Comment submitted by Culligan International

Docket: EPA-HQ-OW-2025-0654 Submitted by: Eric G. Roy, Ph.D., Head of Science at Culligan International Much of my career has been spent working on water science, policy, and advocacy, inclusive of efforts to respond to public health emergencies like the Flint Lead Crisis and testifying before Congress as an expert witness on preventing similar crises in the future. While some have made the legal case that rescinding the MCLs for PFHxS, PFNA, GenX, and PFBS (in mixtures) violates the Safe Drinking Water Act's anti-backsliding requirement, utilities and their advocates are in favor of rescinding these contaminants because treatment is expensive. I would like to contribute, on the record, other ways the proposed rescission will impact the people drinking water regulations are designed to protect. Despite episodic crises like Flint, the public generally believes federal drinking water regulations fully protect them based on scientific standards. However, the EPA's rescission proposal admittedly does not have any scientific basis as seen in its proposal which notes the shift "is not based on any reassessment of the substantive findings" and that it is "solely based on its conclusion that the Agency legally erred." In fact, it states "the scientific literature and the EPA's health assessments have identified evidence linking these substances to adverse health effects," reinforcing the fact that the science did not change. This disclosure is buried in a regulatory document and not included in consumer-facing reports. The Consumer Confidence Report (CCR) was built to be a right-to-know instrument under the 1996 amendments to the Safe Drinking Water Act (SDWA). PFHxS, PFNA, GenX, and PFBS would be regularly measured and reported, as regulated contaminants in CCRs. If the proposed rescission passes, I am concerned nothing will backfill this testing requirement, creating a significant blind spot for consumers. The contaminants in review are openly highlighted in the media, and people rightfully want to know if they are in their water. Given the cost and complexity of testing, transferring the financial burden and accountability to concerned households is not the right solution. Rather, experts from municipal water providers should incorporate testing as part of routine annual reporting to the public, setting strong standards for the wellbeing of all. Given the above, I ask that the EPA reconsider the rescission proposal and solve the utilities' cost concerns directly, with manageable, transparent timelines and funding. As leaders, the United States has an opportunity to do what’s right in this moment and maintain the public’s trust. Respectfully submitted, Eric G. Roy, Ph.D. Head of Science Culligan International