Comment submitted by American Water Works Association (AWWA)

Summary: The American Water Works Association (AWWA) supports the EPA's efforts to update the Interim PFAS Destruction and Disposal Guidance but argues that the current draft lacks practical feasibility and regulatory certainty. They recommend that the EPA focus on providing clear regulatory actions under RCRA and CWA, perform a more robust assessment of relative risks for different waste types, and account for the limited geographic availability and capacity of disposal facilities.