photo credit: l . e . o/flickr

With each passing day, the dire reality of PSNH’s coal-fired business model is becoming clearer in New Hampshire.  The cost of operating PSNH’s obsolete power plants continues to grow, accelerating the Company’s death spiral where fewer captive ratepayers are saddled with unsustainable above-market rates as more PSNH customers choose to buy power from better managed competitive suppliers.  We are also learning that Northern Pass will make the situation worse for ratepayers, not better, and that PSNH and its Northern Pass partners are poised to pull in huge profits.  In just the last few days:

• PSNH revealed that, as it has begun bringing online its $450 million scrubber project at PSNH’s 50 year old coal-fired Merrimack Station, the bill is now coming due. If state regulators at the New Hampshire Public Utilities Commission (PUC) approve passing the cost on to ratepayers, the energy rates for PSNH customers – already the highest in New Hampshire by a wide margin – will go up by at least 1.2 cents per kilowatt hour, or almost 15%.  CLF is seeking to intervene in the PUC proceeding on the rate increase.  PSNH, unsurprisingly, wants to keep CLF out, in addition to any other party seeking to intervene on behalf of ratepayers.  There is no better illustration of the folly – for ratepayers and the environment alike – of major new investments in coal-fired power plants than PSNH’s flawed effort to extend the life of Merrimack Station.  These investments are a disaster for ratepayers, and don’t even ensure compliance with the plant’s environmental requirements – a case CLF is making right now in federal court with regard to other modifications to Merrimack Station.
• Large commercial and industrial customers with the buying power to avoid the high rates for PSNH’s fossil power continue to do so in dramatic numbers.  PSNH announced that, in September, about 82% of these customers were buying power elsewhere in the market (accounting for 93% of the power delivered to these customers) – a phemonenon known as “migration.”  Meanwhile, more than 99% of New Hampshire residents in PSNH territory were left behind to pay PSNH’s already exorbitant rates.  The scrubber rate increase is going to make this situation even worse for residents – additional businesses will find other suppliers and PSNH will need to jack up its rates even more.  More cost-effective competitive suppliers are cleaning PSNH’s clock among large customers.  Given the company’s excessive and increasing rates, residential ratepayers are starting to vote with their pocketbooks for more sustainable energy supplies.
• It is becoming increasingly clear that the current Northern Pass proposal is designed around PSNH’s bottom line, not the interests of New Hampshire ratepayers.  As we’ve mentioned before, the large customer “migration” problem and its upward pressure on homeowners’ electric bills are likely to get worse with Northern Pass, which would further depress regional wholesale electric rates and encourage more customers to leave PSNH.   Adding in the cost of the scrubber will only widen the divide between the businesses that can choose other suppliers and potentially benefit from Northern Pass, and the residential customers who are currently  stuck with PSNH. A new wrinkle emerged last week – testimony from PUC staff showing that PSNH’s consultants estimated a year ago that Northern Pass will cannibalize PSNH’s already meager revenues from Newington Station, PSNH’s little-used power plant in Newington, New Hampshire, that can operate with either oil or natural gas.  Northern Pass would mean it would almost never run and that the investments ratepayers have made over the years to keep Newington Station operating will essentially be lost.  This same dynamic will apply to the rest of PSNH’s power plants:  Northern Pass will diminish their market value further exposing New Hampshire businesses and residents to the risk of excessive costs.  Once again, a series of poor decisions and self-interested advocacy by PSNH (at the expense of ratepayers) is forcing the legislature to intervene.

The costs of PSNH’s coal-fired power plants are becoming untenable, and a radically redesigned Northern Pass proposal and other alternatives could help PSNH meet its customers’ power needs more cheaply and with less damage to public health and the environment.  Instead of planning for a cleaner energy future, PSNH is working only to preserve its regulator-approved profits.  CLF will be using every tool at our disposal to force a rethinking of PSNH’s approach.

