Impact Assessments in the EU: room for improvement? - European Union Committee Contents


Impact Assessment Guidelines

6.  The Third Strategic Review reaffirms the Commission's commitment to an "integrated approach" to impact assessments (IAs). This approach is intended to produce a balanced assessment, taking into account the benefits and costs of the economic, social and environmental impacts of initiatives. All legislative proposals included in the Commission's annual Legislative and Work Programme which are likely to have significant impact are supposed to receive a full impact assessment.

7.  In January 2009 the Commission issued new Impact Assessment Guidelines[7], designed to assist the various services in the production of IAs. The Guidelines explain that IA is "a process that prepares evidence for political decision-makers on the advantages and disadvantages of possible policy options by assessing their potential impacts" to be taken into account by the College of Commissioners when deciding on which legislation to adopt.

8.  Dr Alexander Italianer, Chair of the Impact Assessment Board, summarised the changes:

    "We introduced an explicit subsidiarity test, if you like. Also improvement of consultation was an important topic. And finally the services, through the guidelines, received improved guidance on how to measure certain impacts like social impacts, consumer impacts, impacts on small and medium-sized enterprises, competition and so on" (Q 60).

9.  As to whether the new Guidelines had improved the quality of IAs, he suggested that the required standard of IAs had been raised yet the rate of resubmission requests[8] had remained the same, and reasoned that "if the rate of resubmissions stays the same then, mathematically speaking, the quality of the reports should have increased, but that is nothing more than a mathematical inference!" (Q 60).

Impact Assessment Board

10.  In order to monitor the work of the Commission services in the production of IAs, the Commission set up in 2006 the Impact Assessment Board (IAB), operational from 2007, under the chairmanship of Dr Italianer. The IAB is part of the Commission, but independent of the individual services which produce both legislation and IAs. Dr Italianer explained to us that the IAB

    "is a group of high-level Commission officials that is independent with respect to the other services. It works directly under the authority of President Barroso. My four other colleagues are directors and are all appointed in a personal capacity but they come from the various strands in the Commission that also form the various components of a typical impact assessment" (Q 56).

11.  The IAB examines all IAs and issues opinions on their quality, often requiring the service concerned to resubmit an improved version. In 2008 32% of IAs required resubmission.[9]

The Rights of Ship Passengers Regulation
While we were conducting this inquiry, we also scrutinised a proposed Regulation on the Rights of Ship Passengers. We took this as a case study into how an impact assessment is produced and then assessed by the Impact Assessment Board.

In 2005-06, DG TREN commissioned a study on the level of protection of passenger rights in the EU maritime sector. This study identified problems with regard to passenger rights across Europe. This was particularly the case with passengers of reduced mobility (PRMs).

The Commission then launched a public consultation, and a stakeholder meeting was held. There was "virtual unanimity" concerning the need for minimum standards for the protection of passengers' rights. DG TREN then commissioned a preparatory study from PricewaterhouseCoopers. This examined the economic, social and environmental impacts of four policy options: no action, EU legislative action, national legislation and sector-specific voluntary agreements. The results of this study were fed into the impact assessment.

A draft IA was submitted to the IAB in September 2008. They found that it was "well-structured, written in a clear and non-technical language and accessible to the non-specialist reader". However, they recommended that a clearer justification was needed of the scope of the initiative and the extent to which passengers were already covered at national level. They also recommended that a more developed analysis of the various options was necessary, along with a more accurate assessment of the costs and the impact on SMEs. The draft IA was resubmitted to the Board a further two times, and finally released along with the proposal on 4 December 2008.

We asked Dr Italianer whether IAs were often resubmitted three times and he told us that it was extremely rare: "I think this has happened only in four cases in 2008 and in 2009 it never happened" (Q 58). His explanation of why this dossier was so problematic is as follows:

    "One cause may be insufficient scoping … In the first instance, it was not at all clear if a certain number of the rights that were being looked at in this particular proposal were already covered by all passenger transport activities that were covered by public service obligations, so it was not even clear to which type of activities the initiative was supposed to apply. Secondly, there was a scoping issue as regards the extent to which there was cross-border activity involved because many passengers are being shipped … Then there was an issue of substance on the costs, which were not sufficiently elaborated and on which we had to come back" (Q 59).

