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Letter to Danish Minster of Development, re: Danish promotion of incinerator in Mozambique

2 July 1998

July 2, 1998

Development Minister Poul Nielson
Ministry for Foreign Affairs
Asiatisk Plads 2
1448 Copenhagen K
Fax number: +45 3254 0533

Dear Minister Poul Nielson:

We, the undersigned organizations hope that this letter will be received in the spirit of constructive engagement. It is our hope that we can work together in the near future to quickly resolve our serious and urgent concerns regarding the DANIDA Project: Disposal of Obsolete Pesticides in Mozambique. We have read your recent letter to the Danish press entitled "No Hidden Agenda" and realize that there is still a great deal of misunderstanding and an apparent defensive posture with respect to our concerns. It is time for all of us to become better listeners to ensure that this project does not create more problems than it solves. With this letter, it is our intent to provide a new starting point, and to better clarify our increasingly urgent concerns so that we can move forward together to resolve them.

We are in full agreement with DANIDAís prime objective of collection, safe containment, safe destruction of obsolete pesticides currently stockpiled in Mozambique. We agree that these pesticide stockpiles pose a very serious threat to human health and the environment. However, our review of the documents that have been made available to us to date, along with the explanations provided from DANIDA staff around the world, with respect to concerns first raised by the Environmental Justice Networking Forum (EJNF), have left us with an increasing lack of confidence that the project, in both the collection and disposal phases, will be accomplished in a responsible, and safe manner. Rather, we are concerned that the project as conceived will cause many complex problems in its attempt to solve a relatively simple one. We are also convinced that all of the possible options for achieving the objectives including the preferable ones in terms of both cost, and environmental responsibility to the African environment, have not been appropriately explored or have been unjustifiably dismissed.

For these reasons as further delineated below, and despite the seriousness of the problem, we believe that a complete and immediate halt to the project is necessary in both the collection and disposal phases pending the accomplishment of a true and thorough project evaluation. This evaluation must include an exploration of all of the various options available to fulfill the core objective of protecting the Mozambique environment and populace from obsolete pesticide contamination.


International Trade in Hazardous Wastes

Denmark has been a world leader and champion in the fight against the international trade in hazardous waste. Denmark has worked to secure a waste trade prohibition in the Lomé IV Convention (Article 39), which effectively bans the export of hazardous wastes from European Union (EU) countries to the African, Caribbean and Pacific (ACP) Group (including Mozambique). Denmark has played a champion, leadership role in securing a global Basel Convention ban on the export of hazardous wastes from OECD to non-OECD countries (Decision III/1). With these efforts, Denmark has stood at the forefront of preventing the migration of toxic wastes that might move for economic reasons to avoid costs of eliminating toxic waste generation at source. Thus we would fully expect Denmark would demonstrate more concern about the development of toxic waste technologies in areas of the world which might encourage a re-awakening of international waste trafficking.

In July of 1996 at a regional workshop on the Basel Convention held in South Africa, Mr. Jim Vallette attending from the International Trade and Information Service (ITIS) on behalf of Greenpeace International, learned from then Permanent Secretary for the Ministry for Coordination of Environmental Affairs of Mozambique, Mr. Francisco J. Mabjaia, about a plan to build an incinerator in Mozambique for that country's wastes, as well as for wastes imported from outside of Africa. Although Mozambique government sources now tell Greenpeace that this plan is dead, it nevertheless indicates that government officials in the recent past have planned to import hazardous wastes generated outside of Mozambique and indeed outside of the African continent.

To our knowledge, the only legal instrument which currently serves to prevent the international trade of hazardous wastes to Mozambique is Article 39 of the Lomé IV Convention. However that treaty expires in 1999 and there is no indication whether it will be renewed with a similar prohibition. While the Bamako Convention and the Basel Convention's amendment (Decision III/1) would ban the import of hazardous wastes, Mozambiquehas not ratified those agreements, contrary to what is stated in your recent letters to Danish newspapers and in the Environmental Assessment (EA) (J.No. 104.Mozambique.1.Mika.4 of December 1997), the Project Document (J.No.104.Moz.1.MIKA.4 of November 1997), and in correspondence with DANIDA.

