DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
14 CFR Part 39
[Docket No. FAA-2020-1120; Project Identifier 2019-SW-056-AD]
RIN 2120-AA64
Airworthiness Directives; Goodrich Externally-Mounted Hoist
Assemblies
AGENCY: Federal Aviation Administration (FAA), DOT.
ACTION: Supplemental notice of proposed rulemaking (SNPRM).
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SUMMARY: The FAA is revising a notice of proposed rulemaking (NPRM)
for
various model helicopters with certain part-numbered Goodrich
externally-mounted hoist assemblies (hoists) installed. This action
revises the NPRM by adding a figure and revising certain requirements.
The FAA is proposing this airworthiness directive (AD) to address the
unsafe condition on these products. Since some of these actions would
impose an additional burden over those in the NPRM, the agency is
requesting comments on this SNPRM.
DATES: The FAA must receive comments on this SNPRM by November
1, 2021.
ADDRESSES: You may send comments, using the procedures found in
14 CFR
11.43 and 11.45, by any of the following methods:
Federal eRulemaking Portal: Go to https://www.regulations.gov. Follow
the
instructions for submitting comments.
Fax: (202) 493-2251.
Mail: U.S. Department of Transportation, Docket
Operations, M-30, West Building Ground Floor, Room W12-140, 1200 New
Jersey Avenue SE, Washington, DC 20590.
Hand Delivery: Deliver to Mail address between 9 a.m. and
5 p.m., Monday through Friday, except Federal holidays.
For Goodrich service information identified in this SNPRM, contact
Collins Aerospace; 2727 E Imperial Hwy., Brea, CA 92821; telephone
(714) 984-1461. You may view this service information at the FAA,
Office of the Regional Counsel, Southwest Region, 10101 Hillwood Pkwy.,
Room 6N-321, Fort Worth, TX 76177. For information on the availability
of this material at the FAA, call (817) 222-5110.
Examining the AD Docket
You may examine the AD docket at https://www.regulations.gov by
searching for and locating Docket No. FAA-2020-1120; or in person at
Docket Operations between 9 a.m. and 5 p.m., Monday through Friday,
except Federal holidays. The AD docket contains the NPRM, this SNPRM,
the European Union Aviation Safety Agency (EASA) AD, any comments
received, and other information. The street address for Docket
Operations is listed above.
FOR FURTHER INFORMATION CONTACT: Kristi Bradley, Aerospace Engineer,
General Aviation & Rotorcraft Section, International Validation Branch,
Compliance & Airworthiness Division, FAA, 10101 Hillwood Pkwy., Fort
Worth, TX 76177; telephone (817) 222-5110; email
kristin.bradley@faa.gov.
SUPPLEMENTARY INFORMATION:
Comments Invited
The FAA invites you to send any written relevant data, views, or
arguments about this proposal. Send your comments to an address listed
under ADDRESSES. Include "Docket No. FAA-2020-1120; Project Identifier
2019-SW-056-AD" at the beginning of your comments. The most helpful
comments reference a specific portion of the proposal, explain the
reason for any recommended change, and include supporting data. The FAA
will consider all comments received by the closing date and may again
revise this proposal because of those comments.
Except for Confidential Business Information (CBI) as described in
the following paragraph, and other information as described in 14 CFR
11.35, the FAA will post all comments received, without change, to
https://www.regulations.gov, including any personal information you
provide. The agency will also post a report summarizing each
substantive verbal contact received about this proposed AD.
Confidential Business Information
CBI is commercial or financial information that is both customarily
and actually treated as private by its owner. Under the Freedom of
Information Act (FOIA) (5 U.S.C. 552), CBI is exempt from public
disclosure. If your comments responsive to this SNPRM contain
commercial or financial information that is customarily treated as
private, that you actually treat as private, and that is relevant or
responsive to this SNPRM, it is important that you clearly designate
the submitted comments as CBI. Please mark each page of your submission
containing CBI as "PROPIN." The FAA will treat such marked
submissions as confidential under the FOIA, and they will not be placed
in the public docket of this SNPRM. Submissions containing CBI should
be sent to Kristi Bradley, Aerospace Engineer, General Aviation &
Rotorcraft Section, International Validation Branch, Compliance &
Airworthiness Division, FAA, 10101 Hillwood Pkwy., Fort Worth, TX
76177; telephone (817) 222-5110; email kristin.bradley@faa.gov. Any
commentary that the FAA receives which is not specifically designated
as CBI will be placed in the public docket for this rulemaking.
