Community Development: Reuse of Urban Industrial Sites (Letter Report,
06/30/95, GAO/RCED-95-172).

Pursuant to a congressional request, GAO provided information on
brownfields, focusing on: (1) the extent and nature of abandoned
industrial sites in distressed urban communities and the barriers
brownfields present to redevelopment efforts; and (2) federal
initiatives aimed at helping communities overcome obstacles to reusing
brownfield sites.

GAO found that: (1) while no national inventory of brownfield sites
exist, states have identified thousands of former industrial sites that
are abandoned and possibly contaminated; (2) although brownfield sites
are usually not contaminated enough to qualify for the Superfund
Program, many offer great potential for redevelopment; (3) although
developers and lenders have been reluctant to get involved with
brownfields due to uncertain liability, governments have created
initiatives, such as offering loans and liability protection, to speed
up redevelopment efforts; (4) brownfield redevelopment has remained
state and local in nature, but federal agencies have begun assisting
local governments to reclaim sites; (5) the Environmental Protection
Agency has provided demonstration grants to help redevelop industrial
properties that were not contaminated or had been cleaned up; (6) the
Economic Development Administration has provided financial support for
brownfield research and has also acquired practical experience from
cleaning up properties it acquired through loan defaults; and (7) the
Department of Housing and Urban Development is implementing several
brownfield projects through its Empowerment Zone and Enterprise
Community program.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-95-172
     TITLE:  Community Development: Reuse of Urban Industrial Sites
      DATE:  06/30/95
   SUBJECT:  Community development
             Hazardous substances
             Urban development programs
             Environmental law
             Liability (legal)
             Urban economic development
             Federal/state relations
             Environmental research
             Industrial wastes
             Industrial facilities
IDENTIFIER:  Superfund Program
             HUD Empowerment Zones and Enterprise Communities Program
             Chicago (IL)
             Boston (MA)
             Union County (NJ)
             Monongahela Valley (PA)
             EPA National Priorities List
             Cuyahoga County (OH)
             Richmond (VA)
             Bridgeport (CT)
             Community Opportunity Fund
             Two Harbors (MN)
             EPA Brownfields Economic Development Initiative
             
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Cover
================================================================ COVER


Report to the Chair, Committee on Small Business, House of
Representatives

June 1995

COMMUNITY DEVELOPMENT - REUSE OF
URBAN INDUSTRIAL SITES

GAO/RCED-95-172

Reuse of Urban Industrial Sites


Abbreviations
=============================================================== ABBREV

  EPA -
  CERCLA -
  EDA -
  HUD -
  GAO -

Letter
=============================================================== LETTER


B-261177

June 30, 1995

The Honorable Jan Meyers
Chair, Committee on Small Business
House of Representatives

Dear Madam Chair: 

Over the last several decades, many communities throughout the nation
have experienced a loss of manufacturing industries.  As a result,
urban areas that once housed such manufacturing and served as major
employment centers now contain vacant, abandoned, or underused
industrial sites.  As urban communities seek to revitalize their
economies and create jobs for their residents, these sites, widely
known as "brownfields," are once again the focus of attention because
of their potential for redevelopment.  One obstacle to redevelopment
is that brownfield sites are often contaminated or perceived to be
contaminated with hazardous substances. 

This report responds to your request for information about
brownfields and federal initiatives to facilitate their reuse. 
Specifically, you asked us to

  determine what is known about the extent and nature of abandoned
     industrial sites in distressed urban communities and the
     barriers brownfields present to redevelopment efforts and

  provide information on federal initiatives aimed at helping
     communities overcome obstacles to reusing brownfield sites. 


