Consequences of Unplanned and Under-Measured Air Pollution, with Nikos Zirogiannis

Notable Quotes

• Defining excess emissions: “Excess emissions are violations of the Clean Air Act. They occur when a facility exceeds its permitted emissions threshold, and those incidents happen during startups, shutdowns, or malfunctions … For example, we have substantial excess emissions that are released when a hurricane is coming in on the coast of Texas, and then industrial facilities have to shut down their operations because they don’t want to be online when the hurricane strikes.” (3:40)
• Data on excess emissions aren’t easily accessible: “In Texas … our group just submitted a public information request. We received an Excel file with all excess emissions data for the last 20 years by facility, by pollutant, by stock, with specific information on the details of its event. That type of recordkeeping system is something we argue … should be incorporated across all state environmental agencies in the country.” (12:16)
• Transparency about pollution events: “One of the issues that the East Palestine accident … really highlighted was the need to communicate information to the public as accurately and as quickly as possible. People have the right to know if, when, and what types of pollutants they are being exposed to … Facilities should be 100 percent transparent with the public if and when things go wrong.” (25:26)

Top of the Stack

• “Excess Emissions: Environmental Impacts, Health Effects, and Policy Debate” by Alex Hollingsworth, David M. Konisky, and Nikolaos Zirogiannis
• “Residents Must Stay Indoors After Texas Chemical Fire” by Cecelia Smith-Schoenwalder
• The Big Myth by Naomi Oreskes and Erik M. Conway

Transcript

Daniel Raimi: Hello and welcome to Resources Radio, a weekly podcast from Resources for the Future. I’m your host, Daniel Raimi. Today, we talk with Dr. Nikos Zirogiannis, Assistant Professor at Indiana University’s O’Neill School of Public and Environmental Affairs. Nikos recently published a paper with coauthors on a really important but underappreciated environmental topic: excess air emissions.

In today’s episode, Nikos will help us understand what these emissions events are, why they happen, and their impacts on public health. He’ll also describe the significant data, policy, and research gaps that we need to address to better understand excess emission events and inform policymaking. Stay with us.

Nikos Zirogiannis from the O’Neill School at Indiana University, welcome to Resources Radio.

Nikos Zirogiannis: Daniel, thank you very much. I appreciate having the chance to be on the show. I’ve been a longtime follower and fan of the podcast, and I’m very excited to be joining today as a guest. Thank you.

Daniel Raimi: Thank you so much. That’s nice of you to say, and we’re thrilled to have you. My first question, then, which we always ask our guests, is how they got interested in working on environmental topics, whether at a young age or later in life. What steered you into this line of work?

Nikos Zirogiannis: I grew up in Athens, Greece in the 1980s, and that was a time when Athens was one of the most polluted capitals in Europe. I also suffered from asthma as a child, so I very quickly became aware of the impacts that exposure to pollution can have on respiratory issues. Now, the 1980s was a time when, at least in Greece, cars were still using leaded gasoline, and homes were heated using diesel oil. Several factors would contribute to pollution, and I recall as an elementary school student I would ride the bus to school every morning, and then at some point in the route, the bus would climb up a hill, and there would be a direct view to the Acropolis about two and a half miles away. There were days where the Acropolis was visible and other days when visibility was entirely obscured because of high pollution concentrations in the city.

That loss of visibility was one of my first markers of pollution incidents. So, I was pretty aware of pollution related issues early on, and then when I was an undergrad—I went to business school in the Athens University of Economics and Business—at some point, I took an elective class in environmental economics, and I got hooked. I very quickly realized that the business world was not really made for me, or I wasn’t made for the business world. After undergrad, I pursued graduate degrees in environmental and resource economics initially in Europe and then in the United States at the University of Massachusetts in Amherst, where I graduated in 2013 with a PhD.

Daniel Raimi: That’s great. That’s so interesting. We’ve had several guests who talk about air pollution. People who grew up in Los Angeles in the 1960s or 1970s have very similar stories to the ones you just described from Athens. That’s really interesting.

Nikos Zirogiannis: In fact, I recall Neha Khanna’s response saying how when she was growing up in New Delhi, she was also familiar with pollution issues—one of your former guests.

