Comment submitted by Annika Bennion
AnonymousOpposeIndividual
Summary: The commenter opposes the proposed two-year extension for PFOA and PFOS compliance deadlines, arguing that the delay significantly understates the loss of public health benefits. They express concern that the exemption framework ignores systems with concentrations between 4-12 ppt and lacks rigorous documentation requirements to ensure extensions are only granted for genuine hardships.
I am writing to oppose the two-year extension proposal. EPA significantly understates the harm to public health and cost of continued exposure that will result from further delay.
EPA has previously estimated the health benefits of removing PFOA and PFOS from drinking water at approximately $1.17 billion annually, based on only three health endpoints (reduced birth weight, cardiovascular disease, and kidney cancer), while acknowledging that numerous additional health benefits remain unquantified. A two-year delay represents a substantial loss in health benefits, which the proposed rule appears to significantly understate while comparing foregone benefits against the claimed cost savings of the proposal.
In addition, the EPA has set the Maximum Contaminant Level Goal (MCLG) for both PFOA and PFOS at zero, based on cancer risk, while setting the enforceable Maximum Contaminant Level (MCL) at 4.0 ppt. Yet the proposed exemption framework would require only systems at or above 12 ppt, three times the legal limit, to implement interim mitigation measures.
There exists no adequate scientific, legal, or public-health basis for treating systems at 4–12 ppt, which are already at or above the enforceable MCL and far exceed the health-based goal of zero, as low priority for interim protective action. Accordingly, I request that EPA publish an estimate of the number of public water systems and total population served that fall within the 4–12 ppt range, and would therefore receive no mandated interim protection under this proposal.
Finally, the proposal does not specify rigorous documentation requirements demonstrating why each system cannot comply by the original deadline. Without such requirements, the exemption mechanism risks granting unnecessary extensions to systems that could comply on time, rather than those facing genuine hardship, at the cost to the individual.
I urge EPA to withdraw the proposed extension. While some water systems may need additional federal support to comply with PFAS standards, extending the compliance deadline for chemicals linked to cancer and other serious health risks - which millions of Americans on public water systems, including pregnant women and children, continue to be exposed to - is not a defensible response to administrative inconveniences.