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Consultation on Inshore Netting Byelaw proposals.
Please note: additional link added in text below on 15-10-18 & broken link corrected on 26-10-18 plus drop in sessions added.
Southern IFCA has commenced consulting on possible changes & additions to its regulations regarding fixed netting inshore. Of particular note is a proposed exclusion zone round popular angling Piers as well as an almost total ban within the River Medina.
This is probably a once-in-a-lifetime opportunity to get some inshore fixed netting controlled round the IW so it s vital that as many anglers as possible send in responses in support of the proposals.
Drop-in sessions (all welcome) are being held on the Island as follows:-
15-11-18: Yarmouth Sailing Club between 3pm & 7pm
28-11-18: Bembridge Angling Club between 3pm & 7pm
 
The Angling Trust highly recommends supporting the option of a 47cm minimum size for commercial landings of all species of grey mullet since not only would this afford protection for them but the use of appropriate net mesh size would avoid the supposed "accidental" capture of undersized bass.
 
We also suggest supporting the recommendation made by the SIFCA angling liaison group (Alan Deeming is a member) that the suggested 100m exclusion zone round piers be extended to 200m.
We would also suggest that responses include a comment that ring netting should not be excluded from the regulations as is currently being suggested by SIFCA in a number of areas.
In order to assist with formulating responses, a suggested form of responses is included below (after the SIFCA notification) from which you are welcome to use whatever you wish.
 
The following received from SIFCA:-

I am writing to inform you that Southern IFCA is undertaking a review of net fishing management arrangements for estuary, harbour and pier areas in the district. It is the Authority’s objective to review and, if necessary, develop netting regulations to:

  1. Support the use of estuaries and harbours by bass and other fish populations as nursery and refuge areas;
  2. Provide protection to migratory fish species as they transit through our estuaries and harbours; and, within these areas

iii.    Balance the social and economic benefits and different needs of users in exploiting the fishery.

At this stage we are undertaking an eight-week public consultation to seek your views on a series of proposed measures. The closing date for this consultation is Friday 7th December 2018. The consultation document, supporting evidence and background papers are available on the Authority’s website from these links (apologies but the previous link to the consultation document was broken due to a SIFCA update):-

 consultation document PLUS  Supporting Evidence 

or hard copies can be obtained from the Southern IFCA office. The website also includes further information on opportunities to engage through one-on-one meetings or stakeholder drop-in sessions.

Through this consultation we would especially like to receive your views and any additional evidence relating to our proposals for:

  • ·        changes to the way that net use is managed in harbour and estuarine areas;
  • ·        new net prohibition zones around pier structures;
  • ·        an increase in the minimum legal size for grey mullet species; and
  • ·        a series of defining principles for ring net use.

This consultation process will inform the development of any future management, it is therefore important that you provide evidence-based feedback in your response. Upon the conclusion of this consultation a summary of the responses received will be published on the Authority’s website, together with any further developments as part of this review, including information about any further public consultation. Following a review of this and any further evidence the Authority will consider whether regulation by way of byelaw is necessary and justified. If a byelaw is made, prior to confirmation, it will subject to a formal consultation and stakeholders will have an opportunity at this stage to make representations. The byelaw will only come into force following confirmation by the Secretary of State. Details of this process may be found http://www.association-ifca.org.uk/Upload/About/ifca-byelaw-guidance.pdf

Thank you for taking the time to engage in this important process.

Simon Pengelly

 

Suggested Response to SIFCA public consultation regarding:

Net Fishing Management for Estuaries, Harbours and Piers in Dorset, Hampshire and the Isle of Wight

Name: INSERT

Contact details: INSERT

Interest in the net fishing: Recreational Angling sector

If applicable what is the name of your organisation? INSERT

What is your role in the organisation? INSERT

Would you like your response to be confidential? NO

My Preface: These proposals are highly welcomed since inshore netting has long been a source of major concern to Recreational Sea Anglers (RSAs). Responses are based on the premise that any regulations must be capable of being enforced both effectively and, most importantly, affordably.

Net Management Areas

Please refer to Section 2.1, Maps 1-10 and Annex I

Question 1: Do you agree with the proposed harbour and estuarine net management areas measures for the Southern IFCA district? Please provide a rationale.

