# Proposal
## Local Foods Through Crisis: Dependency & Disruptions in Hawaii
Hunter Heaivilin
Dissertation Proposal
8/25/2020
### Introduction
For over a century, scaling agricultural production to match food consumption has been a recurrent interest in the Hawaiian islands (Stubbs, 1901; Coulter, 1933; Hitch, 1958; DBEDT-OP, 2012). Despite the durability of this desire, once self-sufficient islands now import nearly 90% of their food (Loke & Leung, 2013). Recent goal setting to double local production (Blair, 2014; Ige, 2016) and increase local consumption (Blair, 2014) emphasize supply and demand within the islands as key levers of change but offer little to address structural changes to the food system that have produced the current situation. The shortcomings of this strategy are evident in the novel and recurrent food crises since the early 20th century. Yet, despite the increased role of island food during each crisis, the simple remedy of growing local production and consumption, has been insufficient to reduce vulnerability. A spate of recent large capital investments by external firms are focused on the production of food for local sale, but the potential consolidating effects of these operations may render Hawaii’s food system more delicate than durable. In response to the pandemic, new connections formed both within the agricultural sector, and between the sector and consumers across the economic spectrum. While an immediate boon to local supply and demand, the longevity of these bonds remains to be seen. By exploring a long century of food system change, this research aims to articulate the challenges and opportunities for increasing the resilience of Hawaii’s food system to disruptions.
Global food regimes offer a means to understand the tidal shift from self-reliance to import dependence, but fall short of articulating how those changes have played out in the plains and on the plate. Contrastingly, analysis of food crises in the islands have assessed the details of disruptions but not placed them in the context of broader food system restructuring. Conceptually, resilience is well suited to understand the interactions between periods of gradual (i.e., regimes) and rapid (i.e., crisis) change. Finally, if the myriad economic, social, and ecological goals of food system localization are ever to be achieved they need to understand the barriers to and opportunities for increasing food system resilience. Towards those ends this research will assess a) how global food regimes restructure Hawaii's food system, b) how Hawaii’s food system is reshaped by food crises, and c) the barriers and opportunities for increasing the resilience of Hawaii’s food system.
### Research Outline
My overarching research question is: _How can local food systems become more resilient in the context of food crises and global food regimes_?
I will answer this question by examining the restructuring and reshaping of Hawaii’s agrofood system from the beginning of the 20th century. The working questions, operational questions and prospective data sources I will utilize are articulated below.
<table>
<tr>
<td><strong>Working Questions</strong>
</td>
<td><strong>Operational Questions</strong>
</td>
<td><strong>Data Sources</strong>
</td>
</tr>
<tr>
<td>How have global food regimes restructured Hawaii's food system?
</td>
<td>- What influence have global food regimes had on Hawaii’s food system?
<p>
- How have local food regimes changed in Hawaii over time?
<p>
- How has Hawaii's agricultural landscape changed over time?
<p>
- What are the key asset changes in Hawaii food systems over time?
<p>
- Do changes in Hawaii align with the timelines of global food regimes theorizing?
<p>
- What portion of Hawaii’s food consumption has been locally produced over time?
</td>
<td>
<ul>
<li>Legislative and policy documents
<li>Planning and research documents
<li>Census data
<li>Extension publications
<li>Recent agricultural investments and development projects
</li>
</ul>
</td>
</tr>
<tr>
<td>How have food crises reshaped Hawaii’s food system?
</td>
<td>- What food crisis occurred in Hawaii over the 20th century?
<p>
- What were the immediate impacts?
<p>
- How/did economic foci shift as a result of food crises?
<p>
- What, if any, durable reshaping of food systems occurred?
<p>
- How has the governance of food crises changed over time?
<p>
- How have entitlement bundles and institution response roles shifted over time?
<p>
- What innovations in local food crisis response have emerged?
<p>
- What critical transitions occur in the return to imports as a crisis recedes?
</td>
<td>
<ul>
<li>Government records
<li>Popular press articles
<li>Extension publications
<li>Recent local food sales data
<li>Interviews with food aggregators
</li>
</ul>
</td>
</tr>
<tr>
<td>What are the barriers and opportunities for increasing food system resilience?
</td>
<td>- What mechanisms have been employed to address COVID-19 related food disruptions?
<p>
- Has consideration of food system resilience changed as a result of the pandemic?
