DG MOVE Guidance for the Aviation Industry and EASA on Additional Restrictions for Pilots with Russian Nationality

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Dear Mobility and Transport,

On February 28, 2022, EU Council adopted changes to EU Regulation 833/2014 (hereinafter shall be referred to as "Regulation") implementing a flight ban for Russian-controlled aircraft. Being aimed at the Russian political and business elite it banned unrelated individuals who are:
- student pilots, unable to proceed with their flight training to get a license or pursue/maintain the career; or
- flight instructors or other commercially rated pilots, losing jobs and business, being unable to fly in the EU (not in Russia) as a part of their job or self-employment; or
- non-commercial (private/recreational/sport) pilots, unable to use small aircraft as a hobby, for training, or for personal transportation;
and
- not subject to any individual restrictions (are not designated persons under Council Regulation No 269/2014); and
- not affiliated with Russian business or political elites in any way; and
- residing in the EU Member State permanently and lawfully and paying local taxes for many years; and
- are dual (EU and Russian) citizens.

As if banning unrelated individuals from flying was not enough under this Regulation, EU Aviation Safety Agency (EASA) has published a FAQ that contains several extra restrictions of arguably interpretative nature not visibly following the Regulation in any way. There are a few of them:

- https://www.easa.europa.eu/faq/136177
This statement claims that a pilot with an EU nationality cannot fly a Russian-controlled aircraft anywhere in the world, not just in the EU. Indeed, according to Article 13(c) of the Regulation, an EU national has to comply with sanctions worldwide. However, the wording of Article 3d(1) explicitly reduces the scope of the flight ban to the territory of the EU only. Therefore, this statement is invalid.

- https://www.easa.europa.eu/faq/136297
- https://www.easa.europa.eu/faq/136298
- https://www.easa.europa.eu/faq/136180
These 3 statements ban the issuance of personnel licenses, medical certificates, or providing theoretical examinations to current and future private pilots.
It is not clear what is the legal basis for this. Article 3d of the Regulation is not applicable here as it concerns flying alone.
Article 3c(4a) is equally irrelevant here as "any natural or legal person, entity or body in Russia" as formulated in that Article, clearly applies to the residents of / companies registered in Russia only. Clearly, it is irrelevant to the pilots concerned in this request as they live in the EU. The wording "<...> or for use in Russia" within this Article could have lead to misinterpretation, but according to the official explanation of the EU (question 23, published here: https://ec.europa.eu/info/sites/default/... ) this wording applies to "the sale/supply/transfer/export of goods/services which would be used in Russia, including operations between two points in Russia" only. Clearly, it is irrelevant to the pilots concerned in this request as they do not fly within Russia.

Additionally, EASA FAQ fails to mention the derogation mechanism defined by Article 3d(3), which clearly defines a possibility for authorization (by way of derogation) for flights for ANY purpose consistent with the objectives of the Regulation (NOT JUST humanitarian flights).

Although this FAQ is not legally binding, the national aviation authorities tend to use it as their sole guidance instead of interpreting the Regulation themselves. This promotes unlawful denial of service, over-compliance, and arbitrary enforcement.

In correspondence, EASA claimed that they are not in a position to alter any portion of the FAQ as it was written in consultation with the services of the European Commission, specifically DG MOVE, which assumes that DG MOVE is fully responsible for these excessive restrictions. That is why this request is addressed to DG MOVE.

Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting documents (including but not limited to: copies of any correspondence, written communications, operational and administrative conclusions, briefings, opinions, presentations and notes of telephone conversations or meetings) exchanged between the European Commission and any other parties (including, but not limited to EASA), that:
- contain and/or could be understood or interpreted as direct, indirect, formal, or informal guidance to EASA or national aviation authorities to implement and enforce the additional restrictions listed above as well as the contents of this guidance; and
- could confirm that each and every one of these additional restrictions originates solely from the European Commission and reflects their official position.

Please note that an email containing a similar request has been sent to DG MOVE on August 18, 2022 at 06:20 CEST to the e-mail: [email address] . Follow-ups were repeatedly sent on September 5 and September 22. These requests were never confirmed to be received or replied to.

