INTRODUCTION

The power supply is a critical component for growth in every nation. While many developed and developing countries have successfully implemented various electricity sector reforms to grow their economies; Nigeria, thirteen decades after it commenced electricity generation and supply1, still struggles to provide a reliable power supply. The state of Nigeria's electricity supply has stifled transformational economic growth in the country.2

The sector is bedeviled with many challenges, from lack of sufficient electricity generation to infrastructural deficiency, technical, commercial, and collection losses (ATC & C loss), and lack of funding for electricity projects.

Over time, successive Nigerian governments have deployed several strategies and intervention programs to liberate the NESI. However, the numerous intervention programs have proven to be largely ineffective and, in some cases, a waste of precious state resources on unprofitable ventures in the NESI. These challenges persist despite the concerted efforts of the government and the private sector.

Continuing the efforts of liberating the NESI, the recently sworn-in President of the Federal Republic of Nigeria, His Excellency, President Bola Ahmed Tinubu, fondly referred to as ''Jagaban'', during the presidential elections campaign, outlined his plans for the liberation of the power sector in his manifesto document titled ''Renewed Hope 2023''. Jagaban's plans for Nigeria's power sector include:

  • Eliminate estimated billing in Nigeria
  • Promote domestic manufacturing of prepaid meters
  • A renewable energy plan with primary focus on solar energy
  • Increased rural electrification
  • Promote gas to power projects
  • Revamp/Update the power sector governance reform

Whilst congratulating Jagaban for his emergence as Nigeria's President, this article reviews the state of affairs in the NESI. It projects the sector's future based on Jagaban's plans.

CURRENT STATE OF THE NESI

Before 2005, the NESI operated as a vertical electricity market with one entity operating the entire sector value chain. Today, the NESI operates as one of the vertically unbundled electricity markets in the world, with private participation in the generation and distribution sub-sectors. At the same time, the transmission network is solely owned and operated by the Nigerian government.

In spite of the unbundling and privatization of the NESI, the sector is yet to realize the benefits that necessitate the denationalization and unbundling of the sector. The sector is primarily embattled with the same challenges it faced since its inception in 1896. At present, the NESI has Twenty-Six (26) grid-connected generating plants with a combined installed generation capacity of about 12,522MW excluding off-grid generation. However, the available average generation capacity is approximately about 4,508.38MW.3

Nigeria's transmission network consists of high-voltage substations with a total (theoretical) wheeling capacity of 7,500MW and over 20,000km of transmission lines. The transmission wheeling capacity (5,300MW) is higher than average operational generation capacity of 3,879MW, but it is far below the total installed generation capacity of 12,522MW.4 These statistics vividly demonstrate the worrisome state of infrastructural deficiency of the transmission network. Aside from the transmission losses on the transmission network, the network suffers incessant system collapse.

The transmission network has suffered several system failures/collapses without reaching its total installed generation capacity. In 2018, the grid collapsed thirteen (13) times, eleven (11) times in 2019, four (4) times in 2020 and 2021; and eight (8) times in 2022. Imagine a situation where the NESI reaches its full installed capacity, and the same is to be dispatched through the transmission network; the entire transmission network is likely to collapse as currently constituted.

The transmission network, as presently constituted, is radial and grossly under-maintained. With an urgent upgrade or revamp of the network, the network will be free from constant system disruptions and may eventually grind to a halt.

Another significant challenge in the NESI is the issue of ATC & C losses, electricity theft, shortfalls on remittance obligations, metering issues, amongst others.

Refrain from dismissing some of the positive feats achieved in the NESI, the above-summarized challenges ought to have been depleted to the barest minimum, if not totally eradicated, by now.

Nigeria is one of the most underpowered countries in the world, with grid-powered electricity consumption significantly below the population and income levels of the citizenry despite the vast natural resources at her disposal, which can generate sufficient power for the entire country. Nigeria's consistent inability to deliver beyond 33% of its total installed generation capacity is a function of the long-standing market, infrastructural and regulatory challenges which has prompted mass self-electrification amongst the citizenry, as nearly half of the electricity consumed is self-generated by Nigerians through diesel- or petrol-powered generators and solar power.

In solving Nigeria's energy crisis, Jagaban intends to consolidate on past governmental efforts based on the plans outlined in his Renewed Hope action plan. The plans are examined below.

