Coronavirus and long term policy [UK focus]post by weeatquince · 2020-04-05T08:29:08.645Z · score: 51 (22 votes) · EA · GW · 3 comments
Aim of document: Context and Disclaimer Other ways to help Contact 1. Short term UK response to COVID Positives: Areas for possible improvement POSSIBLE ACTIONS – FOR OTHERS International development POSSIBLE ACTIONS – FOR OTHERS Animal welfare POSSIBLE ACTIONS – FOR US OR OTHERS International leadership and cooperation POSSIBLE ACTIONS – FOR US OR OTHERS 2. Medium term COVID endgame Avoiding overuse of powers Making the most from the rapid policy changes POSSIBLE ACTIONS – FOR US POSSIBLE ACTIONS – FOR OTHERS 3. Long term – UK focus Preventing future pandemic POSSIBLE ACTIONS – FOR US Preventing future risks – UK focus POSSIBLE ACTIONS – FOR US Other risks POSSIBLE ACTIONS – FOR US OR OTHERS: Broader future focused policy POSSIBLE ACTIONS – FOR US 4. Long term – Global cooperation focus Bilateral action Improving existing global institutions POSSIBLE ACTIONS – FOR US OR OTHERS Creating new global institutions An “IAEA” for biosciences An institution to broadly identify, prevent and manage global risks POSSIBLE ACTIONS – FOR US Annex A: How to help as an individual Annex B: DFID response General thoughts On vaccine funding and ODA DFID commitments to date DFID plans going forward Annex C: International cooperation Annex D: Scenario planning Event description – internal Event description – Parliament Coronavirus scenario planning exercise Annex E: review of the risk register LIAISON COMMITTEE Proposal for a special inquiry (ad hoc) committee in 2020-2021 Description of the proposal (in 100-500 words): None 4 comments
Written on 01/04/2020
Aim of document:
- to work out how policy makers should be responding to Coronavirus with more of a long-term Future Generations perspective (starting with the short-term and working forwards).
- thoughts on the best actions we (the secretariat to the APPG for Future Generations and associates) and any others can take to respond to this crisis and shape a better future.
Context and Disclaimer
This was written initially for internal use by the secretariat to APPG for Future Generations. My expertise is in UK policy, in particular regulation safety and risk. In some areas I have, for completeness, opined views despite lacking expertise on these topics (e.g. on the immediate response and on some international institutions) – apologies. Feedback and criticism are welcome. Sections 2, 3, and 4, would be relevant for readership outside the UK.
Other ways to help
Pushing for policy change is only one way to help the world right now. This got started by me setting out my thoughts on other ways to have an impact in Annex A.
If you have found this document useful, want to talk or have any questions please let me know. Get in touch at email@example.com.
1. Short term
UK response to COVID
I am not an expert in pandemic response and not keen to take up the time of experts so the following section should be treated with a grain of salt.
My non-expert view is that to date the Government has responded satisfactorily to the crisis:
- The Government appears to be led by data and listening to science and academics. (Their response seemed to have been shifted by criticism from Imperial academics.)
- Overall the approach taken seems to be in line with the “hammer and dance” approach that looks to have a reasonable backing amongst people I trust . Discussed here.
Areas for possible improvement
- Initially the Government was slow off the mark and poor at clearly communicating plans.
- A number of people are calling for widespread use of masks and the UK government has not adopted this policy – that said, the evidence here is patchy.
- The Government could roll out tests and ventilators quicker, e.g. randomised antibody tests would help us know the case rate [LW · GW] – that said, they are probably moving as quickly as they can.
- The Government should publish more information more regularly. For example they are likely asking UK embassies around the world to collate data on what each country is doing. Information like this should be made public.
POSSIBLE ACTIONS – FOR OTHERS
The APPG for Future Generations will not be taking action on this. If others wish to take action, especially anyone with relevant expertise, they could:
- Continue to monitor the approach taken and organise feedback if it looks wrong.
- Review and assess the published scientific evidence that underlies the response.
- Look into the #masks4all campaign. If the use of masks appears beneficial, then promote the campaign.
- Maybe call for randomised antibody testing.
- Asking the UK government to publish data that could be useful globally, for example analysis of approaches taken around the world.
I expect within the next few weeks we will see devastating impacts of Coronavirus in the developing world (see picture, 27/03/2020).
