Amicus Brief — American Textile Mfrs. Institute, Inc. v. Donovan

IN THE

Supreme Court af the United States

OcroBER TERM, 1980

a a a OED Sites ey

AMERICAN TEXTILE MANUFACTURERS INSTITUTE, INc.,

Mrurken & Company, ARKwrIGHT MILLS,

Spartan Miuys, Biark Mits, Inc., HERMITAGE, INC.,

Dan River, Inc., Cone Mitts CoRPORATION,

Mayra Miixs, Serine Miixs, Inc., RieGEL TEXTILE

CorporATION, Fretpcrest Mii1s, INC., and

West Pornt-PEPPERELL, INC.,

Petitioners,

v.

Ray MarsHALL, SECRETARY OF LaBoR,

Unrrep States DEPARTMENT OF LaBor,

Respondent.

On Writ of Certiorari to the United States Court of Appeals

for the District of Columbia Circuit

MOTION OF AMERICAN IRON AND STEEL |

INSTITUTE FOR LEAVE TO FILE BRIEF AMICUS |

CURIAE IN SUPPORT OF PETITIONERS

and

BRIEF OF AMERICAN IRON AND STEEL INSTITUTE

AMICUS CURIAE IN SUPPORT OF PETITIONERS —

:

JEROME POWELL :

Counsel of Record

W. Scorr RaILton i

Reep Sura SHaw & McCuay |

1150 Connecticut Ave., N.W.

Washington, D.C. 20036 i

(202) 457-6131 \

Of Counsel: Barton C. GREEN

Davip FERBER General Counsel ’ i

Reep Smita Spraw & McCay American Iron and Steel Institute

1150 Connecticut Ave., N.W. 1000 16th Street, N.W.

Washington, D.C. 20036 Washington, D.C. 20036

(202) 457-6117 (202) 452-7143 F

November 20, 1980

a

Press or Byron S. ADAMS PRINTING, INC., WASHINGTON, D. C.

No. 1429

IN THE

Supreme Court of the United States

OcToBER TERM, 1980

AMERICAN TEXTILE MANUFACTURERS InstituTE, INc.,

MILLIKEN & Company, ARKwricHt Mis,

Spartan Mis, Buair Mitts, Inc., Hermrrace, INc.,

Dan River, Inc., Cone Mitts Corporation,

Mayrarr Mitts, Sprine Miizs, Inc., Rrecen Texte

CoRPORATION, Frevpcrest Mitts, Inc., and

West Pornt-PEpPERELL, INc.,

Petitioners,

¥.

Ray MarsHa.t, SECRETARY oF Lazor,

Untrep States DEPARTMENT OF LaBoR,

Respondent.

On Writ of Certiorari to the United States Court of Appeals

For the District of Columbia Circuit

—_—

INSTITUTE FOR LEAVE TO FILE BRIEF AMICUS

; MOTION OF AMERICAN IRON AND STEEL

| CURIAE IN SUPPORT OF PETITIONERS

The American Iron and Steel Institute, a nonprofit

trade association with a membership which includes

63 domestic iron and steel producing companies, moves

for leave to file a brief, amicus curiae, in support of

li

the petitioners. This motion is accompanied by the

written consent of the Solicitor General for the respon-

dents and by the written consents of some of the peti-

tioners. While counsel for each of the petitioners have

orally consented to the filing of this brief, written con-

sents have not been received from all of the petitioners.

As set forth more fully in the attached brief, the

American Iron and Steel Institute’s interest arises

from the fact that the American steel industry, unlike

the petitioners in this case, is substantially affected

by numerous OSHA health and safety regulations pur-

suant to §6(b) of the OSH Act. In the light of the

economic problems now facing the basic steel industry,

this Court’s application and interpretation of the

terms “‘to the extent feasible” and ‘‘the feasibility of

the standards”’ in § 6(b) (5) of the OSH Act, 29 U.S.C.

655(b) (5), and ‘‘reasonably necessary or appropriate’”’

in § 3(8) of that Act, 29 U.S.C. 652(8), are crucial to

the industry. The parties are unlikely to present to

this Court the effect its interpretation of these statu-

tory terms will have on an industry subject to numer-

ous OSHA regulations.

