part a project environmental assessment · second edition, may 2004 a-3 road project environmental...

Second Edition, May 2004 A-1

Road Project Environmental Processes Manual

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PART AProject Environmental

Assessment

A-2 Second Edition, May 2004


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AA.1 Purpose

The purpose is two-fold.

1. To confirm the assessment processunder which a project will be assessed(ie. internal process, with or without oneor more of the external assessmentprocesses).

2. To determine the actual and potentialenvironmental impacts (both positive andnegative) of the project/activity.

A.2 Responsibility

It is the responsibility of the project manageror their delegate to ensure that ProjectEnvironmental Assessment is undertaken.The project manager is responsible forensuring that the relevant environmentalconsiderations have been identified andincorporated into the environmentalassessment. The project manager may seekadvice from an Environmental Officer oranother suitably qualified person.

The assessment includes the following tasks.

• Determining the level of assessmentnecessary.

• Deciding who can undertake theassessment (either internal staff and/orexternal consultants) and carry out theassessment.

• Reviewing the triggers for externalassessment processes to determinewhich process is to be followed.

• Reviewing additional environmentalapprovals/permits/licences requirements.

• Delivering a report that collates theabove information.

A.3 Timing

Project Environmental Assessment is to becarried out during the preparation of theOptions Analysis phase. The collection ofinformation about the existing environmentand identification of potential impacts enablesthe environmental costs and benefits to becompared between different design solutions.

A.4 Content

Task 1 - Determine the level ofassessment

There are several benefits in determining theappropriate level of assessment.

• Cost savings - being able to target theassessment of each environmentalelement in line with the level of risk andother projects on the program reducesunnecessary assessment costs andachieves value-for-money.

• Avoiding project delays - by identifying allrelevant environmental constraints andapproval process should streamlineproject delivery.

• Improving Main Roads environmentalperformance - technically suitedenvironmental assessments willcontribute value to the design andconstruction of a project. This will alsocontinually improve the environmentalperformance of Main Roads and theperception of Main Roads' environmental

PART AProject Environmental

Assessment


performance in the community.

• Achieving government outcomes -undertaking the appropriate level ofassessment helps to establish the actualand potential environmental impacts andtherefore works towards achieving thegovernment's outcomes (refer to Prefacefor explanation of governmentoutcomes).

There are fourteen environmental elementsthat should be addressed as a minimum foreach Main Roads road project.

• Water quality

• Hydrology/hydraulics

• Fauna

• Flora

• Soils/topography/geomorphology

• Noise

• Air quality

• Land use and planning

• Landscape and visual amenity

• Cultural heritage

• Social and economic issues

• Climate (seasonal constraints)

• Waste management

• Legislative requirements

Each of the above elements may beassessed in varying levels of detail. Severalfactors will determine the level of assessmentfor each element. While the scale of worksmay provide some indication of the level ofassessment necessary, the principledeterminants should be the potential to causeenvironmental harm. This includesconsideration of the proximity to significantenvironmental areas, and sensitivities amongthe community.

Three levels of assessment (high, medium orlow) have been developed for ten of thefourteen environmental elements (seeAppendix C). The level of assessment forclimate, waste management and legislativerequirements are common to allassessments, while assessments related tocultural heritage and public consultation arediscussed elsewhere (refer to the MainRoads Cultural Heritage Manual 1998 andMain Roads Public Consultation Policy andGuidelines).

A series of questions to help identify theappropriate level of assessment for eachenvironmental element is provided inAppendix C. In addition, an example terms ofreference for each of the key issues/ activitiesand the minimum outputs associated witheach level of assessment is also provided inAppendix C. Appendix C may be used byEnvironmental Officers when undertaking aninternal assessment or used to develop a'brief' or 'terms of reference' if employingexternal consultants to undertake theassessment.

The information required to determine theappropriate level of assessment should havebeen collected during the Corridor Planningphase (Phase 3 of the strategic framework forroad system asset management).Alternatively, a short scoping study may berequired to better identify the level ofassessment appropriate for the project.

Once the appropriate level of assessmenthas been determined, the next task is toestablish who can undertake theassessment.

Task 2 - Decide who canundertake the assessment

Several factors will influence who canundertake the assessment.

• The availability and expertise of theEnvironmental Officer.

• The budget available.


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• The level of assessment as identifiedabove.

