Assistant Secretary for Fair Housing and Equal Opportunity
By CHESTER HARTMAN
Roberta Achtenberg, former Assistant Secretary for Fair Housing and Equal Opportunity, came to Washington from San Francisco, where she had been an elected member of the city's Board of Supervisors (city council). Prior to her election, Achtenberg worked for 15 years as a civil rights attorney, was a teaching fellow at Stanford Law School, Executive Director of the National Center for Lesbian Rights, and Dean of the New College of California School of Law.
Roberta Achtenberg: I have been on the job 16 months, and we have made great strides. We have completely reorganized. Under the Secretary's leadership, we have been able to increase the numbers of people assigned to my division, triple their training dollars, win funding for new fair housing initiatives, and put the entire field operation under my control, which had never been the case before.
CH: Where had it been?
RA: The fair housing enforcement operation essentially was under the control of the regional administrators. They didn't really work for the Assistant Secretary for Fair Housing: he didn't hire them, he didn't rate them, and they were only indirectly accountable to him. After 15 months of hard work, we were able to turn that around. Now they operate directly under my control.
Inside the Department, the Secretary has elevated the notion that fair housing is an integral part of everything we do. And that has played itself out, not only in terms of more authority for the Assistant Secretary greater staff, greater budget. It has also played itself out in terms of the level of deference to the fair housing mission that other parts of HUD give to it. I wouldn't say it has been as easy to put into place as one might have hoped, but we have been making steady progress in that regard.
The program Assistant Secretaries in fact, the entire political staff and much of the career staff have actually been in favor of that. People retained the notion that in addition to producing affordable housing we had to distribute HUD's resources fairly.
One of the things that we saw early on was having the Department accept responsibility for policies and practices that it had allowed to go on in the past: either HUD had participated inadvertently in allowing segregated practices to be put into place or had, in some cases, known they were being put into place and did very little to stop that from happening. That took place over a period of many years, decades in fact. So we set about trying to settle the meritorious pending housing discrimination cases in which HUD was a defendant.
Obviously, the integration efforts in Vidor and other parts of East Texas have been viewed as a symbol of the kind of action this Administration is willing to take, and I would term that as another success.
The enforcement side of fair housing that I have responsibility for required restructuring from the ground up. We had many, many employees who had worked at HUD a long time, and who were committed to the civil rights mission, but who have never been put into proper restructured work groups, never been sufficiently trained, never had participated in articulating what the fair housing mission should be and what their role should be in it. The ability to transform that bureaucracy into a better enforcement operation has been something of major significance we have been able to accomplish in a relatively short time. The Title VIII enforcement process takes up a large part of the fair housing resources that are available. It is a very important individual guarantee that each person have access to housing without discrimination.
CH: What about on the negative side: things you thought you might be able to accomplish by this time that you feel frustrated about?
RA: I have to admit that I didn't know how long all of this would take. It seemed in the beginning that we should be able to accomplish major changes in 3 1/2 years, then the basics would be in place, and my successor would be in a position to take off from there, which is exceedingly important to rebuilding an institution, beyond publishing regulations. I would say that the pace of change has been disappointing, and although we've tried to motivate people to work as quickly as they can and to work harder than they have ever worked, it still takes a very, very long time. I don't think I have succeeded in trying to get people to focus on the essentials of the fair housing law and what is important and what is not.
The Department has had a tradition of focusing its investigative resources as much on isolated instances of discrimination by "mom and pop" housing providers, as it has on systematic cases of discrimination by a large brokerage firm or a multi-state management firm. And I haven't been able to reorganize that process, to make the kind of resource judgments I think we need to make. This is an era of diminishing resources and increasing claims on resources. I don't think discrimination is on the wane. In fact, I think the opposite probably is the case. We need to be much more strategic than we have been.
CH: As I understand it, the way the Title VIII complaint system works with HUD and the Justice Department is that if either party in the complaint chooses to have Justice involved in the investigation, resources have to be put there on a case-by-case basis rather than in the pattern and practice type of cases, which you would obviously prefer. Is that a resource allocation issue you can't do anything about because it's the law?
RA: If I make a reasonable cause determination, which means that a tremendous amount of HUD investigative resources have already gone into the process, the Justice Department has to take that case. They complain about that, and I completely understand that. That's the way the law is written. I won't suggest that we tamper with the law. Individual rights should have some meaning, and in the event there is a reasonable cause determination, then what should go along with that is the investment of government resources.
