Chair's Final Report After Commissioner's Notice – Police Investigating Police

RCMP Act Subsection 45.46(3)

Vetted version for posting

August 11, 2009

File No.: PC-2007-2673

Table of Contents

The Complaint

The Chair of the Commission for Public Complaints Against the RCMP (CPC) launched a Chair initiated complaint and public interest investigation on November 28, 2007, to assess the conduct of those unidentified RCMP members who have undertaken criminal investigations into the activities of other RCMP members in cases involving serious injury or death, which took place anywhere in Canada between April 1, 2002 and March 31, 2007.

Specifically, the CPC sought to assess:

  1. Whether the RCMP members involved in these investigations conducted the investigations free of actual or perceived conflict of interest, whether they responded appropriately and proportionately to the gravity of the incident, whether they responded in a timely fashion and whether their conduct adhered to the standards set out in section 37 of the RCMP Act.

    More specifically:
    • (a) Line management
      • Whether any actual or perceived conflict of interest.
      • Appropriateness of management structure and reporting relationships.
    • (b) Appropriate level of response
      • Whether RCMP investigative team response to the incident was appropriate and proportionate to the gravity of the incident.
      • Whether qualified investigators have been assigned.
    • (c) Timeliness of the response
      • Whether members of the RCMP investigative team responded in a timely fashion to the incident.
    • (d) Conduct
      • Whether the conduct of members of the RCMP investigative team during the course of the investigation was consistent with section 37 of the RCMP Act.
  2. Whether these same RCMP members complied with all appropriate policies, procedures, guidelines and statutory requirements for such investigations.

The Commission's Public Interest Investigation and Interim Report

With the objective of identifying the most appropriate model for the RCMP's handling of criminal investigations into its own members (involving serious injury, sexual assault or death), the CPC:

  • Undertook a detailed analysis of current media, political, and academic debate on the issue to determine a baseline for discussion;
  • Sought public submissions on the issue to help inform the debate;
  • Assessed the adequacy of current RCMP policy guiding member action when investigating another member;
  • Reviewed a sample of 28 RCMP investigations where member actions were alleged to have resulted in serious injury, sexual assault or death between 2002 and 2007 (the appropriateness of each case was assessed against specific criteria which included: line management; level of response; timeliness; conduct; and compliance with policy); and
  • Researched alternate investigative models and conducted interviews with domestic and international bodies.

Case File Review:

The CPC assessed 28 randomly-selected cases in order to determine how appropriately each RCMP member investigation was handled against five key criteria: (1) conduct, (2) policy compliance, (3) timeliness, (4) line management and (5) level of response.

To secure a random sample for review, cases were first categorized by RCMP region/division and by offence category (assault, sexual assault and death). From this list, a random selection was made to ensure that every RCMP Region and every offence category was represented.

With the sample selected, the CPC then began the work of assessing each case against the RCMP-CPC jointly developed criteria for the E (British Columbia) Division Observer program, set out in the Chair-initiated complaint which includes: (1) conduct, (2) policy compliance, (3) timeliness, (4) line management and (5) level of response.

In order to make a determination about whether or not the RCMP handling of each investigation was appropriate, the CPC included a more detailed definition of what could be considered "appropriate" under each of the pre-established Observer criteria. It is important to note that the development of these detailed baseline definitions was necessary given that nothing currently exists in policy or in legislation to guide the appropriate handling of a member investigation. There is no gold standard. So we created one.

The detailed baseline definition for each criterion was developed based on:

  • An assessment (including interviews) with domestic and international criminal investigative bodies and best practices identified therein.
  • Key concerns identified in the public submissions to the CPC which expressed what key stakeholders (members of the public, international and domestic policing and oversight bodies, NGOs, etc.) identified as acceptable and unacceptable (e.g. need for transparency, timeliness, impartiality).
  • Results of the CPC's preliminary scoping of RCMP member investigations and recommendations regarding common Canadian police practices.

In order to maximize transparency in our review and ensure rigor in the process for both the public and the RCMP, the CPC identified whether the handling of each of the 28 cases was deemed to be overall:

  • Appropriate: Met or exceeded all criteria identified. No issues were found with the handling of the investigation.
  • Inappropriate: Did not meet key criteria. Issues were found that the CPC identified as significant enough to potentially undermine the integrity of the investigation.
  • Partially Inappropriate: Met some criteria but not all. This category was introduced to credit the RCMP in cases where some criteria were met but where room for improvement remained.

