14 June 2016

Recent Transitions in the Leadership of the PLA Rocket Forces

June 06, 2016

The People’s Liberation Army (PLA) Rocket Forces (火箭军) (previously the Second Artillery) has been witnessing leadership transitions and adjustments in its organisation, especially in the year 2015. The leadership transitions were prepared in the light of an eventual upgrade into an independent service, which was finally announced on 31 December 2015. The Chinese Communist Party (CCP) and the Central Military Commission (CMC) headed by President Xi Jinping had approved a number of promotions and transfers in the Rocket Forces, especially among high-ranking officials. While it is notable that some positions in the Rocket Forces had to be filled as the officers were placed under investigation for graft, the leadership changes point to broader concerns about the Rocket Forces’ party loyalty, their training standards, personnel organisation, and efficiency of integrated command and control. The Chinese leadership understands that the commitment of the Rocket Forces’ leadership is necessary for structural reforms to mitigate the challenges. 

These changes point to the leadership’s priorities for the Rocket Forces amidst military restructuring in the PLA and the role of high-ranking military officials and their rise in the organisation. The Rocket Forces have been consistently improving the accuracy and penetration capabilities of missiles. In response to these changes, they have begun to concentrate on scientifically and technically capable personnel to handle equipment as well as competent maintenance staff. Not only has attention been given to improving training standards,1 but integrating equipment systems has also emerged as a significant challenge. Since training methods are moving towards the conduct of joint operations or towards performing integrated training, it was not surprising that as early as 2014 the then Second Artillery Commander asked to implement Xi Jinping’s tasks of improving integrated and joint command (that is, robust, integrated, highly trained in responding to emergencies, and responsive command system).2 In particular, changes have been proposed as the Rocket Forces have also been plagued by invisible formalism (隐形的形式主义).3 It is clear that recent changes not only reflect the need for reform but cannot be only attributed to a strategy by Xi Jinping to increase his political control over the military.4
Importance of the Rocket Forces

The Rocket Forces are transitioning from a purely nuclear deterrence role to one that combines both conventional and nuclear capability. The conventional-nuclear integration was adopted to make the Rocket Forces relevant to the conditions of modern warfare. In other words, the Chinese leadership understood that after Desert Storm warfare would be conventional, short, and limited, but limited by a nuclear threshold. This is understood by the Chinese as ‘information warfare under nuclear conditions’. Previously, the Second Artillery, unlike other services, was directly under the command of the CMC. But now, the Rocket Forces have emerged as one of four independent military services of the CMC, attaining equal importance with the other services. The upgradation into Rocket Forces shows that China is more confident of its identity, as the original name was “strategic missile forces” but referred to as Second Artillery to avoid detection.
Military Training Standards

The attention of the Chinese leadership has shifted towards integrated training and joint operations. A survey of the literature available reflects the attention given to the need to establish training standards that resemble “actual combat” (实战). They stress the need for the operational method5 to be consistent with the actual combat mission, real battlefield environment, existing command structure (weapons and means), and be tied to improvement in training and sudden inspections.6 This is not surprising given that Xi Jinping had approved a publication from the CMC titled “Ideas Regarding the Improvement of Military Training To Actual Combat Standard” (关于提高军事训练实战化水平的意见) on March 20, 2014 to be implemented across the military. According to the publication, the Chinese military would have to change its combat training to resemble conditions of “actual combat”.7 The report widened the scope of “training modules” to include mission-related training, training base, training method, training environment, training supervision mechanism, joint training mechanism, before and after training system reform, talent cultivation, and education and research.8 Zhao, from the Political Department of one of the Second Artillery units, suggests that the Rocket Forces have to adjust to the new situation in modern warfare by transitioning from passive to active management. Because modern warfare has plenty of variables, the purpose of training is to understand and eliminate the blind spots and overcome weaknesses.9

Deficits in the training system are widely prevalent in the Chinese military, and the Rocket Forces are also not immune to deficiencies. But, in 2015, reports emerged that the new training programme has helped in improving skills with respect to the handling of new weapons and operating equipment. In one of the brigades of the Rocket Forces, the average performance score increased by about 10 per cent after the military training assessment system was upgraded.10 While military training standards have been updated and implemented in the Rocket Forces, fundamental changes have also been implemented in the leadership role of the Rocket Forces. 
Leadership Shuffle

