Attachment J.1 IEE-RCE USAID Health Learning .pdf

REQUEST FOR CATEGORICAL EXCLUSION (RCE)

Project/Activity Data

Project/Activity Name: USAID Health Learning – Monitoring, Evaluation, Research and Learning

Geographic Location(s) (Country/Region): Nepal/Asia Region

Amendment (Yes/No), if Yes indicate # (1, 2...): N/A Implementation Start/End Date (FY or M/D/Y): 2024-2029

If Amended, specify New End Date: N/A

Solicitation/Contract/Award Number(s): To be determined

Implementing Partner(s): Pre-award; to be determined

Bureau Tracking ID:

Tracking ID of Related RCE/IEE (if any):

Tracking ID of Other, Related Analyses: N/A

Organizational/Administrative Data

Implementing Operating Unit(s):

(e.g. Mission or Bureau or Office)

USAID/Nepal Health Office (HO)

Other Affected Operating Unit(s):

Lead BEO Bureau: Asia Bureau

Funding Account(s) (if available): USAID/Nepal

Original Funding Amount: USD 5 million

If Amended, specify funding amount:

If Amended, specify new funding total:

Prepared by: Sabita Tuladhar, Health Office

Date Prepared: August 05, 2023

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: ☐Environmental Examination ☐Deferral Environmental Determination(s): ☒Categorical Exclusion(s)

☐Negative Determination with Condition ☐Positive Determination ☐Deferred (per 22 CFR 216.3(a)(7)(iv)

IEE Expiration Date (if applicable):

Additional Analyses/Reporting Required: N/A Climate Risks Identified (#): Low ____x__ Moderate ______ High ______ Climate Risks Addressed (#): Low ______ Moderate ____ High _____

1. BACKGROUND AND PURPOSE OF ACTIVITY

1.1 Purpose and Scope of IEE

The purpose of this request for categorical exclusion (RCE) document is to establish that all proposed activities belong to classes of actions eligible for Categorical Exclusions as set out in Agency regulations (22 CFR 216.2(c)) and that there are no foreseeable significant direct or indirect impacts that would preclude them from receiving a Categorical Exclusion. Upon approval of this document, the Categorical Exclusions are affirmed for the project/activity. This analysis also documents the results of the project/activity level Climate Risk Management process in accordance with USAID policy (specifically,ADS 201 mandatory reference 201mal).

This RCE is a critical element of USAID’s mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation.

1.2 BACKGROUND

USAID Health Learning is a monitoring, evaluation, research and learning (MERL) activity that will support USAID/Nepal’s Health Office (HO) to track the progress of health activities at population outcome, and at health facility and municipality levels, and inform USAID/Nepal’s HO on how well health sector investments are yielding results. USAID Health Learning will be a key activity to monitor the progress of the health component of Country Development Cooperation Strategy (CDCS) 2020-2025 Development Objective (DO) 3 - Strengthening inclusive Health and Education Systems.

2. DESCRIPTION OF THE ACTIVITY

The goal of USAID Health Learning is to assist USAID/Nepal's HO and its implementation partners (IPs) to adopt uniform and systematic MERL activities to advance broader organizational learning and development efforts. USAID Health Learning will assist the USAID/Nepal HO and especially its IPs in the following interlinked objectives:

A. Program monitoring and assessments: Strengthen USAID/Nepal’s HO and its IPs’ program management and decision-making processes by providing high quality, disaggregated data collected from surveys, research, and assessments.

B. Knowledge management: Improve USAID/Nepal’s HO, its IPs, and the federal, provincial, and local governments' learning and knowledge management functions by increasing the availability of timely, high-quality evidence that is applicable to different contexts.

C. Capacity building: Strengthen the MERL capacity of USAID/Nepal HO’s local partners and the federal, provincial, and local governments.

Geographic Focus and Target Populations:

This is a non-programmatic MERL activity. The activity will support MERL activities in all USAID Nepal health activities implementation locations. USAID/Nepal’s health activities are implemented in all 77 of Nepal’s districts. This activity will collect data from participants in various health activities including pregnant, and recently postpartum women, clients visiting health facilities, children under five years, health workers, municipality officials, and various other stakeholders, to assess their knowledge, attitude and practices, and health system capacities.

