Submarine communication cables and the Netherlands: translation of a letter from the Dutch state secretary of Economic Affairs and Climate Policy

On 23 October 2020, the Dutch state secretary for Economic Affairs and Climate Policy, Mona Keijzer, sent a letter (in Dutch) about submarine communication cables to our House of Representatives. This post provides an English translation of that letter.

Takeaways:

  • Distinction must be made between intercontinental cables and non-intercontinental cables. Only the former require underseas repeaters/amplifiers to carry the signal over a (very) long distance.
  • Risks related to the economic end-of-life being reached generally are about intercontinental cables — such as TAT-14. that directly connects the U.S. and the Netherlands. TAT-14 became operational in 2001 and will be disconnected in the nearby future. The state secretary says that this does not affect the Dutch, as most communication between the Netherlands and the U.S. is already transported via other countries.
  • A new submarine cable between the Netherlands and the United Kingdom will be laid in 2021, which can also be used for direct communication between the Netherlands and the U.S.
  • The state secretary explicitly recognizes the added value of laying new submarine cables, and promises to explore options to help facilitate that through, among others, licensing for landing stations. This is a follow-up to a request made by market parties, who also indicated that it would be desirable that the Dutch government plays a stronger role. The state secretary also points out that co-financing from the EU is possible for laying new cables.

The text below this line is the translation of the letter. Note: hyperlinks and parts in square []-brackets were added by me.


During the General Consultation on Digitization of 11 March 2020, I promised MP Verhoeven of the D66 fraction to give an overview of the problems, research, and actions in the field of submarine cables. Subsequently, during the General Consultation on Telecommunications of 11 June 2020, I promised MP Van den Berg of the CDA fraction to write a letter to your House about the outcome of the discussions with the sector about the investments in submarine cables. With this letter I fulfill this commitment and cover the valuable conversations I have had with market parties.

It is important to emphasize that the Netherlands has very good digital connections, both on land, at sea, and in the air. Both our mobile and fixed connections are among the best in the world [reference: https://zoek.officielebekendmakingen.nl/kst-26643-547.html]. For example, many submarine cables come ashore in the Netherlands, as can be seen on the picture elsewhere in this letter. This digital infrastructure is important for our economy and society and it is therefore important to maintain and expand this world-class digital infrastructure.

For a good understanding of submarine communication cables, a distinction must be made between submarine cables running between continents (intercontinental cables) and submarine cables within Europe. European submarine cables do not need active amplifiers on the ocean floor, because of the short distance they span. Intercontinental cables span a longer distance and therefore require such equipment. This makes it relatively easy to increase the capacity of existing cables to the United Kingdom or Denmark. Only the active equipment ashore needs to be renewed.

Increasing the capacity on intercontinental cables is more difficult, because in some cases the underwater amplifiers also need to be replaced. Therefore, when parties talk about risks around the lifetime of submarine cables [e.g. 25 years] they generally refer to these intercontinental cables. The research report by Stratix, about which MP Amhaouch of the CDA fraction asked questions during the General Consultation on Digitization of 11 March 2020, addresses whether there is a problem due to submarine cables being at the end of their economic life and whether new cables are expected to be laid soon. This research report can be found on the site of the national government.

Submarine cables in North-West Europe (source)

Stratix’ quick scan, as well as earlier research conducted in 2018, shows that cables can be active beyond the end of their economic life. However, because the equipment is outdated, the cable’s capacity will not increase in the long run. According to Stratix, the conclusion of the submarine cable industry was that there is no reason to assume that problems will arise in the short term. In addition, it was indicated that there currently is no demand for more capacity via a (new) transatlantic submarine cables to the Netherlands. If such demand arises, the new international submarine cables to Denmark, the United Kingdom, Ireland and France can be used, because of the good land and submarine connections we have with those countries. For example, there already are submarine cables to the United Kingdom and Denmark that can be used for this purpose. The most important conclusion of the Stratix study therefore is that there is sufficient submarine cable capacity to and around the Netherlands, and that market parties do not expect a shortage in the short or long term.

An important development for the longer term is that the market for submarine cable connections is changing. Where previously consortia of telecom companies, such as KPN, were laying a submarine cable, this is increasingly being done by individual non-telecom companies and mostly digital platforms, such as Google and Facebook and Microsoft. Furthermore, it has become clear that a transatlantic cable, the TAT-14 cable, which was laid in the past by a consortium and landed in the Netherlands, will be disconnected. A lot of traffic from the Netherlands already is transported to the U.S. via other countries, however. Given our geographical position, this is not illogical.

