Comment submitted by National Congress of American Indians (NCAI)

July 20, 2026 Lee Zeldin, Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460 RE: Docket ID No. EPA-HQ-OW-2025-0654 — Comments in Opposition to the Proposed Rescission of PFAS Drinking-Water Standards Dear Administrator Zeldin: The National Congress of American Indians (NCAI) respectfully submits the enclosed formal comments opposing the U.S. Environmental Protection Agency’s proposed rescission of Maximum Contaminant Levels (MCLs) and related provisions for PFHxS, PFNA, HFPO-DA (GenX)(collectively, hereafter PFAS), and the Hazard Index mixture. NCAI submits these comments on behalf of the organization, its member Tribal Nations, and Native citizens nationwide. The enclosed submission is authorized by and signed by Larry Wright, Jr., Executive Director of NCAI, and sets forth NCAI’s administrative, legal, and policy objections to the proposed rescission rule. The enclosed submission: • Establishes NCAI’s authority through General Assembly Resolutions #PDX-20-017, #ABQ-19-004, and #PHX-16-067. • Identifies deficiencies under the Safe Drinking Water Act and the Administrative Procedure Act, including EPA’s failure to evaluate reasonable procedural alternatives to wholesale rescission and shortcomings in its analysis of Tribal and other unquantified impacts. • Requests that EPA reconsider its conclusion that the proposed action lacks Tribal implications under Executive Order 13175 and conduct meaningful government-to-government consultation with Tribal Nations. • Explains how the proposed rescission may affect Tribal public health, localized water systems, subsistence practices, treaty-reserved resources, and the practical usability of Tribal water resources. • Provides scientific, administrative, and regional support regarding PFAS monitoring gaps, exposure pathways, and Tribal-system vulnerabilities. NCAI requests that these comments, together with the Appendix and cited supporting materials, be included in the official administrative record for Docket ID No. EPA-HQ-OW-2025-0654. NCAI further requests that EPA withdraw the proposed rescission or, at minimum, undertake structured Tribal consultation, publish a Tribal Implications Analysis or comparable Tribal-specific assessment, address unquantified Tribal impacts, and provide a meaningful opportunity for comment on a procedural alternative that preserves protective drinking-water standards. Thank you for your consideration of this important matter affecting Tribal sovereignty, public health, and the protection of Tribal water resources. Respectfully submitted, Viswatej Attili Policy Associate National Congress of American Indians Enclosure: Formal Comment Letter, Comments in Opposition to the Proposed Rescission of PFAS Drinking-Water Standards (signed by Larry Wright, Jr., Executive Director, NCAI)