North Lanarkshire Federation of Tenants and Residents Associations Tenant Scrutiny Capital Programme Kitchen Replacement Sub Group Findings Report October 2015 1 1.0 1.1 Introduction North Lanarkshire Federation of Tenants and Residents Associations (NLF) is pleased to submit our Tenant Scrutiny (Capital Programme) Kitchen Replacement Sub Group report to North Lanarkshire Council’s (NLC) Senior Management Team and Elected Members for their information. 2.0 2.1 Background In response to the introduction of the Scottish Social Housing Charter (SSHC) and to continue to develop the Federation’s working relationship and influence with the Council’s Housing Service, the NLF established a Tenant Scrutiny Group to inspect the Kitchen Replacement element of the Capital Programme. 2.2 NLF invited representatives of our member groups and individual tenants to participate in this scrutiny group to encourage representation from across the authority. 2.3 The Kitchen Replacement Tenant Scrutiny Group members are: Gordon Encinias Irene Gillies Mary McLellan 2.4 In terms of NLC, the main staff representatives participating with the sub group were agreed as Michelle Hendry and Elaine Munroe. 2.5 Independent advice and support was provided to the sub group by Nancy Robertson, Development Officer from the Tenants’ and Residents’ Participation Project, a Tenant Information Service Project (TIS). 3.0 3.1 Tenant Scrutiny in Context Tenant scrutiny is about tenants being actively involved in reviewing how housing services are being delivered, and even more importantly, how they can be improved. The concept of scrutiny is not new in Scotland and has existed in other social policy fields such as education for some time. However, the emphasis on tenant scrutiny and self-assessment is new to the social housing sector here in Scotland and represents a very significant opportunity to develop partnership working between tenants and landlords to deliver excellent housing services. 3.2 Tenant Led Inspections (TLIs) are a popular way of involving tenants in improving housing services. This is a process where tenants independently inspect a housing service to review how well it is working and to identify recommendations for improvements. It is a tangible way of involving tenants where everyone can see positive results at the end of the process. Tenant Led Inspections provide opportunities to: Inspect housing services from a tenants’ perspective Hold service providers to account Contribute to improvement in housing services, whilst ensuring policies and procedures are clearly understood and implemented Inform policy development and delivery 2 Ensure resources are used effectively and services delivered provide value for money Benchmark and share good practice 4.0 4.1 Aim of the Kitchen Replacement Sub Group The overall aim of the scrutiny sub group work was to provide an opportunity for tenants’ representatives become more informed of the operation and delivery of the Council’s kitchen replacement programme, to discuss issues, concerns and progress raised by tenants and contribute to continuous improvement in service delivery. 5.0 5.1 The Inspection Process The Tenant Scrutiny Kitchen Replacement Sub Group followed an agreed work plan, which included: Understanding and reviewing the kitchen replacement in terms of the capital programme. Understanding the policies and procedures involved in the kitchen replacement programme Making comparisons across all of the contractors involved in the kitchen replacement programme. Circulation of an independent survey to a sample of tenants across North Lanarkshire 1-2-1 Meetings with tenants who have had new kitchens installed 3 6.0 Findings and Recommendations 6.1 Discussions at meetings A Findings Does the Clerk of Works issue a checklist to tenants at mid - work and final inspection stages? Recommendation That the Project Liaison Officer carry out a visit and speak to tenants during the works and at the end before the final inspection takes place and liaise with Clerk of Works as required. That the final inspection is signed off by the tenant and Clerk of Works Tenants receive a copy of the signed off final inspection checklist. Housing Property comments Procedures are currently in place to help and support tenants through the process, including explaining technical matters in more detail. A number of changes have taken place within Property, including the introduction of Programme Liaison Officers, known as PLO’s. The PLO’s role is to guide tenants through the whole process and offer additional support as and when required, based on individual circumstances. At the end of the process, when the kitchen has been installed, the PLO will visit the tenant to discuss their experience of the process in terms of customer satisfaction. There is no tenant sign off required by tenants at present; however this may be looked in the future. The PLO role is in addition to the Clerk of Works, as they carry out different roles. The Clerk of Works carries out a more technical role for the duration of the programme. The Clerk of Works is responsible for carrying out a final inspection and to sign off the contractors work as complete and satisfactory. A checklist has recently been introduced to assist the Clerk of Works when signing off a property. B The sub group found that in some NLC should provide /offer families a full size instances the supply of a small baby microwave and where a baby belling cooker belling cooker as means of cooking is the option then two 2 ring baby belling while the work is being carried out, cookers should be supplied if required. isn’t adequate. Housing Property comments The contractor is responsible for ensuring that tenants are offered temporary cooking facilities for the duration of the programme. Current arrangements include the provision of either a Baby Belling cooker or a microwave cooker. Individual circumstances are taken into consideration at the beginning of the process to ensure that tenants are offered suitable cooking facilities that meet their needs. In terms of supplying two Baby Belling cookers, Health and Safety issues need to be taken into account when identifying a site for a temporary cooker and adjoining workspace. Unfortunately there is some disruption to the living space during the kitchen installation which would make it more difficult to place 2 cookers. The PLO’s will consider individual needs such as respite and/or other support needs. 