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H-GAC Method of Distribution for CDBG Disaster Recovery Program
Adopted February 17, 2009, Amended May 19, 2009
Houston-Galveston Area Council
Method of Distribution for
Community Development Block Grant Disaster Recovery Program
Adopted by H-GAC Board of Directors February 17, 2009, Amended May 19, 2009
Background
On November 26, 2008 the US Department of Housing and Urban Development (HUD)
announced the allocation of $2.1 billion dollars in disaster recovery assistance to 13 States and Puerto
Rico. The emergency funding is intended to help address unmet housing, economic and infrastructure
needs following the natural disasters of 2008. HUD allocated the majority of the funding ($1.3 billion
dollars) to the State of Texas. The emergency funding is provided through HUD’s Community
Development Block Grant (CDBG) Program and will support the State’s long-term disaster recovery.
This is the first allocation of approximately $6.5 billion dollars appropriated by Congress immediately
following Hurricane Ike.
Although entitlement communities like Harris County, the City of Houston and the City of
Galveston typically receive CDBG funds directly from HUD, H-GAC understands that the distribution of
all CDBG funds for disaster recovery will be administered through the State of Texas. These funds can be
used to address housing and infrastructure damage caused by Hurricane Ike. The majority of funding must
benefit low and moderate income citizens.
Governor Perry has designated the Office of Rural Community Affairs (ORCA) as lead state
administrator for CDBG disaster recovery funds. The Texas Department of Housing and Community
Affairs (TDHCA) will work with ORCA to administer the housing portion of the funding.
The framework for distributing funds is a State Action Plan which includes funding priorities,
eligibility criteria, types of eligible projects, and local match/cost sharing requirements. The State’s draft
Action Plan identifies the Councils of Government as the entity that will develop the Method of
Distribution for their respective regions and allocates $814,133,492 to the H-GAC region. The State has
asked that H-GAC recommend a method of distribution that apportions funds for housing and non-
housing (community infrastructure) activities. H-GAC may also recommend that funds be directly
allocated by the State or competitively awarded. H-GAC recommendations are due to the State on
February 20, 2009.
H-GAC posted the initial Draft Method of Distribution on the home page of the H-GAC website
during the evening of February 6, 2009.
Public Notification and Input Process
H-GAC conducted a series of public outreach sessions with local leaders to inform them of the
Method of Distribution process and to seek input on local priorities of housing and non-housing needs.
H-GAC also held two formal public hearings to receive public comment on the proposed method of
distribution on February 11 and 12, 2009. H-GAC posted notices in the Houston Chronicle, Galveston
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H-GAC Method of Distribution for CDBG Disaster Recovery Program
Adopted February 17, 2009, Amended May 19, 2009
County Daily News, on the Secretary of State’s Texas Register/Open meetings webpage, and on the home
page of the H-GAC website at www.h-gac.com.
Adoption, Approval and Amendment
The H-GAC Board of Directors adopted the Method of Distribution on February 17, 2009. The
Office of Rural Community Affairs (ORCA) conditionally approved the regional Method of
Distribution on March 5, 2009, with the caveat that the counties contained within the regional
Method of Distribution further develop processes to either prioritize non-housing projects or
directly sub-allocate funding to the cities within each county. ORCA approval of either process
is required before entities can submit non-housing project applications for consideration of
funding. ORCA is requiring that approved scoring criteria and county-level Methods of
Distribution be included in the regional Method of Distribution as an Appendix.
The H-GAC Board of Directors approved the necessary amendment on May 19, 2009.
The amendment also included a redistribution of the set aside categories for Liberty County.
Relevant portions of the amendment are included within the text of the Method of Distribution.
The entire amendment is included as Appendix B of this Method of Distribution.
Housing and Non-Housing Activities
H-GAC conducted a detailed analysis of FEMA housing damage assessments, HUD low-
moderate income demographics, and severity of damage. H-GAC also utilized infrastructure data used by
the State in development of the Governor’s Texas Rebounds report (data sources included as Appendix
A).
