The right to compensation for damage when the rights of the owner of a land plot are limited. A fresh look at the Constitutional Court

Types of restrictions and encumbrances of land plots

Restrictions on the use of the site and its encumbrances

The essence of encumbrances and restrictions on a land plot can be formulated as follows: these are partial or complete “infringements” established by the authorities and the law in its exploitation, in the right of the owner in favor of the interests of other persons or the state. The concepts of “burden” and “restriction” are not identical.

Encumbrance

An encumbrance is understood as a burden imposed on a land plot as a property of the owner. It determines the rules for the maintenance and operation of the allotment. The owner is obliged to comply with them.

The encumbrance of the land plot represents deviations in the direction of “reducing” the operational volume of the allotment:

• for example, a land plot “sits” within the boundaries of the security zone of a power line or gas pipeline
• during construction near bodies of water or in low-rise buildings
• other circumstances

An encumbrance in this case becomes, for example, a ban on capital construction in the security or protective zone running through the territory of the site.

Limitation

This is a reduction (reduction) of the owner’s rights to the site:

1. apply to real rights (Article 209 of the Civil Code of the Russian Federation)
2. constitutes an element of the ownership regime of any property
3. is associated with existing rights to property of third parties:
   rent
4. easement
5. mortgage
6. etc.
7. is expressed in limited exploitation of part of the land plot:
   for example, the owner does not have the right to locate capital structures and buildings on this part of the land, etc.
8. is retained when the copyright holder of the memory changes
9. creates obligations for third parties

The owner of a restricted plot cannot dispose of his land property in its entirety, but he remains its legal owner. Ownership rights remain with him (except for restrictions in the form of seizure of the plot).

Rights to land are also limited on the grounds established by the Land Code of the Russian Federation (Article 56) and federal laws:

• if the site is included within the borders of the ZOUIT
• special conditions for environmental protection and conditions for the conservation of: flora and fauna have been established
• natural, historical and cultural monuments
• archaeological sites
• fertile soil layer
• natural habitat
• migration routes for wild animals

The same article of the RF Land Code states that restrictions on land rights can be established:

1. acts of executive bodies of state power
2. acts of local government bodies
3. by court decisions for an indefinite period or for a specific period

Restrictions on rights to land and encumbrances are subject to state registration (clause 6 of Article 56 of the Land Code of the Russian Federation). This is a prerequisite for their action. Agreements and decisions on the basis of which such restrictions and encumbrances arise are also registered.

The owner of a plot whose rights are limited may appeal and remove the restriction in court.

Conclusion

The restrictions established for land plots protect the rights and interests of citizens, society or the state itself that are alien to the owner of the plot.

Types of restrictions and encumbrances of a land plot

Restrictions on the use of an allotment and its encumbrances are prohibitions, as well as limiting conditions that prevent the owner from using his rights to the entire land plot.

They cause excitement and anxiety among land owners, since they often arise against the will of the owners themselves, but do not always bring an unpleasant result for them.

Buyers of real estate, before signing a purchase/sale agreement, should clarify the legal status of the property: whether there are any encumbrances on it.

The ongoing confusion of the concepts of “restriction” and “burden” is associated with the legal basis of prohibitive and restrictive measures established in practice. You will have to make sure of this when you get acquainted with their species.

Land easement

A land easement gives the right to limited use of someone else’s land plot (Article 274 of the Civil Code of the Russian Federation).

It is installed for various reasons, for example:

• it is impossible to walk or drive up to the site: you have to negotiate with the owner of the neighboring site on the conditions for providing part of his plot for passage or passage

Types of land easement

An easement can be public or private (Article 23 of the Land Code of the Russian Federation)

1. Public easement

A public easement is created by decision of the authorities for state and municipal needs (based on a regulatory legal act), for example, for the following tasks:

• Carrying out: economic work necessary for the population or municipality
• work on the creation, repair or maintenance of public infrastructure

If the USRN does not contain information:

• on registered rights to land plots encumbered by public easement
• about the coordinates of characteristic points of the boundaries of such land plots

then disputes about the rights to such land plots are not an obstacle to the establishment of a public easement (clause 15 of Article 23 of the Land Code of the Russian Federation).

