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3M: Hutchinson, Minnesota

3M: Letter from Charles Williams to President Bill Clinton

Minnesota Pollution Control Agency

July 5, 1996

The Honorable William J. Clinton, President
The White House
1600 Pennsylvania Avenue
Washington, DC 20001

RE: Minnesota Project XL-Pilot Program

Dear President Clinton:

I ant writing you today to express my disappointment with the U.S. Environmental Protection Agency's (EPA) response to the Minnesota XL Permit and Final Project Agreement for the 3M Hutchinson facility.

My staff at the Minnesota Pollution Control Agency (MPCA) worked very hard in developing the 3M Hutchinson Project XL pilot. The MPCA staff have met with and interacted with EPA Headquarters and Region V staff on a frequent basis. The last face-to-face meeting between MPCA and EPA was held in Chicago on June 10, 1996. At that meeting, my staff were given a clear indication by EPA that major issues were addressed and that EPA was comfortable with the project. In addition, the MPCA worked hard to get a broad-based consensus with two local stakeholder groups involved with the 3M pilot. The MPCA believes it has proven beyond a doubt the 3M Hutchinson pilot fits Project XL pilot criteria, is protective of human, and the environment, and will greatly reduce the administrative burden due to environmental regulations.

My disappointment in EPA is due to the written comments submitted to the MPCA on July 2, 1996. The comments bring up major issues and the suggested changes are prescriptive. The EPA comments are attempting to force this project back into a "command and control" box. As you know, Project XL is intended to be an experiment that moves environment regulation outside this box.

Most disappointing, is that the EPA comments we have received do not live up to the remarks you made during the November 3, 1995, Project XL pilot announcements. You gave the analogy of a high jump competition where government would "set the bar and set it high," but not tell the company how to jump over it. The MPCA has designed a performance-based permit for 3M Hutchinson that accomplishes your vision. Unfortunately, it appears that EPA continues to want to tell companies how to jump over the high bar.

I would appreciate your assistance in facilitating the resolution of the prescriptive FPA comments so that this first Project XL permit can be issued.



Charles W. Williams


cc: The Honorable Albert Gore, Jr., Vice President
The Honorable Rod Grams, U.S. Senator
The Honorable Paul Wellstone, U.S. Senator
The Honorable Gill Gutknecht, U.S. Representative
The Honorable William P. Luther, U.S. Representative
The Honorable David Minge, U.S. Representative
The Honorable Collin Peterson, U.S. Representative
The Honorable Jim Ramstad, U.S. Representative
The Honorable James L. Oberstar, U.S. Representative
The Honorable Martin Olav Sabo, U.S. Representative
The Honorable Bruce Vento, U.S. Representative
The Honorable Arne H. Carlson, Governor, State of Minnesota
Ms. Kathleen McGinty, Deputy Assistant to the President and Director for Environmental Policy
Ms. Carol Browner, Administrator, U.S. Environmental Protection Agency
Mr. Valdas Adamkus, Regional Administrator, U.S. Environmental Protection Agency, Reg. 5
Ms. Mary Gade, Director, Illinois Environmental Protection Agency
Mr. Robbie Roberts, Executive Director, Environmental Council of the States

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