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Section 3: Environmental Documentation

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Overview

This section describes the activities involved in providing decision makers with information relating to a project’s social, economic, and environmental impacts. Documents are prepared that identify and support analyses and evaluations performed during the environmental process of project development.

This section includes discussion of the following tasks. The tasks are listed in approximate chronological order but may be performed concurrently, or may not be required in some cases.

3210. Determine type of environmental document to prepare

3240. Prepare “Purpose and Need” statement

3250. Conduct natural resources study

3260. Conduct cultural resources study

3270. Prepare Section 4(f) evaluation

3280. Perform hazardous materials assessment and investigation

3300. Prepare socioeconomic/environmental justice analysis

3310. Determine right of way relocation impacts

3315. Analyze existing environment

3330. Conduct noise analysis

3340. Conduct air quality analysis

3345. Determine project’s environmental consequences

3350. Prepare landscape recommendations

3360. Prepare description of project alternatives

3370. Prepare exhibits for environmental documentation

3375. Stake areas of potential impact

3390. Prepare environmental mitigation plans

3420. Process draft environmental document

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3210: Determine type of environmental document to prepare

Description. Environmental documents are described in the TxDOT Environmental Manual, and are referred to by the following types:

  • Environmental Impact Statement (EIS)

    An EIS is prepared for a project that may have significant social, economic, or environmental impacts.

  • Environmental Assessment (EA)

    An EA is required for a project not meeting requirements for a CE, and for which the significance of impacts is not known. Occasionally, an EA is prepared for a project that results in a finding of significant social, economic, and environmental impacts - which then requires preparing an EIS. The EA is useful as an early coordination document, but this process usually requires additional time for documentation.

  • Categorical Exclusion (CE)

    A CE is the environmental class of action required for projects which, based on past experience, do not involve significant environmental impacts. A “programmatic” CE, (or PCE, see the Environmental Manual) by agreement between the FHWA and TxDOT, is reserved for project types that are historically classified as a CE. A project not qualifying as programmatic, but also not appearing to involve significant environmental impacts, is potentially a CE. The district advanced project development engineer, in coordination with the district environmental coordinator, determines if the project may classify as a PCE or a CE. The Environmental Affairs Division can assist in determining the classification as a CE and is the approval authority for PCEs.

Pertinent Project Types. All projects.

Responsible Party. Advanced project development engineer

Sub-tasks. Expected type of environmental documentation is presumed, based on project conditions and experience, during planning and programming. This presumption is either confirmed or revised after conducting preliminary environmental surveys and resource agency coordination.

Critical Sequencing. If the project remains idle for three years, a re-evaluation (see 5810: Conduct environmental re-evaluation) may be required.

Authority Requirements. 23 CFR 771

Resource Material. TxDOT Environmental Manual

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3240: Prepare “Purpose and Need” statement

Description. The “Purpose and Need” statement (see the Environmental Manual) should explain both “purpose” for the project and considerations justifying “need” for the project, including alternatives. The evaluation of need is based on current and future conditions - not on an assumption that prior decisions are still valid. The “need” aspect of the statement requires factual justification.

The need should be defined in terms understandable to the public. The discussion should clearly describe problems that the project is to correct. It will form the basis for identifying reasonable alternatives, comparing alternatives, and selecting the preferred alternative.

Pertinent Project Types. Projects requiring an environmental assessment or an environmental impact statement.