According to the Basel Action Network (BAN) which maintains ongoing and recent correspondence with the treaty secretariats, Mozambique has not ratified these two vital global agreements which would make import of hazardous wastes from outside of Africa illegal. According to Mr. Kioku, legal counsel of the Organization of African Unity in Addis Ababa, Mozambique is neither a signatory or a ratifier of the Bamako Convention. According to Mr. Pierre Portas of the Basel Convention Secretariat in Geneva, Mozambique has not ratified Decisions III/1 -- the Basel Ban Amendment. The source and reason for the misinformation to the contrary appearing so often in documentation for the project is cause for alarm. If it has been provided to the authors in bad faith this is a serious matter. If it is merely a mistake, it raises different concerns regarding the possibly hasty and/or incompetent manner in which the entire EA has been produced.

The matter regarding the transboundary movement of hazardous wastes is quite serious in our view as a permanently established facility to burn hazardous wastes might serve as a rationale to recommence a targeting of the African continent by international waste traffickers. Africa has long been a favorite intended destination for international waste traders wishing to avoid the high costs of waste disposal in rich industrialized countries. It is well known that tremendous profits are involved in such trade and that its establishment continues to be a pre-occupation of organized criminals.

Well intended assurances, which apparently have been agreed in this regard, even when placed in contractual language, ie. that a cement kiln financed, modified and operated with Danish funds, must not be used for burning foreign hazardous wastes, is unlikely to have legal standing once Denmark releases contractual control over the retrofitting project. And even if it did, there is no guarantee that once such a facility is in place physically, that agreements about its use could never be renegotiated in future.

It is our belief therefore, that the EA has not adequately assessed the political and environmental implications of potential waste trade that might be encouraged by virtue of establishing a permanent hazardous waste treatment facility in Mozambique, particularly in view of alternative means to meet the prime objective of the project -- to safely manage obsolete pesticide waste.

Denmark's Commitment to Eliminate and Reduce the Generation of Persistent Organic Pollutants

On 24 June 1998, Denmark hosted the signing in Aarhus of an UN/ECE agreement to ban and phase-out and reduce persistent organic pollutants (POPs) worldwide. Likewise, Denmark is expected to take a leadership role in this regard at the POPs Intergovernmental Negotiating Committee (INC1) now taking place in Montreal, Canada. Cement Kilns are known emitters of dioxin and furan emissions -- two of the POPs listed in the priority list for phase-out or reduction. While many of the pesticides to be burned in the project are also POPs, that cannot justify establishing a new source of POPs with a technology that transforms these POPs into other extremely toxic POPs and moreover is designed to do this for many years to come. In short, a policy to eliminate or reduce POPs is incompatible with a policy to manage hazardous waste via incineration which inevitably produces two of the most deadly POPs known.

Inadequate Analysis of Alternatives

The EA in our view does an extremely poor job at evaluating alternatives to various options available for both the cleanup and disposal stages of the project. Of particular concern is the peculiar and misinformed dismissal of the option to export hazardous wastes to another country with far greater capacity, infra-structure and options for appropriate forms of treatment and/or storage. Another concern is the complete omission of those destruction technologies that do not produce dioxins and furans -- the by-products of combustion technologies.

First, the export option seems to have been dismissed on the basis of erroneous information. Previously mentioned was the misinformation regarding the Bamako Convention. However, the EA also mistakenly claims that both of these conventions require member nations to exclusively be self-sufficient in waste management. While the Basel Convention requires Parties to locate disposal facilities for the environmentally sound management of hazardous wastes, Ato the extent possible within each member state, this is hardly seen as a strict obligation by all Parties to refrain from export for any reason, or to commence modifying cement kilns to burn hazardous wastes in each Party's territory. The Bamako and Basel Bans only apply to hazardous wastes entering the African Continent, not exiting. These bans are designed to halt traffic in wastes that are traded for economic reasons, not for environmental ones.

The Unjustified Objective -- Long-term Burning of Hazardous Wastes in Mozambique

Also in its hasty dismissal of the export option, the EA states that the export solution is not sustainable as Mozambique will not have the means to take care of its own hazardous waste. While the idea that the DANIDA project is designed to solve Mozambique's ongoing hazardous waste problems is listed as an immediate objective of the Project in the November 1997 Project Document, we have nowhere been able to find any real justification for this objective nor for this leap toward one particular, dangerous, end-of-pipe disposal option. The only justification we have located for this leap to judgement that Mozambiqueneeds a cement kiln modified to burn hazardous waste is contained in the following statement found in the November 1997 Project document:

ADANIDA recognises that the industrialization process results in a build up of hazardous waste, and is willing to support the establishment of a framework for fighting pollution resulting from hazardous waste...

