Precedents database

Application	Initial
Review	Full, coordinated by NASM
Decision of	06/06/2016
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Stakeholer involvement/students
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (24/04/2025)
RC decision	Partial compliance

“The Review Panel noted that, while the music education sector and the professional field are involved through the nomination of Board members by AEC, EMU and Pearle*, students, alumni and the broader society were not involved in the governance of MusiQuE.According to its statement “Actions undertaken by MusiQuE as a response to the recommendations formulated by the external Review Team”, MusiQuE considered to add a student member to its Board and planned to discuss a selection process at its May 2016 Board meeting.In its clarification (Annex 8), MusiQuE noted challenges related to representation and continuity, and explained that it would invite a student observer to its Board. MusiQuE further noted that it would reconsider this decision in case a European association of music students would be created.Considering the principle of independence, the Register Committee underlined that a student Board member should not be considered a representative of their organisation, but should serve in an individual capacity. Furthermore, while acknowledging that a European association of music students would obviously be desirable for MusiQuE as a direct interlocutor at the European level, the Register Committee did not concur that the absence of such an association is an insurmountable obstacle to appointing a student Board member. Through its own database of student experts, or in contacts with generic student organisations, or national or regional music students' organisations, it should be feasible to identify a suitable student Board member.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	clear distinction between different types of activities
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“When confirming eligibility of the application, the Register Committee requested (see letter of 26/2/2016) that ASIIN demonstrates how it ensures a clear, consistent and transparent separation between activities within the scope of the ESG and others, in particular in its public communication and where similar terms are being used, such as in the case of “type 1” (ESG) and “type 2” (non-ESG) evaluations. The review panel considered that ASIIN needs to further clarify the distinction between “type 1” and “type 2” evaluations. In particular, the panel recommended that ASIIN should no longer use the term “evaluation” for type 2 evaluations, but rather define those as consultation services internally and externally. The Register Committee considered ASIIN's Statement on the review report, noting that third parties tend to use the term “evaluation” for such services. While this might well be the case, the Register Committee could not see how that would prevent ASIIN itself from avoiding the term “evaluation” in its own communication, e.g. on its website. The Register Committee further noted the Statement on the review report does not explain how ASIIN would ensure transparency and a clear distinction despite insisting on using the term “evaluation”. Having considered the additional representation, the Register Committee considered that the distinction between the two types of evaluations is now better presented on the ASIIN website. The Register Committee noted that ASIIN, however, continued to use the word “evaluation” for type-2 evaluations, against the panel's recommendation, arguing that “the term is not restricted to uses as falling under the scope of EQAR”. ASIIN was furthermore “convinced that the distinction between the two types and the fact that type 2 evaluations do not fall under the remit of the ESG, and of EQAR, is very transparent on the ASIIN website”. While the Register Committee recognised that presentation and clarity have been improved, the Committee considered that it remains to be seen whether the presentation is sufficiently clear in practice, in particular in terms of ensuring that all those evaluations that are by their nature within the scope of the ESG are carried out as type-1 evaluations and in compliance with the ESG.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Strategic plan, involvement of students in the governance structures
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that, while the goals and objectives of ECCE are clearly described, ‘the strategic planning work seems to be underdeveloped and lagging behind ‘and ‘there is no clear evidence of robust yearly work planning and how it ties to the long or medium term strategies’ (review report, p. 56). The panel further stated that stakeholder involvement has not been fully ensured and especially recommended the involvement of students in the governance structures of ECCE. In its additional representation ECCE submitted a revised Strategic Plan (dated November 2016) with ‘indicators of success’. The agency also added that a student will be included in its Commission of Accreditation with effect from ECCE’s general meeting in November

2017. While the Register Committee took note of the revised strategic plan and the intention to improve student involvement into the governance of ECCE, the Committee considers that these changes still have to be enacted and externally reviewed by a panel (i.e. showing evidence of a robust yearly work planning, adoption of a strategic plan)”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	03/03/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	separation between activities that are within and outside the scope of the ESG
Panel conclusion	Compliance
Clarification request(s)	Panel (10/02/2023)
RC decision	Compliance

“21. In its Terms of Reference for the review the Register Committee asked the panel to consider how the agency clearly separates between activities that are within and outside the scope of the ESG, in particular considering the ‘Assessment of Quality Agreements in the Netherlands’ and the ‘Assessment of the quality of Training Schools’. While the panel concludes that there is a clear separation between NVAO’s activities within and outside the scope of the ESG, the Committee could not find the argumentation to support the panel’s conclusion and has therefore sought further information.

