NORTH COUNTRY CONSTRUCTORS OF WATERTOWN, INC., WAB No. 92-22
(WAB Sept. 3, 1993)
CCASE:
NORTH COUNTRY CONSTRUCTORS OF WATERTOWN
DDATE:
19930903
TTEXT:
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[1] WAGE APPEALS BOARD
UNITED STATES DEPARTMENT OF LABOR
WASHINGTON, D. C.
In the Matter of:
NORTH COUNTRY CONSTRUCTORS WAB Case No. 92-22
OF WATERTOWN, INC.
With respect to application of the Davis-Bacon
Act to Contract No. DACA51-86-C-0141 (FY 86
Infrastructure Package) Construction of Roads,
Distribution System & Utility Facilities,
Fort Drum, Jefferson County, Watertown, New York
BEFORE: Charles E. Shearer, Jr., Chairman
Ruth E. Peters, Member
DATED: September 3, 1993
DECISION OF THE WAGE APPEALS BOARD
This matter is before the Wage Appeals Board on the petition
of North Country Constructors of Watertown, Inc. ("NCCW"), seeking
review of the November 13, 1992 ruling issued by the Deputy
Assistant Administrator of the Wage and Hour Division. The ruling
in question held that the work of installing underground PVC
electrical conduit, precast concrete electrical manhole structures
and duct bank in Jefferson County, New York was the work of
electricians and that NCCW should have accordingly classified and
paid its employees performing the disputed work. NCCW had
classified and paid its employees as laborers under the wage
determination applicable to the contract. For the following
reasons, the ruling of the Deputy Assistant Administrator is
reversed. [1]
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[2] I. BACKGROUND
A. Factual History
The United States Army Corps of Engineers awarded Contract No.
DACA51-86b-0036 to prime contractor Morrison-Knudsen Company, Inc.
(doing business as Fort Drum Constructors) in May 1986. The prime
contract was for development of the "FY 86 Infrastructure Project,"
under which Morrison-Knudsen was required to construct roadways,
distribution systems for utilities and related utility facilities
at Fort Drum in Watertown, New York.
The prime contractor awarded NCCW a subcontract on June 18,
1986. The subcontract was for construction of the mechanical and
electrical site utilities, including water lines, sanitary gravity
sewers, buried sanitary sewage force mains, underground high
temperature water distribution systems, aerial electrical
distribution system, underground electrical distribution system,
communication system and street lighting, as well as for work on a
sewage pumping station and a sewage treatment plant. The prime
contract and subcontract were subject to and contained General
Wage Decision No. NY86-10, applicable to Heavy and Highway
construction in St. Lawrence, Lewis and Jefferson Counties, New
York.
NCCW commenced performance of its subcontract on or about June
30, 1986. Prior to that time, however, Local 1249 and 910 of the
International Brotherhood of Electrical Workers ("IBEW") initiated
inquiries to certain Congressmen -- characterized by the parties as
a "jurisdictional dispute /FN1/" -- expressing their concern that
their local members perform "the IBEW portion" of the subcontract
work. The IBEW locals also contacted the Corps' contracting
officer, requesting a decision concerning the appropriate
classification and wage rate for work relating to the electrical
conduit and manhole installation.
The Corps conducted an "area practice" investigation regarding
the proper classification for performance of the disputed work.
Among others, the Corps contacted local electrical contractors,
representatives of the IBEW and LIUNA, Local No. 322, and NCCW.
Seventeen contractors responded to the [2]
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
/FN1/ With respect to this aspect of the dispute, the affidavit of
Sam Agati (Business Manager for Laborers International Union of
North America ("LIUNA"), Local 322) was submitted by NCCW. Agati
averred that Article IV of the 1985-1988 Heavy-Highway Agreement
between LIUNA and the New York Chapter of the Associated General
Contractors ("AGC") provides: "that the duties of laborers on
heavy-highway contracts in Jefferson County include the following:
`the laying of all types of pipe and conduit; . . .; and the
placing of all pre-cast and prestressed materials.[']." This is an
accurate representation; a portion of this labor agreement is in
the Administrative Record ("AR") Tab OO, Exhibit I. No written
jurisdictional claim by IBEW has been brought to the Board's
attention by the parties or interested person IBEW Local 910. [2]
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[3] Corps' inquiry; additionally, information was submitted by the
Northern New York Builders Exchange and the AGC, New York Chapter.