3. NATIONAL ENVIRONMENTAL LEGISLATION

The Government of Nepal (GON) has enforced the Environmental Impact Assessment (EIA) Guidelines

19931; Environmental Protection Act 20192; Nepal Labor Act 20743, Environmental Protection Rules 20204, and Public Health Service Act, 20185 to legalize the environmental mitigation of development projects.

The GON has formulated five major environmental policies:

● To manage natural and physical resources effectively and sustainably.

● To balance development efforts and environmental conservation to fulfill the basic needs of

● the people in a sustainable manner.

● To safeguard national heritage.

● To mitigate the adverse environmental impact of development projects and human actions.

● To integrate the environment and development through appropriate institutions, adequate legislation and economic incentives, and sufficient public resources.

The Guidelines, Act, Rules and regulations provide a basic legal framework and require that a preliminary environmental study {which the GON also calls an initial environmental examination (IEE)}, or a more comprehensive EIA for projects likely to have greater environmental impact, is mandatory and to be done by the proponent prior to the implementation of any development activity. Environment Protection Rules and EIA guidelines have grouped projects into three categories from an environmental consideration point of view:

● Projects that need only a preliminary environmental study

● Projects that need a full-scale EIA

● Projects that are being proposed in sensitive areas

Screening is the first step in the environmental assessment process and is used to determine which study is required for the proposed program, project, or activity. It is the preliminary review of a project to determine potential environmental effects. Screening is the responsibility of the project proponent [or implementing agency]. For most smaller and less sensitive development projects, a preliminary environmental assessment, similar in many ways to a technical and economical pre-feasibility study, utilizing readily available information, undertaking less detailed investigations and using rapid methods for information collection and analysis, will be sufficient.

The following subsections provide a brief overview of the aforementioned Guidelines, Act, Rules, and other regulations.

3.1 NATIONAL ENVIRONMENTAL IMPACT ASSESSMENT GUIDELINES 1993

These guidelines were developed “to assess the environmental impacts likely to be caused by a project, and to promote its positive impacts and mitigate or eliminate adverse impacts by undertaking preventive or other effective measures after integrating the environmental impacts in the planning circle of all the projects to be initiated in the Kingdom of Nepal.” The guidelines require screening of all the activities of a project/program and determining whether an IEE or EIA is required. According to the guidelines, an IEE is required for those projects that are likely to cause known environmental impacts and that can be mitigated. All these projects are included in Schedule 1 of the guidelines. An EIA is required for those projects, as specified in Schedule 2, which have either known significant environmental impact or for which the environmental impacts are not clear.

5 hhttps://lawcommission.gov.np/en/?lsvr_document=the-public-health-service-act-2075-2018

4 https://doind.gov.np/detail/58

3 https://www.lawcommission.gov.np/en/wp-content/uploads/2021/03/The-Labor-Act-2017-2074.pdf

2 https://lawcommission.gov.np/en/wp-content/uploads/2021/03/The-Environment-Protection-Act-2019-2076.pdf

1 http://moste.gov.np/legal_documents/Regulation https://drive.google.com/file/d/1OzCj1UYHOmRP7EA_sU64qcdY-SnNnB9u/view https://doind.gov.np/detail/58 https://www.lawcommission.gov.np/en/wp-content/uploads/2021/03/The-Labor-Act-2017-2074.pdf https://lawcommission.gov.np/en/wp-content/uploads/2021/03/The-Environment-Protection-Act-2019-2076.pdf http://moste.gov.np/legal_documents/Regulation

3.2 ENVIRONMENT PROTECTION ACT 1997

The Parliament of Nepal passed an Act in 1997 for the protection of the environment. The provisions are similar to the guidelines of 1993, that an IEE or EIA is mandatory for the implementation of any development project, but it provides a legal cover to enforce the already existing regulations. In addition, the Act made approvals mandatory before doing any project, and provided recommendations to establish the Environment Protection Council, and Environment Protection Fund and laboratory; to appoint environmental inspectors for environmental compliance; and authorized punishment for violating the environmental regulations.

