Foreign Relations of the United States, 1989–1992, Volume XXXI, START I, 1989–1991

65. Memorandum From Richard Davis of the National Security Council Staff to the President’s Assistant for National Security Affairs (Scowcroft)¹

Washington, December 20, 1989

SUBJECT

• Your December 21 Meeting on START: Resolving the ALCM Issue

You are meeting at 1:00 on Thursday² afternoon with Baker, Cheney, and Powell to discuss START issues. As you know, Arnie has been chairing an off-the-record group to support your discussions. That group has completed an issue paper on ALCMs (Tab 1). Although the paper has not been distributed outside the NSC staff pending your approval, it is likely that the members of the group have prepared their principals to discuss the ALCM issue when they meet with you.

This memo provides our suggestions about how to structure the ALCM discussion and our thoughts about possible negotiating approaches with the Soviets.

Objectives and Stakes

The primary U.S. objective is to maintain the flexibility to deploy large numbers of nuclear ALCMS notwithstanding START limits, and to insulate conventional ALCMs from START constraints. Imposing tight limits on Soviet ALCMs is no more than a secondary priority.

Soviet goals are a mirror image. The primary Soviet objective probably is to constrain the U.S. ALCM force as much as possible. Moscow may be particularly concerned about foreclosing any significant increases beyond the currently planned U.S. ALCM force. The Soviets evidently do not plan to deploy a large ALCM force themselves and therefore do not believe that tight ALCM constraints would significantly limit their actions.

Despite these opposing objectives, the key ALCM issues in dispute—counting rules, range threshold, and distinguishability—are perfect for horsetrading among them. At the same time, there is considerable uncertainty about which side has a greater stake in how the overall ALCM question is resolved. Consequently, there is a wide range of views about how much leverage we can get elsewhere in the negotiations by one or another move on ALCMs, and therefore whether we should try to resolve the ALCM issue in isolation, or as part of a tradeoff involving other START controversies.

Following is an assessment of how our interests are engaged in each of the key ALCM issues.

Counting Rules

We currently plan to deploy 10 to 12 ALCMs on each of 95 B–52Hs for a force of 950 to 1140 deployed ALCMs. These loadings roughly correspond to the counting rules we have proposed in START, i.e., current plans would require little, if any, “discounting.” We therefore could readily agree with the Soviets on a counting rule approach that permitted such an ALCM deployment and that fully accommodated current plans to deploy non-ALCM bombers within START limits.

At issue is (a) how large a potential future increase in ALCMs and/or penetrating bombers we want to protect, and (b) how much we think the Soviets would pay to put a cap on the future size of our bomber/ALCM force. (A table which illustrates the relationship between actual and START-accountable ALCM loadings is attached to the issue paper at Tab 1.) Deep discounts become more attractive to us to the extent we need to increase operational ALCM loadings on B–52s to offset curtailment of the B–2 program. ALCM attributions below 10 per heavy bomber become more attractive to the extent that we want to convert some B–1s to ALCM carriers in addition to the B–52Hs.

Moving from our “attribution approach” in the direction of the Soviet “as equipped” position would require decisions about how to verify such a limit, even if the agreed measures were little more than a fig leaf. Agreeing to some maximum ALCM loading would pose a similar requirement.

Distinguishability

As a matter of principle, we want to exempt conventional ALCMs from START limits (the INF example to the contrary notwithstanding). Two recent “sense of the Congress” resolutions have made the same point and, in doing so, have put down clear markers for the ratification debate. As a practical matter, we know of no firm plans for future conventional ALCMs (i.e., beyond paper designs) that would be limited by START, although there evidently are conceptual studies for several black conventional missiles in the 600–1500 km range. Once again, the issue turns in large measure on what kinds of future options we want to protect in a START treaty whose duration could be 15 years or longer.

A satisfactory resolution of the distinguishability issue should give us some flexibility on the range issue (see below). That is, if conventional ALCMs per se are outside START limits, we do not need a very high range threshold to ensure that they are not constrained. Indeed, we already have signaled to the Soviets that if an acceptable solution on other ALCM issues can be found, we probably could agree on a compromise on the range issue at a 1000 km threshold.

