Rescission of Regulatory Determinations and Removal of Related Provisions for Four PFAS Substances (PFHxS, PFNA, HFPO–DA (GenX), and the Mixture of These Three PFAS Plus PFBS)

The commenter opposes the proposed rescission of drinking water standards for specific PFAS substances and the extension of compliance deadlines. They argue that the EPA should correct procedural defects rather than eliminating protections, citing concerns over public health, regulatory uncertainty, and wasted utility investment.

The commenter opposes the EPA's proposal to rescind drinking water standards for several PFAS compounds and extend compliance deadlines for PFOA and PFOS. They argue that these actions jeopardize public health and suggest that the EPA should provide technical assistance and funding to utilities instead of weakening protections.

Dr. Eric G. Roy, Head of Science at Culligan International, opposes the rescission of regulatory determinations for four PFAS substances. He argues that the rescission lacks a scientific basis, creates a "blind spot" for consumers regarding water safety, and urges the EPA to address utility cost concerns through funding and manageable timelines instead of removing regulations.

John Schacht, a wastewater utility engineer, provides professional feedback on the practical challenges of implementing PFAS treatment technologies. He emphasizes the need for robust manufacturing qualifications, traceability, and documentation to ensure that treatment systems are reliable and maintainable at full scale.

The Main Street Foundation's Center for Regulatory Analysis and Engagement (CRAE) supports the EPA's proposal to rescind the regulatory determinations for four PFAS substances due to procedural defects in the 2024 rule. They argue that the EPA must strictly follow the statutory sequence prescribed by the Safe Drinking Water Act, evaluate each contaminant individually based on its specific risk profile, and provide a transparent, evidence-based reconsideration process.

Two researchers from Arizona State University, submitting in their individual capacities, oppose the proposed rescission of PFAS standards. They argue that the current standards for PFHxS, PFNA, HFPO-DA, and PFBS are necessary to identify hazards that PFOA and PFOS standards alone do not capture, and they urge the EPA to retain these protections.

The Olivenhain Municipal Water District supports the EPA's proposal to rescind regulatory determinations for PFHxS, PFNA, HFPO-DA, and PFBS. They argue that the rescission is necessary for a scientifically sound process, will reduce compliance costs for water providers, and that public health is sufficiently protected by existing PFOA and PFOS regulations.

The National Congress of American Indians (NCAI) opposes the EPA's proposed rescission of PFAS drinking-water standards, arguing that the action is arbitrary and capricious under the Administrative Procedure Act. They contend that the EPA failed to adequately analyze the impacts on Tribal Nations, violated Executive Order 13175 regarding Tribal consultation, and requested that the EPA withdraw the rescission or conduct a structured consultation process.

The Tennessee Department of Environment and Conservation (TDEC) and the Tennessee Department of Health (TDH) support the retention of the current Maximum Contaminant Level (MCL) and Maximum Contaminant Level Goal (MCLG) of 10.0 ppt for PFHxS. They argue that recent sampling data shows detections exceeding this level in some Tennessee water systems and emphasize that PFHxS poses significant health risks due to its biopersistence and toxicity.