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Merck & Co., Inc.

Letter from George Frampton to Richard Wilson

October 17, 1996

Mr. Richard D. Wilson
Deputy Assistant Administrator
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460

Dear Mr. Wilson:

Thank you for your letter dated October 16, 1996, confirming our recent discussions regarding the Merck XL project. As your letter substantiates, our discussions were very helpful in producing the clarifications and understandings necessary for the Department of the Interior to determine its support for this project. We can now declare our support for the Merck XL project, and we stand ready to help in expediting the final documents. We commend all the parties for their hard work on this innovative and promising experiment in promoting excellence and leadership in environmental protection.

We are eager to begin work with you as soon as possible concerning the rulemaking to require State Implementation Plans to prevent significant deterioration of air quality by adopting mitigation measures to address adverse impacts on air quality related values in Class I areas. We appreciate Merck's support of this rulemaking approach. Representatives from diverse interests -- the private sector, government, public interest groups -- have touted the substantial advantages inherent in such an expanded approach to remedying documented harm to national park and wilderness area resources. Particularly with respect to multiple-source or regional pollution, this rulemaking should enhance the fairness, cost-effectiveness, and efficiency of solutions to problems that today jeopardize our stewardship of the national resources designed for the highest level of environmental protection and for the enjoyment of present and future generations.

Our recent discussions about the XL and PSD air quality programs have suggested the basis for further sharing of ideas concerning the innovations each of our agencies is pursuing under our respective regulatory authorities. As you know, the Department of the Interior is working with many different kinds of partners and stakeholder groups to fashion experiments under the Endangered Species Act and other statutory authorities for achieving superior resource management and habitat protection throughout the country. These programs of EPA and the Department of the Interior exemplify the Clinton Administration's efforts to maximize long-term environmental protection while also maximizing sustainable economic productivity.

Based on the principles we have developed in Departmental programs, we urge that EPA provide guidance to the regions concerning the case-by-case determination of superior environmental benefits in XL projects. We suggest that you include the following measures to assure that future XL projects provide for the protection of the air quality related values of national park and wilderness areas. (1) Projects should be based on the best available science. (2) Since the lifetime of XL projects might routinely extend beyond the typical regulatory term, it becomes very important to provide for adequate monitoring of results and to allow for the improvement of scientific understanding and the development of technical capabilities over the lifetime of the project. (3) It becomes equally important to provide the flexibility to adapt the project to new information and better science and to correct unanticipated problems. (4) As a backstop, project termination provisions should allow the permit to be terminated based on significant problems (such as adverse impacts on Class I resources) that are not corrected.

Thank you for all your efforts in addressing our concerns. Our work together on the Merck XL project has laid the basis for exciting new approaches to carrying out our shared responsibilities. We are anxious to get started.


George T. Frampton, Jr.
Assistant Secretary for Fish
and Wildlife and Parks

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