European union common border crossings management project

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EUROPEAID/129783/C/SER/multi
Lot 1: Studies and Technical assistance in all sectors

“A Study on Common Border Crossings Points Management between
Schengen Area and Russia / Belarus”
Contract No. 2011/282801

STUDY REPORT

This project is funded by
the European Union

A project implemented
by B&S Europe

Definition of the Core Transport Network in the Northern Dimension area, FWC COM Lot 1

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Common Border Crossings Management Project – Draft Final Report May 2012

Table of contents
Executive Summary
Glossary
Map showing major BCPs between Schengen Area and Russia and Belarus
1. INTRODUCTION .................................................................................................................. 2
2. METHODOLOGY ................................................................................................................. 2
3. CONSTRAINTS AND OPPORTUNITIES .............................................................................. 3
4. SCHEDULE OF FIELD VISITS ............................................................................................. 4
5. INTERNATIONAL CONVENTIONS RELATING TO BORDER CROSSING FACILITATION 5
6. DOMESTIC LEGISLATION IMPACTING ON BORDER CONTROL PROCESSES.............. 7
6.1 OVERVIEW OF RUSSIAN FEDERAL CUSTOMS SERVICE’S OPERATIONS AND FUTURE STRATEGIES
................................................................................................................................................. 8
6.2 OVERVIEW OF BELARUS STATE CUSTOMS COMMITTEE’S OPERATIONS AND FUTURE STRATEGIES
............................................................................................................................................... 10
7. BORDER CONTROL PROCESSES AS ACTUALLY PRACTICED .................................... 11
7.1. CURRENT SEQUENTIAL PROCESSES IN RUSSIA AND BELARUS.............................................. 14
8. DEFICIENCIES AND DISCREPANCIES IN ACTUAL BORDER CONTROL MANAGEMENT
PRACTICES.............................................................................................................................. 20
9. CROSS BORDER COOPERATION BETWEEN BORDER CROSSING POINTS
MANAGEMENT AGENCIES ..................................................................................................... 23
9.1 AUTOMATED EXCHANGES OF INFORMATION ON CUSTOMS MOVEMENTS WITHIN THE CONTEXT OF
OPERATIONAL LEVEL COORDINATION BETWEEN CUSTOMS SERVICES .......................................... 25
10. THE LOGISTICS OF MOVEMENTS OF PASSENGERS AND GOODS AT BORDER
CROSSING POINTS ................................................................................................................. 26
11. THE IMPACT OF PHYSICAL INFRASTRUCTURES ON THE OPERATIONS OF
BORDER CROSSING POINTS................................................................................................. 30
12.

THE VIEWS OF BORDER MANAGEMENT AGENCIES ................................................. 33

13.

THE VIEWS OF TRANSPORT OPERATORS AND THEIR REPRESENTATIVE BODIES
34

13.1 SUMMARY OF THE VIEWS OF EU BASED TRANSPORT OPERATORS. ....................................... 35

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13.2 SUMMARY OF VIEWS OF A RUSSIAN BASED TRANSPORT OPERATOR .................................... 36
14.

THE VIEWS OF DRIVERS. ............................................................................................. 39

14.1 SUMMARY OF DRIVERS’ QUESTIONNAIRES .......................................................................... 41
15.

THE RAIL FREIGHT SITUATION. ................................................................................... 43

16.

THE RAIL PASSENGER SITUATION. ............................................................................ 45

17.

CONCLUSIONS REACHED ............................................................................................ 46

17.1 ROAD FREIGHT ................................................................................................................. 47
17.2 ROAD PASSENGERS ......................................................................................................... 49
17.3 RAIL FREIGHT................................................................................................................... 51
17.4 RAIL PASSENGERS ........................................................................................................... 52
18.

RECOMMENDATIONS ................................................................................................... 52

18.1 HIGH PRIORITY ISSUES...................................................................................................... 52
18.2 GENERIC BORDER MANAGEMENT PROCEDURES ................................................................ 54
18.3 TECHNICAL ROAD FREIGHT PROCEDURES .......................................................................... 56
18.4 GENERIC ROAD FREIGHT PROCEDURES ............................................................................ 56
18.5 GENERIC AND TECHNICAL ROAD PASSENGER PROCEDURES ............................................... 57
18.6 GENERIC AND TECHNICAL RAIL FREIGHT PROCEDURES........................................................ 57
18.7 GENERIC AND TECHNICAL RAIL PASSENGER PROCEDURES ................................................. 58
19. RECOMMENDATIONS ON BORDER CROSSING POINTS REQUIRING
PRIORITISATION OF MODERNISATION AND INTRODUCTION OF NEW PROCEDURES ... 58
TABLE 1 BORDER CROSSING POINTS VISITED BY THE PROJECT TEAM DURING THE STUDY ............ 62
TABLE 2 ALTERNATIVE BORDER CROSSING POINTS NOT VISITED DURING THE STUDY BUT INCLUDING
BCPS RECOMMENDED FOR MODERNISATION PROGRAMMES ........................................................ 63
MAP 1 LOCATION OF BCPS VISITED IN THE FIELD VISITS............................................................. 64
20.

BCP BASED TESTING OF RECOMMENDED MEASURES ........................................... 71

APPENDIX A – IDENTIFICATION OF CORE ROAD AND RAIL TRANSPORT CORRIDORS ...................... 74
APPENDIX B - BORDER MANAGEMENT AGENCY QUESTIONNAIRE RESPONSES ............................ 76
APPENDIX C - PUBLICATIONS CONSULTED ............................................................................. 150
APPENDIX E - ACKNOWLEDGMENTS ........................................................................................ 164
APPENDIX F – TERMS OF REFERENCE .................................................................................... 167


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Executive Summary
The Project Team (PT), composed of the Team Leader, the Logistics Expert and the
Trade Facilitation Expert, together with an interpreter and translator, has completed its
interviews with Border Management Agencies, Freight Forwarders Associations and
Road Transport operators, and with individual drivers. The meetings with Border
Management agencies, including those responsible for infrastructure development, have
all been on the Schengen side of the border, with the exception of a meeting in Poland
with Belarusian Customs staff. Russian Agencies have been kept informed of Project
progress and contacts made.
The results of these interviews and other research have been used in producing
Conclusions and Recommendations for development and modernisation of border
management infrastructures and technologies and particularly of intra state and
interstate information sharing and cooperation procedures. These Conclusions and
Recommendations are summarised at the end of this Executive Summary and the
appropriate sections of the Main Body of the Report with background information being
included in the relevant Appendices, especially Appendix B which reproduces the
Questionnaires used for Field Visits to BCPs on the EU side of the border.
The required outputs of the Study were in relation to using assessments of the current
status of management of road and rail BCPs as outlined in Section 2.1 (a) to (e) of the
Terms of Reference
as reproduced at Appendix F, in order to produce
recommendations in relation to improving physical infrastructures and movement
capacities, developing agency cooperation within countries and between countries and
to coordinate the development of technologies and operational planning to achieve
these aims. Specifically, a list was to be produced of BCPs requiring modernisation.
All these issues were taken into account in the Study, but with a particular emphasis on
organisational, managerial and technological (IT) issues. This approach was taken on
the advice of the NDP TL Secretariat, which advised the Project Team that previous
studies had tended to relate to infrastructure issues.
Because the non-infrastructure modernisation issues are closely related to each other,
the Conclusions and Recommendations have been collated and presented on
functional lines in relation to particular modes of transport, particularly road freight. This
approach has been taken because specific capabilities and procedures have differing
levels of impact on specific modes of transport. This means that specific
recommendations in one transport mode ay relate to several separate output
deliverables. It also means that “modernisation” has several meanings depending on the
context of the recommendation. It does not simply mean expansion of rail lines or road
lanes, or of parking space and shelter facilities.
The Project believes that the opportunities for improving integrated BCP management
within the Schengen Area and between the Schengen Area and both Russia and
Belarus as Customs Union members are both technical and organizational. It is felt that

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there is no single solution to the challenge of reducing delays in the movement of
people and goods while maintaining the security of physical and fiscal borders.
The interviews and written submissions by all parties interviewed have, however,
enabled the PT to reach a number of conclusions for which there is a wide and strong
consensus among the interviewees regarding what is needed to improve border
crossing procedures in the four separate but also related categories of road freight
traffic, road passenger traffic, rail freight traffic and rail passenger traffic.
In reaching this consensus, the PT has been able to identify the major transnational
transport connections between the Schengen Area and Russia and Belarus and has
accordingly produced a list of those road and rail BCPs which would require particular
improvements in management of border crossings. These were identified after taking
into account current and expected traffic volumes and possible procedural changes
such as liberalization of visa regimes. However, the Project Team noted particularly that
the non-infrastructure bottlenecks apply to all BCPs to some extent, and that
infrastructure issues impact on other issues and vice versa. This thinking has to be
considered throughout the Report. While physical infrastructure issues are highlighted,
such as the need for more bridges at river crossings, the modernization of procedural
issues are seen as being of significantly greater importance, both in the short and long
term.
The most important issue is felt to be an organizational one. There needs to be a
significant reduction in the number of processes involved in the movement of freight,
where the delays are greatest. Such reductions would be consistent with the letter and
spirit of the Conventions to which some or all of the Northern Dimension Partnership
states are signatories. The report therefore highlights the provisions of these
Conventions, together with the encouragement of moving to free flow systems for the
passage of goods and commercial and passenger vehicles. Such systems are defined
in detail in the Report and the PT’s calculations are that they can reduce crossing times
by up to 40%.
In relation to technical issues, key identity verification equipment and the operation of
the Schengen Information system can be slow or unreliable or both, leading to severe
entry delays. Communication networks speeds need to be increased considerably, with
significant excess capacity built in. Reliability and robustness of passport readers and
fingerprint readers needs to be improved significantly, especially for use in bad weather.
Reflecting the desirability of saving time, fingerprint checks might be limited to the
checking of just one finger.
Serious consideration needs to be given to much more detailed systematic use of
Advance Passenger Information (API) for both coach and rail transport. Tests between
Poland, Belarus and Russian during the Euro 2012 football championships will provide
experience.


