Document LKYkDXzYDNVkQVVgMn9VG7XYQ

Hon. Lee M. Zeldin March 31, 2025 Page 10 President's America First Investment Policy, "economic security is national security." Consistent with this, the Federal government has determined that the steel industry is "critical to minimum operations of the economy and governmeni."4 In the case of steel, the history of L.S. Government actions to ensure the continued viability of the domestic steel industry demonstrates that, across decades and Administrations, there has been consensus that domestic steel production is vital to our national interest. The overall security of the nation is dependent upon a strong economy and investments in industry and infrastructure. All of these goals arc supported by the steel industry, and it needs to have protection from the proposed rules until such time as a proper review can take place. The unprecedented and exorbitant costs that U. S. Steel would need to incur to attempt to comply with the Coke RTR Rule would risk U. S. Steel losing viable commercial production capabilities and will jeopardize the domestic industry's ability to meet the full spectrum of infrastructure and investment needs. Ensuring that U. S. Steel and other steel producers are able to continue to produce steel in the market for U.S. commercial and infrastructure needs is necessary to grow the U. S. market and economy. The Coke RTR Rule, as well as the other rules affecting the domestic steel industry, will result in unprecedented costs which will jeopardize the long-term operations of U. S. Steel (and other steel producers.) If U. S. Steel is not financially viable to invest in the latest technologies, facilities, and long-term research and development, nor retain skilled workers while attracting a next-generation workforce, it will be unable to support the nation's infrastructure, economy and commercial needs. C. Cumulative Burden In 2024, EPA promulgated three new steel sector rules' resulting in dozens of new emission limits and work practices materially impacting the domestic iron and steel critical operations in the United States. A Presidential Exemption is necessary to prevent significant direct adverse impacts and irreparable harm to domestic steel production and infrastructure. The promulgation of these three rules, simultaneously with other recent significant EPA actions, including most notably, the lowering of the PM2.5 NAAQS and the adoption of the I)cpaitmcnt of Commercc, Bureau of I-lxport Administration; The Effeci SIM on fhe .Vedional Seutordy, October 2001 linpons of Iron Or and Semi-hnished b The three rules at issue are 1) Naiional Emission Standards for Hazardous Air Pollutant: Integraied Iron and Sied Manufaciuring Facilnic (EPAIIQ-EPA-OAR-2002-0083). April 3. 2024. Federal Regi.sfer. (89 Fed. Reg. 23294) 2) National Lmi,,sion Standard', for IFaiardous Air Pollutant', for Coke 0\en,, Pushing. Quenching. and Battery Stack ,,. and Coke (hen Batterie,,. (}.PA I TQ OAR 2002 0085 and EPA I TQ OAR 2003 005 )..1i.dy 5. 2024. bedend Regiver. (89 Fed. Reg. 55684): and 3) Naiional Emission Standards for Hazardous Air Pollutant: Taconite Iron Ore Processing Amendments (EPA-TIQ-OAR20 [7-0664).11...larch 6. 2024. beciend Reg (89 I'(I'd Reg 16408). Sierra Club FOIA 2025-EPA-04883 ED_018388_00000141-00010 SC_EVERSPLIT0005865