DFID is mobilising to address this. Non-key projects are open to being cut and resources shifted to supporting countries contain and recover from Coronavirus. More information is in Annex B.
One area of concern is that ODA (Official Development Assistance) funds are being shifted to support the UK’s internal efforts against Coronavirus. For example it is unclear that the £250m committed for vaccine research is for development purposes or to directly benefit the UK. Some development money may be being spent on UK ventilators.
POSSIBLE ACTIONS – FOR OTHERS
- Look into if ODA is being spent on the UK, consider carefully the pros and cons of this (even if selfish, vaccine development does provide a global good) and call out the Government if so. If you do this please do get in touch. The APPG could likely get MPs/Lords to ask Parliamentary Questions to push the Government on this.
All areas of government have been asked to find deregulatory easing measures to support businesses. There is no indication that this is resulting in a relaxation of animal welfare rules. (Based on conversations, DEFRA publications and NFU & FG industry websites).
POSSIBLE ACTIONS – FOR US OR OTHERS
Continue to monitor this issue.
International leadership and cooperation
There has been a lack of strong international leadership and global cooperation by states so far. To some extent this has been addressed this week with meetings by both the G7 and G20. Statements from these groups express commitment to respond to the crisis, prevent global trade disruptions, ensure there is funding and support for the WHO and for vaccination charities and, in the longer run, increase epidemic preparedness. (See full summary in Annex C)
It appears that the UK Government’s focus is on supporting UK citizens – and letting DFID do its job. For example statements and plans from the Foreign Office focus on getting UK citizens home and keeping supply chains open (crucial given plans to procure ventilators form abroad).
It would be great to see:
- More cooperative messaging: The UK Government could publicly make the case for treating this as a global issue. Fostering an environment where states are vying to show international leadership could help encourage global cooperation.
- Encouraging stronger commitments from other countries. The commitments in the G20 statement were relatively weak. There are commitments that the UK could push for that would favour us in the long run, specifically:
- Financial commitments to support the WHO, CEPI and others and to support healthcare in less developed countries. The UK is already donating significant funds to humanitarian aid so could push other countries to do similarly (e.g. committing 0.7% GNI to ODA with a large % to humanitarian work).
- Commitments to share any vaccine or treatment or health data. There is a risk that a vaccine or treatment is developed but that it is controlled, prices are raised and poorer individuals or states are denied access. An agreement at this early stage to share vaccine development could help mitigate these risks.
- Action taken to prevent abuse of emergency powers. Over the next few years we may see a significant rise in autocratic states as leaders hold onto the emergency powers. (For example Orban has essentially made himself a dictator).It is unclear how much the UK can do here but UK leaders could at least call this out.
POSSIBLE ACTIONS – FOR US OR OTHERS
- Further research on vaccine and treatment sharing agreements.
2. Medium term
It could be useful to see more thinking about how the situation may develop over the next few years and what challenges are likely to arise.
As mentioned above there is a risk that a vaccine or treatment is developed but that it is controlled. Early agreement on vaccine distribution could be useful now, as could planning for this eventuality. There may be other solutions to this problem like influencing the pharmaceutical industry or the Government funding vaccine research through prize funds.
Avoiding overuse of powers
The emergency powers put in place by the UK Government have a 2-year sunset clause and the Government has to report on their use every 8 weeks. This seems satisfactory for preventing abuse. Government surveillance would help fight the virus in the short term but may well be unnecessary and something to be wary of, even in the UK. (for more on this see this article.)
Making the most from the rapid policy changes
The emergency situation is leading to very rapid policy changes across the board. There are changes to rules about evictions, fiscal policy, nationalised railways, and so on. Lifestyle changes as a result of lockdown could also impact expectations about how people work and live. These rapid policy and lifestyle changes present opportunities to prepare and learn.
There are many examples of how action to support good policy making now or hold onto good policies could help, but to pick two:
- Domestic violence is increasing in areas with lockdown. The UK could invest in innovative digital ways of communicating with victims, which will likely remain relevant.
- Due to coronavirus medical care in prisons is being increased (needs source) and overcrowding reduced by realising low risk prisoners early with supervised community sentences. These practices may stick.
POSSIBLE ACTIONS – FOR US
- Scenario planning. The APPG for Future Generations plans to run some scenario planning exercises internally and for Parliamentarians. See event plans in Annex D.
