Geezers have got to go
Geezers have got to go
Geezers have got to go
Geezers are simply in the way.
—The Rules (Van Kooten & De Bie), 1989 (roughly translated from Dutch)
Geezers have got to go
Geezers have got to go
Geezers have got to go
Geezers are simply in the way.
—The Rules (Van Kooten & De Bie), 1989 (roughly translated from Dutch)
There will always be some discrepancy between the documents produced through the bureaucratic paper mill of a municipality, and reality as experienced by the people targeted by the policy concerned. But the gap is rarely as wide as in the case of Amsterdam’s art and culture policy of the past few years. While the city continues to trumpet its identity as ‘creative laboratory’, and as the vibrant centre of all that is hip and liberal and artistic, the artists themselves are seriously concerned about the steady deterioration of the bedrock of the cultural landscape.[1] Facilities are being closed down, affordable places to live and work are becoming scarcer by the day, and networks are eroding because friends and colleagues decide to pursue their luck and career in another country. Every debate organised in the capital city on artists’ accommodation, studio policy, gentrification or the closure of exhibition space – and there are numerous such debates at present – is guaranteed to draw a full house, as some kind of collective therapy session for a decidedly depressed population of cultural workers.
One of the issues that the city’s artists are most concerned about is the policy regarding studios and temporary creative incubator spaces or ‘broedplaatsen’ (‘breeding places’). For many artists, having affordable workspace is a fundamental condition for having a viable professional practice. But in a city where real estate prices continue to rise every day, affordable space is increasingly hard to come by, and that applies to studio space as well. Add to this the fact that rents for dwellings have also increased tremendously in recent years[2], and it is obvious that both young and older artists are in a very tough spot indeed. The Creative Incubator Policy (Broedplaatsenbeleid), through which vacant buildings are redeveloped as temporary multi-tenant studio buildings for ‘creatives’, cultural entrepeneurs and start-ups, goes some way to alleviating the need for studio space, but in a way that reminds one of how a soufflé must continue to rise, since the slightest cooling-off will result in an instant collapse. While the number of ‘creative incubators’ continues to grow, their operating periods are increasingly limited so that an ever-increasing number is needed just to keep the total amount of available surface area up to par. And the shorter the cycle of finding, building, managing and closing down an incubator, the more energy and capital goes to waste.[3] Additionally, there are major concerns about the effects of recent national and European housing law (Woningwet 2015) for the stock of studio space and how housing associations – who own and manage the vast majority of studios and studio dwellings in the city – will interpret and apply these rules.
These concerns have been raised repeatedly and in different ways by the artist representative organisations Platform BK and the Kunstenbond, and by the municipality’s advisory body, the Amsterdamse Kunstraad.[4] Other groups and organisations regularly raise the alarm as well, such as the Fair City campaign platform, various tenants and residents’ associations, and the ‘creative incubator’ developer Urban Resort. And apparently with some success, for it is even starting to get through to the Amsterdam City Hall that a vibrant art and culture policy actually seems plain ludicrous when artists are fleeing the city for lack of a place to work and live. As for the proposed measures, meant to protect and where possible to create studio space, we must wonder whether, in the long term, they will not have a detrimental impact on the city and the artists’ place in it. In this article I wish to critically examine the ‘studio and creative incubator’ and studio policy of Amsterdam, focusing specifically on the following matters: the lack of clarity about the absolute minimum stock of affordable studio space, also referred to as the base stock (‘ijzeren voorraad’); the influence of the 2015 Housing Act (Woningwet 2015) and the role of housing associations in applying the law; the dangerous obsession with ‘housing mobility’; and the introduction of temporary contracts.
