External Meeting Request Form for
Administrator E. Scott Pruitt
U.S. Environmental Protection Agency
To request the Administrator to attend and/or speak at your event, please complete and submit the following
form.
Today's Date: May 4, 2017
Meeting Date: May 15, 2017
Meeting Time: 2:15p.m.
Requested Location (if offsite, please list address, parking instructions, etc.): Administrator Pruitt's DC
office
Requestor: The Chemours Company
Purpose of the Meeting:
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Introduce Chemours to the Administrator
Express Chemours' support for the Administrator's leadership of EPA.
Share what Chemours is doing to put American innovation to work to create global, market-leading
product opportunities, which support new U.S. manufacturing investments and jobs.
Share Chemours' desire to see EPA maintain consistency vis-a-vis HFCs in order to help protect U.S.
leadership in this space and protect significant new U.S. investments the company has made in reliance
on previous EPA policy decisions.
Share Chemours' desire to see EPA implement the Lautenberg Chemical Safety Act in a fair, efficient,
and reasonable manner, consistent with the new law and Congressional intent.

Background on the Meeting:
The Chemours Company commenced business as a stand-alone, publicly-traded corporation on July 1, 2015,
after being separated from DuPont via a spin-off to DuPont shareholders. At its inception, Chemours was
comprised of the former DuPont Chemical Solutions, Fluoroproducts and Titanium Technologies businesses.
Chemours corporate headquarters and global innovation center are both located in Wilmington, DE. The
company has approximately 7,000 employees globally, with more than 5,000 of those workers based in the
United States. 25 of the company's 35 production facilities are located in the United States.

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Refrigerants
The Chemours Fluoroproducts business has a nearly 90-year history of innovation creating products that
have provided critical societal services such as refrigeration, air conditioning, insulation, fire suppression,
personal care products and medical applications while constantly improving the safety of these
applications. That pioneering innovation continues today with a new generation of products that provide
enhanced environmental sustainability and superior performance across a variety of applications while as
"drop-ins" or near drop-in substitutes for existing or slightly modified equipment. These new alternatives
were designed to meet market demand and the requirements of a growing number of international

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 regulations like Japan's high global warming potential (GWP) hydrofluorocarbon (HFC) reduction regulations, the
European Union's Fluorinated Gas Regulations, and existing domestic regulations.

New refrigerants represent a multi-billion dollar industry in which the United States has a clear advantage
in the international marketplace. For example, all auto manufacturers in North America and the European
Union have announced plans to convert their light-duty vehicle air conditioning systems to low-GWP
refrigerants.
Chemours has responded to this demand by investing hundreds of millions of dollars in the development
of new refrigerants such as hydrofluoroolefins (HFOs). These refrigerants provide automobile
manufacturers with a low-cost alternative to meeting light-duty vehicle standards that are already being
implemented in the United States. Importantly, Chemours has also made parallel investments that will
create additional American manufacturing and commercial jobs. For example, in May 2016, the company
announced that it will invest approximately $250 million to construct a new HFO production facility at the
Chemours Corpus Christi site in Ingleside, TX.
American Innovation and Investment
Chemours has invested (and continues to invest) hundreds of millions of dollars in the development and
commercialization of zero ozone depletion potential (ODP) and very low GWP alternatives. This includes
significant investment in new technology and significant production capacity in the United States, which
has resulted in the creation of hundreds of jobs for Chemours, Chemours suppliers and the communities
that support our new product portfolio development and production.
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This commitment includes a world-class R&D center in Wilmington DE, for product and process
development and significant manufacturing footprints in Corpus Christi, TX (new capacity) and
Houston, TX, Louisville, KY; and Deepwater, NJ (existing product capacity).
Chemours provides communities with high-paying jobs and associated top-shelf benefits.
Chemours Fluorochemicals business employs more than 2,000 in the United States, with 125
employees currently assigned full-time to the development, production and commercialization of
these new products. 50 out of 65 new permanent jobs at the Corpus Christi plant have been filled
to operate the new facility, and approximately 300 additional positions will be added by suppliers
and at businesses in the surrounding community to support this effort.
In addition, Chemours currently employs 300 American contractors to build the new facility in
Corpus Christi, Texas using American construction materials.
Chemours and other American companies hold a significant patent portfolio globally for next
generation replacement products. This is the outcome of hundreds of millions of dollars of
investment and more than a decade of development.
Many non-U.S. competitors chose not to make those investments because of the significant cost
and the risk that the investment would never pay off.
Now that these alternatives are in demand, global competitors are actively seeking to
commercialize these products, potentially infringing on intellectual property of others, to enter this
attractive market.

