Jump to main content.

Project XL Logo


Letter from Tom Zosel to Steven Herman

October 16, 1995

Mr. Steven A. Herman
Assistant Administrator, OECA
U.S. Environmental Protection Agency
401 M Street Southwest
Washington, DC 20460

Dear Steve:

I recently received a copy of your October 2 memo on OECA's Operating Principles for Project XL participants. We are very concerned about the impression which this memo creates about initiatives which will be implemented under Project XL and with what appears to be reliance on "standard operating procedures" rather than the development of innovative thinking. The objective of Project XL is to develop new and innovative methods of achieving superior environmental performance. We would hope that his enthusiasm for innovation would extend into the legal as well as the technical areas.

The 3M facilities which (if we are selected) will be participating in Project XL will not be "violating" existing regulations and statutes. They will be implementing alternatives to these regulations and statutes which will produce superior environmental performance, reduce transactional costs for U.S. EPA, the local agencies and 3M, will allow the use of Emission Reduction Credits for community benefit, and will allow greater public accessibility to release and emission information. To view, in legal or any terms, that these facilities will be "violating" because of Project XL is not only objectionable, but will also leave us vulnerable to citizen suit enforcement.

We believe that U.S. EPA has innovative legal options at its disposal which would allow full approval of XL Projects. In the May 23 Federal Register, U.S. EPA requested suggestions on Project XL approval methods. In response to that request, 3M prepared the attached suggestion which was forwarded to Ms. Lisa Friedman. This is only one innovative option which U.S. EPA has at its disposal.

The Office of Enforcement and Compliance Assurance has many highly creative individuals. If their innovative talents could be brought to bear on this issue, there is no question in our minds that a method of accomplishing full approval of XL Projects is attainable. If you or your staff have any questions on the suggestion which 3M has put forth or if we at 3M can be of assistance to you in any other way, please call me at your convenience.

Thomas W. Zosel
Manager, Environmental Initiatives



c: A.J. Donelson, 3M Washington Lisa Friedman, U.S. EPA
D.A. Sonstegard, 3M St. Paul David Gardiner, U.S. EPA
Fred Hansen, U.S. EPA

Local Navigation

Jump to main content.