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Lucent Technologies

Series of Letters of Support from XL Partners

Nancy Birnbaum
401 M Street, SW Room 1025WT (1802)
Washington, DC 20460

July 14,1998

Dear Ms. Birnbaum,

We, the members of the Lucent Allentown Local Environmental Advisory Group (LEAG) unanimously approve the Final Project Agreement (FPA) submitted to the U.S, EPA. As members of a group of citizens whom Lucent has invited for regular discussion, we have had the privilege of providing Input to Lucent to help it develop a dialogue with the community. We represent a variety of organizations and have expertise in environmental, community, industry, local government, and business issues. We are proud to have been a part of the Allentown Lucent Facilities effort to be a forerunner In the development and implementation of the Project Final Project Agreement.

For two years the LEAG has worked closely with the Allentown Lucent Facility. Its members have become familiar
with Lucent's goals and objectives. The Environmental Management System at Lucent developed was wail one and comprehensible to a lay person.

During Me development of the proposed FPA the LEAG reviewed and recommended changes to the document. As participants in this process are pleased to see our input reflected in the final document. This is the approach that government, industry and the community must use in order to protect and enhance the quality of our environment.

This Agreement is an integrated approach to the reinvention of environmental management that goes bond the historical adversarial approach of the agency being ft regulator and the company being #; regulated. It Is a precursor of how things are changing. It reflects a more responsible approach to regulation which acknowledges that industry and the community are partners with regulatory agencies in protecting the environment It is less regulatory and more collaborative.

We encourage you to continue to innovate and allow industry and the community work hand in hand to achieve superior performance for a sustainable environment

Letter #2

Jerome S. Fields
1117 N. 27th Street Allentown,
PA 18104 July 20, 1998

Ms. Nancy Birnbaum
U. S. Environmental Protection Agency 401 M Street SW
Room 1025WT (1802)
Washington, DC 20460

Dear Ms. Birnbaum:

I recommend approval of the Project XL Final Project Agreement (FPA) between the U.S. Environmental Protection Agency, Pennsylvania Department of Environmental Protection, and Lucent Technologies. An agreement between the regulatory agencies and Lucent can only help strengthen management of environmental programs at the Allentown, PA facility and help minimize operational impacts to the environment.

The regulatory agencies should be commended on their forward thinking by allowing Lucent to focus its efforts on continual improvement of its environmental programs. Lucent's commitment to ISO 14001 an Environmental Management System, can only help strengthen this FPA.

Finally, as a resident of the Lehigh Valley and a member of the Lucent Allentown Local Environmental Advisory Group, I am pleased that the hard work by all those involved with this agreement has resulted in a document that is understandable and workable.


Jerome S. Fields

Letter #3



James Bl Houtoun 3748 Haupts Bridge Road, Riegelsville PA 18077
Email: biground@bellatlantic.net Work:610-264-0111 Home:610-346-8209

July 22, 1998

U.S. EPA Region III
1650 Arch Street
Attn: Mr. Rich Kampf (3WPOO)
1650 Arch Street
Philadelphia PA 19103-2029

Re: Lucent Draft Final Project Agreement

Dear Mr. Kampf:

I have attended a number of LEAG meetings at Lucent's Microelectronics facility in Allentown as an observer and recently became a member. The high level of management commitment to more effectively protect the environment through its fully integrated EMS with active community involvement convinced me that this was an opportunity to be a participant in a major environmental improvement project, I believe that many of the concepts being piloted in the FPA can be transferred to both the public and private sectors to vastly improve, the way wastewater discharges are regulated and managed.

With a background in industrial wastewater management, I can appreciate the magnitude of the effort that went into developing the XL Project represented by the draft PPA. All of those involved from Lucent, the LEAG, the EPA, the PA DEP and the Environmental Law Institute are to be commended for a job well done. This project, in my opinion will serve as a model for many others to also develop similar programs based on cooperation and teamwork that will go well beyond compliance to achieve superior environmental performance.

Having worked under OSHA and EPA co to see the protect the environment in a more cost-effective. It is even more impressive to see the EPA and PA DEP working with industry and the community more as partners than just as enforcement oriented regulators. Thus, I believe that this Lucent FPA is a major step toward achieving future superior environmental performance, and I urge that EPA and PA DEP personnel participate actively as working partners whenever possible.

James G. Houstoun

Letter #4

July 22, 1998

Mr. Richard Kampf
1650 Arch Street (3WPOO)
Philadelphia, Pa 19103

RE: Public Comment on Lucent Technologies FPA for Project XL Dear Mr. Kampf,
'Me undersigned members of the Local Environmental Advisory Group (LEAG), to the Microelectronics Group of Lucent Technologies at the Reading, Pennsylvania facility have recently reviewed the Final Project Agreement (FPA) for Project XL. We- wholeheartedly support the system of environmental management defined in the document.

The six project objectives identified in the FPA support the integration of environmental protection and sustainability goals with business goals. This represents our essential common ground needed for the environmentally sensitive success of any business.

We have particular interest in the involvement of agencies and local community members in the Environmental Management System (EMS) process. In order to achieve superior performance within the EMS it is important that involvement and support from appropriate--parties is-in place. The FPA clearly defines opportunities for involvement including the continued importance of Lucent's LEAG within the EMS process.

Once again, we are pleased with the contents of the FPA for Project XL and look forward to reviewing a site-specific addendum for the Reading Microelectronics facility. Thank you for the opportunity to comment


Sean McGowan, Manufacturers Association of Berks County

Tami Jo Lutz, Berks County Conservancy

Joseph Hoffman, Berks County Conservancy

David S. Coult, Tulpehocken Chapter of Trout Unlimited

Lynn W. Scheirer, Retired

Robert J. Keegan, Transportation Skills Programs, Inc.
Richard T. Bell, NO

Annette C Moyer, Berks County Local Emergency Planning Committee

Risa Marmontello, League of Women Voters

Members of Lucent's LEAG
Reading, Pennsylvania

cc: L. Nancy Birnbaum, USEPA


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