United States Office of Water EPA 430/«9-89-005
Environmental Protection (WH-547) May 1989
Agency
ERA Construction Incentive
Guidance
-------
CONSTRUCTION INCENTIVE GUIDANCE
MAY 1989
OFFICE OF WATER
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
-------
SECTION 1
TABLE OF
INTRODUCTION
1.1
1.2
1.3
PURPOSE
BACKGROUND
DISCUSSION
1
1
2
SECTION 2
2.1
2.2
2.3
2.4
2.5
2.6
2.7
CONSTRUCTION INCENTIVE PROGRAM REQUIREMENTS
AUTHORITY 3
APPLICABILITY 3
IMPLEMENTATION PROCEDURES 3
SUBCONTRACTOR PARTICIPATION 4
PARTICIPATION LIMITATIONS 4
CICP REVIEW PROCESS 5
ACCEPTANCE OF CICPS 6
SECTION 3 USE OF THE CONSTRUCTION INCENTIVE CLAUSE
3.1 PURPOSE 7
3.2 THE CI CLAUSE DEFINED 7
3.3 CONTRACTOR'S INCENTIVE 8
3.4 CONTRACTOR'S ROLE 8
3.5 CONTRACTOR'S RISK 8
3.6 PROJECT OWNER'S INCENTIVE 9
3.7 PROJECT OWNER'S ROLE 9
3.8 PROJECT OWNER'S RISK 10
3.9 MODEL CI CLAUSE 10
SECTION 4
4.1
4.2
4.3
SECTION 5
5.1
5.2
5.3
5.4
5.5
5.6
APPENDIX A
APPENDIX B
POTENTIAL SAVINGS
INTRODUCTION 17
ENVIRONMENTAL PROTECTION AGENCY EXAMPLES 18
CORPS OF ENGINEERS EXAMPLES 19
CONTRACTOR MOTIVATION AND GUIDANCE
INTRODUCTION 21
PROGRAM PARTICIPATION BENEFITS 21
CICP OPPORTUNITIES 22
CICP SUBMITTAL 22
CICP INFORMAL NOTIFICATION 24
CICP TRANSMITTAL LETTER 24
REFERENCES 27
CONSTRUCTION INCENTIVE COORDINATORS 29
-------
SECTION 1
INTRODUCTION
i.l purpose
The purpose of this guidance is to encourage the use of the
construction incentive (CD clause in the EPA Construction Grants
Program and the State Revolving Fund (SRF) Program. Applied during
construction, the use of the CI clause is effective in ensuring
that the contractor and the project owner can jointly benefit from
useful changes that reduce construction costs. This guidance
applies to EPA-funded and SRF-funded wastewater treatment faciliti-
es that are to be constructed, renovated, expanded, or improved.
This guidance is intended for use by Federal, State, and local
officials, to explain the use of the CI clause in construction
contracts. It discusses the role of the contractor in the CI
program, and explains the policy and procedures for soliciting and
evaluating construction incentive change proposals (CICPs),
including essential elements that facilitate prompt review and
approval of CICPs.
1.2 Background
The Construction Grants Program was initially authorized and
funded under the Federal Water Pollution Control Act of 1956. In
-------
1978, EPA authorized the use of the CI clause in the Construction
Grants Program, provided that incentive payment limitations imposed
by EPA were not exceeded. During the ensuing ten years, few
project owners used the clause, and even fewer contractors
submitted CICPs. In 1987, in order to encourage project owners to
use the CI clause, and to encourage contractors to submit CICPs
under contracts which include the clause, EPA modified its
limitations on incentive payments for approved CICPs. This
guidance includes an explanation of these modified payment
limitations.
1.3 Discussion
The CI clause offers a mechanism by which construction
contractors can be motivated to apply their construction expertise
to reduce contract costs. This positive motivation is achieved
through substantial monetary incentives for submitting a CICP that
reduces a facility's construction costs, without compromising its
reliability or performance characteristics. The sharing arrange-
ment, contained in the CI clause, is established to encourage
contractor ingenuity and initiative in identifying and challenging
high cost design or specification requirements.
-------
SECTION 2
CONSTRUCTION INCENTIVE PROGRAM REQUIREMENTS
2.1 Authority
Section 212(2)(B) of the Federal Water Pollution Control Act
requires the use of a cost-effective approach to wastewater
treatment projects. This requirement is met by:
a. cost-effectiveness analysis during facilities planning,
b. value engineering (VE) studies during design, and
c. CI clause application during construction.
