Select Committee on Environmental Audit Minutes of Evidence


Examination of Witnesses (Questions 320 - 339)

WEDNESDAY 26 MARCH 2003

MS JOHANNE GÉLINAS, MR JOHN REED, MR CHARLES CACCIA MP, MS HÉLÈNE SCHERRER MP, MR BOB MILLS MP AND MR JOE COMARTIN MP

  320. What sort of role do you see your committee might have in scrutinising the implementation of the government's commitments?
  (Mr Caccia) I do not know. We have not discussed it yet as a committee as to what we will do. Keep in mind that our committee receives legislation from the House and therefore our timetable is pretty heavy. We look at bills and we do that quite intensively, almost with religious fervour, and we send back those bills sometimes with 120 or more amendments, to the chagrin of the government. So when we have that type of time allocation we have also to keep in mind this other item that will eventually emerge, so maybe we will be able to answer your question in the near future. Right now we have not reached the point.

  321. Would it be possible for federal parliamentarians to meet with the provincial parliamentarians to consider these issues given that you were both represented at Johannesburg?
  (Mr Caccia) Well, that would be the close definition of a zoo and I do not know whether we want to go into that! But on a private basis, each one of us knows the environment critic in our respective provinces and so there is always some kind of communication at a personal level but the geography of Canada and the regional differences are such that it would be better if each province or each legislature were to do its own assessment and provide its own reply.
  (Ms Gélinas) What we may say and we often say, at least in my area, is first let us get the federal house in order and then lead by example. We can try to embrace everything but we may reach failure, so let us go step by step, making sure that at the federal level all the pieces of the puzzle are there and then if others, like at the provincial level, want to take the lead they will be free to do so.

  322. Just lastly, Mr Caccia, I wonder if any other standing committees in parliament are looking at post-Johannesburg outcomes?
  (Mr Caccia) Well, this is a very fine initiative by the Commissioner and, as she mentioned earlier, I believe, she appeared already before the Fisheries Committee and definitely the Commissioner, in order to make an impact on the system, including the parliamentary sector, has to almost invite herself before a committee and sometimes the chair is not receptive, in which case you cannot force it, sometimes there is an enthusiastic chair and then it happens and it becomes then an immense educational process in order to bring parliamentarians up to speed on the issues.

  Mr Thomas

  323. I would just like to follow up quickly on one point on the provincial level, and I appreciate you are all federal, are you not, so you may not be able to answer this directly but when we as a committee were in Johannesburg we did meet with the Environment Minister in the Gauteng province, Mary Metcalf, and she told us of what was called the Gauteng declaration and the network of regions for sustainable development and this was an international network of regional and sub-federal government, if you like, working for sustainable development. I just wondered whether you were aware of the provinces in Canada being involved in that sort of international coordination around regional governments for sustainable development?

  (Ms Gélinas) This is news to me.

  324. I was just interested to see whether this was being taken up at all.
  (Mr Caccia) But that soon detracts from the value of that type of initiative because very often the input from local governments is actually in advance of the thinking at the federal level for a number of good reasons.

  325. It is on a website if you want to have a look at it.[3]

www.earthsummit2002.org/subnational/Inserts%20-%20Declaration%20v3.pdf

  (Mr Mills) Two points I might mention. There is an Environment Minister's meeting from the provinces with the Federal Minister, so there is that coordination, and from the province that I represent they were in Johannesburg as well and taking a very active role in particularly the climate change aspects of that.

  Mr Ainsworth

  326. I think that some of us, Commissioner, were surprised to see in your evidence the role being played by the National Audit Office of the United Kingdom in moving forward some of these international issues and I see that you are developing a version of the auditor's guide to Johannesburg for international application. Could you tell us a bit more about that, how it could be made to work?

  (Ms Gélinas) Let me say a few words first about what is this international organisation and then I will turn to John to give you the detail. He is leading that. What we tried to accomplish through the working group on environmental auditing is to exchange information and to advent the audit practice specifically in the environmental field. We have a work plan and what we are trying to do with 48 other countries is to make sure that we are moving ahead in the same direction, if we can, on sustainable development. As you probably know, sustainable development is not a best seller. It is very hard to talk about and we have to find ways to translate that into something concrete and it is complex. When you look at the commitments that were made in Johannesburg and so on it is very difficult for a non-expert to figure out what it means. John was saying that just the vocabulary on its own is difficult to understand. So what we are doing is trying to translate that into concrete terms that an auditor will be able to implement in some way. So we will tell you what we have started to do to advance our thinking on how to audit.