The distribution of funding between housing and non-housing activities is based upon the above-
referenced damage and low-moderate income demographics analysis; input from local governments,
faith-based organizations, long-term recovery groups, the public; and, the above-referenced State and
FEMA reports.
Total available: $814,133,492.
Recommended funding apportionment by housing and non-housing:
Category Percentage Dollar Amount
Housing 56% $452,839,093
Non-Housing 44% $361,294,399
Some local governments in the region have expressed an interest in implementing economic
development projects. A specific amount for economic development has not been identified at this time.
Economic development projects would come from the non-housing portion of the region’s allocation.
H-GAC strongly recommends that the State allow flexibility in reallocating funding
between housing and non-housing activities if the State and local governments are unable to spend
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H-GAC Method of Distribution for CDBG Disaster Recovery Program
Adopted February 17, 2009, Amended May 19, 2009
the funding in a timely fashion. The flexibility to reallocate between activity categories is critical if the
State intends to assist the region and the citizens of Texas in recovering from Hurricane Ike. Progress in
committing funding to housing and non-housing projects should be evaluated on a quarterly basis and
funds reallocated if housing programs cannot deliver housing or if non-housing projects cannot be
initiated in a timely fashion.
Direct Allocations and Set Asides
The Method of Distribution recommends direct allocations to the large entitlement communities
of the City of Galveston, Harris County and the City of Houston, and to counties which because of the
extent of impact by Hurricane Ike would receive substantial funding allocations, in excess of $50 million.
The remaining funds are distributed across the region as set asides at the county level. H-GAC developed
the direct allocations and set asides based on FEMA housing damage reports, severity of damage, low to
moderate income demographics, and infrastructure data associated with the Governor’s Texas Rebounds
report. This method provides a weighted allocation for the most impacted areas of the H-GAC region. An
overview of the weighting factors is included below.
FEMA Housing Damage Assessments and Severity of damage – H-GAC analyzed FEMA home
damage reports for counties, cities, and unincorporated areas within the eligible portions of the H-GAC
region. The analysis included developing an estimated dollar value for each category, from minor
damage to destroyed. H-GAC also reviewed low-moderate income data available through HUD and
included the results of that analysis in its funding allocations. Source data is included in Appendix A.
This method comprised the allocation of 60% of the funding.
Critical Infrastructure and Texas Rebounds – H-GAC analyzed critical infrastructure data used in
the development of the Governor’s Texas Rebounds report. Source data is included in Appendix A. This
method comprised the allocation of 40% of the funding.
H-GAC recommends direct allocation of funding to the following large, impacted entitlement
communities and counties receiving greater than $50 million: City of Galveston, Harris County, City of
Houston and to Galveston County and Chambers County. By direct allocation, these communities will
receive funds from ORCA and TDHCA to conduct housing and non-housing programs. Direct
allocations to counties include all cities therein, except for City of Galveston and City of Houston.
Counties will need to meet HUD requirements to develop criteria for distributing funds within the county
and jurisdictions therein.
Set asides for the remaining counties are contingent upon identifying eligible housing and non-
housing projects which conform to CDBG guidelines. Management of projects in the set aside category
may include substantial assistance from third party contractors, H-GAC, ORCA, or TDHCA to ensure
appropriate capacity is available to administer funds and manage projects (especially housing). Set asides
counties include all jurisdictions therein, and processes for distributing funds must conform to HUD
requirements.
