Read Part 1: Fulfilling the mission.

The OIG faced a series of challenges beginning in 2015. While the Office remained highly productive and continued to release credible and well-respected reports, the cumulative effect of these challenges diverted attention from the OIG’s important role as government watchdog and diminished the Office’s support in some segments of the community. 

Cyber Threat

Information technology presents significant potential risks for Offices of Inspectors General. In order to fulfill its mission, the OIG acquires sensitive information ranging from personal data to grand jury testimony, and it must guarantee confidentiality to informants. In 2015 millions of attempts to breach the OIG’s IT security, primarily from internet service providers in Asia and Eastern Europe, bombarded the OIG’s system and presented the OIG with a significant and stressful problem. Hackers sought personal identification data useful in frauds, and the OIG had personnel data for all city employees. The attempted hack resulted in a minor penetration of the OIG site but the hackers were unsuccessful: No data were lost.

However, a qualitatively different attack occurred by a separate, single attacker.¹ This probe caused significant inconvenience to OIG staff and the smooth functioning of the Office. The OIG website shut down temporarily and visitors were redirected to a spoof of the OIG website in order to disguise the probe and make both users and the site’s attacker think the real OIG website was working. We were fortunate to have internal gateways to our case and report management systems and were successful in protecting them from penetration.

Audio: The Lens interview with Ed Quatrevaux

The OIG hired a nationally recognized IT forensic expert to assist with the transition to a safe environment. This effort required contracting with a new web platform host, migrating to a dot gov domain, and hiring an OIG IT security expert. Security is expensive, but it is also necessary. Serendipitously, an increase in the city’s General Fund that year enabled us to pay for the services and technology upgrades.² Without the additional revenue that year, it would have been impossible to make the necessary changes quickly and respond as effectively to the threat.

The Office’s transition to all new technology hardware and systems was lengthy and disruptive. Staff could not access external websites for several weeks for security reasons, preventing them from doing required research. Then they were permitted only to access secure https websites for an additional period of time. The Office had also been on the verge of launching an eagerly anticipated, redesigned website, and the shutdown of the old website and the newly imposed eleventh-hour security requirements complicated and delayed the new website’s launch.³ The office-wide hardware transition proved complex and lengthy, taking months rather than the few weeks initially anticipated. For a short period, staff could not even send external e-mails; for a longer period all incoming e-mails had to be scanned for malicious content. 

In the end, the Office emerged with greatly enhanced technology and security systems, but the experience was both stressful and frustrating for OIG employees trying to be productive. The rules about allowed and forbidden web and e-mail behaviors constantly changed as new information about the breach emerged, and staff had difficulty determining what was permissible and what was not. Third-party apps were forbidden, frustrating attempts to implement the Office’s developing communications strategy. OIG investigators also interviewed staff members to determine the original sources of the security breach, fomenting anxiety and insecurity throughout the Office. The experience left Office staff with a sense of vulnerability to outside threats and misgivings about internal operations that had not been present before.

An Office Divided

Other challenges also began to emerge in 2015, but these challenges stemmed from structural ambiguities and problems baked into the OIG’s establishing legislation. The first was placing the Independent Police Monitor as a Division in the OIG; the second was endowing an external entity, the Ethics Review Board (ERB), with the potential to exert influence over the Office, thereby unintentionally impairing the IG’s, and thereby the Office’s, independence. 

The 2008 OIG ordinance created “within the Office of Inspector General an Independent Police Monitoring Division, headed by an Independent Police Monitor.”⁴ The IG appointed the Independent Police Monitor and the Division’s staff and controlled the Division’s budget. When the Office went to the City Council in 2012 to ensure that the Independent Police Monitor Division had access to confidential NOPD records, revisions to the ordinance reiterated that the Independent Police Monitor Division was part of the OIG.⁵

At the same time, the 2008 ordinance retained most of the language from the original ordinance intended to establish a separate Office of the Independent Police Monitor. Unlike the other OIG Divisions, it specified staff positions to assist the Independent Police Monitor (IPM) and enumerated numerous divisional duties and powers specific to the police monitor division. The IG also chose the IPM from three finalists selected by an external search committee following a nationwide search; the IG could appoint the Office’s other division heads at will.⁶

Most important, the IG could not dismiss the IPM without the approval of the Ethics Review Board: “The independent monitor shall only be removed based on the recommendation of the inspector general and approved by a majority vote of the ethics review board.”⁷

In sum, the ordinance encouraged a belief that the independent police monitor division was exceptional and created an expectation that it would be treated differently from the Office’s other divisions. Differences in mission, norms for work products, and operational standards appeared almost immediately, resulting in growing tensions. Although some duties overlapped, key differences in their legislatively defined roles increasingly undermined trust between the OIG and the independent police monitor division. 

