Integration of AusAID, effectiveness and benchmarks
This chapter considers the implications of integrating AusAID into DFAT,
and examines measures to improve the effectiveness of aid and the development
of performance benchmarks.
There is a lack of clarity around the rationale for integrating AusAID
into DFAT, and the committee received evidence both in favour, and concerned
about, this development. DFAT considered that the key outcome of the
integration of AusAID would be 'a transformed Department with the skills,
resources and connections to implement foreign, trade and development policies
and programs in a coherent, effective and efficient way that best serves
Australia's national interests'.
Integration will also increase the impact of Australia's
foreign, trade and aid policies and programs. Effective Australian aid provides
access and influence which can support foreign and trade objectives. At the
same time, bringing the full weight of Australia's diplomatic resources to
support development objectives provides the opportunity for greater influence
DFAT outlined for the committee how the integration process was being
managed by a high-level steering committee 'with a view to having a final
integrated structure in place by 1 July 2014'. It noted the steering
committee was aiming for a 'Department that aligns and implements foreign,
development, and trade policies and programs and has the capabilities and
systems to deliver a large and complex aid program'.
In particular, the steering committee has retained 'a central group with
responsibility for the oversight and integrity of the aid management system,
and for providing policy and technical advice to ensure the coherence and
quality of aid investments'.
DFAT also noted that the 'former AusAID Strategic Programming Committee,
which considers major aid investment and program planning decisions, and the
Development Policy Committee, which considers key and emerging development
policy issues, have been incorporated as part of the DFAT governance structure'.
At the public hearing, the Secretary of DFAT, Mr Peter Varghese,
provided a further update on the integration process:
We have 13 working groups looking at everything from
information technology to accommodation, structure and how we get the balance
right between offshore and onshore, and we have begun and indeed very
significantly advanced the process of organisational structural integration. So
we now have made decisions on bringing together in geographic areas aid,
foreign policy and trade policy, to be pursued in an integrated way. We have
either set up or retained specialist divisions that have the expertise that you
need to run a $5 billion aid program, whether that be in the design of the
program, the evaluation of it, the setting up of benchmarks...
Opportunities and risks
Both opportunities and risks were identified as arising from the
integration of AusAID into DFAT. The potential for a more cohesive and stronger
diplomatic approach to development issues was seen as a key opportunity. For
example, the submission from the Australia Strategic Policy Institute observed
that objectives of poverty reduction and promoting Australia's national
interests are not incompatible and that accordingly, the 'amalgamation of
AusAID and DFAT should allow for a more responsive and flexible aid policy,
better aligned to [Australia's] foreign policy'.
However, as well as opportunities there were several risks were
identified. Oaktree were concerned 'that the integration of AusAID into DFAT
will jeopardise the integrity of Australia's aid program and lead to a further politicization
of aid, whereby it will be almost exclusively used as a tool to exert influence
over trade deals as opposed to being a measure focused on impacting extreme
Similarly, the CPSU argued that '[m]achinery of Government changes incur
substantial financial and productivity costs in the short to medium term' and
this would impact on the ability of Australia's aid program to deliver against
its commitments to recipient developing countries.
The Development Policy Centre noted that the announcement of the
integration of AusAID into DFAT was unexpected, and that no convincing
rationale has been provided for the decision. In particular, it noted that the
integration did not mean that there was any more ministerial control over the
aid program. However, it acknowledged that the 'resulting administrative arrangements
will not be unusual' and that many OECD donor countries 'house aid policy and/or
administration in their foreign ministries'.
The Development Policy Centre recommended that the 'government should
give consideration to establishing unified oversight of aid policy and
management within the DFAT Executive and engaging external sources of advice on
the implementation of the integration agenda'.
It indicated it would be desirable, for reasons of coherence and accountability,
for there to be a single senior position within DFAT specifically and
exclusively responsible for the oversight of aid policy and administration.
In relation to the integration, the Development Policy Centre commented
that there is 'a substantial risk, at a time when many commentators are
decrying what they see as the under-resourcing of Australia's diplomatic network,
that aid funds in the departmental expenditure category will be used to
subsidise diplomatic infrastructure and salaries'.
