Comment submitted by Three Rivers Waterkeeper (3RWK)

Summary: Three Rivers Waterkeeper opposes the proposed revisions to the Effluent Limitations Guidelines and Standards for unmanaged combustion residual leachate, arguing that the proposal weakens existing protections and creates regulatory inconsistency. The organization contends that the EPA has not demonstrated that the 2024 standards are technologically infeasible and urges the agency to retain nationally applicable Best Available Technology (BAT) requirements to protect water quality from legacy coal ash pollution.