Crac des Chevaliers and Qal’at Salah El-Din (Syrian Arab Republic) (C 1229)
Year of inscription on the World Heritage List 2006
Year(s) of inscription on the List of World Heritage in Danger
Threats for which the property was inscribed on the List of World Heritage in Danger
Destruction as well as ascertained and potential threats consequent to the armed conflict in Syria started in March 2011
Corrective measures identified
Not yet identified
Timeframe for the implementation of the corrective measures
Not yet identified
Previous Committee Decisions see page https://whc.unesco.org/en/list/1229/documents/
Requests approved: 0
Total amount approved: USD 35,000
For details, see page https://whc.unesco.org/en/list/1229/assistance/
UNESCO Extra-budgetary Funds
Total amount provided to the six Syrian World Heritage properties for World Heritage, movable and intangible heritage: 2.46 million Euros by the European Union, USD 170,000 by the Flemish Government, 63,000 Euros by the Austrian Government, USD 200,000 by the German Government ; for cultural heritage under conflict: USD 200,000 by the Arab Regional Centre for World Heritage in Bahrain
Previous monitoring missions
Since the start of the conflict in March 2011, the security situation has not allowed any missions to be undertaken to this World Heritage property
Factors affecting the property identified in previous reports
Before the conflict:
- Lack of definition of the limits of the properties and of their buffer zones
- Lack of conservation and/or management plans
- Inappropriate restoration works
- Urban encroachment
- Exploitation of quarries within the perimeter of World Heritage properties
- Destruction and damage due to the armed conflict
Illustrative material see page https://whc.unesco.org/en/list/1229/
Conservation issues presented to the World Heritage Committee in 2018
On 15 January 2018, the State Party submitted a state of conservation report for the six Syrian World Heritage properties, which is available at http://whc.unesco.org/en/list/1229/documents, and includes updated information, progress and difficulties in a number of conservation issues addressed by the Committee, as follows:
Restauration works and documentation have been carried out by the Syrian-Hungarian archaeological mission at the Chapel of the Crac des Chevaliers and adjacent courtyard. The mission removed the concrete layer on the roof, which allowed documenting stones, and replaced the isolation. It conducted studies for the roof drain water drain system of the Chapel as well as excavations for the draining system of the courtyard, and documented the frescos inside the Chapel. The report also indicates that consolidation and restauration works have started at the southwestern corner of Chapel.
On 27 March 2018, the Directorate General of Antiquities and Museums (DGAM) submitted to the World Heritage Centre a preliminary project that foresees the implementation of tourism facilities and a cable car at Qal’at Salah El-Din.
Analysis and Conclusions of the World Heritage Centre, ICOMOS and ICCROM
See General Decision 42 COM 36 of this Document on the World Heritage properties of the Syrian Arab Republic.
The works carried out at the Chapel are part of the ‘Urgent restoration works of simple to medium complexity’ recommended by the Committee (Decision 41 COM 7A.48). These works are carried out despite the difficult situation, including reduced human and financial resources. On the images provided in the report, it is noticed that the stones used to build the parapet on the Chapel’s roof in preparation of the isolation works are newly-cut stone blocks that are incompatible with the historic building. The State Party is encouraged to continue implementing the recommendations of the Technical Assistance Workshop organized by the World Heritage Centre, and in particular, to reuse the original stones as much as possible, and supplement them, as much as the current circumstances allow it, with identical newly- extracted one from the quarry of origin.
The detailed 3D modeling of the Crac des Chevaliers has been completed with the support of UNESCO.
The implementation of a cable car at the World Heritage site would represent a threat to the Outstanding Universal Value of the site. It is recommended that the Committee urge the State Party to abandon the project of a cable car, to limit interventions to emergency measures and urgent conservation activities until the situation improves and to submit to the World Heritage Centre for examination by the Advisory Bodies, a detailed project on the tourism facilities foreseen at the property accompanied by a Heritage Impact Assessment, before any work is implemented, in conformity with Paragraph 172 of the Operational Guidelines.
It is recommended that the invited joint World Heritage Centre/ICOMOS/ICCROM Reactive Monitoring mission to the property be carried out to examine the restoration works that have been undertaken and the foreseen ones, as soon as the situation allows.
