20 81. Secondly, the MFHR complains that the affected groups have been refused access to environmental data and other information, which has prevented them from exercising their right to challenge decisions. It again refers to the 2004 request by the Megalopolis citizens' movement to the Arkadia prefecture (see above, §31) for an investigation into access to information on limit values and pollution levels in the region and the lack of any administrative response. 82. Similarly and thirdly, the MFHR argues that the health assessment made by the state into the impact of lignite mining was confined to two epidemiological studies (see below, §86), which were based exclusively on data compiled by Government departments and did not allow those concerned to participate. 83. Fourthly, it maintains that there was no attempt to communicate with persons living in the lignite mining regions and offer them public health information. It states that it considers that the figures quoted by the Government – 103 health and environmental education courses organised in 150 primary and secondary schools in the Kozani prefecture – themselves reveal the shortfall in this area. 84. It also alleges that nothing has been done to inform the affected groups of what they can do to deal with health risks in normal circumstances and when incidents occur, for example when certain thresholds are reached. 85. According to the MFHR, the State has failed to “prevent as far as possible epidemic, endemic and other diseases”, in contravention of Article 11§3 of the Charter. 86. It argues firstly that the state has failed to conduct regular, population-wide health assessments of the effects of air pollution on health, and argues that 45 years after the start of DEH activities in the Kozani-Ptolemaida area, only two epidemiological studies of the population have been carried out. As a result, according to the MFHR, the state does not systematically collect or analyse data on mortality or morbidity in the regions concerned and thus lacks significant information that would allow it to assess the health situation and respond appropriately. For example, while recognising the need for it, the state has not sponsored any research into the impact of lignite mining on the prevalence of cancer. 87. Secondly, the MFHR argues that the state's failure to regularly monitor environmental conditions and assess the state of health of the population, or to provide for the participation and representation of those concerned, signifies that it has no long-term strategy for managing the public health effects of high levels of air pollution and has no policies for responding rapidly and effectively to threats to the environment when air pollution exceeds the limit values. B – The Government 88. The Government states that, as required by Articles 11§§2 and 3, it has a long-term strategy for managing the public health effects of air pollution, and that its policy is to foster a public health culture among its citizens in accordance with WHO objectives, as set out in the Ottawa and Alma-Ata declarations.