Appropriation Bill (No. 1) 2018-2019 [and] Appropriation Bill (No. 2) 2018-2019 [and] Appropriation (Parliamentary Departments) Bill (No. 1) 2018-2019

BILLS DIGEST NO. 131, 2017–18

PDF version [263KB]

Dinty Mather
Economics Section
25 June 2018

Contents

Purpose of the Bill
Structure of the Bill
Background
Committee consideration
Financial implications
Statement of Compatibility with Human Rights

 

Date introduced:  8 May 2018
House:  House of Representatives
Portfolio:  Finance
Commencement: The later of 1 July 2018 and Royal Assent

Links: The links to the Bills, their Explanatory Memoranda and second reading speeches can be found on the Bills’ home pages for the Appropriation Bill (No. 1) 2018–2019, the Appropriation Bill (No. 2) 2018–2019 and the Appropriation (Parliamentary Departments) Bill (No. 1) 2018–2019, or through the Australian Parliament website.

When Bills have been passed and have received Royal Assent, they become Acts, which can be found at the Federal Register of Legislation website.

All hyperlinks in this Bills Digest are correct as at June 2018.

Purpose of the Bill

The purpose of the Appropriation Bill (No. 1) 2018–2019 (the No. 1 Bill) is to seek an appropriation from the Consolidated Revenue Fund (CRF) of $95,230,047,000 ($95.2 billion) for the ordinary services of Government.[1] Of this appropriation:

  • $55,787,512,000 ($55.8 billion) is for the departmental activities of government entities[2] and
  • $39,442,535,000 ($39.4 billion) is for activities that government entities administer on behalf of the Commonwealth Government.[3]

The purpose of the Appropriation Bill (No. 2) 2018–2019 (the No. 2 Bill) is to seek an appropriation for the other services of Government. The No. 2 Bill seeks to appropriate $13,003,986,000 ($13.0 billion) from the CRF:[4]

  • $463,687,000 ($463.7 million) for payments to states, ACT and NT and local governments[5] and
  • $5,810,000 ($5.8 million) for new administered outcomes[6] and
  • $12,534,489,000 ($12.5 billion) for non-operating activities.[7]

The purpose of the Appropriation (Parliamentary Departments) Bill (No. 1) 2018–2019 (the Parliamentary Departments Bill) is to appropriate $249,859,000 ($249.9 million) for the Parliamentary departments.[8]

Structure of the Bill

Part 1 of each Bill deals with preliminary matters, including when the Acts commence, and how to interpret the Acts.

Part 2 of each Bill outlines the quantum and types of appropriation from the CRF.

Part 3 of each Bill provides for either an Advance to the Finance Minister (AFM) or an Advance to the Presiding Officers of the Parliamentary departments, whichever is appropriate.

Part 4 of both the No. 1 Bill and the Parliamentary Departments Bill and Part 5 of the No. 2 Bill deal with technical matters including crediting amounts to special accounts, the formal appropriation of moneys from the CRF, and the automatic repeal of the subsequent Acts.

Part 4 of the No. 2 Bill sets the maximum amounts that can be drawn each year from the CRF for three types of grant to the states and territories that the Commonwealth may make. These limits are known as ‘debit limits’.

Schedule 1 of the No. 2 Bill nominates the Ministers who are able to impose conditions on grants of financial assistance to the states and territories proposed in that Bill.

Schedule 1 of the No. 1 Bill and the Parliamentary Departments Bill and Schedule 2 of the No. 2 Bill contain the details of the amounts and types of appropriation to be made to each entity.

Background

There are certain unique constitutional requirements that a Bill proposing to appropriate moneys must satisfy. An appropriation Bill must also comply with certain presentational requirements. The No. 1 and No. 2 and Parliamentary Departments Bills do not deal with standing appropriations.

Constitutional requirements

Section 81 of the Constitution provides:

All revenues or moneys raised or received by the Executive Government of the Commonwealth shall form one Consolidated Revenue Fund, to be appropriated for the purposes of the Commonwealth ...[9]

Section 83 of the Constitution provides that no money may be withdrawn from the CRF ‘except under appropriation made by law’.[10] The effect of these two sections is that all moneys received by the Commonwealth must be paid into the CRF, and must not be spent before there is an appropriation authorising specific expenditure.

