Final answer:
Criminal history is considered a static element by Andrews and Bonta and is not a criminogenic need, as it cannot be altered through interventions.
Step-by-step explanation:
According to Andrews and Bonta, the factor that is a static element and therefore should not be considered a criminogenic need is D) Criminal history. Static factors are those elements of an individual’s background that cannot be changed, such as the individual's past conduct or actions.
Criminogenic needs, on the other hand, are dynamic factors that can be changed and, if addressed, could reduce the likelihood of reoffending. These include issues such as substance abuse, lack of education, and unemployment. These are dynamic because interventions or changes in circumstances can alter them, unlike a person's criminal history which is immutable.