Dunlop, C.A. and Radaelli, C.M. (2015) ‘Impact Assessment in the European Union: Lessons from a Research Project’, European Journal of Risk Regulation 5, 1: 27-42.

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  EJRR  1|2015  1 Symposium on Policy Evaluation in the EU Impact Assessment in the European Union:Lessons from a Research Project * Claire A. Dunlop and Claudio M. Radaelli** In this article, we present some major lessons drawn from a recently completed researchproject. Our research dealt with ex-ante evaluation, mainly impact assessment (IA). We shed new light on research questions about the control of bureaucracy, the role of IA in decision- making, economics and policy learning, and the narrative dimension of appraisal. We iden- tify how our findings stand in relation to conventional arguments about these issues, and reflect on their normative implications. We finally reason on the possible extensions of our arguments to the wider field of policy evaluation, connecting IA and ex-post evaluation. In the late 1990s, the rare studies of   ex-ante  policy evaluationfounditdifficulttoreportonanyconcretedevelopment within the European Commission out-sidefinancialplanningandthestructuralfunds.Takefor example Pelkmans, Labory, Majone 1  who wereunable to report on the number of   fiches d’impact  (the instrument used at the time to appraise the like-ly effects of policy proposals of the Commission), what they contained, and who was using them. Buttoday this topic has gained a stable place on the re-search agenda of social scientists, for example in po-litical science 2 and law. 3 As Smismans’ notes in theintroduction to this volume, 4 nowadays research onex-ante policy appraisal falls within the wider fieldof policy evaluation, broadly defined to cover the whole policy cycle – from ex-ante analysis to ex-postappraisal.Onthiscoreidea,theEuropeanUnion(EU)is in synch with the Organisation for Economic Co-operation and Development (OECD). The OECD hasrecentlyadoptedanintegratedframeworkforpolicy evaluation 5  where several concepts and even indica-tors developed in the practice of ex-ante assessmentare transferred to ex-post analysis, with the aim of encouraging a common evaluative approach to reg-ulation and legislation more generally.This reflects the politics of attention in regulatory evaluation: in the 1990s, only a few Member States werepushingareluctantCommissiontoactivatesys-tematic initiatives for the integrated appraisal of EUlegislation, be it ex-ante or ex-post. These years wit-nessedtheemergenceoftheconceptsofbusinessim-pactassessment,compliancecostmeasurement,andbetter law-making, but there was no integrated re-sponse from the EU institutions. 6 Radaelli reviewed * The article arises out of srcinal research funded by the EuropeanResearch Council (ERC) project Analysis of Learning in RegulatoryGovernance (ALREG), see: politics/research/centres/ceg/ (#230267). We thank Christie Smithfor all her help in formatting the work and the editor of thisspecial issue and two anonymous referees for their insightfulcomments made on earlier drafts of the work. The usual dis-claimer applies.** Claire A. Dunlop, University of Exeter, UK and Claudio M.Radaelli, University of Exeter, UK.1 Jacques Pelkmans, Sandrine Labory S and Giandomenico Ma- jone, “Better EU regulatory quality: Assessing current initiativesand new proposals”, in Giampaolo Galli and Jacques Pelkmans(eds.),  Regulatory Reform and Competitiveness in Europe, Volume1: Horizontal Issues  (Cheltenham: Edward Elgar, 2000), pp. 461  et sqq .2 Camilla Adelle, Andrew Jordan and John Turnpenny, “Proceedingin Parallel or Drifting apart? A Systematic Review of Policy Ap-praisal Research and Practices”, 30  Environment and Planning C:Government and Policy   (2012), pp. 401  et sqq. ; Claire A Dunlop,“The Temporal Dimension of Knowledge and the Limits of PolicyAppraisal: Biofuels Policy in the UK”, 43  Policy Sciences  (2010),pp. 343  et sqq. ; Claire A Dunlop, Oliver Fritsch and Claudio MRadaelli, “The Appraisal of Policy Appraisal – Learning AboutImpact Assessment”, 149  Revue Française D'AdministrationPublique  (2014), pp. 163  et sqq. ; John Turnpenny, Måns Nilsson,Duncan Russel et al., “The policy and politics of policy appraisal:Emerging trends and new directions", 16  Journal of EuropeanPublic Policy   (2009), pp. 640  et sqq. 