SUPPORTING STATEMENT
SOCIOECONOMICS OF COMMERCIAL WHALE WATCHING OPERATIONS IN THE CHANNEL ISLANDS NATIONAL MARINE SANCTUARY
OMB CONTROL No. 0648-XXXX
A. JUSTFICATION
1. Explain the circumstances that make the collection of information necessary.
This request is for a new information collection to benefit natural resource managers in the Channel Island National Marine Sanctuary (CINMS). The National Ocean Service (NOS) proposes to collect information from whale and marine wildlife watching operations to ascertain the market value of whales via the marine wildlife watching industry in the Channel Islands region.
Up-to-date socioeconomic data is needed to support the conservation and management goals of the CINMS to strengthen and improve conservation of marine mammals within the jurisdiction of the sanctuary and to satisfy legal mandates under the National Marine Sanctuaries Act (16 U.S.C. 1431 et seq), Endangered Species Act (16 U.S.C. 1531 et seq), Marine Mammal Protection Act (16 U.S.C. 1361 et seq), National Environmental Policy Act (42 U.S.C. 4321), Executive Order 12866 (EO 12866), and other pertinent statutes.
CINMS and the CINMS Marine Shipping Working Group (MSWG) are currently in the process of developing new options to reduce the number of whale strikes occurring as a result of collisions of the marine mammals with marine shipping traffic in the Santa Barbara Channel region. Collaborating with affected parties, the CINMS MSWG will explore options for reducing negative encounters between whale and vessels, while minimizing the economic impact on shipping and other industry. Options may include rerouting vessels from current traffic patterns or seeking to reduce the speed of vessels in areas where whales are present or known to occur. Such options may be explored for implementation on a voluntary basis or for future regulatory action by CINMS. The CINMS optioning process will identify alternatives that offer the most logical approach for protecting whales, while fostering robust, sustainable maritime commerce in the region.
While data are readily available to assess the impact of potential alternatives on the marine shipping industry, current information is not available to assess the possible economic benefits of whale protection to the local economy, or the potential impact on whale watching businesses. The type of data targeted for this collection; that is, information on costs and earnings from the whale/marine wildlife watching industry, were last published for the CINMS in 2003.1 Thus, current economic information on the importance of whales to the local tourism industry is required. The present collection will gather data on the non-consumptive, market value of whales. Specifically, researchers will collect data to determine the contribution of whale and marine wildlife watching operations to the economy in the Channel Islands region.
Collection of this data will provide estimates of the potential economic benefits of reduced lethal whale strikes that would potentially accrue from alternative shipping scenarios that may be implemented as a result of the optioning process. Additionally, should the CINMS choose to move forward with a regulatory approach to reduce fatal encounters between whales and maritime vessels, the information and tools developed from this data collection would be required before conducting a socioeconomic impact analyses under the National Environmental Policy Act (NEPA), Executive Order 12866 (Regulatory Impact Review) and an Initial and Final Regulatory Flexibility Analyses (impacts on small businesses).
2. Explain how, by whom, how frequently, and for what purpose the information will be used. If the information collected will be disseminated to the public or used to support information that will be disseminated to the public, then explain how the collection complies with all applicable Information Quality Guidelines.
General Overview
The purpose of this information collection is to obtain the information necessary to calculate estimates and build tools that can be used by natural resource managers at the CINMS to evaluate the value of conserving whales within the sanctuary, as well as estimating potential impacts of alternative management options on the local tourism industry. Socioeconomic data will be gathered from commercial whale and marine wildlife observation operations and will be used to develop social and demographic profiles of business owners/operators. Cost and earnings data will be gathered to develop estimates of the value of these businesses to the local economy. Spatial data documenting, where commercial, non-consumptive marine wildlife viewing activities occur in the region, will be used to assess the cost or benefit of alternative management scenarios to the whale and marine wildlife watching industry.
The unit of measurement is the operation. The interviewer doesn’t select the appropriate person to interview. Instead, the business owner selects the appropriate person (i.e. most knowledgeable) for each type of information. This is a records based data collection where we send out a team to the business establishment and from their records obtain the majority of information. The only information that is tied to a particular person in the operation is the demographics. Demographic information applies to the business owner. This is done so we can meet the requirements of the Regulatory Flexibility Act (impacts on small entities—primarily small businesses) in analyzing the socioeconomic impacts of regulations.