4 C The group note that baby belling cookers are portable and are therefore ‘moveable’ and feel that for this reason this is often not a suitable option. That tenants can’t be left with no means of cooking and should be able to make choice from various types of temporary cooking facilities available and to suit their personal choice and circumstances, particularly where the tenant is elderly or there are young children in the house. Housing Property comments The contractor is responsible for ensuring that tenants are offered temporary cooking facilities for the duration of the programme. Current arrangements include the provision of either a Baby Belling cooker or a microwave cooker. If work needs to stop at the weekend and start again on a Monday then cooking facilities can be re-instated. This will be reviewed on a case by case basis. Individual circumstances are taken into consideration at the beginning of the process to ensure that tenants are offered suitable cooking facilities that meet their needs. D E The sub group considered it was good that NLC ensured SHQS as a minimum standard, but found that kitchens are installed to suit current tenant and therefore not necessarily what they considered as ‘future proof’ i.e. what suits current tenant might not suit future tenants. The sub group noted that it could prove too difficult for NLC to ‘future proof’ kitchen designs/items for future tenants. That NLC considers ensuring the minimum number of units are installed to ensure that kitchens will meet the basic needs of future tenants and not just current tenant. Alternatively NLC ensures that if required additional units are installed for a new tenant to bring the number of units up to the minimum standard. NLC continues to ensure all kitchens meet the SHQS as a minimum standard. Housing Property comments The kitchens are designed around the needs and requirements of the current tenant. However if in the future there was a change in tenant and they required some adjustments to meet their individual needs, this would be assessed and minor works carried out accordingly. Current and future SHQS standards and Energy Efficiency Standards, required by 2020, are continually reviewed. The sub group found that in some NLC should provide information on how to instances tenants had to make make a claim for any damages that might claims for damage to their occur during the works. household items and/or flooring and Tenants should be informed and advised that often tenants were unsure how to do there is a system in place that means they this or they weren’t aware that they can submit a claim for damage where they could submit a claim. think this is appropriate and necessary. Perhaps a form included in the info leaflet or via the PLO or the Clerk of Works. 5 F Housing Property comments To ensure that tenants are made aware that they can make a claim for damage caused during the programme, a recommendation has been made that this will be included in the information leaflet for the Kitchen programme. The leaflet ‘Kitchen replacement programme advice and Information’ is issued to all tenants at the start of the programme. The leaflet is currently under review in order to improve on the content and the information given to tenants. The sub group noted tenants aren’t The sub group recommends that more info is given info regarding how walls will given to tenants regarding this as they feel be made even/flat and how this will that there could be an assumption that the be done. walls will be plastered, when in fact it’s often In instances where a brace & board brace boards that are fitted. are used this makes the floor size Recommend that tenants are advised that the slightly smaller, which could cause a brace & boards system will reduce floor problem with fitting furniture or white space. goods back in place or when buying The sub group asked that this info is included new items. in the information booklet. Housing Property comments During the kitchen installation, additional work may be required, including the ‘sheeting’ of walls, which can however slightly reduce the size of a room. Unfortunately this decision can only be made once the old units have been removed from the walls. To ensure that tenants are made aware of the process and what may be involved, a recommendation has been made that this will be included in the information leaflet for the kitchen programme, which is currently under review. Where homes are being re-wired G the sub group found that in some instances access to electrical sockets in adjacent rooms was required and found that often this was where tenants had stored furniture/white goods (etc.). This should be checked and noted at the preinspection check and tenants should be advised accordingly. In addition the sub group recommends that there should be options regarding the use of trunking/conduit for wiring. In some instances the group felt this should only be used where absolutely necessary - but in others perhaps this could be tenant choice. NLC should ensure that tenants are fully advised of the options to allow tenants consider what is best for them, particularly if it means that laminate/wooden flooring doesn’t need to be lifted. Housing Property comments In line with current procedures the contractor will carry out a pre-inspection check before any re-wiring works are carried out to assess what work is required. However the PLO will visit the tenant before any works are carried out to explain what is involved during each stage of the installation process, including any rewiring, and will be in a position to support the tenant through the process. 