In a pointed letter submitted to WSDOT in mid-December last year the Federal Transit Administration (FTA) criticizes the deep bore tunnel (DBT), saying it would do little to improve transit and would in fact likely have “adverse” impacts on transit “even with mitigation”. The letter, sent by FTA Region X Administrator Richard Krochalis,  a comment to the November 2010 Supplemental Draft EIS (SDEIS), states “… FTA remains disappointed [with] the Project’s impact on public transportation.”

It is normal for governmental agencies to submit comments to each other as part of the EIS process, with comments generally dry in nature and narrowly focused on refining the clarity of the document. This was only partly the case with this letter, posing many almost rhetorical questions, pointing out major gaps in the analysis, and calling the assessment of cumulative impacts “extremely optimistic”. The letter also take WSDOT to task for conveniently confusing language about transit investments which are identified in the EIS, but have no secured funding. This has been a disturbingly common meme of the pro-tunnel campaign.

While these comments are in response to the SDEIS and the details of the transit element of the plan have likely undergone some revision, the lack of secured capital and operation funds for transit investments and the large increase in surface street congestion are inherent and intractable problems with the tunnel as is.

Below are excerpts from the letter, emphasis mine:

F-004-005 We appreciate the work that went into the transit analysis. It appears to be advanced quite a bit from the previous SDEIS (e.g., assessing impacts to transit travel time). However in the broadest sense FTA remains disappointed that the Project’s impacts on public transportation are, from our perspective adverse, even with mitigation. In the short term, “Daily ridership growth between 2005 and 2015 with the 2015 Project would generally be similar to or slightly lower than ridership growth in the 2015 Existing Viaduct, depending on the screenline” (Appendix C p.222). Looking slightly farther out, transit share would grow between 2015 and 2030 due to “expanded bus and rail service, particularly Link LRT service in place by 2030, [and] higher automobile operating costs and higher parking costs.” (Appendix C, p. 224.) That is, transit share actually decreases by 2030 (SDEIS p. 215). The SDEIS ambiguously state that this decrease is both negligible and unacceptable (id.) FTA concurs that any project element that decreases transit ridership is not acceptable.

More after the jump.

F-004-009 The SDEIS states that “Since transit routes are designed to serve trips to downtown, while the tunnel is designed to serve trips through downtown, the impact of tolls on transit is negligible” (p. 215). This is simplistic and inaccurate. First, much transit does indeed serve trips through downtown both by design and necessity, sometimes directly and sometimes through connections. Second, the extent tolling affects the ability of transit to operate effectively – that is, if tolling affects access, reliability or travel time – it obviously affects ridership.


The SDEIS finds the impact of tolling on transit ridership to be “negligible” (p.215). However, FTA believes the assessment of the effectiveness of priority treatments to be optimistic. More realistic is the depiction of dramatically increased travel time on Second and Fourth Avenues (Exh. 9-15)… The Project should be ensuring that even the most conservative assumptions show increasing transit use and only minimally disrupted performance, even if getting to that point requires more mitigation funding than the Project has anticipated.

F-004-013 Cumulative impacts. FTA finds the discussion of cumulative impacts due to the Central Waterfront Project, Elliot Bay Seawall Project and Alaskan Way Surface Street Improvements (p. 170) extremely optimistic. It finds the discussion of cumulative impacts due to additional, “non-Program” projects (p. 170-175) perhaps even more optimistic.

F-004-017 Cost of mitigation measure. Will the project proponents pay for whatever mitigation measure adopted? Or are the measures in the SDEIS available for consideration bus continent upon funding? The document is confusing on this point… on p. 3 most readers would incorrectly infer that the 2009 agreement to proceed with a tunnel includes funding for a First Avenue Streetcar. FTA’s understanding is that the transit enhancements agreed to by Governor Gregoire, County Executive Sims, and Mayor Nickels assumed a revenue from an excise tax that has not be secured.

70 Replies to “FTA: “Disappointed” with DBT, Has “Adverse” Impacts on Transit”

  1. I’m sure these are typos. Everyone knows that only crazy McGinn is against the tunnel. Every other government official supports it.

  2. Well dah.

    These are exactly the transit impacts that the K County transit excise tax was supposed to alleviate. The unfortunate thing is that there is exactly zero commitment at the State level to allowing increased transit as part of the DBT project (or any other alternative to the DBT for that matter).

