Studies and Reports - CHAPTER ONE

PURPOSE AND NEED

INTRODUCTION

This section of the Environmental Assessment (EA) provides an introduction to the proposed project to develop an airport at the Kentucky TriModal Transpark (KTT), which is currently being planned in Warren County, Kentucky. The airport, which would include a 7,000-foot runway, would replace the existing Bowling Green-Warren County Regional Airport. The existing airport is located within the city limits of the City of Bowling Green and has been "boxed in" by the urban growth that now surrounds the airport. The existing airport has no practical way of expanding at the current location to meeting the growing needs of the aviation industry. In addition, the existing airport is surrounded by residential neighborhoods that are currently experiencing noise impacts from the existing operations, which are projected to increase in the future.

The proposed airport would be located within the KTT, which is currently being planned by the Inter-Modal Transportation Authority, Inc. of Bowling Green, Kentucky. The proposed KTT will be located within a 6,600-acre study area approximately 5 miles northeast of Bowling Green and adjacent to I-65, the CSX Railroad and US 31W. This general area is identified throughout this document as the "Yellow Study Area". The land requirement for the KTT is approximately 4,000 acres that will be developed in phases. The KTT is being planned to include the following facilities:
While the business/commerce park is being financed without any federal funding, federal funding may be sought for the airport development within the KTT. Due to the potential for federal funding related to airport development, this document was prepared.

PROJECT DESCRIPTION

This EA addresses the potential environmental impacts of the proposed airport within the KTT. Although there is currently no federal sponsor for this project, the EA was conducted following, to the greatest extent possible, the Federal Aviation Administration's (FAA's) guidelines for completing NEPA documents, which are detailed in Federal Order 5050.4A, "Airport Environmental Handbook." In addition, coordination was conducted with appropriate federal, state, and local agencies, as well as the public in the spirit of the NEPA process. Should this project get a federal sponsor, this EA will serve as a springboard to initiate a federal Environmental Impact Statement (EIS). It is important to note, without a federal sponsor at this point in the project, the formal EA process is not required. The ITA, however, has elected to prepare a document that closely follows FAA procedures in order to identify potential areas of environmental impact and to assure that there is an appropriate level of examination of avoidance, minimization, or mitigation opportunities for potential adverse impacts.

This EA analyzes the potential environmental impacts of the proposed airport runway alternatives. In addition, the potential environmental impacts of the business/commerce park development on the Yellow Study Area were evaluated to the greatest extent possible. The environmental impacts associated with the business/commerce park component of the KTT cannot be evaluated in as great of detail at this time because a final site development plan has not been completed.

The environmental analyses that were performed on the Yellow Study Area will be utilized in the design of the business/commerce park to ensure that potential impacts to sensitive environmental areas will be avoided, minimized, or mitigated. This information will also be utilized in the preparation of environmental permits that will be required for the development of the business/commerce park. The following subsections describe the basic requirements associated with each development area of the proposed KTT.

Airport-Related Development

The airport related development represents one of the most critical elements in defining the ultimate site layout due to the land area needed for the proposed facility. The airfield layout requires a generally level site that is more than two miles in length to accommodate pavement and required runway safety/protection areas. Figure 1-1 depicts a draft airport template with a 7,000-foot long runway. A runway of 7,000 feet will accommodate all types of general aviation business jets and most aircraft being used by commercial air carriers that may serve the Bowling Green area in the foreseeable future.

In addition to the 7,000-foot long runway, sufficient land is required to accommodate runway protection zones (RPZ). RPZs are recommended by the FAA to ensure that incompatible land uses are not developed in the airport approach areas. The FAA recommends that the RPZs be owned, in fee, by the airport. Almost all dwellings, businesses, or non-aviation related structures are considered incompatible land uses. For runways with precision approaches with the most precise minimums, as are envisioned for the proposed runway, a RPZ of 2,500 feet in length is required. The most demanding RPZ has an outer width of 1,750 feet and starts 200 feet from the end of the runway's threshold. Therefore, the total length potentially needed for runway development is 12,400 feet (7,000 foot runway plus two 2,500 foot RPZ plus the required 200 feet from each runway threshold to the RPZs). It should be noted that a shorter, less demanding RPZ might be pursued for the runway end that will experience less activity. The minimum footprint needed for the runway is approximately 660 acres. When ground access, aircraft storage, terminal development, air cargo development and various parcel shapes are considered, the potential airport footprint could approach up to 2,000 acres.

