ASDWA Co-Signs Comment Letter on EPA’s PFAS Action Plans with State Environmental Associations

ASDWA recently co-signed a comment letter on EPA’s PFAS Action Plan to EPA Administrator Wheeler with three other state environmental associations – the Environmental Council of States (ECOS), the Association of Clean Water Administrators (ACWA), and the Association of State and Territorial Solid Waste Management Officials (ASTSWMO). While the comment letter praises EPA for the development of the Action Plan and the Agency’s acknowledgement of the several challenges states are facing with PFAS, the letter also summarizes several significant concerns. Below are some of those concerns:

• The Action Plan needs to go beyond PFOA and PFOS and beyond drinking water, and considering setting limits for other PFAS in various media.
• The Action Plan should focus on keeping PFAS out of the environment, using TSCA and other statutes as tools to meet that objective.
• The Action Plan needs more timelines and deadlines across the board.
• PFAS need to be addressed as a class, not one at a time.

PFAS are a high priority for almost all of the states, across all environmental media. States are spending their time and resources on addressing this group of unregulated contaminants, as the public is demanding action. In its 2018 Report, Beyond Tight Budgets, ASDWA surveyed states and found that the increased workload from activities addressing unregulated contaminants is significant, ranging from 1.1% to 12.5% without calculating the impacts of inflation (an additional 20% increase in costs over the past decade). Given the increase in PFAS issues (more states are being impacted and the impacts are increasing), this estimate is likely low and ASDWA is in the process of updating this estimate for 2019.