The leadership transition throughout 2015 and the early part of 2016 shows an increased focus on strengthening the political leadership of the organisation and bringing expertise to implement the necessary reforms. The most significant change in leadership in the Rocket Forces was the appointment of Lieutenant General Wang Jiasheng (王家胜) as the Political Commissar of Rocket Forces in December 2014. The Rocket Forces have been emphasising that attention would be given to equipment acquisition, procurement and management corresponding to the long-term needs of the organisation. Wang Jiasheng’s expertise in the equipment department would be crucial in improving the Rocket Forces’ equipment upgradation. Wang Jiasheng built his career in the now defunct PLA General Armaments Department (GAD), where he was the Director of its Political Department. Later, he was promoted as GAD’s deputy Political Commissar. He had also held the post of political commissar of 27th test training base, known commonly as the Xichang Satellite Launch Center with GAD, situated in Sichuan.

In addition to Wang Jiasheng, many other officials were also promoted in December 2014. Lieutenant General Tang Guoqing (唐国庆) and Major General Zhang Dongshui (张东水) became the deputy Political Commissars of the Rocket Forces. In fact, after taking the new post in December 2014, Tang Guoqing was promoted as Lt General in July 2015, signalling his ascension within the organisation. These two appointments were necessary as one of the two previous deputy Political Commissars, Lt General Yu Daqing (于大清), was forced to resign due to corruption investigation,11 and the other, Lt General Yang Lishun (杨立顺), retired in December 2014. However, within a month of his promotion, the newly appointed Zhang Dongshui was placed under investigation for corruption. He resigned from his post in January 2015. As his replacement, Major General Chen Pinghua (陈平华) was assigned the post of Deputy Political Commissar in July 2015, after being promoted to the rank of Lt General. Yu Daqing’s investigation was seen as a consequence of his proximity to General Xu Caihou (徐才厚), the previous Vice-Chairman of the CMC, who was investigated for graft in March 2014.12 Yu Daqing was described as Xu Caihou’s ‘trusted aide’ (亲信). These investigations in the Rocket Forces are part of Xi Jinping’s focus on anti-corruption in the Chinese military and his efforts to use it to initiate reforms and restructuring within the military. Xu Caihou was used as an example and benchmark for reorganisation in the army, in education, personnel change, and discipline strengthening.13 The campaign has been addressed as a way for the military ‘to completely remove the negative influence of Xu Caihou’s case’ (在彻底肃清徐才厚案影响上见到实效). 

Tang Guoqing’s rise through the ranks was also significant. He had considerable experience in managing missile bases. He was associated with the 52nd missile base that operates in the southeastern part of China. Rising through the ranks, he later became Director of the Political Department of the Second Artillery. When Tang left this post to become deputy political commissar, Zhang Shengmin (张升民) replaced him in the Political Department. Zhang was previously the political commissar of the 54th base of the Rocket Forces. He had served in the Lanzhou military region as well as in the 53rd, 55th and 56th bases. He was the political commissar of the Second Artillery Command College. Both Tang Guoqing and Zhang Shengmin’s experiences in missile bases show the importance given to such knowledge. It was reported later in February 2016 that Zhang Shenmin has taken the post of Political Commissar of the CMC Military Training Management Department (军委训练管理部). Given his vast experience in several missile bases, Zhang’s contribution would be significant. In this recent transition in early 2016, Chen Pinghua was appointed as the Secretary of the Rocket Forces’ Discipline Commission (火箭军纪委). Previously, Chen worked in the Chengdu military region as its deputy political commissar. With the transfer of Chen Pinghua, the Rocket Forces as of now have only one deputy political commissar. 

