Syria Update
27 November to 03 December, 2019
The Syria Update is divided into two sections. The first section provides an in-depth analysis of key issues and dynamics related to wartime and post-conflict Syria. The second section provides a comprehensive whole of Syria review, detailing events and incidents, and analysis of their respective significance.
Syria 2020 budget approved: more SYP, less USD
In Depth Analysis
On November 26, the Syrian Parliament approved the 2020 Syrian national budget of 4 trillion SYP ($4.3 billion), of which 1.4 trillion SYP ($1.5 billion) will be carried as debt. Without doubt, the most notable aspect of the budget is the self-evident effect of the progressive erosion of the Syrian lira. When it was released in draft form in October, the 4 trillion SYP budget equated to $6.1 billion (Syria Update 2-8 October); since then, its value has shrunk by $1.8 billion. This plummet is even more apparent when seen in the context of the 2019 budget, which was valued at 3.88 trillion SYP, then equivalent to $7.8 billion. To date, there are no signs that the Syrian lira’s freefall will be arrested any time soon; this decline will continue to frustrate long-range state planning, while whittling away at the value of budget allocations and checking the state’s ability to support vital imports and subsidies.
Insofar as the Syrian street is concerned, however, the 2020 budget is distinguished not by what it contains, but by what it lacks: allocations for consumer support to mitigate the effects of a precipitous and continuing decline in Syrians’ purchasing power. The line item for ‘social support’ — to include subsidies for fuel, agricultural production, and flour — fell from 811 billion SYP in 2019 (then worth $1.6 billion) to 373 billion SYP ($401 million) in the newly approved budget. Crucially, this comes as the effects of currency collapse are already being deeply felt throughout Syria. As of 2 December, artisans, craftsmen, and small and medium producers in communities as far afield as Adra, A‘zaz, Afrin, and Menbij, have been compelled to halt their work as a result of the rising costs of raw materials. Likewise, restaurants and cafes — mainstays of Syria’s increasingly service-oriented economy — are also closing their doors, as consumers brace for further uncertainty.
As prices rise, confidence in the Government plummets
Central authorities have responded to price increases and nationwide shortages of staple goods by policing markets; however, such measures should be viewed as evidence of the state’s inability to address the root causes of the crisis by stabilizing prices or facilitating imports at volumes needed to meet demand. Nonetheless, state authorities have offered a multitude of explanations for the prevailing economic conditions. Predictably, speculators and exchange offices have been scapegoated, as have smugglers and tax cheats. Additionally, on 2 December, Majd Mazrah, the director of the General Authority for Competition and Preventing Monopoly, described current shortages as a temporary result of crackdowns to remove illicit goods from the market. In one such incident, the Homs Directorate of Internal Trade and Consumer Protection reportedly closed more than 200 shops, due to violations ranging from a failure to list prices publicly to selling goods of unknown origin. But as a means of calming uncertain markets, such measures are superficial at best, and risk driving more activity underground and into the black market. More fundamentally, rising prices and empty store shelves are a result of the Central Bank’s inaction and its progressive reductions in support for critical imports throughout 2019.
Additionally vexing for consumers is the fact that, during parliamentary debate over the budget, Finance Minister Mamoun Hamdan stated that there was “no need” to adjust the budget in a bid to stabilize prices, due to the recent increase in salaries and pensions (Syria Update 20-26 November). This is wishful thinking. The wage and pension increases will reportedly saddle the Government of Syria with a massive 495.4 billion SYP ($532 million) in additional expenditures — without doubt a massive undertaking for the beleaguered government. For consumers, however, the relief they brought will be short-lived. Nominal rises in payrolls and pensions have already begun to feed inflation; in the long run, they will almost certainly force the Syrian Central Bank to resort to self-defeating measures to stop the gap, namely by increasing the money supply.
An emergency response?
In some respects, the 2020 Syrian budget is an exercise in triage. With it, the Government of Syria has strained to meet its immediate needs, with little consideration (or capacity) to entertain long-range planning imperatives. Without doubt, the ability of outside observers to draw conclusions from the budget is complicated by the fact that the budget is incomplete, and by no means transparent. Defense spending and other large portfolios do not appear in the budget. Curiously, support for electricity constituted the largest single allocation of the draft budget discussed in October (711 billion SYP); however, the large deficit carried by Syria’s electricity authority has now been written-out of the final state budget. According to well-placed local sources, many other allocations are likewise excluded from public-facing budget declarations. As such, the Syrian state’s deficit may be far deeper than is publicly recognized.
