Comment submitted by American Electric Power (AEP)

Summary: American Electric Power (AEP), a large electric utility, supports the proposed revisions to the Coal Combustion Residuals (CCR) Rule because they move toward a risk-based, site-specific regulatory approach. The company argues that the current "one-size-fits-all" requirements for CCR Management Units (CCRMUs) are unworkable and costly, and they advocate for further streamlining, including rescinding CCRMU requirements entirely or providing significant flexibility for beneficial use and closure methods.