Navigating the Legislative Terrain
How Laws and Regulations Can Stop Off-Roaders in Their Tracks
Table of Contents
Like all niches of the auto hobby, off-roading is an activity enjoyed by countless enthusiasts and families all over the country. Responsible use of OHVs (off- highway vehicles) allows off-roaders to enjoy all that America's landscape has to offer on two or four wheels. However, with increasing frequency, enthusiasts are encountering "road closed" signs on public lands. This is often the result of the U.S. Congress passing legislation establishing "wilderness" areas.
A wilderness designation is the strictest form of public land management since virtually all mechanized equipment is outlawed. Motorized recreation is not permitted on these lands. In fact, allowable use wilderness areas only includes travel on foot or horseback-without the luxury of toilets, tables or fire pits.
Wilderness does serve an important environmental purpose in protecting plants and animals and America's natural heritage. The issue is the amount of land that needs such a restrictive designation and whether it is possible to permit some motorized activities on portions of the land. When Congress enacted the Wilderness Act in 1964, it set aside 9 million acres of land. There are now about 110 million acres.
However, there are some OHV-friendly compromises that can be pursued. For example, reasonable limits should be placed on the amount of acreage to be designated. Existing roads and trails should be "cherry-stemmed" so that they do not receive the wilderness stamp. Congress should also consider enacting new "back country" designations - not as drastic as wilderness - that would permit motorized activity on certain lands while simultaneously protecting the environment.
In recent years, anti-OHV activists have pushed dozens of wilderness bills in an organized effort to lock-up as much land as possible. When these bills are rushed through Congress, there is little opportunity to cherry-stem existing roads and trails. In fact, the wilderness designation may be an intentional means to force responsible OHV enthusiasts off public land. This hurts local economies that depend on off-road activities and deprives enthusiasts of legitimate recreational opportunities.
In 2009, Congress combined more than 160 separate wilderness measures into one larger bill called the Omnibus Public Land Management Act. The law created nearly 2.2 million acres of new wilderness in nine states, including areas in and around Joshua Tree National Park and the Eastern Sierras in California, Owyhee-Bruneau Canyonlands in Idaho, Mt. Hood in Oregon, Zion National Park in Utah, Sabinoso Wilderness in New Mexico and Monongahela National Forest in West Virginia. Many roads and trails were swept-up in the closures including Mt. Canaan Trail in Utah and Dickshooter Ridge Road in Idaho.
Congress continues to consider dozens more wilderness measures which could encompass additional millions of acres of land across the country! Scores of popular OHV trails could be closed. It is more important than ever to get involved and make your voice heard by government. Joining the SEMA Action Network (SAN) at www.semasan.com is an excellent first step.
The SEMA Action Network (SAN) is a nationwide partnership of vehicle clubs, enthusiasts and members of the specialty auto parts industry who volunteer to protect their hobby from unreasonable laws and regulations. Founded in 1997, the SAN has over 65,000 individual and car club members throughout the United States and Canada and is in direct contact with millions of enthusiasts through electronic communication, publications and social media.
The SAN maintains that it is possible to balance environmental protection and promote responsible recreational opportunities and advocates a number of basic principles including:
Implementing OHV policies that recognize the importance of vehicle-oriented recreation.
Conducting case-by-case reviews of lands subject to a wilderness designation to ensure widespread local community support, and releasing any lands that do not meet the wilderness criteria since they have been developed with roads, trails, buildings, etc.
Cherry-stemming existing roads/trails, a process that excludes them from the wilderness area and, thereby, remain open to recreation.
SEMA's roots are firmly planted in the racing sector. When formed in 1963, the "Speed Equipment Manufacturers Association" represented companies producing performance equipment for many of the early trailblazers that set land-speed records at the Bonneville Salt Flats or other dry lakes and racing venues. Now, more than 50 years later, the industry has blossomed and the renamed "Specialty Equipment Market Association" embraces the entire distribution chain, including manufacturers, warehouse distributors, jobbers, retailers, specialty stores, sales agents and media companies.
Speed equipment remains the brick and mortar of SEMA. In fact, Bonneville and other dry lakes played a crucial role in SEMA's formation since they were primary venues for industry pioneers to race their cars in the 1930s and 40s. These pioneers would adjust their equipment on the salt flats or lake beds and then go back to the garage to create the next generation of speed equipment. Many started companies and founded the sport of drag racing. In turn, these companies understood the importance of having an industry trade association and created SEMA.
