GE Planning


It is quite clear that this administration and its lackey councillors have absolutely no intention of either listening to residents or changing the direction of its planning policy. Item after item for Tuesday night’s council meeting confirms this. It will be more of the same – no consultation, no up-to-date local analysis, and certainly no let up in over development. We come to this conclusion based on the following:

Akehurst’s ‘review’ of the proposed VicSmart legislative changes is overwhelmingly supportive and even self-congratulatory in that the current Housing Diversity versus Minimal Change Areas as practised in Glen Eira will easily be reconfigured into VicSmart. In other words – no change is necessary in Glen Eira –  “It is assumed that there will be an expectation on behalf of the State Government that the new zones will be applied in as neutral way as possible having regard to our existing zones and policies. The strongest likelihood is that this transition from our one existing residential zone (Residential 1 Zone) and policies (Minimal Change/Housing Diversity) to three new residential zones which incorporate our policy intents will be able to occur via a Ministerial (fast track) amendment. If this can be achieved it will occur relatively smoothly and ultimately with an improved outcome”. Of course, what this ‘improved outcome’ will be is not clarified, much less justified and proven. The message however is inescapable – much, much more of the same.

Whereas other councils (Manningham, Boroodara, Kingston to name just a few) can hold information sessions and urge their residents to become involved and put in submissions, all Glen Eira can do is present a self serving report that barely questions the removal of third party rights and other major drawbacks. What we get are nonsense paragraphs such as – “Third party rights (the involvement of neighbours) are not changing. It must be acknowledged however that the flip side of greater land use opportunities for land owner applicants is less involvement by others.”

Next, there’s the C87 Amendment where residents were excluded from having any say prior to the drafting of the Amendment and hence their voices and protests were ruled out of order. Even when the Panel report recommends that Heritage reviews be undertaken PRIOR to removing several properties from Minimal Change Areas and placing them in Housing Diversity, the response is:

This recommendation is not supported. Whilst it is acknowledged that a heritage control in a Housing Diversity Area may be perceived as a mixed (stop and go) town planning message, a heritage control would take precedence over potential development opportunities. It is considered that the two planning controls (i.e. heritage and housing diversity) can co-exist. For these reasons, it is considered appropriate for this area along Balaclava Road to change to a Housing Diversity Area(as exhibited). This policy should not impact on the potential for this area to have heritage protection in the future.”

We should also note that the Panel’s urging for Heritage reviews and other Amendments are barely mentioned. No time lines are provided, no sense of urgency detected. In the end, residents shouldn’t hold their breaths. What they can be certain about is that unless most of these councillors are voted out, then this municipality will continue to bend over backwards to support (over) development anywhere. This is the legacy of Newton and his toadies.

The Panel Report on the C87 Amendment is now out (uploaded here). No surprises as to what the recommendations are. But that’s not the end of the story. The story itself would appear to be one of back room manipulation on the part of administrators and councillors. The only plausible excuse that councillors may have is that they are just plain ignorant or stupid, but ultimately compliant with the questionable agendas implemented by this administration. Here is what we know:

  1. Every important draft amendment has been subject to a Council Resolution to forward it on to the Minister for permission to exhibit. Following permission for exhibition, there is the compulsory ‘consultation’ phase, a potential Panel hearing if objections are raised and then the final Council Resolution as to accepting, adapting, or rejecting the Panel report.
  2. With c87 no such formal resolution to seek permission to exhibit from the Minister has ever been passed. The Minister’s approval was however gained in June 2011- we presume under officer delegated powers with no clear, open council resolution supporting it. In other words, residents did not get to see the proposed Amendment until it had already gone off to the Minister – far too late to change anything!
  3. Following the consultation period and the number of objections, both Lipshutz and Hyams encouraged residents who wished to add properties to the list to put in submissions in the hope that the Panel would listen to their objections. Utter nonsense as we stated in previous posts (https://gleneira.wordpress.com/2012/05/02/c87-crocodile-tears/ AND https://gleneira.wordpress.com/2012/04/27/move-over-sir-humphrey/). No panel was ever going to exceed its terms of reference, and those terms were set solely by the officers. Hence, we need to ask how honest were both Lipshutz and Hyams in their encouragement of residents to waste their time in writing submissions that would without a shadow of a doubt be ignored? Or perhaps we should ask whether Lipshutz and Hyams were just plain stupid and didn’t know any better? Or were they simply indulging in some political face-saving in order to take the heat off themselves and their colleagues for once again dropping the ball and not exercising their duty to set policy that involved the community at the outset? Or finally, as the examples keep piling up, supporting the administration to the hilt at the expense of residents?
  4. The proposed amendment NEVER gave councillors and residents the right to have any input at the most crucial stage – that is, which properties might be added, removed, etc. The officers’ report in fact stated clearly that once an amendment was exhibited it could not be changed and if properties were to be included then this would involve ANOTHER amendment! Yet Lipshutz and Hyams persisted in telling residents that they should put in their submissions to the very Panel that would reject them. If they did not know that this was a useless exercise, then they should have known. If they did know, and continued to perpetrate this myth, then they should be hauled before a code of conduct panel for deliberately misleading the public!
  5. The upshot is that the community has been duped; councillors have either been duped, or been fully complicit in perpetrating this deceit. It once again illustrates exactly what goes on in this council and how the normal and expected processes are abused, distorted, and manipulated to produce predetermined outcomes that do not in any shape or form benefit the vast majority of residents. In Glen Eira, residents are personae non gratis. Their views do not count, their objections do not count, and their aspirations do not count. All residents are good for is to continue forking out higher and higher rates to cover up poorly managed projects (ie GESAC) that do nothing except serve the gigantic egos and current power structures.

Come election time we urge all residents to take these issues into account when they cast their votes.

A huge crowd witnessed the sale of The Alma Club for $7.94 million this afternoon. The buyer will have the opportunity to deduct $330,000 if he wishes to retain the telecommunications pole which is presently sitting on the property. The terms of sale were the handing over of $1 million upon purchase and the rest in June 2013.

Council has once again let the community down badly. Not only has it forsaken an absolute real estate bargain when the asking price was basically $3 million, but they have again shown what a sham the continual cry of lack of open space means to these decision makers – absolutely nothing! Residents need to be asking some very serious questions –

  • why were no real discussions entered into?
  • who made the decision to say ‘no’?
  • why wasn’t this conducted in an open council meeting?
  • is council that cash strapped because of its poor financial management? If so, then how much credence should residents place in the financial statements and budgets?
  • when will these councillors really start taking charge of this municipality and perform their mandated duties instead of leaving practically everything to unelected ‘fat cats’?

We thought it time to have a close look at how Glen Eira compares with its neighbours on up-to-date planning and forward thinking. True to form, most of the central planning policies in Glen Eira date back to the mid or late nineties. Even the promise to include all central policies on council’s website has never materialised. Basically the agenda is ‘business as usual’, with no real updated local analyses, no up-to-date long term articulated vision and certainly no ‘improvements’.

Below we feature the Incorporated/Reference Documents that are listed in the various council planning schemes. We’ve focused on open space, urban design/land use, and heritage. We ask that readers pay particular attention to:

  • The various dates, and
  • The Glen Eira City Council Traffic Report-Child Care Centres Study March 2009. This is supposedly the document upon which the Amendment removing the child care centres from the ‘non-residential uses in residential areas’ was largely founded upon. Yet, it was never mentioned in the officer’s report and has certainly never been placed into the public domain! Another ‘mystery report’ that remains secret and unaccountable.

GLEN EIRA

Glen Eira Long Term Open Space Strategy, City of Glen Eira, 1998

Glen Eira Heritage Management Plan, 1996

Glen Eira Retail / Commercial Strategy, Essential Economics, 1998

Urban Village Structure Plan, Glen Eira City Council, June 1999

Economic Overview, Henshall Hansen & Associates, 1997

City of Glen Eira Business Development Strategy, 1998

Glen Eira 2020, 1996

Housing and Residential Development Strategy, Glen Eira City Council, 2002

Urban Character Study, Anne Cunningham & Anne Keddie, 1996

Glen Eira City Council Traffic Report-Child Care Centres Study March 2009.

KINGSTON

Retail and Commercial Development Strategy 2006

Highett Structure Plan, May 2006

“City of Kingston Heritage Study Stage One Report”, Living Histories, 2000

“City of Kingston Heritage Study Stage Two”, Bryce Raworth Pty Ltd, 2004

Highett Structure Plan, May 2006 

STONNINGTON

Chapel Vision Structure Plan 2007- 2031, City of Stonnington, December 2007.

