Comment submitted by Reid Stevens

On June 6th, 2025, the Commonwealth of Virginia’s Department of Environmental Quality (VADEQ) requested approval of a partial Coal Combustion Residuals (CCR) permit program, overriding 40 CFR part 257, subpart D, the federal standard for the disposal of CCR in landfills and other surface impoundments. Coal ash, as it is often referred to, can have detrimental effects on human health, with symptoms ranging from irritation of the skin and respiratory system to several types of cancer (Liberty Mutual Business Insurance). It also causes biological damage when introduced into ecosystems, notably aquatic habitats, through metal concentrations entering waterways (ibid). As the Trump Administration has shown an interest in maintaining coal as an energy source, environmental and economic concerns must be taken into consideration. In this particular proposed rule, I support the CCR partial permit program. The Commonwealth of Virginia has made additional steps to mitigate the harmful effects of coal ash on its ecosystem through its state code § 10.1‑1402.05, which orders any facilities with CCR in the Chesapeake Bay Watershed to be excavated, and any disposal of CCR must be done after obtaining a solid waste permit in the Commonwealth of Virginia, as the docket states. These regulations will reinforce the structures of accountability within the Commonwealth for CCR disposal and protect critical habitats. As a result, these habitats and the areas provide benefits to all residents, visitors, and those who benefit from its commerce. For that reason, this program ought to be considered a public good in future analyses. The status of the partial permit program as a public good also provides insight into the debate on the intensity of coal in the energy portfolio of Virginia and the United States. It is important to note that the closure of some facilities that handle CCR waste could lead to intense effects of CCR in permitted facilities, affecting the surrounding communities. Analysis of the use and strategic disposal of coal and its waste must consider the additional cost to communities of increased healthcare spending and lost productivity due to adverse health effects caused by high levels of CCR. Additionally, the benefits of cleaning waste facilities of CCR in the Chesapeake Bay Watershed provide unrealized economic benefits through tourism and fishing industries, as well as abatement of the previous demerits. By the inclusion of positive and negative indirect benefits of this proposed rule, the ideal amount of energy from coal can be estimated. To conclude, I support this rule and recommend that it be further used to balance the demand for energy, industry, and environmental protection in the Commonwealth of Virginia and across America.