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Autumn 1992
   
Garbage Gridlock
Steven M. Polan
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EDITOR’S NOTE:
New Yorkers produce 2,500 truckloads of garbage each day, almost all of which goes either to the Fresh Kills landfill or to out-of-state dumps. Both these options may soon be foreclosed. Recycling is a partial solution, but many of its advocates exaggerate its potential. To avert disaster, the city must build waste-to-energy plants, secure new landfill space, and adopt a realistic approach to recycling.

New York City has a garbage problem that may soon reach disastrous proportions. The city is fast running out of places to put its waste. Sixty years ago, New York had 89 active landfills and 22 operating incinerators; as recently as 15 years ago, the city still operated six landfills and six incinerators. With the recent closing of the Edgemere landfill in Queens, New York City’s resources for solid waste disposal have been reduced to three aging incinerators, a nascent recycling program, and, most critically, a single enormous landfill site of two thousand acres on the western shore of Staten Island called Fresh Kills.

Each year New York’s residents, institutions, and businesses produce some eight million tons of municipal solid waste (excluding sewage sludge, dredge spoils, and construction and demolition debris). This amounts to about 26,000 tons per day, or enough to fill more than 2,500 garbage trucks. It is by far the largest such waste stream in this country, probably in the world. To manage the residential and institutional components of this stream (and perform related functions, such as street cleaning and enforcement), the New York City Department of Sanitation employs some 11,500 men and women and spends close to $600 million in operating funds and $200 million in capital funds annually. Virtually all of its funds are derived from general tax revenues; New Yorkers are among the minority of Americans who get their domestic solid waste removed without charge.

About half the waste stream is produced by New York City businesses and collected by private carters, whose activities and facilities are regulated by the Departments of Consumer Affairs and Sanitation. Private hauling companies charge their commercial customers on the basis of volume; their collection fees are approved by the city. The haulers pay “tipping” fees at Fresh Kills or at out-of-city disposal sites and pass these costs on to their customers. Thus, New York City firms that generate waste have an incentive to control costs by limiting their waste production, while the haulers of their waste search for the least expensive disposal option.

Unlike commercial firms, residents in New York City have virtually no incentive to reduce their waste production. Meanwhile, in order to balance its budget, the city government has historically sought the cheapest lawful disposal option. And because the city’s budget does not account for depletion costs, that option will continue to be Fresh Kills until it is filled.

Fresh Kills, opened in 1948, was originally intended to serve only as a stopgap until the city could construct a sufficient number of new incinerators to eliminate the need for raw-garbage landfills. For a brief period the city had some success; the last of 13 new incinerators came on line in 1962. Since then, despite the efforts of successive administrations, no disposal facility of any significance has been sited within the city’s boundaries. At the same time, New York has been closing its landfills. Many were closed before they were filled, because they could not meet strict new environmental standards. Meanwhile, 10 of the 13 incinerators have been shut down because it was too expensive to retrofit them to meet increasingly rigorous air-pollution limits.

Today, Fresh Kills is estimated to have room for an additional 100 million cubic yards of waste, roughly eighty or ninety million tons. If dumping continues at current rates, the landfill will be full in about twenty years. It is possible, however, that Fresh Kills’ capacity could be exhausted much sooner, or that the landfill could become unavailable altogether on short notice. Thus far, the city has been unable to advance a plan to cope with these risks.

Engineering difficulties may well shorten the life of Fresh Kills. The city’s grading plan for one portion of the landfill involves building a mountain of garbage 437 feet tall, about the height of a forty-story building. This requires daily adherence to precise construction specifications, calibrated to assure that the slopes are steep enough to reach the projected final height, yet gentle enough to guarantee heavy vehicle access. Gradation must also meet regulatory requirements involving drainage and erosion control. As more and more waste pushes the landfill to its physical limits, and a budget-strapped city limits funding for grade monitoring, it becomes increasingly difficult to meet the optimal grading plan.

Even greater problems may be lurking beneath the hill of trash. No one knows whether the landfill’s foundation can support all the garbage at the intense rate of dumping the city plans. The dumping schedule must allow water to drain out of the soils below, and the city is now studying the underlying geologic structure to ensure that the rate of fill does not create the risk of landfill slide or collapse.