POSSIBLE ACTIONS – FOR OTHERS
- Pushing for other policy changes on any of the many important and rapidly changing issues.
3. Long term – UK focus
There is a saying that we are always “preparing to fight the last war”. It is as true in this area as any others. The last great pandemic to hit the UK was the 1918 Spanish Influenza pandemic. The UK had an extremely comprehensive plan for dealing with pandemic flu but no detailed plans to deal with any other pandemics. The UK risk register says that “emerging infectious diseases” could only lead to “up to 100 fatalities”.
The world will almost certainly strengthen global health systems going forward. But the key risk is that we, once again, learn the wrong lessons, for example by preparing to fight another Coronavirus as opposed to broad system and institution strengthening to combat potentially more deadly pandemics or other global risks.
Preventing future pandemic
There is a risk that the UK only prepares for Coronavirus and not for any other pandemics. This sounds like it would be a very foolish mistake to make but it is what appears to have happened to date in the UK. We need to ensure that we invest in broad platform diagnostic and vaccine technologies and develop broad pandemic plans so that we can fight a range of future pandemic risks. Similarly we may plan for outbreaks that are as bad as the Coronavirus outbreak but not prepare for the possibility of something even worse.
Suggested policies include:
- A generic adaptable “pandemic plan” (like a broad version of the Pandemic flu plan).
- Consideration of extreme cases (e.g. 1 million+ deaths in the UK).
- Ensure adequate domestic stockpiling and production of PPE and countermeasures.
- Run scenario-planning exercises.
- Research and develop broad platform-based vaccine and diagnostic technologies.
- Border closures often do not work. Consider changing the criteria so they are used less.
There is a risk that the UK ignores human-caused pandemics and only focuses on natural pandemics. This could be an easy mistake to make but human-caused pandemics could be much more deadly than any natural ones and pose the bigger overall risk. Worse, we could see funding without appropriate oversight for high-risk dual use research.
Suggested policies include:
- Assign responsibility for ‘dual-use’ research and technology to a Minister.
- Increase transparency around accidents in BSL-3 and BSL-4 laboratories.
- Ensure that all DNA synthesis is screened for dangerous pathogens.
- Develop rigorous standards for research that poses security risks
- Establish a National Centre for Biosecurity and Biosafety to improve culture in industry and academia.
- Establish a Biosecurity Leadership Council to collaboratively develop biosecurity policy
- Appoint a liaison officer to improve coordination between the biosciences and security communities.
- Improve and clarify processes for inter-organisational / cross-government cooperation.
That is all a bit jargony. If you want more detail on suggested policies see: 80000Hours: The 12 best ways to stop the next pandemic and [APPG Future Generations] Biosecurity policy recommendations.
POSSIBLE ACTIONS – FOR US
- Open letter on preventing the next pandemic, with as many eminent signatories with relevant expertise as possible. APPG for Future Generations to discuss with Alpenglow.
Preventing future risks – UK focus
The most recent National Risk Register1 suggested that “emerging infectious diseases” could lead to “up to 100 fatalities”. This is both a gross underestimation of the current Coronavirus situation and was out of line with the views of experts2.
We know there are problems with the National Risk Assessment process. The report Evaluating UK natural hazards identifies a host of challenges including: depoliticising risk assessments, assigning risk owners, dealing with uncertainty, and acting to prevent future risks. High consequence low probability threats – events so extreme that one occurrence is too many – need to be more discussed.
When crises hit, the costs can be in the hundreds of billions, but investment in early planning and preparedness can significantly mitigate these risks and costs. Unless the UK’s risk management process is improved, we will be under-prepared to handle future disasters. We need a better risk assessment that looks at high consequence low probability risks, longer timescales (than just 2 years) and assigns clear risk ownership.
CSER has been developing suggestions for what a good national risk management strategy would look like at https://www.gcrpolicy.com/home.
We need to make sure that the response to the current disaster is not just plugging in a few new numbers into the chance of a pandemic risk, but that the way risk management is undertaken in the UK undergoes an independent root and branch review.
POSSIBLE ACTIONS – FOR US
- Push strongly for this. Eg Op-Eds and/or letter to Cabinet Office. Already requested a House of Lords review (see Annex E). Working with Lord Rees.
We can also expect the current crisis to lead to improvements in other specific areas of resilience such as supply chains and food security.
