Question 10. Do you think we should require extra climate adaptation and resilience features to new developments?
5.11 We think the Local Plan should set objectives for developments within a flexible envelope of approaches. There are multiple ways to achieve net zero carbon and these should be applied flexibly in housing developments. 5.12 A tool box approach allows the most cost effective and appropriate solutions for each development so reflecting its particular context. For example, for some developments, Passivhaus energy standards may be achievable (going well above and beyond minimums set out in the Building Regulations), whilst for others, Building Regulations may be appropriate along with an offset solution, such as a green bond or offset fund. Such a bond or fund would achieve a net carbon neutral position. The Plan needs to retain flexibility so that it can incorporate developments in technology and ensure decisions about each development are taken in an informed and appropriate way.
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5.10 A policy approach with multiple options for delivering net zero carbon is likely to be most effective in delivering development, as well as carbon neutrality. A multi-pronged approach should allow different solutions for different developments, reflecting context. For example, for some developments, Passivhaus energy standards may be achievable (going well above and beyond minimums set out in the Building Regulations), but for others, Building Regulations may need to be followed but an offset solution, such as a green bond or offset fund, could be used to achieve a net carbon reduction. Possible options need to be worked up in more detail as the Plan progresses and must build in flexibility.
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Southern & Regional Developments (Willingham) expresses caution relating to the application of higher levels of design standards and construction requirements through development management policies. their concerns is that such requirements will result in restrictions that could impact on viability at this time and deliverability of development within the Plan area. Whilst it may be an objective of the Plan to combat Climate Change to mitigate development impacts and existing factors, the application of restrictive requirements to development design above national standards could directly impact on the Plan's ability to ensure adequate levels of growth are implemented. The Plan should not attach restrictive caveats to development management policies and should explore alternative strategies to combat climate change and achieve a highly environmentally sustainable approach to development. It is important that this is carefully balanced with the needs of the Plan area to achieve growth that meets the demands of its communities and support the everyday requirements of the area's residents. Summary of Comments: Application of restrictive development management requirements is not supported where it will result in the supression of the delivery of growth.
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Southern & Regional Developments (Waterbeach) express caution in relation to the application of higher levels of design standards and construction requirements through development management policies. their concerns is that such requirements will result in restrictions that will impact on viability and deliverability of development within the Plan area at this time. Whilst it may be an objective of the Plan to combat Climate Change to mitigate development impacts and existing factors, the application of restrictive requirements to development design above national standards could directly impact on the Plan's ability to ensure adequate levels of growth are implemented. The Plan should not attach restrictive caveats to development management policies and should explore alternative strategies to combat climate change and achieve a highly environmentally sustainable approach to development. It is important that this is carefully balanced with the needs of the Plan area to achieve growth that meets the demands of its communities and support the everyday requirements of the area's residents. Summary of Comments: Application of restrictive development management requirements is not supported where it will result in the supression of the delivery of growth.
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When framing their priorities the councils should be mindful that they are working within the parameters of the existing legislative and policy framework as it relates to plan-making. The councils’ broader aspirations should not undermine the key objective of appropriately defining and then meeting housing and other development needs through suitable and deliverable sites. Recognising the national housing shortage and the well-documented problems with affordability of homes Greater Cambridge, the councils should carefully consider the consequences of introducing planning policy burdens on new development recognising that the costs of these will ultimately be passed onto the consumer and reduce the ability of new development to viably mitigate its impact or deliver benefits in other areas (e.g. through affordable housing and infrastructure). The soundness of any future plan will turn on among other things its compliance with national planning policy. Paragraph 50, b) of the NPPF states that “Any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.” The Planning Practice Guidance (PPG) expands on this provision stating that policies requiring higher energy performance standards than building regulations “should not be used to set conditions on planning permissions with requirements above the equivalent of the energy requirement of Level 4 of the Code for Sustainable Homes (this is approximately 20% above the current Building Regulations across the build mix).” The ambitions of the plan around energy efficiency should be framed in light this guidance otherwise the resultant policies will not be sound for want of compliance with national policy. Finally, we would emphasise the need for any enhanced energy standards adopted as part of the local plan to incorporate appropriate allowances for viability and feasibility in line with paragraph 153 a) of the NPPF 2019.
