Speak up Now! The IRS seeks public comment on law: a 3% withholding tax required by all government contractors

Companies that do business with government entities should be aware that in May 2006 both the House and Senate passed the Tax Increase Prevention and Reconciliation Act of 2005, Pub. L. No. 109-222 (TIPRA). Accordingly, the Internal Revenue Service recently posted a notice regarding the new requirement for government entities to withhold three percent on payment for property and services. The IRS is seeking public comment on this notice by April 28, 2008. If implemented, this notice will impact companies with existing government contracts that expire after December 31, 2010. To read Notice 2000-38 visit the IRS website: http://www.irs.gov/govt/fslg/article/0,,id=180377,00.html

Government Withholding Relief Coalition

The DoD reports on their cost estimate for compliance with the 3% withholding law. Their estimate is $17 billion for the first five years.

The report states:

DoD anticipates the costs for DoD to comply with section 511 will be significant – over $17 billion for the first five years. The estimated cost impact includes the costs for DoD to implement and manage section 511 within DoD and the additional costs escalation DoD will pay its contractors as a result of section 511. Further, DoD is concerned that section 511 may limit the number of companies willing to enter into the government market, thereby reducing competition and access to new technologies, and may cause other unintended consequences that are addressed in the report.

Click here to read more.

New Health Care Legislation Targets Small Business

Health care is a hot issue in Campaign 2008, and we can expect to see a host of health care solutions proposed in Congress starting now and continuing into next year. In recent weeks, leading Senators have introduced two approaches that seek to help small business owners facing major increases in the cost of health insurance. The Small Business Health Plans Act (S. 2818), introduced by Sens. Enzi (R-WY), Nelson (D-NE), and Gregg (R-NH) is the latest and revised edition of a proposal that has passed the House on several occasions in recent years. This plan creates a version of Association Health Plans (AHPs) where small businesses are permitted to purchase insurance through trade associations who contract with insurance providers and are thus able to pass on lower costs.

A different approach is offered in S. 2795, the Small Business Health Options (SHOP) Act of 2008, takes a slight different approach. Introduced by Sens. Durbin (D-IL), Snowe (R-ME), Lincoln (D-AR), and Coleman (R-MN), the SHOP Act would create national and state-run insurance pools for small employers. The self-employed would also be included in these packages. The bill also provides employer tax credits (up to $1000 per employee) to help encourage participation in the pools.

Learn more about S. 2818, the Small Business Health Plans Act, and S. 2795, the Small Business Health Options Act, visit the Library of Congress’ THOMAS website.

All stories © 2008 The Public Forum Institute, National Dialogue on Entrepreneurship www.publicforuminstitute.org/nde.

IBM Suspended from Federal Contracts

IBM has been hit with an unexpected suspension preventing it from entering into new business with US federal government agencies, as a result of an ongoing investigation by the Environmental Protection Agency (EPA). The temporary suspension comes after the EPA alleged the computer giant violated procurement laws while negotiating a contract with the agency.

An IBM press release states that the notice of temporary suspension was issued by the Environmental Protection Agency (EPA) and relates to an investigation by the EPA of possible violations of the Procurement Integrity provisions of the Office of Federal Procurement Policy Act regarding a bid for business with the EPA originally submitted in March 2006. The temporary suspension applies to all Federal agencies and IBM business units. IBM may continue awards in existence as of the date of this suspension, unless a particular agency directs otherwise.

In addition, the U.S. Attorney’s Office for the Eastern District of Virginia has served IBM and certain employees with grand jury subpoenas requesting testimony and documents regarding interactions between employees of the EPA and certain IBM employees.

IBM has served the Federal agency community for many decades as a vendor in good standing and is committed to the highest standards of business ethics. IBM provides training on its Business Conduct Guidelines to all employees, with specialized training to those employees working on matters with the Federal government, to ensure compliance with all applicable Federal requirements.

Prior to learning of the temporary suspension on March 28, 2008, IBM was not aware that the EPA or U.S. Attorney’s office were considering any action against IBM. Upon learning of the suspension, IBM initiated discussions with the EPA and the U.S. Attorney’s office to obtain additional information and is cooperating with the investigations.

Under Federal procurement procedures, IBM has 30 days in which to contest the scope of the temporary suspension, which can continue for an initial period of up to one year pending the completion of the investigation. IBM intends to take all appropriate actions to challenge the suspension and limit its scope.