The Eastmain Powerhouses from space (photo credit: NASA)

Beyond the discredited sales pitch that Northern Pass will lower electric rates in New Hampshire, the developers have repeatedly claimed that the power to be imported through the Northern Pass project will be “low-carbon,” “clean,” and “green,” with “no greenhouse gases,” and “no global warming.” The power will also, we’re told, “improve the quality of the air we breathe.” The developers have said, over and over, that the project “is expected to reduce regional carbon dioxide emissions by up to 5 million tons per year, the equivalent of removing from the road one million cars annually.” In fact, the study on which this claim is based – a report (PDF) commissioned by Northern Pass and authored by Boston-based energy consultant Charles River Associates – began with the assumption that hydro power is “zero-carbon.” Let me repeat that: the developers’ claim that the project will reduce carbon dioxide emissions by a net 5 million tons is based on their unexamined presupposition that the power to be delivered by the project has no carbon dioxide emissions at all.

There’s no other way to say it: this assumption is false.

You don’t have to take my word for it; read Hydro-Québec’s own research report (4.4 MB PDF) on the net greenhouse gas emissions of the Eastmain 1 Reservoir, flooded in 2005 (aerial shots here). In an Orwellian twist, the developers of Northern Pass have repeatedly cited this very same research.

The Hydro-Québec report found that net carbon emissions from Eastmain-1 were 500,000 tons in 2006 and 165,000 tons in 2009, and are projected to average approximately 158,000 tons per year on a long-term basis.  While certainly less than coal-fired power plants – PSNH’s Merrimack Station emitted more than 2.8 million tons of carbon dioxide in 2010 – 158,000 tons of net carbon emissions per year is far from ”zero-carbon” or even “low-carbon” power.  Based on our own survey of reservoir greenhouse gas research, we have some serious questions about the report, and there is reason to believe that it understates emissions over time and per unit of energy generated. But the report does confirm that Hydro-Québec’s reservoirs will continue to emit more greenhouse gases per year than the natural environment they flooded. These emissions are locked in for decades if not centuries – unlike a power plant that burns fuel, you cannot turn off a reservoir.

When compared with the power plants that Northern Pass’s power could displace, new hydroelectric projects in their early years of operation are no cleaner in terms of carbon emissions.  According to the report, ”it takes about five years for the accumulated CO2 eq. emissions to fall below the [natural gas combined cycle] value” (p.15). So, on a net and cumulative basis since its flooding in 2005, the Eastmain 1 Reservoir has had the same carbon dioxide-equivalent emissions as a modern natural gas power plant that has the same power output and began operating in 2005. 

The report also highlights what appears to be a clear difference between the net emissions of a newly impounded reservoir and the emissions of a reservoir that was impounded decades ago: a new reservoir emits more greenhouse gases, as the vegetation and organic material in the newly inundated area decompose.

This distinction is especially important when considering the contradictory stories we have heard about where Northern Pass will get its power. On the one hand, Northern Pass’s website claims (click on “Hydro-Québec” on this page) that “Hydro-Québec does not need to build any new generation to support this project.” On the other hand, it is clear that Québec is developing and planning vast new hydroelectric projects, many of which will require new inundation and reservoirs, as part of a concerted strategy to maintain and increase exports to New England and the northeast United States. See Erin’s blog post from yesterday for more on Vermont’s new long-term contract with Hydro-Québec. 

In fact, Charles River Associates’ fundamentally flawed estimate of carbon emissions reductions depends on the development of new hydro projects in Canada. And just ten days ago, in testimony to Massachusetts regulators, Northeast Utilities’ CFO David McHale stated under oath: “We already know for a fact that the utility Hydro-Quebec has initiated the construction of dams, and we’ve already entered into the record a discussion about the Eastmain Water Reservoir that will provide the water source. So this is not speculative. They’re building the dams and they will go into service; and that will be the primary source, if not the exclusive source, of energy that will flow over [the Northern Pass] line. . . . [T]hat is the full expectation.” What McHale was referring to is Hydro-Québec’s major new project in the vicinity of Eastmain-1 – the Rupert River project (project website here and explanatory animation here). Since 2009, this 918-MW project – now in the final stages of development – has newly flooded 346 square kilometers  - an area about the size of two Lake Winnipesaukees. That Northern Pass power will be coming from new projects means that Northern Pass will enable and contribute to the substantial carbon emissions associated with new reservoirs.  There has been no accounting of the potential emissions from the Rupert project and other future projects that Northern Pass may make possible, and how they would cut into the potential emissions reductions Northern Pass and Charles River Associates have claimed.

