The World Bank St. Petersburg Economic Development Project (P069063)

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1 Public Disclosure Authorized Public Disclosure Authorized The World Bank RESTRUCTURING PAPER ON A PROPOSED PROJECT RESTRUCTURING OF ST. PETERSBURG ECONOMIC DEVELOPMENT PROJECT APPROVED ON MAY 15, 2003 TO THE RUSSIAN FEDERATION REPORT NO.: RES30347 Public Disclosure Authorized SOCIAL, URBAN, RURAL AND RESILIENCE GLOBAL PRACTICE EUROPE AND CENTRAL ASIA Public Disclosure Authorized Regional Vice President: Country Director: Senior Global Practice Director: Practice Manager/Manager: Task Team Leader: Cyril E Muller Andras Horvai Ede Jorge Ijjasz-Vasquez David N. Sislen Tatyana Shadrunova

2 ABBREVIATIONS AND ACRONYMS CIF EMP FM FISP GDP ICRR ISRs LA MOC MOF M & E PAD PDO PIU POM RF SME SPEDP Cultural Investment Facility Environmental Management Plan Financial Management St. Petersburg Foundation for Investment Projects Gross Domestic Product Implementation Completion and Results Report Implementation Status Reports Loan Agreement Ministry of Culture of the Russian Federation Ministry of Finance of the Russian Federation Monitoring and Evaluation Project Appraisal Document Project Development Objective Project Implementation Unit Project Operational Manual Russian Federation Small and Medium Enterprises St. Petersburg Economic Development Project

3 BASIC DATA Product Information Project ID P Original EA Category Financial Intermediary Assessment (F) Approval Date 15-May-2003 Financing Instrument Investment Project Financing Current EA Category Financial Intermediary Assessment (F) Current Closing Date 31-Dec-2017 Organizations Borrower Ministry of Finance of the Russian Federation Responsible Agency Ministry of Culture of the Russian Federation Project Development Objective (PDO) Original PDO 1) Policy and regulatory environment is conducive to the expansion of private sector enterprises; 2) Larger and more efficient private market for land and real estate; 3) Improved City fiscal management capacity; 4) City to preserve its comparative advantage in culture and the arts. Summary Status of Financing Ln/Cr/Tf Approval Signing Effectiveness Closing Net Commitment Disbursed Undisbursed IBRD May Aug Jan Dec Policy Waiver(s) Does this restructuring trigger the need for any policy waiver(s)? No

4 I. PROJECT STATUS AND RATIONALE FOR RESTRUCTURING 1. St. Petersburg Economic Development Project (SPEDP, US$101.1 million) was approved in May 15, 2003, and became effective in January 24, The Project s PDO is to support the City in its efforts to accelerate the implementation of key elements of the Strategic Plan, which was designed to enhance the city's prospects for sustainable economic growth in the medium- and longer term, and preserve its comparative advantage in culture and the arts. 2. Progress towards the achievement of the Project Development Objectives (PDO) has been satisfactory since Project effectiveness. Disbursements are at 98 percent; the remaining loan amount is US$2.4 million. All activities, envisaged under the SPEDP loan agreement, have been successfully completed with the PDO indicators met, including increase in the number of new Small and Medium Enterprises (SMEs), increase in private transactions for land and real estate, credit rating by international credit rating agency, and increase in the number of city visitors. The Project has supported the Russian Government and St. Petersburg in leveraging the city s cultural heritage to generate investments, job opportunities, and tourism revenues (tourism accounts for 11% of the city s GDP). For example, 130 jobs (120,000 labor days) were created during the restoration works at the St. George Hall of the Russian Museum s Engineering Castle; 140 jobs (145,000 labor days) during the rehabilitation of the Russian Museum s Corp-de-Guards pavilions; and another 1,300 employees (2 million labor days) during the reconstruction and restoration of the State Hermitage East Wing. The buildings and sites benefitting from the SPEDP have become accessible to physically challenged people. 3. The Ministry of Finance (MOF) of the Russian Federation (RF) and the Ministry of Culture (MOC) of the RF have jointly approached the Bank to consider an option of allocating additional Borrower s budget funds of US$ 20.0 million to implement one of the two remaining sub-projects which were appraised and initially planned under the SPEDP namely, rehabilitation of two inner courtyards of the Mikhailovsky Palace of the State Russian Museum. Initially SPEDP was to finance a strategically selected set of eleven iconic cultural heritage assets within the city. Together, these constitute a 'tourism circuit that draws both local and international visitors. 4. Nine of these investments have been completed 1 and following their rehabilitation have transformed the city center, reversing its degradation and decay and providing significant positive spillover effects on tourism- related activities, creative industries, and job creation. The Russian Museum inner courtyards sub-project was originally appraised under the SPEDP but was dropped at the implementation stage and excluded from the list of sites to be financed under the SPEDP loan at the Borrower s request as the benefiting cultural institution was unable to vacate the premises prior to the start of the works. This constraint has been addressed, and the subproject can now be implemented. In 2016, the SPEDP closing date was extended until December 31, 2017 to allow the Borrower to finalize the updated design of the Russian Museum subproject. The updated design is now finalized and approved by all the Russian state expertize bodies. The MOF signed the official request for restructuring on September 29, 2017 and submitted it to the Bank. 5. The State Russian Museum is a long-standing counterpart of the Bank. Three sites of the Russian Museum were included in the original design of the SPEDP project and have been successfully implemented. As a result of implementation of these subprojects, the Russian Museum received square meters of added exhibition space, 1,500 square meters of added lecture facilities, and 1,200 square meters of added training space. More details on completed subprojects and their results are provided in the Table below. 1 East Wing of the former General Staff Building of the State Hermitage, Shostakovich State Academic Philharmonia, Peter and Paul Fortress, Temple of Friendship of Pavlovsk State Museum and Conservation Area, St. George Hall and Corps de Gardes Pavilions of Mikhailovsky Palace of the State Russian Museum, Winter Garden of the Marble Palace of the State Russian Museum, Turkish Bath Pavilion and Hermitage Kitchen and Park of the State Tsarskoe Selo Museum

