HomeMy WebLinkAbout2018-13RESOLUTION NO. 2018-13
A resolution of the City Council for the City of Columbia Heights, Minnesota,
WHEREAS, a Solid Waste Operations Policy has been developed and recommended by City staff; and
WHEREAS, adoption of said policy has been determined to be in the best interest of the City of
Columbia Heights,
WHEREAS, the Solid Waste Operations Policy establishes goals, policy plans, and City procedures for
garbage, single -sort recycling, recycling center, problem materials, reuse, yard waste and organics
recycling operations in the City of Columbia Heights.
Now, therefore, in accordance with the foregoing, and all ordinances and regulations of the City of
Columbia Heights, the City Council of the City of Columbia Heights makes the following:
FINDINGS OF FACT
1. The City Council hereby approves and adopts a Solid Waste Operations Policy for the City of
Columbia Heights.
ORDER OF COUNCIL
Passed this 12th day of March, 2018
Offered by: Buesgens
Seconded by: Williams
Roll Call: All Ayes
I L�� 2 a L4
Donna K. Schmitt, Mayor
Attest:
Katie Bruno, City Clerk /Council Secretary
City of Columbia Heights
Solid Waste Operating Policies*
* As Authorized by the 2018 Amendments to the
City Solid Waste Management Ordinances
January, 2018
CH
COLUMBIA
-HEIGHTS-
REDISCOVER THE HEIGHTS
City of Columbia Heights
Department of Public Works
63738 th Avenue
Columbia Heights, Mil 55421
Contents
Introduction................................................................................................ ..............................1
Section1 Definitions .............................................................................. ............................... 1
Section 2 General Operations ................................................................ ............................... 3
Section 3 Garbage Operations ............................................................... ............................... 5
Section4 Recycling Operations .............................................................. ............................... 6
Section 5 Problem Materials and Other Waste Operations .................. ............................... 7
Section 6 Collection and Composting of Tree and Shrub Waste, Other Yard Waste........... 8
Section 7 Collection of Source Separated Organics and Yard Waste, Every Other Week
GarbageCollection ................................................................. ............................... 9
Section 8 Resolution of Disputes................... .... ............................................................... 10
Appendix: Refuse Services Matrix
Introduction
The City of Columbia Heights has developed these standards as specific requirements for the storage,
collection and transportation of residential solid waste. The goals of these standards are to:
♦ Establish a system for the orderly and regular collection of garbage, recyclables, problem
materials, organics, and yard wastes in the city;
♦ Ensure that the disposal of the materials shall be accomplished in a sanitary manner;
♦ Ensure the protection of public health and safety and promote city cleanliness and livability;
♦ Minimize vehicle wear and tear on streets due to large truck traffic;
♦ Provide high quality solid waste and recycling services in the most cost - effective manner
possible;
♦ Be consistent with the requirements of the state statutes, state rules and Anoka County
ordinances, and with state and Anoka County solid waste plans; and,
♦ Implement the City's Garbage and Recycling Services Ordinance, Chapter 4 of the City's code
of ordinances through detailed instructions.
To accomplish the above goals, it is important for the city to have specific and consistent instructions
for residents to follow as part of the waste and recyclables collection system. These standards do not
replace or supersede city ordinances. The City Manager's authority for adopting or amending these
standards comes from Chapter 4: Municipal Services, Article VII: Refuse and Recycling Services.
These standards address:
♦ Garbage, problem material, recyclables, yard waste and other waste collection and disposal
requirements;
♦ Recycling programs; and,
♦ Other collection system details that are part of the city's garbage collection system.
Section 1 Definitions
All terms used within these standards shall have the same definition as the Garbage and Recycling
Services Ordinance 1646. For convenience, frequently used terms are listed and defined below:
1.1 Appliances include washers, dryers, refrigerators, freezers, air conditioners, dehumidifiers,
humidifiers, stoves, ranges, hot water heaters, water softeners and other, similar large
household items that require electricity and /or special processing under Minnesota laws, but
do not include "electronic waste."
1.2 Construction debris means building materials, packaging, and rubble resulting from
construction, remodeling, repair, and demolition of buildings.
Page 1
1.3 Electronic waste (electronic items) has the meaning set forth in Minnesota Statutes, section
115A.1310, subdivision 7 as a "covered electronic device" and includes items such as
television and computer monitors, computers, computer peripheral devices, fax machines,
DVD players, video cassette recorders, other video display devices, cell phones and other
small appliances with an electric cord.