6 H The Clerk of Works will visit the property at various points during the installation and is available to respond to any technical questions that tenants may have. Currently surface mounted trunking is not being used as part of kitchen installation contracts therefore where the tenant has laminate/wooden flooring the tenant is required to lift this to allow the rewiring to be carried out. The PLO will discuss this with tenants on an individual basis, to assess if further assistance/help is required for the tenant. The sub group also notes that the NLC should offer tenants the choice of box type sockets can cause flat/flush sockets and tenants are consulted problems when putting furniture about what would suit them best. back in place. Housing Property comments Where wiring upgrades are being carried out, single sockets are being replaced with twin sockets. A conversion box is secured over the existing back box for the single socket hence it sits ‘proud’ of the wall adding 15mm in depth to the fitting. The use of a conversion box eliminates any disturbance to the tenants’ decoration. I It was noted that the samples of colour for grouting for tiling is not always what is actually installed. If only white grouting to be used then only this should be shown in samples. Alternatively NLC should perhaps consider finishing with dark coloured grouting if this is the tenants preference. Housing Property comments – The suggested change of grouting colour will be considered as part of the current kitchen and bathroom tenant consultation processes. In relation to the current ‘sample boards’, these will be reviewed to ensure tenants are only shown samples of materials that would be available to them and installed within their homes. J The sub group found situations where works starts on a Friday and stops over the weekend to recommence on a Monday (there was also situations of this happening over a holiday weekend meaning the work started on a Thursday and recommenced on the following Tuesday). This is a long time for tenants to have inconvenience and upheaval. Housing Property comments – The sub group recommends that this is unacceptable and recommends that work does not start on a Friday (or on a Thursday at holiday weekends); or alternatively the work continues until on a rolling programme until it is complete. As per current arrangements, the council’s contractors have been advised not to commence new kitchen installations on a Friday particularly where the tenants are elderly, have a disability or have other specific additional needs. In terms of the contractor working 7 days per week, this would have a significant impact on the council’s budgets. 7 K 6.2 A B The current budgets are based on non weekend working. However this recommendation will certainly be considered as part of the new contract framework arrangements. The sub group noted that in their There needs to be exact samples/ sample own experience samples shown are boards and these need to be exactly as the not exact, nor are they as the final finished product. product The sub group suggests that samples need code numbers and tenants should be given this information so that they can check this at the installation stage. Housing Property comments The council’s contractor is responsible for providing sample boards to tenants displaying the range of options available to them in relation to units, worktops and handles. The contractor will take these to the tenant’s home when they are designing the kitchen with the tenant, in order for the tenant to select what they want. The final drawing, which details the choices made by the tenant, is recorded on the kitchen design drawing which is signed by the tenant and a copy given to them. Both the Clerk of Works and the PLO visit all properties at the installation stage, and any errors in relation to colour choices etc, would be identified very quickly and resolved with the contractor. NLC will continue to monitor this. Info Booklet Findings Recommendation The sub group felt that the booklet NLC changes the wording to note the actual isn’t too clear regarding the number number of working days for the work to be of days it takes to carry out the work carried out and say this includes small from start to finish (page 6). finishing works. Housing Property comments The wording in the booklet ‘Kitchen replacement programme advice and Information’ states ‘We estimate the works will take about 5 days but you should allow a further 5 days to carry out small finishing works, council staff inspecting the works and time for any snagging items the contractor needs to complete’. This booklet is currently being reviewed, this recommendation will be included as part of that review. The sub group felt that perhaps the The sub group asks that photos of real photos used in the booklet are not kitchens are used and/or there a disclaimer as the finished product. added to say that photos are for reference only. Housing Property comments The photos currently used in the booklet are examples of kitchens that have been previously installed by the council. No other photos are used for publicity purposes. 