  327. So you have got 48 countries which are sympathetic to this and are working with you?
  (Ms Gélinas) Which are doing environmental auditing on a regular basis.

  328. Are you trying to set up a common standard of boxes to tick, so to speak?
  (Ms Gélinas) Methodology to audit.

  329. An international methodology?
  (Ms Gélinas) Should we say an international methodology? Probably not. It is an approach. It will be more accurate to say an approach.
  (Mr Reed) I think it would be hard to go that far. Let me just say two other words about the members, because it is important for what we are doing. There are actually 180 auditors general in the world and 45 on this committee but there is quite a range of the mandates that those Offices have. In some ways we are at one end of the continuum because not only do we have a mandate to do performance audits, effectiveness and efficiency in government, but we have a very explicit reference to environment in our legislation. So although we may be at one end of the continuum we have a large number of Offices who have a performance audit mandate, which allows them to look at, among other things, environmental issues. But you also have some Offices who do not even have a performance mandate. They are strictly still doing financial audits for the government. So as a working group we need to bring that whole group together at the same time. So sometimes our approach is to provide high level guidance in a way that each office can adapt within their mandate. One of the ways we have done that as a working group is always starting with the production of papers, descriptive papers about what we want to look at. The very first one that group produced was simply `how to do an environmental audit' because it was new for many members. We have done a paper on water now that was authored by the institution in the Netherlands. Countries have already done over 300 audits on the topic of water alone. We have a second guidance paper which has been developed on waste management and that is being authored now and will be approved very shortly and that is intended to give guidance on how to audit waste. The National Audit Office in the UK has authored a paper on sustainable development. That one is in draft form now and eventually will be finalised. So that is a paper that is basically trying to give awareness on what SD is and how our Offices could audit it. Then behind that—this is where the audit guide comes in—we will take those ideas which are in the plan of implementation, turn them into plain language so that people can understand them and then identify audit criteria on how offices like ours could assess performance. But it will not be prescriptive and INTOSAI is not a prescriptive organisation, it is guidance.

  330. Are you able to share with us any of the content of the UK National Audit Office draft, because we have not seen it?
  (Mr Reed) Well, you would not have seen it because it has not been officially released by the working group yet, but I think we could easily share a copy. It was initially authored by the UK. Of course it gets reviewed and vetted by the entire body within an approvals process, so I think that is something that could be made available.[4]

  331. This may be a very difficult question for you to answer but I would be very interested in your perspective on it. Do you think that this Committee should be seeking reports on the whole implementation of the Johannesburg issue from our National Audit Office in the UK in the way the relationship seems to be working in Canada? Would you recommend it to us?

  (Mr Caccia) You have an excellent Commission actually on sustainable development and probably you have already invited them to appear before you and I cannot think of a more powerful alliance than the one between your Committee and the Commission, the National Audit Office and DEFRA. You have a tremendous amount of intellectual capital that you have invested in this issue and you have to bring it to bear in a coherent manner through your Committee's work.

  332. Thank you for that advice. One slightly more technical question, if I may, to do with these type 2 outcomes, the partnership arrangements. I think some concern has been expressed that they do not involve any formal relationship with ministers or politicians. Is that something which needs to be addressed and if so, how do you think it should be? I think I am now talking to the Commissioner.
  (Ms Gélinas) What we have said is that partnership is probably now the way to go and that was part of Johannesburg, that partnership will be the way to implement some of the commitments that were made. What we have said as auditor is we have to be careful because things are moving in a way that it is becoming more difficult to audit government because part of the task is given to partners and we cannot get to the partners to figure out if they are doing what they were supposed to do. So we need some good governance, a new type of arrangement, so that no matter what the partnership model is that will be put in place we can still hold government accountable for the results. We have thought of that for a while now and it becomes more and more difficult to report back on what the government is doing because in many cases they will have partners who are doing the job and we cannot get there. So part of the challenge is to make sure that there are clear arrangements, that the role and responsibilities are clear, the arrangements are well known, there is transparency, as we should expect, in the government. All these elements should be put in place so that no matter what is the partnership programme that will be put in place we will be able, if the Federal Government is involved, to report back.
  (Mr Reed) Just very quickly, I think there are many types of partnerships. Some are directly implementing public policy, in effect they are displacing work that traditionally has been done by government, and those are the ones that we are especially interested in. If there is anything that we all collectively will need to find out as our governments announce these partnerships, I think it is to know which ones are actually displacing traditional roles of government because those are the ones you have to pay attention to, because that is where accountability in governments comes in. It is not always going to be easy to make that determination because sometimes they are announced as just good things to do and it would be difficult to know whether that partnership is actually replacing a regulation which might have been written. So I think that is the key thing that you need to try and determine, is that partnership something which is displacing a traditional government role, and if it is then you ought to be interested or we as an audit Office would be interested from an accountability in government standpoint.