5 Name of the Russian Museum subproject Rehabilitation of two Corp-de Gardes in the Mikhailovsky Castle Restoration of St. George Hall and entrance (grand stairway, Gallery and Oval room) of the Mikhailovsky Castle Restoration of the Winter Garden in the Marble Palace Condition Prior to Project Corp-de-Gardes pavilions were dilapidated and not used for any activities St. George Hall and its entrance zone were in a poor state, not used for exhibition or public activities Winter Garden was in poor condition and not open to the public Post-Project Condition The West Corp-de-Garde pavilion functions as a museum visitor center (using multimedia) and serves as a subsidiary of the Virtual Russian Museum with weekly videoconferences covering current exhibitions at the Russian Museum which are broadcast to news and learning centers opened by the Russian Museum in the regional art museum in the country. The East Corp-de-Garde pavilion is being used as a Children s educational and art center. It became a home to the Russian Center for Museum Pedagogical Sciences and Children s Crafts, which is an associated member of the Russian Academy of Education and Research and Methodology Center for Russia s Art Museums. Every year the Center arranges training events for some children from St. Petersburg and the Leningrad Oblast, and for nearly 15,000 children from Russian regions. Both pavilions are accessible to visitors with limited mobility. St. George Hall and its entrance zone have been fully restored and are now open to the public. The St. George Hall is on the main visitor s tour. It now serves as a top venue for ceremonials (G8 ministerial meetings, Inter-Parliamentary Assembly, St. Petersburg Economic Forum), national and international cultural and legal forums, and public events, such as poetic and musical soirees, especially during the white nights season, Young Russian Poets contest dedicated to Grand Duke Konstantin Romanov. The Winter Garden of the Marble Palace has been repaired, restored and is now open to the public. Therefore, supporting the restoration of the inner courtyards would be a natural continuation of this collaboration to complete the tourist circuit as originally planned. It will also make use of the already well-functioning mechanisms put in place by the Bank-financed project, as well as the Project Implementation Unit s technical expertise and its strong capacity to effectively supervise the implementation of this subproject. The physical condition of the site has further deteriorated since the original project appraisal, making the restoration increasingly more urgent. 6. Design documentation for the inner courtyards subproject has been revised to reflect its current state and condition, and to comply with recent Russian legislation on safety and fire protection. All the revised design documentation was duly endorsed by the Russian State Expertize bodies. The economic analysis of the inner courtyards sub-project was also conducted in 2014 and is available in the project files. After the restoration and reconstruction works financed by the Project, the Mikhailovsky Palace of the Russian Museum will receive a separate entrance area for unassisted access of disabled visitors with fully adapted and equipped restrooms, a cloakroom and an elevator which will allow them to reach all the floors of the Mikhailovsky Palace. The new lecture room on the first floor of the first inner yard will be used for group classes for children, social rehabilitation groups for the disabled, including disabled children. To this end, the Russian Museum already signed 52 service contracts with Centers for Social Rehabilitation, and it is expected that the museum will admit up 10,000 physically challenged people, including children, annually. 7. The proposed restructuring includes (i) a 3.5-year extension of the Project closing date from the current closing date of December 31, 2017 to June 30, 2021; (ii) an increase of the share of the Borrower s co-financing (the MOF is going to allocate an additional US$20 million); and (iii) a reallocation of funds between the expense categories so as to consolidate all remaining Bank loan funds (US$2.4 million) under the categories which will finance the Russian Museum s subproject and operating costs of the Project Implementation Unit. Furthermore, it is proposed to amend the respective sections of the Loan Agreement to include the rehabilitation of the inner courtyards in the list of