The most significant and irreconcilable difference lay in the divergent missions of the two entities. Both its origins and its legislatively stated duties and responsibilities encouraged the independent police monitor staff to play an advocacy role and to build community support for its efforts. Toward that end, the independent police monitor division’s legislation required a director of community relations, and the division successfully built a strong citizen constituency. 

In contrast, OIG standards required objectivity, independence, and strict reporting standards for evidence-based and impartial “opinions, conclusions, judgments, and recommendations.”⁸ An OIG must build public support by producing meticulous and trustworthy reports that demonstrate its unrelenting efforts to make the city more honest, accountable, and efficient for all the city’s citizens.

It is possible that tensions arising from differences in mission, philosophy, and approach might have been resolved internally as a personnel issue. But the disagreement became public, and, in public discourse, independence for the police monitor equaled independence from OIG work product review. Escalating rhetoric turned the narrative into a David and Goliath story further inflamed by racial politics.⁹ In October 2015 the Police Monitor and the Inspector General signed an agreement to separate the OIG and police monitoring functions, bringing an end to almost two years of intensifying intra-office frustrations.¹⁰

It is not possible to manage personnel unless a manager has supervisory autonomy, without which he or she is set up for failure. Not only does the structure make it impossible to manage the individual, it undermines a supervisor’s authority over the office as a whole. The experience also made very clear just how difficult it is to counter a well-established, compelling narrative backed by a fervent citizen constituency unless the foundation of a strong competing narrative has been laid early on. 

High productivity and a strong track record are not enough. Even the most cost-effective office of inspector general in history could not halt a steady drumbeat of public criticism reinforced by a prevalent social narrative of perceived oppression and injustice. Any alternate message would be adjusted to fit the already established narrative; sometimes facts are not enough.

For an IG, there is a real tension between maintaining independence and integrity, necessary for being seen as a credible arbiter, and wading into the messiness and unpredictability of the media and public discourse. IGs walk a tightrope between an environment defined by standards and protocols, and the public realm where the value of the OIG is judged. My approach as an IG had previously been rooted in the belief that IGs should remain above the fray, that our standard of independence required it. That approach proved to have critical limitations. In an environment with no history or culture of inspector general oversight, developing an effective communications strategy was not a luxury: It proved to be essential. The OIG needed to craft an intentional message with a compelling story of its own, consistently monitor news about the Office, and find additional methods of communicating the content of its work to the public effectively and accurately. 

Toward that end, both I and my staff dramatically increased the number of meetings with civic and neighborhood groups. The OIG redesigned its website to make it information-rich and easy to navigate, and produced web chats and YouTube videos. The videos not only communicated report content effectively, they provided video content that television news programs could use when reporting OIG work. Staff developed their data visualization skills, making work products’ stories readily accessible through diagrams and pictures designed in house, graphs that made data easily comprehensible, and photographs. The Office also began producing an attractive one-page “In Brief” for each publicly released report that summarized the purpose of the report, what the OIG found, and what it recommended. 

In addition, the Office’s professional media consultant increased the number of Twitter and Facebook postings and added visual images and videos to enhance their appeal and encourage more clicks.¹¹ A video monitoring service captured clips of all OIG television coverage and transmitted them to the media consultant in real time. The consultant reviewed them for content accuracy upon receipt and immediately notified broadcasters of any errors in time to correct misinformation before the next news broadcast. During the challenges the Office faced, the media consultant provided crucial expert advice on developing communications strategy and messaging.

We wanted to know if our efforts to convey the OIG’s message were effective, and results of a poll written and orchestrated by a professional political analyst were promising:  67.3 percent of respondents told pollsters that they were aware of a report or investigation the OIG had completed in the past year. When asked if they were aware of how to report fraud, waste, or corruption in city government, 62 percent of respondents agreed or strongly agreed. Finally, almost 60 percent of people polled affirmed the Inspector General’s independence from city government.¹²

OIG under attack

However, the more effectively the Office communicated its work, the more the OIG became a threat to individuals benefiting from the status quo. The Office began to experience increasing push-back as it expanded its inquiries into one particular agency.

