Participants
Names and roles follow the agenda and draft minutes; where the dialogue file labels a person differently, the label is noted. Wards are as each speaker gave them.
| Name | Role | Participation |
| Michael Petrin | Vice Chair; presided | Added items 6 (NHSBA resolutions) and 7 (clerk coverage); had the remote member identify who was with him; reopened citizens’ comments after the finance items; asked why health insurance was still being paid for people who had left; stated that the earlier tax rate “was improperly calculated”. Rendered “Michael patron” in the roll calls. |
| Heather Whitney | Chair | Absent. Named by Angell as an authorized signatory as chair. |
| Arlene Hawkins | Member; Policy Subcommittee chair | Moved the nonpublic session, the O’Neil and Rogers appointments, publication of the compensation letters, and adjournment; seconded the NHSBA motion; asked of the meal agreement, “Board approve that?”; presented the policy package. Recorded the nonpublic-session form. |
| Candace Crawford | Member; Finance and SRVRTC Subcommittee chair | Seconded the nonpublic motion and moved the return; moved the policy package, the DAF revision and the NHSBA resolutions; asked who the meal agreement was with and whether it was valid; had it stated that no fund balance carried forward. |
| William “Bill” Madden | Member | Pressed on the psychology interns’ hiring and pay; reported the whistleblower-law posting was still not done; raised an audit report “that we never saw”; warned the superintendent search was behind. |
| Loren Howard | Member; NHSBA delegate | Participated by video (“Lauren Howard” in the transcript); answered each roll call; explained the NHSBA resolutions vote and that he would attend on October 25. |
| Noelle Kronberg | School Board Clerk | Absent (maternity leave). Angell called the roll. The board discussed a transcriber at $300 per meeting. |
| Kerry Kennedy | Interim Superintendent | Gave the superintendent’s report: the Bluff move, the Concord loan hearing, a lumber donation, the Henry suspension notice, the HR resignations and an HR audit, the interim CMS principal, the eighth-grade teacher, and the compensation letters. |
| Matt Angell | Senior Comptroller / Interim Business Administrator | Called every roll; gave the financial update, the $1.9 million deficit projection, the meal agreement, the signature authorizations and Positive Pay, and the MS-25 / DOE-25 and tax-rate estimate. “Matt Angel” in the draft minutes. |
| Jessica McCleod | Assistant Director for Student Support Services | Presented on the school-psychology interns. Spelling per the draft minutes; she introduces herself as “Jessica McLeod” and the dialogue file labels her “Jessica McCloud”. |
| Jeff Small | Director of Technology | Present per Kennedy (“Mr. Small is here”); no attributed speech. |
| Molly Tremblay | Citizens’ comments — Ward 1 | Thanked Angell; described families without food; urged the board to exhaust every option before raising the tax rate “by even 1%”. |
| Sherry Williams | Citizens’ comments — Ward 3 | Spoke twice, on the emotion behind the tax question and, at 1:55:41, summarizing what a homeowner would take away. The approved December 3 minutes thank a Sherry Williams for producing minutes while the clerk was on leave; the record does not say whether that is the same person. |
| Courtney Porter | Citizens’ comments — Ward 1; school social worker | Invited families in need to contact the district’s social workers. |
| Chris Cogswell | Citizens’ comments — Ward 3 | Thanked staff; argued for training local people rather than hiring outside candidates. |
| Kathy Savage | Citizens’ comments — ward not stated | Asked about fiduciary responsibility and annual audits. |
| Wayne Hemingway | Citizens’ comments — Ward 1; state representative and city councilor | Reported the Concord hearing on the revolving loan; “This was misuse of of monies within this district.” |
| Anthony Emanuel | Citizens’ comments — Ward 3 | Asked Angell about unexplained withdrawals; demanded the books be opened. |
| Unidentified state representative | Citizens’ comments | Name not intelligible in the transcript. Reported the loan-fund vote postponed to January at the earliest; asked at 1:49:40 how the meal contribution works. |
| Dave Larson | Citizens’ comments — Ward 2 | Asked the board to publish raw budget data. |
| “Stephen” | Citizens’ comments — Ward 2 (surname not given) | Recalculated the meal contribution at about $13,500 a year. |
| Unidentified public commenters | Citizens’ comments — Ward 3 and one ward not stated | One (Ward 3, name garbled) praised the board’s effort and the new website; another, at 1:51:35, pressed on why the district’s psychologists are not billable to Medicaid. |
Named on the record but not heard: Mary Henry (former business administrator, subject of the suspension notice); Patrick O’Hearn and Samantha Miller (HR, resigned); Chelsea Weatherford (acting interim HR manager; “Miss Chelsea while the first” in the transcript); Jennifer O’Neil (appointed interim CMS principal; “O’Neill” in the transcript, “O’Neil” in the draft minutes); Kaley Rogers (appointed eighth-grade social studies teacher; “Kaylee”, “Candy” and “Katie” on the recording, “Kaley” and “Haley” in the draft minutes); Michael Koski (Assistant Superintendent, on the roster); Heidi Sprague (Medicaid billing); and Jim O’Shaughnessy, who presented at the Senate hearing with Kennedy and Angell (the draft minutes’ “Mike O’Shaughnessey” was corrected on approval). Sixty rows of the dialogue file are labeled Unidentified.
