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We have proposed a program for determining the reference for the quasi-local energy defined in the covariant Hamiltonian formalism. Our program has been tested by applying it to the spherically symmetric spacetimes. With respect to different observers we found that the quasi-local energy can be positive, zero, or even negative. The observer measuring the maximum energy was identified; the associated energy is positive for both the Schwarzschild and the Friedmann-Lema^{i}tre-Robertson-Walker spacetimes.

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