The OIG began examining Sewerage and Water Board (SWB) financial controls and billing processes in mid-2013, and a series of six SWB reports and public letters began rolling out in mid-2015.¹³ Audits revealed millions of dollars in waste, an appalling lack of internal controls, almost half of SWB accounts receivable delinquent, and virtually no enforcement or consequences for customers delinquent in paying SWB bills. Results of an OIG investigation of SWB take-home vehicle usage and policies exposed a total disregard of existing SWB policies intended to reduce waste. SWB managers responded by simply abolishing the rules for take-home vehicles instead of enforcing them.

In December 2015 an Inspector General public letter expressed concern that the SWB may have violated the Louisiana Constitution by reimbursing employee purchases for a fundraising event unrelated to the SWB and making annual financial employee recognition awards.¹⁴ Another public letter from the Inspector General to the City Council in August 2016 recommended that the Council defer action on a proposal to raise the annual limit on SWB employee overtime from 415 to 750 hours per employee, arguing that the SWB should fix its deficient payroll practices first.¹⁵

At the ERB September 2016 meeting, I informed the Board that the OIG would continue its focus on the SWB and had three projects underway, one of which was an inspection of SWB water quality testing practices and protocols.

One month later the ERB without explanation voted to use funds from that year’s budget to do a national search for an IG. Coming a year ahead of the end of my term, the vote undermined my authority as IG, enabling internal opportunists to sow the seeds of dissent, weakening the Office. But I was most concerned that the action meant the end of an Office that had identified widespread corruption and fostered improved performance in many areas of city government.

The timeline of events suggests that the OIG’s focus on the SWB may have prompted the Board’s decision to conduct a national search for an IG.

In August of 2016, the ERB voted in a new Chair.¹⁶ Unknown to me at the time, the new ERB Chair had not disclosed a potential financial conflict of interest on his annual personal financial disclosure statement required by law. As a signer of a 2015 contract for legal services with the SWB, both he and his firm gained financially from the agreement, arguably the very definition of conflict of interest.¹⁷

In December 2016 the OIG held a press conference to announce the results of a second SWB investigation, in which investigators uncovered theft by SWB employees of more than $500,000 worth of brass fittings used for residential water meters. The findings received extensive local media coverage.¹⁸ And in July 2017 the OIG released “Lead Exposure and Infrastructure Reconstruction.”  The report presented convincing scientific evidence that the SWB potentially exposed residents to high levels of lead when it disturbed lead service lines during the course of infrastructure reconstruction throughout the City.¹⁹

At the meeting following the release of the “Lead Exposure” report, the new ERB Chair vigorously challenged OIG findings. The challenge was both a first in the OIG’s history and surprising because the OIG ordinance gives the ERB no supervisory authority over the OIG’s work products.²⁰ The Chair questioned the scientific consensus upon which the report’s findings were based, dismissing the science as “hypotheticals.”  His attack on the report’s findings was what one might expect from an attorney representing his client, but it was not what one should expect from the Chair of an Ethics Review Board responsible for ensuring trustworthy oversight of city government.²¹

The Chair was not the only member of the ERB with an undisclosed potential financial conflict of interest. A second member of the Board was Executive Director of an agency that received approximately $1 million in annual funding from the City’s General Fund.²²

Even the appearance of impropriety undermines the ERB’s credibility, and a member’s conflict of interest potentially threatens the integrity and independence of the OIG. I later informed ERB members of the dangers posed by ERB financial conflicts of interest. Despite the evidence provided, the chair and ERB general counsel dismissed my concern, and no action was taken.

More than the money

How does one measure the achievements of an office of inspector general?  Financial measures of success tell a part of the story. For example, 2019 will be the eighth consecutive year the airport will reap savings because it eliminated corrupt month-to-month contracts and fraudulent practices, and the presence of the on-site OIG fraud team at the airport ensures that it continues to benefit from these actions: at this writing, estimated savings now approach $40 million. The City also earned $12 million in revenue when it held its first-ever on-line sale of adjudicated properties in 2015. The sale occurred after an OIG report faulted the City for not selling its sizable backlog of properties; the Mayor lauded the sale as “a resounding success.”²³

But not all OIG activities result in direct monetary value. For example, what is the value to rape victims to know their reports will be investigated rather than filed?  Or when more NOPD officers are responding to calls for service instead of performing duties that do not require sworn officers? Or for alerting the City and its citizens to the dearth of pedestrian crossing signals in a city with one of the highest pedestrian death rates in the country?  Sometimes the social benefits of good government are worth more than money.