Respectfully submitted,

Davip FERBER

November 20, 1980

lii

TABLE OF CONTENTS

Page

STATEMENT OF INTEREST ...............00..00.5.,.. 2

SUMMARY OF ARGUMENT .....................00.... 7

vininsiicasceentec ee EL TOT URES ea 8

WE err iid ree ee 12

TABLE OF AUTHORITIES

CasEs:

Industrial Union Dept. AFL-CIO v. American Petro-

leum Institute, 48 USLW 5022 (July 2, 1980). .3, 9, 12

Texas Independent Ginners Ass’n v. Marshall, Nos.

78-2663, ete. (5th Cir. Nov. eae 6, 9

United Steelworkers of America, AFL-CIO v. Mar-

shall, No. 79-1048 (D.C. Cir. Aug. 15, 1980) ....6, 7, 8,

10,1

Statutes anp Rutss:

Clean Air Act, as amended, 42 U.S.C. § 7401, et seg... 4

Clean Water Act, as amended, 33 U.S.C. § 1251, et seq. 4

Occupational Safety and Health Act,

29 U.S.C. 655(b)(5) (1970), §$ 6(a), $6(b)(5) ..2,3,4

6

29 U.S.C. 652(8) (1970), DOE ov bavbia cus ocx 2,3

ye mailece teapot CEO Te FE Cee 3, 4

43 Fed. Reg. 54480-82 SOMME Shi eetecanrca. ce 10

43 Fed. Reg. 54494 ig SE ee ae 8

45 Fed. Reg. 36962 ( MN SS vn leeidyfabsaecas gcc ose 4

45 Fed. Reg. 36971 ec, EEN eee eae 3

45 Fed. Reg. 37648 ( one RE ci one 3, 4

45 Fed. Reg. 37649 WOE hh cOkacase soca oho acs 3

iv

Table of Authorities Continued

Page

MISCELLANEOUS:

American Iron and Steel Institute, Steel at the Cross-

roads: The American Steel Industry in the 1980s.

EC RE 62b sw Lcdanbunse paces Cheung omet 5, 6

Annual Statistical Report, American Iron anp STEEL

oe dg SEE ECT FRE Rate aM ANTES 5

Council on Wage and Price Stability, Catalog of Fed-

eral Regulations Affecting Iron and Steel Indus-

my, Dopemiben, WOVG wi EVs. icie ks Av bap cicseces 4,5

Environmental Protection Agency’s Carcinogen As-

sessment Group “List of Carcinogen,” April 22,

1980

Registry of Toxic Effects of Chemical Substances

NIOSH, as contained in the Environmental Pro-

tection Agency National Institutes of Health

Chemical Information System (July 1979), re-

ferred to at 45 Fed. Reg. 53673 (1980) ......... 3

Report to the President by the Steel Tripartite Ad-

visory Committee on the U.S. Steel Industry (Sept.

24, 1980)

No. 1429

IN THE

Supreme Court of the United States

OctToBER TERM, 1980

AMERICAN TEXTILE Manuracturers Institute, INc.,

MILLIKEN & CoMPANY, ARKWRIGHT M118,

Spartan MiLus, Buair Mitts, Inc., Hermritace, INc.,

Dan River, Inc., Cone Mis CORPORATION,

MAYFAIR Mii1s, SPRING Mis, Inc., Rrece. TEXTILE

CoRPORATION, FIELDCREST ’ MILLS, Inc., and

West Pornt-PEPPERELL, Ino. s

Petitioners,

v.

Ray MarsHAuL, SECRETARY OF LABor,

Unirep STates DEPARTMENT OF LABOR,

Respondent.

On Writ of Certiorari to the United States Court of Appeals

for the District of Columbia Circuit

BRIEF OF AMERICAN IRON AND STEEL INSTITUTE

AMICUS CURIAE IN SUPPORT OF PETITIONERS

2

STATEMENT OF INTEREST OF AMERICAN IRON AND STEEL

INSTITUTE AMICUS CURIAE

American Iron and Steel Institute (AISI) is a non-

profit trade association with a membership that in-

cludes sixty-three domestic iron and steel producing

companies. These companies employ some 449,000 per-

sons in their steel producing and fabricating opera-

tions and possess approximately 92% of the raw steel

producing capability in the United States. AISI is

participating in rulemaking and litigation concerning

the standard proposed by the Occupational Safety and

Health Administration (OSHA) for occupational ex-

posure to lead because that standard has had and will

continue to have a direct impact on certain steel in-

dustry operations. AISI’s interest in the instant case

stems from the consonance of legal issues presented in

the cotton-dust and lead-standard litigations and the

potential precedential effect of this litigation on the

interpretation and application of the Occupational

Safety and Health Act (OSH Act) generally.