City of Stonnington, Public Realm Strategy, October 2010

Commercial Strategy: Stonnington City Council, 1999

Forrest Hill Structure Plan; Stonnington City Council, 2005

Heritage Guidelines; Stonnington City Council, 2002

Heritage Overlay Citations; Stonnington City Council (various dates)

Late night liquor licence trading in the Chapel Street Precinct: measuring the saturation levels Research Paper, April 2010

Prahran Conservation Study: Conservation Controls; Nigel Lewis, 1983

Prahran Data Base: Prahran Conservation Study Listing; Nigel Lewis, 1992

Prahran Character and Conservation Study; Prahran City Council, 1992

Review of Policies and Controls for the Yarra River Corridor – Punt Road to Burke Road; Consultant Report, June 2005

Stonnington Open Space Strategy; Thompson Berrill Landscape Design Pty Ltd, 2000

Stonnington Thematic Environmental History, 2006

Stonnington Thematic Environmental History: Update 1 Addendum, March 2009

City of Stonnington Heritage Overlay Gap Study, Heritage Overlay Precincts Final Report, March 2009

Urban Design Strategy; Stonnington City Council, 1998

Waverley Road Urban Design Framework Plan, 2008

PORT PHILLIP

Sustainable Design Policy (2006)

Port Phillip Housing Strategy (2007)

Port Phillip Activity Centres Implementation Plan (2007)

Port Phillip Activity Centres Strategy (2006)

Port Phillip Industry and Business Strategy (2003)

Open Space Strategy (2006, Revised 2009)

Open Space Strategy Implementation Plan Framework (2009)

Foreshore Management Plan (2004)

Port Phillip Housing Strategy (2007)

Port Phillip Design Manual (2000)

South Melbourne Central Structure Plan (2007)

South Melbourne Central Urban Design Framework (2007)

Ormond Road Urban Design Guidelines (2007)

Beacon Cove Neighbourhood Character Guidelines 2010 (SJB Urban, 2010)

Carlisle Street Activity Centre Structure Plan (2009)

Carlisle Street Urban Design Framework (2009)

Caulfield plan gets the nod

Date: August 18,  2012

Philip Hopkins

A $1 BILLION-PLUS development at Caulfield Racecourse that will create a village where hundreds of people will live and work has been given the go ahead.

The Melbourne Racing Club yesterday awarded the contract for the project to the Beck Probuild Consortium. It will be built on five hectares of land next to the racecourse, Caulfield train station and Monash University.

The development is expected to take up to 15 years to complete and will include more than 1500 dwellings of different types, and office and retail space, including a supermarket, pharmacy, cafes, restaurants, and other health and recreational outlets.

During construction, the development is expected to generate up to 5000 jobs and an ongoing 1100 jobs once completed. Construction is tipped to start within 24 months.

The Melbourne Racing Club will also upgrade the racecourse to complement the  project. The winning consortium is a joint venture between Beck Property Group  and Probuild Constructions.

A new street, The Boulevard, will be the heart of the project, which will  comprise three primary precincts:

■Precinct 1, to the west of the development, will be a low/medium-density  residential area.

■Precinct 2 will be a mixed-use precinct with active street frontages,  tree-lined laneways with retail outlets, including a supermarket, specialty  shops, and a restaurant hub established around the new Boulevard road link.

■Precinct 3 will encompass the Smith Street precinct based in the eastern  section of the site next to Caulfield Station comprising a mix of commercial,  residential and retirement accommodation.

Planning approval came after consultation with the City of Glen Eira, the  local community, state planning authorities, local state MP David Southwick and  other stakeholders.

Melbourne Racing Club’s upgrade of the racecourse infield will include five  activated precincts, exercise pods, a jogging trail, a lake pathway, lake  boardwalk, barbecue, toilets, a picnic area, a dog off-leash area, and a junior  football pitch.

Parking for the new project will be fully contained within the development,  with race-day parking staying in the existing racecourse car parks.

A communication plan will be produced to outline the timing and detail of the  development as master plans are finalised.

MRC chairman Mike Symons said the development would  bring a new vitality to  the area.

Consortium director Sam Beck said the project would deliver a world class new  suburb for Melbourne.