CH: But it does take away from your ability to get at the larger patterns.
RA: Yes, but the truth is that even within the constraint of individual claims, we should be expending more investigative resources and more HUD lawyer resources on the most egregious cases, the cases with the largest impact, the cases that really matter.
CH: So you're saying that even within the individual cases there could be better priorities. Why isn't that done?
RA: Well, we haven't gotten to that yet. Our investigators need a higher level of training. In the process of reorganization, we had five of our regional fair housing directors retire, so we are hiring five new directors, which, given the government personnel process, is a huge undertaking. There are only so many things you can do. Beginning in January, we are going to engage in what they call Business Process Re-Engineering; it's a fancy name for looking again at what you do and how you do it, and paring it down. That will take about six months. And this will focus on a priority-setting process for our investigations. I would have thought that almost two years into my tenure we would have been able to accomplish that.
CH: One of the criticisms I've heard is that your office doesn't have enough housing specialists to deal effectively with CPD, PDR, Housing, etc. Is that something you feel is lacking?
RA: I suppose that's true to some extent, but we're trying to deal with that issue. One way is to impress on everyone the fact that just because you come from Housing does not absolve you of the civil rights responsibility that all these programs carry. So in addition to our people needing to be expert with regard to the conduct of their program, they also need to develop some civil rights expertise that will enable them to unearth the civil rights problems they face.
The people who work in my field offices, where almost all of the program operations review takes place, are actually quite knowledgeable about the operation of all of HUD's programs. They're not as expert in housing as the housing specialist is, but they are trained about how all of HUD's programs operate so that they can oversee implementation of the civil rights requirements. I don't believe our people lack expertise. They certainly have lacked the authority to make their judgments stick, and as a result, the Secretary has given them new authority. They now have delegated civil rights authority. What will go with that is not only advanced training in how the various HUD programs operate, but also training in how you exercise authority and power for people who have not had it to exercise before. When "no" has never meant "no," that puts you into a certain kind of mindset.
With this new power, a lot of mistakes probably will be made. It may very well be that my people will end up saying no when ultimately they could have worked out a way to get to yes. But we are willing to take that chance, because it is very, very important that the civil rights requirements for all the programs be taken seriously. One way you take them seriously is by saying to all of the housing directors I talked to all of Nic's (Nicolas Retsinas, Assistant Secretary for Housing) 148 housing directors last week "This is your responsibility, too." When HUD does wrong, when the civil rights requirements are not carried out by the assisted housing program or through the community development block grant program or by public housing authorities, it's your responsibility as well as mine to recognize that the people we serve have been deprived thereby of free and fair housing choice, which they are entitled to.
CH: Do old-line HUD staff react well to that?
RA: It's a different environment now. The Secretary cares about that. The Assistant Secretaries care about that. And as I say, there are many, many career staff at HUD, at the highest levels and at the lowest levels, and many in between as well, who care about this stuff. But there has not been the culture at HUD, for a very long time, to encourage and support folks in standing up for these things.
CH: Historic racial discrimination in public housing and other HUD programs is widespread and obvious. HUD's recent settlement in the Allegheny County litigation was greeted quite positively by the advocacy community. And quite extraordinarily, HUD recently hired as Deputy General Counsel Elizabeth Julian, one of the attorneys suing HUD in an East Texas public housing discrimination suit, which signals an effort to deal with these problems all over the country. Is the Sanders settlement a model for such suits, and is the money available to do this?
RA: The Sanders settlement has many elements that I believe will provide the backbone for settlement of the meritorious racial discrimination suits.
CH: How many of them are there, roughly?
CH: All over the country?
RA: Yes. Much of the Sanders settlement is predicated on the assumption that many of the public housing funding programs will be ongoing, and I'm not sure that is necessarily a given as we speak.
On the comprehensive housing mobility center, that kind of model will be integral to settlement of a lot of these cases. It's one thing to say we will provide desegregative housing opportunities to the victim class and to say we will do it in the form of X hundred Section 8, tenant-based certificates. But we know from experience that if we do not assist residents in locating appropriate Section 8 rentals of sufficient housing quality, and if we do not do the range of mobility counseling or fund it being done, then essentially we're compensating the victims of our past discrimination by giving them a Section 8 certificate that they are likely to use in another segregated, racially concentrated, impoverished area, because that is where most Section 8 subsidies are exercised.