36. General Decision on the World Heritage properties of the Syrian Arab Republic
- Current conservation issues
The armed conflict in Syria started in March 2011 and has constantly escalated leading to significant violence and degradation of humanitarian conditions. It continues to inflict damage on the inscribed properties as well as on the 12 sites inscribed on the Tentative List. Sites continue to be damaged by shelling, fires, extensive illegal excavations, military use, construction violations, in addition to intentional destructions and inappropriate use of archaeological sites by internally displaced populations.
On 15 January 2017, the State Party submitted a state of conservation report, available at http://whc.unesco.org/en/sessions/42COM/documents/#state_of_conservation_reports, with detailed information on the destruction and damage at the six World Heritage properties. This report represents an official statement from the Syrian authorities and collates available information from the branches of the Directorate General of Antiquities and Museums (DGAM) and from the local communities up to 31 December 2017. The State Party notes that as ground access in Syria for heritage experts is limited, the full extent of the damage to World Heritage properties cannot be assessed in detail. In particular, the report does not provide first-hand information on the Ancient Villages of Northern Syria and the Ancient City of Bosra that are exposed to the armed conflict, and thus does not allow a full understanding of the extent of damage at these properties.
The State Party reported on the actions carried out by the DGAM, despite the difficult working conditions, to monitor the World Heritage properties and cultural heritage in general, assess damages, undertake emergency conservation and risk mitigation actions whenever possible, and inventory built and movable heritage. The report also stressed the DGAM efforts in maintaining salaries for its staff in the inaccessible Ancient Villages of Northern Syria, and highlighted the positive role played by local communities in some cases to safeguard heritage and limit illegal excavations.
On 21 January 2018, the State Party provided updated information on the conservation of the sites inscribed on the Tentative List, which indicates the following:
- In ‘Mari (Tell Hariri) and Dura Europos’, images of the sites sent by local communities confirm illegal excavations at both sites and damages at the Royal Palace in Mari. The DGAM is planning an emergency mission to these sites that are currently back under governmental control and guarded by local communities;
- In ‘Maaloula’, the Municipality and the United Nations Programme for Development (UNDP) have completed the rehabilitation of infrastructures;
- ‘Raqqa-Rafiqa: the Abassid City’ is under the control of armed groups;
- No further damages are reported at the sites of ‘Ebla (Tell Mardikh)’, ‘Apamea (Afamia)’, ‘Qasr al-Hayr ach-Charqi, a desert Castle’;
- No information is given for the sites of ‘Arwad Island’, ‘Noreas of Hama’, ‘Tartus: the Crusaders Citadel-City’ and ‘Ugrarit (Tell Shamra).
Activities undertaken by UNESCO
- Since the 41st session of the Committee (Krakow, 2017), UNESCO has pursued its actions to assist the State Party in its continuous and sustained efforts to safeguard cultural heritage;
- At the international level, UNESCO continues to raise the awareness of the international community on the destruction of cultural heritage in Syria, notably through the #Unite4Heritage campaign and in the framework of the implementation of the United Nations Security Council (UNSC) Resolution 2199 (February 2015) and Resolution 2347 (March 2017) recognizing for the first time the importance of heritage protection for peace and security;
- At the national level, UNESCO has pursued its activities to monitor the situation of Syrian cultural heritage, raise awareness on its protection, undertake short, medium and long-term actions to safeguard it, and coordinate the work of national and international entities working on its safeguarding;
- In the framework of the European Union-funded project “Emergency Safeguarding of Syrian Cultural Heritage” (2.46 million euros), co-financed by Flanders and Austria, started in March 2014 and implemented in partnership with ICOMOS and ICCROM, the following activities were undertaken:
- From 26 February to 2 March 2018, a training workshop was organized in Beirut on emergency and preventive conservation techniques for museums and collections,
- From September 2017 to April 2018, a “Vocational Training in Stone Carving/Cutting and Stone Masonry” workshop was organized in Aleppo in collaboration with the Aga Khan Trust for Culture (AKTC) to provide practical training and theory to 30 builders and stone masons in view of involving them in future restoration works (Aleppo),
- In November and December 2017, workshops, a round table and exhibition entitled “Archaeology for a Young Future” were organized in Beirut (Lebanon), in collaboration with the Society of the Friends of the American University of Beirut, on local communities’ involvement in the archaeological preservation of the Qamishli area (Syria),