Background
The FAA issued an NPRM that proposed to amend 14 CFR part 39 by
adding an AD that would apply to various model helicopters with certain
part-numbered externally-mounted Goodrich hoists installed. The NPRM
published in the Federal Register on December 11, 2020 (85, FR 79930).
In the NPRM, the FAA proposed to require replacing unmodified hoists,
installing placards, revising the existing Rotorcraft Flight Manual
(RFM) for your helicopter, deactivating or removing a hoist if a
partial peel out occurs, reviewing the helicopter's hoist slip load
test records, repetitively inspecting the hoist cable and overload
clutch (clutch), and reporting information to the FAA.
The NPRM was prompted by a series of EASA ADs, the most recent
being EASA AD 2015-0226R5, Revision 5, dated July 23, 2020 (EASA AD
2015-0226R5), to correct an unsafe condition for various model
helicopters with a Goodrich externally-mounted hoist with one of the
following part numbers (P/Ns) or base P/Ns installed: 42315, 42325,
44301-10-1, 44301-10-2, 44301-10-4, 44301-10-5, 44301-10-6, 44301-10-7,
44301-10-8, 44301-10-9, 44301-10-10, 44301-10-11, 44311, 44312, 44314,
44315, 44316, or 44318. EASA advises of an initial incident of a rescue
hoist containing a dummy test load of 552 lbs. that reeled-out without
command of the operator and impacted the ground during a maintenance
check flight, because the overload clutch had failed. EASA states that
this condition, if not detected and corrected, could lead to further
cases of in-flight loss of the hoist load, possibly resulting in injury
to persons on the ground or in a hoisting accident.
Accordingly, EASA AD 2015-0226R5 requires a records review to
determine if the cable has exceeded the allowable limit in previous
load testing, a repetitive load check and test of the clutch slip
value, removal or deactivation of a hoist that cannot be tested due to
lack of approved instructions, replacement of the old clutch P/N with
a
new clutch developed by Goodrich to mitigate some of the
factors resulting in clutch degradation, periodic replacement of the
hoist, reduction of the maximum allowable load on the hoist, addition
of operational limitations to the RFM, and replacement of the hoist
after a partial peel out. EASA AD 2015-0226R5 also prohibits the
installation of a replacement cable that has exceeded the allowable
limit in previous load testing. EASA considers AD 2015-0226R5 to be
interim action and advises further AD action may follow.
Comments
The FAA received comments from three commenters. The commenters
were EASA, Collins Aerospace, and an individual. The following
discussion presents the comments received on the NPRM and the FAA's
response.
Request To Clarify Interval Between Overhaul
EASA requested the FAA clarify why the proposed AD does not include
the reduced time interval between overhaul that is required by EASA's
AD. EASA stated that based on the occurrences and design review, its AD
limits the time between overhaul to 24 months, 1,200 cycles, or 1,600
lifts, which can be extended to 40 months or 2,600 lifts if tests and
documentation are provided to EASA.
The FAA's proposed AD and EASA's AD differ in that the EASA AD
requires repetitive replacement or overhaul of all affected hoists,
while the FAA's proposed AD would require a one-time replacement of
affected hoists that have not been modified with a new overload clutch
assembly (and re-identified with a "4" as the first digit of the
serial number (S/N)). Since the proposed AD would also prohibit
installation of a hoist unless it has a "4" as the first digit of the
S/N, this would have the effect of requiring replacement of a non-
modified hoist with a modified hoist. The FAA acquired data from
Collins Aerospace that showed over 1,000 field load checks of hoists
with a new overload clutch assembly with no reports of low pulling
clutches or peel out events. The FAA evaluated this data and determined
that it does not substantiate a 24-month repetitive replacement or
overhaul of hoists that have been modified with the new overload clutch
assembly. The FAA considers this AD action to be an interim action, and
using the additional data reported following issuance of this AD, will
re-evaluate this determination if needed.
Request Regarding Replacement of the Hoist
One commenter requested the FAA allow installing a new clutch
assembly instead of requiring "scrapping" the entire hoist, if the
hoist does not have the number "4" as the first digit of its S/N.