Agenda
Items as posted in “CSB Agenda 10.15.25 (1).pdf”, with the time each was taken up and its disposition per the recording and the draft minutes.
| Taken up | Item | Agenda text / disposition |
| 0:00:02 | I. Call to order; Pledge | Petrin presiding. Roll by Angell at 0:00:59: Whitney absent; Petrin, Hawkins, Crawford, Madden present; Howard by video, identifying his room at 0:01:13. |
| 0:01:31 | II.a Consent agenda | “Amendments and Final Approval of board agenda” (agenda): items 6 and 7 added. “We don’t have any meeting minutes tonight” (0:02:08); manifest “Not addressed at this time” (draft minutes). Adopted on no objection at 0:02:32. |
| 0:02:32 | II.b Citizens’ comments | “Please reference CSB Policy BEDH” (agenda). Ten speakers from 0:02:56 to 0:27:21: tax rate, fiduciary duty, audits, the revolving loan, raw data, families in need. |
| 0:27:26 | III.1 Nonpublic session, “RSA 91-A:3,II (3)” on the agenda | Hawkins at 0:27:42: “We move into nonpublic session under RSA 91. Dash a colon three comma two. Parentheses three.” Crawford seconded (draft minutes); roll call from 0:28:12, all yes. Return moved by Crawford, seconded by Madden (0:29:07); roll call from 0:29:14, all yes. No decision recorded. |
| 0:29:28 | III.2 Superintendent’s report | “Update on SAU Staffing including Director of Student Services Psychology Intern Update” (agenda). McCleod presented from 0:29:57. Hawkins moved the interim CMS principal at 1:17:25; Petrin seconded; roll call from 1:18:20, all yes. Rogers appointment moved at 1:22:00; roll call from 1:22:33, all yes. Motion to make the compensation letters public at 1:27:02; Crawford seconded; roll call at 1:28:50, all yes. |
| 1:32:00 | III.3 Executive summary financial update | “Mr. Angell, Senior Comptroller Including highlighted expenditures” (agenda). Deficit projection, refrigerators, meal agreement, signatory authorizations, Positive Pay: “As you consensus” (1:39:48); no motion. |
| 1:39:50 | III.4 MS 24, DOE 25 EOY balance, estimated tax rate (Discussion and Board Signatures) | Angell asked the board to sign the MS-25 and DOE-25 (1:40:18); two tax-rate estimates at 1:42:52. Citizens’ comments reopened at 1:48:21. |
| 1:57:01 | III.5 Subcommittee reports | Capital improvement: none. Finance: one meeting, budget work beginning. Policy: Crawford moved BGAA, JICC, JICC-R, JICDD, JICI, JI and JLDBA at 2:01:21; Petrin seconded; roll call at 2:01:55, all yes. DAF revision moved at 2:03:34; roll call at 2:04:00, all yes. SRVRTC open house announced. |
| 2:05:43 | Added item 6: NHSBA resolutions | Crawford moved to support the NHSBA’s recommendations at 2:07:04; Hawkins seconded; roll call at 2:08:18, all yes. |
| 2:08:44 | Added item 7 / IV. Other business | “Public Announcement: Seeking individual to transcribe minutes for CSB while clerk in unavailable pay per meeting is $300” (agenda). Applicants under review. Madden on the superintendent search at 2:10:17. |
| 2:14:01 | V.–VI. Future dates; adjournment | November 5 and November 19. Hawkins moved to adjourn at 2:14:20; an unidentified voice: “You don’t need a roll call. Vote on that one.” The draft minutes record motion, second and “Meeting was adjourned”, with no vote. |
Discussion timeline
Chronological topics. Quotations are from the dialogue transcript as transcribed; bracketed text is an insertion or correction.