POSSIBLE ACTIONS – FOR US OR OTHERS:
- See if we can support AllFed on food security policy work.
- Further research: list related areas of resilience and suggested policy actions
Broader future focused policy
The APPG for Future Generations is working with Lord Bird to push for a Future Generations Bill (based on the Welsh model) and supporting the Today For Tomorrow campaign. We will continue this work, although perhaps focus more on the risk mitigation element.
It is unclear how the current situation will affect manifesto commitments but if the pledged “Constitution, Democracy and Rights Commission” is to go ahead, it could be pushed to focus on the role of government to prevent future risks.
There is also a good case for pushing the Government to improve its capability in and use of foresight and horizon scanning work.
Other policies in this space see [APPG future generations] Policy making for the long-term
POSSIBLE ACTIONS – FOR US
- APPG to continue with actions in this space.
4. Long term – Global cooperation focus
Probably the biggest missed opportunity risk and perhaps the most important thing to focus on is ensuring that global cooperation on preventing extreme risks improves.
Bilateral actions are the easiest actions in this space as they do not require global coordination. For example the UK could:
- Become the world leader in rapid pathogen and data sharing agreements between nation states to enable and streamline time-sensitive research and development
- Create a Research Institute on Global Biodefence which could focus on strengthening disease surveillance technologies, horizon scanning capabilities and improving intra-outbreak countermeasure development.
- Collaborate with other developed nations to strengthen the health systems of less developed countries. As mentioned, the UK does more of this than others and could lead the way. The UK could help developing countries participate in international governance processes, learn from the UK’s expertise and prepare for pandemics.
- Encourage major world powers to each appoint someone responsible for registering and responding to global risks to a senior government position.
Improving existing global institutions
Changes to international institutions are difficult because the barriers are political and global. For example, if the UK unilaterally decided to increase funding to the WHO, this could make the WHO appear to be a ‘pet organisation’ of Western powers. Buy-in needs to be global.
The World Health Organisation (WHO) is already coming under significant scrutiny. Various groups have been calling for reform to the WHO for a while and now may be the time to drive forward useful changes. This is not my area of expertise so I cannot comment in detail about what changes I would like to see. But for starters it would be good to see all WHO member states providing additional resources for rapid disease surveillance, diagnosis and control to enhance the WHO’s ability to respond to pandemics. Stronger reforms may also be appropriate.
[Edit: The reforms needed may be more complex than just more funding and powers. This article suggestes the WHO failed to use strengthened powers it acquired in post-SARS reform, because it defers to the sovereignty and preferences of directly affected nations.]
The Biological Weapons convention (BWC) is significantly weaker than the Chemical Weapons Convention (CWC’s). The BWC could be scaled up to look more like the CWC, for example by raising its budget from $1.4 million to $80 million and granting it investigatory powers. This would not be as simple as just copying the way the CWC works, as there are challenges with the CWC’s verification process that would need to be learned from.
POSSIBLE ACTIONS – FOR US OR OTHERS
- More research. What WHO reform is needed? Would it make sense for the UK to lead a resolution on WHO reform? How to improve the BWC?
Creating new global institutions
As above any changes here need global buy-in.
An “IAEA” for biosciences
Alongside improving pandemic preparedness (e.g. by improving the WHO) and preventing the malicious use of biological weapons (e.g. by improving the BWC), a new institution could exist to ensure the responsible behaviour by all actors working on biosciences. Such an institution could work to prevent any unnecessary sharing of scientific data that could be used by malicious actors, and ensure safety precautions are taken to prevent any accidental release of pathogens.
A good model would be to have an institution similar to the International Atomic Energy Agency (IAEA) but focused on biosciences rather than nuclear technology .
The IAEA was set up by an international treaty in 1957 and there are 171 member states (see image right). The IAEA’s aims are:
- Promoting the peaceful uses of nuclear energy.
- Promoting high standards for nuclear safety and security
- Implementing safeguards to verify that nuclear energy is not used for military purposes
Its scope is broad and the IAEA advises on all aspects of radiological uses from fire alarms to nuclear waste.
It has put in place information-sharing systems and norms so that safety or security incidents at any nuclear site can be shared globally.