The basic guidance pertaining to the CI program, which is
contained in this guidance document, reflects only EPA requirements
for the CI program. Many states and municipalities have laws,
regulations, and policies which supplement Federal requirements.
Before including the CI clause in construction contracts, project
owners should ensure that they are in compliance with existing
State and local requirements.
2.3 Implementation Procedures
Project owners may include the CI clause in any construction
bid package where a potential exists for contractor participation
in the CI program. However, the clause may not be added after bids
have been received, due to the potential for collusion between
3
-------
the project owner and one of the bidders, giving the bidder the
unfair advantage of knowing that the CI clause would be added after
the bid opening.
2.4 Subcontractor Participation
Both the prime contractor and subcontractors may participate
in the CI program when the clause is included in the construction
contract, but subcontractor participation must be effected through
the prime contractor, because no direct contractual agreement
exists between the subcontractors and the project owner. Moreover,
sharing arrangements between the prime contractor and subcontrac-
tors are made solely between these parties, and therefore may
differ from the cost sharing provisions of the prime contract,
unless the prime contract specifically requires the contractor to
insert the same CI clause in all subcontracts.
2.5 Participation Limitations
Individuals and firms who have had prior involvement in the
project's design or the project's VE study are not eligible to
participate in the development of a CICP, or to share in any of the
savings resulting from approved CICPs. Furthermore, contractors
should continue the construction work as scheduled while a CICP is
being evaluated. Delays in processing CICPs by the project owner,
the State, or EPA cannot be used as a basis for extending the
completion date of a construction project, unless the project owner
agrees to do so by executing a change order. If the project owner
4
-------
agrees to such an extension, any additional costs incurred by the
project owner (such as the cost of additional resident inspection
services) will usually be unallowable costs under the EPA Construc-
tion Grants Program.
2.6 CICP Review Process
Because technical and cost data for each CICP submitted by the
contractor must be carefully reviewed, the organization that
reviews the CICP must possess the needed expertise and resources
for performing an effective review. When a CICP is submitted by
a contractor in response to the Cl clause, the project owner should
proceed with the following steps:
a. Expeditiously review the CICP in accordance with the time
limit specified by the contractor in the CICP. The
primary review may be performed by the project owner's
own employees (if qualified) , the construction management
firm, the firm providing inspection services during
construction, or the design firm. If the primary review
is not performed by the design firm, the design firm
should also review the CICP, because the design firm
remains legally responsible for design integrity. In
unusual cases, the project owner may request technical
assistance from EPA or from the State. These agencies,
in turn, may request assistance from the U.S. Army Corps
of Engineers (COE) under its interagency agreement with
EPA. When a project owner requests such assistance,
5
-------
the project owner is responsible for distributing copies
of the CICP to the appropriate offices for review.
b. Carefully review the contractor's cost figures. Compare
the pertinent bid items against the engineer's estimate,
to ensure that cost savings are not based on a bid item
that was unbalanced (i.e., artificially high) when bids
were submitted.
c. Review all comments, and when appropriate, call a special
meeting with all concerned parties to resolve any
outstanding comments.
d. Subject to State and/or EPA approval, notify the
contractor in writing of the decision made on the CICP.
e. If the CICP has been approved, in whole or in part,
prepare a deductive change order and follow normal
procedures for change order review and approval.
2.7 Acceptance of CiCPs
Acceptance or rejection of a CICP requires no justification
in the letter to the contractor. When a proposal involves partial
acceptance, or adjustment of the contractor's estimated savings,
justification should be provided for the project owner's estimated
savings. If the project owner modifies a proposed change before
granting approval, such modifications must be fully described in
the letter of acceptance.
6
-------
SECTION 3
USE OF THE CONSTRUCTION INCENTIVE CLAUSE
3.1 Purpose
The CI clause has three basic purposes:
a. to take advantage of a contractor's construction
expertise;
b. to allow contractors to isolate high-cost areas where
viable lower-cost alternatives exist; and,
c. to provide a contractual means for sharing savings that
will accrue from CICPs submitted by contractors.
