Superfund: EPA's Costs to Remediate Existing and Future Sites Will Likely Exceed Current Funding Levels
Published: 2010-06-22T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: This testimony summarizes the findings of our report on funding issues related to the Environmental Protection Agency's (EPA) Superfund program. To protect human health and the environment from the effects of hazardous substances, Congress enacted the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) in 1980, which established the Superfund program. Since 1980, EPA has identified more than 47,000 hazardous waste sites potentially requiring cleanup. As of the end of fiscal year 2009, 1,269 of the most seriously contaminated sites were included on EPA's National Priorities List (NPL): 1,111 nonfederal sites and 158 federal facilities. At the time of listing, EPA had determined that these sites posed relatively high risks to human health or the environment from releases or threatened releases of hazardous substances, such as lead and polychlorinated biphenyl. These substances can cause a variety of health effects--such as birth defects, cancer, and developmental disorders--in people exposed to them. Of the nonfederal sites listed on the NPL at the end of fiscal year 2009, EPA identified 75 that have "unacceptable human exposure"--actual or reasonably expected exposure of an individual to hazardous substances, pollutants, or contaminants at levels that present an unacceptable risk--to contaminants for people living, recreating, and/or working in the surrounding areas. In addition, another 164 of the sites listed on the NPL at the end of fiscal year 2009 may potentially pose serious risks since EPA is in the process of determining if there is unacceptable human exposure at these sites.
section_title: What GAO Found
paragraphs: Over 60 percent of the 75 nonfederal NPL sites with unacceptable human exposure have all or more than half of the work remaining to complete remedial construction. According to EPA regional officials' responses to our survey, EPA has plans to control human exposure at all of the 75 sites with unacceptable human exposure; however, our survey results also show that EPA regional officials expect 41 of the sites to continue to have unacceptable exposure until fiscal year 2015 or later. Similarly, over 60 percent of the 164 nonfederal NPL sites with unknown human exposure have all or more than half of the work remaining to complete remedial construction, according to EPA regional officials' responses to our survey. The majority of the sites with unknown human exposure that have all of the work remaining to complete construction are in the remedial investigation phase, which is when EPA usually determines a site's human exposure status, according to EPA guidance. EPA may also designate a site as having unknown human exposure during the construction phase of work, or after a site has met the construction complete milestone, if new information suggests that there may be risk at the site, or if an investigation is under way to assess a potential exposure pathway not previously analyzed. EPA's annual costs to conduct remedial construction in the most efficient manner at nonfederal NPL sites for fiscal years 2010 through 2014 may range from $335 million to $681 million, according to EPA regional officials' estimates. These estimates include EPA's costs to conduct remedial actions at 142 of the 416 nonfederal sites that are not construction complete. For the remaining 274 sites, EPA regional officials were unable to provide cost estimates for 57 sites, expect responsible parties to fully fund remedial actions at 206 sites, and do not expect to incur additional costs to complete construction at 11 sites because these sites are already fully funded. These annual cost estimates for remedial construction at these sites exceed past annual funding allocations for such actions. For example, EPA regional officials' cost estimates for remedial construction for the next 2 years--fiscal years 2011 and 2012--are $253 million to $414 million greater than the $267 million in annual funding that EPA allocated for remedial actions in fiscal year 2009. From fiscal years 2000 through 2009, EPA allocated $220 million to $267 million in annual funding for remedial actions. According to EPA headquarters officials, however, funds from additional sources--such as prior year funds, settlements with responsible parties, and state cost share agreements--may also be available to fund remedial construction from year to year. While the amount of funding available through these sources may vary substantially from year to year, according to EPA headquarters officials, approximately $123 to $199 million was available from additional sources for remedial actions in fiscal years 2007 through 2009.

