22 11, 2021

Dec. 7 Webinar: Benefiting from the Broadband Infrastructure Bonanza

2021-11-30T13:20:52-05:00November 22, 2021|Webinars|

Now is the time to prepare for this historic opportunity

The federal Infrastructure Investment and Jobs Act provides $65 billion for broadband-related infrastructure over the next five years, including nearly $42.5 billion in state grants to be used for broadband buildout projects. The availability of this much money is already drawing the attention of non-traditional broadband providers, many of whom will be clamoring to get a slice of the broadband pie. Although the funds will not start flowing out until 2022, now is the time to educate yourself about what will be available, how it can be used, and what you can do now to prepare for a successful future.

Join us for a special webinar on Tuesday, December 7 at 2 p.m. EST to learn more about the infrastructure bill and the sea change this is going to cause in our industry. JSI experts Douglas Meredith and Carl Perry will be discussing:

  • How the money will be divided between traditional providers and new entrants, including electric cooperatives;
  • Priorities for each program;
  • Possible timing of program funding;
  • Ways to best position yourself for the changes this money is going to trigger (here’s a hint, the answer is fiber); and
  • How to prepare for ongoing funding needs after FY2026.

Registration for this webinar is $249 per company. (Can’t make it on the 7th? We offer recordings of our webinars as well.)

Register

Contact Brenda Cordwell in JSI’s Maryland office at 240-556-1295 for more information about this webinar or questions about registration.

22 11, 2021

FCC Seeks Comment on the Affordable Connectivity Program

2021-11-22T10:38:19-05:00November 22, 2021|e-Lerts|

On November 18, 2021, the FCC issued a Public Notice seeking comment on its implementation of the Affordable Connectivity Program (ACP). The ACP is part of the enacted Infrastructure Investment and Jobs Act and expands and modifies the current Emergency Broadband Benefit Program (EBBP) with a $14.2 billion appropriation and changes to the household eligibility requirements. The Commission seeks comment on how to transition from the EBBP to the ACP and welcomes input on how the ACP will operate as a long-term program. Comments are due December 8, 2021. Reply comments are due December 28, 2021.

The biggest change from the EBBP to the ACP is the monthly support amount for households located on non-tribal lands. This monthly support will decline from $50 per month to $30 per month. (The monthly benefit for eligible Tribal households remains unchanged at $75.) The effective start date of the ACP is established in the Act and will be December 31, 2021. There will be a 60-day transition from the EBBP benefit to the lower ACP benefit.

One provision of the ACP allows an enhanced benefit above the standard non-tribal $30 per month benefit, up to $75 per month for households served by providers in “high-cost areas” and where the provider can show a “particular economic hardship.” How providers in high-cost areas benefit from this provision is one area where the Commission seeks industry input.

JSI will be tracking this docket closely and will provide further details as the rules for the transition to the new ACP are finalized. If you have questions about the ACP or would like JSI to assist with filing comments, please contact Lans Chase at 770-569-2105, Liz Kayser at 512-338-0473, or Douglas Meredith at 801-294-4576.

9 11, 2021

Landmark Federal Infrastructure Bill to Provide $65 Billion for Broadband

2021-11-09T15:03:13-05:00November 9, 2021|e-Lerts|

Congress passed the Infrastructure Investment and Jobs Act late on Friday, November 5, 2021. The legislation appropriates more than $1 trillion to fund national infrastructure projects, including approximately $65 billion specifically for broadband infrastructure and related programs over the next five years. The bill now heads to the White House for signing. Rural broadband providers will benefit from several of the Act’s programs. This e-Lert summarizes the key broadband provisions for rural broadband providers.

Broadband Equity, Access, and Deployment (BEAD) Program
The National Telecommunications and information Administration (NTIA) will distribute $42.45 billion to the states based on the number of unserved locations in each state, with an initial minimum allocation of $100 million for each state. The remainder of the funds will be distributed based on each state’s unserved locations, defined as those lacking 25Mbps / 3Mbps. Private companies, cooperatives, and public-private partnerships will be eligible to receive grant funds through each state. Grants can be used for unserved (25/3Mbps) and underserved (less than 100/20Mbps) projects; connecting anchor institutions; data collection, broadband mapping and planning; installing CPE to eligible multi-family residential buildings; providing affordable internet-capable devices; and other uses determined by NTIA. Except for high-cost areas, grant funds may cover a maximum of 75% of the project costs, but grantees may use funds from the four previously passed COVID-19 response laws to meet the remaining 25%. Funded projects must deliver 100/20 Mbps within four years and must offer at least one low-cost broadband service option.