Looking ahead, there will be few means of generating revenue to improve the state’s balance sheets. Syria’s most productive oil and gas fields are now under the firm control of U.S.-led international coalition forces and their production runs are unlikely to serve the needs of Damascus (see Point No. 4, below). Proposals made by the Syrian Finance Ministry to promote growth as a means of raising import tax revenues are decidedly unrealistic. Catching tax cheats — another proposed source of revenue — is also improbable, given that corruption is endemic at all levels of the Syrian state apparatus. The suggestion that the revenue shortfall can be plugged by issuing government bonds and expanding the tax base is impracticable and unlikely to supply the sums needed to buoy the economy. For the time being, the threat of international sanctions and restrictive measures will also deter the foreign investment that Syrian authorities look to as a future economic lifeline. Repatriation of foreign deposits is also a dim prospect, notwithstanding the uncertainty in neighboring Lebanon, formerly the safe haven financial entrepot for Syrian trade. Finally, the spontaneous revival of agricultural production anticipated by Syrian authorities is likewise unimaginable.
The ultimate effect of these conditions will be to increase Syria’s reliance on outside capital — and outside actors. Further concessions to foreign investors, namely Iran and Russia, are almost certain to take place at an accelerated pace. Notably, the 2020 Syrian budget allocates a paltry 50 billion SYP ($53 million) to reconstruction. This is identical (in Syrian pounds, if not dollars) to the sum allocated to reconstruction in the 2019 budget, and it falls woefully short of overall reconstruction costs, which are estimated to be in the hundreds of billions of dollars. Iran is reported to have recently been granted concessions to undertake reconstruction in Syria, yet there is little doubt that Damascus will continue to look to Europe for funding that neither it, nor its closest allies, can supply.
Whole of Syria Review
1. SDF agreement opens door to expanded Russian presence in northeast Syria
Tal Tamr, Al-Hasakeh governorate: On 1 December, SDF commander Mazloum Abdi stated that the SDF and the Government of Russia had reached a security agreement for the deployment of Russian forces in Tal Tamr, Ein Issa, and Amouda. As of 3 December, local sources indicate that the agreement has not been implemented; they note that although the SDF has begun to transfer its command centers from Ein Issa (moving, according to conflicting reports, to Ar-Raqqa or Quamishli cities), its forces have remained present in the areas stipulated under the agreement. As per local and media sources, negotiations between Turkey and Russia concerning future zones of control and influence in northeast Syria continue to take place at the Al Aliya silos, located on the M4 highway south of Tal Tamr and Ras El Ein. According to local sources, the negotiations have resulted in the National Army handover of the silos to the Government of Syria and Russian forces, with the further stipulation that armed groups backed by Turkey withdraw to areas 2 km north of the M4 highway.
Analysis: Russian forces entered northeast Syria in small, but unverifiable, numbers alongside their Government of Syria partners in the wake of the military agreement between the SDF and Government of Syria in October. However, the deal now struck between the SDF and Russia offers a firmer basis for Russia to take on a more central military role that extends beyond the border areas designated for joint Turkish-Russian patrols. Russia’s objectives in northeast Syria can be characterized, to borrow a phrase, as keeping the Americans out, the SDF in, and the Turks down. Already, Russia has filled the U.S.’s shoes by conducting joint patrols with Turkey and deconflicting between the SDF and Turkish forces. Russia’s efforts to build trust with the SDF further close the door to regional autonomy for a breakaway Kurdish region of Syria. Not only will this satisfy Russia’s demands vis-a-vis Syria’s territorial integrity, but it will also give Russia a valuable regional ally as it seeks to secure its own investments in Kurdistan Regional Government areas of Iraq. A further consideration is the fraught Russian-Turkish relationship. Although Russia and Turkey have nurtured a surprisingly robust partnership throughout the course of the Syria conflict, their immediate regional ambitions do clash at times, giving Russia ample reason to seek warmer relations with a powerful ally such as the SDF (Syria Update 13-19 November). In the immediate term, the Russian deployment to Tal Tamr, Ein Issa, and Amouda is part of a military agreement, likely intended to delineate the bounds of Turkish advances in northeast Syria. Looking further ahead, whether this arrangement will impact mobility, transportation, or access to Self Administration areas will be determined by the Self Administration’s ability to sustain its relatively independent course, and preserve its own administrative prerogative. To date, the status quo in these respects remains unchanged. However, it is also important to note that — unlike U.S. forces — Russia’s expanding footprint in northeast Syria is unlikely to be reversed.
