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Comments from Don't Waste Arizona, Inc.

I. Comments from Don't Waste Arizona, Inc. to EPA (August 24)

Mr. Fred Hansen Mr. Keith Laughlin
Deputy Administrator and Associate Director
Mr. David Gardiner Council on Environmental Quality
Assistant Administrator 722 Jackson Place, N.W.
U.S. Environmental Protection Agency Washington, D.C. 20501
401 M. Street, S.W.
Washington, D.C. 20460

Dear Gentlemen:

Don't Waste Arizona, Inc. (DWA) is a state-wide Arizona non-profit environmental organization. DWA has been represented at every Intel Project XL public meeting, on at least one conference call regarding the Project, and has offered comment at every opportunity. DWA's representatives have even attended a sub-committee meeting for the air quality portion of the Project. DWA has also gathered a sense of perspective about the other Project XLs, and believes that the Intel Project XL has shown by process and product that it has done the best job of any in community outreach, access, and environmental performance. Regarding the process, Intel has really been beyond reasonable in seeking and incorporating the views of the community and others like DWA that are not specific members of the stakeholder panel. It has been very obvious that this process was not a sham like DWA often encounters with public agencies in Arizona and that Intel really wanted to hear from DWA and others and was willing to listen and cons
ider all ideas and opinions. This is exactly the type of openness that DWA hopes and expects that EPA will require for all Project XL candidates. The product and the process of the Intel Project XL are a model for other Project XL candidates and facilities of how to do it right.

Intel is to be commended for its openness and honesty about the efficiency of caustic scrubbers at its facilities and the types and amounts of its HAPs. It took courage for Intel to volunteer this information so that stakeholders would have an accurate picture of the situation. Fortunately, even with the full disclosure about air emissions, an acceptable agreement was reached. I don't know of any other industrial leader that has been so forthcoming. Indeed, most operate in a secrecy that is in stark contrast to Intel. For example, when the Motorola 52nd Street facility recently wanted to expand, it withheld all air emissions data from the public throughout the public hearing process with the collusion of the Maricopa County Environmental Services Department, Division of Air Pollution Control. Of course there was nothing for the public to comment on. EPA perhaps can review and compare the Motorola 52nd Street facility's air emissions with Intel's. Judging from the information available through the Toxic
Release Inventory, most certainly, Intel's air emissions are enormously less, illustrating superior environmental performance and accountability to the public.

The air permit for Intel FAB 12/Project XL ensures that the facility will operate within limits that are safe for the public and the environment. This air permit sets a new and better standard for everyone. Also the community will get much more current, accurate, and up-to-date information about exactly what the facility's air emissions are, and more frequently then what the current law requires. The Maricopa County Environmental Services Department, Division of Air Pollution Control, meanwhile, is still attempting to gather the emissions data for all facilities for 1994! DWA has even had to threaten legal action just to get public files from this agency, so Intel's honesty and openness are certainly far beyond regulatory requirements and current practice.

Intel has found a way to ensure that growth can continue in an environmentally safe manner by focusing on what is really important - the environment. Instead of getting wrapped in layers of paperwork, Intel's project ensures that FAB 12 will have the flexibility to quickly change processes while continuing to go beyond compliance with air emissions. With Intel's openness about its facility's environmental compliance and performance, it sets a positive model and precedent for companies, and shows that companies, communities, and government can work together to achieve environmental goals important to all.

DWA is proud to have participated in this Project XL and heartily commends and recommends Intel FAB 12 in Chandler, Arizona to you.


Stephen M. Brittle Scott Meyer
6205 South 12th Street
Phoenix, AZ 85040 cc: Intel

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