    They just threw Sims a bone in the form of the option for a voter approved tax, but there wasn’t any commitment to it so that option died about the time that Sims left. And of course a K County tax to support what amounts to mitigation for a local Seattle project has zero chance of passing at the polls anyhow ( Do you really think KC R’s will vote to increase their taxes and send that money to Seattle? Yes, that is a simplistic view, but that is how they will view it).

    My view is that the best course of action is to work towards getting Transit added back into the DBT project, but I don’t think there is any chance of that while McGinn continues on his current path.

    1. Well one way towards that is voting to reject the tunnel. How I see it, if elected that support the tunnel want to keep it alive (assuming they are able to) after a strong reject vote they’ll have to make changes, and the two messages that resonate most is tolls and transit. I find it unlikely that they would completely ignore the vote and move headlong forward.

    2. Correction: The best course of action is to work towards getting transit added back instead of the DBT project. The DBT project has no impact on anything except making the portal areas unusable by anything but cars – it’s just a giant waste of money. Remove the viaduct and add transit. Done.

      1. Governor Gregoire did not veto the one percent MVET; she vetoed a $20 vehicle license fee in 2010, arguing that a county transportation benefit district already had authority to try for that; the one percent MVET would be a much more robust revenue source (e.g., more revenue and more progressive); the one percent MVET would do three things: fund the AWV related capital, the AWV related service, and most importantly, fill the gap from declining sales tax revenue. it is quite difficult for legislators to take tax votes and let other governments spend the funds.

  3. And yet the tunnel gets federal funding. Contradictions in government hierarchy are clearly a problem…

    1. The tunnel doesn’t get federal funding that I’m aware of. Just the seawall replacement. Let me know if I’m wrong, though.

      1. The list you’re pointing to is not just the tunnel – it’s the whole corridor replacement, which is several projects. Federal funding is definitely present for the southern project, but that’s not the tunnel.

      2. Isn’t there some FEMA money in there somewhere? I thought the Feds pledged some $$ way back for viaduct replacement.

      3. Martin,

        I just read an interesting article speculating that Grover Norquist may take aim at the Federal motor vehicle fuel tax. It’s up for renewal this September and there are about 75 Tea Partiers who are pledged never to vote for a “tax increase”. By TP definition extending a tax that is scheduled for sunset is a “tax increase”.

        So I wouldn’t be counting on that $468 million.

    2. @Anandakos except that a very interesting analysis of the recent debt deal has just been published and it seems to suggest that an ingenious poison pill was concocted in the bill that requires the Congress to trim spending if additional taxes are REDUCED. And the things most sacred to progressives are off the table (Social Security, Medicaid, PELL Grants etc) but the things most sacred to hawks e.g. military spending is subject to 1/2 of any spending reductions. There are major disincentives built in to deter reducing revenues. I suspect that this tax gets renewed simply to save the sacred cows.

  4. “much transit does indeed serve trips through downtown both by design and necessity, sometimes directly and sometimes through connections.”

    Interesting that the feds use Jarrett Walker’s terminology of “connections” rather than “transfers”.

    1. The trouble with that logic is that currently one bus serves both through routed riders as well as collector/distributor of CBD riders, who make up the majority.
      Having a through routed bus, with no stops, makes a fast trip for some, and requires another bus to keep doing the heavy hauling on the route for everyone else.
      It’s a dumb argument to make, unless you can find 30 or 40 riders per bus to make it really productive on its own merits.

      1. I don’t think they’re talking about through-routed routes. They’re just saying that all buses that go through downtown should stop downtown, both due to downtown destinations and to make connections. (Exceptions like the UW expresses are too few to count.)

      2. ” SDEIS states that “Since transit routes are designed to serve trips to downtown, while the tunnel is designed to serve trips through downtown, the impact of tolls on transit is negligible” (p. 215). This is simplistic and inaccurate. First, much transit does indeed serve trips through downtown both by design and necessity, sometimes directly and sometimes through connections.”
        I see your point. If WSDOT and the pro campaign are trying to make the argument that this is good for transit, then I think it’s dumb, and dishonest to say that, without a plan and funding to fill up a bunch of through-routed buses that could serve Ballard/N.Queen Anne to SODO/W.Seattle riders.
        I just don’t think the numbers are there for such custom bus services in our times of austerity.

