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Comments to the Environmental Protection Agency on Proposed Extension of Coal Combustion Residuals Deadline

EPA has proposed to delay closure deadlines by three years for certain coal combustion residual surface impoundments. These impoundments risk leaking hazardous materials, such as mercury, lead, and arsenic, into the environment. In addition to keeping these impoundments open, EPA’s proposal would allow 11 coal plants to operate—and pollute—for three extra years.

We submitted comments urging EPA to withdraw the proposal and explaining (among other arguments):

  • EPA failed to consider the costs of increased air pollution. EPA claims the emissions from the 11 coal plants are unlikely to cause material harms because those plants account for only 5% of coal plants in the United States. But a small percent of a huge number is still a huge number. Each year that these 11 coal plants remain open causes billions of dollars in health and environmental harms.
  • EPA completely failed to analyze other important forgone benefits, such as the increased risk of leaks and structural integrity failure of these toxic storage facilities.