Comment submitted by DTE Electric (DTE)
AnonymousSupportBusiness
Summary: DTE Electric, a large Michigan-based energy utility, supports the EPA's preferred Option 1 in the 2026 Proposal, which allows for case-by-case Best Professional Judgement (BPJ) limits for functional-equivalent direct discharges. The company opposes Options 2 and 3, arguing that the proposed timelines and zero liquid discharge (ZLD) requirements are technically and economically infeasible for the industry.
DTE appreciates the opportunity to submit the attached comments regarding the Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category-Unmanaged Combustion Residual Leachate.