EXHIBIT 63

NPA PRESS RELEASE AND COLLATED LIST OF 71 INTERPRETATIONS OF CONSTRUCTION ORDER M-4A

The National Production Authority, United States Department of Commerce, today issued a collation of 71 interpretations of its construction regulations which includes 60 interpretations not previously announced.

NPA announced 11 of these interpretations previously in releases NPA-1102 and NPA-1180. The rest were issued to regional attorneys between August 3, when the new regulations were promulgated, and September 7.

NPA explained that in some instances these interpretations have been revised or modified and, that the present list supersedes all previous interpretations issued between the foregoing dates.

Many of the interpretations were provided in answer to specific inquiries; others were in response to general questions on certain aspects of the new regu lations.

The interpretations are broken down into eight categories: controlled materials, self-authorization, section 7 of Order M4A (copper and aluminum restrictions), individual projects, commencement or continuance of construction, multiuse projects, categories of construction and delivery.

The interpretations marked with an asterisk in the attached text are those included in releases previously issued.

The collated list of interpretations is attached.

CONTROLLED MATERIALS

1. The steel content of a prefabricated building or other Class B product is not to be considered in computing controlled materials requirements under Schedule 1 of Direction 1 of CMP Regulation 6.

2. Since rigid steel electrical conduit is a Class B product, metal tubing for electrical conduit is also a Class B product.

3. Wire nails are controlled materials.

4. A steel distributor is required under the CMP Regulations to honor controlled materials orders bearing the CMP serial even when less than minimum mill quantities, or if they do not exceed 8,000 pounds of carbon steel, or other quantities of other steel products, as specified in Section 7 of NPA Order M-6.

5. Structural shapes are by NPA definition, "those rolled flanged sections having at least one dimension of their cross-section three inches or greater, commonly referred to as angles, channels, beams and wide flanged sections." This means that any standard rolled section from a 3×2%1⁄2 inch angle, 3 inch I beam, or 3 inch channel up, are structural shapes.

6. Steel bar joists are Class B products.

7. A lally column is a Class B product.

8. Used and new domestic and imported controlled materials are in the same class, and all should be included in determining the quantities involved in construction.

9. In computing quantities of controlled materials, the prime contractor must include the quantities of controlled materials necessary for the fabrication of Class A products which will be used by him in the construction.

10. A controlled material which has been fabricated for a project to such an extent that it has lost its identity as a controlled material, and is not a Class B product, is automatically, therefore, a Class A product. The prohibition and control on the use of controlled materials under Order M-4A and Direction 1 to CMP Regulation 6 is on controlled materials as such and is not on Class A or Class B products. However, the authorized quantities of controlled materials for

contruction include the quantities necessary for the fabrication of Class A products needed by the prime contractor in his construction job.

11. With regard to construction other than multi-unit residential and recreational construction, a prime contractor may exceed the quantities specified in Order M-4A and Direction 1 to CMP Regulation 6, so long as he does not receive delivery of controlled materials in excess of those limits after September 30, 1951. For example, a prime contractor may use in the construction of a one family residence more than 1,850 pounds of steel or 35 pounds of copper if the excess quantities come from his own pre-October inventory. The construction orders limit the amount which may be delivered to the prime contractor after September 30, 1951, but they will not prevent his using up his own previously acquired inventory.

12. Where a prime contractor has self authorized his order for delivery of controlled materials in the Fourth Quarter and does not receive delivery during that quarter, he may not receive delivery in the First Quarter, or any subsequent quarter, in addition to the quantities of materials for delivery in such subsequent quarter which he self authorizes. The right to readjust delivery schedules applies only to allotments received on Form 13 and not to self-authorized orders. 13. If a prime contractor requests an allotment of specific quantities of structural steel and other types of carbon steel, and if he receives an allotment of carbon steel, he may not order quantities of each kind of carbon steel in amounts greater than he indicated in his 4C application. For example, if the 4C application requests an allotment of 10 tons of structural shapes and 10 tons of sheets, and if the allotment granted is for 20 tons of carbon steel, the prime contractor may not order or receive delivery of more than 10 tons of structural shapes and 10 tons of sheets. He may not receive delivery of 15 tons of structural shapes and 5 tons of sheets.