12.  We asked Dr Italianer what the IAB does when it receives an impact assessment. He explained:

    "We check whether the draft has a well-formulated, what we call problem definition, that the objectives that are being sought by the initiative are well-specified, that the options that are being studied are realistic; that there is indeed a case for EU intervention and subsidiarity is being analysed. Then our scrutiny focuses on the measurement or the assessment of the impact of the various options, there is comparison, and at the end of the process there are arrangements for the monitoring and evaluation" (Q 58).

13.  Many of our witnesses thought that the IAB was doing a good job, although some expressed concerns about the structure of the Board. Claudio Radaelli, Professor of Political Science at the University of Exeter Centre for European Governance, described it as "like a clumsy bumble bee that should not fly according to the logic of physics, yet it flies" (p 4). He went on to praise Dr Italianer's chairmanship of the Board, stating that "it is hard to imagine how the next Chair of the Board will be able to match Alexander Italianer's skills" (p 5). This was echoed by the Government, who argued that the "success of the IAB has, to a large extent, been the result of the quality of its board members" (p 44).

14.  Institutionally, the IAB is part of the Commission, and its board members are drawn from the Commission services, that is, the departments producing the impact assessments. The Commission explained that board members must declare any conflict of interest and that this happened on six occasions in 2008. The resubmission rate for IAs produced by services with members on the board was 33%, compared to 32% for those without (p 27). Dr Italianer argued that:

    "The main evidence of our independence is the fact that the opinions that we write on the draft impact assessments are publicly available. It is quite rare that inside a public administration body dissenting opinions come out publicly, but this is one of the cases where this happens" (Q 56).

15.  We received evidence from several witnesses criticising the IAB for a lack of independence. Open Europe argued that the appointment of board members by the President of the Commission stripped the Board "of the vital independence it would need to seriously pick up the fight against the steady stream of new regulations" (p 64). Business Europe also argued in favour of an independent Board (p 58), while the Government suggested that "a couple of non-executives could be added to its members to reinforce its independence" (p 44).

16.  Witnesses also thought that the Board might be tasked with "assessing whether the final legislative proposal properly [met] the results of the impact assessment" (Malcolm Harbour, p 60), that individual stakeholders should be able to address their opinions directly to the Board (Business Europe, p 57), and that the opinions of the Board should be binding (Business Europe, p 57; Open Europe, p 66).

17.  On the question of whether IAB opinions should be binding, Professor Radaelli argued that the current system of sending draft IAs back for resubmission is "precious learning. We may lose that kind of learning with a more adversarial posture of the Impact Assessment Board" (Q 12). The Government suggested that the role of the Board could be strengthened by its commenting on the draft IAs earlier and that "when it is unhappy with the quality of an assessment, even after revision, this should trigger an oral procedure with the College of Commissioners" (p 44).

18.  We are encouraged by the apparent success of the IAB so far. However, there are concerns that this has been the result of the quality of its current board and that this may not continue. Any move to increase the independence of the IAB, for instance by including non-executives, should be done carefully to ensure that the expertise of the Board is preserved.

19.  Purely measuring resubmission rates is not sufficient to determine the quality of impact assessments, and an independent assessment of their conformity to the Guidelines may be warranted.

How an Impact Assessment is produced

20.  Impact Assessments are produced by the lead service for each proposal, in consultation with the IAB and interested parties from other services, through an impact assessment steering group (IASG). Dr Italianer described this as "a fairly elaborate process" (Q 58). The Impact Assessment Guidelines recommend that the steering group should be set up early in the legislative process. Every proposal envisaged as forming part of the Commission Legislative and Work Programme (CLWP) should be accompanied by a "Roadmap" setting out the scope and methodology of the impact assessment (or an explanation of why one is unnecessary), and addressing issues such as timing and the composition of the steering group. This should be done before the CLWP is produced in order to allow the production of the IA itself in a timely fashion.[10]

21.  With regard to the involvement of several Directorates General in the IASG, Professor Radaelli argued that it had "made a virtue out of a vice. The vice is the natural suspicion that each DG has for what the other DGs are doing. The virtue is that with an impact assessment procedure they have to speak the language of evidence-based policy" (Q 6).

22.  The Commission places great importance on the production of the IA by those who are also developing the policy. Dr Italianer explained that it "is done in parallel with the development of the proposal so there is a kind of cross-fertilisation between the analysis and development of the proposal" (Q 58).

