December 15, 2010
The Environmental Integrity Project (EIP), Earthjustice and Sierra Club submitted comments and extensive expert testimony to the US EPA on November 19, making the case for regulation of coal ash disposal under Subtitle C of the Resource Conservation and Recovery Act. Our comments document extensive contamination of groundwater or surface water at dozens of sites across the US, and provide scientific, economic and legal support for federally enforceable standards under Subtitle C. The joint testimony addresses each of the factors EPA must evaluate when regulating this waste, finding that:
- Coal Ash Poses Serious Human Health and Environmental Risks;
- State Regulations are Grossly Deficient in the Majority of States;
- Environmental Justice Concerns Must Be Addressed By EPA;
- The Benefits Greatly Outweigh the Costs of the Subtitle C; and
- Regulation of Disposal Will Encourage Responsible Recycling of Coal Ash.
For the Executive Summary, click here.
For a copy of the full text, click here.
For Expert Testimony available in Appendices and Attachments, click here.