REGULATORY/ INSTITUTIONALANALYSIS

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1 REGULATORY/ INSTITUTIONALANALYSIS Intrductin One f the majr characteristics f an attractive cruise destinatin is a custmer friendly and hassle free lgistical prcess fr the disembarking and embarking cruise passengers. This ease f prcess is essential as passengers begin and end a cruise hliday visiting India destinatins and turing turist sites. Gauging the cruise passenger experience is ne f the mst influential factrs fr Cruise Operatrs t determine whether r nt a vessel is deplyed t a certain regin / destinatin. Cruise passengers shuld be categrized as a leisure type f visitr as the cruise industry is nt related t transprtatin that is similar t an airprt arrivals prcess, but mre specifically the cruise vessel and its itinerary are a hliday destinatin and shuld be treated accrdingly. Mrever, the time it takes t mve n and ff the vessel, disembarkatin and embarkatin shuld be an expeditius prcess t allw passengers adequate time fr pre arranged shre excursins t visit the sites f the destinatin, r allw fr independent visitrs t freely mve frm prt t city and back. Ideally, the disembarkatin f a ship with a range frm 2,000 mre than 4,000 passengers shuld nt take mre than 30 t 1 ½ hurs with individual queuing times under 5 minutes fr all the prcesses required. This is nt nly a matter f cnvenience n a typical destinatin visit, but it als relates directly t the feasibility f the earning mdel f cruise crpratins and n shre service prviders, alng with vendrs, retailers & restaurateurs, turism venues, and transprtatin prvides, which are all negatively impacted by lng prcessing times fr disembarkatin and embarkatin. Overall, it allws less time in the actual city / prt area and that directly impacts the amunt f mney that can be spent within the time perid f the cruise vessel visit. In the majrity f the destinatins wrldwide Authrities understand the nature f cruise and rely n the vessel peratr s wn security prcedures and data cllecting systems at ticketing, embarkatin and debarkatin t gather and submit this infrmatin fr clearance prcessing. The time fr prcessing and the gathering f persnal data relates mre in particular t prcedures with regard t Immigratin, Security,Custms and Health and Taxatin, all f which culd negatively affect the embarkatin and disembarkatinprcessing times as well as the htel functins n bard fr nn debarking passengers and crew. The Cruise Prt Operatin is multi faceted, thus there are many aspects invlved in the entire prcess. There are fur main prcedures: Security Immigratin Custms Health Cruise line and private stakehlder interviews have acknwledged that current security prcedures (mre specifically the Immigratin prcess) is the primary hurdle that must be crafted t develp a cruise ecsystem friendly envirnment. Accrding t a cruise line spkesman India s prcedures are cnsidered thewrst in the wrld. Our Team has studied the current prcesses and created flw charts t clearly utlinethe entire prcess. Frm ur analysis issues were identified in the prcess and the causes behind them defined. This analysis and further insights frm case studies and internatinal practices has allwed fr benchmarks that frm the fundatin t the prpsed recmmendatins. See Table 1. Page 1 f 15

2 Table 1: Cruise prcess issues Figures 1 and 2 prvide fr a mapping f the typical India Prt Operatins prcesses fr cruise passenger vessel embarkatin and disembarkatin. Figure 1: Prt Operatins Assessment Mapping f Existing Embarkatin Prcesses Page 2 f 15

3 Figure 2: Prt Operatins Assessment Mapping f Existing Disembarkatin Prcesses At Cruise Vessel Gate Pax & Crew Disembark Baggage Unlading Within Terminal Building Immigratin Baggage Handling Security Screening 1 Custms Baggage Screening At Cruise Terminal Gate Pax & Crew Baggage k Shuttle/Walk Van/Trlley At Prt Exit Gate CISF Security Check 2 Baggage Cllectin Security The current Security Check prcedures are cmplicated, time intensive and incnsistently enfrced. They call fr intensified security requirements and multiple checks creating lgistical issues fr the cruise crpratin. These issues can severely delay passenger disembarkatin / embarkatin prcesses and prt f call shre excursin dispatch prcess. The prcess creates a negative passenger destinatin experience. During the embarkatin and disembarkatin prcess, Security is ne f the mst imprtant areas frm a natinal security perspective. The Security Check prcess is cmplex, as it encmpasses three different security aspects: Buses/Shuttles and Staff (related) Passengers and Crew Baggage (Passenger and Crew) The security prcess varies based n embarkatin and disembarkatin. Tur Operatrs / Prt Agents prvide buses/shuttle service fr passengers and crew members t and frm the cruise terminal and fr land excursins. The cruise prt security prcess is utlined in Figure 3. Page 3 f 15