      3. OK, but a tunnel route from northwest Seattle to SODO is not “through-routed”, it’s an express. Through-routing is where two different routes are joined, supposedly for service-hour efficiency. This by definition implies a stop where the routes meet or overlap.

  5. Can someone explain to me how more transit (which I assume means buses) will be possible in DT Seattle without the Viaduct? At rush hour, the 3rd Avenue bus zones are heavily congested, forcing buses to wait for the zones ahead to clear. This has a cascading effect on reliability. More buses will only make 3rd Avenue worse, but I can’t think of another corridor that could accomodate a significant increase in transit.

    Unless we can find a way to get high-income Seattle workers/residents to park their cars, we’re going to have a tough time accomodating the Viaduct traffic on the existing road infrastructure. Transit in Seattle isn’t time-competitive with driving, so high-income people (who place a higher value on their time) inevitably choose to drive.

    1. Maybe if we spent less money on maintaining vehicle capacity, transit would be more time-competitive with driving.

      1. How silly.

        Seattle can easily accommodate hundreds of thousands more cars if we just make the space and capacity upgrades necessary. As we all know: more cars equals more progress.

    2. “explain to me how more transit… will be possible in DT Seattle without the Viaduct” We just pulled buses off 1st – add them back. 2nd and 4th have significant bus capacicity available. If they’re still backed up (we’re talking about a lot of new buses for that to happen), then add more bus lanes. Maybe even close 1st to cars like we’ve done for 3rd, and make the cars use 2nd & 4th.

      We have plenty of capacity for buses if we take a bit from cars. How many lanes of car traffic does a single bus lane replace again?

      1. Closing 1st Avenue to cars would be interesting, but I’m not sure it would be politically feasible or solve the capacity issue. How much of the new transit service could use 1st effectively? Also, Being on the edge of downtown makes 1st somewhat less useful than 3rd for downtown workers.

        A bus-only 1st would also force more ex-Viaduct traffic onto 4th Avenue, which is already very congested at rush hour until Stewart and has bus capacity issues of its own (the right lane ending at Pike, horrible traffic on Olive Way causing bus backups onto 4th).

        Thinking about the street capacity issue, I’ve noticed that a lot of the rush hour traffic problems downtown are caused by jaywalking or vehicles “blocking the box.” Seemingly minor incidents significantly reduce the throughput of the street grid. Unfortunately, these are rather intractable problems (selfish personal choices) that I don’t think we can engineer our way out of.

      2. Most traffic problems downtown are caused by I-5.

        I only suggested a bus-only 1st if we have enough buses to need that capacity. At that point we’ve replaced a massive number of cars, and traffic would actually get better. That said, I don’t dare dream that we’ll get there any time soon. Plus at that point it’s probably a better idea to move to high-capacity transit so that we take up less of our limited roadway and need fewer drivers.

      3. Alex, why don’t you just go look at the WSDOT ST5 plan? It answers all these questions.

      4. Thinking about the street capacity issue, I’ve noticed that a lot of the rush hour traffic problems downtown are caused by jaywalking or vehicles “blocking the box.”

        This is how you fix it.

        “Don’t block the box” works. We should implement it tomorrow.

      5. The improvements in ST5 are worth implementing no matter what the ultimate viaduct replacement ends up being. Combine the proposed transit lanes with transit signal priority and it would massively improve the speed and reliablity of any route serving downtown Seattle.

    3. High-income populations are far more likely to leave their cars for trains than for buses. It’s been shown that “choice” riders vastly prefer rail over bus transit. The Link expansions currently in the work will help people leave their BMWs and Audis at home, and so will the streetcar expansions (if they ever get funded).

      To provide more bus capacity downtown, we simply dedicate more lanes to it. Transit-only 3rd is, as you say, getting congested, so we add more transit lanes on other streets. We can move more routes to 2nd & 4th, where the rush-hour bus lanes have some extra capacity, and we can eliminate some parking and expand bus lanes to all-day.

      Even if we end up needing 2 bus lanes on each street, it’s doable. Yes, it will mean less capacity for SOVs. But that simply has to happen when traffic reaches critical mass. You have to start allocating space to move more citizens, rather than simply more vehicles.