1.4 Food waste means residential food waste and includes meal preparation and leftover food
scraps from households intentionally separated at the source by residents for the purpose of
backyard composting or separate collection.
1.5 Garbage /Trash has the meaning set forth in Minnesota Statues, section 115A.03, subdivision
21, mixed municipal solid waste, and means solid waste from residential, commercial,
industrial, and community activities that the generator of the waste aggregates for
collection, but does not include auto hulks, street sweepings, ash, construction debris,
mining waste, sludge, tree and agricultural waste, tires, lead acid batteries, motor and
vehicle fluids and filters, and other materials collected, processed, and disposed of as
separate waste streams.
1.6 Household hazardous waste has the meaning set forth in Minnesota Statutes, section
115A.96, subdivision 1, paragraph (b), and /or Minnesota Pollution Control Agency
regulations and means waste generated from household activities that exhibits the
characteristics of or that is listed as hazardous waste under agency rules, but does not
include waste from commercial activities that is generated, stored, or present in a household
and includes items such as paint, fluorescent light bulbs, mercury thermometers, cleaning
fluids, herbicides, pesticides, fertilizers and other waste as defined in Minnesota statutes or
regulations in that paragraph.
1.7 Premise, Premises shall mean any dwelling unit, building and every other place where any
person resides within the City, including properties with more than one dwelling unit and
properties with premises attached to retail or commercial structures.
1.8 Problem materials means all large, bulky household materials which are too large for one
person to pick up and /or do not fit within the garbage cart, and include (but are not limited
to) carpeting and padding, mattresses, chairs, couches, tables, appliances and household
electronic waste.
1.9 Residential dwelling unit (dwelling unit) is a separate dwelling place with a kitchen.
1.10 Solid waste(s) has the meaning set forth in Minnesota Statutes, section 116.06, subdivision
22(1)(9) but is further defined for purposes of this ordinance to include garbage, recyclables,
appliances, problem materials, organics, yard waste, and household hazardous waste items.
Page 2
Section 2 Goals and Plans
2.1 Background: The Minnesota Pollution Control Agency (MPCA) is mandated by the state
legislature to recycle 75% of solid waste by 2030. The MPCA approved the latest version of
the Metro Solid Waste Policy April 2017. In the document they specify numerous RBMPs
(Recycling Best Management Practices) including organics recycling and bulk recycling.
They are expecting and have been encouraging counties and cities in the metro area to begin
implementing some of these RBMPs. The MPCA manages the SCORE (Select Committee On
Recycling and the Environment) funds and distributes it to the counties.
2.2 Organized Collection: It is the intent of the City Council to continue an organized collection
system for the orderly and regular collection of garbage, recyclables, problem materials,
source separated organic materials, yard waste, and other wastes in the city; to insure that
the disposal of the materials shall be accomplished in a sanitary manner; to ensure the
protection of public health and safety and promote city cleanliness and livability; to minimize
vehicle wear and tear on streets due to large truck traffic; to provide high quality solid waste
and recycling services in the most cost - effective manner possible; and, to be consistent with
the requirements of the state statutes, state rules and Anoka County ordinances, and with
state and Anoka County solid waste plans.
2.3 Goals: The main goal of Columbia Heights Solid Waste Management is to reduce trash
disposal, especially since the City pays separately by the ton for disposal. The more the city
recycles the fewer trash tons and lower costs. By implementing some of the RBMPs the City
expects to increase recycling tonnage 12% over the next two years.
2.4 Solid Waste Management Plan.
2.4.1 Trash: The City will follow county and state waste management plans and policies for disposal
of solid wastes. Therefore, most of the trash collected by the City's organized system will be
incinerated at a Refuse to Fuel facility to generate electricity.
2.4.2 Curbside: The City of Columbia Heights will provide full service recycling programs with various
city run curbside collections including: Unlimited single -sort recycling, Organics comingled with
yard waste recycling, Bulk (furniture, mattresses, carpet) reuse /recycling, Electronics recycling,
Appliance recycling, Christmas tree recycling, Multi- dwellings included, plus City buildings and
events recycling.
