Choosing an Environmental Consultant: Guidance for Small Businesses

Choosing an Environmental Consultant: Guidance for Small Businesses The New York State Environmental Facilities Corporation, Small Business Assistance Program

Disclaimer The New York State Environmental Facilities Corporation (EFC) does not certify or endorse individual consultants, contractors, or equipment for use by small businesses. This document does not offer legal advice in the selection of a consultant, contractor, or equipment. Readers are encouraged to seek their own legal counsel prior to entering into a contract for services with any environmental professional. The reader should investigate the qualifications of any environmental professional with whom they enter into a contract.

Purpose The Small Business Assistance Program (SBAP) created this guide to provide information so that small businesses that need to hire an environmental professional can make an informed decision. This guide will help you more knowledgeably hire an environmental consultant by guiding you through the proposal process listing questions to ask consultants suggesting how to review the proposals you receive from prospective consultants providing tips for negotiating a contract with your chosen consultant For an overview of the steps involved in finding and hiring an environmental professional, refer to The Process of Hiring an Environmental Consultant on page 4. The remainder of this guide explains this process in greater detail, step by step. What is the SBAP? The SBAP is located within the New York State Environmental Facilities Corporation (EFC), which is a non-regulatory, public benefit corporation. The SBAP provides small businesses with free and confidential technical assistance to help them comply with state and federal Clean Air Act requirements. The SBAP The SBAP helps small businesses comply with the Clean Air Act. operates a toll-free hotline (800-780-7227) to provide technical assistance to small businesses 1

suggests measures, including pollution prevention, material substitutions, and changes in manufacturing processes, to help small businesses comply with applicable air pollution control regulations performs an emissions inventory to establish a facility s classification with respect to regulated air pollutants (i.e., whether the facility is a major or minor emitter) assists small businesses with state permit applications and other required forms develops recordkeeping strategies for businesses to document compliance conducts technical assistance workshops statewide develops informational publications, such as compliance guidebooks, factsheets, a newsletter, and this guide, for small businesses provides on-site assistance to small businesses as necessary When To Use a Consultant New York State s SBAP was created as part of the Clean Air Act Amendments of 1990, which required every state to have an SBAP to help small businesses comply with air pollution regulations. Problems with other types of pollution, however, are outside the 2

scope of the SBAP s services. For example, your compliance project may involve addressing water pollution or hazardous waste disposal issues, and the SBAP s federal mandate is only to help small businesses comply with air pollution requirements. You may need an environmental consultant to help address these water or waste issues, since they fall outside the SBAP s scope of services. Additionally, your small business may require an environmental consultant when your needs are related to air pollution but exceed the services provided by the SBAP. For example, although the SBAP can and does help businesses complete the necessary permit applications, develop recordkeeping strategies, and suggest process changes to achieve compliance, we cannot provide engineering design services should your business need to install customized air pollution control equipment. In most cases, that work must be done by a professional engineer licensed to practice in New York State, so again, you would have to hire an environmental professional to assist you. You may need a consultant to help you address environmental issues that fall outside the SBAP s scope of services. If you have any questions about this booklet or about state or federal air pollution regulations, please call the SBAP s toll-free hotline: 1-800-780-7227. You can also reach us on the World Wide Web at http://www.nysefc.org/tas/sbap/sbap.htm. 3

The process of hiring a consultant can be broken down to a few simple steps. The Process of Hiring an Environmental Consultant Hiring an environmental consultant can be a stressful experience for a business owner or operator. After all, the primary reason you would be hiring such a professional is because your business has an environmental problem that you need to address and problems usually mean money, both in the costs to fix the problem and in potential enforcement fines. Additionally, hiring a consultant involves signing a contract, a legal document that you may or may not be comfortable preparing and reviewing. Money and legal matters are a sure recipe for stress. But the process of hiring a consultant can be broken down to a few simple steps, which, if followed carefully, can alleviate your anxiety and help you resolve your business environmental problems. To hire an environmental consultant, you will need to complete the following steps: 1. assess your specific environmental project and what you need to accomplish (see page 5) 2. understand the services that consultants provide (see page 9) 3. find consultants to bid on your project (see page 10) 4. understand the elements of a proposal (see page 11) 5. request proposals from several consultants (see page 12) 4

