Report on the Performance of the Activities of the National Preventive Mechanism for 2019 the Lepoglava State Prison, are encouraging. Nevertheless, there is still much room for improvement and harmonization with international standards. In interviews and anonymous surveys that we conducted during our visits, persons deprived of their liberty have indicated that there is violence among prisoners, about which we wrote more in previous reports. It is additionally concerning that data from the Report on the Conditions and Work in State and County Prisons and Juvenile Correctional Institutions show that during 2018, there have been 166 physical conflicts among prisoners, 31 more than in 2017. In spite of this, the recommendation from the 2018 Report, issued with the CPT's RC report for 2018 (§31) in mind, to draft a national plan to combat violence among prisoners, has not been implemented. As we have been highlighting for years the necessity of adopting a new EPSA, we received the drafting of the Draft proposal with great interest. However, the way the public consultation was carried out, as well as the Draft text itself, do not lend themselves to much optimism. The eConsultation on the Draft proposal was opened in late November, and only lasted for 15 days, which is certainly too little, as the legislation is new. Two weeks after the consultation was closed, it was reopened without any explanation, again for 15 days. Hence, it is difficult to resist the impression that the point of the consultation was not to gather relevant information, ideas and opinion, that is, to promote, ensure and strengthen transparency and inclusion of all stakeholders, but merely to make a show of following procedure. It is additionally concerning that certain existing standards have been omitted, and that its adoption is being used to make it fit around the existing practical problems. For instance, after a four-year trend of growing prison population, it is proposed that the standard 4m2 of space per prisoner be erased. Here, we also have to remind of the European Prison Rules (18.3.), which stipulate that specific minimum standards are to be set in national law. Equally, instead of at least one visit daily by a medical practitioner to prisoners held in solitary confinement, as stipulated by the current EPSA, it is proposed that visits should take place twice weekly. In addition, it is proposed that certain measures to maintain order and security are carried out under the supervision of a medical nurse or technician, rather than exclusively a doctor as has up to now been the case, which is a retrograde step. Although 88% of the comments on the Draft proposal were rejected after the first consultation, and as many as 91% after the second, we hope that as the process continues, which we will be following with interest, suggestions by both the professional and the wider public will be taken into consideration to a greater extent, with the aim of ensuring the quality of the new EPSA. Cooperation with penal institutions during 2019 was good, but there is room to improve the cooperation with the COPSPD, especially when it comes to issuing reports and data within deadlines. Since we warned the COPSPD of this problem in October 2019, we hope that there will be positive changes. 13