Comment submitted by Earthjustice et al. - Main comment

Summary: A coalition of environmental advocacy organizations opposes the proposed rule, arguing that it weakens protections for coal combustion residuals (CCR) and violates the Resource Conservation and Recovery Act (RCRA). They contend that the proposal improperly expands exemptions for "beneficial use," fails to provide minimum criteria for disposal, and ignores the significant risks to human health and the environment.