RDU Airport Authority 2040 Plan — Avoided Environmental Review
SECTION 1 INTRODUCTION
- 1. PROJECT OVERVIEW
Runway (RW) 5L/23R at Raleigh-Durham International Airport (RDU or Authority) is presently experiencing rapid deterioration due to an alkali silica reactivity (ASR) condition. The projected useful life of the RW 5L/23R is approximately four years, thus elevating the urgency for repair or replacement of the runway. To address the RW 5L/23R reconstruction issue with minimal impact to existing airport operations, and to accommodate a new Aircraft Design Group (ADG) as described in the Vision 2040 Master Plan, the Raleigh Durham Airport Authority (Authority) is proposing to relocate RW 5L/23R approximately 540-feet northwest of its existing location, and convert the existing runway to a full-length taxiway, hereinafter referred to as the Proposed Project. The existing runway would remain in operation during construction of the relocated runway. The purpose of this report is to present preliminary results of environmental resource/context mapping and regulatory agency coordination which has been accomplished to support the Authority in coordination with the Federal Aviation Administration (FAA) relating to NEPA documentation requirements for the Proposed Project. - 1.2. PROJECT PURPOSE AND NEED
As noted above, RW 5L/23R is experiencing rapid deterioration and reconstruction or replacement of the runway is required to enable RDU to meet existing and future operational needs. Reconstructing RW 5L/23R in place would require closure of the runway for a period of one to two years. Closure of the runway would have a significant negative impact on airfield capacity. Shifting operations to RW 5R/23L, which has a length of 7,500-feet, would further impact airport operations through payload limitations on long-range domestic and international flights. Development of temporary extension(s) to RW 5R-23L to meet the requirements of long-range domestic and international flights could be considered; however, permanent extension would likely receive public opposition. In contrast, the Proposed Project would provide for continued operations on existing RW 5L/23R throughout the construction period, would enable RDU to accommodate the mix of aircraft presently using the airport, and would maintain the airfield capacity needed to satisfy the existing and forecast level of aircraft operations and change in design aircraft. Based on the above, the purpose and need for the Proposed Project can be summarized as follows:
Need:
- Existing RW 5L/23R pavement is at end of useful life and requires replacement;
- Runway must be of adequate length to support long-range domestic and international flights
- RW 5L/23R modifications are needed to conform with guidance in FAA’s
Advisory Circular 150/5300–13A, Change 1, Airport Design for ADG V aircraft; and - Limited opportunity to reconstruct/replace pavement in-place while preserving airfield capacity and operational capabilities.
Purpose:
- Preserve airfield capacity by maintaining useable runway length and airfield capabilities to meet existing and future demand;
- Avoid capacity constraints during runway reconstruction;
- Avoid airline operational penalties during pavement reconstruction/replacement;
and, - Accommodate a new design aircraft (i.e., ADG V).
3. ALTERNATIVES EVALUATION
Development of the Proposed Project would require FAA unconditional approval of the RDU Airport Layout Plan. FAA’s unconditional (or conditional) ALP approval would constitute a Federal action subject to the requirements of NEPA. The CEQ regulations implementing NEPA
stipulate that alternatives are “the heart of the environmental document ( 40 CFR 1502.14 ).” Those regulations require that the Federal decision-maker perform the following tasks:
- “Rigorously explore and objectively evaluate all reasonable alternatives and, for alternatives which were eliminated from detailed study, briefly discuss the reasons for their elimination.”
- “Devote substantial treatment to each alternative considered in detail, including the proposed action, so that reviewers may evaluate their comparative merits.”
- “Include reasonable alternatives not within the jurisdiction of the lead agency.”
- “Include the alternative of no action.”
In conformance with CEQ regulations and FAA Orders 5050.48 and 1050.1 F, this Section summarizes the screening process used to identify, compare, and evaluate a range of alternatives to the Proposed Project and presents the following: a description of reasonable alternatives to the Proposed Project, including the No-Action Alternative; an overview of the structure of the alternatives screening process and analysis; a concise statement explaining
why some alternatives were eliminated from further evaluation; and identification of reasonable alternatives retained for further evaluation in a subsequent NEPA Environmental Assessment.
The alternatives evaluated are briefly discussed in Section 1.3.2, below.
