Access to information regarding total allowable catches (TACs) of EU fish stocks in the Northeast Atlantic discussed and adopted on 11 and 12 December 2017, and exemptions from the landing obligation

Die Anfrage war erfolgreich.

Dear Maritime Affairs and Fisheries,

In accordance with Article 2 of Regulation 1049/2001 and Article 3 of Regulation 1367/2006, ClientEarth would like to have access to the following:

1. Documents related to the total allowable catches (TACs) for fish stocks in the Northeast Atlantic for 2018, specifically:
• Any records, minutes or notes of meetings/discussions that took place between the Commission and the Member State representatives on the TACs for 2018, including any minutes or notes of Council working party/ministerial meetings taken by Commission staff, and any internal Commission briefings on the subject. We do not seek access to the Commission's legislative proposals for the 2017 TACs, unless such documents are annotated and/or contain negotiation directives. We also do not seek access to the documents that were publicly available in the Council’s document register, filed under interinstitutional code 2017/0287 (NLE) at the date of this request.
• a full table of all proposed and agreed quota top-ups (in tonnes and %) and TACs before the top-ups were applied;
• a detailed description of the methodology used to calculate quota top-ups;
• the calculations that the proposed and agreed quota top-ups were based on, ideally in Excel spreadsheet format.

2. Any documents relating to exemptions from the landing obligation, within the period following the review by STECF’s EWG 17-03 of the joint recommendations in July 2017 until the adoption of the discard plans for 2018 in November 2017, including any correspondence between the Commission and the Member States and any records, minutes or notes of meetings/discussions that took place between the Commission and the Member State representatives regarding this matter.

Yours faithfully,

Anne Friel
Lawyer
ClientEarth

Yours faithfully,

Anne Friel

Generaldirektion Maritime Angelegenheiten und Fischerei

Dear Mrs Friel,

Thank you for your request for access to documents.

Unfortunately you have not indicated your postal address that is required for registering and handling your request in line with the procedural requirements. Please send us your full postal address at your earliest convenience. Pending your reply, we reserve the right to refuse the registration of your request.
You may, of course, use directly the electronic form for entering your request:

http://ec.europa.eu/transparency/regdoc/...

Best regards,

MARE ACCESS TO DOCUMENTS
 
European Commission
DG Maritime Affairs and Fisheries
Unit E.4 – Legal Affairs

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[4]Ares(2018)2327577 - GESTDEM 2018/2076

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Dear Ms Friel,

We refer to your e-mail dated 12/04/2018 in which you make a request for
access to documents, registered on 12/04/2018 under the above-mentioned
reference number.

Your application is currently being handled. However, we will not be in a
position to complete the handling of your application within the time
limit of 15 working days and an extended time limit is needed as your
application concerns documents held by the Member States which must be
consulted.

According to the competent service, one month is needed to proceed to
their consultation. Therefore, we will contact you as soon as this
procedure is concluded in order to make available to you the requested
documents.

We apologize for this delay and for any inconvenience this may cause.

Yours sincerely,

Bien à toi,

 

Cécile DUCATEZ

MARE.E.4 – J-99 05/64 – Tél: 50288

 

 

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Generaldirektion Maritime Angelegenheiten und Fischerei

2 Attachments

Dear Madam,
 
We refer to your e-mail dated 11/04/18 in which you make a request for
access to documents.
We enclose a copy of the pertinent documents related to your requested
originating from a Member State.
We are still waiting for the agreement of other  Member States. We will
come back to you when such agreement is provided.
You may reuse the document requested free of charge for non-commercial and
commercial purposes provided that the source is acknowledged, that you do
not distort the original meaning or message of the document. Please note
that the Commission does not assume liability stemming from the reuse.
Best regards,
 
Efthimiou Alexandra
 
MARE ACCESS TO DOCUMENTS
 
European Commission
DG Maritime Affairs and Fisheries
Unit E.4 – Legal Affairs
 
 
 
 
 
 
 
 

Generaldirektion Maritime Angelegenheiten und Fischerei

3 Attachments

Dear Madam,
 
We refer to your e-mail dated 11/04/2018 in which you make a request for
access to documents.
We enclose a copy of the pertinent documents related to your requested
originating from a Member State. We are still waiting for the agreement of
one Member State and will come back to you when such agreement is
provided.
 
