dissenting:
I am unable to agree with my colleagues’ disposition of the certified question. In my opinion, the majority’s interpretation of Section 5(a) of the Good Time Credits Act of 1986 (GTCA), D.C.Code § 24-431(a) (1996), contravenes the plain language of the statute and conjures up an imaginary ambiguity where none really exists. Judge Ferren endeavors earnestly to harmonize the GTCA with Section 24-206(a) (1996), but, in my judgment, the repugnancy between the two statutes is manifest and cannot be cured or alleviated by resort to an imaginative “construction” which, as I see it, contorts the statutory language.
In ascribing to the legislature an intention which the words of the GTCA will not countenance, the majority has also declined to accord appropriate consideration to the executive construction of the GTCA. That construction has remained consistent from the time that the statute was enacted until the present. In what I view as a departure from the rule of M.A.P. v. Ryan, 285 A.2d 310 (D.C.1971), my colleagues have declined to follow a key part of our decision in Luck v. District of Columbia, 617 A.2d 509, 515 (D.C. 1992) (Luck I), a case in which we held unambiguously that the interpretation by the District of Columbia Department of Corrections (DOC) of the identical statutory provisions here at issue, and of the interplay between them, is entitled to “great weight.” Finally, the majority has impermissibly construed a penal statute broadly beyond its text, to the prejudice of the liberty of the citizen. See, e.g., Ladner v. United States, 358 U.S. 169, 178, 79 S.Ct. 209, 214, 3 L.Ed.2d 199 (1958).
The majority’s disposition, if it is permitted to stand, has placed in jeopardy the settled expectations of many hundreds or even thousands of parolees and their families. Numerous men and women will remain incarcerated for far longer than previously expected, and the District government will be confronted with the thankless task of deciding what to do about those defendants who, under the majority’s new construction of the GTCA, must be deemed to have been prematurely released from prison. The District of Columbia, as amicus curiae, warns us that any retroactive adjustment of sentences is likely to cause much ill will and even chaos, and that prediction may be well-grounded.
To be sure, the unfortunate practical consequences that may flow from my colleagues’ holding cannot be dispositive, for we are obliged to carry out a legislative mandate regardless of our views of the policies that underlie it. In my opinion, however, the travail that this decision is likely to cause is quite unnecessary. It flows from an incorrect interpretation of the relevant statutes and, as to executive construction, from the court’s departure from binding precedent.1 Accordingly, I respectfully dissent.
I.
STATUTORY ANALYSIS
A. The statutes at issue.
In 1932, Congress provided, in what is now D.C.Code § 24-206(a) (1996), that if a grant of parole is revoked, then
the prisoner, unless subsequently repa-roled, shall serve the remainder of the sentence originally imposed less any corn-*1107mutation for good conduct which may be earned by him after his return to custo-dy_ The time a prisoner was on parole shall not be taken into account to diminish the time for which he was sentenced.
(Emphasis added.) It is undisputed that if this case were governed by Section 24-206(a) alone, then Noble would not be entitled to credit for street time accrued before his parole was revoked in 1993.
More than half a century after the 1932 statute went into effect, the Council of the District of Columbia, acting in response to an “unprecedented crowding problem in [the District’s] correctional institutions,”2 enacted the Good Time Credits Act. The GTCA provides in pertinent part that
[e]very person shall be given credit on the maximum and the minimum term of imprisonment for time spent in custody or on parole as a result of the offense for which the sentence was imposed.
D.C.Code § 24-431(a). (Emphasis added.)
Read literally, the language of Section 24-431(a) is inconsistent with that of Section 24-206(a). The GTCA, on its face, authorizes credit for street time for all parolees, whether or not parole has subsequently been revoked. Section 24-206(a), on the other hand, proscribes credit for street time in the event of revocation. In light of this apparent inconsistency between the two provisions, the question before the court is whether the later statute effected a pro tanto repeal of the earlier one.
B. The Good Time Credits Act.
“[N]ot only at the beginning, but [also] at the ending, is the Word.” J. Ungar, Inc. v. Comm’r of Internal Revenue, 244 F.2d 90, 94 (2d Cir.1957) (Learned Hand, J.). In determining whether the GTCA implicitly repealed Section 24-206(a), we look first (and perhaps also last) to the language of Section 24-431(a), for the Council’s intent must be discerned from what the Council has written.
Textually, Noble and the District present a powerful case. Noble points out in his brief that “every person” means every person, and that
[Section 24-431(a) ] does not, as the Commission would have it, state “every person except parole violators.” The statute does not state “every person shall receive credit except if parole is violated and revoked.”
(Emphasis added.) In response to the contention of the USPC that, in context, Section 24-431(a) authorizes credit for street time only for those defendants whose parole has not been revoked, Noble invokes the prose of Justice Brandéis:
What the Government asks is not a construction of a statute, but, in effect, an enlargement of it by the court, so that what was omitted, presumably by inadvertence, may be included within its scope. To supply omissions transcends the judicial function.