2. Despite limited advances, offensive intensifies in Idleb and Lattakia
Idleb and Lattakia governorates: Throughout the reporting period, local and media sources reported that a series of clashes took place between Government of Syria forces and armed opposition groups on active frontlines in southeast Idleb governorate and in Kabanah, Lattakia governorate. On 30 November, a Government of Syria incursion to opposition-held territory in Kabanah was repelled. On the same day, armed opposition groups made limited advances in Aajaz, Rasm El Ward, Istablat, and Sarja, in southeastern rural Idleb, which were quickly reversed when met with intense shelling and airstrikes. Meanwhile, Russia and the Government of Syria continued air raids and bombardment targeting various communities in south, southeast, and eastern rural Idleb governorate, including Kafr Nobol, Maar Tahroma, Hass, Kafruma, Sheikh Mustafa, Ma’arrat An Nu’man, Saraqeb, Kanasfara, Ihsem, and Urm El Joz. Most notably, local sources indicated that airstrikes targeted local markets in Saraqeb and Ma’arrat An Nu’man, resulting in an estimated 25 civilian deaths and 40 injuries.
Analysis: The widening scope and rising intensity of clashes and aerial bombardment witnessed during the reporting period may signal a step change in the Government of Syria’s campaign to retake priority areas — namely the M5 highway and key northwest Syria communities, including Ma’arrat An Nu’man and Saraqeb — from armed opposition forces. Nonetheless, the intensifying counter-assaults launched by opposition groups have stymied this undertaking, while rocket attacks on military airports in Hama and Abul Thohur may signal the willingness of armed opposition groups to draw a firm line in the sand. As noted in previous COAR analysis, the Government of Syria’s offensive is widely believed to carry the implicit backing of a Russian-Turkish agreement — likely one half of a deal that has already seen Russia concede to Turkey large swaths of northeast Syria, with the understanding that Russia and the Government of Syria will be free to pursue their objectives in the northwest. Notably, the actual degree of control exercised by Turkey over armed opposition groups it supports in northwest Syria has long been a subject of debate; whether Turkey has the leverage to facilitate the withdrawal of such groups from priority areas targeted by the current Government of Syria offensive is now a question of the foremost importance. This offensive has proceeded at a measured pace, likely in tacit acceptance of Turkey’s wish to avoid a significant wave of cross-border displacements. Should frontlines remain frozen, the intensity of bombardment in northwest Syria is likely to increase, as the Government of Syria moves to break this deadlock.
3. Dar’a opposition erects checkpoints to challenge Damascus over detainees
Dar’a governorate: On 1 December, local sources reported that former Free Syrian Army combatants had erected three checkpoints on the road linking Yadudeh and Al-Dahyieh, in protest against the Government of Syria’s systematic targeting of reconciled combatants and its refusal to satisfy local demands for the release of detainees. According to these sources, the combatants manning the makeshift checkpoints screened ID cards in search of Government of Syria–affiliated individuals and detained a Government of Syria military security figure. Protesters are also reported to have closed the road linking Maarba and Busra Esh-Sham, likewise to protest the status of detainees and the Government of Syria deployment of 4th Division combatants outside Dar‘a governorate. Local sources also reported a noticeable spike in anti–Government of Syria demonstrations elsewhere in the governorate, including Dar‘a city, Tafas, Mzeirib, Al Kerk, Nasib, and Ash-Shajarah.
