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75 Hawthorne Street
San Francisco, Ca. 94105-3901

June 4, 1997

Richard Baldwin
Air Pollution Control Officer
Ventura County Air Pollution Control District
669 County Square Drive 2nd Floor
Ventura, CA 93003

    Re: Distribution of Imation's Emission Reduction Credits

Dear Mr. Baldwin:

    I understand that there has been some confusion regarding EPA's original intent for distribution of Imation's Emission Reduction Credits (ERCs) pursuant to the Imation XL project.  I would like to restate and clarify EPA's position so that the Ventura County Air Pollution Control Board (APCD) is well informed as it deliberates the best method for distribution of the ERCS.

    Imation was selected as an XL Project because they had proposed a project that could deliver superior environmental performance along with enhanced community participation if they were granted regulatory flexibility.  A major component of the superior environmental performance concerns the ERCS.

    What sets Imation's donation of ERCS apart from other facilities is that the distribution of ERCs was to be conducted by a broad-based community stakeholder process.  This process included such criteria as participating companies that receive ERCs must be "green" and proceeds of the sale were to directly benefit local air pollution control projects.  In addition, this group would have the discretion to retire some of these credits to provide another mechanism to enhance air quality in the area.

    The Covenant entered into by Imation and Ventura County clearly stated that Imation will donate 55 tons per year to the Ventura County Community Foundation, which will distribute the ERCs to a community organization selected by the Project XL stakeholders group.  This Project XL stakeholder group will be formed at the direction of the APCD.

    In addition, the Air Pollution Advisory Committee recommended to the APCD Board on November 12, 1996 that the "group chosen or created to distribute ERCs donated by Imation to include wider public participation and to look closely at any decision made to allocate the ERCS".

    As guarantors of the XL process, EPA's position on stakeholder participation is that this group should include representation from the following entities so as to allow for a balanced perspective that is accordance with EPA Project XL guidance:

    A group that draws from these entities in a balanced manner will provide a diverse perspective and a depth of  knowledge that will enhance the decisions made on distribution of the ERCS.

    I am looking forward to attending the APCD Board meeting on July 15.  If you have any questions, please call me at (415) 744-1962.

Jeff Rosenbloom
Project XL/ELP Coordinator

cc:  Air Pollution Control Board

    Pat Baggerly, Environmental Coalition
    Sara Eithier, Imation
    Lisa Lund, EPA HQ
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