State of Texas. Texas Senate Subcommittee on Flooding and Evacuations and House Select Committee on Hurricane Ike Devastation

Transcription

1 Testimony to the State of Texas Texas Senate Subcommittee on Flooding and Evacuations and House Select Committee on Hurricane Ike Devastation At the League City, Texas Civic Center December 3, 2008 Testimony Regarding FEMA Mitigation Assessment Team Observations Hurricane Ike, 2008 Testimonies of Larry J. Tanner, P.E. Tom Smith, A.I.A. Christopher P. Jones, P.E.

2 Texas Senate Subcommittee on Flooding and Evacuations, December 3, 2008 Testimony Regarding FEMA Mitigation Assessment Team Observations Hurricane Ike, 2008 Residential Structure Performance Testimony of Larry J. Tanner, P.E. Overview of Hurricane Ike, The Storm On August 13, 2008, this Texas Senate Committee convened to hear testimony on the State s preparedness for a major coastal windstorm. On September 13, 2008, in the early morning, Hurricane Ike roared on shore as a Category 2 hurricane with maximum sustained winds of 110 mph wreaking havoc from the west end of Galveston Island, Texas, to Terrebonne Parish in Louisiana.[1] Data collected by Automated Surface Observation System (ASOS) towers, Coastal Marine (C-MAN) stations, and portable towers deployed by universities was fed into FEMA s HAZUS-MH, a wind field modeling program. The results, shown in Figures 1& 2, indicate that the estimated maximum peak gust wind speeds, near the radius of maximum winds, ranged from 90+mph on the west end of Galveston Island to 110-mph on Bolivar Peninsula and 90-mph inland, including the City of Houston.[2] According to the National Weather Service, Hurricane Ike will likely be the third costliest natural disaster in the United States, behind Hurricanes Katrina and Andrew. Figure 1. Swath of maximum gust wind speeds in miles per hour at a height of 10 meters above ground (over land wind speeds are representative of open terrain conditions; over water wind speeds are representative of marine conditions). Wind Swath contour plot (3- second gust at 10 meter elevation) based on HAZUS-MH wind field methodology. [2] Testimony of Larry J. Tanner, P.E. Page 1 of 7

3 Figure 2. HAZUS estimated maximum peak gust wind speeds near radius of maximum winds. Anemometer locations used in model verification are indicated.[2] FEMA Mitigation Assessment Team (MAT) FEMA s Mitigation Division investigates building performance after major disasters using multidisciplinary teams of federal, state, local, private sector, and university experts. These teams are known as Mitigation Assessment Teams (MATs). The Ike MAT, like most MATs, was charged with four tasks: 1) to evaluate how residential and commercial buildings -- that were designed and constructed using modern building codes -- perform under a design-level event, 2) to evaluate the structural and non-structural performance of critical facilities, 3) to evaluate the performance of previous mitigation projects, and to help identify future mitigation opportunities, and 4) to make recommendations on how building codes, standards and design guidance can be improved and how their implementation and enforcement can be assured. On September 18, five days after Ike, a small group of FEMA MAT investigators began preliminary ground and aerial surveys of flood, erosion, and wind damage in coastal Texas. The full MAT was deployed from October 15-22, and studied damage from Brazoria County, Texas, to Terrebonne Parish, Louisiana, including the Galveston Bay area. Testimony of Larry J. Tanner, P.E. Page 2 of 7

4 This testimony will outline some of the observations made by the Hurricane Ike MAT. Findings and recommendations are being developed now, and will be included in the MAT report, to be published in spring The report will summarize building strengths and weaknesses, mechanisms of failure, and the effectiveness of previous hazard mitigation projects. The report will identify Lessons Learned and promote Best Practices for redevelopment and future development. FEMA strives to create safer communities and believes that constructing stronger and safer buildings is a key to that objective. Implementing MAT recommendations will lead to improved design and construction practices; reduced damage to buildings; preserved homes, businesses, jobs, tax base and community function; and accelerated post-storm recovery. MAT Observations of Residential Performance to Ike s Winds The maximum wind speeds of Hurricane Ike, 110-mph on Bolivar Peninsula, were less than the design standards of the American Society of Civil Engineers (ASCE) 7, Minimum Design Loads for Buildings and Other Structure [3] and the Texas Department of Insurance (TDI) adopted wind speeds for the Texas Designated Catastrophe Areas, shown in Figure 3.[4] Figure 3. TDI Designated Catastrophe Areas Testimony of Larry J. Tanner, P.E. Page 3 of 7