A public easement is not established in relation to land plots provided (Federal Law 341 of 08/03/2018):

• for individual housing construction
• gardening
• gardening
• running a private farm

It is prohibited to establish a public easement for the placement of engineering structures on such sites. An exception is, for example, cases when it needs to be installed for the operation or reconstruction of existing engineering structures.

Public easement fee

A public easement usually does not provide monetary compensation to the owner. The exception is those cases when the consequences of the imposed restrictions cause significant problems for the owner of the plot. In this case, the owner of the site has the right to count on compensation from the initiator of the public easement (clause 12 of Article 23 of the Land Code of the Russian Federation).

The procedure for resolving the issue of payment for a public easement:

• you need to apply to the authority that established the easement
• payment for the use of the site must correspond to the inconveniences and restrictions that the owner experiences due to the public easement
• it is necessary to justify the requirements and collect evidence that the use of the site has become difficult: indicate the area that cannot be used for its intended purpose due to a public easement
• attach to the application an appraiser's conclusion with a calculation of the fee for the public easement

If the establishment of the fee is refused, you are not satisfied with its size, or there is no response to the application, you will have to go to court with a claim to establish a proportionate fee and determine the order of payments. Documents supporting the claims must be attached to the claim.

2. Private easement

A private easement is introduced:

1. by agreement of citizens
2. through the court

Typically, an easement is an agreement (agreement) between the person requiring its establishment and the owner of the neighboring plot or other plots. It is formalized in writing (this is a real estate transaction). The agreement must be registered in the Unified State Register of Real Estate (Article 52 of Federal Law No. 218).

Without registration, the easement will not be considered established. It becomes valid from the moment of its registration. According to the concluded agreement, the duration of the easement can be either indefinite or for a specific period.

If the ownership of the encumbered land plot is transferred or transferred to another person, then the easement does not expire. It passes to the new owner of the land together with the real estate (clause 1 of Article 275 of the Civil Code of the Russian Federation).

Agreement establishing a private easement

An easement agreement is a civilized way:

1. establish and regulate the right to exploit part of someone else's land
2. indicate in writing the terms of the easement

The easement agreement must indicate:

• title of the document: “Agreement on the establishment of land easement”

Fee for the provision of a private easement

The owner of a land plot who has granted an easement has the right to demand monetary compensation from the persons in whose interests it was introduced (clause 12 of Article 23 of the Land Code of the Russian Federation).

Payment for easement must be proportionate. The amount of the fee and the procedure for its payment by the person who requested the easement must be specified in the contract. If a dispute arises between the contracting parties regarding the amount of payment for the easement, it can be determined in court.

The fee for a land easement may also be determined in the court decision on the basis of which this restriction was established.

Termination of a private easement

The validity of the land easement is terminated in the following cases:

1. by mutual agreement of the owners
2. when the conditions that led to the introduction of the easement disappear
3. as a result of encumbering the easement, the owner of the plot cannot preserve its intended purpose, he has the right to demand termination of the easement in court

2. Restrictions on the use of the site

2.1. Restrictions in zones with special conditions of use of the territory (ZOUIT)

Restrictions for land plots located within the boundaries of zones with special conditions for the use of territories (ZOUIT) are introduced in accordance with the legislation of the Russian Federation (Article 105 of the Land Code of the Russian Federation).

ZOUIT includes:

• security zones of power lines, water pipelines, gas pipelines, oil pipelines, communication lines
• sanitary protection zones (SPZ): this is a special territory with a special regime of use
• SPZs are established around facilities and industries that are sources of harmful effects on the environment and human health

Land plots partially or completely located within the boundaries of the ZOUIT are not confiscated (clause 3 of Article 104 of the Land Code of the Russian Federation).

Owners of land plots are not limited in administrative rights, that is, they can dispose of land at their own discretion:

• sell
• present
• bequeath
• to rent
• etc.

For plots located in ZOUIT, a special regime of use is introduced. It restricts or prohibits those activities that are incompatible with the purposes of the establishment of the ZOOIT.

The boundaries of ZOUIT are registered in the Unified State Register of Real Estate. The absence of information about the security zone in the Unified State Register of Real Estate is not a basis for exempting the owner of a land plot located in the security zone from complying with the requirements of the land use regime.

Encumbrances on a land plot, for example in the form of power transmission line security zones, impose a ban on the construction of capital structures and buildings.

If an underground electric cable runs through the allotment, then excavation work on the site can be carried out after agreement with the owner of the cable line.

