From: 
D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com>
Sent:
Tuesday, November 24, 2020 10:46 AM
To: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc:
Stuart, Eric <stuart@steelnet.org>; Balserak, Paul <pbalserak@steel.org>; Green, Joseph J. <JGreen@KelleyDrye.com>
Subject: 
Steel Industry's Proposed Redlines to Subpart AAa NSPS for EAF and AOD


Dear Dr. Jones,    I hope you are doing well.  On behalf of the Steel Manufacturers Association (SMA), American Iron & Steel Institute (AISI), and Specialty Steel Industry of North America (SSINA), I am attaching the steel industry's proposed redline edits to the Subpart AAa NSPS for Electric Arc Furnaces (EAFs) and Argon-Oxygen Decarburization vessels (AOD).   We recognize that it has taken us a long time to get these to you, but the time was not wasted; We were able to compile and coordinate feedback and recommendations from all three steel associations and each of their participating member companies.  And as a result of that collaborative process, I believe we were able to develop recommendations that can help EPA clarify and improve the structure of the NSPS.  
 
We appreciate you allowing us to provide these proposed edits and recommendations, and we look forward to discussing them with you at your convenience.  To that end, I plan to reach out to you again in early December to schedule a follow-up discussion with representatives of the three steel associations (copied here).   In the meantime, please let me know if you have any questions or issues you would like to discuss.  Until then, I hope you and yours have a very happy Thanksgiving.
 
Best wishes,
Wayne
 
WAYNE D'ANGELO
Partner
Kelley Drye & Warren LLP
Washington Harbour
3050 K Street NW, Suite 400
Washington, DC 20007
Tel: (202) 342-8525
Cell: (202) 329-3977

WWW.KELLEYDRYE.COM

wdangelo@kelleydrye.com



<< NSPS-Word-Subpart-AAa-steel industry final redlines v1.docx >>


