Select Committee on Trade and Industry Written Evidence


Memorandum by the Association for the Conservation of Energy


  The Association for the Conservation of Energy is a lobbying, campaigning and policy research organisation, and has worked in the field of energy efficiency since 1981. Our lobbying and campaigning work represents the interests of our membership: major manufacturers and distributors of energy saving equipment in the United Kingdom. Our policy research is funded independently, and is focused on four key themes: policies and programmes to encourage increased energy efficiency; the environmental benefits of increased energy efficiency; the social impacts of energy use and of investment in energy efficiency measures; and organisational roles in the process of implementing energy efficiency policy.


  The 2003 Energy White Paper and numerous other documents have correctly identified energy efficiency as the cheapest, cleanest and safest way[2] of addressing all of the UK's four key energy policy objectives: cutting carbon emissions; maintaining reliable energy supplies; promoting competitive markets; and ensuring that every home is adequately and affordably heated.

  This echoes what the Energy Select Committee said over 20 years ago: "It is our considered opinion that there are now many conservation measures which are so much more cost effective than most energy supply investment." [3]It was also the view of the Royal Commission on Environmental Pollution in 2000: "There is a strong economic argument in favour of raising energy efficiency." [4]

  Yet, just three years after the most comprehensive review of energy policy in a generation, we find ourselves still having to make the same point.

  It is true that some of the benefits of energy efficiency have already been realised—through modest schemes and at little or no cost to the consumer.

    —  Climate Change Agreements have been enormously successful;

    —  practically all EEC 2 savings are already accounted for; and

    —  the EU ETS has successfully established a market price for carbon.

  So Government policies to reduce energy use are working. Yet to realise the full potential that demand-side energy measures offer, a simple, market-based framework must be applied on a scale that is commensurate with supply-side solutions currently deployed. In this way any nuisance associated with small scale approaches can be overcome.

  Even at current levels of activity, the economics of saving energy consistently shine when compared with generation. Any programme of nuclear new build is fraught with both cost uncertainties and is almost certain to require taxpayer input. It is ACE's submission that rather than devoting tax revenue to meet costs associated with limited liability guarantees, safety and security arrangements, and so on, these resources would be better spent reducing dependence on energy, reducing fuel bills and creating warmer homes and businesses.

  The central theme of this submission is that an upstream cap and trade scheme, replacing the EEC in 2011 will provide such a framework. It will deliver energy efficiency and microgeneration on such a scale that concerns over lack of consumer awareness, lack of financial incentives, and confidence in installers and rebound effects will be overwhelmed by a robust, competitive energy services market.

  Government must make the wholesale commitment required to shift from modest energy efficiency schemes that are successful on a modest scale to schemes that are hugely successful on a huge scale.


  The Energy Review may not be about replacing one potential solution with another but it is quite clearly about setting a framework that will define the UK's energy priorities. Its outcomes may lock this country into certain trajectories for a very long time.

  Various data are available which compare the cost of both producing and saving energy: the National Audit Office concluded in a report on an electricity-only saving scheme for residential customers, run by the 14 local energy companies in Britain, that the cost of electricity saved was 1.8p per kWh[5]. In December 2003, the European Commission published its draft directive on "Energy End-Use Efficiency and Energy Services"[6], to "promote good practice in energy efficiency". Paragraph 1.1 states that "it is estimated today that the average cost in Member States of saving a unit of electricity in the domestic sector is around 2.6 Euro-cents [1.8p] [7]per kWh, compared to the average off-peak price for delivered electricity of 3.9 Euro-cents [2.7p] per kWh and on-peak price of 10.2 Euro-cents [7p] per kWh."

  In the case of nuclear generation, the most recent price given by the Government for the anticipated cost of a new nuclear power station assumes that current new-build designs could produce electricity for 3.9p/kWh[8]. However, it is far from clear precisely what this figure includes and excludes.