The Soviets have proposed that conventional ALCMs be distinguished from nuclear ALCMs by “on site inspection” but it is far from clear what they have in mind. At the same time, it is important to recognize that the details on how we might move in the direction of the Soviet proposal for OSI can have a substantial impact, particularly with respect to the costs and risks of intrusive inspection. For example, to what extent should we be willing to permit Soviet access to (a) bomber bases, (b) bomber aircraft, including B–2, and (c) ALCMs, including those that have stealthy and other sensitive characteristics?

Put differently, how big a price should we be prepared to pay to reach a compromise with the Soviets on this issue, recognizing that none of these measures would make a major contribution to verification? On the other hand, there are some signs that the Soviets may be tough on distinguishability. Rick Burt believes it could turn out to be an unexpectedly serious stumbling block in the negotiations.

Range

We are interested in a high range threshold (e.g., 1500 km) for three principle reasons: (a) to protect future conventional ALCMs if we cannot prevail on the distinguishability issue, (b) to protect the option of deploying long range theater nuclear ALCMs deployed on tactical aircraft, and (c) to protect the option of deploying long range SRAM-like weapons on penetrating bombers to offset future improvements in Soviet air defenses. Not even a 1500 km threshold would exclude “strategic” ALCMs because cruise missiles launched from stand-off bombers require much longer range to reach their targets.

There currently is one conventional missile, Tacit Rainbow, with a range in excess of 600 km. A range threshold in START of 800 km probably would safely exclude Tacit Rainbow from START limits. As noted above, we do not know of firm plans (i.e., beyond paper design studies) for any other conventional or nuclear ALCMs with ranges in excess of 600 kms. The issue, therefore, is what kinds of future options we want to protect, and how much we think the Soviets would pay for an agreement on a lower range threshold than we have proposed. JCS believes that a 1000 km range threshold would adequately protect capabilities that may be needed in the future.

Conventional Bombers

The Soviets at Wyoming indicated a willingness to exclude about 100 conventional bombers (compared to the U.S. proposal to exclude 115) from the START totals if the U.S. accepted the rest of the Soviet position on ALCMs. Although we clearly were not ready to make that deal, we probably could pocket this Soviet concession at a low price. At the same time, there is a growing question about how much such a right will be worth: budget pressures are steadily dimming the prospects that we can retain anything like 100 dedicated conventional B-52s in the active force, but a treaty provision would permit us to mothball rather than destroy them.

A Possible Approach

The following outlines some tentative bottom lines on ALCM issues which, taken together, describe the boundaries within which Baker could be authorized to make the best package deal he can.

On counting rules, agree to a differential attribution approach that would count B–52s at 10 ALCMs, B–1s and Blackjacks at 12 ALCMs, and Bear–Hs at 6 ALCMs. Such an approach would have the same impact on planned U.S. forces as our current position, but would not penalize the Soviets as much. Additionally, agree to a ban on “MIRVed” ALCMs. If needed to conclude an agreement, agree to a politically binding maximum loading of 20 ALCMs per bomber.

If there is a need to protect the option of deploying substantially more than 130 penetrating bombers, push to count B–52s (and probably B–1s at 8 ALCMs), recognizing that the Soviets probably will insist on major concessions on other issues.

If we are unlikely to expand our ALCM force much beyond the currently planned levels and we can get important Soviet concessions on other START issues, agree to count B–52s as well as B–1s and Blackjacks at 12 ALCMs.

On distinguishability/range threshold, press for Soviet acceptance of the current U.S. position (“distinguishable by NTM”). Agree to a range threshold of 1000 km in exchange. If necessary, accept an 800 km range threshold. Alternatively, agree to carefully circumscribed OSI of non-ALCM carrier bomber bases or of conventional ALCMs (to “confirm” the absence of nuclear ALCMs) in combination with a 1000 km range threshold.

On conventional bombers, press for Soviet agreement to exclude 100 dedicated conventional bombers from START limits, but do not make major concessions on other issues to achieve that agreement.

Tradeoffs with other START Issues

Absent major (and probably undesirable) U.S. concessions on ALCMs, Soviet willingness to make major concessions on other START issues is problematical. There is no strong connection between ALCMs and either non-deployed missiles or telemetry encryption (the other two announced candidates for resolution at the next Ministerial), although some undefined political tradeoffs across these unrelated issues in the context of a “productive” Ministerial always are possible.