Is Health Insurance for Small Businesses and the Self-Employed Prohibitive?

Many small business no longer offer health insurance, and self-employed individuals are have dropped coverage because they cannot afford it. This article in the NY Times has very good information about your options.

“…. an expert on health insurance issues, shared a valuable tool, healthinsuranceinfo.net. The site, maintained by the Georgetown Health Policy Institute, shows a map of the country and after clicking on a state, a document is downloaded that covers everything from what kinds of programs are available to small-business owners to whether there is a high-risk pool available for those who have been rejected by insurance providers. These primers are comprehensive and frequently updated, and they are a great place to start, especially if you have been wondering about the meaning of jargon that peppers insurance providers’ descriptions of their offerings...”

An excerpt from the NY Times article: Finding Health Insurance if You Are Self-Employed

Click here for more info.

ORDP-SSA Internship Opportunities

The Office of Retirement and Disability Policy of the Social Security Administration (SSA) is currently accepting applications for summer internships. Projects involve current and future issues for retirement and disability, such as the analysis of economic/social well-being, labor force participation, financial literacy, benefit applicants, work incentives, international policies, non-citizen issues, authentication, and evidentiary standards. Other opportunities include statistical reporting of beneficiary population characteristics (such as demographic characteristics, immigrant status, or patterns of employment history), computer programming, and developing business process applications.

Deadline: Several internship positions are available, and applications will be accepted on a flow basis. The first review will occur on Monday, March 24, 2008. Individual start dates will occur in May or June.

Click here for more information.

TargetGov Heads Up Alert:

Beware of all offers of grants to start or run your business. There are NO legitimate US government grants to start or run your business. No federal goverment entity, not even the SBA, gives any grants to business people to start or run your business. Anyone who markets or advertises as such is offering misleading in not fraudulent imformation. Essentially, they are trying to run a con game on you. Don't fall for it!

Small Business Development Conference

The Office of Congresswoman Thelma Drake has begun accepting registrations for the Small Business Development Conference on

DATE: Friday, March 28th, 2008
TIME: 8:00am to 12:00pm
LOCATION: Virginia Beach Central Library, Auditorium, Folio, & Libris Rooms
4100 Virginia Beach Boulevard Virginia Beach, Virginia

The Conference will offer separate tract sessions providing a comprehensive, informational opportunity to address your business' changing needs.

Federal, State and local resources will be on hand to present on topics and resources for small business owners, with tract sessions to include:
* Start-Up Business Development
* Advanced Business Development
* Procurement Opportunities

Please contact Ms. Claire Winiarek, Grants and Projects Coordinator, Congresswoman Thelma D. Drake (VA-2), directly to RSVP via 757.497.6859 or email: claire.winiarek@mail.house.gov. Ref: "TLI" as your point of entry.

Workforce Solutions Summit

Baltimore Washington Regional

Breakout Sessions    Exhibitor Tables     Resource Guide

In collaboration with local, state, and federal governments, the educational community, and private employers, the Baltimore Washington Corridor Chamber is developing a half-day summit focused on workforce issues such as:

• BRAC: The largest impact on Maryland’s economy since World War II…
• Fifty percent of my workforce will reach retirement age in the next five years…
• I can’t get enough people with security clearances.
• How can I expand my business if I can’t get the workforce I need?
• How do I find employees from diverse workforce resources?

Download the registration form for more information.

Acuity Sports Insights for Business and Golf

Golf—The Sport of Business: From the trade show floor to the putting green, many organizations are leveraging the power of golf. Golf provides the perfect social and professional environment to facilitate relationships. A day on the links provides an unmatched opportunity for uninterrupted conversation with customers, prospects, and employees. Many people do it, but are not necessarily comfortable with what they should or should not be doing and saying. This workshop is ideal for those new to business golf, Women and Minorities who want to learn how to use golf to enhance business and open doors, and sales professionals who want to learn how to make golf work for them in business.

Acuity Sports Marketing is a professionally managed golf event planning and management firm. They specialize in designing world-class events for first class clients. Whether you are looking for a classic golf tournament for your favorite charity, a special golf-themed event to impress your clients at conventions or large meetings, a team-building session to enhance the effectiveness of your team or simply, a way to say thank you to your employees for a job well done, Acuity Sports Marketing can design, delight and deliver a spectacular event for you. Their professional staff has managed over fifty high-quality events and are eager to customize an event for you.