  Dr Amory Lovins states in his recent publication[9]: "Nuclear power is an inherently limited way to protect the climate, because it makes electricity, whose generation releases only two-fifths of US CO2 emissions. [...] But nuclear power is a still less helpful climate solution because it's about the slowest option to deploy [...] and the most costly. Its higher cost than competitors, per unit of net CO2 displaced, means that every dollar invested in nuclear expansion will worsen climate change by buying less solution per dollar. Specifically, every $0.10 [5.7p] [10]spent to buy a single new nuclear kWh ... could instead have bought 1.2 to 1.7 kWh of wind power, 0.9 to 1.7+ kWh of gas-fired industrial or ~2.2-6.5+ kWh of building-scale cogeneration, an infinite number of kWh from waste-heat cogeneration, or at least several, perhaps upwards of 10, kWh of electrical savings from more efficient use. In this sense of "opportunity cost"—any investment forgoes other outcomes that could have been bought with the same money—nuclear power is far more carbon-intensive than a coal plant. For these reasons, expanding nuclear power would both reduce and retard the desired decrease in CO2 emissions."

  In the UK context, the full cost of nuclear generated electricity remains obscure: In its recent Position Paper on nuclear energy[11], the Sustainable Development Commission (SDC) concluded that cost estimates for a new nuclear programme are unlikely to be accurate, as the available information was not sufficiently reliable, independent, or up to date. It indicated that any such programme is likely to suffer from moral hazard[12] so that taxpayers will inevitably shoulder some of the cost burden. The Commission also identified few certainties in the estimation of waste and decommissioning costs, not least because these cost streams extend to such vast time horizons, and externalities are excluded from standard cost benefit analysis. These externalities include safety and security arrangements, limited liability guarantees, health issues relating to routine operation and accidents, and foreign policy shifts affecting security of uranium supplies. The Warwick Business School shares this view[13].

  The Energy Review consultation document indicates that the share of nuclear generation might fall from its current level of 19% of the total electricity mix, to 7%[14]. Yet in order to replace this deficit like for like, taxpayers (including those not yet born) will have to pay to some extent, for toxic waste storage, decommissioning, limited liability guarantees, health-related costs, and so on. And yet the Review document states that energy efficiency is capable of contributing further savings of 9 MtC by 2020[15], and provides the best opportunities for reducing our dependence on gas[16]. These figures have been produced by eminent independent researchers and analysts, brought together by the former Cabinet Office Performance and Innovation Unit (now Prime Minister's Strategy Unit) and developed for the Energy White Paper.

  Thus, investing in energy efficiency and energy saving is the cheapest way of delivering both carbon dioxide reduction and maximising the use of energy supply. Therefore, until all available energy saving and energy efficiency measures have been undertaken, we should not even consider investment in nuclear plant. Economically there is simply no case for it.


  Work undertaken by the Energy Efficiency Innovation Review[17] has, as spelt out in the Energy Review consultation document, identified four key challenges energy efficiency programmes and policies must overcome in order to be more effective.

    1.  The rebound effect.

    2.  Users unaware of the potential savings inherent in energy efficiency.

    3.  Users not taking into account the full economic savings available from investments in energy efficiency.

    4.  Distrust of suppliers and installers.

  These challenges can be met: they can be met simply by Government setting frameworks and allowing the market to deliver through an upstream cap and trade system.

  Government must make the wholesale commitment required to shift from energy efficiency schemes that are successful on a modest scale, to schemes that are hugely successful on a large scale. In making such a commitment, demand-side schemes can overcome the obstacles named, and can stand alongside supply side options on a like-for-like basis.

4.1  Rebound effects and comfort taking

  Rebound effects occur when some of the energy saved through an energy efficiency measure is then spent on more energy, rather than being saved through lower energy bills. Related, comfort taking occurs when a proportion of energy saving is taken as improved living conditions.

  The rebound loss is at least cancelled out by supply-side loss as, according to Defra, up to 30% of an energy efficiency improvement may be taken by comfort factors. Whilst leakage from comfort taking is significant, it is also true that the electricity supply sector suffers from similar loss rates as, by simply producing energy, it accounts for 35% of all emissions[18].

  However, whereas supply-side losses generally manifest as waste heat, which elicits no benefit, energy efficiency "losses" are taken in the form of "comfort", leading to a net welfare gain. All things being equal, one would surmise that a demand-side welfare gain, especially in low-income households, is preferable to a supply-side loss, in the form of lost heat. Therefore any rebound effect argument is at least matched by supply-side losses.

4.1.1  Upstream cap and trade: domestic sector

  Unlike supply side losses, rebound effects can be virtually eliminated. While the transaction costs associated with a personal carbon trading scheme may at this time prove prohibitively expensive, it is ACE's submission that a large-scale upstream cap and trade scheme, encompassing all suppliers of energy, must be central to any attempts by Government to observe their commitments to tackling climate change.

