Government
Response
Effect
of structural reorganisation on service users
Recommendation 1: It is important that the Government
monitors the outcomes of reform of the motoring agencies to ensure
the expected benefits are realised. (Paragraph 11)
Recommendation 2: We recommend that the Government
make clear its long term agenda for change by setting out clearly
its overall strategy for provision of motoring services. This
should cover all its motoring agencies, demonstrate how the strategy
will make services more unified and deliver efficiencies and cost
savings, and set out a timeline for the further changes needed
to bring about a more unified approach. It should also justify
the different approaches it is promoting for the three agencies
and explain the impact the Department's work on shared services
will have on the agencies. The Department should consider whether
it needs three separate agencies to achieve the streamlined, largely
electronic services it provides. We would like the Government
to expand on its plans for private sector involvement in the provision
of motoring services and how it sees the long term future for
its agencies as monopoly public service providers. The Government
should also make clear the extent to which efficiency savings
will benefit both the users of services through reduced costs
and fees, and the general taxpayer in the form of savings to the
Exchequer. (Paragraph 11)
4. As these two recommendations are linked, we are
responding to them together.
5. The Department thanks the Committee for its continued
interest in the important work of the motoring services agencies,
and will keep it informed of our plans and future strategies.
We have, however, made considerable progress over the last few
years. The Motoring Services Strategy response, published in 2013,
set out our intention to merge the Driving Standards Agency and
the Vehicle and Operator Services Agency into one agency, the
DVSA, which was formally launched in April 2014. We also stated
our intention to seek a Joint Venture partner for the VCA.
6. DVLA will have delivered a sustainable reduction
of £100m in its operating expenditure (including the impact
of inflation) by March 2015. The combined impact of the sustained
cost reductions in the period April 2010 to March 2015 is a saving
of around £250m and DVLA has also committed to an operating
cost reduction by March 2017 of 30%, net of relevant non-statutory
fee income, against an April 2014 baseline.
7. As a result of these efficiencies, drivers are
set to save £150 million over the next 10 years from reduced
fees following the DVLA's review into driver licensing. The introduction
of digital services has also allowed DVLA to reduce its fees for
driving licences, as it reduces overall costs by helping DVLA
to be more efficient.
8. Following a public consultation, from 1 October
fees for HGV and PSV tests fell for more than 80% of customers.
Fees for tests conducted at Authorised Testing Facilities (ATFs)
were reduced by an average of around 3.5%. Fees for tests conducted
at DVSA sites increased by an average of around 18.5%, meaning
that customers who do not use DVSA facilities no longer contribute
to their running costs.
9. In addition, the fee for car and motorcycle theory
tests fell by £6 in October 2014, reducing the cost of a
test from £31 to £25, with a further reduction of £2
due in October 2015. Theory test fees for other categories of
vehicle will also be reduced.
10. The Government agrees that it should monitor
the outcomes of its reforms, and set out the next stages of reform
for these agencies, but does not agree that further rationalisation
of the number of agencies will provide further efficiencies or
better services at this time. While DVLA will continue to provide
better and largely electronic services, that is not the case for
DVSA which will continue to be responsible for the physical testing
of vehicles and the practical and theoretical assessment of drivers'
competence. There are no plans at present for the further involvement
of the private sector in the delivery of those services but the
Government will consider whether there are opportunities for such
involvement.
11. DVSA and DVLA will continue to work together
to maximise the opportunities for further efficiencies.
Recommendation 3: The DVSA should provide us with
a reassurance that the wealth of experience built up by its vehicle
inspectors, examiners and other staff is not being lost in the
course of the merger and the changes it is making to Authorised
Testing Facilities (ATF). Similarly, the DVLA should provide us
with a reassurance that it is managing the risks around the loss
of knowledge and experience as it closes local branches. (Paragraph
12)
12. DVSA is confident that the merger of DSA and
VOSA has posed no risk to the business as usual activities of
its operations. It was a stated objective of the merger that frontline
services and customer service would not be adversely affected
by the merger and DVSA is confident that this is still the case.
VOSA had begun to implement the ATF strategy[2]
before the merger was announced; the ATF strategy offers an improved
service to customers by offering vehicle testing at the customer
site. DVSA has also reduced fees for tests conducted at ATFs by
3.5%, further improving its service to customers. DVSA plans to
continue to use experienced DVSA staff for testing and enforcement
activity.
