Quality of Democracy Audit / Policy Memo - Argentina

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Writing Effective Policy Memos What is a policy memo?

A policy memo is a document that provides analysis and/or recommendations for a particular audience regarding a particular situation or problem. A well-written policy memo reflects attention to purpose; it is well organized; and it has a clear, concise style.

Determining and responding to your audience

In most cases, you will know the audience for your work because (1) you have been hired by that individual or organization or (2) your instructor provides that information to you. Think carefully about the needs and expectations of your audience. For example, if your audience is an elected official seeking analysis on a highly technical matter, you should generally assume that the official lacks substantial technical expertise. You will need to define technical terms and provide enough background about the situation you are discussing that such a “lay” audience can grasp your arguments. On the other hand, if you are writing for a technically trained audience, you will waste time and energy providing background information that your readers already know.

Organizing an effective policy memo

Introduction

One distinguishing characteristic of a policy memo is that a summary of the document’s conclusion(s) and recommendation(s) is placed right at the beginning of the memo. Remember that the purpose of the document is generally to provide your audience advice about a particular decision, project, or policy stance. Thus, you open the memo by summarizing the problem or situation about which you are writing, and by providing a very brief summary of the conclusions/recommendations you have reached during your analysis. The rest of the memo is designed to support the conclusions or recommendations you present.

Background

Keeping in mind that different audiences need different amounts of background information (see above), follow your introduction with a concise summary of any historical or technical that your audience needs to understand the arguments you are building. (It may be that no background information is needed at all.)

Supporting arguments or analysis

Once you have set the stage for your audience, show how this information leads logically to the conclusions/recommendations you have provided.

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Style and format

Your ideas will be no more meaningful to the reader of your memo than you are able to make them. Meaning is not just embellished by style; rather, the two must function together. Muddled writing reflects hazy thinking. Your prose should be simple, clear, and easy to read; you will confuse, not impress, your readers with sophisticated vocabulary. Your reader should be able to describe your conclusions and the general arguments you used to reach them after only one reading of your memo.

Some tips on achieving an effective writing style:

(1) Choose the simplest words available to express your ideas. When discussing technical information, avoid the use of jargon--or at least define your terms clearly.

(2) Make your sentences “active”; avoid phrases such as “there are” or “it is.”

(3) Use one paragraph to develop one idea or argument. Make that idea or argument explicit within the first one or two sentences of the paragraph.

(4) PROOFREAD CAREFULLY. Don’t distract your readers from the content of your memo with poor spelling or grammar.

The format of the memo should be as follows:

(1) Memos must be typed on 8.5 X 11” or A4 paper with margins of one inch on all sides.

(2) Paragraphs should be single-spaced and should be separated by a double space.

(3) You may use any standard conventions for the layout of your memo, including numbering, bullets, indentation, etc. Do address the memo to your audience at the top of the page. See the attached sample for a suggested layout.

Length

The length of your policy memo assignment will be announced in class. Do not exceed this length limit! I am enforcing this rule for several reasons:

(1) I assume that you will continue to write persuasive documents for clients and/or colleagues in the future. Like you, most of these people are busy. They rarely have time to review lengthy documents; these generally wind up unread in a filing cabinet or waste basket. I’m hoping to help you craft documents that are concise and of use to your clients or colleagues.

(2) Confining yourself to a particular page limit encourages careful editing, establishing priorities, and paring your arguments down. In general, these practices also improve the flow and impact of your writing.

(3) Tightly written policy memos have a much better chance of influencing others toward a particular point of view.

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M E M O R A N D U M

TO: Dr. Jane Doe, President Commission for Economic Sustainability

FROM: David R. Ortiz, Analyst

DATE: 7 October 1995

RE: Fuelwood management in Country Central

Introduction

The situation regarding fuelwood availability in Country Central is not yet at a crisis stage. Forests and arable land are readily available for use by the people. Deforestation is minimal compared to our neighboring counties. Yet economic conditions force the majority of the fuelwood to be collected illegally. I propose three major reforms to alleviate the problem of illegal fuelwood collection. First, we should offer individual communities small plots of forest for tenuring. Second, we should establish a network of regional fuelwood management offices to monitor the illegal trade of fuelwood, to encourage fuel efficiency, and to offer technical assistance for the sustainable use of tenured forests. Third, a system of forest plantations should be developed to ensure future fuelwood supplies.