  To this end we support the recommendation made by the Energy Efficiency Innovation Review's household report that EEC should move to a supplier cap and trade arrangement after 2011[19].

  However, in line with Government's thinking that it must "win hearts and minds" to motivate consumers to use less energy[20], ACE firmly believes that, with a view to 2020, some form of downstream, personal carbon trading scheme should be in place by this time. Indeed some energy suppliers have already commented upon the inevitability of such a scheme.

  Through this graduated approach, from upstream to downstream carbon trading, the public will become far more "carbon literate" and will be financially motivated to take action to reduce emissions without "rebound".

  Such an arrangement is also bound to lead to a more competitive market of energy service providers, which will in turn improve the accreditation of and trust in installers and energy suppliers, and reduce the "cost perception gap". Personal carbon trading has also been shown to be less regressive than other financial instruments[21] and could provide a major step forward to realising the legal commitment of the permanent elimination of fuel poverty.

4.1.2  Commercial and industrial sectors—expand cap and trade

  In non-domestic buildings, work by BRE[22] shows that there is potential for savings amounting to 4 MtC—approximately 20% of commercial sector emissions—using only cost-effective options already on the market. Within the workplace, employees should be motivated to contribute to saving energy through the "gain-sharing" approach advocated by the Carbon Trust. There is scope to engage the commercial sector in the approaches already demonstrated to be successful in the wider industry setting.

  Climate Change Agreements (CCAs) have been enormously successful. Over the course of the first target period—from March 2001 to April 2003—they had already saved 4.5 MtC[23] (ie 2.25 MtC per year), with around 88% of all target units recertified. This is against the backdrop of the Energy White Paper estimating 2.5 MtC per annum savings from CCAs by 2010. [24]From the outset, CCAs nearly saved this much per year already. The subsequent Energy Efficiency: The Government's Plan for Action upward-revised carbon savings from CCAs by 2010 to 3.8 MtC annually by 2010, [25]to reflect their success. And, in addition to the financial savings gained from the reduced rate of Climate Change Levy, it is estimated that CCA participants collectively save over £450 million per year from their reduced energy consumption[26].

  These savings, achieved at no cost to the taxpayer, proffer only a taste of what targeted cap and trade approaches offer. Government must maximise the potential of CCAs, widening their application within an expanded UK Emissions Trading Scheme encompassing all industrial and commercial sectors. This type of framework will allow the market to deliver against climate change goals and improve the UK's international competitiveness.

4.2  User lack of awareness and distrust

  Awareness of the benefits of energy efficiency includes the so-called "cost perception gap" and "split incentives". The cost perception gap occurs where consumers have poor knowledge of the costs and benefits of measures, and tend to over-estimate the costs and installation time, while underestimating the savings. A common "split incentive" is where a landlord invests in energy efficiency improvements that lead to lower energy bills for the tenant, but without any benefits accruing in terms of return on investment.

  The cost perception gap can also be addressed by better information and marketing by the agencies and by energy suppliers through an upstream cap and trade framework. Householders will not be convinced by rational arguments alone, and suppliers are well placed to compete with the innumerable product messages consumers receive by motivating the purchase of energy services emotionally too.

  Split incentives will be best dealt with by the energy performance certificates that must be made available whenever a building is rented (or built or sold), as required under the Energy Performance of Buildings Directive. While it is not expected that higher-rated buildings will initially attract higher rents, research by ACE[27], funded by the Carbon Trust, indicates that prospective tenants of poorly rated buildings might use this information to renegotiate the rental terms. This may prove a sufficient motivator for investors and property owners to reassess their portfolios in terms of energy performance and implement energy efficiency improvements.

  Within a revised EEC/energy supplier-led cap and trade framework, it is plainly obvious that consumers will be made aware of potential energy efficiency savings. Indeed, this framework will achieve the step change in carbon literacy required if this country is to "win hearts and minds" and meet its climate change goals.

  Predicated upon the wholesale installation of smart meters, such a framework will oblige suppliers to market energy efficiency to their customers.

  It then remains to remove the distrust of installers and energy suppliers, low awareness of accreditation and the lack of recommendation that combine to impede uptake of energy efficiency measures.