Recommended direct allocation and set-asides by jurisdiction:
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H-GAC Method of Distribution for CDBG Disaster Recovery Program
Adopted February 17, 2009, Amended May 19, 2009
Percent to Non-Housing
Entity Total Amount ($) Housing Housing ($) ($)
City of Galveston $ 267,387,055 60% $ 160,432,233 $ 106,954,822
Rest of Galveston County $ 165,839,163 60% $ 99,503,498 $ 66,335,665
Rest of Harris County $ 140,693,072 40% $ 56,277,229 $ 84,415,843
City of Houston $ 109,070,706 80% $ 87,256,565 $ 21,814,141
Chambers County $ 69,738,606 30% $ 20,921,582 $ 48,817,024
Liberty County $ 21,898,771 40% $ 8,878,923 $ 13,019,848
Brazoria County $ 17,409,490 50% $ 8,704,745 $ 8,704,745
Montgomery County $ 11,515,395 60% $ 6,909,237 $ 4,606,158
Matagorda County $ 5,984,150 20% $ 1,196,830 $ 4,787,320
Fort Bend County $ 2,636,845 60% $ 1,582,107 $ 1,054,738
Walker County $ 1,555,801 60% $ 933,481 $ 622,320
Waller County $ 325,698 60% $ 195,419 $ 130,279
Austin County $ 77,508 60% $ 46,505 $ 31,003
Wharton County $ 1,232 60% $ 739 $ 493
Total $ 814,133,492 56% $ 452,839,093 $ 361,294,399
H-GAC strongly recommends that the State allow flexibility in reallocating funding
between entities if local governments are unable to spend the funding in a timely fashion. The
flexibility to reallocate between entities is critical if the State intends to assist the region and the citizens
of Texas in recovering from Hurricane Ike. Progress in committing funding to housing and non-housing
projects should be evaluated on a quarterly basis and funds reallocated if housing programs cannot deliver
housing or if non-housing projects cannot be initiated in a timely fashion.
Comments and Questions
The Houston-Galveston Area Council (H-GAC) hosted two public hearings to solicit comments on
the method of distribution for Community Development Block Grant (CDBG) disaster recovery funds
related to Hurricane Ike and other natural disasters.
Public Hearings were held: Wednesday, February 11, 2009 at 9:30 a.m. – Noon at the Showboat
Pavilion, 416 6th Street North, City of Texas City and Thursday, February 12, 2009 at 1:30 p.m. – 4:00
p.m. at the H-GAC offices, 3555 Timmons Lane, Houston, Texas 77027, 2nd Floor Conference Room A.
H-GAC invited the public to attend these meetings and to provide comments to H-GAC. H-GAC
accepted written comments through 12 noon, Monday, February 16, 2009 to:
ikecdbg@h-gac.com ,
by fax to 713-993-4503,
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H-GAC Method of Distribution for CDBG Disaster Recovery Program
Adopted February 17, 2009, Amended May 19, 2009
or by mail to: Chuck Wemple, Economic Development Program Manager, Houston-Galveston
Area Council, P. O. Box 22777, Houston, Texas 77227. General questions can be communicated via
phone at 713-993-2448.
H-GAC will provide for reasonable accommodations for persons attending H-GAC functions.
Requests from persons needing special accommodations should be received by H-GAC staff 24 hours
prior to a function. The public hearing will be conducted in English and requests for language interpreters
or other special communication needs should be made at least two working days prior to a function.
Please call 713-993-4557 for assistance.
More information can be found on the H-GAC website at www.h-gac.com under IN THE NEWS.
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H-GAC Method of Distribution for CDBG Disaster Recovery Program
Adopted February 17, 2009, Amended May 19, 2009
APPENDIX A
Data Sources
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H-GAC Method of Distribution for CDBG Disaster Recovery Program
Adopted February 17, 2009, Amended May 19, 2009
FEMA Housing Task Force Report DR1791 - Hurricane Ike - 01/20/09
Assessments by Damage Category
Destroyed
Under $8,000 to $15,000 to Over (Owner- Destroyed
Jurisdiction $8,000 $15,000 $28,000 $28,000 Occupied) (Rental) Total
Austin County 55 0 1 0 1 0 57
Brazoria County 10,955 364 122 134 89 37 11,701
Chambers County 2,133 183 163 364 216 123 3,182
City of Galveston 8,358 4,068 3,510 1,073 147 212 17,368
City of Houston 81,392 2,168 729 326 69 148 84,832
Fort Bend County 6,025 84 25 12 12 2 6,160
Liberty County 6,662 243 98 165 134 40 7,342
Matagorda County 170 11 1 1 1 1 185
Montgomery County 7,254 238 118 120 91 38 7,859
Rest of Galveston County 12,934 1,545 1,859 2,073 1,241 717 20,369
Rest of Harris County 27,303 1,207 1,367 627 167 133 30,804
Walker County 837 10 1 8 6 2 864
Waller County 175 6 10 2 0 2 195
Wharton County 3 0 0 0 0 0 3