By any measure, between 2009 and 2017 the OIG was a highly productive and valuable Office, energetically carrying out its mission to prevent and deter fraud, waste, and abuse, and to promote efficient and effective city government. Yet the citizen board responsible for selecting its leader disrupted a high-performing Office and dismissed evidence of potential financial conflict of interest on the part of its Chair.²⁴

In the end, passing a law with the potential to change the power structures in New Orleans was a remarkable achievement. However, unlike the federal system in which IGs are appointed for unspecified terms, the local ordinance set a four-year term for the Inspector General. It was a fatal flaw. The President or the head of a federal agency may remove a federal IG for cause, but they must communicate their reasons for doing so to both houses of Congress thirty days prior to the IG’s removal. And Congress has used its powers in the past to protect IGs from retaliation for their work. The removal of a federal IG is a serious matter: It has happened only once.²⁵

The New Orleans ordinance’s term limit injects a recurring and too-frequent fulcrum of influence over the IG and the Office’s work. It gives elected officials or their proxies the ability to pressure or remove an IG without concern about resistance from a countervailing power. Compounding the problem, inherent conflicts are also built into the selection of ERB members. The Mayor selects each ERB member from three candidates nominated by each of the six local college presidents, and the Mayor appoints one ERB member solely of his choosing. The process relies on the expectation that college presidents, who nominate candidates, are more ethical than the rest of us and that their nominations could not be manipulated. Neither assumption is credible. Moreover, the Mayor has an inherent motive for using his appointments to reduce the IG’s power since departments and agencies in the executive branch of city government fall squarely under OIG purview.

Efficient and effective government free of corruption is not the natural state, but experience shows that governments can approach that vision by creating and working cooperatively with an independent and high-performing Office of Inspector General. However, deficiencies in the New Orleans OIG’s establishing legislation created a flawed structure that compromised the independence of the Office and its ability to perform its mission. The City should take advantage of the lessons learned to make legislative changes that eliminate the deficiencies outlined above. New Orleans need not wait for the inevitable next disaster to compel the changes needed to support lasting government reform.

Ed Quatrevaux served as the New Orleans Inspector General from 2009-2017.

The opinion section is a community forum. Views expressed are not necessarily those of The Lens or its staff. To propose an idea for a column, contact Lens Founder Karen Gadbois.