<p>
- What are the needs of producers across the state?
<p>
- Do producers’ needs align with state and private interventions?
<p>
- What are the key factors of resilience in Hawaii’s food system?
<p>
- What foresight systems can be established for future disruptions?
</td>
<td>
<ul>
<li>Participatory action research
<li>Farmer needs assessments
<li>Recovery plans
<li>Key informants
<ul>
<li>Emergency Managers
<li>Food access coordinators
<li>Food aggregators
</li>
</ul>
</li>
</ul>
</td>
</tr>
</table>
### Research Methodology
To answer the question of _how global food regimes restructured Hawaii's food system_ I will primarily undertake document analysis and data collection to construct a historical arc of changes in Hawaii’s food system. Earlier periods will receive shorter treatment, with progressive detail offered through time and culminating with an examination of current agrocapital investment and food planning. Particular interest will be paid to the spatial (i.e., distribution of agricultural parcels), demographic (i.e., production characteristics), and economic (i.e., import and local production volumes) composition of food and agricultural systems to assess the extent to which the case of food in Hawaii aligns with successive global relations in food regimes theory.
To address _how food crises have reshaped Hawaii’s food system_ I will compile a timeline of disruptions since the 19th century, and undertake comparative historical analysis to ascertain relationships to broader shifts in Hawaii’s food system. Explicit interest will be paid to response approaches and their influence on durable impacts, if any, to Hawaii foodways. Over the past year I have compiled data on food crises in the islands, with notable collections on World War I and II, and maritime strikes in 1936-37 and 1949.
To assess the _barriers and opportunities for increasing food system resilience_ I will employ a fault tree analysis to construct a model of vulnerabilities that will be expanded upon with interviews with key actors and stakeholders in Hawaii’s food system. Chodur et al.’s (2018) fault tree model will be used to assess the current food system and its failures during COVID-19 pandemic. Additionally, my work as a food system planner as part of the pandemic food response frameworks will provide access and insights into the approaches and interventions employed. In May 2020, I began a position as the food resilience coordinator at the Hawaii Public Health Institute. Among my other responsibilities, in this role I compile data on food crisis responses at community, county, and statewide scales through participation in various networks including, _inter alia_, Oahu’s (and Maui’s fledgling) Kupuna Food Security Coalition, the Hawaii Hunger Action Network, Obesity Prevention Task Force, Agriculture Response & Recovery Working Group, and Hawaii Emergency Management Agency’s Emergency Support Function 6 on Mass Care. This position has afforded opportunity to support the food access coordinators within each county as well as outline collection and analysis systems for community feeding program data.
#### Importance & Research Audience
Failure to consider how global food regimes produce and shape food crises in Hawaii limits the ability of food crisis managers and local food movements to address the current food crisis and rise of globally financed “local” agriculture. Early evidence from recovery planning efforts shows the return of a focus on value added and export focused agriculture as a crisis driven approach to economic diversification by the State requires historical analysis of the viability of such programs to deliver on their intended goals. Analysis of the confluence of global food systems, local agricultural development, crisis response, and economic planning will provide a novel understanding of the means by which food system change is pursued and constrained.
This research will contribute to scholarship on food system resilience through consideration of key facets of resilience in food systems, to agrarian change through a case study of the dynamics of restructuring between scales, to crisis production and management through comparative analysis of disruptions, to agrofood system localization through assessing crisis intervention longevity, and to sustainability transitions through analysis of policy and practice in food system change.
Civil society groups and government bodies focused on facilitating the development of robust local agrofood systems will also find value in the analyses of producer needs and mechanisms of material reproduction of agriculture for local consumption.
### Literature Review
#### Resilience & Food Systems
The concept of resilience emerged from ecological models that emphasized stable equilibriums to consider the facets of systems not near, or moving between, equilibrium states (Holling, 1973). Over time the approach expanded to social-ecological systems (Gunderson & Holling, 2002), with growing interest (Folke 2006) that has spilled out from academia into popular thinking (Walker & Salt, 2006; Boin, Comfort, & Demchak, 2010; Matthews, 2020). Resilience considers “how periods of gradual change interplay with periods of rapid change” thereby offering a valuable lens for the assessment of food systems (Folke, 2006, p. 1).