Insert Figure 1-

Rail/Inter-Modal Development

The current conceptual plan for the KTT recommends approximately 500 acres of industrial property. It is important to note, however, that the size and acreage for the industrial development areas within the park will be refined through coordinated planning with the ITA and the City-County Planning Commission of Warren County. The demand for business development space at the proposed facility is related to both the economic demand for this property along with the availability of land zoned for business and commerce use throughout the region.

Rail service will be provided to the business/commerce development areas. It is anticipated that a rail spur from the CSX mainline will provide rail service to the site and that only one rail access point will be required. Secondary spurs would link this line with the business/commerce development. It is not anticipated that a large rail-yard will be required, but approximately 10-20 acres will be required for a storage/staging area for inter-modal cargo containers.

Business/Commerce Development

The KTT will include between 1,500 and 2,800 acres that are dedicated to office and business development. The actual size of the business/commerce park will depend not only on market conditions, and on site constraints. General planning guidelines for the development of the business/commerce park will include the following elements:
EXISTING AIRPORT LOCATION AND BACKGROUND

The Bowling Green-Warren County Regional Airport is currently owned by the City of Bowling Green and Warren County. The existing airport is located within the city limits of Bowling Green and is managed by an Airport Board, whose members are appointed. The County Judge Executive appoints five members and the Mayor of Bowling Green appoints five members. These appointments are staggered to provide overlapping terms.

Aviation activity was established at the present site in the early to mid-1930s. It was not until the early 1940s that two 4,000-foot runways were constructed and lighted as part of a U.S. Army project. The Western Kentucky State Teachers College (currently Western Kentucky University) initiated flight training courses in 1943. Airline passenger services started in 1944 with Bluegrass Airlines. Few improvements were made at the airport until the late 1950s, when additional land was purchased and Runway 3/21 was extended to 5,200 feet.

In the late 1960s, the runway was again extended to 6,500 feet. Air carrier service was initiated at this time that continued until the late 1970s. During the 1980s, land was acquired to construct an area for a corporate hangar and a maintenance building. During the 1990s, airport improvements included: taxiway and apron additions; improved runway and taxiway lighting; airport signage; purchase of 12 acres for an Instrument Landing System (ILS) installation; construction of T-hangars; Automated Surface Observation System (ASOS) installation; and the construction of a fuel farm and a new fixed base operator (FBO) facility.

Development beyond the current facility is extremely unlikely due the development of residential properties to the north and northwest of the airport as well as the extensive commercial development along Scottsville Road (US 231).

PROJECT PURPOSE AND JUSTIFICATION

The purpose and justification for the proposed airport component of the KTT are twofold: first, to replace the existing Bowling Green-Warren County Regional Airport, which cannot expand at its current location to meet future aviation demand, and, second, to provide an enhancement to the proposed KTT, which will serve as a catalyst for economic growth for South Central Kentucky. These areas of justification are discussed in the following sections. The purpose and need for the proposed business/commerce park development of the KTT is discussed in a separate report, "Environmental Impact Evaluation for the Kentucky TriModal Transpark.."

Replacement of the Existing Bowling Green-Warren County Regional Airport

In the early years of the 1930s, the existing Bowling Green-Warren County Regional Airport sat on the outskirts of the City of Bowling Green. Since that time, the city has expanded and urban development surrounds the airport. The Scottsville Road corridor, which is adjacent to the existing airport and the City's main access to I-65, has rapidly developed with new shopping centers and commercial properties. In addition, residential developments, civic institutions, and commercial offices now surround the existing airport.

As a result of the urban growth that now surrounds the Bowling Green-Warren County Regional Airport, the existing airport is "boxed in" without any practical way of expanding at the current location to meet the needs of a growing aviation industry. In the near future, it is anticipated that the airport will experience operational limitations due to noise and other constraints.

Replacement of the existing Bowling Green-Warren County Regional Airport is warranted based on several critical factors. While the Airport has served the region well over the last 50 years, land use constraints, limited expansion capability, noise concerns, and economic factors have all been considered in the need to build a replacement facility. Several of these factors pertain to immediate airport concerns, while several others are more long-range in scope.