Iselin v. United States, 270 U.S. 245, 251, 46 S.Ct. 248, 250, 70 L.Ed. 566 (1926); see also West Virginia Univ. Hosps. v. Casey, 499 U.S. 83, 101, 111 S.Ct. 1138, 1148, 113 L.Ed.2d 68 (1991) (quoting Iselin); Luck I, supra, 617 A.2d at 513. As a matter of plain syntax, Noble has it right, and I am unable to discern the slightest textual ambiguity in Section 24-431(a).3
Moreover, for all practical purposes, the construction of Section 24-431(a) proposed by the Commission and adopted by the majority strips the provision authorizing credit for street time for persons on parole of any significant effect. Under the interpretation suggested by the USPC, “there would be few, if any, instances in which the GTCA would apply, since a prisoner whose parole elapses without revocation would have completed his or her sentence, and credit for street time would be irrelevant.” Beaty v. Ridley, No. SP 138-93 (Super.Ct.D.C. Jan. 26, 1993) (Alprin, J.). “A basic principle [of statutory construction] is that each provision of the statute should be construed so as to *1108give effect to all of the statute’s provisions, not rendering any provision superfluous.” Veney v. United States, 681 A.2d 428, 433 (D.C.1996) (en banc) (citation omitted); see also the Corporation Counsel’s construction of the GTCA, infra, at pp. 1112-1113.
Our elected representatives are intelligent, literate people. They know how to write what they mean. It is difficult to understand how a single Councilmember who did not intend to grant credit for street time for all parolees could have voted for a statute which grants every person credit for time spent in custody or on parole. It is even more difficult to believe that all of the Councilmem-bers who enacted this statute would have done so if their intent had been something completely at odds with the meaning of the words. Judge Ferren suggests that the drafters intended merely to formalize past practice governing the situation when an inmate completes the sentence without revocation of parole. If that was their intent, however, they most assuredly did not say so.
The majority’s construction of the GTCA presupposes that the drafters either did not read what they had written or, if they did, that they failed to notice what they had said about credit for street time for “every person” who was “in custody or on parole.” The majority’s position is necessarily predicated on the hypothesis that the Couneilmembers voted for the GTCA as written without being aware that it says what it says. This is conceivable, I suppose, but surely very, very unlikely.
“The court even in a good cause may not impose on words a meaning that they will not bear.” United States v. Nord Deutscher Lloyd, 186 F. 391, 395 (S.D.N.Y.1911) (Learned Hand, J.), rev’d on other grounds, 223 U.S. 512, 32 S.Ct. 244, 56 L.Ed. 531 (1912). Whether “the cause” in this case is good or bad is not for the court to decide, but the words of Section 24-431(a) will not bear the meaning that the majority would ascribe to them.
C. Repeals by implication.
The majority argues, and I agree, that we cannot resolve the issue in this case by considering Section 24-431(a) in isolation. “The correct rule of interpretation is, that if divers statutes relate to the same thing, they ought all to be taken into consideration in construing any one of them.” Luck I, supra, 617 A.2d at 514 (quoting United States v. Freeman, 44 U.S. (3 How.) 556, 564-65, 11 L.Ed. 724 (1845)).
Repeals by implication are not favored. Luck I, supra, 617 A.2d at 514 (citation omitted). “In the absence of some affirmative showing of an intention to repeal, the only permissible justification for a repeal by implication is [that] the earlier and later statutes are irreconcilable.” Morton v. Mancari, 417 U.S. 535, 550, 94 S.Ct. 2474, 2482, 41 L.Ed.2d 290 (1974). “The presumption against implied repeals is overcome, however, by a showing that the two acts are irreconcilable, clearly repugnant as to vital matters to which they relate, and so inconsistent that the two cannot have concurrent operation.” 1A Norman J. SINGER, SUTHERLAND ON STATUTORY Construction, § 23.10 at 354 (5th ed.1992) (footnote omitted). The Supreme Court has held that where the “provisions in the two acts are in irreconcilable conflict, the later act to the extent of the conflict constitutes an implied repeal of the earlier one.” Posadas v. National City Bank, 296 U.S. 497, 503, 56 S.Ct. 349, 352, 80 L.Ed. 351 (1936) (citations omitted). The question is therefore whether the two statutes under consideration can rationally be reconciled — whether, in other words, they are capable of “concurrent operation.”
In the present case, a statute enacted in 1932 provided that defendants whose parole has been revoked should not receive credit for street time. More than half a century later, the Council directed that every person, without any stated exception, shall receive credit for time spent in custody or on parole. As to those defendants whose parole has been revoked, the two statutes are in obvious and irreconcilable conflict. The contradiction between them goes to the very heart of Section 24-431(a), for, if that provision is construed as inapplicable to defendants whose parole has been revoked, it will not provide any discernable benefit to anybody. “Reconciliation” of the two statutes is thus a mirage. A device capable of harmonizing *1109two such mutually antagonistic enactments— the Montagues and Capulets of parole— would be a magic wand indeed. Such an instrument could just as readily reconcile the Eighteenth and Twenty-First Amendments, so that Prohibition and legal liquor could enjoy “concurrent operation” and bring joy to boozers and blue noses alike.
“Statutory interpretation is an imperfect science, and generalities about statutory construction help us little. They are not rules of law, but merely axioms of experience.” Speyer v. Barry, 588 A.2d 1147, 1165 (D.C. 1991) (citation omitted). The presumption against implied repeals is a helpful aid in the interpretation of statutes, but it was not designed to permit the court to make a law mean, the opposite of what it says. The canon on which the Commission relies simply will not take it where the Commission seeks to go.