5 However, given the less than design wind speeds, significant failures were observed by the MAT relating to residential envelopes and coverings. These observations include the following: No complete structural building failures attributable to wind were seen by the MAT. However, numerous failures to structural elements were seen related to nailed, rather bolted connections and connector failure related to corrosion by the coastal environment. Very little sheathing damage was observed. However, the damage observed was associated to large unsupported overhangs and poor construction practices, see Figure 4. Roofing damage to older homes appeared to be a function of the age of the roof, whereas roofing damage to newer homes was a function of poor installation and failure to follow guidelines for installations in high wind zones. An extensive amount of envelope wall coverings was damaged by Hurricane Ike. The majority of this damage was relegated to vinyl siding and fiber cement siding. In most cases, the failures were related to the installation of products not rated for the high wind zones and installers not utilizing industry recommendations for high wind zone installations, see Figure 5. Vinyl soffits and roof ridge ventilation systems frequently failed, thereby allowing water infiltration into the homes causing damage. Vinyl soffit failure appeared to be an installation issue, whereas the ridge ventilation system failure appeared to be a function of the system design. Few impact resistant glazed window units were observed by the MAT, with homeowners and builders opting for using shutters to provide debris impact protection. By all accounts from the investigation, it appeared that most homes were protected by some form of shutter. The shutter type varied from simple plywood to expensive roll-down shutters. As previously testified in August, 2008, hurricane resistant construction codes, standards and guidelines currently exist which should insure reasonable structural performance to the limits of the design wind speeds. Even though Hurricane Ike was not a design wind event, extensive envelope damage was observed. This poor envelope performance can only be attributed to the selected building materials, the methods used for the installations, and the inspection of the installations by contractors and building officials. Testimony of Larry J. Tanner, P.E. Page 4 of 7

6 Figure 4. Roof damage to Bolivar Peninsula homes. Figure 5. Typical vinyl siding damage. Testimony of Larry J. Tanner, P.E. Page 5 of 7

7 References 1. NWS (2008) Hurricane Ike Wind Analysis for Southeast Texas. 2. Vickery, P.J., Estimates of Maximum Wind Speed Produced by Hurricane Ike in Texas and Louisiana ASCE, ASCE/SEI 7-05 Minimum Design Loads for Buildings and Other Structures. 2005: American Society of Civil Engineers. 4. TDI. General Information Windstorm [cited; Available from: Testimony of Larry J. Tanner, P.E. Page 6 of 7

8 Curriculum Vitae Larry J. Tanner Registered Professional Engineer/ State of Texas Registered Architect / States of Texas, Oklahoma, and Pennsylvania Graduate of Texas Tech University, 1971, Architectural Engineering Larry Tanner spent 20 years in the private sector in the practice of architecture and structural engineering. His public sector work includes nine years as the Director of Facility Planning and Construction at Texas Tech managing campus design and construction. Currently, Larry Tanner is an adjunct professor and a research associate in the Wind Science and Engineering Research Center (WISE) and manager of the WISE Debris Impact Test Facility. His fields of research include storm protection utilizing above ground in-residence shelters and building performance during extreme storms. His storm investigations and documentation include the following: Spencer, South Dakota Tornado in 1998 Oklahoma and Kansas 1998 Tornadoes (member of FEMA MAT Team) Tuscaloosa, Alabama 2000 Tornado Happy, Texas 2002 Tornado Ohio 2002 Tornadoes Southwest Missouri and Oklahoma City Tornadoes - May, 2003 Hurricane Ivan, Pensacola, Florida - September, 2004 Hurricane Katrina, 2005 (member of FEMA MAT Team) Evansville, Indiana 2005 Tornado Central Florida Tornadoes, 2007 The Super Tuesday Outbreak - Tennessee Tornadoes, 2008 Hurricane Ike, 2008 (member of FEMA MAT Team) His reports and written contributions to storm research include documentation of the listed storms and collaboration with FEMA in the writing of FEMA 320, Taking Shelter from the Storm;, FEMA 361, Design and Construction Guidance for Community Shelters; FEMA 342, Building Performance Assessment Report of Midwest Tornadoes of May 3, 199; authorship of the Evansville Tornado Report, A Focus on the Eastbrook Mobile Home Park; co-authorship of FEMA Publication 549, Hurricane Katrina in the Gulf Coast, Observations, Recommendations, and Technical Guidance; the Central Florida Tornadoes Damage Documentation of 2007 Using the Enhanced Fujita Scale; and co-authorship of the 2008 revisions of FEMA 320 and 361. Larry.tanner@ttu.edu Testimony of Larry J. Tanner, P.E. Page 7 of 7

