Memorandum by Mr Stephen Jakobi OBE, Consultant,
Cross-Border Justice
SUMMARY
1. Background: the history of the EU provisional
liberty proposals
1. The writer initiated the concept in 1994
and with the aid of associate practitioners, he formulated the
Eurobail system.
2. He attended all the Commission's expert
meetings and consultations in this connection.
2. The need for EU action
3. The Scale of the problem. When
your Lordships last examined the position my concern was noted.
21 MARCH 2007
4. This concern was based on a 1995 research
project I conducted.
5. The conclusions of that project were
that there were 5,000 foreign EU prisoners at any one time and
if there was a viable bail system, half of them would not be in
prison.
6. Over the intervening 10 years, the EU
has expanded and the volume of interstate travel has increased.
7. The 2005 research by the independent
contractor estimated 10,000 foreign EU prisoners at any one time
and 80% potentially subject to discrimination.
8. The two studies are broadly in agreement,
the number of prisoners has almost doubled and the number of citizens
affected has more than doubled.
9. The observation is made that foreigners
are likely to spend longer on remand than natives.
10. The cost to the people involved:
the impact assessment uses an economically based assessment that
observes that many are eventually acquitted and others given non-custodial
sentences.
11. It is observed that the attempt to quantify
the experience in economic terms, by reference to compensation
sums, is risible. The psychological effect on the innocent is
devastating, and frequently long-term or permanent. Suicide on
release, though rare, is not unknown.
12. The cost of public authority is reasonably
argued.
3. The major legal and practical implications
of the Commission's proposal
13. Legal and constitutional background:
the current inquiry needs to be considered against the background
of House of Lords previous inquiries.
14. In the inquiry into procedural rights
in criminal proceedings, it was noted that there was a dispute
amongst Member States as to the legal basis of the framework decision.[1]
15. The subsequent inquiry, "Breaking
the deadlock" concluded that there would have to be constitutional
reform before progress could be made.[2]
16. The lack of a common age of criminal
responsibility within the EU gives rise to the possibility that
adults would obtain bail and some young children would be left
in custody.
17. Incompatibility of justice systems:
the common law based systems in essence are compatible with any
sort of enforceable international pre-trial transfer system.
18. By contrast, the code civile based systems
(French example) generally insist on the availability of the accused
for questioning until the formal trial.
19. It is therefore impossible, in theory,
and sometimes in practice, for a Code Civile country to allow
an accused bail outside that country. The only solution is a viable
videoconferencing system throughout the EU.
4. The adequacy of the system proposed and
whether another option is preferable
20. Overview: the classical factors
in magistrates' decisions to grant bail involve assessment of
risk and therefore militate against foreigners. An adequate system
needs to provide for informed and impartial risk assessment.
21. The Commission's perspective:
it is accepted by the Commission that its aim is to promote equal
treatment of all citizens in the EU legal space.
22. There are no proposals in the documents
for any mechanism to deal with the problem of risk assessment.
23. The guarantee of return to court is
dealt with.
24. The mechanism for supervision of the
citizen on bail is too complex.
25. Assessed against the Commission's own
aspirations for its scheme, it is considered it will only have
a marginal impact on the problems if the European arrest warrant
is any precedent.
26. Eurobail is the only viable
alternative, since it is the only scheme proposed that involves
impartial assessment of risk in granting bail.
27. The procedure is examined.
28. The power to deal with conditions of
bail would be vested in the accused's home Court.
29. Advantages: proof against xenophobic
risks, applicable to all cases, allows all courts to apply their
own familiar laws and is simple in concept.
30. Disadvantages: children, juvenile and
Code Civile problems.
5. What amendments might be made to Commission's
proposal
31. Children and code civile problems.
32. Simplification of protocol between countries.
6. Observations
33. The impact assessment is severely flawed.
34. Statistical evaluation has been examined
in detail.
35. Assessment of the policy options are
roughly ranked according to their importance. Individual rights
and notional cost of injustice are bound up together. The fourth,
fifth and sixth criteria are simply different aspects of political
acceptability and should be taken under one head.
36. The comparative assessment between the
schemes discloses obvious bias against Eurobail under most heads.
37. Apart from the above, there is an inexplicable
misrepresentation that the term "bail" only applies
to monetary surety arrangements.
