ATC200715: Report Portfolio Committee on Police on the Adjusted Budget Vote 28, South African Police Services, dated 15 July 2020
Police
Report Portfolio Committee on Police on the Adjusted Budget Vote 28, South African Police Services, dated 15 July 2020.
1. Introduction
The Division of Revenue Amendment Bill [B09-2020] and Adjustments Appropriation Bill, 2020 [B10-2020] was tabled on 24 June 2020 by the Minister of Finance. The purpose of the Bill was to mitigate the measures Departments had to take to deal with the impact of COVID-19 pandemic on the country. This was after the President declared a national lockdown on 15 March 2020.
On the 21st of April 2020 the President announced a R500 billion fiscal support package that includes spending towards COVID-19 priorities. On 30 April National Treasury published on the “Economic Measures for COVID-19”, outlining an R500bn response, as well as identifying the funding sources for the package. Part of the funding sources for this package is a R130 billion baseline re-prioritisation in the 2020/21 financial year.The Special Adjustment Budget seeks to modify the 2020/21 budget to utilise current baseline allocations to provide for the rapidly changing economic conditions and enable spending on the COVID-19 response. A revised fiscal framework has been presented, to account for substantial revenue losses emanating from the economic shock of the pandemic and subsequent lockdown.
The Adjustment Budget has implications for the South African Police Services (Vote 28) as police officers are at the frontline of fighting the pandemic through policing the Lockdown Regulations
2. The implications of the COVID-19 pandemic on the mandate of the Department.
The SAPS derives its mandate from Section 205 of the Constitution of the Republic of South Africa, 1996 (Act No 108 of 1996). The objectives of policing are to:
- prevent, combat and investigate crime;
- maintain public order;
- protect and secure the inhabitants of the Republic and their property; and
- uphold and enforce the law.
The COVID-19 pandemic has placed extra strain on the resources of the Department in view of the extended mandate of the police to police the National State of Disaster Regulations. The police are expected to lead the law enforcement and operational plan work stream is led by the Department of Police and the SAPS plays a main role in it. The operational plan to enforce regulations includes activities such as conducting roadblocks, vehicle check points and visibility patrols. Vandalism and continued instability related to food and job security are specifically prioritised.
It is expected of the police to check on the movement of people and goods during the lockdown, proceed with investigations into crime, enforce the lockdown regulations and maintain safety standards for police officers as frontline workers. In this regard, the Department has to take the lead by ensuring the safety of all frontline police officers. This includes provision of personal protection equipment (PPE) to all officers and police stations around the country. In addition, the SAPS National Instructions provide for detained people to also be protected through de-sanitizing police vehicles, the charge offices and the detention cells. The additional procurement of PPE has implications on the ability of the SAPS to effectively carry out its mandate.
3. Analysis of Adjusted Budget on Programmes
3.1 Budget Vote 28: South African Police Services
The SAPS received a Main Appropriation of R101.7 billion in 2020/21. In nominal terms, the allocation increased with R5.02 billion (5.2%) in 2020/21 compared to the previous financial year.
The Special Adjustment Budget increased the Main Allocation with R3.7 billion, from R101.7 billion to a revised allocation of R105.411 billion, which is a nominal increase of 3.6%. The Department made virements of R1.136 billion to COVID-19 purposes, from Goods and services (-R379.5 million) and Payments for capital assets (-R756.5 million). This, together with the additional allocation of R3.7 billion totals a reallocation of R4.836 billion.
The table below provides an explanation of the budget adjustments. The SAPS reduced the Capital works budget by 22.6%. As such, the Department suspended spending on capital works projects for the remainder of the 2020/21 financial year. The Department also rescheduled capital works projects to the outer years of the Medium-term Expenditure Framework (MTEF).
