should be considered as “at present receiving from organs or agencies other than [UNHCR] protection and assistance” within the meaning of paragraph 1 of Article 1D, and hence is excluded from the benefits of the 1951 Convention. (8): If, however, the person is outside UNRWA’s area of operations, he or she is not “at present receiving from organs or agencies other than [UNHCR] protection and assistance” within the meaning of paragraph 1 of Article 1D, and therefore “such protection or assistance has ceased” within the meaning of paragraph 2 of Article 1D. The person is “ipso facto entitled to the benefits of the [1951] Convention,” providing of course that Article 1C, 1E and 1F of the 1951 Convention do not apply. This would be the case even if the person has never resided inside UNRWA’s area of operations. Such a purely geographical understanding is made even clearer in 2009 UNHCR Statement, which asserted that: [I]n moving from inside to outside the UNRWA area of operations and then back again, the person concerned moves back and forth between paragraphs 1 and 2 of Article 1D.285 Nevertheless, the 2013 UNHCR Note presented an interpretation whose phrasing focuses on the cessation of UNRWA’s activities. Notably, the Note asserts that: the phrase ‘ceased for any reason’ in the second paragraph of Article 1D of the 1951 Convention […] include[s] the following: (i) the termination of UNRWA as an agency; (ii) the discontinuation of UNRWA’s activities; or (iii) any objective reason outside the control of the person concerned such that the person is unable to (re-)avail themselves of the protection or assistance of UNRWA.286 Even though the 2013 UNHCR Note also mentions the impossibility of returning to URNWA’s area of operations as a scenario in which the person concerned falls under the inclusion clause of Article 1D,287 it does not follow, as one might infer, that the opposite, i.e., residing inside UNRWA’s area of operations equates, in itself, to falling under the exclusion clause: even those residing in that area are still potentially subject to “(i) the termination of UNRWA as an agency” and“(ii) the discontinuation of UNRWA’s activities.” Therefore, by focusing on UNRWA activities instead of its area of operations, UNHCR changes its previous interpretation of Article 1D, which gave rise to a purely geographical understanding of how the first and second paragraphs operate. It should be noted that the 2013 Note’s focus on the cessation of URNWA’s activities, rather than on the geographical location of a Palestinian refugee, is in accordance with its emphasis on the applicability of Article 1D also to those 285 UNHCR, “2009 Revised Statement,” 8. This concept is also included in UNHCR, “2002 Note,” para. 8. 286 UNHCR, “2013 Note,” 4. 287 Ibid., 5. The 1951 Refugee Convention and Article 1D 55