So this sort of comprehensive care housing service center, which includes mobility counseling, and then enforcement if necessary, was key to the settlement in the Sanders case, and that would be typical if we made a comparable proposal in East Texas, Dallas and the whole host of other cases. I would expect it to be a centerpiece, the way in which we would offer to desegregate the housing opportunities to people whom HUD policies had helped to segregate.
CH: The controversy over the Moving to Opportunity program in Baltimore derailed the second-year funding for the entire program [see article, this issue]. What lessons can be learned from that experience, in terms of building public support for a deconcentration strategy? And do you think that backlash is going to arise elsewhere?
RA: There are lessons to be learned. Will that kind of resistance arise elsewhere? It has not to date. There are many other sites where MTO is operating just fine, thank you very much. And we have obviously been keeping a much closer eye on even a hint of the kind of political resistance that arose there. Both the private mobility counseling agencies we have retained as well as the HUD field offices and the offices that are located proximate to the demonstration sites are all much more on top of any issues that might arise, and let us know quickly if political intervention is needed.
CH: That's an early warning system once trouble is brewing, but can anything be done to prepare people better so that the trouble doesn't brew in the first place?
RA: We have been talking about this. I think a community organizing strategy could and should be encouraged and supported by HUD. There are good folks out there, a lot of folks in favor of this as an anti-poverty strategy, people who understand the value of mobility, not only to the families who are provided the opportunity to live in neighborhoods of their choosing, but to the communities where these folks choose to live. Under the MTO program, people get counseled, they are screened, they are assisted, they are counseled after placement. People who go through the program make good neighbors, in addition to the program being a personal economic benefit to themselves and to their children.
So it's a decent proposition all around. Obviously, more information about all of that needs to get out. My view is that the eruption of this issue in the Baltimore area centered as much around the fact that there was an upcoming election and some folks saw a way to make hay, as there was genuine resistance on the part of folks in Dundalk or Essex that people were coming from inner-city Baltimore to their neighborhoods. Because, in fact, people were not coming to their neighborhoods, but they were upset nonetheless.
CH: When you say, in fact they weren't coming to their neighborhoods, what do you mean?
RA: Because of the way the MTO program is structured. This is for people living in high concentrations of poverty who move to areas of very low concentrations of poverty, and neither of the two areas that believed they were affected were. They couldn't be receiving areas to begin with. But that didn't make the fear any less.
CH: If MTO is either dead or stalled, are there other strategies you might propose to achieve some of the same dispersion goals?
RA: We have a much more large-scale and systemic effort in mind. We want to make the Section 8 program itself a much more significant vehicle for promoting housing choice, which in many cases would promote mobility, but not necessarily. The point is that people should be able to choose the neighborhoods they live in, given the minimal subsidy that is represented by the Section 8 certificate. Section 8 certificates don't enable folks to live either in tony neighborhoods or to live particularly well by middle-class standards. But to the extent that the certificate does give you more housing options than you would otherwise have, we want people to be able to exercise those options.
CH: Does that involve regionalizing Section 8?
RA: Regionalizing it, and trying to make the counseling responsibility that public housing authorities currently have for distributing Section 8 certificates a much more serious and better funded part of their operation. And they can achieve that either through beefing up their own counseling operations, or, more likely, through partnering with nonprofits.
CH: It's more likely to be successful if they use nonprofits, but, given bureaucracies, aren't they more likely to use the money themselves?
RA: Not the way the program will be structured. It is our hope that we will have the ability in the coming year to fashion a program that will encourage public housing authorities to partner with nonprofit fair housing groups or other private sector, nonprofit players, who could offer a level of counseling of the Chicago (Gautreaux) type.
In fact, even if new sources of funding for such an effort were not available, Assistant Secretary for Public Housing Joe Shuldiner and his headquarters staff are very, very committed to re-working the Section 8 program within existing needs to put greater emphasis on those housing authorities that take this counseling responsibility seriously, so I'm optimistic in that regard.
Within existing legal and budgetary constraints, there is a lot we can do that HUD has not, up until now, done to promote housing choice.
