Comment submitted by Kaikea Blakemore

It appears the cost analysis of this proposal is likely incorrect. When factoring in true costs to public and environmental health this document appears to be missing lots of other true costs, extending the compliance deadline will likely cause harm to individuals and ecosystems, by potentially harming public and environmental health. In Section IV.A, discussing the baseline: "The quantified baseline results in Exhibit IV-1 of this preamble are not representative of all benefits and costs anticipated under the baseline. Due to occurrence, health, and economic data limitations, there are several adverse health effects associated with PFOA and PFOS (and other co-occurring PFAS) exposure and costs associated with treatment that the EPA could not estimate quantitatively." Followed by "the EPA qualitatively discussed additional adverse health effects, including reproductive effects, such as decreased fertility; increased high blood pressure in pregnant women; developmental effects or delays in children, including accelerated puberty, bone variations, or behavioral changes; increased risk of some cancers, including prostate, kidney, and testicular cancers; reduced ability of the body's immune system to fight infections, including reduced vaccine response; interference with the body's natural hormones; and increased cholesterol levels and/or risk of obesity." On the forgone-benefits estimate specifically (Section IV.B, near the end): "The EPA also acknowledges that a number of the long-term forgone benefits of increased PFAS exposure—such as premature mortality, higher medical expenses, lost productivity due to illness, and other reductions in welfare (measured in willingness-to-pay) which are linked to developmental and reproductive toxicity, immune system suppression, liver damage, thyroid disruption, and elevated risk of cancers—remain unquantified." On uncertainty in the public education control measure specifically: "Because of a lack of national level data regarding the effectiveness of public education activities geared towards the prevention of PFAS exposure, the EPA is not able to quantitatively assess the degree to which this control measure requirement would reduce the potential forgone benefits associated with the two-year exemption delay..." It appears that two of the six allowed "control measures" (public education and community outreach) don't reduce PFAS in water at all — and EPA admits it can't even estimate whether they reduce harm in any measurable way. A system could satisfy its legal exemption obligations using two measures that, by EPA's own admission, might do nothing quantifiable to protect public health from the risks regulation is proposing. Educating the public after the fact will not undo preventable harm from toxic water supplies. The compliance deadline should remain, and new regulations for the protection of America's water supply should be implemented. It is likely the cost will be shouldered by average American citizens in the cost of increased mortality and health expenses, and impacts to real estate and ecosystem services if water supplies are harmed. Additionally, public sentiment in terms of trusting water safety at the federal level in general call for more, not less regulation on the safety of our water.