Table 1: Explanations of budget adjustments
|
R’ thousand |
Downward revisions |
Reallocations |
2020/21 |
|
Total net change |
|||
|
Operational spending: Rescheduling and suspensions of spending on various goods and services due to the restrictions on economic activity. Additional allocation (R3.7 billion) provided to support the Department’s COVID-19 response, including personal protective equipment for police officials. |
-379,500 |
4,836,000 |
4,456,500 |
|
Operational spending: Rescheduling and suspensions of capital spending, specifically buildings and other fixed structures, machinery and equipment, and biological assets due to the restrictions on economic activity. |
-756,500 |
– |
-756,500 |
|
Total |
-1,136,000 |
4,836,000 |
3,700,000 |
Source: National Treasury: Adjusted Budget 2020
Table 2: SAPS Vote adjustments: Revised programme allocations
|
|
2020/21 |
Downward revisions |
Reallocations |
|
Increase/ Decrease |
|||
|
R thousand |
Main budget |
Suspension of funds(COVID-19 purposes) |
Virements from(COVID-19 purposes) |
Allocated to (COVID-19 purposes) |
Virements to (COVID-19 purposes) |
2020/21 |
2020/21 |
|
|
Total net change proposed |
Total Allocation proposed |
|
||||||
|
Programmes |
||||||||
|
Administration |
20,912,779 |
– |
-818,200 |
– |
- |
-818,200 |
20,094,579 |
-3.9% |
|
Visible Policing |
52,327,272 |
– |
-115,000 |
3,700,000 |
1,136,000 |
4,721,0002 |
57,048,272 |
+9.02% |
|
Detective Services |
20,624,159 |
– |
-132,800 |
– |
– |
-132,800 |
20,491,359 |
-6.43% |
|
Crime Intelligence |
4,403,531 |
– |
– |
– |
– |
– |
4,403,531 |
- |
|
Protection and Security Services |
3,443,292 |
– |
-70,000 |
– |
– |
-70,000 |
3,373,292 |
-2.03% |
|
Total |
101,711,033 |
– |
-1,136,000 |
3,700,000 |
1,136,000 |
3,700,000 |
105,411,033 |
+3.6% |
|
Economic classification |
|
|
|
|
|
|
|
|
|
Current payments |
96,876,077 |
– |
-379,500 |
3,700,000 |
1,136,000 |
4,456,500 |
101,332,577 |
4.6% |
|
Compensation of employees |
81,112,221 |
– |
– |
– |
– |
– |
81,112,221 |
|
|
Goods and services |
15,763,856 |
– |
-379,500 |
3,700,000 |
1,136,000 |
4,456,500 |
20,220,356 |
28.27% |
|
Transfers and subsidies |
1,497,689 |
– |
– |
– |
– |
– |
1,497,689 |
- |
|
Provinces and municipalities |
53,205 |
– |
– |
– |
– |
– |
53,205 |
- |
|
Departmental agencies and accounts |
50,975 |
– |
– |
– |
– |
– |
50,975 |
- |
|
Households |
1,393,509 |
– |
– |
– |
– |
– |
1,393,509 |
- |
|
Payments for capital assets |
3,337,267 |
– |
-756,500 |
– |
– |
-756,500 |
2,580,767 |
-22.66% |
|
Buildings and other fixed structures |
897,667 |
– |
-400,000 |
– |
– |
-400,000 |
497,667 |
-44.55% |
|
Machinery and equipment |
2,432,671 |
– |
-354,000 |
– |
– |
-354,000 |
2,078,671 |
-14.55% |
|
Biological assets |
6,929 |
– |
-2,500 |
– |
– |
-2,500 |
4,429 |
-36.09% |
|
Payments for financial assets |
– |
– |
– |
– |
– |
– |
– |
- |
|
Total |
101,711,033 |
– |
-1,136,000 |
3,700,000 |
1,136,000 |
3,700,000 |
105,411,033 |
+3.63% |
Source: National Treasury: Adjusted Budget 2020
- The Main Budget of the Administration Programme decreased from R20.912 billion to a Revised Allocation of R20.094 billion, which is a decrease of R818.2 million, or -3.9%.
- The Main Budget of the Visible Policing Programme increased from R52.327 billion to a Revised Allocation of R57.048 billion, which is an increase of R4.721 billion, or +9.02%.
- The Main Budget of the Detective Services Programme decreased from R20.624 billion to a Revised Allocation of R20.491 billion, which is a decrease of R132.8 million, or -6.43%.
- The Revised Budget of the Crime Intelligence Programme remained unchanged: Main Allocation of R4.403 billion.
- The Main Budget of the Protection and Security Services Programme decreased from R3.443 billion to a Revised Allocation of R3.373 billion, which is a decrease of R70 million, or -2.03%.
