Container Deposit Scheme Advisory Group
The Department of Environment and Heritage Protection (EHP) is leading an investigation into state-based options for a container deposit scheme (CDS) in Queensland. While the introduction of a container deposit scheme has significant community support as it can provide litter reduction and resource recovery benefits, there are also impacts and cost considerations.
A Container Deposit Scheme Advisory Group has been established to assist EHP in the preparation of suitable options for public consultation including:
- Principles of a container deposit scheme
- Terms of Reference
- Advisory Group representation
- Member biographies and position statements
Principles of a container deposit scheme
Proposed scope and design principles
In examining the applicability of a container deposit scheme in Queensland, the scope and design of the model to be tested needs to be settled relatively quickly so that the costs, benefits and practicality of the proposed scheme can be fully identified for consideration by government.
The Advisory Group will play a substantial role in helping to scope the proposed model to be tested. As a starting point for identifying the model in question it would be useful to broadly agree the purpose of the model and scope of the scheme relying on some agreed design principles that can guide consideration.
As a starting point, the government is interested in developing a scheme that is consistent and complementary to the scheme to be developed in New South Wales. A longer term prospect is an Eastern Seaboard solution. Obviously a ‘best fit’ solution that suits Queensland’s unique circumstances is desirable.
Recognising that the actual shape of the scheme to be progressed will evolve iteratively through detailed Advisory Group and other discussions, it would be prudent to endeavour to firstly agree the broad objective or purpose of the scheme and a set of supporting design principles.
A first attempt at this, which involves the testing of certain assumptions, is set out below.
Description of a container deposit scheme
It is proposed that the scheme under consideration is:
“A container deposit scheme that involves the manufacturer charging a fixed amount (being a deposit) on a container, at the point of purchase of a regulated beverage container, with a monetary or non-monetary reward (equivalent in monetary value to the deposit) being provided when the container is returned according to the rules of the scheme.”
Focus and objectives of scheme
A proposed focus for the discussion by the Advisory Group is:
- Objective 1 - Reducing the litter impact from beverage containers in the away-from-home context.
- Objective 2 - Improving resource recovery, especially in regions, and providing benefits to jobs and the economy.
- Objective 3 – Enhance social benefits by encouraging community-based enterprises to participate in the scheme
It is recommended that the scheme must:
- Cover the whole state to ensure all Queenslanders have the opportunity and ability to recover their beverage containers – regional arrangements are necessary.
- Be cost-effective with minimal cost to the Queensland community.
- Be straightforward and convenient to use while providing public education and awareness and approaches to encourage participation.
- Recognise the potential financial and resource recovery impacts on existing recycling services and present opportunities to mitigate these impacts and minimising duplication of existing recycling infrastructure.
- Be flexible and responsive, with the ability to improve and adjust over time if circumstances change.
- Provide transparent mechanisms for accountability, including the ability to easily track the flow of monies and the quantities of recovered and recycled containers and materials.
- Provide clear and efficient governance arrangements.
- Consider other national and state packaging initiatives by government and industry either in place or proposed.
- Recognise the potential commercial impacts associated with a scheme.
- Be designed to prevent fraudulent behaviour.
- Utilise different collection methods to suit local circumstances and provide opportunities for multiple participants and beneficiaries.
- Have legislated features (eg. refund amount, container scope, container approval and labelling requirements and governance arrangements) to provide an enduring arrangement.
Terms of Reference
Significant work has been undertaken to look at options to reduce packaging impacts at the national level. While a number of states and territories have investigated container deposit schemes they are currently only implemented in South Australia and the Northern Territory. The New South Wales Government recently announced the introduction of a scheme by July 2017.
The Queensland Government has committed to investigate state-based container deposit schemes.
To give effect to this commitment the government has established an Advisory Group to assist in the investigation of options for container deposits in Queensland.
The government has also committed to investigate restricting the use of single-use plastic bags. The Advisory Group will also be used as the basis for separate consultation during this investigation.
Purpose of the Advisory Group
The purpose of the Advisory Group is primarily to:
- provide independent advice to EHP on options for state-based container deposit schemes to inform the preparation of an options paper
- assist in the development of an options paper to be used as the basis for public consultation
- provide necessary information relevant to a preliminary cost benefit assessment of options
- assist with public consultation on the options.
