# C_2006028EN.01006901.xml

| 3.2.2006 | EN | Official Journal of the European Union | C 28/69 |
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3.2.2006

EN

Official Journal of the European Union

C 28/69

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Opinion of the European Economic and Social Committee on the ‘Proposal for a Regulation of the European Parliament and of the Council establishing the European Union Solidarity Fund’

(COM(2005) 108 final — 2005/0033 (COD))

(2006/C 28/14)

On 27 September 2005 the Council decided to consult the European Economic and Social Committee, under Article 262 of the Treaty establishing the European Community, on the abovementioned proposal.

The Section for Economic and Monetary Union and Economic and Social Cohesion, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 3 October 2005. The rapporteur was Mr Barros Vale.

Mr Barros Vale

At its 421st plenary session, held on 26 and 27 October 2005 (meeting of 27 October), the European Economic and Social Committee adopted the following opinion nem. con. with 74 votes in favour and 3 abstensions.

1.   Introduction

| 1.1 | The European Union Solidarity Fund (EUSF) was set up in 2002, with the aim of providing assistance to regions of Member States or countries preparing for accession that have suffered major disasters. |
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1.1

The European Union Solidarity Fund (EUSF) was set up in 2002, with the aim of providing assistance to regions of Member States or countries preparing for accession that have suffered major disasters.

| 1.2 | The EUSF should be flexible and as free of red tape as possible, so that it can provide immediate assistance to the affected regions. |
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1.2

The EUSF should be flexible and as free of red tape as possible, so that it can provide immediate assistance to the affected regions.

| 1.3 | The EUSF budget for the 2002-2006 period was set at around EUR one billion per year. |
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1.3

The EUSF budget for the 2002-2006 period was set at around EUR one billion per year.

| 1.4 | The EUSF Regulation is due to be revised by the end of 2006, and it is this revision that the present opinion will consider. |
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1.4

The EUSF Regulation is due to be revised by the end of 2006, and it is this revision that the present opinion will consider.

| 1.5 | The current EUSF covers only natural disasters, which means that it is extremely difficult to provide assistance in the wake of industrial accidents, acts of terrorism or even a serious public health emergency. |
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1.5

The current EUSF covers only natural disasters, which means that it is extremely difficult to provide assistance in the wake of industrial accidents, acts of terrorism or even a serious public health emergency.

| 1.6 | The current financial threshold for mobilising the EUSF is very high (EUR 3 billion for costs arising from direct damage, or over 0.6 % of GNI). This has led to more than two-thirds of aid being provided under an exception clause, which has an annual budget of only EUR 75 million. |
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1.6

The current financial threshold for mobilising the EUSF is very high (EUR 3 billion for costs arising from direct damage, or over 0.6 % of GNI). This has led to more than two-thirds of aid being provided under an exception clause, which has an annual budget of only EUR 75 million.

2.   The new proposal

2.1   General issues

| 2.1.1 | The geographical scope of the EUSF remains unchanged, covering the current Member States and also the accession countries. |
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2.1.1

The geographical scope of the EUSF remains unchanged, covering the current Member States and also the accession countries.

| 2.1.2 | Its thematic scope is now extended to cover technological or industrial disasters, public health threats and acts of terrorism as well as natural disasters. |
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2.1.2

Its thematic scope is now extended to cover technological or industrial disasters, public health threats and acts of terrorism as well as natural disasters.

| 2.1.3 | There are two criteria for defining a ‘disaster’ as being eligible for assistance under the Fund, based on quantitative and political considerations. |
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2.1.3

There are two criteria for defining a ‘disaster’ as being eligible for assistance under the Fund, based on quantitative and political considerations.

| 2.1.3.1 | The quantitative criterion: the financial threshold for mobilising the EUSF is lowered from EUR 3 billion to EUR 1 billion, or from 0.6 % to 0.5 % of GNI, which will allow the fund to be mobilised in more cases. |
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2.1.3.1

The quantitative criterion: the financial threshold for mobilising the EUSF is lowered from EUR 3 billion to EUR 1 billion, or from 0.6 % to 0.5 % of GNI, which will allow the fund to be mobilised in more cases.

| 2.1.3.2 | The political criterion: under some clearly justified circumstances (specifically those in which the full scale of the damage is not known at the time the decision is taken), the Commission can mobilise the Fund even where the quantitative criterion is not met. |
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2.1.3.2