• Community expectation.

• Scale of the project.

• Environmental significance/risk associatedwith the project.

The project manager should discuss thesefactors with the Environmental Officer orappropriately qualified person to determinewhether the assessment will be undertakenin-house or by a consultant (or a combinationof both).

Task 3 - Review assessmentprocess triggers

At the time of publication (2004) there arefour external environmental assessmentprocesses of relevance to Main Roadsprojects. A fifth process associated with anEnvironmental Impact Statement under theEnvironmental Protection Act 1994, is nottriggered directly, rather it is used on avoluntary basis.

The four external assessment processes arenot mutually exclusive. Therefore, any oneMain Roads project may need to beassessed using one or more of theseprocesses. The level of information to becollected under each process differs, andmay add up to six to twelve months to theassessment timing. Therefore it is beneficialto determine the process to be followed earlyin the Concept Phase.

The four external assessment processes areas follows.

1. The Commonwealth process asadministered under the EnvironmentProtection and Biodiversity ConservationAct 1999.

2. The state process administered by theDepartment of State Development underSection 26 of the State Development andPublic Works Organisation Act 1971.

3. The state assessment process under theIntegrated Planning Act 1997.

4. The Commonwealth processadministered by the Federal Departmentof Transport and Regional Servicesunder the Australian Land TransportDevelopment Act 1988.

A brief description of each of the four externalassessment processes is provided below(refer to the Main Roads EnvironmentalLegislation Register for more details).

Assessment Process 1 -Environment Protection andBiodiversity Conservation Act 1999

Background to the Act

The Commonwealth Environment Protectionand Biodiversity Conservation Act 1999(EP&BC Act) commenced on the 16th July2000.

Before the EP&BC Act, Commonwealthinvolvement in Main Roads projects was onlyrequired for those projects that receivedfederal funding (i.e. blackspots, NationalHighways). The Commonwealth is now ableto be involved in any activity that is likely tohave a significant impact on the environmentof Commonwealth land, and/or on a matter ofnational environmental significance. As such,Commonwealth involvement may be requiredon any Main Roads project, not simply thosewith federal funding.

The Commonwealth may, through bilateralagreements, delegate to the States theprocess under which the environmentalassessment is conducted. However, abilateral agreement with Queensland had notbeen reached at the time of publication of thismanual (2004). Therefore, until such anagreement has been reached, Main Roadsprojects that trigger the EP&BC Act are tofollow the Commonwealth assessmentprocess.



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How is the Act triggered?

The EP&BC Act is triggered if an action iscarried out which has, will have, or is likely tohave a significant impact on the environmentof Commonwealth land, and/or on a matter ofNational Environmental Significance (NESmatters). Commonwealth land includesfederally owned airports and defence lands.Matters of National EnvironmentalSignificance are as follows.

• World Heritage properties.

• Ramsar wetlands.

• Nationally threatened species andecological communities.

• Migratory species.

• National Heritage List.

• Commonwealth marine areas.

• Nuclear actions (including uraniummining).

• Heritage.

Appendix D provides a checklist of thetriggers to be addressed when determiningwhether a Main Roads activity requiresassessment under the EP&BC Act. Thechecklist considers each of the issuesrelevant to the determination ofCommonwealth involvement. The checklisthas been developed to help address allrelevant questions and to allow a record ofthe assessment to be placed on theappropriate project file.

To further aid the completion of the checklist,a description of each trigger in the checklistand the appropriate information sourcesrelevant to Main Roads to help address thetrigger is provided. In addition, theadministrative guidelines developed byCommonwealth Department of Environmentand Heritage to help determine the level ofsignificance associated with triggering NESmatters may be accessed athttp://www.ea.gov.au/.

By completing the checklist and placing it onthe appropriate project file, Main Roadsdemonstrates due diligence in respect of theCommonwealth Act and retains a record ofthe assessment in the event that a third partyreferral is submitted. A third party referral maybe submitted by any individual or communitygroup directly to the CommonwealthDepartment of Environment and Heritage inrelation to a Main Roads project. Should thisoccur, Main Roads would be contacted by theCommonwealth Department of Environmentand Heritage and asked to demonstratecompliance with the Act.

