Minneapolis Police Department

2008 Republican National Convention

After Action Public Summary
Table of Contents

I. Executive Summary
In January 2007, the Republican National Committee selected
Minneapolis Saint Paul as the host site for the 2008 Republican
National Convention (RNC). Each of the cities signed obligation
contracts with the Republican Nation Committee’s Committee on
Arrangements. In March 2007, Secretary of Homeland Security
Michael Chertoff responded to Governor Pawlenty’s request to have
the Convention a National Special Security Event (NSSE). The NSSE
designates the United States Secret Service (USSS) as the lead federal
agency for the planning and management of the convention. Because
the Xcel Energy Center in Saint Paul was selected as the site of the
convention itself, the Saint Paul Police Department was designated as
the lead local agency for planning and management of the convention.

The United States Congress allocated $50 million in funds to

compensate local government for hosting the convention. Saint Paul
was the fiscal agent for those funds.

Minneapolis’ efforts in planning for the 2008 RNC were led by the City
Coordinator’s Office. The Minneapolis Police Department coordinated
policing and security efforts for the RNC, working closely with the City
Coordinator’s Office, City Attorney’s Office, Public Works Department,
Fire Department, and BIS Department. Virtually every department in
the City of Minneapolis was involved in RNC planning and preparation
and had key personnel involved in planning on top of their day to day
responsibilities. In addition, Minneapolis Police personnel met almost
daily with members of the St. Paul and Bloomington Police
Departments, Hennepin County Sheriff’s Office, Minnesota Department
of Public Safety and numerous other local and federal agencies.

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II. Foreword
The 2008 RNC was the largest long term operation in the history of the
Minneapolis Police Department. Numerous personnel took on
responsibility for RNC planning in addition to their regular assignments.

This document is not designed to be an exhaustive review of the

incredible number of individual events and responsibilities that were
undertaken during the RNC, but rather a summary of key events and
decision points during the RNC to provide a broad overview of the
event. This document addresses events under the command and
control of the Minneapolis Police Department. MPD staff continues to
work with Saint Paul PD and other law enforcement agencies as they
complete after action documents related to events under their
command and control. In addition, MPD is working with the Police
Executive Research Forum (PERF) to develop a comprehensive review
of this event to be used as a template for managing future large scale
events.

Additionally, numerous elements involved in the planning and

operation of the RNC have completed individual reports on their
activities which are designed for sharing with entities which will plan
future events of this nature.

Finally, every member of the Minneapolis Police Department was

involved in some way in the planning and execution of RNC duties.
The members of the department did this work in addition to
maintaining their challenging job of policing the city. The fact that an
event of the scope and complexity of the RNC occurred in Minneapolis
successfully, while maintaining a safe city, is a testament to all
members of the city and its police department.

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III. Planning
As the cities of Minneapolis and Saint Paul jointly prepared a bid to
attract the RNC to the Twin Cities, the Minneapolis and Saint Paul
police departments worked together to ensure that our comments
synched. The Twin Cities are unique: we are a big metropolitan area,
but the area’s largest city has less than 12 percent of the area’s
population. Consequently there is no one dominant law enforcement
agency—when large-scale events occur, numerous agencies have to
work together in order to manage an event the size of the RNC.

Even before the contract was finalized, it was clear that the Xcel
Energy Center would be the convention venue; law enforcement
leaders generally agreed that Saint Paul PD should take the lead in
planning and managing the event. Assistant Chief Matt Bostrom led
the Saint Paul PD’s efforts in planning and management of the event
and became the team leader for local law enforcement in planning the
event.

Federal policy dictates that any event in which federal assets are used
or for which reimbursement through FEMA or other federal programs
will be sought use the Incident Command System outlined in the
National Incident Management Strategy, NIMS. All emergency service
providers from all disciplines are required to be trained in NIMS, and
the City of Minneapolis has taken great pains to ensure that its staff is
NIMS trained. While NIMS was developed out of the fire service,
policing agencies from the various levels of government nationwide
have been working to incorporate NIMS into planning and operating
policies throughout our organizations.

The Secret Service uses a template to plan the event based on having
an “Executive Steering Committee,” which charters a number of (17 in
this case) subcommittees to address various planning elements for the
convention. Generally speaking, each of the subcommittees was co-
chaired by a federal agent and a local law enforcement official. Saint
Paul Police were generally the local co-chairs.