The political criterion: under some clearly justified circumstances (specifically those in which the full scale of the damage is not known at the time the decision is taken), the Commission can mobilise the Fund even where the quantitative criterion is not met.

| 2.1.4 | The States neighbouring the affected country are also eligible if they suffer the effects of the disaster. |
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2.1.4

The States neighbouring the affected country are also eligible if they suffer the effects of the disaster.

| 2.1.5 | The subsidiarity principle must also apply to the EUSF. |
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2.1.5

The subsidiarity principle must also apply to the EUSF.

| 2.1.6 | Under the proposal, the affected country may request an advance payment (around 5 % of the total predicted cost of eligible operations, up to a maximum of EUR 5 million), to be granted immediately following the request for aid. This sum must be repaid by the country in question should the request subsequently prove ineligible. |
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2.1.6

Under the proposal, the affected country may request an advance payment (around 5 % of the total predicted cost of eligible operations, up to a maximum of EUR 5 million), to be granted immediately following the request for aid. This sum must be repaid by the country in question should the request subsequently prove ineligible.

| 2.1.7 | The principle of proportionality must be applied when aid is granted, giving consideration to the total amount of damage, the size of the country and how serious the consequences are likely to be in future. |
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2.1.7

The principle of proportionality must be applied when aid is granted, giving consideration to the total amount of damage, the size of the country and how serious the consequences are likely to be in future.

| 2.1.8 | The beneficiary State is entirely responsible for the implementation of the grant and will have to submit a report detailing expenditure, which must be fully justified and carried out in accordance with the regulation. |
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2.1.8

The beneficiary State is entirely responsible for the implementation of the grant and will have to submit a report detailing expenditure, which must be fully justified and carried out in accordance with the regulation.

| 2.1.9 | The sum proposed by the Commission for the EUSF remains at EUR 1 billion per year. |
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2.1.9

The sum proposed by the Commission for the EUSF remains at EUR 1 billion per year.

| 2.1.10 | The EU budget does not provide for the resources allocated to the EUSF. Whenever the Fund is mobilised, this is done using an amending budget. |
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2.1.10

The EU budget does not provide for the resources allocated to the EUSF. Whenever the Fund is mobilised, this is done using an amending budget.

| 2.1.11 | If the annual amount is exceeded, the following year's budget can be used — which will ensure that aid is granted — provided that this is justified. |
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2.1.11

If the annual amount is exceeded, the following year's budget can be used — which will ensure that aid is granted — provided that this is justified.

3.   General and specific comments

| 3.1 | The European Economic and Social Committee (EESC) welcomes the Commission's aim of extending the scope of the Solidarity Fund and enabling it to provide a rapid response in the event of a crisis. |
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3.1

The European Economic and Social Committee (EESC) welcomes the Commission's aim of extending the scope of the Solidarity Fund and enabling it to provide a rapid response in the event of a crisis.

| 3.2 | The EESC is of the view, however, that various aspects of the Commission proposal need fine-tuning in order to make it more efficient, thus making the Fund a powerful and flexible EU instrument that enables the inhabitants of the territories it covers to benefit fully from its support. This contribution must be free of red tape and must be governed by rules able to cater for various types of disaster, whatever the cause, at the most critical times for the communities it is designed to benefit. As well as offering valuable help to restore infrastructure and bring economic and social life back to normal, it must also provide an unequivocal political signal that Europe can send to citizens affected by serious emergency situations. |
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3.2

The EESC is of the view, however, that various aspects of the Commission proposal need fine-tuning in order to make it more efficient, thus making the Fund a powerful and flexible EU instrument that enables the inhabitants of the territories it covers to benefit fully from its support. This contribution must be free of red tape and must be governed by rules able to cater for various types of disaster, whatever the cause, at the most critical times for the communities it is designed to benefit. As well as offering valuable help to restore infrastructure and bring economic and social life back to normal, it must also provide an unequivocal political signal that Europe can send to citizens affected by serious emergency situations.

| 3.3 | Although the size of the proposed financial envelope appears to be in line with the applications received in recent years, the EESC doubts whether it could meet the needs of a major disaster, such as an earthquake or massive tidal wave, a Europe-wide pandemic or an accident or attack involving weapons of mass destruction. Whilst these situations are indeed exceptional, they should be planned for, by means of a mechanism that would also be exceptional, but that the Union could call upon if a disaster of that magnitude ever occurred. |
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3.3

