Document XKNgVZj3LeZRm2z5oXbqLwXB
I aconite Rule Presidential Exemption Request March 31, 2025 Page 7
to achieve the very low levels of HAP emissions from taconite fun-laces is far from demonstrated
in practice and may not be achievable for many taconite furnaces. Accordingly, a minimum of a
two-year extension of time for compliance is clearly appropriate for all affected sources in the
Taconite Iron Ore Processing industry. For additional information on issues with control
technologies in the taconite processing industry refer to Comments ref AISI and 17. IS.
(July
7, 2023), Docket No. EPA-IIQ-OAR-2017-0664-0181.
For all the reasons stated above, none of the technologies identified to implement standards in the Taconite Rule are available within the period between the present and the compliance date of March 8, 2027, and an exemption should be granted extending the compliance date until March 8, 2029, to all the sources on the attached list, while EPA reconsiders the Taconite Rule.
B. 1T IS IN THE NATIONAL SECURITY INTERESTS OF THE UNITED STATES TO PROVIDE AN EXEMPTION FROM THE TACONITE RULE COMPLIANCE DATE
The impact of the Taconite Rule is far-reaching and undermines the country's national security interests given that taconite is an essential raw material for the integrated iron and steel industry, an industry critical to national security. The L.S. Department of Commerce recognized that domestic steel production is essential for national security applications, which it indicated encompasses transportation systems, the electric power grid, water systems, and energy generation systems in its report summarizing the findings of an investigation conducted by the Department of Commerce pursuant to Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862 ("Section 232")), into the effect of imports of steel mill products ("steel") on the national security of the United States. [ In a 2021 Congressional Research Service Report on United States Steel Manufacturing: National Security and Tariffs, it was noted that under the Defense Production Act, 50 U.S.C.. 4533, "Congress provides the President with a broad set of authorities ..., including Title III, which authorises the use of economic incentives to secure domestic industrial capabilities essential to meet national defense and homeland security needs. DOD has funded several Title III projects to increase domestic production of steel products," including a $56 million agreement in 2020 to boost steel plate production signed by the predecessor owner of a Cliffs' facility.2
Ensuring the strength and global competitiveness of this industry is of vital importance to the nation's economy, security, and manufacturing prowess. Supporting this is the fact the industry provides more than $520 billion in economic output, nearly two million jobs, more than $130 billion in wages and benefits to employees, and S56 billion in federal, state and local taxes. Cliffs alone employs approximately 27,000 people, most of whom are members of
See U S Department of Commerce liureau of Industry and Security Office of I
Evaluation, The /lieu'
rlf Imporis Sieel on nu, Nanonal Se uundr Repon, Repori hF f1 January II 2018,
https:',www.commerce.g,oy,sites defaultfiles'the effect of imports of steel on the national security -
with redactions - 20180111 pdf
2 Congressional Research Service Report, 1- Sfeel Alanufacnoring Nalional Seuurdr and l'ardfs (August 12,
2021), httris ''www.cong,ress g,oviers-product'II-11897
Sierra Club FOIA 2025-EPA-04883
ED_018388_00000218-00007
SC_EVERSPLIT0005989