Powers of the House of Representative to Appropriate

Section 53 of the Constitution provides that laws appropriating money may not originate in the Senate.[11] Further, under section 56 of the Constitution, all proposed laws for the appropriation of money may only be introduced following a recommendation by the Governor-General.[12] By convention the Governor-General acts only upon the advice of the Executive, so section 56 prevents non–government members of the House of Representatives introducing Bills that would propose to appropriate money from the CRF.[13]

Powers of the Senate to amend

The Senate may not amend proposed laws appropriating revenue or moneys for the ordinary annual services of the Government. The Senate may, however, return to the House of Representatives any such proposed laws requesting, by message, the omission or amendment of any items or provisions.[14]

The Senate may amend proposed laws appropriating revenue for purposes other than for the ordinary annual services of the Government, as long as it does not ‘increase any proposed charge or burden on the people’.[15] Conceivably, the Senate could amend an appropriation Bill for the other services of Government so as to, for example, redirect the proposed appropriation to another purpose, or reduce the proposed appropriation to nil. The Senate may also request that, if new measures are included in a Bill for the ‘ordinary annual services of Government’, the Bill be returned to the House with a message requesting those new measures be omitted from the Bill.

The ‘ordinary annual services of government’ versus the ‘other’ services of government

Section 54 of the Constitution requires that there be a separate law appropriating funds for the ‘ordinary annual services of government’, and that other matters must not be dealt with in the same Bill.[16] However, what constitutes the ‘ordinary annual services of the Government’ and ‘other’ services of the Government is not defined in the Constitution.

A working distinction between ordinary and other annual services was agreed in a ‘Compact’ between the Senate and the Government in 1965.[17] Several amendments have been made to the Compact since 1965, and in 2010 the Senate Standing Committee on Appropriations and Staffing recommended the Senate restate the Compact in a consolidated form.[18] On 22 June 2010, the Senate resolved as follows:

(1)   To reaffirm its constitutional right to amend proposed laws appropriating revenue or moneys for expenditure on all matters not involving the ordinary annual services of the Government.

(2)   That appropriations for expenditure on:

        (a)        the construction of public works and buildings;

        (b)        the acquisition of sites and buildings;

        (c)       items of plant and equipment which are clearly definable as capital expenditure (but not including the acquisition of computers or the fitting out of buildings);

        (d)        grants to the states under section 96 of the Constitution;

        (e)        new policies not previously authorised by special legislation;

        (f)         items regarded as equity injections and loans; and

        (g)        existing asset replacement (which is to be regarded as depreciation),

are not appropriations for the ordinary annual services of the Government and that proposed laws for the appropriation of revenue or moneys for expenditure on the said matters shall be presented to the Senate in a separate appropriation bill subject to amendment by the Senate.

(3)   That, in respect of payments to international organisations:

        (a)       the initial payment in effect represents a new policy decision and therefore should be in Appropriation Bill (No. 2); and

        (b)       subsequent payments represent a continuing government activity of supporting the international organisation and therefore represent an ordinary annual service and should be in Appropriation Bill (No. 1).

(4)   That all appropriation items for continuing activities for which appropriations have been made in the past be regarded as part of ordinary annual services.[19]

Adherence to the Compact has not always been strict, and the High Court has held that any disagreements between the Houses are not justiciable.[20] Any disputes are to be determined between the Houses themselves.

Presentational requirements

Departmental and administered expenses

Australian Accounting Standard 1050 Administered Items requires that government agencies distinguish between revenues and expenses that they administer for the Government, and those over which they have some control.[21] Generally, administered expenses are the costs of programs that agencies run for the Government, while departmental expenses are the costs incurred in running agencies.[22]

Appropriation Bills, therefore, distinguish between ‘administered’ expenses and ‘departmental’ expenses. An administered appropriation may be used only for the program or outcome that it is appropriated for, while a departmental appropriation may be moved between different departmental activities.[23]

Outcomes and programs

While the level of detail necessary for an Appropriation Act to be valid is generally low,[24] in the Pharmaceutical Benefits case the High Court held:

... there cannot be appropriations in blank, appropriations for no designated purpose, merely authorising expenditure ... [25]

The Appropriation Bills must therefore describe—in general terms—what the moneys are to be utilised for. The Bills use four methods for describing the purposes of the proposed appropriations.

