Chapter XI: The Limits Of Ecosystem Management The Leopold Committee's report to Secretary Udall in 1963 defined the nexus between the Park Service's preservationist mission and ecological research. If the Park Service were to succeed in its attempt to preserve, or more often recreate, representations of primitive nature in national parks and monuments, it had to have a solid understanding of the ecological relationships at work in each area. This required a knowledge of the variety of plant and animal species found there; an understanding of the food chain, or trophic levels, that bound a particular ecological community; an awareness of the physical boundaries of the community, or ecosystem; and most difficult of all, a grasp of ecological change over time. Only then could park managers effectively prevent or compensate for human disturbance of the area's natural ecology. The Leopold Report provided park managers with a fairly coherent goal, but it was clear from the day that Secretary Udall made it Park Service policy that actually achieving effective ecosystem management would be "vastly more difficult." [1] Glacier Bay National Monument provided enormous promise for ecosystem management. Its promise lay in its great size and the fact that the political boundaries of the monument conformed fairly well to natural boundaries, ensuring Park Service control of nearly all the land area involved in the terrestrial ecosystem. As Coffman and Dixon had pointed out in the 1930s, the monument really encompassed two terrestrial ecosystems with the Fairweather Range and Brady Icefield forming an impassable barrier in between. The interior ecosystem around Glacier Bay was defined by mountain ranges on the west, north, and east, and Icy Strait on the south. The Gustavus area formed one gap in the Park Service's jurisdiction over this ecosystem, and the valley to the east of Adams Inlet leading to Endicott Gap, which was the only significant migration corridor into the area, made another. An outer coast ecosystem included the beaches and forested foothills from Cape Spencer to the monument boundary at Sea Otter Creek and was almost as insular an ecosystem as that around Glacier Bay; terrestrial fauna could only enter or leave the area via the continuation of this narrow coastal strip to the north. (A large addition to the monument on the north, which included the Alsek River corridor through the coastal ranges, would bring a third, very different ecosystem into the picture after 1978.) Apart from the agricultural development around Gustavus and a small amount of hunting and trapping, American civilization had scarcely affected the ecology of the monument's terrestrial ecosystems. Their pristine quality offered an unparalleled opportunity to establish a "before" picture, "against which future change, including human disturbance, [could] be measured," wrote biologist Gregory Streveler and naturalist Bruce Paige. [2] Additional advantages were the Park Service's strong mandate to manage the area for scientific research, the studies by Cooper which provided historical information on some forty years of plant succession in Glacier Bay, the subsequent ecological studies by other scientists outside the Park Service, and a pattern of visitor use that entailed minimal impacts on terrestrial resources. But the monument posed equally formidable problems for ecosystem management. Chief among these was the marine environment of Glacier Bay. As Howe's master plan of 1974 stated, "since physical and biotic constituents of the monument's salt waters mingle freely with those of adjacent areas, the boundary appears to be virtually without meaning from the standpoint of marine ecology." [3] Glacier Bay had populations of harbor seal, harbor porpoise, humpback, minke, and killer whale, and various seabirds that migrated in and out of the monument with the changing seasons. There was a much smaller fund of knowledge about marine ecology for Park Service biologists to work with, and the cost of scientific research in the marine environment was higher than in most terrestrial settings. [4] Moreover, there was a strong belief that human consumptive uses of this marine environment--modern Native seal hunting and commercial fishing--had influenced its evolution, but to understand how much would require some very sophisticated scientific investigation.