Who will use this information?
Data gathered during this collection will be used by CINMS and, more generally, the Office of the National Marine Sanctuaries. The surveys will be conducted by consultants, who are also graduate students at the Bren School of Environmental Science and Management at the University of California at Santa Barbara under the direction of faculty advisor, Dean Steven Gaines. The data will also be used by these graduate students to write a group Master’s thesis document to meet university requirements for the completion of a Master of Science degree.
How frequently will this information be used?
This one-time collection will last one to two months. It is anticipated that the data gathered from this collection will be used on an as-needed basis. Some of the elements of this submission may be replicated to support socioeconomic monitoring in future years.
For what purpose will the information be used?
Data gathered during this collection will be used by CINMS and, more generally, the Office of the National Marine Sanctuaries, to support the optioning process to reduce lethal encounters between whales and marine vessels in jurisdictional waters of the Channel Islands National Marine Sanctuary. Completing this information collection will give CINMS stakeholders fair representation in the design of management strategies by providing information to support the assessment of socioeconomic impacts of management alternatives. The data may potentially be used for conduct of socioeconomic impact analyses under the National Environmental Policy Act (NEPA), Executive Order 12866 (Regulatory Impact Review) and an Initial and Final Regulatory Flexibility Analyses (impacts on small businesses). Finally, the information collected also has potential to be used by resource managers for outreach and education purposes.
Summary of Survey Questions and Mapping Activity
The questions that will be included in this collection are similar to those submitted under OMB Approval Number 0648-0408, Expiration Date: 6/30/2003 for the Channel Islands National Marine Sanctuary. The questions have been slightly modified to meet the data requirement for the present management purpose. The survey items can be categories into two primary components, general information and economic information. Below is a discussion of type of information that is being collected and its importance for the study.
General Information
Respondent ID Number
A respondent identification number will be assigned to each operator for data collection purposes.
1. Which of the following includes your age?
2. Are you Hispanic or Latino?
3. What is your race? (Mark one or more)
These three demographic questions will be used to develop profiles of the whale watching operators in the Channel Islands region. The race and ethnicity questions are written per guidelines issued by OMB. The demographics are specifically for the owner of the business to support socioeconomic impacts of regulations on small entities (primarily small businesses) under the Regulatory Flexibility Act.
4. How many family members do you support (including yourself)?
In combination with economic information gathered, this question will provide information on the degree to which operators (business owners) are dependent upon whale watching as their primary source of income for supporting their household and their vulnerability if this income were to decline.
5. What is your primary port/marina?
6. Do you have a secondary port/marina from where you operate part of the year?
6a. If YES, which one? __________________________________________________
Questions 5 and 6 ask about the primary and secondary ports and/or marinas that the whale watching operation utilizes. This information is important for assessing region of operation as well as travel distance and resulting expenses.
7. How many years have you been a whale watching vessel operator?
This information will help determine how established and dependent the operation is in the local whale watching industry and may explain difference in attitude and perceptions of management strategies and regulations.
8. How many years have you been a whale watching vessel operator in the Santa Barbara Channel?
Question 8 is similar to the prior question in terms of purpose, but collects information regarding the Santa Barbara region, specifically.
9. Do you visit marine reserves/conservation areas specifically during your tours?
(Interviewer—Please show map to identify specific quadrants)
9a. Why?
9b. How often?
9c. If YES, how many years have you taken whale watchers to the Channel Islands
National Marine Sanctuary?
This information is important for understanding visitation rates to, as well as, the importance of, the marine sanctuary to business operation. Also asked is why and how often they visit the sanctuary. This qualitative information is important to ascertain their reasons for visiting the reserves, which will be of use to sanctuary managers.
10. Do you currently have a naturalist on board during whale watching trips?
10a. If NO, would you be interested in having one on board if you had more information about the role they play with whale watching operators?
