Maine’s LURC Rules Favorably Toward Plum Creek’s Proposal to Develop Wildlands of Moosehead Lake Region: NFN and FEN-RESTORE Respond

During the course of the Autumn and Winter of 2007-08, RTNA worked extensively with Native Forest Network-Gulf of Maine (NFN) and other groups in Maine to stop Plum Creek Timber and Real Estate’s proposed massive development of the Moosehead Lake Region in northern Maine’s North Woods. Part of the Great North Woods of eastern North America-this particular region is the largest undeveloped wildland in the U.S. east of the Mississippi River; this region is home to such species such as the Canada lynx, black bear, wolves, moose, loon, and many other native species. This region has also for many generations supported a traditional local economy that included subsistence hunting; fishing, primitive recreation, and eco-tourism. Plum Creek plans to impose luxury vacation resorts, golf courses, gated communities, marinas, and more-along with significant introduction and expansion of roads and other invasive infrastructure.

With all the growing fervor over human-induced global warming-and the attendant discussions of alternative fuels, greenhouse-gas reductions, fuel-efficiency, and “green technology”-there is curiously little discussion regarding one of the most fundamental underpinnings of climate stability: ecosystem health and integrity, and attendant human land-use patterns. When there is such discussion-it usually takes us to far-off (albeit equally critical) bio-regions such as Amazonia or the Siberian taiga. There is virtually no discussion whatsoever regarding land-use policies in the U.S.-despite the rapidly-growing body of scientific evidence (not to mention the centuries’ worth of warnings from the Indigenous Peoples of these and other lands worldwide) that indicates the importance of ecosystem protection, preservation, and restoration in the fight against climate change.

In Deecember, 2008, RTNA representatives testified to Maine’s Land Use Regulatory Commission (LURC), specifically elucidating the critical connections between ecosystem health and integrity on the one hand and climate stability on the other. This was part of a series of public hearings that also included economic as well as other ecological concerns regarding this project-and included many individuals and organizations.

LURC’s recent decision has just come forth as of July, 2008, and-much to the dismay of many (including RTNA)-it is highly favorable toward PC’s egregious, profit-driven development plans for the Moosehead Lake Region.

What follows are detailed comments submitted by both Native Forest Network-Gulf of Maine (NFN) as well as Forest Ecology Network (FEN) and RESTORE: The Maine North Woods (RESTORE)-the two groups RTNA worked with extensively-regarding LURC’s unfortunate decision.

Activists in Maine and elsewhere have launched a major, characteristically bold, nonviolent direct-action campaign to stop this ridiculous corporate development in one of the last wild places in the eastern U.S. Thgis campaign enjoys widespread support from Maine residents, as well as people across New England and the U.S. Northeast.

To read more-including Plum Creek’s “vision” (and subsequent amendments to their plan) for the Moosehead Lake Region, LURC’s decision, and the Natural Resources Council of Maine’s responses to LURC’s decision, see:

http://www.nrcm.org/issue_plumcreek.asp

To learn more of FEN-RESTORE’s response to LURC’s decision, see:

http://www.savemoosehead.org/

NFN-Gulf of Maine’s comments are posted below:

NFN COMMENTS ON LURC STAFF/CONSULTANT RECCOMMENDATIONS FOR ZP 707:

After reviewing the LURC staff/consultant recommendations (hereafter referred to as “LSCR”), NFN feels it necessary to provide comments on this document.

We feel that LURC’s recommendations are not adequate for the approval of the proposed Concept Plan (“CP”) ZP 707.

To begin, it is clear that the proposed CP does not meet the standards necessary for rezoning. Upon entering a negotiations process with Plum Creek, LURC has concluded that the plan, in its current form, is unapprovable and does not conform to the regulatory review criteria. NFN would like to point out that: if the proposed CP met the criteria, there would be no need for negotiations or recommendations. This endeavor of LURC’s to negotiate with PC would not be taking place if the plan, as submitted, was approvable.

The fact is, LURC has entered into a negotiations process with Plum Creek (“PC”) with the intent to approve, rather than reject, the proposed Concept Plan ZP 707.  As a result, LURC staff and consultants have become advocates and promoters of a plan that will have devastating ecological effects on the Moosehead region, Maine and the planet Earth as a whole, and which will adversely affect the region’s economy and existing social structure.