Crucial to the American iron and steel industry will

be this Court’s application and interpretation of the

terms “‘to the extent feasible’ and ‘‘the feasibility of

the standards”’ in § 6(b) (5) of the OSH Act, 29 U.S.C.

655(b) (5), and ‘‘reasonably necessary or appropriate’”’

in § 3(8) of that Act, 29 U.S.C. 652(8). If the view of

the court below should be sustained that these terms

require no more of OSHA than a determination that

the costs of the standard will not bankrupt the regu-

lated industry, the American steel industry will be

dealt a severe blow. This is because the steel industry

is or expects to be subject to numerous OSHA health

and safety regulations promulgated pursuant to §6

3

(b),' including those dealing with coke oven emissions,”

asbestos,* noise,‘ benzene,’ lead,®° carbon monoxide

(CO),’ sulphur dioxide (SO:),° heat stress,® iron

oxide,” benzo (a)pyrene,” naphthylamine,” and trich-

loroethlene,”* all of which are expected materially to

affect the manufacture of steel or subsidiary opera-

tions. Also, of concern to the steel industry are cur-

rent OSHA standards adopted pursuant to § 6(a),

to which the ‘‘reasonably necessary or appropriate”’

language of § 3(8) seems equally applicable. These in-

clude various of the subjects as to which § 6(b) stand-

*§6(b)(5) of the OSH Act containing the ‘‘feasibility’’ lan-

guage clearly covers health standards and may also cover safety

standards. See Industrial Union Dept. AFL-CIO v. American Pe-

troleum Institute, 48 USLW 5022, 5023, n. 1 (July 2, 1980)

(Benzene).

?29 CFR 1910.1029 (1977).

*29 CFR 1910.1001 (1976), 45 Fed. Reg. 36971 (1980).

*29 CFR 1910.95 (1974), 45 Fed. Reg. 36962 (1980).

*29 CFR 1910.1026 (1978), invalidated by Industrial Union

Department, AFL-CIO v. American Petroleum Institute, 48 USLW

5022 (July 2, 1980).

°29 CFR 1910.1025 (1979), 45 Fed. Reg. 63476 (1980).

* 29 CFR 1910.1000, Table Z-1, 45 Fed. Reg. 37648 (1980).

*45 Fed. Reg. 37649 (1980).

* Registry of Toxic Effects of Chemical Substances NIOSH, as

contained in the Environmental Protection Agency National Insti-

tutes of Health Chemical Information System (July, 1979), re-

ferred to at 45 Fed. Reg. 53673 (1980).

1° Td.

*\ Environmental Protection Agency’s Carcinogen Assessment

Group ‘‘List of Carcinogens,’’ April 22, 1980, referred to at 45

Fed. Reg. 53673 (1980).

22 Td.

13 Id.

4

ards are anticipated, such as exposure to noise,” car-

bon monoxide,” sulphur dioxide," electrical standards,”

and standards respecting walking and working sur-

faces," as well as other possible hazards, such as ex-

posure to acid mist,”® coal dust,” and dusts (total).

The §6(b) standards, as adopted or proposed, are

almost uniformly more expensive for the industry than

the “‘consensus”’ or ‘‘established Federal”’ safety and

health standards with respect to the same subject

matters that have been previously adopted by OSHA

pursuant to §6(a) of the OSH Act, although the

latter standards have resulted in substantial compli-

ance costs.

At the same time the industry is subjected to these

heavy expenses of compliance with OSHA regulations,

it is subject to the burdensome costs of complying with

the Clean Air Act, 42 U.S.C. § 7401 et seq., and the

Clean Water Act, 33 U.S.C. § 1251, et seq., as well as

to numerous other Federal regulations. By reason of

such regulations, the Council on Wage and Price Sta-

bility reported:

“Steel is an industry whose production proce-

dures are to some extent prescribed for it by gov-

ernment, whose costs are substantially influenced

by government, whose market share exists at the

sufferance of government and whose profitability

129 CFR 1910.95 (1974), 45 Fed. Reg. 36962 (1980).

*° 29 CFR 1910.1000 Table Z-1.