23.  Dr Italianer was keen to stress that "[t]he idea behind an impact assessment is that it is an aid to decision-making although it should not replace decision-making … The objective is to give an overview of the various possible policy options and their impact so that the decision-makers, the policy-makers if you like, can take an informed decision" (Q 58).

24.  On the content of the IA, Professor Radaelli suggested that "there is little point in pushing towards predictive impact assessments, something where everything is costed to the last euro, because we know that regulation at the EU level is a hypothesis … that has to be implemented by the Member States via transposition and then via administrative action" (Q 6). A practical example of this, in relation to the current proposed Regulation on Biocides, was given by Steve Coldrick of the Health and Safety Executive:

    "there is a lack of transparency about how some of their figures are estimated … [We also] have doubts about the credibility of some of the baseline assumptions from which cost savings are estimated … For example, cost savings in data sharing are based on investments in animal testing of somewhere between €7 billion and €13 billion, which seems implausible when you consider that the total size of the market is around €1.5-3 billion per year … Then thirdly, although there is a mention of small and medium sized enterprises in some policy areas and examples of individual level impacts, there is not enough information to gain an overall picture of how small and medium sized enterprises will be affected by all policy areas, and so by the regulation as a whole" (Q 80).

25.  Taking a wider view, the Minister for Better Regulation, Ian Lucas MP, told us that "There are impact assessments that have been made that have been very helpful to us … but I do not think that all of the impact assessments that have been made at the present time are of sufficiently high quality" (Q 90).

Which proposals should be accompanied by an IA?

26.  The Impact Assessment Guidelines do not define specifically which proposals are liable to an IA: this is decided by the Secretariat General each year. However, they do state that IA will, in general, be necessary for "all legislative proposals of the Commission's Legislative and Work Programme (CLWP) and for all non-CLWP legislative proposals which have clearly identifiable economic, social and environmental impacts … and for non-legislative initiatives … which define future policies".[11] IAs should also be produced for comitology measures[12] likely to have significant impacts.

27.  Some of our witnesses claimed that these principles were not being observed. The Government stated that "there have been occasional examples where an impact assessment has not accompanied a significant proposal" (p 43). The Minister explained in his oral evidence that they were referring in particular to a proposal on electronic VAT invoicing "that we think is a significant proposal which could actually bring about savings of €18 billion across the European Union" (Q 91).

28.  Professor Radaelli said that "[s]ome proposals that are in the annual legislative programme escape impact assessment whilst others are added on. Thus, there is no purpose in having some criteria that then you do not use in real life" (Q 2). Dr Italianer defended the performance of the Commission, claiming that "as far as I know, the only items that escape impact assessments are those items that are either some kind of report without any policy proposals or that are consultative documents like Green Papers which, by definition, are the start of the consultative process" (Q 69). The Commission would like to see IAs performed on any proposal with a "significant impact or that is sensitive in a political sense" (Q 69).

29.  With regard to IAs being performed on items which were not included in the CLWP, Dr Italianer suggested that this might be necessary "for instance in the area of financial regulation, which is a very hot topic and which we could not foresee when the work programme for this year was being prepared" (Q 69). Other witnesses have criticised the Commission for not having produced adequate IAs of proposals arising out of the recent financial crisis (City of London Corporation, p 58; Sharon Bowles MEP[13]).

30.  Professor Radaelli suggested that the fault lay with the principle itself, of trying to determine which proposals require an IA by reference to their inclusion in the CLWP: "There is little point in doing impact assessments of an average study, or to look in detail at costs and benefits of pilot projects, white papers, and framework communications" (Q 2). The need for an IA is meant to be determined according to the principle of proportionate analysis, that is, the depth of the assessment should reflect the significance of the proposal. Professor Radaelli criticised the revised Impact Assessment Guidelines on this issue:

    On pages 15 and 16 they seem to argue that it is the legal nature of the option that suggests the level or depth of analysis, whereas proportionality should be impact driven and cost-benefit driven. The guidelines seem to suggest that if you have a comitology issue, then you have this kind of analysis; if it is self-regulation, you need another type of analysis—the legal nature of the instrument seems to dictate the depth of analysis, which does not make much sense in an IA framework" (Q 10).