CH: Let me switch to another issue: research. What kinds of social science research have been useful to you in addressing fair housing issues? What additional kinds of academic research would you like to see carried out that would support your work?
RA: Mike Stegman and the revitalized PD&R operation he is running up there have been an extraordinary asset to our fair housing operation. I'm not sure how PD&R typically operated in the past, but in the last 15 months, their operation has been just invaluable to us, in getting us consultants from the Urban Institute, for example, running all kinds of programs and analysis that help me figure out whether there might be more flexible ways of achieving some of our Title VI goals in the administration of public housing. They have been able to advise us on everything from how we should judge what constitutes a disparate impact to what extent residency preferences pose legal problems.
CH: Do you propose research projects to him? How has the research helped to get things done? Do you say, "Mike, I need this, this and this?"
RA: Yes. Typically, I work through Marge Turner, his Deputy, whose area is primarily fair housing. They not only can procure consultant services more easily than we can, but Marge can set the research parameters. I tell her, "Can you find out what is statistically significant about X, Y, or Z?" And she can find it out, or she can tell me that's not the right question to ask the right question to ask is such and such.
They have been incredibly helpful. I'll give you a current example. As we started on this property insurance effort, following President Clinton's Fair Housing Executive Order of January, in addition to the Secretary having to set up the President's Fair Housing Council, the Executive Order says the Assistant Secretary of HUD shall promulgate fair lending regulations and regulations governing the provision of casualty and property insurance. So we have been looking very seriously at that responsibility and trying to define what is an unlawful practice under the federal Fair Housing Act.
In doing this, I was assisted by Greg Squires (a University of Wisconsin-Milwaukee sociologist), whom we hired essentially to help us spearhead this effort, and he compiled all the literature on this issue and did summaries of it. We took the entire issue to the Secretary, who noted there has yet to be done a definitive study that would demonstrate insurance redlining practices, in the same way that the Boston Fed study demonstrated there was definitely a problem of fair lending that the industry needs to address. He said, "Why don't you go talk to Stegman and see what could be accomplished here." So we did. We put together a working group and really explored all of the possibilities and the timeframes under which we had to operate, and he has commissioned a research project in this area that I think will give us very valuable information on the nature and extent of the problem, and one that I think will be of great assistance to us as we try to develop an appropriate regulatory framework in this area, where none before us have trod.
CH: HUD has recommended revising and liberalizing occupancy standards, particularly the number of persons allowed per bedroom, since such standards tend to discriminate on the basis of national origin, cultural patterns and family status. Property owners have been lobbying against this, partly using wear-and-tear arguments, but more realistically they simply don't want to lose control over tenant selection. What does HUD plan to do on the occupancy standards issue?
RA: The General Counsel (Nelson Diaz) has said he will be reviewing the Keating memo (issued by HUD Secretary Jack Kemp's General Counsel Frank Keating March 20, 1991), which has been read to suggest that HUD would adhere to something approaching the 2-persons-per-bedroom standard. In fact, that was not what the Keating memo says, but it has been construed to mean that in many cases, which I think both the General Counsel and I agree is not the rule, should not be the rule. So the General Counsel has said he will be withdrawing the Keating memo, and we are now putting the fine points on the guidelines that would take its place in the interim as we go through the process of promulgating a rule. That should be done in a relatively short time. We intend to do this right.
CH: Will the rule be more sensitive to some of the relevant cultural differences?
RA: Yes. Both the General Counsel and I have committed ourselves to that. Obviously, the rule has to be clear and helpful, but it has to take into account the notion that occupancy standards are all culturally imposed. Clearly, the standards need to be more flexible and less biased against larger families and against people whose traditions are not necessarily those of the dominant culture.
CH: On lending discrimination, apparently there is some public inter-agency squabbling going on at least some of the bank regulators are none too happy over the agreement that Chevy Chase Savings Bank just signed. Do you see that kind of agreement as a model you want to push? And if so, will HUD and the Department of Justice prevail?
RA: It's not quite as black and white as you have just painted it. I'll say to you what I just said to the Wall Street Journal, which is that there is not complete agreement among all of us in terms of what the Chevy Chase case means, and that needs to be clarified, so we can determine to what extent it is a model and to what extent it applied to the particular situation that Chevy Chase found themselves in, or that the Justice Department found Chevy Chase in.
Through the Inter-agency Task Force on Fair Lending, which I think is quite a useful body...