In terms of economic classification, the virements of R1.136 billion were made from:
- Payments to capital assets decreased by R756.5 million (-22.66%) comprised of:
- Buildings and other fixed structures: Decreased by R400 million (-44.55%)
- Machinery and equipment: Decreased by R354 million (-14.55%)
- Biological assets: Decreased by R2.5 million (-36.09%)
- Goods and Services decreased by R379.500
- Performance indicators
The 2020/21 SAPS APP identified 96 performance indicators, of which 27 are new indicators. Due to the COVID-19 pandemic, the annual targets of 16 key performance indicators were changed (reduced).
4.1 Programme 1: Administration
Table 2: Changed targets: Programme 1: Administration
|
OUTCOMES |
OUTPUT |
OUTPUT INDICATORS |
APPROVED TARGET 2020/21 |
PROPOSED TARGET 2020/21 |
|
A professional and capable SAPS: Ensure an effective and adequately resources policing capability in response to the demand. |
Modernisation of SAPS Network |
Number of identified digital radio communication infrastructure sites modernised and implemented |
45 high sites |
Adjusted from 45 to 3 High Sites |
|
Number of identified National Network Communication Infrastructure modernised and implemented |
||||
|
|
488 WAN sites |
Adjusted from 488 to 65 WAN sites |
||
|
A professional and capable SAPS: Sound Corporate Governance |
Inculcated culture of regulatory compliance and performance management |
Percentage audits completed in terms of the Internal Audit Plan |
100% (160) |
Internal audits adjusted from 160 to 153 |
|
Percentage inspections completed in terms of the approved Inspection Plan |
100% (309) |
Inspections adjusted from 309 to 231 |
||
Source: SAPS (2020)
The COVID-19 Pandemic had a significant impact on the targets for the Modernisation of SAPS Network. The SAPS reduced the planned 45 sites for implementation of the digital radio communication infrastructure to only three. The SAPS indicated that this is due to delays in the establishment of contracts, scheduling of bid specification meetings, advertisement of tenders and conducting site visits for individual procurement. Further factors include delays in implementation of radio infrastructure and construction of radio towers/masts and the delivery of imported radio equipment.
Similarly, the SAPS reduced the identification of National Network Communication (WAN) sites modernised and implemented from 488 to 65 sites. The SAPS indicated that there were delays in publishing and procurement, mainly due to a reduced personnel availability of SITA. The Information Technology Industry is not able to respond to contracts/bids. Establishment of new cabling contract is currently on hold as urgent procurement is prioritised.
4.1.1 Capital Works Programme
Payments to capital assets decreased by R756.5 million (-22.66%), of which the allocation to Buildings and other fixed structure decreased by R400 million (-44.55%). The decrease has a significant impact on the Capital Works Programme for 2020/2021 to 2022/23. The largest impact is on Focus Area 1: Police Stations in the 2020/21 financial year particularly in terms of site clearance and planning and design. However, the reduction of these targets are not reflected in the 2021/22 and 2022/23 targets in the Addendum. The SAPS should accommodate the downward adjustments on targets in 2020/21 over the medium-term, which are not apparent in the Addendum to the 2020/21 APP.
The reduction in the budget has a significant knock-on effect in the outer years of the MTEF. Of note is the reduction in the building of Police Stations in the next financial year (2021/22). The Department planned to build 10 Police Stations during 2021/22, which is reduced to the building of only one Police Station located in Riemvasmaak (NC).
The table below provides a summary of the changes made in the Addendum to the 2020/21 APP when compared to the 2020/21 APP.
Table 3: Changes to the Capital Works Programme
|
Focus Area 1: Police Stations |
Category
|
Number of projects |
||
|
2020/21 APP |
Addendum 2020/21 APP |
|||
|
Construction |
Site Clearance |
25 |
20 |
|
|
Planning and Design |
38 |
31 |
||
|
Execution |
10 |
10 |
||
|
Repair and Upgrading |
Execution |
14 |
10 |
|
|
Accessibility for persons with disabilities |
Execution |
49 |
49 |
|
|
Focus Area 2 |
Generators – Police Station |
Execution |
51 |
51 |
|
Focus Area 3 |
Air conditioners |
Execution |
224 |
224 |
|
Grand Total – Capital Works Programme |
413 |
395 |
||
Source: SAPS (2020)
The Planned Maintenance Programme remained unchanged in the Addendum 2020/21 APP.