Despite these concerns, at the public hearing, Mr Robin Davies from the
Development Policy Centre noted:
[E]verything we have seen to date including in DFAT's
submission to this inquiry, the structures that are being put in place are very
sensible. We are seeing strong geographic integration but we are also seeing a
preservation of some core aid policy and management functions in dedicated
divisions, and we strongly support that.
Ensuring adequate consultation with stakeholders was also seen as
essential to the successful integration. Mr Paul Kelly from Care Australia
commented that DFAT should be engaging stakeholders, arguing that 'good
communication in this process will reduce the impact of staff turnover and the
likely delays in decision making'.
IDC Australia noted that three critical issues for the sector highlighted by
the 2013 Australian aid stakeholders survey (the avoidance of micromanagement,
quick decision-making, and staff continuity) could be affected by the
integration of AusAID and DFAT. Similarly,
Results International Australia noted that a short term consequence of the
integration 'has been increased difficulty in making contact with officials
(and knowing which person is the best contact on a specific issue) and also
delays in decision-making processes'.
Specialist skills and staff
Prior to the integration there were 2521 DFAT staff with 646 based
overseas and 1724 AusAID staff with 240 based overseas. DFAT characterised the AusAID
staff numbers as reflecting 'an organisation that was recruiting and building
capabilities in anticipation of delivering the previous Government's projected
$8 billion program'. It noted the aid budget has now 'stabilised' at around $5
DFAT also noted it was 'seeking to manage prospective job losses as much as
possible through natural attrition and a voluntary redundancy program'.
At the hearing, Mr Varghese observed there were still a number of
integration issues that DFAT was working through 'including what our final
numbers are going to be'. He noted this matter would be 'sorted out in the
course of the 2014-15 budget'.
The principles for the integration outlined that 'in order to maintain aid
policy and program management expertise, the department will have a development
career stream/structure, with some positions in Canberra and overseas
designated as requiring international development assistance skills'.
Several submissions highlighted that specialist skills and staff are
required to effectively deliver aid programs in developing countries and the
integration of AusAID risked the loss of experienced aid professionals. For
example, TEAR Australia noted that '[s]taff implementing and managing
Australia's aid program need both technical skills and also an understanding of
the local operating context and culture'.
Care Australia advised that '[t]here should be a professional aid cadre with
geographic and sector expertise who are clear about the aid program's quality
and framework and are equipped to implement it'. Childfund
The aid portfolio entails a substantial budget, highly
complex arrangements with multiple partners and numerous policy and operational
challenges. Strong leadership, clear policy directions, professional administration
and a deep understanding of the complexities are required. It is vital that a knowledgeable
and experienced department be retained and valued in order to administer the Government's
aid program effectively. The merger of the departments risks undermining the
dedicated focus on aid policy and administration, and could lead to the loss of
Mr Robin Davies from the Development Policy Centre was also concerned
that significant staffing reductions were taking place at the same time as
structural changes were being implemented. He noted that this 'could well lead
to a very significant loss of professional expertise in the organisation'. Mr Davies
suggested this was a matter that needed to be carefully managed and 'post-integration
will need to be the subject of a stocktake and a substantial workforce planning
Further, the Development Policy Centre recommended staff turnover in DFAT
should be carefully monitored and targeted.
A need for specialist sectoral and technical support within DFAT was
also identified. CBM Australia noted that as the 'integration process
continues, it is essential that strong technical support for disability inclusion
is embedded within the new DFAT structure'. This was required for policy
development and implementation, disability specific programs and ensuring
disability inclusion was embedded across all development programs.
Similarly IWDA urged support for a 'diverse gender advisory and specialist team'
Women and men continue to play different social and economic
roles and face different opportunities and challenges in every country
Australia engages with. Without the analytical capacity to see and understand
the implications of this, opportunities will be lost and policies and programs
will be sub-optimal, an unnecessary and avoidable waste of resources.
The DFAT submission highlighted that the former AusAID's humanitarian
capabilities have been retained in a division which manages 'Australia's
humanitarian policies, programs and capabilities in order to help prevent,
prepare for and respond to disasters and humanitarian crises'.
This was welcomed by Ms Melissa Wells from Save the Children:
We are encouraged to see that the humanitarian unit will
remain distinct. That is really important from our perspective of impartiality
and delivery of humanitarian aid that is not aligned with foreign objectives
and military objectives.
