Re: United States v. CBS Corp.

April 22, 1999

I have shared your letter of April 12, 1999 with our firm's client, CBS Corporation ("CBS"). CBS is currently preparing comments on the U.S. Environmental Protection Agency's ("EPA" or "the Agency") proposed design, and its overall approach, for a water treatment system at Illinois Central Springs, as explained at the March 25, 1999 Chicago meeting. CBS received the remaining document that is needed to understand EPA's design earlier in the week, but has yet to receive the Agency's design assumption. Please provide that document as soon as possible. CBS should be prepared to submit its comments on EPA's proposal in about two weeks. At that time CBS will also be able to respond formally to the request made in your April 12, 1999 letter.

The proposal you outlined for us in Chicago does not resemble in any respect the interim water treatment system you described to Judge Foster and the other parties to the litigation last year. Moreover, your cost projections are at least triple the estimates you presented in Court. Under these circumstances, we believe that it is in both EPA's and CBS's interest that the Agency makes no further commitments to construct its proposed system until it has reviewed CBS's comments and its response to your letter. If this schedule is not feasible, please contact me.