Solid Waste and
EPA 500-F-97-156
:y_Response
October 1997
ment Initiative
tosal Guidelines
It
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EPA's Brownfields Assessment
Demonstration Pilots
Introduction
As a part of the Environmental Protection Agency's (EPA) Brownfields Economic Redevelopment
Initiative, the Brownfields Assessment Demonstration Pilots are designed to empower states,
communities, tribes, and other stakeholders in economic redevelopment to work together in a timely
manner to prevent, assess, safely cleanup, and sustainably reuse brownfields. EPA has awarded
cooperative agreements to states, cities, towns, counties, and tribes for demonstration pilots that test
brownfields assessment models, direct special efforts toward removing regulatory barriers without
sacrificing protectiveness, and facilitate coordinated public and private efforts at the federal, state, tribal
and local levels. To date, the Agency has funded 121 Brownfields Assessment Pilots. Of those pilots,
64 are National Pilots selected under criteria developed by EPA Headquarters and 57 are Regional
Pilots selected under EPA Regional criteria.
EPA expects to select approximately 100 additional National assessment pilots by the end of May
1998. States, cities, towns, counties, and federally recognized Indian tribes that have an interest in
environmentally sound redevelopment of brownfields are invited to apply. EPA expects to select a
discreet number of pilots specifically dedicated to federally recognized Indian tribes. The Office of
Solid Waste and Emergency Response (OSWER) will accept applications on a "rolling submissions"
schedule. The deadlines for the new applications for the 1998 assessment pilots are December 15.
1997. and March 23, 1998. Previously unsuccessful applicants are advised that they must revise
and resubmit their applications to be considered for the 1998 National assessment pilot
competition.
Background
Many sites across the country once used for industrial/commercial purposes have been abandoned or
are under-used—some are contaminated, some are merely perceived to be contaminated. A report
from the General Accounting Office (GAO: Community Development, Reuse of Urban Industrial Sites,
June 1995, GAO/RCED-95-172) finds that:
"As states and localities attempt to redevelop their abandoned industrial sites, they have faced
several obstacles, including the possibility of contamination and the associated liability for
cleanup ... This situation is caused largely by federal and state environmental laws and court
decisions that impose or imply potentially far-reaching liability. The uncertain liability has
encouraged businesses to build in previously undeveloped nonurban areas—called'greenfields'
—where they feel more confident that no previous industrial use has occurred."
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The National Environmental Justice Advisory Council (NEJAC) has likewise "determined that there
exists a compelling need to address issues of economic development and revitalization of America's
urban [and rural] communities." The NEJAC has requested that EPA:
"Provide leadership in stimulating a new and vigorous national public discourse over the
compelling need to develop strategies for ensuring healthy and sustainable communities in
America's urban [and rural] centers and their importance to the nation's environmental and
economic future."
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EPA's Brownfields Initiative
EPA defines brownfields as abandoned, idled, or under-used industrial and commercial facilities where
expansion or redevelopment is complicated by real or perceived environmental contamination. EPA's
Brownfields Economic Redevelopment Initiative is an organized commitment to help communities
revitalize such properties both environmentally and economically, mitigate potential health risks, and
restore economic vitality to areas where brownfields exist. Experience gained from the brownfields
assessment pilots, along with partnerships and outreach activities, is providing a growing knowledge
base to help direct EPA's Brownfields Initiative. A clean and healthy environment is not the enemy of
a growing and robust economy. Successful brownfields redevelopment is proof that economic
development and the environment can, and indeed, must co-exist.
EPA's efforts under the Brownfields Initiative can be grouped into four broad and overlapping
categories:
• Providing grants for brownfields pilot projects;
• Clarifying liability and cleanup issues;
• Building partnerships and outreach among federal agencies, states, tribes, municipalities, and
communities; and
• Fostering local job development and training initiatives.
The brownfields assessment pilots (each funded up to $200,000 over two years) test cleanup and
redevelopment planning models, direct special efforts toward removing regulatory barriers without
sacrificing protectiveness, and facilitate coordinated environmental cleanup and redevelopment efforts
at the federal, state, tribal, and local levels. These funds are to be used to bring together community
groups, investors, lenders, developers, and other affected parties to address the issue of cleaning up
sites contaminated with hazardous substances and preparing them for appropriate, productive use. The
pilots serve as vehicles to explore a series of models for states and localities struggling with such
efforts.