Of course this model has its challenges. In recent years Russia has been refusing to be as open as needed to the IAEA. That said, overall I have been impressed by the IAEA and could see a similar model working very well. Of course there may be other ways to achieve the same aims (and I may be biased towards suggesting institutions of the type I am most familiar with).
An institution to broadly identify, prevent and manage global risks
The world could also benefit significantly from an institution, perhaps a part of the UN, that looks to identify, prevent and prepare for global risks. I am still uncertain about what such an institution would look like, how it would work and the role of the UN, but I am very keen to see one created.
POSSIBLE ACTIONS – FOR US
- Writing up the details of an IAEA for biosciences.
POSSIBLE ACTIONS – FOR US OR OTHERS
- More research.
Annex A: How to help as an individual
- Personal. Am I safe and meeting my basic needs? Consider:
- Making a list of people to call / support and call them.
- Joining your local groups at: covidmutualaid.org
- Promoting social distancing and other useful behaviours amongst friends and contacts.
- Using your skills to contribute to the work and research needed to tackle the crisis. See: 80000hours.org/articles/covid-19-what-should-you-do/ (and maybe coronavirustechhandbook.com and www.reddit.com/r/CoronavirusArmy)
- Tracking any symptoms you have: covid.joinzoe.com
- Volunteer with the NHS at: Join the NHS Volunteer Responders
- Donating (probably not what is needed, but suggestions here [EA · GW] and here).
- Adding your voice to calls for useful policy change, this may be how we can help the most. … see the rest of this document.
And don’t forget that if you were already out doing good things to shape a better world, other problems have not gone away and may still be more important problems to work on, so keep doing what you were doing
Annex B: DFID response
Certainly communities in the developing world are currently terrified of the outbreak (anecdotal). The outbreaks may be less than expected because the virus may be less contagious in warmer environments and because there is a younger demographic, but equally worse healthcare resources may make outbreaks much more deadly.
On vaccine funding and ODA
Funding for CEPI (Coalition for Epidemic Preparedness Innovations) seems good.
Vaccine development should not be ODA although vaccine availability is definitely ODA.
DFID commitments to date
- £50m for handwashing campaign
- £250m for vaccine research
- £75m-150m for IMF’s Catastrophe Containment and Relief Trust
- £0.5m to tackle fake news
DFID plans going forward
To respond to the Coronavirus situation DFID will:
- Put in place a 2-year response plan (roughly a year to contain and a year to recover).
- Repurpose centrally managed programs. Many programs are likely to be carefully wound down so that resources can be repurposed to COVID.
- Move all British staff back to the UK
- Look into how supply chains can be managed.
Charities are also responding. For example Oxfam is investing in WASH and sanitation. DMI are looking at health education. A good summary of how effective charities are responding is at: [TLYCS] How Our Recommended Charities are Addressing the COVID-19 Pandemic.
Annex C: International cooperation
25 March: G7 meeting and statement. Covered:
- Helping support and fund the WHO, the UN, CEPI and Global Accord.
- Protecting global production and supply chains from disruption (including lowering tariffs on medical and pharmaceutical products).
- Ensuring that travel remains sufficient to allow citizens to return home.
- Protecting against disinformation.
Includes: Canada, France, Germany, Italy, Japan, UK, USA, and the EU.
Note: Although a positive step the main message in the media was that Trump wanted the virus to be called the Wuhan Virus and wanted to tackley misinformation from China. 
- Respond to the crisis: Share information, epidemiological and clinical data and materials necessary for research. Communicate responsibly to the public. Expand manufacturing capacity.
- For the future: “strengthen national, regional, and global capacities to respond to potential infectious disease outbreaks by substantially increasing our epidemic preparedness spending.”
- Safeguarding the Global Economy: “continue to conduct bold and large-scale fiscal support”
- Addressing International Trade Disruptions: “ensure the flow of vital medical supplies, critical agricultural products, and other goods and services across borders”
- Enhancing Global Cooperation: “capacity building and technical assistance to at-risk communities.” Strengthen health systems globally. support and fund the WHO's "Strategic Preparedness and Response Plan", the WHO's COVID-19 Solidarity Response Fund, CEPI, Gavi, Vaccine Alliance, etc.
27 March: Trump call. Covered:
- Trump hopes Boris gets well soon
- Focused on supporting British nationals abroad to return to the UK.
Additionally note that China and Germany have been providing support to Italy in responding to the virus.