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There needs to be much greater systematic cross border exchanges of Customs data
regarding common and separate assessments of risk in order to move to genuine
implementation of the aims of the TIR Convention which aims for generally unimpeded
movement.
There are opportunities for improving border security and revenue protection by
developing the use of Automatic Number Plate Recognition (ANPR) systems on national
and transnational bases, which would support tackling cigarette, alcohol and road fuel
smuggling into the EU and support the effective collection of Customs duties and VAT
on private cars imported into the Customs Union (CU).
Reaching agreement on such mutual exchanges will be challenging as there are
currently very different trading patterns with imports into the Customs Union being
generally of higher value with correspondingly greater risks for frauds such as
misdescription and undervaluation. However, the task should be made easier given
Russian’s accession to the WTO with resulting reductions in duty rates. These
measures should be accompanied by reductions in the number of sequential Customs
procedures required by Russian Customs and Belarus Customs on behalf of Russian
Customs, an aim recently highlighted by President Putin.
The most effective measures for reducing the costs burden on freight operators would
be for a major expansion in the use of queue management systems alongside the
provision of off road parking at suitably equipped terminals. For maximum impact, both
need to be introduced as queue management has not necessarily reduced crossing
times but has reduced the amount of time (and therefore costs) incurred in unproductive
waiting which is regarded as being working time for drivers. The project particularly
notes that the Estonian GoSwift system, introduced on a compulsory basis in 2011, is
now to be tested by Rosgrantisa on the Russian side of the Russian – Estonian border
from 1st July 2012.
The above measures are being introduced at several locations on the Schengen Area /
CU border and active discussions should take place regarding harmonizing procedures
on both sides of the border and on introducing queue management systems near
simultaneously. Improved portable sanitation facilities need to be provided as a matter
of urgency at several locations. .
The Project Team proposes that these measures be considered for early introduction on
at least one BCP in each of the core network corridors, together with at least one major
alternative route. Consideration should be given to the long term secondment of staff
between adjacent BCPs. Such deployments would provide experience which might be
used as a basis for considering the introduction of joint BCPs. Capabilities for a joint
BCP already exist at the Koroszczyn terminal on the Polish border with Belarus in
relation to the Kukuryki (Poland) – Kozlowiczy (Belarus ) BCPs.
The thinking in recommending the BCPs appropriate for early introduction of these
measures is that the Norwegian / Russian border crossings will link deep water ports of

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increasing importance, and the Russian / Finnish choice is the direct link between
Moscow and St. Petersburg with Scandinavia. The proposals in the Baltic States are
intended to ensure more effective movements of passengers and goods to and from
both St. Petersburg and Moscow. The routes from Belarus to Lithuania and, especially,
Poland are suggested in order the meet the wider needs of the key Europe wide
transport corridor between Berlin, Warsaw, Minsk and Moscow and
to assist
modernization of links with the Kaliningrad region of Russia.
The suggested locations are Storskog (Kirkenes) – Borisoglebsk (Norway – Russia),
Valimaa – Trorfyanovka and Nuijimaa- Brusnichnoe (Finland – Russia), Narva –
Ivangorod and Luhamaa – Shumilkino ( Estonia – Russia), Terehova – Burachki and
Grebneva – Ubylinka ( Latvia – Russia), Kybartu- Chernyshevskoe ( Lithuania- Russia
– Kaliningrad) and Medininkai – Kamenny Log ( Lithuania – Belarus) and all the Polish –
Belarus crossing points in the immediate area of Terespol / Koroszczyn and Brest (
Kukuryki- Kozlowiczy and Terespol- Brest) together with Grzechotki-Mamonowo and / or
Bezledy -Bagrationovsk ( both Poland – Kaliningrad).
The PT recommends that the suggested modernisation measures be tested out by
carrying out objectively based trials of the recommended measures under close local
(BCP) regional and national supervision. Because the relationships between factors
impacting upon the speed of movements are complex, it is suggested that individual
factors be examined at individual BCPs, with the results being then examined alongside
similar trials of other factors at other BCPs. Given the relatively fast flows of commercial
freight at the Finnish – Russian border and the recent introduction of a queue
management system in Estonia, it is suggested that particular attention be paid to the
views of the BMAs on both sides of these particular borders.


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Glossary
AEO
ANPR
API
ASMAP
ATP
BCP
BG
BMA
BY
CBCP
CBM
CCTV
CIS
COMECON
CTN
CU
EC
ECICS
EDI
EE
EEAS
EORI
EU
FCS
FFAs
FI
Frontex
HBD
HQ
HS
IBM
IRU
IT
ITMS
KGD
KZ
LED
LT
LV
MUR
NATO
NCTS

Authorised Economic Operator
Automatic Number Plate Recognition
Advanced Passenger Information
Association of International Road Carriers (of Russia)
Agreement of the International Carriage of Perishable Foodstuffs
Border Crossing Point
Border Guards
Border Management Agency
Belarus
Customs Border Crossing Point ?
Coordinated Border Management
Closed Circuit Television
Commonwealth of Independent States
Council for Mutual Economic Assistance
Core Transport Network
Customs Union (Russian Federation, Belarus and Kazakhstan)
European Commission
European Customs Inventory and Chemical Substances
Electronic Data interchange
Estonia
(EU) European External Action Service
Economic Operators Registration and Identification
European Union
Federal Customs Service (of Russia)
Freight Forwarders Associations
Finland
Frontieres Exterieures – European Agency for the Management
of Operational Cooperation at the External Borders of the EU
Heart Beat Detector
Head Quarters
Harmonized System
Integrated Border Management
International Road Users (Association)
Information Technology
Integrated Transport Management System
Kaliningrad oblast of Russia
Kazakhstan
Leningrad oblast of Russia
Lithuania
Latvia
Murmansk oblast of Russia
North Atlantic Treaty Organization
New Computerised Transit System


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NDP
NDP TL
NII
NORDIM
OSCE
PL
PSK
PT
RU
SIS
TIR
TOR
UN
UNECE
VAT
WCO
WTO

Northern Dimension Partnership
Northern Dimension Partnership for Transport & Logistics
Non-Intrusive Inspection
Northern Dimension Partnership on Transport and Logistics,
especially Final Report of 30.06.11
Organisation for Security and Cooperation in Europe
Poland
Pskov oblast of Russia
Project Team
Russia
Schengen Information System
Transports Internationaux Routiers
Terms of Reference
United Nations
UN Economic Commission for Europe
Value Added Tax
World Customs Organisation
World Trade Organisation


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Map showing major BCPs between Schengen Area and Russia and Belarus

Storskog (NOR) - Borisoglebsk

Imatra - Svetogorsk
Nujamaa - Brusnichnoe
Vaalimaa - Torfianovka

Narva - Ivangorod

Koidulla – Kunichina Gora
Luhamaa - Shumilkino
Grebneva - Ubylinka

Terehova - Burachki
Silene - Urbany

Panemune - Sovietsk

Salchininkai - Beniakoni
Medidnkai – Kamenny Log

Kybartu - Chernyshevskoe
Bezledy – Bagrationovsk
Gronowo – Mamonovo
Grzhechotki – Mamonovo 2
Kuznitsa Bialostoka - Bruzgi
Bobrowniki - Berestovitca
Kukuryki - Kozlovichi
Terespol - Brest

Slawaticze - Dolmachevo


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1. Introduction
The Project Team (PT) hereby submits its draft Study Report for approval by the NDP
TL Secretariat and its Steering Committee.
The Study Report fulfils the requirements of the Terms of Reference (TOR) to provide
a description and in depth analysis of current border control practices at Border
Crossing Points (BCPs) between the Schengen Area (EU Member States and Norway)
and both Russia and Belarus (as members of the Customs Union – CU – with
Kazakhstan). The Report also analyses procedures for communicating and coordinating
between agencies on both sides of the border and makes recommendations for further
development of these communications and resulting operational procedures. The
Report examines and assesses the logistical procedures applied at both road and rail
crossing points, and for both passengers and freight. Finally, the Report proposes a list
of BCPs which especially require improvements in BCP management.
All these analyses, assessments, proposals and recommendations need to be seen in
the context that they are all connected, and that they may well be applicable to other
BCPs in the border areas within the Project’s scope, and indeed beyond. In addition,
infrastructure improvements will be ineffective without accompanying changes and
adjustments in BCP management procedures. On the other hand, BCP's can improve
their performance in many cases by improved management, even without infrastructure
investments.
While physical infrastructure issues beyond the BCPs, especially regarding
modernization of road and rail networks, have not been subjects for detailed study, it
became clear during the Field Visits that road and rail network capacities had to be
taken into account. This was especially when considering the need for vehicle terminals
and traffic queue management systems.
2. Methodology
In accordance with the requirements of the TOR, the Project Team made use of multiple
sources within Border Management Agencies (BMA) and the private transport sector.
The main information tools were a BMA Questionnaire which was completed by
members of those Agencies, mainly after the Project Team had completed a series of
field visits to key road and rail BCPs in Lithuania, Latvia, Estonia, Finland and Poland,
and a Driver’s Questionnaire. These are reproduced in the Appendices.
The views of the private sector were recorded in separate reports which are also
reproduced in Section 13. of the Study Report. In addition, the Project Team’s
summary of interviews carried out with drivers at or near BCPs in the EU Member
States and in Russia and Belarus is included at Section 14. Separate interviews were
carried out in several EU states and in Russia and, by telephone, in Belarus with
representative associations of road transport operators.