2.4.3 Recycling Center: The City, in partnership with a local volunteer service organization, will
operate a weekly drop -off center which is very convenient for Southern Anoka County residents
to keep hazardous materials out of the waste and for recycling of special items that are not
acceptable in the single sort system. The city will also use the center as a "test site" to work
with the MRF (Materials Recovery Facility) to increase the materials allowed in single sort
recycling. A local volunteer service organization will also conduct the MN Composting Council's
"Plate to Garden Compost" fundraiser at the recycling center to promote organics recycling and
to return fresh compost for participating households.
Page 3
2.4.4 Reuse: The City will also coordinate with local reuse vendors such as Southern Anoka
Community Assistance for drop -off of clothing and other household goods. Plus we will
coordinate with the DAV to partner with several multi - dwellings for collection of those items.
The City will also assist local volunteer service organizations with organizing reuse events such
as Fix -it Clinic, and the Citywide Garage Sale weekend. A local volunteer service organization
and BRIDGING may also assist with the bulk collection and reuse /recycling program.
2.4.5 Promotions /Education: The City will conduct extensive promotions including two citywide
flyers and direct outreach to multi and other rental properties (including tenant recycling kits).
Plus we will produce localized publications for spring /fall cleaning and garage sale reuse and
recycling information. The City will promote recycling through its own entire communication
means monthly. The City is offering a 30 gallon every- other -week trash service option in
conjunction with organics recycling, plus there will be an educational requirement as well so
the City may also help coordinate an Anoka County Master Recycler Course. The City may also
require residential rental properties to add tenant recycling expectations to the lease
agreement. The City will recognize those Recycling Champions who's properties increase
recycling and /or utilize the organics recycling service.
Section 3 General Operations
3.1 Services Required: Every Residential Premise shall use the collection service provided by the
City as directed in City Code CHAPTER 4: MUNICIPAL SERVICES. Multi- dwellings are
considered residential properties for the purpose of refuse operations, but other split use
properties with both dwelling units and commercial units can opt out of the City provided
refuse services.
3.2 Policy Changes: The City manager has the authority to change portions of this policy for
those operations that will have a financial effect under their limit of spending and remains
within budget constraints. The Council can review and update at their discretion or for
financial changes above the City Manager limits. The City will solicit bids for contracted
services at the end of each agreement period.
3.3 Schedule Notification: Collection shall occur on days and in areas designated by the City.
Schedule changes may be made for major holidays, or for adverse weather conditions. The
City will post a news flash on the website and social media for unscheduled service delays.
Collection days may only be permanently modified with the prior approval of the City
Manager. The City shall notify each premise of any change in collection day four (4) weeks
before the change and again one (1) week before the change.
3.4 Collection Points: Directed per City Code CHAPTER 8: PUBLIC HEALTH AND SAFETY, except
as otherwise described in this policy. Properties must have their containers set out for
collection prior to 6:00 a.m. on the collection day for service. Property owners shall ensure
obstructions are removed and hazards (such as accumulation of snow and ice) are mitigated
before collection. Where these conditions exist refuse may not be collected until resolved.
Page 4
3.5 Containers: The City shall provide each residential dwelling property with a garbage cart (30,
60, 90 gallon) or dumpster (2, 4, 6, 8 yards) and a clearly distinguished single -sort recycling
container. All containers shall be handled in accordance with City Code CHAPTER 4:
MUNICIPAL SERVICES. Any markings that appear on the outside of the carts or dumpsters
that are not placed there by the hauler or the City shall be promptly removed by the
customer. The City shall own the carts; residents are granted exclusive use of the carts at
their address only. If a resident moves, the carts shall remain at the assigned premise.
3.6 Service Changes: Official changes will be made through the City and the hauler will be
notified. If temporary discontinuation of collection is desired by the premise due to vacancy
of the property, the request shall be made to the City. Approval or denial of the request
shall be at the sole discretion of the City.
3.7 Customer Service: The contract hauler and other refuse vendors will perform customer
service operations as dictated in contracts and agreements as supervised by the City.
Section 4 Garbage Operations
4.1 Organized Collection: The City organizes collection of Solid Waste for all residential
properties as directed by City Code CHAPTER 4: MUNICIPAL SERVICES. The City reserves the
discretion to add other service locations (non - municipal) as agreed to by Council resolution.