section_title: Letter
paragraphs: I am pleased to be here to summarize the findings of our report on funding  issues related to the Environmental Protection Agency’s (EPA) Superfund  program, which is being released today. To protect human health and the  environment from the effects of hazardous substances, Congress enacted  the Comprehensive Environmental Response, Compensation, and Liability  Act (CERCLA) in 1980, which established the Superfund program. Since  1980, EPA has identified more than 47,000 hazardous waste sites  potentially requiring cleanup. As of the end of fiscal year 2009, 1,269 of the  most seriously contaminated sites were included on EPA’s National  Priorities List (NPL): 1,111 nonfederal sites and 158 federal facilities. At  the time of listing, EPA had determined that these sites posed relatively  high risks to human health or the environment from releases or threatened  releases of hazardous substances, such as lead and polychlorinated  biphenyl. These substances can cause a variety of health effects—such as  birth defects, cancer, and developmental disorders—in people exposed to  them. Of the nonfederal sites listed on the NPL at the end of fiscal year  2009, EPA identified 75 that have “unacceptable human exposure”—actual  or reasonably expected exposure of an individual to hazardous  substances, pollutants, or contaminants at levels that present an  unacceptable risk—to contaminants for people living, recreating, and/or  working in the surrounding areas. In addition, another 164 of the sites  listed on the NPL at the end of fiscal year 2009 may potentially pose  serious risks since EPA is in the process of determining if there is  unacceptable human exposure at these sites.
The Superfund cleanup process begins with the discovery of a potentially  hazardous site or the notification to EPA of possible releases of hazardous  substances that may threaten human health or the environment. EPA  regional offices use a screening system called the Hazard Ranking System  (HRS) to numerically assess sites’ relative potential threat to human health  and the environment. The HRS scores sites on four possible pathways of  exposure: groundwater, surface water, soil, and air. Those sites with  sufficiently high scores are eligible for proposal to the NPL. EPA regions  submit these sites to EPA headquarters for possible listing on the NPL on  the basis of a variety of additional factors, including the availability of  alternative state or federal programs and concurrence from the governor  of the state or environmental agency head in which the site is located.  Sites that EPA decides should be listed are proposed in the Federal  Register. After a period of public comment, EPA reviews the comments  and decides whether to formally list the sites as “final” on the NPL.
Once EPA lists a site, it is typically cleaned up through EPA’s Superfund  remedial program. EPA or a responsible party will begin the remedial  process by conducting a remedial investigation and feasibility study to  identify the nature and extent of contamination, quantify potential risks,  and evaluate potential remedies. The culmination of these studies is a  Record of Decision (ROD), which identifies EPA’s selected remedy for  addressing the site’s contamination. The selected remedy is then designed  during remedial design and implemented with construction activities in  the remedial action phase, when actual cleanup of the site generally  begins. When all physical construction at a site is complete, all immediate  threats have been addressed, and all long-term threats are under control,  EPA generally considers the site to be “construction complete.” Of the  1,111 nonfederal sites listed on the NPL as of the end of fiscal year 2009,  695 had reached EPA’s construction complete milestone, while the  remaining 416 had not. Most sites then enter into the operation and  maintenance phase, when the responsible party or the state maintains the  remedy and EPA ensures that the remedy continues to protect human  health and the environment. Eventually, when EPA and the state  determine that no further site response is needed, EPA may delete the site  from the NPL.
NPL cleanup efforts are typically expensive and can take many years.  While responsible parties are liable for conducting or paying for site  cleanup of hazardous substances, in some cases, parties cannot be  identified or may be unwilling or financially unable to perform the  cleanup. To fund EPA-led cleanups at nonfederal NPL sites, EPA uses the  Hazardous Substance Superfund (trust fund) from which EPA receives  annual appropriations. Historically, the trust fund was financed primarily  by taxes on crude oil and certain chemicals, as well as an environmental  tax on corporations based on their taxable income; however, the authority  for these taxes expired in 1995, and shortly thereafter the balance in the  trust fund started diminishing. Since 2001, appropriations from general  revenues have been the largest source of funding for the trust fund. At the  start of fiscal year 2009, the trust fund had a balance of $137 million.  Superfund program appropriations have averaged about $1.2 billion  annually since 1981, although the annual level of these appropriated funds  has generally declined in recent years when adjusted for inflation.
In fiscal year 2009, EPA received about $1.29 billion for the Superfund  program, of which approximately $605 million was for the remedial  program. Of this amount, EPA allocated $125 million for preconstruction  activities—remedial investigation, feasibility study, and remedial design  activities—as well as other nonconstruction activities, including  conducting prelisting activities through cooperative agreements with  states, oversight of all responsible party-lead activities, and providing  general support and management. In addition, EPA allocated $267 million  for remedial actions. EPA allocated the remaining $213 million for  headquarters and regional personnel to implement and oversee the overall  program; for site management; and for providing technical and analytical  support for all non-NPL sites as well as proposed, final, and deleted NPL  sites. In addition, as part of the American Recovery and Reinvestment Act  of 2009 (Recovery Act), EPA’s Superfund remedial program received an  additional $600 million.
