Discussions on RRF plan Netherlands (2)

Peter a fait une demande de Accès à l'information à Secrétariat général de la Commission européenne

Automatic anti-spam measures are in place for this older request. Please let us know if a further response is expected or if you are having trouble responding.

La demande est partiellement réussie.

Dear Madam, Sir,

Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, and Regulation 1367/2006, I am requesting documents which contain the following information:

All documents held by the Commission on the preparation of a recovery and resilience plan of the Netherlands as part of the European Recovery and Resilience Facility (RRF), from 20 November 2021 until 28 January 2022.

This includes exchanges via e-mail, including attachments, letter, text messages, phone call notes, or meeting notes, between the Commission and the Dutch national government about possible investments and potential projects.

Since the information might at least partly concern also "activities affecting or likely to affect" the "state of the elements of the environment", I believe Regulation 1367/2006 applies.

Should you encounter any difficulties in interpreting or processing my request, I am ready to discuss ways to clarify or amend it to keep the effort required on your part to the necessary minimum.

Please send me an acknowledgement of receipt for this request, as foreseen by Article 7 (1) of Regulation 1049/2001.

If the European Commission is going to argue that disclosure of some or all of the documents would be prevented by the 4th indent of Article 4(1)(a), as it did in the case of reference number GESTDEM 2021/7168, please provide a substantial and non-hypothetical argument why this supposedly is the case.

If the European Commission is going to argue that disclosure of some or all of the documents would be prevented by the first subparagraph of Article 4(3)” , as it did in the case of reference number GESTDEM 2021/7168, please consider that this cannot be properly used because of the following reasons:

- Since there is currently no Dutch Recovery and Resilience Plan submitted by the Netherlands, the decision-making process in relation to the Dutch Recovery and Resilience Plan has not started in the European Commission. Article 19 of Regulation (EU) 2021/241 (of the European Parliament and of the Council of 12 February 2021 establishing the Recovery and Resilience Facility) states that the European Commission "shall assess the recovery and resilience plan". not any correspondence between the Commission and a member state on the preparation of the Recovery and Resilience Plan.

- The documents which constitute "correspondence between the Commission and the Dutch Government" can in no way qualify as internal considerations. By definition, correspondence occurs between two parties. If the Commission is able to share information with the Dutch government without undermining the Commission's decision-making process, disclosure of that information to a wider public equally cannot undermine the Commission's decision-making process.

- Even if the Commission maintains that Article 4(3) applies, please note that you should make an assessment of any overriding public interest. When considering that public interest, please also take into account what the Commission president Von der Leyen has written to the European Ombudsman in a 15 October 2021 letter: ‘You can rest assured of our commitment to ensuring the transparency of the Recovery and Resilience Facility as we share your assessment that full ownership by EU citizens is a prerequisite to ensure its success.’

Sincerely,
Peter Teffer

postal address:
Peter Teffer
Ekko Voorkamer
Bemuurde Weerd WZ 3
3513 BH Utrecht
The Netherlands

Sg-Acc-Doc@ec.europa.eu, Secrétariat général de la Commission européenne

Your message has been received by the Transparency Unit of the
Secretariat-General of the European Commission.
Requests for public access to documents are treated on the basis of
[1]Regulation (EC) No 1049/2001 of 30 May 2001 regarding public access to
European Parliament, Council and Commission documents.
The Secretariat-General will reply to your request within 15 working days
upon registration of your request and will duly inform you of the
registration of the request (or of any additional information to be
provided in view of its registration and/or treatment).
 
 
L’unité «Transparence» du secrétariat général de la Commission européenne
a bien reçu votre message.
Les demandes d’accès du public aux documents sont traitées sur la base du
[2]règlement (CE) n° 1049/2001 du 30 mai 2001 relatif à l’accès du public
aux documents du Parlement européen, du Conseil et de la Commission.
Le secrétariat général répondra à votre demande dans un délai de 15 jours
ouvrables à compter de la date d’enregistrement de votre demande, et vous
informera de cet enregistrement (ou vous indiquera toute information
supplémentaire à fournir en vue de l'enregistrement et/ou du traitement de
votre demande).
 
