80 Brad K. Blitz more than 200,000 refugees, including generations of Palestinians, records having just five stateless people.45 Redefining Statelessness and Developing Data With refugee numbers falling, UNHCR commissioned many studies on statelessness in which it prioritized de jure statelessness over other statuses: In practice, it may sometimes be difficult to distinguish between de jure and de facto statelessness. Because of these complexities, UNHCR would also recommend that censuses ordinarily be restricted to gathering information only about de jure stateless populations, and populations with undetermined nationality.46 In addition to the methodological challenges noted here, Massey’s historical interpretation of the diplomatic discussions during the drafting of the 1954 Statelessness Convention led him to argue for a narrow definition that focused on de jure statelessness.47 Massey calls attention to the Final Act of the 1951 Conference of Plenipotentiaries on the Status of Stateless Persons, which recommended limiting the scope of protection to only those “who have renounced that protection and whose reasons for doing so are considered valid by the foreign State.”48 Thus, the matter turns on state recognition of the individual’s statelessness status. Massey then suggests that many of the areas one might consider to fall under the banner of de facto statelessness might be better covered under the Refugee Convention.49 Furthermore, he notes that, as with refugee matters, the presumption is on the individual to demonstrate that they no longer have protection from their country of origin: As a rule, there should have been a request for, and a refusal of, protection before it can be established that a given nationality is ineffective. For example, Country A may make a finding that a particular individual is a national of Country B, and may seek to return that individual to Country B. Whether or not the individual is de facto stateless may depend on whether or not Country B is willing to cooperate in the process of identifying the individual’s nationality and/or to permit his or her return.50 Based in part on Massey’s paper, UNHCR developed a handbook to “advise on the modalities of creating statelessness determination procedures, including questions of evidence that arise in such mechanisms.”51 The handbook limited the recognition 45 Ibid. Economic Commission for Europe, Difficult to Measure Census Topics, pp. 2–3. 47 UNHCR, UNHCR and De Facto Statelessness, p. 27. 48 Ibid., p. 18. 49 Ibid., p. 30. 50 Ibid., p. 74. 51 UNHCR, Handbook on Protection of Stateless Persons (2014), www.refworld.org/pdfid/53b67 6aa4.pdf, p. 6. 46 https://doi.org/10.1017/9781108914994 Published online by Cambridge University Press