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Coal Ash Association Comments Reflect Huge Volunteer Effort

Members of the American Coal Ash Association undertook an enormous volunteer effort to create comments on the U.S. Environmental Protection Agency's proposed coal ash disposal regulations. More than 14,000 volunteer hours were expended to create a comment document with 211 pages and more than 11,000 pages of supporting material.

In describing the volunteer effort, the Association wrote: "The volunteers responsible for formulating these comments have combined centuries of experience in coal ash beneficial use issues.  They include ash marketing experts, academicians, engineers, technology developers, and former environmental regulators.  Most of the volunteers are employed by small businesses. As a group, they have more experience in the practical considerations of recycling coal ash than any other organization participating in the EPA’s public comment process.  They are also the group who are feeling the early impacts of stigma and are most at risk of further harm if EPA regulatory actions are finalized under Subtitle C, thereby further stigmatizing coal ash and causing a more drastic reduction in beneficial use activities.”

The Coal Ash Association supported strengthening the regulation of coal ash disposal, but argued strenuously against a "hazardous waste" designation that would stigmatize coal ash and undo decades of progress in encouraging recycling of the material.

A copy of ACAA's comment document can be found here: http://www.recyclingfirst.org/pdfs/55.pdf


Posted by: on: Dec 17, 2010 @ 04:50