- In September 2017, a First Aid Support Meeting was organized in Rieti (Italy) in collaboration with the Centro di Conservazione Archeologica (CCA) for the conservation of the mosaics of the Maarat al-Nu’man Museum, which mostly originate from the Ancient Villages of Northern Syria
- On 10 and 11 August 2017, a first Aid Support Meeting was organized on on traditional materials and techniques in Aleppo
- The 3D documentation and structural analysis of the Crac des Chevaliers, Beit Ghazaleh and Beit Ajiqbash (Museum of Folks Arts) in Aleppo have been completed by the DGAM with the technical support of professional teams,
- A 52-minute "Documentary on the Safeguarding of the Syrian Cultural Heritage" in Arabic, English and French, on the actions implemented for the protection of cultural heritage in Syria is being produced and foreseen to be launched by August 2018;
- In the framework of the project funded by Germany entitled “Capacity Building, Technical and Media Support for the Protection of Syrian Cultural Heritage” (USD 200,000) implemented in collaboration with the German Archaeological Institute (DAI), between November and December 2017, three workshops were organized in Beirut and one was organized in Berlin to enhance the Syrian professionals capacities in recording, storing and analyzing cultural heritage research data;
- The UNESCO Heritage Emergency Fund provided financial support for the following activities:
- The emergency consolidation of the stair-step bridge leading to the main gate of the Aleppo Citadel; debris management and damage assessment for 170 historic buildings in the property, by the DGAM.
- A publication on damage assessment in the Ancient City of Aleppo, jointly prepared by the World Heritage Centre and the United Nations Institute for Training and Research’s Operational Satellite Applications Programme (UNITAR/UNOSAT);
- The restoration of the statue of the Lion of Athena/Lion of Al-lāt of Palmyra, by the DGAM with the support of the Polish archaeological
- In the framework of the Flemish Funds-in-Trust project entitled ‘Implementation of the Committee Decisions for the Site of Palmyra’ (USD 100 000), an international expert mission to the site is foreseen to support the DGAM in planning emergency consolidation works in Palmyra, but could not be undertaken yet, due to the security situation on the ground.
- The joint World Heritage Centre/ICCROM/ICOMOS Reactive Monitoring mission, which was foreseen to be carried out to Damascus and Aleppo in March 2017, could not take place under the United Nations security and safety rules.
- The UNESCO Culture and Education national officers in Aleppo continue to ensure coordination with local and national authorities for the implementation of activities for the recovery of the property.
Activities undertaken by the Advisory Bodies
- Capacity building for six Syrian professionals has taken place through their participation in a number of ICCROM activities such as the short course series organized by the ICCROM-Sharjah Office on the conservation and documentation of built cultural heritage, and also ICCROM's International Course on Stone Conservation. In addition, active participation of senior officials took place in the Arab Cultural Heritage Forum as well as the colloquia organized by ICCROM on post-conflict reconstruction at Louvre-Lens and in Rome.
- ICOMOS has closely followed the situation in Syria, maintaining contact with the cultural heritage community in the country, and working to provide advice and raise awareness. Through its Project Anqa, run in cooperation with Cyark, and funded by the Arcadia Foundation, ICOMOS contributed to the 3D recording of six at-risk heritage sites in Syria and capacity building of Syrian professionals – with the aim of fostering the creation of a sustainable 3D architectural inventory. It is also a partner in the AMAL in Heritage project (mobile and web application for rapid damage assessment of cultural heritage in conflict zones) launched by the Global Heritage Fund (GHF) in partnership with ICCROM, the Arab Regional Centre for World Heritage (ARC-WH), and the Prince Claus Fund, which has also provided training to Syrian professionals.
- Analysis and Conclusions of the World Heritage Centre, ICOMOS and ICCROM
The armed conflict situation in Syria and its continued escalation has affected the six World Heritage properties and has substantially limited capacities to adequately sustain and protect their Outstanding Universal Value. The properties have been increasingly threatened by ascertained and potential dangers, in particular the Ancient City of Aleppo, which has been extensively and increasingly destroyed, and which runs the risk of further irreversible destructions during the challenging recovery phase.
The illegal excavations across archaeological sites and tells in Syria are a major source for the illicit trafficking of cultural objects and are causing extensive and irreversible damages to those sites, many of which are on Syria’s Tentative List, as well as providing looted artifacts for sale in regional and international black markets.