As Darling and Eichhorn pointed out in Man and Nature in the National Parks (1967), there was a danger that ecosystem management would set the Park Service in opposition to the very processes of ecological succession that it wanted to preserve. Central to the concept of ecosystems was the theory that ecological change was uneven, tending to diminish to a point of near equilibrium when a biological community attained a "climax" condition. If the goal of park management was to recreate such a stable, climax community, then misinformed or overly aggressive management could suppress some of the instability and ecological change that was inherent in any ecosystem. The attempt, through biological management, to make parks and monuments into "vignettes of primitive America," Darling and Eichhorn warned, would badly misfire if "the change and progression which are basic to natural conditions [were] checked and the parks maintained as static museum exhibits." [5] The recently glaciated basin around Glacier Bay held a biological community in the process of becoming. At the time of its earliest sighting by a white man--the benchmark suggested by the Leopold Committee for defining a pristine state of nature--it was covered by ice. During the entire period of European and American expansion in North America, Glacier Bay was undergoing its own invasion of colonizing plant and animal species. There was no meaningful climax community to restore; indeed, scientific interest in the ecological succession taking place in Glacier Bay was one of the reasons for the monument's existence. "Clearly," wrote Streveler and Paige, "the biotic flux that contributes so importantly to the essence of the Monument should not be disturbed." They proposed a variation on the directive contained in the Leopold Report, redefining the goal of biological management in Glacier Bay National Monument to be: "that the natural processes and systems operative during the period of discovery by white man be allowed (and, perhaps, in some cases, helped) to continue as if civilized man did not exist." [6] Protecting from human interference an ecosystem in disequilibrium was at least as delicate as preserving (or, again, recreating) a natural ecosystem in equilibrium. In the latter case, known climax community associations normally provided some ballast for ecosystem management. [7] Wildlife managers could measure their success by the health of plant and animal populations in the biological community. They could usually discover which species were exotics and needed to be suppressed, and which species were missing and needed to be reintroduced. In Glacier Bay, where the process of ecological succession involved constant displacement of certain species by others, biologists had no comparable experience for helping them to determine if an animal population's increase or decline was natural or a result of human interference. Was the influx of coyotes in the 1920s and 1930s related to cattle grazing and homesteading around Gustavus, which tended to drive out wolves and brown bear, or was it because Sitka deer had recently penetrated the area? Was a potential salmon stream devoid of salmon because it had been fished out, or because it had never been colonized? [8] Howe, Streveler, and other personnel recognized that problems such as these would become increasingly numerous and difficult to solve as time went on; therefore, the Park Service needed baseline data with which to operate in the future. [9] The monument's staff conducted wildlife surveys around Point Carolus, Dundas Bay, Lituya Bay, and the outer coast while on extended ranger patrols aboard M/V Nunatak III in 1968-69. It also censused seal herds and gathered data on vegetation in the upper portions of Glacier Bay by aerial infrared photography whenever available funds permitted an overflight. The Park Service accumulated some valuable data simply by having more personnel in the area to report unusual sightings, such as the tracks of a cow moose and two calves in South Sandy Cove in February 1967. "This is the first confirmed report of moose along the east shore of Glacier Bay. It is now reasonable to assume that at least a small population is established in this general area, most probably in the drainages of the Beartrack and Bartlett Rivers," the annual wildlife report stated. [10] Even with more staff, the Park Service could only acquire a sketchy understanding of some facets of this biological community. So little was known about the blue, or glacier, bear, for example, that it could scarcely be considered managed. The glacier bear, which closely resembled the black bear but was smaller, longer necked, with a squatter skull and less differentiated teeth, was thought to occur along the coast from Lituya Bay to Yakutat Bay. Sportsmen had long prized this animal for its rarity and distinctive "blue" coat, but there was no scientific literature on it. The Alaska Department of Fish & Game (ADF&G) abandoned a study of the glacier bear after failing to locate any individuals. It was speculated that the glacier bear was a "relict form, surviving from the latest glaciation of the Pleistocene," whose differences from the common black bear reflected evolutionary changes that had occurred during centuries of isolation on the coast. "After deglaciation," went the hypothesis, "typical