| Time | Topic | What was said | Flags |
| 0:01:13 | The remote member identifies his room | Petrin: “Lauren, we need you to affirm or let us know who is with you in the room. No one is looking in the room, and I’m in my house.” No reason for remote attendance is stated on the recording or in the draft minutes. | MEDIUM POSITIVE |
| 0:04:22 | Families in need | Tremblay: “I had three separate families approached my staff and I distraught and say, my child doesn’t have a lunch.” At 0:05:01: “I urge the board to confirm that every single possible option, other than raising the tax rate, has been fully explored and exhausted”. | |
| 0:12:44 | A resident asks about audits | Savage: “there is a state law that says that the schools should have to have an audit every year, and they’re supposed to give the audit reports to the board.” Petrin at 0:12:37: “Mr. Angel’s been digging into the numbers”. | OBSERVATION |
| 0:14:59 | The Concord hearing | Hemingway: an “HB 292 amendment” offering a revolving loan; at 0:15:59: “we’re not there to have the state to take and get us out of this hole. We got us in this hole.” An unidentified state representative at 0:22:08: the vote “Has been postponed such that we won’t have a decision at the legislative level until the beginning of January at best”. Kennedy at 1:11:09: “it’s not an extra loan. It’s just accessing the money that we would already be getting.” | |
| 0:18:07 | “Withdrawals without headings” | Emanuel: “did you at any time find withdrawals without headings, explanations, where monies went”. The reply, captured in the same row: “I haven’t found any instances of large instances of fraud … the record keeping is kind of in shambles”. | |
| 0:26:54 | Raw budget data | Larson: “the website only shows a summary”; “I request that the board makes raw data available to the general public.” | |
| 0:27:42 | Nonpublic session | Motion under “Parentheses three”; the board is back in public at 0:29:23 on the recording. | MEDIUM |
| 0:36:14 | School-psychology interns | McCleod: “In the last year that we’ve had this position posted, we’ve had zero qualified applicants apply.” Madden at 0:47:59: “we’ve been asking for an explanation for so long. And the people we ask resign.” Angell at 0:58:40: one intern costs “$96,940”, the other “$109,437”, base salary 80,000 (0:59:39). Kennedy at 1:02:11: “we’re still uncovering” the hiring process. | |
| 1:13:21 | Business administrator suspended | Kennedy: “an important update regarding the former business administrator, Mary Henry. As you know, Miss Henry has been on paid administrative leave since August 22nd, 2025.” At 1:14:01: “Last week, the Sioux [SAU] delivered a formal disciplinary letter to Miss Henry, placing on unpaid disciplinary suspension. Miss Henry has requested a hearing”. | OBSERVATION |
| 1:14:35 | HR office; HR audit | “Patrick O’Hearn, the HR director, and Samantha miller now both resigned”; an HR audit is planned. Crawford at 1:19:03: O’Hearn left “of his own volition” with “no buyout”. Madden at 1:19:38: the whistleblower law was to be posted in the schools; “as of last week it wasn’t done” (1:20:10). | |
| 1:17:25 | Interim CMS principal | Hawkins: “Miss O’Neill, as interim middle school principal with the salary and benefits to align with the collective bargaining agreement of the CAA [SREA, per the draft minutes].” Carried on a roll call. | |
| 1:27:02 | Compensation letters made public | Hawkins: “Salary and benefits package? I move that we make it public.” Kennedy at 1:24:42: “This is public record. Miss Weatherford has been getting for a lot of right to know requests.” At 1:28:08: “people can make informed decisions”. | POSITIVE |
| 1:31:26 | “That audit report that we never saw” | Madden: “Heather has been trying to get the report, that audit report that we never saw, that was hidden from us with 39 pages and 59 points”. Kennedy would follow up when Whitney returns. | OBSERVATION |