JAGABAN'S PLANS

Plan One – Eliminate Estimated Billing

The focus of this plan is to ensure all homes and businesses connected to the grid are metered by building on the past administration's metering policies,5 mandate DISCOs to ensure new connections are metered during the construction phase, and that DISCOs charge cost-reflective tariff for electricity supply.

Estimated billing refers to a system of charging unmetered electricity consumers for energy consumption based on previous usage pattens without considering the actual quantity consumed. The danger here is that estimated billing exposes consumers to overbilling, while metered billing promotes transparency and accountability in the sector. NERC's 2022/Q2 report reveals that estimated billing accounts for 47.76% of consumer complaints received by DISCOs.

To eradicate the bane of estimated billing, the federal government rolled out several significant initiatives; the CAPMI initiative, MAP and NMMP schemes. Under the CAPMI scheme, willing customers can pay the cost of the meter into a dedicated account jointly managed by the DISCO and meter vendor/installer, and the meter can be installed within 45 days of receipt of payment. Under the NMMP scheme, the government works with local manufacturers to provide free smart prepaid meters to unmetered consumers. Here, the government partners with the CBN, World Bank and other relevant stakeholders to provide the necessary financial support to the local manufacturers to supply free meters to end-user customers. Under the MAP scheme, metering is facilitated through third party companies, and customers have the option of purchasing meters. At the same time, the acquisition cost is refunded in form of energy credit issuance over 36 months.

The government recorded some laudable feats in bridging the meter gap under the two schemes. NERC 2022/Q2 report records that as of 30th June, 2022, registered customers totalled 12,643,630, out of which 4,898,721 have been metered representing 38.74% metering rate, which leaves an unmetered population of about 7.78 million customers and a metering gap of 62.3%.

While these metering programs have enjoyed some success, they have barely scratched the surface of the metering gap conundrum, as the expected results in closing the metering gap are yet to be delivered. The significant challenge for closing the metering gap remains the problem of illiquidity and the need for customer awareness and participation. For instance, the suspension of the NMMP scheme caused a liquidity crunch as MAPs and DISCOs could not access funding to meet their metering obligations.

The metering gap is not being depleted, and the power sector has been cash constrained as DISCOs cannot satisfy their remittance obligations to the GENCOs, which has resulted in stunted development of crucial infrastructure that will improve operational efficiency, deliver value and drive down ATC&C losses.

However, Jagaban's administration promises to consolidate past efforts to eradicate estimated billing in the NESI. The new administration is expected to streamline and speed up the current national metering projects and introduce new initiatives, if necessary, to meet the metering goal in the quickest possible period.

Plan Two – Domestic Manufacturing Of Prepaid Meters

In furtherance of the plan to close the metering gap, Jagaban's administration intends to promote domestic manufacturing of prepaid meters. Prior to January 2023, there were only five (5) companies licensed in 2014 to manufacture prepaid meters in Nigeria. Today, twenty-five (25) companies are licensed to manufacture prepaid meters in Nigeria with a combined capacity to produce over six (6) million units of meters. However, these companies are confronted with significant financial, fiscal, and technical expertise challenges that makes it arduous to meet their manufacturing mandate.

Local manufacturing companies do not have access to funding to meet the metering gap goal. In tackling the funding problem for local meter manufacturing, the National Mass Metering Regulation and NERC's MAP Regulation 2021 provide financial contributions in the form of working capital to assist the local manufacturers in meeting their metering mandate.

Similarly, the local manufacturers deal with fiscal challenges, especially when importing raw materials that are unavailable in Nigeria. The tax rate is usually around 5% to 40%, plus additional port fees when importing certain raw materials. There is also a one-off tax payment of 10% on finished meters.

On the technical aspect, there needs to be more technical expertise in meter manufacturing, energy meter installations, and electrical building installations in Nigeria, which leaves the government with no choice than to rely on foreign technical skills to meet the country's metering needs.

In response to the vacuum of technical expertise in meter manufacturing, installation and related matters, the North East Development Commission, in partnership with MOMAS Group, empowered about 150 Nigerian youths in the North East with core metering training to produce certified installers and technicians for meter installations to meet the demand of MAPs within the NMMP initiative, before the suspension of the NMMP.6

The country's local meter manufacturing is slow-paced due to the above-highlighted challenges. The situation will only change if the above-highlighted challenges remain, and the government needs to provide necessary support mechanism.