Current land tenure situation in County Central Residents will continue to collect fuelwood illegally until they are otherwise guaranteed a supply. Land tenure offers the beneficiaries a direct reimbursement for their efforts. A number of key points support a system of land tenure:

(1) The rural population does not have a financial means to purchase land at this time. Foreign ownership as well as ownership by the wealthy of County Central could lead to limited access to forests for the poor. This maldistribution of forest resources could have long term economic effects.

(2) Land ownership means power. With recent government changes, we cannot afford to unleash this power to the people at this time. Actual ownership of the land should remain in the hands of the government.

(3) A system of tenure allows for better government regulation over changes in the forest

resource base. Regulation of private forest lands with our limited work force would be impossible.

In lieu of efficiency concerns, a system of community tenured regions would better accommodate current circumstances. The state forest should be divided into regions, each village or community having an assigned region. The concept of a community region is more realistic than individual tenure due to the unmanageable number of technicalities which would be encountered. Ecological impacts are location specific. These regions should be monitored by regional fuelwood management offices.

Regional fuelwood management offices

Management of the harvests of fuelwood will require local regulation. Your proposal should include the establishment of regional fuelwood management offices to facilitate the transition

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from an illegal market to legal and organized cooperation. The regional offices will have the following roles:

(1) Report and regulate the flow of illegal fuelwood to the central government office so that regulations can be modified for improved efficiency;

(2) Instruct villagers on maximizing use of fuelwood products by encouraging use of efficient stoves and kilns;

(3) Instruct villagers on proper forest management for long-term goals of sustainability. This instruction could also include the role of proper management in erosion control and watershed protection.

The regional fuelwood management offices should include a number of representative groups. Involvement of the local community is a requirement for success. Local farmers and leaders know the region, its customs and its people. In addition, an administrator from our government should be available to act as a liaison and to provide a political update on the situation. Some technical expertise will be required.

Future issues

Our government must plan for the future energy needs of County Central. The World Bank has proposed a hydroelectric power plant which would supply one quarter of current energy needs. This project should be carefully assessed. Special consideration should be given to ecological impacts of the building of the plant, dependence upon foreign technical expertise, and implications for the debt situation. I am skeptical of its success because of the history of failures of these types of development efforts.

Alternatively, our east coast has tremendous excess of arable land which can be developed for forest energy. Long-term planning should maximize use of this land by developing forest plantations. Coupled with these long-term plans for forest plantations should be a program for infrastructure changes which can assist in transporting the fuelwood to villages throughout the county.

Implementation

The creation of regional fuelwood management offices and the allocation of forest regions will require some time. Due to the lack of other available energy sources, it is recommended that residents be permitted to continue collecting fuelwood as previously practices until the fuelwood management program is implemented.

Implementation of these reforms can only take place with your assistance in quality legislation. Outlined above are three major reforms to improving fuelwood management in County Central: development of a community land tenure program, establishment of regional fuelwood management offices, and development of forest plantations along the east coast. These reforms offer the most viable solutions to fuelwood management.

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Ensuring Continuity in United States- El Salvador Relations Summary On March 15, Mauricio Funes, a former journalist from the guerilla movement-turned leftist political party Farabundo Martí National Liberation Front (FMLN) narrowly won the presidency of El Salvador, marking the first time in the country’s history that the Left was able to capture the presidency. Funes worked hard during the campaign to convince voters that he was a committed democrat who represented “safe change” despite representing a party that has traditionally been led hard-line Marxist former guerilleros some of which have questionable democratic credentials. The main challenge faced by Funes will be to keep his campaign promises to create a fairer and more socially-oriented Salvadoran state without alienating the country’s business community. Funes will have to strike a delicate balance between pleasing his party’s establishment and radical base, which have been waiting their entire lives for the day when the Left would gain control of the state, maintaining the support of moderate voters whose discontent with the results of the most recent presidential administrations of the right-wing ARENA party led them to support who they believed was a new kind of FMLN candidate, and not antagonizing the country’s conservative business class, whose investment is necessary in order to prevent further contraction during an already difficult economic juncture.

