The Biofuels Renewable Fuel Standard at a Crossroads

    November 18, 2013 12:52 PM by Wallace E. Tyner - James and Lois Ackerman Professor, Purdue University

                In previous posts [1, 2], I have discussed different aspects of the evolving biofuels Renewable Fuel Standard (RFS) in the U.S. In particular, In the August post, I characterized what the 2014 RFS numbers might look like if EPA followed through with their stated intention in the 2013 Final RFS ruling [3]. On November 15, 2013, EPA issued a proposal for the 2014 RFS levels [4].  In that proposal, EPA went even further than I had suspected and proposed reducing the total RFS volume from 18.15 to 15.21 billion gallons. In the proposal, EPA reconfirmed its commitment to biofuels and the role they can play in reducing greenhouse gas (GHG) emissions and oil imports.  EPA also indicated it was balancing that commitment with the realities of lack of progress in cellulosic biofuels and the blend wall.  In addition, for the first time EPA provided not only proposed point values but also a range of possible values and requested comments on the proposal.

                Table 1 provides the actual legislated RFS levels for 2014, the levels in the EPA November 15 proposal, the numbers I used in my previous posting, and a new set of possible values I am suggesting based on changes that have occurred since August 2013. The way the RFS works, the value in Table 1 for corn ethanol is the difference between the total RFS and advanced biofuel.  There is no RFS for corn ethanol; it’s just that this difference represents the amount that can be filled by corn ethanol. Thus, for example, with the numbers from the legislation [5] for 2014, overall is 18.15, advanced is 3.75, so corn ethanol is 14.40. The row I have named other advanced is the advanced (3.75) minus biodiesel multiplied by 1.5 to get ethanol equivalent (1.5) and minus cellulosic (1.75), which equals 0.50 in the original RFS.  The other advanced category can be met with cellulosic, biodiesel, or other biofuels classified as advanced such as sugarcane ethanol from Brazil and other countries.  The same calculations apply for the other columns.

                EPA proposes reducing the total RFS by 2.94 billion gallons (BG); I proposed in August a reduction of 2.3 BG; and now that is reduced to 1.75 BG – the level of the cellulosic RFS. EPA proposed reducing the advanced category by 1.55 BG: previously I proposed 1.70 BG, and now the value is 1.25 BG.  Therefore, EPA proposes reducing the corn ethanol level by 1.39 BG; my previous reduction was 0.60 BG, and now it is 0.50 BG.

    Table 1. Alternatives for the 2014 RFS (billion gallons)

                Now let me explain the differences.  The two big drivers of the reduction are the lack of technical progress and investment in cellulosic biofuels and the blend wall. Despite the grand hopes in 2007 when the RFS passed Congress, and despite the investments in research and development that have occurred, there is little production of cellulosic biofuels today. Thus essentially all the cellulosic category must be waived because the product simply does not exist.  In fact, the EPA approach has been to estimate how much production is likely to exist in the following year and to set the cellulosic RFS at that level.  Build it, and they will come!  The EPA estimate for cellulosic availability for 2014 is 17 million gallons with a range of 8-30 million gallons.

                The other issue is the blend wall. At present, the U.S. consumes about 133 BG per year of gasoline type fuel, down from 141 BG in 2007, the year the RFS legislation was passed. The reduction has occurred because of the recession and because of the increasing fuel economy of the automobile fleet.  With annual consumption of 133 BG, the maximum ethanol that can be blended at 10% is 13.3 BG.  EPA apparently believes that the realistic maximum is less than that, since they set the proposed level at 13 BG. They apparently did not include any E15 or E85 in their calculation.  E85 can only be used in flex fuel vehicles, of which there are about 12 million on the road today.  There is also limited fuel dispensing infrastructure for E85 and E15.