The Executive Steering Committee first met in June 2007, and

established which subcommittees would be created to address
planning needs for the convention. MPD had representatives on a
number of the subcommittees representing Minneapolis’ interests.

The list below shows how we staffed the various assignments:

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 Executive Steering Committee:
Chief Dolan
Operations & Budget Oversight
AC Lubinski
Gaynell Schandel
Planning Coordinator
DC Allen
Planning XO:
Captain Wagenpfeil
Inspector Martin
Civil Disturbance Committee / Mobile Field Force Commander
DC Gerlicher
Personnel Director
Inspector Arneson
Intelligence Coordinator
Lt. Leaf
Training Coordinator
Capt. Weddel
Multi Agency Coordination Center
Insp. Gerold
Insp. Skomra
Legal Issues
Peter Ginder (Deputy City Attorney)
Susan Segal (City Attorney)
Fire / Life Safety / HazMat
Asst. Chief Fruetel (MFD)
Consequence Management
Rocco Forte (Asst. City Coordinator)
Public Information Coordinator
Capt. Amelia Huffman
Downtown Area Command
Insp. Janee Harteau
Dignitary / VIP Protection & Transportation
Lt. Kevin Stoll
Tactical Teams
Lt. Matt Clark
Crisis Management Committee
Lt. Mike Kjos
Explosive Device Mitigation
Sgt. Wally Krueger
Interagency Communications
Lt. Eddie Frizell
Tom Donohoe (MECC)
Logistics Coordinator
Lt. Kathy Waite

This group of personnel formed the core of the planning committee.

This core group started meeting monthly in July 2006, and began
meeting twice a week in May 2008.

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One of the challenges of the planning process was that the Secret
Service, which coordinates the planning process through the Executive
Steering Committee, has two primary concerns: the protection of the
venue (the Xcel Energy Center), and the protection of its protectees.
While the MPD was committed to assist the USSS and SPPD in the
protection of the venue and the USSS protectees, MPD saw its three
primary goals as:

• Maintaining adequate police protection in the City of Minneapolis

during the convention, to minimize the impact of the convention
on the city.
• Ensuring that delegates and visitors attending the time had a
safe and enjoyable time while attending the convention.
• Ensuring that those people who wanted to lawfully exercise their
First Amendment rights had the ability to do so.

Further, while the NSSE (the convention itself) occurred from Monday,
September 1 through Thursday, September 4, 2008, there was a
tremendous amount of activity occurring in the City of Minneapolis
during the week preceding the convention. The Republican National
Committee held its rules committee and platform committee meetings
at the Minneapolis Convention Center during the week prior to the
convention. The Republican National Committee’s headquarters hotel
was the Hyatt in downtown Minneapolis, and the part’s presidential
nominee, Senator John McCain, had his headquarters at the Hilton
Hotel. Needless, both hotels were extremely busy and both hotels,
along with the Minneapolis Convention Center, were the site of
potential protests both during the convention and the week prior.

One of the biggest events to occur outside of the convention was the
media party held by the RNC and Meet Minneapolis on Saturday,
August 30. That event was along the Minneapolis riverfront and
required a sizable police presence to secure.

While planning a major security event requires a certain amount of

secrecy, the Minneapolis Police Department sought to be as
transparent with the planning process as possible without divulging
security plans that need to remain secret. MPD staff regularly briefed
the Mayor’s staff and Council; further, MPD staff worked with Council
Members and existing community groups to help them understand the
impact of the convention on residents and businesses. Notable in the
pre-convention meetings were sessions conducted by 7th Ward Council
Member Lisa Goodman for businesses and residents in the downtown
area, explaining the impact of the convention to residents, workers,
and business managers and owners.

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MPD staff also worked with SafeZone members, leveraging the
SafeZone website to send alerts and updates to members, advising
them of any traffic changes or other downtown activities. Partner
businesses and security services also notified police of suspicious
activities using the SafeZone Radio Link. The MPD shared as much
information as possible with downtown businesses and businesses, led
by BOMA, Brookfield and Target shared that information with other
businesses.

IV. Training
Early on in the planning process, training was identified as an area of
critical concern for all of the participants. Planners who had met with
Boston PD were impressed with the training that their Department had
implemented prior to the 2004 DNC. The training emphasized
patience in dealing with protests and ensuring that each arrest was
thoroughly documented and, above all, necessary to preserve order.

