1 . SUBMISSIONS RELATING TO THE INDIVIDUAL DECISION FIXING THE TONNAGE OF SCRAP SUBJECT TO EQUALIZATION ( A ) INADEQUATE STATEMENT OF THE REASONS UPON WHICH THE DECISION IS BASED THE APPLICANT'S COMPLAINTS RELATING TO THE FORMAL STATEMENT OF THE REASONS UPON WHICH THE CONTESTED DECISION IS BASED CANNOT BE UPHELD, SINCE THE DECISION MENTIONS IN SUMMARY FORM THE ESSENTIAL CONSIDERATIONS OF FACT AND OF LAW UPON WHICH IT IS BASED AND IN PARTICULAR THE APPORTIONMENT OF THE CHARGEABLE AMOUNTS OF BOUGHT SCRAP BETWEEN THE DIFFERENT ACCOUNTING PERIODS . FURTHER, THE DEFENDANT HAS GIVEN A COMPLETE ANSWER TO THE APPLICANT'S ALLEGATION THAT THERE WAS AN INCONSISTENCY IN THE STATEMENT OF REASONS WITH REFERENCE TO THE RATIO BETWEEN THE INPUT OF SCRAP TO THE FURNACE AND THE PRODUCTION OF STEEL, NAMELY THAT THIS INPUT HAD BEEN CALCULATED FIRST WITH REFERENCE TO CRUDE STEEL AND THEN TO FINISHED PRODUCTS . ( B ) INACCURACY OF THE STATEMENT OF THE REASONS UPON WHICH THE DECISION IS BASED THE APPLICANT ALSO SUBMITS THAT THE CONTENT OF THE FINDINGS RELATING TO THE CONSUMPTION OF SCRAP IN THE CONTESTED DECISION ARE INCORRECT . ( AA ) WITH REGARD TO THE PERIOD FROM APRIL 1954 TO JANUARY 1957, IN RESPECT OF WHICH THE DECISION REFERS TO THE INVOICES FOR THE PURCHASE OF SCRAP CHECKED BY THE INSPECTORS ON THE SPOT, THE SIMPLE ALLEGATION OF THE APPLICANT, WHICH CONSISTS ONLY OF DESCRIBING THE DEFENDANT'S FINDINGS AS ABSURD, CANNOT BE REGARDED AS HAVING ANY VALIDITY . SINCE FROM THE BEGINNING OF THE OPERATION OF THE EQUALIZATION SCHEME DISPUTES AROSE CONCERNING THE DECLARATIONS AND COMPULSORY CONTRIBUTIONS, THE APPLICANT WAS UNDER A DUTY TO KEEP ALL THE DOCUMENTS REQUIRED TO PROVE THE ALLEGED INACCURACY OF THE CALCULATIONS UNTIL THE QUESTIONS STILL IN DISPUTE HAD BEEN FINALLY SETTLED . THE DEFENDANT'S ANSWER TO THE APPLICANT'S ALLEGATION THAT CERTAIN INVOICES CAME NOT FROM THE SUPPLIERS OF SCRAP BUT FROM TRANSPORT UNDERTAKINGS WAS THAT THESE INVOICES APPARENTLY RELATED TO DELIVERIES OF SCRAP BY THE WAGGON DEPARTMENT OF THE ITALIAN RAILWAYS, AND THE APPLICANT HAS NOT ADDUCED ANY EVIDENCE TO THE CONTRARY . ACCORDING TO THE APPLICANT THE SCRAP USED IN CONTRACT WORK HAS BEEN INCLUDED IN EQUALIZATION EVER SINCE THE SCHEME CAME INTO OPERATION, ALTHOUGH RULES TO THIS EFFECT WERE NOT LAID DOWN UNTIL DECISION NO 14/55 WAS TAKEN . HOWEVER DECISION NO 14/55 DID NOT INTRODUCE ANY NEW RULES BUT MERELY CLARIFIED THE PRINCIPLES WHICH APPLIED TO EQUALIZATION FROM THE BEGINNING . P.53 ( BB ) WITH REGARD TO THE PERIOD FROM FEBRUARY 1957 TO NOVEMBER 1958 IN RESPECT OF WHICH THE DECISION REFERS TO DATA RELATING TO THE