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Seanad Éireann debate -
Tuesday, 22 Nov 2022

Vol. 290 No. 3

Nithe i dtosach suíonna - Commencement Matters (Resumed)

I thank the Cathaoirleach and welcome our distinguished guests.

I thank Senator O'Loughlin for raising this matter, to which I will reply on behalf of the Minister of State, Deputy O'Donovan. I will explain what the OPW does on behalf of the Minister for Public Expenditure and Reform in this area.

Section 28 of the State Property Act 1954 provides that property held by a dissolved company at the time of its dissolution becomes property of the State in the name of the Minister for Public Expenditure and Reform. It was previously in the name of the Minister for Finance but a transfer of functions order in 2011 transferred responsibility to the Minister for Public Expenditure and Reform. A legislative exception to this property becoming vested in the Minister is where the property was held on trust for another at the time of dissolution. The legislation provides for both real and personal property and since 2005, the OPW has dealt with real property that devolves to the State. Management of personal property rests with the Department of Public Expenditure and Reform.

Since the early 1990s, the number of companies incorporated has risen significantly from approximately 8,000 per annum in the 1980s to more than 18,000 per annum from 2010 to 2019. There has also been a corresponding increase in the number of companies dissolved where the average number of companies dissolved in the decade 2010-19 was more than 13,000 per year. Only a small proportion of dissolved companies hold real property. There is no register of properties held by dissolved companies at the time of their dissolution. The OPW only becomes aware of property that has devolved to the State when an issue needs to be resolved.

Another important legislative provision to note is that companies can be restored to the register for up to 20 years after dissolution. If the company is restored, the property reverts to the company as though it had never devolved to the State. Therefore property can pass into and out of State ownership without any involvement or without the explicit knowledge of the State. The provision on company restoration significantly restricts what the OPW can do with this property. This is because the Minister's interest is defeasible by company restoration for a significant period. A significant proportion of dissolved company property is the common areas of housing developments such as roads, footpaths, green areas, residual interests in long-term leases and so on. Most of this property is of little value and, in some cases, the dissolution of the developer company causes it to become State property. Another situation is that property is transferred into the ownership of a management company that was allowed to be dissolved. Ownership by the State does not prevent these areas being taken in charge by local authorities. It should be noted that the OPW is not the occupier and does not take over responsibility for the maintenance of these areas.

The circumstances of property other than common areas of housing developments can be unique. A smaller, but not insignificant, category is where former directors remain in occupation but have sometimes inadvertently allowed the company to be dissolved. They often approach the OPW seeking a waiver of the Minister's interests under section 31 of the State Property Act 1954. The power to waive his interest is the only specific power granted to the Minister in the relevant part of the Act. Former directors as a rule are not deemed to be entitled to a waiver. Very few properties of value devolve to the State, especially properties on which there is no competing claim. Despite the volume of properties devolving to the State as a result of company dissolution, the OPW on behalf of the Minister is not managing a portfolio of valuable properties.

Each situation and application to waive property rights is examined carefully in consultation with the Chief State Solicitor's office, as to whether it is an application for a waiver or a situation that involves risk or liability. It is a complex legal area and as such there are specific matters to be considered such as ownership and property rights before a decision can be taken for the Minister to waive ownership of such properties.

In the past five years a total of ten waivers were granted and the total number for the five years 2018-2022 was 30 waivers.

Let us be clear. We are not looking for a waiver in a situation like this. We want to know who owns the land. The Minister of State clarified that the OPW deals with real property that devolves to the State. Therefore, I feel this is in the hands of the OPW. In this instance, the company is not restored so the property has not revert to the company. The Minister of State made the point that in the area of dissolved-company property, the common areas of housing developments are of little value. This is a tiny strip. It is of no value. Is this a situation where the local authority should take this in charge? The estate has taken it in charge. If that is the case, the Minister of State might be able to respond that the council could take this in charge as a petition from the housing estate. I appreciate the area is complex. Again I specify that we are not seeking a waiver but rather want to ensure both residents and the ESB have access to this tiny strip of land and that we are able to resolve the current issue.

The Senator mentioned she had spoken to the Department of Finance. I clarified that the Department of Public Expenditure and Reform has responsibility and that the OPW is the section of that Department which deals with this. Second, a company can be restored for up to 20 years after dissolution. That is the reason the State is reluctant to carry out any development or works on bits of land it may own during that period.