The report also describes that the Ministry of Environment (MICOA) will launch a national hazardous waste management programme which includes among other things:

AA collaboration between countries in the region with regard to hazardous waste management policies in order to ensure that relevant waste streams emerge, e.g. from industry.

We find the above statements to be very alarming. First, one unsubstantiated sentence is utilized to makes a daring and dangerous assumption that hazardous waste is a) an inevitable consequence of development and b) needs to be controlled by burning in a cement kiln. Second, it appears that intra-regional waste trade may indeed be envisaged by DANIDA and/or MICOA.

The first assumption we find to be remarkable especially coming from Denmark, a country which as we have mentioned has championed some of the most progressive waste strategies in the world. This objective is in contradiction to well established waste management principles which view clean production and waste minimization at the apex of the waste management hierarchy. If management of hazardous waste in Mozambique really is to be an objective of the project then the current EA is completely inadequate as there has been no assessment of the quantity, forms and species of hazardous waste generated in Mozambique and whether or not these wastes could be prevented or otherwise managed in a non-end-of-pipe manner, ie. by means of clean production methodologies which Denmark has long espoused. And, there is no assessment or justification provided as to why, if intractable wastes must be produced, an assumption which we would strongly challenge, burning in a cement kiln has been chosen as the preferred option. Clearly, we agree that it is advisable that MICOA produce a waste management programme starting with a complete hazardous waste audit. But making assumptions about the outcome of that audit and a much needed assessment of options following it, is a wrong-headed placing of the cart well before the horse.

With this kind of thinking, DANIDA could clearly justify a strategy of marketing waste combustion technology in every developing country on earth. Such a policy not only violates clean production principles but also advocates for a vast proliferation of POPs production globally. Certainly, until a proper waste audit of Mozambique is conducted and a full assessment of the various options for managing hazardous waste is conducted, this objective of so-called Acapacity building must be removed from the project at hand -- which rightly should be concerned strictly with the immediate priority of rendering very dangerous pesticides harmless.

We cannot help but remind DANIDA that it is precisely these types of short-sighted assumptions about solutions to large problems which led to the promotion and delivery of dangerous pesticides to Mozambique in the first place. In this regard, we would be interested to know if DANIDA played a past role in contracting for use of some of these pesticides in Mozambique and moreover is willing to address how to prevent such dangerous use and stockpiling of pesticides in the future. For clearly if these pesticides are cleaned-up, yet the policies remain which created the problem, we will see an endless repetition of this toxic treadmill.

Intractable Waste -- Modern Destruction Methods

Also, not covered as an alternative in the EA is the use of hazardous waste destruction technologies besides combustion and landfill and land farming. Greenpeace International has compiled much information on these de-toxification technologies. These viable technologies will become increasingly important globally once the priority list of POPs are phased out globally, and safe methods of destruction of complex chemical species are required. Contrary to what is maintained in the EA, burning in cement kilns is not a safe method of destruction and the fact that this facility is designed to be a permanent installation raises many more questions as to why Mozambique needs to promote unsafe, end-of-pipe, hazardous waste disposal instead of source reduction methods.

No Cost Analysis of Alternatives -- Export Provides Savings

Although we certainly hope it exists somewhere, we have not seen a comparison of the costs of the various options outlined in the EA. This is of particular concern, for as we note below, the project, due to lack of sufficient funds, will not attempt a thorough, proper clean-up. Rather it is designed to leave behind contaminated sites and soils which could likely be cleaned up properly if money was not wasted in establishing a permanent combustion facility in Mozambique.

According to the EA, if the export option is used, Athere will be no need for a waste station and incineration facilities at Cimentos de Moçambique. There will also be no need to train and employ waste station operators, no need to purchase special incinerator equipment, no need to modify the cement kiln, and no need to employ the very expensive turn-key consultant etc. We will not even for the moment consider the long term infra-structural costs to Mozambique of maintaining such a waste combustion facility in optimal working order and providing for contingencies such as accidents.

