Designation of PFOA and PFOS as CERCLA Hazardous Substances

  • Nov 7, 2022
  • Comment Letters

Agency: U.S. Environmental Protection Agency

Subject: Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA Hazardous Substances; EPA-HQ-OLEM-2019-0341

Letter excerpt:

The Association of California Water Agencies (ACWA) appreciates the opportunity to provide comments on the Environmental Protection Agency’s (EPA) proposal to designate PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). ACWA’s more than 460 public water agency members supply over 90 percent of the water delivered in California for residential, agricultural, and business uses. Potential liability from a proposed CERCLA designation and the associated costs are a serious concern for ACWA members. As a result, we ask EPA to delay the CERCLA proposal until a regulatory framework is put in place. Should EPA proceed with the rulemaking under CERCLA, we request EPA conduct a comprehensive Regulatory Impact Analysis before moving forward.

Download Comment Letter