New York had done similar training prior to the 2004 RNC, but due to
the scale of the NYPD response, it was not possible to use some of the
NYPD tactics in Minneapolis. Further, NYPD employed some mass
arrest tactics which we deemed not acceptable to either Minneapolis or
Saint Paul. Specifically, planners were concerned about the use of a
fabric mesh used to encircle large groups of people (“penning”) rather
than making arrests of individuals.

Some of the Boston PD staff was teaching a course called Managing

Civil Actions in Threat Incidents (MCATI) at the Center for
Domestic Preparedness (CDP) in Anniston, AL. (The Center for
Domestic Preparedness is the training arm of the US Department of
Homeland Security.) The BOSTON PD spoke highly of many of the
elements of the class including the management and tactics of mobile
field forces. The CDP staff was willing to come to the Twin Cities to
teach the courses at no cost, provided that local agencies sent people
to Anniston to go through the class and assist with the instruction in
the Twin Cities. The planners liked the idea of using CDP staff to teach

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crowd management because it was free, the instructors were generally
good, and it added the imprimatur of a federal agency to our training.

As we sent people to Anniston to get trained, however, we learned of

some weaknesses in the MCATI course. First: the MCATI course was
fairly rigid and they would not adapt the course to align the course
with the values of the Minnesota agencies. While Minnesota agencies
might prefer to wait a while, for example, before clearing an
intersection blocked by protestors, MCATI staff suggested that any
blocking needed to be dealt with immediately.

Because of our concerns with the MCATI training, MPD staff met with
St. Paul and requested that MPD, SPPD and the other agencies
involved develop our own training. The involved police agencies, city
attorneys’ offices and others developed a cadre of officers who
conducted a minimum of 24 hours of crowd management training,
including tactics, legal issues and communication to every officer
involved in the mobile field forces. In addition to the classroom
training, a number of drills were conducted for participants prior to the
actual convention.

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V. Intelligence
The Intelligence sections mission was to obtain, assess and share
information about individuals and groups who may pose a threat to
protectees, designated venues and/or the RNC itself. The objectives of
the Intelligence Subcommittee, which MPD joined was to:

• Establish an intelligence working group of analysts to review and

assess all aspects of information received, and disseminate it as
needed.
• Coordinate the assets of the federal, state and local intelligence
community.
• Predict and prevent illegal actions directed to disrupt the RNC.
• Develop an interagency communications plan for the overall
intelligence operations.
• Determine equipment needs for intelligence operations.
• Develop Field Investigation Teams for forward intelligence
operations.
• Develop an organizational structure to incorporate federal teams’
information with state and local functions.
• Locate staffing for all functions.

The MPD was not involved in intelligence gathering activities prior to

the convention, except to the degree that we participated in SPPD’s
task force and attended meeting with other agencies that were
collecting information about groups that had stated plans to disrupt
the convention.

Prior to the RNC detail all RNC Intelligence officers received 12 hours of
training which included:
• Legal considerations of surveillance
• Information on the background of anarchist and other protest
groups.
• Likely strategies these groups may employ during RNC.
• Illegal tactics and materials that have been used by extremist
groups in protest situations.
• Practical exercises in which undercover (UC) intelligence officers
observed and interacted with “protester” role players and
communicate relevant information to MFF operations
commanders.

West Area Intelligence Officers received 3 hours of additional training

which included briefings on:

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 • The City of Minneapolis’ policy on surveillance of political groups
• West area locations and events where direct action activities by
extremist protest groups were considered most likely to occur.
• West Intelligence Section communications plan.
• Downtown Minneapolis Intelligence Sectors and key RNC sites.
• Instruction on use of video cameras to document suspicious or
illegal behavior observed.

During the convention, there was a multi-agency center consisting of

federal, state, and local law enforcement agencies responsible for
obtaining and analyzing information regarding RNC related events and
participants, and for appropriately sharing and disseminating
intelligence information to administrative and area commands for
operational purposes.

VI. Field Operations

This document will not address activities in St. Paul, as those incidents,
which were under the command and control of the St. Paul Police
Department, are addressed in their after action documents.