Base stock
In the past fifteen years, the media have reported with increasing frequency that studios in Amsterdam are disappearing because the owner – which is often a housing association – has substantially raised the rent or has chosen to convert the space into regular commercially rented space. To counter or at least slow down this trend, the notion of a ‘base stock’ of studios and studio dwellings that needs to be preserved has gained traction in recent years. This pertains to the large-scale studio complexes inherited from the squatters’ era, but also to the individual studios owned by housing associations and the municipality. Until Bureau Broedplaatsen conducted a survey in 2015 and 2016, no one actually knew how many studios and studio dwellings existed in Amsterdam, not even the municipality and housing associations. And still today, much remains unclear about the numbers being bandied around. The memorandum drawn up by Bureau Broedplaatsen, titled Herzien Amsterdams Atelier- en Broedplaatsenbeleid 2015-2018 (published in English as Revised Studio and Creative Incubator Policy for Amsterdam 2015-2018), mentions 1100 studios and 275 studio dwellings, owned by the municipality and the housing associations.[5] This makes a total of 1375 studios and studio dwellings. In the 2016 annual report, published in February 2017, the very same Bureau Broedplaatsen mentions an approximate total of 927 studios (while remaining unclear whether this includes studio dwellings).[6] The Amsterdamse Kunstraad applies figures somewhere in between the two counts by Bureau Broedplaatsen, referring to approximately 900 studios and “at least 275” studio dwellings, which makes a total of 1175.[7] The most recent figure mentioned is that the base stock consists of 750 studios. This would mean a drop of no less than 30 per cent compared to the 1100 studios mentioned in the creative incubator memorandum, as Peter van den Bunder of the Kunstenbond has calculated. I think this calls for an exclamation mark: thirty per cent! This drop is mainly attributable to the housing associations: whereas their studio stock was estimated to be 700 in the creative incubator memorandum, it is now thought to be 424 (-40%).[8]
Clearly, the numbers being quoted vary significantly, but even more worryingly, the sources agree that the numbers are dropping. The figures provided to Bureau Broedplaatsen by the housing associations also warrant some further scrutiny: the figure of 275 studio dwellings is inaccurate, for example, since the specifications per association state that De Key owns 12 studio dwellings,[9] while a single complex owned by De Key (the studio complex at Zomerdijkstraat in the Rivierenbuurt) comprises 30 studio dwellings. So if that figure is incorrect, then how about all the other figures that the housing associations provided to Bureau Broedplaatsen? Apparently, the associations refuse to make a list of addresses available, which makes it impossible to verify the figures. At the debate titled ‘Permanent atelierruimte gezocht’ (‘permanently seeking studio space’), organised by Platform BK and the Kunstenbond, someone quite rightly commented that the ‘base stock’ seems to be getting smaller all the time. “Each time again, another couple of studios appear to have been scrapped from the list”. It sums up the sentiment felt by rent-paying artists: the persistent lack of clarity works to their disadvantage, since you cannot monitor the situation without clarity, and studios continue to disappear without warning. If only the size and also the locations of the studio stock owned by the city and the associations were clear, it would make the debate on how to treat this stock more meaningful.
While I will continue to use the notion of ‘base stock’ in this article, I would like to add one critical comment. The term derives from business administration, where ‘base stock’ refers to the minimum amount of materials and resources required to keep a business or factory in operation. Analogously, the city of Amsterdam is thought to need a minimum amount of studio space to continue functioning properly as a city. Initially, this seems a clever and positive way to frame the issue, as it suggests that studios (and hence artists) are indispensable to a city. The flip side to this analogy, however, is that it implies an economic legitimation: a minimum stock of studios (and hence of artists) is required for the successful operation of Amsterdam Incorporated. This approach therefore actually reinforces the larger neoliberal frame, that the existence of art is justified only by its direct or indirect economic profitability. In my view, artists and activists in Amsterdam are too easily persuaded to adopt an economic narrative, while that narrative is in fact part of the problem and not of the solution.
Housing associations and the Housing Act
Another and more complex issue is at work in the background, namely that since 2015, housing associations have been required to differentiate more sharply between their social and commercial tasks. In typical ‘government-speak’, the social tasks are referred to as ‘Services of General Economic Interest’ (Diensten van Algemeen Economisch Belang, DAEB), while the commercial tasks are referred to as ‘Services Not of General Economic Interest’(Diensten van niet Algemeen Economisch Belang – somewhat oddly abbreviated as ‘not-DAEB’). With this differentiation, the Housing Act formalises a demand made by the then-European Commissioner for Competition, Neelie Kroes, in 2009. Under influence of the real estate investors’ lobby, she stated that if housing associations use public money to operate on the ‘free market’, then this amounts to unfair competition. Since then, housing associations are required to operate in the market as a full-fledged market partner. For that reason, it is formally prohibited to apply any degree of protection or a controlled rent system in the not-DAEB part of associations’ portfolios.
