Big Picture
The electronic newsletter from Federated Farmers Bees
Chairman's commentary
FEDERATED FARMERS BEES CHAIRPERSON, JOHN HARTNELL
Firstly an apology, the regularity of the BIG PICTURE has been poor in 2010, we will ensure this does not happen in 2011.
So here we are again, another season in full flow, the rain has arrived for many and I am sure this will be most welcomed by our white clover producers after a below average 2010 crop. Remember, give yourself options, honey in export quality drums will allow you to weigh up your selling choices.
The BIG question, where will prices sit for this year's crop, domestic buyers are rather silent, international buyers are reeling from their weak currency which ultimately drives up our selling price if we aim to maintain producers returns at least at last season's prices. To put this in perspective, the rise in clover export selling price in international currency between 2009/2010, was almost 40 percent, to maintain the same price this year a further 15 percent will be needed. One must ask, at what point will the buyers choke?
From a Federated Farmers perspective it has been a very busy year, with National Board duties, biosecurity issues on the table every month, Bee Products Standards Council (BPSC) and American Foul Brood Pest Management Strategy (AFBPMS) responsibilities and an earthquake or two just to test our resolve.
Special thanks must go out to Murray Rowlands, Federated Farmers North Canterbury Grains & Seed Chairperson, Carly and Shona Sluys and North Canterbury Federated Farmers Provincial President, Neil Stott, for their massive contribution over the first 30 days following the September 4 shake. Like the majority, we were underprepared for this event - a very valuable lesson learnt I am sure.
Over the last few months we have been receiving many international reports regarding clothianidin, an agricultural pesticide. Clothianidin is a neonicotinoid, a type of insecticide which disrupts the central nervous system of insects. There is rising concern in the United States that this chemical family is responsible for bee deaths and falling pollination effectiveness. Bee keepers there are calling for a total ban on this chemical family similar to one already in place in France. If the bee industry falters a third of the world's food is placed in jeopardy and we must ensure suppliers of such chemicals maintain strict quality control and people follow application instructions to the letter.
One key issue for industry is pyrrolizidin alkaloids (Pa) and their toxicity in Vipers Bugloss. This arose five or six years ago but was brushed under the table as ‘too hard'. Regretfully, the Japanese and EU Authorities have pulled it back out and it is firmly in full view. The BPSC have taken responsibility for this issue and are moving to appoint a project manager to get a three year toxicity test programme underway. The key question is whether Vipers Bugloss Pa is toxic, to what degree and why. Updates will be supplied as they become available.
Throughout 2010, we have maintained a very close working relationship with the National Beekeepers' Association. This is critical when key issues arise and Industry must be united. To this end we have recently meet with MAF Biosecurity New Zealand (MAFBNZ) in an effort to formalise a way forward, so the industry and MAF can overcome past issues and develop stronger working relationships. It is a work in progress but we are seeing positive intent. If communication is strong then many of the challenges faced will seem less frustrating.
Trees for Bees programme - after a very long process the Sustainable Farming Fund (SFF) bid was successful and the three year programme is underway.
As part of our commitment to this initiative we are seeking voluntary donations to fund the beekeepers contribution. A voluntary invoice will be sent to you in the New Year and we would appreciate your support.
To Bob and Shona, we thank you for another sterling effort throughout 2010.
On behalf of your executive and the Federated Farmers team, Christchurch, Timaru and Wellington, may we wish you, your family and friends a wonderful Christmas and bountiful New Year.
John Hartnell
Chairperson
Federated Farmers Bees
Phone: 03 349 5590
Fax: 03 349 5592
Mobile: 021 578 754
Email: john@hartnellnz.com
Industry news
NEW ZEALAND POLLEN TESTS POSITIVE FOR PSA
MAFBNZ has found that samples of New Zealand pollen collected from the Bay of Plenty and south Auckland have tested positive for the bacterial kiwifruit vine disease, Pseudomonas syringae pv actinidiae (Psa). This pollen was collected in 2009 and 2010.
There is no current evidence to show that Psa in pollen can infect healthy kiwifruit vines. MAF's initial analysis of infected orchards shows that many infected orchards have not used artificial pollination, suggesting other mechanisms of spread may be more significant. Response Manager, David Yard, says there seems to be no clear link between the use of artificial pollination and the spread of the disease.
