On Monday, May 24, the DNRC issued a Scoping Notice for a Checklist Environmental Analysis they are conducting on a proposed timber salvage sale at Spencer to harvest downed trees from a winter 2021 blowdown event.
The bad news: FAMB has met with the DNRC and it seems very likely this salvage operation is going to happen, likely as soon as mid-July. During the salvage operation, the Twin Bridges trailhead and trails at North Spencer will likely be closed for up to 30 days. Some of the trails might remain closed for longer if they need to be repaired after the salvage operation. FAMB has several concerns about this salvage operation, and we have submitted our comments to the DNRC on May 30, 2021, shown below. Specifically, FAMB is extremely concerned that this salvage operation could result in significant unnecessary damage to certain trails that we manage and maintain at Spencer, with Otter Pop, Maple Syrup, Big Gulps, and Malice in Plunderland likely to suffer the brunt of the effects of logging operations. We have made several specific requests that the DNRC take all necessary steps to limit unnecessary damage to trails and technical terrain features during this salvage operation by imposing specific restrictions on the salvage operator. How things work at Spencer generally: Spencer is located on state trust lands, which means the DNRC is statutorily mandated to maintain the land for the financial benefit of designated Montana public educational institutions. Recreational use is made possible by a ten-year Special Recreational Use License (SRUL) granted to the City of Whitefish in 2014 by the DNRC. Under this license, the primary use or purpose of these state trust lands is to raise funds for the designated educational institutions, which generally means harvesting timber for profit. Recreation is the secondary use at Spencer under the SRUL as it is on all state trust lands. What exactly is FAMB’s role at Spencer? FAMB signed a Memorandum of Understanding (MOU) in 2013 with the City of Whitefish to assume the responsibility of managing and maintaining the freeride trails at Spencer and paying the annual SRUL fees, which in 2021 come to $5,290.43, plus FAMB’s share of paying for supplies and upkeep of the vault toilet at the Twin Bridges trailhead, which came to $405 this year. Whitefish Legacy Partners also pays their share of the SRUL fee for Whitefish Trail segments and half of the vault toilet upkeep each year. WLP and FAMB also share the cost of upkeep at the Twin Bridges trailhead. What can you do about this? Submit comments to the DNRC to let them know how important recreating at Spencer is to you. Here are a few things we suggest you include in any comments you submit to the DNRC, which can be addressed to Riley Stevenson at riley.stevenson@mt.gov:
FAMB will continue to work with the DNRC to minimize the impacts at Spencer, and your comments show the DNRC that there is community support for those efforts. FAMB recognizes and supports the DNRC’s obligation to manage the forest at Spencer and generate revenue for Montana public schools, and with some reasonable accommodations, we’re sure this salvage sale can happen without excessive damage to the trails. We certainly recognize that the prospect of Spencer closing in the middle of the summer is disappointing, but this is the nature of trails existing on school trust lands. So we encourage you to submit comments and support FAMB’s positions, but we respectfully request that any comments you submit to the DNRC are civil in nature and avoid derogatory language. FAMB values our partnership with the DNRC, and your treatment of their employees reflects directly on FAMB. Thanks in advance for your support in this and all things mountain biking in the Flathead. Here is the DNRC’s scoping notice and public comment solicitation. Email your comments by June 14, 2021 to: Riley Stevenson, riley.stevenson@mt.gov Here are FAMB’s comments submitted to the DNRC on May 30, 2021: May 30, 2021 Department of Natural Resources and Conservation Attn: Riley Stevenson Kalispell Unit 655 Timberwolf Parkway Kalispell MT 59901 Dear Riley: This letter is in response to the Scoping Notice alerting the public to the proposed Spencer Mountain Blowdown Salvage Permit, dated May 24, 2021. FAMB appreciates its partnership with the DNRC throughout the years as we’ve managed and maintained a portion of Spencer Trails for recreational use for the benefit of the public pursuant to our Memorandum of Understanding with the City of Whitefish dated as of August 21, 2013, as amended on March 22, 2017 (the “MOU”). We acknowledge and understand that, pursuant to the Special Recreational Use License granted to the City of Whitefish by the DNRC dated as of January 6, 2014 (the “SRUL”), the primary use of these state trust lands is income generation for the benefit of various Montana educational institutions, and that the recreational use is a secondary use under the SRUL. In terms of trails managed and maintained by FAMB, this salvage operation as proposed has the potential to directly and significantly impact Otter Pop, Maple Syrup, Recess, Malice in Plunderland, and Big Gulps, Eh?, plus impacts to the rest of the trail system and trailhead indirectly via closures that may be required due to the presence of logging trucks and other hazards. We were dismayed to hear that you were not willing