black bears moved in once more from areas beyond the ice cover, to compete with the more specialized glacier bear." The author of this memorandum concluded, "If this sequence did indeed occur, it is possible that the glacier bear may be a dying race, slowly destined to disappear from the scene due to competition from the typical black, and perhaps the brown bear." [11] Unfortunately, the Park Service lacked the resources to investigate this animal. Nor could the Park Service afford a census of the Alaska brown bear, despite worries that the population was in decline. In the early 1960s, the Forest Service attempted to census southeast Alaska brown bear populations by aerial beach counts in the spring, but this was found unsatisfactory as bears would run for forest cover at the sound of an approaching airplane. The ADF&G then experimented with aerial counts of bear tracks in the snow on Admiralty Island as the bears came out of hibernation. [12] NPS officials worried that new development around Gustavus and Bartlett Cove placed more pressure on the brown bears' habitat, and that commercial fishing might have decimated certain salmon stocks and reduced the bears' food supply. [13] On the other hand, these threats had to be weighed against a more basic question as to whether reforestation following the recession of glaciers was encroaching on the open, sparsely vegetated habitat that brown bears prefer, to the disadvantage of that species. Here again, the difficulty of preserving nature from human-caused disturbances in an area that was so profoundly characterized by ecological change was manifest. In order to help the brown bear, the Park Service initiated stream surveys in the early 1960s with a view toward inventorying trout and salmon populations and creating more spawning areas. "The maintenance of streams as fish spawning areas is important not only to fish but to animals and birds dependent upon spawning fish for food," Howe's 1967 revision of the master plan stated. "Therefore, temporary log jams blocking these streams should be removed to assure a natural balance of these biotic communities." [14] This paralleled a program of "habitat improvement" by the ADF&G, which included the building of fishways around obstructions, removal of logjams, enhancement of spawning grounds, and stocking of lakes. While the Park Service did allow the ADF&G to promulgate and enforce commercial fishing regulations within the monument, it would not permit state fish wardens to tamper with the salmon streams; this work was conducted by NPS seasonal rangers. [15] Howe decided that the NPS should take advantage of another ADF&G program: the transplanting of sea otter from Amchitka Island in the Aleutians to points eastward on the long coastline around the Gulf of Alaska. The ADF&G wanted to revive Alaska's old fur trade in sea otter pelts; Howe wanted to restore this native species to the ecosystem on the monument's outer coast. Biologists believed there were few, if any, sea otter in southeast Alaska when the ADF&G attempted its first transplant in the region in 1965. Historical accounts indicated that sea otter hunters had virtually wiped out the once abundant populations of sea otter from Yakutat Bay to Sitka by 1900. It was well-known that the local extinction of the sea otter from its native habitat along the outer coast had significantly altered the ecology, starting with the extinction of kelp "forests." Sea otter and kelp forests tend to occur together, partly because sea otter use kelp beds for shelter while foraging and sleeping, partly because they feed heavily upon sea urchins which graze upon kelp. When the sea otter were eliminated from the ecosystem, sea urchins proliferated and devoured the kelp forests, creating a very different environment. [16] Howe knew that if sea otter were reintroduced successfully on the outer coast they would have a significant impact on the existing fauna, particularly sea urchins. They occupied a limited aquatic environment between the beach and thirty fathoms depth, and within this zone they were ravenous eaters. But after discussions with Streveler, biologist Richard G. Prasil in the Alaska Field Office, and a marine mammal biologist with the ADF&G, Howe was confident it was the correct decision. To the regional director in San Francisco he wrote, "if the sea otter in Glacier Bay became so numerous that they were taxing the habitat, the State would be glad to have a good source of transplant material." [17] Successful transplants had thus far eluded the ADF&G. Studies had shown that sea otters had strong affinities for particular areas, and a given population did not easily expand its range even when it had overutilized its food resources. Moreover, those sea otters that were captured, crated, flown to new locations, and placed in holding pens before their release had suffered a high mortality rate from stress. Nevertheless, there was strong economic incentive to make it work. The governor's office announced in 1967 that 1,000 Alaskan sea otter pelts would be sold on the Seattle fur exchange the following January, and were expected to fetch between $1,800 and $2,700 apiece. [18] NPS and ADF&G representatives signed a memorandum of understanding on April 29, 1968, in which the ADF&G agreed to deliver 30 to 50 sea otters to Gustavus Airport, the