These pilots focus on EPA's primary mission—protecting human health and the environment.
However, it is an essential piece of the nation's overall community revitalization efforts. EPA works
closely with other federal agencies through the Interagency Working Group on Brownfields and builds
relationships with other stakeholders on the national, tribal, and local levels to develop coordinated
approaches for community revitalization.
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Guidelines for the Preparation of
Proposals
Funding for the brownfields assessment pilots is authorized under Section 104(d)(l) of the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended,
(CERCLA or Superfund), 42 U.S.C. 9604(d)(l). States, cities, towns, counties, U.S. Territories, and
federally recognized Indian tribes are eligible to apply. EPA welcomes and encourages applications
from coalitions of such entities, but a single eligible entity must be identified as the legal recipient.
Cooperative agreement funds will be awarded only to an officially recognized political subdivision of a
state or federally recognized tribal government.
Through a brownfields cooperative agreement, EPA authorizes an eligible state, political subdivision,
Territory, or Indian tribe to undertake activities that EPA itself has the authority to pursue under
CERCLA sections 104(a) or 104(b). All restrictions on EPA's use of funding cited in CERCLA
section 104 also apply to brownfields assessment pilot cooperative agreement recipients. Brownfields
demonstration pilot proposals should conform to the following guidelines:
• Pilot activities should be directed toward environmental activities preliminary to cleanup,
such as site assessment, site identification, site characterization, and site response or cleanup
planning and design for areas that have an actual or threatened release of a hazardous
substance, pollutant, or contaminant. "Site identification" in this case means the identification
of sites at which such contamination may be an issue of concern. These activities can
encompass administration, outreach to stakeholders, or field work associated with site
assessment, site identification, site characterization, and site remediation planning and design.
• Brownfields pilot funds may be used to assess, identify, characterize, and plan response or
plan cleanup activities at contaminated sites targeted for redevelopment. These funds may
not be used to pay for non-environmental redevelopment activities (e.g., construction of a
new facility).
• All sites targeted in the pilot must present a threatened or actual release of a hazardous
substance or a threatened or actual release of a pollutant or contaminant that may present an
imminent and substantial endangerment. However, brownfields assessment pilot funds are
not intended to be used for activities at any sites listed on CERCLA's National Priorities List.
• Brownfields pilot funds may not be used for actual cleanup or other response activities often
associated with such cleanups (e.g., landscaping and ground-water extraction and treatment).
Cleanup costs should be funded through other means, such as state voluntary cleanup
programs, state government grants, state tax incentive programs, tribal funds, contributions
from responsible parties, and prospective purchaser agreements. EPA does plan to later
provide followup funding to assessment pilots in a cooperative agreement for capitalization
of revolving loan funds for cleanup.
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Brownfields pilot funds may by used for outreach activities that educate the public about
assessment, identification, characterization, or remedial planning activities at a site or set of
sites. However, the outreach should be directed toward obtaining more effective public
involvement and/or environmental assessment and cleanup of hazardous substances,
pollutants, or contaminants at affected sites. These funds may not be used for general
education activities (e.g., grants to schools for development of curriculum).
Brownfields pilot funds may not be used for job training. Support for job training activities
may be available through the Hazardous Material Training and Research Institute, EPA
programs, other federal agency programs, and state, local, and tribal programs.
Brownfields pilot funds may not be used to support "lobbying" efforts of the grantee (e.g.,
lobbying members of Congress, or lobbying for other federal grants, cooperative agreements,
or contracts).
Brownfields pilot funds may not be used for assessment, identification, characterization, or
remediation planning at sites contaminated by petroleum products unless they are believed to
be co-mingled with a hazardous substance, pollutant, or contaminant (e.g., used oil).
CERCL A expressly excludes petroleum from the definition of hazardous substances.
Brownfields pilot funds may not be used to match any other federal funds without specific
statutory authority.
Brownfields pilot funds may be used to develop creative financing solutions (e.g., tax
incentives, revolving loan funds) to brownfields problems. However, federal grant funds may
not be used for fund-raising purposes.
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Evaluation of the Proposals
The National brownfields assessment pilots are administered on a competitive basis. To ensure a fair
selection process, evaluation panels consisting of EPA Regional and Headquarters staff and other
federal agency representatives will evaluate the applications. The evaluation panels will assess how
well the proposals meet the selection criteria outlined below.