 

My responses regarding spatial issues are based solely on the knowledge I have of the Isle of Wight coastal waters & I am not competent to comment on mainland coastal waters.

Yes, I fully support the proposed areas but would wish to add the following:-

A) There should be no concession for allowing ring netting within Area 16 the River Medina restricted zone. (Or any other area forming part of this consultation.) This area is a prime candidate for becoming a new BNA so having a total ban would assist in the much needed conservation of Bass. It would also pre-empt any pretence of targeting Mullet when the intended target is actually Bass (claimed as an unavoidable by-catch.)

B) On page numbered 31 (at time of writing this response) of the separate “Supporting Evidence” document, under Area 15 Wooton Creek  rationale, you include a note " The site offers shoreline access points for recreational sea angling and forms and offers important opportunities for this past-time to be enjoyed by local users."

You do not, however include any such reference for the Area 16 River Medina.

The River Medina downstream from Newport is by far the most important river on the Island for shore angling & offers several magnitudes more access spots than does Wooton Creek where the foreshore is almost entirely private property.

Wooton Creek sees just a few individual shore anglers (mainly adjacent the road bridge) whereas the River Medina regularly hosts (autumn/winter) shore angling competitions with approaching 100 participants with historical levels far in excess of that prior to the decline of the flounder population. The socio-economic benefits of an increased fish (species of interest to RSAs) population would be considerable. (See next item C )

C) Area 16: Medina River including Cowes Harbour is the largest estuary on the IW with reasonably deep water at high tide. Very restricted shore access to deep water in the area of the main harbour (except East Cowes promenade). The upper stretches of the river between Kingston & Newport used to be prolific flounder angling areas for both shore & dinghy anglers. In addition, several “recreational” dinghies regularly used to set fixed nets across the upper reaches of the estuary (often in the vicinity of what is now Island Harbour). Catches of up to 30 flounder per angling dinghy & up to 10 flounder per shore angler were not uncommon. Catches by the netters were extremely high. Regular winter flounder shore angling competitions held in the river would attract 100 plus anglers with a good proportion actually catching (and returning a high proportion alive). Over the past 10 years or more, the flounder population has crashed in line with national trends. It was reported in the winter of 2017 that a similar angling competition with an exceptional entry (by then) of 90 failed to produce a single flounder & other similar competitions over recent years have resulted in hardly any being caught. Virtually no dinghy angling is now being observed within the river & shore angling is a fraction of what it was with anglers now mainly targeting bass & occasional mullet. A detailed estimate of the annual number of shore angling trips in the Medina was done in 2010 & that probably represented a situation when the flounder fishing had already started to deteriorate. It came up with a figure of 1570 angler shore trips per annum. Using the figure of £25 per shore trip (SA2012 rounded up for inflation) gives an historical shore angling spend of £39,250.00pa. This does not include the additional spends relating to the then dinghy angling activity. It is clearly impossible to determine what proportion of the reduction in angling due to loss of flounder is related to netting so I will not attempt to do so. It is probably fair to estimate that RSA in the river is currently 50% or more down on the 2010 level representing a reduction in spend of c£19,000.00pa.

 On occasions, small unidentified vessels have been observed laying fairly short (less than 100m) fixed nets adjacent to the shore between the Folly Inn & the power station (often at 45 degrees to shore) presumably targeting bass & mullet. It is quite possible that netting activity also occurs under cover of darkness due to the lack of any residences overlooking most of the river. If the river was to be designated as a BNA then it would be necessary to prohibit all netting within it since otherwise there would be no way of preventing bass from being caught in nets claimed to be targeting mullet. The river does not support any population of sandeels so no concession would be needed for netting them.

 

Question 2: In areas where a minimum headline depth restriction of 3 metres has been proposed (Southampton Water and Lyme Bay), do you feel that the risk to salmonid interception will be suitably mitigated? If no, can you suggest an alternative approach?

Yes to a degree but reports from various IFCAs indicate that it has often proved impossible to gain a conviction for contravention of this restriction due to the evidence of total water depth as varied by tidal states & headline depth has been successfully challenged.