The potential for the merger to strengthen DFAT was also highlighted
during the inquiry. The findings of the Australian Public Service Commission's
Capability Review in 2013 included that DFAT had:
- an excellent overseas network, but was less effective in
- could deliver in crisis, but was suspicious of prioritisation and
strategic planning; and
- was a good advocate of existing policy, but was 'less good at
In response to the APSC Capability Review, DFAT noted it has committed
to developing a four-year (2015-19) workforce plan 'to build and maintain the
required organisational capability and culture for the integrated Department'.
In relation this issue, Mr Marc Purcell from ACFID commented:
We think that with the merger you are bringing in aid
managers from AusAID whose strength is in long-term planning and
evaluation—because you have to plan at a country or thematic level around
investment of dollars into programs and then you have to evaluate what is
happening over time. We think there are synergies there if the merger is well
managed and you can combine the two different strengths of the two different
A distinct Australian aid program
Maintaining the distinct identity of the Australian aid program was also
perceived as important by a number of aid organisations and businesses. Save
the Children considered the advantages of the previous arrangement included
that 'AusAID had a distinct humanitarian identity, housed a dedicated body of
expertise on aid and development policy and programs, was one step removed from
short-term political objectives, and was a highly visible demonstration of
Australia's commitment to international development'.
ACFID also pointed out that the model of integration being adopted
appeared to be a merger of foreign policy and aid 'country desks' rather than
maintaining the aid program as a separate identity within DFAT. It noted this
differed from the approach taken in New Zealand when a similar integration of
an aid agency occurred 'where an International Development Group [was]
maintained as a cohesive unit within the Ministry of Foreign Affairs.
ACFID noted that it also differed from the Australian experience with the 'aid
program consistently having a separate identity and direct reporting relationship
to its Minister since the mid-1970s'.
Similarly World Vision recommended that DFAT maintain a cluster within
the DFAT structure which is 'dedicated to aid and development policy and
technical capacity'. It considered this would facilitate 'streamlined
engagement with implementing partners and other key stakeholders, and would
enable working relationships to continue throughout the integration process'.
A proposal made by a number of submitters was that DFAT should alter its
name to reflect its overseas aid responsibilities, for example to the
Department of Foreign Affairs, Aid and Trade. It was noted that the
equivalent department in Canada was recently renamed the 'Department of Foreign
Affairs, Trade and Development' following its amalgamation with the Canadian
International Development Agency.
The Development Policy Centre considered DFAT's mission statement and
priorities should also be amended to 'give appropriately greater emphasis to
the aid and development goals for which DFAT now has responsibility'. It
Australia's aid program does advance Australia's interests
but that is not its sole rationale. The aid program is as much an expression of
Australian values as of Australian interests. DFAT, now that it has
responsibility for Australian aid, should rewrite its mission description to reflect
These might be dismissed as cosmetic changes, and indeed they
will only be important should they come to symbolize a fundamental change in
the way DFAT priorities are set, changes which are required to extract full
value from the recent merger.
Lack of public awareness regarding the activities and achievements of
the Australian aid program was also raised. For example, the Business Council
of Australia noted that Australia's aid program represents 'a significant
investment of federal revenue' and supported increased public understanding and
confidence in the aid program.
This reflected the Independent Review's finding in 2011 that there was not 'an
effective communications strategy for the aid program' and that fostering more
informed public debate and community engagement with the aid program was
It recommended that '[p]ublic engagement should be improved through a new community
grants scheme, embracing new media technologies and promoting development
AusAID launched the 'Engage' blog in November 2011, as a platform to communicate
and discuss Australia's aid program featuring 'updates, stories and analysis
from Australian Government staff who will be blogging from around the world'.
There is a sophisticated matrix of independent measurement tools used by
the OECD to review aid effectiveness. The OECD DAC peer review in 2013
concluded that 'Australia's aid system is set up to deliver the current and a
growing aid programme effectively'.
Similarly, the Independent Review in 2011 commented:
In aid, performance needs to be judged against degree of
difficulty. Australia is seeking to get results in difficult and sometimes
dangerous countries overseas, in a wide range of areas from health and
education to humanitarian support in emergencies, and grappling with multiple methods
of delivery. By the standards of donors generally, Australia is an effective performer.