22. In its response (see minuted conversation), the panel explained that the separation between the agency’s activities that are within and outside the scope of the ESG did not pose any concern.

23. Considering the Assessment of quality agreements in the Netherlands the panel stated that the activity does not address the teaching and learning aspects within higher education and that the focus of the assessment is on how institutions (plan to) spend the so-called study advance grants. The panel added that the agency’s protocol or description does not misrepresent the activity in any way (i.e. referring to ESG or EQAR registration).

24. Considering the evaluation procedure for teacher training schools, the panel clarified that the activity does not address or evaluate the teaching and learning in higher education, but it assesses the collaboration between schools for primary and secondary education and institutions for teacher training.

25. Having considered the clarification provided, the Register Committee can now follow the panel’s conclusion of compliance with the standard 3.1.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ASIIN
Decision of	30/06/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Distinction between HEIs and alternative providers/ Stakeholder involvement in governance
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“28. The Register Committee found ECTE to be only partially compliant with the standard (see decision of 2022-06-28), given the lack of a clear and transparent distinction made between officially-recognised higher education institutions (HEIs) and alternative providers (APs).

29. The panel analysed ECTE’s comprehensive measures introduced and how they have been implemented by both ECTE itself and the accredited providers.

30. The Register Committee commended ECTE for the steps taken and concurred with the panel that these address the earlier mentioned issues.

31. The Register Committee considered that the panel's concerns regarding the Accreditation Commission's (AC) dominance by staff and the lack of other stakeholder representation (e.g. students and business) are an issue related to the requirement of stakeholder participation in ESG 3.1 rather than related to ESG 3.3.

32. The Committee took note of ECTE’s immediate steps to ensure the appointment of stakeholder members (see ECTE statement of 2022-12-21). The Committee further considered the analysis provided by the panel in its addendum to the review report, on the new composition of the Accreditation Commission, that now ensures a broader stakeholder representation.

33. Given that the issues related to the involvement of stakeholders' perspectives on the AC was addressed, Register Committee was now able to concur with the panel's conclusion of compliance.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	30/06/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of student members in the governing/accreditation body
Panel conclusion	Partial compliance
Clarification request(s)	Panel (15/02/2023)
RC decision	Partial compliance

“29. The panel clarified that ECCE had a clear strategy that guided its work; even if the official documents were sometime incoherent in wording, they were coherent in substance.

30. The panel further clarified that ECCE should have been more attentive and flexible as regards the appointment of a new student member to QAAC. The practice led to a student member being absent from QAAC for some time, which could have been avoided if ECCE had been more concerned to prevent this with priority.

31. Having considered the panel's clarification, the Register Committee was able to concur with the panel's conclusion that ECCE partially complies with the standard.

32. The review report explains that ECCE does not provide consultancy themselves but “offers the names and contact details of highly qualified independent educationalists to new chiropractic programmes to assist them with the development of their programmes” (report, p. 14).

33. While the Register Committee considered that these did not appear to be problematic, it found that this should be discussed in more detail in the next review of ECCE.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of stakeholders
Panel conclusion	Compliance
Clarification request(s)	Agency (18/07/2023)
RC decision	Partial compliance

“The Committee was displeased to learn that EAEVE has not involved students and other stakeholders in the decision-making bodies since its registration on EQAR in

2017. While the Committee understood that involvingstudents from a narrow scientific field in the work of the agency could be a challenging task, it found that EAEVE could have found alternatives since its registration (e.g. establish stronger ties with stakeholders associations and or/create incentives for motivating other stakeholders to participate in the work of the agency, expand the involvement of students from closely related scientific fields etc.). The Committee found that the agency’s involvement of stakeholders, including students, in its governance and work is insufficient.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	stakeholders, stakeholders involvement, Accreditation Council
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“19. In its last decision, the Register Committee noted that the composition of NEAA’s Accreditation Council (AC) is dominated by representatives of the academia and that there is a lack of stakeholder involvement with no student or labour market/employment representatives involved in the work and governance of NEAA.