Annex D: Scenario planning
Oxford scenario planning – a few set scenarios, think what we would need to do about each one and what plans need to be made now.
Run events with
- Our contacts (with CSER etc)
- APPG members
- Civil service (?)
Event description – internal
Duration: 1 hour 30 min - 2 hours
Scenarios method: Model a range of possible futures and develop a robust strategy on how to respond now.
Attendees: Up to 6 participants. Expertise in different areas and international spread (Vaccine/pandemic expert, China expert, US expert, etc.)
Aim: To look ahead according to two different timeframes — 6 months as well as 2+ years — at how the international community will be responding to the Coronavirus situation. To focus on how we can make the world more robust to existential risks.
Facilitator: Caroline Baylon. Caroline facilitates a course on scenario-planning at the University of Oxford’s Business School. She also runs a scenario-planning programme within a Fortune 500 company and co-facilitates the APPG for Future Generations. She was previously the lead on cyber security at Chatham House.
Event description – Parliament
Coronavirus scenario planning exercise
20 April, 4pm–5pm
Private: Parliamentarians (and staff) only
We will be running a workshop for Parliamentarians to map out the possibilities for how the Coronavirus situation will have evolved and will have affected the UK 2 years from now.
The session will be led by an expert facilitator: Caroline Baylon. Caroline facilitates a course on scenario-planning at the University of Oxford’s Business School. She also established a scenario-planning programme within AXA and co-leads AXA’s biannual cyber security foresight publication.
To RSVP please reply to this email (to firstname.lastname@example.org)
To attend: you can join the meeting online at: [insert link]
Annex E: review of the risk register
21 members of the Lords have signed up to support a Special Inquiry Committee on risk assessment and risk planning. Details below:
Proposal for a special inquiry (ad hoc) committee in 2020-2021
Title: Special Inquiry Committee on risk assessment and risk planning
Description of the proposal (in 100-500 words):
The most recent National Risk Register suggested that “emerging infectious diseases” could lead to “several thousand people experiencing symptoms, potentially leading to up to 100 fatalities”. This is both a gross underestimation of the current Coronavirus situation and out of line with the available evidence (for example, this survey of risks experts suggests there is consensus that a pandemic could conceivably cause 1 billion+ deaths).
It is a wise maxim that ‘the unfamiliar is not the same as the improbable’. It is a false economy not to explore potentially catastrophic scenarios, not to take action to minimise their probability and to not be prepared for future catastrophic risks. When crises hit the costs can be in the hundreds of billions, but investment in early planning and preparedness can significantly mitigate these risks and costs.
The UK Government maps and models risks through the National Risk Assessment (NRA) and the National Security Risk Assessment (NSRA)*, and individual departments take responsibility for mitigation of and preparation for the identified risks.
We know there are challenges with this process. The Parliamentary Office of Science and Technology’s Evaluating UK natural hazards identifies a host of problems including:
· Ensuring separation between science and politics
· Assigning risk owners
· Dealing with unknown risks or uncertain situations
· Preparing for multiple hazards co-occurring
· Acting to prevent future risks and manage long-term trends
High Consequence low probability threats – events so extreme that one occurrence is too many – need to be more discussed. This issue of risk management is one of the utmost importance and urgency and, unless our risk management process is improved, we will be under-prepared to handle future disasters.
The committee would consider:
1. The risk identification process. Is the existing process (the NSRA and NRA) fit for purpose to identify risks facing the UK? How is it affected by political pressures and does this pose a problem? Is it led by scientific consensus? Is there sufficient peer review and quality assurance?
2. Coronavirus. What may have gone wrong? Should the risk identification process have placed greater emphasis on emerging pandemics?
3. Risk ownership. How are government departments, local authorities and others brought on board and assigned risk ownership? Do they have the incentives and resources in place to ensure they take sufficient action to prepare for, prevent and mitigate the consequences of risks?
4. Future and emerging and unknown risks. How can we ensure that future risks beyond the current political cycle are considered and appropriate action taken on these risks?
5. International engagement. Is the UK learning from and providing support to other countries? What role can the UK play to ensure the global community is working together to prevent global risks?
There is an urgent need for this review.
This is an issue which needs both technical scientific and political expertise and as such a House of Lords committee would be the ideal place to conduct such a review.
*The NSRA and NRA may have been combined in 2019. Public information is not available.
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