Coeur Alaska

Letter from John McGeshick to Rob Mellinger

Lac Vieux Desert Band of Lake Superior Chippewa Indians
P.O. Box 249 - Coate Road
Watersweet, Michigan 49969

August 11, 1995

Rob Mellinger
Project XL at ICF Inc.
9300 Lee Highway
Fairfax, Virginia 22031-1207

Dear Mr. Mellinger,

This letter is in response to your letter R-19J regarding EPA's Regulatory Reinvention XL Pilot Projects. Comments regarding the 8 proposals (Nebraska proposal received contained one page) as received are generally as follows:

a) Are any of the eight projects considered small business?
b) The Alaska project (Couer, etal.) is particularly disturbing as it appears a precedent may be set if the Company is allowed to divert waste into an Alaska designated drinking water quality stream. Not only does the project override a variety of environmental regulations, but it also undermines a public trust of sorts by condoning the companys' plan to prevent anyone from drinking from the stream (?).
c) The other proposal that is disturbing is the Myers plan to recycle PCB's. By permitting such an activity EPA may be encouraging the shipment of hazardous materials through Tribal Reservations.
d) The balance of the proposals are substantially
weak in their arguments for flexibility.

Furthermore, it appears the applicants interpret the project criteria "Cost savings and paperwork reduction" differently than others. The applicants tend to stress their economics/bottomline by not meeting current standards whereas it appears the criteria refers to economics of a simplified, efficient procedure in addressing environmental protection.

I believe these 8 responses to the XL program fall far short of the intent of the program as it is understood. I would suggest you delay selection of projects until there is a clear understanding between the interested parties on what the program is designed to accomplish. It is clear from reviewing the proposals that many view the program from a variety of perspectives none of which are appealing to any degree by the Lac Vieux Desert community.

If you have any questions, please call me or George Beck at (906) 358-4577. Address all correspondence to George at the address above.

Sincerely,

John C. McGeshick
LVD Tribal Chairman

c.c. Shirley Mitchell, Chief of the Planning and Assessment
Branch, EPA Region V

Coeur Alaska

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