3 Anne CM Meuwese and Stijn van Voorst, “Impact Assessment inLegal Studies”, in Claire A Dunlop and Claudio M Radaelli (eds.), Handbook of Regulatory Impact Assessment  , (Cheltenham:Edward Elgar, forthcoming).4 Stijn Smismans, “Introduction to this volume”,  European Journal of Risk Regulation  (2015), this issue.5 OECD,  Framework for Regulatory Policy Evaluation , (Paris: OECDPublications, 2014); see Anne CM Meuwese, Michiel Scheltemaand Lynn van der Velden, “The OECD Framework for RegulatoryPolicy Evaluation: an initial assessment”,  European Journal of Risk Regulation , this issue.6 Julie Froud, Rebecca Boden, Anthony Ogus et al.,  Controlling theRegulators , (Basingstoke, Hampshire: Macmillan, 1998).  EJRR  1|2015 2  Symposium on Policy Evaluation in the EU in 1999 the initiatives for ex-ante evaluation of poli-cy proposals (excluding structural funds and finan-cial planning) and concluded that the various pilotinitiativeswithpolicyinstrumentshadnotproducedan integrated template and a coherent instrumenta-tion – much ado about nothing. 7 Now there is a full range of initiatives for policy evaluation in the so-called smart regulation agendaof the EU and in the Member States. This evaluationturn has affected policy-makers’ understandings of the nature of EU law and its role in larger architec-tures for integrating policy and law, as shown by Smismans. 8 Even the language and the labels usedby policy-makers accompany this rise in attention –alongside the by-now traditional impact assessmentoflegislativeandnon-legislativeproposalsoftheEu-ropeanCommission,weseeanemergingpolicyagen-da concerned with ex-post evaluation and post-im-plementation review, including projects to re-fit Eu-ropeanlegislationtochangingstructuralconditions 9 andcarryout ex-post  evaluations. 10 Theattentionforthe problems created by administrative obligationshas remained high since 2004, with several ‘wars’ onredtapeendorsedbysuccessiveEUpresidencies,theCommission, and stakeholders. 11 All this activity issupposed to connect with the more established tra-dition of evaluation of expenditure programmes, tocreate a coherent evaluation culture across EU insti-tutions – this, at least, is the stated aim of the Com-mission.Inshort,aneglectedissuehasbecomefamiliarter-ritory for researchers and policy-makers. The year2002signalsthemomentwhentheCommissiontookthe commitment to use a single integrated template(Impact Assessment, IA) to evaluate new proposals(beyond what was already done for expenditure pro-grammes),toimplementcommonstandardsforcon-sultation, and to articulate an action plan for betterregulation. 12 After almost fifteen years, researchershave sufficient evidence to review the experience with ex-ante evaluation and IA in particular. We un-dertakethistaskbydrawinglessonsfromafour-yearproject on  Analysis of Learning in Regulatory Gover- nance , 13 funded by the European Research Council.In this contribution, we focus on some importantconceptual findings rather than data on individualpolicy instruments or episodes to contribute to theresearchquestionsonpolicyevaluationsthatinformour special issue. Consequently, we will draw on anumber of articles produced within ALREG – thereader can find evidence and data therein – and con-centrateontheconceptuallessons.Intheremainder,our main concern is the EU level, but when neces-saryweaddobservationsonthesituationistheMem-ber States, since the two levels co-exist and interact.In the conclusions we elaborate on the implicationsof our lessons for a critical research agenda in thisfield 14 and for our wider theoretical understandingof the politics of bureaucracy, learning and diffusionof policy instruments. I. What is impact assessment for? 1. Control instrument, tool of bureaucraticempowerment or just a symbol? At the outset, any appraisal of the experience withIA and smart regulation in the EU has to start witha theoretical proposition about the rationale for pol-icy adoption. 