4.2 Programme 2: Visible Policing
The Department changed 11 performance indicators in the Addendum, of which eight targets are in the Visible Policing Programme. The changed targets relate to feelings of safety in communities, crimes against women and children and an active citizenry. These are all crucial elements in the combatting of violent crime and community-orientated policing.
Table 4: Changed Targets: Visible Policing
|
OUTCOMES |
OUTPUT |
OUTPUT INDICATORS |
APPROVED TARGET 2020/21 |
PROPOSED TARGET 2020/21 |
|
The law upheld and enforced to support the stamping of the authority of the State: Improved feeling of safety in communities |
Improved regulation of firearms |
Number of stolen, lost and illegal firearms recovered |
Increase to 3 750 (1%) |
The target was reduced from 1% to 0.5% in the Addendum. Firearm recoveries performance updated to 4 204. Target adjusted to 4 225. The target increased due to the actual performance of the 2019/20 financial year |
|
SAPS firearms recovered |
Increase to 428 (10%) |
SAPS firearms recoveries updated to 459. Target adjusted to 5% increase (482) as opposed to 10%. The target increased due to the actual performance of the 2019/20 financial year. |
||
|
Application for new firearms licences finalised |
90% in 90 days |
Adjusted from 90 to 120 days |
||
|
Collaborative and consultative approach to policing Increased feelings of safety in communities |
Reduce levels of contact crime |
Percentage reduction in the number of contact crimes |
Reduce by 7.5% to 576 664 |
Target adjusted to 7.48% (slight reduction) The target increased due to the actual performance of the 2019/20 financial year. |
|
Collaborative and consultative approach to policing Responsive policing of GBVF |
Reduce violence against women and children |
Percentage reduction in the number of contact crimes against women (18 years and above) |
Decrease reported crimes against women by 7.6% to 168 517 |
Target adjusted from 7.6% to 6.9% reduction. The target increased due to the actual performance of the 2019/20 financial year. |
|
Percentage reduction in the number of contact crimes against children (below 18 years) |
Decrease reported crimes against children by 7.6% to 42 113 |
Target adjusted form 7.6% to 6.7% reduction. The target increased due to the actual performance of the 2019/20 financial year. |
||
|
Collaborative and consultative approach to policing Citizenry actively supporting the fight against crime. |
Increased police visibility |
Number of provinces in which the “community-in-Blue concept has been implemented. |
9 provinces by 31 March 2021 |
Community-in-blue concept, traditional policing concept and Safer Cities Framework commitment adjusted from “implemented” |
Source: SAPS (2020)
4.3 Detective Services
The 2020/21 targets (percentages) remains as initially committed to in the 2020/21 APP. Thus, the Addendum APP did not amend performance targets.
Of note is the exclusion of an introduction by the National Head of the Directorate for Specialised Investigations (DPCI/”Hawks”), compared to the 2020/21 APP.
4.4 Programme 4: Crime Intelligence
The Department changed several performance targets associated with Counter Intelligence measures instituted in the SAPS. This includes conducting security risk and vetting assessments within the SAPS. This outcome is important to reduce possible corruption in the SAPS.
Table 4: Changed targets: Programme 4: Crime Intelligence
|
OUTCOMES |
OUTPUT |
OUTPUT INDICATORS |
APPROVED TARGET 2020/21 |
PROPOSED TARGET 2020/21 |
|
Counter-intelligence measures instituted in the SAPS |
Network operations to infiltrate criminal groupings and gather intelligence |
Percentage of network operations successfully terminated |
65.07% (570 from a total of 876 network operations planned). |
Network operations target adjusted from 570 to 475 (The percentage target remains the same, but the identified number of operations were changed). |
|
Security risk and vetting assessments conduced within SAPS |
Percentage of security clearances finalised in the SAPS in relation to the total number planned. |
100% (1 154) |
Security clearances target adjusted from 1154 to 865 (The percentage target remains the same, but the identified number of operations were changed). |
|
|
Percentage of ICT security assessments finalised in the SAPS in relation to the total number planned. |
100% (3 160) |
ICT security assessments target adjusted from 3 160 to 2 370. (The percentage target remains the same, but the identified number of operations were changed). |
||
|
Percentage of mandatory physical security assessments finalised in the SAPS in relation to planned. |
100% (640) |
Physical security assessments target adjusted from 640 to 480 (The percentage target remains the same, but the identified number of operations were changed). |
Source SAPS (2020)
4.5 Programme 5: Protection and Security Services
The 2020/21 targets (percentages) remains as initially committed to by the SAPS. Thus, the Department did not change any performance targets.
