Authors: Partha PratimMitra and Prakash Sharma*
The United Nations General Assembly in 2006 adopted 22nd May every year as the International Day for Biological Diversity.The day commemorates the adoption of the agreed text of the Convention on Biological Diversity(CBD).This year’s slogan is “Our solutions are in nature”, which emphasizes upon ‘hope, solidarity and the importance of working together at all levels’, and a future built in harmony with nature. This year is important because it is the final year for three major instrument, namely United Nations Decade on Biodiversity (2011-2020), the Strategic Plan for Biodiversity (2011-2020) and its Aichi Biodiversity Targets.
The year is also important because CBD is revising and working on another strategic plan to adopt post-2020 global biodiversity framework as a stepping stone towards the 2050 vision of “Living in harmony with nature”. The present paper discusses how ‘biodiversity’ is central to the development of environment discourse, especially when issues concerning ‘biodiversity’ makes international negotiations and agreements controversial and highly politicized. Amongst issues, perhaps three appears to be crucial i.e. national sovereignty; conservation and sustainable use of biodiversity; access and sharing of benefits of biodiversity.
CBD was signed in the year of 1992 at the United Nations Conference on Environment and Development(the Rio Earth Summit).CBD links traditional conservation efforts to the economic goal of sustainable using of biological resources. CBD has ensured that international environment law recognizes the conservation of biodiversity as “a common concern of humankind”, and at the same time remains an integral part of the development process.CBD is legally binding, and nation-states that join it are obliged to implement its provisions.
CBD covers ecosystems, species, genetic resources, biotechnology, and links traditional conservation efforts to the economic goal of using biological resources. It sets out principles for a fair and equitable sharing of the benefits arising from the use of genetic resources. While it reminds decision-makers that natural resources are not infinite and its sustainable use, it recognizes that ecosystems, species and genes must be used for the benefit of humans. The earlier conservation efforts were only aimed at protecting particular species and habitats. Further, CBD offers guidance based on the precautionary principle to the decision makers and demands that where there is a threat of significant reduction or loss of biological diversity, lack of full scientific certainty should not be used as a reason for postponing measures to avoid or minimize such a threat.
To date the Conference of the Parties (COP) has held 14 ordinary meetings, and one extraordinary meeting, namely the Biosafety Protocol, which was held in two parts. From 1994 to 1996, COP was held annually, and thereafter meetings were held less frequently. However, following a change in the rules of procedure in 2000, COPs were held every two years. COP is the governing body of the Convention, and advances implementation of the Convention through the decisions it takes at its periodic meetings.
Through its Cartagena Protocol on Biosafety, it addresses concern of technology development and transfer, benefit-sharing and biosafety issues. It is the first international regulatory framework for the safe transfer, handling and use of Living Modified Organisms. Likewise, the Jakarta Mandate on marine and coastal biological diversity was adopted by the CBD Parties in 1995 to underline the importance of establishing coastal and marine protected areas. Subsequently, the CBD Parties have agreed that marine and coastal protected areas are one of the essential tools and approaches in the conservation and sustainable use of marine and coastal biodiversity. In the same year, Protocol concerning specially protected areas and biological diversity in the Mediterranean was adopted in Barcelona(came into force on 12 December, 1999). It is a key facilitator of CBD implementation in the Mediterranean area. Under the instrument, Parties are obliged to take necessary actions, In order to protect, preserve and manage in sustainable and environmentally sound way, areas of particular natural or cultural value, notably by the establishment of specially protected areas, and to protect, preserve and manage the threatened or endangered species of flora and fauna.
Another important instrument was the Nagoya Protocol on access to genetic resources and the fair and equitable sharing of benefits arising from their utilization. Adopted in the year 2010, the instrument sets out core obligations for its contracting Parties to take measures in relation to access to genetic resources, benefit-sharing and compliance. It also creates incentives mechanism for conserving and sustainably using genetic resources for human well-being.