With respect to taking in charge, the note I have tells me that ownership by the State does not prevent these areas being taken in charge by local authorities and that it is a complex legal area. It is a question for local government. It should be asked directly of the executive, the Minister of State, Deputy Peter Burke, or the Department of Housing, Local Government and Heritage. I would be happy to help with any other question the Senator wants to send to me or to the Minister of State, Deputy O'Donovan.

As a former councillor, I was involved in many taking in charge episodes, ransom strips, pieces of land and disputes between neighbours over small pieces of land. I understand that even if it does not have a particular financial value, it can have a significant social value or cause a lot of disruption within a community.

Road Tolls

I welcome the Minister of State to the House to discuss the issue of the proposal by Transport Infrastructure Ireland, TII, to increase toll charges on many of our national routes. There are currently ten toll roads on the national road network, eight of which are operated under a public-private partnership, PPP, model and two of which are operated directly on behalf of TII, namely, the M50 and the Dublin Port Tunnel. TII recently announced that it plans to increase toll charges on nine of these roads in line with inflation from 1 January 2023. The only exception to this will be the Dublin Port Tunnel which will be the only toll road not to face an increase. Charges relate to those driving cars with charges higher again for those driving vans, buses and heavy goods vehicles, HGVs. The Government needs to step in to ensure this does not happen.

As the Minister of State will be aware, we are in the middle of a cost-of-living crisis and the Government's emphasis to date - and rightly so - has been on measures to reduce the cost of public services for many hard-pressed families and businesses. The decision of TII flies in the face of Government policy. These private companies are already making millions of euro. It begs the question, how can TII justify increasing toll charges to the maximum permitted value at this point in time?

Just last month, for example, the M3 toll operator reported €11 million in profit for the previous financial year. Many commuters are totally dependent on the private car. In places like County Monaghan, where I come from, there is no reliable public service transport available to people, so they have no option but to use their car and hit the road. Increasing these charges at this point in time will have the effect of people avoiding these toll charges and taking roads through small villages and towns; that is not what we are looking to see happen. It is clear that the Government needs to call a halt to this. Common sense needs to prevail. I look forward to the Minister of State's response; I hope it will indicate that process is under way.

The Minister for Transport has the responsibility for overall policy and Exchequer funding in relation to the national roads programme. Once funding arrangements have been put in place with Transport Infrastructure Ireland, TII, under the Roads Acts 1993 to 2015 and in line with the national development plan, the operation and management of individual national roads is a matter for TII in conjunction with the local authorities concerned. Matters relating to day-to-day operations regarding national roads, including toll roads and the establishment of a system of tolls, are a statutory function of TII. More specifically, the statutory power to levy tolls, make toll bye-laws and enter into agreements with private investors are vested in TII under Part V of the Roads Act 1993, as amended. The Act does not provide for a consultative function with the Minister regarding specific toll increases.

There are 11 toll roads in the State and of these, ten are on the national road network. Of the ten tolls on the national road network, two are essentially public tolls, namely, the M50 and the Dublin tunnel. Revenue from these tolls is collected directly for TII by operating companies under contract to TII. These revenues are invested by TII in the operation and maintenance of the national road network. The other eight roads are public private partnership, PPP, roads which were constructed and are now operated and maintained under long-term contracts with TII. Revenue generated by these roads is collected by the PPP company and is then used to repay loans arising from the construction of the road and to fund ongoing operations and maintenance activities. Tolls on the eight PPP roads and the M50 were increased at the start of this year, which was the first increase in toll rates for motor cars since 2013.

The setting of tolls is a statutory function of Transport Infrastructure Ireland. In line with that statutory function, the TII board agreed to a toll increase in 2023 on the M50. TII has also reviewed and agreed with the toll increases submitted by the PPP companies for the eight PPP routes. There will be no changes to toll rates for the Dublin tunnel. Tolls are due to increase because of the consumer price index, CPI, calculations carried out for each year. The CPI increased by 8.6% between August 2021 and August 2022; this has resulted in increased tolls on all eight PPP schemes and on the M50. The bye-laws for each individual toll scheme set out the basis for calculating the maximum toll for each year. On the M50, a deferral of the toll increase would require funding to be allocated from other national roads projects and would reduce funding for asset management and renewal activities across the rest of the network. This toll revenue plays a key role in protecting and maintaining our national road network and it safeguards the investments which have taken place in the network over recent decades. As required by the legislation, TII will shortly publish details of the proposals in the national media prior to their introduction.