Responsible Party. Environmental coordinator

Helpful Suggestions. The purpose and need statement should include a “project status” section which briefly describes project history including actions taken to date, other agencies and governmental units involved, actions pending, schedules, etc. The following list identifies items to consider when developing the purpose and need statement:

  • Results of preliminary plans or studies including Major Investment Study (see 1440: Determine need for Major Investment Study).
  • Supporting legislation – Is there a legislative mandate for the project?
  • Safety – Is the project necessary to correct an existing or potential safety hazard?
  • Transportation system linkage – Does the project provide a connecting link in the transportation system?
  • Maintenance and operational deficiencies – Does the project correct existing deficiencies such as substandard geometrics, load limits, roadway cross-section, or high maintenance costs?
  • Transportation demand exceeding capacity – What is the Level of Service of the existing and proposed facility? Is the project in conformance with adopted state and urban transportation plan(s)?
  • Economic development – What projected economic development or land use changes show the need to improve highway capacity?
  • Modal relationships – How will the facility interface with and serve to complement air, rail, and port facilities, mass transit, etc.?
  • Non-attainment areas – Be sure the project is part of the conforming plan (see the Transportation Programming and Scheduling Manual) in the Transportation Improvement Program (TIP).
  • Include results of preliminary planning studies. (See 1440: Determine need for Major Investment Study).

Critical Sequencing.

  • Prepare the initial purpose and need statement. (See 1000: Identify project need and scope) before conducting the design concept conference. (See 2000: Conduct Design Concept Conference).
  • During environmental document development stage, the purpose and need statement should be reviewed and updated as needed.

Resource Material. TxDOT Environmental Manual

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3250: Conduct natural resources study

Description. Natural resource issues may include potential impacts to features such as

  • biological or botanical resources
  • prime or unique farmland
  • water quality
  • wetlands
  • floodplains
  • navigable waterways
  • water and land resources near an international border.

Review all project alternatives to the same level of detail for potential impacts [ENV – preliminary surveys] to natural resources and perform studies to evaluate the value of, and likely impact to, these resources.

Pertinent Project Types. Projects having potential impact to natural resources.

Responsible Party. Environmental coordinator

Helpful Suggestions.

  • Coordinate this work with project manager.
  • The Environmental Affairs Division can provide technical assistance and will provide reviews of environmental documentation.
  • Geographic Information System (GIS) is a helpful tool in conducting natural resource studies, especially for alternatives on new alignment. The Technology Services Division can assist in using GIS.

Critical Sequencing.

  • Conduct natural resource studies as soon as there is reasonable assurance that all project alternatives have been identified. More detailed study and the report can be generated as soon as the preferred alternative has been identified.
  • A right of entry (see 2150: Obtain right of entry) or other written evidence of permission must always be obtained before entering private property.

Authority Requirements.

Resource Material. TxDOT Environmental Manual

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3260: Conduct cultural resources study

Description. The cultural resources study documents archeological or historical resources (see the Environmental Manual) within the project area that may be affected by project alternatives. The study should indicate whether resources within the project area are identified and assessed in accordance with Section 106 of the Historic Preservation Act of 1966, as amended. Historical properties are assessed for their existence on, or eligibility to be on, the National Register of Historic Places (NRHP). The cultural resources report presents and discusses findings of the archeological and historical resources study, and it proposes mitigation measures for each alternative under consideration. Coordination is conducted with the Texas Historical Commission (THC). Conduct the study on all alternatives to the same level of detail.

Pertinent Project Types. Projects requiring additional right of way or work in undisturbed areas of existing right of way.

Responsible Party. Environmental coordinator

Helpful Suggestions.

  • A thorough review of findings with the roadway design engineer is recommended for efficiently developing project alternatives.
  • Coordinate the study and document development with THC.

Critical Sequencing.

  • Conduct the study as soon as there is reasonable assurance that all project alternatives are identified. More detailed study and reports can be generated as soon as the preferred alternative is identified.
  • A right of entry (see 2150: Obtain right of entry) or other written evidence of permission must always be obtained before entering private property.

Authority Requirements.

Resource Material.

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3270: Prepare Section 4(f) evaluation

Description. A Section 4(f) evaluation describes the project impacts to a Section 4(f) property (see 3050: Identify potential Section 4(f) properties), alternatives and mitigation measures. Perform an evaluation in accordance with Section 4(f) of the U.S. Department of Transportation Act of 1966 (see the Environmental Manual) if the project may affect an area identified as a Section 4(f) property. For a draft Environmental Impact Statement (EIS), prepare the evaluation for all alternatives. For a final EIS, prepare the evaluation for only the preferred alternative.