The objective would be much better achieved by the addition of exclusion zones whose boundaries were set based on a particular chart depth contour which is selected so as to be the 3m headline depth plus an agreed maximum net depth. (This assumes that all charts show depths at mean LW at spring tide.) A possible example of how this could be calculated (all figures hypothetical) is:-

Regulation headline depth   =  3m

Agreed maximum net depth (totally free hanging) = 6m

Thus minimum depth contour line = 3+6 = 9m with nearest higher on charts normally = 10m

Question 3: Do you agree with the proposed pier net management areas measures for the Southern IFCA district? Please provide a rationale.

Yes but exclusion zone distance should be extended from 100m to 200m where only 100m is currently proposed. By way of example, anglers fishing Sandown Pier can easily cast 100m or more as there are no restrictions on casting method. 200m would provide a suitable buffer zone.

Sandown bay (beach & intertidal) consists almost entirely of fine sand resulting in the towns of Sandown & Shanklin being the principle holiday destinations on the IW with many hotels etc located there. Access to the beach is easy throughout & the intertidal area normally slopes gently. The one remaining pier at Sandown provides an ideal venue for angling at its outer most end & an angling club is based there.

Going back a couple of decades, the beaches at Yaverland & Shanklin were very popular with anglers once the holiday makers had left for the day. The Piers at Shanklin (now gone) & Sandown were also extremely popular angling venues with Plaice & Rays popular species as well as Mackerel, Garfish & Bass.

As the proliferation of fixed nets deployed in the bay increased so the catch rate of anglers dwindled to the extent that it became almost impossible to make any decent catches from the shore & pier. Contrary to information supplied to SIFCA by some local commercial boats, actual observations by RSAs in the bay indicate that fixed nets are being deployed close to shore along virtually the entire length of the bay with the area from Lake eastwards, including round the pier, being particularly highly saturated. To emphasise the negative effect of the nets on RSA catches, during recent seasons there have been short periods (of a week or two) when conditions have prevented the nets being deployed & anglers have reported massive improvements in their catch rate during these periods.

There is lots of anecdotal evidence to indicate that, prior to the increased netting reducing beach angling catches, lots of mainland anglers would book family holidays here so that their families could enjoy the facilities during the day whilst allowing the angler to fish. Now that there is a perception among potential holidaying RSAs that there is little prospect of success for such anglers, it is plain that they are going elsewhere to the detriment of the local tourist trade. Obviously with the exceptional weather experienced this year (2018) there is likely to have been minimal, if any, negative economic impact on the local economy from this loss but it is highly likely to be more significant in normal years. Local anglers do, of course have the option to fish elsewhere on the island but there is still a negative economic impact on them due to increased travel costs.

The evidence incorporated in the data base for the South Marine Plan indicates an estimate of 3410 pier & shore angling trips per annum within this area as of 2010. The average spend per shore trip per the governments own figures (SA2012) is £24 so for simplicity & allowing for inflation say that is now £25 which would equate to a annual pier & shore RSA related spend within this area of £82,250.00 pa as of 2010. Since then there has been a significant reduction in pier & shore angling here but specific details are not available within the short time frame available. This reduction in pier & shore angling is thought to be at least 25% which would result in a £20,560.00 pa reduction in spend making something like £164,000.00 reduction since 2010. Of that probably 30% would relate to RSA activity on the pier.

Adding the exclusion zone round the pier should eventually result in increased RSA catches from it thus increasing its attractiveness to potential holidaymakers as well as local RSAs

Definition of Ring Net Use

Please refer to Section 2.2

Question 4: Do you agree with the principles for the definition of ring net use? Please provide a rationale.

Have no detailed knowledge of this system but on-line information suggests that ring netting is confined to operation by vessels in open water, not shore based deployment which I am advised constitutes a straightforward seine net.

The permitted depth of net at 6m gives rise to concern that, despite only allowing a single weight to aid shooting, the use of a leaded foot rope could cause significant damage to sea bed features when such a net is deployed in water depths of 6m or less. Even without a leaded foot rope, there is the danger of bottom damage resulting from the retrieval of the net especially if deployed from shore.

If the shore deployment definition is to be retained then one clerical comment is that the last point “.....shall then be drawn back into the vessel without ....” should read ““.....shall then be drawn back into the vessel, or shore when deployed from shore, without ....”