The Advisory Group will also be asked, where relevant, to provide advice to EHP in relation to options to restrict the use of plastic bags.
The advice will be taken into consideration along with other sources of information available to the department in relation to the development of options. While the group will aspire to a consensus position, in some cases it may be necessary to record differing opinions.
To ensure an equitable and independent mix of expertise, knowledge and attitude to container deposit schemes is provided, the Advisory Group will comprise representation from the following sectors:
- Resource recovery and recycling
- Local government
- Food and grocery.
EHP will chair the Advisory Group and provide secretariat support for the group.
Members will be expected to represent the views of their organisation and not the individual views of a company or business. Members should be in a position to be able to present views on behalf of the organisation and sector they represent. Additional representation may be invited where the Advisory Group identifies a need for specific advice or expertise.
Other stakeholders will also be invited to participate on the Advisory Group for consultation involving plastic bags and all Container Deposit Advisory Group members will be invited to take part on an ‘opt-in’ basis for these discussions.
Additional technical working groups may also be required in order to provide information and advice on specific issues. Membership will be invited on a needs basis depending on the issue to be discussed.
Representatives will not be remunerated for participation on the Advisory Group.
Term of the advisory group
The Advisory Group will remain active until June 2016. At such time the role and requirements for the group will be reviewed to determine whether the term of the group should be extended and the purpose and scope of works for the group amended.
Face-to-face Advisory Group meetings will be held at regular intervals with the representatives to decide a schedule of meetings at the first meeting. Out-of-session meetings may also be required where critical deadlines are to be met.
The department will co-ordinate and organise all Advisory Group meetings.
Agenda and agenda items
The department will undertake to circulate any papers and a draft agenda prior to each meeting. If members have items or information they wish to discuss at the meeting any papers or information for circulation to the group should be provided to the department ahead of the meeting to allow the information to be distributed.
Record of meetings
All record of meetings and papers prepared for meetings may be published on the department’s website, except where marked as commercial in confidence.
Roles and responsibilities
Environment and Heritage Protection
The department will provide the following secretariat support:
- Co-ordinate and organise Advisory Group meetings
- Distribute meeting documents and papers to Advisory Group representatives
- Record and distribute record of meetings
- Draft options paper with input from the Advisory Group
- Organise the publication of various documents on the department’s website.
The department will also undertake a cost/benefit assessment of the options, including a business as usual option.
Advisory Group members
Members of the Advisory Group will:
- Undertake to attend meetings of the Advisory Group
- Organise for a suitable proxy if unavailable for meetings
- Contribute information and data necessary to the development of options and the cost benefit assessment
- Provide independent advice
- Agree to the publication of their name, representation and short biography on the department’s website.
Advisory Group representation
- Mr Jeff Angel, Boomerang Alliance
- Ms Terri-Ann Johnson, Clean Up Australia
- Mr Toby Hutcheon, Wildlife Preservation Society (Queensland)
- Mr Grant Musgrove, Australian Council of Recycling
- Mr Greg Hoffman, Local Government Association of Queensland
- Ms Tanya Barden, Australian Food and Grocery Council
- Mr Alan Wilson, Cook Shire Council
- Mr Trevor Ruthenberg, Scouts Queensland
- Rick Ralph, Waste Recycling Industry Association (Qld)
- Ms Julie McLellan, Healthy Waterways
- Rob Kelman, Association of Container Deposit Technology Service Providers
- Angela Siggery, EHP, Conservation and Sustainability Services
- Matt Fraser, City of Gold Coast
- David Curtin, Keep Queensland Beautiful
Member biographies and position statements
Jeff Angel is Executive Director of Total Environment Centre and Convenor/Director of the Boomerang Alliance of 32 groups. Jeff has an economics degree (USyd) and diploma of environmental studies (MUni) and worked on a wide variety of environmental issues with the community, government and business since the 1970s.
The Boomerang Alliance has been advocating for efficient and comprehensive container deposit schemes (CDS) for the last 12 years. It has investigated many overseas models, their economic and financial impacts, social and environmental benefits. It believes the evidence shows a modern CDS is an assured and multi-value approach that fits well into local, state and national litter reduction, recycling and sustainable economy programs.
Terrie-Ann Johnson joined Clean Up Australia in 2003 as Corporate Affairs Manager.