In more recent times, founding SEMA members like Ansen, B&M, Crager, Edelbrock, Grant Industries, Halibrand, Hedman, ISKY Racing Cams, JE Pistons, Mooneyes, Shelby, Trans-Dapt and Weiand have been joined by scores of other companies that produce high performance parts. Meanwhile, SEMA's special ties to Bonneville remain. Where else but Bonneville does one test the limits of that equipment? Whether it is a 1932 hot rod, a 1960s muscle car, a streamliner or anything in-between, Bonneville is the proving ground for SEMA member companies and their customers.
Legislative and regulatory advocacy has been a key factor in helping SEMA member companies succeed and prosper. In the 1950s, the industry operated largely free of regulatory constraints. Following the introduction of California regulations in the '60s to curb mobile-source air pollution, federal and state governments proposed a variety of restrictive measures. Without SEMA's advocacy efforts, the laws and regulations that came to control our industry could have been overly restrictive with unnecessarily detrimental effects on businesses and consumers.
Although the current legislative/regulatory arena places a focus of attention on street vehicles, SEMA and its Government Affairs staff continue to advocate on racing issues. To follow are recent examples:
|Racers Against Street Racing (RASR): SEMA re-launched RASR to promote safe and legal alternatives to illegal street racing. The webpage is part of the SAN website and provides resources to help enthusiasts take their racing activities to the track. SEMA has partnered with the National Speedway Directory in order to identify racing venues.|
|Bonneville Salt Flats: SEMA is a partner in the "Save the Salt Coalition," which fosters and supports a comprehensive salt replenishment campaign by the racing community, BLM and mine operator.||Johnson Valley, CA: SEMA is working with the Off-Road Business Association (ORBA) and a number of other organizations to protect the Johnson Valley OHV recreation area, home of the King of the Hammers event. SEMA advocates continued control of the land by the BLM and issuance of special-use permits to the U.S. Marines to conduct one or two months of training exercises on the land, which is adjacent to the Twentynine Palms Marine base.|
Noise Laws: SEMA continues to advocate for reasonable application of noise laws before lawmakers and regulators. In many instances, a long-established facility becomes the target of noise restrictions when new housing developments are constructed nearby.
Depreciation: SEMA partnered with NASCAR to support efforts to include 7-year race track depreciation exemption amendment to "Fiscal Cliff" legislation. The amendment allows "motorsports entertainment complexes" to depreciate the cost of capital improvements over a shorter, seven year period than other facilities.
Sponsorships: SEMA worked with NASCAR to support and protect military sponsor-ships of race teams (U.S. Army, Air Force, National Guard). An amendment to a federal funding bill was introduced to eliminate military expenditures on these sponsorships and was defeated by a narrow vote. SEMA directly engaged members of the Congressional Automotive Performance and Motorsports Caucus to urge their support for sponsorships and votes against the amendment.
CAA Racing Exemption: SEMA continues to advocate for clear and practical application of the Clean Air Act's exemption for emissions-related equipment used
solely for competition use.
Canada: In 2010, as requested by SEMA, Environment Canada issued a final rule to indefinitely extend an exemption allowing the use of leaded gasoline in competition motor vehicles.
U.S.: SEMA monitors for any attempt to modify the Clean Air Act exemption permitting leaded fuel for competition vehicles.
Land Use Policies & Off-Road Equipment
Many SEMA members market equipment that is used by off-road enthusiasts. Importantly, the same equipment is used to improve and individualize the performance of their vehicles. The enthusiasm for these products is dependent, in part, on the availability of public lands for off-road use.
Threats to off-highway vehicle (OHV) access typically take form in legislation passed by Congress or regulations issued by the U.S. Forest Service, U.S. Bureau of Land Management or other federal and state agencies. Roads and trails may be closed when lands are designated as "wilderness," unnecessarily large amounts of lands are closed to protect endangered species, or other restrictions are placed on federal and state lands.