MAF has also tested reference samples of New Zealand pollen collected in the last few seasons. Positive results from 2009 and 2010 samples, and ‘weak' positive results from 2007 pollen, indicate that Psa may have been present in New Zealand for a number of years. Further testing of historical samples will be carried out.
Earlier testing of imported Chilean pollen produced a single positive result, which may have resulted from contamination during the sampling process. Subsequent retesting has produced a ‘weak' positive result on a single sample. The implications of this result are still unclear; however testing of historical samples suggests that this pollen may not be the original source of infection.
On 14 November 2010, MAFBNZ advised growers, via the ZESPRI Canopy website, that pollen may present a risk of spread of Psa. MAF cautioned growers on the use of artificial pollination. If the use of artificial pollination is essential to a grower, using pollen collected on the same orchard presents a lower risk than pollen sourced from another property. Growers may wish to ensure that pollen used on their orchards is tested for Psa before they pollinate.
For more information regarding Psa, please click here.
IMPORTATION OF POLLEN INTO NEW ZEALAND
It now appears pollen has been imported into New Zealand for many years. Amazingly, New Zealand beekeepers were never consulted on this and most were unaware this was happening.
They were also unaware that imported pollen had been used on kiwifruit orchards prior to the Psa bacterium outbreak. It has not been restricted to kiwifruit with other plant pollens also permitted subject to Import Health Standard requirements.
The first import of commercial pollen from Chile was cleared by MAF in January 2009. Amounts ranging from one kilogram to 221kg have since arrived from Chile and China. The pollen was not tested for Psa. However, the pollen had been imported under conditions set down by MAFBNZ. For kiwifruit pollen, the import permit requires that the pollen is from hand-collected unopened flower buds. This is to mitigate any risk of contamination with any pests that could be deposited on to opened flowers.
From a bee industry perspective the untested pollen from high risk countries posed a serious question over import health standards, the pollen testing regime and the integrity of the phytosanitary certificates that accompany the pollen.
The importation of pollen was done under the MAFBNZ standard 155.02.06 - Importation of Nursery Stock, which says;
2.2.3 Importation of pollen - An import permit must be obtained from MAFBNZ prior to import. Prior to issuing the permit to import, MAFBNZ will assess, on a case by case basis, the requirements that must be met to import the pollen. All import requirements will be detailed on the permit to import.
You can find more information, by clicking here.
Questions need to be asked of MAFBNZ as to why consultation did not occur with the bee industry and why the importation of pollen was not included in the Bee Products Import Heath Standard. At no time was the imported pollen tested for bee diseases. So who is accountable and who should pay for the incursion response if another pest or disease enters the bee industry via this pathway?
MAFBNZ has asked to suspend artificial pollination. Due to biosecurity concerns and to check the potential spread of Psa, Federated Farmers is calling for kiwifruit ‘artificial pollination' to be suspended.
The Federation will further ask for all imports of pollen to be suspended, until MAFBNZ is able to certify imported pollen as being free of viruses and pathogens, not present in New Zealand.
Federated Farmers believes the precautionary principle needs to apply. That starts by ceasing artificial Kiwifruit pollination until the pollen, both domestic and imported, is certified clean.
It is possible that ‘artificial pollination' may have unwittingly spread Psa, as could the movement of contract harvesting machinery from orchard to orchard. This has not yet been determined, but that uncertainty is why the precautionary principle should be adopted.
On a more distressing note, who in their right mind would put at risk the New Zealand's bee industry? It is well recognised that more than 80 percent of all pollination world-wide, including Kiwifruit, is done by honeybees. To jeopardise this has massive implications and shows us how poorly respected our industry is from those who rely heavily on pollination outcomes.
The recent discovery of Nosema ceranae in the Coromandel is yet another major blow to the bee industry. Regretfully, MAFBNZ determined it was already ‘established' in New Zealand and no further action was warranted.
However, this begs the question if there is linkage between the importation of pollen over recent years and Nosema ceranae's discovery. One would assume it's unlikely but we may never know. And it's not as if we don't have evidence of the risk posed by pollen. MAFBNZ staff were authors of published an international paper in 2007, tellingly titled, Plant pathogens transmitted by pollen. It found that 39 plant viruses are pollen-transmitted, a further six were tentatively considered to be pollen-transmitted and a limited number of fungal pathogens. While that study was pretty much confined to vegetable crops, it confirms pollen as a biosecurity risk vector.