Pertinent Project Types. Projects affecting a Section 4(f) property.

Responsible Party. Environmental coordinator

Sub-tasks.

  • Coordinate with project manager.
  • Obtain alignment map.
  • Determine with jurisdictional authority whether Section 4(f) site is significant.
  • Identify and develop alternatives to eliminate or minimize impact to Section 4(f) properties.
  • Prepare draft Section 4(f) report.
  • Obtain approval of draft report from the Environmental Affairs Division.

Helpful Suggestions.

  • All reasonable alternatives to eliminate or minimize impacts to Section 4(f) properties must be exhausted before selecting a preferred alternative that affects a Section 4(f) property.
  • Work with the project manager and the roadway design engineer to minimize impacts.
  • A Section 4(f) evaluation may be included in the environmental document, or it may be a stand-alone document.

Critical Sequencing. Section 4(f) evaluations should be conducted as soon as there is reasonable assurance that all project alternatives are identified.

Authority Requirements.

Resource Material. TxDOT Environmental Manual

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3280: Perform hazardous materials assessment and investigation

Description. Soil and groundwater contamination from hazardous substances and petroleum products is often encountered on transportation projects. Also, some projects may generate hazardous materials. For example, projects with structures (enhancement or bridge projects) may involve asbestos containing materials and/or lead-based paint requiring testing and analysis during project development. An initial site assessment (see the Environmental Manual), (Phase I Environmental Site Assessment (ESA) is performed to identify possible or known contamination sources. Results of an initial site assessment may be used to determine applicable regulatory requirements before, during, or after construction. Additional environmental site investigation(s) (Phase II ESA) may also be required.

Pertinent Project Types. All projects

Responsible Party. Environmental coordinator

Sub-tasks.

  • Coordinate with project manager and right of way staff.
  • Perform initial site assessment including
    • 1010: Performing a site visit and field surveys
    • researching land use
    • reviewing regulatory database and files
    • interviewing appropriate individuals.
  • Determine need, scope, and schedule for further investigation.
  • Contact the Environmental Affairs Division for project specific guidance, if needed.
  • Request a work authorization from the Contract Services Offices if consulting services from the statewide environmental engineering contracts are needed.
  • Conduct or manage consultants to perform environmental site investigation(s) for contamination that will be encountered by the preferred alignment – both horizontal and vertical.
  • Coordinate findings with property owners, potentially responsible parties, regulatory agencies, and local government authorities.
  • Determine regulatory requirements – such as for handling and disposing material.
  • Determine considerations for right of way (ROW) acquisition and design.
  • Monitor progress and make arrangements for handling contamination if required.

Helpful Suggestions.

  • The project-specific requirements for each component of an initial site assessment can be based on the preliminary design and right of way requirements.
  • Coordination with regulatory agencies or negotiation with potentially responsible parties to determine responsibilities for additional investigation, corrective action, and closure should be conducted before right of way acquisition.
  • Environmental site investigations should be considered for the preferred alignment if results of the initial site assessment show significant contamination likely exists within the project’s ROW existing and proposed), or outside ROW (easement areas) and will likely be disturbed during construction.
  • Generally, TxDOT is not required to perform environmental site investigations for areas within the existing ROW that will not be disturbed during construction or maintenance activities.

Critical Sequencing.

  • Initial site assessments should be conducted as soon as there is reasonable assurance that all project alternatives are identified.
  • Environmental site investigations may be conducted, if determined necessary, as soon as the preferred alternative is identified.
  • A right of entry (see 2150: Obtain right of entry) or other written evidence of permission must always be obtained before entering private property.

Resource Material. TxDOT Environmental Manual

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3300: Prepare socioeconomic/environmental justice analysis

Description. Study socioeconomic issues to determine project impact on the human environment. These issues may include concerns such as

  • land use
  • urban growth patterns
  • community/neighborhood cohesion
  • business impacts
  • property values
  • access to public facilities.