 
Ihre Nachricht ist beim Referat „Transparenz“ des Generalsekretariats der
Europäischen Kommission eingegangen.
Anträge auf Zugang zu Dokumenten werden auf der Grundlage der
[3]Verordnung (EG) Nr. 1049/2001 vom 30. Mai 2001 über den Zugang der
Öffentlichkeit zu Dokumenten des Europäischen Parlaments, des Rates und
der Kommission behandelt.
Das Generalsekretariat beantwortet Ihre Anfrage innerhalb von
15 Arbeitstagen nach deren Registrierung und wird Sie über die
Registrierung Ihres Antrags (oder die Notwendigkeit weiterer Informationen
im Hinblick auf dessen Registrierung und/oder Bearbeitung) unterrichten.
 
 

References

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1. https://eur-lex.europa.eu/legal-content/...
2. https://eur-lex.europa.eu/legal-content/...
3. https://eur-lex.europa.eu/legal-content/...

SG ACCES DOCUMENTS, Secrétariat général de la Commission européenne

Dear Sir,

Thank you for your e-mail of 28/01/2022. We hereby acknowledge receipt of
your application for access to documents, which was registered on
31/01/2022 under reference number GESTDEM 2022/654.

In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents, your application
will be handled within 15 working days.

The time limit will expire on 21/02/2022. In case this time limit needs to
be extended, you will be informed in due course.

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
Privacy statement – access to documents.

Yours faithfully,

Access to documents team (cr)
SG.C.1
Transparency

Afficher les sections citées

SG RECOVER ATD, Secrétariat général de la Commission européenne

1 Attachment

Link: [1]File-List
Link: [2]Edit-Time-Data
Link: [3]themeData
Link: [4]colorSchemeMapping

Dear Sir,

Subject:       Your application for access to documents – GESTDEM
2022/0654

We refer to your e-mail of 28 January 2022 in which you made a request for
access to documents, registered on  31/01/2022 under the above mentioned
reference number.

Your application is currently being handled. However, we were not in a
position to complete the handling of your application within the time
limit of 15 working days, which expires on 21 February 2022.

An extended time limit is needed as (part of) the documents requested
originate from third parties, which have been consulted.

Therefore, we have to extend the time limit with 15 working days in
accordance with Article 7(3) of Regulation (EC) No 1049/2001 regarding
public access to documents. The new time limit expires on 14 March 2022.

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

Yours faithfully,

Yours faithfull

The SG RECOVER ATD TEAM

 

[5]cid:image001.png@01D6771A.7B64B1A0
European Commission

 

 

References

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3. file:///tmp/~~themedata~~
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SG RECOVER ATD, Secrétariat général de la Commission européenne

5 Attachments

Link: [1]File-List
Link: [2]Edit-Time-Data
Link: [3]themeData
Link: [4]colorSchemeMapping

[5]Your application for access to documents – GESTDEM 2022/0654 -
Ares(2022)1417002  (Please use this link only if you are an Ares user –
Svp, utilisez ce lien exclusivement si vous êtes un(e) utilisateur d’Ares)

Dear Sir,

 

Please find attached a reply to your request for access to documents of 28
January 2022, registered on 31 January 2022 under the above mentioned
reference number.

 

Please acknowledge receipt by replying to this e-mail and confirming that
you could open the transmitted 7z file.

 

Kind regards,

 

SG RECOVER ACCESS TO DOCUMENTS TEAM

[6]cid:image001.png@01D31AA3.9A26C5A0
European Commission

 

References

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1. file:///tmp/cid:filelist.xml@01D8299B.1BB1DAA0
2. file:///tmp/cid:editdata.mso
3. file:///tmp/~~themedata~~
4. file:///tmp/~~colorschememapping~~
5. https://webgate.ec.testa.eu/Ares/documen...