  Once again, an upstream, supplier-led cap and trade framework will deal with these issues. Once energy suppliers are required to offer energy services in order to meet their tradable carbon quotas, the market must deliver a credible service—through accreditation of installers, through quality assurance, through marketing. Once these services are available, personal recommendations from customers are bound to follow.

4.3  Fiscal Incentives

  Given the above, it is clear that there is a need for the introduction of greater fiscal incentives in order to achieve Government goals, and these must be in step with moves towards a cap and trade EEC by 2011.

  The Treasury, in consulting no fewer than three times in the last four years on possible measure, has explicitly acknowledged the need for such incentives.

  On each occasion, the Association for the Conservation of Energy has responded fully and positively in favour of a range of fiscal incentives, many of which have a wide range of support both in and outside Parliament.

  There has, however, been a distinct lack of progress. The Association for the Conservation of Energy joined last November with the Energy Saving Trust, the Energy Retail Association, the Environment Agency, National Insulation Association and WWF-UK in writing formally to the Economic Secretary, John Healey MP, endorsing three important measures—council tax rebates, a stamp duty rebate and Reduced Planning Gain Supplement for housing developments meeting a high energy performance standard. However, despite this latest plea to Government, Budget 2006 has once again disappointed us by failing to introduce a single new fiscal incentive to encourage energy efficiency.

  ACE firmly agrees with the suggestion by the Energy Efficiency Innovation Review[28] that reduced costs, delivered via a rebate on Council Tax, will create more of the awareness and confidence needed to increase uptake, than suppliers could deliver by themselves. Indeed we support the recent initiative launched by Defra and British Gas where householders receive a council tax rebate of up to £100 upon installing cavity wall insulation. This approach is a clear step towards introducing the provision of energy services by energy suppliers.

4.4  Building Regulations

  With 40% of UK CO2 emissions coming from buildings, there is a huge opportunity for Government to make better use of building standards that are understood by the industry and enforced by building control officers. It is shameful that a sector of UK industry is allowed to flout legally required minimum standards with impunity[29].

4.4.1  Buildings Obligation

  It is encouraging that the Government has signalled its intention to improve the Code for Sustainable Homes (CSH) in line with three of ACE's key CSH recommendations[30]. We welcome the proposal to set minimum, non-tradable energy efficiency standards for each of the five levels, and we hope that they will stretch sufficiently beyond Building Regulations in order to make a meaningful contribution to the UK's fuel poverty and climate change goals.

  We also welcome ODPM's statement that the new CSH requirements will form the basis of the next wave of improvements to Building Regulations. This will allow developers to prepare with confidence for the future.

  However, in addition to using the CSH to signal future revisions to Part L, we recommend the Code itself be developed to encompass a Builders Obligation, as called for in the Energy Efficiency Innovation Review. Under such a framework volume builders would be required to construct a fixed percentage of their homes to CSH standards each year. Such an obligation would stimulate greater market penetration of new technologies and lead to further institutional learning within the domestic construction industry. Ultimately it would set a framework and allow the housing market to deliver savings in a sector that accounts for 30% of total UK energy demand[31].


  The emerging microgeneration industry has the potential to offer a more competitive alternative than nuclear new-build and other supply-side options. Some of this is directly observable even at today's pre mass-production prices, but there are other less tangible effects likely to be experienced, outlined below.

  Energy efficiency measures and microgeneration are mutually reinforcing—once energy demand has been cost effectively reduced, microgeneration can produce a much larger share of the remaining demand very cheaply and consumers become more aware of the energy they are consuming. Of course this combination is best delivered through the cap and trade approach recommended throughout this document, and manifests a tidy solution: it ensures energy security for each household and business (as well as for the entire UK), tackles fuel poverty directly through reduced, externally generated energy, reduces CO2 emissions and significantly, introduces truly competitive energy markets. Large-scale adoption of an integrated demand-side energy framework embracing energy efficiency and microgeneration is central to a sustainable UK energy future.

5.1  Cost comparisons: micro versus large scale generation

  British Energy has estimated the cost of building a further 11GW of nuclear capacity at £10billion, or £833-£1,000 per kW—rather ambitious given that the last station to be built in the UK cost almost £3,000 per kW, over three times as much. By comparison, microgeneration technologies start at around £500/kW of installed capacity.