| 1:34:04 | $1.9 million deficit; failed refrigerators | Angell: “I’m still estimating a deficit at the end of this fiscal year of almost $1.9 million.” Two walk-in refrigerators “filled [failed] our health inspection” (1:34:28), at “about $45,000 apiece” (1:34:54). | OBSERVATION |
| 1:34:54 | Ten cents a meal, no appropriation | Angell: “an agreement that was signed by the former business administrator nine days before I was brought on that, that said that we’re going to contribute $0.10 to every meal that served at school lunch, and it’s going to come out of our appropriations.” Hawkins at 1:35:43: Board approve that? Crawford: “Who is the agreement with?” Angell at 1:35:47: “It’s with, the state of New Hampshire.” At 1:36:15: “I don’t have an appropriation to pay for this.” | MEDIUM |
| 1:37:12 | Signatories; Positive Pay | “school board policy. DG, a [DGA] requires authorization of signatures”; signatories at 1:37:45. Positive Pay and two-person approval at 1:38:33: “One is one enters a transaction. The second person, well releases it.” Hawkins: “Which we have not had till this point.” | POSITIVE |
| 1:40:18 | MS-25 and DOE-25 for signature | “These are necessary documents to set the tax rate. And I need the school board to sign both of these. Okay. I, I emailed copies of them to you this this morning.” “normally I get this done in August, so that the board has time to review it.” Crawford at 1:41:04: “there was no positive balance going forward.” Angell at 1:45:30: “I’m going to file everything tomorrow”. | HIGH |
| 1:41:14 | Special-education aid unconfirmed | “Basically, the DRA allows us to estimate up to 80% of that number.” At 1:41:46: “It’s $1.1 million. Last year it was 479,000.” At 1:41:57: “I’d hate to set the tax rate and artificial and have it come back and hurt us.” | OBSERVATION |
| 1:42:52 | Two tax rates | “a combined increase is with the 500,000. In special ed is a, $1.48 increase over last year or 9.18%. Okay. If if the state comes back and says the 1.1 million is correct, then it’s a 98 cent increase or a 6.08% increase.” Last year’s assessed values used, “because the, the city hasn’t filed their assessed values yet” (1:42:15). | OBSERVATION |
| 1:43:55 | Why the old rate was too low | Petrin: “the previous tax rate was improperly calculated.” Angell at 1:44:28: “last year they were using a fund balance number that I don’t believe that they had.” Hawkins at 1:44:38: “So the tax rate was not set correctly.” | |
| 1:45:50 | Health insurance for people who had left | Angell at 1:46:57: “people that were on the health insurance that had been on for a couple of years that shouldn’t have been there. We were we found employees that we weren’t, deducting the amounts correctly.” | |
| 1:48:46 | A resident redoes the meal arithmetic | “We’re not talking $1,000. Real math tells me that we have 1550 students”; at 1:49:11: “That’s $75 a day. There’s 180 school days. That’s $13,500.” Crawford at 1:51:20: “It’s the same debt, right?” Angell: “That’s right.” | MEDIUM |
| 1:55:41 | What residents will hear | Williams: “we’re looking at $1.48 per square foot or a 9.8% increase” [Angell’s figure was 9.18%, and the rate is per thousand of valuation]; “I can roughly anticipate a 10% increase in the school district taxes.” | |
| 2:02:11 | Policy DAF: whistleblower notice | Hawkins: the revision adds reporting on real property and “Daff 13 [DAF-13] … the whistleblower protections, notifications, rights and remedies.” | |
| 2:10:17 | Superintendent search | Madden: a “very stern email from Miss Hawkins. Cease and desist” (2:10:45); at 2:13:45: “Time is going on and nothing is happening.” Petrin at 2:12:33: “Unity is leaving the SA6.” Hawkins at 2:13:05: “a superintendent search committee would need to be formed and approved by the board. And I don’t think that has happened yet.” | |
| 2:14:20 | Adjournment without a roll call | “I moved to adjourn second.” Unidentified: “You don’t need a roll call. Vote on that one.” Petrin: “No. It’s fine. No.” | MEDIUM |
Items flagged for review
These flags are a reviewer’s aid. They are not findings of violation and not legal advice. Each flag cites the rule it rests on; an Observation rests on no confirmed rule.
