ASDWA Joins AWWA and AMWA in Supporting New PFAS Reporting Requirements Under the Clean Air Act

On November 17, ASDWA, the American Water Works Association, and the Association of Metropolitan Water Agencies submitted comments to EPA in response to the Agency’s proposed revisions to the Air Emissions Reporting Requirements (AERR). Under the Clean Air Act, the proposed AERR amendments would require state, local, and certain tribal air agencies to report emissions data to the EPA and would require owners and operators of some facilities to report additional emissions data. The associations’ letter is supportive of the proposal as a regulatory avenue that can be utilized to tackle PFAS contamination and protect both surface and ground water sources of drinking water. The letter reiterates the associations’ support of “EPA’s overarching interest in addressing PFAS holistically to ‘get upstream of the problem’ and ‘hold polluters accountable’ as laid out in the Agency’s PFAS Roadmap.”  The three associations highlighted concerns with the proposed reporting threshold of 0.05 tons per year (tpy) and asked the Agency to lower the threshold to 0.005 tpy. The letter argues that even small releases of PFAS can cause widespread environmental contamination above state and/or federal PFAS regulatory levels and that the lower threshold would more accurately compile an inventory of facilities that have either manufactured, processed, or otherwise used PFAS and released these chemicals into the environment, potentially contaminating drinking water sources.