Minnesota Pollution Control Agency (MPCA)
Support Letter from Univ. of Minnesota to Carol Browner
University of Minnesota
Twin Cities Campus Strategic
Management Research Center
822 Management and Economics
271 - 19th Avenue South
Minneapolis, MN 55455
612-624-0226
Fax: 612-625-2873
June 14, 1995
Ms. Carol Browner, Administrator
U.S. Environmental Protection Agency
401 M Street SW
Mail Code A-100
Washington, D.C. 20460
Dear Ms. Browner:
As members of the Pilot Project Committee
(PPC) of the Pollution Prevention Dialogue we are writing to express our
support for the MPCA's proposal to be delegated authority to undertake
Project XL pilots in Minnesota.
The Pollution Prevention Dialogue, "Collaborating
for a Better Environment and Economy in Minnesota," is a diverse
group consisting of representatives from industry, government, environmental
advocacy organizations, the legal profession, environmental engineering
consultants, and academia. The Dialogue has been convened through the
collaborative efforts of the Strategic Management Research Center (SMRC)
of the Carlson School of Management, University of Minnesota, the Minnesota
Environmental Initiative (MEI), and the Center for Global Change, University
of Maryland. The Dialogue has the support of the Minnesota Sustainable
Development Initiative and is funded by a grant from the Joyce Foundation.
When first convened, the Dialogue took on
the task of finding innovative means to promote pollution prevention (P2)
activities and has been seeking adidtional incentives for P2 or ways of
removing existing barriers to it. One of the projects identified by the
group was to create a pilot program to examine the advantages of increased
regulatory flexibility in Minnesota. Representatives of the MPCA, as participants
of the Dialogue, endorsed the idea and agreed to seek ways to implement
such a pilot project. Our Pilot Project Committee (PPC) was formed to
advise and oversee the pilot project on behalf of the Pollution Prevention
Dialogue. Committee members represent a range of constituencies similar
to that found in the larger Dialogue group and have an interest in environmental
regulation.
Our discussion and endorsement of Minnesota's
effort to create a regulatory flexibility pilot program occurred at about
the same time and independently of the President's announcement of Project
XL. That announcement confirmed to our group that Minnesota's project
was consistent with federal policy and suggested that any efforts undertaken
by the MPCA should be consistent with the goals of Project XL.
We support the delegation of Project XL authority
to the MPCA for several reasons. First, we believe the MPCA has the appropriate
experience and expertise to undertake flexible pilot projects. The agency's
experience with 3M's St. Paul Tape Plant Permit confirms this point. Second,
the MPCA has an excellent working relationship with the arious constituencies
having an interest in this issue. As the agency's participation in the
P2 Dialogue suggests, the MPCA appears keenly interested in finding innovative
regulatory approaches that accommodate the goals of environmental protection,
pollution prevention, and economic viability. Third, there is significant
interest among all stakeholders in developing flexible approaches in Minnesota
that, at the same time, will provide companies with increased incentives
and opportunity to introduce significant pollution prevention measures.
Fourth, we believe your agency's approval of the MPCA's application will
introduce a valuable innovation into Project XL - namely to demonstrate
that such programs can effectively be delegated to the state level.
Another important factor in support of the
MPCA's proposal is the existence of our committee as a multi-stakeholder
oversight group. As the MPCA proceeds with any pilot projects, the PPC
is committed to hold regular meetings at which we review and monitor the
projects' progress and to provide comment and advice. In addition, we
will work to ensure that such pilot projects meet broader goals and to
ensure that, to the extent possible, any approaches developed in the pilot
phase are ultimately transferable to the broader regulated community.
The MPCA's ability to rely on our oversight committee for such assistance,
we believe, makes this proposal unique.
Once again, we strongly support the MPCA's
efforts and urge the EPA to approve and endorse the MPCA's proposal.
Jon Bloomberg, Attorney Oppenheimer Wolff & Donnelly |
Lisa Thorvig, Division Manager, Air Quality Division, MPCA |
Ciaran Mannion, Minnesota Environmental Initiative |
||
Pam Graika, Director of Environmental Affairs Northern States Power | Gary Weisbrod, Sr. Dir. Environment, Health & Safety, Deluxe Corp. | Donald Geffen, Research Associate, SMRC, University of Minnesota | ||
Brian Lim, Env. Services Manager, H.B. Fuller Company | Carol Wiessner, Staff Attorney, MN Center for Environmental Advocacy | Alfred Marcus, Professor, SMRC, University of Minnesota | ||
Lee Paddock, Dir. Env. Policy, MN Att. General's Office | Dennis Willis, VP Operations, Capsule Environmental Eng. | Ken Sexton, Professor, School of Pub. Health, University of Minnesota | ||
Brett Smith, Conservat. Chair, MN Chapter of the Sierra Club |