Footnotes

1. At additional expense, the Office hired the security expert to trace the source of the probe. According to the Assistant IG for Investigations, the expert pinpointed the computer and its location.
2. The OIG receives a fixed percentage of the City’s General Fund.
3. The redesigned OIG website came on line initially as a secure “https” address and remained secure during my tenure.  However, the site was prefaced by the unsecure “http” as of the writing of this article.
4. New Orleans Municipal Code of Ordinances, Art. XIII, Sec. 2-1120 and Sec 2-1121, amended July 12, 2012.
5. The independent police monitor would not be able to exercise its intended police oversight authority without access to confidential police records. The amended OIG ordinance stipulated that “all records of the independent police monitor division of the office of inspector general shall be exempt from public disclosure and shall be considered confidential … .” New Orleans Municipal Code of Ordinances, Art. XIII, Sec. 2-1121(21). The revision referred to the “independent police monitor division of the office of inspector general” three times in one paragraph, and further stated that the independent police monitor division was subject to review and disciplinary action by the IG if it disclosed information without authorization. Concerns that confidential NOPD records given to the IPM might be subject to the public records law prompted the OIG to request the revision.
6. New Orleans Municipal Code of Ordinances, Art. XIII, Sec. 2-1121(1) and (3) through (16), amended July 12, 2012. For example, individual paragraphs list a director of community relations as a named staff member, instructed the independent police monitor to receive complaints from civilians who allege misconduct by the NOPD, and required the independent police monitoring division to hold quarterly community meetings in the five city council districts.
7. New Orleans Municipal Code of Ordinances, M.C.S. Ord. No. 23146 § 1, June 5, 2008. The Inspector General has complete autonomy when selecting Assistant Inspectors General overseeing the Office’s other divisions.
8. New Orleans Municipal Code of Ordinances, Art. XIII, Sec. 2-1121(1) and (20), amended July 12, 2012. The OIG’s establishing legislation stipulated that it conform to Association of Inspectors General Green Book standards, which include requirements for office organization, staff, work products, and individual divisions. “Principles and Standards for Offices of Inspectors General,” Association of Inspectors General, Rev. May 2014.
9. Ken Daley, “Embattled New Orleans Police Monitor:  ‘This department has suffered from cover-ups and secrets too long,” Nola.com/The Times-Picayune, October 1, 2015. Ultimately, the two entities separated, a move that required voters to amend the Home Rule Charter of the City of New Orleans. The Bureau of Governmental Research, a private, nonprofit research organization in New Orleans, suggested that amending the “charter ordinarily is not a mechanism for resolving disputes of the origin and nature at issue here.”  Further, it noted that one alternative would be to “align hiring and firing authority within the OIG.” See: “BGR In Brief: New Orleans Police Monitor Charter Amendment: On the Ballot, New Orleans, November 8, 2016,” October 12, 2016; and “BGR Report: New Orleans Police Monitor Charter Amendment.” Ordinance revisions and a City Charter amendment subsequently codified the separation.
10. Jonathan Bullington, “New Orleans inspector general, police monitor agree to split offices,” Nola.com-The Times Picayune, October 14, 2015. On October 14, 2015 the Inspector General and the Police Monitor agreed to separate the two offices and support the proposed charter change that guaranteed .16 percent of the City of New Orleans general fund budget to the Office of the Independent Police Monitor; the Office of Inspector General and the Ethics Review Board would share .59 percent of the general fund budget. Home Rule Charter of the City of New Orleans, Sec. 9-404, accessed March 9, 2017.
11. The Office was fortunate to receive a grant from a local, private foundation, which initially funded the media consultant, the production of several report videos, and the media monitoring service. It also funded the website redesign. The amount and quality of the consultant’s contribution proved invaluable, and the role of the consultant expanded. Recognizing the Office’s need for a communications professional long-term, the Office subsequently conducted a competitive procurement to engage a communications director funded by the OIG.
12. The poll was part of a public information campaign made possible by additional funding from the private foundation. The campaign included the production of a public service announcement that informed the public about the OIG and its mission, a media buy that paid for the airing of the PSA on local TV stations, and a poster campaign that placed posters with OIG messaging at bus shelters around the City. The Office hoped to conduct a follow-up poll to determine if the public information campaign was effective but future events derailed that effort.
13. Established by the Louisiana State Constitution, the Sewerage and Water Board (SWB) is responsible for providing and maintaining the City’s water, sewerage, and drainage systems. See: “Our History,” Sewerage and Water Board New Orleans, accessed July 19, 2019.
14. Auditors also found that the SWB reimbursed expenses without documentation, including a $2,000 advance for purchases that were never verified. Inspector General Ed Quatrevaux, letter to New Orleans Sewerage and Water Board, December 9, 2015.
15. http://www.nolaoig.gov/reports/all-reports/public-letter-to-new-orleans-city-council-re-proposed-ordinances