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The interviews took place during or around the series of Field Visits to key BCPs
previously identified in Phase One of the Project, or proposed by the host BMAs. As the
Project accepted the recommendations of the BMAs regarding the BCPs which should
be visited, rather than necessarily those the Project had identified as worthy of particular
attention, the list of BCPs which are, in accordance with the required outputs in the
TOR, particularly requiring improvements in management are not identical with the
BCPs actually visited. The Project believes these differences are not material, as the
management procedures identified and which are the subject of the Conclusions and
Recommendations at sections 17, 18 and 19 are common across most or all BCPs.
In all cases, the Project’s Summaries also included the views of the Project Team (PT)
as source documents for the Conclusions and Recommendations. The Summaries
of the views of the BMAs are not simply accounts of the key views of the BMAs but have
been used to make suggestions for future developments. As the BMAs have agreed
the contents of their Questionnaires and any amendments they have made have been
incorporated into the final versions of the Questionnaires, the Project is satisfied that
these are accurate assessments. .
3. Constraints and Opportunities
There were a number of constraints experienced during the Project’s research and Field
Visits. Partly due to time limitations, it was not possible to formally meet with the BMAs
of the Russian Federation. Obviously this is a major limitation. The Border Guard
Service of Belarus as lead BMA in Belarus was unable to provide the Project Team with
an invitation to visit Belarus and meet BMA personnel formally, though this has partially
been offset by a meeting with the Belarusian Customs. The PT is very grateful to Polish
Customs for arranging for these colleagues to join the PT in Poland.
These are significant constraints, especially as all the Conclusions and
Recommendations Sections are, wholly or partly, intended to be considered on both
sides of the border ideally simultaneously or near simultaneously. However, these
constraints were partially mitigated by the above mentioned meeting with Belarusian
customs as well as visits to selected BCP's as travellers. BMA staff interviewed in all
the EU States visited included personnel with specific responsibilities for cooperation
with their Russian or Belarusian counterparts. These colleagues stressed their
cooperation with their Russian and Belarusian colleagues, especially from Border
Guards and Customs. The PT believes that the opinions given to it are likely to be
reasonable and broadly very accurate representations of the views of their colleagues,
although clearly there are likely to be some differences from the actual views of their
counterparts.
Thanks to the assistance of the Polish Customs Service, the Belarus Customs
colleagues were able to join the Project Team’s visit to the Polish – Belarus border.
Their views are represented by the Project Team in Appendix B in the polish BMA

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Questionnaire and in the issues highlighted in the Conclusions (Section 17) and in the
proposals made in the Recommendations (Section 18). The PT was able, when
deploying to the series of Field Visits by traveling from Lithuania to Belarus, and later
from Ukraine through Belarus to Poland, to observe passenger vehicle processing
procedures and systems for the arrival of EU and non EU ( Schengen visa holding)
persons. A similar opportunity also has been taken at the Russian – Estonian and the
Russian Finnish borders, which were crossed by the PT as well. There were also
opportunities throughout the Field Visits to interview truck drivers from the EU and CU
regarding their experiences in relation to freight traffic on both sides of the EU / CU
border.
There were some practical constraints regarding the delivery and analysis of data from
drivers as the questionnaires did take far more time to be returned than anticipated.
Drivers appear to be often away for more than one month and international mail, even in
EU member states from the remote border areas is slow. Furthermore, some
associations declined to meet the Project, and another gave only limited information,
relying on the Project Team to draw its own conclusion.
However, the Project does not believe that these constraints materially affect the
Conclusions and Recommendations listed at Sections 17, 18 and 19 below. There
was an obvious consensus among all the EU Border Management Agencies, including
regarding the views of their Russian and Belarusian counterparts. The responses from
drivers and transport operators showed a similar consensus. Therefore, the Project
Team believes that its findings are based on reliable evidence, obtained in sufficient
quantity.
The level of consensus from both the official sector and the private sector, and the
congruence of the
views within the EU with the imminent and longer term
modernization plans of the Belarus and Russian Federation BMAs in relation to what
are commonly agreed as key transport facilitation challenges give the PT a high degree
of confidence in its Conclusions at Section 17 below. We therefore believe that further
information which can be expected to be available in the near future will confirm the
basic validity of the Conclusions or identify where those Conclusions are incorrect or
require further study. Examples of such new data might include the early and longer
term results of imminent Russian Federation Customs moves towards reductions in the
number of Customs procedures at import and the June 2012 introduction of a
compulsory web based system for pre arrival declaration of imports of goods. Such
fresh data should allow early modification of our Conclusions, with some resulting
modifications of our Recommendations.
4. Schedule of Field Visits
In all the Field Visits the PT met Border Management Agencies of the Schengen Area
States at BCPs proposed by the PT
as being of particular significance on key
transport corridors, or which the Schengen area BMAs felt had facilities and capabilities
which were of particular relevance to the Study. During the Polish visit, representatives

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of the State Customs Committee of Belarus crossed the border to join the meeting.
These colleagues were given details of the entire schedule, as were contacts in the
Customs Service of the Russian Federation, through introductions made by Finnish
Customs. However, some states proposed visits to other locations. These proposals
were accepted. However, the PT did not restrict its recommendations regarding the
BCPs to be prioritized for modernization to the sites visited.
The opportunity was taken at all Field Visits sites to issue drivers’ questionnaires and to
interview drivers informally. Some transport operators were interviewed separately at
around the same time. In order to ensure the maximum level of frankness, anonymity
was guaranteed.
The first set of BCP visits were to the Lithuanian Belarus border (Medininkai BCP with
Kamenny Log 2nd April) and the Lithuanian – Russian border (Panemune BCP with
Sovietsk 3rd April). The second visit was to the Latvian – Russian border ( Terehova –
Burachki and the Latgale Rail BCP at Zilupe ) on 4th April. The third visit was to the
Finnish – Russian Border ( Nuijamaa- Sosnovskoye / Brusnichnoe) on 16th April.
Following a meeting with Estonian BMA HQ staff in Tallinn on 17th April, visits were
made to the Estonian – Russian border at both Koidula – Pechory / Kunichina Gora
and Narva – Ivangorod on 18th and 19th April respectively with road and rail BCPs being
visited at both locations. The Polish – Belarusian border was visited at Koroszczyn
Terminal on 25th April in relation to the Kukuryki BCP and nearby at Terespol ( road and
th
rail BCP on the Polish side of the Bug river opposite Brest) on 26 April.
Members of the Project Team also carried out an informal Field Visit when travelling
between deployments, i.e. at Medininkai and Kamenny Log on 8 th April and at Brest –
Terespol road on 12th April.
5. International Conventions relating to Border Crossing Facilitation
A wide range of international Conventions provide for the regulation of the movements
of passengers, goods and, inter alia, commercial and private vehicles. The most
important of them are listed in Appendix D, together with wider and more detailed
descriptions of their provisions. Many of them have not been ratified by the Customs
Union States or by their Schengen neighbours. However, the most important
conventions such as the:


Convention on the Harmonised Commodity Description and Coding System.



International Convention on the Harmonisation of Frontier Controls of Goods



International Convention on the Simplification and Harmonization of Customs
procedures (1973 and 2006 amendments)



Customs Convention on the International Transport of Goods under Cover of TIR
Carnets (1975 with amendments)



Convention on Temporary admission (1990)


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have been ratified by all reviewed countries.
By ratifying or acceding to these Conventions, the countries committed themselves to
undertake a number of commitments which can be summarised as follows:










to ensure sufficient staff and infrastructure at BCP's, taking into consideration
traffic demands1,
to carry out only those controls that are absolutely necessary as established on
the basis of risk assessments2 especially in the case of transit shipments,
to the extent practically possible, to carry out multiple controls simultaneously or
with minimum delay,
to have customs clearance to take place away from the border as much as
possible,
to share information with each-other that facilitates the processes at the border,
in case of rail cargo crossings, to carry out both export and import controls as
much as possible at the same station near to the border (joint controls)
to give priority to vehicles carrying perishable foodstuffs and live animals,
provide facilities to create a competitive market in customs brokerage service at
the border crossing points,
to use IT based systems to the extent practically possible.

In addition to the above commitments made on relation to goods transport, countries
have to a more or lesser extent ratified certain conventions related to the passenger
traffic. These are discussed in detail in the annex to this document.
Notwithstanding the above, the fact that a Convention has not been ratified or acceded
to does not, of course, mean that the procedures required or suggested in a
Convention cannot be introduced under purely domestic legislation. However, we wish
to point out that in many cases there is the need for procedures to be introduced on
both sides of a border. Clearly, the effectiveness of the procedure is reduced
significantly if this is not the case. Throughout this Study, we
have made our
evaluations on this understanding, and that even if a Convention is not signed there
need not necessarily be valid reasons for not introducing its provisions.
Equally, the reverse applies. Because a Convention has been ratified does not mean its
provisions are necessarily implemented. This is especially the case regarding
Conventions which have major impacts on cross border movements, particularly
economic ones. The key Conventions here are in the view of the PT, the TIR
Convention ( International Transport of Goods under Cover of TIR Carnets) and
the International Convention on the Harmonisation of Frontier Controls of
Goods.. Many private and official sources made it clear that if the requirements of the
Convention were being more fully adhered to in the Customs Union, then movements of
goods would be significantly faster.