6. review these proposals to see how they compare to your needs (see page 13) 7. negotiate a contract with the consultant you select (see page 19) 8. carefully review, then sign the contract (see page 24) 9. ensure a good working relationship with your chosen consultant (see page 26) 10. take appropriate steps upon project completion (see page 27) The following sections describe these steps in detail and provide tips for successfully completing each step. Remember, however, that only your attorney can provide legal advice. If you need additional information about hiring environmental consultants, see Sources for More Information and Referral on page 28. Understanding Your Needs Starting an environmental project using your own personnel can save you money in the short run, but hiring an environmental consultant to supplement your in-house staff may help you complete the project more efficiently. The skills and areas of expertise that environmental professionals have to offer vary greatly, however, so you ll want to be sure your project s scope matches your consultant s abilities. To do so, you ll need to understand both your own project s needs and the consultant s role Hiring an environmental consultant to supplement your in-house staff may help you complete the project more efficiently. 5

(explained in the next section). Use the following three-step process to assess your project s needs: Ask yourself a few key questions to shape the objectives of your project. Step 1. Review Your Project s Objectives Review the objectives of your project, making sure they are specific and well defined. To help shape these objectives, answer the questions below. In some cases, you may want to have an environmental consultant help you answer these initial questions (for a fee). When you re ready to implement any of their suggested changes, solicit proposals from additional consultants (see Identifying the Elements of a Proposal on page 11). What environmental regulations apply to your business? (the SBAP can help you with this) What changes will be necessary to achieve compliance with these regulations? You may not have all the answers to this question, but you can make a start. If your business is already in compliance with the applicable regulations, what are your other environmental objectives, such as pollution prevention? What is the timetable for completing the project? If you re already out of compliance and/or under a Consent Order from the Department of Environmental Conservation (DEC), time may be of the essence to avoid potential penalties. If your compliance deadline hasn t arrived yet, the timetable may be less urgent. 6

How much money can your company devote to the project (both in capital costs and consulting costs)? What are the projected cost savings and payback period of the project? Don t forget to include any tax savings that may be available as a result of your project. Consult your accountant for specific tax advice. What is the company s commitment to the project? In other words, is it willing to make changes that may affect production processes? What parts of your operation, if any, will require changes to meet your objectives? If changes to production processes are required, will your staff need to change the way they do their jobs and will they need to be trained to properly implement production process changes? If so, be sure to involve your staff in the decision-making process. How much of the project work can be done by your staff and how much must be done by an outside person or firm? What resources are available free-of-charge through equipment vendors and public information sources, such as libraries and public technical assistance programs (the SBAP, trade associations, Small Business Development Centers, etc.), to help you complete your project? The next two steps will help you plan your project and assess its impact on your business. 7

Step 2. Plan Your Project Plan how you will meet your project objectives. It helps to write down the steps that are necessary to complete your project. Develop a preliminary timetable for completing the project. Step 3. Assess Your Project s Impacts Assess how changes, such as process or product changes, material substitutions, and disposal cost reductions, will affect your business operations, its profitability, and what regulatory requirements apply. The process of writing up your project so that consultants can bid on it will often help you identify additional questions you ll need to answer. After you ve completed these three steps and answered the questions within them, you should take a moment to write up a brief summary of your project. This will help you to provide the same information to each consultant you invite to submit proposals for your project (more on that later). The process of describing your project on paper so that a consultant can submit a proposal will often help you identify additional questions you ll need to answer for your specific project. If possible, put your written description aside for at least a day, then read it over again, share it with your staff to get their input, and make any needed changes before showing it to prospective consultants. 8

Understanding the Consultant s Role and Services Based on your assessment of your project s needs, you should have a pretty good idea about what kinds of help you ll need from an environmental consultant. The specific services provided by consultants vary, based on their areas of expertise. However, depending on the contractual arrangements, consultants generally will do the following: provide expertise in certain areas provide an independent assessment of your situation help with interpreting regulations and seek interpretations from the state and federal regulatory agencies on your behalf act as a temporary supplement to your staff resources and knowledge base provide technical and economic analyses of alternatives and conduct feasibility studies develop recommendations provide design and engineering support conduct sampling and laboratory analysis help with permit applications and report writing assist with equipment selection and purchasing assist with implementing operational changes and startup complete one-time projects support operation and maintenance of your facility perform annual tasks, such as facility reviews 9