13. DVLA's network of 39 Local Offices closed to
the public at the end of December 2013. DVLA ensured that staff
at the headquarters in Swansea were fully trained to deliver the
range of services previously carried out by Local Offices. It
also ensured that skilled and knowledgeable staff were available
to support commercial and trade customers. Application forms
were simplified and specific postcodes set up to ensure the efficient
administration of forms.
14. Where possible, previously complex transactions
were simplified, processes redesigned and data sharing between
different government departments and organisations, including
DVLA and DVSA, improved. Some services are also being developed
with the motor trade e.g. personalised registrations and electronic
notification of acquisition and disposal of a vehicle. These
enhancements recognise the desire by the motor trade to provide
a better service to its customers, and have also reduced the need
for DVLA to provide face-to-face services to customers.
Recommendation 4: We are concerned about the six-month
delay in issuing the OJEU notice for the VCA's private sector
partner and seek assurances from the Government that a partner
will be announced on schedule in January 2015. If there are any
further delays to plans to recruit a private sector partner for
the VCA, we would expect the Government to write to us. (Paragraph
13)
15. In a Written Statement to the House on 15 August
2013, the then Parliamentary Under Secretary of State for Transport,
Stephen Hammond MP, announced that the Department of Transport
would undertake market engagement and a procurement competition
to find a commercial partner to form a joint venture to grow the
work of the VCA.
16. The Parliamentary Under-Secretary of State for
Transport, Claire Perry MP, issued a Written Ministerial Statement
on 8 December 2014[3] to
inform the House that the competition was not successful in identifying
a suitable joint venture that would achieve the objectives of
both partners. The VCA will continue to provide vehicle testing
and certification services, as it does at present. The Department
will consult with a wide range of stakeholders before considering
any alternative proposals.
Support for Business
Recommendation 5: The DVLA and DVSA respond effectively
to the needs of individuals, who usually undertake only two or
three transactions each year but account for the bulk of the agencies'
business. However, on the basis of the evidence we received they
do not adequately meet the needs of businesses, some of whom undertake
hundreds of vehicle or driver transactions in each year. The agencies
need to develop a better understanding of the needs of their business
users, particularly small fleet owners and operators who play
an important part in economic prosperity. We recommend that DVLA
and DVSA develop specific strategies for responding to the needs
of business customers. In setting out a longer-term strategy for
the future of its motoring agencies, the Government should consider
the needs of business users as well as those of individual motorists.
(Paragraph 16)
17. As it considers its longer-term strategy for
the motoring agencies, the Government will further consider the
needs of business users as well as those of individual motorists,
and support the work DVLA and DVSA are already undertaking to
improve their support for business - including sharing data between
the agencies where possible.
18. DVLA works closely with business representatives
through its Industry Liaison Group meetings and is taking significant
steps to ensure that services are developed specifically for business
users. One example is the development of the Insurance Industry
Access to Driver Data service which, when finalised, will enable
insurers to request accurate driving entitlement and motoring
conviction data from DVLA. In addition, DVLA has introduced a
dedicated Corporate Service Manager to work with industry stakeholders.
19. DVLA has delivered, or is about to deliver, a
number of Red Tape Challenge initiatives, many of which are focussed
on reducing costs and burden on business. These include abolishing
the paper tax disc from 1 October 2014; abolishing the insurance
check at vehicle licensing; introducing a facility for vehicle
keepers to inform DVLA electronically of changes when they have
bought or sold a vehicle; and sending vehicle registration certificates
to fleet companies only when they need one, significantly reducing
their burden as they will not have to retain libraries of registration
certificates. These initiatives will deliver benefits to
business of over £15 million each year. During November 2014
the DVLA won three digital awards for services provided to business
customers. The DVLA's View Driving Licence project won both the
Next Gen Digital Challenge and the Civil Service Digital Award.
DVLA was also voted Fleet Service Company of the Year in the
2014 Association of Car and Fleet Operators (ACFO) Awards. DVLA
gained the most votes among ACFO members to win this award, which
recognises the Agency's engagement with fleet operators over the
ongoing development of a range of online solutions for the corporate
sector.
20. DVSA has made significant investments into improving
online practical test booking services for business customers,
and is also working with users, traffic commissioners and other
stakeholders to develop a new, more efficient licensing and compliance
system.
