HomeMy WebLinkAbout12 Mello-Roos Community Facility District Agenda Item #
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Memorandum
To: Board or Directors
From: Peter Holzmeister
Date: March 26, 2002
Subject: Mello--Roos Community Facility District
At the last Board meeting I was asked to schedule a workshop for the Directors to
discuss Mello-Roos Community Facility District processes. Attached is a chapter
entitled "Mello-Roos Bond(Community Facilities Districts)"that I have copied from a
much larger document entitled California Debt issuance Primer. Also attached is the
outline of the discussion we had in the past concerning Mello-Roos. This is probably an
excellent time to review the Mello-Roos material.
The last time you discussed this matter the directors posed the following questions or
concerns:
Why would we do it? How does the District as a whole benefit?
What areas would be covered by the CFD and be subject to the tax?
We are so busy now why tackle another big project?
Will other developers ask us to provide Mello-Roos for them?
We will become identified with the tax.
There can be no cost to the other customers of the District
It is not our practice to provide financing for development
What impact would there be on our bonded debt limits
This is agendized as a workshop so I have no formal recommendation, and not action is
necessary at this time.
Mello-Roos Community Facility District (CFD)
1. This discussion initiated by East West partners. Request TDPUD for a CFD. I have
no experience with CFD
2. Burdens shift to TDPUD. Burdens can be mitigated by compensation. What are the
burdens?
CEQA
CDF formation process
Debt issuance process
On-going disclosure
On-going administration
Possible JPA
3. Process for forming a CFD
Adoption of local goals and policies
JPA
Resolution of intention
Report of responsible officer
Notice
Protest hearing
Resolution of formation
Election (2/3 of property owners must approve)
Recording and notice of special tax lien
4. Process for approving and issuing bonds
Public hearing
Resolution of necessity
Resolution to incur bonded debt
5. Financing team
Bond counsel
Financial advisor
Underwriter
Fiscal agent
Trustee
6. General consideration
Financial master plan
Debt standards and policies
General Fund of TDPUD not obligated to pay
Security of debt
Value of land must be three times debt
Additional security
Tax formula can be complex and confusing
Who owns the improvements - CFD or TDPUD
MELLO-ROOS BONDS (COMMUNITY FACILITIES DISTRICTS)
DEFINITION AND PURPOSE
The Mello-Roos Community Facilities Act of 1982 (the "Mello-Roos Act")
provides a mechanism by which certain public entities, such as cities, counties, special districts,
school districts, joint powers entities and redevelopment agencies, can finance the construction
and/or acquisition of facilities and the provision of certain services. The Mello-Roos Act
authorizes such a public entity to form a Comm uuty Facilities District (a "CFD" or "district'),
otherwise known as a Mello-Roos district. Once formed, the district can finance facilities and
provide services. Upon approval by a two-thrids vote of the registered voters or landowners
within the district, the district may issue bonds secured by the levy of special taxes.
The special taxes are not assessments, and there is no requirement that the special
tax be apportioned on the basis of benefit to property. This affords greater flexibility in
designing the special tax. A special tax levied by a district is not an ad valorem property tax
under Article XIIIA of the California Constitution, however the lien of the special taxes has the
same priority as property taxes.
PROJECTS WHICH MAY BE FINANCED
A district may finance the purchase, construction, expansion, improvement or
rehabilitation of real or other tangible property with an estimated useful life of five or more
years, or planning and design work that is directly related thereto. The financed facilities do not
need to be physically located within the district. In general, a district may finance the purchase
of facilities that are completed before the resolution of formation to establish the district is
adopted. A district may also finance the purchase of facilities that are completed after the
adoption of the resolution of formation, so long as such facilities were constructed as if they had
been constructed under the direction and supervision, or under the authority of, the local agency
creating the district. This means, at a minimum, that the prevailing wage law applies if the
resolution of formation is adopted before the public improvement is completed. In addition, a
district may finance facilities to be owned or operated, or services to be provided, by an entity
other than the entity that created the district, pursuant to a joint community facilities agreement
or a joint exercise of powers agreement entered into pursuant to the Mello-Roos Act.