Although the size of the proposed financial envelope appears to be in line with the applications received in recent years, the EESC doubts whether it could meet the needs of a major disaster, such as an earthquake or massive tidal wave, a Europe-wide pandemic or an accident or attack involving weapons of mass destruction. Whilst these situations are indeed exceptional, they should be planned for, by means of a mechanism that would also be exceptional, but that the Union could call upon if a disaster of that magnitude ever occurred.

| 3.4 | The rules governing access to the Fund must, the EESC believes, be simple and clear and as free of red tape as possible, but must also contain mechanisms that ensure transparency, as well as the subsequent evaluation and monitoring of the uses to which the resources made available to the beneficiary State are put. |
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3.4

The rules governing access to the Fund must, the EESC believes, be simple and clear and as free of red tape as possible, but must also contain mechanisms that ensure transparency, as well as the subsequent evaluation and monitoring of the uses to which the resources made available to the beneficiary State are put.

| 3.5 | Given the current EU budgetary climate and Europe's economic situation, the EESC is not opposed to the proposed variable form of budgeting with a pre-set ceiling. However, it considers that the EUSF should be established as a Permanent Independent Fund as soon as possible with its own fixed annual budget, the ‘leftovers’ from which, gleaned from unused annual funds, would form a reserve for major disasters. |
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3.5

Given the current EU budgetary climate and Europe's economic situation, the EESC is not opposed to the proposed variable form of budgeting with a pre-set ceiling. However, it considers that the EUSF should be established as a Permanent Independent Fund as soon as possible with its own fixed annual budget, the ‘leftovers’ from which, gleaned from unused annual funds, would form a reserve for major disasters.

| 3.6 | Concerning the rules on deadlines for use, the EESC considers that the Commission proposal is a step in the right direction. It welcomes the planned rapid response mechanism as it will help to ensure rapid assistance as soon as the facts have been ascertained, which is the whole purpose of mobilising the EUSF. |
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3.6

Concerning the rules on deadlines for use, the EESC considers that the Commission proposal is a step in the right direction. It welcomes the planned rapid response mechanism as it will help to ensure rapid assistance as soon as the facts have been ascertained, which is the whole purpose of mobilising the EUSF.

| 3.7 | Estimating the damage will be quite a complex matter, given the scale of the situations covered by the proposed Regulation. The process is also likely to be highly fallible, given the wide range of costs and actors involved, and the fact that it covers damage to both public and private property. The short space of time in which the application must be submitted to the Commission, together with the great variety of interests and material assets affected, may lead to a significant overestimation or underestimation of the impact of the crisis concerned. States' requests must therefore be evaluated meticulously, making use of specialists, historical data and earlier records and adjusting the amount of finance provided in line with the cost of living in the beneficiary State. |
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3.7

Estimating the damage will be quite a complex matter, given the scale of the situations covered by the proposed Regulation. The process is also likely to be highly fallible, given the wide range of costs and actors involved, and the fact that it covers damage to both public and private property. The short space of time in which the application must be submitted to the Commission, together with the great variety of interests and material assets affected, may lead to a significant overestimation or underestimation of the impact of the crisis concerned. States' requests must therefore be evaluated meticulously, making use of specialists, historical data and earlier records and adjusting the amount of finance provided in line with the cost of living in the beneficiary State.

| 3.8 | With regard to the type of costs that the Fund would meet, the EESC approves of the eligible operations listed in Article 4 of the proposed Regulation, but would like an additional category to be included with the following title: 'other operations of public interest, designed to return the social and economic life of the affected populations and/or areas to normality, while opening access to the EUSF to all civil society players, in accordance with provisions and safeguards to be defined'. The aim of including this new point is to address the unpredictable nature of the types and consequences of events to be covered under the EUSF by making the decision-making process in unusual situations more flexible, in cases where social and production structures would be threatened if there is no possibility of assistance for damage to private property. |
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3.8