Generally, consultants are hired to provide customized solutions. Although environmental consultants can provide many services to improve your business operations and productivity, remember that you are the expert about your company; consultants can only enhance your expertise. Don t depend on consultants to do any of the following: Make decisions for you. You need to evaluate what will work for your business. Purchase specific products. Find out if the consultant receives compensation when you buy recommended products through them. If so, the product they recommend may not be the most cost effective. Provide standard services. Generally, consultants are hired to provide customized solutions for clients. Finding Consultants Several resources are available for finding consultants in your area: call the SBAP for a list of the environmental consultants in your area who responded to our request for information and qualifications check your local telephone listings under Air Pollution Control Environmental or Ecological Services Engineers Professional Water Pollution Control conduct a search on the Internet 10

read publications from trade or industry associations in your industry sector talk to other business owners in your area to get recommendations Using these resources, develop a list of a half-dozen or so consultants. These are the consultants that you will speak with about submitting a proposal to complete your project. Identifying the Elements of a Proposal Simply put, a proposal is a consultant s estimate to perform specific work on your project. It s a consultant s written analysis of what he or she will do to address your environmental problem and how much his or her services will cost. At a minimum, each consultant s proposal should do the following: respond to your project s needs based on the written description you provided each consultant spell out exactly what services the consultant will provide to complete your project include a project timetable that covers both consultant s time and your staff s time so you will know when major milestones will occur and when and for how long your staff will be involved in the project indicate if and for how long your facility may need to be shut down to complete elements of the project A proposal is a consultant s written analysis of what he or she will do to address your problem and how much his or her services will cost. 11

explain all fees and equipment costs clearly include billing procedures for deposits, partial payments, and final payment provide references relevant to your project so that you can assess the quality of the consultant s work A consultant s written proposal should also clearly spell out the following: responsibilities of your company s personnel responsibilities of the consultant what personnel from the consulting firm are assigned to the project, their experience levels, and their billing rates what items are specifically not included in the proposal A good rule of thumb is to have at least three proposals to review. Requesting Proposals When you request a proposal from each of the consultants you identified above in Finding Consultants, give each the written description of your project that you developed earlier. Take a look at the evaluation criteria in the next section ( Reviewing Proposals ) for ideas on what to ask for in the proposals they prepare. Using these criteria, you may want to prepare a cover letter to the consultants that lists the elements you expect their proposals to include. Provide this letter with your written project description. 12

A good rule of thumb is to have at least three proposals to review, so you may want to ask for proposals from more than three consultants, in case one or more doesn t respond in a timely fashion or isn t interested in bidding on your project. Be sure to indicate a deadline for consultants to submit proposals to you. Reviewing Proposals As part of your review of each proposal that you receive from a consultant, evaluate them according to the following factors. Some of these factors may require you to do additional research about the consultant. Work Experience A consultant s work experience is one of the most important criteria for reviewing the proposals, since you want to find a consultant with experience in solving your particular type of problem. Be sure the consultants have included descriptions of previous projects in their proposal. Consultants frequently submit a standard statement of qualifications package with their bids, which provides a history of the company, background on key personnel, and a select listing of project experience. How similar were these projects to the type of work you need? Review proposals by examining a consultant s work experience, professional references, credit references, and prices, and by considering your working relationship with them. 13

A consultant s training and experience should be related to the type of work to be performed on your specific project. What are the consultants specialties? Proposals should include resumes of staff who will be working on your project. If they do not have specialized knowledge in the area of pollution control, who will they be calling on (or using as a subcontractor) to help solve your particular problem? Have they worked with other experts with appropriate experience? If so, ask for the names of these experts and contact them for reference information. The proposal should include descriptions of the technical training the consultant s staff has received and the experience of staff. If it doesn t, ask for this information. The proposal should also indicate what professional licensing, such as a Professional Engineering License, or certifications the staff has. It is important for their training and experience to be related to the type of work to be performed on your specific project. You are hiring people with specific expertise make sure that expertise matches your project needs. Professional References It s always wise to have prospective consultants include a list of three or four former clients in their proposal so you can contact these references and ask them about the consultant s performance. The following are some suggested questions to ask former clients: 14