Implications of triggering the Act

If the Act is triggered, a referral to theCommonwealth Environment Minister isrequired. The referral is to be submitted onthe twelve-page referral form developed byCommonwealth Department of Environmentand Heritage. A current version of the formand associated guidelines can be accessedat http://www.ea.gov.au/.

The purpose of the referral is to provide theCommonwealth Environment Minister withsufficient information so that he/she, followingadvice from Commonwealth Department ofEnvironment and Heritage, may determinewhether or not the activity requiresassessment under the EP&BC Act. If theCommonwealth Environment Ministerdecides that the action is a controlled action,then the Commonwealth assessmentprocess applies.

It is vital that a representative from MainRoads establishes contact withCommonwealth Department of Environmentand Heritage as early as possible in theprocess. This will ensure that Main Roads isfully informed about the requirements andconcerns of the Commonwealth Departmentof Environment and Heritage, and minimisethe likelihood of delays in the referralprocess.

Figure A-1 outlines the key steps and timingassociated with the Commonwealth


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assessment process. This figure shows thattriggering the EP&BC Act will add from 5 to 6months to the Main Roads projectassessment depending on the level ofassessment required. This period is only the'controlled time', allocated for reviews andapprovals by the Commonwealth. A further 6to 12 months may be required forconsultation and report preparationundertaken by Main Roads.

Assessment Process 2 - The StateDevelopment and Public WorksOrganisation Act 1971


Main Roads has environmentalresponsibilities pursuant to the StateDevelopment and Public Works OrganisationAct 1971 (SDPWO Act). The legislation isdesigned to ensure that environmental issuesare adequately addressed throughout theplanning and delivery of infrastructureprojects. The SDPWO Act requires appraisalof environmental issues when consideringthe undertaking of works or when consideringan application for approval of a projectdeemed to be of State significance.


There are two sections of the revised Act(Section 25 and 26) relevant to identifying theassessment process to be followed.

• Section 25 (previously Section 29A)establishes that all activities requireconsideration of environmental impacts.Compliance with this section can beachieved by following the internal MainRoads assessment process.

• Section 26 (previously 29B) of the Act istriggered if Main Roads’ project isdeclared to be of State significance. TheCoordinator-General, by his/her ownmotion or at the direction of the Minister,may declare a road project a 'significantproject'. Alternatively, Main Roads mayseek a Main Roads project to be deemed

a significant project. Should either occur,the assessment process under theSDPWO Act is to be followed. AppendixE provides a checklist to establishwhether an external assessment processis triggered under the SDPWO Act.


As Main Roads has developed an internalassessment process that addressesenvironmental impacts of their activities,triggering Section 25 of the revised Act hasno implications.

If Section 26 of the Act is triggered, theassessment process under the SDPWO Actis to be followed. This process is described inDivision 3, Part 4 of the SDPWO Act. The keyrequirements are as follows.

• The Coordinator-General must advisethe proponent (Main Roads) that anEnvironmental Impact Statement (EIS) isrequired.

• The Coordinator-General must publiclynotify:

- that an EIS is required

- where copies of the draft terms ofreference may be obtained

- that comments on the draft terms ofreference are invited

• The Coordinator-General must haveregard to the comments received whenfinalising the terms of reference for theEIS.

• The proponent must prepare an EIS tothe satisfaction of the Coordinator-General.

• After the proponent has prepared an EIS,the proponent must publicly notify thefollowing.

• Where a copy of the EIS is available forinspection

• Where a copy of the EIS may be obtainedat a stated reasonable cost (the cost



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Figure A-1 Outline of the EPBC assessment and approvals processSource: EA. October 1999. An Overview of the EPBC Act

must not be more than the actual cost ofproducing the copy)

• That submissions may be made to theCoordinator-General about the EIS

• The period set by the Coordinator-General during which a submission maybe made

• The Coordinator-General must consider,after the end of the submission period,the EIS, submissions about the EIS andany other material the Coordinator-General considers relevant to the project.

• The Coordinator-General may ask theproponent for additional information orcomment about the EIS.

• The Coordinator-General must prepare areport evaluating the EIS. In thisevaluation, the Coordinator-Generalmay:

- evaluate the environmental effects ofthe project and any other relatedmatters

- state conditions for the project

- make recommendations for theproject

• After completing the report, theCoordinator-General must give a copy ofit to the proponent and issue a publicnotice about the completion of the report.

