The Appointment of Michael Brown by George W

The appointment of Michael Brown by George W. Bush to be director of FEMA was an example of

A) a president appointing someone outside of his own party.
B) an appointment based on a lifetime of experience in that department's field.
C) a department head being nominated for their skill of administrating, but not experience.
D) Congress rejecting a president's nominee.
E) an appointment based on political connections and loyalty rather than qualifications and experience.