The 31st-60th Commission replies to confirmatory applications issued in 2019

La demande a été rejetée par Secrétariat général de la Commission européenne.

Maarten Hillebrandt

Dear Secretariat General of the European Commission,

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

The 31st to the 60th final decisions by the European Commission in confirmatory application procedures under Regulation 1049/2001 issued in 2019. (An initial request for access to the first 30 documents of this category was already made on 26 April 2019.)

Explicitly excluded from my request are:

- Any personal data contained in these decision documents - which means that the Commission need not spend any time contacting third parties, and that I agree to the Commission preemptively suppressing the contents of any such sections.
- Any related documents - I am exclusively interested in the documents issuing decisions and the legal justification contained therein.

My postal address is:
Dr. Maarten Hillebrandt
University of Helsinki
Faculty of Law
Eric Castrén Institute
Yliopistonkatu 3
00101 Helsinki
Finland

Although I kindly request you to send all relevant documents also in digital form to my email address: [email address].

The purpose for my request is academic research.

In case any of the documents included in my request were already proactively published, I kindly request you to refer me to the precise URL at which they can be located.

Yours faithfully,
Maarten Hillebrandt

ve_sg.accessdoc (SG), Secrétariat général de la Commission européenne

[1]Ares(2020)2545210 - RE: access to documents request - The 31st-60th
Commission replies to confirmatory applications issued in 2019 --- Ref.
Gestdem 2020/2853

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

Dear Sir,

Thank you for your e-mail of 13/05/2020. We hereby acknowledge receipt of
your application for access to documents, which was registered on
14/05/2020 under reference number GESTDEM 2020/2853.

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 09/06/2020. 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 (rc)

Afficher les sections citées

Secrétariat général de la Commission européenne

2 Attachments

Dear Sir,

 

Please find attached an advance copy of a letter concerning your initial
requests for access to documents registered under the number GESTDEM
2020/2451 & 2020/2853.

 

Yours faithfully,

 

Access to documents team (rc)
SG.C.1
Transparency
[1]cid:image004.gif@01D4F9CD.7B22B0F0

 

References

Visible links

Maarten Hillebrandt

Dear Ms Olivan Aviles,

Thank you for your letter of 18 February, with a proposal for a fair solution in my access request of 13 May, and related remarks concerning a separate access request of 26 April.

As you correctly remark, both requests refer to the same type of document, namely confirmatory application decisions of the Commission issued in 2019, excluding annexes or references to personal data-sensitive information .

My application of 26 April ["the first request"] originally concerned all decisions issued in the months of January and February 2019. However, upon the Commission's proposal and with mutual agreement, it was decided to limit this request to the first 30 confirmatory application decision issued in 2019.

My application of 13 May ["the second request"] consequently followed up with a request for the next 30 documents of the same category.

In your letter, you state that "By introducing a connected application, within the same time period pending the handling of your original request, and concerning the same category of requested documents, namely decisions on confirmatory applications adopted by the Commission, it appears that you are indeed aiming at evading the fair solution you agreed with the Commission by making a, seemingly separate, request."

I disagree with this interpretation of my exercise of the right of access to documents, which I find peculiar. The first and second request were filed 17 days apart, and the very purpose of postponing the filing of a new request was to allow the Commission sufficient time to deal with my first request. I fail to understand how two access requests filed separately with a considerable time lag could meaningfully be construed as signifying a single request, or even requests that are related in the meaning of Regulation 1049/2001. An application for access to documents should typically take 15 working days to handle (Regulation 1049/2001, art. 7(1)). The first application you mentioned was just nearing its deadline as I filed my second request, and consequently, should have been well under way. Since I received no notification that the deadline was going to be extended, and since the request had been reduced to a small number of highly standardised documents, it was reasonable for me to presume that I would be receiving the documents pertaining to my first request soon. In fact, until today I have received no notification of an extension of the deadline, meaning that the Commission is currently in breach of its obligations under Regulation 1049/2001 regarding the first request.

Furthermore, in the very restrictive interpretation of Regulation 1049/2001 that the Commission proposes, the fact that I agreed upon a fair solution in one access request would disqualify me for applying for similar documents for a period of more than 14 days, or, as your letter seems to suggest, even 30 working days. I reject this interpretation as a contravention of Regulation 1049/2001, which guarantees applicants the widest possible access to documents, and also as a breach of the principle of legal certainty, given the fact that the Commission gave no warning ahead of time that under the fair solution that I agreed to, I was barred from filing new access requests for a period of weeks or possibly even months.

