The Association of State Drinking Water Administrators, Environmental Council of States, the Association of Clean Water Administrators, and the Association of State and Territorial Solid Waste Management Officials sent a comment letter to EPA Administrator Wheeler on April 4 regarding the agency’s PFAS Action Plan.
In the letter, the four groups commend EPA for developing the Action Plan, which outlines both short-term and long-term actions that the agency will deploy to address per- and polyfluoroalkyl substances (PFAS). However, the majority of the letter criticizes the plan and highlights a multitude of concerns. In particular, the letter states EPA “should commence the work required for developing a Safe Drinking Water Act (SDWA) Maximum Contaminant Level (MCL) for PFOA and PFOS while completing the regulatory determination rather than taking those steps sequentially.” They also state that the agency should look beyond setting contaminant levels for only PFOA and PFOS and consider the multitude of other PFAS that could potentially be impacting environmental and human health. Many states are already implementing or developing their own MCLs for a variety of PFAS and the four groups encourage EPA to use these as guidelines.
The groups also emphasize the need to focus on keeping PFAS out of the environment through programs like the Toxic Substances Control Act and requests that EPA provide more timelines and deadlines within the Action Plan.