The area encumbered by the security zone of a gas pipeline or oil pipeline is limited in use. In their security zones of linear objects, engage in:

• planting trees and shrubs
• make passages
• keep livestock
• arrange parking for vehicles
• organize garbage dumps
• etc.

possible after obtaining special permission from the owners of these linear facilities (operational services). Before agreeing with them, you need to determine the location of the site in the security zone. To do this, you will have to obtain information about the boundaries of the security zone from the Unified State Register of Real Estate.

It is allowed to carry out agricultural work on the site in the security zone. You do not need to obtain special permission for this.

It is strictly forbidden to move warning signs indicating that a gas or oil pipeline is located here, light a fire near them, open hatches, etc. These actions may lead to a violation of their integrity and, as a result, create a dangerous situation.

Responsibility for violating the regime of use of a land plot encumbered by a security zone rests with the owner of the plot.

Changing the security zone

If the owner of the plot has any doubts about the correctness of the established dimensions of the security zone, you need to contact a cadastral engineer. He will check the distance from the site to the boundaries of the security zone of the object for which it was established. Next, he will clarify the distance that is entered in the Unified State Register of Real Estate.

If the distances differ, we can conclude that the site does not fall within the protection zone. The data obtained during measurements is a good reason to contact the operating organization with a request to revise the boundaries of the protection zone. A judicial procedure for resolving the issue is not excluded.

Note on the application of the “dacha amnesty” within the ZOUIT

The State Duma Committee on State Building and Legislation recommended adopting in the first reading the draft Federal Law “On Amendments to the Federal Law “On State Registration of Real Estate” (on the issue of applying the legislation on “dacha amnesty” within zones with special conditions for the use of the territory (No. 1174787- 7). On May 24, 2021, the bill has already been considered by the Council of the GL

The planned law is aimed at clarifying the procedure for applying the “dacha amnesty” within zones with special conditions for the use of the territory:

• provides a mechanism for protecting the interests of citizens in already constructed facilities - if the ZOOIT is installed before 01/01/2022, the use of already constructed facilities is allowed except in cases where the presence of such a facility is harmful to the health and safety of citizens, for example, in airfield areas

The changes proposed by the bill will allow citizens to exercise their rights provided for by the “dacha amnesty” if their houses are located on the territory of a ZOOIT.

2.2. Restrictions in areas of specially protected natural areas (SPNA)

The territories of protected areas include (clause 2 of article 2 of Federal Law No. 133):

• lands of state nature reserves
• biosphere parks
• National parks
• natural parks
• state nature reserves
• natural monuments
• dendrological parks and botanical gardens with particularly valuable ecological systems and objects

Within the boundaries of protected areas it is prohibited:

• changing the purpose of land plots
• termination of rights to land for needs contrary to their intended purpose
• provision of horticultural and garden plots
• construction: highways
• pipelines
• power lines and other communications

The main VRI and auxiliary types of land plots located within the boundaries of protected areas are established by the regulations on specially protected natural areas (clause 14 of Article 2 of Federal Law No. 133):

• if zoning of protected areas is carried out, all main and auxiliary VRI regulations on specially protected natural areas are established for each functional zone of protected areas
• in cases where VRI ZU within the boundaries of a specially protected natural area allow construction, the regulations on the specially protected natural area reflect the maximum (maximum and (or) minimum) parameters of the permitted construction, reconstruction of the OKS

3. Rent of land

Rent of storage units can be short-term (for a period of up to a year) and long-term (from a year or more). A long-term lease agreement must be registered (clause 2 of Article 651 of the Civil Code of the Russian Federation). In this case, an encumbrance (lease) arises on the land plot. The validity period of a long-term lease begins from the moment of its registration.

If the property is rented out, this factor does not affect the execution of the transaction between the parties (the owner of the plot and the buyer). A change of landlord does not require the consent of the tenants. It does not entail termination of the lease agreement (clause 2 of Article 617 of the Civil Code of the Russian Federation).

Until the end of the transaction made by the owner of the plot with another person, the lessor and the lessee retain all rights and obligations under the lease agreement.

After completion of the transaction, the tenant has a new landlord, who continues to fulfill the terms of the lease agreement concluded between the previous landlord (former owner of the site) and the tenant.

