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Public Comments on the Economics of Coal Ash Disposal

In many places around the nation the toxic sludge leftovers of the coal combustion process are stored in vast unlined pools where poisons can leak into groundwater. Sometimes, like in Kingston, Tennessee, these holding pens break letting loose an avalanche of black poisonous muck.

Surprisingly, this substance goes completely unregulated by the federal government. But in June, EPA proposed rules to control its use in certain ways. And today, Policy Integrity submitted public comments on those rules.

There are two alternatives being debated in the proposal. The first would classify coal ash as a “special waste” as opposed to a “hazardous waste,” subjecting it to many of the same standards as other wastes but allowing certain beneficial recycled uses. These ways of recycling the material accrues significant greenhouse gas savings as well as cost savings.

The second alternative would only issue minimum national standards for their disposal—leaving crucial public health, safety and environmental decisions up to the states.

We have determined that, overall, the first option is the more economically justified policy. An improved regulatory analysis—including a fuller accounting of health and environmental benefits, and a more fine-grained environmental justice analysis—should further strengthen the case for that policy choice.

EPA should select the regulatory proposal that delivers the most benefits—in other words, the regulations that will protect public health and the environment while simultaneously promoting economic gains by recycling the waste. The first regulatory alternative will achieve these twin goals.