CH: Do you serve on that?
RA: Yes. It was convened by the Secretary of HUD, the Attorney General, and the Comptroller of the Currency, and it includes the two enforcement agencies, HUD and Justice, the Comptroller, as well as all the other bank regulators, the Fed, the FDIC, the OTS. There are some 10 or 11 members. They meet regularly on a staff level, quarterly on an Assistant Secretary level, and no less than once a year on the Secretary level to ratify principles and articulate federal policy as it relates to interpretations of the Equal Credit Opportunity Act and the Fair Housing Act on which we can agree.
To the extent that the Chevy Chase agreement stands for the proposition that you cannot purposely, or even unintentionally, organize your area of operation in a way that effectively excludes populations that are protected under the Fair Housing Act, then I think it has some principles of general application that we need to examine very seriously as we go forward.
CH: The voluntary agreement recently signed with mortgage bankers parallels the Voluntary Affirmative Marketing plan signed a few years back with the National Association of Realtors. How many mortgage bankers have actually signed this?
RA: Three, so far. Right now, we are working with some very big mortgage lenders and many others.
CH: Is there a different agreement for each broker?
RA: Yes, so in that respect it is very different from the way we operated with the National Association of Realtors.
CH: A criticism of voluntary plans like this is that they are intended to forestall more rigorous and effective measures, like bringing mortgage bankers under the Community Reinvestment Act. What do you think the chances are that they could ever be brought under the CRA as an alternative to voluntary measures?
RA: A few months ago, I thought it was unlikely that they would be. Asking me today, I would say that it is probably even more remote. Under Title VIII, the Secretary has the authority, in fact is urged to engage in voluntary programs with members of the housing industry to further the purposes of the Fair Housing Act which is all that this is.
These are voluntary. If you don't live up to your agreement, you don't live up to your agreement. You hope they will lose in the court of public opinion, but there is no enforcement sanction there. This was not an effort to forestall regulation, and I don't believe that the mortgage bankers themselves viewed it that way. I do believe they thought of it as I think of it as a positive effort on their part both to acknowledge there is a problem and take some important steps to improve the fair lending performance of their members by encouraging them to sign individually tailored agreements with HUD.
We have some 400 expressions of interest, and we'll be pursuing them, but we have never portrayed this as anything other than what it is: an effort to use the authority the Secretary already has under law to encourage better fair lending performance.
CH: The brouhaha in Berkeley of all places regarding what was portrayed as your attempts to harass, punish, prosecute neighborhood residents opposing a group home caused what seemed like a quick retreat on your part and certainly created a major backlash in the press. What lessons did you learn from that?
RA: That is a complete mischaracterization of what happened. In the Berkeley case, a fair housing group filed a complaint with HUD that we had a legal obligation to investigate. The complaint alleged that a number of individual Berkeley residents had organized to oppose a group home for recovering drug addicts. To be fair to the Berkeley residents opposed to this, there is a large concentration of assisted housing in the neighborhood as well as homeless shelters.
The complaint was investigated over a 6- or 8-month period. The issue never came to our attention until the beginning of August of this year. And, as was consistent practice at the time, which practice we inherited from our predecessors in office, the Fair Housing Office in San Francisco investigated the case, as it investigates every other case. They asked for a whole host of information and did a number of things they do in general investigations that in this case were inappropriate, because this case really involved the protected expression of political opinion that could not have been construed to sustain a fair housing complaint against the residents. To the extent that the residents organized, testified at public hearings, wrote editorials, passed out leaflets and generally stirred things up as a way of opposing a decision by the planning or zoning commission to grant a use permit to the group home, they were engaged in protected political activity that could not have been construed as interference, intimidation or coercion under the Fair Housing Act.
However, they did one other thing, a complicating factor. In addition to all that protected talking and writing and leafletting, they also filed a lawsuit, which is conduct and not speech, and which poses a challenge under fair housing case law. If you file a frivolous lawsuit for purposes of depriving someone of their fair housing rights a lawsuit adjudged to have been without legal or factual support then it is possible that filing a lawsuit could be construed as interference within the meaning of the Fair Housing Act. It happens that the whole thing including the filing of the lawsuit and the lawsuit having been dismissed occurred before the case ever came to our attention. We got a call from the Oakland Tribune asking what's happening in this Berkeley case, which we didn't know anything about. So we pulled the Berkeley case in to find out what they were talking about, and in reviewing the case I also had to look at the lawsuit that was filed, to judge whether or not it was a violation of fair housing law. I ultimately decided it was not.
