Frequently Asked Questions


Tune-Up Requirement

Tune-Up Applicability

Tune-Up Costs


Alternative Compliance, Waivers, & Extensions 

Tune-Up Specialist

Tune-Up Requirements and the Washington State Clean Buildings Performance Standard (CBPS) 



Why is the City requiring Building Tune-Ups?
Building energy use accounts for more than 20% of Seattle's GHG emissions. To meet the targets established in Seattle's Climate Action Plan, we must reduce emissions from buildings by 82%. Building Tune-Ups will contribute toward Seattle's goal to be carbon neutral by 2050.  

Why didn't the city make Tune-Ups voluntary first?
The City has had voluntary energy efficiency incentive programs in place for decades. These programs have demonstrated progress yet to reach our Climate Action Plan goals we need widespread action, and City leaders have asked us to take bold steps, including the Tune-Ups mandate.

How does the Tune-Ups policy demonstrate Seattle's leadership?
The Tune-Ups requirement is a new approach to energy efficiency in existing buildings, which are a significant source of carbon pollution in cities. While other cities have auditing or retro-commissioning requirements, Seattle's Building Tune-Ups mandate requires that operation and maintenance work be completed to achieve energy efficiency. The City is leading by example: during the first cycle of required tune-ups, three of the four groups of municipal buildings complied one year ahead of private sector compliance deadlines.  See Resolution 31652 for more information. 

Do other cities have similar regulations?
Yes, many other cities including New York, San Francisco, Atlanta, and Los Angeles have existing building energy efficiency legislation. See www.buildingrating.org for additional information.

Tune-Up Requirement

Why is Seattle requiring two cycles of tune-ups 5 years apart?
While tune-ups generate energy savings, those savings can taper off over time as building systems are adjusted or additional maintenance is required. Typically, payback is expected within 3 years, and by requiring two cycles of tune-ups 5 years apart, owners should be able to reap financial rewards from their tune-up.  

Why are water measures included in Tune-Ups?
Tune-ups are a holistic approach to building energy savings, and water savings provide energy savings. Having a professional Tune-Up Specialist assess your building allows you to find new opportunities to waste less and save more.  

What are Corrective Actions?
Appropriate Corrective Actions are operational and/or maintenance actions intended to improve energy or water efficiency or to correct an operational deficiency. An appropriate maintenance action is one that is commonly considered to be standard or normal maintenance. An appropriate operational adjustment can be made to existing equipment without purchasing new equipment. Appropriate Corrective Actions are listed in the Directors Rule, Section 11.

When should I use "Extenuating Circumstances" in a Tune-Up assessment element response?
Our expectation is that when you observe a deficiency for a Tune-Up assessment element with a Required Corrective Action, you implement the corrective action to fix the deficiency. This must be done before you submit to the City for review. There are rare cases, however, when corrective action is not possible due to extenuating circumstances. The following are examples of such:

-If the property use (i.e. hotel, lab) requires 24/7 conditioning or ventilation, then reducing the schedule may not be possible.

-Likewise, it may not be possible to reduce DHW temperature to 120°F if a commercial kitchen or process requires higher.

-Utilizing optimal start/stop may not be feasible due to either 24/7 operation or controls that don't allow it.

-Safety or security concerns may prevent certain corrective actions from being implemented such as reducing lighting levels.

It is never acceptable to submit a Tune-Up using "Extenuating Circumstances" due to high cost or long payback period. Although the hope is for Tune-Ups to be low or no-cost corrective actions, there is no dollar or payback period threshold for determining whether a Required Corrective Action must be implemented. If you're in a situation where you don't know if you should use Extenuating Circumstances, please reach out to us as early in the process as possible at BuildingTuneUps@seattle.gov to discuss.

Can I sample a portion of my building equipment during the building assessment/walk-through?
Yes, a Tune-Up Specialist may review a sample of multiple pieces of repetitive, identical equipment (such as fan coils, plumbing fixtures, or lighting sensors on the same schedules). The sample must include at least 12% of each identical pieces of equipment, and at least 10 of each in buildings 50,000-99,999 square feet, and at least 20 of each in buildings 100,000 square feet or larger. We will ask the Tune-Up Specialist to describe their sampling approach in the Tune-Up Summary Report.