3.2 The CI Clause Defined
The CI clause is an option that may be included in the
contract documents, if not prohibited by State or local laws. The
CI clause allows a contractor or subcontractor to propose changes
in the project which will:
a. provide at least a $50,000 gross capital savings (a lower
amount may be specified in the CI clause by the project
owner, if it can be demonstrated that a smaller CI
proposal can be cost-effectively reviewed).
b. result in a net life cycle cost (LCC) savings over the
life of the project; and,
c. not reduce the quality or integrity of the project,
including compliance with National Pollutant Discharge
Elimination System (NPDES) or State Pollutant Discharge
Elimination System (SPDES) permit requirements.
7
-------
3.3 Contractor's Incentive
Contractors are in the construction business to make a profit.
The CICP rewards contractors who propose changes without sacrific-
ing the essential functions and characteristics of a treatment
facility. The contractor may not share in any savings resulting
from a decrease in operation and maintenance (O&M) costs, because
no provision is made for such savings in the CI clause. However,
the CI clause offers the contractor an opportunity to receive 55
percent of the net capital savings that accrue from accepted CICPs.
3.4 Contractor's Role
There are may valid reasons why contractors can improve
on the best of wastewater treatment designs. First and foremost,
they are in a better position to keep current on the latest
advances in construction methods and cost of materials. They know
first hand the day-to-day problems involved in the construction of
treatment facilities. They also are in a better position to get
new and innovative ideas from subcontractors and vendors.
3.5 Contractor's Risk
The CI clause encourages entrepreneurship by rewarding
contractors for the financial risks they undertake to develop
CICPs. Entirely voluntary in nature, the clause permits a
contractor to ignore this provision and still perform satisfactori-
ly under the contract. If the contractor chooses to submit one or
more proposals, he risks the investment necessary to prepare and
8
-------
submit CICPs, since he will not be reimbursed for this effort.
Because the contractor is not allowed to delay the construction
schedule for CICP development or for any other reason not approved
by the project owner, he further risks paying liquidated damages
for any delay that may occur as a result of his participation.
3.6 Project Owner's Incentive
There is a powerful incentive for project owners to include
the CI clause in construction contracts - the chance to save
substantial amounts of capital funds, without the need to undertake
an effort to identify sources of potential savings. The construc-
tion contractor will initiate and develop potential cost-saving
ideas, which the project owner needs only to review - a review very
much similar in nature to that performed for other change orders
initiated by the construction contractor.
3.7 Project Owner»s Role
Project owners are encouraged to insert the CI clause in their
construction contracts. Although the CI program is voluntary, the
contractor may participated in the program only if the clause is
included in the original contract documents. The CI clause may not
be added after the bids are received on the project. Where the
CI clause is included in the contract, the contractor can propose
changes in construction techniques or materials at any time after
contract award.
9
-------
Since insertion of the CI clause in the contract does not
guarantee contractor participation in the CI program, it is
important for the project owner to encourage development of ClCPs,
and to assure contractors that the proposals will be processed
fairly, impartially, and expeditiously.
3.8 Project Owner's Risk
The project owner assumes a very minimal financial risk from
using the CI clause, since most costs that result from implementing
accepted CI proposals (redesign costs, net increases in inspection
and testing costs, and the present value of net increases in O&M
costs during the useful life of the project) are deductible from
gross CICP savings, and thus have only a small negative impact on
the LCC of the treatment facility. The costs of including the CI
clause in the approved contract documents, promoting use of the CI
clause, reviewing CI proposals, and processing deductive change
orders are not deductible from gross CICP savings, but these costs
will be a very small portion of a construction project's total
administrative costs.
3.9 Model CI Clause
To assist project owners in implementing the CI program, a
model CI clause has been developed. However, project owners should
review this model clause carefully, and should only use language
10
-------
'which implements this model clause, consistent with State and local
laws, regulations, and court decisions.
I. PURPOSE
This clause defines a "construction incentive change proposal"
(CICP) and establishes the policy and procedures for application
of CICPs.
II. REQUIREMENTS
A CICP is a formal written proposal for a deductive change
order during the construction of a wastewater treatment project.
A CICP must be initiated, developed, and identified as such by the
contractor or subcontractor. A CICP must result in a gross capital
savings of $50,000 or more. A CICP must also result in a net
capital cost reduction, while meeting all of the following
conditions:
1. The total life cycle cost of the project will not increase.
2. The required functions, reliability, and safety of the project
will be maintained.
