I am writing to oppose the revisions to the definitions of “coal pile” and “beneficial use.” These revisions to EPA’s “Hazardous and Solid Waste Management System; Disposal of Coal Combustion Residuals from Electric Utilities,” rule, or the “CCR” rule would increase the risk of contamination and health impacts from coal ash.

There is no doubt—coal ash is extremely toxic and needs to be carefully transported, stored, and disposed of or recycled to prevent the release of dangerous heavy metals and other pollutants. As more and more coal ash sites are being rightfully excavated in response to groundwater and surface water contamination, it is imperative that EPA impose federal standards that prevent this toxic burden from being hoisted on even more communities. EPA’s coal ash disposal standards should ensure that the short-term storage and final disposal of coal ash are always done in a way that ensures no further contamination. Instead, these revisions will make it more likely that companies will cut corners and release toxic pollutants.

It is particularly concerning to me that large amounts of coal ash fill can be used in construction projects without any notice to nearby communities. Using coal ash as fill is linked with groundwater contamination, and is not a responsible method of disposal. Furthermore, if EPA allows the use of coal ash as fill, the rule should require companies to complete the environmental demonstrations no matter where the fill is used and to publicly post these demonstrations.

I remind you that EPA’s mission is “to protect human health and the environment.” Please protect communities from the dangers of irresponsibly managed coal ash by not weakening standards for coal ash piles and the use of coal ash fill.