With regard to the type of costs that the Fund would meet, the EESC approves of the eligible operations listed in Article 4 of the proposed Regulation, but would like an additional category to be included with the following title: 'other operations of public interest, designed to return the social and economic life of the affected populations and/or areas to normality, while opening access to the EUSF to all civil society players, in accordance with provisions and safeguards to be defined'. The aim of including this new point is to address the unpredictable nature of the types and consequences of events to be covered under the EUSF by making the decision-making process in unusual situations more flexible, in cases where social and production structures would be threatened if there is no possibility of assistance for damage to private property.

| 3.8.1 | With reference to this wish to widen access it should be noted that take-up of the appropriations available has been small, not least because of the clause limiting use of the funds to public expenditure only. This makes it impossible to address situations which are in fact in keeping with the EUSF rationale. |
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3.8.1

With reference to this wish to widen access it should be noted that take-up of the appropriations available has been small, not least because of the clause limiting use of the funds to public expenditure only. This makes it impossible to address situations which are in fact in keeping with the EUSF rationale.

| 3.8.2 | The threshold level should also be reviewed, so as to adjust the fund's intervention potential to local needs and reflect the regional dimension of some natural phenomena. |
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3.8.2

The threshold level should also be reviewed, so as to adjust the fund's intervention potential to local needs and reflect the regional dimension of some natural phenomena.

| 3.9 | The EESC considers that the ultimate beneficiaries of the Fund's operations must be the EU's citizens. It is only for logistical or organisational reasons that States are the intermediate beneficiaries, since it is they who receive the relevant resources from the EUSF budget. By the same token, State organisations should also not be the only recipients of public funds available under the Fund; civil society organisations should also receive these funds, since they are often involved in eligible operations because States do not generally have the resources to deal with the effects of this type of disaster without their help. Fire brigades, voluntary civil society bodies working in the areas of health or social assistance, and other civil society actors must be properly compensated for their efforts and dedication and for the expenses they incur, since their budgets are not generally geared to the enormous scale of such events. |
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3.9

The EESC considers that the ultimate beneficiaries of the Fund's operations must be the EU's citizens. It is only for logistical or organisational reasons that States are the intermediate beneficiaries, since it is they who receive the relevant resources from the EUSF budget. By the same token, State organisations should also not be the only recipients of public funds available under the Fund; civil society organisations should also receive these funds, since they are often involved in eligible operations because States do not generally have the resources to deal with the effects of this type of disaster without their help. Fire brigades, voluntary civil society bodies working in the areas of health or social assistance, and other civil society actors must be properly compensated for their efforts and dedication and for the expenses they incur, since their budgets are not generally geared to the enormous scale of such events.

| 3.10 | The EESC considers that the geographic scope of the countries covered in the event of disaster should be reviewed, so as to ensure that countries which do not share a border with the affected country can also receive assistance. Large-scale disasters (e.g. a nuclear disaster) may affect countries which do not border the State in which the tragedy originated, and they too should be eligible for assistance. Where other States are affected, and provided that the Fund has been mobilised, it must be implemented in all the States involved, even if some of them do not meet the thresholds set out in Article 2 of the proposal. |
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3.10

The EESC considers that the geographic scope of the countries covered in the event of disaster should be reviewed, so as to ensure that countries which do not share a border with the affected country can also receive assistance. Large-scale disasters (e.g. a nuclear disaster) may affect countries which do not border the State in which the tragedy originated, and they too should be eligible for assistance. Where other States are affected, and provided that the Fund has been mobilised, it must be implemented in all the States involved, even if some of them do not meet the thresholds set out in Article 2 of the proposal.

| 3.11 | The EESC also considers that the issue of neighbourhood comes into play as regards non-Member or non-Candidate States affected by an event originating in the EU or in a Candidate State. If the EUSF is mobilised for an event originating in or caused within this geographical area, the other neighbouring States would also warrant support from the Union, either under the EUSF or under the other international cooperation instruments in force, provided that this does not affect and thus hamper the specific cooperation programmes already in place. |
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3.11

The EESC also considers that the issue of neighbourhood comes into play as regards non-Member or non-Candidate States affected by an event originating in the EU or in a Candidate State. If the EUSF is mobilised for an event originating in or caused within this geographical area, the other neighbouring States would also warrant support from the Union, either under the EUSF or under the other international cooperation instruments in force, provided that this does not affect and thus hamper the specific cooperation programmes already in place.