It can be assumed that the recommendations within LSCR are (at least) partly a result of private meetings and conversations held between LURC staff/consultants and Plum Creek following the completion of the public/party hearings. With some additional tweaking by LURC staff, ZP 707 could be characterized as a catalyst for the statewide economic shift being promoted by the Brookings study entitled “Charting Maine’s Future”.  NFN views this study as a plan for Maine which does not respect the ecological, cultural, and economic needs of our communities, and a study which should not have an influence on or provide any basis for LURC staff and consultants moving into the role as advocates for Plum Creek’s plan.  (See our Post Hearing Brief “PHB”, section VII, pg 66, titled “Alternative Visions for North Woods Communities”)

I.) OUR MAJOR ISSUES WITH THE LSCR:

1.) IN GENERAL:

To generally summarize the LSCR, NFN finds that LURC is suggesting a series of “trade-offs” which have been formulated during private meetings and have been discussed previously with Plum Creek. The idea of the “trade-offs” is to try and pacify the opposition (by making it sound as though the recommendations are sensitive to environmental concerns) while ultimately benefiting the interests of Plum Creek’s investors (by approving the largest development ever proposed in Maine and compromising the largest undeveloped area east of the Mississippi River). NFN feels that “trade-offs” are not acceptable when attempting to negotiate with our planet’s integrity.

We feel that major concerns stated by NFN and other intervener groups have been completely overlooked by the LURC staff and consultants (some of which we will list below). There is little or no reference in the LSCR to many of the concerns NFN raised throughout the hearing process and summarized within our PHB.  NFN and other groups have made enormous efforts to outline the impacts we feel this plan would pose, and it is unacceptable to us that LURC would bypass or ignore much of the pertinent information we have provided.

To begin, we find that the LSCR solely addresses specific details within the plan and does not question the plan as a whole. It fails to recommend actual substantive changes within the plan and does not question the total amount of development or its overall impacts. It does not evaluate whether the proposed zoning is more appropriate for existing uses than current zoning. It does not take into account the fact that Plum Creek has repeatedly violated land-use laws in Maine and other places where it has operated. Although language clarifications have been recommended by LURC, it fails to address the concern raised at Party Hearings that unless an agreement is in legally-binding writing, Plum Creek can not be relied upon to act on basic recommendations or agreements sealed with a handshake (NFN PHB, pg 51). Also, the LSCR does not address the threat to the remote character of the region. For these reasons and the more detailed criticisms below, NFN will continue to oppose Plum Creek’s proposal, even with the addition of the LURC staff and consultant recommendations.

2.) ON IMPACTS:

Nowhere does the LSCR address or consider adverse social or economic impacts.

The LSCR has failed to consider or test the adverse ecological, economic and social impacts of the overall plan at the rezoning stage. The cumulative impacts of the proposed developments are not addressed. LURC’s own language suggests that the proposed CP will have adverse impacts, even with the recommendations in place (pg 107, rt column, end of 1st pgh).

Nor does it evaluate the specifications within the existing CLUP that require adequate protection of the following resources: cultural, air, archaeological, geological, historical, recreational, water and wetland, wildlife, or fisheries.

3.) ON MITIGATION OF THESE IMPACTS:

Adverse impacts are sometimes referred to as “potential”, but we feel it more suitable to refer to them as “predictable”. There will undoubtedly be adverse impacts from this development. One of LURC’s responsibilities is to decide whether or not these impacts can be properly mitigated. Instead of deciding that the adverse impacts from the plan as a whole would outweigh mitigation efforts, LURC has chosen to:

A) View the Conservation Easements (plus the Roaches and Bog Properties acquisitions) as the major players in environmental impact mitigation efforts, calling this “Offset Conservation”. (We feel that the “conserve some, destroy the rest” model is not viable and should not be used as an attempt to attain proper mitigation. Also, this relies too much on the Grantor/easement Holder/3rd party Holder (BPL) to properly assess adverse impacts within the easements.)