                So what is behind the differences in both my suggested values and the EPA proposal?  The biggest difference in my original post and EPA is in the level of the corn ethanol mandate.  EPA put the level significantly below the blend wall and made no account of possible growth of E85.  I think it is a mistake to put the RFS that low.  When Congress passes a mandate, they expect it to pull the mandated product into the market.  Otherwise, they would not pass a mandate. It is important to have the corn ethanol mandate high enough to provide an incentive for companies to blend and sell more E85. With the price difference between gasoline and ethanol (today 80 cents/gallon) and the price of RINs, there is an incentive to blend and sell more E85.  Setting the RFS at 13 BG would destroy that incentive.  It would not pull any additional ethanol into the market.  Also, we have a production capacity of corn ethanol of around 14.7 BG, so there is no capacity issue.  Of course the “pull” cannot be so strong that it is totally unrealistic. That is why I am suggesting something a bit less than the original RFS. This level should expand use of ethanol somewhat without increasing corn prices significantly. So what if enough E85 was not sold? In the near term, it is not a problem. There are carry forward RINs from previous years that can be used in 2014 and 2015.

                What has happened since August to cause me to somewhat modify my proposed numbers?  First, the gap between wholesale gasoline and ethanol has widened significantly.  The price of E85 has started to fall.  It is important to maintain an incentive to pull more ethanol into E85 blends.  Second, biodiesel production in 2013 is likely to exceed 1.6 BG, so it is not clear we need to maintain the 2014 biodiesel target at 1.28 BG, so I increased it to 1.5 BG in these numbers.  Finally, the basic change since the RFS was passed is that we have not achieved the cellulosic biofuels production desired.  Thus, it makes sense to reduce the RFS by no more than the level of the cellulosic category – 1.75 BG in 2014.

                My current proposal is for a 2014 RFS total of 16.4 BG with 13.9 BG of that allowed to be corn ethanol.  I think something in that area does a better job of fulfilling the original intent of Congress in the RFS, but adjusted for current market and technology realities.  While any numbers at this point involve a good bit of judgment, and there is no magic to any particular set of values, I do think the current proposal reflects a good balance between the original intent of the legislation and current conditions.

    References:

    1. Tyner, W.E. The Biofuels Renewable Fuel Standard - EPA to the Rescue. August 12, 2013; Available from: http://www.pennenergy.com/index/blogs/energy-and-environmental-economics/2013/08/the_biofuels_renewab.html.
    2. Tyner, W.E. The Ethanol Blend Wall and the Renewable Fuel Standard. June 13, 2013; Available from: http://www.pennenergy.com/index/blogs/energy-and-environmental-economics/2013/06/the_ethanol_blendwa.html.
    3. Environmental Protection Agency, EPA Finalizes 2013 Renewable Fuel Standards. August 6, 2013: Washington, D.C.
    4. Environmental Protection Agency. EPA Proposes 2014 Renewable Fuel Standards. November 15, 2013; Available from: http://yosemite.epa.gov/opa/admpress.nsf/d0cf6618525a9efb85257359003fb69d/81c99e6d27c730c485257c24005eecb0!opendocument.
    5. U.S. Congress, Energy Independence and Security Act of 2007, in H.R. 6, 110 Congress, 1st session. 2007.

     

    Time to Reconsider a Carbon Tax?

    October 15, 2013 3:45 PM by Wallace E. Tyner - James and Lois Ackerman Professor, Purdue University

                It may seem strange to be suggesting reconsideration of a carbon tax amidst the inability of Congress to do anything these days.  However, as I will argue below, a carbon tax might just be what the doctor ordered to help us move forward with some very important issues.

                First, with the new IPCC report it is abundantly clear that global warming and climate change represent a clear and present danger not only to the US but for the entire planet.  The only way we can prevent substantial increases is global temperature is to reduce our carbon emissions.  That is exactly what a carbon tax is designed to do. Yes, it would not have a huge impact if the US were over the longer term the only country to do it. However, the US is the world’s leader, and if we were to implement a carbon tax, there might well be considerable following by other countries around the world. Most economists would argue that a carbon tax is the most effective policy measure to reduce carbon emissions.  It basically provides an economic incentive for all actors in the economy to change the basket of goods and services consumed and produced to become less carbon intensive.

                A carbon tax would raise lots of revenue for the government.  A 2009 study by the Congressional Budget Office estimated that a tax equivalent to $28 per ton of carbon dioxide would raise about $104.7 billion per year [1, 2].  In this note, I will use a round figure of $30/ton, so that CBO figure translates to $112 billion/year. 