There was sporadic activity related to the RNC in Minneapolis during

the week prior to and during the convention. This document will
address the largest activities the MPD were involved with:

A. Crime in the rest of Minneapolis during the

RNC

From the initial planning for the RNC, one of our stated goals was
to ensure that all of the work going into RNC-related activities did
not have a deleterious effect on crime in the rest of the city. We
maintained staffing levels in the precinct at levels that were at
least as high as average staffing. We also maintained our crime
analysis and tracking function in place to ensure that we would
be able to rapidly respond to any emerging crime trends or
patterns.

As demonstrated by the chart below, crime in Minneapolis was

far below the three year average for the week of the RNC.

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B. Critical Mass Bike Ride

BACKGROUND: The Critical Mass Ride is a monthly event that

takes place in locations all over the world on the last Friday of
each month. The intent of the ride is to bring attention to the
perceived over-dependency of the world on fossil fuels and to
encourage people to use alternative forms of transportation,
such as cycling, to preserve these resources. In Minneapolis, the
Critical Mass Ride has taken place for many years with very few
criminal incidents. Typically, the ride lacks formal leadership or
guidelines, and this has caused many traffic issues. Normally,
MPD has had Officers attempt to escort the group on its ride to
block traffic and protect the motorists, riders and pedestrians
form harm or confrontation.

On Friday, August 31, 2007, the Critical Mass ride again took
place, but due to several incidents concerning riders and lack of
formal command / control in the part of the MPD, several arrests
were made. This resulted in a small “riot” occurring, a “HELP”
call being sent out, and in the end, 19 participants being
arrested. From that ride forward, the Police Administration has
ordered that the Special Operations Division will coordinate the
detail and act as Incident Command each month.

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The mission of the MPD during this ride was to facilitate a
peaceful ride that is safe for the riders, the motoring public, and
police officers, prevent crashes between riders and motor
vehicles, prevent assaults by riders on motorists and by
motorists on riders, prevent major traffic congestion sustained
over an unreasonable amount of time in one location, uphold the
criminal codes and traffic laws when other options to handle a
situation are unreasonable, document the event with video
cameras, and use only reasonable force when necessary.

DEPLOYMENT RESPONSIBILITIES FOR AUGUST 2008 RIDE:

 Incident Commander to provide overall supervision for the
event.
 MFF Division 8 Officers to provide rear escort for the riders.
 MFF Division 8 Officers to function as arrest teams and stay
out of sight of the ride until needed.
 SOD-ISAC positioned in close support to provide video
documentation if any incidents occurred during the event.
 MPD Bike Teams to provide close escort and vehicular
traffic control.
 SPPD Incident Commander to accompany the ride and take
charge of the ride if it entered St. Paul. A SPPD division to
take over all Law Enforcement elements of the ride while in
St. Paul.

SUMMARY OF THE EVENT:

 There was an estimate of approximately 550 riders at the
beginning of the event.
 The MPD Administration and IC (Lt. Matt Clark) meet with
some possible event leaders.
 At approximately 1720 hours an announcement was made
to the CM group by the IC. This announcement contained a
greeting, expectations of the riders by MPD, and outlined the
MPD escort plan.
 At approximately 1740 hours the ride began.
 Due to the large number of critical mass riders, all
elements of the detail were deployed from onset of ride.
 Elements from Division 8 stayed in close support to the
ride, traveling along parallel routes but out of sight in case
they were needed to assist.
 Division 8 Escort Squads, Bike Teams and IC vehicle rode
with the group through Minneapolis and St. Paul.
 The ride went into St. Paul and command of the event was
released to a SPPD Commander for a brief period of time. The

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 SPPD division was not able to assist in St. Paul because they
were out of position.
 While downtown the slower riders stretched the ride out
over 10-14 blocks. A second IC (Lt. Stoll) was placed in
command of the rear group, while the original IC commanded
the front group. The second group later diminished.
 The ride then re-entered St. Paul. Command was turned
over to Cmdr. Iovino (SPPD). An SPPD MFF Division took over
the escort duties of the ride.
 At approximately 2045 hours SPPD left a small group of CM
riders as they entered Minneapolis.

OUTCOME NARRATIVE:

The CM riders were relatively friendly and cooperative during the

ride. MPD and SPPD officers maintained a professional
demeanor, establishing rapport with fellow riders, and
distributing water to riders who appeared to be distressed from
the heat. No arrests were made.