9 FEMA Mitigation Assessment Team Observations Hurricane Ike, 2008 Critical Facilities & Houston CBD Testimony of Tom Smith, A.I.A. Performance of Critical Facilities During Hurricane Ike In Texas the FEMA Mitigation Assessment Team (MAT) investigated 23 critical facilities (including emergency operation centers, fire and police stations, hospitals and schools). The purpose of the investigations was to determine: 1) if the buildings experienced wind damage, 2) if the buildings experienced functional (i.e. operational) loss due to wind damage or interruption of municipal utilities and 3) if the buildings were vulnerable to future hurricane damage. The investigated buildings ranged in age from a few years to several decades old. The current design wind speed for the investigated buildings ranges from 108 to 132 miles per hour (mph), peak gusts, measured in flat open terrain (Exposure C) at 33' above grade. The estimated wind speeds at these buildings ranged from 90 to 110-mph. At all of the investigated buildings the estimated wind speed was less than the current design wind speed. None of the investigated buildings experienced structural damage, but 16 of the 23 facilities experienced damage to the building envelope and/or rooftop equipment (Figure 1). The most common building envelope damage was roof membrane blow-off or puncture by wind-borne debris. Other envelope damage included broken windows and blown-off wall coverings. In many instances, damaged envelopes and rooftop equipment allowed the entrance of rain into the building. Figure 1: The exhaust fan shown at the inset blew off the curb. The fan landed on a lowerlevel roof. The estimated speed at this location was 105 mph. Four of the facilities experienced failure with their emergency generator. One of the generators ran on natural gas it shut down when the gas supply was turned off. Another generator shut down because of water leakage after the roof membrane above it blew off. Still another generator failed because of an engine problem. At three of these four facilities there was no back-up Testimony of Tom Smith, A.I.A. Page 1 of 6

10 generator. Therefore, the facility was out of electrical power until a portable generator could be brought to the site. Several of the facilities had their emergency generators located outdoors or within flimsy buildings. These generators were susceptible to being damaged by tree-fall (Figure 2) and windborne debris. Figure 2: The tree shown by the red line nearly fell on the emergency generator (red arrow). The tree did hit and damage a metal roof that was over the compressed gas cylinders (blue arrow). Based on the Hurricane Ike MAT investigations, as well as MAT investigations after several other hurricanes, it is apparent that relatively few critical facilities (including facilities that are quite new) are sufficiently robust enough to ensure that they will remain fully functional during and after moderate and strong hurricanes. FEMA design guides 543 and 577 provide recommendations for designing new critical facilities and upgrading existing ones.[1, 2] Performance of Buildings in Houston's Central Business District During Hurricane Ike During Hurricane Alicia (1983) there was extensive glass breakage in several buildings in Houston's central business district, including significant breakage at six high-rise buildings (one of which lost between 1,100 and 1,200 windows). The majority of the glass breakage was attributed to wind-borne aggregate from built-up roofs.[3] During Hurricane Ike, there was extensive glass breakage in one mid- and two high-rise buildings (Figure 3). Several other low- and high-rise buildings had a few to several broken windows. Some of the glass breakage appeared to be caused by wind-borne roof aggregate from built-up roofs, but this did not appear to be the cause of the majority of the breakage. (The cause of the extensive breakage at the three buildings is still being investigated.) Testimony of Tom Smith, A.I.A. Page 2 of 6

