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HomeMy WebLinkAbout112017_cabs01CABS Commissioners Office JEFFERSON COUNTY BOARD OF COUNTY COMMISSIONERS AGENDA REQUEST TO: Board of County Commissioners Philip Morley, County Administrator FROM: Jill Silver, 10,000 Year Institute DATE: November 20, 2017 SUBJECT: West Jefferson County invasive species and jobs projects STATEMENT OF ISSUE: An update on the Pulling Together in Restoration and Hoh River Riparian Restoration projects — results, challenges, and jobs created in 2017 in west Jefferson County; and future proposals with a request for letters of support. ANALYSIS: Please see attachments. RECOMMENDATION: Prevention of roadside invasive species is the single -most effective means to reduce spread of noxious, habitat -destructive, agriculture -impacting, and forest -degrading invasive plants. REVIEWED BY: Philip Morle , County Admin' ator D to WASHINGTON COAST RESTORATION INITIATIVE 2015 - 2017 BIENNIUM Pulling Together in Restoration Project Summary Project Description The Pulling Together in Restoration Project (PTIR) is a pilot invasive species program working across jurisdictions in thirteen coastal watersheds to prevent the spread of invasive species into sensitive habitats. Through cost-effective containment, community-based education and engagement, the program focuses local crews to work on a short list of invasive species that cause great harm to forest health, agriculture, and habitat for fish and wildlife; and which are not effectively managed by other programs or projects. Which species and why? Knotweeds, Scotch broom, reed canarygrass, herb Robert, everlasting peavine and other several other noxious weeds replace important functions of plants including food, structure, shade, nutrient cycling, and carbon storage. These particularly aggressive non-native species form 'monocultures' which arrest the growth of other species; affecting forests, rivers, wetlands, and pastures. Knotweed is the focus of many projects as funding is available through WSDA. Without funding to prevent their spread, the other afore -mentioned species are advancing on the coast. There's no funding in part because they're widely distributed across some parts of the state where it is believed that control is not achievable, but in fact, prevention IS achievable, and where . Scotch broom (SB) is a good example. SB is present over perhaps 10% of coastal watersheds at present. A SB monoculture grows to ten feet tall, producing 12,000 seeds per plant per year, which may remain viable for 90 years. SB is shown to arrests native forest succession through a variety of influences, replacing early successional native willow, alder, and in time, the conifer forests providing forage, shade, nutrients, and other services including large woody debris, bank stability and sediment filtration to keep streams and rivers and forests naturally healthy. SB alters the composition of several important soil nutrients, and reportedly disrupts the mycorrhizal fungi critical to healthy forest growth'. It is mildly toxic to grazers, which avoid it. It is also more flammable than native shrubs and trees. Although SB causes significant ecological impacts, control in forestlands is often assumed unnecessary — i.e. it will be 'shaded out' by conifer forest growth. Unfortunately, not only does SB impede the growth of conifer and other forest species by nutrient and mycorrhizal fungi impacts; with 30 to 50 -year harvest rotations over a 90 -year seed bank and seed -infested gravel spread on forest roads, SB outcompetes native forest species again. The fact is: With local jobs and training, SB can be reduced and even eliminated, saving the public millions of dollars of long-term impact and control costs (State of Oregon reports 34:1 cost/benefit analysiS2, and State of Washington reports a $142.8 million per year impact'). Early and persistent action is key to protecting our landscapes and resources from invasive species. 1 Grove S, Haubensak KA, Parker IM (2012) Direct and indirect effects of allelopathy in the soil legacy of an exotic plant invasion. Plant Ecol 213:1869-1882 2 http://www.ore-gon.-goy/oda/shared/documents/publications/weeds/ornoxiousweedeconomicimpact.pdf 3 httD://invasivesoecies.wa.aov/council Droiects/economic impact/Invasive%20SDecies%20Economic%20lmoacts%20Fact%20sheet%20Jan%202017.Ddf Summary: Pulling Together in Restoration — WCRI FY18 and FY19 Page 1 How will this project make a difference? This project represents a critical investment in local environmental and economic health, by training local crews in Early Detection and Rapid Response (EDRR) methods, and conducting on -the -ground control, stitching up gaps in prevention and protection across jurisdictional boundaries. Contributing to existing projects and programs conducted by agency, tribal, and local partners, these teams work along connecting pathways including roads and rivers along which millions of weed seeds and fragments move via tires, mowers, wind, and water into