SALE OF FINISHED PRODUCTS THE APPLICANT DISPUTES THE ACCURACY OF THE DATA USED . IT SUBMITS, IN PARTICULAR, THAT THE DECISION IS BASED ON FINISHED PRODUCTS WHICH FALL OUTSIDE THE AMBIT OF THE ECSC TREATY . IT IS NOT DISPUTED THAT THE APPLICANT ITSELF PRODUCES THE STEEL REQUIRED FOR THE MANUFACTURE OF ITS FINISHED PRODUCTS . THEREFORE IT IS THE SCRAP USED AS THE RAW MATERIAL FOR THE PRODUCTION OF STEEL WHICH HAS QUITE PROPERLY BEEN MADE SUBJECT TO EQUALIZATION . IT WAS THEREFORE PERMISSIBLE TO CALCULATE THE CONSUMPTION OF SCRAP REQUIRED FOR THE PRODUCTION OF CRUDE STEEL ON THE BASIS OF THE VOLUME OF THE PRODUCTION OF FINISHED PRODUCTS . THE APPLICANT ALSO SUBMITS THAT, IN CALCULATING THE CONSUMPTION OF SCRAP ON THE BASIS OF THE SALES OF FINISHED PRODUCTS, IT IS PROBABLE THAT CERTAIN AMOUNTS OF SCRAP, WHICH WERE BOUGHT AT THE END OF THE PERIOD ENDING IN JANUARY 1957 WERE PROCESSED INTO FINISHED PRODUCTS AT THE BEGINNING OF THE PERIOD COMMENCING IN FEBRUARY 1957 AND WERE THEREFORE TWICE MADE THE SUBJECT OF EQUALIZATION CONTRIBUTIONS . AS THE HIGH AUTHORITY ONLY TOOK INTO ACCOUNT SALES OF FINISHED PRODUCTS EFFECTED UP TO THE END OF NOVEMBER 1958, ANY SUCH DOUBLE CHARGE WOULD IN ANY EVENT BE OFFSET BY THE FACT THAT SCRAP BOUGHT AND CONSUMED BEFORE THIS DATE FOR THE MANUFACTURE OF FINISHED PRODUCTS AT A LATER DATE WAS NOT TAKEN INTO CONSIDERATION IN CALCULATING THE BASIS OF ASSESSMENT . ( CC ) THE APPLICANT FINALLY CRITICIZES THE CHECKING OF THE CONSUMPTION OF SCRAP ON THE BASIS OF THE CONSUMPTION OF ELECTRICITY . WHATEVER CRITICISMS MAY BE LEVELLED AGAINST THIS METHOD OF CALCULATION IT WAS ONLY USED IN THIS CASE TO CORROBORATE BY MEANS OF A CROSS - CHECK RESULTS OBTAINED BY ANOTHER METHOD . THE APPLICANT ADDUCES NO EVIDENCE TO SUPPORT ITS ALLEGATIONS OR IN PARTICULAR TO PROVE THE USE OF LARGE QUANTITIES OF NEW PIG-IRON INSTEAD OF CAST - IRON SCRAP WHICH UNDER THE EQUALIZATION RULES IS SUBJECT TO THE PAYMENT OF CONTRIBUTIONS . ( DD ) THIS SUBMISSION IS THEREFORE UNFOUNDED ( C ) INFRINGEMENT OF ARTICLES 4 OF DECISIONS NOS 2/57 AND 16/58 THE APPLICANT CLAIMS THAT THE DEFENDANT BASED ITS CALCULATIONS EXCLUSIVELY ON THE CONSUMPTION OF SCRAP WITHOUT MAKING ANY DEDUCTIONS FOR OWN ARISINGS AND REDUCTION OF STOCKS AS PROVIDED BY DECISIONS NOS 2/57 AND 16/58 . WITH REGARD TO THE DEDUCTIONS FOR THE REDUCTION OF STOCKS, THE DEFENDANT HAS SHOWED, WITHOUT BEING CONTRADICTED BY THE APPLICANT, THAT THE LATTER ONLY EVER KEPT SUFFICIENT STOCKS FOR A FEW DAYS' PRODUCTION, SO THAT THERE WAS NO NECESSITY TO TAKE THE REDUCTION IN STOCKS INTO CONSIDERATION FOR THE CALCULATION OF THE CONTRIBUTION . P.54 