Facilities. Examples of the types of facilities that may be financed are as follows:
• Local park, recreation,parkway and open-space facilities
• Elementary and secondary school sites and structures that meet the
building area and cost standards of the State Allocation Board
• Libraries
• Child care facilities
MELLo-Roos BONDS 183
• Facilities to transmit and distribute water, natural -as pipeline facilities,
telephone lines, facilities to transmit or distribute electrical energy and
cable television lines for customers that do not have those services or to
mitigate existing visual blight
• Facilities, whether publicly or privately owned, for flood and storm
protection purposes, including storm drainage systems and sandstorm
protection systems
• Any other governmental facilities the legislative body creating the district
is authorized by law to contribute revenue toward, construct, own or
operate
• Work to bring buildings or real property, including privately owned
buildings and real property, into compliance with seismic safety standards
and regulations, if such work is certified as necessary by local building
officials
• Work deemed necessary to repair damage to real property caused by the
occurrence of an earthquake within any county or area designated by the
President of the United States or the Governor as a disaster area(subject to
certain limitations in the Mello-Roos Act)
• Work deemed necessary to repair and abate damage caused to privately
owned buildings and structures by soil deterioration (subject to certain
limitations in the Mello-Roos Act)
A district may not own any facilities for the transmission or distribution of natural
gas, telephone service or electrical energy and may only operate and maintain those facilities
pursuant to an agreement with a public utility.
A district may be used to eliminate fixed special assessment liens on property
within the district and to repay any indebtedness secured by any tax, fee, charge or assessment
levied within the area of the district, or may pay debt service on that indebtedness.
Services. Types of services that may be provided by a district are as follows:
• Police protection services
• Fire protection and suppression services and ambulance and paramedic
services
• Recreation program services, library services, maintenance services for
elementary and secondary school sites and structures, and the operation
and maintenance of museums and cultural facilities
• Maintenance of parks, parkways and open space
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• Flood and storm protection services, including but not limited to the
operation and maintenance of storm drainage systems and sandstorm
protection systems
• Removal or remedial action services for the cleanup of any hazardous
substance released or threatened to be released into the environment
The Mello-Roos Act contains restrictions on services authorized by landowner
election. Such services may only be paid for by a CID to the extent that they are in addition to
those provided in the territory of the CFD before it was created. The services to be paid for by
the CFD may not supplant services already available within that territory when the CFD was
created. In addition, a landowner election may not authorize the levy of a special tax for
recreation program services, library services, school maintenance services or museum and
cultural facility maintenance services. Such restrictions do not apply, however to services
authorized by registered voter election.
POLICY CONSIDERATIONS
The nature of the facilities and services to be financed or paid for largely
determine whether special taxes are levied instead of special assessments. Special taxes permit
financing such general benefit facilities as libraries and schools, which are not authorized by the
special assessment statutes. In addition, the financed facilities are not required to be located in
the district, which allows a district to finance regional facilities. Finally, the flexibility allowed
in structuring a Mello-Roos tax formula (also known as the rate and method of apportionment)
may make a Mello-Roos financing a more attractive alternative than an assessment district
financing. Because of the election requirement, the Mello-Roos Act has been used as a financing
vehicle primarily where the voters are landowners as rather than registered voters.
Compared to special assessment financings, most Mello-Roos district financings
are complicated. Because of the flexibility provided by the Mello-Roos Act, special tax formulas
are often quite complex and specific, making it difficult for a property owner to understand the
nature of the burden on his property. Great care must be taken in designing the special tax
formula to reduce political concerns and to provide clear and complete disclosure to home buyers
of the burden imposed by the special tax.
SECURITY AND SOURCES OF REPAYMENT FEATURES
Mello-Roos bonds are payable from and secured by special taxes, which are
levied upon the property in the district according to the rate and method of apportionment
approved by the voters in the district. Like assessments, special taxes are levied upon real
property and are not a personal debt of the property owners. The remedy for delinquencies is
foreclosure. The general fund of the local agency that created the district is not obligated to pay
debt service on the bonds. A bond reserve fund is permitted, and the special tax may be levied to
replenish the bond reserve fund so long as the tax rate does not exceed the maximum special tax
rate approved by the voters in the district.