3. The proposed change will not result in any contract rebidding.
4. The proposed change will not cause undue interruption of the
contract work.
5. The proposed change will be in compliance with all Federal,
State, and local permits and regulations.
11
-------
III. CONTENT
A CICP must contain pertinent information and supporting
documentation for evaluation by the project owner. As a minimum,
the following information must be included:
1. Names of individuals associated with the development and
preparation of the CICP.
2. A detailed description of the present design and the proposed
changes. Clear identification of any advantages and disad-
vantages for each proposed change.
3. A detailed procedure and schedule for implementing the
proposed change. This should include all necessary contract
amendments, as well as the latest date that the CICP could be
approved for implementation, without disrupting the construc-
tion schedule. Normally, at least 90 days should be allowed
for the project owner's review of the CICP.
4. A summary of the estimated costs, including the following:
a. project construction costs before and after the CICP.
This should be a detailed estimate identifying the
following items for each trade involved in the CICP:
l. quantities of materials and equipment.
2. unit prices of materials and equipment.
3. labor hours and rates for installation.
b. life cycle operation and maintenance costs before and
after the CICP;
12
-------
c. costs for implementing the CICP not included in item 4a
above, to the extent that they can be identified by the
contractor (e.g., additional resident inspection
services);
d. contractor's share of the savings, based on paragraph III
below;
e. other data as required in the contract specifications for
change orders; and
f. time required for executing the proposed change.
To the extent indicated below, contractors may restrict the
use of any CICP, or the supporting data submitted pursuant to this
clause, by the project owner and by other Federal, State, and local
government agencies. Suggested wording is provided below:
"The data, furnished pursuant to the construction incentive
clause of contract * shall not be disclosed
beyond that which is necessary to accomplish the review of the
CICP, or duplicated, used, or disclosed, in whole or in part,
for any purpose other than to evaluate ciCPs submitted under
said clause. This restriction does not limit the right of the
project owner, or any Federal, State, or local government
agency, to use information contained in the data if it is or
has been obtained, or is otherwise available, from the
contractor, or from any other source, without limitation. If
13
-------
such a proposal is accepted by the project owner under said
contract, the project owner and all other Federal, State, and
local government agencies shall have the right to duplicate,
use, and disclose such data, in any manner and for any purpose
whatsoever, and to have others do so also."
The project owner may modify, accept, or reject the CICP.
However, if a CICP is modified, or is not acted upon within the
time frame specified in the CICP, the contractor may withdraw the
proposal, in whole or in part. In any event, the project owner
will not be liable for the contractor's cost of developing the
CICP.
When a CICP is accepted by the project owner, the processing
procedure for change orders will be used, except that for a CICP,
a deductive change order, for 45 percent of the net capital
savings, will be processed. (The remaining 55 percent of the net
capital savings will be retained by the contractor.) When a CICP
is rejected, the contractor may not appeal the rejection to any
Federal, State, or local government agency.
IV. SHARING PROVISIONS
Upon acceptance of a CICP, the contractor will share the net
capital savings pursuant to this contract, based on the formula
14
-------
below. computation for the net savings is to be based on the
following formula:
Net capital savings equals initial construction cost less
revised construction cost, and less CICP implementation cost.
The CICP implementation cost shall include the project owner's
cost of redesign, the net increases (but not decreases) in inspec-
tion and testing costs, and the present value (using the EPA
discount rate in effect on the date of grant award or loan
approval) of the net increases (but not decreases) in operation and
maintenance costs during the useful life of the project. However,
change order processing costs incurred by the project owner and the
reviewing agency are not included in the CICP implementation cost.
The contractor's cost for developing the CICP is not an
allowable cost, but is to be offset by a portion of the contrac-
tor's share of the net capital savings.
The contractor will receive 55 percent of the net capital
savings (or a lower amount specified in the contract).
15
-------
SECTION 4
POTENTIAL SAVINGS
4.1 Introduction
Although the CI program has been in existence in EPA since
1978, few project owners have used the CI clause, primarily because
the clause and its potential benefits are not understood by project
owners, and because its use is not mandatory. Similarly, construc-
tion contractors have been unfamiliar with the incentive provisions
where the clause was included in their contracts. Unfortunately,
if the clause was not part of the contract documents at the time
of bid opening, it could not be added later, even though the
contractors may have uncovered areas for potential CICP savings.