Applications must be clear and decisive, strictly follow the criteria, and provide sufficient detail for the
panels to compare the merits of each and decide which application best supports the intent of the pilot
program. Vague descriptions, unnecessary redundancy, and inappropriate use of EPA pilot funds may
reduce the chance of a favorable rating. Applications providing the best evidence of a true need, a
quality project, and appropriate use of funds will have the best chance of being recommended by the
panels. Applicants are encouraged to contact and, if possible, meet with EPA Regional Brownfields
Coordinators (see list on page 16).
The panels' recommendations will be presented to EPA Senior Management for final selection. When
a proposal is selected, applicants will receive a confirmation letter, and the appropriate EPA Regional
Brownfields Coordinator and Regional Grants Specialist will be informed. The applicant then will be
asked to submit a formal cooperative agreement application package. This package will include a
formal work plan that describes the work to be performed, including a Quality Assurance Project Plan,
a final budget, and the required certification forms. When an applicant is a county, municipality, or
tribal consortium, an additional letter of support will be required from the appropriate state, territory,
or Indian tribe as an attachment to the cooperative agreement. The EPA Regional Brownfields
Coordinator and Regional Grants Specialist will work closely with the applicant to process and finalize
the cooperative agreement package.
Applicants with proposals that are not selected will be informed in writing. An applicant may choose
to revise the proposal for submittal by a future deadline announced by EPA at a later date.
EPA's goal is to select a broad array of assessment pilots that will serve as models for other
communities across the nation. EPA seeks to identify applications that demonstrate the integration or
linking of brownfields assessment pilots with other federal, state, tribal, and local sustainable
development, community revitalization, and pollution prevention programs. Special consideration will
be given to Empowerment Zones and Enterprise Communities (EZ/ECs) and communities with
populations of under 100,000.1
'EPA will conduct a special outreach effort to address the unique needs of Indian Tribes.
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Structure of the Proposal
Proposals for brownfields pilot projects should consist of the following sections:
• Cover Page
• Project Overview
• Budget
• Responses to Evaluation Criteria
• Attachments
[1 page]
[3 pages]
[Ipage]
[up to 12 pages]
[as appropriate; please provide an index]
Attachments should be kept to a minimum. Attachments that will be considered during proposal
evaluation are letters of commitment, support, or partnership from other government or private
entities. Examples of attachments that will not be considered during proposal evaluation include
strategies or plans developed for other programs, advertising brochures, newspaper articles,
resolutions, statutes, and videotapes. Information in these types of attachments should be distilled and
incorporated into the responses to criteria.
To ensure fair and equitable evaluation of the proposals, please do not exceed the above, single-sided
page limitations. In addition, all materials included in the proposal (including attachments) must be
printed on letter-sized paper (8V£" by 11") and font sizes may be no smaller than 11 points. Please
submit two copies of your application materials, including attachments, to EPA headquarters. In
addition, please submit one copy of your application, including attachments, to your EPA Regional
Brownfields Coordinator (list on p. 16). - • •
Cover Page
This is intended to identify the brownfields pilot applicant and a point of contact for communication
with EPA. This should be on a single page and in the format of your choice.
1. Project title: this should be as specific as possible.
2. Location: city, county, and state or reservation, tribally-owned lands, tribal fee lands, etc. of
the pilot area.
3. Population of the pilot area (tribal/non-tribal members affected).
4. Applicant identification: the name of the main implementor of the project (e.g., state or local
agency).
5. Project director: the name of the person who is responsible for the project proposal. We will
contact this person if we need further information.
6.
Mailing address of the project director.
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7. Telephone/Fax/E-mail of the project director,
8. Name of the representative of the appropriate political subdivision (Mayor, County
Executive, Tribal President, etc.) if different from the project director.
9. Mailing address of the representative of the appropriate political subdivision or tribal official
if different from the project director.
10. Telephone/Fax/E-mail of the representative of the appropriate political subdivision or tribal
official if different from the project director.
11, Date submitted: the date when the proposal is postmarked or sent to EPA via registered or
tracked mail.
12. Project period: the project period must not exceed two years. When planning the project
period, take into consideration that a final report is due at the end of the project.
13. Community background: statistics on the demographics and employment in the pilot area
(i.e., poverty and unemployment rates).
