Putting the "Public" Back in "Public Trust"
"We are getting our conservation asses kicked!"
Montana politics infects alot of issues in this state, especially
wildlife & habitat conservation. I became acutely aware of this with
the interference of our EMWH Newsletter, back in 2014, when it got
blacklisted and targeted as spam right after I sent out that expose work
on Sen. Jennifer Fielder's Doublespeak and her EQC agenda to turn over
federal public lands to the states. It took me three months to fight
back and gain control over my newsletter. But then it kept happening (I
know, I get into some controversial issues that involve powerful
groups/individuals - cant help that), when similar subjects came up and
more subscribers have been blocked from receiving it of late. So
finally, after this last newsletter on Sept. 27th, "We are getting our
conservation asses kicked" not being received by many of the
subscribers, I had enough. See, I thought it was a great idea years ago
to keep my money and support of businesses in Montana, so my server was
based here, not in another state. While fine for my archaeology site, it
apparently sucks for conservation, like giant whirlpool level sucking. Thanks
to the help of a number of fellow conservationists contributing to this
specific "take back control" effort (thank you Steve Kelly, Ray Gross,
Harold Johns, Leroy Mehring, Tony Schoonen, Glenn Elison and the Skyline
Sportsmen's Association), I was able to purchase a Constant Contact
account for a year. Friday, I created the template to pretty much mirror
my original, had to manually add all 925 addresses into the system on
Saturday, then sent myself a test at my emwh.org address to view it,
which was blocked by my own server. There have been others that said
they sent things I didnt receive, sometimes having to use my gmail
address to get it through. So Saturday, I purchased web server space
with a company out of Montana that not only provided two years for what I
just paid for one year, I also have other layers of domain protections
and preventions to help subscribers receive the newsletter and such, as
well as increased bandwidth and such. I then migrated almost 1300
website files and made sure it was populated here in the technology
boonies of Montana (kind of ironic that Europe got it updated yesterday,
but Montana didnt have it until this morning) before compiling this
newsletter. I am a very exhausted, but a relieved conservation activist
now. With that said, below is the newsletter from Sept. 27th that
many didnt receive, with some amended information right now. Right
after I sent the newsletter out, I received a certified mailing from BLM
of some of the missing comments from the Bullwhacker Access scoping
process - 191 additional pages of bloody missing comments, most of which
were for new road access constructed. I compared the two disks, removed
the duplicates and compiled a table showing the commentors and their
votes - I
erred greatly on the side of the Wilks land exchange, for example, if a
commentor didnt want any road put in the Bullwhacker area and mentioned
a land exchange, I added that to the Wilks Land Exchange column, not
the "No Road" column, so that no one could accuse me of trying to
minimize that option. Yet, even with that handicap, of the 187 comments
found so far, the Wilks land exchange only received 25.67% of the total,
where new road access, especially on the east side of the Anchor Ranch,
received 61% of the total, a clear majority. So how can the
Lewistown BLM justify the public statements they have been making like,
"The public overwhelmingly said they wanted us to reconsider a land
exchange as a possible alternative", which prompted my comment request
to see what the reality was? Additionally, the Central
Montana District Manager, Stan Benes, left BLM
unexpectedly on Friday, Oct. 2nd. The
BLM Lewistown Field Manager, Geoff Beyersdorf, who supposedly did the
investigation of the Durfee Hills fall 2014, putting out an official BLM
News release that the Wilks fences were fine, previously transferred to
Fairbanks, Alaska.
Thank you for your patience while we
worked out the political "technical difficulty". And to those of you who
have been fiscally, materially, inspirationally and emotionally
supportive, I greatly thank you for your contribution to putting the
"Public" Back In "Public Trust". | Sept. 27, 2015 Newsletter
|
I
am not going to write about or link to the Sage
Grouse news, there are a plethora of articles
with a myriad of perspectives, which many of you
are already aware of. I am not going to write
about the numerous feel good National Public
Lands Days goings on curently taking place here
in Montana and elsewhere. Instead, I feel there
are some interconnected issues more important to
discuss, that have been gnawing at me awhile,
especially since a number of us met with FWP
Director Hagener recently - cause we are getting
our conservation asses kicked.