NCCW, meanwhile, had proceeded under its subcontract and
classified and paid its employees laying conduit and installing the
manhole fixtures and duct banks as laborers. On December 3, 1986,
the Corps informed the prime contractor of the results of its
investigation, stating that NCCW had "misclassified the
installation of underground conduit and ductbank for electrical
systems as laborers' work, instead of the correct classification,
electricians' [sic]." AR Tab K.
As a result of this classification determination, the Corps
ultimately determined that back wages in the amount of $13,943.10
were due affected employees for the alleged misclassification as
laborers. This amount was withheld from contract payments by the
Corps. Subsequent work -- the "FY 87 project" -- was also
performed by NCCW utilizing the laborer classification. For the FY
87 project, the Corps has also purportedly withheld more than an
additional $50,000 for alleged misclassification and overtime
violations at Wage and Hour's request, based on the 1987 (and
ostensibly) 1990 ruling letters. See AR Tab AA. At all times
during the Corps' and Wage and Hour's investigations, NCCW has
contended the proper classification for the work was that of
laborer and refused to authorize the Corps to disburse the withheld
funds as back wages.
B. Procedural History
On February 18, 1987, the Corps transmitted its investigation
report to the Wage and Hour Division and NCCW requested Wage and
Hour to review the Corps' determination. Additional information
was obtained from IBEW, LIUNA, local construction contractors, and
the AGC. After its review, Wage and Hour informed the Corps on May
20, 1987 that "it was the practice in Jefferson County for
electricians rather than laborers to install manholes, underground
electrical conduit and duct banks during the period." AR Tab R, p.
1.
On June 19, 1987, both NCCW and LIUNA requested Wage and Hour
to reconsider the May 20 determination. On the same day NCCW also
appealed the ruling to this Board, which first stayed consideration
of the petition for review pending a final ruling on the request
for reconsideration; subsequently, the Board -- by Order dated
August 17, 1990 -- remanded the pending case to the Wage and Hour
Division to complete reconsideration. Meanwhile, on July 11 and
December 22, 1989, NCCW requested Wage and Hour to issue its
decision or, alternatively, grant a hearing to resolve the dispute.
NCCW addressed numerous other requests for information or action to
Wage and Hour; however, the record discloses no responses other
than the 1987 and 1992 ruling letters. [3]
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[4] Wage and Hour conducted yet another area practice
investigation in the latter part of 1990. Based on this newest,
third, survey, Wage and Hour stated its conclusion that "employees
who installed manholes, conduit and duct banks on the Fort Drum
infrastructure project should be re-classified and compensated as
electricians in accordance with the contract wage determination. .
. ." AR Tab A, p. 2. Wage and Hour found that "68% of the
employees who installed manholes, underground electrical conduit
and duct bank on projects of a character similar to the Fort Drum
project, were classified as electricians, while only 23% were
classified as laborers (i.e., a ratio of 21 electricians to 10
laborers)." Id. Counsel for Wage and Hour now explains that -- as
a result of a transposition or "clerical" error -- the correct
laborers' statistic was 32%.
The November 13, 1992 Wage and Hour ruling was issued pursuant
to 29 C.F.R. 5.13 and NCCW was notified of its right to appeal the
new determination. On December 10, 1992 the instant petition for
review was filed. IBEW Local No. 910 has participated in this
proceeding as an interested person, filing statements on behalf of
the Wage and Hour ruling and appearing at the oral argument
conducted on July 28, 1993.
II. DISCUSSION
The central question for resolution in this case is not
difficult, i.e., the counting of respective classifications
performing the disputed NCCW work on the project. /FN2/ The Wage
and Hour Division's ruling concluded -- based on the results of the
1990 area practice survey -- that approximately 68% (21 out of a
total of 31 workers) of the survey population were electricians
performing the work similar to that in dispute. However, to make
a proper count of these survey numbers, first resort must be had to
the pertinent statutory requirement and several policies and
procedures utilized by the Wage and Hour Division in conducting
area practice surveys in general and with particular application in
this matter.