14. Cooperative partners: give details of the individuals and organizations that have agreed to
participate in the implementation of the project.
Project Overview
The Project Overview is an important opportunity to briefly summarize the overall goals and objectives
of a proposed pilot. Some of the information you provide in the Project Overview will overlap with the
selection criteria. Provide an overview of the following topics:
Background
• Map of brownfields target area(s).
• The background section should be a description of the factual and historical context for the
potentially affected site(s) and community (or communities).
• Discuss the ultimate target or goal of your overall brownfields effort. This may represent
broader goals than those to be attained by an EPA brownfields pilot; however, it will provide
an important context for understanding how EPA brownfields pilot funding might be used.
Goals should be specific, measurable, attainable, realistic, and within a timeframe. Try to be
as specific as possible in detailing the means for measuring success.
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Goals and Objectives ; -
• Discuss the goals of the EPA-funded aspects of your overall brownfields effort. Please refer
to the Guidelines (see page 4) when writing this section.
Project Strategy
• Describe the overall strategy for achieving the goals and objectives.
Budget
• Provide a proposed budget for your project. This should show the distribution of the
demonstration pilot funds, including cost estimates for each of the proposed pilot activities.
A clear and concise budget is a critical element of the package.
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Evaluation Criteria
Your response to each of the following criteria will be the primary basis on which EPA selects or
rejects your proposal for one of the pilots. The proposal evaluation panels will review the proposals
carefully and assess each response based on how well it addresses each criterion.
1. Problem Statement and Needs Assessment
(4 points out of 20)
Effect of Brownfields on your Community or Communities
• Define your community or communities. This definition will be assumed to apply throughout
your response to the criteria unless otherwise noted.
• Characterize the impact of brownfields on your community (or communities) by describing
their extent (size, number, location) and providing specific evidence of their economic and
environmental impacts. Your response should provide clear links between your community's
brownfields and measurable environmental, economic, and social impacts. Maps and
demographic data can be provided as evidence of such impacts.
IB
• Describe the process by which brownfields site(s) have been or will be identified. If specific
site(s) have not been selected yet, describe the process by which the selection will take place.
Value Added by Federal Support
• Describe how you will use the EPA funding provided through the cooperative agreement to
advance your overall brownfields goals and objectives.
• Describe other EPA assistance (technical, legal, enforcement, risk communication, pollution
prevention) that might be beneficial to your program.
• Demonstrate how this cooperative agreement will leverage additional resources, support, or
assistance for addressing brownfields. Describe additional local, state, tribal, or federal
sources of technical, financial, or regulatory support that you intend to access and how an
EPA pilot may help gain that support. (Brownfields assessment pilot fonds may be used in
conjunction with other programs to develop creative solutions to community revitalization
and sustainable development issues as long as the brownfields pilot funds themselves are used
for assessment, identification, characterization, or remediation planning.) Provide any
evidence of commitments of support from outside resources that will depend on, or be
enhanced by, the cooperative agreement with EPA. Evidence can be documented through
letters of support.
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2. Community-Based Planning and Involvement
(6 points out of 20)
Existing Local Commitment
• Provide evidence of your community's or communities' interest in brownfields problems.
Describe your efforts to involve community-based organizations in developing this proposal
Provide a list of the community-based organizations involved and a contact person, phone
number, and brief description of the organization's activities and representation. These
organizations may include, but are not limited to, local citizen groups, environmental
organizations, civic organizations, local business groups and institutions, educational
institutions, and local labor organizations. Evidence of interest can be documented through
letters of support. .
• Describe your efforts to develop partnerships at the local, state, and tribal level with other
stakeholders to ensure appropriate and sustainable cleanup and redevelopment of
brownfields. Stakeholders may include affected public authorities, citizens, responsible
parties, current owners, potential future owners, chambers of commerce, lending institutions,
developers, labor groups, and other organizations interested in brownfields cleanup and
redevelopment.
• Describe the progress that your community has made in the assessment, cleanup, and
revitalization of brownfields.
• Describe creative solutions that your community has made in areas of master-planning,
pollution prevention, and sustainable development, and describe how these solutions link to
brownfields. .
Community Involvement Plan
• Describe your plans for ensuring the future, long-term involvement of your communities.