Since then she has held the positions of Acting General Manager and Campaign Director leading, developed and managed the strategic development, delivery and evaluation of all of Clean Up Australia’s campaigns and projects including Clean Up Australia Day, Clean Up the World, Clean Water and Towards Zero Waste.
In 2007 Terrie-Ann was appointed Chief Executive, responsible for strategic planning, advocacy, people management, fundraising, compliance, communication management, stakeholder management, financial controls and business ethics.
In 2012 she was appointed to the Board of Clean Up Australia Limited as Managing Director.
During the span of her 28 years as a professional communicator, Terrie-Ann has worked with a vast array of specialist services organisations including Rubicon Point, Perpetual Trustees Australia Limited, Lend Lease Corporation, MLC Limited, Business Men’s Assurance, Mercantile Mutual Insurance (Australia) Limited and The Scout Association of Australia (NSW).
Terrie-Ann has also held multiple Board and Committee Memberships including the NSW Government Sports Advisory Committee, International Association of Business Communicators, the United Grand Lodge of NSW and ACT, Surf Life Saving Australia, the Westpac Helicopter Rescue Service and most recently Clean Up Australia Limited.
Terrie-Ann is a graduate of the University of Technology, NSW, Australia (Bachelor of Arts), and Charles Sturt University (Master of Arts).
Clean Up represents Australian communities which are calling for an incentive to reduce the number of bottles and cans found in our environment together with an increase in the recycling rates of beverage containers nationally.
Of rubbish reported by Queensland volunteers in 2014, 33% of the Top Ten Items were beverage containers and their associated rubbish.
86% of Queenslanders surveyed [Jan 2015 Newspoll] support the introduction of a container refund system.
International and more recently state based experience in the Northern Territory, shows that the introduction of reverse vending technology provides the most accessible method for high volume and clean recyclate collections.
The key for community acceptance is clean, easy to access facilities that are simple to use, placed in locations we are likely to frequent and that can accept high volumes of material.
Toby Hutcheon was born in the United Kingdom and spent much of his childhood in India and Pakistan. He came to live in Australia in 1981.
He has tertiary qualifications in education, marketing and journalism. He has worked on environmental issues for 30 years, primarily in the NGO sector.
He started at Greenpeace as a campaigner on the Nuclear Free Seas campaign opposing nuclear powered and armed ship visits to Australia- dividing his time between the Greenpeace office and the bows of nuclear warships.
He subsequently became Greenpeace Australia’s first Actions Coordinator, ran the Communications Division and was a member of the Greenpeace Olympics team that initiated the idea of the ‘green’ Sydney Olympics.
Toby moved to Europe in 1996 working on the Chernobyl Campaign for Greenpeace International in Moscow.
He returned to Australia in 1997 to coordinate the successful local government campaign opposing a second Sydney airport at Holdsworthy.
Since that time, Toby has worked for the NSW Government (Western Sydney Waste Board) on waste to resource issues and ran a consultancy advising business, government and communities on zero waste initiatives.
Toby worked for Queensland Conservation Council from 2004-2014 as Coordinator and Executive Director.
Toby now runs a consultancy, Ecomatters QLD, and is currently engaged by the Boomerang Alliance and Wildlife Queensland on campaigns to restrict the pollution of the environment by plastics.
He believes that we can all make a difference.
Queensland is facing a growing problem with rubbish and litter and is now regarded as the most littered state in Australia. Discarded materials, and plastics in particular, represent a problem for the environment due to their persistence, toxicity, extent and potential to harm wildlife.
As a result, minimising discarded materials and plastics in the environment must be a long term goal for our society. A significant step forward on this agenda can be made by introducing a container deposits scheme (cash for containers) in Queensland. Such schemes are proven to reduce container and plastic pollution, act to change behaviour, provide a financial boost to community organisations and stimulate economic opportunities (particularly in regional Queensland) for resource recovery.
I support the introduction of a container deposit scheme. It will provide significant benefit to Queensland. I believe that the role of the Advisory Group is to provide the Government with advice that ensures that the most effective scheme is introduced in Queensland. One that optimises container collection and stimulates new economic and social opportunity in resource recovery across the whole state.
Grant Musgrove is the National CEO of the Australian Council of Recycling (ACOR), the peak industry body for the resource recovery industry. Grant has studied CDS internationally and ACORs membership spans all companies operating in Australia that focus on resource recovery which have genuine expertise in the impact of CDS systems globally.