Perform a socioeconomic analysis (see the Environmental Manual) on each project alternative. Assess the extent that alternatives may adversely impact disadvantaged communities or minority populations. In the environmental justice analysis, (see the Environmental Manual) consider the degree that each environmental resource may be impacted by each alternative. Socioeconomic and environmental justice issues should be considered when evaluating project alternatives.

Pertinent Project Types. New construction and reconstruction projects.

Responsible Party. Environmental coordinator

Helpful Suggestions. The Environmental Affairs Division can assist in developing studies.

Authority Requirements.

  • TxDOT Executive Order 12898: Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations
  • Uniform Relocation Assistance and Real Properties Acquisitions Act (the “Uniform Act”), 42 USC §§4601-4665
  • 23 CFR 771.

Resource Material.

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3310: Determine right of way relocation impacts

Description. The Uniform Relocation Assistance and Real Properties Acquisition Act (the “Uniform Act”) of 1970 requires relocation advisory services and payments to eligible displaced individuals, families, businesses, farms, and non-profit organizations. Identify potential displacees, and the relevant circumstances surrounding displacement in environmental documentation as right of way relocation impacts (see the Environmental Manual) for all alternatives. Determine relocation impacts while developing the schematic.

Pertinent Project Types. Projects involving displacement of individuals, families, businesses, farms, and non-profit organizations.

Responsible Party. Environmental coordinator

Authority Requirements. Uniform Relocation Assistance and Real Properties Acquisition Act of 1970.

Resource Material.

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3315: Analyze existing environment

Description. This discussion in the environmental document provides a concise description of the existing social, economic, and environmental setting for the area affected by all reasonable project alternatives (see the Environmental Manual).

All socially, economically, or environmentally sensitive locations or features in the project impact area (e.g., neighborhoods, elderly/minority/ethnic groups, parks, hazardous material sites, historic resources, wetlands) should be identified on exhibits and briefly described in the text. This section should also briefly describe the scope and status of the planning processes for local jurisdictions and the project area.

In an Environmental Impact Statement (EIS), this is included as part of the affected environment section. In an Environmental Assessment (EA)/Finding of No Significant Impact (FONSI) or Categorical Exclusion (CE), this is included as part of the impacts section.

Pertinent Project Types. Projects requiring either an Environmental Impact Statement (EIS) or Environmental Assessment (EA), and Categorical Exclusion (CE) projects having social, economic, and environmental features.

Responsible Party. Environmental coordinator

Helpful Suggestions. To save space and communicate effectively, this section of the document should be a single description for the general project area rather than a separate one for each alternative.

Critical Sequencing. This section should be completed as soon as all social, economic, and environmental data is collected and evaluations are made.

Resource Material. TxDOT Environmental Manual

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3330: Conduct noise analysis

Description. When projected noise levels at noise-sensitive receptor sites exceed federal, state, or local guidelines, noise abatement measures must be evaluated. Noise abatement measures typically include traffic management, alignment modifications, buffer zones, insulation of public buildings, and construction of noise barriers.

Elements of a noise analysis include traffic information (existing and future), design information, noise-sensitive receptors, results of field measurements, and computer modeling. The analysis is designed to provide comprehensive information to the public and local government officials.

Pertinent Project Types. New construction, reconstruction (with substantial horizontal or vertical realignment) and all added capacity projects.

Responsible Party. Environmental coordinator

Sub-tasks.

  • Determine the need (see the Environmental Manual) for a noise analysis.
  • Perform the noise analysis according to the TxDOT Guidelines for Analysis and Abatement of Highway Traffic Noise (1996).
  • Prepare noise abatement proposal for preferred alternative if abatement would be feasible and reasonable for impacted receivers.

Helpful Suggestions.

  • Noise workshops may be appropriate to inform the public about a noise abatement proposal or to obtain input regarding a noise abatement proposal.
  • A noise contour analysis may be useful to compare noise impacts of alternatives.