4.2 Vendors: Contracted haulers and other refuse vendors will follow the duties and
performance standards for garbage /trash operations as dictated in contracts and
agreements as supervised by the City.
4.3 Trash Requirements. Each residence shall have its garbage and all other permissible
disposable items collected a minimum of once each week, per City Code 8.301 STORAGE
CONTAINERS, except as otherwise noted in this policy. Only household garbage shall be
placed in the garbage containers. Items prohibited from disposal with garbage in the carts
include, but may not be limited to: problem materials, tree and shrub waste, other yard
waste, automotive parts or fluids, electronic waste, or hazardous waste. Garbage must be
handled according to CHAPTER 8: PUBLIC HEALTH AND SAFETY. If the hauler determines a
trash container is too contaminated with non - disposable materials, service will not be
provided, nor will a refund be authorized. Collection of materials can be provided by the
contracted hauler when issues are resolved.
4.4 Service Levels: There are also two classifications of household trash services which are "Full
Service" and "Limited Service ". Households are considered triplex and below dwelling unit
properties. Multi- dwellings are those properties with four or more dwelling units. City
utility charges for trash service will be volume based following MN Statute CHAPTER 115A.
WASTE MANAGEMENT.
Page 5
4.4.1 Full Service: Full service households are those who pay for the 90 gallon trash cart service,
plus senior service properties with any size cart. They are allowed up to 1.5 yards of
additional amounts of solid waste such as stone, sod, earth, concrete, and building materials
resulting from minor remodeling of the residence on the property at which these materials
have been placed. Where practicable, such items will be bagged, boxed, or bundled. Premise'
will call the contracted hauler to schedule pick up before placing the material outside. See
Refuse Service Matrix (attachment A) for other city refuse services provided to full service
households.
4.4.2 Limited Service: Limited Service properties are not allowed extra material outside of the 60 or
30 gallon cart. See Refuse Service Matrix (attachment A) for other city refuse services
provided to limited service households.
4.5 Multiple Dwelling: The contracted hauler shall provide each multiple dwelling (four and more
units) premise with at least one standard dumpster (if not serviced by carts) and provide
collection at a minimum of once /week. Multiple dwelling premises may not have extra
garbage or waste outside of the provided cart or dumpster, except for problem materials.
See Refuse Service Matrix (attachment A) for other city refuse services provided to multi-
dwelling properties.
Section 5 General Recycling Operations
5.1 Vendors: Contracted haulers and other refuse vendors will follow the duties and
performance standards for recycling operations as dictated in contracts and agreements as
supervised by the City.
5.2 Requirement to Recycle: The City is required to provide all residents the ability to recycle a
basic set of materials as set out in MN Statue 115A.552 OPPORTUNITY TO RECYCLE;
therefore the City's basic refuse service package includes single -sort recycling. Single sort
recyclable materials generated from premises will be collected a minimum of once every -
other -week, except for multi - dwellings which will have weekly collection. All properties can
order larger or additional containers, plus households can place additional recyclable
materials outside of the cart when bagged (paper bags only NO plastic bags) or boxed in a
manner that meets the contracted hauler specified procedures. General recycling utility rate
will be flat based on living quarter units and not charged on volume or weight.
5.3 Recycling Standards: Recyclable materials included as part of the city's single -sort recycling
system will be consistent with the designated MRF (i.e. sorting plant) requirements, except
items by agreement with the City and the MRF to study methods for increasing the materials
allowed. Recyclable materials are to be clean, and kept as dry as practicable. If the hauler
determines a recycling cart is too contaminated with non - recyclable materials, service will
not be provided, nor will a refund be authorized. Collection of recycling materials can be
provided by the contracted hauler when issues are resolved.
5.4 Rental Properties: The City will require residential rental properties to add tenant recycling
expectations to the lease agreement. The City will provide rental properties with tenant
recycling kits and advise upon request.
Page 6
5.5 Recognition: The City will recognize those Recycling Champions whose properties increase
recycling and /or utilize the organics recycling service on an annual basis.
5.6 City of Columbia Heights Recycling Center.
5.6.1 Operations: The Recycling Center will operate according to City Code CHAPTER 4: MUNICIPAL
SERVICES. The center will be open on Saturdays except for major holiday weekends.
5.6.2 Materials: The City's recycling drop -off center will be used to provide convenience for disposal
of certain hazardous wastes, but also recyclable items not accepted in the single sort system.