ArcGIS Grant, but will it be used to map our Montana conservation ass kickings? I am totally excited to share that EMWH put in for a grant request to ESRI for the ArcGIS Advanced mapping program
that I downloaded the trial version of (ditched
the open source), used to create the Elk distribution/Objectives/Outfitter map for the Elk Shoulder Seasons
issue. ArcGIS is a totally awesome and
expensive program (used by governments and
agencies), no way I could pay for one. But, a
FEMA guy, familiar with our conservation work
suggested I put in for a grant, so I filled out
their gauntlet ASCII grant application, with my
non-conformist answers (they wanted to know what
make and model of computer I have, I build my
own; they wanted to know what GIS training I
had, didnt have any, have been creating maps by
hand with graphics programs and made one using
their trial version; etc.). Not only did I get
the machine coded response back right away,
meaning I passed their gauntlet, but I received a
response back in an hour, that granted my
request for the ArcGIS software, as well as the
4 training manuals I requested, with an
offers for training and extensions. Woohoo. So
we can now create more maps based on
science/data to advocate for Public Trust
scientific wildlife/habitat management or, if
things are as bad as I relate below, I will at
least be able to gloriously map out our downfall
to political bullshit, cause we are getting our
asses kicked, and need to start effectively
pushing back!
Chipping Away at Wildlife Habitat and Public Access Besides
the special interest legislative sportsmen's
ass kicking to stop FWP from acquiring any more
public lands for wildlife and habitat, there is
another way they are giving us the boot -
privatizing public lands and access. As most of
you know, we of course did not get a Corner
Crossing bill through the Republican blockade,
the previous legislative session. Recently, while researching a Corner Crossing issue
I had bookmarked back when I was injured, Tony
Schoonen referred me to the Anaconda public
access advocate referred to in the article
written by Jack Jones. Dale Schafer, led
the charge for getting the illegal closure by a
private landowner of a public access county
road, Modesty Creek Road, opened back up to the
public. (BTW, Dale told me that his trial
download of ArcGIS maps used in court made all
the difference. I told him we now have one for
future reference.) :)
But, it wasnt Modesty Creek
that caught my attention, it was that Dale and
another hunter had intentionally utilized corner
crossing of public lands, not once, but twice
and did not have to pay fines. He challenged the
FWP Game Warden to write on the citation
exactly what law or regulation he was breaking
by not trespassing on private lands, but walking
on our public lands. None was cited. Dale asked
to be shown in the regulation book where the
violation was, it was not produced. See, this
issue has been gnawing at my mind for over a
year, prompting the below EMWH Conservation
Postcard I had been working on before I spoke
with Dale.
| This
is one of those issues that I think we need a
Ballot Initiative on, to take directly to the
Montana voters, a push back against the
privatization of the public wildlife and lands.
"Corner Crossing, not a taking of the private
rights, but a Connecting of our Public Lands."
Another boot in the habitat and access scenario
is an example by Gayle Joslin, conservation
hunter and retired FWP wildlife biologist. She
is fighting against Helena
National Forests recent attempt to reject a
proven, science-based Forest Plan standard for
wildlife security during the hunting season,
that has been in place for 30 years. "The
existing old standard is based on decades of
peer-reviewed research by dozens of wildlife
researchers. There are no new studies that
refute the long-standing science of wildlife
security needs on public lands. That research
focused on the need to reduce roads, but never
did the science suggest that vegetative cover
should be reduced as a component of security
during the hunting season." And our Montana Fish, Wildlife
and Parks has agreed to the change in big game
security if travel plans for the Divide and Blackfoot
landscapes are implemented. Which leads me to
FWP's increasing rejection of hard science.
FWP Soft Science/Hard Science Some
of us recently met with Dir. Hagener after the
EQC meeting, where we expressed a number of
concerns involving FWP, their recent game damage
amendment, elk shoulder seasons and some other
interconnected subjects (like Joslin's
discussion above). I had stated a number of
times in the two days I made comments at the EQC
about our need for scientific wildlife
management, which FWP is supposed to be based
on; that Montana Fish, Wildlife & Parks and
the FWP Commission are members of Association of
Fish and Wildlife Agencies (AFWA) and the
Western Association of Fish and Wildlife
Agencies (WAFWA). In WAFWA's Public Trust
Doctrine Resolution it mandates, "that fish and
wildlife resources are to be held in trust by
government for the benefit of present and future
generations." It further states, "...the public
must be made aware of this Public Trust, and it
must be enforceable against the government."
