The EU's dependence on Russian gas: how an integrated EU policy can reduce it

July 28, 2014 - nr.26
Summary

Conclusions and recommendations

The EU needs to introduce an integrated EU energy policy as quickly as possible. The crisis in Ukraine could provoke the necessary sense of urgency among the heads of EU governments. Petro Poroshenko was elected Ukraine’s new president on 25 May 2014, and the next few months will show whether Ukraine’s elected representatives can solve the country’s constitutional and economic problems without external involvement. Russia must not be allowed to present the eastern provinces with faits accomplis by means of ‘fifth column’ activities as it did in Crimea – activities to which the EU member states are unable to respond adequately, given their fear of economic reprisals. The need for the EU to take action soon is also underlined by the relatively short time available to take measures in anticipation of possible disruptions in the supply of Russian gas this winter.

The EU leaders must be convinced that the EU’s capacity to act as a trade and political bloc would be strengthened by close cooperation, especially in such a vital field as energy, not only in word, during this month’s summit, but also in deed, when measures have to be approved in October 2014. In the AIV’s opinion, delay is not an option: there is now a window of opportunity. The ambition remains a liberalised energy market. The EU will have to go to great lengths to create this market – by connecting networks efficiently (interconnectivity and reverse flows) and making the necessary investment in the transport of non-Russian gas, the storage of liquefied gas and the diversification of gas suppliers, wherever they are located.

Reducing EU dependence on Russian gas will require considerable financial investment. The member states must realise that while not every business case will be commercially feasible some may be necessary for strategic reasons. The Netherlands has a longstanding trade and investment relationship with Russia. It would not be realistic to subordinate it entirely to the imposition of sanctions in response to the Ukraine crisis. Nevertheless, the EU must seek smart measures that exert pressure and perhaps have other positive side effects. The EU could apply its competition instruments, for example, to bring Gazprom’s activities into line with EU legislation.

On the basis of the above, the AIV has arrived at the following conclusions and recommendations.