3.3 ENVIRONMENT PROTECTION RULES 1997 (amended in 1998 and 1999) The Environmental Protection Rules are more comprehensive and added some additional requirements for both IEEs and EIAs. These additional requirements include the approval of work schedules for IEE/EIAs;

new formats for reporting; public advertisement of the proposed projects to seek public opinions of any potential or perceived impacts; monitoring and evaluation procedures; emission permits; definition of the roles and responsibilities for environmental inspectors and laboratories; and compensation provisions. In addition, Schedule 1 and 2 of the 1993 Guidelines were categorized by sectors such as forest, industry, mining, road, water resources and energy, and agriculture. Other schedules were added to define the requirements for IEE/EIA work schedules and matters to be considered during the process. The Guidelines, Act, and Rules require that either an IEE or EIA is conducted for any development project and provide specific guidance for some sectors. However, none of the existing regulations have specific guidance or requirements for the construction of small to medium scale public buildings such as education or healthcare facilities (with the exception of a 25 bed hospital under Schedule 2). From the review of the above regulations and experience from other similar programs, it is concluded that small to medium scale public infrastructure facilities (as described in Section 1.3) are not likely to have significant environmental impacts. These activities could be covered by an IEE and the expected low to moderate level environmental impacts can be mitigated by sound environmental design, best management practices, and environmental monitoring.

3.4 ENVIRONMENTAL PROTECTION RULE, 2019

The act emphasizes new provisions such as Brief Environmental Studies, IEEs and EIAs being under the jurisdiction of local authorities, and provincial and central governments. Among the new requirements of this Rule are the need for a Strategic Environmental Assessment for policies/plans/programs, and climate change considerations for projects..

3.5 ENVIRONMENTAL PROTECTION RULE, 2020

Environment Protection Rules (EPR), 2020 defined thresholds for environmental assessment under 3 categories - Brief Environmental Study, IEE and EIA. It defined the roles of provincial and local governments as well as the process for the environmental assessment of development projects.

3.6 LOCAL GOVERNMENT OPERATIONS ACT, 20176

The Local Government Operations Act, 2017 empowers local authorities to conserve local natural resources, implement environmental conservation activities, and gives them prime responsibility for conducting development projects which include water supply, sanitation, and awareness activities.

3.7 WATER RESOURCES ACT, 19927

The Act is a comprehensive law on the development, use and conservation of water resources in Nepal, aiming to minimize damage to water bodies by requiring EIA and preparation of an EIA report before granting a license to use water resources for any purpose.

6https://www.dpnet.org.np/resource-detail/333#:~:text=Summary&text=This%20is%20the%20Act%20formulated,Disaster%20Ris k%20Reduction%20and%20Management.

Proponents shall make sure that the beneficial use of water resources does not cause damage to other water uses/users (Article 4). Article 17 requires proponents to apply for any necessary land acquisition accordingly; Article 18 requires compliance to quality standards in making use of water resources. Article 19 prohibits the pollution of water resources. Under the Act are two regulations for drinking water : (i) Water Resources Regulation 1993, setting out the implementation procedures for the Act; and (ii) Drinking Water Regulation, 1998, which specifies compliance with drinking water quality standards and control of water pollution (or sanitation) as it affects drinking water.

3.8 PUBLIC HEALTH SERVICE ACT, 2018

This Act is made to provide for public health service. Chapter 5 of the Act - Social, Cultural and Environmental Determinants for Protection, Promotion and Improvement of Public Health has made the following provisions for sanitation and waste management: 1) The Government of Nepal may, in order to control or cause to be controlled the adverse effect to the human health by environmental pollution and waste, make necessary standards in accordance with the prevailing Federal law, 2) The Government of Nepal shall make necessary standards for collecting, reusing, refining, disposing and regulating the health friendly waste, 3) It shall be the duty of the Provincial and Local Level to comply with the standards referred to in sub-section (1) and (2), 4) Each health institution shall manage the risk-free and risky waste by separating them pursuant to the prescribed standards, and 5) Each health institution shall provide the service providers with clean drinking water pursuant to the prescribed standards.

3.9 CONSTITUTION OF NEPAL 2015

Article 30: Right to the clean environment (Fundamental Right) 1. Every citizen shall have the right to live in a clean and healthy environment 2. The victim shall have the right to obtain compensation, in accordance with the law, for any injury caused by environmental pollution or degradation Article 51 (g):

Policies related to protection, promotion, and use of natural resources To make an advance warning, preparedness, rescue, relief, and rehabilitation to mitigate risks from natural disasters

4. ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK ENVIRONMENTAL DETERMINATIONS

In order to achieve the above objectives and the activity will implement following MERL interventions:

Table 1: Activity objectives and key activities.

