Federal Advocacy Update: Week of May 22, 2018

Washington, D.C.
Washington, D.C.

In this issue:

During Infrastructure Week, City Leaders Press Congress to Invest and Rebuild

Ashley Smith, 202.626.3094

In meetings on Capitol Hill and during events across the nation, city leaders came together for Infrastructure Week 2018 to highlight the current state of America’s infrastructure and tell Congress that we need a federal partner to invest in infrastructure with cities. 

To begin this week of advocacy, on Monday, May 14, NLC President Mark Stodola, mayor, Little Rock, Ark., joined U.S. Secretary of Transportation Elaine Chao, corporate executives, and labor leaders during the Infrastructure Week 2018 East Coast kick off in Washington, D.C.’s Union Station. To read his remarks, click here. Also on May 14, NLC hosted a briefing in our National City-County Leadership Center to highlight the workforce development needs from the perspective of workers, employers and the data which impacts the economic vitality of cities. The panel, moderated by NLC CEO and Executive Director Clarence Anthony, featured NLC President Mayor Mark Stodola, Amy Blair of the Aspen Institute, David Mallino of the Laborers International Union of North America, Danial Villao of the U.S. Department of Labor and Dave Young of Boeing. To learn more about this event, visit NLC’s blog, CitiesSpeak.

On Tuesday, May 15, NLC First Vice President Karen Freeman-Wilson, mayor, Gary, Ind., and Human Development Federal Advocacy Committee Chair Gil Ziffer, commissioner, Tallahassee, Fla., paved the way on Capitol Hill while meeting with professional staff from the Senate and House authorizing committees that oversee workforce and education policy. 

NLC Infrastructure Week

On Wednesday, May 16, NLC First Vice President Freeman-Wilson and leaders from six of NLC’s Federal Advocacy Committees joined NLC staff for our annual Infrastructure Week fly-in. During this time on Capitol Hill, NLC leaders and staff met with key Members of Congress and committee staff to press them to make federal infrastructure investment a priority. To learn more about this fly-in, visit NLC’s blog, CitiesSpeak. In addition, delegations from the Georgia Municipal Association, the Florida League of Cities, and the Kentucky League of Cities traveled to Washington, D.C. to advocate for city priorities.

NLC also participated in several events throughout Infrastructure Week: 

  • NLC Energy, Environment and Natural Resources Federal Advocacy Committee Chair Cynthia Pratt, deputy mayor, Lacey, Wash., provided the local perspective during the “Water, Parks and Cities: Partners in Green Infrastructure” Capitol Hill briefing, which highlighted ways water utilities, park and recreation agencies, planners, and landscape architects are working to plan, fund, and implement green infrastructure projects. 
  • NLC First Vice President Freeman-Wilson gave opening remarks at the “C-Suite Perspectives on the Value of Water” discussion, which highlighted how companies are driving innovative water management practices and navigating the challenges of today’s complex water landscape. 
  • NLC Community and Economic Development Federal Advocacy Committee Chair Gyna Bivens, councilmember, Fort Worth, Texas provided the local perspective on the panel for the “Municipal Bonds: The Foundation and Future of Infrastructure Finance” discussion, which examined the role municipal bonds have played in infrastructure development.
  • Mayor Wade Troxell, Fort Collins, Colo., participated in the “Bloomberg Next: Infrastructure,” event and provided the local perspective on the creative and practical applications of commercial drone deployment.

Finally, NLC’s Rebuild With Us message reached a new level as digital billboards went live on highways, at bus stops and at airports in 48 cities across the country. With the support of Clear Channel, these billboards asked a simple question to the general public: How was your commute today? While the nation’s infrastructure needs loom large, NLC hopes that by connecting the impact of poor infrastructure on American’s lives to how cities are already rebuilding and reimagining for the future, we can continue to build support for local and national infrastructure needs. 

NLC Infrastructure Week Billboard

Throughout Infrastructure Week, NLC's message was amplified through social media under the hashtag #RebuildWithUs. For additional photos and highlights from Infrastructure Week, follow NLC on Twitter and Facebook.