      1. There are also a number of short-term and long-term changes that will or could improve bus flow downtown.

        One is moving the northbound 522 to 4th Ave (approx cost: $0) and axing the 14N (a matter of time). These right turns from 3rd to Pike take ages and cause back-ups on 3rd Ave northbound, as the many drivers who need to stop on 3rd at Pike are reluctant to change lanes.

        A lot of the southbound PM peak congestion is caused by the notorious right turn from 3rd to Columbia as the 120 and many other routes have to fight their way onto the viaduct. I have a post coming up about that.

        If we’re looking at a 2030 horizon, it’s entirely possible by then that Metro and ST will have become hip to the double-decker bus thing. CT’s Enviro 500s carry more people than an artic and are much more maneuverable. Having seen them in action in Victoria, I’m totally sold.

        Finally, I can’t prove this, but I suspect that moving the 3 and 4 to Yestler would improve 3rd Ave flow southbound a little. Currently those buses have to block a travel lane to make that left on James. At Yestler there is a left-turn-only lane.

      2. More maneuverable and importantly take up less curb space. More than anything we have a shortage of curb space on 3rd.

      3. It’s been shown that “choice” riders vastly prefer rail over bus transit.

        Honest question: have any of these studies controlled for the effects of grade separation, improved frequency, clearer branding/maps, and/or faster travel time?

      4. I’ve heard CT has been having maintenance issues with the E500s; they’ve had much more frequent road calls than the rest of CT’s fleet. This impacts the maint. budget somewhat, but more importantly it impacts service reliability.

        On the other hand, Metro’s New Flyer hybrid artics have the least frequent road calls of anything in the fleet (around 1 per 7000 miles!) I’m hoping that the E500s will shape up as the design matures, but they’ve got a long way to come.

        So I don’t know if it’s worth it to switch to double-deckers for the extra curb space, when it means commuters will be stranded twice as often as with the artics.

      5. Aleks:

        I don’t have them in front of me today; it’s been probably a year since I last really dug into this issue. I’ll try and sum it up as best I can from memory. The studies were comparing rail to full BRT equivalents with comparable travel time and headways.

        In the end, it’s not a service-quality or reliablity issue. It has to do with comfort, ride quality and the psychological perception of trains as being “nicer”.

        A BRT system, built properly, may provide near-rail-quality transport. But in order to get long-term ridership, citizens have to be willing to step on it for their first ride, and simply try it out.

        That is the hardest barrier to cross for BRT; it takes a LOT of marketing / public outreach to even begin to overcome the social stigma associated with buses. Rail systems have no such stigma, and as such get more “test riders”, many of whom become regular riders.

      6. Splitting the N and S halves of the 2, 3, and 4 would seem to make a lot of sense along with moving the 3 & 4 to Yestler. The South/East halves could be live looped downtown so they don’t have to make turns on/off 3rd and it would allow service patterns to more closely match demand patterns.

      7. One advantage rail has over BRT is peak capacity. Sure some of the South American BRT systems move an impressive amount of people through some sections of their networks but those are generally in areas where several lines converge. In addition the busiest lines generally are running 80′ coaches with interiors set up more like a streetcar (lots of standing room) than like typical coaches.

        Look at the N/N study for the Freemont/Ballard HCT corridor where the only mode that came close to meeting peak demand was the streetcar.

        Another example will come once U-Link and especially North Link opens. During peak times Link trains will need to be 4 cars every 3 minutes to meet demand.

      8. Splitting the 2 makes sense if you move the 2S to live-loop on Madison and interline with the 12, which I think is a great idea. The downside is that it’d cost more for the same frequency, because you’d have to run the 2N down to the turnback wire on Jackson used by the 70 before it was dieselized.

        Splitting the 3/4 is awkward because there’s nowhere good in the street grid for the 3S/4S to live-loop unless you turn onto or off of 3rd, which somewhat defeats the point, and, as I noted earlier, I don’t think the left on Yestler is problematic like some of the others. You’re also right on the very south edge of downtown, with a crappy walkshed.

      9. Whenever I ride RapidRide A I’m struck by how small the bus is. Maybe it’s just fewer seats rather than a smaller bus, but it makes me wonder how the bus could ever handle a lot of people travelling at once. So that may be one aspect of how “rail can absorb bigger load peaks” than buses can.