1

No specific target has been set for waiting delays or the duration of the BCP crossing process though two
hours waiting and two hours of processing should be considered as a maximum.
2
A high percentage of cargo inspected and / or X-rayed does not constitute controls based on risk assessment.

Page 6

It is for this reason that the PT has
highlighted in its Conclusions and
Recommendations at Sections 17, 18 and 19 below that the implementation of the
TIR Convention and the international Convention on the Harmonisation of Frontier
Controls of Goods should be a priority for the Customs Union states in close
cooperation with their EU neighbours, especially in relation to risk analysis procedures
and the logical resulting reductions in the number of physical inspections. We stress
that the implementation of the letter and spirit of these conventions and the resulting
reductions in the number of processes, with enhanced risk management based
supplementary checks, is our number one recommendation.
It is accepted that the TIR Convention does recognise the need to qualify the provisions
regarding the prevention of irregularities. Further discussion on how this might be done
in the context of developing and improving cross-border cooperation is provided in
Section 9 below - Cross border cooperation between Border Crossing Points
Management Agencies.

6.

Domestic legislation impacting on Border Control processes

As mentioned at Section 5. above, all of the states in the Partnership have ratified
several key international Conventions for facilitating the movement of persons and
goods across borders. Under common practice, this makes that the convention
provisions supersede domestic law. However, much of the actual implementation of
these procedures is implemented by domestic legislation or in the case of the EU
Member States and Norway3 sometimes by EU Regulations. (which also applies to
Norway in respect of the Schengen Agreement’s provisions).
The practical compliance of these states with the provisions of the Agreement is subject
to regular scrutiny by external evaluation teams.
The introduction of the Customs Union (CU) between Russia, Kazakhstan and Belarus
as well as the easing of border controls between Russia and Belarus for movements of
persons has created a somewhat similar situation to that pertaining in the EU for
customs purposes and movements of persons. Each external border state is in effect
responsible for not just its own borders but the borders of the fellow members of the
respective Customs Union or free movement area. Therefore domestic legislation is
increasingly impacting upon the interests of those other states. Accordingly, such
legislation ought to take account of common interests of all the states.
It is for this reason that the PT now provides a detailed description of current and
imminent Russian legislation and practice in relation to Customs operations in Russia,
on the understanding that both the legislation and practice will impact on operations in
Belarus too.

3

Norway, as part of the EEA is bound to the provisions of EU Regulations like a member state. Furthermore,
in case of EU Directives, Norway is also obliged to transpose their provisions in to domestic legislation.

Page 7

We provide these details because we believe that the description of the current and
planned situations, and the criticisms made by drivers and transport operators provide
an extremely useful and important overview of current challenges and opportunities. We
also believe that the challenges are consistent with similar experiences of the EU states
in the past in relation to their own operations, and to their comments about areas of
operations where they would like to enhance cooperation with Russian (and by
extension) Belarus Customs.
We also stress that the reports by private sector sources regarding scepticism about the
concerns of short term negative impacts from the introduction of the compulsory
electronic pre- information system scheduled for 17th June 2012 are not unique.
Worldwide experience has shown that when new technologies are introduced, there are
often problems in the introduction period. It is for this reason that the PT includes in its
Recommendations a proposal to monitor the positive and any possible negative results
from a very early stage and to share the findings with Schengen Area neighbouring
states.
6.1 Overview of
strategies

Russian Federal Customs Service’s operations and future

Russian Customs (Federal Customs Service - http://www.customs.ru) is a part of the
executive branch of the Government. In 2006 the Government of Russian Federation
transferred public policy decisions and development of legal regulation in the area of
customs administration from the Ministry of Economic Development and Trade to the
Federal Customs Service (Resolution #459). The Federal Customs Service (FCS)
reports directly to the Government of Russian Federation.
Currently, the FCS is focused on implementation of the following initiatives, strongly
related to border crossing operations:
Integrated control (One-Stop control). The Federal Law #394-ФЗ (28/12/2010) fully
assigned all transport control activities and documentary control on behalf of the
Medical Sanitary, Phytosanitary and Veterinary control at the Border Crossing Points to
Customs.
Currently Customs fulfil (document) control on behalf of other Federal Control Agencies,
but according to road operators, around 30% of BCP’s throughput capacity was lost due
to insufficient training of customs officers in other forms of control delegated to them
and low integration of Information Systems of various agencies, which requires multiple
entry of the same data in several Information Systems. Further implementation of the
integrated border control will focus on elimination of these gaps.
Customs clearance in near-border Logistics Terminals. According to the ‘The
concept of customs clearance and control in areas close to the State Border of the
Russian Federation’ customs clearance will be mostly done in the frontier Logistics
Terminals. It applies to many, but not all types of goods.

Page 8

According to this concept, private sector will invest in construction of border Logistics
Terminals, with support from the State through Public-Private Partnership (PPP)
mechanisms. It is planned that many terminals will be located side-by-side with BCPs.
This will help eliminate transit declarations, which take several hours for opening at the
BCPs and closing at the customs clearance depots.
Several logistics terminals near the border have already been constructed. Logistics
terminal Ubylinka was put into operation by a private investor in 2011. It is located sideby-side with the BCP Ubylinka. According to various publications in the mass-media, it
does not work smoothly. Cargo still needs transit declarations and the total clearance
takes days rather than hours. The investor – the local logistics company - TecoTerminal 1 – apparently, is not happy about the work of local customs. Carriers, who
know about current operational challenges in the Logistics Centre Ubylinka drive past it
and do customs clearance in large towns (Moscow, etc.) or choose alternative routes
through Belarus.
Remote customs clearance and electronic declarations. Remote customs clearance
allows traders to clear goods, which arrived to the border logistics terminals, in their
towns. This technology helps to implement the concept of customs clearance in the
frontier logistics terminals. Active implementation of this technology started in 2010,
when it was defined in the Customs Code of the Customs Union (Article 193-6). This
technology requires that all internal and border customs are EDI or Internet connected
to the server of the Federal Customs Service. According to the FCS, 100% of customs
are now connected to the server and are ready to work with electronic declarations, and
90% of all declarations are submitted by traders through Internet channels.
The two other countries of the Customs Union also achieved significant progress in
implementing electronic declarations and remote customs clearance.
The logistics community believes that although this technology gives traders certain
flexibility in planning truck routes from the border to the final destination, it may cause
more physical inspection at the border. This is because the trader is represented in the
border terminal by a broker who may not be able to provide all answers about cargo to
the customs officer. Shipments with multiple types of products will most likely go through
physical inspection often.
Preliminary information
According to the Decision # 899 of the Customs Union Commission (09/12/2011),
preliminary information should be provided for all goods to be imported at least 2 hours
before crossing the border starting from 17 June 2012. Electronic preliminary
information provided by a trader or a carrier should contain information about the goods
(HS codes should be in HS6 format for transit goods and in HS4 for goods cleared at
the border), consignors and consignees, carriers and vehicles, declarants, planned
transloading (for transit goods) and applicable transport constraints (dangerous and
other goods).

Page 9

Customs should review preliminary information and within 2 hours make a decision
about types of control applied to the cargo. The transit declaration is automatically
generated from preliminary information provided by the consignor or the carrier.
Mandatory preliminary information is closely linked to the implementation of Customs
Risk Management System. Requirements to the Risk Management System are provided
in the Customs Code of the Customs Union (Chapter 18, Articles 128-130) and in the
Federal Law #311-ФЗ on Customs Regulation in the Russian Federation (Article 162).
Unlike the Kazakh Law on Customs Affairs (Article 23), which defines the key objective
of their Risk Management System as the simplification of control procedures for the
Authorized Economic Operators, neither the Customs Code of the Customs Union, nor
the Federal Law #311-ФЗ set this goal for the Risk Management System.
Readiness of Russian Customs was one of the main issues raised by international road
carriers, who believe that borders crossing delays on and shortly after 17 June will
increase considerably.
6.2 Overview of Belarus State Customs Committee’s operations and future
strategies
The following comments by the PT are shorter than those for the Russian Customs
Service. However, our comments make it clear that the current draft Law on Customs
Regulation is intended to bring national Customs legislation, introduced before the CU,
into line with the requirements arising logically from the introduction of the CU. We also
note that, as was clear from our Field Visits to the Lithuanian and Polish borders with
Belarus, and our discussions with State Customs Committee colleagues from Minsk that
Belarus’ border management procedures will become of increasing importance to
Russia, given the location of key transport corridors through Belarus. An example of this
was the reporting of increased use of Belarus BCPs by transport operators from and
through Latvia for traffic destined for Russia, following the introduction of the CU.
The Belorussian State Customs Committee is regulated by the National Customs Code
(#204-3 adopted on 4 January 2007). Additional provisions, regulating customs
administration were stipulated in the Presidential Decree #228 (21 April 2008).
Since 2010 most issues of customs operations and administration in Belorussia are
regulated by the Customs Union Customs Code. Accordingly, Belorussian Customs is
working on replacing the provisions of the current national Customs Code, not covered
by the Customs Union Customs Code, by a new law on Customs Regulation. The Law
on Customs Regulation is going to be introduced in 2012 subject to the approval in the
Cabinet of Ministers and in the Parliament (in September).
The proposed Law will cover a number of topics not regulated by the CU Customs
Code, such as the organizational and administrative issues related to work of Belarusian
customs. This law will also regulate work of customs representatives, customs carriers,