  1. In the AIV’s opinion, the EU should urgently introduce an integrated energy strategy. The strategy should not only be based on economic and climate considerations, but also give geopolitical interests greater prominence than in the past. The Ukraine crisis has shown Europe’s political vulnerability owing to its dependence on Russian gas. It has also shown that Russia will not eschew energy when playing power politics.
  2. Before the winter of 2014-2015, the European Council must consider with priority the countries in Central and Eastern Europe that import more than 50% of their gas from Russia via Ukrainian pipelines. In the AIV’s opinion, the key areas of consideration should be interconnectivity and reverse flows, gas from non-Russian sources and strategic storage.
  3. The AIV does not favour a centralised purchasing mechanism to strengthen solidarity among the member states, as proposed by the prime minister of Poland. Such an instrument would rob the system of its flexibility, impede the liberalisation of the EU energy market and probably diminish market efficiency. In the interest of solidarity, a certain proportion of strategic stocks could be held for unforeseen shortages elsewhere. It is doubtful, though, whether this would enjoy the support of market parties in a liberalised market. The AIV is fully aware of this but it believes the final decision should be based on geopolitical considerations. The AIV recommends that the Commission study the regulations necessary for such a mechanism.
  4. In view of Ukraine’s heavy and ongoing dependence on Russian gas and its function as a transit hub for gas imports to the West, the EU and the IMF must persuade it to introduce a strategic and coherent energy policy. It must not use gas pipelines to force Gazprom to lower its prices; it must reform gas pricing, tackle corruption and lack of transparency in the Ukrainian gas industry and dramatically improve the industry’s energy efficiency. This will entail a difficult support operation requiring large-scale action and substantial funding. As well as the EU and IMF, Russia will also have to show political will. The AIV doubts that it will do so in the near future. At the same time, the EU must not close its eyes to the fact that gas transmission is an important source of revenue for Kyiv. In the AIV’s opinion, the EU (and the IMF) must follow up on the Deep and Comprehensive Free Trade Agreement (DCFTA) by supporting the diversification of the Ukrainian economy. Diversification could make up for the loss of EU demand for Russian gas piped through Ukraine.
  5. To reduce dependence on Russian gas in the longer term, the AIV would propose greater diversification of oil and gas imports (pipelines to other areas, increased LNG capacity and interconnectivity, and higher storage and reverse flow capacity). The AIV is aware that this will require deep and long-term investment. Economic feasibility, however, may not be the only driver of interconnectivity. Geopolitical considerations must also be taken into account. The EU can commit itself to increasing diversification and so achieve the desired political impact on Moscow in the short term. The increase in reverse flow capacity offers the most expedient solution in areas with dense networks. The EU should also examine the scope for deepening gas relations with established suppliers such as Norway and Qatar, as well as completing alternative gas supply routes from Azerbaijan (Tanap and TAP) and connecting Iraq and Iran to those routes after the sanctions imposed on the latter are lifted.
  6. Serious thought should also be given to the gas connection with North Africa, even though the countries in this region are a source of uncertainty as regards security and political instability. This will seriously influence the conclusion of long-term agreements. Furthermore the feasibility of producing gas in the eastern Mediterranean and imports of LNG from the US in the longer term should be studied.
  7. The European Commission (through the CEF) and the EIB have the funds necessary to support these proposed steps. The CEF funding criteria were recently revised but should be aligned even more closely to the EU’s needs and perhaps linked more strongly to the EIB instruments. Criteria such as ‘maturity of the project’ must not be applied rigidly.
  8. The AIV recommends that renewable energy grants be coordinated at EU level in keeping with the agreements applicable to the European Semester. Financial support for sustainable energy distorts competition between countries, which is at odds with the creation of a level playing field. As in the case of financial governance (compare the European Semester mentioned above), national competences (the awarding of grants) will remain intact; they will just be underpinned by a common sustainable energy policy. The common policy, including the margins within which renewable energy grants can fluctuate, should be indicative.
  9. In the AIV’s opinion, geopolitical considerations are incorrectly given secondary billing in both EU and national energy policies. The EU should consider giving the High Representative for Foreign Affairs and Security Policy and the European External Action Service power to agree the energy policy and the criteria for awarding funds from the CEF to energy projects. Furthermore, there should be a clear link with neighbourhood policy. It is also advisable that, when allocating the portfolios in the Commission and possibly establishing policy clusters, the incoming President of the European Commission take account of the High Representative’s position in the energy cluster. In the Netherlands, too, energy policy is determined primarily by economics, and thus primary responsibility for it lies with the Minister of Economic Affairs. To a large extent, however, energy policy is also a matter of foreign policy.1 The Minister of Foreign Affairs should have a prominent voice in strategic investment decisions.
  10. Finally, the AIV is aware that an integrated EU energy policy cannot be introduced overnight. It will affect the member states’ competitiveness, but, as in financial and economic policy, European governments must realise that long-term close cooperation will increase all the member states’ capacity to act. The AIV therefore recommends that the Third Energy Package be actively implemented in full in all member states, especially when it comes to the construction of vital infrastructure.

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1 The AIV made the same recommendation in a joint report with the Dutch Energy Council in 2005, Energised Foreign Policy: Security of Energy Supply as a New Key Objective, advisory report no. 46, The Hague, December 2005.

 

Advice request
Government reactions

To the President of the House of Representatives
of the States General
Binnenhof 4
The Hague

 

Date: 7 October 2014

Re: Government’s response to AIV advisory letter no. 26 ‘The EU’s Dependence on Russian Gas: How an Integrated EU Policy can Reduce it’

 

Dear Madam President,

The Minister of Foreign Affairs and I enclose the government’s response to advisory letter no. 26 by the Advisory Council on International Affairs (AIV), ‘The EU’s Dependence on Russian Gas: How an Integrated EU Policy can Reduce it’. The government generally agrees with the points made in the AIV’s letter and thanks the AIV for its efforts. The government’s response focuses primarily on the conclusions and recommendations outlined in the AIV’s letter.

During the debate of 3 September 2014, the House requested a letter on the future of the EU’s energy supply.1 The enclosed response is also intended to meet this request.