20. The Register Committee noted that while NEAA expanded the direct participation of stakeholders in its work i.e., including representatives of students and employers in the Expert Groups and the Standing Committees, that the composition of the Accreditation Council (AC) is still limited to only representatives of the academic community.

21. Despite the improvements done by NEAA in the involvement of stakeholders’ in some of its processes and bodies, the Register Committee considered the lack of stakeholder involvement (as per the requirement of the standard) in the core governance body of NEAA as of crucial importance.

22. The Committee further emphasised the recommendation of the panel to ensure the inclusion of a representative of students and employers/industry in the AC, including a representative of students (preferably with a legal background) in NEAA’s Ethics Committee.

23. In its representation, the agency provided information on the actions taken toward the government and parliament around the need for legislative changes. The Committee took note and welcomed the positive developments towards the involvement of stakeholders in the Accreditation Council, however at the time of the Register Committee’s consideration, no changes have happened, nor a clear timeline for such changes has been provided.

24. The Register Committee acknowledge that although NEAA has taken all possible actions to improve the involvement of stakeholders within relevant normative documents, the fact remains that the level of compliance is negatively impacted by the regulatory framework within which NEAA operates.

25. The Register Committee therefore concurs with the panel that NEAA complies only partially with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	presentation of activities within and outside the scope of the ESG
Panel conclusion	Compliance
Clarification request(s)	Panel (03/10/2023)
RC decision	Partial compliance

“17. The Register Committee noted the following concerns with the way QAA has separated its consultancy and related activities from its external QA activities within the scope of the ESG. In particular the Register Committee remained in doubt whether:

• readers (at least lay readers) are able to distinguish whether the reviews carried out in Albania (with the national QA body) fall within the scope of QAA's registration on EQAR, as they were not officially certified as in line with the ESG and

• how the agency ensures a clear communication and separation of the QE-TNE activity from QAA’s activities within the scope of the ESG, given that the activity can be easily misconstrued as an ESG activity (see change report of 2023-02-13).

18. The Register Committee noted that these concerns have not been addressed in the self-evaluation and external review report and therefore the Committee sought further clarifications from the panel to clarify how are the services rendered by QAA itself (internationally or domestically) separated from QAA’s regular ‘ESG activities’.

19. The panel explained (see minuted call of 2023-10-03) that in its understanding the QE-TNE activity is outside the scope of the ESG and thus outside the scope of the review. While the panel did bring this matter up during its discussion with the agency, the panel was reassured by the agency that this activity is not within the scope of the review. The panel was also unaware of the concerns raised by the Register Committee with regards to the consultancy activity carried out by the agency in Albania.

20. The Register Committee could not establish how the agency ensures a clear separation between ESG-type external quality assurance activities especially in cases where such a risk has been previously noted. The Committee therefore could not follow the panel’s judgment of compliance and found that QAA complies only partially with ESG 3.1.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	student, stakeholder involvement
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“17. The Register Committee noted the panel’s concerns in terms of a lack of student perspective in the Executive Board of the agency. While the agency has two nominated student representatives in the Executive Board, neither one is a student or a recent graduate of a higher education institution.

18. Furthermore, the Committee noted the unrealistic requirements for one of the two student representatives to hold a third-level university degree and have at least 15 years of academic or professional experience.

19. Considering the lack of diverse stakeholder representation within the governance of the agency i.e., the limiting conditions in allowing the representation of a student or employer perspective the Register Committee could not follow the panel’s judgement of compliance and found that SAAHE complies only partially with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	strategic plan, stakeholder, stakeholders involvement
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“12. The Register Committee noted the concerns raised by the panel that CYQAA’s Strategic Plan (2020-2025) is rather generic, with no specific

activities and clear timeframes. Furthermore, the Committee noted that the panel did not see any evidence of public, annual corporate or activity plan than operationalise the Strategic Plan.

