July 20, 2026, came and went quietly. No press conference. No ceremony. Just a deadline on regulations.gov, and then it was over.
The public comment period on EPA's two proposed PFAS drinking water rules — one to rescind enforceable limits for four forever chemicals, the other to push compliance deadlines for PFOA and PFOS back to 2031 — closed after 60 days and a single virtual hearing on July 7. Whatever the public had to say about the future of their tap water, the agency has now heard it. What comes next is up to the rulemakers.
What the Rules Actually Do
It helps to be precise about what's on the table, because the details matter more than the headlines.
Rule 1: The Rescission. EPA proposes to rescind the 2024 drinking water limits for PFHxS, PFNA, HFPO-DA (the GenX family), and the Hazard Index that governs mixtures of those compounds plus PFBS. The agency's argument is procedural: Biden's EPA simultaneously proposed and finalized these standards, skipping the sequential notice-and-comment process the Safe Drinking Water Act requires. If finalized, the enforceable federal limits for these four compounds vanish. The underlying health science does not change. The contamination does not change. Only the legal obligation to do something about it disappears.
Rule 2: The Extension. The PFOA and PFOS limits stay at 4 parts per trillion — unchanged. But the compliance deadline would shift from 2029 to 2031 under a new federal exemption framework. Utilities could apply for two extra years to hit those numbers. This is the less dramatic of the two rules, but for any community whose water system is already behind on treatment upgrades, two more years of elevated exposure is not academic.
These are separate dockets with separate legal fates. Both will almost certainly face court challenges regardless of which direction EPA goes. The comment record — the real utility data, the local test results, the community testimony filed before Monday's deadline — will shape those fights.
Sludge, Science, and a Shrug
The same week, a parallel story underscored the pattern. On July 1, EPA released what it called "Draft Guidance for Reducing Risk from PFOA and PFOS in Biosolids" — non-binding recommendations for wastewater utilities and landowners dealing with PFAS-contaminated sewage sludge spread on farmland as fertilizer.
What the guidance replaced was more telling than what it contained. Under Biden, EPA had developed a draft health risk assessment finding that PFAS concentrations above 1 part per billion in biosolids increase cancer and other health risks. That threshold was low enough to functionally end most land application of sludge if implemented as regulation. The current EPA discarded that assessment and issued voluntary suggestions instead.
The agency also advised the public to "research" sludge companies themselves to protect against toxic exposure from home fertilizer products — a recommendation that Laura Dumais of Public Employees for Environmental Responsibility called "a bit bonkers."
The biosolids problem is not new and it is not small. Every sample of sewage sludge tested by regulators in Maine and Michigan has contained PFAS. A 2001 federal review found the same thing nationally. The United States spends billions annually treating wastewater, only to take the toxic byproduct and spread it on cropland — re-introducing to the food system and groundwater the very contaminants we just paid to remove. Farmers have been sickened. Livestock have died. Water supplies have been contaminated. Non-binding guidance does not change any of that.
UCMR 6: Monitoring More, but Not Everything
Not all the news pointed downward. On July 1, EPA also proposed the Sixth Unregulated Contaminant Monitoring Rule — UCMR 6 — which would require public water systems to collect data on 30 unregulated contaminants between 2028 and 2030. The list includes seven ultrashort-chain PFAS compounds, three pesticide metabolites, and twenty semi-volatile and purgeable organic compounds. EPA estimates the national cost at $33.7 million annually and will cover testing costs for systems serving 10,000 or fewer people.
This is genuinely useful work. UCMR monitoring is how we build the data foundation for future drinking water standards. You cannot regulate what you have not measured, and the inclusion of ultrashort PFAS — a class that slips through many conventional treatment systems — reflects real scientific priority.
But there was a conspicuous omission. Despite a formal petition from the governors of seven states — Connecticut, Delaware, Illinois, Maryland, Michigan, New Jersey, and Wisconsin — and supporting environmental organizations, EPA declined to include microplastics in UCMR 6. This, even though EPA itself added microplastics to the draft Sixth Contaminant Candidate List in April 2026, acknowledging them as a contaminant that "may require regulation." The agency cited concerns that including microplastics would prevent listing contaminants of higher public health priority — a judgment call that seven state governors evidently disagreed with.
The States Are Not Waiting
Here is what we find encouraging amid the turbulence: state-level action is accelerating, not retreating.
As the Ballard Spahr legal team documented in their June analysis, the federal pullback has not created a vacuum so much as it has created a patchwork — states moving faster, sometimes with stricter limits, to fill the space Washington is leaving open. Multiple states already had PFAS drinking water standards tighter than the 2024 federal rule. Others are now advancing legislation. Georgia introduced SB 577, the Coordinated PFAS Remediation Act, seeking to centralize the state's litigation and cleanup efforts for PFAS contamination in public waters and lands.
This is messy. A family's protection from forever chemicals should not depend on which side of a state line they live on. But it is also how progress often works in American environmental law — states serve as laboratories, building the evidence base and political will that eventually forces federal action. It happened with lead in gasoline, with acid rain, with drinking water standards themselves.
What We Are Watching
At EPR Foundation, our position is consistent: we follow the science, we follow the data, and we follow the water. Three things matter right now.
First, the comment record. Thousands of public comments were filed before Monday's deadline. Those comments — especially the ones from utilities with real cost data and communities with real exposure data — will be the foundation of whatever legal challenges follow. The administrative record is not just paperwork. It is the battlefield.
Second, the states. Every state that sets an enforceable PFAS standard, tests its private wells, or funds treatment upgrades is building durable protection that does not depend on the next election cycle. We will be tracking and mapping these actions.
Third, the sludge. The biosolids question is a sleeper issue with enormous consequences. When PFAS-laden sludge goes on farmland, it enters soil, groundwater, crops, and livestock. Non-binding guidance is not a solution. This issue needs enforceable limits — and if the federal government will not set them, states and courts will.
The comment window closed this week. The work did not.