These inaccuracies and contradictions are being disseminated with hundreds of thousands of dollars in media buys, money which could have been invested in engaging in a collaborative process to rework the current proposal.  This situation makes CLF’s fight for a world-class, independent, and comprehensive permitting process all the more important.

CLF has been adamant that the Department of Energy must consider the environmental impacts – including greenhouse gas emissions – of the hydropower generation projects and any other power plants in Canada that will supply the Northern Pass project.  Given the developers’ recent announcement of new delays in their schedule, there’s still time for the Department of Energy to change course and answer our call for a regional, holistic analysis of the right approach to importing power from Canada, taking into account the truth about that power’s greenhouse gas emissions.

PSNH: In a death spiral? (photo credit: CC/Nick Seibert)

In every possible way – on television, in mailings, and on the web – New Hampshire has heard again and again that the proposed Northern Pass transmission project will reduce electric rates for New Hampshire customers. The claim is at the core of PSNH’s case that the project is a good deal for New Hampshire. If only it were true…

As I mentioned in a post last month, the very design of the project as it stands is for reduced electric rates to benefit only those ratepayers that get their power from the regional electric markets. In New Hampshire, homes and small businesses in PSNH territory would see very little benefit because their energy rates are overwhelmingly tied to propping up PSNH’s old, inefficient fleet of coal-fired and oil-fired power plants.  These plants would not be able to compete with other cleaner power sources if forced to compete in the marketplace, something New Hampshire law does not currently allow and PSNH has fought to avoid. (Supposedly, an agreement between PSNH and Hydro-Québec for some power for PSNH customers is in the works, but, if it ever materializes, Northern Pass has said it would only be for a small amount of power, which would not do much to change PSNH’s overall portfolio. Northeast Utilities admitted as much in testimony before the Massachusetts DPU this week and also noted that there is “really little activity” around securing any such agreement.)

As explained in a piece on NHPR featuring our own Jonathan Peress, the above-market costs of PSNH’s aging fleet are causing large customers to buy power from (or “migrate” to) cheaper suppliers. Regulators this week turned back PSNH’s attempt to saddle those customers with its fleet’s escalating costs. But this situation is creating a so-called “death spiral,” because PSNH is forced to raise its rates again and again on a shrinking group of customers – homeowners and small businesses who do not have the purchasing power to contract with another supplier.

What does this all have to do with Northern Pass? The truth is that Northern Pass will – indeed, is intended to – make the “death spiral” worse.  If Northern Pass lowers the regional price of power as all those ads proclaim, it will make PSNH power even less competitive, causing even more customers with choices to leave PSNH behind.  PSNH spokesman Martin Murray so much as promises that result when he says in the NHPR piece that Northern Pass power will not displace PSNH generation. As Jonathan explained on NHPR, that means that the same homeowners and small businesses that will have to deal with 180 miles of new transmission lines will have higher, not lower, electric rates. This is not the Northern Pass story PSNH has been telling.

None of this makes sense. PSNH’s coal- and oil-fired power plants are bad for ratepayers and disasters for public health and the environment. As our lawsuit filed last week makes clear, PSNH’s efforts to prop up its largest plant failed to comply with even basic emissions permitting requirements and have increased that plant’s emissions. Any plan to import Canadian power with PSNH’s name on it should provide real benefits to its own customers and focus on responsibly freeing New Hampshire (and the lungs of millions of New Englanders) from PSNH’s dirty, uncompetitive dinosaurs.

ADDED: I should also point out, in the same Massachusetts DPU proceeding mentioned above, that counsel for NSTAR (the junior partner in Northern Pass) asserted that “[i]t’s entirely speculative as to what the impact of Northern Pass will be on rates in New Hampshire, and then [migration].”  Quite a statement given Northern Pass’s public relations campaign asserting that rates will go down. And we disagree with NSTAR’s counsel wholeheartedly. It is reasonable – not speculative – to expect the current proposal will lead to higher rates for PSNH ratepayers.

Merrimack Station power plant in Bow, NH. (Photo credit: John Moses)

Today CLF filed a federal Clean Air Act citizen suit in New Hampshire federal district court against Public Service Company of New Hampshire (PSNH), the owner of Merrimack Station power plant for the plant’s repeated failures to obtain required air permits. CLF’s citizen suit also cites numerous violations of Merrimack Station’s current permits and the resulting illegal emissions from the plant.