Ask them to describe the type of work the consultant did. Was it the same or similar to your project? Find out if the work was completed on time and at the agreed-upon cost. If not, why? Ask if they were satisfied with the work and why or why not. Find out if any unforeseen problems arose during the project. If so, what were they and why did they occur? Was the consultant willing to troubleshoot the problem? How were problems resolved and were they resolved to the client s satisfaction? Check with your local Better Business Bureau. Ask if they have any information about each consultant either good or bad. This could help you to learn more about the consultant and how he or she does the job. You can use a computer and the World Wide Web (available at many local libraries if you don t have access at your business or home) to check on a consultant s Professional Engineering license status in New York State. Visit the New York State Education Department s website at http://www.nysed.gov/dpls/opnme.html to search for a particular consultant by name within their profession. 15

Ask each prospective consultant for the names of industrial or professional associations to which he or she belongs. Contact these organizations to see if the consultant is a member in good standing (is upto-date with their dues, has taken any required continuing education courses, etc.). Find out if the prospective consultant has published any articles in the scholarly journals of their field. If the articles relate directly to your environmental problem, you may want to read them check with your local library to see if they either have the journal or can obtain a copy of the article(s) for you. A consultant must have the financial resources to undertake and complete your project. Credit References In order for your project to be successful, the consultant must have the financial resources to undertake and complete the project. The following are suggestions to help ensure that the consultant you select is financially sound: Ask to see a copy of the consultant s liability insurance policy. Contact the insurer to verify that the policy is in force, that the premiums have been paid, and that the insurance covers liability for your type of project. Request a copy of the insurance statement and ask for updates when they are due. Verify that the consultant s Workers Compensation Insurance is valid for their employees working at your site. You want to be sure the 16

consultant s insurance policy would cover their employees if one should be injured on your property. Check the consultant s credit with his or her banks or a credit service. For a fee, a credit service will provide you with a summary of a consultant s credit history. Working Relationship In addition to evaluating a consultant s professional and financial references, you should consider your own working relationship with a consultant. The following list includes some of these considerations: Who will be the consultant s representative for your project? That person should be identified in the proposal. Talk to them about the project. Is it someone with whom you feel comfortable? How available will the consultant be to answer questions or respond to problems, both during and after project completion? How close is the consultant s office to your business? If they are based in another city, will the distance slow the pace of work, reduce the consultant s availability, or increase the project s cost? Will the consultant accommodate your business operations by scheduling on-site work during off-hours or after-hours? Such accommodations should be clearly spelled out in the 17

proposal. Will work by the consultant during your peak hours of operation (if required) significantly affect your business? Keeping all of these considerations in mind when choosing a consultant will help you select one with whom you can build a solid relationship while addressing your environmental project. You can t always compare apples to apples when it comes to price quotes, so ask additional questions about consultants proposed fees. Prices Price quotes may be difficult to compare since proposals from different consultants will take different approaches and use different pricing strategies. Since you can t always compare apples to apples when it comes to price quotes, gather as much information as you can by asking additional questions about consultants proposed fees. Consider these tips to help you make an informed choice: One consultant may give a lump-sum figure, whereas another may charge a lump sum plus the costs for samples. If the quote is for a fee plus samples, ask how many samples they expect will be taken and what each will cost. The specifics of your situation might make it difficult to determine the extent of the environmental problem until a detailed investigation begins. In that case, a consultant is likely to charge for both time and materials for the duration of the project. If that s how a proposal is priced, be sure the proposal lists the 18

hourly rates of the consultant s staff and any anticipated expenses, such as travel, samples, or equipment. Some price quotes that use time and materials may include a maximum cap or a dollar amount beyond which the consultant must get your approval to proceed. Compare quotes not only by price, but by what specific work is to be done. Occasionally, a consultant will offer a lower initial bid to get their foot in the door, and, after the project has begun, add costs for work that should have been included in the original proposal. Make sure the proposals cover similar amounts of work before you compare their individual prices. Negotiating the Contract After you select a consultant for your project, it s time to negotiate the details of the work and the terms of the contract. For you to successfully negotiate a contract with the consultant, you must 1. understand the contract 2. anticipate and resolve problems before they occur Understanding the Contract Usually your consultant will have a standard contract form that has blanks for information specific to your project. If you want to write your own contract or add specific provisions to the standard contract, then you, your lawyer, and your consultant should 19