My testimony today summarizes highlights from our report. Specifically, I  will discuss (1) the cleanup and funding status at currently listed  nonfederal NPL sites with unacceptable or unknown human exposure, (2)  what is known about the future costs to EPA to conduct remedial actions  at nonfederal NPL sites that are not construction complete, (3) the process  EPA uses to allocate remedial program funding, and (4) the number of  sites EPA and selected state officials expect will be added to the NPL over  the next 5 years, and what they expect the costs of cleaning up those sites  will be.
The findings of our report are based on an electronic survey of branch  chiefs from the 10 EPA regions; data from EPA’s Comprehensive  Environmental Response, Compensation, and Liability Information System  and Integrated Financial Management System; EPA guidance and planning  documents; and interviews with officials from EPA headquarters and  regional offices, 10 selected states, and the Association of State and  Territorial Solid Waste Management Officials. The report contains a  detailed overview of our scope and methodology. This work was  conducted in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Considerable Work Remains at Most Nonfederal NPL Sites with Unacceptable or Unknown Human Exposure, and Some Site Cleanups Have Not Been Funded at the Most Efficient Level
paragraphs: As detailed in our report, over 60 percent of the 75 nonfederal NPL sites  with unacceptable human exposure have all or more than half of the work  remaining to complete remedial construction. According to EPA regional  officials’ responses to our survey, EPA has plans to control human  exposure at all of the 75 sites with unacceptable human exposure;  however, our survey results also show that EPA regional officials expect  41 of the sites to continue to have unacceptable exposure until fiscal year  2015 or later. Similarly, over 60 percent of the 164 nonfederal NPL sites  with unknown human exposure have all or more than half of the work  remaining to complete remedial construction, according to EPA regional  officials’ responses to our survey. The majority of the sites with unknown  human exposure that have all of the work remaining to complete  construction are in the remedial investigation phase, which is when EPA  usually determines a site’s human exposure status, according to EPA  guidance. EPA may also designate a site as having unknown human  exposure during the construction phase of work, or after a site has met the  construction complete milestone, if new information suggests that there  may be risk at the site, or if an investigation is under way to assess a  potential exposure pathway not previously analyzed.
Since CERCLA was passed in 1980 through the end of fiscal year 2009,  EPA expended a total of $3 billion in constant 2009 dollars on the 75 sites  with unacceptable exposure and $1.2 billion in constant 2009 dollars on  the 164 sites where exposure is unknown, based on EPA data. However,  despite the relatively high level of expenditures at sites with unacceptable  human exposure, EPA regional and headquarters officials told us that  construction has not been conducted in the most timely and cost-efficient  manner at some of these sites because EPA had to balance limited annual  resources among various program activities. At the Eureka Mills site in  Utah, people who are in contact with soil and dust contaminated with lead  from mining activities face human health risks. From 2003 to 2008, the site  received $6.6 million to $10 million a year for construction, even though  regional officials said that an additional $3 to $5 million per year would  have allowed them to complete construction at the site 3 to 4 years earlier  at a reduced overall cost. However, with the addition of $26.5 million for  the Eureka Mills site in fiscal year 2009 from Recovery Act funding,  officials said that they will be able to complete construction at least 1 year  earlier than planned and control human exposure at the site. In response  to our survey, EPA regional officials noted that they are using Recovery  Act funding to partially or completely control the unacceptable human  exposure at 20 NPL sites. However, despite EPA’s use of Recovery Act  funds to control human exposure at these sites, EPA officials noted that  EPA’s constrained funding has caused delays in the control of human  exposure at some sites.
section_title: EPA’s Costs for Conducting Remedial Construction at Nonfederal NPL Sites Will Likely Exceed Recent Funding Levels for These Activities
paragraphs: As we noted in our report, EPA’s annual costs to conduct remedial  construction in the most efficient manner at nonfederal NPL sites for fiscal  years 2010 through 2014 may range from $335 million to $681 million,  according to EPA regional officials’ estimates (see table 1). These  estimates include EPA’s costs to conduct remedial actions at 142 of the  416 nonfederal sites that are not construction complete. For the remaining  274 sites, EPA regional officials were unable to provide cost estimates for  57 sites, expect responsible parties to fully fund remedial actions at 206  sites, and do not expect to incur additional costs to complete construction  at 11 sites because these sites are already fully funded.