NOSEMA CERANAE PARASITE CONFIRMED IN NEW ZEALAND
Positive tests in both the North and South islands have confirmed that bee parasite Nosema ceranae (N. ceranae) is widespread in New Zealand.
MAFBNZ had its first ever detection of N. ceranae in New Zealand in Coromandel hives in September.
N. ceranae is a spore-producing parasite which infects adult bees causing Nosema disease which can reduce honey yields and bee populations.
It was found present in several apiaries belonging to an individual Coromandel beekeeper as part of a MAFBNZ investigation into bee deaths. The bee mortality has been attributed to parasitic mite syndrome, made worse by climatic conditions and ineffective treatment against mites.
MAFBNZ has decided there will be no attempt to contain N. ceranae (by movement controls imposed on beekeepers) as their information has told them it would not be effective in containing the organism. MAFBNZ's reasons for this is that they consider that imposing movement controls would come at a high cost to beekeepers in terms of inconvenience and lost pollination business at the peak of the pollination season. This cost has been balanced against the lack of benefits and can not be warranted. MAFBNZ considered containment in the Coromandel unfeasible
As well, MAFBNZ has decided that there is no gain in making N. ceranae an unwanted organism. They consider such an action would create unnecessary barriers to the beekeeping industry conducting their business - which relies on moving hives.
MAFBNZ believes N. ceranae has likely been in New Zealand for some time and could be well established. This is based on samples tested to date, hive movements in the past year and what is known about the organism.
New Zealand beekeepers already deal with nosema disease - it has been traditionally attributed to the very similar parasite Nosema apis which is thought to have been in New Zealand since the mid-1800s. Until molecular testing methods were recently developed, N. ceranae could not be effectively distinguished from N. apis. Since then N. ceranae has been detected in every country that has looked for it using new DNA-based molecular methods.
N. Ceranae is not a notifiable or OIE listed disease - therefore it will have no trade impacts for New Zealand.
MAFBNZ is completing analysing samples that have been collected from Coromandel over this week. Consideration is being given to continuing some surveillance of other areas in New Zealand for N. ceranae and options will be discussed directly with the bee industry.
If you have concerns about your hives ring the MAFBNZ 0800 hotline and they will send out sample kits for testing.
To link to the MAF website where you can find more information, please click here.
AUSTRALIAN HONEY UPDATE
The current situation: earlier this year MAF indicated that the Import Health Standard (IHS) for Australian honey will proceed based on work they are doing to satisfy the independent panel. This work should be completed by the end of the year and they expect the director general of MAF to be in a position to approve Australian imports by early next year.
MAF have stated that they have found two instances of the P.Alvei bacteria. The New Zealand Animal Health Reference Laboratory has been doing the testing. Samples of the findings could be sent to offshore facilities for further checking.
Nosema Ceranae has also been confirmed which now excludes this from use in the HIS challenge.
MAF are currently doing pilot surveillance for Israeli acute paralysis virus (IAPV). The findings have been negative so far but MAF says there is still more work to do on this front.
MAF says it is working closely with Australian regulators to ensure full compliance across the ditch with all aspects of the IHS before the honey leaves Australia. They have meetings planned for Feb 2011 to put in place detailed ‘verification systems'.
They will also be meeting with the BPSC here to discuss procedures in New Zealand for post-arrival checking of Australian products for country of origin compliance (to detect laundering) and to monitor residues.
Industry response: a steering committee has been formed to coordinate the industry's response. The committee comprises Daniel Paul, Steve Lyttle, Allen McCaw, John Hartnell, and Frans and Dennis Crowley. Russell Berry has also been invited to participate.
BIG and the NBA are working together on this issue to ensure a strong and unified industry response.
The committee has asked lawyer David Boldt to undertake the following:
- Examine the IHS to determine if there are new threats it does not cover (Asian honey bees), or does not cover adequately (Small Hive Beetle) and what can be done.
- Examine the IHS to assess if and how it conflicts legally with the PMS and what can be done about this. It must be a level playing field, no concessions for Australian beekeepers with regard to the AFBPMS.
- Provide a view on how the option for heat treating for 24 hours to 120 degrees could be made the only approval process for exportation of honey from Australia.