   BACKGROUND
------------------------------------------------------------ Letter :1

In many cases, contamination on idle or underused industrial
sites--brownfields--is not identified until the sites are sold or an
environmental accident--such as a toxic substance seeping into
drinking water--occurs.  Once contamination is identified, federal
and state environmental laws and regulations impose potentially broad
pollution cleanup liability.  For example, under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA),
commonly known as Superfund, past or present owners of a site
containing hazardous substances may be liable for cleanup costs. 
Also, each party responsible for cleanup costs may be held liable
under CERCLA for the entire cost of the cleanup.  While the
Environmental Protection Agency's (EPA) policy is to place only the
worst sites on its National Priorities List for cleanup under
Superfund\1 , federal environmental laws--including liability
standards---still apply to sites with lower-level contamination. 
This report explores issues related to redeveloping brownfield sites
with lower-level contamination that are not on the National
Priorities List.  We collected information on state and local
initiatives in Boston, Massachusetts; Union County, New Jersey;
Chicago, Illinois; and Pittsburgh, Pennsylvania, because these cities
were identified by EPA officials and brownfield researchers as having
active site reuse programs. 


--------------------
\1 The National Priorities List is EPA's list of sites designated for
cleanup under CERCLA.  As of December 1994, there were over 1,200
sites on the National Priorities List. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :2

While no national inventory of brownfield sites exists, states have
identified thousands of former industrial sites that lie abandoned
and possibly contaminated.  Since these sites are typically not
contaminated enough to qualify for the federal Superfund's list of
the most seriously contaminated sites, many offer greater potential
to be redeveloped.  However, in part because of far-reaching and
uncertain liability imposed by federal and state environmental laws,
developers and lenders have been reluctant to get involved with
industrial properties.  Faced with this situation, state and local
governments across the nation have created initiatives to speed
redevelopment, such as offering loans for cleanup and changing state
and local laws to protect new purchasers from liability. 

Although the issues related to redeveloping brownfields have remained
primarily state and local in nature, federal agencies--mainly the
EPA, the Department of Commerce's Economic Development Administration
(EDA), and the Department of Housing and Urban Development
(HUD)--have begun assisting local efforts to reclaim sites.  EPA has
provided demonstration grants to three jurisdictions to redevelop
their industrial properties and has recently acted to remove about
25,000 properties that were not contaminated or had been cleaned up
from its national data base of potentially contaminated sites.  EDA
has provided financial support for brownfield research and also
acquired practical experience from cleaning up properties it acquired
through loan defaults.  HUD has developed and is now implementing a
brownfield policy that includes emphasis on the issue through its
Empowerment Zone and Enterprise Community program.  HUD and EPA have
also initiated a joint research project to study several brownfield
issues. 


   CITIES WITH BROWNFIELDS FACE
   OBSTACLES IN REDEVELOPING THEM
------------------------------------------------------------ Letter :3

While the precise magnitude and severity of brownfields is unknown
because there is no national inventory, the cities we visited had
hundreds of acres of brownfields.  In trying to redevelop
brownfields, local governments and community organizations have faced
reluctance on the part of lenders and developers who fear having to
pay for costly environmental cleanups.  To overcome this obstacle and
others and to speed redevelopment, state and local governments have
created a variety of initiatives. 


      THE NUMBER OF UNUSED
      INDUSTRIAL SITES IS LARGE
---------------------------------------------------------- Letter :3.1

State and local governments have estimated that they have thousands
of vacant industrial properties that could be redeveloped.  In 1987,
we estimated that anywhere from about 130,000 to over 425,000 sites
throughout the nation contain some contamination.\2 This estimate
includes many vacant industrial sites.  Our visits to the four states
confirmed the existence of numerous former industrial sites that were
once productive but now sit abandoned and probably contaminated: 

  The state of Illinois has estimated that 5,000 abandoned or
     inactive industrial/commercial sites exist throughout the state. 
     In Chicago alone, an estimated 18 percent of the industrial
     acreage is unused.  This estimate includes 1,500 acres spread
     among 2,000 sites. 

  One Boston neighborhood, located around Dudley Street, covers just
     1-1/2 square miles but has within its boundaries 54
     state-identified hazardous waste sites. 

  A regional planning group study of Union County, New Jersey,
     identified 185 separate sites containing more than 2,500 acres
     of reusable land in the county, all zoned for commercial or
     industrial development. 

  Towns throughout the Monongahela Valley in Pennsylvania, once a
     major steel-making center, contain hundreds of acres of land
     filled with vacant steel mills and other manufacturing
     facilities. 


--------------------
\2 Superfund:  Extent of Nation's Potential Hazardous Waste Problem
Still Unknown (GAO/RCED-88-44, Dec.  17, 1987). 