Merrimack Station  is among the most polluting coal-fired power plants in New England and is the single largest source of greenhouse gas emissions in New Hampshire, releasing over 2 million pounds of toxic chemicals every year. In addition, the plant is causing PSNH’s energy rates (already the highest in New Hampshire) to steadily climb as ratepayers are forced to foot the bill for the above-market cost of keeping PSNH’s old coal plants in operation.

CLF’s complaint contends that the plant, which is more than a half-century old and is in the midst of a major, multi-faceted life extension project, never obtained required permits authorizing renovations to major components of Merrimack Station, including much of an electric-generating turbine, even though the changes increased pollution from the plant.  As predicted by PSNH’s own projections, the changes led to more emissions of pollutants, including smog-causing nitrogen oxide and particulate matter, or soot, which causes respiratory problems when inhaled and is linked to increased hospitalizations, lung damage in infants and children, and premature death.

“In the course of this project, PSNH has repeatedly violated the Clean Air Act, putting the health of the public, especially children and senior citizens, at risk,” said Christophe Courchesne, CLF staff attorney. “PSNH is not above the law and CLF is committed to holding them accountable. With PSNH trumpeting the supposed ‘clean air’ benefits of the Northern Pass project with full-page ads in newspapers across New Hampshire, it is imperative to shine a light on PSNH’s coal plants, which easily cancel out the purported benefits of Northern Pass.” Read more >

PSNH's Merrimack Station (photo credit: flickr/Jim Richmond)

I appeared on NHPR’s The Exchange with Laura Knoy this morning, and the topic was the potential energy and economic impacts of the Northern Pass project. The show provided a good opportunity to explain why the project is inspiring so much opposition, why CLF has been skeptical of the current proposal, and how Canadian hydropower could play a role in the New England electric system if pursued appropriately. There was also a segment on the project’s potential impact on property values. You can catch the replay here if you’re interested.

Joining me on the show was Julia Frayer, an economist hired by the Public Service Company of New Hampshire (PSNH) to tout the energy and economic benefits of the project. Recently, she penned a widely-reprinted op-ed and provided testimony to the New Hampshire legislature, suggesting the project will be a boon to consumers and the reliability of the electric system.

Unfortunately, and as I made an effort to point out on the show, the arguments for the current proposal are pleasant talking points without much to back them up. All the cited benefits are speculative, rather than firm commitments, and are not forthrightly presented alongside the proposal’s potential costs. As any student of economics can attest, an intelligent discussion about the economics of a project requires that we at least try to describe and compare the costs and benefits.  We know that the project may have significant negative impacts, ranging from the environmental impacts of generating the power in Canada to the potential effects of major new transmission lines on New Hampshire’s tourism and recreation industries. PSNH and the project developer, Northern Pass Transmission, LLC, have stubbornly failed to acknowledge these impacts, and there is no evidence they were taken seriously in the planning of the current proposal.

One point worth highlighting – the current plan calls for all of the supposed clean energy benefits and electric rate reductions to be delivered through the wholesale market, where Hydro-Quebec intends to sell the power delivered by the project.  But these benefits would mostly bypass the very residential ratepayers in New Hampshire who pay PSNH for electricity – because PSNH acquires very little power from the wholesale market. Instead, as customers of PSNH’s retail power, PSNH residential customers have been left to shoulder the uneconomic costs of PSNH operating several coal-fired generating units – and to pay the highest electric rates in New Hampshire as a result. Northern Pass does nothing to change this situation.  Many commercial ratepayers in PSNH territory have “migrated” in increasing numbers to other utilities that – unlike PSNH – do buy substantial power from the wholesale market to supply their customers. Residential ratepayers don’t have this choice – which means they’re saddled with PSNH’s higher costs, as PSNH loses more and more of its commercial rate base.  Again, Northern Pass does nothing to change this situation.  On closer inspection, the claimed benefits for New Hampshire consumers look more like phantom benefits than anything real.

The proposal promises to send huge profits to Hydro-Quebec, as it bids power into the wholesale market (easily paying back its investment in the transmission lines), and to provide a revenue stream of transmission payments to Northeast Utilities, PSNH’s parent company. But this structure makes very little sense because it means New Hampshire residents will continue to bear the burden of high cost power and dirty air from PSNH’s coal plants and will also face the environmental and economic impacts of a massive transmission project, while the power would only displace relatively less-polluting natural gas generation and may undermine the development of local renewable energy projects in the state. If it does indeed lower costs on the New England market, the effect will be to increase costs for PSNH’s residential customers as more large customers migrate to the competitive market and fewer customers are left to pay the costs of PSNH’s expensive coal plants.