LESSONS LEARNED – FUTURE PLANNING:

• The new ATVs with PA systems and sign board

are a valuable tool. The ability to address the entire
group of riders may have set the cooperative tone of
the ride.
• As always the bike officers were the most
important asset. Their ability to provide a close and
personnel escort maintains order within the ride.

C. Media Party

On Saturday, August 30, the City of Minneapolis, the RNC Host

Committee and Meet Minneapolis hosted a party for members of
the media who were in town to cover the RNC. The party was
held along the riverfront and posed potential logistical challenges
because of a concurrent University of Minnesota Gophers football
game at the nearby, which was anticipated to draw between 30
and 40 thousand people to the area. MPD personnel worked with
City Coordinator’s Office staff to develop a security plan and
address logistical concerns for the event.

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 The MPD had a goal of having a robust security presence due to
the fact that it was a high threat target, without it seeming like
there was a large police presence. Detail commanders did this
by “hiding” some of the available police assets and by putting
out officers who were friendly and there to help guide and greet
the attendees. There were no security problems or arrests at the
event.

D. Liberty March

On Sunday August 31, Intermedia Arts, a community arts

organization based in South Minneapolis, hosted the “Liberty
Parade,” which they described as a way for the arts community
to participate in the RNC. MPD assisted with traffic management
for this parade. Staff worked with parade organizers to ensure
that the parade went smoothly. The only event of note during
this event was the presence of a small group of protestors from
anonymous.org, who regularly protest outside of the church of
scientology. This group is very peaceful, and we didn’t have any
issues associated with their presence.

E. Ron Paul Rally

Supporters of Representative Ron Paul had a number of small

demonstrations throughout the city during the RNC. Their
gatherings were all peaceful; on one occasion when they
gathered at the Federal Reserve Bank they were asked to not
block a sidewalk and immediately complied. On Tuesday,
September 2 supporters held a rally at Target Center from 1400-
2200. MPD staff worked with organizers and Target Center staff
to ensure the safety of all concerned. While several thousand
people attended the rally, there were no reported issues.

F. Rage Against the Machine Concert

On Wednesday, September 3 the band Rage Against the Machine

played a concert at Target Center. The band is reported to have
a strong following among members of the community who are
occasionally inclined to destructive protests. LAPD staff had
reported to MPD that they had a number of confrontations with
attendees when the band played in Los Angeles during the
Democratic National Convention in 2000.

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MPD staff conducted sweeps of the area adjacent to Target
Center prior to the concert and discovered some small hidden
caches of concrete chunks and bottles, which led MPD to believe
that some attendees might attempt to damage property or throw
these items at police following the concert. MPD staff developed
a security plan for a large protest / demonstration following the
concert.

During the concert the band reportedly implored the audience to

remain peaceful and not engage in destructive or unlawful
behavior. The vast majority of attendees left the area without
incident.

A group of about 150-200 individuals stood in front of a police

line on N 7th Street, just east of 1st Ave N. That group expressed
its desire to march in the streets, EB on 7th Street. As the group
did not have a permit for a march and as 7th Street is a one way
westbound, the group was directed to move south on 1st Ave N.
MPD staff agreed to facilitate a march—despite the fact that the
group did not have a permit—southbound on 1st Avenue. The
individuals on 7th Street refused and sat down in front of the
police on 7th Street. MPD command told the people seated in the
street, via PA, that if they did not leave the street, they would be
arrested

MPD mobile field forces had sufficient personnel to arrest the

people sitting on 7th Street and refusing to leave. On scene, top
commanders of the MPD felt that since the group was relatively
small and we had adequate resources to address any unlawful
behavior, 1st Avenue and 7th Street should be opened up. A
group of about 100 individuals than ran east, through traffic on
7th street. MPD bike teams and mobile field forces stopped the
group after 4 blocks. 98 individuals were cited—processing of
the individuals took only 90 minutes.

The decision to allow this group to leave or to move up the street

and face arrest later was made by MPD leaders on the scene. By
addressing the situation this way, we gave demonstrators a
chance to leave without arrest. Those who chose to continue to
illegally occupy the street were arrested after several blocks,
away from the open air events at 7th and 1st Avenue N and
without using any force.

As these cases are still working through the court system, it is

inappropriate to comment further.