 

Yours sincerely,

(signed)

Henk Kamp
Minister of Economic Affairs

__________________________________

Government’s response to AIV advisory letter no. 26 ‘The EU’s Dependence on Russian Gas: How an Integrated EU Policy can Reduce it’

1. Introduction

In June 2014 the Advisory Council on International Affairs (AIV) issued, on its own initiative, an advisory letter on reducing the EU’s dependence on Russian gas.2 In this letter, the AIV made recommendations on action that can be taken in the near term to increase the energy security of the EU as a whole, and so contributed to the Netherlands’ input into the European Council of 26 and 27 June 2014. The advisory letter focuses on the geopolitical dimension and argues that this should play a greater role in national and EU energy policy. The European Commission issued proposals for a new energy strategy3 (EESS) on 28 May 2014, while the letter was being drafted. On the basis of these proposals, a number of short-term measures were taken by the European Council in June to enhance EU energy security for the winter of 2014-2015.4 The government’s response to these proposals was sent to the House on 17 June 2014.5

During the parliamentary committee meeting on the EESS of 18 June 2014, I undertook to send the House the government’s response to the AIV’s advisory letter prior to the European Council of October. This document fulfils that undertaking. The government generally agrees with the points made by the AIV. The letter’s contents are in line with previous reports by the AIV and the former General Energy Council, which at the time, provided the impetus for strengthening the working relationship between the Ministries of Foreign and Economic Affairs. The advisory letter contains a large number of elements that correspond with government policy. The letter therefore underpins this policy and the Netherlands’ input into the informal Energy Council of 6 October and the European Council of 23 and 24 October, where security of supply and import dependence will again be discussed. As usual, the House will receive an annotated agenda shortly before the aforementioned Councils take place.

The government’s response to the letter’s conclusions and recommendations follow below.
 

2. The AIV’s conclusions and recommendations

The AIV made the following conclusions and recommendations:

  1. In the AIV’s opinion, the EU should urgently introduce an integrated energy strategy. The strategy should not only be based on economic and climate considerations, but also give geopolitical interests greater prominence than in the past. The Ukraine crisis has shown Europe’s political vulnerability owing to its dependence on Russian gas. It has also shown that Russia will not eschew energy when playing power politics.

Government’s response:
The government endorses the importance the AIV attaches to an integrated energy strategy. At the European Council of October 2014, the government argued that decision-making on climate and energy security policy should be integrated. This is now expected to become reality. The government also recognises the prominent and increasingly important role the geopolitical dimension plays in energy policy. The Ukraine crisis, for example, could potentially affect the EU’s security of energy supply. One-sided dependence on imports has left Eastern European countries particularly vulnerable. In addition, any gas shortage in Eastern Europe would lead to higher gas prices and this would have negative consequences for the competitiveness of energy-intensive industries throughout Europe. In light of the potential risks, it is crucial that security of energy supply – and of gas supply in particular – features prominently on the European political agenda and that concrete measures are developed to improve it. European countries currently cooperate closely on security of energy supply and speak with one voice whenever necessary. 

The government would emphasise that a balanced approach is called for. While some degree of dependence on Russian gas cannot be denied, the Russian Federation for its part depends on its income from gas for a significant part of its GNP and government revenue. This interdependence makes continued efforts towards a stable energy relationship vital for both Russia and the EU.

  1. Before the winter of 2014-2015, the European Council must consider with priority the countries in Central and Eastern Europe that import more than 50% of their gas from Russia via Ukrainian pipelines. In the AIV’s opinion, the key areas of consideration should be interconnectivity, reverse flows, gas from non-Russian sources and strategic storage.

Government’s response:
Improving and increasing interconnectivity, reverse flows and gas from other sources (diversification) have been on the EU agenda for some time. Actions undertaken in that area have arisen from the Third Energy Package, the Infrastructure Package and the Regulation concerning measures to safeguard security of gas supply. The European Economic Recovery Plan has also provided fresh impetus for investment in gas infrastructure and, more specifically, for establishing reverse flows to Central and Eastern Europe.

These topics were also discussed in the recent European Commission Communication on the European Energy Security Strategy (EESS), and 33 infrastructure projects have been identified as key projects for the security of energy supply. The majority of them (27) are concerned with gas infrastructure and Central and Eastern Europe.

The government agrees with many of the ideas set forth in the Communication, with the exception of the central purchasing mechanism (see the response to recommendation 3) and the idea that the Commission might play a greater role in intergovernmental energy agreements.

The government takes a very cautious approach to strategic gas storage. Existing storage facilities in the Netherlands are intended to meet extra demand for gas during the winter, while strategic storage is intended to cover the risk of long-term disruption to the gas supply. It is vital that EU member states first fully implement existing European legislation in order to strengthen the European gas market and its security of supply. Responsibility for this lies primarily with the member states themselves. Only if this approach proves insufficient should the question of whether or not to build up strategic gas stocks be examined. The costs are high, however, (ten times higher than that of oil) and the stocks only offer a short-term solution, quite apart from the distortive effect they could have on the market.