31.  In their written evidence the Commission argued that

    "the need for an impact assessment on a European initiative [cannot] be easily established on the basis of objective ex ante (quantitative) criteria … The Commission's integrated approach to impact assessment requires that even impacts that cannot be easily quantified/monetised, or may be limited in their total size, should nevertheless be fully considered and analysed if they have important repercussions for specific groups, sectors or regions" (p 24).

32.  The broad consensus among our witnesses was that IAs should be produced wherever there was likely to be a significant impact, but they differed in the details of their suggestions. Tina Sommer of the Federation of Small Businesses (FSB) thought IAs should be for both legislative and non-legislative proposals, pointing to the CE standard[14] on enhanced supply-chain security: "It is not a law; it is a standard which is supposed to be voluntary but as such it does not have an impact assessment and as such it does not measure what it does to small business" (Q 17). She suggested that the test should be whether there would be an impact on small business and, if so, "we definitely need an impact assessment" (Q 17). By contrast the British Chambers of Commerce argued that "Impact Assessments should be targeted only at legislative instruments: regulations and directives" (p 55). Business Europe suggested impact assessments should be conducted on "all initiatives, including decisions taken by comitology committees, notices and guidelines and decisions regarding international agreements" (p 57). The Minister hoped that the Commission would "ensure that, in every significant case, in every proportionate case, the assessments are made" (Q 91).

33.  Of particular interest was the application of IA to comitology proposals. Professor Radaelli suggested that this was important because "in comitology we get a bit closer to the specificity of the rule, the particular features of the regulatory regime, and so on; and therefore it is easier then to reason in terms of cost-benefit and look at who is affected and how" (Q 2). Most witnesses, as described above, argued that the main consideration should be the significance of the proposal, rather than its origin. For instance, the Minister said "I think that any significant proposal that comes forward should be subject to impact assessment, whether it is through the comitology process or through the Commission itself" (Q 95).

34.  Dr Italianer referred to the Framework Directive on Ecodesign as resulting in comitology proposals which "have an economic impact where it would be useful to do an impact assessment", but he warned that "it would be going a bit too far if all comitology proposals were accompanied by an impact assessment given their sheer number. In 2008, for instance, we had 1,258 comitology proposals" (Q 69). The Commission said it was "currently examining how to identify where such proposals would benefit from impact assessment" (p 24).

35.  We agree that impact assessments should be performed wherever a proposal is likely to have a significant impact. Particularly with regard to comitology proposals, there would be value in further work to determine which measures are, and are not, accompanied by an impact assessment, and whether, in practice, the selection is appropriate.


36.  The 2009 Impact Assessment Guidelines suggest Commission services should base their IAs on

    "information gathered from stakeholders (hearings, conferences), and results of consultation documents such as Green Papers. In many cases you will have to rely on data available at national or regional level in the Member States. You may need the support of Member States and/or stakeholders to identify and use these data, and you should seek this support as early as possible."[15]

37.  The Guidelines call for Roadmaps to be produced as soon as it seems likely an item will be included in the Commission Legislative and Work Programme (CLWP), and "[a]s the Roadmaps for CLWP items are published in parallel to the CLWP, i.e. at a relatively early stage in the planning process, you should encourage stakeholders to examine these and to give early feedback on your plans for the IA."[16]

38.  Consultations are supposed to include the following key elements[17]:

  • Clear, concise consultation documents
  • Unambiguous questions and problems
  • Consultation of all relevant target groups
  • Sufficient publicity
  • Sufficient time for participation: not just the minimum eight-week period
  • Published results
  • Acknowledgment of responses
  • Feedback

39.  Four themes emerged in our discussion of consultation: the deadline, publication of draft IAs, the ability of SMEs to engage with the process and the weight given to responses from various bodies.

40.  The Minister suggested that the eight-week consultation period "is very short … it is a very demanding deadline for small businesses" (Q 115). The British Chambers of Commerce suggested that the minimum period should be extended to 12 weeks (p 56). The Commission said that departments should extend the deadline for "complex or sensitive proposals" (p 26), but we have not seen evidence as to how often this actually occurs.

41.  Professor Radaelli suggested that there was a problem with the publication of the IA simultaneously with the proposal. It was only available for consideration (beyond the Impact Assessment Board) "when the College of Commissioners gives the green light to a proposal" (Q 6). The Government agreed. They argued that "there is scope for greater stakeholder engagement with the development of impact assessments, particularly by allowing the opportunity to comment on draft versions" (p 44).

