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Records of the Council on Environmental Quality (Clinton Administration)
Kathleen McGinty's Files
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FOIA Number: 2012-0769-F
FOIA
MARKER
This is not a textual record. This is used as an
administrative marker by the William J. Clinton
Presidential Library Staff.
Collection/Record Group:
Clinton Library Collection
Subgroup/Office of Origin:
Council on Environmental Quality
Series/Staff Member:
Kathleen (Katie) McGinty
Subseries:
Correspondence
OA/ID Number:
2254
FolderID:
Folder Title:
[J - February 1994] [Loose]
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S
61
5
2
2
THE WHITE HOUSE
WASHINGTON
February 25, 1994
Ms. Mary K. Jakeway
Senior Environmental Engineer
Whirlpool Corporation
Marion Division
1300 Marion-Agosta Road
Marion, OH 43302
Dear Ms. Jakeway:
Thank you for your letter regarding the Enhanced Monitoring
Rule of the Clean Air Act Amendments of 1990. It was good to
hear from you.
As you know, I am dedicated to the preservation of the
environment in a way that leads to strong and sustainable
economic growth. I understand your concerns about the Enhanced
Monitoring Rule. I have taken the liberty of forwarding a copy
of your letter to the EPA for their reference. Please be assured
that all viewpoints, including those of industry, will be
considered as the rule is finalized.
Again, thank you for sharing your views with me.
Sincerely,
Kathleen A. McGinty
Director, White House Office on
Environmental Policy
KAM/jdm
Whirlpool
Marion Division
CORPORATION
1300 MARION-AGOSTA ROAD, MARION, OHIO 43302
AREA CODE 614 383-7122
January 28, 1994
Katie McGinty
Deputy Assistant to the President and Director
Office of Environmental Policy
Old Executive Office Building
Room 360
Washington, D.C. 20500
Dear Ms. McGinty,
The Enhanced Monitoring Rule proposed pursuant to the Clean Air Act
Amendments of 1990 will impact the Whirlpool Corporation since we are a "major
manufacturing facility". The EM requirements are in addition to compliance assurance
monitoring already required for the same operations under the new federal permitting
requirements and produce no incremental environmental benefit beyond that required
by permit monitoring.
As the environmental engineer for the Marion, Ohio Division of the Whirlpool
Corporation, I would like to submit the following comments regarding the enhanced
monitoring rule as proposed:
1.
This represents another unfunded mandate that is contrary to Executive Order
12875 and contravenes the Regulatory Planning & Review Directive in Executive
Order 12866, with additional hidden costs to states to revise their state
implementation plan. These requirements also ignore the significant compliance
costs state and local governments will incur for their own compliance with EPA
enhanced requirements at water treatment facilities, state universities, hospitals,
airports, local incinerators, and maintenance shops for municipal buses and other
governmental fleets.
2.
The rule would place extra cost burdens on the regulated community without
justifiable environmental benefits.
3.
Large Environmental Opportunity Costs -- The rule will freeze manufacturing
technologies and pollution control as well as innovative pollution prevention
because of financial and human resources diverted to meeting enhanced
monitoring requirements.
4.
EPA has grossly understated the cost of compliance equipment and of its
operations and maintenance.
5.
Rule locks in existing operations and create a disincentive for pollution prevention
and waste minimization, which will reduce incentive to create new jobs and could
close economically marginal operations which otherwise meet all environmental
standards.
Ohio EPA estimates an additional staffing level of 20 persons to handle the additional
workload generated by this rule alone. For sulfur dioxide, 129 sources emitting greater
that 1000 tons/year represent 96% of the total emissions. These 129 sources
represent 5.8% of the total sources impacted by the rule. Therefore tremendous effort
and cost would be expended for minimal return. For VOC's, 70% of the emissions
would be captured by those sources emitting greater than 1000 tons/year.
Requiring submittal of quarterly reports will add costs with no benefits. The operating
permit program already requires submittal of monitoring data from all sources.
Whirlpool is part of the voluntary 33/50 program and has reduced emissions 60% from
1987 levels. The EM program will pull manpower from this pollution prevention effort to
conduct "after the fact" monitoring. We urge you to incorporate industry concerns into
the final rule.
