YOUR NAME WILL BE ADDED TO THE FOLLOWING LETTER:
Dear Administrator Michael S. Regan and Director Jennifer McLain,
In April 2018, the Ohio Environmental Council (“OEC”) submitted a petition for rulemaking to the U.S. EPA regarding regulation of PFAS under the Clean Water Act and Safe Drinking Water Act. The Trump Administration played procedural games with our petition, sending non-answer interim responses and proposing a PFAS Action Plan that largely ignored the greatest threats of PFAS pollution.
Today, on the three-year anniversary of the OEC’s submission of its Petition for Rulemaking on PFAS, we request the U.S. EPA reconsider our Petition and provide a formal response affirming the need for immediate regulatory action. The science has been more than certain for years: PFAS pose a real risk to human health and the environment.
In addition, we encourage the U.S. EPA to take the opportunity to provide the public with transparency surrounding our Petition for Rulemaking and the petitions of other organizations over the past four years. Beginning in early 2017, the agency stopped publicly posting petitions submitted for review. With the agency now under new leadership, the public deserves to see the petitions received and the decision-making processes that went into the agency’s consideration of those petitions.
Even since 2018, the data regarding PFAS has become more concrete. States like Michigan and Ohio have conducted extensive testing to determine the extent of PFAS pollution in their drinking water systems. Some communities have taken action, while others have been left behind by their elected officials.
We encourage the U.S. EPA to look at our Petition for Rulemaking with fresh eyes. In particular, we encourage Administrator Regan and Director McLain to closely consider the need to regulate PFAS as a class, rather than simply regulate PFOA or PFOS individually.
With these considerations in mind, the OEC petitions the EPA to take immediate action to propose, allow for public comment, and promulgate standards and regulations related to perfluoroalkyl substances under the aforementioned laws.
We thank you in advance for your prompt and diligent attention to this matter and look forward to your response.