Weyerhaeuser Company

Letter from William Tietjen to Lisa Lund

16 December, 1996

Ms. Lisa Lund
Deputy Assistant Administrator
Office of Policy, Planning and Evaluation
United States Environmental Protection Agency
Washington, DC 20460

Dear Ms. Lund:

The conference call/meeting on Project XL that took place on the afternoon of 12 December was interesting. This was the first opportunity I have had to participate in the general discussion. All of my interaction in the past has been more on the one to one level or in the local discussions specific to the Weyerhaeuser Flint River Operations in Oglethorpe, Georgia.

Obviously, several persons had some points they felt called upon to emphasize, making it was somewhat difficult for a south Georgia boy to ease in a comment, thus this letter.

Dave ? in his discussion of Intel made a point that struck home sufficiently to raise concern about one part of the XL process: namely the advocate role of EPA.

I have basic comfort with the environmental attitude of the people I know at the Weyerhaeuser Flint River Operations, having been involved with several of them for some years. The plant has been supportive of water quality studies on the Flint and Lake Blackshear. I have written, as a stakeholder, in support of the Flint River XL Project. As I have done so, I assumed that EPA would be standing by as an advocate for environmental quality, and that nothing would be allowed that was of questionable action. Thursday's conference causes me to question this assumption. I feel that I have some limited expertise in water quality. I am one of two PIs for the Blackshear Clean Lakes Study. I have been teaching aquatic biology for thirty years. At the same time, my approach is academic. I have no claim to expert knowledge in air quality (a part of the Flint River Operations XL). In addition, the amount of local "Stakeholder" participation has been quite small, in spite of extensive publicity on the part of Weyerhaeuser. It is my suspicion that our Georgia Environmental Protection Division does not have sufficient personnel to do the advocacy role that is required to assure full environmental protection. I know that the USEPA also has budget constraints, but I still have been counting on you all to be the final guide to what is needed to assure proper environmental quality, based on current knowledge. I certainly have not felt that this final level of acceptance was the role of the stakeholder public. Our resources of time, knowledge, and funds are quite insufficient for such a function. The research, quality assurance, and basic monitoring required for proper standards approval and for compliance assurance are certainly not within the means of the stakeholder public found in south Georgia.

The stakeholder public needs to understand the reasons why certain exceptions to standard regulations are being granted and should educate themselves to the point that they support reasonable exceptions. I believe that the public does play a role in helping to watch that environmental changes do not adversely occur as a result of these exceptions.

While I think the basic premise of XL with the easing of certain bureaucratic regulations in response to quality environmental plant operation is most reasonable, I strongly believe that the final decisions of level of variance must be at least with the advocate guidance provided by EPA. If I find that such overall supervision is not provided by EPA, then I will be forced to withdraw my support.

Sincerely,

William L. Tietjen, Ph.D.
Chair, Department of Biology and
Acting Dean, School of Arts and Sciences

Weyerhaeuser Company

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