This fundamental challenge will extend to Funes’ foreign policy. Important elements within his party will want him to develop closer ties with anti-American Leftist leaders, namely Venezuela’s Chavéz, Cuba’s Castro and Nicaragua’s Ortega. However, the majority of El Salvador’s people want continuity in the country’s foreign policy, particularly in regard to the country’s historically-close ties with the United States. El Salvador is culturally and economically tied to the United States and cannot afford to be on bad terms with the country where 2.5 million Salvadorans (out of a total of 8 million) live. The United States is by far the country’s largest source of exports, imports, foreign investment and remittances. El Salvador even uses the U.S. dollar as its currency. Thus, to be an effective president, Funes will have to convince U.S. officials that his administration will maintain continuity in U.S.-El Salvador relations. The purpose of this memorandum is to outline the main issues in the bilateral relationship and highlight the steps Funes can take to convince Washington that he truly does represent “safe change” and does not intend to jeopardize the bilateral relationship. Brief History

In October 1980, under influence from Fidel Castro, five revolutionary factions united to form the FMLN and launch a revolutionary armed struggle. From 1980 to 1992, FMLN waged a violent campaign against the U.S.-backed military, the traditional ruling class, and moderate reformists. By the time the war officially ended with the signing of the 1992 Peace Accords, the country had been devastated and approximately 75,000 Salvadorans had lost their lives. It was during the conflict that the first wave of Salvadoran immigrants fled to the United States, primarily to the cities of Los Angeles and Washington DC, which continue to be home to the bulk of the country’s Diaspora.

Upon the war’s conclusion, the FMLN entered the formal political arena as a political party. Though the FMLN succeeded in consistently winning a substantial share of legislative seats and came to dominate the San Salvador local government, it had never – until last month – won the country’s presidency.

Conservative elites coalesced behind the center-right ARENA, a pro-business party that has consistently pursued close ties with the United States. ARENA’s monopoly on the presidency raised questions regarding the consolidation of the country’s democracy. According to some definitions, a

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consolidated democracy would require the successful transition of power between two different political parties.

President Francisco Flores (1999-2004) adopted the U.S. dollar as the country’s currency, negotiated the CAFTA-DR trade agreement with the United States and even sent troops to Iraq. Outgoing President Antionio Saca (2004-2009) secured the passage of CAFTA-DR and maintained his party’s strong pro-U.S. stance by co-operating with it on internal and regional security issues, as well as continuing his predecessor’s policy of maintaining Salvadoran troops to Iraq until the end of last year. Saca was an unpopular president by Salvadoran standards as a result of the country’s lackluster economic growth and growing domestic concerns over internal security, particularly the rise of youth gang activities and urban violence.

On the eve of this year’s presidential election, 46 Republican members of the U.S. Congress sent a letter to President Obama expressing deep concerns about the FMLN’s violent revolutionary past and its ties to Colombia’s FARC guerrillas and Venezuela's Chávez. Members of Congress warned that if the FMLN aligned itself with sponsors of international terror like the FARC, such actions would have an adverse impact on remittance flows and the renewal of Temporary Protected Status (TPS) for Salvadoran immigrants in the United States in 2010. Despite these pressures, the Obama Administration expressed impartiality toward the election's outcome.

Funes won with 51.3 percent of the vote, while Avila received 48.70 percent, a margin of less than three percentage points. ARENA lost by less than 70,000 votes out of the 2.6 million ballots cast. International observers certified the election as “free and fair.” Vote counting moved swiftly and within five hours of the polls closing, the outcome was known. The loser, ARENA’s Rodrigo Avila, conceded defeat the evening of the elections. The Funes government will assume office on June 1. Avila and President Saca have promised a constructive relationship during the transition.

Funes worked tirelessly to center the campaign on the bread-and-butter issues of economic growth and poverty, where he possessed a clear advantage over ARENA, whose recent track record has left much to be desired. Funes spent the latter part of the campaign on the defensive, dodging attacks by Avila and attempting to make clear his intention to govern pragmatically, respecting democratic institutions and private property, and maintaining close ties with the United States. Funes has repeatedly publicly promised to maintain the U.S. dollar as the country’s currency and rejected the possibility of withdrawing from CAFTA-DR.