As mentioned above, a number of short-term measures were agreed by the June European Council to enhance EU energy security for the winter of 2014-2015, including national stress tests that were conducted this summer. The European Commission is expected to report on the findings shortly.

  1. The AIV does not favour a centralised purchasing mechanism to strengthen solidarity among the member states, as proposed by the prime minister of Poland. Such an instrument would rob the system of its flexibility, impede the liberalisation of the EU energy market and probably diminish market efficiency. In the interest of solidarity, a certain proportion of strategic stocks could be held for unforeseen shortages elsewhere. It is doubtful, though, whether this would enjoy the support of market parties in a liberalised market. The AIV is fully aware of this but it believes the final decision should be based on geopolitical considerations. The AIV recommends that the Commission study the regulations necessary for such a mechanism.

Government’s response:
Like the AIV, the government is not in favour of a centralised purchasing mechanism, even in an attenuated form, such as voluntary demand bundling as proposed in the aforementioned European Commission Communication. Bundling demand risks creating cartels, which in turn could disrupt the internal market. The government considers this undesirable, and believes that the European Commission and member states should focus first and foremost on putting its markets and infrastructure in order so as to reduce dependence on a single supplier. The government has already given its views on strategic gas storage. It awaits the new Commission’s plans in this area. This topic will be further explored in the government’s policy letter on gas in early October.

  1. In view of Ukraine’s heavy and ongoing dependence on Russian gas and its function as a transit hub for gas imports to the West, the EU and the IMF must persuade it to introduce a strategic and coherent energy policy. It must not use gas pipelines to force Gazprom to lower its prices; it must reform gas pricing, tackle corruption and lack of transparency in the Ukrainian gas industry and dramatically improve the industry’s energy efficiency. This will entail a difficult support operation requiring large-scale action and substantial funding. As well as the EU and IMF, Russia will also have to show political will. The AIV doubts that it will do so in the near future. At the same time, the EU must not close its eyes to the fact that gas transmission is an important source of revenue for Kyiv. In the AIV’s opinion, the EU (and the IMF) must follow up on the Deep and Comprehensive Free Trade Agreement (DCFTA) by supporting the diversification of the Ukrainian economy. Diversification could make up for the loss of EU demand for Russian gas piped through Ukraine.

Government’s response:
Developments in Ukraine have shown that the EU’s energy security cannot be taken for granted. In the government’s opinion, the AIV is right to argue that a strategic and coherent Ukrainian energy policy is indispensable if the energy security of both Ukraine and the EU is to be strengthened. By extension, the government agrees with the AIV that using existing pipelines to influence Gazprom’s gas prices is an inappropriate tactic and that corruption in the energy sector must be tackled. It is not just political will and tangible measures from Kyiv which are needed for this large-scale support operation to succeed; the EU, the IMF and the Russian authorities must also be prepared to contribute.

Furthermore, the AIV emphasises the need for the Ukrainian economy to diversify if Kyiv is to avoid becoming too dependent on income generated from the piping of Russian gas to Western Europe through Ukraine. The government supports the AIV’s analysis and would emphasise that the Deep and Comprehensive Free Trade Agreement (DCFTA) between the EU and Ukraine offers sufficient opportunities for diversifying the Ukrainian economy, thereby making it more resilient to reductions in gas transit income. The same applies to the programme of reform recently agreed with the IMF. The DCFTA helps provide Ukraine with gradual access to parts of the EU’s internal market. The DCFTA and the liberalisation of trade will have a positive impact on reciprocal trade and investment flows, and will aid diversification. The government considers it important that the DCFTA be implemented as soon as possible.

  1. To reduce dependence on Russian gas in the longer term, the AIV would propose greater diversification of oil and gas imports (pipelines to other areas, increased LNG capacity and interconnectivity, and higher storage and reverse flow capacity). The AIV is aware that this will require deep and long-term investment. Economic feasibility, however, may not be the only driver of interconnectivity. Geopolitical considerations must also be taken into account. The EU can commit itself to increasing diversification and so achieve the desired political impact on Moscow in the short term. The increase in reverse flow capacity offers the most expedient solution in areas with dense networks. The EU should also examine the scope for deepening gas relations with established suppliers such as Norway and Qatar, as well as completing alternative gas supply routes from Azerbaijan (Tanap and TAP) and connecting Iraq and Iran to those routes after the sanctions imposed on the latter are lifted.
     