18 Tq,

* 29 CFR 1910.308-309, 45 Fed. Reg. 37648 (1980).

8 29 CFR 1910.21.34, 45 Fed. Reg. 37648 (1980).

1° 29 CFR 1910.1000 Table Z-1.

*° Id. at Table Z-2.

21 Id. at Table Z-3. Pig

4)

has a good deal less to do with innovation and

enterprise than it does with what government

decides to let it keep.” ™

Over the past several years, the basic American steel

industry has been characterized by production far be-

low capability, by low or negative rates of return, and

by declining employment. During the most recent four

calender quarters for which data is available, the

second quarter of 1979 to the second quarter of 1980,

the major integrated steel producers suffered a decline

of 63% in corporate profits, with outright losses in

steelmaking operations as a result of escalating costs

and underutilization of facilities.” From 1970 to 1979

employment by American companies in the production

and sale of steel products declined by 15%, from

531,000 to 453,000. Not coincidently, imports of steel

have increased both absolutely and proportionately

during the past three decades. In the early 1950s steel

imports represented 1.8% of domestic sales; by 1978

that figure had grown ten-fold to 18.1%.”

** Council on Wage and Price Stability, Catalog of Federal

Regulations Affecting Iron and Steel Industry, December, 1976,

at iv.

°° Report to the President by the Steel Tripartite Advisory Com-

mittee on the U.S. Steel Industry, (Sept. 24, 1980) at 1. Co-chaired

by the Secretaries of Labor and Commerce and comprised of gov-

ernment, labor, and industry leaders, the Steel Triparitite Ad-

visory Committee submitted findings on the steel industry and rec-

ommendations for its revitalization to President Carter. These

recommendations provided the basis for President Carter’s pro-

gram for tne industry, announced on Sejtember 30, 1980.

** Annual Statistical Report, AMERICAN IRON AND STEEL INsTI-

TUTE 1979, p. 21.

*° American Iron and Steel Institute, Steel at the Crossroads: The

American Steel Industry in the 1980s (Jan. 1980) (hereinafter

**Steel at Crossroads’’) at 9.

6

Modernization of facilities is the key to the indus-

try’s recovery but this will require enormous capital

expenditures over the next five years. The Steel Tri-

partite Committee has examined this matter and has

concluded that when the industry’s capital needs for

modernization and for meeting environmental and

health requirements are compared to available capital

resources for the critical 1980-84 period a shortfall of

1.7 to 2 billion dollars annually results.”

It must be added that the economic problems con-

fronting the steel industry and inflation and persistent

balance of payments deficits, among other things, bear

testimony to a malaise in the American economy in

general and in basic industries in particular. It is

against this economic backdrop that OSHA’s cotton

dust standard—and specifically the agency’s treatment

of the economic feasibility issue—must be judged.

AISI’s participation in the on-going proceedings to

establish a health standard for occupational exposure

to inorganic lead has served to focus the steel indus-

try’s attention on the legal issues presented. to this

Court in the instant case. In the lead standard pro-

ceeding OSHA, with approval of the Court of Appeals

of the District of Columbia Circuit,” has determined

among other things that it has the power under § 6

(b) (5) of the Act to force whole industries to convert

their basic manufacturing facilities from traditional

to novel and untried technologies because the latter

*° This estimate represents a consensus reached with Treasury

Department representatives on the Steel Tripartite Advisory Com-

mittee. STC Report at 8. Industry estimates of the capital shortfall

are in fact somewhat larger. See Steel at the Crossroads, supra,

at 50.

** United Steelworkers of America, AFL-CIO v. Marshall, No.

79-1048 (D.C. Cir. Aug. 15, 1980) (Lead).

7

may, in OSHA’s view, achieve some health gains for

employees. OSHA further concluded, again with the

approval of the Court of Appeals, that the unknown

but unquestionably vast dollar expenditures required

to eifect these changes in fundamental technology and

manufacturing processes did not render the standard

economically infeasible because, as here, it did not

appear that the costs imposed by the standard would

bankrupt the affected industries.

While Certiorari will be sought in Lead, this Court’s

disposition of this case may establish precedents

which both will affect the disposition of some of the

issues in Lead and will resolve critical questions con-

cerning the meaning and application of the OSH Act

generally. For the reasons already indicated and de-

veloped further herein, the proper resolution of these

questions here is a matter of the gravest concern to

the American steel industry.