In its submission to the inquiry, DFAT stated that 'the aid program will
be driven by a strong performance culture' which 'recognises the need to use
taxpayers funds as effectively as possible'. DFAT noted that the Office of
Development Effectiveness (ODE) and Independent Evaluation Committee (IEC)
'have been maintained as part of DFAT's governance and accountability
In particular, the ODE 'will continue to produce independent, high-level
evaluations of aid program policies and strategies, development themes, and
selected individual aid activities'.
Support was expressed during the inquiry for continuing and expanding
existing aid effectiveness measures. For example, ACFID recommended that the
government continue to fund 'initiatives to ensure a focus on results and a
evidence-based approach to Australian aid including through the Office of
Development Effectiveness' as well as undertaking an annual review of aid
ODE plays an important role in informing and advising the
Australian aid program through in-depth evaluations and reviews of Australia's
aid, analysis of aid performance systems, and collaborations with leading
international think-tanks and research organisations. Greater independence and
credibility could be achieved by making the ODE fully independent, reporting to
Similarly, Sustineo queried the independence of the ODE, arguing that it
reports to the head of the aid program. It recommended the establishment of an
independent body which reports directly to the Parliament to monitor, evaluate
and benchmark the activities delivered by the Australian aid program. Save the
Children also argued that the ODE should be strengthened and for a 'more timely
release of the Annual Review of Aid Effectiveness' in order for it 'to feed
meaningfully into the Cabinet's yearly consideration of progress against the
government’s four year budget strategy'.
TEAR Australia noted that AusAID had developed a comprehensive set of
assessment, monitoring and evaluation tools which had been tested and proved
their value. These were the Monitoring, Evaluation and Learning Framework; the
Due Diligence Framework; and the Effectiveness Assessment Methodology. It
argued these existing effectiveness measures 'should be retained and modified
in light of experience'.
Aid is delivered by a large number of other government agencies, such as
the Australian Federal Police.
A frequently cited factor to improve the effective delivery of aid was
increased coordination of aid programs across government. Previously, whole-of-government
oversight of Australia's aid program was provided by the Development
Effectiveness Steering Committee, a cross-agency committee which advised the
Australian Government on major aid policy and aid budget priorities and concerns.
In its submission DFAT did not indicate how this role would be filled following
the integration. On 28 June 2013, AusAID announced that '[a]ll Australian
government agencies delivering overseas development assistance have agreed to
adopt uniform standards for the planning, delivery, monitoring and reporting of
Australia's total aid program':
The standards are
principles based and will ensure that Australia's aid activities are delivered
in a consistent way whilst at the same time allowing agencies to operate in
accordance with their own management systems...The first suite of uniform
standards have been endorsed by a high level inter-departmental committee and
are now in place.
In 2011, at the 4th High Level Forum on Aid Effectiveness in
Busan, donor countries committed to 'improve the availability and public
accessibility of information on development cooperation and other development
resources'. The OCED DAC peer review in 2013 considered that 'Australia has
taken exemplary steps to increase the transparency of its development
co-operation and is one of the forerunners in implementing the Busan commitment
Nonetheless, transparency issues were raised during the inquiry. For
example, the Development Policy Centre recommended that the Transparency
Charter adopted by the previous government be endorsed and given wide
application to increase the amount of activity-level information made
Analysis conducted by researchers at the Development Policy Centre of the
AusAID website concluded that 'there was a substantial data dump in 2011 when
the Transparency Charter was introduced, but much less by way of subsequent
effort to fill holes or add new information'. It identified institutionalising
'a culture of transparency' as an important change so that 'the timeliness and
comprehensiveness of publicly-available data improve over time'.
ACFID also noted that, while Australia was a signatory to the
International Aid Transparency Initiative and had developed a Transparency
Charter, there had still been 'slow and incomplete provision of activity level
Micah Challenge urged DFAT to recommit to the transparency agenda commenced by
AusAID 'by publishing integrated country strategies with expected development
outcomes clearly outlined, and publishing timely project level reviews and
assessments for all aid-related activities'.
World Vision recommended that DFAT 'maintain the practice of producing a
Ministerial Statement (Blue Book) on the Australian aid program':
The production of a Ministerial Statement (Blue Book) for the
Australian aid program has been a significant contributor to advancing the
transparency of the aid program. Breakdowns by priority, geography, sector and
multilateral institution have provided an invaluable source of data for
implementing partners, academics, civil society and the broader aid community...While
departmental funds associated with the former-AusAID will likely be integrated
into DFAT reporting, it is still important that ODA funds, including those
administered by departments other than DFAT, are reported separately and
Others such as Professor Richard Feachem highlighted the right of
Australian taxpayers to know how aid resources are invested in other countries.