21. VCA operates almost entirely on a business to
business basis and in a commercial environment, competing with
other public and private sector companies across the world. In
general, companies have a choice whether to use VCA services and
this means that as an organisation, there is a significant focus
on meeting the needs of business, without compromising on standards
- customer satisfaction was recorded at 95% in 2013/14.
22. In respect of future digital and electronic services,
all transactions must now comply with the Government's digital
standard. This standard requires extensive user testing during
development and before going live and requires that each service
has a service manager to effect ongoing improvements in response
to user feedback.
Driver Training
Recommendation 6: If businesses and drivers must
commit time and resource to mandatory training then that training
must be worthwhile and effective. At the present time this is
not the case. (Paragraph 21)
Recommendation 7: Under the current regulations
the Government could not add modules on vulnerable road users
to the Driver Certificate of Professional Competence (CPC) or
compel drivers to select them. If the Government unilaterally
amended regulations to make such modules compulsory drivers from
other countries using roads in the UK would not have equivalent
training. We recommend that the Government lobby the European
Commission to introduce an amending Directive to require the inclusion
of a compulsory new training module in the Driver CPC focused
on vulnerable road users. (Paragraph 21)
23. As these two recommendations are linked, we are
responding to them together.
24. The Department is clear that mandatory training
must be worthwhile and effective, and has worked with the HGV
industry and stakeholders to ensure mandatory training is fit
for purpose. It is for the employer and employee to identify the
course that best meets the needs of the company or the individual
driver. Cost should not be the sole factor in choosing the training
to be undertaken, and consideration should be given to conducting
training annually throughout the five year entitlement period.
25. Driver CPC has been in operation for six years,
and the first five-year cycle of periodic training for professional
lorry drivers has come to an end (the equivalent period for bus
drivers finished in September 2013). Many in the industry
have recognised it can deliver benefits in terms of improved skills
and a sense of professionalism for drivers. We acknowledge
the suggestions that some drivers are merely seeking to satisfy
the requirement to undertake 35 hours of periodic training but
believe that the vast majority of drivers use Driver CPC to improve
their skills and knowledge.
26. DVSA is working with the industries and the Sector
Skills Councils to raise the quality of training that is available. DVSA
approves all courses that are offered for Driver CPC periodic
training, assessing each course application against the syllabus
prescribed in Directive 2003/59/EC. Course approvals have
to be renewed each year. DVSA also undertakes inspections
of courses and audits of training providers, to ensure that they
are delivering quality training.
27. When introducing Driver CPC, the UK negotiated
flexibility in the content and timing of training to allow individual
drivers to choose courses that meet their individual training
needs. We reiterated our desire to maintain that position
in our response to the Commission's review of Driver CPC in autumn
2013, arguing against mandating specific training content on the
basis that it is better to allow freedom for drivers to select
training that meets their individual needs.
28. DVSA considers that the safety of vulnerable
road users is an important issue that should be covered in periodic
training. So it is encouraging training course providers to include
content on the safety of vulnerable road users in each periodic
training course in the future. Guidance will be issued shortly
to training bodies by the Joint Approvals Unit for Periodic Training
that all seven hour blocks of periodic training should contain
information relating to vulnerable road users; this will be considered
as part of the course approvals process from April 2015.
29. This change means all UK drivers covered by periodic
Driver CPC requirements should receive training related to vulnerable
road users during the five-year training period just started (except
for some drivers starting their second training before April 2015).
This route achieves significant change far more quickly than an
amendment of the European directive, whilst retaining more choice
for the UK.
30. The Commission's review of Driver CPC is ongoing.
DVSA and the Department will ensure that the UK's interests are
represented in those discussions to protect the interests of British
business and the UK's enviable road safety record.