Describe existing or proposed processes for actively seeking and using their input. Describe
how affected communities will be involved in the selection of sites for the brownfields pilot,
future land-use decisions, and site ownership decisions.
• Describe your long-term plans for communicating technical environmental information to the
public to help clarify consequences and facilitate discussion of activities performed under the
brownfields program. Discuss any special communication needs of under-represented
communities and how you plan to meet those needs, including plans for communicating in
languages indigenous to the community. Describe the expertise available in your area that
you might access, such as risk communication specialists, environmental professionals,
community colleges, translators, technical associations, and other community-based
organizations.
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Environmental Justice Plan
• Environmental justice seeks to rectify the disproportionately high burden of environmental
pollution that is often borne by low income, minority, and other disadvantaged communities.
Describe how these communities have participated in the development of your brownfields
plans and will continue participating in their implementation.
• Describe your plans for ensuring that affected disadvantaged populations benefit
environmentally and economically (directly or indirectly) from the assessment, cleanup, and
reuse of brownfields as proposed in your application. Describe how you plan to ensure that
environmental risks to disadvantaged communities are not increased during assessment and
cleanup or as a result of redevelopment.
• Describe other steps you have taken or plan to take (outside of the brownfields program) to
achieve an appropriate level of environmental quality in disadvantaged communities near
brownfields.
3. Implementation Planning
(6 points out of 20)
Appropriate Authority and Government Support
• Describe the legal authority—for example, state, tribal, or municipal Superfund or voluntary
action/cleanup programs or other local, state, territorial, or tribal regulatory programs—
available for identifying, assessing, and remediating brownfields.
• Provide evidence of support from state, tribal and local environmental, economic
development, and health agencies (including local health departments). Evidence of support
can be documented through letters from these agencies.
Environmental Site Assessment Plan
• Describe your plans to ensure the use of quality environmental sampling and analysis
procedures necessary for sound environmental assessments of brownfields. Describe your
plans for accessing the technical environmental expertise in your state, tribe, or region.
Describe your plans for ensuring implementation of appropriate health and safety measures
during on-site activities.
Proposed Cleanup Funding Mechanisms
• Demonstrate the link between your brownfields assessment program and the eventual cleanup
of contaminated areas by identifying potential sources of funds for cleanup. Funding sources
may include potentially responsible parties, potential purchasers, financial institutions, or
state, tribal, and local funding programs (funds from an EPA brownfields assessment pilots
cannot be used for site cleanup activities). Describe commitments of cleanup funding from
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these and other sources. Evidence of support from these parties can be demonstrated
through letters from their organizations.
Flow of Ownership Plan
Describe the anticipated flow of ownership of brownfields properties throughout the process
of assessment, cleanup, and redevelopment. Potential scenarios for transferring ownership
may include a direct transfer of ownership to a private purchaser or interim ownership by a
public authority, court-appointed trustee, lessor, tribal re-acquisition, or bankruptcy
authority. Describe commitments or interest from potential future owners. Evidence of
commitments or interest from these parties can be demonstrated through letters of support.
Describe the problems, particularly with respect to liability, associated with the ownership
scenario that you anticipate. Describe how you plan to address these problems, including
through partnerships with stakeholders, such as chambers of commerce, business groups and
institutions, and lending institutions.
4. Long-Term Benefits and Sustainability
(4 points out of 20)
National Replicability
Describe the local barriers that you will face in revitalizing brownfields. Describe the
technical and managerial methods, particularly innovative methods, that you plan to
implement to address these barriers and facilitate brownfields cleanup and reuse. Methods
may include master-planning for: environmentally friendly future land use, zoning processes
that incorporate environmental quality, pollution prevention, sustainable development, new
cleanup technologies, environmental awareness training, workforce training and
development, environmental justice planning, or other methods to institutionalize
environmental policies. Describe how any innovative methods will be implemented.
Given the complexity and local nature of the problem, no single plan will be applicable
nationwide, but how you address specific barriers may provide lessons for others with similar
problems. Describe how this project can serve as a model for others to use in addressing
barriers to revitalizing brownfields.
Measures of Success
Describe how assessment, cleanup, and revitalization of brownfields will spur additional
beneficial activity in nearby locations, how site assessment will benefit the community, and
whether a direct health or environmental threat will be mitigated.
