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Honorable Lisa Jackson Administrator United States Environmental Protection Agency Ariel Rios Building 1200 Pennsylvania Avenue, NW Mail Code: 1101A Washington, DC 20460

March 2, 2009

Dear Administrator Jackson:

Coal combustion waste poses a serious threat to th e environment and public health across the United States. Nearly a hundred million tons of toxic coal ash and related combustion wastes pile up in unlined ponds and pits across the United States every year. The disaster at TVA’s Kingston plant d ramatized the need for federal standards for safe disposal of these wastes, which are virtually unregulated by the U.S. Environmental Protection Agency (EPA). After eight years of counterproductive backpedaling, we are confident that you will chart a new, responsible course for the Agency by supporting the adoption of standards, whe ther reflected in legislation or new regulations, that reflect the gravity of the situat ion and are guided by a consistent set of principles. In this regard, we urge you to recogni ze the following:

(1) The EPA has been weighing whether and how to regula te coal combustion wastes for at least a decade, while this toxic material ha s continued to leak or spill from unsafe dumpsites. Nearly five years ago, a coaliti on of 125 environmental groups petitioned the Agency to stop disposal of coal ash in the kind of wet “surface impoundment” that gave way in Kingston. The eviden ce is in, and the Agency needs to act now to regulate the disposal of coal c ombustion wastes under Subtitle C of the Resource Conservation and Recover y Act.

(2) The EPA should consult with the Office of Surface M ining and other federal agencies as appropriate. But the EPA must assume t he lead responsibility for writing the rules, as it is the federal agency with the broadest statutory mandate to protect both human health and the environment, and because it has the expertise and experience to write and enforce hazardous waste regulations.

(3) Standards should be designed to protect both public health and natural resources, taking into account existing federal and state stan dards for protecting drinking water and aquatic life.

(4) Regulations should apply to all forms of land dispo sal, not just surface impoundments, and should be designed to prevent slo w leaks as well as catastrophic structural failures. EPA’s 2007 “Huma n and Ecological Risk Assessment from Coal Combustion Wastes” documented the highest cancer risks from surface impoundments, but also found unaccepta ble health risks from clay-2 lined coal combustion waste landfills leaking arsen ic into groundwater. The same study showed that both impoundments and landfi lls threaten to overwhelm aquatic ecosystems with toxic levels of other heavy metals.

(5) The wet storage or disposal of coal combustion wast e should be phased out. All containment structures around coal combustion waste surface impoundments should be examined immediately to ensure their stru ctural stability, and contained wastes should be transferred to lined and consisten tly covered landfills located outside of flood plains. Active surface impoundmen ts should be closed and emptied within two years. Monitoring and cleanup s tandards should be required for impoundments that have already closed, and any remaining ash should be transferred to dry disposal sites within five years

.

(6) Coal combustion waste should be carefully analyzed to determine its toxic constituents and the likelihood that contaminants w ill leach under real world conditions. This characterization should include t est measures called for in the National Research Council’s 2006 report, Managing C oal Combustion Residues in Mines , and recommended by the EPA’s own Science Advisory Board to evaluate the hazards of coal combustion waste at ex isting and proposed disposal sites.

(7) The topography and hydrogeology of proposed disposa l sites should be carefully examined to evaluate the likelihood that toxic meta ls and other contaminants will migrate offsite. Siting requirements should keep c oal combustion waste landfills out of locations that are vulnerable to leaks, cont amination, or major breaches of waste into the surrounding environment, such as flo od plains, wetlands, sandy or gravel soils, shallow groundwater tables, active se ismic fault lines, karst zones, and sensitive wildlife habitat.

(8) Coal combustion waste disposal facilities should be designed to prevent offsite contamination. Standards should include placement of waste well above the water table, composite synthetic liners to prevent leaks, leachate collection systems to trap and treat any wastes that do escape , caps and covers to minimize the creation of leachate, and fugitive dust control s to eliminate dispersion of dust or fine particles. The discharge of any wastes int o groundwater, surface water or air should be strictly prohibited.

(9) Groundwater and surface water should be sampled to fully characterize baseline (predisposal) water quality and monitored above and below a disposal site and in likely pathways for offsite migration of toxic meta ls or other pollutants. Samples should be collected frequently enough to detect con tamination and long enough to take into account that pollutants may be release d over an extended period of time. Monitoring should be designed with clear cor rective action standards to detect and prevent contamination from the full rang e of pollutants that are associated with coal combustion waste.3

(10) Site owners and operators should assume respon sibility for monitoring of disposal sites for at least 30 years after closure, and for cleaning up any contamination that may result during that time. Ow ners or operators should be required to demonstrate that they have the financia l means to meet these obligations and post appropriate financial assuranc e to ensure these obligations are promptly met.