How should I account for a data center in my benchmarking report (in Portfolio Manager)?
As part of the Tune-Up, the building's Portfolio Manager account must be reviewed by the Tune-Up Specialist to verify that it has been set up properly. If you have a data center, please follow the below instructions to ensure your data center meter is input correctly:

(1) If the Data Center is not independently metered, the user should select:
a. Apply Data Center Energy Estimates = "Yes", and
b. IT Energy Configuration = "No IT Energy Configuration Selected"

In this situation, Portfolio Manager will apply an estimate of the energy consumption associated with the Data Center, and remove this estimated energy to evaluate the building without the data center. If estimates are used for data centers over 10% of the building's GFA, there is a cap applied (the estimate will be for a data center as if it were only 10% of the building's GFA). An ENERGY STAR score and certification will only be available if the GFA of the data center and all other non-scorable property types in the building don't exceed 25% of the property's GFA.

(2) If the Data Center is independently metered, the user should select:
a. Apply Data Center Energy Estimates = "No", and
b. IT Energy Configuration = one of the following configurations (and associated meter types):

IT Energy Configuration Meter Type
Uninterruptible Power Supply (UPS) Supports Only IT Equipment (Preferred) Uninterruptible Power Supply (UPS) Output Meter
UPS, including non-IT load less than 10% Uninterruptible Power Supply (UPS) Output Meter
UPS, including non-IT load greater than 10% (non-IT load is submetered and subtracted) Uninterruptible Power Supply (UPS) Output Meter
UPS, including non-IT load greater than 10% - load not submetered Power Distribution Unit (PDU) Input Meter

In this situation, because the data center is independently metered, Portfolio Manager will be able to remove a more accurate amount of energy associated with the Data Center, allowing the building to also be evaluated more accurately without the data center. This is preferred. An ENERGY STAR score and certification is available.

More details on how to input data centers in Portfolio Manager can be found here.

Tune-Up Applicability

What is a commercial condo? And does it have to comply
A commercial condo is a building or portion of a building comprised of individually owned commercial units that are part of a larger multi-unit building with various owners, and managed by an owner's association. Yes, they must comply if the commercial part of the building is greater than 50,000 SF (excluding parking space). In the case of a commercial condo, the owner's association is responsible for compliance.

What buildings are not subject to the Tune-Ups mandate?

  • Single-family residential buildings.
  • Multifamily residential buildings that contain less than 50,000 square feet of nonresidential space.
  • Mixed-use buildings with less than 50,000 square feet of nonresidential space.
  • Buildings used primarily for manufacturing or industrial uses, with a Certificate of Occupancy (CO) or construction permit showing at least 50% of the gross square footage is classified under the Seattle Building Code as Factory Industrial Group F.  

Do the spaces that my tenants use have to do a Tune-Up?
Yes - and you as the building owner are responsible for their compliance. The only exception for compliance is tenant spaces, 5,000 square feet or smaller, occupied by a tenant and where the tenant owns, operates, and maintains the mechanical equipment (e.g. heating, ventilation, air conditioning).  

How are parking spaces treated in this requirement?
A Tune-Up must include a review of the lighting, ventilation, and other system in the parking area and other unconditioned spaces. Parking space should be excluded from the building square footage when determining if your building is required to comply (and by when).  

I'm tearing down my building - do I have to comply?
Buildings scheduled to be demolished within three years of the tune-up compliance date can apply for a waiver for a tune-up cycle. A demolition or deconstruction permit must be active, or issued no more than two years prior to the Tune-Up compliance date.  

I just bought this building - do I have to comply?
If you purchased the building within one year prior to or on the compliance deadline (October 1st of the required compliance year), you may apply for a one-year deadline extension. You will not be held to the requirement of submitting extension requests six months in advance if you did not own the building at that time.

Tune-Up Costs

Can I get a one-year extension since our budgeting cycle doesn't align with the scheduled Tune-Ups compliance date?
No, the City does not grant extensions or exemptions due to budget/schedule constraints. However, if you are experiencing financial distress, please review the details and requirements for a Waiver.

How much will a Tune-Up assessment walk-through cost?
It depends on your building size and the complexity of your building's systems. The Tune-Ups Specialist you select should provide you with a general estimate of the cost based on the size of your building and your mechanical systems.