  Joan Walley

  333. Just to pick up on that point, I think when we were asked in Johannesburg—and not just then but at other times as well—we are particularly concerned about that whole agenda and the WTO and the way in which the whole trade agenda is progressing and the need for accountability and transparency there. I think that in view of the latest trade talks which are now under way and setting the agenda for the WTO, we would be very interested in any thoughts you have about where these partnership arrangements, which are the outcomes of Johannesburg, fit into this separate issue which is also a governance issue as well.

  (Mr Comartin) I suppose, Chairman, at least the people sitting here at the table, who are politicians, would have a widely divergent view on that particular issue. My guess would be that mine would be fairly close to Miss Walley's but Bob's would probably be significantly different.

  Mr Ainsworth: We will allow that to rest, I think!

  Gregory Barker

  334. I wanted to pick up with the Commissioner the point about communicating a vision of political leadership which she alludes to in her annual report and it is something obviously that we are very aware of here where we have a government which is very keen on the environment, unless of course it costs money or conflicts with any other priorities or requires legislative action. In particular, in point 41 you talk about the need to have a small number of key priorities and specific objectives for the next 10 years and to couch that in language which ordinary Canadians can understand. How has that been received and how effective do you perceive the Canadian political parties to be at the moment in actually implementing that?

  (Ms Gélinas) The problem we are facing in Canada—and I will not get into the politics of it, I will leave that to Mr Caccia—what we are seeing at the moment is that we have different strategies. The Department of Industry had its own strategy, the Department of Environment, International Affairs, and so on, and we are wondering how we can move forward in the future if we do not know what is the big picture. John has used a metaphor to illustrate that it is like asking the partners to do a puzzle without the picture on the box. So we do not know as a country what are the priorities, what we would like our country to look like and we need something, a destination somewhere to make sure that all the strategies are moving in the same direction. They may not go at the same speed, they may not choose the same mode of transportation but at least we would like to know where they are going and if there is some contradiction in their path. So what we need is a vision. We do not have, as we speak, in Canada a priority. If you ask anybody what are the environmental and SD priorities of the government you will be lucky if you can find an answer. You may find many answers but they will not be the same and what we have asked was for the central agency like the Privy Council, Treasury Board, to help the departments shaping that vision so that each of the departments will be able to follow a path that will bring us to the same place. So we need that. We are at that stage when I am talking about a plateau. This is where we are at the moment. We need that vision. Politicians are involved in building that vision, Canadians are involved, we are all involved in creating that vision, but the political will has to be there and we are asking who is the pilot in the plane.
  (Mr Caccia) Usually political parties, as you know, and governments think from one election to the next. That is the pattern of democracy. Sustainable development poses the unique challenge of having to think beyond the next election and that is where your challenge is for politicians. We are not accustomed to doing that. All our efforts are usually aiming at winning the next election and then once that goal has been achieved then the next one. So in the case of sustainable development the political problem, if you like, is no longer four years or a variation to it, it is 20, 40, 60 years, beginning to think in terms of a century. This is why your report on the reduction by 60% of greenhouse gas emissions by 2050 is so remarkable because it sets a benchmark which has emerged for the first time, as far as I know at least, within the government. The White Paper I am referring to. Therefore you can imagine then the difficulty that the Commissioner faces when the Commissioner has to convince parliament to think beyond the next election while their masters are focussed on the next election and in avoiding embarrassment for the next election. Therefore, you do not want to close down the fisheries, you do not want to reduce cuts in the forest, you do not want to deny water permits to those who want to export water because it is good for a certain region, you name it, there are many resolutions that are short term and the Commissioner for Sustainable Development instead is swimming in long-term waters.

