Comment submitted by National Waste & Recycling Association (NWRA)

Summary: The National Waste & Recycling Association (NWRA) supports the EPA's efforts to update the PFAS destruction and disposal guidance but requests more clarity and balance in the document. They argue that the guidance should explicitly recognize modern Subtitle D landfills as a necessary and effective management pathway for large volumes of non-hazardous PFAS-containing materials, while also incorporating more science-based evidence regarding PFAS sequestration in solid phases.