to postpone this timber salvage sale - as FAMB has requested - to the Fall months when recreational use is not at its peak as it is during the midsummer months, which is when this salvage sale is targeted for. We do understand that there is very real risk for resource damage from Douglas Fir bark beetles. We also understand that this salvage sale is motivated by the current high market price of lumber and that the DNRC is statutorily obligated under Montana state law to manage these state trust lands for the financial benefit of several Montana educational institutions. That all being said, we have made several requests to you in this matter that we hope you will honor and follow through on, and recent conversations with you have provided us with encouragement that this will be the case. Our requests are squarely aimed at preventing and/or mitigating damage to the trails, technical terrain features (TTFs), and the trailhead at North Spencer. FAMB has invested heavily in Spencer Trails over the last seven years - to the tune of $83,000 in RTP-funded trail and TTF construction and maintenance costs, and 2,528.25 hours of FAMB volunteer trail construction and maintenance labor (which has a value of $63,206.25 at $25/hour), plus significant administrative payroll costs, all for the benefit of the public. A substantial portion of that money has been spent on trails that are within the salvage sale project area. The SRUL requires the DNRC to work with the licensee to minimize impacts to recreation, stating in Section 7(C) that “licensee will be invited to participate in the MEPA process to develop a solution that minimizes impacts to licensed activities while meeting Trust Land Management goals.” The SRUL also provides in Section 26(E) that “when forest management activities are scheduled that may impact the SRUL corridor, DNRC will take reasonable precautions within the scope of the logging process to avoid unnecessary damage within the trail corridor.” Below, FAMB lays out several safeguards that we believe must be taken by the DNRC in order to minimize unnecessary impacts to recreation on Spencer Trails. First, we are happy to hear that the DNRC intends to limit any temporary closure of any or all of Spencer Trails, including the trailhead amenities, to a 30-day period as required under Section 26(G) of the SRUL. Because the DNRC has the ability to place restrictions and requirements in the unit card and resulting salvage sale contract, FAMB has requested that the timber salvage operation cross trails only in this manner so as to “minimize impacts to licensed activities while meeting Trust Land Management goals”, as mandated under Section 7(C) of the SRUL: -perpendicularly, -with skid trails no wider than 15', -as infrequently as possible but no more than every 200', and -to avoid all built trail features including bermed turns and freeride features (with a 50' no-work zone around any built wood features to protect approach/landings which take significant investment to construct and often help provide stability to the structure). We have also requested an explicit ban on skidding up or down trail corridors “to avoid unnecessary damage within the trail corridor” pursuant to Section 26(E) of the SRUL, and have requested that the DNRC walk the affected trails with a FAMB representative to flag zones where skid trails would be best placed, and to designate zones as “off-limits” for skid trails due to significant past investments made by FAMB in certain trail features and TTFs. Furthermore, we request that the salvage operator be contractually obligated to abide by these restrictions during the salvage operation. These safeguards would help satisfy section 7(C) of the SRUL mandating that the licensee “be invited to participate in the MEPA process to develop a solution that minimizes impacts to licensed activities while meeting Trust Land Management goals”. When we last spoke, both FAMB and the DNRC were committed to doing this “walk-through”, and FAMB was encouraged that both parties seemed to agree that skid trails could be placed so as to minimize unnecessary damage yet still allow for the practical harvest of timber, and that such zones could be marked and dictated to the operator. FAMB’s key objective here is to ensure that the salvage operator is contractually obligated to abide by these requirements and that there be a mechanism for such contractor to be held accountable for disregarding any such requirements and inflicting significant, unnecessary damage to the trails and features. As such, we would like to do this walk-through at a time that allows for these safeguards to be placed in the unit card and salvage contract. FAMB also extends the offer to be a point of contact with whom the operator can consult during the salvage operation for any questions the operator has, with the understanding that the DNRC is the operator’s main point of contact during the salvage operation. FAMB has requested that log landings and slash piles be located away from trail junctions and trail corridors, since they can create a safety hazard if located in a runout zone or near a trail intersection and the woody debris left over from log decks and slash piles is detrimental to the trail tread and difficult to repair. We would like to cover this during the above-mentioned walk-through with the DNRC and are happy to serve in