Total 164,256 10,127 8,004 4,905 2,174 1,455 190,921
Texas Rebounds - Critical Infrastructure Data
County $ Infrastructure
Austin County $ -
Brazoria County $ 7,700,000
Chambers County $ 210,000,000
City of Galveston $ 550,000,000
City of Houston $ 104,500,000
Fort Bend County $ -
Liberty County $ 13,000,000
Matagorda County $ 25,500,000
Montgomery County $ -
Rest of Galveston County $ 120,200,000
Rest of Harris County $ 411,600,000
Walker County $ 2,500,000
Waller County $ -
Wharton County $ -
Grand Total $ 1,445,000,000
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H-GAC Method of Distribution for CDBG Disaster Recovery Program
Adopted February 17, 2009, Amended May 19, 2009
APPENDIX B
May 19, 2009 Amendment
County-level Processes and Redistribution of Liberty County Categories
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H-GAC Method of Distribution for CDBG Disaster Recovery Program
Adopted February 17, 2009, Amended May 19, 2009
Scoring Process - H-GAC staff shall use the scoring criteria below to score and rank eligible
project applications.
Appeals Process – Applicants may appeal scoring determinations by contacting Mr. Jeff Taebel,
Director of Community and Environmental Planning. In the event the appeal is not resolved, the
applicant may appeal to the Chief Operating Officer of H-GAC.
Reallocation of unspent funding (non-housing projects) – Any funding that becomes available
within a given county due to withdrawn projects, reduced budgets, determination of ineligibility,
etc. will be awarded to the next highest scoring project based on the original score results.
HURRICANE IKE—CDBG DISASTER RECOVERY UPDATE
(Presented to H-GAC Board May 19, 2009)
Background
At its February meeting H-GAC’s Board approved the region’s proposed Method of Distribution
for Community Development Block Grant (CDBG) disaster recovery funds. Board action
apportioned over $814 million for housing and non-housing activities, with direct allocations and
set-asides to jurisdictions.
The Office of Rural Community Affairs (ORCA) conditionally approved the regional Method of
Distribution on March 5, 2009, with the caveat that the counties contained within the regional
Method of Distribution further develop processes to either prioritize non-housing projects or
directly sub-allocate funding to the cities within each county. ORCA approval of either process
is required before entities can submit non-housing project applications for consideration of
funding. ORCA is requiring that approved scoring criteria and county-level Methods of
Distribution be included in the regional Method of Distribution as an Appendix.
Current Status
County-level processes as of May 18, 2009:
Approved by ORCA – Chambers
Under review by ORCA – Austin, Brazoria, Fort Bend, Galveston, Harris, Liberty,
Matagorda, Montgomery, Walker and Waller counties
The City of Galveston and the City of Houston are not required to develop the scoring
criteria or Method of Distribution process.
County-level reallocation – Liberty County
The Liberty County Method of Distribution reallocates housing and non-housing funds. The
proposed reallocation swaps the original allocation from 60/40 housing/non-housing to 40/60,
and results in a net change of the regional housing/non-housing allocation of less than 1%.
Liberty County based this reallocation on the results of a housing survey conducted by the
Liberty County Long Term Recovery Committee. The survey included a review of a detailed
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H-GAC Method of Distribution for CDBG Disaster Recovery Program
Adopted February 17, 2009, Amended May 19, 2009
FEMA database of 14,000 homes, completing a questionnaire for 5,000 homes, and conducting
detailed surveys for approximately 150 high priority homes. The results of the survey indicated
that the need for housing services may be less than the original set-aside amount.
Because the proposed reallocation affects the regional Method of Distribution, ORCA will not
grant approval of the Liberty County Method of Distribution unless a) Liberty County revises
their Method of Distribution to the original allocation of housing and non-housing funding, or b)
H-GAC modifies the regional Method of Distribution to reflect the proposed reallocation. Given
the number of homes reviewed during the survey and the documented support of the reallocation
by the Liberty County Long Term Recovery Committee, H-GAC staff recommends adjusting the
regional Method of Distribution to reflect the proposed Liberty County revision.