Daniel Raimi: Right. Absolutely. Well, today, we’re going to talk about a kind of pollution, but we’re going to talk about a different kind of pollution, I think. We’re going to talk about this topic of excess emissions events, why they matter, what their implications are for public health, and how policymakers might address them. Can you first define this term, “excess emissions events,” and maybe give us an example or two that folks might have heard of?

Nikos Zirogiannis: Absolutely. Excess emissions are violations of the Clean Air Act. They occur when a facility exceeds its permitted emissions threshold, and those incidents happen during startups, shutdowns, or malfunctions. Those emissions are often referred to as SSM—startup, shutdown, and malfunction. For example, we have substantial excess emissions that are released when, for example, a hurricane is coming in on the coast of Texas, and then industrial facilities have to shut down their operations because they don’t want to be online when the hurricane strikes. That’s one case where we have large amounts of excess emissions.

One example that listeners might have heard of, especially those listeners in Texas—and one that we mentioned in the paper we recently published in the Review of Environmental Economics and Policy—is the Intercontinental Terminals fire in March of 2019. This was a fire that started in a chemical storage facility about 17 miles southeast of Houston, Texas, and lasted for about three days. There were several shelter-in-place orders that were issued for nearby communities because of concerns of high levels of benzene released from the fire, and listeners can click on the link on the website of the podcast and see an aerial view of the fire covering the entire downtown of Houston with a black plume of smoke.

This was one of the worst industrial accidents that have happened in Texas in terms of amounts of pollution released. About 7,500 tons of pollution were released due to the fire. It got a lot of media attention, state media attention, and even some national media attention, although not as much as the recent rail accident in East Palestine.

Other accidents are less visible. Other examples of excess emissions are less visible than the one I just described. For example, in April of 2003, there was a lightning strike at the Total Petrochemicals Refinery in Port Arthur, Texas. This is a city on the border between Texas and Louisiana. The lightning strikes, that causes the refinery to lose power, and now several emissions-controlled devices will go offline. Within the next 56 hours, the refinery releases 1,300 tons of sulfur dioxide in the form of excess emissions. Now, to put this in context, that same refinery emitted about half the amount of sulfur dioxide through its routine operations over the entire year of 2003—about 700 tons. Within a very short period of time, the refinery’s annual pollution doubled because of this accident, and then, usually, what happens is that the Texas Commission on Environmental Quality (TCEQ), which is the state environmental agency of Texas, reviews those accidents.

In this particular case, the agency decided that no fines should be assessed, because it acknowledged the unexpected nature of the accident. One last example, just again to provide some more context here: in 2011, again, in a refinery in Port Arthur, in the Valero Refinery, the employees were doing some gas sampling, and during that sampling they realized that excess sulfur dioxide was being released from a flare over the course of seven months. Here, we’re talking about a seven-month-long, undetected excess emission event that released over 2,000 tons of sulfur dioxide.

Again, that’s almost four times as much as the refinery released in that entire year from its routine, permitted operations. In this case, the state environmental agency assessed a penalty of $2 million for that and for other emissions events that the refinery had faced. Overall, excess emission releases can involve highly visible accidents, like the one I described in the Intercontinental Terminals fire, that are very close to large cities. They are very visible and release a large plume of smoke, although others might be a lot less visible either, because they happen in remote locations, or because they involve pollutant releases from stocks that might be indistinguishable from routine emissions.

Daniel Raimi: That’s so interesting. So, you and your coauthors in the paper—which of course, we’ll have a link to in the show notes—you note that many of these events don’t actually get a lot of attention. Some of them do, of course, like the East Palestine train derailment or the accident in Texas that you mentioned, but what do we know about how common these types of events are, and why is it that you think they might be underappreciated?

Nikos Zirogiannis: Absolutely. Those accidental emissions happen very frequently in Texas. In our work—and this is work with coauthors David Konisky and Alex Hollingsworth, both from the Paul O’Neill School here at Indiana University—we estimate that there is at least one excess emissions event in Texas every single day that emits at least 10 tons of pollution and about three excess emissions events per year each emitting over 1,000 tons of pollution. In an average year, Texas experiences about 3,600 of those events. Most of them are very small in terms of what they release—the median excess emission event releases less than a ton of pollution.