(11) Federally enforceable permits should be requir ed for the construction or operation of new or expanded coal combustion waste disposal sites. The public should have the opportunity to participate in permi t proceedings, submit comments, request a public hearing, and appeal a fi nal decision by EPA or the authorized state agency.

(12) Unsafe practices should not be sheltered under so-called “beneficial use” exemptions. In particular, the use of coal ash to “reclaim” surface or underground mines, including abandoned mines, shoul d be subject to the same stringent standards to prevent offsite contaminatio n that apply to land disposal facilities. As recommended by the National Researc h Council, the characteristics of both coal combustion waste and potential reclama tion sites should be evaluated to determine whether minefilling is suita ble for specific locations. EPA, in consultation with the Office of Surface Min ing, should promulgate enforceable federal regulations governing the dispo sal of coal ash in mines.

We hope these principles provide a useful framework as the Agency moves forward to address this important issue. We also r ecognize that you have inherited a backlog of urgent environmental problems that need your attention.

But we feel confident that you will agree that it i s important for the EPA to act as soon as possible. The Agency first recognized coal ash to be a contingent hazardous waste requiring safe standards for disposal in the regulatory determination dated March 5, 2000, which it posted on its website. That decisio n was based on years of study, and over the past decade, the evidence to support federal st andards has continued to accumulate. For example:

• The number of damage cases where ground water and s urface water have been contaminated by coal ash has more than doubled sinc e the publication of EPA’s Final Regulatory Determination on Wastes from the C ombustion of Fossil Fuels, 65 Fed. Reg. 32214 (May 22, 2000). This has occurr ed despite the fact that EPA has not searched independently for damage cases sin ce 2000 nor has the Agency updated its damage case list since 2005. As a resu lt, dozens of documented cases of substantial releases and contamination are absen t from the agency’s list.

• Reports published by EPA’s Office of Research and D evelopment indicate that coal combustion waste leaches hazardous constituent s such as arsenic, cadmium, antimony, selenium and other pollutants in much gre ater quantities than was previously recognized in EPA’s March 1999 Report to Congress: Wastes from the4 Combustion of Fossil Fuels . The Agency’s Office of Research and Development has recognized that air pollution controls will tra nsfer even larger quantities of heavy metals into ash, scrubber sludge, or other co mbustion wastes, and these will be dumped into impoundments or landfills that are n ot designed to contain toxic

waste.

• EPA reports published in 2005 and 2006 have documen ted that the majority of states still lack regulations mandating basic safeg uards at waste disposal sites, including liners and groundwater monitoring. See U.S. Dep’t of Energy & U.S. Envtl. Prot. Agency , Coal Combustion Waste Management at Landfills and Surface Impoundments, 1994–2004 (Aug. 2006) and DPRA Inc. , Estimation of Costs for Regulating Fossil Fuel Combustion Ash Man agement at Large Electric Utilities Under Part 258 (prepared for the Office of Solid Waste, U.S. Envt l. Prot. Agency) (Nov. 30, 2005).

• The National Research Council warned in 2006 that c oal ash used to reclaim abandoned mines could release their toxic burden in to groundwater or surface water, unless the federal government established sa fe standards for this practice.

• As noted above, the EPA’s 2007 assessment estimated risks to both human health and aquatic life from surface impoundments and land fills to be well above levels that EPA generally considers “acceptable.”

EPA’s failure to act to prevent the hazards documen ted extensively in the Agency’s own studies is difficult to understand. S o is the Agency’s refusal to respond to a Petition for Rulemaking submitted in February 200 4 and signed by 125 environmental groups, which requested the prohibition of disposal of coal ash in water and the regulation of disposal sites under Subtitle C of RC RA. EPA has essentially done nothing to move toward regulation of the waste since the pu blication of a Notice of Availability in August 2007.

We hope that under your leadership, the Agency will put an end to this waiting game, and we are ready to do our part. In January of 2007, a coalition of more than forty environmental groups delivered a detailed model of coal combustion waste regulations that the Agency should use as a template for new fe deral regulations. Our proposal provides a good starting point, but should be suppl emented to account for what has been learned from the disasters in Tennessee and Alabama , as well as EPA’s Human and Ecological Risk Assessment and the documents cited above.