On May 15, 2009, the CPC concluded generally in its Interim Report that:

To answer the question: "Can the current process of the RCMP investigating itself legitimately engender confidence in the transparency and integrity of the criminal investigation and its outcome?" – the informed CPC answer is that it cannot. To address this, the CPC has recommended legislative, policy, procedural and structural proposals for change.

While the specific findings and recommendations relating to this issue are set forth below, the following are highlights of the Report:

  • While the RCMP contention that member investigations be handled like any other investigation may be an honourable one (meaning without bias), the very nature of an investigation by one police officer into another is fundamentally different from the police investigating a member of the public for the exact same crime. Police are held to higher account by the very nature of the work they do. It is therefore the CPC's contention that criminal investigations into RCMP members should not be treated procedurally the same as any other criminal investigation.
  • Results of the CPC's policy analysis revealed inconsistencies in policy content and application across RCMP divisions. While the RCMP has developed a number of policies relating to how criminal investigations should be undertaken generally, very few policies address the issue of RCMP member-committed offences specifically. This is a serious concern.
  • At present, the handling of member investigations varies by Division, with discretion resting at the Division level with no national, mandatory requirements for the handling of member criminal investigations.
  • Overall, the lack of national and divisional data collection – or monitoring capacity – for member investigations (combined with varied divisional RCMP record-keeping and retrieval methods on this issue) demonstrates a lack of centralized coordination and attention being placed on member investigations.
  • This is why the CPC therefore recommends the creation of the position of National RCMP Member Investigation Registrar to coordinate the development of national policy and the handling of member investigations at the Division level.
  • It is the CPC's contention that there are certain instances where the RCMP should not investigate itself. As the seriousness of the offence alleged against a member rises, the discretion for the RCMP to respond as it deems appropriate must be removed and mandatory requirements should be inserted in its place.
  • The CPC recommends the following mandatory requirements be introduced:
    • All member investigations involving death should be referred to an external police service or a provincial criminal investigative body (where in place). There should be no RCMP involvement in the process and the CPC Observer should be embedded to ensure transparency from a civilian perspective.
    • In all member investigations involving serious injury and sexual assault, it is recommended that the CPC and the RCMP National RegistrarFootnote 1 jointly determine an appropriate response from the following options:
      • Refer the investigation to an external police service or provincial investigative body (where in place); or
      • Deploy an RCMP HQ Mobile Critical Incident member investigation team; and
      • Ensure the CPC observer is embedded in the investigation.

Overall key findings from the case file review:

Grid summarizing the total level of appropriateness for each of the five complaint criteria.
Text Version