There is also a compelling, case-specific reason why we should not accord decisive weight here to the presumption against implied repeals. That presumption is based on the premise
that when a legislature contemplates passing a new statute it is careful to search the statute book for any statute that might overlap the new one, and if it finds any such older statute ... in force it repeals it explicitly when passing the new one. “The presumption against implied repeals is founded upon the doctrine that the legislature is presumed to envision the whole body of the law when it enacts new legislation.” 1A SUTHERLAND STATUTORY CONSTRUCTION § 23.10 at p. 346 (4th Ed.1985).
Edwards v. United States, 814 F.2d 486, 488 (7th Cir.1987) (Posner, J.). But if the legislators who passed the later statute were not apprised of the earlier enactment, then the justification for applying this presumption is fatally undermined.
In the present case, as I show in more detail below, there is persuasive and pragmatic contemporaneous evidence that the Council did not consider the earlier statute at all. Specifically, in a memorandum explaining the operation of the GTCA issued twelve days after the new law’s effective date, Deputy Corporation Counsel Margaret L. Hines explained that “[t]he apparent reason for the bill’s failure expressly to repeal the inconsistent language in D.C.Code § 24-206 (1981) was that no one discovered the inconsisten-cy_”4 Ms. Hines was writing almost contemporaneously with the passage of the Act, and her information was surely far more reliable than any speculation by this court, years after the fact, as to why Section 24-206(a) was not repealed in so many words.5
Under these circumstances, I cannot agree that the presumption against repeals by implication trumps the plain terms of Section 24-431(a). If, as Ms. Hines suggested at the time, the members of the Council were unaware of Section 24-206(a), then their failure expressly to repeal it lacks any probative value. If, on the other hand, the legislators had Section 24^-206(a) in mind, then it is surely unlikely, to say the least, that they would have cast Section 24-431(a) in the all-inclusive language found in that provision unless they intended the later enactment to trump the earlier one.
Consider what must have happened if Judge Ferren has it right. The drafters and the Council, according to him, are supposed to have been aware of the provisions of Section 24-206(a). They wanted to retain that statute in effect and to reaffirm the rale that a defendant receives no credit for street time if his parole is revoked. They also wished to *1110reaffirm street time credit for those defendants whose parole was not revoked (and who did not need the credit anyway). “I know how to do that!” the leader of the drafting team must have exclaimed or thought. “I will write a provision which says that every person shall receive credit for tune spent ‘in custody or on parole.’ That way, everybody will know that you get no credit if your parole is revoked.” The Coun-cilmembers must then have read the finished product and joyfully proclaimed: “Right on! You’ve written it to say exactly what we meant!” I respectfully suggest that this scenario is implausible, and that if the drafters and the legislators intended what my colleagues say they intended, then they could not have written and enacted the statute as it now reads.
D. The legislative history.
The majority deals at some length with the legislative history of the GTCA. Given what I regard as the unambiguous language of Section 24-431(a), it is not obvious that resort to legislative history is called for at all. See, e.g., Duvall v. United States, 676 A.2d 448, 452-53 (D.C.1996).6 In any event, the legislative history, as described in the majority opinion, may arguably tilt in some measure in favor of Judge Ferren’s position, but it is inconclusive with respect to the issue before us.7
As Judge Ferren points out, the original version of Section 5(a) authorized credit for time spent “in custody,” but not on parole. Maj. op. at pp. 1090-1091. Section 5(d) as initially drafted, however, would have provided as follows:
(d) In any case in which parole is revoked for violations of the conditions of parole and the person is recommitted to serve the remainder of the maximum term, the person shall not forfeit good time credits earned while on parole.
(Emphasis added.) Obviously, the author of this draft of Section 5(d) intended defendants to receive credit for street time notwithstanding the revocation of parole.
The proposed legislation went through a number of successive versions, which did not contain the language italicized above. See maj. op. at pp. 1090-1092. Ultimately, however, the Judiciary Committee added language, subsequently enacted as Section 24-431(a), to the effect that “[ejvery person shall be given credit ... for the time spent in custody or on parole as a result of the offense for which sentence was imposed.”
The majority says that the Judiciary Committee proposed this language, and the Council enacted it, all “without explanation.” In my opinion, the explanation is not hard to find. The Council had before it a proposal that all defendants receive credit for street time. There was a competing proposal which would have denied such credit to those defendants whose parole had previously been revoked. The trend, for a while, appeared to be in favor of the latter approach, but a final choice had to be made.8 The Committee *1111reported a bill that provided credit for street time for all defendants, regardless of whether parole had been revoked. The Council enacted the bill in that form. That is the explanation.
The reader may think it odd that the amount of time a defendant must spend in prison is to be reduced by a period that he spent at liberty, even when he has abused that liberty by violating his parole. I have wondered myself why this should be so.9 In my opinion, however, the legislature has decreed in unambiguous language that all defendants shall receive credit for street time. It is not the court’s role to question that decision.
II.