Yours faithfully,

Boris Samoylenko

MOVE-ACCES-DOCUMENTS@ec.europa.eu,

Dear Sir or Madam,

We are writing to you concerning your request for access to documents sent
on 19/10/2022 and registered on 20/10/2022 under case number 2022/5971.

Since you have not indicated your postal address, we are not able to start
handling your request. The 15 working days to reply to your request will
start running only when you send us your postal address.

You can send your postal address by replying to this e-mail. If we do not
receive your reply we may close this case.

Please note that you can submit a request for access to Commission
documents via the portal [1]'Request a Commission document', which does
not require you to indicate your postal address.

Why do we need your personal postal address?

Since 1 April 2014, the submission of a postal address became a mandatory
feature when submitting an application for access to Commission documents
via an e-mail. We would like to explain why we need your postal address in
order to register and handle your application for access to documents when
submitted via e-mail:

• Firstly, to obtain legal certainty as regards the date you received
the European Commission reply to your application for public access to
documents. Article 297 of the Treaty on the Functioning of the
European Union (TFEU) states that 'decisions which specify to whom
they are addressed, shall be notified to those to whom they are
addressed and shall take effect upon such notification.' In line with
this provision, if the Commission does not grant full access to the
requested documents, it notifies the reply to the applicant via
registered mail with acknowledgement of receipt or via delivery
service. This requires an indication of a valid postal address by the
applicant;
• Secondly, to apply correctly the [2]Data Protection Regulation (EU)
2018/1725. Knowing whether the applicant is an EU resident (or not) is
necessary for deciding which conditions shall apply for the
transmissions of personal data to applicants for access to documents.
These conditions are not the same for recipients established in the
Union and for recipients in third countries. As the vast majority of
the documents requested contain personal data, the Commission cannot
ensure the correct application of the data protection rules in the
absence of a postal address;
• Thirdly, to apply correctly [3]Regulation (EC) No 1049/2001. Article
4(1)(b) of that Regulation refers to the protection of the privacy and
integrity of the individual and has to be applied in line with the
Data Protection Regulation;
• Fourthly, to protect the interest of other citizens and safeguard the
principle of good administration. The Commission has to treat all
citizens equally by ensuring that the legal framework for public
access to documents is respected. For example, it has to verify
whether Article 6(3) of Regulation (EC) No 1049/2001 is being evaded
by introducing several requests under different identities. Indeed, in
its Ryanair judgment ([4]EU:T:2010:511), the General Court confirmed
that Article 6(3) of Regulation (EC) No 1049/2001 cannot be evaded by
splitting an application into several, seemingly separate, parts. In
addition, the Commission has to make sure that the legal framework is
respected and the right of access to documents is not abused by making
requests under an invented identity.

The considerations above show that the request for and the consequent
processing of the applicant's postal address is not only appropriate, but
also strictly necessary for the performance of a task carried out in the
public interest within the meaning of Article 5(1)(a) of Data Protection
Regulation, namely providing a smooth and effective access to documents.

Yours faithfully,

Directorate-General for Mobility and Transport - Access to Documents
European Commission

References

Visible links
1. https://www.ec.europa.eu/transparency/do...
2. https://eur-lex.europa.eu/legal-content/...
3. https://eur-lex.europa.eu/legal-content/...
4. https://eur-lex.europa.eu/legal-content/...

Please use the following postal address:

Boris Samoylenko
[ADDRESS REDACTED]
[ADDRESS REDACTED]
[ADDRESS REDACTED]

Mail Delivery System,

2 Adjuntos

This message was created automatically by mail delivery software.

A message that you sent could not be delivered to one or more of its
recipients. This is a permanent error. The following address(es) failed:

[email address]
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SMTP error from remote mail server after end of data:
550 5.7.1 Delivery not authorized. To contact the Commission, please send an email to:
[email address]

Dear Mobility and Transport,

Please confirm that postal address provided to you on October 20 is received in good order, and that response to this FOI request will be provided in due time, by November 10.

MOVE-ACCES-DOCUMENTS@ec.europa.eu, Movilidad y Transportes

1 Adjuntos

Dear Sir,

 

Thank you for your email.

 

We have not received any communication mentioning your postal address.
Therefore, we are not able to start handling your request.