15 This rationale lies in delegation the-ory. The srcinal intuition by McCubbins, Noll andWeingast 16  was that by saddling United States (US) 7 Claudio M Radaelli, "Steering the Community regulatory system:the challenges ahead", 77  Public Administration  (1999), pp. 855 et sqq. 8 Stijn Sismans, “From Harmonization to Co-ordination? EU Law inthe Lisbon Governance Architecture", 18  Journal of EuropeanPublic Policy   (2011), pp. 504  et sqq. 9 Commission Communication on the Regulatory fitness andperformance programme (REFIT): State of play and outlook,COM(2014)368.10 Commission Communication on Strengthening the foundations of Smart Regulation – improving evaluation, Communication,COM(2013)686.11 Paola Coletti,  Evidence for Public Policy Design: How to Learnfrom Best Practice , (Basingstoke: Palgrave, 2013).12 Commission Communication on Impact assessment,COM(2002)276; Commission Communication Towards a rein-forced culture of consultation and dialogue. General principlesand minimum standards for consultation of interested parties bythe Commission, COM(2002)704; Commission CommunicationAction plan: Simplifying and improving the regulatory environ-ment, COM(2002)278.13 Details available on the internet at See John Turnpenny, Claudio M Radaelli, Andrew Jordan et al.,"The policy and politics of policy appraisal: Emerging trends andnew directions", 16  Journal of European Public Policy   (2009),pp. 640  et sqq. 15 Fabrizio De Francesco,  Transnational Policy Innovation: TheOECD and the Diffusion of Regulatory Impact Analysi,  (Colch-ester: ECPR Press, 2013).16 Mathew D McCubbins, Roger G Noll and Barry R Weingast,"Administrative procedures as instruments of political control", 3  Journal of Law, Economics, and Organization  (1989), pp. 243  et sqq.  EJRR  1|2015  3 Symposium on Policy Evaluation in the EU agencies with formal obligations to carry out andpublish regulatory analysis, information asymmetry  would be reduced, taking the informational advan-tage away from the agency. Ex-post evaluation fol-lowsasimilarcontrolrationale,althoughtointerveneon an agency when the policy programme is evalu-ated may be too late. Early warnings via administra-tive procedures during the drafting process, in con-trast, are effective because they capture an agency’sdeviation ‘ prior   to the agency’s implementation of achange in policy’. 17 Damonte, Dunlop and Radaelli 18 generalisethisargumenttoallinstrumentsbasedona fire-alarm logic: regulatory analysis is a fire alarminstrument that affected interests can pull at an ear-ly stage when a regulatory proposal damages them.IA enfranchises these interests and gives a voice toaffected industries, constituencies of support for theelected politicians, and experts like economists, sothat bureaucratic drift is limited. 19 Indeed, much of the US literature on IA stemsfrom this rationale, with questions on the nature of control exercised by the Office for Information andRegulatory Analysis (OIRA) on federal executiveagencies. 20 Other US projects have looked at the dif-ferent ways in which bureaucratic control can be ef-fectively exercised by pressure groups. 21 Briefly, it has become customary to think of eval-uation, especially in IA, as policy instrument for thecontrol of bureaucracy. The Commission being a bu-reaucracy, the extension to the European case seemsstraightforward. But, is it? Indeed, when our teamprobed the different implications of the control ar-gument in Europe, the findings have been less sup-portive of the control thesis. IA can be quite blunt asinstrumentofcontroloftheCommission–and,turn-ingtothedomesticlevel,insomeMemberStateslikeDenmark and Sweden there isn’t evidence for theclassic manifestations of bureaucratic control. 22 Inanother ALREG paper, Radaelli and Meuwese 23 con-clude that IA has increased capacity for operationaland strategic management within the Commission,thus effectively empowering the bureaucracy, ratherthan controlling it. Other projects have shown thatIA in some EU Member States has symbolic proper-ties – a veneer of rationality on a thick web of infor-mal decision-making procedures and policy formu-lation conventions, hardly affected by the formal re-quirementsofex-anteappraisal. 24 ForsomeMemberStates, the issue is most likely the absence of analyt-icalandinstitutionalcapacity. 