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united 5tatcs senate WASHINGTON, DC 20510 December 6, 2023 The I lonorable Michael S. Regan Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington, D.C. 20460 Dear Administrator Regan: We write to you today regarding the U.S. Environmental Protection Agency's (EPA) three proposed rules related to steel manufacturing and related supply chains. We have serious concerns with these proposed rules because they would dramatically undermine the domestic steel industry and national security while driving production overseas likely resulting in no net reduction in emissions from the steel industry globally. Reducing the emission of harmful air pollutants should be done based upon sound science and with proven technology that is both technically and economically feasible. The irony is that the United States' steel industry is world's cleanest major producer of steel'. American steel manufacturers take seriously their commitment to protecting the environment; however, rules that drive production overseas are bad for our economy, bad for national security, and bad for the environment. These rules: 1) National Emission Standards for Hazardous Air Pollutants: Integrated Iron and Steel Manufacturing Facilities (EPA-HQ-EPA-OAR-2002-0083), 2) National Emission Standards for Hazardous Air Pollutants for Coke Ovens: Pushing. Quenching, and Battery Stacks, and Coke Oven Batteries. (EPA HQ OAR 2002 0085 and EPA HQ OAR 2003 0051), and 3) National Emission Standards for Hazardous Air Pollutants: Taconite Iron Ore Processing Amendments (EPA-HQ-OAR-2017-0664), if finalized as proposed, would require billions of dollars in capital investments and increased annual operating costs for the U.S. steel industry. We support reducing harmful air pollution. We also support rules that are durable, realistic, and based upon proven technology and reflect a consensus view among stakeholders on how to best improve public health while protecting good paying jobs and supporting industries essential to our national and economic security. These rules fail to meet those standards. As you move forward with these rulemakini2s, we urge you to take an inclusive approach -- working directly with major stakeholders in developing technically-sound final rules that achieve further emissions reductions while not harming the competitiveness of our American steel companies. Written properly, regulations can help American steel manufacturers lead the world in clean steel production. Poorly written rules undermine domestic manufacturing and promote reliance upon inputs made by foreign manufacturers manufacturers that pollute more than their American counterparts. Regulations that cost [ "Steel Climate Impact - An International Bench/I-larking of Energy and CO, Intensities." Found at: https:"'WWW.bluegreenalliance.orgiup-content'uploads/2022 '04 'Steelclimateimpacthenehmarkingreport7Apri12022.pdf Sierra Club FOIA 2025-EPA-04883 ED_018388_00000151-00016 SC_EVERSPLIT0005896