WITH REGARD TO THE DEDUCTIONS FOR THE APPLICANT'S OWN ARISINGS, THE HIGH AUTHORITY MADE AND APPLIED ITS OWN ESTIMATE, BECAUSE THE APPLICANT FAILED TO SUPPLY IT WITH PARTICULARS OF ITS OWN PRODUCTION AND BECAUSE THE APPLICANT FAILED TO SUPPLY EVIDENCE THAT, OWING TO SPECIAL CIRCUMSTANCES, THE AMOUNT OF THE ARISINGS HAD BEEN HIGHER THAN THE TONNAGE TAKEN INTO ACCOUNT . FOR THESE REASONS THIS COMPLAINT IS UNFOUNDED . ( D ) INFRINGEMENT OF ARTICLES 80 AND 81 OF THE TREATY THE APPLICANT SUBMITS THAT THE DEFENDANT EXCEEDED ITS POWERS BY INCLUDING IN THE BASIS OF ASSESSMENT TO CONTRIBUTION SCRAP CONSUMED FOR THE PRODUCTION OF FISH-PLATES, DOG-SPIKES AND PLATES AS THESE PRODUCTS ARE OUTSIDE THE SCOPE OF THE ECSC TREATY . AS BECAME APPARENT DURING THE EXAMINATION OF THE FIRST SUBMISSION IT IS NOT DISPUTED THAT THE APPLICANT ITSELF PRODUCED THE STEEL REQUIRED FOR THE MANUFACTURE OF THE ABOVEMENIONED FINISHED PRODUCTS AND THAT IT WAS THEREFORE THE SCRAP USED AS THE RAW MATERIAL FOR THE PRODUCTION OF STEEL WHICH WAS QUITE PROPERLY MADE SUBJECT TO EQUALIZATION . IT FOLLOWS THAT THIS SUBMISSION IS UNFOUNDED . ( E ) INFRINGEMENT OF ARTICLE 47 OF THE TREATY THE APPLICANT SUBMITS THAT, AS THE CHECKS CARRIED OUT IN 1961 BY FIDITAL WERE NOT AUTHORIZED BY THE HIGH AUTHORITY, THEY COULD NOT BE TAKEN INTO CONSIDERATION IN CALCULATING THE AMOUNT OF CHARGEABLE SCRAP . THE CHECKS CARRIED OUT BY THE HIGH AUTHORITY PURSUANT TO ARTICLE 47 OF THE TREATY THROUGH PRIVATE AUDITING COMPANIES ARE NOT A DELEGATION BY IT OF ITS POWERS BUT THE EXERCISE BY IT OF ITS OWN POWERS BY MAKING USE OF INFORMATION WHICH IT HAS OBTAINED ON ITS OWN RESPONSIBILITY . IT IS NOT DISPUTED THAT THE HIGH AUTHORITY HAD AGREED TO THE CHECKS CARRIED OUT BY FIDITAL . IT FOLLOWS THAT AN UNDERTAKING SUBJECT TO INVESTIGATION CANNOT DISPUTE THE PROCEDURES ADOPTED FOR THE SELECTION OF THOSE APPOINTED TO CARRY OUT THE INVESTIGATION BUT CAN ONLY CHALLENGE THE RESULTS BY ADDUCING EVIDENCE THAT THEY ARE INCORRECT . THEREFORE THE RESULTS OF THE INVESTIGATIONS CARRIED OUT BY FIDITAL MUST BE TAKEN INTO ACCOUNT UNTIL THE APPLICANT PROVES THAT THEY ARE WRONG . THIS SUBMISSION IS THEREFORE UNFOUNDED . P.55
2 . SUBMISSION RELATING TO THE INDIVIDUAL DECISION FIXING THE AMOUNT OF THE EQUALIZATION CONTRIBUTIONS DURING THE ORAL PROCEDURE THE APPLICANT ALLEGED THAT THE CONTESTED INDIVIDUAL DECISION HAD NO LEGAL BASIS, BECAUSE THE HIGH AUTHORITY ADOPTED ON 15 DECEMBER 1965 GENERAL DECISION NO 19/65 RELATING TO THE ESTABLISHMENT OF FINAL ACCOUNTS FOR THE EQUALIZATION OF IMPORTED FERROUS SCRAP AND SCRAP TREATED AS SUCH, WHICH LAYS DOWN NEW CRITERIA FOR