4 Figure 3: Security Clearance fr Private Sectr Service prviders Busses/Shuttles and Staff (related) The verall prcesses fr cruise security embark / debark are utlined belw: Prt Cruise pre arrival prcess Tur Operatrs/Prt Agents share the infrmatin required fr prt entry with CISF, including vehicle licence plate numbers and registratin, drivers licence cards, guides and ther related staff IDs, etc. (IN ADVANCE). Tur Operatrs/Prt Agents btain prir clearance frm CISF fr the applied buses/shuttles, drivers, guides, staff, etc. Cruise arrival day prcess (Embark) Frm Airprt / Htel / Other CISF Security Check 1 at Prt Entry Gate Fr buses entering fr the first time that day, CISF security will perfrm licence plate verificatin and face t face checks f drivers, guides, etc. Entry int Prt upn validatin against prir verified clearance. Passenger is drpped ff by the bus/shuttle at the Terminal Entry. Bus/shuttle exits frm prt. Cruise arrival day prcess (Disembark) T Shre Excursins / Airprt / Htel / Other Buses/shuttles queue utside prt gate, befre cruise vessel arrival. CISF Security Check 1 at Prt Entry Gate Fr buses entering fr the first time that day, CISF security will perfrm licence plate verificatin and face t face checks f drivers, guides, etc. Entry int Prt upn validatin against prir verified clearance. Passenger bards the bus / shuttle at the Terminal Entry. Exit frm Prt fr Shre Excursins r Airprt / Htel. Cruise arrival day prcess (Embark) Frm Shre Excursins at Prt f Call Quick CISF Security Check 1 at Prt Entry Gate CISF Security will perfrm a quick check t validate the same apprved buses are returning back t the Prt. Entry int Prt. Passenger drpped ff at the Terminal Entry. Bus/shuttle exits frm Prt. See Figure 4 fr the security embarkatin prcess. Page 4 f 15

5 Figure 4: Flw chart f Security Clearance Prcess fr Embarkatin Passenger, Crew and Baggage Passenger and Crew Embark Frm Airprt (start f jurney) CISF Security Check 1 at Prt Entry Gate: Arrive at the Prt entry gate. Face t face check (Ticket and Passprt) f passengers and crew (grup and standalne) against the ship manifest (prvided prir). Upn validatin, passengers and crew cntinue via bus r bard a shuttle r walk t the Cruise Terminal. The baggage is cllected by the Prt Agent and transprted in vans / trlleys t the CruiseTerminal. CISF Security Check 2 at Terminal Entry/Cruise Area Entrance: Face t face check f passenger and crew (grup and standalne) against the ship manifest. Upn validatin, passengers and crew enter the Terminal building r cruise receptin area. The baggage has already been cllected by the Prt Agent (if nt, then it is dne at the Terminal building gate r cruise receptin area entrance. CISF Security Check 3 within Cruise Terminal Building: Custms fficers are present during baggage screening. Security screening Passenger and crew. Baggage Carry n screening and prtal prcess fr passengers and crew. Baggage screening Prt Agent is respnsible fr baggage handling and screening prcess. Fllwing Security prcessing, passengers and crew embark the vessel.prt Agent transprts baggage t the vessel shell dr. Passengers and Crew Embark Frm Shre Excursin Arrival at the Prt entry gate. Page 5 f 15