I thank the Minister of State for his response. If one were to go by speculation and comment from our political leaders in recent days, it would seem that this matter is now being reconsidered. I welcome that. I do not need to tell the Minister of State how difficult times are for many families, workers and businesses. The Government has intervened in the cost of public services; that is to be welcomed and it is good to see. This is another area where Government can intervene and I would welcome it were it to do so. Apart from the additional financial burden that would be placed on people, it will also result in people using alternative routes to avoid motorways, thereby resulting in our villages and towns being clogged up, which is the last thing we need.

I hope common sense will prevail. I look forward to an outcometo which we can all sign up.

I thank the Senator. I appreciate his point that if the toll is set too high, it could lead to traffic entering city centres. Unfortunately, I was not at the Cabinet meeting today to know whether a decision was taken or whether there was a discussion on this, but I will update the Senator on the matter later today. The Government has identified transport as an area to target for cost-of-living mitigation measures. There was a reduction in public transport fares, both a 20% reduction for everybody and a 50% reduction for young people. Actions were taken like the licensed haulage emergency support scheme and there were reductions in the excise duty of 20 cent on petrol per litre and 50 cent on diesel per litre. Regarding tolls, as I outlined, it is a statutory function of TII and it is under contract with the operator; that does not mean nothing can be done, but it is the TII's statutory area. I think the Senator understands that. What the State will do in response, we will have to wait and see. I will apprise the Senator as soon as I have more information.

I welcome Councillor Shelly Herterich Quinn from Galway County Council. She is welcome today to see the two Chambers in operation. I thank her for coming in and for the questions, queries, advice and support she has given us. We appreciate it. The Commencement matter will be taken by the Minister of State at the Department of Agriculture, Food and the Marine, Senator Hackett. I call Senator Boyhan.

I join the Cathaoirleach in welcoming the women that are in today, particularly sitting councillors from the women's caucus. They are welcome to Leinster House. It is great to see them; we do not see enough of them. As I said earlier in the dining room, I look forward to many of them competing in the next elections, be they Dáil or Seanad elections. We can have the women's caucus and other groups but it is important that we bring them into the centre of politics and into elections.

I asked the Minister to make a statement on the inclusion of genetically-modified, GM, ingredients used in animal feedstuff used for sheep, cattle and poultry and if the Department of Agriculture, Food and the Marine would confirm the level of GM foodstuffs in the agricultural sector. That was somewhat modified by the Commencement Matterbefore us. Genetically-modified food is a big issue; it is a controversial one for some. It was initially brought to my attention by the Irish Rural Association. I will read a post from its Facebook page because it is the kernel of the issue, "So now we are asking for a bit of help from you all out there who may use animal feedstuff in bags for cattle, sheep, hens, etc. Have you actually read the label?" On close examination, many of the feeds have a label that states, "Produced from genetically-modified soya beans... Does that bother anyone?" It raises the questions, should we know more about it? Is the labelling clear enough, is it big enough? Are people aware of it? It goes on to state, "As for GM foods and crops, the hypocrisy on the part of both Ireland and EU is stunning. While we pat ourselves on the back for banning the growing of GM crops, we import GM corn and soya by the millions of tonnes".

How do Bord Bia, Teagasc and the Department of Agriculture, Food and the Marine square the circle in terms of the export of Irish beef when on average the contents of a bag of winter feed for beef consists of 94% of genetically modified, GM, corn, soya and alfalfa. That is the kernel of the issue and we need more education about it. It is not banned but we need greater labelling. I am more interested to know how the Department quantifies the amount. Does it keep a record of the amount because that is really important? What is going on in terms of Teagasc, the Department of Agriculture, Food and the Marine and Bord Bia on the monitoring of GM food and GM foodstuffs?