Acuity Sports Marketing, www.acuitysports.com/

Tip to Recession-Proof Your Business

You can make your business more recession-proof by having the U.S. federal government as a customer. Every year, over 200 agencies throughout the entire U.S. buy over $400 Billion in products and services of every type from businesses of every type and size. Advantages of selling to the federal government include large contracts, repeat business, guaranteed payment and a built-in referral base. Businesses of all sizes, from very small, one person operations to small/medium companies up to 500 people to large corporations, have all become successful government vendors. Selling your products and services to the federal government is different from selling to consumers or other businesses, but if you invest in learning how to it, follow the rules, and are persistent, you can build a recession-proof business!

We Did It -- So Far

SBA Rule Comments Period Extended!
Let them know what YOU Think

Women-Owned Businesses: The SBA is extending the comment period for its proposed rule on women-owned small business federal contract assistance procedures. Comments must now be received by March 31, 2008. The extension is a result of the significant level of interest in the proposed rule.

Go online to www.wipp.org to take action!

It is Time to Spring Forward

Soon the days will be longer and we can enjoy a little more sunshine. This coming Sunday, March 9, 2008 it's time to spring your clocks forward to Daylight Saving Time.

Most of the United States begins Daylight Saving Time (DST) at 2:00 a.m. on the second Sunday in March and reverts to standard time on the first Sunday in November.

During DST, clocks are turned forward an hour, effectively moving an hour of daylight from the morning to the evening.

Click here for more information on Daylight Saving Time.

Women in Government Contracting National Teleconference for Women: Reach for the Goal Now

Washington, DC. The national teleconference, “Women in Government Contracting” will be held Thursday, March 6, 2008 from 1:00 to 2:00pm EST (noon CST, 11:00 am MST and 10:00 am PST). There is no cost to attend the teleconference for any woman or anyone who works for a woman-owned company located anywhere in the United States. No wasted travel time or expenses, attend directly from any phone. Phone lines are limited to the first 500 people to register.

Are women setting their government contracting goals high enough? Five percent of the $400 Billion Federal Contracting Budget is targeted to go to small businesses owned by women – that is $20 BILLION Dollars. That goal has never been reached. Government contracting can be a very lucrative market for savvy business women. And the federal government buys virtually every type of product and service available. Any business that wants to win a government contract must be registered with the federal government.

There are over 2,000,000 women-owned businesses in the U.S and only 55,000 are registered as government contractors. In one hour, at no cost, learn how to become registered as a federal government contractor and tackle the world’s fortune one customer: The U.S. Federal Government.

Attend this national complimentary teleconference to learn how to open the doors to government contracting. Hear from women business owners who have already become successful in this market. Learn the specific steps to become registered. Learn about the no-cost support services available directly from the federal government that will help you begin your government contracting business.

To register for this teleconference go to www.targetgov.com and click on the “Teleconference” button in the upper right corner of the home page. Select the Women in Government Contracting teleconference. Or call toll free 1-866-579-1346 to register.

Gloria Berthold is the host of the teleconference and is President of TargetGov at Marketing Outsource Associates, Inc. which focuses on government procurement and related business development services. She is Procurement Committee Co-Chair for Women Impacting Public Policy (WIPP); author of The Veterans Business Guide: How to Build a Successful Government Contracting Business (book); an international speaker and she has created a series of Government Business Guides highlighting specific federal agencies and business opportunities. She has been interviewed on television and radio shows and has been quoted in national publications such as USA Today, Government Executive and Entrepreneur magazine.

Gloria Berthold Speaks: The Art of Entrepreneurship

Come hear Gloria Berthold, President, Marketing Outsource, Inc., and Targetgov speak at "The Art of Entrepreneurship."
The "Art of Entrepreneurship" is the 2nd Annual Johns Hopkins University Carey Business School Entrepreneurship Conference.

March 8, 2008 Downtown Center Baltimore 8:30 a.m. - 2:30 p.m.

$25 in advance; $40 at the door, space permitting. Payable by credit card or check.