Given the allowed maximum size of net, & the catching efficiency of mono nets,  allowing deployment in estuaries cannot be considered compatible with a desire to maintain refuge & nursery areas and/or conservation of Bass & Mullet. They would also pose a danger to Shad which are known to migrate through local mainland rivers & which are subject to their own protection regulations due to their endangered status. Due to being very delicate, they are very vulnerable to even being handled so being caught in (& released from) these nets is highly undesirable. In light of the various risks described above, I totally disagree with including any concession to allow the use of ring nets in any of the proposed controlled areas.

Looking at the socio-economic issues & the assertion that ring netting is primarily for mullet:

MMO landings data for grey mullet into ports in the SIFCA area indicate a gross landing value of £85K of which £50K was landed in Poole. Those landings included captures by all methods but the majority are listed as by fixed or drift nets. Even if the majority of landings were from ring nets then that only equates to 2 full time equivalent livelihoods at best. Any assertions by the commercial sector that “many livelihoods would be at stake” if ring netting was totally banned in the areas under consideration should be thoroughly tested with a requirement for full evidential backup.

Question 5: From your experience can you describe the likelihood of catching a salmon or a sea trout in a ring net?

No due to no experience.

The maximum size of net proposed to be allowed does, however, suggest a strong likelihood especially when deployed in narrow waterways where the 75% coverage limit comes into effect.

Question 6: From your own experience are there any steps that can be taken to avoid catching salmon or sea trout in a ring net?

No due to no experience other than don’t use them.

Grey Mullet Minimum Size Increase

Please refer to Section 2.3

Question 7: What would be your preferred option for the minimum size of grey mullet species in the Southern IFCA district? Please provide a rationale.

Definitely Option 4. That provides for a first breeding of both male & female thick lip mullet which must be a corner stone of a sustainable fishery. It would also provide protection for both other smaller grey mullet species.

IFCO Simon Pengelly has correctly pointed out to the SIFCA Recreational Angling Sector Group that for any given net mesh size, a greater length mullet would pass through it than a bass due to differing body shapes. Thus a 47cm MLS for mullet would result in an ancillary benefit of an appropriate net mesh size being also appropriate for the 42cm MLS for bass. This would then reduce the instances of “unavoidable” by catch of under size bass when targeting mullet.

 

Question 8: Do you agree that the proposed measures will (a) support fish nursery areas; (b) provide areas of refuge for fish; (c) provide protection for migratory species, such as salmon and

sea trout?

a) Yes but only where part of an overall package of restrictions that include, for instance, exclusion of bottom towed gear & does not permit any netting including “ring netting”.

b) Yes but only where part of an overall package of restrictions that include, for instance, exclusion of bottom towed gear & does not permit any netting including “ring netting”.

c) Yes but with additional management as described in answer to question 2.

Question 9: How do you believe net fishing by recreational users should be managed?

In addition to the management measures for commercial fishers, recreational netters should be restricted regarding:-

a) Maximum overall size of net commensurate with a potential to harvest a quantity appropriate for own private consumption.

b) Pre-register their use of nets (free of fees until such time as commercials pay a similar fee)

c) Mark their net(s) with their contact details (and possibly some registration ref number)

d) Prohibit from deploying after dark. That would reduce the number of instances where netted catches are sold illegally since most such activity is carried out clandestinely after dark & would aid enforcement. Deployment of nets is often not illegal in itself but the selling of fish so caught “recreationally” may become an illegal act. (I do realise that this is against your recommended code of conduct but I suspect that unwanted entanglement is a low risk in the areas currently proposed for management).

Question 10: How would you like to see fishing nets marked in the district?

This needs to be addressed in conjunction with a similar requirement for other fixed engines (pots).

Should meet the following:-

a) All surface markers need to be clearly visible in order to assist with safe navigation of all vessels. This should include provision to ensure they do not sit under but near the surface during strong tide runs.

b) Should be marked in a standard agreed way that makes a clear distinction between markers for nets & those of other fixed engines. Suggest this could be by way of requiring net markers to incorporate flags of a defined minimum size mounted on poles of a defined minimum length. Markers of other fixed engines to be without such flags. This would then make this part of the regulations comply with the requirement of being capable of being enforced effectively & affordably.

c) Net markers should incorporate vessel identification (as is required for pots) in addition to or in replacement for identification on the net’s head rope. Current requirements considerably impede IFCA officers in efficient execution of their inspection/enforcement duties.

Question 11: What are the anticipated costs or benefits to you as a result of these measures? Where possible, please provide financial estimates.

