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Comments to EPA on Coal Combustion Residuals Rule

In 2015, the United States Environmental Protection Agency (EPA) established minimum criteria for the safe disposal of coal combustion residuals. At the time, EPA projected that the new rule would yield substantial health and environmental benefits. EPA now proposes to weaken the requirements of the 2015 rule but insists that doing so “will not change risks to human health and the environment” and thus will have no effect on the projected benefits of the 2015 rule.

Our comments explain why EPA cannot reasonably assume that its proposed changes will have no effect on the 2015 rule’s projected benefits. We also critique the agency’s proposal to expand an exemption from some of the 2015 rule’s requirements based on poorly substantiated concerns about electric reliability.