CPC Complaint Criteria – Overall Assessment

  • Conduct
    • Appropriate – 100%
    • Partially Inappropriate – 0%
    • Inappropriate – 0%
  • Policy Compliance
    • Appropriate – 93%
    • Partially Inappropriate – 0%
    • Inappropriate – 7%
  • Level of Response
    • Appropriate – 82%
    • Partially Inappropriate – 14%
    • Inappropriate – 4%
  • Timeliness
    • Appropriate – 32%
    • Partially Inappropriate – 43%
    • Inappropriate – 25%
  • Line Management
    • Appropriate – 32%
    • Partially Inappropriate – 36%
    • Inappropriate – 32%
  • Overall, RCMP member conduct was deemed highly appropriate in 100% of the cases reviewed. The CPC found that the RCMP investigators charged with the task of investigating another member acted professionally and free from bias.
  • The CPC also concluded that RCMP member policy compliance was appropriate in 93% of the cases. Only two minor policy violations were found. It is important to note that this criterion sought only to determine how well members followed policy in place at the time of each investigation, and did not seek to assess the adequacy of these policies (this issue was assessed separately, as outlined previously).
  • The timeliness of member investigations was also deemed overall appropriate 82% of the time. Of the 28 cases reviewed, 60% were completed in six months or less. However, 19% of these cases took over one year to complete, thereby potentially excluding members from internal disciplinary processes, if required. Specific concerns were also raised around the handling of historical cases which took considerably longer to investigate (one historical case still remained ongoing after 28 months at the time of publication).
  • The two criteria the CPC found of greatest concern were the RCMP's handling of the investigations in relation to line management (which looked at any actual/perceived conflict of interest; appropriate management structure and reporting relationships) and level of response (which looked at how appropriate and proportionate the RCMP response was to the gravity of the incident).
  • Given the fact that these two criteria specifically relate to the process of how member investigations are handled, this analysis further helps to illustrate the fact that CPC concerns relate largely to the current RCMP process (which is flawed) and not individual RCMP member action.
  • Of particular concern to the CPC is the RCMP's line management, which was deemed to be appropriate in only 32% of the cases. Sixty-eight percent of the cases reviewed were deemed to be handled either partially or entirely inappropriately.
    • Of particular concern was the fact that 25% of primary investigators identified themselves as personally knowing the subject member. Another critical concern is the fact that in 60% of the cases reviewed, a single investigator was assigned to investigate another member, thereby placing the integrity of the investigation at risk for potential conflict of interest or perception of bias.
      • Further, in 32% of the cases, the primary investigator assigned was of the same or lower rank as the subject member, thereby creating the potential for intimidation. Recommendations to address these concerns are outlined in greater detail below.
  • Of equal concern to the CPC is the 68% of cases deemed to be partially or entirely inappropriate for level of response.
    • Of particular concern was the fact that interviews with subject members and witness officers were conducted by a lone investigator in 17 of the 28 cases, again creating the potential for intimidation or a conflict of interest.
    • Other concerns included the referral of cases to the proper sections. The CPC noted inconsistent assignment of files across divisions and an absence of formal criteria to identify which investigative unit should be assigned which cases.
    • The CPC also found a significant disparity in the qualifications of the investigators (including primary investigators) assigned to member investigations.

The RCMP Commissioner's Notice

Pursuant to subsection 45.46(2) of the RCMP Act, the RCMP Commissioner is required to provide written notification of any further action that has been or will be taken in light of the findings and recommendations contained in the Interim Report.

On July 30, 2009, the CPC received the RCMP Commissioner's Notice. The RCMP Commissioner provided commentary touching upon some of the CPC's findings and recommendations.

These comments focused on concerns related to the language in the report which the RCMP believes to be "unduly negative" and questions are raised about the reasonableness of making judgments about past investigations based on newly proposed criteria. The Commissioner further states his personal preference would be for the "RCMP never to investigate our members and for such investigations to be carried out by another agency" but states that the model proposed by the CPC to address this may be "impractical in some instances".

In response to the Commissioner's comment regarding the reasonableness of the CPC's assessment of the 28 cases against criteria that was not in place at the time of the investigation, it is important to go back to the premise of the review which sought to address ongoing public outcry in relation to the practice of the RCMP investigating itself. In the public interest, the CPC set out to assess the handling of RCMP member investigations and make specific recommendations in that regard. Of central concern to the CPC was a systematic failure by the RCMP to have any national standards, policies or procedures for the handling of its own member investigations.

Despite the fact that s. 37 of the RCMP Act calls for members to "avoid any actual, apparent or potential conflict of interests" and the Commissioner's Standing Order states: "[a] member shall not investigate a complaint where that member may be in a conflict of interest situation" – nowhere is there any definition of what could be considered a real or perceived conflict of interest.

The absence of any national guidelines speaks to the RCMP's failure to proactively look at the common practices of other agencies or government departments in order to develop a standard. To address this public concern, the CPC developed criteria that were advanced in the course of the PIP evaluation that is reflective of best practices followed by other police forces and criminal investigative bodies in Canada and abroad.

Overall, the CPC was pleased that the Commissioner's Notice also confirms that "the report will no doubt prove useful in guiding and evaluating future investigations and in our ongoing policy development." The RCMP further agrees that "criminal investigations of RCMP members may necessitate different treatment from a procedural point of view."

The Commission's Findings and Recommendations:

For ease of reference, the overall findings and recommendations are listed below in the format in which they appear in the body of the report (numbered and boxed). Overall, the CPC made 20 findings and 14 recommendations, all of which were used to develop the recommended CPC model for how the RCMP should handle its member investigations involving serious injury, sexual assault or death in future.

CPC Final Report Findings:

Finding No. 1: What is at issue today is no longer whether civilian review is desirable, but rather, how civilian involvement in investigations can be most effective.

Finding No. 2: The very nature of conducting criminal investigations requires that police, to some extent, must be part of the solution.