NPS agreed to build holding pens, and they mutually agreed that if the numbers of sea otter exceeded the carrying capacity of the habitat, the excess would be available as a source of stock for transplants to other locations. On July 30, 1968, fifty-five sea otters arrived in Gustavus aboard an Alaska Airlines C-130 Hercules. After sorting the animals by sex, ADF&G and NPS personnel loaded eight males and seventeen females into three seaplanes and flew them to Dicks Arm, at the southwest corner of the monument. The other thirty were subsequently flown to two locations outside the monument. A seasonal ranger stayed at Dicks Arm after the animals' release and reported that they appeared to be in excellent condition. After vigorously grooming themselves for two hours, the sea otters made their way to some kelp beds around Cape Spencer. The following day the ranger counted only three to five animals around Cape Spencer from his observation point on a nearby promontory, and only one the day after that. Four years later, as no more sightings had been made, the Park Service concluded that these animals had left the monument. [19] The NPS cooperated with the ADF&G on another transplant attempt in 1979. These animals too, were thought to have left the monument, only to reenter it and establish themselves around Cape Spencer three years later. More than fifty individuals were sighted in 1984, and a team of researchers studying the subtidal zone in Torch Bay reported that several hundred sea otters recolonized that site in 1986-87. The presence of the sea otters caused rapid ecological change, with kelp beds dominating Torch Bay by 1988. While it continued to monitor the sea otters' effect on this marine subtidal area, the Park Service counted the reintroduction of this species as a success, for it had once been the "only mammal species of historic record...not found within the park," and its reintroduction made the inventory complete. [20]
In 1971, Congress passed Alaska's most important land legislation since statehood: the Alaska Native Claim Settlement Act. Section 17 (d) (2) of this act directed the secretary of the interior to withdraw up to 80,000,000 acres for study and possible inclusion in the various federal land management systems, including the national park system. The debate over the so-called D-2 lands would culminate nine years later in Alaska's third important land bill, the Alaska National Interest Lands Conservation Act (ANILCA), which created several new national parks and monuments, expanded Glacier Bay's boundaries, and redesignated Glacier Bay as a national park and preserve. Theoretically, the process of determining which Alaska lands would be managed by which agencies was to be governed by ecosystem management planning on an unprecedented scale. But in practice, Alaska lands became political currency to be traded back and forth on a kind of D-2 futures market as congressional committees, developers, conservationists, and the Interior Department honed this large and complicated land bill. [21] The Park Service's Task Force on D-2 lands considered two additions to Glacier Bay National Monument; they got one and lost the other. The smaller of the two areas was the eastern approach to Endicott Gap, a low point on the divide between Glacier Bay and Lynn Canal, which biologists now recognized as an important corridor for wildlife migrating into the basin. The ecological significance of Endicott Gap was first noted in a study by the Institute of Polar Studies in 1966, which suggested that the dramatic recession of the Adams Glacier over the past three decades had exposed the lowlands around the head of Adams Inlet to "invasion from large refugia from Lynn Canal through Endicott Valley." [22] In the early 1970s the Park Service gathered more evidence that it was an important migration route: deer mice were found on both sides of the gap but nowhere else in the Glacier Bay basin, and a pack of thirteen wolves was sighted once at the mouth of the Endicott River on Lynn Canal and again four weeks later in Adams Inlet. [23] It was believed that this corridor had developed in the 1930s, after Dr. Cooper had recommended boundaries for the monument. In a sense, the ecosystem of 1925 had sprung a leak. The NPS Task Force proposed an addition of 102,320 acres to cover the Endicott Valley from the gap to the mouth of the Endicott River, and all the surrounding drainage. This addition, together with cooperative agreements with wildlife managers of the adjoining Tongass National Forest, would promote the natural ecological development of the Glacier Bay basin, protecting it from hunting pressure and logging threats just outside the boundary. [24] The Endicott addition was included in H.R. 39, the House's original version of the Alaska lands bill, but it was cut out of the final bill. Some Park Service officials argued against the Endicott addition on the grounds that it was an unnatural addition on the other side of a divide; their favored alternative came to pass as Congress made the area minus the river mouth a wilderness area within the Tongass National Forest. [25] The second, larger area (more than half a million acres) was the Alsek addition north of Mount Fairweather. It had long been recognized that the existing boundary, which followed a major spur off Mount Fairweather