EXECUTIVE CONSTRUCTION
A. Introduction.
The majority’s interpretation of Section 24-431(a) is contrary not only to the unambiguous language of that provision but also to its construction by the District of Columbia officials charged with its administration and enforcement. The executive branch of the District government adopted that construction less than two weeks after the enactment of the GTCA. Three different District of Columbia agencies have now consistently adhered to it for an entire decade. In conformity with a formidable array of precedents which we have already applied to the very statutes under consideration in this case, see Luck I, supra, 617 A.2d at 515, we are bound to accept the executive construction if it is a reasonable one. Here, the interpretation by the Corporation Counsel, the District of Columbia Department of Corrections (DOC), and the District’s Board of Parole (BOP) is consistent with the statutory text and eminently reasonable. Given our unambiguous decision in Luck I, my colleagues’ refusal to accord appropriate weight to the interpretation of the statute by the District’s officers and agencies is contrary to M.A.P. v. Ryan, supra, 285 A.2d at 312, and passing strange besides.
An understanding of the background of the executive construction is important. The proposed legislation which became the GTCA had the support of the executive branch of the District of Columbia government. Hal-lem Williams, the Director of the DOC, testified in favor qf its passage. Indeed, he proposed certain revisions which the Council subsequently adopted.10 There is no doubt that members of the executive branch followed with some interest legislative developments relating to the proposed statute. The construction of the GTCA by District of Columbia officials must be assessed in the context of their role during and immediately after the enactment of the new law.
B. Corporation Counsel’s interpretation of the GTCA
Less than two weeks after the GTCA became effective, the Deputy Corporation Counsel prepared a memorandum for the DOC- in which she responded to various questions relating to the meaning of the new legislation. In that memorandum, Ms. Hines wrote, inter alia, as follows:
[Question]. Is § 5(a) of the act11 inconsistent with D.C.Code § 24-206 (1981)?
[Answer]. Yes. Section 5(a) of the act gives a recommitted parole violator a credit on the maximum term equal to the time served on parole.
*1112At the conclusion of her answer to this question, Ms. Hines explained that the Council was apparently unaware of the inconsistent provision in Section 24-206(a) when it enacted Section 24-431(a). See page 1109, supra.
On September 16, 1987, Patrick S. Glynn, the General Counsel for the USPC, wrote a letter to Corporation Counsel Frederick D. Cooke, Jr., in which he expressed his disagreement with Ms. Hines’ interpretation. Mr. Glynn argued that “a specific statute must always take precedence over a statute of general applicability, regardless of priority of enactment.” He also expressed the view that “the Councilmembers could not have intended to benefit a category of offenders that includes many of our most dangerous recidivists.”
On October 30,1987, Mr. Cooke responded to Mr. Glynn’s submission with a comprehensive five-page letter in which he discussed the meaning of Section 24-431(a) in considerable detail. Mr. Cooke noted, inter alia, that one of the principal purposes of the GTCA was to relieve prison overcrowding, and that “construing [Section 24-431(a) ] to provide for credit against the maximum sentence for time served on parole, even when parole is later revoked, accords with this principal purpose.” Addressing the legislative history of the GTCA, Mr. Cooke quoted the section-by-section analysis of the statute in the Report of the Judiciary Committee. In that Report, the language that “ended up” as Section 5(a) was described as follows:
Requires that a person be given credit for time spent in custody and time spent on parole.
Committee Repoet, at 3. Mr. Cooke pointed out that the Report specified no exceptions to the foregoing requirement, and he wrote that
[i]f the last sentence of D.C.Code § 24-206(a) (1981) had been brought to the Committee’s attention, and the Committee had intended that sentence to remain an exception, it would likely have so indicated in the section-by-section analysis.[12]
Finally, the Corporation Counsel stated:
[Y]our limiting construction of the phrase “or on parole” in § 5(a) of the act renders that phrase superfluous. For if that phrase means only what you have construed it to mean, its elimination would not change the state of the law in any way. This is so because pre-existing law makes quite clear the general rule, namely that time served on parole is time served in fulfillment of the maximum sentence.
Of course, “... a court must, if possible, give effect to every phrase of a statute so that no part is rendered superfluous.” National Insulation Transp. Committee v. Interstate Commerce Comm’n, 221 U.S.App. D.C. 192, 196, 683 F.2d 533, 537 (1982).
C. Implementation by the agencies.
The other District of Columbia agencies concerned with the implementation of the GTCA have likewise construed Section 24-431(a) as providing for credit for street time irrespective of whether parole is subsequently revoked. On May 22, 1987, in conformity with the Hines Memorandum, the DOC issued an Order which provided as follows:
Every resident returned to custody as a parole violator shall be given credit for time spent on parole after 11 April 1987 until the time that the parole violation warrant is executed.
DOC Order 4340.2, quoted in Duck I, supra, 617 A.2d at 512. On February 19, 1988, the same agency adopted a regulation which states:
Revocation of parole shall not result in a loss of credit, for the time spent on parole, toward service of the sentence on which parole was granted.
28 DCMR § 601.7 (1988). It appears to be undisputed that, in conformity with these regulations, the BOP has granted credit for *1113street time to many hundreds of parolees whose parole has been revoked.