Middle-Mile Infrastructure Grant Program
Congress appropriated $1 billion to NTIA for a competitive middle-mile grant program to connect unserved and underserved last mile areas to the Internet backbone. Rural carriers are among the entities eligible for this program, which encourages public/private partnerships and may fund up to 70% of the middle-mile project costs. NTIA must release its notice of funding within the next six months.

Affordable Connectivity Program
Congress extended and modified the Emergency Broadband Benefit Program (EBBP), now called the Affordable Connectivity Program (ACP), with $14.2 billion to the FCC. The Act decreases the non-tribal monthly household benefit from $50 to $30.

ReConnect
Congress appropriated $2 billion for the fiscal year ending Sep. 30, 2022, to Rural Utilities Service’s existing the ReConnect program for broadband grants, loans and grant/loan combinations. ReConnect requires broadband speeds of at least 100/20 Mbps.

Tribal Broadband Connectivity Program
Congress appropriated $2 billion to the existing Tribal Broadband Connectivity Program for 2021-2022 fiscal year and to remain available until expended.

Appalachian Region High-Speed Broadband Deployment Initiative
Congress appropriated $1 billion over five years to the Appalachian Regional Commission for High-Speed Broadband Deployment and Regional Energy Hub initiatives. Congress directs that at least 65% of the funds be used for the broadband initiative. The Regional Commission must coordinate its grants with the FCC, NTIA, and the Economic Development Administration (EDA) to avoid duplication of federal funding programs.

Digital Equity Programs
Congress appropriated $1.5 billion over five years to promote the achievement of digital equity, support digital inclusion activities, and build capacity for efforts by states related to broadband adoption. States must develop a State Digital Equity Plan and submit it with its application for grant funds. The Commerce Department will also create the Digital Equity Competitive Grant Program to award $1.25 billion over five years to support those efforts.

Other Notable Items

Beyond the various grant programs contained in the legislation, Congress directed the FCC to take action in three broadband-related administrative programs:

  • $10 million to the FCC for a Broadband Deployment Locations Map. This program is funded separately from the FCC’s broadband DATA maps but will incorporate broadband service availability reported by those maps.
  • The FCC is directed to examine and make recommendations on how it should achieve universal service goals for broadband and submit to Congress its report in 270 days after the Act’s enactment.
  • Congress also directs the FCC to develop rules for consumer labels for broadband service no later than one year of enactment. After the FCC develops the rules, broadband providers must use broadband consumer labels when giving information to customers regarding broadband internet access service plans.

In addition, the legislation includes funds for improving the nation’s electric grid through smart grid and boost its security. The Rural and Municipal Utility Advance Cybersecurity Grant and Technical Assistance Program will provide $250 million for grants to help rural and municipal utilities deploy advanced cybersecurity technologies for electric utility systems and increase participation in threat sharing programs. As well, $3 billion will go towards a Smart Grid Investment Matching Grant Program to fund up to 50% of qualifying smart grid investments.

Please contact Douglas Meredith at 801-294-4576 or Carl Perry at 512-338-0473 if you have questions or concerns about the Infrastructure Act or would like JSI’s help in planning your participation in these new opportunities.

2 11, 2021

CAF-BLS Cos. Without Locations in HUBB Must Contact USAC About Samples for Broadband Pre-Testing

2021-11-02T14:02:42-04:00November 2, 2021|e-Lerts|

Legacy CAF-BLS companies that may not have adequate locations in the HUBB for a random sampling before broadband performance pre-testing begins in January 2022 must contact USAC by Monday, November 8, 2021. All Legacy CAF-BLS companies, along with A-CAM II, Alaska Plan and CAF Phase II Auction carriers, must begin pre-testing in first quarter 2022 as part of the FCC’s performance measures testing framework. Companies will use a USAC-generated random sample of broadband locations deployed (and reported in the HUBB) that have active subscribers.