Finding No. 3: RCMP policies, while voluminous, are inconsistent and do not adequately address the handling of member investigations.

Finding No. 4: The lack of national and divisional data collection – or monitoring capacity – for member investigations (combined with varied divisional RCMP record-keeping and retrieval methods on this issue) demonstrates a lack of attention being placed on member investigations.

Finding No. 5: Overall, personal knowledge of subject member for primary investigators occurred 25% of the time and 4% of primary investigators were from the same detachment as the subject member.

Finding No. 6: There was a slightly higher likelihood of primary investigators personally knowing the subject member (14%) in remote and northern postings than in other more centralized locations (12%). However, there does remain a large number of primary investigators (12%) from more centralized divisions where external assistance is more readily accessible.

Finding No. 7: Overall, in the opinion of the CPC investigators, the use of expert witnesses in the cases was appropriate.

Finding No. 8: Overall, the number of team members assigned to the 28 investigations was inadequate.

Finding No. 9: Overall, the CPC found the structure and reporting relationships of the 28 cases reviewed to be partially or entirely inappropriate (68%).

Finding No. 10: Of the 28 files that the CPC investigators reviewed, it was found that in 17 of these files, the subject member and witnesses were investigated by a lone RCMP investigator.

Finding No. 11: Overall, the section or unit tasked with member investigations (including their mandates) lack uniformity across the country.

Finding No. 12: In the 28 case files reviewed, the qualifications of the investigators varied greatly. Some had all the major crime and related courses, while others had as few as two years experience in the General Investigation Section.

Finding No. 13: Overall, it was found that the investigations conducted by the Major Crime Unit were focused and completed in a timely fashion, as they had the ability, resources and the time to conduct the investigation. This was not found to be the case when the investigation was assigned to a Detachment Commander or General Duty or GIS member whose heavy workload was not adjusted accordingly.

Finding No. 14: Of the 28 cases reviewed, six of which involved death, an administrative review was only undertaken in four cases: two of which were member-involved shootings (Manitoba (D) & Nunavut (V) Divisions); and two of which were in-custody deaths (Saskatchewan (F) and Alberta (K) Divisions).

Finding No. 15: The CPC found that, overall, the level of response was handled partially or entirely inappropriately (68%). Key concerns related to interviews being undertaken by lone investigators as well as inconsistent referral of cases to the appropriate investigative unit.

Finding No. 16: Of the eight charges laid, three (37.5%) resulted in successful convictions, while five (62.5%) resulted in no convictions.

Finding No. 17: In cases where an immediate response was required, such as member-involved shootings and in-custody deaths, the CPC investigators found that all necessary personnel were dispatched to the incident as soon as possible and practicable.

Finding No. 18: The CPC found that most investigations were completed in a timely manner. The files that took significantly longer to complete were not due to a lack of interest but rather to the heavy workload of the investigator in addition to general hindrances encountered (court dates, difficulty locating witnesses or complainants, employee absence, etc.).

Finding No. 19: Overall, the CPC found that the RCMP investigators were free of bias and were professional and conscientious in their approach to their assignments. It was also found that most subject members and witness members cooperated with the CPC investigators and conducted themselves in a professional manner.

Finding No. 20: After an in-depth review of the randomly selected cases, it was found that in most cases, the appropriate policies were complied with. In the few cases where it was found that some aspects of the related policies were not adhered to, they were minor in nature and did not appear to have any effect on the outcome of the investigation.

CPC Final Report Recommendations:

Recommendation No. 1: Overall, it is the CPC's contention that criminal investigations into members should not be treated the same as any other criminal investigation.

Recommendation No. 2: The CPC recommends that the rank of the primary investigator must be at least one rank higher than that of the subject member.

Recommendation No. 3: In order to reduce the length of time to conduct statutory investigations against RCMP members, it is recommended that member investigations be assigned to a team of (minimum) two members in a specialized investigative unit.

Recommendation No. 4: The RCMP should assign competent senior investigators with a proven track record in court who have completed the appropriate courses (e.g. sexual assault, major crime, interviewing and interrogation techniques and statement analysis); who can effectively interview witnesses with strong analytical skills.

Recommendation No. 5: Workload of members assigned to member investigations should be reassigned or adjusted to prioritize member investigations accordingly.