Balancing Intellectual Property Rights and Biological Diversity: Key Issues
Article 8 (j), CBD encourages to take steps that respect, preserve, maintain knowledge, innovations, practices of indigenous and local communities embodying traditional lifestyles relevant for the conservation and sustainable use of biological diversity. It also suggests use of measures that promote their wider application with the approval and involvement of the holders of such knowledge, and encourage the equitable sharing of the benefits. Article 15(7), CBD mandates that each contracting Party, upon mutually agreed terms, shall take legislative, administrative or policy measures, with the aim of sharing in a fair and equitable way the results of research and development and the benefits arising from the commercial and other utilization of genetic resources with the contracting Party providing such resources. Under Article 16(5), CBD the contracting Parties are required to recognize patents and other intellectual property rights (IPRs)that may have an influence, and shall cooperate in this regard, subject to national legislation and international law in order to ensure that such rights are supportive of and do not run counter to its objectives.
Now, the current IPR regime encourages commercialization of seed development, monoculture, protection of new plant varieties, microorganisms, and genetically modified organisms. As a consequence, the rich biogenetic diversity is being eroded irreversibly. The relationship between the CBD and IPRs has been even considered by the COP in a number of decisions. In this regard, invitation was made to Word Trade Organization (WTO) to consider relevant provisions of CBD, their interrelationship with the provisions of the TRIPS Agreement, and to further explore this interrelationship. Policy-makers and members of civil society have registered concerns that the TRIPS Agreement promotes private commercial interests at the expense of public policy objectives contained in the CBD. It is disastrous to allow commercial priorities at the expense of the diverse eco-systems. The extent IPRs are considered essential to the industries, and in view of the increasing corporate control of biotechnological research, demands revisit of CBD. In this sense many argue that CBD is now regarded as a case of a hard treaty gone soft in the implementation trajectory.
Indian Position on Biodiversity Conservation
India plays a significant role in the protection of biodiversity acknowledges the value of biodiversity for sustaining and nourishing human communities. There are17 “mega-diverse” nation-states that contain 70 % of world’s biodiversity. India is one of these megadiverse countries with 2.4% of the land area, accounting for 7-8% of the species of the world, including about 91,000 species of animals and 45,500 species of plants, that have been documented in its ten bio-geographic regions. In order to honour the mandate of CBD, India had enacted the Biological Diversity Act, 2002for preservation of biological diversity, and establishes a mechanism for equitable sharing of benefits arising out of the use of traditional biological resources and knowledge. The Act establishes Authorities at both Central [National Biodiversity Authority (NBA)] and State level [State Biodiversity Board (SBB)].India has framed Guidelines on Access to Biological Resources and Associated Knowledge and Benefits Sharing Regulations, 2014 in pursuance of the Nagoya Protocol. As a result, any person who intends to obtain any IPR by whatever name called, in or outside India, for any invention based on any research or information on any biological resources obtained from India, shall make an application to the NBA in Form III of the Biological Diversity Rules, 2004.Now, where the applicant himself commercializes the process or product or innovation, the monetary sharing shall be in the range of 0.2 to 1.0% based on sectoral approach, which shall be worked out on the annual gross ex-factory sale minus government taxes. Likewise, where the applicant assigns or licenses the process or product or innovation to a third party for commercialization, the applicant shall pay to NBA monetary sharing of 3.0 to 5.0% of the fee received (in any form including the license or assignee fee) and 2.0 to 5.0% of the royalty amount received annually from the assignee or licensee, based on sectoral approach. However, any person applying for any right under the Protection of Plant Varieties and Farmers’ Rights Act, 2001 is exempted from this procedure.
India is a leading country in having established a comprehensive legal and institutional system to realize the objectives of CBD. Besides, the efforts on behalf of NBA is recognized globally for its pioneering work to implement the CBD and fully operationalize the access and benefit-sharing provisions, among others through a national network of Biodiversity Management Committees, alongside the establishment of People Biodiversity Registers. There have been certain collaborative efforts, for instance the Government of India in collaboration with the Norwegian Government has established “Centre for Biodiversity Policy and Law” (CEBPOL) for strengthening the biodiversity policy and law in India.
Policy-makers have an important role to play in ensuring that policies and practices relating to IPRs, and the need for the conservation of biodiversity, remain mutually supportive. In this regard, Governments are required to adopt an integrated approach ‘across’and ‘between’ different national and international fora, to strictly implement the objectives and provisions of the CBD. Presently, CBD is in the epicenter of Global North-South debate, wherein developed States wants to promotes “scientific development, IPR for plant verities, genetically modified foods”,and developing States wants to extent protection on “agriculture, farmer’s rights, animal welfare, environment and ecology”.