These annual cost estimates for remedial construction at these sites  exceed past annual funding allocations for such actions. For example,  EPA regional officials’ cost estimates for remedial construction for the  next 2 years—fiscal years 2011 and 2012—are $253 million to $414 million  greater than the $267 million in annual funding that EPA allocated for  remedial actions in fiscal year 2009. From fiscal years 2000 through 2009,  EPA allocated $220 million to $267 million in annual funding for remedial  actions. According to EPA headquarters officials, however, funds from  additional sources—such as prior year funds, settlements with responsible  parties, and state cost share agreements—may also be available to fund  remedial construction from year to year. While the amount of funding  available through these sources may vary substantially from year to year,  according to EPA headquarters officials, approximately $123 to $199  million was available from additional sources for remedial actions in fiscal  years 2007 through 2009. Our analysis indicates that, even if this level of  funding were available in future years, it would not supplement EPA’s  annual funding allocation enough to cover the estimated costs for  conducting remedial construction in fiscal years 2011 and 2012. Therefore,  despite funding from additional sources, EPA’s estimated costs to conduct  remedial construction will exceed available funds if funding for remedial  construction remains constant.
Furthermore, these annual cost estimates are likely understated. These  officials were not able to provide annual construction cost estimates for 57  of the 416 nonfederal sites that are not yet construction complete because  they are in the early stages of the remedial process, and EPA does not yet  know the extent of the contamination and/or has not chosen a cleanup  remedy for them. For some additional sites, EPA regional officials were  unable to provide cost estimates for construction at some of the operable  units at the site. In addition, EPA regional officials’ estimates did not  include costs for conducting long-term response actions—such as  operating groundwater treatment facilities—which are considered part of  the remedial action, or for performing 5-year site reviews, both of which  EPA funds from its remedial action allocation and would, therefore,  increase the cost estimate for remedial actions.
EPA’s estimates also did not include construction costs for sites that  currently have a potentially responsible party that may be unable to fund  the cleanup. EPA officials told us that EPA has identified one or more  potentially responsible parties at 206 of the 416 nonfederal NPL sites that  are not yet construction complete. However, officials also said that they  were slightly or not at all confident that a responsible party would fund  future remedial actions at 27 of these sites.
EPA headquarters and regional officials also told us that EPA’s actual  costs for construction are typically higher than its cost estimates because  of a number of uncertainties. Most importantly, according to EPA officials,  the extent of contamination at a site is often greater than EPA expected  when it developed the cost estimate, which can expand the scope of work  and remedies needed and increase overall construction costs. For  example, we recently reported that at the Federal Creosote Superfund site  in New Jersey, the greater-than-expected quantities of contaminated  material contributed to a $111 million increase in construction costs over  EPA’s estimates. Another factor that can increase construction costs is a  change in acceptable contaminant levels. In addition, according to EPA,  the actual costs of goods and services—such as energy, construction  materials, and labor—may increase above estimated prices, causing an  increase in the actual construction cost. EPA officials noted that there may  be some instances when construction costs are overestimated because, for  example, there is less contamination at a site than previously thought or  the prices of goods and services decrease; however, the officials  commented that this is rare. The frequent occurrence of additional  unexpected costs enhances the likelihood that EPA’s costs for remedial  actions over the next several years will exceed recent funding levels for  these activities, and EPA may be forced to choose between funding  construction at some sites in the most efficient manner or funding  construction at more sites less efficiently.
section_title: EPA Allocates Remedial Program Funding Separately for Preconstruction Activities and Remedial Actions, and Limited Funding Has Caused Delays at Some Sites
paragraphs: As explained in our report, EPA allocates funds separately for pre- construction activities—such as remedial investigation and remedial  design—and remedial actions. EPA headquarters allocates funds for pre- construction activities to the regions for them to distribute among sites.  EPA headquarters determines the amount of resources that the Superfund  program will allocate to the regions by using a model that distributes  available funding based on a combination of historical allocations and a  work-based scoring system that scores each region based on projects  planned for the upcoming year. According to EPA’s Superfund Program  Implementation Manual, at the initiation of the planning process,  headquarters provides general projections of funding for preconstruction  activities that will be available to the regions. On the basis of these  projections, each region then develops a plan for allocating these funds to  sites. Before finalizing this plan, each region holds planning discussions  with headquarters to discuss actions that can be accomplished during the  year and alters its plans, as needed, based on refined projections of  available funding from headquarters.