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CambridgePPF strongly agrees that additional resilience features for new developments are essential if climate change is to be tackled. • The Local Plan must be sufficiently flexible that it can accommodate the latest technologies and mechanisms to improvements in resilience to climate change – see our response to Q9. Greater Cambridge should be at the forefront of adopting such practices and therefore we want to see a Local Plan that will encourage the construction industry to be early adopters. • Water resource use will be critical for Cambridge if our rivers and wetlands are to support wildlife. We would like to see the highest standards of water efficiency and grey water recycling in all new developments with the aim that water use be reduced to below 80 litres per day per person. We would like the standards set at Eddington to become the new normal for Greater Cambridge. • The Local Plan should encourage a standard of building design and layout that provides efficient insulation to minimise the need both for excessive use of air conditioning in summer and central heating in winter. The provision of large trees can shade buildings, pavements and gardens. • If sea level rises and extreme weather events occur, as some scientists are predicting, then it is likely that new areas may become prone to flooding. This in turn means that the flood zone maps will need to be re-drawn in the coming decades. The Environment Agency will be responsible for this future modelling and its latest information must be incorporated in the Councils’ planning decisions. If this is not possible then the Councils should carry out a future modelling assessment of the flood risk for all new large development sites proposed for the Local Plan. The Plan should include a Policy requiring applicants for all new developments (even in flood zone 1) to submit a statement of possible flood risk based on future climate predictions. Land identified as at risk of future flooding could be considered for biodiversity creation, woodland planting, etc
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Yes. There should be stronger measures to prevent building on flood plains and/or require additional mitigation measures.
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The Wildlife Trust strongly agrees with this approach and the issues identified. Urban areas must be designed to be cooler without energy intensive air conditioning systems, so the inclusion of natural vegetation, trees, and green roofs and walls must become standard practice. These features will also need to be retrofitted to existing urban areas. Sustainable urban drainage systems must work to ensure water is recharged to the ground and aquifer (without causing flooding), but should make provision for grey water systems for non-potable water uses, to reduce the currently unsustainable abstraction of water. New buildings must be designed to use no more than 75 to 80 litres of clean water per person per day.
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See above One adaption to development design would require them to ensure that bus routes through the development would be viable.
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The housebuilding industry, through the HBF, recognises that there is a need to move towards stronger measures to improve the environmental performance of new residential development. This is in terms of reducing carbon emissions in new homes, providing gains in biodiversity on all developments, green infrastructure and improving the environment around new developments. However, the HBF, and our members, consider a national and standardised approach to improving such issues as the energy efficiency of buildings, the provision of renewable energy and the delivery of electric vehicle charging points to be the most effective approach that balances improvements with continued deliver of housing and infrastructure. It is the industry’s preference for a national approach to improving the environmental performance of residential developments, rather than local authorities setting their own standards. We consider this is necessary to allow research and development and supply chains to focus upon responding to agreed national targets, and for training providers to plan their programmes to equip the labour force to meet these new requirements. It is fundamentally inefficient to create a plurality of standards. The industry will clearly need to take into account the Government’s measures on the Future Homes Standard and Bio-Diversity Gain – both of which will be mandatory for new residential developments in 2020. In terms of these new regulatory targets applying to new development from 2025 onwards – to deliver the objectives of the Future Homes Standard – the industry, with the leadership of the HBF, will be commissioning work to consider what the industry can do, taking into account developments in research and product development within that time-frame, and what new standards can feasibly be adopted and implemented by the industry. Therefore, when considering their approach to such matters the councils should ensure that they are working within the current policy and legislative framework and not seeking to deliver a different range of standards that will work against the collective drive on this matter. The importance of a collective approach will also balance the cost of delivering the energy efficiency improvements required alongside other planning obligations and development aspirations that the Councils are seeking to deliver through the GCLP, such as meeting housing needs in full and improving the affordability of homes in this area. The Councils will therefore need consider the consequences of introducing planning policy burdens on new development recognising that the costs of these will ultimately be passed onto the consumer or leave some sites undeliverable. Prior to the future standards the Councils must take account of current guidance which sets out the approach that Councils should take with regard to technical standards relating to energy efficiency with paragraph 50 of the NPPF stating that: “Any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.” The Planning Practice Guidance (PPG) expands on this provision outlining that policies requiring higher energy performance standards than building regulations should not be used to set conditions on planning permissions with requirements above the equivalent of the energy requirement of Level 4 of the Code for Sustainable Homes. As such the aspirations of this plan with regard to improving the energy efficiency of new homes must be made within the context of this guidance if the plan is to be consistent with national policy and found sound.
