"The need for such a massive volume of data collection in this area is not supported by reliable data...the systems could cast an 'unpleasant shadow' on the EU in its treatment of third countries nationals,
“The need for such a massive volume of data collection in this area is not supported by reliable data…the systems could cast an ‘unpleasant shadow’ on the EU in its treatment of third countries nationals, in particular those in need of international protection, in the light of EU and ECHR legal requirements.” Moreover, “even if it is established that an EES would be necessary for the purpose of preventing and detecting overstay, this would not be a justification to grant law-enforcement access as well.”
See: Full letter (pdf)