Comment submitted by American Coal Ash Association (ACAA)

Summary: The American Coal Ash Association (ACAA) opposes the proposed revisions to the Effluent Limitations Guidelines because they would redirect coal combustion products (CCP) from beneficial use markets back into disposal settings. The association argues that the EPA's analysis overestimates fly ash availability and fails to account for the regional nature of markets and the impact of other regulations on CCP harvesting.