Objectives Key activities Environmental

Determination 1.Program Monitoring and Assessment

1. Household Surveys: These annual surveys will provide aggregate population-level indicator estimates across several health indices and program areas with a focus on nutrition, MNCH, FP/RH, WASH, and select infectious diseases in line with indicator matrixes and AMELPs of health activities.

2. Health Facility Rapid Assessments (HFRA): Conduct biennial, rapid health facility assessments to track key supply-side indicators tracked by the USAID/Nepal HO, select activities, and the GON.

3. Client Satisfaction Surveys: Measure client satisfaction with health care services supported by USAID, covering USAID’s priority supported geographies.

4. Sub-national Governments Health Systems Capacity Assessments:

Support USAID activities/IPs to conduct two rounds of health systems capacity assessments of local and provincial governments in select intervention areas.

Categorical exclusion (CE)

5. Special Studies and Assessments: Conduct research or assessments to provide data and reports to inform health sector decision making and for use in USAID HO activity baseline, midline, and endline studies. The assessments will cover USAID/Nepal health program technical areas of maternal newborn and child health (MNCH), family planning/reproductive health (FP/RH), nutrition, water, sanitation, and hygiene (WASH), physical rehabilitation, infectious diseases, and health system strengthening.

2. Knowledge Management

1. Further and Deep-Dive Analysis: Support the GON, primarily at the provincial and local levels, to conduct further and deep-dive analysis of the survey and assessment data collected by USAID Health Learning and develop visualizations and presentations for use in policy, guidelines, and service delivery decision-making using appropriate statistical software such as Stata, Statistical Package for Social Sciences (SPSS), R, etc.

2. Collaborating, Learning, and Adapting (CLA): Conduct, facilitate, and/or arrange logistics and other support for CLA events such as review meetings with IPs and the GON, joint field visits with the GON, etc. Use the data collected under this activity, the findings from the further and deep-dive analysis, and other data available in Nepal to organize small-scale learning sessions at sub-national levels to optimize the utilization of data.

3. Planning and Review of the USAID Health Direct Financing Project:

Support annual program reviews and planning workshops with the federal MOHP, provincial health ministries, and local governments.

4. Secondary Analysis of National Level Surveys: Support secondary analysis of national level surveys supported by USAID/Nepal or other external organizations, such as the Nepal Health Facility Surveys, Nepal Demographic and Health Surveys, Nepal Multiple Indicators Cluster Surveys, National Female Community Health Volunteer Surveys, etc., primarily to provide evidence for sub-national governments, USAID, and its IPs in programmatic decision-making.

Categorical exclusion (CE)

3.Capacity Development

1. MERL Capacity Building: Strengthen local MERL capacity by providing training, organizing workshops, coaching, mentoring, organizing exchange visits, etc. in collaboration with USAID Learning for Development activity.

2. Health Research Ethics: Support USAID/Nepal HO to improve ethical practices in health research design and implementation. In coordination with the GON’s Nepal Health Research Council (NHRC), organize events to strengthen ethical review practices across health research supported by USAID/Nepal. Review the research protocols developed by USAID/Nepal health IPs to ensure compliance with NHRC requirements prior to their submission to the NHRC.

3. Data Analysis and Use: Organize events to build the capacity of the GON’s provincial and local governments to analyze, visualize, interpret, and use the data collected by this activity. This includes providing skills on the use of statistical software such as Stata, SPSS, R, etc. using the data collected by this activity.

4. Internship Program: Recruit youth from remote areas and marginalized population groups within USAID health geographies

Categorical exclusion (CE) and build their MERL capacity through a short- to medium-term internship program.

5. CLIMATE RISK MANAGEMENT

In accordance with Executive Order (EO) 13677 and Mandatory Reference for ADS Chapter 201 on Climate Risk Management for USAID Projects and Activities,8 USAID conducts climate risk management (CRM) screening for all new strategies, projects, and activities. CRM is the process of assessing, addressing and adaptively managing climate risks; it helps to ensure USAID investments are resilient to weather events and climate impacts. It improves effectiveness and sustainability of USAID's results and ensures U.S.

taxpayer dollars are well spent.