a consulting role with the salvage operator if necessary and helpful. FAMB requests that the DNRC give as much prior notice as possible to the City of Whitefish, Whitefish Legacy Partners, and FAMB of trail closures and restrictions of public access. The DNRC is the appropriate party to take on the responsibility of providing to the public via on-site signage all necessary information regarding trail closures at trailheads and anywhere else in the project area deemed necessary or appropriate, as well as a public announcement in print and/or social media if this isn't already part of the salvage sale process. FAMB is happy to assist in this process by getting the word out about closures via social media or subscriber email communications. FAMB has specifically requested that every effort be made to limit the time span of trail closures, as well as the overall trail mileage of closures, with the recognition that closing a significant portion of a trail effectively closes the entire trail for recreational use. This is especially true in the case of trails that are designated primarily for downhill traffic, which includes all trails managed and maintained by FAMB at Spencer. Additionally, FAMB requests that the contract require the salvage operator return the trailhead to the same condition it was in prior to the salvage operation. FAMB, along with Whitefish Legacy Partners, has invested substantial funds in the grading and graveling of the trailhead, and any damage needs to be promptly addressed. Since repairing the trailhead will almost certainly require a continued closure of the trailhead, FAMB requests that this work be completed within the 30 day period required under Section 26(G) of the SRUL. FAMB also anticipates that, even with the salvage operator taking reasonable precautions to preserve and avoid damaging the trails, some damage is inevitable. As such, as part of this project, FAMB requests approval to use a mini-excavator (no larger than 10,000 lbs) to repair all trails within the project area, as needed. As with past use of a mini-excavator, FAMB would notify the DNRC prior to moving the machine on site and would ensure that the machine had been cleaned so as to minimize the spread of noxious weeds. As we have discussed, this process will require some “give and take” on both sides. If this project is slated for completion during peak recreational use months (now through the end of October), FAMB formally requests a pro rata refund or credit of SRUL fees proportionate to the acreage and mileages of trail affected (keeping in mind the point above regarding “effective closure” of entire trails and networks when a significant portion of a trial or network is closed) and a pro rata refund of the Base/Recreation Use fees associated with that time frame (recognizing here that the apex of of recreational use occurs midsummer and slowly tapers until dropping steeply in October). This pro rata refund should extend to the time when FAMB is next able to conduct repair and reconstruction work on damaged trails, most likely Spring of 2022. This gesture would serve to recognize that the licensed use FAMB will have paid for as of June 15, 2021 is being temporarily taken away. A refund/credit determined in the above-mentioned manner is arguably just a de minimis cost of doing business (the salvage sale), especially when taken in the context of the substantial income likely to be generated by the salvage sale. FAMB would invest these funds instead in repairing damage done during the salvage operation, although we anticipate this may not even come close to covering the cost of repairs after this operation. FAMB is committed to a continued partnership with the DNRC, the City of Whitefish, and Whitefish Legacy Partners at Spencer Trails. We appreciate the time DNRC has spent explaining the timber salvage sale process and its justifications. FAMB is contractually obligated to manage and maintain Spencer Trails for the benefit of the public - specifically recreationalists. We take this responsibility very seriously, and feel that the requests made in this letter are those that we must make in order to prevent unnecessary damage to a trail system in which FAMB has invested a total of $146,206.25, plus significant administrative payroll, since 2014. Although recreation is the secondary use under the SRUL, the SRUL requires the DNRC to work with the license holder to prevent any “unnecessary damage” to trails and trailhead amenities. We have laid out some achievable objectives toward accomplishing this goal, and we are encouraged by the willingness expressed by the DNRC to do what is necessary to minimize any such unnecessary damage. Sincerely, /s/ Dan Hansen Dan Hansen President Flathead Area Mountain Bikers, Inc.
1 Comment
FAMB has submitted the following comments on the US Forest Service's Lake Five Project Environmental Assessment. The stated objective of this project is to "reduce tree densities and fuel loadings within the wildland-urban interface in the Lake Five area; improve the diversity and resilience of terrestrial ecosystems and vegetation; and provide a mix of forest products to contribute to economic sustainability." FAMB is asking the Forest Service to take steps to prevent and mitigate damage to existing trails and legacy logging roads in the area currently in use by a wide variety of user groups.