16. The new Chair, Allen C. Miller, joined the ERB for the first time at its July 2013 meeting, two months after the ERB voted to reappoint me for a second term and “lauded the efforts of Mr. Quatrevaux since his tenure began.” See “Minutes,” New Orleans Ethics Review Board, May 20, 2013, and “Minutes,” New Orleans Ethics Review Board, July 29, 2013. For Mr. Miller’s election as Chair of the ERB, see “Minutes,” New Orleans Ethics Review Board, August 17, 2016.
17. “Professional Services Agreement Between Sewerage and Water Board and Phelps Dunbar,” June 11, 2015, and invoices for “Legal Consulting Services” rendered April 2015 through October 2017. The new ERB chair, a partner of the law firm, signed the Agreement and the invoice cover letters to the SWB, and consistently billed hours on invoices submitted to the SWB. Search Allen C. Miller (ERB Chair), at “Disclosure Portal,” Louisiana Ethics Administration Program, accessed June 20, 2019. On the eve of the ERB’s selection of a new IG after my retirement, I sent a letter to the Board notifying it of the Chair’s conflict. Letter from former Inspector General Ed Quatrevaux to New Orleans Ethics Review Board, December 15, 2017. The Chair’s personal financial disclosure form for 2018 also indicated that his wife was Vice President of Programs at Youth Force NOLA, which received more than a $1 million in city funding for 2017─2020. “City of New Orleans, YouthForce NOLA Enter Into $1.1M Cooperative Endeavor Agreement to Place Nearly 1K Students in Paid Internships through 2020,” City of New Orleans Press Release, December 18, 2017.
18. At an ERB meeting following the press conference announcing the results of the investigation, the ERB Chair questioned the OIG about whether, in addition to SWB staff, investigators had also investigated the scrap yards at which the brass had been sold, but the OIG does not have jurisdiction over private companies. “Minutes,” New Orleans Ethics Review Board, December 21, 2016. For more information about the news conference, see: “New Orleans Office of Inspector General and the Sewerage and Water Board of New Orleans Announce Theft Investigation Results and Enhanced Security Measures,” New Orleans Office of Inspector General; and “Live News Coverage: OIG/S&WB News Conference,” Video Production of the Office of Inspector General, December 14, 2016.
19. Lead service lines supply water from the water main in the street to properties. The SWB did not know how many lead service lines were in use in the City or where they were located. Moreover, residents and business owners were not told whether lead service lines were found at their locations. When replacing water mains, the SWB removed the public portion of the service line from the main to the water meter or property line; lead service lines on the property owner’s side of the property line remained in place. Construction and the removal of the public portion of service lines disturb the pipes, shaking loose the coating of corrosive scale that minimizes exposure to the lead pipe. The corrosive scale, which contains high concentrations of lead, then travels through the property’s water lines, increasing the risk of exposure to lead. “Lead Exposure and Infrastructure Reconstruction,” New Orleans Office of Inspector General, July 19, 2017, 18─24.
20. The ERB’s sole role is as the IG’s appointing authority; it has no authority over the Office’s work products or internal operations.  New Orleans Municipal Code, Art. XIII, Sec.2-1120(3)(a) and (4).
21. The report had been reviewed and its content confirmed by two experts in the field. The former regulations manager for U.S. Environmental Protection Agency, Region 5 wrote: “It is a very well-written report … . Please let me know when it is ok to share as the report is very comprehensive and would be extremely useful for others who are struggling with these same issues.”  Miguel DelToral, e-mail message to Assistant IG for Inspection and Evaluation, July 10, 2017. Dr. Marc Edwards wrote, “Report looked great … well done.”  Marc Edwards, e-mail message to Assistant IG for Inspection and Evaluation, June 15, 2017. Dr. Edwards and his graduate students conducted testing and research that exposed the unsafe lead levels in Flint, MI. John McQuaid, “Without These Whistleblowers, We May Never Have Known the Full Extent of the Flint Water Crisis,” Smithsonian Magazine, December, 2016.
22. The member is the Executive Director of the New Orleans Council on Aging, Howard Rodgers III. “Board,” City of New Orleans Ethics Review Board, accessed June 20, 2019. For the agency’s budget, see “2017 Annual Operating Budget,” City of New Orleans, accessed June 20, 2019, 435. This member’s personal financial disclosure statements can be found by searching Howard Rodgers III at “Disclosure Portal,” LA Ethics Administration Program, accessed June 23, 2019.
23. OIG Recommended Sales of Tax Delinquent Properties Produce More Than $12 Million in Revenue,” New Orleans Office of Inspector General, December 23, 2015. The report recommended the sale of adjudicated properties at the earliest date allowable by law. “Delinquent Property Tax Collection Program,” New Orleans Office of Inspector General, March 21, 2013, 18.
24. It is even more unfortunate that the Office’s upheaval occurred during the City’s administrative transition. Independent and nonpolitical, IGs can provide stability, institutional memory, and valuable historical knowledge about issues that will face a new administration. For this reason, they typically remain in office during administrative transition periods. “Presidential Transition Handbook: The Role of Inspectors General and the Transition to a New Administration,” Council of the Inspectors General on Integrity and Efficiency, October 4, 2016, 2 and 16.
25. Ibid, 6.