Revised Distribution Table – changed fields are shaded
Percent to Non-Housing
Entity Total Amount ($) Housing Housing ($) ($)
City of Galveston $ 267,387,055 60% $ 160,432,233 $ 106,954,822
Rest of Galveston County $ 165,839,163 60% $ 99,503,498 $ 66,335,665
Rest of Harris County $ 140,693,072 40% $ 56,277,229 $ 84,415,843
City of Houston $ 109,070,706 80% $ 87,256,565 $ 21,814,141
Chambers County $ 69,738,606 30% $ 20,921,582 $ 48,817,024
Liberty County $ 21,898,771 40% $ 8,878,923 $ 13,019,848
Brazoria County $ 17,409,490 50% $ 8,704,745 $ 8,704,745
Montgomery County $ 11,515,395 60% $ 6,909,237 $ 4,606,158
Matagorda County $ 5,984,150 20% $ 1,196,830 $ 4,787,320
Fort Bend County $ 2,636,845 60% $ 1,582,107 $ 1,054,738
Walker County $ 1,555,801 60% $ 933,481 $ 622,320
Waller County $ 325,698 60% $ 195,419 $ 130,279
Austin County $ 77,508 60% $ 46,505 $ 31,003
Wharton County $ 1,232 60% $ 739 $ 493
Total $ 814,133,492 56% $ 452,839,093 $ 361,294,399
County-level reallocation – Wharton County
Wharton County has elected to return the $1,233 in set aside funding to the region. The set aside
amount will be reallocated regionally.
Action Requested
Request approval of amendment to the H-GAC community development block grant disaster
recovery Method of Distribution to reflect the reallocation of Liberty County housing and non-
housing funds, redistribution of the Wharton County set aside, and including locally developed
scoring criteria and county-level Methods of Distributions as an Appendix.
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H-GAC Method of Distribution for CDBG Disaster Recovery Program
Adopted February 17, 2009, Amended May 19, 2009
Summary of County-Level Processes
H-GAC Regional Method of Distribution
County Process Status
Austin County Regional Process- Local Criteria Under review by ORCA
Brazoria County Regional Process- Local Criteria Under review by ORCA
Chambers County County-Method of Distribution Approved by ORCA
Fort Bend County County-Method of Distribution Under review by ORCA
Galveston County County-Method of Distribution Under review by ORCA
Harris County County-Method of Distribution Under review by ORCA
Liberty County County-Method of Distribution Under review by ORCA
Matagorda County Regional Process- Local Criteria Under review by ORCA
Montgomery County County-Method of Distribution Under review by ORCA
Walker County Regional Process- Local Criteria Under review by ORCA
Waller County Regional Process- Local Criteria Under review by ORCA
Wharton County Reallocated to Regional Fund Reallocated to Regional Fund
H-GAC will oversee the regional process with input from the Commissioners Court and locally
developed scoring committees. Local criteria currently under review by ORCA are attached.
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H-GAC Method of Distribution for CDBG Disaster Recovery Program
Adopted February 17, 2009, Amended May 19, 2009
H-GAC Regional Process – Austin County
Non-Housing Project Scoring Criteria
1) Local Priorities:
Sewer/Wastewater 25 points
Water 20 points
Other eligible projects 3 points
2) % of Population Served:
0.00 - 20.0 1 point
20.01 – 40.0 2 points
40.01 – 60.0 3 points
60.01 – 80.0 4 points
80.01 – 100.0 5 points
Tie-breaker is % of LMI for the project. Project serving greater percentage of LMI
beneficiaries will be advanced in ranking.
Maximum grant award -- $77,508/per Project
Maximum grant award -- $77,508/per Entity
*An Entity is defined as a City, County, MUD, Drainage District, or Utility District.
