Coal ash can complicate redevelopment, but it does not automatically make a property unusable.
The amount and type of ash, contaminant concentrations, site conditions and intended reuse each shape the environmental, engineering, regulatory and financial decisions that follow. The presence of ash is the start of the evaluation, not the conclusion.
“This all depends on the amount of ash present, contamination levels, site conditions and intended reuse,” said Scott Vinsant, PG, Subsidiary Assistant Regional Manager for ECS Southeast, LLC, who has worked in the coal ash industry for about 20 years.
What is coal ash, and why does it affect redevelopment?
Coal ash, also called coal combustion residuals or CCR, is produced when coal is burned to generate electricity. The U.S. Environmental Protection Agency (EPA) reports that coal ash can contain constituents such as mercury, cadmium, chromium and arsenic. Material that is not managed under an applicable program may affect groundwater, surface water or air.
That is why ash matters to a buyer or a community evaluating a property. Ash last for decades. Where it remains, it becomes part of the subsurface conditions that any future land use has to manage.
Does coal ash make a property unusable?
Vinsant says several assumptions come up repeatedly, and that site data often tells a different story. Among them:
- Ash sites are too contaminated to redevelop
- Ash is the same everywhere
- A site must be excavated
- Homes cannot be built nearby
- Ash is regulated in the same way as a hazardous waste landfill
- Groundwater is affected in every case
- A property with ash holds no value
- Ash is found only at power plants.
Instead of relying on assumptions, consider a site evaluation to help measure site conditions. These conditions can include:
- The type of redevelopment proposed
- The amount of ash and where it sits
- Contaminant concentrations
- Whether the material is capped or otherwise contained
- Foundation requirements
- Regulatory permitting and agency involvement
The above factors point toward material removal, containment, specialized foundations or another approach fitted to the site.
How common is coal ash?
Coal ash is not a narrow redevelopment topic. According to the American Coal Ash Association (ACAA), coal-fired electric utilities produced 63.6 million tons of coal combustion products in 2024, down from 66.7 million tons in 2023. EPA cites the same survey on its CCR reuse pages.
The volumes involved at a single site are large. “There are hundreds and hundreds of acres, and they take many years, anywhere from 5 to 15 years to do these projects,” Vinsant said.
The market is also shifting. ACAA also reported that 46 million tons were beneficially used in 2024, a recycling rate of 72%, up from 69% the year before. That was the 10th consecutive year in which more than half of the coal ash produced in the United States was beneficially used rather than disposed. Use of fly ash in concrete rose from 11.9 to 14.6 million tons. ACAA also reports growth in the harvesting of previously disposed ash for beneficial use markets.
Can coal ash be reused?
The answer is: sometimes. But testing is the only way to truly answer this question. Material characterization evaluates whether a given ash may meet the requirements of a defined application. Applications vary by product and include concrete, cement manufacturing, gypsum panels and other engineered materials.
EPA’s current definition of beneficial use rests on criteria that address functional benefit, substitution for a virgin material, and conformance with relevant product specifications or design standards. Beneficial use is a technical finding, not simply a new destination for the material.
Vinsant describes the work as addressing “an environmental issue in a construction way.” He also points to a longer arc that many people outside the industry have not encountered. Modern ash landfills can be built so that characterized material stays traceable within the unit.
“As they determine a use, they can go in and open these back up and actually mine them for that material for use in another product later on, and then close it back up,” he said. “It’s a continual cycle.”
That reframes the disposal unit. It becomes a managed inventory of characterized material rather than a closed chapter.
Is a coal ash site a brownfield?
Not by definition. EPA describes a brownfield as real property where expansion, redevelopment or reuse may be complicated by the presence or possible presence of a hazardous substance, pollutant or contaminant. Some properties with ash meet that description. Others are regulated units at operating facilities and sit under a different program entirely.
Eligibility for brownfields funding is decided by the program and the applicant, not by the presence of ash. Communities evaluating a former industrial, fill or disposal property are better served by asking what the site data shows and which program applies.
What is changing in coal ash regulation right now?
The federal picture is constantly changing, so it’s best to treat any summary as dated.
EPA published a proposed rule in April 2026 that would amend the CCR regulations. As proposed, it would rescind the CCR management unit requirements, broaden the closure-by-removal certification options for legacy surface impoundments and revise the definition of beneficial use, including removal of the environmental demonstration criterion for larger unencapsulated non-roadway placements. The comment period closed on June 12, 2026. Litigation over the 2024 legacy rule has been held in abeyance while EPA reconsiders it.
For property owners and developers, the practical effect is that requirements may shift while a project is in progress. Site characterization data holds its value across those changes, but assumptions about the rules do not. This is why working with a trusted engineering consultant, whose job it is to stay on top of these changes as they occur, is important.
How ECS supports coal ash projects
ECS professionals work at both ends of the coal ash life cycle.
At a closed ash disposal landfill in Georgia, permitted by the state, ECS has provided semi-annual groundwater sampling and consulting since 2021 under an approved Groundwater Monitoring Plan. The work includes constituent of concern trend analysis, statistical analysis and semi-annual assessments of the low permeability barrier and vegetative cover system.
On an active CCR closure project in Alabama, Scott’s team supports landfill construction for coal ash, including soil compaction, pond work and liner systems built from compacted clay and synthetic membrane. Vinsant notes that this work calls for credentialed staff. “You have to have a team of highly qualified and certified individuals before they can even step on the site,” he said.
Both projects combine field observation, laboratory testing, evaluation and construction materials services. That combination is what allows a client to evaluate ash placement, containment and possible reuse using site-specific data.
For communities and developers, the more useful question is not whether coal ash is present, but what the site data, the applicable requirements and the intended reuse indicate about the path forward.