agree on the wording of all clauses. The consultant s lawyer may also be involved because a contract is a legal document and it involves money. Contracts usually include the following items: Withhold at least 10% of the payment until you accept the project as complete. A description of duties, i.e., what the consultant will do as part of your project. In some cases and if it is acceptable to you, the consultant will include their original proposal for your project as an element of the contract. Warranties or performance guarantees, i.e., what work is guaranteed and what the consultant will do if work isn t completed properly. The starting date for the project and the time period for completing the work. This section of the contract should include (a) key milestones and the requirement for any progress reports and (b) a penalty clause for late completion. The price and terms of compensation; prices may be stated as a fixed fee (one price covering all work), as time spent plus materials required, or in other terms. Note that partial payments usually are made up front and at agreed-upon points in the project (such as 30%, 50%, and 80% complete). Consider withholding at least 10% of the payment until you accept the project as complete; this may provide you with some leverage should you and the consultant not agree on how the project was completed. 20

The use of subcontractors, i.e., whether subcontractors will be used on the project and whether the consultant charges a fee to manage them, in addition to the actual cost of the subcontractor. The confidentiality of the information you make available to the consultant during the course of the project; look for a non-disclosure clause that would keep a consultant from revealing anything he or she learns about your business if you are concerned about such information. Liability, indemnity, and hold harmless clauses, i.e., what financial or other responsibilities you or the consultant will have if certain events should happen, such as accidents or errors, during the course of the project. Conditions for modifying the contract, which is important should you wish to make any changes to the contract during the course of the project. The governing law, i.e., what state s laws will govern the implementation of the contract and any questions that arise later. This is typically only an issue if your business is located in one state and your consultant is located in another. Legal advice is very helpful in developing and reviewing a contract. Seek legal advice before signing a contract, especially if you are not comfortable with the provisions or if you do not understand them. Remember, the contract is a legal document. Only a 21

licensed attorney is qualified to give you legal advice about a contract or any other legal matter. Try to identify problems that might arise during the project and address them in the contract. Anticipating and Resolving Problems You should try to identify problems that might arise during the course of the project and address them in the contract. For example, you might want to anticipate the following issues that occur frequently during environmental projects and include solutions in the contract: Testing any equipment. Contracts for the construction and/or installation of any equipment should require the consultant to test the equipment after it has been installed. The project should not be considered complete until such testing is successful. Testing can be done by a neutral third party, which may allow for a more-accurate testing procedure. Maintenance and repairs. The contract should say who is responsible for the maintenance and repair of any equipment after it has been installed. The contract should define the activities and specify who is responsible for each activity. Work site and space. The contract should indicate whether you are responsible for providing a work space for the consultant onsite, if a work space is necessary. 22

Hazards to employees and/or customers. If the work involved in your project might pose a hazard to your employees or customers, you ll want to minimize that risk by having the work performed during off-hours or in other ways to prevent injuries. The contract should indicate when work is to occur and the other steps the consultant will take to prevent hazards. It should also specify who is liable should injuries to employees or customers occur during the project. Be sure to involve your attorney in any discussions about liability. Additional expenses. The contract should define how unforeseen project expenses will be handled. In most cases, you will want to be contacted for your authorization before such expenses are incurred. Inaccurate recommendations. The contract should address the possibility that the consultant s recommendations are not appropriate. The contract should specify what actions the consultant must undertake to correct the effects of false or inaccurate information without additional charges. Require consultants to have Errors and Omissions liability coverage. Permits and recordkeeping. If a permit or other paperwork is required, you may want the consultant to complete your application for submittal to the New York State Department of The contract should specify who is liable should injuries to employees or customers occur during the project. 23

Environmental Conservation (DEC) or the US Environmental Protection Agency (EPA). If compliance with a regulation requires you to maintain records or submit periodic reports, you may want the consultant to design a recordkeeping system or report templates for you (but see Ownership of a work product below). Include these tasks in the contract if applicable. Ownership of a work product. If a consultant prepares a report, plans, maps, specifications, management system, etc., for you, you may want to ensure that you own that work product. Clean up. The contract should specify who is responsible for removing any debris or construction material that results from your project. This list is not exhaustive. You should carefully plan for potential problems by having the contract include provisions that spell out how such problems will be handled if they arise. Read every word of the contract and any attachments and consult with your attorney before signing. Before Signing the Contract A Final Review After you select a consultant and have negotiated a contract, the next step is to carefully review the final contract before signing it. Consider the following advice: Read every word of the contract and any attachments and consult with your attorney. If you have a partner and/or accountant, have 24