Continued American Leadership is Needed
Without leadership from the United States to compete vigorously to succeed in this segment, global
competitors can quickly move into position to lead the HFC replacement industry.
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For example, the Chinese may want to leverage their natural resources/supply (fluorspar) and
have already started producing HFOs domestically. They are also developing core manufacturing

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 capabilities that they can leverage in the future. This strategy could increase challenges to U.S. company
intellectual property rights abroad and encourage the exercise of domestic protectionism. It could also
result in counterfeit products being shipped into the United States and other regulated markets.

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In fact, there have been two affirmative rulings in HFC anti-dumping cases recently,
outlining unfair dumping by Chinese companies of HFCs into the United States. This behavior has
caused significant injury to the U.S. industry forcing American companies to either exit business or
participate at or below the cost of manufacture.
In addition, in less developed countries, like China, companies have announced plans to
commercialize alternative refrigerants. Without U.S. leadership and support for domestic
technologies, these foreign-based alternatives to U.S. technologies could gain support, displacing
our "first mover" advantage in international markets.
At the same time, some environmental NGOs oppose some of the technically proven options
developed by American companies. U.S. regulations are technically neutral and allow for the use
and further development of fluorochemicals and so-called "natural" refrigerant solutions by
American companies. Organizations like Greenpeace and Europe-based Shecco promote the use
of carbon dioxide, hydrocarbons, ammonia, water and air as the only viable solutions for many
applications, including refrigerants. While these options may indeed be preferred for some uses
and equipment types, in many cases they are significantly more expensive for equipment
manufacturers to implement than HFO solutions, and, in some cases, have poor energy
performance, higher operating costs, and severe safety risks Therefore, continued U.S. leadership
and engagement is needed to ensure a level playing field and fair consideration of all options.

Policy Recommendations:

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Continuity of the current regulatory structure managing fluorochemicals is critical as American
companies continue to invest hundreds of millions and even billions of dollars in new technologies
that will be used in the United States and around the world as other countries continue to regulate
this space.

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Continued EPA Funding is also needed for the Office of Air and Radiation for the approval of
volatile organic compound (VOC) exemptions for fluorochemicals and for the Stratospheric Ozone
Division Significant New Alternatives Policy (SNAP) Program to approve new products and provide
continued support to industry to ensure that new technologies can successfully enter the market.
Other countries rely on EPA SNAP program approvals to allow the use of American patented
products.

TSCA Implementation
Chemours was one of a number of chemical companies that strongly advocated for modernizing and
improving the Toxic Substances Control Act via the Lautenberg Chemical Safety Act, the bi-partisan
legislation that was signed into law in 2016. Implementation of the law is an EPA priority, and Chemours
is fully committed to working with EPA to achieve that goal.
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Chemours believes that fair and balanced implementation of the LCSA should:
o Fully address the significant scientific principles and standards embedded in the statute;
o Adopt workable, pragmatic processes in regulatory implementation- particularly to look to
simple processes where those achieve Congressional intent;
o Build public and industry confidence in EPA's ability to evaluate the safety of the products
of chemistry efficiently and effectively through TSCA, especially for the new chemicals
program;

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Encourage technological innovation and globally competitive chemical industry through the
strong protection of confidential business information.
Chemours' most significant concern, to date, is with EPA's implementation of the modest changes
to Section 5- the new chemicals program.
Chemours believes that Section 5 was working well before the LCSA was enacted. LCSA's new
chemicals provisions require EPA to "show its work" and demonstrate it has sufficient information
to make a decision on a new chemical. It also codified EPA's practice of considering potential
exposures to new chemicals. LCSA did not change the legal standard for review.
Since enactment, the New Chemicals Program has experienced significant backlogs that
jeopardize innovation and the competitive position of U.S. chemical companies. More than 500
new chemical applications are still pending, including many submitted before LCSA was enacted.
The rate of new chemical approvals is down significantly from prior practice.
Chemours believes the New Chemicals Program must reach a point where the vast majority
(90%+) of pre-manufacture notices are addressed within the statutory review period (90 days, with
a possible extension of 90 days).
Chemours has been pleased to see EPA, under the leadership of the new Administrator, begin to
take steps to remedy the implementation problems in Section 5.

Role of the Administrator:

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Strong leadership of EPA to deliver on its core mission of protecting human health and the environment
and, at the same time, promote U.S. investment and job creation via responsible environmental policies
and regulations.
Policy consistency on HFCs to promote and protect U.S. leadership, investments and job creation.
Prompt and fair implementation of the LCSA.

Attendees:

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Mark Vergnano, Chief Executive Officer, Chemours;
Greg Smith, Director- Government Affairs, Chemours;
Eddie Johnston, Manager- Federal Government Affairs, Chemours; and
Rich Gold, Partner, Holland & Knight.

Point of Contact:

Greg Smith, Director- Government Affairs
The Chemours Company
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