8 6.3 Survey Questionnaire A Findings One of the findings was that there had been no response to a complaint. Recommendation The sub group asks that NLC respond to all complaints regardless of how small and that this is done timeously. The sub group recommends that a job number should be given and details of who to contact or speak to with regards follow up e.g. PLO’s Housing Property comments The new PLO’s will be able to assist with this; If a tenant is experiencing any difficulties, they should initially highlight this to their PLO, who may be in a position to resolve the issue for them timeously or offer appropriate advice or assistance. However if required the council does operate a formal complaints procedure, in line with the Public Services Reform (Scotland) Act 2010. All complaints are responded to and progressed in line with relevant timescales. Please see attached link to the complaints procedure. http://www.northlanarkshire.gov.uk/index.aspx?articleid=1161 B The sub group found that one tenant reported that it they had difficulties in getting the small jobs done after the installation took place. The sub group recommends that the ‘small jobs’ should be included in the signing off of the works and that tenants should be advised of this. The sub groups asks that NLC consider that this should be part of the service carried out by the new Project Liaison Officers (PLO). The sub group recommends that the PLO’s work with tenants to ensure that all small jobs are completed and that they keep in contact with tenants to track the progress of these jobs. Housing Property comments Procedures are currently in place to help and support tenants through the process, including explaining technical matters in more detail. A number of changes have taken place within Property, including the introduction of Programme Liaison Officers, known as PLO’s. The PLO’s role is to guide tenants through the whole process and offer additional support as and when required, based on individual circumstances. At the end of the process, when the kitchen has been installed, the PLO will visit the tenant to discuss their experience of the process in terms of customer satisfaction. The PLO role is in addition to the Clerk of Works, as they carry out different roles. The Clerk of Works carries out a more technical role for the duration of the programme. The Clerk of Works is responsible for carrying out a final inspection and to sign off the contractors work as complete and satisfactory. A checklist has recently been introduced to assist the Clerk of Works when signing off a property C The sub group found instances of the contractor not keeping the time frame and tenants not being The sub group recommends that Contractors need to keep to the time frame as much as possible. The sub group understands that 9 informed as to why or given information on how much longer the work would take. D E F often there can be legitimate reasons for a delay but recommends that tenants are advised of any delay and given information on any subsequent new timescale for the work. The sub group felt that it’s important that workmen aren’t taken away from one contract and moved to work on another as can result in delays. Housing Property comments The council’s contractors currently decide on how they can best utilise their workforce to achieve planned completion timescales, however these are continually monitored by the Clerk of Works to ensure delays are kept to a minimum. The PLO will keep in contact with tenants throughout the kitchen installation. The sub group found that often The sub group would recommend that the problems raised are not dealt with new PLO’s liaise with tenants and contractor quickly or to tenant’s satisfaction. to ensure that problems are dealt with quickly and that tenants are satisfied with the outcome. Housing Property comments The PLO and Clerk of Works will liaise with tenants on a daily basis during the installation period, in person and by phone, to ensure any issues are dealt with as soon as possible should they arise. In relation to customer satisfaction levels, these are monitored each month and appropriate action taken where necessary. The sub group found that there Again the sub group would recommend that needs to be a little more the PLO’s should provide a point of contact communication from tradesmen and for tenants and should communicate and more support from contractor. liaise with tenants and contractors. Housing Property comments The PLO and Clerk of Works will liaise with tenants on a daily basis during the installation period, in person and by phone, to ensure any issues are dealt with as soon as possible should they arise. The PLO and Clerk of Works will also liaise with the contractors on a daily basis. Single points of contact via a Freephone number and a single email address have been set up to improve communication for tenants with the Clerk of Works and PLO teams. The sub group found an instance The sub group would like information on any where someone was waiting for an legal requirement in terms of signing off electrical check two weeks after electrical works and would suggest that work was complete. electrical works are tested by an electrician as part of the works, and is this included in the signing off by the Clerk of Works (CoW). Housing Property comments This finding relates to one property. Electrical safety is of paramount importance to North Lanarkshire Council. As a result of a recent audit, improvements have been put in place to ensure that an Electrical Test Certificate is received for each property following the kitchen installation. 