Appropriations for ‘outcomes’ of non-corporate Commonwealth entities

For non-corporate Commonwealth entities, the purposes of operating appropriations (both departmental and administered) are specified with reference to the ‘outcomes’ of those entities. The Department of Finance explains ‘outcome statements’ in the following terms:

... outcome statements articulate Government objectives and form an integral part of the appropriations framework. They:

1.     explain the purpose for which annual appropriations are approved by the Parliament for use by entities;

2.     provide a basis for budgeting and reporting against the use of appropriated funds; and

3.     measure and assess entity and program non-financial performance in contributing to Government objectives.

An outcome statement should provide an immediate impression of what success looks like.[26]

Outcome statements, therefore, tend to be aspirational in nature.

Appropriations for corporate Commonwealth entities

As corporate Commonwealth entities are legally distinct from the Commonwealth itself, money cannot be appropriated directly to those entities.[27] Instead, amounts are appropriated to relevant departments for on-payment to corporate Commonwealth entities within departments’ portfolios.

Non-operating appropriations

Non-operating appropriations are amounts designated for the capital needs of entities. Typically, these amounts are equity injections into entities, or monies for the purchase or development of the assets of entities. Under the Compact, they can only ever be proposed in a Bill dealing with the ‘other’ annual services of Government.

Appropriations for payments to the states

Under section 96 of the Constitution, the Commonwealth may make payments to the states with or without conditions, and amounts intended for payments to the states are identified separately. Again, because of the Compact, amounts to the states can only ever be proposed in a Bill dealing with the ‘other’ annual services of Government. Amounts to the Australian Capital Territory and the Northern Territory are also included with the amounts for the states.

Appropriations for the Parliament and the Judiciary

In 1981, the Senate Select Committee on Parliament’s Appropriations and Staffing considered the appropriations for the Parliament. That Committee noted the unique constitutional position of the Parliament vis-à-vis the Executive. That Committee noted section 53 of the Constitution’s reference to the ‘ordinary annual services of the Government’ before observing:

... the Parliament may be ordinary; it may be annual; it may even be regarded as a service; but it is not a service of the Government. It is therefore inconsistent with the concept of the separation of powers and the supremacy of Parliament to treat the provisions made for the Parliament as being an ordinary annual service of the Government.[28]

That Committee recommended:

... all items of expenditure administered by the Executive departments on behalf of the Parliament be brought together in [a] Parliamentary Appropriation Bill ...

Since 1982, the appropriations for the Parliamentary departments have been provided for via a distinct Appropriation Bill.

Quarantining appropriations in this way only applies to the Parliamentary departments (of which there are currently four).[29] It does not extend to other aspects of the finances of the Parliament, such as providing for the remuneration and allowances of parliamentarians.

Despite the fact that, under the Constitution, the Judiciary is also distinct from the Executive, there is no equivalent practice whereby the Judiciary is provided for via a distinct Appropriation Bill.

Advances to the Finance Minister and the Presiding Officers

The advance to the Finance Minister and the advance to the responsible Presiding Officers is an appropriation of moneys without any particular outcome or purpose specified. The advances are established in the first Appropriation Acts each year. The advances are then replenished whenever supplementary Appropriation Acts are passed.

The Finance Minister may use the amount appropriated as an advance to modify the schedule to the Appropriation Act, but only where:

... the Finance Minister is satisfied that there is an urgent need for expenditure, in the current year, that is not provided for, or is insufficiently provided for, [...]:

(a)   because of an erroneous omission or understatement; or

(b)   because the expenditure was unforeseen until after the last day on which it was practicable to provide for it in the Bill for this Act before that Bill was introduced into the House of Representatives.[30]

The Explanatory Memorandum asserts that an advance may also be used to add a new item or outcome to the schedule.[31]

An equivalent legislative scheme is proposed for the Presiding Officers.[32]

The amount of appropriation proposed to be allocated to the advance to the Finance Minister in 2018–2019 is $295 million in relation to the ordinary annual services of the Government; and $380 million in relation to the other annual services of the Government.[33]

For the Presiding Officers of the Parliament, the amounts of appropriation proposed to be allocated to the advance in 2018–2019 are:

  • $300,000 each in relation to the:
    • Department of the Senate[34]
    • Department of the House of Representatives[35] and
    • Parliamentary Budget Office[36] and
  • $1,000,000 in relation to the Department of Parliamentary Services.[37]

In order to access an advance, the Finance Minister or Presiding Officers, as the case may be, must issue a determination under the relevant Appropriation Act. A determination is a legislative instrument, but disallowance and sunsetting under section 42 and Part 4 of Chapter 3 of the Legislation Act 2003 respectively do not apply.[38]

Debit limits

In addition to appropriating moneys for the other annual services of the Government, Part 4 of the No. 2 Bill also sets a maximum amount—known as a ‘debit limit’—that may be provided to the states and territories under three specific grant programs.