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MELLO-Roos BONDS 185
The proceeds of a special tax may only be used to pay the cost of providing the
facilities, services and incidental expenses authorized by the election. Special taxes are generally
collected in the same manner as ad valorem property taxes are collected and are subject to the
same penalties and the same procedure, sale and lien priority in the case of delinquency as are ad
valorem property taxes. However, the legislative body may adopt another collection procedure,
including direct billing of property owners, if circumstances so require.
The legislative body may provide additional security for the bonds by
covenanting on behalf of the bondholders that it will commence foreclosure proceedings by a
specified time if a special tax installment is delinquent. Because the foreclosure process can be
lengthy, the legislative body may also provide for special tax alternate procedures, such as the
waiver of delinquency and redemption penalties and the acceptance of bonds tendered in
payment of special taxes or at a foreclosure sale.
The legislative body may require additional security for the bonds in the form of a
letter of credit or a guaranty where the land in the district is largely undeveloped and is owned by
a few persons. The additional security is typically only required until the district is fully
developed and the property is sold to the general public. Bond insurance may be available for
bonds issued by substantially developed districts, but is not commonly available for bonds issued
by new, undeveloped districts.
The formula for levying special taxes may be based upon a variety of factors,
including density of development, square footage of construction, acreage or zoning. Unlike
special assessment districts, there is no requirement that the special tax be based upon the benefit
a parcel receives from the facilities or services to be financed, however, the tax must be levied on
a reasonable basis, as determined by the legislative body of the district.
PROCESS FOR APPROVAL—ESTABLISIIING COMMUNITY
FACILITIES DISTRICT AND LEVYING SPECIAL TAX
Adoption of Local Goals and Policies. Local agencies that initiate proceedings to
establish districts on or after January 1, 1994 must first adopt local goals and policies concerning
the use of the Mello-Roos Act. The policies must at least include:
• A statement of the priority that various kinds of facilities will have for
financing through the use of the Mello-Roos Act, including public
facilities to be owned and operated by other public agencies (such as
school districts)
• A statement concerning the credit quality to be required of bond issues,
including criteria to be used in evaluating the credit quality
+ A statement concerning the steps to be taken to ensure that prospective
property purchasers are fully informed about their taxpaying obligations
under the Mello-Roos Act
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• A statement concerning the criteria for evaluating the equity of tax
allocation formulas, and the desirable and maximum amounts of special
tax to be levied against any parcel
• A statement of the definitions, standards and assumptions to be used in
appraisals required by the Mello-Roos Act
In addition, the local goals and policies adopted by school districts must include a
priority access policy that gives priority attendance access to students residing in a school district
whose residents have contributed to the financing of the construction of school district facilities.
Initiation of proceedings. Proceedings to establish a district may be instituted in
any of the following ways:
• By initiative of the legislative body
• By written request signed by two members of the legislative body
containing the information required by the Mello-Roos Act
• By petition signed by not less than 10% of the registered voters residing
within the proposed district
• By petition signed by the owners of not less than 10% of the area of land
within the proposed district
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If the facilities to be financed by the district will be owned or operated by an
entity other than the local agency creating the district, the local agency and the entity must enter
into a joint community facilities agreement or a joint exercise of powers agreement prior to the
adoption of the resolution of formation creating the district. No local agency that is a party to a
joint community facilities agreement or a joint exercise of powers agreement may have primary
responsibility for formation of the district unless that local agency is:
(i) A city, a county or a city and county
(ii) An agency created pursuant to a joint powers agreement that is separate
from the parties to the agreement, is responsible for the administration of
the agreement and subject to certain notification requirements under the
Government Code
(iii) An agency that is reasonably expected to have responsibility for providing
facilities or services to be financed by a larger share of the proceeds of
special taxes or bonds of the district created pursuant to the joint exercise
of powers agreement or the joint community facilities agreement than any
other local agency
Resolution of intention. A "resolution of intention" to establish a district must be
a adopted within 40 days after a written request or a petition to create the district is filed with the
legislative body of the local agency that will form the district. The resolution of intention must:
MELLo-Roos BONDS 187
• State that the district is being formed pursuant to the Mello-Roos Act
• Describe the proposed boundaries of the district (which need not be
contiguous)
• State the name of the proposed district
• Describe the facilities or services to be financed in a manner sufficient to
allow a taxpayer within the district to understand what district funds may
be used to finance
• Describe any financing plan, lease, lease-purchase or installment-purchase
arrangement that will be used to finance the facilities