Digital services and extending
digital services
Recommendation 8: Digital services must cater
for all users not just individual motorists and the agencies'
assisted digital strategies must help and support those who cannot
access services online. The Department needs to ensure that its
motoring agencies have viable plans for assisted access, which
recognise the distinct needs of individuals and businesses. The
motoring agencies must ensure a good standard of accessibility
to their services is provided to users who are unable to benefit
from investment in digital services. They should also monitor
outcomes and customer feedback to ensure that their assisted digital
strategies are working. (Paragraph 27)
Recommendation 9: Digital services are clearly
popular and they have the potential to reduce costs for the taxpayer,
motorists and businesses. We recognise the need for the multi-channel
approach that the agencies are adopting; and lessons learned from
the progress made so far should inform the planning and roll-out
of new digital services. Concerns about digital exclusion and
access to services for people who cannot use online services are
valid. The move to digital provision and recent organisational
changes (for example, the closure of DVLA local branches) have
the potential to make access to some services much more difficult
and costly for certain groups of people and some businesses. The
Department and the agencies need to show how they are addressing
these concerns and what steps they are taking to ensure that there
is alternative provision for those unable or unwilling to use
digital services, especially in the context of changes to local
networks and branches. The Department should also consider the
extent to which reliance on the Post Office and other providers
is an adequate means of dealing with digital exclusion. In addition,
digital services must work seamlessly with those that will continue
to require some degree of physical presence. (Paragraph 30)
31. As these two recommendations are linked, we are
responding to them together.
32. The Department is committed to implementing its
actions in response to the Government's Digital Strategy[4].
Since 2012, the Department has worked with the agencies to increase
take up of their digital services through GOV.UK - with considerable
success. DVLA is implementing three of the Government's 25 digital
exemplars.[5]
33. Each agency is committed to providing users with
multi-channel services to meet their needs. For example, DVLA
already offers vehicle taxation online but has also retained the
option for customers to use the Post Office. The introduction
of direct debit and the abolition of the tax disc has increased
online take-up since October 2014. DVLA also offer first registration
of a vehicle via both an online service and a paper channel. The
DVLA Contact Centre provides a telephone assisted digital service
for users who require help with online services such as Electronic
Vehicle Licensing, Drivers Licensing Online and View your Driver
Record. The Agency also provides a telephone transaction service
for vehicle relicensing, duplicate registration certificates and
driving licences. DVLA's ongoing intention is to provide the best
customer service, regardless of the channel through which users
choose to interact with the Agency.
34. DVSA has also been highly successful at moving
transactional services online and encouraging take-up. In September
2014, 97% of practical driving tests were booked online. DVSA
received just 120 paper applications for driving tests in the
first six months of 2014/15.
35. Although online take-up of transactional services
is high, DVSA also makes services available through non-digital
means. It is possible to book, change or cancel a theory test
by phone and to book, change or cancel a practical test by paper
application or phone. Vocational and motorcycle trainers can also
reserve test slots by phone or fax and notify the Agency of the
names of candidates who will use those slots in the same ways.
There is a customer support team available to the public between
8am and 12pm Monday to Friday and for business customers between
8am and 6pm Monday to Friday.
36. Vehicle type approval does not lend itself to
a wholly digital approach because of the degree of product testing
and face-to-face interaction required. However, where digital
tools can be employed to support the process, VCA has introduced
them. For example, VCA uses an online tool to allow customers
to quickly and securely send and receive documentation, which
leads to efficiencies in the overall approval process.
37. The Department and its motoring agencies recognise
the issues around access and the capability of internet-based
services. We continue to work with the Cabinet Office on the development
of the Assisted Digital (AD) approach to make sure AD support
is in place before any new service goes live and remain committed
to ensuring that our services are available to people who remain
either unable or unwilling to use digital services. The Post Office
for example has more than 4,000 outlets. They are required to
offer good geographical cover and meet strict service level standards.
Motor dealers will soon be able to carry out a number of services
on behalf of their customers. The paper route remains open for
all applications.
38. However, we have a duty to reduce costs to the
taxpayer, and encourage people to use our digital services wherever
possible, designing them to be easy to use and in line with Government
Digital Service's (GDS) Digital-by-Default Service Standard which
is published on GOV.UK. Before going live every Digital by Default
Service developed by the Department is also required to make sure
appropriate Assisted Digital (AD) support is in place to extend
the reach of digital services. Impact Assessments are carried
out when introducing new proposals and the Department is committed
to ensuring alternative channels do not degrade inclusivity and
disability access.
Copycat websites
Recommendation 10: It is illegal to deliberately
mislead the public or obtain money by fraud; the agencies providing
services on behalf of the Government should do everything practicable
to prevent users of their services from being misled or becoming
the victims of fraud. Transport for London's agreement with the
DVLA to alert drivers using unofficial websites is an interesting
model that the Department should evaluate to see how well the
approach works and whether it can be extended to other services.
