Comment submitted by Shari D. (no surname provided)

I am writing to express my opposition to the proposed Federal CCR Permit Program, docket EPA-HQ-OLEM-2019-0361, in its current form. This program will determine how decisions are made for most states nationwide. Only four states have their own EPA-approved CCR programs. The federal program's design, deadlines, criteria, and data requirements will impact how much leeway given in the April rollback weakens actual protections. The EPA's questions during this comment period directly affect public health. The EPA is considering reducing the deadline for first-tier permit applications from 18 months to six months after the rule's effective date. I oppose this reduction. The proposed April 2026 amendments mean facilities must submit detailed technical analyses for alternative requirements in groundwater monitoring, cleanup, and closure timelines. Creating thorough applications demands extensive data analysis and site-specific risk assessments, often taking over a year. A six-month timeframe will lead to incomplete applications, increasing permit authority discretion, which historically favors operators over communities. The EPA should maintain the 18-month deadline at a minimum. The EPA also asks which facilities should apply first and suggests prioritizing CCR units in states not pursuing their permit program approval. I oppose prioritizing based on state preferences. States opting out often have minimal regulatory infrastructure and lack political will to protect against coal ash contamination. Prioritizing these sites under time constraints and reduced staffing does not safeguard at-risk communities but speeds up processing under unfavorable conditions for review. Criteria should focus on documented risks to health and the environment, prioritizing sites with confirmed groundwater contamination, those near communities without alternative drinking water, and legacy sites without federal oversight. Tiering decisions should be based on contamination risk and community vulnerability, not state administration. The EPA is considering whether states with their CCR programs should enter permit data into the EPA's RCRAInfo database or maintain separate systems. I strongly support mandatory participation in the federal database for all CCR permit authorities, urging the EPA to mandate it. The 2020 proposal for a CCR module in RCRAInfo for federal permits should extend to state permits for public accountability and data consistency. Key coal ash management decisions occur at the permit level, not through national standards. Without a centralized, public system, communities can't access crucial information, and environmental groups can't track enforcement weaknesses across states. A permitting system without public data access cannot be accountable. The EPA should require all state CCR programs to input data into the accessible federal database. Communities near coal ash sites have long awaited effective federal oversight. This program's design must reflect that responsibility. Thank you.