7. Conclusions
38. There is no prospect of any viable scheme
without fundamental constitutional change in the governance of
the EU and therefore no reason why any scheme should be pursued
against the current background.
39. However unpromising the setting, the
need for EU action is even greater than the Commission's assessment
of the position.
40. The impact of the Commission's scheme
will be at best marginal.
41. There are serious practical shortcomings
in all schemes.
42. The Eurobail system is clearly superior
to the chosen scheme on merit and it is unfortunate that the comparison
of schemes is not impartial. There should be no confusion between
inherent merit and political expediency.
SECTION 1
BACKGROUND—THE HISTORY OF EUROPEAN
UNION PROVISIONAL LIBERTY PROPOSALS
1. The writer can claim to have initiated
the concept of an EU wide provisional liberty system. He invented
the concept in the course of an article on European Bail problems
published in the Times on October 18th 1994. He also invented
the term Eurobail at about the same time though it does not appear
in the article. In 1995 the writer, on behalf of the organisation
he founded, Fair Trials Abroad (FTA), gave written evidence on
the concept to your Lordships' Select Committee considering the
1996 Intergovernmental Conference. Apart from some activity by
the Civil Liberties Committee of the European Parliament the concept
made little headway until 1999. In the meantime, the writer
had, at the request of the British Home Office and interested
MEPs, been working on the practicalities of such a system with
the aid of FTA's British, French, Dutch and Italian correspondents.
By 1999 we had reached the final form of the system known as the
Eurobail system.
In January 1999 both written and oral evidence
was given on behalf of FTA to your Lordships' EU Select Committee
on the Corpus Juris project. The ensuing report gave specific
endorsement to the concept of Eurobail.[3]
Since then Eurobail System, in common with all other measures
for protection of citizens' rights, was on "hold" until
the 2002 Commission initiative.
2. From 2002 to 2005 the writer attended
all the experts meetings mentioned in the Commission's proposal.
It is of particular significance that in 2004 the official responsible
for the preparation of the framework resolution met with FTA's
European criminal lawyers panel (ECLAP). After a detailed exposition
of the various alternatives canvassed in the impact assessment
Eurobail was unanimously selected as the only system that answered
the perceived problems.
SECTION 2
THE NEED FOR EU ACTION ON PRE-TRIAL SUPERVISION
MEASURES
THE SCALE
OF THE
PROBLEM
3. It may be recalled that your Lordships
last examined the bail position in the EU in the course of your
inquiry into procedural rights in criminal proceedings.[4]
In paragraph 56 of the report it was noted "Mr Jakobi said
that the question of bail causes far more misery and demonstrable
injustice in the European system than almost anything else you
can think of affecting foreigners. Whereas the native goes free
on conditions, the foreigner sticks inside jail."
4. This observation was as a result of a
desk research project carried out by the writer in 1995 to ascertain
the number of EU citizens affected by pre-trial custody outside
their own country and such evidence of discrimination as existed.
For various reasons, including incomplete statistics, it was presented
as a rough estimate of the parameters of the problem.
5. The conclusions were as follows
There are at least 5,000 prisoners in the
EU at any one time who are on remand and facing the legal handicaps
discussed in this paper.
Nearly half of them, over one in five of
the total number of "foreign" EU prisoners would not
be in prison if they were natives of the country holding them.
At the experts' meeting held in 2005 it was
apparent that this was the only published work on the topic before
the external contractor was commissioned.
6. Over the intervening 10 years, the EU
has expanded and there was more interstate travel by EU citizens.
These factors must be taken into consideration in comparing the
new figures, compiled by the external contractor, with the old
results.
7. The Commission impact assessment[5]
summed up the numbers of people in pre-trial detention as follows,
"During each calendar year, it is estimated
that almost 10,000 EU nationals are detained in pre-trial detention
in EU countries other than their normal country of residence.
At any moment, there are around 4,500 EU nationals in pre-trial
detention in EU countries other than their normal country of residence."
"Based on the data from several countries,
it was estimated that as many as 80 per cent of EU nationals currently
in pre-trial detention could be potentially subject to a pre-trial
transfer order and the application of alternative measure than
pre-trial detention."
"This would suggest that during any
one year as many as 8,000 EU non-resident pre-trial detainees
could be subject to an alternative pre-trial non-custodial measure."