D. Luck I and M.A.P. v. Ryan.
The judiciary is the final authority responsible for deciding issues of statutory construction, Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837, 843 n. 9, 104 S.Ct. 2778, 2781 n. 9, 81 L.Ed.2d 694 (1984), for “[i]t is emphatically the province and duty of the judicial department to say what the law is.” Marbury v. Madison, 5 U.S. (1 Cranch) 137, 177, 2 L.Ed. 60 (1803); see also Harris v. District of Columbia Office of Worker’s Compensation, 660 A2d 404, 407 (D.C.1995). Nevertheless, as we reiterated in Luck I — a case in which, as here, the relationship between Sections 24-206 and 24-431(a) was at issue—
[t]his court accords “great weight” to any reasonable interpretation of a statute by the agency charged with its administration, and ... this is particularly true where, as here, we have a contemporaneous construction of a statute by the [agency] charged with the responsibility of setting its machinery in motion and making the parts work efficiently and smoothly while they are yet untried and new.
617 A.2d at 515 (quoting, inter alia, Norwegian Nitrogen Products Co. v. United States, 288 U.S. 294, 315, 53 S.Ct. 350, 358, 77 L.Ed. 796 (1933) (Cardozo, J.)).
I am at a loss to understand how, in light of M.A.P. v. Ryan, the majority regards itself as free to proclaim that no deference at all is due to the construction of the GTCA by the officials whose function it is to administer it. I find the explanation in the majority opinion to be quite unpersuasive. In Luck I, according to Judge Ferren, this court accorded great weight to the DOC’s interpretation “merely to buttress a conclusion we already had reached.” Judge Ferren implies, in other words, that the “great weight” language was dictum and that we can disregard it at our caprice.
With due respect, this is a serious misreading of our opinion in Luck I. In that case, we rejected a prisoner’s contention that under the GTCA, he was entitled to credit for street time spent on parole prior to the effective date of the Act. In our unanimous opinion, which Judge Ferren joined, we stated in detail our reasons for refusing to accept the construction of the statute urged upon us by the prisoner. Luck I, 617 A.2d at 512-15. One of those reasons was that the DOC had construed the Act in a manner contrary to the prisoner’s position, and that dispositive precedent required us to accord great weight to the agency’s views.
There is nothing in Luck I to suggest that the “great weight” discussion was less significant than any other portion of the opinion. Plainly, that discussion was not a mere add-on which we included just for fun. On the contrary, we explicitly “factor[ed] into our calculus ... [the] administrative construction of the GTCA and its interplay ivith Section 21-206.” Id. at 515 (emphasis added). Obviously, a point that was factored into our calculus, and was thus part of our holding, could not be dictum. It is not at all clear to me, and it cannot be clear to Judge Ferren, that in Luck I, the court would have reached the result that it did if the administrative construction had been to the contrary.13
Judge Ferren also argues that even if Luck I requires us to give some weight to the executive construction of the GTCA, there is no reason for “absolute obeisance.” This is, of course, quite correct; the ultimate responsibility for construing the statute devolves upon this court. Chevron, supra, 467 U.S. at 843 n. 9, 104 S.Ct. at 2781 n. 9. But *1114“great weight” means great weight, not an inconsequential milligram. The question before us is whether the interpretation of the GTCA by the District of Columbia officials who enforce it is a reasonable one. Id. at 845, 104 S.Ct. at 2783. In this case, those officials have construed the act in a manner consistent with its unambiguous language, and their construction is manifestly reasonable.
E. “Great weight” and the deference due.
“[T]he deference which courts owe to the interpretation by agencies of statutes which they administer is at its zenith where the administrative construction has been consistent and of long standing.” James Parreco & Son v. District of Columbia Rental Hous. Comm’n, 567 A.2d 43, 48 (D.C.1989) (citation omitted). The executive construction of Section 24-431(a) by District of Columbia officials has been consistent for almost a decade.
In Luck I, we applied the “great weight” principle solely on the basis of DOC Order No. 4340.2. In the present case, the force of the DOC’s position is enhanced by the BOP’s practice over a period of ten years14 and, especially, by the interpretation of the relevant provisions by the Corporation Counsel.15 The view of the Corporation Counsel as to the meaning of local statutes, “while not binding on this court, is entitled to great weight.” National Org. of Women v. Mutual of Omaha Ins. Co., 531 A.2d 274, 278 (D.C. 1987). In a context such as the present one, in which the Corporation Counsel acted in his capacity as legal adviser to District of Columbia agencies, rather than as a party to contested litigation, we should adopt the Corporation Counsel’s construction “unless plainly unreasonable or contrary to ascertainable legislative intent.” Jordan v. District of Columbia, 362 A.2d 114, 118 (D.C.1976) (quoting Williams v. W.M.A. Transit Co., 153 U.S.App. D.C. 183, 189, 472 F.2d 1258, 1264 (1972) (Leventhal, J.)).16
The views of the Corporation Counsel are especially significant in this case. Corporation Counsel’s responsibility to represent the interests of the District and its citizens from a law enforcement perspective often places him in an adversarial position vis-a-vis the claims of prisoners. See, e.g., Luck I, supra; Winters v. Ridley, 596 A.2d 569, 576-79 (D.C. 1991) (per curiam);17 Abdullah v. Roach, 668 A.2d 801 (D.C.1995); White v. Hyman, 647 A.2d 1175 (D.C.1994). Indeed, the District’s position in successive cases involving Sections 24-206(a) and 24-431(a) — Corporation Counsel opposed the prisoner’s more extreme claim in Luck I but supported Noble’s more modest one here — reflects an objective and impartial approach, a circumstance that should reinforce our disposition to accord weight to the District’s construction.
