Comment submitted by Terry Ann Towers Saint Amand

I am writing regarding EPA's proposed approval of Louisiana's Coal Combustion Residuals (CCR) permit program. Coal ash contains contaminants including arsenic, lead, mercury, selenium, chromium, and other pollutants that can pose significant risks to groundwater, surface waters, wetlands, wildlife, and nearby communities when not properly managed. Any state permit program approved by EPA should provide protections that are at least as strong as the federal CCR requirements and should not weaken public oversight, enforcement, or environmental safeguards. Louisiana faces unique environmental challenges that warrant particular caution. The state experiences frequent flooding, severe storms, hurricanes, coastal land loss, subsidence, and changing hydrologic conditions. These factors increase the potential risks associated with long-term coal ash storage and make strong monitoring, maintenance, and enforcement especially important. I encourage EPA to ensure that any approved state program includes robust groundwater monitoring requirements, timely public reporting of monitoring results, independent inspection authority, meaningful enforcement mechanisms, and clear requirements for corrective action when contamination is detected. Communities should have easy access to information regarding facility performance, monitoring data, violations, and remediation efforts. Financial assurance requirements should also be strong enough to ensure that cleanup, closure, post-closure care, and corrective actions can be completed without shifting costs to taxpayers if operators fail to meet their obligations. Long-term stewardship should be considered from the outset rather than after contamination problems emerge. EPA should also carefully evaluate whether existing and future facilities are adequately designed to withstand increasingly severe weather events. Climate resilience should be incorporated into permitting, inspection, closure, and post-closure requirements. Facilities located in flood-prone areas or areas vulnerable to storm impacts should receive heightened scrutiny. Protection of wetlands, rivers, streams, groundwater resources, and nearby communities should remain the central objective of any approved CCR program. The public should be able to trust that state administration of the program will maintain or strengthen environmental protections rather than reduce them. Thank you for considering these comments and for ensuring that coal ash management programs provide strong, transparent, and enforceable protections for public health and the environment. TerryAnn Towers Saint Amand