8. It will be seen that the two studies
are broadly in agreement: the number of prisoners has almost doubled,
probably primarily due to the two factors noted above, and the
number of citizens affected has more than doubled.
9. With regard to the problems experienced
by EU nationals in pre-trial detention[6]
attention should be drawn to the figure in table 3.2 for France.
Whilst it would appear that the average pre-custodial remand time
for the jail population as a whole is four months a more realistic
figure in the writer's experience would be approaching double
that for the non-native. The writer would attribute this to delays
in obtaining and assessing foreign evidence in relation to the
case. Unfortunately there is an absence of data for Spain in the
Table.
THE COST
TO PEOPLE
INVOLVED[7]
10. These have been categorised in the Impact
Assessment under four heads: loss of freedom, loss of earnings,
"consequential loss" (professional standing, stigma,
breakdown of families and relationships) and cost of family and
friends visiting whilst in detention. The section goes on to observe
that many people who have been held in pre-trial detention are
eventually acquitted and to those should be added cases that are
disposed of in a non-custodial manner.
11. As one who has had probably more professional
opportunity to observe at close quarters the effects of discrimination
in remand practices involving the innocent on both the victims
involved and their families than anyone, I am forced to comment
that the attempt to quantify the experience in economic terms
by reference to compensation sums is risible.
The psychological effect on the innocent and
their close family of even a comparatively short term of imprisonment
in a foreign country for whatever reason is devastating. It usually
leads to the need for professional assistance and frequently long-term
or permanent economic, social and psychological breakdown. Matrimonial
breakdown is a prominent feature of such incidents, and suicide,
though rare, is not unknown.
THE COST
TO PUBLIC
AUTHORITY[8]
12. The economics of custody and its alternatives
would appear to be reasonably argued. Videoconferencing is a major
technological advance which needs to be built into the thinking
of those concerned with cross-border justice policy generally.
SECTION 3
THE MAJOR LEGAL AND PRACTICAL IMPLICATIONS
OF THE COMMISSION'S PROPOSAL
LEGAL AND
CONSTITUTIONAL BACKGROUND
13. The current inquiry needs to be considered
against the background of your Lordships' previous inquiries into
Procedural rights in criminal proceedings[9]
and, subsequently, Breaking the deadlock.[10]
14. In the inquiry into Procedural rights
in criminal proceedings it was noted[11]
"that some member states have in the past expressed reservations
about the usefulness and legality of such a proposal. They have
argued that subsidiarity precludes action at EU level and that
the treaty does not provide a sufficient legal basis for the proposal."
15. The subsequent inquiry, Breaking
the deadlock,[12]
specifically focused on the problem of progress of procedural
rights. The Writer summarised the position as follows:[13]
"The committee based its deliberations
on evidence given by the Attorney General and various government
officials. To summarise: the European law on procedural rights,
which would have made a marked difference to the rights to justice
of Britons abroad, is so locked in committee that the UK Government
has despaired. As a consequence, the UK Government, together with
the Czech Republic, Irish Republic, Malta, Cyprus and Slovakia,
is proposing a non-binding "code of good practice" resolution
to the same affect.
During the course of his evidence, the Attorney
General went out of his way to point to the difficulties which
have arisen for this type of legislation as a result of the failure
to ratify the constitutional treaty. In particular: "This
treaty would have brought important changes to the way criminal
justice measures are agreed in the (European) Council." It
was quite clear that he considered the abolition of the unanimity
rule as a vital ingredient to progress.
His comments are applicable to the whole
spectrum of criminal justice measures."
CHILDREN AND
JUVENILES EXCLUDED
16. During discussions of the Commission
proposals for a Framework Decision on Cross-border Supervision
of Probation a serious anomaly was discovered due to the lack
of a common age of criminal responsibility within the EU—which
varies from 7 in Ireland to 16 in Portugal. The problem is that
the European arrest warrant has as a mandatory ground for refusal
to execute it that the child is below the age of criminal responsibility
in the executing authority. It would appear to be impossible for
any other criminal justice measure within the ambit of the European
legal space to deviate from this precedent.
What this must mean in practice is that while
some adults may get bail, some quite young children in the same
circumstances may be detained in a strange land with no one to
speak their language while their case is disposed of.
The EU must determine a common age for criminal
responsibility, and what that should mean in practice for foreign
children, as a matter of urgency.