No indication of timing for the assessment orapproval process is provided within theSDPWO Act. However, a timeframe from twoto six months is likely to establish the terms ofreference, evaluate the EIS and develop therequired report. Six to twelve months ofadditional time may also be required for MainRoads to prepare the EIS, await publicsubmissions and prepare responses to thesesubmissions (if required by the Coordinator-General).

Assessment Process 3 - TheIntegrated Planning Act 1994

This section of the manual discusses theIntegrated Planning Act 1999 (IPA) in relationto the environmental assessment process forMain Roads. It is not written to reflect thelegal context and terminology of IPA. Rather,to help determine whether the assessmentprocess under IPA is triggered.


Within Queensland the planning systemoperates under the IPA. The Act integrates alldevelopment decision-making processes andaims to achieve ecological sustainabilitythrough the coordination, integration andstreamlining of a number of land use planningprocesses.

The Act focuses on land use planningoutcomes, the management of developmentprocesses and the management of impactson the environment by development. UnderIPA, local government planning schemes andState planning policies guide the manner inwhich development is undertaken.


IPA may be triggered by the road or certainactivities (eg quarries, site offices, etc.)associated with roads project. This isdependant on the tenure of the land whichthe activity occurs on, the content of the localgovernment planning scheme and the activitytriggers licencing under specific legislation(eg quarry, overland flow). Depending onthese factors, the road/activity may requireexternal assessment and approval (stateagency and local government or internalassessment and approval. Furthermore, anexternal assessment process is only requiredif the project id designated as communityinfrastructure.

Figure A-2 outlines the steps in determiningwhether and when designation would beconsidered and how a Main Roads projectmay trigger IPA. Appendix F provides achecklist to determine if a Main Roads project



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Figure A-2 Summary of IPA triggers applicable to Main Roads

triggers an external assessment process andthe implications of triggering an approvalprocess under IPA. The checklist in AppendixF should be completed for all Main Roadsprojects, and placed on the relevant projectfile.

As per Figure A-2, there are three questionsthat need to be answered in relation to IPA.

1. Is the Main Roads project ‘assessabledevelopment’ or ‘self-assessabledevelopment’?

2. If ‘assessable development’, is it 'impactassessable' or 'code assessable'?

3. Should Main Roads designate the projectas community infrastructure?

Questions 1 and 2 - determining thetype of assessment

The ‘IPA Planning Scheme Manual’ and the'IDAS Manual for Main Roads as anApplicant' should be referenced to helpanswer these questions. A summary of thekey points from Schedule 8 of the IPA andissues relevant to a Planning Scheme to helpdetermine the level of assessment is alsoprovided below. However, as changes mayoccur to Schedule 8 and Planning Schemes,it is recommended that the two sourcedocuments (ie Schedule 8 of the IntegratedPlanning Act 1997 and the Planning Schemeof the local government in which the worksare to be undertaken) be reviewed at the timeof addressing these questions.

Under Schedule 8, Part 3 of IPA

• Reconfiguring a lot is 'assessabledevelopment' unless it is done as anecessary result of building/delivering aroad.

• Undertaking any EnvironmentallyRelevant Activity (ERA) listed under theEnvironment Protection Act 1994 triggers‘assessable development’.

• Clearing of native vegetation is'assessable development' if the clearingoccurs on freehold land and:

- Clearing is occurring in an urban areaand in an area of high natureconservation or clearing a remnantendangered regional ecosystem asshown on a Queensland Herbariumregional ecosystem map.

- Clearing is occurring in a non-urbanarea unless it is reconfiguration notfor opening a road or the total area ofthe land on which the development iscarried out is less than 5 hectares.

• Ancillary Works and Encroachments ifundertaken in accordance with a gazettenotice under Section 47 of the TransportInfrastructure Act 1994 are deemed to be'exempt development'.

Under a Planning Scheme

• Any activities identified as being ‘exemptdevelopment’ under Schedule 8 of IPAcannot be made ‘assessable or self-assessable development’ under aPlanning Scheme.

• Local government through its PlanningScheme may control road developmentand/or road activities. Triggers for‘assessable development’ under aPlanning Scheme may not only relatespecifically to a road but also associatedissues such as tree clearing, disturbingacid sulfate soils and protecting watercatchments. Therefore, the PlanningScheme should be reviewed for all issuesrelated to the Main Roads project and notsimply a review for the word ‘road’.