There were also several adjustments in the post of Chief of Staff of the Second Artillery. Initially, Lt General Gao Jin (高津) had occupied this post. However, when he became the Assistant to the Chief of Staff of the PLA in July 2014, Lt General Lu Enfu (陆福恩) had to take this post on a temporary basis along with his original posting of deputy Commander of the Second Artillery.14 By 2015, a replacement was found in Zhang Junxiang (张军祥), who replaced him as the Second Artillery’s Chief of Staff. Zhan Junxiang was previously posted in the then Second Artillery’s Equipment Department. His expertise in the Equipment department will be used to cement Second Artillery’s equipment upgradation. His views on equipment upgradation is going to be useful in ascertaining the trajectory of reforms in the Rocket Forces. For instance, before the opening of the “Two Sessions”15 in March 2014, where Zhang was one of the military delegates, there was discussion on the reforms to bring laws and regulations to govern civil-military integration. Civil-military integration was seen as an effective way to utilise the private sector in defence production. Zhang said that as the ‘informationisation level of weapons and equipment has continued to increase, the structure of the organisation, strength of forces and the day-to-day management of troops has become complex. Therefore, improving the system of laws and regulations have become inevitable for a strong army.’16 Zhang’s position as the Chief of Staff would cement Rocket Forces’ equipment upgradation. The post of Chief of Staff is significant as General Wei Fenghe, the current commander of the Rocket Forces, also held the Chief of Staff post.

Gao Jin’s rise in the organisation was rewarded when the Chinese leadership formed the PLA Strategic Support Force SSF (战略支援部队) in December 2015. Gao Jin was promoted as its Commander. This shows a deep connection between the Rocket Forces and SSF. Lu Enfu, for his part, retained his post of deputy Commander of the Second Artillery, which he assumed in 2011. Lu had experience in nuclear missile bases such as the 55th and 54th as the Commander and Chief of Staff, respectively. When Xi Jinping formed the Rocket Forces, Lu Enfu became the deputy Commander. Earlier, in July 2014, Lt General Wang Zhimin (王治民) became the Second Artillery’s Deputy Commander from being the deputy Commander of the Guangzhou Military Region. In December 2014, Wang Jiurong (王久荣), the then deputy Commander of the Second Artillery, had retired. To replace Wang, in January 2015, Lt General Zhou Yanning (周亚宁) was assigned as the Deputy Commander of the Second Artillery. Zhou Yanning had been a Commander of the Second Artillery’s 52nd base. Along with long time deputy Commander Lt General Wu Guohua (吴国华), by 2015, after the initial leadership adjustment, the Second Artillery deputy Commanders were Wang Zhimin, Lu Enfu, and Zhou Yanning. 

After the initiation of the Rocket Forces, eleven military officials were confirmed as part of the leadership of the Rocket Forces General Headquarters. Among them, except for Wang Zhimin, all the other deputy Commanders such as Lu Enfu, Zhou Yanning and Wu Guohua were confirmed as deputy Commanders.17 That could have been because Wang Zhimin was nearing 63 years, the retirement age.18 By May 2016, Lu Enfu had also retired and stepped down from the post. In his place, Major General Li Chuanguang (李传广) has become the deputy Commander. Li was a former Chief of Staff of the 55th missile base. 

At the base level leadership, there were also several transitions, especially a group of military officials were promoted as Major General. Among them, Wang Minghua (王明华), previously the head of the Second Artillery brigade (822 brigade, 51 base), was promoted as a Major General in December 2014. It is possible that he was transferred as the deputy Commander of the 56 missile base. Major General Lan Jiyin (兰吉银), who was the Head of the Military Training Department in the Headquarters of the Second Artillery, was also promoted. However, there is speculation that he has been promoted twice, first as the Chief of Staff of 52nd missile base, and then sometime in the first half of 2016 as the Commander of the 51st missile base replacing Li Jun.19 Major General Li Hongjun has taken his place in the military training department. He Junmin (何钧民), the former Director of the Political Department of the Second Artillery Engineering College, was also among those promoted in December 2014. He was later promoted to the post of deputy Political Commissar of the 54th missile base. Zhang Youxiang (张有祥), who was previously the director of the political department of the 54th missile base at the time of his promotion, is now the political commissar of the 53rd missile base.20

Other military officers who were promoted include Major General He Jun (何骏), who is now the deputy Political Commissar of the 55th base; Major General Pan Jihui (潘吉慧), deputy Political Commissar of the 56th base; Li Shuiming (林水明), deputy Commander of the 54th missile base); Chen Guangjun (陈光军), Head of Second Artillery Engineering University Training Department); Zhou Wei (周巍), head of Second Artillery Equipment Research, Science and Technology Department; Xue Xinfeng (薛今峰), Chief of Staff of 22nd Base; Chen Zhaodong (陈朝东), dean of Second Artillery Engineering Design Institute; Ren Yongji (任永吉), deputy Commander of 56th base; Cheng Dezhi (程德志), deputy chief engineer of 56th base; Xiang Songbo (向松波), deputy chief engineer of 56th base; Sun Danping (孙旦平), Political Commissar of base 22; Zhao Guisheng (赵桂生), deputy head of Second Artillery Command College); and Yu Zongbao (于宗宝), Chief Engineer of 53rd base.

