From: 
D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com>
Sent:
Friday, December 16, 2022 12:42 PM
To: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc:
Green, Joseph J. <JGreen@KelleyDrye.com>; Balserak, Paul <pbalserak@steel.org>; Stuart, Eric <stuart@steelnet.org>
Subject: 
Supplemental Comments on Costs Associated with Proposed Subpart AA/AAa revisions


Good afternoon Dr. Jones.  Thank you again for meeting with the Steel Associations last month.  Per EPA's request during that conference, the Steel Associations drafted the attached supplemental comments explaining the costs associated with some of the Agency's proposed new monitoring and compliance requirements for existing Subparts AA and AAa.   We hope that these supplemental comments provide EPA the information it needs to timely confirm that the Agency must rescind its costly and impermissible proposed revisions to the existing subparts.  
 
As the Steel Associations' representatives apprised EPA during our November 10[th] conference and reiterate in the attached comments, the EAF steel industry will not be able to comply with the proposed Subpart AA/AAa revisions if they are enacted as proposed.  Given the looming threat of widespread noncompliance just a few months from now, the Steel Association implore EPA to provide us confirmation as soon as possible that the Agency will not finalize any of the new compliance obligations it proposed for Subparts AA and AAa.  If you or your colleagues require any additional information in order to timely provide this confirmation, please let us know.
 
Thank you again for engaging with the Steel Associations on this very important and deeply concerning compliance issue.  I will be traveling until December 28[th] with limited access to email so please send any follow up communications and questions to both Joe Green and me.
 
I hope you and yours have a happy and healthy holiday season.
 
Best,
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

wdangelo@kelleydrye.com



<< Supplemental NSPS Comments on Subpart AA and AAa Costs.pdf >>