Federal Funding Maintained for City Priorities in FY19 First Draft Spending Bills

Michael Wallace, 202.626.3025

Last week, the House and Senate Appropriations Committee’s began the process of advancing the 12 annual spending bills necessary for maintaining federal programs and government operation. Under regular order, Congress has until the new fiscal year, beginning October 1, to send the 12 bills to the President for enactment. However, existing time constraints on the Congressional calendar make it all but certain that Congress will again extend that deadline and put off any difficult spending bills until after the midterm elections.

In the House, several Fiscal Year (FY) 2019 spending bills have already received subcommittee consideration including the Energy-Water bill; the Interior-Environment bill; the Transportation-HUD bill; and the Commerce-Justice-Science bill. The Senate is expected to follow suit this week with subcommittee consideration of those bills, plus the Agriculture bill.

For cities, the hard-fought federal funding increases for city priorities enacted in FY18 are generally maintained in the FY19 drafts, including:

Energy-Water
The House bill largely rejects the President’s proposed cuts, providing level funding at $251 million for Weatherization and $2.1 billion for the Office of Energy Efficiency & Renewable Energy (EERE), a decrease of $200 million over FY18. The bill includes several policy riders, including one to repeal the U.S. Environmental Protection Agency and U.S. Army Corps of Engineers Clean Water Rule. 

Interior-Environment
The House bill provides an increase to the Water Infrastructure Finance and Innovation Act (WIFIA) – providing $75 million, compared to $63 million in FY18, and funds the Clean Water and Drinking Water State revolving loan fund programs at FY17 levels, $1.393 billion and $863 million respectively. The bill also includes policy riders, including one to repeal the U.S. Environmental Protection Agency and U.S. Army Corps of Engineers Clean Water Rule. 

Commerce-Justice-Science
The House bill provides $447 million for grant programs to help stem the tide of overdoses resulting from opioid abuse, including drug treatment, prescription drug monitoring, overdose-reversal drugs, and at-risk youth programs. The bill also increases resources for programs that reduce violent and gun crime, including $75 million in grants to states to improve their records used in background checks, $50 million in grants to reduce gang and gun violence, $100 million as authorized by the STOP School Violence Act, $100 million for youth mentoring programs, and $20 million for police active shooter training.

Transportation-HUD
The House bill would increase funding for affordable housing and transportation programs that, according to committee documents, would represent another significant down-payment on infrastructure. The biggest increase is a $1.7 billion, or 68 percent, increase in highway grants to states, to $4.25 billion.  The Better Utilizing Investments to Leverage Development, or BUILD, program (formerly known as TIGER Grants) would be cut under the proposal, from $1.5 billion to $750 million. 

On the housing side, the bill would maintain last year’s increase for CDBG for a total of $3.37 billion; as well as level funding for homeless assistance grants, public housing, and Choice Neighborhoods. The bill excludes most of the controversial policy riders sought by the White House including minimum rent increases, new work requirements, and time limits on assistance.

City leaders can track the development of the FY19 spending bills by visiting NLC’s Budget Tracker, which tracks dozens of federal programs important to cities across all federal agencies.

House Passes Senate Banking Bill

Brian Egan, 202.626.3107; Michael Wallace, 202-626-3025

Today, the House passed the Economic Growth, Regulatory Relief, and Consumer Protection Act (S. 2155) and sent it to the President to be signed into law. The Act, which passed the Senate on March 14, rolls back some banking regulations set forth under the Dodd–Frank Wall Street Reform and Consumer Protection Act of 2010. The legislation contains provisions that will help cities served by community banks by providing targeted regulatory relief and will lower interest rates for municipal bonds by making them more attractive to large institutional investors. 

Community Banks
S. 2155 raises the threshold for a bank to be considered a Systemically Important Financial Institution (SIFI) from $50 billion in assets to $250 billion. Many community banks fell within the original range and were constrained by the accompanying compliance regulations that larger national banks were more easily able to meet.

HQLA Reclassification for Municipal Bonds 
The legislation also instructs bank regulators to reclassify investment grade municipal bonds that are both market ready and liquid as level 2B “high quality liquid assets” (HQLA). An HQLA classification of municipal bonds would make them more attractive to larger financial institutions who would then be able to use bonds to satisfy part of their Liquidity Coverage Ratio (LCR) requirements, set forth under Dodd Frank. This in turn would lower interest rates on municipal debt. 