However, USAC has identified three scenarios where CAF-BLS companies may not have any locations or enough locations reported in the HUBB for the random sampling:

  1. Fully Deployed Prior to May 25, 2016 – Under this scenario, CAF-BLS companies have not reported any locations into the HUBB because they were fully deployed in their service territory prior to May 25, 2016 and therefore have no HUBB filing obligations.
  2. No Reported Deployments to Date – Since CAF-BLS companies only have one deployment milestone at the end of 2023, there may be some companies that do have a HUBB filing obligation but have not yet submitted any locations in HUBB due to no deployment of 25/3 broadband during the period May 25, 2016 to present.
  3. Limited Deployment to Date – Under this scenario, CAF-BLS carriers have entered some locations in the HUBB due to deployment of 25/3 broadband after May 25, 2016 but must rely on locations that were fully deployed prior to May 25, 2016 to meet their buildout obligations. For example, a company may have a buildout requirement of 3,000, but 2,800 of these were prior to May 25, 2016 and therefore only 200 locations are in the HUBB.

USAC has asked any Legacy CAF-BLS companies that fall under scenarios 1 and 2 to contact them at HCproduct@USAC.org by November 8. USAC is meeting with the FCC to discuss scenario 3 and is planning to send an updated email with language that is directly applicable to this situation. USAC is likely to ask companies under scenario 3 to tell them how many locations and at what speeds were deployed pre-2016 to be added to those that they did upload into HUBB. Regardless, USAC will follow up with CAF-BLS companies under each of the three scenarios on how to obtain random location samples for speed and latency pre-testing in 2022.

If you have any questions about this requirement or any other questions related to broadband performance testing, please contact Lans Chase at 770-569-2105 or Paul Nesenson at 651-452-2660.

15 07, 2021

JSI’s 2021 Financial Seminars

2021-11-02T13:08:35-04:00July 15, 2021|Archived Events|

2021 Financial Seminars

JSI’s Part 32 & Part 64 Accounting Seminar provides a detailed review and explanation of the FCC’s Part 32 and Part 64 accounting principles and applications. JSI staff discuss specific issues of the FCC’s accounting procedures, including the “allowable” expenses for USF and NECA purposes, as well as increased regulatory scrutiny of the Part 64 allocation mechanisms. This seminar also covers the ongoing USAC and NECA audits and reviews. And new for 2021, we also covered how to account for broadband grants and COVID-19 relief efforts your company may have received.

Topics:

  • Part 32/64 Introduction
  • Part 64 and elements of the Cost Allocation Manual (CAM)
  • NECA & USAC audits
  • Rate base
  • Operating revenues
  • Expenses
  • Taxes
  • Accounting for FCC and other grants
  • Accounting issues related to the Federal PPP program
  • Changes to Part 32 Accounting to conform to GAAP accounting

Learning Objectives: At the end of the seminar, attendees are be able to:

  • Understand concepts and principles of the FCC Part 32 accounting rules
  • Determine sources and drivers of primary regulated revenue streams, including USF and NECA Settlements
  • Understand the hierarchy of Cost Allocations contained within Part 64 of the FCC’s rules
  • Compare and contrast valuation of transactions between affiliated entities and non-affiliated entities
  • List the primary areas of focus of USAC OIG and other audit processes

Attendees receive electronic copies of the seminar materials and JSI’s Accounting Manual for the Independent Telephone Company. The seminar includes lecture, group discussion, and sample accounting problems. Everyone is encouraged to participate.

This is a basic level course for accountants, bookkeepers, and auditors, as well as telco staff looking to gain a better understanding of telecommunications and FCC accounting requirements. Attendees are eligible for 8 hours of CPE credit (see below for more information).

CPE Information

CPE Credits & Information: This course offers 8 hours of Accounting CPE credit. For those interested in earning CPE credits, you will be required to respond to a series of engagement activities throughout the seminar sessions. The number of credits you receive will be based on the engagement activities you complete, as well as the amount of time spent in the meeting. The Accounting Seminar is considered an “Overview” program through NASBA classification. No prerequisites or advanced preparation is required for this course.