Using the statistics of twenty-five (25) local manufacturers having the capacity to produce six (6) million units of meters and the government's target to close the metering gap in eighteen (18) months, if these 25 manufacturers are equipped with the necessary financial assistance, tax waivers/incentives, sufficient technical expertise, and an increase of locally manufactured meters from the extant 30% to about 50%, the government's objective of closing the metering gap will be realized in quick time.

Plan Three – Focus On Solar Power

Jagaban's administration intends to multiply Nigeria's solar energy capacity by working with stakeholders to increase the solar energy capacity and create opportunities for solar energy policy development and increase investment in solar projects.

Nigeria's electricity generation mix is a combination of renewable,7 and non-renewable energy8 resources. The challenges of insufficient gas, poor grid infrastructure and carbon emissions associated with non-renewable energy resources in power generation have necessitated the resort to renewable energy in Nigeria. Solar energy has gained impressive traction in Nigeria as a primary renewable energy resource. Nigeria receives about 4.851 * 1012kWh of solar energy daily, which amounts to an average of 6 hours of sunlight daily. Nigeria's solar deployment creates limitless opportunities from its solar energy capacity, which can help it actualize its sustainable clean energy objective.

Several countries have since exploited renewable energy resources for power supply in their countries. For instance, while Nigeria is seriously lagging in its renewable energy resources, South Africa recently connected an 86MW solar PV plant to its Northern Cape Grid.9

Nigeria has a number of policies in realization of its renewable energy goals. There is the Renewable Energy Master Plan 2005, Renewable Energy Policy Guidelines 2006, National Renewable Energy Efficiency Policy 2013, National Renewable Energy and Energy Efficiency Policy 2015, NERC's Mini-Grid Regulation 2018 that set up a CBN solar intervention fund, National Energy Efficiency Action Plans 2015 – 2030. These governmental policies create opportunities for developing Nigeria's renewable energy resource, offers tax incentives, and emphasize adequate energy, and emissions reduction, amongst others, towards the realizing Nigeria's renewable energy goals.

Commendably, the outgoing administration embarked on some laudable projects to further Nigeria's renewable energy goals. First, in July 2022, the federal government of Nigeria, announced that it had commenced the decentralization of the national grid by using renewable energy-driven mini-grids to meet the country's power needs. On the back of this decentralization plan, former President Muhammadu Buhari, on 30th January, 2023 commissioned the 10MW Kumbotso solar PV project funded by the Nigeria Sovereign Investment Authority in Kano State. The Kumbotso solar project is Nigeria's most prominent and first national-grid connected solar power plant. There is also the NASENI solar cell production plant in Nasarawa State, commissioned on 24th March 2023 by the former Vice-President, Prof. Yemi Osinbajo, SAN.

Nigeria currently has an installed renewable energy capacity of about 2,000MW, operated mainly as mini-grids and targeted towards providing power supply to rural communities.

By Nigeria's Sustainable Energy 4 All Agenda 2016, the country intends to generate 30GW of electricity by 2030, with renewable energy making up 30% of the proposed energy mix. Solar energy can produce a 30% renewable energy contribution to the proposed 30GW power generation. To meet and surpass this goal, the new administration must create an enabling environment, drive purposive legislation and policies to attract local and foreign investment for renewable energy, particularly solar energy solutions, to the country's generation mix.

Plan Four – Increase Rural Electrification

Rural electrification means the process of electrifying rural and remote areas in Nigeria. The Nigerian Rural Electrification Agency (REA) is responsible for electrifying rural and unserved communities in Nigeria by facilitating affordable power supply for residential, commercial, industrial, and social activities in the rural and remote areas across Nigeria.

REA was set up pursuant to section 88 of the ESPRA 2005, and its management board was inaugurated on 16th March, 2006. Since its creation, REA has been tasked with implementing Nigeria's rural electrification policy as expressed in the National Energy Policy, the ESPRA 2005, and the Rural Electrification Strategy and Implementation Plan. Its core objective is to achieve 60% rural electrification by 2020. As of 2022, Nigeria could only meet 39% of its rural electrification goal instead of the 60% it set to achieve by 2020. Thus, Nigeria is 21% behind its rural electrification goal. To attain its 90% goal by 2030, Nigeria must achieve additional 51% connection rate between now and 2030.

