Comment submitted by American Coal Ash Association (ACAA)

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Summary: The American Coal Ash Association (ACAA) supports the EPA's proposed approval of Virginia's state coal combustion residuals (CCR) permit program. They argue that state-led programs provide necessary regulatory certainty and flexibility to encourage the beneficial use of coal combustion products (CCP) as a domestic mineral resource.
Attached are comments of the American Coal Ash Association.

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