Best regards,
 
Efthimiou Alexandra
 
MARE ACCESS TO DOCUMENTS
 
European Commission
DG Maritime Affairs and Fisheries
Unit E.4 – Legal Affairs
_____________________________________________

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[4]Ares(2018)2870557 - GESTDEM 2018/2076

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Dear Madam,

 

We refer to your e-mail dated 11/04/18 in which you make a request for
access to documents.

We enclose a copy of the pertinent documents originating from a Member
State.

You may reuse them free of charge for non-commercial and commercial
purposes provided that the source is acknowledged, that you do not distort
the original meaning or message of the document. Please note that the
Commission does not assume liability stemming from the reuse.

Best regards,

Cécile DUCATEZ
MARE.E.4 – J-99 05/64 – Tél: 50288

 

 

 

 

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Dear Ms Ducatez,
I write in relation to request GESTDEM 2018/2076. Could you confirm if your message on 1 June is your final response or if you intend to send further documents?
Many thanks,
Anne Friel

EC ARES NOREPLY,

[1]Ares(2018)3059361 - RE: access to documents request - Access to
information regarding total allowable catches (TACs) of EU fish stocks in
the Northeast Atlantic discussed and adopted on 11 and 12 December 2017,
and exemptions from the landing obligation

Sent by ve_mare.acces.documents (MARE)
<[email address]>. All responses have to be sent to this
email address.
Envoyé par ve_mare.acces.documents (MARE)
<[email address]>. Toutes les réponses doivent être
effectuées à cette adresse électronique.

Dear Ms Friel,
Thank you for your message registered Ares(2018)3059154.
In relation to your question below, I confirm that the documents sent to
you are the only ones regarding this subject.

Best regards,
Cécile DUCATEZ
MARE.E.4 – J-99 05/64 – Tél: 50288

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Dear Sir/Madam,

RE: GESTDEM 2018/2076 - Confirmatory application in relation to the Commission's decision not to disclose information on total allowable catches (TACs) of EU fish stocks in the Northeast Atlantic discussed and adopted on 11 and 12 December 2017

In accordance with Article 7(2) of Regulation (EC) No 1049/2001 of the European Parliament and of the Council regarding public access to European Parliament, Council and Commission documents, ClientEarth hereby submits a confirmatory application with regard to the Commission's initial reply to its request for documents with reference GESTEM 2018/2076 relating to the adoption of the fishing opportunities for the Northeast Atlantic for 2018 under Article 16 of Regulation (EC) No 1380/2013 and exemptions from the landing obligation.

On 11 April 2018 ClientEarth requested access to the following information:
1. Documents related to the total allowable catches (TACs) for fish stocks in the Northeast Atlantic for 2018, specifically:
• Any records, minutes or notes of meetings/discussions that took place between the Commission and the Member State representatives on the TACs for 2018, including any minutes or notes of Council working party/ministerial meetings taken by Commission staff, and any internal Commission briefings on the subject. We do not seek access to the Commission's legislative proposals for the 2017 TACs, unless such documents are annotated and/or contain negotiation directives. We also do not seek access to the documents that were publicly available in the Council’s document register, filed under interinstitutional code 2017/0287 (NLE) at the date of this request.
• a full table of all proposed and agreed quota top-ups (in tonnes and %) and TACs before the top-ups were applied;
• a detailed description of the methodology used to calculate quota top-ups;
• the calculations that the proposed and agreed quota top-ups were based on, ideally in Excel spreadsheet format.
2. Any documents relating to exemptions from the landing obligation, within the period following the review by STECF’s EWG 17-03 of the joint recommendations in July 2017 until the adoption of the discard plans for 2018 in November 2017, including any correspondence between the Commission and the Member States and any records, minutes or notes of meetings/discussions that took place between the Commission and the Member State representatives regarding this matter.

The Commission replied on 2 May 2018, stating that it needed to extend the deadline by an additional 15 working days. Following this, the Commission disclosed five documents.

On 15 May the Commission sent document 1 with title, "Table: Completed STECF table for information on Nephrops grounds outside Farne Deeps". The Commission did not state the origin of the document, its date or to which part of the request it relates. It seems to be from the UK government and to relate to part 2 of the request on landing obligation exemptions.

On 17 May the Commission resent the document it had already sent on 15 May, together with document 2 with title, "Study of the Portuguese Fleets catching hake (Merluccius merluccius) in Area IXa (HKE 8C3411)", again without stating its date or to which part of the request it relates. It seems to relate to part 2 of the request also.

