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ATTACHMENT B Sierra Club FOIA 2025-EPA-04883 ED_018388_00000165-00024 SC_EVERSPLIT0012573 united tatcs ,$cnatc WASHINGTON, DC 2.0510 June 14,2024 The Honorable 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 three U.S. Environmental Protection Agency (EPA) rules that together threaten the economic competitiveness of the American integrated steel industry. We urge EPA to grant the petitions filed by the domestic integrated steel industry seeking administrative reconsiderations and stays of all three final rules until the EPA can complete a comprehensive review of each rule through the administrative reconsideration process. Working together, EPA and industry have achieved notable reductions in environmental impacts to air, water, and land over the past 50 years. The steel industry in the U.S. is the world's cleanest major producer of steel and is already subject to more environmental regulation than its global competitors, resulting in a cleaner environment. While we appreciate EPA's efforts to address concerns raised by multiple stakeholders-- including steel companies, the United Steelworkers (USW), coke producers, and numerous Members of Congress throughout the rulemaking process, we remain concerned that the final rules contain flaws that will undermine the domestic steel industry and national security while driving production overseas. We are specifically concerned about the following three rules: National Emission Standards fin- Haiardous Air Pollutants: Taconite Iron Ore Processing (EPA-HQ-OAR-2017-0664) National Emission Standards for iIazardous Air Pollutants: Integrated Iron and Steel Manufacturing Facilities (EPA-HQ-OAR-2002-0083) 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-- I IQ-OAR-2003-0051). A failure to get these regulations right will not only have a negative impact on domestic steel production and American steelworkers, but it will also likely fail to achieve a net reduction in emissions from the steel industry globally. In fact, emissions will likely rise as production moves to countries, like China, with far less stringent rules and regulations. By granting the requested administrative reconsideration and stay of the rules, the EPA and industry can build on their shared track record of success and continue to work together in a constructive manner to achieve durable rules that both protect the environment and our domestic integrated steel industry. Sierra Club FOIA 2025-EPA-04883 ED_018388_00000165-00025 SC_EVERSPLIT0012574 Throughout the rulemaking process, EPA worked to address technical and analytical flaws with these rules raised by multiple stakeholders, The modifications incorporated into the final rules in response to stakeholder feedback were important steps in the right direction, but we remain concerned they did not go far enough in addressing fundamental flaws with the rules. Further modifications are needed to address new information provided to EPA by stakeholders to ensure the rules are achievable by the industry, as required by the Clean Air Act, and that the regulations do not induce unintended consequences, such as loss of domestic steelmaking capacity and jobs. Given all that is at stake in terms of our country's advanced steel manufacturing capabilities and the good-paying, middle class union jobs the steel industry sustains, it is critically important that these rules are technically and economically feasible and do not undermine the competitiveness of the industry. A stay of these rules will allow l'PA to continue to work with industry stakeholders, including domestic companies and the (JSW, to obtain a complete and thorough understanding of the new information, equipment, and processes and ensure regulations moving forward are sound policy. Absent a stay, the steel industry will be forced to proceed with planning and spending for unproven technologies and work practices while the final provisions of the rules remain uncertain. Given that these regulations will impact nearly every aspect of the integrated iron and steelmaking process, it is imperative that 1.PA grant both the petitions for reconsideration and requests for stay of the rules. We urge ll)A to grant the industry's petitions for reconsideration and stay requests to ensure that these regulations both safeguard our environment and preserve production capacity and jobs in our strategically important integrated iron and steel sector. Thank you for your work to date with us on these important matters. Sincerely, Sherrod Brown United States Senator Mike Braun United States Senator Robert I'. Casey, Jr. United States Senator ). Vance United States Senator Amy Klobachar United States Senator Todd Young United States Senator cc: Janet McCabe, Deputy Administrator, U.S. Environmental Protection Agency Sierra Club FOIA 2025-EPA-04883 ED_018388_00000165-00026 SC_EVERSPLIT0012575