May 22, 2009 

Honorable Lisa Jackson 

EPA Administrator 

USEPA Headquarters 

Ariel Rios Building 

1200 Pennsylvania Ave., NW 

Mail Code 1101A 

Washington, D.C. 20460 

Dear Administrator Jackson: 

We are the owners and managers of Beneficial Reuse Management, a firm organized 

more than 10 years ago to develop environmentally friendly programs for reuse of 

industrial byproducts that would be economically practical and attractive to industry. A 

meaningful portion of our activity involves utilizing byproducts from coal combustion as 

geotechnical construction material in building projects. As a result, we are vitally interested 

in your current deliberations regarding the future regulation of coal ash for disposal and 

reuse. 

We initially built our business in the State of Wisconsin, whose introduction of 

comprehensive regulations on industrial byproduct reuse in 1999 created the opportunity 

that led to the creation of our company. As we have expanded to other States, we have 

utilized the high standards incorporated in Wisconsin’s NR 538 reuse regulations as the 

template for all our projects, even in jurisdictions where our activities are more or less 

unregulated. We have successfully implemented more than 200 projects since our 

founding, adhering to our guiding principal that protection of the natural environment and 

human health was our first and most important priority. 

We strongly believe that the benefits achievable from properly engineered and constructed 

beneficial reuse projects utilizing of coal combustion byproducts as geotechnical 

construction material are substantial and well proven. Such reuse conserves natural 

resources, reduces CO2 emissions, strengthens local economies, saves money and 

preserves landfill space. We also believe that these benefits can be gained without 

harming the environment through a thoughtfully constructed and implemented regulatory 

framework. 

Beneficial Reuse Management, LLC. • 212 West Superior Street • Suite 402 • Chicago, IL 60654 

Phone: 312-784-0300 • Fax: 312-784-0310 • www.beneficialreuse.com
We are consulting with some of our peer companies, our utility customers and with several 

environmental groups close to these issues. For these discussions, we have prepared a 

draft regulatory and environmental framework for use of coal combustion byproducts as 

geotechnical construction materials, a copy of which is attached. We believe this proposal, 

refined through discussions with all parties and then applied on a national level, could go a 

long way toward preserving the substantial benefits of beneficial reuse while protecting the 

environment. We are hopeful that the United States Environmental Protection Agency 

(USEPA) will consider this proposal in its rulemaking process on coal combustion 

byproducts and we offer our experience and expertise in this area to you wherever it might 

be helpful. 

We respectfully request a meeting with you to provide additional clarification and 

information. 

Sincerely, 

BENEFICIAL REUSE MANGEMENT 

David B. Schuurman, Chairman Robert C. Spoerri, CEO 

Cc: Matt Hale, USEPA 

 John Sager, USEPA 

 Lisa Evans, Earth Justice 

 Tom Fitzpatrick, Kentucky Resources Council 

 Jeff Stant, Environmental Integrity Project 

 Eric Schaeffer, Environmental Integrity Project 

 Tom Adams, American Coal Ash Association 

Beneficial Reuse Management, LLC. • 212 West Superior Street • Suite 402 • Chicago, IL 60654 

Phone: 312-784-0300 • Fax: 312-784-0310 • www.beneficialreuse.com