Document 44B0vJEqeyGbkejdMe2yMwgge

Celanese ri I y I "HU,' .f1. Celanese Corporation 222 West Las Colinas Blvd. Suite 900N Irving, Texas 75039 March 31, 2025 U.S. Environmental Protection Agency 1200 Pennsylvania Ave. NW Washington, DC 20460 RE: Presidential Exemption: [New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry (SOCNII) and National Emission Standards for Hazardous Air Pollutants (NESIIAP) for the Synthetic Organic Chemical Manufacturing Industry and Group 1 & 11 Polymers and Resins industry]: Narrows (Virginia), Clear Lake (Texas), Bishop (Texas), and Bay City (Texas) Facilities o Whom It May Concern, The Celanese Corporation (Celanese) requests a two-year exemption from compliance obligations of the New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry (SOCMI) and National Emission Standards for Hazardous Air Pollutants (NEST TAP) for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry (collectively referred to as the HON Rule).[ For the reasons highlighted in this letter, we believe it is necessary and appropriate for the President to grant an exemption under Clean Air Act (CAA) Section 1 12(i)(4) for sources regulated by the final rule either on an individual basis or collectively. We request that the U.S. Environmental Protection Agency (EPA) include our regulated facilities under that action. We urge the Administration to swiftly consider and issue such an action based on an understanding that both: 1) "availability" for the purposes of this section refers not only to the existence of technology capable of achieving compliance with the rule, but encompasses practical challenges with the timeframes necessary to plan, procure, and install required technologies and such activity cannot occur within the current compliance tirneframe; and 2) national security encompasses not only military defense applications and infrastructure, but also economic security, a perspective that has been acknowledged by the President in Executive Orders and key security agencies like the Department of Defense. Indeed, as the White I louse has stated regarding domestic priorities, "economic security is national security."2 As additional support on this point, we reference the separate joint coalition submission sent to EPA from the National I-.missions Standards for IIa7ardous Air Pollutants (NESI LAP), Powering the Circat American ('omcback -:. -I -1. - ' . i 89 Fed Reg 42932 (May 16, 2024) 2 lineriert hrsi Inuesininif . .. . (Feb. 21. 2025) Sierra Club FOIA 2025-EPA-04883 ED_018388_00000215-00001 SC_EVERSPLIT0005979