Note: Projects ranked using the criteria will be funded up to amount of available funding set-
aside for Austin County non-housing projects listed in H-GAC Regional Method of
Distribution. Population and LMI percentages shall be derived from U.S. Census and HUD
databases.
H-GAC Regional Process – Brazoria County
Non-Housing Project Scoring Criteria
1) Local Priorities:
Sewer/Wastewater 25 points
Water 20 points
Fire/Police/EMS/First Responder Shelter 15 points
Road/Bridge Improvements 12 points
Shoreline protection 10 points
Drainage 5 points
Medical Services 5 points
Schools 5 points
Other eligible projects 5 points
2) Projects that address structures or facilities 5 points
affected by the storm surge of Hurricane Ike
3) % of Population Served:
0.00 - 20.0 1 point
20.01 – 40.0 2 points
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H-GAC Method of Distribution for CDBG Disaster Recovery Program
Adopted February 17, 2009, Amended May 19, 2009
40.01 – 60.0 3 points
60.01 – 80.0 4 points
80.01 – 100.0 5 points
Tie-breaker is % of LMI for the project. Project serving greater percentage of LMI
beneficiaries will be advanced in ranking.
Maximum grant award -- $200,000/per Project
Minimum award -- 1 project per Entity*
Maximum grant award -- $700,000/per Entity
*An Entity is defined as a City, County, MUD, Drainage District, or Utility District.
Minimum project is based on submittal of a project that is eligible for funding under CDBG
disaster recovery guidelines. Justification of minimum of 1 project per eligible entity is
based on need to provide a level playing field for all applicants and to ensure each impacted
community will be provided the opportunity to recover from Hurricane Ike.
Note: Projects affected by storm surge must provide documentation (i.e., damage reports,
FEMA project worksheets, or other verifiable information). Population and LMI percentages
shall be derived from U.S. Census and HUD databases.
H-GAC Regional Process – Matagorda County
Non-Housing Project Scoring Criteria
1) Local Priorities:
Shoreline protection/Restoration including bulk heading 3 points
Other projects other than those listed on this table 2 points
Water and Sewer Utility Systems 1 points
3) Tie-breaker is based upon total project cost from lowest to highest.
Only Cities and the County can make application directly to the County. The County shall
be the applicant for any unincorporated areas requesting assistance. Districts will access
assistance through the governmental entity eligible to apply in which the District is located.
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H-GAC Regional Process – Walker County
Non-Housing Project Scoring Criteria
1) Local Priorities:
General (i.e., non-generator) Projects*
First Responders 6 points
Water/Sewer 5 points
Roads/Bridges 4 points
Drainage 4 points
Community Centers 4 points
Other eligible projects 2 points
Generator Projects*
First Responder Generator 25 points
Sewer Generator 20 points
Water Generator 15 points
Other eligible project Generators 2 points
4) 50% Beneficiaries served are low-mod income 3 points
Tie-breaker is greater % of LMI for the project, followed by greater number of LMI if
necessary.
Note: Sewer projects are capped at $60,000 per entity. *points for each priority category are
non-cumulative – - no combinations of points allowed.
H-GAC Regional Process – Waller County
Non-Housing Project Scoring Criteria
1) Local Priorities:
Sewer/Wastewater 25 points
Water 20 points
Fire/Police/EMS/First Responder Shelter 15 points
Road/Bridge Improvements 12 points
Drainage 5 points
Other eligible projects 3 points
5) % of Population Served:
0.00 - 20.0 1 point
20.01 – 40.0 2 points
40.01 – 60.0 3 points
60.01 – 80.0 4 points
80.01 – 100.0 5 points
Tie-breaker is % of LMI for the project. Project serving greater percentage of LMI
beneficiaries will be advanced in ranking.
H-GAC Method of Distribution for CDBG Disaster Recovery Program
Adopted February 17, 2009, Amended May 19, 2009
*An Entity is defined as a City, County, MUD, Drainage District, or Utility District.
Note: Projects ranked using this criteria will be funded up to amount of available funding
set-aside for Waller County non-housing projects listed in H-GAC Regional Method of
Distribution. Population and LMI percentages shall be derived from U.S. Census and HUD
databases.
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