Page 10

and customs warehouses and will also define requirements to the Authorized Economic
Operators.
Belorussian Customs implement similar initiatives and programs as Russian Customs.
Within the concept program e-Customs (2011 – 2015) they plan to implement electronic
declarations, Singe Electronic Window for traders and One Stop control at the borders.
It is planned that Belorussia will follow the World Customs Organization (WCO)
recommendations and will soon leave only two Border Management Agencies (BMA) on
their borders – Border Guards and Customs. Two other initiatives related to logistics
infrastructure and border control technologies are implementation of Non-Intrusive
Inspection (NII) equipment and construction of logistics terminals. Unlike Russia, which
plans to build logistics terminals in close proximity to the borders, Belorussia plans to
build logistics terminals in regional (oblast) centers.
Belorussia achieved significant progress in implementing anticorruption measures. The
base document regulating anticorruption activities in Belorussia is the Law on
Anticorruption Measures (20 July 2006). The next important step was adoption of the
state program of anticorruption measures for 2007 – 2010, approved by the Presidential
Decree #220 (8 May 2007). Important component of the anticorruption program in
Belorussia was promoting feedback from the society and mass-media. International
road carriers reported that although Belorussian border control is slow and inefficient,
rent seeking by the BMA was negligible for the last several years.

7. Border Control processes as actually practiced
The BMAs who were visited by the PT during the Field Visits responded positively to the
request to complete the BMA Questionnaire. These are listed in full at Appendix B. The
Questions and Answers are intended to provide data which enable all aspects of the
required Project Outputs to be delivered. The emphases were on identifying the current
levels of traffic movements and delays, expected changes and how BMAs work with
each other and with their counterparts across the external border. For reasons
explained at section 5. above Constraints and Opportunities the formal meetings
were limited to those on the EU side of the external border, although the PT are
extremely grateful to the colleagues of the Belarus State Customs Committee who
participated in the Polish Field Visit. Their views and the key points of their presentation
on 25th April are taken into account in the Conclusions and Recommendations at
Sections 17, 18 and 19.
During the Field Visits, the PT discussed with Border Guards and Customs jointly the
past, current and expected future levels and natures of cross border traffic patterns. The
PT visited the traffic lanes and examined passenger and vehicle terminals and Queue
Management vehicle parks where these exist. The physical layouts of the BCPs were
observed, as were the procedures for the movements of persons and of freight. The
road infrastructures in the region were also noted, particularly as the PT travelled by car,
typically along the major transport corridors and there was therefore considerable

Page 11

opportunity to examine the road infrastructures, which inevitably impact on the levels of
traffic.
Particular attention was paid to the nature and levels of cross border information
exchanges in all their forms, e.g. in relation to traffic management, on operational
“casework” issues in the customs and immigration fields, and in opportunities for
automated exchanges of customs import, export and transit data in a systematic
manner. In order to discuss these matters effectively, it was also necessary to discuss
and observe the working relationships and information sharing procedures between
BMAs within the BCP.
There was a clear consensus among BMAs regarding the key issues which needed to
be considered. Improvements to the physical infrastructure of BCPs and of the nearby
transport networks need to be considered together. Where BCPs and the access roads
between them are in urban areas ( often connected by lane restricted bridges) there
was seen to be a need to increase such lane capacity, such as by new bridges as once
planned at Ivangorod – Narva / Riigikula (Russia – Estonia) and whose status is now in
doubt, and as currently planned at Panemune – Sovietsk (Lithuania – Russia). Similar
points were raised at non- bridge locations such as Medininkai – Kamenny Log
(Lithuania- Belarus) and Terehova – Burachky (Latvia – Russia).
However, these nonetheless very important points were felt to be secondary to
improving the management of border crossing processing and the more efficient and
flexible use existing infrastructure. The introduction of queue management systems,
such as introduced on a compulsory basis in Estonia in August 2011 was felt to be a
major positive development and was being examined closely by other regional states.
The speed of handling of both freight (customs) and passengers (customs and border
guards) can be enhanced by the proper use of such queue management systems in
risk management, using the management system as a form of advanced passenger
information processing and analysis.
While it is crucial to note that the Estonian system does not necessarily reduce the
crossing time it does allow much more productive waiting time as the vehicles and their
drivers do not have to wait in a queue but can do other productive activities or at least
wait in terminal vehicle parks which have more comfortable facilities, especially sanitary
facilities, as was seen as Narva and Koidula in Estonia. Further explanations of the
opportunities the GoSwift system offers, as well as its values are found in the joint
Estonian / Russian audit of border crossing issues (March 2012), listed in Appendix C“Border Crossing of cargo at the land boundary between Estonia and Russia”. The
impact of this Report, and of GoSwift specifically, has been demonstrated by the
decision of Rosgranitsa, as the lead agency for the management of infrastructure issues
in relation to BCPs, to introduce trial operations of GoSwift at Russian BCPs, including
Ivangorod, from 1st July 2012.
The fact that such management systems do not necessarily reduce the time to cross
(but provide some certainty and reduce unproductive queue by allowing “ prebooking” of

Page 12

the queue place) demonstrates that it is the actual border crossing processes which
matter. Crossing times varied enormously despite most BCPs visited having significant
numbers of vehicle processing lanes and these being well prioritized ( with special
lanes for passenger coaches, perishable goods, low risk goods as identified in advance
through existing (EU) or planned (Russia) web based pre arrival declaration systems,
or through Queue Management Systems). Given the ranges of times reported for
crossing, it is clear that other factors are more important. Crossing times from Finland
to Russia are generally shorter than crossing times from Estonia to Russia, where on
the Russian side there are a large number of sequential, and not simultaneous
processes, which are currently required by Russian Customs. Many operators on the
Finnish – Russian routes are Finnish registered, Russian owned companies, while
drivers are Russian nationals employed by these companies.
This suggests that there may be significant opportunities for making use of risk analysis
based on greater awareness of the identities and operational and ethical standards of
the operators, with more of them deemed to be low risk. These long crossing times from
Estonia occur despite the queue management system there, and are consistent with the
experiences of transport operators working between Latvia and Russia and Belarus and
between Lithuania and Belarus. At the Russian Finnish border there were reports of
relatively fast crossing times especially from Russia, whereas there were reports from
drivers elsewhere (e.g. from Estonia into Russia) of delays of as much as five days in
extreme cases. Factors given in relation to faster movements included the truck being
empty and being subject to fewer checks outwards. Factors given as exacerbating
delays were, not surprisingly, several sequential inspections (x rays, physical
examination) and bad weather, delays due to shift changes and incorrect completion of
import declarations, such as use of incorrect HS tariff codes. .
The need to consider reductions in processes as a priority alongside the simultaneous
monitoring of the management systems designed to allow significant reductions in the
crucially time consuming procedure of physical inspection of goods is demonstrated by
recent Latvian and Russian experience. Latvia has reported that a recent pilot scheme
for submission of transit data to Russia via the NCTS SPEED platform ( the EU New
Computerised Transit System for use by economic operators eligible to use Simplified
Procedures) has not - yet - resulted in reductions to crossing times. This pilot cross
border scheme has been carried out under an EU level project with Russia.
Clearly, other factors are impacting on the apparent lack of positive results. This
demonstrates the need to consider measures in the context of other developments and
not in isolation. In relation to this Latvian – Russian example, the PT would therefore
advise that, if adopted, our proposals be shared with the other participants in this pilot
scheme. Given the great interest in shown in Estonia’s use of their GoSwift system for
pre booking of vehicles’ place in BCP queues, and that system’s use in providing
greater time for the carrying out of risk analysis, Estonian involvement would be logical
in order to determine what the relevant additional factors might be.


Page 13

All BMAs stressed close cooperation between agencies within the BCP. Staff of Border
guards, customs and phytosanitary and veterinary staff were generally co located or
were easily contactable. In the EU States, essential private sector providers such as
insurance brokers (for vehicle insurance) and banks were generally collocated in
weather protected buildings. Times spent in the open at the BCPs themselves were
usually not excessive, though in urban BCPs such as at Narva passport check queues
at vehicle, as opposed to pedestrians, limited terminal space meant that significant
numbers of passengers in coaches and private vehicles had to queue in the open.
In the EU States visited, both road and rail passengers are normally cleared through
border controls and customs controls in close sequence.
However, there were examples of lack of awareness among some staff regarding the
practical process of carrying out of mandatory (fingerprint) checks on non EU citizens
and especially those requiring visas. The sending of enquiries into the SIS and the input
of suspect documents often took time and the system was not always available. The PT
had noted this when travelling into Poland from Belarus when deploying to the Field
Visits, and these challenges were highlighted by Border Guards. Together with wider
equipment reliability issues ( such as portable passport scanners for border guards and
X ray scanners for Customs) the overall issue of proper training in the use of equipment
and the need to take account of higher maintenance requirements – reflecting often
severe weather conditions – and the need for significantly greater communications
capacity to allow for speedier transmission times now and in the future - were seen as
the key technical equipment issues.
7.1. Current sequential processes in Russia and Belarus
The PT now produces in detail a diagram outlining the sequential processes applied in
BCPs in Russia and Belarus in relation to freight movements. The principle of highly
sequential, rather than near simultaneous processes also applies, to a lesser extent, to
the movements of vehicle passengers. It is noted particularly that where batch
systems are operated, with no movement until all participants in a group (e.g. of trucks)
have been processed, movement is significantly slower than when continuous flow
systems are applied. Different systems sometimes apply at nearby BCPs on the same
border, such as at the Russian – Finnish border, where a batch system is used at
Torfianovka whereas a free flow system is used at Brusnichnoe.
This section leads naturally into the further comments at Section 8. below.
The following Diagram shows border control process in Russian and Belorussian BCPs.
The depicted process shows sequence of control procedures for trucks entering from
the European Union to Russia/Belorussia. Exit from Russia and Belorussia includes the
same steps, except that passport control is done first for vehicles entering to the BCP
from the EU, and last – for vehicles going out to the EU.