Dear Madam, Sir

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

I am filing the following confirmatory application with regards to my access to documents request, registered on 31/01/2022 under reference number GESTDEM 2022/654.

Before I go into the reasons of my confirmatory application, allow me to request that you treat the following remarks as a formal complaint.

Aside from the reasoning in the reply, which is based on the Commission's legal interpretation of Regulation 1049/2001 and about which one can have a debate, I am deeply offended by the SG Recover Access to Documents team's reply.

GESTDEM 2022/654 is a similar request as GESTDEM 2021/7168, registered on 19 November 2021, but focusing on a later time period. Having had what I experienced as an unsatisfactory reply to GESTDEM 2021/7168 (for which a confirmatory application is still pending), I added some requests in my application.

I specifically asked that "[if] the European Commission is going to argue that disclosure of some or all of the documents would be prevented by the 4th indent of Article 4(1)(a), as it did in the case of reference number GESTDEM 2021/7168, please provide a substantial and non-hypothetical argument why this supposedly is the case." The Commission did not provide any substantial and non-hypothetical argument.

I specifically asked that "[if] the European Commission is going to argue that disclosure of some or all of the documents would be prevented by the first subparagraph of Article 4(3)” , as it did in the case of reference number GESTDEM 2021/7168, please consider that this cannot be properly used because of the following reasons:

- Since there is currently no Dutch Recovery and Resilience Plan submitted by the Netherlands, the decision-making process in relation to the Dutch Recovery and Resilience Plan has not started in the European Commission. Article 19 of Regulation (EU) 2021/241 (of the European Parliament and of the Council of 12 February 2021 establishing the Recovery and Resilience Facility) states that the European Commission "shall assess the recovery and resilience plan". not any correspondence between the Commission and a member state on the preparation of the Recovery and Resilience Plan.

- The documents which constitute "correspondence between the Commission and the Dutch Government" can in no way qualify as internal considerations. By definition, correspondence occurs between two parties. If the Commission is able to share information with the Dutch government without undermining the Commission's decision-making process, disclosure of that information to a wider public equally cannot undermine the Commission's decision-making process."

The Commission's reply did not address the issues mentioned above.

I specifically requested that even "if the Commission maintains that Article 4(3) applies, please note that you should make an assessment of any overriding public interest". The Commission did not make an assessment of any overriding public interest.

Instead, the Commission copy-pasted the exact same vague and unconvincing paragraph from its reply to GESTDEM 2021/7168.

I hope you realise that this is an insult to my intelligence, and shows contempt towards me as an EU citizen. After this experience, Commission president Von der Leyen's comments to the European Ombudsman in a 15 October 2021 letter - ‘You can rest assured of our commitment to ensuring the transparency of the Recovery and Resilience Facility as we share your assessment that full ownership by EU citizens is a prerequisite to ensure its success.’ - ring hollow and insincere.

Apart from a renewed assessment as part of my confirmatory application, I expect a formal apology from the Commission about how my request was treated.

My reasons for why a confirmatory application are needed, have been partly cited above. Additionally, please consider the following remarks (since the Commission copy-pasted the same unconvincing answer, I feel entitled to do the same, so what follows is a copy of the arguments I gave in the confirmatory application about GESTDEM 2021/7168).

The Commission argued disclosure of those documents was “prevented by exceptions to the right of access laid down in the 4th indent of Article 4(1)(a) and in the first subparagraph of Article 4(3)” of Regulation 1049/2001.

The Commission is thus arguing that disclosing these documents would undermine:
– the financial, monetary or economic policy of the Community or a Member State;
– the institution's decision-making process

However, the Commission does not provide any arguments why the financial, monetary or economic policy of the Community or a Member State would be undermined by disclosure of the documents.

Article 7 of the Regulation states that the institution “shall either grant access [..] or, in a written reply, state the reasons for the total or partial refusal”. Simply referring to “the 4th indent of Article 4(1)(a)” cannot be sufficient to fulfill the requirement of stating the reasons of refusal. This argument should thus be dismissed.