Termination of a lease agreement for a land plot is the basis for removing the encumbrance registered in Rosreestr.

4. Seizure of land

Seizure of land is a common type of land encumbrance. It is imposed:

• by court determination: as a measure to secure a claim (Article 140 of the Code of Civil Procedure)

The seizure of a plot is associated with the debts of its owner (for example, debts for alimony, loans, taxes). Land, depending on the amount of debt:

• are arrested
• describe
• sell at auction

Seizure of a plot means a ban on the disposal of land, and, if necessary, a restriction of the right to use it or its seizure.

The arrest is made:

• during the trial to determine the owner of the plot
• if there are reasonable fears that the disputed land will be alienated before the end of the court cases
• based on a court decision

After the court has made a decision to arrest the allotment, the owner is prohibited from performing actions with it at his own discretion, alienating it in favor of third parties until the arrest is lifted:

• sell
• present
• bequeath
• rent out
• use as collateral
• make any other types of transactions

This means that transactions with seized land are impossible. Agreements on them simply will not be registered.

Land seizure is an absolute prohibition. Until it is removed, the copyright holder will under no circumstances be able to:

• dispose of the land
• create new land plots
• divide the land into several plots
• re-register the plots received during the division in some way

If the land plot is not confiscated, the seizure does not prohibit the owner from using the plot.

Land plots on which a building has been erected, which is the only place suitable for the debtor to live, is not subject to seizure, but on the condition that the structure should not be pledged. This means that the plot on which the mortgaged house stands may be seized due to the debt under the mortgage agreement.

Removing the seizure of a land plot

Both for imposing and lifting the seizure of land, the following rules must be followed:

1. the following may file a claim:
   owner-debtor
2. other share owners of the site
3. heirs
4. representatives by notarized power of attorney
5. The statement of claim contains the basis for lifting the arrest:
   confirmation of debt repayment, etc.
6. the requirement to lift the restriction is supported by evidence:
   certificate of ownership
7. court decision or ruling on arrest
8. by the bailiff's order
9. debt payment receipts and other documents

The conditions for lifting restrictions depend on the reasons for applying the penalty:

• a debt collected by a bailiff as part of enforcement proceedings to pay off a debt for alimony, mortgage, etc.: the arrest can be lifted after repaying the debt under the obligation (pay a loan, alimony)

With a court decision marked as having entered into force, you must contact the authorized body that imposed the arrest. After he sends the decision to Rosreestr, appropriate changes are made to the Unified State Register, and the owner is issued a new document on the renewal of ownership.

Checking the existence of a lien on a land plot

Property buyers need to check the lien on the land before signing the purchase/sale agreement. To do this, you should submit an application to Rosreestr or order an extract from the Unified State Registration Register:

• at the Rosreestr office
• at the MFC
• online

Rosreestr maintains the Unified State Register of Real Estate. It contains information about objects, including arrest data.

Land mortgage

Types of land mortgage of real estate:

• mortgage by force of law : arises from a loan from a bank or other credit organization taken out to purchase a plot of land
• real estate is pledged from the moment of state registration of the mortgage in the Unified State Register of Real Estate (clause 1 of Article 77 of the Mortgage Law No. 102-FZ)

1. Mortgage by force of law

Land mortgage by force of law (legal pharmacy) is a targeted loan for the purchase of a plot. The bank issues a mortgage loan against collateral. It becomes an allotment purchased with borrowed funds. The plot remains pledged to the bank until the debt is paid in full (clause 1 of Article 338 of the Civil Code of the Russian Federation).

When applying for a mortgage, a mortgage agreement is signed between the borrower and the bank. A mortgage agreement is an agreement on the pledge of real estate.

A mortgage agreement containing an obligation secured by a mortgage is not subject to state registration. Only the purchase/sale agreement of a land plot is registered in Rosreestr.

A mortgage is subject to state registration by force of law (clause 2 of Article 20 of the Law on Mortgage (Pledge of Real Estate) No. 102-FZ). At the same time, the allotment has an encumbrance (mortgage). It arises automatically from the moment of state registration of ownership of a land plot (clause 2 of Article 11 No. 102-FZ). The ownership of the plot and its encumbrance are registered simultaneously.

You can do construction on the site. The bank's permission and a report to it on the progress of work are not required. The mortgage applies to all structures and buildings built on the site (Article 64.2 No. 102-FZ).