14. Standard concrete reinforcing bars made of steel are controlled material and not Class B products. A standard bar is either straight, or bent to required shape. It can be smooth or deformed. A fabricated bar is a bar which has been bent and welded.

15. The inquiry is whether steel sheets cut to size and drilled before delivery, and used for exterior walls and partitions in conjunction with a prefabricated steel frame, are controlled materials. The answer is no. They are Class B products. However, if such sheets are delivered uncut or undrilled, they are Class A products even if applied by the manufacturer or distributor of prefabricated steel structures.

16. The inquiry concerns the distinction between carbon steel and structural steel. Carbon steel includes structural steel. Lintels are structural steel; if the dimension is three inches or over, it is structural steel (heavy). Sheet metal duct work and steel pipe are carbon steel.

17. Lintels and small angles with dimensions less than three inches wide are not structural steel but are bar shapes.

18. The inquiry is whether the steel and steel window sash, also reinforced concrete B products such as blocks, beams, roofing, floor tile, are charged against amount of steel allowed in construction of residential and other buildings, pursuant to Schedule I Direction 1 to CMP Regulation 6. The answer is that if pre-cast by a manufacturer they are Class B products; if pre-cast on the job they are Class A. (See Press Release NPA-1151.)

19. The inquiry is whether fabricated steel bar joist and steel roof decking are controlled materials. The answer is no. They are Class B products.

20. The inquiry is whether stran steel is a Class B product. The answer is yes. 21. The inquiry is whether web steel joists are Class B products. The answer is yes.

22. The inquiry is whether a home builder who procures carbon steel which is not structural steel and welds the same into a piece of angle iron, and uses the welded piece as a lintel, may self authorize orders for the purchase of such carbon steel within the tonnage limitation of Schedule 1 to Direction 1 to CMP 6. The answer is yes, despite the fact that the welded article which will be manufactured from the carbon steel will be the equivalent of a structural shape, since the builder is not acquiring a structural shape.

SELF AUTHORIZATION

1. The inquiry is whether a prime contractor may self authorize 2 tons of steel and 200 pounds of copper per project per quarter, or whether the self authorization is only permitted per project. In the case of commercial, public

and religious (but not recreational) the prime contractor is permitted to self authorize 2 tons of steel and 200 pounds of copper per projects per quarter.

2. The inquiry is whether a prime contractor building an industrial plant may self authorize delivery orders in consecutive quarters until the building is completed. The answer is yes. This interpretation does not conflict with the provisions of Section 5 of Order M-4A

SECTION 7 OF ORDER M-4A

1. Type K tubing for underground water service, connecting from the street to a house or building, may be used under Section 7 of Order M-4A. However, the weight of this copper tubing must be figured in computing the specified quantities of coper under Direction 1 of CMP Regulation 6.

2. When a prime contractor has copper in his inventory, or held for his account by another, and will require no copper or other controlled materials for delivery after September 30, 1951, and wishes to use such copper for a purpose prohibited by Section 7 of Order M-4A, he must file and application on Form 24-A and ask for an exception and the right to use it prior to his making use of the copper for the prohibited purpose.

3. The inquiry is whether Section 7 of M-4A prevents a sheet metal contractor from fabricating on the job sheet aluminum in connection with an apartment house now under construction. The answer is yes. Aluminum cannot be used in construction other than industrial construction without specific authorization from the National Production Authority. Section 7 of Order M-4A does not prohibit the use of galvanized steel sheet in construction.

INDIVIDUAL PROJECTS

1. In an office building where alterations are necessary for the occupancy of tenants, the whole building is considered one project, and the work done for or by each tenant cannot be considered a separate project. Therefore, the limitation of 2 tons of steel and 200 pounds of copper per project per quarter refers to the requirements of an entire office building for that quarter.