It is time to face the obvious: coal combustion was te needs to be regulated as the hazardous waste that it is, before even more damage is done. The evidence is in, and the time to act is now.

Thank you for considering our views.5

Sincerely,

Eric Schaeffer Executive Director Environmental Integrity Project 1920 L St., NW, Suite 800 Washington, D.C. 20036 eschaeffer@environmentalintegrity.org

Frances Beinecke President Natural Resources Defense Council 40 West 20th Street New York, NY 10011 jdevine@nrdc.org

Carl Pope Executive Director Sierra Club 85 Second Street, 2nd Floor San Francisco, CA 94105 Lyndsay.Moseley@sierraclub.org

Armond Cohen Executive Director Clean Air Task Force 18 Tremont Street, Suite 530 Boston, MA 02108 acohen@catf.us aweeks@catf.us

Mike Clark Executive Director Greenpeace 702 H Street, NW, Suite 300 Washington, D.C. 20001 rick.hind@wdc.greenpeace.org

Tom Smitty Smith Director Public Citizen 1303 San Antonio St Austin, TX 78701 Smitty@Citizen.org Trip Van Noppen President Earthjustice 426 17th Street Oakland, CA 94612 levans@earthjustice.org

Paloma Galindo President United Mountain Defense P.O. Box 20363 Knoxville, TN 37920 unitedmountaindefense@yahoo.com

Stephen A. Smith, DVM Executive Director Southern Alliance for Clean Energy P.O. Box 1842 Knoxville, TN 37901 sasmith@cleanenergy.org

Fred Krupp President Environmental Defense Fund 257 Park Avenue South New York, NY 10010 tolson@edf.org

Larry Schweiger President and Chief Executive National Wildlife Federation 11100 Wildlife Center Dr. Reston, VA 20190 dittloff@nwf.org

Margie Alt Executive Director Environment America 218 D St. SE Washington DC 20003 christyg@environmentamerica.org6

Gene Karpinski President League of Conservation Voters 1920 L Street NW #800 Washington, DC 20036 tiernan_sittenfeld@lcv.org

Jesse Kharbanda Executive Director Hoosier Environmental Council 3951 N. Meridian St. Indianapolis, IN 46208 jkharbanda@hecweb.org

Rachel Filippini Executive Director Group Against Smog and Pollution (GASP) 5604 Solway St., #204 Pittsburgh, PA 15217 gasp@gasp-pgh.org

Frank Carl Executive Director Savannah Riverkeeper 1226 River Ridge Rd Augusta, GA 30909 frank.carl@savannahriverkeeper.org

James D. Jensen Executive Director Montana Environmental Information Center P.O Box 1184 Helena, MT 59624 jjensen@meic.org

Martha Dansdill Executive Director HealthLink P.O. Box 301 Swampscott, MA 01907 healthlink@healthlink.org John DeCock President Clean Water Action 1010 Vermont Avenue NW, Ste. 1100 Washington, D.C. 20005-4918 lthorp@cleanwater.org

Kristine Stratton Executive Director Waterkeeper Alliance 50 South Buckhout Street, Suite 302 Irvington, NY 10533 sedwards@waterkeeper.org

Jan Schlichtmann, Esq. President Wenham Lake Watershed Association Beverly, Salem, and Wenham Massachusetts P.O. Box 233 Prides Crossing, MA 01965 jan@schlichtmannlaw.com

Karen Hadden Executive Director Sustainable Energy and Economic Development (SEED) Coalition 1303 San Antonio St Austin, TX 78701 karen@seedcoalition.org

Kathy Andria President American Bottom Conservancy P.O. Box 4242 Fairview Heights, IL 62208-4242 kathyandria@gmail.com

Raina Rippel Executive Director Center for Coalfield Justice 96 E. Chestnut Street Washington, PA 15301 Raina@coalfieldjustice.org7

Jan Jarrett President and CEO Citizens for Pennsylvania's Future (PennFuture) 610 North Third Street Harrisburg, PA 17101 jarrett@pennfuture.org

Bob Shavelson Executive Director Cook Inletkeeper P.O. Box 3269 3734 Ben Walters Lane Homer, AK 99603 bob@inletkeeper.org

Brent Blackwelder President Friends of the Earth 1717 Massachusetts Ave., Suite 600 Washington, DC 20036 epica@foe.org

Beverly Braverman Executive Director Mountain Watershed Association, Inc. P.O. Box 408 Melcroft, PA 15462 mwa@mtwatershed.com