We need to understand that the presentCOVID-19 pandemic has shown us how important is biodiversity in nature, and how scientific development and medicinal advancement are incomplete to handle situations like these. It is a clarion call from our creator is to remind ourselves of “live and let others live”. Extinction of species do affect our ecosystem, particularly when every specie has an important role to play on the planet. Biodiversity combines interactions of all living organisms and their existence on the planet. Only this time no Noah’s ark will come unless strict adherence to CBD is made. Indeed, itis possible to save all species in the mother earth because “Solutions are in Nature”.
*Assistant Professor, VSLLS, Vivekananda Institute of Professional Studies, New Delhi.
Climatic refugees: Natural calamities and migration flows
The London-based Institute of Economics and Peace has presented a Report with a profound insight into environmental dangers that threaten countries and territories and could jeopardize socio-economic stability worldwide. According to the Report, “in 2050 the living space of more than one billion people may turn out under threat”. This could be the result of climatic changes, “hurricanes, floods, deficit of water and food”. “Many residential areas will no longer be habitable”
In the estimates of the authors of the Report, climate changes affect the rate and direction of movement of masses of people in at least two ways. Firstly, the more profound they are, the stronger the impact of natural disasters on the living environment will be. Secondly, these processes will depend on the extent of the climate change – caused destabilization in the sphere of food security, on whether they will restrict or close access to fresh water and food for a significant number of people.
In turn, the dynamics and geography of migration have an immediate impact on the structure of the population in countries and regions. Meanwhile, in terms of politics, demography plays a major role in determining the level of stability and ascertaining the historical prospects for political regimes. It produces a tangible influence on social policy, geopolitical potential, and domestic electoral processes.
Poor countries with a growing population will run the risk of plunging into “political instability and violence”. A decrease in the number of employable residents will likely have a negative impact on the rates of the economic growth “in mainly developed and in some developing countries”. Cross-border migration will become an ever more important factor in political processes. Maximum population growth is expected over the next 20-30 years in Africa, which is home to most poor and unstable countries. Under a negative scenario, this will trigger a new wave of global migration “of unprecedented scale” which will provoke blatant interference in the affairs of the region on the part of foreign powers.
According to the Report, such countries as India and China are more than others likely to experience shortages of fresh water. While Pakistan, Iran, Kenya, Mozambique and Madagascar are facing “a combination of threats which they find ever more challenging”. In the estimates of the authors of the research, Pakistan, Ethiopia and Iran are countries where “a slight deterioration” of the environmental situation, along with natural calamities, can produce a significant number of migrants.
In general, the authors of the Report predict that the most acute shortage of social and economic resources, which has been caused by negative climatic changes, will take place, in decreasing order, in countries of Africa, South Sahara, the Middle East, North Africa, and South Asia. 17 of 28 countries that are most affected by the deficit of essential resources are located in “black” Africa, another 4 – in Maghreb and in the Middle East.
Citing the given trends, the authors of the Report predict the formation of “powerful migration flows which may first affect European countries, which are believed to be relatively resistant to crisis”. “Ever since 2015 we have observed how a relatively small number of migrants may provoke large-scale political unrest and disorder”, – chief of the research Steve Killelea said in an interview with dpa.
Undoubtedly, a dramatic rise in the number of climatic refugees and forced migrants may be envisaged in case there is an unfortunate combination of a population growth, on the one hand, and an increase in territories suffering from shortages of water resources, on the other. As history shows, the political instability caused by an ever growing deficit of fresh water may put into question the long-term plans of socio-economic development of entire regions and even continents.
Regions which will see climate change – caused conflicts in the next few years include territories south of Russian borders. For example, the number of territories in Central Asia, Iran, Afghanistan, and Turkey which suffer from low precipitation rises year after year. In this way, “climatic refugees” are becoming a potential threat to stability and security of the Russian Federation.
The environmental issues which are frequently overlooked by observers but which can send people fleeing comprise so-called “heatwaves” – periods of abnormally hot weather. Meanwhile, these problems are already causing “superfluous” mortality in many regions, including the developed countries. According to The Economist, the heatwave that hit Europe in 2003 killed about 70,000 people. This issue will acquire still more urgency as yearly temperatures continue to rise and urbanization proceeds at fast pace.