The legal appropriation for the three grant programs is provided by the special appropriation in section 80 of the Public Governance, Performance and Accountability Act 2013, which provides a standing appropriation for debits from special accounts. However, the design of the legislative schemes associated with each of the three grant programs requires that the maximum annual amount that may be debited under each program each year is to be set in an annual appropriation Bill. The three grant programs are as follows:

  • grants from the Education Investment Fund provided for by Part 3.2 of the Nation-building Funds Act 2008, limited in the No. 2 Bill at $2.0 million[39]
  • grants of general purpose financial assistance (other than the revenue from the Goods and Services Tax) provided under section 9 of the Federal Financial Relations Act 2009,  limited at $5.0 billion[40] and
  • grants made as National Partnership Payments via section 16 of the Federal Financial Relations Act, limited at $25.0 billion.[41]

Because the Compact prevents the No. 1 Bill from dealing with grants to the states and territories, the debit limits are set in the No. 2 Bill.

Committee consideration

Senate Standing Committee for the Scrutiny of Bills

The Senate Standing Committee for the Scrutiny of Bills had no comment on the Parliamentary Departments Bill, but raised concerns with the other two Bills.[42]

Appropriation Bill (No. 1) 2018–2019

In relation to the No. 1 Bill, the Committee noted that initial expenditure for some items of expenditure announced in the 2018–19 Budget ‘may have been inappropriately classified as “ordinary annual services” and therefore improperly included in Appropriation Bill (No. 1) 2018–2019’.[43] These measures are:

  • establishment of international services at Avalon Airport ($20 million in 2018-19)[44]
  • small and medium enterprises export hubs program ($20 million over four years)[45]
  • enhancing female financial capability—Australian Securities and Investments Commission grant program ($10 million in 2018-19).[46]

In relation to this matter, the Committee stated:

The committee has previously written to the Minister for Finance in relation to inappropriate classification of items in other appropriation bills on a number of occasions; however, the government has consistently advised that it does not intend to reconsider its approach to the classification of items that constitute the ordinary annual services of the government.

The committee again notes that the government's approach to the classification of items that constitute ordinary annual services of the government is not consistent with the Senate resolution of 22 June 2010.

The committee notes that any inappropriate classification of items in appropriation bills undermines the Senate's constitutional right to amend proposed laws appropriating revenue or moneys for expenditure on all matters not involving the ordinary annual services of the government. Such inappropriate classification of items impacts on the Senate's ability to effectively scrutinise proposed appropriations as the Senate may be unable to distinguish between normal ongoing activities of government and new programs or projects.

The committee draws this matter to the attention of senators as it appears that the initial expenditure in relation to certain items in the latest set of appropriation bills may have been inappropriately classified as ordinary annual services (and therefore improperly included in Appropriation Bill (No. 1) 2018-2019 which should only contain appropriations that are not amendable by the Senate).[47]

Appropriation Bill (No. 2) 2018–2019

In relation to the No. 2 Bill, the Committee noted that the debit limits set in clause 13 for grants from the Education Investment Fund, of general purpose financial assistance and as National Partnership Payments (NPPs) were substantial and, at least in relation to the NPPs, were significantly more than the forecast expenditure.[48] The Committee drew this matter to the attention of senators, stating:

The committee draws its scrutiny concerns to the attention of senators and leaves to the Senate as a whole the appropriateness of setting debit limits for these grant programs well above the expected level of expenditure, noting that this practice appears to undermine the effectiveness of the debit limit regime as a mechanism for ensuring meaningful parliamentary oversight of these grant programs.[49]

Financial implications

The No. 1 Bill proposes to appropriate $95,230,047,000 ($95.2 billion) from the CRF.