6 CISF Security Check 1 at Prt Exit Gate: Face t face check and Shre Landing Pass check f passengers and crew (grup and standalne). CISF Security Check 2 at Terminal Gate: Face t face check and Shre Landing Pass check f passengers and crew (grup and standalne) CISF Security Check 3 within Cruise Terminal Building: Custms fficers are present during baggage screening. Security screening Passenger and crew. Embark cruise vessel. Passengers and Crew Disembark Fr Shre Excursin / Airprt / Htel / Other Get a Shre Landing Pass frm the Immigratin fficer. CISF Security Check 1 at Prt Exit Gate: Face t face check f passengers and crew (grup and standalne) with Shre Landing Pass. Surrender the Shre Landing Pass t CISF at the Prt Exit Gate (if end f the jurney). Exit the Prt. See Figure 5 fr the verview f the current security clearance prcess fr disembarkatin at India prts. Figure 5: Flw chart f Security Clearance Prcess fr Disembarkatin Passenger, Crew and Baggage Issues There is an intensified level f security impsed n cruise peratins when the terminal facility is in clse prximity t designated secured naval areas r shared facilities with ther areas f prt peratins, such as carg mvement. There are incnsistent security prcedures at all Indian prts, as each prt is fllwing its wn security prcedure inclusive f shre pass requirements fr passengers and care Page 6 f 15

7 There are multiple CISF shre pass checks at every prt causing a majr incnvenience and time delay passengers and crew need t g thrugh multiple checks including at the terminal, bus dispatch, gate, etc. Every prt has its wn versin f the shre pass. It is als required t be printed n bard each cruise ship prir t arrival at the prt. Excess checks f every bus permit, driver license, etc. at the prt gate delay the entire prcess significantly as the caches take time t assemble and be prepared fr the passenger disembarkatin prcess. Fr every cruise call each bus, driver, etc. must g thrugh a registratin prcess. This is nt nly a bureaucratic burden n the Prt Agent and Tur Operatr, but als the Indian rganizatin. It als des nt allw fr any flexibility n the part f the Tur Operatr shuld a bus r driver have an issue in the AM arrival. There are embarkatin lgistics issues, such as the cllectin and mvement f baggage / security screening. There are time cnsuming manual prcesses that culd use technlgy t alleviate issues. Overall, this prcess creates an extremely pr passenger experience. Causatin Shared resurces: Cruise and ther prt related functins that are integrated and share facilities inclse prximity increase security requirements leading t multiple face t face checks (duplicatin f Immigratin prcesses). Inefficient cmmunicatin & training: Due t the unclear / nn updated prcedures and / r prdirectives, the grund persnnel prcesses are pen t interpretatin by prt, creating incnsistencies acrss the Indian prt system, thus lengthening the time f the prcess verall due t the incnsistency. Manual prcesses: Currently, the entire security check prcess is nt aligned with any technlgy(cmpletely manual) and in sme cases multiple checks are cnducted t avid manual / human errr, further prlnging the prcess. N natinwide Standard Operating Prcedure: There is n mnitring frm any Central Level as tthe implementatin n the grund (prt). N pl f pre registered drivers, guides and vehicles: Withut a prir selectin prcess, theregistratin / security clearance prcess is cnducted fr each and every vessel call fr each vehicle, each driver, each service prvider, each staff member, etc. This creates an extreme burden n the peratr, csts time and dllars and creates additinal time cnsuming bureaucracy. Recmmendatins fr Imprvements / Plicy Level Strategies The pre cruise requirements fr tur peratins (registratin f drivers, staff, caches, etc.) culd be dne electrnically and streamlined with a licensing practice fr the entirety f the cruise seasn. Implement a simple system (ne single windw) fr the entrance f vehicles, persnal and guides t the prt. Enter all data electrnically. Last minute changes need t be allwed. There is n need t check insurance, registratin and license papers fr all vehicles each time. A simple sticker n the bus shuld prvide fr the prper registratin and required infrmatin (plus the security check). Security can perfrm a Quick Check f Identificatin Dcuments fr guides and persnnel invlved in cruise peratins as needed. There is n need t d any additinal face t face checks n disembarking passengers and crew as nce the vessel is cleared as all frmalities are cmpleted. Each passenger and crew als carries a shipbard ID which prvides key infrmatin fr each persn including a pht, full name, DOB, etc. CISF shuld be prvided with a manifest f passenger and crew (sent electrnically) befre the ship arrives as this is a requirements fr cruise vessel clearance by Immigratin. Page 7 f 15