In the Channel Islands region, naturalists will often come aboard for whale watching trips to talk with customers and collect data on the location and species of whales seen per trip. This program is coordinated by the CINMS. Question 10 asks if operators participate in this naturalist program, meaning that they allow naturalists on board during whale watching trips. This question will help researchers and Sanctuary workers better understand the participation rate of operators in the naturalist program, as well as interest among operators for program expansion.
11. Do you use Spotter Pro to record your whale watching expeditions and whale sightings?
Question 12 collects information on whether someone on the whale watching vessel (either the operators or naturalists) use Spotter Pro, which is a tracking and reporting tool for whale watching operators. Spotter Pro tracks information on vessel routes as well as sightings. This information will help local resource managers understand how robust the dataset is that is generated by this mobile application.
12. Are customers targeting particular whale species when they go on a whale watching trip?
12a. If YES, please list:
This information will allow researchers to roughly ascertain the species of viewing preference among whale watching customers in the region.
13. Are you aware that whales in the region are at risk of being struck by vessels and that encounters with vessels 65 feet or greater in length can lead to the serious injury or death of the animal?
13a. If YES, how concerned are you that whale strikes are currently having a negative impact on your business, with 1 being not concerned and 5 being extremely concerned?
This question series queries the operation on the issue of whale-strikes in the region. Gauging awareness of the issue would help local resource managers plan future education and outreach efforts among whale watching businesses. Question 13a gathers information on the level of concern among whale watching operations about the impact of whale mortality from vessels on their businesses. This question will help managers to understand how interested stakeholders from this group are about whale conservation issues relative to vessel-strikes.
14. In your opinion, on a scale of 1 to 5, how has the quality of whale watching changed in the last 10 years?
14a. If you believe that the quality of whale watching has changed, could you tell me why you think this is true (e.g. change in the abundance of whales, overcrowding from other operators, new regulations, etc.).
This series of questions, Questions 14 and 14a, asks the operations to indicate if the quality of whale watching has changed in the last 10 years. This information is will be helpful in gauging the status of the industry from an “insider’s” point of view. Question 15a elicits detailed feedback on what factors affected a change in quality. Together, this information will allow researchers to understand what factors are believed to be most associated with changes in quality in the industry.
Economic Information
This section addresses costs and earnings of the whale watching operation. This section was designed to conform to other studies being conducted on the economics of recreational for-hire and head-boat operations, but modified to account for the differences for whale watching and marine wildlife observation businesses.
15. What approximate percentage of the TOTAL business income is derived from whale watching operations?
Question 15 will provide information about how much of a respondent’s business income is dependent solely on whale watching services, as opposed to other goods or services offered as a part of their business (e.g., the operation may offer fishing tours as well). This information will allow researchers to assess the degree of dependency of these businesses on whale watching ventures.
16. What approximate percentage of your TOTAL household income is derived from whale watching operations?
Question 16 will be used, in combination with other information gathered, to determine the degree of dependency of the business owners on whale watching tourism for their household support. This question, in combination with Question 4, will help researchers to understand the economic vulnerability of owners’ households should management options or other factors impact the industry. This will help us meet the needs of socioeconomic impact analysis of regulations under the Regulatory Flexibility Act which applies to small entities (primarily small businesses.
17. How would you describe the whale watching operation? (Mark one or more)
18. Number of boats/vessels at the operation:
Questions 17 and 18 ascertain the type and size of the operation. This information will be used to develop a profile of the business, which will inform cost and earnings calculations.
19. Number of whale watching participants per vessel in operation (capacity):
20. Number of participants per vessel in recreational cruise operation (capacity):
21. Number of kayakers per vessel in operation (capacity):
22. Number of divers/snorkelers per vessel in operation (capacity):
23. Number of wildlife observers per vessel in operation (capacity):
Questions 19-23 ask about the capacity of vessels in terms of the number of participants for each of the operator’s different vessels for each activity. This information will help assess supply capacity and will be used in cost/earnings calculations.
24. Number of employees at the operation:
Question 24 will gather data on the number of employees at the operation. Employee numbers and status will help determine the size of the operation and costs.