tributaries, pastures, and forest stands. To improve the success of salmon recovery and restoration projects, we will continue to provide a field review of each of 300+ projects, and develop recommendations for invasive species management for each. Where time and capacity are available, we will provide control services. We are working with the Department of Natural Resources for an offender crew to be dedicated to roadside and gravel mine Scotch broom control. The crew and a trained and licensed supervisor would be available to agency, tribal and non-profit landowners and partnerships at a reasonable cost. The program also provides detailed watershed -specific education and outreach, coordination and information encapsulated in a platform focused on increasing prevention and control of resource - damaging invasive species. With local jobs focused on effective prevention of the rising tide of invasive species; protecting investments in coastal restoration and economic vitality in forestry, fisheries, local agriculture, recreation, and tourism is an achievable outcome. More details and current project work to date The PTIR project evolved in response to expanding populations and impacts of invasive plants in forested and aquatic habitats, combined with insufficient funding and coordination necessary to effectively prevent and contain them. With changing climate, receding glaciers and unstable river channels, increasing traffic, rapid timber harvest, and billions invested in restoration for threatened fish populations, it's time to invest in preventing the spread of noxious invasive Eurasian plants so that habitats can be resilient to these impacts where protected and restored. This program addresses the movement of invasive plants between multiple ownerships with differing capacity, interest, and legal authority or responsibility to reduce or control invasive species in each watershed on the coast. Layered on that ownership, rivers and roads connect between watersheds, and invasive species move down these pathways. Each entity does some weed control, but all lack sufficient resources and strategies to address species moving across their ownership boundaries via wind, water, construction, or traffic. When small Scotch broom, knotweed, everlasting peavine, and reed canarygrass sites are removed from roadsides, source populations are prevented from traveling down ditches and through culverts to streams, where water transports each seed to bare gravel and banks, the ideal environments for invasion. Invasive species also degrade other categories of restoration. Whether constructing instream jams or restoring fish passage through a barrier, planning to treat existing invasives or to prevent the introduction of new ones is necessary to avoid inadvertent spread via construction, materials, and equipment. If the gravel for a forest road comes from a mine covered with Scotch broom or knotweed, seeds and fragments of these species become established in stands that were likely free of them, quickly growing and eliminating important habitats and ecosystem services ranging from carbon storage to air and water temperature attenuation. Prevention is easy, but the cost of eliminating these species grows with the size of the infestation, producing more seeds, and spreading environmental impacts through the various pathways. Finally, most weed control focuses only on Class A or B weeds — not the Class C weeds such as Scotch broom4. SB is an issue of climate resiliency, riparian succession, and forest growth, and is allowed to Summary: Pulling Together in Restoration — WCRI FY18 and FY19 Page 2 grow until it has inundated roadsides, harvest units, gravel mines, or pastures, and soil or gravel is contaminated with seeds lasting 90 years, continuing the spread. It is a climate issue because it is extremely flammable, and it replaces the forest stands sequestering carbon, providing humidity, shade, and capturing fog drip. Counties on the east side of the Olympic Peninsula blanketed in SB have a substantially different fire response and management plan than the current response on the coast. Most of the Olympic Peninsula is NOT invaded YET, and all invasive species are preventable if we act upon them persistently — meaning EARLY and OFTEN. So, let's pull together! Goals and Objectives The primary goals of the program are 1) Increased effectiveness of invasive species prevention and management across these coastal watersheds, addressing root causes and sources of invasions; 2) Employing, training and deploying a local workforce for local benefit; 3) Improving containment of invasives that affect forests and habitat creation; and 4) Public and agency education, engagement and empowerment. Objectives are to 1) Decrease the costs of invasive species impacts and control, 2) Improve the success of restoration investments, 3) Develop a coastal coordinated weed management plan that is incorporated into Lead Entity Salmon Restoration Strategies and other relevant plans, 4) Decrease herbicide use across