The Water & Health Advisory Council recently submitted formal comments to the U.S. Environmental Protection Agency’s National Drinking Water Advisory Council (NDWAC) regarding proposed revisions to the PFAS National Primary Drinking Water Regulation (NPDWR).
In our letter, we express strong support for science-based drinking water policy that safeguards public health while ensuring access to safe, affordable and reliable water for all communities. However, we raise serious concerns about the scientific and economic foundations of the EPA’s proposed rule.
Key Concerns Raised in Our Comment Letter
Uncertain Science – The proposed maximum contaminant levels (MCLs) for PFAS are based on inconsistent toxicological evidence, with wide-ranging expert opinions and limited consensus on health risks from low-level exposure.
Economic Underestimation – EPA’s cost analysis significantly underestimates real-world impacts, especially on small and disadvantaged water systems.
New UCMR 5 Data – The latest national monitoring data contradicts EPA’s projections, showing fewer people impacted and highlighting the disproportionate burden on smaller systems.
Funding Priorities – Overly stringent PFAS limits could divert critical funding from higher-priority drinking water issues such as lead, arsenic, and legionella.
Global Context – Other developed nations have adopted more balanced, pragmatic PFAS standards that align better with available science and treatment capabilities.
Why This Matters
If implemented without adjustment, the proposed PFAS rule could impose billions of dollars in costs on local water systems. The result could be reduced investment in infrastructure, deferred maintenance and slower progress on addressing known public health risks.
We urge EPA to re-evaluate the PFAS rule in light of evolving science and new national monitoring data. Regulations must deliver meaningful public health benefits while ensuring that communities, especially small and disadvantaged ones, can continue to provide reliable and affordable water.
Read our full comment letter to the EPA to explore our detailed analysis, data-driven findings, and policy recommendations.