I furthermore observe that in its representation of the principle of proportionality, the Commission apparently only deems itself to have the administrative capacity to consider 1 on the documents that I requested per day. I regret that I find this interpretation to lack any and all credibility from the perspective of good administration.

Before agreeing or disagreeing to the suggestions for a fair solution that you extend, I therefore should first like to receive a clarification from the Commission as to when, according to the Commission's estimate, it would be appropriate for me to file a request for the next "batch" of confirmatory application decisions issued in 2019. I would also like to ask the Commission as a matter of the frank exchange that should characterise the search of a fair solution, whether under this application of the rules it would ever be materially possible to obtain access to all of the Commission's confirmatory application decisions at the same speed as, or sooner than they are being produced. By my estimate, this appears not to be the case.

For the purpose of record keeping and public monitoring, I submit this response both directly by email as you requested, and via the AsktheEU portal, with your original letter copied in at the end. For the purpose of a complaint filed with the European Ombudsman in a similar access request filed at the end of December, I will also forward your letter to the European Ombudsman's office for consideration of the merits of my complaint.

Yours faithfully,

Maarten Hillebrandt

Brussels SG.C.1/CS/rc -
By registered mail with AR

Mr Maarten Hillebrandt
University of Helsinki Faculty of Law
Eric Castrén Institute
Yliopistonkatu 3
00101 Helsinki
Finland

Copy by email:
[email address]
[email address]

Subject: Your applications for access to documents – GESTDEM 2020/2451 and 2020/2853

Dear Mr Hillebrandt,

We refer to your e-mail sent to the European Commission on 13 May 2020 in which you make a request for access to documents, registered on 14 May 2020 under the reference number GESTDEM 2020/2853.

In your application, you request access to, I quote, ‘[T]he 31st to the 60th final decisions by the European Commission in confirmatory application procedures under Regulation 1049/2001 issued in 2019’. You further specify that ‘an initial request for access to the first 30 documents of this category was already made on 26 April 2019’.

Indeed, on 26 April 2020, you made another request for access to documents, registered on 28 April 2020 under the reference number GESTDEM 2020/2451. By this application, you request access to all decisions on confirmatory applications adopted by the Commission in January and February 2019.

Regarding both your applications GESTDEM 2020/2451 and 2020/2853, you further specify that you exclude from the scope of your request (i) any personal data contained in the requested decisions; and (ii) ‘any related documents’. By the latter, we understand your request to exclude explicitly the annexes to decisions on confirmatory applications, Ref. Ares(2020)2600906 - 18/05/2020 namely the documents forming part of these decisions and to which full or partial access is granted.

Your applications registered as GESTDEM 2020/2451 and 2020/2853 concern the same category of documents, namely decisions on confirmatory applications adopted by the Commission in the year 2019.

On 29/04/2020, the Commission sent you a letter proposing a fair solution in the meaning of Article 6(3) of Regulation (EC) No 1049/2001 for dealing with your initial application for access to documents registered under the reference number GESTDEM 2020/24511. In its said letter, the Commission provided detailed reasons for its decision to put forward a proposal for a fair solution in accordance with Article 6(3) of Regulation (EC) No 1049/2001. It explained that your application concerns a very large number of documents, which need to be assessed individually, and that, according to its first estimates, a number of 10 documents could be dealt with within the extended deadline of 30 working days, counting from the date of registration of your initial application. Nevertheless, the Commission proposed to deal with an increased overall number of 30 documents falling within the scope of your request, or, in the alternative, to deal with all documents falling within the scope of your request as limited to one specific month covered by the timeframe of your request. In its decision to put forward this proposal, the Commission took into account the fact that you already exclude from the scope of your request any personal data contained in, as well as the annexes to, the requested documents, and your stated purpose of academic research. It also took into account the identical circumstances underpinning its earlier proposal for a fair solution concerning the handling of your similar initial requests registered under reference numbers GESTDEM 2019/7132, 2019/7134, 2019/7136, 2019/7137 and 2019/71382.