ACOR's position is principally to make a positive contribution to ensuring any system works, while acknowledging that there will be losers amongst its membership from changes in feedstock and that these are sovereign risk events that government needs to be willing to provide structural adjustment and/or innovation funding to ensure that a system introduction is commercially benign.
Greg has had a long and distinguished career with local government. With over 40 years dedicated to local government he has worked for three councils including the position of CEO of Darwin City Council following Cyclone Tracy. He was the Executive Director of LGAQ for 10 years, the Local Government Commissioner for Queensland for five years, and for the last 19 years he has been the General Manager - Advocacy at the LGAQ.
Greg holds two Degrees— a Bachelor of Business with majors in Accounting and Management and a Bachelor of Arts, majoring in Public Policy and Media Relations. He is a Certified Practicing Accountant and a Fellow of the Local Government Managers Association.
In 1994 Greg was awarded a Public Service Medal in the Australia Day Honours List for outstanding service to Local Government and in 2002 received a Centenary of Federation Medal.
Qualifications, Memberships and Accreditations
- Bachelor of Business (majors in Accounting and Management)
- Bachelor of Arts (majors in Communityand Media Studies)
- Certified Practising Accountant
- Justice of the Peace (Qual)
- Fellow, Local Government Managers Association
Tanya Barden is Director, Economics and Sustainability at the Australian Food and Grocery Council, which is the peak industry body representing Australia’s food, beverage and grocery manufacturing industry. Tanya is also chair of the National Packaging Covenant Industry Association.
The Australian Food and Grocery Council and beverage companies have a track record of working with governments and other stakeholders to reduce the environmental impacts of consumer packaging waste. Through the former AFGC Packaging Stewardship Forum, beverage companies funded significant investments in projects such as glass recovery and recycling; the installation of away from home recycling infrastructure, including in airports and shopping centres; and education and awareness programs (such as Do the Right Thing, Use the Right Bin).
The beverage industry has also made advances in sustainable packaging design, such as the lightweighting of plastics and use of biodegradable packaging. The industry is now keen to examine the role that reverse vending machines can play in reducing public place litter of beverage containers, as a lower cost alternative to a traditional container deposit system, which risks significant impacts on kerbside recycling systems and comes at additional costs to consumers and/ or industry.
Cr Wilson was elected to Cook Shire Council in 2004 and has had an active interest in waste management and reduction for many years. He has conducted a lot of research both within Australia and overseas, looking at the range of processes and systems used in other shires, states and nations.
Cr Wilson has held the role of Chair of the North Queensland Local Authority Waste Management Advisory Committee (LAWMAC) for the past five years and has presented at a range of meetings and forums the findings of his research. He has continually encouraged support for the introduction of a container deposit scheme in QLD based on the financial and environmental benefits such a scheme delivers. He put forward the successful motion at the 2014 LGAQ annual conferencein Mackay in relation to supporting the introduction of a CDS in Qld.
Waste management is a legislated responsibility that forces substantial costs to ratepayers and local governments.
The introduction of a CDS would bring a benefit to local governments including savings in terms of waste management (collection, handling and disposal), litter collection and disposal and community education which would result in significant environmental, financial and social benefits along with considerable savings to local governments and therefore ratepayers.
Big Trev was born and grew up in Papua New Guinea. After starting his working life in a Toowoomba fibreglass factory, Big Trev joined the RAAF and gained a trade as an airframe engineer. After the RAAF he had a short stint as a youth worker before starting work in the mining and oil and gas industries, working overseas for about nine years. Big Trev lived for a year in Indonesia (Irian Jaya), a year in Chile, 18 months in Canada and five and a half years in the USA.
Big Trev worked as a senior maintenance professional, primarily in heavy industries then as a maintenance process consultant before entering the senior executive ranks in marketing, brand management, sales and implementation of high tech solutions, developing innovative go to market and customer support solutions.
In 2006, returning to Queensland Big Trev changed focus from heavy industry, becoming Executive Officer of the Lutheran Church in Queensland and in July 2009 became the Executive Officer of the Lutheran Church of Australia. In March 2012 Big Trev was elected to the Queensland Parliament, Chairing the Health and Community Services Committee for the 54th Parliament. Following the Queensland State elections in January 2015, Big Trev started as the General Manager of Scouts Queensland in May of 2015.