 As a recreational sea angler, these would not impose any additional costs on me.

Anticipated benefits in terms of increased numbers of fish available to catch would have both social & financial benefits to me including:

a) Willingness to increase the number of angling trips undertaken. (Thus assisting with the government’s national aim to increase participation)

b) Increased ability to catch fish for my own consumption. (Say £50pa)

c) Not travelling so far to fish venues that offer a realistic chance of catching fish. (Say £100pa)

d) Increased sense of satisfaction at having been successful in catching rather than disappointment at not catching.

There are clearly financial benefits to be had by sectors such as tourism etc which I refer to in question 12

Question 12: Are there any further comments you would like to make on the impact of the

proposal?

The general lack of fish available to be caught by RSAs is undoubtedly the top concern with the sector. Successful implementation of these proposals (and proposed enhancements) would go a long way towards addressing the strong concern felt by RSAs that fisheries management is far too biased towards the benefits for the commercial fishing sector. Fish are a commonly owned national asset & are not the sole property of the commercial fishing sector.

The anticipated consequence of these measures of increasing the number of fish available to be caught by RSAs would undoubtedly have significant positive financial benefits to the tourist, charter fleet, angling guide and tackle manufacturing sectors among others. SA2012 includes an estimate of the combined value to these sectors of single angler/day shore/pier trip which equates to about £25 today.

Just taking examples above of Sandown Pier plus the River Medina, there is a potential annual benefit to the RSA sector of up to £25K pa if angling levels returned to those in 2010.

If one could add up all the similar financial benefits for the other SIFCA areas proposed for management, it is not hard to imagine a total benefit in excess of £150Kpa and possibly up to £250K

As stated previously, regulations must be capable of being enforced both effectively and, most importantly, affordably. If stakeholders, that have the potential for non-compliance, view the measures as being incapable of being so enforced then there is an increased risk that they will be non-compliant. Hence my emphasis in responses above on making the regulations simple to enforce.

Not part of my response directly to this consultation but you mention fyke nets being subject to control by the Environment Agency. I very much doubt that many (if any) rank & file anglers or members of the public would be aware of that. I certainly was not. If SIFCA has not done so already, then I would strongly request that SIFCA include reference to that by way of an information only note readily viewed from its section of its web site relating to regulations etc. This is entirely separate from the netting controls being currently consulted on and thus not dependant on the outcome of the consultation.

 
 END OF SECTION DEALING WITH NETTING CONSULTATION
 
Existing Byelaws:-
 
Enacted by the Southern Inshore Fisheries & Conservation Authority (SIFCA)
 
The Southern Inshore Fisheries & Conservation Authority www.southern-ifca.gov.uk took over responsibility for inshore commercial fishing from the old Southern Sea Fisheries Committee & was additionally given authority to also regulate the activities of recreational sea anglers (RSAs) including the gathering of marine bait of all descriptions. Their web site includes full details of all their byelaws which mostly affect just commercial fishermen.  SIFCA byelaws are here List of Byelaws
 
The Angling Trust has emphasised that its position regarding anglers selling their boat caught catch is that any such angler is not a recreational sea angler but is instead an unlicensed commercial fisherman performing an illegal act.
 
 
Restrictions on inshore bottom trawling (not mid water trawling)
Whilst not directly affecting Anglers, the SIFCA bottom towed gear byelaw will be of some interest: This relatively recent & now enacted byelaw prohibits the use of all forms of towed fishing gear from (amongst others) a significant number of areas round the Solent coast of the IW as well as inshore round the entire south coast of the IW from Bembridge round to the Needles. SIFCA was sent letters of support for this byelaw on behalf of IW anglers. Alan Deeming has received assurance from SIFCA that the practice of dragging chain or poles round set nets to frighten fish into them is prohibited. This practice had been previously observed being carried out by at least one local commercial fisherman.
 
See chart below for areas where the use of bottom towed fishing gear is now prohibited.
 