Probuild managing director Phil Mehrten said it was a great outcome for  Melbourne’s construction industry.

”This will mean jobs and investment, and is a vote of confidence in the  future of Melbourne’s development industry,” he said.

Read more: http://www.smh.com.au/business/caulfield-plan-gets-the-nod-20120817-24e03.html#ixzz23qrFe1Ed

The Leader story below is the result we presume from another public question that was asked at last council meeting and as per norm, was woefully responded to. Also included is an online comment from a resident.

Bentleigh open space concern

13 Aug 12 @  02:16pm by Jessica Bennett

The Clover Estate at East Bentleigh

The Clover Estate at East Bentleigh

A BENTLEIGH EAST man is concerned that despite Glen Eira having the lowest amount of open space in Victoria, it is taking cash contributions instead of building new parks.

Newton Gatoff said a subdivision on the corner of Ellen and Malane streets, to be the Clover Estate, included 50 blocks that in 2010 sold to a developer for $52 million.

Mr Gatoff, who intends to run for Glen Eira Council in the November elections, said when a new subdivision was over a certain size, land was required to be set aside for its residents for open space.

But under the Subdivision Act, a council can accept payment in the form of a public open space levy from the developer instead, as was the case with Clover Estate.

“Glen Eira Council is not using the open space money for what it was intended,” Mr Gatoff said.

“Glen Eira has the lowest amount of open space for a council in Victoria.

“Where did the money go and where is our park?

“They are legitimate questions that never received an answer.”

Glen Eira Council spokesman Paul Burke said the public open space contribution required by the original permit was 4.5 per cent of the land value ($450,000) paid to the council in May.

He said money collected via an open pace contribution must be spent on land acquisition for open space purposes or improvements to existing open space and council had significantly spent on both, including re-seeding sporting ovals and parks and installing water efficient drip irrigation systems.

Bert Haskins writes: Posted on 14 Aug 12 at  08:29am

This Council loudly proclaims it actively looks for opportunities to increase Glen Eira’s public open space yet their record is abysmal.  As developers continue to ravage Glen Eira which results in even less open space per capita, this Council focusses on building supersized pavillions and carparks that are underutilised and consume more open space, planting warm season grasses and concrete plinthing.  At the same time Council either dismisses out of hand the opportunity to expand open space by purchasing the heavily discounted Alma Club or let’s the windfall land of the Booran Road Reservoir remain derelict for over 10 years .

 

590 Orrong Road Update

STONNINGTON TO CHALLENGE VCAT DECISION AT SUPREME COURT

Stonnington Council will appeal the recent VCAT decision on 590 Orrong Road, at the Supreme Court, based on an ‘error of law’.

The Victorian Administrative Appeals Tribunal (VCAT) had ruled in favour of Lend Lease, in July, granting a permit for a major, controversial development at 590 Orrong Road and 4 Osment Street, Armadale, which drew significant community objection.

Stonnington Mayor, Councillor John Chandler said: “Council’s focus on appealing the VCAT decision is based on legal advice that there is an ‘error of law’ to be pursued, which presents the potential for a different decision to have been reached.

“The legal opinion considers that an error of law could be established, principally based on the tribunal’s express statement that “the number of objections to the proposed development was an irrelevant consideration.”

Cr Chandler said: “It is considered that VCAT failed to give due regard to significant community input and has made a decision that is not supported by the local community or Council. In Council’s view, the decision reflects a lack of consideration of neighbourhood character or respect for local community concerns around appropriate development.

“Council remains committed to seeking an appropriate planning outcome for the site.”

Documentation was lodged on Monday 6 August for Stonnington Council to be granted leave to appeal to the Supreme Court.”

Source: Stonnington Council Media Release. There’s also an article in today’s Age by Jason Dowling. See: http://www.theage.com.au/victoria/supreme-court-challenge-to-armadale-complex-20120810-24017.html

No surprises that other councils such as Yarra and Kingston are on the front foot when it comes to speaking their mind, and encouraging residents to participate in feedback to Matthew Guy’s recently announced shakeup of the planning system. Glen Eira on the other hand is once again SILENT. Nothing on the website, nothing in chamber except for a few mumbled sentences, but certainly no indication that Council is inviting public comments and urging residents to have a say. We remind readers that not for the first time has this council put in submissions that were drafted behind closed doors (in secret) and submitted without a formal council resolution – ie VEAC submission, Parking Review & Speed Limit Review. We anticipate that exactly the same thing will happen here – that is, if council even bothers to put in a submission. Our major concern of course is governance and how submissions made in council’s name, and of such importance, do not warrant an agenda item and thus formal and legal endorsement via council resolution. It’s staggering that other councils continually publish their draft submissions. In Glen Eira, everything is secret and a travesty of good governance.