| 3.12 | The EESC believes that the Fund should also be mobilised for disasters arising from an accumulation or continuation of situations not immediately identified as being particularly damaging (for example a serious drought); the point at which they receive consideration would have to be clarified. The climate changes that have been taking place, caused partly by global warming — for which the Union as a whole also bears some responsibility — affect some States more than others, and it would be neither reasonable nor supportive for the European Union to shirk its obligations, as regards either the causes of climate change or its consequences. |
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3.12

The EESC believes that the Fund should also be mobilised for disasters arising from an accumulation or continuation of situations not immediately identified as being particularly damaging (for example a serious drought); the point at which they receive consideration would have to be clarified. The climate changes that have been taking place, caused partly by global warming — for which the Union as a whole also bears some responsibility — affect some States more than others, and it would be neither reasonable nor supportive for the European Union to shirk its obligations, as regards either the causes of climate change or its consequences.

| 3.12.1 | The comments gathered on the ground during the EESC fact-finding visit to Spain and Portugal on 14-16 September 2005 highlighted the need, in a number of cases, to dovetail the use of:






  — | the EUSF, in its rapid response capacity, to provide an immediate solution to urgent needs, both to help the affected communities and to provide material assistance; |
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3.12.1

The comments gathered on the ground during the EESC fact-finding visit to Spain and Portugal on 14-16 September 2005 highlighted the need, in a number of cases, to dovetail the use of:

—

the EUSF, in its rapid response capacity, to provide an immediate solution to urgent needs, both to help the affected communities and to provide material assistance;

| — | the Funds that offer more structural assistance, so as to provide long-term solutions to more fundamental problems, for example by creating infrastructure to deal with drought, reafforestation, and the development of alternative activities in areas ravaged by fires. |
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—

the Funds that offer more structural assistance, so as to provide long-term solutions to more fundamental problems, for example by creating infrastructure to deal with drought, reafforestation, and the development of alternative activities in areas ravaged by fires.

| 3.12.2 | The integration of EUSF assistance in a wider context of large-scale long-term measures should be an important criterion for the Commission when it selects projects. This would improve the overall effectiveness of both the EUSF and the Structural Funds. |
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3.12.2

The integration of EUSF assistance in a wider context of large-scale long-term measures should be an important criterion for the Commission when it selects projects. This would improve the overall effectiveness of both the EUSF and the Structural Funds.

| 3.12.3 | Like floods, tornados and severe storms, which are already covered, the issues of water supply, useable infrastructure and providing social or health-related assistance for the population in unforeseeable situations of drought or heat waves must not be excluded from the list of phenomena that the EUSF should support. The regulation should provide for these situations and clearly define at what point they become worthy of consideration, since they are not caused by a rapid and immediately identifiable event but instead by the ongoing deterioration of a given situation (climate-related or otherwise). |
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3.12.3

Like floods, tornados and severe storms, which are already covered, the issues of water supply, useable infrastructure and providing social or health-related assistance for the population in unforeseeable situations of drought or heat waves must not be excluded from the list of phenomena that the EUSF should support. The regulation should provide for these situations and clearly define at what point they become worthy of consideration, since they are not caused by a rapid and immediately identifiable event but instead by the ongoing deterioration of a given situation (climate-related or otherwise).

| 3.13 | To this end, an obligation could be introduced for the national authority responsible for water management to issue an ‘official declaration of serious drought’, based on uniform objective criteria to be followed by the water management authorities in all the Member States. |
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3.13

To this end, an obligation could be introduced for the national authority responsible for water management to issue an ‘official declaration of serious drought’, based on uniform objective criteria to be followed by the water management authorities in all the Member States.

| 3.14 | The EESC also believes that the Member States and the Union must establish clear rules concerning the obligation of the EU insurance system to provide cover for certain types of risk which insurance companies often try to avoid. This is all the more important because the EUSF and national aid do not generally cover damage sustained by private individuals, the cost of which is usually much higher than that of the assistance which public authorities feel obliged to provide in the case of problems that affect a community as a whole. |
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3.14

The EESC also believes that the Member States and the Union must establish clear rules concerning the obligation of the EU insurance system to provide cover for certain types of risk which insurance companies often try to avoid. This is all the more important because the EUSF and national aid do not generally cover damage sustained by private individuals, the cost of which is usually much higher than that of the assistance which public authorities feel obliged to provide in the case of problems that affect a community as a whole.