SEMA supports land use decisions that are reasonable and enjoy local community support but opposes unnecessarily restrictive land-use policies. Since the federal laws and regulations that govern land use are complex, it is sometimes difficult to relate how "NO TRAILS" translates into "NO SALES" for SEMA members that cater to the off-road industry. The following is a guide to major laws that dictate land use, federal agencies that administer the laws, some of the organizations that SEMA works with to protect the rights of off-road enthusiasts to use their vehicles on public lands, and SEMA's positions on these issues.
The Wilderness Act of 1964 established a framework whereby Congress protects land that is essentially undisturbed, retains a primeval character, is without permanent improvements and generally appears to have been only affected primarily by the forces of nature. The lands become part of the "National Wilderness Preservation System" which began with 9 million acres and now encompasses nearly 110 million acres. Many of the wilderness areas are in national parks, while most of the other lands are within national forests or fish/wildlife preserves. "Wilderness" is closed to all motorized vehicles and mechanical forms of transportation, including mountain bikes.
"Wilderness Study Areas" (WSAs) are lands that have been designated as having wilderness characteristics, potentially making them eligible for the "wilderness" status. Federal agencies manage the lands so as to protect these characteristics until Congress ultimately decides their final status. There is no timeline for making a decision and legislation must be enacted to finalize the process.
SEMA Position: SEMA supports a case-by-case review of all WSAs to determine an appropriate designation which has widespread local community support. Decisions must be based, in part, on an inventory of all developments within the WSA including roads, routes, trails, cabins, etc. When the decision favors wilderness, SEMA urges lawmakers to be reasonable in the amount of acreage to be designated, "cherry-stem" existing roads/trails and consider applying a new "back country" designation to certain lands rather than the "wilderness" designation so as to provide for a wide range of recreation opportunities for motorized and mechanized uses. See "Regulating Motorized Recreation on Federal Lands" for more information on SEMA land use positions.
Current law provides the president with authority to declare land of "historic or scientific interest" to be a national monument. Although not as onerous as a wilderness designation, motorized recreation and other activities may be subject to limitations within the monument. While this authority has only been used 137 times in 100 years, vast amounts of land have been set aside in the process. In 1996, President Clinton set aside 1.9 million acres of land in Southern Utah as the Grand Staircase-Escalante National Monument. President Obama is now under pressure to establish a 1.4 million-acre "Greater Canyonlands National Monument," closing 1,050 miles of off-road vehicle trails and monitoring another 1,450 miles for future closure.
SEMA Position: SEMA supports a collaborative approach to land-use decisions, including input from local citizens, elected leaders and other stakeholders. This would include widespread local support for a National Monument designation. SEMA supports legislation that would require the president to complete an environmental review under the National Environmental Policy Act (NEPA) before designating more than 5,000 acres as a national monument. The bill would ensure public involvement in the process and discussion of multiple factors, including economic impact.
Endangered Species Act
The Endangered Species Act of 1973 (ESA) was designed to protect threatened and endangered species, and the habitats in which they are found. It applies to federal, state and private lands. The U.S. Fish and Wildlife Service (FWS) maintains a list of more than 2,000 threatened or endangered species, which includes birds, insects, fish, reptiles, mammals, crustaceans, flowers, grasses, and trees. Given its successes and failings over the past four decades, there have been widespread calls to revise the ESA to foster more cooperative efforts and incentive programs between the government, private landowners and conservation organizations. The law has favored a blanket approach of setting aside millions of acres rather than nurturing smaller recovery zones. During this time, the OHV community has been unnecessarily deprived of access to roads and trails but the sacrifice has not necessarily meant that a particular species is better protected.
SEMA Position: SEMA supports establishment of recovery habitats rather than setting aside huge tracts of lands and then spending time and money in endless court challenges. The FWS agrees that its recovery resources are drained by constant lawsuits. SEMA supports initiatives to permit and develop habitat conservation plans, conservation banking, voluntary agreements with landowners, incentive-based actions by individuals and businesses. SEMA supports strengthened cooperation with local, state and tribal governments on species recovery plans. SEMA believes species listings should be determined using best available scientific information. SEMA believes mediation of issues should be required before parties can file lawsuits.