and then Sea Otter Creek down to the ocean, was arbitrary from an ecological standpoint. In fact, it divided into two nearly equal parts the narrow coastal area running from Cross Sound all the way to Yakutat Bay. Backed by the massive ramparts of the Saint Elias Range and its southern extension the Fairweather Range, this was a virtual biological island, connected to the interior by just one major corridor--the Alsek River valley. Moose, bear, wolves, and other fauna were known to have migrated along the Alsek River from the interior to the coast. Birds used the valley as a flyway. One NPS wildlife report indicated that "very recently at least five species (beaver, moose, coyote, lynx, and snowshoe hare) have made their way through the pass and at least two of these are expanding their populations north and south along the coast." [26] In terms of ecosystem management, it made sense to include the entire coastal strip to Yakutat Bay, linking Glacier Bay National Monument with the proposed Wrangell-Saint Elias National Park (as well as Canada's Kluane National Park across the international boundary). At least two economic considerations prevented it, however. Both Yakutat Bay and Dry Bay, at the mouth of the Alsek, were important areas to the commercial fishing industry, and oil companies were exploring for offshore oil near the coastal village of Yakutat. So this area would remain under the Forest Service's multiple use management. The Park Service proposed the Alsek River valley as a suitable northern boundary instead. For most of its length the river cuts a deep canyon through the high coastal mountain ranges and forms a natural boundary; as it reaches the coastal plain, however, the biological rationale for continuing the park boundary along the river's course becomes less compelling. Most of the debate over the Alsek addition therefore focused on approximately 50,000 acres around the mouth of the Alsek River, Dry Bay, and the coastal plain to the south of it. Two principal alternatives emerged: either to include the coastal plain from the Grand Plateau Glacier north to Dry Bay, or to delete this area from the Alsek addition. In 1976, Superintendent Howe and biologist Streveler indicated to the Park Service's planning team that the complications arising from inclusion of this area would marginally outweigh the benefits. The disadvantages were that it would bring Park Service jurisdiction uncomfortably close to the heavily impacted area around Dry Bay, and from a biological standpoint a boundary cutting across the coastal plain at Dry Bay would be no less arbitrary than a boundary along the Grand Plateau Glacier. The advantages were that the coastal plain contained some important wildlife habitat and served as a migration pathway for biota between the Dry Bay area and the coastal strip to the south, and the Deception Hills, which flanked the Grand Plateau Glacier to the north and having escaped the most recent glaciation, contained some of the oldest forest in southeast Alaska. On balance, Howe and Streveler recommended that the park boundary run along the Grand Pacific Glacier from Alsek Lake to the coast, leaving a buffer between the monument and Dry Bay to be cooperatively managed by the NPS and the Forest Service. [27] As the mark-up of the Alaska lands bill got underway, recreational values weighed as heavily as ecological factors in locating the precise boundary. Not only was the corridor biologically significant, but the Alsek and its tributary in Canada, the Tatshenshini, had "exciting potential" for recreational use. In 1977, when the Park Service first formulated its proposals for the Alsek and Endicott additions in detail, river guides were marketing float trips on the Tatshenshini-Alsek for the first time. This would be "a superb wilderness river adventure," the Park Service planning team wrote. [28] The proposed Alsek addition survived in the Interior Department's version of the Alaska lands bill, and President Jimmy Carter added it to the monument by proclamation on December 1, 1978, pending passage of a revised Alaska lands bill by the next Congress. The boundary took in the Alsek River valley from the international line to Alsek Lake, and then followed along the base of the Deception Hills to the coast. This brought the boundary closer to the Dry Bay area than Howe and Streveler had suggested, but still excluded the flats around Dry Bay. [29] ANILCA adjusted this boundary once more. In the two-year interim between Carter's unilateral action on the D-2 lands and Congress's final passage of the Alaska lands bill (ANILCA) in December 1980, Tongass National Forest officials demonstrated little interest in cooperating with the Park Service in managing land use by commercial fishermen in the Dry Bay area. Thus the boundary was extended north from the Deception Hills to Dry Bay, bringing both the Dry Bay fish camps and the take-out point for Alsek River float trips within Park Service jurisdiction. In acknowledgement of the commercial fishery, ANILCA designated this area a national preserve, while it upgraded the rest of Glacier Bay National Monument to national park status. Contrary to the historical pattern of tug-of-war between the Park Service and the Forest Service, this was a parcel of land that Forest Service officials were only too willing to let go.