3.2 ALTERNATIVES EVALUATED
In addition to the Proposed Project the following alternatives were identified and evaluated:
- Alternative 1: Temporarily shift operations to RW 5R/23L and reconstruct existing RW 5L/23R. During reconstruction the runway would be closed and all operations would be shifted to the shorter RW 5R/23L which is 7,500-feet in
length. - Alternative 2: Temporarily extend RW 5R/23L to a length of 9,000 feet, shift operations from RW 5L/23R and reconstruct in place (Figure 1.3–1 );
- Alternative 3: Maintain existing runways and construct a new 9,000-foot air carrier runway to the south of existing RW 5R/23L. Close RW 5L/23R upon completion of new runway (Figure 1.3–2);
- Alternative 4 (Proposed Project): Relocate RW 5L/23R to the northwest and convert existing runway into a full-length parallel taxiway (Figure 1.3–3).
- 3.3 EVALUATION CRITERIA
Three principal levels of evaluation were conducted on the Alternative concepts presented in Section 1.3.2. The Level 1 evaluation identified the extent to which an Alternative meets the designated Purpose and Need; the Level 2 evaluation addressed potential environmental impacts associated with the Alternatives; and the Level 3 evaluation assessed the operational impacts and constructability of each Alternative. Ev(31uation criteria for each of these levels is described as follows
Level 1 Evaluation Criteria — Purpose and Need
Consistent with the Purpose and Need for the project, Alternatives were evaluated for their ability to meet the following criteria:
- The alternative must provide adequate runway length to support long-range domestic and international flights.
- Avoid airline operational penalties during runway reconstruction.
- Develop airfield improvements to conform to AC 150/5300–13A, Change 1, for ADG V aircraft.
Level 2 Evaluation Criteria — Environmental Impacts
The Level 2 evaluation focused on the potential environmental impacts associated with the Proposed Project and potential Alternatives. Impacts evaluated include those associated with land acquisition and relocation requirements, aircraft noise, and key environmental resources protected by special-purpose laws. Specifics of each evaluation criteria are outlined below.
- Land Acquisition and Relocations- Alternatives that would require no or minimal land acquisition, and no or minimal relocation of residences and businesses were considered to be reasonable.
- Wetlands and Other Sensitive Water Resources- Only alternatives that would not result in substantial impacts to high quality wetlands or other sensitive water resources were considered to be reasonable.
- Critical Habitat- Only alternatives that would not directly affect critical habitat, or designated habitat management areas, associated with threatened or endangered species, were considered to be reasonable.
- Floodplains- Only alternatives that would result in no significant floodplain impacts were considered to be reasonable.
- Historic Resources — Only alternatives that would not directly affect
archaeological, historic and cultural resources listed or eligible for listing in the National Register of Historic Places (NRHP) were considered to be more reasonable than alternatives with greater impacts. - U.S. Department of Transportation (DOT) Act Section 4(f) Resources- Only alternatives that would not directly affect public parks, recreation areas, wildlife and waterfowl refuges of national, state, or local significance or land of an historic site of national, state, or local significance were considered to be reasonable.
Level 3 Evaluation Criteria — Operations and Constructability
The Level 3 analysis evaluated alternatives in light of FAA airport design criteria, potential airfield operational impacts, and probable development cost. Alternatives that had substantial constructability concerns and/or potential operational impacts were eliminated from further
study.
- Only alternatives that would result in no significant complexities in terms of staging, phasing, and construction activities were considered reasonable.
- Ability of the site to accommodate the proposed project with minimal impact on existing airfield infrastructure, airfield operations, and ground handling of aircraft. This also includes whether or not the site would cause substantial impacts or conflicts in regard to regional airspace.
1.3.4 ALTERNATIVES SCREENING
Results of the alternatives screening process are discussed below. Refer to Table 1.3–2 at the end of this section for a summary of the screening results.
1.3.4.1 ALTERNATIVE 1 : TEMPORARILY SHIFT OPERATIONS TO RW 5R/23L AND RECONSTRUCT
EXISTING RW 5L/23R
Purpose and Need: Closing RW 5L/23R during reconstruction and requiring RDU to operate with the shorter RW 5R/23L would have a significant impact on RDU operations including payload restrictions on long-haul domestic and international flights, airfield congestion, and operational delays.