them read it too. In a written contract, every word is there for a reason; therefore, make sure that you agree with every word. Make sure every item you want is written into the contract. Otherwise, you probably will not get it, regardless of what the consultant or his or her representative may have told you, since the contract itself is the binding legal document. Don t feel pressured to sign a contract immediately. If you need time to read the contract or to seek legal advice, wait a day or two before signing. If the consultant really wants your business, he or she should be happy to give you this time. Obtain signed lien waivers from your consultant and/or suppliers. Such waivers will protect you in the event that your consultant does not pay his or her subcontractors or suppliers. If this were to occur, the subcontractors and suppliers could sue you, even though you already paid the consultant. Your only protection from such a suit is a lien waiver. In order to ensure that the waiver is executed properly, you should consult an attorney for help, especially if the dollar amount of the contract is large. Check with your insurance agent or legal counsel to see if you need additional insurance for your property, employees, or customers during the course of the environmental project. Obtain signed lien waivers from your consultant and/or suppliers. 25

Don t pay in full for the project when you sign the contract or before the project is completed. As the previous section indicated, the contract should state the terms of payment. Make sure the contract includes a plan for the phased completion of the project and associated payments, and follow this schedule. Keep the lines of communication open between you and your consultant. Ensuring a Good Relationship This project may be the beginning of an on-going relationship with the consultant. Or you may only need a consultant once in the life of your business. In either case, the success of this particular project will depend in large part on the quality of your working relationship with your consultant. Follow these tips to help achieve a good working relationship: Have a clear idea of what you expect to achieve from the project. Express these expectations to your consultant, both in your written project description and in your routine personal interactions with the consultant. Keep the lines of communication open between you and your consultant. Be available during the project for the consultant to contact you. Keep a written record or notes of your meetings or discussions to help everyone stay on track. Consider having meetings at a neutral site, or alternate meeting locations between your 26

offices and those of your consultant. That way, neither of you is always the visitor. Keep up with the consultant s progress and make sure that both of you meet contractual expectations. Follow up in writing to the consultant whenever there are significant problems with the project or performance under the contract. Also document any changes to the project. A separate contract may be required for additional work. If your consultant fills out your permit or other documents for submittal to DEC or the EPA, make sure you read and understand these documents and their implications before you sign and submit them. Have the consultant explain these documents, their terms, and conditions if you have any questions. After Completing the Project After the project is complete, you should review the contract. Have you done all of the things that you agreed to do in the contract? Has your consultant? For example, has any debris created during the project been removed? Any money still owed to the consultant will be due at this time, in accordance with the contract s provisions. Review the contract after the project is complete. 27

Sources for More Information and Referral You may obtain additional information about hiring environmental consultants from the following resources: trade and professional business associations (referrals and guidance) trade magazines and journals (advertisements and guidance) legal counsel (referrals and guidance) other companies in your industry (referrals) county or university extension agencies (guidance) Better Business Bureau (reference information) Small Business Development Centers (guidance) Small Business Administration offices (guidance) Yellow Pages (advertisements) Dun s Consultants Directory provides a listing of consultants by area of expertise and location. This directory is updated annually and is available in the business reference section of your local public library. The SBAP has a state-wide list of environmental professionals who responded to our request for information and qualifications. Call us for a list of consultants in your area. 28

Acknowledgments The SBAP expresses its appreciation to the Texas Natural Resource Conservation Commission and the US EPA for providing source material for this document. Help for Small Businesses The Small Business Assistance Program (SBAP), provided by the New York State Environmental Facilities Corporation, gives technical assistance and help with permitting to small businesses that must comply with the Clean Air Act. For help, call the SBAP hotline: 800-780-7227. The SBAP s program partner, the Small Business Environmental Ombudsman (SBEO), provided by Empire State Development, gives information about regulations and financing and helps with resolving regulatory issues. For help, call the SBEO hotline: 800-STATE-NY. Both the SBAP and the SBEO offer free and confidential help to small businesses with fewer than 100 employees. 29

New York State Environmental Facilities Corporation Small Business Assistance Program 50 Wolf Road Albany, NY 12205 800-780-7227 (within New York State) 518-457-9135 (outside New York State) 518-457-8681 (fax) http://www.nysefc.org George E. Pataki, Governor John Cahill, Chairman EFC Terry Agriss, President EFC printed on recycled paper using environmentally friendly, soy-based ink 1Q99