From: 
David Ailor <dailor@accci.org>
Sent:
Wednesday, May 25, 2022 6:07 PM
To: 
French, Chuck <French.Chuck@epa.gov>
Cc:
Lassiter, Penny <Lassiter.Penny@epa.gov>; Jones, DonnaLee <Jones.Donnalee@epa.gov>
Subject: 
COETF FEEDBACK LETTER ON EPA'S COKE OVEN RTR PLANS


Chuck:

On May 16, EPA provided the coke industry with a draft plan setting forth a new approach to the rule development that EPA has been following for the past seven years for the Pushing, Quenching, and Battery Stack (PQBS) (Part 63 Subpart CCCCC) RTR and the technology review for Coke Batteries (Part 63 Subpart L).  On May 18, EPA held a virtual meeting with the Coke Oven Environmental Task Force (COETF), which ACCCI manages, and SunCoke Energy to discuss the draft plan.

During the meeting, you requested that we provide you our initial feedback on the draft plan, to the extent feedback is possible at this early stage and with the information provided in it.  Attached is a May 25 letter from me, acting on behalf of the COETF, setting forth the initial feedback of the COETF on the draft plan.

Thank you for the opportunity to provide this initial feedback.  We look forward to working collaboratively with EPA to develop a reasonable and scientifically defensible way forward including, critically, developing a realistic scope and deadlines for any Section 114 ICR and a schedule for completing proposed and final rulemaking packages that does not jeopardize meaningful industry stakeholder participation.

Please contact me if you have any questions.  David Ailor

David C. Ailor, P.E.
President
American Coke and Coal Chemicals Institute
25 Massachusetts Avenue, N.W.
Suite 800
Washington, D.C. 20001
Phone: 703-795-3541
eFax.: 866-422-7794
dailor@accci.org
www.accci.org



<< COETF Feedback Letter on EPA's Coke Oven RTR Plans 25 May 2022.pdf >>