The USPC contends that “[t]he [cjourt owes no special deference” to the DOC’s *1115interpretation of Sections 24-206 and 24-431(a). It further argues that because it (the USPC) is also entrusted with administering District of Columbia parole laws, its interpretation “cannot be ignored.” In my view, the first of these contentions is foreclosed by our opinion in Luck I. With respect to the USPC’s second point, I agree that the Commission’s views should be given some consideration. I note, however, that federal appellate courts have rejected the USPC’s attempt to apply federal standards to District of Columbia legislation. See, e.g., Thomas v. Brennan, 961 F.2d 612, 617 (7th Cir.1992). Moreover, the United States Court of Appeals having certified the present case to this court in order to resolve a controlling question of District of Columbia law, it would be somewhat incongruous for us to be unduly deferential to the views of a federal agency as to the proper construction of our local statutory scheme.18
III.
STRICT CONSTRUCTION OF PENAL STATUTES
Noble further argues that Section 24-431(a) is a statute governing criminal penalties, and that if we find its language and executive construction inconclusive, then we should resolve any ambiguity in his favor. We have described the principle that criminal statutes are to be strictly construed as a “secondary” rule of construction, which can “tip the balance in favor of criminal defendants only where, exclusive of the rule, a penal statute’s language, structure, purpose and legislative history leave its meaning genuinely in doubt.” Lemon v. United States, 564 A.2d 1368, 1381 (D.C.1989) (citation omitted); Luck I, supra, 617 A.2d at 515. The rule of strict construction “only serves as an aid to resolving an ambiguity; it is not to be used to beget one.” Callanan v. United States, 364 U.S. 587, 596, 81 S.Ct. 321, 326, 5 L.Ed.2d 312 (1961). If we assume, however, that the language and executive construction of the GTCA leave any room for doubt as to the Act’s meaning, then this is the kind of case in which Noble and others similarly situated are entitled to the benefit of that doubt.
“The rule that penal laws are to be construed strictly is perhaps not much less old than construction itself.” United States v. Wiltberger, 18 U.S. (5 Wheat.) 76, 95, 5 L.Ed. 37 (1820) (Marshall, C.J.). It applies not only to interpretations of the substantive ambit of criminal proscriptions, but also to the penalties they impose. Lemon, supra, 564 A.2d at 1381 (citing Bifulco v. United States, 447 U.S. 381, 387, 100 S.Ct. 2247, 2252, 65 L.Ed.2d 205 (1980)); see also Luck I, supra, 617 A.2d at 515. The rule “embodies the instinctive distaste against men [and womenj languishing in prison unless the lawmaker *1116has clearly said they should.” United States v. Bass, 404 U.S. 336, 348, 92 S.Ct. 516, 523, 30 L.Ed.2d 488 (1971) (citation omitted); Luck I, supra, 617 A.2d at 515.
In the present case, the USPC essentially contends, and the majority holds, that Section 24-431(a) should be read as meaning something quite different from what its words seem so plainly to say. As we explained in District of Columbia v. Riggs Nat’l Bank, 581 A.2d 1229 (D.C.1990), however, “[sjtatutes imposing penalties mil not be construed to include anything beyond their letter, even though it may be within their spirit.” Id. at 1262 (emphasis added) (citations omitted).
Regardless of what we may think the Councilmembers had in mind, Riggs tells us that we ought not to countenance a restriction upon a defendant’s liberty unless we are satisfied that such a restriction is within the letter of what the Council said. The text of a statute is not to be stretched or expanded to put men or women in prison or to keep them there. Here, the legislature decreed that every person in custody or on parole shall be entitled to credit for street time. Even if— and it is a very big “if’ — the majority’s assessment of the Council’s subjective intent were correct, the authorities I have cited would preclude the construction of this penal statute beyond its language where the effect of that construction would be to impair the liberty of the citizen.
IV.
CONCLUSION
In its brief as amicus curiae, the District of Columbia informs us that during the period from 1987 to 1995, the BOP revoked the parole of an average of approximately one thousand offenders per year. There have thus been about ten thousand parole revocations since the GTCA came into effect. We have no information as to how many of the defendants whose parole was revoked have been released from the custody of the DOC, but the number is obviously quite substantial. Each defendant so released has received credit for street time spent on parole since the effective date of the Act. Under the majority’s construction of the GTCA, all of these defendants should have been required to serve additional time in custody. Some of them should doubtless still be in prison.
The potential impact of the majority’s ruling should not be underestimated. I quote from the brief filed by the District of Columbia:
If the United States’ interpretation prevails in this case and the [cjourt rules that D.C. offenders have no entitlement to street time credit, the ruling would have a significant effect on the administration of the District’s prisons, and could create chaos in the retroactive adjustment of the sentences of parole-violators. Many such offenders have already been released from their sentences with credit for time spent on parole. The possibility that the District might have to search for and reincarcerate ex-offenders who have been told that their sentences have lapsed would create confusion and ill-will in the District’s prison system, and would aggravate over-crowding in the system.