A superintendent once described Glacier Bay as "a perfect design for a national park area." The large majority of visitors, milling about their ships as they cruised up the bay, enjoyed comfortable, economical, unintrusive access to the monument's main attractions. As these passengers witnessed the remarkable changes along the shoreline from mature forest to sparsely vegetated slopes to tidewater glaciers, they gained an appreciation of "the principal story of the formation of the park." [30] From the standpoint of managing people, passage of visitors in and out of the monument by water was presumed to have numerous advantages over automobile traffic: the waterway required no construction, maintenance, litter control, or service stations; there were fewer accidents or emergencies; visitors mostly came and went by a form of mass transit; and all those who did, experienced the monument from a moving, railed platform that prevented conflicts between people and wildlife. At first, this marine highway seemed to have great advantages from the standpoint of ecosystem management too. Compared to fishing trollers or seal hunters in outboard skiffs, sightseeing vessel traffic seemed to be nonconsumptive and nondisruptive. Despite an enormous increase in the number of humans entering the area, most of the new load came from visitors who were not entering into the food chain; they did not "divert or supply significant amounts of materials and energy to or from the park ecosystem," as one biologist described the relationship of visitors to national park ecosystems generally. [31] What soon became apparent, however, was the fact that animals, particularly hair seals and humpback whales, were affected by the noise from increased boat traffic. Ironically, it was the sightseeing boats, with their erratic speeds, courses, and tendency to pursue these animals, that appeared to cause the most havoc. Once they had identified these problems, Park Service officials applied the analytical tools of ecosystem management to find solutions. The problem was that Glacier Bay was not really an ecosystem. Its populations of hair seal, humpback whales, and even some fishes and other lower animals migrated in and out of the bay with the seasons. When looking at a specific migratory population, such as Glacier Bay's humpback whales, Park Service officials had to resist a tendency to look for stability where there was none. At the same time, they had to be certain that fluctuating numbers did not reflect despoliation of this part of the population's customary range. Trying to protect the health of Glacier Bay, not to mention the monument's other bays, when there was such an "extensive interchange of biotic elements and even [of] the water masses themselves," was a challenge. [32] As early as 1971, before the effects of boat traffic had become pronounced, Streveler and Paige articulated the basic dilemma that the NPS faced in managing the monument's marine resources. Either the Park Service could minimize disturbance of marine resources while the resources were inside NPS jurisdiction, in keeping with standard NPS management objectives; or it could cooperate with other agencies in developing comprehensive treatment of mobile populations, generally along the lines of sustained yield management. [33] This may have been the most realistic statement of the problem that NPS officials made. In 1979, Lynne Zeitlin Hale and R. Gerald Wright completed a report for the Park Service titled "The Glacier Bay Marine Ecosystem." Adapting ecologist Howard T. Odum's pragmatic definition of an ecosystem, Hale and Wright considered Glacier Bay as a system comprising "a set of regularly interacting and interdependent components forming a unified whole." In contrast to earlier statements by Howe and Streveler that the monument boundary was virtually meaningless from the standpoint of marine ecology, Hale and Wright sounded a more positive note:
Hale and Wright described how the massive input of meltwater into Glacier Bay, not unlike other Alaska fjords, created peculiar conditions for sea life. Water temperature, clarity, and salinity were lowest in summer, when the freshwater runoff from the glaciers was at its peak, but nearly matched conditions in Icy Strait in winter, when runoff became negligible. These conditions varied spatially as well as seasonally, and affected the strength of tidal currents in and out of the bay. In the authors' model, tidal currents were one of the principal exchanges across the geographic boundary, bringing plankton and nutrient-rich water into the system, while glacial meltwater and streams brought sediment and organic material into the upper and lower parts of the bay respectively. These variables, added to the longer time span for post-glacial successional development the further one got from the receding glaciers, produced a gradient from a relatively simple to more complex ecosystem as one moved down the bay. [35] The implications of this conceptual model for resource management were significant. Hale and Wright provided a rudimentary framework by which the Park Service could measure human influences upon the marine ecology of Glacier Bay and take remedial action. The ecosystem model implied that the Park Service's mandate to administer Glacier Bay National Monument as a natural area applied equally strongly to the marine environment as it did to the land surface. If the Park Service were willing to accept these implications, it had to confront the problem of commercial fishing in Glacier Bay, which was obviously extracting something from the ecosystem. It also had to explore the possibility that visitor access via the monument's "marine highway" might have to be restricted. Further, it had to increase signficantly its operating budget for marine ecological research. None of these measures was taken. In his master plan of 1974, Howe ignored commercial fishing while holding to his view of unrestricted marine access. The Park Service made a minimal commitment to research in the 1970s, the regional office providing Streveler with an operating budget of approximately $30,000 per year. The inadequacy of the Park Service's research effort in Glacier Bay attracted little notice through most of the 1970s, but it was suddenly laid bare at the end of the decade when public concern and controversy erupted over the monument's population of humpback whales, which it appeared had been driven from the bay by a rising volume of boat traffic. [36]
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