42.  Open Europe and Business Europe both argued that draft IAs should be made available, on the grounds that this would enable interested parties to establish which stakeholders had been consulted (Open Europe, p 65) and enable stakeholders to address concerns directly to the Impact Assessment Board (Business Europe, p 57).

43.  However, Professor Radaelli warned that publication of draft IAs might result in "some European Parliament quarters representing special interests (and many pressure groups of course) [abusing] procedures for negative political reasons" (p 3).

44.  Another common theme was the difficulty of engaging with the consultation process, particularly for small businesses. The FSB pointed to SMEs' "difficulty understanding regulatory language and Euro-jargon" (p 14). Tina Sommer of the FSB suggested that proposals themselves were "extremely difficult to read" but that a proposal, rather than an IA, "probably has to be in a legal language" (Q 17). Open Europe described as "laughable" the idea that members of the public would be able to understand an EU IA (p 65).

45.  The FSB told the Committee that they produced summaries of the consultations for the benefit of their members and that their members were able to submit their own responses (QQ 29, 31). But this raises a further problem for small businesses. Dr Italianer told us that "[t]he idea is that all relevant stakeholders are involved" in the consultation process (Q 32) but it was not clear how feasible this was. Tina Sommer raised a concern over the use of responses from individual businesses and business representatives: "If an organisation does not consult with its members, the actual small businesses, they can say what they like. How does the Commission know that they are really representative?" (Q 31) The new Impact Assessment Guidelines advise that "[n]ot all interest groups are equally able to take part in consultations or express their views with the same force … you may need, therefore, to make specific efforts to ensure that all relevant stakeholders are both aware of and able to contribute to the consultation."[18]

46.  Dr Italianer told us that the Commission "actually distinguish between two types of contributions. One is individual contributions, and this can be an individual SME or it can be a multi-national company, or there could be a contribution from an organisation that claims to be representative of a group of stakeholders, like for instance a business organisation" and that "the only thing we require is that when in an impact assessment the consultation is being discussed a balanced view is given that covers all the stakeholders" (Q 72).

47.  The burden of participating in consultations was also a concern to some of our witnesses. The FSB said that "small businesses do not have time to respond to consultations" (p 14). In relation to regulation generally, Steve Coldrick of the HSE argued that the provision of data is expensive and that streamlining the process will not automatically "enable small and medium sized enterprises to succeed in a regulated environment that requires a lot of data" (Q 87).

48.  The Government also produce impact assessments of EU proposals, designed to assess the impact on the UK, rather than the EU as whole. The Health and Safety Executive has had particular problems in gathering data for the UK impact assessment on the Biocides Regulation, which we discuss in greater detail in paragraphs 67-70. When we asked why the consultation had proved problematic, Robin Foster suggested that IAs might be too "high level" for SMEs engage with, that is, they deal with EU or UK-wide issues and do not always obviously apply to the concerns of a particular small enterprise (Q 83). We put this to the Minister who agreed and added that "it is very difficult for a small business to keep abreast of what all the proposals that are going around are from legislative bodies" (Q 114). He went on to suggest that the SME Envoy[19] has an important role in helping SMEs to engage with "the behemoth that is the European Union" (Q 115).

49.  Further work could be undertaken to establish, for a representative sample of proposals, the length of consultation period actually applied to each proposal, at what stage in the process it was launched, how widely it was disseminated, how many responses were received, and from whom.

The SME Test

50.  Our discussion of consultation was focussed on the experience of small businesses, mainly because it seems that they have more trouble engaging with the process than larger organisations. Another aspect of the IA system relating to small businesses is the "SME test" in which "[t]he IA should analyse whether SMEs are disproportionately affected or disadvantaged compared to large companies, and if so, options should cover alternative mechanisms and flexibilities in approach that might help SMEs to comply."[20]

51.  Dr Italianer explained that the IAB "look at this systematically. You will also find in the annual reports of the Board that this is one of the items that is being looked at, but the proposals do not always lend themselves to really single out SMEs" (Q 70).

52.  The Minister thought "the fact of the SME test is a very positive step forward. It is very early to assess it as far as the EU is concerned" and "I cannot come up at this stage with concrete examples of what it has been able to achieve" (Q 112).