Project owners are encouraged to insert the" clause in all
construction contracts. Once the CI clause has been developed, the
cost to make it a part of the contract is insignificant, while the
potential savings can be quite significant. For example, COE
savings from the use of incentive clause provisions during the last
four fiscal years were $31.6 million. During this period, the COE
received a total of 2,086 proposals and approved 1,358 proposals,
which is 65 percent of the proposals received.
17
-------
4.2 Environmental Protection Agency Examples
The following examples represent CICPs submitted by contrac-
tors and accepted by project owners for EPA-funded construction
projects:
a. A CICP in Camden County, New Jersey resulted in a 1.6
percent capital savings through realignment of portions
of an interceptor sewer to avoid construction near
overhead power lines. Because of the extreme caution
required when working near power lines, the new alignment
enabled the contractor to work more rapidly. Net savings
to the Camden County Municipal Utilities Authority
equaled $220,014.
b. A CICP in Keokuk, Iowa produced capital savings of 1.3
percent through structural design modifications. The
modifications included:
(1) Replacement of drilled piers with driven steel
pilings;
(2) Substitution of lightweight vermiculite
concrete with a structural cap for standard
concrete fill; and
(3) Grit channel modification instead of demolition
of existing concrete.
Net savings to the City of Keokuk equaled $104,961.
c. A CICP for an outfall for the Hampton Roads Sanitation
18
-------
District in Virginia Beach, Virginia resulted in a 1.5
percent capital savings through the use of a Hydro-Pull
Method instead of a draw bolt assembly for joining
prestressed concrete pipe. Net savings to the Hampton
Roads Sanitation District equaled $44,975.
4.3 Corps of Engineers Examples
The following examples illustrate change proposals submitted
by contractors and approved by the COE:
a. A contractor proposed increasing the maximum weight of
stones used in dike construction from 550 pounds to 5,000
pounds, which reduced the total contract cost by
$148,000. The 5,000 pound stone constitutes a standard
maximum weight for dike construction.
b. A contractor proposed using 2-inch wood chips instead of
gravel to construct a walkway in a public recreation
area, which reduced the contract cost by $63,000.
c. In constructing the roof of a building, a contractor
proposed using elastomeric roofing material in lieu of
polyvinyl chloride (PVC) single-ply roofing, which
reduced the cost of construction by $22,000.
19
-------
SECTION 5
CONTRACTOR MOTIVATION AND GUIDANCE
5.1 Introduction
The success of the CI program depends on motivating contrac-
tors to develop innovative ideas and to submit CICPs. Their basic
incentive is the monetary share of the savings that they receive
when the CICP is accepted, but more use of the CI clause does not
of itself ensure success. Project owners should encourage
contractors by highlighting the fact that their contract contains
a CI provision, and that the project owner is receptive to
receiving and approving proposals that reduce the contract cost
without reducing the quality or changing the design characteristics
of the facility. A successful program requires a cooperative
effort by the project owner and the contractor.
This section is intended to give project owners a concise
source of information needed to gain contractor acceptance of the
CI program. If project owners understand the basic needs of their
contractors, they will be more likely to gain their confidence and
encourage the development of CICPs.
5.2 Program Participation Benefits
The most obvious tangible benefit derived from contractor
participation in the CI program is the share of savings that accrue
21
-------
from CICP approvals. The savings represent an increase in the
contractor's return on investment in contract performance.
In addition to their share of savings from implemented CICPs,
contractors who develop and submit CICPs gain an advantageous
competitive edge over other contractors by constructing facilities
at lower cost; hence, they gain a reputation as cost-conscious
contractors.
5.3 CICP Opportunities
Although a CICP may be submitted at any time after contract
award, a proposal originated soon after contract award tends to
produce greater savings. Early CICP submittal allows sufficient
time for review and approval by the project owner, permits
proposals to be submitted on all phases of construction, and
facilitates acceptance of new and improved components or subsystems
that require testing and/or evaluation prior to acceptance.
Consequently, during pre-award and post-award contractor conferen-
ces, project owners should not only highlight the fact that the
proposed contract contains the CI clause, but also stress the value
of early CICP submittal.