On 1 June the Commission sent three further documents. Document 3 entitled, "Informe: Asesoramiento para aportar informacion cientifica a una solicitud de informacion complementaria sobre el estudio de la merluza para la solicitud des "de minimis" y la de la cigalas" and document 4 entitled, "Additional information the de minimis exemption consolidation request for hake (merluccius merluccius) of 6%, for 2017 and 2018 and 5% thereafter proposed from Spain for trawlers catching hate in the Bay of Biscay". Both of these documents seem to be supporting information from Spain regarding a de minimis exemption request for hake. Document 5 is an Excel table with fishery/discard info for Nephrops. Again, these documents seem to relate to part 2 of the request.

In response to a message dated 11 June to clarify whether the Commission intended to send any further documents, the Commission replied that same day to confirm that, "the documents sent to you are the only ones regarding this subject."

ClientEarth requests that the Commission reassess its decision to disclose only document 1 - 5 in relation the request for the reasons set out below.

FAILURE TO DISCLOSE ANY DOCUMENTS IN RELATION TO THE TOTAL ALLOWABLE CATCHES (TACs) FOR FISH STOCKS IN THE NORTHEAST ATLANTIC FOR 2018

The Commission has not provided access to a single document in relation to the first part of our request.

First, ClientEarth has cause to believe that documents falling within the scope of part 1 of its request exist and are in the Commission's possession. In response to a similar request for information made to the Commission on 26 June 2017 (GestDem 2017/3796 - Ares (2017)3211301), the Commission disclosed its own record of the discussions which took place in the Council working parties leading up to the adoption of the TACs and quota Regulation for 2017. Either the Commission simply did not take any record of the working party discussions leading to the adoption of the TACs and quotas Regulation for 2018 or it has failed to disclose them.

In the latter case, as confirmed by the CJEU (Case T-653/16 Malta v Commission, para. 63), it is well-established practice for the Secretary-General to verify as part of the assessment of a confirmatory application whether all documents falling under the scope of the request have been identified at the initial stage. This is especially the case where the applicant, as in this confirmatory application, contests that the initial list of documents was complete. ClientEarth therefore requests the Secretary General to conduct such a verification of the scope of the initial request. This request is not confined to clarifying whether Commission minutes of Council discussions exist. It extends to all other aspects of ClientEarth's request for access to documents which is the subject of this confirmatory application.

Should any relevant documents, such as Commission minutes of working party meetings, in fact exist, non-disclosure would constitute an implied refusal of access, for the purposes of Article 7(1) of Regulation No 1049/2001. As clarified by the CJEU, "[s]uch an implied refusal implies, by definition, an absolute lack of reasoning" (Case T-300/10 Internationaler Hilfsfond eV, para. 186) and therefore also a failure to comply with Article 296 TFEU .

Second, if the documents do not exist because the Commission simply failed to record the discussions at the working party meetings leading to the TACs and quotas Regulation for 2018, ClientEarth submits that this is a breach of the Commission's obligations under the EU's transparency framework. This also applies to its failure to record the discussions which took place at the Agriculture and Fisheries Council on 11 and 12 December 2017.

The EU institutions have a legal duty to draw up and retain documentation relating to their activities in a non-arbitrary and predictable manner. Article 10(3) of the Treaty on European Union states that, "Every citizen shall have the right to participate in the democratic life of the Union. Decisions shall be taken as openly and as closely as possible to the citizen". Article 15(3) of the Treaty on Functioning of the European Union further develops this principle by giving citizens a right to access documents of the Union’s institutions, “subject to the principles and the conditions to be defined in accordance with this paragraph.”

The principles and conditions were defined in Regulation 1049/2001, Article 2 of which provides that, “Any citizen of the Union, and any natural or legal person residing or having its registered office in a Member State, has a right of access to documents of the institutions, subject to the principles, conditions and limits defined in this Regulation.”

In Case T-264/04 WWF European Policy Programme v the Council of the European Union, the Court of First Instance held that “it would be contrary to the requirement of transparency which underlies Regulation No 1049/2001 for institutions to rely on the fact that documents do not exist in order to avoid the application of that regulation. In order that the right of access to documents may be exercised effectively, the institutions concerned must, in so far as possible and in a non-arbitrary and predictable manner, draw up and retain documentation relating to their activities.”