• The road development and associatedactivities may be identified in thePlanning Scheme as ‘self-assessable’,‘code assessable’, ‘impact assessable’ or‘exempt’.



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Question 3 - should Main Roadsdesignate?

As a general guide, Main Roads would onlyconsider designation if the project triggers'impact assessable' development. Even then,designation may not occur. If designated, theproject is exempt under a Planning Scheme,however triggers under Schedule 8 still apply.

The key issues in relation to designation areas follows.

• Designation must still considerenvironmental protection.

• If designated, an external assessmentprocess is required. The designationprocess is described in the IPA.

• If considering designation, it is essentialthat Road System and Engineering groupbe consulted.

Implications of designation

If the external assessment process istriggered (ie. the project will be designated),the implications are as follows.

• An EIS as per the process under theIntegrated Planning Act 1997,Environmental Protection Act 1994 or theState Development and Public WorksOrganisation Act 1971 is to beundertaken. This is to include a minimumpublic consultation period of 20 businessdays.

• Main Roads (acting on behalf of theMinister) is to provide written notice of anintention to designate to each affectedlocal government and/or the localgovernment nearest to the land proposedfor designation.

• Main Roads (acting on behalf of theMinister) must publish a notice at leastonce in a newspaper circulating generallyin the area of each local governmentgiving notice (see Schedule 6 of IPA forinformation to be included in the notice).

• A sign notifying the public of the intentionto designate is to be erected on theproject site.

If the Act is triggered the internal assessmentprocess may be followed, however theimplications are as follows.

• If ‘self-assessable’ - Main Roads canfollow their internal assessment processand no application or approval to localgovernment is required. However, therelevant external standards (eg standardbuilding regulations) are to beaddressed.

• If ‘code assessable’ - Main Roads isrequired to lodge an application and gaindevelopment approval. However, theinformation required may be obtainedthrough the internal Main Roadsassessment process. In this instance, theinformation provided within theapplication would be assessed by anexternal agency (ie. State or LocalGovernment) against the applicablecodes.

• If ‘impact assessable’ - Main Roads willbe required to lodge an application underthe IPA and requirements additional tothose of the internal Main Roads processwill be required (refer Chapter 3 Part 4 ofIPA for these requirements).

• If ‘exempt’ - no application under IPA isrequired.

Assessment Process 4 - TheAustralian Land TransportDevelopment Act 1988


This Act was developed to establish areserve for the purpose of the constructionand maintenance of land transport systemsand related purposes. The Act commencedon 1 January 1989.


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The Act is triggered on any Main Roadsproject that receives Federal Department ofTransport funding. Such funding is providedfor construction or maintenance workscarried out on a National Highway. TheMinister may declare a National Highway if:

• the road is a principal link between two ormore State capital cities and/or betweenBrisbane and Cairns (as per Section 4 ofthe Act)

• the road constitutes a road that should, inthe opinion of the Minister, be treated, byreason of its national importance, as anational highway


Federally funded projects are also subject tothe Environment Protection and BiodiversityConservation Act 1999.

It is necessary to first establish whether theproject triggers this Act. Section A.4discusses how to establish whether a projecttriggers the Environment Protection andBiodiversity Conservation Act 1999. If theAustralian Land Transport Development Act1988 and the Environment Protection andBiodiversity Conservation Act 1999 aretriggered, the following tasks are to becompleted.

• Provide a briefing note or the actualenvironmental assessment documentationto the Federal Department of Transport onthe environmental issues of the project(including indigenous and non-indigenousheritage) 10 days prior to undertakingreferral to the Commonwealth Departmentof Environment and Heritage.

• Provide the referral to theCommonwealth Department ofEnvironment and Heritage and provide acopy of all referral documents to theFederal Department of Transport.

If the Environment Protection & BiodiversityConservation Act 1999 is not triggered, theenvironmental assessment report(s)undertaken for the Main Roads project andthe environmental certification are to beprovided to the Federal Department ofTransport. The environmental certification isto be as follows (as per Appendix 4 of theAustralian Land Transport Development Act1988 Notes on Administration).