Though perhaps unintentionally, this law has had a drastic impact on the stock of studios in the Netherlands, for the simple reason that the vast majority of studios are owned by associations. The core social task of these associations is described as building, renting out and managing social rental dwellings to people with a low income. Additionally, however, the DEAB category is also assigned some scope to retain “societal property” and to perform “certain services to support quality of life”. As examples of “societal property”, reference is made to neighbourhood libraries, schools, community and youth centres. Could studios or studio dwellings also be designated as such? Some artists’ organisations have suggested, with some hope, that the answer is affirmative. But the then-alderman Kajsa Ollongren (D66) was unequivocal in her “no”. As she wrote in a letter to the Raadscommissie Jeugd en Cultuur in December 2016: “There is a definitive list in which the Ministry indicates what can and what cannot be considered daeb (sic). From this it is clear: studios are not-daeb.”[10] Another letter by Ollongren in October 2016 nevertheless holds out some hope: “The Ministry permits housing associations to own and manage these studios, (…) but they are free to determine their actions with respect to setting rent prices”.[11]
This corresponds to what a co-worker of the Ministry of the Interior and Kingdom Relations (which has now absorbed Housing and is headed by no one other than Minister Kajsa Ollongren) writes in an email, in response to an enquiry: housing associations are permitted to operate existing small-scale studios under DAEB regulations, but are not permitted to rent out any new properties as studios in the future.[12] The associations actually admit as much: in a meeting with the field, they stated that they can choose whether to designate their studios and studio dwellings as DAEB or as not-DAEB. They did have to submit their designation proposals to the housing associations authority (Autoriteit Woningcorporaties) by 1 January of 2017. A definitive decision has yet to be taken.
Why are the messages coming out of the municipality and out of Bureau Broedplaatsen so confusing? This way, not much will remain of the ‘base stock’, even before this stock has been properly surveyed. The issue moreover illustrates the ambiguity of the tasks assigned to the housing associations, with “societal” and “commercial” properties differentiated from each other on entirely arbitrary grounds. As the Amsterdamse Kunstraad notes, rather euphemistically, this rigid division raises questions, since the building and management of studios “concerns activities that are considered to be economic activities in the context of the internal market, but which may concern a public or societal task in the national context.”[13] At the same time, the consequences of applying this distinction remain in the dark. If the law is executed to the letter, housing associations are completely barred from renting out new studios for a ‘social’ rent price, which would mean that studios located in the urban regions are put entirely beyond the reach of artists. Yet the gist of the cryptic and sometimes internally contradictory official messages emerging from Amsterdam’s City Hall is that the ball is in the court of the housing associations. It is up to them to determine their policy on this point. This would mean that artists renting studio space – as well as urban authorities who wish to guarantee a minimum stock of studios – are at the mercy of the housing associations, who will make their choices based on their policy goals, their financial situation, and their goodwill towards artists. Some may decide to keep studios affordable, while others may choose to showcase their studios as hot commodities, with reference to the “statutory obligation to maximise profits”. Certainly in a city like Amsterdam, there’s a lot of money to be made from all that centrally located real estate, as it becomes available. Set a pot of honey on the table, and it takes a great deal of self-restraint to not take a scoop.
It is not my intention to single out De Key as a negative example here. Rochdale housing association is also known for having put new ‘regular’ tenants in studio dwellings, and there are similar stories about other associations. However, the examples regarding De Key illustrate the severity of the impact if even just one association decides to change course and to do away with its stock of ateliers, despite all previous agreements. It demonstrates the vulnerability of current studio policy. Besides, it gives reason to wonder how agreements – or covenants, or moratoriums, or gentlemen’s agreements – regarding the base stock can or will be observed, if the municipal authority apparently can only look on passively if an association decides to no longer play ball. It wouldn’t surprise me if the base stock agreements will in time turn out to be a case of ‘too little, too late’.
