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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, and other stakeholders in economic redevelopment to work
together i:i a timely manner to prevent, assess, safely cleanup, and sustainably reuse
brownfiel Is. EPA has awarded cooperative agreements to States, cities, towns, counties, and
Tribes for demonstration pilots that test brownfields assessment models, direct special efforts
toward re tioving regulatory barriers without sacrificing protectiveness, and facilitate
coordinated public and private efforts at the Federal, State and local levels. To date, the Agency
has fundei 76 Brownfields Assessment Pilots. Of those pilots, 39 are National Pilots selected
under crileria developed by EPA Headquarters and 37 are Regional Pilots selected under EPA
Regional < riteria.
EPA expet ts to select 25 additional National assessment pilots by March 1997. The deadline
for the ne w applications for the 1997 assessment pilots is January 13,1997. Previously
unsuccessful applicants are advised that they must revise and resubmit their applications.
Applications submitted before November 1996 will not be considered for the 1997
National assessment pilots.
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."
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'? 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
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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 define;; brownfields as abandoned, idled, or under-used industrial and commercial
facilities wnere expansion or redevelopment is complicated by real or perceived environmental
contamina ion. EPA's Brownfields Economic Redevelopment Initiative is an organized
commitment to help communities revitalize such properties both environmentally and
economica ly, 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 Brow nfields Initiative. A clean and healthy environment is not the enemy of a growing
and robust economy. Successful brownfields redevelopment is proof that economic
developme it and the environment can, and indeed, must co-exist.
EPA's effor s under the Brownfields Initiative can be grouped into four broad and overlapping
categories:
• Pro1 dding grants for brownfields pilot projects;
• Clai ifying liability and cleanup issues;
• Bui] ding partnerships and outreach among federal agencies, states, municipalities, and
con munities; and
• Post sring local job development and training initiatives.
The brown "ields assessment pilots (each funded up to $200,000 over two years) test cleanup
and redeve .opment planning models, direct special efforts toward removing regulatory
barriers wi:hout sacrificing protectiveness, and facilitate coordinated environmental cleanup
and redeve opment efforts at the federal, state, and local levels. These funds are to be used to
bring toget ler 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 pilot: focus on EPA's primary mission—protecting human health and the environment.
However, i is an essential piece of the nation's overall community revitalization efforts. EPA
works dost ly with other federal agencies through the Interagency Working Group on
Brownfield > and builds relationships with other stakeholders on the national 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 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.
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,
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.
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Brc wnfields 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
no) be used for general education activities (e.g., grants to schools for development of
cuiriculum).
Brc wnfields 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 and local programs.
Brownfields pilot funds may not be used to support "lobbying" efforts of the grantee
(e.j., lobbying members of Congress, or lobbying for other federal grants, cooperative
agi cements, or contracts).
Bn wnfields 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.,
usf. d oil). CERCLA expressly excludes petroleum from the definition of hazardous
substances.
Brownfields pilot funds may not be used to match any other federal funds without
sp< cific 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 or municipality, 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.'
'EPA will conduct a special outreach effort to address the unique needs of Indian Tribes.
6
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Structure of the Proposal
Proposals for brownfields pilot projects should consist of the following sections:
Co/er Page
Prcject Overview
Bu iget
Re: ponses to Evaluation Criteria
Attachments
[1 page]
[1 page]
[1 page]
{up to 12 pages]
[as appropriate; please provide an index]
Attachmei.ts should be kept to a minimum. Attachments that will be considered during
proposal evaluation include maps and letters of commitment, support, or partnership from
other gove rnment 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 type;; 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-side d page limitations. In addition, all materials included in the proposal (including
maps and rther attachments) must be printed on letter-sized paper (SVz" by 11") and font sizes
may be no smaller than 1] points. Please submit two copies of your application materials,
including .ittachments.
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. Prc ject title: this should be as specific as possible.
2. Location: city, county, and state of the pilot area.
3. Pop ulation of the pilot area.
4. Applicant identification: the name of the main implementor of the project (e.g., state or
local agency).
5. Proiect director: the name of the person who is responsible for the project proposal.
We will contact this person if we need further information.
6. Ma .ling address of the project director.
7. TeL :phone/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.
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9. Mailing address of the representative of the appropriate political subdivision if different
from the project director.
10. 1 elephone/Fax/E-mail of the representative of the appropriate political subdivision 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. F'roject 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.
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
• 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.
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.
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 y 3ur 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 B 'ownfields on your Community or Communities
• Def ine your community or communities. This definition will be assumed to apply
throughout your response to the criteria unless otherwise noted.