Senate and House Release Water Resources Bills

Carolyn Berndt, 202.626.3101 

On May 8, the Senate Environment and Public Works Committee introduced the America’s Water Infrastructure Act (S. 2800) to authorize water resources projects and other water infrastructure programs. NLC weighed in on the bill, which authorizes flood control, navigation and ecosystem restoration projects under the U.S. Army Corps of Engineers (Army Corps) and includes provisions that will help communities improve our nation’s drinking water and wastewater infrastructure and improve stormwater management. The bipartisan bill is sponsored by Committee Chairman John Barrasso (R-WY), Ranking Member Tom Carper (D-DE), Subcommittee Chairman James Inhofe (R-OK) and Subcommittee Ranking Member Ben Cardin (D-MD).

Specifically, the bill:

  • Requires the Army Corps headquarters and districts to have greater local government input in the development and implementation of a 5-year budget and work plan of projects and initiatives to be carried out;
  • Provides the sense of Congress for robust funding for the Clean Water and Drinking Water State Revolving Funds;
  • Authorizes grant programs to address combined sewer overflow, sanitary sewer overflow and stormwater discharges at $225 million for fiscal years 2019 and 2020;
  • Reauthorizes and expands the Water Infrastructure Finance and Innovation Act (WIFIA) at $100 million for fiscal years 2020 and 2021;
  • Codifies the U.S. Environmental Protection Agency’s Integrated Planning framework; and 
  • Establishes a water infrastructure workforce development program.

The bill does not include a provision to ensure that the money in the Harbor Maintenance Trust Fund is used on an annual basis for its designated purpose of ensuring that our nation’s ports and harbors do not continue to fall into disrepair. The Committee marked up the bill on May 22 and passed a manager’s amendment.

Meanwhile, the House Transportation and Infrastructure Committee introduced the Water Resources Development Act (WRDA, H.R. 8) on May 18. Sponsored by Committee Chairman Bill Shuster (R-PA), Ranking Member Peter DeFazio (D-OR), Subcommittee Chairman Garret Graves (R-LA) and Subcommittee Ranking Member Grace Napolitano (D-CA), the bill is similar to the Senate bill with regard to the authorization of Army Corps projects, but does not include the other water infrastructure provisions, which could be incorporated into a separate water infrastructure package later this year. The House bill, however, does include a provision that provides for the full use of the Harbor Maintenance Trust Fund for its intended purpose. 

The Committee plans to mark up the bill on May 23, with the idea of bringing it to the House floor for a vote in June. Last week, NLC weighed in on our priorities for the bill, as well as met with key committee staff and member offices of the House and Senate as part of Infrastructure Week. 

Perkins Act Reauthorization May Have New Life in Senate

Stephanie Martinez-Ruckman, 202.626.3098

The Carl D. Perkins Career and Technical Education Act (Perkins Act) directs investment by the federal government to vocational and technical education across the country, with an increased focus on academic achievement and strengthening the connections between secondary and postsecondary education. NLC has long advocated for federal support of this bill through our National Municipal Policy and strengthening connections to career and technical education through the Perkins Act is one of the key recommendations of our workforce provisions for infrastructure investment.

While leaders of our Federal Advocacy Committees traveled to Washington, D.C. during Infrastructure Week to meet with House and Senate congressional staff who oversee workforce and education policy, staff from Senators Alexander (R-TN) and Murray (D-WA) began negotiations over the Perkins Act.  This signals a major shift in the Senate, who has been inactive on this legislation since the House passed their version of the bill, H.R. 2353, in June of last year. Perkins was last reauthorized in 2006 and was originally due for reauthorization in 2012.  Needless to say, the reauthorization is well overdue.

Senators Murray and Alexander will be working closely with Senators Enzi (R-WY) and Casey (D-PA) to craft a final piece of legislation that staff hope will receive a vote in the Senate before August recess.

Senate Judiciary Committee Advances the Substance Abuse Prevention Act

Yucel Ors, 202.626.3124

On May 17, the Senate Judiciary Committee advanced the Substance Abuse Prevention Act (S. 2789), which reauthorizes drug abuse programs and provides assistance to various agencies to better combat opioid addiction and support those recovering from substance abuse.  NLC supports provisions in the bill that would reauthorize crucial substance use prevention programs and provide assistance to local efforts to address the opioid crisis.  