Maureen O’Connell Executive Director Save Our Cumberland Mountains P.O. Box 479 Lake City, TN 37769 alex@socm.org

Michael J. Churchman Executive Director Alabama Environmental Council 2431 Second Avenue North Birmingham, AL 35213 michael@aeconline.org James O. Kennon President Sevier Citizens For Clean Air And Water, Inc. 146 North Main Street, Suite 27 P.O. Box 182 Richfield, UT 84701 sccaw@yahoo.com

William D. Lockwood President S.U.F.F.E.R. (Save Us From Future Environmental Risk) 531 South Poplar Street--Rear Hazleton, PA 18201 locklock@ptd.net

Rich Cogen Executive Director Ohio River Foundation 4480 Classic Drive Cincinnati, OH 45241 rcogen@ohioriverfdn.org

Grace West Director and Secretary-Treasurer Concerned Citizens of Carroll County 30879 JJ Highway Norborne, MO 64668 gwest@greenhills.net

Dr. Bretwood Higman Director Ground Truth Trekking P.O. Box 164 Seldovia, AK 99663 hig314@gmail.com

Ann Mesrobian Conservation Chair Bastrop County Environmental Network P.O. Box 1069 Bastrop, TX 78602 akamai@onr.com8

Glynnis Collins Executive Director Prairie Rivers Network 1902 Fox Drive, Suite G. Champaign, IL 61820 gcollins@prairierivers.org

John Blair President Valley Watch, Inc. 800 Adams Avenue Evansville, IN 47713 Ecoserve1@aol.com

Mark Pearson Executive Director San Juan Citizens Alliance P.O. Box 2461 Durango, CO 81302 meisenfeld@frontier.net

Dennis Shekinah President Watauga Watershed Alliance 900 Miningtown Rd Mountain City, TN 37683 wwa@me.com gla4797@embarqmail.com

Thomas J. Yurick, Sr. President Citizen Advocates United to Safeguard the Environment, Inc. (CAUSE) 400 North Broad Street West Hazleton, PA 18202 tjyurick@verizon.net

Karen M. Schapiro Executive Director Midwest Environmental Advocates 551 W. Main Street, Ste. 200 Madison, WI 53703 kschapiro@midwestadvocates.org Michael Noble Executive Director Fresh Energy 408 Saint Peter Street, Suite 220 Saint Paul, MN 55102 noble@fresh-energy.org

Mike Ewall Founder & Director Energy Justice Network 1434 Elbridge St. Philadelphia, PA 19149 catalyst@actionpa.org

Deb Berry President Smith Lake Environmental Preservation Committee 860 Alford Avenue Hoover, AL 35226 debbiecberry@aol.com

Justine Thompson Executive Director GreenLaw State Bar of Georgia Building 104 Marietta St. NW, Suite 430 Atlanta, GA 30303 jthompson@green-law.org

Carrie La Seur, Ph.D., J.D. President and Founder Plains Justice 100 First Street SW Cedar Rapids, IA 52404 claseur@gmail.com

Maya K. van Rossum Executive Director Delaware Riverkeeper Network 300 Pond Street, Second Floor Bristol, PA 19007 tracy@delawareriverkeeper.org9

Michael D. Fiorentino, Esq. Executive Director Mid-Atlantic Environmental Law Center 4601 Concord Pike Wilmington, DE 19803 mdfiorentino@widener.edu

Tammy Cromer-Campbell Executive Director Working Effectively for Clean Air Now (WE CAN) 207 N. Center St. Longview, TX 75601 wecan2009@gmail.com

Stephen A. Sanders Director and Attorney at Law Appalachian Citizens Law Center, Inc. 317 Main St Whitesburg, KY 41858 steve@appalachianlawcenter.org

Michael J. Crosby President BCAAT, Inc. (Breathe Clean Air Action Team) 298 Village Square #129 Loudon, TN 37774 miklonx@msn.com

Norman Harvey President Greater Gambrills Improvement Association Odenton, MD normanking@netzero.net

William T. Hopwood President Hopwood Inc. An Environmental Trust, Inc. 46 High St. Camden, ME 04843 bill@hopwoodinc.com Louise Gorenflo Director Solar Valley Coalition 185 Hood Drive Crossville TN 38555 lgorenflo@gmail.com

Mark Trechock Staff Director Dakota Resource Council P.O. Box 1095 Dickinson ND 58602-1095 mark@drcinfo.com