      FEAR OF CLEANUP LIABILITY
      HAS SLOWED REVITALIZATION
      EFFORTS
---------------------------------------------------------- Letter :3.2

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. 

Lenders, environmental attorneys, local officials, and community
development officials in the areas we visited and the documents we
reviewed reported that the general uncertainty about the costs of
environmental cleanup and who will pay those costs has delayed the
redevelopment of industrial properties.  A lending official with a
large Pittsburgh-based bank, for example, stated that little
redevelopment has occurred on the former steel mill sites because of
environmental concerns.  In some cases, the bank has chosen not to
foreclose on properties because it does not want to assume cleanup
and associated liabilities.  Furthermore, some owners have preferred
to keep properties idle rather than sell them and take the risk that
the environmental assessments required upon sale will detect
contamination that they will have to clean up. 

A January 1995 EPA action agenda on brownfields stated that the fear
of contamination and its associated liability has left many investors
wary of buying properties that may be contaminated and is enough to
stop real estate transactions from moving forward.  In its local
strategic plan, EPA's Chicago Regional Office further concluded that
lenders are often unwilling to provide loans for property that could
be contaminated because they are concerned about their own liability,
the reduced collateral value of the land if it is found to be
contaminated, and the ability of the property owners to repay a loan
if they must also pay for a major cleanup. 

A variety of interest groups has also concluded that the potentially
large and uncertain liability thwarts efforts to revitalize
communities.  For example, the U.S.  Conference of Mayors has adopted
the brownfield issue as one of five priority areas and has publicly
endorsed EPA's efforts to reduce the fear of and uncertainty about
cleanup liability.  The National Association for the Advancement of
Colored People testified before the Congress in June 1994 that
liability concerns have impeded the efforts of communities to clean
up brownfield sites.  Furthermore, the Mortgage Bankers Association
of America has concluded that the redevelopment of potentially viable
properties has been obstructed by concerns in the commercial real
estate market that lenders will be held liable for environmental
contamination that they did not cause. 

Rather than face the uncertain liability and potential delays
associated with an old industrial site, businesses have looked to
greenfields--previously undeveloped sites in rural and suburban
areas--for expansion and new development.  This trend, according to a
regional EPA official, has contributed to suburban sprawl and leads
to increased congestion and air pollution.  Furthermore, such
development requires the construction of new infrastructure and
results in reduced tax bases and employment in traditional urban
centers, according to state officials and community development
practitioners. 

In addition to the fear of and uncertainty about the costs of
environmental cleanups, other factors have also contributed to the
slow pace of brownfields' redevelopment.  City and state officials
and community development practitioners told us that, often, unused
industrial sites have infrastructure weaknesses (e.g., poor
transportation access), are perceived to be areas of high crime, and
have a general unattractiveness that reduce their redevelopment
potential. 


      STATE AND LOCAL GOVERNMENTS
      ARE RESPONDING WITH
      INITIATIVES TO ENCOURAGE
      REDEVELOPMENT
---------------------------------------------------------- Letter :3.3

Wanting to revitalize their communities and yet fearing environmental
cleanups, state and local governments and community groups have
responded with a variety of initiatives.  These efforts address those
state laws and regulations that appear to hinder redevelopment.  For
example, some of the provisions provide covenants not to sue so that
innocent purchasers are protected from liabilities, some clarify the
lender's liability, and others seek to streamline the states'
regulatory processes.  A few even provide seed money and loans for
cleanup and redevelopment. 

In Massachusetts, for example, the legislature changed environmental
laws to make it clear that a lender does not automatically become
liable for environmental cleanup when it forecloses on property,
according to state officials.  The state law also authorizes state
officials to take into account future uses of the site and
surrounding areas in determining the appropriate cleanup level.  And,
among other things, for economically distressed target areas, under a
pilot program Massachusetts will provide a covenant to new property
owners:  The state will not sue new owners who have followed the
procedures of the state's voluntary cleanup program.  This provision,
it is hoped, will reduce some property owners' and lenders' fear of
liability for contamination identified in the future. 