The Davis-Bacon Act requires, in part, that contractors and
subcontractors on construction of public buildings and works shall
pay wages to [4]
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
/FN2/ There is no dispute concerning the vast majority of
Petitioner's work on the FY 86 project, which entailed the
construction of 28,500 feet of high temperature hot water lines,
35,000 feet of gravity sewers, 18,300 feet of sewer force mains,
approximately 21,000 feet of above ground electric lines,
approximately 79,000 feet of water lines and a pumping station. No
violations were alleged for NCCW's employment practices with
respect to any of the trades concerned with this work. Moreover,
with regard to the work related to the present dispute, NCCW
employed and properly classified equipment operators to dig and
fill trenches and electricians to pull necessary cabling or
lines.[4]
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[5] various classes of laborers and mechanics which shall be
based upon the wages that will be determined by the
Secretary of Labor to be prevailing for the corresponding
classes of laborers and mechanics employed on projects of
a character similar to the contract work in the city,
town, village, or other civil subdivision of the State in
which the work is to be performed....
40 U.S.C. 276a(a); emphasis supplied. The Wage and Hour Division
has accordingly established a methodology for determining the
nature of construction projects appropriate for comparison to
disputed work: residential, building (or commercial), highway, and
heavy construction. The parties and Interested Person IBEW Local
910 are in agreement that the FY 86 project is heavy construction
and that "projects of a character similar" would be other heavy
construction projects. Moreover, since the applicable prevailing
rates in the locality were determined as those from collective
bargaining agreements, it is appropriate in this case to look only
to the area practice of union contractors. See Fry Brothers
Corporation, WAB Case No. 76-06 (June 14, 1977).
In conducting a full area practice survey, Wage and Hour looks
to the "peak week" of employment for work of a character similar to
that in dispute. A peak week is "the week in which the greatest
number of employees performed the work in question. . . ." Field
Operations Handbook ("FOH") 15f05(d)(4).
Furthermore, a proper area practice survey should encompass a
period of "no more than one year prior to the beginning of the
survey or the request for a wage determination." 29 C.F.R. 1.7(a).
We begin our analysis of the record supporting Wage and Hour's
ruling here. With respect to this part of the procedure, counsel
for the Wage and Hour concedes that two survey projects --both at
the "Cloverdale Complex" of apartments /FN3/ were constructed in
November 1984 and February 1985 -- prior to the appropriate one-
year period. Counsel, nevertheless, states
[a]rguably, the survey should have included only the
projects ongoing between May 1985 and May 1986, but
inclusion of the projects of 1984 [sic] is harmless, as
the more restrictive period would only eliminate two
projects (the Cloverdale Complex projects) and four
electricians from the survey. [5]
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
/FN3/ Wage and Hour did not characterize these "projects" as
building construction, but as "electrical power line and
underground distribution when City converted from a private utility
to own municipal power company." AR Tab A, Attachment, p.1. These
projects entailed the installation of 20 [*] feet [*] and 10 [*]
feet [*] of underground electrical conduit, respectively, which ran
from streetside elevated power lines into the buildings.
[[*]EMPHASIS IN ORIGINAL[*]] [5]
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[6] Statement of the Acting Administrator at p. 13, n.9. This
error may have been harmless in light of the remainder of Wage and
Hour's conclusions, but it was clearly wrong to include these
results in the final survey report. See Northstar Steel, Inc., WAB
Case No. 89-22 (Aug. 21, 1991), slip op. at p. 4 (the applicable
regulation requires "expansion of the geographic sample prior to an
historical search").
Another project employing electricians (two) to perform
similar work was the Watertown Correctional Facility, where again
10 feet of electrical conduit was installed. Petitioner argues
that this project was not of a character similar and should not
have been included in the survey because 1) it was part of a
building project; and 2) it was so small and therefore not
"similar" to the Fort Drum FY 86 project. Wage and Hour considered
this Correctional Facility work pertinent to the survey as it was
part of a heavy construction project: "part of the City conversion
project and not part of the expansion of the facility." AR Tab A,
p. 1.
It must be noted at this juncture that most of the projects
contained in the Wage and Hour 1990 survey were for installation of
substantial amounts of underground electrical conduit. For
instance, another Watertown Correctional Facility project (for a
closed circuit television perimeter alarm) entailed installation of
14,000 feet of conduit and 5 electricians were reported in the peak
week; 2000 feet of conduit were involved in the Sandy Hollow
Hydroelectric facility and 6 electricians were tallied for the peak
week. The scope of these two electrician-staffed projects
represent a stark contrast to that of the 10 feet of conduit in the
Correctional Facility "conversion project," which surely entailed
less than a single day's work for the two reported electricians.