During the construction period, usable runway length for the aircraft fleet using RDU would be limited to 7,500 feet, which does not meet the Take-off Distance Available (TODA) and Landing Distance Available (LOA) criteria for many commercial aircraft servicing RDU. Furthermore, the airport is currently at approximately 60 percent of its Annual Service Volume (ASV) capacity with both existing runways in operation. In the event that operations would be shifted to a single runway during construction of Alternative 1, there is potential for the airport to experience capacity constraints and increased operational delays.
- This alternative would not meet with purpose and need for the Proposed Project.
Environmental Impact Overview: There are no direct impacts to physical resources such as wetlands, streams and floodplains associated with this Alternative. However, shifting all operations to RW 5R/23L will result in increased noise impacts to residential areas located northeast and southwest of RDU. Noise impacts may be incurred on William B. Umstead State
Park, which may constitute a “constructive use” of this DOT Section 4(f) resource.
Operational impacts: Alternative 1 would reconstruct RW 5L/23R in place. During reconstruction there would be a significant loss in airfield capacity, increased airfield congestion and cause operational delays. This alternative would also commit the runway to this location and severally limit any potential future expansion of Terminal 2. RW 5L/23R is designed to meet ADG IV standards and cannot meet ADG V. A change in critical aircraft to ADG V is necessary based on the analysis and recommendations documented in the Vision 2040 Master plan.
1.3.4.2 ALTERNATIVE 2: TEMPORARILY EXTEND RW 5R/23L TO A LENGTH OF 9,000 FEET,
SHIFT OPERATIONS FROM RW 5L/23R, AND RECONSTRUCT IN PLACE
Purpose and Need: Extension of RW 5R/23L to a length of 9,000' would enable RDU to meet runway length requirements for many of the critical aircraft operating at RDU. However, larger aircraft would continue to experience payload restrictions on long-haul domestic and international flights.
Providing a 9,000-foot runway with Alternative 2 would alleviate some runway length constraints incurred under Alternative 1, however, TODNLDA requirements for larger aircraft may exceed the 9,000 feet available. Although this situation exists today, the approach and departure Runway Protection Zones (RPZ) on the extended Runway 5R end may create a greater
encroachment over the existing a public highway, which may present an incompatible land use and in contravention to airport design standards published at Advisory Circular 150/5300–13A, Airport Design.
To mitigate this potential incompatibility, the Authority could request a Modification of Standard (MOS) from the FAA to allow the RPZ to encroach upon the highway, or, as depicted on Figure 1.3–1, apply a displaced threshold to Runway 5R and accept declared distances such that the
total LOA would be constrained to 7,640 feet. Further, due to the shifted departure RPZ, declared distances would also be applied to departures on 23L, constraining usable TODA to 8,440 feet.
Based on the discussion above, this alternative would not meet the purpose and need for the Proposed Project.
Environmental Impact Overview: There are no direct impacts to physical resources such as wetlands, streams and floodplains associated with this Alternative. The extension of RW 5R/23L would bring the Runway 23L approach end into closer proximity to William B. Umstead State Park, which may constitute a “constructive use” on this DOT Section 4(f) resource. Feedback received from the public during the Vision 2040 Master Planning process revealed that any proposed extensions to RW 5R/23L would likely face public opposition due to perceived increased noise impacts on the Section 4(f) resource.
Operational Impacts: As stated for Alternative 1, operating RDU with a single commercial runway during the in-place reconstruction of RW 5L/23R would result in a loss of airfield capacity, increase airfield congestion and cause operational delays. Reconstruction in place would also commit the runway to this location and severally limit any potential future expansion
of Terminal 2. RW 5L/23R is designed to meet ADG IV standards and cannot meet ADG V. A change in critical aircraft to ADG V is necessary based on the analysis and recommendations defined in the Vision 2040 Master Plan. Because this Alternative would result in only a temporary runway extension which would be abandoned in place or removed following reconstruction of RW 5L/23R, modification of taxiways or other airfield geometry to accommodate ADG V aircraft in accordance with FAA Advisory Circular 150/5300–13A, Change 1, Airport Design would not be accomplished under this Alternative.