25. Number of vessel trips per day:
Whale watching ___________
Recreational cruise ___________
Fishing ___________
Kayaking ___________
Diving/snorkeling ___________
Wildlife cruises ___________
Question 25 gathers information on the number of trips per day will help researchers understand the magnitude of participants/customers in the area, as well as the percentage of business that is dedicated to whale watching, as opposed to other services.
26. Please provide your best estimate for annual operating expenses (i.e., docking fees, permits/licenses, maintenance and repair, and office expenses) last year.
Information gathered from Question 26 will be used with revenues to assess the profitability of the operation that can be used to assess the impacts of management options or other factors on individual business and the industry as a whole.
27. Please provide your best estimate for trip related expenses (i.e. food/supplies, bait, captain and crew wages, equipment costs) last year.
Question 27 asks about additional annual expenses from the previous year. This information will help researchers to calculate the operation’s total operating costs.
28. Please provide your best estimate of your total business revenues last year:
Question 28 asks about the operation’s total revenue from last year. Revenue information is essential for understanding profits and the size of the local industry.
29. Please provide your best estimate of your total revenues and/or percent of total revenue last year by each geographic area: (See map for definitions of each area)
Channel Islands National Marine Sanctuary $ ______________ % _____
Outside Channel Islands National Marine Sanctuary $ ______________ % _____
Question 29 focuses on total whale watching and marine wildlife observation operation revenues for the past year and the distribution by major spatial units related to areas being considered for alternative shipping regulations. This will establish dependency on the different areas for whale watching operation revenues.
30. What is the minimum number of whales that need to be seen in order to make the trip worthwhile financially?
31. If you do not see any whales on the trip, do you reimburse customers?
31a. If YES, how do you reimburse customers?
This series of questions gathers information on the threshold of probable success before a vessel operator agrees to go out, as well as the impact of unsuccessful trips, meaning trips made when no whales are spotted. The latter information is useful in determining how much loss is associated if whales are not encountered during a whale watching trip.
32. Use by activity and month
Question 32 collects information on the person-days by activity type for the business over a twelve-month period. A person-day is one person doing an activity for a whole day or any part of the day. This measurement corresponds generally to what the operations record in their log books as the number of passengers taken to a specific location on a specific day. There is some potential for double-counting across activities, so totals across activities is asked and it is not required that the sum by activity equal the total. This type of information has been collected previously by ONMS to ascertain the spatialized recreational value of marine protected areas in the CINMS and the Florida Keys National Marine Sanctuary.2
33. Map Distribution of each activity
Respondents should be advised to provide information on their anticipated spatial use of the region. This anticipated spatial use may be the same as their current use or it may be different. Give respondents 100 penny budget meaning one penny equals one percent of passenger activity. Have respondent allocate their budget across all map cells. Record codes on the coding sheet.
Map cells should be referenced by column and row: For example, C1R1 1% means 1% of activity is in cell Column 1 Row 1. Percent of each activity must add up to 100.
Question 33 is needed to obtain a detailed spatial resolution of “expected person-days”. The purpose of this information is to assess the potential impacts of alternative management scenarios on the whale watching industry. This evaluation is by its nature forward looking, thus past spatial distribution of effort may not be good representation of future impact. Whale watching operations will be asked to provide the percent distribution of where they expect to undertake their future effort (i.e., their anticipated spatial use area) by type of activity at spatial resolutions of 1-minute by 1-minute of one nautical square mile grid cells. It is important to note that a respondent’s future, anticipated spatial use area may be similar or identical to their current or past use area. Detailed maps will be provided with NOAA Nautical chart layers with latitude and longitude lines, as well as key reference points such as benthic structure and depth contours. The person-day totals provided in Question 32 will provide the information to weight percentage distributions across operations when extrapolating to population totals by spatial unit. A copy of the map that will be used for data collection is included with this package. This type of information has been collected previously by ONMS to ascertain the influence of a marine protected area designation on the economic condition of commercial fishermen and recreational boat operators in CINMS and the Florida Keys National Marine Sanctuary.3 Additionally, similar data have been collected for the Flower Garden Banks National Marine Sanctuary in the Gulf of Mexico, although data from this report have not been published to date.