If the borrower has a large debt, the bank has the right to sell the land along with the buildings already built on it. They are put up for auction by the bank, and the proceeds go to repay the debt.

The owner of a plot encumbered with a mortgage has the right to dispose of the land plot:

• to rent
• sell

A contract for the purchase and sale of a land plot with an encumbrance can be concluded after the mortgage debt is transferred to the buyer. This is possible only with the consent of the creditor bank.

The encumbrance of the mortgage on the plot is removed after its repayment.

2. Mortgage by virtue of an agreement

A contractual mortgage arises on the basis of a mortgage agreement (mortgage of real estate).

A mortgage agreement is not an independent obligation, but one under which the obligation establishes:

• or loan agreement
• or loan agreement
• or other agreement

A mortgage arises by virtue of a contract when the buyer-borrower:

• registers the land plot, which is purchased with credit funds, as his own property: at the same time, he receives the plot without encumbrance
• transfers to the bank a package of documents for a plot or other real estate, which in the future will become the subject of collateral

That is, the mortgage by virtue of the contract is subject to registration upon a separate application of the parties. In this way, it differs from a legal mortgage, which arises by virtue of a direct indication in the law and is registered automatically along with the purchase/sale agreement of the land plot.

The mortgage encumbrance by virtue of the agreement is removed in the Unified State Register of Real Estate after the borrower repays the debt and submits to Rosreestr a mortgage note from the bank indicating the absence of debt.

During the period of validity of the mortgage, the borrower has the right to dispose of the land plot without its alienation or re-registration.

Tax lien

A tax lien is one of the ways a taxpayer can pay debts on taxes (fees, insurance premiums, penalties, fines) in case of failure to pay them within the time limit established by the Tax Code.

From April 1, 2021, amendments to the Tax Code related to the formation of a pledge in the event of a taxpayer’s failure to fulfill obligations to the budget will come into force:

• new paragraph 2.1 of Article 73 of the Tax Code of the Russian Federation
• will appear in the text 04/01/2020

The right of a tax lien arises by force of law (subparagraph “b” of paragraph 19 of Article 1 of Federal Law No. 325-FZ). The property of a payer who has a tax payment debt is transferred to a tax lien.

The taxpayer’s property will be recognized as being pledged to the tax authority on the basis of law in the following cases:

1. if the taxpayer, within 1 month, does not repay the debt on taxes and fees, insurance premiums under the decision on collection, according to which the property was seized
2. failure to comply with a decision that has entered into force to prosecute a tax offense, which introduced a ban on the alienation or pledge of property without the consent of the tax authority

It means:

• tax authorities will be able to automatically take the taxpayer's property as collateral if he ignores demands for payment of arrears and the subsequent seizure of assets
• the pledge will be established on the property that was mentioned in previous decisions: if the property is already pledged, then the new pledge (from the tax authorities) will be recognized as follows

The resulting tax lien is subject to state registration and accounting. You can avoid forced encumbrance:

1. if you provide a bank guarantee confirming that the bank undertakes to pay the arrears, as well as penalties and fines
2. on behalf of a third party

Amendments to Article 73 of the Tax Code of the Russian Federation vest the authorized body with the rights of a mortgagee by force of law. The Federal Tax Service receives the status of a secured creditor and gives it an advantage in satisfying its claims over other creditors.

The right of tax lien applies to any property of the taxpayer that is in his ownership (economic control or operational management). The price of the property must be equal to the amount of the taxpayer’s tax debt. The collateral can also be a land plot.

Property subject to the right of tax lien is documented in an inventory act. It includes liquid property that can be used as a source of repayment of tax debt.

An inventory of property in tax lien is made based on the decision of the head of the tax authority. It is presented to the taxpayer-debtor.

A taxpayer’s refusal to sign a property inventory report does not exempt him from extending the right of a tax lien to the described property. The property will then be described in the presence of at least two witnesses.

If the taxpayer does not allow the tax administrator to make an inventory of his property as a tax lien or does not submit the documents necessary for the inventory, the tax authority has the right to go to court to suspend debit transactions on the taxpayer’s accounts and prohibit the alienation of property by such a taxpayer.

The taxpayer retains the right to use the property located in the tax lien, unless otherwise prohibited by law. Transactions in relation to pledged property (for example, transactions made to repay debts) can only be carried out with the consent of the pledgee.