Page 14

In Russian BCPs, Customs perform transport control and documentary control on behalf
of the phytosanitary and veterinary inspection. In Belorussian BCPs all controls are
implemented by separate agencies (i.e. Transport control by Transport inspection of the
Ministry of Transport, Phyto and Veterinary controls by inspectors of the Ministry of
Agriculture)


Page 15

Diagram 1. Border control at Russian and Belarusian BCPs: entry from the EU
Entry gate,
from EU

Document control area
(Passport control line)

Physical
Inspection Area

Exit Gate,
to RU

Preliminary
document check
(Border Guards)

Immigration
card
Border control
checklist (BCC)

Physical Check
(by BG)

Passport control
(by BG)
BCC stamped
by BG

Suspected
infection

Medical Sanitary
control
Suspected
infection

No suspected
infection
(cargo, driver)
No infection
(cargo)
Transport
documentary
and physical
control

BCC stamped
by MSI

Weights
printed in BCC
Customs prelim
document check
and vehicle
examination


Page 16

Entry Gate,
from EU

Document control area
(Passport control line)
Veterinary,
Phytosanitary
control needed

Veterinary,
Phytosanitary
control not
needed

Physical
Inspection Area

Exit Gate,
to RU

Veterinary or
Phytosanitary
Control
Suspected
infection

No infection
(cargo)
BCC stamped

Customs
documentary
control

Physical Inspection
required (Customs or BG)
Physical Inspection
not required

NII and Physical
Inspection
Transport docs
stamped
BCC stamped
by Customs

BCC and docs
stamped by
inspecting
agency

BCC with all
stamps collected
by BG

Normally trucks stop in 3 or 4 control areas, depending on the applied types of control:
 Entry Gate – all vehicles
 Document control area – all vehicles
 Physical Inspection Area – high risk vehicles
 Exit Gate – all vehicles
Entry Gate
Entry to the BCP normally takes several minutes. Border Guards check driver and
vehicle documents, and issue a Borer Control Checklist (BCC). This is some sort of a

Page 17

runner, which needs to be filled with stamps and signatures of the control authorities.
The BCC has names of controls, and fields for stamps and signatures
Example of the Belorussian Border Control Checklist
:------------------------------------------------------------------:
:
Контрольный талон № ______
:
:
:
:Марка, регистрационный номер транспортного средства _____________ :
:
:
:Фамилия водителя ________________________________________________ :
:
:
:Количество пассажиров ___________________________________________ :
:
(прописью)
:
:
:
:Фамилия лица, пересекающего государственную границу в пешем
:
:порядке _________________________________________________________ :
:_______________ "__" ____________ 200_ г.
:
: (время)
(дата)
:
:
:
:
ВЪЕЗД (entry)
:
ВЫЕЗД (departure)
:
:---------------:-------------:--------------:---------------------:
: Зеленый канал :Красный канал:Зеленый канал : Красный канал :
: Green channel : Red channel :Green channel : Red channel :
:---------------:-------------:--------------:---------------------:
:
:
:
:
:
:---------------:-------------:--------------:---------------------:
: Подпись : Подпись : Подпись :
Подпись
:
: Signature : Signature : Signature :
Signature
:
:---------------:-------------:--------------:---------------------:
: Вид контроля :Время осуществления контроля:Отметка о прохождении:
:
:
:
контроля
:
:---------------:-------------:--------------:---------------------:
:
: начало : окончание :
:
:---------------:-------------:--------------:---------------------:
:Пограничный :
:
:
:
:---------------:-------------:--------------:---------------------:
:Таможенный :
:
:
:
:---------------:-------------:--------------:---------------------:
:Автомобильный :
:
:
:
:---------------:-------------:--------------:---------------------:
:
:
:
:
:
:---------------:-------------:--------------:---------------------:
:
:
:
:
:
:---------------:-------------:--------------:---------------------:

Page 18

Document Control
After entry drivers park their trucks at the Border Guards documentary control area,
pass passport control and drive to the weighbridge. This control takes several minutes,
but with a queue can often take about one hour. Weights are printed on the back side of
the BCC.
Transport control can take more time for exit from Belorussia, because drivers often
obtain driving permits to the EU countries in the BCP. Bilateral driving permits are
purchased from the Transport control authority stationed at the BCP. This involves
payment of the required fee in the bank (located in the BCP) and preparation of the road
permit of the designated country (Poland, Lithuania, etc.) by the Transport authority.
Both steps can take from several minutes (without queues) to more than an hour (with
queues). Russian drivers obtain road permits outside of the BCP areas, normally
through local offices of the Russian International Road Carriers Association (ASMAP).
After weighting drivers park their vehicles in a designated location and arrive to the
customs control terminal for documentary customs control. Phytosanitary and Veterinary
certificates are checked here as well, either by customs (Russia) or by the Ministry of
Agriculture inspectors (Belorussia).
Documentary control and preparation of transit declaration take about half an hour. But
often drivers have to spend much more time in the terminal because of queues. Waiting
for 2-3 hours is considered normal, and waiting for more than 6 hours is not uncommon.
The Customs documentary control zone has a number of customs inspectors. In BCP
Torfianovka ( Russian – Finnish border) there are 12-14 inspectors in separate booths
in for entry to Russia, and 3-4 inspectors for exit from Russia. There may be separate
queues to inspectors (like in the BCP Torfianovka) or one common line (as at the BCP
Brusnichnoe). The common line procedure should be encouraged everywhere.
After document control, drivers can either get their documents stamped and allowed to
drive to the Exit Gate, or may be required to drive to the inspection area.
Physical Inspection Area
Trucks can end up in the Physical Inspection Area for a number of reasons. reasons.
As shown in the diagram 1 above, any of the border control agency may want to
conduct detailed control checks. Sometimes trucks can be even sent back to the NonIntrusive Inspection (NII) by Border Guards at the Exit Gate. About 25% of trucks are
sent to the Non-Intrusive Inspection by x-ray stationary or mobile units. This control
takes about 15 minutes, if a driver is lucky. But because of the large proportion of trucks
sent to the NII, trucks have to queue for the NII for many hours.
If control authorities are not satisfied by the results of the NII control, more detailed
physical inspection, often with full or partial unloading can be required. When unloading

Page 19

is required, this results in delays for days. To minimize delays consignors can buy
unloading services of customs terminals (managed by ROSTEK).
Exit Gate
After several hours (if very lucky) or several days, trucks arrive to the Exit Gate. The
border guards verify that all documents have been checked and all required controls
have been completed. The Border Control Checklists are collected, and the departure
time is recorded.

8. Deficiencies and discrepancies in actual Border Control management
practices
This Section has reached its assessments based upon its own observations in the Field
Visits, and from the data supplied by the BMAs in their answers to the Questionnaires,
presented in Appendix B.. It particularly addresses issues in 2.1. a and b and d and e.
of the TOR, i.e. issues which are generic as they impact on most other BCP
management issues.
All BMAs were open and honest regarding the factors which limit the effectiveness of
border controls in ensuring the safe and speedy cross border movements of goods and
persons which maintaining proper border controls. The difficulties were made quite
clear to the PT and were usually visibly obvious. While there was no single reason for
extensive delays, the dramatic differences in crossing times for road freight, especially,
made it clear that several factors were particularly important.
Rail issues – passengers
Rail passenger movements were generally reported as being achieved satisfactorily,
without undue delay. The checking of passports on board long distance trains or in wellappointed passenger terminals which offer protection from the weather (e.g. Narva and
Koidula in Estonia regarding trains from St. Petersburg and Moscow respectively, and at
Terespol in Poland from Moscow and Minsk) involves processing times which are
acceptable given the length of the journeys. However, Estonian Border Guards advised
there concern about the risk of delays to both road and rail passengers in the event of
visa relaxations between the Schengen Area and Russia and Belarus. Therefore the
Project has noted in the Conclusions and Recommendations at Sections 17, 18 and
19 below, that the introduction of more and higher reliability mobile passport readers
should be actively considered and that consideration should be given to the introduction
of Advance Passenger Information (API) for long distance trains and coaches. The
inconvenience of this to passengers, and possible extra costs to them and the road and
rail operators would be at least partially offset if such travel were able to use priority
crossing procedures, reducing overall travel times.