SUMMARY OF ARGUMENT

The criteria applied by OSHA and the court below

to determine that the cotton dust standard is econom-

ically feasible are clearly inadequate. They confer on

OSHA an unfettered power to impose costs on affected

industries and to direct the allocation of their capital

resources without regard to the realities of today’s

economy. In so doing, they inescapably raise grave

questions of unconstitutional delegation of legislative

power. The constitutional questions can be avoided and

the American economy can be spared the imposition of

unnecessary costs by a reading of the OSH Act which

compels OSHA to justify the costs of its standards.

8

ARGUMENT

In the language of the Court of Appeals, OSHA’s

determination that the cotton dust standard was eco-

nomically feasible rested on the agency’s ‘conclusion

that the standard will not put the industry out of

business.’’ “* (Pet. App. 69). In Lead, supra, the Court

of Appeals further explicated its understanding of the

term ‘‘economic feasibility.”” The Court said (per

Chief Judge Wright) :

‘“‘A standard is feasible if it does not threaten

‘massive dislocation’ to, AFL-CIO v. Brennan,

supra, 530 F.2d at 123, or imperil the existence

of, American Iron and Steel Institute v. OSHA,

supra, 577 F.2d at 836, the industry .... More

specifically, Industrial Union Dept., AFL-CIO

v. Hodgson, supra, teaches us that the practical

question is whether the standard threatens the

competitive stability of an industry, 499 F.2d at

478, or whether any inter-industry discrimination

in the standard might wreck such stability or lead

wea concentration ... .’’ Slip Opinion at

143-44,

We submit that this reading of feasibility is both

practically and legally deficient. Practically it fails

**OSHA does recognize that the costs of a given standard are

not to be viewed in complete isolation. In its preamble to the lead

standard the agency stated its position as follows:

‘‘Costs from other sources, including other OSHA standards,

have been considered in the same manner as any other known

costs facing an industry. As such they become part of the

economics of the industry from which the likely impact of

the “en standard is measured.’’ 43 Fed. Reg. 54494 (Nov.

21, 1978).

As indicated from the quotation from the lead standard case in the

text, supra, however, the ‘‘likely impact’’ of a proposed OSHA

standard sufficient to restrain OSHA is the virtual bankruptcy of

the affected industry.

9

because at a time when American industry cannot tol-

erate unnecessary additions to its costs, it imposes on

OSHA no real obligation to justify the costs of its

regulations. Legally it fails because, bankruptcy of the

affected industry aside, it furnishes no guidelines for

the exercise of OSHA’s regulatory discretion.

Of course, it is implicit in the adoption of the OSH

Act that the American economy will bear the costs of

upgrading the safety and health of the industrial

workplace. However, as this Court noted in Benzene,

supra, 48 USLW at 5033, 34, both the language of the

OSH Act and its legislative history make plain that

Congress did not wish to confer on OSHA a limitless

authority over the American economy.

Just such a limitless delegation of authority is

achieved, however, by the construction given to the

term ‘‘feasible’’ by OSHA with the approval of the

court below.” So long as industry bankruptcy is

avoided, OSHA is left free to decree whatever changes

in the domestic economy it feels may contribute to an

improvement in the health or safety of the industrial

workplace,

OSHA’s lead standard discloses the extent to which

such an unbridled discretion can be carried. Com-

pliance with that standard among other things will

require the primary lead industry to convert its basic

manufacturing processes from a pyrometallurgical

technology to a new and unproven hydrometallurgical

* But ef. Texas Independent Ginners Ass’n v. Marshall, Nos.

78-2663, ete., (5th Cir. Nov. 14, 1980) Slip Opinion 1208, 1225

n. 50:

‘The economic feasibility aspect of the statutory limitation

requires that OSHA regulations must be affordable and also

must be of practical cost.’’

10

technology.” OSHA does allow the industry ten years

in which to achieve the conversion, but this regulatory

magnanimity serves only to underscore the scope of

the power asserted. OSHA’s justification for the ten-

year compliance period is its recognition that the

technology to meet the standard exists today in em-

bryonic form only." Thus, the standard requires the

industry to invest its capital resources in the pursuit

of an unproven technology which OSHA has selected

for it and this without any real assurance that the

health objective of the standard can be achieved

through the new technology.”

