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CONSAD Research Group

Letter from David Gardiner to Wilbur Steger

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASINGTON, D.C. 20460

NOV 13 1995

Wilbur A. Steger
CONSAD Research Corporation

121 North Highland Avenue
Pittsburgh, Pennsylvania 15206

Dear Mr. Steger:

Thank you for CONSAD's proposal to EPA's Project XL. Although your proposal raised some interesting policy questions and trade-offs, I am sorry to inform you of my decision not to pursue it as an XL project.

XL proposals are reviewed carefully by a team from across all EPA regions and headquarters offices, and by representatives of state and tribal environmental agencies. In this and other cases, proposals are reviewed based on a set of eight criteria outlined in the May 23, 1995, Federal Register notice launching Project XL.

The first of these criteria is environmental results. This is the "eXcellence" part of XL. Your proposal was very interesting and creative. However, based upon our review of the information you submitted, your proposal would not deliver the superior environmental results which the XL program was designed to foster. Overall, your proposal presents both environmental positives and negatives, but in my judgment, not the sort of superior environmental performance envisioned in the XL criteria.

Another of these criteria is transferability. XL projects are intended to test new principles that could be incorporated more broadly. XL projects are meant to be the building blocks of a new performance-based system of environmental protection. This is the "Leadership" part of XL. I do not believe that implementation of your proposal would have broad implications for how we do business at EPA.

I want to stress that EPA's decisions on whether to accept or decline XL proposals are, by definition, judgment calls. Project XL has produced tremendous interest, and so competition for participation in the program is significant. Good arguments were made on both sides of the issues raised in your proposal.

Once again, thank you for your interest in Project XL and your continued support of environmental protection.

Once again, thank you for your interest in Project XL and your continued support of environmental protection.


Sincerely,



David Gardiner
Assistant Administrator

cc: Shirley Mitchell, EPA Region 5


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