Below we present Yarra Council’s Media Release, then Kingston’s appeal from the Moorabbin Leader.

CITY OF YARRA

Concerns about State Government’s zoning proposals

24 July 2012

In mid-July 2012, the Minister for Planning announced that some changes were to be made to Victoria’s planning zones.

The Government is seeking feedback on the proposed changes by 21 September.

Council encourages community members to look into what is proposed as the changes are likely to have a significant impact in Yarra.

Council staff have undertaken a preliminary assessment of the changes and understand that the changes could result in the following:

  • In business and some      industrial zoned areas, a supermarket of up to 2000 square metres with an  additional 500 square metres of shops could proceed without the need for a  planning permit
  • In some of the residential zones, small shops, offices and cafes could proceed without the need for a  planning permit if they are within 100 metres of a business/commercial zone and if they share the same street frontage.
  • Medical centres of up to 250 square metres could proceed without the need for a planning permit in all of the proposed residential zones.

The changes could therefore mean that some developments and changes in land uses could go ahead without public input and Council assessment under the proposed zone provisions. Significant changes could occur in local neighbourhoods without an opportunity for community members to lodge formal objections and without an opportunity for Council to weigh up the issues and decide whether or not to issue a permit.

For more information on the proposed zoning reforms and how you can have a say, visit the Department of Planning and Community Development website.

You may also be interested in the State Government’s intention to prepare a new metropolitan planning strategy. More information on that project is also available on the Department of Planning and Community Development website.

Kingston Council wants comments on planning proposal

 

KINGSTON Council is urging residents to have their say on the biggest change to planning rules in decades.

The State Government’s proposed new planning zones will have the potential to make a big impact on many Kingston neighbourhoods, as well as green wedge areas.

The neighbourhood residential zone will be the toughest of the new zones.

It will allow councils to restrict the number, height and block size of new homes.

The reforms will also make agricultural operations in green wedge areas easier by getting rid of the need for planning permits.

Public feedback on the proposed changes is open until September 21.

Kingston Mayor John Ronke said the council hoped to include residents’ views in its submission.

Residents must contact the council by August 6.

Planning Minister Matthew Guy said the neighbourhood residential zone gave planning power back to councils.

But Opposition spokesman Brian Tee said the new rules would protect only Melbourne’s wealthier suburbs from developers.

Jessica Wray

Trucks would cause chaos 

REGARDING the plans for the recycling plant in Glenhuntly Rd, Carnegie, traffic and noise are already issues in this area given on-road parking, the trams and a level crossing down the road.

Trucks coming and going will cause further traffic congestion and noise, not to mention the dust and pollution local residents and businesses will have to deal with.

I can only imagine how teachers and parents at Glen Huntly Primary will feel about children walking to and from school in the new ‘‘industrial’’ Carnegie. Hopefully, Glen Eira Council will dismiss this proposal immediately.

Given the application to rezone the area and build residential apartments next door, I wonder how the proposals will affect one another. Who wants to buy an apartment next door to a rubbish factory? 

Axe the plan immediately 

THIS is a ridiculous proposal for the area. The council really needs to stop this without delay.

Imagine the dust and noise 

I HAD the misfortune of walking past this place when they were operating without a permit. They dumped a load of old bricks and the noise and dust was unbelievable.

It’s the wrong place 

I THINK it’s disgraceful in this day and age that they would allow people’s lives to be affected in such a thoughtless way by toxins, fumes and noise. These places belong in outer industrial zones and not in the middle of residential areas near schools, flats, aged people’s homes and so on.

Hand over the permit 

SURELY someone can do something to stop this ridiculous plan. Is this a grab for rates from Glen Eira Council? If the council has no rateable property outside residential areas it should give the planning permit to neighbouring Kingston or Monash, who have plenty of vacant land.