Analysis: The establishment of ad-hoc checkpoints is highly noteworthy as an assertion of defiance on the part of the reconciled former FSA fighters, and it speaks to the degree to which atomized armed actor control has permitted anti-Government sentiment to surface in southern Syria (Security Archipelago: Security Fragmentation in Dar‘a Governorate). It is possible that the undertaking was calculated to force further concessions from the Government of Syria following the release of as many as 118 detainees the previous week (Syria Update 20-26 November). Unsatisfied with the scale of the release, these actors may view further escalation as the clearest means of securing the release of further detainees. For its part, the Government of Syria clearly understands the seriousness of the challenges it faces in the restive south. Facing persistent flare-ups in the region, the Government has continued to seek the intercession of local notables, whose buy-in central authorities view as essential to the difficult task of pacifying southern Syria. Having met with limited success in such initiatives to this point, the Government of Syria is unlikely to succeed in containing a growing (though seemingly decentralized) popular resistance that bears the trappings of a nascent insurgent opposition. Should the Government fail to win buy-in, detentions, conscriptions, and arrests are likely to continue, thus fueling the cycle of violence that now characterizes southern Syria.
4. Government bombs oil sites in bid to block smuggling
Al-Bab and Jarablus, northern Aleppo governorate: On 27 November, Syrian state media issued a cryptic report suggesting that the Government of Syria had carried out the recent airstrikes targeting oil infrastructure in Al-Bab and Jarablus that resulted in the death of eight individuals. These strikes had initially been reported on 25 November. At least 10 crude oil refining facilities, located on the outskirts of the cities, were reportedly targeted, due to their use by networks smuggling oil to Turkey. Syrian state media also reported that tanker trucks from northeast Syria “were destroyed,” while noting that the ostensibly Kurdish smugglers had been dealing with “their inveterate enemy,” Turkey. The report added that “strict measures will be taken against any operation to smuggle oil stolen from Syrian territory outside Syria.”
Analysis: Although the specifics of these oil smuggling operations are difficult to confirm, the episode is a reflection of the increasing pressure that the Government of Syria faces to secure its domestic oil supply. The most obvious factor now shaping Syria’s oil supply is the loss of output from oil fields in eastern Syria. Although these fields are now under the nominal control of the SDF, the latter is facing increasing pressure from U.S. forces to sever the crossline oil trade that has long been brokered by the Qaterji company to mutual benefit (Syria Update 6-12 November). Iran’s reactivation of a $3 billion credit line to Syria may provide some support to meeting shortfalls in domestic production during the fuel-intensive winter months (Syria Update October 23-29), yet it is doubtful that Iran — embattled by a domestic uprising and isolated abroad — will be capable of guaranteeing that all of Syria’s fuel needs are met. A further cause of Syria’s chronic oil shortages is a series of bottlenecks resulting from damaged and inefficient infrastructure. Media sources reported that President Bashar Al-Assad has personally overseen grants that cede to various Qaterji enterprises the rights to develop two oil refineries and an oil terminal in Tartous. While such measures will provide the Government with greater energy security in the long term, they will do little to stopgap current needs. What is now most evident is that the crossline oil trade in Syria is in flux; how needs will be met in the meantime remains to be negotiated. The Government’s threats of decisive action against smuggling do reflect the deep need to stop the outflow of domestically sourced oil, but it is unclear whether such attacks will be part of a wider strategy to prevent smuggling in the longer term.
5. Local tribal militias clash in Aleppo
Aleppo city, Aleppo governorate: Between 25 and 28 November, local media sources reported that clashes had taken place among various local militias in the eastern neighborhoods of Aleppo city. As per these sources, the Al-Berri militia, a constituent of the Russia-supported Doshka Al-Nimr Brigade, raided several bases of the Al-Baqir Brigade, an armed group primarily comprised of Al-Beggara and Asasinah tribesmen and known for its ties to the Islamic Revolutionary Guard Corps. The raid was reportedly met with limited resistance, and it ended with the Al-Berri militia in secure control over the Bab Neirab, Bab Hadid, Karm El Jabal, Al-Maysar, and Ferdaws neighborhoods of eastern Aleppo city, as well as Jeb Al Qebber and Sahet El Hatab, in the center of the city. According to local sources, Russian Military Police refrained from taking action to contain intergroup confrontations in the city, leading some to see the Al-Berri raid as an initiative undertaken at the behest of Russia, as a means of curtailing the presence of Iranian militias in the city.