What should I use for a budget estimate?
The walk-through and the Corrective Tune-Up Actions are separate processes that will vary based on the size and complexity of your building, and its mechanical systems. Required Tune-Up Corrective Actions will be based on assessment findings.   

Is there a dollar limit on what you need to spend on a Tune-Up?
No, there's not.

How much energy will I save by doing a Tune-Up?
It varies by building and mechanical systems, but on average, tune-ups save 10-15% in energy and typically payback within 2-3 years per research conducted by PNNL's Building Re-tuning Program.

Are cost calculations required as part of the Tune-Up?
No. Some building owners may voluntarily choose to add that information to their scope of work with a Tune-Up Specialist, but that information will not be reported to the City or used as a basis for what Corrective Actions are needed.  

Is there a fee to file my tune-up report?
No, at this time, there is no cost to file the Tune-Up Summary Report.  

Do I have to pay for Tune-Up work in tenant spaces? Can I pass the fees on to my tenant(s)?
The City cannot get involved in contract issues. How costs are recovered is a decision between landlord and tenant based on lease terms, or other arrangements you may have with your tenants.  

Are there incentive programs available to assist with the cost of conducting a Tune-Up?
Puget Sound Energy (PSE) has a Tune-Up incentive program for buildings with PSE gas heating. See their website for program requirements and eligibility details. 

Please check with your utility company about incentive programs that may facilitate compliance with Building Tune-Ups via one of our Alternative Compliance pathways. There is potential to achieve even deeper energy savings with existing building commissioning and pay for performance programs.


What happens if I don't comply?
Our primary goal is compliance. While the City of Seattle has the legal authority to assess fines for non-compliance, we have designed the Building Tune-Ups policy with a variety of compliance pathways and staggered deadlines. Should a building owner fail to comply with the regulation by the reporting due date, the City will issue a warning notice outlining potential fines for continued non-compliance. Fines are associated by building size in two phases. More details see our Enforcement page.

Alternative Compliance, Waivers, & Extensions 

What about buildings that are already great energy performers?
We recognize that many building owners are making great strides toward improving energy efficiency. To allow flexibility for owners, alternative compliance pathways are available, including for energy performance certifications (LEED O+M, ENERGY STAR, Living Building) or for completing work similar to a tune-up, such as a retro-commissioning project. See OSE Director's Rule 2016-01 for additional information.

Will ENERGY STAR Certification be accepted for Second Cycle Tune-Up Alternative Compliance?
Yes, if your certified ENERGY STAR score reflects the proper updates required by the EPA to account for changes in building operations post the COVID-19 pandemic. See Seattle benchmarking FAQ on how to account for COVID-19 operational impacts in annual benchmarking reports.*

The building’s certification must include the whole building’s energy use in the Portfolio Manager record and not exempt any high energy space uses, have a qualifying score of 90 or above in buildings equal to or larger than 100,000 square feet and 85 or above in buildings less than 100,000 square feet. Qualifying certified ENERGY STAR scores must be attained in one of the two years prior to the building's tune-up compliance deadline. For example, if your 200K + SF building has a Tune-Up due 10/1/2023, ENERGY STAR Certifications must be issued in 2022 or 2021.

*Please note, many commercial buildings have operational and building use changes post COVID-19. All ENERGY STAR Certification Alternative Compliance requests will be subject to careful review to ensure building use details such as weekly operating hours, number of workers in the building on main shift, vacancy, and occupancy rate have been updated in Portfolio Manager to reflect current use details. Certification occupied percentage minimums apply to the following building types:

  • 55% minimum: Office, Financial Office, Bank Branch, and Courthouse
  • 60% minimum: Hotel

For ENERGY STAR ratings - why is the rating not 75?
The ENERGY STAR score is a screening tool that helps assess how a building is performing. We have determined the high-performance threshold based on Seattle's benchmarking data. The required threshold reflects the top 20-25% of Seattle's buildings.

My building was certified LEED for new construction (LEED NC), does that count?
No, LEED NC Certification doesn't qualify. However, all buildings constructed within the 3 years of the tune-up deadline may apply for a new construction waiver.