However, their overall distribution is highly skewed. The top 10 percent of excess emission events release the vast majority of total pollution. Most accidents, as you mentioned, do not receive a lot of media attention, either because people are not aware of them, or because they happen in parts of the country that have low population density—like West Texas, for example. Now, I’ve been talking a lot about Texas, because Texas is the only state in the country that has a very detailed reporting and a recordkeeping requirement for those excess emissions.

Louisiana and Oklahoma also collect data from facilities, but do not have something unique that Texas has, which is a 24-hour public disclosure requirement. In Texas, industrial facilities are required to report those kinds of excess-emissions events within 24 hours of occurrence to the TCEQ, the Texas Commission on Environmental Quality—the state Environmental Protection Agency, essentially—and then the agency, once it receives that report, immediately puts up the information on its website and makes that information publicly available. Each excess-emissions event report that is uploaded has information on the date and the time of the event, how long the event lasted, what pollutants were released in what amounts, as well as the reasons for the accidents and the steps the facility took to mitigate the impacts of the event.

Now, facilities, as part of the report, can also file for what is called affirmative defense. That means that they can make the claim that this particular event they faced was unavoidable. There was no way they could have prevented the event and that the release of those excess emissions did not endanger compliance of the county with the Clean Air Act thresholds. If the TCEQ accepts that claim and grants affirmative defense, then the facility cannot be sued in civil court for that accident. The state agency itself can still take enforcement steps, but the affirmative defense protects the facility from civil lawsuits. In communications we have had with the TCEQ, anecdotally, we know that those affirmative defense applications are the norm amongst violating facilities.

Now, other states require facilities to report excess emissions, but do not keep systematic track of them. I’ll give the example of my home state of Indiana, which also requires facilities to report excess emissions as part of their quarterly compliance reports. These are reports that facilities have to submit and the agency, the Indiana Department of Environmental Management, makes those reports available online. If I wanted to do the same type of analysis that our group did for Texas—if I wanted to do the same analysis for Indiana, I would have to download each quarterly report from each facility across multiple years, then skim through the 400 to 500 pages of each report and find the page that lists the excess emissions releases for that facility in that quarter. Even then, I would only know the total amount of excess emissions over the past quarter. I wouldn’t know the date when they happened, I wouldn’t know the time when they were released, and I would also probably need half a dozen research assistants to work on this for several weeks, if not months, to complete this process.

I would argue that, while Indiana provides information on excess emissions, the way the information is provided is not meaningful and does not allow for the data to be used for research. In Texas, on the other hand, our group just submitted a public information request. We received an Excel file with all excess emissions data for the last 20 years by facility, by pollutant, by stock, with specific information on the details of its event. That type of recordkeeping system is something we argue in the paper should be incorporated across all state environmental agencies in the country.

Daniel Raimi: That’s a really clear and good policy implication. There are so many questions that come to mind as you’re describing this policy framework, but I’d love to ask you briefly about what we know about the environmental and health effects of these excess emissions events. You mentioned some of the pollutants that have been emitted or can be emitted. Are there studies that have looked at the consequences of these excess health events, and what do they tell us?

Nikos Zirogiannis: There have been studies in the atmospheric science literature in the early 2000s looking at the air-quality implications of excess emissions events, but ours is one of the first ones to look at the health impacts of those types of emissions. As I mentioned earlier, those are emissions that happen very frequently in Texas, and they are often large in amounts. They represent a substantial share of permitted, routine emissions that happen during normal operations of the facilities. For example—just to give a sense of magnitude of how big a deal these emissions are—we find that in Texas, volatile organic compound excess emissions are about 7.5 percent of total routine volatile organic compound emissions, which is a pretty sizable share.

For particular industries, that share of excess-over-routine emissions can be substantially higher. For example, for the crude petroleum and natural gas operations industry, we have about 17 percent share of excess-to-routine emissions of sulfur dioxide, and then there’s also variation across space. In some counties in West Texas, for example, where we have a lot of oil and gas drilling, excess emissions of all pollutants are over 30 percent of total routine emissions from those drilling operations. Now, in our work, we’ve been able to causally identify the impacts of excess emissions on air pollution; namely, on ground-level ozone and also on premature elderly mortality, meaning mortality among age groups 65 years and above.

The reason we’ve been able to provide causal estimates is because those excess emissions are caused by unplanned accidents. We can think of them as plausibly exogenous shocks to pollution. We have data over more than 17 years. We observe months with and without excess emissions at the county level. Essentially, each of the 254 counties in the state of Texas acts both as a control group in months when we do not have excess emissions and the treatment group in months where we have excess emissions. This quasi-experimental variation allows us to account for a series of county specific and observable factors that are time variant, like changes in population, industry expansions, and so on.