The argument provided to substantiate the other exception, the perceived undermining of the institution's decision-making process, is as follows: “The documents included in Annex 1 are mostly correspondence between the Commission and the Dutch Government on the preparation of the Dutch Recovery and Resilience Plan. They also include minutes that are internal documents of the Commission. The disclosure of the internal considerations laid down in the requested documents would undermine the independence and objectivity of the Commission’s decision-making process on the Dutch Recovery and Resilience Plan, which has not been completed.”

There are no other arguments the Commission provides.

The above-cited argument is flawed on several levels.

The most obvious fallacy is that there is currently no Dutch Recovery and Resilience Plan. As of 12 January 2022, the Netherlands has not submitted one. That means that as of this date, the decision-making process in relation to the Dutch Recovery and Resilience Plan has not started in the European Commission.

Article 19 of Regulation (EU) 2021/241 (of the European Parliament and of the Council of 12 February 2021 establishing the Recovery and Resilience Facility) states that the European Commission "shall assess the recovery and resilience plan". It does not state that the Commission shall assess correspondence between the Commission and a member state on the preparation of the Recovery and Resilience Plan. Such correspondence, as well as any minutes by the Commission, should be out of the scope of the Commission’s assessment of the Recovery and Resilience Plan. These documents cannot be refused based on the argument that they can affect the Commission’s decision-making process on the Dutch Recovery and Resilience Plan.

Additionally, the Commission argued specifically that disclosure of “the internal considerations laid down in the requested documents would undermine the independence and objectivity of the Commission’s decision-making process on the Dutch Recovery and Resilience Plan”.

The documents which constitute "correspondence between the Commission and the Dutch Government" can in no way qualify as internal considerations. By definition, correspondence occurs between two parties. If the Commission is able to share information with the Dutch government without undermining the Commission's decision-making process, disclosure of that information to a wider public equally cannot undermine the Commission's decision-making process.

I’m unconvinced that specifically “the independence and objectivity” of the Commission’s decision-making process could be affected by the decision to disclose the documents. The independence and objectivity of the decision-making processes in the European Commission should be guaranteed regardless of the release of whichever documents.

Article 17 (3) of the Treaty on European Union determines that:
"[..]The members of the Commission shall be chosen on the ground of their general competence and European commitment from persons whose independence is beyond doubt. In carrying out its responsibilities, the Commission shall be completely independent. Without prejudice to Article 18(2), the members of the Commission shall neither seek nor take instructions from any Government or other institution, body, office or entity. They shall refrain from any action incompatible with their duties or the performance of their tasks."

The independence and objectivity of Commission’s decision-making process is a function of many factors, but one factor which cannot influence the independence or objectivity of the Commission’s decision-making process, is whether specific documents are released or not.

Independence and objectivity are binary attributes of that decision-making process. The decision-making process is either independent, or it is not. It is objective or it is subjective.

But even if we view independence and objectivity on a scale, the argument lacks any logic. As a thought experiment, let’s assume that the independence and objectivity of the Commission’s decision-making process each can be determined by a number from 1 to 10, whereby 10 would mean the decision-making process is fully independent/objective.

How on Earth could the release of documents negatively affect the independence or objectivity of the decision-making process? Is the Commission seriously arguing that the mere existence of the documents in the outside world would reduce the score in this thought experiment?

It would truly be worrying if “the independence and objectivity” of a decision-making process in the Commission could be undermined by transparency.

Regardless of the above, since the documents listed in Annex 1 “also include minutes that are internal documents of the Commission”, this means there is also a category of documents that are not “minutes that are internal documents of the Commission”. Those documents cannot be refused based on the argument that “disclosure of the internal considerations laid down in the requested documents would undermine the independence and objectivity of the Commission’s decision-making process on the Dutch Recovery and Resilience Plan, which has not been completed”. Any document which is not produced by the Commission cannot in any way be part of internal considerations. The content of correspondence between the Commission and a member state cannot influence the Commission’s independence and/or objectivity.