  Chairman

  335. Just following that up, Mr Caccia, could I ask whether you are pessimistic about the importance or the perception of the environment worldwide? Do you think we are going through a phase now where the environment is becoming regarded as less important or more important in the eyes of government and public opinion?

  (Mr Caccia) I will quote for you from page 5, item 12, of the paper that is before you, what the Commissioner has written, namely, "a new kind of deficit: not a financial one but an environment and sustainable development deficit—a growing environmental health and economic burden that our children will have to bear. We reached this conclusion based on 10 years of audit findings as well as analysis of key trends over the past decades." So this is the message that our Commissioner is giving you and us and I think that comes as close as I can come to your question.
  (Mr Mills) All I wanted to add is that I think it is a communication thing. As an example, I just had a professional poll done on my riding this past Sunday, "What is the number one issue for you as a Canadian?" and the result is that 40% of the people identified health as their biggest concern, 15% were taxes, and so it went, and 2% were concerned about the environment. So the key is to tie the environment to what they are most concerned about, and that is health. So as soon as you now start talking about the environment affecting your health you now have tied it in. They do care about the environment but when you tie it to health now they really care about the environment. So that is the critical thing for all of us who care about the environment, to tie everything to what the public's number one issue is and that is their security and health.
  (Mr Caccia) Yes, that is fine and that is desirable and it is as Mr Mills put it, but you also have to tie the environment to the long term economy because then people will start to listen to you carefully. Most of governmental decisions are based on economic considerations and when you are talking about the economy as it will be affected by declining quality, declining trends and all other elements that you have established by the Commissioner and other sources then you can develop a pretty strong economic argument as well parallel to the health argument.

  Mr Ainsworth

  336. I hear what you say about the lack of public interest and yet the Commission's pronouncements, particularly the annual report, I think I am right in saying, gets quite a lot of publicity. So is there something different about the media in Canada to what we have got here, because here it is very, very hard to get environmental stories anywhere near the front page of any newspaper? The specialist journalists have their bit but turning those stories into news stories is incredibly difficult to do. Is there something you do that we are not doing that you could share with us?

  (Ms Gélinas) I can speak for my work. We have found over time that to have an impact we have to talk about things that affect people. I will give you an example of one of the audits we did last year. We have looked at federal contaminated sites. It concerns every region of Canada. First, that is something important because we may have an impact across the country. Then we have linked our analysis with some health issues and then to get attention of another sub-section of the audience we have linked that also with economic consequences. So it is easier now the way that we shape our audit with the three pillars of what is sustainable development to avoid using the word because it is very abstract, but we also bring that to a reality for Canadians, what does that mean. This is one of the challenges we have with Johannesburg. We have to translate that event and what it means into concrete terms for everyone and that is one of the challenges we have. I have to say that overall we have very few specialised journalists in environmental, I would say probably less than five, but nevertheless the environmental group find their way to get attention and industry also are involved in some environmental issues. I would say that probably every week we have good stories dealing with the environment, from different perspectives but still the environment. Even if it is not that high when you look at the polls, on the other hand it is on the agenda. We talk about the environment. Maybe not as much as we would like to, but still.
  (Ms Scherrer) Maybe for those of you who have worked at the municipal level, for example, we do not use maybe the broad term "sustainable development" or "environment" and if we do some polls and ask the people what are their priorities they will come up with pieces of environment, such as waste, or they will come up with pesticides and they will come up with the quality of water, which now is for us something that we talk about in the press. So maybe because we are so used to using the broad term "environment" people do not really know what it means in the day to day living but if you come up with pieces of environment, such as the quality of water, for example, it is one priority. But for the people, if you ask them, the quality of water maybe does not go under the broad umbrella of environment but if you talk about concrete actions, concrete subjects such as waste management, for example, it is a priority. It seems that when you come up at the provincial level and the federal level environment is just something like a cloud going around and you cannot touch it really and maybe the challenge that we have working for sustainable development, working under the environment, would be to make sure that it is concrete in the day to day living and that every citizen has his responsibility. Once we have done that maybe the people will get into sustainable development.
  (Mr Caccia) Establish a yearly award by this Committee for the best environmental writer in the UK and the first year you will have problems in finding one but once the word goes around that there will be recognition for a good environmental writer they will begin to pay attention.