  A recent Green Alliance report[32] gives the cost of nuclear power delivered to grid as anything between 1 and 6p/kWh. Costs associated with transmission and distribution, metering and losses need to be added to this. These typically make up just fewer than 40% of today's retail price of electricity, or around a further 3.5p/kWh. This places the cost of nuclear power, at the point of delivery to the customer, at up to 9p/kWh.

  According to the Performance and Innovation Unit Energy Review, some forms of microgeneration are as cheap at today's manufacturing prices as 4p/kWh, falling to 2.5p/kWh once in mass production. Towards that objective, the announcement in Budget 2006 of ring-fenced funds to this end, within the Low Carbon Buildings programme, is welcome. The bulk of cost associated with transmission and distribution is avoided for microgeneration, because it generates at the point of demand. Moreover, the lead-time associated with installing microgeneration can be measured in months, not years.

5.2  The Capital and Energy Markets

  The waste processing and decommissioning liabilities associated with nuclear plant have led to the widely accepted view that the private equity markets will not provide the total capital needed for a programme of new build.

  Given this, there would appear to be little choice other than for the taxpayer to fund a new build programme directly, or at least to act as a guarantor.

  Acknowledging that around £10 billion would be required up-front for a new nuclear build programme, the Green Alliance report examines possible alternative uses for this money in the microgeneration sector:

  Micro-combined heat and power (mCHP) —The price differential between a conventional boiler and a mCHP boiler is £500. If half of the 1.3 million boilers replaced every year were mCHP, 650,000 units could be installed per year at an additional cost of £325 million a year, or £6.5 billion for 13 million units over 20 years. Assuming a capacity of 1kW per unit, this would result in 13GW of capacity. In other words the same capacity would cost half as much, and this is without factoring in any cost reductions associated with mass production.

  The findings of a new study[33] confirm that mCHP products could realistically displace over 30% of annual domestic boiler replacements by 2015. This would provide annual carbon savings of 0.4 MtC by 2015 rising to 1.1 MtC by 2020. At this level of market penetration mCHP operating in UK homes would have a generation capacity of 5.6 GW, the equivalent of about five Sizewell B nuclear power stations.

  Micro-wind—Once mass production is reached, micro-wind's capital costs would be similar to the £800—£1,000 per kW from nuclear, but it is important to remember that a substantial amount of grid-based investment would be avoided, as well as marginal costs associated with transmission and distribution losses.

  A recent DTI-commissioned report (by consultants Mott MacDonald) [34]estimated that 17GW of microgeneration capacity would result in £1.2 billion per annum of avoided costs elsewhere on the network. Scaling this to the 11GW of nuclear under review would suggest annual savings of £800 million per year if microgeneration were deployed instead of nuclear.

  With an infrastructure that becomes geared to local generation through domestic microgeneration, it becomes feasible to introduce mandatory microgeneration into the Building Regulations. At present, it is entirely feasible to require new developments above a certain size to generate a minimum percentage of their energy requirements from microgeneration or other renewable sources. This reinforces the trends introduced by Merton, Woking and other local authorities towards sustainable energy systems.

5.3  Cultural effects—power to the people

  There is a further, less tangible dimension to microgeneration as an alternative to nuclear. This is the cultural change likely to result from the widespread uptake of microgeneration.

  Microgeneration can act as a catalyst for cultural change in the way consumers view their use of energy. A consumer who installs, for example, a micro-wind turbine experiences a daily reminder that they are "doing their bit", and sends a clear and visible signal to neighbours. The microCHP units whose prominent display panel in a kitchen or hallway consistently informs the user that they are generating their own power (and how much) will create interest amongst guests and within a family. Moreover, consumers who take up microgeneration are subsequently likely to alter their behaviour in other ways—and begin to realise just how much of a difference the other energy saving measures make. They become more likely to insulate their home properly, turn off unwanted lights, perhaps even cut down on car journeys, and so on.

  Although the Review may prefer hard-and-fast cost comparisons, we believe that it should take these secondary effects into qualitative consideration. They might be difficult to quantify, but a cultural change of this nature is likely to prove critical in transforming the public's attitude to climate change. This is certainly not the case for nuclear power.


