As a community of water professionals, AWWA and its members share EPA’s desire to keep harmful levels of PFAS out of the nation’s drinking water. We support setting national drinking water standards for PFAS that protect all consumers, including the most sensitive populations, using the best available science. We stand for transparency, and support requirements for utilities to actively share PFAS monitoring results and other water quality information with consumers. We support sound scientific process to create regulations in which the public health benefits outweigh the costs. To date, a mosaic of state standards and guidelines have been established for multiple PFAS compounds at varying levels. As proposed, EPA’s standards would be stricter than any of those state regulations. AWWA appreciates EPA’s progress on this rulemaking as states, water systems, and consumers have been waiting for a clear and consistent path forward to address PFAS. AWWA will carefully review EPA’s proposal over the next 60 days and provide comments informed by the latest research and water system experiences. While it is too soon to offer a detailed analysis of the rule, a few important points stand out. Under the proposed rule, EPA would establish three new drinking water standards, including individual maximum contaminant levels (MCLs) for PFOA and PFOS and a third, grouped MCL for PFHxS, PFNA, PFBS, and GenX. The proposal requires drinking water systems to maintain water quality with PFAS levels below these MCLs, monitor regularly, and report violations and annual water quality to customers. To meet the proposed standards, more than an estimated 5,000 water systems will have to develop new water sources or install and operate advanced treatment; another 2,500 water systems in states with existing standards will need to adjust existing PFAS treatment systems. Advanced drinking water treatment systems for PFAS will require communities to make significant investments. A recent study conducted by Black & Veatch on behalf of AWWA estimated the national cost for water systems to install treatment to remove PFOA and PFOS to levels required by EPA’s proposal exceeds $3.8 billion annually. The vast majority of these treatment costs will be borne by communities and ratepayers, who are also facing increased costs to address other needs, such as replacing lead service lines, upgrading cybersecurity, replacing aging infrastructure and assuring sustainable water supplies. The 2021 Bipartisan Infrastructure Law provides increased federal water infrastructure investment, but the costs of meeting the proposed standards will far exceed the additional funding. At the low levels set in the EPA proposed standards, protecting source water from PFAS contamination – especially at locations where it is released into the environment -- is critical. AWWA urges EPA, Congress and other decision-makers to implement policies that keep harmful PFAS out of our drinking water supplies and our communities. AWWA looks forward to working collaboratively with EPA on a final PFAS standard that significantly advances public health protection. # # # Established in 1881, the American Water Works Association is the largest nonprofit, scientific and educational association dedicated to managing and treating water, the world’s most vital resource. With approximately 50,000 members, AWWA provides solutions to improve public health, protect the environment, strengthen the economy and enhance our quality of life.