Document MDn1p0V7qDKgZLr3nz33LJ9y

From: Mavian, Kari (K) [KMavian@dow.com] ent: 3/5/2025 10:06:29 PM o: Tardif, Abigale (Abbie) [Tardif.Abigale@epa.gov] C: Lassiter, Penny [Lassiter.Penny@epa.gov]; Tsirigotis, Peter [Tsirigotis.Peter@epa.gov]; Bouchard, Andrew [Bouchard.Andrew@epa.gov]; Donahue, Sean [donahue.sean@epa.gov]; Szabo, Aaron [Szabo.Aaron@epa.gov]; Dominguez, Alexander [dominguez.alexander@epa.gov]; Lessard, Patrick [Lessard. Patrick@epa.gov] object: Dow follow-up to ACC/AFPM HON meeting ttachments:2025-03-4 HON Reconsideration Letter Dow Final.pdf; 2025-03-4 HON Reconsideration Letter UCC Final.pdf Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Dear Principal Deputy Assistant Administrator Tardif, Please find attached two follow-up letters from Dow and Dow's subsidiary, Union Carbide, reiterating our immediate request for an extension of the compliance date for the HON. Thank you again for meeting with us in February to discuss this rule and the urgent nature of this request. As we mentioned in our meeting, and in our comments and meetings with EPA during the HON rulemaking process, the two-year compliance deadline is not practical for the types of projects needed to comply with this rule. That has been confirmed by our project teams and further detailed in the attached letters. In addition, we express support for the ACC and AFPM petition for reconsideration due to the technically unachievable requirements in the final rule, also further detailed in the attachments. Please contact me with any questions or information you may need to assist with this request. Thank you for your attention to this. Best regards, Kari Kari Mavian Global Director of Regulatory Advocacy and Poli Dow 500 North Capitol St "TUT Suite 200. Washington, D.C. 20001 Mobile: 202.997 161.1 Lrnail lunavian dow.com Sierra Club FOIA Request: 2025-EPA-04193 ED_018475D_00003154-00001 SC_FOIA_0001081 Seek 'ou General Business Sierra Club FOIA Request: 2025-EPA-04193 ED_018475D_00003154-00002 SC_FOIA_0001082