As I promised to your House, I have spoken to market parties about these developments, also on the basis of the letter that various parties have addressed to me on this subject [those parties were Stichting Digitale Infrastructuur Nederland, Dutch Data Center Association, Fiber Carrier Association and SURF]. From these discussions and the round table I organized on 29 September 2020, various insights have emerged. First of all, it is nice to be able to report that next year a new submarine cable will be laid between the United Kingdom and the Netherlands, which will also be connected to Ireland. Data traffic can be carried to the U.S. directly via this cable. Secondly, it appears that there is a diffuse picture about the added value of direct intercontinental connections over connections via other countries. Parties that have large data centers in the Netherlands, for example, indicate that they do not see any problem in this in the future. During the round table discussion I organized, it was also emphasized that the disappearance of cables generally has no consequences for Dutch users, but it is desirable for the Netherlands to be easily accessible, and therefore direct cables can be of added value.

I also see that submarine cables add value to the Dutch digital infrastructure. I want to explicitly express my positive opinion about the added value of laying new submarine cables. Therefore, if market parties or consortia of parties are considering laying a new submarine cable to the Netherlands, I am willing to facilitate this, for example in the licensing process.

This was also requested during the round table held with market parties. It was also indicated that it would be desirable that the Dutch government plays a stronger role. It was explicitly stated that this is not about paying for these cables, but about facilitating the landing. I will look at the laws and practical objections that might stand in the way of this. For example, parties have indicated that laying cables in the North Sea could be difficult in the future. I recognize this, and it is inherent in an intensively used North Sea. I feel it is important to leave room for new submarine cables, and this has been included in the National Environmental Vision [in Dutch: “Nationale Omgevingsvisie” aka NOVI] sent to your House by the Minister of the Interior and Kingdom Relations. As mentioned in this vision, this aspect will be further elaborated in the North Sea program. With regard to both the licensing and the North Sea program, I will contact other governments and ministries, including the Ministry of the Interior and Kingdom Relations.

A good investment climate for the installation of these cables is desirable. If a submarine cable lands in the Netherlands, this can stimulate business activity surrounding it. The Netherlands Foreign Investment Agency (NFIA) can play an acquiring or facilitating role where possible. In addition, European funds are also available for the construction of submarine cables. If market parties wish to lay these cables, co-financing from the EU is possible. I will also bring these funds to the attention of market parties.

Over the past few months, various discussions have taken place with market parties and a round table has been convened. Sea cables continue to have my attention as part of the digital infrastructure and in addition to the aforementioned actions I will continue to actively monitor developments in the coming period.

Argos Radio: ‘Two-way radios of Dutch police and Royal Netherlands Marechaussee (KMar) could be eavesdropped by the NSA since the 1970s’. Or: how Operation Rubicon affected the Netherlands via Ascom SE-660 devices

UPDATE 2020-10-26: I replaced the word “cryptophones” with “two-way radios” everywhere because in this (historic) context, the use of the word “cryptophones” is anachronistic and needlessly confusing.

This is a translation of a piece published at Nu.nl today, covering an upcoming story by investigative journalists of Dutch radio program Argos (Twitter: @Argosradio1) about how Operation Rubicon, the German-U.S. joint operation involving Crypto AG, (may have) affected the Netherlands.

  • Note 1: at the time of writing, nothing about this is mentioned yet on the website or Twitter account of Argos. Nu.nl is however a reliable online news site.
  • Note 2: hyperlinks were added by me.

‘Two-way radios of Dutch police and Royal Netherlands Marechaussee (KMar; military police) could be eavesdropped by the NSA’
23 October 2020 13:46

For years, Dutch police and security units reportedly used specially secured two-way radios that could be eavesdropped on by the U.S. intelligence agency NSA.

That was revealed by documents that Dutch radio program Argos has seen.

Among others, the Dutch police and Royal Netherlands Marechaussee [military police] purchased hundreds of Swiss-made Ascom SE-660 Crypto devices. These two-way radios used encryption to protect the confidentiality of conversations.

It would now be clear that these devices contained a backdoor placed by the NSA. This allowed the NSA to eavesdrop on the communication. It is unclear how often conversations have actively been eavesdropped.