Recommendation No. 6: Special attention should be paid to enforce the RCMP requirement to consult with the Crown prior to laying any charges against members, given the particular need for independence and impartiality in member investigations. The RCMP should also undertake a review regarding recommendations made to the Crown in cases involving RCMP members.

Recommendation No. 7: Given the sensitivity and transparency required for member investigations, it is recommended that administrative reviews be undertaken in all cases of serious injury, sexual assault or death.

Recommendation No. 8: The RCMP should consider applying the use of the "probe"Footnote 2 to lower-end investigations in all divisions.

Recommendation No. 9: The RCMP could consider recommending that the Officer in Charge of the Criminal Operations Section be the appropriate recipient of the probe report in order to determine whether or not a lower-end investigation should proceed to a statutory investigation.

Recommendation No. 10: Historical cases require expertise not typical of most investigators. It is therefore recommended that these types of cases be handled by a specialized unit at the national or regional level.

Recommendation No. 11: Policy guiding criminal investigations of RCMP members should be standardized nation wide. This would allow for the statutory investigations into RCMP members to be conducted uniformly across the country.

Recommendation No. 12: Create the position of National RCMP Member Investigation Registrar responsible to provide the CPC Chair with regular monthly reports for all member investigations undertaken for indictable offences, hybrid offences and summary convictions.

Recommendation No. 13: The RCMP should formalize a memorandum of understanding for every division across the country to ensure consistency in the referral of member investigations to an external police service.

Recommendation No. 14: The RCMP should create an Integrated Manual to specifically address procedures for investigations undertaken by the RCMP into one of its members.

The CPC proposed model for RCMP handling of member investigations:

Based on the CPC findings and recommendations listed above; academic, political and media research; public submissions; as well as interviews with domestic and international bodies, the CPC proposes the following model for implementation.

Recommended legislative changes:

To effectively enhance review capacity, legislative changes should be considered to provide the new RCMP Review Body the authority to:

  • Refer an RCMP member investigation to another police force or to another criminal investigative body in Canada.
  • Grant the RCMP Review Body the authority to monitor any criminal investigation relating to a member of the RCMP, where it deems it appropriate to do so. This would therefore extend the RCMP Review Body's ability to deploy the observer to an RCMP member investigation being undertaken by an external police service and/or provincial criminal investigative body. While permission from the investigating body would be required to embed the observer, the authority would at least provide the RCMP Review Body with the power where granted permission to observe.
  • Undertake joint investigations with like-mandated bodies. The amendment could allow the new RCMP Review Body to "conduct a joint investigation, review, inquiry, audit or hearing with another body in Canada that has powers, duties and functions that are similar to the RCMP Review Body's, including provincial criminal investigative bodies." This would allow the new RCMP Review Body to undertake investigations with new criminal investigative bodies (like the Alberta Serious Incident Response Team) as they emerge across the country.

Other recommended legislative changes should include:

  • The RCMP Commissioner revise the current version of his Standing Orders to direct handling of member investigations, as per the recommendations herein (specify that member investigations are not to be handled like any other criminal investigation and a better definition of the term "conflict of interest" should be included).

It is important to note that the RCMP recommendations specifically related to structure, procedure and policy (outlined below) do not rely on any legislative enhancements and can be implemented immediately.

Recommended structural changes for the RCMP:

  • Create the position of National RCMP Member Investigation Registrar to manage, track, train, promote and advise on all issues related to member investigations. The National Registrar would be responsible to:
    • Create an RCMP National Registry for all police investigating police data (especially for serious injury, sexual assault, and death cases) with timely sharing of data with the CPC.
    • Create and manage an RCMP Police Investigating Police Advisory Group to help determine actions to be taken in sensitive cases.
    • Monitor effective compliance with policy and enforce compliance where necessary (e.g. consultation with Crown re: laying of charges mandatory).
    • Create and oversee a specialized unit with expertise on the handling of RCMP historical cases to be consulted-or deployed-where necessary.
    • Create a mobile critical incident member investigation team (with a CPC civilian observer embedded) that can be deployed where both the RCMP National Registrar and the CPC Chair jointly determined it necessary to do so (a pool of qualified senior investigators placed on standby that can be deployed quickly).