On July 6, 2015, five more officers were promoted to the rank of Major General. They were Wang Liping (汪利平), political Commissar of the 51st base; Zhang Jincheng (张金成), an expertise rank Professor in Second Artillery Command College; Bi Yongjin (毕永军), Director of the Political Department of the Second Artillery Command College; Zhuo Lingceng (卓凌曾), deputy political commissar of Second Artillery Command College; and Li Xiangyu (李贤玉), Chief Engineer of Second Artillery Equipment Institute. Further appointments have been made around May 2016. Apart from Li Chuangguang, Yu Chunfu (于春福) and Jiang Jiage (蒋家革) have become the deputy directors of the Rocket Forces Political Work Department; Wang Qifan (王启繁), head of Rocket Forces Logistics Department replaced retired Liu Huanmin. 

While analysing the significance of the leadership transition, the prospects of Rocket Forces’ contribution to joint operations emerge as an essential factor according to the Chinese military’s vision of future war.21 The joint exercises held in 2014 and 2015 were conducted in the South China Sea. Therefore, it is not a surprise that officials from Second Artillery had also been transferred to the Navy for facilitating this process. For instance, Ren Yongji, a few months after his promotion at the end of May 2015, was transferred as the deputy Chief of Staff of PLA Navy’s South Sea Fleet.22 After this stint, Ren was transferred back to 56th missile base as its deputy Commander in 2016. In fact, the deputy Chief of Staff from the South Sea Fleet, Major General Wang Liyan, was also from the Second Artillery. He was placed in this position in July 2014. The purpose of the September 2014 exercise, “Joint Action 2014 – A” was to test joint command performance and conventional missile strike. The naval exercises conducted in July 2015 was an annual drill to test the “air defence system and early warning system of the navy”. The Rocket Forces had also participated in the exercises.23 Such exercises are always exhibitional deterrence, designed to use the deterrent capability of the Second Artillery’s anti-ship missiles and to facilitate training for joint operational capabilities among different branches of the Chinese military. Commenting on this exercise, a Global Times report hinted that the Second Artillery in general might use its operational tactical missiles for such exercises. These missiles would be used in the early stages of war against enemy command centres, key radar positions, air defence missile positions and airports. The objective of the attack by Rocket Forces missiles would be to paralyse enemy points and open up aviation routes for Chinese naval aircraft to strike enemy targets.24 In Chinese calculations, the Rocket Forces’ cruise missiles could also be modified into anti-ship missiles for use against large warships, given that the Tomahawk was initially a surface missile and later converted into an anti-ship missile.25

A Chinese report gave the opinion of Li Li of PLA National Defence University that the inclusion of missile units is aimed at “reminding those who might want to control China in the South China Sea that they will face formidable missile strength.”26 Commenting about the objective of the Second Artillery’s mission in the exercise, Major General Yin Zhuo of the Navy Informatisation Expert Advisory Committee pointed out that the force has two main targets: ‘large warships and offshore targets… if countries in bases or airports around South China Sea attack China or attempt to occupy the islands, then China has the right to use Second Artillery to attack these airport or bases.’27
Increasing Profile of Equipment Research Department:

In recent years, the profile and contribution of the Second Artillery’s Equipment Department (第二炮兵装备部), now the Rocket Forces Equipment Department (in short Equipment Department), has increased substantially. Not only have personnel from the Equipment Department (火箭军装备部) been shifted to the higher Rocket Forces command (Wang Jiasheng, Zhang Junxiang), but its function has also been raised. This could be due to the understanding that the Rocket Forces need to upgrade weapons and equipment, on the one hand, and integrate new weapons, on the other. For instance, reports have emerged that the Equipment Department and an “unknown”28 department within the China North Industries Group Corporation (Norinco Group) have signed a technology strategy cooperation agreement to ‘to improve missile technology performance and combat effectiveness.’29 The report noted that the fundamental objective was to promote Second Artillery’s missile weapons equipment development. This is part of China’s efforts to promote civil-military integration to encourage private enterprises into entering the military procurement market to meet the PLA’s equipment needs. This particular agreement is reported to have the following objectives: (i) missile weapons technology capabilities and combat effectiveness; (ii) creating civil military integration platform; and, (iii) integrating real military needs with technology.30 This had led to efforts to streamline the licensing directory, which was released last year.31

