My name is Rachael Belz. I’m here today representing 80,000 members of Ohio Citizen Action, the state’s largest environmental organization. I’m here to strongly urge you to adopt the strictest possible standards for coal ash.

There is good reason that Subtitle C is favored by most citizens and environmental groups, including Ohio Citizen Action. It classifies coal ash as a hazardous waste, requires operating permits, closes down dangerous wet ponds, and contains minimum standards that are federally enforceable.

And of course Subtitle D is favored by industry. Since it basically maintains the totally unacceptable “status quo” – it would be absolutely inadequate for the USEPA to choose Subtitle D. It categorizes coal ash as non-hazardous, provides guidelines that are not enforceable, sets no minimum federal standards and only addresses coal ash disposal.

You may or may not know, but the Ohio EPA is not exactly known for environmental enforcement. Keeping the status quo won’t do anything in a state like ours.

I live in Cincinnati, Ohio. 15 of the 44 United States Environmental Protection Agency’s “high hazard sites” for coal ash are in the Ohio River Valley.

Five million people get their drinking water from the Ohio River. This water could be contaminated if the ponds leak, or the man-made dams break. Not to mention the breathing problems that can result from the fly ash coming off the miles long conveyor belts or the dry ash landfills.

There are a number of things that the USEPA missed in both of these proposals, however. It doesn’t even begin to address beneficial use (a recycling of this toxic waste) that is so prevalent in consumer products like drywall, bowling balls, cosmetics and even toothpaste. That’s disgusting. And how could this have happened? Because coal ash isn’t even as regulated as the trash at our curb.

I am including a short video we produced in August, 2010 called Coal Ash in Ohio with my testimony. It highlights the many problems with coal ash in our state and in the Ohio River Valley. It was unbelieveable to see these large coal ash landfills and wet ponds from an aerial flyover we were given by an organization called SouthWings. We attempted to see these landfills and ponds from the ground, but they are hidden from the public. It’s truly unbelieveable to me that even after the devastation at the TVA plant in December 2008 that the USEPA is just now getting around to proposing regulations.

These regulations need to be strict, enforceable, and they need to start now.