Recommended RCMP policy and procedural changes

As mentioned previously, there are certain instances where the RCMP should not investigate itself. Below is a chart that delineates that as the seriousness of the member-involved offence increases, a corresponding degree of independence and impartiality in that member investigation is required. The chart below highlights the CPC's contention that as the seriousness of the offence alleged against a member rises, the discretion for the RCMP to respond as it deems appropriate must be removed and mandatory requirements inserted in its place.

Table illustrating the recommended RCMP response to member investigations.
Text Version
Mandatory RCMP Action with CPC Role
Type of offence defined Member offence (by level of seriousness) Current RCMP handling Recommended RCMP handling of member investigation
Indictable offences
An offence which, in Canada, is more serious than those which can proceed by summary conviction. In many regards, this is the Canadian equivalent to the USA felony. Murder and treason are examples of crimes committed in Canada which would be indictable offences. These crimes are usually tried by federally-appointed judges and carry heavy sentences.

Death

Criminal Negligence causing Death (s. 220 CCC)

Discretionary at RCMP Division level RCMP Mandatory Action:
  • CPC to refer all death cases to external police service or provincial criminal investigative body (no RCMP member involvement)
  • Divisional MOUs activated
  • CPC Observer embedded
Serious Injury & Sexual Assault

Assault with Weapon or Assault Causing Bodily Harm
(s. 267 CCC) Sexual Assault
(s. 272 CCC)
Discretionary at RCMP Division level RCMP Mandatory Action: CPC and National Registrar to determine appropriate response from options below for serious injury/sexual assault cases:
  • Referral to external police service or to provincial investigative body through MOU103
  • Deployment of RCMP HQ mobile critical incident member investigation team
  • CPC Observer embedded

Discretion Retained By The RCMP
Type of offence defined Member offence (by level of seriousness) Current RCMP handling Recommended RCMP handling of member investigation
Hybrid Offences

Dual Procedure Offences which Crown can elect to proceed with an indictable offence or a summary conviction.
Assault

(s. 265 CCC)
Discretionary at RCMP Division level RCMP HQ National Registrar retains discretion to determine appropriate response.
Summary Conviction

In Canada, a less serious offence than indictable offences for which both the procedure and punishment tends to be less onerous.
Example:

Theft under $5,000
Discretionary at RCMP Division level RCMP HQ National Registrar retains discretion to determine appropriate response.
  • Recommended CPC standard policies and procedures are followed (outlined next).

Recommended policy changes

The CPC's policy analysis revealed that RCMP policies, while voluminous, are inconsistent and do not adequately address the handling of member investigations. Criminal investigations into members should not be treated the same as any other criminal investigation. To address the current void in effective and consistent policies and procedures related to the handling of member investigations, the CPC recommends the following key changes:

  • Criminal investigations of RCMP members into allegations of serious injury, sexual assault or death in hardship or remote postings must be consistent with all other member investigation protocols, no exception.
  • An administrative review is mandatory for all member investigations.
  • The RCMP establish formalized MOUs for every RCMP division to ensure the mandatory referral of member investigations to an external police service is consistent and documented. At present, only New Brunswick (J) Division, Nova Scotia (H) Division and Newfoundland (B) Division have formalized MOUs in place. These existing MOUs should be revised as per the CPC's recommendations to reflect new processes.

Where it is deemed appropriate for the RCMP to handle its own member investigation or where an RCMP member forms part of the investigative team (led by an external police force), the following policy recommendations would apply.

  • Create an RCMP integrated manual to specifically address procedures for investigations undertaken by the RCMP into one of its own members. This integrated manual should have links to any additional relevant policies for ease of reference. Key features to be included in the integrated manual:
    • CPC recommended investigative team structure:
      • Qualified primary investigator at least one rank higher than that of subject member;
      • A minimum of two members required for every member investigations (including for subject and witness officer interviews);
      • Minimum mandatory qualifications of investigative team;
      • Workload of members assigned to member investigations reassigned or adjusted to prioritize member investigation accordingly;
      • Timely completion of investigation preferably six months and not recommended to exceed one year;
      • Assign liaison position to member of investigative team to ensure timely and effective communication with public, family and subject member;
      • Self-identification of knowledge of subject member mandatory;
      • Use of the probeFootnote 3 in lower-end investigations.

Pursuant to subsection 45.46(3) of the RCMP Act, I respectfully submit my Final Report and, accordingly, the Commission's mandate in this matter is ended.

_____________________
Paul E. Kennedy
Chair

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