To allocate funding for remedial actions, EPA headquarters works in  consultation with the regions to allocate funds on a site-by-site basis.  EPA’s Superfund Program Implementation Manual states that sites with  ongoing construction receive priority for funding over new construction  work. Headquarters develops the initial plan for ongoing construction  based on regional funding requests, projections of available funding, and  discussions with regional officials. According to EPA, the agency’s goal in  allocating funds is to ensure that all sites with ongoing construction  continue to progress toward construction completion while also funding  some new construction projects.
According to EPA headquarters and regional officials, the funds for both  preconstruction activities and remedial actions have not been sufficient to  clean up some sites in the most timely and cost-efficient manner. EPA  officials from several regions told us that their regions currently receive  about half or less than half of the funding they could use for  preconstruction activities. As a result, according to our survey, which  collected data on fiscal years 2000 through 2009, most regions have sites  that have experienced delays in the preconstruction phase because of  insufficient funding. Similarly, sites with ongoing construction have  experienced delays caused by limited funding, according to EPA officials.  Since fiscal year 2000, most regions have experienced delays because of  insufficient funding at one or more sites with ongoing construction,  according to responses to our survey. According to several EPA regional  officials, delays in funding for sites with ongoing construction increase the  length of time it takes to clean up a site; the total cost of cleanup; and, in  some cases, the length of time populations are exposed to contaminants.  In addition, funding limitations have caused delays at sites that were ready  to begin new construction. According to EPA Superfund Accomplishment  Reports, between fiscal years 2004 and 2008, 54 sites, or over one-third of  all sites ready for new construction funding, were not funded in the year  that they were ready to begin construction, and some sites were not  funded for several years after they were construction-ready.
EPA officials told us that EPA prioritized sites to receive the $582 million  in American Recovery and Reinvestment Act funds allocated to  remediation in a manner similar to the way EPA prioritizes sites for  remedial actions. According to EPA headquarters officials, 25 sites  needing new construction funding in fiscal year 2009 would most likely not  have received funding had Recovery Act funding not been available.
section_title: Most EPA Regional and Selected State Officials Expect an Increase in the Number of Sites Added to the NPL over the Next 5 Years but Cannot Estimate the Cleanup Costs
paragraphs: Our report also notes that most of the EPA regional officials and state  officials we interviewed told us they expect the number of sites listed on  the NPL over the next 5 years will be greater than the number listed in the  past 5 years. EPA regional officials estimate that from 101 to 125 sites—an  average of 20 to 25 sites per year—will be added to the NPL over the next  5 years. This is higher than the 79 sites—an average of about 16 sites per  year—added from fiscal years 2005 through 2009. As table 2 shows, all  EPA regions expect that the number of sites added to the NPL over the  next 5 years from their region could increase. According to EPA  headquarters officials, the number of sites proposed for listing over time  has decreased as a result of the expanded use of other cleanup programs,  including state programs. Most of the officials who expect an increase in  listings noted that current economic conditions—which can limit states’  abilities to clean up sites under their own programs and responsible  parties’ abilities to pay for cleanup—are a contributing factor to the  expected increase in listed sites.
Most of the officials we spoke with in the 10 selected states also expect  that the number of sites listed from their states over the next 5 years could  increase above the number of sites listed over the past 5 years, as table 3  shows. For example, officials from the Michigan Department of Natural  Resources and Environment said that they expect EPA to list five sites in  Michigan to the NPL over the next 5 years, even though no sites have been  listed from their state since 1996. These officials noted that the Superfund  program has traditionally been a program of last resort, but declining  resources in their state’s cleanup program have renewed Michigan’s  interest in cleaning sites up through the federal program.