Additionally, I would like to point out that my position about the decision-making process in relation to the Dutch Recovery and Resilience Plan not having been started, is reinforced by a letter from the Dutch minister of Finance, Mrs Sigrid Kaag. On 17 February, she answered questions from Dutch parliament members about the informal discussions held between the Commission and the Netherlands. The letter can be found here:
https://www.tweedekamer.nl/kamerstukken/...

In answers 11 and 13, Kaag confirms what I argued in my confirmatory application:

"Het is gebruikelijk dat Europese lidstaten conceptplannen informeel toetsen bij de Europese Commissie. De HVF-verordening is voor alle Europese lidstaten een nieuw proces, vandaar dat informeel en ambtelijk bij de experts van de Europese Commissie getoetst is of bepaalde zaken voldoen aan de eisen van de verordening. Er is hiermee geen officiële procedure omzeild. De officiële procedure met de Europese Commissie gaat van start op het moment dat wij het plan indienen bij de Commissie, cf. preambule lid 38 van de HVF-verordening."

and

"De gesprekken vormen echter geen onderdeel van het beoordelingsproces, maar worden ingezet ter voorziening van benodigde informatie ten aanzien van de HVF-verordening. De Commissie velt in deze gesprekken dan ook geen oordeel over de samenhang van het plan, maar geeft slechts toelichting bij de technische vereisten. Dit blijkt ook uit de openbaargemaakte stukken d.d. 1 november 2021."

The minister stated that the official procedure of the assessment of the RRF plan will only start "the moment we submit the plan", and the discussions held before that "are not part of the assessment process".

I would like to ask that in your assessment of my confirmatory application, you accept this letter from the Dutch finance minister as part of the relevant context.

Sincerely
Peter Teffer

Sg-Acc-Doc@ec.europa.eu, Secrétariat général de la Commission européenne

Your message has been received by the Transparency Unit of the
Secretariat-General of the European Commission.
Requests for public access to documents are treated on the basis of
[1]Regulation (EC) No 1049/2001 of 30 May 2001 regarding public access to
European Parliament, Council and Commission documents.
The Secretariat-General will reply to your request within 15 working days
upon registration of your request and will duly inform you of the
registration of the request (or of any additional information to be
provided in view of its registration and/or treatment).
 
 
L’unité «Transparence» du secrétariat général de la Commission européenne
a bien reçu votre message.
Les demandes d’accès du public aux documents sont traitées sur la base du
[2]règlement (CE) n° 1049/2001 du 30 mai 2001 relatif à l’accès du public
aux documents du Parlement européen, du Conseil et de la Commission.
Le secrétariat général répondra à votre demande dans un délai de 15 jours
ouvrables à compter de la date d’enregistrement de votre demande, et vous
informera de cet enregistrement (ou vous indiquera toute information
supplémentaire à fournir en vue de l'enregistrement et/ou du traitement de
votre demande).
 
 
Ihre Nachricht ist beim Referat „Transparenz“ des Generalsekretariats der
Europäischen Kommission eingegangen.
Anträge auf Zugang zu Dokumenten werden auf der Grundlage der
[3]Verordnung (EG) Nr. 1049/2001 vom 30. Mai 2001 über den Zugang der
Öffentlichkeit zu Dokumenten des Europäischen Parlaments, des Rates und
der Kommission behandelt.
Das Generalsekretariat beantwortet Ihre Anfrage innerhalb von
15 Arbeitstagen nach deren Registrierung und wird Sie über die
Registrierung Ihres Antrags (oder die Notwendigkeit weiterer Informationen
im Hinblick auf dessen Registrierung und/oder Bearbeitung) unterrichten.
 
 

References

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

SG ACCES DOCUMENTS, Secrétariat général de la Commission européenne

Dear Sir,

Thank you for your email dated 15/03/2022 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 SG
RECOVER in reply to your initial application GESTDEM 2022/654.