 

We recall that the 15 working days to reply to your request will start
running only when you send us your postal address.

 

You can send your postal address by replying to this e-mail. If we do not
receive your reply we may close this case.

 

Please note that you can also submit a request for access to Commission
documents via the portal [1]'Request a Commission document', which does
not require you to indicate your postal address.

 

Finally, please also note that you have lodged your application via
a private third-party website, which has no link with any institution of
the European Union. Therefore, the European Commission cannot be held
accountable for any technical issues or problems linked to the use of this
system.

 

Best regards,

 

MOVE ACCES DOCUMENTS TEAM

 
[2]cid:image001.gif@01D7643D.DC7E5B10
European Commission
Directorate-General for Mobility and Transport

Unit MOVE A4

Legal Issues & Enforcement

▪ Postal address: Europese Commissie/Commission européenne, B-1049
Brussel/Bruxelles

▪ Office address: Rue de Mot 28, B-1040 Brussels

▪ Tel. +32 2 299 11 11

E-mail: [3][DG MOVE request email]

 

 

mostrar partes citadas

MOVE-ACCES-DOCUMENTS@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your request for access to documents
sent on 19/10/2022 and registered on 09/11/2022 under the case number
2022/5971.

We will handle your request within 15 working days as of the date of
registration. The time-limit expires on 30/11/2022. We will let you know
if we need to extend this time limit for additional 15 working days.

To find more information on how we process your personal data, please see
[1]the privacy statement.

Yours faithfully,

Directorate-General for Mobility and Transport - Access to Documents
European Commission

References

Visible links
1. https://ec.europa.eu/info/principles-and...

MOVE-ACCES-DOCUMENTS@ec.europa.eu, Movilidad y Transportes

1 Adjuntos

Dear Sir,

 

As a complement to our previous e-mail, please note the following.

 

You have lodged your application via a private third-party website, which
has no link with any institution of the European Union. Therefore, the
European Commission cannot be held accountable for any technical issues or
problems linked to the use of this system.

 

Please note that the private third party running the AsktheEU.org website
is responsible and accountable for the processing of your personal data
via that website, and not the Commission. For further information on your
rights, please refer to the third party’s privacy policy.

 

We understand that the third party running the AsktheEU.org website
usually publishes the content of applicants’ correspondence with the
Commission on that website. This includes the personal data that you may
have communicated to the Commission (e.g. your private postal address).

 

Similarly, the third party publishes on that website any reply that the
Commission will send to the email address of the applicants generated by
the AsktheEU.org website.

 

If you do not wish that your correspondence with the Commission is
published on a private third-party website such as AsktheEU.org, you can
provide us with an alternative, private e-mail address for further
correspondence. In that case, the Commission will send all future
electronic correspondence addressed to you only to that private address,
and it will use only that private address to reply to your request. You
should still remain responsible to inform the private third-party website
about this change of how you wish to communicate with, and receive a reply
from, the Commission.

 

For information on how we process your personal data visit our page
[1]Privacy statement – access to documents.

 

Yours faithfully,

 

MOVE ACCES DOCUMENTS TEAM

 
[2]cid:image001.gif@01D7643D.DC7E5B10
European Commission
Directorate-General for Mobility and Transport

Unit MOVE A4

Legal Issues & Enforcement

▪ Postal address: Europese Commissie/Commission européenne, B-1049
Brussel/Bruxelles

▪ Office address: Rue de Mot 28, B-1040 Brussels

▪ Tel. +32 2 299 11 11

E-mail: [3][DG MOVE request email]

 

 

 

From: [DG MOVE request email]
<[email address]>
Sent: Wednesday, November 9, 2022 1:52 PM
To: [FOI #12027 email]
Subject: Case 2022/5971 - Acknowledgement of receipt

 

Dear Sir or Madam,

We hereby acknowledge the receipt of your request for access to documents
sent on 19/10/2022 and registered on 09/11/2022 under the case number
2022/5971.

We will handle your request within 15 working days as of the date of
registration. The time-limit expires on 30/11/2022. We will let you know
if we need to extend this time limit for additional 15 working days.

To find more information on how we process your personal data, please see
[4]the privacy statement.