It is recommended that the Committee commend the DGAM, heritage professionals in Syria and local communities who have made sustained efforts to protect cultural heritage and to monitor it closely.
The World Heritage Centre and the Advisory Bodies will continue to support the State Party in the identification of the necessary corrective measures and in the development of a Desired state of conservation for the removal of the property from the List of World Heritage in Danger (DSOCR), for all six properties, as soon as the situation allows.
It is important that humanitarian and security actions be done in coordination with cultural heritage stakeholders, to avoid further irreversible damages to the properties, and allow for undertaking first aid measures for its cultural heritage. Furthermore, it is recommended that systematic documentation of all damage incurred at the World Heritage properties be duly pursued, whenever the situation allows, and that the Committee reiterate its call to the State Party to safeguard damaged properties through minimal first aid interventions to prevent theft, further collapse and natural degradation, and refrain from undertaking other measures until the situation allows for the development of a comprehensive strategy and action plan that respond to international standards and high-quality scientific methods.
With regard to post-conflict interventions, it is recommended that the Committee call on the State Party to plan the future of the World Heritage properties according to international conservation charters and standards, in full consultation with the World Heritage Centre and the Advisory Bodies.
It is recommended that the Committee call for international and national heritage professionals to continue to unite for the safeguarding of Syria’s cultural heritage; and to further support its safeguarding through earmarked funds and to contributions to the UNESCO Heritage Emergency Fund.
Until conditions improve, it is also recommended that the Committee urge all parties associated with the conflict in Syria to refrain from any action that can further damage the heritage of the country, in particular World Heritage properties and all sites included on the Tentative List, and to fulfil their obligations under international law, and in particular the United Nations Security Council Resolution 2347 of March 2017, in part by taking all possible measures to protect such heritage including the evacuation of World Heritage properties used for military purposes, and the halting of all damages that result from targeting World Heritage properties. It is also recommended that the Committee reiterate its suggestion that the State Party consider ratifying the Second Protocol (1999) of the 1954 Hague Convention for the Protection of Cultural Heritage during times of Armed Conflict.
It is further recommended that the Committee also call upon all parties associated with the conflict in Syria and the international community, in particular the neighboring countries to Syria, to ensure effective measures for the fight against illicit trafficking of cultural objects, in line with the UN Security Council Resolution 2199.
Decision Adopted: 42 COM 7A.34
Note: the following reports on the World Heritage properties of the Syrian Arab Republic need to be read in conjunction with Item 36.
The World Heritage Committee,
- Having examined Document WHC/18/42.COM/7A.Add,
- Recalling Decisions 41 COM 7A.48 and 41 COM 7A.50 adopted at its 41st session (Krakow, 2017),
- Taking into account Decision 42 COM 7A.36 on the World Heritage properties of the Syrian Arab Republic,
- Takes note of the restoration works undertaken at the Chapel despite difficult conditions;
- Encourages the State Party to continue implementing the recommendations of the Technical Assistance Workshop organized by the World Heritage Centre, and in particular, while undertaking urgent restoration works, to reuse as much as possible the original stones, and supplement them with identical newly- extracted ones from the quarry of origin, as much as the current circumstances allow it;
- Urges the State Party to:
- Abandon the project of a cable car at Qal’at Salah El-Din,
- Limit interventions to emergency measures and urgent conservation activities until the situation improves,
- Submit to the World Heritage Centre, for examination by the Advisory Bodies, a detailed project on the tourism facilities foreseen at the property accompanied by a Heritage Impact Assessment, before any work is implemented, in conformity with Paragraph 172 of the Operational Guidelines;
- Calls on all UNESCO Member States to support emergency safeguarding measures, including through the UNESCO Heritage Emergency Fund;
- Requests that the invited joint World Heritage Centre/ICOMOS/ICCROM Reactive Monitoring mission be carried to proceed to a comprehensive assessment of the state of conservation of the property and identify measures needed to reverse the decay and ensure the conservation and protection of the property, as soon as the security situation allows;
- Also requests the State Party to submit to the World Heritage Centre, by 1 February 2019, an updated report on the state of conservation of the property and the implementation of the above, for examination by the World Heritage Committee at its 43rd session in 2019;
- Decides to retain the Crac des Chevaliers and Qal’at Salah El-Din (Syrian Arab Republic) on the List of World Heritage in Danger.