The Board does not reach the question of whether the
Correctional Facility "conversion project" -- as a whole -- was
heavy construction and therefore of a "character similar" for
purposes of the area practice survey. However, the minimal nature
of installing 10 feet of conduit does raise another issue: the
appropriateness of counting the 2 electricians on that project in
the same manner as those electricians and laborers employed on
similar projects of far greater scope. In this regard, the Board
notes without comment that among the surveyed projects, one -- the
Sandy Hollow Hydroelectric Plant -- was a building project, but
since it had a more than "incidental" amount of conduit, (i.e.,
approximately 20% of project cost), Wage and Hour counted the
conduit work as heavy construction and 5 electricians were included
in the survey results contained in the November 13, 1992 ruling
letter. (The investigator who compiled the 1990 area practice
survey did not count this project at all in reaching his
conclusion. Compare AR Tab LL, pages 2 and 4.) [6]
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[7] Granting the same weight to data from vastly disparate-sized
projects is remarkably similar to the area practice methodology
rejected by this Board in Gust K. Newberg Construction Co., WAB
Case No. 91-35 (Mar. 31, 1992). In that case, Wage and Hour had
departed from its usual procedures in determining area practice
data -- since there was no peak week employment information -- and
instead issued an area practice determination based on simply
counting projects where differing practices were utilized. The
Board held that
the approach used by Wage and Hour in this case is
unreasonable as a method of determining area practice
because this approach does not provide a sufficient
measure of the amount of work performed or the number of
workers employed. Furthermore, as LIUNA noted at oral
argument, the use of this approach in this case is
inconsistent with the position taken by Wage and Hour
when the Davis-Bacon helper regulations were under
consideration. See Iron Workers II, WAB Case No. 90-26
(March 20, 1992), at p. 9. Thus, in response to
suggested alternatives (counting projects on which
helpers are used, or counting contractors employing
helpers) for determining area practice regarding
employment of helpers, Wage and Hour stated that these
alternatives "are not acceptable approaches . . . because
they fail to give necessary weight to the size of a
project or a contractor's workforce." 54 Fed. Reg. 4239
(Jan. 27, 1989). Likewise, the project counting approach
used in this case is not an acceptable method of
determining area practice. On remand Wage and Hour
either must utilize its traditional approach of analyzing
peak employment data or, if such information is not
available, must utilize an alternative approach which
gives appropriate weight to the amount of work performed
and the number of employees performing that work.
Id. at pp. 4-5. In the Board's view, the present situation also
evidences an unreasonable approach -- tantamount to "project
counting" -- to determination of this area practice dispute. Under
the holding in Gust Newberg, 2 electricians installing 10 feet of
conduit should not reasonably be given the same weight as 6
installing 14,000 feet. Thus, Wage and Hour gave improper weight
to the two electricians counted in the survey data for the
Correctional Facility conversion project, and those two are neither
valid nor acceptable survey results. /FN4/ [7]
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
/FN4/ We would reach the same conclusion with respect to the two
Cloverdale Complex projects where 10 and 20 feet of underground
conduit were installed by four electricians, had not these projects
been rejected for being outside the correct survey time period.
See pp. 5-6, supra. [7]
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[8] For another project -- the Watertown Electrical Distribution
System -- the investigator found that "[s]ome conduit was laid into
buildings such as the power station, schools and the municipal
building." AR Tab LL, p. 2. Wage and Hour's investigator reported
that this project was "similar" to the Cloverdale Complex projects
where one 10-foot and one 20-foot conduit project were constructed.
Id. at 2-3. Given our disapproval of "project counting" for area
practice surveys, granting full weight for the laying of "some
conduit" would --without clarification of the amounts involved --
appear to be proscribed, as well. Four electricians were included
in the survey results for this project, but should be also be
excluded.