We raise an issue that has important ethical implications about the interdependence of developers and council planners. Two questions stand out:

  1. How ‘impartial’ should a council planning officer be when he/she drafts the report to council?
  2. To what extent should officers’ reports to council be an almost verbatim transcript of the developer’s proposal or, if not verbatim, then a very close paraphrasing of the application?
  3. To what extent do officers rely completely on developers’ reports and to what extent to they do their own homework and investigations?

We focus here on two documents related to the proposed C80 amendment which seeks to rezone parts of Glen Huntly Rd in order to create a 5 storey, 62 unit dwelling with car parking waiver. Part of this site also featured in this week’s Leader, since there is another application in to create a recycling facility on a section of this proposed rezoned land. (See our previous post: https://gleneira.wordpress.com/2012/07/31/pilling-foot-in-mouth-disease/)

We’ve located the Urbis ‘Planning Permit Report’ (104 pages) and compared this with the five and a half page officer report presented to councillors. It’s important to note that of this five and a half pages, more than two are taken up with the usual preliminaries and protocols – ie the processes involved in seeking amendments, and an opening page which outlines the proposal, plus the aerial view of the site. That leaves roughly 3 pages upon which councillors have to make their decision. Hardly adequate we believe! And especially inadequate when justification for recommending the proposal rests on such nebulous language as ‘appropriate’, “consistent”, “adequately cater”, etc.  This is the part that is important. The rest of the item consists of architect drawings and a ten page draft Permit Application. We doubt that any councillor actually read this ‘permit’!

We’ve extracted some paragraphs from the Urbis report and compared this with the council planner’s effort. The selective plagiarism should be obvious to everyone and makes us seriously question not only the ethics of this, but also whether council planners by quoting, or paraphrasing so liberally can be seen as impartial adjudicators?

THE URBIS REPORT

COUNCIL OFFICER’S   REPORT

“The   proposed amendment provides opportunities for new economic growth and   additional housing supply within the Glen Huntly Activity Centre. The   existing N3Z applied to the subject land is designed to encourage the   development of industries and associated uses which are becoming increasingly redundant within this area. This is evidenced by the number of vacant   premises within the subject land. The rezoning of the land to B2Z allows   for a different mix of possible land use outcomes that would be consistent   with the Glen Huntly Activity Centre.” The existing Industrial 3 Zone (IN3Z) applied to 1232-1258   Glen Huntly Road, supports industries and associated uses, which are becoming increasingly redundant within   this area. This is evidenced  by the number of vacant premises and nonindustrial uses operating with the area. Also the industrial zoning   currently prohibits any residential use/development on the land (other than a   caretaker’s dwelling).

Therefore the rezoning has the potential to create   opportunities for economic growth and additional housing supply consistent with the Glen Huntly Neighbourhood Centre.

 

“The   majority of the subject land is currently zoned for industrial use. A Site Assessment   Report, prepared by Douglas Partners has indicated that a number of the sites   have had past and current land uses that are considered to be of medium to high potential for contamination,   including 122 Grange Road, Carnegie. Therefore the amendment seeks to   implement an Environmental Audit Overlay to the land to ensure that it is suitable for any future sensitive uses. A   chronological land use history of all the sites has been undertaken to   identify whether  the land is potentially contaminated. Based on these findings it is considered that   there is medium to high potential for contamination. Therefore the application of an Environmental Audit Overlay (EAO) to all of the land is required, to ensure  that the land is suitable for any sensitive use, such as residential, in the future.

 

“The   Framework Plan identifies the land as being located within a Neighbourhood   Activity Centre (NAC). It is important   to note, that the activity centre designation of the Glen Huntly is different   from (sic) State Government’s   perspective under Melbourne 2030. The B2Z encourages a range of office   and associated commercial uses, which complement the core retail uses of the   centre and achieve the desired strategic outcomes for an activity centre of   this level.” The   rezoning of 122 Grange Road from Residential 1 to Business 2 is considered appropriate and will reflect the long term commercial use that has operated on the land since the 1950s. It will also facilitate future mixed use redevelopment opportunity of  this prominent corner location.

It is important to note that there currently is a discrepancy between State and Local Planning Policy in regards to the identification of the Glen Huntly Activity Centre.

State   Planning Policy identifies Glen Huntly as a Major Activity Centre (MAC). Council’s Local Planning Policy identifies this area as a Neighbourhood Centre.

 

 

 

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