Decision Adopted: 42 COM 7A.36
The World Heritage Committee,
- Having examined Document WHC/18/42.COM/7A.Add,
- Recalling Decision 41 COM 7A.50, adopted at its 41st session (Krakow, 2017),
- Deplores the conflict situation prevailing in the country, the loss of human life and the degradation of humanitarian conditions;
- Taking note of the reports provided by the State Party regarding the state of conservation of the six Syrian World Heritage properties and of the sites inscribed on the Syrian Tentative List, commends the Directorate General of Antiquities and Museums (DGAM) and all the heritage professionals and the local communities in Syria who are working on monitoring and protecting cultural heritage for their sustained efforts amidst extremely difficult conditions, but expresses its utmost concern at the damage occurred and the threats facing these properties and cultural heritage in general;
- Urges all parties associated with the situation in Syria to refrain from any action that would cause further damage to cultural heritage of the country and to fulfil their obligations under international law, and in particular the United Nations Security Council Resolution 2347 of March 2017, by taking all possible measures to protect such heritage, including the halting of all damages that result from targeting World Heritage properties, sites included in the Tentative List and other cultural heritage sites;
- Also urges the State Party to adopt measures for the evacuation of World Heritage properties being used for military purposes;
- Further urges the State Party and the international community to include recovery actions within the properties to the overall humanitarian, security and peace building response;
- Urges furthermore the State Party to safeguard damaged properties through minimal first aid interventions to prevent theft, further collapse and natural degradation, and to refrain from undertaking conservation and restoration work until the situation allows, for the development of comprehensive conservation strategies and actions that respond to international standards in full consultation with the World Heritage Centre and the Advisory Bodies;
- Launches an appeal to all Member States of UNESCO to cooperate in fighting against the illicit trafficking of cultural heritage coming from Syria as per the United Nations Security Council Resolution 2199 of February 2015, and in engaging in the protection of cultural heritage during armed conflict as per the United Nations Security Council Resolution 2347 of March 2017, and reiterates its suggestion to the State Party to consider ratifying the Second Protocol (1999) of the 1954 Hague Convention for the Protection of Cultural Heritage during times of Armed Conflict;
- Requests the State Party to pursue the systematic documentation of all damage incurred by the World Heritage properties, whenever conditions allow, and to implement all possible risk mitigation measures, to inform on the development of the Desired state of conservation for the removal of the properties from the List of World Heritage in Danger (DSOCR) and the identification of corrective measures for all six properties;
- Calls upon the international community to further support the safeguarding of Syrian cultural heritage through earmarked funds or through contribution to the UNESCO Heritage Emergency Fund;
- Also calls upon the international and national cultural heritage professionals to unite for the safeguarding of Syria’s cultural heritage, and pursue their ongoing initiatives in coordination with UNESCO;
- Also requests the State Party to submit to the World Heritage Centre, by 1 February 2019, an updated report on the state of conservation of the properties and the implementation of the above, for examination by the World Heritage Committee at its 43rd session in 2019.