IW Chart
 
 
Restrictions on bait gathering.
Anglers are directly affected by the SIFCA Hand Gathering in Seagrass beds prohibition byelaw. Both Tony Williams & Alan Deeming were heavily involved in trying to minimise the impact on bait gathering on local beaches that would have resulted from a byelaw that has now been enacted by Southern Inshore Fisheries & Conservation Authority (SIFCA). They initially challenged the entire validity of the proposed byelaw that sought to prevent the collection of any worm, shellfish or crab by any hand method within seagrass beds. Despite eventually being able to get Fish Legal (the legal support arm of the AT) to submit official legal argument against it, this failed so Tony & Alan were faced with having to seek concessions to the benefit of RSA. Alan was eventually able to obtain confirmation that anchoring whilst fishing (angling) from a boat was not prohibited by the byelaw. It is also thought that representations made by Tony to the then fisheries minister, Richard Benyon, regarding allowing the continued use of push nets for prawns, resulted in the final wording of the byelaw specifically excluding any control on the use of such nets. Tony & Alan did not involve themselves with proposed restricted areas on the mainland coast so there were 2 main local proposed areas of particular concern that they addressed: East Cowes (between the breakwater & Old Castle Point) and most of Ryde Sands.
 
Being local to him, Alan concentrated on East Cowes where the originally proposed area boundary not only included the harbour side of the breakwater but also took in the road along the seafront. A particular restriction within the byelaw would have meant that anyone driving along the road with a fork or spade in the car would technically be committing an offence. After a lot of discussion with SIFCA they eventually amended the boundary to only reach mean high water and they incorporated the breakwater as a boundary line, thus allowing collection on the harbour side. Unfortunately, as the seagrass bed here is recorded as extending for the entire area between the breakwater & the sand spit at Old Castle Point, no concession could be obtained to allow the (all be it low level) digging of lugworm to continue.
 
Being local to him, Tony concentrated on Ryde Sands. One main concern here was that, although the main lugworm beds do not exist within the seagrass, SIFCA had added a wide buffer zone round the charted seagrass beds which resulted in the adjacent lugworm beds being included in the controlled zone. This was compounded by the seagrass bed being a complicated shape and SIFCA had simplified the outline of the controlled zone by drawing long straight lines which resulted in more of the lugworm beds to be included. After a lot of dialogue, Tony succeeded in getting the boundaries amended to a point where some significant lugworm beds now remain accessible.
As of Nov 2017 SIFCA has failed to erect any notices regarding the restricted areas on the IW despite being requested to on numerous occasions.
 
Damage to Seagrass beds at Ryde Sands: As a side issue relating to the above byelaw, Tony compiled a photo based report on the ongoing damage being caused to the seagrass beds by the (probably unlawful) dumping of spoil from Ryde harbour and the Monkton Mead storm water outfall onto the seagrass beds by heavy plant. It proved difficult to get any government body to acknowledge interest in this matter but eventually in early 2014 someone from the MMO accepted the report for their consideration. In addition, the winter storms of 2013/4 have resulted in significant changes to the intertidal sand which may require the seagrass beds to be resurveyed at some point. In November 2014 further work on Ryde Sands associated with the Monkton Mead storm water outfall has resulted in further extensive damage to the eco-system of the sands resulting from heavy plant & diggers transporting large amounts of sand further down the coast & depositing it in the intertidal zone. It is difficult to see how any angling related activity restrictions arising from the designation of an MCZ here could be justified in the light of this latest highly damaging yet authorised activity. SIFCA has no authority to regulate activities not directly related to fishing/angling & the responsibility lies with the MMO which has so far failed to take any action.
 
It should not be forgotten that the seagrass dies back over winter and re-grows in the spring. Southern IFCA plus other government agencies use the survey of local seagrass beds that is published by the Hampshire & Isle of Wight Wildelife Trust on an annual basis. The trust attempted to re-survey the seagrass around the entrance to Bembridge harbour in mid 2014 but it was not totally successful due to equipment problems. Alan is now listed to receive copied of new versions of the report as they become available but as of 2017, funding has been restricted & the surveys reduced.
 
The following charts show restricted areas on IW but some reference numbers for boundary points do not tie up with those in the latest SIFCA byelaw as the numbers were changed after some of the charts were provided.
 
Seagrass chart IW 3Restricted Area Thorness Bay
 
East Cowes Hand Gather 2016
Restricted Area East Cowes 
Woodside handRestricted areas Osborne to Woodside
Ryde detailed Final

Restricted areas around  Ryde Sands 

Hand Work Byelaw chart019Restricted Areas around Bembridge

 

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