Resilience analyses in food systems are often rooted in the ecological systems that underpin agricultural productivity. Biodiversity underlies all ecosystem services that are critical to the function of agroecosystems (Altieri, 199). The relative presence of biodiversity impacts both regulating services like nutrient storage and cyclicing to supporting services like crop pollination (Bommarco et al., 2013). Diversified farming systems that incorporate functional biodiversity require less external inputs to maintain productivity and can provide comparative advantages ecologically, socially, and economically (Kremen & Miles, 2012; Reganold et al., 2016). Despite these advantages federal funding in the United States to support diversified farming research and implementation has been slim (Delonge et al, 2016), and nearly nonexistent when compared to private and public funds spent globally to enable conventional production. Additionally, US policies enable the food system status quo and perpetuation of externalization of many ecological, social, and economic costs of conventional agricultural production (Shannon et al., 2015). Some of those externalities exacerbate the risk to agrofood systems from climate change (Myers et al., 2017), so too does the need to define and develop more resilient production systems (Tendall et al., 2016). Biologically diversified farming systems are the foundation of sustainable and resilient food systems. Reintegrating biological diversity into farming systems, from the genetic, to field, to landscape scales, is a key mechanism to reduce climate change vulnerability (Altieri et al, 2015). Resilience assessments of food systems also scale beyond the farm landscape into broader social-ecological factors.
Rotz and Fraser (2015) define food system resilience as a “system’s ability to absorb external shocks while maintaining core functions, such as food production and distribution”. Their analysis considers the vulnerabilities created by industrialization of the food system, not just through the loss of diversity (i.e., biological simplification), but increasing connectivity of system elements (e.g., crop similar at landscape scale or firm consolidation). Similarly, but at the global scale, Hendrickson (2015) finds risk in consolidation and concentration in that have reduced key aspects of diversity in food systems through standardization and specialization. These various simplifications have led to a global food system that while arguably unresilient to myriad disruptions, has proven somewhat resilient to change. Oliver et al. (2015) term and attribute this undesirable resilience to ‘lock-in’ induced by various biophysical, knowledge, sociocultural, and economic and regulatory constraints.
Others have sought to define critical factors to the production of resilient food systems. Tendall et al. (2015) find robustness, redundancy, flexibility and resourcefulness as key elements in their multi-level model of resilience in food systems. Seekell et al. (2017) compare national systems through the dimensions of socio-economic access limitations and the biophysical capacity and production diversity of agricultures. Schipanski et al. (2016), instead pursue the definition of strategies to produce food resilience from ecological processes to policy, through equity efforts and food system regionalization. Worstell and Green (2017) also find regionalization, framed as local self-organization, as an important factor on their index of resilient food systems qualities.
Often in response to global food system vulnerabilities regional analyses are common in food system resilience assessments. Blay-Palmer, Landman, Knezevic, and Hayhurst (2013) define and find the networks of food hubs as an important intervention in the production of resilient regional food systems. Kondoh (2014) situates similar alternative food movement approaches, this time in Japan not Canada, both historically and within the context of crisis (the Fukushima Daiichi nuclear disaster) and also finds social networking a critical aspect of resilience. At a more macro scale, Fraser’s (2007) review of historical famines in different countries determined three key mechanisms to be addressed in food system resilience building: limited livelihood diversity, agricultural specialization, and institutional social safety nets. These recommendations reasonably align with Pingali, Alinovi, and Sutton’s (2005) finding, in the pursuit of managing food crises to build resilience, that crisis response policies should connect relief activities with longer term food system development. Doing so however requires an awareness of not just crisis dynamics but those of broader food system change.
#### Food Regimes
Food regime analysis is ideal for articulating connections between state and global governance and identifying trajectories of accumulation in agrofood sectors (Marsden, Munton, Ward, and Whatmore, 1996). Each food regime is a post hoc bounding of moments to aid in “the understanding of agriculture and food’s role in capital accumulation across time and space” (McMichael, 2009a).
In the first global food regime, dominated by British colonialism from 1870-1930s, foreign capital reconfigured agriculture across Pacific Islands to produce bulk commodities for export to colonial centers (Plahe, Hawkes, & Ponnamperuma, 2013). In the second food regime roughly from the 1950s through the 1970s, United States ascension and global north productivity drove exports to postcolonial states, shifting the net flow of goods and creating food import dependence across much of the pacific (Plahe et. al, 2013). The third global food regime from the 1980s to today, framed by the politics of neoliberalism and evidenced in the “corporatization of agriculture and agro-exports” (McMichael, 2005), has shifted the “locus of control for food security away from the nation-state to the world market” (Plahe et. al, 2013).