Specifically, the legislation would:

  • Reauthorize the Office of National Drug Control Policy at the White House, which oversees Executive Branch efforts on narcotics control and ensures efforts complement and strengthen state and local anti-drug activities. 
  • Reauthorize drug abuse prevention programs such as the Drug-Free Communities Program and the High-Intensity Drug Trafficking Area Program and allows the ONDCP Director to participate in and expand opioid and heroin awareness campaigns which were authorized under the Comprehensive Addiction and Recovery Act (CARA).
  • Reauthorize the Department of Justice funding for drug courts, which provide targeted interventions for individuals with drug addiction and substance abuse disorders and allows non-profit organizations to provide important training and technical assistance to drug courts.
  • Authorize the Drug Enforcement Agency (DEA) to conduct a pilot program in partnership with healthcare and community organizations to raise awareness of substance abuse, strengthen community organizations that provide long-term substance abuse assistance, and target criminal organizations responsible for increasing the supply of illicit narcotics.
  • Provide resources to the Department of Health and Humans Services (HHS) for screening, treatment, supportive housing, and interventions in order to help support families as they battle substance abuse challenges.
  • Eliminate barriers that previously prevented members of group and individual health plans from accessing abuse-deterrent opioids and requires commercial and Medicare plans to educate practitioners on abuse prevention efforts, including the use of abuse-deterrent opioids.
  • Require hospitals that accept Medicare and Medicaid patients to provide overdose reversal medication and a referral to treatment options as part of the discharge protocol for overdose patients.
  • Require the DOJ and HHS to complete a plan for educating and training medical practitioners in best practices for prescribing controlled substances.

The full Senate may consider this and other opioid related bills prior to the Memorial Day recess.  

What the Senate Net Neutrality Vote Means for Cities

Angelina Panettieri, 202.626.3196

After months of protest by state governments and delays, the Senate voted 52-47 on May 16 in favor of a Congressional Review Act resolution to overturn the FCC’s December Restoring Internet Freedom Order, an action by the agency to eliminate net neutrality regulations. The vote was supported by all Senate Democrats, as well as Republican Senators Lisa Murkowski (AK), Susan Collins (ME), and John Kennedy (LA). The FCC’s action remains in place and will go into effect in June, unless the House also passes the resolution and it is signed by the President – currently an unlikely scenario.

The vote was intended to restore the 2015 net neutrality framework, which was overturned in December in a move that NLC opposed. Elimination of net neutrality regulations opens cities and consumers to the possibility of blocking, throttling, and the paid prioritization of internet traffic, and preempts state and local governments from enacting their own net neutrality requirements. Thus far, 23 state attorneys general have joined a lawsuit to block the rollback of net neutrality, and a number of states have introduced or passed legislation or executive orders to preserve some degree of net neutrality in their states, in defiance of the FCC ruling’s preemptive measures.  

The FCC’s regulatory rollback is set to go into effect in June, after several months of delay in publication of the final order. Congresswoman Marsha Blackburn (TN-7) has introduced the Internet Freedom Act (H.R. 4070) which partially moves net neutrality principles into statute, but falls short of prohibiting paid prioritization of internet traffic by ISPs, and has failed to gain bipartisan support. The legal challenges brought by states and the anticipated actions by internet service providers could take months or years to unfold, but in the intervening time, some cities, such as Fort Collins, Colo., have elected to create their own municipal broadband networks to ensure residents’ access to free and open internet traffic is protected.

Senate Stalls on NFIP Reauthorization 

Yucel Ors, 202.626.3124

Unless Congress renews the statutory authority of the National Flood Insurance Program (NFIP) to operate by July 31, the Federal Emergency Management Agency (FEMA) would stop selling and renewing flood insurance policies for millions of properties in communities across the nation. Nationwide, the National Association of Realtors estimates that a lapse might impact approximately 40,000 home sale closings per month.

NLC is very concerned that the Senate has been slow to consider legislation that would provide long-term reauthorization of the NFIP.  We are urging the Senate to quickly pass the legislation to provide long-term reauthorization of the NFIP, while making essential reforms to reduce the program’s complexity while transitioning it to a sounder financial framework.  

Specifically, NLC is urging the Senate to require FEMA to work with state and local governments, the insurance industry, and other stakeholders to develop an incentive-based disaster insurance and mitigation system that would encourage property owners to retrofit existing structures to reduce future losses from natural disasters. We are also asking that the legislation should encourage lending institutions to incorporate mitigation provisions as conditions for loans. Finally, Congress should provide additional resources to FEMA to utilize the best technology and methods available to improve the mapping process, including seeking the input from local government officials prior to approving any flood map that could impact local zoning rules.