In order to establish a definite purpose and need for an enhanced, relocated airport, a "facility adequacy review" was prepared that draws on information presented in the 1999 draft Master Plan Update. In addition to Master Plan data, an independent analysis of airport constraints was completed. This analysis included a review of land use compatibility related to noise concerns and incompatible land uses located in the runway protection zones (RPZs).

The Bowling Green-Warren County Regional Airport is currently the busiest general aviation airport in the State. According to the Master Plan Update, there are 64 aircraft based at the airport, including four turbojets. This number is projected to increase to nearly 120 (seven turbojets) by 2019. Based on the Master Plan Update, 7,200 commuter operations are projected by the end of the 20-year planning period. The Airport is sited on approximately 505 acres and has two operational runways. The primary runway, Runway 3/21, is currently listed as 6,500 feet in length and 150 feet wide. Runway 3/21 is equipped with: High Intensity Runway Lights (HIRL); glide slope, localizer, and precision approach path indicators; and a parallel taxiway. Runway 3 is equipped with an ILS approach; however, approach lighting is not available due to conflicting land uses. Visibility minimums are 747 feet (above ground level) and _ mile (distance). The Airport also has a crosswind runway, Runway 12-30, that is 3,956 feet in length. This runway reportedly experiences limited use, mainly by light, single-engine aircraft.

According to the Statewide Aviation System Plan, Bowling Green-Warren County Regional Airport's role is a Level III Enhanced facility. This type of facility provides the highest level of general aviation service in the State. Level III Enhanced facilities should also be able to support commercial service needs if required. Such an airport should be able to provide a full compliment of navigational aids and services to support the demands of commercial and corporate users.

There are four primary reasons related to existing airside facilities that support building of an improved, replacement airport. These include: It should be noted that the existing airport has no potential to directly support the multimodal and business and commerce park features that have been proposed for the KTT.

The FAA provides guidance for planning and design of airport facilities through FAA Advisory Circulars that promote airport safety, economy, efficiency, and longevity. FAA Advisory Circular 150/5300-13, "Airport Design," was used to determine the Airport Reference Code (ARC) for Bowling Green-Warren County Regional Airport. The ARC is a coding system used by the FAA to relate airport design standards to the operational and physical characteristics of the airplanes intended to operate at an airport.

The ARC has two components that relate to an airport's design based on the critical aircraft. The critical aircraft is the most demanding aircraft currently conducting or projected to conduct 500 annual operations. The first component, depicted by letter of the alphabet, is the aircraft approach category, as determined by the approach speed of the critical aircraft. The second component, depicted by Roman numeral, is the airplane design group, as determined by the critical aircraft's wingspan. Generally, aircraft approach speed applies to runways and runway- related facilities. Airplane wingspan relates primarily to separation criteria involving taxiways and taxilanes. According to the draft Master Plan Update, the required ARC for the Airport is C- III. Considering the Airport's role in the State system as well as it's existing based and operating fleet, an ARC of C-III is warranted.

Runway Safety Area (RSA)

The RSA serves as a safety area if an aircraft overruns the paved runway surface. According to the FAA's definition, the RSA should be cleared and graded and have no potentially hazardous ruts or surface variations. Grading or storm sewers should also drain this area. For Design Standard C runways, the RSA is required to be 500 feet wide and extend 1,000 feet beyond the runway end. General requirements for the grading of this area are a 0 to -3 degree grade for the first 200 feet from the runway end, with the remaining longitudinal grade ensuring that no part of the RSA penetrates the approach surface or drops below a -5 degree grade.

An examination of Runway 3/21 indicates that Runway 3's RSA extends beyond airport property and contains a corner of a large building, as well as a section of Scottsville Road's frontage road. Approximately 430 feet of the RSA is completely contained on airport property. The remaining 570 feet is only partially controlled and contains the noted obstructions. (See Figure 1-2)

There are three alternatives that could be considered to bring the RSA up to FAA requirements: Insert 1-2

Considering the commercial land use associated with the portion of the RSA not on airport property, land acquisition would be costly. Impacts to the last 100 feet of the RSA stemming from Scottsville Road's frontage road cannot be avoided, since relocating Scottsville Road or the frontage road appears unfeasible. Relocating the threshold by 570 feet would clear the RSA, however this would shorten the available runway length to 5,930 feet. Finally, using the declared distances, which would displace the threshold, would also limit Runway 3/21's take-off run and landing distance available. Therefore, none of the alternatives would resolve the issue of bringing the RSA up to FAA standards without affecting the length of Runway 3/21 available for departures or resulting in a conflict with existing incompatible land uses.

