Document zQkv5jJvjJEMLj9MMzDygOrZR

Message From: Sent: To: Subject: Attachments: Tisa, Nathaniel [Tisa.Nathaniel@epa.gov] 3/19/2025 2:51:20 PM Szabo, Aaron [Szabo.Aaron@epa.gov]; Donahue, Sean [donahue.sean@epa.gov] RE: Legal Analysis of CAA 112(i)(4) - Presidential Exemption NESHAP Presidential Exemption DRAFT 03.19.2025.docx Aaron, Attaching a high-level write-up here. Feel free to call with questions. Nathaniel Tisa Deputy General Counsel U.S. Environmental Protection Agency (202) 658-5262 From: Szabo, Aaron <Szabo.Aaron@epa.gov> Sent: Wednesday, March 19, 2025 9:35 AM To: Tisa, Nathaniel <Tisa.Nathaniel@epa.gov>; Donahue, Sean <donahue.sean@epa.gov> Subject: Re: Legal Analysis of CAA 112(i)(4) - Presidential Exemption 11:15am. Thanks, Aaron Szabo 202-564-7043 From: Tisa, Nathaniel <Tisa.Nathaniel@epa.gov> Sent: Wednesday, March 19, 2025 9:34:01 AM To: Szabo, Aaron < ho.Aaron@epa., >; Donahue, Sean <Annahue.sean@epa.gov> Subject: Re: Legal Analysis of CAA 112(i)(4) - Presidential Exemption What time is the meeting? Will make sure you have at least initial answers to these questions. From: Szabo, Aaron <Szabo.Aaron@epa.gn-> Sent: Wednesday, March 19, 2025 7:35:50 AM To: Donahue, Sean < ihu an@e >; Tisa, Nathaniel <- isa.Nathaniel@epa.gov> Subject: RE: Legal Analysis of CAA 112(i)(4) - Presidential Exemption Hey all -- just wanted to follow up on this. I know there is a meeting today on this issue and was wondering if OGC had a memo I can read before we have the meeting today. Thanks, Aaron Szabo Senior Advisor to the Administrator 202-564-7043 (office) 202-855-3241 (mobile) Sierra Club FOIA 2025-EPA-04883 ED_018865_00000561-00001 SC_EVERSPLIT0008039 From: Szabo, Aaron Sent: Tuesday, March 11, 2025 11:54 AM To: Donahue, Sean < nahue.seanE >; Tisa, Nathaniel <-9sa.Nathaniel@epa.gov> Subject: RE: Legal Analysis of CAA 112(i)(4) - Presidential Exemption Would the end of the week be possible? I think that after the announcement tomorrow we will be getting a lot of incoming and would like to make sure we can provide the correct information. Thanks, Aaron Szabo Senior Advisor to the Administrator 202-564-7043 (office) 202-855-3241 (mobile) From: Donahue, Sean < Sent: Tuesday, March 11, 2025 11:53 AM To: Szabo, Aaron < lbo.Aaron@epa >; Tisa, Nathaniel <'.sa.Nathaniel@epa.gov> Subject: Re: Legal Analysis of CAA 112(i)(4) - Presidential Exemption Aaron, OGC will look into it. When would you like a response? Sean Get Outlook for iOS From: Szabo, Aaron <Szabo.Aaron@epa.gov> Sent: Tuesday, March 11, 2025 11:23:28 AM To: Tisa, Nathaniel < isa.Nathaniel@epa.gov> Cc: Donahue, Sean <*lonz"ie.sei- i.gov> Subject: Legal Analysis of CAA 112(i)(4) - Presidential Exemption Hey Nate, I was wonderin_gif it would be ppssible for OGC to p_rovide an analysis oft ___ _ _ _ _ _ _ _ ,,Ex. 5 AC/DP Ex. 5 AC/DP X I was wondering_(11. Ex. 5 AC/DP Happy to discuss this in more detail if you would like. Sierra Club FOIA 2025-EPA-04883 ED_018865_00000561-00002 SC_EVERSPLIT0008040 (4)Presidential exemption The President may exempt any stationary source from compliance with any standard or limitation under this section for a period of not more than 2 years if the President determines that the technology to implement such standard is not available and that it is in the national security interests of the United States to do so. An exemption under this paragraph may be extended for 1 or more additional periods, each period not to exceed 2 years. The President shall report to Congress with respect to each exemption (or extension thereof) made under this paragraph. Thanks, Aaron Szabo Senior Advisor to the Administrator 202-564-7043 (office) 202-855-3241 (mobile) Sierra Club FOIA 2025-EPA-04883 ED_018865_00000561-00003 SC_EVERSPLIT0008041