25 Withoutcapacity,the whole idea of using detailed information to controlbureaucraciesviafire-alarminstrumentscannotpos-sible work.All this leads us to conclude that we might havebeen inspired by the wrong theory: control may bea correct lens for the US, but in Europe either thereis little capacity to control, or, simply, control is notthemaineffectofimplementation.Arguably,bureau-cracies like the Commission are empowered by IA, whilst national bureaucracies use IA as signal andsymbol when they do not have analytical capacity tomanagethispolicyinstrument.Normatively,theem-powerment effect may or may not be desirable. It isdesirableifwethinkthataccountabilityinmulti-lev- 17  Ibid.,  at p. 481, emphasis in srcinal; David Epstein and SharynO'Halloran, "Asymmetric Information, Delegation, and the Struc-ture of Policy-making", 11  Journal of Theoretical Politic s (1999),pp. 37  et sqq. 18 Alessia Damonte, Claire A Dunlop and Claudio M Radaelli,“Controlling bureaucracies with fire alarms: policy instrumentsand cross-country patterns’, 21  Journal of European Public Policy  (2014), p. 1330  et sqq. 19 See  ibid  , for the full-length explanation.20 Steven Croley, "White house review of agency rulemaking: Anempirical investigation", 70  University of Chicago Law Review  (2003)  ,  p. 821  et sqq, ; Winston Harrington, Lisa Heinzerling andRichard D Morgenstern (eds.),  Reforming Regulatory Impact  Analysis,  (Washington DC: Resources for the Future, 2009);Stuart Shapiro, "Evaluating the benefits and costs of regulatoryreforms: What questions need to be asked?", 31  Evaluation and Program Planning   (2008), p. 223  et sqq. ; William F West, "Theinstitutionalization of regulatory review: Organizational stabilityand responsive competence at OIRA", 35  Presidential StudiesQuarterly   (2005), p. 76  et sqq. 21 Susan Webb Yackee, “Sweet-Talking the Fourth Branch: theInfluence of Interest Group Comments on Federal Agency Rule-making”, 16  Journal of Public Administration Research and Theo-ry   (2006), pp. 103  et sqq. 22 Claudio M Radaelli, "Rationality, Power, Management and Sym-bols: Four Images of Regulatory Impact Assessment", 33  Scandi-navian Political Studies,  (2010), pp. 164  et sqq. ; on ex-anteappraisal in the domain of sustainable development see DuncanRussel and John Turnpenny, "The politics of sustainable develop-ment in UK government: what role for integrated policy ap-praisal?", 27  Environment and Planning C: Government and Policy   (2009), pp. 340  et sqq. 23 Claudio M Radaelli and Anne CM Meuwese, "Hard Questions,Hard Solutions: Proceduralisation through Impact Assessment inthe EU", 33  West European Politics  (2010), pp. 136  et sqq. 24 Julia Hertin, Andrew Jordan, John Turnpenny et al., "Rationalisingthe policy mess? Ex ante policy assessment and the utilisation of knowledge in the policy process", 41  Environment and Planning  A (2009), pp. 1185  et sqq. ; Turnpenny et al., "Policy and politicsof policy appraisal",  supr  a note 14, at p. 5.25 John Turnpenny, Måns Nilsson, Duncan Russel et al., "Why IsIntegrating Policy Assessment So Hard? A Comparative Analysisof the Institutional Capacities and Constraints", 51  Journal of Environmental Planning and Management   (2008), pp. 759  et sqq.  EJRR  1|2015 4  Symposium on Policy Evaluation in the EU el systems needs high bureaucratic capacity ratherthan weak bureaucratic organisations. It is not desir-able if we think that an empowered European Com-mission can make regulatory trade-offs disguised astechnical management rather than discussed interms of constitutional values – an issue that is ex-plored in Radaelli and Meuwese. 26 2. An instrument for decision-makingprocesses? Asecondfindingwewishtodiscussconcernstheroleof IA in decision-making processes. The guidelineson IA published by the member states and the Com-missionpresentIAasex-anteevaluationtoolthatsup-ports the decision-making process. In a recent reso-lution, the European Parliament 27 reiterated this po-sition arguing it is “convinced that IAs are an impor-tant means of supporting the decision-making in allEU institutions and an important part of the betterregulationprocess;recognises,nevertheless,thatIAscannot be substitutes for political evaluation and de-cisions”. Put differently, IA should assist the final de-cision on a proposal – that is, the decision taken by the College of the Commission, but also decisionsconcerning substantive amendments to draft legisla-tion introduced by the EP and the Council. The Eu-ropeanParliamentlamentedthatthescopeofIAmay no longer mirror the proposals adopted when theseproposals are altered at a final stage once submittedforapprovalbytheCollege.TheEPthereforerequest-ed in its resolution “that the IA should be updated toensure continuity between matters considered in itand any proposals finally adopted by the Commis-sion”. 