Comment submitted by Saundra Holloway
AnonymousOpposeIndividual
Summary: Saundra Holloway, a private citizen from Yuma, Arizona, opposes the EPA's proposal to rescind and delay compliance deadlines for PFAS National Primary Drinking Water Regulations. She argues that the health risks and economic costs of PFAS contamination outweigh the compliance costs for industry and urges the EPA to uphold the 2024 standards.
Public Comment on the Proposed Repeal and Delay of PFAS National Primary Drinking Water Regulations
Docket ID: EPA-HQ-OW-2025-1742-0001
I am writing to express my strong opposition to the Environmental Protection Agency’s (EPA) proposed actions to rescind and reconsider the Maximum Contaminant Levels (MCLs) for several per- and polyfluoroalkyl substances (PFAS)—specifically PFHxS, PFNA, HFPO-DA, and PFBS—as well as the proposed petition option that would delay critical compliance deadlines for PFOA and PFOS. The EPA must uphold its core mission to protect public health and the environment by fully implementing and defending the 2024 final PFAS National Primary Drinking Water Regulation without delay.
The 2024 standards were established based on rigorous scientific evidence, corroborated by the Centers for Disease Control and Prevention (CDC) and state health departments. Decades of data link PFAS exposure to devastating health conditions, including testicular, kidney, and liver cancers, thyroid disease, pregnancy complications, low birth weights, reduced fertility, and immune system suppression. Because these "forever chemicals" bioaccumulate in human tissue and remain highly mobile and persistent in the environment, every single day compliance is delayed results in further toxic accumulation in the bodies of millions of Americans. Furthermore, evidence shows that short-chain PFAS variants, such as PFBS and PFHxS, are linked to severe health impacts and are notoriously difficult and costly to remove from public water supplies once contamination spreads.
The need for immediate, uniform federal standards is underscored by extensive data showing that PFAS contamination spans the entire country, heavily impacting both the Midwest and Western states. According to the U.S. Geological Survey (USGS), at least 45 percent of the nation's tap water contains one or more types of these chemicals, with the highest probabilities of exposure concentrated near urban centers, industrial corridors, and military installations across the Great Lakes region and Central and Southern California. In the Midwest, states like Michigan have identified thousands of confirmed contamination sites, forcing widespread testing and infrastructure overhauls. Similarly, in the West, California has faced extensive groundwater plumes from industrial facilities, landfills, and firefighting foam, prompting strict state-level notification thresholds long before federal action. Relying on state-by-state discrepancies or allowing a piecemeal approach leaves millions of Americans unprotected. Federal oversight via the 2024 MCLs is the only mechanism that ensures equitable access to clean drinking water regardless of geography.
Advocates for delaying these rules often cite compliance costs for industry, yet the economic toll of inaction on families and communities far outweighs these expenses. A 2017 study regarding groundwater contamination litigation demonstrated that localized PFAS contamination caused residential home values to plummet by 4.4 to 7.2 percent, directly harming family wealth and local tax bases. The medical and societal burden of treating illnesses stemming from daily PFAS exposure is equally catastrophic. Peer-reviewed research published in the journal Exposure and Health by investigators at the NYU Grossman School of Medicine reveals that daily PFAS exposure drives a massive economic strain, costing the United States between $5.5 billion and $63 billion annually in direct medical bills and lost worker productivity. Prioritizing industrial requests over public safety shifts this staggering financial burden from the corporate entities responsible for generating the pollution directly onto innocent taxpayers, healthcare consumers, and compromised public water utilities.
The EPA's proposal to roll back these rules directly contradicts federal health initiatives aimed at strengthening chemical oversight and protecting children's developmental health. The science is settled, the contamination is widespread, and the human and economic costs of delay are unacceptable. Americans deserve the peace of mind that the water coming out of their taps is safe. I strongly urge the EPA to withdraw this proposed deregulation, reject industry-led petitions for delay, and commit to fully enforcing the 2024 PFAS National Primary Drinking Water Regulation.
Respectfully submitted for the record,
Saundra Holloway, Yuma, Arizona