IFB comments on proposed PFAS drinking water standards



Drinking water regulations surrounding per- and polyfluoroalkyl substances (PFAS) proposed by the U.S. Environmental Protection Agency (EPA) overlook cost and compliance challenges for rural communities, acording to Illinois Farm Bureau.

In comments submitted to EPA on May 30, IFB also raised concerns about the agency promulgating a rule when research and data about the topic is incomplete.

“Illinois farmers share concerns regarding the health impacts of PFAS exposure; however, research to prove causation is still under development,” IFB President Richard Guebert Jr. wrote. “We encourage this work to continue as there are many factors that must be considered when developing regulatory limits.”

Under the proposed rule, EPA would set a Maximum Contaminant Level (MCL) for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) at 4 parts per thousand (ppt). It would also designate a hazard index for perfluorononanoic acid (PFNA), PF perfluorohexane sulfonic acid (PFHxS), hexafluoropropylene oxide dimer acid and its ammonium salt (also known as Gen X chemicals) and perfluorobutane sulfonic acid (PFBS).

But because the costs the proposed rule will impose are likely underestimated, Guebert said EPA should both obtain accurate and proven data and change the proposed MCLs to properly balance costs and benefits.

He pointed to “significant uncertainty” about the health risks at the proposed MCLs for all six PFAS due to a gap in research studies and data on PFAS’ impacts on humans.

“We believe EPA needs to improve the transparency of their review of studies and update their assessments based on availability of human studies to ensure the limit they regulate is both in line with the best science on health impacts but also takes into consideration the feasibility of implementation,” Guebert wrote.

He further cited the World Health Organization recommending a PFOA or PFOS drinking water MCL of 100 ppt, respectively, and a total cap of 500 ppt for combinations of up to 30 PFAS — levels that are far higher than EPA’s proposed 4 ppt but were formulated using the same basic data the agency used.

And Guebert noted the cost-benefit analysis EPA prepared relies solely on national median income, a level “which is not representative of the entire country” and if codified into the rule would “negatively impact rural communities.”

The estimated annualized costs for the proposed MCL of 4 ppt for PFOA and PFOS total $1.8 billion and are more than double the costs EPA estimated in its analysis, according to Guebert. And legislation like the Infrastructure Investment and Jobs Act falls short of providing the funding for communities to cover that cost, he said.

The issue of limited funding will be especially compounded in rural communities which “have far less resources to address expensive federal regulatory requirements,” Guebert said, adding rural water utilities will “undoubtedly experience more challenges” in meeting the proposed 4 ppt MCL.

“Rural communities will incur extensive costs to obtain and install new technology. Then, uncertainty with testing availability/costs and lack of clarity with disposal methods/ costs only exacerbate our concerns,” Guebert wrote.

“It will be infeasible for many rural communities to meet the standards outlined in the short timeframe identified and the exorbitant costs will inevitably be handed down to the water users,” Guebert said.


Content for this story was provided by FarmWeekNow.com.