The leadership shuffle in the Equipment department was to bring in leaders who could facilitate and implement these new reforms. Major General Mo Junpeng (莫俊鹏) is one such example. In February 2015, Mo had assumed the post of Deputy Chief of Staff of the Second Artillery. Before that, he was the Commander of the 22nd base (nuclear warhead storage). But in March 2015, he was once again transferred to the Equipment Department as its Director. Mo Junpeng’s experience must be the reason for bringing him to the Equipment Department soon after a transfer. He was the Equipment Department’s deputy Director before he became the Commander in 22nd base. Mo seems to be eager to implement the reforms. He has already stated that it is important to ‘implement Xi Jinping’s instructions, to develop an understanding about the role of the tasks, to have a clear idea of learning what is ‘real combat’, to understand that one has to be prepared for war anytime’.32 Admitting that the national defence and military reforms are very important and that the problems in reforms are quite serious, he stated that all the leading cadres ‘should have the courage to face the problems and support reforms’.33

Mo’s involvement in the reforms is also considerable. At the 12th session of the National People’s Congress meeting of the PLA delegation, it was reported that he gave a few suggestions on ‘issues in military strategic guidance’.34 Given that he is a graduate of PLA National Defence University with specialisation in military strategy, his suggestions would have been taken seriously. Earlier, in 2014, Mo was actively involved in legislation regarding civil-military integration for equipment support. In a report, he commented that ‘with Second Artillery’s new high tech weapons developing, the growing cooperation with military industry is becoming more complex. It also suffers from challenge due to insufficient legislation affecting coordination and continuity, and timely implementation of the projects’.35 Mo is best suited to the Equipment Department as he is more than aware of the challenges due to his involvement in an “unknown” department in the Second Artillery that studied the combat efficiency of troops. This department, according to Mo, upgraded 178 research tasks in eight major categories, where operational constraints were removed to enhance combat effectiveness. These problems were tackled one by one. The department concluded that scientific research at their operational site contributed to the improvement in equipment operation and combat command efficacy and actual combat-like training exercises. The department specifically grew confident in ‘special equipment transportation, special emergency rescue and operating special equipment in complex conditions’.36

In addition to Mo, a missile expert, Li Xianyu, was also brought to one of the institutes under the Equipment Department as its Chief Engineer. Li, who has compared military research to war, has been steadily rising through the ranks by working in technical teams associated with missile brigades, where she had worked on issues related to launch control systems and operational command procedures.37 Further, the Equipment Research Institute (第二炮兵装备研究院) also saw some changes. The task of this research institute is to focus on innovation, establish a scientific research laws and regulations, realise the scientific projects, and help the Rocket forces to accelerate the development of weapons and equipment.38 In short, the focus is to engage in “real combat research and innovation”. In July 2015, Major General Zhuo Ling (卓凌) was promoted and transferred to the post of Political Commissar of the Equipment Research Institute. He replaced Major General Mu Xiudong (穆修栋). Previously, Zhuo was in the 52nd base as the deputy Director of the Political Department. Further, the research institute had established a new research centre called the Second Artillery Strategic Research Centre (第二炮兵战略研究中心) in 2012. This research centre would be the key institute in all areas of strategic research concerning the Rocket Forces and would provide the force with a development strategy, technical support and advice to the CMC, development of military strategy, weapons and equipment design, and core academic exchange platform. 
Conclusion

The leadership transition in the Rocket Forces shows that the service is not only integrating with other services but that its officials are increasingly called upon to other services to facilitate joint training and exercises. The reorganisation and restructuring of the Chinese military has reached the Rocket Forces, with the leadership finding ways to utilise one of its efficient forces for future warfare. The Rocket Forces are being modernised to act as a deterrent force in potential conflicts in the South China Sea and East China Sea. In that respect, the efficiency of their warfighting capability has to be enhanced. Therefore, the equipment and command competence becomes integral to the force, leading the leadership’s attention to equipment upgradation and integration of the Rocket Forces. Given this focus, it is not surprising that there is growing focus on the Equipment Department. Already, in another rank promotion in May 2016, Jiang Jinglian, the Chief Engineer of the Equipment Department, has been promoted to the rank of Major General. A year after assuming the post of Political Commissar of the Equipment Department, Ma Li would be retiring now, which is likely to result in a further change in personnel. The importance of the Rocket Forces would ensure that the leadership would implement the reforms more rapidly here than in any other service. 