  337. Chairman, I think that is an extremely good idea.
  (Mr Comartin) I am trying to figure out why he did not tell us that!

  Mr Savidge

  338. From your annual report carbon dioxide emissions are actually still going up rather than coming down towards Kyoto levels. I wonder to what extent Canada feels constrained from taking more decisive action in areas like energy production by your very close economic links to the United States? Coming back to the issue of public attitudes as well, when we were visiting Canada we had a very graphic illustration of the problem when we were visiting the Ontario authorities. They did not bother showing us a slide or anything, they asked us to look outside the window and you could see—I think your phrase was "a cloud going around that one could almost touch." Well, it was a cloud going around that you definitely did feel you could touch. It was this great block of air pollution coming from the south side of the lake. I just wondered how far that creates difficulties for you at present?

  (Ms Gélinas) But not in terms of auditing. Certainly that helps us in a way that people want to know more about what is going on and will bring some very factual information that will help. Maybe one thing that we can take a few minutes to talk about is, two years ago we decided to do a report dealing with a geographical area, which is the Great Lakes, and we have looked at five different issues there and we have a report back on the environmental and SD situation in this area. John was responsible for that, so maybe that can illustrate the kind of issues that we are dealing with and how people react to that report. We get a lot of buy-in into our report because we were able to illustrate all the linkages between air pollution, water quality, agriculture and other aspects.
  (Mr Reed) The Great Lakes, as you know, border Canada and the US so clearly it is the equivalent of the air situation, that is if the US does not take action anything Canada does could more or less be moot in any event because they have a much greater concentration of industry and influence, and so on. In part of the framework of this audit we very much wanted to look at it from an ecosystem perspective and that is why, as Johanne says, we looked at issues of water but also issues of fisheries, agriculture, habitat, endangered species, as components of that ecosystem. There were more but we could not have done those. We also looked at the overall governance framework that existed in that region. There is a binational institution that oversees an agreement there. We had many, many lessons out of that piece of work but with respect to the binational component it really did drum home for Canadians, first of all if we expect the US to do their fair share, we have to do our fair share and the reality was we were not meeting our basic commitments under our binational agreement. So it becomes pretty hard to try to convince another country to take action when they have not taken it themselves. Secondly, we determined that the key institution that protects Canadian interests, the International Joint Commission, was being undermined by reduced budgets and loss of scientific personnel and loss of scientific data. So it was a very different kind of audit. I am not sure that is getting to your question around the influence of the US, but it was clearly learning for us.
  (Mr Caccia) Going back to your experience in Toronto, it is easy to blame the Americans for this dark cloud that you mentioned but the fact is that in Toronto, where I come from, there is a very large power plant using coal and the pollution that we have is mostly generated on our side of the lakes rather than the American side of the lakes. Having said that, going now on CO2, it is—for Canada—going to be a major task to reduce by 6% by the year 2012 based on 1990 because what happened between 1990 and now is a sharp increase in emissions and therefore we have to reduce by 23, not 25, 26 percentage points. So we are engaged in a major effort here, but it can be done. We are an energy waster. We have not yet learned how to conserve, how to innovate in energy efficiency and we have a plan now, which is quite elaborate. It was produced in October and it is also unique because it reaches out to the public. It invites the individual Canadian to do his or her share in the reduction of tonnage per year, in addition to what it is asking various sectors. So we have a long way to go but we have a reasonably imaginative and good plan and we will get there. But there is no blaming the Americans here, this is our responsibility and the fact that it is a difficult task is because of our making.
  (Mr Mills) I blame the Americans! I could talk a long time about Kyoto. Some of you might check the record on that one but two things regarding the Americans. First of all, Canada has exempted the automobile industry in terms of manufacture. However, because automobiles are a major polluter, the reason why we will achieve our goals on automobiles of a 25% reduction is because California will. Thirty-nine states will in fact probably achieve Kyoto targets. So this concept that the Americans are doing nothing is just totally not correct because they are probably going to be the guys selling fuel cells to all of us and they are developing new windmills and all kinds of things. They are really quite into this. The other thing to remember is that where I come from we have oil deposits that are twice as large as Iraq's. Just to put that into perspective, people say, "Well, the Americans are going to war because of oil," we have twice as much oil in the Tarsands as there is in Iraq, proven reserves, so it would be much easier to develop those reserves than to spend $100 billion, or whatever, in Iraq. That is another issue, but still the point is that those reserves are going to be developed and right now it takes a lot of energy to do that and right now it is natural gas that is producing that energy to produce the steam to get that oil out of the ground. Each year it is a 100,000 more barrels that come out of there. What it is going to result in because of Kyoto, I think, is we are going to go to nuclear and we will develop nuclear plants which will provide the energy to get that oil out of the ground. Is that what we wanted to achieve? From a public perspective, I think it is going to be a hard sell but if you want to sell that oil, that huge reserve, you have got to have energy to get it out of the ground and where are you going to get it from? Well, either you are going to put more CO2 into the air or you are going to use nuclear.
  (Mr Comartin) I cannot let that go by! You can imagine we have had this debate once or twice, several thousand times! Bob does make a good point and we do agree on this, that it is really the Bush administration, not the American public and certainly not the state governments. The state governments in fact, as Bob says, in most cases the majority of the state governments are going to meet what would be their Kyoto requirements by 2010-15, which is very positive. But the problem with the cross-border air pollution is a major problem. I come from Windsor and I am right across from Detroit. I get all of the air pollution which comes up from the Mid-West in the United States, which is the industrial heartland of the United States still. So it is a major problem and it is one where—we go back to why we are here—the effect it is having on us is one that we are seeking some relief from the Federal Government, much as you did when you were on the receiving end when you were damaging the forestries in Norway in the 60s and 70s because of the amount of coal and the sulphur in fact that you were sending across, the whole acid rain problem. We have begun to work on that with the Americans at the Federal level. Unfortunately, the Chancy Report on the use of energy in fact encourages the operation of coal-fired energy plants. So that situation is going to be a real deterioration. It is one again where we go to what we are here about, that Commissioner will in fact, I would think, be documenting that on an ongoing basis. Bob has the same problem on the western end of the country with plants being built in the American side that are going to increase not only CO2 but we are going to be getting benzine and mercury and some of the other really toxic material moving across because of prevailing winds.