The No. 2 Bill proposes to appropriate $13,003,986,000 ($13.0 billion) from the CRF.

The Parliamentary Departments Bill proposes to appropriate $249,859,000 ($249.9 million) from the CRF.

The total amount of money proposed to be appropriated by the three Bills is $108,483,892,000 ($108.5 billion).

Statement of Compatibility with Human Rights

As required under Part 3 of the Human Rights (Parliamentary Scrutiny) Act 2011 (Cth), the Government has assessed the Bill’s compatibility with the human rights and freedoms recognised or declared in the international instruments listed in section 3 of that Act. In relation to the human rights implications of the Bills, the Government states:

... the Bill performs an important constitutional function, by authorising the withdrawal of money from the CRF for the broad purposes identified in the Bill.

However, as the High Court has emphasised, beyond this, Appropriation Acts do not create rights and nor do they, importantly, impose any duties.

Given that the legal effect of Appropriation Bills is limited in this way, the Bill is not seen as engaging, or otherwise affecting, the rights or freedoms relevant to the Human Rights (Parliamentary Scrutiny) Act 2011.

Detailed information on the relevant appropriations, however, is contained in the portfolio statements.[50]

Parliamentary Joint Committee on Human Rights

The Parliamentary Joint Committee on Human Rights has repeatedly stated that it considers that Appropriation Bills may engage human rights; particularly given the capacity for Appropriation Bills to give effect to a reduction in funding for programs that might be aimed at the realisation of human rights.[51]

In its assessment of the Bills, the Committee referred to its comments in relation to prior Appropriation Bills before stating as follows:

The committee notes that, as with previous appropriations bills, the statements of compatibility for the current bills provide no assessment of their compatibility with human rights on the basis that they do not engage or otherwise create or impact on human rights. However, while the committee acknowledges that appropriations bills present particular challenges in terms of human rights assessments, the appropriation of funds may engage and potentially limit or promote a range of human rights that fall under the committee's mandate.

Given the difficulty of conducting measure-level assessments of appropriations bills, the committee recommends that consideration be given to developing alternative templates for assessing their human rights compatibility, drawing upon existing domestic and international precedents. Relevant factors in such an approach could include consideration of:

  • whether the bills are compatible with Australia's obligations of progressive realisation with respect to economic, social and cultural rights;
  • whether any reductions in the allocation of funding are compatible with Australia's obligations not to unjustifiably take retrogressive or backward steps in the realisation of economic, social and cultural rights; and
  • whether the allocations are compatible with the rights of vulnerable groups (such as children; women; Aboriginal and Torres Strait Islander Peoples; persons with disabilities; and ethnic minorities).[52]

The Committee recommended that departmental officials meet with it ‘to develop workable approaches to statements of compatibility for appropriations bills’ and sought the advice of the Minister on the proposed course of action.[53]

Members, Senators and Parliamentary staff can obtain further information from the Parliamentary Library on (02) 6277 2500.


[1].      Appropriation Bill (No. 1) 2018–2019, clause 6.

[2].      Ibid., Schedule 1, ‘Summary of appropriations’.

[3].      Ibid.

[4].      Appropriation Bill (No. 2) 2018–2019, clause 6.

[5].      Ibid., Schedule 2, ‘Summary of appropriations’.

[6].      Ibid.

[7].      Ibid.

[8].      Appropriation (Parliamentary Departments) Bill (No. 1) 2018–2019, clause 6.

[9].      Commonwealth of Australia Constitution Act (The Constitution), section 81.

[10].    Ibid., section 83.

[11].    Ibid., section 53.

[12].    Ibid., section 56.

[13].    BC Wright, ed, House of Representatives practice, sixth edn, Department of the House of Representatives, Canberra, 2012, p. 420.

[14].    The Constitution, section 53.

[15].    Ibid., section 53.

[16].    Ibid., section 53.

[17].    R Laing, ed, Odgers’ Australian Senate practice, 14th edn, The Senate, Canberra, 2016, p. 386.

[18].    Senate Standing Committee on Appropriations and Staffing, 50th report: ordinary annual services of the government, The Senate, Canberra, June 2010, p. 3.

[19].    Laing, ed, Odgers’ Australian Senate practice, op. cit., p. 387.

[20].    Osborne v Commonwealth (1911) 12 CLR 321 at 336, [1911] HCA 19.

