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Minnesota Pollution Control Agency (MPCA)

Support Letter from Univ. of Minnesota to Carol Browner

University of Minnesota
Twin Cities Campus Strategic
Management Research Center
822 Management and Economics

271 - 19th Avenue South
Minneapolis, MN 55455

Fax: 612-625-2873

June 14, 1995

Ms. Carol Browner, Administrator
U.S. Environmental Protection Agency
401 M Street SW
Mail Code A-100
Washington, D.C. 20460

Dear Ms. Browner:

As members of the Pilot Project Committee (PPC) of the Pollution Prevention Dialogue we are writing to express our support for the MPCA's proposal to be delegated authority to undertake Project XL pilots in Minnesota.

The Pollution Prevention Dialogue, "Collaborating for a Better Environment and Economy in Minnesota," is a diverse group consisting of representatives from industry, government, environmental advocacy organizations, the legal profession, environmental engineering consultants, and academia. The Dialogue has been convened through the collaborative efforts of the Strategic Management Research Center (SMRC) of the Carlson School of Management, University of Minnesota, the Minnesota Environmental Initiative (MEI), and the Center for Global Change, University of Maryland. The Dialogue has the support of the Minnesota Sustainable Development Initiative and is funded by a grant from the Joyce Foundation.

When first convened, the Dialogue took on the task of finding innovative means to promote pollution prevention (P2) activities and has been seeking adidtional incentives for P2 or ways of removing existing barriers to it. One of the projects identified by the group was to create a pilot program to examine the advantages of increased regulatory flexibility in Minnesota. Representatives of the MPCA, as participants of the Dialogue, endorsed the idea and agreed to seek ways to implement such a pilot project. Our Pilot Project Committee (PPC) was formed to advise and oversee the pilot project on behalf of the Pollution Prevention Dialogue. Committee members represent a range of constituencies similar to that found in the larger Dialogue group and have an interest in environmental regulation.

Our discussion and endorsement of Minnesota's effort to create a regulatory flexibility pilot program occurred at about the same time and independently of the President's announcement of Project XL. That announcement confirmed to our group that Minnesota's project was consistent with federal policy and suggested that any efforts undertaken by the MPCA should be consistent with the goals of Project XL.

We support the delegation of Project XL authority to the MPCA for several reasons. First, we believe the MPCA has the appropriate experience and expertise to undertake flexible pilot projects. The agency's experience with 3M's St. Paul Tape Plant Permit confirms this point. Second, the MPCA has an excellent working relationship with the arious constituencies having an interest in this issue. As the agency's participation in the P2 Dialogue suggests, the MPCA appears keenly interested in finding innovative regulatory approaches that accommodate the goals of environmental protection, pollution prevention, and economic viability. Third, there is significant interest among all stakeholders in developing flexible approaches in Minnesota that, at the same time, will provide companies with increased incentives and opportunity to introduce significant pollution prevention measures. Fourth, we believe your agency's approval of the MPCA's application will introduce a valuable innovation into Project XL - namely to demonstrate that such programs can effectively be delegated to the state level.

Another important factor in support of the MPCA's proposal is the existence of our committee as a multi-stakeholder oversight group. As the MPCA proceeds with any pilot projects, the PPC is committed to hold regular meetings at which we review and monitor the projects' progress and to provide comment and advice. In addition, we will work to ensure that such pilot projects meet broader goals and to ensure that, to the extent possible, any approaches developed in the pilot phase are ultimately transferable to the broader regulated community. The MPCA's ability to rely on our oversight committee for such assistance, we believe, makes this proposal unique.

Once again, we strongly support the MPCA's efforts and urge the EPA to approve and endorse the MPCA's proposal.

Jon Bloomberg, Attorney
Oppenheimer Wolff & Donnelly
Lisa Thorvig, Division Manager,
Air Quality Division, MPCA
Ciaran Mannion, Minnesota
Environmental Initiative
Pam Graika, Director of Environmental Affairs Northern States Power Gary Weisbrod, Sr. Dir. Environment, Health & Safety, Deluxe Corp. Donald Geffen, Research Associate, SMRC, University of Minnesota
Brian Lim, Env. Services Manager, H.B. Fuller Company Carol Wiessner, Staff Attorney, MN Center for Environmental Advocacy Alfred Marcus, Professor, SMRC, University of Minnesota
Lee Paddock, Dir. Env. Policy, MN Att. General's Office Dennis Willis, VP Operations, Capsule Environmental Eng. Ken Sexton, Professor, School of Pub. Health, University of Minnesota
Brett Smith, Conservat. Chair, MN Chapter of the Sierra Club

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