If we were to subtract the budget items deemed unnecessary with the export option from the 39.428.000 budget provided in Project Action Plan Report No. 1 (13 March 1998), by even a rough and very conservative estimate we find that this export option can save at least 14,6 million Dkr. as demonstrated below:

Estimated Savings:

Waste Station

3.600.000 Dkr.


3.300.000 Dkr.

Equipment (half of total)

1.300.000 Dkr.

Task Force (half of total)

1.101.500 Dkr.

Project Supervision (half of total)

500.000 Dkr.

Turn Key Consultant (2/3 of total)

6.533.000 Dkr.

TOTAL Estimated Savings

16.334.500 Dkr.

Recent experience at repatriating hazardous wastes to Europe from Mauritania by Royal Dutch Shell cost for 200 tonnes was 2.200.000 Dkr. (11.000 Dkr/tonne). This cost included shipping and incineration. While we do not support incineration anywhere on earth, these examples are included here to illustrate the cost differential in the export option leaving the combustion technology as a constant. As 150 tonnes are involved in Mozambique we must therefore add 1.650.000 Dkr. (11.000 x 150) to the figure above to get a revised estimate of the total project under the export option:

TOTAL Projected DANIDA Project Budget:

39.428.000 Dkr.

MINUS Estimated Savings on Project Budget with Export:

16.334.500 Dkr.

PLUS Estimated Cost of Shipping/Disposal Europe:

1.650.000 Dkr.


24.743.500 Dkr.


14.684.500 Dkr.

These very large estimated savings are significant as they could allow more funds to both completely clean-up the contaminated sites as well as employ possibly more expensive alternative, non-combustion means of destruction.

Problems Associated with Burning Pesticides in Cement Kilns

First, it should be noted that burning pesticides containing chlorine, bromine or other halogens in cement kilns is generally contrary to the guidelines issued by the United Nations Food and Agriculture Organization (FAO) for the disposal of obsolete pesticides. FAO cautions that this practice is "often not applicable in a safe and/or cost-effective manner," going on to note as follows:

"Many of the older types of cement kilns are not suitable. Only a few of the cement kilns in developing countries meet the technical requirements that, in principle, would make them suitable for incineration of certain groups of pesticides. Expert advice is needed to assess whether kilns can be used and special equipment is required to inject the pesticides into the kiln. Such equipment is expensive and should only be installed and used under expert supervision."

Dioxins and furans are typically generated by cement kilns, whether they are fired with conventional fuels or with hazardous waste. However, according to the U.S. Environmental Protection Agency (USEPA), cement kilns that burn hazardous waste emit dioxins in stack gases at 80 times the rate of that when conventional fuels are burned. As a result, USEPA identifies waste-burning cement kilns as the fifth largest source of dioxin emissions to the air in that country. Further, USEPA has reported that the levels of dioxins and furans in cement kiln dust (CKD) from kilns burning hazardous waste are some 100 times higher than those in CKD from kilns burning conventional fuels. Dioxins have also been found in the clinker from cement kilns.

USEPA has also found that burning hazardous waste in cement kilns increases the volume of CKD produced by an average of 75 to 104 percent over that of conventionally-fired kilns. Emissions of airborne particulates increased by 66 percent when hazardous wastes were burned in cement and aggregate kilns, and by 203 percent when the hazardous waste also contained chlorine.

The American Lung Association notes that poorly-managed CKD handling, transport and disposal has been shown to cause severe fugitive dust and air pollution problems. Even relatively low concentrations of airborne particulate matter, such as CKD, can cause or aggravate lung diseases such as asthma or emphysema, and is associated with premature death.

Burning chlorine-containing chemicals in cement kilns increases the likelihood of upsets, since the presence of additional chlorine encourages the formation of "rings" in the kilns. When the rings detach or break, the sudden release of solids in the kilns is accompanied by increased emissions of unburned wastes and products of incomplete combustion, or even more severe consequences.

Spills, both on-site and off-site, are also a concern at cement kilns where hazardous materials are burned. A report commissioned by the New York State Legislature assessed the likelihood of repeated spills at cement kilns that burn hazardous waste:

"It is virtually impossible to completely prevent small spills of hazardous waste during unloading and pumping of waste fuels. These spills may be caused by equipment failures, maintenance operations, or operator error."