The FAA agrees. The requirement proposed by this AD to replace a
hoist without the number "4" as the first digit of its S/N with a
modified hoist would not require removing the hoist from service. The
proposed requirement states to "replace" the hoist. This would not
prohibit re-installing a hoist after modifying it to install a new
overload clutch assembly and (re)-identifying it with a "4" as the
first digit of the S/N. No changes to this proposed AD are necessary as
a result of this comment.
Safety Concern Addressed by Existing AD
One commenter stated that this clutch safety concern has already
been addressed by AD 2013-06-51 (78 FR 38826, June 28, 2013) (AD 2013-
06-51), Goodrich Alert Service Bulletin (ASB) No. 44301-10-15, dated
March 8, 2013 (ASB 44301-10-15), and Goodrich ASB No. 44301-10-18,
Revision 6, dated October 10, 2016 (ASB 44301-10-18).
The FAA agrees that ASB 44301-10-18 specifies procedures to address
this issue. However, while an operator may incorporate the procedures
in this service bulletin into its inspection program, not all operators
are required to do so. In order for these procedures to become
mandatory, and to correct the unsafe condition identified in the NPRM,
the FAA must issue an AD. Further, AD 2013-06-51 (and ASB 44301-10-15,
which is mandated by AD 2013-06-51) requires a one-time cable
conditioning lift and load inspection test as interim corrective
action. AD 2013-06-51 does not require all of the same actions as this
proposed AD.
Requests Regarding Compliance Time for Hoist Replacement
The individual commenter requested that the FAA change part of the
compliance time for replacing a hoist without the number "4" as the
first digit of its S/N from 55 operating hours to 55 hours since the
last clutch overhaul. The commenter's hoist has 89 operating hours and
was overhauled 2 hours ago; the commenter's understanding is that such
a hoist would need to be replaced immediately when the proposed AD
becomes effective.
The FAA disagrees. If the commenter's hoist has an S/N without the
number "4" as the first digit, then at its recent overhaul it was not
modified with a new overload clutch assembly. Thus, it is still subject
to the unsafe condition. Operators in this situation may, under the
provisions of paragraph (h) of this SNPRM, request approval of an
alternative method of compliance (AMOC) if sufficient data is submitted
to substantiate an acceptable level of safety.
Collins Aerospace stated that the compliance time for converting a
hoist to a hoist with a new overload clutch assembly should be 24
months, based on improved risk analysis information from initial load
checks and subsequent load checks.
The FAA partially agrees. The FAA also determined that 24 months is
an adequate compliance time to mitigate the risk to reasonable levels.
However, the FAA proposed a 12-month compliance time after factoring an
estimated 12-month processing time before issuance of the final rule of
this AD. The FAA did not make any changes to the SNPRM as a result of
these comments.
Requests Regarding the Operating Limitations
EASA requested the FAA explain why it did not adopt two of the
operating limitations required by EASA AD 2015-0226R5: The limit on the
number of persons that can be hoisted, and the warning that exceeding
15[deg] of lateral pendulum angle/helicopter vertical axis may lead to
clutch slippage.
EASA AD 2015-0226R5 limits the number of persons that can be
hoisted to two, except when hoisting more persons (such as children)
will not exceed the weight limit. The FAA determined that the maximum
hoist load limitations described in terms of weight alone, without the
extraneous information on the number of persons lifted, are sufficient.
The FAA did not propose to include the lateral pendulum angle of the
hoist cable with respect to the helicopter's vertical axis after
determining that such a limitation would not be measurable or
enforceable. The FAA did not make any changes to the SNPRM as a result
of this comment.
EASA requested the FAA explain why the proposed AD would require
different temperature ranges for the weight limitations than EASA AD
2015-0226R5 and would omit limitations for OAT below -20 [deg]C.
The FAA agrees that the maximum hoist load limitations in this
proposed AD should be consistent with those in the EASA AD and that
this proposed AD should include requirements for all temperatures.
Accordingly, the FAA has changed the temperatures in the
maximum hoist load limitations in this SNPRM.