10 The sub group found that tenants The sub group recommends that NLC G seemed very happy with the final continue to install good, quality fitments and result and were in the main very keep the kitchens to a good standard and pleased with the quality, layout and ensure that the work to install the kitchens is improvements in the finished also carried out to a good standard. kitchen. Housing Property comments Housing Property operate a process of continuous improvement to ensure a high standard of service delivery. 6.4 A 1-2-1 Meetings (Home Visits) Findings The sub group found that there can be a lot of waiting about for contractor. Recommendation The sub group asks that NLC ensure that contractor arrives on time every day and as much as possible doesn’t keep tenants waiting for the work to be carried out. Housing Property comments The council’s Contractors are aware of the service standards expected from them, which includes keeping to arrangements made with tenants. Tenant satisfaction levels are monitored each month, and action taken where necessary. B It was reported that there was instances when the contractor arrived when they wanted to and arrived very early in the morning (at 7am), and that the tradesmen kept going away and coming back again. The sub group understand that it’s not unreasonable for work to start early in the day. However, the sub group recommends that an 8.00am start is more acceptable, unless it suits the tenant for the work to start earlier, and if work needs to start later then this should be considered. The sub group recommends that there should be as much flexibility as possible to suit tenant’s needs. Personal circumstances should be considered; such as in the cases of families where there are young children heading out to school and it’s a busy period in a household, where someone is working or in some circumstances there might be a health issue. The sub group recommends that this information is the kind of information the PLO’s could hold and could ensure that if need be it could be that the work starts a bit earlier or later in the day. 11 C D E Housing Property comments Individuals tenant’s circumstances are discussed at the start of the process and taken into consideration when making access arrangements for the contractor. Contractors are aware of the service standards expected from them, including keeping to arrangements made with tenants. The sub group found that there can The sub group notes that this information be misinformation given to tenants, is contained in the Info booklet given out such as tradesmen advising that to tenants. there is no decoration allowance. The sub group recommends that tenants should be referred to the hand book for info; and should be able to discuss any questions they may have with the PLO’s and that the tradesmen shouldn’t be giving out this kind of information and should advise tenants to speak to PLO’s/CoW/Office for any information they need. Housing Property comments The booklet ‘Kitchen replacement programme advice and Information’ is given to all tenants when a kitchen is being replaced. This booklet is currently being reviewed, this recommendation will be included as part of that review. The PLO will remain in contact with tenants for the duration of the programme and can support and advise tenants on a variety of issues including the Disturbance/Decoration Allowance process. It was reported to the sub group that The sub group understand that this is not the tradesmen could do more with always the case, and recognises this will regards tidying up after their work, differ between tradesperson to that they only made a very small tradesperson, contractor to contractor effort and that there was a lot of and tenant to tenant. dust – more than expected. The sub group feels that whilst it may seem that everyone would understand that with this type of work there is going to be a lot of dust they note that perhaps it does need saying and recommends that there’s a bit more info in the booklet with regards general mess. The sub group recommends that contractors must ensure that dust sheets are supplied and in place, and that tenants are made fully aware of this. Housing Property comments The booklet ‘Kitchen replacement programme advice and Information’ is given to all tenants when a kitchen is being replaced. This booklet is currently being reviewed, this recommendation will be included as part of that review. The sub group found that often The sub group thinks this will be covered tenants don’t know if they’ve seen through previous point as noted at 6.1 A 12 the Clerk of Works in terms of the work being reviewed/signed off. Housing Property comments As detailed in 6.1, The Clerk of Works is responsible for carrying out a final inspection and to sign off the contractors work as complete and satisfactory. A checklist has recently been introduced to assist the Clerk of Works when signing off a property. F The sub group were advised that The sub group feels that this goes there needs to be care and without saying and that all due care and consideration of tenants floor attention needs to be in place at all times covering and white goods. by all tradesmen and all contractors. Housing Property comments The contractor is responsible for taking as much care as possible to protect tenants’ floorings and white goods while carrying out the works. This is monitored by the Clerk of Works. However if there are any individual concerns, tenants can raise these issues with the Clerk of Works or the PLO to look into and take any appropriate action. A copy of the checklist can be made available. G The sub group found a report of a The sub group finds that this is baby belling cooker that wasn’t unacceptable and recommends that