Another unknown is the amount of waste that will come to the landfill. Four years ago the City of New York doubled the tipping fee it charges private haulers at Fresh Kills. It did so because the landfill charges did not reflect the actual replacement cost, and the city could collect more revenues if its landfill were properly priced. The unintended consequence has been the best thing to happen in city waste policy in the last thirty years. The amount of garbage dumped at Fresh Kills each day has declined from 25,000 tons to 14,000 tons. To avoid the increased tipping fee, private haulers simply took their business elsewhere, principally to landfills in the Midwest. Each night hundreds of trucks and rail cars leave New York City transfer stations to haul garbage hundreds and sometimes thousands of miles away. As a result, New York is currently saving every bit as much landfill space as would have been saved had a plan, approved in 1985 by the Board of Estimate, for five new energy-producing incinerators proceeded on schedule.

Unfortunately, as waste-importing states like Indiana, Ohio, and Pennsylvania recognized that their own landfill capacity was being consumed by garbage from New York City, Long Island, and New Jersey, resistance to the interstate movement of trash intensified. The federal courts have consistently ruled that state bans on waste imports violate the Constitution, which gives Congress the power to regulate interstate commerce. But it is virtually certain that Congress will, sometime in the next few years, pass legislation permitting states to erect barriers to out-of-state waste. That could direct much of New York’s waste stream back to Fresh Kills, potentially cutting its useful life in half.

A final problem threatens the future of Fresh Kills: It does not and cannot comply with current state regulations, because it is impossible to place a liner under forty years’ accumulation of garbage. Under the most recent consent order with Albany, operations have been permitted to continue only until 1996, or until 2000 if certain conditions are met. Two sections of Fresh Kills will soon be closed, by agreement with the state, before they reach their physical capacity. And new restrictions could be imposed that will further limit the capacity of the site.

Since the mid-1970s, Sanitation Department planners have urged the construction of new resource-recovery plants in the city. These plants burn garbage to produce energy for sale to local electric utilities. Unlike the older generation of incinerators (which produce no useful energy), they are equipped with sophisticated and effective pollution-control features and burn garbage more efficiently, turning it into ash of only one-tenth the original volume. Beginning in 1977, when a task force of the Departments of Sanitation and Environmental Protection estimated the need for up to a dozen new plants through the 1980s, resource recovery was the primary focus of disposal capacity planning. In 1980, the State Legislature authorized the city to enter into long-term contracts to finance these facilities. In 1985, the Board of Estimate approved a plan to build one new facility in each borough, the first to be sited at the Brooklyn Navy Yard.

The latter decision followed a lengthy and highly charged debate about the environmental effects and health risks associated with resource recovery plants. Over time, a wealth of data, scientific studies, and health risk assessments demonstrated to the satisfaction of the members of the Board of Estimate that modern plants with properly operated and maintained pollution-control systems entail no significant risks. Leading environmental organizations, including the Natural Resources Defense Council and the Environmental Defense Fund, concurred and testified in support. Other environmental groups, as well as neighbors of the site in the Williamsburg area, opposed the project.

The administration’s victory in 1985 was short-lived. The application for the Navy Yard project still required the approval of the State Department of Environmental Conservation (DEC). Opponents of the project again mobilized. The adjudicatory process was repeatedly delayed by the introduction of new questions requiring new study and additional hearings. Plans for the other four new facilities were put on hold. Finally, in 1989, the DEC commissioner formally concluded that the proposed plant posed no unacceptable environmental risk. The commissioner promised to issue a permit for the project, if the city would commit to a meaningful recycling program and dispose of incinerator ash separately from raw garbage.

The recycling condition insisted upon by the DEC was the primary factor leading the Koch administration to agree to a proposal for recycling put forth by environmental organizations and the City Council. Legally mandated recycling was thought necessary because the administration’s commitment was highly suspect: Its 1985 plan to recycle 10 to 15 percent of New York’s waste had not advanced appreciably, and it had repeatedly rejected separate collections of recyclables as too expensive.

In 1989, in the face of election-year pressures as well as pressure from the state, Mayor Koch agreed to mandatory recycling legislation, known as Local Law 19. This law established requirements for the recycling of specified daily tonnages of waste in both the residential and commercial sectors. It also required the construction of processing centers to sort and prepare the material for market, authorized the Sanitation Department to ticket households and businesses that fail to recycle, and directed the city to undertake a host of studies and initiatives aimed at fostering markets for recyclables. Taken as a whole, the new law attempted to institute profound changes in the way New Yorkers manage their trash and to alter the underlying economic forces at work in the waste and recycling marketplaces.