Farm Bill Fails in House

Stephanie Martinez-Ruckman, 202.626.3098

On May 18, the House failed to pass the Agriculture and Nutrition Act (Farm Bill; H.R. 2), by a vote of 198 to 213. All Democrats opposed the bill, largely due to the inclusion of work requirements for the Supplemental Nutrition Assistance Program (SNAP; formerly known as food stamps). These requirements would have expanded the number of participants that would be subject to work requirements and create stronger penalties for those who don’t comply. The bill was also opposed by 30 conservative Republicans, members of the Freedom Caucus, who opposed the amount of funding for SNAP in this bill as well as failing to get concession on a future vote on immigration in exchange for their support.

NLC’s National Municipal Policy supports federal efforts to encourage employment that reduces dependence on welfare, provided it considers local capacity as well as regional differences and does not create unfunded mandates. As such, we had strong concerns about the inclusion of increased work requirements in this bill. Additionally, NLC opposed an amendment by Rep. Steve King (R-IA) that preempts state authority to regulate production of farm goods in other states.

The Farm Bill is wide-ranging legislation that establishes federal farm, food and rural policy. The current authorization expires on September 30. Important to cities and towns are the portions of the bill pertaining to rural development, water infrastructure and conservation, and food and nutrition. Prior to the House Agriculture Committee mark up, NLC weighed in on local priorities for the bill. 

It’s unclear if the House will modify the bill and attempt to bring it back to the floor for another vote. Meanwhile, the Senate has yet to introduce its bill. 

EPA Extends Deadline for WIFIA Applications

Carolyn Berndt, 202.626.3101 

On May 15, the U.S. Environmental Protection Agency (EPA) extended the deadline to apply for a Water Infrastructure Finance and Innovation Act (WIFIA) loan to July 31. 

WIFIA provides low-interest loans and loan guarantees for large water infrastructure projects of national or regional significance (projects of at least $20 million or $5 million for communities serving less than 25,000 people). WIFIA received $63 million under the FY18 omnibus appropriations bill, which the agency estimates could leverage over $11 billion toward water infrastructure projects. 

WIFIA credit assistance can be used for a wide range of projects, including:

  • Drinking water treatment and distribution projects;
  • Wastewater conveyance and treatment projects;
  • Enhanced energy efficiency projects at drinking water and wastewater facilities;
  • Desalination, aquifer recharge, alternative water supply, and water recycling projects; and
  • Drought prevention, reduction, or mitigation projects.

EPA has a number of resources to assist prospective borrowers, including:

In addition, past webinar presentations and recordings are available, and registration is open for two more webinars that the WIFIA program is hosting during the letter of interest submission period:

  • May 30, 2018; 2:00 p.m. - 3:30 p.m. (ET): WIFIA Letter of Interest Submission and Selection Process Question and Answer Session
  • June 4, 2018; 2:00 p.m. - 3:30 p.m. (ET): Overview of the WIFIA Program and 2018 Selection Round

Deadlines Fast Approaching for Department of Justice Grants

Yucel Ors, 202.626.3124

The Department of Justice’s Office of Justice Programs has several open grant solicitations that have fast approaching application deadlines. These grants include:

