EUROPEAN COMMISSION
Strasbourg, 22.11.2016
SWD(2016) 389 final
COMMISSION STAFF WORKING DOCUMENT
Synopsis Report summarising the main results of the consultation on the new European Consensus on Development
Accompanying the document
COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS
Proposal for
a new European Consensus on Development.
Our World, our Dignity, our Future
{COM(2016) 740 final}
{SWD(2016) 387 final}
{SWD(2016) 388 final}
TABLE OF CONTENTS
1.
Background on the Consultation (Strategy, Method and Target Groups)
2.
Response to Consultation and Participation in Outreach Activities
2.1.
Online Public Consultation (EU Survey)
2.2.
Dialogue with EU Member States
2.3.
Dialogue with the European Parliament
2.4.
Dialogue with the European Economic and Social Committee
2.5.
Dialogue with Partner Countries and multilateral institutions
2.6.
European Development Days
2.7.
Dialogue with Civil Society
2.8.
Private Sector
2.9.
Dialogue with Think Tanks and Academia
2.10.
Use of social media
3.
Overall Messages from the Consultation Process
3.1.
Issues
3.2.
Approaches
3.3.
Means of Implementation
4.
Further input to the implementation of the 2030 Agenda
5.
Next steps
Staff Working Document
Synopsis Report summarising the main results of the consultation on the new European Consensus on Development
1.Background on the Consultation (Strategy, Method and Target Groups)
The Commission has sought to ensure that the process towards a new European Consensus is open and inclusive. A number of outreach and consultation activities have been undertaken since the international community's adoption of the 2030 Agenda for Sustainable Development at the UN Summit in September 2015. These have been aimed at gathering views from a wide range of stakeholders on how EU development policy might respond to the Agenda, taking full account of key global trends, and contribute to other important related international agreements. As a side-benefit, the consultation also helped to raise the level of awareness and engagement amongst stakeholders on the future direction of EU development policy.
The consultation strategy included a wide range of consultation opportunities, centred around an open, internet-based public consultation, as a principal method of consultation with civil society and the public. This was complemented with targeted stakeholder consultations with major stakeholder groups. These consultations allowed more focused interactions with key stakeholders and tapped experience and suggestions for policy orientations very efficiently. In the end, many more consultation and outreach opportunities were arranged than originally considered feasible in the time made available. Consultative discussions were held with different stakeholders. EU Member States, other EU institutions such as the European Parliament, other EU bodies such as the European Economic and Social Committee, partner governments, international organisations and financial institutions, civil society organisations and the private sector, think tanks and academia contributed to the consultation process. Further outreach was sought via social media activities to increase the level of awareness on the on-going reflection on reshaping European development policy.
An adequate overview of relevant material was gathered from stakeholders during the consultation process, and the main orientations were shown to be very consistent at key events and in all consultation windows.
2.Response to Consultation and Participation in Outreach Activities
The following section sets out the principal components of the consultation strategy and the main stakeholder groups consulted.
2.1.Online Public Consultation (EU Survey)
A public on-line consultation on EU Survey was launched on 30 May 2016 for twelve weeks until 21 August 2016. The survey was accessible in all 24 official languages of the EU. The public consultation was intended to allow a wide range of stakeholders to state their views on some aspects of the 2030 Agenda as a whole and more in details on how EU development policy should respond to the range of landmark 2015 summits and conferences, and also to the rapid changes happening in the world, taking account of the role of development policy within the context of EU external action as framed by the Lisbon Treaty. In particular, respondents were asked what they considered as the main global challenges and trends; what they considered priority areas for future action for EU development policy (what needs to be done); what means of implementation were required to get there; how to involve different actors (including for working better together); and how to keep track of progress. Nearly 200 contributions were received from 54 countries in 11 EU languages; including from EU Member States, multilateral institutions, the private sector, universities and think tanks, and civil society. For for more details on the respondents please refer to the Final Report by the Consultants Aide a la decision economique / ADE "Analysis of the external consultation on the new Consensus".