Views expressed are of the author and do not necessarily reflect the views of the IDSA or of the Government of India. 
1. Some of the significant changes that the new training standards emphasise are strategic and tactical training, joint training, inter-services training, domestic and foreign joint exercises and training; developing combat training methods such as cross-base training, battlefield flexibility training; and operational command training such as joint operational command training and command strategy training to handle uncertain situations; and equipment training. See, Zhong Xun and Liang Pengfei, “PLA General Staff Department Deploys New Annual All-Military Training Tasks (总参部署新年度全军军事训练任务),” Zhongguo Junwang, January 18, 2015, (Accessed May 20, 2015). 
3. Invisible formalism is where the training does not reflect actual training but reflects what the PLA calls “false skill”. It means that peacetime training is not a representation of battlefield conditions or does not perform the actual exercises in training, only for “playacting”. See, Zhao Xifeng, “Practice Training Cannot Always Be “Attack the Mountaintop (演训不能总“攻山头),” Keji Ribao, June 23, 2015, (Accessed October 5, 2015). 
4. Xi Jinping’s anti-corruption drive in the military has been dubbed as a strategy to increase his control over the army and strengthen his political leadership. But signs are visible that the Chinese army needs urgent reforms. 
5. Operational method in this case means how tactics and strategy together constitute an innovative system. 
6. Zhang Xudong, “Military Strategy Innovation: To be constantly improved upon with ‘Real’ (战法创新：在“实”上精益求精),” Zhongguo Gongjun, November 29, 2013, , (Accessed May 20, 2015). 
8. Ibid. 
9. Zhao Xifeng, Note 3. 
12. Xu Caihou was one of the highest ranking military officials to be put under investigation for corruption; he was part of the CMC and CPC Politburo. He was accused of taking bribes in exchange for assisting in promotion of officers. He was expelled from the CPC on March 30, 2014. While under investigation and prosecution, he died of bladder cancer in March 2015. 
13. The Chinese leadership published an education plan titled “2015 All Military Education Campaign and Special Education Rectification”, which indicated the measures for a massive education campaign for soldiers and officers towards the proper ideological and political work. This education campaign was specifically addressed towards removing ‘Xu Caihou’s adverse effects and initiate a rectification campaign’. See, “CMC Chairman Xi Jinping Passes Ratification, General Political Department Publishes ‘2015 All Military Education Campaign and Special Education Rectification’ (经中央军委主席习近平批准, 总政印发《二○一五年全军主题教育活动和专题教育整顿的意见》),” Xinhua, January 7, 2015, (Accessed December 8, 2015). 
15. Two Sessions are the National Party Congress and the Chinese People’s Political Consultative Conference. They are an annual gathering, where a ‘government work report’ is generally submitted. 
18. Whether Wang Zhimin has already retired is not known. No replacement for him has been announced yet. Whether his retirement was the reason his name was not part of the transition is not clear as Lu Enfu before his retirement not only took the post of deputy Commander of the Rocket Forces but was approved in March 2016 as part of the Rocket Forces General Leadership Group. 
19. Li Jun has been transferred as the Commander of the 56th missile base. 
23. Xinhua, “Chinese Navy Conducts Live Firing Drill in South China Sea,” July 28, 2015, (Accessed July 28, 2015). 
25. US warships in the Pacific are all fitted with Tomahawk cruise missiles. 
26. “Navy Stages Live-Ammo Drill in S. China Sea,” China Daily, August 3, 2015 (Accessed December 3, 2015). 
28. The term “unknown or a certain” signified by the character (某) refers to a department or institute within an organisation which cannot be named in public reports. Therefore, news releases use this term to denote an unnamed department. 
30. Ibid. 
31. “Experts Interpret China’s New Licensing Directory for Weapons Equipment,” Xinhua, September 10, 2015, (Accessed September 29, 2015). 
33. Ibid. 
35. Note No. 16 
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