It will be important to understand how much any alternative approach
costs to administer, what effect it may have on fees for users
of services and whether it results in fewer motorists using unofficial
sites. In such an evaluation it will be important for the Department
to consider the effect of the scheme on unofficial operators and
any unintended consequences for legitimate providers of value-added
services. We also ask the GDS to provide specific details of its
progress so far in identifying and alerting search engines to
misleading websites offering services to motorists, and to report
on what enforcement action has been taken against such sites.
(Paragraph 33)
39. This is an issue of relevance and concern to
DVLA, DVSA and the Department. Copycat websites are not affiliated
with or authorized by the motoring agencies, and some use the
DVLA trademark illegally in their domain name.
40. Typically these sites suggest they provide services,
already available directly from the motoring agencies, in a way
which adds value, or they underplay the services that customers
can get for free, or at a lower cost, from the agencies on the
Gov.UK website. They can often be found in the sponsored links
or paid-for results section of online search engines.
41. The Department is involved in addressing this
issue and is in contact with the Government Digital Service (GDS),
other public organizations with similar concerns, enforcement
agencies and search engine providers. DVSA and DVLA have both
recently issued press notices warning customers not to use unofficial
sites. In addition, we will review the TfL model referred to in
the Committee's Report.
Sharing vehicle keeper data with
parking enforcement companies
Recommendation 11: Protecting personal data is
an issue that people feel strongly about and the DVLA needs do
more to explain to the public the legal basis for its sharing
of personal data and the steps that are being taken to deal with
private parking companies and local authorities caught misusing
parking data; the Government needs to ensure there is more transparency
and better accountability on this issue. We recommend that the
DVLA and Department for Transport consider whether each vehicle
keeper should be told when their data is released and what more
can be done to help target persistent repeat offenders. The Government
needs to be mindful of the costs of any changes and we would expect
it to consult widely on any proposals it brings forward, including
how the costs of any such scheme could be met. (Paragraph 42)
42. DVLA takes its responsibilities to protect people's
personal data seriously. Private parking operators who receive
DVLA data are required to be members of an Accredited Trade Association
(ATA) and comply with its code of practice. Action is taken when
companies are found not to be meeting the standards required including,
where necessary, suspension of the company's facility to request
vehicle keeper data. In 2013, DVLA ceased supplying data to private
parking companies on 22 occasions.
43. A range of communication channels are used to
inform motorists that private car park operators can request vehicle
keeper information to pursue alleged parking contraventions. This
means that motorists should be aware that their contact details
could be requested from the DVLA. There would be significant
costs for DVLA to write to every vehicle keeper when their data
is released - postage alone would be around £400k per annum.
Based on similar system changes the costs of introducing the
change is estimated to run into millions of pounds, making it
impracticable at this time.
Recommendation 12: The DVLA should not subsidise
private parking companies by providing data at a loss, if anything
it should err on the side of making a small surplus. As it reviews
its fees and income, the DVLA should consider whether efficiencies
can be made to reduce the cost of processing these requests. If
not, the DVLA should adjust the fee for the provision of personal
data to ensure costs are covered. The DVLA should make clear on
its website how the costs are calculated. It should also consider
whether the enhanced provision of information to drivers, as recommended
above, could be financed through the fee (Paragraph 43)
44. DVLA's fees are set at levels that cover costs.
Given the fluctuation in transaction and enquiry volumes, fees
are kept under annual review. The Agency sets its fees in line
with Managing Public Money guidelines.
45. DVLA implemented a first phase of fee changes
on 31 October covering Drivers fees.
Policy changes that increase reliance
on the quality, accuracy and effective sharing of data
Recommendation 13: Interoperability of systems
and the ability to share data with other agencies needs to be
given a high priority by all the motoring agencies. The motoring
agencies should think carefully about what data their users need,
how this can be shared effectively and what safeguards need to
be in place. They should assess policy changes to understand what
impact they may have on data sharing. The need to share and exchange
data needs to be balanced with the protection of personal data.