2. Where construction is necessary to sink a well for water supply to serv ice a building, each such well or series of wells is a construction project separate from the construction of the building, and the prime contractor building the well may self authorize the procurement of controlled materials for such well and its casing on the basis of 2 tons of steel and 200 pounds of copper per quarter per project. The quota of controlled materials for such well is not charged against the quota of steel to be used in the construction of the building.

3. Where an oil supply tank is connected to an oil burner by copper tubing and such tubing is installed by and is to be used by the owner of a building, the weight of such copper tubing is included within the quota which may be self authorized under Direction 1 to CMP Regulation 6 for the building. However, if the tubing is installed by a utility and title to it remains in the utility, then such quota should not be charged against the owner of the building. This interpretation applies to all types of construction including residential.

4. Each gasoline station at a different location, although built by or for one company, is a separate project and self authorization may be used for each such gasoline station.

5. Each separate house in a building development is a separate project within the meaning of Schedule 1 of Direction 1 to CMP Regulation 6. Therefore, the prime contractor may self authorize orders for delivery of controlled materials for each unit without regard to the total number of units in the development. This rule applies without regard to whether the prime contractor is building the units for sale or intends to retain title to all the units and rent them.

COMMENCEMENT ON CONTINUANCE OF CONSTRUCTION

*1. With respect to construction other than Table I construction or multiunit residential construction, if, prior to October 1, 1951, a prime contractor has in his possession or has held for his account by another his requirements of controlled materials for completion of the building, and does not require delivery after September 30, 1951, of controlled materials in quantities in excess of the appropriate amount specified in Schedule 1 to Direction 1 to CMP Regulation 6, he may commence construction at any time and he may use such materials in his construction job, provided he conforms to Section 7 of Order

M-4A and to any other restrictions on use of materials contained in other NPA orders.

*2. A prime contractor who has been issued a Certificate of Necessity for plant expansion and a DO-46 is nevertheless subject to Order M-4A and CMP Regulation 6. If he has not yet commenced construction, and if he will require delivery of more controlled materials than he can self authorize orders for, he may not commence construction unless he receives an authorized construction schedule and related allotment. If construction is now under way, he may not continue after September 30, 1951, without filing an application for an authorized construction schedule and related allotment unless his total requirements for delivery after September 30, 1951, do not exceed the amounts for which he may self authorize orders. For example, if construction of an industrial plant is now under way after the issuance of the Certificate of Necessity, and the construction job will require delivery of more than 25 tons of steel per quarter in order to complete the job, if the prime contractor files a 4C application with the request for an allotment, he may continue with his construction after September 30, 1951.

*3. A prime contractor has in inventory 50 tons of steel plus all the copper which he requires for the completion of his proposed building. He desires to build a commercial building which will require 100 tons of steel for completion. He may not commence construction unless he receives an authorized construction schedule since, after September 30, 1951, he will require delivery of more than 2 tons of steel per quarter.

*4. A prime contractor has in inventory 50 tons of steel. He desires to build a commercial building which requires 52 tons of steel plus 200 pounds of copper for completion. He may commence construction at the present time since, after September 30, 1951, he will not require delivery of more controlled materials than the amount for which he may self authorize his orders for delivery.

*5. A prime contractor has in inventory 50 tons of steel and 1,000 pounds of copper. He desires to build a commercial building which will require 50 tons of steel and 500 pounds of copper for completion. He may commence construction now since he will not require delivery of any controlled materials after September 30, 1951.

*6. The rules stated under Items 3, 4 and 5 above apply equally if the building is already under construction. Therefore, if the building referred to in Item 3 is under construction, the prime contractor will be permitted to continue construction during the Third Quarter. He may not continue after September 30, 1951, unless he has filed an application on Form CMP-4C for authorization to continue after September 30, 1951, and has received an allotment. There is no guarantee that such application will be granted. In the instances cited in Items 4 and 5, the prime contractor will be able to continue construction without stopping, and without filing any application on Form CMP-4C.

*7. (a) A prime contractor has 50 tons of steel and 1,000 pounds of copper in his inventory. He desires to build a motion picture theater or other Table I category which will not require more than that amount of controlled materials. Under Section 4 of Order M-4A, he may not commence construction unless he is granted an exception under Section 8 of that order. Since the proposed construction would not result in a diminution of the controlled materials allocation available for distribution, this fact will be considered in processing the application for exception.