5.1 CLIMATE RELATED RISK IN NEPAL

Climate change is among the top threats to public health, livelihoods, and productivity, affecting nutrition outcomes and learning and educational attainment.9 Climate change is best characterized as a risk multiplier for health affecting vulnerable groups, leading to vicious cycles of risk and impact. Climate affects health through interdependent pathways, including direct risks such as extreme heat or flooding leading to traumatic injury, exacerbating noncommunicable disease (NCD) and worsening mental health;

ecosystem-mediated risks including vector-borne diseases (VBDs) such as dengue and malaria; and indirect risks such as poverty, conflict, and migration. While Nepal has made notable progress in key health indicators, including reduced child mortality and improved health care coverage, climate and environmental threats still loom large.

Four key emerging climate-related health threats should be considered:

1. Heat-related morbidity and mortality.

2. Nutrition risks

3. VBDs.

4. Waterborne diseases.

Climate change risks exacerbate existing disparities in health service delivery, particularly in remote regions. Despite significant improvements in health coverage, gaps remain between policy and practice, especially at the subnational level. The Ministry of Health and Population (MoHP) has not completed the full assessments of climate readiness of the health care infrastructure and workforce. There is also a need to put in place adequate contingency planning for anticipated climate-related hazards such as heat, floods, and landslides. Minimum standards for climate-sensitive health care infrastructure have also not been developed further impeding refurbishment efforts of existing health care facilities.

Nepal has a Health-National Action Plan which is incorporated within the National Health Sector Strategy.

The strategy acknowledges the climate-related burden of disease and impacts on health system capacities; however, a lack of resource allocation and integration wiDespite significant improvements of the early warning system (EWS), there is insufficient integration with health information systems across a sufficient breadth of climate-related health risks. Since its establishment in 1997, the flow of information to the EWS on VBDs and certain other outbreak-prone diseases has been strengthened. However, there is limited inclusion of climate-related information focused on aspects of health risks. EWS mechanisms do exist for several climate- related disasters such as community-based EWS for floods; however, no comprehensive approach to a fully climate informed health EWS exists. Health information systems are currently not integrated with hydromet services, and there is limited collaboration between entities across the health and environmental sectors. Strengthening a shock-responsive social protection (SRSP) system is another key area of risk management and preparedness.

9 https://openknowledge.worldbank.org/handle/10986/38012 8 https://www.usaid.gov/sites/default/files/documents/1868/201mal_042817.pdf

USAID’s new Climate Strategy10and the USAID/ Nepal Country Development Cooperation Strategy (CDCS) recognizes and addresses climate Vulnerabilities, hazards and mitigation measures as summarized herein.

Nepal’s Climate Risk Profile Fact Sheet can be found here. A factsheet on Greenhouse Gas Emissions in Nepal can be found here. Nepal’s climate risk country profile can be found here.

5.2 CLIMATE RISK SCREENING

Table 2: Climate Risk Screening Objectives/ interventions

Climate Risks Risk Rating

How Risks are Addressed and further analysis

Opportunities to Strengthen Climate

Resilience Program Monitoring and Assessment

Interventions will focus on collecting data from activities and secondary sources to determine how the activities are performing and to understand contexts while designing strategies, and activities. Climate change is not anticipated to impact this set of interventions.

No Risk

Not applicable. There are opportunities to discuss/enhance awareness about climate change impact and environmental and natural resource management wherever relevant during evaluation, studies, assessment, and other knowledge management platforms.

Knowledge management

Interventions in this area of work include developing knowledge management systems, organizing learning summits and other learning and knowledge-sharing events/workshops, developing learning briefs, study syntheses , and policy briefs for dissemination, and promoting knowledge sharing and exchanges among health IPs and GON participants. These sets of interventions are not affected by climate change.

No Risk

Not applicable.

Capacity building

The interventions in this area of work include building capacity of individuals and organization in data analysis, management, and use. These activities will not be affected by climate change.

No Risk

Not applicable.

*Climate Risk Ratings are defined as:

● Low climate risk: Climate change is unlikely to significantly impact achievement of development outcomes relative to other stressors and development challenges.

● Moderate or high climate risk: Climate change is likely or highly likely to significantly impact achievement of development outcomes.