(Paragraph 48)
46. In terms of interoperability, the IT systems
and databases used by the respective Agencies have been developed
to meet specific needs and to enable performance of statutory
functions. There are already a number of important areas where
DVLA and DVSA share data through a mixture of electronic transfer
methods. These include confirmation from DVSA that a vehicle
has a current MOT prior to it being taxed using DVLA's electronic
vehicle licensing system and notification from DVSA that a learner
driver has passed their driving test. Memoranda of Understanding
are in place between DVLA, DVSA and other agencies within the
Department and beyond[6].
There is little need to share data routinely between VCA and other
agencies and this need does not extend to personal data. However,
the need to appropriately protect personal information is considered
as part of any request to share data and Privacy Impact Assessments
are carried out in accordance with the Information Commissioner's
Code of Practice.
47. In terms of wider users of DVLA data, the enormous
benefit of sharing the vast amount of data that the Agency holds
is recognised - as well as the importance of protecting personal
data. DVLA operates a comprehensive process for managing requests
for its data.
48. Nonetheless, all agencies are committed to being
as transparent about their work as they can. DVSA publishes information
proactively about driver and vehicle testing. Both DVLA and DVSA
are considering what additional information could be made available
to the public.
49. Access to data can also be constrained by current
IT systems. DVSA is looking at how it might improve its IT to
enable industry to access core datasets.
Working with enforcement agencies
Recommendation 14: Offenders need to be caught
and dangerous vehicles must be removed from the road network.
An intelligence-led approach to enforcement that targets the most
serious non-compliance and the repeat offenders depends on access
to and the effective sharing of data. We view this as essential
to reduce the likelihood of traffic accidents and save lives.
The Department should drive forward a culture change in the approach
to sharing data between the motoring agencies and their enforcement
partners and should identify the steps that need to be taken to
ensure data is accurate and can be shared in a timely way to support
the work of the agencies and enforcement bodies. (Paragraph 53)
50. The motoring agencies already have a proven record
in sharing data. DVSA share both MoT and goods vehicle test data
with DVLA so that there is assurance that the vehicle is roadworthy
before it is licensed. Furthermore, there is extensive sharing
of data between DVSA and the Traffic Commissioners to ensure there
is effective regulation and enforcement in respect of licensed
goods and passenger vehicle operators.
51. DVLA is working with the insurance industry to
enable it to use driver data to confirm driving licence entitlement
and current endorsements and motoring convictions. DVLA is also
working with the police and HMRC to develop an enforcement process
to deal with foreign registered vehicles in the UK remaining in
the UK illegally. In addition, DVLA is exploring what opportunities
exist to share intelligence with other enforcement agencies.
Any opportunities identified by DVLA and other enforcement agencies
will of course need to be underpinned by appropriate legal powers.
52. DVSA uses networked ANPR (automatic number plate
recognition) data in its enforcement activity with the aim of
using the data to coordinate road checks, better target non-compliant
vehicles and use staff time more effectively. It is setting up
a Strategic Traffic Management Office to deliver this work and
maximise the use of the ANPR data. This will be a central strategic
resource management and tactical deployment function that will
coordinate both strategic planning of resources and road checks
and provide the tactical coordination of targets as they pass
through the network. The team will also be able to monitor enforcement
productivity in real time and redirect local teams as needed.
DVSA is working with other agencies and enforcement partners to
share ANPR data where appropriate and possible.
53. The systems for the HGV levy, which was introduced
in April, were designed from the ground up with data sharing in
mind. There is the capability to take information from HMRC on
vehicles entering and exiting the country, and merge it with data
from the levy payment system. This provides information on which
vehicles are in the country, but have not paid the levy. This
data is then shared with DVSA. The project to link this data with
DVSA ANPR cameras will go live shortly, giving DVSA improved capability
to target enforcement of non-compliant vehicles.
2 Where DVSA examiners conduct annual vehicle tests
for goods and passenger carrying at customer sites, rather than
at goods vehicle testing stations
Back
3
HC Deb, 8 December 2014, Col 25WS Back
4
https://www.gov.uk/government/publications/department-for-transport-digital-strategy Back
5
These are View Driving Licence, Personalised Registrations and
Vehicle Management. Back
6
For example the Memorandum of Understanding Between The Driver
and Vehicle Licensing Agency And (police force, DVSA etc) For
The Provision Of The Driver Validation Service and the Memorandum
of Understanding Between The Driver & Vehicle Standards Agency
and The Driver and Vehicle Licensing Agency For the Supply and
Receipt of the ADLI Interface. Back
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