28 The relationship with decision-making isslightlyambiguous,becausetoupdateanIA,inprac-tice,maymeantoretrofitex-anteevaluationtomatchthe political decision taken by the College – as wellasthemorebenignbutarguablyunrealisticinterpre-tation of carrying out new analysis to check if the fi-nal political decision still delivers net benefits.The College of Commissioners is not supposed toreact mechanically to the conclusions of an IA, andreject or support a proposal automatically. The sameprincipleappliestotheEPandtheCouncilwhensub-stantiveamendmentsareintroduced.ButneitherareCommissioners,MEPsandCouncilofficerssupposedto simply take note of the IA and treat it as one of themanyinputstodecision-making.Inshort,the de- cisional value ofIAhascapturedtheattentionofpol-icy-makers. This is the reason why stakeholderslament that very few IAs conclude with a rejectionofapossiblepolicyinterventionbytheCommission.The average IA does not challenge the ‘priors’ of theCommission – this is the polemical claim – but sup-ports them. The European Parliament in the Nieblerreport 29 complained that there is insufficient over-sight of the IAs of the Commission. This is becausetheoversightbody(theImpactAssessmentBoard)ismade up of high-level Commission officers and isstaffedbytheSecretariatGeneral–indeedtheJunck-erCommissionsignalleditsintentiontoopenuptheboard to external expertise. 30 Overall, these criticalopinions claim that the IA ought to be a strong toolfor decision-making, but in the real world it may beused exclusively to support a given policy choice.Empiricalevidenceshedsdifferentlightonthede-cisional value of IA. Ex-ante evaluation is not neces-sarily used to ‘speak the truth to power’ – shown thecase studies in Meuwese’s project. 31 In our project, we found that the IA is not a decisional tool, but itsrole can be to lay out the evidence-based case for acertain policy preference of the Commission. 32 Thispreference is not necessarily the output of IA. It canbe pre-defined, or it can come out of last minute dis-cussions within the College. And yet, IA still im-proves policy choice – even if it does not identify  what this choice should be. The improvement con-sistsofempiricalanalysesoftheeffectsofthechoice,on how the chosen option can be modulated acrosstime and sectors, and on the deeper consideration of  26 Claudio M Radaelli and Anne CM Meuwese, “How the regulatorystate differs. The constitutional dimensions of rulemaking in theEuropean Union and the United States”, XLII  Rivista Italiana di Scienza Politica  (2012), pp. 177  et sqq. 27 European Parliament Motion for a Resolution on the Revision of theCommission’s impact assessment guidelines (2014), point 6, avail-able on the internet at:  Ibid  ., point 8.29 European Parliament Report on Guaranteeing IndependentImpact Assessments, Committee on Legal Affairs A7-0159/2011.30 See European Commission Press Release “President Junckerappoints Dr Edmund Stoiber Special Adviser for Better Regula-tion; First Vice-President Timmermans announces reform of theImpact Assessment Board”, available on the internet at http:// Anne CM Meuwese,  Impact Assessment in EU Lawmaking,  (TheHague: Kluwer Law International, 2008).32 Claire A Dunlop, Martino Magetti, Claudio M Radaelli, et al.,"The many uses of regulatory impact assessment: A meta-analysisof EU and UK cases", 6  Regulation & Governance  (2012), pp. 23 et sqq.  EJRR  1|2015  5 Symposium on Policy Evaluation in the EU administrative compliance costs and implementa-tion problems. Consultation reveals new issues to betaken on board.Importantly, the process of carrying out an IAobliges the Commission to give empirical and con-ceptualreasonsforpolicychoice–whethertheCom-mission would have gone for the same choice withour without IA is not the fundamental issue.Indeed this argument does not mean that the IAhas limited usage. The IA has an effect after its pub-lication, that is, post-decision. After its publication,the IA has a post-decisional role when it is used by the EP or later in the process by the European Courtof Justice. 