Regulatory Alert: AAAE to Host Second Discussion on EPA's Proposed Rule to Designate PFOA/PFOS as Hazardous Substances Under CERCLA

October 26, 2022

AAAE will be hosting our second virtual discussion with members on Wednesday, November 2, at 1“2 p.m. ET, to discuss the U.S. Environmental Protection Agency's (EPA) proposed rule that would designate two PFAS chemicals, PFOA and PFOS, as “hazardous substances“ under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), known as the Superfund law. You can sign up to receive a calendar invite for the meeting using the form here.

We appreciate everyone who was able to join us during our first meeting on October 7. During our final discussion before the close of the comment period, we will provide a brief overview of the proposed rule and its potential impacts for those who were not able to participate earlier this month. However, the primary purpose of the discussion will be to share additional details on AAAE's response to the proposal and ensure we are coordinating with any airports that may be planning to file their own comments. In addition, we want to solicit feedback from airports that have concerns, feedback, or other comments that they would like us to consider including in our response. You can use the form here to share that feedback with us. We greatly appreciate your participation and any contributions you can make to the conversation.

As a reminder, EPA has set Monday, November 7, as the date for airports, industry stakeholders, and the public to respond to the proposal. We will share AAAE's comment letter via Regulatory Alert after we submit the document to EPA. Please reach out to Justin Barkowski if you have any questions.

Resources on EPA's CERCLA Proposal
• EPA's Proposed Rule to Designate PFOA/PFOS as Hazardous Substances&nbsp;
• EPA's Press Release on the Proposed Rule&nbsp;
• EPA's Summary of the Proposed Rule&nbsp;
• EPA's Strategic Roadmap on PFAS (Oct. 2021)&nbsp;
• AAAE's September 6 Regulatory Alert&nbsp;on Deadline for Responding&nbsp;
• AAAE's August 26 Regulatory Alert&nbsp;on EPA's Proposed Rule&nbsp;
• AAAE's October 18 Regulatory Alert&nbsp;on EPA's Strategic Roadmap on PFAS&nbsp;