Register Now | Payment Form | Get Directions

A Cautionary Tale About Sharing Passcode

Court Order Requires Two Companies
to Pay CoStar $100,000 for Passcode Sharing

Bethesda-based CoStar Group has announced that a Maryland federal court recently entered an order requiring Laser Marketing, a marketing firm doing business under the name Atkinson Hunt, and Resource Realty, both of southern New Jersey, to pay CoStar $100,000 to settle charges that the two firms shared a CoStar passcode in order to gain unauthorized access to CoStar’s real estate information database.

The court also entered a permanent injunction restraining Atkinson Hunt and Resource Realty from engaging or assisting in any future unauthorized use of CoStar services.

The court found that Resource Realty provided Atkinson Hunt with a CoStar passcode that had been assigned to an approved subscriber at Resource Realty. Using fraud detection technology, CoStar determined that the passcode assigned to Resource Realty was used illegally and repeatedly from the offices of Atkinson Hunt to access CoStar’s information services.

“The thousands of honest subscribers who invest in CoStar’s service for the competitive advantage it offers expect CoStar to provide the most complete and highest quality information service we can at the lowest cost possible. When some users illegally resell or share CoStar passcodes with unauthorized users, they are really stealing from CoStar’s legitimate subscribers,” said Jonathan Coleman, CoStar Group’s general counsel.

Recently, the company also announced a $1 million judgment to settle a lawsuit against Centers & Malls, a Lake Forest, Ill., limited liability company, for infringing on CoStar’s copyrighted commercial real estate information.

Thanks to The Business Monthly at www.bizmonthly.com for this story

OSDBU Procurement Conference: Registration Is Open

We are now accepting exhibit space reservations for the 18th Annual OSDBU Procurement Conference, April 24, 2008 held at the Showplace Arena in Upper Marlboro, MD. For 17 years, FBC and the OSDBU Directors Council, have been successful in bringing together small businesses, large corporations and government agencies for this dynamic one-day Procurement Conference. In 2007, exhibit space was sold out with over 375 exhibitors and 2750 industry and government attendees.

Registration Now Open

Exhibitors: There are a variety of ways for your company to have a presence at OSDBU. Exhibit Space is available for Prime and Small Businesses as well as additional sponsorship opportunities to enhance your exposure. Please ask your FBC Account Manager about these opportunities.

Attendees: For more information and to register, please visit the OSDBU Website.

Attendee and Exhibitor Website: https://www.fbcinc.com/osdbu/registration.asp

Procurement Matchmaking Procurement Matchmaking "matches" small company "sellers" with participating "buyers" represented by government agencies and large business Prime Contractors. These buyers and sellers will convene for a series of one-on-one meetings that will occur throughout the OSDBU event in a special matchmaking meeting room. This opportunity is a first come, first serve basis and sell out quickly so do not wait!

To learn how to participate in Procurement Matchmaking, click here...

Additional Information

For more information on exhibit space, sponsorship opportunities, and attending the 18th Annual OSDBU Procurement Conference, visit the OSDBU website or contact us your FBC Account Manager at 800-878-2940 or bj@fbcinc.com.

Conference Website: www.fbcinc.com/osdbu

New Tools to Measure Innovation

In late 2006, Secretary of Commerce Carlos Gutierrez announced the creation of a blue ribbon Advisory Committee on Measuring Innovation in the 21st Century Economy. The panel was chaired by Carl Schramm, president and CEO of the Ewing Marion Kauffman Foundation, and was composed of leading business executives and experts from academia. It was asked to review how the US government tracks and measures innovation and to provide recommendations for how measurement systems can do a better job of tracking new forms of innovative activity. The panel released its findings earlier this month, and its report should be considered a “must-read” for anyone with an interest in the innovation economy.

The Committee began its work with a basic working definition of innovation: “The design, invention, development and/or implantation of new or altered products, services, processes, systems, organizational structures, or business models for the purpose of creating new value for customers and financial returns for the firm.” This definition helped set important guidelines for the Committee’s work. Their work focused on measuring the creation of new value, not just something new. In addition, the Committee recognized that effective innovation measurement must go beyond tracking inputs such as R&D spending; it must also track outcomes for firms, customers, regions, and nations.

The report includes a series of recommendations for both government and business. For government, the Committee recommends better coordination between government statistical agencies, increased access to government data sources for outside researchers, and enhanced funding to create a stronger framework for measuring innovation. For business, the Committee recommends that corporate leaders provide expanded support for the creation of new firm and industry-level measures of innovation. Business leaders should also actively participate in innovation research activities.