Subsequent to that case, we polled the field to determine what other cases out there posed this same kind of First Amendment problem or potential problem. It turned out there were a number of such cases. That is not the way those cases should have been investigated, from a policy point of view, and it is not the way the cases will be investigated in the future. We have issued guidelines, through notice, that tell our investigators at what point those kinds of complaints should be allowed to be logged into the process, or essentially dismissed before they are filed because they clearly present only protected conduct that can't be construed to be a violation of the Fair Housing Act.
CH: But it clearly came off as a black eye for HUD.
RA: There was such a high level of irresponsible conduct on the part of the media with respect to this issue. Look, I care as much about the First Amendment, probably more than, the next guy and consider myself a constitutional lawyer. And in three weeks, once having learned of these issues, I put a binding policy in place that we believe protects against this happening again. I don't disagree with you that this was played up in the press as if somehow HUD was on some kind of mission to intimidate people who oppose group homes being placed in their neighborhood. But that's not what happened.
CH: I assume what also was going on was your perception that the Right was going to try to use this incident to weaken the Fair Housing Act and HUD's enforcement powers. I think you were quite prescient in seeing it that way. And what has happened since November 8 makes your resolution of the matter even smarter.
RA: There are a number of problems that have been brewing. These are civil rights laws after all, and there are those of us who believe that there is a unique and important role the federal government has to play when it comes to civil rights. Nonetheless, there is a growing popularity toward the notion that local control is very, very important. And I would agree that in many respects delivery of a whole host of services that have been federalized does have to be looked at again.
We have found that the most effective actors in delivering housing services and producing high-quality, low-income housing is not HUD at all, but occurs when HUD funds the right CDC or gives the money to the state, which then teams with good private sector actors. And so I have a lot of sympathy for many elements of the deregulation movement and the notion that there should be greater local control and less federal control over a lot of things, and I'm willing to engage in that debate and to try to look anew at the delivery of many of the services that have been federalized over the last 20, 30, 40 years.
But when local protest rises to the level of interference, intimidation, harassment of people who have a federally guaranteed right to free and fair housing choice, I do have a problem with that. I do believe there is an important role for federal law enforcement in that regard. And it's not something that should be up to a vote. I will resist very strongly efforts to weaken the civil rights laws.
CH: What will your strategy be for dealing in the new conservative Congress? How will this dramatic shift in the political climate change the Clinton Administration's fair housing and anti-redlining agenda? What will it do to the unpassed Housing and Community Development Act, to the HUD budget and to issues like insurance redlining and plans to make HMDA data more accessible?
RA: Housing policy, it seems to me, and civil rights policy has been very much a bipartisan effort over the last many years. The Banking Committee in the Senate, somewhat less in the House, has conducted itself in a way that has meant that the HUD bills, and even the passage of the 1988 amendments to the Fair Housing Act, have been pretty much a bipartisan enterprise. It's my hope that that tradition holds in this next Congress. Recognize that there are some who think that HUD shouldn't be in the business that it's in, that it's too big a bureaucracy, that it should be dismantled. I've heard all the scare stories. I don't know how high HUD is on their agenda. And so I'm hopeful that HUD will fare decently in the new Congress. Whether that means that we'll get every program we had hoped to get through the old Congress, or whether that means we will have to downsize and reorganize our programs as well as our personnel structure I guess it probably means that, at a minimum.
As far as the fair housing law is concerned, I feel optimistic that its value will be appreciated. I intend to personally explain to any member of Congress who cares to listen the history of the Fair Housing Act, including the amendments, why it's important, the strides we have taken to improve the quality of Fair Housing Act enforcement, and stress the importance of keeping the intentions of the law intact. And it is my hope that that, plus the vocal support of the people all over the nation who care about fairness and equality, will prevail. I don't think the voters have really said, even by virtue of this vote that was lopsided by party, that we don't want fairness, we don't want civil rights, we don't want federal housing policy that helps people become first-time homeowners or gives people who have been disadvantaged a little bit of a better start so that they can find a way to improve their lives and the lives of their families.
So I'm not as pessimistic as some, although I am realistic.
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