Analysis: At present, the trigger for the confrontations is unclear, but there can be little doubt that both Russia and local tribal figures played a role in the incident — even if indirectly. Precedent exists for Russian forces to undertake efforts to contain intergroup clashes in Aleppo city (Syria Update 1-7 August); their unwillingness to intercede in this case suggests Russian acceptance of the operations. Nonetheless, such clashes are more likely to be strongly shaped — if not driven — by localized feuds and grievances among individual families and tribes. Tribal identity is a touchstone of armed group mobilization in Aleppo city. Throughout the war, intertribal dynamics have been a driving force behind local armed group competition, as well as conflict mediation. For the foreseeable future, in the absence of effective command and control by any major party to the conflict, security in Aleppo is likely to remain dependent upon the mediation and intervention of local notables, including tribal figures, who are likely to prioritize efforts to convert military primacy into economic or political advantage. In the present case, the Al-Berri family is reportedly known for its involvement in trade; the growing influence of the Al-Berri militia might well augur a wider role in local economic markets as well.
6. Despite claims of its collapse, Constitutional Committee continues work, slowly
Geneva, Switzerland: Throughout the reporting period, the blocs in the Syrian Constitutional Committee representing the Government of Syria, on the one hand, and the Syrian opposition, on the other, have persisted in leveling charged accusations that the other party has set out to obstruct and delay the constitutional reform process. Among the myriad accusations flying in Geneva, Yahya Al-Aridi, a spokesperson for the opposition bloc, stated that Government delegates had walked out of the Constitutional Committee’s second meeting over a raft of procedural complaints; the incident prompted one source identified as a “Western diplomat” to declare that “the situation is clearly blocked,” according to Turkish media. Similar accusations were leveled by the Government of Syria against opposition-aligned representatives in Geneva. Nonetheless, despite prevailing media narratives that suggest the reform process has broken down entirely, local sources close to the Constitutional Committee report that its work continues, albeit at a slow pace. These sources note that the third session in Geneva will proceed as planned, in two week’s time.
Analysis: Without doubt, the parties in Geneva have been at loggerheads over a host of issues, ranging from the fundamentals of the reform they are mandated to undertake, to the scope of the working agenda and the length of the working sessions (Government representatives advocated for a two-hour day). Nonetheless, it is important not to overlook the important fact that the committee continues to meet, which belies the prevailing narrative that talks have collapsed altogether; on the contrary, this persistence suggests that (for now) the slow, incremental progress that the committee was designed to undertake is happening. In this context, heated rhetoric by parties to the committee should neither be received with surprise, nor should it be seen as a failure of the process writ large. UN Special Envoy for Syria Geir Pedersen has prioritized efforts to slowly build trust between the blocs and has stated that “things have gone much better than what most people expected.” Nonetheless, insofar as the modest goal of the brokered discussions has been to bring diametrically opposed blocs into direct conversation, the process will have to overcome psychological barriers, as well as those raised by divergent legal and political views. According to local sources, one member of the committee, a former armed opposition figure, broke down in tears during the committee’s proceedings, as he recalled the siege and reconciliation of eastern Ghouta.
7. Basic service debt poses new HLP risks in southern Damascus
Southern Damascus suburbs: On 27 November, media and local sources reported that the Government of Syria Directorate of Electricity had begun to collect debt owed for electricity and water bills dating back to 2012 in southern Damascus, including the suburbs of Yalda, Babila, and Beit Sham. Government of Syria–aligned security forces are reportedly stopping civilians at checkpoints and demanding that they produce receipts for such payments; civilians who are unable to demonstrate the full payment of their bills are threatened with suspension of provision of public services, such as electricity and water. Local sources report that, as a result of the crackdown, residents have hastened to settle their service debts for fear of facing movement restrictions, losing access to essential services, or being arrested. Outstanding bills for both electricity and water reportedly range from 20,000 SYP to 100,000 SYP ($21 to $107). Since large portions of the population are currently in dire economic straits, many are paying off their debt in instalments.
Analysis: In myriad contexts throughout the reconciled areas of Syria, mobility, access to services, and the permission to return have been conditional upon settling service debts that have accumulated over the course of the conflict. Such bills have been levied in dubious circumstances, including cases in which individuals have been displaced to other communities or outside Syria. In some cases, such bills relate to services provided by authorities that were not affiliated with the Government of Syria at all, raising further doubt over their essential legitimacy. These are not the only concerns to be raised, however. What distinguishes the southern Damascus suburbs from other communities where such measures have been imposed is the prominence of Damascus ring communities in future reconstruction plans. Acquiring proof that water and electricity debts have been paid in full will be important for residents seeking to establish legal ownership under the patchwork of reconstruction laws that pose an acute risk to their property. Notably, these communities have a high rate of informal housing and experience high levels of poverty, meaning that even modest fees represent an onerous burden for residents. As such, even if reconstruction plans in southern Damascus are not widely implemented at pace, the consequences of such bills for mobility and security of vulnerable populations are nonetheless a poignant and pervasive concern.
