Continental Carbon
May 24, 2017
Highly Confidential/ Settlement Communication Subject to FRE 408 Contains Confidential Business Information
By Email
Jeffrey Wood Acting Assistant Attorney General Environmental and Natural Resources Division U.S, Department of Justice Washington DC
Byron Brown Deputy Chief of Staff Amanda Gunasekara Senior Policy Advisor U.S. Environmental Protection Agency Washington DC
Re: Continental Carbon Company
On behalf of Continental Carbon Company (CCC), I want to thank you and your colleagues from the Department of Justice and the Environmental Protection Agency for meeting with us last week.
As we explained, the situation at CCC is dire. We must have urgent relief from the deadlines in our Consent Decree. Without urgent relief, the extraordinary costs to install the pollution controls imposed by the Decree will soon force us to close operations.
Moreover, beyond providing this urgent relief to CCC, DOJ and EPA must take action to ensure all U.S. carbon black companies face the same Clean Air Act requirements on the same schedule as imposed upon CCC. Failure to act against our three non-settling competitors has led to an unfair marketplace - solely due to uneven EPA enforcement.
To be clear, CCC does not seek special treatment. We seek only the level playing field DOJ and EPA committed to when CCC signed its Consent Decree. Otherwise, hundreds of high-paying jobs for hardworking Americans will be lost - and the small communities in Oklahoma, Alabama, and Texas where we invest more than $300 million each year will suffer. Without CCC, our competitors will increase production and reap windfall profits --all while significantly increasing emissions from uncontrolled facilities.
Please do not force Continental Carbon out of business. Instead, we urge you to apply the law consistently and fairly, and thereby preserve American jobs and protect the environment.
Thank you for your consideration.
16850 Park Row, Houston, IX 77084, TEL (281 ) 647-3700
Sierra Club v. EPA 18cv3472 NDCA
9.14.2020 Production
ED 002061 00087912-00001