Facing what at first seemed would be a crushing defeat, Avila centered his campaign on character issues, raising questions about how an eventual FMLN presidency would govern, at times claiming Funes would turn out to be little more than a puppet controlled by his party’s radical wing. Whereas Funes has shunned any dealings with Chávez, many FMLN mayors do receive subsidized oil from Venezuela. The name of one of its congressmen surfaced in a computer recovered at the camp of Raúl Reyes, a leader of Colombia’s FARC guerrillas killed a year ago. Partly to blame for FMLN’s slide in the polls in the run-up to the election was Funes’ appointment of Salvador Sánchez Céren, an aging for guerillero, as Vice-President. Tensions between Funes and party officials occasionally flared up during the campaign.

Funes narrow margin of victory and lack of a majority in the legislature provide him with a limited mandate. Furthermore, the dramatic reduction in Funes’ lead in the weeks prior to the election (early in the campaign he held a double-digit lead and was expected to win comfortably), shows the success of ARENA scare tactics. This confirms that that the majority of Salvadorans, though yearning for political change, have little desire for radical policies. They backed Funes because he promised “safe change” and because they were unhappy with the results of ARENA’s most-recent administrations. El Salvador’s population has not undergone an ideological shift, it simply elected a new government that it found more attractive than the party that had ruled for the past two decades. This outcome and ARENA’s gracious recognition of its electoral defeat should be taken as signs that El Salvador’s democracy is maturing and inching its way toward consolidation.

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Main Issues 1) Ensuring Continuity in U.S.-El Salvador Relations: The main challenge faced by Funes will be to convince the United States that he is what he says he is, a responsible and committed democrat who, though perhaps more left-leaning than some U.S. officials would like, does not intend to disrupt the historically good relationship the two countries have enjoyed over the past two decades. The desire for continuity in the bilateral relationship needs to stressed during bilateral meetings and, if necessary and possible, through private lobbying.

 Between now and his swearing in on June 1, Funes needs to do everything in his power to put to rest U.S. fears that he plans to take his country down the path toward populist authoritarianism and instead stress his social-democratic credentials and intention to govern from the center-left much like Brazil’s Lula, who he claimed to admire. As these fears are put to rest, Funes should begin to gradually move beyond pursuing the acceptance of the Obama administration and begin to earn its trust. If this succeeds, he should seek to expand his “circle of friends” to include some members of Congress with the intent of creating a counter-weight to potential enemies such as the Republicans who signed the letter mentioned above. Simply put, the United States is too important for Funes to allow any misunderstandings and misconceptions about his motives to sour the relationship.  Above all, Funes should challenge claims of a “Left Turn” in El Salvador and instead stress continuity. He should stress that his country’s voters, much like voters in the United States and other democracies, chose to change the party in office and that this is a natural part of democracy. That he is to the left of previous governments does not mean that there has been any kind of fundamental shift in the views of the Salvadoran people. It simply means they preferred his message to that of the other candidate and did so by a narrow margin. There is no reason to expect a dramatic shift in the country’s relations with the United States. He should stress that one of the reasons why FMLN was able to win the presidency this time was that the party has matured and become more moderate, having learned from previous mistakes and defeats that the Salvadoran people are not interested in radical ideologies but rather in effective and transparent governments that will deliver economic growth and jobs.  Funes should continue to stress his message of responsible change. As in the past, he should stress that he 1) intends to modernize the country’s institutions and strengthen the rule of law as these are the actions needed to increase growth and reduce the need for immigration, 2) will not to seek alliances with Latin American heads of state that could jeopardize El Salvador’s vital relationship with the United States, and 3) will not repeal dollarization and CAFTA as these would scare away investment that is vital for achieving growth, which in turn is the most effective way of reducing poverty, which is ultimately his goal.  Funes must make it clear that he is not an ideologue but rather a pragmatist and a committed democrat who wishes to strike a better balance between the state and the market, a message that is likely to carry much weight given the presumed causes of the current global economic crisis. He should stress his campaign promise to improve tax collection with the goal of using tax funds to finance initiatives that will create new jobs for returning immigrants and promote rural development. Funes should stress that poverty and exclusion are the enemy and that the United States is part of the solution.  Funes must assure U.S. officials that what he seeks is continuity in his country’s relationship with the United States. This, however, does not mean he will not adopt a foreign policy that is more independent from the United States than that followed during the ARENA administrations. He must insist that a country can remain a “trusted friend” of the United States while at the same time pursuing an independent foreign policy that may include accepting aid from Venezuela and

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closer ties to Cuba. After all, Costa Rica and the Dominican Republic, both steadfast allies of the United States, had, up until recently, benefited from subsidized Venezuelan oil.