Perspectives statement - Scouts Queensland—thoughts with regard to a Queensland container deposit scheme.
Scouts Queensland is the largest youth development organisation in Queensland. Approximately 10,000 young people aged between six and 26 each year are developing their full physical, intellectual, emotional, social and spiritual potentials as individuals, as responsible citizens and as members of their communities.
Approximately 3500 adult volunteers give their time freely in many different ways to ensure our young people have the opportunity Scouts Queensland provides. Scouts do not have any regular income from government but our positive contribution to the community is immeasurable.
Scouts have a promise and law that holds members to a set of values, one of which is to care for the environment. Our driving interest in the container deposit scheme is the benefit to our communities from an environmental perspective.
A secondary interest for Scouts Queensland comes from the experience of Scouts South Australia which owns 10 recycling plants and the profits produced from this operation go directly back into the Scouts groups with subsidised membership fees, free adult training, excellent resources and very exciting learning opportunities. Similar opportunities evade us in Queensland because of a lack of funds.
Scouts Queensland sees a significant opportunity in the introduction of a container deposit scheme in Queensland for community groups like Scouts, to accomplish several goals via a single mechanism. If designed and managed properly, the overheads of the scheme to the community would be minimal but the benefit would be considerable. For example, the immediate obvious benefit would be a positive impact on the environment. Secondarily, but I think as important to society would be a positive impact for community groups like Scouts. The financial support a scheme like this could inject into our operation will contribute to the long term viability of our association. Many community groups I have spoken to would welcome this initiative.
Rick Ralph is the Chief Executive Officer of the Waste Recycling Industry Association (QLD) Inc. (WRIQ)
Founded in 2007 by Rick and six industry peers the organisation has become the premier industry organisation in Queensland. It represents the interests of the waste management and secondary resources sector. The organisation has more than 90 members, represented by International and National corporations, with more than 50% small family based operations. In 2014 he established a similar industry organisation in the Northern Territory ( www.wrint.com.au) He is the founding Executive Director of that organisation.
Career achievements include, introducing Australia’s world renowned, first community based recycling program, Comalco Aluminium’s ‘Cash for Cans’ initiative, and similar programs in New Zealand and South Africa, Director of Waste Services, City of Brisbane, Australia’s largest Local Government, Director and owner of a multi material post-consumer recycling business, and General Manager of Operations of Australia’s first Alternate Waste processing operation. He is a Director of his own company providing speciality services to select industry clients related to secondary resource recycling and other waste management matters.
Previous board and executive positions include Transport Logistics Workforce Advisory Group – QLD Dept Main Roads and Transport, Ministerial Committee – QLD Dept Environment and Heritage Protection, Chairman Aluminium Can Recycling Association – South Africa, President of Keep Australia Beautiful Council WA and QLD, founding Secretary and Past President of the Australian Council of Recycling (ACOR) as well having held numerous other executive and chair positions on select Industry and Government committees.
Rick is a qualified Justice of the Peace, and member of the Australian Institute of Company Directors. He is a Director of Mates4Mates a non-profit organisation that provides enduring welfare, psychological and support services for current and ex-serving Australian Defence Force members who are wounded, injured or ill and their families (www.mates4mates.org).
Rick is regarded as having significant expertise in his field and is a leading Australian industry figure. He is accredited with several major awards for this industry leadership and his services to the community.
Julie McLellan joined Healthy Waterways as Chief Executive Officer in July 2013. Julie has over 25 years of experience in senior positions within the water industry and an extensive background in water management. Prior to joining Healthy Waterways, Julie was Executive Director of Strategy and Growth at Queensland Urban Utilities. During her 15 years at Brisbane City Council, Julie held a number of positions including Acting Divisional Manager of City Planning and Sustainability, Manager of Water Resources, Manager of Water Services and Manager of Design and Connections. Julie holds a Degree in Applied Science (Chemistry) with Graduate Diplomas in Training, Development and Assessment. Julie is a graduate of the Australian Institute of Company Directors.
Perspective statement—Healthy Waterways
Healthy Waterways has been a lead organisation in the monitoring and reporting of waterway litter in South East Queensland for the past 14 years. Since then, the Healthy Waterways Clean Up Program has been removing litter from the South East Queensland waterways and river banks, and collating data and statistics on the litter collected. The Clean Up Program takes a holistic approach to managing plastic pollution, using the data collected to inform actions that address waterway litter at its source.