It is doubtful that we could get more than minor moves from the Soviets on SS–18s as part of an ALCM deal. An ALCM agreement, however, could provide a convenient vehicle for a political tradeoff with the SLCM issue. Thus, if the Soviets were prepared to accept some variant of our current approach (e.g., politically binding SLCM limits that could be changed at three year intervals combined with future discussions about alternative approaches to SLCM verification), that willingness could be linked to resolution of the ALCM issue.

The major drawbacks of such an approach are that it would require us to be willing to make such changes in our current SLCM position now, and it would make more difficult, if not foreclose, the prospects for more radical solutions to the SLCM issue over the coming months.

Provided agreement could be reached along the lines described above, on balance we would not recommend deferring resolution of the ALCM issue in order to incorporate it into some larger START tradeoffs during the end game.

Bob Blackwill concurs.³

Tab A

Paper Prepared in the National Security Council Staff⁴

Washington, December 18, 1989

ALCMs

U.S. and Soviet Positions

The U.S. has consistently opposed tight constraints on ALCMs and other bomber weapons in START. The original U.S. position did not directly limit these weapons, constraining them only indirectly through an overall limit on the number of heavy bombers. We have argued that bomber forces should not be treated the same as ballistic missiles because they are less destabilizing (i.e., they cannot carry out a short warning first strike), they face formidable Soviet air defenses that would not be constrained by START, and they have far lower readiness rates.

The Soviets have sought constraints on heavy bomber weapons comparable to those on ballistic missiles. In response to stated Soviet concerns, we agreed in 1986 to count ALCMs and other bomber weapons under the 6,000 warhead limit, but only if they were heavily discounted. In establishing this position, the U.S. recognized that the Soviets would have an equal right to exploit the rules. We judged, however, that protecting our flexibility to deploy a large bomber force was more important than constraining similar Soviet capabilities.

Following are significant features of the current U.S. and Soviet approaches:

— Both sides have agreed (under the “Reykjavik counting rule”) to count bombers which carry only gravity bombs and SRAMs as “one” against both the 1600 SNDV and 6000 warhead limits; count ALCM-carrying heavy bombers as one unit against the 1600 SNDV limit; treat all existing long-range air-to-surface cruise missiles as nuclear-armed; provide geographically separate basing for the three classes of bombers (ALCM-carrying heavy bombers, non-ALCM carrying heavy bombers, former heavy bombers).

— U.S. proposes to count ALCM-carrying heavy bombers as 10 warheads against the 6000 warhead limit regardless of actual load or capability. Soviets propose to count bombers as the number of ALCMs for which they are actually equipped, verified by on-site inspections.

— U.S. considers “ALCMs” to include only those air-launched, nuclear-armed cruise missiles with ranges in excess of 1500 kilometers, although we have expressed flexibility to include shorter-range ALCMs if the Soviets agree to other parts of our ALCM proposal. Soviets propose a 600 km range threshold.

— U.S. rejects any numerical limits on future long-range conventionally-armed cruise missiles and proposes to distinguish them from treaty accountable nuclear-armed ALCMs through NTM. Soviets agree that future conventional and nuclear ALCMs can be distinguished, but they propose to do so on the basis of both observable and functionally-related differences. It is not clear what differences would be required to meet these Soviet standards.

— U.S. proposes to limit ALCMs indirectly through rules that attribute a certain number of ALCMs to each ALCM-carrying heavy bomber. We reject any direct limits on deployed or nondeployed ALCMs, as well as any numerical sublimit on heavy bomber weapons under the 6000 aggregate. Soviets propose a limit of 1100 weapons on deployed heavy bombers and a numerical limit on the number of nondeployed ALCMs, to be verified by on-site inspection and continuous monitoring of ALCM production facilities. They have recently informally proposed to eliminate all numerical limits on nondeployed systems (both ballistic and cruise missiles), but would apparently retain the ALCM verification measures and the 1100 bomber weapon sublimit.

— U.S. approach would provide for 115 “former heavy bombers” (i.e. conventional bombers) which would not count against either the 1600 or 6000 limits; the absence of nuclear capability would be verified by on-site inspection. Soviets have recently offered to accept about 100 such bombers if the U.S. accepts other elements of their ALCM/heavy bomber proposal.