Use by special services

In the Netherlands, the equipment was commonly used by special services, including the department that protects diplomats, and the Special Security Missions Brigade. The devices were also used by the International Criminal Tribunal for the former Yugoslavia (ICTY) in The Hague.

Earlier this year it become clear that backdoors had been placed in the radios. This was part of Operation Rubicon, in which the German foreign intelligence service BND and the NSA jointly secretly acquired Crypto AG.

The acquisition enabled Germany and the U.S. to eavesdrop on the so-called secured conversations since the 1970s. This became evident when anonymous sources talked to The Washington Post and ZDF.

Impact on the Netherlands previously unknown

Previously it was clear that many countries could be eavesdropped in that way, but the exact impact on the Netherlands was not clear until now. The documents that Argos has seen show the extent to which Dutch police services were affected.

According to an anonymous source, at least 625 of the Ascom devices were bought by the Netherlands. A spokesperson of the Royal Netherlands Marechaussee stated that about 150 were in use. The Dutch police could not yet share numbers.

U.S. Senators and Members of Congress probe Juniper Networks over the status of its investigation into the likely (Dual_EC-)backdoor in NetScreen firewalls

UPDATE 2020-10-28: Spy agency ducks questions about ‘back doors’ in tech products (Reuters) and NSA: We’ve learned our lesson after foreign spies used one of our crypto backdoors – but we can’t say how exactly (The Register). Takeaway: “NSA now asserts that it cannot locate [the lessons learned] document [about the Juniper incident]”, according to Wyden spokesman Keith Chu.

On 10 June 2020, the office of U.S. Senator Ron Wyden submitted questions (.pdf) to Juniper Networks about the status of the investigation that Juniper announced four years ago to clarify questions about the presence of the intentionally weakened Dual_EC_DRBG random bit generator in Juniper NetScreen firewalls. For more about Dual_EC_DRBG, see the Wikipedia entry about the NSA program Bullrun and Daniel J. Bernstein et al.’s website on Dual_EC.

Due to the importance of this topic, I repost the content of Wyden et al.’s letter below.

We write to seek information about Juniper Networks’ investigation of several likely backdoors in its NetScreen line of firewalls.

In December of 2015, Juniper announced that it had discovered unauthorized code in the software it distributed to customers between 2012 and 2015 for its NetScreen firewalls. Soon after Juniper revealed this security breach, cybersecurity researchers determined that the code was likely an encryption backdoor that could be exploited by a sophisticated adversary to unmask the encryption used to protect data flowing over virtual private networks.

Alarmingly, the suspicious code that Juniper discovered in 2015 did not create the backdoor — it apparently modified one that was seemingly already there. Subsequent analysis by an international team of leading experts determined that, in fact, a backdoor had likely been added to Juniper’s products as far back as 2008. According to the researchers, the unauthorized code Juniper discovered in 2015 merely changed the keys to this pre-existing backdoor.

The researchers determined that sometime between 2008 and 2009, Juniper quietly added a National Security Agency (NSA) designed encryption algorithm to its products. This encryption algorithm, known as Dual_EC_DRBG, had, since 2005, been the subject of criticism by independent cryptographers who argued that it probably contained a backdoor. In spite of these warnings, the National Institute of Standards and Technology (NIST), which issues U.S. government standards for encryption algorithms, standardized Dual_EC_DRBG in 2006. However, after Edward Snowden’s disclosures in 2013, NIST withdrew the algorithm. In a post-mortem published in 2014, a senior NIST cryptographer confirmed that NSA had in fact created Dual _ EC _DRBG, that he had been told that NSA did not want to answer questions about possible backdoors, and that, in retrospect, it “should not have been included” in the official NIST standard.

Soon after Juniper revealed in 2015 that it discovered unauthorized code in its products, Juniper announced that it was conducting an investigation into the matter. According to media reports at the time, the Federal Bureau of Investigation also launched an investigation. It has now been over four years since Juniper announced it was conducting an investigation, but your company has still not revealed what, if anything, it uncovered. The American people and the companies and U.S. government agencies that trusted Juniper’s products with their sensitive data — still have no information about why Juniper quietly added an NSA-designed, likely-backdoored encryption algorithm, or how, years later, the keys to that probable backdoor were changed by an unknown entity, likely to the detriment of U.S. national security.