U.S. Forest Service Policy on Off-Highway Vehicle Use
Following recommendations made by SEMA and other organizations, the U.S. Forest Service (USFS) created revised regulations for off-highway vehicle (OHV) use in national forests and grasslands. The need for reasonable travel management stems from the fact that off-road activity has risen from 5 million riders in 1972 to 36 million in 2000. Under the policy, the USFS is required to formally designate a system of roads, trails and areas where motorized vehicle use would be allowed. Local agency officials are required to seek public comments from state and local officials and other stakeholders in determining routes open to OHV use. The rule provides for increased involvement from the OHV community in the designation process. As recommended by SEMA, USFS considers "user-created" routes in the review process. Many of these routes came into existence during "open" management and serve a legitimate need and purpose, and do not pose an environmental threat. The USFS is also updating its official maps since many existing roads and trails do not appear in the official inventory. Each individual forest or ranger district is pursuing route designations. Many have been completed while some are still being developed and subject to public comment.
BLM Policy on Off-Highway Vehicle Use
In 2001, the U.S. Bureau of Land Management (BLM) issued a "National Management Strategy for Motorized OHV Use" which recognizes motorized recreational as a legitimate use of public land. Under the program, public lands are designated as "open," "limited," or "closed" to OHV use. Open areas are areas where all types of vehicle use are permitted at all times, anywhere in the area. Limited areas are lands where OHV use is restricted at certain times or use is only authorized on designated routes, and closed areas are lands where OHV use is prohibited. In 2005, the BLM revised its "Land Use Planning Handbook" to incorporate specific guidance for "Comprehensive Travel and Transportation Management." In 2007, the BLM sent guidance to its field offices to further clarify travel management decisions in the planning process. It noted that continued designation of large areas as open to unregulated "cross-country travel" was not a practical management strategy (although still permitted), and that field offices should direct OHV travel to designated roads and trails. For the 258 million acres of BLM administered lands, the BLM's current OHV designation status is approximately 32% "open," 4% "closed," 48% "limited," and 16% "undesignated". Included among the "open" areas, BLM manages approximately 100 specifically designated OHV riding areas. The BLM estimates that it hosts over 55 million recreation visitors on its lands every year, an increase of over 80% since 1990. The agency estimates that 22 million of these visitors participate in motorized recreation.
Additional information is available at:
National Park Service Policy on Off-Highway Vehicle Use
The National Park Service (NPS) manages nearly 400 units covering about 85 million acres of land. The parks enjoy nearly 300 million recreational visits each year, including a variety of OHV activity. Less NPS land is open to OHV activity than for lands managed by the BLM or USFS. The NPS has four categories of lands - national recreation areas, national seashores, national lakeshores and national preserves. The NPS generally requires a special rulemaking, with environmental impact analysis and public comment, to designate OHV routes and activity areas within the park units. Under its 2006 management policies, OHV activity is permitted when determined to be an appropriate recreation that will have no adverse impact on the area's "natural, cultural, scenic and esthetic values." Examples of site-specific disagreements regarding appropriate off-road activity include OHVs in North Carolina's Cape Hatteras National Seashore, ATVs in Florida's Big Cypress National Preserve, and snowmobiles in Yellowstone National Park. The NPS continues to evaluate OHV use in a number of park units and issue park-specific regulations. Many such regulations have already been completed. Some have sparked lawsuits and triggered efforts to resolve the matter via Congressional legislation. Lawmakers also have authority to conduct oversight hearings and provide guidance to the NPS officials regarding Congressional intent.
For more information: www.nps.gov/index.htm
Forest Service Planning Rule: In 2012, the USFS issued its latest regulations governing how the agency prepares individual Forest Plans for each forest and grassland. The so-called "Planning Rule" is the master guidance document for developing, amending and revising land use plans. For example, it governs broad issues such as multiple-use, preferred use, and the implications of global warming. The USFS and the public have struggled to define the meaning of words and phrases used in the planning directives. The Planning Rule has been issued several times in recent years. It has been the subject of lawsuits and been overturned by the courts. The current Rule has been challenged. Meanwhile, the USFS has established an advisory task force to provide guidance on its implementation.
For more information: http://www.fs.usda.gov/planningrule
In 2001, the U.S. Forest Service issued a rule to stop construction of roads in 58.5 million acres of potential wilderness lands under its control. The so-called Roadless Rule affects about 30% of the total Forest Service land base, namely the inventoried roadless areas. Forest Service roads provide access for the timber and mining industries that may eventually become recreational roads.