We hereby acknowledge receipt of your confirmatory application for access
to documents which was registered on 16/03/2022 (Ares(2022)1922357).

Your application will be handled within 15 working days (06/04/2022). 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 providing 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,

Access to documents team (cr)
SG.C.1
Transparency

Afficher les sections citées

SG ACCES DOCUMENTS, Secrétariat général de la Commission européenne

1 Attachment

Link: [1]File-List
Link: [2]Edit-Time-Data
Link: [3]themeData
Link: [4]colorSchemeMapping

[5]Your confirmatory application for access to documents under Regulation
(EC) No 1049/2001 - GESTDEM 2022/654 - 1st holding letter -
Ares(2022)2620850  (Please use this link only if you are an Ares user –
Svp, utilisez ce lien exclusivement si vous êtes un(e) utilisateur d’Ares)

Dear Mr Teffer,

 

I refer to your email of 15 March 2022, registered on 16 March 2022, 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 (EC) No
1049/2001"), registered under reference number above.

 

Your confirmatory application is currently being handled. Unfortunately,
we have not yet been able to gather all the elements needed to carry out a
full analysis of your request and to take a final decision.

Please note that the ongoing internal consultations are necessary in order
to carry out an assessment of the documents falling under the scope of
your request in light of their length, sensitivity and taking into account
that some originate from a third party.

 

Therefore, we are not in a position to reply to your confirmatory request
within the prescribed time limit which expires on 6 April 2022.
Consequently, we have to extend this period by another 15 working days in
accordance with Article 8(2) of Regulation (EC) No 1049/2001. The new
deadline expires on 2 May 2022. However, I can assure you that we are
doing our utmost to provide you with a final reply within the next 15
working days.

 

I regret this additional delay and sincerely apologise for any
inconvenience this may cause.

 

Yours sincerely,

 

 

 

Mariusz Daca, Ph.D.
Deputy Head of Unit

European Commission

Secretariat General

Unit C.1 (Transparency, Document Management and Access to Documents)

References

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5. https://webgate.ec.testa.eu/Ares/documen...

SG ACCES DOCUMENTS, Secrétariat général de la Commission européenne

1 Attachment

Link: [1]File-List
Link: [2]Edit-Time-Data
Link: [3]themeData
Link: [4]colorSchemeMapping

[5]Your confirmatory application for access to documents under Regulation
(EC) No 1049/2001 - GESTDEM 2022/0654 - 2nd holding letter -
Ares(2022)3372199  (Please use this link only if you are an Ares user –
Svp, utilisez ce lien exclusivement si vous êtes un(e) utilisateur d’Ares)

Dear Mr Teffer,

 

I refer to your email of 15 March 2022, registered on 16 March 2022, 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 (EC) No
1049/2001"), registered under reference number above.

 

I also refer to our holding reply of 6 April 2022, by which the time limit
for replying to your confirmatory application was extended by 15 working
days, pursuant to Article 8(2) of Regulation 1049/2001. This extended time
limit expires on 2 May 2022.

 

I regret to have to inform you that we are not able to respond within the
extended time-limit, as we have not yet finalised internal and external
consultations. Please note that the ongoing consultations are necessary in
order to carry out an assessment of the documents falling under the scope
of your request in light of their length, sensitivity and taking into
account that some originate from a third party. I can assure you that we
are doing our utmost to provide you with a final reply as soon as
possible.

 

I regret this additional delay and sincerely apologise for any
inconvenience this may cause.

 

Yours sincerely,

 

 

Mariusz Daca, Ph.D.
Deputy Head of Unit

European Commission

Secretariat General

Unit C.1 (Transparency, Document Management and Access to Documents)

References

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2. file:///tmp/cid:editdata.mso
3. file:///tmp/~~themedata~~
4. file:///tmp/~~colorschememapping~~
5. https://webgate.ec.testa.eu/Ares/documen...