Over the past year, Attorney General William Barr and other senior government officials have renewed their call for technology companies to subvert the encryption in their products in order to facilitate government surveillance. Juniper’s experiences can provide a valuable case study about the dangers of backdoors, as well as the apparent ease with which government backdoors can be covertly subverted by a sophisticated actor. To that end, we would appreciate answers to the following questions by July 10, 2020:

1. In August of 2009, Juniper obtained joint certification from the U.S. and Canadian governments, certifying that Juniper’s Netscreen products running ScreenOS satisfied the Federal Information Processing Standards (FIPS) for cryptographic modules. Despite the fact that Dual_EC_DRBG was then a FIPS-certified algorithm, Juniper did not disclose the inclusion of Dual_EC_DRBG in its FIPS application, although Juniper disclosed the use of several other FIPS-certified algorithms. Why did Juniper not disclose to NIST that its products used the Dual_EC_DRBG algorithm?

2. Rather than using the “Q” value for the Dual_EC_DRBG algorithm specified in the NIST standard, Juniper used a different Q value when it originally added Dual_EC_DRBG to its products, sometime between 2008-2009. Please explain why Juniper opted to use a different Q value, how it was generated and by whom. If Juniper did not generate this Q value following the procedures described in NIST Special Publication 800-90, please explain why.

3. What were the results of Juniper’s investigation following its 2015 discovery of unauthorized code?
a. Who was responsible for conducting the investigation?
b. What was the scope of the investigation?
c. If a written report was produced, please provide us with a copy.

4. Did the investigation examine Juniper’s decision to add and retain support for the Dual _ EC _DRBG algorithm in Juniper’s ScreenOS software, long after cryptography experts publicly raised serious questions regarding a potential backdoor in Dual_EC_DRBG? If not, why not?

5. According to the research team that studied the Juniper backdoors, at or around the same time that Juniper added support in ScreenOS for the Dual_EC_DRBG algorithm, Juniper also increased the Internet Key Exchange nonce size from 20 bytes to 32 bytes. The research team argues that this change would make it easier for a sophisticated adversary to exploit backdoors in Dual_EC_DRBG. Did Juniper’s investigation look into the decision to increase the size of the nonce? If yes, what did Juniper discover? If not, why not?

6. Please identify the Juniper employees who approved the changes to ScreenOS described in questions 4 and 5.

7. Did Juniper’s investigation uncover any information relating to the source of the unauthorized code revealed by Juniper in December 2015, and in particular, the code that altered the Q value in the Dual_EC_DRBG algorithm? 

8. Did the results of the investigation include any recommendations to prevent future security incidents? If yes, has Juniper implemented all of the recommendations?

Thank you for your attention to this important matter. If you have any questions about this request, please contact Chris Soghoian in Senator Wyden’s office.

[…signatures…]

New brochure on espionage from the Dutch General Intelligence & Security Service (AIVD) – unofficial English translation

Note: this post is only of interest to those not already (self-)informed about the basics of intelligence and espionage and those who in general take an interest in what the AIVD communicates to the public.

On 26 May 2020, the Dutch General Intelligence & Security Service (AIVD) released a new brochure (.pdf, in Dutch) to inform the general Dutch public about threat of espionage. The post below is an unofficial English translation of that brochure (a manually corrected version of an automated translation by DeepL.com). The AIVD will likely release an English translation itself; when it is released, I will add a link to it here.

Parts in [] brackets were added by me.

Espionage – How do you recognize it and what can you do about it?

Espionage is of all times and poses a major threat to the Netherlands. At the same time, espionage is almost invisible and few people are aware of its dangers. All kinds of foreign countries are spying in the Netherlands. Not only via digital means, but also in the classic way: humans. Why does espionage happen and why is it harmful? How do you recognize it and what can you do about it?

What is espionage?

Passing on knowledge about Dutch foreign policy, copying and, for a fee, handing over documents from the European Commission, or hacking into a high-tech company to steal business secrets. They’re all examples of espionage. But what is espionage? Espionage is the surreptitious gathering of intelligence (information) or objects (e.g. products or machines). It may involve sensitive (personal) information, technology or state secrets, for example.