  • The Justice and Mental Health Collaboration Program (JMHCP) Grant Program: The program supports cross-system collaboration to improve responses and outcomes for individuals with mental illnesses (MI) or co-occurring mental illness and substance abuse (CMISA) who come into contact with the justice system. This program supports public safety and violence reduction through service partnerships that enhance and increase law enforcement responses to people with MI and CMISA. Deadline May 29, 2018.
  • Body-Worn Camera Policy and Implementation Program: The program supports the implementation of body-worn camera programs in law enforcement agencies across the country. The BWC PIP addresses the development and implementation of policies and practices for effective program adoption, and includes factors such as the purchase, deployment, and maintenance of camera systems and equipment; data storage and access; and privacy considerations. Deadline May 31, 2018.
  • Adult Drug Court Discretionary Grant Program: The program provides grants to either establish new drug courts or enhance existing drug court programs using evidence-based principles and practices. The program supports courts that integrate the National Association of Drug Court Professionals (NADCP) adult drug court standards into existing drug court services. Deadline June 5, 2018.
  • Comprehensive Opioid Abuse Site-based Program (COAP): COAP’s purpose is to provide financial and technical assistance to states, units of local government, and Indian tribal governments to plan, develop, and implement comprehensive efforts to identify, respond to, treat, and support those impacted by the opioid epidemic. Deadline June 7, 2018.
  • Adult Reentry and Employment Strategic Planning Program: The Second Chance Act programs are designed to help communities develop and implement comprehensive and collaborative strategies that address the challenges posed by incarcerated adults re-entering their communities and the workforce, as well as recidivism reduction.  The FY 2018 Adult Reentry and Employment Strategic Planning Program will provide funding for strategic planning grants to develop innovative approach to reduce recidivism and increase job readiness for offenders returning from incarceration and to integrate best practices in reentry and employment. Deadline June 18, 2018.

For more information about these and other DOJ grant programs, click here.

EPA Releases New Risk Management Proposed Rule

Carolyn Berndt, 202.626.3101 

On May 17, the U.S. Environmental Protection Agency (EPA) released the Proposed Risk Management Program (RMP) Reconsideration Rule to rescind or modify certain provisions of a rule published under the previous administration. The Risk Management Rule applies to facilities that use regulated toxic and flammable hazardous substances, including water and wastewater treatment facilities, and requires coordination with local emergency responders. 

On May 21, EPA held a briefing for state and local government organizations on the items for reconsideration from the 2017 RMP amendments. NLC previously raised concerns with several of the 2017 provisions, including costs to local governments both as owner and operators of water and wastewater treatment facilities and as first responders, as well as vague and unworkable definitions. 

The proposed reconsideration rule would eliminate requirements around third party audits and root cause analysis for accidents and near misses, while maintaining, with modification, provisions around local emergency coordination, emergency response exercises and public meetings. 

The Agency will be accepting public comments on the proposed rule for 60 days following publication in the Federal Register. The Agency’s intent is to finalize the reconsideration rule by early 2019. NLC is reviewing the rule and will likely submit comments. If cities or towns also submit comments, please forward a copy to NLC at berndt@nlc.org. 

FAA Drone Pilot Takes Off Over Cities

Brittney Kohler, 202.626.3164

On May 9, the FAA named the first ten participants for the Unmanned Aircraft Systems (UAS or drone) Integration Pilot Program (IPP). Announced last fall by the White House, this Federal Aviation Administration (FAA) IPP invites local, state and tribal governments to create partnership teams with the private sector to expand new and expanded integration of drone operations. While many cities have gained access to drone operations using a waiver process, these pilot sites are meant to drive data-collection for future rulemaking, increase drone use in the U.S. and encourage greater collaboration. 

Fields that could see immediate opportunities from the program include commerce, photography, emergency management, public safety, precision agriculture and infrastructure inspections, and industry enthusiasts posit that in less than a decade, the economic benefit of integrating UAS in the nation’s airspace could reach $82 billion and create 100,000 jobs. 

FAA received a robust response, with about 150 applications submitted in a very short response window, yet FAA’s selection of teams included the following cities:

  • City of Reno, Nev.
  • City of San Diego, Calif.
  • Choctaw Nation of Oklahoma, Durant, Okla.
  • North Dakota Department of Transportation, Bismarck, N.D.
  • Kansas Department of Transportation, Topeka, Kan.
  • North Carolina Department of Transportation, Raleigh, N.C.
  • Virginia Tech - Center for Innovative Technology, Herndon, Va.
  • Memphis-Shelby County Airport Authority, Memphis, Tenn.
  • Lee County Mosquito Control District, Ft. Myers, Fla.
  • University of Alaska-Fairbanks, Fairbanks, Alaska

NLC continues to advocate for expansion of cities’ capabilities to integrate drones in their communities on their terms and many drone provisions are being pursued in the FAA bill. NLC believes that cities’ engagement within current pilot projects can set the collaborative expectations for the future. If your state will have UAS testing, we encourage city leaders to request information and consultation from the drone pilot state lead, ask how they will facilitate community engagement, and learn more about cities’ traditional roles and authorities with drones in NLC’s “Cities and Drones” report. 

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