OSHA’s authority to preempt core managerial de-

cisions regarding changing to different manufactur-

ing technologies is directly at issue in the Lead case

but is not present, as such, in the instant case. OSHA’s

assertion in Lead, on the other hand, of the power to

direct the allocation of corporate resources to the pur-

suit of specific new technologies does bear directly on

the cotton dust standard. Indeed, the lead standard

takes OSHA’s assertion of authority one step farther

than the instant case. Here, the expenditures which

the standard would require of the industry are, by

and large, hygenic in nature (improved ventilation,

enclosure of equipment, ete.). In Lead the agency

claims the power to direct the expenditure of cor-

*° 43 Fed. Reg. 54480-82 (Nov. 21, 1978).

** Id. The Court of Appeals found the ten-year compliance pe-

riod consoling. It said :

“OSHA’s technology-forcing strategy, and its reliance on

embryonic schemes for compliance, are particularly reasonable

in the light of such a generous phase-in period.’’ Lead, supra,

Slip Opinion at 172.

*? See the Court of Appeals’ discussion of the new technology,

td, at 174.

11

porate funds in areas—selection of manufacturing

technologies for example—that lie wholly outside the

agency’s statutory competence solely because the

agency believes that there may be some beneficial side

effects from the expenditures,

This is limitless discretion. It is discretion exercised

without reference to meaningful guidelines and with-

out the possibility of effective judicial oversight. This

is not regulation; it is legislation.

To avoid the constitutional consequences of such a

Sweeping delegation of power, the Act must be con-

strued to impose realistic limitations on OSHA’s feas-

ibility determinations. We believe that this objective

is achieved if the agency is required to demonstrate

that its standards impose on industry no greater costs

than are necessary for the responsible discharge of

the agency’s regulatory function. This would include

a showing that the benefits to be derived from the

standard will bear some reasonable relationship to

their anticipated costs and that the standard repre-

sents a cost-efficient mode of achieving those. benefits,

The court below explicitly rejected this construction

of the Act here (Pet. App. 69-77) and in Lead, supra,

Slip Opinion at 140, n. 102.

The parties will address the statutory bases for the

construction of the Act which they advocate. It suffices

to repeat here that the construction placed on the

term ‘‘feasible’’ by OSHA and the court below serves

neither to restrain OSHA in the selection of health-

improvement alternatives nor to provide meaningful

guidelines for the exercise of the agency’s discretion,

Short of industry bankruptcy, OSHA is left free to

direct the application of massive corporate resources

12

to achieve minimal or speculative health gains. Such a

construction of the Act raises inescapably those ques-

tions of unconstitutional delegation of legislative

power foreseen in Benzene, supra, 48 USLW at 5082.

CONCLUSION

The unfettered discretion which OSHA has fash-

ioned for itself, with the approval of the court below,

to direct the restructuring of whole industries in the

name of safety and health raises inescapably the most

serious constitutional questions. However, there is

nothing in either the terms of the Act or its legislative

history or its overall purpose to suggest that Congress

intended to confer any such far-reaching authority on

OSHA. To the contrary, as this Court observed in

Benzene, supra, 48 USLW at 5033, 34, there is clear

evidence of a Congressional purpose to circumscribe

OSHA within reasonable bounds. This goal can be

achieved and difficult constitutional questions can be

avoided if the Act is read to impose practical and ob-

jective limitations on OSHA’s economic feasibility

determinations,

At a minimum these limits should include obliga-

tions to perform cost-benefit and cost-efficiency analy-

ses. Nothing less will suffice to confine OSHA to a

regulatory as opposed to a legislative role and to

insure that the costs to the American economy of the

OSH Act are not wholly disproportionate to the safety

and health benefits to be derived from it,

13

Respectfully submitted,

JEROME. POWELL

Counsel of Record

W. Scorr Ratton

Reep Smitn SHaw & McCuay

1150 Connecticut Ave., N.W.

Washington, D.C. 20036

(202) 457-6131

Of Counsel: Barton C. GREEN

Davip FEerBEeR General Counsel

Reep Smitx SHaw & McCuay American Iron and Steel Institute

1150 Connecticut Ave., N.W. 1000 16th Street, N.W.

Washington, D.C, 20036 Washington, D.C. 20036

(202) 457-6117 (202) 452-7143

November 20, 1980