Can my building use LEED O+M Certification as alternative compliance?
LEED O+M Certification will no longer be accepted as an alternative compliance pathway for Seattle Building Tune-Ups. When the Director’s Rule was adopted, the LEED O+M Energy and Atmosphere point system and required prerequisites for certification were vetted for versions v2009 and v4 as alternatives to completing a building Tune-Up. However, LEED v4.1 introduced ARC to determine energy performance points and removed required prerequisites for LEED O+M Energy and Atmosphere credits, including minimum energy performance, building-level energy metering, and existing building commissioning analysis.

What is expected of an ASHRAE Level II energy audit to qualify for Alternative Compliance?
ASHRAE's "Procedures for Commercial Building Energy Audits" document, linked here, outlines the specific requirements of an ASHRAE Level II energy audit. After meeting the requirements of the Preliminary Energy-use Analysis and the Level I audit (including in-person, rather than remote, walk-through), the more rigorous Level II audit requires, amongst others, a more detailed building survey including energy consumption and peak demand analysis, a breakdown of energy end uses, an energy analysis identifying savings and cost analyses of practical energy efficiency measures (EEMs), a review of M&E design and condition and O&M practices, and a meeting with the building owner/operator to review recommendations.

Note that the Level II report produced for the owner/building operator must also be submitted as part of the Alternative Compliance request. The audit and report must be completed by an auditor meeting the Tune-Up Specialist qualifications. Additionally, to qualify for Alternative Compliance, the building owner must correct all deficiencies and implement all EEMs recommended in the Level II audit that were projected to have a simple payback of three years or less.

We just completed a large project/alteration/renovation/tenant improvement in our building. Is this considered a "Substantial Alteration" that will get us Alternative Compliance?
For a building to be eligible for the Substantial Alteration Alternative Compliance pathway, the project must be classified as "Substantial Alteration" by SDCI and have completed one of the four energy efficiency requirements within three years of the building's Tune-Up deadline. Per Seattle Energy Code (SEC) section C503.8, the four energy efficiency options provided are:

1. Fully comply with the requirements of this code for new construction
2. Envelope thermal performance within 15% of code
3. Total building performance within 10% of code
4. Operating energy alternative-negotiated between applicant and SDCI 

All buildings that have been deemed a Substantial Alteration by SDCI will have picked one of these four options and demonstrated energy savings to SDCI in a pre-submittal conference. You should be able to produce evidence of Substantial Alteration and will know that your chosen energy efficiency option was implemented per SEC C503.8. If you have more questions to what makes a project Substantial or not, please consult SDCI's Public Resource Center.

What type of supporting documentation should I submit for Ongoing Commissioning?
To meet the requirements of Alternative Compliance via Ongoing Commissioning, all five of the following systems must be actively monitored and continuously commissioned: (1) Heating, (2) Cooling, (3) Ventilation, (4) Domestic Hot Water, and (5) Lighting*

You must submit, along with your Alternative Compliance Request, eight quarterly reports for a continuous two-year period that demonstrate how your facility addresses faults/alarms detected by your Ongoing Commissioning process. The two-year period must occur during the three years prior to the Tune-Up due date. Each report should be a representative sample of that quarter (perhaps a few days or a week of data), and must contain at a minimum the following:

1. Type of faults/issues detected
2. When faults/issues were detected
3. Location of faults/issues
4. Work Order #
5. Staff/vendor notes on what was done to remedy the faults/issues
6. Date and time of corrections/repairs

Ongoing commissioning processes that have a late start are allowed to submit no less than 6 quarterly reports by the alternative compliance deadline and then later submit the last 2 quarterly reports by the tune-up compliance deadline.

*For lighting not tied into OCx software system, night walkthroughs or data logging are sufficient. Please provide documentation demonstrating that regular night walkthroughs or data logging occurred during each of the eight quarters. This should show when the work was done and what the findings were. If deficiencies were found, please also include how and when they were corrected.

Can I apply for a Low Occupancy Extension if tenant occupancy is low?
In most cases, no. The Low Occupancy Extension is designed for cases when the building is less than 50% leased. There must be "physical vacancy" in at least 50% of the building rather than a tenant change in operations that may result in fewer people in a space at a given time such as an increase in telecommuting workers. Buildings with more than 50,000 sq ft of leased commercial space are not eligible.

Physically vacant space won't be leased, won't have equipment for customer/business needs, and the lighting and mechanical systems may be shut down. On the other hand, a tenant change in operations can mean reduced hours, reduced staff, reduced business needs, etc., but the space is still leased, usually equipped with desks or goods being sold, and is typically conditioned. Additionally, leased spaces with a tenant change in operations often still have other power loads such as data centers and servers for remote workers and business needs. In short, the space is still being "used" for a business purpose.