All items collected curbside will also be collected at the Recycling Center with the addition of
scrap metal, used oil, oil filters, fluorescent bulbs, string lights, household batteries, and
rimless tires.
5.6.3 Illegal Activities: Residents must leave only acceptable items or will be considered illegal
dumping subject to penalties described in city ordinances and laws. No one may remove
items dropped off for the Recycling Center as it becomes the property of the City, unless
authorized by City staff. If persons do not leave the Recycling Center, when asked by the
monitor, they will be reported for trespassing on City property.
5.6.4 Volunteers: The City will work with a non - profit service organization to monitor the Recycling
Center and provide assistance to residents at the center. The organization shall be paid
$3,000 /year plus rebates for material value collected at the Recycling Center. The non - profit
organization must provide their own insurance for members performing this activity and
indemnify the City of their operations.
5.6.5 Other Activities: The Recycling Center will also be used by a local service organization to
package and distribute fresh compost to the community, plus to promote organics recycling.
The non - profit organization must provide their own insurance for members performing this
activity and indemnify the City of their operations.
Section 6 Problem Materials (Bulk), Appliances, and Electronic Waste services.
6.1 Vendors: Contracted haulers and other refuse vendors will follow the duties and
performance standards for special material handling as dictated in contracts and agreements
as supervised by the City.
6.2 Bulk (furniture, mattresses, carpet): The City will provide a convenient curbside collection to
properly dispose of problem materials (bulk). See the Refuse Service Matrix for service level
information. The designated vendor must collect the items within three business days.
Problem materials will be collected where determined by the property owner. All items
must have come from the property where collected i.e. no items from other premises.
6.2.1 Recycling: The City will arrange for reuse or recycling of items before disposing with the trash.
Premises must keep problem materials inside, or otherwise protected from rain /snow until
collection. In addition, furniture, mattress, and bed springs that are known to be
contaminated by bedbugs or other vermin must be securely bagged or wrapped to prevent
infestation of other persons or property. If materials are wet or infested items are not sealed,
the property will pay for disposal of the items. Premises must call the designated vendor to
schedule the special service.
Page 7
6.2.2 Service Organization: The City may utilize a volunteer service organization as a subcontractor
to the contracted hauler for collection and recycling of bulk materials. The non - profit
organization must provide their own insurance for members performing this activity and
indemnify the City of their operations.
6.3 Appliances: The City will provide a convenient curbside collection to properly recycle
appliances. See the Refuse Service Matrix for service level information. Premises must call
the designated vendor to schedule the special service and follow City Code 5A.205 to limit
hazards to children. All items must have come from the property where collected i.e. no
items from other premises.
6.4 Electronics: The City will provide a convenient curbside collection to properly recycle
electronic waste. See the Refuse Service Matrix for service level information. Premises
must call the designated vendor to schedule the special service. All items must have come
from the property where collected i.e. no items from other premises.
6.5 Other Reuse: Reduction of trash through reuse operations and events: The City will sponsor
or partner with local service organizations for reuse events such as Fix -It Clinic and the
Citywide Garage Sale day. The City will also produce packets of local reuse vendors and
options for residents to utilize when conducting spring and fall cleaning to reuse or recycle
household goods and clothing. The City will also organize collection of those items from
multi - dwelling buildings. The non - profit organizations must provide their own insurance for
members performing this activity and indemnify the City of their operations.
Section 7 Collection of Yard and Shrub Waste.
7.1 Vendors: Contracted haulers and other refuse vendors will follow the duties and
performance standards for yard waste handling as dictated in contracts and agreements as
supervised by the City.
7.2 Requirement to Collect: The City will provide a convenient curbside collection to properly
recycle yard waste to assist property lawn care, plus to keep yard waste off the street and
down the storm drain which causes problems with street flooding and pollution of lakes and
rivers. Therefore the City's basic refuse service package includes yard waste collection.
7.3 Container Standards: Must follow City Code CHAPTER 4: MUNICIPAL SERVICES. Those who
choose to use the City provided cart will not need to bag or bundle the yard waste.
Household owned reusable containers will not be used to contain yard waste for collection
by the designated hauler due to worker safety concerns and liability of handling private
containers.