• Chi racterize the impact of brownfields on your community (or communities) by
describing their extent (size, number, location) and providing specific evidence of their
eco lomic and environmental impacts. Your response should provide clear links
between your community's brownfields and measurable environmental, economic, and
socal impacts. Maps and demographic data can be provided as evidence of such
impacts.
• 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
wit take place.
Value Add:d 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,
pol ution 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, or
federal sources of technical, financial, or regulatory support that you intend to access
anc how an EPA pilot may help gain that support. (Brownfields assessment pilot funds
ma'j be used in conjunction with other programs to develop creative solutions to
community revitalization and sustainable development issues as long as the brownfields
pile t 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 and state 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.
• Etescribe 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 disadvantaged communities and how you plan to meet those
needs. Describe the expertise available in your area that you might access, such as risk
communication specialists, environmental professionals, community colleges, technical
associations, and other community-based organizations.
10
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Environmental Justice Plan
• Envi -onmental 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
inert ased 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)
Appropriafo; Authority and Government Support
• Describe the legal authority—for example, state or municipal Superfund or voluntary
action/cleanup programs or other local, state, Territorial, or Tribal regulatory
prog rams—available for identifying, assessing, and remediating brownfields.
• Prov de evidence of support from state and local environmental, economic
deve opment, and health agencies. Evidence of support can be documented through
lettei s from these agencies.
Environmet.tal Site Assessment Plan
• Desc ribe 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 or region.
Describe your plans for ensuring implementation of appropriate health and safety
meaj ures during on-site activities.
Proposed Cleanup Funding Mechanisms
• Dem ^nstrate the link between your brownfields assessment program and the eventual
clear up of contaminated areas by identifying potential sources of funds for cleanup.
Funding sources may include potentially responsible parties, potential purchasers,
finar cial institutions, or state and local funding programs (funds from an EPA
brow nfields assessment pilots cannot be used for site cleanup activities). Describe
commitments of cleanup funding from these and other sources. Evidence of support
from these parties can be demonstrated through letters from their organizations.
11
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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, 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
• E'escribe 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, or other indicators of what you would consider a successful brownfields
program.
12
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Desc :ibe baseline measures that you have developed or plan to develop for the
meas ures of success. If baseline measures have not been developed yet, describe how
and 'vhen you plan to develop them.
Desc :ibe any reports or other deliverables you plan to provide to EPA as documentation
of your project's progress and success.
13
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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 for 25 National Brownfields Assessment Pilots in
1997*. For assistance with your brownfields assessment pilot applications, please callyour
Regional Brown fields Coordinator (see list on page 16). A detailed activity timeline is outlined
below:
Activiiy Timeline for January 13,1997, Applications
January 13 Application deadline for 25 EPA National Brownfields Assessment Pilots.
January 13-March Panels evaluate applications.
March Announcement of 25 EPA National Brownfields Assessment Pilots
awards.
37 Regional Brownfields Assessment Pilots have been awarded to date. For more information
about Regional Office pilots, please call your Regional representative.
The applications must be post-marked or sent to EPA via registered or tracked
mail by January 13, 1997, to:
U.S. Environmental Protection Agency
OSWER Outreach and Special Projects Staff (5101)
401M Street, SW
Washington, DC 20460
14
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EFA Regional Brownfields Coordinators
If you have qi estions regarding the application, you may call EFA's Superfund Hotline at 1-800-424-
9346 or your Regional representative presented below:
Regions and States
EPA Region 1
John Podgurski
EPA Region 2
Larry D'Anc rea
EPA Region 3
Tom Stolle
EPA Region 4
Barbara Dick
EPA Region 5
Mary Beth Tuohy
EPA Region 6
Stan Hitt
EPA Region 7
Susan Klein
EPA Region 8
David Ostre nder
EPA Region 9
Jim Hanson
EPA Region 10
Lori Cohen
EPA Headqi arters
Katherine C awes
CT,ME,MA,NH, RI,
VT
NJ, NY, PR, VI
DE, DC, MD, PA, VA,
WV
AL, FL, GA, KY, MS,
NC, SC, TN
IL, IN, MI, MN, OH,
WI
AR, LA, NM, OK, TX
IA, KS, MO, NE
CO, MT, ND, SD, UT,
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
100 Alabama Street, SW
Atlanta, GA 30303
Phone (404) 562-8923 Fax (404) 562-8896
77 West Jackson Boulevard
Chicago, IL 60604-3507
Phone (312) 886-7596 Fax (312) 886-2737
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) 312-6931 Fax (303) 312-6071
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) 260-8394 Fax (202) 260-6606
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