In your reply of 29 April 2020, you stated that you agree to narrow down the scope of your request to ‘either the first 30 confirmatory application decisions produced by the Commission in 2019, or to all confirmatory application decisions produced by the Commission in January 2019, whichever results in the highest number of documents being considered’3. Therefore, you indicated your agreement with the proposal for a fair solution put forward by the Commission and, as a result, the Secretariat-General of the Commission is currently handling your application registered as GESTDEM 2020/2451 by assessing the 30 decisions on confirmatory applications first adopted by the Commission in the year 2019, as this results in the highest number of documents being assessed.

In accordance with the case law of the EU Courts, Article 6(3) of Regulation (EC) Νο 1049/2001 may not be evaded by splitting an application into several, seemingly separate, applications4.

1 Reference Ares(2020)2295844 - 29/04/2020.
2 Reference Ares(2020)54028 - 07/01/2020.
3 Reference Ares(2020)2304392 – 30/04/2020.
4 Judgment of the General Court of 10 December 2010, Ryanair v Commission, T-494/08, EU:T:2010:511, paragraph 34.

You submitted your second application for access to documents registered as GESTDEM 2020/2853 while being aware that, at the same time, the Commission is handling your first application registered as GESTDEM 2020/2451 based on the fair solution already agreed with you in view of respecting the time-limits set by Regulation (EC) No 1049/2001. By introducing a connected application, within the same time period pending the handling of your original request, and concerning the same category of requested documents, namely decisions on confirmatory applications adopted by the Commission, it appears that you are indeed aiming at evading the fair solution you agreed with the Commission by making a, seemingly separate, request.

Moreover, your application registered as GESTDEM 2020/2853 is wide in scope in itself, as it concerns a large number of documents, which need to be assessed individually. Such a detailed analysis cannot be completed within the normal time limits set out in Article 7 of Regulation (EC) No 1049/2001.

As already explained, according to our first, preliminary estimates of the workload for the treatment of your request, and taking into account the performance of other tasks by the staff concerned, the handling of 10 documents would take approximately 30 working days5, covering the following steps:

• identification of the documents falling under your request;
• retrieval and establishment of a complete list of the documents identified;
• scanning of the documents;
• assessment of the content of the documents in light of the exceptions of Article 4 of Regulation (EC) No 1049/2001;
• preparation of the reply;
• redaction of those parts of the documents to which one or several exceptions apply;
• internal review and approval of the draft decision; and
• preparation of the reply and the documents for dispatch.

In this context, I would like to stress that the corresponding resources cannot be allocated to handle your request(s), so as to safeguard the interests of good administration and to ensure the proper handling of applications originating from other applicants.

Article 6(3) of Regulation (EC) No 1049/2001 provides for a possibility to confer with an applicant informally with a view to finding a fair solution when an application relates to a very long document or concerns a very large number of documents.

In accordance with the case law of the EU Courts, such a solution can only concern the content or the number of documents requested, not the deadline for replying6.

5 Taking into account other applications for access to documents and other tasks that the staff concerned are likely to have to deal with during the same period.

6 Judgment of the Court of Justice of 2 October 2014, Guido Strack v Commission, C-127/13, EU:C;2014:2250, paragraphs 26-28.

4
This means that the scope of the request must be reduced in a way that would enable its processing within the extended deadline of 15 + 15 working days.
As stated by the EU Courts, the Commission needs to respect the principle of proportionality and ensure that the interest of the applicant for access is balanced against the workload resulting from the processing of the application for access in order to safeguard the interests of good administration7.
Based on the above, with a view to reaching a fair solution, in the meaning of Article 6(3) of Regulation (EC) No 1049/2001, concerning the handling of your initial applications registered under the reference number GESTDEM 2020/2451 and 2020/2853, and to respect the time-limits set by Regulation (EC) No 1049/2001, we propose to continue to deal with the agreed number of overall 30 documents falling within the scope of your request GESTDEM 2020/2451, i.e., the 30 decisions on confirmatory applications first adopted in the year 2019, within the extended deadline of 30 working days, counting from the registration of your application GESTDEM 2020/2451.