Collins Aerospace requested the FAA change the proposed maximum
hoist load limitations to distinguishing between non-modified hoists
(without the number "4" as the first digit of its S/N) and modified
hoists with a new clutch (with the number "4" as the first digit of
its S/N). Collins Aerospace stated that after EASA AD 2015-0226R1 was
issued, Goodrich performed a series of characterization tests that
demonstrated the performance envelope of the modified hoist in various
conditions. According to Collins Aerospace, the results of these tests
as documented in Goodrich Report No. 49000-1087, Revision A, dated July
31, 2017, indicate that margins are maintained with a less restrictive
temperature limitation than those imposed on non-modified hoists.
The FAA disagrees with requiring different maximum hoist load
limitations for non-modified hoists and modified hoists. After
reviewing the data in the report referenced by the commenter, the FAA
determined it does not demonstrate with an acceptable level of
confidence that less restrictive temperature limitations are
appropriate for modified hoists.
Request To Allow Additional Load Check Tool
Collins Aerospace requested the FAA change the proposed requirement
to use load check tool P/N 49900-889-104 for the cable conditioning and
a hoist slip load test to also allow using tool P/N 49900-889-103.
Collins Aerospace stated that both are tool kits, with P/N 49900-889-
104 having all of the components of P/N 49900-889-103, plus extra
components so that P/N 49900-889-104 can be used to perform tests on
helicopters with older versions of the large hook damper. Collins
Aerospace further stated that helicopters with newer model dampers and
all other platforms can utilize tool P/N 49900-889-103, which is
expected to supersede tool P/N 49900-889-104 as the older dampers are
removed from service.
The FAA agrees and has revised this SNPRM accordingly.
Request Regarding Hoist Load Check (Test) After Installation
EASA requested the FAA explain why the proposed AD does not require
accomplishing a hoist load check (test) after installing a new clutch,
as required by the EASA AD. EASA stated the test will check for any
uncertainties that might develop during handling and storage before
installation.
The FAA is not aware of any modified hoists with a new clutch
(having a number "4" as the first digit of the S/N) failing the hoist
load test. Accordingly, the FAA determined there is insufficient data
to support proposing this as an additional requirement.
Request Regarding Compliance Time for Initial Load Test
Collins Aerospace requested that, for certain hoists, the FAA
extend the compliance time for the initial hoist slip load test from 30
days to six months. In support of this request, Collins Aerospace
stated the 30 day compliance time calculation is appropriate for non-
modified hoists that have: No improvements from manufacture, repair, or
overhaul after February 1, 2018; not complied with ASB 44301-10-18 or
ASB 44301-10-15; or not had a load check performed. Collins Aerospace
further stated that enough load check tools may not be available to
test all hoists that would be affected by the proposed AD.
The FAA disagrees with changing the proposed AD to account for
manufacturing improvements because not enough data has been provided to
substantiate the commenter's request. However, the FAA agrees with
providing an allowance for the initial instance of the cable
inspections and hoist slip load test proposed by this AD if those
actions have been accomplished within the last six months. The FAA has
changed the proposed compliance time accordingly.
Request Regarding the Costs of Compliance
Collins Aerospace stated that replacing a hoist is not necessary as
the clutch can be replaced instead for an average cost of $24,000, plus
8 hours of labor. Collins Aerospace also stated that the cost for the
field load check tool is $11,171.
The FAA agrees that replacing a hoist without the number "4" as
the first digit of its S/N, as required by paragraph (g)(1) of this
SNPRM, may be accomplished by modifying the hoist with the new overload
clutch assembly and re-identifying it with a
"4" as the first digit of the S/N. The FAA has updated the Costs
of Compliance section accordingly.
Comment Regarding Figure 4
Collins Aerospace stated that although a figure 4 is referenced in
the Required Actions of the NPRM, no figure 4 appears in the NPRM.
The FAA agrees. Figure 4 to paragraph (e)(2)(iv) of the NPRM (now
Figure 4 to paragraph (g)(2)(iv) of this SNPRM), which is necessary to
accomplish the required actions, was inadvertently omitted in
reproduction when the NPRM published in the Federal Register.
Other Differences Between the NPRM and the SNPRM
In this SNPRM, the FAA has added "total" to the compliance time
and usage thresholds for hoists without a "4" as the first digit of
its S/N to clarify that it is the total accumulation of time on the
hoist that would trigger the proposed requirement to replace the hoist.