13. The Register Committee understood by the panels analysis, that the agency involves representatives from both public and private universities, students and regulated professions. However, as underlined by the panel, the involvement of private higher education institutions and many public and private colleges and their students is very limited and CYQAA should further widen their engagement in its governance and evaluation processes.

14. Considering the lack of comprehensive and rather generic Strategic Plan and the shortcomings in the involvement of stakeholders from all

higher education institutions, public and private colleges, the Register Committee concurred with the panel and found that CYQAA only partially

complies with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Distinction between ESG aligned and consultancy activities
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“14. In its previous decision for renewal of registration on EQAR (of 11-05-2019), Unibasq was found to be partially compliant with the standard as it did not make a clear distinction between its ESG aligned and consultancy activities (i.e. the evaluation of “títulos propios”). At the time, the agency removed the information regarding the evaluation of “titulos proprios” from its website; the Committee, however, could not verify whether the new method of communication brought clarity for all stakeholders.

15. From the external review report, the Committee has learned that the agency “ has made...efforts to request from higher education institutions [involved in the consultancy activities] not to use misleading information on their websites and has succeeded as far as the panel could determine through an internet search”.

16. The Committee therefore followed the panel’s conclusion and found that the agency now complies with the standard. The Committee, however, shared the panel’s view that the agency could improve the distinction between these two group of activities by creating a separate section on its website where it showcases clear information to the public.

17. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	student in governance, distintion between activities
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“44. MFHEA has a mission statement which is publicly available and included in the strategic plan. As outlined by the panel, however, the strategic plan lacks a detailed outline of clear and explicit goals.

45. The Committee learned from the panel’s analysis that MFHEA did not ensure a clear distinction between its external quality assurance activities in the field of higher education and its other fields of work. In its statement on the report, the agency explained in order to enable a clear distinction

between its activities, it plans to initiate legislative changes. These changes, however, were either planned to happen later in 2024 or in 2025.

46. The Register Committee also learned from the report that MFHEA involves external stakeholders from different sectors in its governance and

work, e.g., members of the Board have different backgrounds in higher education. The Committee, however, noted that students are not involved in

the work of the governance body (or governance), i.e., the Board nor in its accreditation body, i.e., the Quality Assurance Committee (QAC). The Register Committee understood that in order to ensure better involvement of stakeholders, including students, in its governance structures, MFHEA

has foreseen legislative changes.

47. For the Committee it was unclear which particular changes will take place in order to address the lack of clear distinction between higher education and non-higher education activities and the lack of student involvement in the governance and work of the agency (in the Board and the

QAC), and whether the planned legislative changes have been adopted yet

48. In its additional representation, the agency informed that the clear distinction between MFHEA’s external quality assurance activities in higher

education and its other fields of work, will be ensured through structural changes in its organisational structure; the agency plans to set two units

tackling further and higher education separately.as of January

2025. Furthermore, the agency informed that legal provisions were amended to

include student representatives in the Quality Assurance Committee and the MFHEA Board and that students are now represented in both of them.

49. The Register Committee noted and welcomed the planned changes aiming to ensure clear distinction between its external quality assurance

activities in the field of higher education and its other fields of work and the involvement of students in the Board and the Quality Assurance Committee.

50. However, given the concerns raised above and that relevant parts of the presented actions are yet to be fully translated into the daily work of the

agency, they remain to be reviewed by an external review panel. Therefore, the Committee could not concur with the panel and found that the agency complies only partially with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Student involvement in governance
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“17. In its last decision for renewal of registration on EQAR (of 2019-11-05), evalag was found to be partially compliant with the standard as it had no clear overarching strategy, bringing together planning, budgeting and risk assessment. Furthermore, the main decision-making body, the Foundation Board, did not included a student member.

18. From the review report and the panel’s analysis the Register Committee noted that the main shortcomings identified in the previous decision were only minimally improved i.e., the statutory changes in order to involve student member in the Foundation Board, limits their involvement only in specific cases ( “If international standards in the field of study and teaching are dealt with, a student member may be called upon as a permanent or temporary, non-voting guest.”)