New Jersey recently made some similar legislative changes with the
Industrial Sites Recovery Act and the Lender Liability Act.  One
component is a $55 million hazardous site remediation fund to provide
grants and low-interest loans for assessing and cleaning up sites. 
Also, the state participated in a model industrial site redevelopment
project in Union County that identified numerous sites having less
contamination and more development potential than most officials had
thought. 

Local governments and neighborhood groups, working with other
stakeholders, have also been trying to overcome obstacles and spur
redevelopment.  For example, officials in Chicago have recognized
that if cleanup is not coupled with redevelopment, sites are likely
to be recontaminated through illegal dumping.  The city has worked
closely with state and federal environmental protection agencies in
assessing and cleaning up five demonstration brownfield sites.  The
project has received $2 million in city funds for the sites, several
of which have specific redevelopment plans. 

In Boston, the Dudley Street neighborhood has been working to
overcome the negative impact of years of industrial contamination.  A
community group, with the help of city officials, was recently
successful in getting a private developer to build a supermarket and
shopping center on a large former industrial tract.  Not only does
this shopping center provide essential services for community
residents, but its success has caused adjacent vacant lots to become
more economically viable. 


   FEDERAL EFFORTS ARE TARGETED
   TOWARD REDEVELOPING BROWNFIELDS
------------------------------------------------------------ Letter :4

As state and local governments have shown increased interest in
redeveloping their industrial sites, several federal agencies have
begun to help them.  Both EPA and EDA have gained practical
experience through redevelopment activities at several sites, while
HUD has started a series of projects to carry out its brownfield
strategy.  In addition, the agencies have begun to coordinate their
efforts and sponsor joint projects. 


      EPA HAS PROVIDED AID THROUGH
      DEMONSTRATION PROJECTS AND
      ADMINISTRATIVE REFORM
---------------------------------------------------------- Letter :4.1

While maintaining its chief focus on the National Priorities List,
EPA has in recent years become more involved with state and local
governments in efforts to redevelop less contaminated industrial
sites.  In January 1995, the agency announced a multifaceted action
agenda on brownfields, which includes a variety of ongoing, enhanced,
and new initiatives. 

A major element of EPA's agenda is the demonstration pilots funded
under the Brownfields Economic Redevelopment Initiative.  The main
intent of these demonstrations, according to EPA, is to learn how
environmental hurdles can be overcome and urban communities restored. 
The first major project started with the State of Ohio and Cuyahoga
County (Cleveland) in November 1993.  EPA contributed $200,000, which
the county used to identify contaminated areas for cleanup and
redevelopment.  According to the Cuyahoga County Planning Commission,
the project has generated $625,000 in new tax revenues and resulted
in 100 new jobs.  The project also includes plans to consult with
communities surrounding these sites to help decide on future uses. 
Two more cities, Richmond, Virginia, and Bridgeport, Connecticut,
were selected as demonstration projects in 1994, and EPA expects to
select 47 more locations by 1996.  EPA plans to work closely with EDA
to make the transition from the cleanup to the redevelopment stage of
its demonstration projects. 

Another item on EPA's agenda was its announcement that it has removed
from its data base of potentially contaminated sites about 25,000
sites where the agency planned to take no further remedial action. 
According to EPA, many of these sites either were not contaminated,
had already been cleaned up under state programs, or were being
cleaned up; still, potential developers were reluctant to get
involved with them because they remained on EPA's list.  To further
reduce the stigma associated with these sites, EPA officials planned
an outreach program to inform interested parties about the true
status of a purchaser's federal liability in each case. 

To assist in removing liability barriers, the action agenda calls for
EPA to develop a package of reforms to limit liability for brownfield
sites.  As part of this package, EPA is developing guidance that is
intended to expand the circumstances under which the agency will
agree not to hold prospective purchasers liable for preexisting
contamination on a property.  In addition, EPA plans to issue
guidance explaining its policy of not pursuing lenders for cleanup
costs.  EPA is also working to clarify municipal liability so that
local governments will be encouraged to start the cleanup process
without concern for liability under Superfund. 