2) Immigration: El Salvador is closely linked to the United States through a 2.5-million strong Diaspora that, through remittances, now plays a central role in the country’s economy. However, as a result of the ongoing economic crisis, remittances are expected to decrease by as much as 8 percent this year. The presence of Salvadoran migrants in the United States has been facilitated by the extension of Temporary Protected Status (TPS) for Salvadorans until September 2010. Given that this deadline is approaching, the resolution of TPS status for Salvadoran nationals will become an increasingly imperative consideration for the Salvadoran government. The deportation of Salvadoran gang members to El Salvador by the United States is the principal cause of El Salvador’s current youth gang (mara) problem. It is in the interest of El Salvador to continue to cooperate with the United States to tackle the gang problem.

 Temporary Protected Status: Salvadoran nationals living and working in the United States have benefited from legal protection under TPS. Most recently, TPS was extended until September 2010. Though TPS provides temporary protection, it is not a legal stepping stone for Legal Permanent Resident status. El Salvador continues to be interested in additional extensions to TPS and, ideally, a comprehensive reform of U.S. immigration policy that will allow beneficiaries of TPS to permanently establishment themselves as legal residents of the United States.  Maras (Youth Gangs): U.S. deportation of criminals back to El Salvador has become a key point of contention in both migration and security-related discussions. Recently, much attention has been given to the deportation of gang members to El Salvador and other Central American nations. The problem has centered on the lack of communication between the U.S. officials and the governments of the countries to which criminals are deported. Often gang members are deported without giving their receiving countries sufficient warning, thus allowing them to easily assimilate into the Salvadoran gang networks. Hence, efforts to monitor these gang members as they cross transnational boundaries should be a central focus. Gangs such as Mara Salvatrucha were initially created in the United States and now present a significant internal security threat to El Salvador. It was only after a wave of criminal deportations to Central America that these gangs developed a Central American presence. According to recent estimates, as many as half of gang members in Salvadoran prisons are U.S. deportees. Given this background, recent moves have been made to increase communication between the United States and El Salvador in regards to criminal deportations. Both the Central American Fingerprint Exploitations Initiative (CAFÉ) as well as the Electronic Travel Document System are designed to help track criminals once they reach Central America.

3) Economic Development and Trade Initiatives: Since the end of the civil war, subsequent ARENA administrations implemented reforms that dramatically transformed El Salvador’s economy. It was hoped that these reforms would jumpstart growth and thus create jobs and reduce poverty. The adoption of the U.S. dollar as the national currency and the implementation of the CAFTA-DR trade agreement with the United States have been the most dramatic recent reforms. Despite these reforms, growth over the last decade has been sluggish by regional standards. Discontent with the country’s economic performance was one of the main reasons behind Funes’ electoral triumph. Though critical of dollarization and CAFTA-DR in the past, Funes has made clear that he has no intention of reversing them. Future economic growth is expected to depend on the success of initiatives aimed at modernizing the country’s infrastructure, promoting non-traditional products, and linking Salvadoran products to foreign markets.

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 CAFTA-DR: Under the Saca administration, El Salvador became the first country to both sign and implement the CAFTA-DR. El Salvador has actively sought U.S. assistance aimed at helping it develop the capacities that will allow it to take full advantage of the agreement’s provisions. U.S. bilateral aid initiatives in the country have been broadly focused on assisting in the achievement of these goals. Friendly relations with the United States are crucial in keeping these programs going. Though critical of CAFTA-DR, Funes has insisted that it will honor the agreement and not seek to repeal it. It is in his interests for the United States to go ahead with initiatives aimed at improving El Salvador’s ability to benefit from the agreement.  Millennium Challenge Account: El Salvador’s $461 million Millennium Challenge Compact is the most significant recent economic development in terms of bilateral aid. Signed in December 2006, the agreement is centered mostly on the development of the country’s impoverished northern region. The Human Development Project ($95.1 million) concentrates on increasing access to formal and informal education in the northern region, as well as increasing access to and the quality of sanitation and water. The Productive Development Project ($87.5 million) is designed to foster local business ventures, especially among poor farmers and micro- enterprises. The project also encourages the development of local banks and non-bank financial institutions with the goal of fostering a more efficient use of economic resources. The Transportation Project ($233.6 million) aims to address the region’s physical isolation by investing in paving most of the northern region’s roads.  Development Aid: The direction of USAID’s ongoing aid to El Salvador has been adjusted to reflect the goals of the MCA compact. According to USAID, current development aid is concentrated on three sectors: ruling justly, economic freedom and investing in people. Through “Ruling Justly,” USAID seeks to promote rule of law, reduce corruption, improve judicial systems and professionalize political parties. These goals are seen as contributing to the consolidation of El Salvador’s democracy, which is in turn expected to improve long-run economic prospects. Through “Economic Freedom,” USAID seeks to increase the country’s trade capacities. These programs aim to increase access to financial services, support the creation of jobs in new industries, focus on small and medium business development and promote laws and policies that improve the country’s business climate. Finally, through “Investing in People,” USAID seeks to improve social and health conditions. Among other goals, programs in this category also seek to decentralize the health system, improve reproductive health standards and promote HIV/AIDS awareness and prevention.