Page 8
7.4 Composability: Yard waste materials included as part of the City's yard waste program will be
consistent with the designated Yard Waste /Organics Recycling Facility (i.e. the composter)
requirements. Brush must be bundled in manageable 3 -foot lengths not to exceed an 18"
roll. Woody yard waste not collected by the hauler i.e. tree limbs, stumps, and roots greater
than four (4) inches in diameter must be transported to a properly permitted and licensed
tree waste transfer or handling facility, such as the Anoka County Bunker Hills site, by the
property owner. Christmas trees will be collected when the property schedules it after the
holiday season. If the hauler determines yard waste is too contaminated with non -
compostable materials, service will not be provided, nor will a refund be authorized.
Collection of yard waste can be provided by the contracted hauler after issues are resolved.
Section 8 Collection of Source Separated Organics Comingled with Yard Waste,
Every Other Week Garbage Collection
8.1 Vendors: Contracted haulers and other refuse vendors will follow the duties and
performance standards for organics handling and composting as dictated in contracts and
agreements as supervised by the City.
8.2 Yard Waste /Organic Cart: The City will provide a convenient curbside collection to properly
recycle organics by utilizing a dual purpose cart for both yard waste and organics (food
scraps and food soiled paper). Premises can request the cart plus will receive a free kitchen
starter kit and the required bags for disposal from the City. Apartment buildings and condos
can order also, townhomes will be offered small organic carts as well. Duplexes can share
one yard waste /organics cart. An organics cart service fee will be charged. Collection will
occur weekly on the same day as garbage during the yard waste season, and every- other-
week in the winter. Yard waste comingled with organics in City provided carts will be
collected on the curb during the season, except properties where it is physically challenging
due to the landscape of the front yard, then it will be collected in the alley. Organics will be
collected in the alley during the winter for all properties with alleys; otherwise organics is
collected at the curb.
8.3 Organics Standards: All food waste must be securely contained in a BPI - Certified
compostable bag and disposed of in the City provided carts only. Organics materials
included as part of the City's organics recycling program will be consistent with the
designated Organics Recycling Facility (i.e. the composter) requirements. Paper plates,
bowls, cups, dinnerware must have the BPI - Certificate on the packaging in order to compost
it. Comingled yard waste must meet the standards stated in Section 7 of this policy. If the
hauler determines a yard waste /organics cart is too contaminated with non - compostable
materials, service will not be provided, nor will a refund be authorized. Collection of organic
materials can be provided by the contracted hauler when issues are resolved.
8.4 Low Volume Trash: The City will authorize 30 gallon limited service garbage carts with every -
other -week (EOW) garbage service; 30 gallon, EOW garbage collection must be combined
with organics collection. In addition, households must attend a City - provided recycling class
for information on how to reduce trash and maximize recycling. Approval or denial of the
request shall be at the sole discretion of the City.
Page 9
Section 9 Fees and Charges other than Utility Rates.
9.1 Bulk collection and disposal. Limited service properties pay per item fees based on the
designated hauler rates.
9.2 Unacceptable Bulk. Bulk that is wet or infested, and not properly sealed, will pay per item
fees based on the designated hauler rates.
9.3 Properties will pay for additional appliances, over the one free per year, based on the
designated hauler rates.
9.4 All properties will pay a flat $20 electronics pickup fee when service is scheduled.
9.5 Yard Waste /Organic cart service fee is $2.50 per month for households that sign up for the
service. Multi- dwellings will pay $2.50 for the cart plus $2.00 for a yard waste fee, which
they are not currently charged.
9.6 Low volume trash service as defined in section 8.4 of this Policy: 30 gallon limited service
collected every- other -week collection charge is $10.00 per month.
Section 10 Resolution of Disputes
10.1 Contractor: If there is a dispute between the customer and the Contractor regarding
expenses related to poor service or damages caused by the Contractor's actions, resident
and /or property owner shall file a claim with the Contractor as the City is indemnified by
contract from their operations.
10.2 City: If there is a dispute between the customer and the City regarding poor service and the
City's utility charge for refuse they can file a claim including any and all evidence related to
the dispute (photographs, neighbor's statements, etc.). The City may only deduct from the
next utility bill the affected time period of the poor service.
10.3 Fines: Administrative fines imposed by the City can be appealed to the City Council and
further in District Court if the property owner and /or resident seek additional remedy.
Page 10
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