Just as the department began to struggle with the new law, its long-stalled but still primary disposal strategy—resource recovery—was thrown into doubt by the election of David Dinkins. In his election campaign, the new Mayor had pledged to delay resource recovery pending further environmental review and an assessment of whether an aggressive recycling program could satisfy some or all of the disposal capacity of the five large waste-to-energy plants deemed necessary.

These critical evaluations were to be made in two arenas. First, the recycling program would be tested on the streets of New York; by the fall of 1990 separate collection of recyclables was already being provided in one-third of New York’s neighborhoods. Prompt expansion to the balance of the city was included in the city’s four-year financial plan. Second, the future potential of recycling, and of all other conceivable waste-management strategies, would be assessed through the development of a state-mandated Comprehensive Solid Waste Management Plan.

When I became commissioner of the Sanitation Department in 1990, one of my first tasks was to evaluate the status and potential of Local Law 19. It quickly became apparent that the legislation was based more on enthusiasm about recycling than on objective analysis of what was realistic. Tonnage requirements and percentage goals had been established without examining the composition of the waste stream, determining what materials might be favorably sold in the recyclables marketplace, calculating what levels of public participation could be achieved, or forecasting whether processing plants could be built quickly (or at all) in communities intensely opposed to any waste-related facilities.

Moreover, neither the City Council nor the administration took into account the restraints embedded in the city’s existing contract with the sanitation union. The city and the union had agreed, eight years earlier, to a reduction from three to two workers on each Sanitation Department truck in return for a daily productivity bonus for each of the two. The agreement, a successful productivity initiative of the Koch years, also restricted management’s ability to revise the daily basic collection workload.

While the workload modification might have made sense in the early 1980s, it posed an enormous obstacle to developing an economically rational recycling program. As material is diverted from regular collection routes to special recycling routes, the workload on the regular route declines. But the city is contractually barred from compensating for this. If, for example, the regular collection route previously entailed picking up ten tons and recycling diverts two tons of that load, the city cannot add two tons to the regular route by extending it. Instead, after finishing the “lighter” route, the collection crew is permitted to return to the garage to idly await the end of the day. Nor can the city simply substitute a once-a-week recycling pickup for one of the two or three regular weekly garbage collections without union agreement.

The sanitation workers’ union ultimately stands to benefit from a successful recycling program. Even without the inefficiencies fostered by the existing collective bargaining agreement (which are unique within the industry), separate collections and more dumping sites require more workers. Notwithstanding this potential bargaining chip, in 1989 the city began the recycling program without negotiating necessary contractual changes. In March 1992, the city granted the sanitation union a wage increase, accompanied only by an as-yet-unrealized labor-management process to evaluate new workload requirements. At the same time as the recycling collection work force grew from zero to 700, the city cut back on street cleaners, from 1,500 to 600.

The Sanitation Department’s 1990 analysis of the city’s program suggested that the cost estimates for recycling had been unrealistically low. Recycling currently costs nearly $300 per ton, four to five times what was projected at the time Local Law 19 was adopted, and much higher than the projected cost of either resource recovery or landfilling, even including the cost of replacing landfill capacity.

Part of the problem was that Local Law 19 misjudged the potential of recycling markets. The premise of the program was that if the city demonstrated its commitment to produce a supply of materials, demand would develop. Supply, however, is but one of the critical factors. Market demand is also affected by the relative cost and availability of virgin materials, relative cost of transportation and energy, existing capital investment and plant capacity in facilities that require virgin materials, and consumer demand for goods with recycled content. Consequently, while markets for some recyclables, such as aluminum, have been adequate, markets for most other materials have been unstable and usually poor. In 1991, for example, the city had to pay paper dealers $23 a ton to process and market newspaper, most of which was sent to the Far East.