    Of course, there is no way a tax increase of that magnitude would fly in today’s environment unless it were clear that it would not be used to increase the size of government.  What I suggest in this note is a carbon tax 50-50.  That is, 50% of the revenue would be used to keep whole the lowest three quintiles (lowest 60%) of households. In other words, those households would receive income transfers of one sort or another to completely offset the inflationary costs of the carbon tax.  Only the highest 40% would see any adverse impacts of the carbon tax.  The other 50% of the revenues would be used to begin reducing the federal debt. Assuming the CBO adjusted figure of $112 billion/year, we would be reducing the federal debt by $56 billion/year.  That is a substantial step towards getting our federal books on a more sound financial footing.

    Now let me provide a few more details on how this might work. Dinan, in a November 2012 CBO paper suggests there are seven approaches one could take to achieving the income transfers to the lower segments of the population [2].  These include reduced income tax rates, income tax rebates (as was done in 2008), earned income tax credits, payroll tax rebates, and additional payments to SNAP recipients.  Each of these options has pros and cons, but the point is that a well-targeted program could be designed to provide effective income transfers to keep the lower 60% of our citizens from being adversely affected by the carbon tax.  In addition, the automatic indexing of social security payments and SNAP benefits would also provide a buffer for lower income households.

    What would this cost? CBO estimates that it would take 11, 14, and 17 percent of the carbon tax revenue respectively for the lowest 20%, second 20%, and middle 20% of households.  In other words, 42% or $47 billion of the carbon tax revenue would be needed to keep whole the lower 60% of the population.  Let’s assume that there would be added cost for social security and SNAP and administration that would bring the total cost up to 50% or $56 billion.  That means we would have the other half to use for lowering the US debt.

    This program could be implemented gradually so that all actors in the economy would have plenty of time to plan ahead and adjust their investment and consumption decisions.  For example, we could start with a 10% carbon tax for 5 years, then 20% for the next 5 years, and after 10 years reach the target level of 30%.

    So why might this proposal be attractive?  First, clearly we need to take action to reduce carbon emissions.  Anyone who understands the science agrees with this, and a carbon tax is the most effective way to do it.  It is a market based solution to global warming. Second, the most conservative elements in Congress are adamant that we need to take action to reduce the national debt, and this approach would do that.  Third, this approach would not harm the most vulnerable in our society, so it could be attractive to politicians and others who are deeply concerned about US poverty.

    So what this proposal amounts to is a tax increase of which half would become a rebate to the lower 60% of our citizens to keep them whole, and the other half would be used to reduce the deficit.  The carbon tax would provide market based incentives for all of us to reduce our carbon footprint and our carbon emissions. It would provide a model for other countries to follow.  And it would not increase the size of government.  What’s not to like?

    References

    1. Congressional Budget Office, The Estimated Costs to Households from the Cap-and-Trade Provisions of H.R. 2454. 2009: Washington, D.C.

    2. Dinan, T., Offsetting a Carbon Tax's Costs on Low-Income Households, C.B.O. Microeconomic Studies Division, Editor. 2012.

    The Biofuels Renewable Fuel Standard – EPA to the Rescue

    August 12, 2013 12:38 PM by Wallace E. Tyner - James and Lois Ackerman Professor, Purdue University

    The Renewable Fuel Standard (RFS) has become controversial this year because for the first time it will be difficult to meet the required RFS levels. The oil industry and other lobby groups have argued that the RFS should be scrapped, while the pro-biofuels lobby has argued that it is working and can be made to function as it was intended. The RFS is administered through Renewable Fuel Identification Numbers (RINs), which all obligated parties are required to submit to EPA at the end of each year. All biofuels produced domestically or imported come with a RIN. Obligated parties just accumulate RINs as they blend during the year, and turn in their requirement at the end of the year. RINs are tradable, so if a company has too few or too many RINs, it can go to the market and buy or sell RINs.  In addition, RINs can be carried forward from one year to the next if there are excess RINs. For corn ethanol, the RIN price prior to 2013 has generally been less than 5 cents per gallon. This low price indicated that the RFS really was not binding.  However, in the first quarter of 2013, corn ethanol RINs shot up to over $1 per gallon signaling that the RFS together with the blend wall are now binding.