- Examine the independent panel's report to identify and understand its implications for MAF (what MAF's reporting obligations are).This will tell us what benchmarks MAF has to meet and where MAF might be potentially exposed.
MAFBNZ have just advised that the United States laboratory contracted to complete heat treatment testing has withdrawn and MAF have to find a new lab. It is likely it will now be well in to the second half of 2011 before a new lab service is secured.
Based on Mr Boldt's feedback, the steering committee will have all the relevant facts to make informed decisions about how best to proceed.
We will also be asking MAF to provide us with all their research around P. Alvei and other issues for peer reviewing and double checking.
We have met with Green MP, Sue Kedgley who has promised support. We are also arranging a meeting with Labour's Agriculture spokesperson, Damien O'Connor. We will also provide briefings to all other relevant MPs and officials.
However, the focus is to gather all the evidence we need in order to build a solid case against the importation of Australian honey products. This is where Mr Boldt's work will be so valuable.
TUTIN UPDATE - NEW STANDARD IN PLACE
From 1 January 2011, the Food (Tutin in Honey) Standard 2010, which can be found by clicking here, applies to all honey produced, harvested or packed for sale or export for human consumption. Further information about the standard is found in the 2010 Tutin Standard Compliance Guide, by clicking here.
Honey for sale or export must comply with the temporary limits for maximum levels of Tutin in honey and comb honey set in the Australia New Zealand Food Standards Code (Standard 1.4.1). The maximum level of Tutin in honey is 2 milligrams per kilogram and the maximum level of Tutin in comb honey is 0.1 milligrams per kilogram.
Beekeepers and/or packers of honey must ensure that they take appropriate measures to meet these limits which have been prescribed under New Zealand law in the form of Food Standards issued by the Minister for Food Safety.
MAXIMUM LIMITS FOR TUTIN IN HONEY - FSANZ
After consideration of draft variations for the following Applications and Proposal, Food Standards Australia New Zealand (FSANZ) decided to approve the draft variations. FSANZ has given the Australia and New Zealand Food Regulation Ministerial Council (Ministerial Council) written notification of these approvals:
- Proposal P1009 - Maximum Limits for Tutin in Honey
Once FSANZ has notified the Ministerial Council that it has approved the draft standard or variation, the Ministerial Council has 60 days to either request FSANZ to review the approved standard or inform FSANZ that it does not intend to request a review. Further information on the Ministerial Council process is available on the FSANZ website, clicking here.
VARROA NEWS
Please keep us updated with the spread of Varroa as being able to advise beekeepers in regions where Varroa has just arrived means they can then plan management requirements.
It has been advised that there have been considerable losses this spring as beekeepers adjust to Varroa. When in doubt put strips in as per the instructions on the packet. Do not half treat as this leads to a far greater risk of hive mortality.
BEE PRODUCT STANDARDS COUNCIL
The Council has agreed to implement honey standards on a voluntary basis from October 2010 and that further work is still required before they can be fully implemented.
It was agreed that the standards were well advanced for all except Manuka honey. The standards are now available as guidelines on the BPSC website under ‘Standards'.
The Council is working to get more laboratories involved in testing to give a good choice for this work. The laboratories will be listed on the BPSC website following the final BPSC meeting for the year.
It was noticeable that there conflicting methodology used by the laboratories, this has been redefined and all Labs are using the same assay to determine key markers in honey.
The standard for bio-active manuka will be subject to on-going review by the BPSC. A technical advisory group of active scientists has been established to provide advice on the known science and identify the scientific knowledge still required.
The Bee Product Standards Council now has its very own website. To keep up to date with the issues the council are dealing please click here.
Regional roundup
WEST COAST - GARY GLASSON
There was an AFB recognition course held on 18 September at Blackball. Many years had passed since the last course on the West Coast and it was well attended with 14 turning out on a very wet Saturday.
The weather in September was really wet with only two rain free days. We were putting cells out the day before the AFB course in what was described by the media as the biggest storm on the planet. When the weather improved and the bees which were suffering through September in some areas recovered.
The West Coast has been very dry during November. The bees have had a good go at the Kamahi that has flowered well this year along with the cabbage trees which have been very noticeable.
Extracting started early December three weeks earlier than last year and the honey season is showing a lot of promise. However, it is still early days yet, starting early could also mean we finish early. Varroa is wide spread now and we will be treating all of our hives this autumn.