      10. One advantage rail has over BRT is peak capacity.

        No argument there. But saying “rail is better because of capacity” is a lot different than “rich people won’t ride buses”. If there’s a class distinction between bus and train riders, I doubt it’s because of capacity (otherwise, the Microsoft Connector wouldn’t have any riders :P).

  6. Thanks Ben – very interesting analysis. Please don’t take my questions the wrong way – I’m not trying to be argumentatitve, just trying to better understand how we go from “more transit” as a concept to actually implementing transit improvements within the physical constraints of downtown. All of the transit-haters I know are always lobbing these kinds of questions at me and I don’t have good answers for them.

    1. Well for an honest answer – not having a highway into downtown actually would reduce overall car volumes a little. Enough that buses will flow slightly better.

  7. So, could the city ask the state for streetcar funding to mitigate the impacts on traffic?

    The win-win situation I see here is if we get the DBT (satisfying WSDOT’s requirement of faster Green Lake – Duwamish River travel times), and then get portions of ST5 and/or one of the high ridership HCT corridors funded by the state as part of the mitigation process for the DBT.

    Of course, this doesn’t solve the problem that the state has no funding sources.

    1. The problem with this as a win-win is that the wins are really small and the costs are really large. There are losses: every other program that needs money.

      1. That’s true. But WSDOT is going to build SOMETHING to bypass downtown no matter what the cost. I think they can still meet their SR-99 through-traffic travel time reduction goal with a 2 lane tunnel, which would cheapen things dramatically, but I don’t think they’re going to consider it. In their minds, they’ve already made a huge sacrifice by going from the current 3 lanes to 2 (even though the majority of the current traffic shifts off the highway to the western/alaskan couplet in every plan).

        They might still end up going back to the elevated option, when faced with the mitigation costs for the tunnel. Even that wouldn’t be so bad. Because it’s aligned above Alaskan, rather than side-by-side with it like the current viaduct, it would still dramatically reduce the highway’s footprint through downtown vs. today.

        They’re not going to go with ST5, even if there’s no money for anything else. To do so at this stage would mean losing face for them.

      2. “They’re not going to go with ST5, even if there’s no money for anything else. To do so at this stage would mean losing face for them.”

        Which, of course, illustrates the thing that keeps me up at night if PSN does manage to stop the tunnel. A two-lane elevated highway through the waterfront is only slightly less of a disaster than the current viaduct. It’ll still be a blight and an eyesore on the waterfront for another generation.

      3. So elect a governor and legislature who are willing to throw out the entrenched, “face-saving”, do-what-we’ve-always-done tunnel backers at WSDOT.

        Problem is I’m not even sure it’s WSDOT. The DBT came out of a backroom deal and we have no idea who actually pushed it.

    2. Exactly. There is a lot to be gained from collaboration. And with a big project like the DBT, the potential benefits to transit could be big too. Unfortunately that means that people actually have to work together constructively, and that doesn’t seem to be something we are good at around here.

      My favorite idea to get things started is to implement early tolling on the viaduct similar to what is being done on SR520. During the early tolling phase I’d split the revenue 50-50 between the city and the DBT project. WSDOT could use its revenue to cover basic project costs, and the city could use its revenue to develop surface improvements to handle toll diversion. After the early tolling phase future toll revenue would go 100% to WSDOT, but SDOT would already have the surface improvements in place and paid for.

      Of course McGinn et el would never go for early tolling as it 1) advances the DBT, and 2) allows Seattle to deal with the diversion issue (before they can use it to kill the DBT).

      1. Hmm, with early tolling, could they install the tolling infrastructure south of the south portal and north of the north portal to avoid having to move it in the future? Would that reduce the amount of traffic diversion?

      2. What are the “big” potential benefits to transit of the DBT? I haven’t heard one yet.

        Meanwhile, lots of cities all over the world have great transit and don’t have expensive, complex tolled freeways running through their downtown cores. Big benefits to transit come from transit projects, not freeway projects.

  8. I know this is only part of the problem, but i feel that pedestrians downtown cause a lot of congestion. Mostly by backing up turning vehicles. Having spent much time in Japan recently I’ve noticed that numerous pedestrian overpasses over intersections seem to greatly help traffic flow. Has this been thought of for Seattle? It just seems to me that several intersections along 4th, Pine and Pike corridors have the most foot traffic, and could benefit from such an approach.