the coastal landscape, and 5) A final objective is to demonstrate the success of local jobs in invasive species prevention and control, to encourage the investment of dedicated funding to similar programs in every watershed. How will the project have a direct positive benefit for the local ecosystem? Native plants and their diverse communities are the foundations of coastal ecosystem food webs and terrestrial, riparian, and aquatic habitats. The project will provide a direct positive benefit to the local ecosystem through increased protection from degrading impacts of invasive Eurasian plants. All life history stages of fish and aquatic organisms benefit by the continuous inputs of native plant materials they've evolved to use for creating pools, providing insect prey, and filtering sediment, providing bank stability through root structures, and maintaining nutrients in the soil and water that they're adapted to. A specific example has been reported by Amy Borde, Battelle Laboratory, from research on reed canarygrass (RCG) and native Lynbye's sedge: RCG significantly reduced the production of chironomids (black fly larvae) eaten by juvenile fish', affecting their food web. Another example is the recent ESA listing of Oregon spotted frogs, which do not successfully breed in RCG. All native animals, birds, amphibians, and insects benefit from healthy native plant communities. A specific animal example is Roosevelt elk, a keystone species in floodplain forests, which will benefit from fewer toxic plants (tansy ragwort, Scotch broom, and foxglove) and more native high quality forage. All native forest soil biota directly benefit from the prevention and removal of Eurasian allelopathic, acidic, or nutrient -impoverishing species including knotweeds, Scotch broom, and herb Robert. Aspects of life in the local community that will benefit from the project The local community will benefit through healthier forests growing faster (less competition from Scotch broom, herb Robert, and blackberry) and cleaner (i.e. less herbicide application — benefiting all species and people), fish and wildlife for recreational, commercial, and subsistence harvest, hiking and nature experiences in native plant communities, supporting native biodiversity and the Olympic Biosphere Reserve. Fewer resources will have to be allocated and spent on fire suppression (from SB and due to healthier forests), as well as weed control in restoration and road management. Summary: Pulling Together in Restoration — WCRI FY18 and FY19 Page 3 Project partners • Olympic National Park (ONP) — Upper Queets Invasive Plant Control Project, others TBD • Olympic National Forest (ONF) — ONF Invasive Plant Control Projects — Queets, Sol Duc • Tribes: Quileute, Hoh, Queets, and Quinault — Knotweed and other weed projects, boat cleaning stations • WA Department of Transportation — IVM Control Program, Adopt -a -Highway Program • WA Department of Natural Resources — Access to all state lands sites, forest road and gravel mine invasives prevention and control, sites for signage, participation in weed -free seed mix use • WA State Parks - Partner on control at Bogachiel State Park, possible site for signage • Counties: Clallam, Jefferson, Grays Harbor Weed Boards — Contribution to protocol development, partner on roadside control, participation in weed -free seed mix use • County Parks and Rec Sites: - Allow access for treatment and educational outreach • County Road Departments — partner in control and prevention activities on county roads • City of Forks — Roadside weed control collaboration, opportunities for community outreach, possible pilot weed disposal site or processing facility • Nonprofits: North Olympic Land Trust, Jefferson Land Trust — educational outreach, practice methods • Pacific Coast Salmon Coalition — Partner and crew for Hoh, Queets, Clearwater projects • The Nature Conservancy — Partner in Hoh, Queets, and Clearwater invasives control • Recreational groups: Guides Association — Partner in education/outreach to river guides • Olympic Correction Camp — Partner in developing and deploying a dedicated Scotch broom control crew • Private residential landowners — Partners in preventing and controlling ornamental and other invasives. Update on current project activities and achievements 25 crew trained and employed 800 miles of roads surveyed, and focal species pulled, cut, treated Two tons of seeds collected and disposed of Contract crews from Hoh, Queets, Chehalis and Elma Partnerships expanded with ONP and ONF Bio -control releases with WSU Outreach and education to resource professionals and community members Quinault Nation Hoh Indian Tribe City of Forks Local Schools, Forks and Sequim Olympic Natural Resources Center COAST North Pacific Coast Lead Entity North Pacific Coast Marine Resources Committee Washington State Salmon Recovery Conference Scotch broom Forks Community Garden Hoh, Queets, Quillayute and Clearwater Rivers Residential outreach Reed Canarygrass 14 miles Snahapish River, Year 1 13 of 26 