4) Internal and Regional Security Issues: El Salvador’s continued economic and political progress has been hampered by the increasingly difficult internal security conditions. The United States has taken an important role in promoting anti-gang efforts throughout Central America, particularly in El Salvador. In 2007, then-Attorney General Alberto Gonzalez announced the development of a comprehensive anti-gang initiative. El Salvador’s status as a transit country in the South to North narcotics trafficking chain is also a flashpoint of the bilateral relationship. It is in El Salvador’s interest to continue these projects. Failure to substantially improve citizen insecurity was one of the factors responsible for outgoing President Saca’s low approval ratings and played a role in bringing about Funes’ victory.

 Anti-Gang Initiative: In February 2007, the United States and El Salvador launched a joint anti-gang initiative. The initiative aims to achieve four central goals: 1) enhancing enforcement of anti-gang laws, 2) facilitating apprehension of fugitives though the use of shared information databases, 3) training of Salvadoran police by U.S. officials, and 4) crime prevention. As part of this initiative, the United States is assembling a Transnational Gang Unit (TAG) that will consist of members of the FBI and El Salvador’s Policia Nacional Civil. In addition, the United States

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will continue its support of the International Law Enforcement Academy in San Salvador. This joint initiative is designed to support existing anti-gang and violence initiatives in El Salvador, such as “Operación Mano Dura,” which sharply increased punishments involved in gang activity and leadership. For its part, the Salvadoran government has tightened its gun laws, increased border patrol cooperation with Guatemala, and supported U.S. ICE’s “Operation Common Shield,” which seeks to improve cooperation in the apprehension of transnational criminals. It is in El Salvador’s interest to continue working closely with the United States to combat criminal gangs.  Human Rights Concerns: It must be noted that there have been some criticism aimed towards the Salvadoran government’s use of “Operación Mano Dura.” According to concerned sources, the Salvadoran government has utilized its extra-judicial powers in this area to imprison Salvadoran youths who, despite appearance, are not, in fact, gang members. These concerns also tie into other concerns regarding the lack of effective rule of law and the weakness of the Salvadoran judicial system. Taking steps to address these concerns and stressing his government’s commitment to human rights could be beneficial for Funes.  Drug Trafficking: El Salvador is a transit country mainly cocaine and heroin. Increased gang activity has contributed to rising levels of narcotics trafficking in the country. In response to rising levels of narcotics trafficking, El Salvador participates as a “Forward Operating Location” for trafficking monitoring. As a FOL, El Salvador serves as a central point for tracking and interception of inter-American narcotics shipments. At different times in recent years, the government of El Salvador, along with the U.S. Department of Defense, the U.S. Coast Guard, and Guatemala, has conducted maritime efforts to disrupt trafficking efforts along the Central American coasts. In addition to fostering regional anti-narcotics initiatives, U.S. efforts are also designed to increased internal governing and enforcement capacities in El Salvador, as well as promote drug prevention and awareness programs in local Salvadoran communities.  Merida Initiative: As a Central American country, El Salvador is eligible to receive funds under the Merida Initiative anti-narcotics and security cooperation plan. During last week’s visit to the region, Vice-President Biden announced that the United States would increase the amount of Merida Initiative funds available this year to Central America to $110 million (from $60 million). How these funds will be divided and administrated is not yet clear.