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The key aspect of adapting to climate change will be in the location of new development. This must be carefully considered in the Local Plan. For example, regardless of emerging measures for energy efficiency and better building fabric, if development is allocated in settlements with few services or facilities then this will result in the need for more travel compared to development in towns where more facilities are available that are within walking / cycling distance, or connected by public transport. Paragraph 4.1.3 correctly recognises that, as this winter has demonstrated, flooding has become a key issue as events predicted as 1 in 100 year floods are happening more frequently. Caution should therefore be used in allocating sites that are close to existing modelled flood plains, particularly where topographic contours are shallow.
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No answer given
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Southern & Regional Developments (Swavesey) expreses caution relating to the application of higher levels of design standards and construction requirements through development management policies. their concerns is that such requirements will result in restrictions that will impact on viability and deliverability of development within the Plan area. Whilst it may be an objective of the Plan to combat Climate Change to mitigate development impacts and existing factors, the application of restrictive requirements to development design above national standards could directly impact on the Plan's ability to ensure adequate levels of growth are implemented. The Plan should not attach restrictive caveats to development management policies and should explore alternative strategies to combat climate change and achieve a highly environmentally sustainable approach to development. It is important that this is carefully balanced with the needs of the Plan area to achieve growth that meets the demands of its communities and support the everyday requirements of the area's residents. Summary of Comments: Application of restrictive development management requirements is not supported where it will result in the supression of the delivery of growth.
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4.33 Newlands Developments strongly agree with Greater Cambridge that climate adaptation and resilience features should be required for all new development. The UKCP18 climate projections predict that the UK will experience increased summer and winter temperatures, reduced summer rainfall, increased winter rainfall and increased extreme weather events. 4.34 Newlands Developments currently includes a number of features to protect buildings and their occupants against the impacts of climate change. This includes rainwater harvesting and water saving sanity fittings and extensive Sustainable Drainage Systems (SuDS) which provide additional benefits such as biodiversity enhancement, recreation opportunities for building users and mitigating urban heat island effects.
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Yes, strongly agree. In designing new development there is an opportunity to secure high standards for climate adaptation and resilience features. Historic England is broadly supportive of the goal to achieve net zero carbon by 2020. A sustainable approach should secure a balance between the benefits that such development delivers and the environmental costs it incurs. The policy should seek to limit and mitigate any such cost to the historic environment. We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://content.historicengland.org.uk/images-books/publications/energy-efficiencyhistoric-buildings-ptl/heag014-energy-efficiency-partlL.pdf/ to be helpful in understanding these special considerations. We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. A sustainable approach should secure a balance between the benefits that such development delivers and the environmental costs it incurs. The policy should seek to limit and mitigate any such cost to the historic environment. Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://content.historicengland.org.uk/images-books/publications/energy-efficiencyhistoric-buildings-ptl/heag014-energy-efficiency-partlL.pdf/ to be helpful in understanding these special considerations.
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No answer given
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Please refer to the Sustainability Vision Statement which seeks out opportunities to bring the big themes to life in every aspect of the project.
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Any additional design requirements attached to development management policies above national standards could result in restrictions to development delivery that could impact on viability and deliverability of development within the Plan area. Whilst it may be an objective of the Plan to combat Climate Change to mitigate impacts, the application of restrictive requirements to development design could directly impact on the Plan's ability to ensure adequate levels of growth are implemented. The Plan should not attach such restrictive caveats to development management policies and should explore alternative strategies to combat climate change and achieve a highly environmentally sustainable approach to development. It is important that this is carefully balanced with the needs of the Plan area to achieve growth that meets the demands of its communities and support the everyday requirements of the area's residents. Instead, Eurpean Property Ventures (Cambridgeshire) seeks for the policy of the emerging plan to adopt an approah that delivers sustainable development through a strategic approach that provides development in locations that are sustainable as a first principle to reducing environmental detriment. The over-concentration of development alongside existing major centres should also be considered with caution given the intensification of pollutants, environmental influences and detrimental impacts that can result from the concentrted clustering of development. Instead, distributing some of the development required to sustainable locations that have a high degree of social independence is advanced. Summary of Comments: Application of restrictive development management requirements is not supported where it will result in the supression of the delivery of growth.