  Government policies to reduce energy use are working. A simple, market-based framework must be applied on a scale that is commensurate with supply-side solutions currently deployed. In this way any nuisance associated with small scale approaches can be overcome.

  The economics of saving energy consistently shine when compared with generation. Energy saving and microgeneration are quicker to deploy than major infrastructure projects at a fraction of the cost, and at half the cost per kWh. Resources would be better spent reducing dependence on energy, reducing fuel bills and creating warmer homes and businesses.

  An upstream cap and trade scheme, replacing the EEC in 2011 will provide such a framework. It will deliver energy efficiency and microgeneration on such a scale that concerns over lack of consumer awareness, lack of financial incentives, and confidence in installers and rebound effects will be overwhelmed by a robust, competitive energy services market.

  Government must make the wholesale commitment required to shift from modest energy efficiency schemes that are successful on a modest scale to schemes that are hugely successful on a huge scale.

23 March 2006

2   DTI (2003) Energy White Paper: Our energy future-creating a low carbon economy. TSO, London, p 32. Back

3   House of Commons Select Committee on Energy (1982) 5th Report, Energy Conservation in Buildings. TSO, London, p xxxvii, para 66. Back

4   Royal Commission on Environmental Pollution (2000) 22nd Report. TSO, London, p 86, para 6.9. Back

5   National Audit Office (31 July 1998). Back

6   European Commission (2003) Proposal for a Directive on the promotion of End-use efficiency and Energy Services (COM (2003) 739). Brussels. Back

7   €1 = £0.689. Back

8   Cabinet Office Performance and Innovation Unit (2001) Working Paper on Energy Systems in 2050. TSO, London. Back

9   Lovins, A (September 2005) Nuclear Power: economics and climate-protection potential. Rocky Mountain Institute, Colorado. Back

10   1USD = GBP0.569. Back

11   Sustainable Development Commission (2006) Position Paper: The role of nuclear power in a low carbon economy. SDC, London. Back

12   Moral hazard is the presence of incentives for individuals to act in ways that incur costs that they do not have to bear or a financial system which offers "rescue packages" that may encourage borrowers and lenders to undertake low-quality or high-risk investments, thus increasing the likelihood of a crisis. Back

13   Mitchell, C (2006) New Nuclear Power-implications for the transition to a sustainable energy economy; University of Warwick Business School, quoted at ESRC Sustainable Technologies Research Workshop, London 14 March 2006. Back

14   DTI (2006) Our Energy Challenge: Securing clean, affordable energy for the long term. TSO, London, p 39. Back

15   Ibid p 29. Back

16   Ibid p 54. Back

17   Defra & HMT (2005) Energy Efficiency Innovation Review. TSO, London. Back

18   DTI (2006) op cit, p 25. Back

19   Defra & HMT (2005) op cit, p 9. Back

20   A comment frequently made by Energy Minister, Malcolm Wicks. Back

21   Ekins, P and Dresner, S (2004) Green taxes and charges: Reducing their impact on low-income households. Policy Studies Institute. Back

22   Pout et al (2002) Carbon Dioxide from Non-Domestic Buildings: 2000 and beyond. BRE, Watford. Back

23   Defra (2004a) Climate Change Agreements-results from the first target period assessment V1.2. Back

24   DTI (2003) op cit, p 40. Back

25   Defra (2004b) Energy Efficiency: The Government's Plan for Action. TSO, London, p 11. Back

26   Defra (2004a) op cit. Back

27   Pett et al (2004) Asset Value Implications of Low Energy Offices-Phase 2 Report. Association for the Conservation of Energy, London. Back

28   Defra & HMT (2005) op cit, p 9. Back

29   BRE (2004) Assessment of energy efficiency impact of Building Regulations compliance. Energy Efficiency Partnership for Homes, London. Back

30   "Final response to Code for Sustainable Homes consultation" news item on ACE website March 2006 Back

31   Boardman et al (2005) Research Report 31: 40% House. University of Oxford Environmental Change Institute, Oxford, p 11. Back

32   Green Alliance (June 2005) Small or Atomic? Comparing the finances of nuclear and micro-generated energy. Green Alliance, London. Back

33   SBGI (2006) MicroCHP-Updated market projections. SBGI, Leamington Spa. Back

34   DTI (2004) System Integration of Additional Microgeneration. Report to DTI report by Mott MacDonald, Back

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