Anonymous public comment

To the Administrator: These comments are submitted by a company developing and operating technology to beneficially use and recover resources from coal combustion residuals (CCR). We support the Agency’s goal of expanding the legitimate beneficial use of CCR and reducing reliance on disposal. We write to recommend three targeted changes that would keep the proposed amendments aligned with that goal while preventing them from becoming pathways to unmonitored disposal. Citations below are to the proposed rule as published at 91 FR 18968 (April 13, 2026). Summary of recommendations. (1) Condition the categorical exclusion for FGD gypsum used in agriculture on a minimum purity standard. (2) Do not treat on-site placement as a categorical beneficial use exempt from oversight; require it to meet established engineering and environmental standards. (3) Retain a framework for managing legacy CCR rather than rescinding the CCR management unit (CCRMU) requirements wholesale. We support the Agency’s effort to expand legitimate beneficial use of CCR. The three changes above would ensure that the final rule promotes genuine beneficial use and resource recovery without creating new, unmonitored disposal pathways for off-spec or legacy material. We appreciate the opportunity to comment and would welcome the chance to provide additional data. Respectfully submitted,