On Monday, July 7, EPA held its virtual public hearing on two proposed rules that would reshape federal PFAS drinking water regulation. One rule would rescind the enforceable limits for GenX (HFPO-DA), PFHxS, PFNA, and the Hazard Index mixture. The other would keep the 4-parts-per-trillion limits for PFOA and PFOS but push the compliance deadline from 2029 to 2031. The hearing ran from 11:00 a.m. to 7:00 p.m. Eastern. Written comments remain open through July 20 under Docket ID EPA-HQ-OW-2025-0654.
We have been tracking this closely. But the hearing itself — and the week around it — crystallized something that the legal briefs and Federal Register notices tend to obscure: the growing gap between federal rulemaking speed and the reality on the ground.
What the Hearing Revealed
EPA's rationale for the rescission is procedural. The agency argues that the Biden-era rule for PFHxS, PFNA, GenX, and the Hazard Index did not follow the sequential cost-benefit process the Safe Drinking Water Act requires. EPA has said it may re-regulate these compounds through what it calls a “lawful process,” possibly with more stringent standards. That is not reassurance — it is a timeline reset. Re-regulation could take years.
The environmental and public health groups who testified were blunt. The Environmental Working Group has estimated that 176 million Americans are exposed to PFAS in their tap water. The Environmental Defense Fund emphasized that PFAS are “highly toxic, even at very low levels,” linked to liver damage, cancers, and developmental harm in children and pregnant women. Earthjustice organized a guide specifically to help people participate in the hearing and comment period.
But there was another constituency that spoke up — one that doesn't fit neatly into the pro-regulation or anti-regulation camps: the water utilities and testing laboratories that have already spent real money preparing for these standards.
The Sunk-Cost Problem
This is the part that gets lost in the policy debate. When EPA finalized the PFAS drinking water rule in April 2024, it triggered an investment cycle. Utilities began evaluating treatment technologies — granular activated carbon, ion exchange, reverse osmosis. Testing laboratories expanded analytical capacity for EPA Methods 533 and 537.1. Procurement timelines were set. Budgets were approved.
Now EPA is proposing to remove four of the six regulated compounds. For utilities, the compliance-extension to 2031 for PFOA and PFOS is manageable — more time to build is rarely unwelcome. But the rescission of GenX, PFHxS, and PFNA limits creates a different problem: utilities that serve communities with known contamination by those specific compounds now face a choice. Continue investing in treatment for chemicals the federal government may no longer require them to address, or pause and wait.
For the labs, it is even more pointed. As one trade publication noted this week, the rescission proposal “raises questions for utilities and laboratories that have already built out testing capacity.” Lab capacity for PFAS analysis was a genuine bottleneck two years ago. Some of that capacity was built specifically to meet the now-threatened federal standards. If those standards disappear, the business case for maintaining that capacity weakens — even though the contamination itself does not.
States Are Not Waiting
We covered this dynamic in depth last week — the states stepping into the gap left by federal retreat. But a few data points from this week are worth noting. Nearly 100 state PFAS bills have been introduced across 17 states in 2026 alone, with another 280 carried over from 2025. These range from product bans to water remediation funding to impact studies. In March, New Mexico approved regulations implementing its Per- and Poly-Fluoroalkyl Substances Protection Act, including phased bans on PFAS-containing products. North Carolina's state GenX standard — born from the Cape Fear River contamination crisis, which we profiled in June — remains in force regardless of what happens at the federal level.
The result is a patchwork. If you live in a state with its own PFAS standards, the federal rescission may not affect your drinking water protections. If you don't, it could mean years without enforceable limits for compounds your water system may be serving you right now.
Meanwhile, the Monitoring Moves Forward
In a development that reads like bureaucratic irony, EPA on July 1 proposed the Sixth Unregulated Contaminant Monitoring Rule (UCMR 6), which would require public water systems to collect data on 30 unregulated contaminants — including seven ultrashort organofluorine compounds, several of which are PFAS — between 2028 and 2030. The agency is simultaneously removing enforceable limits for some PFAS while proposing to monitor for others.
This is not necessarily contradictory. UCMR data feeds future regulatory decisions — it is how EPA builds the occurrence database to justify setting (or not setting) maximum contaminant levels. But the timing underscores a pattern: the federal apparatus for studying PFAS continues to expand, while the apparatus for actually regulating them contracts.
One notable absence from UCMR 6: microplastics. Seven state governors petitioned EPA to include them. EPA declined, citing the lack of a validated federal test method — even though California has already adopted a standardized state methodology. Another gap. Another state filling it.
Ten Days Left
The written comment period closes July 20. If you work in water treatment, environmental consulting, public health, or if you simply drink water from a public system in a state without its own PFAS standards, this is your window.
We are not in the business of telling people what to say. But we will say this: the most effective public comments are specific, factual, and grounded in real experience. If your utility has already invested in PFAS treatment, say so. If your community has documented GenX or PFHxS contamination, cite the data. If you are a lab that built analytical capacity to meet these standards, explain what the rescission means for your operations.
The docket is at regulations.gov under EPA-HQ-OW-2025-0654. Comments can be submitted online or mailed. This is one of the few moments in the regulatory process where public input is not just invited — it is required to be considered in the final rule.
Where We Stand
At EPR Foundation, we believe that enforceable drinking water standards for known toxic contaminants are a baseline, not a ceiling. The science on GenX, PFHxS, and PFNA is not in dispute — these compounds are harmful. The question is procedural, not toxicological. Whether the 2024 rule followed the precise statutory steps is a legal argument. Whether these chemicals are in people's water and making them sick is a scientific fact.
We will continue to track both the federal comment process and the state-level responses. The patchwork is growing. Whether that represents resilience or fragmentation depends on where you live — and that, frankly, is not good enough.