The critical issue in evaluating recycling is how the costs of the entire process—separate collection, processing, and sales of the material—compare with the cost of burning or landfilling. When the question is asked this narrowly, recycling as mandated by Local Law 19 does not fare well. On the other hand, the current cost of $300 per ton can be reduced substantially as the program becomes better understood and participation increases. Processing costs can be lowered through the introduction of more-efficient separation equipment, and it is anticipated that markets for some materials, newspapers in particular, will increase significantly when the city contractually guarantees a long-term supply.

Even with all of this, it is highly unlikely that the cost of the recycling program can be reduced to the projected $160 per ton cost of resource recovery (including collection and ash disposal) or even the current $190 per ton cost of landfilling at Fresh Kills with depletion costs fully allocated. It is probable, however, that with a more rational approach to recycling, a portion of the waste stream could be recycled at an acceptable cost.

The experience of the commercial sector is instructive. When the city increased the tipping fee it charges private carters to use Fresh Kills, it focused attention on the potential of recycling to avoid disposal costs. Consequently, commercial recycling has begun to prosper in New York City. At private transfer stations across the city, significant portions of the waste stream are being separated (by hand or machine) before the residual is loaded on trucks destined for out-of-city landfills. Still other material, such as office paper and corrugated cardboard, is being collected separately. These activities are occurring because it is more economical to recycle certain materials in the commercial waste stream (which differs significantly in composition from the residential stream) than it is to landfill or burn. The lesson is that a market-driven recycling program can be a meaningful component of the city’s overall waste disposal strategy.

For many people, however, recycling has much more to do with lifestyle and personal notions of environmental consciousness than it does with waste disposal. In a culture that values convenience, where diapers are used only once and food servings are packaged individually, recycling makes people feel more virtuous about their own consumption and the waste it entails. Suggesting that the potential of recycling is limited by factors other than what is physically capable of being recycled in a laboratory environment puts the policymaker—and, more importantly, the elected official—in the uncomfortable position of seeming to condone a wasteful lifestyle and, by extension, the degradation of the planet.

For others, recycling advocacy is merely an effective tactic to oppose incineration, a cause which generates religious fervor among its adherents and a propensity to bend all facts in support of the mission. For this faction, admitting that the potential of recycling is limited would be to acknowledge that it is necessary to deal with part of the waste stream by other means. Landfilling is not practical as a long-term solution for New York City; thus, incineration is essential. (Ironically, since they make productive use of garbage, waste-to-energy plants should be regarded as a form of recycling.)

Given that there are limits on recycling, what percentage can we reach on an affordable basis? Many recycling advocates claim the answer is between two-thirds and 100 percent of the waste stream, but this is far too optimistic.

The Sanitation Department’s Comprehensive Solid Waste Management Plan (issued soon after my departure but reflecting my views on this subject) predicts that some market will exist for roughly half the material in the residential waste stream, with a somewhat higher percentage in the commercial waste stream. But determining what percentage of this theoretically recyclable waste can practically be recycled is quite another matter. The actual amount recycled, known as the diversion rate, is limited by both the participation rate (the percentage of the population that sets out recyclables in separate containers) and the capture rate (the percentage of each participant’s recyclable waste that is actually separated and is sufficiently uncontaminated to be suitable for reuse). Thus, if half the residential waste stream is recyclable, half the citizenry participates, and each participant separates half of his recyclable material, the diversion rate will be only 12.5 percent. Using optimistic but not outlandish assumptions about participation and capture rates, the city now estimates that a 25 to 28 percent diversion rate might be achievable in the residential sector and a somewhat higher percentage in the commercial sector.

Neighborhood diversion rates now range from less than 5 percent to almost 20 percent. One reason for this variation is that apartment dwellers, more than half of New Yorkers, have insufficient incentive to comply with recycling requirements, because it is nearly impossible for city enforcement agents to trace bags of trash back to individual households. Among densely populated neighborhoods with many apartment buildings, only the Upper West Side has a high diversion rate. Some cities with high diversion rates, most notably Seattle, provide an economic incentive to recycle. They charge for collection services, but pick up recyclables without charge.

The city’s hope to recycle more than a quarter of residential waste can, in my opinion, be attained only if the city devotes substantial resources to educational and advertising campaigns of a sort not yet seen. Even under the best of circumstances, recycling requires changes in living habits that will need a generation to take hold.