• Identify any completed facilities to be purchased or incidental expenses to
be incurred
• State that except where funds are otherwise available, a special tax will be
levied annually to pay for the facilities and services and that it will be
secured by recordation of a continuing lien against all nonexempt property
in the district
• Specify the rate and method of apportionment and manner of collection of
the special tax in sufficient detail so each landowner or resident is able to
estimate the maximum annual amount to be paid, and if the special taxes -
will be levied against property used for private residential purposes,
specify (a) the dollar amount of the maximum special tax, and state that
such amount will not be increased by more than 2% per year, (b) the tax
year after which no further special tax will be levied or collected, and (c)
that under no circumstances will the special tax levied against any parcel
be increased as a consequence of delinquency or default by the owner of
any other parcel within the district by more than 10%
• Specify the conditions under which the obligation to pay the special tax
may be prepaid and permanently satisfied
• Fix a time and place for a public hearing not less than 30 days nor more
than 60 days after the resolution of intention is adopted
• Describe any adjustment in property taxation to pay prior indebtedness
• Describe the proposed voting procedure
Report. When the resolution of intention is adopted, the legislative body must
direct each officer responsible for providing one or more of the proposed facilities or services to
file a report at or before the time of the hearing that contains:
188 MELLO-Roos BONDS
• A brief description of the type of facilities or services required to meet
adequately the needs of the district
• An estimate of the cost of providing the facilities or services
• If the district proposes to purchase completed facilities or to pay incidental
expenses, an estimate of the fair and reasonable cost of those facilities or
expenses
• If the district proposes to finance removal or remedial action for the
cleanup of any hazardous substance, either (i) a remedial action plan, or
(ii) a determination that the remedial action plan is not required
Notice. The clerk of the legislative body is required to publish a notice of the
public hearing once, in a newspaper of general circulation in the proposed district, at least seven
days before the public hearing, containing the information required by the Mello-Roos Act.
Notice of the public hearing may also be given by first-class mail to each registered voter and to
each landowner within the proposed district, sent at least 15 days before the public hearing
Protests. Oral or written protests may be made at the public hearing by any
interested persons or taxpayers against the establishment of the district, the extent of the district,
the type of facilities or services to be provided or the regularity or sufficiency of the proceedings.
Protests about the regularity or the sufficiency of the proceedings must be in writing and filed
._K with the clerk of the legislative body prior to the hearing, and must specify the irregularities or
defects. Written protests may be withdrawn at any time before the conclusion of the hearing.
Majority protest to formation of district. If 50% of the registered voters or six of
the registered voters (whichever is more) residing in, or the owners of one-half or more of the
nonexempt land in, the territory proposed to be included in the district protest against the
establishment of the district, the proceedings to create the district or to levy the special tax must
be discontinued for a period of one year. If the majority protest is only against the furnishing of
a specified type of facility or service, that facility or service must be eliminated. If the protest is
against levying a specified special tax, that special tax must be eliminated.
At the public hearing, the resolution of intention may be modified by eliminating
proposed facilities or services, reducing the special tax, or removing territory from the proposed
district. Any modification of the resolution of intention that would increase the probable special
tax must be preceded by a report analyzing the impact of the proposed modification on the
special tax, which report must be considered prior to approval of the modification.
Resolution of Formation. If, at the conclusion of the public hearing, the
determination is made to establish a district, a "resolution of formation" must be adopted. The
resolution of formation must:
• Contain all of the information contained in the resolution of intention
MELLO-Roos BONDS 189
• State that the proposed special tax to be levied in the district has not been
precluded by majority protest
• Identify the facilities and services to be funded
• State the name, address and telephone number of the entity responsible for
preparing the annual roll of special tax levy obligations by assessor's
parcel number and for estimating future special tax levies
• State that upon recordation of a notice of special tax lien, a continuing lien
to secure each levy of the special tax will attach to all non exempt real
property in the district and will continue until the special tax obligation is
permanently satisfied or the legislative body ceases collection of the
special tax
• State the county of recordation and the recording information for the
boundary map of the proposed district
• Determine by a specific finding whether the proceedings were valid and in
conformity with the Mello-Roos Act
Election. The levy of a special tax must be approved by two-thirds of the votes
cast by the qualified electors of the district in a general or special election held at least 90 days,
but not more than 180 days, after the public hearing. These time limits may be waived with the
unanimous consent of the qualified electors and the concurrence of election officials, and this
action is typically taken in a developer(i.e. landowner vote) district.