B) Continuing to allow industrial activities at all within the easements does not constitute as a proper balance of development or an adequate means of mitigation, in our opinion. People continue to refer to the easements as “protected areas” when in fact these areas will not remain untouched or allowed to return to a natural, restored state of existence. NFN opposes this use of language which defines the easements as “protected” or labels them as “Conservation Easements”, considering the continued allowance of industrial forestry with the introduction of new industrial activities (water extraction, septage spreading, wind generation facilities, etc…) within the easement areas. NFN does not endorse the easements (written by PC or revised by LURC) as viable means for true conservation and we oppose the use of the easements (including Balance, Legacy, Roaches and Bogs areas) as a form of impact mitigation for the development aspects of the CP.

C) Incrementally assess impacts vs. mitigation in a fractured scenario during the site-specific subdivision stages. (First, this places too much faith that proposed mitigation efforts will in fact work. We feel that when looking at the overall scenario, proper mitigation could never be attained and this should be addressed at the rezoning stage while rejection of the entire plan is still possible.  Second, these mitigation efforts would take place in the future, not now when the assessment of overall impact is critical to approval. Finally, Public Hearings are not guaranteed. It would be at LURC’s discretion whether or not to hold a Public Hearing during the subdivision stage, LSCR pg 59, pgh 1.)

D) In the LSCR, the only type of impact that was addressed in any detail was scenic impacts. LURC gave this a pretty thorough review and offered some substantive recommendations regarding the mitigation of this issue.

It appears that, rather than question the overall amount/size/nature of development and its appropriateness, LURC has put its priority in limiting visibility. In fact, the scenic values seem to be worth more to LURC than all of the Native Brook Trout streams combined, considering the word “scenic” appears throughout the entire LSCR. The recommendations for scenic impacts are referenced as an example at least 12 times in various sections within the document.

There are a few concerns with this:
If LURC can address this issue with thoroughness and detail at the rezoning stage, why are they putting off mitigation recommendations of other, more critical ecological impacts until the subdivision stage?
Does LURC feel that limiting visibility of the development is more important than the mitigation of ecological impacts, therefore placing visual values over ecological values?
Is there language within the regulations that supports the inequality of values, in particular with scenic values having more of an importance in the criteria than ecological values?
Why is the scenic impact issue such a priority to LURC? Does the study entitled “Charting Maine’s Future” have any influence in making this a priority?
This effort doesn’t change the increase of humans and human activity within the region and it certainly doesn’t mitigate any substantive adverse impacts from the plan.

To NFN, this reads as: “go ahead and build it, as long as it’s not completely visible it will be fine.” The problem with this approach is that, no matter how much of a vegetative buffer LURC is suggesting, whatever the vegetation is attempting to hide is still there. It may be less visible, but it is still adversely impacting the planet. It may be camouflaged, but it still exists. Behind the vegetative curtain will be converted forest, replaced by condos, mansions, golf courses, Starbucks, and what-have-you.

Between the “Offset Conservation”, mitigation of scenic impacts, and an enormous reliance on future mitigation efforts, it sounds like LURC is sold.

E) There are no recommendations for mitigation of adverse economic or social impacts mentioned within the LSCR.

4.) ON FINANCIAL COMPENSATION FOR MITIGATION:

LURC is requiring the turnover of both the Balance and Legacy easements, as well as other areas such as the Roaches and Bog Properties be mandatory before plan approval or further application processing, and deems the so-called “protection” of these areas integral to plan approval. Considering the monetary transactions that will take place with the turnover of the Legacy easement and the Roaches parcel, LURC is essentially recommending that PC be financially compensated to balance their development. If these areas are required for adequate “Offset Conservation” or adequate mitigation of impacts incurred by the development aspect, then why should PC be paid $35 million? It is the landowners own responsibility to effectively balance/mitigate their development. If PC receives money to balance their development, it could set a precedent allowing future corporations/landowners to receive monetary compensation for impact mitigation efforts.

5.) ON EASEMENT LEVERAGE:

NFN feels that it is completely unacceptable that LURC is using the leverage which PC has provided by offering the Conservation Easements in addition to the Concept Plan as a means for approval. It is our understanding that, by law, LURC cannot approve a proposed Concept Plan based on the addition of Conservation Easements. What the LSCR suggests is that LURC permits for development within the CP area and the processing of other development-related applications is entirely dependent on the sale/solidification of the easements including Balance, Legacy, and Roaches acquisition. This recommendation officially intertwines the approval of the plan with the solidification of the easements (with the agreement to turn over the easements within the suggested timeframe of 45 days after approval). Plum Creek has clearly used the easements as the key selling point of the plan, and it sounds like LURC has bought it.