| 3.15 | Lastly, the EESC considers that work on risk prevention must be encouraged at all levels to mitigate or nullify the consequences of such situations, by forecasting events of this nature, preventing disasters, and preparing and setting in motion early response mechanisms in order to safeguard human life and wellbeing and to prevent the destruction of infrastructure and of material and immaterial assets. The EESC would not, therefore, object to the inclusion in the Regulation of a restrictive clause which, in order to encourage prevention, would limit, reduce or eliminate EUSF support in proven cases of negligence on the part of the public authorities of the State in question, provided that the State is able to cope financially with the event's aftermath. The EUSF could nevertheless still provide assistance in such cases, in the form of a loan rather than a grant, because it is the populations affected by the disaster that the support is ultimately intended to benefit. Giving EU grants to States which have been negligent creates a climate of slackness and irresponsibility and increases the risk of certain types of disaster which could in some cases be prevented. |
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3.15

Lastly, the EESC considers that work on risk prevention must be encouraged at all levels to mitigate or nullify the consequences of such situations, by forecasting events of this nature, preventing disasters, and preparing and setting in motion early response mechanisms in order to safeguard human life and wellbeing and to prevent the destruction of infrastructure and of material and immaterial assets. The EESC would not, therefore, object to the inclusion in the Regulation of a restrictive clause which, in order to encourage prevention, would limit, reduce or eliminate EUSF support in proven cases of negligence on the part of the public authorities of the State in question, provided that the State is able to cope financially with the event's aftermath. The EUSF could nevertheless still provide assistance in such cases, in the form of a loan rather than a grant, because it is the populations affected by the disaster that the support is ultimately intended to benefit. Giving EU grants to States which have been negligent creates a climate of slackness and irresponsibility and increases the risk of certain types of disaster which could in some cases be prevented.

4.   Conclusions

| 4.1 | The EESC reiterates the position it has always maintained, which is to support prevention, accountability and the forecasting of serious disasters. It also attaches considerable importance, however, to the existence of a mechanism such as the EUSF, provided that this is adjusted to take account of the criticism and suggestions made in point 3 above. |
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4.1

The EESC reiterates the position it has always maintained, which is to support prevention, accountability and the forecasting of serious disasters. It also attaches considerable importance, however, to the existence of a mechanism such as the EUSF, provided that this is adjusted to take account of the criticism and suggestions made in point 3 above.

| 4.2 | The EESC welcomes the improvements made in the proposed Regulation, but considers that these are insufficient to enable the EUSF to achieve its full potential and capacity to take appropriate action. |
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4.2

The EESC welcomes the improvements made in the proposed Regulation, but considers that these are insufficient to enable the EUSF to achieve its full potential and capacity to take appropriate action.

| 4.3 | The Committee thinks that the Commission proposal should be amended in three ways so as to gear it more effectively to practical requirements:






  a) | extend its scope to cover other forms of disaster, particularly droughts; |
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4.3

The Committee thinks that the Commission proposal should be amended in three ways so as to gear it more effectively to practical requirements:

a)

extend its scope to cover other forms of disaster, particularly droughts;

| b) | lower the threshold figures for the scale of damage (which are too high, and exclude most recent disasters) and/or give the Commission greater powers of discretion, so that it could recognise disasters with a serious regional impact; |
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b)

lower the threshold figures for the scale of damage (which are too high, and exclude most recent disasters) and/or give the Commission greater powers of discretion, so that it could recognise disasters with a serious regional impact;

| c) | be more flexible about the types of eligible expenditure, by introducing a new, more comprehensive clause to cover other significant costs that are not included in the Commission's list of ‘eligible operations’. |
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c)

be more flexible about the types of eligible expenditure, by introducing a new, more comprehensive clause to cover other significant costs that are not included in the Commission's list of ‘eligible operations’.

| 4.4 | An own-initiative opinion evaluating the principles and operation of the Solidarity Fund and its ability to meet the needs of the EU's Member States and regions could also be drawn up at an early opportunity, as a further way of addressing the problems already identified. |
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4.4

An own-initiative opinion evaluating the principles and operation of the Solidarity Fund and its ability to meet the needs of the EU's Member States and regions could also be drawn up at an early opportunity, as a further way of addressing the problems already identified.

Brussels, 27 October 2005.

The President

of the European Economic and Social Committee

Anne-Marie SIGMUND

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