John Horning Executive Director WildEarth Guardians 312 Montezuma Ave. Santa Fe, NM 87501 jhorning@wildearthguardians.org

Renée Victoria Hoyos Executive Director Tennessee Clean Water Network 123 A Gay St. Knoxville, TN 37902 renee@tcwn.org

John McFadden Executive Director Tennessee Environmental Council One Vantage Way, E-250 Nashville, TN 37228 John_mcfadden@att.net

Frank O’Donnell President Clean Air Watch 1250 Connecticut Avenue, NW, Ste. 200 Washington, DC 20036 cleanairfrank@cleanairwatch.org10

Cathy Lodge President Residents Against Power Plant (RAPP) 257 Meinrad Drive Bulger, PA 15019 tophcat@windstream.net

Hugh Rogers President West Virginia Highlands Conservancy P.O. Box 306 Charleston, WV 25321 clrank@hughes.net

Karin P. Sheldon Executive Director Western Resource Advocates 2260 Baseline Road Boulder, CO 80302 ksheldon@westernresources.org

Nelson Brooke Riverkeeper/Executive Director Black Warrior Riverkeeper 712 37th Street South Birmingham, AL 35222 nbrooke@blackwarriorriver.org

Cindy Lowry Executive Director Alabama Rivers Alliance 2027 2nd Ave N, Ste A Birmingham, AL 35203 clowry@alabamarivers.org

Richard Stout Chair Citizens Coal Council P.O. Box 964 Washington, PA 15301 ccc@citizenscoalcouncil.org Robert LeResche, PhD Chair Powder River Basin Resource Council 934 N. Main St. Sheridan, WY 82801 sanderson@powderriverbasin.org

J. Casey Sterr Executive Director Appalachia - Science in the Public Interest 50 Lair Street Mt. Vernon, KY 40456 casey@a-spi.org

Rebecca Jim Executive Director LEAD Agency, Inc. (Local Environmental Action Demanded) 19257 South 4403 Drive Vinita, OK 74301 rjim@neok.com

Robert M. East Jr. Ph.D. Director of Environmental Studies Washington & Jefferson College 026 Thistle Hall 60 South Lincoln Street Washington, PA 15301 reast@washjeff.edu

Scot Rutledge Executive Director Nevada Conservation League & Nevada Conservation League Education Fund 7473 West Lake Mead Blvd. Ste. 100 Las Vegas, NV 89128 scot@nvgreenvote.org

Matthew Wasson Interim Executive Director Appalachian Voices 191 Howard Street Boone, NC 28607 scott@appvoices.org11

Roseann Weinrich President Mahanoy Creek Watershed Association 420 Dutchtown Road Ashland, PA 17921 rbwbionerd@yahoo.com

Joe Lovett Executive Director Appalachian Center for the Economy and the Environment 5640 Howards lick Rd Mathias, WV 26812 mjanes@appalachian-center.org

Julia Bonds Co-Director Coal River Mountain Watch P.O. Box 651 Whitesville, WV 25209 judy@crmw.net

Elizabeth Crowe Director Kentucky Environmental Foundation P.O. Box 467 Berea, KY 40403 elizabeth@cwwg.org

Tom FitzGerald Director Kentucky Resources Council, Inc. P.O. Box 1070 Frankfort, KY 40602 fitzkrc@aol.com

Travis Brown President Neighbors for Neighbors 1139 PR 7009 Lexington, TX 78947 travisbrown1@earthlink.net mggangnes@aol.com Pam Solo President and CEO theCLEAN.org, c/o the Civil Society Institute 1 Bridge Street, Suite 200 Newton, MA 02458 psolotls@aol.com

James (Bud) Prast President People in Need of Environmental Safety (PINES) 1607 N 500 E Michigan City, IN 46360 pkysel@live.com

Janet Keating Executive Director Ohio Valley Environmental Coalition P.O. Box 6753 Huntington, WV 25773-6753 janet.ovec@gmail.com

Sarah McCoin Farm Manager & Farm Resident The Adkisson Farm 786 Swan Pond Circle Road Harriman, TN 37748 smccoin@gmail.com

Dana Kuhnline Coordinator Alliance for Appalachia P.O. Box 11701 Charleston, WV 25339 dana.kuhnline@gmail.com

Diana L. Anderson Tennessee Coal Ash Survivors Network 364 Emory River Road Harriman, TN 37748 diana@artphotosbydiana.com tncasn@gmail.com12

Dr. Robert A. Bardwell Principal Bardwell Consulting Ltd. 4801 W. Yale Drive Denver CO 80219 andy@bardwellconsulting.com