The Netherlands is an attractive target for espionage. Our country is a member of the North Atlantic Treaty Organization (NATO) and the European Union (EU) and has interesting information at its disposal. We are also host to numerous international organizations such as the Organization for the Prohibition of Chemical Weapons (OPCW) and the International Criminal Court (ICC). Dutch universities and the private sector also have a great deal of knowledge and high-quality technology at their disposal. The task of the General Intelligence and Security Service (AIVD) is to identify and help end espionage and to raise awareness of it.

Who is spying and why?

All kinds of foreign countries are spying within and against the Netherlands in order to obtain information or objects from which they can benefit. There are various reasons to spy. A foreign country can, for example, keep an eye on its emigrated countrymen abroad to check whether they pose a threat to the foreign country’s regime. Or they can map out the political situation and the decision-making process in the Netherlands in order to influence it. They can also steal economic knowledge to advance their own economy.

Some countries spy on a large scale and have professional intelligence services at their disposal that carry out this work to the best of their ability. The AIVD investigates these countries. Which foreign countries pose the greatest threat depends very much on the (inter)national situation. Relations between countries can change rapidly, leading to new players appearing on the espionage scene.

How are they spying?

Foreign intelligence services spy in various ways. Nowadays a lot of spying is done digitally: intelligence services hack into computers to steal information without being seen. Ministries, research centers and companies in the high-tech, chemical and energy sectors are frequently attacked digitally.

Espionage is also still done in the traditional way, by approaching people to gain access to information through them. Employees of intelligence services look for interesting interlocutors (sources) such as civil servants, scientists, top officials and journalists. Supporting personnel can also be interesting to intelligence services, because they can also have access to confidential information.

Why is espionage harmful?

Espionage takes place out of sight from society. For many people it is hard to imagine that espionage is harmful to national security, but this surreptitious way of gathering information can have a major impact. If, for example, another country gains access to secret information, that country can use the information to influence decision-making or take other measures. Countries can use information about their own population abroad to intimidate or even eliminate opponents.

Espionage can also cause economic damage. As soon as other countries have access to confidential business information, it has an impact on the financial position of those companies. If blueprints and unique equipment are copied, the country that is spying no longer has to pay the (often high) R&D costs itself. This can result in the Dutch company selling fewer products or being unable to compete with the foreign company. Scientific projects whose results and methods are secretly copied for use in another country may result in the financing no longer being profitable. There is also a risk that knowledge about atomic technology will fall into the wrong hands. It is therefore important that confidential information or technology cannot simply be diverted to other countries.

How do you recognize espionage?

Espionage is largely human work. Let’s say you have interesting information, and you stand out to a foreign intelligence service because of it. They then try to get in touch with you through one of their employees. That person will try to establish a relationship of trust with you. For example, he or she poses as a diplomat, journalist or entrepreneur in order to get in touch with you in a natural way [i.e., inconspicuous]. However, you may notice certain signs indicating that you are dealing with an employee of a foreign intelligence service.

Intelligence services often carry out extensive preparatory investigations into people who may be of interest to them. On the Internet, for example, they look for people who have access to sensitive files. They also look for information about a person’s private life, such as hobbies or membership of a sports club, to get to know someone better. This information is used to get in touch with you ‘spontaneously’.

Was the first contact successful? Then more meetings often follow. You will be taken out to dinner, receive gifts and may think you are building a friendship. Appointments mainly take place outside, and the foreign intelligence employee appears to be extremely interested in your private affairs. But all this time he or she has only one goal: get you to spy. Eventually, the intelligence officer will ask you to provide information for a fee. In the beginning this may be trivial information, a test to see how far you are prepared to go, but later on it will also include sensitive documents to which you have access.

What can you do against espionage?

It already helps to be aware of the fact that espionage exists. If you get a strange feeling during a contact, it is always wise to exercise restraint and report this to your employer’s security department. By recognizing signals, you can be ahead of espionage. Do you suspect espionage by a foreign intelligence service? Then report this to your employer and the AIVD: aivd.nl/contact

Be aware of the potential value of information about your work and network. Information you can easily access, such as innocent-looking files or working conditions [note: it’s unclear what the AIVD is referring to with the Dutch word “werkomstandigheden” – perhaps salary information, corporate structure, culture, and/or internal policies], can be of interest to an intelligence service. An intelligence service may also be interested in your relationship with important people.

Find a good balance in what you share online about yourself and your work. For example, do not mention on LinkedIn or Facebook that you’re working on sensitive files. Be aware of what you share and especially with whom.