HIGH The FY2025 financial reports due September 1 were put to the board for signature on October 15
RSA 21-J:34, V: “School districts shall submit financial reports on or before September 1 of each year” (statute). RSA 198:4-d, as in force on this date, requires the DOE-25 “on or before September 1 of each year” (statute) and contains no extension provision. At 1:40:18 Angell asked the board to sign both reports, e-mailed to members that morning, and apologized that “normally I get this done in August, so that the board has time to review it.” At 1:45:30: “I’m going to file everything tomorrow”, six weeks after the due date. The tax rate waits on these filings. Mitigation: Angell had taken over the books weeks earlier and was rebuilding them, and he raised the lateness himself. The board had less than a day to review what it signed.
Sources: RSA 21-J:34, V (source note ends 2007, 182:2; text read 2026-09-25); RSA 198:4-d (2025, 141:401, eff. July 1, 2025; the 2026 reenactment post-dates this meeting); FY 25 MS-25.pdf; FY 25 DOE-25.pdf.
MEDIUM An agreement signed by the former business administrator committed appropriations to ten cents a meal, and no one could find a board vote or an appropriation
Angell reported at 1:34:54 an agreement signed “nine days before I was brought on” committing the district to “contribute $0.10 to every meal” from “our appropriations”, and at 1:36:15: “I don’t have an appropriation to pay for this.” Hawkins, Madden and Crawford asked whether the board had approved it and whether it was valid; Angell would “have to go through it in more detail”. The draft minutes describe “written agreements signed by the former business administrator”. RSA 32:8 bars a school board from paying or agreeing to pay money “for any purpose for which no appropriation has been made” (statute), and RSA 197:23-a lets the treasurer pay out “only upon orders of the school board” or members it empowers (statute). The sums are small (Angell’s $1,000 against a resident’s $13,500 at 1:49:11), and Crawford established that the money only moves a deficit into the school-lunch fund. The agreement is not in the packet and its counterparty and legal basis were not established on the record.
Sources: RSA 32:8 (1993, 332:1); RSA 197:23-a; draft minutes.
MEDIUM The nonpublic motion cited a subparagraph that does not exist, and the session’s minutes are misdated and were filed late
RSA 91-A:3, I(b): the motion “shall state on its face the specific exemption under paragraph II” (statute). The agenda and draft minutes read “RSA 91-A:3,II (3)” and Hawkins moved under “comma two. Parentheses three” (0:27:42); paragraph II is lettered, not numbered. The agenda then prints the text of II(c), so the intent is recoverable. The nonpublic-session form in the Unsealed Minutes share ticks II(c) but is dated “October 16, 2025”. It matches this meeting in members present, the remote member, and the mover and seconder of entry, and differs on the return (Petrin and Hawkins on the form; Crawford and Madden on the recording at 0:29:04–0:29:07). It records entry at 7:00 p.m. and return at 8:30 p.m., which the recording cannot test because it was paused; Hawkins’s “I apologize for the hour” at 1:57:27 is consistent with a long session. The form records no motion to seal, so RSA 91-A:3, III required disclosure “within 72 hours of the meeting”; the earliest copy located was created in Drive on October 30, 2025. Mitigation: the roll call was taken, the correct ground is recoverable, and the session was not sealed.
Sources: RSA 91-A:3, I(b), II(c), III (2023, 189:1, eff. Oct. 3, 2023; text read 2026-09-25); 10.16.25 CSB Nonpublic Meeting session minutes Unsealed; CSB Agenda 10.15.25 (1).pdf.
MEDIUM Minutes gaps: late draft, missing elements, no stated reason for remote attendance, and an adjournment without a roll call
RSA 91-A:2, II requires minutes within 5 business days and, from August 22, 2025, “the start time and end time of the meeting, and name of the person who produced the minutes” (statute). The draft located was created in Drive on November 26, 2025, six weeks after the meeting; it gives only the agenda’s scheduled times and names no producer. RSA 91-A:2, III: “Any reason that such attendance is not reasonably practical shall be stated in the minutes of the meeting,” and “All votes taken during such a meeting shall be by roll call vote” (statute). The draft minutes record Howard as “present virtually” with no reason, and the adjournment (2:14:20) was taken after “You don’t need a roll call” (2:14:28) with no vote recorded. Mitigation: the clerk was on leave and the district advertised for a transcriber that night; the minutes were approved as amended on December 3, 2025.