  2. Serious thought should also be given to the gas connection with North Africa, even though the countries in this region are a source of uncertainty as regards security and political instability. This will seriously influence the conclusion of long-term agreements. Furthermore the feasibility of producing gas in the eastern Mediterranean and imports of LNG from the US in the longer term should be studied.

Government’s response:
In his H.J. Schoo lecture of 2 September 2014, the Minister of Foreign Affairs shared some of his thoughts on the importance of and opportunities for diversification. The Netherlands and the EU wish to see diversification in the economies of the countries they import – or could import – gas from. The government can help promote this process in several ways, for instance by facilitating new infrastructure works – such as pipelines and LNG (liquefied natural gas) import terminals – and concluding trade agreements. As the AIV notes in its advisory letter, much is already under way. In 2013, the EU’s initial list of Projects of Common Interest (PCIs) was adopted and has now entered the implementation phase. A second list is now being prepared and is expected to be adopted in 2015. The extent to which a project would increase security of supply is of vital importance when deciding whether or not to allocate EU funding from the Connecting Europe Facility to PCIs. For more on this, see the response to recommendation 7.

Other types of policy can also help promote diversification. One example is in Spain, where gas supplies are very limited. Here, legislation has been introduced to ensure that no more than 50% of all imports come from any one country. If it looks like the limit is about to be exceeded, the country’s major gas importers must import from other countries, which for Spain, with its seven LNG terminals, is a real possibility.

Helping countries with potential gas reserves bring them to market more quickly is another way to increase scope for diversification. For example, the Netherlands and other European countries, such as the United Kingdom and Norway, are helping countries in the eastern Mediterranean, such as Cyprus and Israel, strengthen their legislation and governance mechanisms with a view to boosting gas extraction. Malta, Cyprus and the European Commission have recently established a gas platform involving all of the Mediterranean countries. The platform is primarily focused on facilitating knowledge exchange, but also on exploring whether the region could develop into a gas hub. The Netherlands is also helping East African countries like Mozambique and Tanzania to strengthen their legislation and governance mechanisms. Large gas reserves have recently been discovered there and they are awaiting effective exploitation. East African gas could also help diversify EU imports. Perhaps not directly, because this gas will primarily go to the closer Asian markets, but indirectly, because Middle Eastern gas destined for Asia will subsequently become available for export to the EU.

In the US, LNG export licences are currently being developed as a result of the country’s shale gas revolution. Shale gas has turned the US into the world’s biggest gas producer. The first export licences have already been issued. The International Energy Agency expects that in five years’ time, the US and Canada will together export more gas than Russia. Other providers may also come into the picture. For a long time, the Commission has been working to develop the Southern Gas Corridor, which will transport gas from the Caspian region – and later, possibly from the Middle East – to the EU. More gas could also be imported from Algeria, which has desert shale gas reserves. In the future Iran may be an option, if an agreement can be concluded which will lift current sanctions. Finally, consultations are taking place with other producers such as Norway and Qatar on a systematic basis.

All these developments will create more providers and a more flexible global gas market, thereby furthering the diversification of the EU’s energy supply.

  1. The European Commission (through the CEF) and the EIB have the funds necessary to support these proposed steps. The CEF funding criteria were recently revised but should be aligned even more closely to the EU’s needs and perhaps linked more strongly to the EIB instruments. Criteria such as ‘maturity of the project’ must not be applied rigidly.

Government’s response:
The 2014 round of CEF funding focused on projects to improve electricity infrastructure and relieve energy isolation. The CEF allocation criteria are somewhat flexible, however, and are a topic of discussion between the Commission and member states. A new round of funding is expected next year, the criteria for which can be brought into line with current EU needs. Some criteria, like ‘maturity of the project’ are derived directly from the Regulation on guidelines for trans-European energy infrastructure. It is more difficult to diverge from these criteria and the Netherlands sees no reason to. It is important that projects seeking funding are sufficiently well-defined so that it is clear what their added value is, when they can be completed and exactly how much funding is needed. This ensures efficient use of the CEF’s limited funds so as to contribute as much as possible to strengthening security of supply and market integration. Linking criteria to the European Investment Bank’s instruments offers scope for generating more infrastructure-strengthening resources. However, projects must still be sufficiently well-defined for their added value to be clear.