I thank Senator Boyhan for raising this matter. In Ireland more than 80% of animal feed for ruminants is provided by grass, hay and silage, complemented where appropriate by compound feeds. From an animal feed perspective, the pig, poultry and dairy sectors in particular rely on high-protein feed rations that are primarily made up of soya bean and maize by-products. Ireland has a limited capacity to grow certain protein crops and is therefore more dependent on feed imports relative to other EU member states. Climatic conditions in Ireland are traditionally not suited to the cultivation of soya bean although improvements in crop breeding and the availability of new varieties may change that. Therefore we are particularly dependent on the global market for supplies of high-quality vegetable protein.

Total annual feed production in 2021 was 5.4 million tonnes, an increase of 6% on the previous year, of which 1.3 million tonnes was home-grown, mainly cereals. In 2021 4.1 million tonnes of feed material was imported which was a reduction of 3% compared to 2020. Of the 4.1 million tonnes imported, approximately 75% is sourced from third countries, mainly Argentina, the USA, the UK, Canada, Brazil and, historically, Ukraine. Significant quantities of maize and oilseed rape meal are also imported from EU member states.

Some 2.3 million tonnes of imported feed from third countries was genetically modified, representing 42% of the total animal feed production. The main genetically modified feeds imported are maize and maize by-products, soya bean meal and soya hulls. More than 1 million tonnes of this imported genetically modified feed was maize or maize by-products, distillers dry grains and maize gluten feed. Approximately 800,000 tonnes was soya bean and soya meal.

These consignments are imported from genetically modified, GM, producing regions especially in the USA, Argentina, Brazil, and Canada. It is important to the Irish agriculture industry, especially the sectors requiring rations with high-protein content, that there is a consistent supply of quality feed that is not subject to delays as there is limited scope for alternative protein substitution from home or from EU-grown high-protein crops.

In terms of the use of genetically modified organisms, GMOs, in feed, the reality is that the feed materials containing GM make up the bulk of the market and provide the lowest cost source of proteins for feed manufacturers to use in their products. It should be borne in mind that there is a significant additional cost of approximately €60 to €100 per tonne for non-GM feed which can leave livestock production in Ireland at a competitive disadvantage compared to other countries that have the capacity to produce soya and other protein crops. This price differential would have a trickle-down effect on the overall feed prices which have already seen significant rises since the outbreak of the war in Ukraine.

The EU has a legislative framework in place for the authorisation of feed products consisting of, or containing, genetically modified ingredients on the markets of member states. Only GM feed that has been authorised by the EU can be placed on that market. All applications for authorisation by the EU to place feed products consisting of, or containing, genetically modified ingredients on the markets of member states are considered individually.

Government policy is positive but precautionary on biotechnology and a common voting position is adopted by Ireland for food and feed on the basis of a favourable opinion from the European Food Safety Authority and the Food Safety Authority of Ireland. Advance notification of feed imports is a legal requirement and imports containing GM are notified accordingly. My Department carries out risk-based analysis and testing for the presence of authorised and non-authorised GM in feed imports.

The real substance is in the last two lines, that is, that the Irish policy is cautious and that random tests are carried out. I thank the Minister of State for her comprehensive reply. The three important things from that are that the Government needs to demonstrate its caution, that we need to see more statistics in terms of the testing and that is something I can take up with the agriculture committee, of which I am a member, and that many people are not aware of GM feedstuffs in animals. We talk at great length about not growing GM produce in this country but we are feeding our animals - sheep, poultry and cattle for beef - with this modified food.

There is a little bit of misunderstanding but we need bigger labelling and more education and to be upfront and open, honest and transparent with the fact that we are using GM foods to feed animals in this country. I thank the Minister of State.

I thank Senator Boyhan and I take his points on board. We have limited capacity to grow our own and more growing of our own is something that the Department has tried to support in the past year, as we cannot grow GM food in Ireland. In this regard the Minister, Deputy McConalogue, recently announced a second tillage incentive scheme which has as its focus the purpose of increasing the amount of grain and forage that will be essentially home-grown, as in grown here in Ireland with the aim of converting grassland to tillage use. It is widely acknowledged that the first tillage incentive scheme contributed approximately a 6% increase in tillage area or an additional 20,000 ha in 2022. In addition to this the protein aid scheme which is a payment to farmers for growing other protein crops such as beans, peas and lupins also works to increase domestic production of protein crops. These crops, which are also nitrogen fixing, provide important environmental benefits as a co-benefit. We need to grow more of our own and we are aspiring to do so.