Discussion

U.S. and Soviet Objectives. Significant asymmetries in U.S. and Soviet force structures, target bases and technologies underlie the ALCM issue. The U.S. relies heavily on air-breathing systems in its force structure and on advanced technologies, including ALCMs, to maintain the capability to penetrate Soviet air defenses. This emphasis has led us to seek the loosest possible constraints on bombers and ALCMs, consistent with our force plans. Another important consideration in seeking to discount bomber weapons in START is the judgment that the U.S. requires significantly more than the 6000 weapons nominally permitted under START for an effective deterrent (as defined by our ability cover and damage targets). Given relatively greater Soviet reliance on ballistic missiles and the very limited U.S. air defenses, the U.S. has concluded that Soviet ALCMs do not add significantly to the Soviet threat and that tight constraints on Soviet ALCMs are a secondary priority.

In contrast, the Soviet position in START is probably driven primarily by a desire to constrain the U.S. force, and implies relatively modest Soviet requirements for ALCM-carrying heavy bombers. Although the Soviets have agreed to discount bombs and short-range missiles heavily (each non-ALCM bomber counts as only one weapon, regardless of its actual load), they propose to constrain ALCMs through “as equipped” counting rules that are comparable to the standard applied to ballistic missile RVs. The Soviets may be less concerned with current U.S. ALCM capabilities than with foreclosing future possibilities, such as “flying boxcars” loaded with very large numbers of ALCMs or “MIRVed” nuclear ALCMs.

ALCMs in U.S. Forces. Implicit in our planning has been an assumption that weapons on penetrating heavy bombers, heavily discounted, would continue to comprise a significant part of U.S. strategic forces. The impact of near-term defense budget cuts on the size and schedule of the B-2 program, however, may mean that the U.S. will have fewer weapons on penetrating bombers. Thus, in terms of our ability to cover Soviet targets, discounted ALCMs could become more important, but they cannot fully substitute for the B-2.

A related, more general, premise of our START proposal is that U.S. heavy bombers and their weapons, including ALCMs, will remain affordable and effective in the face of Soviet air defenses that would not be constrained in START. Although the U.S. considered air defense limitations early in the negotiations, we have never adopted such a proposal.

ALCMs in Soviet Forces. In resisting constraints on ALCMs, we also recognized that the Soviets would have an equal right to exploit the rules, and that an expanded heavy bomber force may be attractive to them under START ballistic missile warhead limits which will require about a 50% reduction in Soviet RVs. So far, the Soviets appear not to be interested in taking full advantage of the Reykjavik counting rule, since both of the new Soviet heavy bombers will apparently carry ALCMs. Nevertheless, NIE 11–3/8 projects that the Bear H ALCM carrier, Blackjack, and two long-range ALCMs, may nearly triple the number of Soviet heavy bomber weapons by 1995, to well over 2000 weapons, notwithstanding the lower projected production of Blackjack.

Negotiating Precedents. Our position on discounted ALCMs also preserves the negotiating principle that air-breathing weapons should be limited less strictly than ballistic missiles. A decision to accept the Soviet-proposed “as equipped” counting rule for ALCMs in START could limit our ability in the future to negotiate favorable treatment for weapons on heavy bombers, including gravity bombs, SRAMs and ALCMs, as well as SLCMs.

Monitoring. An additional important consideration underlying the U.S. START position is our conclusion that realistic ALCM limits cannot be monitored with any degree of confidence. As a corollary, the U.S. position recognizes that any binding limit at a level lower than the maximum capacity of the entire heavy bomber force could in practice constrain the U.S., but would not preclude a realistic Soviet breakout capability. In order to insulate SRAMs and non-nuclear ALCMs from START limits, we have proposed range threshold and distinguishability rules, even though they cannot be monitored with any confidence. We propose to sidestep the monitoring problem with regard to counting ALCMs deployed on heavy bombers by attributing an assigned number of ALCMs to each ALCM-heavy bomber. This approach—in contrast to the Soviet “as equipped” approach—removes the formal need to verify that ALCM loading limits are not or cannot be exceeded. In the end, however, verification of ALCM limits could be a political issue, especially if the Soviets chose to highlight it.