Sincerely,
Mary K
Mary K. Jakeway
Sr. Environmental Engineer
MKJ:kt
CC:
Sally Katzen, Administrator
Office of Information & Regulatory Affairs
THE WHITE HOUSE
WASHINGTON
February 24, 1994
Johnson
ive
8161
son:
u for contacting me regarding your thoughts about
cated in the Tennessee River Valley. It was good
you.
now, I share President Clinton's and Vice President
ment to the preservation of our environment. I
ur concerns about the potential environmental
ip mills on the adjacent rivers, as well as the
mber harvesting in regions surrounding the mills. I
the Administrator of the Environmental Protection
e Acting Assistant Secretary of Civil Works of your
his matter. I am sure that your concerns will be
onsideration.
hank you for sharing your views with me.
Sincerely,
Kathleen A. McGinty
Director, White House Office on
Environmental Policy
Feb, 14 Feb.14
I am writing this letter to you because
Ms McGinty:
I am concerned about the poss bility of an
invasion of chip mills, pulp mills, and paper
mills into the bioregions of the Southeastern
Un kd States Clearcutting of the native hard-
wood forests to make pulp, to ship off to
Japan, to subsequently plant monospecies pine
plantations, on any scale 13 completely
unacceptable. I demand that trat.justice be done
for once in a situation like this, instead of
the usual montel 'money talks' influenced
outcome. Specifically- the Army Corps of
Engineers should be stricky made to follow all
Environmental rules and regulations in regard to
Sincerely,
Newkirk L. Johnson
13800 Lake Drive
Monroe, MI
48161
this problem.
THE WHITE HOUSE
WASHINGTON
February 17, 1994
Mr. Thomas Jensen
Executive Director
Grand Canyon Trust
"The Homestead"
Route 4
Box 718
Flagstaff, AZ 86001
Dear Mr. Jensen:
Thank you for writing to me about noise pollution in the
Grand Canyon. As always, it was good to hear from you.
As you know, I am dedicated to the improvement of America's
natural resources. I appreciate your bringing this problem to my
attention. I understand your concern in this area, and have
taken the liberty of forwarding your letter and information to
the FAA for their review and response. I am sure that your
concerns will be given every consideration.
Again thank you for sharing this information with me.
Sincerely,
Ms. Kathleen A. McGinty
Director, White House Office on
Environmental Policy
KAM/jdm
GRAND CANYON TRUST
BOARD OF TRUSTEES
Steven Snow
Chairman
Hansjörg Wyss
MEMORANDUM
Secretary-Treasurer
James Trees
Founder and
TO: Katie McGinty
Honorary Chairman
Claudeen Bates Arthur
FR: Tom Jensen KJ
James E. Babbitt
Anne K. Bingaman
David Bonderman
RE: Attached Articles
Robert Elliott
Bert Fingerhut
DT: November 23, 1993
David H. Getches
Helen Ingram
Ann McBride
Norma W. Matheson
Katie,
N. Scott Momaday
Chase N. Peterson
John P. Schaefer
Isn't there something you could do to encourage the FAA
William B. Smart
to protect the Grand Canyon? They've got the jurisdiction,
Stewart L. Udall
they've got the authority, they just don't have the political will.
Thomas C. Jensen
This should be an easy one.
Executive Director
The single best first step for the FAA to take would be to
sign-on to the agreement that is referenced in the Arizona
Republic editorial.
Have a great holiday. It was a delight to see you the other
evening. I hope all is well.
Please let me know if you would like additional
information on the aircraft issue.
Tom
Headquarters Office: "The Homestead", Route 4, Box 718, Flagstaff, Arizona 86001 (602) 774-7488 FAX (602) 774-7570
Utah Office: "The Sandstone Bldg.", 46 Ancestor Square, 2 West St. George Blvd., St. George, Utah 84770 (801) 673-8558 FAX (801) 673-8545
Washington Office: 1400 16th Street, N.W., Suite 300, Washington, D.C. 20036 (202) 797-5429 FAX (202) 939-3427
USA TODAY THURSDAY, NOVEMBER 18, 1993 11A
THE ENVIRONMENT
Push afoot to shush
air-tour park noise
THE NATION'S NEWSPAPER
By Linda Kanamine
ing a ban of the helicopter
USA TODAY
landing pad there.
A helicopter operator
National park visitors are
tried to locate a helipad out-
USA
rumbling about obtrusive
side Utah's Zion National
noise from air tours.
Park. Adjacent towns reject-
Six years after Congress
ed it, saying Zion Canyon is a
passed a law to turn down the
natural echo chamber.
volume from tour planes and
Tennessee, home to the
helicopters over Arizona's
TODAY
Great Smoky Mountains Na-
Grand Canyon, activists there
tional Park, passed a law pro-
/ Cape Solitude has no soli-
hibiting helipads within 9
NO. 1 IN THE USA
tude. Point Sublime isn't.
miles of the park border.