Agriculture Industry

I welcome the Minister of State and thank her for coming to the House. I requested this Commencement debate because it is a very important topic for 35,000 sheep farmers in the country and is particularly of huge interest for farmers in County Louth who have nearly 70,000 sheep between them. Today I am asking what actions have been taken by the Department since the wool feasibility study was published last July and for an update on the establishment of the Irish wool council to which the Department has committed €30,000 to help establish.

I do not have to tell the Minister of State about what an incredible product wool is but for the record it is one of the most regenerative and sustainable products known to us. The fleece grows every year and needs to be sheared off to keep the sheep in good condition. Wool is such a valuable resource and until modern times was the very fabric of our clothes and the bedding we slept in. Wool lasts longer than synthetic fibres and requires washing at lower temperatures. It is recyclable, biodegradable and does not contribute to any microplastic pollution. Wool can act as a fertiliser, releasing nutrients and carbon back into the soil when disposed of. It does not accumulate in landfill or oceans as it biodegrades naturally. There are so many other reasons to be positive about wool but sadly we are failing to act swiftly enough on this in so many ways.

The first is by not utilising the product adequately; the second is by not educating consumers effectively; the third is by not creating a market and supporting and assisting producers and processors and the final way is by not supporting the farmers to deal with the wool. The ignoring of the situation by successive Governments has led to a situation where the value of wool is so low it is costing the farmer to clip their sheep and they do not make any profit on the product. This is a greatest of all sins in my opinion. I am old enough to remember selling wool at the end of the summer and we would pick up every scrap of wool off the ground and our fields because it was worth something. It was important and it was valuable. Now there is no support from the Department of Agriculture, Food and the Marine to deal with this.

There is a short-term way to support farmers. They could be supported by making an additional payment to the new sheep improvement scheme that was opened by the Department today. It could specifically assist farmers with the costs associated with shearing and handling wool, and sorting out the dagging and the bagging of wool in a clean way, which has to be done for the wool merchant. It would be a really important way and a positive opportunity to assist and support farmers.

As the Minister of State is probably aware, Ulster Wool scheme is a farmer-owned co-operative has been hailed as an example of collective marketing and praised for its success in improving prices for sheep farmers in Northern Ireland. In Northern Ireland, they are selling wool through the Ulster Wool scheme and there are huge opportunities for all of us to work together to develop a unique brand for Irish wool. I believe in this work and that is why I have asked the Minister of State for an update today because it is really important and I have no doubt but that the Minister of State is a big advocate and a pusher of this project.

I thank Senator McGreehan for raising this issue, which is as close to her heart as it is to mine. The sheep sector is extremely important to the Cooley Peninsula and to County Louth as a whole. I agree wholeheartedly with all the positive benefits she has outlined in the context of wool.

The production of wool is an important aspect of the agriculture industry. According to data from the 2021 sheep census, there were just over 4 million sheep kept in registered herds in the country on 31 December 2021. This represents an increase of approximately 120,000 on the total numbers recorded for 2020. The sheep census also indicates an increase in the number of registered herds from 35,500 in 2020 to over 42,000 in 2021. Approximately 3 million sheep were slaughtered in 2021. In terms of producing wool for sale, farmers generally outsource the sheering of sheep and the selling of wool to agents. Officials in the Department of Agriculture, Food and the Marine oversee and inspect 41 approved and registered wool stores where wool is held while awaiting sale. Ireland has always had a reputation for producing wool. Irish genetic breeding standards, sheep care requirements and the availability of quality grass, water and nutritional supplementation on Irish sheep farms all contribute to this reputation. Irish sheep have a high animal health status. They are free from diseases such as sheep pox that, when present, downgrade wool quality. Furthermore, Irish sheep farmers follow strict biosecurity and quality assurance guidelines. The animal husbandry on Irish sheep farms also ensures that programmes are in place to control ectoparasites such as sheep scab that can downgrade wool quality where not controlled. All of these factors contribute to the excellent quality of Irish wool.

Most wool produced in Ireland is sold at the Bradford wool market in the UK. Current prices are disappointingly low. Industry sources have stated that wool prices for this year are similar to previous years, at around 20 cent per kilo for lowland wool. I know, first hand, how disappointing this is for sheep farmers who do such tremendous work to ensure the fleece is in good condition at shearing time.

