Document JrJ2Kq8JrxLOJGmNZQOrZQVra

11&S Rule Presidential Exemption Request March 31. 2025 Page 10 of 10 encourage' ine EPA to communicate with "industry experts and other stakeholders" and ensure that the final rulcmakings arc "technically feasible, financially reasonable, and continue to protect the livelihoods, health, and safety of workers and steel-producing communities throughout our nation." That is exactly what this Administration is doing by providing outreach in the form of a Presidential Exemption, and we ask that you consider this request on its merits. The threat of global steel imports raised by the Senators in the letters to EPA is a material threat. Foreign steel imports risk the competitiveness and advancement of the domestic steel industry, to the point of potentially threatening U.S. domestic production capacity and continued investment in taconite iron mining, coke manufacturing, and iron and steelmaking capacity based on the costs outlined above. As emphasized by the L.S. Department of the Treasury's Committee on Foreign Investment in the United States ("CHUS"), without such domestic steelmaking investment, there could be ripple effects on the supply chains that depend on such steel, particularly supply chains that arc part of our national defense infrastructure such as "critical manufacturing, energy, transportation, and communications (all vital to national security)." 3' National defense infrastructure, for example, needs ready access to high purity steel from blast furnaces.3 ' Once these complicated iron and steel making operations arc shut down and/or idled, it is no simple matter to restart them. In short: "The loss of domestic production is a critical national security concern given the ubiquitous nature of steel throughout multiple critical industries."32 For all the reasons stated above, Cliffs urges the issuance of a two-year exemption from the compliance deadlines in the final 11&S Rule, pending EPA's review of the rule for possible revision. If you have questions or need additional information, please contact Walter Iamukang at 216-694-4862 or at 11,2t c!,:\ ,2LoRLI Respectfully submitted, Traci L. Forrester Executive Vice President, Environmental & Sustainability Cleveland-Cliffs Inc. cc: Peter Tsiri2otis, U.S. EPA OAQPS Director, 1..[:yeti, Penny Lassiter, U.S. EPA OAQPS Director of Sector Policies and Programs Division I.etter from Andrew Fair, Acting Assistant Secretary for Investment Security, U S. Department of the 1Freasury, to Ama Adams, Ropes & Ciray I.I.P, and Mark Plotkin, Covington & Hurling I.I.P, Re CHUS Case 24-154 (I)cc. 14, 2024) ("CFIUS Letter"), p 28. 3 Id at p 24 32 Id at p 28 1104059958 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000118- 00010 SC_EVERSPLIT0005816