1.3.4.3 ALTERNATIVE 3: MAINTAIN EXISTING RUNWAYS, CONSTRUCT A NEW 9,000 AIR CARRIER RUNWAY TO THE SOUTH OF RW 5R/23L, CLOSE RW 5L/23R UPON COMPLETION OF NEW RUNWAY
Purpose and Need: Relocation of the runway would allow the existing RW 5L/23R to remain open during construction which would avoid delays and/or congestion which would occur if RDU were to operate with one air carrier runway. However, Alternative 3 would not meet the purpose and need for the Proposed Project. Although this Alternative provides a 9,000 foot runway to reduce operational impacts on usable runway length, this Alternative carries with it the need for a MOS for the Runway 5R end RPZs, else the airport would need to accept declared distances on LDA and TODA as described for
Alternative 2 above.
Environmental Impact Overview: There are no direct impacts to physical resources such as wetlands, streams and floodplains associated with this Alternative. The proposed Runway 23L blast pad under this Alternative may slightly intervene with an area stream, which would need to be mitigated. The proximity of this stream to the runway may also present wildlife hazard considerations which would require mitigation.
Operational Impacts: Because RW 5L/23R would remain operational during construction of the new runway, operational impacts would be reduced, although there is potential for an intermittent single-runway condition to occur during construction. Construction of a new air carrier runway south of RW 5R/23L would enable future expansion of Terminal 2 and other support facilities in the future as needed. Importantly, design and environmental permitting requirements may present a timeline for this Alternative that is incompatible with the remaining useful life of Runway 5L/23R; pavement
failure on the exiting 5L/23R may occur prior to completion of the new Runway construction. Due to potential delays in design and permitting requirements associated with development of Alternative 3, this Alternative does not meet the operations and constructability evaluation
criteria established for the Proposed Project.
- 3.4.4 ALTERNATIVE 4: RELOCATE RW 5L/23R NORTH AND CONVERT EXISTING RUNWAY INTO A FULL-lENGTH PARALLEL TAXIWAY
Purpose and Need: This is the only Alternative that would meet the purpose and need for the Proposed Project. Relocation of the runway would allow the existing RW 5L/23R to remain open during construction of the relocated runway, and accommodate the construction of an ADG V runway. This alternative would also preserve current airfield capacity and eliminate the
delays and/or congestion which would occur if RDU were to operate with one air carrier runway and would maintain operational capabilities of the existing airfield. The existing RW 5L/23R would be closed following completion of the relocated runway, and a new parallel Taxiway “8” constructed. - Environmental Impact Overview: As documented in Section 2.4, no direct impacts to wetlands or floodplains are anticipated with development of the Proposed Project. However, candidate borrow areas for the Project (see Figure 2.2–1) contain stream, wetland, and floodplain resources as identified in Table 1.3–1. Although further study is required, use of these areas for earthworks purposes may require mitigation. Relocation of the runway at the new location may cause indirect impacts to water quality and aquatic resources due to sedimentation from earth moving activities.
Otherwise, substantive offsite impacts relating to noise, land use, and other environmental resources listed in FAA Order 1050.1 F are not anticipated.
Operational Impacts: Because RW 5L/23R would remain operational during construction of the new runway, operational impacts would not occur. Construction of a new air carrier runway northwest of RW 5L/23R would allow the airfield to comply with ADG V standards, and enable
future expansion of Terminal 2 and other support facilities in the future as needed. Potential operational capacity constraints and delays described for the other Alternatives considered would be eliminated with the Proposed Project because construction phasing would likely not require single-runway operations and usable runway length would be available to accommodate
the needs of the entire commercial fleet currently servicing RDU.
SECTION 2 ENVIRONMENTAL REVIEW
2.1. NATIONAL ENVIRONMENTAL POLICY ACT OF 1969 (NEPA)
NEPA establishes a broad national policy to protect and enhance the human environment. NEPA and its implementing regulations require that Federal agencies such as the Federal Aviation Administration (FAA) demonstrate compliance with its provisions prior to approving, funding or otherwise supporting actions with a potential deleterious effect upon the human
environment. With respect to airport improvement projects such as the replacement of Runway 5LI23R, the FAA must demonstrate that the project(s) have underwent the appropriate NEPA review and secured environmental approval before the project(s) can be implemented.