    On August 6 the Environmental Protection Agency issued their final ruling for the 2013 RFS [1, 2]. In addition to providing all the final RFS levels for 2013, it also provided an indication that for 2014 and perhaps beyond, EPA intends to accept the reality that it will be difficult to meet the RFS levels that increase each year through 2022:

    Given these challenges, EPA anticipates that in the 2014 proposed rule, we will propose adjustments to the 2014 volume requirements, including to both the advanced biofuel and total renewable fuel categories. We expect that in preparing the 2014 proposed rule, we will estimate the available supply of cellulosic and advanced biofuel, assess the E10 blend wall and current infrastructure and market-based limitations to the consumption of ethanol in gasoline-ethanol blends above E10, and then propose to establish volume requirements that are reasonably attainable in light of these considerations and others as appropriate. [2]

    Essentially what this implies is that EPA intends to reduce the overall RFS and the advanced RFS by the amount of reduction in the cellulosic component.  So far, EPA has been forced to reduce the cellulosic mandate every year because the biofuel was not available.  However, in reducing the cellulosic mandate, they have maintained the overall mandate at its original level. What this means is that the shortfall in cellulosic biofuels must be made up from other advance biofuels such as sugarcane ethanol or biodiesel.  However, today with the ethanol blend wall, biodiesel RINs are needed to meet the shortfall in ethanol, so it became pretty clear that moving forward, the RFS was not workable.  The above paragraph also signals that EPA will take into account the ethanol blend wall in setting the RFS levels for 2014 and beyond.  The RFS problem is illustrated in Table 1. The table provides numbers for 2014-16. The first row provides the overall RFS, which in the past EPA has maintained even when it reduced the cellulosic mandate. Rows 2 and 3 provide the conventional total and the level of the blend wall (13.3 bil. gal.). The next row provides my assumption on the amount of carry-forward RINs that will be available for 2014. If prior practice were maintained, all the carry-forward RINs would be needed in 2014, and none would be available for 2015 and beyond. The sugarcane row provides my assumptions on sugarcane ethanol imports, and these levels are much higher than recent history. The corn ethanol row is the blend wall minus sugarcane ethanol imports.  The next two rows provide biodiesel RINs and assumed biodiesel production. The assumed biodiesel production is much higher than current, which is about 1.3 bil. gal. Biodiesel has 1.5 times the energy content of ethanol so each gallon gets 1.5 RINs. Next are the advanced RFS mandate and the advanced supplied (sugarcane ethanol plus biodiesel RINs). The final row provides the total RINs generated under these assumptions.  For 2014, with pretty extreme assumptions on sugarcane ethanol imports plus biodiesel production and using all carryforward RINs, it is barely possible to meet the RFS.  In 2015 and 2016, we cannot even come close to meeting the RFS (row 1).  Table 1 illustrates the problem and the reasons EPA was compelled to act.

    Table 2 contains numbers assuming that EPA reduces the overall mandate in two ways. First, they reduce it by the amount of reduction in the cellulosic mandate. Second, they reduce it taking into account the blend wall. The structure of Table 2 is similar to Table 1, but with four added rows. The first added row is labeled revised conventional, which represents an assumption of what EPA might view as a realistic assumption on the blend wall.  I have set the level higher than the current blend wall assuming EPA would want to encourage more blending of E85, which is quite limited at present. The next added row is actual cellulose, which represents assumptions on what EPA might deem to be the cellulosic biofuels available in 2014-16.  The values given are just assumptions, but are probably pretty close to what will transpire. The third added row is revised overall total. It is equal to the original RFS total minus the cellulose mandate plus the actual cellulose minus the difference between the conventional RFS and the revised conventional. Using this approach, the revised total in 2016 is almost 5 bil. gal. lower than the original total. The last row added is revised advanced, which is equal to the advanced RFS minus the cellulosic mandate plus the actual cellulose. The bottom line is that with these changes in the RFS, the targets can be met with reasonable assumptions on the corn ethanol blend wall, sugarcane ethanol, and biodiesel production.

    All we have from EPA on what they intend to do for 2014 and beyond is in the text quoted above.  The devil is in the details. However, it is clear that if EPA does what is implied in the text, the RFS moves from being unworkable to quite manageable.  Thus, EPA has taken a preemptive strike to make the RFS continue to work in promoting renewable fuels without imposing undue costs on producers or consumers.

     

    1. Environmental Protection Agency, EPA Finalizes 2013 Renewable Fuel Standards. August 6, 2013: Washington, D.C.

    2. Environmental Protection Agency, 40 CFR Part 80, Regulation of Fuels and Fuel Additives: 2013 Renewable Fuel Standards. August 6, 2013: Washington, D.C.