6 cultural assets under Part A of the Project (Rehabilitation of Cultural Assets in St. Petersburg), as well as include services of an engineer-consultant and author s supervision to carry out the works on rehabilitation of inner courtyards under Part D (Project Implementation). Also, it is proposed to use a portion of funds under Part D (Project Implementation) for consultant services to assess the effectiveness of the Project supported activities and their results. 8. The restructuring will not change the PDO and associated outcomes. At the same time, there will be intermediate indicators proposed to track the subproject implementation progress and consolidate the Project results. Composition of the Project s components and the Project institutional arrangements will also remain unchanged. 9. Since the cumulative extension of the Loan Closing Date exceeds two years, it requires the Bank Regional Vice- President decision. 10. There are no outstanding audits under the Project. All audit and financial management reports have been submitted in time and found to be acceptable to the Bank. Both Procurement and Safeguards compliance are satisfactory, and no safeguards related issues have been reported. II. DESCRIPTION OF PROPOSED CHANGES 11. Summary of Proposed Changes. In response to the Borrower s request of September 29, 2017, this restructuring paper seeks (i) a 42 month extension of the SPEDP closing date from December 31, 2017 until June 30, 2021; (ii) an increase of the share of the Borrower s co-financing under newly introduced Category 1 (b) Works and consultants services under Parts A, D2 and D3 of the Project for two inner courtyards of the Mikhailovsky Palace of the State Russian Museum and assessment of the effectiveness of the Project supported activities ; (iii) reallocation of funds from Categories 1, 1(a), 2(b), 3(a), 3(b) to Categories 2(b) and (4); and introduction of new intermediate indicators to the Results Framework to track the inner courtyards subproject implementation progress and consolidate the Project results. 12. The extension of closing date is needed to provide sufficient time for completion of all activities related to the rehabilitation of inner courtyards of the State Russian Museum. The funds to support the implementation of this contract will be provided from the increased share of the Borrower s co-financing (US$ 20 million). The Borrower s rationale for the proposed 42-month extension is driven by the estimated time needed for tendering and completing restoration works. 13. The reallocation of funds between Categories is required to accumulate all remaining undisbursed Bank loan funds (US$2.4 million) under the categories which will finance activities related to the implementation of the Russian Museum subproject, assessing the effectiveness of the Project investments, as well as ensuring adequate operating costs during the extended Project implementation period to secure proper functioning of the Project Implementation Unit (PIU) which is responsible for day-to-day project implementation and monitoring. The proposed reallocation of funds from Categories 1, 1(a), 2(b), 3(a), 3(b) to Category 1(b) Works and consultants services under Parts A, D2 and D3 of the Project for two inner courtyards of the Mikhailovsky Palace of the State Russian Museum and assessment of the effectiveness of the Project supported activities and Category 4 Operating Costs (Part D1 of the Project) is presented below: Additional Allocation per Categories Category Category 1(B) Category 4 1 Works under Part A of the Project except for the State Hermitage Museum and Phase 2 of the Rehabilitation of two Corp-de Gardes in the Mikhailovsky Palace of the State Russian Museum US$ (A) Works under Part A of the Project for the State Hermitage Museum and for Phase 2 of Rehabilitation of two Corp-de Gardes in the Mikhailovsky Palace of the State Russian Museum US$ 1,887,500.00