2.1.1. CATEGORIES OF NEPA ANALYSIS
FAA implements NEPA using FAA Order 1050.1 F, Environmental Impacts, Policies and Procedures. The Order guides FAA officials on demonstrating compliance of FAA actions with NEPA, as well as determining the required scope of environmental review and associated documentation (i.e., an Environmental Impact Statement [EIS], an Environmental Assessment
[EA], or a Categorical Exclusion [CATEX]). Order 1050.1F is supplemented as necessary with Order 5050.4, NEPA Implementing Instructions for Airport Actions.
2.1.2. ENVIRONMENTAL REVIEW, APPROVAL AND PERMITTING REQUIREMENTS
Order 1050.1 F calls for the analysis of seventeen (17) environmental resource categories within NEPA documents, identified below:
- Air Quality
- Biological Resources (including fish, wildlife and plants)
Jr. - Climate
- Coastal Resources
- Department of Transportation (DOT) Section 4(f) Resources
- Farmlands
- Floodplains
- Hazardous Materials, Pollution Prevention and Solid Waste
- Historical, Architectural, Archaeological and Cultural Resources
- Land Use
- Light Emissions and Visual Effects
- Natural Resources and Energy Supply
- Noise and Noise Compatible Land Use
- Socioeconomics, Environmental Justice, Children’s Health and Safety Risks
- Surface Water/Groundwater Resources
- Wetlands
- Wild and Scenic Rivers
FAA has established significance criteria and other factors that inform the scope and level of a NEPA analysis for each of these categories, which are discussed as applicable throughout the environmental review presented in Section 2 of this report.
2.2. STUDY AREAS
The 885 acre study area established for the purposes of environmental review bounds the limits of disturbance of Proposed Project and is shown on Figure 2.2–1. Specific limits of disturbance for each of the Proposed Project elements are summarized on Table 2.2–1. The direct Proposed Project disturbance areas constitute 107.9 acres of the overall 885 acre project area.
Additional disturbance activities may occur with the Proposed Project due to the transport, excavation and stockpiling of fill material, provision of staging areas, and creation of hauling routes. Importantly, cross-sectional comparisons of the proposed shifted Runway 5L/23R centerline with the existing RW 5L/23R centerline (Figures 2.2–2a and 2.2.2b) reveal a change
in elevation of between 20 and 50 feet, requiring earthworks to bring the newly-installed airfield pavement up to appropriate elevation and grade. Consequently, potential on-airport borrow sites that would meet the fill requirements of the Proposed Project are being considered. These areas
constitute a maximum of 822 acres of construction-related disturbance area for the Proposed Project and are therefore also accounted in the environmental review. However, not all of this aggregate 822 acre area would be used for Proposed Project fill requirements, and portions of
this area that are used for fill excavation would avoid or mitigate natural resource loss. Furthermore, Borrow Area #3 referenced on Figure 2.2–1 was used to stockpile materials for previous projects and some of that material remains.
RESOURCES NOT IMPACTED/STUDIED
Based on the nature of the Proposed Project and in consideration of regulatory requirements established in Section 2.1.2 of this report, the following environmental resource areas are discounted from further review in this report:
- Climate
- Coastal Resources
- Farmlands
- Natural Resources and Energy Supply
- Light Emissions and Visual EffectsWild and Scenic Rivers
2.4. ENVRIONMENTAL REVIEW SUMMARY
Table 2.4–1 provides a summary of the environmental impact screening performed for the Proposed Project. Figure 2.4–1 presents a map of physical environmental resources within and surrounding the study areas of the Proposed Project. Results of the environmental screening indicate that development of the Proposed Project may have limited impacts on wetlands, and surface waters during the construction period. These impacts would not exceed significance thresholds established by FAA as published in FAA Order 1050.1 F.
SECTION 3 STRATEGY RECOMMENDATIONS
This section presents a summary of the preliminary coordination with regulatory agencies, the purpose of which was to obtain insight as what would be the primary concern of each agency should the Proposed Project advance to a NEPA study. An evaluation of environmental factors
and impact significance threshold are presented with regards to a recommend level of NEPA documentation. Precedent from similar FAA actions and NEPA decisions are also presented.