McMichael posits that “the food regime is not a political–economic order, as such, rather it is a vehicle of a contradictory conjuncture, governed by the ‘double movement’ of accumulation/legitimation” (2005). And indeed, in Hawaii today corporatized agrofood development is used as a means of state legitimation, clearly reflected in a recent newsletter from the Governor’s office stating that “businesses ... have heard about our commitment to doubling local food production and are interested in making significant investments here.” (Office of the Governor, 2019). Accumulation by capital in this regime is accomplished through the “appropriation of agricultural resources for capitalist consumption relations … realized through an expanding foundation of human impoverishment and displacement, and the marginalization of agrarian/food cultures” (McMichael, 2005). The recent spate of land grabs in Hawaii by financial and corporate interests are exemplary of this type of appropriation, while marginalization is evidenced by the lack of material support for existing agricultural producers that was present in previous decades. These factors create vulnerabilities in the food system that contribute to the production of food crises.
#### Food Crises
Legal frameworks for the concept of food security begin with the 1948 Universal Declaration of Human Rights (Ayalew, 1997), but as the concept developed the focus has shifted from the global and national level to the individual household (Loke & Leung, 2013). Scale jumps in the locus of management of food security trends well with the establishment of neoliberal approaches to governance. While the concept of food security has grown to encompass availability, access, utilization, and stability (Loke & Leung, 2013), the party responsible for food security has increasingly become the individual citizen; exemplified in the three-day and fourteen-day supply of food and water recommendations by the US Federal Emergency Management Agency and the Hawaii Emergency Management Agency, respectively. When individual food security is disrupted hunger and undernourishment can result. A food crisis occurs when hunger and undernourishment increase drastically across a population (Timmer, 2010). Hunger when scaled to the point of an absolute lack of food, is experienced by a population, is reclassified as famine (Ayalew, 1997). Food crisis encompasses both hunger and famine. Famine however has driven much of the theorizing around food crises.
#### Famine and Food Crisis
The greatest tectonic shift in understanding food crises of the past decades came with Amartya Sen’s (1981) work on poverty and famine. Sen’s (1981) ‘entitlement approach’ focuses on the ability of people to access food through, _inter alia_, production, trade, and state entitlements. The entitlement approach parses household endowments (e.g. wealth and ownership of productive resources), production possibilities (e.g., land and labor), and exchange conditions (market access). Sen distinguished between increasing supply (e.g. doubling local food production) and ensuring there are efficient distributive mechanisms achieved through a free market system. Currey’s (1984) critique of Sen's entitlement approach however finds that it does little to articulate the causes of famine, in particular the lack of political and environmental factors. Devereaux’s (2001) sweeping review of Sen’s work finds shortcomings in a focus on legal mechanisms over socio-political factors. While famine is not the subject of this research, the embeddedness of famine within the taxonomy of food crisis is of import as the value of geographic inquiry to famine is well documented (Harriss, Currey & Hugo, 1986).
#### Food Regimes, Dependency, and Crisis
Talbot’s (2015) review of development of Jamaica’s food dependency as a byproduct of global food regimes over the latter half of the 20th century demonstrates the importance of local factors in global food system integration. Liu (2008) focuses on shifts in Taiwan’s hog feeding to expound on the global food regime impacts to the island’s food dependency. The islandness of these analyses lend to the view that a theory of geographic proximity in relation to global regimes and offshore dependency may be in order. Only Liu however addresses the critical aspect of crisis production
Reviewing the 2007-2008 food price spike McMichael (2009b) applies the concept of food regimes to trace the global repercussions of shifting approaches of capitalism and agribusiness, and neoliberal restructuring in the production of food crisis. Usefully concluding that the “institutional mechanisms of the corporate food regime are unlikely to provide solutions to its socio-ecological contradictions” (McMichael, 2009b). Xu (2019) vets food regimes theory in a quantitative approach by discerning three period of global ‘food price tranquility’ and thereby defines crisis periods as the price spikes occurring in transitions between them. This approach offers a mechanism to examine the price of effects of a crisis on the strategy of increasing local production and consumption.