33 Majone 34 has shown the various effectsof post-decisional analysis, exactly mentioning theuse in Courts among others. It is also realistic to con-sider what the IAs of the Commission are about: onaverage,theyarenotabout‘yes’or‘no’decisionslike‘shall we regulate the environmental consequencesofsteelproductionornot’–theyareaboutthemode,timing and details of a certain design of policies thathavebeenelaboratedviastudies,workingpartiesandother preparatory activities through the years.Although we argue that the ‘yes/no’ straightfor- ward decisional role is weak, there are effects on theCommission’s decisional process that seem empiri-cally important. Consider the following. Within theCommission, the preparation of IAs has made poli-cy formulation more complicated than before. TheIAsteeringgroupsoftheCommissionincludealltheDirectorates General affected by a proposal plus theSecretariat General with a co-ordination role. IA asprocess has brought more actors into the process of preparing policy proposal. In an article by Radaelliand Meuwese 35  we argued that the preparation of IAs has limited the silos mentality of the past. Itforces the different interests represented by the offi-cers (from different DGs) involved in the IA steeringgroups to dialogue and coordinate, using evidence-based argumentation. 36 Thus, in a sense, makingthings complicated is a  virtue  of IA because it allowsthe Commission to exploit the benefits of partisanmutualadjustment.Evidence-basedbargainingwith-in the Commission’s units working in the IA steer-ing groups is a way to learn from informationbrought into the policy process by officers with dif-ferent policy preferences and interests. 37 To con-clude,ourprojectprovidescontenttotheambiguousproposition that the IA should support decisions withoutbeingasubstituteforpoliticaldecision-mak-ings.Itssupportingroleisaboutimprovingthequal-ityofthepolicyformulationprocesswithintheCom-missionviapartisanmutualadjustmentand,beyondthe Commission, in post-decisional analysis. II. How ‘good’ is impact assessment? 1. Economics logic and modes of learning How ‘good’ is a policy instrument? There are differ-ent answers to this question. In the case of ex-anteevaluation,wecanconsiderdifferentcriteriasuchas whethertheIAisusedbydecision-makersandstake-holders 38 or carries out the tests prescribed in theguidelines. 39 Morefundamentally,wecanraiseissuesabout the robustness of the underlying rationale –the intrinsic social scientific robustness of a givenpolicy instrument for evaluation. The literature onpolicy instruments 40 argues that the instrumentsadopted by governments are carriers of specific eco-nomic ideas or economic theories. There is no doubtthat economics is the main rationale evoked in theliterature on ex-ante policy formulation. Actually itis exactly for this reason – that is, IA as vehicle of  33 Alberto Alemanno, “Impact assessment and Courts”, in Claire A.Dunlop and Claudio M. Radaelli (eds.),  Handbook of Impact  Assessment,  (Edward Elgar, forthcoming).34 Giandomenico D Majone,  Argument and Persuasion in thePolicy Process,  1st ed. (New Haven and London: Yale UniversityPress, 1989).35 Radaelli and Meuwese, "Hard Questions, Hard Solutions”,  supra note 23, at p. 7.36 The same findings appear in Erica Melloni, “Ten Years of Euro-pean Impact Assessment: How It Works, for What and forWhom”, 9  World Political Science Review   (2013), pp. 263  et sqq. 37 Radaelli and Meuwese, "Hard Questions, Hard Solutions”,  supra note 23, at p. 7.38 Dunlop et al., “The many uses of regulatory impact assessment”, supra  note 32, at p. 10; Hertin et al., “Rationalising the policymess?”,  supra  note 24, at p. 7; Lorna Schrefler, "The Usage of Scientific Knowledge by Independent Regulatory Agencies", 23 Governance  (2010), pp. 309  et sqq. 39 Robert W Hahn and Patrick M Dudley, “How Well Does theGovernment Do Cost-Benefit Analysis?”,  Working Paper 04/01 ,(AEI Brookings Joint Center for Regulatory Studies, 2004); AndreaRenda,  Impact Assessment in the EU: The State of the Art and the Art of the State,  (Brussels: Centre for European Policy Studies,2006); Caroline Cecot, Robert Hahn, Andrea Renda et al., "AnEvaluation of the Quality of Impact Assessment in the EuropeanUnion with Lessons for the US and the EU", 2  Regulation &Governance  (2008), pp. 405  et sqq. 40 Pierre Lascoumes and Patrick Le Galès, "Introduction: Under-standing Public Policy through Its Instruments—From the Natureof Instruments to the Sociology of Public Policy Instrumentation",20  Governance  (2007), pp. 1  et sqq.
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