19. Furthermore, the Committee understood that evalag, at the time of the review, worked on a new overarching strategy bringing together planning, budgeting and risk assessment, however this strategy was to be approved only in July 2024.

20. Considering the minimal improvements made since the last decision, the Register Committee could not follow the panel’s judgement of compliance and found that evalag complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Lack of stakeholder involvement in governance bodies
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“23. The Register Committee learned from the review report that the Governing Board of ANVUR consists exclusively of university professors, while no other stakeholders were involved in the governance of the agency.

24. In its additional representation, ANVUR explained that their regulations do not prevent any expert, regardless of which stakeholder group they belong to, from being a member of the Governing Board. In the Register Committee’s view, however, participation in the Governing Board is challenging, especially for students, due to the full-time character of the role, even though there are different governance arrangements and divisions of governance tasks which would enable broader stakeholder involvement. (e.g. by reducing the expected working hours for some stakeholder groups).

25. ANVUR further argued that stakeholders are involved in other bodies of the agency, such as the Advisory Board, leading to ANVUR’s governance being informed by stakeholders. While the Register Committee found the involvement of stakeholders in the work of the Advisory Board to be a positive practice, it noted that this does not fulfil the requirements of the standard which implies stakeholders’ involvement in strategic decision-making (governance), and not merely in the advisory processes of the agency.

26. Considering lack of stakeholder involvement, beyond the university academic staff, in ANVUR’s governance, the Register Committee was unable to concur with the panel’s conclusion and found that ANVUR only partially complies with ESG 3.1.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Stakeholder involvement in governance
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“15. The Register Committee learned that the governing body of AQUIB (i.e., the Board of Directors), is composed exclusively of representatives of the University of the Balearic Islands (UIB) and the regional government. The Board does not include student members nor other stakeholders.

16. The Register Committee learned that AQUIB has prepared a draft of the new Statutes which, in the review panel’s view, would ensure a more representative composition of the Board of Directors. However, these Statutes are not yet in force at the time of the review.

17. Considering lack of stakeholder involvement in AQUIB’s governance, the Register Committee was unable to concur with the panel’s conclusion of compliance and found that AQUIB only partially complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	stakeholders invovlement
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. In its last decision, the Register Committee found the agency to be partially compliant due to the lack of stakeholders involvement on governance level and its lack of strategic planning.

14. The Register Committee learned from the panel’s analysis that the agency has addressed the issues raised in the previous review. The Committee noted that ACCUA has involved students and other stakeholder as members of the Governing Council of the agency. Furthermore, the Committee noted that ACCUA adopted an Initial Action Plan which is well-conceived to carry forwards the agency's mission and vision.

15. Following the improvements towards ESG compliance undertaken by the agency, the Register Committee was able to follow the panel’s conclusion that the agency complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	3.2 Official status
Keywords	agency’s formal recognition
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that IEP itself does not have separate legal personality and therefore it is represented by EUA in all legal and contractual matters. The Committee acknowledged that the recognition of IEP as a quality assurance agency by public authorities is demonstrated by the numerous contracts that IEP (represented by EUA) signed with national authorities for conducting evaluations, or by the selection of IEP as an evaluating body through a public procurement procedure. [...] The Register Committee interprets the requirement of formal recognition in a broad sense and therefore concurred with the panel's conclusion that IEP complies with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	3.3 Independence
Keywords	Infringement of the organizational independence
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Committee could not verify how the agency ensures its independence from its founder and found the distribution of power among stakeholders in the governing of the agency unequal. The Committee noted that the current arrangements include the possibility of

the founder or the Director General exercising their controlling stake in several regards, causing a substantial risk of an infringement on the

independence of the agency (see also interpretation 18).”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	3.3 Independence
Keywords	Organizational independence; Lack of formal mechanisms for tackling conflict of interest
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (15/03/2021)
RC decision	Partial compliance

“Concerns about the Government's control of all major appointments remain. In particular, the way in which the Director General is selected has not been made fully transparent and it remained unclear whether the involvement of stakeholders in appointing the Advisory Board is secured in official documents. Moreover, the potential conflict of interest that the Director General could come across in their daily operations does not seem to be fully addressed through formal means by the agency.”

Full decision: see agency register entry