FIXING THE AMOUNT OF THE CONTRIBUTIONS PAYABLE . IN THESE PROCEEDINGS THE LEGAL SITUATION TO BE TAKEN INTO ACCOUNT IS THAT EXISTING WHEN THE CONTESTED DECISION WAS TAKEN . MOREOVER, SINCE THIS LATTER DECISION WAS ONLY PROVISIONAL, THE DEFENDANT WILL HAVE TO TAKE INTO CONSIDERATION THE NEW FACTORS INTRODUCED BY DECISION NO 19/65 IN ORDER TO RECTIFY, IF NECESSARY, THE AMOUNT OF THE EQUALIZATION DEBT WHICH THE APPLICANT IS LIABLE TO PAY . THEREFORE THIS SUBMISSION IS UNFOUNDED .
3 . SUBMISSIONS RELATING TO THE GENERAL DECISIONS UPON WHICH THE CONTESTED INDIVIDUAL DECISIONS ARE BASED ( A ) THE DETERMINATION OF THE ACCOUNTING PERIODS THE APPLICANT CRITICIZES GENERAL DECISION NO 19/30 ON THE GROUND THAT THIS DECISION LAID DOWN AN ACCOUNTING PERIOD OF 12 MONTHS FOR THE PERIOD DURING WHICH DECISION NO 22/54 WAS TO REMAIN IN FORCE AND AN ACCOUNTING PERIOD OF 22 MONTHS FOR THE PERIOD DURING WHICH DECISION NO 14/55 WAS TO REMAIN IN FORCE . ON THIS ISSUE THE APPLICANT HAS NOT ADDUCED ANY EVIDENCE THAT THE ADOPTION OF SHORTER ACCOUNTING PERIODS WOULD HAVE LED TO A REDUCTION IN THE AMOUNT OF ITS CONTRIBUTIONS . ON THE CONTRARY, THE DEFENDANT IN ITS REJOINDER SHOWED THE VERY OPPOSITE, NAMELY THAT THE APPLICANT'S EQUALIZATION DEBT WOULD HAVE BEEN HIGHER IF, IN ACCORDANCE WITH ITS REQUEST, ACCOUNTING PERIODS OF THREE MONTHS HAD BEEN APPLIED . THIS SUBMISSION IS THEREFORE UNFOUNDED . ( B ) INCLUSION IN THE CALCULATION OF SCRAP ' TREATED AS IMPORTED ' ( AA ) THE APPLICANT SUBMITS THAT SCRAP TREATED AS IMPORTED HAS BEEN WRONGLY INCLUDED IN THE EQUALIZATION OF PRICES, SO THAT THE TOTAL EQUALIZATION CHARGES AND THEREFORE THE AMOUNT OF THE CONTRIBUTIONS PAYABLE BY THE APPLICANT HAVE BEEN INCREASED . ( 1 ) ARTICLE 1 OF DECISION NO 22/54 ONLY MENTIONS IMPORTED SCRAP WITH THE RESULT THAT, AT LEAST DURING THE PERIOD WHEN THIS DECISION WAS IN FORCE, SCRAP TREATED AS SUCH COULD NOT BE INCLUDED IN THE EQUALIZATION CALCULATION UNDER DECISIONS NOS 18/60 AND 20/60 . P.56 ARTICLE 2 OF DECISION NO 22/54 EXPRESSLY STATES THAT ' UNDERTAKINGS...SHALL PAY THE CONTRIBUTIONS REQUIRED TO FINANCE THE EQUALIZATION OPERATIONS IN RESPECT OF SCRAP IMPORTED FROM THIRD COUNTRIES OR SCRAP TREATED AS SUCH ... '. THE ARGUMENT THAT NEITHER THE HEADING OF DECISION NO 22/54 NOR ARTICLE 1 THEREOF MENTIONS SCRAP TREATED AS IMPORTED CANNOT BE UPHELD, BECAUSE A DECISION LIKE ANY OTHER LEGISLATIVE PROVISION MUST BE INTERPRETED AS A WHOLE . ( 2 ) THE APPLICANT SUBMITS THAT THE EXPRESSIONS ' EXPENSIVE SCRAP ' AND ' SCRAP TREATED AS IMPORTED ' CANNOT BE ACCURATELY DEFINED, SO THAT THE ADMINISTRATION IS ENTITLED TO DECIDE WHICH KINDS