3.1. PRELIMINARY AGENCY COORDINATION
Several state and federal agencies were contacted as part of a preliminary coordination effort, with the purpose of briefing the agencies on the Proposed Project and on the results of the preliminary environmental analysis. The following agencies were contacted: US Army Corps of Engineers (USAGE), US Fish and Wildlife Service (USFWS), US Environmental Protection Agency (EPA), NC Department of Environmental Quality — Division of Water Resources (NC DWR), NC Wildlife Resources Commission (NC WRC), NC State Historic Preservation Office (SHPO), and NC Department of Transportation (NCDOT). Each of these agencies was contacted with the purpose of setting up meetings or soliciting comments on the Proposed Project plans as they relate to agency interests. Comments were received from the EPA on February 2, 2017 and from the USFWS on February 17, 2017
(Attachment A). The EPA noted the presence of low income populations in the project vicinity and commented that public outreach should aim to be inclusive of these populations. The USFWS commented that the project would be unlikely to adversely affect federally-listed species, but expressed a concern of the effect of sedimentation on nearby aquatic species. A meeting was held with the NC WRC on February 22, 2017, and a joint meeting was held with
the USAGE and the NC DWR on February 23, 2017. The WRC generally expressed a desire that the airport continue to take measures to discourage wildlife encroachment on the airport property and airspace. The USAGE and the NC DWR commented that the project would not likely encounter any hurdles related to Section 404/401 permitting. However, they expressed a
desire to see the Lumley Road relocation route minimize impacts to surface waters to the extent practicable, and a stormwater plan created that incorporates best management practices into the project design. Minutes from these meetings can be found in Attachment A. Contact was made with the remaining agencies, the SHPO and the NCDOT, but these agencies
chose not to meet to discuss the Proposed Project and did have any comments.
This preliminary agency coordination was conducted in order to request informal feedback from each of the agencies regarding the Proposed Project and its potential impacts to agency resources, but is not intended to be a replacement for early agency coordination. Additional agency coordination will be conducted during future planning efforts.
3.2. LEVEL OF NEPA DOCUMENTATION
The Authority’s Proposed Project is to relocate the existing RW 5L/23R at RDU approximately
540 feet’ to the northwest of its existing location. Upon completion of the relocated runway, the
existing runway would be redeveloped into a full-length parallel taxiway. The relocated
RW 5L/23R would enable RDU to maintain the existing and forecast level of aircraft operations
and continue to accommodate the mix of aircraft requiring a 10,000' runway. In addition, the
area identified for the RW 5L/23R relocation has been previously impacted by construction
activities as shown in Figure 2.2–1.
FAA Order 1050.1 F, Section 3–1.3 states that FAA must prepare an EIS “for actions significantly
affecting the quality of the human environment.” The Order further states that “an EIS is a
detailed written statement required when one or more environmental impacts would be
significant and mitigation measures cannot reduce the impact(s) below significant levels”. As
listed in FAA Order 1050.1 F, Section 4–3.3, the FAA uses significance thresholds that serve as
specific indicators of significant impact for some environmental impact categories. The impact
categories are listed in Order 1050.1 F, Section 4–3.3 and are listed below:
Proposed actions that would result in impacts at or above these thresholds require the preparation of an EIS, unless impacts can be reduced below threshold levels. As discussed in Section 3.2.2 above, a preliminary environmental review of the proposed relocation of RW 5L/23R indicated that the project would not result in a significant impact to any of the environmental resource categories identified in Order 1050.1 F. Initial discussions with the USAGE, USFWS and the NC DWR as discussed in Section 3.1 support this assessment. Less than significant impacts could occur to several impact categories such as water resources and air quality during construction activities. However, these impacts could be minimized and/or
mitigated through implementation of best management practices and engineering controls. Based on the less than significant level of environmental impact anticipated to result from the Proposed Project both during the construction and operational phases, preparation of an EIS is not required, and an Environmental Assessment (EA) prepared in accordance with FAA Order 1050.1 F would be the appropriate form of documentation to meet FAA requirements under NEPA and the implementing regulations issued by the CEQ.
3.3 PROPOSED APPROACH TO MEET NEPA REQUIREMENTS
Based on results of the environmental screening accomplished for the Proposed Project as detailed above, the Authority proposes to prepare a NEPA EA to evaluate potential environmental impacts associated with relocation of Runway 5L/23L at RDU. Preparation of an EA rather than an EIS, would provide for full assessment and review of potential environmental resource impacts, and would allow RDU to accomplish the runway relocation before operations at RDU are impacted due to deteriorating pavement.
3.4 SCHEDULE
The anticipated schedule for preparing the EA, if approved by FAA, is presented on Table 3.4–1.