Aside from the brownfield activities led by EPA's headquarters
offices, several regional offices have formed partnerships with local
governments to work on industrial site redevelopment issues.  EPA's
Region 5 office in Chicago, for example, has developed a strategy
aimed at developing partnerships with key stakeholders, encouraging
voluntary cleanups, promoting broad community participation in the
cleanup processes, and disseminating information to prospective
purchasers and lenders involved in brownfield sites.  EPA has also
loaned staff to local governments to further assist efforts to
redevelop brownfields. 


      EDA'S PROJECTS HAVE PROVIDED
      OPERATIONAL EXPERIENCE
---------------------------------------------------------- Letter :4.2

EDA's involvement in industrial sites' redevelopment has two primary
aspects:  The agency, according to its environmental officer, has had
direct experience in cleaning up and developing its own properties,
and it has sponsored projects to educate and inform state and local
entities about redevelopment issues. 

The agency's direct experience stems largely from loans that EDA
guaranteed in the 1970s and early 1980s to improve industrial
facilities.  When several borrowers defaulted on the loans, EDA
acquired title to the sites and was thus faced with the
responsibility for cleaning them up before they could be sold and
redeveloped.  The sites, which include a 176-acre steel mill in
southeast Chicago and a 22-acre foundry in Two Harbors, Minnesota,
have undergone environmental assessments and are now in the cleanup
phase. 

EDA officials have used this practical experience to help communities
as they attempt to redevelop their industrial sites.  The agency has
provided, among other things, funds for independent research into the
issues related to reusing industrial buildings.  EDA has awarded a
grant to develop and publish a booklet aimed at helping communities
deal with their abandoned industrial sites.  In addition, EDA has
developed a cooperative relationship with EPA on its pilot initiative
concerning brownfields, which has included providing help in
selecting projects and assisting EPA on technical matters. 


      HUD HAS BEGUN SEVERAL
      BROWNFIELD PROJECTS
---------------------------------------------------------- Letter :4.3

While HUD has become active in brownfield issues relatively recently,
it has developed a strategy with several ongoing and planned
components.  The Department's Empowerment Zone and Enterprise
Community program may provide, among other things, opportunities for
the agency to learn and disseminate information on how selected
communities deal with issues related to reusing industrial sites. 
And in addition to its own initiatives, HUD has formed a cooperative
relationship with EPA to pursue research and other mutually
beneficial objectives. 

One of HUD's first major activities in brownfield issues was a
December 1994 conference on "The Relationship Between Environmental
Protection and Opportunities for Inner-City Economic Development."
The meeting, attended by a wide variety of federal, state, and local
officials, researchers, and community development practitioners, was
aimed at advising and informing HUD on programs' obstacles and policy
options associated with reusing industrial sites. 

In 1994, almost 300 communities applied for six federal Urban
Empowerment Zone and 65 Enterprise Community designations that
provide tax incentives.  Empowerment Zones also provide other
benefits to businesses that locate in these economically distressed
communities.  Several cities that received designations in late 1994
included industrial and commercial sites' redevelopment as part of
their Empowerment Zone strategies: 

  Chicago cited its own brownfield program as an element of its
     revitalization plan and listed several "environmental waivers"
     that could speed the cleanup and redevelopment of sites in the
     zone. 

  Boston, which contains an Enhanced Enterprise Community, proposed a
     strategy including plans to redevelop a 175-acre former hospital
     site and create a center for emerging industries at the site of
     a former computer-manufacturing facility. 

  For the two-state Empowerment Zone contained in Philadelphia/Camden
     there is a plan to clean up and redevelop a former oil company
     site with help from Pennsylvania's program to clean up
     industrial sites. 

Another important brownfield project, according to HUD officials, is
a research project sponsored jointly with EPA.  Although the project
started out with HUD, the two agencies have since combined resources
and plan to contract for a study that will explore the reasons why
businesses locate in certain areas.  The study is designed to provide
knowledge that will be useful to both agencies as they look for ways
to help communities redevelop industrial sites. 