Val West President Save Our Land & Environment (SOLE) John L. Wathen Hurricane Creekkeeper Friends of Hurricane Creek 5600 Holt Peterson Rd. Tuscaloosa, AL 35404 creekkeeper@hughes.net

Donna Lisenby Watauga Riverkeeper Appalachian Voices 191 Howard Street Boone, NC 28607 donna@appvoices.org

V. John White Executive Director Center for Energy Efficiency & Renewable Technologies 1100 Eleventh Street, Suite 311 Sacramento, CA 95814 vjw@ceert.org

Rick S. Middleton Executive Director Southern Environmental Law Center Headquarters 201 West Main St., Suite 14 Charlottesville, VA 22902-5065 ctaylor@selcnc.org

Don Mottley Save Our Rivers 6222 Yankeetown Road Boonville, IN 47601-8279 valley@evansville.net Adella Begaye President, Board of Directors Diné Citizens Against Ruining Our Environment (DINÉ CARE)

P. O. Box 3405 Chinle, AZ 86503 frazierann1@hotmail.com

Kevin Knobloch President Union of Concerned Scientists Two Battle Square Cambridge, MA 02238-9105 kknobloch@ucsusa.org mwentworth@ucsusa.org

Elisa Young Founder Meigs Citizens Action Now! 48360 Carmel Road Racine, OH 45771 elisayoung1@yahoo.com

R. John Dawes Executive Director Foundation for Pennsylvania Watersheds 9697 Loop Road Alexandria, PA 16611 rjdawes1@verizon.net

KA Owens Chairperson Kentuckians For The Commonwealth P.O. Box 1450 London, KY 40743 blauderdale@earthlink.net

Dave Cooper The Mountaintop Removal Road Show 608 Allen Ct. Lexington, KY 40505 davecooper928@yahoo.com13

Ernie Reed Council Chair Heartwood P.O. Box 1011 Alton, IL 62002-1011 andy@blueriver.net

Rhonda Roff President Save It Now, Glades! P.O. Box 1953 Clewiston, FL 33440 marshmaid@gmail.com

James A. McGrath Chair Concerned Citizens of Giles County P.O. Box112 Pearisburg, VA 24134 HqBrtt@i-plus.net

Michael D. Maccanelli President Illinois Citizens Opposed to Longwall Mining P.O. Box 343 Litchfield, IL 62056 mdmeng@consolidated.net

Thomas Price Quality Control Manager Rebel Computers 175 Bradley Lane Harriman, TN 37748 rebeldude835@yahoo.com

Catherine Edmiston President Citizens Against Longwall Mining (CALM) P.O. Box 274 Hillsboro, IL 62049 ruansch7@wamusa.com Cynthia Luppi Co-Director Clean Water Action New England 262 Washington St. Boston, MA 02108 cluppi@cleanwater.org

Judy Poulson Co-President League of Women Voters of Tennessee P.O. Box 158369 Nashville TN 37215-8369 jpoulson319@comcast.net

Martin A. Bartels Executive Director American Canoe Association 1340 Central Park Blvd., Suite 210 Fredericksburg, VA 22309 mbartels@americancanoe.org

Hope Taylor Executive Director Clean Water for North Carolina 291⁄2 Page Ave. Asheville, NC 28801 hope@cwfnc.org

Elaine Lite Chair Mountain Voices Alliance P.O. Box 4093 Asheville, NC 28805 info@mvalliance.net

June Blotnick Executive Director Carolinas Clean Air Coalition 1801 N. Tryon Street, Suite 326 Charlotte, NC 28206 director@clean-air-coalition.org14 References Cited

Committee on Mine Placement of Coal Combustion Wast e, Nat’l Research Council, Managing Coal Combustion Residues in Mines (2006).

DPRA Inc., Estimation of Costs for Regulating Fossil Fuel Com bustion Ash Management at Large Electric Utilities Under Part 2 58 (prepared for the Office of Solid Waste, U.S. Envtl. Prot. Agency) (Nov. 30, 2005).

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Office of Research & Dev., U.S. Envtl. Prot. Agency, Characterization of Coal Combustion Residues from Electric Utilities Using W et Scrubbers for Multi-Pollutant Control (July 2008).

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U.S. Envtl. Prot. Agency, Human and Ecological Risk Assessment of Coal Combustion Wastes (released as part of a Notice of Data Availa bility) (Aug. 6, 2007) (draft).