Comment submitted by Laura Georgi

Docket ID No. EPA-HQ-OW-2009-0819 If you were truly serious about unleashing energy, you wouldn’t be blocking renewables. Electricity from coal is expensive and dirty. The only way you make your Regulatory Impact Assessments come out the way you want is by pretending you can’t quantify the value of health and lifespan costs and benefits so you just ignore them. Coal is currently the most expensive source of electricity. You need to factor THAT into your cost-benefit analysis. Your concern about the previous rule’s underestimation of costs of rule compliance seems hypocritical in light of the expense to utilities and their customers of Trump’s insistence that aging plants scheduled for shutdown remain open. Closed utilities may not be generating revenue, but keeping them open is resulting in actual losses. This administration’s promotion of coal ignores economic reality, in return for what? not the good of the country or planet. You are justifying increased pollution on the basis of the massive growth in power consumption by Data Centers. That isn’t an excuse. It isn’t an emergency just because Trump says so. Industrial users have an obligation to pay for the inclusive costs of their activities, i.e., including costs of cleaning up any mess generated. If this cost is high, then it should encourage efficiency. I have read that Chinese AI achieves nearly equivalent results with much lower energy requirements; competition from this quarter is another incentive for US to seek greater efficiency. China is also investing heavily in clean power and is eating our lunch there as well. History shows that no regulation is likely to satisfy both industry and environmentalists; indeed, it generally displeases both. They will see you in court. Therefore, your goal should be something you can defend in court, not just serve the political donor class. We’re talking about contaminating ground and surface waters with toxic pollutants including mercury and arsenic, and debating who is responsible for either keeping those pollutants out of the water (clearly the better option) or cleaning them up afterwards. Should it be the polluters, or the public? The answer seems obvious to me, particularly for those parts of the 2024 ELG rule that some utilities are already complying with. This proposal appears to relax antipollution regulations specifically for the dirtiest plants – those with “functional equivalent of direct discharge of unmanaged CRL” (and leaving it up to the states, again). Also you appear to be relaxing regulation of closed plants. You spend a fair amount of pixels discussing how complicated and expensive it is to deal with waste contaminating groundwater. It’s there already and more is headed that way, and it’s a disaster, but doing nothing isn’t the solution. Requiring action from the utilities also motivates them to find more effective ways to comply. We should of course make every effort to stop adding to the problem. Water matters a lot.