There are 7 important Public Trust components to
the North American Model of Wildlife
Conservation. The 6th states that Science is the
proper tool to discharge wildlife management.
"Science as a base for informed decision making
in wildlife management has become standard in
Canada and the U.S. Nevertheless, funding has
been largely inadequate to meet the research
needs of management agencies, and a trend toward
greater political influence in decision making
threatens this principle. " During the meeting with Dir.
Hagener, he asks me, "Kathryn, isnt sociology a
science?" I replied it was, but our elk
management plan is based on biology, a hard
science, which they are supposed to be managing
for. So this greatly concerned me that the head
of FWP, Dir. Hagener, was advocating for a soft
science of society's behavior, rather than
wildlife biology, a hard science. See, hard
science and soft science are terms used to
compare different scientific fields, "on the
basis of perceived methodological rigor,
exactitude, and objectivity." Basically, the
natural sciences are considered hard sciences,
such as the biology used for wildlife management
that requires proven methods that consistently
produce the same results, whereas the social
sciences, such as politics, psychology,
psychiatry are soft sciences. 4+4 always equals
8, elk consistently need certain things in order
to survive in a habitat - hard, consistently
provable science. But the science of society is
not so "hard". Not all landowners hate wildlife,
not all landowners want to privatize our public
wildlife, one legislator does not represent the
actual views of every single person in their
area - see, lots of variables, open to
interpretation and change, which is why it is
considered "soft". This is why Helena FWP is failing the
wildlife, the public in general and
specifically, the conservation sportsmen whose
dollars pay their salaries and expect scientific
wildlife management; Helena FWP has been
managing for "soft" politics, rather than "hard"
biology. You cant expect, "that fish and wildlife
resources are to be held in trust by government
for the benefit of present and future
generations," if the Director of the agency does
not advocate for the hard science we need. Nor
if you cater to the loudest yelling whims,
legislative bullying, or certain special
interest groups. Nor can you manage for
scientific wildlife management when a culture of
fear is entrenched in the agency, where
biologists are hamstrung, in preference to
special interest politics, or they get
marginalized, pushed out or fired for speaking
up. Nor when a ranching FWP employee can be in
charge of a number of interconnected programs
with little to no transparency, which has been
failing audits, showing partiality to landowners
that dont legally qualify, using our sportsmen's
dollars and the Director is not even willing to
discuss it. Nor, as an example, if you are going
to haze elk off of a FWP Wildlife Management
Area in Region 3, which was purchased for the
wildlife, to the benefit of the domestic cows
(our elk are seriously getting their wildlife
asses kicked by Helena FWP). This is ludicrous.
These are just some of the pieces of this absurd
picture. Also disturbing at the meeting was yet another
excuse of what is taking place in FWP. In
relation to my statements of the AFWA and
WAFWA's Public Trust Doctrine and FWP's
membership with them, Director Hagener asked if
Colorado, Wyoming, Idaho and Utah were also
members of AFWA and WAFWA? Do we consider that
they uphold the Public Trust Doctrine,
scientific wildlife management, why should
Montana have to then? Before I could answer, one
of the men next to me quickly and adamantly sat
forward and stated, "Because Montana is the
'Last Best Place' and we dont want to be like
those other states!" Couldnt have said it better
myself. To excuse FWP's lack of following the Public
Trust Doctrine, involving scientific wildlife
management, just because other state fish &
game agencies arent, is not leadership. We need
good leadership for Montana and for Montanans.
Ultimately, it is the Governor that appoints the
Director and since the Director is not
advocating for Montana's fish and wildlife, per
Montana FWP law 87-1-201 and its subsections,
"the department shall enforce all the laws of
the state regarding the protection,
preservation, management, and propagation of
fish, game, fur-bearing animals, and game and
nongame birds within the state," which involves
the hard science of biology, perhaps we need to
begin pressing the point with Governor Bullock,
cause we are getting our conservation asses
kicked big time on this one.