Currently, about 92 million Nigerians need access to grid-powered electricity. A vast proportion of this figure is apportioned to rural communities.10 This is due to the cost of extending the national grid to rural areas, which makes it difficult for the government to undertake grid extension to rural areas to achieve its rural electrification goal. Research conducted in 201511 revealed that rural grid extension in Borno State would cost a whooping US$2.9 billion, while rural grid extension in Edo State would cost US$73 million. Thus, it would take an average of US$1 billion for rural grid extension projects in rural areas per state in Nigeria. The high costs for grid-based rural electrification projects across states are attributable to distance in locations from existing national grid infrastructure and population size, amongst others. In response to this significant challenge, REA opted for a centralized and decentralized approach to meet its rural electrification goal. REA's strategy entails a mix of grid extension program by engaging DISCOs to meet their grid extension obligations, mini-grid solutions; and stand-alone solar home systems. REA's strategy is primarily powered by solar energy resources to achieve its rural electrification goal and support the federal government's climate change obligations under the PARIS Agreement to promote renewable energy and reduce carbon emissions in the country.

In the face of these daunting challenges, the REA still recorded commendable performance. In its 2020 project impact report, REA recorded 99,450 connections impacting 457,470 people.

To achieve Nigeria's rural electrification goal, Jagaban's administration intends to streamline and relax regulations on rural electrification to incentivize the private sector and state actors to participate in the rural electrification program.

Jagaban's administration may consider increasing the mini-grids maximum capacity of 1MW as fixed by the Mini-Grid Regulation 2016 to achieve a relaxed regulatory landscape for the rural electrification goal. The new administration should also create an enabling environment for investment and private participation in driving the rural electrification goals.

Plan Five – Gas To Power

Of the abundant energy resources in Nigeria, natural gas dominates our energy generation mix. As of 2020, electric energy generated from gas-fired plants totaled 76.69%. By 2022/Q2, gas powered generation rose to 81.44%.

Even with the abundance of gas resources in Nigeria, the power sector still needs more gas supply for power generation. This insufficiency in gas supply is attributable to illiquidity and gas flaring issues in the NESI. The sector needs to be more transparent with collection and remittance issues. DISCOs' collection challenge makes it difficult for them to properly account for and offset the total cost of electricity supplied by the GENCOs, which culminates in GENCOs inability to recover the actual cost of power generated and offset bills for gas supply for electricity generation. Consequently, gas suppliers are only willing to sell gas to GENCOs with an assurance/payment guarantee from the GENCOs, resulting in a shortfall of gas supply to gas-fired generating plants.

Notwithstanding the above, Nigeria has about twenty-four (24) gas-fired power plants with a combined installed generating capacity of 12,204MW. Nigeria's gas-generated power capacity was projected in Nigeria's Energy Transition Plan (NETP), published in 2022 by former President Muhammadu Buhari. The transition plan recorded a total natural gas consumption of 2.9tcf in 2019, with 243bcf (8.1%) of the natural gas used for power generation (gas to power). The NETP projects a 25% increase of the 2.9tcf gas consumption recorded in 2019 by 2030. By 2030, a 25% increase of 2.9tcf would have amounted to 3.6tcf natural gas consumption per year. The NETP further records a 504bcf projection for gas to power by 2030, a 14% share of the total projected gas consumption for 2030. This projects a 5.9% increase of gas to power between 2019 and 2030.

Nigeria has some impressive governmental policies that incentivize investment inflow and private sector participation in realizing the lofty gas-to-power plan. Some extant policies include the ten (10) years tax holiday for gas production as guaranteed by the Petroleum Industry Act 2021. Companies involved in domestic midstream petroleum operations, downstream gas operations and large-scale gas utilization are eligible to take advantage of the incentives offered by section 39 of the Companies Income Tax Act 2004. Investors in gas pipelines will be given additional five (5) years of tax-free time after the tax-free period specified in section 39 of the CITA expires. Further, section 5.2.6 of the National Gas Policy 2017, provides for domestic gas supply obligations requiring all gas producers to make gas available for the domestic market. The issuance and renewal of upstream licenses will be subject to strict compliance by the applicant with its domestic gas supply obligations. The policy's imperative is for gas development for priority supply to promote power generation in the country.

