Comment submitted by Ohio Utilities and Generation (OUG)

Summary: The Ohio Utilities and Generation (OUG), an association of electric utilities, opposes the proposed rule's approach to regulating unmanaged combustion residual leachate (CRL). They argue that the rule should not be used as a groundwater remediation program and that any discharge limits must be site-specific, economically feasible, and focused only on actual point source discharges rather than background or offsite contaminants.