INCOMPATIBILITY OF
CRIMINAL JUSTICE
SYSTEMS
17. The common law based systems, in essence,
are compatible with any sort of enforceable international pre-trial
transfer system since they share the following characteristics:
— The accused has to be charged or
released within days of arrest, the outside limits being, at present,
28 days in the UK.
— After charging, the accused cannot
be questioned in the course of the inquiry, although the police
are at liberty to continue their inquiries.
— The trial commences as a specific
stage of the proceedings, is continuous and starts at a specific
date.
18. By contrast, the code civile based systems
share the following characteristics to a greater or lesser extent
(the French system is used for this comparison):
— Charging is a much more flexible
concept. In 95 per cent of the cases, the investigation is conducted
by the police and are judicially supervised by the prosecutor.
In these cases, charging usually occurs as quickly as it does
in a common law system. The other 5 per cent are the more serious
charges, where an examining magistrate is involved and is potentially
a very lengthy investigation. It is possible for the accused to
be in custody for months before formal charges are decided by
the examining magistrate.
— The accused can be questioned at
any stage of the inquiry until the examining magistrate hands
the case over to the trial tribunal.
— The trial can be said to commence
with the opening of the inquiry by the examining magistrate since
all the evidence taken in the presence of the accused and his
lawyer is, in general, unquestionable evidence for the formal
hearing at trial. The accused is not only questioned about the
offence, he will also be questioned about his background and personality.
19. It is for these reasons that a code
civile criminal justice system requires the availability of the
accused to attend the examining magistrate at all stages of the
pre-trial procedure until the case is closed and passed to the
trial tribunal. It is therefore essential that a viable video
conferencing system be set up throughout the EU before any practical
pre-trial alternative to custody for non-residents can operate.
SECTION 4
THE ADEQUACY OF THE SYSTEM PROPOSED AND IN
PARTICULAR WHETHER ONE OF THE OTHER OPTIONS CONSIDERED BY THE
COMMISSION WOULD BE PREFERABLE
OVERVIEW
20. In its response to the Commission Green
Paper[14]
FTA stated its view that the heart of the problem regarding discrimination
against foreigners, was best expressed as follows:
"As both the Commission in itself and
the ECJ have recognised, the magistrate's decision on bail essentially
involve `the classical grounds.' That is to say consideration
of three factors: gravity of the offence, the likelihood of further
criminal activity whilst on bail (including interfering with witnesses
or repetition of offence) and the danger of absconding.
Of these classical grounds, the gravity of
the offence is a common factor for nationals and foreigners alike.
However, the other factors involve assessment of risk and militate
against foreigners. It is routine for a court, secure in its knowledge
of its own society, to assess such important factors as ties with
the community when it comes to nationals. By contrast, for foreigners,
the assessment of ties with the community is fraught with difficulties:
there is an inevitable lack of personal information before the
court and possible cultural difficulties.
Further, in the absence of swift and effective
arrest arrangements operating throughout the EU against fugitives
from justice, magistrates will fear that if a foreigner is allowed
home he will not return.
What is required in an adequate system is
that it provides answers to these two needs such as an informed
and impartial personal risk assessment, coupled with an ironclad
guarantee that the defendant would be arrested and returned to
the court if he/she became a fugitive from justice."
THE COMMISSION'S
PERSPECTIVE
21. The Commission's proposal (referred
to as policy option 2 in the impact assessment) is for a new Council
framework decision. It is accepted by the Commission that "the
general aim of this proposal is to . . . promote equal treatment
of all citizens in the common area of freedom and security and
justice."[15]
22. The impact assessment document[16]
agrees in general terms with the view expressed by FTA on risk
assessment.[17]
However, one searches in vain for any mechanism in the proposed
framework decision for dealing with this problem. On the contrary,
the original provisional liberty decision remains with the issuing
court.
23. The guarantee of a return to court on
application by the issuing authority is reasonably dealt with,
if one can accept that children and juveniles will be excluded
from operation of the framework decision.
24. The mechanism for supervision of the
citizen released on remand between release and trial is of unnecessary
complexity, put forward by the Commission on the grounds that
it is necessary to keep the issuing court in control of the process
(see above).
