Table 4b. Emergency Funding – SOLID Framework, 2008-2013 External Borders Fund Return Fund European Refugee Fund 5 million 5 million 34 million *Source: Commission Staff Working Document on the Assessment of the Implementation of the Greek Action Plan on Asylum and Migration Management, 2014 In terms of the absorption of the Funds, Greece’s rate had some serious fluctuations (at its lowest 43%)35, but since 2011 it has been relatively high, with an average rate of over 85%.36 In order to draw funding from each instrument, Greece had to prepare a multi-annual national program, setting out the strategy to achieve the objectives of the EU's common policy, accompanied by a draft financial plan. This was then sent to the Commission for approval. Greece was largely free to select its projects and the way they would be carried out, as long as they were intrinsically linked to the common standards, or sought to bring collective benefits at an EU level.37 Once approved, funding was released on an annual basis. Additional funding could be provided in emergency situations. The cooperation between Greece and the Commission has largely been fruitful. The most wellknown disagreement was the Commission's refusal to participate, through the External Borders Fund, in the erection of the fence along the Greek-Turkish Border; an undertaking it publicly renounced as “pointless”.38 In response, the Greek authorities accused the Commission of hypocrisy.39 What is important to note, however, is that from a financial and political perspective, Greece's irregular migration control practices are in many respects the direct product of the EU's common policy approach. 35 See Commission Staff Working Document, 2014, p. 18, fn 23 36 See Ministry of Citizen Protection, Statement , 9 March 2011, http://www.minocp.gov.gr/index.php?option=ozo_content&lang=&perform=view&id=3542&Itemid=497 ; see also Commission Staff Working Document on the Assessment of the implementation of the Greek Action Plan on Asylum and Migration management, 2014, fn 23 which noted that until 2010 only 43% of the EBF allocation was actually absorbed, p. 18 37 See Commission of the European Communities, “Communication from the Commission to the Council and the European Parliament establishing a framework programme on Solidarity and the Managem ent of Migration Flows for the period 2007-2013”, COM/2005/0123 final , 6 April 2005, available at http://eur-lex.europa.eu/legalcontent/EN/TXT/?uri=CELEX:52005DC0123 38 See “Minister in EU row over fence”, 7 February 2012, available at http://www.ekathimerini.com/4dcgi/_w_articles_wsite1_1_07/02/2012_426615 39 Ibid. Page 21