Describe your plans for measuring success in achieving your brownfields pilot goals. Please
ensure that your measures of success are specific and linked to the goals established for your
pilot project. Measures of success may include environmental indicators, economic
indicators, institutionalized environmental or communication processes, increased availability
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of previously unavailable facilities, such as parks or recreation areas for commemorative
activities, or other indicators of what you would consider a successful brownfields program.
Describe baseline measures that you have developed or plan to develop for the measures of
success. If baseline measures have not been developed yet, describe how and when you plan
to develop them.
Describe any reports or other deliverables you plan to provide to EPA. as documentation of
your project's progress and success.
Indicate specifically if you are applying for a specially-designated category, such as a tribal
set-aside.
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Schedule for Selecting National
Brownfields Assessment Pilots
To accommodate the interest of states, cities, towns, counties, territories, and Indian tribes in applying
for EPA Headquarters' brownfields assessment pilots, the Office of Solid Waste and Emergency
Response will accept applications on a "rolling submission" schedule. Detailed activity timelines
corresponding to each application deadline are outlined below. For assistance -with your brownfields
assessment pilot applications, please call your Regional Brownfields Coordinator (see list on page
16).
Activity Timeline for December 15,1997, Applications
December 15, 1997 Deadline for applications for first round of EPA 1998 awards.
January 1998 Panels evaluate applications.
February 1998 Announcement of first round of EPA 1998 awards.
Activity Timeline for March 23,1998, Applications
March 23, 1998 Deadline for applications for second round of EPA 1998 awards.
April 1998 Panels evaluate applications.
May 1998 Announcement of second round of EPA 1998 awards.
The applications must be post-marked or sent to EPA via registered or tracked mail by
the stated application deadlines* to:
U.S. Environmental Protection Agency
OSWER Outreach and Special Projects Staff (5101)
401 M Street, SW
Washington, DC 20460
* Applications postmarked after December 15, 1997, will be considered in the second
round of competition.
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EPA Regional Brownfields Coordinators
If you have questions regarding the application, you may call EPA's Superfund Hotliae at 1-800-424-9346 or
your Regional representative presented below:
Regions and States
EPA Region 1
John Podgurski
EPA Region 2
Larry D'Andrea
EPA Region 3
Tom Stolle
EPA Region 4
Mickey Hartnett
EPA Region 5
Jim Van der Kloot
EPA Region 6
StanHitt
EPA Region 7
Susan Klein
EPA Region 8
David Ostrander
EPA Region 9
Jim Hanson
EPA Region 10
Lori Cohen
EPA Headquarters
Myra Blakely
CT, ME, MA, NH,
RI,VT
NJ, NY, PR, VI
DE, DC, MD, PA,
VA,WV
AL, FL, GA, KY,
MS, NC, SC, TN
EL, IN, MI, MN, OH,
WI
AR,LA,NM,OK,
TX
IA, KS, MO, NE
CO, MX, ND, SD,
TJT,WY
AZ,CA,HI,NV,AS,
GU
AK, ID, OR, WA
Address and Phone Number
John F. Kennedy Federal Building
One Congress Street
Boston, MA 02203
Phone (617) 573-9681 Fax (617) 573-9662
290 Broadway
18th Floor
New York, NY 10007
Phone (212) 637-4314 Fax (212) 637-4360
841 Chestnut Building
Philadelphia, PA 19107
Phone (215) 566-3129 Fax (215) 566-3001
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303
Phone (404) 562-8661 Fax (404) 562-8628
77 West Jackson Boulevard
Chicago, IL 60604-3507
Phone (312) 353-3161 Fax (312) 886-0753
First Interstate Bank Tower at Fountain PI.
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
Phone (214) 665-6736 Fax (214) 665-6660
726 Minnesota Avenue
Kansas City, KS 66101-2728
Phone (913) 551-7786 Fax (913) 551-7063
999 18th Street, Suite 500 (EPR)
Denver, CO 80202-2405
Phone (303) 3 12-693 1 Fax (303) 3 12-6071
75 Hawthorne Street, H-l
San Francisco, CA 94105
Phone (415) 744-2237 Fax (415) 744-2180
1200 Sixth Avenue
Seattle, WA 98101
Phone (206) 553-6523 Fax (206) 553-0124
401 M Street, SW (5101)
Washington, D.C. 20460
Phone (202) 260-4527 Fax (202) 260-6606
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