A large majority of respondents highlighted the existing linkages between the different sustainable development global goals and the importance to take a holistic and integrated approach while addressing the 2030 Agenda, encompassing the social, environmental and economic aspects of sustainable development. Respondents also emphasized the central place for poverty eradication in EU development policy, with appropriate links to other policy areas. In addition, respondents noted the importance to diversify and adapt the EU aid modalities to the new global challenges as well as the need to align the new Consensus with the Addis Ababa Action Agenda, the 2030 Agenda and other international agreements. See further analysis in Part 4 on “Overall messages for consultation process”, which takes account of both the online public consultation and the other consultation activities.
2.2.Dialogue with EU Member States
There has been regular interaction and consultation with EU Member States towards the new Consensus at different levels over the past year. At their informal meeting on 10 December 2015, Development Ministers discussed on how to take further the EU development cooperation policy in the light of the 2030 Agenda, including the possibility of a new European Consensus for Development. The Commission then formally presented its intention to come forward with a proposal for a new Consensus at the meeting of the Council (Foreign Affairs/Development) of 12 May. The informal meeting of Development Ministers on 12 September 2016 confirmed support for the main orientations of the preparatory work. Many Member States also called on the Commission to come forward, in addition to the proposal for a new Consensus, with an overarching initiative on EU action in relation to the 2030 Agenda.
Discussions at Ministerial level have been supplemented by meetings of officials in Council Working Groups. A dedicated workshop on 5 July 2016 addressed issues of differentiation and the nexus between development and other external policies. Additionally, technical working groups on Policy Coherence for Development, Joint Programming and Development Effectiveness also provided useful input. All these discussions confirm that there is clear support from EU Member States to update the European Consensus on Development and that there is overall broad agreement on the main elements that should feature into a new European Consensus.
2.3.Dialogue with the European Parliament
The Committee on Development (DEVE) of the European Parliament has been actively engaged in discussions on the 2030 Agenda. The European Parliament issued a Resolution on the 'Follow-up and state of play of the Agenda 2030' in May 2016. This built on an earlier Resolution on 'The EU and the global development framework after 2015' in December 2014 and the work of a delegation of Members of the European Parliament to the New York Summit in September 2015. The Commission discussed the concept of a new Consensus at the Structured Dialogue with the DEVE Committee on 21 June 2016.
Issues that were raised at the Structured Dialogue included the importance of a strong EU voice in the implementation and follow up of the 2030 Agenda. Particular areas that were highlighted as needing to be included in the new Consensus included: the promotion of peace and justice, good governance, policy coherence for development (including in relation to tackling tax evasion and tax avoidance), the appropriate links between development and security, migration and humanitarian action and corporate social responsibility. Many Members of the European Parliament also looked forward to the Commission's overarching initiative (as announced in the Commission Work Plan 2016) on EU action in relation to the 2030 Agenda.
The Commissioner in charge of International Cooperation and Development also led an exchange of views with the DEVE Committee on the proposal for a new Consensus on 27 September 2016, where he presented some of the main contours of the Commission's thinking on the new Consensus and invited views. Members of the European Parliament raised the various nexus' between development and other policy areas, including climate, humanitarian, resilience, migration and security issues and the importance of policy coherence. A number of Members of the European Parliament stressed the importance of keeping EU commitments on aid, including on 0.7% of Gross National Income (GNI) for Official Development Assistance (ODA). Issues around private sector accountability, the role of civil society and civil society space in developing countries were also raised. The session formed part of the DEVE Committee's preparatory work on an own-initiative Opinion on the Revision of the European Consensus on Development (2016/2094(INI)).
2.4.Dialogue with the European Economic and Social Committee
A number of consultative discussions were held with the European Economic and Social Committee (EESC), including during the development of the Opinion ‘2030 Agenda –a European Union committed to sustainable development globally’ (REX/461), at a conference on 7 July 2016 ‘Next steps for a sustainable European future - Reforming Europe, implementing SDGs’ and at a REX Section debate on the review of the European Consensus for Development on 19 July. The Commission also participated in an EESC side-event at the High Level Political Forum in New York on 19 July on civil society as an active player in the implementation of the 2030 Agenda. In addition, the EESC has issued two related Opinions (e.g. ‘A European Sustainable Development Civil Society Forum’ (NAT/678) and ‘Sustainable development: a mapping of the EU's internal and external policies’ NAT/693)). EESC views on the Consensus stress the issue of policy coherence for sustainable development and EU leadership and credibility in the overall implementation of SDGs through internal and external policies. The EESC is keen to avoid a silo approach, supports having a new Consensus on Development and stresses the importance of civil society engagement in the implementation and follow-up and review of the 2030 Agenda.