7 2(B) Consultants services under Part D2 of the Project US$ 384, US$86, (A) Goods and works financed under CIF Sub-projects US$ 70, (B) Consultants services financed under CIF Sub-projects US$ 3, Total amount re-allocated US$ 2,271, US$ 161, Change in Components and Cost. There is no change in the structure of the Project components and their names. The costs allocated for each of the components have been revised to reflect the proposed reallocation of funds. 15. Change in Results Framework. The proposed restructuring does not entail any changes to the PDO and the PDO indicators. All original targets have been met. However, target values for the SPEDP intermediate indicator on the number of completed sub-projects under sub-component "Rehabilitation of Cultural Assets in St. Petersburg is increased from 9 to 10 to capture the inner courtyards site. Furthermore, to monitor the implementation of the inner courtyard sub-project and consolidate the Project results, additional intermediate indicators are introduced as follows: Number of cultural institutions sites rehabilitated under the Project that provide improved unassisted access for people with disabilities Number of cultural institutions sites rehabilitated under the Project with improved visitor facilities Increased usable floor space for public cultural activities and events in the Mikhailovsky Palace of the Russian Museum due to the Project Added floor space for restauration workshops at the Mikhailovsky Palace of the Russian Museum due to the Project Increased number of visitors in the Mikhailovsky Palace of the Russian Museum per year Increase in earnings generated by the Mikhailovsky Palace of the State Russian Museum from public events, workshops, and lectures (Russian Rubles) 16. The disbursement estimates and implementation schedule are revised to reflect the extended Project Closing Date. 17. Other Changes. Paragraph 2 of Part A, Schedule 2 Description of the Project of the Loan Agreement will be amended to include the rehabilitation of the Russian Museum inner courtyards in the list of cultural assets under Part A of the Project (Rehabilitation of Cultural Assets in St. Petersburg). Furthermore, Paragraph 2 of Part D (Project Implementation) of Schedule 2 of the Loan Agreement will be amended to include provision of services of an engineer-consultant and author s supervision to carry out the works on rehabilitation of inner courtyards; and to include provision of consultant services to assess the effectiveness of the Project supported activities and their results. 18. There will be no changes in the institutional and implementation arrangements. The Project will continue to follow the existing Project Operational Manual. 19. The restructuring will not lead to any changes to safeguards policies. The Project s environmental category does not change and will remain Category B, and there are no new safeguards policies triggered. The safeguards issues of the civil works to be supported under the restructured project are in line with and can be addressed by the exiting project Environment Management Plan (EMP) which is also part of the Project Operational Manual (POM). The EMP was updated in May 2014 to reflect changes in the Russian regulatory environment. No changes regarding types and scale of impacts or proposed mitigation measures were made. Effectiveness of the EMP has been demonstrated by the Highly Satisfactory ratings for Safeguards in the SPEDP Implementation Status Reports (ISRs), and there is no need for revision. FISP has a designated safeguards specialist with an extensive track record in implementing the SPEDP and Preservation and Promotion of Cultural Heritage Project and has received training by the World Bank. 20. The subproject will exclusively finance the repair and rehabilitation of the existing historic building that belongs to the Federal Government. Environmental impact from construction activities may include dust, noise, and other