We find about a 10 percent increase in ground-level ozone concentrations—and these are increases in pollution that are induced by excess emissions—increased elderly mortality by about 3.9 percent, and that’s a change driven primarily by older cohorts, meaning 85-year-olds and above, and that cohort actually sees an increase of 5.2 percent in mortality. To put this in perspective, we combine those marginal estimates with actual frequency and magnitude of excess emissions, and we find that excess emissions are responsible for about 35 deaths per year on average in Texas alone for that age group of 65 years and above.

Daniel Raimi: Yeah. So, really quite significant. That’s so interesting. I wonder—it seems plausible that there’s a lot we don’t know about these emissions, especially in states outside of Texas and maybe even within Texas if there are events that are unreported. What are our known unknowns here? What are the things that we know we’re probably missing?

Nikos Zirogiannis: Quite a few things, actually. In our analysis and in our work, we’ve made some very conservative assumptions, and we’ve made those assumptions so that we can make sure that we identify the true effect of individual pollutants on excess emissions. For example, we’ve restricted our sample to emissions events that only release a single pollutant—carbon monoxide or only volatile organic compounds or only nitrogen oxides. Doing that substantially decreases our sample size. It’s likely that the actual damages are a lot higher, and we have to do this so that we can provide a causal estimate from each pollutant separately. In our analysis, we also use monthly mortality data.

We did not have access to daily mortality data. Had we had access to that information, we probably could have produced a lot more accurate estimates of mortality. Something we also did not do is we did not look at effects on morbidity, like asthma attacks or emergency department visits, where the literature in environmental economics has determined that there are very big impacts on morbidity from pollution. We were also not able to identify effects on particulate matter 2.5 (PM2.5) concentrations. We only have effects on ozone, and that’s in part because we have a much smaller sample size of PM2.5 monitors in Texas and many other states.

There are fewer PM2.5 quality monitors in Texas compared to ozone monitors, and those PM2.5 monitors operate with a staggered schedule. They operate only once every six days, or once every three days. That really compromises our ability to detect a causal effect on PM2.5 concentrations, but that doesn’t mean that effect is not there. We see our estimates as a lower bound of health damages. As you mentioned, and more importantly, we know nothing about—or very little, I should say—about the incidence and the magnitude of excess emissions in other states.

That’s a very important limitation, since other states might face similar and perhaps even higher marginal damages than those we find in Texas, and, finally, our work provides estimates on the damages caused by excess emissions, but we do not know the cost of reducing those emissions—what, in environmental economics, we call the marginal abatement cost. That is particularly challenging to do for excess emissions, because controlling routine emissions can be as straightforward as installing an emissions control device, but in the case of excess emissions, reducing them would require things like investing in better maintenance, personnel training, emergency response procedures to limit the size of emissions once an accident occurs, perhaps installing backup power capacity to avoid emissions during power outages, and so on. So that’s another important aspect of policy analysis that we don’t have good information on.

Daniel Raimi: Right. That makes a lot of sense. I wonder—have you thought about using those PurpleAir monitors that are distributed pretty extensively? I was just looking on the PurpleAir map, and it looks like there are a bunch of them in Houston—not very many in West Texas, though.

Nikos Zirogiannis: Absolutely. The use of PurpleAir monitors has received a lot of attention in the literature and also from the US Environmental Protection Agency (EPA). There’s an issue with those monitors in that they’re not as accurate, I should say. They’re not as nearly as accurate as regulatory monitors, but, in this case, what we lose in accuracy, we gain in density, because, as you said, there are a lot of them, particularly in cities like Houston and Dallas. Definitely, that’s within our future scope of work to try to incorporate that additional information and also information from satellite images, which can be very useful here in order to close those gaps in information on air pollution.

Daniel Raimi: Right, for sure. It’s interesting. I was actually just out in the Permian Basin a couple of weeks ago on the New Mexico side of the border, and I was talking with someone about air quality, and we had the same conversation about the trade-offs of using cheaper sensors with slightly less accurate measurements.