5. Observations and Findings
Costs of Personal Protection Equipment (PPE)
The Committee raised questions on the pricing and costs associated to PPE, especially the price of the containers and hand sanitizers. The Committee requested the SAPS to provide an explanation for increased prices, especially for hand sanitizer. The Committee requested a breakdown of prices for such PPE per unit costs. The Committee, in raising this matter, was concerned that corrupt practices were present in the supply chain of such PPE.
Murder of police officials
Members questioned the SAPS on the number of police officers killed in the line of duty. The presentation was silent on such statistics and the Members wanted to know how SAPS was dealing with such circumstances.
Rural Safety
Members wanted the SAPS to explain if the Rural Safety Strategy was still relevant and implemented in rural communities given that there has been increased attacks on farmers in the last few weeks. According to one member, there was 11 attacks on farmers in one day and the Member wanted to know what the SAPS was doing about it.
Goods and Services budget: Purchasing of vehicles
The Committee questioned the fact that there has been cuts to the Goods and Services budgets and wanted to know how SAPS was going to purchase the vehicles that it requires, especially over the outer years of the medium term expenditure framework. Members wanted to know what the plan was for filtering such purchases into the main budget.
Target of Firearm Licensing process
Members noted that the target for processing firearm license applications has changed in the Annual Performance Plan and questioned what the reasons were for changing the performance target.
Capital Works
The Committee was not pleased that as far as Capital Works portion of the budget was concerned, as there was only provision for the building of one police station. In terms of the re-prioritised budget, the amount to Public Works has decreased by 22% and this was a huge cause for concerned. The Committee asked for an explanation.
Detective Services
The Committee raised concerns about the reduction of the Detective Services budget and noted that Detectives are over-burdened. The Detectives Services budget was reduced with R132.8 million (or 6.43%) and members noted that it was not acceptable and raised concerns over the investigation of crime.
Crime Intelligence
The Committee noted that the budget allocation for Crime Intelligence was not changed. In view of the fact that the investigation of crime must be intelligence-led, Members raised concerns that there was no increase in the programme, despite the increase in gender based violence cases during the lockdown. Of great concern was the fact that Crime Intelligence was responsible for vetting processes within the SAPS and that this would be negatively impacted as a result.
Recruitment of additional 7000 members
Members wanted to know how the SAPS was progressing on the recruitment of the additional 7000 officials that the Minister announced would be recruited.
VISPOL reduction of targets
The Committee expressed its concerns in view of the fact that the Visible Policing (VISPOL) programme was receiving an additional R3.7 billion in the adjusted budget allocation, but that it had revised some of its targets downward. This was especially concerning given that these targets included Gender Based Violence GBV) targets and that could not be acceptable. In addition, the FCS units were not well resourced and that the presentation did not talk to the resourcing of such units. Members urged the SAPS to review this situation given that GBV was a priority of government and asked the SAPS to provide reasons why it was changed.
Modernisation and digital radio communication
The Committee expressed its concerns regarding the huge decrease in the budget for the SAPS radio communication network. Given that communication is critical for effective policing, Members could not accept that the budget was cut so drastically and what the SAPS management was going to do about it. Members also questioned the situation with the State Information Technology Agency (SITA), given the problems experienced by the SAPS which was reported to the Committee in previous engagements.
Impact of COVID-19 pandemic on performance
The Committee expressed its concerns about the impact of the COVID -19 pandemic on the members of the SAPS as there were reports of stations having to close and the numbers of SAPS members contracting the COVID-19 virus was increasing. It requested a response from the SAPS in terms of how they are managing the situation.
SAPS response
The SAPS reported that they viewed rural safety as a priority and that they intended to respond to the farm murders taking place. They have also placed farm murders on the agenda of the Modus Operandi Centre.
The question with regard to the R4 billion allocation to the SAPS was that when it comes to visible policing, the SAPS will never have enough budget and therefore the reprioritization of the budget is a response to the strategic deployment of resources. This will help the SAPS responding to the safety of people.