Authority Requirements. 23 CFR Part 772

Resource Material.

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3340: Conduct air quality analysis

Description. An air quality analysis (see the Environmental Manual) needs to be performed for projects in both attainment and non-attainment counties in accordance with the TxDOT Air Quality Guidelines.

The air quality analysis is not conducted for various alternatives. Rather, the analysis is performed for the general project airshed.

Pertinent Project Types. Projects adding capacity, resulting in travel lanes being closer to the right of way line, or having a design year average daily traffic (ADT) of 20,000 or more, require an air quality analysis.

Responsible Party. Environmental coordinator

Helpful Suggestions. Use same traffic data throughout project development.

Resource Material.

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3345: Determine project’s environmental consequences

Description. In this section of the environmental document

  • include the expected beneficial and adverse social, economic, and environmental (see the Environmental Manual) consequences of project alternatives.
  • describe measures proposed to mitigate adverse effects (see: 3390: Prepare environmental mitigation plans).
  • be sufficiently scientific to provide a comparative basis for evaluating alternatives.
  • do not use the term “ significantly” unless the term is synonymous with the Council on Environmental Quality definition and is supported by factual information.

Pertinent Project Types. Projects requiring an environmental document.

Responsible Party. Environmental coordinator

Critical Sequencing. Complete this section as soon as all social, economic, and environmental data is collected.

Resource Material. TxDOT Environmental Manual

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3350: Prepare landscape recommendations

Description. Significant improvements in environmental compatibility as well as increased public support for transportation projects can be achieved by improving the visual and aesthetic quality of the project. Methods that can be used to blend the project with adjacent land use include the following:

  • incorporating architectural features into the design of structures
  • integrating aesthetic elements in the design phase
  • landscaping
  • xeriscaping
  • screening
  • selective clearing and thinning
  • earthwork.

Pertinent Project Types. New construction, reconstruction, and rehabilitation projects.

Responsible Party. Project manager

Sub-tasks.

  • Request the landscape architect perform a visual inspection of the project area and identify visual and aesthetic resources that might be affected.
  • The landscape architect prepares a report identifying the resources and proposing mitigation measures for affected resources.

Helpful Suggestions.

  • Enlist the support and advice of the landscape architect early in project development.
  • Consider clear zone, sight distance, and maintenance requirements when developing the landscape plan.
  • Coordinate planning with local officials to ensure compatibility with local aesthetic planning efforts.

Critical Sequencing. The aesthetic and landscape recommendations are usually developed only for the preferred alternative.

Resource Material.

  • TxDOT Landscape and Aesthetics Design Manual, Chapter 3, Section 3, Prepare Landscape Recommendations (3350)
  • TxDOT Environmental Manual
  • A Guide for Highway Landscape and Environmental Design; 06/30/70; AASHTO Operating Committee on Roadside Development
  • A Guide for Transportation Landscape and Environmental Design; 06/91; by AASHTO Highway Subcommittee on Design – Task Force for Environmental Design.
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3360: Prepare description of project alternatives

Description. The “Alternatives” section (see the Environmental Manual) of the environmental document discusses the range of alternatives, including all “reasonable alternatives” under consideration and ‘other alternatives’ eliminated from detailed study. Reasonable alternatives should include the ‘no-build’ alternative. All reasonable alternatives under consideration in the draft environmental document should be developed to a similar level of detail so that comparisons are fair.

Pertinent Project Types. Projects requiring an environmental document.

Responsible Party. Environmental coordinator

Critical Sequencing. The environmental document’s section containing a description of project alternatives should be developed throughout the environmental documentation phase.

Resource Material. TxDOT Environmental Manual

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3370: Prepare exhibits for environmental documentation

Description. Environmental document exhibits (see the Environmental Manual) are prepared to show existing social, economic, and environmental resources, and potential impacts to these resources. The environmental specialist, drainage engineer, and project manager typically contribute to developing certain exhibits.

