Comment on "wildlife and the coal waste policy debate: proposed rules for coal waste disposal ignore lessons from 45 years of wildlife poisoning".

This analysis examines wildlife poisoning from coal combustion waste (CCW) in the context of EPA's proposed policy that would allow continued use of surface impoundments as a disposal method. Data from 21 confirmed damage sites were evaluated, ranging from locations where historic poisoning has led to corrective actions that have greatly improved environmental conditions to those where contamination has just recently been discovered and the level of ecological impacts has yet to be determined. The combined direct and indirect cost of poisoned fish and wildlife exceeds $2.3 billion, which is enough money to construct 155 landfills with state-of-the-art composite liners and leachate collection systems. This cost is projected to increase by an additional $3.85 billion over the next 50 years, an amount that would construct 257 landfills. Evidence revealed through this study indicates the following: (1) for the past 45 years, environmental damage has been a recurring theme with surface impoundment of CCW, (2) the National Pollutant Discharge Elimination System has not been effective in preventing serious environmental damage from CCW, (3) EPA's Regulatory Impact Analysis of the costs and benefits of pollution control options fails to include benefits of avoided damages to natural resources, specifically, poisoned fish and wildlife, and (4) surface impoundments pose unacceptably high ecological risks regardless of location or design. Regulators should no longer ignore rigorous science and the lessons from multiple case examples. EPA and the United States need to show leadership on this issue by prohibiting surface impoundments, particularly since the rise in coal use in developing countries is leading to the same CCW pollution problems on a global scale.