6.) ON EASEMENT HOLDERS:

While it is a pro for LURC to be recommending that a Public entity like the BPL be the 3rd party easement holder, there is still an issue with allowing a private non-profit entity like Forest Society of Maine, The Nature Conservancy, or the Western Mountains Foundation to be the primary easement holder. This is not acceptable since there are problems of conflict of interest with these easement holders that were raised in the NFN PHB. The ability for the Public to have effective oversight is much stronger if the easement is held by a Public entity instead of a Private Non-Profit. Even if the BPL becomes the chosen easement holder, there still needs to be a stronger mechanism in place to ensure that there is effective oversight and enforcement of the terms of the easement.

7.) ON SPECIFIC EASEMENT ACTIVITIES:

It appears that LURC is not heeding the previously stated concerns regarding certain activities within the easements. While it is an improvement to recommend limiting septic spreading and water extraction to local uses only, this does not address the fact that there remain serious dangerous impacts to the health of area water quality and fisheries by allowing any additional septage spreading or water extraction in the easement lands. The developments would significantly increase both the production of septage sludge (which can include many toxins including household waste cleaners and chemicals, runoff from fertilizers and pesticides, and pharmaceuticals) and the extraction of water for potentially thousands of households (plus water for lawns, golf courses, and pools). Furthermore, Aqua Maine expressed plans to handle water operations for the resorts, and this would result in the largest private water company in the US (which makes increased profits proportionate to increased water extraction) having an incentive to extract increasingly large amounts of water from the local aquifers.

8.) ON DEMONSTRATED NEED:

It is our understanding that LURC must consider the demonstrated need of the community when approving a concept plan. After sitting through weeks of public and technical hearings and reviewing the information that was uncovered during these sessions, we feel that LURC is mostly disregarding Public interest and the needs of the community and has failed to test the ‘demonstrated need’ which they previously deemed an integral element to approval.

9.) ON THE OVERALL LURC PROCESS:

We feel that the overall process is a sham, and has mostly been in vain, considering that LURC has used only a small portion of the opposing information that was uncovered in testimony and during the hearings. We feel that, while a great many people came out to Public Hearings and voiced their opposition to Plum Creek’s plan, there are many more who were discouraged or intimidated from attending the Hearings that were dominated by a heavy police presence, paid for by Plum Creek.
LURC has not respected the voices of the people, begging them to reject this plan. Instead they have entered into a negotiations process with the corporation, with the intent to approve a plan which the people of Maine are against. Public outcry has been ignored. LURC may be throwing out a few crumbs, but we want the whole pie: intact.

10.) ON CONFLICT OF INTEREST AND THE LURC STRUCTURE:

We question the ability of LURC Commissioners to make a fair decision and promote a functioning democratic process, in light of the facts that the LURC Commission is an unelected decision-making body appointed by the Governor. We question whether the fact that Plum Creek’s lead lawyer, Severin Beliveau, is a major fundraiser and advisor to Governor Baldacci, and the fact that Plum Creek’s law firm, Preti Flaherty, has the Governor’s second-cousin, former Senator George Mitchell, serving as its Senior Counsel, has an influence on LURC’s approval of this plan.

11.) ON NEGOTIATIONS AT ALL:

We question whether or not it is within LURC’s authority at all to be engaged in negotiations with a landowner. It is of our understanding that a CP should either be approved as is, or denied by the Commission. NFN was never aware that LURC is authorized to amend a re-zoning proposal to make it approvable.

LURC had previously acknowledged that PC has been given enough opportunities to revise their plan. This is why the current version of the plan went through the hearing process to begin with. Now, it is LURC who is promoting and carrying out a revision of their own. This is unacceptable. Especially considering this revision is somehow exempt from the same review and critique that ZP 707 was required to go through by means of the hearing process.

The LURC recommendations are not based on sound science. LURC staff is not qualified to recommend changes, especially if there is no accumulation of new scientific data or accurate analysis of the recommended changes, or without an appropriate and thorough public review and comment period following.