You can read more about this project at: https://www.fs.usda.gov/project/?project=58984 If you would like to submit comments on this project, they are due by May 19. More details on how to submit comments: www.fs.usda.gov/nfs/11558/www/nepa/114631_FSPLT3_5622286.pdf FAMB's comments, submitted via email Wednesday, May 12, 2021: May 12, 2021 Robert Davies, District Ranger Hungry Horse-Glacier View Ranger District P.O. Box 190340 Hungry Horse, MT 59919 Dear District Ranger Davies: Please accept these comments on behalf of the Flathead Area Mountain Bikers (FAMB) regarding the Lake Five Project. It has been our experience that, with some reasonable design criteria restrictions, trails and silvicultural activities can coexist amicably, and we hope this project can effectively look after the trails in the Lake Five area. While the Lake Five Project doesn’t have a specific recreation component, as you know and as the environmental assessment acknowledges, there are a number of trails in the area that will be impacted by the logging activities and vegetation management. While FAMB is a mountain bike advocacy group, we believe efforts to preserve these trails will benefit all non-motorized user groups. We appreciate that the recreation design features set forth in the EA attempt to minimize and account for impacts to some extent, but we feel those design features do not go far enough. Primarily, those design features only require repairing damage to outfitter and guide permitted trails. This ignores the fact that the general public have been using and enjoying this area for many years, and there may be popular trails that are impacted by the project that would not be repaired because they are not used by guides or outfitters. We request that the recreation design features be amended to include all trails in the “Green Gates” area as mapped on Trailforks (https://www.trailforks.com/region/green-gates/?activitytype=1&z=12.7&lat=48.46523&lon=-114.00189). While we recognize that some of the mapped trails are historic logging roads that will likely be used for hauling as part of this project, we also request that design features be included that help protect the trails that are not used as roads. Specifically, we request design features that:
Thank you for your consideration, and feel free to reach out with any questions or concerns. Sincerely, /s/ Dan Hansen President Flathead Area Mountain Bikers, Inc. The Forest Service has completed an environmental assessment on its proposed Stovepipe Project in the Tally Lake area. The project includes logging, controlled burns, and a small recreation component. As you will see below, FAMB's concerns are mostly centered on the potential damage to high-use trails within the project area. We feel that the project can be modified very slightly with little if any loss to logging operations in a manner that would prevent significant damage to a two high-use Tally trails.
For more info on the project, visit: https://www.fs.usda.gov/project/?project=58217 To submit comments: Email in word (.doc or .docx)/PDF/.rtf format to Project Team Leader MacKenzie, with "Stovepipe Project" in the subject line, to: comments-northern-flathead-tally-lake Comments will be accepted through (on or around) April 21, or more exactly: 30 days from publication of the notice in the Daily Inter Lake. FAMB submitted the following comments on the Stovepipe Project EA today: Dear Project Team Leader MacKenzie, Please accept these comments on behalf of the Flathead Area Mountain Bikers (FAMB) regarding the Stovepipe Project. FAMB does not take issue with the majority of the proposed action, but we feel that several small adjustments can be made to better serve the recreation community. The Tally area is heavily used for all manner of recreation, and there are quite a few trails within the project area. Some of the most popular trails run along, or near the boundary of the project area. Our primary concern is damage to these trails from logging activities. We feel that minor adjustments to unit boundaries could effectively avoid these trails without a significant reduction in the overall size of the project. Specifically, units 60, 112, 114, 521, 522, 532, and 538 are all on or near the Reid Divide trail (trail 800). Adjusting those units such that their western boundary ends 50 feet from the trail tread would prevent substantial damage to the trail and significant time and expense required in repairing the trail. It would also limit resource damage, as users (particularly motorized users, of which there are many on trail 800) tend to create new user built paths when faced with damage to the trail tread from logging. The boundary adjustments to those units would be relatively minor, as trail 800 already runs very close to the project boundary. A similar concern exists for units 13, 17, 18, and 19 for the Tally Ridge Trail (trail 458). A relatively small adjustment to those units would keep all logging operations to the east of the trail tread and thus substantially reduce the time and effort required to maintain the trail. There are also a number of non-system trails in units 13, 16, 24, 801, and 814. While there is no reasonable way to adjust the unit boundaries to avoid those trails, we do ask that any logging contracts require efforts to minimize damage to trails in those areas. The trails are well established and popular, and substantial damage to the trails would likely lead to new user built trails to serve as replacement routes. We feel that it would be preferable to preserve the trails in their existing locations. Thank you for your consideration, /s/ Dan Hansen President Flathead Area Mountain Bikers For Immediate Release: FAMB’s Flathead Trail Crew is Hiring!