Stabilizing Reductions. A related premise of the U.S. position is that stability is improved if U.S. and Soviet forces depend more heavily on “slow-flying” heavy bomber forces that are inherently not capable of conducting a short-warning first strike. Under the agreed counting rule for bombs and short-range missiles, both sides will have enhanced incentives to increase their reliance on heavy bombers (notwithstanding the low Blackjack production rate). In addition, the more lenient U.S. proposal on ALCM counting rules could mean up to 1000 additional ALCMs for the U.S., but only 200–300 for the Soviets, given the lower ALCM capacity of their current bombers. The effect of this force restructuring on stability, however, depends in part on the capabilities of the remaining ballistic missile forces, and in part on the continuing inability of heavy bombers and ALCMs carry out short warning strikes. The U.S. position is based on a conclusion that, notwithstanding the deployment of stealth bombers and ALCMs, the warning time and attack coordination uncertainties in heavy bomber forces will remain high enough so that a START agreement that leads to increased reliance on “slow-flying” systems will improve stability.

Range Limits. Flexibility for future U.S. forces has led us to propose a 1500 km range threshold for long-range ALCMs. All shorter-range missiles would be counted under the lenient “one per bomber” Reykjavik counting rule (The Soviets have proposed 600 km). In part this position is designed to protect conventional ALCMs and give us additional negotiating room on the distinguishability issue (see below). In part this position is intended to protect theater and strategic options for extending the range of shorter-range nuclear missiles at some future time to offset improving Soviet air defenses. The U.S. position concludes that these benefits outweigh the corresponding increase in the threat posed by potential Soviet air-to-surface missiles, a conclusion based in large part on the substantial asymmetries in air defenses.

As the range threshold in START is lowered from 1500 km, various U.S. cruise missile options are affected differently. For air-launched cruise missiles carried by heavy bombers, the ALCM range threshold in START does not affect target coverage, since strategic ALCMs are designed to fly to greater ranges than 1500 km. The range threshold could, in principle, affect the maximum range of future shorter-range stand-off missiles carried by penetrating bombers. However, the current SRAM has a maximum range of 60–180 km, depending on its profile, and no currently planned missile of this type will have a range over 600 km.

For air-launched cruise missiles carried by tactical aircraft not constrained by START, the START ALCM range threshold sets the upper boundary on the permitted range that can directly affect target coverage in the theater. Notional launch points in the North Sea, the Mediterranean, and the extreme northern flank suggest that with a 1500 km threshold, over ten times as many potential targets in Europe could be covered as with a 600 km threshold, and with a 1000 km threshold, over five times as many as with a 600 km threshold. There are no U.S. plans at present for nuclear-armed stand-off missiles over 600 km range. There are plans for future conventional stand-off missiles between 600 km and 1500 km range. One such cruise missile, Tacit Rainbow, currently exists, and therefore must be protected by a range threshold of at least 800 km (since all existing types of ALCMs over the range threshold will be treated as nuclear ALCMs). U.S. interest in these longer-range stand-off missiles may grow given prospective improvements in Soviet air defenses.

Nuclear/Non-nuclear Distinguishability. We have also concluded that the value to the U.S. of future long-range non-nuclear ALCM options outweighs the risk that comparable Soviet ALCMs could be converted to nuclear ALCMs. Moreover, the FY 1989 and 1990 Defense Authorization Acts clearly state the sense of Congress that non-nuclear cruise missiles should not be limited. If the range threshold in START is lowered from 1500 km, an increasing number of potential future U.S. conventional ALCM programs would be captured by START limits if they are not protected by a distinguishability rule. Even at a 1500 km threshold, the Long-Range Conventional Cruise Missile (LRCCM) would be captured unless we negotiate a distinguishability rule.

Despite our clear interest in protecting conventional ALCMs from START limits, we have been unable to identify meaningful and monitorable design differences between nuclear and conventional ALCMs. The considerations above have led us to propose an essentially declaratory verification type rule, “distinguishable by NTM,” to differentiate between accountable nuclear ALCMs and non-accountable conventional ALCMs. Soviet incentives to cheat in this area (by covertly deploying ALCMs on non-ALCM carriers), as well as increases in the threat if they do cheat, may be small. This is because the deployment of additional gravity bombs on these bombers, which are permitted by START, would be a more effective option for the Soviets, given the absence of U.S. air defenses.

Conventional Bombers. Flexibility for U.S. force planning has also led us to propose an exclusion from START numerical limits for up to 115 heavy bombers converted for non-nuclear capability. These converted heavy bombers would be subject to an inspection procedure to confirm that they were indeed “converted” according to agreed procedures. However, no such procedures could prevent a realistic breakout capability represented by the re-conversion of conventional bombers to nuclear bombers. The current U.S. position in START concludes that the conventional capability gained by up to 115 “converted” bombers outweighs the breakout threat from Soviet heavy bombers. An additional consideration is whether defense budget cuts make the conversion of older B-52s to conventional bombers more or less attractive.