Question 34 clarifies if
the distribution is for current or future movements,
Compliance with Information Quality Guidelines
It is anticipated that the information collected will be disseminated to the public or used to support publicly disseminated information. NOAA National Ocean Service, Office of National Marine Sanctuaries will retain control over the information and safeguard it from improper access, modification, and destruction, consistent with NOAA standards for confidentiality, privacy, and electronic information. See response to Question 10 of this Supporting Statement for more information on confidentiality and privacy. The information collection is designed to yield data that meet all applicable information quality guidelines. Prior to dissemination, the information will be subjected to quality control measures and a pre-dissemination review pursuant to Section 515 of Public Law 106-554. All analyses and reports developed in this project will be peer reviewed before release to the public.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological techniques or other forms of information technology.
No automated, electronic, mechanical, or other technological or other forms of information technology are being used. All surveys with whale and marine wildlife watching operators will be conducted face-to-face and will be recorded on paper forms.
4. Describe efforts to identify duplication.
The research team consulted with resource managers at the CINMS to determine what types of socioeconomic data collection activities were planned or presently ongoing in the region related to whale and marine wildlife watching industries. To avoid survey fatigue and overburdening business owners with data collections, the team consulted with researchers who have projects underway or planned to determine if there was overlap of target populations. We identified no projects that included our target population of whale and marine wildlife watching operators for collections. The literature review did not reveal any more recent efforts completed or underway to collect similar information. Additionally, two representatives of the whale watching industry were consulted to inquire about whether they were currently or recently involved in the same or similar type research. The response from both individuals was negative.
Researchers conducted a literature review to determine if and to what extent existing information might meet the needs of CINMS. While a socioeconomic impact analysis of the proposed marine reserves in the Channel Islands National Marine Sanctuary (CINMS) was completed in 2005, this information is now deemed outdated for policy purposes.4 This project does not duplicate recent or ongoing efforts.
5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.
All the business entities in this information collection request can be classified as small businesses. Our approach is not to send out questionnaires to be filled out by respondents. Rather, to increase efficiency and reduce the respondent’s burden, we send out an information collection team to the home or office of the business owner/operator. The information collection team works with the respondent to complete the information collection. When arranging information collection interviews, our approach is to discuss the types of information we will be asking for during the interview. This enables the respondent to prepare before the interview, gathering any important records or documents that might be needed by the team. For example, for the cost-and-earnings questions, financial records are needed. Similarly, for the spatial use information, access to trip log-books is generally required.
6. Describe the consequences to the Federal program or policy activities if the collection is not conducted or is conducted less frequently.
NOAA and the managers of the CINMS, with the advice and consent from the CINMS Sanctuary Advisory Council, have agreed to collect the information necessary to assess the socioeconomic impacts of the management alternatives forthcoming from the MSWG optioning process. Without this collection, a critical data gap will remain, thereby hampering the optioning process and reducing the ability of resource managers to conduct a thorough social impact assessment in the event of a regulatory action. Additionally, this collection will serve as the foundational research for at least three graduate students at the University of California at Santa Barbara. If this collection does not go forward, this federal government – academic collaborative effort will be compromised to the detriment of participating students.
7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
All data collection will be consistent with OMB guidelines.
8. Provide information on the PRA Federal Register Notice that solicited public comments on the information collection prior to this submission. Summarize the public comments received in response to that notice and describe the actions taken by the agency in response to those comments. Describe the efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.
A Federal Register Notice published on March 5, 2015 (80 FR 11977) solicited public comment on this collection. None was received.
Consultation with persons outside of the agency was undertaken via members of the Sanctuary Advisory Council (SAC). The SAC is composed of stakeholders to the CINMS, including local and state agency representatives, other federal agencies, non-government organizations and private industry. CINMS Sanctuary Advisory Council, which has recently convened a working group to study options for reducing the risk of vessel collisions with whales. The working group is composed, in part, of SAC membership. The working group requested the information that will be gathered through this survey to help them assess management options. This group provided their views on the type of data to be collected, the research questions to be addressed, etc. The research team also consulted with two captains of whale watching operations in the Santa Barbara, California area. These operators provided suggestions on the type of data available, input on how data might be collected and recorded, preferences regarding disclosure, and reporting format. They also provided information needed to profile whale watching operations, generally, to aid in development of the survey instrument.
