Comment submitted by James River Association (JRA), Chesapeake Bay Foundation (CBF), and Southern Environmental Law Center (SELC)

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Summary: The Southern Environmental Law Center and Potomac Riverkeeper Network are advocating for stricter enforcement of the federal Coal Combustion Residuals (CCR) Rule in Virginia. They argue that the EPA must ensure the state and Dominion Energy implement effective groundwater cleanup remedies rather than relying on inadequate "natural recovery" methods.
To Whom It May Concern: Comments of Southern Environmental Law Center and Potomac Riverkeeper Network on Docket ID No. EPA-HQ-OLEM-2025-3325, and three attachments thereto, are attached below. Sincerely, Jonathan Gendzier Senior Attorney Southern Environmental Law Center 120 Garrett Street, Suite 400 Charlottesville, VA 22902 (434) 977-4090 jgendzier@selc.org

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