Another question that I’d love to hear your thoughts on, Nikos, is about policy implications. I imagine our listeners have thought of several during our conversation. You’ve already mentioned one important one, which is reporting. Are there other really important policy implications that you would draw from this work?

Nikos Zirogiannis: Absolutely, and perhaps it might help if I provided some background here, and that’s something we discuss in the paper—that there’s a nontrivial policy debate around how those emissions are being regulated. For decades, those excess emissions were literally flying under the regulatory data radar. EPA was aware that those emissions were happening, and, more importantly, EPA was aware that states had provisions in their state implementation plan (SIP)—the state plan that details how a state achieves and maintains compliance with the Clean Air Act. Those state implementation plans had clauses that violated the statute.

States were offering loopholes that eased enforcement on facilities that released excess emissions. Examples of those loopholes are automatic exemptions, the affirmative defense provisions I mentioned earlier. This was happening for decades, and it was not until 2011 when the Sierra Club, a nonprofit environmental advocacy group, filed a petition arguing that several states included language in their SIPs that was not in accordance with the Clean Air Act. In response to that petition, EPA asked 36 states back in 2015 to revise the language in their SIPs and remove any language that was in violation of the Clean Air Act.

This happened in 2015. Those 36 states had until November of 2016 to submit their revised SIPs. November 2016, as listeners will remember, was a change in the administration. We had the Trump administration coming in, and many states did not submit revised SIPs. In fact, several EPA regional offices during the 2016–2020 period, and, eventually, the EPA administrator himself, Andrew Wheeler, issued a series of memoranda allowing enforcement exceptions to go back into SIPs, and this was a time where our group here at O’Neill tried to be very active in voicing our concerns about those deregulatory moves that we were concerned would increase the incidents of excess emission.

We wrote op-eds; we wrote public comments against those deregulatory rules. We presented work to the EPA. We wrote a memo to the EPA administrator, and, thankfully, the EPA recently reinstated the 2015 SIP call asking states to bring their SIPs in line with the Clean Air Act. It’s important to give credit to the agency and acknowledge that the EPA has recently taken steps in the right direction on closing those regulatory loopholes that could increase excess emissions.

Now, that said, there are still states around the country where we know very little about the incidence of excess emissions. I gave the example of my home state of Indiana earlier, and, in our most recent paper, we argue that the EPA and state agencies need to develop a detailed reporting and recordkeeping system similar to the one that Texas has, because without that kind of detailed information on the incidents and the magnitude of excess emissions, we cannot design effective policy. We cannot know what the true health impacts are.

Daniel Raimi: That all makes a lot of sense. I was wondering, when you were describing the lengthy documents that one would have to review from the state of Indiana, whether there might be a role for artificial intelligence in helping sort some of this out, but that’s kind of another conversation, maybe.

Nikos Zirogiannis: We’ve actually gone down that road with not a lot of success, but maybe other colleagues in the field might do a better job on that, because, exactly, that web scraping and artificial intelligence could be very useful in sorting through those hundreds or even thousands of documents.

Daniel Raimi: Interesting. Great. A couple more questions I’d love to ask you, Nikos. This topic has been in the news over the last couple of months because of the East Palestine train derailment—clearly, a major excess emissions event there. I’m wondering if you think that event in particular might lead policymakers to focus their attention more on this topic, or whether you think it’ll fade from people’s memories as these events sometimes do.

Nikos Zirogiannis: I really hope that more attention can be paid on this issue, and this is why I’m actually very appreciative of being able to be on the podcast today and having a chance to discuss this. One of the issues that the East Palestine accident, I think, really highlighted was the need to communicate information to the public as accurately and as quickly as possible. People have the right to know if, when, and what types of pollutants they are being exposed to, and they need to know that, so that they can engage in mitigating actions. They might stay indoors, they might run their air filters, they might choose to evacuate.

I think an important message to communicate here is that facilities should be 100 percent transparent with the public if and when things go wrong, and that those reporting mechanisms that are in place are there so that we can use them if we have to. Now, I’d say, taking a step back and looking at the bigger picture here, it’s important to emphasize the health costs of air pollution. Fortunately, there were no fatalities due to the accident in East Palestine. However, there might be health impacts due to exposure that people faced, and it’s important to remember that people die every day from pollution exposure. In 2019 alone, there are estimates of about 7 million deaths around the world.