Incompatible Land Uses in Runway Protection Zones
The RPZ, formerly the runway clear zone, is trapezoidal in shape and is centered on the extended runway centerline. The function of the RPZ is to enhance the protection of people and property on the ground. This is typically achieved through airport control over the RPZ through acquisition. Residential, commercial, and institutional land uses are not typically compatible. The RPZ begins 200 feet beyond the end of the runway pavement that is usable for takeoffs and landings. Displacing the landing or takeoff threshold does not change the beginning point of the RPZ. If runway pavement is used for either takeoffs or landings, the start of the RPZ remains at the 200-foot standard. The actual width and length of the RPZ is contingent on the size of the aircraft operating on the runway, as well as on the type of approach available. Generally, as the aircraft size increases and the approach minimums become more precise, the dimensions of the RPZ increase.

Runway 3's RPZ is currently designed to accommodate approaches with at least .75 mile of visibility. The existing RPZ contains nearly 49 acres and extends 1,700 feet beyond the primary surface. Approximately 75 percent of this RPZ contains commercial land uses and is not controlled by the Airport. The current ALP submitted for FAA review depicts the future RPZ with an expansion to 78.9 acres. The proposed RPZ extends 2,500 feet from the primary surface in order to accommodate visibility minimums lower than .75 mile. The entire proposed expansion of Runway 3's RPZ would encompass even more commercial development.

Runway 21's RPZ is less demanding since its visibility minimums are not lower than one mile. However, this RPZ extends 1,700 feet beyond the primary surface. The airport does not control approximately 20 percent of the RPZ area. An estimated 14 homes are currently located in the RPZ. Any extension of the RPZ associated with any type of runway extension or shifting to free up the opposite end's RSA would impact additional homes. This significantly limits the possibility of a runway extension on Runway 21 to make up for a relocated threshold for Runway 3 end.

The crosswind runway, Runway 12-30, also has RPZs that are not completely controlled by the airport. Runway 12's RPZ generally appear to provide compatible land uses; however, Runway 30's RPZ contains institutional land uses that are not compatible with FAA guidelines.



Limited Runway Extension Capability

The draft Master Plan Update does not recommend a runway extension during the planning period. Several critical issues are related to the potential need for runway expansion; however, these were not specifically addressed. As previously discussed, in order to provide clear RSAs, Runway 3's threshold must either be displaced and declared distances applied or relocated. Either scenario would decrease the runway available for departures. While a minimum amount of room for an offsetting extension is available on Runway 21; such an extension would move the RPZ over an established residential neighborhood, thereby diminishing operational safety.

By decreasing the runway length to less than 6,000 feet, Bowling Green-Warren County Airport would not be able to effectively serve the current operating fleet. Based on the data contained in the Master Plan Update as well as a review of runway length requirements for possible commuter aircraft that may someday serve the region, a minimum runway length of 6,500 to 7,000 is warranted. Other factors considered in the determination of the required runway lengths at Bowling Green-Warren County Regional Airport include the Airport's elevation (547 feet), average daily high temperatures during the hottest month (89 degrees Fahrenheit), and relatively level runway conditions. In addition, due to the incompatible land uses located off each runway end, the airport has no potential to expand beyond its current runway length.

Commercial Aircraft

The draft Master Plan Update for the existing airport indicates that the design aircraft for the existing airport is the Boeing 727-200. While Boeing planning manuals indicate that 6,000 feet of runway may allow operations by a 727-200, such operations would be severely weight restricted, and operations would be limited to short haul lengths, especially during warm weather. For 727-200 service, a runway length of 7,000 feet or greater is typically required. It should be noted that service by 727 aircraft at the existing airport is considered unlikely.

In addition to considering the 727-200, other aircraft or families of aircraft should be considered when developing current and future runway length requirements. Another potential aircraft was evaluated to determine runway length requirements necessary to serve the Bowling Green area. While the 727-200 was mentioned in the Master Plan Update, a more likely commercial service aircraft is the Bombardier Regional Jet.