5.4 CICP Submittal
The probability of CICP acceptance can be increased by the
effort the contractor expends in its preparation. First and
22
-------
foremost, the proposal should contain sufficient information to
answer all reasonable questions that an evaluator may have. To
avoid delays in processing because of insufficient information or
the appearance of inadequate investigation, each CICP should:
a. Be complete. The CICP should present the proposal to the
evaluator in a clear and concise manner. Although no
forms are required to submit a proposal, the recommended
format contained in paragraph II of the model CI clause
should be followed, to enhance the evaluator's ability
to make a positive decision regarding the proposal.
b. Provide technical supporting data. Supporting data should
include the benefits and risks to the project owner,
tolerances, operating manuals, test data, LCC impact, and
previous uses of the proposal. This type of data is most
beneficial to the evaluator. In particular, test results
and a description of the tests performed are of sig-
nificant value in gaining acceptance of new methods or
materials.
c. Sell the proposal. An oral presentation should be offered
by the contractor, through the project owner, to the
technical evaluator. This approach is particularly valid
if the CICP is a high dollar value proposal and/or
presents a significant departure from current technology.
d. Provide a detailed cost analysis. In addition to "before
and after" costs for the proposed change, the contractor
23
-------
should address any potential LCC benefits, as well as any
intangible benefits (such as increased reliability) that
may accrue if the CICP is accepted.
5.5 Informal Notification
Rather than risk significant funds to develop, prepare, and
submit a formal CICP, contractors may informally notify the project
owner that they intend to submit a proposal having a major impact
on the wastewater treatment process or on the total cost of the
construction contract. The project owner may then informally tell
the contractor whether the proposal should be pursued or dropped.
At the same time, the contractor should be informed that a positive
response by the project owner does not ensure that a formal CICP
will be accepted. Also, unlike the formal CICP, informal dis-
closure does not establish the contractor's rights to the proposal
or to supporting data.
5.6 CICP Transmittal Letter
Although the contractor is not required to submit a transmit-
tal letter, it is a good marketing tool that improves the rapport
between the project owner and the contractor, speeds up the
evaluation and acceptance process, and increases the probability
that the proposal will be accepted by the project owner. At a
24
-------
minimum, the letter should contain the following items:
a. a statement that the CICP is being submitted in accor-
dance with the CI provisions of Contract # - •
b. a summary of the proposed change, including the proposed
change in the contract amount and the total net capital
saving expected if the CICP is approved;
c. any additional advantages that may be derived as a result
of the change, including intangible benefits; and
d. the contractor's point-of-contact for questions that may
arise during proposal evaluation.
25
-------
APPENDIX A
REFERENCES
For additional information on project management methodology and
processing of change orders, EPA has several publications available
from its Instructional Resource Center, 1200 Chambers Road, Room
310, Columbus, Ohio 43212. Specific ordering information may be
obtained by calling 614-292-6717.
1. Management of Construction Change Orders - A Guide for
Grantees. U.S. EPA, March 1983.
2. Prevention and Resolution of Contractor Claims, U.S. EPA,
March 1985.
3. Management of a Construction Project - A Guide for Grantees,
U.S. EPA, April 1986.
For additional information on the methodology of life cycle
costing, the following book can be obtained commercially through
most bookstores.
4. Life Cycle Costing for Design Professionals, Alphonse J.
Dell'Isola and Stephen J. Kirk, McGraw Hill, 1981.
27
-------
APPENDIX B
CONSTRUCTION INCENTIVE COORDINATORS
Region
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
HQ
Name
William Bulter
Raymond Kvalheim
Bruce Smith
Don J. Cotter
Harold Heavlin
Gene P. Wossum
Gerald Gutekunst
Mohammad Razzazian
Enio Sebastiani
Commercial Phone
617-565-3564
Boston, MA
212-264-7177
New York, NY
215-597-9890
Philadelphia, PA
404-347-3633
Atlanta, GA
312-886-0269
Chicago, IL
214-655-7130
Dallas, TX
913-236-2813
Kansas City, KS
303-293-1551
Denver, CO
415-974-8316
San Francisco, CA
Richard Hetherington 206-442-1941
Seattle, WA
Thomas J. Moran
202-382-7274
Washington, DC
FTS Phone
835-3564
264-7177
597-9890
257-3633
886-0269
255-7130
757-2813
564-1551
454-8316
399-1941
382-7274
29
------- |