Thankfully, the new administration's roadmap for power generation entails policy development to guarantee top priority for gas-to-power generation. However, to fully realize the gas-to-power plans, the new administration will need to develop critical gas infrastructure, such as pipelines for gas transportation to the plants. Increased gas-gathering investment is also crucial in the realization of this objective. The government would also need to create an enabling environment for public-private partnerships, as more than public funds will be insufficient to achieve the lofty gas to power goal.

Plan Six – Revamp/Update The Power Sector Governance Reform

Nigeria's power sector is primarily regulated by the Electric Power Sector Reform Act (EPSRA) 2005. The EPSRA heralded the unbundling and privatization of the sector in response to the numerous issues affecting the power sector. According to the EPSRA, NERC was established as the chief regulator of the sector, the defunct National Electric Power Authority (NEPA) was unbundled into three (3) sub-sectors; to wit, the GENCOs, TCN and the DISCOs. Since 2005 till date, all power sector policies set up by the government and regulations, amongst others, were birthed on the backbone of the EPSRA.

The EPSRA currently regulate activities in the NESI value chain. However, the power sector has since transformed, and the extant policies, as fixated by the EPSRA, need to address the current realities of the sector sufficiently. Against this backdrop, there have been calls from various quarters for the overhaul of the regulatory landscape in the sector. The 9th National Assembly set the motion for the review/repeal of the law in favour of a new Electricity law. The proposed new electricity law is currently on the legislative process before the two components of the National Assembly, and will be passed into law under this new administration.

Jagaban's approach to updating governance reform in the sector is two-pronged. Jagaban intends to revise the current legislative and regulatory landscape of the sector and create policies to expand the country's existing off-grid power solutions and expand the country's power generation mix by exploring clean coal, solar, hydropower, and other sustainable energy technologies for power generation.

OUR THOUGHTS

The Nigerian electricity market is indeed performing beyond its apparent capacity despite the enormous energy resources at its disposal. However, Jagaban's plans for the power sector presents an opportunity to liberate the Nigerian power sector. The problems of the power sector are multifaceted but with the requisite political will by the new administration, the problems are well surmountable.

Some of the critical challenges we believe Jagaban's administration should also address in realizing its plans for the power sector are as follows; Nigeria's generation capacity and transmission network must be addressed. Despite its vast energy resource combination, the sector still needs to meet its power demand for its citizenry.12 The country's present generation capacity is an estimated 12,225MW, with only about 5,000MW dispatchable on the current transmission network. The new administration must devise a strategy whereby the available energy resources can co-exist and be appropriately harnessed to reach Nigeria's projected generation capacity and meet its carbon emission reduction goals. The new administration should increase renewable energy electricity generation in the country. For instance, the new administration can revisit the Siemens deal to increase Nigeria's generation capacity to 25,000MW.

NERC's 2022/Q1 & Q2 reports record that GENCOs generated an average of 7,000MW, but only about 5,000MW was dispatched due to the state of the transmission network. Thus, the transmission network must be rehabilitated. The national grid infrastructure as currently constituted is primarily the same since inception of electricity supply in Nigeria's power sector. Despite the transmission network being exclusively owned and operated by the government, the same government failed to develop the transmission infrastructure over the years, and this accounts for the poor state of the transmission network. Since the days of NEPA till date, the vast transmission network has received little to no infrastructural development. The poor state of the grid network faces further deterioration and imminent risk of total national collapse if the new administration does not immediately address the situation. The grid-distributed power supply is critical to the efficiency of the electricity market. Nigeria's grid network lacks cannot wheel the country's whole and projected increased generation capacity. Hence, the need for rehabilitation of the entire transmission network. It is hoped that the federal government's Presidential Power Initiative will yield positive results for the transmission network.

There have been agitations for the unbundling of the transmission operator – TCN, due to the poor state of the transmission network. TCN currently performs three critical functions in the power sector; transmission service provider, system operator and market operator. Arguments have been made which suggest that the TCN is overwhelmed by these responsibilities and lacks adequate manpower and the requisite technical know-how to carry out its functions effectively. Hence, the call for the unbundling of the TCN. It has been suggested that the TCN retains the transmission service while the system and market operator functions are farmed out to another entity, whether private or government-owned. The new administration therefore needs to resolve this critical issue in the NESI if significant improvement is to be witnessed in our power supply.