Contrary to the present case, in Case T-264/04, the Court of First Instance held that it could not be concluded that the Council, in claiming that minutes of the first agenda item of its Article 133 Committee meeting did not exist, acted in an arbitrary or unpredictable manner. The Court came to this conclusion owing to the “purely informative nature of that item at the meeting and the fact that it did not call for any specific implementing measure”. The same conclusion cannot be applied to the Commission's failure to draw up and retain a record of the discussions leading to the unanimous political agreement for a Regulation which, in many respects, departs significantly from its proposal and which requires implementing legislation at national level.

This is supported by the text of Regulation No. 1049/2001. Recital 2 of the Regulation states that, “[o]penness enables citizens to participate more closely in the decision-making process”. Article 6 very clearly states that “[w]ider access should be granted to documents in cases where the institutions are acting in their legislative capacity, including under delegated powers, while at the same time preserving the effectiveness of the institutions' decision-making process. Such documents should be made directly accessible to the greatest possible extent.”

These considerations are of particular importance in the context of setting TACs. The Commission’s proposed TACs take account of the scientific advice provided by the International Council for the Exploration of the Sea (ICES), and have the objective of bringing the stocks to levels that can deliver MSY by achieving the corresponding MSY exploitation rates by "2015 where possible and on a progressive and incremental basis at the latest by 2020". Recital 7 to the CFP Basic Regulation states that, "Achieving those exploitation rates by a later date should be allowed only if achieving them by 2015 would seriously jeopardise the social and economic sustainability of the fishing fleets involved." To fulfil its duty as guardian of the Treaties (and of measures adopted by the institutions pursuant to them, including Regulation (EU) No 1380/2013 on the Common Fisheries Policy) under Article 17 TEU, the Commission must defend its proposal during discussions in Council working parties and ministerial meetings. Therefore, in order for EU citizens to be able to scrutinise whether the Commission has fulfilled its role in the decision-making process by adequately defending and explaining its original proposal to the Member States, it must accurately record the discussions leading to the final TACs and quotas adopted by the Council, both at working party level and in the Agriculture and Fisheries Council that took place on 11 and 12 December 2017. Failure to do so breaches ClientEarth's right to access documents of the institutions under Article 2 of Regulation 1049/2001, as well as Article 10 TEU and Article 15 TFEU.

FAILURE TO DISCLOSE DOCUMENTS RELATING TO TOP-UPS

In addition to this, ClientEarth specifically requested access to the following documents regarding top-ups:
• a full table of all proposed and agreed quota top-ups (in tonnes and %) and TACs before the top-ups were applied;
• a detailed description of the methodology used to calculate quota top-ups;
• the calculations that the proposed and agreed quota top-ups were based on, ideally in Excel spreadsheet format.

No information on this has been provided in response to our request. There can be no doubt that this information exists and is in the Commission's possession for the following reasons.

The gradual introduction of the obligation to land all catches of quota stocks in the Northeast Atlantic has added a further level of complexity to the annual exercise of comparing the proposed and agreed TACs to the underlying scientific advice. As the 'discard ban' is phased in throughout European waters, the purpose of TACs changes from regulating landings to regulating catches. What was previously a Total Allowable Landing limit now becomes a true Total Allowable Catch limit. Until 2019, catches of many stocks are subject to the landing obligation only if taken by certain fleet segments, i.e. these stocks are only partially under the landing obligation. This means that the Commission must calculate the appropriate quota 'top-up' or 'uplift' amounts that are added to the advised landings to account for those catches that were previously discarded, but which must now be landed.

Since 2015, the Commission has been proposing such quota top-ups, which have subsequently been incorporated into the TACs adopted by the Council. This means that they must be in possession of information on a) the methodology and data used to calculate the top-ups, b) the calculations themselves, and c) the proposed and agreed top-ups.

In previous years, the Commission has provided this top-up information in response to access to documents requests submitted by other NGOs, such as Seas at Risk (Access to documents request to the Commission with Ref. Ares(2017)499998) and Pew Charitable Trusts (Access to documents request to the Commission with Ref. Ares(2016)542872). This raises questions regarding the Commission's failure to disclose this information.