#### Food Localization
Food system localization, the kneejerk antipode of globalized food, seeks a “voluntary regional closure that links production and consumption around particular sites” (Allen, FitzSimmons, Goodman and Warner, 2003). Allen et. al’s review of California’s early aughts alternative agrofood initiatives considered whether the programming provided alternatives within global food hegemony or acted directly in opposition to such a regime. In both cases localization narratives were present. Questions of who constructs these narratives and who benefits abound (Guthman on alternative food practice, 2008; Louis on transnational food sovereignty, 2016). Born and Purcell (2006) argue that local food systems are not inherently more sustainable or global ones and that localism for its own sake is a form of nativism that can impede social justice goals. Conscious use of relational scale and development of networks (both horizontal and vertical) are advised as complementary tools to navigate past the“local trap” (Born and Purcell, 2006). While DeLind (2006) agrees that enabling local consumption and production is insufficient to achieve the broad goals of local food, she finds the deficit coming from too great an emphasis on market-based solutions to the detriment of sensual, emotional, and cultural facets that undergird the values of local food movements. Similarly, Morgan (2010) echoes that local food chains are not inherently more ethical than global ones and, more importantly, that ethical consumerism is an insufficient tool to address social justice or environmental sustainability. DeLind (2011) decries the developmental direction of local food movements: the rise of locavorism and its individualistic consumerism, local being increasingly defined by corporate actors pursuing greater market share, and food localization celebrity edicts filling the place of democratic local foodway specificity. Connecting these concerns is a call for the “reintegration of local food into place-based practice”.
#### Hawaii Food
Rice’s (2020) recent work covering the production of famine in early 17th century Hawaii offers an invaluable context for framing understanding of early integrations of the islands and world markets. Other analysis in Hawaii has explored the interplay between “local” as both a place-based identity and a geographic distinction of foodways (Hobart, 2016) and recounted the trials of local food placemaking (Inda, Washburn, Beckham, Talisayan and Hikuroa, 2011). Yet unexamined are who constructs the narratives around local food in Hawaii; the degree to which planning and policy, during crisis or otherwise, are caught in the “local trap”; and how an embrace of “local” as identity in place-making and value-based initiatives aids or inhibits achieving local food movement goals. Kimura and Suryanata (2016) highlight the foibles of Hawaii’s agricultural planning and alternative food movements being caught in similar traps of food self-sufficiency and agricultural diversification. Kent’s (2016) work further outlines the costs of policy emphasizing food self-sufficiency to broader consideration and action on food security. While not a perfect synecdoche of late global changes in agrofood, Hobart’s take that “Hawai‘i’s food system represents the myriad issues that challenge communities in the continental United States and beyond” (2016) clearly has purchase. With the closure of the last sugarcane plantation in late 2016 (HNN Staff, 2016) the future of agriculture in Hawaii remains both uncertain and a broad field of opportunity. Melrose, Perroy, and Cares (2015) agricultural baseline study provides the most thorough snapshot of agricultural land use across the state in decades. Their review found increases in diversified agricultural production (Perroy, Melrose, and Cares, 2016) and potential to capture some of the previously identified considerable economic opportunity of increased local production (Leung and Loke, 2008). Despite uncovering a trend towards smaller diversified operations the baseline study only reviewed parcels three acres or larger, leaving a considerable portion of producers, albeit maybe only marginally productive, out of the analysis. From an economic perspective Arita, Hemanchandra and Leung (2014) pointedly examined if Hawaii farms can survive globalization. While all diversified producers are the subject of their inquiry, the results find that smallholders are likely to be most negatively impacted. Though the globalization they consider focuses on imported goods, the new wave of agribusiness investment, in part focused on production for local consumption, is a new facet of globalization that this study intends to explore.
### Preliminary Results
#### Hawaii Farmer Needs Assessment
The 2018 assessment of farmers' needs (Miles & Heaivilin) found the primary barriers to increasing food production to be Farm Labor, Land and Capital, with 76% of survey respondents one of those factors among their top three barriers. When asked for solutions that would best address each barrier, the most frequently selected responses were, respectively, increased availability of farm labor, access to more land, and low-interest loans or grants for farm improvements or expansion.
