Document npZKV4LBR4pOXkXar2K9r0mdm

March 28, 2025 U.S. Environmental Protection Agency 1200 Pennsylvania Ave. NW Washington, DC 20460 RE: Presidential Exemption: New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Synthetic Organic Chemical Manufacturing Industry (SOCMI) and Group I & II Polymers and Resins Industry: SABIC Innovative Plastics Mt. Vernon, LLC To Whom It May Concern, SABIC Innovative Plastics Mt. Vernon, LLC ("SABIC") requests an exemption from the compliance obligations of the New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Synthetic Organic Chemical Manufacturing Industry (SOCMI) and Group I & II Polymers and Resins Industry (collectively referred to as the HON Rule).' For the reasons highlighted in this letter, we believe it is necessary and appropriate for the President to grant an exemption under Clean Air Act (CAA) Section 112(i)(4) for sources regulated by the final rule either on an individual basis or collectively. If done collectively, we request that EPA include SABIC's regulated facilities under that collective action. We urge the Administration to swiftly consider and issue such an action based on an understanding that both: 1) "availability" for the purposes of this section refers not only to the existence of technology capable of achieving compliance with the rule, but encompasses practical challenges with the timeframes necessary to plan, procure, and install required technologies and such activity cannot occur within the current compliance timeframe; and 2) national security encompasses not only military defense applications and infrastructure, but also economic security, a perspective that has been acknowledged by the President in Executive Orders and key security agencies like the Department of Defense. Indeed, as the White House has stated regarding domestic priorities, 'economic security is national security."2 As additional support on this point. we reference the separate joint coalition submission sent to EPA from 1 National Emissions Standards for Hazardous Air Pollutants (NESHAP), Powering the Great American Comeback https://www epa.goWsystem/files/documents/2025-03/neshap_powering-the-great-americancomeback_fact-sheet_2.pdf 89 Fed. Reg. 42932 (May 16, 2024). 2 https://www whitehouse.gov/presidential-actions/2025/02Iamerica-first-investment-policy/. SABIC Innovative Plastics Mt. Vernon, LLC One L&an Lane Mount Vernon, IN 47620 USA T: .1 812 833 8891 F. +1812 8314856 E: MTV Environmental@sabic.carn www.sabic.corn Sierra Club FOIA 2025-EPA-04883 ED_018388_00000243-00001 SC_EVERSPLIT0006010