miles Clearwater, Year 6 Summary: Pulling Together in Restoration — WCRI FY18 and FY19 Page 4 8 miles Goodman Creek, Year 1 7 miles Queets River and Estuary, Year 5 1 mile Thunder Road/Meadow Leyendecker Boat Launch, Year 1 Eagle Springs Off -Channel Spawning and Rearing Pond, Year 2 Tansy ragwort and St. John's -wort SR 101, 109, 110 Clallam, Jefferson, and Grays Harbor county roads Biocontrols with WSU Herb Robert Jefferson County roads Olympic National Forest Olympic National Park Knotweed City of Forks Bogachiel River SR 101 Clearwater In summary, without persistent and early action, the unique biodiversity of the Olympic Peninsula will be rapidly overwhelmed; more restoration will be required, but with exponentially higher costs and reduced opportunity for long-term success. Based on achievements in the Hoh, Queets, and Clearwater rivers, we can demonstrate that prevention is highly cost-effective; analysis on the costs of control, effectiveness of actions, estimated numbers of invasive species stopped from invading specific places, and economic inputs to the local community will be provided in year-end reports. Why the project is a good fit for WCRI funding WCRI is the only non -salmon funding source focused on coastal restoration issues with sufficient funds to add significantly to the resolution of ongoing restoration needs, especially with regard to invasive species impacts, which are some of the most important restoration issues for coastal counties, and the lowest priority in all other resource or infrastructure management programs. Funding for invasive species prevention and control is extremely limited, and requires yearly application and reporting. WSDA is the sole reliable funding for knotweed control, but has much less funding than is needed. The State Department of Transportation's Integrated Vegetation Management Program is also underfunded relative to need, and lacks the ability or authority (state or county weed board - mandated) to work on SB. The State Salmon Recovery Funding is not intended to fund repeat projects (they term these 'programs') —which invasive species require. It is also the only program available to non-profit organizations, focused on local jobs and therefore local expertise and knowledge. Empowering communities, local youth, agencies and tribes in protecting and maintaining local ecosystems and the forestry, fisheries, and clean water, air, and soil that all rely on is really what coastal restoration is about; modeling how it can become locally -owned and operated. Added to that, it's funding the current PTIR program, saving the public, agencies, private industry, and tribes lots of money in the future by doing the work to end the destructive cycles of constant and costly habitat degradation resulting from invasive species. Summary: Pulling Together in Restoration — WCRI FY18 and FY19 Page 5 Sponsor Contact Information Name I Jill Silver Organization 110,000 Years Institute Phone 1 360.301.4306 E -Mail Address I (silver(cD10000yearsinstitute.org Summary: Pulling Together in Restoration — WCRI FY18 and FY19 Page 6 o w1404�F 4 b C a x O yb NFWFH {b« 00� Pre -proposal Project Narrative 1. Context: (Describe the project in terms of current conditions, opportunities for improvement, and relevance to existing conservation plans, strategies, or priorities (may provide links to documents). Ignored for decades on Washington State's Olympic Peninsula (OP) as merely a ubiquitous irritant, Scotch broom (Cytisus scoparius or CS) has migrated from roadsides and timber harvest units to the OP's dynamic river corridors and shorelines. From mid -elevation forest to nearshore dunes, CS out -competes native plant communities critical to species ranging from endangered Pacific salmon to marbled murrelets. Healthy resilient forests are an implicit goal of recovery programs for both species, and millions of dollars are both invested and accrued in forestry, fisheries, and restoration. Local economies are struggling with effects of climate change as precipitation regimes change and glaciers recede, reducing summer flow to aquatic habitats and drinking wells. As we all know, native plant communities support the entire ecosystem's web of biota, and non-native plants cause cascading harm throughout ecosystems. Research on the complex interaction of CS on native species is still evolving, and without science, the full impact of Scotch broom has yet to be accepted by landscape and resource managers, and the regulatory agencies, who guide practices to be most beneficial for both economies and environment. At present, CS is present over perhaps 10% of coastal watersheds, but has become a dominant forest cover to the east and south sides of the OP. A CS monoculture grows to 15 feet in height, produces 12,000 seeds per plant per year, which can remain viable for 80 years, and will not change over time as do natural plant communities, via forest succession. It replaces the early successional native species in disturbance zones such as river gravel