NRECA appreciates EPA's efforts to provide the opportunity for extensions to the deadline due to the lack of alternative disposal capacity for both CCR and non-CCR wastes. While urging the agency to move expeditiously to finalize this and the upcoming Part B proposal, we also offer three recommendations to improve this proposed rule: 1.Do not shorten the construction timeline from October 31, 2020 but extend the deadline to January 15, 2021 as recommended and justified by the USWAG analysis and recommendation; 2.Revise the proposed extensions to better accommodate events beyond a plant's control (e.g. weather) and remove the proposed language (and related notifications) making the extensions mutually exclusive per the attached Appendix A; and 3.Finalize the CCR Part A and Part B rules concurrently and in coordination with the final ELG rule.
EPARulemakingEPA-HQ-OLEM-2019-0172
Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; A Holistic Approach to Closure Part A: Deadline to Initiate Closure
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Oct 19, 2022
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closed 2370d ago
National Rural Electric Cooperative Association filings
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Activity
National Rural Electric Cooperative Association filed 1 comment on this docket between Feb 5, 2020 and Feb 5, 2020. 21 other organizations filed here. The comment window closed 2370d ago.
What National Rural Electric Cooperative Association filed (1)
Feb 5, 2020· Comment submitted by Dorothy Allen Kellogg, Regulatory Director, Water and Waste Issues, National Rural Electric Cooperative Association (NRECA)· EPA-HQ-OLEM-2019-0172-0086
Abstract
This rule is in response to the vacatur of certain provisions of the 2015 CCR Rule in the August 2018 USWAG court decision and in response to the court’s remand of a specific provision in the July 2018 CCR rule, issued on March 13, 2019. This rule will establish a new date for CCR surface impoundments to cease receipt of waste and initiate closure. It is not economically significant.
View on regulations.gov →Co-filers (21)
See everyone who commented →- National Rural Electric Cooperative AssociationTHIS ORG1 filing · confidence 97%
- American Public Power Associationtrade assoc.1 filing · confidence 97%
- Arizona Public Service Companyunverified attribution1 filing · confidence 70%
- Association of State and Territorial Solid Waste Management Officialstrade assoc.1 filing · confidence 85%
- Basin Electric Power Cooperativeunverified attribution1 filing · confidence 70%
- Berkshire Hathaway Energy Companyunverified attribution1 filing · confidence 70%
- Chesapeake Bay Foundationtrade assoc.1 filing · confidence 85%
- Cleco Corporate Holdings LLCunverified attribution1 filing · confidence 70%
- Electric Power Research Institutetrade assoc.1 filing · confidence 85%
- Environmental Protection Network (EPN)trade assoc.1 filing · confidence 97%
- FirstEnergy Corporationunverified attribution1 filing · confidence 70%
- Geosynthetic Materials Associationtrade assoc.1 filing · confidence 85%
- Indian River Power LLCunverified attribution1 filing · confidence 70%
- Institute for Policy Integritytrade assoc.1 filing · confidence 85%
- Intermountain Power Agency (IPA) and Intermountain Power Service Corporationunverified attribution1 filing · confidence 70%
- Luminant Generation Company LLCunverified attribution1 filing · confidence 70%
- National Ground Water Associationtrade assoc.1 filing · confidence 85%
- Natural Resources Defense Council (NRDC)trade assoc.1 filing · confidence 97%
- Sierra Club1 filing · confidence 97%
- Talen Energy Corporationunverified attribution1 filing · confidence 70%
- West Virginia Rivers Coalitiontrade assoc.1 filing · confidence 85%
- Xcel Energy Inc.unverified attribution1 filing · confidence 70%