NOTE: Low climate risk does not require the development of specific plans to address climate risk.

Moderate to high climate risk requires appropriate consideration and response to the risk and therefore requires an IEE. In some cases, the program may decide to accept the risk.

Screening of the USAID Health Learning activity showed no climate risk and hence a “No Risk” or “Low climate risk” rating was issued. Hence, the activity does not require the development of any specific climate change mitigation plans.

10 https://www.climatelinks.org/climate-strategy https://www.climatelinks.org/sites/default/files/asset/document/2017_USAID%20CCIS_Climate%20Risk%20Profile_Nepal.pdf https://www.climatelinks.org/sites/default/files/asset/document/2017_USAID%20CCIS_Climate%20Risk%20Profile_Nepal.pdf https://www.adb.org/sites/default/files/publication/677231/climate-risk-country-profile-nepal.pdf

6. RECOMMENDED ENVIRONMENTAL ACTIONS

● In line with objectives, the activity joint monitoring, evaluation, and verification tools should address environmental and social issues, and potential impacts on health and spread of diseases as these relate to the scope of work

● The activity should use opportunities to discuss/enhance awareness about climate change impact and environmental and natural resource management wherever relevant.

● The COR and MEO/CIL shall explain the Request for Categorical Exclusion (RCE) to the IP (and/or executing agencies/beneficiaries.)

7. LIMITATIONS OF THE CATEGORICAL EXCLUSION

The categorical exclusions recommended in this document apply only to projects/activities and sub-activities described herein.

Other projects/activities that may arise must be subject to an environmental analysis and the appropriate documentation prepared and approved, whether it be a new RCE, an amendment, or other type of 22 CFR 216 document.

It is confirmed that the projects/activities described herein do not involve actions normally having a significant effect on the environment, including those described in 22 CFR 216.2(d).

7.1 MANDATORY INCLUSION OF ENVIRONMENTAL COMPLIANCE REQUIREMENTS IN SOLICITATIONS, FIXED-PRICE CONTRACTS a, BUDGETS, AND WORK PLANS USAID will ensure the environmental compliance requirements are incorporated into solicitations, awards, budgets, and work plans, including the relevant limitations of Section 3 above. In addition, climate risk management requirements will also be incorporated.

7.2 GENERAL IMPLEMENTATION & MONITORING REQUIREMENTS

USAID will ensure that the following requirements are met:

● Provide briefings for the IP on environmental compliance responsibilities;

● Ensure integration of compliance responsibilities in prime and sub-awards and grant agreements;

● Ensure compliance with applicable partner country requirements;

● Review project activities annually to ensure that scope is still covered by Categorical Exclusion.

8. REVISIONS

As with all USAID-funded projects and pursuant to 22 CFR 216.3 (a)(9), if new information becomes available which indicates that any of the proposed actions to be funded under this activity might be "major" and their effects "significant," the threshold decisions for those actions will be reviewed and revised by the MEO and an environmental assessment prepared, as appropriate. It is the responsibility of the COR to inform, in a timely manner, the MEO/Nepal and BEO/Asia of any changes in the scope and nature of the approved activities that may require the revision of the approved Categorical Exclusion Threshold Decision.

APPROVAL OF REQUEST FOR CATEGORICAL EXCLUSION (RCE) RECOMMENDED

APPROVED DATE DISAPPROVED DATE

Karen Welch Karen Welch Acting Mission Director Acting Mission Director

CONCURRENCE:

APPROVED DATE DISAPPROVED DATE

Will Gibson Will Gibson Bureau Environmental Officer Bureau Environmental Officer

CLEARANCES:

Clearance: Clear w/edits 8/17/2023

Patricia Mengech, Office Director Date

Clearance: Clear 08/18/2023

Deepana Shanthan, Mission Environmental Officer, USAID/Nepal

Date

Clearance: Cleared in email w/edits 08/25/2023

Andrei Barannik, Regional Environmental Adviser for Central & South Asia, and for Afghanistan and Pakistan

Date

Clearance: Clear 8/30/2023

Grace Hwa, RLO Date

Clearance: clear 9/27/23

David Issak, Acting Deputy Mission Director Date https://docs.google.com/document/d/1gIkFq0zP5p0THty38NZFzjP6MTGnLQmb/edit#bookmark=id.vx1227