We therefore request that the Commission verify whether it is in possession of documents falling within the scope of our request on this point, in line with the CJEU's case law in case T-653/16 Malta v Commission, para. 63. It should be recalled that failure to disclose existing documents constitutes an implied refusal of access, for the purposes of Article 7(1) of Regulation No 1049/2001, read in conjunction with Regulation 1367/2006, and a failure to state reasons in breach of Article 296 TFEU (Case T-300/10 Internationaler Hilfsfond eV, para. 186).

DOCUMENTS DISCLOSED IN RELATION TO EXEMPTIONS FROM THE LANDING OBLIGATION

ClientEarth requests that the Commission verify the documents in its possession which relate to part 2 of its request for access to documents, namely, any documents relating to exemptions from the landing obligation, within the period following the review by STECF’s EWG 17-03 of the joint recommendations in July 2017 until the adoption of the discard plans for 2018 in November 2017.

The reason we ask for this verification is that the Commission's decisions adopting discard plans for both the North Sea (https://eur-lex.europa.eu/legal-content/...) and the North Western Waters (https://eur-lex.europa.eu/legal-content/...) are in some cases not in line with the conclusions of the STECF.

For example, a high survival exemption for undersized sole caught with certain trawl gears in area IVc 'within 6 nautical miles of the coast in ICES area IVc and outside identified nursery areas' was adopted in the North Sea discard plan for 2018 (Article 5 of Commission Delegated Regulation (EU) 2018/45). However, the discard plan does not specify where these nursery areas are located within the North Sea, despite the STECF's conclusion that 'it is important that the position of these nursery areas is clearly indicated in the relevant Regulation' (STECF 17-02, https://stecf.jrc.ec.europa.eu/documents..., p. 30.) The failure to include a clear specification of the location of these nursery areas in the discard plan is contrary to STECF's conclusion, and means that it is unclear where exactly this exemption applies.

Moreover, the 2018 discard plan for demersal fisheries in the North Western Waters contains three de minimis exemptions for whiting, which were originally requested and evaluated in 2016 and have since then been rolled over from year to year. The STECF Plenary 16-02 concluded in the 16-10 report (https://stecf.jrc.ec.europa.eu/documents..., pp. 8-10) that the information provided to support these exemption requests was 'insufficient' and that 'STECF is unable to complete an evaluation until the requested information is provided'. All three exemptions were nevertheless included in the 2016 discard plan, with a requirement for Member States to provide the missing information by 1 May 2016 (Article 3(2) in Commission Delegated Regulation (EU) 2015/2438). The exemptions were then re-included in the 2017 and 2018 discard plans (Commission Delegated Regulation (EU) 2016/2375, and 2018/44, respectively) - without an equivalent requirement to provide further information, but not re-evaluated in the STECF 17-02 report. It is therefore unclear whether any of the missing information requested by the STECF was actually provided before the (re-)inclusion of these exemptions in the relevant discard plans.

These examples illustrate that the final discard plans do not adequately reflect the STECF's findings in a number of cases, raising the question why the Commission decided to include these exemptions as recommended by the Member States, contrary to the STECF's conclusions. Therefore, we take this opportunity to further clarify our original request to access any documents relating to the exemptions from the landing obligation, including any documents which mention the Commission's decision to adopt certain exemptions in spite of STECF's findings to the contrary and/or documents relating to meetings with the Member States or STECF held in this period. If the Commission failed to document any meetings that did in fact take place during this period, such failure constitutes a breach of Article 2 of Regulation 1049/2001 and Regulation 1367/2006.

ACCESS TO 'ENVIRONMENTAL INFORMATION' IN COMPLIANCE WITH REGULATION 1367/2006 ON THE APPLICATION OF THE PROVISIONS OF THE AARHUS CONVENTIONON ACCESS TO INFORMATION, PUBLIC PARTICIPATION AND ACCESS TO JUSTICE IN ENVIRONMENTAL MATTERS TO COMMUNITY INSTITUTIONS AND BODIES

The minutes of the discussion that took place at the working party meetings and the Agriculture and Fisheries Council, the information on top-ups and the information on exemptions from the landing obligation constitute “environmental information” within the meaning of Article 2(d) of the Aarhus Regulation because they are information on measures affecting biological diversity. The Aarhus Regulation goes further than Regulation No 1049/2001 in that it guarantees access, not only to documents, but to information. Therefore, even if the Council is not in possession of the documents requested, it is obliged to provide ClientEarth with information on the content of the discussions at the Council meeting in question.