If the CP is approved with the LURC recommendations in place, it will mean that the Commission has voted on a new plan that had a very minimal amount of review. This is because impacts from the recommendations/revisions have not been accurately assessed. Any revisions of a CP or any land-use rezoning plan, by natural law, inherently change the nature of the plan and thus change the impacts of the plan on its surrounding environment. The way the LURC-revised plan would relate to the proposed areas within the CP would be completely different than the plan we have just reviewed. All issue-related studies/assessments done previously are now in vain because a revised version is completely unique from the original proposal. All calculations incurred by these analyses are completely different from the original proposal. So, essentially, if the LURC revisions are accepted by PC, an entirely new CP will be created. NFN believes that this newly created plan should be subject to the same conditions of review as any rezoning application. An entirely new plan should go through the same review process that the former plan did. As a suggestion, NFN feels that an alternative and acceptable LURC response would be to deny the current proposal and state the reasons why, which would allow PC to file an entirely new application which would be subject to the same thorough and democratic review process as the current application was allowed.

II. SOME SPECIFIC CONCERNS RAISED BY NFN WHICH LURC HAS FAILED TO ADDRESS/CONSIDER IN THE LSCR (A BRIEF OVERVIEW):

Does not adequately assess at the re-zoning stage, the adverse impacts of the overall plan on: fisheries/streams/water quality (see NFN Post Hearing Brief pg 8-9); wildlife (PHB pg 10-11); climate change (PHB pg 12-14); accelerated resource uses by affluent people (PHB pg 15)
Does not address accelerated waste generation and the lack of local ability to handle increased waste, or impact on communities through which waste would be trucked and where waste would be dumped. Relies on landfill capacity in West Old Town that has not been approved and which is being opposed by local communities. (PHB pg 17)
Does not provide any assessment whatsoever of adverse social or economic impacts (PHB pg 21-47)
Does not make any specific suggestions for provisions concerning affordable housing, or address concerns that the Plan’s so-called “affordable” housing does not fall under Maine’s own affordable housing standards (PHB pg 43)
Does not effectively address conflict of interest (PHB pg 59)
Does not take into consideration rejection of the proposal ZP 707 and recommendation of alternative projects which would potentially benefit North Woods communities in ways the current proposal never could (see NFN PHB, section VII, pg 66)
Does not consider putting this proposal on hold until the new CLUP is developed and in effect. It is clear that the current CLUP is not designed to handle a development of this magnitude or deal with certain items proposed within the CP. At this point, the existing CLUP is an outdated tool being used in an enormously unprecedented proposal.
Does not suggest more inclusion of the public to monitor, inspect, survey, and report on any and all activities within the CP area. (see Community Monitoring suggestion, PHB section VII)
Does not evaluate further issues NFN has raised regarding the easements, including continued allowance of industrial activities at all within these areas (see PHB, pg 52-58)

III. THE FOLLOWING ARE LISTS OF PROS AND CONS WE HAVE FOUND IN THE LSCR:

1.) LSCR PROS (MOST PROS TAKE PLACE WITHIN EASEMENT RECOMMENDATIONS):

There are some suggestions within the LSCR which NFN sees as beneficial. Although some of these are sincerely addressing minor environmental concerns, distribution of control, and clarification of elusive PC language; most can be viewed as beneficial to LURC as well and will result in ease of management on their part, which must play a key role in why they are being suggested.

When looking at the proposal as a whole, though, we feel that these recommendations are minor and really only address details of the plan. This is unfortunate, since these details don’t make much of a difference in the big picture. Therefore, although some beneficial recommendations have been made, these are merely details and ultimately inadequate for the approval of ZP 707. In addition, many of the standards being proposed are subject to change depending on circumstances when evaluated at the subdivision stage, and really have no solid ground to begin with.

The “pros” section will be separated into 2 categories pertaining to A.) Easements and B.) General

A.) EASEMENT PROS:
Before we go any further, we would like to mention, again, that NFN DOES NOT condone the easements as they are written by PC, or revised by the LSCR (see section I, 3B, above). We also need to clarify that NFN does not condone the negotiations process at all (see section I, 11). We are merely attempting to outline the recommendations which we feel would be improvements.