[21].    Australian Accounting Standards Board (AASB), Administered items, AASB 1050, December 2013.

[22].    The Department of Finance describes administered appropriation items as ‘normally related to activities governed by eligibility rules and conditions established by the Government or parliament such as grants, subsidies and benefit payments’, Department of Finance, ‘Guide to appropriations’, Department of Finance website, 25 January 2017.

[23].    Combet v Commonwealth (2005) 224 CLR 494, [2005] HCA 61 at para.123.

[24].    See generally, Combet v Commonwealth, op. cit.

[25].    Attorney-General (Vic); Ex rel Dale v Commonwealth (‘Pharmaceutical Benefits case’) (1945) 71 CLR 237, per Latham CJ at 253, [1945] HCA 30.

[26].    Department of Finance, Guide to preparing the 2018–19 portfolio budget statements, Department of Finance, p. 33.

[27].    Public Governance, Performance and Accountability Act 2013 (Cth), section 11, ‘Note’.

[28].    Senate Select Committee, Parliament’s appropriations and staffing: report of the Senate Select Committee, Parliamentary paper 151/1981, The Senate, Canberra, 1981, p. 18.

[29].    Namely: Department of the Senate, Department of the House of Representatives, Department of Parliamentary Services, and the Parliamentary Budget Office.

[30].    Appropriation Bill (No. 1) 2018–2019, clause 10; Appropriation Bill (No. 2) 2018–2019, clause 12.

[31].    Explanatory Memorandum, Appropriation Bill (No. 1) 2017–2018, p. 8; Explanatory Memorandum, Appropriation Bill (No. 2) 2017–2018, p. 10.

[32].    Appropriation (Parliamentary Departments) Bill (No. 1) 2018–2019, clause 11.

[33].    Appropriation Bill (No. 1) 2018–2019, subclause 10(3); Appropriation Bill (No. 2) 2018–2019, subclause 12(3).

[34].    Appropriation (Parliamentary Departments) Bill (No. 1) 2018–2019, subclause 11(3).

[35].    Ibid., subclause 11(4).

[36].    Ibid., subclause 11(6).

[37].    Ibid., subclause 11(5).

[38].    Appropriation Bill (No. 1) 2018–2019, subclause 10(4); Appropriation Bill (No. 2) 2018–2019, subclause 12(4); Appropriation (Parliamentary Departments) Bill (No. 1) 2018–2019, subclause 11(7).

[39].    Appropriation Bill (No. 2) 2018–2019, subclause 13(1).

[40].    Ibid., subclause 13(2).

[41].    Ibid., subclause 13(3).

[42].    Senate Standing Committee for the Scrutiny of Bills, Scrutiny digest, 6, 2018, The Senate, 20 June 2018, pp. 4–12, 54.

[43].    Ibid., p. 6.

[44].    Australian Government, Budget measures: budget paper no. 2: 2018–19, p. 136.

[45].    Ibid., p. 154.

[46].    Ibid., p. 183; Senate Standing Committee for the Scrutiny of Bills, Scrutiny digest, 6, 2018, op. cit., p. 6.

[47].    Senate Standing Committee for the Scrutiny of Bills, Scrutiny digest, 6, 2018, op. cit., pp. 6–7.

[48].    Ibid., p. 12. The Committee noted that the expected expenditure on NPPs in 2018–19 is $13.8 billion (Australian Government, Budget Paper No. 3: Federal Financial Relations 2018–19, p. 2) but that the debit limit prescribed for that program under clause 13 of the No. 2 Bill is $25 billion, which ‘would allow an additional $11.2 billion in national partnership payments to be made without the need to seek further parliamentary approval’.

[49].    Senate Standing Committee for the Scrutiny of Bills, Scrutiny digest, 6, 2018, op. cit., p. 12.

[50].    Explanatory Memorandum, Appropriation Bill (No. 1) 2018–2019, p. 3; Explanatory Memorandum, Appropriation Bill (No. 2) 2018–2019, p. 4; Explanatory Memorandum, Appropriation (Parliamentary Departments) Bill (No. 1) 2018–2019, p. 4.

[51].    Parliamentary Joint Committee on Human Rights, Human rights scrutiny report, 5, 19 June 2018, pp. 49–50.

[52].    Ibid., pp. 51–2.

[53].    Ibid., p. 52.

 


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