8 If there is a need t check a particular persn they can be identified prir and request the vessel t call that persn t be interviewed separately, thus aviding multiple face checks f every persn. Security checks fr embarking passengers shuld be dne ne time at the Terminal Entry OR Prt Gate (nt bth). Each cruise vessel perfrms an independent security screening f hand baggage and persn via prtal (upn entry t the vessel) and verifies the check in prcess was cmpleted and the passenger / crew has the crrect shipbard Identificatin. Create a separate dedicated apprach rad and entrance frm / t the cruise terminal. This rad shuld be lcated adjacent t the secure area. Assess pssibilities t have direct access cnnecting t the main rad in all prts. This allws separatin f cruise peratins frm carg activities and avids multiple security checks. Separatin f Carg and Passengers flw is the benchmark fr new terminal develpment glbally and is helpful frm a Prt safety and security perspective. Passengers and crew members present their ship s ID pass (each has a pht). N cpies f passprts r shre passes are t be printed and checked by CISF (This is a majr incnvenience fr the cruise ship, passenger and shipbard staff). This is a cmmn practice all ver the wrld. CISF needs t use technlgy, and get away frm time and manpwer cnsuming manual prcesses. CISF must trust and use cruise vessel data cllectin systems, crdinate with Immigratin and reduce bureaucracy. Jint cllabratin between the Bureau f Immigratin (BI) and CISF with CLIA wuld enable a ptential redesign f prcedures and culd then place India in a leading rle in the field as a Glbal Champin. Security prcedures need t be cnsistent in all India prts. Cnsider nrmalizatin f security levels when in prximity t naval installatins / vessels. Develping systems t transprt bnded checked in luggage frm airprt directly t ship culd be helpful in reslving luggage lgistics issues. Training f lcal management and staff is a key issue t implement prcedures as directed frm Central level. With the abve recmmendatins substantial labur frce can be saved within the Gvernment, the Private Sectr and the Cruise Industry likewise Independent passenger cverage Prvide adequate security and access t prts fr passengers vernighting and visiting lcal venues / shws, thus returning late at night. Allw Turism persnnel t bard the vessel r have stands at the pier t prvide turism infrmatin. Assist the independent passenger with a pleasant experience: Prvide maps and infrmatin abut the destinatin. Currency exchange infrmatin. Prvide easy access t the destinatin: Taxis with crrect and fixed pricing. Shuttle bus frm the ship. Immigratin The current Immigratin prcess is incnvenient, extremely time cnsuming and incnsistent fr the cruise vessel and passenger prcess. There is n unifrmity acrss varius prts and the visa prcess is lengthy. While the E visa is available, there are sme majr implementatin issues, which further increase the negative passenger destinatin experience. Additinally, the prpsed e Landing Card is perceived t have multiple implementatin issues. The current Immigratin prcess is utlined belw: Passengers and Crew Embark Frm Airprt / Htel / Other (start f jurney) Arrival at the Cruise Terminal building after CISF security check. Immigratin clearance: Present ticket, passprt and visa t Immigratin fficer. Security screening: Passenger and crew security screening. Page 8 f 15

9 Baggage screening and prcessing (by Prt Agent) Embark vessel. Passengers and Crew Disembark Fr Shre Excursin Arrival at the Cruise Terminal building frm the cruise vessel. Immigratin clearance: Present ticket, passprt and visa t Immigratin fficer. Obtain entry stamp n passprt. Obtain a Shre Landing pass frm the Immigratin fficer. Present the Shre Landing pass alng with passprt cpy t CISF at the Prt Exit Gate. Exit Prt. Passengers and Crew Disembark T Airprt / Htel / Other (end f jurney) Arrive at the Cruise Terminal building frm vessel. Immigratin clearance: Present ticket, passprt and visa t Immigratin fficer. Obtain entry stamp (if prt f entry in India). Obtain a Gate pass frm Immigratin fficer (if d nt have a Shre Pass). Present Custms Declaratin frm. Surrender the Shre Landing Pass r Gate pass t CISF at the Prt Exit Gate. Exit Prt. Deviances frm the abve prcess includes the fllwing examples: Shre Landing Pass: Each Indian Prt has a different prcess. By example, Mumbai Prt accepts the e landing card with a passprt phtcpy; Cchin Prt requires the vessel t adhere a pht n each card. This makes it very difficult fr the cruise vessels t be acquainted with the exact requirement fr each prt. It is als extremely time cnsuming (e.g. making cpies f passprts and pasting phts) On bard Immigratin clearance prcess: On bard Immigratin clearance when a vessel is cming frm a prir prt in rder t avid lng clearance times. This happens in Cchin, Ga and New Mangalre. N Face t Face check: In Prt Blair there is n face t face check, but Immigratin cnducts a bulk passprt check. Issues and specific cmmentary n the Immigratin prcess The prcess is time cnsuming, cmplicated and incnsistent (frm prt t prt). The arrival f a 4,000 passenger cruise ship may be cmpared with the arrival f 15 B747 planes at nce t an airprt. This wuld create multiple lgistical challenges at a large airprt facility. Prcedures need t be designed t address the lgistics that are specific t the cruise industry. Refer t thechapter Intrductin. Face t face immigratin in every single prt. This is deemed unnecessary if cming frm anther Indian prt r a Far freign prt n a clsed lp service that the Indian Security Services have vetted prir. Bureaucratic burdens are cmmn practice and include: Shre leave passes must be prepared at every single Indian prt. This prcess includes an ID that is ppulated with passenger / crew details / pht. Must be delivered t the passenger / crew directly in rder t be signed by them, then cllected back t insert in each passprt / seamen s bk. They are then presented with dcuments t an Immigratin fficer, wh will verify them befre validating each with signature and stamp. Page 9 f 15

