Comment submitted by Jason Gordon

I am voicing my opposition to the proposed Federal CCR Permit Program, docket EPA-HQ-OLEM-2019-0361, as it stands. The permit program will shape decisions for most states, with only four having EPA-approved CCR programs. Its structure, deadlines, criteria, and data requirements will affect the rollback's impact on protections. The EPA's questions during this comment period bear directly on public health. I oppose reducing the first-tier permit application deadline from 18 months to six months. The proposed amendments require complex technical analyses to justify alternative groundwater monitoring, cleanup levels, and closure timelines. Accurate and complete applications need extensive data analysis and site-specific risk assessments, often taking a year or more. A six-month deadline results in incomplete applications, increasing permit authority discretion, usually benefiting operators over communities. The 18-month deadline should remain. I oppose tiering criteria based on state preferences. States opting out of CCR permit programs typically lack regulatory infrastructure and political will, compromising protection against coal ash contamination. Processing these sites first, under pressure and limited resources, doesn't protect at-risk communities. Tiering should be based on documented risks to health and environment: sites with groundwater contamination, near communities lacking alternative water supplies, or legacy sites lacking federal oversight should be prioritized. EPA's tiering should focus on contamination risk and community vulnerability over state decisions. I strongly advocate for mandatory use of the federal RCRAInfo database for all CCR permit authorities. The 2020 proposed rule included a CCR module in RCRAInfo for federal permits. Extending this to state permits is essential for public accountability and data consistency. Permit-driven compliance shifts crucial coal ash management decisions to the permit level. Without a centralized system, communities cannot know local protections or exemptions, and environmental organizations cannot track weakened enforcement patterns. A permitting system without public, centralized data fails as an accountability tool. EPA should require all CCR programs to enter data into the accessible federal database. Communities near coal ash sites have waited long for federal oversight. This permit program must honor that responsibility. Thank you.