MAT (management advisory team regarding forestry activities within easements) structured so IFW is responsible, removes PC and all other landowners from its membership, plus makes all documents available to public (p 86)
Reduces amount of subdivisions within easements from 25 to 5-10 (p 84) (CON: allowing subdivisions at all)
LURC has say in approval of land inspector (p 123) (although they need to add ability of Public to voluntarily offer this service and submit their findings in addition to land inspector, see NFN PHB “alternative vision”)
BPL has 3rd party oversight of easement activities/Holder performance and ensuring they have rights consistent with those of the Holder (p 77, footnote 76)
Clarifies specific clauses in easement language so as to avoid future conflicts with conservation vs. profit (pg 81)
Limit construction material removal/septic spreading/water extraction in easements to supply nearby communities (mapped and attached to easements) only (p 82) Although this might be an improvement, NFN still feels that there is still an issue with allowing these activities at all (see “cons” section, below).
Eliminates mining activities within easements (p 82)
With conservation values in mind, fixes open-ended PC language regarding structures and improvements within the easements to prohibit or limit proliferation of certain structures (p 85)
Tighten language/control of forestry certification programs and forestry practices within the easements(p 87/88)
Eliminate waiver of Grantor liability regarding public access in easements (p 90)
Tightens language regarding baseline documentation of easements (p 90)
Strikes PC proposed provisions regarding enforcement (p 91)
Tightens language regarding amendments of easement provisions (p 92)
Establishment of  community/stewardship funds before CP approval and solidification of said funds dependant on further processing of CP development-related applications (p 80/81)

B.) GENERAL CONCEPT PLAN PROS:

Attempts to protect scenic values by recommending tighter visibility standards than what PC is proposing: enforcing max bldg height provisions and standards on materials used for structures and docks throughout the plan area (attempt to make these “blend” into the landscape) (p 66) and adding vegetative buffer requirements (p 67) (Why not protect scenic values by rejecting the plan?)
Limits docks throughout plan area and eliminate PC’s vague language to define proposed water-related facilities (pg 64)
Minimizes power of homeowners associations to influence allowed activities (p 119, 123-124)
Deletes PC language to allow opening of view corridors (p 65)
Delete proposed PC language on noise standards and keeps existing standards instead (p 69)
Ensures that Roaches property will be used for primitive recreation only.  (Why can’t they suggest this for entire plan area?)
Have BPL govern peak-to-peak trails and receive PC’s loan (pg 112)

2.) LSCR CONS:
As stated before, there are many concerns of the parties which were ignored by LURC. The major concerns/criticisms we have with the LSCR are explained above in sections I and II. The following is a more specific list of “cons” which deals with more minor concerns raised when scrutinizing the details of the LSCR and in no way reflects NFN’s overall critique of the plan.

Eliminates proposed expansion of the “balance” conservation easement into development zones upon buildout, and instead continues to make that land (and potentially more) available for future development after the 30 year life of the plan (pg 61/91)
Allow more structures on shore areas/remove requirements for clustering (in certain areas)
No longer caps development
Allows for 3rd resort at Moose Bay
Limits, but continues to allow septage spreading and water extraction
Makes no reduction to the 2,025 allowed housing units and in fact, allows up to 2,000 of these to be individual house lots
Allows a waiver of the existing adjacency requirements, as specified in the CLUP
Fails to consider sensitive species habitat by not eliminating development in highly sensitive areas
Allows additional land within certain areas of the CP to be subject to rezoning at end of 30 year term (ex: Big Moose Mtn., Moose Bay, Brassua, Rockwood/Blueridge, Route 16 corridor, Beaver Cove), allowing more development than what is being proposed
No guarantee that PC will comply with the view corridor recommendations
Instead of removing environmentally sensitive areas from easements and donating, in fee, to the state, they suggest that these areas receive “special management protection”, which merely limits management and harvesting practices (pg 75)
$5,000 per year to stewardship fund is not adequate (pg 77/78)
Unlimited # of employee, caretaker, manager and so-called “affordable” housing units in certain development areas. This could mean an addition of over 1,000 more residents than what the development itself would bring!
Eliminates ability to rezone development areas to protection subdistricts for the 30 year life of plan.  (bottom pg 54)
Allows wind power generation within easements (p 82)
Allows unlimited amount of backcountry “huts” in easements of 5,000 sq feet and up to 40 ft in height (seemingly removing size requirements for these huts) (p 85)
No limitation to increase in or type of watercraft

IV. CONCLUSION:
In conclusion, we would like to say that NFN does not, in any way, endorse the proposed Concept Plan ZP 707, with or without the LURC staff and consultant recommendations in place.

Native Forest Network, Gulf of Maine

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