Options:

Counting Rules

Each of the options below would permit a range of mixes between ALCM carriers and penetrating heavy bombers. The key variable in evaluating alternative U.S. forces is the number of ALCMs assigned to each ALCM carrier. The attached table shows how this variable affects the total number of ALCMs possible in the force.

All of the options would permit at least 1000–1160 ALCMs to be deployed on B–52Hs, at the numerical levels illustrated. In addition, the attribution approaches (options 1 and 2) would permit up to about 1940 ALCMs to be deployed on B–52Hs. Although the B–1B is not currently planned to carry ALCMs (except for the two aircraft that have been converted for the test program), an attribution of 8 ALCMs (see option 2) per B–52 would permit up to about 25 B–1Bs to carry ALCMs, raising the total number of possible ALCMs to about 2440.

1. Attribution at 10 ALCMs per bomber (current U.S. position)

2. Differential attribution negotiated for each type (e.g., 8–12 for B–52 and B–1, 10 for Blackjack, and 6 for Bear H)

3. Fixed discount from as equipped levels (for example 50% of high “as equipped” levels: B–1 and B–52=10, Blackjack=6, Bear H=6–7)

4. As equipped (Soviet position. B–52 and B–1=12, Blackjack=6–12, Bear H=6)

The following additional elements could be considered in combination with any of the options above primarily as a way of making the alternatives more attractive to the Soviets:

– an absolute loading limit of 12–20 ALCMs per heavy bomber

– a ban on “MIRVed” nuclear ALCMs

Range

1. 1500 km (current U.S. position)

2. 1000 km (a “compromise” we have discussed with the Soviets)

3. 800 km (approximately the minimum needed to protect Tacit Rainbow)

4. 600 km threshold (current Soviet position)

Distinguishability

1. Nuclear/non-nuclear distinguishability by NTM only (current U.S. position)

2. Distinguishability with OSI of ALCMs (part of the Soviet position, but they have not said specifically what they mean. Some possibilities include:

a. external visual inspection of ALCMs,

b. radiological sensing for absence/presence of nuclear material,

c. internal examination to confirm specific design features.

3. Distinguishability with OSI of non-ALCM bomber bases to confirm absence of nuclear ALCMs (part of Soviet position)

4. All ALCMs—both nuclear and non-nuclear—above the range threshold are limited (no distinguishability requirement)

Conventional Bombers

1. A certain number permitted outside 1600/6000 limits (115 is U.S. position, about 100 is Soviet position)

2. Counted within the 1600/6000 limits

Illustrative U.S. Force Structures Numbers of ALCMs

(Assumes 95 B-52H and 2 B-1B ALCM Carriers and 1100 Accountable Bomber Weapons)

Actual Bomber Loading	8	10	12	16	20
START
Acc’table Number of ALCMs per Bomber
8
(plus 324 penetrating bombers)	780	970	1160	1550	1940
(plus 1245 penetrating bombers)	9706	12207	14608	19509	244010
10
(plus 130 penetrating bombers)	-	970	1160	1550	1940
12
(plus 95 penetrating bombers)	-	-	1000	1330	1660

1. Source: George H.W. Bush Library, Bush Presidential Records, Brent Scowcroft Collection, Scowcroft Close-Hold Files, Box WI–13, NSC Original Files—IF—Brent Scowcroft Folder #4 [8921239–8921549]. Secret. Sent for information. Sent through Kanter. A stamped notation indicates Scowcroft saw the memorandum.
2. December 21. No minutes were found.
3. Blackwill initialed over his typed name.
4. Secret.
5. Numbers assume that 27 B–1Bs are converted to carry ALCMs. Two B–1Bs have been converted to carry ALCMs in the test program. There are no current plans to convert additional B–1Bs to carry ALCMs. [Footnote is in the original.]
6. Footnote in the original directs to the same text as footnote 5, above.
7. Footnote in the original directs to the same text as footnote 5, above.
8. Footnote in the original directs to the same text as footnote 5, above.
9. Footnote in the original directs to the same text as footnote 5, above.
10. Footnote in the original directs to the same text as footnote 5, above.