2.5.Dialogue with Partner Countries and multilateral institutions
Views from partner countries are an important element of the consultation process. There were four outreach rounds during the negotiations for the 2030 Agenda that aimed mainly at listening and understanding developments in the positions of our partners and issues of key importance to them, which provided information that remains relevant also for the implementation phase. Also after the adoption of the 2030 Agenda, EU Delegations were encouraged to engage further with their host countries (or International Organisations) on implementation plans, and to reflect on potential areas of particular common interest for the implementation of the 2030 Agenda. During the public consultation EU Delegations have also been mobilised: (i) to feed in to the Commission's reflection by contributing perspectives from the field; and (ii) conducting outreach in partner countries, with regional organisations, governments, local authorities and civil society, and feeding back the results to headquarters.
Several discussions with representatives from partner countries, international organisations and international financing institutions have taken place throughout the year at different levels.
A Commission-organised side event “A renewed European development policy in response to the UN 2030 Agenda: revision of the European Consensus on Development” at the High-Level Political Forum on Sustainable Development on 18 of July 2016 in New York attracted more than 100 people from different constituencies (partner countries, representatives from international organisations and financial institutions, civil society and private sector). The frank and interactive discussion provided useful material for reflection on the new Consensus. Main issues raised were differentiation, use of country systems, capacity building for integrating the SDGs into national development plans, stronger policy coherence, nexus security-development-migration and the need to mobilise domestic resources. The speakers also emphasised support for using development cooperation to leverage public and private finance.
2.6.European Development Days
The 10th edition of the flagship European Development Days (EDDs) on 15 and 16 June 2016 took as its overarching theme the implementation of the 2030 Agenda and the SDGs, helping ensure a broad and in-depth discussion of the implementation of the 2030 Agenda.
An estimated 6000 participants from over 140 countries attended the event, representing a wide variety of sectors: EU institutions, Member States, civil society organisations, private sector, think tanks, development agencies, citizens and academia. Many partner countries were represented at political level, including 7 Heads of State and Government, the UN Secretary General, the President of the World Bank and 7 United Nations high level officials. Youth and women leaders were especially well represented. 11 Members of the College intervened at the various sessions.
Sessions were organised around the 5 Ps of the 2030 Agenda: people, prosperity, planet, peace and partnership. Several sessions addressed key issues for a new Consensus. The EDDs were therefore a unique opportunity to collect ideas and grasp the orientation of the debates towards the new European Consensus. The event clearly showed the development community’s motivation and commitment to move ahead quickly from words to action, and to embrace the 2030 Agenda’s new way of thinking and working together. The fact that the 2030 Agenda is universal and should be owned by all in an inclusive way was welcomed. There was a broad recognition that SDGs are interconnected and of the importance of linking different challenges together. Peace, security, migration, climate change and humanitarian aid therefore had a significant place in the discussions. Everyone agreed that all stakeholders, notably the private sector, young people, local communities and those most difficult to reach should be included in multi-stakeholder partnerships in order to achieve the SDGs and leave no one behind. Many participants also stressed the need to hold actors accountable for their actions (and inactions).
A breakfast session was also held, organised by the European Commission and the European Think Tank Group. It was well attended by high-level participants from diverse backgrounds (European Parliament, United Nations, think tanks, NGOs, private sector, development agencies and Member States). Participants underlined the need for the new consensus to integrate the wide variety of country situations (fragile countries, MICs) and issues (including poverty, but also global public goods, financing, policy coherence). Participants also stressed the need to cooperate with all partners in order to pool together our competences, avoid working in silos, remain open to non-traditional actors in development, in particular, the private sector. Better accountability for aid and continued attention to corruption were also highlighted.
2.7.Dialogue with Civil Society
Existing dialogues have been used to encourage and invite CSOs, their associated platforms, philanthropic organisations/foundations and the private sector to contribute. The greatest opportunity to engage with the civil society on the 2030 Agenda and possibilities for the new Consensus has been the European Development Days (details see 3.6.).