Under the foregoing analysis, the Board has determined that at
least 10 electricians should not have been counted -- or should
have been pro-rated on a reasonable basis -- in the survey results,
which originally reported 21 electricians (67.7%) and 10 laborers
(32.3%). Upon elimination of ten electricians under four projects,
the ratio stands at 11 electricians (52.4%) to 10 laborers (47.6%).
Given these statistics, Wage and Hour should be viewed as having
failed to document sufficient evidence to support the conclusion
that Jefferson County area practice was for electricians to perform
the disputed work. The FOH specifies procedures for counting data
in area practice surveys:
Compile all information received and total the number of
employees in each classification which performed the work
in question. The classification which has the clear
majority of employees performing the work in question is
the proper classification. However, if it is found that
only 51% to 60% of the employees in a classification
performed the work in question, contact the RO [Regional
Office] for guidance. The RO should contact the NO
[National Office], if necessary. If no common, single
classification practice is found to be predominant in the
area or if no project involving work of a similar
character is found, we will not take exception to the
contractor's particular practices.
FOH 15F05(d)(4)(6/29/90); emphasis supplied. A margin of one
employee is not a "clear majority." With only 52% of the survey
represented by electricians --and in light of Wage and Hour's FOH
directives -- the Board cannot conclude that Wage and Hour has
demonstrated that electricians were "predominant in the area."
This percentage is well within the FOH zone where predominance
cannot be established and exception should not be taken to NCCW's
practices.
We next reach consideration of three more projects -- each
involving installation of conduit and manholes for the New York
telephone system -- and for which Wage and Hour concluded that the
contractor (Altec Construction Co., Inc.) utilized laborers. Wage
and Hour stated in the ruling letter that Altec had [8]
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[9] employed 3, 4, and 3 laborers (respectively) on the three projects.
However, the record demonstrates that in responding to Wage and Hour's
1987 area practice survey, on March 18, 1987 Altec first claimed it
employed crews of six, seven and five men -- without identifying peak
weeks. AR Tab S. In clarification, on April 20, 1987 Altec reported
peak week employment of "a six man crew," "a [sic] eight man crew," and
"a nine man crew" on the three New York Telephone Co. projects. AR Tab
U. Altec did not identify the work classification for the members of its
work crews in either 1987 submission.
At the July 28, 1993 hearing, Petitioner raised -- for the
first time -- the discrepancy between both of Altec's survey data
reports and the Wage and Hour conclusion regarding that
contractor's employment numbers on these three projects. Counsel
for Wage and Hour was granted five working days to submit an
explanation -- based on the administrative record as then
constituted -- to explain the discrepancy. On August 4, 1993,
counsel submitted Wage and Hour's explanation but by
contemporaneous motion requested permission to supplement the
record with a compliance officer's work sheets (which were not a
part of the original record) in order to explain the reduction of
Altec's statistics to the levels stated in the November 13, 1992
ruling letter.
The motion to supplement the record is hereby denied. The
Board's directive to Wage and Hour plainly precluded submission of
additional information to support the ruling determinations. We
note that Wage and Hour's counsel states
[a]s a rule, work sheets of Wage and Hour investigator's
are not part of the record submitted to the Wage Appeals
Board. The work sheets do not alter, modify, or amend
the record, but merely explain and show the process that
Wage and Hour used to determined the number of laborers
working on the projects that Altec listed.
Administrator's Supplemental Statement, p. 4. In this case, the
Board must disagree with the "rule." These work sheets do alter,
modify and amend the record in which Altec separately states its
non-peak and peak week employment. The work sheets serve to
explain how the Wage and Hour investigator reduced Altec's reported
numbers in the March 18, 1987 submission, which did not reference
peak employment data /FN5/. But counsel for Wage and Hour also [9]
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
/FN5/ The numbers in the Altec's March 18, 1987 submission were
reduced by several employees, based on the contractor's verbal
advice that -- in addition to laborers -- two of the crews
consisted of a foreman, a driver, and an operator and the third had
a foreman and an operator. Administrator's Supplemental Statement,
pp. 5-6. [9]
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[10] dismisses the importance of the investigator's omission of the
data described by Altec as being peak employment:
The notes do not address the number of employees that
Altec stated in its April 20, 1987 letter work on the
project. Because Wage and Hour should have had that
letter at the time that it spoke with Altec, apparently
the numbers in the first letter were deemed the relevant
numbers.