25. Assessed against the Commission's own
aspirations for its scheme, it is considered that it will only
have a marginal impact, if any, on the problem posed by the mass
discrimination established in section 2 of this paper. The European
Arrest Warrant has been operational for some three years, and
is in essence a compulsory extradition system. It may be recalled
that claims were made by the Commission on its launching that
its existence would increase the likelihood of provisional liberty
being granted. The ECLAP experience was that defence practitioners
who cited the arrest warrant in efforts to obtain provisional
liberty for their clients found no practical difference in the
results attained.
THE ONLY
ALTERNATIVE: EUROBAIL
26. Since the only scheme proposed that
deals with the inherent xenophobic factors involved in an original
bail decision by a foreign tribunal is Eurobail, it is the only
viable alternative, in view of problems concerning the objectivity
of the Commission's impact study in its final form and bizarre
misrepresentations made concerning Eurobail. The procedure and
advantages of the scheme as presented to the Commission[18]
is set out below.
27. Procedure
The authority where the foreign national was
arrested would consider if the offence, as committed, could result
in provisional liberty for a national of that country. If the
offence and its circumstances were too grave to permit provisional
liberty, the accused would be remanded in the custody of that
authority. If the circumstances of the offence might permit provisional
liberty, the arresting authority would notify the appropriate
authority in the accused's home country, whereupon the accused
would be sent home as expeditiously as possible for the disposal
of his application for provisional liberty. It would then become
the responsibility of the accused's home law enforcement officials
to ensure that the accused is delivered back to the jurisdiction
of the crime.
28. Reasonable notice of requirement for
judicial purposes would be a factor. The power to vary conditions
or rescind bail between release and return would be vested in
the accused's home court.
29. Advantages
— It is proof against xenophobic risk
assessment in any of its manifestations (culture clash, evaluating
community ties of a foreigner or the quality of foreign evidence
collection).
— It is applicable to all cases involving
the provisional liberty of a foreign EU citizen.
— It allows both trial and home court
to apply their own laws and knowledge at appropriate stages of
consideration of transfer.
— It is simple in concept, in that
responsibility for ensuring the defendant shall be present at
trial passes with his person.
30. Disadvantages
— Children and juveniles.
— Code Civile problems unlikely, in
practice, to be completely solved even by universal videoconferencing
arrangements.
SECTION 5
WHAT AMENDMENTS MIGHT BE MADE TO THE PROPOSAL
TO IMPROVE THE PROCEDURE
31. Establishing a common age of criminal
responsibility, coupled with an approximation of systems for dealing
with juveniles and a common age of transition between juvenile/adult.
The Approximation of regimes for dealing with the young is an
important prerequisite for any scheme to operate fairly.
32. Code Civile problems require solution.
33. The protocol recommended with regard
to communication and powers of the competent authorities in both
countries concerned should be re-examined with a view to simplification.
SECTION 6
OBSERVATIONS
IMPACT ASSESSMENT
34. It has already been remarked that the
impact assessment is severely flawed. The criticisms that follow
should not be laid at the door of the external examiner. It is
specifically stated in the impact assessment that he was working
under the guidance of a steering committee, and, in accordance
with usual practice within the Commission, the Commissioners bear
the responsibility for the accuracy of the impact report.
35. Statistical evaluation: has
already been examined in detail in section 2.
36. Assessment of the policy options.
The criteria are explained in detail in the introduction to the
assessment.[19]
They are, in fact, roughly ranked according to importance.
— The first (individual rights and
equal access to justice) is vital if any scheme is to pass
muster policy in accordance with the most fundamental principles
on which the EU is founded.
— The second (notional cost of injustice)
is bound up with the first criteria, and it is somewhat hard
to see how qualitatively the two can be distinguished. Indeed,
detailed perusal of the ranking of all schemes shows no difference
between these two rankings within any individual schemes (eg if
**** for first criteria then **** for second criteria). What was
the point of the exercise?
— The fourth, fifth and sixth (reducing
the net costs of detention and the spin-off effects on judicial
and police co-operation) are not to be considered as of equal
importance to the first three criteria. It is submitted that they
are all, in fact, different aspects of political acceptability
and they should really be lumped together under that one head.
37. The comparative assessment: new legal
instrument (NLI) and Eurobail
— Ensuring equal access to Justice.
(Impact assessment NLI ***** Eurobail ****). Since NLI does nothing
to alleviate discrimination in risk assessment during the original
decision to grant bail it must surely merit a rating of merely
**/***. On the other hand, what are the grounds for not granting
Eurobail ***** status?