Housing mobility and temporariness
To conclude I wish to address one further worrying trend in urban studio policy, namely the introduction of the terms ‘housing mobility’ and ‘temporariness’. These have become magical words in housing policy in recent years, and now they are also applied to studios. As someone who frequently writes about housing policy, I know that these are not neutral words, but that they are used to legitimise disastrous and deeply anti-social legislation. The word ‘housing mobility’ is mainly used to lament the lack of such mobility. Social housing tenants remain where they are for too long, with growing waiting lists and a clogged-up housing system as a result; such is the diagnosis. Young people cannot get their foot on the property ladder. ‘Temporariness’ is now touted as a solution to this problem. Temporary contract forms with low levels of tenant protection – ‘disposable contracts’, one might say – should ensure that tenants do not stay put for too long and that everyone and everything passes through the system smoothly. This does not address the real problem, however, which is the horrendous shortage of affordable housing. Quite the contrary: social rental dwellings are being transferred to the commercial market en masse, thereby depleting the stock of social housing. In other words, ‘housing mobility’ is a policy euphemism for a game of musical chairs, in which everyone is encouraged to get up and keep moving on, while the number of chairs is steadily reduced.[16] Thou shalt keep moving!
We find the same strategy in Amsterdam’s studio policy. While suggesting that the immobile tenants are to blame, the number of affordable studios continues to dwindle, with increasingly less work space available as a result. The previously mentioned memorandum Herzien Amsterdams Atelier- en Broedplaatsenbeleid 2015-2018 (Revised Studio and Creative Incubator Policy for Amsterdam 2015-2018), prepared by Bureau Broedplaatsen, is an interesting example. From the first page of the Introduction, the emphasis is on the influx of young talented artists: creative newcomers, described as “budding artistic talents seeking space in Amsterdam to settle down”, or more concisely as “new accommodation seekers on a limited budget”. It is calculated that between 1000 and 1500 creative workers seek to settle in Amsterdam every year. Their “limited budget” needs to cover both affordable housing and affordable work space.[17] But the available options are scarce, and settled artists are not prepared to move on to another (and more expensive) studio. To increase the accessibility of the city – “and so to strengthen Amsterdam as an attractive base for talent and entrepreneurship” – requires, you guessed it: ‘housing mobility’. To this end, the municipal authority will start renting out studios on five-year contracts only, which can be renewed for another five years once only. Further, housing associations and creative incubators developers are called on to adopt “the revised policy with maximum rental terms of five plus five years”, based on a “shared awareness of urgency to give new accommodation-seeking creative workers more chance of finding a place”.[18]
There is nothing wrong with accommodating new arrivals, but the proposed approach is not exactly elegant; especially because it prioritises the status of newcomer over that of the settled tenant. To quote Claudia Zeller, who wrote a sharp analysis of the incubator memorandum for the project ‘De Frontlinie’: “the goal is never for artists to stay where they are”.[19] She says that in such policy documents, the recently graduated artist – the ‘young talent’ – is viewed as “a resource to help keep the city and economy churning”.[20] This is also illustrated by how the memorandum describes the tenants of the so-called ‘base stock’: at least they keep moving on. For the creative incubators, the throughput is between 5 and 15 per cent, and those moving on are largely the creative entrepreneurs. Artists dedicated to making autonomous art are more prone to stay put, which produces the low percentage of throughput in the base stock. To increase the mobility, tenants will be assessed for the extent to which they are still active artists. If not, they will need to vacate their space to make room for newly arriving ‘talents’. This rule also applies to studio dwellings, the memo goes on to say: “Under the current studio and incubator policy, the current tenants of studio dwellings, who currently have a rent contract for an indefinite period of time, will likewise be assessed to determine whether they still meet the requirements for a studio dwelling.” One complication is of course that the studio dwellings are often social rental dwellings as well. So does the memo really want to advocate shredding the rent contracts currently in place?