    The Ethanol Blend Wall and the Renewable Fuel Standard

    June 13, 2013 2:29 PM by Dr. Wallace E. Tyner

    The US has a Renewable Fuel Standard (RFS) that mandates blending a certain quantity of different types of biofuels growing to 36 billion gallons of ethanol equivalent by 2022.  The overall biofuels mandate is depicted in the Figure below.  As can be seen, it grows over time to the 36 billion gallons ethanol equivalent.

    The largest part of the RFS is 16 billion gallons ethanol equivalent of cellulosic biofuels by 2022.  However, since the technology has not developed as rapidly as hoped, the Environment Protection Agency (EPA) has had to waive most of the cellulosic component of the RFS each year.  In fact, the cellulosic RFS grows so fast from here to 2022 that it would be impossible for plant construction to keep up with the ramping up of the RFS, so EPA will be forced to waive much of the cellulosic component every year.

                Biodiesel is currently 1.28 billion gallons per year, and the industry hopes to grow that number over time.  The original target was 1 billion gallons, and there is no blending barrier for biodiesel.

                Another category is called other advanced biofuels, and it can be met with sugarcane ethanol (imported), biodiesel, or cellulosic biofuels.  Since cellulosic is not available, only sugarcane ethanol and biodiesel count. Together, they are able to meet the mandate level for this category, at least at the present time.

                Corn ethanol is classified as conventional biofuel, and can only be used for that category.  In fact, there is no explicit mandate for corn ethanol, but it can be used in the conventional category as can biodiesel, sugarcane ethanol, and cellulosic biofuel.   Since corn ethanol is less expensive than these other options, it is the fuel of choice to meet that category mandate to the extent it is available.

    The Blend Wall

                Herein lies the problem.  In the US, most ethanol is consumed as a 10% blend of ethanol and gasoline.  There is a very small amount of E85 (currently a bit over 100 million gallons) and an inconsequential amount of E15. Thus, most of the ethanol (around 13 billion gallons) is consumed as E10. Currently, the US consumes about 133 billion gallons of gasoline type fuel including 10% ethanol. That means that the absolute physical limit on the amount that can be blended and consumed is 13.3 billion gallons. DOE forecasts that gasoline consumption will actually continue to decline, as it has since 2007.  Thus 13.3 is the maximum ethanol, and it will fall over time a bit.

                However, the RFS for 2013 is 13.8 billion gallons, and it increases to 15 billion in 2015. Thus the minimum under the RFS is greater than the maximum with the blend wall.  Something has to give.

                RIN stands for Renewable Fuel Identification Number, and it is the way EPA keeps track of compliance with the RFS.  At the end of the year, obligated parties must provide EPA enough RINs to demonstrate compliance with their obligation. This blend wall problem has caused the price of RINs to skyrocket in 2013 (see the figure below).  Basically the reason is that the conventional category can be filled with either ethanol or with biodiesel or other advanced.  So the ethanol RIN price now approaches the RIN prices of those categories, which have been high for some time.

                So the question is what can be done to solve the contradiction between the RFS and the blend wall.  Some in Congress have proposed drastic changes to the RFS or even abandoning the RFS.  Some have proposed freezing the RFS so that it does not grow in future years as planned.  Others have proposed requiring that the RFS be filled only with domestically produced fuels.  Each of these proposals has problems.

                One option that could come from the market would be greater use of E85.  There has been very low penetration of E85 in the marketplace because it currently is not priced competitively on an energy basis with E10, and consumers’ fuel economy is a function of the energy content of the fuel they use.  In addition, there are only about 2,600 service stations out of 161,000 in the country that sell E85.  DOE estimates that there are 11.5 million flex fuel vehicles in 2013.  However, they also estimate that only about 10% of them use E85 with the rest using E10.  Even worse, if one looks at the ethanol consumption as E85 (about 113 million gallons/year), and factors in mileage, miles driven, number of flex fuel vehicles, one can back out that less than 3% of the potential E85 is actually consumed as such.