bars, landslides, roadsides, and clearings: Willow, alder, and in time, the conifer forests; habitats providing forage, shade, nutrients, and other services including large woody debris, bank stability and sediment filtration to keep streams and rivers and forests naturally healthy. CS alters the composition of several important soil nutrients, and reportedly disrupts the mycorrhizal fungi critical to healthy forest growth 1. It is toxic to grazers, which avoid it. It is also considerably more flammable than native shrubs and trees, and certainly does not store the carbon taken up by a 200 foot tall Sitka spruce or Douglas fir. Although CS has enormous ecological impacts, it allowed to proliferate because it is assumed too costly and unnecessary to address. Not so! With people to do the work (local JOBS!), it can be done, saving the public millions of dollars of long-term impact and control costs. A recent economic impact analysis conducted by the state of Oregon reports 34:1 cost/benefit analysis2 for controlling CS. A similar study conducted by Washington State and released early this year states that CS costs $142.8 million in impacts, and 660 jobs3. Our work on the Hoh River shows a 40:1 benefit to cost ratio for pulling a plant in seedling stage rather than as a mature seeded plant. Contrary to a widely -held belief that CS is shaded out by forest regrowth — at 30-50 year rotations, it is the first species to appear in new harvest units, and glacial sediments in migrating rivers are transporting it too. Disturbance is the new normal, and CS thrives on it. The strategy to turn this situation around is the goal of the Scotch Broom Working Group (SBWG), a vibrant coalition of non-profit groups, tribes, timber industry, farmers, federal, state, and local agencies, and private landowners from the region, which has functionally dissolved without the support of a coordinator. 10KYI and a local concerned citizen established the group in 2013 to address the lack of regulatory and funding tools available to respond to the visible explosion of Scotch broom on the Olympic Peninsula. At that time, as now, as a Class C noxious weed, CS is relegated to 'voluntary control, usually by unpaid volunteers — completely inadequate to the task of eradicating this truly noxious invasive species that threatens so much of our economy 1 Grove S, Haubensak KA, Parker IM (2012) Direct and indirect effects of allelopathy in the soil legacy of an exotic plant invasion. Plant Ecol 213:1869-1882 2 http://www.oregon.gov/oda/shared/documents/publications/weeds/ornoxiousweedeconomicimpact.pdf 3 http://invasivespecies.wa.gov/council projects/economic impact/Invasive%20Species%20Economic%201mpacts%20Report%20Jan2017.pdf and wellbeing. Indeed, two of the goals outlined by the SBWG have been completed with hard work from four state agencies and others: 1) The initial Washington State Economic Impact Analysis, and 2) A region -wide symposium on the ecology and management of Scotch broom, held on May 23, 2017 in Snoqualmie, Washington. Three hundred concerned federal, state, local, tribal, non-profit and private citizens attended the conference', indicating the degree to which concern has risen. These two achievements, combined with persistent presentations and outreach to open-minded elected officials, information generated by researchers, and results from fieldwork conducted by IOKYI, have set a stage for massive change on the front of the `battle with broom'. This proposal and funding would create the foundational support of a formal working group and CISMA for the Olympic and Kitsap Peninsulas. The group would be supported by a coordinator with skills in all of the above disciplines and activities to make the case to decision -makers that a significant investment in CS eradication jobs, BMPs such as clean gravel, training in prevention, monitoring and control, tools, and other strategies is necessary and prudent to protect our forests, salmon, endangered species, and communities from decades of easily avoidable harm. 2. Activities: Project activities how achievable and expected to lead to the outcomes indicated below. A. Re-establish the working group; develop education and outreach tools and materials, speakers bureaus B. Craft legislation for funding for jobs; advocate for an Olympic and Kitsap Peninsula Conservation Corps to train local workers in effective methods. C. Design legislation for changing requirements for construction, landscaping, and other materials to be free of Scotch broom. D. Develop a certification program for clean materials and practices E. Develop the Second Scotch Broom Ecology and Management Symposium 3. Outcomes: Describe project outcomes using quantifiable metrics as described in RFP discuss what makes the outcomes achievable. 