Comment submitted by Xcel Energy Services, Inc.

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Summary: Xcel Energy, a public utility holding company, supports the EPA's proposed rule to align coal combustion residuals (CCR) requirements with site-specific risks while maintaining environmental protectiveness. They advocate for a flexible, risk-based permit framework that accounts for site-specific conditions, existing state oversight, and the practical realities of managing legacy CCR units.
See attached file(s) for Xcel Energy's comments on the Legacy/CCRMU amendments proposal. Included are our comments as well as material previously submitted directly to the EPA, as well as supporting documentation.

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