Comment submitted by California Association of Sanitation Agencies (CASA)

Mr. Tso: The California Association of Sanitation Agencies (CASA) appreciates this opportunity to comment on the U.S. Environmental Protection Agency’s (USEPA) Interim PFAS Destruction and Disposal Guidance (Interim Guidance). CASA represents more than 150 public agencies and municipalities in California engaged in wastewater collection, treatment, and recovery of valuable resources to protect public health and the environment. We are the leading California association dedicated to advancing sound public policy and programs to advance community resilience and create a more sustainable environment and economy for Californians. CASA members recover resources from the wastewater treatment process, including recycled water to augment local supply, biogas for the production of renewable energy or low-carbon fuel, biosolids for use as an organic soil amendment, and other valuable resources. Our members (and ratepayers) have experienced firsthand the fallout of the widespread use of non-essential PFAS in household products – through increased costs for sampling of PFAS throughout their systems and directly funding research to attempt to understand the fate of only a subset of PFAS for which we have sampling methods, as well as the real threat to their resource recovery programs. While we understand that the Interim Guidance does not directly address the land application of biosolids, we offer the comments that follow because the Interim Guidance directly intersects with product quality, policy, and operational decisions that water resource recovery facilities continually address to protect public health and the environment.