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5.11 A policy approach with multiple options for delivering net zero carbon is likely to be most effective in delivering development, as well as carbon neutrality. A multi-pronged approach should allow different solutions for different developments, reflecting context. For example, for some developments, Passivhaus energy standards may be achievable (going well above and beyond minimums set out in the Building Regulations), but for others, Building Regulations may need to be followed but an offset solution, such as a green bond or offset fund, could be used to achieve a net carbon reduction. Possible options need to be worked up in more detail as the Plan progresses and must build in flexibility.
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Yes. Prior to the introduction of the National Planning Policy Framework, there was Planning Policy Guidance which dealt with many aspects of climate adaption and resilience. These included guidance on power supply, water usage and drainage, designing for heavier rainfall, insulation and more. This guidance should be brought back into use urgently. If necessary, include as Supplementary Planning Documentation in the Local Plan.
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We support the Councils’ recognition of the severity of the climate change issue and recognition of the key issues and challenges of reducing our climate impact and the need to adapt to more extreme weather, a hotter climate and a changing ecology. We support key actions to address climate change including: Using renewable and low carbon energy generation; Promoting sustainable travel and discouraging car use where possible; Retrofitting existing buildings; Rooftop greening – this could be extended to generally extending and enhancing the ecological network We generally support the promotion of climate change adaptation measures including: Managing flood risk and incorporating SUDS; Increasing biodiversity and tree planting; Improving water efficiency. The Plan should prioritise avoiding key factors contributing to climate change (through more greenhouse gases) e.g. pollution, habitat fragmentation, loss of biodiversity and to protecting and enhancing the natural environment’s resilience to change. Green Infrastructure and resilient ecological networks play an important role in aiding climate change adaptation. Development should be located and designed to remove/reduce reliance on car travel, promoting sustainable travel to improve air quality and its contribution to climate change. Development should incorporate multi-functional sustainable drainage and flood risk management measures in accordance with the SPD. Plan policies should focus on securing implementation of an enhanced and extended ecological network that will deliver climate change mitigation in addition to wider environmental services. This should be delivered through appropriate policy requirements. We are aware that an Integrated Water Management Study, incorporating a Water Cycle Study and Strategic Flood Risk Assessment, is being progressed as a key evidence document to inform preparation of the Local Plan. We welcome this and urge for a strong focus /recommendation for the implementation of integrated drainage including multi-functional SUDs in all development, where possible. It should also identify and promote delivery of benefits and opportunities associated with climate change, for example to create more extensive wetland habitats and to protect and enhance the degraded peat soils remaining in the Greater Cambridge area. Without appropriate measures new development will harm Greater Cambridge’s natural natural Page 3 of 15 environment. Measures to avoid impacts must be prioritised. Cambridgeshire is especially dependent on its groundwater which is currently being pumped dry with knock-on effects for the natural environment including water quality and biodiversity. In addition to new buildings climate change requires retrofitting of existing buildings. Revised and more ambitious water consumption targets are also needed. The Plan should include appropriate policies to secure delivery of the recommendations identified through the Integrated Water Study. We would also advise that consideration be given to updating the existing Flood and Water Supplementary Planning Document to reflect current BNG and climate / net zero carbon targets. The Local Plan and relevant policies should reflect the importance of remaining peat soils as a significant carbon store that can help to improve air quality and mitigate against climate change. The development strategy and relevant policies should seek to protect Best and Most Versatile Land, including peat soils, and contribute towards enhancement of degraded peat to deliver a wide range of environmental services including biodiversity, open space, flood risk and drainage benefits, in addition to helping to mitigate climate change. With regard to tree planting for carbon offsetting Natural England advises that planting of trees needs to be considered in the context of wider plans for nature recovery. Tree planting should only be carried out in appropriate locations, taking into consideration potential impacts on existing ecology and the opportunities to create alternative habitats that could deliver better enhancements for people and wildlife, and also store carbon effectively. Where woodland habitat creation is appropriate, consideration should be given to natural regeneration for the economic and ecological benefits this can achieve. Any tree planting should use native and local provenance tree species suitable for the location. Natural England advocates an approach which seeks to increase biodiversity and green infrastructure generally, not simply planting of trees, and protecting / enhancing soils, particularly peat soils.