HUD officials also told us that brownfield issues are mentioned
specifically in two major initiatives:  HUD's own plan to transform
or reinvent itself and a strategy announced in March 1995 targeted to
achieving environmental justice.  In the reinvention plan, HUD
proposes to consolidate its grants for community economic development
into a single Community Opportunity Fund.  A bonus pool in this
program would be used to give good performers the opportunity to
compete for additional funds for large-scale job creation projects
and environmental cleanup of brownfield sites.  HUD's environmental
justice plan, which is part of a larger strategy approved by the
President, designates brownfields' redevelopment as one of four
priority initiatives. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :5

We requested comments on a draft of this report from EPA, the
Department of Commerce, and HUD.  We met with the Director for
Outreach and Special Projects Staff in the Office of Solid Waste and
Emergency Response, EPA; and the Director of the Building and
Technology Division in the Office of Policy Development and Research,
HUD, to discuss their agencies' comments on our report.  EPA and HUD
generally agreed with the information provided in the report;
however, both agencies said that they had made substantial recent
progress on brownfield issues.  We incorporated information that EPA
and HUD provided us about their new initiatives into the report where
appropriate. 

The Department of Commerce, in written comments that are contained in
appendix I of this report, suggested that we include additional
information on EDA's initiatives.  In response, we added to our
report information about EDA's current activities and partnership
with EPA.  We did not address several other issues raised in the
comments--such as rural brownfields and existing businesses'
relocations--because the issues were beyond the scope of this
assignment. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :6

To determine what is known about the extent and nature of abandoned
industrial sites in distressed urban communities and the barriers
that brownfields present to redevelopment efforts, we reviewed
previous GAO reports on Superfund issues and other reports on the
subject, such as the Northeast-Midwest Institute's report entitled
New Life For Old Buildings and Resources for the Future's report
entitled The Impact of Uncertain Environmental Liability on
Industrial Real Estate Development.  To find out about state and
local initiatives, we visited Boston, Massachusetts; Union County,
New Jersey; Chicago, Illinois; and Pittsburgh, Pennsylvania, because
they were identified by EPA and brownfield researchers as having
active site reuse programs.  While there, we obtained information
from directors of state and local government environmental and
community development efforts, environmental attorneys, developers,
and community development practitioners, such as those at the Jamaica
Plain Neighborhood Development Corporation in Boston and Bethel New
Life, Inc., in Chicago.  We also interviewed public interest group
officials, including the Directors of the Coalition for Low Income
Community Development, the National Council for Urban Economic
Development, and the Urban Land Institute and researchers and
analysts at the Northeast-Midwest Institute, the Environmental
Defense Fund, and Resources for the Future to obtain their
perspectives on the issue. 

To provide information on federal initiatives aimed at helping
communities overcome obstacles to reusing brownfield sites, we
discussed brownfield programs and issues at three federal
agencies--EPA, HUD, and the Department of Commerce--that were
identified by public interest group, state government, or local
government officials as having brownfield programs.  We interviewed
EPA's Director of Outreach and Special Projects, Office of Solid
Waste and Emergency Response, and her staff; HUD's Director of the
Building and Technology Division in the Office of Policy Development
and Research and the Director, Office of Block Grant Assistance, and
their staffs; and the environmental officer and staff in the
Department of Commerce's EDA's Office of Research and Technical
Assistance.  We also reviewed programs' guidance, policy statements,
and reports on the programs at these agencies.  Finally, we also
contacted officials at other federal agencies, such as the Small
Business Administration, the Department of Agriculture's Farmer's
Home Administration, and the Department of Transportation, to
determine whether they had any initiatives under way.  We conducted
our review between November 1994 and May 1995 in accordance with
generally accepted government auditing standards. 


---------------------------------------------------------- Letter :6.1

As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 14 days from the date of this letter.  At that time, we will
send copies to the appropriate congressional committees and
subcommittees, the Secretaries of HUD and Commerce, the Administrator
of EPA, and the Director of the Office of Management and Budget.  We
will also make copies available to others on request.  If you would
like additional information on this report, please call me at (202)
512-7631. 

Sincerely yours,

Judy A.  England-Joseph
Director, Housing and Community
 Development Issues




(See figure in printed edition.)Appendix I
COMMENTS FROM THE DEPARTMENT OF
COMMERCE
============================================================== Letter 



(See figure in printed edition.)


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II

Erin Bozik, Assistant Director
Wendy Bakal
Susan Beekman
Frank Putallaz
Tom Repasch