Determining who votes. The vote on the special tax must generally be by
registered voters residing in the district. However, if fewer than 12 persons have been registered
to vote within the district for any of the 90 days preceding the close of the public hearing, the
vote must, or if the special tax will not be apportioned on any then residential property, the vote
may be by the landowners within the district. Each of such landowners must be granted one vote
for each acre or portion of an acre owned within the district.
Manner of conducting election. The election may be conducted by mail, or
ballots may be delivered by personal service to the voters. A ballot proposition may combine the
questions relating to the levy of a special tax, the incurring of bonded indebtedness and the
establishment or change of an appropriations limit. If the vote is to be by the landowners of the
district, analysis and arguments may be waived with the unanimous consent of all of the
landowners, and such waiver must be stated in the order for the election.
Recordation and Notice of Special Tax Lien. Upon a determination by the
legislative body that the requisite two-thirds of votes cast in the election are in favor of levying
the special tax, the clerk of the legislative body must record a notice of special tax lien in the
office of the county recorder for each county in which the district is located, whereupon the lien
of the special tax will attach as provided in Section 3114.5 of the Streets and Highways Code.
190 MELLO-Roos BONDS
Levy of special tax. The provisions of Streets and Highways Code, Sections 3100
et seq. apply to any proceedings taken under the Mello-Roos Act. The special tax must be levied
initially by an ordinance adopted by the legislative body, and thereafter (assuming the tax is
levied at the same or a lower rate than in the ordinance), it may be adjusted annually by the
adoption of a resolution. Reasonable administrative costs incurred in collecting the special tax
may be deducted by the tax collector.
Extension of Authorized Facilities and Services and Changes in Special Taxes.
After adoption of the resolution of formation, the legislative body, 25% or more of the registered
voters residing in the district or the owners of 25% or more of the land in the district may
institute proceedings to change the types of public facilities or services financed by the district,
change the rate and method of apportionment or levy an new special tax, as specified in the
Mello-Roos Act.
Disclosure Requirements. In addition to the continuing disclosure requirements
under SEC Rule 15c2-12, the Mello-Roos Act requires the legislative body to supply the certain
information to CDIAC by October 30 of each year after the sale of any bonds, until the final
maturity of such bonds. The information required to be supplied to CDIAC includes (i) the
principal amount of the bonds outstanding, (ii) the balance in the bond reserve fund, (iii) the
balance in the capitalized interest fund, if any, (iv) the number of parcels which are delinquent
with respect to their special tax payments, the amount that each parcel is delinquent, the length of
time that each has been delinquent, and when foreclosure was commenced for each delinquent
parcel, (v)the balance in any construction funds, and (vi) the assessed value of all parcels subject
to special tax to repay the bonds as shown on the most recent equalized roll. In addition, the
Mello-Roos Act requires the legislative body to notify CDIAC within 10 days upon the
occurrence of(x) a failure of the local agency or the paying agent or fiscal agent to pay principal
and interest due on the bonds on any scheduled payment date, or (y) withdrawal of funds from a
reserve fund to pay principal and interest on the bonds beyond the levels set by CDIAC.
Proposition 218. Proposition 218 added Article X1HC and Article XIM to the
California Constitution. Article XIED has no direct application to bonds issued under the
Mello-Roos Act, because they are authorized by a two-thirds vote of the qualified electors of the
district. Article XlHC states, among other things, that ". . . the initiative power shall not be
prohibited or otherwise limited in matters of reducing or repealing any local tax, assessment, fee
or charge." As discussed above, the Mello-Roos Act provides for a procedure, which includes
notice, hearing, protest and voting requirements, to alter the rate and method of apportionment of
an existing special tax. However, the Mello-Roos Act also prohibits the legislative body from
adopting any resolution to reduce the rate of any special tax or terminate the levy of any special
tax pledged to repay any debt incurred pursuant to the Mello-Roos Act unless the legislative
body determines that the reduction or termination of the special tax would not interfere with the
timely retirement of that debt. Consequently, although the matter is not free from doubt, it is
likely that Proposition 218 has not conferred on the voters the power to repeal or reduce special
taxes if such reduction would interfere with the timely retirement of any bonds issued by a
district. For more information regarding Proposition 218, see "State Constitutional Limitations
—The Jarvis Family of Initiatives."
