Comment submitted by Peter Ernst
AnonymousOpposeAdvocacy
Summary: Will Willauer of Nantucket Tipping Point opposes the rescission because it would end ongoing monitoring and data collection for these four PFAS chemicals. He argues that without continuous federal data, it will be impossible to establish future limits or track trends in water quality.
Comment — Docket ID EPA-HQ-OW-2025-0654
Re: Proposed Rescission of PFAS Limits for PFHxS, PFNA, HFPO-DA, and Hazard Index
Mixtures
Submitted via regulations.gov by July 20, 2026
By: Will Willauer, President, Nantucket Tipping Point, Nantucket, Massachusetts
Nantucket sits on a single federally designated sole source aquifer (49 FR 2952, 1984). We have no
other water. We know PFAS is in it: one of our public wells has been shut down for PFAS since 2022,
and testing at a town parcel under state investigation found PFAS in groundwater from 4.9 to 22.3 parts
per trillion.
The current nationwide screening for these four chemicals (UCMR5) ends in 2025. After that, the 2024
rule is what keeps them measured — it makes every affected water system test for them on an ongoing
basis and report the results. This rescission removes that. Once the one-time national survey closes and
the rule is gone, routine testing for these four PFAS stops.
That matters because you cannot rebuild a limit later — through the "correct" process EPA says it
wants — without ongoing data. Rescind the requirement, and the record needed for any future decision
simply stops growing.
Voluntary disclosure won't fill the gap, because local disclosure doesn't last. Our town's water-quality
webpage posts only the current year's report; last year's is taken down when the new one goes up. To
check whether a system's PFAS levels are rising over time, a resident has to use the Internet Archive or
file a records request. Federal monitoring data, by contrast, stays in a federal database. That durability
is what rescission would remove for these four chemicals.
Request: If EPA rescinds these limits on legal grounds, keep the ongoing testing and public-reporting
requirements for these four PFAS in place until any new limit is finalized, and keep those results in a
lasting federal database. A rescission that also ends the data collection defeats the corrected process it
claims to make possible.