Based on an air service analysis that was conducted as part of the benefit-cost analysis for the KTT, it was determined that regional/commuter aircraft ranging in size from 50 seat regional jets to smaller 30 seat turboprop aircraft could serve the market area in the future. Many regional/commuter carriers are replacing their smaller aircraft, such as the Metroliner and the Jetstream 31, with larger aircraft, such as the 37 and 50 passenger regional jets. For a market the size of Bowling Green, it is likely a 50 seat regional jet aircraft represents the most demanding air carrier aircraft that can reasonably be anticipated in the near-term.

To identify the runway length required to support regional jet operations at the Airport, aircraft performance data from manufacturers were obtained and analyzed. Required runway departure length is a function of the temperature, airport altitude, and the weight of the departing aircraft. It should be noted that the information supplied in the Bombardier's planning manual only provides a general overview of runway length requirements. Actual conditions and pilot discretion will determine whether an aircraft can depart on a given runway.

By analyzing the impact of temperature, weight, and altitude on the regional jet, a recommended length of approximately 6,500 feet was developed for Bowling Green-Warren County Regional Airport's primary runway. When the existing runway's RSA violations are considered, it only provides approximately 6,000 feet of usable pavement. A runway length of 7,000 feet would accommodate the maximum allowable take-off weight of a 50 passenger regional jet (51,000 pounds) during warm conditions (91 degrees Fahrenheit).

General Aviation Aircraft

In order to determine runway length requirements for general aviation aircraft the FAA runway length curves for families of aircraft below 60,000 pounds were reviewed. The FAA Airport Design computer program produces recommended runway lengths based on a family of airplanes having similar performance characteristics. The most demanding family of general aviation aircraft using the primary runway at Bowling Green-Warren County Regional Airport is "Large Aircraft." This aircraft family includes all general aviation aircraft that have a maximum gross weight between 12,500 and 60,000 pounds. This group includes most business jets commonly in use today.

The runway length results for large aircraft between 12,500 and 60,000 pounds are as follows:

                                                                               Required Runway Length These data indicate the need for a runway length of 7,000 feet in order to accommodate 75 percent of the fleet of aircraft currently operating at 90 percent of their useful load at Bowling Green-Warren County Regional Airport.

Runway Length Summary

Based on the review of runway length requirements for the 727-200 (master plan critical aircraft), a 50-passenger regional jet (most demanding air carrier aircraft anticipated in the near term), and 75 percent of the "large general aviation fleet" operating at 90 percent of their useful load, a runway length of 7,000 feet is recommended to serve the Bowling Green area. While the current runway length of 6,500 feet can accommodate these aircraft, it does not provide an optimal level of operating efficiency, since these aircraft cannot operate at higher payloads. When this information is combined with the fact that the existing primary runway's non-standard RSAs support a runway reduction, the ability of the existing airport to adequately fulfill its role is compromised.

Noise Impacts

One of the potential benefits of relocating the existing Bowling Green-Warren County Airport to a new site is the reduction of noise impacts to the densely developed residential communities located just north of the primary runway. In 1979, the Aviation Safety and Noise Abatement Act required the FAA to designate a single methodology for measuring and describing noise. In 1981, the Federal Aviation Administration formally adopted day-night average sound level (DNL) as the single system for determining the exposure of individuals to airport noise. DNL is the 24-hour average sound level, in decibels, obtained from the accumulation of all sound events. This includes the addition of a 10-decibel penalty for sounds occurring at night between 10 p.m. and 7 a.m. The weighting of nighttime events accounts for the usual increased interfering effects of noise during the night, when ambient levels are lower and people are trying to sleep. The FAA land use guidelines state that residential development is typically considered an incompatible development inside the 65 DNL or higher noise contours.

In order to estimate the noise impacts in the area surrounding the airport, the most recent version of the FAA's computer model, Integrated Noise Model (INM) Version 6.0, was used. This state-of-the-art mathematical computer model is used to predict aircraft noise around airports. The INM calculates noise exposure from airport specific information (including the physical layout of the airport runways, flight tracks, fleet mix, aircraft activity levels, runway utilization and terrain) and data contained in the model (including aircraft noise levels, operational and performance data). Operating assumptions for the airport were derived from the Draft 1999 Master Plan Update as well as from conversations with airport management.

