Comment submitted by East Kentucky Power Cooperative, Inc. (EKPC)

Summary: East Kentucky Power Cooperative, Inc. (EKPC), a non-profit electric utility, supports the EPA's proposal to use Best Professional Judgment (BPJ) permitting for unmanaged combustion residual leachate (CRL) due to its site-specific variability and high costs. The commenter also urges the EPA to continue revising the broader 2024 Effluent Limitations Guidelines (ELGs), specifically advocating for the elimination of zero discharge standards for managed CRL.