The discourse as carried on in the incubator memorandum creates an image – intentionally or not – of young talents clamouring at the gates to the city, while the once-were squatters, now artistically exhausted, continue to hang out at ease in ‘their’ affordable and attractively located studios. This image is not without antecedents. Already in 2002, the then-director of Stadgenoot, Gerald Anderiesen, described the Amsterdam artists as ‘too rooted in place’. “Take the debate about broedplaatsen (creative incubator): cheap places in the inner city where young talent can develop. I would say: rent these place out on a temporary basis. At a certain point you should have developed sufficiently to make it on your own. Then it’s time to pack up and go.”[21]
This is of course a highly contentious position. What happens after the five or ten years that you were able to rent a relatively affordable studio? Then you need to find your own space on the commercial market, say the politicians. And if the youth or campus contract that assured you of a relatively affordable dwelling also expires, then you’re facing a double whammy in terms of costs: for both a dwelling and a studio on the commercial market. How many artists are able to rent a dwelling and a studio before the age of thirty in Amsterdam, where rent prices continue to go through the roof? “But they had their chance, didn’t they?”, say the advocates of temporary contracts in return. This pseudo-meritocratic position – everyone starts with equal opportunities – seems to me a poorly camouflaged neo-Darwinist argument: whoever doesn’t make it did not make enough of the opportunities they had, and the city is simply not a place for losers. But since when can ‘success’ in the world of art be measured according to a neatly and steadily climbing income curve? Interestingly, this is also acknowledged in the incubator memorandum; though not in the main text, but in brief text boxes meant to add some colour to the document. Well-to-do artists are interviewed about what their workspace in an incubator has meant for their professional practice. Several artists say that they, despite their success, would never be able to afford a commercial rent price for a studio in the city. According to a photographer, the assurance of having a studio without the threat of sudden eviction made it possible for him “to work on long-term planning (…) for the first time”:
The big advantage is that it suddenly becomes possible to invest time and money in the space and that you no longer have to work out of removal boxes. I can now equip my studio according to my professional requirements. (…)In practice, success in the arts also means an enormous increase in costs. That is why my affordable studio (…), which was made possible by the creative-incubator policy, is worth so much to me. It lies at the very core of my artistic work.[22]
In my view, introducing temporary contracts and the emphasis put on housing mobility are evidence of how policy-makers in Amsterdam, both at the municipality and the housing associations, are mainly out to capitalize on the current attractiveness of the city for young newcomers. This is clear from the eagerness with which the associations – particularly De Key and Stadgenoot – have embraced short-term youth and campus contracts, but also from the determination with which the city pursues gentrification policies (with due consequences for housing prices), while tirelessly pumping energy into the hotspot soufflé at the same time. The guiding vision in studio policy seems to be – to paraphrase The Rules – that geezers have to go because geezers are simply in the way. Some of the artists renting from the associations who I spoke to last month confirm this: “The atmosphere now is that all those old-time squatters and artists are paying nickels and dimes for their splendid front-row seats. They are seen as conservative geezers that simply refuse to budge.” And you don’t need to be very old to qualify as a geezer nowadays: to quote another artist, “In fact [this policy] means that if you’re not well-to-do by the age of 32, then there’s no place for you in the city.”
A meaningful and successful studio policy should not just focus on people wanting to settle in the city, but also on those at risk of having to leave. Now that Amsterdam is booming, the city believes it possesses the secret formula for eternal youth; but one should not mistake an elixir for immortality for crass plastic surgery, that simply keeps cutting away all that tends to age.
—
[1] See City of Amsterdam, Kunstenplan 2017-2020, Amsterdam 2016. Download available at: https://www.amsterdam.nl/kunst-cultuur/kunstencultuurbeleid/kunstenplan/
[2] The average commercial rental price for dwellings in Amsterdam is 22.28 euro per square metre, according to housing site Parasius. See: Tom Damen, ‘Huurprijzen in vrije sector stabiliseren’, Het Parool, www.parool.nl, 3 August 2017.
[3] See Bureau Broedplaatsen/Gemeente Amsterdam, Herzien Amsterdams Atelier- en Broedplaatsenbeleid 2015-2018, Amsterdam 2016, p. 6. See also the Grafiek ontwikkeling broedplaatsmetrage in Bureau Broedplaatsen/ Gemeente Amsterdam, Jaarrapportage 2016: Bureau Broedplaatsen, Amsterdam 2017, p.6. You can download the English version here: https://stipo.nl/app/uploads/2017/05/2016-herzien-broedplaatsenbeleid-ENGELS.pdf. I will refer to the Dutch version of the document.
[4] An example is the Manifest behoud betaalbare ateliers in Amsterdam by the Kunstenbond, Platform BK, Loods 6 and others of October 2016.
[5] Bureau Broedplaatsen/ Gemeente Amsterdam, Herzien Amsterdams Atelier- en Broedplaatsenbeleid 2015-2018, City of Amsterdam, 2016, p. 14.
[6] Bureau Broedplaatsen/ Gemeente Amsterdam, Jaarrapportage 2016: Bureau Broedplaatsen, Amsterdam 2017.
[7] Amsterdamse Kunstraad, Briefadvies over het behoud van ateliers en atelierwoningen, December 2016, see: https://www.kunstraad.nl/advies/ijzeren-voorraad/.