Download the January 2008 report of The Advisory Committee on Measuring Innovation in the 21st Century Economy, Innovation Measurement: Tracking the State of Innovation in the American Economy.

© 2008 The Public Forum Institute and the National Dialogue on Entrepreneurship www.publicforuminstitute.org/nde.

Alternative Financing For Government Contractors

Alternative Financing For Government Contractors©

When Significant Capital Needs Precede
Customer Payments on Government Contracts

Richard Lewis, Vice President,
Wells Fargo Business Credit, Government Services Group

“While poor management is cited most frequently as the reason businesses fail, inadequate or ill-timed financing is a close second. Whether you are starting a business or expanding one, sufficient ready capital is essential. However, it is not enough to simply have sufficient financing; knowledge and planning are required to manage it well. These qualities ensure that entrepreneurs avoid common mistakes like securing the wrong type of financing, miscalculating the amount required, or underestimating the cost of borrowing money.” http://www.sba.gov/financing/basics/basics.html.

The Good News: Your Company has landed a new Government contract, one that will result in a significant increase in revenues.

The Challenge: In order to fulfill this contract, you must immediately commit to additional people (payroll), training, materials, and related costs. This commitment must be made in advance of receiving payments from your customer (the US Government). Unfortunately, the amount of capital needed to cover your commitments exceeds the balance available on your existing line of credit or your credit card. It also exceeds the amount of cash that could be made available by delaying payments to selected vendors. The nature of this contract might justify issuing new equity or debt, but raising capital generally is an expensive, complex task that ultimately may take too long to meet your short-term contract specific capital requirements.

Solution – Planning!:

In order to minimize the risk of your company having to scramble to raise enough capital to ramp up for future major contracts, your internal business development forecasting process should identify and signal situations early to senior management. This will allow for a pro-active review of any significant operational, personnel, and financial impacts. Specific terms may be negotiated into the customer’s agreement to dampen these impacts. Such terms may include extended delivery dates, partial payment upon order placement, or progress payments based upon specific performance criteria.

Existing Bank or Lender - If your company has an existing line of credit or borrowing arrangement with a bank or other lender, try to negotiate an increase with them. A responsive lender may provide all of the short-term capital needed until the Government agency begins payment. You should be aware that trade-offs of a significantly higher level of credit might involve committing to a new long term deal, additional loan covenants, greater reporting requirements, and/or higher interest rates. In addition, your credit agreement may constrain your ability to take on other types of debt or lease obligations. In any event, it is best to discuss the situation as far in advance as possible and have a full financing/business plan and presentation available. Remember, LENDERS HATE SURPRISES. If your company does not have an accommodating lender, the following alternatives should be considered:

Factoring – This is the sale of your invoices, accounts receivable, to a bank or finance company (the “Factor”), as opposed to using them as borrowing collateral. The Factor will advance a percentage, usually between 75% and 90%, of the invoice amount to the customer; the balance is refundable upon receipt of payment, less interest and transaction costs. Some Factors may also provide weekly or mid-month, funding of unbilled accounts receivable, mobilization financing for new contracts, and/or “term loans” for multi-year contracts. The Factor will, through the Federal Assignment of Claims provisions, notify the Federal Government agency customer that the invoice has been financed and is payable directly to them. There are several advantages to factoring; most of the A/R bookkeeping, customer credit worthiness, collections, and credit risk become a shared responsibility with the Factor, and the initial approval process can usually be a matter of days.

In addition, because the primary credit criteria is based on your government customer, the federal, state, or municipality, a Factor will generally provide financing for start-ups, 8a, minority, Native American, disabled veteran, woman owned contractors, or other companies that may have a questionable credit history. Although sometimes more costly, it is a viable alternative to traditional bank financing because of its increased flexibility. In addition, many Factors will provide a “financial support” letter, submitted with the proposal, to the Government agency insuring that their institution’s financial strength is behind the client.

Contract Financing/Purchase Order Financing - You may be able to negotiate financing based upon your Federal Government customer Purchase Order(s). Some lenders provide Purchase Order financing based upon the credit worthiness of your customer (in this case the US Federal Government). PO financing is easiest when your products or services are well established. If your products are new, services are non-standard and/or unproven, PO financing is more difficult to obtain. The effectiveness of contract/PO financing in a pre-revenue ramp up situation will be determined by how soon your company can invoice the customer.