Alienation of property held as a tax lien is possible in the following cases:

1. the taxpayer has received the consent of the Federal Tax Service
2. The Federal Tax Service within 10 days from the date of receipt of the taxpayer’s application did not give him an answer regarding the provision (non-provision) of consent

Termination of tax lien

The taxpayer's property is released from the tax lien from the date:

1. receipt by the tax authority of confirmation of full repayment of the amount of the tax debt in the manner prescribed by law
2. recognition of a tax debt as hopeless
3. court decisions within the framework of procedures under legislation in bankruptcy matters
4. receipt by the taxpayer of a decision to cancel previous decisions on the accrual of the amount of a monetary liability or part thereof (fines and penalties) as a result of an administrative or judicial appeal procedure

If a taxpayer's property is released from a tax lien, a notification in the prescribed form is sent to him.

Trust management

Trust management is one of the types of land encumbrance. It is registered with the Rosreestr authorities.

In case of trust management:

• the disposal of land is carried out by a person appointed by the owner of the land plot (manager): paragraph 4 of Article 209 of the Civil Code of the Russian Federation

When concluding a trust management agreement, the main restriction is not violated - the land plot does not become private property (clause 2 of Article 27 of the Land Code of the Russian Federation). It is generally impossible to change the owner under such an agreement.

The conclusion of a trust management agreement is permitted by law. This is indirectly confirmed in Article 1013 of the Civil Code of the Russian Federation. In it, among the objects of the trust management agreement, enterprises and property complexes are named, which can include and usually have land plots.

Several legal norms are devoted to issues of trust management:

• Article 16 of Federal Law No. 101 states that previously concluded lease agreements for land shares must be brought into compliance with the rules of the Civil Code of the Russian Federation and paragraph 2 of Article 9 of this Law within 2 years from the date of its entry into force

It turns out that previously concluded lease agreements are recognized as trust management agreements, since:

• the tenant is treated as a trustee
• the concept of “beneficiary” can be applied to the lessor
• to rent – ​​apply the concept of “benefit under the contract”

In matters of changing the legal regime, a number of basic elements of trust management and lease agreements do not coincide:

• rent and remuneration under a trust management agreement have different regimes, since their economic significance does not coincide: rent, as a general rule, is included in the cost
• Manager's remuneration is not included in the cost price

The rule on extending the rules of a trust management agreement to previously concluded lease agreements for land shares applies only to those cases where the lease agreements have not been brought into compliance with current civil legislation.

The practice of trust management is usually used abroad. In Russia, it is much less common, especially rare, for individuals to use such an agreement.

Consulting services

Cost of consultation conducted by specialists on the use of land plots in the presence of encumbrances/restrictions (clause 17 of the “Tariffs” section):

• 3,000 rub. – for individuals
• 5,000 rub. - for legal entities

Helpful information

• On the requirements for the construction of residential buildings and other public buildings in the area near the airfield (APT) from July 1, 2021 - here
• You can get acquainted with the characteristics of agricultural land, the concept of quality score, and the mode of use of such land here
• About the practical usefulness of the cadastral territory plan (CTP) - here
• Regulations for the preparation and approval of the layout of a land plot on the cadastral plan of the territory (CPT) - here
• Provision of public land plots from agricultural lands for farming and running private household plots - here
• Simplified technological connection diagram for gardeners, summer residents, legal entities, individual entrepreneurs - 2021 - read here
• Read about a new approach to the integrated development of settlement territories (SDT) and achieving housing comfort for citizens here
• “Dacha Amnesty” 2021 – 2026: new opportunities – read here
• How to get a plot from a municipality or state - read here
• Read about the procedure for including sites within the boundaries of settlements here
• Risks from establishing red lines on a land plot – here
• What is a “development spot” on a land plot – read here

How to find out about the presence of an encumbrance

Before purchasing land, you need to check whether it is under encumbrance. It's not difficult to do this.

The main option is to contact Rosreestr or MFC and order an extract from the Unified State Register of Real Estate. It will indicate the presence of imposed restrictions.

Also popular is the question of how to find out about the presence of prohibitions via the Internet. At the moment, you can get an extract from the Unified State Register of Real Estate online without leaving your home. The service will be paid, but will be cheaper than the paper version.