OF SCRAP OTHER THAN IMPORTED SCRAP SHALL BE SUBJECT TO EQUALIZATION AND THAT THE REASONS FOR THIS ENLARGEMENT OF THE EQUALIZATION SCHEME HAVE NOT BEEN GIVEN . THE APPLICANT HAS NOT PROVED THAT THE GENERAL DECISIONS WHICH IT CRITICIZES UNEQUIVOCALLY PERMIT THE INCLUSION IN THE EQUALIZATION SCHEME OF AMOUNTS OF SCRAP WHICH COULD NOT ON ANY REASONABLE BASIS BE SO INCLUDED . THE STATEMENTS OF ACCOUNT RELATING TO THE EQUALIZATION OF SCRAP ARE ONLY PROVISIONAL . IT WILL NOT BE POSSIBLE UNTIL THE INVESTIGATIONS IN PROGRESS ARE COMPLETED TO ASCERTAIN FINALLY THE AMOUNT OF EQUALIZATION PAYMENTS OBTAINED BY FRAUD OR TO DETERMINE THE AMOUNT WHICH MAY EVENTUALLY BE RECOVERED . THEREFORE THE APPLICANT CANNOT AT PRESENT PUT FORWARD ANY REASON FOR DISPUTING IN THIS RESPECT THE PROVISIONAL EQUALIZATION CALCULATIONS . ( CC ) FOR THESE REASONS THIS SUBMISSION IS UNFOUNDED . ( C ) CHANGES IN THE AMOUNTS OF SCRAP BROUGHT INTO EQUALIZATION THE APPLICANT SUBMITS THAT THE EQUALIZATION CALCULATIONS ARE INACCURATE INASMUCH AS THE FIGURES RELATING TO THE SCRAP BROUGHT INTO EQUALIZATION HAVE CHANGED WITHOUT ANY EXPLANATION OF THIS FACT HAVING BEEN SUPPLIED BY THE HIGH AUTHORITY . THE STATEMENTS OF ACCOUNT RELATING TO EQUALIZATION ARE ONLY PROVISIONAL AND REFLECT THE STAGE REACHED IN THE INVESTIGATIONS AND CHECKS BEING CARRIED OUT . THE REQUIREMENT THAT THE REASONS UPON WHICH GENERAL DECISIONS RELATING TO EQUALIZATION ARE BASED MUST BE STATED DOES NOT INCLUDE AN OBLIGATION TO REPRODUCE IN DETAIL ALL THE RESULTS OF THE CHECKS . THIS SUBMISSION IS THEREFORE UNFOUNDED . P.57 ( D ) ECONOMIES IN THE USE OF SCRAP BY THE INCREASED USE OF PIG-IRON THE APPLICANT SUBMITS THAT THE GRANT OF A BONUS UNDER DECISION NO 26/55 FOR USING PIG - IRON IN SIEMENS AND MARTIN FURNACES AND THE GRANT OF A BONUS UNDER DECISION NO 3/56 FOR USING THOMAS STEEL IN ELECTRIC FURNACES AMOUNTS TO DISCRIMINATION AND DISTORTS THE CONDITIONS OF COMPETITION TO THE PREJUDICE OF UNDERTAKINGS WHICH, LIKE THE APPLICANT UNDERTAKING, USE SOLID-CHARGE FURNACES . THE BONUS GRANTED TO UNDERTAKINGS UNDER THE CONDITIONS LAID DOWN IN DECISIONS NOS 26/55 AND 3/56 ONLY AMOUNTED TO COMPENSATION PAYABLE TO THEM FOR THE INCREASE IN THEIR RUNNING COSTS CAUSED BY AN INCREASED INPUT OF PIG-IRON . THEREFORE THESE UNDERTAKINGS DID NOT DERIVE A FINANCIAL ADVANTAGE FROM THE BONUS . IT FOLLOWS THAT THE GENERAL DECISIONS CRITICIZED BY THE APPLICANT WERE INCAPABLE OF EITHER DISCRIMINATING AGAINST IT OR OF DISTORTING THE CONDITIONS OF COMPETITION TO ITS DETRIMENT . THIS SUBMISSION IS THEREFORE UNFOUNDED . ( E ) THE FIXING OF THE EQUALIZATION PRICES ( AA ) THE APPLICANT