1 

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 the 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 dramatized 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, whether reflected in legislation or new 

regulations, that reflect the gravity of the situation and are guided by a consistent set of 

principles. In this regard, we urge you to recognize the following: 

(1) The EPA has been weighing whether and how to regulate coal combustion wastes 

for at least a decade, while this toxic material has continued to leak or spill from 

unsafe dumpsites. Nearly five years ago, a coalition 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 evidence is in, and the Agency 

needs to act now to regulate the disposal of coal combustion wastes under 

Subtitle C of the Resource Conservation and Recovery Act. 

(2) The EPA should consult with the Office of Surface Mining and other federal 

agencies as appropriate. But the EPA must assume the 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 standards for protecting drinking 

water and aquatic life. 

(4) Regulations should apply to all forms of land disposal, not just surface 

impoundments, and should be designed to prevent slow leaks as well as 

catastrophic structural failures. EPA’s 2007 “Human and Ecological Risk 

Assessment from Coal Combustion Wastes” documented the highest cancer risks 

from surface impoundments, but also found unacceptable health risks from clay-
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lined coal combustion waste landfills leaking arsenic into groundwater. The 

same study showed that both impoundments and landfills threaten to overwhelm 

aquatic ecosystems with toxic levels of other heavy metals. 

(5) The wet storage or disposal of coal combustion waste should be phased out. All 

containment structures around coal combustion waste surface impoundments 

should be examined immediately to ensure their structural stability, and contained 

wastes should be transferred to lined and consistently covered landfills located 

outside of flood plains. Active surface impoundments should be closed and 

emptied within two years. Monitoring and cleanup standards 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 will leach under real world 

conditions. This characterization should include test measures called for in the 

National Research Council’s 2006 report, Managing Coal Combustion Residues 

in Mines, and recommended by the EPA’s own Science Advisory Board to 

evaluate the hazards of coal combustion waste at existing and proposed disposal 

sites. 

(7) The topography and hydrogeology of proposed disposal sites should be carefully 

examined to evaluate the likelihood that toxic metals and other contaminants will 

migrate offsite. Siting requirements should keep coal combustion waste landfills 

out of locations that are vulnerable to leaks, contamination, or major breaches of 

waste into the surrounding environment, such as flood plains, wetlands, sandy or 

gravel soils, shallow groundwater tables, active seismic 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 controls to eliminate dispersion of dust 

or fine particles. The discharge of any wastes into 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 metals or other pollutants. Samples 

should be collected frequently enough to detect contamination and long enough 

to take into account that pollutants may be released over an extended period of 

time. Monitoring should be designed with clear corrective action standards to 

detect and prevent contamination from the full range of pollutants that are 

associated with coal combustion waste. 
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(10) Site owners and operators should assume responsibility for monitoring of 

disposal sites for at least 30 years after closure, and for cleaning up any 

contamination that may result during that time. Owners or operators should be 

required to demonstrate that they have the financial means to meet these 

obligations and post appropriate financial assurance to ensure these obligations 

are promptly met. 

(11) Federally enforceable permits should be required for the construction or 

operation of new or expanded coal combustion waste disposal sites. The public 

should have the opportunity to participate in permit proceedings, submit 

comments, request a public hearing, and appeal a final 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, should be subject to the same 

stringent standards to prevent offsite contamination that apply to land disposal 

facilities. As recommended by the National Research Council, the characteristics 

of both coal combustion waste and potential reclamation sites should be 

evaluated to determine whether minefilling is suitable for specific locations. 

EPA, in consultation with the Office of Surface Mining, should promulgate 

enforceable federal regulations governing the disposal 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 recognize that you have inherited a 

backlog of urgent environmental problems that need your attention. 

But we feel confident that you will agree that it is 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 decision was based on years of study, and over 

the past decade, the evidence to support federal standards has continued to accumulate. 