A building’s energy use dropped due to COVID-19 impacts. Is it eligible for the 15% EUI reduction Tune-Up waiver?
The 15% EUI reduction waiver exists to provide an alternative compliance pathway for building owners who go above and beyond the Tune-Up requirement. This requires significant energy efficiency operations and maintenance (O&M) and/or capital improvements. During the COVID-19 pandemic, many buildings experienced significant reductions in energy consumption, however, these buildings are not eligible for the 15% EUI reduction Tune-Up waiver unless they can prove the drop was the result of energy savings measures and not related to changes to building operations. When applying for the 15% EUI reduction waiver, the building owner must provide a detailed explanation and documentation of work completed to achieve the EUI reduction. They also must self-certify that the change in energy consumption is not due to changes in tenants, occupancy, or operating hours.

Tune-Up Specialist

What do Tune-Up Specialists do?
A Tune-Up Specialist is a person qualified to conduct a tune-up assessment, identify required Corrective Actions, verify that actions were completed, and in some cases, perform tune-up actions. It is the responsibility of the building owner to verify the qualifications of your Tune-Up Specialist. A building owner will be considered non-compliant if somebody who is NOT qualified conducts your tune-up. See How to Comply for details on required Tune-Up Specialist qualifications.  

Does one Tune-Up Specialist certification carry more weight than another?
No - all certifications are equal under the mandate. However, you may want to request references to learn how your Tune-Up Specialist has performed for other clients.  

How do I find a Tune-Up Specialist?

  • Does your building have a regular maintenance contract? Check with them, they might be qualified to conduct a tune-up.
  • Building Potential, formerly the Northwest Energy Efficiency Council (NEEC), maintains a list of firms with staff that meet the requirements of a Tune-Up Specialist. Inclusion on the list is voluntary and does not represent an endorsement by the City of Seattle.
  • Do your on-site staff meet the qualifications?  If so, they are eligible to serve as a Tune-Up Specialist.
  • Try searching for "MEP" - mechanical, electrical, plumbing - engineers.  

Can my own staff conduct a Tune-Up?
Yes, but only if they meet the Tune-Up Specialist qualifications. Tune-Up Specialists will need to provide evidence of their credentials via the Seattle Services Portal and be approved prior to claiming a building and submitting the Tune-Up Summary Report to the City of Seattle.  

Are Tune-Up Specialists who do the walk through the same people who implement the Corrective Actions?
Maybe, but not necessarily - it depends on the work that needs to be done. Once the Tune-Up Specialist completes the building assessment, they will present their findings to you, and will note the Corrective Actions. Your building may need operational fixes, or you may need to go to vendor-specific experts (like HVAC) for assistance. Although you may use other staff or vendors to implement, the Tune-Up Specialist is required to verify the Corrective Actions and sign off on the Tune-Up report.

Do I have to report everything my Tune-Up Specialist finds to the City?
The findings for each Tune-Up assessment element (including both Required and Voluntary Corrective Actions) must be reported by the Tune-Up Specialist in the Tune-Up report they submit to the City via the Seattle Services Portal. If there are additional findings outside of the scope of the Tune-Up, these items do not necessarily need to be reported.

Can a qualified Tune-Up Specialist also provide me with my ENERGY STAR score?
Potentially, yes. Your Tune-Up Specialist could have the qualifications to provide you with an ENERGY STAR score. As part of the ENERGY STAR certification process, a building owner or manager is required to have a licensed professional verify that the information in their application is accurate and complete before it's submitted to the U.S. EPA. For more visit the EPA's website.  

Why Does Seattle require completion and 80% passage of the City's Building Tune-Up Specialist training?

Required training was a program recommendation and embraced during Tune-Up Specialist feedback sessions following the completion of the first cycle of required tune-ups as a method to improve outcomes and clarify expectations. If you are an experienced Tune-Up Specialist, the information will be a great refresher. Units include resources and tips to assist seasoned professionals alike. The training also highlights ways the Seattle Building Tune-Up aligns with the State’s upcoming Clean Building Performance Standard requirement.

