Nineteen AGs Submitted Comments Supporting Expanded Reach of Public Water Systems Rule to PFAS Chemicals

Wisconsin Attorney General Joshua Kaul led a coalition of nineteen attorneys general in submitting comments on the Environmental Protection Agency’s (EPA) proposed update to the Unregulated Contaminant Monitoring Rule (UCMR) 5, a rule that would require public water systems to monitor for certain per- and polyfluoroalkyl (PFAS) substances. These “forever” chemicals, which are resistant to environmental degradation, have been linked to human health harms. In their comments, the AGs called for the development of a method to analyze the total level of all PFAS contamination in drinking water, rather than only testing for the 29 individual chemicals, and recommended that such testing be required. Additionally, the comments suggested lowering the levels at which the presence of PFAS must be reported in UCMR 5 and prioritizing environmental justice in conducting PFAS monitoring by, for example, collecting census data for each public water system’s service area to support future impact assessments.