Document 85KMbXYwL1L3Mr5YqrNgYxKxe

Vinyl Institute Letter in Support Request for Presidential Exemption March 31, 2025 The economic implications are significant when we consider jobs for downstream fabricators, transporters, distributors, and recyclers of PVC construction products (installers are included in the 350,000 number above). It is estimated that 75% of PVC products are used in construction applications, including drinking water pipes and fittings, energy-efficient windows, roofing, wall covering, flooring, and fire-resistant wires and cables. All of these products are important to expanding U.S. inventory of new homes and also are widely used in renovating existing homes. Thus, it would be unfortunate in the extreme if the HON rule and its technically infeasible requirements were to cause disruptions in facility operations, threaten supply chains for products vital to our economy and our national security, at a time when we are looking to expand domestic manufacturing and economic activity. Nor would these adverse effects be limited to the construction industry. As Figure 1 below indicates, PVC and its raw materials inputs are important components in the chlor-alkali supply chain. Disruptions in these downstream raw material inputs will reverberate back throughout that chain with broader implications for the national economy. US PVC Resin Operations Upstream Production ,I PVC Resins Homopol yrnef and Copolymer Downstream Products after Ing:cdic lit Compounding Recycling LJ Resin Polyrnerizetiort z F, h.:, iF, p --, Buk Blending - Latex Figure 1: PVC Industry Role in the Chlor-Alkali Supply Chain Such disruptions are also unnecessary, as far as VI members that produce PVC are concerned, as those facilities have been subject to and are operating under D/F limits since 2012.' Indeed, 17 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Polyvinyl Chloride and Copolymers (PVC) Production, 77 Fed. Reg. 22,848 (April 17, 2012). 1747 Pennsylvania Avenue, NW, Suite 825 Washington, D.C. 20006 (202) 765-2179 www.vinylinfo.org www.vantagevinyl.com Page 5 of 6 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000080-00005 SC_EVERSPLIT0005639