In the 2013 Aid Transparency Index, AusAID was placed 24th
out of 67 aid organizations scored and ranked for transparency. Australia
scored 43%, in comparison to the highest scorers which achieved over 80%...Becoming
a top scorer in the Aid Transparency Index is a readily achievable short-term
priority for the Australian aid program. It would do much to enhance
credibility and deter or detect corruption.
In her speech to the Australasian Aid and International Development
Policy workshop, Minister Bishop provided further details on the proposed
benchmarks for aid and how they would be used to direct resources:
At the strategic level, we will assess the entire aid
programs progress against key goals and priorities – a small number of high
level targets. We will use performance benchmarks at the level of individual
programs to assess the relative effectiveness of our portfolio of investments,
and these assessments will determine how the aid level are allocated. Then at
an individual assessment level, we will ensure funding is directed to those
programs, those investments that are making the most difference and that
poor-performing projects or poor-performing deliverers are either improved or
the funds are redirected...We will also review the way we assess the performance
of our delivery partners – multi-lateral organisations, NGOs and contractors –
to ensure there is a stronger link between performance and funding...
DFAT noted it was developing performance benchmarks for the Minister's
consideration which 'will provide additional assurance that the aid program is
effective, efficient and achieving results'. It stated:
The benchmarks will promote greater value for money and
increase transparency of aid expenditure. The aid program and the Department
will be assessed annually against these performance benchmarks, with policy
settings and investments adjusted in line with the outcomes. Consultations on
the proposed benchmarks are being held with key stakeholders, including partner
governments, NGOs, industry, academia and other Australian government agencies
with a role in delivering the aid program.
Broad support existed for the creation of benchmarks for Australian aid
to allow the impacts of aid to be measured. However, a number of witnesses and submissions
also cautioned against benchmarks that were narrowly focused on outputs rather
than the achievement of outcomes in developing countries.
For example, the Australian Strategic Policy Institute argued that any benchmarks
for aid would need to be framed carefully:
On the question of
how the aid program might be structured to ensure that performance against
benchmarks has a direct feedback effect on the overall size and allocation of
the aid budget, we would agree that in general good results could often
usefully be incentivised. However, we'd also caution that where key strategic
imperatives are at stake, it could be strongly against our national interest to
penalise poor performance in some part of a project. This too argues for
evaluating the contribution of aid projects against high level strategic
benchmarks more than more specific tactical ones.
Similarly, Ms Joy Kryiacou from ACFID cautioned that 'depending on what
they are focused on and how they are measured sometimes benchmarks can pose a
threat to effective development':
[W]e want to make sure that benchmarks do not reduce
innovative approaches and that they do not lead to over-compliance and red
tape. Sometimes in other contexts we note that benchmarks can lead agencies to
invest only in those activities that can be easily measured, such as
vaccinations, and not necessarily in programs that might drive more
transformational change, such as women's leadership initiatives.
The Development Policy Centre noted that the previous government's Comprehensive
Aid Policy Framework incorporated 'the kind of benchmarks or "hurdles"'
previously recommended by the Independent Review:
First-tier results related to overall development progress in
partner countries, second-tier results captured the specific contribution of
Australia's aid effort and third-tier results related to aid management
measures. First-tier results were to be monitored but no accountabilities
applied. Second- and third-tier results constituted Australian government
commitments for which the government accepted accountability. This approach
broadly reflected best practice among international development agencies,
particularly the multilateral development banks.
However, the Development Policy Centre considered this framework was 'excessively
oriented toward highly aggregated headline results, without a sufficient emphasis
on efficiency and effectiveness at the level of country programs, specific
activities and delivery partnerships'.
It made a number of suggestions for the development of performance benchmarks:
Performance benchmarks should be defined within the three-tier
framework already adopted for the 2012 [Comprehensive Aid Policy Framework],
and should, for a variety of reasons, give greater weight to process benchmarks
vis-à-vis 'headline' policy-related or 'results' benchmarks, with an emphasis
on the consistent and demonstrated application of key aid management systems. Benchmark
assumptions and data should be reported in detail, for both targets and
performance against targets. Performance benchmarks should be used for redistributive
purposes, not to determine aggregate aid levels.