(Footnote omitted.)
The court’s decision today is being delivered by a house divided. The construction of the GTCA which I have urged in this dissenting opinion has also been adopted by the United States District Judge who initially heard this case, see Noble v. United States Parole Comm’n, 887 F.Supp. 11, 12-14 (D.D.C.1995) (Noble I), by Judge Alprin of the Superior Court, see Beaty, supra,19 and by the Corporation Counsel, the BOP, and the DOC. The USPC and one federal appellate court, however, have taken a different position, see Tyler v. United States, 929 F.2d 451 (9th Cir.1991), cert. denied, 502 U.S. 845, 112 S.Ct. 142, 116 L.Ed.2d 108 (1991),20 and *1117District of Columbia prisoners in federal custody whose parole has been revoked have not received credit for street time and have spent more time behind prison walls than their otherwise similarly situated counterparts at Lorton.
The liberty interests of many citizens are at issue in this case. The District of Columbia advises us that the United States Court of Appeals for the Tenth Circuit has stayed proceedings in a case raising the same issue pending this court’s ruling in the present case. Johnson v. Kindt, No. 96-6154 (10th Cir.).21 The question certified to us is undoubtedly one of exceptional public importance. I therefore believe that our federal appellate colleagues should receive an answer to the certified question from our full court, sitting en banc.
I respectfully dissent.
. Noble claims that the case as a whole, and not merely the issue of executive construction, is governed by Luck I and Franklin v. Ridley, 635 A.2d 356 (D.C.1993). In both of these cases, however, the parties assumed that Section 24-431 (a) confers credit for street time served after the effective date of the GTCA, regardless of whether or not parole has been revoked. The opinions for the court were written in conformity with that assumption. The United States Parole Commission ("USPC" or "the Commission") was not a party in either case, and the position which the Commission is presenting to us here was not argued to the court in Luck I or in Franklin. Under these circumstances, I do not consider either Luck I or Franklin to be controlling authority in the present case. See, e.g., District of Columbia v. Sierra Club, 670 A.2d 354, 360 (D.C. 1996).
. See Council op the District of Columbia, Committee on the Judiciary, Report on Bill 6-505, District of Columbia Good Time Credits Act of 1986, (Nov. 11, 1986) (hereinafter Committee Report).
. The reader is invited to decide for himself or herself whether the purported ambiguity to which Judge Ferren refers, see, e.g., maj. op. at p. 1105 n. 35, is real or imaginary.
. See Memorandum of April 23, 1987 from Margaret L. Hines, Deputy Corporation Counsel, to Walter B. Ridley, Acting Deputy Director of Operations, Department of Corrections, entitled "Implementation of the District of Columbia Good Time Credits Act of 1986, D.C. Law 6-218.”
. Contrary to the final paragraph of Judge Fer-ren's final footnote, I am not suggesting that Ms. Hines was guilty of the "separation of powers" equivalent of industrial espionage, or of some other comparable legerdemain, and then of leaking inside information. As a matter of common sense, an executive branch attorney working contemporaneously for the enactment of a proposed statute can be expected, quite legitimately, to know what is going on. So far as I am aware, there is no taboo in effect against communication between the proponents of a bill and the legislators who must decide whether, and in what form, it is to be enacted.
. "It is elementary in the law of statutory construction that, absent ambiguity or an absurd or unreasonable result, the literal language of a statute controls and resort to legislative history is not only unnecessary but improper.” Elm City Broadcasting Corp. v. United States, 98 U.S.App. D.C. 314, 319, 235 F.2d 811, 816 (1956) (citation omitted); Duvall, supra, 676 A.2d at 452. In this case, the language of Section 24 — 431(a) is clear and unambiguous. Because we are dealing here with two statutes rather than with one, however, and because the presumption against implied repeals must be incorporated into our analysis, an inquiry into legislative history may be appropriate notwithstanding the lack of any ambiguity.
.The presentation of different proposals to the Council of the District of Columbia mirrors the existence of different approaches in other jurisdictions; some statutes deny credit for street time where parole has been revoked, some authorize it, and some leave the issue to the discre*1111tion of the parole authority. See 67A C.J.S. Pardon and Parole § 82(a), at 153-54 & im. 76-80 (1978 & Supp.1996).
.But cf. People v. Sims, 38 Mich.App. 127, 195 N.W.2d 766, 768 (1972) (quoting Michigan statute):
A parole granted a prisoner shall be construed simply as a permit to such prisoner to go without the enclosure of the prison, and not as a release, and while so at large he shall be deemed to be still serving out the sentence imposed upon him by the court, and shall be entitled to good time the same as if he were confined in prison.
. Mr. Williams criticized a provision contained in the bill, as originally submitted, which would have authorized credit for street time spent on probation. This provision was subsequently deleted from the statute as enacted.
. Section 5(a), as previously noted, was codified as D.C.Code § 24-431(a).
. Mr. Cooke expressed his agreement with Ms. Hines’ conclusion that Section 24-206(a) probably was not brought to the Committee's attention at all.