The Roadless Rule was the subject of nearly endless challenges and litigation until 2013. The rule was modified to permit local forest managers more input on access issues and to provide state governors with an opportunity to request exemptions from the rule. Conflicting opinions worked there way through the appeals courts until the Supreme Court eventually ratified the 2001 rule. At issue for the OHV community is the ability of state government and local communities to help shape forest management decisions.
Additionally, many current USFS maps do not include routes well known to users and state/local officials. The USFS is still in the process of inventorying the routes and update maps, so it would not be appropriate to unilaterally close the lands under the guise that they are "roadless."
In 2003, the Interior Department initiated a policy to make it easier for states and counties to claim rights of way on thousands of dirt roads that run across federal lands, most of which were created between 1866 and 1976 when federal mining laws encouraged western settlement. The subject mining law is called "Revised Statute 2477(RS 2477). At issue is whether state and local governments, and the OHV community, will pursue huge numbers of public right-of-way claims to these old trails that can be maintained as dirt-bike trails or OHV roads, or even converted into paved roads. One important element of this issue is that where roads are protected, areas will be ineligible for designation as wilderness. The State of Utah has been most active in pursuing RS 2477 right-of-way claims. The claims are now subject to a number of lawsuits.
A variety of economic studies have been prepared that document the importance of outdoor recreation to the local and state economies, and demonstrate the importance of responsible land use access to enthusiasts across the country. One of the more important and comprehensive studies prepared by the Western Governors' Association (WGA) and a coalition of outdoor industry groups and issued in 2012. The outdoor recreation study projected a $646 billion benefit to the national industry.
WGA/Industry Study (6/12): Summary: Outdoor Recreation Study - Summary
WGA/Industry Study (8/12): Comprehensive: Outdoor Recreation Study - Technical Report
Most of the current land use concerns relate to federal lands controlled by four federal agencies: Bureau of Land Management, U.S. Forest Service, National Park Service, and Fish and Wildlife Service. The following is a brief description of the major players.
|The U.S. Bureau of Land Management (BLM) is part of the Department of the Interior and administers the bulk of federal lands. The BLM manages about 262 million acres of federal land. This is about one-eighth of all of the land in the United States and 42% of all federal lands.The BLM was initially created to manage range lands for use by mining, grazing, oil and gas development. Its role was expanded in 1976 to include recreation and wilderness. It manages 2% of the "National Wilderness Preservation System" (161 separate wilderness areas) along with a large amount of land that has been reserved as "potential" wilderness (which are called "Wilderness Study Areas").|
|The U.S. Forest Service (USFS) is part of the Department of Agriculture and oversees the National Forests. Among the purposes of its supervision is ecological protection and public access. The USFS is responsible for managing about 191 million acres (about the size of Texas) comprising 155 national forests and 20 grasslands, which is 30% of all federal lands. Within that acreage, it manages 18% of the National Wilderness Preservation System (406 separate wilderness areas) along with a large amount of land that has been reserved as potential wilderness.|
|The National Park Service (NPS) is part of the Department of the Interior and manages land set aside for its natural, historical and cultural resources and for recreation. This includes 51 national parks and more than 300 national monuments, historic sites, memorials, seashores, and battlefields. The NPS manages about 81 million acres of federal land, which is 13% of all federal lands. Within that acreage, it manages 56% of the National Wilderness Preservation System (54 separate wilderness areas) along with a large amount of land that has been reserved as potential wilderness.|
|The U.S. Fish and Wildlife Service (FWS) is part of the Department of the Interior and conserves the nation's wild animals and their habitats by managing a system of more than 500 national wildlife refuges and other areas, totaling about 91 million acres of land and water. The FWS manages 15% of all federal land, of which 22% is part of the National Wilderness Preservation System (71 separate wilderness areas) along with a large amount of land that has been reserved as potential wilderness. The FWS also administers the Endangered Species Act, making decisions on whether there should be public access to certain lands.|
There are a number of groups involved in land use issues seeking to keep the public lands open for public use. Those groups seeking to keep the public lands open include:
|American Motorcyclist Association: AMA advocates for motorcyclists' interests before local, state and federal government officials, and before the public.|
|American Recreation Coalition (ARC): ARC seeks to catalyze public/private partnerships to enhance and protect outdoor recreational opportunities and resources. Members encompass a large range of recreational industries.|