When an FWP "EIS" is not really an "EIS" Again
with the hard science - this Bison "EIS" was
not only a waste of time and finances, but of
the public's time and expectations. We expected
the public trust, scientific based wildlife
management, a proper Montana Environmental
Impact Study and what we got was either lazy,
poorly produced, incompetent, driving towards
privatization or horribly calculated to
intentionally fall short of the mark as a delay
tactic, all the while using our sportsmen's
dollars. I attended the FWP bison working group meetings,
where they broke their chosen participants into
4 groups to come up with alternatives. Group 4
produced a site specific Charles M. Russell
alternative with a large bison population for
the necessary genetic diversity and more
accurate science that a much smaller population
would not reflect. According to current publication, A
Guide to the Montana Environmental Policy Act
(MEPA), pg. 33, the "substantive requirements"
of an EIS are: a description of the purpose and
need for the proposed action; a description of
the AFFECTED ENVIRONMENT; a description and
analysis of the alternatives, including the NO
ACTION ALTERNATIVE; and an analysis of the
impacts to the human environment of the
different alternatives, including an evaluation
of appropriate mitigation measures." The
capitalization and underlining is theirs. FWP
has failed at the most basic level of producing
an EIS, by not producing a site specific EIS.
The poorly produced draft EIS originally sent
around in spring, still retained the CMR as a
site specific alternative produced by Group 4,
until an email on April 3rd, from Sen. Taylor
Brown (one of the bison working group members)
was sent back to FWP's Lauri Hanuska-Brown,
objecting to the CMR site specific product of
Group 4, which btw, was publicly produced and
presented at those working group meetings. "My
concern is that the attached EIS Update lists
the Charles M. Russell National Wildlife Refuge
as a 'Montana Site that Appears to Fit the
Sideboards of Alternative #4'. I would question
whether that is the case." As a result of Sen.
Brown's "soft social science" objections, the
"EIS" was revised to exclude it, thus falling
short of one of the essential criteria of an
EIS. This was only one of the many, many deficiencies
of this "EIS" because they didnt do the bloody
hard science required, instead choosing to
pander, once again, to soft science politics.
Perhaps, if FWP had not politically fired a
proven and qualified wildlife biologist,
"coincidentally" their bison specialist, but an
employee who has produced real EIS's, we would
have had an awesome EIS based on hard science,
but I am sure that was their point. We,
definitely, and Arnie Dood, especially, got our
asses kicked on that one. But the wild bison
migrating into Montana definitely have been
getting the biggest political species ass
kicking of all.
Public Comments Ass Kicking A
number of times when public comments are
submitted on controversial subjects, I will
request a copy of the public comments, sometimes
needing to do so as a Montana Public Information
Request, knowing that if I don't, it will get
dragged out until I need to end up doing so
anyway. FWP's legal office recently replied and
warned that while they waived any fee's per this
Game Damage request, they would not do so in the
future. Now FWP already has to compile and
review these comments. How hard is it to take
that electronic folder and copy it onto a disk?
So what are all the hours and costs for putting
it on a CD and mailing it? Except, it is a means
of keeping the public from the information FWP
doesnt want them to possess and it makes FWP
accountable for the comments. I think a lot of
us need to be requesting Public Comments more
frequently!
FBI - Not what you think it is! In
the Game Damage Amendment Public Comments I
recently requested and received, I was struck by
three things. First, so few people take the time to submit a public comment.
Second, concerning the rule change allowing
landowners to chose the hunters for Game Damage,
one hunter wrote about not allowing the
landowners to choose. "I have a concern about
the addition of or list of names supplied by the
landowner. That the list will become the only
way that hunters are chosen to hunt and it will
become FBI (families, buddies and in-laws) list
hunt and only FBI list will be able to be chosen
to hunt." This has already been a complaint on a number of
Block Management issues as well. Again, paid for
by our sportsmen's dollars to provide access,
but the system is being gamed by some in more
ways than the 2013 failed Legislative Services
audit found. Like the recent example of a
landowner in Region 7 who already had his
"reservations" filled right at the moment of the
opening day and time, when a public hunter
called, as was the case the previous year as
well, probably from FBI. Thankfully, this public
hunter has filed a complaint that is on record.