The general assumptions used in developing the noise contours are as follows: Based on the above assumptions, in 1999 approximately 320 single-family residential units are contained within the 65 DNL noise contour. The 1999 65 DNL contour contains approximately 1,500 acres. As shown in Figure 1-3, by 2019, with the addition of commercial service activity as well as the projected increase in general aviation activity, the 65 DNL or greater noise contour is expected to increase to more than 1,870 acres and contain approximately 420 single-family units (as depicted on the following aerial photographs). While noise abatement procedures may be able to mitigate some of these concerns, this information clearly underscores the extensive amount of incompatible land uses that have developed around the existing airport. Even without the addition of commercial aircraft such as the CRJ and the 737, the current noise contours contain an inordinate number of single-family homes.

Economic Development

In the past ten years, expanding and new industry has occupied approximately 655 acres in Warren County. This represents an average annual absorption rate of more than 66 acres. Currently, about 300 acres, most of which are small development tracts, are currently available for new business park development. Given the historic absorption rates, existing developable property will be built out within five years. The Chamber of Commerce has reported that the community has recently lost potential investors due to the lack of large development tracks (parcels over 100 acres).

As a result of the current and future demand for high quality sites for commercial development and the current limitations of the existing airport, the concept was developed to combine all elements needed by business today such as air, rail, and highway access, in one location. During the site selection process, a Benefit-Cost and Economic Impact Analysis was completed for several scenarios of airport and industrial park development. The most prudent scenario included a small, enhanced airport with a large (over 1,200 acres) industrial/business/commerce park.

While the development of a business/commerce park does not typically require the completion of an EA, the ITA elected to analyze the potential development to identify areas that may be unsuited for development. The business park development will not include the use of federal funds and all land transfers will likely require concurrence from both the existing landowners and the ITA. The primary benefit associated with the construction of the business park will be the creation of high quality jobs for the region. The Benefit-Cost and Economic Impact Analysis indicated that by 2030, the business park could generate more than 6,100 jobs receiving $267.9 million in payroll. The Gross Regional Product associated with the business park is estimated to reach more than $650 million by 2030.




Purpose and Need Summary

The purpose and need for the entire project is two-fold. The primary reason for the entire KTT project is the creation of jobs. As demonstrated in the Benefit-Cost and Economic Impact Analysis, there is a strong need in the region for additional industrial/commerce park property. A
Insert 1-3

development as envisioned for the KTT could add more than 6,100 jobs to the region over the next 30 years. The secondary reason is the relocation of the airport from the existing Bowling Green site would allow the creation of an unconstrained facility that can grow to meet the aviation needs of the area. The existing airport has little expansion capability and contains a number of non-standard conditions that may require the actual reduction of runway length to meet full FAA compliance. Incompatible land uses are also a concern at the existing airport. Although federal funds would not be used for the business/commerce park, the significant economic benefits associated with its creation can be linked to the airport as well.

ENVIRONMENTAL ASSESSMENT REQUIREMENTS

Although there is not a federal sponsor for the proposed KTT at this time, it is possible that federal funding will be sought for the airport component of the project. To ensure that the proposed airport development would qualify for federal funds, federal, state and local environmental requirements were followed to the maximum practicable extent and documented in this EA. In addition, coordination with federal, state, and local resource agencies, and the public was undertaken in the spirit of NEPA.

According to the FAA's Airport Development Handbook, an Environmental Assessment is required for projects that meet the following conditions if they are to be implemented within a three-year timeframe with the use of federal funds: It is anticipated that the airport proposed for the KTT will meet each of the above conditions and will therefore require a Federal EA or EIS to qualify for federal funding. Unless federal funds are sought for the airport development, there is no requirement to prepare an EA or EIS. The ITA, however, elected to complete an EA closely following FAA guidelines and to identify areas of concern so that reasonable measures to avoid, minimize, and mitigate adverse project development consequences could be fully examined. This document also reviews the environmental impacts stemming from the business/commerce park to the extent that is practical. This information will be useful in meeting the required State and local permitting needs associated with any development of this type.


This category is typically used to assess demanding operations by the average business jet fleet. A limited number of 737s were modeled based on preliminary proposal by a start up airline to serve Bowling Green with 737 aircraft configured for a combination of passengers and cargo.
Working Paper #4, Benefit-Cost and Economic Impact Analysis, March 16, 2000, WSA


Chapter 2