In this SNPRM, the FAA has also added the metric conversion (kg) for
the hoist ratings in the first two figures.
Lastly, this SNPRM uses an updated format. As a result, paragraph
identifiers have changed.
FAA's Determination
Affected helicopters include helicopters that have been approved by
the aviation authorities of Canada, Italy, France, and Germany and are
approved for operation in the United States. Pursuant to the FAA's
bilateral agreement with the European Union, EASA has notified the FAA
about the unsafe condition described in its AD. The FAA is issuing this
SNPRM after determining the unsafe condition described previously is
likely to exist or develop on other helicopters of the same type
design. Certain changes described above expand the scope of the NPRM.
As a result, it is necessary to reopen the comment period to provide
additional opportunity for the public to comment on this SNPRM.
Related Service Information Under 1 CFR part 51
The FAA reviewed ASB 44301-10-18, which specifies maximum hoist
load limitations with respect to ambient temperature and describes
actions and conditions that could reduce the capacity of the clutch.
This service information also specifies procedures for inspecting the
cable and inspecting the clutch by performing a cable conditioning lift
and a hoist slip load test.
This service information is reasonably available because the
interested parties have access to it through their normal course of
business or by the means identified in the ADDRESSES section.
Proposed AD Requirements in This SNPRM
This proposed AD would require:
Replacing any hoist without a "4" as the first digit of
its S/N within 12 months after the effective date of this AD or before
the hoist accumulates 55 total operating hours, 1,200 total hoist cycles
(cycles), or 1,600 total hoist lifts (lifts), whichever occurs first.
Installing placards and revising the existing RFM for your
helicopter to add maximum hoist load limitations, an excessive
maneuvering warning, a maximum sustained bank angle in turn, and a
prohibition on operating the hoist in the event of a partial peel out.
Deactivating or removing any hoist that experiences a
partial peel out from service.
Reviewing records for cable load-testing that was
previously performed, and depending on the findings, replacing the
cable.
Repetitively inspecting the cable, inspecting the clutch
by performing a cable conditioning lift and hoist slip load test,
inspecting the cable a second time, reporting certain information to
the FAA, and depending on these inspection outcomes, replacing the
cable or removing the hoist from service.
This proposed AD would also prohibit installing an affected
replacement or original installation hoist that has not been re-
identified to indicate it has an improved clutch assembly.
Installation of a hoist with an improved overload clutch assembly,
which is indicated by having a "4" as the first digit of its S/N,
would not terminate the actions required by this proposed AD.
Differences Between This SNPRM and the EASA AD
EASA AD 2015-0226R5 requires repetitively replacing the hoist with
a modified hoist, whereas this proposed AD would require a one-time
replacement of the hoist with a modified hoist that has the improved
clutch assembly installed. EASA AD 2015-0226R5 requires adding a
placard or operational limitation to the RFM warning that exceeding
15[deg] of lateral pendulum angle/helicopter vertical axis can lead to
clutch slippage, and this proposed AD would not. EASA AD 2015-0226R5
requires adding an operating limitation to the RFM limiting the number
of persons who can be hoisted, whereas this proposed AD would not. This
proposed AD would require replacing the cable before the next hoist
operation if a cable has previously been load-tested at more than 1,500
lbs or at an unknown weight during at least one cable pull, while EASA
AD 2015-0226R5 requires this replacement during multiple cable pulls.
This proposed AD would require visually inspecting and measuring the
diameter of the cable before and after performing a cable conditioning
and a hoist slip load test, whereas EASA AD 2015-0226R5 does not. This
proposed AD would require performing the cable conditioning and hoist
slip load test within 30 days after the effective date of this AD,
unless already done within the last 6 calendar months, and thereafter
at intervals not to exceed 6 months, 400 lifts, or 300 cycles. EASA AD
2015-0226R5 specifies performing the hoist slip load test according to
the compliance time of the design approval holder instead. After the
installation (not reinstallation) of a modified hoist, EASA AD 2015-
0226R5 requires performing an initial hoist load check/test prior to
hoisting operation, whereas this proposed AD would not.