10 i.e. fr each 7 days cruise the Csta Ne Classica printed an average f 2,300 crew shre leave passes f which 80% are dispsed f due t the fact that crew is nt always able t g ashre. Based upn internatinal cruise experience nrms this extreme prcess is nt understandable t the cruise industry and ship s persnnel. There is a high n bard labur cst t accmplish this task each time. When ging ashre passenger / crew need t take bth their shre pass and a cpy f their passprt. If the shre pass r cpy f the passprt is lst it can be difficult fr the persn t return t the vessel. The shre pass will need t be replaced n bard the vessel, but the passprt culd take much time and cause the vessel and passenger specifically issues with travel, prt clearance, immigratin, etc. Authrities make mistakes and mit stamps. Passengers are frced t return t the vessel by Terminal Security. Passengers and crew g ver 3 t 4 checks inclusive f CISF t mve frm ship t city and vice versa. Passprts are taken away frm the Terminal t an ffice fr hurs t be scanned and then brught back n bard. This passprt prcess places freign passprt hlders at risk. Sending Immigratin fficers t the prir prt f call is unsustainable with grwing vlumes and can nly be cnsidered as a temprary slutin. Cruise Terminals being currently planned cannt accmmdate Immigratin prcedures fr large vessels with an average f 4,000 t 5,000 plus passengers. Limited human resurces: The current situatin requires enrmus prcessing time and / r resurces. With regard t Immigratin checks and/r CISF checks it shuld be understd that as an Internatinally accepted benchmark the prcessing time n the grund fr passenger entry has t be limited t a maximum f 15 minutes (prt f call) and 30 minutes (hmeprt). Individual queuing time shuld be limited t 5 minutes. Even with a minimum prcessing time f 30 secnds per passenger, a ttal time f 2,000 minutes is required fr a ship f 4,000 plus passengers. In rder t prcess entry within 30 minutes mre than 60 bths are required. Visa prcessing is still a huge prblem, as all internatinal passengers need t btain visas prir t their departure frm their hmeland, and there is n prvisin f n arrival visa at Indian seaprts. E visa is fast, lw cst and cnvenient. This is expected t develp rapidly. E Visa is already ffered and being used in the turism industry. Hwever, there are huge implementatin issues. By example, 7 passengers with e visas were denied entry t India in Nvember E Visa requires cllectin f bimetrics thus lengthening the prcess time further. It is likely the whle prcess wuld fail if the prpsed E Landing Card is fully intrduced and each cruise vessels is required t cllect passenger bimetrics. E Landing Card The prpsed E Landing card will require each cruise vessel t prepare a separate passenger file next t the already existing passengers manifest. This file wuld include passprt infrmatin, pht, and visa infrmatin. If a passenger btained an E Visa the file wuld als include bimetrics that wuld be required t be cllected n bard. The file wuld be required t be upladed hurs prir t arrival in the first prt f India entry. This wuld be upladed t the BI system t undertake n line clearance. BI wuld prvide a file f E Landing Cards fr cleared passengers that wuld need t be printed and distributed n bard each cruise vessel fr each sailing. Nn cleared passengers wuld g thrugh a face t face check. The E landing card is valid fr each Indian Prt and is cllected by Immigratin upn departure. The prcedure in fact utsurces BI tasks t the vessel and places a heavy burden n the ship s human resurces. Assuming every passenger has btained an E Visa (which given its success, is realistic fr the near future), and assuming an average necessary prcessing time per passenger f 5 minutes (inclusive f frmatting data, uplading n line, printing and distributing landing cards) fr a ship f 4,000 passengers, then that means 20,000 minutes r 333 man hurs is required fr prcessing. Shuld this be dne in an vernight shift envirnment this means 42 crewmembers Page 10 f 15