SUBMITS THAT THE EQUALIZATION PRICES COULD NOT HAVE BEEN VALIDLY DETERMINED BECAUSE THE PRICES PAID FOR COMMUNITY SCRAP HAVE NOT BEEN ACCURATELY ESTABLISHED OR CHECKED . THE FACTS UPON WHICH THE CALCULATION OF THE EQUALIZATION PRICES HAVE TO BE BASED HAVE BEEN TAKEN FROM THE MONTHLY DECLARATIONS OF UNDERTAKINGS SETTING OUT THE PRICES WHICH THEY PAID . THE HIGH AUTHORITY CAREFULLY ESTABLISHED THE ACCURACY OF THESE DECLARATIONS BY CHECKING THE PURCHASE INVOICES . ( BB ) THE APPLICANT ALSO SUBMITS THAT THE DETERMINATION OF UNIFORM EQUALIZATION PRICES FOR THE WHOLE OF THE COMMUNITY HAD A DISCRIMINATORY EFFECT BECAUSE OF THE DIFFERENCES IN THE PRICES OF COMMUNITY SCRAP WHICH IN FACT EXISTED INSIDE THE COMMUNITY . IT CLAIMS THAT IN FACT THE PRICES WHICH IT PAID FOR SCRAP INSIDE THE MARKET WERE DISTINCTLY HIGHER THAN THE EQUALIZATION PRICES AND THAT FOR THIS REASON IT HAS BEEN PLACED AT A DISADVANTAGE BY COMPARISON WITH UNDERTAKINGS WHICH COULD ACQUIRE SCRAP INSIDE THE MARKET AT A PRICE LOWER THAN THE EQUALIZATION PRICE . IT IS A FEATURE OF THE MARKET FOR SCRAP, THAT HAVING REGARD TO THE PLACE OF ESTABLISHMENT OF THE CONSUMING UNDERTAKINGS, THERE ARE PRICE VARIATIONS, WHICH ARE COMPATIBLE WITH THE GENERAL UNITY OF THIS MARKET . THE EQUALIZATION PRICE IS THE WEIGHTED AVERAGE OF THE DIFFERENT PRICES RULING ON THE MARKET . THE APPLICANT HAS NOT PROVED THAT THE OPERATION OF THE EQUALIZATION SCHEME HAS INFLUENCED THESE PRICE DIFFERENCES OR THAT IT HAS INCREASED THE DISADVANTAGES WHICH IT HAS SUFFERED COMPARED WITH MORE FAVOURABLY PLACED UNDERTAKINGS . ( CC ) FINALLY THE APPLICANT PLEADS INFRINGEMENT OF ARTICLE 47 OF THE TREATY ON THE GROUND THAT ALL THE FACTORS NECESSARY TO DETERMINE THE VARIOUS EQUALIZATION DATA HAVE NOT BEEN PUBLISHED OR NOTIFIED TO THE UNDERTAKINGS . THE RATE OF CONTRIBUTION AND THE EQUALIZATION PRICE, FACTORS WHICH ARE NECESSARY TO ENABLE UNDERTAKINGS SUBJECT TO EQUALIZATION TO FIX THEIR SALE PRICES, WERE ALWAYS COMMUNICATED TO THEM IN DUE TIME, FIRST BY THE AUTHORITIES IN BRUSSELS OR BY THEIR REGIONAL OFFICES AND LATER BY THE HIGH AUTHORITY ITSELF . THE HIGH AUTHORITY IS NOT OBLIGED UNDER ARTICLE 47 OF THE TREATY TO MAKE KNOWN TO THE UNDERTAKINGS THE OTHER FACTORS RELATING TO EQUALIZATION CALCULATIONS . ( DD ) FOR THESE REASONS THIS LAST SUBMISSION MUST BE DISMISSED AS UNFOUNDED .
4 . THE REQUEST BY THE APPLICANT FOR MEASURES OF INQUIRY IT IS NOT NECESSARY TO GRANT THE APPLICANT'S REQUEST FOR AN ORDER THAT MEASURES OF INQUIRY BE ADOPTED . DURING THE PROCEEDINGS THE APPLICANT HAS HAD THE OPPORTUNITY TO ADDUCE THE EVIDENCE NECESSARY TO SUPPORT ITS SUBMISSIONS .