NORTH CANTERBURY - GRAEME ALBON
After having survived the 4 September earthquake with minimal damage, only two beekeepers that I know of were hit to any mayor extent, the beekeeping industry in Canterbury has had a good spring and lead up to the honey flow.
Clover is well and truly coming in and looking like producing good volumes. Manuka is flowering well in the foothills and if the weather treats us right from now until the end of January we should have a good season. Honey Dew produced during spring with some beekeepers getting a crop - looking forward to a good autumn to produce a good crop. All this may not be enough though if exchange rates stay as high as they are. We will require a 15 percent increase in price, just to match last year's returns.
Once again there is demand for pollination hives and once again some seed producers are leaving it until the last minute to organise hives for pollination. It's not good enough. Show some respect to your beekeeper and organise pollination requirements early if you value your seed crops.
MID-CANTERBURY - JOHN SYME
Our hives were good coming out of winter. We have had a very wet and cold September. At the moment it is Queen rearing time and so far we have had good success.
Currently we aren't getting any surplus brood, we will have a lot more hives on carrots for pollination this season. So far the season is looking quite good.
SOUTH CANTERBURY - PETER BELL
The hives have come out of winter at average strength. We have had a good October on willow and dandelion and there will hopefully be good mating. The area is currently looking for some rain, but we are currently worried about Pa's in honey in the short term. In south Canterbury we are dealing with Varroa now as a normal part of our beekeeping practice.
NORTH OTAGO - MICHAEL VERCOE
This past winter has been the coldest and greyest for sometime. We shut down our hives light and early then in previous years and had to do lots of sugar feeding.
This spring we had a bit of a willow flow, with the dandelion flow helping a lot. Pollination wise we have struggled to get up to strength but we managed to get the cherries pollinated in the first two days. So far we have had good rain, with no frost. Unfortunately with Varroa now in the Queenstown/Wanaka area, all beekeepers should now be treating and everyone will need to treat in January.
The late spring was almost as good as it gets with the hives on a good dandelion flow building well. Those that chase the thyme appear to have good a reasonable crop.
Central Otago is now looking like a painted canvas and is just as dry. The Maniototo has faired a little better some coastal rain on a few days, with the driest period still to come its not looking good. Southland is a green as and farmers have heaps of grazing, so hopefully with some warmth beekeepers will get a good flow there.
Opinion
FOOD FOR THOUGHT – GRAEME ALBON
When learning how to deal with varroa we were told, you do not extract honey produced while treatment is in hives. It worries me that many beekeepers are ignoring this advice and extracting honey collected while treatment is in hives. Yes it's true to say, residue has not shown up in honey ... yet. Sooner or later someone will get stung, which will leave a large volume of crop unsalable.
Many beekeepers feed large amounts of sugar but at what cost? Taking into account the cost of sugar, the feeders, syrup tanks and gear, wear and tear on vehicles and time and labour it adds up to a real expense.
Perhaps if beekeepers separated the varroa treated honey as feed and used it instead of sugar they might not be so out of pocket by not selling it. Which leads me to another point - if you use this system of management, as I do, you will find that you have more feed than you need.
Is there a market out there for surplus honey as a molasses type of animal management feed supplement? This is an area which needs investigation. The more market opportunities we can create, the better.
Advice
TREES FOR BEES
The Trees for Bees guides consist of a series of 10 regional fact sheets, which indicate the shrubs and trees that are known to keep bees healthy with nutritious pollen and nectar. The guides aim to stop our bee population from declining further by informing farmers about what they can do to support and protect our threatened honey bee population. If you would like a copy of one of the guides, please click here or contact policy advisor, Shona Sluys, by clicking here.
ABANDONED HIVES
Federated Farmers Bees would like to know if you have neglected or abandoned hives on your property. Managing bee disease is vital for the ongoing sustainability of beekeeping and pollination services. The American Foul Brood Pest Management Strategy requires that all beehives are registered and apiary details are recorded on the national database. Please assist us by calling 0800 327 646 or emailing details of any neglected or abandoned hives, by clicking here. Alternatively, you can fax your report to 03 357 9451.