Yours faithfully,

Directorate-General for Mobility and Transport - Access to Documents
European Commission

References

Visible links
1. https://ec.europa.eu/info/principles-and...
3. mailto:[DG MOVE request email]
4. https://ec.europa.eu/info/principles-and...

1 Adjuntos

[Note from AsktheEU.org admin: The European Commission replied to this
request on 29 November 2022. The reply was edited to redact the private
address of the requester]

 

Hello,

Please find attached a message concerning your requests for access to
Commission documents registered under the above case numbers 2022/5971 and
2022/5972.

Kind regards,

 

Dear Mobility and Transport,

Please pass this on to the person who reviews confirmatory applications.

I appreciate the time taken by the Commission to review access to document requests EASE(2022)5971 and EASE(2022)5972. In the response dated 29/11/2022, the Commission articulated its choice to withhold information asked in those requests by claiming an impressive number of exceptions.

I am not satisfied with this decision and, thus, filing this confirmatory application.

Taking into account the history of all prior communication attempts with the Commission and other relevant EU institutions on the matter, I recognize a remarkable interest of the these institutions to withhold any information by all means possible. This, however, in no way improves the situations for the EU pilots who are being restricted in an unmotivated and discriminative manner, contrary to the principles of justice, proportionality, non-discrimination, and presumption of innocence, which must be respected in the EU. It renders aforementioned access to document requests as well as this confirmatory application necessary and highly relevant.

Firstly, you claimed an exception under Article 4(2), second indent of Regulation (EC) No 1049/200.

You stated that:
“The question of the interpretation of Council Regulation (EU) No 833/20148 (as amended,
inter alia, by Council Regulation (EU) 2022/3349) with respect to the application of certain
restrictions to student pilots and General Aviation pilots holding Russian and EU citizenship
is currently pending before the General Court as Case T-233/22
<…>
The Commission submitted a request to intervene in those legal proceedings.
<…>
The disclosure of these documents, related to the application of Council Regulation (EU) No 833/2014 as amended by Council Regulation (EU) 2022/334, could undermine the integrity and purpose of those proceedings, which is to ensure an independent examination
of the matter by the EU courts, and contend with the principles of sound administration of justice.
<…>
Disclosure of the documents setting out a position defended by an EU institution, which relates to pending court proceedings, would have the effect of exposing the judicial activities to external pressure, albeit only in the perception of the public, and would disturb the serenity of the proceedings.”

Your response did not include any significant evidence to support these statements. Without this evidence, the statements remain hypothetical. It is important to note that stating facts without providing supporting evidence is not sufficient to establish their validity.

Nevertheless, I would like to thank you for informing me about legal proceeding T-233/22.
I find it commendable to see that pilots take initiative to defend their rights and launch court proceedings on this highly questionable matter. It facilitates justice, the rule of law and democratic principles in Europe. I also recognize the interest of the Commission to intervene in this process.

But it must be noted that this legal proceeding is lodged against the European Council, not the Commission. Your statements indicate that the Commission's involvement was optional. You have not provided any evidence to suggest that the Commission's participation was necessary or inevitable.

I am confident that the Commission thoroughly evaluates any potential restrictions and limitations arising from certain actions, including limitations on the ability to disclose information under the rights of access to documents as outlined in Regulation 1049/2001 due to intervention in relevant legal proceedings.

Given that the Commission's intervention in case T-233/22 was completely voluntary and optional, I do not find the justification for withholding the information under Article 4(2) of Regulation (EC) No 1049/2001 sufficient. After all, the Commission could have easily avoided any of these restrictions by not getting involved in this optional legal proceeding.

In light of the lack of evidence presented, and the information discussed above, I am not convinced that the claim of exception under Article 4(2), second indent of Regulation (EC) No 1049/2001 by the Commission is sufficiently justified. As a part of review of this confirmatory application, I request that this claim be either nullified or that sufficient evidence be provided to support it.