One of the commitments in the current programme for Government is to conduct a review of the potential demand for wool-based products such as for insulation and fertilisers in domestic and international markets. Despite its versatility in many industries, wool prices remain low. In order to address this issue and seek a more favourable outlook for the future, I initiated a comprehensive review of the wool industry to explore market opportunities in order to maximise the potential of this valuable natural resource. Following the allocation of €100,000 funding in budget 2021 for this review, a public consultation process was initiated in March 2021 to determine the terms of reference and to invite interested stakeholders to submit their proposals on the potential market opportunities for wool products. There were 45 submissions made.

Following a competitive public procurement procedure, the Agile Executive, a consortium made up of experts from Munster Technological University and Donegal Yarns, was appointed in November 2021 to carry out the wool review and examine the submissions received under the public consultation process. The Agile Executive produced a report on the findings of the review. It was published in July 2022. This independently compiled report contains a number of findings and recommendations, including in respect of potential funding streams, market opportunities and multiple areas for additional research and development for wool. One of the main recommendations was the establishment of an independent wool council, led by industry, that would develop and promote Irish wool domestically and internationally and bring together multiple stakeholders to foster collaboration, innovation and scaling activities in the wool sector. It is envisaged that this council would be a forum where stakeholders could further examine and explore the potential uses for wool identified in the wool feasibility report.

When I launched the report, I called on stakeholders and industry to come together to form an independent, stakeholder-led wool council. I also committed that, following the formation by industry of a wool council representative of a broad range of stakeholders, my Department would provide financial assistance of €30,000 towards the initial set-up costs of the group. I am pleased to inform the House that a group of stakeholders from across the wool industry have taken the initial steps towards the formation of a wool council. My officials and I have been engaging with that group to ensure that farm organisations will form a part of this council along with other stakeholders.

I apologise for running over time a bit. I will be as quick as I can. Late last week, I received confirmation that the initial group of stakeholders which contacted my Department had engaged with farm organisations with a view to their inclusion in the council. The next logical step is a meeting between the relevant stakeholders and for the stakeholders to agree among themselves their common aims as a group, as well as agreeing the means by which the group wishes to go about completing the necessary formalities associated with its establishment.

The next logical step is a meeting between the relevant stakeholders and for the stakeholders to agree among themselves their common aims as a group and the means by which it wishes to go about completing the necessary formalities associated with its establishment. While such formalities are likely to include proposed corporate governance structures, I have written to a representative of the stakeholders to suggest the Department give a brief presentation at their initial meeting as to the requirements that will need to be satisfied from the Department's perspective in order for the seed funding towards the establishment of the wool council to be drawn down.

An independent stakeholder-led Irish wool council is something we need to see established in the short term to help drive our ambitions for the industry, so I have suggested in the same correspondence that this initial meeting of stakeholders take place next month. The industry-led wool council will create a roadmap that will lead to greater returns for this natural and sustainable product. Having a wide range of interests represented in a body that acts as an Irish wool champion for the entire sector will help boost the industry and create a clearer vision of the future of Irish wool. It is my hope the council can build on the valuable findings of that report and create a pathway towards maximising the true potential of Irish wool. This can be an exciting time for the wool industry and we must all work hard together to deliver on that.

I thank the Minister of State. It is good news that the meeting will start next month and I look forward to it. It is very important. Unfortunately, the wheels of bureaucracy turn slowly, and I reiterate there is a space for supporting sheep farmers in the new sheep improvement scheme. Being able to shear sheep is a sheep welfare issue. When the Minister of State said agents usually shear sheep, she made it sound as though there is a massive output, but it is usually a young farmer who shears a few other farmers' sheep. It is not a large agency that comes in to do it. Alternatively, it is done by farmers themselves, as is the case in the Cooley Peninsula. In any event, it costs a great deal to look after these sheep and shear their wool.

I look forward to further updates on this because it is very important.

I agree there is a great opportunity here. I recently saw some photos of what could have been an organic horticultural grower that was using wool in its polytunnels as the mulch and insulator, which it had bought from a neighbouring farmer, with nice symbiosis. That is just one example, and there are plenty of others throughout the country. I often get correspondence asking why we do not do this.

The opportunity is there and the sooner we get the wool council up and running, the better the outlook for our sheep farmers and that wonderful wool, which is always of high quality.

Sitting suspended at 3.18 p.m. and resumed at 3.33 p.m.
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