Another difficulty in attaining a high recycling rate is that New York is uniquely constrained in how and what it counts. Newark, New Jersey, for example, includes scrapped automobile tonnage in its recycling percentage. Local Law 19 prohibits the city from taking credit for material that was commonly recycled before the law’s enactment. Thus, the very substantial tonnage attributable to auto dismantling is excluded, precisely because it is a legitimate market-driven recycling activity. Bottles and cans that are redeemed for deposit likewise are not counted, even though they are usually recycled. New York City does, however, take some liberties in order to maximize its recycling rate. For example, more than 40 percent of reported recycling tonnage comes from recycling street asphalt and dirt from vacant lots—two forms of recycling initiated after the passage of Local Law 19. Both of these activities save landfill space, but they are hardly what the public has in mind when it thinks about recycling.

I would argue that the constant focus on the maximum attainable rate of recycling in New York misses the point, and that the political obsession with meeting legislated goals undermines actual opportunities for success. There are simply too many uncertainties to project with any degree of confidence what rate of recycling might be achieved in New York City now, much less ten years from now.

Perhaps the greatest recycling challenge in New York is the one that is least talked about. In order to accommodate the thousands of tons of recyclables that the city will collect if it reaches its recycling objectives, it will need to build five or more processing facilities. These plants, sometimes called material recovery facilities or MRFs, provide the means to separate recyclable material and ready it for market.

The public enthusiasm for recycling does not extend to the construction of these facilities in their neighborhoods. We have already seen evidence of this in the opposition to the siting of private transfer stations, which have proliferated in recent years as places to consolidate, recycle, and transfer commercial waste before it is exported. Concerns about truck traffic, noise, odor, and air pollution, all of which are understandably perceived to affect neighborhood quality of life and property values, will be no less intense because the required facilities are related to recycling.

Assuming the City of New York resolves each and every uncertainty in favor of recycling, it remains an absolute certainty that some combination of landfill and resource recovery will be required for a significant portion of the city’s waste stream. The long-term program in the Mayor’s proposed plan issued in March 1992, which includes optimistic recycling projections, calls for burning a minimum of one-third and potentially up to two-thirds of the waste stream. The approach that limits incineration to a one-third share assumes diversion rates that can best be described as heroic, as well as separate residential collection of compostable garbage, a costly proposal of dubious practicality for most city neighborhoods. Moreover, while odors can be adequately controlled in both waste-to-energy plants and MRFs, food-waste composting plants sited in the city would emit air pollutants of uncertain environmental acceptability.

Given the city’s own numbers, and even given a very optimistic assessment of recycling potential, the city should certainly move to construct waste-to-energy capacity to handle at least one-third of its waste stream. Still, the plan proposed waiting until 1996 before beginning to build the first of three or four facilities likely to be required. The delayed construction of new waste-to-energy facilities means that the city will continue to emphasize the most environmentally adverse form of waste disposal, dumping at Fresh Kills, needlessly consuming as much as twenty million cubic yards of the landfill’s capacity, one-fifth of its maximum remaining useful life. And this assumes that incinerators—with ever more rigorous permit requirements—can proceed without delay at the end of the decade.

The decision to delay might have been understandable had the city’s plan found new evidence that waste-to-energy plants create unacceptable environmental risks, or if new and better technology appeared to be on the horizon. But the public health analyses included in the city’s plan agree with what every serious study here and elsewhere had previously concluded: that properly operated state-of-the-art waste-to-energy plants are environmentally acceptable. In fact, since 1985, when the Board of Estimate first approved the resource-recovery program, evidence that waste-to-energy is environmentally acceptable has grown even more convincing.

The State Department of Environmental Conservation, no friend of resource recovery, concluded in its 1989 decision on the Navy Yard incinerator that “the facility is capable of operating without any undue risks to the public or the environment.” In 1990, the federal Environmental Protection Agency rated a variety of health-related environmental risks in the New York/New Jersey metropolitan area. The risks from motor vehicle emissions were ranked very high, landfilling was ranked medium, and incinerators were ranked low.

