Document kw8oO4zzg2vLREKnB1YqJyZ0

To: Dravis, Samantha[dravis.samantha@epa.gov] From: Maciolek Natalie - Attorney Sent: Wed 4/19/2017 5:04:00 PM Subject: Request for Review & Meeting on EPA's Clay MACT Rule Letter to S. Dravis.pdf Dear Ms. Dravis, Attached is a letter requesting EPA's review of the Clay MACT Rule, as well as a request for a meeting. Regards, Natalie Natalie Maciolek Lead Attorney Office: (920) 459-1685 Mobile: (920) 917-8948 Email: Natalie.Maciolek@kohler.com 444 Highland Drive | Kohler | Wl | 53044 Experience Gracious Living Online at http://www.kohler.corn PRIVILEGED AND CONFIDENTIAL. The content of this message may be confidential. If you are not the intended recipient, please notify the sender. Any unauthorized use of this transmission is prohibited. 17cv1906 Sierra Club v. EPA 6/22 Production ED 001523 00008105-00001 Kohler Co., Kohler, Wisconsin 53044 Founded in 1873 920-457-4441 Fax 920-459-1583 natalie.maciolek@kohler.com April 19 2017 r ' KOHLER Natalie G. Maclolek Sr. Attorney Dear Ms. Dravis: Subject: Request for Review of and Meeting on EPA's Clay MACT Rule As you review Environmental Protection Agency regulations in response to President Trump's February 24th Executive Order 13777, "Enforcing the Regulatory Reform Agenda," and Administrator Pruitt's March 24th memorandum on implementing that order, Kohler Co. urges you to review the Clay Ceramics Manufacturing National Emission Standards for Hazardous Air Pollutants (NESHAP), 40CFR63, Subpart KKKKK, commonly referred to as "Clay MACT." This rule targets major sources as defined in the Clean Air Act. We believe Clay MACT meets the President's test of being unnecessary and burdensome, and therefore it is appropriate for repeal, replacement, or modification. Kohler Co. is the only company in the U.S. affected by the Clay MACT rule. Kohler's three U.S. sanitaryware manufacturing locations are subject to the rule not because they emit pollutants at major source levels, but rather solely because of Kohler's unique co location situation. Kohler's three sanitaryware facilities themselves are considered minor sources based on their emissions; however, because they are co-located with other, distinct operations that are major sources, the sanitaryware operations are being regulated as major sources. This status is inconsistent with their potential area source impact and puts Kohler at a significant competitive disadvantage. We believe this rule and its unique application to Kohler merit your attention and consideration. We respectfully request a meeting with you at your earliest convenience to discuss more fully Kohler's concerns about Clay MACT and why it deserves EPA's regulatory reform review. I look forward to hearing from you. Sincerely, Ms. Samantha Dravis Senior Counsel and Associate Administrator for Policy Dravis.samantha@epa.Kov NGM/jlr 17cv1906 Sierra Club v. EPA - 6/22 Production ED 001523 00008106-00001