Suspect an exotic disease or pest? Then phone 0800 80 99 66
It is important if you suspect an exotic pest or disease that you phone the Ministry of Agriculture and Forestry's (MAF) Exotic Disease and Pest 24 hour emergency hotline on 0800 99 66. That way MAF Biosecurity can investigate and advise as necessary. All calls are kept in confidence.
FEES AND CHARGES
The new ‘Fees and Charges' web page is accessible from the MAF Biosecurity New Zealand homepage, by clicking here. On this page are links to a wide range of fees and charges for services provided by MAF, links to applicable legislation, and a link to the New Zealand Customs Service costs recovery web page.
NEW ZEALAND FOOD SAFETY UPDATES
The following notices are updates in regards to NZFSA requirements:
- Animal Products (Harvest Statement and Tutin Requirements for Export Bee Products) Notice 2010 (Effective from 1 January 2011)
- Statement for the Transfer of Exports Bee Products between Export Premises (Effective from 1 January 2011)
- Apiarist and Beekeeper Statement for the Harvest of Honey and other Bee Products for Human Consumption (Effective from 1 January 2011)
- Animal Products (Harvest Statement and Tutin Requirements for Export Bee Products) Notice 2009 No 2
- This notice has been amended to revise clause 15 for the purposes of clarity. Bees - apiarist and beekeeper statement for the harvest of honey or other products for human consumption
Notices
Your notices
If you have a meeting notice you would like to advertise in the BIG Picture, please contact policy advisor, Shona Sluys, by clicking here or by calling 0800 327 646.
Training and education
FEDERATED FARMERS LEADERSHIP PROGRAMME 2011
Are you interested in becoming more involved in your community? Have you ever considered building your leadership skills to influence and inspire others? If this sounds like you, then we want you on our leadership programme. Federated Farmers is committed to growing new agricultural leaders and offers a two part leadership training opportunity. Our level one course, Getting Your Feet Wet, provides an introduction to agricultural policy and advocacy and is to be held next from 23 - 24 February 2011. Our level two course, Shining Under the Spotlight, offers a challenging and positive environment to practice your presentation skills and strategic thinking. The next Shining Under the Spotlight course will be held 6 - 7 April 2011. Both courses are run on site from the Federated Farmers Wellington office. To register on a course, or for more information, email events@fedfarm.org.nz or phone 0800 327 646. Our courses fill quickly so registering early will ensure you're not disappointed.
ENROL FOR ALL YOUR 2011 AGRICULTURE ITO COURSES NOW
Don't forget that you can enrol in next year's courses now, as trainees who are able to enrol and pay for their upcoming courses in 2011 before 24 December 2010, will pay at the current fee price. Agriculture ITO would also like to remind all prospective and current trainees that it will be closed from midday Friday, 24 December until Monday, 10 January. The industry training organisation looks forward to working with you in 2011, as it's going to be a great year for training! Remember, to find out more about this course and many more, contact an Agriculture ITO training advisor on 0800 691 111 or visit www.agricultureito.ac.nz.
Member benefits
ARE YOU PREPARED FOR THE HOLIDAYS?
For all your Christmas wine orders, visit Winesonline.co.nz. Winesonline.co.nz has a fantastic selection of bubbles, white and red wines to see you through Christmas and New Years, and as always, something for everyone's palate and wallet. To view all these great wine offers, just go to www.winesonline.co.nz.
RAVENSDOWN FLYSAFE®
Trust Ravensdown to protect your sheep from flystrike with new Flysafe® Liquid and Flysafe® Spray-On. Call 0800 100 123 for more information.
More member benefits and offers
To view special discounts exclusive to Federated Farmers members, please call 0800 327 646 or click here to log onto our members only area.
Recruitment
NEW MEMBERS WELCOME
Federated Farmers Bees are always looking for new members. As with any organisation or group there are meetings and opportunities to participate in discussion groups as well as having your say on the future of beekeeping in New Zealand, there are plenty of challenges ahead. So if you know someone that may like to join Federated Farmers Bees, please recommend them to us. As you know our best referrals come from our members, so if you do introduce a new member, you will receive a $50 petrol voucher as a thank you for the work you do.
Contacts
Contact us
If you have any questions or comments about matters in this newsletter, or anything else relating to the bee industry, please contact the Bee Industry Group executive or committee by clicking here. Alternatively, you can contact policy advisor, Shona Sluys, by clicking here or by calling 0800 327 646.



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