Pertinent Project Types. Projects requiring an environmental document.

Responsible Party. Environmental coordinator

Critical Sequencing. Exhibit preparation for the environmental document should be accomplished throughout the environmental documentation phase.

Resource Material. TxDOT Environmental Manual

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3375: Stake areas of potential impact

Description. Once a preferred alignment is selected, limits of potential impact areas should be staked (or flagged) on the ground. These limits are established to gain permitting agency approval of the extent of affected natural resources. Once permitting authority is gained, the limits are surveyed to establish quantifiable impacts. This includes the limits of environmentally sensitive areas such as:

  • wetlands
  • high water marks
  • tidal waters
  • water resources
  • archeological/historical properties
  • critical biological habitat
  • endangered species.

Pertinent Project Types. Projects having potential environmental impacts to areas such as those listed above.

Responsible Party. Environmental coordinator

Sub-tasks.

  • Obtain the alignment map showing the preferred alternative.
  • A right of entry (see 2150: Obtain right of entry) or other written evidence of permission must always be obtained before entering private property.
  • Stake impact areas in the field.
  • Permitting agencies review and approve the staked impact area limits – by review of a report and map or by field visit.
  • After permitting agency approval of limits, surveyors perform a controlled survey of staked areas. Provide surveyors with impact area map.
  • Refine constraints map (see 3030: Collect environmental data) previously prepared and provide impact area limits to the project manager for inclusion on project drawings.

Resource Material. TxDOT Environmental Manual

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3390: Prepare environmental mitigation plans

Description. Preliminary or conceptual plans for mitigating adverse social, economic, and environmental effects (see the Environmental Manual) are developed at this stage and may be included in the project plans and/or specifications. If mitigation work must be completed before highway construction begins, detailed plans and specifications may be prepared at this point. Examples include threatened species relocation; habitat/wetland creation or restoration; work outside the typical highway construction to minimize environmental impacts to nesting birds; and hazardous material/petroleum product cleanup. The plan may be a written agreement to compensate others in order for them to perform mitigation elsewhere.

Pertinent Project Types. Projects requiring environmental mitigation.

Responsible Party. Environmental coordinator

Sub-tasks.

  • Obtain environmental mitigation commitments made to the public and resource agencies.
  • Obtain input from the project manager, drainage engineer, landscape architect, biologist, and archaeologist.
  • Prepare mitigation plan drawings and specifications as necessary.
  • Prepare cost estimates for environmental mitigation measures.

Helpful Suggestions. Regional mitigation for wetland and wildlife impacts has advantages over isolated, smaller-scale environmental enhancements.

Critical Sequencing. The mitigation plan development schedule is usually driven by the permitting process.

Resource Material.

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3420: Process draft environmental document

Description. When the draft environmental document is completed, it should be circulated to the following district staff:

  • right of way section
  • project manager
  • area engineer
  • director of transportation planning and development.

Once district approval is obtained, the document is submitted to the Environmental Affairs Division for approval. A Categorical Exclusion must be approved by the Environmental Affairs Division. Approval by the FHWA (for federal-aid projects) or the Environmental Affairs Division (for non federal-aid projects) of the Environmental Assessment (EA) or Environmental Impact Statement (EIS) must be obtained before a public hearing or affording an opportunity for a hearing.

An EIS is circulated to various stakeholders and interested persons. An EA, on the other hand, is not circulated but is made available for public inspection at various federal, state, and local offices.

Pertinent Project Types. Projects requiring an EA or EIS.

Responsible Party. Environmental coordinator

Sub-tasks. Submit draft document to Environmental Affairs Division for approval.

Helpful Suggestions.

  • If project does not involve federal funds the Environmental Affairs Division is responsible for approval.
  • If the project involves federal funds, the Environmental Affairs Division forwards the document for FHWA approval.

Critical Sequencing. Approval for further processing is needed before advertising for public hearing.

Resource Material. TxDOT Environmental Manual

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