Alternatively, we could propose to deal with all documents falling within the scope of your request GESTDEM 2020/2853, i.e., the 31st to the 60th decisions on confirmatory applications adopted in the year 2019, within the extended deadline of 30 working days, counting from the registration of your application GESTDEM 2020/2853.

In order to enable us to respect the time limits of Regulation (EC) No 1049/2001, we would ask you for a swift reply to our invitation to propose a fair solution, within five working days at the latest:

• by email to: [email address].
If you have any questions concerning the invitation, you can contact us:

• by email at: [email address].
In the absence of a reply within five working days, we we will unilaterally restrict the scope of your application to those parts that can be dealt with within the extended deadline of 30 working days, counting from the registration of your respective application.

Thank you in advance for your understanding.

Yours sincerely,
Maria OLIVAN AVILES Head of Unit

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/...

ve_sg.accessdoc (SG), Secrétariat général de la Commission européenne

[1]Ares(2020)2626737 - Your initial requests for access to documents -
GESTDEM 2020/2451 & 2020/2853

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

Dear Mr Hillebrandt,

Thank you for your e-mail of 18 May 2020 in reply to our letter of
proposal for a fair solution sent to you on the same date in relation to
your requests for access to documents registered under the reference
numbers GESTDEM 2020/2451 and 2020/2853 (reference Ares(2020)2600906 –
18/05/2020).

The solution under Article 6(3) of Regulation (EC) No 1049/2001 may
concern the number or content of the documents applied for, but not the
timeframe for dealing with the initial request. Such a fair solution is
therefore aimed at enabling the request to be dealt with within the double
fifteen-day time limit provided for under Regulation (EC) No 1049/2001.

The Commission has stated clearly this information in all its earlier
proposals to you to find a fair solution within the meaning of Article
6(3) of Regulation (EC) No 1049/2001 concerning your requests.

Having in mind that you already agreed to the fair solution proposal
regarding your request registered as GESTDEM 2020/2451, the Commission is
dealing with your request by assessing an overall number of 30 documents
of the requested category within the extended deadline of 30 working days,
counting from the registration of your application. Therefore, it would
not be reasonable to presume that you would be receiving the documents
pertaining to your request prior to the expiration of the first
fifteen-day deadline, as stated in your message. In any event, this first
fifteen-day deadline would only lapse on 25/05/2020.

Please also note that an agreement for a fair solution concerning one
particular request may not extend automatically to all connected requests
made by the same applicant and concerning a large number of documents. As
already explained, the workload resulting from a particular request has to
be balanced against the general interest in safeguarding that the
Commission manages its resources efficiently and ensures the proper
handling of applications originating from other applicants.

In light of the above, the arguments that you appear to raise in your
below message are deemed as not valid.

We would appreciate a concrete reply to our last above-referenced proposal
for a fair solution the soonest possible, so as to enable us to treat your
request within what remains of the time-limits laid down in Regulation
(EC) No 1049/2001 counting from the registration of your respective
application.

Yours faithfully,

Access to documents team (rc)
SG.C.1
Transparency
Berl. 07/251

Afficher les sections citées

Maarten Hillebrandt

Dear ve_sg.accessdoc (SG),

I received your response to my email of 18 May concerning the search of a fair solution in my request for access to documents in good order. In response to this email I would like state the following.

Unfortunately, I fail to understand why it would have been reasonable for me to understand that the Commission's dealing with my access request would automatically be extended to 30 days without prior notification. As I wrote yesterday, I applied for a small number of highly standardised, very similar documents, and thus expected the Commission to be able to assess the possibility for access accordingly swiftly. Either way, there is nothing in art. 6(3) of Regulation 1049/2001, or any other article of that Regulation that would permit the Commission to extend the handling period by an additional 15 days without prior notification. A clear statement from the Commission's side as to the expected deadline of the first request, and consequences for a potential follow-up request would have prevent this unfortunate misunderstanding from occurring.

Apart from this fact, the above dispute would seem immaterial from the perspective of the law. There is nothing in Regulation 1049/2001 that suggests an applicant is barred from filing a new request upon reaching an agreement for a fair solution, provided that a sufficient amount of time has passed. As I stated, in my case there were 17 days between the first and the second request. Since I have an interest in accessing the requested documents in the fastest possible time frame without undue delay, it is logical for me to seek access to them in the fastest possible manner available to me under Regulation 1049/2001, and to resist delays in this process by the Commission.