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4.12 A policy approach with multiple options for delivering net zero carbon is likely to be most effective in delivering development, as well as carbon neutrality. A multi-pronged approach should allow different solutions for different developments, reflecting context. For example, for some developments, Passivhaus energy standards may be achievable (going well above and beyond minimums set out in the Building Regulations), but for others, Building Regulations may need to be followed but an offset solution, such as a green bond or offset fund, could be used to achieve a net carbon reduction. Possible options need to be worked up in more detail as the Plan progresses and must build in flexibility.
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- The potential for district heating and cooling should be examined carefully and then followed up for individual, significant, new developments. A special case may exist where there is a source of waste heat from landfill or wastewater treatment nearby or where deep aquifers or rivers could be utilised. - New developments should be designed with planned retrofitting to remove natural gas heating and cooking or, if national legislation permits it, designed to not include it in the original build. Some hot water storage may be required in buildings with electric water heating to reduce short term peaking factors in the power network. - The possibility should be examined for buildings in new developements to be more resilient to flooding on the occasions when drainage design thresholds will be exceeeded.
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4.9 A policy approach with multiple options for delivering net zero carbon is likely to be most effective in delivering development, as well as carbon neutrality. A multi-pronged approach should allow different solutions for different developments, reflecting context. For example, for some developments, Passivhaus energy standards may be achievable (going well above and beyond minimums set out in the Building Regulations), but for others, Building Regulations may need to be followed but an offset solution, such as a green bond or offset fund, could be used to achieve a net carbon reduction. Possible options need to be worked up in more detail as the Plan progresses and must build in flexibility.
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4.10 A policy approach with multiple options for delivering net zero carbon is likely to be most effective in delivering development, as well as carbon neutrality. A multi-pronged approach should allow different solutions for different developments, reflecting context. For example, for some developments, Passivhaus energy standards may be achievable (going well above and beyond minimums set out in the Building Regulations), but for others, Building Regulations may need to be followed but an offset solution, such as a green bond or offset fund, could be used to achieve a net carbon reduction. Possible options need to be worked up in more detail as the Plan progresses and must build in flexibility.
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2.1 Magdalene College fully commits to reducing its impact on the climate and supports the aspirations of the Local Plan with regard to climate change. 2.2 However, it is important to recognise that the vast majority of the College’s building stock is historic – some dating back more than 600 years. Achieving energy efficiency whilst maintaining user comfort and not harming the heritage significance of the buildings is a difficult balancing act.
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No response proposed.
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4.5.1 A policy approach with multiple options for delivering net zero carbon is likely to be most effective in delivering development, as well as carbon neutrality. A multi-pronged approach should allow different solutions for different developments, reflecting context. For example, for some developments, Passivhaus energy standards may be achievable (going well above and beyond minimums set out in the Building Regulations), but for others, Building Regulations may need to be followed but an offset solution, such as a green bond or offset fund, could be used to achieve a net carbon reduction. Possible options need to be worked up in more detail as the Plan progresses and must build in flexibility.
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4.9 A policy approach with multiple options for delivering net zero carbon is likely to be most effective in delivering development, as well as carbon neutrality. A multi-pronged approach should allow different solutions for different developments, reflecting context. For example, for some developments, Passivhaus energy standards may be achievable (going well above and beyond minimums set out in the Building Regulations), but for others, Building Regulations may need to be followed but an offset solution, such as a green bond or offset fund, could be used to achieve a net carbon reduction. Possible options need to be worked up in more detail as the Plan progresses and must build in flexibility.
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4.9 A policy approach with multiple options for delivering net zero carbon is likely to be most effective in delivering development, as well as carbon neutrality. A multi-pronged approach should allow different solutions for different developments, reflecting context. For example, for some developments, Passivhaus energy standards may be achievable (going well above and beyond minimums set out in the Building Regulations), but for others, Building Regulations may need to be followed but an offset solution, such as a green bond or offset fund, could be used to achieve a net carbon reduction. Possible options need to be worked up in more detail as the Plan progresses and must build in flexibility.
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