Delivery Method: All JSI seminars are “group-live” sessions as defined by NASBA.

CPE Sponsorship Information: JSI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

Questions?

For questions or complaints about the seminar, registration, or program cancellation policies, please contact Leah Yoakum, Seminar Administrator, at 301-459-7590.

The FCC’s never-ending changes to the universal service and access charge regimes continue to add levels of complexity to the cost settlement system and significantly threaten your settlements and revenue streams. Understanding the allocation of costs and maximizing cost recovery, especially with the current pressures on your revenue streams, is critical to continued success. JSI’s Separations & Access Seminar focuses on responding to today’s broadband network and services, in addition to its usual assessment of cost settlements, regulated and non-regulated allocations, jurisdictional categorizations, access procedures, and intercarrier compensation. The 2021 seminar included the continued reform of Universal Service funding mechanisms; data reporting and compliance for A-CAM electors; special access/BDS issues; using operational and financial data to manage for success; and federal and state grants and loans issues and opportunities.

Topics:

  1. Separations concepts and principles
  2. Settlements and compensation
  3. Accounts affecting the separations process:
    • Part 32, USoA
    • Part 64
    • Regulated / non-regulated allocations
  4. NECA cost issues
  5. NECA & USAC audits
  6. A review of the cost study and cost allocation process, including the analysis of the telephone network, operating expenses and other inputs
  7. Broadband
    • Potential policy shifts
    • Current and proposed settlements
  8. Part 69 – Access Charges and the Recovery of Interstate Costs
  9. Federal Universal Service Funding
    • Overview of the categories
    • Current and proposed policy shifts
  10. Emerging trends and issues
  11. Projecting future revenue streams associated with Universal Service and FCC access charges

Learning objectives:
At the end of the seminar, attendees will be able to:

  • Understand how changes in FCC rules impact separations and settlements
  • Compare and contrast the FCC Part 36 Separations rules for various Part 32 Accounting groups
  • Understand the FCC’s High Cost Support Mechanisms, including A-CAM and Legacy programs and potential future changes
  • Identify the primary drivers of Federal High Cost Loop and other USF mechanisms
  • Define the steps involved in determining the Interstate Revenue Requirement
  • Analyze regulated revenue sources for purposes of budgeting and forecasting of future results

This is a basic level course for separations, settlement, and access personnel new to this area or company, or with responsibility for financial or operational issues. Other management, financial, and regulatory staff who rely on or make use of separations and access data will also benefit from this seminar. Attendees are eligible for 20 hours of CPE credit (see below for more information).

CPE Information

CPE Credits & Information: This course offers 20 hours of Specialized Knowledge CPE credit. For those interested in earning CPE credits, you will be required to respond to a series of engagement activities throughout the seminar sessions. The number of credits you receive will be based on the engagement activities you complete, as well as the amount of time spent in the meeting. The Accounting Seminar is considered an “Overview” program through NASBA classification. No prerequisites or advanced preparation is required for this course.

Delivery Method: All JSI seminars are “group-live” sessions as defined by NASBA.

CPE Sponsorship Information: JSI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

Questions?

For questions or complaints about the seminar, registration, or program cancellation policies, please contact Leah Yoakum, Seminar Administrator, at 301-459-7590.

13 07, 2021

NTIA Funding Application Deadlines Quickly Approaching

2021-11-02T13:08:42-04:00July 13, 2021|e-Lerts|

Two NTIA grant programs providing more than $1 billion for broadband projects are accepting applications but the deadlines for both programs are right around the corner. NTIA’s Broadband Infrastructure Program (BIP) has $288 million in funding for government entities. And the Tribal Broadband Connectivity Program will distribute $980 million for tribal broadband deployment and adoption. Broadband providers are not eligible stand-alone applicants of either program, but many of the government and tribal entities vying for the grants will need support from current broadband providers to make a successful application. These programs provide a unique opportunity to build relationships in the community and serve areas that are not economical without grant funding. If you are considering participating as a partner with a government entity or a Tribal group, you must act soon. BIP program applications are due August 17. The Tribal Broadband Connectivity Program applications are due September 1.