NLC clean being delivered to a tenant. must ensure that all temporary equipment given to tenants while the work is ongoing is/are clean and ready to use. Housing Property comments The contractor is responsible for providing the tenant with temporary cooking facilities for the duration of the works. These facilities should be cleaned between each use and each receive an electrical PAT test before use. This is monitored by the Clerk of Works and the PLO and should any issues arise due to the cleanliness of the equipment the Clerk of Works or PLO will take appropriate action to remedy the situation. H The sub group found that tenants The sub group recommends that NLC are happy with the quality of the continues to provide a high standard of fittings. quality fittings in future kitchen programmes. Housing Property comments Housing Property operate a process of continuous improvement to ensure a high standard of service delivery. A specification review of the kitchen is being undertaken as part of our tenant engagement programme with the NLF. I The sub group found that in the responses they gathered tenants were happy with the finished job and that tenants felt they had been involved in the design stage and that they received a copy of the design. The sub group recognises the effort made by NLC and contractors to ensure this is the case and would recommend that NLC continues to provide a high level of service to all tenants. 13 Housing Property comments Housing Property operate a process of continuous improvement to ensure a high standard of service delivery. A specification review of the kitchen is being undertaken as part of our tenant engagement programme with the NLF. J The sub group received good reports about the Residents Liaison Officer and received some comments to say that the tradespersons were very good. The sub group recognises that there is a good service provided and recommends again that NLC endeavours to ensure this standard is delivered across the board. Housing Property comments Housing Property operate a process of continuous improvement to ensure a high standard of service delivery. A specification review of the kitchen is being undertaken as part of our tenant engagement programme with the NLF. 7.0 Other issues considered by the Capital Programme Replacement Sub Group and NLF in relation to tenant scrutiny Kitchen 7.1 Data Protection rules were a bit inhibiting at times; particularly in this type of scrutiny where the need to contact tenants is crucial. The sub group members and the Federation understand the need for Data Protection and that the Council must abide by these rules. However this meant that the sub group relied on NLC to contact people for visits and surveys with no input or choice from the sub group which in turn affects the ‘independence’ of tenants and the Federation in this type of scrutiny activity. The Sub Group and the Federation would recommend that NLC looks at how other local authorities and registered social landlords have addressed this issue. 7.2 The sub group considers that it’s important that NLC staff are given the time and the resources to carry out scrutiny activity work. The sub group feels that it’s important that this is seen as a part of people’s work and isn’t an ‘add – on’. 7.3 The sub group feels that it is difficult to put a specific timescale on a scrutiny topic or subject and the subsequent activity. For future reference perhaps there needs to be a mid-term evaluation of where the scrutiny as at, what progress has been made and redefine timescales accordingly to allow scrutiny groups to change direction or course if this is required. 7.4 The sub group recommends that future scrutiny groups give thought to the various options and ways of gathering information; the group recognises that without hindsight it’s perhaps difficult to do this but it would be good for groups not to go through processes that don’t bring the results groups need. The sub group members feel that in the instance of this particular type of scrutiny, telephone calls, mystery shopping or street surveys when and where a kitchen replacement installation was in progress might have been useful, would have brought results, and would have assisted with the issues around data protection. 14 Other issues – Housing Property comments Data Protection Data Protection legislation provided protection for tenants against their details being shared without the tenants’ agreement. An agreement was reached with the Capital Programme Kitchen Replacement Sub Group that the North Lanarkshire Council would write to tenants on the group’s behalf. The group were advised which towns both contractors were working in and made a choice as to which tenants should be contacted. Over 100 tenants were contacted in writing, however, the response from tenants, willing to participate in the Scrutiny activity, was less than 5%. Housing Property support the recommendation that future scrutiny groups should give thought to the various options and ways of gathering information; with early planning and consideration on what might work best in different types of scrutiny activity. 8.0 8.1 Next Steps NLF considers the content of the report 8.2 NLC considers the content of the report and responds to the Capital Programme Kitchen Replacement Sub Group and NLF regarding the findings and recommendations. 8.3 NLC develops and action plan in partnership with the sub group and NLF to agree and implement agreed improvements. 8.4 NLC meets with the sub group in 12 months’ time to monitor and review the action plan. 9.0 Appendix 9.1 A summary report of the results of the questionnaire issued by the group is attached. 15
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