Key Readings
The Open Source Annex highlights key media reports, research, and primary documents that are not examined in the Syria Update. For a continuously updated collection of such records, searchable by geography, theme, and conflict actor, and curated to meet the needs of decision-makers, please see COAR’s comprehensive online search platform, Alexandrina, at the link below.
Note: These records are solely the responsibility of their creators. COAR does not necessarily endorse — or confirm — the viewpoints expressed by these sources.
YPG, Syria on top of Turkey’s agenda at NATO summit
What does it say? Turkey has called on NATO members to join it in classifying the YPG as a terrorist organization
Reading Between the Lines: NATO is unlikely to fall in lock step behind Turkey, thus calling attention to widening fissures between Turkey and other NATO members.
Source: Hurriyet Daily
Language: English
Date: 2 December 2019
Who Are Turkey’s Proxy Fighters in Syria?
What does it say? Most combatants fighting for Turkey’s local partner of choice in Syria, the Syrian National Army, claim they joined the group to collect a salary.
Reading Between the Lines: Charges of extremism among the ranks may be overblown, yet there is little indication that violence and vandalism will abate in new areas captured by the group.
Source: New York Review of Books
Language: English
Date: 27 November 2019
Lebanon: rival protests near EU HQ over dispute on Syrian refugees
What does it say? Protesters gathered outside the European Union Delegation in Beirut to call for the return of Syrian refugees to Syria.
Reading Between the Lines: The deteriorating economic situation in Lebanon threatens social cohesion in host communities that are already enduring economic hardship.
Source: Asharq Al-Awsat
Language: English
Date: 30 November 2019
How accurate are the figures on the number of tourists coming to Syria?
What does it say? The Syrian Ministry of Tourism has reported that the number of tourists who entered Syria in 2019 rose by 46 percent over the previous year.
Reading Between the Lines: Tourist numbers are certainly on the rise, after zeroing out during the conflict, yet state figures misconstrue visitor numbers to sell the idea of Syria’s return to normalcy.
Source: Enab Baladi
Language: Arabic
Date: 2 December 2019
Who committed the Tel Rifaat massacre: the opposition or Rasoul al-Aathaam?
What does it say? Kurdish forces have accused Turkish-backed armed groups of shelling a residential neighborhood in Tal Rifaat, killing nine civilians.
Reading Between the Lines: Although the National Army has denied culpability and it is unclear who carried out the attack, attacks targeting civilians have previously been used as a pressure tactic in Syria.
Source: Al-Modon
Language: Arabic
Date: 3 December 2019
Syrian unity is impossible without a deal between Russia, the USA, and Turkey
What does it say? Two scenarios are possible for Syria’s future: a divided occupation, similar to that of postwar Germany, or the forced resignation of Bashar al-Assad.
Reading Between the Lines: Neither scenario is likely to be obtainable. Ultimately, no workable solution is possible without the agreement of major foreign powers who remain at loggerheads.
Source: Russian International Affairs Council
Language: English
Date: 22 November 2019
The Wartime and Post-Conflict Syria project (WPCS) is funded by the European Union and implemented through a partnership between the European University Institute (Middle East Directions Programme) and the Center for Operational Analysis and Research (COAR). WPCS will provide operational and strategic analysis to policymakers and programmers concerning prospects, challenges, trends, and policy options with respect to a conflict and post-conflict Syria. WPCS also aims to stimulate new approaches and policy responses to the Syrian conflict through a regular dialogue between researchers, policymakers and donors, and implementers, as well as to build a new network of Syrian researchers that will contribute to research informing international policy and practice related to their country.
The content compiled and presented by COAR is by no means exhaustive and does not reflect COAR’s formal position, political or otherwise, on the aforementioned topics. The information, assessments, and analysis provided by COAR are only to inform humanitarian and development programs and policy. While this publication was produced with the financial support of the European Union, its contents are the sole responsibility of COAR Global LTD, and do not necessarily reflect the views of the European Union.