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G. Ramsey County Search Warrants
On Thursday, August 28, members of the Ramsey County
Sheriffs Office contacted MPD and stated that they had obtained
search warrants for three locations in Minneapolis. They stated
that the search warrants were related to RNC protest activity and
requested MPD’s help in executing the warrants. It is standard
practice for MPD to assist other agencies serving search warrants
in Minneapolis if said warrants are properly attained and signed
by a judge. Because MPD staff was concerned due to the
potentially sensitive political nature of these warrants, MPD
asked the Hennepin County Attorney’s Office to review the
search warrants to ensure they were proper. Because they were
reviewed by the Hennepin County Attorney’s Office and signed
by a District Judge, MPD provided personnel to assist Ramsey
County in executing the search warrants on the morning of
August 30. Senior commanders from MPD were assigned to each
of the three locations to ensure that any problems that arose at
the scene could be quickly addressed. There were no reported
injuries or unexpected complications related to the execution of
the warrants.

Because the criminal cases surrounding the execution of these

warrants have not been resolved, it is inappropriate to comment
further.

H. Other Individual Incidents

It is important to note that, to date, MPD has received no
complaints through Internal Affairs or Civilian Review regarding
our actions during the RNC. Chief Dolan asked MPD’s Internal
Affairs Unit to examine two incidents to determine if appropriate
force was used. The first was a much-televised incident in which
chemical spray was used by MPD bike officers on a protester who
refused repeated orders to clear a street. The other was the
arrest of an AP reporter who allegedly crossed police lines after
being warned not to do so. The investigations into these two
incidents is complete, but will not be released at this time
pending the result of possible criminal cases or civil litigation.

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VII. Future Considerations
Political Conventions have typically been held in large cities—Los
Angeles, New York Boston, Miami, Chicago—where there is one
large police department. The Twin Cities is unique in that we are
big metropolitan area but both central cities are relatively small.
This event proved challenging because it required a number of
agencies, that are used to operating independently, to work
together. This required establishing communications and
command and control systems specifically for this event. While
there were challenges, Minnesota law enforcement—with a lot of
help—was quite successful in managing an incredibly complex
event.

MPD planners said early on that we would either be criticized for

being over-prepared or not prepared enough. The planners were
wrong: we have been criticized for both. Some have suggested
that the fact that were small groups of protestors who committed
property damage to buildings and delegates’ buses shows that
we were unprepared. Others have suggested that there were far
too many police and that the Twin Cities seemed like a “police
state,” stifling free expression. This is the fundamental challenge
in any special event planning: how do you protect the public and
ensure that people’s freedom of expression, at the same time, is
not stifled.

The MPD is working with the Police Executive Research Forum

(PERF) to further study this event and how we should address the
issues that we face in managing future events. Here are key
areas that we anticipate the PERF study will address:

Command and Control: Crowd management orthodoxy calls

for centralized command and control of mobile field forces, and
generally it works very well. It was clear to MPD command,
though, that there has to be a high level of command presence
at the scene of incident. While centralized coordination of
resources is essential, decisions about the actions of officers is
best made at the scene by a high level commander who
understands the larger ramifications of those actions.

Communications: The Joint Information Center model that has

developed did a good job of getting media the information they
need. There were challenges with controlling crowds and
simultaneously allowing media access to cover the story. This

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challenge is exacerbated by the fact that there is no clear
definition of who “the media” is. There were very clearly
individuals claiming media status who were involved in
disruptive activities.

One of the real successes in Minneapolis was the communication

between the city and downtown businesses and residents.
Meeting facilitated by Seventh Ward Council Member Lisa
Goodman were critical in easing the concerns of downtown
residents. The MPD’s existing SafeZone structure can serve as a
national model for communication between the police and the
business community.

Crowd Management: The policing profession has gotten

better at balancing the need to maintain public safety with the
need to facilitate people’s First Amendment right to free
expression. While Minneapolis did well, there are areas that
need to be addressed once the criminal prosecutions and any
civil litigation have been completed. One of the key areas
addressed will be the need to be prepared to deal with a crowd
that engages in unlawful behavior without creating an
appearance of a “police state,” potentially chilling legitimate first
amendment expression.

Intelligence: Balancing the need for information about

potential unlawful activity with avoiding surveillance of peaceful,
lawful groups.

The analysis of MPD’s performance in managing the RNC is an

ongoing process. As different elements of the process clear the
court system and as discussions and feedback from stakeholders
continues to arrive, we will continue to evaluate our performance
and look for ways to improve.

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