Page 20

Rail issues – freight
Rail freight movements were generally reported as being achieved satisfactorily, without
undue delay. The general effectiveness of rail freight procedures is described in detail at
Section 15. below.
In general, the nature of rail freight is well known in advance to the BMAs of export,
import and transit countries. Customs clearance is normally not carried out at the
border. There are therefore seen to be no major challenges in relation to rail freight, and
the capacities examined at, for instance, the Polish Belarus and the Estonian – Russian
and Latvian – Russian borders appeared sufficient for current and expected traffic
levels.
However, following the carrying out of the Field Visits, Polish colleagues did point out to
the PT that there were significant opportunities for streamlining procedures through
greater use of the CIM / SMGS Consignment Note, which from experience on key east
west freight routes, has been a major step forward. This matter is suggested as a key
issue for consideration in future phases following on from this project.
This general effectiveness offers indicators as to what needs to be done in relation to
improving the admittedly more challenging situations regarding movements of
passenger vehicles, including coaches, and freight.
Generic road traffic issues
Queues varied greatly, with there generally being little link between the levels of road
network and BCP lane capacity and the levels of delays. At the risk of stating the
obvious, capacity increases on one side of the border lost much of their effectiveness if
there were no physical capacity increases on the other side (e.g. at Koidula – Pechory/
Kunichina Gora between Estonia and Russia, where the full benefit of the introduction
of terminals and queue management on the Estonian side will be limited until the
ongoing Russian vehicle park upgrades are completed).
Major examples of this situation were at Medininkai – Kamenny Log (Latvia – Belarus)
and Terehova – Burachky (Latvia – Russia) and Koroszczyn ( Kukuryki – Kozlowiczy)
freight and Terespol – Brest passenger vehicle crossings from Poland to Belarus. The
levels of delays were very severe at all these sites, with freight queues especially being
in excess of 10 kilometres and crossing times being well over 24 hours in some cases.
As previously mentioned, several drivers spoke not of hours but of days when
describing delays. Extensive funding has delivered significant new road capacity in
Poland in the Terespol and Koroszczyn area, while capacity is less extensive at
Medininkai and is limited at Terehova (although upgrades have started on the regional

Page 21

network). The significant on BCP terminal facilities available at Koroszczyn are of
limited support to transport operators as the queues to get to the terminal are so long.
Road issues – freight
These observations made it clear that the main opportunities and challenges relate to
the number and effectiveness of processes required to cross. While the introduction of
queue management systems such as that introduced in Estonia has, as previously
noted, led to much more comfortable conditions at vehicle terminals for truck operators
especially, it has not necessarily reduced crossing times. Given that the delays are
much greater for trucks, it is clear that the solutions going forward need to involve the
introduction of fewer and simpler processes. These need to include the reduction on
the CU side in the number of physical checks ( e.g. x raying and physical examination
of cargo, and to a lesser extent weighing which is more automated) and , accordingly,
much greater use of Risk Analysis systems and procedures for automated clearance
with post clearance audit checks away from the border.
Concern was raised by several operators, and in the media, that the June 2012
introduction of compulsory electronic submission of customs preliminary information
in advance of arrival would actually lead to longer delays, at least in the short term.
Economic operators’ unfamiliarity with the new system might lead to increased numbers
of rejections, with vehicles being turned back or subjected to higher levels of physical
controls. Therefore, it is suggested that there is close cooperation between Russian and
Belarus Customs and their EU counterparts in order to share views on what degree of
licence can be allowed to operators for mistakes which are not felt to be significant. EU
experience in relation to the introduction of its own system would be likely to be highly
relevant.
The use of free flow systems as opposed to batching is strongly recommended. Delays
caused by batching (delays which are multiplied when applied to several processes,
such as passport control followed by Customs clearance ) were stressed by several
BMAs as a major cause of delays. See Section 10. below for a detailed description of
the benefits of free flow systems.
Road issues – passengers in private vehicles and in coaches
On the road borders, both sides face a set of challenges that, though in themselves are
only minor, accumulate to require substantial resources and therefore are a cause of
delays. All countries in the Schengen zone face challenges in relation to illegal migration
and the proper processing of asylum seekers and the use of false documents. There
was a clear need seen to coordinate on a regional basis the sharing of subject specific
information on refused persons and the use of false documents. There seem to be
weaknesses here. Persons refused entry into the EU in Estonia and who were returned
to Russia were identified as attempting to enter into Finland a few days later, with the
inevitable result that they were refused entry there. This problem is worsened by the fact
that, though these persons are attempting to cross illegally into Europe, their presence

Page 22

in the CIS is fully legal and as long as they do not actually attempt to cross the border
outside of BCP's, there is nothing that can stop them from moving around.
Furthermore, there are also challenges for the EU states regarding smuggling of
alcohol, cigarettes and road fuel from Belarus and Russia where prices are much lower.
These are not risk areas for the CU but the need to carry out significant numbers of
physical examinations using risk analysis and spot checks means that delays can occur
at EU entry points. There are severe practical limitations to what can be done to reduce
these problems. It is suggested that all the States in the Partnership consider
maximizing the use of Border Guards to carry out Customs checks (i.e. first line physical
checks of vehicles), as several already do. Where BCPs do not yet have access to
central nationwide databases holding ANPR data, this should be introduced and
considered for extension to link several states. Such access would potentially increase
the effectiveness of risk analysis by identifying suspiciously frequent movements across
a border, where different BCPs are used in attempts to allay suspicion.
At the CU side, a major source of delays is the need for filling in a customs declaration
to fulfill the requirements in relation to temporary importation of (foreign) motor vehicles.
At present, the source of identification of a vehicle movement from an importation or
temporary importation point of view is the Customs declaration, the completion and
delivery of which does take time. Up to 10 minutes processing time by customs has
been noted4. Consideration should be given to evaluating other means of recording the
import or temporary import, perhaps taking the example of Ukraine, which has abolished
the use of a manual Customs Declaration.
The coordinated national and transnational use of ANPR data in relation to vehicle
movements, especially passenger vehicle movements would potentially have significant
benefits for the Customs Union. The centralization of movement data would also make it
easier for Border Guards to cooperate with customs in identifying the passengers in,
and particularly the drivers of, vehicles of potential interest from both the perspective of
identifying the smuggling of goods.
Such measures would also be consistent with the general viewpoint of the PT that
basic customs checks be undertaken by Border Guards as improvements in passport
integrity technology frees up resources for other purposes. The PT noted that at several
BCPs Customs and Border Guards worked exceptionally closely together, to an extent
that they might almost be regarded as one service, so such measures are considered
feasible.

9. Cross border cooperation between Border Crossing Points Management
Agencies

4

At the Belarus – Poland border, when the vehicle is crossing the border at the particular crossing for the
first time.

Page 23

This part of the Report addresses the requirements of Section 2.1. d and of the TOR,
i.e. communication and common decisions and personnel knowledge.
The PT accepts that its comments here must be considered as being largely based on
the views of EU Member States BMAs. With the exception of the meeting with Belarus
State Customs Committee at Koroszczyn terminal and the Kukuryki and Terespol BCPs
in Poland in April 2012 the PT was not able to meet BMA representatives from the CU,
although it did seek to keep them informed through the host BMAs before, during and
after the Field Visits.
The PT’s assessment of the situation regarding cross border cooperation between
BMAs is drawn from our observations during the Field Visits and the cross border
cooperation section of the Questionnaire. While the effectiveness of such cooperation
is a separate issue from such internal cooperation between the BMAs of a single
country, the PT believes the two need to be looked at together.
There are considerable bases for developing operational and tactical (case by case)
cooperation, especially regarding increasing the quantity and particularly the quality of
risk analysis. The operational / organizational issue of regulating traffic flow between
BCPs used by Belarus and Polish Customs should be considered for adoption
elsewhere, to the extent that it is not currently adopted. There are well established 24/7
procedures overseen by senior officers and their deputies on both sides which ensure
that vehicles are only released from the truck BCP when sufficient space is available
for them to cross. This does not in itself speed up clearance times, but does allow
drivers to rest to some extent and to make use of refreshment facilities. However, given
the sheer volume of freight traffic at Koroszczyn ( Kukuryki-Kozlowiczy), even with this
system there were still delays of 8 to 10 hours (and in some cases of up to 24 hours) in
the area between the Polish controls and the Belarus controls, i.e. after the Polish
terminal. There were no refreshment facilities in this area, which clearly demonstrates
the sheer scale of the challenges on this key east – west route.
There were, at all BCPs visited, arrangements whereby specific BMA staff and their
deputies or replacements had direct responsibilities for exchange of information on
operational and tactical matters, staff often referred to as Border Delegates. There were
normally regular formal meetings on topics of mutual interest, especially on
organizational issues. These were typically monthly or quarterly, with other meetings
held as necessary. “Hotlines” were established at several BCPs, such as at Koidula in
Estonia for contact with Pechory / Kunichina Gora BCP. In that case, given the very
close cooperation between Estonian Border Guards and Customs, the link was in effect
for all services.
There have also been cases of short term deployments of BMA personnel between
BCPS. In April 2012 Russian Border Guards were due to be based at Terehova during
Operation ZAPAT, a joint exercise against illegal migration. In June 2012, there will be
extended cooperation between all the BMAs of Poland, Belarus and Russia regarding
ensuring speedy processing of football supporters travelling to Poland for the European