    1. Few people know the advantages of using the tunnel stations on 3rd as pedestrian shortcuts. My feeling is that Seattleites will eventually catch on as they get used to living in a real city…

    2. One way to mitigate that problem (which is common in Tokyo too!) is “all way walk” intersections — replace walk signals that are with parallel traffic with an entire cycle of pedestrian crossing in all directions (pedestrians obviously have a “no walk” sign during other parts of the cycle when vehicles are going). We actually have one by SAM. The trick is that the cycle has to be frequent or pedestrians will cross against signal.

      1. And one at Pike Place Market. I’ve been told they are common in some eastern seaboard cities as well.

    3. There are a lot of pedestrian overpasses over Aurora. Obviously this is not downtown, but they can illustrate some realities of overpasses. First, they have to be pretty high for traffic to fit underneath. If you’re installing enough to make a difference downtown, you’re installing a lot, and in the worst case forcing people to climb up and down lots of stairs just to cross a couple streets. That’s pretty pedestrian-hostile. Second, they require a significant footprint. That matters when pavement space is scarce, as in a dense area like downtown.

      There are also ways overpasses downtown would be different from ones on Aurora. They would need to be wider, to handle large pedestrian crowds at peak times and events. And they would need to be accessible to people that can’t climb stairs — not all the ones over Aurora are, but that would be unacceptable for new construction downtown.

      Ultimately, a proposal to get pedestrians out of the way for the sake traffic flow is basically a proposal to turn some downtown corridor into Aurora: a fast-moving, pedestrian-hostile car corridor. Maybe San Francisco’s Route 1 is another apt comparison. Again, like Aurora, it is not downtown, and does not belong there.

      1. +1 When we give up the streets to the car, we’ve lost.

        That said, an elevated bike freeway would be nice.

    4. Moscow and St Petersburg have underpasses that work well, but many in England don’t. A successful underpass needs: ramps rather than stairs, and barriers at the sidewalk corners to prevent people from crossing on the surface. Even better if the bottom of the underpass has a metro entrance or underground mall, or at least a newsstand, so that lots of pedestrians are always milling around there.

      The underpasses in Bristol have none of these: they just go down under the street and up another side. The crosswalks are still there, so most people use the crosswalks because it’s a shorter distance. The people who do hang out in the underpasses are drug dealers and dodgy types. That makes other people feel unsafe so they avoid the underpasses. The net result is that these underpasses do little to separate pedestrians and cars.

      Overpasses are more difficult because they have to be higher than an underpass is low, which implies stairs or a steeper approach, and the negative part (going up) occurs before the positive part (going down). That doesn’t jive with people’s instinct to take rewards sooner and postpone difficulties.

  9. How about for mitigation a transit only tunnel is built as cut and cover when replacing the seawall. It would be a much smaller endeavor than the GP tunnel proposed with this synergism.

    1. I thought the whole point of the deep bore tunnel was that a cut and cover would be too intrusive.

      1. I don’t remember if the original proposal was 4 lanes or 6 lanes but a two lane bus tunnel would certainly be on a much smaller scale. I don’t know anything about building modern seawalls but I think you’d have to trench back at least one lane for construction access. If they work nights they could keep AK Way open most of the time by building in sections and use of those large metal plate covers. Since it would be shallow tunnel you might be able to get by with a good ventilation system and not require overhead or special “hush mode” hybrids. The big draw back is that it’s literally at the edge of DT and doesn’t have good transfers to any existing service. It’s not the first choice for where to locate a bus tunnel/subway. I’m just wondering what the marginal cost would be since they’re building the seawall anyway.

  10. The Cut and Cover tunnel was a way to get the state to pay for the seawall replacement by making the sea side of the tunnel also the seawall. Fortunately that abomination died when Greg Nickles lost the mayorship.

    1. Well, it was a lot less of an abomination than the DBT. For one thing, *it was a way to get the state to pay for the seawall replacement*; for another, it had the possibility of intermediate exits. Enjoy your local taxes going to seawall replacement. :-P

  11. Woah. Hold it. Let’s wait until Robbie McKenna is governor. Let him decide.


  12. From the New York Times, “In Seattle, an old elevated highway that runs along the waterfront and is at risk of collapse during an earthquake will be torn down and replaced with a series of parks, open areas and new transit.”

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