8 construction-related local and temporary inconveniences such as a temporary increase in heavy vehicle traffic. To mitigate such adverse environmental impacts, contractors will be required to follow environmentally sound construction practices and incorporate include environmental safety requirements into the technical specifications and contracts for civil works. Compliance with such instructions will be closely monitored during implementation, as it was done under completed SPEDP activities. Possible environmental issues arising from these activities will continue to be addressed through appropriate instructions, respectively in the EMP and the Operations Manual environmental assessment guidelines updated by the PIU. 21. The implementation of the inner courtyards subproject will not require land acquisition and will not result in involuntary resettlement as the targeted building is owned by the Federal Government. The project focuses exclusively on preservation of existing cultural properties. It will continue to support the protection of high priority cultural heritage assets from further deterioration, increase the capacity of cultural institutions that will be using the rehabilitated sites, improve the operational safety and efficiency of facilities for both visitors and personnel, ensure the security of art objects currently on display, and safeguard other cultural assets from physical damages, theft or other hazards. The restoration and rehabilitation works will primarily include the repair and upgrading of buildings. The SPEDP will not alter the current low- tariff easy-access conditions to cultural events and monuments or the extensive educational out-reach programs enjoyed by all Russian citizens. Throughout the project, the number and outreach of such programs, as well as event capacity of the Russian Museum, will be expanded. Moreover, both the rehabilitation of the inner Courtyards will improve access to physically challenged visitors. 22. Since the intended primary project impact is to rehabilitate the physical cultural assets, a gender lens or specific gender activities were not considered relevant for SPEDP design. Disaggregating the different project outcomes between men and women will not be attempted. It is expected that the project will indirectly benefit patrons (including disabled people), artists and employees across gender boundaries. Nevertheless, an effort will be made to collect data with regard to gender dimensions to inform the Project Completion and Results Report (ICRR) as part of activities aimed to assess the effectiveness of the Project investment which are planned to be conducted during the extended Project implementation period. III. SUMMARY OF CHANGES Changed Change in Results Framework Not Changed Change in Components and Cost Change in Loan Closing Date(s) Reallocation between Disbursement Categories Change in Disbursement Estimates Change in Implementation Schedule Other Change(s) Change in Implementing Agency Change in DDO Status Change in Project's Development Objectives

9 PDO_IND_TABLE The World Bank Cancellations Proposed Change in Disbursements Arrangements Change in Overall Risk Rating Change in Safeguard Policies Triggered Change of EA category Change in Legal Covenants Change in Institutional Arrangements Change in Financial Management Change in Procurement Change in Economic and Financial Analysis Change in Technical Analysis Change in Social Analysis Change in Environmental Analysis IV. DETAILED CHANGE(S) OPS_DETAILEDCHANGES_RESULTS_TABLE RESULTS FRAMEWORK Project Development Objective Indicators More competitive environment due to 10% p.a. increase in number of new SMEs registered in SPB. Value No Change Date 31-Dec Dec Dec % p.a. increase in private transactions for land and real estate. Value No Change Date 31-Dec Dec Dec-2007 Credit rating by international credit rating agency

10 Unit of Measure: Text Value Fitch IBCA: BB (positive) Moody's: Baa1 (Stable); Creditworthy status S&P: BB (stable) Fitch: BBB (Stable), S&P: achieved and No Change Moody's: Ba2 (Figures BBB (stable) maintained are for 2003) Date 31-Dec Mar Aug-2009 Growth in tourism 8%p.a. Value No Change Date 31-Dec Sep Aug-2009 Intermediate Indicators IO_IND_TABLE Divestiture of City owned enterprises Unit of Measure: Text Value Reduction of the Reduction of the number of Cityowned or City- number of City-owned or City-controlled controlled commercial commercial enterprises Baseline value is zero enterprises in St. in St. Petersburg though as this is the start of Petersburg though No Change diversiture or other the process diversiture or other means, including but not means, including but limited to SUEs, not limited to SUEs, achieved and achieved and maintained in 2007 maintained Date 01-Jan Dec Dec-2007 Number of completed sub-projects under sub-component "Rehabilitation of Cultural Assets in St. Petersburg"

11 Value Revised Date 24-Jan Nov Jun-2021 Number of completed sub-projects under "Cultural Investment Facility" sub-component Value No Change Date 24-Jan Nov Dec-2013 Cultural Investment Facility (CIF) resources fully committed by end of fourth year of project implementation and completion of all CIF operations by end of project Unit of Measure: Text Value All CIF funds (US$ All CIF funds (US$ mln. of loan mln. of loan amount) are amount) are fully Baseline is zero, as it is fully committed; and committed; and start of the project: no implementation of all implementation of all CIF funds committed CIF subprojects financed CIF subprojects and no CIF operations from the awarded CIF financed from the completed grants is successfully awarded CIF grants is No Change completed successfully completed Date 24-Jan May Dec-2013 Number of viable/sustainable applications submitted by participants to St. Petersburg Cultural Committee as a result of completion of the Staff Reserve program Value No Change Date 26-Feb Dec Dec-2010 Number of cultural institutions sites rehabilitated under the Project that provide improved unassisted access for people with disabilities