For example: 

• The number of damage cases where ground water and surface water have been 

contaminated by coal ash has more than doubled since the publication of EPA’s 

Final Regulatory Determination on Wastes from the Combustion of Fossil Fuels, 

65 Fed. Reg. 32214 (May 22, 2000). This has occurred despite the fact that EPA 

has not searched independently for damage cases since 2000 nor has the Agency 

updated its damage case list since 2005. As a result, dozens of documented cases 

of substantial releases and contamination are absent from the agency’s list. 

• Reports published by EPA’s Office of Research and Development indicate that 

coal combustion waste leaches hazardous constituents such as arsenic, cadmium, 

antimony, selenium and other pollutants in much greater quantities than was 

previously recognized in EPA’s March 1999 Report to Congress: Wastes from the 
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Combustion of Fossil Fuels. The Agency’s Office of Research and Development 

has recognized that air pollution controls will transfer even larger quantities of 

heavy metals into ash, scrubber sludge, or other combustion wastes, and these will 

be dumped into impoundments or landfills that are not designed to contain toxic 

waste. 

• EPA reports published in 2005 and 2006 have documented that the majority of 

states still lack regulations mandating basic safeguards 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 Management at Large Electric 

Utilities Under Part 258 (prepared for the Office of Solid Waste, U.S. Envtl. Prot. 

Agency) (Nov. 30, 2005). 

• The National Research Council warned in 2006 that coal ash used to reclaim 

abandoned mines could release their toxic burden into groundwater or surface 

water, unless the federal government established safe 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 landfills to be well above levels 

that EPA generally considers “acceptable.” 

EPA’s failure to act to prevent the hazards documented extensively in the 

Agency’s own studies is difficult to understand. So is the Agency’s refusal to respond to 

a Petition for Rulemaking submitted in February 2004 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 RCRA. EPA has essentially done nothing 

to move toward regulation of the waste since the publication 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 federal regulations. Our proposal 

provides a good starting point, but should be supplemented 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 waste 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.org 
6 

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.org 
7 

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.com 
8 

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.org 
9 

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.org 
10 

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.org 
11 

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.com 
12 

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.com 
13 

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.org 
14 

References Cited 

Committee on Mine Placement of Coal Combustion Waste, Nat’l Research Council,

Managing Coal Combustion Residues in Mines (2006). 

DPRA Inc., Estimation of Costs for Regulating Fossil Fuel Combustion Ash 

Management at Large Electric Utilities Under Part 258 (prepared for the Office of Solid 

Waste, U.S. Envtl. Prot. Agency) (Nov. 30, 2005). 

Final Regulatory Determination on Wastes from the Combustion of Fossil Fuels, 65 Fed. 

Reg. 32214 (Envtl. Prot. Agency, May 22, 2000). 

Office of Research & Dev., U.S. Envtl. Prot. Agency, Characterization of Coal 

Combustion Residues from Electric Utilities Using Wet Scrubbers for Multi-Pollutant 

Control (July 2008). 

Office of Research & Dev., U.S. Envtl. Prot. Agency, Characterization of MercuryEnriched Coal Combustion Residues from Electric Utilities Using Enhanced Sorbents for 

Mercury Control (Feb. 2006). 

Office of Solid Waste & Emergency Response, U.S. Envtl. Prot. Agency, Report to 

Congress: Wastes from the Combustion of Fossil Fuels (Mar. 1999). 

Susan Thorneloe et al., “Improved Leach Testing for Evaluating Fate of Mercury and 

Other Metals from Management of Coal Combustion Residues,” Proceedings Global 

Waste Management Symposium: Promoting Technology and Scientific Innovation (Sept. 

7–10, 2008). 

U.S. Dep’t of Energy & U.S. Envtl. Prot. Agency, Coal Combustion Waste Management 

at Landfills and Surface Impoundments, 1994–2004 (Aug. 2006). 

U.S. Envtl. Prot. Agency, Human and Ecological Risk Assessment of Coal Combustion 

Wastes (released as part of a Notice of Data Availability) (Aug. 6, 2007) (draft).