53.  Tina Sommer of the FSB also welcomed the introduction of the test (Q 30), but written evidence from the BCC warned that "its effectiveness will depend on the extent to which it is able to quantify or even identify additional cost" (p 56).

54.  We welcome the SME test, but it is too early to assess how well it works. We recommend that the inclusion of the test is assessed in the near future to determine whether it adds value.

Administrative burdens

55.  As part of the Better Regulation agenda, the Commission has been pursuing a policy of reducing administrative burdens, that is, the costs to businesses of complying with EU information requirements. In 2007 the European Council endorsed a target of 25% administrative burden reduction by 2012.

56.  An assessment of the anticipated administrative burden should be included in the impact assessment. The Commission Impact Assessment Guidelines explain that

    "[t]he assessment of … administrative burden … should begin with a full mapping of information obligations for each of the options. This mapping should show how policy options differ in terms of information obligations. You should then determine which are likely to impose significant administrative burdens (usually through a qualitative assessment of the likely number of entities concerned as well as the frequency and complexity of required actions)."[21]

57.  EU impact assessments are intended to be "integrated", that is, to take into account the likely environmental, social and economic costs and benefits. Professor Radaelli expressed concern that the focus on administrative burdens could undermine the "integrated" nature of IAs. He warned that the "emphasis on administrative burdens … pushes us back to the old logic of special assessments. It disintegrates the logic of integrated impact assessment" and risks the creation of a "legal kebab" in which the various areas of assessment are included separately in the IA but not considered as a whole (p 2 and Q 4). He argued that administrative burdens should be assessed in an IA "only when and how they are relevant to the overall appraisal of the impact of the proposal, they are not a separate category of costs" (p 2).

58.  The Minister disagreed. "I do not accept it. I think that administrative burden reductions are very, very important" (Q 103). With regard to the 25% reduction campaign, he warned that "[t]he steps forward that the Commission have made in recent years have begun to be taken on board by the European Parliament but perhaps less so by the Council, and I think that the progress that the European Union will make will be constrained by the lack of buy-in right across the board" (Q 108).

59.  Dr Italianer defended the "integrated" nature of IAs, saying that "[w]e are generally satisfied that [the economic, environmental and social] aspects are being covered, although we are trying to improve the assessment of the social and environmental impacts because this is not always easy to quantify" (Q 62).

60.  Evidence from some of the business representatives argued that costs to businesses should be taken more seriously in IAs. The FSB argued that "regulatory pressure throughout the entire regulations chain should be taken into account. This means that as well as administrative burdens there should be attention on the compliance costs" (p 14). The British Chambers of Commerce argued that IAs should "take into account the cumulative burden that regulation can impose in areas like employment" (p 55).

61.  The administrative burdens campaign is worthwhile and the inclusion of an administrative burdens section in EU impact assessments is a positive move. We recognise that an over-emphasis on burdens might affect the balance of an integrated impact assessment but we have seen no evidence to suggest that this is actually happening.

7   SEC (09) 92 Back

8   If the IAB is unsatisfied with the quality of an impact assessment, it requests that the Commission service responsible resubmits an improved version for consideration. Back

9   Op. Cit. p 6 Back

10   Op. Cit. p 8 Back

11   Op. Cit. p 6 Back

12   Measures adopted by the Commission under a power given in a legislative act of the Council or Council and Parliament, for the purpose of making detailed subordinate provisions. A comitology measure is subject to scrutiny by a committee of the representatives of the Member States. Following the coming into force of the Lisbon Treaty "delegated legislation" is no longer subject to a comitology procedure, but for the purpose of this report the same considerations apply to it. Back

13   European Union Committee, 3rd Report (2009-10): Directive on Alternative Investment Fund Managers (HL Paper 48), QQ 375-384 Back

14   The "CE" marking, which stands for "Conformité Européenne", may be placed on products conforming to certain standards. Back

15   Op. Cit. p 17 Back

16   Op. Cit. p 18 Back

17   Op. Cit. p 19 Back

18   Op. Cit. p. 19 Back

19   The SME Envoy has been appointed by the Commission to facilitate communication between the Commission and small businesses. The Envoy is currently Françoise Le Bail, who is also Deputy Director-General at DG Enterprise and Industry. Back

20   Op. Cit. p 39 Back

21   Op. Cit. p 41 Back

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