Page 24

football championships. These special measures will, the PT was informed, involve
some forms of API use.
The PT has noted these positive developments in the Conclusions and
Recommendations at Sections 17, 18 and 19 below, and suggested that they be
developed further with more special joint cross border operations, the results of which
should be shared with all other States in the Partnership and not merely within the
States taking part in a particular exercise. The information exchanges through the
methods of formal regular meetings, and hotline notifications on urgent organizational
(traffic flow) or tactical situations do have some gaps. All BMAs and especially Customs
pointed out that there was a need to coordinate cooperation in relation to the
considerably different Customs risks situations for the EU states and the CU states
regarding
smuggling of excise dutiable goods and drugs into the EU, and the
undervaluation and misdescription of consumer goods into the CU.
It is the view of the PT that both automated exchanges of data enabling the accuracy
of export and import valuations and regular operational meetings should take place.
These operational meetings would seek to build upon the automated exchanges of core
declaration data by discussing ways of dealing with particular tactical cases of mutual
concern, within the context of dealing with the generic challenges, rather than simply
dealing with each case as it comes. In view of the importance of this issue, it is now
discussed further, immediately below.
9.1 Automated exchanges of Information on Customs movements within the
context of operational level coordination between Customs Services
The following comments seek to make proposals which strike a balance between the
desirability of reducing passage times by implementing the provisions of the TIR
Convention regarding the free flow of goods, while ensuring that the very real revenue
and public protection issues of concern to the CU and the EU are taken into full
account. This section particularly addresses the requirements outlined in the TOR at
2.1. (b) and (d). interoperability of technologies and procedures and communication and
common decisions.
In relation to the clause requiring the avoidance of detailed scrutiny of goods at an
external border customs post, the TIR Convention allows in accordance to Article 5 (2)
of the Convention: “....to prevent abuses, Customs authorities may in exceptional cases,
and particularly when irregularity is suspected, carry out an examination of the goods at
such offices”
Clearly, systems need to be in place to prevent such abuse. The PT has therefore
recommended that extensive and early efforts be taken to introduce long term automatic
sharing of risk profiling information and the mutual recognition of Authorised Economic
Operators between Schengen Area states and Customs Union states.
It is recognised that there are domestic data protection issues here and that there is
also the need to recognise key national interests in all states regarding the regulation of
law enforcement agencies IT systems. However, the introduction of international good

Page 25

practices in relation to making significant reductions in the number of Customs
processes, and in reducing physical inspections is consistent with government and
Customs Service policy in the Russian Federation and, by extension, with that of its
Customs Union partners. A recent speech by President Putin, while still Prime Minister,
highlighted the significant reduction in the number of Customs processes as a key
priority for Customs to implement. Equally, the Russian Customs Service regularly
publishes figures regarding the percentages of freight movements which are subject to
intensive (physical) examinations. The publication of these figures implies recognition of
the need to move to a more developed risk management system.
Such risk management systems inevitably benefit significantly from the timely exchange
of information between neighbouring states, especially those which are the points of
entry to or from their respective customs unions.
Accordingly, the PT highlights in its Recommendations the need for enhanced
exchanges and the carrying out of special joint information exchange exercises, and the
long term deployment of staff between states in relation to both the operational and “IT
technical” aspects of information exchange.
The PT believes that the carrying out of such recommendations should be notified
before, during and after the results to all Customs agencies of the Northern Dimension
Partnership. While we believe that all states would benefit from the carrying out of such
recommendations, we would especially suggest that there be such exchanges between
Poland and Belarus in view of the volume of traffic, and between Lithuania and Belarus
in relation to transit traffic between the Kaliningrad region of Russia and Russia itself.
The nature of the information to be exchanged would, of course, be matters for the
BMAs themselves but we suggest that examples would include high consumer demand
electronic goods imported into the CU and which are felt to be prone to serious
undervaluation, as well as capital goods which may be free of Customs duties and may
therefore be misdescribed, with the goods actually being different and subject to duties.
In relation to exports from the CU, EU MS may be able to help regarding the verification
of the integrity of the reported importers of goods which are suspected of being
vulnerable to false export fraud from the CU. But we suggest that the key ways of
reducing physical inspections would be to agree on criteria for mutual recognition of
Authorised Economic Operators and the monitoring of their future compliance.
Given that transport operators reported that clearance times were relatively short when
entering or leaving Finland, there would also be opportunities for comparing the reasons
for this with challenges experienced between Russia and Estonia and Latvia
respectively.
10. The logistics of movements of passengers and goods at Border Crossing
Points
Introduction
This section of the Report addresses particularly the requirements of Section 2.1 c of
the TOR – terminal logistics.

Page 26

It is common practice to use a so called “batch” system to the flow of especially cargo
vehicles through a BCP. Though not apparent immediately, this can have substantial
influence on the overall throughput in a 24 hour period in comparison to a flow system
due to delays caused by bottlenecks5 caused by infrastructure. This section attempts to
explain and visualise the practical implications of the use of one or another system. The
relative benefits of the “batch” system are summarised in the Table at the end of the
Section.
The common process
To illustrate the difference, a simplified but not completely unusual process is taken as
an example. The process concerns the following processes:
 weighbridge,
 customs clearance
The processing duration for the weighbridge is 5 minutes, while the customs processing
takes 20 minutes, but there are 4 windows, allowing for 4 vehicles to be processed at
the same time. For simplicity of the explanation, it is assumed that there are no time
delays going from one process to the other, or there are no queue's anywhere.
In addition, the calculations reflect current practice as reported by drivers, that the next
batch is only allowed into the BCP when the entire previous batch has been processed
and has left the BCP at the other end.
We do not however make the assumption that, like in normal practice for batch systems,
all vehicles in the batch will first need to clear the first process before the second
process can start, but we assume instead that the every vehicle clearing the first
process can immediately proceed to the second process.

5

A bottleneck process is a process of which the throughput capacity is the smallest of all processes at a BCP. Most likely, these are
processes that require specific pieces of hardware that are expensive to acquire and of which there is often only one. Managing the bottleneck, by
for example ensuring that its process is only used in particular cases when justified by identified risks is one option that comes at very little or no
cost. Alternatively, but already far more expensive is to increase the quantity of equipment available for the bottleneck process. More on
managing bottlenecks can be found in the book “the goal” from Ely Goldrat.


Page 27

batch size 10
time lapse time lapse time lapse time lapse time lapse time lapse time lapse time lapse time lapse time lapse
process duration
1st
2nd
3rd
4th
5th
6th
7th
8th
9th
10th
Weighbridge
5
5
10
15
20
25
30
35
40
45
50
Customs 1
20
Customs 2
20
Customs 3
20
Customs 4
20
time lapse from begin first process

20

20
20

20
20

20
25

30

35

20
20

20
40

45

50

55

20
60

Maximum process duration for individual vehicle:
Time required to process 10 vehicles:

65

70

70 Minutes
50+20 = 70 minutes

Continuous flow
time lapse time lapse time lapse time lapse time lapse time lapse time lapse time lapse time lapse time lapse
process duration
1st
2nd
3rd
4th
5th
6th
7th
8th
8th
10th
Weighbridge
5
5
5
5
5
5
5
5
5
5
5
Customs 1
20
Customs 2
20
Customs 3
20
Customs 4
20
time lapse from begin first process

20

20
20

20
20

20
25

25

25

20
20

20
25

25

25

25

Maximum process duration for individual vehicle:
Time required to process 10 vehicles:

20
25

25

25 Minutes
50 + 20 = 70 minutes

As can be noted from above, the application of a batch system substantially increases
the waiting time for individual vehicles in the worst case scenario, in the example, it is 70
minutes for the batch processing versus 25 minutes for a continuous flow system. With
regard to the duration of the total process (e.g.) from the total of 10 vehicles being
processed, in this particular case, there is no difference in duration, for each situation,
the total time to process 10 vehicles is 70 minutes.
However, the numbers hide a more important difference, which does severely affect the
total capacity to process vehicles in a certain period of time. In case of the batch
processing approach, the there are several work stations that do not have any work for
a certain period of time either before the first customer arrives (in case of customs) or
after the last customer has left, such as in case of the weighbridge. As time dissipates
when it goes forward, the lost production cannot be recovered easy. In the above
example, the processing capacity of a continuous flow system would be at least 20%,
but up to 40% higher than in the batch processing approach.
If we once more take the example, in case of batch, the throughput in 70 minutes would
be 10 vehicles, regardless what happens. In case of the continuous flow, the maximum
throughput that can be achieved in the same 70 minute period at the bottleneck (the
weighbridge) would be 14 vehicles, an improvement of 40%. This would then also
provide for a more constant workflow at the customs posts and increase its capacity
there through reducing idle time.


25

Page 28

Concluding, a critical assessment is essential of all processes at a BCP over a period of
to identify the bottleneck processes6 . There is no single process that is solely or even
very largely responsible for delays, though the PT felt that the replacement of batch
systems with flow systems was perhaps the biggest step which could be taken.
Table Batch v Flow
Batch size

st

10
st

nd

rd

th

Process duration, min

1

2

3

4

Weighbridg
e

5

5

10

15

20

Customs 1

20

25

Customs 2

20

Customs 3

20

Customs 4

20

Total time in the BCP

th

Time lapse from arrival of a truck at the BCP (from 1 to 10 )
th

th

th

th

6

7

8

25

30

35

40

45

45

10

50

65
50

35

70
55

40
30

th

9

30

25

th

5

35

40

60
45

50

55

60

65

70

Maximum duration of stay of a vehicle in the BCP is 70 minutes
Time required to process 10 vehicles is 70 minutes
Total number of vehicles in the BCP area at the same time is 10

Batch size

st

1
st

Process duration, min

1

Weighbridg
e

5

5

Customs 1

20

Customs 2

20

Customs 3

20

Customs 4

nd

rd

20

th

25

Total time in the BCP

th

Time lapse from arrival of a truck at the BCP (from 1 to 10 )
2

5

3

5

4

5

th

5

5

th

6

5

th

7

5

5

25
25

5

25

25

th

10

5

25
25

25
25

th

9

25

25

25

th

8

25

25
25

25

25

25

25

25

Each vehicle is processed within 25 minutes since arrival at the BCP
Time required to process 10 vehicles is 70 minutes
6


Page 29

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