Document LJY4JjeEGxgy7z9dpzZbE97v7

ACC-AFPM Letter on HON CAA 112(i)(4) Exemption March 31, 2025 Page 8 well as fungi, yeasts, and spore formers. It is also used as a fumigant to control insects in the storage and transport of grain, seeds, and nuts. Agriculture: EO derivatives are used in agricultural products to help protect crops and boost crop production. It is used to produce active ingredients in insecticides, pesticides, and herbicides. It is also used to produce surfactants (wetting agents) and dispersants which reduce the amount of pesticides, insecticides, and herbicides required in agriculture and enhances the effectiveness of the application of those products. The HON Rule and its technically infeasible requirements will result in facility shutdowns, imperiling jobs, and threatening supply chains for a vital chemical building block critical to our national security. The substantial risk of multiple shutdowns combined across HON facilities could result in a massive strain on domestic supply of chemicals that are critical to national security and central to the U.S.'s strategic position in the global economy in key markets. Without immediate intervention, such as a Presidential exemption under CAA Section 112(i)(4) to extend the compliance deadline for two years or, in the alternative, a compliance extension under CAA Section 112(i)(3), and an interim final rule rescinding those regulatory requirements not based on the best reading of CAA section 112(f), companies will evaluate whether to shut down units or offshore their operations to prevent the application of an imprudent and unlawful rule. * * * * * * * * * ACC and AFPM appreciate this opportunity to request a two-year compliance extension for all sources subject to the HON Rule. If you have questions or need more information, please do not hesitate to contact Leslie Bellas at lbellas afpm.org or Brendan Mascarenhas at Brendan Mascarenhas americanchemistry.com. Sincerely, Brendan Mascarenhas Senior Director, Regulatory & Scientific Affairs American Chemistry Council Leslie Bellas Vice President, Regulatory Affairs American Fuel & Petrochemical Manufacturers cc: Aaron Szabo, Senior Advisor to the Administrator, Office of the Administrator Abigale Tardiff, Principal Deputy Assistant Administrator, Office of Air and Radiation Sean Donahue, Principal Deputy General Counsel, Office of General Counsel Alex Dominguez, Deputy Assistant Administrator for Mobile Sources, Office of Air and Radiation Peter Tsirigotis, Director, Office of Air Quality Planning and Standards Penny Lassiter, Director, Sector Policies and Programs Division, Office of Air Quality Planning and Standards Patrick Lessard, Refining and Chemicals Group Leader, Office of Air Quality Planning and Standards Andrew Bouchard, General Engineer, Office of Air Quality Planning and Standards Sierra Club FOIA 2025-EPA-04883 ED_018388_00000225-00008 SC_EVERSPLIT0005340