FIRST II DAILY READERS.
Similar complaints created
Businesses are challenging it.
such cacophony at Hawaii's
Superintendents have no
craters, pools and volcanoes
real authority to limit, control
that Congress begins hearings
or charge fliers because air
today on legislation to curb
traffic is regulated by the
flight effects over national
Federal Aviation Administra-
parks there.
tion. "That's why there's frus-
"It sounds like you're in
tration," says the Park Ser-
downtown traffic," says Ho-
vice's Wesley Henry.
Noise in national parks
nolulu's Nelson Ho, about hik-
He is compiling a report
The National Park Service studied aircraft noise at 39
ing the giant crater at Hale-
that shows visitors continue to
of its 367 sites in the USA. Those sites found to have
akala National Park.
be unhappy about noise.
"In the 1970s. the only
Recommendations to Con-
noise that could be considered annoying:
sound there was the wind, the
gress may range from limit-
ARIZ.: Glen Canyon National Recreation Area, Grand
crunching of lava cinder be-
ing numbers, times and areas
Canyon National Park, Saguaro National Monument
neath my boots, and the
of overflights; giving opera-
sound of blood rushing
tors incentive to use new, qui-
ARK.: Park Buffalo National River, Hot Springs National
through my eardrums."
et technology; and charging
Hawaii and Grand Canyon
fliers park fees.
CALIF.: Sequoia and Kings Canyon national parks, Yo-
are a leading wave in the
For Roger Clark of the
semite National Park
soaring, $180 million-a-year
watchdog group Grand Can-
FLA.: Everglades National Park, Gulf Islands National
air tour business.
yon Trust there's little doubt
Seashore (also in Mississippi)
As the nation's most trea-
change is needed: "If you're
GA.: Cumberland Island National Seashore
sured reai estate draws ever-
seeking Solimute, it's a place
growing crowds - 250 mil-
hard to get to."
HAWAII: Hawaii Volcanoes National Park, Haleakala
lion a year air tour
But the key rests in large
National Park
operators aren't far behind.
part with the FAA, concerned
MD.: Assateague Island National Seashore
Air operators call this legis-
primarily with safety.
lation, and a pending Park
"The agency recognizes
MASS.: Cape Cod National Seashore
Service report on systemwide
that protecting the environ-
MO.: Wilson's Creek National Battlefield
problems, an attack.
ment is also part of our mis-
MONT.: Glacier National Park
"The park service says we
sion. We intend to cooperate
have not restored the natural
fully with the Park Service,"
NEV.: Lake Mead National Recreation Area
quiet to the Grand Canyon, as
says the FAA's Pat Cariseo.
N.M.: Bandelier National Monument
the law requires," says Miles
Without action soon, many
Becker of Papillon Grand
parks will face the same pres-
OHIO: Perry's Victory, International Peace Memorial
Canyon Helicopters. "But we
sures as the Grand Canyon,
PA.: Gettysburg National Military Park
must figure out some type of
says Terri Martin of National
S.D.: Mount Rushmore National Monument
solution."
Parks and Conservation Asso-
Meanwhile, the popularity
ciation. "National parks are
TENN.: Great Smoky Mountains National Park
of air tours is spreading:
just 1.5% of the land base in
VA.: Shenandoah National Park
Helicopter flights began
the lower 48 states, and you
this summer over Arches and
still can't escape the sound of
WASH.: Mount Rainier National Park, North Cascades
Canyonlands national parks
machinery?" she says.
National Park, Olympic National Park
in Utah. Moab, Utah. is debat-
"That's a travesty."
Source: National Park Service
The New York Times
THE NEW YORK TIMES EDITORIALS/LETTERS WEDNESDAY, NOVEMBER 17, 1993
Parks Are for People, Not Planes
You and your kids have just hiked or driven to
visitors buzzed the canyon in 1992; one outfit alone
Desert View, a vantage point at the eastern end of
conducts 100 flights a day during the summer.
the Grand Canyon. To the north and west lies the
The villains are not so much the tour operators
Colorado River; to the east, the Painted Desert. And
as the Department of Transportation and the Fed-
right above you, not quite close enough to touch but
eral Aviation Administration. In 1988 the F.A.A.
certainly close enough to ruin the moment, hovers a
gave Arizona $1 million to expand helicopter facili-
sightseeing helicopter.
ties at Grand Canyon National Park Airport, which
The Grand Canyon has become a battleground
could lead to still more flights.