A dramatic increase in the number of climatic refugees can also evoke an increase in the level of the World Ocean. Under a forecast made by the Institute of Economics and Peace, coastal territories in China, Bangladesh, India, Vietnam, Indonesia and Thailand are at a particular risk over the next 30 years. Estimates presented in the Report maintain that water levels in the World Ocean may rise by more than 2 meters by 2100. As a result, territories populated by at least 200 million people will face the danger of flooding.
Cross-border migration, which was caused, among other things, by ecology-related factors, is contributing to the strengthening of “extreme” political forces. Poor nations with a growing population are particularly exposed to violence and political instability. Trends of this kind tend to lead to revision of political agenda. This means a new stage of regulating social and economic processes on the part of the state. In addition, according to Professor Rubinsky of the French Research Center of the Institute of Europe of the Russian Academy of Sciences, «mass migration is becoming a target, and at times, an instrument of the foreign policy of a whole range of countries».
Climatic changes lead to ever more cross-border and internal migration and may contribute to the strengthening of separatist movements in many regions of the world, including Europe. Disintegration of countries into smaller territorial entities stimulates conflicts and encourages intervention from foreign powers. In the long run, the natural need for expanding international cooperation for settling global problems will go hand in hand with the equally natural growth of nationalism and isolationism.
The issue of climatic refugees has been recognized at the international level. Formally, the UN Convention on the status of refugees does not embrace people who flee their homes because of the deterioration of the climate. Nevertheless, the Executive Committee of the Agency of the UN High Commissioner for Refugees has passed a decision to expand the Agency’s mandate “to include commitments regarding refugees who cannot return to their countries because of climatic changes”. UN Secretary General Antonio Guterres in person is rendering substantial assistance to the victims of environmental disasters.
However, there is no international system of a long-term assistance for refugees and migrants, including climatic, to help them move and adapt to their new place of residence. The policy of countries and territories that most climatic migrants strive for is fairly controversial. In the first place, due to the growing public discontent over “an influx of migrants” in the past decades.
“The European Union boasts one of the most elaborated systems of migration policy, which has no analogues elsewhere». One of the most remarkable achievements of the EU is the European Commission – suggested «mechanism of using an emergency trust fund to ensure stability and assistance in connection with the problem of migrants and refugees in Africa». But, as we know, this does little to solve the problems of Europe, which stem from migrants and public discontent over their growing numbers.
For this reason, it is easy to understand why some European countries refuse to support the UN Pact on Migration, which was signed in December 2018. More than two million refugees that arrived on the European continent after 2013 caused serious upheavals on the political scene of leading countries of Europe. They even put into question the mere existence of the EU in its present format. As a result, most EU countries are involved in an intense political battle with Brussels for regaining their sovereignty in regulating migration flows.
In the USA, a country which has always received millions of migrants, immigration issues had acquired so much urgency by 2016 that they became a top point on the agenda of the presidential election campaign. However, like in previous years, emotions took upper hand ousting the attempts to produce a balanced and comprehensive solution. At present, the opponents are criticizing the Trump administration for the draconian migration policy, which is depriving America of thousands of highly qualified immigrants. They point to Canada, which, they say, is much more open to migrants, though on the basis of fairly tough criteria.
Until recently, a particular approach to this issue was demonstrated by Japan, which makes considerable contributions to the funds of the Agency of the UN High Commissioner for Refugees but does not receive migrants. In recent years, public opinion has become more tolerant towards refugees and forces migrants. Tokyo has been examining the experience of Australia, which is ready to receive a large number of immigrants as long as the process is well-organized. Meanwhile, Canberra’s tough policy regarding the “illegals”, who are sent to detention camps in difficult-of-access areas in New Guinea and Nauru, вis facing ever more reprimands from the international community.
On the whole, as it appears, climatic changes which trigger degradation of the environment and socio-political conflicts will produce an ever more significant, and, at times, decisive, influence on migration processes. This, in turn, will cause political, social, economic and geopolitical problems.
Degradation of the environment leads to socio-political conflicts while military operations or long-lasting public unrest can easily inflict damage on ecosystems. There is thus a vicious circle. Given the situation, the international community will sooner or later have to focus on political, economic and social measures which could help the humanity to better adapt to the changing natural environment.