— Reducing notional costs of injustice.
(Impact assessment NLI ***** Eurobail ****). In view of the remarks
on criteria (36) NLI**/***? Eurobail*****?
— Decreasing the risks of absconding
(NLI** Eurobail**) is correctly explained in the comment on NLI
which is applicable to both schemes. So what is one to make of
the comment on Eurobail?
— Reducing the costs of detention.
(NLI***** Eurobail****) since the same comments are applicable
to this criterion as to the others noted above NLI**/*** Eurobail*****
38. Misrepresenting Eurobail.[20]
Apart from the curious presentation of comparative star ratings
noted above, the assessment of benefits and constraints rests
upon an inexplicable misrepresentation that the term "bail"
only applies to monetary surety arrangements. Not only was it
explained in the memorandum submitted on behalf of FTA during
the consultation process that the British expression "bail"
should be taken in this context as being the equivalent to the
continental expression "Provisional liberty", the concept
was explained in all papers and expert meetings throughout the
process.
SECTION 7
CONCLUSIONS
39. The Attorney General has given evidence
that there is no prospect of any viable scheme for a European
Council framework decision to be enacted in the sphere of fundamental
procedural rights without fundamental constitutional change in
the governance of the EU. Accordingly, there is no reason why
an inferior scheme should be pursued for political expediency
purposes against current background.
40. However unpromising the setting the
need for EU action on pre-trial supervision measures is even greater
and more urgent than the assessment contained in the impact statement.
The numbers affected by the lack of a proper measure have demonstrably
increased over the last 10 years and will continue to do so. The
assessment of the effect of injustice on them is likely to be
greater since foreigners are likely to be kept on remand awaiting
trial and the economic assessment made is risible.
41. The experience gained through the operation
of the European Arrest Warrant, although anecdotal in character,
suggests that the impact of the new legal instrument scheme on
the mass injustice demonstrated will be at best marginal.
42. There are serious practical shortcomings
in all schemes. The lack of a common age for criminal liability,
coupled with a lack of approximation in methods of dealing with
juveniles, generally requires attention. The Code Civile criminal
justice system requires virtual attendance of the accused on demand
throughout the criminal justice process from arrest to close of
the dossier. This problem can be largely solved by mandatory video
conferencing arrangements throughout the EU which may take a long
time to become operationally viable. Since there are clearly no
reasonable prospects in the near future of any scheme being brought
into operation it is recommended that the Commission now gives
priority to resolving these obstacles by establishing a common
minimum age for criminal responsibility and a practical judicial
video conferencing system.
43. The Eurobail system is in fundamental
rights terms clearly superior to the chosen framework option,
but is apparently considered by the Commission to be politically
inexpedient in the current climate of the European Legal Space.
It is unfortunate that the impact assessment and comparison of
schemes considered bears the appearance of stealthy bias under
the cloak of impartial appraisal. It is surely right that political
expediency and acceptability be separately assessed so that there
is no confusion on inherent merit.
February 2007
1 (1st Report 2005-05 HL Paper 28). Back
2
(2nd Report 2007-07 HL Paper 20). Back
3
Prosecuting Fraud on the Communities' Finances-the Corpus
Juris (9th Report 1998-99 HL Paper 62). Back
4
(1st Report 2004-05 HL Paper 28). Back
5
SEC (2006) 1079 clause 3.2. Back
6
Ibid 3.3. Back
7
Ibid 3.4.1. Back
8
Ibid 3.4.2. Back
9
(1st Report 2004-05 HL Paper 28). Back
10
(2nd Report 2006-07 HL Paper 20). Back
11
Paragraph 9. Back
12
Op. cit. Back
13
Letter to The Times 18th of January 2007. Back
14
"A fair approach to provisional liberty/bail" October
2004. Back
15
Explanatory memorandum: consistency with other policies and objectives
of the Union. Back
16
SEC (2006) 1079. Back
17
In particular, ibid 3.3 "the court in a `foreign'
country is in a difficult position to make a risk assessment..."
And the remaining arguments expressed therein. Back
18
"A fair approach to provisional liberty/bail", FTA
response to the Commission's Green Paper, October 2004. See also:
Eurobail: preliminary reflections for a framework programme, FTA
June 2002. Back
19
Impact assessment, 6.1. Back
20
Op. cit 6.2.5. And table 6.5. Back
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