12 Value New Date 31-Jan Nov Jun-2021 Increased usable floor space available for public cultural activities and events at the Mikhailovsky Palace of the Russian Museum due to the Project Unit of Measure: Square Meter(m2) Value New Date 15-Nov Nov Jun-2021 Number of cultural institutions sites rehabilitated under the Project with improved visitor facilities Value New Date 31-Jan Nov Jun-2021 Number of visitors in the Mikhailovsky Palace of the Russian Museum per year Value New Date 15-Nov Nov Jun-2021 Added floor space for restauration workshops at the Mikhailovsky Palace of the Russian Museum due to the Project Unit of Measure: Square Meter(m2) Value New Date 15-Nov Nov Jun-2021 Increase in earnings generated by the Mikhailovsky Palace of the State Russian Museum due to public events, workshops and lecturing activities (Russian Rubles)

13 OPS_DETAILEDCHANGES_COMPONENTS_TABLE OPS_DETAILEDCHANGES_LOANCLOSING_TABLE The World Bank Value New Date 15-Nov Nov Jun-2021 COMPONENTS Current Component Name Rehabilitation of Cultural Assets in St. Petersburg Current Cost (US$M) Action Revised Cultural Investment Facility (CIF) 7.99 Revised Proposed Component Name Rehabilitation of Cultural Assets in St. Petersburg Cultural Investment Facility (CIF) Proposed Cost (US$M) Institutional Strengthening 0.47 No Change Institutional Strengthening 0.47 Project Implementation Revised Project Implementation TOTAL LOAN CLOSING DATE(S) Ln/Cr/Tf Status Original Closing IBRD Effective 31-Aug-2009 Revised Closing(s) 01-Jul-2012, 31-Dec- 2013, 31-Dec-2014, 31-Dec-2015, 31- Dec-2016, 31-Dec Proposed Closing 30-Jun-2021 Proposed Deadline for Withdrawal Applications 30-Oct-2021 OPS_DETAILEDCHANGES_REALLOCATION _TABLE REALLOCATION BETWEEN DISBURSEMENT CATEGORIES Current Allocation Actuals + Committed Proposed Allocation Financing % (Type Total) Current Proposed IBRD Currency: USD

14 ilap Category Sequence No: 1 Current Expenditure Category: IBRD46940 WORKS UNDER PART A 34,024, ,023, ,023, ilap Category Sequence No: 1(A) Current Expenditure Category: IBRD46940 WORKS-HERMITAGE MUSEUM 46,736, ,848, ,848, ilap Category Sequence No: 2 Current Expenditure Category: IBRD46940 CONS. SVS-PARTS C&D ilap Category Sequence No: 2(A) Current Expenditure Category: IBRD46940 CONS. SVS-PARTS C&D3 849, , , ilap Category Sequence No: 2(B) Current Expenditure Category: IBRD46940 CONS. SVS-PART D2 5,250, ,724, ,778, ilap Category Sequence No: 3(A) Current Expenditure Category: IBRD46940 GOODS&WORKS CIF GRAN 7,400, ,329, ,329, ilap Category Sequence No: 3(B) Current Expenditure Category: IBRD46940 CONS.SERV-CIF GRANTS 230, , , ilap Category Sequence No: 4 Current Expenditure Category: IBRD46940 OPERATING COSTS 5,000, ,991, ,161, ilap Category Sequence No: 5 Current Expenditure Category: IBRD46940 TRAINING-PART C ilap Category Sequence No: 6(A) Current Expenditure Category: IBRD46940 TRANCHE I

15 ilap Category Sequence No: 6(B) Current Expenditure Category: IBRD46940 TRANCHE II ilap Category Sequence No: 1(B) Current Expenditure Category: IBRD46940 WORK&CONSULTANT SERVICES UNDER PARTSA,D2,D3 ON RUSSIAN MUSEUM INNTER COURTYARDS SUBPROJECT AND SPEDP EVALUATN ,271, Total 99,489, ,987, ,489, OPS_DETAILEDCHANGES_DISBURSEMENT_TABLE DISBURSEMENT ESTIMATES Change in Disbursement Estimates Yes Year Current Proposed ,427, ,427, ,896, ,896, ,929, ,929, ,399, ,399, ,300, ,221, ,748, ,663, ,926, ,078, ,800, ,700, ,450, ,201, ,221, , ,000.00

16 , ,267, ,500.00

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