Secondly, you claimed an exception under Article 4(1)(a), third indent of Regulation (EC) No 1049/2001. You stated that:

“Rendering public information contained in other documents about the way in which the Commission and the Member States work to ensure a consistent application of EU legislation, an internal EU discussion, is likely to affect, in a foreseeable and non-hypothetical way, the EU’s position in its external relations with third countries, in particular with the Russian Federation in the case at hand, which are considered politically sensitive. Such disclosure could indeed reveal internal views that may not correspond to the positions ultimately laid down in the publicly available guidance, which would in turn affect the international relations between the EU and third countries affected by the legal framework in question. It is to be noted that the EU institutions and Member States must be free to exchange views free from external pressure.”

Your response did not include any further evidence to support these statements. Without this evidence, the statements remain hypothetical. It is important to note that stating facts without providing supporting evidence is not sufficient to establish their validity.

Additionally, I am deeply concerned that exercising the EU citizen’s right to access documents is being classified as a factor of / leading to “external pressure”, which the EU institutions and Member States must be free of. This compromises the purpose of this right as well as the whole idea of transparency with the EU. After all, any interest of a kind can be then conveniently classified as “external pressure” and, thus, be dismissed.

I am further alerted by the fact that the Commission appears to prioritize maintaining relations with a foreign government committing crimes on the territory of another sovereign state, over upholding transparency in the EU (e.g. ensuring the right of the EU citizen to access documents). While I do appreciate the complex nature of international relations, this does not diminish the importance of upholding fundamental principles and values.

In light of the lack of evidence presented, and the information discussed above, I am not convinced that the claim of exception under Article 4(1)(a), third indent of Regulation (EC) No 1049/2001 by the Commission is sufficiently justified. As a part of review of this confirmatory application, I request that this claim be either nullified or that sufficient evidence be provided to support it.

Thirdly, you claimed an exception under Article 4(3) of Regulation (EC) No 1049/2001. You stated that:

“By disclosing the documents requested, which represent EU-internal exchanges, the services of the Commission would expose preliminary assessments to undue external pressure and disseminate preliminary conclusions that may not represent the final positions that were or are to be included on this guidance. This may lead to premature conclusions and serious interference with the institution’s decision-making process concerning the interpretation of Council Regulation (EU) No 833/2014 (as amended). It is to be noted that the Commission services must be free to explore all possible options in preparation of a decision free from external pressure, in order to avoid the risk that the disclosure would lead to future self-censorship.”

Your response did not include any further evidence to support these statements. Without this evidence, the statements remain hypothetical. It is important to note that stating facts without providing supporting evidence is not sufficient to establish their validity.

Additionally, I am deeply concerned that exercising the EU citizen’s right to access documents is being classified as a factor of / leading to “external pressure”, which the EU institutions and Member States must be free of. This compromises the purpose of this right as well as the whole idea of transparency with the EU. After all, any interest of a kind can be then conveniently classified as “external pressure” and, thus, be dismissed.

In light of the lack of evidence presented, and the information discussed above, I am not convinced that the claim of exception under Article 4(3) of Regulation (EC) No 1049/2001 by the Commission is sufficiently justified. As a part of review of this confirmatory application, I request that this claim be either nullified or that sufficient evidence be provided to support it.

Finally, you stated that:

“We have considered whether partial access could be granted to the documents requested, pursuant to Article 4(6) of Regulation (EC) No 1049/2001. However, given the nature and structure of the documents, no meaningful partial access would be possible without undermining the protection of the public interests described above. We have therefore concluded that these documents are entirely covered by the exceptions explained above.

The exceptions laid down in Article 4(2) and (3) of Regulation (EC) No 1049/2001 apply unless there is an overriding public interest in disclosure of the documents. We have examined whether there could be an overriding public interest in disclosure. However, we were not able to identify any public interest that would override, in this case, the need to safeguard the proper administration of justice by the European courts and preserve the independence and objectivity of the European judicial body, or the need to preserve the decision-making process of the Commission.”

Your response did not include any further evidence to support these statements. Without this evidence, the statements remain hypothetical. It is important to note that stating facts without providing supporting evidence is not sufficient to establish their validity.