NTIA’s BIP is looking for both last mile and middle mile project applications between $5 million and $30 million, but applications outside those ranges will be considered (See JSI’s May 24, 2021, e-Lert for more information). In addition, the partner can be the owner of the plant constructed if they comply with the other requirements of the grant. Lastly, there is no matching requirement, but there is additional scoring if a 10% match is provided.

The NTIA Tribal program is looking for applications between $1 million and $50 million for broadband deployment applications and between $50,000 and $2.5 million for increased adoption applications.  However, like the NTIA BIP applications outside those ranges will be considered.  There is no restriction for the commercial partner from owning the constructed plant and there is no matching requirement.

If your company is hoping to participate in an application for either program, you will need to act now. If you need assistance, JSI can support your application with maps, check lists, financial projections, project management, support for the narratives, and engineering support. If you would like our assistance or if you have questions about the requirements for either program, please contact Amanda Molina at 321-985-5709, Lans Chase at 770-569-2105 or Valerie Wimer at 301-459-7590.

23 06, 2021

Webinar Duo: Broadband Funding – Where’s the Money & How to Plan for Success

2021-11-02T13:09:56-04:00June 23, 2021|Webinar Recordings|

Expanding broadband, particularly in rural America, is finally in the spotlight after the COVID-19 pandemic has shown the need for everyone to be connected. We are seeing billions of dollars being appropriated on the federal and state levels for broadband buildout and other programs to connect Americans to their work, schools, doctors, and other institutions.

This flood of money will provide many opportunities for broadband providers, but you need to keep track of these new developments and prepare for the various programs’ requirements. We recently held a two-part webinar event. During Part One we surveyed all the programs that are authorized and being planned—including state grant deployments, tribal land funds, and NTIA funding programs. Part Two focused on steps you can take today to prepare and what you need to do to be successful in receiving these funds for your deployment.

Part One:

  • Updates on several annual grant/loan programs, including RUS’s ReConnect and Community Connect;
  • How state and local governments plan to use the $220 billion provided in the COVID-19 State Fiscal Recovery Fund and $130 billion in the Coronavirus Local Fiscal Recovery Fund and what portion of those funds could be earmarked for broadband-related efforts;
  • New funding programs under the National Telecommunications and Information Administration (NTIA), including the Economic Development Appropriation and the Broadband Infrastructure Program; and
  • Other programs that may tangentially benefit broadband providers and their customers, such as the Homeowners Assistance Fund and the Emergency Connectivity Fund.

Part Two:

  • Identifying potential target areas even before an application deadline is announced;
  • Starting conversations with potential partners/allies in order to expand eligibility for grants based on the qualification of both parties;
  • Preparing business cases, buildout budgets and financial documents, including letters of support; and
  • Getting set up with required registrations (CAGE codes, Dunns numbers, state registrations, etc.) to speed up your application prep.

Recordings of the full two-part webinar are available for $400. Contact Leah Yoakum or Brenda Cordwell in the Maryland office at 301-459-7590 for more information about these webinars or to purchase the recording.

11 06, 2021

Save the Dates – JSI’s 2021 Financial Seminars

2021-11-02T13:11:07-04:00June 11, 2021|News|

We are excited to welcome everyone back to in-person trainings with our Financial Seminars this fall in Nashville! Begin making plans now for your key accounting and financial staff to attend these two seminars. Our one-day Part 32 & Part 64 Accounting Seminar will be Tuesday, September 28. Then we hope you’ll stay for our Separations & Access Seminar which runs Wednesday, September 29 – Friday, October 1. And as always, you’ll be eligible for CPE credits for both seminars.

Our Accounting Seminar provides a detailed review and explanation of the FCC’s Part 32 and Part 64 accounting principles and applications. Brian Sullivan and Ryan Denzel will once again discuss the FCC’s latest accounting procedures, including the “allowable” expenses for USF and NECA purposes, plus its increased regulatory scrutiny of the Part 64 allocation mechanisms.

The Separations & Access Seminar again will focus on how cost settlements, regulated and non-regulated allocations, jurisdictional categorizations, access procedures, and intercarrier compensation affect today’s broadband-centric network. Brian and Ryan will discuss the Universal Service funding mechanisms; data reporting and compliance; special access/BDS issues; using operational and financial data to manage for success; and federal and state grants and loans issues and opportunities.