1. A demonstration of thriving early, mid, and late neral stage forest and riverine habitats where prevention and control is clearly effective in preventing costly impacts from CS. Most say `it can't be done'! We say `Pull one, stop many; early and often!' We're showing that it's achievable, modeling the BMPs. 2. The increased recognition and ranking of CS as an impact to salmon recovery and climate resiliency in Washington's Salmon Recovery and Watershed Planning processes and forums. We're bringing research, data, imagery, and results to these forums, making presentations that are opening eyes and minds. 3. The development and refinement of ED/RR management protocols for the focal noxious weed species impacting forest development and growth, but which are considered too widely spread and infeasible to prevent and control, and which are rarely approached on a regional scale. 4. Increasing awareness of the value of ED/RR for protection of resource industries and salmon and their habitats, and carbon storage/climate change, at all levels of government, resource management agencies, academia, private commercial and industrial landowners, and the public. 5. A locally -based Conservation Corps contributing their knowledge of the rivers and forest, learning about watershed ecosystem services and the degrading impacts of non-native plants; which is then shared with their family and friends and their elected representatives, and makes the case that investing in local jobs on CS has an enormous benefit to the resources the sustain these communities. We're working with a regional group — Rural Communities Partnership Initiative — made up of many jurisdictions and industries on the Olympic Peninsula to bring this idea forward. Everyone wants local sustainable jobs and resilient communities. This FITS. 4. Other (Optional): Provide any additional information important for the review of this proposal. 4 http://www.invasivespecies.wa.aov/scotch-broom-symposium.shtml Page 2 Economic Impact of Invasive Species to Washington State $1.3 Billion Total Economic Impact Invasive species are non-native organisms that cause economic or environmental harm and are capable of spreading to new areas of the state. Invasive species harm Washington State's landscapes, ecosystems, agriculture, commerce, recreation, and sometimes human health. The damages from invasive species translate into economic losses for communities and businesses. While there more than over 200 known invasive species found within or near Washington State, this economic analysis highlights the damages and potential impacts that could result if 23 of these plant and animal species were allowed to spread in Washington in a single year. Without prevention and control, the selected invasive species could have a total impact of $1.3 billion dollars annually Four Costly Invasive Species These four invasive species damage our state economy and resources. The dollar amounts and lostjobs represent the potential total economic impact* of each species. Plants Scotch Broom Cytisus scoparius Ubiquitous Scotch broom is a serious threat to native prairies and forests. It prevents timber regeneration and displaces pasture forage for grazing animals. The plant is toxic to livestock and is a fire hazard. $142.8 million 660 jobs lost Animals Quagga/Zebra Mussels Dreissena bugensis/D, polymorpha While not established in Washington, invasive mussels have the potential to devastate numerous industries. The freshwater mollusks threaten lakes, rivers, dams, and irrigation systems; degrade water quality; and impact the ability to recreate on waterways. $100.1 million 500 jobs lost Smooth Cordgrass Spartina alterniflora Smooth cordgrass is an estuarine grass that has densely arranged stems and a thick mat of roots. It displaces native species, destroying habitat and food sources for fish, waterfowl, and other marine life. $48.6 million 360 jobs lost Apple Maggot Rhagoletis pomonella A major threat to Washington's apple industry, the apple maggot also affects pear, plum and cherry crops. If apple maggots are found in an orchard, the fruit is unsuitable for export. $392.5 million 2,900 jobs lost °..., .,NGYIGa,@ 1K9$41 sh' Nto lnvaST&" Control Bo ird I s %^CIPS f`f%afFCll I Industry Impacts The dollar amounts shown represent the potential total economic impact* of 23 invasive species on Washington industries in terms of lost revenue and jobs. Cad Recreation $47.6 million 300 jobs Water Facilities $100.5 million 500 jobs Livestock $282.9 million 1,500 jobs Timber $297.0 million 1,300 jobs Crops $589.2 million 4,400 jobs Invasive species included in this analysis Rush skeletonweed Scotch broom Himalayan blackberry Yellow starthistle Knapweed species Leafy spurge Purple loosestrife Invasive knotweed Eurasian watermilfoil Smooth cordgrass Apple maggot Quagga/zebra mussels Gypsy moths Emerald ash borer Nutria Feral swine *Total economic impact includes direct, indirect and induced impacts vrPWSDOT ECOLOGY° 4 7 § § CQ ] �t j �\ » § / 2 � I a LU � § ui U, / LS § k HI � § LU § § 2 n m o' 1O oo O m N m m ci m V1 .-I c -I 01 m W 'oci oo oo n N c -I m oo N N N m Lf1 m c -I c -I c -I Lfl c -I c -I N Oo N ti m c -I N N W ai oo oo Qa N 2 m mJ w � 71m c6N Q d N D. 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