In any event, in my email of yesterday, I requested clarification on the Commission's position as to how long I would not be permitted to file a second request. I note that the Commission has not explicitly answered this question. Before responding to the Commission's offer for a fair solution, I would thus very much be obliged to receive a precise response to this question, as it would offer me legal certainty about my rights to rely on Regulation 1049/2001 in a regular fashion. Legal certainty in this respect should be reasonably expected as a matter of good administration.

Finally, I observe that the Commission's decision to count the first 15-day period of consideration as starting after conclusion of the search for a fair solution is inconsistent with its handling of an earlier access request filed by me in December 2019, which is currently the subject of an investigation by the European Ombudsman. In this request, the Commission insisted that the handling time should be counted as starting on the date of the registration of the initial request. This also appears inconsistent with the statement at the conclusion of your email, that a fast response is required "so as to enable us to treat your request within what remains of the time-limits laid down in Regulation (EC) No 1049/2001 counting from the registration of your respective application". Either the Commission starts counting 15 days from the moment at which a fair solution has been agreed upon, or it doesn't. It would be neither logically possible nor consistent for the Commission to apply both manners of counting at the same time.

I feel obliged to notify the Commission in advance that a decision by the Commission to regard this response directly as invalid will result in my filing yet another complaint with the European Ombudsman concerning maladministration in the handling of an access to documents request.

Yours sincerely,
Maarten Hillebrandt

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/...

ve_sg.accessdoc (SG), Secrétariat général de la Commission européenne

[1]Ares(2020)2653053 - RE: Ares(2020)2626737 - Your initial requests for
access to documents - GESTDEM 2020/2451 & 2020/2853

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

Dear Hillebrandt,

Thank you for your below reply.

The Commission has provided you with detailed reasons for its decision to
put forward a proposal for a fair solution in accordance with Article 6(3)
of Regulation (EC) No 1049/2001 on several instances.

It has also consistently explained how an agreed fair solution works in
order to enable the handling of an initial application relating to a very
large number of documents within the extended deadline of 30 working days,
counting from the date of registration of the application.

In accordance with the case-law of the EU Courts, Article 6(3) of
Regulation (EC) No 1049/2001 may not be evaded by splitting an application
into, seemingly separate, applications.
Therefore, a further connected application should normally be assessed for
treatment once the handling of the application already being treated is
completed pursuant to the terms of the agreed fair solution.  

We hope you will find this useful and that you can provide us with your
reply to our proposed fair solution the soonest possible.

Yours faithfully,

Access to documents team (rc)
SG.C.1
Transparency
Berl. 07/251

Afficher les sections citées

Maarten Hillebrandt

Dear ve_sg.accessdoc (SG),

Thank you for providing an answer to my question after have asked twice. While I disagree with the reasoning provided by the Commission for the reasons provided in my email of yesterday, I will withdraw my second request until 25 May (the maximum statutory period of consideration as provided under Regulation 1049/2001), as a continuation of this email exchange will only result in further inconvenient delays in my obtaining access to the requested documents.

Yours sincerely,
Maarten Hillebrandt

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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ve_sg.accessdoc (SG), Secrétariat général de la Commission européenne

[1]Ares(2020)2724044 - RE: Ares(2020)2653053 - RE: Ares(2020)2626737 -
Your initial requests for access to documents - GESTDEM 2020/2451 &
2020/2853

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

Dear Mr Hillebrandt,

Thank you for your below reply.

From your message, we take note that, in reply to our last proposal for a
fair solution of 18 May 2020 (reference Ares(2020)2600906), you state your
preference that we continue to treat your request GESTDEM 2020/2451 and
that you therefore withdraw your second request GESTDEM 2020/2853.

As per our above-referenced letter of proposal for a fair solution and
previous correspondence, and our holding reply of 25 May 2020 (reference
Ares(2020)2688656), you will receive a reply to your request within the
extended fifteen-day deadline provided for under Regulation (EC) 1049/2001
counting from the registration of your application. As stated in our
above-referenced holding reply, this time limit expires on 16 June 2020.

Thank you for your cooperation and understanding.

Yours faithfully,

Access to documents team (cr)
SG.C.1
Transparency
Berl. 07/251

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