. Judge Ferren has devoted a major part of his opinion to a discussion of the pros and cons (mostly cons, according to him) of judicial deference to executive construction in this kind of case. In my opinion, Luck I is dispositive as to the weight to be accorded to that construction in the present case. Accordingly, I will not prolong this dissenting opinion by debating the question whether, and to what extent, we would be obliged to defer in this case if Luck I had not been decided. I suggest, however, that Justice Cardozo's opinion in Norwegian Nitrogen Products Co., 288 U.S. at 315, 53 S.Ct. at 358, quoted in Luck I, as well as the numerous cases that have followed Norwegian Nitrogen Products Co., all contemplate that courts should accord great weight to agency construction in a substantially broader category of cases than Judge Ferren suggests.
. See National Treas. Employees Union v. United States Merit Sys. Protection Bd., 240 U.S.App. D.C. 51, 72-73, 743 F.2d 895, 916-17 (1984) (administrative construction by two agencies).
. In one rather startling passage of his opinion, Judge Ferren tells us that the DOC "apparently relied in its analysis exclusively on the Hines memorandum from the Corporation Counsel’s office.” ilia/, op. at p. 1098. He adds that this reliance was "entirely appropriate” but that it nevertheless "reveals the absence of any expert input by the [DOC] itself.” Id. From this, Judge Ferren concludes that we haye before us "entirely a legal question” and that there is no reason to accord the agency’s view any weight. Under this theory, an agency that wants the court to defer to its judgment can most effectively attain this end by declining to obtain legal advice.
. The Corporation Counsel is the highest ranking legal officer in the District's executive branch. His position is roughly analogous, in this regard, to that of the Attorney General of a state. In the absence of controlling judicial authority, courts accord great weight to the opinions of state attorneys general with respect to the construction of state statutes. See, e.g., Phyle v. Duffy, 334 U.S. 431, 441, 68 S.Ct. 1131, 1135-36, 92 L.Ed. 1494 (1948); McDowell v. Good Chevrolet-Cadillac, 397 Pal 237, 154 A.2d 497, 501 (1959); 2B Sutherland, supra, § 49.05 at 16 & n. 7; see also Rodriguez-Padron v. INS, 13 F.3d 1455, 1460 (11th Cir.1994) (deportation case; United States Attorney General’s reasonable interpretation of statutory immigration scheme is entitled to deference). The authorities in this jurisdiction according great weight to the Corporation Counsel’s opinions are thus consistent with the case law elsewhere.
.In Winters, the District successfully argued that prisoners who had been convicted of first-degree murder were not entitled to credit for good time.
. The District contends that the executive construction of the GTCA should be accorded an especially high level of deference because the Council of the District of Columbia is said to have acquiesced in it. The District points out that in 1988, 1991 and 1994, the Council made significant changes in the GTCA as a result of judicial or administrative interpretations with which the Council disagreed. See, e.g., Winters, supra, 596 A.2d at 571 (Schwelb, J., concurring) (describing the Council's "swift and emphatic” reaction against federal court ruling authorizing good time credit for first degree murderers).
There is some support in the case law for the District’s position. "Acquiescence by Congress in an administrative practice may be an inference from silence during a period of years.” Norwegian Nitrogen Co., supra, 288 U.S. at 313, 53 S.Ct. at 357; see also EEOC v. Associated Dry Goods Corp., 449 U.S. 590, 600 n. 17, 101 S.Ct. 817, 823 n. 17, 66 L.Ed.2d 762 (1981); Marshall v. District of Columbia Rental Hous. Comm'n, 533 A.2d 1271, 1276 (D.C.1987). "[A] consistent administrative interpretation of a statute, shown clearly to have been brought to the attention of Congress and not changed by it, is almost conclusive evidence that the interpretation has congressional approval.” Kay v. FCC, 143 U.S.App. D.C. 223, 231-32, 443 F.2d 638, 646-47 (1970) (emphasis added) (footnote omitted). "Legislative silence cannot mean ratification, [on the other hand], unless, as a minimum, the existence of the administrative practice is brought home to the legislature.” Thompson v. Clifford, 132 U.S.App. D.C. 351, 361, 408 F.2d 154, 164 (1968) (footnote omitted).
In the present case, there is no direct evidence that the Councilmembers were aware of the disfavored executive construction; at most, the Council’s reaction to the construction by courts or agencies of other provisions suggests, but does not prove, that our legislature knew at relevant times what the DOC was doing. Accordingly, the failure of successive Councils to amend the statute, while perhaps supportive in some measure of the District’s position, is not conclusive.
. The District informs us that its position in this case has also been sustained in several other unreported Superior Court cases.
. In Tyler, the court rejected the interpretation of the GTCA, a District of Columbia statute, by District of Columbia officials, and concluded that Section 24-431(a) did not implicitly repeal Section 24 — 206(a). With due respect for the views of the court in Tyler, I am not at all persuaded by the decision in that case. Cf. Luck I, supra, 617 A.2d at 514 n. 6 (rejecting Tyler analysis); see *1117also Beaty v. Ridley, supra, in which Judge Alprin concluded that the Tyler case “improperly interpreted D.C.Code § 24-206(a) to preempt the broad language of the GTCA,” and pointed out that under Tyler, there would be few if any instances in which Section 24-431(a) would apply.
. In Johnson, according to the District, the trial judge adopted the District’s construction of the GTCA.