The new administration must also assist DISCOs in tackling their ATC & C losses, particularly collection and metering issues. The government should consider continuing the NMMP metering initiative, suspended during the previous administration, accelerating the implementation of all existing metering schemes and introduce new schemes if the current ones prove ineffective.

The legislative and regulatory landscape should be revamped to meet the current realities in the sector. The foundation to achieving this is to immediately complete the legislative process for the new electricity law. Interestingly however, the proposed new law does not embody some vital provisions necessary to deliver the Nigeria power sector of our dreams. For instance, the proposed new law does not contain provisions for estimated billing, smart metering and related issues. The proposed new law does not contain provisions relating to local manufacturing of prepaid meters, tax incentives and capacity building of local content in metering. The proposed new law is silent on natural gas and other petroleum gasses for power generation. The proposed law to properly clarify the scope of powers of the federal government and states because of the recent constitutional amendment permitting states to legislate on generating, transmitting and distributing electricity in all areas within the states. It is crucial that the proposed new law adequately address these items to facilitate the seamless realization of the Nigeria power sector of our dreams.

The country's renewable energy resource should be exploited appropriately, particularly solar energy, with a mindset of having grid-connected solar projects nationwide. Thankfully, the proposed new law embodies some necessary provisions for renewable energy obligations for generating and distributing for GENCOs and DISCOs, respectively.

The new administration must remember to tackle corruption in the NESI. For instance, the NMMP mass metering scheme was suspended because of corruption amongst the MAPs, to whom CBN disbursed monies, but the MAPs allegedly diverted the funds.13

The new administration must engage technocrats to realize its plans for the power sector. Key appointments, such as the office of the Minister of Power, should be occupied by core technocrats with demonstrable industry know-how. Individuals like Sam Amadi, Bart Nnaji or other individuals of equal status, as mentioned earlier, must be appointed to drive the necessary reforms to liberate the power sector.

Finally, while addressing all these challenges, it is hoped that the new administration will learn from past administrations' errors in the NESI to avoid falling into similar pitfalls in the power sector.

Footnotes

1. The history of electric power supply in Nigeria can be traced back to 1886 when two (2) small generating plants were installed to serve the then Colony of Lagos - See Sambo, Abubakar & Garba, Babayo & Zarma, Ismaila & Gaji, Muhammed. (2010). Electricity Generation and the Present Challenges in the Nigerian Power Sector. J Energy Power Eng. 6. However, public electricity power generation started in 1896 – see Okoro, O.I. & Govender, Poobalan & Chikuni, Edward. (2007). Power sector reforms in Nigeria: Opportunities and challenges. Journal of Energy in Southern Africa. 18. 10.17159/2413-3051/2007/v18i3a3386.

2. World Bank's Press Release No. 2020/151/AFR accessible at https://www.worldbank.org/en/news/press-release/2020/06/23/nigeria-to-keep-the-lights-on-and-power-its-economy (last accessed on 29th May, 2023)

3. NERC 2022/Q2 Report

4. https://nerc.gov.ng/index.php/home/nesi/404-transmission accessed 24th May, 2023

5. CAPMI initiative, NMMP and MAP metering schemes.

6. MOMAS, NEDC train 150 youths to tackle metering gap accessible at https://businessday.ng/energy/article/momas-nedc-train-150-youths-to-tackle-metering-gap/

7. Solar, hydro, wind, and biomass are renewable energy resources in Nigeria

8. Coal, oil, natural gas are non-renewable energy resources in Nigeria.

9. Phelan Energy Connects 86MW PV plant to grid in South Africa https://www.pv-magazine.com/2023/05/11/phelan-energy-connects-86-mw-pv-plant-to-grid-in-south-africa/

10. Tracking SDG 7 – Energy Progress Report

11. Ohiare, S. Expanding electricity access to all in Nigeria: a spatial planning and cost analysis. Energ Sustain Soc 5, 8 (2015). https://doi.org/10.1186/s13705-015-0037-9

12. Nigeria requires 30,000MW electricity generation to meet its current demand https://leadership.ng/nigeria-requires-30000mw-electricity-generation-to-meet-current-demand/

13. FG may suspend free four million meters' distribution https://punchng.com/fg-may-suspend-free-four-million-meters-distribution/

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