In summary, burning obsolete pesticides in cement kilns can be expected to have detrimental impacts on the health of workers, the general public and the environment through increased exposure to dioxins and furans released in stack emissions and cement kiln dust, increased exposure to harmful particulates, and increased exposure to the pesticides themselves through fugitive emissions and spills during handling, storage and transfer.

Collection and Remediation Phase

The EA admits that contaminated soil cannot be handled by the retro-fitted cement kiln. Therefore, as they have refused to consider the export option, they claim that Ait is not intended that the Project will clean up all sites to 'zero risk' sites. Consequently there will be sites where no general public access should be allowed even after the stores have been cleaned.

We find this decision absolutely unacceptable and feel compelled to especially alert the Danish public and Parliament to this little known fact. Leaving contaminated areas defeats the purpose of the entire project and creates a double standard between how things might be cleaned up in a country like Denmark and what is proposed in a country like Mozambique. Under such a scenario it will be impossible to ensure that persons will not enter contaminated areas, that fencing will not be removed and that the contamination will not migrate offsite. The object of the entire project should be to eliminate areas sacrificed to toxic contamination, not simply remove the burnable materials, leaving the rest. Likewise, intentions to land farm or create land disposal sites near contaminated locations, defeats the purpose of the exercise.

How will it reflect on Denmark, if after they leave the country, people or wildlife are poisoned because they did not do the job as well as it should be done and would have been done in Denmark. The collection and remediation of contaminated materials must be full and complete -- not a job half- done.

Lack of Public Participation / Independent Review

Although, according to the Project Document of November 1997, a public hearing was held in Matola, there was no summary provided in the document of the outcome of that hearing. We doubt very much whether all of the concerns that we have outlined in this letter were brought to the attention of local residents. For example it is not clear whether citizens had an opportunity to comment on the export option or the fact that the incinerator will be used in the long-term for burning hazardous wastes in their neighborhood. We believe it is essential to hold another public hearing where international and regional Non-Governmental Organizations (NGOs) can provide testimony and make presentations as well as those made by officials.

It is in our view a failing of the project that, regional and international NGOs with tremendous expertise with respect to such problems have not been involved in the scoping process and project design. We the undersigned organizations have had to beg for documents and have yet to receive full disclosure of all of them. An indication of the unwarranted secrecy is found on the cover of the EA and Project Document which claims that it is a restricted report and is for official use only.

One of the reasons we believe that the EA has proven to be inadequate especially in justifying its chosen course in ignorance of other viable options, is due to the fact that it has been written by the same person involved in promoting the cement kiln retro-fit idea. Additionally, it is our understanding that the source of information provided with respect to environmental impacts of burning pesticides in a cement kiln is the supplier of the retrofitting technology! Such a lack of objectivity is more in keeping with a marketing strategy than public policy. In view of these concerns, we believe it is now imperative to involve some independent expert reviewers in addition to the stakeholders mentioned above. It is certainly not too late to ensure that impacted populations and expert non-governmental organizations and other professional reviewers are allowed to undertake a review of the entire project.

Waste-Tech's Record

Some of the important information which would have come to light had non-governmental organizations been more appropriately involved, is the dubious track record of one of the chosen contractors --Waste-Tech Ltd. First, Waste-Tech's parent company, Enviroserve, recently stated to a public commission which viewed environmental atrocities committed against marginalized people in South Africa, that Waste-Tech is actively seeking opportunities of importing foreign waste to Africa, for incineration purposes. This fact has been born out in a news story that appeared in the Namibian on 26 June 1998 verifying that Enviroserve has proposed to the Namibian city of Walvis Bay that they accept garbage from New York City for incineration. As we write this letter this proposal is still being considered. Such importation would be in violation of the Basel, Bamako and Lomé IV Conventions as well as numerous Organization of African Unity Resolutions.

Subsequent to the meeting described above, the Human Rights Commission of South Africa, has launched a formal investigation into alleged human rights abuses by Waste-Tech against a community that has suffered for the last twenty years due to the establishment of a hazardous waste site a few hundred meters from the community, as well as a recently established medical waste incinerator across the fence line of the community. Both the incinerator and the hazardous waste site are operating in contravention of the law and guidelines of the South African government.