However, judging by the current state of affairs, the world’s leading countries are highly unlikely to step up their coordination on migration issue in the years to come. As the 2010s experience shows, the migration issue will be resolved by every recipient nation progressively, “one at a time”. For many ordinary voters the problem of migration “seems obvious and relevant” but they hardly know of the many aspects associated with it. For this reason, only “simple”, tactical in essence and consequences solutions, enjoy most support. The main challenge of the present-day migration will still be a search for a balance between humanistic issues and global security in the context of changes of the climate. The importance of this context is bound to increase over time.
From our partner International Affairs
Blessing In Disguise: The Lockdown-Effect On Environment
Authors: Deepanjali Jain and Prateek Khandelwal*
From one Wuhanese to over 4 million humans, the coronavirus has shackled pillars and institutions of our civilisation. The pandemic has socially distanced humans and spread fear which could be gauged from any nook and corner of the world. Though it seems, nature can finally breathe after decades, the signatures of which were visible from space.
As the factories and vehicle closed, dirty brown pollution belts shrunk over industrial centres in the country within days after lockdown. After decades of relentless exploitation, the human footprint on the earth has lightened. The persistent denial by the industrialist got an answer that climate change is real and that it is a reflection of human ‘exploitation’. The overexploitation of nature is fuelled by human greed, where consumption increases production and vice-versa. This vicious cycle depletes the natural ability of environment, which can be sensed in the lockdown months, to balance itself and so disrupts ecology.
COVID-19 is not only a pandemic; it reflects a broader trend that more planetary crisis is scheduled for upcoming years. While we muddle through each new crisis, with the current economic model, then the repercussions will eventually exceed the capacity of financial institutions to respond. Indeed, the “corona crisis” has already done so. For just climate transition, new economic reforms should have a blueprint for “planned degrowth” that emphasizes on the wellbeing of people over profit margins.
The initial move towards this is assuring the incentives that governments are announcing across the globe are not exhausted on bailing out corporations. Instead, the funds should be allocated to decentralised renewable energy production to implement the ‘Green’ New Deal and create meaningful jobs for ‘the Great Depression’ post-COVID-19. Along with this, the state should enact on the provision of social welfare such as universal healthcare and free education for all vulnerable populations.
Though set for 2025, by G7 and many European countries, elimination of perverse fossil-fuel subsidies can be done amid the recent oil-price plunge. It is the appropriate moment to deploy renewable energy technologies, which are now globally accessible without any economic barrier and phase out age-old fossil fuel.
A shift from exploitative industry setup to regenerative industries is immediately feasible. Also, it would allow us to sequester carbon emission spread by the current economic framework at a rate that is ample to reverse the ongoing climate crisis. This will have a positive impact on the environment and improve global wellbeing; also, it would turn to be an economically profit-enhancing model.
Though defined with differences and demarcated with boundaries, the planet with various species, nations, and geopolitical issues are ultimately interconnected. COVID-19 narrated that crisis does not observe national or even physical borders; the same is the case with climate change, biodiversity loss, and other environmental problem. Collective actions to curb these from becoming a full-blown crisis can only help in managing these issues. The current rescue plan for battling COVID-19 could usher these changes, as we are getting accustomed to the lifestyle and economic pattern that minimise consuming.
With the idea of sticking with this development structure, Governments can succeed in curbing the Corona epidemic. But we should move a step ahead to do a greater good for society and nature. The use of science can be moulded to construct an economy that will not mitigate the threats of climate change, biodiversity loss, pandemics and other challenges. A green economy should be laid down that has a preamble of nature-based solutions and is geared toward the public good.
Obviously, the circumstances are not ideal, but the rapid reflex actions and response to the virus of mutual aid also illustrates that human society is capable of controlling and working collectively in the face of a grave pandemic. The phase of development which humans are at, they are entrepreneurial and capable to begin again perfectly. If we learn from our failures and embrace this moment of upheaval as an opportunity to invest in shared prosperity, planetary health, and green economy, we can build a brighter future than the one we are heading towards. We have long since exceeded our natural limits; it is time to try something new.
*Prateek Khandelwal is a 2nd Year student pursuing B.B.A., LL.B. (Hons.) from Chanakya National Law University, Patna.
How video games are joining the fight to save the planet
As bush fires were raging across Australia in December 2019, players of Space Ape video games reached out to the company and asked what they could do to help. The London-based firm quickly put an in-game purchase into several of its mobile titles, with all proceeds going to either a wildlife or humanitarian charity working in the area.
