Comment submitted by TerryAnn Towers Saint Amand

Docket ID: EPA-HQ-OW-2009-0819 I am writing to express concern regarding the proposed revisions to wastewater discharge requirements applicable to unmanaged combustion residual leachate from steam electric power plants. While I understand the stated goals of grid reliability, operational flexibility, and increased electricity demand associated with AI infrastructure, data centers, electrification, and industrial growth, those pressures should not become a blanket justification for weakening long-term water protections without rigorous cumulative-impact analysis, enforceable monitoring requirements, and transparent accountability mechanisms. Coal ash leachate and associated wastewater streams may contain arsenic, mercury, selenium, cadmium, lead, bromide, and other contaminants capable of causing long-term harm to groundwater, surface waters, aquatic ecosystems, and downstream communities. Once contamination migrates into groundwater systems or watershed sediments, remediation becomes significantly more difficult, expensive, and uncertain. I am particularly concerned by proposals that may weaken treatment obligations for unmanaged combustion residual leachate or create regulatory distinctions between wastewater that is actively collected versus contamination that migrates or seeps into waters through groundwater pathways. Such distinctions risk creating loopholes where environmentally significant contamination may occur without equivalent treatment or accountability requirements. The administrative record should fully evaluate cumulative downstream impacts from aging coal ash disposal areas, long-term groundwater migration uncertainty, impacts on rural communities and private well users, risks associated with delayed contamination detection, future cleanup liability burdens transferred to taxpayers or local communities, environmental justice concerns for downstream populations, climate-related flooding or extreme-weather impacts on coal ash containment systems, the practical enforceability of monitoring and reporting requirements, and whether weakened requirements reduce incentives for modernization, ash removal, or safer long-term waste handling practices. I am also concerned about the broader precedent established by framing environmental safeguards as incompatible with infrastructure growth or national competitiveness. Temporary regulatory flexibility granted during periods of grid stress or rapid electricity-demand growth can become effectively permanent if agencies do not establish clear limits, review mechanisms, and enforceable performance standards. Recent federal discussions have explicitly linked AI growth and data-center expansion to continued or expanded coal generation. If increased electricity demand is being used to justify extended operation of aging coal facilities, then associated wastewater, groundwater, and cumulative watershed impacts should receive heightened scrutiny rather than reduced oversight. The administrative record should also evaluate potential impacts on Tribal Nations, including downstream water quality concerns affecting treaty-protected resources, subsistence uses, culturally significant ecosystems, and communities already burdened by legacy industrial contamination. The agency should carefully evaluate whether the proposed revisions appropriately account for cumulative watershed impacts across multiple facilities, aging infrastructure risks, changing hydrological conditions, downstream drinking water implications, long-term monitoring and remediation costs, and realistic enforcement capacity over multi-decade timelines. I urge EPA to maintain robust treatment standards, require transparent monitoring and reporting, preserve enforceable safeguards for groundwater-connected discharges, and avoid creating regulatory pathways that externalize long-term environmental and public-health costs onto downstream communities. Thank you for the opportunity to comment.