As far as murder of police officers were concerned, the Department was reactivating the police safety strategy which provides a two-pronged response which talks to these murders. The strategy proposes intensification of investigations and many resources have been invested in the police safety strategy. Police management has also started to address the matters related to the COVID-19 infections of police officers and police stations. The number of infections have been increasing in the western Cape, Gauteng and KwaZulu-Natal provinces and there is a safety and contingency plan across the country to provide a response in case a station is infected until the decontamination process takes effect.
The SAPS is aware of the impact of the Capital Works budget creates a dependency and they are working on a response to deal with the building programme. The SAPS noted that they could not be continuing as normal and that they would have to provide direction with a rapid service delivery strategy. In order to deal with the shortfall of police stations, the SAPS are working with the Safer City to provide enhanced safety through technology visibility.
The SAPS reported that seven FCS units will be capacitated to provide a response to GBV and that it will influence the targets. According to the Department, the Department of Monitoring, Performance and Evaluation (DPME) advised them to look at the actual targets. In line with year-end results, after the police received the actual results, the initial increase was projected to a 1.5% increase, but the actual was 4% decrease. The SAPS did the adjustments, the percentage reduction was adjusted to 6.9%, as the numerical target was actually better and they have increased the numbers of cases. However, in order to provide a response, the Department is willing to revisit the figures.
The SAPS also reported that of the recent recruitment drive, 326 members will be added to the FCS units. The SAPS received 500 000 applications for the 7000 posts and they were at an advanced stage of assessment of the candidates. The Department is targeting reservists, public service employees from the internal environment, university graduates and new applicants. The COVID -19 pandemic interrupted the process. The SAPS announced that they will be targeting 3000 reservists and this will be completed by 1 October 2020. Another 500 posts will be advertised for re-enlistments, 300 cleaners will be employed from 1 September 2020 and 250 forensic workers will be employed by 1 November 2020.
As far as vehicles were concerned, the SAPS will procure the amount of vehicles equal to the baseline. There was no reprioritisation of the Crime Intelligence budget as they can continue with their work.
The SAPS have procured sanitizer in line with protocols of the World Health Organisation and the Department of Health and they have stock for the next six months. This is in line with the fact that the detainees must also be supplied with PPE, buildings, vehicles and furniture must be de-contaminated. The vehicles are sufficient for the Department and 38 vehicles were seconded to the Organised Crime Unit in Durban. E-vetting is assisting the crime intelligence environment as they want to capacitate Crime Intelligence.
The Minister of Police concluded the SAPS responses by indicating that 6391 police officers are members infected with COVID-19 virus and 1600 have recovered. The Department has lost 36 officers and are expecting further problems as the post-COVID-19 world is still a long way off. Three provinces, including the Western Cape, Gauteng and KwaZulu-Natal are bearing the brunt of the pandemic.
As far as GBV is concerned, the targets will be revised and with the unbanning of alcohol on 1 June 2020, there has been an increase in violence. Almost everyone who now engages in GBV has been arrested.
Lastly, there have been several meetings between the Ministers of Police and Communications to address the SITA problem and it was reported that the matter was work in progress. The municipalities handled land invasions and the SAPS do not lead on the matter.
6. Recommendations
The Committee recommends the following:
- The Committee recommends the SAPS provides a breakdown of personal protection equipment and make it available to the Committee.
- The Committee recommends that the SAPS provide an alternative plan for the building of police stations.
- The Committee recommends that the SAPS revises all its targets for Gender Based Violence and increase it to reflect the priority in line with the President’s priority including those in the Visible Policing Programme dealing with violence against women and children.
- The Committee recommends that the SAPS provide details how the processing time for new firearm applications can change from 90 to 120 days, without a change in the Police Act.
- The Committee recommends that the SAPS provides a plan to ensure that the Detective Services programme achieve its targets, despite the shortfall.
- The Committee recommends that the SAPS finalises a MOU with SITA with respect to the delivery of ICT services.
- The Committee recommends that the SAPS monitors the health of SAPS members with a view to reducing the spread of COVID-19 pandemic amongst police officers and at police stations.
- The Committee recommends that SAPS provide feedback on the implementation of the rural safety strategy and the funding thereof.
The Portfolio Committee on Police, having considered the adjusted budget, recommends approval of the Adjusted Budget Vote 28.
Report to be considered
Documents
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