In just four days the company raised $120,000.
“That just speaks to how much people want to do good,” said Deborah Mensah-Bonsu, former Head of Content at Space Ape Games, who now runs her own consultancy focused on using games for social impact.
Now, the video game industry is poised to roll up its sleeves and do even more for the planet. In August 2020, some of the biggest names in mobile gaming unveiled a series of environmentally themed missions and messages that will be integrated into popular titles, such as Angry Birds 2, Golf Clash and Subway Surfers. The additions will encourage players to do things like combat climate change or protect endangered wolves. The initiative is part of a push by the United Nations Environment Programme (UNEP) to work with game developers to raise awareness about pressing environmental issues.
“Video gaming is one of the biggest communication mediums on the planet,” says Sam Barratt, Chief of Education and Advocacy with UNEP. “We aim to support the industry to encourage gamers to be educated, inspired and activated around the wider environmental agenda, and so far it seems to be working.”
Globally, 2.6 billion people play video games and a growing number are taking an interest in the environment and conservation. A 2019 UNEP report, Playing for the Planet, found that video games could engage billions to contribute to solutions to social and environmental challenges.
The video game industry has yearly revenues of $140 billion—more than Hollywood, Bollywood and recorded music sales combined. In 2017, 666 million people watched other people play games on YouTube and Twitch – more than the combined audience of HBO, ESPN and Netflix. According to the UNEP report, channelling even a small portion of that attention and the industry’s revenues towards the planet would create tremendous impact in the real world.
Playing for the Planet
Space Ape is one of 25 members of UNEP’s Playing for the Planet Alliance, an initiative that aims to harness the power of gaming to encourage action on climate change. The project, which launched in 2019, has reached more than 970 million players. In joining the alliance, game companies make commitments, ranging from integrating green activations into games to reducing their emissions to supporting the global environmental agenda.
The alliance held a Green Game Jam earlier this year which saw 11 mobile game companies compete to add a sustainability element to one of their existing games, a so-called “green nudge.” The objectives included asking players to make personal commitments, like skipping meat on Mondays or biking to work, or designing green environments, solar panels or electric cars into games.
Space Ape, whose game Transformers: Earth Wars contains environmental themes in the original storyline, picked renewable energy. For the updated release, it brought both good and evil Transformers together to find a new technology to harvest Earth’s energy resources more sustainably.
Mensah-Bonsu says that the company also wanted to give players a call to action, so it asked them to take a pledge to switch their lightbulbs from incandescents to LEDs.
California-based Pixelberry Studios focused on climate change in its title “Choices.” The game centres on a young woman who returns to her coastal hometown where there has been a large fish die-off. The girl’s younger sister is convinced the die-off is connected to climate change, despite skepticism from local politicians and business owners. The player’s role is to help their young sister rally others and raise awareness about climate change.
Saran Walker, one of the writers at Pixelberry, said the team had read dozens of articles about younger generations experiencing anxiety around climate change. (A recent survey of millennials — 30,000 individuals under the age of 30 from 186 countries confirmed this — finding that climate change and destruction of nature were the most critical issues for them.)
“We were all really inspired by Greta Thunberg’s story,” Walker said, referring to the young Swedish environmental activist. “Anyone at the company who has kids is thinking about what kind of world are they going to leave to their children. We wanted to show people that they can actually do a lot as an individual.”
A shift in the industry
The gaming industry is also considering how it can become carbon neutral, or in some cases carbon positive – a welcome move for a sector that has been scrutinized for its environmental footprint. Currently, 50 million tons of electronic waste is generated annually, with that number projected to reach 120 million tons by 2050.
Supercell, which makes mobile titles, recently committed to going entirely carbon neutral and offsetting the carbon dioxide used by players when playing their games. Rovio and Space Ape aim to take similar action.
The Playing for the Planet Alliance will share guidance with its members on how to decarbonize, with Sony leading a working group that includes other console makers. The alliance will help devise a new carbon calculator for the industry, develop fresh guidance on offsetting and forge new collective commitments around the restoration of forest landscapes, which help absorb carbon emissions.
“When we set out on this journey we wanted to help others in the industry too,” said Mensah-Bonsu. “If we all do our part, we can make a change in the world.”
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