I know it is an inconvenience, but more people
need to do this to ensure accountability and
transparency. Third, there are some key things
conservationists need to know about making
public comments, cause we are getting our
individual asses kicked by those that know how
to game the system. 1. I learned this at a Board of Livestock
meeting and have been telling people this for
over a year and a half now - Montana only counts
FORM comments as ONE comment. So it doesnt
matter if there are 1000 comments on a matter,
MT only counts the form comment as 1. So
conservation/sportsmen groups need to stop
creating the bloody web forms that are cheating
us of a valid voice. And individuals need to
stop lazily filling the damn things out. Some
groups do it to data mine the contact
information, then they can then send you
requests for donations. Groups, if you really
care about the issue, put up a web page or
newsletter of bullet points, encourage your
readers to pick and choose like a buffet and
make sure they are encouraged to create an
original subject line and additional original
sentences. This sh*t has gotta stop. 2. Groups, stop sending a
comment from your group alone. It doesnt matter
if you have 10 members or 1000, the agencies are
counting that group comment letter as 1
comment. And the agencies are taking advantage
of that to minimize the number of comments they
present in their reviews. So send your group
comment letter, but again, encourage your
members to send in their own comments. I have
even seen comments that were all generated by an
obvious - sit down comment writing session, all
with the same generation and received by date,
location addresses and all the same paper (such
as lined notebook paper) with similar comments,
but it wasnt by the conservation hunters and
anglers! Here's another example. In the illegal FWP April 2014 Elk Brucellosis Work Plan public comments,
Jessica Anderson sent in a comment on Park
Conservation District letterhead, as the
District Administrator. On the same letterhead,
Anderson sent in another comment for the Upper
Yellowstone Watershed Basin, as the Watershed
Coordinator, she also sent in a comment as an
individual. Now, the UYWB appointed Druska
Kinkie, one of their members, as the Paradise
Valley Elk Brucellosis Working Group Chair (this
was not an FWP working group, also lacked multi
stakeholders as it was supposed to).
Druska Kinkie also writes out a comment.
Additionally, Rep. Alan Redfield, also a
Watershed member and also a member of the
brucellosis working group writes his own
individual public comment, as did others that
were members of both. I have seen this play out repeatedly
with public comments and special interest ag
groups - they know how this works, and again, we
are getting our collective conservation asses
kicked because conservationists/sportsmen dont
know how to play the game!
What's
in your backyard? When your conservation
"neighbors" join in the ass kicking. Heartbreakingly,
it happens. One "conservation" group, to
leverage getting what they want in their
backyard, will sell another conservation group
down the river, throw them under the bus, pick
your metaphor, it's happening. An example is the
recent Wilks Brothers land exchange where they
are trying to exchange private landlocked land
in the Missouri Breaks National Monument in
Blaine County they bought to leverage for the
awesome Durfee Hills, beautiful elk habitat in
Fergus County. The Friends of the Monument and
Montana Wilderness Association submitted public comments for the land exchange,
throwing other public lands and wildlife they
were not involved with, under the bus for what
they wanted. I get their wanting to consolidate
more of the Monument, but you shouldnt throw our
public elk and the Durfees in another area,
under your special interest bus to do so. And
again, there was a group letter, then the
individual letters from their members. Then there
are the "conservationists" who position
themselves within the funding foundations,
effectively, politically starving out other
conservation "doers" from being able to "do".
Trust me, while the head wills, and the heart
wills, there is much you simply cannot do
without even the most basic funding. I have been
hearing and watching this over the last few
years, that funding is shut off to certain
conservation groups and projects, after
leadership and boards at funding foundations
change, who then begin to funnel that money into
"their" interest groups. Additionally, there is credit robbing
(sometimes this is used to garner more
contributions, by making it look like the group
is doing more than they are actually doing).
This is part of the political positioning, turf wars and pissing
contests that jockey for membership and their
contributions. They "market" themselves with
nice ad campaigns, spending more time on the
appearance than if hey had actually gotten out
on the ground and actually done something
concrete. They know the majority of the
membership or contributors will not look into
it, and they get away with it. My daughter's dog
used to do that. I would throw the ball, he
would wait for my dog to run out and retrieve
it, then just as she was bringing it back, he,
being much larger, would intercept and tackle
her, grabbing the ball, dropping the ball in
front of me as though he had retrieved it
himself. I put a stop to that. Sometimes the simple silence or
inaction of a conservation group, because some
higher member has a personal friendship with
another involved in an agency, for example, puts
personal politics ahead of conservation issues.