The city’s own Solid Waste Plan analysis found that a full-scale incinerator program would produce very little pollution. New emissions of dioxin and heavy metals, except for mercury, would amount to an addition of less than 0.1 percent of existing levels. For mercury, the contribution to existing levels was somewhat higher, but not to the point of risk, even under the study’s highly conservative assumptions. Moreover, the study did not take account of recent industry efforts and new state legislation intended to substantially reduce the mercury content of batteries, the source of 88 percent of the mercury in municipal solid waste. Neither did the study consider that each ton of trash burned replaces roughly one barrel of oil, thereby reducing the amount of pollution produced by nearby fossil fuel generating plants. Nonetheless, the study concluded that the public health risks of incineration were “negligible.”

The decision to delay was the logical result of several coalescing forces: the Mayor’s position in his 1989 campaign, the delayed expansion of recycling as a consequence of the city’s fiscal crisis, the emergence of the City Council as the ultimate arbiter of land-use policy, and the enhanced political strength of recycling advocates.

Significantly, the Mayor had lent legitimacy to the incineration-versus-recycling dichotomy in the 1989 mayoral campaign. While all of his opponents in both parties had supported resource recovery, including the Navy Yard project, he alone had called for delay to await the verdict on recycling. Then, faced with an immense budget shortfall and very few options for reducing expenditures, the Mayor reluctantly undermined the credibility of his administration’s commitment to recycling by proposing—as part of what came to be known as the “doomsday budget”—the suspension of the entire program for the 1991-92 fiscal year.

While funding was ultimately pieced together to save the program, the damage was done. The administration was no longer seen as sufficiently committed to recycling; the city, whatever it said or did, was not to be trusted. Recycling advocates gained the upper hand in the superficial political debate, which starts from the premise that all waste can be recycled. The same environmental groups that supported the Navy Yard in 1985 now called for putting the project on hold. In response to lobbying by these advocates, the City Council quickly enacted legislation giving itself veto power over the Mayor’s solid waste plan, including resource recovery.

The Mayor, to his credit, was still willing to acknowledge the ultimate need for new incinerators, but also wanted to put forward a plan that was deferential to the possibilities of recycling and stood some chance of acceptance by the Council.

Even with the proposal to scale back and defer the city’s previous waste-to-energy program, the Mayor’s plan met strong resistance when it came before the Council. One longtime Council member observed that he had never seen such venom and ignorance displayed among his colleagues as on this issue. Thus, in August 1992, Council Speaker Peter Vallone managed to gain support for a compromise which at best represents a modest shuffle forward: While construction of one waste-to-energy plant will begin in 1996 (assuming it is not stymied in the permit process or stopped by litigation) and recycling expansion will be expedited, two old incinerators scheduled for upgrade in the Mayor’s plan will instead be closed and the city will forgo plans to build a controversial ash landfill at Fresh Kills. As a practical matter this means that the city will sacrifice about one thousand tons per day of disposal capacity in order to build a new plant capable of handling three thousand tons per day, and the construction of that plant will depend on the uncertain prospect of securing an out-of-city disposal site for ash. In addition, planning for the other new waste-to-energy plants called for in the Mayor’s original proposal will be put on hold; among the consequences will be the probable loss to other public uses of the few remaining sites in the city appropriate for construction of incinerators.

Though the press treated the compromise as a breakthrough in civic responsibility on the part of the Council, in reality it came at the steep price of sacrificing precious waste-disposal assets that another generation of political leadership will have responsibility to replace.

Waste disposal in New York City is largely a story of the city government’s inability to cope with public hostility toward new facilities, even though those facilities are necessary to accommodate the by-products of its citizens’ lifestyles. Ultimately, New York will be forced by circumstances to face up to this dilemma. We are spending more of our limited tax resources on garbage disposal than ever before, and it will soon be apparent that our political system’s inability to deal effectively with this issue hinders our ability to fund other essential services. This is true even assuming what is likely to be the best case: that we are legally permitted to continue to export garbage out of state to a handful of communities willing to take New York’s garbage for exorbitant fees.

It is possible that our government institutions are incapable of handling this problem, that barriers of siting cannot be overcome within the existing political framework. It may take a real fiscal or health emergency to force meaningful action, and even then legislative or judicial actions from higher levels of government may have to override the city’s decision-making mechanisms. For the time being, notwithstanding press reports to the contrary, New York’s waste gridlock continues as the day of reckoning grows nearer.

 

 

 
New Yorkers produce 26,000 tons of garbage each day, and our landfill space is quickly running out. Where will we put our trash?
City Journal Autumn 1992.
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