11 Note: Soon after Hurricane Alicia, a change to the City of Houston Building Code was proposed. The proposed change prohibited the use of aggregate on roof surfaces over 55' above grade. However, the City Council did not accept the recommendation. Sometime in the late 1990s, the Houston Building Code was changed to prohibit roof aggregate, but this code provision did not require removal of existing aggregate surfaced roofs. At the time of Hurricane Ike, most of the roofs in the central business district were not aggregate surfaced. The small number of aggregate surfaced roofs at the time of Hurricane Ike versus Hurricane Alicia is the likely reason that there was reduced glazing damage during Hurricane Ike. The 2006 edition of the International Building Code prohibits roof aggregate in hurricane-prone regions. Figure 3: Most of the windows in the red oval were broken during Hurricane Ike. Testimony of Tom Smith, A.I.A. Page 3 of 6

12 In addition to glass breakage, there was a moderate amount of roof covering damage. In some cases, portions of the roof membrane blew off, and in other cases, the roof membrane was punctured by glass shards from the broken windows (Figure 4). Figure 4: These buildings are in the vicinity of the high-rise building shown in Figure 3. The arrows indicate buildings that had roof membrane damage. In summary, critical and essential facilities should have hardy structures with more robust envelopes and support systems, capable of withstanding stronger winds than the design standard. These stronger facilities will enable government and facilitators to respond and recover more effectively and more efficiently to natural disasters. Aggregate surfaced roofs should not be allowed on tall buildings, 55-feet and taller, which are located in hurricane-prone regions. Testimony of Tom Smith, A.I.A. Page 4 of 6

13 References: 1. FEMA, FEMA 543, Design Guide for Improving Critical Facility Safety from Flooding and High Winds FEMA, FEMA 577, Design Guide for Improving Hospital Safety in Earthquakes, Floods, and High Winds Savage, R.P., Baker, J., Golden, J.H., Kareem, A., Manning, B.R., Hurricane Alicia, Galveston and Houston, Texas, August 17-18, National Research Council, 1984: p Testimony of Tom Smith, A.I.A. Page 5 of 6

14 Curriculum Vitae Tom Smith, AIA, RRC Licensed Architect/State of Alaska Certificate from the National Council of Architectural Registration Boards (NCARB) Bachelor of Architecture, University of Arkansas, 1972 Mr. Smith is president of TLSmith Consulting Inc. He performed building performance research investigations after Hurricane Hugo (South Carolina, 1989) and Hurricane Andrew (Florida, 1992). He was a member of FEMA teams that performed building performance investigations after Hurricane Marilyn (U.S. Virgin Islands, 1995), Typhoon Paka (Guam, 1997), Hurricane Georges (Puerto Rico, 1998), the Oklahoma and Kansas Tornadoes of May 1999, Hurricanes Charley, Frances and Ivan (Florida 2004), Hurricane Katrina (Louisiana and Mississippi, 2005), the February 2007 Florida Tornadoes and Hurricane Ike (Texas, 2008). He also performed specific building investigations after five other hurricanes and several other tornadoes. Mr. Smith was a contributing author of FEMA's Coastal Construction Manual (FEMA 55), Home Builder's Guide to Coastal Construction (FEMA 499), Design Guide for Improving School Safety in Earthquakes, Floods, High Winds (FEMA 424), Design Guide for Improving Critical Facility Safety from Flooding and High Winds (FEMA 543), and Design Guide for Improving Hospital Safety in Earthquakes, Floods, and High Winds (FEMA 577). In 2002 Mr. Smith served on an expert elicitation team for the correlation of tornado wind speed and damage. Expert judgment is used to represent the informed scientific/technical community's state of knowledge. The team was convened by Texas Tech University to obtain estimates of mean wind speeds to cause specified types of wind damage and estimate the uncertainty in the mean value estimates. This work led to the development of the Enhanced Fujita Scale, which is now used by the National Weather Service. Mr. Smith has been a member of the committee responsible for ASCE 7, Minimum Design Loads for Buildings and Other Structures since tlsmith@hughes.net Testimony of Tom Smith, A.I.A. Page 6 of 6