9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.
No payments or gifts will be provided to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation, or agency policy
Procedures have been established to protect the proprietary information provided by respondents. All personal identification information will be removed from all databases sent to NOAA or distributed to the public. Each individual respondent will be assigned an identification number in the database so the data from different portions of the survey can be linked for analysis. Release of proprietary information is further protected by the Freedom of Information Act (5 USC 522 (b) (4)) concerning trade secrets or proprietary information, such as commercial business and financial records. All non-personal or non-proprietary information will be available for distribution.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.
No such questions will be asked.
12. Provide an estimate in hours of the burden of the collection of information.
The affected public for this collection are the owners or managers of whale/marine wildlife watching businesses in the Channel Islands Region. We estimate that there are 21 or fewer relevant businesses in the region. We expect that it will require an average of 2.5 hours of interview/record compilation time to complete each data collection per respondent. This time can be roughly divided into 1 hour for record compilation by the respondent in preparation for the interview, and then 1.5 hours of working with our interviewers to fill out and check the forms completed during the actual interview. We anticipate completing interviews with the entire population of commercial whale/marine wildlife watching operators in the study area. Based on the SAC working group’s consultation with two whale watching operators in the region (see A8), we anticipate full cooperation with the clear understanding that responses to the survey questions remain anonymous. The members of this business community are interested in understanding their contribution to the local economy and the value of whales to their operation. Thus, we are requesting a total of 52.5 (53) burden hours for this collection.
13. Provide an estimate of the total annual cost burden to the respondents or record- keepers resulting from the collection (excluding the value of the burden hours in Question
12 above).
There will be no cost to respondents beyond burden hours.
14. Provide estimates of annualized cost to the Federal government.
The cost to the Federal government for contract services, supplies, equipment, travel, etcetera, is approximately $28,000 for FY2015. There is no anticipated cost in these budget categories for FY2016. The total annual cost for Federal labor on the project is approximately $42,000 for FY2015 and $42,000 for FY2016. Averaging the totals of $70,000 ($28,000 + $42,000) and $42,000, the annualized total is $56,000.
15. Explain the reasons for any program changes or adjustments.
There are no program changes or adjustments.
16. For collections whose results will be published, outline the plans for tabulation and publication.
All reports will be peer reviewed per NOAA standards under the Information Quality Act and posted on the ONMS Socioeconomic Web site:
http://sanctuaries.noaa.gov/science/socioeconomic.
A new page(s) will be set up on this Web site to provide the project report to the general public. All data and documentation will be put on CD-ROM and will be made available to the general public, subject to any masking of the data required to protect privacy.
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons why display would be inappropriate.
Not applicable.
18. Explain each exception to the certification statement.
1 Leeworthy, V.R. and P.C. Wiley. 2003. Socioeconomic impact analysis of marine reserve alternatives for the Channel Islands National Marine Sanctuary. Silver Spring, MD: U.S. Department of Commerce, National Oceanic and Atmospheric Administration, National Ocean Service, Special Projects, 366pp.
2 Leeworthy, V.R. and P Wiley. 2003. Socioeconomic Impact Analysis of Marine Reserve Alternatives for the Channel Islands National Marine Sanctuary. Silver Spring, MD: U.S. Department of Commerce, NOAA.; Jeffrey, C.F.G., V.R. Leeworthy, M.E. Monaco, G. Piniak, M. Fonseca (eds.). 2012. An Integrated Biogeographic Assessment of Reef Fish Populations and Fisheries in Dry Tortugas: Effects of No-take Reserves. NOAA Technical Memorandum NOS NCCOS 111. Prepared by the NCCOS Center for Coastal Monitoring and Assessment Biogeography Branch. Silver Spring, MD. 147 pp.
3 Leeworthy, V.R. and P Wiley. (2003); Jeffrey, et al. (2012).
4 Leeworthy, V., Wiley, P., Stone, E. (2005). Socioeconomic impact analysis of marine reserve alternatives for the Channel Islands National Marine Sanctuary. Report to the National Oceanic and Atmospheric Administration. Silver Spring, MD.
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Author | Sarah Ball |
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