The current proposal is coming into focus as a bad energy and economic deal for New Hampshire, and regionally the benefits seem less than impressive – especially because the emissions reductions made possible could be so much greater if there was a firm commitment to pair the new imports with the retirement of coal-fired units. As the project continues to wind its way through the federal and state permitting process, CLF will keep pushing for the project to make sense for New Hampshire and for the energy future of the region as a whole.

For more information about Northern Pass, visit CLF’s Northern Pass Information Center (http://www.clf.org/northernpass) and take a look at our prior Northern Pass posts on CLF Scoop.

Major voices in the New England Fishing community speak up in support of the Regional Greenhouse Gas Initiative (RGGI) in this letter to SeafoodSource (a fishing industry website):

The oceans provide food for the world. As fishermen, growers, employers, and participants in the seafood industry, we are gravely concerned about the silent toll that ocean acidification has begun to take on marine resources. Seafood supplies, and our jobs and businesses, depend on healthy oceans.

That’s why we support continuation of the Regional Greenhouse Gas Initiative (RGGI). RGGI helps to reduce carbon dioxide (CO2) emissions from large power plants in the 10 states from Maryland to Maine.

These emissions don’t just foul the air. They mix into the oceans and increase the acidity of seawater. More than 30 billion tons of CO2 poured from the world’s tailpipes, smokestacks and cleared lands in 2009, mostly from burning coal, oil, and gas. In seawater the CO2 forms carbonic acid. The acid depletes the ocean’s rich soup of nutrients that support shellfish, corals, many plankton species and the marine food webs that underpin the world’s seafood supply.

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Photo credit: Flickr/peupleloup

As noted in numerous media reports (for example, here and here), the Province of Québec has formally announced its “Plan Nord,” a 25 year, $80 billion plan to develop Québec’s northern region (official “nutshell” here).  Plan Nord reflects major new public investments in mining operations, hydroelectric and wind energy facilities, forestry, and transportation and communications infrastructure.

The scale of Plan Nord is hard to overstate; Premier Jean Charest is proudly proclaiming that Plan Nord is the “project of a generation,” “a sweeping, human adventure,” and “unique both in its scope and its approach.”  The plan adds that “the scope of the Plan Nord will make it in the coming decades what the development of La Manicouagan and James Bay were to the 1960s and 1970s.”  The land area covered by the plan is about twice the size of Texas.

The formal public launch of Plan Nord is an opportunity to think about what Québec’s plans may mean for New England and our regional energy future. A fundamental part of Plan Nord is developing the region’s energy resources, including new hydroelectric generating capacity totaling 3,000 megawatts.  (This amount of power is equivalent to five Vermont Yankees.) While important to the plan’s projections of provincial energy needs, these facilities are also integral to Québec utility Hydro-Québec’s strategy to step up exports of electric power to the northeastern United States, including New England.  The plan itself notes Vermont’s recent renewal of a long-term agreement to import 225 megawatts of power from Hydro-Québec as a key early success.

Although Québec has marketed Plan Nord as at the vanguard of “sustainable development,” any plan this massive and costly should inspire a fair amount of skepticism, especially when its scale is compared to the breathtaking ecological manipulations of Québec’s recent history. Indeed, the plan’s economic focus on new investments in mining suggests less than a total commitment to sustainability. On the other hand, as our colleagues at the Pew Environment Group’s International Boreal Conservation Campaign noted yesterday, the plan commits to protection of 50% of Québec’s northern land area for environmental protection and safeguarding biodiversity. It remains to be seen if this commitment is meaningful; if it is, it would be a historic and farsighted move.

CLF is deeply concerned about what this plan – including its focus on resource extraction and exploitation - means for Québec, New England, and indeed the global environment.  Hydroelectric developments on the scale contemplated by Plan Nord involve inundation of vast land areas, which in turn results in the destruction of wide swathes of Canada’s boreal forest – one of the world’s largest intact carbon sinks - as well as methane and other greenhouse gas emissions from decomposing vegetation and releases of heavy metals from flooded soils. Hydropower reservoirs in Québec already cover an area greater than the size of New Hampshire, and further inundation will be required for Plan Nord projects.   These projects have dramatic impacts on indigenous people and their way of life; at least some indigenous groups appear deeply dissatisfied with the public process that led to the Plan Nord.