15 Texas Senate Subcommittee on Flooding and Evacuations, December 3, 2008 Testimony Regarding Observations of Hurricane Ike Flood and Erosion Damage by FEMA Mitigation Assessment Team by Christopher P. Jones, P.E. Overview of Hurricane Ike Flood Levels Although Hurricane Ike came ashore as a Category 2 storm, its wind field was very large prior to landfall, and tropical storm force winds extended out 275 miles from the center [1]. This resulted in significant storm surge levels along several hundred miles of coast, from Texas to Florida. High water marks were highest in east Texas and southwest Louisiana (see Figure 1 for one example of the maps produced by FEMA following Ike). Figure 1. One of several high water mark maps produced by FEMA following Hurricane Ike [2]. Preliminary estimates of Ike high water mark elevations, including some wave effects, are as follows [1, 2, 3]: Freeport/Surfside Beach, 6 to 8 feet above mean sea level Galveston Island, 10 to 13 feet above mean sea level Western Galveston Bay, 10 to 13 ft above mean sea level Galveston Bay, Chambers County, 15 to possibly 20 ft above mean sea level Bolivar Peninsula, 13 to 17 ft above mean sea level Port Arthur, 10 to 12 feet above mean sea level Testimony of Christopher P. Jones, P.E. Page 1 of 8

16 Additional high water mark elevation data are expected soon, and the elevations shown above will be supplemented and possibly revised. That being said, it is clear that the flood levels during Hurricane Ike were as much as several feet higher than the Base Flood Elevations (BFEs) shown on the Flood Insurance Rate Maps (FIRMs) for some areas north and east of Galveston Bay Entrance. MAT Observations of Residential Performance during Ike s Flooding Members of the MAT inspected buildings and other structures throughout coastal Texas on September and October 15-21, Beach and dune erosion were severe along the entire Gulf shoreline, from Brazoria County to Sabine Pass, even in areas where dunes had been reinforced with geotextile tubes (see Figure 2). Figure 2. Erosion along the Galveston Island shoreline, west of the seawall (Oct. 17, 2008 photo) Hundreds of residential buildings were lost as a result of undermining, high flood levels, waves and floodborne debris. Damage was particularly widespread and severe along the Gulf shoreline where Ike flood levels exceeded BFEs (see Figure 3). In my opinion, the flood-related building damage in some communities was as severe as in coastal Mississippi during Hurricane Katrina. Buildings elevated above the BFE on strong and deep foundations sustained less damage than homes at lower elevations (see Figure 4). This damage pattern is consistent with that which has been observed in other storms (see Figure 5). Testimony of Christopher P. Jones, P.E. Page 2 of 8

17 Figure 3. Ike damage along the Gulf shoreline at Crystal Beach, TX (Sept. 19, 2008 photo). Figure 4. Bolivar Peninsula house on left sustained minor flood damage (to access stairs and below-bfe enclosures) during Ike, while the house on the right was severely damaged. The house on the left was constructed 5.5 ft above the BFE, the house on the right was estimated to be at the BFE (Oct. 18, 2008 photo). Testimony of Christopher P. Jones, P.E. Page 3 of 8

18 Figure 5. Idealized flood depth vs. building damage relationship for an elevated home attacked by waves [4]. One observation unique to the Ike MAT was the amount of scour around foundations on the barrier islands (see Figures 6 and 7). Most of the scour was observed at foundations with concrete slabs at ground level, but significant scour was also observed around some pile foundations without concrete slabs. Foundation scour depressions were frequently several feet deep, and tens of feet in diameter. Homes subject to scour and not on deep foundations collapsed. Figure 6. Foundation scour around a pile-supported home, Bolivar Peninsula (Sept. 19, 2008 photo). Testimony of Christopher P. Jones, P.E. Page 4 of 8

19 Figure 7. Collapse of a home subject to severe foundation scour, Bolivar Peninsula (Oct. 18, 2008 photo). Significant foundation scour was not observed along the bay shorelines, but storm surge and waves and floodborne debris did damage older buildings constructed at grade and did damage elevated homes that were not high enough to rise above Ike s flood level. Bayfront Testimony of Christopher P. Jones, P.E. Page 5 of 8