Protect your equipment. Intelligence services may be interested in the information on your phone or laptop. Be alert to phishing mails, make use of security software and keep software up to date. During business trips it is wise to keep equipment that contains valuable information with you and not to check it in as luggage. Also read the AIVD publication ‘On a trip abroad – Security risks en route‘.

Getting in contact with someone from another country does of course not automatically mean you are dealing with an intelligence service.

However, it is good to be aware of the nature of the relationship. Make sure you do not become dependent on the other person and be aware of the underlying intentions of your contacts.

Want to know more?
Would you like to know more about espionage and the role of the AIVD? Then go to aivd.nl/spionage.

Colophon
This brochure is a publication of:

The General Intelligence and Security Service
aivd.nl
P.O. Box20010|2500ea The Hague
May 2020

Dutch Council of Ministers approves establishment of committee to evaluate the Dutch Intelligence and Security Services Act of 2017 (Wiv2017)

On 9 April 2020 the Dutch government announced (in Dutch) that the Council of Ministers approved the establishment of an independent committee to evaluate the Intelligence and Security Services Act of 2017 (“Wiv2017”). In the legislative process that followed the draft bill — back then referred to as “Wiv20xx” — released in 2015, the House of Representatives and the Senate had requested the government to add an evaluation clause to the law, which the government accepted and was subsequently included in the Coalition Agreement 2017-2021 (.pdf; coalition partners being VVD, CDA, D66 & CU).

The announcement states that the committee’s task is broad: it evaluates the entire law. Based on prior official documents it can be expected that the committee will also explicitly examine, from a legal perspective, the way of working of the new ex ante oversight committee introduced by the Wiv2017, the “Toetsingscommissie Inzet Bevoegdheden” aka TIB. According to the coalition agreement, specific attention will also be paid to whether “arbitrary mass collection of data of citizens in the Netherlands or abroad” is (not) taking place. Be reminded that the Wiv2017 introduced so-called “OOG interception”, which for the first time ever in the Netherlands laid down explicit legal provisions for bulk-like interception of communications on non-ether links, e.g. optic-fiber & copper cables. Prior to the Wiv2017, legal provisions only existed for bulk interception of ether links, e.g. HF radio & satcom. Also, the prohibition of so-called “sigint search” on domestic-domestic communication was removed per the Wiv2017 (“sigint search” is that phase that precedes “sigint select”. “Sigint search” is, roughly speaking, browsing/searching network links that can be intercepted to identify channels/links/places of possible interest to the legal tasks of the intelligence services. Data can be intercepted in bulk from there for subsequent querying in the “sigint select” phase to obtain communication matching specific persons, organizations and/or keywords as part of an ongoing investigation). Depending on outcome of the evaluation it is possible that changes will be proposed to the current law, for instance the addition of new legal safeguards and improvements to the oversight mechanisms.

The remainder of this post consists of an (unofficial) translation of the announcement that the government released yesterday.

Evaluation Committee for the Intelligence and Security Services Act

News release | 09-04-2020 | 14:45

The Council of Ministers has approved the establishment of an independent committee to evaluate the Intelligence and Security Services Act of 2017. This implements the decision, laid down in the coalition agreement, to evaluate the Act no later than two years after its entry into force on 1 May 2018.

The evaluation committee is chaired by Mrs R.V.M. (Renee) Jones-Bos and will start its work as of 1 May 2020 insofar the measures to combat the Coronavirus allow. In addition to the chairperson, six other members will be appointed. Their appointment will take place as soon as the AIVD has concluded their security screening procedure with positive results. The composition of the committee will take into account the knowledge and expertise required for the evaluation in the areas of legislation, operational knowledge of the work of intelligence and security services, digital security and data analysis, human rights and privacy.

The committee is charged with evaluating the law itself, not with evaluating the proper functioning of the services. The evaluation has a broad scope. An important research question is whether the objectives of the law, i.e., modernisation of the powers of the intelligence services and strengthening of the safeguards, are being achieved. The committee must also examine whether the new law has proved to be a workable instrument in practice for the performance of the services’ tasks and what bottlenecks and points for attention exist in the application of the law.

The committee will release its findings in a public evaluation report. The date of delivery of the report will be determined after consultation with the chairperson and will depend on the impact that the Corona measures have on the progress of the committee’s work. For the time being, publication is expected before the end of this year.