With Plan Nord moving forward, the time is now for the U.S. Department of Energy to answer CLF’s call for a regional, comprehensive analysis of the nature and extent of the need for energy imports from Québec.  Québec clearly has a plan for its future, and – laudable environmental “commitments” aside – that plan is all about enriching Québec; New England and the northeastern U.S. need a coherent plan of our own that reflects our energy policies and environmental values.

Last Friday, the U.S. Department of Energy (DOE) announced in the Federal Register that it’s extending to June 14, 2011 the deadline for submitting scoping comments on the proposed Northern Pass electric transmission project.

UPDATE:  As of June 15, 2011, DOE has again reopened the comment period – this time indefinitely – pending the submission of updated route information from Northern Pass.  See more here.

This extension of the public comment period comes on the heels of huge turnouts at DOE’s seven public meetings in March and the news (noted on NHPR here and in the Concord Monitor here) that the developer of the project wants DOE to stop considering several alternative routes for the project in favor of its original preferred route.

DOE’s extension means that you still have an important opportunity to help shape the environmental impact statement (EIS) and influence DOE’s decision on the project.  The EIS will be a detailed statement of the environmental, social, and economic impacts of the Northern Pass proposal and alternatives.

What Should I Address in My Comments?

CLF encourages you to raise any reasonable concern or question about the proposed Northern Pass project and alternatives:

• Describe how the project could affect the natural resources that you value.
• Explain your concerns about the potential impacts of the project on scenic landscapes, communities, wildlife, forest resources, wetlands, recreation areas, the energy sector, and the local economy.
• Demand that DOE analyze the environmental impacts associated with generating the hydroelectric power that the project will transmit.
• Insist that DOE rigorously examine all reasonable alternatives to the project, including alternative project designs (like burying the lines in railroad or highway rights of way) and options that would generate or save the same amount of power here in New England (like local renewable energy, energy efficiency, or conservation programs).
• Join CLF’s request for a comprehensive EIS that assesses New England’s need for Canadian hydropower and develops a more holistic, proactive plan for addressing any such need (as opposed to reacting to project-specific proposals such as Northern Pass)

How Do I Submit Comments?

To comment, email DOE at Brian.Mills@hq.doe.gov or use DOE’s Northern Pass EIS web form by June 14, 2011.  UPDATE: As mentioned above, the deadline for comments has been extended again – to a date yet to be determined.

For More Information

• Visit CLF’s Northern Pass Information Center at http://www.clf.org/northernpass, and download CLF’s detailed written comments to DOE.
• Check out project maps and Northern Pass’s application filings (available at http://www.northernpasseis.us, under “Document Library”).
• Contact me at ccourchesne@clf.org.
• Become a member of CLF here, to support us in our work.

Daniel Johnson Dam, north of Baie-Corneau, Québec

Last night, CLF filed detailed written comments with the U.S. Department of Energy (DOE) regarding the scope of the Environmental Impact Statement (EIS) for the Northern Pass project. (A PDF of our comments is here.)   First and foremost, our comments urge DOE to stay the Northern Pass proceeding and instead conduct a comprehensive, regional analysis (a comprehensive EIS) of the region’s need for Canadian imports, to enable sound planning as opposed to the piecemeal, project-by-project approach DOE is currently taking by simply reacting to the permit applications of private entities like Northern Pass.   

Our comments expand on the remarks (PDF) I made at the Pembroke scoping meeting last month and come on the heels of yesterday’s major news that (1) Northern Pass wants DOE not to consider some alternative routes it included in its Presidential Permit application and also needs more time to discuss additional potential routes through the North Country (a PDF of Northern Pass’s filing is here and coverage on NHPR here) and (2) DOE is reopening the scoping public comment period through a date to be determined in June.  The fact that Northern Pass itself has asked for a delay to reconsider aspects of its project is an even stronger indication that DOE can and should take the time it needs to undertake a full regional analysis through an open, and collaborative public process.   

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