Commercial Financing-Asset Based Lending - This is a common type of financing provided by most banks and commercial financial companies. The primary asset used in this type of lending is your company’s accounts receivable, although inventory, fixed assets, and in some instances, intellectual properties may be used to collateralize additional long term financing requirements. With asset based lending your, as well as your customers’ credit worthiness will determine the percentage of the receivables that will be advanced, usually between 75% and 90%. Inventory and fixed assets advance rates are most often significantly lower because these are less liquid assets. This financing is almost always provided on a revolving or an on-going basis, thus the term “revolving credit.”

Leasing and/or Sale and Leaseback - These financing alternatives can be used to generate capital from fixed assets that are to be obtained or currently owned by your company, such as computers, equipment, furniture and fixtures, vehicles, and real estate. Banks, financing companies, dealers, and manufacturers provide these more specialized services. Your company’s credit standing and the quality of the assets involved will determine the amount of cash that can be raised and the terms under which it is provided. The specifics of the agreement will determine if these leases have to be reported on your company’s balance sheet or if they can be treated as “off balance sheet” items.

SBA Loan – The SBA offers numerous loan programs to assist small businesses. It is important to note, however, that the SBA is primarily a guarantor of loans made by private and other institutions.

The Basic 7(a) Loan Guaranty serves as the SBA’s primary business loan program to help qualified small businesses obtain financing when they might not be eligible for business loans through normal lending channels. It is also the agency’s most flexible business loan program, since financing under this program can be guaranteed for a variety of general business purposes. Loan proceeds can be used for most sound business purposes including working capital, machinery and equipment, furniture and fixtures, land and building (including purchase, renovation and new construction), leasehold improvements, and debt refinancing (under special conditions). Loan maturity is up to 10 years for working capital and generally up to 25 years for fixed assets. http://www.sba.gov/financing/sbaloan/snapshot.html.

SBIR and Grants: SBIR (Small Business Innovation Research) is a federal government program administered by 10 federal agencies for the purpose of helping to provide early-stage Research and Development funding to small technology companies (or individual entrepreneurs who form a company). Solicitations are released periodically from each of the agencies and present technical topics of R&D, which the agency is interested in funding. Companies are invited to compete for funding by submitting proposals answering the technical topic needs of the agency's solicitation. Each agency has various needs and flavors of the SBIR program and you can learn more about them by visiting their sites. Here are the addresses for the SBA, DOD, and NIH: www.sba.gov/sbir/, www.acq.osd.mil/sadbu/sbir/, grants.nih.gov/grants/funding/sbir.htm, www.grants.gov.

None of the alternatives mentioned above are mutually exclusive. In many cases, combinations can be very effective. However, there are significant legal and operational differences in these financing arrangements. The terms of some borrowing agreements may limit your ability to take on additional debt and they should be entered into only as part of a coherent financing strategy. Do not be alarmed when the lender asks for your personal guaranty. Personal guarantees are virtually standard for all but the most credit worthy and/or public companies.

For questions or additional information, please do not hesitate to contact Richard Lewis at 703-462-2310 or email at richard.lewis@wellsfargo.com.

WIPP Action Alert: Contact the SBA now!

Our hard work is paying off! The momentum decrying the SBA’s proposed new rule for the Women’s Procurement Program has grown exponentially. In the past five weeks, WIPP members have written op-eds, been interviewed and quoted by local and national media, and participated in online podcasts. Senators and Representatives in Washington have heard our call and, as a result, held Congressional hearings and briefings, circulated ‘Dear Colleague’ letters, and sent SBA Administrator Steve Preston letters lambasting the SBA’s proposed new rule.

We have worked hard and seen results but there is still one more task. It is vital that we each, individually, demand that the SBA withdraw the rule. Submit your comments to the SBA directly; the official comment period ends February 25. Do not miss this chance to have your business' voice go on the record.

We have posted a sample letter to the SBA on our website. Please click here and follow the simple instructions; or if you prefer, go directly to the SBA comment section and write your own comments. Please forward Anna Lubiner at alubiner@wipp.org your comments to the SBA.

Do not miss this important opportunity to stand up and be heard. The deadline for comments is February 25th, so act now!

888.488.WIPP ~ www.WIPP.org