(b) If a motion picture theater or other Table I category is now under construction pursuant to an exception granted under NPA Order M-4, and if it will require more than 2 tons of carbon steel or 200 pounds of copper for completion, the prime contractor may not continue with the construction after September 30, 1951, unless he receives an authorized construction schedule and related allotment under CMP 6. However, if the prime contractor needs not more than 2 tons of carbon steel or 200 pounds of copper to complete the theater, he may continue with the construction, but he may not self authorize his orders for delivery.

*S. If a prime contractor has received permission to construct under NPA Order M-4 (by authorization or exception) but had not commenced construction, he may not now commence construction unless he receives an authorized construction schedule and related allotment, if the building, structure or project will require delivery after September 30, 1951, of more controlled materials than the quantities for which he may self authorize orders for delivery. *9. In instances where an authorized construction schedule and related allot

ment of controlled materials has been granted in the Third Quarter by the Federal Security Agency for the construction of a school or hospital, the prime contractor may continue with the construction underway or may commence construction at this time if he has not already done so.

10. Where substantial site clearance was undertaken prior to August 3, 1951, but no foundations were poured, construction has not been commenced prior to the effective date of Order M-4A. This rule applies without regard to the fact that such substantial site clearance may have been done as the result of an authorization granted under Order M-4.

11. The effect of Order M-4A is to supersede all authorizations and denials previously granted under Order M-4. The right to commence or continue construction must be determined under Order M-4A without regard to any authorization or denial previously issued.

12. Projects on which authorization has been denied under Order M-4 can now proceed if they are not prohibited by Section 4 or 5 of Order M-4A.

13. The inquiry is whether a prime contractor denied permission to commence construction under Order M-4 may now commence construction without authorization if commencement of such construction would be permitted under provisions of M-4A. The answer is yes. Order M-4A supersedes all authorizations or denials previously granted under Order M-4.

MULTI-USE PROJECTS

1. If a proposed building is to be part residential and part commercial, to determine whether the limitations on residential or commercial construction apply, the prime contractor must use the test specified in Section 2 (b) of Direction 1 to CMP Regulation 6.

2. If a proposed building will contain a Table I use as well as other features (e. g., a multi-purpose building containing general commercial use and also a bar and grill or an auditorium), construction cannot be commenced or continued unless the provisions of Section 4 of Order M-4A are complied with.

3. A swimming pool which is to be an adjunct to a private residence is to be considered as one project with the residence in applying the provisions of Order M-4A and Direction 1 of CPM Regulation 6. Since a portion of the project is a Table I use, the prime contractor must comply with Section 4 of M-4A for the entire project.

CATEGORIES OF CONSTRUCTION

1. The following types of construction come within the categories “general or commercial", and therefore, a prime contractor desiring to build any one of these categories may self authorize orders for delivery of controlled materials in quantities not to exceed 2 tons of carbon steel and 200 pounds of copper per quarter: amateur radio station, administration building for an industrial or other type of enterprise, garage, filling station.

2. Construction of highways and bridges is not industrial construction. The maximum quota of controlled materials for which self authorized orders may be issued with respect to such construction is 2 tons of carbon steel and 200 pounds of copper per project per quarter.

3. A municipal water system is public construction and not industrial construction.

4. A plant for the manufacture of ice is an industrial building.

5. A plant for the publication of a newspaper is a commercial building and not an industrial building.

6. Cabins to be rented by resort owners are in the same category as hotels or motels. They are commercial construction and not recreational construction.

7. Erection of a billboard or outdoor advertising sign comes within Order M-4A. If a group of billboards or signs are being constructed together they should be classified as one project. Generally speaking, the erection of a billboard or outdoor advertising sign is commercial construction. However, if the billboard or sign is an adjunct of a recreational building, structure or project, then the erection of the billboard or sign is a part of that recreational project. In such instance, the prime contractor must comply with Section 4 of Order M-4A.

8. A grain elevator or feed mill is a commercial building and not an industrial building.