BREACH OF THE DUTY TO STATE REASONS (ARTICLE 296 TFEU) AND THE RIGHT TO GOOD ADMINISTRATION (ARTICLE 41 CFR)

Each citizen of the EU has a right to good administration in accordance with Article 41 of the EU Charter for Fundamental Rights. ClientEarth believes that the Commission's conduct in replying to this access to documents request is not in keeping with the spirit of that right. The documents disclosed were not labelled, dated or explained. Furthermore, ClientEarth has serious cause to believe that the Commission is in possession of other documents that come within the scope of the request, as detailed above. Such non-disclosure must be motivated by reasons in accordance with Article 296 TFEU as well as Article 41 CFR.

Yours faithfully,

Anne Friel
Lawyer - Environmental Democracy
ClientEarth
60 Avenue du Trone
1050 Brussels
t. +32(0)2 808 0172
e. [email address]

Jenni Grossmann
Science and Policy Advisor - Fisheries
ClientEarth
t. +44(0)303 050 5943
e. [email address]

Generaldirektion Maritime Angelegenheiten und Fischerei

Dear Ms Friel,
Please be advised that your confirmatory application has to be addressed to the Secretariat-General of the Commission at the following address: European Commission
Secretary-General
Transparency unit SG-B-4
BERL 5/282
B-1049 Bruxelles
or by email to: [email address]

Best regards,
Cécile DUCATEZ
MARE.E.4 – J-99 05/64 – Tél: 50288

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[1]Ares(2018)3358008 - FW: GESTDEM 2018/2076

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Dear Madam,

Thank you for your email dated 22/06/2018 by which you request, pursuant
to Regulation No 1049/2001 regarding public access to European Parliament,
Council and Commission documents, a review of the position taken by DG
MARE in reply to your initial application GESTDEM 2018/2076.

We hereby acknowledge receipt of your confirmatory application for access
to documents which was registered on 25/06/2018 (Ares(2018)3355212).

Your application will be handled within 15 working days (16/07/2018).  In
case this time limit needs to be extended, you will be informed in due
course.

Please be informed that the answer to your confirmatory application is a
formal Commission decision that will be notified to you by express
delivery.  Thank you for having provided your contact phone number, so
that the external delivery service can contact you in case of absence.

Please note that the Commission will not use your phone number for any
other purpose than for informing the delivery service, and that it will
delete it immediately thereafter.

Yours faithfully,

Carlos Remis
SG.B.4
Transparence
Berl. 05/315

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[5]Ares(2018)3717248 - Your confirmatory application for access to
documents under Regulation (EC) No 1049/2001 – GESTDEM 2018/2076

Sent by ve_sg.accessdoc (SG) <[email address]>. All responses have
to be sent to this email address.
Envoyé par ve_sg.accessdoc (SG) <[email address]>. Toutes les
réponses doivent être effectuées à cette adresse électronique.

Dear Ms Friel,

 

I refer to your e-mail of 22 June 2018, by which you submit a confirmatory
application in accordance with Article 7(2) of Regulation (EC) No
1049/2001 regarding public access to European Parliament, Council and
Commission documents (‘Regulation 1049/2001’).

 

Your confirmatory application is currently being handled. Unfortunately,
due to ongoing consultations, we are not in a position to reply to your
confirmatory request within the prescribed time limit that expires on 16
July 2018. Consequently, we have to extend this period by another 15
working days in accordance with Article 8(2) of Regulation 1049/2001. The
new deadline expires on 6 August 2018.

 

Yours sincerely,

 

 

Martine Fouwels

Deputy Head of Unit

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European Commission

Secretariat General

Unit B4 (Transparency)

 

 

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Generaldirektion Maritime Angelegenheiten und Fischerei

12 Attachments

 
 
 
 
 
Dear Madam,
Please find attached a copy of the confirmatory decision taken on your
request for access to documents registered under Gestdem number 2018/2076,
adopted on 20/07/2018 in the above-mentioned case.
Please note that the Secretariat-General of the European Commission will
proceed with the formal notification of the decision in the coming days.
This copy is solely sent for your information and is not the formal
notification of the confirmatory decision.
 
Yours faithfully,
 
 
ACCESS TO DOCUMENTS TEAM (GD)
 
European Commission
Secretariat-General
SG B.4 – Transparency
[1][email address]
 
 
 
 

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