Sources: RSA 91-A:2, II and III (2025, 112:1, eff. Aug. 22, 2025; text read 2026-09-25); draft minutes; approved December 3, 2025 minutes.
OBSERVATION The tax-rate estimate turned on a special-education aid figure the state had not confirmed
Angell had asked the Department of Education to confirm $1.1 million of special-education aid against $479,000 the year before (1:41:46), and gave two rates (1:42:52): 9.18% with $500,000, 6.08% with $1.1 million. For this fiscal year RSA 186-C:18, III, as amended in 2025, requires the department to distribute “not less than 80 percent of the district’s entitlement in the fiscal year” (statute), where FY2025 was prorated. That change may explain part of the increase and matches Angell’s “up to 80%” (1:41:14); this page does not determine the figure. Petrin said the previous rate “was improperly calculated” (1:43:55) and Hawkins that it “was not set correctly” (1:44:38). Choosing the lower aid figure is the conservative course; no rule was breached.
Sources: RSA 186-C:18, III (source note ends 2025, 141:276, eff. Sept. 1, 2025; text read 2026-09-25); draft minutes (“9.18% increase in tax rate using $500,000 in special education aid”).
OBSERVATION An employee’s unpaid suspension was announced by name in open session before her requested hearing
At 1:13:21–1:14:01 Kennedy read a statement naming the former business administrator, her paid leave since August 22, 2025, a notice of termination, “additional concerns about her performance”, and the unpaid suspension, adding that she “has requested a hearing”. RSA 91-A:3, II(a) allows a body to take up “the disciplining of such employee” in nonpublic session (statute); it permits privacy and does not prohibit a public announcement. No verified rule bars this statement. Recorded because it concerns an unresolved matter about a named person, made before the hearing she requested.
Sources: RSA 91-A:3, II(a); draft minutes (“Kerry Kennedy read a pre-written notice”).
OBSERVATION A $1.9 million projected deficit and failed kitchen equipment, with the board still seeking an audit report
Angell projected a year-end deficit of “almost $1.9 million” (1:34:04) and two walk-in refrigerators to replace at about $45,000 each (1:34:54). A resident asked where the annual audits were (0:12:44), and Madden said the board had been trying to obtain “that audit report that we never saw” (1:31:26). RSA 21-J:19 permits a school district to have its audit done by an independent accountant; it is permissive as to timing, and this meeting’s record does not establish how many years are outstanding. Recorded as an observation.
Sources: RSA 21-J:19 (permissive; anchor catalogue); CSD 09.30.2025 GF Expenditures Report (2).pdf.
POSITIVE Remote participation handled on the record, with a roll call on every substantive vote
RSA 91-A:2, III requires a remote member to “identify the persons present in the location from which the member is participating” and a quorum to be “physically present” (statute). Petrin put the question at 0:01:13, and the draft minutes record the answer. Four members were in the room. Angell called a roll on every substantive motion: nonpublic entry and return, both appointments, the compensation letters, the policy package, DAF and the NHSBA resolutions. The exceptions are in flag 4.
Sources: RSA 91-A:2, III; draft minutes.
POSITIVE The board voted to publish staff compensation, and the business office moved to two-person payment approval
On Hawkins’s motion at 1:27:02, carried on a roll call at 1:28:50, the board released the staff salary-and-benefits compensation letters for posting, which Kennedy tied to the volume of Right-to-Know requests (1:24:42). RSA 91-A:4 makes such records available on request; the board chose to post them without waiting to be asked. Separately, Angell brought a Positive Pay agreement and two-person entry and release of payments (1:38:33), which Hawkins noted the district had not had before. These go beyond the legal minimum.
Sources: RSA 91-A:4; draft minutes.
Appendix — source files
Official and public sources
Project files
Working files this page was built from. The dialogue file is linked; the others are not published with the page.
Laws and rules cited on this page
- Right-to-Know: RSA 91-A:2, II and III (2025, 112:1, eff. Aug. 22, 2025); RSA 91-A:3, I(b), II(a), II(c), III (2023, 189:1, eff. Oct. 3, 2023); RSA 91-A:4
- Financial reporting and audit: RSA 21-J:34, V; RSA 198:4-d (2025, 141:401 vintage); RSA 21-J:19
- School money: RSA 32:8; RSA 197:23-a; RSA 186-C:18, III (as amended 2025)