20 buildings that were above Ike s storm surge and waves did survive, often with little damage (see Figure 8). Figure 8. Older Baytown home constructed at ground level was largely destroyed, while adjacent elevated house (in foreground) sustained little damage (Oct. 19, 2008). The MAT believes that wave effects and floodborne debris impacts were the dominant causes of building structural failure during Hurricane Ike, both along the Gulf of Mexico shoreline and along many bayfront shorelines. Damage was more severe and widespread along the Gulf shoreline, as would be expected, since the wave heights were larger and since more buildings were lost there, adding greatly to the debris stream available to strike other buildings. While it is virtually impossible to separate the individual effects of waves from the effects of floodborne debris in most cases, without damaging waves fewer buildings would have been lost and less debris would have been generated. The direct and indirect effects of waves should be considered the most dangerous aspect of coastal flooding to buildings. Avoiding waves, by elevating buildings above them, is crucial to reconstruction efforts. As Ike, Katrina, Ivan and other recent hurricanes have shown, flood levels and waves above the BFE do occur. The MAT believes that reconstructed and new buildings should be elevated above the BFEs shown on the Flood Insurance Rate Maps, at least until new FIRMs are produced. This process of elevating above the BFE is called adding freeboard and has proven repeatedly to be the most cost-effective way to reduce coastal flood damage [5]. Designing and constructing for flood levels above the BFE should be encouraged, and guidance is available to assist communities and the State [6]. Testimony of Christopher P. Jones, P.E. Page 6 of 8

21 References 1. National Weather Service, Houston/Galveston, TX (2008). Post Tropical Cyclone Report, Hurricane Ike. [Available from 2. FEMA (October 2008). Final Report -- Texas Hurricane Ike Rapid Response Coastal High Water Mark Collection. 3. National Oceanic and Atmospheric Administration, Center for Oceanographic Operational Products and Services (2008). Preliminary Tide and Water Level Data. [Available from 4. FEMA (2006). Mitigation Assessment Team Report Hurricane Katrina in the Gulf Coast. [Available from 5. Jones, C.P., W.L. Coulbourne, J. Marshall and S.M. Rogers (October 2006). Evaluation of the National Flood Insurance Program s Building Standards. [Available from 6. FEMA (2006). Designing for flood levels above the BFE, Hurricane Katrina Recovery Advisory no. 8. [Available from Testimony of Christopher P. Jones, P.E. Page 7 of 8

22 Curriculum Vitae Christopher P. Jones Registered Professional Engineer/ States of North Carolina, South Carolina and Florida Graduate of the University of Florida, 1977, M.S., Coastal and Oceanographic Engineering Mr. Jones specializes in coastal engineering, coastal zone management and flood hazard mitigation. He has 30 years experience as a practicing engineer, and has worked throughout the United States and abroad on studies and projects related to: flood hazard mapping coastal construction codes post-storm damage investigations flood loss estimation modeling shoreline erosion beach nourishment Mr. Jones is a recognized expert on coastal floodplain mapping and coastal building code issues. He is currently or has recently been a consultant to various local, state and federal agencies and to private clients on a variety of projects: Post-hurricane investigations for FEMA Mitigation Assessment Teams, hurricanes Opal (1995), Fran (1996), Ivan (2004), Katrina (2005) and Ike (2008). Chair of Technical Review Committee, Guidelines for Design of Structures for Vertical Evacuation from Tsunamis. One of the Principal Authors for the rewrite of FEMA s (2000) Coastal Construction Manual and co-author of FEMA s (2005) Home Builder s Guide to Coastal Construction. Developer and instructor for 2-day and 5-day CCM training courses. Project Investigator and team leader, NFIP Building Standards Evaluation as part of the NFIP Evaluation Project. National Fire Protection Association: represented FEMA for the incorporation of floodresistant design and construction requirements in the NFPA 5000 Building Code and NFPA 225 Manufactured Home Installation Standard. Member of Project Engineering Panel and Author of updated flood provisions, ATC-45 Field Manual: Safety Evaluation of Buildings after Wind-Storms and Floods. Chair of Technical Working Group on the development of a NFIP Technical Report, Guidance for Coastal Flood Hazard Analyses and Mapping in Sheltered Waters. SE Louisiana post-katrina flood hazard mapping. Consultant to FEMA for development and review of post-katrina coastal flood hazard mapping procedures and mapping. Technical Working Group member for FEMA on the update of Atlantic and Gulf of Mexico Coastal Flood Hazard Analysis and Mapping Guidance. Chair of Technical Working Group for FEMA on the development of NFIP Technical Procedure Memorandum 47 (Guidance for the Determination of the 0.2-Percent-Annual- Chance Wave Envelope along the Atlantic Ocean and Gulf of Mexico Coasts). Chair of 2006 Florida Dept. of Environmental Protection s Innovative Shore Protection Technology Workshop and chairman of the Innovative Shore Protection Technical Review Committee. Testimony of Christopher P. Jones, P.E. Page 8 of 8