11 wuld be needed t cmplete this task. This is clearly nt feasible. It is hard t believe that the E Landing Card wuld wrk fr the Indian Prts and the cruise industry. Recmmendatins fr Immigratin prcessing imprvements Rethink Visa requirements and the prcess. Make the prcess easier and friendlier fr cruise turists t visit India. Allw E visa t be applied fr cruise passengers (AND mdified t wrk). Immigratin clearance t be dne at first prt f entry nly. Rethink the n line prcess t ptimize it fr all parties invlved. Maximize the use and integratin f technlgy. Use the cruise ship s data cllectin systems. Jint cllabratin f Bureau f Immigratin (BI) and CISF with CLIA wuld enable a redesign f prcedures. India culd becme a Glbal Champin and set the internatinal standard fr Immigratin prcessing. It is currently a greenfield peratin, thus it is a unique ne timechance t make this happen. Waive bimetrics until the cruise industry is ready. The prcesses in each Prt f Entry shuld be identical. Instructin & training f the Officers respnsible fr this prcess are essential. Achieve substantial saving n man pwer Once cleared by Immigratin n special landing card wuld be required t mve ashre. Passengers / crew wuld be required t carry their ship ID card ashre nly. Use the ships ID card as the fficial landing card. All passengers infrmatin is stred n that card and it cntains a pht as well. Eliminate crew shre passes. Treat them as turist visitrs. Crew have their individual ship ID which can be used fr identificatin and checks. As an ptin a Grup landing card culd be created. If shre passes cannt be eliminated then have ne shre pass fr the whle cruise (Als in the case f crew that wrk n bard fr the whle seasn). After disembarkatin clearance n additinal passenger and crew checks shuld be cnducted at the Prt r Terminal by any fficials. Only upn returning t the Prt (nly at the Gate shuld a check f ship s ID be perfrmed). Their passprts are held n bard. They always cme back t the ship. They carry a ship s ID with all their passenger infrmatin n it at all times. The cruise ship has all their passprt infrmatin available, which can be prvided up t 72 hurs prir t Indian Immigratin. Redundant cntrls f passprts and shre passes by security staff must be avided. It delays the departure f passengers frm the prt can aggravate passengers. Cnsider the intrductin f a Visa Waiver Plicy fr select natinalities (Cnsider the ship t be intransit with n visa necessary). India shuld waive the landing cards fr cruise passengers with immediate effect. This has been eliminated in mst cuntries and adapt the ship s ID. After plicy decisins have been made a Standard Operating Prcedure shuld be written t prvide fr training & educatin f the persnnel carrying ut the prcess. Internatinal Practices / Advise fr India / Plicy Level Strategies Table 15 prvides an verview f Internatinal clearance prcedures fr cmparative cuntries with India. As shwn, there is a wide variety f clearance prcedures, with many f the cuntries currently discussing the tpic f bimetrics as a future prcedure fr checking incming travellers t the cuntry. Additinally, and mst imprtantly, cruise peratins are treated differently in many cases than an airprt arrival due t the nature f the entry mass arrival f turism and the ability / bligatin f the cruise line t perfrm / allw security screenings n passengers prir t barding / arrival t meet security, ISPS and lcal immigratin requirement plicies. Page 11 f 15

12 Table 2: Immigratin / Security India vs. Internatinal Practices Page 12 f 15

13 Nte s: *) Prcess fails in case f E Visa; **) frm Initial dck side check in, and eventual Malaysia, but recently cmplicated prcedure each vessel. On debarkatin the PAX find tw prceed t cllect their luggage and g thru C Schengen Area, each cuntry r even each Pr Based upn this study (Cruise Line Internatin begin assessing and dev manifest develpment subsequently allw fr f directin in which wrld a greenfield peratin Regardingg the key indic Visa: Cnsider a the wrklad.

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