                So how could E85 consumption grow? With the RIN price in early June at 95 cents/gallon, there is an incentive for companies to attempt to sell more E85 to get more RINs. Excess RINs can be sold in the RIN market.  So in essence, an E85 vendor gets the price of the blended fuel plus the value of the RINs embedded in the fuel.  E85 is actually 74% ethanol on a year round basis, so 10 gallons of E85 would contain 7.4 gallons of ethanol with a RIN value of $7, which is in addition to the revenue from the fuel.  To entice consumers to buy E85 instead of E10, the breakeven pump price can be no more than 75% of the E10 pump price.  Without the RINs, it cannot happen.  However, by our calculations, with the additional revenue from RINs, companies could afford to sell E85 for less than 75% of E10 and still make a good profit.

                So how much difference could this make.  Let’s suppose that fuel consumption of the 11.5 flex fuel vehicles could move from 3% of potential to 30%, a large increase, but perhaps not impossible.  By our calculations, if this were to happen 1.3 billion gallons of ethanol could be sold as E85 – enough to surpass the blend wall and meet the RFS in 2013 and 2014.  In fact, if E85 sales could continue to grow, the 2015 RFS could be met, and it does not grow after that.  Admittedly, this is a huge change in a very short period.  But it is not completely beyond the pale.

                One important caveat.  As E85 consumption grew, and it became apparent that the RFS could be met, the ethanol RIN price likely would fall. The most likely outcome is that it would fall to breakeven for E85, but one cannot be sure.  This story will unfold over the months to come.

    Wallace E. Tyner
    Purdue University

    The views expressed here are my personal views and do not represent policy or views of Purdue University.

    Caution is in Order in Approving Large Levels of LNG Exports

    May 9, 2013 3:24 PM by Dr. Wallace E. Tyner

    In this blog, I will periodically post thoughts and analysis on a wide range of energy and environmental policy issues.  I am an energy economist and James and Lois Ackerman Professor at Purdue University.  I will be writing on biofuels, natural gas, solar energy, overall energy policy, and in general a wide range on energy and environmental policy topics.  I look forward to interacting with readers of this blog.

    This first post is on the issue of whether or to what extent we should export our currently abundant supplies of natural gas.  Natural gas can be converted to a liquid (LNG) and shipped around the world. It is a hot topic with the oil industry anxious to export the gas, and natural gas consumers wanting to limit exports to avoid large natural gas price increases.  I report on the conclusions of a recent study we completed.

    In many cases, free trade is in our nation’s interest.  In fact, economic theory suggests that globally free trade always results in a net global gain.  However, there is nothing in economic theory that indicates that all countries gain from free trade in all cases. One has to examine the evidence in each case.  Our examination of the evidence in the case of high levels (higher than 6 billion cubic feet per day (BCF/day)) of LNG exports suggests that caution is in order.

    Our results suggest that high natural gas export levels could result in domestic natural gas price increases of 40% or more, which, in turn, would increase costs for all energy intensive industries and for electricity. These higher costs would reverberate throughout the economy resulting in reduced economic activity.  Part of the reason for our manufacturing resurgence is low cost energy, and 40% higher natural gas prices could put that in jeopardy. The higher natural gas costs also would deter conversion of electric generation from coal to natural gas and also would deter conversion of parts of the transportation fleet to compressed natural gas (CNG).  These two impacts would result in higher greenhouse gas and particulate emissions in the US if we export more LNG.

    Our analysis suggests that electricity prices would increase, energy intensive manufacturing would be less advantageous and there would be less use of natural gas in the transportation sector if we export more natural gas.  Our analysis also suggests that there would be a small decline in national income due to these effects on consumers, electricity, manufacturing, and transportation.

    In addition, there are dynamic effects not considered completely in this analysis.  When the US exports LNG, energy prices fall for importing countries, and in this case, the most likely importing countries are those with whom we compete in international markets.  At the same time energy costs fall for our competitors, they increase for our own industry.  Thus, our energy intensive manufacturing sectors are rendered less competitive in the global economy.

    Finally, some have argued that it does not matter how much LNG exports DOE approves because the market will limit the actual level to a low quantity.  However, DOE approval of high levels of exports would hang over the market and create a deterrent to investors, who would depend on less expensive natural gas for their potential investment to be economically attractive.  Less transportation fleets would be converted to CNG, less electric power plants converted to natural gas, etc.  Thus, in our view, the Department of Energy should approach LNG export approvals with caution.

    Wallace E. Tyner
    Purdue University

    The views expressed here are my personal views and do not represent policy or views of Purdue University.

     

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