  1. The AIV recommends that renewable energy grants be coordinated at EU level in keeping with the agreements applicable to the European Semester. Financial support for sustainable energy distorts competition between countries, which is at odds with the creation of a level playing field. As in the case of financial governance (compare the European Semester mentioned above), national competences (the awarding of grants) will remain intact; they will just be underpinned by a common sustainable energy policy. The common policy, including the margins within which renewable energy grants can fluctuate, should be indicative.

Government’s response:
The government supports the AIV’s recommendation of greater EU coordination of renewable energy grants. Differing, uncoordinated grant schemes can lead to member states competing for grants and pose an obstacle to cost-effective adoption of renewable energy. The government is currently in talks with Germany on adapting renewable energy policy. It also supports the new EU state aid framework for renewable energy presented this spring, which gives guidelines for renewable energy grants. The EU is currently discussing goals for 2030. The government supports the European Commission’s proposal of setting a single European renewable energy goal which is not broken down into specific goals for individual member states, provided this does not obstruct cost-effective CO2 reduction under the EU Emissions Trading System (ETS).

The EU Ecodesign Directive contributes to a level playing field in the area of energy savings. The Dutch input to decision-making in Brussels is in accordance with government policy and the Energy Agreement for Sustainable Growth, which aims to ensure the highest possible ambition level with regard to appliance energy efficiency.

  1. In the AIV’s opinion, geopolitical considerations are incorrectly given secondary billing in both EU and national energy policies. The EU should consider giving the High Representative for Foreign Affairs and Security Policy and the European External Action Service power to agree the energy policy and the criteria for awarding funds from the CEF to energy projects. Furthermore, there should be a clear link with neighbourhood policy. It is also advisable that, when allocating the portfolios in the Commission and possibly establishing policy clusters, the incoming President of the European Commission take account of the High Representative’s position in the energy cluster. In the Netherlands, too, energy policy is determined primarily by economics, and thus primary responsibility for it lies with the Minister of Economic Affairs. To a large extent, however, energy policy is also a matter of foreign policy. The Minister of Foreign Affairs should have a prominent voice in strategic investment decisions.

Government’s response:
The government supports the AIV’s argument that geopolitical considerations should be given a prominent place in EU energy and foreign policy and in national energy policies. The government is pressing for the High Representative for Foreign Affairs and Security Policy to coordinate external aspects of EU energy policy in close cooperation with the European External Action Service (EEAS) and the European Commission. To guarantee a consistent external policy, the High Representative must be closely involved in the energy cluster being set up by the new Commission. The High Representative and the EEAS should be involved in the policy framework for security of energy supply, which includes the Connecting Europe Facility. The government believes energy should occupy a central position in the European Neighbourhood Policy. At national level, the Ministers of Foreign and Economic Affairs work together in shaping and implementing external energy policy.

  1. Finally, the AIV is aware that an integrated EU energy policy cannot be introduced overnight. It will affect the member states’ competitiveness, but, as in financial and economic policy, European governments must realise that long-term close cooperation will increase all the member states’ capacity to act. The AIV therefore recommends that the Third Energy Package be actively implemented in full in all member states, especially when it comes to the construction of vital infrastructure.

Government’s response:
Implementing the Third Energy Package is one of the central themes of the government’s energy policy. The completion of the internal energy market is essential for an efficient energy market where, in combination with good energy infrastructure, energy can flow freely and countries can effectively support each other when problems arise. Countries themselves are responsible for bringing their infrastructure up to standard, however, and ensuring good interconnectivity is their joint responsibility. If this is not economically viable but nonetheless essential for ensuring security of supply, a CEF contribution can be provided on the basis of the relevant criteria.

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1 Reference 2014Z14823.
2 The EU’s dependence on Russian gas ‘How an integrated EU policy can reduce it’, AIV Advisory Letter no. 26, 11 June 2014.
3 COM (2014) 330.
4 European Council Conclusions of 26/27 June 2014.
5 Parliamentary Papers 21501-33, no. 491.
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