Australia is a signatory to the Paris Declaration on Aid Effectiveness
and the Accra Agenda for Action, which focus on improving the quality of aid,
the coordination of donor efforts and aligning donor programs with recipient
In this context, Oxfam Australia recommended that performance benchmarks for
Australia's aid program should be based on internationally agreed
aid-effectiveness principles and applied consistently. Ms Jo Pride from Oxfam
I think the critical point is to ensure that, whichever
department is delivering aid, we are holding ourselves to a consistent standard
about aid effectiveness. If we are looking at benchmarks for what it is that
the Australian aid program does through DFAT, then those same benchmarks should
be applied to the other departments that are spending aid as well.
Others argued that, to be useful, the proposed benchmarks must be
directly linked to the objectives of Australia's aid program. For example, the
United Nations Association of Australia urged:
In developing benchmarks, the Government must make clear what
its overriding goal is, and it must be more than advancing Australia's
interests. To date, there has been little mention of poverty in discussion
about the new direction of Australia’s aid program and much mention of aid for
trade and economic diplomacy.
Specialist staff and skills
The committee was encouraged by the number of witnesses and submissions who
identified opportunities to improve Australia's aid program through the integration
of AusAID into DFAT. However, there is clearly a risk that DFAT, through the integration
process, will lose key skills, procedures and specialist staff needed to effectively
administer Australia's aid program. The committee is gratified that DFAT appears
to be taking steps through the integration process to manage this risk. Nonetheless,
the committee considers that an independent audit/review of DFAT's capabilities
should be undertaken following the conclusion of the integration process to
ensure the aid program continues to be delivered effectively.
The committee recommends that the Australian National Audit Office undertake
a review of the Department of the Foreign Affairs and Trade to ensure it has
retained and maintained the key skills, processes and specialist staff necessary
to effectively administer Australia's aid program.
During the inquiry recommendations were made for the name of the
department to be changed to reflect its additional responsibilities for
overseas aid and development assistance. For example, the Department of Foreign
Affairs, International Development and Trade (DFAIDT). The committee considers
this change would be beneficial to promote this new role in Australia and
overseas. The committee supports the continued promotion of the 'Australian
Aid' logo in all international development programs and projects funded by the
The committee recommends the Australian Government consider changing the
title of the Department of Foreign Affairs and Trade to reflect the importance
of its overseas aid and development assistance responsibilities.
Accountability and transparency
The committee welcomes the retention of the Office of Development
Effectiveness and the Independent Evaluation Committee in the accountability
framework of DFAT as it integrates the functions of AusAID. The committee is
also pleased to note that the Joint Committee on Foreign Affairs, Defence and
Trade has established a Foreign Affairs and Aid Subcommittee. This was
previously a recommendation of the committee in its report on official
development programs in Afghanistan.
The resources for the aid program are contributed by the Australian
community. They have a right to know how and where aid funding is expended and
what outcomes have been achieved. As far as possible, information about
Australia's aid program should be made publicly accessible in a timely manner.
In this context, the committee considers that DFAT should recommit to the
Transparency Charter and continue to work to increase the volume of information
publicly available regarding Australia's aid program.
The committee recommends that the Department of Foreign Affairs and
Trade recommit to the Transparency Charter and continue to increase the amount
of publicly available information regarding Australia's aid program.
Aid effectiveness and benchmarking
The creation of benchmarks for Australia's aid program was supported by
the vast majority of those who contributed to the inquiry. The committee also
considers that appropriate benchmarks have the potential to improve the
effectiveness of Australia's overseas aid. However, a number of concerns were
also raised during the inquiry which highlighted that, in some circumstances,
benchmarks could act to reduce the effectiveness of aid. In the view of the
committee it is vital that any benchmarks for aid are applied consistently
across all government agencies which provide overseas aid and are consistent
with OECD DAC guidelines for ODA. The committee urges Senator Mason to
continue his close consultation with the aid sector in the development of the
The committee recommends that the Australian Government develop aid
benchmarks which can be applied consistently to all agencies which provide
official development assistance.
The committee recommends the Australian Government continue to consult
closely with aid sector stakeholders in the development and implementation of
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