Healthy Waterways’ perspective is that a behaviour change approach, combined with on- ground actions such as the Healthy Waterways clean up boats and community clean up events, will reduce waterway litter. However, to encourage changes in behaviour we must first understand the barriers to this change, followed by the facts, information and tools aimed at addressing these barriers. Healthy Waterways plays a lead role in the development of education programs and initiatives that address the impact of litter on the waterways of South East Queensland. We currently support over 20 community groups across South East Queensland in the removal of waterway litter and have established permanent monitoring sites. Healthy Waterways has been the lead organisation in the implementation of the Moreton Bay Clean Up Program, the development of a Litter Education Strategy for Queensland, the Love Your Reusable Bottle Campaign and now our revolutionary new initiative ‘Water on Tap’
Complementary strategies and programs include ‘Water on Tap’ Junior Flotilla, a mobile website which provides access to the location of over 3600 water fountains, Waterways Ambassador Programs and Up the Creek and Down the Drain Programs. All of these are aimed at raising awareness of the issue of waterway litter, empowering the community to take action, and encouraging people to get connected to their waterways and to love and care for them for future generations.
Rob Kelman is part-time Executive Officer of the Australian Tyre Recyclers Association and has advocated in favour of container deposit schemes in Australia since 2004 when he helped jointly found the Boomerang Alliance. His engagement with CDS in Australia has included consulting advisory roles with Diageo Australia and O-I, alongside direct and indirect employment with the Boomerang Alliance.
Rob also undertook a six-month project based in the Netherlands advocating in defence of that country’s existing CDS in 2002/03. Rob holds a wealth of experience and knowledge of various stakeholders’ positions in relation to CDS, as well as expertise in scheme design variables that are important for real-world effective operations of a CDS; and will of course bring the expertise and experience of the association’s members with him to these advisory processes.
Rob is additionally employed on various corporate consulting projects including corporate sustainability advisory and stakeholder management roles in sectors such as forestry, agriculture, resources and waste management and recycling; and brings additional, advocacy, communication, and policy management expertise to his role at CDSO.
The Association of Container Deposit System Operators has been established to represent the interests of container deposit (CD) technology and system operators and suppliers and to assist governments in designing and implementing best practice CD schemes.
Our members include the world’s leading reverse vending machine (RVM) manufacturers, suppliers and operators; post collection material sorting technology operators and providers; and CD scheme managers and operators more broadly.
CDSO constitution outlines the association’s purpose and objectives including:
- Advocate for the adoption, design and implementation of the most effective, efficient and consumer-friendly CDS, including convenient redemption options for consumers at regular shopping destinations.
- Advocate for efficient CDS with the goal of achieving the highest practicable return rates of containers, including all material types and the widest practicable range of container sizes, with low net systems costs.
- Deliver a strong advocacy position into processes of consultation established by States planning the introduction of a CDS.
- Engage in policy, regulatory, public, media and operational discussions and consultations associated with the adoption, design and implementation of container deposit and recycling schemes, including working with supportive stakeholders.
- Act as a representative and advocacy body for CD operators using modern automated technology aligned with the above objects and purposes.
Queensland Litter Prevention Alliance and the Queensland Youth Environment Council
David joined the Keep Queensland Beautiful team in April 2011, being appointed to the Chief Executive Officer role in January 2014, where he has been tasked with reinvigorating an ageing organisation. He comes from a background in community Fundraising, Marketing and Communications, having worked with some of Queensland's largest not-for-profit organisations, including Blue Care and DRUG ARM Australasia.
David is passionate about grassroots community projects; overseeing 74 active on-the-ground (and marine) clean-up groups across Queensland – with the sole aim to improve Queensland’s dirty littering habit.
Keep Queensland Beautiful is an independent not-for-profit organisation, with programs developed to motivate people to enhance the quality of their local environment through personal initiative and community action. While the Keep Australia Beautiful National Association has previously been outspoken about a national Container Deposit Scheme, Keep Queensland Beautiful would like to have an open discussion on the topic, including options available to overcome Queensland’s vast landscape-distances to our rural and remote communities and better community education.
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