The Minister specified that the Coquelles CRA does not have the capacity to meet the atypical requirements of the numerous migrants that need to be placed in detention, and it is therefore necessary to place a part of them in other CRA across the national territory. He stated that, every day and across the territory, people are placed in administrative detention outside the department and even outside the place in which they were taken into custody, and that moreover, since the objective of the detention is to identify the detainees, priority is given to placing them in administrative detention in CRA in the Paris region (close to the consulates) or in those close to the France-Italy border due to the Schengen or Dublin re-entries. As regards access to legal remedy, the Minister stated that the placement in a faraway CRA is determined at the same time as the decision to place the person in detention, and that these procedures do not hinder the exercising of the right to asylum. In addition, he informed the Contrôleur général that the intervention of the liberty and custody judge was reduced to 48 hours in the bill pertaining to the rights of foreign nationals. As regards the physical conditions of custody and detention for the purpose of verifying the right of residence, the Minister indicated that each person is provided with sheets and that toilets were present in the individual cells. The Minister specified that the law dissociates the decision of the obligation to leave French territory (OQTF) from the decision determining the country of destination. He indicated that the obligation of not separating minors from their parents is meticulously respected. A reminder of the instructions was given concerning the absence of interpreters in the Paris-Vincennes CRA. As regards the misuse of placing people in administrative detention, the Minister disputed the analysis of the Contrôleur général. He indicated firstly that the prefect cannot and must not presume the completion of the deportation procedure when he initiates it and that it is physically impossible for the questioning services to carry out the documentary verifications of people before they are placed in administrative detention. He specified that pursuant to applicable law, the prefects do not demand for the foreign national to be kept in administrative detention beyond five days if no identification information on that person was found within this period; the person is freed in this case. On the other hand, extending the detention period is systematically done if there is a possibility of identification and therefore the deportation of the person involved. He added that the Pas-de-Calais prefecture supported extending the detention period in 45% of the cases. Finally, concerning the scheduling of the transfers organised according to a predefined frequency, the Minister justified this practice using the size of the migration flows and the intense activity of taking people in for questioning. He added that the rhythm of these transfers has decreased, from forty-three people per day on an average at the start of this practice to an average of twenty-seven from 1 November, specifying that the reduction of placements should allow improving the monitoring of the measures and an increase in the rate of execution of deportation measures. The Contrôleur général upheld her observations and her analysis of the collective transfers. She was satisfied concerning the fact that the intervention of the liberty and custody judge was reduced to 48 hours in the bill pertaining to the rights of foreign nationals, which had been a recommendation of the Contrôleur général for several years. She regrets that, while the number of people transferred daily has reduced, this practice has not yet been ended. 2. Three opinions published in the Journal Officiel [Official Gazette] 44

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