In fact, there are a number of evidences suggesting the very opposite. Namely, that the public interest in disclosing the information and/or resolving the issue associated with it is very much present. This includes, but not limited to:
- a legal proceeding T-233/22 you kindly referenced;
multiple online discussion on social media and professional communities, including official EASA General Aviation Community:
https://www.easa.europa.eu/community/pos...
- a public website, supported by a movement of the affected EU pilots, that extensively describes the negative impacts of the flight ban on them:
https://freeskies.eu
- numerous complaints raised with the European Ombudsman against EASA and the Commission;
- numerous access to documents requests to EASA, the Commission and national competent authorities of the EU Member States;
- numerous legal proceedings launched against competent authorities in the various EU Member States.

There is another significant factor that must be taken into account. As mentioned at the beginning of this application, the level of cooperation from EU institutions with affected individuals has been remarkably low. The combination of this and other factors, such as: the publication of overly restrictive guidance by EASA not visibly following for the Regulation (EC) No 833/2014, the arbitrary application of the ban based solely on nationality, and the administrative disregard and blame-shifting between institutions, all contribute to creating an extremely hostile environment for the individuals impacted. It promotes the EU-wide impression that the misuse of the law towards them and treating them as “second-class” of people is nominally prohibited, but in practice allowed and even encouraged on the territory of the EU.

It shall be understood that regardless of the legal justification set forth to excuse this, it will always be perceived as unfair, discriminatory and originating from the EU institutions by these individuals. Therefore, it is reasonable and predictable that the absolute most of affected individuals will not raise this issue with the authorities out of fear and distrust, regardless of the extent of damage suffered. For the sake of context, it shall be reminded that we are not discussing (war) criminals in this application, but instead, law-abiding citizens of the EU, who are being restricted solely based on their second nationality. More details are given in the access to documents requests at issue.

Therefore, the level of public interest, which appears insufficient to the Commission, does not necessarily correspond with the actual level of public interest.

Notwithstanding the above, I appreciate your emphasis on the importance of bringing more public interest to the issue.

In summary, I do not believe that any of the exceptions claimed by the Commission to deny access to document requests EASE(2022)5971 and EASE(2022)5972 are sufficiently substantiated. I therefore conclude that these requests were denied without due justification. Pursuant to Article 7(2) of Regulation (EC) No 1049/2001, I request the Commission to either review its position and provide the documents requests in full; or provide more substantial documentary evidences to the exceptions claimed otherwise.

A full history of my request and all correspondence is available on the Internet at this address: http://www.asktheeu.org/en/request/dg_mo...

Yours faithfully,
Boris Samoylenko

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your confirmatory request for case
2022/5971, sent on 19/12/2022 and registered on 19/12/2022.

We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 18/01/2023. We will let
you know if we need to extend this time limit for additional 15 working
days.

Yours faithfully,

Secretariat-General - Access to Documents
European Commission

sg-acc-doc@ec.europa.eu,

Hello,

We are writing concerning your confirmatory requests for access to
Commission documents for cases 2022/5971 and 2022/5972 registered on
19/12/2022.

We are currently working on your confirmatory requests. However, we have
not yet been able to gather all the elements necessary to carry out a full
analysis of your request. We will not be able to send you the reply within
the prescribed time limit expiring on 18/01/2023.

Therefore, in line with Article 8(2) of [1]Regulation (EC) No 1049/2001 we
need to extend this time limit by 15 additional working days. The new time
limit expires on 08/02/2023.

We apologise for any inconvenience this may cause.

Kind regards,

SG ACCESS TO DOCUMENTS TEAM

References

Visible links
1. https://eur-lex.europa.eu/legal-content/...

sg-acc-doc@ec.europa.eu,

Hello,

We are writing concerning your confirmatory requests for access to
Commission documents for cases 2022/5971 and 2022/5972 registered on
19/12/2022.

We are currently working on your confirmatory requests. However, we have
not yet been able to gather all the elements necessary to carry out a full
analysis of your request. We will not be able to send you the reply within
the prescribed time limit expiring on 18/01/2023.

Therefore, in line with Article 8(2) of [1]Regulation (EC) No 1049/2001 we
need to extend this time limit by 15 additional working days. The new time
limit expires on 08/02/2023.

We apologise for any inconvenience this may cause.

Kind regards,

SG ACCESS TO DOCUMENTS TEAM

References

Visible links
1. https://eur-lex.europa.eu/legal-content/...