That’s about 13 percent of total global mortality attributed to air pollution, and we often don’t think about those deaths, because air pollution is never listed on someone’s death certificate as the cause of death. People die from asthma—they don’t die from air pollution. People die from heart attacks—they don’t die from air pollution. But air pollution contributes, in some cases, very substantially to those causes of death. Recently, there was the first case of a nine-year-old girl in London, Ella Roberta Kissi-Debrah, that died from an asthma attack in 2013, and she was the first person ever to have air pollution listed as the cause of death on her death certificate.

This happened following a 10-year-long battle that her mother took on to specifically acknowledge that air pollution was the cause of her death. It’s important to continue, I think, to raise awareness on the effects of air pollution, especially since air pollution is something we do not see, we do not smell, but can significantly affect health—and, if I may offer an anecdote from my life—as somebody that didn’t grow up here in this country, I’m always amazed at how often—the simplest thing—people will idle their cars. I’ll drop off my daughter at a daycare in the morning, and I’ll see other parents dropping off their kids and they’ll just leave the car running the entire time they drop off, and I’m thinking, would I ever do this in Greece? I wouldn’t, because, number one, gas prices are about twice in Greece what they are in the United States, and also there’s parts of Athens where, if you leave your car idling, you might actually not find it when you come back. It might actually not be there anymore.

Daniel Raimi: I notice the same thing when I dropped my son off at daycare, too, and even when the daycare administrators send everybody notes telling them not to idle their cars, because it can exacerbate asthma, which my son has, people don’t do it. It is completely maddening.

Nikos Zirogiannis: Even when there’s a sign saying “No-Idle Zone” right there in the parking lot, it’s hard to underscore how important that is.

Daniel Raimi: Absolutely. Nikos, one more question before we go to our Top of the Stack segment, which you’ve highlighted how important this topic is for policymakers, but we also have a lot of researchers, of course, who listen to the show. What are some of the things that you think the research community can do to advance our knowledge on these issues?

Nikos Zirogiannis: In addition to the issues I mentioned earlier about things that we did not do in our work, one thing that’s important to note is that excess emissions do not appear on the National Emissions Inventory. The National Emissions Inventory is a large dataset maintained by the EPA that keeps track of all emissions from large industrial facilities across the country. This is important, because several pollution models—as they’re called, integrated assessment models—rely on the National Emissions Inventory as a source of input for emissions data.

By not including excess emissions in the National Emissions Inventory, we are systematically underestimating the magnitude of pollution releases. That’s, I would say, a nontrivial issue that we need to correct from a research perspective. It will also be interesting to study the impact of enforcement practices on the incidence of excess emissions—something that our group hasn’t done yet and could be done, since Texas does take enforcement actions against violating facilities. Unfortunately, this is something that can only be done in Texas due to the data limitations I discussed earlier.

Daniel Raimi: Right. Really interesting. This is such fascinating work, Nikos. Thank you for coming on the show and highlighting it for us. I hope people are going to get more tuned in to this topic, and, hopefully, we’ll have more data to work with in the future, but now I’d love to ask you the last question we ask all of our guests, which is to recommend something that you’ve read or watched or heard that you think is great and that you’d recommend to our listeners. What’s at the top of your literal or your metaphorical reading stack?

Nikos Zirogiannis: Absolutely. Lately, I’ve started reading a new book called The Big Myth by Naomi Oreskes and Erik Conway, and it’s a very fascinating historical account of the intense propaganda and misinformation campaigns that were launched by multiple industries in the early twentieth century—manufacturers, electric utilities. These were campaigns that tried to advocate against government regulation—what the authors called fundamental market capitalism—and, as someone that works in a school of public affairs and also as someone that did not grow up in this country, it’s very interesting for me to learn all those types of information that people were exposed to in the 1930s and the 1940s that could have affected their perceptions about the validity and the use of government regulations. That’s something I would recommend to listeners.

Daniel Raimi: Yeah, sounds really fascinating, and I think people have recommended Naomi Oreskes’s previous work, as well, and some of her other books.

Nikos Zirogiannis: Absolutely.

Daniel Raimi: Great. Well, one more time, Nikos Zirogiannis from Indiana University, the O’Neill School, Thank you so much for joining us today on Resources Radio.

Nikos Zirogiannis: Daniel, thank you very much. I appreciate the opportunity to be here.

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