  339. I applaud the way that all of you have avoided the lure of the easy jingoism as far as the US is concerned, but really taking up the point you made that the Bush administration is really more the problem than individual state administrations, do you have any dialogue of the sort you are having with us with committees in Congress? Similarly, taking up the point you were making that the individual states very often are considerably more forward looking than perhaps the Federal administration, is there a significant amount of dialogue between parliamentarians at the state and provincial legislative level? Are you doing that at present or is that something you think might be an easy thing to do?
  (Mr Comartin) I personally am having some involvement because there is this issue of the way the wind blows through the area you are at. We do have those coal-fired plants on our state. The State of New York has initiated law suits in the past and has one going on right now that we have actually participated in, both the provincial government, Ontario, and the Federal Government participated in that action and it was resolved and then the Bush administration just before the holidays, before the turn of the year, changed the regulation and in fact opted not to enforce. So the State of New York has now opened up a new law suit, so I am having some direct contact with the Attorney-General of that state. So we have those kind of contacts. Some of the other members of this committee were in Washington last January when we met with parliamentarians from Europe, both the Senate and Congressional Committees, and our committee was in Washington. That was mostly around climate change.
  (Mr Mills) I can add too that on the western half of things, just to put it into perspective for distance, from where I live I am one hour from Seattle, two and a half hours from Los Angeles and four and a half hours from Ottawa. So obviously we have quite a close connection to the south, sometimes more than to the east, but we do talk to them quite frequently and do communicate on issues, particularly environmental ones.

  Mr Chaytor


3   The Gauteng Declaration-please see: Back

4   Not printed here. Please see documents on the INTOSAI website at:
http://www.environmental-auditing.org/intosai/wgea.nsf/viewEsearch/3DEE046BA2075CD185256CDF00568EC8
http://www.environmental-auditing.org/intosai/wgea.nsf/viewEsearch/1D115A594AED998985256CEC006A3FE0
http://www.environmental-auditing.org/intosai/wgea.nsf/viewEsearch/30C46FAA21F73F0285256CDF005693F9
http://www.environmental-auditing.org/intosai/wgea.nsf/viewEsearch/45EF4C7B0501489585256CDF00568722 
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