Id. at p. 5, n.3; emphasis supplied. The basis for stating the
March 18, 1987 numbers were the relevant numbers is not "apparent"
to the Board. What is apparent from the record is that Wage and
Hour did not address Altec's peak employment data and the
Administrator's Supplemental Statement confirms this. If, for
instance, the investigator had extrapolated the method used to
reduce Altec's March 18 numbers to Altec's numbers reported in the
April 20 peak employment numbers (commensurately reducing the
"crews" by a foreman, an operator and, where appropriate, a
driver), an additional five laborers could have been counted in the
survey of Altec's projects. Five additional laborers would
increase the valid total for that classification to 15, which would
be over 57% of the survey universe. This would raise the
conclusion of "predominance" for the laborer's classification.
Finally, the Board will also consider Wage and Hour's
treatment of survey results concerning another heavy construction
conduit project, this one constructed in the proper time frame on
Fort Drum itself -- the Multi-Purpose Training Range for Tanks.
Both the prime contractor and a subcontractor reported having
performed work of a character similar on this project, but Wage and
Hour excluded from consideration all information for the Training
Range project because "conflicting data was received on whether
electricians or laborers performed the installation of cable or
conduit. Additional fact finding efforts failed to resolve the
conflict." AR Tab A, Attachment, p. 3. The Board concludes that
Wage and Hour's basis for excluding both contractor's data --
inability to resolve the "conflict" -- was unreasonable. /FN6/ The
prime contractor, [10]
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
/FN6/ Exclusion of Zeronda's area practice evidence based on the
record was not reasonable. The prime contractor F.J. Zeronda, Inc.
reported that an electrician supervised three laborers who
installed conduit on this project. AR Tab V. Zeronda stated that
it "installed all concrete structures and PVC conduit duct banks
and concrete encasements." Id. On the other hand, the
subcontractor on the project (T.H. Green Electric Co.) reported --
apparently orally -- that it performed similar work and used
electricians. However, the record also demonstrates that T.H.
Green's representative also stated "that the project was too long
ago for him to be able to answer" the Wage and Hour investigator.
This is not -- in the Board's opinion -- a conflict which would
merit the exclusion of the prime contractor's information. A more
reasonable result would have been exclusion of the subcontractor's
information. T.H. Green's report was inherently unreliable as to
the amount of conduit work; moreover, the subcontractor did not
report that it [10][NOTE 6 CONTINUED TO PAGE 11 [11] performed any
duct bank or manhole installation as did Zeronda. The only
reasonable use of this "conflicting" information would have been to
exclude the subcontractor's report and include Zeronda's -- thus
adding three more laborers to the area practice survey result. [END
NOTE 6][11]
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[11] F.J. Zeronda, Inc., reported that an electrician supervised
three laborers who installed conduit on this project. AR Tab V.
Zeronda stated that it "installed all concrete structures and PVC
conduit duct banks and concrete encasements." Id. On the other
hand, the subcontractor on the project (T.H. Green Electric Co.)
reported that it performed similar work and used electricians.
Even if this "conflict" were unresolvable by Wage and Hour's
investigation, the Board believes that a more appropriate solution
would have been referral of the factual dispute to an
administrative law judge for taking of evidence, credibility
resolutions, and determination of the issue. In fact, so many
conflicts in the overall evidence collected by Wage and Hour
existed that it would could have been more reasonable to submit the
entire dispute to an administrative law judge for decision.
For the foregoing reasons, the Board holds that the evidence
of record supports only a determination that there was no
predominant classification performing work of a character similar
to that in dispute and concludes that the decision of the Wage and
Hour Division must be reversed. Moreover, in light of the passage
of time, the Board finds that no useful purpose would be served in
remanding the case for additional consideration. Accordingly, the
Department of Labor should take no exception to NCCW's practice of
employing laborers for the installation of precast manholes,
underground electrical conduit and duct banks on the FY 86
infrastructure project. Finally, given the Board's disposition of
this matter, Petitioner's otherwise acceptable employment policies
under the FY 86 project must be considered in any subsequent
determination of area practice for the FY 87 project.
BY ORDER OF THE BOARD:
Charles E. Shearer, Jr., Chairman
Ruth E. Peters, Member
Gerald F. Krizan, Esq.
Executive Secretary [11]