|Americans for Responsible Recreational Access (ARRA): ARRA promotes responsible use of public lands and waterways, and seeks to protect access to these areas. It includes OHV and snowmobile enthusiasts along with horseback riders, hunters, fishermen, and others.|
|Blue Ribbon Coalition (BRC): BRC champions responsible use of public lands for the benefit of all recreationists. Its primary focus is defending access for motorized recreation nationwide: motorcycles, ATVs, off-road vehicles, snowmobiles, mountain biking and watercraft.|
|Motorcycle Industry Council (MIC): MIC represents manufacturers, distributors, dealers and retailers of motorcycles, scooters, ATVs, ROVs, and related parts and accessories. Protecting land-use access for the OHV community is an important part of MIC's mission.|
|National Off-Highway Vehicle Conservation Council (NOHVCC): NOHVCC provides information on club and state association development, OHV land management, and other services. It educates and provides materials to individuals, clubs, associations and agencies in pursuit of responsible OHV recreation.|
|North American Motorized Recreation Council (NAMRC): NAMRC is an alliance of organizations which facilitates communications within the motorized recreation community. NAMRC seeks to share information, expertise and resources to enhance a unified message.|
|Off-Road Business Association (ORBA): ORBA is comprised of hundreds of businesses nationwide involved in the off-highway vehicle recreation industry. ORBA's principal mission is to ensure the long-term viability of those businesses by working to keep public lands open to responsible recreational activities.|
|Recreational Off-Highway Vehicle Association (ROHVA): ROHVA is a nonprofit trade association which promotes the safe and responsible use of recreational off-highway vehicles (ROVs) manufactured by its members.|
|Specialty Equipment Market Association (SEMA): SEMA is comprised of mostly small businesses nationwide that design, manufacture, rebuild, distribute and retail specialty automobile parts and accessories for the automotive hobby. OHV equipment - wheels, tires, lift kits, lights, truck caps, running boards, cargo storage, etc. - represents an important segment of products manufactured by SEMA members. SEMA also operates the SEMA Action Network (SAN), a nationwide partnership between vehicle clubs and enthusiasts who have a common interest in the auto hobby, including OHV and back-country recreation.|
|Tread Lightly! Tread Lightly leads a national initiative to protect and enhance OHV recreation by promoting good stewardship. The group offers a myriad of programs, trainings and educational material to help educate recreationists across the nation on the importance of treading lightly.|
SEMA supports managed care of the nation's public lands in a manner that balances responsible recreational opportunities with a need to maintain the health and beauty of our federal lands, and the safety of patrons.
SEMA supports OHV policies that recognize the importance of vehicle-oriented recreation: Increased OHV use in recent years has provided the American public with the ability to enjoy public lands in record numbers.
SEMA supports broad national guidelines combined with local management decision-making: It is important that local officials have authority to work with the public and State, Federal and Tribal government leaders to make appropriate decisions on OHV access.
SEMA supports strong public involvement in decision-making: SEMA recommends that government agencies be required to seek the active participation of the public in the process of designating OHV access.
SEMA supports flexible timetables for designations: The designation process is complex and may vary from forest-to-forest, or other federal land area. While there may be a uniform approach, the specifics must be dealt with at the local level according to the unique circumstances of each land area.
SEMA supports certain "user-created" routes: By default, the designation process places the onus on the OHV recreational community to identify routes that were created in recent years that have not yet been inventoried ("user-created" routes). Many of these routes came into existence during "open" management and serve a legitimate need and purpose, and do not pose an environmental threat. In some cases, these uninventoried routes may even be more environmentally friendly and provide a better overall access solution than their inventoried counterparts.
SEMA supports reasonable application of "Emergency Powers": There are times when emergency closures are necessary to provide short-term resource protection or to protect public health and safety. Nevertheless, the public should be included in the decision-making process when such closures last beyond 12 months.
SEMA supports defined vehicle classes and use authorizations: Vehicle classes need to be defined at the federal level so there is uniform application across the country when it comes to planning, mapping of roads/trails, etc.
The future of our prized cars and trucks is being threatened! Add your voice to our growing U.S. and Canadian forces united to advance our automotive freedoms. SAN members defend the hobby by responding to timely e-mail updates on vehicle-related legislation and regulations. No fees. No SPAM. No obligations. Great strength comes with great numbers. Can we count on you to help preserve the classics of today and tomorrow?
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