of the urban poor and the rural poor in the arid and semi-arid areas. Promotes the implementation of special programs for enhancing basic sanitation at public places/installations.

Regulation and standards for services to the poor • • •

• • • •

Formal service provision to replace gradually informal Requires utilities and formal service providers such as the Nairobi City Water Sewerage Company to expand its services to underserved areas. Enforcement of minimum standards (technical and managerial) for service provision with low cost technologies (WASREB, WSTF and WSBs) and enforcement of minimum standards (monitoring such as water quality, compulsory reporting, etc.). Use of regulatory instruments such as tariff negotiations, reporting, guidelines, etc. to enforce (incentives to the WSP) improved service provision to the poor. Service provision to the poor shall be one of the key performance indicators for all sector institutions. Reducing unaccounted for water and wastage. Water Service Providers to move to 100% metering, 27

billing according to consumption and rising block tariffs for increased cross-subsidization from bigger consumers to the poor. Affordability, availability and non-discrimination • •

Ensure that tariffs for basic (lifeline) consumption are affordable at household level connections and at public outlets. Rationing program and disaster management (emergency situation) designed and carried out to pro-poor requirements.

Governance: Participation, transparency and accountability • • • • •

The Boards of sector institutions and WSP should include representatives from areas that are not served or underserved and ensure gender balance. The management and operation of public water points should be by the poor and particularly women. Water Service Providers and Water Service Boards should make public information on their performance of service provision for serving the poor. Water Service Providers should ensure that the poor have access to information, their communication and complaint systems. Design and use public water points for information dissemination including HIV/AIDS sensitization and prevention.