How do I get my approved Tune-Up Specialist status back so I can submit Tune-Up reports?

You can reinstate your Tune-Up Specialist status if you complete the training, which will remain available online throughout the second cycle of required tune-ups (use coupon code “btust200” to reduce the cost to $0). Once you finish the training, if you were previously an approved Tune-Up Specialist in the Seattle Services Portal, you will need to submit a Building Tune-Up Specialist Registration Amendment. Please follow these steps to amend your existing Tune-Up Specialist registration. If you have yet to register in the Seattle Services Portal, you will simply begin a Tune-Up Specialist Registration and provide the date you successfully completed the training. Staff will review your amendment or registration request. After verifying you have successfully completed the required training and have a current certification, we will approve the request and you will be able to submit Tune-Up Summary Reports.

Tune-Up Requirements and the Washington State Clean Buildings Performance Standard (CBPS)

Do I still have to do a Tune-Up now that the Washington State Clean Buildings Performance Standard (CBPS) (HB 1257, 2019) requires an energy management plan and an operations and maintenance program?
Yes. Buildings in Seattle will need to comply with the Tune-Up requirement for the second "round" on the current timelines:

  • October 1, 2023 for buildings 200,000+ SF
  • October 1, 2024 for buildings 100,000 - 199,999 SF
  • October 1, 2025 for buildings 70,000 - 99,999 SF
  • October 1, 2026 for buildings 50,000 - 69,999 SF  

These tune-up deadlines are about 2-3 years ahead of the state CBPS deadlines depending on the building size.  Compliance with the second cycle (2023-2026) of tune-ups will help building owners prepare for Seattle’s newly adopted Building Emissions Performance Standard (BEPS), as well as the new Washington State Clean Building Performance Standard (CBPS).  After the second cycle is completed, the Building Tune-Ups program will sunset to reduce overlap with the CBPS regulation’s first cycle of deadlines starting in 2026 for buildings 220,000 SF and larger.

If I comply with the Tune-Up policy, can I get out of the Clean Building Performance Standard requirements?
No, the state is not currently accepting the tune-up as compliance with the O+M requirements (see Section 6 of ASHRAE Standard 100-2018 and WAC 194-50-060 for the CBPS requirements). The CBPS O+M requirements, in some cases, are more extensive than a tune-up and require more frequent action.

Building owners who achieve compliance with CBPS by their tune-up deadline are eligible to apply for tune-up alternative compliance.

How does the O+M component of the State of Washington's Clean Building Performance Standard differ from Seattle's Tune-Up requirements?
Both policies require in depth actions to maintain building systems to save energy. Some important differences to keep in mind as you are complying include:

  • Different deadlines and cohorts - the CBPS's first deadline is not until 2026-2028 depending on building size and compliance cohorts are slightly different:
    • June 1, 2026 - over 220,000 sf
    • June 1, 2027 - 90,001- 220,000 sf
    • June 1, 2028 - 50,000- 90,000 sf
  • Additional systems - the CBPS requires regular maintenance of two additional systems that the tune-up does not: refrigeration and electric power distribution and on-site power generation.
  • Different frequency of required action - the CBPS requires the development of a formal operations and maintenance (O&M) program but does not specify a specific frequency of maintenance actions. See Annex L of ANSI/ASHRAE/ACCA Standard 100 and WAC 194-50-130 for detailed requirements. The City of Seattle tune-ups policy requires a tune-up every five years.
  • Different specificity of required action - the CBPS requires the development of a maintenance plan covering all systems, setting of performance objectives, and condition indicators - but leaves the specific actions up to the building owner to determine. The City of Seattle tune-up policy requires all buildings to assess, fix, and verify specific actions when a deficiency is found.

For details on the Clean Building O+M requirements see Section 6 and Annex L of ANSI/ASHRAE/ACCA Standard 100 and WAC 194-50.

Where can I learn more about what the Clean Buildings Performance Standard requirement?
The Department of Commerce has a website with a summary of the law, information on how to comply, how to get help, and how to apply for an Early Adopters Incentive if your building's EUI is 15 points above your target EUI. 

Sustainability and Environment

Jessyn Farrell, Director
Address: 700 5th Avenue, #1868, Seattle, WA, 98104
Mailing Address: PO Box 94729, Seattle, WA, 98124-4729
Phone: (206) 256-5158

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