
REGULATORY CORNER / CURRENTS
3
Extension Rule Interim Control
Measures. Systems with a PFOA
or PFOS sample at or above 12 ng/L
would be required to implement at
least two of six control measures
during the exemption period.
1 Provide water pitchers and a
two-year supply of filters certified
to reduce PFOA and PFOS levels.
2 Deliver alternative water supplies
with lower PFOA and PFOS levels
by distributing bottled water,
temporarily switching to a
new source,
or blending
water supplies.
3 Install, operate,
and maintain
point-of-use or
point-of-entry
devices certified
to decrease PFOA
and PFOS in all
customer locations.
4 Implement actions and plans to
decrease PFOA and PFOS levels
in drinking water sources via
source identification and
source control.
5 Distribute written public education
materials to consumers on PFOA
and PFOS exposure sources.
6 Conduct community education
and outreach activities on PFOA
and PFOS in drinking water.
Note that the control measures selected
cannot include options 5 and 6 only.
Control measures for systems
with PFOA and PFOS levels above
4 ng/L but below 12 ng/L would
not be required during the
exemption period.
Jan. 1 Apr. 26 Apr. 26 Apr. 26
2027 2029 2031
Initial monitoring begins
Compliance
monitoring begins
MCL compliance begins Potential PFOA and
PFOS MCL compliance
extension
Initial monitoring must be
completed and submitted
Public notification required
for MCL violations
2019-2026
Engage early and often with
your state primacy agency.
States will ultimately decide if they
want to allow for the federal exemption. Once
states obtain primacy, they may choose to shorten
or end an exemption granted by USEPA. Early
engagement can clarify expectations and
reduce uncertainty.
Continue advancing treatment
planning and implementation.
Do not pause or delay technology
evaluation, system design, construction, or system
commissioning while these two proposed rules are
being finalized.
Consider alternative project delivery
approaches. For capital improvement
projects, advance early work packages
or pre-procurement strategies to secure long-lead-
time items and reduce schedule risk.
Plan for interim actions. Utilities
may need to identify and implement
interim measures, such as raw water
blending, powdered activated carbon application,
and other available tools. Communicate with state
primacy agencies and customers about these
interim control strategies.
Establish a public communication
and outreach plan. Seeking a
compliance extension requires formally
certifying noncompliance, which may necessitate
public perception strategies.
Proposed changes may offer more time for
PFOA and PFOS compliance, but they do not
reduce the need for planning. The period for
public and written comments has passed;
however, utilities can still implement several
proactive measures to better navigate the
evolving PFAS regulatory landscape.
ACTIONS UTILITIES CAN
TAKE TO STAY AHEAD
Carollo Can Help
Carollo can help utilities understand
the proposed rules, coordinate with
state primacy agencies, prepare
extension applications, determine
treatment needs, design treatment
systems, advance procurement
and construction strategies, and
develop public outreach to foster
consumer trust while utilities
prepare for compliance.
PROPOSED PFAS MAXIMUM
CONTAMINANT LEVEL
RESCISSION RULE
This rule would rescind the MCLs
for perfluorohexane sulfonic acid
(PFHxS), perfluorononanoic
acid (PFNA), hexafluoropropylene
oxide dimer acid (HFPO-DA), and
hazard index (HI) mixtures that
include these three compounds
plus perfluorobutanesulfonic
acid (PFBS).
This rescission will not affect the
PFOA and PFOS regulation. NA,
HFPO-DA, and PFBS would
not be regulated beyond the
final date. USEPA emphasizes
that this change is not an
abandonment of concern
about these PFAS, but rather
a restart to consider regulating
them in the future with proper
scientific review and public input.
As of January 2026, only nine
systems nationwide exceeded
MCLs for PFHxS, PFNA, HFPO-DA,
and/or HI mixtures—indicating
that only a small percentage of
systems will be able to avoid
PFAS treatment under the MCL
rescission rule.
PFAS monitoring and data reporting milestones remain unchanged
by the proposed compliance extension and MCL rescission rules.