The Policy Forum for Development (a structured dialogue platform which brings together civil society organisations (CSOs) and Local Authorities with European institutions and bodies) was invited and encouraged to contribute to the online public consultation. On 19 October 2016, a high-level consultative discussion with European civil society was organised by the European Commission in Brussels. Around 80 CSO representatives from 63 different networks participated in the event, covering most EU national platforms and encompassing all categories of CSOs, including the private sector, cooperatives and trade unions.
The Commission has received and reviewed carefully a range of input papers circulated spontaneously by NGOs and civil society actors and platforms.
2.8.Private Sector
There have been several debates dedicated to the role of the private sector, including during the EDDs and the 5th EU-Africa Business Forum on 15 and 16 June 2016. These discussions aimed to combine entrepreneurs with policymakers and multilateral actors to discuss the private sector's contribution to the SDGs. There was agreement that national resources mobilisation was not enough and that the private sector will need to play a much more prominent role in financing investments which, in turn, will require partner countries to create an enabling environment for innovative financing solutions. The private sector, which provides about 90% of employment, is key for inclusive sustainable growth and prosperity. There is therefore a need to work with the private sector and local authorities, develop training programmes, transfer skills, set up public-private partnerships and adapt to national contexts. Social enterprises can form part of an innovative financing approach and should be included in the mainstream private investment climate. Creating an environment where both public and private sector have a regular dialogue, identify constraints and remove them was also highlighted as key in situations of fragility. Further encounters with the private sector have taken place during the Africa Forum II in Tallinn on 25 October.
2.9.Dialogue with Think Tanks and Academia
Leading representatives of think tanks and academia were invited and encouraged to contribute to the open consultation as well as requested to provide input on specific areas. Think Tanks have also contributed by organising dedicated seminars such as a side-event at the EDDs (“Change-makers breakfast” in cooperation with DEVCO). Several events have discussed the link between the implementation of the 2030 Agenda, including in the field of development policy, and the preparation of the Global Strategy for the EU's Foreign and Foreign Security Policy (including a conference in Berlin on 1-2 March 2016 organised by the European Think Tank Group on "The Future of EU External Action", and a conference in Rome on 7 March 2016 on "The EU and the global development framework: A strategic approach to the 2030 Agenda"). These events called for ensuring coherence with the Global Strategy and the implementation of SDGs, including the new Consensus, and to strengthen a joined-up approach between the EU and its Member States.
A consultative discussion with the Friends of Europe’s Development Policy Forum was held on 27 September 2016. In addition a series of events organised by the European Think Tank Group and partners, involving the participation of the Commissioner in charge of International Cooperation and Development, took place in October 2016 (Warsaw on 6 October, organised by the Polish Institute of International Affairs (PISM); Munich on 14 October, organised by the Hanns Seidel Foundation; Dublin on 18 October, organised by the Institute of International and European Affairs; Paris on 24 October, organised by IDDRI; and The Hague on 28 October, organised by ECDPM).
2.10.Use of social media
A twitter chat (eudevchat-social-campaign) was launched on 30 June 2016 and was an opportunity for direct questions from the public on the new Consensus. Topics raised included: gender issues (women and girls' empowerment and gender equality), youth and children, poverty and marginalization, malnutrition, population resilience, capacity development, remittances and diaspora, empowering local people and field offices, aid transparency and development effectiveness.
11,750 people saw the #EUDevchat tweet about the consultation on how to shape the future EU development policy; leading to 178 engagements. Similarly, the EU’s Facebook post reached 15,749 people and gave rise to 201 reactions, comments and shares for the English version; the post in the French version reached 11,973 people and gave rise to 77 reactions.
3.Overall Messages from the Consultation Process
The online consultation (see above under 3.1.) and consultation activities (see above under 3.2. – 3.10.) have confirmed a broad support among stakeholders on the importance of having a new European Consensus on Development. They contributed with messages on crucial elements that the European development policy should take further to respond to the 2030 Agenda, in the light of ongoing global challenges and trends.
Throughout the consultation process there was general support that the new Consensus should address together poverty eradication, sustainability and respect for the environment and economic growth – not as competing priorities. It should promote partnerships with countries at all stages of development and make sure the benefits of our actions are spread more evenly, helping to address inequalities within and between countries. It should put the focus on women and youth – not just as beneficiaries, but as agents of development. And it should strengthen the links between development effort on peace, humanitarian and migration management.