Following consultation with the ‘EnvironmentProtection Agency’ or ‘in accordance withprocedures agreed between the Departmentof Main Roads and the EnvironmentProtection Agency’, the environmentalimplications of the proposal have beenassessed and are set out in the ‘ProjectProposal Report’ or ‘attacheddocumentation’. In my opinion, the proposal‘is’ or ‘is not’ a matter which raises ‘anyenvironmental issues under Commonwealthor State legislation’ or ‘any environmentalissues have been addressed to thesatisfaction of the relevant environmentalauthorities, whether Commonwealth orState’.

Internal Assessment Process

The internal assessment process is to befollowed for all projects. However, it mayhave been completed by an externalassessment process.

If the internal assessment process isfollowed, it achieves the objectives of Section25 of the State Development and PublicWorks Organisation Act 1971. The internalassessment process is described in Parts A,B and C of this manual.

Task 4 - Review additionalenvironmental approvals/permits/licences

The project manager in charge of theproposed project is responsible for ensuringthat all necessary project approvals, permits/licences have been identified and obtained



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where possible. Some permits/licences maynot be obtained prior to letting the contract. Inthis case, it is the project manager'sresponsibility to ensure the contractdocumentation identifies thosepermits/licences to be obtained by thecontractor.

There are two issues associated with thetiming of internal approvals and externalpermits/licences.

1. Identifying the required approvals/permits/licences

2. Obtaining the approvals/permits/licences.

Identifying the required approvals/permits/licences

There are numerous environmentalapprovals/licences/permits that may berequired for any Main Roads project. TheMain Roads Environmental LegislationRegister should be referenced to establish allpossible approvals/permits/licences. Themost common required on Main Roads roadprojects include the following.

• Environmental certification of all projectsby the District Director (for Federalproject certification see Section A.3; forall other projects see Section C.5)

• Obtaining a development approval underthe Integrated Planning Act 1997

• Authority required for an EnvironmentallyRelevant Activity

• Permit/licence required for works within awatercourse

• Permit/licence required for works withintidal waters (coastal districts)

• Permit/licence required for removal ofmarine plants (coastal districts)

The number and type of approvals/permits/licences required for a project willneed to be considered as early as possible inthe Concept Phase and reviewed throughout

the life of the project.

Obtaining approvals/permits/licences

The timing of external permits/licences willvary depending on the extent and location ofworks and the amount of relevant informationthat can be supplied to the approvingauthority (see the latest permit applicationforms for required information). An indicationof the timing associated with the mostcommon external permits/licences is shownin Table A.1.

All necessary approvals/permits/licencesshould be identified prior to letting aconstruction contract.

Task 5 - Preparation of a report

The information collected throughout theProject Environmental Assessment processestablishes the condition of the existingenvironment in the area of the proposed MainRoads road project and the potentialenvironmental opportunities and constraintsassociated with the proposed works so thatthey may be investigated further, later in theprocess.

Reports are needed for each of theenvironmental assessment, managementand certification processes. A separate reportmay or may not be prepared for each of thesestages. If separate reports were prepared,these would best correlate with the following.

• Project Environmental Assessment stage- Review of Environmental Factors (REF)

• Project Environmental Managementstage - Environmental Management Plan(Planning) (EMP Planning)

• Project Environmental Certification stage- Environmental Certification andEnvironmental Design Report (EDR).

Alternatively, a single report may be preparedto combine all of the above information. Forthe purpose of this manual, this report is


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termed an Environmental Approval Report(EAR). This single report includes theenvironmental certification and forms thebasis of the information to be included in theconstruction and maintenance contractdocumentation. Appendix G describes thesuggested content of an EAR.

Irrespective of the number of reportsproduced during the Concept andDevelopment phases, the main objective is toassess the environmental implications of theMain Roads project and ensure that cost-effective and practical mitigation measuresare included within the contractdocumentation.



ATable A.1 Indication of time to obtain permits/licences

Activity Associated Act Timing

Development approval under the Integrated Planning Act 1997 12-22 weeksIntegrated Planning Act 1997

Environmentally Relevant Activity Environmental Protection Act 1994 4-8 weeks

Works within a watercourse Water Act 2000 8-16 weeks*

Works within tidal waters Harbours Act 1955 6-8 weeks

Removal of marine plants Fisheries Act 1994 8-16 weeks

Removal of scheduled plants Nature Conservation Act 1992 2-4 weeks

* longer period required if Native Title notification by the Department of Natural Resources and Mines isneeded



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