Job Title Trail Crew Organization Flathead Area Mountain Bikers is a non-profit organization whose mission is to preserve and advance mountain biking opportunities in the Flathead Valley of Northwest Montana (Whitefish, Kalispell, Bigfork, and Columbia Falls). We provide free mountain bike programming to the community and organize volunteer trail work events. We also manage and maintain Spencer Trails in Whitefish and built the pump track in Whitefish’s Armory Park. 2020 was the first year of operations for our Flathead Trail Crew (FTC), a valley-wide trail maintenance and construction crew. The FTC’s 2021 work season was funded by generous contributions from the community in the 2020 Great Fish Community Challenge. FAMB’s projects and programs are led by an Executive Director, with trail projects being managed by a Trail Project Coordinator, all with guidance from FAMB’s volunteer Board of Directors. Responsibilities Reporting to FAMB’s Trail Crew Leader (TCL) Trail Crew will carry out trail maintenance and construction projects on state and federal lands as well as city and county parks in the Flathead Valley, on trails that FAMB has identified as high value to the mountain biking community. Identify and prioritize needed maintenance on each trail project. Perform trail maintenance both independently and as a team, including clearing downed trees, brush cutting, performing reroutes, drainage and tread work. Act as an ambassador for FAMB on the trail. Qualifications Previous trails and/or chainsaw experience is not required but helpful. Self-motivated; able to multi-task with excellent attention to detail; can perform duties successfully without constant supervision. The ability to collaborate with the entire crew to complete projects is important. Reliable transportation and driver’s license is required. Must be able to perform strenuous physical work for long periods of time, lift 50 pounds, and be comfortable hiking with tools and heavy loads. Familiarity with bike-friendly trails is a plus. Required Certifications Current CPR/First Aid cert Current Wilderness First Aid (WFA) or similar (WFR/OEC) is required; applicant must enroll in and pass WFA course in Kalispell May 22-23 if s/he doesn’t have a current cert. Compensation and Schedule Pay $14-$16/hour DOE. This is a part-time seasonal position. Scheduling is flexible, 30-50 hours / week. To Apply Send resume and cover letter to Bryan Tremayne, FAMB’s Trail Project Coordinator, at trailprojectcoordinator@flatheadamb.org. Position is open until filled. FAMB is committed to diversity, equity and inclusion in our hiring practices. For Immediate Release: FAMB’s Flathead Trail Crew is Hiring!