Neither EPA regional officials nor state officials we contacted were able to  provide cost estimates for many of the sites they expect to be added to the  NPL over the next 5 years. Furthermore, when these officials were able to  provide cost estimates, most of them were imprecise figures based on  limited knowledge and best professional judgment. Officials also  explained that they could not provide cost estimates for some of the sites,  because either the type and extent of contamination are not yet known, or  officials have not yet identified the actual sites that may be listed.  Therefore, it is impossible to accurately estimate what the cost may be to  clean up these sites. However, we reported in July 2009 that the average  amount EPA spent to clean up individual sites has increased in recent  years. For example, EPA spent an average of approximately $7.5 million  at sites that reached EPA’s construction complete milestone in fiscal year  1999. EPA’s expenditures increased to an average of about $10.2 million in  total expenditures per site at sites reaching construction complete in fiscal  year 2007. In that report, we noted that individual site costs may have  increased because the sites on the NPL now are more complex than in the  past, construction costs have been rising, and EPA has not been able to  identify as many responsible parties to fund site cleanups as in the past,  leaving a higher share for EPA to fund.
In addition to the number of sites that could be listed, the number of sites  eligible for the NPL could increase if EPA begins to assess, as a part of its  listing process, the risk of vapor intrusion caused by subsurface hazardous  substances that have migrated via the air into homes and commercial  properties. Although sites with vapor intrusion can pose considerable  human health risks, EPA’s HRS—the mechanism used to identify sites that  qualify for NPL listing—does not currently recognize these risks;  therefore, unless a site with vapor intrusion is listed on some other basis— such as groundwater contamination—EPA cannot clean up the site using  remedial program funding. Many EPA regional officials and state officials  noted that vapor intrusion is a concern, and several of these officials told  us that they believe additional sites would be eligible for listing if  assessments of vapor intrusion were included as part of the listing  process. According to an EPA headquarters official, based on recent  discussions with regional officials, up to 37 sites could be eligible for NPL  listing if EPA includes vapor intrusion assessments as part of the listing  process. However, according to EPA headquarters officials, EPA must first  determine whether or not it can consider the vapor intrusion pathway  under its existing HRS regulations, and it has not yet made such a  determination. While these sites are not currently eligible for NPL listing,  the EPA headquarters official noted that EPA is addressing vapor intrusion  at 13 of these sites through its Superfund removal program; however, this  official also told us that, when conducting removal actions, EPA is limited  in its ability to fully remediate the source of contamination. For example,  according to an official from the Montana Department of Environmental  Quality, preliminary data collected at the Billings PCE site—which the  official noted is not eligible for NPL listing—indicated vapor intrusion in  buildings, and EPA conducted a removal action at this site. However,  according to this official, it is unclear whether the removal action was  effective in mitigating the vapor intrusion contamination, and people may  continue to be exposed.
In conclusion, we found that limited funding for the Superfund program  has caused delays in cleaning up some sites in recent years. This limited  funding, coupled with increasing costs of cleanup, has forced EPA to  choose between cleaning up a greater number of sites more slowly at  higher cost and cleaning up fewer sites more quickly at lower cost.  Compounding these challenges, EPA does not currently assess the relative  risk posed by vapor intrusion when deciding which sites to include on the  NPL, and assessing this risk could lead to an increase in the number of  sites listed on the NPL. However, if these sites are not assessed and, if  needed, listed on the NPL, some seriously contaminated hazardous waste  sites with unacceptable human exposure may not be cleaned up. In our  report being released today, we are recommending that the Administrator  of EPA determine the extent to which EPA will consider vapor intrusion  as part of the NPL listing process and how this will affect the number of  sites listed in the future. EPA agreed with our recommendation.
Mr. Chairman, this concludes my prepared statement. I would be pleased  to respond to any questions that you or Members of the Subcommittee  may have at this time.
section_title: GAO Contact and Staff Acknowledgments
paragraphs: For questions about this statement, please contact John Stephenson at  (202) 512-3841 or stephensonj@gao.gov. Individuals making key  contributions to this testimony include Barbara Patterson and Vincent P.  Price, Assistant Directors; Deanna Laufer; and Kyerion Printup. Elizabeth  Beardsley, Pamela Davidson, and Mehrzad Nadji also made important  contributions.
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