There was also a common understanding that the EU and its Member States need to put all the tools at their disposal to good use. The new Consensus should signal a shift towards more effective mobilisation and use of resources. It should signal a move beyond just measuring aid, towards a culture of results, transparency, inclusive follow-up and review.
In particular, from the variety of topics of discussion that arose from the outreach meetings, the feedback to the online public consultation and the twitter chat, three main clusters of concerns could be discerned, addressed in a balanced manner in the responses:
i) the issues to be tackled by the new EU development policy (‘issues’),
ii) the approach to be used (‘approach’), and
iii) the manner in which to tackle them (‘implementation: how’).
Following aspects/suggestions raised by stakeholders have been reflected in the policy framework outlined in the Communication.
3.1.Issues
Responses from EU MS and civil society made a clear call for the Commission to push forward with the implementation of the 2030 Agenda across all policies, including action through development policy specifically.
Respondents identified a broad range of trends, which could impact on development policy; issues often raised included inequality, demography, migration, climate change, environmental issues, water, good governance and security, amongst others. A range of contributors agreed that the breadth of the 2030 Agenda demanded a broad and comprehensive approach, balancing the social, environmental and economic aspects of sustainable development.
Stakeholders stressed the continuing importance of the eradication of poverty and hunger, tackling discrimination and the promotion of human rights.
One of the topics most mentioned was migration. A number of Member States and civil society stakeholders called for development cooperation to tackle the 'root causes' of forced migration and displacement, whilst some cautioned against what they describe as the potential 'instrumentalisation' of development for EU's migration or security objectives. Respondents also considered it important to address migration in a wider development contex and called for coherence between migration, security and development policies (most often cited together) but also trade (e.g. on market access and sustainability) and justice policies.
A significant proportion of stakeholders raised issues around good governance, peace and security (addressing corruption and tax evasion, addressing root causes of conflict and fragility, the importance of conflict prevention, building resilience and a coherent response, shrinking space for civil society). Many respondents, and in particular responses for EU Member States made a very clear call, echoed by others, for stronger coordination between development and humanitarian action (including help build population's resilience to disasters and crises and enable them to better manage risks).
Addressing gender inequality and implementing the Gender Action Plan was an important part of a number of Member States and civil society responses. A number of contributors raised about the role of women in development and gender equality and pressed for EU development policy to take account of the welfare of young girls.
A number of respondents also raised the importance of tackling issues faced by the youth, including the protection of children and creation of employment opportunities for youth.
On inequalities in general, a number of stakeholders raised the issue of data disaggregation and capacity building for statistics in order to leave no one behind. Private sector inputs stressed the potential of the digital revolution.
Global public goods was another issue frequently raised by the respondents. Discussions focused mostly on climate-related issues and environmental degradation (e.g. water) and the interlinkages to other policy issues and on need for a new way of thinking and working together.
The proposal for a new European Consensus has to a very large extent taken into account the above considerations and suggestions. It has sought to present these issues in a manner that takes inspiration from the Preamble of the 2030 Agenda and the need to link people, prosperity, planet and peace; it strengthens the nexus to peace, security, migration and climate change while retaining an appropriate focus on poverty eradication; and it puts emphasis on drivers such as youth and gender equality.
3.2.Approaches
The discussions and inputs overwhelmingly resonated with a key feature of the 2030 Agenda for Sustainable Development, which is the systematic call for universality, for working together, across countries, across actors, across sectors and across policies.
Inclusiveness has been raised in different discussions and inputs, in particular the need to involve all stakeholders (e.g. local authorities, youths, marginalised groups, regional organisations) in the planning and implementation of the 2030 Agenda. A multi-stakeholder approach with the whole spectrum of actors has been considered as cornerstone of a global partnership. Coherence and complementarity should be actively ensured. Respondents called for the EU's approach to be driven by its fundamental values, including freedom, justice and human rights.
The private sector was often held up as a crucial player in the development landscape. Many contributors thought it vital to engage the national and international private sector in the implementation of the 2030 Agenda and to develop new business models. Calls for corporate social responsibilities and private sector accountability were often raised as well as issues around tax evasion and tax avoidance.