MELLo-Roos BONDS 191
PROCESS FOR APPROVAL—ISSUING BONDS
The legislative body may generally only sell Mello-Roos bonds if it determines,
prior to the sale of the bonds, that the value of the property in the district that would be subject to
the special tax will be at least three times the principal amount of bonds to be sold plus the
principal amount of all other bonds outstanding and secured by a special tax or a special
assessment on the property in the district. However, if the legislative body concludes that the
proposed bonds do not present any unusual credit risk (due to credit enhancement or for other
reasons), or that the bond issue should proceed for specified public policy reasons, then such
determination need not be made.
The proceedings to issue bonds secured by the levy of a special tax are usually
combined with proceedings to establish a district. In such cases, a resolution of intention to issue
bonds is adopted at the same time as the resolution of intention to establish the district. The local
agency is required to hold a public hearing regarding the proposed bond issuance and to publish
notice of the hearing, which actions are typically combined with the public hearing and notice
published in connection with the establishment of the district. At the public hearing, any
interested person may appear and present any matters material to the question of issuing the
bonds. After the public hearing, a district may authorize the issuance of bonds by adopting a
resolution of necessity to issue bonds, and a resolution to incur bonded indebtedness.
Resolution of Necessitv.
The resolution of necessity must:
• Contain a declaration of the necessity for the indebtedness
• State the purpose for which the proposed debt is to be incurred
• State the amount of the proposed debt
• State the time and place for a hearing by the legislative body on the
proposed debtissue
Resolution to Incur Bonded Indebtedness.
The resolution to incur bonded indebtedness must:
• State that the legislative body deems it necessary to incur the bonded
indebtedness
• State the purpose for which the bonded indebtedness will be incurred
• State that either the whole of the district or a portion of the district will
pay for the bonded indebtedness, as previously determined by the
legislative body
• State the amount of debt to be incurred
192 MELLO-Roos BONDS
• Describe the maximum the bonds to be issued will run before maturity,
which term may not exceed 40 years
• State the maximum annual rate of interest to be paid, payable annually or
semiannually, or in part annually and in part semiannually
• State the date of the election (which may be consolidated with the election
to levy the special tax), the polling hours if the election will not be
conducted by mail or the hour when the mailed ballots must be returned to
the election officer if the election is conducted by mail
If more than two-thirds of the votes cast at the election are in favor of incurring
the indebtedness, the legislative body may, by resolution, provide for:
• The form, execution and issuance of the bonds
• The appointment of a paying agent or bond registrar
• The execution financing documents securing the bonds
• The pledge or assignment of any revenues of the district to the repayment
of the bonds
Y • The investment of bond proceeds and other revenues, which investment
provisions must comply with the restrictions in the Mello-Roos Act
• The dated date and maturity date(s) of the bonds, and the place(s) and
time(s) that the bonds are payable
• The denominations, forms and registration privileges of the bonds
• Any other terms and conditions determined to be necessary by the
legislative body
PROCESS FOR SALE
Mello-Roos bonds may be sold at negotiated sale if the governing body
determines that a negotiated sale would result in a lower overall cost. Otherwise, the bonds must
be sold at competitive sale.
MAXIMUM AMOUNT; OTHER LIMITATIONS ON TERMS OF BONDS
The maximum amount of the bonds that may be issued is the amount approved by
the qualified electors at the bond election. Bonds may bear Fixed or Variable interest at a Rate
not exceeding 12% per year. Interest on the bonds may be paid annually or semiannually.
The maximum maturity of any bond may not exceed forty years.
MELLO-Roos BONDS 191
SPECIAL FEDERAL TAX CONSIDERATIONS
The federal tax considerations that apply to a community facilities district are
identical to the tax considerations that apply to assessment districts. See "Assessment Bonds"
above.
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