Job Title Trail Crew Leader Organization Flathead Area Mountain Bikers is a non-profit organization whose mission is to preserve and advance mountain biking opportunities in the Flathead Valley of Northwest Montana (Whitefish, Kalispell, Bigfork, and Columbia Falls). We provide free mountain bike programming to the community and organize volunteer trail work events. We also manage and maintain Spencer Trails in Whitefish and built the pump track in Whitefish’s Armory Park. 2020 was the first year of operations for our Flathead Trail Crew (FTC), a valley-wide trail maintenance and construction crew. The FTC’s 2021 work season was funded by generous contributions from the community in the 2020 Great Fish Community Challenge. FAMB’s projects and programs are led by an Executive Director, with trail projects being managed by a Trail Project Coordinator, all with the guidance of FAMB’s volunteer Board of Directors. FAMB is committed to diversity and inclusion in our hiring practices. Responsibilities Reporting to FAMB’s Trail Project Coordinator, the FTC Trail Crew Leader (TCL) will plan and carry out trail maintenance and construction projects on state and federal lands as well as city and county parks in the Flathead Valley, on trails that FAMB has identified as high value to the mountain biking community. Identify and prioritize needed maintenance on each trail project. Perform trail maintenance both independently and as a team, including clearing downed trees, brush cutting, performing reroutes, drainage and tread work. Interface with land managers from the DNRC and US Forest Service and ensure crew adherence to land manager rules and regulations. Supervise crew work, set crew schedule and expectations, and review crew timesheets. Document work performed via photo and video using a personal mobile device, for use on FAMB social media, subscriber emails, and fundraising campaigns. Act as an ambassador for FAMB on the trail. Prioritize safety for the entire crew and for trail users. Qualifications Previous trails and chainsaw experience is required. Self-motivated; able to multi-task with excellent attention to detail; can perform successfully without constant supervision. The ability to collaborate with the entire crew to complete projects is key. Reliable transportation and driver’s license is required. Mileage will be reimbursed at the federal rate. Must be able perform strenuous physical work, lift 50 pounds, and be comfortable hiking with tools and heavy loads. Familiarity with bike-friendly trail design is a plus. Required Certifications Minimum of Wilderness First Aid (WFA) certification. Minimum of USFS B (bucking) chainsaw certification. Compensation and Schedule Pay $16-$18/hour DOE. This is a part-time seasonal position. Scheduling is flexible, 30-50 hours / week, though the TCL must be able to work around any land manager scheduling needs. To Apply Send resume and cover letter to Bryan Tremayne, FAMB’s Trail Project Coordinator, at trailprojectcoordinator@flatheadamb.org. Position is open until filled. The US Forest Service is soliciting public comment on proposed changes to management of e-bikes on Forest Service lands to bring these policies in line with guidance already in effect for the Department of Interior, BLM and National Parks:
"The United States Department of Agriculture (USDA), Forest Service, is proposing to revise its directives to update and clarify guidance on management of electric bicycle (e-bike) use on National Forest System (NFS) lands. E-bikes have become increasingly popular nationwide among outdoor recreationists on NFS and other federal lands. E-bikes expand recreational opportunities for many people, particularly the elderly and disabled, enabling them to enjoy the outdoors and associated health benefits. Currently e-bike use is not allowed on NFS roads, on NFS trails, and in areas on NFS lands that are not designated for motor vehicle use. To promote designation of NFS roads, NFS trails, and areas on NFS lands for e-bike use, the proposed revisions include new definitions for an e-bike and a Class 1, Class 2, and Class 3 e-bike, as well as guidance and criteria for designating e-bike use on NFS roads, on NFS trails, and in areas on NFS lands...Over 27 States have adopted a standard definition for an e-bike and a three-tiered classification system for e-bikes. Additionally, the United States Department of the Interior (DOI) recently issued proposed e-bike rules for the Bureau of Land Management, U.S. Fish and Wildlife Service, Bureau of Reclamation, and the National Park Service pursuant to a Secretarial Order that promotes e-bike use on DOI-managed federal lands. The Forest Service’s proposed directive revisions align with the 27 States and DOI’s proposed e-bike rules in adopting a standard definition for an e-bike and a three-tiered classification for e-bikes and align with DOI’s proposed e-bike rules in requiring site specific decision-making and environmental analysis at the local level to allow e-bike use" FAMB has carefully considered this issue, and will be submitting the following comments to the US Forest Service:
https://cara.ecosystem-management.org/Public/DownloadCommentFile?dmdId=FSPLT3_5465326&project=ORMS-2619 Here are some helpful resources on e-bikes if you're looking to educate yourself on the topic: https://peopleforbikes.org/our-work/e-bikes/ Different classes of e-bikes: https://www.bosch-ebike.com/us/everything-about-the-ebike/stories/three-class-ebike-system/ IMBA’s stance: https://www.imba.com/education/emtb Proposed changes to USFS Regs: https://www.govinfo.gov/content/pkg/FR-2020-09-24/pdf/2020-21128.pdf We recognize that this can be a controversial and emotionally charged issue for many. FAMB's mission is the preservation and advancement of mountain biking in the Flathead, and we have crafted these comments in keeping with this mission. Stay tuned for our developing stance on this and many other mountain biking-related issues - FAMB's Position Statements are listed on our website, and we're always happy to hear from you on these issues. Wherever you fall on the e-bikes issue, you can submit comments to the US Forest Service regarding their proposed changes through October 26: https://cara.ecosystem-management.org/Public/CommentInput?project=ORMS-2619 This position has been filled |
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