for the human senses, and the airplanes are win-
Bruce Babbitt, the Secretary of the Interior,
ning. At peak season, anyone standing at Desert
has urged the Secretary of Transportation, Feder-
View might experience only a few minutes of tran-
ico Peña, to delay the expansion pending the com-
quillity between flights.
pletion of a National Park Service study on noise
This is not what Congress had in mind when it
levels. Mr. Babbitt clearly foresees a day when
passed the National Parks Overflights Act in 1987 to
there will be fewer flights, not more; so far, Mr.
restore "the natural quiet and experience of the
Peña has been silent on the matter.
park." Subsequent regulations banned flights below
It's difficult to find any national park where
the canyon's rim but did nothing to prevent flights
only the silence of nature is heard. Parks are for
from doubling in the next six years. Nearly 800,000
people. But not for 200 or 300 planes a day.
EDITORIALS
OVERFLIGHTS AT GRAND CANYON
Tuesday, November 23, 1993
FAA lost in space
O
K Mr. President, what is it going
meddlesome bother, Babbitt clearly is on
to take to bring a little badly
the mark.
needed focus to the Federal
What makes this dalliance by the
Aviation Administration? We're not allud-
FAA especially bothersome is the fact that
ing to the crowded air corridors above
there appeared to be a consensus reached
metropolitan areas of the East or West
this summer in Gov. Symington's office.
coasts. We're talking about the congested
The purported deal was that canyon tour
skies above one of the marvels of this
operations for each company would be set
planet the Grand Canyon.
at the level recorded from Sept. 1, 1992
In the past the FAA curiously has
through Aug. 31, 1993, plus a 5 percent
moved with all the grace of a stubborn
growth. These limits would be in force
burro whenever Grand Canyon overflights
until new regulations based upon the NPS
has been the topic. Early on the FAA
study of noise.
always had a great deal of difficulty
This is a sensible approach and
coming to grips with the congressional
should not be onerous for tour operators.
THE ARIZONA REPUBLIC
intent of the 1987 legislation that sought
To permit uncontrolled expansion at this
to regulate noisy and intrusive overflights
time would be foolish, especially if the
at Grand Canyon National Park for the
studies find that the canyon's level of
"substantial restoration" of the natural
quietness is not appreciably improving.
quiet.
Tour operators, for their part, appear
Six years later, with the number of
to be willing to limit expansion, but with a
rattling helicopters having doubled -
catch; a loophole as big as the Big Ditch is
serving 250,000 passengers per year - the
deep. They would do so only for 12
stubborn streak shows no signs of
months, not wanting to wait until
weakening.
implementation of new regulations. The
The FAA now is refusing to
difficulty with this cart-before-the-horse
participate in an agreement that is being
approach is that if full-blown expansion
sought by, among others, the National
were to be allowed, the law likely would
Park Service and the non-profit Grand
Canyon Trust, a Flagstaff-based environ-
be on the side of tour operators, regardless
mental group. The idea is to limit the
of what the studies found. Thus, the
expansion of helicopter air tours pending
possibility exists for more flights and more
the completion of studies on aircraft noise
noise, and the studies be damned.
It was the FAA that awarded
and air capacity over Grand Canyon.
Oddly, not even a letter from Interior
Arizona $1 million for the building of new
Secretary Bruce Babbitt to Transportation
facilities at Grand Canyon. That was in
Secretary Frederico Peña seems to have lit
1988, and still pending is the awarding of
a fire. The only thing it has produced is
leases by Arizona to air tour operators.
stoney silence. Do matters of turf take
The consolidation of operations at the
precedent on something as important as
airport cannot be faulted from the
improving the canyon experience for
standpoint of safety.
visitors from around the world, Mr.
But this is much more than just a
President?
question of safety. This is about natural
What Babbitt is seeking are assur-
quiet at Grand Canyon, about following
ances that a new heliport at Grand
the will of the U.S. Congress, and about
Canyon National Park Airport will not be
not letting the skies over the crown jewel
used by air tour operators as justification
of the country's park system rival LAX.
to expand operations until ongoing studies
Mr. President, you ought to haul the
are finished. The interior secretary warned
FAA back to Earth, and encourage the
that the construction of new helicopter
agency to keep air tour operations at
facilities "has the potential to increase the
Grand Canyon in line with existing levels.
capacity for overflights and thus will
What's the rush? Until studies are
further negate the statutory goal." With
completed and new regulations imposed,
the canyon skies arguably at capacity and
to permit anything else would be irrespon-
with few places left where noise is not a
sible and premature.