Interim Action
The FAA considers this proposed AD would be an interim action. The
inspection reports that would be required by this proposed AD will
enable better insight into the condition of the hoists, and eventually
be used to develop final action to address the unsafe condition. Once
final action has been identified, the FAA might consider further
rulemaking.
Costs of Compliance
The FAA estimates that this AD, if adopted as proposed, would
affect 2,911 hoists installed on helicopters of U.S. Registry. Labor
rates are estimated at $85 per work-hour. Based on these numbers, the
FAA estimates the following costs to comply with this proposed AD.
Replacing a clutch would take about 8 work-hours and parts would
cost about $24,000 for an estimated cost of $24,680 per hoist.
Alternatively, replacing a hoist would take about 8 work-hours and
parts would cost about $200,000 for an estimated cost of $200,680 per
hoist.
Revising the existing RFM for your helicopter and installing
placards would take about 0.5 work-hour for an estimated cost of $43
per helicopter and $125,173 for the U.S. fleet.
Deactivating or removing a hoist that experiences a partial peel
out would take about 2 work-hours for an estimated cost of $170.
Reviewing records would take about 0.5 work-hour for an estimated
cost of $43 per helicopter and $125,173 for the U.S. fleet.
Inspecting the cable and performing a cable conditioning lift and
hoist slip load test would take about 2 work-hours for an estimated
cost of $170 per helicopter and $494,870 for the U.S. fleet per
inspection cycle. A (field) load check tool would cost about $11,171.
Reporting the hoist slip load test information would take about 0.25
work-hour for a cost of $21 per helicopter and $61,131 for the U.S.
fleet per reporting cycle.
Replacing the cable would take about 3 work-hours and parts would
cost about $3,150 for a total replacement cost of $3,405 per hoist.
Paperwork Reduction Act
A federal agency may not conduct or sponsor, and a person is not
required to respond to, nor shall a person be subject to penalty for
failure to comply with a collection of information subject to the
requirements of the Paperwork Reduction Act unless that collection of
information displays a currently valid OMB Control Number. The OMB
Control Number for this information collection is 2120-0056. Public
reporting for this collection of information is estimated to take
approximately 0.25 hour per response, including the time for reviewing
instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the
collection of information. All responses to this collection of
information are mandatory. Send comments regarding this burden estimate
or any other aspect of this collection of information, including
suggestions for reducing this burden, to: Information Collection
Clearance Officer, Federal Aviation Administration, 10101 Hillwood
Parkway, Fort Worth, TX 76177-1524.
Authority for This Rulemaking
Title 49 of the United States Code specifies the FAA's authority to
issue rules on aviation safety. Subtitle I, section 106, describes the
authority of the FAA Administrator. Subtitle VII: Aviation Programs,
describes in more detail the scope of the Agency's authority.
The FAA is issuing this rulemaking under the authority described in
Subtitle VII, Part A, Subpart III, Section 44701: General requirements.
Under that section, Congress charges the FAA with promoting safe flight
of civil aircraft in air commerce by prescribing regulations for
practices, methods, and procedures the Administrator finds necessary
for safety in air commerce. This regulation is within the scope of that
authority because it addresses an unsafe condition that is likely to
exist or develop on products identified in this rulemaking action.
Regulatory Findings
The FAA determined that this proposed AD would not have federalism
implications under Executive Order 13132. This proposed AD would not
have a substantial direct effect on the States, on the relationship
between the national Government and the States, or on the distribution
of power and responsibilities among the various levels of government.
For the reasons discussed, I certify this proposed regulation:
(1) Is not a "significant regulatory action" under Executive
Order 12866,
(2) Would not affect intrastate aviation in Alaska, and
(3) Would not have a significant economic impact, positive or
negative, on a substantial number of small entities under the criteria
of the Regulatory Flexibility Act.
List of Subjects in 14 CFR Part 39
Air transportation, Aircraft, Aviation safety, Incorporation by
reference, Safety.
The Proposed Amendment
Accordingly, under the authority delegated to me by the
Administrator, the FAA proposes to amend 14 CFR part 39 as follows:
PART 39--AIRWORTHINESS DIRECTIVES
1. The authority citation for part 39 continues to read as follows:
Authority: 49 U.S.C. 106(g), 40113, 44701.
Sec. 39.13 [Amended]
2. The FAA amends Sec. 39.13 by adding the following new airworthiness
directive:
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