A number of respondents saw clear benefits associated with a stronger, collective EU approach, including through Joint Programming and joint action. A number of stakeholders also called for a more flexible set of EU instruments. EU value-added was described in terms of: the EU's broad geographical reach through its network of Delegations and Representations; the EU's influence in political dialogue (with partner countries and in international for a) and comprehensiveness of the EU's tool set and the advantages of joint, coherent and coordinated EU and MS action.
Policy coherence is at the forefront of participants’ concerns. Coherence at national level between policies in different sectors or on different themes (peace and security; fragility and security; food security, energy and water) need to be addressed as being interconnected. This was thus relevant for partner countries but also for the EU as a global actor. Stakeholders considered coherence between different parts of EU external action and between internal and external policies critical. Action in this field should include applying the EU commitment on Policy Coherence for Development, whereby the EU shall take account of the objectives of development cooperation in all policies that it implements which are likely to affect developing countries. According to the stakeholders, this should be taken further and strengthened within a broader approach to policy coherence for sustainable development.
There have also been clear calls for a strong and effective system of monitoring, accountability and review.
In line with the above considerations, the proposed new policy framework puts forward concrete actions, which sets out how the EU and its Member States can make their development cooperation more effective, for instance through joint analysis, programming and action. It includes proposal for enhanced commitments for policy coherence for sustainable development in the context of SDGs. It also outlines how development cooperation policy can contribute to an efficient and robust system of monitoring, accountability and review, which also requires improving data availability and analysis capacities worldwide.
3.3.Means of Implementation
On Means of Implementation (MoI) a number of stakeholders, called for a central place for the Addis Ababa Action Agenda: stressing the importance of policies and non-financial MoI. Several stakeholders called on the EU to support partner countries in their own efforts to promote policy coherence. The EU should also pursue greater policy coherence through bilateral and multilateral dialogue. Many stakeholders also raised the issue of the EU's commitments, including those on ODA, and recognized the potential catalytic role of ODA in mobilising other resource flows (e.g. domestic resource mobilisation, blending and leverage of private finance).
Many discussions and responses also raised the importance of the principles of development effectiveness in the implementation of future cooperation.
Finally, capacity building was a recurring theme with specific mention of the need to build capacities at decentralised levels (local actors, local authorities, even private sector) and on data gathering and assessment.
The proposal for a new Consensus puts forward ways to deliver smarter cooperation and to build stronger and differentiated partnerships – to respond effectively to the different capacities, capabilities and circumstances of our partners, and to target support where it is most needed. Least Developed Countries and fragile countries still deserve the highest concentration of ODA. At the same time Middle Income Countries also have an essential role to play in implementing the SDGs, but increasingly through different forms of international cooperation (including less-concessional financing), in terms of trade, foreign direct investment, technical and policy support for sustainable development.
4.Further input to the implementation of the 2030 Agenda
During the various discussions stakeholders also raised issues that concern the implementation of the 2030 Agenda in more general terms, for example linked to the fight against tax evasion. The stakeholders raised, among other, proposals to revisit the guidelines for impact assessments to integrate an assessment on how policy initiatives contribute to relevant SDGs which would require addressing working methods at overarching level to encompass all policies. The EU's initiative 'Collect More, Spend Better approach' helps developing countries increase the efficiency, effectiveness, fairness and transparency of domestic resource mobilisation to tackle tax evasion, tax avoidance and illicit financial flows. However, strengthening the global economic and financial governance structure has to be addressed through the relevant international fora, where these challenges are already high on the agenda. The call in some responses for fostering sustainable development through trade, which is reflected in the Consensus, in some cases falls outside the realm of development policy and into trade policy.
Furthermore it should be noted, in response to the call by some stakeholders to merge or re-design the financial instruments, that the new European Consensus on Development will be a framing political document, setting out the main orientation for the development policy of the EU and its Member States in the years ahead. Proposals for the next Multi-Annual Financial Framework (MFF) will deal with external financing instruments and the programming cycle for the post-2020 period in more detail.
5.Next steps
The findings of the consultation process have been taken into account and reflected in the proposal for the new European Consensus on Development. Upon adoption, this proposal will be discussed with the European Council and the European Parliament before being adopted as a joint statement in spring 2017. In the spirit of open dialogue the views of stakeholders during the course of these discussions and during the implementation of the 2030 Agenda will be sought.