#### Background Historical analysis
The pandemic disruption to Hawaii’s food system is significant, but fortunately not as disordering as some previous crises. 18th-century famines in the islands were driven by weather and warfare. Drought and battle decimated local production, yielding starvation. In the early 19th, economic factors shifted labor from agriculture to sandalwood, producing famine as the draw of a global market overwhelmed efforts at local production (Rice, 2018). Over the next century, the global market grip grew tighter as export agriculture and food imports both expanded. By the start of the 20th century, most agricultural parcels, excepting plantation lands, were only five acres in size. In the first half of the 20th century, our food crises were again mostly driven by warfare.
In World War I and World War II the narrowing supply coming into the islands drove food system disruptions. During both wars a local governing body was formed to oversee pricing, allocate imports and bolster local production. The year prior to the start of WWI in April 1917, Hawaii imported $10,000,000 of mostly staple foods (Kuykendall & Gill, 1928). By May 1917, Hawaii’s Legislature created the Territorial Food Commission to govern food production and conservation, and make the islands as “independent as possible of the mainland for subsistence” (Maui News, 1917). This broad ambit made the commission the “most powerful board ever created in the Islands” (Maui News, 1917). The commission addressed increasing the taro supply, included a robust Women’s Committee that performed statewide outreach, and funded county agents to work with small farmers (which became part of UH Extension). Wheat flour shortages led to incorporating local starches into ‘war bread’. The Banana Consuming Propaganda Committee redirected the oversupply of once exported fruit into local bakeries and homes, developing Hawaii’s taste for banana bread that persists today.
By the late 1930s, sixty percent of fresh vegetables were being imported (Magistad & Frazier, 1938). Over the course of WWII, the Hawaii food administration changed hands from the Office of Civilian Defense’s Food Control Board to the army Governor’s Office of Food Control. The Food Control Board developed a plan to bolster rapidly declining taro production exacerbated by labor shortages. The board was chided for not including women, responsible for “90 per cent of the food purchased and prepared”, in efforts to address food conservation and price issues (Honolulu Star-Bulletin, 1942). As the conflict wore on, planning work became dominated by plantation interests that wrongly assumed their industrial agricultures could easily transition to local food production. The grounding of offshore fishing fleets, over fears of naval surveillance, created a protein gap in local diets that SPAM filled. Poke eventually returned, but SPAM musubi also remained. After the war, only five percent of agricultural lands, in small parcels, were producing vegetable and fruit crops (Scheffer, 1948), and by the end of the decade, just over half of Hawaii’s food was being imported. These wartime reflections show the complexity of food crisis management, and how our responses shape ‘local’ food.
Today’s food crisis, spared so far from drought and war, is economic. Supply chains have remained intact, but mass unemployment has drastically diminished purchasing power of most households. Initial pandemic disruptions ofto food purchasing, from restaurants, to hotels, and to farmers markets, carved into the bottom line of farms across the state. Hawaii farms are often motivated by the desire to reduce imports but merely increasing production doesn’t necessarily mean less food insecurity in our communities. New relationships between farms and food banks have become lifelines for farmers and families. New funding mechanisms--, federal, state, county, and philanthropic--, have supported these efforts. Food hubs connecting farms and buyers have seen surges in membership, routing unprecedented amounts of local fare onto family tables. The open questions are about how durable these changes are. Will we, like in past crises, have filled our plate with local produce so much that we no longer dine without it? When funding wanes and we trudge back to work, will our palates have been transformed? More pointedly, how do we ensure that addressing hunger and supporting local agriculture aren’t just crisis responses but new realities? This research aims to uncover some of these answers.
### Work Plan & Timeline
**Spring 2020**
* Defend dissertation research proposal
* Continue historical data collection
* Survive global pandemic
* Revise research proposal
**Summer 2020**
* Continue historical data collection
* Survive global pandemic
* Revise research proposal
* Get hired to work for the agrofood investments you are researching
**Fall 2020**
* Survive global pandemic
* Revise research proposal
* Submit Form II
* Restructure proposal into draft introductory chapter
* Data analysis “completed”
* Draft three papers for publication
**Spring 2021**
* Survive global pandemic?
* Compile into dissertation draft
* Draft conclusion chapter
* Submit draft to committee for review
* Edit, edit, edit.
* Submit draft
* Defend dissertation
* Final draft complete by end of May with committee revisions
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