Comment submitted by Estelle Bille

I am writing to oppose the proposed Federal CCR Permit Program, docket EPA-HQ-OLEM-2019-0361, as it currently stands. This program will guide permit decisions in most states, with only four states having EPA-approved CCR programs. The structure of this federal program—its timelines, tiering system, and data requirements—will impact how the April rollback might weaken protections. The EPA's inquiries during this comment period are crucial for public health. The EPA is considering reducing the first-tier permit application deadline from 18 months to six months after the rule's effective date. I oppose this reduction. The proposed amendments for April 2026 require facilities to present detailed, site-specific analyses for alternate groundwater monitoring, cleanup, and closure standards. Accurate applications need months of data analysis and often take over a year to prepare. A six-month deadline will result in incomplete applications, increasing permit authority discretion, favoring operators over communities. The EPA should maintain the 18-month deadline. The EPA also asks which facilities to prioritize for permit applications, suggesting CCR units in states not pursuing their permit program approval. I oppose prioritizing based on state administrative choices. States that forgo their own CCR programs often lack regulatory infrastructure and political will to protect residents from coal ash contamination. Processing these sites first, quickly and with limited resources, doesn't protect the most at-risk communities. Tiering should be based on risk to human health and the environment: sites with confirmed groundwater contamination, sites near communities without alternative drinking water, and legacy sites without federal oversight should be prioritized. The EPA should base tiering on contamination risk and community vulnerability instead of administrative decisions. The EPA is also asking whether states with their CCR programs must input permit data into the EPA's RCRAInfo database or maintain separate systems. I strongly support mandatory federal database participation for all CCR authorities and urge the EPA to require this. The 2020 rule proposed a CCR module in RCRAInfo for federal permits, and extending this to state-issued permits is vital for public accountability and data consistency. Permit-driven compliance means key coal ash management decisions occur at the permit level, not through national standards. Without centralized, public data access, communities can't track site protections or exemptions, and environmental groups can't monitor enforcement across states. A permitting system needs centralized public data for accountability. The EPA should mandate all state CCR programs to input data in the federal database, accessible to the public. Communities near coal ash sites have awaited federal oversight for decades. This permit program's design should honor that need. Thank you.