Decision Adopted: 42 COM 8C.2
The World Heritage Committee,
- Having examined the state of conservation reports of properties inscribed on the List of World Heritage in Danger (WHC/18/42.COM/7A, WHC/18/42.COM/7A.Add and WHC/18/42.COM/7A.Add.2),
- Decides to retain the following properties on the List of World Heritage in Danger:
- Afghanistan, Cultural Landscape and Archaeological Remains of the Bamiyan Valley (Decision 42 COM 7A.1)
- Afghanistan, Minaret and Archaeological Remains of Jam (Decision 42 COM 7A.2)
- Austria, Historic Centre of Vienna (Decision 42 COM 7A.5)
- Bolivia (Plurinational State of), City of Potosí (Decision 42 COM 7A.8)
- Central African Republic, Manovo-Gounda St Floris National Park (Decision 42 COM 7A.45)
- Chile, Humberstone and Santa Laura Saltpeter Works (Decision 42 COM 7A.9)
- Côte d'Ivoire / Guinea, Mount Nimba Strict Nature Reserve (Decision 42 COM 7A.46)
- Democratic Republic of the Congo, Garamba National Park (Decision 42 COM 7A.47)
- Democratic Republic of the Congo, Kahuzi-Biega National Park (Decision 42 COM 7A.48)
- Democratic Republic of the Congo, Okapi Wildlife Reserve (Decision 42 COM 7A.49)
- Democratic Republic of the Congo, Salonga National Park (Decision 42 COM 7A.50)
- Democratic Republic of the Congo, Virunga National Park (Decision 42 COM 7A.51)
- Egypt, Abu Mena (Decision 42 COM 7A.17)
- Honduras, Río Plátano Biosphere Reserve (Decision 42 COM 7A.44)
- Indonesia, Tropical Rainforest Heritage of Sumatra (Decision 42 COM 7A.40)
- Iraq, Ashur (Qal'at Sherqat) (Decision 42 COM 7A.18)
- Iraq, Hatra (Decision 42 COM 7A.19)
- Iraq, Samarra Archaeological City (Decision 42 COM 7A.20)
- Old City of Jerusalem and its Walls (site proposed by Jordan) (Decision 42 COM 7A.21)
- Libya, Archaeological Site of Cyrene (Decision 42 COM 7A.22)
- Libya, Archaeological Site of Leptis Magna (Decision 42 COM 7A.23)
- Libya, Archaeological Site of Sabratha (Decision 42 COM 7A.24)
- Libya, Old Town of Ghadamès (Decision 42 COM 7A.25)
- Libya, Rock-Art Sites of Tadrart Acacus (Decision 42 COM 7A.26)
- Madagascar, Rainforests of the Atsinanana (Decision 42 COM 7A.53)
- Mali, Old Towns of Djenné (Decision 42 COM 7A.13)
- Mali, Timbuktu (Decision 42 COM 7A.14)
- Mali, Tomb of Askia (Decision 42 COM 7A.15)
- Micronesia (Federated States of), Nan Madol: Ceremonial Centre of Eastern Micronesia (Decision 42 COM 7A.3)
- Niger, Aïr and Ténéré Natural Reserves (Decision 42 COM 7A.54)
- Palestine, Birthplace of Jesus: Church of the Nativity and the Pilgrimage Route, Bethlehem (Decision 42 COM 7A.27)
- Palestine, Palestine: Land of Olives and Vines – Cultural Landscape of Southern Jerusalem, Battir (Decision 42 COM 7A.29)
- Palestine, Hebron/Al-Khalil Old Town (Decision 42 COM 7A.28)
- Panama, Fortifications on the Caribbean Side of Panama: Portobelo-San Lorenzo (Decision 42 COM 7A.10)
- Peru, Chan Chan Archaelogical Zone (Decision 42 COM 7A.11)
- Senegal, Niokolo-Koba National Park (Decision 42 COM 7A.55)
- Serbia, Medieval Monuments in Kosovo (Decision 42 COM 7A.6)
- Solomon Islands, East Rennell (Decision 42 COM 7A.41)
- Syrian Arab Republic, Ancient City of Aleppo (Decision 42 COM 7A.30)
- Syrian Arab Republic, Ancient City of Bosra (Decision 42 COM 7A.31)
- Syrian Arab Republic, Ancient City of Damascus (Decision 42 COM 7A.32)
- Syrian Arab Republic, Ancient Villages of Northern Syria (Decision 42 COM 7A.33)
- Syrian Arab Republic, Crac des Chevaliers and Qal’at Salah El-Din (Decision 42 COM 7A.34)
- Syrian Arab Republic, Site of Palmyra (Decision 42 COM 7A.35)
- Uganda, Tombs of Buganda Kings at Kasubi (Decision 42 COM 7A.16)
- United Kingdom of Great Britain and Northern Ireland, Liverpool – Maritime Mercantile City (Decision 42 COM 7A.7)
- United Republic of Tanzania, Selous Game Reserve (Decision 42 COM 7A.56)
- United States of America, Everglades National Park (Decision 42 COM 7A.42)
- Uzbekistan, Historic Centre of Shakhrisyabz (Decision 42 COM 7A.4)
- Venezuela (Bolivarian Republic of), Coro and its Port (Decision 42 COM 7A.12)
- Yemen, Historic Town of Zabid (Decision 42 COM 7A.37)
- Yemen, Old City of Sana’a (Decision 42 COM 7A.38)
- Yemen, Old Walled City of Shibam (Decision 42 COM 7A.39)