Comment submitted by American Public Power Association (APPA)
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Summary: The American Public Power Association (APPA), representing community-owned utilities, supports the EPA's proposal to move toward a more practical, risk-based framework for coal combustion residual (CCR) regulations. They advocate for specific refinements, including reaffirming the limits of Subtitle D authority, broadening exemption pathways for legacy impoundments, and rescinding or narrowing CCRMU requirements to reduce unnecessary regulatory burdens.
Comments of the American Public Power Association on the Hazardous and Solid Waste Management Systems: Disposal of Coal Combustion Residuals from Electric Utilities: Legacy /CCRMU Amendments.