[8] Peter van den Bunder, reported during the committee meeting of Jeugd en Cultuur, 5 October 2017.
[9] See: Kajsa Ollongren, Laatste stand van zaken over inventarisatie ijzeren voorraad ateliers + atelierwoningen, Letter by the Raadscommissie Jeugd en Cultuur, 24 October 2016.
[10] Kajsa Ollongren, Advies Kunstraad ‘Behoud IJzeren Voorraad’, Letter to the Raadscommissie Jeugd en Cultuur, 15 December 2016.
[11] Kajsa Ollongren, Laatste stand van zaken over inventarisatie ijzeren voorraad ateliers + atelierwoningen, Letter to the Raadscommissie Jeugd en Cultuur, 24 October 2016.
[12] This email was sent to the Ministry of the Interior and Kingdom Relations by a stakeholder in this discussion, and was shown to the author.
[13] Amsterdamse Kunstraad, Briefadvies over het behoud van ateliers en atelierwoningen, December 2016, see: https://www.kunstraad.nl/advies/ijzeren-voorraad/.
[14] Maxime Smit, ‘De Key verhoogt huur ateliers: ‘Ik kan nu de bijstand in’’, Het Parool, 4 September 2016, https://www.parool.nl/amsterdam/de-key-verhoogt-huur-ateliers-ik-kan-nu-de-bijstand-in~a4369554/.
[15] See: https://www.wonenindekeizer.nl/. For the prices per square metre, see also: Henk Willem Smits, ‘Erik de Vlieger over verkoop Tabakspanden (€7.500 per m2): Amsterdam is verziekt’, Quote, 6 September 2016, http://www.quotenet.nl/Nieuws/Erik-de-Vlieger-over-verkoop-Tabakspanden-7.500-per-m2-Amsterdam-is-verziekt-184205.
[16] I owe this metaphor to the Bond Precaire Woonvormen. At the tenants’ day on 17 June as part of the Flexspektakel Utrecht, the image of musical chairs was used to illustrate the effect of the current housing policy.
[17] These figures are based on a survey conducted by Bureau Broedplaatsen in 2013 in collaboration with the department of Onderzoek, Informatie en Statistiek. In 2012 in Metropolis M, Jolien Verlaek says that in that year, more than 1500 Bachelor students will graduate from art academies in the Netherlands in the fields of Autonomous Visual Arts and Design. Jolien Verlaek, ‘De Club van 1500: Eindexamen 2012 in cijfers’, Metropolis M, 12 July 2012, http://www.metropolism.com/nl/features/22936_de_club_van_1500.
[18] Bureau Broedplaatsen/City of Amsterdam, Herzien Amsterdams Atelier- en Broedplaatsenbeleid 2015-2018, City of Amsterdam, 2016, p. 11. Quotes are taken from the Dutch version of the memorandum except when stated otherwise.
[19] See: Claudia Zeller, ‘Hand op de knip: Over de economisering van het Nederlandse kunst- en cultuurbeleid’, in: Roel Griffioen (eds.), De Frontlinie: Bestaansonzekerheid en gentrificatie in de Creatieve Stad, Amsterdam 2017, p. 151.
[20] Ibid, p. 153.
[21] Cited in: Roel Griffioen, Abel Heijkamp, ‘Woonnomadisme’, in Roel Griffioen (eds.), De Frontlinie: Bestaansonzekerheid en gentrificatie in de Creatieve Stad, Amsterdam 2017, p. 49. Original quotation: Fred van der Molen, ‘“Je moet je voortdurend instellen op een veranderende markt”, Interview: Gerard Anderiesen, van wetenschapper tot directeur’, NUL20, 1 (March 2002) 1. Anderiesen was director at Stadgenoot until 1 October 2016.
[22] See text box ‘Lard Buurman – fotograaf’, in: Bureau Broedplaatsen/Gemeente Amsterdam, Herzien Amsterdams Atelier- en Broedplaatsenbeleid 2015-2018, City of Amsterdam, 2016, p. 9. Here I’m citing from the English version of the memorandum, Revised Studio and Creative Incubator Policy 2015-2018, available for download here: https://stipo.nl/app/uploads/2017/05/2016-herzien-broedplaatsenbeleid-ENGELS.pdf.