We believe that it is inappropriate and unacceptable to hire companies actively involved in planning waste trade schemes in Africa. Further, it is also inappropriate and unacceptable in our view to hire companies possessing a track record of human rights or environmental violations, or to engage companies which are currently under investigation for such violations as is the case with Waste-Tech.

Given the fact that Waste-Tech is involved in the first phase of the program, our request for a halt to the project pending a greater investigation, ie. into the track record and allegations against Waste-Tech, takes on greater urgency.


It is hard to reconcile Denmark's domestic and international environmental policies with the manner in which the DANIDA Mozambique project has been planned. Further, the Environmental Assessment and Project Document makes it apparent that real political, social, and environmental dangers, both local and global, of the partial collection of pesticides and the establishment of a hazardous waste combustion facility in Mozambique have not been adequately addressed. It appears that the public and NGO sectors have hardly been involved in the planning stages, while those that have, may be acting with a conflict of interest. For whatever the motivation, DANIDA has dismissed alternatives without justifiable cause which we believe will be far less dangerous and expensive.

In view of these serious shortcomings in the planning and implementation process of this project, we seek a halt to all phases of the Mozambique DANIDA obsolete pesticides project pending:

  • a redesign of the project to ensure that all sites are left uncontaminated, at least as defined and required in Danish law.
  • a thorough review of all of the disposal options including a reassessment of precisely why the option of export, which has been successfully used in the past in Africa for obsolete pesticides, has been dismissed. This review must consider the environmental concerns raised above, as well as the cost-effectiveness of each option.
  • preparation of, or participation in a program to review the entire Southern African regional hazardous waste situation and an exploration of the implications of the transboundary movement of hazardous wastes and the opportunities for clean production. The review must include participation from local, regional, and international NGO experts.
  • a rewriting of the EA to correct numerous inaccuracies about environmental impacts of the entire project, including open burning of contaminated materials and the emission of dioxins/furans from cement kilns burning hazardous wastes. Special consideration should be given to the difficulty in maintaining the optimal combustion conditions to achieve the optimal emission levels. Furthermore, alternative, non-combustion destruction technologies must be assessed and compared with burning in cement kilns.
  • an examination of the need and short and long-term impacts of a permanent hazardous waste combustion facility in Mozambique including an assessment of the possible disincentive it might create for cleaner production methodologies.
  • an examination of the appropriateness of employing Waste-Tech Ltd. given the ongoing investigation into their possible human rights abuses as well as their wish to import wastes into the African continent in violation of the Bamako, numerous Organization of African Unity (OAU) resolutions and possibly other waste trade treaties.

In closing, we hope that you will agree that our concerns are serious enough to warrant the above actionsbefore proceeding any further in project implementation. Ignoring the issues raised above, will be dangerous with respect to human health and the environment, will set dangerous precedents in Africa with respect to hazardous waste management, and endanger the good name of the country of Denmark. In addition they will likely waste Danish taxpayer money. On the other hand, if the above concerns are appropriately addressed, the project will have every chance of success and will provide an excellent example of international environmental and development aid. To the fruitful end of this project, we stand ready to assist DANIDA and meet with you to discuss these important matters at any time. In the spirit of cooperation, let us work together to ensure that both short and long-term risks are truly minimized while we rid Mozambique from this deadly pesticide legacy. We look forward to such cooperation and your response.

Sincerely yours,
Jim Puckett

on behalf of the following organization representatives:

Jim Puckett
Basel Action Network (BAN) Secretariat
c/o Asia Pacific Environmental Exchange
1827 39th Ave. E.
Seattle, Washington 98112 USA
Phone/fax: +1 2067206426

Chris Albertyn
Environmental Justice Networking Forum (EJNF), Pietermaritzburg, South Africa
Phone: +27 331949073
Fax: +27 331455841

Marcelo Furtado
Greenpeace International, Sao Paolo, Brazil
Phone: +55 1130612934
Fax: +55 112825500

Jacob Hartmann
Greenpeace Denmark, Copenhagen, Denmark
Phone: +45 33935344, +45 33938660
Fax: +45 33935399

Steen Gade, Chairman
The Parliaments Committee on Environment and Planning
1240 Copenhagen K

Mr. Svend Auken
Minister of Environment
Hoejbro Plads 4
1200 Copenhagen K
fax: +45 3332 2227 

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