Watch for More Information Soon!

Right now, block off September 28-October 1 on your calendar and look for a registration announcement in a few weeks. If you have any questions before registration opens, you can contact Leah Yoakum at 301-459-7590.

2 06, 2021

EBBP Claims for Reimbursement Begin

2021-11-02T13:11:29-04:00June 2, 2021|e-Lerts|

Providers can now start the process for seeking reimbursement through the EBBP Claims System. For the June 1st snapshot, providers can claim reimbursement for any subscriber enrolled in the National Lifeline Accountability Database (NLAD) by May 31st. Unfortunately, most providers reported struggles enrolling subscribers who qualified through the National Verifier into NLAD due to issues with matching the subscriber’s correct personally identifiable information (PII) such as name, address, DOB, etc. USAC requires an exact match for this information as to what appears on the applicant’s National Verifier application. If you are having issues with NLAD enrollments, please contact Lans Chase.

USAC sent out an email yesterday that brought to light a potential issue with processing of EBBP reimbursements. USAC stated that to ensure timely disbursement of EBBP claims, providers should confirm as soon as possible that the FCC Registration Number (FRN) and Dun & Bradstreet Number (DUNS) provided in your company’s EBBP election notice match the Employer Identification Number (EIN) listed in the Commission’s Registration System (CORES) and in SAM.gov. If the EINs do not match, it could impact the timing of your EBBP reimbursement.

To avoid delays in EBBP reimbursements, USAC has requested that all providers check whether the FRN and DUNS provided with their election notice have the same EIN in both CORES and SAM.gov. If the EINs do not match, USAC has asked providers to email them, by June 8, at EBBElection@usac.org and provide the FRN and EIN of the company that matches the DUNS registered in SAM.gov. This will allow USAC to issue EBBP reimbursement and help ensure timely payment processing.

If you have questions on the EBBP NLAD enrollment issues or with EBBP reimbursements, please contact Lans Chase at 770-569-2105.

24 05, 2021

NTIA Announces $288M Broadband Grant Program

2021-11-02T13:11:36-04:00May 24, 2021|e-Lerts|

Money will go to state/broadband provider partnerships

As explained in our January 18 e-Lert, Congress established a new $288 million grant program designed to support broadband infrastructure deployment funded through the National Telecommunications and Information Administration (NTIA). After anxiously waiting for months for NTIA to announce the details, the agency released its Notice of Funding Opportunity (NOFO) this week for the Broadband Infrastructure Program (BIP) and set a deadline of August 17, 2021, for applications.

This funding is available only to fixed broadband providers that partner with their states. Also, the program excludes funding to any areas currently funded by federal or state funding programs, including those that receive Universal Service or ReConnect funds from the Rural Utilities Services (RUS). If these criteria are not an issue for your company, and you are interested in pursuing this funding opportunity, the clock is ticking for you to develop a partnership and find an area to secure a portion of the funding. NTIA is expecting to award 200 grants between $5 million and $30 million per award to covered partnerships and is not requiring cost sharing or matching funds.

What to do now to get started:

  1. Reach out to your state, or political subdivision of your state, to determine partnership opportunities and formulate the partnership’s description. The lead applicant must be the governmental entity.
  2. Locate eligible service areas and the number of households in the potential eligible service areas.
    1. Eligible area(s) are census block(s) in which the minimum broadband service speed of 25/3 is not available at one or more households or businesses within the block.
    2. Areas may not be in counties, cities, and towns with populations of more than 50,000; located in the urbanized area contiguous or adjacent to a city or town of more than 50,000; or in an area where a broadband provider has been selected to receive, or is otherwise receiving, federal or state funding subject to enforceable build-out commitments (e., ReConnect, RDOF, A-CAM).
  3. Broadband projects must be provisioned via fixed broadband and with technologies that are forward looking. Fiber is not required but is encouraged. NTIA will give priority to applications planning to provide 100Mbps download and 20 Mbps upload, but minimum speeds must be at least 25Mbps/3Mbps.

If you would like any assistance with locating eligible areas or with preparing a grant application, please reach out to Lans Chase at 770-569-2105 or Amanda Molina at 321-985-5709.

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