Clean Water Current

NACWA reminds all its members that the next few days are the last chance to file comments on EPA’s proposed rule to list PFOA and PFOS – the two most common PFAS chemicals – as hazardous substances under the federal Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).  The comment deadline remains Nov. 7 after EPA recently denied multiple requests for a deadline extension.   

The proposed rule, if finalized, will present significant potential legal and financial liabilities for public clean water utilities.  It does not currently contain an exemption for clean water agencies despite the repeated advocacy efforts by NACWA and other water sector partners to secure one.   

NACWA has developed a robust set of comments outlining the significant flaws with the proposal and its potential negative impacts on the public clean water sector.  NACWA encourages all utilities to file their own comments as well and is happy to share a copy of the Association’s comments with NACWA members to aid them in developing their own.  Any comments from individual utilities to EPA expressing concern with the proposal – whether detailed or very short – will be helpful. 

If you would like a copy of NACWA’s comments or have questions about how best to develop your own utility comments, please contact Emily Remmel, NACWA’s Director of Regulatory Affairs.