Well hell, there are a lot of people who know a
lot of other people in this state, yet you dont
see this affecting the ag special interests. I
didnt see the Montana Farm Bureau from refusing
to publicly support SB245 when there were a
number of outspoken conservation hunter farmers
opposing SB245. The ag industry probably tells
dissenting members to "suck it up" or "take one
for the team", because they dont let anything
get in the way of their machinery. There needs
to be some kind of separation of church and
state thing, because the silence or inaction of
conservation issues, due to personal
relationships, is allowing the privatizers to
capitalize on that paralysis or simply co-opt
the silence as an endorsement. This is where conservationists
get our asses kicked that should be the easiest
to prevent, but ag special interests dont play
this game. I have seen meetings and public
comments where even if it doesnt have anything
to do with sheep, the wool growers will weigh in
FOR their ag cattle brothers, like with an elk
issue. Likewise, the cattlemen will support
their wool growing buddies in a bighorn
sheep/domestic sheep issue. And the Farm Bureau
will also weigh in, even if it has nothing to do
with crops. They learned long ago the power of a
united front, contributing to their bigger
picture - solidarity. But the desperateness,
scarcity, the lack of conservation wins, has
some conservationists acting like drowning
swimmers, so desperate to save themselves they
are willing to drown those that could help them,
and we all lose as a result of the "every man
for himself, at all costs" mentality.
Back to the Brink, the Final Ass Kicking From
where I am sitting, after this meeting with the
FWP Director Hagener, looking at all the
interconnections of this issue, we are at the
point of totally losing fish &
wildlife/habitat conservation here in Montana to
privatization, if we dont aggressively fight
back now and stop habitually accepting the
calculated ass kickings. If only these issues
were as appalling and mobilizing to the public
as yoga pants or Montana legislator cleavage or
skirt length. Perhaps, as some have said, we
have already lost, in which case I should just
get back to my archaeological/historical
research and art, take care of myself
financially, instead of pouring myself out for
something that has already had its jugular cut
and there is no way to stop the hemorrhage. In
my new spare time, should I then begin working
on a new book, "Back to the Brink: Montana's
Conservation Rise and Fall of the Last Best
Place"? Perhaps, as a few other cynics have
stated, "Let the privatizing fuckers have it all
and then the conservation hunters & anglers
eyes will be open." But could we get it back,
once lost? Chances are slim, it is always harder
to regain something lost, than to prevent the
loss in the first place, but the loss may be
inevitable. The question really comes down to this, are
Montana conservationists going to keep taking
these privatizing ass kickings, or are we going
to rise up and start effectively kicking some
major ass ourselves? It really is that simple. We
have the tools (such as Networking, Ballot
Initiatives and Public Comments) and the
majority numbers, which presently are not being
adequately utilized, if properly organized and
orchestrated, could ensure Public Trust Doctrine
scientific wildlife management, wildlife and
public access to public lands and waters, for
future generations. Your individuality enmasse
is a powerful, powerful thing... when you chose to
use it. What's in it for you? Will you set aside
a little short term inconvenience to fight back,
for some long term invested gain? Heraclitus, a long dead
Greek Philosopher from Ephesus wrote, "Out of
every one hundred men, ten shouldn't even be
there, eighty are just targets, nine are the
real fighters, and we are lucky to have them,
for they make the battle. Ah, but the one, one
is a warrior, and he will bring the others
back." Instead of the 80% of conservationists
being targets for privatizing ass kickings,
Montana needs those 80 to become her
conservation warriors, because it is going to
take a 90% effort to keep Montana from becoming a
privatizing Texas/European Model and slipping
back into the "Brink". An even older dead, Greek
philosopher, Plato, expressed that we are twice
armed, if we fight with faith. I saw a quote about a year ago,
"What makes a movement strong is not the number
of people willing to give money, but the number
of people willing to believe there is hope."
Are we going to be one of the 90% that kicks
some epic conservation ass, so that no one will
ever be able to write that Back to the Brink
book, instead inspiring a - how the public
picked their bruised asses up off of the ground
and took back our Public Trust Doctrine - for
our future generations? I have faith and I
have hope that we can. The numbers question is,
do you? |  | I would like to thank the following contributors for supporting EMWH. Your gift is very much appreciated. Shawn Danielson If you would like to further this work and research, please click to contribute to EMWH. Thank you, Kathryn QannaYahu 406-579-7748 | | | Enhancing
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